mpca air quality permits guide part 1 defining your facility

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MPCA Air QualityPermits Guide

Part 1Defining Your Facility

Prepared by: Air Quality Staff

Minnesota Pollution Control Agency

520 Lafayette RoadSt. Paul, MN 55155

March 1994 Revised September 1998

Part 1 AcknowledgmentsMarch 1994 version:Author: Barbara Conti

Contributors: Lori Bartels Leo RaudysDick Cordes Kathy SeeburgerBernadette Halverson Toni StevensJulie Hendricks Mark StrangeMary Hoffman Phyllis StrongBarb Loida Neesha WolfMPCA Air Quality DivisionMinnesota Office of the Attorney General

Project Manager: Leo Raudys

Editor: Valerie Williams, VKW Consulting

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

Additional assistance providedby:

Rust Environment & Infrastructure

1998 revision:Coordinator: Toni Volkmeier

Contributors: Peggy Bartz Bonnie Nelson

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

MPCA Air Quality Permits GuidePart 1: Defining Your Facility -- Revision 1, September 1998 Page i

Table of ContentsPreface To The Guide......................................................................................vFocus Of Part 1 .............................................................................................vii1.0 What Is A Permit?....................................................................................1-12.0 What Air Pollutants Are Regulated By The MPCA?..............................2-12.1 Criteria pollutants................................................................................................... 2-12.2 Volatile Organic Compounds (VOCs) ................................................................... 2-22.3 Hazardous Air Pollutants (HAPs) .......................................................................... 2-42.4 Other regulated pollutants ...................................................................................... 2-4

3.0 Steps For Completing A Permit Application .........................................3-14.0 How Is Your Facility Defined? ................................................................4-14.1 What are your emission points? ............................................................................. 4-14.2 What are your emission units? ............................................................................... 4-24.3 How should you describe your operations?............................................................ 4-3

5.0 What Is Potential To Emit (PTE)?...........................................................5-15.1 How do you calculate Potential to Emit (PTE)? .................................................... 5-1

5.1.1 What references can you use to calculate PTE?......................................... 5-25.1.2 Examples of potential emissions calculations............................................ 5-35.1.3 What is the next step after calculating the PTE of your emission units? ... 5-85.1.4 What about fugitive emissions? ................................................................. 5-95.1.5 What if your PTE is below the thresholds?................................................ 5-10

5.2 Do you need any other emissions data? ................................................................. 5-115.2.1 What are your actual emissions? ................................................................ 5-11

5.3 How can you limit your Potential to Emit (PTE)? ................................................. 5-125.3.1 What about your air pollution control equipment? .................................... 5-125.3.2 What if you do not want to be subject to federal regulations? ................... 5-12

5.3.2.1 What are acceptable options for synthetic minor limits? ............... 5-13

6.0 What Rules And Regulations Apply To You? ........................................6-16.1 What are the federal regulations?........................................................................... 6-1

6.1.1 National Ambient Air Quality Standards (NAAQS).................................. 6-16.1.1.1 State Implementation Plan ............................................................. 6-2

6.1.2 National Emission Standards for Hazardous AirPollutants (NESHAPs) ............................................................................... 6-2

6.1.3 New Source Review (NSR)........................................................................ 6-36.1.3.1 Does NSR apply to your facility?................................................... 6-46.1.3.2 What is required for NSR? ............................................................. 6-5

6.1.4 New Source Performance Standards (NSPS)............................................. 6-66.1.4.1 An example of an NSPS................................................................. 6-7

MPCA Air Quality Permits GuidePart 1: Defining Your Facility -- Revision 1, September 1998 Page ii

6.1.5 Acid rain..................................................................................................... 6-76.1.6 Stratospheric ozone protection ................................................................... 6-76.1.7 Compliance assurance monitoring ............................................................. 6-8

6.2 What are the Minnesota rules? ............................................................................... 6-86.2.1 Air Quality permit rule ............................................................................... 6-96.2.2 Environmental review program.................................................................. 6-96.2.3 Standards of performance for stationary sources ....................................... 6-106.2.4 Emission inventory and air quality emission fees ...................................... 6-106.2.5 Performance testing for emissions ............................................................. 6-11

7.0 How Do You Maintain Flexibility In Your Operations?.........................7-17.1 What is operational flexibility? .............................................................................. 7-1

7.1.1 Alternative operating scenarios .................................................................. 7-17.1.2 Emission trading......................................................................................... 7-2

8.0 What If You Have Confidential Material In An Application? ................8-19.0 What Is In A Complete Permit Application?..........................................9-19.1 Why is a "complete" application important?.......................................................... 9-19.2 When were complete permit applications due?...................................................... 9-29.3 What happens to your application at the MPCA? .................................................. 9-3

10.0 Case Study -- Blue Ox Woodworks........................................................10-110.1 History of Blue Ox Woodworks............................................................................. 10-110.2 Blue Ox Woodworks Emission Unit Information.................................................. 10-2

10.2.1 Boilers ........................................................................................................ 10-210.2.2 Milling operations ...................................................................................... 10-310.2.3 Painting operations..................................................................................... 10-610.2.4 Diesel generator.......................................................................................... 10-710.2.5 Fugitive dust emissions .............................................................................. 10-710.2.6 Insignificant activities ................................................................................ 10-7

10.3 Blue Ox Woodworks emission calculations........................................................... 10-710.3.1 Wood boiler #1 calculations....................................................................... 10-810.3.2 New boiler #2 calculations ......................................................................... 10-910.3.3 Milling equipment calculations.................................................................. 10-1110.3.4 Painting equipment calculations................................................................. 10-1110.3.5 Diesel generator calculations...................................................................... 10-1910.3.6 Summary of all potential to emit calculations............................................ 10-1910.3.7 Proposed permit conditions and operating limits....................................... 10-20

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

FIGURESFigure 1-1 What Type of Air Emission Permit Do You Need?................................... 1-2Figure 3-1 The Permit Application Process............................................................. 3-1Figure 9-1 Process to Issue an Air Emission Permit for a Total Facility.................... 9-4

TABLES

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

APPENDIX 1

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

APPENDIX 2

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

APPENDIX 3

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

APPENDIX 4

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

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

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

ACRONYMSGLOSSARY

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

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

Part 1: Defining Your Facility shows how to describe your equipment and quantify itsemissions. After defining your facility, you may or may not need to apply for a permit.

Part 2: Determining Compliance tells you how to prepare the compliance portion of your airemission permit application.

Part 3: Making Changes explains what air quality rules and regulations apply when makingchanges at your facility and how the change affects your air emission permit.

If you have not already done so, you may find it helpful to read MPCA's booklet, Getting Started,as a first step. It introduces you to Minnesota's air quality permit program and offers an overviewof the permit application process.

Please take your time going through each part of the Guide. Do not expect to read all three partsin one day. You will find some things that do not apply to your facility. For this reason, youprobably will not need to read every section in detail.

To help you define key terms, each part of the Guide contains a glossary and an acronym list. Acase study at the end of each part of the Guide provides examples of how a fictitious facility,Blue Ox Woodworks, completed an air emission permit application. To answer your questionsfor help, phone numbers are given in the Focus section of each part. In addition, orderinginformation is offered in the Appendix of Part 1 should you want copies of the air quality rulesand regulations.

IMPORTANT NOTE: The MPCA has tried to make the Air Quality Permits Guide as completeas possible, however, it is not a substitute for the rules and regulations themselves. The Guidewill be revised periodically, but it will not be updated each time a specific requirement is revisedor added. It is your responsibility to find out which requirements apply to your facility.

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

FOCUS OF PART 1Welcome to Part 1: Defining Your Facility of the MPCA Air Quality Permits Guide. The Guideis an introduction to the Minnesota Pollution Control Agency (MPCA) and its Air Quality (AQ)rules. Under the MPCA rules, your facility may need an air emission permit. The Guide will helpyou find out whether your facility needs a permit and offers direction for completing a permitapplication.

Part 1 helps you:

• Define your sources of air emissions• Calculate your air emissions• Determine what rules apply• Assemble your descriptions and calculations for an application (if one is needed)

If you have questions about the material covered in Part 1, you are welcome to call any of thesenumbers for help. You may also write to the MPCA for information.MPCA Air Permit Technical Advisor1-800-MinnAir (1-800-646-6247) or(651) 282-5844

Responds to questions about rules or applying forair emissions permits

MPCA Air Permit Document Coordinator(651) 282-5843

Can send a copy of the Air Quality PermittingRules, application forms, fact sheets.

MPCA Small Business TechnicalAssistance Program(651) 282-5847 or 1-800-657-3938

Helps business with fewer than 100 employees tounderstand the air quality rules and completepermit applications

Training Registration1-800-571-7227

Provides information on available classes andtraining sessions

Air Quality Small Business Ombudsman(651) 297-8615 or 1-800-985-4247

Provides confidential assistance to smallbusinesses; helps to resolve complaints anddisputes

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

Assists with pollution prevention

TTY(651) 282-5332 or 1-800-657-3864

Teletypewriter for persons withhearing impairment

Minnesota Pollution Control AgencyAir Quality Permit Technical Advisor520 Lafayette RoadSt. Paul, Minnesota 55155

Mailing Address

MPCA Air Quality Permits GuidePart 1: Defining Your Facility -- Revision 1, September 1998 Page 1-1

1.0 WHAT IS A PERMIT?A permit is a regulatory document that is legally enforceable. An air emission permit spells outthe process equipment and air pollution control equipment you have and the rules or regulationsthat apply to your facility. Your air emission permit also includes operational requirements,emission limits, and monitoring requirements for your facility.

A Part 70 permit is a type of air emission permit that the MPCA issues to implement certainfederal requirements. "Part 70" is a section in the Code of Federal Regulations for theProtection of the Environment. Because of the requirements set by the federal Clean Air ActAmendments of 1990, all states are now required to have Part 70 permit programs. Your facilityis a Part 70 source if its potential to emit air pollutants meets or exceeds specific emissionthresholds. A Part 70 permit is valid for five years, then it must be renewed.

A state permit is issued to facilities that have the potential to emit smaller amounts of airpollutants than Part 70 sources. State permits generally do not expire. Requirements forshowing compliance under state permits may be less extensive than for Part 70 permits.

You may also qualify for a general permit. General permits cover a group of similar facilities,such as asphalt plants or construction aggregate producers. A general permit requires lessindividual processing by the MPCA than a permit developed to meet unique requirements foryour facility. Because of this, a general permit may be quicker to obtain. A general permit canbe written as either a state permit or a Part 70 permit.

A fourth type of permit is a registration permit. Registration permits are simple, one-pagepermits for some facilities whose actual emissions are low, and which are not subject to complexfederal regulations. Typical facilities qualifying for a registration permit include auto body shopsand schools operating boilers for heat. Refer to the Registration Permit Handbook, availablefrom the Permit Document Coordinator, for more detailed information on registration permits.

Figure 1-1 illustrates the process for deciding what type of permit your facility needs. Othersections of Part 1 will define the types of permits and provide overall direction for completingthe permit application. Section 10.0, a case study created by the MPCA, offers an overview ofthe permit application process from the applicant's viewpoint.


Figure 1-1 What Type of Air Emission Permit Do You Need?

A facility located in Minnesota, emitting anyair pollutant at any rate

�� No

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

�� No ��

Is your PTE of any criteria pollutant ≥100tons per year (tpy)? Is your PTE of any oneHAP ≥ 10 tpy? Is your PTE of anycombinations of HAPs ≥ 25 tpy?

Yes

��Facility is required to obtain a Part 70

Permit

�� No �� Optional

�� No Can the source take permit limits toqualify for a Federally Enforceable

(Synthetic Minor) State Permit?

�� No ��Yes

�� No ��Yes

Is a unit at the facility subject to a 40 CFRpart 60 or 61 Requirement, or a SIP* ��

Required Permit? Yes

�� No Facility is required to obtain a StatePermit

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

≥ 100 tpy of VOC?

�� No ��YesNo Permit Required (Source must stillcomply with all applicable standards.)

State Individual orGeneral or

Registration Permit

* State Implementation Plan (applies to 25 facilities statewide)


2.0 WHAT AIR POLLUTANTS ARE REGULATED BY THE MPCA?

2.1 Criteria pollutants

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

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

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

• Small particulate matter (PM10 – particulate matter less than 10 microns in size) can beinhaled, causing irritation or respiratory illness.

• Carbon monoxide (CO) decreases the ability of the blood to carry oxygen.

• Lead (Pb) can cause anemia, brain damage and nervous system damage.

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

2.2 Volatile Organic Compounds (VOCs)

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


Table 2-1CHEMICALS NOT CONSIDERED VOLATILE ORGANIC COMPOUNDS (VOCs)

A. methane;B. ethane;C. 1,1,1-trichloroethane (methyl chloroform);D. 1,1,2-trichloro-1,2,2-trifluoroethane (CFC-113a);E. methylene chloride (dichloromethane);F. trichlorofluoromethane (CFC-11);G. dichlorodifluoromethane (CFC-12);H. chlorodifluoromethane (HCFC-22);I. trifluoromethane (HFC-23b);J. 1,2-dichloro-1,1,2,2-tetrafluoroethane (CFC-114);K. chloropentafluoroethane (CFC-115);L. 1,1,1-trifluoro-2,2-dichloroethane (HCFC-123c);M. 1,1,1,2-tetrafluoroethane (HFC-134ad);N. 1,1-dichloro-1-fluoroethane (HCFC-141b);O. 1-chloro-1,1-difluoroethane (HCFC-142b);P. 2-chloro-1,1,1,2-tetrafluoroethane (HCFC-124);Q. pentafluoroethane (HFC-125);R. 1,1,2,2-tetrafluoroethane (HFC-134);S. 1,1,1-trifluoroethane (HFC-143a);T. 1,1-difluoroethane (HFC-152a);U. parachlorobenzotrifluoride (PCBTF);V. cyclic, branched, or linear completely methylated siloxanes;W. acetone;X. perchloroethylene (tetrachloroethylene);Y. 3,3-dichloro-1,1,1,2,2-pentafluoropropane (HCFC-225ca);Z. 1,3-dichloro-1,1,2,2,3-pentafluoropropane (HCFC-225cb);AA. 1,1,1,2,3,4,4,5,5,5-decafluoropentane (HFC 43-10mee);BB. perfluorocarbon compounds which fall into these classes:

(1) cyclic, branched, or linear completely fluorinated alkanes;(2) cyclic, branched, or linear completely fluorinated ethers with no unsaturations;(3) cyclic, branched, or linear completely fluorinated tertiary amines with no unsaturations; and(4) sulfur-containing perfluorocarbons with no unsaturations and with sulfur bonds only to

carbon and fluorine;


Table 2-1, continuedCHEMICALS NOT CONSIDERED VOLATILE ORGANIC COMPOUNDS (VOCs)

CC. difluoromethane (HFC-32);DD. ethylfluoride (HFC-161);EE. 1,1,1,3,3,3-hexafluoropropane (HFC-236fa);FF. 1,1,2,2,3-pentafluoropentane (HFC-245ca);GG. 1,1,2,3,3-pentafluoropropane (HFC-245ea);HH. 1,1,1,3,4-pentafluoropentane (HFC-245eb);II. 1,1,1,3,3-pentafluoropentane (HFC-245fa);JJ. 1,1,1,2,3,3-hexafluoropropane (HFC-236ea);KK. 1,1,1,3,3-pentafluorobutane (HFC-365mfc);LL. chlorofluoromethane (HCFC-31);MM. 1,2-dichloro-1,1,2-trifluoroethane (HCFC-123a);NN. 1 chloro-1-fluoroethane (HCFC-151a);OO. 1,1,1,2,2,3,3,4,4-nonafluoro-4-methoxy-butane;PP. 2-(difluoromethoxymethyl)-1,1,1,2,3,3,3-heptafluoropropane;QQ. 1-ethoxy-1,1,2,2,3,3,4,4,4-nonafluorobutane;RR. 2-(ethoxydifluoromethyl)-1,1,1,2,3,3,3-heptafluoropropane;SS. methyl acetateTT. any other compound listed in table 1, as amended, of the United States Environmental

Protection Agency's Recommended Policy on Control of Volatile Organic Compounds, FederalRegister, volume 42, page 35314, July 8, 1977; or

UU. any other compound determined by the United States Environmental Protection Agency to benegligibly photochemically reactive, upon publication of the determination in the FederalRegister.

a CFC = chlorofluorocarbonb FC = fluorocarbonc HCFC = hydro-chlorofluorocarbond HFC = hydro-fluorocarbon


2.3 Hazardous Air Pollutants

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

2.4 Other regulated pollutants

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


Table 2-2188 HAZARDOUS AIR POLLUTANTS

75070 Acetaldehyde60355 Acetamide75058 Acetonitrile98862 Acetophenone53963 2-Acetylaminofluorene107028 Acrolein79061 Acrylamide79107 Acrylic acid107131 Acrylonitrile107051 Allyl chloride92671 4-Aminobiphenyl62533 Aniline90040 o-Anisidine1332214 Asbestos

71432 Benzene92875 Benzidine98077 Benzotrichloride100447 Benzyl chloride92524 Biphenyl117817 Bis (2-ethylhexyl) phthalate (DEHP)542881 Bis (chloromethyl) ether75252 Bromoform106990 1,3-Butadiene

156627 Calcium cyanamide133062 Captan63252 Carbaryl75150 Carbon disulfide56235 Carbon tetrachloride463581 Carbonyl sulfide120809 Catechol133904 Chloramben57749 Chlordane7782505 Chlorine79118 Chloroacetic acid532274 2-Chloroacetophenone108907 Chlorobenzene510156 Chlorobenzilate67663 Chloroform107302 Chloromethyl methyl ether126998 Chloroprene1319773 Cresols/Cresylic acid (isomers and mixture)95487 0-Cresol108394 m-Cresol106445 p-Cresol98828 Cumene

94757 2,4-D, salts and esters3547044 DDE334883 Diazomethane132649 Dibenzofurans96128 1,2-Dibromo-3-chloropropane84742 Dibutylphthalate106467 1,4-Dichlorobenzene(p)91941 3,3'-Dichlorobenzidene111444 Dichloroethyl ether (Bis(2-chloroethyl)either)542756 1,3-Dichloropropene62737 Dichlorvos111422 Diethanolamine121697 N,N-Diethyl aniline (N,N- Dimethylaniline)64675 Diethyl sulfate119904 3,3-Dimethoxybenzidine

60117 Dimethyl aminoazobenzene119937 3,3-Dimethyl benzidine79447 Dimethyl carbamoyl chloride68122 Dimethyl formamide57147 1,1 Dimethyl hydrazine131113 Dimethyl phthalate77781 Dimethyl Sulfate534521 4,6-Dintro-o-cresol, and salts51285 2,4-Dinitrophenol121142 2,4-Dinitrotoluene123911 1,4-Dioxane (1.4-Diethyleneoxide)122667 1,2-Diphenylhydrazine

106898 Epichlorohydrin (1-Chloro-2,3-epoxypropane)106887 1,2-Epoxybutane140885 Ethyl acrylate100414 Ethyl benzene51796 Ethyl carbamate (Urethane)75003 Ethyl chloride (Chloroethane)106934 Ethylene dibromide (Dibromoethane)107062 Ethylene dichloride (1,2- Dichloroethane)107211 Ethylene glycol151564 Ethylene imine (Aziridine)75218 Ethylene oxide96457 Ethylene thiourea75343 Ethylidene dichloride (1,1-Dichloroethane)

50000 Formaldehyde

76448 Heptacholor118741 Hexachlorobenzene87683 Hexachlorobutadiene77474 Hexachlorocyclopentadiene67721 Hexachloroethane822060 Hexamethylene-1,6-diisocyanate680319 Hexamethylphosphoramide110543 Hexane302012 Hydrazine7647010 Hydrochloric acid7664393 Hydrogen flouride (hydrofluoric acid)123319 Hydroquinone

78591 Isophorone

58899 Lindane (all isomers)

108316 Maleic anhydride67561 Methanol72435 Methoxychlor74839 Methyl bromide (Bromomethane)74873 Methyl chloride (Choromethane)71556 Methyl chloroform (1,1,1-Trichloroethane)78933 Methyl ethyl ketone (2-Butanone)60344 Methyl hydrazine74884 Methyl iodide (Iodomethane)108101 Methyl isobutyl ketone (Hexone)624839 Methyl isocyanate80626 Methyl methacrylate1634044 Methyl tert butyl ether101144 4,4-Methylene bis (2-chloroaniline)75092 Methylene chloride (Dichloromethane)


Table 2-2, continued

101688 Methlene diphenyl diisocyanate (MDI)101779 4,4'-methylenedianiline

91203 Naphthalene98953 Nitrobenzene92933 4-Nitrobiphenyl100027 4-Nitrophenol79469 2-Nitropropane684935 N-Nitroso-N-methylurea62759 N-Nitrosodimethylamine59892 N-Nitosomorpholine

56382 Parathion82688 Pentachloronitrobenzene (Quintobenzene)87865 Pentachlorophenol108952 Phenol106503 p-Phenylenediamine75445 Phosgene7803512 Phosphine7723140 Phosphorus85449 Phthalic anhydride1336363 Polychlorinated biphenyls (aroclors)1120714 1,3-Propane sultone57578 beta-Propiolactone123386 Propionaldehyde114261 Propoxur (Baygon)78875 Propylene dichloride (1,2-Dichloropropane)75569 Propylene oxide75558 1,2-Propylenimine (2-Methyl aziridine)

91225 Quinoline106514 Quinone

100425 Styrene96093 Styrene Oxide

1746016 2,3,7,8-Tetrachlorodibenzo-p-dioxin79345 1,1,2,2-Tetrachloroethane127184 Tetrachloroethylene (Perchloroethylene)7550450 Titanium tetrachloride

108883 Toluene95807 2,4-Toluene diamine584849 2,4-Toluene diisocyanate95534 o-Toluidine8001352 Toxaphene (chlorinated camphene)120821 1,2,4-Trichlorobenzene79005 1,1,2-Trichloroethane79016 Trichloroethylene95954 2,4,5-Trichlorophenol88062 2,4,6-Trichlorophenol121448 Triethylamine1582098 Trifluralin540841 2,2,4-Trimethylpentane

108054 Vinyl acetate593602 Vinyl bromide75014 Vinyl chloride75354 Vinylidene chloride (1,1-Dichloroethylene)

1330207 Xylenes (isomers and mixtures)95476 o-Xylenes108383 m-Xylenes106423 p-Xylenes

COMPOUNDS0 Antimony compounds0 Arsenic compounds (inorganic including arsine)0 Beryllium compounds0 Cadmium compounds0 Chromium compounds0 Cobalt compounds0 Coke oven emissions0 Cyanide compounds0 Glycol ethers0 Lead compounds0 Manganese compounds0 Mercury compounds0 Mineral fibers0 Nickel compounds0 Polycyclic organic matter0 Radionuclides0 Selenium compounds


3.0 STEPS FOR COMPLETING A PERMIT APPLICATIONFigure 3-1 shows the process to follow when you apply for an air emission permit. The rest ofPart 1 and Part 2 will take you through this process.

Figure 3-1 The Permit Application Process

Review Part 1 and become familiar with the forms and attachments.

��Identify the property boundaries and activities included in your facility. Gather and review existing

information you may have.

��Identify all emission sources.

��Compile detailed stack/vent information.

��Compile pollution control equipment information.

��Prepare detailed emission source data.

��Calculate potential emissions or PTE from each of your sources.

��Review potential to emit from your facility and evaluate whether a permit is needed based on potentialemission levels. If not, see whether a permit is required because of National Emissions Standards forHazardous Air Pollutants (NESHAPs) or New Source Performance Standards (NSPS). If a permit is

required, continue with the application, otherwise stop.

��Calculate actual emissions from your sources, if needed.

��Complete the necessary forms to describe your facility, sources and emissions.

��Identify all requirements that apply to your facility.

��Go to Part 2: Determining Compliance to develop the compliance information needed to complete your

application.

��Review permit application for completeness and accuracy.

��Submit your application to the MPCA.


4.0 HOW IS YOUR FACILITY DEFINED?Your permit application will "define your facility" by detailing the facility's location andequipment. A facility may have a fixed location, like a factory or school. A facility can also bemovable, like a portable asphalt plant. A facility includes all buildings or structures onconnected or adjacent pieces of property that are under common ownership or control.Operations across the street from one another, however, may also be part of the same facility.Also, some facilities may have supporting operations on site with different owners. In thissituation, your air emission permit would cover all of your facilities as a single source.

The major Standard Industrial Classification (SIC) code also helps to define what is part of afacility. The SIC code is a four digit number used to identify industries. The first two digits arethe "major group" of a facility. For example, major group 20 is "Food and Kindred Products."The last two digits of the SIC code identify the specific type of facility. Food products that have43 as the last two digits, for instance, are Cereal Breakfast Foods manufacturing (SIC code2043). A list of common SIC code categories is found in Getting Started. The StandardIndustrial Classification Manual contains all the SIC codes.

All emission units in the same major group SIC code (the first two digits) are considered part ofthe same facility. There are times when sources having different major SIC codes may be part ofthe same facility. In that case, use the SIC code that is the main one for your operations. Anexample of a facility that has more than one SIC code is a plant that both makes and prints oncardboard boxes. Its primary SIC code is 2653, Corrugated and Solid Fiber Boxes. Since thecompany does some of its own printing on site, its secondary SIC code is 2754, CommercialPrinting, Gravure.

4.1 What are your emission points?

An emission point is where emissions are released into the atmosphere. An emission point may bea stack, a wall vent, the general building ventilation exhaust, or a window. Your permitapplication will need to identify the emission points at your facility. Stacks are the easiestemission points to identify. Use a systematic approach to identify all stacks and roof vents andlocate them on a drawing.

It is helpful if each emission point is labeled with a sturdy tag or marking. Labels should beweatherproof so that the stack identity is clearly and permanently displayed. Note whether a stackhas a rain cap, sampling ports or monitoring devices. Note any unusual odors, visible emissions ordeposited materials by the stacks.


After you have finished making a list of your stacks, walk around the outside and through theinside of the building. You may find vents other than the roof stacks, such as wall vents orexhaust fans. Also look for operations that exhaust into the building. Any emission units orsources that exhaust into the building must be included in your emission calculations. After thissurvey, you should have found all of your emission points. Describe each stack or vent on FormGI-04, Stack/Vent information.

Also note if there is pollution control equipment at any emission point. If you have monitoringequipment for the control equipment at the emission point, be sure to describe it. Monitoringequipment examples are temperature gauges, pressure gauges and flow meters. Complete FormGI-05A to describe your control equipment.

Using your survey notes of outside and inside stacks or vents, place all your emission points on afacility or section layout diagram. This information will be helpful as you begin to complete thepermit application forms. Your application must include information describing the location ofyour emission points. Form GI-03 is a facility and stack/vent diagram form that you could alsouse. An example diagram is included in the Blue Ox case study (Section 10.0).

IMPORTANT NOTE: Even though some of your operations do not have a stack or vent, theirprocess emissions will exhaust into the atmosphere through building ventilation or escape throughdoors or windows. These types of emissions must be included in your calculations. Operationsthat do not have a specific stack or vent are still considered emission units (see Section 4.2). Donot confuse this type of emission with "fugitive" emissions. Sections 4.2 and Section 5.1.4provide more information on fugitive emissions.

4.2 What are your emission units?

An emission unit is any piece of equipment or any process that emits pollutants into the air. Theyare the sources that emit pollutants to the air through your stacks and vents. For each stack or ventin your facility survey, list all the equipment and operations that vent at each emission point. Besure to include any sources not located in your main building. If you have a standby generator,storage silo or other source located on your property, but away from the main building, it is stillpart of the facility. You may also have equipment or processes that you do not operate anymore.If these sources are still able to operate, they are considered emission units. You must includethem in your application. Complete Form GI-05B, Emission Unit Description, for each emissionunit other than storage tanks. Use form GI-05C for information related to tanks.

Air emissions that cannot reasonably exhaust through a stack or a building structure are fugitiveemissions. Examples of fugitive emissions include dust blowing from rock and coal piles andtraffic on unpaved roads. Volatile organic compound emissions from outdoor leaking valves or


flanges are also fugitive emissions. Printing emissions at a print shop, on the other hand, are notfugitive emissions because they could be collected and emitted from a stack or vent. Note anysources of fugitive emissions in your application (use Form GI-05D, Fugitive Emission SourceDescription).

After surveying your facility, you should have found all of your emission points and units. Notevery unit must be included in your application. Appendix 1-A provides a list and description ofthe activities or sources you may exclude from an application. Excluded activities include fuelcombustion for food preparation (e.g., an employee cafeteria), maintenance activities and clericalactivities. There is also a second group of similar sources that you must include in yourapplication. For these sources, you may not have to calculate the emissions unless it wouldincrease your potential emissions enough to make your facility subject to different requirements.Appendix 1-B shows the sources for which you must include at least a description in yourapplication.

4.3 How should you describe your operations?

Your permit application should describe how your raw materials, processes, products andemissions are related. Diagrams are a useful tool for describing operations and their relationshipsin a clear and efficient way. A process flow diagram form (Form GI-02) can be used for thispurpose. An example of a process flow diagram is included in the Blue Ox case study (Section10.0).

At this point, begin to think about your operations as a whole and work toward more detaileddescriptions and process flow diagrams. Start with a rough sketch of your overall operations.Show the raw materials used, the process steps, and the finished products. After you havesketched the overall operations, do the same for specific processes. All emission points identifiedon the walk-through of your facility should also be on these process flow diagrams.


5.0 WHAT IS POTENTIAL TO EMIT (PTE)?

Now that you have a list of all your emission points and units, you are ready to look at your airemissions. The potential to emit (PTE) from your facility is one of the most important parts ofyour permit application. Primarily, it helps you determine what federal rules and regulationsapply to your facility. For most facilities, PTE is the basis for deciding whether a permit isneeded.

Potential to emit is the maximum amount of air emissions a unit or facility can possibly producein a year. PTE gives the MPCA a uniform way to assess all types of facilities. In addition, PTEhelps to classify types of modifications at a facility (refer to Part 3: Making Changes fordetails).

This is the definition of PTE that Minnesota uses for most facilities (Minnesota Rules7005.0100, subp. 35a):

"PTE is the maximum capacity while operating at the maximumhours of operation of an emissions unit, emission facility, orstationary source to emit a pollutant under its physical andoperational design. Any physical or operational limitation on thecapacity of the source to emit a pollutant, including air pollutioncontrol equipment and restrictions on hours of operation or on thetype, or amount of material combusted, or stored, or processedshall be treated as part of its design if the limitation or the effect itwould have on emissions is federally enforceable..."

5.1 How do you calculate Potential to Emit (PTE)?

Calculate your PTE using these assumptions:

• The emission unit operates continuously. This means it runs 24 hours per day, 365 daysper year. This amounts to 8,760 hours per year.

• The emission unit operates at its physical and operational design capacity. This meansthe absolute maximum performance the emission unit or source can achieve.

• The material with the most emissions is processed or used 100% of the time (e.g., forvolatile organic compound calculations, assume the coating with the highest solventcontent is used 100% of the time; for particulate matter calculations, assume the coatingwith the highest solid content is used 100% of the time.).


• The emission unit is uncontrolled. This means any pollution control equipment cannotbe counted as reducing emissions while calculating potential to emit.

Using the previous assumptions gives your unrestricted PTE. In most cases, this is whatdetermines if an air emissions permit is needed. Once you’ve determined that an air emissionspermit is needed, it may be possible to consider pollution control equipment when determiningwhat type of permit is required. If the control equipment can be considered “listed controlequipment” under Minn. R. 7011/0060 - 7011/0080, it may be used to calculate emissions forthe type of permit.

Potential to emit (PTE) calculations can include certain process limitations or bottlenecks. Abottleneck is an activity or process that restricts the capacity of other operations. As a result of abottleneck, PTE may be reduced. The following examples illustrate bottlenecks that can andcannot be used in emissions calculations.

Example A –– A grain facility has a dryer with a capacity of 50,000 bushels per hour (bu/hr).The facility has only one gallery conveyor for loading the dryer. The conveyor has a 40,000bu/hr capacity. Since the conveyor physically limits the amount of grain that can be dried, it is abottleneck. 40,000 bu/hr is used to calculate PTE for the dryer.

Example B –– A spray booth has two spray guns and one compressor. The operator can sprayeither varnish or paint. The operator sprays these coatings separately to make the desiredproduct. This is not considered a bottleneck. Because the compressor is large enough to allowboth guns to run at the same time, the PTE calculation must assume both guns are used.

If you want to use a bottleneck limitation in calculating your PTE, describe how it affects yourprocess and emissions. You should also show it on your process flow diagrams. Please notethat if you subsequently make a change that eliminates or reduces the bottleneck, you may haveto amend your permit, or obtain one if you don’t already have one. If removing the bottleneckwould cause an increase in potential emissions, the increase may be considered a modificationto your facility.

IMPORTANT NOTE: Heatset web offset presses and wafer board dryers must calculate theemissions of PM10 (condensable) emissions that result from their volatile organic compoundusage. Other volatile organic compound emission sources will be required to calculate PM10

emissions as emission factors or other data become available.

5.1.1 What references can you use to calculate PTE?

The potential to emit must be calculated separately for each regulated pollutant from eachemission unit. You may use the EC series of forms for the different types of emission units oroperations.


Show your work for your PTE calculations! Part of the MPCA's review of your applicationincludes checking how you came up with your PTE. If you use a computer spreadsheet, show asample calculation or the formulas used as part of your application.

Table 5-1 (next page) gives methods for calculating emissions. Appendix 2-A lists referencedocuments that might assist you. Remember that excluded activities, as listed in Appendix 1-Aand 1-B, may not need emission calculations unless the additional emissions would cause yourfacility to be subject to different requirements.

5.1.2 Examples of Potential Emissions Calculations

Example A –– Potential Emissions Calculations Using EMISSION FACTORS. If you useemission factors, pay attention to two things. First, make sure the factor you use is appropriatefor your process. For example, three sets of emission factors are available for natural gas-firedboilers depending on their firing rate. To select the right factor, you need to know the size ofyour burner. Second, pay close attention to the units used with the emission factor. Make sureyour process data agree with the units in the emission factor.

The emission unit is a natural gas-fired boiler rated at 12 million Btu per hour, or 8,600 lb ofsteam per hour. NOx potential emissions will be calculated using an emission factor.

Heating value of natural gas = 1050 Btu/cubic foot

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

Hourly maximum fuel use = 12 million Btu/hr = 12,000 cubic feet/hour1000 Btu/cubic foot

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

Annual potential emissions of NOx:

8760 hoursyear

12,000 cubic feet of fuelhour

105 12 million cubic feet of fuelyear

× = .

105 12 million cubic feet of fuelyear

100 pounds of NOxmillion cubic feet of fuel

10 512 pounds of NOxyear

. ,× =

10 512 poundsyear

2 000 poundston

5 26 tonsyear

,

,.=


Table 5-1 METHODS FOR CALCULATING EMISSIONS

1. Emissionfactors

Emission factors exist for many types of emission units and processes. An emission factor is anaverage emission value from industry data. It relates an activity or process to the quantity of apollutant released into the atmosphere. Factors are usually expressed as the weight of pollutantreleased per volume or weight of the activity. You may need to know your process capacity ordesign rating to use an emission factor. An example of an emission factor is 0.0001 lb of NOxper cubic foot of natural gas burned.

Emission factors for pollutants can be found in EPA publications such as AP-42**. If you needmore information, AIRS**, , the FIRE*** database, and Toxic Air Pollutant Emission Factorsmay also be useful. These documents contain emission factors for many source classificationcodes. These factors are intended for use as default values if a facility lacks other emission data.Ordering information is in Appendix 2-A. If you do have data specific to your operations (e.g.from stack testing), use that instead of an emission factor from a book or database.

2. Massbalances

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

3. Performancetest data

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

4. Minnesotarules

Regardless of your PTE, the limits listed in the Minnesota rules (primarily the MinnesotaStandards of Performance for Stationary Sources) cannot be exceeded. You can use the rulevalues to calculate your "allowable" emissions from an emission unit. If your PTE is greater thanthe allowable emissions under the rule, the allowable emissions are used as your PTE because therules do not let you emit more than the allowable amount. If your emissions unit cannot meet thestate rule limit, you will have to add control equipment or modify operations so that the limit ismet.

Only if you have no other source of emissions data for calculating the PTE for an emission unit,can the allowable emissions be used as the PTE for that unit.

5. FederalNew SourcePerformanceStandardslimits

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

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


Example B –– Potential Emissions Calculations Using MASS BALANCE. You can use a massbalance calculation to determine emissions from an individual process or series of process steps.The mass balance approach assumes that what goes into a process step equals what comes out.To use a mass balance, be certain that you know how the products and process behave. Forexample, at what temperature does your compound evaporate? Is any solvent retained in ahardened resin? These characteristics affect how much of your compound is emitted.

In this example, the emission unit is one spray gun. The gun capacity is 5 gallons per hour.Primer, paint and varnish are used at this emission unit. Mineral spirits are used for cleaning.To calculate the PTE of volatile organic compounds from spray coating, assume the coatingwith the highest solvent content is used continuously. To calculate the PTE of particulate matterfrom coating, assume the highest solid content coating is used continuously. Although there is awall filter on the booth for particulate matter, this control efficiency is not used in determining ifa permit is needed.

The transfer efficiency of the spray gun is 75% (taken from Table 1, Form PE-07). This means75% of the coating adheres to the part and 25% is overspray. The overspray is released to theambient air.

White Paint Sealer(varnish)

Wipe Stain Primer Mineral Spirits

Density (lb/gal) 9.85 8.06 7.54 9.87 7.2Percent VOCcontent by weight 75% 69% 96% 57% 100%

Percent solidcontent by weight 25% 31% 4% 43% 0%

VOC Content(lb/gal) Calculatedfrom density andpercent VOC byweight

7.39 5.56 7.24 5.64 7.2

Solids Content(lb/gal) Calculatedfrom density andpercent solid byweight

2.46 2.5 0.3 4.23 0

Particulate Matter Emissions

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

5 gallonshour

4 23 pounds of solidgallon

0 25 over spray 5 29 pounds of solidhour

× × =. . .


5 29 pounds of solidhour

8 760 hoursyear

1 ton2000 pounds

23 16 tonsyear

. , .× × =

Volatile Organic Compound Emissions

Annual potential emissions of volatile organic compounds from spray coating are calculated asfollows:

5 gallonshour

7 .39 pounds of VOCgallon

36 .95 pounds of VOChour

× =

36 .95 pounds of VOChour

8 760 hoursyear

1 ton2000 pounds

161.84 tonsyear

× × =,

Last year, the company used 800 gallons of mineral spirits and the plant operated 4,000 hours.For this calculation, those numbers will be scaled up, since there is not a "rated capacity" forcleaning, as there is for the spray gun. The usage of cleaning solvent is variable. For thepurposes of establishing PTE, a margin for error will be factored into the calculation. Anadditional 30% was selected as an adequate margin for their operations.

Annual potential emissions of volatile organic compounds from cleaning are calculated asfollows:

800 gallonsyear

4000 hoursyear

0 2 gallonshour

= .

0 2 gallonshour

7 2 pounds of VOCgallon

1 44 pounds of VOChour

. . .× =

1.44 pounds of VOChour

8 760 hoursyear

1 ton2000 pounds

6 .31 tonsyear

× × =,

6 31 tonsyear

1 3 8 20 tonsyear

. . .× =


Hazardous Air Pollutant EmissionsIn addition to calculating your overall VOC emissions, you must also calculate the emissions ofany individual hazardous air pollutant (HAP) from the list of HAPs. For the painting operationdescribed in Example B, a review of the material safety data sheets showed what hazardous airpollutants are in the coatings. Only the paint, sealer and stain contain any chemicals that arehazardous air pollutants. The hazardous air pollutants are formaldehyde, toluene, methyl ethylketone, methyl isobutyl ketone, and xylene.

