AIR EMISSION PERMIT NO. 05301047-006 Total Facility Operating Permit - Reissuance · 2015-12-15 · a§i!> AIR EMISSION PERMIT NO. 05301047-006 Total Facility Operating Permit - Reissuance

a§i!>

AIR EMISSION PERMIT NO. 05301047-006 Total Facility Operating Permit - Reissuance

IS ISSUED TO

EDCO Products, Inc.

EDCO PRODUCTS, INC. 8700 Excelsior Boulevard

Hopkins, Hennepin County, Minnesota 55343

The emission units, control equipment and emission stacks at the stationary source authorized in this permit reissuance are as described in the Permit Applications Table.

This permit reissuance supersedes Air Emission Permit No. 05301047-005 and authorizes the Permittee to operate the stationary source at the address listed above unless otherwise noted in Table A. The Permittee must comply with all the conditions of the permit. Any changes or modifications to the stationary source must be performed in compliance with Minn. R. 7007.1150 to 7007.1500. Terms used in the permit are as defined in the state air pollution control rules unless the term is explicitly defined in the permit.

Unless otherwise indicated, all the Minnesota rules cited as the origin of the permit terms are incorporated into the SIP under 40 CFR § 52.1220 and as such as are enforceable by U.S. Environmental Protection Agency (EPA) Administrator or citizens under the Clean Air Act.

Permit Type: Federal Permit; Part 70/Limits to Avoid NSR

Operating Permit Issue Date: August 12, 2015

Expiration Date: August 12, 2020 - All Title I Conditions do not expire.

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

for John Line Stine Commissioner Minnesota Pollution Control Agency

TDD (for hearing and speech impaired only): (651) 282-5332 Printed on recycled paper containing at least 10% fibers from paper recycled by consumers

Permit Applications Table Permit Type Application Date Permit Action Total Facility Operating Permit -Reissuance 3/25/13 006

TABLE OF CONTENTS

Notice to the Permittee

Permit Shield

Facility Description

Table A: Limits and Other Requirements

Table B: Submittals

Appendices

Appendix A: Operator's Summary (not used)

Appendix B: New Source Performance Standards Calculations: 40 CFR pt. 60, subp. TT

Appendix C: 40 CFR pt. 63 subp. MMMM Compliance Equations •

Appendix D: Insignificant Activities and General Applicable Requirements

Appendix E: Maximum Contents of Materials and Process Parameters

NOTICE TO THE PERMITTEE:

Your stationary source may be subject to the requirements of the Minnesota Pollution Control Agency's (MPCA) solid waste, hazardous waste, and water quality programs. If you wish to obtain information on these programs, including information on obtaining any required permits, please contact the MPCA general information number at:

Metro Area 651-296-6300

Outside Metro Area 1-800-657-3864

TTY 651-282-5332

The rules governing these programs are contained in Minn. R. chs. 7000-7105. Written questions may be sent to: Minnesota Pollution Control Agency, 520 Lafayette Road North, St. Paul, Minnesota 55155-4194.

Questions about this air emission permit or about air quality requirements can also be directed to the telephone numbers and address listed above.

PERMIT SHIELD:

Subject to the limitations in Minn. R. 7007.1800, compliance with the conditions of this permit shall be deemed compliance with the specific provision of the applicable requirement identified in the permit as the basis of each condition. Subject to the limitations of Minn. R. 7007.1800 and 7017.0100, subp. 2, notwithstanding the conditions of this permit specifying compliance practices for applicable requirements, any person (including the Permittee) may also use other credible evidence to establish compliance or noncompliance with applicable requirements.

FACILITY DESCRIPTION:

EDCO Products, Inc. (the Facility) is the single largest manufacturer of residential steel roofs and siding in the U.S. Edco consists of a manufacturing and a distribution arm. The manufacturing process consists of roll coaters where aluminum and steel coils are coated and then dried in one of three curing ovens. The emissions from these operations are controlled with a thermal oxidizer. The Facility also has two spray booths that apply coatings to metal shingles followed by two curing ovens. The main emissions consist of volatile organic compounds (VOC), hazardous air pollutants (HAP), and particulate matter (PM). The Facility has several smaller sources that qualify as insignificant activities under Minn. R. 7007.1300, subp. 3 and 4. These are described in Appendix D of this permit.

The distribution arm distributes Edco's products directly to contractors and through two and three step distribution channels. The distribution arm also assembles sales demonstration kits that are sold to distributors and contractors. These kits consist of siding and shingle samples as well as color slips to assist customers in making the proper product selections.

The Facility has taken limits to avoid major source classification for New Source Review (40 CFR § 52.21). However, the Facility is a major source under the federal operation permits program (40 CFR pt. 70) and the National Emissions Standards for Hazardous Air Pollutants (NESHAPs, 40 CFR pt. 63).

TABLE A: LIMITS AND OTHER REQUIREMENTS A-1 08/11/15 Facility Name: EDCO Products Inc

Permit Number: 05301047-006

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

Subject Item: Total Facility

What to do Why to do it SOURCE-SPECIFIC REQUIREMENTS hdr

Permit Appendices: This permit contains appendices as listed in the permit Table of Contents. The Permittee shall comply with all requirements contained in the appendices. The appendices are as follows:

Appendix A: Operator's Summary (not used) Appendix B: New Source Performance Standards Calculations: 40 CFR pt. 60, subp. TT Appendix C: 40 CFR pt. 63 subp. MMMM Compliance Equations Appendix D: Insignificant Activities and General Applicable Requirements Appendix E: Maximum Contents of Materials and Process Parameters

Minn. R. 7007.0800, subp. 2

This permit establishes limits on the facility to keep it a minor source under New Source Review. The Permittee cannot make any change at the source that would make the source a major source under New Source Review until a permit amendment has been issued. This includes changes that might otherwise qualify as insignificant modifications and minor or moderate amendments.

Title I Condition: To avoid classification as a major source under 40 CFR Section 52.21 and Minn. R. 7007.3000

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

Minn. R. 7007.0800, subp. 2

Equipment Inventory: The Permittee shall maintain a written list of all emissions units and control equipment on site. The Permittee shall update the list to include any replaced, modified, or new equipment prior to making the change.

The list shall correlate the units to the numbers used in this permit (EU, GP, CE) and shall include the data on GI-04, GI-05B, and GI-05C. The date of construction shall be the date the change was made for replaced, modified, or new equipment.

Minn. R. 7007.0800, subp. 2

OPERATIONAL REQUIREMENTS hdr

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

Minn. Stat. Section 116.07, subds. 4a & 9; Minn. R. 7007.0100, subp. 7(A), 7(L), & 7(M); Minn. R. 7007.0800, subps. 1, 2 & 4; Minn. R. 7009.0010-7009.0080

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

Minn. R. 7011.0020

Air Pollution Control Equipment: Operate all pollution control equipment whenever the corresponding process equipment and emission units are operated.

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

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

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

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

Minn. R. 7019.1000, subp. 4



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

Minn. R. 7011.0150

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

Minn. R. 7030.0010 - 7030.0080

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

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

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

Minn. R. 7007.0800, subp. 16

PERFORMANCE TESTING hdr

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

Minn. R. ch. 7017

Performance Test Notifications and Submittals:

Performance Tests are due as outlined in Table A of the permit. See Table B for additional testing requirements.

Minn. R. 7017.2018; Minn. R. 7017.2030, subps. 1-4, Minn. R. 7017.2035, subps. 1-2

Performance Test Notification (written): due 30 days before each Performance Test Performance Test Plan: due 30 days before each Performance Test Performance Test Pre-test Meeting: due 7 days before each Performance Test Performance Test Report: due 45 days after each Performance Test Performance Test Report - Microfiche Copy: due 105 days after each Performance Test

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

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

Minn. R. 7017.2025, subp. 3

MONITORING REQUIREMENTS hdr

Monitoring Equipment Calibration - The Permittee shall either: Minn. R. 7007.0800, subp. 4(D)

1. Calibrate or replace required monitoring equipment every 12 months; or 2. Calibrate at the frequency stated in the manufacturer's specifications.

For each monitor, the Permittee shall maintain a record of all calibrations, including the date conducted, and any corrective action that resulted. The Permittee shall include the calibration frequencies, procedures, and manufacturer's specifications (if applicable) in the Operations and Maintenance Plan. Any requirements applying to continuous emission monitors are listed separately in this permit.

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

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

RECORDKEEPING hdr

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

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

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

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



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

Minn. R. 7007.1200, subp. 4

REPORTING/SUBMITTALS hdr

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

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

Minn. R. 7019.1000, subp. 3

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

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

Minn. R. 7019.1000, subp. 2

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

Minn. R. 7019.1000, subp. 1

Notification of Deviations Endangering Human Health or the Environment Report: Within 2 working days of discovery, notify the Commissioner in writing of any deviation from permit conditions which could endanger human health or the environment. Include the following information in this written description: 1. the cause of the deviation; 2. the exact dates of the period of the deviation, if the deviation has been corrected; 3. whether or not the deviation has been corrected; 4. the anticipated time by which the deviation is expected to be corrected, if not yet corrected; and 5. steps taken or planned to reduce, eliminate, and prevent reoccurrence of the deviation.

Minn. R. 7019.1000, subp. 1

Application for Permit Amendment: If a permit amendment is needed, submit an application in accordance with the requirements of Minn. R. 7007.1150 through Minn. R. 7007.1500. Submittal dates vary, depending on the type of amendment needed.

Minn. R. 7007.1150-7007.1500

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

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

Emission Inventory Report: due on or before April 1 of each calendar year following permit issuance, to be submitted on a form approved by the Commissioner.

Minn. R. 7019.3000 - 7019.3100

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

TABLE A: LIMITS AND OTHER REQUIREMENTS Facility Name: EDCO Products Inc


A-4 08/11/15

Subject Item:

Associated Items:

GP 001

CE 001

EU 001

EU 002

EU 003

EU 004 m

c

005

EU 006

EU 008

EU 010

EU 011

EU 012

m

c

013

Facility VOC Emissions Limits

Direct Flame Afterburner .

Primer/Backer Coater Spray Booth/Coating Line

Topcoater Spray Booth/Coating Line

Finish Oven (2-Zone) Dryer/Oven, unknown firing method

Primer Quench Bath Quenching Equipment

Topcoat Quench Bath Quenching Equipment

Primer IR Oven Process Heater

New NSPS Oven Dryer/Oven, unknown firing method .

Paint Booth 1 Spray Booth/Coating Line

Flat Line Continuous Flow Oven (IR) Process Heater



What to do Why to do it

Volatile Organic Compounds: less than or equal to 225.0 tons/year using 12-month Rolling Sum to be calculated by the 15th day of each month for the previous 12-month period as described later in this permit. All noncombustion VOC-emitting equipment at the Facility other than that listed in Appendix D of the permit is subject to this limit and shall be included in the 12-month rolling sum calculation.

VOC contents for each VOC-containing material shall be determined as described under the Material Content requirement in GP 001. Credit is given for the VOCs controlled by CE 001. The calculation of VOCs used may take into account recovered/recycled VOCs as described under the Waste Credit requirement in GP 001.

Title I Condition: To avoid classification as major source and modification under 40 CFR Section 52.21 & Minn. R. 7007.3000

All VOC-emitting equipment at the Facility is subject to this limit. If the Permittee replaces any existing VOC-emitting equipment, adds new VOC-emitting equipment, or modifies the existing equipment, such equipment is subject to this permit limit as well as all of the requirements of GP 001. Prior to making such a change, the Permittee shall apply for and obtain the appropriate permit amendment, as applicable. The Permittee is not required to complete VOC calculations described in Minn. R. 7007.1200, subp. 2. A permit amendment will still be needed regardless of the emissions increase if the change will be subject to a new applicable requirement or requires revisions to the limits or monitoring and recordkeeping in this permit.

Title I Condition: To avoid classification as major source and modification under 40 CFR Section 52.21 & Minn. R. 7007.3000

Pre-Authorized Changes to GP 001: The Permittee may replace EU 006 with like-kind equipment (IR ovens) during the term of this permit. In addition, the Permittee may add a new oven, EU 008, as specified later in this permit. All changes must meet all other permit limits.

If a proposed change triggers an applicable requirement not contained in this permit (e.g., 40 CFR pt. 63), the change must go through the appropriate procedure in Minn. R. ch. 7007.

Title I Condition: To avoid classification as major source and modification under 40 CFR Section 52.21 & Minn. R. 7007.3000;

MONITORING AND RECORDKEEPING hdr

Daily Recordkeeping. On each day of operation, the Permittee s hall record and maintain the quantity of all VOC-containing materials used in any coating operation at the Facility. This shall be based on written usage logs and/or purchase records.

For all other VOC-containing materials used'at the Facility (i.e., clean up solvent), the Permittee shall keep monthly records of materials purchased or used.

Title I Condition: To avoid classification as major source and modification under 40 CFR Section 52.21 & Minn. R. 7007.3000; Minn. R. 7007.0800. subp. 4 and 5

Monthly Recordkeeping - VOC Emissions. By the 15th of the month, the Permittee shall calculate and record the following: 1) The total usage of VOC-containing materials for the previous calendar month using the daily usage and monthly purchase records. This record shall show VOC materials used at the controlled vs. uncontrolled emissions units and shall also include the VOC contents of each material as determined by the Material Content requirement of this permit. 2) The VOC emissions for the previous month using the formulas specified in this permit. 3) The 12-month rolling sum VOC emissions for the previous 12-month period by summing the monthly VOC emissions data for the previous 12 months.

Minn. R. 7007.0800, subps. 4 and 5



Monthly Calculation - VOC Emissions. The Permittee shall calculate VOC emissions using the following equations:

VOC (tons/month) = [VC x ((100-C)/100)] + VU -VW VC = (A1 x B1) + (A2 x B2) + (A3 x B3) + .. .. VU = (D1 x E1) + (D2 x E2) + (D2 x E2) + .... VW= (F1 x G1) + (F2 x G2) + (F3 x G3) + ....

Minn. R. 7007.0800, subps. 4 and 5

Monthly VOC Emissions Calculation Continued:

where: VC = total VOC used at equipment vented to the thermal oxidizer, CE 001 in tons/month; A# = amount of each VOC-containing material used, in tons/month; B# = weight percent VOC in A#, as a fraction; C = the overall control efficiency for CE 001. This shall be the value as required by this permit for CE 001; VU = total VOC used that is NOT vented to the thermal oxidizer, in tons/month D# = amount of each VOC-containing material used, in tons/month; E# = weight percent VOC in D#, as a fraction; VW = the amount of VOC shipped in waste, in tons/month; F# = amount, in tons/month, of each VOC-containing waste material shipped. If the Permittee chooses to not take credit for waste shipments, this parameter would be zero; and G# = weight percent of VOC in F#, as a fraction.

Minn. R. 7007.0800, subps. 4 and 5

Material Content: VOC contents in materials shall be determined by the Material Safety Data Sheet (MSDS) provided by the supplier for each material used. If a material content range is given on the MSDS, the highest number in the range shall be used in all compliance calculations. Other alternative methods approved by the MPCA may be used to determine the VOC contents. The Commissioner reserves the right to require the Permittee to determine the VOC contents of any material, according to EPA or ASTM reference methods. If an EPA orASTM reference method is used for material content determination, the data obtained shall supersede the MSDS.

Minn. R. 7007.0800, subps. 4 and 5

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

Minn. R. 7007.0800, subps. 4 and 5

Maximum Contents of Materials and Process Parameters: The Permittee assumed certain worst-case contents of materials when determining the annual and short term potential to emit of units in GP 001. These assumptions are listed in Appendix E of this permit. Changing to a material that has a higher content of any of the given pollutants is considered a change in method of operation that must be evaluated under Minn. R. 7007.1200, subp. 3 to determine if a permit amendment or notification is required under Minn. R. 7007.1150.

Minn. R. 7005.0100, subp. 35a



A-6 08/11/15

Subject Item:

Associated Items:

GP 002

CE 001

EU 001

EU 002

EU 003

EU 004

EU 005

EU 006

EU 008

SV 001

SV 002

SV 003

NSPS Subpart TT Limits

Direct Flame Afterburner .







New NSPS Oven Dryer/Oven, unknown firing method .

Coating Emissions

Primer/Backer Quench

Top Coat Quench


The requirements of this portion of Table A apply to each affected facility in a metal coil surface coating operation: each prime coat operation, each finish coat operation, and each prime and finish coat operation combined when the finish coat is applied wet on wet over the prime coat and both coatings are cured simultaneously. At the time of permit issuance, EUs 001-006 and 008 are considered affected facilities.

40 CFR Section 60.460; Minn. R. 7011.2570

Terms used in this portion of Table A are as defined in state air pollution control rules or as defined in 40 CFR pt. 60, subps. A and TT. The definitions from 40 CFR Section 60.461 are included in Appendix B of this permit for clarity.

40 CFR Sections 60.2 and 60.461; Minn. R. 7011.0050 and 7011.2570

EMISSION REQUIREMENTS hdr

Volatile Organic Compounds: less than or equal to 10 percent of the VOCs applied at each affected facility in GP 002 shall be emitted, for each calendar month (90 percent emission reduction).

40 CFR Section 60.462(a)(3); Minn. R. 7011.2570


When required by 40 CFR Section 60.463(c)(2)(i), the Permittee shall use the procedures detailed in Appendix B of this permit for determining monthly volume-weighted average emissions of VOCs in kilograms per liter of coating solids applied. Each 1-month calculation is considered a performance test under 40 CFR Section 60.463(b).

40 CFR Section 60.463(c); Minn. R. 7011.2570

The Permittee shall install, calibrate, operate, and maintain a device that continuously records the combustion temperature of any effluent gases incinerated to achieve compliance with 40 CFR Section 60.462(a)(3). This device shall have an accuracy of +/- 2.5 deg C or +/- 0.75 percent of the temperature being measured expressed in degrees Celsius, whichever is greater.


The Permittee shall record all periods (during actual coating operations) in excess of 3 hours during which the average combustion temperature of CE 001 remains more than 28 deg C (50 deg F) below the temperature at which compliance with 40 CFR Section 60.462(a)(3) was demonstrated during the most recent measurement of incinerator efficiency required by 40 CFR Section 60.8. The Permittee shall record each such occurrence and its duration.


The Permittee shall maintain records of the occurrence and duration of any startup, shutdown, or malfunction in the operation of an affected facility; any malfunction of the air pollution control equipment; or any periods during which a continuous monitoring system or monitoring device is inoperative.

40 CFR Section 60.7(b), Minn. R. 7019.0100, subp. 1

Recordkeeping: The Permittee shall maintain a file of all measurements, including continuous monitoring system, monitoring device, and performance testing measurements; all continuous monitoring system performance evaluations; all continuous monitoring system or monitoring device calibration checks; adjustments and maintenance performed on these systems or devices; and all other information required by 40 CFR pt. 60 part recorded in a permanent form suitable for inspection. The file shall be retained for at least 2 years following the date of such measurements, maintenance, reports, and records.

Minn. R. 7007.0800, subp. 5(C) requires that all records be retained for an additional 3 years, for a total of 5 years from, the date of generation.

40 CFR Section 60.7(f); Minn. R. 7019.0100, subp. 1; Minn. R. 7007.0800, subp. 5(C)



The Permittee shall maintain at the source, for a period of at least 2 years, records of all data and calculations used to determine monthly VOC emissions from each affected facility and to determine the monthly emission limit, where applicable. The Permittee shall also maintain, at the source, daily records of the incinerator combustion temperature.

Minn. R. 7007.0800, subp. 5(C) requires that all records be retained for an additional 3 years, for a total of 5 years from the date of generation.

40 CFR Section 60.465(e); Minn. R. 7011.2570; Minn. R. 7007.0800, subp. 5(C)

REPORTING hdr

At all times, including periods of startup, shutdown, and malfunction, the Permittee shall, to the extent practicable, maintain and operate any affected facility including associated air pollution control equipment in a manner consistent with good air pollution control practice for minimizing emissions. Determination of whether acceptable operating and maintenance procedures are being used will be based on information available to the Commissioner which may include, but is not limited to, monitoring results, opacity observations, review of operating and maintenance procedures, and inspection of the source.

40 CFR Section 60.11(d); Minn. R. 7017.2015, subp. 2(B)

The Permittee shall not build, erect, install, or use any article, machine, equipment or process, the use of which conceals an emission which would otherwise constitute a violation of an applicable standard.


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

40 CFR Section 60.13(b); Minn. R. 7017.1010, subp. 1(A)

All continuous monitoring systems or monitoring devices shall be installed such that representative measurements of emissions or process parameters from the affected facility are obtained. Additional procedures for location of continuous monitoring systems contained in the applicable Performance Specifications of Appendix B of 40 CFR pt. 60 shall be used.

40 CFR Section 60.13(f); Minn. R. 7017.1010, subp. 1(A)



A-8 08/11/15

Subject Item:

Associated Items:

GP 003 Part 63 Subpart MMMM NESHAP

EU 010 Paint Booth 1 Spray Booth/Coating Line

EU 011 Flat Line Continuous Flow Oven (IR) Process Heater




See GP 006 and CE 001 for additional requirements that apply to the facility from 40 CFR pt. 63, subp. MMMM.

Minn. R. 7007.0800, subps. 4 and 5

Based on the current and expected operations of the affected source, this permit only includes the emission rate with add-on controls option specified in 40 CFR Section 63.3891(c). This is based on the Permittee complying using the Facility-Specific Emission Limit (FSEL) by using a combination of uncontrolled (40 CFR pt. 63, subp. MMMM units) and controlled units (40 CFR pt. 63, subp. SSSS units).

If the Permittee later chooses to switch to or add one or both of the other compliance options allowed in the standard, the Permittee shall comply with all applicable portions of 40 CFR pt. 63, subp. MMMM for those options. In addition, the Permittee shall apply for a permit amendment, as appropriate (e.g., to add applicable NESHAP language, installation of a different type of control device, etc.). '

40 CFR Section 63.3891; Minn. R. 7007.1150; Minn. R. 7011.8090

APPLICABILITY hdr

The activities in GP 003 are a new affected source that applies general use coatings to miscellaneous metal products. The facility meets the applicability criteria of 40 CFR pt. 63, subp. MMMM and at the same time also performs surface coating that meets the applicability cr iteria of another final surface coating NESHAPS (40 CFR pt. 63, subp. SSSS, see GP 005). The Permittee plans to comply with a FSEL as specified in 40 CFR Section 63.3881(e)(3).

40 CFR Section 63.3881 (e)(3); Minn. R. 7011.8090

The affected source is the collection of all of the items listed below that are used for surface coating of miscellaneous metal parts and products. 1) All coating operations as defined in 40 CFR Section 63.3981; 2) All storage containers and mixing vessels in which coatings, thinners and/or other additives, and cleaning materials are stored or mixed; 3) All manual and automated equipment and containers used for conveying coatings, thinners and/or other additives, and cleaning materials; and 4) All storage containers and all manual and automated equipment and containers used for conveying waste materials generated by a coating operation.

40 CFR Section 63.3882(b); Minn. R. 7011.8090

EMISSION AND OPERATIONAL LIMITS hdr

HAPs - Organic: less than or equal to 0.230 kilograms/liter coating solids used during each 12-month compliance period. This is the limit from 40 CFR pt. 63, subp. MMMM that is used for the Facility-Specific Emission Limit calculated as specified by this permit at GP 006.


The Permittee elects to comply using the FSEL alternative. See GP 006 for requirements that cover all activities subject to the FSEL.

40 CFR Section 63.3890(c)(2); Minn. R. 7011.8090

COMPLIANCE REQUIREMENTS hdr

The Permittee must include all coatings (as defined in 40 CFR Section 63.3981), thinners and/or other additives, and cleaning materials used in the affected source when determining whether the organic HAP emission rate is equal to or less than the FSEL at GP 006. To make this determination, the Permittee must use at least one of the three compliance options listed in 40 CFR Section 63.3891 (a)-(c).

As stated earlier, this permit only includes the requirements associated with emission rate with add-on controls option spe cified in 40 CFR Section 63.3891(c). continued below



Permit Number: 05301047 - 006

A-9 08/11/15

continued from above Even so, the Permittee may apply any of the compliance options to an individual coating operation, or to multiple coating operations as a group, or to the entire affected source as specified in 40 CFR Section 63.3891. If the Permittee switches between compliance options for any coating operation or group of coating operations, the Permittee must document this switch as required by 40 CFR Section 63.3930(c), and the Permittee must report it in the next semiannual compliance report listed in Table B (at GP 006).

A permit amendment is needed if switching to a compliance option not included in this permit.


TABLE A: LIMITS AND OTHER REQUIREMENTS Facility Name: ED CO Products Inc


A-10 08/11/15

Subject Item:

Associated Items:

GP 004 Paint Booths and IR Cure Ovens





What to do Why to do it EMISSION LIMITS hdr

Total Particulate Matter: less than or equal to 0.30 grains/dry standard cubic foot of exhaust gas unless required to further reduce emissions to comply with the less stringent limit of either Minn. R. 7011.0730 or Minn. R. 7011.0735. This applies separately to each unit in GP 004.

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

Opacity: less than or equal to 20 percent opacity . This applies separately to each unit in GP 004.

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

The Permittee shall vent emissions from all paint booths, including existing, modified, or new paint booths, to control equipment meeting the requirements of GP 007. The Permittee shall document periods of non-operation of the control equipment. All such booths must also meet the requirements of GP 004.

Minn. R. 7007.0800, subp. 2


Paint Booth Total Enclosure: The Permittee shall close the paint booth doors prior to and during any coating application in order to achieve a tot al enclosure.

Minn. R. 7007.0800, subp. 2

Paint Booth Total Enclosure Monitoring and Recordkeeping: The Permittee shall keep a log of all paint booth coating activities to demonstrate the booth doors are closed during all coating application. Each person that applies coating in a paint booth shall make a daily log entry on the date the coatings are applied noting the EU number of the paint booth.

The log shall be dated and signed by each person, and shall confirm if the booth doors were closed during all coating applications made by that person on that date. Failure to close the doors during coating application is a deviation that must be reported on the semi-annual deviation report requirement in Table B.

Minn. R. 7007.0800, subps. 4 and 5



A-11 08/11/15

Subject Item:

Associated Items:

GP 005 Part 63 Subpart SSSS NESHAP

CE 001 Direct Flame Afterburner

EU 001 Primer/Backer Coater Spray Booth/Coating Line

EU 002 Topcoater Spray Booth/Coating Line

EU 003 Finish Oven (2-Zone) Dryer/Oven, unknown firing method

EU 004 Primer Quench Bath Quenching Equipment

EU 005 Topcoat Quench Bath Quenching Equipment

EU 006 Primer IR Oven Process Heater

EU 008 New NSPS Oven Dryer/Oven, unknown firing method


See GP 006 and CE 001 for additional requirements that apply to this equipment. Minn. R. 7007.0800, subps. 4 and 5

Based on the current and expected operations of the affected source, this permit only includes the capture and control option specified in 40 CFR Section 63.5170(d). If the Permittee later chooses to switch to or add one or both of the other compliance options allowed in the standard, the Permittee shall comply with all applicable portions of 40 CFR pt. 63, subp. SSSS for those options. In addition, the Permittee shall apply for a permit amendment, as appropriate (e.g., to add applicable NESHAP language, installation of different controls, etc.).

40 CFR Section 63.5170; Minn. R. 7007.1150 and Minn. R. 7011.7905

APPLICABILITY hdr

The facility is an existing affected source that performs metal coil surface coating operations and is a major source of Hazardous Air Pollutants (HAP). As allowed under 40 CFR Section 63.3881(e)(3), the Permittee has chosen to comply with both 40 CFR pt. 63, subps. MMMM and SSSS using a Facility-Specific Emission Limit (FSEL). See GP 006 for FSEL requirements.

40 CFR Section 63.5080, Minn. R. 7011.7905

The affected source is the collection of all of the coil coating lines at the facilit y. 40 CFR Section 63.5100; Minn. R. 7011.7905

LIMITS hdr

HAPs - Organic: less than or equal to 0.0460 kilograms/liter of solids applied during each 12-month compliance period. This is the limit from 40 CFR pt. 63, subp. SSSS that is used for the FSEL calculated as specified at GP 006 in this permit.

40 CFR Section 63.5120(a)(2), Minn. R. 7011.7905

The Permittee must be in compliance with 40 CFR pt. 63, subp. SSSS at all times, except during periods of start-up, shutdown, and malfunction of any capture system and control device used to comply with 40 CFR pt. 63, subp. SSSS.


COMPLIANCE REQUIREMENTS hdr

The Permittee must include all coating materials (as defined in 40 CFR Section 63.5110) used in the affected source when determining compliance with the FSEL at GP 006. The Permittee may apply any of the compliance options listed in Table 1 of 40 CFR Section 63.5170 as required by that Section.

As stated earlier, this permit only includes the requirements associated with the capture and control option specified in 40 CFR Section 63.5170(d). continued below


continued from above Even so, the Permittee may apply any of the compliance options to an individual coil coating line, or to multiple lines as a group, or to the entire affected source. The Permittee may use different compliance options for different coil coating lines, or at different times on the same line. However, the Permittee may not use different compliance options at the same time on the same coil coating line. If the Permittee switches between compliance options for any coil coating line or group of lines, the Permittee must document this switch as required by 40 CFR Section 63.5190(a), and must report it in the next semiannual compliance report listed in Table B of this permit (either at GP 005 or GP 006, as applicable).

A permit amendment is needed if switching to a compliance option not included in this permit. .




A-12 08/11/15

Subject Item:

Associated Items:

GP 006

EU 001

EU 002

EU 003

EU 004

3

UJ

005

EU 006

EU 008

EU 010

EU 011

m

c

012

EU 013

Facility-Specific Emission Limit







New NSPS Oven Dryer/Oven, unknown firing method



Paint Booth 2 Spray Booth/Coating Line .



Unless otherwise noted, all equations referenced in the requirements of GP 006 can be found in Appendix C of this permit.

Minn. R. 7007.0800, subps. 4 and 5


The Permittee elects to comply using the facility-specific emission alternative of 40 CFR pt. 63, subp. MMMM for equipment subject to 40 CFR pt. 63, subp. MMMM and equipment subject to 40 CFR pt. 63, subp. SSSS.

In calculating the facility-specific emission limit, the Permittee must include coating activities that meet the applicability criteria of the other subcategories and constitute more than 1 percent of total coating activities. Coating activities that meet the applicability criteria of other surface coating NESHAP but comprise less than 1 percent of coating activities need not be included in the determination of predominant activity but must be included in the compliance calculation, continued below


continued from above The Permittee shall calculate the Facility-Specific Emission Limit (FSEL) when submitting the notification of compliance status required in Table B of this permit and on a monthly basis afterward using the following formula:

FSEL = [(0.23 x S4M) + (0.046 x S4S)]/(S4M + S4S)

Where: FSEL = the Facility-Specific Emission Limit, in kg organic HAP/liter of coating solids used; S4M = The liters of solids used in all 40 CFR pt. 63, subp. MMMM coating operations in the 12-month compliance period that is subject to the FSEL; and S4S = The liters of solids used in all 40 CFR pt. 63, subp. SSSS coating operations in the 12-month compliance period that is subject to the FSEL.


Work Practice Plan. The Permittee must develop and implement a work practice plan to minimize organic HAP emissions from the storage, mixing, and conveying of coatings, thinners and/or other additives, a nd cleaning materials used in, and waste materials generated by units in GP 006. The plan must specify practices and procedures to ensure that, at a minimum, the following elements are implemented: 1) All organic-HAP-containing coatings, thinners and/or other additives, cleaning materials, and waste materials must be stored in closed containers. 2) Spills of organic-HAP-containing coatings, thinners and/or other additives, cleaning materials, and waste materials must be minimized. 3) Organic-HAP-containing coatings, thinners and/or other additives, cleaning materials, and waste materials must be conveyed from one location to another in closed containers or pipes. continued below

40 CFR Sections 63.3881(e)(3) and 63.3893(b); Minn. R. 7011.8090

continued from above 4) Mixing vessels which contain organic-HAP-containing coatings and other materials must be closed except when adding to, removing, or mixing the contents. AND 5) Emissions of organic HAP must be minimized during cleaning of storage, mixing, and conveying equipment.

40 CFR Sections 63.3881(e)(3) and 63.3893(b); Minn. R. 7011.8090

TABLE A: LIMITS AND OTHER REQUIREMENTS A-13 08/11/15 Facility Name: EDCO Products Inc •


Proper Operation and Maintenance: At all times, including periods of startup, shutdown and malfunction, the Permittee shall operate and maintain the emission units subject to 40 CFR pt. 63, subps. MMMM and SSSS and their associated air pollution control and monitoring equipment in a manner consistent with safety and good air pollution control practices for minimizing emissions at least to the levels required by all relevant standards.

Malfunctions shall be corrected as soon as practicable after their occurrence.

40 CFR Section 63.6(e)(1)(i) and (ii); Minn. R. 7011.7000

GENERAL COMPLIANCE REQUIREMENTS hdr

Emission rate with add-on controls option. The Permittee shall demonstrate that, based on the coatings, thinners and/or other additives, and cleaning materials used in the coating operation(s), and the emission reductions achieved by emission capture systems and add-on controls, the organic HAP emission rate for the coating operation(s) is less than or equal to the FSEL, calculated as a rolling 12-month emission rate and determined on a monthly basis. The Permittee must meet all the requirements of 40 CFR Sections 63.3960 through 63.3968 to demonstrate compliance with the emission limits, operating limits, and work practice standards using this option.

40 CFR Section 63.3891(c) (40 CFR 63.5170, table 1, item 4); Minn. R. 7011.8090

The Permittee must be in compliance with the emission limitations as specified below for all units in GP 006: 1) The coating operation(s) must be in compliance with the FSEL at all times except during periods of startup, shutdown, and malfunction. 2) The coating operation(s) must be in compliance with the operating limits for emission capture systems and add-on control devices listed at CE 001 in this permit at all times except during periods of startup, shutdown, and malfunction. 3) The coating operation(s) must be in compliance with the work practice standards listed in this permit at all times. AND 4) The Permittee must always operate and maintain the equipment according to the provisions in 40 CFR Section 63.6(e)(1)(i).

40 CFR Section 63.3900(a)(2) and (b); Minn. R. 7011.8090

The Permittee must develop a written startup, shutdown, and malfunction plan (SMMP) according to the provisions in 40 CFR Section 63.6(e)(3). The plan must address the startup, shutdown, and corrective actions in the event of a malfunction of the emission capture system or the add-on control device. The plan must also address any coating operation equipment that may cause increased emissions or that would affect capture efficiency if the process equipment malfunctions, such as conveyors that move parts among enclosures.

The SSMP must be located at the plant site and must be kept updated. When the SSMP is updated, the Permittee must keep all previous versions of the SSMP for a period of 5 years. The Permittee must submit the SSMP when required.

40 CFR Sections 63.3900(c), 63.6(e)(3)(i), and 63.6(e)(3)(v); Minn. R. 7011.7000 and Minn. R. 7011.8090

COMPLIANCE DEMONSTRATION hdr

Because the Permittee is complying with a FSEL with some controlled and some uncontrolled coating operations, the Permittee shall use the emission rate with add-on controls option for the group of both controlled and uncontrolled coating operations.

The Permittee must meet all the requirements of 40 CFR Section 63.3961.

40 CFR Section 63.3961 (a); Minn. R. 7011.8090

The Permittee does not need to redetermine the mass of organic HAP in coatings, thinners and/or other additives, or cleaning materials that have been reclaimed onsite (or reclaimed off-site if you have documentation showing that you received back the exact same materials that were sent off-site) and reused in the coatings operation(s) for which the emission rate with add-on controls option was used. If coatings, thinners and/or other additives, or cleaning materials were used that have been reclaimed on-site, the amount of each used in a month may be reduced by the amount of each that is reclaimed. That is, the amount used may be calculated as the amount consumed to account for materials that are reclaimed.

40 CFR Section 63.3961 (a); Minn. R. 7011.8090

Compliance with emission limits. The Permittee must follow the procedures specified in this permit to demonstrate compliance with the FSEL.

40 CFR Section 63.3961 (d); Minn. R. 7011.8090

TABLE A: LIMITS AND OTHER REQUIREMENTS A-14 08/11/15 Facility Name: EDCO Products Inc •


Mass Fraction of HAP: The Permittee shall determine the mass fraction of organic HAP for each coating, thinner and/or other additive, and cleaning material used during each month by using one of the following options: 1) The Permittee may use Method 311 (appendix A to 40 CFR pt. 63) for determining the mass fraction of organic HAP. Use the procedures specified in 40 CFR Section 63.3941 (a)(1)(i) and (ii) when performing a Method 311 test; 2) For coatings, the Permittee may use Method 24 (appendix A to 40 CFR part 60) to determine the mass fraction of nonaqueous volatile matter and use th at value as a substitute for mass fraction of organic HAP. For reactive adhesives in which some of the HAP react to form solids and are not emitted to the atmosphere, the Permittee may use the alternative method contained in appendix A to 40 CFR pt. 63, subp. PPPP, rather than Method 24. continued below

40 CFR Sections 63.3961(e) and 63.3951(a) (40 CFR Sections 63.5160(b) and 63.5170(f)(1 )(vii)); Minn. R. 7011.8090

2) continued from above The Permittee may use the volatile fraction that is emitted, as measured by the alternative method in appendix A to subpart PPPP, as a substitute for the mass fraction of organic HAP; 3) The Permittee may use an alternative test method for determining the mass fraction of organic HAP as specified in 40 CFR Section 63.3941(a)(3); 4) The Permittee may rely on information other than the three options given above, such as manufacturer's formulation data, if it represents each organic HAP that is present at 0.1 percent by mass or more for OSHA-defined carcinogens as specified in 29 CFR Section 1910.1200(d)(4) and at 1.0 percent by mass or more for other compounds. For reactive adhesives in which some of the HAP react to form solids and are not emitted to the atmosphere, you may rely on manufacturer's data that expressly states the organic HAP or volatile matter mass fraction emitted, continued below

40 CFR Sections 63.3961(e) and 63.3951(a) (satisfies 40 CFR Sections 63.5160(b) and 63.5170(f)(1)(vii)); Minn. R. 7011.8090

4) continued from above If there is a disagreement between such information and results of a test conducted according to the three other options, then the test method results will take precedence unless, after consultation, the Permittee can demonstrate to the satisfaction of the Agency that the formulation data are correct; or 5) Solvent blends may be listed as single components for some materials in data provided by manufacturers or suppliers. Solvent blends may contain organic HAP which must be counted toward the total organic HAP mass fraction of the materials. When test data and manufacturer's data for solvent blends are not available, the Permittee may use the default values for the mass fraction of organic HAP in these solvent blends listed in Table 3 or 4 of 40 CFR pt. 63, subp. MMMM. continued below


5) continued from above If these tables are used, the Permittee must-use the values in Table 3 for all solvent blends that match Table 3 entries according to the instructions for Table 3, and the Permittee may use Table 4 only if the solvent blends in the materials used do not match any of the solvent blends in Table 3 and the Permittee knows only whether the blend is aliphatic or aromatic. However, if the results of a Method 311 (appendix A to 40 CFR pt. 63) test indicate higher values than those listed on Table 3 or 4, the Method 311 results will take precedence unless, after consultation, you demonstrate to the satisfaction of the Agency the formulation data are correct.


Volume Fraction of Solids: The Permittee shall determine the volume fraction of coating solids (liter (gal) of coating solids per liter (gal) of coating) for each coating used during each month by one of the methods given below. If test results obtained according to item 1 below do not agree with the information obtained under items 3 or 4 below, the test results will take precedence unless, after consultation, you demonstrate to the satisfaction of the Agency that the formulation data are correct. 1) The Permittee may use ASTM methods as specified in 40 CFR Section 63.3941(b)(1); 2) The Permittee may use an alternative test method for determining the solids content of each coating as specified in 40 CFR Section 63.3941(b)(2); 3) The Permittee may obtain the volume fraction of coating solids for each coating from the supplier or manufacturer; or 4) The Permittee may determine the volume, fraction of coating solids using the equation in 40 CFR Section 63.3941(b)(4).

40 CFR Sections 63.3961(e) and 63.3951(b) (satisfies 40 CFR Sections 63.5160(c) and 63.5170(f)(1)(viii)); Minn. R. 7011.8090

TABLE A: LIMITS AND OTHER REQUIREMENTS A-15 08/11/15 Facility Name: EDCO Products Inc . '


Density: The Permittee shall determine the density of each liquid coating, thinner and/or other additive, and cleaning material used during each month from test results using ASTM Method D1475-98, "Standard Test Method for Density of Liquid Coatings, Inks, and Related Products" (incorporated by reference, see 40 CFR Section 63.14), information from the supplier or manufacturer of the material, or reference sources providing density or specific gravity data for pure materials. If the Permittee is including powder coatings in the compliance determination, determine the density of powder coatings, using ASTM Method D5965-02, "Standard Test Methods for Specific Gravity of Coating Powders" (incorporated by reference, see 40 CFR Section 63.14), or information from the supplier, continued below

40 CFR Sections 63.3961(e) and 63.3951(c) (satisfies 40 CFR Sections 63.5160(c) and 63.5170(f)(1)(viii)); Minn. R. 7011.8090

continued from above If there is disagreement between ASTM Method D1475-98 or ASTM Method D5965-02 test results and other such informa tion sources, the test results will take precedence unless, after consultation the Permittee demonstrates to the satisfaction of the Agency that the formulation data are correct. If the Permittee purchases materials or monitor consumption by weight instead of volume, the Permittee does not need to determine material density. Instead, the Permittee may use the material weight in place of the combined terms for density and volume in Equations 1A, 1B, 1C, and 2 of Appendix C.

