Air Emission Permit No. 17100009-006 Is Issued to Dura

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

AIR EMISSION PERMIT NO. 17100009- 006

IS ISSUED TO

Dura Supreme Inc.

DURA SUPREME INC. 300 Dura Drive

Howard Lake, Wright County, MN 55349 The emission units, control equipment and emission stacks at the stationary source authorized in this permit are as described in the following permit application(s): Permit Type Minor Amendment Major Amendment

Application Date August 02, 2006 June 07, 2006

Major Amendment Total Facility Operating Permit - Reissuance

November 22, 2005 October 25, 2002

This permit authorizes the Permittee to operate and construct 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.

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

Issue Date: December 15, 2006

Authorization to Construct and Operate (40 CFR § 52.21) Issuance Date: November 21, 2006

Final Permit Issuance Date: December 15, 2006

Expiration: May 15, 2011 All Title I Conditions do not expire. Richard J. Sandberg, Manager Air Quality Permits Section Industrial Division for Brad Moore Acting Commissioner Minnesota Pollution Control Agency

TABLE OF CONTENTS

Notice to the Permittee Permit Shield Facility Description Table A: Limits and Other Requirements Table B: Submittals Appendices: Attached and Referenced in Table A

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: Dura Supreme manufactures pre-finished cabinetry. Emissions from the facility consist of PM, PM10, VOCs, SOx, NOx, HAPs and CO.

TABLE A: LIMITS AND OTHER REQUIREMENTS 12/15/06

Dura Supreme Inc

17100009 - 006

Facility Name:

Permit Number:

A-1

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

Subject Item: Total Facility

What to do Why to do itOPERATIONAL REQUIREMENTS hdr

The Permittee shall comply and, upon written request, demonstrate compliancewith National Primary and Secondary Ambient Air Quality Standards, 40 CFR pt.50, and the Minnesota Ambient Air Quality Standards, Minn. R. 7009.0010 to7009.0080.

40 CFR pt. 50; Minn. Stat. Section 116.07, subds. 4a &9; Minn. R. 7007.0100, supbs. 7A, 7L & 7M; Minn. R.7007.0800, subps. 1, 2 & 4; Minn. R.7009.0100-7009.0080.

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

Minn. R. 7011.0020

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

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

Operation and Maintenance Plan: Retain at the stationary source an operation andmaintenance plan for all air pollution control equipment. At a minimum, the O & Mplan shall identify all air pollution control equipment and control practices and shallinclude a preventative maintenance program for the equipment and practices, adescription of (the minimum but not necessarily the only) corrective actions to betaken to restore the equipment and practices to proper operation to meet applicablepermit conditions, a description of the employee training program for properoperation and maintenance of the control equipment and practices, and the recordskept to demonstrate plan implementation.

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

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

Minn. R. 7019.1000, subp. 4

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

Minn. R. 7011.0150

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 orcitizens under the Clean Air Act.

Minn. R. 7030.0010 - 7030.0080

Inspections: The Permittee shall comply with the inspection procedures andrequirements 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

The Permittee shall keep records of fuel purchases for the facility on a monthlybasis.

Minn. R. 7007.0800, subp. 5

The construction authorization expires 18 months after permit issuance. ThePermittee must keep a record of the dates of installation and start-up on site. ThePermittee may apply for an extension of the construction authorization deadline byfollowing the Administrative Amendment provisions in Minn. R. 7007.1400.

Minn. R. 7007.0800, subp. 2

PERFORMANCE TESTING hdr

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

Minn. R. ch. 7017


Dura Supreme Inc

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Facility Name:

Permit Number:

A-2

Performance Test Notifications and Submittals:

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

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

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

Minn. Rs. 7017.2030, subp. 1-4, 7017.2018 and Minn.R. 7017.2035, subp. 1-2

Limits set as a result of a performance test (conducted before or after permitissuance) apply until superseded as specified by Minn. R. 7017.2025 followingformal review of a subsequent performance test on the same unit.