White Paint Sealer Wipe Stain

Density (lb/gal) 9.85 8.06 7.54Percent Xylene content by weight 13% 30% 27%Percent Toluene content by weight 15% 31%3% 7%Percent Formaldehyde content by weight 0.2% 0.25% 0Percent Methyl Ethyl Ketone content byweight 5% 2% 0

Percent Methyl Isobutyl Ketone content byweight 8% 0 6%

Xylene Content (lb/gal) Calculated fromdensity and percent xylene by weight 1.28 2.42 2.04

Toluene Content (lb/gal) Calculated fromdensity and percent toluene by weight 1.48 0.24 0.53

Formaldehyde Content (lb/gal) Calculatedfrom density and percent formaldehyde byweight

0.02 0.02 0

Methyl Ethyl Ketone Content (lb/gal)Calculated from density and percent methylethyl ketone by weight

0.49 0.16 0

Methyl Isobutyl Ketone Content (lb/gal)Calculated from density and percent methylisobutyl ketone by weight

0.79 0 0.45

For each hazardous air pollutant, take the highest content in pounds per gallon and calculate theuncontrolled potential to emit from one spray gun.

Annual potential emissions of xylene from spray coating is calculated as follows:

5 gallonshour

2 42 pounds of xylenegallon

12 1 pounds of xylenehour

× =. .

12 1 pounds of xylenehour

8 760 hoursyear

1 ton2000 pounds

53 0 tonsyear

. , .× × =

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


Pollutant Potential to Emit (tons per year)

Xylene 53.0

Toluene 32.41

Formaldehyde 0.44

Methyl Ethyl Ketone 10.73

Methyl Isobutyl Ketone 17.30

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

5.1.3 What is the next step after calculating the PTE of your emission units?

Once you have found the potential to emit (PTE) from each individual emission unit, find thetotal PTE for each pollutant emitted by your facility. To obtain the total PTE for each pollutant,add the PTE from all the individual emission units. Once you have the total facility PTE foreach pollutant, compare each of your totals to the thresholds for permits.

Table 5-2 lists all the emission thresholds. If your total facility PTE for any one pollutant isabove the level in Table 5-2, a permit is required. If you are building a new facility and thepotential emissions meet or exceed the thresholds in Table 5-2, a permit is required before youstart construction. If you meet or exceed a threshold for Part 70, your facility is called a "major"source for Part 70.


Table 5-2 EMISSION THRESHOLDS REQUIRING A PERMIT

Type of Pollutant Permitting ThresholdPermitType

Common Sourcesof Each Pollutant

Particulate Matter (PM) 100 tons/year State Dusty activities such as grainhandling, milling, sand andgravel operations

PM10 (Particulate Matter lessthan 10 microns)

25 tons/year

100 tons/year

State

Part 70

Fuel combustion, dustyactivities such as grainhandling.

Volatile Organic Compounds(VOCs)

100 tons/year excludingfugitive emissions (unless listedin Table 5-3)

100 tons/year includingfugitive emissions

Part 70

State

Solvent cleaning, painting,fuel storage and transfer

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

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

Sulfur Dioxide (SO2) 50 tons/year

100 tons/year

State

Part 70

Fuel combustion

Lead (Pb) 0.5 tons/year

10 tons/year

State

Part 70

Wave soldering, leadsmelting and recycling

Hazardous Air Pollutants (HAPs)Any single HAPAny combination of HAPs

10 tons/year25 tons/year

Part 70 Solvent cleaning, painting,fuel storage and transfer

(both numbers include fugitive emissions)

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


Table 5-3 TYPES OF FACILITIES THAT INCLUDE FUGITIVE EMISSIONS IN PTE

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

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

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

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

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

Petroleum Refineries (2911)

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

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

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

Fuel Conversion Plants Sintering Plants*

Secondary Metal Production Plants(332X, 334X, 336X)

Chemical Process Plants (28XX)

Fossil-Fuel Boilers (or combinationthereof) totaling more than 250 MMBtu/hr

Petroleum Storage & Transfer Units, TotalStorage Capacity over 300,000 Barrels

Taconite Ore Processing Plants (1011) Glass Fiber Processing Plants

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

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

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

5.1.5 What if your PTE is below the thresholds?If your potential emissions are below all the thresholds listed in Table 5-2, you may not have tosubmit a permit application. You should keep records showing your calculations and decisions.Also, keep track of any future increases in emissions in case your total facility PTE ever exceedsa threshold. If it does, you will have to obtain a permit. You should calculate emissionsincreases before you start construction. Certain changes require the permit to be issued forconstruction to begin (refer to Part 3: Making Changes).

Even if your emissions are below all the thresholds listed in Table 5-2, you may still need apermit. If an emission unit or facility is subject to any federal New Source PerformanceStandard (NSPS)*, you will need a state permit just for the unit covered by the NSPS. Certain


National Emission Standard for Hazardous Air Pollutants (NESHAPs) cause a facility to need astate permit. These NESHAPs are the ones listed in Form GI-09(A)**. More information aboutthese two regulations is in Section 6.1.2 and 6.1.4. Minnesota's rules regarding wastecombustors require a permit for some waste combustors whose emissions are below thethreshold levels in Table 5-2.* except: 40 CFR 60 Subp. AAA, New residential wood heaters; 40 CFR 60 Subp. JJJ, Petroleum Dry Cleaners; 40CFR 60 Subp. Kb, Volatile Organic Liquid Storage Vessels, if all vessels have capacity less than 75 m3; 40 CFR 60Subp. Dc, Small Industrial-Commercial-Institutional Steam Generating Units, if all are only capable of burningnatural gas or propane.

**except for 40 CFR 61 Subp. M, Asbestos section 61.145 Standard for Demolition and Renovation

5.2 Do you need any other emissions data?

5.2.1 What are your actual emissions?

Your actual emissions for the previous year may have to be part of your permit application.Actual emissions are the emissions to the air that result from your actual material usage andactual hours of operation. For some facilities, a federal program called New Source Review(NSR) will apply (see Section 6.1.3). In NSR, the actual emissions data for operations now andin the past may be important.

If you filed an annual Emission Inventory Report (Section 6.2.4) with the MPCA in the previousyear, you do not have to submit actual emissions data with your application. If you have notsubmitted an annual Emission Inventory Report, you may not know your actual air emissions.The same methods used to calculate PTE can be used to find your actual emissions. You haveseveral tools at your facility to help you calculate actual emissions. These reports will help youdefine your material usage:

• Purchasing records

• Production records

• Fuel usage records

• Hazardous waste manifests (for solvents, inks, paints or other materials)

• Material safety data sheets (MSDSs)

• Toxic Release Inventory reports

Information collected from these sources should help to define your actual emissions. The massbalance approach (Section 5.1.2) is also useful for calculating actual emissions. For example,suppose you are using an organic cleaning solvent that is disposed as a hazardous waste. Tocalculate the portion that evaporated (your volatile organic compound emissions), you need to


know how much solvent went into the process and subtract the amount that went out ashazardous waste.

5.3 How can you limit your Potential to Emit (PTE)?5.3.1 What about your air pollution control equipment?

The “Control Equipment Rule” (Minn. R. 7011.0060 - 7011.0080) allows you to count theeffects of some control equipment toward limiting your PTE. However, not all types of controlequipment can be counted, and it can’t be used to reduce PTE to below permitting thresholds orto avoid permitting. Refer to the rule for more information, or to the fact sheet called “ControlEquipment Performance Standards.”

5.3.2 What if you do not want to be subject to federal regulations?

Suppose your potential to emit exceeds a threshold for a Part 70 permit for either criteria orhazardous air pollutants. Perhaps your PTE exceeds the thresholds for a major source in theNew Source Review (NSR) regulations (see Section 6.1.3). However, your actual emissions arebelow the thresholds. You can then choose to have a synthetic minor permit. Your permitapplication for a synthetic minor permit must comply with all the requirements of a majorsource. Your facility does not become a synthetic minor facility until the permit is issued.

The synthetic minor permit contains operating and emission limits. By accepting permitconditions that limit what you are allowed to emit, your PTE is redefined. Your allowableemissions in your permit become your PTE. If your actual emissions already exceed thethresholds for New Source Review, you cannot have a synthetic minor permit for your totalfacility. Refer to Part 3: Making Changes for information on synthetic minor modifications.

A synthetic minor permit or amendment has benefits. For example, suppose you receive asynthetic minor state permit, instead of a Part 70 permit. Most state permits will not expire andyou would be exempt from compliance assurance monitoring (CAM) requirements (see Section6.1.7). You may also avoid environmental review (see Section 6.2.2). In addition, a syntheticminor permit for New Source Review (NSR) has some advantages. A synthetic minor permitfor NSR may give you more flexibility for future changes. You also save both time and moneywith a simpler application process. Remember that if you receive a synthetic minor permit, youmust perform sufficient record keeping and monitoring to show you are meeting the permitlimits.

The following discussion introduces you to what goes into your proposal for synthetic minorlimits.


5.3.2.1 What are acceptable options for synthetic minor limits?

Acceptable permit conditions for a synthetic minor permit set specific limits for specificpollutants. Your permit cannot be written as, "do not exceed 99 tons per year of CO" –– that istoo vague to be enforced. A permit limit for a synthetic minor must be enforceable.Enforceability means:

• The limit is in a permit that was issued under an EPA approved program and that had apublic comment period.

• The limit is enforceable in a practical way (practically enforceable).

Practically enforceable limits may be:

• Production limits –– restrictions on the amount of a final product that can bemanufactured or produced at a facility or process line.

• Operational limits –– restrictions on how a source is run. These include limits on thehours of operation, fuel use, raw material type and usage, and the operation of pollutioncontrol equipment.

• Emission limits –– these are acceptable if they are on a quantifiable, production basis.Examples are: pounds of pollutant/million Btu heat input or pounds of pollutant/unit ofproduct. Emission limits are often linked to operational limits (e.g., a limit on theamount of fuel burned).

You must be able to show that you comply with all your limits or requirements at any time. Toshow this, you may use some or all of these methods:

• Record keeping such as production throughput and hours of operation

• Continuous emission monitoring (CEM) data

• Stack test data

• Material analysis such as Material Safety Data Sheets (MSDSs), supplier certification, orlaboratory analysis results

If you choose to limit your hours of operation, your PTE must be calculated using the maximumdesign capacity for all the hours allowed by the permit. Be aware that putting a limit on thehours of operation may be more restrictive for you than other operating limits. However, youcan also use a combination of types of limits, such as hours of operation with material usage.

For many sources, the time period associated with a production or material usage limit may beproposed in any of several ways. It could be a straight monthly limit (i.e., not to exceed 500hours per month). It could be an annual limit where you calculate the total over the previous 12


months (called a 12-month rolling sum). It could be one where you calculate the daily averageover the previous 365 days (called a 365-day rolling average). Either of the rolling limits willgive you a bit more operating flexibility than a monthly limit. Low months will allow you tohave high months and still not exceed your limit. For some facilities (often those that are morecomplex than most or those that have an NSR requirement), a 30- or 365-day rolling averagemay be necessary.

If you propose a rolling average or rolling sum for a new unit, you must provide a way to showthat you comply with your limits during the first 12 months of operation. This could be aformula as shown in the following example. It could be a temporary monthly limit. If you arerequesting new limits on an existing source, you have the option of using existing operating datain the rolling period. This would eliminate the need for a special limit for the first 12 months.

Example –– This is a new installation of a stand-by diesel generator set. The unrestrictedpotential to emit would make the facility subject to both Part 70 and NSR. The limits keeppotential emissions less than 100 tons per year. By accepting limits, the facility would not beconsidered a major source for both programs. In addition, the requirement for an EnvironmentalAssessment Worksheet is avoided (see Section 6.2.2).

Pollutant Limitation

Nitrogen Oxides (NOx) (limitedto less than 100 tons per year)

Not to exceed 300 hours of operation in each calendar year

Annual hours of operation shall be calculated monthly,based upon a 12-month rolling sum.

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

Hn < 27.27 + 22.73n

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

n = number of months of unit operation

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


month. If 30 hours were enough for the first month, the formula could use 30. If more hourswere needed in the first month, the formula could use more hours.

IMPORTANT NOTE: Make sure you can live with the limits in your synthetic minor permit.Suppose that in the future you want to modify your facility or permit and would then exceed thesynthetic minor limits. At that time, you may have to address the requirements you avoidedwhen you received a synthetic minor permit. Those requirements could include the installationof control equipment, computer modeling of the emissions, or environmental review, amongothers.

If you do not comply with your synthetic minor limits, your permit may be a sham permit andyou may be subject to enforcement action. This is because the objective of a synthetic minorpermit is to simplify the permit process for sources whose actual emissions are minor. It is notfor sources to circumvent major source requirements, if those requirements apply to them.


6.0 WHAT RULES AND REGULATIONS APPLY TO YOU?Some federal and state air quality rules and regulations apply to specific emission units. Someapply to the entire facility. This section is a brief introduction to what the MPCA calls"applicable requirements." Requirements Form GI-09 will help you define all the rules andregulations that apply to you in the permit application. Refer to Part 2 for the rules andregulations that relate to completing the compliance portion of your application.

Federal regulations are found in the Code of Federal Regulations (CFR). Title 40 of the CFRcovers the protection of the environment. Air quality regulations are in parts 50 to 99 of Title40. If you see a reference to 40 CFR 61.01, it means the Code of Federal Regulations, Title 40,Part 61, Section 01. MPCA Air Quality rules are in Minnesota Rules, Chapters 7002 to 7030.Copies of federal and state regulations are at the MPCA library, county law libraries, universityor college libraries, and some public libraries. The MPCA can also provide assistance inobtaining specific rules. You can also order copies of the Minnesota Rules or the CFR. SeeAppendix 2-A for a list of the rule publications and where to order them.

6.1 What are the federal regulations?

Whether your facility needs a permit or not, remember that you still have to comply with thefederal regulations.

6.1.1 National Ambient Air Quality Standards (NAAQS)

The National Ambient Air Quality Standards (NAAQS) set the maximum concentrations ofpollutants allowed in the ambient air. The pollutants for which the standards are developed arethe criteria pollutants (PM10, PM2.5, SO2, NOX, CO, lead, and ozone). Minnesota also has astate standard for hydrogen sulfide. Primary and secondary standards exist for each of thepollutants. Primary standards protect public health, while secondary standards protect publicwelfare. Public welfare includes economic and environmental effects such as damage to plantsor buildings. The NAAQS are found in Part 50 of the Code of Federal Regulations.

If the National Ambient Air Quality Standards are met in a given area (e.g., a county), then thearea is an attainment area. A nonattainment area is where the level of a criteria pollutant in theair exceeds the NAAQS for a pollutant. Nonattainment areas in Minnesota are shown in Table6-1 and Appendix 3-A. Your location affects your facility's status for New Source Review (seeSection 6.1.3 and Part 3 of the Guide).


Table 6-1 NONATTAINMENT AREAS IN MINNESOTA

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

Particulate Matter Lessthan 10 Microns (PM10)

Portions of Ramsey County along the Mississippi River

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

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

If your facility requires a Part 70 permit, you will also have to show compliance with NAAQS.Current MPCA policy is to required this for all facilities that have potential emissions of PM10,SO2, or NOX exceeding 100 tons per year. Other facilities may also have to conduct modelingin certain instances. If this applies to your facility, your permit will require you to conductdispersion modeling of your potential emissions. Dispersion modeling uses a computer programin which facility and emissions data are used to estimate pollutant concentrations. Estimatedconcentrations at various locations in the surrounding area are compared to the standards. Themodeling requirement must be completed within the first five-year term of a Part 70 permit.You may submit your modeling with your initial application if you wish. Dispersion modelingis discussed further in Part 2, Section 2.5.4.1.

6.1.1.1 State Implementation Plan

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

6.1.2 National Emission Standards for Hazardous Air Pollutants (NESHAPs)

The NESHAPs rules are in 40 CFR Parts 61, 63 and 68. Part 61 has standards for ninehazardous air pollutants when they are emitted from specific source types. The nine hazardousair pollutants are: radon, beryllium, mercury, vinyl chloride, radionuclides, benzene, asbestos,inorganic arsenic and volatile hazardous air pollutants. Form GI-09(B) lists the source types.

Part 63 contains a list of hazardous air pollutants [see Table A in Form GI-09(A)]. Some of thehazardous air pollutants overlap with the nine listed in Part 61. These chemicals includecomponents of common solvents and heavy metals like cadmium. For sources that emit thesehazardous air pollutants, the EPA is developing Maximum Achievable Control Technology


(MACT) standards. MACT standards are being developed for new major sources and also forexisting sources of hazardous air pollutants. The standards apply to source categories, such ashalogenated solvent cleaning equipment or wood treatment. A facility may be subject to aMACT standard but not required to have a permit.

MACT standards will be established based on current technology. A MACT standard can be anemission rate, a product substitution, a work practice, or a control technology requirement.When setting the standards, the EPA can consider factors such as cost, energy use, wastedisposal and water quality. Once a MACT standard is in effect, an existing source has up tothree years to comply. If your facility has opted to participate in the federal Early ReductionsProgram, you may have up to six years to comply with MACT. A new source must comply withMACT upon start-up. Table B in Form GI-09(A) contains the list of source categories forwhich MACT standards are developed or planned and the dates they are expected to be in effect.Please note that if a MACT standard is promulgated that applies to your facility, you mustcomply with it regardless of your permit status at that time.

Some MACT standards are not due to be promulgated until the year 2000. If your facilitybecomes subject to any of these requirements, you will need to comply with the new rules. Youcan track these regulations and others that may be proposed in the Federal Register, TheMinnesota State Register, and through updates in the MPCA's Air Mail newsletter.

Part 68 of the Code of Federal Regulations concerns the prevention of accidental releases. Itapplies to specific chemicals, but only if a facility uses, handles, processes or stores more than athreshold amount of the chemical. Form GI-09(G) lists the chemicals in this regulation and thethreshold amounts. However, these requirements are not permit requirements. Be aware that ifthis part of the regulation applies to you, you are required to write a management plan for theprevention of accidental releases that covers hazard assessment, pollution prevention, andemergency response issues for your facility.

6.1.3 New Source Review

New Source Review (NSR) regulations are federal regulations that Minnesota administersthrough its permits. NSR regulations are in Parts 51 Appendix S and Section 52.21 of Title 40of the Code of Federal Regulations. The present NSR regulations have been in effect since1980. The goal of NSR is to allow economic growth while protecting air quality.

These pollutants are currently regulated by the NSR program:


Carbon Monoxide (CO) Ozone (hydrocarbons and VOCs)

Sulfur Dioxide (SO2) Sulfuric acid mistPM10 and Total Particulate Matter (PM) Total reduced sulfur compounds (TRS)

Nitrogen Oxides (NOx) Municipal waste combustor acid gases and metals

Lead (Pb) Fluorides

PM2.5 will be regulated in the future.

Within NSR, two related programs are based on your location. One is called Prevention ofSignificant Deterioration (PSD), which is the part of the NSR program that applies to facilitieslocated in attainment areas. The other program is Nonattainment Area New Source Review forareas where one or more National Ambient Air Quality Standards (NAAQS) are exceeded.Many similarities exist between PSD and Nonattainment Area review.

The NSR program also provides special protection to geographic areas with special scenic orrecreational values. These locations are called "Class I" areas. In Minnesota, the BoundaryWaters Canoe Area and Voyageurs National Park are Class I areas. In Wisconsin, the RainbowLakes Wilderness Area is a Class I area that may be affected by Minnesota facilities.

6.1.3.1 Does NSR apply to your facility?

Your facility could be a "major source" and require a Part 70 permit. That does not necessarilymean your facility is a major source for NSR. NSR applies to facilities whose emissions meetor exceed the thresholds in the NSR regulations. The major source threshold for NSR is apotential to emit 100 tons per year if either of these criteria applies:

• Your facility is one of the 28 types listed in Table 6-2. The numbers in parentheses arethe typical SIC codes for the source type. (Note: For these 28 sources, count fugitiveemissions in your potential to emit to determine if your facility is "major.")

• Your facility is located in a nonattainment area (see Section 6.1.1). "NonattainmentArea" review is triggered only if your facility's potential emissions of the nonattainmentpollutant in the nonattainment area exceeds 100 tons per year.

If neither of these criteria applies to you, then the threshold for facilities defined as a "major"source is 250 tons per year.


Table 6-2SOURCES THAT ARE MAJOR FOR NSR IF PTE EXCEEDS 100 TONS PER YEAR

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

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

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

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

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

Nitric Acid Plants (2873) Petroleum Refineries (2911)

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

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

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

Fuel Conversion Plants Sintering* Plants

Secondary Metal Production Plants (332X,334X, 336X)

Chemical Process Plants (28XX)

Fossil-Fuel Boilers (or combinationthereof) totaling more than 250 MMBtu/hr

Petroleum Storage & Transfer Units, TotalStorage Capacity over 300,000 Barrels

Taconite Ore Processing Plants (1011) Glass Fiber Processing Plants

Charcoal Production Plants (2819, 2861) Fossil Fuel-Fired Steam Electric Plants of

More Than 250 MMBtu/hr

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

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

6.1.3.2 What is required for NSR?

If you have to perform a New Source Review for your project, it will include these items:


• Analysis for each pollutant to show whether PSD or nonattainment review applies

• Environmental review by the Environmental Quality Board (see Section 6.2.2)

• Public participation during a comment period

• Review by the National Park Service or Forest Service if a Class I area is nearby

• Analysis of the proposed emission rate or control technology

• Ambient air monitoring (for some facilities)

• Computer modeling to analyze impacts on air quality, visibility, soils and vegetation

NSR requires that you look at ways to minimize your emissions. In a nonattainment areareview, you must have the Lowest Achievable Emission Rate (LAER). LAER does not accountfor things like cost –– it is strictly a technical determination of what the smallest emission rate isfor your emission unit. For Prevention of Significant Deterioration (PSD) reviews in attainmentareas, Best Available Control Technology (BACT) must be applied. BACT is not necessarily atype of pollution control equipment, although the name implies it. A BACT study gives anemission rate, and it does consider cost, along with other factors. If you can achieve theemission rate with something like good process control, then good process control is BACT.

You may have the option of obtaining a synthetic minor permit to restrict your emissions to lessthan threshold levels for New Source Review. If you do, the requirements of NSR are avoided.You may take permit conditions to restrict emissions from a new facility to less than 100 tonsper year or 250 tons per year. If your existing facility has always had actual emissions belowNSR thresholds, then you may also be able to receive a synthetic minor permit. You may alsoobtain a synthetic minor permit amendment for a modification. Please note that whether yourfacility is a major source or a synthetic minor source, you may not begin construction until apermit is issued.

6.1.4 New Source Performance Standards (NSPS)

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


When looking at NSPS, modification has a specific meaning. Modification means a physical oroperational change to your facility that results in an increase in the emission rate of a regulatedpollutant. Routine maintenance and repair is not considered a modification. Neither would anincrease in the hours of operation because the potential emission rate (i.e., lb/hr) would notchange. Reconstruction may be a modification and is defined for NSPS. Reconstruction is thesignificant replacement of existing components to an emission source (i.e., the cost of repair isgreater than 50% of the cost of replacing the entire emission source).

6.1.4.1 An example of an NSPS

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

6.1.5 Acid Rain

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

6.1.6 Stratospheric Ozone Protection

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


number is 1-800-296-1996 and it is available Monday through Friday, from 9:00 am to 3:00 pmCentral Standard Time.

Note that if you replace an ozone depleting chemical with a VOC containing compound, youmay need a permit to authorize the change in your operations.

6.1.7 Compliance Assurance Monitoring

Compliance Assurance Monitoring requirements apply to facilities that operate emission controldevices subject to federally enforceable regulations promulgated prior to 1990. Theseregulations are not limited to EPA regulations, but include any regulation that pertains to thePart 70 operating permit rule. This includes New Source Performance Standards (NSPS),National Emission Standards for Hazardous Air Pollutants (NESHAPs), and Minnesota Rulescontained in the State Implementation Plan.

Periodic monitoring applies to those facilities and units that are not subject to enhancedmonitoring. The MPCA has guidance on what it will accept as periodic monitoring. Thisguidance is attached to Form CD-01, Compliance Plan. You can find more information onmonitoring and compliance in Part 2 of the Guide.

6.2 What are the Minnesota rules?

Whether your facility needs a permit or not, you still have to comply with the state rules. Table6-3 lists the Minnesota rules related to air emission facilities. The Minnesota Air Quality Ruleswere renumbered as listed in The Minnesota State Register dated August 23, 1993. If you havedifficulty locating a specific rule, contact the Permit Information Specialist, whose phonenumber is in Focus Section of Part 1.

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

Chapter Title

7002 Fees

7005 Air Quality Definitions and Abbreviations

7007 Air Emission Permits

7009 Ambient Air Quality Standards

7011 Standards of Performance for Stationary Sources

7017 Monitoring and Testing Requirements

7019 Notification, Reporting, and Emission Inventory Requirements

7030 Noise Pollution Control


6.2.1 Air Quality Permit Rule

Minnesota Rules Chapter 7007 contains the requirements for air emission permits. Even thoughthis Guide introduces many sections of the permit rule, you should become familiar with the ruleitself. Again, you can obtain a copy of the rule from the Permit Information Coordinator (seethe Focus Section in Part 1 for the phone number). Copies of the rule can also be ordered fromthe Minnesota Print Communications Division (see Appendix 2-A for ordering information).

6.2.2 Environmental Review Program

The Environmental Planning and Review function of the MPCA conducts environmentalreviews of projects with the potential for significant environmental effects. If your new facilityor modification has potential air emissions of 100 tons per year or more, EQB review isrequired. EQB review is also required for projects that fall in certain "mandatory" categories.The mandatory category lists are in Appendix 4. Some government units (e.g., a city) mayrequest environmental review even if it is not mandatory. Citizens can also petition forenvironmental review.

An Environmental Assessment Worksheet (EAW) is the first step in environmental review. AnEAW consists of a series of questions about your project. You will have to answer questionsrelated to land use, impacts on plants and animals, air pollution and water pollution. An EAWdetermines if an Environmental Impact Statement (EIS) should be done. Typically, an EAWtakes up to six months to complete, including a 30-day public comment period.

If an EIS is required, the EIS will contain more detailed information. An EIS considersalternatives to the proposed project and explores methods for reducing adverse environmentaleffects. An EIS typically takes over a year to complete, including two public comment periods.

If you obtain a permit that restricts your potential emissions to less than 100 tons per year,environmental review may be avoided. If you have another modification, however,environmental review may be required at that time even if the increase in potential emissionsfrom the project is less than 100 tons per year. The rules governing environmental review arefound in Minnesota Rules Chapter 4410.

6.2.3 Standards of performance for stationary sources

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


type of fuel burned. These limits cover particulate matter, opacity, sulfur dioxide, and nitrogenoxides. There are also different standards based on the age of the equipment.

One Minnesota standard that you can choose to have apply to your facility is for controlequipment (Minn. R. 7011.0060 - 7011.0080). This rule only applies if you choose to use thelisted efficiencies in the rule to determine what type of air emissions permit (or permitamendment) you need. If you choose to be subject to this rule, then you must meet all theconditions of the rule -- the recordkeeping, monitoring, and operation and maintenancerequirements listed in the rule. These requirements will be added to your permit when it isissued. There are limitations on when the rule can be used when making modifications. Referto Part 3: Making Changes for more information on modifications.

6.2.4 Emission inventory and air quality emission fees

If your facility is subject to the air permit rule, you must also file an annual Emission Inventory.This inventory details the actual emissions from the facility based on records of material use andtotal production. You must sign a certification that says your inventory is true, accurate andcomplete to the best of your knowledge. Air quality fees are based on the amount of actualemissions reported in your inventory. These rules are found in Chapters 7002 and 7019.

The MPCA mails the forms for your inventory in January of each year. The completedinventories are due in April. If you are required to pay emission fees, but you do not submit aninventory of your actual emissions, your fees will be based on your facility's potential to emit.Since your potential emissions may be greater than your actual emissions, it is important thatyou submit your emission inventory on time.

6.2.5 Performance testing for emissions

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


7.0 HOW DO YOU MAINTAIN FLEXIBILITY IN YOUR OPERATIONS?The air permit rule has some provisions that allow you to build flexibility into your permit. Forexample, permit limits can be somewhat flexible. For example, a limit can specify materialusage for a group of emission points, such as paint usage for a group of spray booths. In thiscase, a group or overall limit may be more flexible for you than limits for each individualemission point.

In addition, modifications (changes that may cause an increase in emissions) allow you to makesome changes before a permit or amendment is issued. Part 3 of the Guide describes thedifferent types of modifications and when you may make the changes.

7.1 What is operational flexibility?

Specific provisions are outlined in the air permit rule for operational flexibility. When youapply for a permit, you would request this flexibility and propose specific language to include inyour permit.

7.1.1 Alternative operating scenarios

After you have an air emission permit for your total facility, your operations may change. Youmay have frequent operational changes or changes with short time tables. These changes maycause you to need a permit amendment. Applying for and waiting for an amendment may beinconvenient or even hurt your business. If you can foresee the various modes of operation thatyou may need, they can be included in your facility's air emission permit. If so, you would notneed to amend a permit when you switch between operating modes.

In your application, you must describe each operating mode. Each mode is an alternativeoperating scenario. Each scenario must have its own calculations and methods of monitoringand record keeping. The monitoring and record keeping must be specific enough to verify yourcompliance status at all times. When you switch between scenarios, you must record relateddata. These include the date, time, duration and production totals for each change of scenario.Section 2.10.2 in Part 2 discusses record keeping and reporting in greater detail.

An example of an alternative operating scenario is a boiler that uses natural gas as its primaryfuel, and fuel oil as a backup fuel. Different record keeping and monitoring would be donewhen fuel oil is used than when gas is used. For instance, the sulfur content of the fuel oilwould be tracked while using oil, but not when using gas.

Another example is a printing press with control equipment for volatile organic compounds.Both solvent-based inks and water-based inks are used. When water-based inks are used, thecontrol equipment may not have to be run at all. If the control equipment does run, it most


likely would be at a different temperature and efficiency than when solvent-based inks are used.Both operating scenarios should be addressed in the permit application.

7.1.2 Emission trading

Emission trading may apply to your facility. Emission trading is another way to avoid delayswhen making changes within your facility. Emission trading applies to the emissions of a singlepollutant and is facility-specific. The facility will typically have an emission cap on a group ofsources or the total facility, rather than limits for each emission point. The cap can be asynthetic minor permit limit. Trading allows you to exchange emission increases with emissiondecreases that occur within your facility. The cap and any other emission limits must not beexceeded. Emission trades are not allowed if they would be a modification as defined in NewSource Review, New Source Performance Standards, or National Emissions Standards forHazardous Air Pollutants. When you wish to make a trade, the MPCA must be notified at leastseven working days in advance.

To use emission trading, request it in your permit application. You must also propose yourmonitoring and record keeping methods to quantify the emission trades. Be aware that themonitoring and record keeping must be done the same way every time a trade is made. Optionsfor monitoring and quantifying the trades range from simple to complex as shown by theseexamples:

• Fuel use or material usage records

• Calculations based on acceptable engineering estimation techniques

• Measurement of emissions, process parameters, control equipment parameters, andmaterial data performed on a periodic basis

• Results of operations and maintenance programs, work plans, leak detection programs,and dust control programs

• Continuous monitoring systems for process or control equipment parameters, or foremissions


8.0 WHAT IF YOU HAVE CONFIDENTIAL MATERIAL IN ANAPPLICATION?Your permit application will contain detailed information about your facility. You may wish tokeep some of that material confidential. Normally, everything submitted to the MPCA isavailable to the public. The Minnesota Data Practices Act allows some kinds of data, such astrade secrets or sales figures, to be kept confidential. Facility data related to emissions may not bekept confidential.

For the MPCA to treat information in your application as confidential, you must submit awritten request to the MPCA using Form CR-03. This request should identify what specificdata in your application is confidential. You must state the reason for keeping the dataconfidential and certify that the material is confidential.

The two legal provisions most likely to apply to permit applications protect the following kindsof data:

• Data furnished to the agency that relates to (a) sales figures, (b) processes or methodsof production unique to the owner or operator, OR (c) information which would tendto affect adversely the competitive position of said owner or operator. (Minn. Stat §116.075, subd. 2)

• Data including a formula, pattern, compilation, program, device, method, techniqueor process (1) that was supplied by the affected individual or organization, (2) that isthe subject of efforts by the individual or organization that are reasonable under thecircumstances to maintain its secrecy, AND (3) that derives independent economicvalue, actual or potential, from not being generally known to, and not being readilyascertainable by proper means by, other persons who can obtain economic valuefrom its disclosure or use. (Minn. Stat. § 13.37, subd. 1(b))

However, even if the information falls under one of the above categories, if it is consideredemissions data (defined in 40 CFR § 2.301), then the information is considered public. Both theClean Air Act and Environmental Protection Agency (EPA) regulations require that “emissiondata” submitted to the MPCA under Title V or Minnesota’s State Implementation Plan must beavailable to the public. In addition, EPA has issued guidance on what type of information itgenerally considers to be emission data (Federal Register Vol. 56, No. 35; February 21, 1991).Please note that only specific data within an application can be considered confidential, not theentire application or permit.

The MPCA staff will review your request and reply in writing. If your request is approved, theconfidential material is kept in a separate, locked file at the MPCA.


Once a piece of information has been approved as confidential, you must submit another copy ofyour application with the confidential data removed. That copy will be for the public file. If yousend the MPCA any other documents that contain the confidential data, you must label it andrequest confidential status again. It is your responsibility to properly label (approved) data asconfidential. The MPCA staff will not sort documents for data that may be confidential, but arenot labeled.

If you do not request and receive approval to have material treated as confidential, please takenote! Stamping the word "Confidential" on a document will not cause the MPCA to treat it asconfidential. For material to be treated as confidential, you must submit a written request forconfidentiality and the MPCA must approve your request.

The MPCA can agree to keep your data confidential. However, if the EPA requests theinformation from the MPCA, the agency must provide it. The material will not be treated asconfidential by the EPA unless you request that the EPA does so. Requests for the EPA to keepdata confidential are governed by Part 2 of Title 40 of the Code of Federal Regulations.Requests to EPA for confidentiality should be made to:

Chief, Grants Management and Program Evaluation SectionEPA Region V77 West Jackson Blvd.Chicago, Illinois 60604


9.0 WHAT IS IN A COMPLETE PERMIT APPLICATION?A complete permit application contains information about your emission sources and yourfacility. It is the starting point for your permit. Your application should include the facility andemissions data you have collected based on the suggestions offered in Sections 2 through 5 ofPart 1 of the Guide.

The MPCA has developed standard forms you must use when you apply for a permit. The BlueOx Woodworks case study (Section 10) has examples of completed forms (Appendix 5-A).These forms list the information needed by the MPCA to write a permit for your facility. If aquestion on a form is not applicable or the information is not available, note that by the question.If you find that a form does not apply to your facility, do not submit it. Table 9-1 shows theinformation you must supply in an application. The Application Forms Master List can serve as atable of contents for your application. This form can also be used as a checklist while you prepareyour application. It will help to monitor those portions of the application you have completed.

Your application will also cover compliance issues. After you decide what air permit rules applyto your facility, you must determine whether you comply with them. Your application shouldoutline how you will correct any situations where your facility does not comply at the time yousubmit the application. Also, you must submit a plan for keeping your facility in complianceonce the permit is issued. Part 2: Determining Compliance helps you work through thecompliance issues for your application.

Your application must certify that the information is complete and correct to the best of yourknowledge. This certification must be signed by a responsible official. The signer can be apresident, general partner or a ranking elected official. Other qualified people are listed inMinnesota Rule Chapter 7007.0100, subpart 21. The person signing an application is responsiblefor its contents, regardless of who prepared it.

9.1 Why is a "complete" application important?

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


Table 9-1SUMMARY OF INFORMATION TO BE INCLUDED IN AN APPLICATIONType of Information Typical Information to be Provided

Identifying Information Facility location and mailing address. Contact persons. Generaprocess and products description. Application Certification.

Facility layout and stack locations.

Process and Products Description Detailed process schematic flow diagrams.

Detailed Emissions Related Information Detailed stack or vent information.

Detailed emissions unit information.

Emission data.

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

Compliance Requirements A compliance certification statement for all requirements thatapply.

A compliance plan to provide for long-term compliance with allrules that apply.

A compliance schedule to correct any noncompliance

9.2 When were complete permit applications due?

Due dates for complete permit applications were based on SIC codes (see Section 4.0). Table 9-2shows the due dates for air emission permit applications for your entire facility. If you did notsubmit a timely application, this may affect your ability to utilize the modification provisions,described in Part 3: Making Changes.

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

SIC Code Range Application Due Date

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

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

3000 to 4499 June 15, 1995

4500 to 5099, excluding 4953 September 15, 1995

5100 to 8199 December 15, 1995

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


9.3 What happens to your application at the MPCA?

Figure 9-1 is a flowchart showing the steps of the process to issue an air emission permit for yourfacility. After you submit a permit application, the MPCA performs two reviews. During thefirst review, the administrative completeness review, the MPCA checks that your application issigned, uses the MPCA's forms, and has no obvious omissions. The second review is thetechnical completeness review. This is when the MPCA permit engineer analyzes the content andtechnical details of your application. The PTE calculations will be reviewed and rule citationschecked, among other things.

Within 60 days, the MPCA may send a letter telling you if your application is not complete. Ifthe application is not complete, the MPCA will explain what must be added or revised tocomplete the application. Once the application is complete, the process of issuing your permitstarts. PLEASE NOTE THAT IF YOUR APPLICATION IS NOT COMPLETE, THE PROCESSSTOPS AND YOUR PERMIT WILL BE DELAYED.

A complete permit application allows the MPCA permit engineer to continue the process anddraft your permit. The permit engineer may then contact you to discuss your application, askquestions, and request other necessary information. The permit engineer also can answer yourquestions regarding your permit.

Drafts of facility permits and some amendments must have a public notice. The public noticeannounces that the MPCA intends to issue your permit and will accept comments from the publicon the draft permit. The public comment period lasts 30 days. If a facility is within 50 miles of astate border, the neighboring state also reviews the draft permit.

The permit engineer replies to public comments with a letter. The draft permit may have to berevised based on public comments. Occasionally, the comments indicate a need for more analysisor more public participation. These comments are often those that bring to the MPCA's attentionthe extent of public concern over a project, that call into question whether rules were properlyfollowed, or if the right data were used. Public meetings or contested case hearings may be heldto resolve such issues.

The EPA reviews draft air emission permits. For state permits, the EPA review period is 30 days,and occurs at the same time as the public comment period. For Part 70 permits, the EPA has 45days to comment. This 45-day comment period occurs after the 30-day public comment period.If the EPA has comments that require changes to your draft permit, then your draft permit will berevised. If no comments arise that require changes to the draft permit, your permit is issued. Ingeneral, the MPCA will either issue or deny your permit within 18 months from the time yourapplication has passed the technical completeness review.


Figure 9.1Process to Issue an Air Emission Permit for a Total Facility

Complete application package received

��

Acknowledgment sent by support staff �� Within 7 days of receipt of application

��

Completeness determination �� Within 60 days of receipt of application

��

Draft permit written by permit engineer, reviewedby Air Quality staff, and revised as necessary

��

Draft permit reviewed by applicant, possibly revised bypermit engineer

��

Draft permit placed on public notice for 30 days

��

Address comments received during notice period

��

State or Synthetic Minorpermit can be issued

If a Part 70 permit, theEPA gets an additional

45 days to review

��

Resolve all of EPA’scomments and concerns

��

Part 70 permit can beissued


10.0 CASE STUDY -- BLUE OX WOODWORKSA case study has been assembled to show how the concepts in Part 1 fit together. A fictionalfacility, Blue Ox Woodworks, has been created by the MPCA. This case study will be used ineach Part of the Guide. The concepts presented here will show how the forms were completedfor the Blue Ox Woodworks' permit application.