40 CFR Sections 63.3961(e) and 63.3951(c) (satisfies 40 CFR Sections 63.5160(c) and 63.5170(f)(1)(viii)); Minn. R. 7011.8090

Volume: The Permittee shall determine the volume (liters) of each coating, thinner and/or other additive, and cleaning material used during each month by measurement or usage records. If the Permittee purchases materials or monitors consumption by weight instead of volume, the Permittee does not need to determine the volume of each material used. Instead, the Permittee may use the material weight in place of the combined terms for density and volume in Equations 1A, 1B, and 1C of Appendix C.

40 CFR Sections 63.3961(e) and 63.3951(d); Minn. R. 7011.8090

Pre-Control Total Mass Organic HAP. Using Equation 1 of Appendix C, the Permittee shall calculate the total mass of organic HAP emissions before add-on controls from all coatings, thinners and/or other additives, and cleaning materials used during each month in the coating operation or group of coating operations.

40 CFR Section 63.3961 (f); Minn. R. 7011.8090

HAP Reduction from Controls. The Permittee shall determine the mass of organic HAP emissions reduced for each controlled coating operation during each month. The emission reduction determination quantifies the total organic HAP emissions that pass through the emission capture system and are destroyed or removed by the add-on control device. Use the procedures specified below to calculate the mass of organic HAP emission reduction for each controlled coating operation using an emission capture system and add-on control device other than a solvent recovery system for which you conduct liquid-liquid material balances.

40 CFR Section 63.3961(g); Minn. R. 7011.8090

Organic HAP Emission Reduction. The Permittee shall use Equation 3 of Appendix C to calculate the organic HAP emission reduction' for coating operations in GP 006. The calculation applies the emission capture system efficiency and add-on control device efficiency to the mass of organic HAP contained in the coatings, thinners and/or other additives, and cleaning materials that are used in the coating operation served by the emission capture system and add-on control device during each month.

40 CFR Section 63.3961(h) (satisfies 40 CFR Section 5170(f)(1)(v)); Minn. R. 7011.8090

The Permittee must assume zero efficiency for the emission capture system and add-on control device for any period of time a deviation specified in 40 CFR Section 63.3963(c) or (d) occurs in the controlled coating operation, including a deviation during a period of startup, shutdown, or malfunction, unless the Permittee has other data indicating the actual efficiency of the emission capture system and add-on control device and the use of these data is approved by the Administrator. Equation 3 of Appendix C treats the materials used during such a deviation as if they were used on an uncontrolled coating operation for the time period of the deviation.

40 CFR Section 63.3961(h) (satisfies 40 CFR Section 5170(f)(1 )(v)); Minn. R. 7011.8090

The Permittee shall calculate the following using the referenced equations in Appendix C of this permit: 1) Calculate the mass organic HAP in the coatings used in the controlled coating operation, kg (lb), using Equation 3A; 2) Calculate the mass of organic HAP in the thinners and/or other additives used in the controlled coating operation, kg (lb), using Equation 3B; 3) Calculate the mass of organic HAP in the cleaning materials used in the controlled coating operation during the month, kg (lb), using Equation 3C; and 4) Calculate the mass of organic HAP in the coatings, thinners and/or other additives, and cleaning materials used in the controlled coating operation during deviations specified in 40 CFR Section 63.3963(c) and (d), using Equation 3D.

40 CFR Section 63.3961 (h)(1)-(4) (satisfies 40 CFR Section 63.5170(f)(1 )(vi)); Minn. R. 7011.8090

TABLE A: LIMITS AND OTHER REQUIREMENTS A-16 08/11/15 Facility Name: EDCO Products Inc '


Total Volume of Coating Solids used. The Permittee shall determine the total volume of coating solids used, liters, which is the combined volume of coating solids for all the coatings used during each month in the coating operation or group of coating operations for which the Permittee uses the emission rate with add-on controls option, using Equation 2 of Appendix C.

40 CFR Section 63.3961 (k); Minn. R. 7011.8090

Mass of Organic HAP Emissions. The Permittee shall determine the mass of organic HAP emissions, kg, during each month, using Equation 4 of Appendix C.

40 CFR Section 63.3961(1) (satisfies 40 CFR Section 63.5170(f)(1)(ix)); Minn. R. 7011.8090

Organic HAP Emission Rate. The Permittee shall determine the organic HAP emission rate for the compliance period, kg (lb) of organic HAP emitted per liter (gal) coating solids used, using Equation 5 of Appendix C. The organic HAP emission rate for the initial compliance period, calculated using Equation 5, must be less than or equal to the FSEL.

40 CFR Section 63.3961 (m) and (n) (satisfies 40 CFR Section 63.5170(f)(1)(x)); Minn. R. 7011.8090

FSEL. To demonstrate continuous compliance with the FSEL, the organic HAP emission rate for each compliance period, determined according to the procedures in 40 CFR Section 63.3961, must be equal to or less than the FSEL. A compliance period consists of 12 months. Each month after 3/31/2009 is the end of a compliance period consisting of that month and the preceding 11 months. The Permittee must perform the calculations in 40 CFR Section 63.3961 on a monthly basis using data from the previous 12 months of operation. The Permittee must also perform the FSEL calculation using the FSEL formula specified earlier in this permit on a monthly basis using the data from the previous 12 months of operation, continued below

40 CFR Section 63.3963(a) (satisfies 40 CFR Section 63.5170(d)(2)); Minn. R. 7011.8090

continued from above If the organic HAP emission rate for any 12-month compliance period exceeded the FSEL, this is a deviation from the emission limitation for that compliance period that must be reported as specified in 40 CFR Sections 63.3910(c)(6) and 63.3920(a)(7).


Work Practice. The Permittee must demonstrate continuous compliance with the work practice standards in 40 CFR Section 63.3893. If the Permittee did not develop a work practice plan, or did not implement the plan, or did not keep the records required by 40 CFR Section 63.3930(k)(8), this is a deviation from the work practice standards that must be reported as specified in 40 CFR Sections 63.3910(c)(6) and 63.3920(a)(7).

40 CFR Section 63.3963(e); Minn. R. 7011.8090

RECORDKEEPING hdr

Recordkeeping: The Permittee shall maintain files of all information required by 40 CFR pt. 63 in a form suitable and readily available for expeditious inspection and review.

The files should be retained for at least 5 years following the date of each occurrence, measurement, maintenance, corrective action, report, or record. Only the most recent two years of information must be kept on site.

40 CFR Sections 63.10(b)(1), 63.3931 and 63.3952(d); Minn. R. 7019.0100, subp. 2(B)

The Permittee shall maintain, at a minimum, the following information in the files: 1) the occurrence and duration of each startup, shutdown, or malfunction of operation; 2) the occurrence and duration of each malfunction of the air pollution control equipment; 3) all maintenance performed on the pollution control equipment; 4) actions taken during periods of startup, shutdown, and malfunction when such actions are different from the procedures specified in the SSMP. In this case, the Permittee shall report this action within 2 days of occurrence and follow by a written notification within 7 days of occurrence. 5) all information necessary to demonstrate conformance with the SSMP and actions taken in accordance with SSMP.

40 CFR Sections 63.10(b)(2), 63.3931, and 63.3963(j); Minn. R. 7011.7000

6) each period during which a continuous monitoring system (CMS) is malfunctioning or inoperative; 7) all required measurements needed to demonstrate compliance with a relevant standard; 8) all results of performance test, CMS performance evaluations, and opacity and visible emission observations; 9) all measurements as may be necessary to determine the conditions of performance tests and performance evaluations; 10) all CMS calibration checks; 11) all adjustments and maintenance performed on CMS; and 12) all documents supporting initial notifications and notifications of compliance status (for both 40 CFR pt. 63, subps. SSSS and MMMM).

40 CFR Sections 63.10(b)(2), 63.3931, and 63.3963(j); Minn. R. 7019.0100, subp. 2(B)



The Permittee must collect and keep records of the data and information specified below. Failure to collect and keep these records is a deviation from the applicable standard. 1) A copy of each notification and report that the Permittee submitted to comply with 40 CFR pt. 63, subp. MMMM and the documentation supporting each notification and report; 2) Records of the data used to calculate the FSEL for the initial compliance demonstration. The Permittee must also keep records of any data used in each calculation of the FSEL for each 12-month compliance period included in the semi-annual compliance reports; continued below

40 CFR Section 63.3930(a), (b), (c)(1) and (c)(4), (d), (e), (f), (9). (h) and (j); 40 CFR Section 63.3963(j); Minn. R. 7011.8090 (satisfies 40 CFR Section 63.5190(a)(1), (a)(2)(iii), (iv), and (vi))

continued from above 3) A current copy of information provided by materials suppliers or manufacturers, such as manufacturer's formulation data, or test data used to determine the mass fraction of organic HAP and density for each coating, thinner and/or other additive, and cleaning material, and the volume fraction of coating solids for each coating. If the Permittee conducted testing to determine mass fraction of organic HAP, density, or volume fraction of coating solids, the Permittee must keep a copy of the complete test report. If the Permittee uses information provided to the Permittee by the manufacturer or supplier of the material that was based on testing, the Permittee must keep the summary sheet of results provided to the Permittee by the manufacturer or supplier. The Permittee is not required to obtain the test report or other supporting documentation from the manufacturer or supplier; continued below

40 CFR Section 63.3930(a), (b), (c)(1) and (c)(4), (d), (e), (f), (g), (h) and (j); 40 CFR Section 63.3963(j); Minn. R. 7011.8090 (satisfies 40 CFR Section 63.5190(a)(1), (a)(2)(iii), (iv), and (vi))

continued from above 4) For each compliance period, the records specified below: - A record of the coating operations on which the Permittee used each compliance option and the time periods (beginning and ending dates and times) for each option the Permittee used; - A record of the calculation of the total mass of organic HAP emissions for the coatings, thinners and/or other additives, and cleaning materials used each month using Equations 1 and 1A through 1C and, if applicable, the calculation used to determine mass of organic HAP in waste materials; - A record of the calculation of the total volume of coating solids used each month using Equation 2; - A record of the calculation of the mass of organic HAP emission reduction by emission capture systems and add-on control devices using Equations 3 and 3A through 3D; - A record of the calculation of each month's organic HAP emission rate using Equation 4; and continued below


continued from above -A record of the calculation of each 12-month organic HAP emission rate using Equation 5. 5) A record of the name and volume of each coating, thinner and/or other additive, and cleaning material used during each compliance period; 6) A record of the mass fraction of organic HAP for each coating, thinner and/or other additive, and cleaning material used during each compliance period unless the material is tracked by weight; 7) A record of the volume fraction of coating solids for each coating used during each compliance period; 8) The density for each coating, thinner and/or other additive, and cleaning material used during each compliance period; ' continued below

40 CFR Section 63.3930(a), (b), (c)(1) and (c)(4), (d), (e), (f), (g), (h) and (j); 40 CFR Section 63.39630); Minn. R. 7011.8090 (satisfies 40 CFR Section 63.5190(a)(1), (a)(2)(iii), (iv), and (vi))

continued from above 9) If the Permittee uses an allowance in Equation 1 for organi c HAP contained in waste materials according to 40 CFR Section 63.3951(e)(4), the Permittee must keep the following records: - The name and address of each TSDF to which the Permittee sent waste materials for which the Permittee uses an allowance in Equation 1; a statement of which subparts under 40 CFR parts 262, 264, 265, and 266 apply to the facility; and the date of each shipment; - Identification of the coating operations producing waste materials included in each shipment and the month or months in which the Permittee used the allowance for these materials in Equation 1; continued below

40 CFR Section 63.3930(a), (b), (c)(1) and (c)(4), (d), (e), (f), (g), (h) and (j); 40 CFR Section 6 3.3963®; Minn. R. 7011.8090 (satisfies 40 CFR Section 63.5190(a)(1), (a)(2)(iii), (iv), and (vi))



continued from above - The methodology used in accordance with 40 CFR Section 63.3951(e)(4) to determine the total amount of waste materials sent to or the amount collected, stored, and designated for transport to a TSDF each month; and the methodology to determine the mass of organic HAP contained in these waste ma terials. This must include the sources for all data used in the determination, m ethods used to generate the data, frequency of testing or monitoring, and supporting calculations and documentation, including the waste manifest for each shipment. 10) The Permittee must keep records of the date, time, and duration of each deviation. '


The Permittee shall collect and keep the following records: 1) For each deviation, a record of whether the deviation occurred during a period of startup, shutdown, or malfunction; 2) The records in 40 CFR Section 63.6(e)(3)(iii) through (v) related to startup, shutdown, and malfunction; 3) The records required to show continuous compliance with each operating limit that applies to CE 001; 4) For each capture system that is a permanent total enclosure (PTE), the data and documentation used to support a determination that the capture system meets the criteria in Method 204 of appendix M to 40 CFR pt. 51 for a PTE and has a capture efficiency of 100 percent, as specified in 40 CFR Section 63.3965(a); continued below

40 CFR Section 63.3930(k); 40 CFR Section 63.3963(j); Minn. R. 7011.8090 (satisfies 40 CFR Section 63.5190(a)(2)(ii) and (v))

continued from above 5) The following records for each add-on control device organic HAP destruction or removal efficiency determination as specified in 40 CFR Section 63.3966: - Records of each add-on control device performance test conducted according to 40 CFR Sections 63.3964 and 63.3966. - Records of the coating operation conditions during the add-on control device performance test showing that the performance test was conducted under representative operating conditions; 6) Records of the data and calculations used to establish the em ission capture and add-on control device operating limits as specified in 40 CFR Section 63.3967 and to document compliance with the operating limits that apply to CE 001; AND 7) A record of the work practice plan required by 40 CFR Section 63.3893 and documentation that the Permittee is implementing the plan on a continuous basis.

40 CFR Section 63.3930(k); 40 CFR Section 63.3963(j); Minn. R. 7011.8090 (satisfies 40 CFR Section 63.5190(a)(2)(ii) and (v))

REPORTING hdr

Content of Semiannual Compliance Report: At a minimum, the report shall include: 1) Company name and address; 2) Statement by a responsible official with that official's name , title, and signature, certifying the truth, accuracy, and completeness of the content of the report; 3) Date of report and beginning and ending dates of the reporting period. The reporting period is the 6-month period ending on June 30 or December 31. Note that the information reported for each of the 6 months in the reporting period will be based on the last 12 months of data prior to the date of each monthly calculation; 4) Identification of the compliance option or options specified in 40 CFR Sections 63.3891 and 63.5170 (Table 1) that the Permittee used on each coating operation during the reporting period. If the Permittee switched between compliance options during the reporting period, the Permittee must report the beginning and ending dates for each option the Permittee used. continued below

40 CFR Sections 63.3920(a)(3), (4) and (7) and 63.3963(f) (satisfies 40 CFR Section 63.5180(g)(2) and (h)); Minn. R. 7011.8090

continued from above 5)The calculation results for each rolling 12-month organic HAP emission rate during the 6-month reporting period; ' 6) The calculation of the FSEL for each 12-month compliance period during the 6-month reporting period; 7) If there were no deviations from the applicable HAP emission limit, the semiannual compliance report must include a statement that there were no deviations from the emission limitations during the reporting period. If there were no periods during which the continuous parameter monitoring systems (CPMS) were out-of-control as specified in 40 CFR Section 63.8(c)(7), the semiannual compliance report must include a statement that there were no periods during which the CPMS were out-of-control during the reporting period; and continued below




continued from above 8) If there was a deviation from an emission limitation, the semiannual compliance report must contain the information specified below. This includes periods of startup, shutdown, and malfunction during which deviations occurred: a. The beginning and ending dates of each compliance period during which the 12-month organic HAP emission rate exceeded the FSEL. b. The calculations used to determine the 12-month organic HAP emission rate for each compliance period in which a deviation occurred. The Permittee must provide the calculation of the total mass of organic HAP emissions for the coatings, thinners and/or other additives, and cleaning materials used each month using Equations 1 and 1A through 1C; and, if applicable, the calculation used to determine mass of organic HAP in waste materials; the calculation of the total volume of coating solids used each month using Equation 2; continued below


8.b) continued from above the calculation of the mass of organic HAP emission reduction each month by emission capture systems and add-on control devices using Equations 3 and 3A through 3D; the calculation of the total mass of organic HAP emissions each month using Equation 4; and the calculation of the 12-month organic HAP emission rate using Equation 5. The Permittee does not need to submit the background data supporting these calculations (e.g., information provided by materials suppliers or manufacturers, or test reports). c. The date and time that each malfunction started and stopped. d. A brief description of the CPMS. e. The date of the latest CPMS certification or audit. f. The date and time that each CPMS was inoperative, except for zero (low-level) and high-level checks. g. The date, time, and duration that each CPMS was out-of-control, including the information in 40 CFR Section 63.8 (c)(8). continued below


8). continued from above h. The date and time period of each deviation from the temperature and air flow limits listed at CE 001; date and time period of any bypass of the add-on control device; and whether each deviation occurred during a period of startup, shutdown, or malfunction or during another period. i. A summary of the total duration of each deviation from the temperature and air flow limits listed at CE 001 and each bypass of the add-on control device during the semiannual reporting period, and the total duration as a percent of the total source operating time during that semiannual reporting period. j. A breakdown of the total duration of the deviations from the temperature and air flow limits listed at CE 001 and bypasses of the add-on control device during the semiannual reporting period into those that were due to startup, shutdown, control equipment problems, process problems, other known causes, and other unknown causes. continued below

40 CFR Sections 63.3920(a)(3), (4) and (7) and 63.3963(0 (satisfies 40 CFR Section 63.5180(g)(2) and (h)); Minn. R. 7011.8090

8). continued from above k. A summary of the total duration of CPMS downtime during the semiannual reporting period and the total duration of CPMS downtime as a percent of the total source operating time during that semiannual reporting period. I. A description of any changes in the CPMS, coating operation, emission captu re system, or add-on control device since the last semiannual reporting period, m. For each deviation from the work practice standards, a description of the deviation, the date and time period of the deviation, and the actions the Permittee took to correct the deviation. AND n. A statement of the cause of each deviation.


Startup, shutdown, malfunction reports. If there is a startup, shutdown, or malfunction during any semiannual reporting period, the Permittee must submit the following reports:

1) If any actions taken were consistent with the SSMP, include the information specified in 40 CFR Section 63.10(d) in the semiannual compliance report listed in Table B of this permit (for GP 006). 2) If any actions taken were NOT consistent with the SSMP, submit the following immediate startup, shutdown, and malfunction reports: - Describe the actions taken during the event in a report delivered by facsimile,

telephone, or other means to the Administrator within 2 working days after starting actions that are inconsistent with the plan; and - Submit a letter to the Administrator within 7 working days after the end of the

event. The letter must contain the information specified in 40 CFR Section 63.10(d)(5)(H).

40 CFR Sections 63.10(d)(5)(ii) and 63.3920(c) (satisfies 40 CFR Section 63.5180(f)); Minn. R. 7011.8090


Permit Number: 05301047 -006 '

A-20 08/11/15

Subject Item: GP 007 Paint Booth Filters

Associated Items: CE 002 Mat or Panel Filter

CE 003 Mat or Panel Filter


Unless otherwise specified, the requirements in GP 007 apply separately to each CE in GP 007.

Minn. R. 7007.0800, subp. 2

EMISSION LIMITS hdr

The Permittee shall operate and maintain the control equipment such that it achieves an overall control efficiency for Total Particulate Matter: greater than or equal to 92 percent control efficiency

Minn. R. 7007.0800, subp. 2

The Permittee shall operate and maintain the control equipment such that it achieves an overall control efficiency for Particulate Matter < 10 micron: greater than or equal to 92 percent control efficiency

Minn. R. 7007.0800, subp. 2

The Permittee shall operate and maintain the panel filters any time that any process equipment controlled by the panel filters is in operation. The Permittee shall document periods of non-operation of the control equipment.

Minn. R. 7007.0800, subps. 2 and 14


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

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

Periodic Inspections: At least once per calendar quarter, or more frequently as required by the manufacturing specifications, the Permittee shall inspect the control equipment components. The Permittee shall maintain a written record of these inspections.

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

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

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

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

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

TABLE A: LIMITS AND OTHER REQUIREMENTS A-21 08/11/15

Facility Name:

Permit Number:

Subject item:

Associated Items:

EDCO Products Inc

05301047-006

EU 008 New NSPS Oven Dryer/Overt, unknown firing method


GP 001 Facility VOC Emissions Limits

GP 002 NSPS Subpart TT Limits


GP 006 Facility-Specific Emission Limit

SV 001 Coating Emissions

What to do Why to do it The Permittee is authorized to install a new oven, EU 008, at any time during the life of this permit. EU 008 shall meet all requirements of this permit (e.g., GP 002) and shall meet the following design requirements: 1. Combust only natural gas or propane, and 2. Have a total capacity of 4.0 MMBtu/hr or less.

Minn. R. 7007.0800, subp. 2

Fuel Recordkeeping: The Permittee shall keep records of fuel combusted on a monthly basis.

Minn. R. 7007.0800, subp. 4 and 5



A-22 08/11/15

Subject Item: EU 014 Makeup Air Unit

What to do Why to do it Total Particulate Matter: less than or equal to 0.40 lbs/million Btu heat input. The potential to emit from the unit is 0.0070 Ib/MMBtu due to equipment design and allowable fuels.

Minn. R. 7011.0515, subp. 1

Opacity: less than or equal to 20 percent opacity except for one six-minute period per hour of not more than 60 percent opacity.

Minn. R. 7011.0515, subp. 2



A-23 08/11/15

Subject Item:

Associated Items:

CE 001

EU 001

EU 002

EU 003

EU 006

m

c

008

GP 001

GP 002

GP 005

MR 001

Direct Flame Afterburner





New NSPS Oven Dryer/Oven, unknown firing method

Facility VOC Emissions Limits

NSPS Subpart TT Limits

Part 63 Subpart SSSS NESHAP

Type K Thermocouple Parametric Monitor

What to do Why to do it The Permittee shall operate and maintain the thermal oxidizer at all times that any emission unit controlled by the thermal oxidizer is in operation. The Permittee shall document periods of non-operation of the control equipment.

Title I Condition: To avoid classification as a major source and modification under 40 CFR Section 52.21 and Minn. R. 7007.3000


The Permittee shall operate and maintain the control equipment such that it achieves an overall control efficiency for Volatile Organic Compounds: greater than or equal to 90.0 percent control efficiency

Title I Condition: To avoid classification as a major source and modification under 40 CFR Section 52.21 and Minn. R. 7007.3000

The Permittee shall operate and maintain the control equipment such that it achieves an overall control efficiency for Total HAPs - Organic: greater than or equal to 90.0 percent control efficiency

Minn. R. 7007.0800, subp. 2

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

Minn. R. 7007.0800, subp. 14

Temperature: greater than or equal to 1190.0 degrees F using 3-hour Block Average at the combustion chamber outlet, unless a new limit is set pursuant to Minn. R. 7017.2025, subp. 3 based on the values recorded during the most recent MPCA-approved performance test where compliance was demonstrated. The new limit shall be implemented upon receipt of the Notice of Compliance letter granting preliminary approval. The limit is final upon issuance of a permit amendment incorporating the change. If the 3-hour block average temperature is below the minimum temperature limit, the VOC and HAP emitted during that time shall be considered uncontrolled until the average temperature is above the minimum temperature limit. This shall be reported as a deviation.

Title I Condition: To avoid classification as a major source and modification under 40 CFR Section 52.21 and Minn. R. 7007.3000; 40 CFR Sections 63.3881(e)(3), 63.3892(b), and 63.3963(c); Minn. R. 7011.8090

Air Flow Rate: greater than 200.0 feet/minute facial velocity of air through all natural draft openings in the enclosure AND the direction of air flow at all times must be into the enclosure.

40 CFR Sections 63.3881(e)(3), 63.3892(b), and 63.3963(c); Minn. R. 7011.8090

If the air flow is below the limit or the air flow direction is not as required, this is a deviation that must be reported as specified by this permit. If an operating parameter deviates from these operating limits, the Permittee must assume that the capture efficiency was zero during the time period of the deviation unless the Permittee has other data indicating the actual efficiency of the capture system and the use of the data is approved by the Administrator.

Total Particulate Matter: less than or equal to 0.30 grains/dry standard cubic foot of exhaust gas unless required to further reduce emissions to comply with the less stringent limit of either Minn. R. 7011.0730 or Minn. R. 7011.0735.

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

Opacity: less than or equal to 20 percent opacity except for one six-minute period per hour of not more than 60 percent opacity.

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

MONITORING AND RECORDKEEPING hdr .

TABLE A: LIMITS AND OTHER REQUIREMENTS A-24 08/11/15 Facility Name: ED CO Products Inc


Temperature Monitoring: The Permittee shall install, calibrate, maintain, and operate temperature monitoring equipment according to manufacturer's specifications. The calibration of the chart recorder, data logger, or temperature indicator must be verified every 3 months; or the chart recorder, data logger, or temperature indicator must be replaced. The Permittee must replace the equipment either if the calibration is not performed, or if the equipment cannot be calibrated properly. Each temperature monitoring device must be equipped with a continuous recorder. The device must have an accuracy of plus or m inus 1 percent of the temperature being monitored in degrees Celsius, or plus or minus 1 degrees Celsius, whichever is greater.

The recording device shall also calculate the three-hour block average combustion chamber temperature. Recorded values outside the range specified in this permit are considered Deviations as defined by Minn. R. 7007.0100, subp. 8a. continued below

Title I Condition: To avoid classification as a major source and modification under 40 CFR Section 52.21 and Minn. R. 7007.3000; 40 CFR Sections 64.3(b)(4)(ii) and 64.7(b); Minn. R. 7017.0200; 40 CFR Section 63.5150(a)(3)(i) and (ii); Minn. R. 7011.7905

continued from above The Permittee must install the thermocouple or temperature sensor in the combustion chamber at a location in the combustion zone.

Title I Condition: To avoid classification as a major source and modification under 40 CFR Section 52.21 and Minn. R. 7007.3000; 40 CFR Sections 64.3(b)(4)(ii) and 64.7(b); Minn. R. 7017.0200; 40 CFR Section 63.5150(a)(3)(i), (ii) and (b); Minn. R. 70117905

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

Title I Condition: To avoid classification as a major source and modification under 40 CFR Section 52.21 and Minn. R. 7007.3000; 40 CFR Section 64.3(b); Minn. R. 7017.0200

The Permittee shall maintain a continuous hard copy readout or computer disk file of the temperature readings and calculated 3-hour block average temperatures for the combustion chamber.

Title I Condition: To avoid classification as a major source and modification under 40 CFR Section 52.21 and Minn. R. 7007.3000; 40 CFR Section 64.9(b); Minn. R. 7017.0200

Air Flow Monitoring System. The Permittee must install, operate, and maintain each Continuous Parameter Monitoring System (CPMS) to measure airflow according to the following requirements: • 1) The CPMS must complete a minimum of one cycle of operation for each successive 15-minute period. The Permittee must have a minimum of four equally spaced successive cycles of CPMS operation in 1 hour; 2) The Permittee must determine the average of all recorded readings for each successive 3-hour period of the emission capture system and add-on control device operation; 3) The Permittee must record the results of each inspection, calibration, and validation check of the CPMS; 4) The Permittee must maintain the CPMS at all times and have available necessary parts for routine repairs of the monitoring equipment; continued below .

40 CFR Section 63.3968(a) (satisfies 40 CFR Section 63.5150(a)(4)), Minn. R. 7011.8090

continued from above 5) The Permittee must operate the CPMS and collect emission capture system parameter data at all times that a controlled coating operation is operating, except during monitoring malfunctions, associated repairs, and required quality assurance or control activities (including, if applicable, calibration checks and required zero and span adjustments); 6) The Permittee must not use emission capture system parameter data recorded during monitoring malfunctions, associated repairs, out-of-control periods, or required quality assurance or control activities when calculating data averages. The Permittee must use all the data collected during all other periods in calculating the data averages for determining compliance with the emission capture system operating limits; AND continued below


continued from above 7) A monitoring malfunction is any sudden, infrequent, not reasonably preventable failure of the CPMS to provide valid data. Monitoring failures that are caused in part by poor maintenance or careless operation are not malfunctions. Any period for which the monitoring system is out-of-control and data are not available for required calculations is a deviation from the monitoring requirements.




Capture Air Flow Monitoring System. The capture system monitoring must comply with the following requirements. For each flo w measurement device, the Permittee must: i) Locate a flow sensor in a position that prov ides a representative flow measurement in the duct from each capture device in the emission capture system to the add-on control device; • ii) Use a flow sensor with an accuracy of at least 10 percent of the flow; iii) Perform an initial sensor calibration in accordance with the manufacturer's requirements; iv) Perform a validation check before initial use or upon relocation or replacement of a sensor. Validation checks include comparison of sensor values with electronic signal simulations or via relative accuracy testing; continued below

40 CFR Section 63.3968(g) (satisfies 40 CFR Section 63.5150(a)(4)), Minn. R. 7011.8090

continued from above v) Conduct an accuracy audit every quarter and after every deviation. Accuracy audit methods include comparisons of sensor values with electronic signal simulations or via relative accuracy testing; vi) Perform leak checks monthly; AND vii) Perform visual inspections of the sensor system quarterly if there is no redundant sensor.

40 CFR Section 63.3968(g) (satisfies 40 CFR Section 63.5150(a)(4)), Minn. R. 7011.8090

Annual Calibration: The Permittee shall calibrate the temperature monitor at least once every 12 months and shall maintain a written record of the calibration and any action resulting from the calibration.


Quarterly Inspections: At least once per calendar quarter, the Permittee shall inspect the control equipment internal and external system components, including but not limited to the refractory, heat exchanger, and electrical systems. The Permittee shall maintain a written record of the inspection and any corrective actions taken resulting from the inspection.


Annual Inspection: At least once per calendar year, the Permittee shall conduct an internal inspection of the control device that includes all operating systems of the control device. The Permittee shall maintain a written record of the inspection and any action resulting from the inspection.


For periods when the thermal oxidizer is operated above the minimum combustion chamber temperature limit and the airflow meets the specified capture system operating limits, the Permittee shall use either one of the following when completing calculations as required elsewhere in this permit (for GP 001): a. The overall control efficiency limit specified in this permit for this equipment (90%); or b. The overall control efficiency determined during the most recent MPCA approved performance test. If the tested efficiency is less than the efficiency limit in this permit, the Permittee must use the tested value in all calculations until the efficiency is demonstrated to be above the permit limit through a new performance test.

Title I Condition: To avoid classification as a major source and modification under 40 CFR Section 52.21 and Minn. R. 7007.3000; Minn. R. 7007.0800, subp. 4 and 5

For time periods when the 3-hour block average temperature is below the minimum combustion chamber temperature limit, this is a deviation.

For VOC, the Permittee shall use "zero" for the control efficiency in the permit calculations listed at GP 001 for all VOC-containing materials used during that time period.

For HAP, the Permittee must assume the control efficiency was zero during the time period of the deviation unless the Permittee has other data indicating the actual control efficiency of the control device and the use of the data is approved by the Administrator.

Title I Condition: To avoid classification as a major source and modification under 40 CFR Section 52.21 and Minn. R. 7007.3000; 40 CFR Section 63.3963(c); Minn. R. 7007.0800, subp. 4 and 5; Minn. R. 7011.809.0

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

40 CFR Section 64.7(d); Minn. R. 7017.0200

Documentation of Need for Improved Monitoring: If the Permittee fails to achieve compliance with an emission limitation or standard for which the monitoring did not provide an indication of an excursion or exceedance while providing valid data, or the results of compliance or performance testing document a need to modify the existing minimum combustion chamber temperature, the Permittee shall promptly notify the MPCA and, if necessary, submit a permit amendment application to address the necessary monitoring changes.

40 CFR Section 64.7(e); Minn. R. 7017.0200



As required by 40 CFR Section 64.9(a)(2), for the Semi-Annual Dev iations Report listed in Table B of this permit and/or the Notification of Deviations Endangering Human Health and the Environment listed earlier in Table A of t his permit, as applicable, the Permittee shall include the following related to the monitoring identified as required by 40 CFR pt. 64: 1) Summary information on the number, duration, and cause of excursions or exceedances, as applicable, and the corrective action taken; and 2) Summary information on the number, duration, and cause for monitor downtime incidents.


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


Performance Test: due before end of each calendar 60 months starting 09/28/2011 to determine VOC control efficiency. The performance test shall be conducted at worst case conditions as defined at Minn. R. 7017.2005, subp. 8, using EPA Reference Method 25A, or other method approved by MPCA in the performance test plan approval.

Testing conducted during the 60 days prior to the performance test due date satisfies the performance test due date, and will not reset the test due date for future testing as required: 1) by this permit; 2) by the most recently approved Performance Test Frequency Plan; or 3) within a Notice of Compliance letter. Testing conducted more than two months prior to the performance test due date satisfies this test due date requirement and will reset the performance test due date.

Minn. R. 7017.2020, subp. 1

TABLE B: SUBMITTALS Facility Name: EDCO Products Inc


B-1 08/11/15

Table B lists most of the submittals required by this permit. Please note that some submittal requirements may appear in Table A or, if applicable, within a compliance schedule located in Table C. Table B is divided into two sections in order to separately list one-time only and recurrent submittal requirements. .

Send submittals that are required to be submitted to the U.S. EPA regional office to:

Chief Air Enforcement Air and Radiation Branch EPA Region V 77 West Jackson Boulevard Chicago, Illinois 60604

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

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

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

Send any application for a permit or permit amendment to:

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

Also, where required by an applicable rule or permit condition, send to the Permit Document Coordinator notices of: - accumulated insignificant activities, - installation of control equipment, - replacement of an emissions unit, and - changes that contravene a permit term.

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

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

TABLE B: ONE TIME SUBMITTALS OR NOTIFICATIONS B-2 08/11/15 Facility Name: EDCO Products inc '


What to send When to send Portion of Facility Affected

Application for Permit Reissuance due 180 days before expiration of Existing Permit

Total Facility

Notification of the Date Construction Began due 30 days after Start Of Construction. The Permittee shall submit emission unit information with the notification using the latest MPCA application forms.

EU008

TABLE B: RECURRENT SUBMITTALS B-3 08/11/15 Facility Name: EDCO Products Inc


What to send When to send Portion of Facility Affected

Quarterly Report due 30 days after end of each calendar quarter following Permit Issuance. The Permittee shall identify, record, and submit a written report to the Commissioner every calendar quarter of each instance in which the volume-weighted average of the local mass of VOCs emitted to the atmosphere per volume of applied coating solids (N) is greater than the limit specified under 40 CFR Section 63.462. If no such instances have occurred during a particular quarter, a report stating this shall be submitted to the Commissioner • semiannually, with the Semiannual Deviations Report listed in Table B of this permit.

GP002

Report due 30 days after end of each calendar half-year following Permit Issuance. The Permittee shall submit reports semiannually when the CE 001 temperature drops as defined under 40 CFR Section 63.464(c). If no such periods occur, the Permittee shall state this in the report. The report shall be submitted with the Semiannual Deviations Report listed in Table B of this permit. '

GP002

Semiannual Compliance Report due 31 days after end of each calendar half-year following Permit Issuance for equipment in GP 006. The report shall contain the information specified in Table A of this permit, under GP 006.

Each semiannual compliance report must cover the semiannual reporting period from January 1 through June 30 or the semiannual reporting period from July 1 through December 31. '

This report may be submitted with the Semiannual Deviations Report also listed in Table B of this permit.

GP006

Semiannual Deviations Report due 30 days after end of each calendar half-year following Permit Issuance. The first semiannual report submitted by the Permittee shall cover the calendar half-year in which the permit is issued. The first report of each calendar year covers January 1 - June 30. The second report of each calendar year ' covers July 1 - December 31. If no deviations have occurred, the Permittee shall submit the report stating no deviations.

Total Facility

Annual Report due 31 days after end of each calendar year following Permit Issuance. The Permittee shall submit an annual report by January 31st that describes the changes made at the facility during the previous calendar year using the latest MPCA application forms. The report shall include the emission unit, stack/vent, group, and control equipment data for any new or replaced units or control devices. The report shall document the VOC 12-month rolling sum calculations for the previous calendar year. The report shall be submitted with the annual Compliance Certification listed in Table B. As part of the Annual Report, the Permittee shall verify and certify that the facility has maintained minor source status for New Source Review.

Total Facility

TABLE B: RECURRENT SUBMITTALS Facility Name: EDCO Products Inc


B-4 08/11/15

Compliance Certification due 31 days after end of ea ch calendar year following Permit Issuance (for the previous calendar year). The Permittee shall submit this on a form approved by the Commissioner, both to the Commissioner and to the US EPA regional office in Chicago. This report covers all deviations experienced during the calendar year.

Total Facility

APPENDIX B Facility Name: EDCO Products, Inc.


New Source Performance Standards Calculations: 40 CFR pt. 60, subp. TT

1.0 Definitions

Coating means any organic material that is applied to the surface of metal coil. Coating application station means that portion of the metal coil surface coating operation where the

coating is applied to the surface of the metal coil. Included as part of the coating application station is the flashoff area between the coating application station and the curing oven.

Curing oven means the device that uses heat or radiation to dry or cure the coating applied to the metal coil.

Finish coat operation means the coating application station, curing oven, and quench station used to apply and dry or cure the final coating(s) on the surface of the metal coil. Where only a single coating is applied to the metal coil, that coating is considered a finish coat.

Metal coil surface coating operation means the application system used to apply an organic coating to the surface of any continuous metal strip with thickness of 0.15 millimeter (mm) (0.006 in.) or more that is packaged in a roll or coil.

Prime coat operation means the coating application station, curing oven, and quench station used to apply and dry or cure the initial coating(s) on the surface of the metal coil.

Quench station means that portion of the metal coil surface coating operation where the coated metal coil is cooled, usually by a water spray, after baking or curing.

VOC content means the quantity, in kilograms per liter of coating solids, of volatile organic compounds (VOCs) in a coating.

Ca = the VOC concentration in each gas stream leaving the control device and entering the atmosphere (parts per million by volume, as carbon).

Cb = the VOC concentration in each gas stream entering the control device (parts per million by volume, as carbon).

Cf = the VOC concentration in each gas steam emitted directly to the atmosphere (parts per million by volume, as carbon).

Dc = density of each coating, as received (kilograms per liter). Dd = density of each VOC-solvent added to coatings (kilograms per liter). Dr = density of VOC-solvent recovered by an emission control device (kilograms per liter). E = VOC destruction efficiency of the control device (fraction). F = the proportion of total VOCs emitted by an affected facility that enters the control device

(fraction). G = volume-weighted average mass of VOCs in coatings consumed in a calendar month per unit

volume of coating solids applied (kilograms per liter). Lc = the volume of each coating consumed, as received (liters). Ld = the volume of each VOC-solvent added to coatings (liters). Lr = the volume of VOC-solvent recovered by an emission control device (liters). Ls = the volume of coating solids consumed (liters). . Md = the mass of VOC-solvent added to coatings (kilograms). M0 = the mass of VOCs in coatings consumed, as received (kilograms). Mr = the mass of VOCs recovered by an emission control device (kilograms). N = the volume-weighted average mass of VOC emissions to the atmosphere per unit volume of

coating solids applied (kilograms per liter).

Appendix B, Page 1



Qa = the volumetric flow rate of each gas stream leaving the control device and entering the atmosphere (dry standard cubic meters per hour).

Qb = the volumetric flow rate of each gas stream entering the control device (dry standard cubic meters per hour).

Qf = the volumetric flow rate of each gas steam emitted directly to the atmosphere (dry standard cubic meters per hour).

R = the overall VOC emission reduction achieved for an affected facility (fraction). S = the calculated monthly allowable emission limit (kilograms of VOC per liter of coating solids

applied). Vs = the proportion of solids in each coating, as received (fraction by volume). W0 = the proportion of VOCs in each coating, as received (fraction by weight).

Other terms are as defined in 40 CFR pt. 60, subp. A or TT or are as defined in state air pollution control rules.

2.0 Calculations

As required by Table A of this permit, the Permittee shall complete the calculations detailed in this Appendix A.

The Permittee shall calculate the monthly volume-weighted average emissions of VOCs in kg/I of coating solids applied using the following procedures:

(A) Determine the overall reduction efficiency (R) for the capture system and control device. For the initial performance test, the overall reduction efficiency (R) shall be determined as prescribed in this Appendix A. In subsequent months, the Permittee may use the most recently determined overall reduction efficiency (R) for the performance test, providing control device and capture system operating conditions have not changed (including the 3-hour rolling average temperature from the initial performance test). The procedure in this section of Appendix A shall be repeated when directed by the Commissioner or when the Permittee elects to operate the control device or capture system at conditions different from the initial performance test.

(1) Determine the fraction (F) of total VOCs emitted by an affected facility that enters the control device using the following equation:

/

F = 1=1

/ p Equation 5

Where: I is the number of gas streams entering the control device, and p is the number of gas streams emitted directly to the atmosphere.

Appendix B, Page 2



(2) Determine the destruction efficiency of the control device (E) using values of the volumetric flow rate of each of the gas streams and the VOC content (as carbon) of each of the gas streams in and out of the device by the following equation:

n m

E = i=\ /=!

Equation 6 ^bi^bi

i-1

Where: n is the number of gas streams entering the control device, and m is the number of gas streams leaving the control device and entering the atmosphere.

The Permittee shall construct the VOC emission reduction system so that all volumetric flow rates and total VOC emissions can be accurately determined by the applicable test methods and procedures specified in 40 CFR § 60.466. The Permittee shall construct a temporary enclosure around the coating applicator and flashoff area during the performance test for the purpose of evaluating the capture efficiency of the system. The enclosure must be maintained at a negative pressure to ensure that all VOC emissions are measurable. If a permanent enclosure exists in the affected facility prior to the performance test and the Commissioner is satisfied that the enclosure is adequately containing VOC emissions, no additional enclosure is required for the performance test.