Minn. R. 7017.2025

MONITORING REQUIREMENTS hdr

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

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

Operation of Monitoring Equipment: Unless otherwise noted in Tables A, B, and/orC, monitoring a process or control equipment connected to that process is notnecessary during periods when the process is shutdown, or during checks of themonitoring systems, such as calibration checks and zero and span adjustments. Ifmonitoring records are required, they should reflect any such periods of processshutdown or checks of the monitoring system.

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

MODELING INFORMATION hdr

RECORDKEEPING hdr

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

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

Recordkeeping: Maintain records describing any insignificant modifications (asrequired 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 emissionsresulting from those changes.

Minn. R. 7007. 0800, subp. 5(B)

REPORTING/SUBMITTALS hdr

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

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

Minn. R. 7019.1000, subp. 3

Breakdown Notifications: Notify the Commissioner within 24 hours of a breakdownof more than one hour duration of any control equipment or process equipment ifthe breakdown causes any increase in the emissions of any regulated air pollutant.The 24-hour time period starts when the breakdown was discovered or reasonablyshould have been discovered by the owner or operator. However, notification is notrequired 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 operatorshall inform the Commissioner of the cause of the breakdown and the estimatedduration. The owner or operator shall notify the Commissioner when thebreakdown is over.

Minn. R. 7019.1000, subp. 2

Notification of Deviations Endangering Human Health or the Environment: As soonas possible after discovery, notify the Commissioner or the state duty officer, eitherorally or by facsimile, of any deviation from permit conditions which could endangerhuman health or the environment.

Minn. R. 7019.1000, subp. 1


Dura Supreme Inc

17100009 - 006

Facility Name:

Permit Number:

A-3

Notification of Deviations Endangering Human Health or the Environment Report:Within 2 working days of discovery, notify the Commissioner in writing of anydeviation from permit conditions which could endanger human health or theenvironment. 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 yetcorrected; and5. steps taken or planned to reduce, eliminate, and prevent reoccurrence of thedeviation.

Minn. R. 7019.1000, subp. 1

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

Minn. R. 7007.1150 through Minn. R. 7007.1500

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

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

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


Dura Supreme Inc

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Facility Name:

Permit Number:

A-4

Subject Item: GP 001 Painting/Coating Operations (NESHAP Requirements)

Associated Items: EU 001 Paint Spray Booth #1

EU 002 Automatic Spraying Machine with overspray recovery system

EU 003 Paint Spray Booth #3














EU 034 High Speed Glaze Line Toner Booth

EU 035 High Speed Glaze Line Stain Booth

EU 037 High Speed Glaze Line Sealer Booth

EU 039 High Speed Glaze Line Glaze Booth

EU 040 High Speed Glaze Line Top Coat Booth

SV 001 Solid Color Booth

SV 002 Venjakob Auto Spray

SV 003 East Case Stain Booth

SV 004 West Case Stain Booth

SV 005 Case Sealer Booth

SV 006 Specials Booth

SV 007 East Door Stain Booth

SV 008 West Door Stain Booth

SV 009 Door Sealer Booth

SV 010 Case Top Coat Booth

SV 011 Mist Booth

SV 012 White Booth

SV 013 Lab Booth

SV 014 Booth A

SV 015 Booth B

SV 016 Booth C

SV 029 High Speed Glaze Line Toner Booth

SV 030 High Speed Glaze Line Stain Booth


Dura Supreme Inc

17100009 - 006

Facility Name:

Permit Number:

A-5

Associated Items: SV 032 High Speed Glaze Line Sealer Booth

SV 034 High Speed Glaze Line Glaze Booth

SV 035 High Speed Glaze Line Top Coat Booth

What to do Why to do itThe requirements of this group apply to each item listed under the group. Minn. R. 7007.0800, subp. 2

EMISSION AND OPERATIONAL LIMITS hdr

Volatile hazardous air pollutant (VHAP) mean any volatile hazardous air pollutantlisted in Table 2 of 40 CFR pt. 63, subp. JJ.