10.1 History of Blue Ox Woodworks

Otto Walder started Blue Ox Woodworks, a small millwork shop, in 1954. Otto saw a need toprovide good quality trim and other milled goods to his neighbors in Central Minnesota. Aformer dairy farmer, Otto named his new company in memory of his favorite ox, Babe.

The original milling operations included saws, planers, shapers, routers and sanders. As muchas 20% of the wood was being thrown away as waste, so Otto and his employees begancollecting the scrap wood from these operations and burning it in the boiler to heat the building.Much of the scrap collected during the summer is stored outside until it is needed.

In 1966, Blue Ox Woodworks added three baghouses to the facility to collect the sawdustgenerated by the various operations. The sawdust was also burned in the boiler. Otto installed adiesel generator to provide backup electricity in case of power disruptions.

In the later 1960s and the early 1970s, Otto replaced all of the original equipment and thenadded to it. Blue Ox Woodworks' production rose and fell over the years, but the maximumproduction rate was 460,000 board feet per year. He sold the milled wood directly toconstruction companies, window manufacturers, and to other small companies who stain, coat,prime and paint the wood before selling it in retail outlets.

In the mid-1980s, Otto's daughter, Phyllis, became the day-to-day head of operations at the BlueOx plant. Phyllis saw an opportunity to increase profits by finishing the millwork internally. In1988, she installed a spray booth. To handle the variety of coatings, Blue Ox Woodworksinstalled four spray guns in the booth. Only two of the four guns are ever used at once, so thecompressor was sized for two guns. Wall filters in the booth control particulate emissions. Asteam-heated dryer is used to dry the finished coating. Solvent vapors from the spray booth andthe dryer are directed to and then burned in a thermal oxidizer.

When her dad retired in 1990, Phyllis became Blue Ox Woodworks' owner and operator. Theplant began to utilize its raw material much more efficiently, and as a result, there was notalways enough wood waste to fuel the boiler, particularly in the winter months. In 1991, Phyllisinstalled a new boiler as a backup, fueled primarily by natural gas, but also able to burn distillateor residual oil.


Blue Ox Woodworks now operates two eight-hour shifts per day, five days a week. The plantshuts down for two weeks in December every year. 1997 was a record production year for BlueOx Woodworks. However, Phyllis was concerned about her limited paint spray booth capacity.Phyllis plans to add an additional spray booth and compressor identical to the current systemsometime in 1999.

The following information lists emission units at Blue Ox Woodworks. Section 10.3 alsoincludes potential to emit calculations for the facility. You may want to review Appendix 5-Awhich includes completed facility description and calculation forms for Blue Ox Woodworks.

10.2 Blue Ox Woodworks Emission Unit Information

Blue Ox Woodworks, Inc.

Owner: Phyllis Walder

Address: 11 Green LaneClear Sky (Dry Rock County), Minnesota 55000

Telephone Number[Fax]:

(218) 555-0011[(218) 555-0012]

Name of Firm: Blue Ox Woodworks, Inc.

SIC Code: 2431 (Millwork)

Previous permits: None

Number of Employees 28

Size of Property 5 acres (buildings are located at least 1/4 mile from nearest residenceor public roadway)

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


Boiler No. 1:Manufacturer: Bunyan Boilers, Inc.

Date installed: 1954

Rated heat input 7.2 million Btu per hour

Fuel: Wood, sawdust

Firing Method: Stoker

Stack Parameters:

Height: 50 feet

Inside exit diameter: 1.5 feet

Exhaust flow rate, acfm: 14,400 @ 300 °F

Boiler No. 2:Manufacturer: Superior Boilers

Date Installed: 1991

Rated Heat Input: 11.5 million Btu per hour

Fuel: Natural gas, distillate oil, residual oil

Stack Parameters:

50 feet



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

10.2.2 Milling operationsBlue Ox Woodworks operates several milling lines: a saw line, a molding line, a planing line,and a sanding line. The saw line consists of a cutoff saw, two table saws, a resaw, and a ripsaw.The molding line has four molders; the planing line has three planers. The sanding line includesfive sanders.

Emissions from the milling lines flow through one of three bag filters. Each has an air-to-clothratio of 8:1. The rated air flows are 20,000, 40,000 and 65,000 acfm (@ 70 °F).

All existing milling equipment was installed between 1969 and 1975. (All of the originalequipment was replaced.) The bag filters were also installed during this time.


Saw line: Molding Line:

Cutoff Saw: Molder:Manufacturer: Norske Manufacturer: BuzzsawDate installed: 1974 Date installed: 1973

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

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

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

Ripsaw:Manufacturer: RipleyDate installed: 1974

Planing line: Sanding Line:

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



Sander:Manufacturer: LoonDate installed: 1976

Sander:Manufacturer: LoonDate installed: 1976


Baghouse No. 1Manufacturer: Ladyslipper


Model: 143 AB 94

Air to cloth ratio: 8:1

Flow rate, acfm: 65,000 @ 70 ºF

Manufacturer's recommended pressure drop: 2 - 4 inches water column (W.C.)

Stack Parameters:

Height 24 feet

Inside exit diameter: 2.0 feet by 8 feet




Model: 143 AB 94



Manufacturer's recommended pressure drop: 2 - 4 inches W.C.

Stack Parameters:

Height 24 feet





Model: 143 AB 94



Manufacturer's recommended pressure drop: 2 - 4 inches W.C.

Stack Parameters:

Height 24 feet




10.2.3 Painting operationsThe spray booth contains four guns, only two of which can operate simultaneously. (Thecompressor for the booth will only produce enough pressure for two guns.) The process isairless spray so the transfer efficiency is 45 percent. Each gun is rated at 5 gallons per hour.

The coating process uses white paint, sealer, wipe stain, basecoat, and mineral spirits forcleanup. They also use a proprietary paint and stain identified as “paint 1A” and “stain 2A.”The properties of these materials are shown in a table in Section 10.3.4.

The booth is equipped with wall filters capable of collecting 90 percent of captured particulateemissions. [The booth is a hood-type design, so not all emissions are captured; 80% of the totalparticulate matter is captured.] Sixty percent (60%) of the Volatile Organic Compound (VOC)emissions flow to a thermal oxidizer that destroys 90 percent of the VOCs it receives. Theremaining 40% of the VOC emissions escape into the atmosphere. The thermal oxidizercombusts 5 million Btu per hour of natural gas.

Spray Booth: Wall Filter:Manufacturer: Blizzard Manufacturer: Northwind FiltersDate installed: 1988 Date Installed: 1988

Control Efficiency: 72% PM10 (80% is captured,90% of that is collected)

Spray Guns:Manufacturer: Blizzard Cure Oven:Date installed: 1988 Manufacturer: Great Lakes Ovens

Number of guns: 4 Date installed: 1988Maximum flow rate: 5 gal/hr Operating temperature: 350 °F

Thermal Oxidizer:(Control equipment for spray booth and cure oven.)

The control and capture efficiency for thermal oxidizer are based on the manufacturer'sguarantee.

Manufacturer: Inferno Control Systems


Fuel: Natural Gas

Rating: 5 million Btu/hr

Control efficiency (VOCs): 90 percent (VOCs)

Capture efficiency(spray booth & oven VOCs)

60 percent (VOCs)

Operating temperature, combustion chamber: 1400 °F

Volume, combustion chamber: 525 cubic feet

Residence time: 0.75 seconds


Stack Parameters:

Height: 45 feet



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

10.2.4 Diesel generatorThe diesel generator, installed in 1966, produces 225 horsepower of electrical output. It is usedas an emergency generator, and typically operates less than 90 hours per year.

Manufacturer: Powerhouse


Rated electrical output: 225 horsepower

Fuel: Diesel

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

10.2.6 Insignificant activities• The facility was painted during the last year.

• A copier and a laser printer are used in the office portion of the facility.

• There are some bathroom vents.

• The employees park in a gravel parking lot.

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


10.3.1 Wood boiler #1 calculationsRated heat input: 7.2 MMBtu/hour

Heat content of wood: 8.0 MMBtu/ton

• AP-42 emission factors for wood boilers in pounds per ton of wood:PM PM10 SO2 NOX VOC CO Pb8.80 7.90 0.01 1.50 0.22 13.60 0.00

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

7 2 MMBtuhour

1 ton of wood8 MMBtu

8 8 lbs PMton of wood

1 ton PM2000 lbs PM

8760 hoursyear

34 6 9 tpy. . .× × × × =

• Potential emissions based on AP-42, in tpy:PM PM10 SO2 NOX VOC CO Pb

34.69 31.14 0.04 5.91 0.87 53.61 0.00

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

0 6 lbs PMMMBtu

7 2 MMBtuhour

8760 hoursyear

1 ton PM2000 lbs PM

18 92 tpy. . .× × × =

• Potential Emissions including State Rule limitations:PM PM10 SO2 NOX VOC CO Pb

18.92 18.92 0.04 5.91 0.87 53.61 0.00

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

PM PM10 SO2 NOX VOC CO Pb0.81 0.71 0.01 0.14 0.02 1.25 0.00


10.3.2 New boiler #2 calculationsRated heat input: 11.5 MMBtu/hour

Gas: 1000 Btu/cubic foot

Distillate: 140,000 Btu/gal, 1% sulfur

Residual: 150,000 Btu/gal, 2% sulfur

NATURAL GAS CALCULATIONS

• AP-42 emission factors for natural gas, in pounds per million cubic feet (MMcf):PM PM10 SO2 NOX VOC CO Pb HAPs*7.6 7.6 0.60 100.0 5.5 84.0 0.0005 1.89

*Total HAPs; itemization of which pollutants are emitted is included in Appendix 5-A, Form EC-13C.

• Sample Calculation (PM):

11.5 MMBtuhour

1 MMcf1000 MMBtu

7.6 lb PMMMcf

8760 hoursyear

1 ton2000 lb

0.383 tpy× × × × =

• Potential emissions for natural gas based on AP-42:PM PM10 SO2 NOX VOC CO Pb HAPs

0.383 0.383 0.03 5.04 0.28 4.23 0.00 0.095

• 1997 Actual Emissions (based on 28.8 MMcf of natural gas used):PM PM10 SO2 NOX VOC CO Pb HAPs

0.109 0.109 0.009 1.44 0.079 1.21 0.00 0.027

RESIDUAL OIL CALCULATIONS

• AP-42 Emission Factors for residual oil in lb/1000 gallons:PM PM10 SO2 NOX VOC CO Pb HAPs*

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

• AP-42 Emission Factors corrected for 4% sulfur:PM PM10 SO2 NOX VOC CO Pb HAPs39.2 34.7 636 55.00 0.28 5.00 0.0042 0.156


11.5 MMBtuhour

1 gallon150,000 Btu

1,000,000 BtuMMBtu

39.2 lb PMgallon

8760 hoursyear

1 ton2000 lb

13.16 tpy× × × × × =


• Potential emissions for residual oil based on AP-42:PM PM10 SO2 NOX VOC CO Pb HAPs

13.18 11.65 213.6 18.47 0.094 1.68 0.001 0.057

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

DISTILLATE OIL CALCULATIONS

• AP-42 emission factors for distillate oil in lb/1000 gallons:PM PM10 SO2 NOX VOC CO Pb HAPs*2.00 1.00 144S 20.00 0.20 5.00 0.0004 0.082

*Total HAPs; itemization of which pollutants are emitted are included in Appendix 5-A, Form EC-13C.

• AP-42 emission factors corrected for 1% sulfur:PM PM10 SO2 NOX VOC CO Pb HAPs2.00 1.00 144 20.00 0.20 5.00 0.0004 0.082


11.5 MMBtuhour

1 gallon140,000 Btu

1,000,000 BtuMMBtu

2 lb PMgallon

8760 hoursyear

1 ton2000 lb

0.72 tpy× × × × × =

• Potential emissions for distillate oil based on AP-42:PM PM10 SO2 NOX VOC CO Pb HAPs0.72 0.36 51.77 7.20 0.07 1.80 0.00 0.130

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

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

PM PM10 SO2 NOX VOC CO Pb HAPs13.18 11.65 213.6 18.47 0.28 4.23 0.001 0.130

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

0.4 lb PMMMBtu

11.5 MMBtuhour

8760 hoursyear

1 ton2000 lb

20.15 tpy× × × =

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


10.3.3 Milling equipment calculations• Potential PM Emissions based on baghouse manufacturer’s guarantee (Option 3 on

Form EC-11, assumption is that all PM is PM10): Guaranteed emission rate = 0.02 gr/dscf for each baghouse

SV #3: 35,000 dscfmin

0.02 grainsdscf

525,600 minyear

1 lb7000 grains

1 ton2000 lb

26.3 tpy× × × × =

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

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

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

25,000 dscfmin

0.066 grainsdscf

525,600 minyear

1 lb7000 grains

1 ton2000 lb

62.1 tpy× × × × =

• 1997 actual emissions (SV#3, #4, and #5 combined):PM: 17.45 tpyPM10: 17.45 tpy

10.3.4 Painting equipment calculationsSpray Booth Parameters:

• 4 spray guns, 5 gallons per hour each

• Transfer efficiency of airless spray (Y) = 45%

• Thermal oxidizer destruction efficiency = 90%

• Wall filter control efficiency = 90%

• PM Capture efficiency = 80%

• VOC Capture efficiency = 60%

There is one spray booth at the facility. The booth is used to spray stain and varnish, as well asprimer (basecoat) and paint. There are 4 guns in booth; however, only 2 guns can be used at atime due to compressors. The potential emissions are the highest emission rates for VOC andparticulates given the coatings available.


WhitePaint Sealer

WipeStain Basecoat Paint 1A Stain 2A

Coating reference number 1 2 3 4 5 6

Density (lb/gal) 9.85 8.06 7.54 9.14 7.5 7.3

VOC content (lb/gal) 7.39 5.56 7.24 5.64 5.1 6.0

Solid content (lb/gal) 2.46 2.5 0.3 3.5 2.4 1.3

1997 usage (gals) 4000 5200 2000 1000 1200 500

HAPs content (lb/gal)

Methyl ethyl ketone 0.528 0 0 0 0.492 0

Methyl isobutyl ketone 0 0.377 0.140 0 0.82 0

Toluene 0.025 0.377 0.365 0 1.312 0

Xylene 0 1.885 1.46 0 0.902 0

Total Volatile HAPs 0.553 2.64 1.97 0 3.53 0

Cadmium Compounds 0.014 0 0 0.019 0 0.022

Lead Compounds 0.006 0 0 0.008 0 0

Total PM HAPs 0.02 0 0 0.027 0 0.022

Phyllis looked at using the Minnesota control equipment performance standard (Minn. R.7011.0060 - 7011.0080) for the thermal oxidizer and spray filters. The control efficiencieslisted in the rule are 57% overall reduction for VOC (includes both capture and control) and74% overall reduction for PM. The equipment currently obtains 54% overall reduction for VOCand 72% for PM. Phyllis doesn’t think it would be reasonable to make improvements to theefficiencies at this time, or to spend the money to do performance tests as required by the rule,so she decided not to use the Minnesota performance standard in her permit application.(Applicability of this particular standard is at the discretion of the applicant - it can be used tothe applicant’s benefit if all conditions can be met. See also the fact sheet entitled “ControlEquipment Standards,” attached in Appendix 6-A.)

CALCULATIONS

• VOC (before controls):

2 guns 5 galhour

8760 houryear

X lb VOCgal

1 ton2000 lb

uncontrolled VOC, tpy× × × × =


Coating No. 1 VOC PTE = 323.68 tons per year






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







Controlled PTE, coatingoperations = 148.89 tons per year (occurs when Coating No. 1 is

used 100% of the time.)

• PM (before controls):

2 guns 5 galhour

8760 houryear

X lb PMgal

1 ton2000 lb

uncontrolled PM, tpy× × × × × − =( )1 Y

Coating No. 1 PM PTE = 59.26 tons per year







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









• PM allowed by State Rules:At exhaust flow rate of 10,000 actual cubic feet per minute and exhaust temperature of300 °F, allowed PM is 0.1 gr/dscf, or 5.95 lb/hr, or 26.08 tons per year.

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

2 guns 5 galhour

8760 houryear

X lb MEKgal

1 ton2000 lb

uncontrolled MEK, tpy× × × × =

Coating No. 1 MEK PTE = 23.13 tons per year


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





• Methyl Isobutyl Ketone (MIbK) (before controls):

2 guns 5 galhour

8760 houryear

X lb MIbKgal

1 ton2000 lb

uncontrolled MIbK, tpy× × × × =


Coating No. 2 MIbK PTE = 16.51 tons per year



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






• Toluene (before controls):

2 guns 5 galhour

8760 houryear

X lb toluenegal

1 ton2000 lb

uncontrolled toluene, tpy× × × × =

Coating No. 1 Toluene PTE = 37.58 tons per year




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







• Xylene (before controls):

2 guns 5 galhour

8760 houryear

X lb xylenegal

1 ton2000 lb

uncontrolled xylene, tpy× × × × =


Coating No. 2 Xylene PTE = 82.56 tons per year



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






• Cadmium (Cd) compounds (before controls):

2 guns 5 galhour

8760 houryear

X lb Cd compoundsgal

1 ton2000 lb

uncontrolled Cd compounds, tpy× × × × × − =( )1 Y

Coating No. 1 Cd compound PTE = 0.60 tons per year



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




Controlled PTE, coatingoperations = 0.27 tons per year (occurs when Coating No. 6

is used 100% of the time.)

• Lead (Pb) compounds (before controls):

2 guns 5 galhour

8760 houryear

X lb Pb compoundsgal

1 ton2000 lb

uncontrolled Pb compounds, tpy× × × × × − =( )1 Y

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



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



Controlled PTE, coatingoperations = 0.10 tons per year (occurs when Coating No. 4

is used 100% of the time.)

• Total HAPs = Total volatile HAPs + Total PM HAPs (before controls):

2 guns 5 galhour

8760 houryear

X lb vol. HAPsgal

1 ton2000 lb

uncontrolled vol HAPs, tpy× × × × =

2 guns 5 galhour

8760 houryear

X lb PM HSPsgal

1 ton2000 lb

(1 Y) uncontrolled PM HAPs, tpy× × × × × − =

CoatingUncontrolledVolatile HAPs

Uncontrolled PMHAPs

Total UncontrolledHAPs

1 60.71 0.84 61.55 tons per year

2 115.59 0 115.59 tons per year

3 86.33 0 86.33 tons per year

4 0 1.2 1.2 tons per year

5 154.44 0 154.44 tons per year

6 0 0.96 0.96 tons per year

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

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

CoatingControlled

Volatile HAPsControlledPM HAPs

Total ControlledHAPs

1 27.93 0.24 28.17 tons per year2 53.17 0 53.17 tons per year3 39.71 0 39.71 tons per year4 0 0.34 0.34 tons per year5 71.04 0 71.04 tons per year6 0 0.27 0.27 tons per yearControlled Total HAP PTE,coating operations = 71.04 tons per year (occurs when Coating No. 5 is used 100%

of the time.)


• 1997 Actual Emissions for Painting/Coating (based on actual usage):

Pollutant Tons/yearPM/PM10 4.27VOC 27.53MEK 0.62MIbK 0.74Toluene 1.77Xylenes 3.18Cd Compounds 0.02Lead Compounds 0.01Total HAPs 6.34

Thermal Oxidizer• Capacity = 5 MMBtu/hour

• Fuel = Natural gas

• AP-42 Emission Factors for natural gas in pounds per MMcf:PM PM10 SO2 NOX VOC CO Pb7.6 7.6 0.60 100 5.5 84 0.0005


5 MMBtuhour

1 MMcf1000 MMBtu

7.6 lb PMMMcf

8760 hoursyear

1 ton2000 lb

0.166 tpy× × × × =

• Potential emissions for oxidizer based on AP-42:PM PM10 SO2 NOX VOC CO Pb

0.166 0.166 0.013 2.19 0.12 1.84 0.00

• 1997 Actual Emissions for Oxidizer (based on 11 MMcf natural gas usage):PM PM10 SO2 NOX VOC CO Pb

0.042 0.042 0.003 0.55 0.03 0.462 0.00

Clean-up Materials (Mineral Spirits)Since Blue Ox reclaims the solvent used for cleanup, it is difficult to determine exactly what thepotential emissions are. By looking at records of how much mineral spirits they purchase in ayear and how much they ship out as waste, they can calculate how much is allowed to evaporatein a year. That number can then be scaled up to what it might be if they really operated 8760hours per year.

In 1997, Blue Ox operated 4000 hours, and used the most mineral spirits they ever had: 800gallons. By multiplying 800 gallons per 4000 hours by 8760 hours per year, and doubling their


answer as a safety factor (assuming that they could conceivably use the mineral spirits at twicetheir normal rate if they weren’t careful), they came up with a quantity of mineral spirits peryear.

Density of mineral spirits = 7.2 pounds per gallon

VOC content = 100% = 7.2 pounds per gallon

800 gallons4000 hours

2 8760 hoursyear

7.2 pounds VOCgallon

1 ton2000 pounds

12.61 tpy× × × × =

10.3.5 Diesel generator calculationsThis is an emergency generator. By authority of an EPA guidance memo dated September 6,1995, Blue Ox (or any operator of an emergency generator meeting the requirements of thememo) can assume 500 hours of operation when calculating unrestricted PTE. This is becauseengines designed for emergency use are typically not designed for and not capable of running8760 hours per year.

Rated Heat Input = 2.1 MMBtu/hour

• AP-42 emission factors, in pounds per MMBtu:PM PM10 SO2 NOX VOC CO Pb0.31 0.31 0.29 4.41 0.36 0.95 0.00

• Sample calculation (PM):

2.1 MMBtuhour

0.31 poundsMMBtu

500 hoursyear

1 ton2000 pounds

0.2 tpy× × × =

• Potential emissions based on AP-42 emission factors, in tons per year:PM PM10 SO2 NOX VOC CO Pb0.2 0.2 0.152 2.32 0.189 0.5 0.00

• 1997 Actual Emissions, based on 90 hours of operation:PM PM10 SO2 NOX VOC CO Pb

0.028 0.028 0.026 0.393 0.032 0.085 0.00


10.3.6 Summary of all potential to emit calculations• Total uncontrolled total PTE, in tons per year:

PM PM10 SO2 NOX VOC CO Pb400.4 398.8 213.8 28.9 337.7 60.2 0.00

MEK MIbK Toluene XyleneCd

compoundsPb

compoundsTotalHAP

23.1 35.9 57.5 82.6 1.0 0.4 154.6

• Total controlled total PTE:PM PM10 SO2 NOX VOC CO Pb65.0 63.5 213.8 28.9 162.9 60.2 0.00


compoundsPb

compoundsTotalHAP

10.6 16.5 26.4 38.0 0.3 0.1 71.2

• 1997 actual emissions:PM PM10 SO2 NOX VOC CO Pb11.5 11.4 0.05 2.4 37.1 3.0 0.00


compoundsPb

compoundsTotalHAP

2.4 3.8 6.0 8.6 0.06 0.02 16.2

10.3.7 Proposed permit conditions and operating limitsWood Boiler: Will be removed

Gas/Oil Boiler: To comply with NSPS (40 CFR 60, Subpart Dc), Blue Ox will burn onlynatural gas and distillate oil. The oil will contain a maximum of 0.5 weightpercent sulfur. No limit on distillate oil usage is required.

• AP-42 distillate oil emission factors (lbs/1000 gallons) corrected for 0.5% sulfur:PM PM10 SO2 NOX VOC CO Pb HAPs*2.00 1.00 144S 20.00 0.20 5.00 0.0004 0.082

*Total HAPs; itemization of which pollutants are emitted are included in Appendix 5-A, Form EC-13C.

• Distillate oil limited PTE:PM PM10 SO2 NOX VOC CO Pb HAPs0.72 0.36 25.9 7.20 0.07 1.80 0.0001 0.13


Spray Booth Limits:

� Limited to 185 tons/year of VOC usage, assuming 54% overall control.

Basis: To keep the source under 100 tpy for VOC, this is the amount that can be used given theallowable VOC emissions from the boilers and the clean-up solvent.

� Limited to 52 tons/year of Total HAP usage, assuming 54% overall control of volatileHAPs.

Basis: To keep the source under 25 tpy for total HAPs.

� Limited to 20 tons/year of individual HAP usage, assuming 54% overall control of volatileHAPs.

Basis: To keep the source under 10 tpy for each individual HAP.

Clean-Up Solvent:

� Limited to 10 tons/year VOC use (no control)

Basis: Blue Ox commits to this being the absolute maximum they would ever use.

TOTAL LIMITED EMISSIONS:PM PM10 SO2 NOX VOC CO Pb33.6 33.3 26.1 11.7 95.7 6.6 0.00


compoundsPb

compoundsTotalHAP

9.0 9.0 9.0 9.0 9.0 9.0 24.1

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

Appendix 1-AActivities NOT Required To Be Listed In Your ApplicationMinn. Rules Part 7007.1300, subp. 2

A. Fuel use:1. production of hot water for on-site personal use not related to any industrial process;

2. fuel use related to food preparation by a restaurant or cafeteria; and

3. fuel burning equipment with a capacity less than 30,000 BTU/hour, but only if thecombined total capacity of all fuel burning equipment at the stationary source with acapacity less 30,000 Btu per hour is less than or equal to 500,000 BTU/hour.

B. Plant upkeep:1. routine housekeeping or plant upkeep activities not associated with primary

production processes at the stationary source, such as: painting buildings, retarringroofs, paving parking lots, but excluding use of spray paint equipment.

2. routine maintenance of buildings, grounds, and equipment;

3. use of vacuum cleaning systems and equipment for portable steam cleaning;

4. clerical activities such as operating copy machines and document printers, exceptoperation of such units on a commercial basis;

5. janitorial activities; and

6. sampling connections used exclusively to withdraw materials for laboratory analysisand testing.

C. Fabrication operations:1. equipment used for the inspection of metal products;

2. equipment used exclusively for forging, pressing, drawing, spinning, or extrudingcold metals;

3. equipment used exclusively to mill or grind coatings and molding compounds whereall materials charged are in paste form; and

4. mixers, blenders, roll mills, or calendars for rubber or plastics for which no materialsin powder are added and in which no organic solvents, diluents, or thinners are used.

D. Processing operations:1. closed tumblers used for cleaning or deburring metal products without abrasive

blasting;

2. equipment for washing or drying fabricated glass or metal products, if no VOCs areused in the process, and no gas, oil, or solid fuel is burned;

3. equipment venting particulate matter (PM) or particulate matter less than 10 microns(PM-10) inside a building provided that emissions from the equipment:

(a) are vented inside of the building 100% of the time; and


(b) do not use air filtering systems used to control indoor air emissions; and

4. blast cleaning operations using suspension of abrasive in water.

E. Storage tanks:1. pressurized storage tanks for anhydrous ammonia, liquid petroleum gas (LPG), liquid

natural gas (LNG), or natural gas;

2. storage tanks holding lubricating oils;

3. above and below ground fuel oil storage tanks with a combined total tankagecapacity of less than 100,000 gallons; and

4. gasoline storage tanks with a combined total tankage capacity of less than 2000gallons.

F. Drain, waste, and vent piping:1. stacks or vents to prevent escape of sewer gases through plumbing traps, not

including stacks and vents associated with processing at wastewater treatment plants;

2. sewer maintenance access covers and shafts;

3. sludge and septage landspreading sites;

4. sludge loadout pumping operations for publicly owned treatment works with adesign flow less than 5,000,000 gallons per day; and

5. odor control systems on components of publicly owned treatment works collectionsystems.

G. Residential activities:typical emissions from residential structures, not including the following:

1. fuel burning equipment with a total capacity of 500,000 Btu/hour or greater; and

2. emergency backup generators.

H. Recreational activities:use of the following for recreational purposes:

1. fireplaces;

2. barbecue pits and cookers; and

3. kerosene fuel use.

I. Health care activities:activities and equipment directly associated with the diagnosis, care, and treatment ofpatients in medical or veterinary facilities or offices, not including support activitiessuch as power plants, heating plants, emergency generators, incinerators, or otherunits affected by applicable requirements as defined in Minn. R. 7007.0100, subp. 7.


J. Miscellaneous:1. safety devices, such as fire extinguishers, if associated with a permitted emission

source, but not including sources of continuous emissions;

2. flares to indicate danger to the public;

3. vehicle exhaust emissions from the operation of mobile sources at a stationarysource;

4. purging of natural gas lines;

5. natural draft hoods, natural draft ventilation, comfort air conditioning, or comfortventilating systems not designed or used to remove air contaminants generated by, orreleased from specific units of equipment;

6. funeral home embalming processes and associated ventilation systems; and

7. use of consumer products, including hazardous substances as that term is defined inthe Federal Hazardous Substances Act, where the product is used at academic andhealth care institutions in the same manner as normal consumer use.

K. Demonstration project conducted by a teaching institutionwhere the sole purpose of a demonstration project is to provide an actual functionalexample of a process unit operation to the students or other interested persons, whereactual operating hours of each emissions unit must not exceed a total of 350 hours ina calendar year and where the emissions unit is not used to dispose of wastematerials.

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

Appendix 1-BInsignificant Activities REQUIRED To Be Listed In Your ApplicationMinn. Rules Part 7007.1300, subp. 3

The activities described below must be listed in your permit application. Under Minn. R.7007.0500, subp. 2(C)(2), the MPCA may require you to submit calculations of emissions fromthese emission units. You must calculate emissions from these emission units and include themin your permit application if any of the following are true:

1) the emissions units are subject to additional requirements under Section 114(a)(3) ofthe Clean Air Act;

2) the emissions units are subject to Hazardous Air Pollutant requirements underSection 112 of the Clean Air Act;

3) the emissions units are part of a Title I modification; or

4) if accounted for, the emissions units make the stationary source subject to a part 70permit.

A. Fuel use:space heaters fueled by, kerosene, natural gas, or propane. A space heater is a heatingunit that is not connected to piping or ducting to distribute the heat.

B. Furnaces, boilers, and incinerators:1. infrared electric ovens; and

2. fuel burning equipment with a capacity less than 500,000 Btu/hour but only if thetotal combined capacity of all fuel burning equipment at the stationary source with acapacity less than 500,000 Btu per hour is less than or equal to 2,000,000 Btu/hour.

C. Fabrication operations:equipment used exclusively for forging, pressing, drawing, spinning, or extruding hotmetals.

D. Processing operations:1. open tumblers with a batch capacity of 1,000 pounds or less; and

2. Equipment venting particulate matter (PM) or particulate matter less than 10 microns(PM-10) inside a building, provided that emissions from the equipment are:

a) filtered through an air cleaning system; and

b) vented inside of the building 100% of the time.

E. Storage tanks:1. gasoline storage tanks with a combined total tankage capacity of not more than

10,000 gallons; and


2. non-hazardous air pollutant VOC storage tanks with a combined total tankagecapacity of not more than 10,000 gallons of non-hazardous air pollutant VOCs andwith a vapor pressure of not more than 1.0 psia at 60 degrees Fahrenheit.

F. Cleaning operations:commercial laundries, not including dry cleaners and industrial launderers.

G. Emissions from a laboratoryas defined in this item: "Laboratory" means a place or activity devoted to experimentalstudy or teaching in any science, or to the testing and analysis of drugs, chemicals,chemical compounds or other substances, or similar activities, provided that theactivities described in this sentence are conducted on a laboratory scale. Activities areconducted on a laboratory scale if the containers used for reactions, transfers, and otherhandling of substances are designed to be easily and safely manipulated by one person. Ifa facility manufactures or produces products for profit in any quantity, it may not beconsidered to be a laboratory under this item. Support activities necessary to theoperation of the laboratory are considered to be part of the laboratory. Support activitiesdo not include the provision of power to the laboratory from sources that provide powerto multiple projects or from sources which would otherwise require permitting, such asboilers that provide power to an entire facility.

H. Miscellaneous:1. total usage of less than 200 gallons of VOC (including hazardous air pollutant-

containing VOC) combined in any consecutive 12 months period at a stationarysource, where gallons of VOC equals volume percentage of VOC multiplied by thegallons of VOC-containing material, except that if the owner or operator ships VOCoff-site for recycling, the amount recycled may be subtracted from the amount of VOCused. "Recycling" means the reclamation or reuse, as defined in part 7045.0020, of aVOC. If the owner or operator ships VOC off-site for recycling, the owner or operatorshall keep records of the amount of material shipped off-site for recycling and thecalculations done to determine the amount to subtract. Records may be MSDS,invoices, shipping papers, or hazardous waste manifests;

2. equipment used exclusively for packaging lubricants or grease;

3. equipment used for hydraulic or hydrostatic testing;

4. brazing, soldering or welding equipment;

5. blueprint copiers and photographic processes;

6. equipment used exclusively for melting or application of wax;

7. nonasbestos equipment used exclusively for bonding lining to brake shoes; and

8. cleaning operations: alkaline/phosphate cleaners and associated cleaners andassociated burners.

I. Individual emissions units at a stationary source, each of which have apotential to emit the following pollutants in amounts less than:1. 4,000 lbs/year of carbon monoxide; and


2. 2,000 lbs/year each of nitrogen oxide, sulfur dioxide, particulate matter, particulatematter less than ten microns, volatile organic compounds (including hazardous airpollutant-containing VOC), and ozone.

J. Fugitive Emissions from roads and parking lotsexcept from a stationary source applying for an Option D registration permit underMinn. R. 7007.1130.

K. Infrequent use of spray paint equipmentfor routine housekeeping or plant upkeep activities not associated with primaryproduction processes at the stationary source, such as spray painting of buildings,machinery, vehicles, and other supporting equipment.

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

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

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

A. 5.7 lbs/hr of carbon monoxide;B. potential emissions of 2.28 lbs/hr or actual emissions of one ton per year

for nitrogen oxides, sulfur dioxide, particulate matter, particulate matter less than tenmicrons, and volatile organic compounds; and

C. for hazardous air pollutants, emissions units with:1. potential emissions of 25 percent or less of the hazardous air pollutant thresholds

listed in Minn. R 7007.1300, subp. 5; or

2. combined HAP actual emissions of one ton per year unless the emissions unit emitsone or more of the following HAPs: carbon tetrachloride;1,2-dibromo-3-chloropropane; ethylene dibromide; hexachlorobenzene; polycyclicorganic matter; antimony compounds; arsenic compounds, including inorganic arsine;cadmium compounds; chromium compounds; lead compounds; manganesecompounds; mercury compounds; nickel compounds; selenium compounds;2,3,7,8-tetrachlorodibenzo-p-dioxin; or dibenzofuran. If the emissions unit emits oneor more of the HAPs listed in this subitem, the emissions unit is not an insignificantactivity under this subitem.


APPENDIX 2-AList Of References and Ordering Information

Air Pollution Engineering ManualAir and Waste Management Association. 1992.Air and Waste Management AssociationPublications DepartmentP.O. Box 2861Pittsburgh, PA 15230Telephone: 412-232-3444

Air Quality PermitsA Handbook for Regulators and IndustryState and Territorial Air Pollution Program Administrators and the Association of Local AirPollution Control Officials.Washington, D.C. 1991

Code of Federal Regulations (CFR)Protection of Environment - Section 40, Parts 1-99July 1996 RevisionNational Technical and Information Service5285 Port Royal RoadSpringfield, Virginia 22161Telephone: 703-487-4650FAX: 703-321-8547Also available via the Internet at the following address:

http://earth1.epa.gov/epacfr40/chapt-I.info/subch-C/40P0060/

EPA Policy Memos and Guidances3 volume setFor sale by:Air and Waste Management AssociationPublications DepartmentP.O. Box 2861Pittsburgh, PA 15230Telephone: 412-232-3444Many EPA memos and Guidance Documents are also available via the Internet at the followingaddress: http://www.epa.gov/ttn/


Minnesota Rules, Parts 4410, 7002, 7005, 7007, 7009, 7011, 7017, 7019, 7021, 7030For sale by:Print Communication DivisionDepartment of Administration117 University AvenueSt. Paul, Minnesota 55055Telephone: 651-297-3000 or 1-800-652-9747Also available via the Internet at the following address:

http://www.pca.state.mn.us/air/air_mnrules.html

New Source Review Workshop Manual: Prevention of Significant Deterioration andNonattainment Area Permitting - Draft October 1990.U.S. Environmental Protection AgencyOffice of Air Quality Planning and StandardsFor sale by:Air and Waste Management AssociationPublications DepartmentP.O. Box 2861Pittsburgh, PA 15230Telephone: 412-232-3444

Standard Industrial Classification (SIC) ManualExecutive Office of the PresidentOffice of Management and Budget[Although the SIC codes were replaced in 1997 by the North American Industry Classification,SIC codes are still referenced in some rules. Copies of the SIC Manual may be available from:National Technical and Information Service5285 Port Royal RoadSpringfield, Virginia 22161Telephone: 703-487-4650FAX: 703-321-8547)

U.S. EPA Public Information CenterPM-211B401 M Street SWWashington, DC 20460Telephone: 202-260-7751FAX: 202-260-6257Also available at local libraries.EPA’s Internet address is: http://www.epa.gov


EPA Emission Factor References

AIRS Facility Subsystem Source Classification Codes and Emission Factor List for CriteriaAir PollutantsEPA #450/4-90-003AIRS information is also available via the Internet through the following address:

http://www.epa.gov/ttn/direct.html

AP-42 Compilation of Air Pollutant Emission FactorsVolume I. Stationary Point and Area Sources 5th EditionAP-42, including all supplements, is also available via the Internet at the following address:

http://www.epa.gov/ttn/chief/ap42.htmlAP-42 and its supplements compile emission factors and descriptions of the activities thatproduct criteria pollutant emissions for most stationary point and area sources.. The emissionsdata in the AP-42 document have been gathered from source tests, material balance studies, andengineering estimates. Volume II of AP-42 contains information on mobile source emissions.

Air Toxics Emission Factor References

Toxic Air Pollutant Emission Factors - A compilation for Selected Air Toxic Compounds and SourcesEPA-450/2-88-006a.

VOC Species Manual, Vol. 1: Volatile Organic Compound Species ProfilesEPA 450/2-90-0012.

These reports contain emission factors and chemical speciation profiles for various sources ofVOC and PM emissions. Each profile lists the elements or compounds identified as beingemitted by a source category or process according to the weight percent of each compound as afunction of total VOC or PM emissions. Each individual pollutant specification factor within aprofile can be multiplied against a VOC or PM emission rate for a source of interest to producean estimate of air toxic emissions.