(3) Determine overall reduction efficiency (R) using the following equation:

A — H,r Equation 7

If the overall reduction efficiency (R) is equal to or greater than 0.90, the affected facility is in compliance and no further computations are necessary. If the overall reduction efficiency (R) is less than 0.90, the average total VOC emissions to the atmosphere per unit volume of coating solids applied (N) shall be computed as follows.

(B) Calculate the volume-weighted average of the total mass of VOCs per unit volume of coating solids applied (G) during each calendar month for each affected facility using equations in 40 CFR § 60.463(c)(l)(i) (A), (B), and (C).

(C) Calculate the volume-weighted average of VOC emissions to the atmosphere (N) during each calendar month by the following equation:

N — G(\ ~ R) Equation 8

Appendix B, Page 3



(D) If the volume-weighted average mass of VOCs emitted to the atmosphere for each calendar month (N) is less than or equal to 0.14 kg/I of coating solids applied, the affected facility is in compliance. Each monthly calculation is a performance test.

Appendix B, Page 4

APPENDIX C Facility Name: EDCO Products, Inc.


40 CFR PT. 63, SUBP. MMMM COMPLIANCE EQUATIONS

All equation numbers correspond to the equation numbers used in 40 CFR pt. 63, subp. MMMM.

EQUATION 1 (Equation 1 from 40 CFR § 63.3951)

He = A + B + C -Rw

Where:

He = Total mass of organic HAP emissions during the month, kg.

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

B - Total mass of organic HAP in the thinners and/or other additives used during the month, kg, as calculated in Equation IB.

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

Rw = Total mass of organic HAP in waste materials sent or designated for shipment to a hazardous waste TSDF for treatment or disposal during the month, kg, determined according to 40 CFR § 63.3951(e)(4). (The Permittee may assign a value of zero to Rw if the Permittee does not wish to use this allowance.)

EQUATION 1A (Equation 1A from 40 CFR § 63.3951)

m A = YJyVolc,ifDc,^Wc,) '

i=i

Where:

A - Total mass of organic HAP in the coatings used during the month, kg.

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

Dcj = Density of coating, i, kg coating per liter coating.

Appendix C, Page 1



WCii - Mass fraction of organic HAP in coating, i, kg organic HAP per kg coating. For reactive adhesives as defined in 40 CFR § 63.3981, use the mass fraction of organic HAP that is emitted as determined using the method in appendix A to 40 CFR pt. 63, subp. PPPP.

m - Number of different coatings used during the month.

EQUATION IB (Equation IB from 40 CFR § 63.3951)

7=1

Where:

B - Total mass of organic HAP in the thinners and/or other additives used during the month, kg.

Volt/j = Total volume of thinner and/or other additive, j, used during the month, liters.

Dt/j - Density of thinner and/or other additive, j, kg per liter.

WtJ = Mass fraction of organic HAP in thinner and/or other additive, j, kg organic HAP per kg thinner and/or other additive. For reactive adhesives as defined in 40 CFR § 63.3981, use the mass fraction of organic HAP that is emitted as determined using the method in appendix A to 40 CFR pt. 63, subp. PPPP.

n = Number of different thinners and/or other additives used during the month.

EQUATION 1C (Equation 1C from 40 CFR § 63.3951)

C = ̂ (Vols, k̂ yDsJ^Ws, k) k=1

Where:

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

VolS/k - Total volume of cleaning material, k, used during the month, liters.

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

Appendix C, Page 2



WS/k - Mass fraction of organic HAP in cleaning material, k, kg organic HAP per kg material.

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


m Vs, =

(=1

Where:

l/st = Total volume of coating solids used during the month, liters.

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

Vsj = Volume fraction of coating solids for coating, i, liter solids per liter coating, determined according to 40 CFR § 63.3941(b).

m = Number of coatings used during the month.

EQUATION 3 (Equation 1 from 40 CFR § 63.3961) CF DRF

He = (Ac + Be + Cc - Rw - HUNC)X(—-— X 100 100

Where:

Hc = Mass of organic HAP emission reduction for the controlled coating operation during the month, kg-

Ac = Total mass of organic HAP in the coatings used in the controlled coating operation during the month, kg, as calculated in Equation 3A.

Bc = Total mass of organic HAP in the thinners and/or other additives used in the controlled coating operation during the month, kg, as calculated in Equation 3B.

Cc = Total mass of organic HAP in the cleaning materials used in the controlled coating operation during the month, kg, as calculated in Equation 3C.

Rw = Total mass of organic HAP in waste materials sent or designated for shipment to a hazardous waste TSDF for treatment or disposal during the compliance period, kg, determined according to 40 CFR § 63.3951(e)(4). (The Permittee may assign a value of zero to Rw if you do not wish to use this allowance.)

Appendix C, Page 3



HUNC = Total mass of organic HAP in the coatings, thinners and/or other additives, and cleaning materials used during all deviations specified in 40 CFR § 63.3963(c) and (d) that occurred during the month in the controlled coating operation, kg, as calculated in Equation 3C.

CE = Capture efficiency of the emission capture system vented to the add-on control device, percent. Use the test methods and procedures specified in 40 CFR §§ 63.3964 and 63.3965 to measure and record capture efficiency.

DRE = Organic HAP destruction or removal efficiency of the add-on control device, percent. Use the test methods and procedures in 40 CFR §§ 63.3964 and 63.3966 to measure and record the organic HAP destruction or removal efficiency.

EQUATION 3A (Equation 1A from 40 CFR § 63.3961) m

Ac = ^ {Vole, l\Dc, ifWc, i) /=i

Where:

Ac = Total mass of organic HAP in the coatings used in the controlled coating operation during the month, kg.

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

DC/) = Density of coating, i, kg coating per liter coating.

WC/I- Mass fraction of organic HAP in coating, i, kg organic HAP per kg coating. For reactive adhesives as defined in 40 CFR § 63.3981, use the mass fraction of organic HAP that is emitted as determined using the method in appendix A to 40 CFR pt. 63, subp. PPPP.

m = Number of different coatings used during the month.

EQUATION 3B (Equation IB from 40 CFR § 63.3961)

Be = £(FO/,,/XA,.,X^,/) M

Where:

Bc = Total mass of organic HAP in the thinners and/or other additives used in the controlled coating operation during the month, kg.

Appendix C, Page 4



VoltJ = Total volume of thinner and/or other additive, j, used during the month, liters.

Dy = Density of thinner and/or other additive, j, kg per liter.

WtJ - Mass fraction of organic HAP in thinner and/or other additive, j, kg organic HAP per kg thinner and/or other additive. For reactive adhesives as defined in 40 CFR § 63.3981, use the mass fraction of organic HAP that is emitted as determined using the method in appendix A to 40 CFR pt. 63, subp. PPPP. .

n = Number of different thinners and/or other additives used during the month.

EQUATION 3C (Equation 1C from 40 CFR § 63.3961)

Cc = ^(Vols,k\Ds,k)iWs,k) . k=\

Where:

Cc = Total mass of organic HAP in the cleaning materials used in the controlled coating operation during the month, kg.

VolS/k - Total volume of cleaning material, k, used during the month, liters.

Ds k - Density of cleaning material, k, kg per liter.

WS/k - Mass fraction of organic HAP in cleaning material, k, kg organic HAP per kg material.

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

EQUATION 3D (Equation ID from 40 CFR § 63.3961)

HUNC = h=1

Where: .

HUNC= Total mass of organic HAP in the coatings, thinners and/or other additives, and cleaning materials used during all deviations specified in §63.3963(c) and (d) that occurred during the month in the controlled coating operation, kg.

Volh= Total volume of coating, thinner and/or other additive, or cleaning material, h, used in the controlled coating operation during deviations, liters.

Appendix C, Page 5



Dh= Density of coating, thinner and/or other additives, or cleaning material, h, kg per liter.

Wh= Mass fraction of organic HAP in coating, thinner and/or other additives, or cleaning material, h, kg organic HAP per kg coating. For reactive adhesives as defined in 40 CFR § 63.3981, use the mass fraction of organic HAP that is emitted as determined using the method in appendix A to subpart PPPP of this part.

q = Number of different coatings, thinners and/or other additives, and cleaning materials used.


HHAP = Total mass of organic HAP emissions for the month, kg.

He = Total mass of organic HAP emissions before add-on controls from all the coatings, thinners and/or other additives, and cleaning materials used during the month, kg, determined according to 40 CFR § 63.3961(f).

Hc,i = Total mass of organic HAP emission reduction for controlled coating operation, i, not using a liquid-liquid material balance, during the month, kg, from Equation 3.

HCSRJ = Total mass of organic HAP emission reduction for coating operation, j, controlled by a solvent recovery system using a liquid-liquid material balance, during the month, kg, from Equation 3 of 40 CFR § 63.3961.

q = Number of controlled coating operations not controlled by a solvent recovery system using a liquid-liquid material balance.

r = Number of coating operations controlled by a solvent recovery system using a liquid-liquid material balance.


Where:

n

Hannual n

2>.,

Appendix C, Page 6



Where:

Hannuai = Organic HAP emission rate for the compliance period, kg organic HAP emitted per liter coating solids used.

HHAP,V = Organic HAP emissions for month, y, kg, determined according to Equation 4.

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

y = Identifier for months.

n = Number of full or partial months in the compliance period (for the initial compliance period, n equals 12 if the compliance date falls on the first day of a month; otherwise n equals 13; for all following compliance periods, n equals 12).

Appendix C, Page 7

APPENDIX D Facility Name: EDCO Products, Inc.


Insignificant Activities and General Applicable Requirements

The table below lists the insignificant activities that are currently at the Facility and their associated general applicable requirements.

Minn. R. 7007.1300,

subp. Rule Description of the Activity Applicable Requirement

3(B) Infrared electric ovens Minn. R. 7011.0715

3(G) Emissions from a laboratory, as defined in the subpart. Minn. R. 7011.0515 + Minn. R. 7011.0610 + Minn. R. 7011.0715

3(H)(3) Brazing, soldering, or welding equipment. Minn. R. 7011.0515 + Minn. R. 7011.0610 + Minn. R. 7011.0715

3(H)(7) Cleaning operations: alkaline/phosphate cleaners and associated cleaners and associated burners.

Minn. R. 7011.0515 + Minn. R. 7011.0610 + Minn. R. 7011.0715

3(1) Individual emission units at a stationary source, each of which have a potential to emit the following pollutants in amounts less than:

(1) 4,000 pounds per year of carbon monoxide;

(2) 2,000 pounds per year each of nitrogen oxide, sulfur dioxide, particulate matter, particulate matter less than ten microns, VOCs (including hazardous air pollutant-containing VOCs), and ozone; and

(3) 1,000 tons per year of C02e.

EDCO has a total of 55 natural gas combustion units under this subpart with a total capacity of 16.4 MMBtu/hr.

Minn. R. 7011.0515

or Minn. R. 7011.0610

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

Minn. R. 7011.0715

4 Individual emissions units at a stationary source, each of which has:

A. Potential emissions of 5.7 pounds per hour or actual emissions of two tons per year of carbon monoxide;

Minn. R. 7011.0715 or Minn. R. 7011.2300

Appendix D, Page 1

APPENDIX D Facility Name: EDCO Products, Inc.


Minn. R. 7007.1300,

subp. Rule Description of the Activity Applicable Requirement

B. Potential emissions of 2.28 pounds per hour or actual emissions of one ton per year for particulate matter, particulate matter less than ten microns, nitrogen oxide, sulfur dioxide, and VOCs;

C. For hazardous air pollutants, emissions units with:

(1) potential emissions of 25 percent or less of the hazardous air pollutant thresholds listed in subp. 5; or

(2) combined HAP actual emissions of one ton per year unless the emissions unit emits one or more of the HAPs listed in this subpart; AND

D. Potential emissions up to 10,000 tons per year or actual emissions up to 1,000 tons per year of C02e.

EDCO has a cooling tower and an emergency generator with a heat input capacity of 0.32 MMBtu/hr under this subpart. .

Appendix D, Page 2

APPENDIX E Facility Name: EDCO Products, Inc.


Maximum Contents of Materials and Process Parameters

The tables below give the maximum materials contents and process design parameters used by the Permittee in calculating potential to emit for coil coating and spray booths. These values are not limits; however, changing to a material that has a higher VOC or solids content, or increasing the usage/application rate, is considered a change in method of operation that must be evaluated under Minn. R. 7007.1200, subp. 3 to determine if a permit amendment or notification is required under Minn R. 7007.1150. This list is not exhaustive; it generally includes emission units with a VOC or PM emission rate of over 1 Ib/hr before applying additional emission factors (e.g. mixing emission factors). .

Coil Coating

Table A: Coil Coating Maximum Material Contents

Emission Unit Line Speed (sq. ft/hr) Coverage (sq.

ft/gal) HAPs Content (lb/gal)

EU 001/006 .

Primer Coater1,2 21487.5 1453 2.7

Backer Coater1,2 21487.5 1212 0.58

EU 002/003

Topcoater1 21487.5 761.7 4.51

Emission Unit VOC Content (lb/gal) Density (lb/gal)

EU 001/006

Primer Coater1,2 8.33 12.48

Backer Coater1,2 4.45 15.12

EU 002/003

Topcoater1 5.28 12.6

1 Per AP-42, 5th Edition, Section 4.2.2.10, coating lines themselves estimated to emit only 10% of calculated PTE, ovens estimated to emit remaining 90% 2 Emission Unit 1 is split into two units, the primer and the backer. To obtain the total PTE, these are added.

Appendix E, Page 1



Spray Booths

Table B: Spray Booth Common Factors

Emission Unit Production Rate (shingles/hour)

Shingle Area (sq. ft)

Overspray (%) Gal MEK/Gal Paint

EU010 Paint Booth 1 553 2.083 25 4.00 EU012 Paint Booth 2 553 1.018 25 4.00

Table C: Spray Booth VOC Maximum Contents Emission Unit Coverage (sq. ft/gal)1 VOC Contents (lb/gal) MEK VOC Content (lb/gal)

EU010 Paint Booth 1 3427.5 4.58 7.00 EU012 Paint Booth 2 3427.5 4.58 7.00

Table D: Spray Boot h HAP Maximum Contents

Emission Unit VOC Contents

(lb/gal) Density (lb/gal) VHAPS (%) Coverage (sq. ft/gal)1

EU010 Paint Booth 1 4.4 10.5 35.81 3427.5 EU012 Paint Booth 2 4.4 10.5 35.81 3427.5

Table E: Spray Booth PM PTE Maximum Contents

Emission Unit Coverage (sq. ft/gal)1 Density (lb/gal) Solids (%)

EU010 Paint Booth 1 3641.3 11.2 100 EU012 Paint Booth 2 3667.5 11.1 100

Table F: Spray Booth Meta lie HAP Maximum Contents

Emission Unit % Weight Metallic HAPs Solids (%) Coverage (sq.

ft/gal)1 Density (lb/gal) EU010 Paint Booth 1 15.06 63 3641.3 11.2 EU012 Paint Booth 2 15.06 63 3667.5 11.1

1 The coverage was calculated by multiplying the coverage value listed in the MSDS by the thickness listed in the MSDS and dividing by the applied thickness.

Volatile HAPs Content

Table G: Top Three Individual HAPs Maximum Contents

HAP Weight Percent EU010/012 Coverage

(sq. ft/gal) EU010/012 Density

(lb/gal) Xylene 33.2 762.0 10.92

Toluene 29.9 762.0 10.92 Isophorone 25.81 762.0 10.92

Appendix E, Page 2



Appendix E, Page 3

TECHNICAL SUPPORT DOCUMENT For

AIR EMISSION PERMIT NO. 05301047-006

This technical support document (TSD) is intended for all parties interested in the permit and to meet the requirements that have been set forth by the federal and state regulations (40 CFR § 70.7(a)(5) and Minn. R. 7007.0850, subp. 1). The purpose of this document is to provide the legal and factual justification for each applicable requirement or policy decision considered in the preliminary determination to issue the permit.

1. General Information

1.1 Applicant and Stationary Source Location

Table 1. Applicant and Source Address

Applicant/Address Stationary Source/Address

(SIC Code: 3479) EDCO Products, Inc. 8700 Excelsior Blvd Hopkins Hennepin County, Minnesota 55343

EDCO Products, Inc. . 8700 Excelsior Blvd Hopkins Hennepin County, Minnesota 55343

Contact: Michael Bergeson Phone: 952-945-2640

1.2 Facility Description EDCO Products, Inc. (the Facility) is the single largest manufacturer of residential steel roofs and siding in the U.S. Edco consists of a manufacturing and a distribution arm. The manufacturing process consists of roll coaters where aluminum and steel coils are coated and then dried in one of three curing ovens. The emissions from these operations are controlled with a thermal oxidizer. The Facility also has two spray booths that apply coatings to metal shingles followed by two curing ovens. The main emissions consist of volatile organic compounds (VOC), hazardous air pollutants (HAP), and particulate matter (PM). The Facility has several smaller sources that qualify as insignificant activities under Minn. R. 7007.1300, subp. 3 and 4. These are described in Appendix D of this permit.

The distribution arm distributes Edco's products directly to contractors and through two and three step distribution channels. The distribution arm also assembles sales demonstration kits that are sold to distributors and contractors. These kits consist of siding and shingle samples as well as color slips to assist customers in making the proper product selections.

1.3 Description of the Activities Allowed by this Permit Action This permit action is the reissuance of the Part 70 operating permit. It also authorizes a lower minimum operating temperature limit for the direct flame afterburner due to new performance testing results.

1.4 Facility Emissions

Table 2. Total Facility Potential to Emit Summary

Technical Support Document, Permit Action Number: 05301047-006 Page 1 of 15

PM tpy

PM10

tpy PM2.5 tpy

so2 tpy

NOx

tpy CO tpy

C02e tpy

VOC tpy

Single HAP tpy

All HAPs tpy

Total Facility Limited Potential Emissions

1.19 1.19 1.19 0.05 7.60 6.38 9118 225.0 153.27 159.57

Total Facility Actual Emissions (2012)

0.01 0.01 0.01 0.01 1.19 1.00 * 3.91 *

*Not reported in MN emission inventory.

Table 3. Facility Classification Classification Major/Affected Source Synthetic Minor/Area Minor/Area

PSD X Part 70 Permit Program X Part 63 NESHAP X

1.5 Changes to Permit The permit does not authorize any specific modifications, however, the MPCA has a combined operating and construction permitting program under Minnesota Rules Chapter 7007, and under Minn. R. 7007.0800, the MPCA has authority to include additional requirements in a permit. Under that authority, the following changes to the permit are also made through this permit action:

• The permit has been updated to reflect current MPCA templates and standard citation formatting.

• Completed requirements and the requirements for equipment that has been removed have been deleted.

• Some requirements have been reordered to help with clarity (i.e., similar requirements are grouped).

• The required minimum operation temperature of CE 001 has been reduced from 1317 degrees F to 1190 degrees F to account for the results of the most recent MPCA-approved stack test.

• Removed EU007 and EU009 from the permit. EU007 is non-operational and has no potential emissions. EU009 was never installed and will never be installed in the future. These were left in the previous permit as potential additions. Removed SV 004, which was only used for EU 009.

• The total facility VOC limit has been lowered from 240 tons per year to 225 tons per year to leave a larger margin with the federal threshold for a major source under Part 70.

• The 'Maximum Contents of Materials and Process Parameters' appendix (Appendix E) has been significantly reworked to account for new calculation methods and paints.

• Added PTE data for several new HAPs as well as greenhouse gases and PM2.s in Delta. • Altered language in the permit to allow credit for VOC-containing waste. • Due to a change in Minn. R. 7007.1300, subp. 3(B)(2) that placed a maximum combined capacity

on units falling in this category, air makeup unit EU 014 is no longer considered an insignificant activity and has been added to the permit.

• Due to the change in Minn. R. 7007.1300, subp. 3(B)(2) above and for simplicity, several units considered insignificant activities have been moved to Minn. R. 7007.1300, subp. 3(1).

2. Regulatory and/or Statutory Basis

New Source Review (NSR)


The facility has taken a facility wide emission limit of 225.0 tons per year of VOCs to maintain status as a NSR non-major source. Greenhouse gas emission calculations have been added to the permit, but are well below NSR thresholds. Therefore, the facility remains an existing minor source under NSR.

No changes are authorized by this permit.

Part 70 Permit Program The facility remains a major source under the Part 70 permit program.

New Source Performance Standards (NSPS) Portions of the facility operations (EUs 001-006 and EU008 if installed) are subject to the NSPS for Metal Coil Surface Coating (40 CFR pt. 60, subp. TT).

National Emission Standards for Hazardous Air Pollutants (NESHAP) Portions of the facility are subject to the NESHAPs for Surface Coating of Metal Coil (40 CFR pt. 63, subp. SSSS) and for Surface Coating of Miscellaneous Metal Parts and Products (40 CFR pt. 63, subp. MMMM). The facility has chosen to comply with both standards using a facility-specific emission limit (see section 3.2 below). The facility is considered a major source under 40 CFR pt. 63.

Compliance Assurance Monitoring (CAM) The Facility has several coating and oven units (EUs 001-003 and EU 006) that are subject to CAM (40 CFR pt. 64). A thermal oxidizer (CE 001) is used to control emissions from EUs 001-003 and EU 006 to comply with both a total facility VOC limit to avoid PSD and 40 CFR pt. 60, subp. TT. Post control potential emissions for VOCs are under 100 tpy, so the emission units are not considered large. For PSEUs that are not large, records of the monitored parameters must be made at a minimum of once per 24 hours. See Attachment 5 for the Facility's CAM plan.

The paint booths have control equipment for particulate matter that is used to comply with an emissions limit or standard, but the pre-control potential emissions are less than 100 tpy; therefore, CAM does not apply to these emission units.

Environmental Review & Air Emissions Risk Analysis (AERA) There are no changes authorized that would trigger the need for an Environmental Assessment Worksheet (EAW) or an Air Emissions Risk Analysis (AERA).

Minnesota State Rules Portions of the facility are subject to Minn. R. 7011.0610 (Standards of Performance for Fossil-Fuel-Burning Direct Heating Equipment) and/or Minn. R. 7011.0715 (Standards of Performance for Post-1969 Industrial Process Equipment).

Table 4. Regulatory Overview of Facility

Subject Item* Applicable Regulations Rationale



GP 001 (VOC Usage Limits)

40 CFR §52.21 Minn. R. 7007.3000

Prevention of Significant Deterioration (PSD). Limits taken to avoid major source classification under PSD for all non-combustion emissions of VOC. It is a rolling limit due to substantial and unpredictable variations in operation.

The limit is written as a PreCap. It limits all non-combustion VOC emissions (other than those listed in Appendix D of the permit) regardless of whether they are existing, modified, or new. If the Permittee wishes to make changes to these units in the future, the changed equipment would continue to be subject to these requirements.

This permit also continues to pre-authorizes the replacement of one unit and the installation of a new curing oven. This authorization was originally provided in permit 05301047-001.

GP 002 (NSPS)

40 CFR pt. 60, subp. TT; Minn. R. 7011.2570

New Source Performance Standard for Metal Coil Surface Coating. The Permittee complies by using a thermal oxidizer.

GP 003

(NESHAP subp. MMMM)

40 CFR pt. 63, subp. MMMM; Minn. R. 7011.8090

NESHAP for Surface Coating of Miscellaneous Metal Parts and Products. The equipment defined under this category is listed in this group as well as general requirements about applicability of the standard.

The units in GP 003 (paint booths EU 010 and EU 012, ovens EU 011 and EU 013) are considered a new affected source that applies general use coatings. Because the Permittee has chosen to comply by using the Facility-Specific Emission Limit (FSEL) allowed in 40 CFR § 63.3881(e)(3) (see Section 3.2 of this TSD for more discussion), all of the limits and compliance requirements that apply to the combined activities are listed at GP 006. The permit includes the emission rate with add-on controls option (at GP 006 and CE 001).

GP004

(Paint Booths and Cure Ovens)

Minn. R. 7011.0715

Minn. R. 7007.0800, subp. 2

Standards of Performance for Post 1969 Industrial Process Equipment.

Particulate Controls. The permit requires that the paint booths be vented to panel filters meeting requirements 1-7 of GP 007. The unlimited particulate PTE of the paint booths is minor for NSR, so the basis of the limit is to limit the PTE (not to avoid NSR). The limits are written to apply to all existing, new, or modified units. This allows the control requirements (at GP 007) to be considered when determining if future changes require a permit amendment based on the emissions increase.

Total Enclosure. The Permittee assumed that the paint booths had total enclosures for determining the controlled PTE of the particulate emissions. The permit includes a requirement to operate and maintain the total enclosures.



GP 005

(NESHAP subp. SSSS)

40 CFR pt. 63, subp. SSSS; Minn. R. 7011.7905

NESHAP for Surface Coating of Metal Coil. The equipment defined under this category is listed in this group as well as general requirements about applicability of the standard.

The units in GP 005 are considered an existing affected source; however, because the Permittee has chosen to comply by using the Facility-Specific Emission Limit (FSEL) allowed in 40 CFR § 63.3881(e)(3) under 40 CFR pt. 63, subp. MMMM (see Section 3.2 of this TSD for more discussion), all of the limits and compliance requirements that apply to the combined activities are listed at GP 006. Prior to becoming subject to 40 CFR pt. 63, subp. MMMM (early 2008), the Permittee complied with 40 CFR pt. 63, subp. SSSS by using a thermal oxidizer. The Permittee will continue to use this oxidizer to comply with the FSEL in GP 006.

GP 006

(FSEL)

40 CFR pt. 63, subp. MMMM -FSEL; Minn. R. 7011.8090

Facility-Specific Emission Limit Requirements from 40 CFR pt. 63, subp. MMMM. Permit includes the requirements for the emission rate with add-on controls, specifically for a thermal oxidizer with a total enclosure.

GP 007 (Paint Booth Filters)

Minn. R. 7007.0800, subp. 2 Control efficiency and other requirements to limit PM/PM10 PTE. Reflects total enclosure. Permit specifies that new, replaced, or modified panel filters must meet the GP 007 requirements.

EU 008

(Oven)

Minn. R. 7007.0800, subp. 2 Authorization to install a new oven that combusts natural gas or propane. This is carried over from the previous permit. The emissions increase from the new oven is minor for NSR (see PTE calculations in Attachment 1).

EU 014 (Air Makeup Unit)

Minn. R. 7011.0715 Standards of Performance for New Indirect Heating Equipment EU 014 (Air Makeup Unit)

CE 001

(Thermal Oxidizer)

40 CFR § 52.21; 40 CFR pt. 60, subp. TT; Minn. R. 7007.3000; and Minn. R. 7011.2570

PSD and NSPS. Control efficiency and other operating parameter requirements to limit VOC PTE to avoid major source classification under PSD. Limits are based on NSPS requirements listed at GP 002 with some additional monitoring and recordkeeping.

40 CFR pt. 63, subp. MMMM; Minn. R. 7011.8090

FSEL Requirements from 40 CFR pt. 63, subp. MMMM. By choosing to comply using this option, the oxidizer must meet all emissions limitations from this standard which include the temperature and capture efficiency limits from 40 CFR pt. 63, subp. MMMM. See Section 3.2 for more discussion.

40 CFR pt. 64; Minn. R. 7017.0200-

Compliance Assurance Monitoring (CAM). The thermal oxidizer is used to comply with the NSPS as well as the VOC cap, and the uncontrolled potential and post-control potential from the coil coaters is greater than 100 tpy, so CAM applies and the units are considered large PSEUsforVOC.

Minn. R. 7011.0610 Minnesota Standard of Performance for Direct Heating Equipment. Natural gas only.


*Location of the requirement in the permit (e.g., EU, SV, GP, etc.).

3. Technical Information

3.1 Calculations of Potential to Emit Attachment 1 to this TSD contains Form GI-07, which summarizes the PTE of the Facility, while Attachment 3 contains detailed spreadsheets and supporting information prepared by the MPCA and the Permittee. Attachment 3 includes the sources of the emission rates other than those obtained from MSDSs or emission unit specifications. Below is a detailed explanation of how emissions for the coating lines and spray booths were calculated.

Coil Coating The VOC emissions for the coil coating lines was calculated by dividing the line speed by the coverage and then multiplying by the VOC content, the permitted control destruction/removal efficiency, and the fraction emitted from the given unit (90% for oven, 10% for the coater).

The HAP emissions for the coil coating lines was calculated by dividing the line speed by the coverage and then multiplying by the HAP content, the permitted control destruction/removal efficiency (currently 90%), and the fraction emitted from the given unit (90% for oven, 10% for the coater). The total HAP PTE was determined separately from the individual HAP PTE values, so the total HAPs emitted is much lower than the sum of the individual HAPs.

Table A of Appendix E contains all values used in these calculations.

Spray Booths • VOC PTE Calculations:

VOC PTE values were calculated by multiplying the shingle area by the extra paint used from overspray before multiplying by the VOC contents, and dividing by the coverage. The Methyl Ethyl Ketone (MEK) was calculated using a similar method with the MEK/Paint ratio along with the MEK VOC content and then added to produce the final VOC emission factor. Multiplying this emission factor by the production rate produces the PTE for the facility. Tables B and C of Appendix E were used for these calculations.

• HAP PTE Calculations: HAP PTE values were determined by dividing the value calculated in the VOC section above by the VOC contents and then multiplying by both the density and Volatile HAPs (VHAPs) values in Table D. Note that this includes the MEK above, which produces a much higher HAP emission rate than the actual PTE. Multiplying this emission factor by the production rate produces the PTE for the facility. Tables B and D of Appendix E were used for these calculations. The total HAP PTE was determined separately from the individual HAP PTE values, so the total HAPs emitted is much lower than the sum of the individual HAPs.

• PMio and PM2.5 PTE Calculations:


Particulate matter PTE values were determined by dividing the shingle area by the coverage value before multiplying by the density, accounting for additional paint due to overspray, and then discounting the paint that is not considered overspray (which is not considered in PM calculations for spray booths). This calculation assumes the paint is 100% solids (that is, it is very conservative). Multiplying this emission factor by the production rate produces the PTE for the facility. PM2.5 emissions were assumed to be the same as PMi0 emissions, a conservative estimate. Tables B and E of Appendix E were used for these calculations.

• Metallic HAP PTE Calculations: Metallic HAP PTE values were determined by dividing the emission factor from the PM calculations above by the percent solids of the worst-case paint before multiplying by the percent weight of metallic HAP. Multiplying this emission factor by the production rate produces the PTE for the facility. Tables B and F of Appendix E were used for these calculations.

Volatile HAPs Content Table G of Appendix E lists the three individual HAPs with the highest potential to emit at EDCO. These weight percentages were used in all emission units to determine the potential to emit of each individual HAP.

For the coil coating lines, these were calculated using the density, line speed, and coverage values from Table A of Appendix E along with the weight percent values in Table G. Like above, it was assumed the ovens emit 90% of the total PTE and the coaters emit the remaining 10%.

For the spray booth lines, HAP PTE values were calculated by multiplying the weight percentage and density from Table G, multiplying by the area of the shingle, and then dividing by the coverage from Table B.

3.2 NESHAP Requirements

Applicability of Limits The Facility is an existing affected source under 40 CFR pt. 63, subp. SSSS because of the existing two coil coating lines. The facility is also a new affected source under 40 CFR pt. 63, subp. MMMM for two spray booths. The coil coating lines and spray booths are subject to two different standards; however, under 40 CFR pt. 63, subp. MMMM, the Permittee can choose to comply with a new combined limit - a facility-specific emission limit (FSEL) - for ALL affected sources under the two subparts. This requires the Permittee to calculate a new limit each month based on the actual proportions of coatings used that month and then demonstrate compliance with that combined limit. This allows averaging between the different units which gives this facility more flexibility because the 40 CFR pt. 63, subp. SSSS units are controlled with a thermal oxidizer.

In addition, per 40 CFR pt. 63, subp. MMMM, the Permittee must comply with the FSEL as well as "the emissions limitations" in 40 CFR pt. 63, subp. MMMM for all equipment subject to the FSEL. Emission limitation is defined in 40 CFR § 63.3981 to include "all requirements associated with a compliance


option including emission limit, operating limit, work practice standard, etc." This has the effect of making the 40 CFR pt. 63, subp. SSSS equipment subject to the work practice requirements of 40 CFR pt. 63, subp. MMMM and the controls used on the 40 CFR pt. 63, subp. SSSS equipment subject to the control equipment operating limits of 40 CFR pt. 63, subp. MMMM.

Streamlined Monitoring, Recordkeeping, and Reporting Some of the 40 CFR pt. 63, subp. SSSS equipment is subject to emission limitations from 40 CFR pt. 63, subp. MMMM that do not have corresponding monitoring requirements in 40 CFR pt. 63, subp. SSSS. In these instances, the monitoring, recordkeeping, and reporting from 40 CFR pt. 63, subp. MMMM have been included in the permit as applying to the 40 CFR pt. 63, subp. SSSS equipment (at both GP 006 and CE 001) as required due to the definition of "emission limitation".

In addition, there is some overlap in the compliance requirements. For example, both standards have similar, but different, temperature and capture system monitoring requirements for the controls. For each such requirement, the MPCA reviewed them and either:

• included the 40 CFR pt. 63, subp. SSSS requirements if they yielded adequate data to ensure compliance with the 40 CFR pt. 63, subp. MMMM limitations (e.g., the temperature monitoring); OR

• included the 40 CFR pt. 63, subp. MMMM requirements where the 40 CFR pt. 63, subp. SSSS requirement was missing or inadequate to establish compliance with the new limitation. Where a corresponding 40 CFR pt. 63, subp. SSSS requirement existed (e.g., capture system monitoring), the permit streamlines the requirements as discussed in EPA's White Paper #2 (http://www.epa.gov/ttn/oarpg/t5/memoranda/wtppr-2.pdf. sections II.A.2.e, II.A.3, and II.A.5) and states that the new 40 CFR pt. 63, subp. MMMM requirement satisfies the 40 CFR pt. 63, subp. SSSS requirement.

None of the requirements needed to be consolidated into an amalgam of each - the permit either includes the 40 CFR pt. 63, subp. SSSS or 40 CFR pt. 63, subp. MMMM requirements directly. Such requirements are found at GP 006 and CE 001.

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

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

the emission unit; • the technical and economic feasibility of possible periodic monitoring methods; and • the kind of monitoring found on similar units elsewhere.

Table 5 summarizes the monitoring requirements.

Table 5. Monitoring


http://www.epa.gov/ttn/oarpg/t5/memoranda/wtppr-2.pdf

Level* Requirement (basis)

Additional Monitoring Discussion

VOC Usage Limits: GP 001

VOC <225.0 tons per year (limit to avoid major source under NSR)

Recordkeeping: Daily records of VOC usage; On-going records of coating contents; Monthly calculations

Records can be generated on a daily basis for all coating materials. For smaller use items such as clean up solvents, the permit allows monthly purchase records. Historical usage has been too low to even measure daily.

Credit cannot be taken for waste materials shipped off-site. The Permittee does not currently need this credit and it would add a significant amount of recordkeeping.

A thermal oxidizer is required on the coil coating lines by the NSPS. Because the spray booths do not have VOC controls, the calculation procedure has variables for both controlled and uncontrolled processes.

NSPS Units: GP 002 (CE 001, EU 001008)

VOC < 10% of coating materials applied (40 CFR pt. 60, subp. TT)

None The NSPS monitoring is adequate to have a reasonable assurance of compliance. See CE 001 for additional monitoring of the oxidizer.

MMMM Units: GP 003 (EU 010-013)

HAP <0.230 kg HAP/liter solids used (40 CFR pt. 63, subp. MMMM)

None The NESHAP monitoring is adequate to have a reasonable assurance of compliance. This is the limit that is used to calculate the FSEL listed at GP 006.

Spray Painting Units: GP 004 (EU 010-013)

PM: variable, depending on airflow

Opacity: < 20 %, (Minn. R. 7011.0715)

Total Enclosure (Minn. R. 7007.0800, subp. 2)

None

Daily recordkeeping of operation of enclosure

Other PM limits at GP 007 (and associated monitoring) help ensure that this applicable requirement is being met. Both booths have controlled PTEs significantly less than the allowable rule limits. Per MPCA policy, this Minnesota Performance Standard applies in addition to the NESHAP.

Closing of booth doors is required to achieve total enclosure. Filters shall be maintained at the facility to control PM. See GP 007 for additional monitoring of the filters.




SSSS Units: GP 005 (CE 001, EU 001-008)

HAP < 0.0460 kg HAP/liter solids used (40 CFR pt. 63, subp. SSSS)

None The NESHAP monitoring is adequate to have a reasonable assurance of compliance. This is the limit that is used to calculate the FSEL listed at GP 006.

FSEL Requirements: GP 006 (EU 001-008, EU 010-013)

FSEL Calculation (40 CFR pt. 63, subp. MMMM)

None The NESHAP monitoring is adequate to have a reasonable assurance of compliance.

Panel Filters: GP 007 (CE 002-003)

PM/PM1Ci > Overall Control Efficiency of 92% (Minn. R. 7007.0800, subp. 2)

Recordkeeping, O&M, inspections

Monitoring based on the Minnesota Performance Standard for Control Equipment is adequate to have a reasonable assurance of compliance (daily and periodic inspections, corrective actions, and O&M).

New Curing Oven: EU 008

Capacity < 4.0 MMBtu/hr

None Design limit only. Facility is required to report the capacity in the construction notification.

Fuel limited to natural gas or propane

Fuel records Used to verify that original permitted PTE is correct.

Air Makeup Unit: EU 014

PM < 0.40 Ibs/MMBtu heat input

Opacity: < 20 %, with exceptions

(Minn. R. 7011.0515)

None This unit uses natural gas only; therefore, the likelihood of violating either of the limits is very small. Design based PTE, using AP-42, is 0.0175 compared to the PM rule limit.




Thermal Oxidizer: CE 001

VOC > Control Efficiency of >90% (limit to avoid NSR + NSPS)

Temperature monitoring, Recordkeeping, O & M, inspections

Monitoring based on the NSPS (see above) and the Minnesota Performance Standard for Control Equipment is adequate to have a reasonable assurance of compliance. CAM applies to the VOC related requirements and they are identified as such in the permit with CAM citations. Some of the monitoring overlaps with the NESHAP-based limits -in which case all applicable citations are included: VOC basis and CAM as well as NESHAP and equivalent Minnesota rule.

Based on results of previous performance tests, a 5-year testing frequency is included. The next test is due before September 28, 2016.

HAP > Control Efficiency of 90% (Minn. R. 7007.0800, subp. 2)

None Monitoring from the NESHAP is adequate to have a reasonable assurance of compliance. This limit is included in the permit to limit the HAP PTE - to allow credit for the control equipment when determining HAP PTE and actual emissions.

Temperature > 1190 "F, 3-hr block average (to avoid NSR, NSPS, and 40 CFR pt. 63, subp. MMMM)

None The monitoring in the permit is based on the NESHAP monitoring and is used to meet all requirements.

Airflow > 200 ft/min (40 CFR pt. 63, subp. MMMM)

None Monitoring from the NESHAP is adequate to have a reasonable assurance of compliance.

PM: variable, depending on airflow

Opacity: < 20 %, with exceptions

Recordkeeping: fuel records

This unit uses natural gas only; therefore, the likelihood of violating either of the limits is very small. Design based PTE, using AP-42, is 0.0072 compared to the rule limit.

(Minn. R. 7011.0610)

* Location oft he requirement in the permit (e.g., EU, SV, GP, etc/

3.4 Insignificant Activities


EDCO Products, Inc. has several operations which are classified as insignificant activities under the MPCA's permitting rules. These are listed in Appendix D to the permit.

The permit is required to include periodic monitoring for all emissions units, including insignificant activities, per EPA guidance. The insignificant activities at this Facility are only subject to general applicable requirements. Using the criteria outlined earlier in this TSD, the following table documents the justification why no additional periodic monitoring is necessary for the current insignificant activities.

Table 6. Insignificant Activities

Insignificant Activity General Applicable

Emission limit Discussion

Infrared electric ovens Opacity <20%

(Minn. R. 7011.0110)

These units are not likely to have any emissions of particulate matter at this site (used to dry off VOCs). It is highly unlikely that they could violate the applicable requirement.

Emissions from a laboratory, as defined in Minn. R. 7007.1300, subp. 3(G)

PM, variable depending on airflow

Opacity < 20%

(Minn. R. 7011.0715)

These are very small, intermittent, bench-top operations that typically do not even have any emissions. It is highly unlikely that they could violate the applicable requirement.

Brazing, soldering or welding equipment


Opacity <20%

(Minn. R. 7011.0715)

For these units, based on EPA published emissions factors, it is highly unlikely that they could violate the applicable requirement. In addition, these units are typically operated and vented inside a building, so testing for PM or opacity is not feasible.

Cleaning operations: alkaline/phosphate cleaners and associated cleaners and associated burners


Opacity <20%

(Minn. R. 7011.0610+ Minn. R. 7011.715)

For these units, there are some factors available for the burners, but very little information regarding the cleaning operation itself. However, based on general knowledge of how they operate, it is highly unlikely that they could violate the applicable requirement or that testing would be feasible.

Individual units with potential or actual emissions less than the various thresholds in the rule


Opacity < 20% (with exceptions)

(Minn. R. 7011.0515+ Minn. R. 7011.610)

These include 55 natural gas combustion units. For all of these activities, based on EPA published emissions factors, it is highly unlikely that they could violate the applicable requirement.