40 CFR Section 63.801 ant Table 2 of 40 CFR pt. 63,subp. JJ

Emission Limit for Finishing Materials (compliance based on averaging): theaverage volatile hazardous air pollutant (VHAP) content (E) of all finishingmaterials, which include but are not limited to, stains, basecoats, washcoats,enamels, sealers, and topcoats used, shall not exceed 1.0 kg VHAP/kg solids (1.0lb VHAP/lb solids), as applied "E" shall be calculated using the equation given inthis permit.

40 CFR Section 63.802(a)(1) and Table 3 of 40 CFRpt. 63, subp. JJ

Emission Limit (strippable spray booth coatings): the VOC content, as applied, shallnot exceed than 0.8 kg VOC/kg solids (0.8 lb VHAP/lb solids).

40 CFR Section 63.802(a)(3)

Work practice implementation plan: The Permittee shall maintain and adhere to thework practice implementation plan (WPIP) which defines environmentally desirablework practices for each wood furniture manufacturing operation and addresseseach of the work practice standards presented in paragraphs (b) through (l) ofSection 63.803. These standards are included in the Appendix material of thispermit. The plan shall be available upon request by the Administrator and shall berevised upon request by the Administrator.

40 CFR Section 63.803(a)

Total Particulate Matter: less than or equal to 0.3 grains/dry standard cubic foot ofexhaust gas unless required to further reduce emissions to comply with the lessstringent limit of either Minn. R. 7011.0730 or Minn. R. 7011. 0735. This limitapplies separately to each piece of industrial process equipment.

Minn. R. 7011.0715, subp. 1A

Opacity: less than or equal to 20 percent opacity This limit applies separately toeach piece of industrial process equipment.

Minn. R. 7011.0715, subp. 1B

MONITORING AND RECORDKEEPING hdr

The VHAP content for each finishing material, thinner, and strippable spray boothcoating shall be determined as specified in 40 CFR Section 63.805(a). Thisinformation shall be found on the certified product data sheet (CPDS).

40 CFR Section 63.805(a)

Compliance Procedure for Finishing Materials: The Permittee shall calculate theaverage VHAP content (E) using the following equation:E=(Mc1Cc1+Mc2Cc2+...+McnCcn+S1W1+S2W2+...+SnWn / (Mc1+Mc2+...+Mcn)Where: n+1,2,3...(the first finishing material(c), the second finishing material(c), etc);Mc=the mass of solids in a finishing material(c), in kg (lb);Cc=the VHAP content of a finishing material(c), in kg of VHAP per kg of coatingsolids (lb VHAP/lb solids), as supplied;S=the VHAP content of a solvent, in weight fraction, added to finishing materials;andW=amount of solvent, in kg (lb), added to finishing materials during the monthlyaveraging period.

40 CFR Section 63.804(a)(1)

Recordkeeping: The Permittee shall maintain the following records onsite:1) A certified product data sheet for each finishing material, thinner, and strippablespray booth coating;2) Copies of the averaging calculation for each month following the initial startup,as well as the data on the quantity of coatings and thinners used that is necessaryto support the above E calculation;3) The VHAP content, in kg VHAP/kg solids, as applied, of each finishing material;4) The VOC content, in kg VOC/kg solids, as applied, of each strippable boothcoating; and5) The WPIP and all records associated with fulfilling the requirements of the WPIP.

40 CFR Section 63.806(b), (c) and(e)

The minimum WPIP onsite record content shall include:1) Records demonstrating that the operator training program is in place;2) Records collected in accordance with the inspection and maintenance plan;3) Records associated with the cleaning solvent accounting system;4) Records associated with the limitation on the use of conventional air spray gunsshowing total finishing material usage and the percentage of finishing materialsapplied with this type of spray guns for each semiannual period;5) Records associated with the formulation assessment plan required by 63.803(e)and;6) Copies of documentation such as logs developed to demonstrate that the otherprovisions of the WPIP are followed.