Locating and EstimatingEmissions ... SeriesThese reports are the products of the EPA's ongoing effort to compile and publish information ontoxic pollutants and the source categories for which these emissions have been characterized.These reports are pollutant or source specific. The documents in the series are listed below, andare available via the Internet at the following address:

http://www.epa.gov/ttn/chief/ap42etc.html#LE


Arsenic FormaldehydeBenzene Methyl chloroform1,3-Butadiene Methyl ethyl ketoneCadmium Methylene chlorideChlorobenzenes Polycyclic Organic Matter (POM)Chromium StyreneCyanide TolueneDioxins and furans Vinylidene ChlorideEpichlorohydrin XyleneEthylene Oxide

Order NTIS Documents from:

National Technical Information ServicesU.S. Department of Commerce5285 Port Royal RoadSpringfield, VA 22161Telephone: 703-487-4650FAX: 703-321-8547

Newly published material is sometimes not available from NTIS but can be ordered from:

Superintendent of DocumentsU.S. Government Printing OfficeWashington, D.C. 20402-9375Telephone: 202-783-3238Internet Address: http://www.gpo.gov/


Appendix 3-ANonattainment Area Maps

Carbon Monoxide Nonattainment AreaSeven County Metropolitan Area and Wright County

(Map not available)


Appendix 3-ANonattainment Area Maps

PM10 Nonattainment AreaTwin Cities Area

(Map not available)


Appendix 4-AMandatory EAW CategoriesMinnesota Rules 4410.4300

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

1) Meets or exceeds thresholds given for categories listed below (unless a threshold for EIS ismet or exceeded, in which case an EIS must be prepared)

2) Nuclear fuels and nuclear waste3) Electric generating facilities4) Petroleum refineries5) Fuel conversion facilities6) Transmission lines7) Pipelines8) Transfer facilities9) Underground storage10) Storage facilities11) Metallic mineral mining and processing12) Nonmetallic mineral mining13) Paper or pulp processing mills14) Industrial, commercial, and institutional facilities15) Air Pollution16) Hazardous Waste17) Solid waste18) Wastewater systems19) Residential development20) Campgrounds and RV parks21) Airport projects22) Highway projects23) Barge fleeting24) Water appropriation and impoundments25) Marinas26) Stream diversion27) Wetlands and protected waters28) Forestry29) Animal feedlots30) Natural areas31) Historical places32) Mixed residential and industrial-commercial projects33) Communications towers34) Sports or entertainment facilities35) Release of genetically engineered organisms36) Land use conversion, including golf courses


Appendix 4-BMandatory EIS CategoriesMinnesota Rules 4410.4400

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

1) Meets or exceeds thresholds given for categories listed below2) Nuclear fuels and nuclear waste3) Electric generating facilities4) Petroleum refineries5) Fuel conversion facilities6) Transmission lines7) Underground storage8) Metallic mineral mining and processing9) Nonmetallic mineral mining10) Paper or pulp processing11) Industrial, commercial, and institutional facilities12) Hazardous waste13) Solid waste14) Residential development15) Airport runway projects16) Highway projects17) Barge fleeting facilities18) Water appropriation and impoundments19) Marinas20) Wetlands and protected waters21) Mixed residential and industrial-commercial projects22) Sports or entertainment facilities23) Water diversions24) Pipelines25) Incineration of wastes containing PCBs


Appendix 5-AApplication Forms For Blue Ox Woodworks

MINNESOTA POLLUTION CONTROL AGENCYAIR QUALITY520 LAFAYETTE ROADST. PAUL, MN 55155-4194

PERMIT APPLICATION FORM GI-01FACILITY INFORMATION

5/13/98

1a) AQ Facility ID No.: 99009999

1b) AQ File No.:

2) Facility Name: Blue Ox Woodworks, Inc.3) Facility Location:

Street Address: 11 Green Lane

City: Clear Sky State: MN ZIP Code: 55000

Mailing Address: same as above

City: State: ZIP Code: 4) Corporate/Company Owner:

Name: Phyllis Walder

Mailing Address: 11 Green Lane

City: Clear Sky State: MN ZIP Code: 55000Owner Classification: Private Local Govt State Govt. Federal Govt. Utility

5) Corporate/Company Operator (if different than owner):

Name:

Mailing Address:

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

Name:

Mailing Address:

City: State: ZIP Code: 7) Legally responsible official for this permit/facility:

Mr/Ms: Phyllis Walder Phone: 218-555-0011

Title: Owner Fax: 218-555-0012At (check one): Owner Address Operator Address Emission Facility Address

Other (specify) 8) Contact person for this permit:

Mr/Ms: Phyllis Walder Phone: 218-555-0011Title: Owner Fax: 218-555-0012At (check one): Owner Address Operator Address Emission Facility Address

Other (specify)

9) All billings for annual fees should be addressed to:Mr/Ms: Phyllis Walder Phone: 218-555-0011Title: Owner Fax: 218-555-0012At (check one): Owner Address Operator Address Emission Facility Address

Other (specify)

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

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

12) Facility is: Stationary Portable

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

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

15) Is environmental review required (either an Environmental Assessment Worksheet (EAW) or an Environmental ImpactStatement (EIS)) for this facility? Call the Minnesota Environmental Quality Board for more information (1-800-657-3794, or 296-8253 in the Twin Cities metro area).

Yes NoNote: If you answered “Yes” to this question, you may also be required to perform a state air toxics review foryour facility. Please call 1-800-MINN-AIR or (651)282-5844.

16) Are you required to submit a Toxics Release Inventory (Form R) under SARA Title 313 for this facility? Call theMinnesota Department of Public Safety, Emergency Response Commission for more information (651-297-7372).

Yes No

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

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

19) Are you proposing any alternative operating or emissions trading scenarios in this application (see Minn. R. 7007.0800,subp. 10 and 11)?

Yes NoIf yes, attach a description of your proposal, including a statement on how the proposal will meet all applicablerequirements (in particular, please address federal New Source Review requirements, if applicable). See Form GI-09(C).

MINNESOTA POLLUTION CONTROLAGENCYAIR QUALITY520 LAFAYETTE ROADST. PAUL, MN 55155-4194

PERMIT APPLICATION FORM GI-02PROCESS FLOW DIAGRAM

5/13/98

1) AQ Facility ID No.: 990099992) Facility Name: Blue Ox Woodworks3) Flow Diagram:

Cutoff SawEU003

ResawEU004

Table SawEU005

Table SawEU006

RipsawEU007

CE002

Incoming Wood

Ventilation or air flowProduct Flow

Molder #1EU008

Molder #2EU009

Molder #3EU010

Molder #4EU011

SV003

CE003SV004

Planer #2EU013

Planer #3EU014

Planer #1EU012

CE004

SV005

Sander #1EU015

Sander #3EU017

Sander #2EU016

Sander #4EU018

Sander #5EU019

ToCE004

ToCE004

ToCE004

ToCE004

ToCE004

Product to Paint Line(next page)

Spray BoothEU020

Product fromsanding Cure Oven

EU021

Final Product

CE005

CE001

SV006

Boiler #1EU001

Boiler #2EU002

EmergencyGenerator

EU022SV001

SV002

heat forbuilding

heat forbuilding

SV007

Ventilation or air flowProduct Flow

MINNESOTA POLLUTION CONTROLAGENCYAIR QUALITY520 LAFAYETTE ROADST. PAUL, MN 55155-4194

PERMIT APPLICATION FORM GI-03FACILITY AND STACK/VENT DIAGRAM

5/26/98

1) AQ Facility ID No.: 990099992) Facility Name: Blue Ox Woodworks3) Facility and Stack/Vent Diagram:

flat roof: 15 ft above grade roof = 50 ft at peak, 30 ft atedge

Flat roof = 15 ft

Flat roof = 10 ft

Flat roof = 14 ft

SV001SV004

SV003

SV005

SV006

SV007

SV002

Building 250200 feet

100 feet

North

Property boundary


PERMIT APPLICATION FORM GI-04STACK/VENT INFORMATION

5/26/98

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

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

SV IDNo.

Operator’s DescriptionHeight ofOpening

FromGround

(ft.)

Inside Diameter in ft.(left column only)

orLength x Width in ft.

(both columns)

Design FlowRate at Exit

(acfm)

Exit GasTemperature

(° F)

Rate/TempInformation

Source

DischargeDirection

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

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

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

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

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

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

007 Backup generator 11.0 1.00 1,500 250 E U


PERMIT APPLICATION FORM GI-05APOLLUTION CONTROL

EQUIPMENT INFORMATION5/26/98


3a) 3b) 3c) 3d) 3e) 3f) 3g) 3h) 3i)ControlEquipID No.

CETypeCode

Description Manufacturer Model No. PollutantsControlled

CaptureEfficiency

Destruct/Collect

Efficiency

AfterburnerCombustionParameters

001 021 Thermal Oxidizer Inferno ControlSystems

IF-1400 VOC 60 90 1400 F

002 018 Low Temp FabricFilter

Ladyslipper 143 AB 94 PM 100 99

PM10 100 99



PM10 100 99



PM10 100 99

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

PM10 80 90


PERMIT APPLICATION FORM GI-05BEMISSION UNIT INFORMATION,

PART 15/26/98


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

EmisUnit ID

No.SV IDNo(s).

RelationType

ControlEquipID No.

Emission Unit Operator’s Description Manufacturer Model No.

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

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

003 003 (M)ain 002 Cutoff saw Norske NS001

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

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

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

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

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





PART 15/26/98


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

EmisUnit ID

No.SV IDNo(s).

RelationType

ControlEquipID No.



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



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





020 006 (M)ain 001

005

Spray Booth Blizzard 5000-B



PART 15/26/98


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

EmisUnit ID

No.SV IDNo(s).

RelationType

ControlEquipID No.


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

022 007 (M)ain Emergency Generator Powerhouse G1100



PART 2


3a) 3h) 3i) 3j) 3k) 3l) 3m) 3n) 3o) 3p)Emis

Unit IDNo.

MaximumDesign

Capacity

MaximumDesign Capacity

Units

MaximumFuel Input(MMBTU)

CommenceConstruction

Date(MM/DD/YY)

Initial StartupDate

(MM/DD/YY)

Firing Method (coal-burning units only)

% Fuel forSpace Heat

(boilers only)

Bottle-neck?F = facility

G = group ofsources

SIC Code

001 7.2 1/1/54 100

002 11.5 1/1/91 100

003 1/1/74

004 1/1/69

005 1/1/71

006 1/1/74

007 1/1/74

008 1/1/73

009 1/1/74

010 1/1/76



PART 2


3a) 3h) 3i) 3j) 3k) 3l) 3m) 3n) 3o) 3p)Emis

Unit IDNo.

MaximumDesign

Capacity


Units



Date(MM/DD/YY)

Initial StartupDate

(MM/DD/YY)



(boilers only)


G = group ofsources

SIC Code

011 1/1/76

012 1/1/72

013 1/1/72

014 1/1/75

015 1/1/71

016 1/1/74

017 1/1/74

018 1/1/74

019 1/1/76

020 10 gal/hour 1/1/88



PART 2


3a) 3h) 3i) 3j) 3k) 3l) 3m) 3n) 3o) 3p)Emis

Unit IDNo.

MaximumDesign

Capacity


Units



Date(MM/DD/YY)

Initial StartupDate

(MM/DD/YY)



(boilers only)


G = group ofsources

SIC Code

021 1/1/88

022 175 kW 1/1/66


PERMIT APPLICATION FORM IA-01INSIGNIFICANT ACTIVITIES

(REQUIRED TO BE LISTED)5/26/98

1) AQ Facility ID No.: 99009999

2) Facility Name: Blue Ox Woodworks

3) Description of Activities:

7007.1300, subp. 3 (A) -- 5 space heaters fueled by propane

7007.1300, subp. 3 (H)(3) -- 2 blueprint copiers

7007.1300, subp. 3 (J) -- Fugitive Emissions from roads and parking lots


PERMIT APPLICATION FORM EC-02EXTERNAL COMBUSTION (BOILER) CALCULATION FORM

5/27/98

- Fill out this form for each boiler, or attach sheets with equivalent information.- Instructions begin on Page 6.- If the boiler emits Hazardous Air Pollutants (HAPs), fill out and attach Form EC-13C.1) AQ Facility ID No.: 99009999


3) Emission Unit IdentificationNumber:

001

4) Stack/Vent Designation Number: 001

5) Maximum Rated Boiler Capacity: 7.2 million BTU/hr

6) Control Equipment: NA

7) Fuel Parameters

7a)Fuel Type

7b)% Sulfur

7c)% Ash

7d)Heat Value Units

7e)Fuel Consumption Rate Units

wood 8000000 Btu/ton, Btu/gal, Btu/cf 0.90 ton/hr; gal/hr; cf/hr

NA Btu/ton, Btu/gal, Btu/cf ton/hr; gal/hr; cf/hr

Btu/ton, Btu/gal, Btu/cf ton/hr; gal/hr; cf/hr

When calculating Potential Emissions, use items 8a, 8b, 8d, 8e, 8g, 8h, and 8i (if a limit is proposed in item 12).When calculating Actual Emissions, use items 8a, 8b, 8c, 8f, 8g, and 8j.

8) Calculations Summary - Primary Fuel:

8a 8b 8c 8d 8e 8f 8g 8h 8i 8jPollutant Emission

Factorlb/ton

ActualAnnual

Fuel Use

EmissionRate

MaximumUncontrolled

Emissions

ActualUncontrolled

Emissions

PollutionControl

Efficiency

MaximumControlledEmissions

LimitedControlledEmissions

ActualControlledEmissions

(lbs/ton, lbs/gal,lbs/cf, etc.)

(tons, gallons, cf,etc.)

(lbs/hr) (tons/yr) (tons/yr) (%) (tons/yr) (tons/yr) (tons/yr)

PM 8.8 184 7.92 34.7 0.81 0.00% 34.7 0.0 0.8

PM10 7.9 184 7.11 31.1 0.71 0.00% 31.1 0.0 0.7

SOx 0.01 184 0.01 0.0 0.0 0.00% 0.0 0.0 0.0

NOx 1.5 184 1.35 5.9 0.14 0.00% 5.9 0.0 0.1

VOC 0.22 184 0.20 0.9 0.02 0.00% 0.9 0.0 0.0

CO 13.6 184 12.24 53.6 1.25 0.00% 53.6 0.0 1.3

Lead 0 184 0.00 0.0 0 0.00% 0.0 0.0 0.0


9) Calculations Summary - Back-up Fuel:


FactorActualAnnual

Fuel Use

EmissionRate

MaximumUncontrolled

Emissions

ActualUncontrolled

Emissions

PollutionControl

Efficiency







PM

PM10

SOx

NOx

VOC

CO

Lead


10) Calculations Summary - Back-up Fuel:10a 10b 10c 10d 10e 10f 10g 10h 10i 10j

Pollutant EmissionFactor

ActualAnnual

Fuel Use

EmissionRate

MaximumUncontrolled

Emissions

ActualUncontrolled

Emissions

PollutionControl

Efficiency







PM

PM10

SOx

NOx

VOC

CO

Lead

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

PollutantBefore

OperatingLimits:

AfterOperating

Limits:(tons/yr) (tons/yr)

PM 34.7 0.0PM10 31.1 0.0SOx 0.0 0.0NOx 5.9 0.0VOC 0.9 0.0CO 53.6 0.0Lead 0.0 0.0

12) Operating Limitations, if applicable: (Ignore this item if filling out this form for a Registration Permit Option D)

This boiler will be permanently shut down.


PERMIT APPLICATION FORM EC-02EXTERNAL COMBUSTION (BOILER) CALCULATION FORM

5/27/98

- Fill out this form for each boiler, or attach sheets with equivalent information.- Instructions begin on Page 6.- If the boiler emits Hazardous Air Pollutants (HAPs), fill out and attach Form EC-13C.1) AQ Facility ID No.: 99009999


3) Emission Unit IdentificationNumber:

002


5) Maximum Rated Boiler Capacity: 11.5 million BTU/hr

6) Control Equipment: NA

7) Fuel Parameters

7a)Fuel Type

7b)% Sulfur

7c)% Ash

7d)Heat Value Units


natural gas 1000 Btu/ton, Btu/gal, Btu/cf 11500 ton/hr; gal/hr; cf/hrresidual fuel oil 4.00% 150000 Btu/ton, Btu/gal, Btu/cf 76.67 ton/hr; gal/hr; cf/hr

distillate oil 1.00% 140000 Btu/ton, Btu/gal, Btu/cf 82.14 ton/hr; gal/hr; cf/hr


8) Calculations Summary - Primary Fuel: Natural Gas


Factorlb/MMcf

ActualAnnual

Fuel Use

EmissionRate

MaximumUncontrolled

Emissions

ActualUncontrolled

Emissions

PollutionControl

Efficiency







PM 7.6 28.8 0.087 0.383 0.109 0.00% 0.383 0.383 0.11

PM10 7.6 28.8 0.087 0.383 0.109 0.00% 0.383 0.383 0.11

SOx 0.6 28.8 0.0069 0.03 0.009 0.00% 0.03 0.03 0.009

NOx 100 28.8 1.15 5.037 1.44 0.00% 5.037 5.037 1.44

VOC 5.5 28.8 0.063 0.277 0.079 0.00% 0.277 0.277 0.079

CO 84 28.8 0.97 4.23 1.21 0.00% 4.23 4.23 1.2

Lead 0.0005 28.8 0.000006

0.000025 0.0 0.00% 0.000025 0.000025 0.0


9) Calculations Summary - Back-up Fuel: Residual Oil, 4% sulfur


Factorlb/gal

ActualAnnual

Fuel Use

EmissionRate

MaximumUncontrolled

Emissions

ActualUncontrolled

Emissions

PollutionControl

Efficiency







PM 0.0392 0 3.01 13.18 0 0 13.18 0 0

PM10 0.0347 0 2.66 11.65 0 0 11.65 0 0

SOx 0.636 0 48.76 213.6 0 0 213.6 0 0

NOx 0.055 0 4.217 18.47 0 0 18.47 0 0

VOC 0.00028 0 0.0215 0.094 0 0 0.094 0 0

CO 0.005 0 0.383 1.68 0 0 1.68 0 0

Lead 0.0000042

0 0.00032 0.001 0 0 0.001 0 0


10) Calculations Summary - Back-up Fuel: Distillate Oil, 1% sulfur10a 10b 10c 10d 10e 10f 10g 10h 10i 10j

Pollutant EmissionFactorlb/gal

ActualAnnual

Fuel Use

EmissionRate

MaximumUncontrolled

Emissions

ActualUncontrolled

Emissions

PollutionControl

Efficiency







PM 0.002 0 0.164 0.718 0 0 0.718 0.718 0

PM10 0.001 0 0.082 0.359 0 0 0.359 0.359 0

SOx 0.144 0 11.82 51.77 0 0 51.77 25.90 0

NOx 0.020 0 1.643 7.196 0 0 7.196 7.196 0

VOC 0.00020 0 0.016 0.07 0 0 0.07 0.07 0

CO 0.005 0 0.411 1.80 0 0 1.80 1.80 0

Lead 0.0000004

0 0.000033

0.000144 0 0 0.000144 0.000144 0


PollutantBefore

OperatingLimits:

AfterOperating




This boiler will burn only natural gas and distillate fuel oil (no residual fuel oil). The distillate oil will have a maximum

sulfur content of 0.5 weight % to comply with 40 CFR pt. 60, subp. Dc.


PERMIT APPLICATION FORM EC-13CHAZARDOUS AIR POLLUTANTS

CALCULATION FORM (FUEL COMBUSTION HAPS)5/27/98

- Duplicate this form as necessary, or attach sheets with equivalent information.- Instructions begin on Page 6.


2) Facility Name: Blue Ox Woodworks, Inc.

3) Emission Unit Identification Number: 002


5) Maximum Rated Equipment Capacity: 11.5 million BTU/hr

6) Control Equipment Designation Number: NA

7) Fuel Parameters

7a)Fuel Type

7b)% Sulfur

7c)% Ash

7d)Heat Value Units 7e)

Fuel Consumption Rate Units

natural gas 1000.00 Btu/ton, Btu/gal, Btu/cf 11500.00 tons/hr; gal/hr; cf/hr

distillate fuel oil 1.0% 140000.00 Btu/ton, Btu/gal, Btu/cf 82.14 tons/hr; gal/hr; cf/hr

residual fuel oil 4.0% 150000.00 Btu/ton, Btu/gal, Btu/cf 76.67 tons/hr; gal/hr; cf/hr



8a 8b 8c 8d 8e 8f 8g 8h 8i 8j

HAP Name

(CAS)

EmissionFactor

(lbs/ton,

ActualAnnual Fuel

Use

EmissionRate

MaximumUncontrolled

Emissions

ActualUncontrolled

Emissions

PollutionControl

Efficiency




lbs/gal,lbs/MMcf,

etc.)

(tons, gallons,MMcf, etc.)


benzene (71432) 0.00213 28.8 0.000024 0.0001 0.0000 0 0.0001 0.0001 0.0000

dichlorobenzene (106467) 0.0012 28.8 0.000014 0.00006 0.0000 0 0.00006 0.00006 0.0000

formaldehyde (50000) 0.075 28.8 0.00086 0.0038 0.0011 0 0.0038 0.0038 0.0011

hexane (110543) 1.80 28.8 0.0207 0.0907 0.0259 0 0.0907 0.0907 0.0259

naphthalene (91203) 0.00061 28.8 0.000007 0.00003 0.0000 0 0.00003 0.00003 0.0000

toluene (108883) 0.0034 28.8 0.000039 0.00017 0.0000 0 0.00017 0.00017 0.0000

POM (total) 0.000086 28.8 0.000001 0.000004 0.0000 0 0.000004 0.000004 0.0000

arsenic 0.0002 28.8 0.000002 0.00001 0.0000 0 0.00001 0.00001 0.0000

beryllium 0.000012 28.8 1.38E-8 6.04E-8 0.0000 0 6.04E-8 6.04E-8 0.0000

cadmium 0.0011 28.8 0.000013 0.00006 0.0000 0 0.00006 0.00006 0.0000

chromium 0.0014 28.8 0.000016 0.000071 0.0000 0 0.000071 0.000071 0.0000

manganese 0.00038 28.8 0.000004 0.000019 0.0000 0 0.000019 0.000019 0.0000

mercury 0.00026 28.8 0.000003 0.000013 0.0000 0 0.000013 0.000013 0.0000

nickel 0.0021 28.8 0.000024 0.00011 0.0000 0 0.00011 0.00011 0.0000

selenium 0.000024 28.8 2.76E-7 0.000001 0.0000 0 0.000001 0.000001 0.0000

Total HAP 1.8879 28.8 0.0217 0.0951 0.0272 0 0.0951 0.0951 0.0272


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

9a 9b 9c 9d 9e 9f 9g 9h 9i 9j

HAP Name

(CAS)

EmissionFactor

(lbs/ton,

ActualAnnual Fuel

Use

EmissionRate

MaximumUncontrolled

Emissions

ActualUncontrolled

Emissions

PollutionControl

Efficiency




lbs/gal,lbs/MMcf,

etc.)



formaldehyde (50000) 0.061 0 0.0050 0.0219 0.0000 0 0.0219 0.0219 0.0000

POM (total) 0.0033 0 0.000271 0.0012 0.0000 0 0.0012 0.0012 0.0000

arsenic 0.000588 0 0.00021 0.0002 0.0000 0 0.0002 0.0002 0.0000

beryllium 0.00035 0 0.00013 0.00057 0.0000 0 0.00057 0.00057 0.0000

cadmium 0.0015 0 0.00054 0.00237 0.0000 0 0.00237 0.00237 0.0000

chromium 0.00938 0 0.00338 0.0148 0.0000 0 0.0148 0.0148 0.0000

manganese 0.00196 0 0.00071 0.0031 0.0000 0 0.0031 0.0031 0.0000

mercury 0.00042 0 0.00015 0.00066 0.0000 0 0.00066 0.00066 0.0000

nickel 0.00252 0 0.00091 0.00399 0.0000 0 0.00399 0.00399 0.0000

lead 0.001246 0 0.000045 0.00020 0.0000 0 0.00020 0.00020 0.0000

total HAP 0.08226 0 0.0296 0.1292 0.0000 0 0.1296 0.1296 0.0000

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

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

10a 10b 10c 10d 10e 10f 10g 10h 10i 10j

HAP Name

(CAS)

EmissionFactor

(lbs/ton,

ActualAnnual Fuel

Use

EmissionRate

MaximumUncontrolled

Emissions

ActualUncontrolled

Emissions

PollutionControl

Efficiency




lbs/gal,lbs/MMcf,

etc.)



benzene (71432) 0.000214 0 0.000016 0.000072 0.0000 0 0.000072 0.0000 0.0000

ethylbenzene (100414) 0.0000636 0 0.000005 0.000022 0.0000 0 0.000022 0.0000 0.0000

formaldehyde (50000) 0.033 0 0.00253 0.0111 0.0000 0 0.0111 0.0000 0.0000

naphthalene (91203) 0.00113 0 0.000087 0.00038 0.0000 0 0.00038 0.0000 0.0000

1,1,1-trichloroethane (71556) 0.000236 0 0.000018 0.000079 0.0000 0 0.000079 0.0000 0.0000

toluene (108883) 0.0062 0 0.000475 0.00208 0.0000 0 0.00208 0.0000 0.0000

o-xylene (95476) 0.000109 0 0.000008 0.000035 0.0000 0 0.000035 0.0000 0.0000

POM (total) 0.0013 0 0.00010 0.000438 0.0000 0 0.000438 0.0000 0.0000

antimony 0.00525 0 0.00040 0.00175 0.0000 0 0.00175 0.0000 0.0000

arsenic 0.00132 0 0.00010 0.000438 0.0000 0 0.000438 0.0000 0.0000

beryllium 0.0000278 0 0.000002 0.000009 0.0000 0 0.000009 0.0000 0.0000

cadmium 0.000398 0 0.000031 0.000136 0.0000 0 0.000136 0.0000 0.0000

cobalt 0.00602 0 0.000462 0.00202 0.0000 0 0.00202 0.0000 0.0000

chromium 0.00109 0 0.000084 0.000368 0.0000 0 0.000368 0.0000 0.0000

manganese 0.0030 0 0.00023 0.00101 0.0000 0 0.00101 0.0000 0.0000

mercury 0.000113 0 0.000009 0.000495 0.0000 0 0.000495 0.0000 0.0000

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

10a 10b 10c 10d 10e 10f 10g 10h 10i 10j

HAP Name

(CAS)

EmissionFactor

(lbs/ton,

ActualAnnual Fuel

Use

EmissionRate

MaximumUncontrolled

Emissions

ActualUncontrolled

Emissions

PollutionControl

Efficiency




lbs/gal,lbs/MMcf,

etc.)



Nickel 0.0845 0 0.006479 0.0284 0.0000 0 0.0284 0.0000 0.0000

Lead 0.00151 0 0.000116 0.00051 0.0000 0 0.00051 0.0000 0.0000

Phosphorous 0.00946 0 .000725 0.00318 0.0000 0 0.00318 0.0000 0.0000

Selenium 0.000683 0 0.000052 0.000229 0.0000 0 0.000229 0.0000 0.0000

Total HAP 0 0.01294 0.05669 0.0000 0 0.05669 0.0000 0.0000

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

11a) 11b) 11a) 11b)

HAP Name (CAS)Before

OperatingLimits:

AfterOperating

Limits:HAP Name (CAS)

BeforeOperating

Limits:

AfterOperating

Limits:(tons/yr) (tons/yr) (tons/yr) (tons/yr)

benzene (71432) 0.0001 0.0001 chromium 0.0148 0.0148

ethylbenzene (100414) 0.000022 0 manganese 0.0031 0.0031

formaldehyde (50000) 0.0219 0.0219 mercury 0.00066 0.00066

hexane (110543) 0.0907 0.0907 Nickel 0.0284 0.00399

naphthalene (91203) 0.00038 0.00003 Lead 0.00051 0.00020

1,1,1-trichloroethane (71556) 0.000079 0 Phosphorous 0.00318 0

toluene (108883) 0.00208 0.00017 Selenium 0.000229 0.000001

o-xylene (95476) 0.000035 0 Total HAP 0.1296 0.1296

POM (total) 0.0012 0.0012

antimony 0.00175 0

arsenic 0.00038 0.0002

beryllium 0.00057 0.00057

cadmium 0.00237 0.00237

cobalt 0.00202 0

12) Operating Limitations, if applicable: (Ignore this item if filling out this form for a Registration Permit Option D)This boiler will burn only natural gas and distillate fuel oil (no residual oil).


PERMIT APPLICATION FORM EC-11WOODWORKING OPERATIONS

CALCULATION FORM6/8/98

- This form is used for calculating potential and actual particulate emissions from cutting, sanding, andother woodworking and milling operations. You must complete the Painting and/or CoatingOperations Calculation Form (EC-07) if you paint, varnish or apply any finish to your products. Fillout one copy of this form for each stack/vent, unless information for multiple stacks is identical or ifusing Option 1 or 2 as described below. If using Option 1 or 2, fill out this form for the entire facility.

- Instructions begin on Page 3.

Items 1 - 5 and the calculation summary in the form below must be completed for all options. Not allof the other data fields need to be completed.

- If an emission inventory is used for determining actual emissions, it is not necessary to provideinformation on the past year’s production and operation where requested below.

- Duplicate this form as necessary, or attach sheets with equivalent information

1) AQ Facility ID No. (if known): 99009999


3) Emission Unit Identification Number(s): 003, 004, 005, 006, and 007

4) Stack/Vent Designation Number(s): 003

5) Pollution Control Equipment Identification Number(s) 002

Option 1 - Complete items 6 - 9 if basing emission calculations on the capacity of the entire facility, in board-feet per year. Then go on to item 16.

6) Maximum Capacity of Milling: Bd ft/yr

7) Past Year’s Actual Production: Bd ft

8) Waste Wood Percent of Total Wood: %

9) Density of Wood: lb/ft³

Option 2 - Complete items 10 and 11 if basing emission calculations on published emissions factors. Then goon to item 16.

10) Maximum Capacity of Milling tons logsprocessed/yr

11) Past Year’s Actual Production tons logsprocessed

Option 3 - Complete items 12 - 14 if basing emission calculations on a vendor’s emission guarantee for abaghouse. Then go on to item 16.

12) Baghouse Vendor Guarantee, if applicable: 0.020 gr/dscf

13) Maximum Rated Capacity of Pollution Control Equipment Fan: 35,000 SCFM

14) Past Year’s Hours of Operation of the Baghouse: 2000 hrs

Option 4 - Complete item 15 if basing emission calculations on emission factors for cyclone-controlledoperations. Then go on to item 16.

15) Past Year’s Hours of Operation of the Cyclone: hrs

16) Calculation Summary (use for all options):

16a) 16b) 16c) 16d) 16e) 16f) 16g)

Pollutant EmissionRate

MaximumUncontrolled

Emissions

PollutionControl

Efficiency



ActualEmissions

(lbs/hr) (tons/yr) (%) (tons/yr) (tons/yr) (tons/yr)

PM 6.54 26.28 26.28 6.0PM10 6.54 26.28 26.28 6.0

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




- This form is used for calculating potential and actual particulate emissions from cutting, sanding, and otherwoodworking and milling operations. You must complete the Painting and/or Coating OperationsCalculation Form (EC-07) if you paint, varnish or apply any finish to your products. Fill out one copy of thisform for each stack/vent, unless information for multiple stacks is identical or if using Option 1 or 2 asdescribed below. If using Option 1 or 2, fill out this form for the entire facility.


Items 1 - 5 and the calculation summary in the form below must be completed for all options. Not all of theother data fields need to be completed.

- If an emission inventory is used for determining actual emissions, it is not necessary to provide information onthe past year’s production and operation where requested below.




3) Emission Unit Identification Number(s): 008, 009, 010, and 011










11) Past Year’s Actual Production tons logs processed








16a) 16b) 16c) 16d) 16e) 16f) 16g)

Pollutant Emission

Rate

MaximumUncontrolled

Emissions

PollutionControl

Efficiency



ActualEmissions


PM 5.24 22.98 22.98 5.77PM10 5.24 22.98 22.98 5.77





- This form is used for calculating potential and actual particulate emissions from cutting, sanding, and otherwoodworking and milling operations. You must complete the Painting and/or Coating OperationsCalculation Form (EC-07) if you paint, varnish or apply any finish to your products. Fill out one copy ofthis form for each stack/vent, unless information for multiple stacks is identical or if using Option 1 or 2 asdescribed below. If using Option 1 or 2, fill out this form for the entire facility.

- Instructions begin on Page 3.Items 1 - 5 and the calculation summary in the form below must be completed for all options. Not all of theother data fields need to be completed.

- If an emission inventory is used for determining actual emissions, it is not necessary to provide informationon the past year’s production and operation where requested below.




3) Emission Unit Identification Number(s): 012, 013, 014, 015, 016, 017, 018, and 019










11) Past Year’s Actual Production tons logsprocessed








16a) 16b) 16c) 16d) 16e) 16f) 16g)

Pollutant Emission

Rate

MaximumUncontrolled

Emissions

PollutionControl

Efficiency



ActualEmissions


PM 4.37 19.15 19.15 5.68PM10 4.37 19.15 19.15 5.68



PERMIT APPLICATION FORM EC-07PAINTING/COATING OPERATIONS

CALCULATION8/11/98

- Use this form to calculate emissions from painting and coating operations.

- Attach sheets to show all calculations, and duplicate this form for each booth/operation or attachsheets with equivalent information.

- Use the External Combustion (Ovens, Dryers, Furnaces, etc.) Calculation Form (EC-08) tocalculate emissions from any fuel-fired curing ovens used in this process.

- If the painting/coating operation emits Hazardous Air Pollutants (HAPs), fill out Forms EC-13Aand/or EC-13B.




3) Emission Unit Identification Number(s): 020


5) Control Equipment I.D. Number(s): 001

6) Application Method: Airless Spray

7) Number of Spray Ports in the Booth: 4

8) Oven Curing, if applicable: Number of Ovens: 1

Oven Fuels (if fuel fired): steam from boiler

Total Maximum Rated Heat Input of Ovens: MMBTU/hr

9) Coating Information (attach additional pages if necessary):

9a) 9b) 9c) 9d)Identify Coating VOC Content Solid Content Density

(lb/gal) (lb/gal) (lb/gal)

1 white paint 7.39 2.46 9.85

2 sealer 5.56 2.5 8.06

3 wipe stain 7.24 0.30 7.54

4 basecoat (primer) 5.64 3.5 9.14

5 Paint 1A 5.10 2.4 7.5

6 Paint 2A 6.0 1.3 7.3

7

8

10) Maximum Coating Application Rate: 10 gallons/hour

11) Minimum Transfer Efficiency (%): 45%

12) Potential-to-Emit and Maximum Hourly Allowable Emissions Calculations Summary:

12a) 12b) 12c) 12d) 12e) 12f) 12g) 12h) 12i) 12j)

PollutantMaximum

VOCContent

MaximumSolids

Content

MaximumEmissions

PollutionControl

Efficiency(overall)


Hourly emissionrate allowed byState Rule or

federal regulation


(tons/yr) (lbs/gal) (lbs/gal) (lbs/hr) (tons/yr) (%) (lbs/hr) (tons/yr) (tons/yr)

PM/PM10 3.5 19.25 84.32 72% 5.39 23.61 5.95 17.68

VOC 7.39 73.9 323.68

54% 33.99 148.89 n/a 85

13) Operating Limitations, if applicable

VOC usage limited to 185 tons per year

14) Actual Emissions Calculations Summary:

14a) 14b) 14c) 14d) 14e) 14f) 14g) 14h)

IdentifyCoating

Annualusage

UncontrolledVOC

Emissions

UncontrolledPM/PM10Emissions

VOCControl

Efficiency

PM/PM10Control

Efficiency

ControlledVOC

Emissions

ControlledPM/PM10Emissions

(Gallons) (lbs/yr) (lbs/yr) (%) (%) (tons/year) (tons/year)

1 white paint 4000 29560 9840 54% 72% 6.8 1.38

2 sealer 5200 28912 13000 54% 72% 14.0 1.82

3 wipe stain 2000 14480 600 54% 72% 3.33 0.084

4 primer 1000 5640 3500 54% 72% 1.30 0.49

5 Paint 1A 1200 6120 2880 54% 72% 1.41 0.40

6 Stain 2A 500 3000 650 54% 72% 0.69 0.091

7

8

15a) Total Uncontrolled VOC Emissions, lbs/year: 87712

15b) Total Uncontrolled PM/PM10 Emissions, lbs/year: 30470

16a) Total Controlled VOC Emissions, tons/year: 27.53

16b) Total Controlled PM/PM10 Emissions, tons/year: 4.27


PERMIT APPLICATION FORM EC-13AHAZARDOUS AIR POLLUTANTS

CALCULATION FORM (VOLATILE HAPS)5/27/98


1) AQ Facility ID No.: 990099992) Facility Name: Blue Ox Woodworks, Inc.3) Emission Unit Identification Number: 0204) Stack/Vent Designation Number: 0065) Control Equipment Designation Number: 001 Complete item 6 or 7, not both.

6) Calculations Summary using Material Content:

Potential Emissions (Do not complete this table if using this form for Registration Permit Option D. Go to Actual Emissions Table in item 6.)6a) 6b) 6c) 6d) 6e) 6f) 6g) 6h)

Volatile HAP Name(CAS)

Maximum HAPContent

MaximumMaterial Usage

Rate

MaximumUncontrolled HAP

Emission Rate

MaximumUncontrolled

HAP Emissions

PollutionControl

Efficiency

MaximumControlled HAP

Emissions

LimitedControlled HAP

Emissions(lbs/gal) (gal/hr) (lbs/hr) (tons/yr) (%) (tons/yr) (tons/yr)

Methyl Ethyl Ketone (78933) 0.528 10 5.28 23.13 54.00% 10.64 9.0

Methyl Isobutyl Ketone (108101) 0.82 10 8.20 35.92 54.00% 16.52 9.0

Toluene (108883) 1.312 10 13.12 57.47 54.00% 26.43 9.0

Xylene (1330207) 1.885 10 18.85 82.56 54.00% 37.98 9.0

Total HAP 3.526 10 35.26 154.44 54.00% 71.04 24

Actual Emissions6a) 6i) 6j) 6k) 6l) 6f) 6m)


ActualHAP

Content

Actual MaterialUsageRate

ActualUncontrolled HAP

Emission Rate

ActualUncontrolled

HAP Emissions

PollutionControl

Efficiency

ActualControlled HAP

Emissions(lbs/gal) (gal/hr) (lbs/hr) (tons/yr) (%) (tons/yr)

Coating 1: Methyl Ethyl Ketone(78933)

0.528 10 5.28 1.06 54.00% 0.49

Coating 5: Methyl Ethyl Ketone(78933)

0.492 10 4.92 0.295 54.00% 0.14

Coating 2: Methyl Isobutyl Ketone(108101)

0.377 10 3.77 0.98 54.00% 0.45


0.146 10 1.46 0.146 54.00% 0.07


0.82 10 8.2 0.492 54.00% 0.23

7) Calculations Summary using Emission Factors:

Potential Emissions (Do not complete this table if using this form for Registration Permit Option D. Go to the Actual Emission Table in item 7.)7a) 7b) 7c) 7d) 7e) 7f) 7g) 7h)


MaximumEmission Factor

Maximum HourlyProduction orMaterial Use

MaximumHAP Emission

Rate

MaximumUncontrolled

HAPEmissions

PollutionControl

Efficiency

MaximumControlled

HAPEmissions

LimitedControlled

HAPEmissions

(lbs/hr) (tons/yr) (%) (tons/yr) (tons/yr)



ActualHAP

Content

Actual MaterialUsageRate


Emission Rate

ActualUncontrolled

HAP Emissions

PollutionControl

Efficiency


Emissions(lbs/gal) (gal/hr) (lbs/hr) (tons/yr) (%) (tons/yr)

Coating 1: Toluene (108883) 0.858 10 8.58 1.716 54.00% 0.79

Coating 2: Toluene (108883) 0.377 10 3.77 0.98 54.00% 0.45

Coating 3: Toluene (108883) 0.365 10 3.65 0.37 54.00% 0.17

Coating 5: Toluene (108883) 1.312 10 13.12 0.782 54.00% 0.36

Coating 2: Xylene (1330207) 1.885 10 18.85 4.89 54.00% 2.25

Coating 3: Xylene (1330207) 1.46 10 14.6 1.457 54.00% 0.67

Coating 5: Xylene (1330207) 0.902 10 9.02 0.54 54.00% 0.25

Total HAP 5.40

7) Calculations Summary using Emission Factors:



MaximumEmission Factor


MaximumHAP Emission

Rate

MaximumUncontrolled

HAPEmissions

PollutionControl

Efficiency

MaximumControlled

HAPEmissions

LimitedControlled

HAPEmissions

(lbs/hr) (tons/yr) (%) (tons/yr) (tons/yr)



Actual EmissionFactor

ActualHourly Production

or Material Use


Emission Rate

ActualUncontrolled

HAP Emissions

PollutionControl

Efficiency


Emissions(lbs/hr) (tons/yr) (%) (tons/yr)

8) Operating Limitations, if applicable: (Ignore this item if using the form for Registration Permit Option D).Limit HAP usage such that each individual HAP PTE is 9.0 tpy and combined HAP PTE is 24 tpy.