Insignificant Activity General Applicable

Emission limit Discussion

Infrequent use of spray paint equipment for routine housekeeping or plant upkeep activities not associated with primary production processes at the stationary source

PM, variable depending on airflow or process weight rate

Opacity <20%

(Minn. R. 7011.0715)

While spray equipment will have the potential to emit particulate matter, these particular activities are those not associated with production, so they would be infrequent and usually occur outdoors. Testing or monitoring is not feasible.

Individual units with potential or actual emissions less than the various thresholds in the rule


Opacity <20% (with exceptions)

(Minn. R. 7011.0715)

or

S02 < 0.50 Ib/MMBtu

Opacity < 20%

(Minn. R. 7011.2300)

These include an emergency generator and a cooling tower. For all of these activities, based on EPA published emissions factors, it is highly unlikely that they could violate the applicable requirement. In addition, many of these units are operated and vented inside a building, so testing for PM or opacity is not feasible.

3.5 Permit Organization In general, the permit meets the MPCA Delta Guidance for ordering and grouping of requirements. One area where this permit deviates slightly from Delta guidance is in the use of appendices. While appendices are fully enforceable parts of the permit, in general, any requirement that the MPCA thinks should be electronically tracked (e.g., limits, submittals, etc.), should be in Table A or B of the permit. The main reason is that the appendices are word processing sections and are not part of the electronic tracking system. Violation of the appendices can be enforced, but the computer system will not automatically generate the necessary enforcement notices or documents. Staff must generate these.

Appendix B contains the specific calculation procedures for 40 CFR pt. 60, subp. TT. These procedures are too complex to enter into Delta and must go in an Appendix.

Appendix C contains the specific calculation procedures for 40 CFR pt. 63, subp. MMMM. These procedures are too complex to enter into Delta and must go in an Appendix.

Appendix D contains a listing of the Facility's Insignificant Activities and their applicable requirements.

Appendix E contains documentation of the process parameters used by the Permittee to calculate the potential Ib/hr emissions from the various coating operations. This is a standard way to document these assumptions in the permit so all parties have access to this data.

Another area that deviates from the guidance is in the use of groups where the requirements in the group apply to the members of the group individually. This was done in order to shorten the permit and where no testing or tracking specific to a unit is in the permit (thereby reducing the likelihood that there


where will be further unit-specific requirements later). This is the case for the requirements at GP 004 (paint booths) and GP 007 (panel filters).

While the thermal oxidizer (CE 001) is considered control equipment, it does have emissions of its own. These emissions were left at the stack level (SV 001) since it is not possible to enter emissions at the control equipment level.

3.6 Comments Received

Public Notice Period: 6/19/2015-7/20/2015 EPA 45-day Review Period: 6/19/2015 - 8/4/2015

No comments were received during either review period.

4. Permit Fee Assessment

This permit action is the reissuance of an individual Part 70; therefore, no application fees apply under Minn. R. 7002.0016, subp. 1.

5. Conclusion

Based on the information provided by EDCO Products, Inc., the MPCA has reasonable assurance that the proposed operation of the emission facility, as described in the Air Emission Permit No. 05301047-006 and this TSD, will not cause or contribute to a violation of applicable federal regulations and Minnesota Rules.

Staff Members on Permit Team:

AQ File No. 3830; DQ 4336, DQ 3719

Nicholas Coleman (permit engineer) Brent Rohne (enforcement) Marc Severin (compliance) Hassan Bouchareb (peer reviewer) Beckie Olson (permit writing assistant) Sandy Simbeck (administrative support)

Attachments: 1. PTE Summary Calculation Spreadsheets 2. Facility Description and CD-01 Forms 3. Detailed Calculation Spreadsheets 4. CAM Plan


EDCO Products Inc Permit No. 05301047-006 Technical Support Document

Attachment 1 PTE Summary Calculation Spreadsheets

SDCO Products inc Title V Renewal Application PTE Summary Calculations

Emission Type EU001 EU002 EU003 EU006 EU007

Emission Potential to Emission Potential to Emission Potential to Emission Potential to Emission Potential to Rate Emit (PTE) Rate Emit (PTE) Rate Emit (PTE) Rate Emit (PTE) Rate Emit (PTE)

Pollutant (Ib/hr) (ton/yr) (Ib/hr) (ton/yr) (Ib/hr) (ton/yr) (Ib/hr) (ton/yr) (Ib/hr) (ton/yr) Total VOC 2.022 8.854 1.490 6.524 13,406 58.718 18.194 79.688 0.000 0.000 PM 0.000 0.000 0.000 0.000 0.021 0.091 0.000 0.000 0.000 0.000 PM10 0.000 0.000 0.000 0.000 0.021 0.091 0.000 0.000 0.000 0.000 PM2.5 0.000 0.000 0.000 0.000 0.021 0.091 0.000 0.000 0.000 0.000 CO 0.000 0.000 0.000 0.000 0.231 1.010 0.000 0.000 0.000 0.000 SOX 0.000 0.000 0.000 0.000 0.002 0.007 0.000 0.000 0.000 0.000 NOX 0.000 0.000 0.000 0.000 0.275 1.202 0.000 0.000 0.000 0.000 Total HAP 0.502 2.198 1.273 5.575 11.461 50.201 4.516 19.782 0.000 0.000 Highest HAP Xylene 1.503 6.584 1.180 5.169 10.621 46.521 13.528 59.254 0.000 0.000 Individual HAP Glycol Ethers 0.465 2.039 0.365 1.601 3.289 14.405 4,189 18.347 Ethyl Benzene 0.308 1.348 0.242 1.059 2.175 9.528 2.771 12.136 Naphthalene 0.081 0.357 0,064 0.280 0.576 2.522 0.434 1.903 Xylene 1.503 6.584 1.180 5.169 10.621 46.521 13.528 59.254 Cumene 0.016 0.071 0,013 0.056 0.115 0.504 0.147 0.643 Formaldehyde 0.005 0.020 0.004 0.016 0.032 0.140 0.041 0.178 Triethyiamine 0.001 0.006 0.001 0.005 0.010 0.042 0.012 0.054 Isophorone 1.169 5.118 0.917 4.018 8.257 36.166 10.517 46.065 Toluene 1.354 5.929 1.063 4.655 9.565 41.897 12.184 53.365 Metallic HAPs Arsenic Compounds 5.49E-07 2.40E-06 Benzene 5.76E-06 2.52E-05 Beryllium Compounds 3.29E-08 1.44 E-07 Cadmium Compounds 3.02E-06 1.32E-05 Chromium Compounds 3.84E-06 1.68E-05 Cobalt Compounds 2.31E-07 1.01E-06 Dichlorobenzenes 3.29E-06 - 1.44E-05 Formaldehyde 2.06E-04 9.02E-04 Hexane 4.94E-03 2.16E-02 Lead Compounds 1.37E-06 6.01E-06 Manganese Compounds 1.04E-06 4.57E-06 Mercurv Compounds 7.14E-07 3.13E-06 Naphthalene 1.67E-06 7.33E-06 Nickel Compounds 5.76E-06 2.52E-05 Selenium Compounds 6.59 E-08 2.89E-07

Toluene 9.33E-06 4.09E-05 POM 2.42E-07 1.06E-06 C02 e 1442

2

EOCQ Products inc Title V Renewal Application PTE Summary Calculations

Emission Type EU008 EU009 EU010 EU 012 EU014 I

Emission Potential to Emission Potential to Emission Potential to Emission Potential to Emission Potential to

Rate Emit (PTE) Rate Emit (PTE) Rate Emit (PTE) Rate Emit (PTE) Rate Emit (PTE)

Pollutant (Ib/hr) (ton/yr) (Ib/hr) (ton/yr) (Ib/hr) (ton/yr) (Ib/hr) (ton/yr) (Ib/hr) (ton/yr)

Total VOC 0.022 0.094 0.000 0.000 14.833 64.093 7.153 31.331 0.032 0.139

PM 0.030 0.131 0.000 0.000 0.094 0.414 0.045 0.199 0.044 0.193

PM10 0.030 0.131 0.000 0.000 0.094 0.414 0.045 0.199 0.044 0.193

PM 2.5 0.030 0.131 0.000 0.000 0.094 0.414 0.045 0.199 0.044 0.193

CO 0.329 1.443 0.000 0.000 0.000 0.000 0.000 0.000 0.486 2.128

SOX 0.002 0.010 0.000 0.000 0.000 0.000 0.000 0.000 0.003 0.015 NOX 0.392 1.718 0.000 0.000 0.000 0.000 0.000 0.000 0.578 2.534

Total HAP 0.007 0.032 0.000 0.000 12.527 54.870 6.124 26.822 0.011 0.048 Highest HAP Xylene 0.000 0.000 0.000 0.000 5.480 24.005 2.679 11.734 0.000 0.000 Individual HAP

Glycol Ethers 1.697 7.433 0.830 3.633 Ethyl Benzene 1.123 4.917 0.549 2.403 Naphthalene 0.297 1.301 0.145 0.636 Xylene 5.480 24,005 2.679 11.734 Cumene 0.059 0.260 0.029 0.127 Formaldehyde 0.017 0.072 0.008 0.035 Triethylamine 0.005 0.022 0.002 0.011 Isophorone 4.261 18.661 2.083 9.122 Toluene 4,936 21.619 2.413 10.568 Metallic HAPs 0.023 0.099 0.011 0.048

Arsenic Compounds 7.84E-07 3.44E-06 1.16E-06 5.07E-06

Benzene 8.24E-06 3.61 E-05 1.21 E-05 5.32E-05

Beryllium Compounds 4.71 E-08 2.06E-07 6.94 E-08 3.04E-07

Cadmium Compounds 4.31 E-06 1.89E-05 6.36E-06 2.79E-05

Chromium Compounds 5.49E-06 2.40E-05 8.10E-06 3.55E-05

Cobalt Compounds 3.29E-07 1.44E-06 4.86E-07 2.13E-06

Dichlorobenzenes 4.71E-06 2.06E-05 6.94E-06 3.04E-05

Formaldehyde 2.94E-04 1.29E-03 4.34E-04 1.90E-03

Hexane 7.06E-03 3.09E-02 1.04E-02 4.56E-02

Lead Compounds 1.96E-06 8.59E-06 2.89E-06 1.27E-05

Manqanese Compounds 1.49E-06 6.53E-06 2.20E-06 9.63E-06

Mercury Compounds 1.02 E-06 4.47E-06 1.50E-06 6.59E-06

Naphthalene 2.39E-06 1.05E-05 3.53E-06 1.55E-05

Nickel Compounds 8.24E-06 3.61 E-05 1.21 E-05 5.32E-05

Selenium Compounds 9.41 E-08 4.12E-07 1.39E-07 6.08E-07

Toluene 1.33E-05 5.84E-05 1.97E-05 8.61 E-05

POM 3.46E-07 1.51 E-06 5.10E-07 2.23E-06

C02 e 2061 3039

3

EDCO Products inc Title V Renewal Application PTE Summary Calculations

Emission Type CE001 Total Facilit y (w/o Limits) GP001

Emission Potential to Emission Potential to Emission Potential to

Rate Emit (PTE) Rate Emit (PTE) Rate Emit (PTE)

Pollutant (Ib/hr) {ton/yr) (Ib/hr) (ton/yr) (Ib/hr) (ton/yr)

Total VOC 0.027 0.118 56.977 249.560 225.000 PM 0.037 0.163 0.272 1.191 PM10 0.037 0.163 0.272 1.191 PM2.5 0.037 0.163 0.272 1.191 CO 0.412 1.804 1.458 6.384 SOX 0.003 0.013 0.010 0.046 NOX 0.490 2.147 1.735 7.601 Total HAP 0.009 0.041 36.431 159.569 Highest HAP Xylene 0.000 0.000 34.992 153.267 Individual HAP Glycol Ethers 10.835 47,457 Ethy! Benzene 7.167 31.392 Naphthalene 1.598 7.000 Xylene 34.992 153.267 Cumene 0.379 1.662 Formaldehyde 0.105 0,462 Triethylamine 0.032 0.138 Isophorone 27.203 119.151 Toluene 31.514 138.032 Metallic HAPs 0.034 0.147 Arsenic Compounds 9.80E-07 4.29E-06 3.47E-06 1.52E-Q5 Benzene 1.03E-05 4.51 E-05 3.64E-05 1.60E-04 Beryllium Compounds 5.88E-08 2.58E-07 2.08E-07 9.12E-07 Cadmium Compounds 5.39E-06 2.36E-05 1.91 E-05 8.36E-05 Chromium Compounds 6.86E-06 3.01 E-05 2.43E-05 1.06E-04 Cobalt Compounds 4.12E-07 1.80E-06 1.46E-06 6.38E-06 Dichlorobenzenes 5.88E-06 2.58 E-05 2.08E-05 9.12E-05 Formaldehyde 3.68E-04 1.61E-03 1.30E-03 5.70E-03 Hexane 8.82E-03 3.86E-02 3.12E-02 1.37E-01 Lead Compounds 2.45E-06 1.07 E-05 8.68E-06 3.80E-05 Manganese Compounds 1.86E-06 8.16E-06 6.59E-06 2.89E-05 Mercury Compounds 1.27E-06 5.58E-06 4.51 E-06 1.98E-05 Naphthalene 2.99E-06 1.31 E-05 1.06 E-05 4.64E-05

Nickel Compounds 1.03E-05 4.51 E-05 3.64E-05 1.60E-04

Selenium Compounds 1.18E-07 5.15E-07 4.16E-07 1.82E-06

Toluene 1.67E-05 7.30E-05 5.90E-05 2.58E-04

POM 4.32E-07 1.89E-06 1.53E-06 6.70E-06

C02 e 2576 9118


Attachment 2 Facility Description and CD-01 Forms

3 December, 2014 15:59

FACILITY DESCRIPTION: BUILDINGS (BG)

Show: Active and Pending Records Action: PER 006 AQD Facility ID: 05301047 Facility Name: EDCO Products Inc

MINNESOTA POLLUTION < AIR QUALITY ?20 LAFAYETTE RO AD ST. PAUL. MN 55155—41V-1

ONTROL ACiKNCY

ID No. Added By

(Action)

Retired By

(Action)

Operator ID

for Item

Length {feet.)

Width (feet)

Roof Height from

Ground (feet)

Description/Comment Building

Status

1 BG 001 PER 005 544 ..1 254.3 20 Manufacturing Building Active

2 BG 002 PER 005 1S5.4 80.2 16 Manufacturing Building Active

3 BG 003 PER 005 102.3 63.0 14 Manufacturing Building Active

4 3G 004 PER 005 144.0 68.0 16.6 Manufacturing Building Active

5 BG 005 PER 005 739.3 336.2 23.0 Distribution Center (north of railroad tracks) Active

Page 1 of 1

3 December, 2014 15:59 3 December. 2014 15:59

FACILITY DESCRIPTION: CONTINUOUS MONITORING SYSTEMS (CM)

ID Ho. CMS Added Retired Monitor DAS Operator CMS Description Parameter Month/ Month/ Cert Cert. Status By By ID NOES). ID Nofs). ID Year Year Date Basis

(Action) (Action) for Item installed Removed

1 CM 001 Active PER 005 MR 001 DA 001 Honeywell Miniirend Recorder Temperature 09/2007

Page 1 of 1

"W. MINNESOTA POLLUTION CONTROLAGENCY / \ J\ AIR QUALITY IgPyy 520 LAFAYETTE ROAD

"mugs*" ST. PAUL, MM ?5iSMlv4


MINNESOTA POLLUTION CONTROLAGENCY \ AIR QUALITY

' 520 1. ARAYETTE ROAD ST. PA UL. M.N 5515^-4194

3 December, 2014 16.02

FACILITY DESCRIPTION: DATA ACQUISITION SYSTEMS (DA)


ID No. DAS Status

Added By

(Action)

Retired By

{Action}

Operator ID

for Item

Data Acquisition System Description Manufacturer Model Number Serial Number Data Storage Medium

installation Date

Removal Date

I s DA 001 Active PER 005 J Minitrend Video Recorder Honeywell TVMIQX-40-2-22-0-015-G 0734Y775373900001 Electronic 09/10/2007

Page 1 of 1

2 June. 2015 11:46

FACILITY DESCRIPTION: EMISSION UNIT (EU)

Show: Active and Pending Records Action: AQD Facility ID : 05301047 Facility Name: EDCO Products Inc

'lT' "V MINNHS0TA POLLUTION CONTROL As'lFN AIRQUALIIV

520 LAFAYETTE ROAD Tll'ifliii - s r. PAUL. MN 55155-;41 v-1

ID No. Emission Unit

Status

Added By

(Action)

Retired By

(Action)

Insignificant

Activity

Operator ID

for Item

Stack/ Vent

ID No{s).

Contrci Equip.

ID No(s).

Operator Description Manufacturer Model Number

SIC Max. Design

Capacity

Maximum Design

Capacity

Max

Input fmil'Btuj

Materials Units r Units d

1 EU 001 Active PER QG1 r—; SV 001 {M} CE 001 Primer/Backer Coater EDCO Products NA 3479 221 Ft Min

2 EU 001 Active PER 006 LJ SV 001 (M} CE 001 Primer/Backer Coater Spray Sooth/Coating Line

EDCO Products NA 3479 221 Ft Min

3 EU 002 Active PER 001 \ 1 SV 001 (M) CE 001 Topcoater Gasway NA 3479 227 Ft Min

4 EU 002 Active PER 005 LJ SV 001 \1V1) CE 001 Topcoater Spray Booth/Coating Line

G a sway NA 3479 227 Ft Min

5 EU 003 Active PER 001 i 1 SV 001 iM> CE 001 Finish Oven (2-Zone) Oven Systems Inc. 120 AH 3479 2800 Ft 3 Br 2.8

6 EU 003 Active PER 006 SV 001 (Mi CE 001 Finish Oven (2-Zone) Dryer/Oven, unknown firing method

Oven Systems inc. 120 AH 3479 2S00 R3 Hr 2.8

7 EU 004 Active PER 001 ! | sv 002 m Primer Quench Bath EDCO Products NA 3479 15 Gal Min

S EU 004 Active PER 006 LJ SV 002 (iVI) Primer Quench Bath Quenching Equipment

EDCO Products NA 3479 15 Min

9 EU 005 Active PER 001 SV 003 (IVI) Topcoat Quench Bath Gasway NA 3479 15 Gal Min

10 EU 005 Active PER 006 SV 003 :iVh 'Topcoat Quench Bath Quenching Equipment

Gasway NA 3479 15 Gal Min

11 EU 006 Active PER 001 SV 001 (M) CE 001 Primer IR Oven BGK 1 3479 200 Ft Min

12 EU 006 Active PER 006 SV 001 (M) CE 001 Primer IR Oven Process Heater

BGK 1 3479 200 Ft Min

13 EU 007 Active PER 001 ! 1 sv coi m CE 001 Top-Coat IR Oven BGK 2 3479 200 Ft Min

14 EU 007 Removed PER 006 SV 001 (M) TopCoat IR Oven -non-operational

BGK 2 3479 200 Ft Min

15 EU 00S Active PER 005 • SV 001 (M) CE GQ1 New NSPS Oven unknown unknown 3479 4

16 EU 008 Active PER 006 n SV 001 (M) CE 001 New NSPS Oven Dryer/Oven, unknown firing method

unknown unknown 3479 4 Mmfriu Hr 4

17 EU 009 Removed PER 005 1 Mew Emergency Generator -never installed

unknown unknown 3479 1 5

18 EU 010 Active PER 005 ; 1 SV 005 (M) CE 002 Paint Booth 1 TECOR Inc. Finish Pro 3000 3479 553 Shingles Each Hr

19 EU 010 Active PER 006 LJ SV 005 (M) CE 002 Paint Booth 1 Spray Booth/Coating Line

TECOR Inc. Finish Pro 3000 3479 Shingles Each Hr

20 EU 011 Active PER 005 ^ ^ sv 006 m Fiat Line Continuous Flow Oven (IR)

Seneca Industrial QuikKILN 3479 553 Shingles Each Hr

21 EU 011 Active PER 006 SV 006 (M) Flat Line Continuous Flow Oven (IR) Process Heater

Seneca Industrial QuikKMN 3479 553 Shingles Each Hr

Page 1 of 2 (a)

2 June, 2015 11:46



Status

Added By

(Action)

Commence

Const. Date

Initial Startup Date

Removal Date

Firing Method Pet. Fuel/

Space Heat

Bottleneck Elevator Type

1 EU 001 Active PER 001 01/01/1982 03/01/1982

2 EU 001 Active PER 006 01/01/1982 03/01/1982

3 EU 002 Active PER 001 12/01/1971 12/01/1971

4 EU 002 Active PER 006 12/01/1971 12/01/1971

5 EU 003 Active PER 001 12/01/1971 12/01/1971

6 EU 003 Active PER 006 12/01/1971 12/01/1971

7 EU 004 Active PER 001 12/01/1971 12/01/1971

8 EU 004 Active PER 006 12/01/1971 12/01/1971

9 EU 005 Active PER 001 12/01/1971 12/01/1971

10 EU 005 Active PER 006 12/01/1971 12/01/1971

11 EU 006 Active PER 001 01/01/1998 01/01/1998

12 EU 006 Active PER 006 01/01/1998 01/01/1398

13 EU 007 Active PER 001 03/01/1982 03/01/1962

14 EU 007 Removed PER 006 03/01/1982 03/01/1962

15 EU 008 Active PER 005

16 EU 008 Active PER 006

17 EU COS Removed PER 005 04/01/2008

IS EU 010 Active PER 005 11/12/2007 03/10/2008

19 EU 010 Active PER 006 11/12/2007 03/10/2008

20 EU 011 Active PER 005 11/12/2007 03/10/2008

21 EU 011 Active PER 006 11/12/2007 03/10/2008

Page 1 of 2 (b)

2 June. 201s 11:46

FACILITY DESCRIPTION: EMISSION UNIT <EU)

Show: Active and Pending Records Action: AQD Facility ID: 05301047 Facility Name: EDCO Products Inc

MINNESOTA POLLUTION CONTROL ACiENCY \ AIR QUALITY

520 LAFAYETTE ROAD ST. PAUL. MN 5SISM1*!

ID Ho. Emission Unit

Status

Added By

(Action)

Retired By

(Action)

insignificant

Activity

Operator !D

for Item

Stack/ Vent

ID No{s),

Control Equip.

ID No(s).

Operator Description Manufacturer Model Number

SIC Max. Design

Capacity

m D

Ca

Materials

<irnuni ?sign oacity

Units n Units d

Max Fuel input

(mil Btu;

22 EU 012 Active PER 005 [J SV 007 (M) CE 003 Paint Booth 2 TECOR Inc. Finish Pro 30D0 3479 553 Shingles Each Hr

23 EU 012 Active PER 00S • SV 007 (M) CE 003 Paint Booth 2 Spray Booth/Coating Line

TECOR Inc. Finish Pro 3000 3479 553 Shingles Each Hr

24 EU 013 Active PER 005 • SV 008 {«) Flat Line Continuous Flow Oven OR)

Seneca Industrial QuikKiLN 3479 553 Shingles Each Hr

2.5 EU 013 Active PER 006 • SV 008 (M) Fiat Line Continuous Flow Oven f!R) Process Heater

Seneca Industrial QuikKlLN 3479 553 Shingles Each Hr

26 EU 014 Active PER 006 • Makeup Air Unit Rupp Ram 36 3479 5.9 Natural Gas jVlmPtu Hr 5.9

Page 2 of 2 (a)

2 June, 2015 11:46



Status

Added By

(Action)

Commence

Const. Date

Initial Startup

Date

Removal Date

Firing Method Pet. Fuel/

Space Heat

Bottleneck Elevator Type

22 EU 012 Active PER 005 11/12/2007

23 EU 012 Active PER 006 11/12/2007

24 EU 013 Active PER 005 11/12/2007

25 EU 013 Active PER 006 11/12/2007

26 EU 014 Active PER 006 05/01/2013 05/01/2013

Page 2 of 2 (b)

3 December, 2014 16:00

FACILITY DESCRIPTION: FUGITIVE SOURCES (FS)

Show: Active and Pending Records Action: PER 006 AQD Facility ID: 05301047 Facility Name: EDCO Products inc

MINNESO TA POLL AIR. QUALITY

.YETTE ROAD

. MN 55155-41V4

ION C ON TROL AG

ID No. Fugitive Added Retired Insignif Operator Pollutants) Control Fugitive Source Description Year Year Source By By icant " ID Emitted Equip. installed Removed Status (Action) (Action) Activity for Item ID No(s).

Page 1 of 1

MINNESOTA POLLUTION CONTROLAGE NCY AIR QUALITY 520 LArAYETTE ROAD ST. f'AUJ.. MN 55155-4194


3 December, 2014 15:58

FACILITY DESCRIPTION: GROUPS (GP)

SD No. Group Status

Added By

(Action)

Retired By

(Action)

Include in El

Operator ID

for item

Group Description Group items

1 GP 001 Active PER 005 f Facility VOC Emissions Limits EU 001. EU 002. EU 003, EU 004, EU 005, EU 006, EU 007. EU 00S EU 010, EU 011, EU 012, EU 013

2 GP 002 Active PER 001 r NSPS Limits CE 001. EU 001, EU 002, EU 003. EU 004. EU 005. EU 006. EU 007. EU 008.

SV001, SV 002. SV 003

3 GP 002 Active PER 006 r NSPS Subpart IT Limits CE 001. EU 001. EU 002, EU 003, EU 004, EU 005, EU 006, EU 007: EU 008,

SV 001. SV 002, SV 003

4 GP 003 Active PER 004 r Part 63 Subpart MMMM NESHAP EU 010. EU 011, EU 012, EU 013

5 GP 004 Active PER 005 r Paint Booths and Cure Ovens EU 010, EU 011, EU 012, EU 013

6 GP 005 Active PER 004 r Pail S3 Subpart SSSS NESHAP CE 001. EU 001. EU 002, EU 003, EU 004, EU 005. EU 006, EU 007 EU 00S

7 GP 006 Active PER 005 r Facility-Specific Emission Limit EU 001, EU 002. EU 003, EU 004. EU 005. EU 006. EU 007. EU 008. EU 010.

EU 011. EU 012, EU 013

S GP 007 Active PER 005 r Paint Booth Filters CE 002. CE 003

Page 1 of 1

MINNESO 3"A POLLUHON CONTROL AGENCY \ AIRQUAUTV

520 LAFAYETTE ROAD ST. PA UL. MN' 55155-1194

3 December. 2014 16:00

FACILITY DESCRIPTION: CONTINUOUS MONITORS (MR)


ID No. Monitor Status

Added By

(Action)

Retired By

(Action)

Monitored item

{ID No(s),)

Operator ID

for Item

Monitor Description Manufacturer Mode! Number Serial Number Parameter's Monitored

1 MR 001 Active PER 005 CE 0G1 Type K Thermocouple J&W Instruments 12:'.S gauge w/ceramic insula Temp

Page 1 of 1 {a}

3 December, 2014 16:00

FACILITY DESCRIPTION: CONTINUOUS MONITORS (MR)

ID No. Monitor Status

Added By

(Action)

Span Value

System Full-Scale Value

Bypass Capability?

Optica' Path

Length Ratio

Installation Date

Removal Date

1 MR 001 Active PER 005 No 12/01/1971

Page 1 of 1 (b)

MINNESOTA POLLUTION CONTROL AGENCY \ AIR QUALITY

520 LAFAYETTE ROAD ST: PAUL MN 5SIJMW

3 December. 2014 16:01

FACILITY DESCRIPTION: CONTROL EQUIPMENT (CE)


ID No. Control Equip. Status

Added By

(Action!

Retired By

(Action)

Operator ID

for Item

Control Equip. Type

Control Equipment Description Manufacturer Model Pollutants Controlled

Capture Efficiency

(%}

Destruction/ Collection Efficiency

Afterburner Combustion Parameters

1 CE 001 Active PER 005 021 Direct Flanie Afterburner Oven Systems Inc. unknown VOC 100 30 1300

2 CE 001 Active PER 006 021 Direct Flame Afterburner Oven Systems Inc. unknown V'OC 100 90 1190

3 CE 002 Active PER 004 099 Mat or Panel Filter 1 Superior Glass Fibers Inc.

T GT-25-250" 15-2-2-00 PM10 PM

100 100

92 32

4 CE 003 Active PER 004 099 Mat. or Panel Filter 2 Superior Glass Fibers Inc.

TGT-25-250-15-2-2-00 PM10 100 100

92 92

Page 1 of 1

&

MINNESOTA POLLUTION CONTROL AGENCY AIR QUALITY 520 LAfAYETTE ROAD ST. PAUL. MN 55 f 55-4191


3 December, 2014 15:59

FACILITY DESCRIPTION: STACK/VENTS <SV)

ID No. Stack/ Vent

Status

Added By

(Action)

Retired By

(Action)

Operator ID

for item

Operators Description Height of Opening

From Ground

(feet.)

inside Dimensions Design How Rate

at Top (ACFM)

Exit Gas Temperature

at Top (°F)

Flow Rate/ Temperature

Information Source

Discharge Direction Stack/ Vent

Status

Added By

(Action)

Retired By

(Action)

Operator ID

for item

Height of Opening

From Ground

(feet.)

Diameter or Length

(feet)

Width (feet)

Design How Rate

at Top (ACFM)

Exit Gas Temperature

at Top (°F)

Flow Rate/ Temperature

Information Source

1 SV 001 Active PER 001 Coating Emissions 27.3 3 8300 1400 Manufacturer Up; No Cap

2 SV 002 Active PER 001 Primer/Backer Quench 23 1.5 750 110 Manufacturer Up, No Cap

3 SV 003 Active PER 001 Top Coat Quench 23 1.5 750 88 Manufacturer Up. No Cap

4 SV 004 Active PER 001 New Emergency Generator Stack Up. No Cap

5 SV 005 Active PER 004 Spray Booth 1 Stack 29 1.5 4000 72. Manufacturer Up, With Cap

6 SV 00G Active PER 004 Cure Oven 1 29 0.833 1500 275 Manufacturer Up. With Cap

7 SV 007 Active PER 004 Spray Booth 2. Stack 29 1.5 4000 72 Manufacturer Up. With Cap

S SV 008 Active PER 004 Cure Oven 2 29 0,833 1500 275 Manufacturer Up, With Cap

Page 1 of 1

MINNESOTA POLLUTION CONTROL AGFNCY \ AIR QUA LITY

520 LAFAYETTE ROAD ST. RAt'i. MN 5SIJMIW

3 December. 2014 15:58

FACILITY DESCRIPTION: STORAGE TANKS (TK)


ID No. Tank Added Retired Insignif Operator Control Product Stored Interior Interior Capacity Construction Type Status By By icant ID Equip. Height Diameter ^ s 000 gal)

(Action) (Action) Activity for item ID No(s). (ft.) irt.j

Page 1 of 1 (a)

3 December, 2014 15:58

FACILITY DESCRIPTION: STORAGE TANKS (TK)

ID No, Tank Added Support Type Column Column Deck Type Seal Type Year Year Status By (floating roof only) Count Diameter {floating roof only) (floating roof only) installed Removed

(Action) eft.) (floating roof only)

Page 1 of 1 |b)

MINNESOTA POLLUTION CONTROL AGf'NCY 2 June. 2015 11:46 AIR QUALITY

ST S1 ?si™ FACILITY DESCRIPTION: Potential-to-emit (by pollutant)

Show: Active and Pending Records AQD Facility ID: 05301047 Facility Name: EDCO Products Inc

Pollutant Item Added Bv

(Action)

Retired By

(Action)

Hourly Potential

(lbs per hi )

Unrestricted Potential

{tons per yr)

Limited Potential

(tons per yr)

Actual Emissions

(tons per yr)

Benzene

EU 003 PER 006 5.760E-06 2.52OE-05 2.52GE-05

EU 008 PER 006 8.240E-06 3.610E-05 3.610E-05

EU 014 PER 006 1.210E-05 5.320E-05 5.32QE-05 :

SV 001 PER 005 2.410E-05 1.060E04 1.060E-04

SV 001 PER 006 1.030E-05 4.S10E-05 4.510E-05

Totals 1.596E-04 1 596E-04 O.OOOE'OO

Arsenic compounds

EU 003 PER 006 5.490E-07 2.400E-06 2.4OOE-06

EU 008 PER 006 7.840E-07 35«0E-06 3.44OE-06

EU 014 PER 006 1.160E-06 5.070E~06 5.O7OEr0B^;

SV 001 PER 005 2.300E-06 1.010E-05 1 010E-05

SV 001 PER 006 9.800E--07 4.290E-06 4.29QE-Q6

Totals 1.520E-05 1.520E-05 0.OOOE+OO

Beryllium Compounds

EU 003 PER 006 3.290E-08 1.44OE-07 im0E-07:

EU 008 PER 006 4.710E-08 2.050E-07 " 2.0806,07 :

EU 014 PER 006 6.940E-08 3.G40E-07 3.O4OE-07

SV 001 PER 005 1.380E-07 6.030E-07 6.030E-07

SV 001 PER 006 5.880E-08 2.58OE-07 2.580Eftl7:|;

Totals 9.120E-07 9.120E-07 O.OOOE+OO

Carbon Dioxide Equivalent

EU 003 PER 006 ;1.4426*03

EU 008 PER 006 2.Q61E-W1 2.O61§*03

EU 014 PER 006 3i39Et03 j 3.039E+03

SV 001 PER 006 2St6E+03 2.578§ffl3 ;

Totals 7.676E+03 9.118E+03 0.000E+00

Cadmium compounds

EU 003 PER 006 | 3.020E-06 1.32OE-05 1.320E-O5 s iffif life 1;:

EU 008 PER 006 | 4.310E-06 1.890E-05

EU 014 PER 006 | 6.360E-06 2.|gpE|J5 • ' 2.790E-05

SV 001 PER 005 1.260E-05 5.530E-05 5.530E-05

SV001 PER 006 5.390E-06 2.380E-05 2.36OE-05


Methane

EU 003 PER 006 1.000E-02 2400Ej®

EU 008 PER 006 1 000E-02 Slooe&A 3.WE-02'! |

Page 1 of 12

2 June. 2015 11:45

FACILITY DESCRIPTION: Potcntial-to-emit (by pollutant)

Show: Active and Pending Records AQD Facility ID; 05301047 Facility Name: EDCO Products Inc

Pollutant Item Added By

(Action)

Retired By

(Action)

Hourly Potential

(lbs per hr)


(tons per yr)

Limited Potential

(tons per yr)

Actual Emissions

(tons per yr )

Methane

SV 001 PER 006 1.000E-02 430QE-O2 4.300E-Q2


Carbon Monoxide

EU 003 PER 001 2.200E-01 9.800E-01

EU 003 PER 006 2.310E-01 T.010E+00 1.010E+00

EU 008 PER 001 3.200E-01 1.400E+00

EU 008 PER 006 3.290E-01 1M3E-F00 ;: 1,443E#Q

EU 009 PER 005 0.000E+00 O.OOOE+OO

EU 014 PER 006 4.860E-01 2:128E+00 > 2.128E+QP

SV 001 PER 001 4.200E-01 1.840E+00

SV 001 PER 006 4.120E-01 1P04E+OO 1.8®E«0

Totals 6.385E+00 6.385E+00 O.OOOE+OO

Carbon Dioxide

EU 003 PER 006 3.280E+02 ft3SE+;03 1.435E+03

EU 008 PER 006 4.680E+02 2,049E*O3; 2iO^0E+!33

SV 001 PER 006 5.850E+02 2f8gE+b3 • 2.562E+03


Cobalt compounds

EU 003 PER 006 2.310E-07 1CH0E-Q6 1,016E-06 : :

EU 008 PER 006 3.290E-07 1»440E-0fe; hMOE-gp

EU 014 PER 006 4 HOOF 0/ £;|3fe06 A 2,1301-06 ;

SV 001 PER 005 9.640E-07 4.220E-06 4.220E-06

SV 001 PER 006 4.120E-07 1.800E-06 1.800E-06


Chromium compounds

EU 003 PER 006 3.840E-06 1 680E-05 1.680E-05

EU 008 PER 006 5.490E-06 2 400E-05 2.40GE-05

EU 014 PER 006 8.100E-06 3.550E-05 3.550E-06

SV 001 PER 005 1.610E-05 7.040E-05 7.040E-05

SV 001 PER 006 6.860E-06 a;ii|i-cfc $ 3.010E-05


Cumene

EU 001 PER 005 4.000E-02 1.750E+00 1.700E-01

EU 001 PER 006 1.600E-02 7.100E-02

EU 002 PER 005 1.600E-02 6.800E-01 6.800E-02

EU 002 PER 006 1.300E-02 5;6l}p-qi A :: |

Page 2 of 12

MiNNl-.SOl'A POLLLTION CONTROi. ACii:\CV AiK Ol. Ai .i [ V ^20 i.AFAYEi II- ROAD ST. MA

FACILITY DESCRIPTION: Potential-to-emit (by pollutant)

Show: Active and Pending Records AQD Facility ID: 05301047 Facility Name: EDCO Products Ine


(Action)

Retired By

(Action)

Hourly Potential

(lbs per hr)


(tons per yr)

Limited Potential

(tons per yr)

Actual Emissions

(tons per yr)

Cunieno

EU 003 PER 005 1.260E-01 5.500E+00 5.500E-01

EU 003 PER 006 1.150E-01 5.044E+00 5,Q40E-01

EU 006 PER 005 3.590E-01 1.573E+01 1.570E+00

EU 006 PER 006 1.470E-01 6.42SE+00 6.43QE-G1

EU 007 PER 005 i 1.400E-02 l

6.100E-01 6.100E-02

EU 007 PER 006 O.OOOE+OO Q.0OOE+QO G.OODF+OO

EU 010 PER 006 5.900E-02 2.600E-01 2,eooE-or;a EU 012 PER 006 2.900E-02 1.270E-01 :: 1.27QE-01 :

Totals 1.313E+01 1.661 E+00 O.OOOE+OO

1,4-Dichlorobenzene

EU 003 PER 006 3.290E-06 1.44t)E-05 :1.440Es05 : ;

EU 008 PER 006 4.710E-06 2Q60E-QB: 2:0|6E-0§ J

EU 014 PER 006 6.940E-06 3M0E-05 3.O4OE-05

SV 001 PER 006 5.880H-06 2.58QE%5.;;. 2.5OTK05 s


Ethyfbenzene

EU 001 PER 005 1.900E-01 2.020E+00 8.340E-01

EU 001 PER 006 3.080E-01 1.349E+01 : 1.348E+00

EU 002 PER 005 2.190E-01 3.270E+00 9.590E-01

EU 002 PER 006 2.420E01 1.0596*0 V 1.059E%30 i

EU 003 PER 005 4.760E-01 2.083E+01 2.080E+00

EU 003 PER 006 2.175E+00 9,528£«Q1 ^ 9 528E+00

EU 006 PER 005 2.710E+00 1.187E+01 1.190E+00

EU 006 PER 006 2.771 E+00 1J14E+g2: 1.214E+01

EU 007 PER 005 5.300E-01 2.310E+00 2.310E-01

EU 007 PER 006 0.000E+00 0.000E+00 amsmi: EU 010 PER 005 6.900E-02 3.040E-01 3.040E-01

EU 010 PER 006 1.123E+00 4:fil7EpO;V

EU 012 PER 005 6.900E-02 3.040E-01 3.040E-01

EU 012 PER 006 5.490E-01 2:403E+gO • I.403E+0O


Formaldehyde

EU 001 PER 005 4.000E-03 1.500E-01 1.S00E-02

EU 001 PER 006 5.000E-03 1:88|Ei-01; v:: 2.000E-02

EU 002 PER 005 | 3.000E-03 1.500E-01 1.500E-02 |

MiNM-SOTA POLL! I iO.\ CONTROL XGL'Xt Y AJR OUA I.I ! l ?20 LAIvWl-.T'lT. HO AO Si: I'AI-L. MX :>Sl3?-4iy.1

Page 3 of 12

2 June. 2015 11:45


Show: Active and Pending Records AQD Facility ID' 05301047 Facility Name: EDCO Products inc


(Action)

Retired By

(Action)

Hourly Potential

(lbs per hr)


(tons per yr)

Limited Potential

(tons per yr)

Actual Emissions

(tons per yr)

Formaldehyde

EU 002 PER 006 4.000E-03 1.560E-01 1.800E-02

EU 003 PER 005 2.800E-02 1.230E+00 1.230E-01

EU 003 PER 006 3.200E-02 1,401£+00 1.400E-01

EU 006 PER 005 3.200E-02 1.390E+00 1.390E-01

EU 006 PER 006 4.100E-02 1.785E+00 1780E-01

EU 007 PER 005 3.000E-03 1.400E-01 1.400E-02

EU 007 PER 006 0.000E+00 O.OOOE+OO D.OOQE+OO

EU 008 PER 006 2.940E-04 1.29OE-03 1.29OE-03

EU 010 PER 006 1.700E-02 7.200E-02 7.2Q0E-02

EU 012 PER 006 8.000E-03 3.500E-02 3.50QE^02

EU 014 PER 006 4.340E-04 1(9O0E-O3: 1.S^pE-03

SV 001 PER 005 8.610E-04 3.770E-03 3.770E-03

SV 001 PER 006 3.680E-04 1.610E-03 N.610E-03 Totals 3.652E+00 4.658E-01 O.OOOE+OO

Hexane

EU 003 PER 006 4.940E-03 2.160E-02 : 2.160E-02

EU 008 PER 006 7.060E-03 i5§0E-6i; 3.090E-02 : i

EU 014 PER 006 1 04OL 02 4.560&02::