40 CFR Section 63.806(e)


Dura Supreme Inc

17100009 - 006

Facility Name:

Permit Number:

A-6

The Permittee shall maintain records of all reports submitted to the agencyincluding the supporting materials.

40 CFR Section 63.806(h) and (i)

The Permittee shall maintain all records for a period of 5 years and, at a minimum,the most recent 2 years of data shall be retained on site. The records including allrequired reports shall be in a form suitable and readily available for expeditiousinspection and review.

40 CFR Section 63.806(j) and 40CFR Section 63.10(b)(1)

CONTROL EQUIPMENT - see also GP002 hdr

The Permittee shall vent emissions from all units listed under GP001 to controlequipment meeting the requirements of GP002 as specified in this permit.

Title I Condition: Limit taken toavoid classification as a majorsource and modification under 40CFR Section 52.21 and Minn. R. 7007.3000; Minn. R.7007.0800, subp. 4 and 5


Dura Supreme Inc

17100009 - 006

Facility Name:

Permit Number:

A-7

Subject Item: GP 002 Control Equipment: Panel Filters

Associated Items: CE 001 Andre - Cardboard Binks Filter (Accordian)

CE 002 Mat or Panel Filter

CE 003 Andre - Cardboard Binks Filter (Accordian)




















The Permittee shall operate and maintain the control equipment such that itachieves an overall control efficiency, for Total Particulate Matter: greater than orequal to 74 percent

Title I Condition: Limit taken to avoid classification asa major source and modification under 40 CFR Section52.21; Minn. R. 7007.0800, subp. 2 and 14

The Permittee shall operate and maintain the control equipment such that itachieves an overall control efficiency, for Particulate Matter < 10 micron: greaterthan or equal to 74 percent control efficiency


The Permittee shall operate and maintain the control equipment any time that anyprocess equipment controlled by the control equipment is(are) in operation. ThePermittee shall document periods of non-operation of the control equipment.



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


Periodic Inspections: At least once per calendar quarter, or more frequently asrequired by the manufacturing specifications, the Permittee shall inspect the controlequipment components. The Permittee shall maintain a written record of theseinspections.

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

Operation and Maintenance of Filters: The Permittee shall operate and maintaineach filter in accordance with the Operation and Maintenance (O & M) Plan. ThePermittee shall keep copies of the O & M Plan available onsite for use by staff andMPCA staff.

Minn. R. 7007.0800, subp. 14


Dura Supreme Inc

17100009 - 006

Facility Name:

Permit Number:

A-8

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

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

Initial Hood Certification and Evaluation: The control device hood must conform tothe requirements listed in Minn. R. 7011.0070, subp. 1, and the Permittee hascertified this as specified in Minn. R. 7011.0070, subp. 3. The Permittee shallmaintain a copy of the evaluation and certification on site.

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

Annual Hood Evaluation: The Permittee shall measure and record at least onceevery 12 months the fan rotation speed, fan power draw, or face velocity of eachhood, or other comparable air flow indication method. The Permittee shall maintaina copy of the annual evaluation on site.

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


Dura Supreme Inc

17100009 - 006

Facility Name:

Permit Number:

A-9

Subject Item: GP 003 Direct Heating Units (ovens)

Associated Items: EU 020 Oven 2 burner 6670 Sunkiss

EU 021 Oven 2 burner 6668 Sunkiss

EU 022 Oven 3 burner (2) 6657 Sunkiss

EU 036 High Speed Glaze Line Stain/Glaze Oven

EU 038 High Speed Glaze Line Sealer/Topcoat Oven

EU 067 Low Speed Specials Line Stain Oven

EU 068 Low Speed Specials Line Sealer Oven

EU 069 Low Speed Specials Line Glaze Oven

EU 070 Low Speed Specials Line Topcoat Oven

SV 021 Oven

SV 023 Oven

SV 031 High Speed Glaze Line Stain/Glaze Oven (EU 036)

SV 033 High Speed Glaze Line Sealer/Topcoat Oven (CE 038)

SV 037 Low Speed Specials Line Stain Oven (EU 067)

SV 038 Low Speed Specials Line Sealer Oven (EU 068)

SV 039 Low Speed Specials Line Glaze Oven (EU 069)

SV 040 Low Speed Specials Line Topcoat Oven (EU 070)



Total Particulate Matter: less than or equal to 0.3 grains/dry standard cubic foot ofexhaust gas unless required to further reduce emissions to comply with the lessstringent 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 periodper hour or not more than 60 percent opacity.