Control HAP emissions with a thermal oxidizer that will achieve an overall control efficiency of 54% for each volatile HAP.


PERMIT APPLICATION FORM EC-13BHAZARDOUS AIR POLLUTANTS

CALCULATION FORM (PARTICULATE HAPS)5/27/98






5) Control Equipment Designation Number: 005

6) Calculations Summary using HAP Content of Particulate Matter: (Use this table only if you do not have emission factors but know the weight fraction of HAPs in theparticulate matter emitted from the emission unit):

Potential Emissions (Do not complete this table if using this form for Registration Permit Option D. Go to Actual Emissions Table in item 6.)6a) 6b) 6c) 6d) 6e) 6f) 6g) 6h)

Particulate HAP Name(CAS)

MaximumWeight Fraction

HAP in PMEmissions

MaximumUncontrolledPM Emission

Rate

MaximumUncontrolled

HAP EmissionRate

MaximumUncontrolled

HAP Emissions

PollutionControl

Efficiency

MaximumControlled HAP

Emissions

LimitedControlled HAP

Emissions

(lbs/hr) (lbs/hr) (tons/yr) (%) (tons/yr) (tons/yr)



ActualWeight Fraction

HAP in PMEmissions

ActualUncontrolledPM Emission

Rate

ActualUncontrolled

HAP EmissionRate

ActualUncontrolled

HAP Emissions

PollutionControl

Efficiency


Emissions

(lbs/hr) (lbs/hr) (tons/yr) (%) (tons/yr)

7) Calculations Summary using Emission Factors: (Use this table if you have specific emission factors for the HAPs emitted by this type of emission unit in thisindustry):



Maximum HAPEmission Factor


MaximumUncontrolled

HAP EmissionRate

MaximumUncontrolled

HAPEmissions

PollutionControl

Efficiency

MaximumControlled

HAPEmissions

LimitedControlled

HAPEmissions

(lb/gallon) (gal/hour) (lbs/hr) (tons/yr) (%) (tons/yr) (tons/yr)

Cadmium compounds 0.022 10 0.22 0.96 72.00% 0.27 0.27

Lead compounds 0.008 10 0.08 0.36 72.00% 0.10 0.10

Total PM 0.028 10 0.28 1.23 72.00% 0.34 0.34



Actual HAPEmission Factor

ActualHourly Production

or Material Use


Emission Rate

ActualUncontrolled

HAP Emissions

PollutionControl

Efficiency


Emissions(lb/gallon) (gal/hour) (lbs/hr) (tons/yr) (%) (tons/yr)

Coating 1: Cadmium compounds 0.014 10 0.14 0.028 72.00% 0.01



Coating 1: Lead compounds 0.006 10 0.06 0.01 72.00% 0.00

Coating 4: Lead compounds 0.008 10 0.08 0.00 72.00% 0.00

Total PM HAP 0.01

8) Operating Limitations, if applicable: (Ignore this item if using this form for Registration Permit Option D.)

Control particulate matter with wall filters with an overall control efficiency of 72 percent.


PERMIT APPLICATION FORM EC-08EXTERNAL COMBUSTION (OVENS, DRYERS, FURNACES

ETC.) CALCULATION FORM5/27/98

- Fill out this form for each fuel burned in each external combustion unit, or attach sheets with equivalent information.- Instructions start on Page 6.- If the external combustion unit emits Hazardous Air Pollutants (HAPs), fill out and attach Form EC-13C.- If you operate a furnace, oven, or dryer for the purpose of heating a material inside (such as a foundry furnace for melting metals, or a

sweat furnace for recovering metals from scrap, or a grain dryer for drying grain), you must also account for emissions from thematerial being heated/melted/dried. Use Form EC-16 for grain drying. Use Form EC-01 for others.



3) Emission Unit Identification Number: NA -- Thermal Oxidizer


5) Maximum Rated Burner Capacity: 5.0 million BTU/hr

6) Control Equipment: 001

7) Fuel Parameters

7a)Fuel Type

7b)% Sulfur

7c)% Ash

7d)Heat Value Units


natural gas 1000 Btu/ton, Btu/gal, Btu/cf 5000 ton/hr; gal/hr; cf/hr Btu/ton, Btu/gal, Btu/cf ton/hr; gal/hr; cf/hr

Btu/ton, Btu/gal, Btu/cf ton/hr; gal/hr; cf/hr


8) Calculations Summary - Primary Fuel:


Factorlb/MMcf

ActualAnnual

Fuel Use

EmissionRate

MaximumUncontrolled

Emissions

ActualUncontrolled

Emissions

PollutionControl

Efficiency







PM 7.6 11 MMcf 0.038 0.166 0.042 0 0.166 0.166 0.042

PM10 7.6 11 0.038 0.166 0.042 0 0.166 0.166 0.042

SOx 0.6 11 0.003 0.013 0.003 0 0.013 0.013 0.003

NOx 100 11 0.50 2.19 0.55 0 2.19 2.19 0.55

VOC 5.5 11 0.0275 0.120 0.030 0 0.120 0.120 0.030

CO 84 11 0.420 1.84 0.462 0 1.84 1.84 0.462

Lead 0.005 11 0.000025

0.0001 0.00003 0 0.0001 0.0001 0.00003


9) Calculations Summary - Back-up Fuel: NA


FactorActualAnnual

Fuel Use

EmissionRate

MaximumUncontrolled

Emissions

ActualUncontrolled

Emissions

PollutionControl

Efficiency







PM

PM10

SOx

NOx

VOC

CO

Lead


10) Calculations Summary - Back-up Fuel: NA10a 10b 10c 10d 10e 10f 10g 10h 10i 10j


ActualAnnual

Fuel Use

EmissionRate

MaximumUncontrolled

Emissions

ActualUncontrolled

Emissions

PollutionControl

Efficiency







PM

PM10

SOx

NOx

VOC

CO

Lead


PollutantBefore

OperatingLimits:

AfterOperating




None


PERMIT APPLICATION FORM EC-13CHAZARDOUS AIR POLLUTANTS

CALCULATION FORM (FUEL COMBUSTION HAPS)5/27/98




3) Emission Unit Identification Number: NA -- thermal oxidizer


5) Maximum Rated Equipment Capacity: 5.0 million BTU/hr

6) Control Equipment Designation Number: 001

7) Fuel Parameters

7a)Fuel Type

7b)% Sulfur

7c)% Ash

7d)Heat Value Units 7e)

Fuel Consumption Rate Units

natural gas 1000.00 Btu/ton, Btu/gal, Btu/cf 5000.00 tons/hr; gal/hr; cf/hr

Btu/ton, Btu/gal, Btu/cf tons/hr; gal/hr; cf/hr

Btu/ton, Btu/gal, Btu/cf tons/hr; gal/hr; cf/hr



8a 8b 8c 8d 8e 8f 8g 8h 8i 8j

HAP Name

(CAS)

EmissionFactor (lbs/ton,

Actual AnnualFuel Use

EmissionRate

MaximumUncontrolled

Emissions

ActualUncontrolled

Emissions

PollutionControl

Efficiency




lbs/gal,lbs/MMcf, etc.)



benzene (71432) 0.00213 11 0.000011 0.000048 0.0000 0 0.000048 0.000048 0.0000

dichlorobenzene (106467) 0.0012 11 0.000006 0.000026 0.0000 0 0.000026 0.000026 0.0000

formaldehyde (50000) 0.075 11 0.000374 0.000163 0.0004 0 0.000163 0.000163 0.0004

hexane (110543) 1.80 11 0.0090 0.0394 0.0099 0 0.0394 0.0394 0.0099

naphthalene (91203) 0.00061 11 0.000003 0.000013 0.0000 0 0.000013 0.000013 0.0000

toluene (108883) 0.0034 11 0.000017 0.000074 0.0000 0 0.000074 0.000074 0.0000

POM (total) 0.000086 11 4.3E-7 0.000002 0.0000 0 0.000002 0.000002 0.0000

arsenic 0.0002 11 0.000001 0.000004 0.0000 0 0.000004 0.000004 0.0000

beryllium 0.000012 11 6.0E-8 2.63E-7 0.0000 0 2.63E-7 2.63E-7 0.0000

cadmium 0.0011 11 0.000006 0.000024 0.0000 0 0.000024 0.000024 0.0000

chromium 0.0014 11 0.000007 0.000031 0.0000 0 0.000031 0.000031 0.0000

manganese 0.00038 11 0.000002 0.000008 0.0000 0 0.000008 0.000008 0.0000

mercury 0.00026 11 0.000001 0.000006 0.0000 0 0.000006 0.000006 0.0000

nickel 0.0021 11 0.000011 0.000046 0.0000 0 0.000046 0.000046 0.0000

selenium 0.000024 11 1.20E-7 0.000001 0.0000 0 0.000001 0.000001 0.0000

Total HAP 1.8879 11 0.00944 0.0413 0.0104 0 0.0413 0.0413 0.0104



9a 9b 9c 9d 9e 9f 9g 9h 9i 9j

HAP Name

(CAS)

EmissionFactor

(lbs/ton,

ActualAnnual Fuel

Use

EmissionRate

MaximumUncontrolled

Emissions

ActualUncontrolled

Emissions

PollutionControl

Efficiency




lbs/gal,lbs/MMcf,

etc.)



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


10a 10b 10c 10d 10e 10f 10g 10h 10i 10j

HAP Name

(CAS)

EmissionFactor

(lbs/ton,

ActualAnnual Fuel

Use

EmissionRate

MaximumUncontrolled

Emissions

ActualUncontrolled

Emissions

PollutionControl

Efficiency




lbs/gal,lbs/MMcf,

etc.)



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

11a) 11b) 11a) 11b)

HAP Name (CAS)Before

OperatingLimits:

AfterOperating

Limits:HAP Name (CAS)

BeforeOperating

Limits:

AfterOperating

Limits:(tons/yr) (tons/yr) (tons/yr) (tons/yr)

benzene (71432) 0.000048 0.000048 manganese 0.000008 0.000008

dichlorobenzene (106467) 0.000026 0.000026 mercury 0.000006 0.000006

formaldehyde (50000) 0.000163 0.000163 nickel 0.000046 0.000046

hexane (110543) 0.0394 0.0394 selenium 0.000001 0.000001

naphthalene (91203) 0.000013 0.000013 Total HAP 0.0413 0.0413

toluene (108883) 0.000074 0.000074

POM (total) 0.000002 0.000002

arsenic 0.000004 0.000004

beryllium 2.63E-7 2.63E-7

cadmium 0.000024 0.000024

chromium 0.000031 0.000031


None


PERMIT APPLICATION FORM EC-12CLEAN-UP MATERIALS


- Duplicate this form as necessary, or attach sheets with equivalent information.- If the clean-up materials contain Hazardous Air Pollutants (HAPs), fill out and attach form EC-13A.- When calculating potential emissions, use items 3a, 3b, 3d, 3f, 3h, 3i, and 3j. [Note: You do not need to calculate PTE if using this form for Registration Permit Option

D.]- When calculating actual emissions, use items 3a, 3c, 3e, 3g, 3h, and 3k.

1) AQ Facility ID No.: 990099992) Facility Name: Blue Ox Woodworks3) Calculations Summary for Clean-up Materials:

3a 3b 3c 3d 3e 3f 3g 3h 3i 3j 3k

Clean-Up MaterialsMaximumAmount

Used

ActualAmount

Used

MaximumVOC

Content

ActualVOC

Content

MaximumUncontrolled

Emissions

ActualUncontrolled

Emissions

PollutionControl

Efficiency




(gal/hr) (gal/yr) (lbs/gal) (lbs/gal) (tons/yr) (tons/yr) (%) (tons/yr) (tons/yr) (tons/yr)

Mineral Spirits 0.4 500 7.20 7.00 12.6 1.8 0.00% 12.6 10.0 1.8

4) Operating Limitations, if applicable: (Ignore this item if filling out this form for Registration Permit Option D)

Permit limit of 10 tons of VOC per year.


PERMIT APPLICATION FORM EC-03INTERNAL COMBUSTION ENGINE

(SINGLE-FUEL) CALCULATION FORM7/22/98

- Fill out this form for each fuel burned in each engine, or attach sheets with equivalent information.- If the engine emits Hazardous Air Pollutants (HAPs), fill out and attach form EC-13C.1) AQ Facility ID No.: 99009999




5) Control Equipment Identification Number:

6) Engine Type: Reciprocating Turbine Other:

7) Engine is Used For: Routine operational use Emergency or back-up use only8) Rated Heat Input: 2.1 MMBtu/hr

9) Rated Mechanical Output: HP @ RPM

10) Fuel Type: Diesel @ 0.5 % Sulfur

11) Fuel Consumption Rate: 15 (gal/hr or cf/hr)

12) Calculations Summary:12a) 12b) 12c) 12d) 12e) 12f) 12g) 12h)


EmissionRate

MaximumUncontrolled

Emissions

PollutionControl

Efficiency



ActualEmissions

(lbs/gal, lbs/cf) (lbs/hr) (tons/yr) (%) (tons/yr) (tons/yr) (tons/yr)

PM 0.31 0.65 0.2 0 0.2 0.2 0.028

PM10 0.31 0.65 0.2 0 0.2 0.2 0.028

SOx 0.29 0.61 0.152 0 0.152 0.152 0.026

NOx 4.41 9.26 2.32 0 2.32 2.32 0.393

VOC 0.36 0.756 0.189 0 0.189 0.189 0.032

CO 0.95 2.0 0.50 0 0.50 0.50 0.085

Lead

13) Operating Limitations, if applicable:This is an emergency generator and per EPA letter dated Sept. 6, 1995, can assume 500hours of operation per year when doing PTE. No proposed limits.


PERMIT APPLICATION FORM GI-07FACILITY EMISSIONS SUMMARY

5/26/98

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

Emission Emission3d) Pollutant Name: Carbon Monoxide Pollutant Name: Lead compounds Pollutant Name: Nitrogen Oxides

Source Source 3e) 3f)Type ID No. Potential Actual Potential Actual Potential Actual

Lbs perHr

Unctpy

Limtpy

Tons peryr

Lbs perHr

Unctpy

Limtpy

Tons peryr

Lbs perHr

Unctpy

Limtpy

Tons per yr

EU 001 12.24 53.6 0 1.25 0 0 0 0 1.35 5.9 0 0.14

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

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

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

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

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

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

FC

4) Potential Actual Potential Actual Potential Actual

Total Unc Lim Yr Unc Lim Yr Unc Lim YrFacility 60.2 6.6 3.0 0.36 0.10 0.010 28.9 11.7 2.5



5/26/98


Emission Emission3d) Pollutant Name: Particulate Matter Pollutant Name: PM10 Pollutant Name: Sulfur Dioxides


Lbs perHr

Unctpy

Limtpy

Tons peryr

Lbs perHr

Unctpy

Limtpy

Tons peryr

Lbs perHr

Unctpy

Limtpy

Tons per yr

EU 001 4.32 18.92 0.0 0.81 4.32 18.92 0.0 0.71 0.01 0.04 0.0 0.0

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

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

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

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

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

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

FC





5/26/98

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

Emission Emission3d) Pollutant Name: VOC Pollutant Name: dichlorobenzene Pollutant Name: arsenic


Lbs perHr

Unctpy

Limtpy

Tons peryr

Lbs perHr

Unctpy

Limtpy

Tons peryr

Lbs perHr

Unctpy

Limtpy

Tons per yr

EU 001 0.20 0.87 0.0 0.02

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

SV 003

SV 004

SV 005

SV 006 76.81 336.42 95.12 30.46

SV 007 0.756 0.189 0.189 0.032

FC


Total Unc Lim Yr Unc Lim Yr Unc Lim YrFacility 337.8 95.6 30.6 0.00006 0.00006 0 0.0004 0.0002 0



5/26/98

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

Emission Emission3d) Pollutant Name: benzene Pollutant Name: beryllium Pollutant Name: cadmium compounds


Lbs perHr

Unctpy

Limtpy

Tons peryr

Lbs perHr

Unctpy

Limtpy

Tons peryr

Lbs perHr

Unctpy

Limtpy

Tons per yr

EU 001

EU 002 0.0001 0.0001 0 0.00057 0.00057 0 0.00237 0.00237 0

SV 003

SV 004

SV 005

SV 006 0.062 0.96 0.27 0.02

SV 007

FC


Total Unc Lim Yr Unc Lim Yr Unc Lim YrFacility 0.0001 0.0001 0 0.00057 0.00057 0 0.96 0.27 0.02



5/26/98

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

Emission Emission3d) Pollutant Name: ethylbenzene Pollutant Name: formaldehyde Pollutant Name: hexane


Lbs perHr

Unctpy

Limtpy

Tons peryr

Lbs perHr

Unctpy

Limtpy

Tons peryr

Lbs perHr

Unctpy

Limtpy

Tons per yr

EU 001

EU 002 0.00002 0.00 0 0.0219 0.0219 0.0011 0.0907 0.0907 0.0259

SV 003

SV 004

SV 005

SV 006

SV 007

FC


Total Unc Lim Yr Unc Lim Yr Unc Lim YrFacility 0.00002 0 0 0.0219 0.0219 0.0011 0.0907 0.0907 0.0259



5/26/98

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

Emission Emission3d) Pollutant Name: Manganese Pollutant Name: mercury Pollutant Name: methyl ethyl ketone


Lbs perHr

Unctpy

Limtpy

Tons peryr

Lbs perHr

Unctpy

Limtpy

Tons peryr

Lbs perHr

Unctpy

Limtpy

Tons per yr

EU 001

EU 002 0.0031 0.0031 0 0.00066 0.00066 0

SV 003

SV 004

SV 005

SV 006

SV 007 5.27 23.1 9.0 0.62

FC


Total Unc Lim Yr Unc Lim Yr Unc Lim YrFacility 0.0031 0.0031 0 0.00066 0.00066 0 23.1 9.0 0.62



5/26/98

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

Emission Emission3d) Pollutant Name: methyl isobutyl

ketonePollutant Name: Naphthalene Pollutant Name: nickel


Lbs perHr

Unctpy

Limtpy

Tons peryr

Lbs perHr

Unctpy

Limtpy

Tons peryr

Lbs perHr

Unctpy

Limtpy

Tons per yr

EU 001

EU 002 0.00038 0.00003 0 0.0284 0.00399 0

SV 003

SV 004

SV 005

SV 006 3.77 35.92 9.0 .74

SV 007

FC


Total Unc Lim Yr Unc Lim Yr Unc Lim YrFacility 35.9 9.0 0.74 0.00038 0.00003 0 0.0284 0.004 0



5/26/98


Emission Emission3d) Pollutant Name: chromium Pollutant Name: Polycyclic Organic

MatterPollutant Name: selenium


Lbs perHr

Unctpy

Limtpy

Tons peryr

Lbs perHr

Unctpy

Limtpy

Tons peryr

Lbs perHr

Unctpy

Limtpy

Tons per yr

EU 001

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

SV 003

SV 004

SV 005

SV 006

SV 007

FC


Total Unc Lim Yr Unc Lim Yr Unc Lim YrFacility 0.0148 0.0148 0 0.0012 0.0012 0 0.00023 0.00001 0



5/26/98

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

Emission Emission3d) Pollutant Name: toluene Pollutant Name: xylene Pollutant Name: Total HAPs


Lbs perHr

Unctpy

Limtpy

Tons peryr

Lbs perHr

Unctpy

Limtpy

Tons peryr

Lbs perHr

Unctpy

Limtpy

Tons per yr

EU 001

EU 002 0.00208 0.00017 0 0.1296 0.1296 0.0272

SV 003

SV 004

SV 005

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

SV 007

FC




PERMIT APPLICATION FORM GI-09REQUIREMENTS FORM

05/11/98

Federal and State Requirements

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

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

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

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

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

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

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

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

2b) After completing item 2a, check one of the following boxes:YES, my facility is subject to NESHAP requirements.NO, my facility is not subject to NESHAP requirements.

3) New Source Review(NSR, New Source Review, 40 CFR pt. 52)

3a) Did you construct, make any physical change to (as defined in 40 CFR § 52.21) or change the method of operation of(as defined in 40 CFR § 52.21) your facility since August 7, 1980?

YES. Go to form GI-09C REQUIREMENTS: NEW SOURCE REVIEW.NO. Go to question 3b and answer NO.

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

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

4a) Did you answer NO to question 3b above or are you taking "synthetic minor" permit limitations which allow you toavoid having to submit a complete NSR application?

YES, my facility is not subject to this requirement.NO, my facility is subject to this requirement. I must complete an analysis of ambient air, increment andvisibility in my NSR application as prescribed by Sections 109 and 160-169(B) of the 1990 Clean Air ActAmendments.

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

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

5b) Have you constructed, modified (as defined in 40 CFR § 60.14), or reconstructed (as defined in 40 CFR § 60.15)your emission facility, or any portion thereof, after August 17, 1971?

NO.YES, you may be subject to this regulation. Complete the attached form GI-09D REQUIREMENTS: NSPS.

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

5d) After completing the above questions (and the attachment if necessary) check one of the following boxes:YES, my facility (or a portion of it) is subject to NSPS requirements.NO, my facility is not subject to NSPS requirements.

6) Acid Rain Program under Title IV (40 CFR pt. 72, 40 CFR pt. 73; and 1990 Clean Air Act, as amended, Sections 401-416)

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

Austin Utilities: Northeast Station

Interstate Power: Fox Lake

Minnesota Power and Light: Clay Boswell M.L. Hibbard Syl Laskin

Northern States Power: High Bridge Minnesota Valley RiversideSherburne County Allen S. King Black DogNa. 1 -- 7237 Future Base

Otter Tail Power: Hoot Lake

Rochester Public Utility: Silver Lake

6b) Does your facility combust fossil fuel and generate electricity for wholesale or retail sale, such as a cogenerationfacility, a qualifying facility (as defined in the Federal Power Act), independent power producer, or solid wasteincinerator?

NO. Go to question 6c and answer NO.YES. Your facility may be subject to Acid Rain Requirements. Refer to the applicability definitions in 40CFR § 72.6 to find out if they apply.

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

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

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

7b) After completing form GI-09F REQUIREMENTS: STRATOSPHERIC OZONE, check one of the following boxes:YES, my facility is subject to this requirement.NO, my facility is not subject to this requirement.

8) RISK MANAGEMENT PROGRAMS FOR CHEMICAL ACCIDENTAL RELEASE PREVENTION(40 CFR pt. 68, Section 112(r) of the Clean Air Act Amendments)

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

8b) Determine if you produce, process, store or use any of the substances listed in form GI-09G: RISKMANAGEMENT PROGRAMS FOR CHEMICAL ACCIDENTAL, RELEASE PREVENTION, and checkone of the following boxes:

Yes, my facility does produce, process, store or use one or more of the substances listed in form GI-09G, inamounts exceeding the listed thresholds.No, my facility does not produce, process, store or use any of the substances listed in form GI-09G, inamounts exceeding the listed thresholds.

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

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

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

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

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

11) Minnesota State Air Quality Rules

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

11b) Whether permitted or not, every business and activity in Minnesota is subject to the rules listed in the followingtable:

Title of the Rule Minnesota Rules (Chapteror Part)

What the Content of the Rule is:

Air Quality Emission Fees Part 7002.0025 - 7002.0095 Requires facilities to pay emission fees every yearwithin 60 days of MPCA billing.

Air Emission Permits Parts 7007.0050 - 7007.1850 Outlines when an air emission permit is required andprocedures for obtaining one.

Minnesota and National AmbientAir Quality Standards

Part 7009.0010 - 7009.0080 No one is allowed to emit any of the limited pollutantsin such a manner that ambient levels of the pollutantare higher than the maximum level.

Applicability of Standards ofPerformance

Parts 7011.0010, and7011.0050

Indicates that facilities must comply with allapplicable state air pollution rules.

Circumvention Part 7011.0020 States that no one may conceal or dilute emissionswhich would otherwise violate a federal or state airpollution control rule.

Emission Standards for Visible AirContaminants

Part 7011.0100 - 7011.0120 Outlines restrictions against emitting opaque smokefrom facilities.

Preventing Particulate Matter fromBecoming Airborne

Part 7011.0150 States that no person shall cause particulate matter tobecome airborne if it can be avoided with listedpreventative measures.

Continuous Monitors Part 7017.1000 Outlines requirements for continuous monitoringsystems.

Performance Tests Part 7017.2001 - 7017.2060 Outlines procedures and methods for emissions andperformance testing if required.

Notifications Part 7019.1000 Requires facilities to notify the MPCA of shutdownsand breakdowns.

Reports Part 7019.2000 Requires specific records and reports from facilitieswith continuous monitoring systems.

Emission Inventory Part 7019.3000 - 7019.3100 Requires facilities to submit an Emission InventoryReport by April 1 every year.

Motor Vehicles Part 7023.0100 - 7023.0120 Outlines restrictions against emitting opaque smokefrom motor vehicles, trains, boats, constructionequipment and stationary internal combustion engines.

Noise Pollution Control Part 7030.0010 - 7030.0080 Sets noise standards which cannot be exceeded.

12) You have completed the Applicable Requirements form.


PERMIT APPLICATION FORM GI-09AREQUIREMENTS: NESHAP

FOR SOURCE CATEGORIES (40 CFR pt. 63)05/11/98

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

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

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

2b) Does your source have the potential to emit 25 tons per year or more of any combination of pollutants listed in TableA?

Yes, my facility is a major source of HAP emissions. Go to question 3.No. Go to question 6.

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

No. Go to question 4.Yes. Briefly describe the limitations you would be willing to accept and abide by in your permit so thatyour HAP emissions will not exceed 10 tons per year for each HAP and 25 tons per year for all HAPscombined (use separate sheet if needed). Description must include each of the HAP pollutants. Refer to theApplication General Instructions for guidance in establishing these limitations, and include your proposedlimit, monitoring, recordkeeping, and reporting on Form CD-01. Your facility may be subject to NESHAPfor Source Categories requirements until you receive a federally enforceable permit limiting your facility’sHAP emissions to a nonmajor source. When you return to form GI-09 Requirements, you must answer“YES” to question 1b. To determine whether your facility is subject to NESHAP for nonmajor sources, goto question 6.

Limit HAP usage at the spray booth (SV006) such that each individual HAP PTE is 9.0 tpy andcombined HAP PTE is 24.0 tpy (for the spray booth).Control HAP emissions with a thermal oxidizer with an overall efficiency of 54%.

4) The attached Table B is a list of NESHAP for Source Categories and important dates associated with each of them.Does your facility have any equipment that fits any of the source categories listed?

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

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

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

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

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

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

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

Yes, my facility is subject to the preconstruction review requirements under its MACT standard and to theGeneral Provisions of the MACT standard. Return to form GI-09 Requirements and answer “YES” toquestion 1b and “NO” to question 1c.No, my facility may be subject to preconstruction review requirements under section 112(g)(2)(B). Go toquestion 9.

9) If you answered “No” to question 8, it may be possible to avoid the section 112(g)(2)(B) requirement of performinga case-by-case MACT determination for your proposed project by proposing a federally enforceable permitconditions to limit your potential HAP emissions to less than 10 tons per year for each HAP and/or 25 tons per yearfor all HAPs combined from the new proposed project. Do you want to accept permit limitations on HAPs to avoidthe section 112(g)(2)(B) requirement?

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

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

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

TABLE AHazardous Air Pollutants

A75070 Acetaldehyde60355 Acetamide75058 Acetonitrile98862 Acetophenone53963 2-Acetylaminofluorene107028 Acrolein79061 Acrylamide79107 Acrylic acid107131 Acrylonitrile107051 Allyl chloride92671 4-Aminobiphenyl62533 Aniline90040 o-Anisidine1332214 Asbestos

B71432 Benzene92875 Benzidine98077 Benzotrichloride100447 Benzyl chloride92524 Biphenyl117817 Bis (2-ethylhexyl) phthalate (DEHP)542881 Bis (chloromethyl) ether75252 Bromoform106990 1,3-Butadiene

C156627 Calcium cyanamide133062 Captan63252 Carbaryl75150 Carbon disulfide56235 Carbon tetrachloride463581 Carbonyl sulfide120809 Catechol133904 Chloramben57749 Chlordane778505 Chlorine79118 Chloroacetic acid532274 2-Chloroacetophenone108907 Chlorobenzene510156 Chlorobenzilate67663 Chloroform107302 Chloromethyl methyl ether126998 Chloroprene1319773 Cresols/Cresylic acid (isomers and mixture)95487 0-Cresol108394 m-Cresol106445 p-Cresol98828 Cumene

D94757 2,4-D, salts and esters3547044 DDE334883 Diazomethane132649 Dibenzofurans96128 1,2-Dibromo-3-chloropropane84742 Dibutylphthalate106467 1,4-Dichlorobenzene(p)91941 3,3'-Dichlorobenzidene111444 Dichloroethyl ether (Bis(2-chloroethyl)either)542756 1,3-Dichloropropene62737 Dichlorvos111422 Diethanolamine

121697 N,N-Diethyl aniline (N,N- Dimethylaniline)64675 Diethyl sulfate119904 3,3-Dimethoxybenzidine60117 Dimethyl aminoazobenzene119937 3,3-Dimethyl benzidine79447 Dimethyl carbamoyl chloride68122 Dimethyl formamide57147 1,1 Dimethyl hydrazine131113 Dimethyl phthalate77781 Dimethyl Sulfate534521 4,6-Dintro-o-cresol, and salts51285 2,4-Dinitrophenol121142 2,4-Dinitrotoluene123911 1,4-Dioxane (1.4-Diethyleneoxide)122667 1,2-Diphenylhydrazine

E106898 Epichlorohydin (1-Chloro-2,3-epoxypropane)106887 1,2-Epoxybutane140885 Ethyl acrylate100414 Ethyl benzene51796 Ethyl carbamate (Urethane)75003 Ethyl chloride (Chloroethane)106934 Ethylene dibromide (Dibromoethane)107062 Ethylene dichloride (1,2- Dichloroethane)107211 Ethylene glycol151564 Ethylene imine (Aziridine)75218 Ethylene oxide96457 Ethylene thiourea75343 Ethylidene dichloride (1,1-Dichloroethane)

F50000 Formaldehyde

H76448 Heptacholor118741 Hexachlorobenzene87683 Hexachlorobutadiene77474 Hexachlorocyclopentadiene67721 Hexachloroethane822060 Hexamethylene-1,6-diisocyanate680319 Hexamethylphosphoramide110543 Hexane302012 Hydrazine7647010 Hydrochloric acid7664393 Hydrogen flouride (hydrofluoric acid)123319 Hydroquinone

I78591 Isophorone

L58899 Lindane (all isomers)

TABLE AHazardous Air Pollutants

M108316 Maleic anhydride67561 Methanol72435 Methozychlor74839 Methyl bromide (Bromomethane)74873 Methyl chloride (Choromethane)71556 Methyl chloroform (1,1,1-Trichloroethane)78933 Methyl ethyl ketone (2-Butanone)60344 Methyl hydrazine74884 Methyl iodide (Iodomethane)108101 Methyl isobutyl ketone (Hexone)624839 Methyl isocyanate80626 Methyl methacrylate1634044 Methyl tert butyl ether101144 4,4-Methylene bis (2-chloroaniline)75092 Methylene chloride (Dichloromethane)101688 Methlene diphenyl diisocyanate (MDI)101779 4,4'-methylenedianiline

N

91203 Naphthalene98953 Nitrobenzene92933 4-Nitrobiphenyl100027 4-Nitrophenol79469 2-Nitropropane684935 N-Nitroso-N-methylurea62759 N-Nitrosodimethylamine59892 N-Nitosomorpholine

P56382 Parathion82688 Pentachloronitrobenzene (Quintobenzene)87865 Pentachlorophenol108952 Phenol106503 p-Phenylenediamine75445 Phosgene7803512 Phosphine7723140 Phosphorus85449 Phthalic anhydride1336363 Polychlorinated biphenyls (aroclors)1120714 1,3-Propane sultone57578 beta-Propiolactone123386 Propionaldehyde114261 Propoxur (Baygon)78875 Propylene dichloride (1,2-Dichloropropane)75569 Propylene oxide75558 1,2-Propylenimine (2-Methyl aziridine)

Q91225 Quinoline106514 Quinone

S100425 Styrene96093 Styrene Oxide

T1746016 2,3,7,8-Tetrachlorodibenzo-p-dioxin79345 1,1,2,2-Tetrachloroene127184 Tetrachloroethylene (Perchloroethylene)7550450 Titanium tetrachloride108883 Toluene95807 2,4-Toluene diamine584849 2,4-Toluene diisocyanate95534 o-Toluidine8001352 Toxaphene (chlorinated camphene)120821 1,2,4-Trichlorobenzene79005 1,1,2-Trichloroethane79016 Trichloroethylene95954 2,4,5-Trichlorophenol88062 2,4,6-Trichlorophenol121448 Triethylamine1582098 Trifluralin540841 2,2,4-Trimethylpentane

V

108054 Vinyl acetate593602 Vinyl bromide75014 Vinyl chloride75354 Vinylidene chloride (1,1-Dichloroethylene)

X

1330207 Xylenes (isomers and mixtures)95476 o-Xylenes108383 m-Xylenes106423 p-Xylenes

COMPOUNDS0 Antimony compounds0 Arsenic compounds (inorganic including arsine)0 Beryllium compounds0 Cadmium compounds0 Chromium compounds0 Cobalt compounds0 Coke oven emissions0 Cyanide compounds0 Glycol ethers0 Lead compounds0 Manganese compounds0 Mercury compounds0 Mineral fibers0 Nickel compounds0 Polycyclic organic matter0 Radionuclides0 Selenium compounds

TABLE BSOURCE CATEGORIES

Categories of Major SourcesRule Promulgation Date

or ScheduledPromulgation Date*

(*date subject to change)

Compliance Date forExisting Sources

(if applicable)

Acetyl resins production (Polymers & Resins III) 7/99Acrylic fibers/modacrylic fibers production 12/98Acrylonitrile-butadiene-styrene production(Polymers and Resins IV) 9/12/96 3/12/97Aerosol can filling facilities (may be delisted) 11/15/2000Aerospace industries surface coating 9/1/95 9/1/98Alkyd resins production(Miscellaneous organic NESHAP) 11/15/2000Alumina processing 11/15/2000Amino resins production(Polymers and Resins III) 7/99Ammonium sulfate production 11/15/2000Antimony oxides manufacturing 11/15/2000Asphalt/coal tar application - metal pipes 11/15/2000Asphalt concrete manufacturing 11/15/2000Asphalt processing 8/99Asphaltic roofing manufacturing 8/99Auto and light duty truck surface coating 11/15/2000

Baker's yeast manufacturing 6/99Benzyltrimethylammonium chloride production(Miscellaneous organic NESHAP)

11/15/2000

Boat manufacturing 12/2000Butadiene dimers production(Manufacturing of Tetrahydrobenzaldehyde) 2/98Butadiene-furfural cotrimer (R-11) production 11/15/2000Butyl rubber production(Polymers and Resins I) 9/5/96 3/5/97

Captafol production(Pesticide Active Ingredient Production) 3/99Captan production(Pesticide Active Ingredient Production) 3/99Carboxymethylcellulose prod.(Miscellaneous Cellulose MACT)

11/15/2000

Carbonyl sulfide production(Miscellaneous organic NESHAP)

11/15/2000

Cellophane production(Miscellaneous Cellulose MACT)

11/15/2000

Cellulose ethers production(Miscellaneous Cellulose MACT)

11/15/2000

Cellulose food casing manufacturing(Miscellaneous Cellulose MACT)

11/15/2000

Chelating agents production(Miscellaneous organic NESHAP)

11/15/2000

Chlorinated paraffins production(Miscellaneous organic NESHAP)

11/15/2000


or ScheduledPromulgation Date


(if applicable)4-chloro-2-methylphenoxyacetic acid production(Pesticide Active Ingredient Production) 3/99Chloroneb production(Pesticide Active Ingredient Production) 3/99Chlorothalonil production(Pesticide Active Ingredient Production) 3/99Chromic acid anodizing 1/25/95 1/25/97Chromium refractories production 5/2000Clay products manufacturing 11/15/2000Coke by-product plants(see 40 CFR part 61, subp. L) n/aCoke ovens: charging, top side, and door leaks 10/27/93 11/15/93Coke ovens: pushing, quenching and battery stacks 11/15/2000Commercial dry cleaning (Perc) transfer machines 9/22/93 12/20/93Commercial sterilization facilities 12/2/94 12/6/98Cyanuric chloride production(Cyanide Chemical Production) 11/2000

2,4- salts and esters production(Pesticide Active Ingredient Production) 3/99Dacthal production(Pesticide Active Ingredient Production) 3/99Decorative chromium electroplating 1/25/95 1/25/984,6,-dinitro-o-cresol production(Pesticide Active Ingredient Production) 3/99Dodecanedioic acid production 11/15/2000Dry cleaning (Petroleum solvent) 11/15/2000

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

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

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

Halogenated solvent cleaners 12/2/94 12/2/97Hard chromium electroplating 1/25/95 1/25/97




(if applicable)Hazardous waste incineration 11/15/2000Hydrazine production(Miscellaneous organic NESHAP)

11/15/2000

Hydrochloric acid production 11/15/2000Hydrogen cyanide production(Cyanide Chemical Production)

11/15/2000

Hydrogen fluoride production 12/98Hypalon production(Polymers and Resins I) 9/5/96 3/5/97

Industrial boilers(Industrial Combustion Coordinating Rule)

11/15/2000

Industrial dry cleaning (Perc) dry-to-dry machines 9/22/93 12/20/93Industrial dry cleaning (Perc) transfer machines 9/22/93 12/20/93Industrial process cooling towers 9/8/94 3/8/96Institutional/commercial boilers(Industrial Combustion Coordinating Rule)

11/15/2000

Integrated iron and steel manufacturing 11/15/2000Iron foundries 11/15/2000

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

Magnetic tape surface coating 12/15/94 12/15/96Maleic anhydride copolymers production(Miscellaneous organic NESHAP)

11/15/2000

Manufacture of paints, coating and adhesives(Miscellaneous organic NESHAP)

11/15/2000

Marine vessel unloading and loading 9/19/95 9/19/99Metal can surface coating 11/15/2000Metal coil surface coating 11/15/2000Metal furniture surface coating 11/15/2000Methylcellulose production(Miscellaneous Cellulose MACT)

11/15/2000

Methyl methacrylate-acrylonitrile-butadiene-styrene production(Polymers and Resins IV)

9/12/96 3/12/97

Methyl methacrylate-butadiene-styrene terpolymers production(Polymers and Resins IV)

9/12/96 3/12/97

Mineral wool production 4/98Miscellaneous metal parts and products s.c. 11/15/2000

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

3/8/95 3/3/98

Oil and natural gas production 4/98




(if applicable)Organic liquids distribution (non-gasoline) 11/15/2000Oxybisphenoxarsine (OBPA)/1,3-diisocyanate production(Miscellaneous organic NESHAP)

11/15/2000

Paper and other webs surface coating 11/15/2000Paint stripper users 11/15/2000Petroleum refineries - catalytic cracking (fluid and other) units, catalytic reforming units, and sulfur plant units 11/98Petroleum refineries - Other sources not distinctly listed 8/18/95 8/18/98Pharmaceuticals production 4/98Phenolic resins production(Polymers and Resins I)

7/99

Phosphate fertilizers production 2/98Phosphoric acid manufacturing 2/98Photographic chemicals production(Miscellaneous organic NESHAP)

11/15/2000

Phthalate plasticizers production(Miscellaneous organic NESHAP)

11/15/2000

Plastic parts and products surface coating 11/15/2000Plywood/particle board manufacturing 11/15/2000Polyether polyols production 9/98Polybutadiene rubber production(Polymers and Resins I) 9/5/96 3/5/97Polycarbonates production(Polymers and Resins IV)

9/12/96 3/12/97

Polyester resins production(Miscellaneous organic NESHAP)

11/15/2000

Polyethylene terephthalate production(Polymers and Resins IV)

9/12/96 3/12/97

Polymerized vinylidene chloride production(Miscellaneous organic NESHAP)

11/15/2000

Polymethyl methacrylate resins production(Miscellaneous organic NESHAP)

11/15/2000

Polystyrene production(Polymers and Resins IV)

9/12/96 3/12/97

Polysulfide rubber production(Polymers and Resins I) 9/5/96 3/5/97Polyvinyl alcohol production(Miscellaneous organic NESHAP)

11/15/2000

Polyvinyl butyral production(Miscellaneous organic NESHAP)

11/15/2000

Polyvinyl chloride and copolymers production 11/15/2000Portland cement manufacturing 9/98Primary aluminum production 9/19/97Primary copper smelting 6/98Primary lead smelting 8/98Primary magnesium refining 5/2000Printing, coating, and dyeing of fabrics 11/15/2000Printing/publishing surface coating 5/30/96 5/30/99Process heaters(Industrial Combustion Coordinating Rule)

11/15/2000




(if applicable)Publicly owned treatment works 5/98Pulp and paper production (con-combust) 11/14/97Pulp and paper production (combust) 7/98Pulp and paper production (con-chemical) 11/97

Quaternary ammonium compounds production 11/15/2000

Rayon production(Miscellaneous Cellulose MACT)

11/15/2000

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

11/15/2000

Secondary aluminum prod. 3/99Secondary lead smelting 6/23/95 6/23/97Semiconductor manufacturing 11/15/2000Sewage sludge incineration 11/15/2000Shipbuilding and ship repair surface coating 12/15/95 12/16/97Site remediation 11/15/2000Sodium cyanide production(Cyanide Chemical Production)

11/15/2000

Sodium pentachlorophenate production(Pesticide Active Ingredient Production) 3/99Off-site Waste Treatment Facilities 7/1/96 7/10/99Spandex production 11/15/2000Stationary internal combustion engines(Industrial Combustion Coordinating Rule)

11/15/97

Stationary turbines(Industrial Combustion Coordinating Rule)

11/15/2000

Steel foundries 1/15/2000Styrene-acrylonitrile production(Polymers and Resins IV)

9/12/96 3/12/97

Styrene-butadiene rubber and latex production(Polymers and Resins I) 9/5/96 3/5/97Symmetrical tetrachloropyridine production(Miscellaneous organic NESHAP)

11/15/2000

Synthetic organic chemical manufacturing 4/22/94 10/24/94

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

Uranium hexafluoride production 11/15/2000Vegetable oil production 11/15/2000Wood furniture surface coating 12/7/95 11/21/97, 12/7/98Wool fiberglass manufacturing 3/98


PERMIT APPLICATION FORM GI-09BREQUIREMENTS: NESHAP

(40 CFR pt. 61)05/11/98

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

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

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

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

3) After reviewing the NESHAP reference list and reading the corresponding 40 CFR pt. 61 subpart(s) check one of thefollowing boxes:

NO, my facility is not subject to NESHAP requirements. Return to form GI-09 Requirements, and answer“NO” to question 2b.YES, my facility (or a portion of it) is subject to NESHAP requirements. Answer “YES” to question 2bwhen you return to form GI-09 Requirements.