SV 001 PER 005 2.070E-02 9.050E-02 9.050E-02

SV 001 PER 006 8.820E-03 8:S6i0Er02; 3.86pp;:K

Totals 1.367E-01 1.367E-01 0.000E+00

Methyl ethyl ketone (MEK)

EU 001 PER 005 0.000E+00 O;BOOE+0fi

EU 002 PER 005 0.000E+00 O.OOOE+Od

EU 003 PER 005 O.OOOE+OO 0:OOQi*pOT:;

EU 006 PER 005 0.000E+00 gigpfo EU 007 PER 005 0.000E+00 O.OOOE^#

Totals O.OOOE+OO O.OOOE+OO O.OOOE+OO

Methyl Isobutyl ketone

EU 001 PER 005 1.220E-01 5.340E+00 5.340E-01

EU 001 PER 006 0.000E+00 OflOOfjOOA owotHxy;! EU 006 PER 005 1.100E+00 4.809E+01 4.810E+00

EU 006 PER 006 0.000E+00 Q;0Q0E't-a0 0.(8p+(®:

Totals O.OOOE+OO O.OOOE+OO O.OOOE+OO

Glycol ethers

EU 001 PER 005 1.550E-01 6.800E+00 6.800E-01

Page 4 of 12

MiNNhSOTA POLLUTION OOX'TROLAGlvNOY AIR Qi;At! ("V -K'LAl.W LTJ L ROAD ST. PAVl . MA 5S 155-41^4

• 2 June. 2015 11:45

FACILITY DESCRIPTION: Potenlial-to-emit (by pollutant)



(Action)

Retired By

(Action)

Hourly Potential

(lbs per hr)


{tons per yr)

Limited Potential

(tons per yr)

Actual Emissions

(tons per yr)

Glycol ethers

EU 001 PER 006 4.650E-01 2.Q39E+01, 2,039)5+00

EU 002 PER 005 2.230E-01 9.780E+00 9.780E-01

EU 002 PER 006 3.650E-01 1.601 £+01 1.801E+Q0

EU 003 PER 005 1.810E+00 7.926E+01 7.930E+00

EU 003 PER 006 3.289E+00 1.44QE+02 1.441E+01

EU 006 PER 005 1.400E+00 6.122E+01 6.120E+00

EU 006 PER 006 4.1 SQL-i on 1.835E+02 1:835§H)1 A

EU 007 PER 005 2.010E-01 8.810E+00 8.810E-01

EU 007 PER 006 O.OOOE+OO OJOOE+fO 0.OOOE+OO [ EU 010 PER 006 1.697E+00 M33E+er 7.43SE+00 :

EU 012 PER 006 8.300E-01 3«W: 3.633E+00

Totals 3.750E+02 4.746E+01 0 OOOL '00

Naphthalene

EU 001 PER 005 8.200E-02 3.600E+00 3.600E-01

EU 001 PER 006 8.100E-02 3M0E+6& 3.570E-01

EU 002 PER 005 2.510EI-01 1.099E+01 1.100E+00

EU 002 PER 006 6.400E-02 2.802E+00 2.8OQ|§0T.\

EU 003 PER 005 2.030E+00 8.905E+01 8.900E+00

EU 003 PER 006 5.760E-01 2.522E+01 : g.S&E+OO1

EU 006 PER 005 7.410E-01 3.244E+01 3.24QE+00

EU 006 PER 006 4.340E-01 l||3Efi&ij u 190«W • | EU 007 PER 005 2.260E-Q1 9.890E+00 9.890E-01 |

EU 007 PER 006 0.000E+00 6;|p0Et0O: 0.0B0E+00a; | i -;S:IXifK EU 008 PER 006 2.390E-06 1yCpE-|5: :

EU 010 PER 005 2.600E-02 1.120E-01 1.120E-01

EU 010 PER 006 2.970E-01 1.301E+00 :

EU 012 PER 005 2.600E-02 1.120E-Q1 1.120E-01

EU 012 PER 006 1.450E-01 6 360E-01 6.36QE-01

EU 014 PER 006 3.530E-06 1.550E-05 1.550E-05

SV001 PER 005 7.000E-06 3.070E-05 3.070E-05

SV 001 PER 006 2.990E-06 1.310E-05


HAPs - Total

EU 001 PER 005 2.240E+00 7.273E+01 9.800E+00

| EU 001 PER 006 | 5.020E-01 2.198E+01

MiNNhSOlA !}0!.i .1. HON CONTROL AULN' V AIR QUA].! IT ?:0 1 AF AYHm-. KOAD ST PAUL. MN 5S15MI91

Page 5 of 12

2 June. 2015 11:45


Show: Active and Pending Records AQD Facility ID" 05301047 Facility Name: EDCO Products Inc

• Pollutant Item Added By

(Action)

Retired By

(Action)

Hourly Potential

(lbs per hr)


{tons per yr)

Limited Potential

(tons per yr)

Actual Emissions

(tons per yr)

HAPs - Total

EU 002 PER 005 2.240E+00 7.300E+01 9.830E+00

EU 002 PER 006 1.273E+00 5:§75E+Q1 5.575E+00

EU 003 PER 005 1.300E+01 5.685E.+02 5.690E+01

EU 003 PER 006 1.146E+01 5.018E+02 5.020E+01

EU 006 PER 005 1.440E+01 6.293E+02 6.290E+01

EU 006 PER 006 | 4.516E+00 1.978E+02 1.078E+O1

EU 007 PER 005 1.440E+00 6.317E+01 6.320E+00

EU 007 PER 006 O.OOOE+OO OMGOE+OO P.OOIE+OO

EU 008 PER 006 7.000E-03 3.200E-02 • 3;?00E-02:

EU 010 PER 005 1.420E+00 6.220E+00 6.220E+00

EU 010 PER 006 1.251E+01 5.477E+01 5^776+01

EU 012 PER 005 | 1.420E+00 6.220E+00 6.220E+00

EU 012 PER 006 6.113E+00 2.677E+01 2,677lpjj

EU 014 PER 006 1.100E-02 4.8066-02 : 4:§«E-02

GP 001 PER 005 D.OPOE+OO

SV 001 PER 005 2.170E-02 9.480E-02

SV 001 PER 006 9.000E-03 4.T00E-Q2 4.10QE-02

Totals 8.590E+02 1 594E+02 O.OOOE+OO

Mercury Compounds

EU 003 PER 006 7.140E-07 3:i3ogm& 3.13QE-06

EU 008 PER 006 1.020E-06 4.4?fi6-06 i; 4:WflE-06 ™ SfH VH SA#A EU 014 PER 006 1.500E-06 9.590E-0B Si AAIAA -SV 001 PER 005 2.980E-06 1.310E-05 1.310E-05

SV 001 PER 006 1.270E-06 5:5806-06 : B.smm . Mill:.. . Totals 1.977E-05 1.977E-05 O.OOOE+OO

Toluene

EU 001 PER 005 1.080E+00 2.370E+01 4.750E+00

EU 001 PER 006 1.354E+00 5.929E+00 -EU 002 PER 005 6.090E-01 2.940E+00 2.670E+00

EU 002 PER 006 1.063E+00 4:<5§5£+0A :: 4.655E+00 A ASK v. EU 003 PER 005 5.500E-02 2.410E+00 2.410E-01

EU 003 PER 006 9.565E+00 4:1,90E+02 -fl;: ftisoE+oiite LAIIIS,-EU 006 PER 005 4.330E+00 1.900E+02 1.900E+01

EU 006 PER 006 1.218E+01 &3a6E4-t)2 5.337E+01, JAIIA ; J EU 007 PER 005 6.000E-03 2.680E-01 2.700E-02 |

MINNESOTA POI.!.LTIO?S CONTROL AIR O l.Ai.M V fv20 i. U'AYhTIT. ROAD ST. PAUI.. MA 55I5>4)V4

Page 6 of 12

MINM-.SOTA s?oi.Li, no\ coM'Roi. Aui'NO 2 June. 201 5 11:45 AIR QUA1J i Y

FACILITY DESCRIPTION; Potential-to-emit (by pollutant)

Show: Active and Pending Records AQD Facility ID' 05301047 Facility Name: EDCO Products Inc


(Action)

Retired By

(Action)

Hourly Potential

(lbs per hr)


(tons per yr)

Limited Potential

(tons per yr)

Actual Emissions

(tons per yr)

Toluene

EU 007 PER 006 O.OOOE+OO O.OOOE+OO 0;OOOE+Ot)

EU 008 PER 006 1.330E-05 5.S40E-05 : 5.84OE-05

EU 010 PER 006 4.936E+00 2.162E+01 2.162E+01

EU 012 PER 006 2.413E+00 H057E+O1 1.0571+01

EU 014 PER 006 1.970E-05 8.610E-05 8:610E-0S

SV 001 PER 005 3.900E-05 1.710E-04 1.710E-04

SV 001 PER 006 1.670E-05 7.30OE-O5 7.3Q06435 •


Triethylamine

EU 001 PER 006 | 1.000E-03 5.9QOE-02 6."0OOE-O3,v |

EU 002 PER 006 1.000E-03 4.7Q0E-02 ; 5.0QQ6-03-

EU 003 PER 006 1.000E-02 4J00E-01 4.20OE4&

EU 006 PER 006 1.200E-02 5:350fg)f 5:«OOE4)2 ; ;

EU 010 PER 006 5.000E-03 2.#0E-02 < 2.200E-G2

EU 012 PER 006 2.000E-03 1,100E-p2 1.1QGE# J;

Totals 1.094E+00 1.400E-01 O.OOOE+OO

Xylenes (mixed isomers)

EU 001 PER 005 7.700E-01 8.320E+00 3.360E+0Q

EU 001 PER 006 1.503E+00 6.i}84Ef01 6.584E+G0

EU 002 PER 005 1 .OOOE+OO 1.841E+01 4.370E+00

EU 002 PER 006 1.180E+00 5. ip9E+01 5.1|9S*W |

EU 003 PER 005 2.880E+00 1.264E+02 I.260E+01

EU 003 PER 006 1.062E+01 4,^52Ej02 4;652p0f::

EU 006 PER 005 1 130E+00 4.956E+01 4.960E+00

EU 006 PER 006 1.353E+01 5|25£f02 5.925E+01

EU 007 PER 005 3.210E-01 1.404E+01 1.4G0E+00

EU 007 PER 006 O.OOOE+OO o.ofiofcfioc O.OOOE+OO

EU 010 PER 005 2.740E-01 1.200E+00 1.200E+00

EU 010 PER 006 5.480E+00 2,#01EJ-01: ' 2.401 E+01

EU 012 PER 005 2.740E-01 1.200E+00 1.200E+00

EU 012 PER 006 2.679E+00 1.173E+Q1 1.173E+01


Manganese compounds

EU 003 PER 006 1.CM0E-06 4.f?0fr#3? 4;570Ei0e::;|:

EU 008 PER 006 | 1.490E-06 6p0g|)6 : 6:530|-Q|H I ' fvflll:-

Page 7 of 12

2 June. 2015 11:45


Show; Active and Pending Records AQD Facility ID' 05301047 Facility Name; EDCO Products inc


(Action)

Retired By

(Action)

Hourly Potential

(lbs per hr)


(tons per yr)

Limited Potential

(tons per yr)

Actual Emissions

(tons per yr)

Manganese compounds

EU 014 PER 006 2.200E-06 9.630E-06 9.630E-Q8

SV 001 PER 005 4.360E-06 1.910E-05 1.910E-05

SV 001 PER 006 1.860E-06 %16@E-06 :• 8/i6®06T:

Totals 2.8S9E-05 2.889E-05 O.OOOE+OO

Dimethyl formamide

EU 001 PER 005 6.000E-02 2.630E+00 2.630E-01

EU 001 PER 006 O.OOOE+OO Q.GOOE+0Q O.OO0E+O6

EU 006 PER 005 5.400E-01 2.365E+01 2.370E+00

EU 006 PER 006 0.000E+00 OjQOE+dfe p,QQ0E|90 •:

Totals 0.000E+00 O.OOOE+OO O.OOOE+OO

Nitrous Oxide

EU 003 PER 006 1.000E-02 2;|0O©O2 2.4001-02

EU 008 PER 006 1.000E-02 3,500E-02 3.5OC5E-02 •

SV 001 PER 006 1.000E-02 43Q0E-O2L 4,39pE|® S Totals 1.020E-01 1.020E-01 O.OOOE+OO

Isophorone

EU 001 PER 005 1.300E+00 5.693E+01 5.690E+00 |

EU 001 PER 006 1.169E+00 S.118E+01 :/ 5.1186+00 f

EU 002 PER 005 1.170E+00 5.113E+01 5.110E+00

EU 002 PER 006 9.170E-01 4v018E+01 4.01.86+00' [ EU 003 PER 005 9.460E+00 4.141E+02 4.14GE+01 |

EU 003 PER 006 8.257E+00 3,817E^Q2" • 3.6:1?E+01- [

EU 006 PER 005 1.170E+01 5.123E+02 5.120E+01

EU 006 PER 006 1.052E+01 4S07E+02: V 4.607E+01

EU 007 PER 005 1.050E+00 4.601E+01 4.600E+00

EU 007 PER 006 0.000E+00 f5.0i|E+!l;;. O.OOOE+OO

EU 010 PER 005 1.050E+00 4.600E+00 4.600E+00

EU 010 PER 006 4.261E+00 1.866E+01 §,8(pE+01 ,

EU 012 PER 005 1.050E+00 4.600E+00 4.600E+00

EU 012 PER 006 1 2.083E+00 9,iilE+0i: -. 9.122E+O0 i"

GP 001 PER 005 f O.OOOE+OO


Lead Compounds

EU 003 PER 006 1.370E-06 8.O10E-0S 1 8.010E-G6

EU 008 PER 006 1.960E-06 8.59QE-06 8.590E-O6

EU 014 PER 006 2.890E-06 T;370|#iil

Page 8 of 12

MlXNkSOl'A i'Oi.TSON CONTROL \GFKCY AER 01. Al.I I S

L AK-Vs LNL ROAD ST. PALL. MN M1S5-41SM

MiNNi-.so'i'A FoiJ.i/fiON CON'TKOL •U.HAC A 2 June. 2015 11:45 AIR Q UALITY

^MULMNfsisM^ FACILITY DESCRIPTION: Potential-to-emit (by pollutant)



(Action)

Retired By

(Action)

Hourly Potential

(lbs per hr)


(tons per yr)

Limited Potential

(tons per yr)

Actual Emissions

(tons per yr)

Lead Compounds

SV 001 PER 006 2.450E-06 1.Q70E-05 1.070E-Q5

Totals 3.800E-05 3.800E-05 0.000E+00

Nickel compounds

EU 003 PER 006 5.760E-06 2.520E-05 2.520Ej05

EU 008 PER 006 i 8.240E-06 i

3.81GE-05 3.610E-05 -j

EU 014 PER 006 1.210E-05 5,320E-Q5 5.320E-05 :

SV 001 PER 005 j 2.410E-05 1.060E-04 1.060E-04

SV 001 PER 006 1.030E-05 4.510E-0S: 4;S10E-05 i :

Totals 1 596E-04 1.596E-04 O.OOOE+OO

Nitrogen Oxides

EU 003 PER 001 5.900E-01 2.570E+00

EU 003 PER 006 2.750E-01 1.2026+00 ,2G2E-iOQ -f

EU 008 PER 001 8.400E-01 3.680E+00 I EU 008 PER 006 3.920E-01 i,|l#E+0D 1.718E+O0: |

EU 009 PER 005 j 0.000E+00 OflO0E«OK r€ A I AASAAA

EU 014 PER 006 5.780E-01 2.534E+O0;:s: 2.534E+00

SV 001 PER 001 1.100E+00 4.830E+00

SV 001 PER 006 4.900E-01 2;147E*00 2.147E+00

Totals 7.601 E+00 7.601 E+00 O.OOOE+OO

PM < 2.5 micron

EU 003 PER 006 2.100E-02 9,1006-62 r; 9.100E-02

EU 008 PER 006 3.000E-02 IfJOE'Ol : H.3WE0IA EU 010 PER 006 9.400E-02 5:1t3E+Q|g 4.140E-01

EU 012 PER 006 4.500E-02 2,#8fw •: 1.990E-01

EU 014 PER 006 4.400E-02 V93OE-01 1.930E-01

SV 001 PER 006 3.700E-02 1.630E-01 1.630E-01

Totals 8.239E+00 1.191E+00 0.000E+00

PM <10 micron

EU 003 PER 005 2.030E-02 8.880E-02 8.880E-02

EU 003 PER 006 | 2.100E-02 0.1OOE-O2 9.100E-02

EU 008 PER 005 2.900E-02 1.268E-01 1.268E-01

EU 008 PER 006 3.000E-02 1.310E-01 1.310E-01

EU 009 PER 005 0.000E+00 QH®QEM§^ •••••. EU 010 PER 005 4.700E-02 2.550E+00 2.040E-01

EU 010 PER 006 9.400E-02 5;f736t0® 4.140E-G1

EU 012 PER 005 4.700E-02 2.550E+00 2.040E-01

Page 9 of 12

MINNESOTA POLLUTION CONTROL AOl'NCY 2 June 2015 11:45 •MR QU ALITY " " ' *

5511M194 FACILITY DESCRIPTION: Potential-to-emit (by pollutant)



(Action)

Retired By

(Action)

Hourly Potential

(lbs per hr)


{tons per yr )

Limited Potential

(tons per yr)

Actual Emissions

(tons per yr)

PM < 10 micron

EU 012 PER 006 4.500E-02 2.488E-H30 1,990|-01

EU 014 PER 006 4.400E-02 1,930E.-tfl 1:930E-01 ; ;

SV 001 PER 005 3.800E-02 1.664E-01 1.664E-01

SV001 PER 006 3.700E-02 1.630E-01 ; 1.630E-01

Totals 8.239E+00 1.191E+00 0.000E+00

Polycyclic organic matter

EU 003 PER 006 2.420E-07 1,060E-06: 1.060E-06;

EU 008 PER 006 3.460E-07 1.510E-06i 1.510E-&6

EU 014 PER 006 5.100E-07 2.230E-06 2.230E-06

SV 001 PER 005 9.900E-07 4.340E-06 4.340E-06

SV 001 PER 006 4.320E-07 i:-:S90E-06i 1.89QE-06:.:


Total Particulate Matter

EU 003 PER 005 2.030E-02 8.880E-02 8.880E-02

EU 003 PER 006 2.100E-02 9:IOOEJ32, 9.100E-02

EU 008 PER 005 2.900E-02 1.268E-01 1.268E-01

EU 008 PER 006 3.000E-02 1.31"0E-01| 1 .310E-01 : $

EU 009 PER 005 O.OOOE+OO O.OOOE+OO: EU 010 PER 005 4.700E-02 2.550E+00 2.040E-01

EU 010 PER 006 9.4Q0E-02 5173E+00

EU 012 PER 005 4.700E-02 2.550E+00 2.040E-01

EU 012 PER 006 4.500E-02 2488E+00 1.990&O1 $

EU 014 PER 006 4.400E-02 1.93015-01$ 1.930E-01

SV 001 PER 005 3.800E-02 1.664E-01 1.664E-01

SV001 PER 006 3.700E-02 1.63OE-01 'f-• 1.630E-01


Selenium compounds

EU 003 PER 006 6.590E-08 2.890E-97 2.890E-07 ; : flllHI 11V EU 008 PER 006 9.410E-08 4®&E#|; II1#07 EU 014 PER 006 1.390E-07 6.080E-07

SV 001 PER 005 2.750E-07 1.210E-06 1.210E-06

SV 001 PER 006 1.180E-07 5.150E-07 8.1:#EJ07


HAP-Single

EU 001 PER 006 | 1.503E+00 I 6.584E+01 6;6fe4E*00; ;:

EU 002 PER 006 J 1 .180E+00 riigioo ;

Page 10 of 12

2 June. 2015 11:45


Show; Active and Pending Records AQD Facility ID: 05301047 Facility Name: EDCO Products Inc


(Action)

Retired By

(Action)

Hourly Potential

(lbs per hi)


{tons per yr)

Limited Potential

(tons per yr)

Actual Emissions

(tons per yr)

HAP-Single

EU 003 PER 006 1.062E+01 4.852E+02 4.652E+01

EU 006 PER 006 1.353E+01 5.9|5E-H32 5.925E+01

EU 010 PER 006 5.480E+00 M01E+O1 2,401 E+01 ;;

EU 012 PER 006 2.679E+00 1.#3E+£)1 1.173E+01


Sulfur Dioxide

EU 003 PER 001 9.300E-03 4.070E-02

EU 003 PER 006 2.000E-03 7.#0E-O3 7.000E-03:

EU 008 PER 001 1.330E-02 5.810E-02

EU 008 PER 006 j 2.000E-0 3 1.000E-O2 1.O0OE-O2

EU 009 PER 005 0.000E+00 O.OOOEfOO

EU 014 PER 006 3.000E-03 1 f.'OOE 02 1.50OE-02 A

SV 001 PER 001 1.740E-02 7.620E-02

SV001 PER 006 3.000E-03 1.30PE-O2 ; : 1.3Q0E-O2

Totals 4.500E-02 4.500E-02 0.000E+00

Volatile Organic Compounds

EU 001 PER 001 1.709E+01 2.029E+02

EU 001 PER 006 2.022E+00 8.854K01

EU 002 PER 001 1.653E+01 1.785E+02

EU 002 PER 006 1.490E+00 8.S?4E+01

EU 003 PER 001 2.181E+01 9.549E+02 6.780E-02

EU 003 PER 006 1.341E+01 5.872E+02

EU 006 PER 001 2.924E+01 1.281E+03

EU 006 PER 006 1.819E+01 7 J69E+® ;

EU 007 PER 001 2.420E+00 1.061E+02

EU 007 PER 006 0.000E+00 o#b#oo: EU 008 PER 001 2.000E-02 1.000E-01 9.680E-02

EU 008 PER 006 2.200E-02 9.400E-02

EU 009 PER 005 O.OOOE+OO O.OOOE+OO 0.000E+00

EU 009 PER 006 O.OOOE+OO O.OOOE+OO

EU 010 PER 005 1.250E+01 5.470E+01

EU 010 PER 006 1.463E+01

EU 012 PER 005 1.250E+01 5.470E+01

EU 012 PER 006 7.153E+00 3.133E+01

[ EU 014 PER 006 | 3.200E-02 1.390E 01 l.39<JE-0f!: :; J v I llllSl; j

VIINNhSO ] \ POLLUTION CONTROL AOLM.Y AIR OUAS.J 1 Y .^0 I U.Vi L I ; L K OAD ST. PAUL. MN 55155-4194

Page 11 of 12

2 June. 2015 11:45


Show: Active and Pending Records AQ.D Facility ID' 05301047 Facility Name: EDCO Products Inc


(Action)

Retired By

(Action)

Hourly Potential

(lbs per hr)


(tons per yr)

Limited Potential

(tons per yr)

Actual Emissions

(tons per yr)

Volatile Organic Compounds

GP 001 PER 005 2.350E+02

GP 001 PER 006 2,250E+02

SV 001 PER 001 3.000E-02 1.300E-01 1.300E-01

SV 001 PER 006 2.700E-02 1.180E-01

Totals 1.634E+03 2.251 E+02 0.000E+00

MINNESOTA 1'Ol.U.'HON CON TROL At it'K'i'"V AIR ObAUI'Y

I AlAYK i TL ROAD ST. PAl'i.. MN HI5MW

Page 12 of 12

M:\Ni.Si) i A POU riKAiii'aROi AG1AC AIR CH Ai 1TY 5?0 LAFAYF1 IT ROAD M. PAUL, MN 55l?5-4i'M

Facility Name:

Permit Number:

EDCO Products Inc

05301047-006

Subject Item: Total Facility

Pago 1 of 28 2 Jun. 2015 11:38

COMPLIANCE PLAN CD-01

NC/ CA

Type Citation Requirement

1.0 CD hdr SOURCE-SPECIFIC REQUIREMENTS

2.0 CD Minn. R. 7007 0800 , subp 2 Permit Appendices. This permit contains appendices as listed in the permit Table of Contents. The Permittee shall comply with all requirements contained in the appendices. The appendices are as follows:

Appendix A: Operator's Summary (not used) Appendix B: New Source Performance Standards Calculations: 40 CFR pt. 60. subp. TT Appendix C: 40 CFR pt. 63 subp. MMMM Compliance Equations Appendix D: Insignificant Activities and General Applicable Requirements Appendix E. Maximum Contents of Materials and Process Parameters

3.0 CD Title I Condition: To avoid classification as a major source under 40 CFR Section 52.21 and Minn. R 7007.3000

This permit establishes limits on the facility to ke ep it a m inor source under New Source Review. The Permittee cannot make any change at the sourc e that would make the source a major source under New Source Review until a permit amendment has been issued. This includes changes that might otherwise qualify as insignificant modifications and minor or moderate amendments.

4,0 S/A Minn. R. 7007.0800, subp. 2 Annual Report: due 31 days after end of each calendar year following Permit Issuance. The Permittee shall submit an annual report by January 31st tha t describes the changes made at the facility during the previous calendar year using the latest MPCA application forms. The report shall include the emission unit, stack/vent, group, and control equipment data for any new or replaced units or control devices. The report shall document the VOC 12-month rolling sum calculations for the previous calendar year. The report shall be submitted with the annual Compliance Certification listed in Table B. As part of the Annual Report, the Permittee shall verify arid certify that the facility has maintained minor source status for New Source Review.

5,0 CD Minn. R. 7007.0800, subp. 2 Equipment Labeling: The Permittee shall permanently affix a unique number to each emissions unit for tracking purposes. The numbers shall correlate the unit to the appropriate EU and GP numbers used in this permit. The number can be affixed by placard, stencil, or other means. The number shall be maintained so that it is readable and visible at all times from a safe distance. If equ ipment is added, it shall be given a new unique number: numbers from replaced or removed equipment shall not be reused.

6.0 CD Minn. R. 7007.0800. subp. 2 Equipment inventory: The Permittee shall maintain a written list of all emissions units and control equipment on site. The Permittee shall update the list to include any replaced, modified, or new equipment prior to making the change.

The list shall correlate the units to the numbers used in this permit (EU, GP, CE) and shall include the data on GI-04, G1-05B, and GI-05C. The date of construction shall be the date the change was made for replaced, modified, or new equipment.

7.0 CD hdr OPERATIONAL REQUIREMENTS

8.0 CD Minn. Stat. Section 116.07, subds. 4a & 9; Minn. R. 7007.0100. subp. 7(A), 7(L), & 7(M); Minn. R. 7007,0800, subps. 1, 2 & 4; Minn. R. 7009.0010-7009.0080

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

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

10.0 CD Minn. R. 7007.0800. subp. 2: Minn. R. 7007.0800, subp. 16(J)

Air Pollution Control Equipment: Operate all pollution control equipment whenever the corresponding process equipment and emission units are operated.

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

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

MIVN'KSOiAPOt.M'lK>N CON'IROI AOI-.NCY / V J \ AIROUAITI Y

<?!> i. ••\FAYirnT' ROAD ST. PAUL MN 5SI55-4I04

F acility Name: EDCO Products Inc


Page 2 of 28 2 Jun, 2015 11:38


12 0 CD Minn. R. 7019.1000, subp. 4 Operation Changes: In any shutdown, breakdown, or deviation the Permittee shall immediately take all practical steps to modify operations to reduce the emission of any regulated air pollutant. The Commissioner may require feasible and practical modifications in the operation to reduce emissions of air pollutants. No emissions units that have an unreasonable shutdown or breakdown frequency of process or control equipment shall be permitted to operate.

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

14.0 CD Minn. R. 7030.0010 - 7030.0080 Noise: The Permittee shall comply with the noise standards set forth in Minn. R. 7030,0010 to 7030.0080 at all times during the operation of any emission units. This is a state only requirement and is not enforceable by the EPA Administrator or citizens under the Clean Air Act.

15.0 CD Minn. R. 7007 0800. subp. 9(A) Inspections: The Permittee shall comply with the inspection procedures and requirements as found in Minn. R. 7007.0800, subp. 9(A).

16.0 CD Minn. R. 7007.0800. subp. 16 The Permittee shall comply with the General Conditions listed in Minn, R. 7007,0800, subp. 16.

17.0 CD hdr PERFORMANCE TESTING

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

19.0 CD Minn. R. 7017.2018: Minn. R. 7017.2030. subps. 1-4. Minn. R. 7017.2035, subps. 1-2

Performance Test Notifications and Submittals:

Performance Tests are due as outlined in Table A of the permit. See Table B for additional testing requirements.

Performance Test Notification (written): due 30 days before each Performance Test Performance Test Plan: due 30 days before each Performance Test Performance Test Pre-test Meeting: due 7 days before each Performance Test Performance Test Report: due 45 days after each Performance Test Performance Test Report - Microfiche Copy, due 105 days after each Performance Test

The Notification. Test Plan, and Test Report may be submitted in an alternative format as a llowed by Minn. R. 7017.2018.

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

21.0 CD hdr MONITORING REQUIREMENTS

22.0 CD Minn. R, 7007.0800, subp. 4(D) Monitoring Equipment Calibration - The Permittee shall either:

1. Calibrate or replace required monitoring equipment every 12 months; or 2. Calibrate at the frequency stated in the manufacturer's specifications.

For each monitor, the Permittee shall maintain a record of all calibrations, including the date conducted, and any corrective action that resulted. The Permittee shall include the calibration frequencies, procedures, and manufacturer's specifications (if applicable) in the Operations and Maintenance Plan. Any requirements applying to continuous emission monitors are listed separately in this permit.

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

24.0 CD hdr RECORDKEEPING

\n^\rsoT:\ POi f .r i io\ COMROI Ani.NO AIR QUALITY 5-Hi LA.rAYi"! Tf- RO M)

. PAl/i.. \!\ 5^5-iiM

Facility Name: EDCO Products Inc

Permit Number: 0530104? - 006

Page 3 of 28 2 Jun.2015 11.38


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

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

27.0 CD Minn. R. 7007,1200, subp. 4 If the Permittee determines that no permit amendment or notification is required prior to making a change, the Permittee must retain records of all calculations required under Minn, R. 7007,1200. These records shall be kept for a period of five years from the date the change was made or until permit reissuance, whichever is longer. The records shall be kept at the stationary source f or the cur rent calendar year of operation and may be kept at the stationary source or office of the stationary source for all o ther years . The records may be maintained In either electronic or paper format.

28,0 CD heir REPORTING/SUBMITTALS

29.0 CD Minn. R. 7019.1000, subp. 3 Shutdown Notifications: Notify the Commissioner at leas t 24 hours in advance of a planned shutdown of any control equipment or process equipment if the shutdown would cause any increase in the emissions of any regulated air pollutant. If the owner or operator does not have advance knowledge of the shutdown, notification shall be made to the Commissioner as soon as possible after the shutdown. However, notification is n ot required in (he circumstances outlined in Items A, B and C of Minn. R, 7019,1000. subp. 3.

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

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

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

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

32.0 CD Minn, R. 7019.1000, subp. 1 Notification of Deviations Endangering Human Health or the Environ ment Report: Within 2 working days of discovery, notify the Commissioner in writing of any deviation from permit conditions which could endanger human health or the environment. Include the following information in this written description: 1. the cause of the deviation; 2. the exact dates of the period of the deviation, if the deviation has been corrected; 3. whether or not the deviation has been corrected; 4. the anticipated time by which the deviation is expected to be corrected, if not yet corrected; and 5. steps taken or planned to reduce, eliminate, and prevent reoccurrence of the deviation.

33.0 S/A Minn, R. 7007.0800, subp. 6(A)(2) Semiannual Deviations Report: due 30 days after end of each calendar half-year following Permit Issuance. The first semiannual report submitted by the Permittee shall cover the calen dar half-year in which the permit is issued. The first report of each calendar year covers January 1 - June 30. The second report of each calendar year covers July 1 - December 31. If no deviations have occurred, the Permittee shall submit the report stating no deviations.

Mi\'NL$0'iA POLLUTION CONTROL AG1;.N( / V J \ AIR 01 AilTY

550 LAFAYFTTf ROAD ST. f'AL 'i.. MN 55155-4 I'M



Page 4 of 28 2 Jun, 2015 11.38


34.0 CD Minn. R, 7007.1150- 7007.1500 Application for Permit Amendment: If a permit amendment is needed, submit an application in accordance with the requirements of Minn R. 7007.1150 through Minn. R. 7007,1500. Submittal dates vary, depending on the type of amendment needed.

35.0 S/A Minn. R. 7007.0400, subp. 2 Application for Permit Reissuance: due 180 days before expiration of Existing Permit

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

37.0 S/A Minn. R. 7007.0800, subp. 6(C) Compliance Certification: due 31 days after end of each calendar year following Permit Issuance (for the previou s calendar year). The Permittee shall submit this on a form approved by the Commissioner, both to the Commissioner and to the US EPA regional office in Chicago. This report covers all deviations experienced during the calendar year.

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

39.0 CD Minn. R. 7002.0005-7002.0095 Emission Fees: due 30 days after receipt of an MP CA. bill.

MiXVj'SO lA POi AIR 01 AU1Y

l .AFAYFn t ROAD

ON CONTROL AGENCY

S'l. PALI.

Facility Name:

Permit Number:

Subject Item:

Associated Items:

MN 53155-J lc^

EDCO Products Inc

05301047 - 006





EU 003 Finish Overi (2-Zone) Dryer/Oven, unknown firing method





EU 010 Paint Booth I Spray Booth/Coating Line

EU 011 Flat Line Contin uous Flow Oven (IR) Process Heater



Page 5 of 28

COMPLIANCE PLAN

2 Jim. 2015 11:38

CD-01

NC/ CA


1.0 LIMIT Title 1 Condition: To avoid classification as major source and modification under 40 CFR Section 52.21 & Minn. R. 7007,3000

Volatile Organic Compounds: less than or equal to 225.0 tons/year using 12-month Rolling Sum to be calculated by the 15th day of each month for the previous 12-month period as described later in this permit. All noncombustion VOC-emitting equipment at the Facility other than that listed in Appendix D of the permit is subject to this limit and shall be included in the 12-month roiling sum calculation.

VOC contents for each VOC-containing material shall be determined as described under the Material Content requirement in GP 001, Credit is given for the VOCs controlled by CE 001, The calculation of VOCs used may take into account recovered/recycled VOCs as described under the Waste Credit requirement in GP 001.

2,0 CD Title I Condition: To avoid classification as major source and modification under 40 CFR Section 52.21 & Minn. R. 7007.3000

All VOC-emitting equipment at the Facility is subject to thi s limit. If the Permittee replaces any exis ting VOC-emitting equipment, adds new VOC-emitting equipment, or modifies the existing equipment, such equipment is subject to this permit limit as well as all of the requirements of GP 001. Prior to making such a change, the Permittee shall apply for and obtain the appropriate permit amendment, as applicable. The Permittee is n ot required to complete VOC calculations described in Minn. R. 7007,1200, subp, 2, A permit amendment will still be needed regardless of the emissions increase if the change will be subject to a new applicable requirement or requires revisions to the limits or monitoring and recordkeeping in this permit.

3.0 CD Title I Condition: To avoid classification as major source and modification under 40 CFR Section 52.21 & Minn. R. 7007.3000:

Pre-Authorized Changes to GP 001. The Permittee may replace EU 006 with like-kind equipment (IR ovens) during the term of this permit. In addition, the Permittee may add a new oven, EU 008, as specified later in this permit. Ail changes must meet all other permit limits.

If a proposed change triggers an applicable requirement not contained in this permit (e.g., 40 CFR pt, 63), the change must go through the appropriate procedure in Minn. R. ch. 7007.

4.0 CO hdr MONITORING AND RECORDKEEPING

5,0 CD Title I Condition: To avoid classification as major source and modification under 40 CFR Section 52.21 & Minn. R. 7007.3000: Minn. R. 7007.0800, subp. 4 and 5

Daily Recordkeeping. On each day of operation, the Permittee shall record and maintain the quantity of all VOC-containing materials used in any coating operation at the Facility, This shall be based on written usage logs and/or purchase records.

For all other VOC-containing materials used at the Facility (i.e., clean up solvent), the Permittee shall keep monthly records of materials purchased or used.

MI\'N|-'SOiAPOU.l."nO\ COXiROi AGUNC" \ AIROl'UiTY

5?0 I.AFAVrf'IT: ROAD ST. PAH.. MX 5rl5.5~m<l


Permit Number- 05301047 - 006

Page 6 of 28 2 Jun. 2015 11:38


6.0 CD Minn, R, 7007.0800. subps. 4 and 5

Monthly Recordkeeping VOC Emissions. By the 15th of the month, the Permittee shall calculate and record the following: 1) The total usage of VOC-containing materials for the previous calendar month using the daily usage and monthly purchase records. This record shall show VOC materials used at the controlled vs. uncontrolled emissions units and shall also include the VOC contents of each material as determined by the Material Content requirement of this permit. 2) The VO C emissions for the previous month using the formulas specified in this permit. 3) The 12-month rolling sum VOC emissions for the previou s 12-month period by summing the monthly VOC emissions data for the previous 12 months.

7.0 CD Minn, R. 7007.0800. subps. 4 and 5

Monthly Calculation - VOC Emissions, The Permittee shall calculate VOC emissions using the following equations:

VOC (tons/month) = [VC x ((100-Q/100)] + VU -VW VC = (A1 x B1) + (A2 x B2) + (A3 x B3) + .... VU = (D1 x E1) + (D2 x E2) + (D2 x E2) + .... VW= (F1 x G 1) + (F2 x G2) + (F3 x G3) + ....

8.0 CD Minn. R. 7007.0800. subps, 4 and 5

Monthly VOC Emissions Calculation Continued:

where: VC = total VOC used at equipment vented to the thermal oxidizer, CE 001 in tons/month; A# = amount of each VOC -containing material used, in tons/month; B# = weight percent VOC in A#, as a fra ction: C = the overal l control efficiency for CE 001. This shall be the value as required by this permit for CE 001; VU = total VOC used that is NOT vented to the thermal oxidizer, in tons/month D# = amount of each VOC-containing material used, in tons/month; E# = weight percent VOC in D#, as a f raction; VW - the amount of VOC shippe d in waste, in tons/month, F# - amount, in tons/month, of each VOC-containing waste material shipped. If the Permittee chooses to not take credit for waste shipments, this parameter would be zero; and G# = weight percent of VOC in F#, as a fra ction.

9.0 CD Minn, R, 7007.0800, subps. 4 and 5

Material Content: VOC contents in materials shall be determined by the Material Safety Data Sheet (MSDS) provided by the supplier for each material used. If a material content range is given on the MSDS, the highest number in the range shall be used in all compliance calculations. Other alternative methods approved by the MPCA may be used to determine the VOC contents. The Commissioner reserves the right to require the Permittee to determine the VOC contents of any material, according to EPA or ASTM reference methods. If an EPA or ASTM reference method is used for material content determination, the data obtained shall supersede the MSDS.

10.0 CD Minn. R, 7007.0800, subps. 4 and 5

Waste Credit: If the Permittee elects to obtain credit for VO C shipped in waste materials, the Permittee shall either use item 1 or 2 to determine the VOC content for each credited shipment. 1) The Permittee shall analyze a composite sample of each waste shipment So determine the weight content of VOC excluding water. 2) The Permittee may use supplier data for raw materials to determine the VOC contents of each waste shipment, using the same content data used to determine the content of raw materials. If the waste contains several materials, the content of mixed waste shall be assumed to be the lowest VOC content of any of the materials.

11.0 CD Minn. R. 7005.0100, subp. 35a Maximum Contents of Materials and Process Parameters: The Permittee assumed certain worst-case contents of materials when determining the annual arid short term potential to emit of units in GP 001. These assumptions are listed in Appendix E of this pe rmit. Changing to a material that haS a higher content of any of the given pollutants is considered a change in method of operation that must be evaluated under Minn. R. 7007.1200, subp. 3 to determine if a permit amendment or notification is required under Minn. R. 7007.1150.

M. PAUi.

Facility Name:

Permit Number:

Subject Item:

Associated Items:

XU\M:SOIA PO! •URQlWiriY

LM'AYrni' ROAD MN 551 r-5-4 1

no\ o r'ROi Mil-XT Page 7 of 28

COMPLIANCE FLAN

2Jun. 2015 11:38

CD-01 EDCO Products Inc

0530104? - 006





EU 003 Finish Overi (2-Zone) Dryer/Oven, unknown firing method





SV 001 Coating Emissions

SV 002 Primer/Backer Quench

SV 003 Top Coat Quench

NC/ CA


1.0 CD 40 CFR Section 60.460; Minn, R. 7011.2570

The requirements of this portion of Table A apply to each affected facility in a metal coil surface coating operation: each prime coat operation, each finish coat operation, and each prime and finish coat operation combined when the finish coat is applied wet on wet over the prime coat and both coatings are cured simultaneously. At the time of permit issuance, EUs 001-006 and 008 are considered affected facilities.

2.0 CD 40 CFR Sections 60.2 and 60.461: Minn, R, 7011.0050 and 7011.2570

Terms used in this portion of Table A are as defined in state air pollution control rules or as defined in 40 CFR pt. 60. subps. A and TT. The definitions from 40 CFR Section 60.461 are included in Appendix B of this permit for clarity.

3.0 CD hdr EMISSION REQUIREMENTS

4.0 • LIMIT 40 CFR Section 60.462(a)(3), Minn. R. 7011.2570 '

Volatile Organic Compounds: less than or equal to 10 percent of the VOCs applied at each affected facility in GP 002 shall be emitted, for each calendar month (90 percent emission reduction).