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

Fuel usage: Natural gas. Propane to be used as a back-up only. Minn. R. 7007.0800, subp. 2

Monthly Recordkeeping: By the 15th day of each month, the Permittee shallcalculate, record, and maintain the total fuel use and the type of fuel burned. Thisshall be based on throughput logs, meters, and/or delivery records.

Minn. R. 7007.0800, subps. 4 and 5


Dura Supreme Inc

17100009 - 006

Facility Name:

Permit Number:

A-10

Subject Item: GP 004 Indirect Heating Units (Make Up Air)

Associated Items: EU 026 Makeup Air System

EU 027 Makeup Air System



EU 033 Miscellaneous Heating Sources (see Appendix Material)



Total Particulate Matter: less than or equal to 0.4 lbs/million Btu heat input Thisapplies separately to each piece of indirect heating equipment (the potential to emitcalculations are based on 0.007 lbs/MMBtu heat input)

Minn. R. 7011.0515, subp. 1

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

Minn. R. 7011.0515, subp. 2

Fuel Type: Natural Gas. Propane to be used as a back-up only. Minn. R. 7007.0800, subp. 2

Monthly Recordkeeping: By the 15th day of each month, the Permittee shallcalculate, record, and maintain the total fuel use and the type of fuel burned. Thisshall be based on throughput logs, meters, and/or delivery records.

Minn. R. 7007.0800, subps. 4 and 5


Dura Supreme Inc

17100009 - 006

Facility Name:

Permit Number:

A-11

Subject Item: GP 005 Painting/Coating Operations (VOC Requirements)

Associated Items: EU 001 Paint Spray Booth #1

EU 002 Automatic Spraying Machine with overspray recovery system















EU 034 High Speed Glaze Line Toner Booth

EU 035 High Speed Glaze Line Stain Booth

EU 037 High Speed Glaze Line Sealer Booth

EU 039 High Speed Glaze Line Glaze Booth

EU 040 High Speed Glaze Line Top Coat Booth

SV 001 Solid Color Booth

SV 002 Venjakob Auto Spray

SV 003 East Case Stain Booth

SV 004 West Case Stain Booth

SV 005 Case Sealer Booth

SV 006 Specials Booth

SV 007 East Door Stain Booth

SV 008 West Door Stain Booth

SV 009 Door Sealer Booth

SV 010 Case Top Coat Booth

SV 011 Mist Booth

SV 012 White Booth

SV 013 Lab Booth

SV 014 Booth A

SV 015 Booth B

SV 016 Booth C

SV 029 High Speed Glaze Line Toner Booth

SV 030 High Speed Glaze Line Stain Booth


Dura Supreme Inc

17100009 - 006

Facility Name:

Permit Number:

A-12

Associated Items: SV 032 High Speed Glaze Line Sealer Booth

SV 034 High Speed Glaze Line Glaze Booth

SV 035 High Speed Glaze Line Top Coat Booth

What to do Why to do itEMISSION AND OPERATIONAL LIMITS hdr

Volatile Organic Compounds: less than or equal to 205 tons/year using 12-monthRolling Sum to be calculated by the 15th day of each month for the previous12-month period as described later in this permit.

All materials used at emission units in GP 005 as allowed in this permit shall beincluded in this calculation. VOC contents for each VOC-containing material shallbe determined as described under the Material Content requirement in GP 005.