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

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

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

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

Describe Emission Facility Date of Facility Construction Applicable 40 CFR pt. 61 subparts(s) Applicable Minnesota State Rule Reference Has this Source Been Permitted Previously?

NOYES, list Air Emission Permit Number

4c) My facility has one or more emission unit(s) subject to NESHAP requirements. Provide the informationrequested below for each unit that is subject to a NESHAP.

Describe Emission Equipment Emission Unit Number Stack/Vent Number Date of Original Equipment Installation (Month/Date/Year)Applicable 40 CFR pt. 61 subpart(s) Applicable Minnesota State Rule Reference Has this Unit Been Permitted Previously?






5) Return to form GI-09 Requirements, question 2b.

TABLE CNATIONAL EMISSION STANDARDS FOR HAZARDOUS AIR POLLUTANTS

POLLUTANT FACILITY OR EMISSION UNIT TYPE MINNRULES

40 CFR 61SUBPART

RADON Underground Uranium Mines; Department of Energy Facilities;Phosphorus Fertilizer Plants; and Facilities Processing orDisposing of Uranium Ore and Tailings

7011.9960 B, Q, R, T, W

BERYLLIUM Beryllium Extraction Plants; Ceramic Plants, Foundries,Incinerators, Propellant Plants, and Machine Shops that ProcessBeryllium Containing Material; and Rocket Motor Firing TestSites

7011.9940 -7011.9945

C, D

MERCURY Mercury Ore Processing; Manufacturing Processes UsingMercury Chloralkali Cells; and Sludge Incinerators

7011.9950 -7011.9955

E

VINYLCHLORIDE

Ethylene Dichloride Manufacturing Via Oxygen, HCl andEthylene; Vinyl Chloride Manufacturing; and Polyvinyl ChlorideManufacturing

7011.9980 F

RADIO-NUCLIDES

Department of Energy; Nuclear Regulatory CommissionLicensed Facilities; Other Federal Facilities; and ElementalPhosphorus Plants

7011.9970 H, I, K

BENZENE Fugitive Process, Storage, and Transfer Equipment Leaks; CokeBy-Product Recovery Plants; Benzene Storage Vessels; BenzeneTransfer Operations; and Benzene Waste Operations

7011.9930 J, L, Y, BB,FF

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

7011.9920 -7011.9927

M

INORGANICARSENIC

Glass Manufacturer; Primary Copper Smelter; Arsenic Trioxideand Metallic Arsenic Production Facilities

7011.9910 N, O, P

VOLATILEHAZARDOUS

AIRPOLLUTANTS

(VHAP)

Pumps, Compressors, Pressure Relief Devices, Connections,Valves, Lines, Flanges, Product Accumulator Vessels, etc. inVHAP Service(As of 11/30/94 only vinyl chloride and benzene are regulated by40 CFR 61, subp. V)

7011.9990 V

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


PERMIT APPLICATION FORM GI-09CREQUIREMENTS:

NEW SOURCE REVIEW (40 CFR pt. 52)05/11/98

New Source Review(NSR; 40 CFR pt. 52)

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

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

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

It may be possible for sources that were major to become synthetic minor facilities. Items 9-10 are basic criteria questionsthat need to be answered. Sources who wish to pursue this option will need to work closely with MPCA staff to determine ifthe facility does qualify for the synthetic minor status. Items 11, 12, and 13 determine if you constructed a major facility.Item 14 requires a description of each change (physical or operational) made at your facility after it actually began emittingpollutants at a rate higher than your threshold. A detailed description is required for each change, including dates andemission levels through today. If necessary and/or allowed, item 14f requires you to specify "synthetic minor" limitations forjust the change. Item 14 must be filled out separately for each change made, requiring duplication of those two pages. Item15 directs specific sources to contact the MPCA for further guidance.

1) Is your facility defined as one of the following, (Some SIC Code(s) applying to specific categories are given inparentheses):

Coal Cleaning Plants-With Thermal Dryers Kraft Pulp Mills (2611, 2621)Portland Cement Plants (3241) Primary Zinc Smelters (3339)Iron and Steel Mills (332X) Primary Aluminum Ore Reduction Plants (3334)Primary Copper Smelters (3331) Municipal Incinerators Capable of Charging

More Than 250 Tons of Refuse per DayHydrofluoric Acid Plants (2819, 2899) Sulfuric Acid Plants (2819)Nitric Acid Plants (2873) Petroleum Refineries (2911)Lime Plants (3274) Phosphate Rock Processing Plants (1475)Coke Oven Batteries (3312) Sulfur Recovery Plants (2819)Carbon Black Plants (Furnace Process, 2895) Primary Lead Smelters (3339)Fuel Conversion Plants Sintering Plants*Secondary Metal Production Plants (334X) Chemical Process Plants (28XX)Fossil-Fuel Boilers (or combination thereof) totaling

more than 250 MMBtu/hrPetroleum Storage & Transfer Units, Total Storage

Capacity over 300,000 BarrelsTaconite Ore Processing Plants (1011) Glass Fiber Processing PlantsCharcoal Production Plants (2819, 2861) Fossil Fuel-Fired Steam Electric Plants of more than 250

MMBtu/hr* Processing of fine grain materials into coarser lumps (performed primarily on ores).

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

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

PM10 SO2 CO

An air emission source having the potential to emit more than 100 TPY of any pollutant(s) checked above, or 250TPY of any single regulated pollutant not checked above is considered a major stationary source. For the rest ofthis form, 100 TPY is the threshold for any pollutant(s) checked above, and 250 TPY is the threshold for theremaining regulated pollutants. You must use these values in answering the remaining questions. Go to item4.

3) I answered NO to items 1 and 2; my facility is not one of the 28 sources listed and my facility is not located in a non-attainment area. An air emission source having the potential to emit of more than 250 TPY of any single regulatedpollutant is considered a major stationary source. For the rest of this form, 250 TPY is the threshold you mustuse in answering the questions.

4) In the boxes below, enter the current PTE (in tons per year) of your entire facility under each regulated pollutant.(“Current PTE” means the PTE of your facility prior to receiving the permit for which you are now applying.)

PM10

PM(includes

PM10) SO2 NOX VOC CO Pb Fluorides

183.7 185.2 213.8 28.9 337.7 60.2 0.4 0

SulfuricAcid Mist H2S

Totalreducedsulfur

(includesH2S)

Reducedsulfur

compounds(includes

H2S)

MWCorganics

MWCmetals

MWCacidgases

MSWlandfillgases

Ozone-depleting

substances

0 0 0 0 0 0 0 0 0

5) Is the current PTE of your facility above the 100/250 TPY threshold for your facility, making your facility a majorstationary source?

YES. My facility is currently considered a major stationary source, go to question 7.NO. Go to question 6.

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

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

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

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

7) Since August 7, 1980, have the actual emissions from your facility ever exceeded the 100/250 TPY threshold valuefor your facility?

YES. Go to item 9.NO. My facility is allowed to accept federally enforceable permit limitations to limit potential emissions toless than a major source (below the threshold). Go to question 8.

8) The actual emissions from your facility have never exceeded the 100/250 TPY threshold established for yourfacility. Would you be willing to accept federally enforceable permit limitations to limit potential emissions fromyour facility to less than the 100/250 TPY threshold?

NO. Go to item 11.YES. You are required to specify limitations (called synthetic minor limits) for your facility. Theselimitations will limit your air emissions. This will be dependent on your emission sources and can havesome flexibility. Briefly describe what limitations you would be willing to accept and abide by. Refer tothe Application General Instructions for guidance in establishing these limitations. Include the specificlimits, monitoring, recordkeeping, and reporting on Form CD-01.

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

(DUPLICATE THIS FORM OR ADD EXTRA PAGES AS NEEDED)

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

9) Have you removed any equipment from your facility since the actual emissions exceeded the 100/250 TPYthreshold?

NO. Go to question 11.YES. Go to question 10.

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

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

PM10

PM(includes



Totalreducedsulfur

(includesH2S)

Reducedsulfur

compounds(includes

H2S)

MWCorganics

MWCmetals

MWCacidgases

MSWlandfillgases

Ozone-depleting

substances

12) Are any of the PTE values entered in question 11 greater than the 100/250 TPY threshold for your facility?NO. Go to question 14.YES. Go to question 13.

13) Have the actual emissions for the operations installed during the facility’s construction ever exceeded the 100/250TPY threshold for any year after the construction date?

NO. Go to question 14.YES. My facility was a major source when it was constructed. If a BACT/LAER analysis was not done atthe time of construction, the facility may be subject to backward looking NSR (if the analysis was not doneat the time of construction but has been done since, it may not be necessary to repeat it). Contact the PermitTechnical Advisor at (651)282-5844 or (800)646-6247 for additional guidance. Go to question 14.

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

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

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

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

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

PM10

PM(includes



Totalreducedsulfur

(includesH2S)

Reducedsulfur

compounds(includes

H2S)

MWCorganics

MWCmetals

MWCacidgases

MSWlandfillgases

Ozone-depleting

substances

14d) Are the values you entered in item 14c for this modification greater than the values listed in item 14e for eachregulated pollutant?

NO. This was a minor change, go to question 14g.YES. Go to question 14e.

14e) Beginning with the year entered in item 14b through the current date, did the actual emissions of regulated pollutantsresulting only from this modification ever exceed the values listed in the following table?

Pollutant Threshold(tons/year) Effective Date

PM10 15 July 31, 1987PM 25 August 7, 1980SO2 40 August 7, 1980NOX 40 August 7, 1980VOC 40 August 7, 1980CO 100 August 7, 1990Pb 0.6 August 7, 1980Fluorides 3 August 7, 1980Sulfuric Acid Mist 7 August 7,. 1980H2S 10 August 7, 1980Total reduced sulfur 10 August 7, 1980Reduced sulfur compounds 10 August 7, 1980MWC organics 3.5 x 10-6 August 12, 1991MWC metals 15 August 12, 1991MWC acid gases 40 August 12, 1991MSW landfill gases 50 March 12, 1996Ozone depleting substances 100 March 19, 1998 (EPA memo)

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

14f) The actual emissions from this modification have never exceeded the levels listed in item 14e. Are you willing toaccept federally enforceable permit limitations to limit the potential emissions increase of the modification to lessthan those levels?

NO. Go to item 14g.YES. You are required to specify limitations (called “synthetic minor” limits) for this change. These limitswill limit your air emissions to below the levels listed in item 14e. This will be dependent on youremissions sources and can have some flexibility. Briefly describe what limitations you would be willing toaccept and abide by. Refer to the Application General Instructions for guidance in establishing theselimitations. Include the specific limits, monitoring, recordkeeping, and reporting on Form CD-01.

(DUPLICATE THIS FORM OR ADD EXTRA PAGES AS NEEDED)

Go to item 14g.

14g) Repeat item 14 until each non-permitted physical change or change in method of operation to your facility has beenidentified, duplicating item 14 as necessary.

15) It may be possible to accept synthetic minor permit limitations if your actuals have exceeded the threshold levels, ifyou have removed equipment and the actual emissions for the last two calendar years of operation have remained under thethreshold levels. You should contact the MPCA for more guidance on whether your facility qualifies for synthetic minorlimitations.

If you have triggered NSR/PSD levels and cannot or choose not to accept synthetic minor limitations, you need tocheck YES to question 3b on Form GI-09 Requirements. If your facility has received permits for modifications orcompleted NSR/PSD reviews as requested by the MPCA, you should work with MPCA staff to determine the compliancestatus of your facility regarding NSR/PSD and establishing limits.


PERMIT APPLICATION FORM GI-09DREQUIREMENTS: NSPS (40 CFR pt. 60)

05/11/98

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

1) NSPS are federal rules that define limits, testing and monitoring for certain specific emission units. These standardsare proposed and promulgated in the Federal Register and published in the Code of Federal Regulations, title 40 part60 (40 CFR pt. 60). Table D lists the standards promulgated through April 1998. Table D may not be complete if anew NSPS has been promulgated since this form was last revised. The table contains:

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

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

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

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

3) After you review the list of sources subject to NSPS and read any applicable 40 CFR pt. 60 subparts, check one ofthe following boxes:

NO, my facility is not subject to NSPS. Return to Form GI-09 Requirements, and answer “NO” toquestion 5d.YES, my facility is subject to NSPS.

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

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

5) Return to Form GI-09 Requirements, and answer “YES” to question 5d.

Describe Emission Equipment BoilerEmission Unit Number 2Stack/Vent Number 2Date of Equipment Manufacture 3/1/91 (Month/Date/Year)Date of Equipment Installation 3/1/91 (Month/Date/Year)Date of Reconstruction (if applicable) na (Month/Date/Year)Date of Modification (if applicable) na (Month/Date/Year)Applicable 40 CFR pt. 60 subpart or Federal Register Reference Subpart DcThis source is also subject to the general provisions of 40 CFR pt. 60, subp. A.Has this Unit Been Permitted Previously?


Have you attached a photocopied, highlighted version of the 40 CFR pt. 60 subpart?YESNO

Describe Emission Equipment Emission Unit Number Stack/Vent Number Date of Equipment Manufacture (Month/Date/Year)Date of Equipment Installation (Month/Date/Year)Date of Reconstruction (if applicable) (Month/Date/Year)Date of Modification (if applicable) (Month/Date/Year)Applicable 40 CFR pt. 60 subpart or Federal Register Reference This source is also subject to the general provisions of 40 CFR pt. 60, subp. A.Has this Unit Been Permitted Previously?



Describe Emission Equipment Emission Unit Number Stack/Vent Number Date of Equipment Manufacture (Month/Date/Year)Date of Equipment Installation (Month/Date/Year)Date of Reconstruction (if applicable) (Month/Date/Year)Date of Modification (if applicable) (Month/Date/Year)Applicable 40 CFR pt. 60 subpart or Federal Register Reference This source is also subject to the general provisions of 40 CFR pt. 60, subp. A.Has this Unit Been Permitted Previously?



DUPLICATE THIS FORM AS NEEDED

TABLE DSTANDARDS OF PERFORMANCE FOR NEW STATIONARY SOURCES

Performance standards promulgated as of April 30, 1998Source categories subject to federal performance

standards40 CFR 60

SubpartEffective date constructed, modified or

reconstructedFossil-Fuel Fired Steam Generators >250 MMBtu D After: 08/17/71Electric Utility Steam Generators >250 MMBtu Da After: 09/18/78Industrial-Commercial-Institutional Steam Generators>100 MMBtu

Db* After: 06/19/84

Small Industrial-Commercial-Institutional SteamGenerators >10 MMBtu but <100 MMBtu

Dc* After: 06/09/89

Incinerators E After: 08/17/71Hospital/Medical/Infectious Waste Incinerators Ec, Ce Initial ConstructionMunicipal Waste Combustors Ea, Eb,

Ca, CbInitial Construction

Portland Cement Plants F After: 08/17/71Nitric Acid Plants G After: 08/17/71Sulfuric Acid Plants H,Cd Initial ConstructionAsphalt Concrete Plants I* After: 06/11/73Petroleum Refineries J After: 06/11/73Storage Vessels for Petroleum Liquids K*, Ka* After: 06/11/73Volatile Organic Liquid Storage Vessels (IncludingPetroleum Liquids)

Kb* After: 07/23/84

Secondary Lead Smelters L After: 06/11/73Secondary Brass and Bronze Production Plants M After: 06/11/73Oxygen Process Furnaces N After: 06/11/73Oxygen Process Steelmaking Facilities Na After: 01/20/83Sewage Treatment Plants O After: 06/11/73Primary Copper Smelters P After: 10/16/74Primary Zinc Smelters Q After: 10/16/74Primary Lead Smelters R After: 10/16/74Primary Aluminum Reduction Plants S After: 10/23/74Phosphate Fertilizer Industry T,U,V,W,X After: 10/22/74Coal Preparation Plants Y After: 10/24/74Ferroalloy Production Facilities Z After: 10/24/74Steel Plants AA,AAa After: 10/21/74Kraft Pulp Mills BB After: 09/24/76Glass Manufacturing Plants CC After: 06/15/79Grain Elevators DD* After: 08/03/78Surface Coating of Metal Furniture EE* After: 11/28/80Stationary Gas Turbines GG After: 10/03/77Lime Manufacturing Plants HH After: 05/03/77Cold Cleaning Machines JJ Promulgation expected in near futureLead-Acid Battery Manufacturing Plants KK After: 01/14/80Metallic Mineral Processing Plants LL After: 08/24/82Automobile and Light-Duty Truck Surface CoatingOperations

MM After: 10/05/79

Phosphate Rock Plants NN After: 09/21/79Ammonium Sulfate Manufacture PP After: 02/04/80

TABLE D, continued

Source categories subject to federal performancestandards

40 CFR 60Subpart

Effective date constructed, modified orreconstructed

Graphic Arts Industry: Publication Rotogravure Printing QQ After: 08/28/80Pressure Sensitive Tape and Label Surface CoatingOperations

RR After: 12/30/80

Industrial Surface Coating: Large Appliances SS After: 12/24/80Metal Coil Surface Coating TT After: 01/05/81Asphalt Processing and Asphalt Roofing Manufacture UU After: 11/18/80Equipment Leaks of VOC in the Synthetic OrganicChemicals Manufacturing Industry

VV* After: 01/05/81

Beverage Can Surface Coating Industry WW* After: 11/26/80Bulk Gasoline Terminals XX* After: 12/17/80New Residential Wood Heaters ** AAA After: 07/01/88Rubber Tire Manufacturing Industry BBB After: 01/20/83VOC Emissions from the Polymer ManufacturingIndustry

DDD After: 09/30/87

Flexible Vinyl and Urethane Coating and Printing FFF After: 01/18/83Equipment Leaks of VOC in Petroleum Refineries GGG After: 01/04/83Synthetic Fiber Production Facilities HHH After: 11/23/82VOC Emissions from the Synthetic Organic ChemicalManufacturing Industry Air Oxidation Unit Processes

III After: 10/21/83

Petroleum Dry Cleaners JJJ After: 12/14/82Onshore Natural Gas Processing: VOC Equipment Leaksand SO2 Emissions

KKK, LLL After: 01/20/84

VOC Emissions from Synthetic Organic ChemicalManufacturing Industry Distillation Operations

NNN* After: 12/30/83

Nonmetallic Mineral Processing Plants (Including Sandand Gravel Processing)

OOO* After: 08/31/83

Wool Fiberglass Insulation Manufacturing Plants PPP After: 02/07/84VOC Emissions from Petroleum Refinery WastewaterSystems

QQQ After: 05/04/87

VOC Emissions from the Synthetic Organic ChemicalManufacturing Industry (SOCMI)Reactor Processes

RRR* After: 06/29/90

Magnetic Tape Coating Facilities SSS After: 01/22/86Industrial Surface Coating: Surface Coating of PlasticParts for Business Machines

TTT After: 01/08/86

Calciners and Dryers in Mineral Industries UUU After: 04/23/86Polymeric Coating of Supporting Substrates Facilities VVV After: 04/30/87Municipal Solid Waste Landfills WWW, Cc Initial Construction* Reprinted versions of regulation available from the MPCA. Contact the Permit Document Coordinator at (651)282-5843 for copies.** According to Minn. Rules Pt. 7007.0300, subp. 1(B), "any stationary source that would be required to obtain a permit solely because it issubject toCode of Federal Regulations, title 40, part 60, subp. AAA" is exempt from permitting.


PERMIT APPLICATION FORM GI-09FREQUIREMENTS: STRATOSPHERICOZONE PROTECTION (40 CFR pt. 82)

05/11/98Stratospheric Ozone Protection(1990 Clean Air Act, as amended, Sections 601-618; 40 CFR pt. 82)

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

1) After reviewing Table F check one of the following:NO, my facility does not manufacture, sell, distribute or use any chemicals from the list, and the1990 Clean Air Act, as amended, Sections 601-618 do not apply to my facility. Return to FormGI-09 Requirements, question 7b.YES, my facility does manufacture, sell, distribute or use one or more of the chemicals from thelist. Go to question 2.

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

2a) 2b) 2c) 2d)Chemical

Name:ClassType:

CASNumber:

Replacement Chemical(after phase out):

3) Return to form GI-09 Requirements, question 7b.

TABLE ECLASS I OZONE DEPLETING CHEMICALS

Group I: Chemical CAS NumberCFCl3-Trichlorofluoromethane (CFC-11) 75-69-4CF2Cl2-Dichlorodifluoromethane (CFC-12) 75-71-8C2F3Cl2-Trichlorotrifluoroethane (CFC-113) 76-13-1C2F4Cl3-Dichlorotetrafluoroethane (CFC-114) 76-14-2C2F5Cl-Monochloropentafluoroethane (CFC-115) 76-15-3All isomers of the above chemicals

Group II: Chemical CAS NumberCF2ClBr-Bromochlorodifluoromethane (Halon-1211) 421-01-2CF3Br-Bromotrifluoroethane (Halon-1301) 75-63-8C2F4Br2-Dibromotetrafluoroethane (Halon-2402) 124-73-2All isomers of the above chemicals

Group III: Chemical CAS NumberCF3Cl-Chlorotrifluoromethane (CFC-13) 75-72-9C2FCl5 (CFC-111) 954-56-3C2F2Cl4 (CFC-112) 76-12-0C3FCl7 (CFC-211) 422-78-6C3F2Cl6 (CFC-212) 3182-26-1C3F3Cl5 (CFC-213) 2354-06-5C3F4Cl4 (CFC-214) 29255-31-0C3F5Cl3 (CFC-215) 4259-43-2C3F6Cl2 (CFC-216) 661-97-2C3F7Cl (CFC-217) 422-86-6All isomers of the above chemicals

Group IV: Chemical CAS NumberCCl-Carbon Tetrachloride 56-23-5

Group V: Chemical CAS NumberC2H3Cl3-1,1,1 Trichloroethane (Methyl chloroform) 71-55-6All isomers of the above chemical except 1,1,2-trichloroethane 79-00-5

Group VI: Chemical CAS NumberCH3BR - Bromomethane (Methyl Bromide)

Group VII: Chemical CAS NumberCHFBR2CHF2Br (HBFC-22B1)CH2FBrC2HFBr4C2HF2Br3C2HF3Br2C2HF4BrC2H2FBr3C2H2F2Br2C2H2F3BrC2H2FBr2C2H3F2BrC2H4FBrC3HFBr6C3HF2Br5

TABLE E (continued)

Group VII: Chemical CAS NumberC3HF3Br4C3HF4Br3C3HF5Br2C3HF6BrC3H2FBR5C3H2F2BR4C3H2F3Br3C3H2F4Br2C3H2F5BRC3H3FBR4C3H3F2Br3C3H3F3Br2C3H3F4BrC3H4FBr3C3H4F2Br2C3H4F3BrC3H5FBr2C3H5F2BrC3H6FB

TABLE FCLASS II OZONE DEPLETING CHEMICALS

Chemical CAS NumberHCFC-21 CHFCl2 -dichlorofluoromethane 75-43-4HCFC-22 CHF2Cl -chlorodifluoromethane 75-45-6HCFC-31 CH2FCl -chlorofluoromethane 593-70-4HCFC-121 C2HFCl4 -tetrachlorofluoroethane 130879-71-9HCFC-121 C2HFCl4 -tetrachlorofluoroethane 134237-32-4HCFC-121 C2HFCl4 -1,1,1,2-tetrachloro-2-fluoroethane 354-11-0HCFC-121 C2HFCl4 -1,1,2,2-tetrachloro-1-fluoroethane 354-14-3HCFC-122 C2HF2Cl3 -trichlorodifluoroethane 41834-16-6HCFC-122 C2HF2Cl3 -trichloro-1,1-difluoroethane 55949-46-7HCFC-122 C2HF2Cl3 -1,2,2-trichloro-1,1-difluoroethane 354-21-2HCFC-122 C2HF2Cl3 -1,2,2-trichloro-1,2-difluoroethane 354-15-4HCFC-122 C2HF2Cl3 -1,1,1-trichloro-2,2-difluoroethane 354-12-1HCFC-122 C2HF2Cl3 -1,1,2-trichloro-2,2-difluoroethane NAHCFC-123 C2HF3Cl2 -dichlorotrifluoroethane 34077-87-7HCFC-123 C2HF3Cl2 -dichlorotrifluoroethane 134237-33-5HCFC-123 C2HF3Cl2 -dichloro-1,1,2-trifluoroethane 90454-18-5HCFC-123 C2HF3Cl2 -2,2-dichloro-1,1,1-trifluoroethane 306-83-2HCFC-123a C2HF3Cl2 -1,2-dichloro-1,1,2-trifluoroethane 354-23-4HCFC-123b C2HF3Cl2 -1,1-dichloro-1,2,2-trifluoroethane 812-04-4HCFC-123 C2HF3Cl2 -2,2-dichloro-1,1,2-trifluoroethane NAHCFC-124 C2HF4Cl -chlorotetrafluoroethane 63938-10-3HCFC-124 C2HF4Cl -2-chloro-1,1,1,2-tetrafluoroethane 2837-89-0HCFC-124 C2HF4Cl -1-chloro-1,1,2,2-tetrafluoroethane 354-25-6HCFC-131 C2H2FCl3 -trichlorofluoroethane 27154-33-2HCFC-131 C2H2FCl3 -trichlorofluoroethane 134237-34-6HCFC-131 C2H2FCl3 -1,1,2-trichloro-1 (or 2)-fluoroethane 90134-98-8HCFC-131b C2H2FCl3 -1,1,1-trichloro-2-fluoroethane 2366-36-1HCFC-131a C2H2FCl3 -1,1,2-trichloro-1-fluoroethane 811-95-0HCFC-131 C2H2FCl3 -1,1,2-trichloro-2-fluoroethane 359-28-4HCFC-132 C2H2F2Cl2 -dichlorodifluoroethane 25915-78-0HCFC-132 C2H2F2Cl2 -dichloro-1,1-difluoroethane 55494-45-6HCFC-132 C2H2F2Cl2 -1,1-dichlorodifluoroethane 31153-51-2HCFC-132 C2H2F2Cl2 -1,2-dichloro-1,2-difluoroethane 33579-37-2HCFC-132 C2H2F2Cl2 -1,2-dichloro-1,2-difluoroethane 33489-30-4HCFC-132c C2H2F2Cl2 -1,1-dichloro-1,2-difluoroethane 1842-05-3HCFC-132b C2H2F2Cl2 -1,2-dichloro-1,1-difluoroethane 1649-08-7HCFC-132a C2H2F2Cl2 -1,1-dichloro-2,2-difluoroethane 471-43-2HCFC-132 C2H2F2Cl2 -1,2-dichloro-1,2-difluoroethane 431-06-1HCFC-133 C2H2F3Cl -chlorotrifluoroethane 13330-45-6HCFC-133 C2H2F3Cl -1-chloro-1,2,2-trifluoroethane 431-07-2HCFC-133b C2H2F3Cl -1-chloro-1,1,2-trifluoroethane 421-04-5HCFC-133a C2H2F3Cl -2-chloro-1,1,1-trifluoroethane 75-88-7HCFC-141 C2H3FCl2 -dichlorofluoroethane 25167-88-8HCFC-141b C2H3FCl2 -1,1-dichloro-1-fluoroethane 1717-00-6HCFC-141 C2H3FCl2 -1,2-dichloro-1-fluoroethane 430-57-9HCFC-141a C2H3FCl2 -1,1-dichloro-2-fluoroethane 430-53-5HCFC-142 C2H3F2Cl -chlorodifluoroethane 25497-29-4HCFC-142 C2H3F2Cl -chloro-1,1-difluoroethane 55949-44-5HCFC-142a C2H3F2Cl -2-chloro-1,1-difluoroethane 338-65-8HCFC-142b C2H3F2Cl -1-chloro-1,2-difluoroethane 338-64-7HCFC-142 C2H3F2Cl -1-chloro-1,1-difluoroethane 75-68-3HCFC-221 C3HFCl6 -hexachlorofluoropropane 29470-94-8

TABLE F (continued)

Chemical CAS NumberHCFC-221 C3HFCl6 -hexachlorofluoropropane 134237-35-7HCFC-221 C3HFCl6 -1,1,1,2,3,3-hexachloro-3-fluoropropane 431-79-8HCFC-221 C3HFCl6 -1,1,1,2,3,3-hexachloro-2-fluoropropane 422-40-2HCFC-221 C3HFCl6 -1,1,1,2,2,3-hexachloro-1-fluoropropane 422-26-4HCFC-221 C3HFCl6 -1,1,2,2,3,3-hexachloro-1-fluoropropane 422-28-6HCFC-221 C3HFCl6 -1,1,1,3,3,3-hexachloro-2-fluoropropane NAHCFC-222 C3HF2Cl5 -pentachlorodifluoropropane 116867-32-4HCFC-222 C3HF2Cl5 -pentachlorodifluoropropane 134237-36-8HCFC-222 C3HF2Cl5 -1,1,2,3,3-pentachloro-1,3-difluoropropane 421-82-3HCFC-222 C3HF2Cl5 -1,1,1,2,3-pentachloro-3,3-difluoropropane 431-80-1HCFC-222c C3HF2Cl5 -1,1,1,3,3-pentachloro-2,2-difluoropropane 422-49-1HCFC-222 C3HF2Cl5 -1,2,2,3,3-pentachloro-1,1-difluoropropane 422-30-0HCFC-222 C3HF2Cl5 -1,1,1,2,2-pentachloro-3,3-difluoropropane 422-27-5HCFC-222 C3HF2Cl5 -1,1,1,2,3-pentachloro-2,3-difluoropropane NAHCFC-222 C3HF2Cl5 -1,1,1,3,3-pentachloro-2,3-difluoropropane NAHCFC-222 C3HF2Cl5 -1,1,2,2,3-pentachloro-1,3-difluoropropane NAHCFC-222 C3HF2Cl5 -1,1,2,3,3-pentachloro-1,2-difluoropropane NAHCFC-223 C3HF3Cl4 -tetrachlorotrifluoropropane 29470-95-9HCFC-223 C3HF3Cl4 -tetrachlorotrifluoropropane 134237-37-9HCFC-223 C3HF3Cl4 -1,1,1,3-tetrachloro-2,3,3-trifluoropropane 54002-59-4HCFC-223 C3HF3Cl4 -1,1,2,3-tetrachloro-1,3,3-trifluoropropane 431-83-4HCFC-223 C3HF3Cl4 -1,1,1,2-tetrachloro-3,3,3-trifluoropropane 431-81-2HCFC-223ca C3HF3Cl4 -1,1,3,3-tetrachloro-1,2,2-trifluoropropane 422-52-6HCFC-223cb C3HF3Cl4 -1,1,1,3-tetrachloro-2,2,3-trifluoropropane 422-50-4HCFC-223 C3HF3Cl4 -1,2,3,3-tetrachloro-1,1,2-trifluoropropane 422-41-3HCFC-223 C3HF3Cl4 -2,2,3,3-tetrachloro-1,1,1-trifluoropropane 422-35-5HCFC-223 C3HF3Cl4 -1,1,2,2-tetrachloro-1,3,3-trifluoropropane 422-29-7HCFC-223 C3HF3Cl4 -1,1,1,2-tetrachloro-2,3,3-trifluoropropane NAHCFC-223 C3HF3Cl4 -1,1,3,3-tetrachloro-1,2,3-trifluoropropane NAHCFC-223 C3HF3Cl4 -1,2,2,3-tetrachloro-1,1,3-trifluoropropane NAHCFC-223 C3HF3Cl4 -1,1,2,3-tetrachloro-1,2,3-trifluoropropane NAHCFC-224 C3HF4Cl3 -trichlorotetrafluoropropane 127564-91-4HCFC-224 C3HF4Cl3 -trichlorotetrafluoropropane 134237-38-0HCFC-224 C3HF4Cl3 -1,1,3-trichloro-1,2,3,3-tetrafluoropropane 53063-53-9HCFC-224 C3HF4Cl3 -1,1,1-trichloro-2,3,3,3-tetrafluoropropane 53063-52-8HCFC-224 C3HF4Cl3 -1,2,3-trichloro-1,1,3,3-tetrafluoropropane 431-85-6HCFC-224 C3HF4Cl3 -1,1,2-trichloro-1,3,3,3-tetrafluoropropane 431-84-5HCFC-224ca C3HF4Cl3 -1,3,3-trichloro-1,1,2,2-tetrafluoropropane 422-54-8HCFC-224cb C3HF4Cl3 -1,1,3-trichloro-1,2,2,3-tetrafluoropropane 422-53-7HCFC-224cc C3HF4Cl3 -1,1,1-trichloro-2,2,3,3-tetrafluoropropane 422-51-5HCFC-224 C3HF4Cl3 -2,3,3-trichloro-1,1,1,2-tetrafluoropropane 422-47-9HCFC-224 C3HF4Cl3 -1,2,3-trichloro-1,1,2,3-tetrafluoropropane 422-42-4HCFC-224 C3HF4Cl3 -1,2,2-trichloro-1,1,3,3-tetrafluoropropane 422-32-2HCFC-224 C3HF4Cl3 -2,2,3-trichloro-1,1,1,3-tetrafluoropropane NAHCFC-224 C3HF4Cl3 -1,1,2-trichloro-1,2,3,3-tetrafluoropropane NAHCFC-225 C3HF5Cl2 -dichloropentafluoropropane 127564-92-5HCFC-225 C3HF5Cl2 -1,3-dichloro-1,1,2,3,3-pentafluoropropane 136013-79-1HCFC-225aa C3HF5Cl2 -2,2-dichloro-1,1,1,3,3-pentafluoropropane 128903-21-9HCFC-225 C3HF5Cl2 -1,1-dichloro-1,2,3,3,3-pentafluoropropane 111512-56-2HCFC-225 C3HF5Cl2 -2,3-dichloro-1,1,1,2,3-pentafluoropropane 111512-55-1HCFC-225 C3HF5Cl2 -2,3-dichloro-1,1,1,2,3-pentafluoropropane 111512-51-7HCFC-225cc C3HF5Cl2 -1,1-dichloro-1,2,2,3,3-pentafluoropropane 13474-88-9HCFC-225cb C3HF5Cl2 -1,3-dichloro-1,1,2,2,3-pentafluoropropane 507-55-1

TABLE F (continued)