5.0 CD hdr MONITORING AND RECORDKEEPING

6.0 CD 40 CFR Section 60.463(c): Minn, R. 7011,2570

When required by 40 CFR Section 60.463(c)(2)(i). the Permittee shall use the procedures detailed in Appendix 8 of this permit for determining monthly volume-weighted average emissions of VOCs in kilograms per liter of coating solids applied. Each 1-month calculation is considered a performance test under 40 CFR Section 60.463(b).

7.0 CD 40 CFR Section 60.464(c): Minn, R. 7011.2570

The Permittee shall install, calibrate, operate, and maintain a device that continuously records the combustion temperature of any effluent gases incinerated to achieve compliance with 40 CFR Section 60.462(a)(3), This device shall have an accuracy of +/- 2.5 deg C or +/- 0.75 percent of the temperature being measured expressed in degrees Celsius, whichever is greater.

8.0 CD 40 CFR Section 60.464(c): Minn. R, 7011.2570

The Permittee shall record all periods (during actual coating operations) in excess of 3 hours during which the average combustion temperature of CE 001 remains more than 28 deg C (50 deg F) below the temperature at which compliance with 40 CFR Section 60,462(a)(3) was demonstrated during the most recent measurement of incinerator efficiency required by 40 CFR Section 60.8. The Permittee shall record each such occurrence and its duration.

9.0 CD 40 CFR Section 60.7(b), Minn. R. 7019,0100, subp. 1

The Permittee shall maintain records of the occurrence and duration of any startup, shutdown, or malfunction in the operation of an affected facility; any malfunction of the air pollution control equipment: or any periods during which a continuous monitoring system or monitoring device is inoperative.

VliNNFSO IA POLL I ! ION C OM ROI AG1.NCY AIR 01 A! 1TY 530 UHVE1TF ROAD ST. PAUL. MN 5SI?5»11<>4

Facility Na me. Permit Number1

EDCO Products Inc 05301047-006

Page 8 of 28 2 Jun, 2015 11:38

COMPLIANCE FLAN CD-01

10.0 CD 40 CFR Section 60.7(f); Minn. R. 7019.0100. subp. 1; Min n. R. 7007.0800. subp. 5(C)

Recordkeeping: The Permittee shall maintain a file of all measurements, including continuous monitoring system, monitoring device, and performance testing measurements; all continuous monitoring system performance evaluations; all continuous monitoring system or monitoring device calibration checks; adjustments and maintenance performed on these systems or devices: and all other information required by 40 CFR pt. 60 part recorded in a permanent form suitable for inspection. The file shall be retained for at least 2 years following the date of such measurements, maintenance, reports, and records

Minn. R. 7007.0800, subp. 5(C) requires that all records be retained for an additional 3 years, for a tota l of 5 years from the date of generation.

11.0 CD 40 CFR Section 60.465(e): Minn. R, 7011.2570: Minn. R. 7007.0800. subp. 5(C)

The Permittee shall maintain at the source, for a period of at least 2 years, records of all data and calculations used to determine monthly VOC emissions from each affected facility and to determine the monthly emission limit, where applicable. The Permittee shall also maintain, at the source, daily records of the incinerator combustion temperature.

Minn. R. 7007.0800, subp. 5(C) requires that all records be retained for an additional 3 years, for a total of 5 years from the date of generation.

12.0 CD hdr REPORTING

13.0 S/A 40 CFR Section 60.465(c): Minn. R. 7011.2570

Quarterly Report: due 30 days after end of each calendar quarter following Permit Issuance. The Permittee shall identify, record, and submit a written report to the Commissioner every calendar quarter of each instance in which the volume-weighted average of the local mass of VOCs emitted to the atmosphere per volum e of applied coating solids (N) Is greater than the limit specified under 40 CFR Section 63,462. If no such instances have occurred during a particular quarter, a report stating this shall be submitted to the Commissioner semiannually, with the Semiannual Deviations Report listed in Table B of this permit.

14.0 S/A 40 CFR Section 60.465(d) and 60.7(c): Minn. R. 7011.2570 and 7019.0100, subp. 1

Report: due 30 days after end of each calendar half-year following Permit Issuance, The Permittee shall submit reports semiannually when the CE 001 temperature drops as defined under 40 CFR Section 63.464(c). if no such periods occur, the Permittee shall state this in the report. The report shall be submitted with the Semiannual Deviations Report listed in Table B of this permit.

15.0 CD 40 CFR Section 60.11(d): Minn. R. 7017.2015. subp. 2(B)

At all times, including periods of startup, shutdown, and malfunction, the Permittee shall, to the extent, practicable, maintain and operate any affected facility including associated air pollution control equipment in a manner consistent with good air pollution control practice for minimizing emissions. Determination of whether acceptable operating and maintenance procedures are being used will be based on information available to the Commissioner which may include, but is not limited to, monitoring results, opacity observations, review of operating and maintenance procedures, and inspection of the source.

16.0 CD 40 CFR Section 60.12; Minn. R. 7011.0050

The Permittee shall not build, erect, install, or use any a rticle, machine, equipment or process, the use of which conceals an emission which would otherwise constitute a violation of an applicable standard.

17,0 CD 40 CFR Section 60.13(b): Minn. R. 7017.1010. subp. 1(A)

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

18.0 CD 40 CFR Section 60.13(f); Minn. R. 7017.1010, subp. 1(A)

All continuous monitoring systems or monitoring devices shall be installed such that representative measurements of emissions or process parameters from the affected facility are obtained. Additional procedures for location of continuous monitoring systems contained in the applicable Performance Specifications of Appendix B of 40 CFR pt. 60 shall be used.

\ii\"\TSO!APO[i.rnn> '"<">\TROI A(,!-\CY AIR QUA! rr v 520 LAFAVrn r ROAD ST. I'-V.'l.. MN VilxMl'M

Facility Name:

Permit Number:

Subject Item:

Associated Items:

Page 9 of 28

COMPLIANCE PLAN

2 Jun. 2015 11:38

CD-01 EDCO Products Inc

05301047-006

GP 003 Part 63 Subpart MMMM NESHAP



EU 012 Paint Booth 2 Spra y Booth/Coating Line


NC / OA

Typo Citation Requirement

See GP 006 and CE 001 for additional requirements that apply to the facility from 40 CFR pt. 63. subp. MMMM.

CD Minn. R. 7007 0800. subps. 4 and 5

2.0 CD 40 CFR Section 63.3891: Minn. R, 7007.1150: Minn. R. 7011,8090

Based on the current and expected operations of the affected source, this permit only includes the emission rate with add-on controls option specified in 40 CFR Section 63.3891(c). This is based on the Permittee complying using the Facility-Specific Emission Limit (FSEL) by using a co mbination of uncontrolled (40 CFR pt. 63, subp. MMMM units) and controlled units (40 CFR pt. 63, subp. SSSS units).

If the Permittee later chooses to switch to or add one o r both of the other compliance options allowed in the standard, the Permittee shall comply with all applicable portions of 40 CFR pt. 63. subp. MMMM for those options, in addition, the Permittee shall apply for a pe rmit amendment, as appropriate (e.g., to add applicable NESHAP language, installation of a different type of control device, etc.).

3.0 CD hdr APPLICABILITY

4,0 CD 40 CFR Section 63.3881(e)(3): Minn. R. 7011.8090

The activities in GP 003 are a new affected source that applies general use coatings to miscellaneous metal products. The facility meets the applicability criteria of 40 CFR pt. 63, subp. MMMM and at the same time also performs surface coating that meets the applicability criteria of another final surface coating NESHAPS (40 CFR pt. 63, subp. SSSS. see GP 005). The Permittee plans to comply with a FSEL as specified in 40 CFR Section 63.3881(e)(3).

5.0 CD 40 CFR Section 63.3882(b); Minn. R. 7011.8090

The affected source is the collection of all of the items listed below that are used for surface coating of miscellaneous metal parts and products. 1) All coating operations as defi ned in 40 CFR Section 63.3981; 2) All storage containers and mixing vessels in which coatings, thinners and/or other additives, and cleaning materials are stored or mixed: 3) All manual and automated equipment and containers used for conveying coatings, thinners and/or other additives, and cleaning materials; and 4) All storage containers and all manual and automated equipment and containers used for conveying waste materials generated by a coating operation.

6.0 CD hdr EMISSION AND OPERATIONAL LIMITS

7.0 LIMIT 40 CFR Section 63.3890(a)(1): Minn. R. 7011.8090

HAPs - Organic; less than or equal to 0.230 kilograms/liter coating solids used during each 12-month compliance period. This is the limit from 40 CFR pt. 63, subp. MMMM that is used for the Facility-Specific Emission Limit calculated as specified by this permit at GP 006.

8.0 CD 40 CFR Section 63.3890(c)(2); Minn. R. 7011.8090

The Permittee elects to comply using the FSEL alternative. See GP 006 for requirements that cover all activities subject to the FSEL.

9.0 CD hdr COMPLIANCE REQUIREMENTS

10.0 CD 40 CFR Section 63.3891; Minn, R. 7011.8090

The Permittee must include all coatings (as defined in 40 CFR Section 63.3981), thinners and/or other additives, and cleaning materials used in the affected source when determining whether the organic HAP emission rate is equal to or less than the FSEL at GP 006. To make this determination, the Permittee must use at least one of the three compliance options listed in 40 CFR Section 63.3891 (a)-(c).

As stated earlier, this permit only includes the requirements associated with emission rate with add-on controls option specified in 40 CFR Section 63.3891(c). continued below

M1N\TS0"!A POLLUTION COYTROi AGLNCY AIR QUALITY 520 LAl'AYmi ROAD ST. PAl'i .M N 55155 -4 104

Facility Name:

Permit Number:

EDCO Products Inc

05301047 - 006

Page 10 of 28 2 Jun. 2015 11:38


11.0 CD 40 CFR Section 63.3891; Minn. R. continued from above 7011.8090 Even so. the Permittee may apply any of the c ompliance options to an individual

coating operation, or to multiple coating operations as a group, or to the entire affected source as specified in 40 CFR Section 63.3891. If the Permittee switches between compliance options for any coating operation or group of coating operations, the Permittee must document this switch as required by 40 CFR Section 63.3930(c), and the Permittee must report, it in the next semiannual compliance report listed in Table B (at GP 006).


MiVVFSO ! \ p AIR QUALITY 5?0 l.-AI'AVin'l

'Ol.I.l . r.'ONTKO! A(

M. T'AIAi

Facility Name:

Permit Number'

Subject Item;

Associated Items:

Page 11 of 28 2 Jun. 20 15 11:38

MN SSIr-.Mi'H

EDCO Producls Inc

05301047-006

GP 004 Paint Booths and IR Cure Ovens





COMPLIANCE FLAN CD-01

NC/ CA


1.0 CD hdr EMISSION LIMITS

2.0 LIMIT Minn, R. 7011 0715. subp 1(A) Total Particulate Matter: less than or equal to 0.30 grains/dry standard cubic foot of exhaust gas unless required to further reduce emissions to comply with the less stringent limit of either Minn. R 7011.0730 or Minn. R. 70 11.0735. This applies separately to each unit in GP 004.

3,0 LIMIT Minn. R. 7011.0715, subp. 1(B) Opacity: less than or equal to 20 percent opacity , This applies separately to each unit in GP 004.

4.0 CD Minn, R. 7007.0800. subp. 2 The Permittee shall vent emissions from all paint booths, including existing, modified, or new paint booths, to control equipment meeting the requirements of GP 007. The Permittee shall document periods of non-operation of the control equipment. All such booths must also meet the requirements of GP 004.


6.0 CD Minn. R. 7007.0800, subp. 2 Paint Booth Total Enclosure: The Permittee shall close the paint booth doors prior to and during any coating application in order to achieve a total enclosure.

7.0 CD Minn, R. 7007.0800. subps. 4 and 5

Paint Booth Total Enclosure Monitoring and Recordkeeping: The Permittee shall keep a log of all paint booth coating activities to demonstrate the booth doors are closed during all coating application. Each person that applies coating in a paint booth shall make a daily log entry on the date the coatings are applied noting the EU number of the paint booth.

The log shall be dated and signed by each person, and shall confirm if the booth doors were closed during all coating applications made by that person on that date. Failure to close the doors during coating application is a deviation that must be reported on the semi-annual deviation report requirement in Table B,

INXi.'SOIA POS.M \ MR oi Ai nv

5?0 i..\S \sn II ROM) M. PAi.T. MN 5? Iro-4 I

COAIROL AGLM'Y Pago 12 of 28

COMPLIANCE PLAN

2 Jun; 2015 11:38

CD-01 Facility Name:

Permit Number:

EDCO Products Inc

0530104? - 006

Subject Item: GP 005 Part 63 Subpart SSSS NESHAP

Associated Items: CE 001 Direct Flame Afterburner

EU 001 Primer/Backer Coater Spray Booth /Coating Line







NC/ CA


1.0 CD Minn. R. 7007.0800. subps, 4 and 5

See GP 006 and CE 001 for add itional requirements that apply to this equipment.

2.0 CD 40 CFR Section 63.5170: Minn. R. 7007.1150 and Minn. R. 7011,7905

Based on the current and expected operations of the affected source, this permit only includes the capture and control option specified in 40 CFR Section 63.5170(d). If the Permittee later chooses to switch to or add one or both o f the other compliance options allowed in the standard, the Permittee shall comply with all applicable portions of 40 CFR pt. 63, subp. SSSS for those op tions. In addition, the Permittee shall apply for a per mit amendment, as appropriate (e.g., to add applicable NESHAP language, installation of different controls, etc.).

3.0 CD hdr APPLICABILITY

4,0 CD 40 CFR Section 63.5080. Minn. R. 7011,7905

The facility is an existing affected source that performs metal coil surface coating operations and is a m ajor source of Hazardous Air Pollutants (HAP). As allow ed under 40 CFR Section 63.3881(e)(3), the Permittee has chosen to comply with both 40 CFR pt. 63, subps. MMMM and SSSS using a Facility-Specific Emission Limit (FSEL). See GP 006 for FSEL requirements.

5.0 CD 40 CFR Section 63.5100: Minn. R. 7011.7905

The affected source is the collection of all of the coil coating lines at the facility.

6.0 CD hdr LIMITS

7.0 LIMIT 40 CFR Section 63.5120(a)(2), Minn. R, 7011.7905

HAPs • O rganic, less than or equal to 0.0460 kilograms/liter of solids applied during each 12-month compliance period This is the limit from 40 CFR pt. 63, subp. SSSS that is used for the FSEL calculated as specified at GP 006 in this permit.

8.0 CD 40 CFR Section 63.5140, Minn. R. 7011.7905

The Permittee must be in compliance with 40 CFR pt. 63. subp. SSSS at all times, except during periods of start-up. shutdown, and malfunction of any capture system and control device used to comply with 40 CFR pt. 63, subp. SSSS,

9.0 CD hdr COMPLIANCE REQUIREMENTS

10.0 CD 40 CFR Section 63.5170. Minn. R. 7011.7905

The Permittee must include all coating materials (as defined in 40 CFR Section 63.5110) used in the affected source when determining compliance with the FSEL at GP 006. The Permittee may apply any of the compliance options listed in Table 1 of 40 CFR Section 63.5170 as required by that Section.

As stated earlier, this permit only includes the requirements associated with the capture and control option specified in 40 CFR Section 63.5170(d). continued below

11,0 CD 40 CFR Section 63.5170. Minn. R. 7011,7905

continued from above Even so, the Permittee may apply any of the compliance options to an individual coil coating line, or to multiple lines as a group, or to the entire affected source. The Permittee may use different compliance options for different coil coating lines, or at different times on the same line. However, the Permittee may not use different compliance options at the same time on the same coil coating line. If the Permittee switches between compliance options for any coil coating line or group of lines, the Permittee must document this switch as required by 40 CFR Section 63.5190(a). and must report it in the next semiannual compliance report listed in Table B of this permit (either at GP 005 or GP 006, as applicable).


VliVM'.'SO i.\ PO! LI "HON 0'>\-(R0i. AG!;.N CY AIR QUA! 1TY 520 I.AFAVOTF ROAD S i. PAUL. V|\ 5^155-4104

Pago 13 of 28

COMPLIANCE PLAN

2 Jun. 2015 11:38

CD-01 Facility Name; EDCO Products Inc


Subject Item: GP 006 Facility-Specific Emission Limit

Associated Items: EU 001 Primer/Backer Coa ter Spray Booth/Co ating Line

I U 002 Topcoater Spray Booth/Coating Line


EU 004 Primer Quench Bath Que nching Equipment




EU 010 Paint Booth 1 Spray Boo th/Coating Line

EU 011 Fiat Line Continuous Flow Oven (IR) Process Heater


EU 013 Flat Line Continuous Flo w Oven (IR) Process Heater

NC/ CA


1.0 CD Minn. R. 7007.0800. subps. 4 and 5

Unless otherwise noted, all equations referenced in the requirements of GP 006 can be found in Appendix C of this permit.

2.0 CD ' hdr EMISSION AND OPERATIONAL LIMITS

3.0 CD 40 CFR Section 63.3890(c)(2): Minn. R. 7011.8090

The Permittee elects to comply using the facility-specific emission alternative of 40 CFR pt. 63. subp. MMMM fo r equipment subject to 40 CFR pt. 63, subp. MM MM and equipment subject to 40 CFR pt. 63, subp. SSSS.

In calculating the facility-specific emission limit, the Permittee must include coating activities that meet the applicability criteria of t he other subcategories and constitute more than 1 percent of total coating activities. Coating activities that meet the applicability criteria of other surface coating NESHAP but comprise less than 1 percent, of coating activities need not be included in the determination of predominant activity but must be included in the compliance calculation, continued below

4.0 CD 40 CFR Section 63.3890(c)(2): Minn. R. 7011.8090

continued from above The Permittee shall calculate the Facility-Specific Emission Limit (FSEL) when submitting the notification of compliance status required in Table B of this permit and on a monthly basis afterward using the following formula:

FSEL = [(0.23 x S4M) + (0.046 x S4S)]/(S4M + S4S)

Where: FSEL = the Facility-Specific Emission Limit, in kg organic HAP/liter of coating solids used: S4M = The liters of solids used in all 40 CFR pt. 63, subp. MMMM coating operations in the 12-month compliance period that is subject to the FSEL; and S4S = The liters of solids used in all 40 CFR pt. 63. subp. SSSS coating operations in the 12-month compliance period that is subject to the FSEL.

5.0 CD 40 CFR Sections 63.3881(e)(3) and 63.3893(b): Minn. R. 7011.8090

Work Practice Plan. The Permittee must develop and implement a work practice plan to minimize organic HAP emissions from the storage, mixing, and conveying of coatings, thinners and/or other additives, a nd cleaning materials used in, and waste materials generated by units in GP 006. The plan must specify practices and procedures to ensure that, at a minimum, the following elements are implemented: 1) All organic-HAP-containing coatings, thinners and/or other additives, cleaning materials, and waste materials must be stored in closed containers. 2) Spills of organic-HAP-containing coatings, thinners and/or other additives, cleaning materials, and waste materials must be minimized. 3) Organic-HAP-containing coatings, thinners and/or other add itives, cleaning materials, and waste materials must be conveyed from one location to another in closed containers or pipes. continued below

MIN\i.'SO IA POi.Ll; I KJK CON'IRO! AGhNCY AER Ol Al ITY ^0 f.Al'AS FlT!- ROAD hi. PAUL. MX 55 1 55-4 !f}4

Page 14 of 28 2Juns2015 1138

COMPLIANCE PLAN CD-01 Facility Name:

Permit Number'

EDCO Products Inc

05301047 - 006

6.0 CD 40 CFR Sections 63.3881(e)(3) and 63.3893(b), Minn. R. 7011.8090

continued from above 4) Mixing vessels which contain organic-HAP-containing coatings and other materials must be closed except when adding to. removing, or mixing the contents. AND " 5) Emissions of organic HAP must be minimized during cleaning of storage, mixing, and conveying equipment.

continued from above 4) Mixing vessels which contain organic-HAP-containing coatings and other materials must be closed except when adding to. removing, or mixing the contents. AND " 5) Emissions of organic HAP must be minimized during cleaning of storage, mixing, and conveying equipment.

7.0 CD 40 CFR Section 63.6(e)(1)(i) and (ii): Minn. R. 7011.7000

Proper Operation and Maintenance: At all times, including periods of startup, shutdown and malfunction, the Permittee shall operate and maintain the emission units subject to 40 CFR pt. 63, subps. MMMM and SSSS and their associated air pollution control and monitoring equipment in a manner consistent with safety and good air pollution control practices for minimizing emissions at least to the levels required by all relevant standards.

Malfunctions shall be corrected as soon as practicable after their occurrence.

8,0 CD hdr GENERAL COMPLIANCE REQUIREMENTS

9.0 CD 40 CFR Section 63.3891(c) (40 CFR 63.5170. table 1, item 4): Minn. R. 7011.8090

Emission rate with add-on controls option. The Permittee shall demonstrate that, based on the coatings, thinners and/or other additives, and cleaning materials used in the coating operation(s). and the emission reductions achieved by emission capture systems and add-on controls, the organic HAP emission rate for the coating operation(s) is less than or equal to the FSEL, calculated as a rolling 12-month emission rate and determined on a monthly basis. The Permittee must meet all the requirements of 40 CFR Sections 63.3960 through 63.3968 to demonstrate compliance with the emission limits, operating limits, and work practice standards using this option.

10.0 CD 40 CFR Section 63.3900(a)(2) and (b): Minn. R. 7011.8090

The Permittee must be in compliance with the emission limitations as specified below for all units in GP 006: 1) The coating operations) must be in compliance with the FSEL at all times except during periods of startup, shutdown, and malfunction. 2) The coating operation(s) must be in compliance with the operating limits for emission capture systems and add-on control devices listed at CE 001 in this permit at all times except during periods of startup, shutdown, and malfunction. 3) The coating operation(s) must be in compliance with the work practice standards listed in this permit at al! times. AND 4) The Permittee must always operate and maintain the equipment according to the provisions in 40 CFR Section 63.6(e)(1)(i).

11.0 CD 40 CFR Sections 63.3900(c), 63.6(e)(3)(i), and 63.6(e)(3)(v); Minn. R. 7011,7000 and Minn. R. 7011.8090

The Permittee must develop a written startup, shutdown, and malfunction plan (SMMP) according to the provisions in 40 CFR Section 63.6(e)(3). The plan must address the startup, shutdown, and corrective actions in the event of a malfunction of the emission capture system or the add-on control device. The plan must also address any coating operation equipment that may cause increased emissions or that would affect capture efficiency if the process equipment malfunctions, such as conveyors that move parts among enclosures.

The SSMP must be located at the plant site and must be kept updated. When the SSMP is updated, the Permittee must keep all previous versions of the SSMP for a period of 5 years The Permittee must submit the SSMP when required.

12.0 CD hdr COMPLIANCE DEMONSTRATION

13.0 CD 40 CFR Section 63.3961(a): Minn. R. 7011.8090

Because the Permittee is complying with a FSEL with some controlled and some uncontrolled coating operations, the Permittee shall use the emission rate with add-on controls option for the group of both controlled and uncontrolled coating operations.

The Permittee must meet all the requirements of 40 CFR Section 63.3961.

14.0 CD 40 CFR Section 63.3961(a): Minn. R. 7011.8090 '

The Permittee does not need to redetermine the mass of organic HAP in coatings, thinners and/or other additives, or cleaning materials that have been reclaimed onsite (or reclaimed off-site if you have documentation showing that you received back the exact same materials that were sent off-site) and reused in the coatings operation(s) for which the emission rate with add-on controls option was used. If coatings, thinners and/or other additives, or cleaning materials were used that have been reclaimed on-site, the amount of each used in a month may be reduced by the amount of each that is reclaimed. That is. the amount used may be calculated as the amount consumed to account for materia ls that are reclaimed.

15.0 CD 40 CFR Section 63.3961(d); Minn.. R. 7011.8090

Compliance with emission limits. The Permittee must follow the procedures specified in this permit to demonstrate compliance with the FSEL.

i A I HH i.( M KA C< < N j ROI AGPVY \JR QVMJ JY

5io i..\i;A\n n ROAD SI. PAUL, MN

Facility Name. EDCO Products inc


Page 15 of 28 2 Jun. 2015 11:38


16.0 CD 40 CFR Sections 63.3961(e) and 63.3951(a) (40 CFR Sections 63.5160(b) and 63.5170(f)(1)(viii); Minn. R 7011.8090

Mass Fraction of HAP: The Permittee shall determine the mass fraction of organic HAP' for each coating, thinner and/or other additive, and cleaning material used during each month by using one of the following options: 1) The Permittee may use Method 311 (appendix A t o 40 CFR pt. 63) for determining the mass fraction of organic HAP. Use the procedures specified in 40 CFR Section 63.3941 (a)(1)(i) and (ii) when performing a Method 311 test; 2) For coatings, the Permittee may use Method 24 (appendix A to 40 CFR part 60) to determine She mass fraction of nonaqueous volatile matter and use that value as a substitute for mass fraction of organic HAP. For reactive adhesives in which some of the HAP react to form s olids and are not emitted to the atmosphere, the Permittee may use the alternative method contained in appendix A to 40 CFR pt. 63, subp. PPPP. rather than Method 24. continued below

17,0 CD 40 CFR Sections 63.3961(e) and 63.3951(a) (satisfies 40 CFR Sections 63.5160(b) and 63.5170(f)(1)(vii)): Minn. R. 7011.8090

2) continued from above The Permittee may use the volatile fraction that is emitted, as measured by the alternative method in appendix A to subpart PPPP, as a substitute for the mass fraction of organic HAP; 3) The Permittee may use an alternative test method fo r determining the mass fraction of organic HAP as specified in 40 CFR Section 63.3941(a)(3), 4) The Permittee may rely on information other than the three options given above, such as manufacturer's formulation data, if it represents each organic HAP that is present at 0 .1 percent by mass or more for OS HA-defined carcinogens as specified in 29 CFR Section 1910 1200(d)(4) and at 1.0 percent by mass or more for other compounds. For re active adhesives in which some of the HAP react to form solids and are not emitted to the atmosphere, you may rely on manufacturer's data that expressly states the organic HAP or volatile matter mass fraction emitted, continued below

18.0 CD 40 CFR Sections 63.3961(e) and 63.3951(a) (satisfies 40 CFR Sections 63.5160(b) and 63.5170(f)(1)(vii)): Minn. R. 7011.8090

4) continued from above If there is a disagreement between such information and results of a test conducted according to the three other options, then the test method results will take precedence unless, after consultation, the Permittee can demonstrate to the satisfaction of the Agency that the formulation data are correct; or 5) Solvent blends may be iisted as single components for some materials in data provided by manufacturers or suppliers. Solvent blends may contain organic HAP which must be counted toward the total organic HAP mass fraction of the materials. When test data and m anufacturer's data for solvent blends are not available, the Permittee may use the default values fo r the mass fraction of organic HAP in these solvent blends listed in Table 3 or 4 of 40 CFR pt, 63, subp. MMMM. continued below

19.0 CD 40 CFR Sections 63.3961(e) and 63.3951(a) (satisfies 40 CFR Sections 63.5160(b) and 63.5170(f)(T)(vii)}; Minn. R, 7011.8090

5) continued from above If these tables are used, the Permittee must use the values in Table 3 for all solvent blends that match Table 3 entries according to the instructions for Table 3, and the Permittee may use Table 4 only if the solvent blends in the materials used do not match any of the solvent blends in Table 3 and the Permittee knows only whether the blend is aliphatic or aromatic. However, if the results of a Method 311 (appendix A to 40 CFR pt. 63) test indicate higher values than those listed on Table 3 or 4, the Method 311 results will take precedence unless, after consultation, you demonstrate to the satisfaction of the Agency the formulation data are correct.

20.0 CD 40 CFR Sections 63.3961(e) and 63.3951(b) (satisfies 40 CFR Sections 63.5160(c) and 63.5170(f;(1)(viii)), Minn. R. 7011.8090

Volume Fraction of Solids: The Permittee shall determine the volume fraction of coating solids (liter (gal) of coating solids per liter (gal) of coating) for each coating used during each month by one of the methods given below. If test results obtained according to item 1 below do not agree with the information obtained under items 3 or 4 below, the test results will take precedence unless, after consultation, you demonstrate to the satisfaction of the Agency that the formulation data are correct. 1) The Permittee may use ASTM methods as specified in 40 CFR Section 63.3941(b)(1); 2) The Permittee may use an alternative test method for determining the solids content of each coating as specified in 40 CFR Section 63.3941(b)(2); 3) The Permittee may obtain the volume fraction of coating solids for each coating from the supplier or manufactu rer: or 4) The Permittee may determine the volume fraction of coating solids using the equation in 40 CFR Section 63.3941(b)(4).

>N MiN^tAPOLiriiONroK-moi AGENCY Page 16 of 28 2Jun,20i5 11:38

V COMPLIANCE PLAN CD-01 Facility Name: EDCO Products Inc


21.0 CD 40 CFR Sections 63.3961(e) and 63.3951(C) {satisfies 40 CFR Sections 63.5160(c) and 63.5170<f)(1 )(viii)): Minn. R. 7011.8090 ' '

Density: The Permittee shall determine the density of each liquid coating, thinner and/or other additive, and cleaning material used during each month from test results using ASTM Method D1475-98. "Standard Test Method for Density of Liquid Coatings, Inks, and Related Products" (incorporated by reference, see 40 CFR Section 63.14). information from the supplier or manufacturer of the material, or reference sources providing density or specific g ravity data for pure materials. If the Permittee is including powder coatings in the compliance determination, determine the density of powder coatings, using ASTM Method D5965-02, "Standard Test Methods for Specific Gravity of Coating Powders" (incorporated by reference, see 40 CFR Section 63.14), or inf ormation from the supplier, continued below

22.0 CD 40 CFR Sections 63.3961(e) and 63.3951(c) (satisfies 40 CFR Sections 63.5160(c) and 63.5170(f)(1)(viii)); Minn. R. 7011.8090

continued from above If there is disagreement between ASTM Method D1475-98 or ASTM Method D5965-02 test results and other such information sources, the test results w ill take precedence unless, after consultation the Permittee demonstrates to the satisfaction of the Agency that the formulation data are correct. If the Permittee purchases materials or monitor consumption by weight, instead of volume, the Permittee does not need to determine materia! density. Instead, the Permittee may use the material weight in place of the combined terms for density and volume in Equations 1A, 1B. 1C. and 2 of Appendix C.

23,0 CD 40 CFR Sections 63.3961(e) and 63.3951(d); Minn. R, 7011,8090

Volume: The Permittee shall determine the volume (liters) of each coating, thinner and/or other additive, and cleaning material used during each month by measurement or usage records, if the Permittee purchases materials or monitors consumption by weight instead of vol ume, the Permittee does not need to determine the volume of each material used. Instead, the Permittee may use the material weight in place of the combined terms for density and volume in Equations 1A, 18, and 1C of Appendix C.

24.0 CD 40 CFR Section 63.3961(f); Minn, R. 7011.8090

Pre-Control Total Mass Organic HAP. Using Equation 1 of Appendix C. the Permittee shall calculate the total mass of organic HAP emissions before add-on controls from all coatings, thinners and/or other additiv es, and cleaning materials used during each month in the coating operation or group of coating operations.

25.0 CD 40 CFR Section 63.3961(g); Minn. R. 7011.8090

HAP Reduction from Controls. The Permittee shall determine the mass of organic HAP emissions reduced for each controlled coating operation during each month. The emission reduction determination quantifies the total organic HAP emissions that pass through the emission capture system and are destroyed or removed by the add-on control device. Use the procedures specified below to calculate the mass of organic HAP emission reduction for each controlled coating operation using an emission capture system and add-on control device other than a solvent recovery system for which you conduct liquid-liquid material balances.

26.0 CD 40 CFR Section 63.3961(h) (satisfies 40 CFR Section 5170(f)(1)(v)); Minn. R. 7011.8090

Organic HAP Emission Reduction. The Permittee shall use Equation 3 of Appendix C to calculate the organic HAP emission reduction for coating operations in GP 006. The calculation applies the emission capture system efficiency and add-on control device efficiency to the mass of organic HAP contained in the coatings, thinners and/or other additives, and cleaning materials that are used in the coating operation served by the emission capture system and add-on control device during each month.

27.0 CD 40 CFR Section 63.3961(h) (satisfies 40 CFR Section 5170(f)(1)(v)); Minn. R. 7011.8090

The Permittee must assume zero efficiency for the emission capture system and add-on control device for any period of time a deviation specified in 40 CFR Section 63.3963(c) or (d) occurs in t he controlled coating operation, including a deviation during a period of startup, shutdown, or malfunction, unless the Permittee has other data indicating the actual efficiency of the emission capture system and add-on control device and the use of these data is approved by the Administrator, Equation 3 of Appendix C treats the materials used during such a deviation as if they were used on an uncontrolled coating operation for the time period of the deviation.

28.0 CD 40 CFR Section 63.3961 (h)(1)-(4) (satisfies 40 CFR Section 63.5170(f)(1)(vi)); Minn. R, 7011.8090 '

The Permittee shall calculate the following using the referenced equations in Appendix C of this permit: 1) Calculate the mass organic HAP in the coatings used in the controlled coating operation, kg (lb), using Equation 3A; 2) Calculate the mass of organic HAP in the thinners and/or other additives used in the controlled coating operation, kg (lb), using Equation 3B; 3) Calculate the mass of organic HAP in the cleaning materials used in the controlled coating operation during the month, kg (lb), using Equation 3C; and 4) Calculate the mass of organic HAP in the coatings, thinners and/or other additives, and cleaning materials used in the controlled coating operation during deviations specified in 40 CFR Section 63.3963(c) and (d), using Equation 3D.

M!V\t;SO!A P01.U HON CONH'RO! AG1.NCY AIR QUALITY ??0 l.ALAYin TL ROAD Si. RAUL, MN 5?I:VS~4 104

Facility Name:

Permit Number:

EDCO Products Inc

05301047-006

Page 17 of 28 2 Jun, 2015 11.38


29.0 CD 40 CFR Section 63.3961(k): Minn, R. 7011.8090

Total Volume of Coating Solids used. The Permittee shall determine the total volume of coating solids used, liters, which is the combined volume of coating solids for a ll the coatings used during each month in the coating operation or group of coating operations for which the Permittee uses the emission rate with add-on controls option, using Equation 2 of Appendix C.

30.0 CD 40 CFR Section 63.3961(1} (satisfies 40 CFR Section 63.5170(f)(1)(ix)): Minn. R. 7011.8090

Mass of Organic HAP Emissions. The Permittee shall determine the mass of organic HAP emissions. Kg. during each month, using Equation 4 of Appendix C.

31.0 CD 40 CFR Section 63.3961 (m) arid (n) (satisfies 40 CFR Section 63.5170(f)( 1 }{x)); Minn. R, 7011.8090

Organic HAP Emission Rate. The Permittee shall determine the organic HAP emission rate for the compliance period, kg (lb) of organic HAP emitted per liter (gal) coating solids used, using Equation 5 of Appendix C. The organic HAP emission rate for the initial compliance period, calculated using Equation 5, must be less than or equal to the FSEL.

32.0 CD 40 CFR Section 63.3963(a) (satisfies 40 CFR Section 63.5170(d)(2)), Minn. R. 7011.8090

FSEL. To demonstrate continuous compliance with the FSEL, the organic HAP emission rate for each compliance period, determined according to the procedures in 40 CFR Section 63.3961, must be equal to or less than the FSEL. A compliance period consists of 12 months. Each month after 3/31/2009 is the end of a compliance period consisting of that month and the preceding 11 months. The Permittee must perform the calculations in 40 CFR Section 63.3961 on a monthly basis using data from the previous 12 months of operation. The Permittee must also perform the FSEL calculation using the FSEL formula specified earlier in this permit on a monthly basis using the data from the previous 12 months of operation, continued below

33.0 CD 40 CFR Section 63.3963(b); Minn. R. 7011.8090 *

continued from above If the organic HAP emission rate for any 12-mo nth compliance period exceeded the FSEL, this is a deviation from the emission limitation for that compliance period that must be reported as specified in 40 CFR Sections 63.3910(c)(6) and 63.3920(a)(7).

34.0 CD 40 CFR Section 63.3963(e); Minn. R. 7011.8090

Work Practice. The Permittee must demonstrate continuous compliance with the work practice standards in 40 CFR Section 63.3893. If the Permittee did not develop a work practice plan, or did not implement the plan, or did not keep the records required by 40 CFR Section 63.3930(k)(8), this is a deviation from the work practice standards that must be reported as specified in 40 CFR Sections 63.3910(c)(6) and 63.3920(a)(7).

35,0 CD hdr RECORDKEEPING

36,0 CD 40 CFR Sections 63.10(b)(1), 63.3931 and 63.3952(d); Minn. R. 7019.0100, subp. 2(B)

Recordkeeping: The Permittee shall maintain files of all information required by 40 CFR pt. 63 in a form suitable and readily available for expeditious inspection and review.

The files should be retained for at least 5 years following the date of each occurrence, measurement, maintenance, corrective action, report, or record. Only the most recent two years of information must be kept on site.

37,0 CD 40 CFR Sections 63.10(b)(2), 63.3931, and 63.3963(j): Minn. R. 7011.7000

The Permittee shall maintain, at a minimum, the following information in the files: 1) the occurrence and duration of each startup, shutdown, or malfunction of operation; 2) the occurrence and duration of each malfunction of the air pollution control equipment: 3) all maintenance performed on the pollution control equipment: 4) actions taken during periods of startup, shutdown, and malfunction when such actions are different from the procedures specified in the SSMP. In this case, the Permittee shall report this action within 2 days of occurrence and follow by a written notification within 7 days of occurrence. 5) all information necessary to demonstrate conformance with the SSMP and actions taken in accordance with SSMP.

MiWYSO i A j'Ol L!: HON COM ROIAGRM'Y AIR 01 -A! iTY

l.AFAYjrni ROAD ST PAI L . MN 5SI55--JI04

Facility Name:

Permit Number:

EDCO Products Inc

0530104? - 006

Page 18 of 28 2 Jun, 2015 11:38


38.0 CD 40 CFR Sections 63.10(b)(2), 63.3931. and 63 3963(j): Minn R. 7019.0100. subp. 2(B)

6) each period during which a continuous monitoring system (CMS) is malfunctioning or inoperative; 7) all required measurements needed to demonstrate compliance with a relevant standard; 8) all results of performance test, CMS performance evaluations, and opacity and visible emission observations; 9) all measurements as may be necessary to determine the conditions of performance tests and performance evaluations; 10) all CMS calibration checks; 11) all adjustments and maintenance performed on CMS, and 12) all documents supporting initial notifications and notifications of com pliance status (for both 40 CFR pt. 63, subps. SSSS and MMMM).

39,0 CD 40 CFR Section 63.3930(a). (b), (c)(1) and (c)(4), (d). (e), (f), (g), (h) and (j); 40 CFR Section 63.3963®: Minn, R, 7011.8090 (satisfies 40 CFR Section 63.5190(a)(1). (a)(2)(iii). (iv), and (vi))

The Permittee must collect and keep records of the data and information specified below. Failure to collect and keep these records is a deviati on from the applicable standard. 1) A copy of each notification and report that the Permittee submitted to comply with 40 CFR pt. 63, subp. MMMM and the documentation supporting each notification and report; 2) Records of the data used to calculate the FSEL for the initial compliance demonstration. The Permittee must also keep records of any data used in each calculation of the FSEL for each 12-month compliance period included in the semi-annual compliance reports; continued below

40.0 CD 40 CFR Section 63.3930(a), (b), (c)(1) and (c)(4). (d), (e), (f), (g). (h) and (j); 40 CFR Section 63.3963(j); Minn. R. 7011.8090 (satisfies 40 CFR Section 63,5190(a)(1), (a)(2)(iii). (iv), and (vi))

continued from above 3) A current copy of information provided by materials suppliers or manufacturers, such as manufacturer's formulation data, or test data used to determine the mass fraction of organic HAP and density for each coating, thinner and/or other additive, and cleaning material, and the volume fraction of coating solids for each coating. If the Permittee conducted testing to determine mass fraction of organic HAP. density, or volume fractio n of coating solids, the Permittee must keep a copy of the complete test report. If the Permittee uses information provided to the Permittee by the manufacturer or supplier of t he material that was based on testing, the Permittee must keep the summary sheet of results provided to the Permittee by the manufacturer or supplier. The Permittee is not required to obtain the test report or other supporting documentation from the manufacturer or supplier; continued below

41.0 CD 40 CFR Section 63.3930(a). (b), (c)(1) and (c)(4), (d). (e), (f), (g), (h) and (j); 40 CFR Section 63.3963(j); Minn, R, 7011.8090 (satisfies 40 CFR Section 63.5190(a)(1). (a)(2)(iii). (iv), and (vi)) '

continued from above 4) For each compliance period, the records specified below: - A record of the coating operations on which the Permittee used each compliance option and the time periods (beginning and ending dates and times) for each option the Permittee used; • A record of the calculation of the total mass of organic HAP emissions for the coatings, thinners and/or other additives, and cleaning materials used each month using Equations 1 and 1A through 1C and, if applicable, the calculation used to determine mass of organic HAP in waste materials; - A record of the calculation of the total volume of coating solids used each month using Equation 2; • A r ecord of the calculation of the mass of organic HAP emission reduction by emission capture systems and add-on control devices using Equations 3 and 3A through 3D: - A record of the calculation of each month's organic HAP emission rate using Equation 4; and continued below

42.0 CD 40 CFR Section 63.3930(a). (b), (c)(1) and (c)(4), (d). (e), (f). (g), (h) and (j); 40 CFR Section 63,3963(j); Minn. R. 7011.8090 (satisfies 40 CFR Section 63.5190(a)(1), (a)(2)(iii), (iv). and (vi)) ' ' '

continued from above - A record of the calculation of each 12-month organic HAP emission rate using Equation 5. 5) A record of the name and volume of each coating, thinner and/or other additive, and cleaning material used during each compliance period; 6) A record of the mass fraction of organic HAP for each coating, thinner and/or other additive, and cleaning material used during each compliance period unless the material is tracked by weight; 7) A record of the volume fraction of coating solids for each coating used during each compliance period; 8) The density for each coating, thinner and/or other additive, and cleaning material used during each compliance period; continued below

M1WTS0TA POI !.n KA CI. fx ! ROi A'Ai-VCY \ MRQIAI.ITY

5?0 LAFAN K l IT; ROAD ST. i'AUi , MX 5:i!A5--41r'4


Permit Number: 0530104? - 006

Pago 19 of 28 2 Jun. 201 5 11:38


43.0 CD 40 CFR Section 63.3930(a), (b). (c)(1) and (c)(4), (d), (e), (f). (g). (h) and (j'c 40 CFR Section 63.3963(j); Minn. R. 7011 8090 (satisfies 40 CFR Section 63.5190(a)(1), (a)(2)fiil), (iv). and (vi))

continued from above 9) If the Permittee uses an allowance in Equation 1 for organic HAP contained in waste materials according to 40 CFR Section 63.3951(e)(4), the Permittee must keep the following records. - The name and address of each TSDF to which the Permittee sent waste materials for which the Permittee uses an allowance in Equation 1; a statement of which subparts under 40 CFR parts 262 . 264, 265, and 266 apply to the facility: arid the date of each shipment; - Identification of the coating operations producing waste materials included in each shipment and the month or months in which the Permittee used the allowance for these materials in Equation 1; continued below

44.0 CD 40 CFR Section 63.3930(a). (b), (c)(1) and (c)(4), (d). (e), (f), <g). (h) and (j); 40 CFR Section 63.3963(j): Minn. R. 7011.8090 (satisfies 40 CFR Section 63.5190(a)(1). (a)(2)(iii), (iv), and (vi))

continued from above - The methodology used in accordance with 40 CFR Section 63.3951(e)(4) to determine the total amount of waste materials sent to or the amount collected, stored, and designated for trans port to a T SDF each month; and the methodology to determine the mass of o rganic HAP contained in these waste materials. This must include the sources for all data used in the determination, methods used to generate the data, frequency of testing or monitoring, and supporting calculations and documentation, including the waste manifest for each shipment, 10) The Permittee must keep records of the date, time, and duration of each deviation.