Title I Condition: Limit to avoid classification as majorsource and modification under 40 CFR Section 52.21;Minn. R. 7007.3000

Total Particulate Matter: less than or equal to 0.3 grains/dry standard cubic foot ofexhaust gas unless required to further reduce emissions to comply with the lessstringent limit of either Minn. R. 7011.0730 or Minn. R. 7011.0735.

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

Opacity: less than or equal to 20 percent opacity. Minn. R. 7011.0715, subp. 1(B)

Pre-Authorized Changes: The permittee may replace listed emission units withemission units similar to those listed in GP 005, provided that:

1. VOC emissions are tracked and calculated as specified in this permit.2. The total maximum capacity of each unit is not greater than that specifiedin Attachment 2 of the TSD.3. The spray gun technology is equivalent to or better than the current transferefficiency.4. The emission rate is equivalent to or better than the current emission rate.5. The permit contains all applicable requirements for the change.

If a proposed change triggers an applicable requirement that is not contained in thispermit, the change must go through the appropiate procedure in Minn. R. ch. 7007.

Title I Condition: Limit to avoid classification as majorsource and modification under 40 CFR Section 52.21;Minn. R. 7007.3000


Daily Recordkeeping. Each day of operation, the Permittee shall calculate,record, and maintain the total quantity of all coatings and other VOC, solids, andHAP containing materials used at the facility. This shall be based on written usagelogs, flowmeters, and/or delivery records.

Title I Condition: Monitoring forLimit to avoid classification asmajor source and modificationunder 40 CFR 52.21 and 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 monthusing the daily usage records. This record shall also include the VOC and solidscontents of each material as determined by the Material Content requirement of thispermit.2) The VOC emissions for the previous month using the formulas specified in thispermit.3) The 12-month rolling sum VOC emissions for the previous 12-month period bysumming the monthly VOC emissions data for the previous 12 months.

Minn. R. 7007.0800, subp. 4 and 5

Monthly Calculation -- VOC Emissions.The Permittee shall calculate VOC emissions using the following equations:VOC (tons/month) = V - WV = (A1 x B1) + (A2 x B2) + (A3 x B3) + .....W = (C1 x D1) + (C2 x D2) + C3 x D3) + .....where:V = total VOC used in tons/month;A# = amount of each VOC-containing material used, in tons/month;B# = weight percent VOC in A#, as a fraction;W = the amount of VOC shipped in waste, in tons/month;C# = amount, in tons/month, of each VOC-containing waste material shipped. Ifthe Permittee chooses to not take credit for waste shipments, this parameter wouldbe zero; andD# = weight percent of VOC in C#, as a fraction.

Minn. R. 7007.0800, subp. 4 and 5


Dura Supreme Inc

17100009 - 006

Facility Name:

Permit Number:

A-13

Material Content: VOC and Solids contents in all materials shall bedetermined by the Material Safety Data Sheet (MSDS) or Certificate of Analysis(COA) provided by the supplier for each material used. If a material content rangeis given on the MSDS, the highest number in the range shall be used in allcompliance calculations. Other alternative methods approved by the MPCA maybe used to determine the VOC and solids contents. The Commissionerreserves the right to require the Permittee to determine the VOC and solidscontents of any material, according to EPA or ASTM reference methods. If an EPAor ASTM reference method is used for material content determination, the dataobtained shall supersede the MSDS or COA.

Minn. R. 7007.0800, subp. 4 and 5

Waste Credit: If the Permittee elects to obtain credit for solids, and/or VOCshipped in waste materials, the Permittee shall either use item 1 or 2 to determinethe VOC and/or solids content for each credited shipment:

1) The Permittee shall analyze a composite sample of waste to determine theweight content of VOC or total solids excluding water. An alternative testingfrequency of waste shipments (e.g., not each shipment) may be approved by theMPCA if the Permittee presents historical data that shows the waste content of anygiven waste stream is within 5% of the original value (e.g., original value 20%,second value 21%). This would need to be provided on an individual waste streambasis. At a minimum, an annual composite sample will be required for each wastestream.