Chemical CAS NumberHCFC-225da C3HF5Cl2 -1,2-dichloro-1,1,3,3,3-pentafluoropropane 431-86-7HCFC-225ca C3HF5Cl2 -3,3-dichloro-1,1,1,2,2-pentafluoropropane 422-56-0HCFC-225ba C3HF5Cl2 -2,3-dichloro-1,1,1,2,3-pentafluoropropane 422-48-0HCFC-225 C3HF5Cl2 -1,2-dichloro-1,1,2,3,3-pentafluoropropane 422-44-6HCFC-226 C3HF6Cl -chlorohexafluoropropane 28987-04-4HCFC-226 C3HF6Cl -chlorohexafluoropropane 134308-72-8HCFC-226ba C3HF6Cl -2-chloro-1,1,1,2,3,3-hexafluoropropane 51346-64-6HCFC-226da C3HF6Cl -2-chloro-1,1,1,3,3,3-hexafluoropropane 431-87-8HCFC-226ca C3HF6Cl -3-chloro-1,1,1,2,2,3-hexafluoropropane 422-57-1HCFC-226cb C3HF6Cl -1-chloro-1,1,2,2,3,3-hexafluoropropane 422-55-9HCFC-226ea C3HF6Cl -1-chloro-1,1,2,3,3,3-hexafluoropropane 359-58-0HCFC-231 C3H2FCl5 -pentachlorofluoropropane NAHCFC-231 C3H2FCl5 -pentachlorofluoropropane 134190-48-0HCFC-231 C3H2FCl5 -1,1,1,2,3-pentachloro-2-fluoropropane 421-94-3HCFC-231 C3H2FCl5 -1,1,2,3,3-pentachloro-2-fluoropropane NAHCFC-231 C3H2FCl5 -1,1,1,3,3-pentachloro-3-fluoropropane NAHCFC-231 C3H2FCl5 -1,1,2,2,3-pentachloro-1-fluoropropane NAHCFC-231 C3H2FCl5 -1,1,1,2,2-pentachloro-3-fluoropropane NAHCFC-231 C3H2FCl5 -1,1,1,2,3-pentachloro-3-fluoropropane NAHCFC-231 C3H2FCl5 -1,1,1,3,3-pentachloro-2-fluoropropane NAHCFC-231 C3H2FCl5 -1,1,2,2,3-pentachloro-3-fluoropropane NAHCFC-231 C3H2FCl5 -1,1,2,3,3-pentachloro-1-fluoropropane NAHCFC-232 C3H2F2Cl4 -tetrachlorodifluoropropane 127564-82-3HCFC-232 C3H2F2Cl4 -tetrachlorodifluoropropane 134237-39-1HCFC-232 C3H2F2Cl4 -1,2,3,3-tetrachloro-1,1-difluoropropane 67879-59-8HCFC-232ca C3H2F2Cl4 -1,1,3,3-tetrachloro-2,2-difluoropropane 1112-14-7HCFC-232cb C3H2F2Cl4 -1,1,1,3-tetrachloro-2,2-difluoropropane 677-54-3HCFC-232 C3H2F2Cl4 -1,1,1,3-tetrachloro-3,3-difluoropropane 460-89-9HCFC-232 C3H2F2Cl4 -1,1,1,3-tetrachloro-2,3-difluoropropane NAHCFC-232 C3H2F2Cl4 -1,1,1,2-tetrachloro-2,3-difluoropropane NAHCFC-232 C3H2F2Cl4 -1,1,1,2-tetrachloro-3,3-difluoropropane NAHCFC-232 C3H2F2Cl4 -1,1,3,3-tetrachloro-1,2-difluoropropane NAHCFC-232 C3H2F2Cl4 -1,1,2,3-tetrachloro-1,2-difluoropropane NAHCFC-232 C3H2F2Cl4 -1,1,2,3-tetrachloro-1,3-difluoropropane NAHCFC-232 C3H2F2Cl4 -1,2,3,3-tetrachloro-1,2-difluoropropane NAHCFC-232 C3H2F2Cl4 -1,2,2,3-tetrachloro-1,1-difluoropropane NAHCFC-232 C3H2F2Cl4 -1,2,2,3-tetrachloro-1,3-difluoropropane NAHCFC-232 C3H2F2Cl4 -1,1,3,3-tetrachloro-1,3-difluoropropane NAHCFC-232 C3H2F2Cl4 -1,1,2,2-tetrachloro-3,3-difluoropropane NAHCFC-232 C3H2F2Cl4 -1,1,2,2-tetrachloro-1,3-difluoropropane NAHCFC-233 C3H2F3Cl3 -trichlorotrifluoropropane 61623-04-9HCFC-233 C3H2F3Cl3 -trichlorotrifluoropropane 134237-40-4HCFC-233ca C3H2F3Cl3 -1,1,3-trichloro-2,2,3-trifluoropropane 131221-36-8HCFC-233cc C3H2F3Cl3 -1,1,1-trichloro-2,2,3-trifluoropropane 131211-71-7HCFC-233 C3H2F3Cl3 -1,1,3-trichloro-1,2,3-trifluoropropane 54377-32-1HCFC-233 C3H2F3Cl3 -1,1,1-trichloro-2,3,3-trifluoropropane 54306-56-8HCFC-233 C3H2F3Cl3 -1,1,2-trichloro-2,3,3-trifluoropropane 13058-99-6HCFC-233 C3H2F3Cl3 -1,1,1-trichloro-3,3,3-trifluoropropane 7125-84-0HCFC-233 C3H2F3Cl3 -2,2,3-trichloro-1,1,1-trifluoropropane 7125-83-9HCFC-233 C3H2F3Cl3 -2,3,3-trichloro-1,1,1-trifluoropropane 431-51-6HCFC-233cb C3H2F3Cl3 -1,1,3-trichloro-1,2,2-trifluoropropane 421-99-8HCFC-233 C3H2F3Cl3 -1,2,3-trichloro-1,1,2-trifluoropropane 421-95-4HCFC-233 C3H2F3Cl3 -1,1,3-trichloro-1,3,3-trifluoropropane 333-26-6

TABLE F (continued)

Chemical CAS NumberHCFC-233 C3H2F3Cl3 -1,1,2-trichloro-1,2,3-trifluoropropane NAHCFC-233 C3H2F3Cl3 -1,2,3-trichloro-1,2,3-trifluoropropane NAHCFC-233 C3H2F3Cl3 -1,1,2-trichloro-1,3,3-trifluoropropane NAHCFC-233 C3H2F3Cl3 -1,3,3-trichloro-1,1,2-trifluoropropane NAHCFC-233 C3H2F3Cl3 -2,2,3-trichloro-1,1,3-trifluoropropane NAHCFC-233 C3H2F3Cl3 -1,2,3-trichloro-1,1,3-trifluoropropane NAHCFC-233 C3H2F3Cl3 -1,2,2-trichloro-1,1,3-trifluoropropane NAHCFC-234 C3H2F4Cl2 -dichlorotetrafluoropropane 127564-83-4HCFC-234fa C3H2F4Cl2 -1,3-dichloro-1,1,3,3-tetrafluoropropane 76140-39-1HCFC-234ca C3H2F4Cl2 -1,3-dichloro-1,2,2,3-tetrafluoropropane 70341-81-0HCFC-234cd C3H2F4Cl2 -1,1-dichloro-1,2,2,3-tetrafluoropropane 70192-63-1HCFC-234 C3H2F4Cl2 -1,1-dichloro-1,3,3,3-tetrafluoropropane 64712-27-2HCFC-234 C3H2F4Cl2 -1,3-dichloro-1,1,2,3-tetrafluoropropane 53149-65-8HCFC-234 C3H2F4Cl2 -1,3-dichloro-1,1,2,3-tetrafluoropropane 5306355-1HCFC-234 C3H2F4Cl2 -3,3-dichloro-1,1,1,2-tetrafluoropropane 53063-54-0HCFC-234 C3H2F4Cl2 -2,2-dichloro-1,1,3,3-tetrafluoropropane 17705-30-5HCFC-234cb C3H2F4Cl2 -1,1-dichloro-2,2,3,3-tetrafluoropropane 4071-01-6HCFC-234 C3H2F4Cl2 -1,2-dichloro-1,2,3,3-tetrafluoropropane 425-94-5HCFC-234cc C3H2F4Cl2 -1,3-dichloro-1,1,2,2-tetrafluoropropane 422-00-5HCFC-234da C3H2F4Cl2 -2,3-dichloro-1,1,1,3-tetrafluoropropane NAHCFC-234 C3H2F4Cl2 -1,1-dichloro-1,2,3,3-tetrafluoropropane NAHCFC-234 C3H2F4Cl2 -1,2-dichloro-1,1,3,3-tetrafluoropropane NAHCFC-234 C3H2F4Cl2 -2,3-dichloro-1,1,1,2-tetrafluoropropane NAHCFC-234 C3H2F4Cl2 -2,2-dichloro-1,1,1,3-tetrafluoropropane NAHCFC-234 C3H2F4Cl2 -1,2-dichloro-1,1,2,3-tetrafluoropropane NAHCFC-234 C3H2F4Cl2 -1,3-dichloro-1,1,2,3-tetrafluoropropane NAHCFC-235 C3H2F5Cl -chloropentafluoropropane 108662-83-5HCFC-235 C3H2F5Cl -chloropentafluoropropane 134237-83-5HCFC-235 C3H2F5Cl -3-chloro-1,1,1,2,3-pentafluoropropane 134251-06-2HCFC-235da C3H2F5Cl -2-chloro-1,1,1,3,3-pentafluoropropane 28103-66-4HCFC-235ca C3H2F5Cl -1-chloro-1,2,2,3,3-pentafluoropropane 679-99-2HCFC-235cc C3H2F5Cl -1-chloro-1,1,2,2,3-pentafluoropropane 677-55-4HCFC-235fa C3H2F5Cl -1-chloro-1,1,3,3,3-pentafluoropropane 460-92-4HCFC-235cb C3H2F5Cl -3-chloro-1,1,1,2,2-pentafluoropropane 422-02-6HCFC-235 C3H2F5Cl -2-chloro-1,1,1,2,3-pentafluoropropane NAHCFC-235 C3H2F5Cl -1-chloro-1,1,2,3,3-pentafluoropropane NAHCFC-235 C3H2F5Cl -2-chloro-1,1,2,3,3-pentafluoropropane NAHCFC-241 C3H3FCl4 -tetrachlorofluoropropane NAHCFC-241 C3H3FCl4 -tetrachlorofluoropropane 134190-49-1HCFC-241 C3H3FCl4 -1,1,1,2-tetrachloro-3-fluoropropane 84816-05-7HCFC-241 C3H3FCl4 -1,1,1,3-tetrachloro-3-fluoropropane 23153-22-2HCFC-241 C3H3FCl4 -1,1,2,3-tetrachloro-3-fluoropropane 21981-25-9HCFC-241 C3H3FCl4 -1,1,2,2-tetrachloro-1-fluoropropane 7126-06-9HCFC-241 C3H3FCl4 -1,1,2,3-tetrachloro-2-fluoropropane 3175-26-6HCFC-241 C3H3FCl4 -1,1,1,2-tetrachloro-2-fluoropropane 3175-25-5HCFC-241 C3H3FCl4 -1,1,2,3-tetrachloro-1-fluoropropane 666-27-3HCFC-241 C3H3FCl4 -1,1,1,3-tetrachloro-2-fluoropropane NAHCFC-241 C3H3FCl4 -1,1,2,2-tetrachloro-3-fluoropropane NAHCFC-241 C3H3FCl4 -1,2,2,3-tetrachloro-1-fluoropropane NAHCFC-241 C3H3FCl4 -1,1,3,3-tetrachloro-1-fluoropropane NAHCFC-241 C3H3FCl4 -1,1,3,3-tetrachloro-2-fluoropropane NAHCFC-242 C3H3F2Cl3 -trichlorodifluoropropane 127564-90-3HCFC-242 C3H3F2Cl3 -trichlorodifluoropropane 134237-42-6

TABLE F (continued)

Chemical CAS NumberHCFC-242 C3H3F2Cl3 -1,3,3-trichloro-1,1-difluoropropane 460-63-9HCFC-242 C3H3F2Cl3 -1,2,3-trichloro-1,2-difluoropropane 7164-14-9HCFC-242 C3H3F2Cl3 -1,1,3-trichloro-2,2-difluoropropane 1112-13-6HCFC-242 C3H3F2Cl3 -1,2,3-trichloro-1,1-difluoropropane 431-24-3HCFC-242 C3H3F2Cl3 -1,1,1-trichloro-2,2-difluoropropane 1112-05-6HCFC-242 C3H3F2Cl3 -1,2,2-trichloro-1,1-difluoropropane 7126-05-8HCFC-242 C3H3F2Cl3 -1,1,2-trichloro-1,2-difluoropropane 7126-04-7HCFC-242 C3H3F2Cl3 -1,1,1-trichloro-2,3-difluoropropane NAHCFC-242 C3H3F2Cl3 -1,1,2-trichloro-1,3-difluoropropane NAHCFC-242 C3H3F2Cl3 -1,1,3-trichloro-1,2-difluoropropane NAHCFC-242 C3H3F2Cl3 -1,1,2-trichloro-2,3-difluoropropane NAHCFC-242 C3H3F2Cl3 -1,2,2-trichloro-1,3-difluoropropane NAHCFC-242 C3H3F2Cl3 -2,2,3-trichloro-1,1-difluoropropane NAHCFC-242 C3H3F2Cl3 -1,1,1-trichloro-3,3-difluoropropane NAHCFC-242 C3H3F2Cl3 -1,1,3-trichloro-1,3-difluoropropane NAHCFC-242 C3H3F2Cl3 -1,1,2-trichloro-3,3-difluoropropane NAHCFC-242 C3H3F2Cl3 -1,1,3-trichloro-2,3-difluoropropane NAHCFC-242 C3H3F2Cl3 -1,2,3-trichloro-1,3-difluoropropane NAHCFC-243 C3H3F3Cl2 -dichlorotrifluoropropane 116890-51-8HCFC-243 C3H3F3Cl2 -dichlorotrifluoropropane 134237-43-7HCFC-243 C3H3F3Cl2 -2,2-dichloro-1,1,1-trifluoropropane 7126-01-4HCFC-243cc C3H3F3Cl2 -1,1-dichloro-1,2,2-trifluoropropane 7125-99-7HCFC-243 C3H3F3Cl2 -1,2-dichloro-1,1,2-trifluoropropane 7126-00-3HCFC-243da C3H3F3Cl2 -2,3-dichloro-1,1,1-trifluoropropane 338-75-0HCFC-243ca C3H3F3Cl2 -1,3-dichloro-1,2,2-trifluoropropane 67406-68-2HCFC-243cb C3H3F3Cl2 -1,1-dichloro-2,2,3-trifluoropropane 70192-70-0HCFC-243 C3H3F3Cl2 -3,3-dichloro-1,1,1-trifluoropropane 460-69-5HCFC-243 C3H3F3Cl2 -1,3-dichloro-1,1,2-trifluoropropane NAHCFC-243 C3H3F3Cl2 -1,2-dichloro-1,1,3-trifluoropropane NAHCFC-243 C3H3F3Cl2 -1,1-dichloro-1,2,3-trifluoropropane NAHCFC-243 C3H3F3Cl2 -2,3-dichloro-1,1,2-trifluoropropane NAHCFC-243 C3H3F3Cl2 -2,2-dichloro-1,1,3-trifluoropropane NAHCFC-243 C3H3F3Cl2 -1,2-dichloro-1,2,3-trifluoropropane NAHCFC-243 C3H3F3Cl2 -1,3-dichloro-1,1,3-trifluoropropane NAHCFC-243 C3H3F3Cl2 -1,1-dichloro-1,3,3-trifluoropropane NAHCFC-243 C3H3F3Cl2 -3,3-dichloro-1,1,2-trifluoropropane NAHCFC-243 C3H3F3Cl2 -2,3-dichloro-1,1,3-trifluoropropane NAHCFC-243 C3H3F3Cl2 -1,3-dichloro-1,2,3trifluoropropane NAHCFC-244 C3H3F4Cl -chlorotetrafluoropropane NAHCFC-244 C3H3F4Cl -chlorotetrafluoropropane 134190-50-4HCFC-244db C3H3F4Cl -2-chloro-1,1,1,3-tetrafluoropropane 117970-90-8HCFC-244ca C3H3F4Cl -3-chloro-1,1,2,2-tetrafluoropropane 679-85-6HCFC-244cb C3H3F4Cl -1-chloro-1,2,2,3-tetrafluoropropane 67406-66-0HCFC-244fb C3H3F4Cl -1-chloro-1,1,3,3-tetrafluoropropane 2730-64-5HCFC-244da C3H3F4Cl -2-chloro-1,1,3,3-tetrafluoropropane 19041-02-2HCFC-244bb C3H3F4Cl -2-chloro-1,1,1,2-tetrafluoropropane 421-73-8HCFC-244cc C3H3F4Cl -1-chloro-1,1,2,2-tetrafluoropropane 421-75-0HCFC-244 C3H3F4Cl -1-chloro-1,1,2,3-tetrafluoropropane NAHCFC-244 C3H3F4Cl -3-chloro-1,1,1,2-tetrafluoropropane NAHCFC-244 C3H3F4Cl -2-chloro-1,1,2,3-tetrafluoropropane NAHCFC-244 C3H3F4Cl -3-chloro-1,1,1,3-tetrafluoropropane NAHCFC-244 C3H3F4Cl -3-chloro-1,1,2,3-tetrafluoropropane NAHCFC-251 C3H4FCl3 -trichlorofluoropropane NA

TABLE F (continued)

Chemical CAS NumberHCFC-251 C3H4FCl3 -trichlorofluoropropane 134190-51-5HCFC-251 C3H4FCl3 -1,2,3-trichloro-1-fluoropropane 84847-80-3HCFC-251 C3H4FCl3 -1,2,3-trichloro-1-fluoropropane 84847-79-0HCFC-251 C3H4FCl3 -1,2,3-trichloro-1-fluoropropane 76985-34-7HCFC-251 C3H4FCl3 -1,2,3-trichloro-1-fluoropropane 76985-33-6HCFC-251 C3H4FCl3 -1,2,3-trichloro-1-fluoropropane 67832-50-2HCFC-251 C3H4FCl3 -1,2,3-trichloro-1-fluoropropane 67832-44-4HCFC-251 C3H4FCl3 -1,2,3-trichloro-2-fluoropropane 7126-16-1HCFC-251 C3H4FCl3 -1,2,2-trichloro-3-fluoropropane 70192-89-1HCFC-251 C3H4FCl3 -1,1,3-trichloro-1-fluoropropane 818-99-5HCFC-251 C3H4FCl3 -1,1,3-trichloro-2-fluoropropane 76937-36-5HCFC-251 C3H4FCl3 -1,1,2-trichloro-1-fluoropropane 421-41-0HCFC-251 C3H4FCl3 -1,1,2-trichloro-2-fluoropropane 3175-24-4HCFC-251 C3H4FCl3 -1,1,1-trichloro-2-fluoropropane NAHCFC-251 C3H4FCl3 -1,1,1-trichloro-3-fluoropropane NAHCFC-251 C3H4FCl3 -1,1,2-trichloro-3-fluoropropane NAHCFC-251 C3H4FCl3 -1,1,3-trichloro-3-fluoropropane NAHCFC-251 C3H4FCl3 -1,2,2-trichloro-1-fluoropropane NAHCFC-251 C3H4FCl3 -1,2,3-trichloro-1-fluoropropane NAHCFC-252 C3H4F2Cl2 -dichlorodifluoropropane NAHCFC-252 C3H4F2Cl2 -dichlorodifluoropropane 134190-52-6HCFC-252cb C3H4F2Cl2 -1,1-dichloro-2,2-difluoropropane 1112-01-2HCFC-252 C3H4F2Cl2 -1,1-dichloro-3,3-difluoropropane 131404-17-6HCFC-252 C3H4F2Cl2 -1,1-dichloro-1,3-difluoropropane 121612-64-4HCFC-252 C3H4F2Cl2 -1,2-dichloro-1,1-difluoropropane 7126-15-0HCFC-252 C3H4F2Cl2 -1,2-dichloro-2,3-difluoropropane 70192-74-4HCFC-252 C3H4F2Cl2 -2,3-dichloro-1,1-difluoropropane 82578-00-5HCFC-252 C3H4F2Cl2 -1,3-dichloro-1,1-difluoropropane 819-00-1HCFC-252 C3H4F2Cl2 -1,3-dichloro-1,2-difluoropropane 111483-26-2HCFC-252ca C3H4F2Cl2 -1,3-dichloro-2,2-difluoropropane 1112-36-3HCFC-252 C3H4F2Cl2 -1,1-dichloro-1,2-difluoropropane NAHCFC-252 C3H4F2Cl2 -1,1-dichloro-2,3-difluoropropane NAHCFC-252 C3H4F2Cl2 -1,2-dichloro-1,2-difluoropropane NAHCFC-252 C3H4F2Cl2 -1,2-dichloro-1,3-difluoropropane NAHCFC-252 C3H4F2Cl2 -1,3-dichloro-1,3-difluoropropane NAHCFC-252 C3H4F2Cl2 -2,2-dichloro-1,1-difluoropropane NAHCFC-252 C3H4F2Cl2 -2,2-dichloro-1,3-difluoropropane NAHCFC-253 C3H4F3 Cl-chlorotrifluoropropane 26588-23-8HCFC-253 C3H4F3 Cl -chlorotrifluoropropane 134237-44-8HCFC-253 C3H4F3 Cl -2-chloro-1,1,1-trifluoropropane 421-47-6HCFC-253 C3H4F3 Cl -3-chloro-1,1,1-trifluoropropane 460-35-5HCFC-253 C3H4F3 Cl -1-chloro-1,1,2-trifluoropropane 134251-05-1HCFC-253 C3H4F3 Cl -2-chloro-1,1,2-trifluoropropane 69202-10-4HCFC-253 C3H4F3 Cl -3-chloro-1,1,2-trifluoropropane 121612-65-5HCFC-253 C3H4F3 Cl -1-chloro-1,1,3-trifluoropropane 83124-56-5HCFC-253cb C3H4F3 Cl -1-chloro-1,2,2-trifluoropropane 70192-76-6HCFC-253ca C3H4F3 Cl -1-chloro-2,2,3-trifluoropropane 56758-54-4HCFC-253 C3H4F3 Cl -2-chloro-1,1,3-trifluoropropane NAHCFC-253 C3H4F3 Cl -3-chloro-1,1,3-trifluoropropane NAHCFC-253 C3H4F3 Cl -1-chloro-1,2,3-trifluoropropane NAHCFC-253 C3H4F3 Cl -2-chloro-1,2,3-trifluoropropane NAHCFC-261 C3H5FCl2 -dichlorofluoropropane 127404-11-9HCFC-261 C3H5FCl2 -dichlorofluoropropane 134237-45-9


PERMIT APPLICATION FORM GI-09GREQUIREMENTS: RISK MANAGEMENT

PROGRAMS FOR CHEMICALACCIDENTAL RELEASE PREVENTION

(40 CFR pt. 68)05/11/98

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

TABLE GLIST OF REGULATED TOXIC SUBSTANCES AND THRESHOLD

QUANTITIES FOR ACCIDENTAL RELEASE PREVENTION

Chemical Name CAS No.ThresholdQuantity(lbs)

Acetaldehyde 75-07-0 10,000Acetylene [Ethyne] 74-86-2 10,000Acrolein [2-Propenal] 107-02-8 5,000Acrylonitrile [2-Propenenitrile] 107-13-1 20,000Acrylyl chloride [2-Propenoyl chloride] 814-68-6 5,000Allyl alcohol [2-Propen-1-ol] 107-18-6 15,000Allylamine [2-Propen-1-amine] 107-11-9 10,000Ammonia (anhydrous) 7664-41-7 10,000Ammonia (conc 20% or greater) 7664-41-7 20,000Arsenous trichloride 7784-34-1 15,000Arsine 7784-42-1 1,000Boron trichloride [Borane, trichloro-] 10294-34-5 5,000Boron trifluoride [Borane, trifluoro-] 7637-07-2 5,000Boron trifluoride compound with methyl ether (1:1) [Boron,trifluoro[oxybis[metane]]-, T-4-

353-42-4 15,000

Bromine 7726-95-6 10,000Bromotrifluorethylene [Ethene, bromotrifluoro-] 598-73-2 10,0001,3-Butadiene 106-99-0 10,000Butane 106-97-8 10,0001-Butene 106-98-9 10,0002-Butene 107-01-7 10,000Butene 25167-67-3 10,0002-Butene-cis 590-18-1 10,0002-Butene-trans [2-Butene, (E)] 624-64-6 10,000Carbon disulfide 75-15-0 20,000Carbon oxysulfide [Carbon oxide sulfide (COS)] 463-58-1 10,000Chlorine 7782-50-5 2,500Chlorine dioxide [Chlorine oxide (ClO2)] 10049-04-4 1,000Chlorine monoxide [Chlorine oxide] 7791-21-1 10,000Chloroform [Methane, trichloro-] 67-66-3 20,000Chloromethyl ether [Methane, oxybis[chloro-] 542-88-1 1,000Chloromethyl methyl ether [Methane, chloromethoxy-] 107-30-2 5,0002-Chloropropylene [1-Propene, 2-chloro-] 557-98-2 10,0001-Chloropropylene [1-Propene, 1-chloro-] 590-21-6 10,000

TABLE G (Continued)


Crotonaldehyde [2-Butenal] 4170-30-3 20,000Crotonaldehyde, (E)- [2-Butenal, (E)-] 123-73-9 20,000Cyanogen [Ethanedinitrile] 460-19-5 10,000Cyanogen chloride 506-77-4 10,000Cyclohexylamine [Cyclohexanamine] 108-91-8 15,000Cyclopropane 75-19-4 10,000Diborane 19287-45-7 2,500Dichlorosilane [Silane, dichloro-] 4109-96-0 10,000Difluoroethane [Ethane, 1,1-difluoro-] 75-37-6 10,000Dimethyldichlorosilane [Silane, dichlorodimethyl-] 75-78-5 5,0001,1-Dimethylhydrazine [Hydrazine, 1,1-dimethyl-] 57-14-7 15,000Dimethylamine [Methanamine, N-methyl-] 124-40-3 10,0002,2-Dimethylpropane [Propane, 2,2-dimethyl-] 463-82-1 10,000Epichlorohydrin [Oxirane, (chloromethyl)-] 106-89-8 20,000Ethane 74-84-0 10,000Ethyl acetylene [1-Butyne] 107-00-6 10,000Ethylamine [Ethanamine] 75-04-7 10,000Ethyl chloride [Ethane, chloro-] 75-00-3 10,000Ethylene [Ethene] 74-85-1 10,000Ethylenediamine [1,2-Ethanediamine] 107-15-3 20,000Ethyleneimine [Aziridine] 151-56-4 10,000Ethylene oxide [Oxirane] 75-21-8 10,000Ethyl ether [Ethane, 1,1'-oxybis-] 60-29-7 10,000Ethyl mercaptan [Ethanethiol] 75-08-1 10,000Ethyl nitrite [Nitrous acid, ethyl ester] 109-95-5 10,000Fluorine 7782-41-4 1,000Formaldehyde (solution) 50-00-0 15,000Furan 110-00-9 5,000Hydrazine 302-01-2 15,000Hydrochloric acid (conc 30% or greater) 7647-01-0 15,000Hydrocyanic acid 74-90-8 2,500Hydrogen 1333-74-0 10,000Hydrogen chloride (anhydrous) [Hydrochloric acid] 7647-01-0 5,000Hydrogen fluoride/Hydrofluoric acid (conc 50% or greater) [Hydrofluoric acid] 7664-39-3 1,000Hydrogen selenide 7783-07-5 500Hydrogen sulfide 7783-06-4 10,000Iron, pentacarbonyl- [Iron carbonyl (Fe(CO)5), (TB-5-11)-] 13463-40-6 2,500Isobutane [Propane, 2-methyl] 75-28-5 10,000Isobutyronitrile [Propanenitrile, 2-methyl-] 78-82-0 20,000Isopentane [Butane, 2-methyl-] 78-78-4 10,000Isoprene [1,3-Butadiene, 2-methyl-] 78-79-5 10,000Isopropylamine [2-Propanamine] 75-31-0 10,000Isopropyl chloride [Propane, 2-chloro-] 75-29-6 10,000Isopropyl chloroformate [Carbonochloridic acid, 1-methylethyl ester] 108-23-6 15,000Methacrylonitrile [2-Propenenitrile, 2-methyl-] 126-98-7 10,000

TABLE G (Continued)


Methane 74-82-8 10,000Methylamine [Methanamine] 74-89-5 10,0003-Methyl-1-butene 563-45-1 10,0002-Methyl-1-butene 563-46-2 10,000Methyl chloride [Methane, chloro-] 74-87-3 10,000Methyl chloroformate [Carbonochloridic acid, methylester] 79-22-1 5,000Methyl ether [Methane, oxybis-] 115-10-6 10,000Methyl formate [Formic acid, methyl ester] 107-31-3 10,000Methyl hydrazine [Hydrazine, methyl-] 60-34-4 15,000Methyl isocyanate [Methane, isocyanato-] 624-83-9 10,000Methyl mercaptan [Methanethiol] 74-93-1 10,0002-Methylpropene [1-Propene, 2-methyl-] 115-11-7 10,000Methyl thiocyanate [Thiocyanic acid, methyl ester] 556-64-9 20,000Methyltrichlorosilane [Silane, trichloromethyl-] 75-79-6 5,000Nickel carbonyl 13463-39-3 1,000Nitric acid (conc 80% or greater) 7697-37-2 15,000Nitric oxide [Nitrogen oxide (NO)] 10102-43-9 10,000Oleum (Fuming Sulfuric acid) [Sulfuric acid, mixture with sulfur trioxide] 8014-95-7 10,0001,3-Pentadiene 504-60-9 10,000Pentane 109-66-0 10,0001-Pentene 109-67-1 10,0002-Pentene, (E)- 646-04-8 10,0002-Pentene, (Z)- 627-20-3 10,000Peracetic acid [Ethaneperoxoic acid] 79-21-0 10,000Perchloromethylmercaptan [Methanesulfenyl chloride, trichloro-] 594-42-3 10,000Phosgene [Carbonic dichloride] 75-44-5 500Phosphine 7803-51-2 5,000Phosphorus oxychloride [Phosphoryl chloride] 10025-87-3 5,000Phosphorus trichloride [Phosphorous trichloride] 7719-12-2 15,000Piperidine 110-89-4 15,000Propadiene [1,2-Propadiene] 463-49-0 10,000Propane 74-98-6 10,000Propionitrile [Propanenitrile] 107-12-0 10,000Propyl chloroformate [Carbonochloridic acid, propylester] 109-61-5 15,000Propylene [1-Propene] 115-07-1 10,000Propyleneimine [Aziridine, 2-methyl-] 75-55-8 10,000Propylene oxide [Oxirane, methyl-] 75-56-9 10,000Propyne [1-Propyne] 74-99-7 10,000Silane 7803-62-5 10,000Sulfur dioxide (anhydrous) 7446-09-5 5,000Sulfur tetrafluoride [Sulfur fluoride (SF4), (T-4)-] 7783-60-0 2,500Sulfur trioxide 7446-11-9 10,000Tetrafluoroethylene [Ethene, tetrafluoro-] 116-14-3 10,000Tetramethyl lead [Plumbene, tetramethyl-] 75-74-1 10,000Tetramethylsilane [Silane, tetramethyl-] 75-76-3 10,000Tetranitromethane [methane, tetranitro-] 509-14-8 10,000

TABLE G (Continued)


Titanium tetrachloride [Titanium chloride (TiCl4) (T-4)-] 7550-45-0 2,500Toluene 2,4-diisocyanate [Benzene, 2,4-diisocyanato-1-methyl-] 584-84-9 10,000Toluene 2,6-diisocyanate [Benzene, 1,3-diisocyanato-2-methyl-] 91-08-7 10,000Toluene diisocyanate (unspecified isomer) [Benzene, 1,3-diisocyanatomethyl-] 26471-62-5 10,000Trichlorosilane [Silane, trichloro-] 10025-78-2 10,000Trifluorochloroethylene [Ethene, chlorotrifluoro-] 79-38-9 10,000Trimethylamine [Methanamine, N,N-dimethyl-] 75-50-3 10,000Trimethylchlorosilane [Silane, chlorotrimethyl-] 75-77-4 10,000Vinyl acetate monomer [Acetic acid ethenyl ester] 108-05-4 15,000Vinyl acetylene [1-Buten-3-yne] 689-97-4 10,000Vinyl chloride [Ethene, chloro-] 75-01-4 10,000Vinyl ethyl ether [Ethene, ethoxy-] 109-92-2 10,000Vinyl flouride [Ethene, fluoro-] 75-02-5 10,000Vinylidene chloride [Ethene, 1,1-dichloro-] 75-35-4 10,000Vinylidene flouride [Ethene, 1,1-difluoro-] 75-38-7 10,000Vinyl methyl ether [Ethene, methoxy-] 107-25-5 10,000


PERMIT APPLICATION FORM GI-09HREQUIREMENTS: CAM (40 CFR pt. 64)

05/11/98

Compliance Assurance Monitoring(40 CFR pt. 64)

The CAM rule applies to facilities that operate emission control devices subject to federally enforceable regulationspromulgated prior to 1990. These regulations are not limited to EPA regulations, but include any regulation thatpertains to the Part 70 operating permit. This includes New Source Performance Standards (NSPS), NationalEmission Standards for Hazardous Air Pollutants (NESHAP), and Minnesota Rules contained in the StateImplementation Plan.

To determine applicability, source owners need to answer the following questions pertaining to individual emissionsunits:

• Is the unit located at a major source required to obtain a Part 70 permit?

• Is the unit subject to an emission limitation or standard which is specified in a rule or regulation?

• Is a control device used to achieve compliance with that limitation or standard?

• Are the potential uncontrolled emissions of the controlled pollutant from the unit at least 100 percent of themajor source threshold amount? (As of the date of this fact sheet, “major source threshold amount” as it appliesto Minnesota, means 100 tons per year of particulate matter (PM10), sulfur dioxide (SO2), nitrogen oxides(NOX), volatile organic compounds (VOC), carbon monoxide (CO), or lead; 10 tons per year of any hazardousair pollutant (HAP); or 25 tons per year of any combination of HAPs. The levels may be different in current orfuture nonattainment areas. Refer to 40 CFR § 70.2 under the definition of “major source” for further detail.)

CAM applies if the answers to all of these questions is “yes.”

DEADLINES FOR SUBMITTALS

Those emissions units with the potential to emit a regulated air pollutant equal to or greater than the major sourcethreshold amount (after effects of control equipment are considered) shall make the required CAM submittals asfollows:

1. If the initial Part 70 permit application has not been submitted by April 20, 1998, the owner or operator shallsubmit CAM information as part of the initial application.

2. On or after April 20, 1998, the owner or operator shall submit CAM information as part of any application for amajor amendment to a Part 70 permit, but only with respect to those emissions units for which the proposedamendment is applicable.

The owner or operator shall submit any information not submitted under the above deadlines as part of the application forthe reissuance of the Part 70 permit.

For those emissions units where the potential to emit a regulated air pollutant is below the major source threshold amountafter control equipment is taken into account, the information required by the CAM rule shall be submitted with thenext application for reissuance of a Part 70 permit.

It is not anticipated that Minnesota facilities subject to the CAM rule will be required to take any steps to implementCAM until reissuance of their Part 70 permit, unless they apply for a major amendment to their existing Part 70permit.

HOW CAM WORKS

The Permittee must submit the required information to the MPCA. The CAM submittal should include:

• information on indicators (gauges, meters, or other devices used to monitor operating parameters of controlequipment)

• indicator ranges, or the process by which indicators are to be established

• performance criteria

• justification for the proposed monitoring

• control device operating data recorded during a performance test, supplemented by engineering assessments ormanufacturer’s recommendations to justify the proposed indicator range

• a test plan and schedule for obtaining data if performance test data are not available

• an implementation plan, if monitoring requires installation, testing or other activities prior to implementation

The next step is review and approval by the MPCA. If additional information or corrections are required, the MPCAwill notify the Permittee that the CAM submittal must be revised or supplemented. If the CAM submittal isdetermined to be complete and acceptable, the MPCA will establish permit terms for the affected emissions unit.

After approval and incorporation of the CAM requirements into the permit, owners and operators of affected unitsmust implement the monitoring upon issuance of the permit, unless the permit specifies a later date.

EXEMPTIONS

The CAM rule does not apply to:

1. Units subject to federal regulations issued after 1990. In situations where some portions of a facility operatecontrol devices in order to comply with emission standards issued prior to 1990, only those portions of thefacility must comply with the requirements of the CAM rule.

2. Situations where continuous compliance monitoring is already specified in an operating permit. The CAM ruleexempts the Permittee from additional monitoring requirements and directs the Permittee to use the continuouscompliance monitoring data to fulfill the CAM rule monitoring and certification requirements.

3. Stratospheric ozone protection requirements

4. Acid Rain Program requirements

5. Emission limitations or standards that apply solely under an emissions trading program

6. Municipally-owned utility peak-shaving units where

� the unit is exempt from all Acid Rain Program monitoring requirements, and

� the unit operates for the sole purpose of providing electricity during periods of peak electrical demand oremergency situations, and

� the unit will be operated consistent with that purpose throughout the permit term, and

� emissions from the unit are less than 50 tons per year.

For additional information, please refer to the CAM rule at 40 CFR pt. 64.


PERMIT APPLICATION FORM GI-09IREQUIREMENTS: STATE RULES

05/11/98

Minnesota State Air Quality Rules

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

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

1a) After your facility is permitted, will your facility be allowed to emit more than 250 tons per year of any one of thefollowing pollutants: particulate matter, sulfur dioxide, nitrogen oxides, ozone [volatile organic compounds], carbonmonoxide, or non-methane hydrocarbons?

No, my facility is not subject to the Minn. R. 7009.1000-7009.1110.Yes, my facility is subject to the Minn. R. 7009.1000-7009.1110

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

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

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

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

2b) Is your facility type or process equipment found in Table H on pages 6 and 7?

No, none of the Minnesota Rules listed in Table H apply to my facility. Go to question 3.Yes, my facility or process equipment may be subject to the rule associated with it in Table H. Read theassociated rule to see if it applies.

NOTE: the starred performance standards indicate Minnesota Rules that incorporate by reference federal NewSource Performance Standards (NSPS) and/or National Emission Standards for Hazardous Air Pollutants(NESHAP). To comply with these state rules, you must comply with the federal NSPS and/or NESHAP.

2c) After reading through Table H and any rule that may apply to your facility or equipment, list the ones that do applyto your air emission source(s) below. You do not need to list the Standards of Performance for Indirect HeatingFossil-Fuel Burning Equipment again, if it applies (see 2a, above).

Minnesota Rule Part thatApplies

What the Rule Part Applies to (Whole facility or SpecificPiece of Equipment)

Emission UnitID Number

7011.0570 boiler 002

7011.2300 generator 022

(DUPLICATE THIS TABLE AS NEEDED)

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

3a) Does your facility generate electricity?

No. My facility is not subject to Acid Deposition Control Requirements. Go to question 4.Yes. Go to question 3b.

3b) Does your facility contain indirect heating equipment with a rated heat input of more than 5,000 million BTUs perhour?

No. Go to question 3c.Yes. My facility is subject to Acid Deposition Control Requirements.

3c) If your facility is an electric utility, is the total generating capacity of all the electric generating facilities inMinnesota which are owned by your facility’s parent company more than 1,000 megawatts?

No. My facility is not subject to Acid Deposition Control Requirements.Yes. My facility is subject to Acid Deposition Control Requirements.

4) Standards of Performance for Industrial Process Equipment(Minn. R. 7011.0700 - 7011.0735)

4a) Do you have any industrial process equipment on-site that generates particulate matter (i.e. dust, smoke, or gaseousmaterial) in any amount and is not regulated by another Standard of Performance (NSPS, NESHAP, or MN RulesStandard of Performance)?

No, my equipment is not subject to this rule. Go to question 6.Yes. Go to 4b.

4b) Opacity Standard(Note: Opacity is a measure of visible emissions or how much of the view is obscured by stack emissions. Theemissions causing opacity are often smoke or dust.)

For industrial process equipment which was in operation before July 9, 1969, the equipment shall not exhibit greaterthan 20 percent opacity, except that a maximum of 60 percent opacity shall be permissible for four minutes in any 60minute period and a maximum of 40 percent opacity shall be permissible for four additional minutes in any 60minute period.

For industrial process equipment which was not in operation before July 9, 1969, the equipment shall not exhibitgreater than 20 percent opacity.

4c) Does the industrial process equipment have particulate control equipment with a collection efficiency of at least 99percent if it was in operation before July 9, 1969, or 99.7 percent if it was not in operation before July 9, 1969?

No. Go to question 4d.Yes. My equipment is not subject to the remaining requirements of this rule. Go to question 6.

4d) Is the industrial process equipment located outside of the seven county Minneapolis-St. Paul metropolitan regionAND outside of the city of Duluth AND at least 1/4 mile from any residence or public roadway, AND does theindustrial process equipment have particulate control equipment with a collection efficiency of at least 85 percentAND is the operation of the entire facility in compliance with all ambient air quality standards?

No, my equipment is subject to the remaining requirements. Go to the attached Table I.Yes, my equipment is not subject to the remaining requirements of this rule. Go to question 6.