45,0 CD 40 CFR Section 63.3930(k); 40 CFR Section 63.3963(j); Minn, R, 7011.8090 (satisfies 40 CFR Section 63.5190(a)(2)(ii) and (vi)

The Permittee shall collect and keep the following records: 1) For each deviation, a record of whether the deviation occurred during a period of startup, shutdown, or malfunction; 2) The records in 40 CFR Section 63,6(e)(3)(iii) through (v) related to startup, shutdown, and malfunction; 3) The records required to show continuous compliance with each operating limit that applies to CE 001; 4) For each capture system that is a permanent total enclosure (PTE), the data and documentation used to support a determination that the capture system meets the criteria in Method 204 of appendix M to 40 CFR pt, 51 for a PTE and has a capture efficiency of 100 percent, as specified in 40 CFR Section 63.3965(a); continued below

46.0 CD 40 CFR Section 63.3930(k); 40 CFR Section 63.3963(j): Minn. R. 7011.8090 (satisfies 40 CFR Section 63.5190(a)(2)(ii) and (v))

continued from above 5) The following records for e ach add-on control device organic HAP destruction or removal efficiency determination as specified in 40 CFR Section 63.3966: - Records of each add on control device performance test conducted according to 40 CFR Sections 63.3964 and 63.3966. - Reco rds of the coating operation conditions during the add-on control device performance test showing that the performance test was conducted under representative operating conditions; 6) Records of the data and calculations used to establish the emission capture and add-on control device operating limits as specified in 40 CFR Section 63.3967 and to document compliance with the operating limits that apply to CE 00 1; AND 7) A record of the work practice plan required by 40 CFR Section 63,3893 and documentation that the Permittee is implementing the plan on a continuous basis.

47.0 CD hdr REPORTING

48.0 S/A 40 CFR Section 63.3920(a)(1)(i), (ii). and (iv) (satisfies 40 CFR Section 63.5180(g)(1)); Minn. R, 7011.8090

Semiannual Compliance Report: due 31 days after end of each calendar half-year following Permit Issuance for equipment in GP 006. The report shall contain the information specified in Table A of this permit, under C3P 006,

Each semiannual compliance report must cover the s emiannual reporting period from January 1 through June 30 or the semiannual reporting period from July 1 through December 31.

This report may be submitted with the Semiannual Deviations Report also listed in Table B of this permit.

MiNN'i-so I'A POI.LI"HON c< INTROI A GENCY Page 20 of 28 2 Jun. 2015 11:38 AIR Ot ALII Y ' 5?0 LAi ASTITr ROAD ST. VA\ 1.. rviN fli COMPLIANCE PLAN C-LMIl



49 0 CD 40 CFR Sections 63.3920(a)(3), (4) and (7) and 63.3963(f) (satisfies 40 CFR Section 63.5180(g)(2) arid (h)); Minn. R. 7011.8090

Content of Semiannual Compliance Report: At a minimum, the report shall include: 1) Company name and address; 2) Statement by a responsible official with that official's name, title, and signature, certifying the truth, accuracy, and completeness of the content of the report: 3) Date of report and beginning and ending dates of the reporting period. The reporting period is the 6-month period ending on June 30 or December 31. Note that the information reported for each of the 6 months in the reporting period will be based on the last 12 months of data prior to the date of each monthly calculation; 4) Identification of the compliance option or options specified in 40 CFR Sections 63.3891 and 63.5170 (Table 1) that the Permittee used on each coating operation during the reporting period. If the Permittee switched between compliance options during the reporting period, the Permittee must report the beginning and ending dates for each option the Permittee used, continued below

50.0 CD 40 CFR Sections 63.3920(a)(3), (4) and (7) and 63.3963(f) (satisfies 40 CFR Section 63.5180(g)(2) and (h)); Minn. R. 7011.8090

continued from above 5)The calculation results for each rolling 12-month organic HAP emission rate during the 6-month reporting period; 6) The calculation of the FSEL for each 12-month compliance period during the 6-month reporting period: 7) If there were no deviations from the applicable HAP emission limit, the semiannual compliance report must include a statement that there were no deviations from the emission limitations during the reporting period. If there were no periods during which the continuous parameter monitoring systems (CPMS) were out-of-control as specified in 40 CFR Section 63.8(c)(7), the semiannual compliance report must include a statement that there were no periods during which the CPMS were out-of-control during the reporting period: and continued below

51.0 CD 40 CFR Sections 63.3920(a)(3). (4) and (7) and 63.3963(f) (satisfies 40 CFR Section 63.5180(g)(2) and (h)); Minn. R. 7011.8090

continued from above 8) If there was a deviation from an emission limitation, the semiannual compliance report must contain the information specified below. This includes periods of startup, shutdown, and malfunction during which deviations occurred: a. The beginning and ending dates of each compliance period during which the 12-month organic HAP emission rate exceeded the FSEL, b. The calculations used to determine the 12-month organic HAP emission rate for each compliance period in which a deviation occurred. The Permittee must provide the calculation of the total mass of organic HAP emissions for the coat ings, thinners and/or other additives, and cleaning materials used each month using Equations 1 and 1A through 1C; and, if applicable, the calculation used to determine mass of organic HAP in waste materials; the calculation of the total volume of coating solids used each month using Equation 2; continued below

52.0 CD 40 CFR Sections 63.3920(a)(3). (4) and (7) and 63.3963(f)' (satisfies 40 CFR Section 63.5180(g)(2) and (h)); Minn. R. 7011.8090

8,b) continued from above the calculation of the mass of organic HAP emission reduction each month by emission capture systems and add-on control devices using Equations 3 and 3A through 3D; the calculation of the total mass of organic HAP emissions each month using Equation 4: and the calculation of the 12-month organic HAP emission rate using Equation 5. The Permittee does not need to submit the background data supporting these calculations ( e.g., information provided by materials suppliers or manufacturers, or test reports). c. The date and time that each malfunction started and stopped. d. A brief description of the CPMS. e. The date of the latest CPMS certification or audit. f. The date and time that each CPMS was inoperative, except for zero (low-level) and high-level checks. g. The date, time, and duration that each CPMS was out-of-control, including the information in 40 CFR Section 63.8 (c)(8). continued below

MiWTSO : A POLI.rHON CONTROi AGl:.\('Y \ AlKOS AiiTY

5.70 LAFAVn iti ROAD ST. PAIJI..MN

Facility Name:

Permit Number:

EDCO Products Inc

05301047 - 006

Page 21 of 28

COMPLIANCE PLAN

2 Jun, 2015 11:38

53.0 CD 40 CFR Sections 63.3920(a)(3), (4) arid (?) and 63.3963(f) (satisfies 40 CFR Section 63.5180(g)(2) and (h»; Minn. R. 7011.8090 '

8). continued from above h. The date and time period of each deviation from the temperature and air flow limits listed at CE 001; date and time period of any bypass of the add-on control device; and whether each deviation occurred during a period of startup, shutdown, or malfunction or during anothe r period, i. A summary of the tot al duration of each deviation from the temperature and air flow limits listed at CE 001 and each bypass of the add-on control device during the semiannual reporting period, and the total duration as a percent of the tota l source operating time during that semiannual reporting period. j. A breakd own of the total duration of the deviations from the temperature and air flow limits listed at CE 001 and bypasses of the add-on control device during the semiannual reporting period into those that were due to startup, shutdown, control equipment problems, process problems, other known causes, and other unknown causes. continued below

54.0 CD 40 CFR Sections 63.3920(a)(3), (4) and (7) and 63.3963(f) ' (satisfies 40 CFR Section 63.5180(g)(2) and (h)); Minn. R. 7011.8090

8). continued from above k. A summary of the tota l duration of CRMS downtime during the semiannual reporting period and the total duration of CRMS downtime as a percent of the total source operating time- during that semiannual reporting period. I. A description of any changes in the CRMS, coating operation, emission capture system, or add-on control device since the last, semiannual reporting period, m. For each deviation from the work practice standards, a description of the deviation, the date and time period of the deviation, and the actions the Permittee took to correct the deviation. AND n. A statement of th e cause of each deviation.

55.0 CD 40 CFR Sections 63.10(d)(5)(H) and 63.3920(c) (satisfies 40 CFR Section 63.5180ft)): Minn. R. 7011.8090

Startup, shutdown, malfunction reports. If there is a startup, shutdown, or malfunction during any semiannual reporting period, the Permittee must submit the following reports: '

1) If any act ions taken were consistent with the SSMP, include the information specified in 40 CFR Section 63.10(d) in the semiannual compliance report listed in Table B of this permit (for GP 006). 2) If any ac tions taken were NOT consistent with the SSMP, submit the following immediate startup, shutdown, and malfunction reports:

- Describe the actions taken during the event in a report delivered by facsimile, telephone, or other means to the Administrator within 2 working days after starting actions that are inconsistent with the plan; and - Submit a letter to the Administrator within 7 working days after the end of the

event. The letter must contain the information specified in 40 CFR Section 63.10(d)(5)(ii).

INNTSO'lA POLLL 1 ION CONTROL AG1-.NCY \ AIR QUALITY

JM LArAYLTTL ROM) ST. P AL L. MN ?51? 5-4! '14

Facility Name:

Permit Number:

Subject Item:

Associated Items:

EDCO Products Inc

05301047 - 006

GP 007 Paint Booth Filters



Page 22 of 28 2 dun, 2015 11:38


NCI CA


1.0 CD Minn. R. 7007.0800, subp 2 Unless otherwise specified, the requirements in GP 007 apply separately to each CE in GP 007.

2.0 CD heir EMISSION LIMITS

3.0 LIMIT Minn. R. 7007.0800. subp. 2 The Permittee shall operate and maintain the control equipment such that it achieves an overall control efficiency for Total Particulate Matter: greater than or equal to 92 percent control efficiency

4,0 LIMIT Minn. R, 7007.0800, subp. 2 The Permittee shall operate and maintain the control equipment such that it achieves an overall control efficiency for Partic ulate Matter < 10 micron: greater than or equal to 92 percent control efficiency

5.0 CD Minn. R. 7007.0800, subps. 2 and 14

The Permittee shall operate and maintain the panel filters any time that any process equipment controlled by the panel filters is in operation. The Permittee shall document periods of non-operation of the control equipment.


7,0 CD Minn, R. 7007.0800, subps, 4, 5. and 14

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

8,0 CD Minn. R, 7007.0800, subps. 4, 5, and 14

Periodic Inspections: At least once per calendar quarter, or more frequently as required by the manufacturing specifications, the Permittee shall inspect the control equipment components. The Permittee shall maintain a written record of these inspections.

9.0 CD Minn. R. 7007.0800. subps. 4, 5, and 14

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

10.0 CD Minn, R, 7007.0800, subps, 4, 5, and 14

The Permittee shall operate and maintain the panel filters in accordance with the Operation and Maintenance (O & M) Pian, The Permittee shall keep copies of the O & M Plan available onsite for use by staff and MPCA staff.

IV\T.'SO'!A POLM/T10v CON ! RO! AGENCY' \ AIR QUALITY

520 I.AFAYFliT ROAD ST. PAUL, MN 5:5155-J 104

Page 23 of 28

COMPLIANCE FLAN

2 dun. 2015 11:38

CD-01 Facility Name.

Permit Number:

Subject Item: Associated Items:

EDCO Products Inc 05301047 -006

EU 008 Now NSPS Oven Dryer/Oven, unknown firing method



GP 002 NSPS Subpart IT Limits


GP 006 Facility-Specific Emission Limit

NC# CA


1.0 CD Minn. R. 7007 0800. subp 2 The Permittee is authorized to install a new oven. ElJ 008; at any time during the life of this permit. EU 008 shall meet all requirements of this per mit (e.g., GP 002) and shall meet the following design requirements. 1. Combust only natural gas or propane, and 2. Have a total capacity of 4,0 MMBtu/hr or less.

2.0 CD Minn. R. 7007.0800, subp. 4 and 5

Fuel Recordkeeping: The Permittee shall keep records of fuel combusted on a monthly basis.

3.0 S/A Minn. R, 7007.0800, subp. 2 Notification of the Date Construction Began: due 30 days after Start Of Construction. The Permittee shall submit emission unit information with ttie notification using the latest MPCA application forms.

Page 24 of 28 2 Jua 2015 11:38

COMPLIANCE PLAN CD-01 Facility Name: EDCO Products Inc

Permit Number' 05301047 - 006

Subject Item: EU 014 Makeup Air Unit

•••#'' '"Y M|\Wr$OTA POI I l; i'lON ( I >N 1KOl AGt,\CY / \ / \ AIR 01 A) nv

l-Al As riTi: ROAD AT. I'AI.M... MN

NC/ CA


1.0 LIMIT Minn. R. 7011.0515. subp. 1 Total Particulate Matter: less than or equal to 0.40 lbs/million Btu heat input. The potential to emit from the unit is 0.0070 Ib/MMBtu due to equipment design and allowable fuels.

2.0 LIMIT Minn. R. 7011.0515, subp. 2 Opacity: less than or equal to 20 percent opacity except for one six-minute period per hour of not m ore than 60 percent opacity.

\i;\\FSO A £ R 01 Ai 5?0 I.AFW>

"«ROi

S i. ROAD

. MN 5^!5>-4iO

Page 25 of 28 2 Jun,2Q15

COMPLIANCE PLAN CD-01 Facility Name:

Permit Number:

Subject Item:

Associated Items:

EDCO Products Inc

05301047 - 006










MR 001 Type K Thermoc ouple Parametric Monitor

NCI CA


1.0 CD Title I Condition: To avoid classification as a major source and modification under 40 CFR Section 52.21 and Minn. R. 7007.3000

The Permittee shall operate and maintain the thermal oxidizer at all time s that any emission unit controlled by the thermal oxidizer is in operation. The Permittee shall document periods of non-operation of the control equipment.

2.0 CD hdr EMISSION AND OPERATIONAL LIMITS

3.0 LIMIT Title I Condition: To avoid classification as a major source and modification under 40 CFR Section 52.21 and Minn. R. 7007.3000

The Permittee shall operate and maintain the control equipment such that it achieves an overall control efficiency for Volatile Organic Compounds: greater than or equal to 90.0 percent control efficiency

4.0 LIMIT Minn. R, 7007.0800, subp. 2 The Permittee shall operate and maintain the control equipment such that it achieves an overall control efficiency for Total HAPs - Organic: greater than or equal to 90.0 percent control efficiency

5.0 CD Minn. R. 7007.0800. subp. 14 The Permittee shall operate and maintain the thermal oxidizer in accordance with the Operation and Maintenance (O & M) Plan. The Permittee shall keep copies of the O & M Plan available onsite for use by staff and MPCA staff.

6.0 LIMIT Title I Condition: To avoid classification as a major source and modification under 40 CFR Section 52.21 and Minn. R. 7007.3000: 40 CFR Sections 63.3881(e)(3). 63.3892(b). and 63.3963(c): Minn. R, 7011.8090

Temperature: greater than or equal to 1190.0 degrees F using 3-hour Block Average at the combustion chamber outlet, un less a new limit is set pursuant to Minn, R. 7017.2025, subp, 3 based on the values recorded during the most recent MPCA-approved performance test where compliance was demonstrated. The new limit shall be implemented upon receipt of the Notice of Compliance letter granting preliminary approval. The limit is final upon issuance of a permit amendment incorporating the change. If the 3-hour block average temperature is below the minimum temperature limit, the VOC and HAP emitted during that time shall be considered uncontrolled until the average temperature is above the minimum temperature limit. This shall be reported as a deviation.

7.0 LIMIT 40 CFR Sections 63.3881(e)(3), 63.3892(b), and 63.3963(c): Minn, R. 7011.8090

Air Flow Rate: greater than 200.0 feet/minute facial velocity of air through all natural draft openings in the enclosure AND the direction of air flow at all times must be into the enclosure.

If the air flow is below the limit or the air flow direction is not as required, this is a deviation that must be reported as specified by this permit. If an operating parameter deviates from these operating limits, the Permittee must assume that the capture efficiency was zero during the time period of the deviation unless the Permittee has other data indicating the actual efficiency of the capture system and the use of the data is approved by the Administrator.

8.0 LIMIT Minn. R. 7011.0610. subp. 1(A)(1) Total Particulate Matter: less than or equal to 0.30 grains/dry standard cubic foot of exhaust gas unless required to further reduce emissions to comply with the less stringent limit of eith er Minn. R. 7011.0730 or Minn. R. 7011.0735.

9.0 LIMIT Minn. R. 7011.0610, subp. 1(A)(2) Opacity: less than or equal to 20 percent opacity except for one six-minute period per hour of not more than 60 percent opacity.


MiN'M.'SOiA iH'.H.I.U IION CONTROL AGENCY' AIR QU A! STY 5?0 l.-\|-\\s i; 1']? ROAD ST. PAUL, MN 55155-4 I'M

Page 28 of 28 2 Jun. 2015 11:38

COMPLIANCE FLAN CD-01 Facility Name:

Permit Number:

EDCO Products Inc

05301047 - 006

11.0 CD Title I Condition: To avoid classification as a major source and modification under 40 CFR Section 52.21 and Minn. R. 7007.3000; 40 CFR Sections 64.3(b)(4)(h) and 64.7(b): Minn. R. 7017.0200; 40 CFR Section 63.5150(a)(3)(i) and (ii); Minn. R 7011.7905 ' '

Temperature Monitoring: The Permittee shall install, calibrate, maintain, and operate temperature monitoring equipment according to manufacturer's specifications. The calibration of the chart recorder, data logger, or temperature indicator must be verified every 3 months: or the chart recorder, data logger, or temperature indicator must be replaced. The Permittee must replace the equipment either if the calibration is not performed, or if the equipment cannot be calibrated properly. Each temperature monitoring device must be equipped with a continuous recorder. The device must have an accuracy of plus or minus 1 percent of the temperature being monitored in degrees Celsius, or plus or minus 1 de grees Celsius, whichever is greater.

The recording device shall also calculate the three-hour block average combustion chamber temperature. Recorded values outside the range specified in this permit are considered Deviations as defined by Minn. R. 7007.0100, subp. 8a, continued below

12.0 CD Title I Condition: To avoid classification as a major source and modification under 40 CFR Section 52.21 and Minn. R. 7007.3000; 40 CFR Sections 64.3(b)(4)(ii) and 64.7(b); Minn. R. 7017.0200; 40 CFR Section 63.5150(a)(3)(i). (ii) and (b) : Minn, R. 7011,7905

continued from above The Permittee must install the thermocouple or temperatur e sensor in the combustion chamber at. a location in the combustion zone.

13.0 CD Title I Condition: To avoid classification as a major source and modification under 40 CFR Section 52.21 and Minn, R, 7007,3000: 40 CFR Section 64.3(b); Minn. R. 7017.0200

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

14.0 CD Title I Condition: To avoid classification as a major source and modification under 40 CFR Section 52.21 and Minn. R. 7007,3000: 40 CFR Section 64.9(b); Minn, R. 7017,0200

The Permittee shall maintain a continuous hard copy readout or computer disk file of the temperature readings and calculated 3-hour block average temperatures for the combustion chamber.

15.0 CD 40 CFR Section 63.3968(a) (satisfies 40 CFR Section 63.5150(a)(4)). Minn. R. 7011.8090

Air Flow Monitoring System. The Permittee must install, operate, and maintain each Continuous Parameter Monitoring System (CRMS) to measure air flow according to the following requirements: 1) The CRMS must complete a minimum of one cycle of operation for each successive 15-minute period. The Permittee must have a minimum of four equally spaced successive cycles of CRMS operation in 1 hour; 2) The Permittee must determine the average of all recorded readings for each successive 3-hour period of the emission capture system and add-on control device operation; 3) The Permittee must record the results of each inspection, calibration, and validation check of the CRMS; 4) The Permittee must maintain the CRMS at all times and have available necessary parts for routine repairs of the monitoring equipment; continued below

16.0 CD 40 CFR Section 63.3968(a) (satisfies 40 CFR Section 63.5150(a)(4)). Minn. R. 7011.8090

continued from above 5) The Permittee must operate the CPMS and collect emission capture system parameter data at all times that a controlled coating operation is operating, except during monitoring malfunctions, associated repairs, and required quality assurance or control activities (including, if applicable, calibration checks and required zero and span adjustments); 6) The Permittee must not use emission capture system parameter data recorded during monitoring malfunctions, associated repairs, out-of-control periods, or required quality assurance or control activities when calculating data averages. The Permittee must use all the data collected during all other periods in calculating the data averages for determining compliance with the emission capture system operating limits; AND continued below

M'NAT'HViA POL! l:TIO\ r<v<|RO£ AGi-NOY MR 01AllTY 5?0 L \!AYF! IT ROAD ST. PAUI.. MN 5515.5-4 IN

Facility Name: EDCO Products inc


Page 27 of 28 2 Jun. 2015 11:38


17.0 CD 40 CFR Section 63.3968(a) (satisfies 40 CFR Section 63.5150(a)(4)). Minn. R, 7011.8090

continued from above 7) A monitoring ma lfunction is any sudden, infrequent, not reasonably preventable failure of the CRMS to provide valid data. Monitoring failures that are caused in part by poor maintenance or careless operation are not malfunctions. Any period for which the monitoring system is out-of-control and data are not available for required calculations is a deviation from the monitoring requirements.

18,0 CD 40 CFR Section 63.3968(g) (satisfies 40 CFR Section 63.5150(a)(4)), Minn. R. 7011.8090

Capture Air Flow Monitoring System. The capture system monitoring must comply with the following requirements. For each flow measurement device, the Permittee must; i) Locate a flow sensor in a position that provides a representative flow measurement in the duct from each capture device in the emission capture system to the add-on control device: ii) Use a flow sensor with an accuracy of at least 10 percent of the flow; iii) Perform an initial sensor calibration in accordance with the manufacturer's requirements; iv) Perform a valida tion check before initial use or upon relocation or r eplacement of a sensor. Validation checks include comparison of sensor values with electronic signal simulations or via relative accuracy testing; continued below

19.0 CD 40 CFR Section 63.3968(g) (satisfies 40 CFR Section 63.5150(a)(4)). Minn, R, 7011,8090

continued from above v) Conduct an accuracy audit every quarter and after every deviation. Accuracy audit methods include comparisons of sensor values with electronic signal simulations or v ia relative accuracy testing; vi) Perform leak checks monthly; AND vii) Perform visual inspections of the sensor system quarterly if there is no redundant sensor.

20.0 CD 40 CFR Section 64.3; Minn. R. 7017,0200

Annual Calibration: The Permittee shall calibrate the temperature monitor at least once every 12 months and shall maintain a written record of the calibration and any action resulting from the calibration.

21.0 CD 40 CFR Section 64.3; Minn. R. 7017.0200

Quarterly Inspections: At least once per calendar quarter, the Permittee shall inspect the control equipment internal and external system components, including but not limited to the refractory, heat exchanger, and electrical systems. The Permittee shall maintain a written record of the inspection and any corrective actions taken resulting from the inspection.

22.0 CD 40 CFR Section 64.3; Minn. R. 7017,0200

Annual Inspection: At least once per calendar year, the Permittee shall conduct an internal inspection of the control device that includes all operating systems of the control device. The Permittee shall maintain a written record of the inspection and any action resulting from the inspection.

23,0 CD Title ! Condition: To avoid classification as a major source and modification under 40 CFR Section 52.21 and Minn, R, 7007.3000; Minn, R. 7007.0800. subp. 4 and 5

For periods when the thermal oxidizer is operated above the minimum combustion chamber temperature limit and the airflow meets the specified capture system operating limits, the Permittee shall use either one of the following when completing calculations as required elsewhere in this permit (for GP 001): a. The overall control efficiency limit specif ied in this permit for this equipment (90%); or b. The overall control efficiency determined during the most recent MPCA approved performance test. If the tested efficiency is less than the efficiency limit in this permit, the Permittee must use the tested value in all calculations until the efficiency is demonstrated to be above the permit limit through a new performance test.

24.0 CD Title I Condition: To avoid classification as a major source and modification under 40 CFR Section 52.21 and Minn, R, 7007.3000; 40 CFR Section 63.3963(c); Minn. R. 7007.0800. subp. 4 and 5: Minn. R. 7011,8090

For time periods when the 3-hour block average temperature is below the minimum combustion chamber temperature limit, this is a deviation.

For VOC, the Permittee shall use "zero" for the control efficiency in the permit calculations listed at GP 001 for all VOC-containing materials used during that time period.

For HAP, the Permittee must assume the control efficiency was zero during the time period of the deviation unless the Permittee has other data indicating the actual control efficiency of the control device and the use of the data is approved by the Administrator,

Ml\"\TSO 1A POLI.l " i ION (' (i'\ i ROi AGhNCY AIR 01 A) 11 y

I.Al'A1! FI Ti: RO AD ST. RUM.. MX 5S 155-4 I < >4

Facility Name:

Permit Number:

EDCO Products inc

05301047-006

Page 28 of 28 2 Jun. 2015 11:38


25.0 CD 40 CFR Section 64.7(d): Minn, R. 7017.0200

Corrective Actions: If the temperature or airflow are below the minimum specified by this permit, the a ir flow is riot in the direction specified by this permit, or if the thermal oxidizer or any of its components are found during the inspections to need repair, the Permittee shall take corrective action as soon as possible. Corrective actions shall return the temperature or air flow to at least the permitted minimum and/or include completion of necessary repairs identified during the inspection, as applicable. Corrective actions include, but are not limited to, those outlined in the O & M Plan fo r the thermal oxidizer. The Permittee shall keep a record of the type and date of any corrective action taken.

26.0 CD 40 CFR Section 64.7(e): Minn. R. 7017.0200

Documentation of Need for Improved Monitoring: If the Permittee fails to achieve compliance with an emission limitation or standard for which the monitoring did not provide an indication of an excursion or exeeedance while providing valid data, or the results of compliance or performance testing document a need to modify the existing minimum combustion chamber temperature, the Permittee shall promptly notify the MPCA and, if necessary, submit a permit amendment application to address the necessary monitoring changes.

27.0 CD 40 CFR Section 64.9(a)(2): Minn R. 7017.0200

As required by 40 CFR Section 64.9(a)(2), for the Semi-Annual Deviations Report listed in Table B of this permit and/or the Notification of Deviations Endangering Human Health and the Environment listed earlier in Table A of th is permit, as applicable, the Permittee shall include the following related to the monitoring identified as required by 40 CFR pt. 64: 1) Summary information on the number, duration, and cause of excursions or exceedances, as applicable, and the corrective action taken; and 2) Summary information on the number, duration, and cause for monitor downtime incidents.

28,0 CD 40 CFR Section 64.9(b): Minn. R. 7017.0200

The Permittee shall maintain records of monitoring data, monitor performance data, corrective actions taken, and other supporting information required to be maintained. The Permittee may maintain records on alternative media, such as microfilm, computer files, magnetic tape disks, or microfiche, provided that the use of such alternative media allows fo r expeditious inspection and review, and does not conflict with other applicable recordkeeping requirements.

29.0 S/A Minn. R. 7017.2020. subp. 1 Performance Test: due before end of each calendar 60 months starting 09/28/2011 to determine VC)C control efficiency. The performance test shall be conducted at worst case conditions as defined a t Minn. R. 7017.2005, subp. 8, using EPA Reference Method 25A, or other method approved by MPCA in the performance test plan approval.

Testing conducted during the 60 days prior to the pe rformance test due date satisfies the performance test due date, and will not reset the test due date for future testing as required: 1) by this permit: 2) by the most recently approved Performance Test Frequency Plan: or 3) within a Notice of Compliance letter. Testing conducted more than two months prior to the performance test due date satisfies this test due date requirement and will reset the performance test due date.

EDCO Products inc Permit No. 05301047-006 Technical Support Document

Attachment 3 Detailed Calculation Spreadsheets

EDCO Products inc Title V Renewal Application Detailed Calculation Spreadsheets

Emissions Calculations

EDCO

Criteria Pollutant and HAP Emissions

Uncontrolled Pollution Controlled Controlled

Stack Emission Potential to Control Potential to Potential to Vent Maximum Rate Emission Factor Rate Emit (PTE) Efficiency Emit (PTE) Emit (PTE)

Unit ID Unit Name ID Pollutant (units/hr) (lb/units) (Ref.No.) (Ib/hr) (ton/yr) (%) (Ib/hr) (ton/yr)

Unit ID Unit Name ID Pollutant units hr units ref (Ib/hr) (ton/yr) <%) (Ib/hr) (ton/yr) EUOOl Primer/Backer Coater 1 Total VOC 32.53 gal 6.21E-01 1 20.215 88.542 90 2.02 8.854 EUOOl Primer/Backer Coater 1 Glycol Ethers 32.53 gal 1.43E-01 .1 4.654 20.386 90 0.47 2.039 EUOOl Primer/Backer Coater 1 Ethyl Benzene 32.53 gal 9.47E02 1 3.079 13.485 90 0.31 1.348 EUOOl Primer/Backer Coater 1 Naphthalene 32.53 gal 2.51E-02 1 0.815 3.570 90 0.08 0.357 EUOOl Primer/Backer Coater 1 Xylene 32.53 gal 4.62E-01 1 15.032 65.838 90 1.50 6.584 EUOOl Primer/Backer Coater 1 Cumene 32.53 gal S.01E-03 1 0.163 0.714 90 0.02 0.071 EUOOl Primer/Backer Coater 1 Formaldehyde 32.53 gal 1.39E-03 1 0.045 0,198 90 0.00 0.020 EUOOl Primer/Backer Coater 1 Triethylamine 32.53 gal 4.18E-04 1 0.0.14 0.059 90 0.00 0.006 EUOOl Primer/Backer Coater 1 Isophorone 32.53 gal 3.59E-01 1 11.686 51.183 90 1.37 5.1,18 EUOOl Primer/Backer Coater 1 Toluene 32,53 gal 4.16E-01 1 13.537 59.294 90 1.35 5,929 EUOOl Primer/Backer Coater 1 Total HAP 32.53 gal 1.54E-01 1 5.018 21.980 90 0.50 2.198

EU006 Primer |R Oven 1 Total VOC 32.53 gal 5.59E+Q0 1 181.936 796.879 90 18.19 79,688 EU006 Primer IR Oven 1 Glycol Ethers 32.53 gal 1.29E+00 .! 41.889 383,475 90 4.39 18.347 EU006 Primer IR Oven 1 Ethyl Benzene 32.53 gal 8.52.E-0.1 1 27.709 121.364 90 2.77 12.136 EU006 Primer IR Oven 1 Naphthalene 32.53 gal 1.34E-01 1 4.344 19.026 90 0.43 1.903 EU006 Primer IR Oven 1 Xylene 32.53 gai 4.16E+00 1 135.284 592.544 90 13.53 59.254 EU006 Primer !R Oven 1 Cumene 32.53 gal 4.51E-02 1 1.467 6.425 90 0.15 0.643 EU006 Primer IR Oven 1 Formaldehyde 32.53 gal 1.25E--02 1 0.407 1.785 90 0.04 0.178 EU006 Primer IR Oven 1 Triethylamine 32.53 gal 3.76E-03 1 0.122 0.535 90 0.01 0.054 EU006 Primer IR Oven 1 Isophorone 32.53 gal 3.23E+00 .1 105.171 460.650 90 10.52 46.065 EU006 Primer IR Oven 1 Toluene 32.53 gal 3.75000 1 121.837 533.647 90 12.18 53.365 EU006 Primer IR Oven 1 Total HAP 32.53 gal 3.39E+00 .1 45.164 397.817 90 4.52 19.782

EU002 Top Coater 1 Total VOC 28.21 gal r 5.28E-01 1 14.895 65.242 90 1.49 6.524 EU002 Top Coater 1 Glycol Ethers 28.21 gal 1.30E-01 1 3.654 16.005 90 0.37 1.601 EU002 Top Coater Ethyl Benzene 28.21 gal 8.57E-02 1 2.417 10.587 90 0.24 1.059 EU002 Top Coater -} Naphthalene 28.21 gai 2.27E-02 1 0.640 2,802 90 0.06 0.280 EU002 Top Coater 1 Xylene 28.21 gai 4.18E-01 1 1:1.803 51.690 90 1.18 5.169 EU002 Top Coater i. Cumene 28.21 gal 4.54E-03 1 0.128 0.560 90 0.01 0.056 EU002 Top Coater 1 Formaldehyde 28.2.1 gai 1.26E-03 1 0.036 0.156 90 0.00 0.016

EU002 Top Coater j. Triethylamine 28.21 gal 3.78E-04 1 0.011 0.047 90 0.00 0.005

EU002 Top Coater 1 Isophorone 28.21 gal 3.25E-01 1 9.174 40.184 90 0.92 4.018

EU002 Top Coater 1 Toluene 28.21 gal 3.77E-01 1 10.528 46.552 90 1.06 4.655

1

EDCO Products inc Title V Renewai Application Detailed Calculation Spreadsheets

Unit ID Unit Name ID Pollutant units hr units ref (Ib/hr) (ton/yr) (%) (Ib/hr) Ston/yr) EU002 Top Coater .1 Total HAP 23.21 gal 4.51E-01 1 12.729 55.753 90 .1,2.7 5.575

EU003 Top Coster Oven i Total VOC 28.21 gal 4.75E+00 1 134.059 587,180 90 13.41 58.718

EU003 Top Coater Oven 1 Glycol Ethers 28.2:1 gal 1.17E+00 1 32.887 144.046 90 3.29 14,405

EU003 Top Coater Oven 1 Ethyl Benzene 28.21 gal 7.71E-01 1 21.754 95.283 90 2.18 9.528

EU003 Top Coater Oven 1 Naphthalene 23.2.1 gal 2.04E-01 .1 5.758 25.222 SO 0.58 2.522

EU003 Top Coater Qven 1 Xylene 2.8.21 gal 3.76E+00 1 106.212 465.207 90 10.62 46.52.1.

EU003 Top Coater Oven 1 Cumene 28.21 gal 4.03E-02 .1 1.152 5.044 90 0.12 0.504

EU003 Top Coater Oven 1 Formaldehyde 28.21 gal 1.13E-02 1 0.320 1.401 90 0.03 0.140

EU003 Top Coater Oven i Triethylamine 28.21 gai 3.40E-03 1 0.096 0.420 90 0.01 0.042 EU003 Top Coater Oven 1 Isophorone 28.21 gal 2.93E+00 1 82.570 361.656 90 8.26 36.166 EU003 Top Coater Oven 1 T oluene 28.21 gai 3.39E+00 1 95.654 4.18.966 90 9.57 41.897 EU003 Top Coater Oven a Total HAP 28.2.1 gal 4.06E.+00 .1 114.551 501.779 90 11.46 50.178

EU004 Primer Quench Total VOC 0 lb 1.00E+00 3 0.000 0.000 0 0.00 0.000 EU0Q5 Top Coat Quench 3 Total VOC 0 lb 1.00E+00 3 0.000 0.000 0 0.00 0.000 EU007 Top Coat IR Oven 1 Total VOC 0 lb 1.00E+00 4 0.000 0.000 0 0.00 0.000 EUOOS NSPS Oven 1 Total VOC 0 lb 1.00E+00 .5 0.000 0.000 0 0.00 0.000 EU009 Emergency Generator 4 Total VOC 0 lb l.OOE+OQ 7 0.000 0.000 0 0.00 0.000 EU011 Cure Oven 6 Total VOC 0 lb 1..G0E+00 6 0.000 0.000 0 0.00 0.000 EU013 Cure Oven 8 Total VOC 0 lb 1.OCT:+00 6 0.000 0.000 0 0.00 0.000

EU010 Shingle Painting Line 1 5 Total VOC 553 shingles 2.658.-02 2 14.633 64.093 0 14.63 64.093 EU010 Shingle Painting Line 1 5 Glycol Ethers 553 shingles 3.07E-03 2 1.697 7.433 0 1.70 7.433 EU010 Shingle Painting Line 1 5 Ethyl Benzene 553 shingles 2.03E-03 y 1.123 4.917 0 1.12 4.917 EUOIC! Shingle Painting Line 1 5 Naphthalene 553 shingles 5.37E-04 2 0.297 1.301 0 0.30 1.301 EU010 Shingle Painting Line 1 5 Xylene 5S3 shingles 9.91E-03 2 5.480 24.005 0 5.48 24.005 EU010 Shingle Painting Line 1 5 Cumene 553 shingles .1.07E-04 2 0.059 0.260 0 0.06 0.2.60 EU010 Shingle Painting Line 3. 5 Formaldehyde 553 shlnales 2.9SE-05 2 0.017 0.072 0 0.02 0.072. EU010 Shingle Painting Line 1 5 Triethylamine 553 shingles 8.36E-06 2 0.005 0.022 0 0.00 0.022 EUOIO Shingle Painting Line 1 5 Isophorone 553 shingles 7.70E-03 2 4.251 18.661 0 4.26 18.661 EUDIO Shingle Painting Line 1 5 Toluene 553 shingles 8.93E-03 y 4.936 21.619 0 4.94 21.619 EUOIO Shingle Painting Line 1 5 Total HAP 553 shingles 2.26E-02 2 12.505 54.771 0 12.50 54.771 EUOIO Shingle Painting Line 1 5 Total Metallic HAP as PM 553 shingles 5.11E-04 2 0.282 1.237 92 0.02 0.099 EUOIO Shingle Painting Line 1 5 Total PM 553 shingles 2.1.4E-03 2 1.18:1 5.173 92 0.09 0.414

EU012 Shingle Painting Line 2 7 Total VOC 553 shingles 1.29E-02 2 7.153 3.1.331 0 7.15 31.331 EU012 Shingle Painting Line 2 7 Glycol Ethers 553 shingles 1.50E-03 2 0.830 3.633 0 0.83 3.633 EU012 Shingle Painting Line 2 7 Ethyl Benzene 553 shingles 9.92E-04 7 0.549 2.403 0 0.55 2.403 EU012 Shingle Painting Line 2 7 Naphthalene 553 shingles 2.63E-04 2 0.145 0.636 0 0.15 0.636 EU012 Shingle Painting Line 2 7 Xvlene 553 shingles 4.84E-03 2 2.679 11.734 0 2.58 11.734 EU012 Shingle Painting Line 2 7 Cumene 553 shingles 5.25E-05 2 0.029 0.127 0 0.03 0.127

EU012 Shingle Painting Line 2 7 Formaldehyde 553 shinales 1.46E-05 2 0.008 0.035 0 0.01 0,035

EU012 Shingle Painting Line 2 7 Triethylamine 553 shingles 4.38E-06 2 0.002 0.011 Q 0.00 0.011

EU012 Shingle Painting Line 2 7 Isophorone 553 shingles 3.77E-03 2 2.083 9.122 0 2.08 9.122

EU012 Shingle Painting Line 2 7 Toluene 553 shingles 4.36E-03 ? 2.413 10.568 0 2.41 10.568

2


Unit ID Unit Name ID Pollutant units hr units ref (Ib/hr) (ton/yr) <%) (Ib/hr) (ton/yr) EU012 Shingle Painting Line 2 7 Total HAP 553 shingles 1.11E-02 2 6.113 2.6,774 0 6.11 26.774

EU012 Shingle Painting Line 2 7 Total Metallic HAP as PM 553 shingles 2.50E-04 2 0.138 0.604 92 0.01 0.048 EU012 Shingle Painting Line 2 7 Total PM 553 shingles 1.03E-03 2 0.558 2.488 92 0.05 0.199

TOTAL VOC EMISSIONS 372.892 1,633,268 249.208 TOTAL PM EMISSIONS 1.749 7.661 0.613 TOTAL PM10 EMISSIONS 1.749 7.661 0.6:13 TOTAL CO EMISSIONS 0.000 0.000 0,000 TOTAL S02 EMISSIONS 0.000 0.000 0.000 TOTAL NOx EMISSIONS 0.000 0.000 0.000 TOTAL HAP EMISSIONS 392.180 858.874 159.278 LARGEST SINGLE HAP EMISSIONS (Xylene) 276.488 1,211,018 153.267 TOTAL Pb EMISSIONS 0.000 0.000 0.000

VOC = volatile organic compounds PM -- particulate m atter PM10 = particulate matter under 10 microns CO = carbon monoxide S02 = sulfur dioxide NOx = nitrogen oxides HAP = hazardous air pollutant Pb = Lead

REFERENCES:

1. Primer/Backing/Top Coat Coating/Drying Operations Maximum coating rate based on a maximum linespeed of 225 ft/min See "Coaler Specs" tab for more information Maximum VOC and HAP based on worst case paints. Individual HAP concentrations based on worst case paints. Potential and Actual emissions will be much lower than calculated.

Per AP-42, 5th Edition, Section 4.2.2.10, approximately 10% of coating emissions occur al mixing/coating and 90% occur at drying. These percentages are assumed for the calculations. However, both coating and drying emissions are exhausted out. of SVQ01. SV001 is controlled by a thermal oxidizer thai is permitted with a minimum of 90% VOC/HAP control.

2. Maximum capacity based on maximum design rate, 553 shingles per hour. See "Shingle Specs" tab for more information.

EDCO Products inc Title V Renewal Application Detailed Calculation-Spreadsheet®-

Annual maximum production hours based on 5 days per week, 52 weeks per year, and two shifts per day (5x8x52x2=4.160 hr/yr) Maximum VOC and HAP based on worst case paints. Individual HAP concentrations based on worst case paints. Potential and Actual emissions wiil be much lower than calculated.

MSDS Information: (maximum values) Density 10.92 ib/gal Total HAP 3.91 Ib/gal

VOC Content, Paint 4.576 ib/gal VOC Content, MEK 6.75 Ib /gal

Solids Content i% wtlj 100.00

Maximum Capacity 553 shingles/hr

Spray Gun Information: Overspray 25 %

Fiiter Information: Efficiency (per MPCA) 92 %

Actual rate based on 8100 shingles/day (maximum is 1.3,272)

3. Quenching Operations This Is a cooling operation that has negligible emissions. All potential emissions are calculated at the coating and drying units.

4. Top Coat IR Oven Unit has no potential emissions and has not operated sifioe-aooo. Cufraiitly being used as a duct.

5. NSPS Oven. Potential VOC emissions are accounted for at SV001 (Unit ID'S EU001. EU002, EU003. EU006) Unit will have combustion emissions (4 mmbtu/hr).

6. Cure Ovens. All potential emissions are calculated at the spray booth units (EU01Q and EU012).

7. Emergency Generator was previously permitted but will not be installed. Remove from emission Inventory.

4

EDCO Products !nc Title V Renewal Application Detailed Calculation Spreadsheets

Potential Combustion Emission Calculations EDCO Combustion Calculations

Form Unit ID Unit N3me Pof'utant

Poifutant Type

Maximum R<stis (tinitsfhfi | iunltSf'hr}2

Eri::«»Si<V!1 racfor (!b.'iinits) RefNc

fcrnbsion Rate

(fb-'hrj

Uncontrolled Potentiai to emit {PT6<

(tori/yr)

Pollution

Efficiency

Controlled Potential to Em:t {PTfr.5

(tcn-'yr;

Estimated HoufS fhf/yr}

cstiroatcd fi.miSiS:OI5S {toniyr? 2

Gicbal Wnrrmn?} PetttniiiJi (GWPi

Pctcntini Emit (P"f!}

{ton CO; ••!• Form

Unit ID Unit N3me Pof'utant

V 0 C r, P

M 10

c 0 iSs H

A P

P b

Maximum R<stis (tinitsfhfi | iunltSf'hr}2

Eri::«»Si<V!1 racfor (!b.'iinits) RefNc

fcrnbsion Rate

(fb-'hrj

Uncontrolled Potentiai to emit {PT6<

(tori/yr)

Pollution

Efficiency

Controlled Potential to Em:t {PTfr.5

(tcn-'yr;

Estimated HoufS fhf/yr}

cstiroatcd fi.miSiS:OI5S {toniyr? 2

Gicbal Wnrrmn?} PetttniiiJi (GWPi

Pctcntini Emit (P"f!}

{ton CO; ••!•

Unit 10 Unit Name Pollutant c 10 0 P b (units-'hr) (fb/units) (Ref.No.) (Eb.'lirj • toiVyr} {%{ (hr/yri {ton/yr- •GWP) Hon CO; ••:• ryr":

FACILITY EQUIPMENT

CE0G1 C-"> •< OOCJ$< rnrncf r-1 0 '12 i.S04 1 S0-1 o-eô 1.004

CEDC1 N0'< nunc:: l{':0 O.^-'O 2 14? 2 14.' 0'0(- 2 VJ/

CF001 Thwnial C*l4^<?r PS A •< G 'JCM^ rr-rr-irf 0.0005 0 i)0l; 0 000 0 l; 000 O.'OO 0 000

CE0G1 Thermal Oxld^r 11 1 V > 0 oo.it rnrnci 0 0i.' i G 3:S? =<.•00 •0.

CKJ01 i>V3 < ;'>.Oi;4;5 nunc;: :-".p 0.037 0 *b> 0 IS J 0-00 0 100

oeoc! T"ll.'ll GAid:Zi>r SOX 0 'J04C: n-n-c? 0 0 0 00J •j 0"{* 0 0 -J i 3 570'J 010 CE0C1 Thermal Cr^zei Tots: VOC V C' 0C-1& ITITC: 5 jl 02" o. • • s 0 110 s.-eo 0 * ' b CE0C1 7o<invra: Oxidizer COG r-.oooo- •v-tvibur : 1 v 0 r S-'-J'j 2'iV-2 0 ?.'bvl O-'OO 2':02 ,?0->2 CEiOO't i'n« < ^n.=«l CH4 :j OC'liO 'nmwu 0 00'.: G- G ;}«:i 0/^0 {;.-040 : 1

CE001 Thermal Cridizei ;<J20 5 0000 ummbtu 0 002 l~ Hi 0 0-1 J •J 0 040 t/00 0.040 25-3 U'j

CKOt; I Th<rt«i.a! ;• {-04^ mmcf :• G0E-04 0 000 G.OCv 4.':0:v0-0 0700 -0.00-C: CE0C1 Thermal 0*:d:i>«;[ Benzene (j.OO'lS iniroi : 0E-00 0.000 0 000 0 5'E-O? fi.-OO 0 000 OEOOI Tneinial Oxidizer SeivKiuni Conrco^nos r.CG4?; n-mcf ! 20=-0:-- 0.000 0 -JO-J 2 5SE-0/ 37';U U C-OG CE0G1 Thermal Oldzv Cacir;i:urr; Cnrnirouncis i; C'v4& rnrncf 1 1CE-03 G GOG 0.000 V OOGO-OO •O.C"X;

CE-301 T>:.jrni<i! 0*:di;:et C!w)»ui?: Oorr-^cuncisi 0.0(^:5 ;ninc;; i.^G-CO-OO 0.000 0 00") 0 ? 0;>0 0'j 0 GOO CEOC f Tnema! 0*:d:'<?r Cobait Compounds •j 00*1?: n:n:CT e 40E'05 0.000 0 000 0 1 30E-06 37'30 0 000 CECO'l Thermal Oyidi?:* Oich;woberi2en<n. 0 '.5C -4& rnrncf 1 20E-03 0 GOG G- 00- 0 r: 2 :^!v.-0:i 0700 O.O'OO' OEOOI T>:-»^sri{»l OK:tii;: s-r »vCr!fl8!d<}f;vd« < ni;m-.i -'.)2 1 0.000 0.002 &•'<¥.) 0 002 CEOC-i Thesm?;! OiJdi^-v Hiaant- x 0 0C-<tT- rjKUCf '•• OOE ÔO 0 002 0 -J?0 0 S0E-02 0760 0 00f:

CEOOt Thermal C^das! 0 OC'S :-n srtcf 5 C-OE-O-1 C..100 0 000 o 1 07E-05 £760 0 000 CED01 •ffw-ria! Ocdiner Mannsnese Compounds O.CG4'v fnrTir.t o.oodl 0 000 6 10E-0:> .->,,"G0 0 GOG CE001 Th<t-Em-:i! Oxidizer Me'CU:'/ Compounds 0 U04c' mmcf 2 i50E.04 0 000 0 000 0 S.55E-0& 0760 0.000 CE001 Thermal O^dizei Naphtrsiene 0 0C-1S jr-ir-c: •3 10E-0-1 0 000 0 000 0 • 0'5 -05 S"£0 O.OC-O CED01 Thermal Oxidizer Nickel Cci'r-tr-ounds 0.0G4:-; mmc: 2.1GE-C-0 1 O.ODC 0 000 G ;''3 8."00 0 OC-G CEOO'i ThS:i«)4l Ssrlarn'jfn Corn;:-:;un;!s '.;04^ rr-rr-cf G- 000 0.000 0 :'xv-07 0700 C;0-C;

CED01 "hi'r-nai O^dizet ToKiene O.vO.lij ir-mo: 3/0E-C? 0.000 0 000 0 7 OOE-O? £700 0 000 OEOC • Tnernial Oxsrsirer j POM ninict P.S2E-05 o.oco 0 000 1 oOE-G-o^ •3760 0 000

EU003 ~ Zone Own 00 y 0.0027 iriinis 64 0.2o': i 010 ; 010 •3760 EU003 2 Zone Oven N0V. v 0.C027 n i rt'i cf- "00 0 275 1 202 n 1 202 •37-':0 ~-rr £UOGO 2. Zone Oven .< o rrrrcf 0 -OOG 0.000 0 0 -000 0700 V 00-0 CviJDOS 2 /.one C-v-ii'i PM10/PM:: ? V:.Q0Z' mint:; y.b O.OG'l 0 001 '• 00'! ?)7.;o 0- 0 C:' =:JOOO 2 Zone Oven PM Y 0 '.;0/?V £-n':Ci 7 0 0 ;J2I 0 0 001 -<7F.i} 0 00 : EUOOo 2 Zen? Oven «QY 0 C-C27 mir J 0 •" ri 002 0 007 o L C' -°IJ 07C0 n 007 ;rJ003 2 Zone Gv-si'i Tolfil VOC • < {'.00/7 ir ind 0.01? 0.000 h ~ 00^ 0700 0 oe-!5 =:JOO? 2 Zona Oven C02 2 ?/OCO rnri:Wu 117 0 528 1-105 o :4"5 *<7fs3 14" 1<i3r' tOJOOi A. Zone Oven CH.1 2 3000 mir-btu 0 002 n - 02 <- o n o"d £7l;:.:"i 0 Q- y, 2-" 0 0 ••/•JOCS '] /.one Gv^n :S2.0 •V:n-:fctl! 0.002 0 0 024 0 0'>'Tt 0 024 v

EU003 2 Zone Ov;?n Ai-seivc CC;m!X:UfidS OQ-j'.' [<11)10? 2 00E -0.1 n nc-n o ooo 2 40E- 06 0"'6Q -••••ros 2 i.one Ovin c.ooz; i;i mc- ^."iOvl-OC-- C-.OG-O 0 000 •srvsr1: 0 '--O'-EIJOGO 2. 'c rii! v.ivcrn K«rivS!i;fi) C-:yn;:ou:x::» 0 GO" rt;r!-d 1 ÔKvO:; 0 ;!0G- 0 -ooo o 1 44 --'.(V.' 070') f; 000 EU0C3 jZone Oven CjidriiMin Oesruouno'? 0.0027 inro- 1 IC'P-O? •0 ooo 0 OOO 2 i r-c-o^ 0700 0 r'-O'i EUOO? 2 _one Oven CI"iron'::Mir Oompo-j":d? '10027 n: n-icf i -iOE-c;- 0 0"0 0 000 0 1 ê.p.ryj W-o 0 000 EUOOO 2. Zone Oven Coba;t C omoourics o GO:~;' IT mcf o ^0rX-C;: 0 -GOG' 0 -000' r: : O'lv'.OO 070-0- i\ r.,-V: •vu::o;-: Zone Ov-;n ii.'i-^-i-MObenênesi 0.0G/7 nn)i;:; '.2:}(v-00 o O;;D 0 000 o 1 o ,10,1 EU003 2 i.one Oven ôi nialdenvde 0 0027 n:n-:cf ~ S0E-G2 1 0 000 0 001 0 02E-04 0 0"1 LLVOO 2 Zone '."/en Hwjine oc-v:-" WKi i.SOt--'* 0 G0;; G 0/2 2 16 [v.-02 rvj'--(v.UGOO :: Zone: Oven liMi Cwiooisvlf.- •:;.0l;27 ;r:i)i;:: r.OOi'•O'S O.OG-O O GOO 6 01E- 06 07G-: 0 000 E! JOO? 2 <_on;> Oven 0.002"' -nrnd .? SOE-04 0 000 0 000 r. 4 07F-O5 "<7'*0 -'lO-'l EUOOO 2 Zon<D Oven Merely Con-iDounds 0 0027 IT ITC.? 2 -?CE-0^ 0 000 0 000 c ?• !'3E-00 67£.I r-: onn ;vJOO.-J G Zone Oven •'•'.OC'/V mmcr O.'lGiiv-G'a o ooo 0 0-00 ? 50>-'-{.:> :1 ,'10i1 B.JOGO 2 Zona Oven C-onn:otKi--5i. !; GO-1' r-rji-rK-? :• lOE-OO o :;OG 0 000 0 " O/O- 0700- O'X-tUOOi l Zens Oven Seieniym Comocuncl-s 0 0027 rrrr-cf 2 <i0P.C5 0 00^ 0 000 2 c.oc.o? 0760 n noc-

2 /.one Ovei'i lo-uens {'i.CGZ/ pi mc! O.-iOiiv-G-O J: 000 0 000 00>;--0'5 :1

EUOOO 2.1'.tine uvc.-n POM 0 <K!2:' rnrncf «0:; 0 GOO (: ' '^0-O-G 0700 -", v :0-0

EU0C8 NSPS Oven CO ,V 0 r>o* n-in-ic< •S4 1 0 i"-9 1 4.^ .irijo 1 443 EUOOO KSPS Oven :-10A > G'.C ;>s rnrncf i 0 :^97 1 •' * 8 0 < V-lf! i ! EL'OOS NSPS Oven r'S > 0 004 ;ri;nc? 0 cooo 0.000 r oon 1; n ooo n 000 suooe NSP-S Oven PM lO.,pM2 5 n-n-sr? 7 6 0.000 0 ''2'- 0 1^1 37:10 0 ' ' El'OGo NSPS Oven rrrrcf '.' G 0 GvG 0 1 3 : r; >'• i 5 5 0700 ri : 5: v:j:)08 KiOr-^ Ovar; -•C-A 0 004 nmid •:).6 0.002 0 0:0 0.010 .07,50 EJ006 N3?3 Oven TotJi VOC X O.OC-I 5 5 0 022 0 0:54 n 0 034 0 0--M tUOOS NSPS Oven C02 4 000 [iîribtu 1*7 0 <•68 "•0-19 o ":"!49 S7»r- 20*9 i-uooa 0 •;<>?• cm 4 GOG rv-iibUi P. 002 0 0 005 0 005 S7GO 0 0*0 tUOOO f;3P3 wen N20 •1.000 n-r-W-; 0 002 0 005 0 0 0 • n-«o G 03^ 10 4

NSPS '..."/ft!* Afwrac Con-fMurr;]^ 0.004 rr;iT;.:-f 2 G0E-04 000 0 0 440'0G r<7f-0 •0 00( ;

EU008 NSi-'S Ovi??! 0 004 niiro! 2. lQP-0? c< non n ooo " 6n-.-j*? £700 0 GOO Jv'OS NS-PS- Oven j^rvlliun": 0 00' nnic* 1 20E-0S 1 0 000 0 000 "• 2 C6E-07 17^0 0 000

BJOGO N3PS OVB:"- Cfldmsurt- CcsR-tounciK :< 0.0G4 n-n-if 1 10E-('.5 0 GOG 0 0:0-0 c VOGO-Ori 0700 ••'.OOC^

EDCO Products Inc Title V Renewal Application Detailed Calculation Spreadsheets


TOTAL FACiLiTY EQUIPMENT TOTAL VOC EMISSIONS TOTAL PM gMiSSiONS TOTAL PM10 EMISSIONS TOTAL P1V12.5 EMiSSiOMS TOTAL CO EMISSIONS

VOC -PM = paniculate matter '•VU! - particulate carter under 10 microns. CO :: oarhXi mor!<Xi-:55r SO?. - OOV:OT NO>. :: nitrocicn oridss HAP " haMiUlous i)ir

CO2<? = eaibon d-oxide eou:vs:?--j

RefERGNCES:

•• G3? CC:ri!XiSt:0:': !-vUi}(«v Zl-

Procs-st rjts '.£;J00-C5). <V C MMBtu.'hi Proc-»? rate (CE001:

fectcws: i-'fotr S-dion l£. A"-J", n'h v:di;:c-n t.r^ssion f.sc.to; 5 iGf'IG) 7.3bl? 1'j. I of TCS GRP !h>ts ?i f? soi:or of 52 {* C02 ; MMP-u ;o; Natural Ga& • U.S. Av?r.?;}?:• Emission factors iGHGi TsHc '>2.7 of "'CR GKP T-JNC '-2 7 list s faaors of 0 9 g CH<!: WMBtu ?:ii<2 0 ? g N2C- MMBtu fo- Ma turs: Boilers Avfj-ii or ^timeted »vorit c,:se op-irat:na hou-s-

6



Form

Unit ID Uiirf Name FofUitant

PoMutant Type

Maximum Rate

(unMs/hr) }{urnls/hr)2 Emission Factor

(Jb/unitiJ) Ref N«>

Emission Rate

(fb/hrj

Uncontrolled Pofontia? to Emit {PTE}

{i:oti/yr}

Pofiution Control

Efficiency

{%}

Controlled Po'ontiai to Emit (PTE)

(to!Vyr)

Esfjcnafed Hours (hr.'yr)

Estrsnatfjfl Emissions (ton/yr) 2

Global Wan-nirKf Potential

(GWP;

Potential to Emit (PTE)

{ton CO if) Form

Unit ID Uiirf Name FofUitant

V 0 P

M

P W

ID

C

0

s 0

N 0

H A s>

p

b

Maximum Rate

(unMs/hr) }{urnls/hr)2 Emission Factor

(Jb/unitiJ) Ref N«>

Emission Rate

(fb/hrj

Uncontrolled Pofontia? to Emit {PTE}

{i:oti/yr}

Pofiution Control

Efficiency

{%}

Controlled Po'ontiai to Emit (PTE)

(to!Vyr)

Esfjcnafed Hours (hr.'yr)

Estrsnatfjfl Emissions (ton/yr) 2

Global Wan-nirKf Potential

(GWP;

Potential to Emit (PTE)

{ton CO if)

Unit ID Unit Name Poiiutam L C M 10 0 2 P b (units/hr) (lb/units) {Ref.No.) (!b/hr) (ton/yr; {%) (ton.'yr; {hr/yr; (ton/yr) (GWP) {•on CO.-e ,-vr)

FACILITY EQUIPMENT

IA Lanjesl IA NG Combustion Un=t CO O.Ou i 2 mm-:! £4 1 O.OSS 0.4:^ 0 0 430 376!; 0.403 f.

Lsroesi IA NG Combustion Unit NOX 0.0012 •rsmcl '00 1 0.118 0.515 Q 0.515 3760 0.515 IA Laroest IA NG Combustson Unit PR 0.001? •rircicf 0 0005 0 000 0.000 0 0.000 8760 0 000 IA Largest IA NG Combustion Unit PM10/PM2.5 0.0012 •ririicl' 7.6 i 0.003 0 039 0 0.039 C750 0 039 !A Largest IA NG Combustion Unst PM 0.0012 n-srviof 7,6 1 0.003 0.02? 0 0 039 S7'5G 0.039 iA L'srqesl IA NG Combustion Unit SOX 0.0012 mind 0 5 i 0.00 i 0.003 0 0.003 8760 0.003 IA Lsroesf. IA NG Combustion Unit Total VOC x 0.0012 srsmcf 5.5 1 0 005 0.024 0 0.028 8760 0 02$ iA. Laraest IA NG Combustion Unit C02 1.2000 inmfctu f 1 ? 0 i •<50 615 o 615 £750 e J 5 615 !A Lards#' IA NG Combustion Unit CH4 1.2000 m mbtu 0 002 1 0 0.0 Ki 0 010 S760 0.010 25 0.3 IA largest IA NG Combustion Unit N20 1.2000 mmbtu 0.002 i 0 0.010 o o 0 i 0 3760 0.010 2S3 : IA Largest [A NG Combustion Unit Arsenic Compounds? 0.0012 mmof 2.00E-04 C',000 0.000 0 1.03E-05 87SG 0.000 !A Larqe^f iA NG Cornbustion Unit Senrene 0.00:2 mmd 2 10-03 i 0.000 0.000 0 i 08E-05 O 7>y:.) 0.000 iA Leraest iA NG Combustion Unit Beryllium Compounds 0.0012 mmcf t.20E-05 1 u, OOu 0.000 o 5.18E-0P 3760 0.000 IA L-araest !A NG Qombustson Unit Cadmium Compounds 0.0012 •y-mcf 1.10E-03 1 0.000 0.000 0 5.67E-0S 4760 0 000 IA Larqest IA NG Combust-ors Unit Chromium Compounds 0 0012 rr-rncl' 1.40E-03 t 0.000 0.000 0 7.21 E-05 S760 0.000 ;A Largest iA NG Combustion Unst Cobalt Compounds- 0.0012 rnmct 8 40E 05 1 0.000 0.000 1) 4 2 ;ic.r:7 8760 0.000 :A Laroest iA NG Combustion Un-l D'chlorobenênes 0.00*2 rnmcf I.20E-03 1 0.000 0.000 o 6.18E-06 3760 0.000 !A Larci<?st !A NG Combus'son Unit For-r-isildehvd® 0.0012 •nrnrf 7.50E-02 L 0 000 0.000 0 3.$i5E-04 3760 0 000 !A Laraest IA NG Combustion Un-l Hexane 0.0012 sTinicf {.80E-5-00 i 0.002 0 00? Q 9.2SE- 03 6750 0.009 iA Largest IA NG Combustion Unst Lead Compounds 0.0012 mm--:! fj 00=.04 i 0.000 n ooo o 2 f:Se-0o 67.^0 0.000 iA L«:raesl iA. NG Combustion Unit Manganese Compounds 0.0012 mmcf 3.S0E-04 0.00 0 0.000 o ;.S(3E-0S 0.000 IA Laroest iA NG Oombus'son Uri-t Mercury Compounds. 0.0012 srsmcf 2.60E-04 C 00 0 0.000 o 1 •5760 0 000 IA larqest !A NG Combustion Unit Naahthalenv' 0.0012 irrmcf 6.I0E-C4 0 ooo 0.000 ~Q" :-.14E-0-3 5760 0.000 iA I. arcse?:t IA NG Combustion Unst Nickel Compounds; x 0.0012 mmof 2 io f:-o:> < 0 000 0.000 I 08E-05 8760 0.000 IA Largest IA NG Combustion Unit Selenium Compounds X 0.0052 mmof 2.40E05 0.000 0.000 0 ; 24P--07 8760 0.000 IA Lar<i*st !A NG Combustsor Unit Tc>!u*ne X 0.0012 ir-mcf 3.40E--0S •i 0 000 0.000 0 1 75P..:-.r, 0 000

Li)f<!<i'S>t IA NG Combuslsor- L'mt POM < 0.00-2 ir-rncl" $.$2E--0S i 0 000 0.000 G 4.ME-07 6 7 GO

TOTAL FACILITY EQUIPMENT TOTAL VOC EMISSIONS — 0.006 0 028 0 028 0 028 TOTAL PM EMISSIONS 0.009 0 0'i^ 0 0'!-' TOTAL PM10 EMISSIONS " """ 0.009 0^3^ 0.033 TOTAL PM2.5 EMISSIONS 0 009 0.053 TOTAL CO EMISSIONS — 0 0S9 0.430 TOTAL SO2 EMISSIONS 0.00 s 0 '-y-? TOTAL NOx EMISSIONS '— 0.218 TOTAL HAP EMISSIONS 0 002 0.010 LARGEST SINGLE HAP EMISSIONS fTotai HAPi " 0.002 o'oio TOTAL Pb EMISSIONS 0.000 TOTAL C02e EMISSIONS SREF! SF-EF-:

VOC :: volatile organic compounds PM = pa rl=c;ti!?i:.'j mailer PfvS :0 :: particulate matter under 10 microns CO = carbon monoxide S02 "• dioxsde NOx = nitrogen oxides HAP :: hzz'.-urious asr polmtant

00?e carbon dioxide equivalents

REFERENCES:

1 Proses?"- • Natural G as Combti?;tion Process i ate {EU0G3;: 2.8 WMBlu/hr Process rate (EU008; 4.0 MMStu'br Process rale (CE001) 5 MMetu/hr Emission factors: From Section 1 < 1. A P-<12, 5th Edition Emission factors -GHG): T ?•!:>!•!• 12 .1 of TCR GRP I ssts a facto r o[ 53 06 k< ;f C02 • MMotu for Natur al Ga:? - Un<'.pec:!fi-?d (Wysyhlsw U.S. Avâj;!*} Emission factors (GHGV Tabie ! 2 7 of TCR GRP Table 12.7 lists factors of 0.9 g CH 4 • MMBtu and 0. 9 g N20 • MMBtii for Naiurai G as Boilers Ac;UJ.a! e missions based on (intimated vwsl operating hours

7

Title V Renewal Application Detailed Calculation Spreadsheets

Assumptions: Units Max Per Units

Hour Max Coil Width .19.1 Inches Max Line Speed 225 FPM Max Sq F T per Hour 21487.5 Sq. Ft./Hour Backer Coverage E2Z-18236EDCH 1212 Sq. Ft./Gal 17.73 Gal/Hr Backer HA PS 0,58 Lbs/Gal 10.30 Lbs/Hr Backer VOC 4.45 Lbs/Gal 78.95 Lbs/Hr Primer Coverage UYR60000 1453 Sq. Ft./Gal 14.79 Gal/Hr Primer HAPS 2.70 Lbs/Gal 39.88 Lbs/Hr Primer VOC 8.33 Lbs/Gal 123.20 Lbs/Hr Top Coat Coverage PW1D3303 761.67 Sq. Ft./Gal 28.21 Gal/Hr Top Coat HAPS 4.51 Lbs/Gal .1.27.29 Lbs/H r Top Coat VOC 5.28 Lbs/Gal 148.95 Lbs/Hr

Total Gallons 60.74 Gal/Hr Total HAPS 177.47 Lbs/Hr Total VOC 351.11 Lbs/Hr

Primer/Backer Primer/Backer Primer/Backer VOC Emission Factor HAP Emission Factor

32.53 Gal/Hr 202.15 Lbs/Hr VOC.

50.18 Lbs/Hr HAP 6.215 lbs VOC/gaiion 1.543 lbs HAP/gailon

Top Coat Top Coat Top Coat VOC Emission Factor HAP Emission Factor

28.21 Gal/Hr 148.95 Lbs/Hr VOC 127.29 Lbs/Hr HAP

5.280 lbs VOC/gallon 4.51.2 lbs HAP/galion

Top Coat Fraction Top Coat Oven Fraction

0.1 0.9

Worst Case Coatings

Vendor ID

Total VOC (lb/gal)

Total HAP (lb/gal)

Type

Paint, Trinar Black XG1Y54184 4.34 2.82 Top Coat

Primer solvent- base 368-25Y23-0261 3.26 2.49 Primer

Primer, Universal 60000 UY9R60000 4.33 | 0.48 Primer

Paint Poly 10 Degree Pol White PW1D33303 3.39 0.86 Top Coat

Kel Waterbase Plus Backer E2Z-18236EDCH 1.2 0.46 Backer

Stone, Trinar Paint KA1Y49313 4.1 2.64 Top Coat

Paint PVC Charcoal 373-30E27-1163 i—i o

-vi o

Top Coat


Shingle Painting Sheet

Maximum production rate = 553 Shingles per hour

Paint Spec Weight lb/gal solid weight % VOC lb/gal 10.92 100% 4.58

MEK Thinner Weight ib/gai 6.75

Paint coverage - 0.2 mils dft = 3600 sq. ft. per. gal. Less over s pray - 20% (3600 -20%) = 2880 sq. ft. per. gal. Yield. 0.2 mils paint depth MEK coverage: 4 parts ME K to 1 part paint

Coated area per shingle - 2.083 sq. ft for EU010 Coated area per shingle 1.083 sq. ft for EU0I2 (Shingle Basis 12.75" x 11.5" )

Paint usage 553 shingies/hr x 2. 083 sq.ft./shingle = 1152 sq.ft/hr / 762 sq. ft./gal = 1.51 gal/hr MEK usag e - 1.51 gal paint/hr • 4 gal MEK/! gal paint = 6.05 gal MEK/hr

Maximurn paint usage per. Year = 1.5 1 gal/hr x 8760 hr/yr = 13.228 gal/yr Maximum MEK usage per. Year = 6 .05 gal/hr x 8760 hr/yr = 52,969 gal/yr

Actual production (perfect day). Pai nt Use = 2700 shingles/shirt x 3 shifts/ day - 8100 shingles/day \ 2.083 sq. it. = 16.872 sq . it/day / 2880 sq. it/gal x 365 days = 2138 gal paint/yr. Actual production (perfect day), MEK Use = 213 8 gal paint/yr • 4 gal MEK/f gal paint = 8552 ga l MEK/yr

Tons of VOC emissions, Paint Actual 2138 gal x 2 = (4276 x 4 .4 lb/gal) = 18814 Ih/y r = 9.4 tons/yr. I'ons of VOC emissions, ME K - Actual 2138 gal x 2 x 4 gal MEK/ gal paint x 6.75 lb VOC /gal = 115452 lb/vr = 57.7 tons/yr. Tons of VOC emissions. Total - Maximum 9.4 + 57.7 = 67.1 tons/yr

Known: Maximum Production Rate: 553 Shingle s per Hour Paint Coverage Rate (0.2 mil thickness) 3600 sq. ft/ga llon Spray Gun Designed Overspray 25 % Faint Coverage Yield 659,1346 sq. ft/gallon Shingle Coated Area, EU010 2.083 sq. ft/shin gle Shingle Coated Area, EU012 1.018 sq. ft/shingle

EDCO Products Inc Title V Renewal Application Detailed Calculation Spreadsheets

Paint VOC Content HAP Content, Maximum

4.58 lb /gallon 3.91 lb/gallon

Maximum Solids Content Maximum Metallic HAP Content Maximum Paint Density - VOC Maximum Paint Density - PM MEK Use MEK Density

100.00 {% by wt) 100.00 {% by wt) Assume worst case as all solid is Metallic HAP 10.92 lb/gallon 11.65 lb/gallon

4.00 ga! MEK/gal Paint 6.75 lb VOC/gallon

Find: Emission Factors (lb VOC/shingle),( lb HAP/shingle), (lb PM/shingle)

Analysis: VOC, Paint Shingle area (sq. ft/shingle) * paint coverage yield (gal/sq. ft) * Paint VOC Content (lb VOC/gal paint) * coated mil/spec mil

VOC, MEK = Shingle area (sq. ft/shingle) * paint coverage yield (gal/sq. ft)" 4 gal MEK/gal Paint * VOC Content (lb VOC/gal MEK)*coated mil/spec mil

VOC. Total = VOC, Paint + VOC MEK EU010 = 2.65E-02 lb VOC/shingle EU012 1.29E-02 lb VOC/shingle

HAP = Shingle area (sq. ft/shingle) * paint coverage yield (gal/sq. ft) * Paint HAP Density(lb HAP/gal paint) * coated mil/spec mil EU010 2.26E-02 lb HAP/shingle EU012 1.11E-02 lb HAP/shingle

PM = Shingle area (sq. ft/shingle) * paint coverage yield (gal/sq. ft) * Paint Solids Content (IbPM/gal paint) * Overspray (%/100) EU010 = 2.14E-03 lb (PM/PM10/PM2.5)/shingle EU012 1.03E-03 lb (PM/PM10/PM2.5)/shingle

Metallic HAP PM = Shingle area (sq. ft/shingle) * paint coverage yield (gal/sq. ft) * Metallic HAP Content (IbPM/gal paint) * Overspray (%/100) * coated mil/spec mi! EU010 = 5.11E-04 lb Metallic HAP/shingle EU012 2.50E-04 lb Metallic HAP/shingle


Conclusion Emission factor is Emission factor is Emission factor is Emission factor is Safety Factor

EU010 EU012 2.65E-02 1.29E-02 lb VOC/Shingle 2.26E-02 1.11E-02 lb HAP/Shingle 2.14E-03 1.03E-03 l b (PM/PM10/PM2.5)/shingle 5.11E-04 2.50E-04 lb Metallic HAP/shingle

1.2 EU001/EU006/EU002 /EU003 1.04 EU010/EU012 VOC 1.6 EU010/EU012 PM


Attachment 4 CAM Plan

EDCO Products !nc Title V Renewal Application CAM Pian

Note: The emission limit has bee n reduced from 240 tons/yea r to 225 tons/year.

ATTACHMENT A

Compliance Assurance Monitoring Plan Permanent Total Enclosure and Thermal Oxidation for VOC Emissions Control from Coil Coating Lints

I. Background

A, Source Information

Facility:

Emission Unit(s) Description:

Emission Unites) ID: Stack ID; APCD ID:

EDCO Products, Inc. 8700 Excelsior Boulevard Hopkins, MN 55343

Coil Coating Line including primer/backer coater, topcoatcr, finish oven, primer IR oven, and topcoat IK. oven EU 001,002,003,006,007,008 SV 00 i . CE001

B. Applicable Regulation. Emissions Limit, and Monitoring Requirements

Regulation:

Emissions Limit:

Monitoring Requirements:

C. Control Technology:

(I) Title 1 Condition, permit limit to avoid classification as major source under 40 CFR Section 52.21 audi Minn, R. 7007.3001); (2) 40 CFR Section 60.462(a)(3) rati Minn, R, 7011.2570; (3) Title .1 Condition, permit limit to avoid classification as a major source under 40 CFR Section 52,21 and Minn. R, 7007.3000, Minn. R„ 7017.2025 subp.3

(I) Less than or equal to 240 tons/year of VOC emissions using 12-month rolling sum; (2) Less than or equal to 10 percent of VOCs applied on coating line shall be discharged into the atmosphere (90 percent emission reduction); (3) Operate and maintain control equipment to achieve overall control efficiency for VOCs greater than or equal to 90 percent, maintain temperature at combustion chamber at greater than or equal to 1300 degrees F using 3-hour rolling average

(1) Daily/monthly recordkeeping of quantities of coating used and monthly calculation of VOC emissions; {2} monthly volume weighted average emissions of VOCs in kilograms per liter of coating solids applied, and combustion temperature of effluent gases incinerated and records of periods in excess of 3 hours when average combustion temperature remains less than 1300 degrees Fahrenheit: (3) Temperature readings and calculated 3hour rolling average temperatures.

Permanent total enclosure with thermal oxidation.

j\23 SDCOW0r*Fii«»\2Q<>8 Pa<i 70 R^suenc^vgDCO CAM Ptan.doc Page? 1 of 4

EDCO Products inc Title V Renews! Application CAM Plan

II. Monitoring Approach

indicator No. 1

1. Indicator Measurement Approach;

Oxidizer combustion chamber temperature 1. Indicator Measurement Approach; Record the 3 hour block average of the oxidizer combustion chamber.

II. Indicator Range A deviation is defined as any 3 hour Hock average recorded temperature less than the temperature specified by the permit.

Corrective Action A deviation below the minimum permit specified temperature requires correcti ve actions to be takes as soon as possible. Corrective actions shall return the temperature to at least the permitted minimum and/or include completion «f necessary repairs. Corrective actions include but are not limited to (hose outlined in the O&M Plan for the thermal oxidizer. The permittee shall keep a re cord of the type and date of any corrective action taken.

lit. Performance Criteria Thermocouple has accuracy of +/- 2.5 degrees C or +/- 0.7$ percent of temperature measure in degrees Celsius, whichever is greater.

A. Data Representativeness

Thermocouple has accuracy of +/- 2.5 degrees C or +/- 0.7$ percent of temperature measure in degrees Celsius, whichever is greater.

B. Verification of Operational Status

Temperatures recorded manually, on. chart paper, or electronic media

C. QA/QC Practices and Criteria

Thermocouple and monitoring device are calibrated annually by manufacturer.

D. Monitoring Frequency Continuous (sampling twice per second) Data Collection Procedures

Temperature is recorded continuously by the Honeywell Mini trend V5 recorder and saved to disk. B ate can be extracted from archives on demand.

Averaging period 3 tour block average

P;',MjrisU!3 mi\2T<3tZZl&Q'l £0CO*Wo«WteS #Oea Fsft 70 ReissuarîEDCQ CAM Pian.dec Pag« 2 Of 4

EDCO Products Inc Title V Ren ews! Application CAM Plan

: i tVshl. ..- .I A/..

! .A- < i A , v

A: -;1 I i Aisndu A as.K:-?A>!V, AA A Ac:;.•..i.'irVrih.j.iUIi.' V- -j'h f A .A

.; i/i iu'':H'|s!V'S

! i hkiu'Ûir Rj;V:\ f A - - - • : <a « ; Av^nA'A ^ s i . r:. • A • • -•. ;.A ••'••• ??.<• ; PL = 1?::uJ JAA IAUO.U >; :AACivy

ConcCLv-:; ; !.Âi :1 !? •< •. A•/•• .ii i A v-i Uu: \ ) Y I. i;!AlO:* v-AkA.

] A-< v tnyy^; .t p{>; A y a:p u ;-ISK "P

:U. IVllorr: '•

A. DaU; . A K>.J {M oA,',-i • AAi pc P::S:T<:NA ; ?JA appr o- ::d Ap :hc r\ : A.A'p- Aprnc; HA'-? ocMUm ci.c- s ; pi A>r K> O-H.A'.K Apr; :1K 1 pcnorîuruc ICA.

|\ \ Mi. >:•«. f Ao? s.:pAA. AA,;, PAAiAiAA A.;sA>. :

'i . \J.\ \;5 A ( J.. ' 1 ^ • ••;:!• '• . [ A \r--l "Â A = A ipp" i •• •" 1 '' A •

AAATA ::

<A SAAA.M.I.A: > :e.,pAAA

A . I AUi i OAA AA V'TZi:: h-A

OAA cxvf\ :> A

|A:- ,spp;.AA..- As< tJ•;? A

AAAAUA rAAU

t'DCO Product;-, inc Title V Renewal Application CAM Plan

. >NiiiUtn-iHu A p|irii;ii'ii JiislittS'Hiioii

! HaeKrroaaJ

i lie p>aiUnam-,per: he emis:e<an ur,it i> :ae em s ôssanp hex

f!w Mn ssoe a -uJiicc; vi a ^nihche seena: source b;-a: io avoid PSD, aea so oSi'K Sabpan *1 b.

(b) K jnt rUMe ior Sesevtsess of IV- hnnsisjsrc b ale .slsn-

1. lie operaarsu tcsaperaUire <•.' the Iherreal so,-diver voir s-eteeiod heca u'.e ti nipeaUare s:> soJieaave os'use OHeiiab ue idiAaV perUa maoei: NUse):s;?aris; v^ ^»5<i:.;s11<>ri t(:xr: seiis pvianae a; o: silaoe 'be epeesbad pernM Sevc: :s ej.peeied to meei the rtcuireJ icvd of dia'iroePoii eihcieiiey

hsoo.,-(Mi aes I '01 maaee te:,:: v, bs he eoebacieu soiee eêrv 5 yea rs per Use reijea emenl:- uf Pie peornp ihe pel biovaaee serls Will dersiotssanaia eorsipbance 0. ids the pernsi u:snd;!;i!:i/- ii.v. de:Ont,.Pei:: eseeicne; 1

se; RaUoisase Pa bck:oUoo-sO la aioaav Raaees.

i ne r'aces vp srstln:i?' ranee for the da i nns! e>\Kh,'er Wi ll he (eKea'ru at a isamaaaai eompaanee leiopt'n!u,:o:: iepaaiv by tbv PCiaae I'd:.- fHtankU loohae; >y•:»icne iadod e:-,: semper;;: are eoneaiaer that liBisnsma she smnmnim openome iensperaiia'e b> n nni; :in VMX>'st;ny bs irrser The semprraPsH: eof'StoHei :• > -.ei lo usee -;ea she eompbsshac posei iempesavure ,a or above !'ae er-usbbM^d iiteieaiOr ran gy.

;• ? :kf .. A •••••:.ev:!':: ^ t: v«V :.r*

Documents

AIR EMISSION PERMIT NO. 05301047-006 Total Facility Operating Permit - Reissuance · 2015-12-15 · a§i!> AIR EMISSION PERMIT NO. 05301047-006 Total Facility Operating Permit - Reissuance