5) Waste Combustors(Minn. Rules 7011.1201-7011.1290)

Note: Depending on the type of waste combustor you operate, you may be instructed to fill out one or more of thefollowing forms:

WC-01 -- Required if you determine that your waste combustor requires a permit.WC-02 -- Required if you install/operate a Class IV waste combustor at a hospital.WC-03 -- Required if you do not met the stack height requirements of Minn. R. 7011.1235.

If after reading through the following section, you determine that you are required to fill out one or more of the WCforms, contact the Air Quality Permit Document Coordinator.

5a) Do you operate a waste combustor?

“Waste Combustor” means any emissions unit or emission facility where mixed municipal solid waste, solid waste,or refuse-derived fuel is combusted, and includes incinerators, energy recovery facilities, or other combustiondevices. A metals recovery incinerator is a waste combustor. A combustion device combusting primarily wood, orat least 70 percent fossil fuel and wood in combination with up to 30 percent papermill wastewater treatment plantsludge is not a waste combustor. A soil treatment facility, paint burn-off oven, wood heater, or residential fireplaceis not a waste combustor.

“Wood” is defined as: wood, wood residue, bark, or any derivative fuel or residue thereof, in any form, includingsawdust, sander dust, wood chips, wood scraps, slabs, millings, shavings, and processed pellets made from wood andother forest residues.

A facility that is co-firing RDF or MSW at rates less than 30 percent by weight is not regulated as a wastecombustor, but is regulated as a boiler.

Yes, I operate a waste combustor. Answer questions 5b through 5e to determine whether you are allowed tocontinue to operate, and what type of permit the waste combustor requires. Allowed waste combustors mustobtain an air emissions permit.No, the facility equipment is not subject to this rule. Go to question 6.

5b) Is the waste combustor solely a crematory, pathological or an animal carcass incinerator?

Yes. It is subject to standards of performance in 7011.1215, subp. 3. The waste combustor is aninsignificant activity that does not need to be reported. Go to question 6.No, the facility equipment is not subject to this rule. Go to question 6.

5c) Is the design capacity of the waste combustor equal to or greater than 3 million Btu/hr?

“Design capacity” means: the hourly throughput of the waste combustor unit based on heat input from solid waste tothe combustion system as stated by the manufacturer or designer, based on accepted design and engineeringpractices. For a non-continuous feed system, design capacity means the total heat input from solid waste per cycle.

If you don’t have a manufacturer’s design capacity in terms of heat input, you may estimate heat input by thefollowing formula:

Hin = (HHV) x (R)

Where:Hin = Heat input rateHHV = heat value of wasteR = waste input rate, in lb/hr, as defined by the manufacturerCommercial/Retail/Institutional Wastes = 7000 Btu/lbGeneral Industrial Wastes = 9000 Btu/lbMedical/Infectious Wastes = 10,000 Btu/lb

Yes, the waste combustor has a design capacity of 3 million Btu/hr or greater. The waste combustor issubject to the standards of performance applicable to waste combustors. There are also additional permitapplication requirements for this unit, as described in Minn. R. 7007.0501, or 7011.1210. Complete formWC-01.No, the heat input rate is below 3 million Btu/hr. Go to question 5d.

5d) Is the waste combustor used as a metal recover incinerator?

“Metals recovery incinerator” means a furnace or incinerator used primarily to recover precious and non-preciousmetals by burning the combustible fraction from waste. An aluminum sweat furnace is not a metals recoveryincinerator.

Yes. The waste combustor is subject to the standards of performance applicable to waste combustors.There are also additional permit application requirements for this unit, as described in Minn. R. 7007.0501,or 7011.1210. Complete form WC-01.No. Go to question 5e.

5e) Is the waste combustor located at a hospital?

Yes. The waste combustor is subject to the standards of performance applicable to Class IV wastecombustors. There are also additional permit application requirements for this unit, as described in Minn.R. 7007.0501, or 7011.1210. Complete form WC-02 if the waste combustor will comply with all of thedesign, operating, and standards of performance in parts 7011.1201 to 7011.1290. Otherwise, an airemissions permit must be issued, and you must complete for WC-01. [Please Note: There are federalStandards of Performance that must also be met for new sources (see Form GI-09D), and the state will beadopting more stringent standards for existing incinerators by December of 1998.]

No, the waste combustor is not located at a hospital. The operation of this waste combustor was bannedafter January 30, 1996. Your compliance plan must contain specific steps to cease operation of this wastecombustor.

6) Return to Form GI-09 REQUIREMENTS, question 11b.

Table H:Minnesota Standards of Performance for Stationary Sources

Facility or Equipment Type Associated Minnesota Rule*Steam Generating Units 7011.0555 through 7011.0570Direct Heating Equipment 7011.0600 through 7011.0610*Portland Cement Plants 7011.0800 through 7011.0830*Asphalt Concrete Plants 7011.0900 through 7011.0925*Asphalt Processing and Roofing Manufacture 7011.0950*Grain Elevators 7011.1000 through 7011.1015Coal Handling Facilities 7011.1100 through 7011.1140*Coal Preparation Plants 7011.1150Incinerators (waste combustors) 7011.1201 through 7011.1207*Sewage Sludge Incinerators 7011.1300 through 7011.1350*Petroleum Refineries 7011.1400 through 7011.1435, and

7011.7280*Liquid Petroleum and VOC Storage Vessels 7011.1500 through 7011.1520*Bulk Gasoline Terminals 7011.1550, 7011.7180*Sulfuric Acid Plants 7011.1600 through 7011.1635*Nitric Acid Plants 7011.1700 through 7011.1730*Lead Smelters 7011.1800 through 7011.1820 and

7011.7240*Copper Smelters 7011.1840 and 7011.9910*Zinc Smelters 7011.1880*Brass and Bronze Plants 7011.1900 through 7011.1920*Iron and Steel Plants 7011.2000 through 7011.2020*Primary Aluminum Reduction Plants 7011.2050*Ferroalloy Production Facilities 7011.2080Inorganic Fibrous Materials 7011.2100 through 7011.2105Stationary Internal Combustion Engine (Generators) 7011.2300*Stationary Gas Turbines 7011.2350*Phosphate Fertilizer Industry 7011.2400*Kraft Pulp Mills 7011.2450*Glass Manufacturing Plants 7011.2500 and 7011.9910*Surface Coating 7011.2550 through 7011.2580*Lime Manufacturing Plants 7011.2600*Lead-acid Battery Manufacturing Plants 7011.2650*Metallic Mineral Processing Plants 7011.2700*Phosphate Rock Plants 7011.2750*Ammonium Sulfate Manufacture 7011.2800*Graphic Arts Industry 7011.2850*Synthetic Organic Chemicals Manufacturing Industry 7011.2900 and 7011.7040 through

7011.7060*Residential Wood Heaters 7011.2950*Rubber Tire Manufacturing Industry 7011.3000*Polymer Manufacturing Industry 7011.3050*Polymeric Coating of Substrates Facilities 7011.3100*Flexible Vinyl and Urethane Coating and Printing 7011.3150*Synthetic Fiber Production Facilities 7011.3200*Petroleum Dry Cleaners 7011.3250*Onshore Natural Gas Processing Plants 7011.3300*Non-Metallic Mineral Processing Plants 7011.3350*Wool Fiberglass Insulation Manufacturing Plants 7011.3400*Magnetic Tape Manufacturing and Coating Facilities 7011.3450 and 7011.7300* Denotes Minnesota Rule(s) which incorporate federal NSPS and/or NESHAP requirements by reference.

Table H (continued)

*Municipal Solid Waste Landfills 7011.3500 through 7011.3510* Emissions from Coke Oven Batteries 7011.7080* Emissions from Perchloroethylene Dry Cleaners 7011.7100* Chromium Emissions from and Decorative Chromium Electroplating andChromium Anodizing Tanks

7011.7120

*Ethylene Oxide Emissions from Sterilization Facilities 7011.7140* Industrial Process Cooling Towers 7011.7160*Halogenated Solvent Cleaning 7011.7200*Epoxy Resins Production and Non-Nylon Polyamides Production 7011.7220*Marine Tank Vessel Loading Operations 7011.7260*Aerospace Manufacturing and Rework Facilities 7011.7320*Arsenic Trioxide and Metallic Arsenic Production Facilities 7011.9910*Asbestos 7011.9920*Benzene Emissions 7011.9930*Beryllium 7011.9940*Mercury 7011.9950*Radon 7011.9960*Radionuclides 7011.9970*Vinyl Chloride 7011.9980*Volatile Hazardous Air Pollutants 7011.9990* Denotes Minnesota Rule(s) which incorporate federal NSPS and/or NESHAP requirements by reference.

TABLE I:INSTRUCTIONS FOR DETERMINING YOUR PARTICULATE LIMIT

Minnesota has a State rule for the concentration of particulate matter that may be in your exhaust stream. The unit ofthe standard is grains per dry standard cubic foot. You need to convert your actual exhaust flow to dry standardcubic feet per minute to find the emission limit from the rule.

Sources subject to this rule are required to meet the emission limits established at all times. These limits will varydepending on operating conditions. To determine compliance at any point in time (i.e. for a stack test), follow thesteps below:

1. Determine the amount of dry material (subtract any water or moisture content) in pounds per hour that isprocessed by your equipment.

2. Use Table I.1 to determine your allowed emission rate based on process weight rate. If your process weight ratefalls between two values on the table, interpolate or extrapolate using the equation:

E 3.59 P2000

0.62= × �

��

�� for P ≤ 60,000 lbs/hour; and:

E 1 P2000

0.16= ×�

��

��7 31. for P > 60,000 lbs/hour

where:E = emission rate in lbs/hour; andP = process weight rate in lbs/hour

3. If your process equipment is vented to the atmosphere, determine the airflow through your stack. Correct to 68 Fand 14.7 psi, and correct to remove any moisture in the gas stream to obtain the air flow in dry standard cubic feetper minute (dscfm).

4. Use Table I.2 to determine your allowed concentration in grains per dry standard cubic foot (gr/dscf). Interpolateusing the equation:

c 1.7627 V 0.3241= × −

where:c = concentration in gr/dscf,V = gas volume in dscfm

5. Determine which of the two emission rates calculated above is less stringent. To convert a concentration(calculated in step 4) to an emission rate (calculated in step 2), use the following equation:

E = c V 607000

× ×��

��

where:E = emission rate in lbs/hour;c = concentration in gr/dscf,V = gas volume in dscfm

Table I.1 Table I.2Process Rate (lbs/hour) Emission Rate

(lbs/hour)Source Gas Volume

(dscfm)Concentration

(gr/dscf)

50 0.08 7,000 or less 0.100100 0.55 8,000 0.096500 1.53 9,000 0.092

1,000 2.25 10,000 0.0895,000 6.34

10,000 9.73 20,000 0.07120,000 14.99 30,000 0.06260,000 29.60 40,000 0.05780,000 31.19 50,000 0.053

120,000 33.28 60,000 0.050160,000 34.85200,000 36.11 80,000 0.045400,000 40.35 100,000 0.042

1,000,000 46.72 120,000 0.040140,000 0.038160,000 0.036180,000 0.035200,000 0.034

300,000 0.030400,000 0.027500,000 0.025600,000 0.024

800,000 0.0211,000,000 or more 0.020

Regardless of the allowable emission rates calculated from Tables I.1 and I.2, no process equipment is allowed toemit more than 0.30 grains per standard cubic foot of exhaust gas.


Appendix 6-AFact Sheet: Control Equipment Standards

Minnesota Pollution Control Agency

AQ Doc. # 4.07 March 1998

Facts about Control Equipment Performance Standards

The Minnesota Pollution Control Agencyrules (Minn. R. pts. 7011.0060 to 7011.0080)allow facilities with certain types of pollutioncontrol equipment to take emission reductionsinto consideration and reduce the permittingrequirements of the facility.

What are the advantages ofusing this rule?You may use this rule to calculate yourfacility’s potential-to-emit (PTE) in order toavoid New Source Review (NSR); get a statepermit instead of a part 70 permit; and/orallow your facility to get an option Dregistration permit instead of a more complexstate or part 70 permit.

You may also use this rule to calculate yourfacility’s emission rate change resulting froma proposed modification. This may allow youto apply for a minor or moderate amendmentinstead of a major amendment. Or you maydetermine that the change is an insignificantmodification and may require no permitamendment.

This rule is used primarily for facilitymodifications/permit amendments and foroption D registration permits. The result ofthese reduced permitting requirements willsave eligible facilities time and money.

Who is subject to the rule?If you choose to use this rule to limit yourfacility’s potential-to-emit, you are subject tothe requirements of the rule. Facilities that do

not choose to use this rule are not subject tothe requirements of the rule.

Facilities can only use this rule to determinethe type of permit needed. This rule cannot beused to avoid permitting altogether. Forexample, once a facility has determined thatan air emissions permit is needed, then therule may be used to apply for an option Dregistration permit instead of a state or part 70permit.

What types of control equipmentare in the rule?The table on page two defines the types ofpollution control equipment that are assigneda control efficiency under this rule.

Table A on page 2 lists the pollutants forwhich a control efficiency has been assignedand the control efficiency (percent emissionreduction) that the facility is allowed to claimwhen applying for a permit or permitamendment.

The assigned control efficiency does not applyto hazardous air pollutants (HAPs). Thefacility is allowed to assign a controlefficiency for hazardous air pollutants onlyafter an efficiency has been demonstrated byconducting a performance test approved bythe commissioner under Minn. R. pts.7017.2001 to 7017.2060.

TABLE ACONTROL EQUIPMENT EFFICIENCY

Control Equipment Description Pollutant Control EfficiencyTotal

EnclosureHood

PM CONTROL CATEGORY - CYCLONESmeans a device where airflow is forced to spin in a vortex through a tube.Centrifugal Collector (cyclone) - high efficiency - a cyclonicdevice with parameters stated in drawing 1 and table B

PM, PM10 80% 64%

Centrifugal Collector (cyclone) - medium efficiency - a cy-clonic device with parameters stated in drawing 1 and table B

PM, PM10 50% 40%

Centrifugal Collector (cyclone) - low efficiency - a cyclonicdevice with parameters stated in drawing 1 and table B

PM, PM10 10% 8%

Multiple Cyclone without Fly Ash Re-injection - a cyclonicdevice with more than one tube where fly ash isn’t reinjected

PM, PM10 80% NA

Multiple Cyclone with Fly Ash Re-injection - a cyclonicdevice with more than one tube where fly ash is re-injected

PM, PM10 50% NA

Wet Cyclone Separator or Cyclonic Scrubbers - a cyclonicdevice that sprays water into a cyclone.

PM, PM10 50% 40%

PM CONTROL CATEGORY - ELECTROSTATIC PRECIPITATORSControl devices in which incoming particulate matter receives an electrical charge and is thencollected on a surface with the opposite electrical charge.- assumed efficiency for boiler fly ash control PM, PM10 40% NA- assumed efficiency for other applications PM, PM10 70% 56%PM CONTROL CATEGORY - OTHER CONTROLSFabric Filter - the incoming gas stream to the filter passesthrough a porous fabric filter forming a dust cake

PM, PM10 99% 79%

Spray Tower - the incoming gas stream to the tower passesthrough a chamber in which it contacts a liquid spray

PM, PM10 20% 16%

Venturi Scrubber - the incoming gas stream to the scrubberpasses though a venturi into which low pressure liquid isintroduced

PM, PM10 90% 72%

Impingement Plate Scrubber - the incoming gas stream to thescrubber passes a liquid spray and is then directed at highvelocity into a plate

PM, PM10 25% 20%

HEPA and other Wall Filters - removable panels for cleaningand replacement, or liquid curtains for particulate removalthat provide little resistance to air flow

PM, PM10 92% 74%

VOC CONTROL CATEGORYAfterburners (thermal or catalytic oxidation) - devices usedto reduce VOCs to the products of combustion throughthermal (high temperature) oxidation or catalytic (use of acatalyst) oxidation in a combustion chamber

VOC 95% 57%

Flaring or Direct Combustor - a device in which air,combustible organic waste gases, and supplementary fuel(if needed) react in the flame zone (e.g., at the flare tip) todestroy the VOCs

VOC 98% 59%

Table A also lists two differentcontrol efficiencies: one for apollution control system that usesa total enclosure to capture theemissions from the source andanother that uses a hood as thecapture device.

The control efficiency for asystem that uses a hood is 80percent of a system that uses atotal enclosure because hoodsystems are assigned a captureefficiency of 80 percent instead of100 percent for total enclosures.

The facility must evaluate andcertify the design and operatingcharacteristics of hood systems inorder to claim the assignedcontrol efficiency. The systemmust comply with the design andoperating practices recommendedin “Industrial Ventilation - AManual of RecommendedPractice, American Conference ofGovernmental IndustrialHygienists.”

Cyclone Design

s

w

H

D

De

s

w

H

D

De

If I have control equipment that is notlisted in Table A, may I consider itscontrol efficiency when calculating PTE?In general no. However, if you have an Option D permitand have conducted a performance test, the controlequipment may be eligible.

TABLE B

Ratio Dimensions High Efficiency Medium Efficiency Low Efficiency

Height of inlet, H/D � 0.44 > 0.44 and < 0.8 � 0.8

Width of inlet, W/D � 0.2 > 0.2 and < 0.375 � 0.375

Diameter of gas exit, De/D � 0.4 > 0.4 and < 0.75 � 0.75

Length of vortex finder, S/D � 0.5 >0.5 and < 0.875 � 0.875

If one or more of the “ratio dimensions,” as listed in Table B, are in a different efficiency category(high, medium, low), then the lowest efficiency category shall be applied.

Will I have any monitoring and/orrecordkeeping responsibilities ifI choose to use this rule?Yes. A condition of being able to claim theassigned control efficiency for the pollutioncontrol equipment is that the equipment mustbe operated and maintained in accordancewith the rule and the manufacturer’sspecifications for the control equipment. Youmust have the pollution control equipmentmanufacturer’s specifications to takeadvantage of this rule. You must also monitorcontrol equipment operating parameters andkeep records as specified in Table C.

Who do I contact if I have anyquestion about this rule?Questions regarding this rule may be directedto the Permit Technical Advisor at (651) 282-5844 or, toll-free at (800) 646-6247.

TABLE CControl Equipment Monitoring Requirements

Pollution ControlEquipment Type

Monitoring Parameters Recordkeeping Requirement

Centrifugal Collector(Cyclone)

Pressure drop Record pressure drop every 24hours if in operation

Electrostatic Precipitator Primary and secondary voltage;primary and secondary current;sparking rate; and no. fields on line

Record each parameter every 24hours if in operation

Fabric Filter (BagHouse)

Pressure drop Record pressure drop every 24hours if in operation

Spray Tower Liquid flow rate and pressure drop Record each parameter every 24hours if in operation

Venturi or ImpingementPlate Scrubber

Pressure drop and liquid flow rate Record each parameter every 24hours if in operation

HEPA & Other WallFilters

Condition of the filters including,but not limited to, alignment;saturation; and tears and holes

Record of filter(s) condition every24 hours if in operation

Wet Cyclone Separator Pressure drop; and water pressure Record each parameter every 24hours if in operation

Thermal Incinerator Combustion temperature or inlet andoutlet temperatures

Continuous hard-copy readout oftemperatures or manual readingsevery 15 minutes

Catalytic Incinerator Inlet and outlet temperatures; andcatalyst bed reactivity as permanufacturer’s specifications

Continuous hard-copy readout oftemperatures or manual readingsevery 15 minutes; and results ofcatalyst bed reactivity

Flaring Temperature indicating presence of aflame

Continuous hard-copy readout oftemperatures or manual readingsevery 15 minutes

MPCA Air Quality Permits GuidePart 1: Defining Your Facility -- Revision 1, September 1998 Acronyms - 1

AcronymsAPO Administrative Penalty OrderAQ Air QualityBACT Best Available Control TechnologyCAA Clean Air ActCAAA Clean Air Act AmendmentsCAS Chemical Abstracts ServicesCEM Continuous Emission MonitorCFR Code of Federal RegulationsEAW Environmental Assessment WorksheetEIS Environmental Impact StatementEPRO Environmental Review and Planning OfficeEPA Environmental Protection AgencyEQB Environmental Quality BoardHAPs Hazardous Air PollutantsLAER Lowest Achievable Emission RateLOW Letter of WarningMAAQS Minnesota Ambient Air Quality StandardsMACT Maximum Achievable Control TechnologyMnTAP Minnesota Technical Assistance ProgramMPCA Minnesota Pollution Control AgencyMSDS Material Safety Data SheetNAAQS National Ambient Air Quality StandardsNESHAPs National Emission Standards for Hazardous Air PollutantsNOV Notice of ViolationNSPS New Source Performance StandardNSR New Source ReviewPOTW Publicly Owned Treatment WorksPSD Prevention of Significant DeteriorationPTE Potential to EmitRACT Reasonable Available Control TechnologySIC Standard Industrial ClassificationSIP State Implementation Plan

MPCA Air Quality Permits GuidePart 1: Defining Your Facility -- Revision 1, September 1998 Glossary - 1

Glossary

acfm - actual cubic feet per minute. A measurement of the rate of exhaust (volume per unit oftime) from an emission unit or emission facility.

actual emissions - amount of pollutants that are emitted from a stationary source, emission unit,or emission facility over a given period of time.

affected facility - facility or emission unit subject to a New Source Performance Standard(NSPS). The affected facilities for each NSPS are outlined in that NSPS.

affected source - emission source that is subject to Title IV (Acid Rain). (Minn. R. 7007.0100,subp. 4)

affected state - any state located adjacent to Minnesota and whose air can be affected byMinnesota's activities, or any state that is within 50 miles of a permitted source (Minn. R.7007.0100, subp. 5)

affected unit - an emission unit that is subject to Title IV (Acid Rain) (Minn. R. 7007.0100,subp. 6)

air toxics - any pollutant, other than the six criteria pollutants, that scientists believe have thepotential to cause adverse environmental or health effects.

administrative penalty order - an enforcement action used by the MPCA that requiresviolations to be corrected within 30 days; penalties can be assessed up to $10,000.

administrative permit amendment - amendment to correct typographical errors; changecompany name or ownership or mailing address and other simple changes to a permit that do notchange emissions. An administrative permit amendment does not require formal application, andcan be initiated by either the permittee or the MPCA.

air emission permit - legal document that describes a facility and also how the facility ismeeting federal and state air quality regulations. A permit also authorizes construction andoperation of a facility.

alternative operating scenarios - terms and conditions in an air emission permit that allowplanned changes to a facility's operating conditions. These must be identified by the permitteewhen applying for a permit (Minn. R. 7007.0800, subp. 11)

ambient air quality standards -

Minnesota (MAAQS) - air quality standards established by the state of Minnesota that apply to outside air in Minnesota.

National (NAAQS) - air quality standards established by EPA that apply to outside air throughout the country.

applicable requirements - all air quality rules and regulations that apply to emission units in afacility (Minn. R. 7007.0100 subp. 7).

application shield - with some exceptions, allows an existing facility that is operating on theeffective date of the permit rule and has submitted a complete and timely application to continueoperating before the facility's air emission permit is issued (Minn. R. 7007.0350, subp. 3).


attainment area - geographic area considered to have air quality as good as or better than thenational ambient air quality standards as defined in the Clean Air Act. An area can be anattainment area for one pollutant and a nonattainment area for others (see nonattainment area).

begin actual construction - start of on-site physical construction or other activities inpreparation for a planned modification to a facility. Examples include, but are not limited to,installation of building supports and foundations, laying of underground pipework, andconstruction of permanent storage structures (Minn. R. 7005.0100, subp. 3a).

Best Available Control Technology (BACT) - emission limitation based on the maximumdegree of emission reduction that can be achieved through application of production processesand available methods, systems and techniques while also considering energy, environmental andeconomic impacts, and other costs.

bottleneck - physical or operational limitation that is part of the design of an emission facility oremission unit. Bottlenecks prevent operation of equipment at 100% of capacity, and can beconsidered in potential to emit (PTE) calculations when determining if a permit is needed.

Clean Air Act - federal law that regulates air pollution in the United States.

Clean Air Act Amendments - revisions made in 1990 to the Federal Clean Air Act.

carbon monoxide - colorless, odorless gas that is toxic because of its tendency to reduce theoxygen-carrying capacity of the blood.

Code of Federal Regulations - regulations published by the Executive departments and agenciesof the federal government. The Code of Federal Regulations (CFR) is revised annually as a set ofpaperback books, and is available in libraries. Title 40 of the CFR contains all federal rules andregulations relating to Protection of the Environment.

completeness review

administrative - MPCA review confirming that a permit application is submitted on standard forms and is properly organized.

technical - MPCA review confirming that the technical details of a permit application arecomplete and accurate.

compliance agreement - a negotiated settlement between a facility and the MPCA that includesa schedule of corrective action (see stipulation agreement).

compliance assurance monitoring (CAM) - the methods used to determine continuouscompliance with standards and limitations that apply to a facility.

compliance certification - portion of a permit application that outlines a facility’s compliancestatus for all air quality rules and regulations that apply. A responsible official must certify thatthe compliance certification is accurate and complete (see responsible official). Compliancecertifications are also required on an annual basis after the permit is issued.

compliance plan - plan in an air emission permit that shows how a facility will be incompliance with the air quality rules and regulations that apply to the facility. A compliance planincludes specific monitoring, record keeping, reporting, and operation and maintenanceprocedures that must be followed during the life of a permit.


compliance schedule - negotiated agreement between a facility and a government agency thatspecifies dates and procedures by which a facility will reduce emissions, and thereby, complywith a regulation.

construction - any fabrication, erection, or installation of an emission facility, emission unit orstationary source (Minn. R. 7005.0100, subp. 5; also see begin actual construction).

construction permit - permit to construct (not operate) a source (see installation and operationpermit).

continuous compliance - compliance status of a facility when monitoring data show the facilityto be operating within emission limits and standards throughout a specified reporting period.

corrective action - activities undertaken to correct air quality violation(s).

criteria pollutants - six pollutants (ozone, carbon monoxide, total suspended particulates, sulfurdioxide, lead, and nitrogen oxide) determined by the US EPA to be hazardous to human health.The term "criteria pollutants" comes from the requirement that EPA must describe thecharacteristics and potential health and welfare effects of these pollutants. It is on the basis ofthese criteria that air quality standards are established.

dscfm - dry standard cubic feet per minute. A measurement of the volume of air per unit of timeexhausted from an emission unit or emission facility (see acfm), corrected to account for thetemperature and moisture content being different from "standard conditions."

deviation - departure from permit limits or conditions that may or may not endanger humanhealth or the environment. Facilities are required to report deviations in their air permits withinschedules contained in Minn. R. 7007.0800, subp. 6.

dispersion modeling - analysis of a facility's air emission data using computer programs toestimate the affects of emissions on the surrounding air.

emission - pollution discharged into the atmosphere from smokestacks, other vents, and surfaceareas of commercial or industrial facilities.

emission facility - any group of activities and/or equipment that can cause pollutants to bereleased into the air. Emission facilities are made up of emission units and are contained withinstationary sources (Minn. R. 7005.0100, subp. 10).

emission factor - number that describes the relationship between the amount of raw materialprocessed in an emission unit and the amount of pollution produced from the emission unit. Forexample, an emission factor for a gas-fired boiler would be pounds of NOx produced per millioncubic feet of gas burned.

emission limit - restriction on the amount of a particular pollutant that can be released from anemission unit or emission facility over a given period of time. Emission limits are commonlyexpressed as a concentration (grains per dry standard cubic foot) or rate (pounds per hour).

emission point - where air pollutants are emitted to the outside air from a facility (e.g., a stack orvent). One or more emission units may exhaust at an emission point.

emission source - (see emission unit).


emission thresholds - levels of emission rates (pounds/hour or tons/year) above which certainrules or permit requirements apply.

emission trading - EPA policy that allows a facility to increase and decrease emissions of thesame pollutant among several emission units provided that total facility emissions do notincrease. Emission trades cannot result in a Title I modification or violate any applicablerequirement (see operational flexibility).

emission unit - an identifiable piece of equipment or process that emits air pollution. Examplesinclude a boiler, a coal storage pile, a parts washer or any activity or equipment that can causepollutants to be released.

enforcement waiver - in some cases, protection from potential enforcement actions for notholding a permit in the past for facilities that should have had one.

Environment Assessment Worksheet (EAW) - tool of environmental review. It may bemandatory, meaning the project falls into a category specified in Minnesota rules, or it may beordered when facts indicate the project "may have the potential for significant environmentaleffects." An EAW is required by Minnesota rules when the construction or modification of astationary source results in an increase of 100 tons per year or more of a single air pollutant, afterpollution control equipment is considered, or under any of the other conditions listed underMinn. R. 4410.4300. The EAW process typically takes six months to complete.

Environment Impact Statement (EIS) - the more intensive part of environmental review. AnEIS is not always required, but is mandatory under the conditions listed in Minn. R. 4410.4400.The EIS is required when the project is such that it is inevitable that it will have some impact onthe environment. The EIS process typically takes 9-12 months to complete.

environmental review - process that provides information to units of government on theenvironmental impacts of a project before approvals or permits are issued. It creates theopportunity to anticipate and correct potential adverse affects on the environment due to a project(see Environmental Assessment Worksheet and Environmental Impact Statement).

fugitive emissions - emissions that are not and cannot be contained or collected and emittedthrough a stack or vent. Examples are unpaved roads and outdoor storage piles. Thedetermination of whether an emission is fugitive is often made on a case-by-case basis. (Minn. R.7005.0100, subp. 11c)

general permit - permit for a class or category of facilities.

gr/dscf - grains per dry standard cubic foot. A unit of measurement of the concentration of apollutant in flue or exhaust gas. There are 7000 grains in a pound.

Hazardous Air Pollutants (HAPs) - group of pollutants regulated by the US EPA, other thanthe six criteria pollutants, that scientists believe have the potential to cause adverseenvironmental or health effects.

insignificant activities - activities that do not require permitting. Some insignificant activitiesare required to be listed in a permit application for facilities otherwise required to obtain a permit(Minn. R. 7007.1300).


insignificant modification - constructing or beginning an activity or emission unit that is on theinsignificant activities list, or a modification that is not on the insignificant list but results in anincrease less than the thresholds listed in the rules (Minn. R. 7007.1250).

installation and operation permit - permit issued by the state that authorizes the installation ofnew equipment or the modification of existing equipment. This type of permit is issued to afacility that lacks a valid total facility permit, but submitted a timely application under the currentpermit program.

intermittent compliance - compliance status of a facility when monitoring data shows thefacility to be operating within emission limits and standards for part of a reporting period. Incontrast, if a facility is in compliance for an entire reporting period, the facility is in continuouscompliance ( continuous compliance).

lead - heavy metal that is hazardous to human health when breathed or swallowed. Its use ingasoline, paints, and plumbing compounds has been sharply restricted or eliminated by federallaws and regulations (see criteria pollutants).

Letter of Warning (LOW) - enforcement tool used by the MPCA for alleged minor violations;generally requires corrective action but no penalties.

listed control equipment - control equipment that is listed in the Minnesota performancestandard for control equipment (Minn. R. 7011.0070).

Lowest Achievable Emission Rate (LAER) - under the Clean Air Act this is the rate ofemissions that reflects: (a) the most stringent emission limitation contained in a StateImplementation Plan for a facility, unless the owner or operator of a facility can demonstrate thatthe limitation is not achievable; or (b) the most stringent emissions limitation achieved inpractice, whichever is more stringent.

major permit amendment - amendment to an air emission permit that cannot be made under theminor or moderate amendment provisions of the rules. (Minn. R. 7007.1500)

Material Safety Data Sheet (MSDS) - document that outlines information about a chemicalsubstance, including ingredients, health and environmental hazards, flammability, safetyprecautions, etc. MSDSs for all chemical substances are available from the supplier of thematerial.

Maximum Achievable Control Technology (MACT) - emissions limitations based on the bestdemonstrated control technology or practices to be applied to major sources emitting one or moreof the federally listed hazardous pollutants.

minor permit amendment - amendment to an air emission permit that allows a modificationthat results in an emissions increase below the levels described in Minn. R. 7007.1450, subp. 2,with the exceptions that are found in Minn. R. 7007.1450.

moderate permit amendment - amendment to an air emission permit that allows a modificationthat results in an emissions increase greater than the levels described in Minn. R. 7007.1450,subp. 2, but that does not require a major permit amendment (Minn. R. 7007.1450).


modification - any physical or operational change at an emission unit or emission facility orstationary source (not allowed by any existing permit) that can cause the amount of pollutantsreleased to increase, either at the specific unit being changed, or elsewhere in the facility. Alsoany Title I modification. Routine maintenance, repair, and replacement are not consideredmodifications (Minn. R. 7007.0100, subp. 15).

National Emission Standards for Hazardous Air Pollutants (NESHAPs) - emissionsstandards set by EPA for air pollutants not covered by NAAQS that may cause an increase indeaths or in serious irreversible or incapacitating illness.

New Source Performance Standards (NSPS) - uniform national EPA air emission and watereffluent standards that limit the amount of pollution allowed from new sources or from existingsources that have been modified.

New Source Review (NSR) - federal program that contains the Nonattainment Area andPrevention of Significant Deterioration programs and that applies to certain facilities with thepotential to emit air pollution of 100 or 250 tons per year.

nitrogen oxides (NOX) - Oxides of nitrogen (except nitrous oxide) that are regulated becausethey can cause lung and eye irritation, can contribute to the formation of acid rain, and react inthe atmosphere to form ozone and smog (see criteria pollutants).

nonattainment area - geographic area that does not meet one or more of the NAAQS for thecriteria pollutants designated in the Clean Air Act.

Notice of Violation (NOV) - enforcement tool used by the MPCA as a formal notice issued foralleged violations; requires corrective action but no penalties.

opacity - amount of light obscured by particulate pollution in the air (e.g., clear window glasshas zero opacity, a brick wall has 100 percent opacity). Opacity is used as an indicator of changesin performance of particulate matter pollution control systems.

operating permit - permit to operate a source.

operational flexibility - provisions in the Minnesota permit rule that allow a facility to makecertain changes without obtaining a permit amendment. In order to qualify, the facility wouldhave had to request these changes in their total facility permit application. (See alternativeoperating scenarios and emission trading.)

ozone - at ground level, ozone is a noxious pollutant and is the major component of smog. Thesource of ozone is the chemical reaction of VOCs and NOX. Health effects of ozone arebreathing problems, reduced lung function, asthma, eye irritation, stuffy nose, and reducedresistance to colds and other infections. Environmental effects of ozone can damage plants andtrees. Smog also causes reduced visibility (see criteria pollutants).

Part 70 - U.S. EPA's interpretation of Title V of the 1990 Clean air Act Amendments, outlinedin the Code of Federal Regulations, 40 CFR 70.

Part 70 permit - air emission permit issued under Minn R. 7007.0200, and 40 CFR 70.

particulate matter - fine liquid or solid particles such as dust, smoke, mist, fumes or smogfound in air or emissions. (see PM10).


performance test - the quantification of emissions or the determination of the physical,chemical, or aesthetic properties of those emissions from an emission unit (Minn. R. 7017.2005,subp. 4).

permit amendment - document issued by the MPCA to change conditions in a total facilitypermit. A permit amendment may reflect a physical change or a change in the permitrequirements.

permit rule method - calculation technique used to quantify changes in emissions due to aphysical change. This method is used only when the change is not a Title I modification. Minn.R. 7007.1200 describes the permit rule method.

permit shield - condition in a permit stating that if the terms of the permit are complied with, thefacility will be considered to be in compliance with the applicable rule or regulation. The permitshield only applies if and where the permit specifically states that it applies (Minn. R.7007.1800).

PM10 - standard for measuring the amount of solid or liquid matter suspended in the atmosphere.Refers to the amount of particulate matter smaller than 10 micrometers in diameter. The smallerPM10 particles penetrate to the deeper portions of the lung, affecting sensitive population groupssuch as children and people with respiratory diseases. (see criteria pollutants)

portable facility - emission facility capable of being easily moved, e.g., an asphalt plant.

portable source - emission source that is capable of being easily moved; e.g., a diesel generatoror auxiliary power unit.

potential emissions - (see potential to emit)

potential to emit (PTE) - maximum amount of a pollutant that a source is capable of emitting,assuming the source runs at full capacity 24 hours per day and 365 days per year. (Minn. R.7005.0100, subp. 35a).

Prevention of Significant Deterioration (PSD) - US EPA program that requires air emissionpermits to restrict emissions for new or modified sources in places where air quality meetsprimary and secondary ambient air quality standards. PSD is the part of NSR that applies inattainment areas.

responsible official - individual at a facility who is responsible for the accuracy andcompleteness of a permit application. A responsible official is also required to certify thefacility’s compliance status in the permit application and on an annual basis after the permit isissued (Minn. R. 7007.0100, subp. 21; see compliance certification).

rolling average - sometimes used as a calculation method for showing compliance with a permitlimit. For example, to calculate the "12 month rolling average" for operating hours, each monthyou would total the operating hours for the 12 months immediately prior to the current month,and divide by 12.

rolling sum - sometimes used as a calculation method for showing compliance with a permitlimit. For example, to calculate the "12 month rolling sum" for operating hours, each month youwould add together the operating hours for the 12 months immediately prior to the currentmonth. (This is very similar to the rolling average, but usually a little easier to use.)


SIC code - Standard Industrial Classification code. The SIC code is a numerical indicator of theprimary type of activity at a business. For example, 5153 is a grain elevator; 2951 is an asphaltplant; etc. The first two digits indicate the broad category, the second two digits are moreindustry-specific.

significant level - thresholds for specific regulated pollutants used to determine if a modificationis major as defined in New Source Review rules. Modifications that are major must undergofurther review.

state permit - permit issued under Minn. R. 7007.0250. This is a permit for a source that is not amajor source, but still needs a permit under Minnesota Rules (Minn. R. 7007.0100, subp. 24).

stationary source - place or object from which pollutants are released and which does not movearound. Stationary sources include power plants, gas stations, incinerators, etc.

stipulation agreement - a negotiated settlement between a facility and the MPCA that includes aschedule of corrective action and a penalty for past noncompliance (see compliance agreement).

sulfur dioxide (SO2) - heavy, pungent, colorless, gaseous air pollutant formed primarily byindustrial fossil fuel combustion processes (see criteria pollutants).

synthetic minor limit - federally enforceable operating or emissions limitations accepted by apermit applicant that limits a facility’s PTE and makes the facility a minor source under Part 70or New Source Review regulations.

synthetic minor permit - air emission permit that contains one or more synthetic minor limits.

Title I - refers to Title I of the federal Clean Air Act, which protects ambient air quality. Title Iprograms include Prevention of Significant Deterioration and Nonattainment Area New SourceReview; New Source Performance Standards; and National Emission Standards for HazardousAir Pollutants.

Title I condition - permit condition that is based on a requirement of Title I of the Clean Air Act(NSR, NSPS, NESHAPs). This includes conditions required under PSD and Nonattainment Areaprograms, those that enable a source to avoid becoming subject to PSD or Nonattainment Areaprograms, and those required for achieving or maintaining NAAQS. Permit requirements setunder Title I are permanent requirements (Minn. R. 7007.0100, subp. 26).

Title I modification- any change that is considered a modification under Title I of the Clean AirAct (PSD and Nonattainment Area, NSPS, HAPs). (Minn. R. 7007.0100, subp. 27)

Title III - Refers to Title III of the Clean Air Act Amendments of 1990 targeting hazardous airpollutants; Title III defines the Hazardous Air Pollutants and describes how the standards will bedeveloped.

Title V - section of the Clean Air Act that covers the operating permit program.

total facility permit - air emission permit issued for the entire source.

volatile organic compounds (VOC) - any organic compound that participates in smog-formingreactions except for those designated by the EPA Administrator as having negligiblephotochemical reactivity (see criteria pollutants).