(CONTINUED)

Minn. R. 7007.0800, subp. 4 and 5(CONTINUED)

(CONTINUED)

2) The Permittee may use supplier data for raw materials to determine the VOCand solids contents of each waste shipment, using the same content data used todetermine the content of raw materials. If the waste contains several materials, thecontent of mixed waste shall be assumed to be the lowest VOC and solids contentof any of the materials.

(CONTINUED)Minn. R. 7007.0800, subp. 4 and 5





Dura Supreme Inc

17100009 - 006

Facility Name:

Permit Number:

A-14

Subject Item: GP 006 Control Equipment: Fabric Filters

Associated Items: CE 017 Fabric Filter - Low Temperature, i.e., T<180 Degrees F

CE 018 Fabric Filter - Low Temperature, i.e., T<180 Degrees F



What to do Why to do itThe following requirements of this group apply to each item listed under the group. Minn. R. 7007.0800, subp. 2

EMISSION LIMITS hdr

Total Particulate Matter: less than or equal to 0.020 grains/dry standard cubic foot Title I Condition: Limit taken to avoid classification asa major source and modification under 40 CFR Section52.21 and Minn. R. 7007.3000; Minn. R. 7007.0800,subp. 2 and 14

Particulate Matter < 10 micron: less than or equal to 0.020 grains/dry standardcubic foot

Title I Condition: Limit taken to avoid classification asa major source and modification under 40 CFR Section52.21 and Minn. R. 7007.3000; Minn. R. 7007.0800,subp. 2 and 14

OPERATIONAL LIMITS hdr

The Permittee shall operate and maintain the control equipment such that itachieves an overall control efficiency for Total Particulate Matter: greater than orequal to 79 percent control efficiency


The Permittee shall operate and maintain the control equipment such that itachieves an overall control efficiency for Particulate Matter < 10 micron: greaterthan or equal to 79 percent control efficiency


Pressure Drop: greater than or equal to 1 inches of water column and less than orequal to 5 inches of water column , unless a new range is required to be setpursuant to Minn. R. 7017.2025, subp. 3. If a new range is required to be set, it willbe based on the values recorded during the most recent MPCA approvedperformance test where compliance was demonstrated. The Permittee shallrecord the pressure drop once every 24 hours when in operation.

Title I Condition: Limit taken to avoid classification asa major source and modification under 40 CFR Section52.21 and Minn. R. 7007.3000; Minn. R. 7007.0800,subp. 2 and 14; also meets 40 CFR Section 64requirements (CAM)

Visible Emissions: The Permittee shall check the fabric filter stack for any visibleemissions once each day of operation during daylight hours. During inclementweather, the Permittee shall read and record the pressure drop across the fabricfilter, once each day of operation.

Title I Condition: Limit taken to avoid classification asa major source and modification under 40 CFR Section52.21 and Minn. R. 7007.3000; Minn. R. 7007.0800,subp. 4 and 5; also meets 40 CFR Section 64requirements (CAM)

Venting: Once each day, the permittee shall record the number of hours per daythat emissions were vented outside.

Title I Condition: Limit taken to avoid classification asa major source and modification under 40 CFR Section52.21 and Minn. R. 7007.3000


Recordkeeping of Visible Emissions and Pressure Drop. The Permittee shallrecord the time and date of each visible emission inspection and pressure dropreading, and whether or not any visible emissions were observed, and whether ornot the observed pressure drop was within the range specified in this permit.

Title I Condition: Monitoring for Limit taken to avoidclassification as a major source and modification under40 CFR Section 52.21 and Minn. R. 7007.3000; Minn.R. 7007.0800, subp. 4 and 5

The Permittee shall operate and maintain the fabric filter at all times that anyemission unit controlled by the fabric filter is in operation. The Permittee shalldocument periods of non-operation of the control equipment.

Title I Condition: Monitoring for Limit taken to avoidclassification as a major source and modification under40 CFR Section 52.21 and Minn. R. 7007.3000; Minn.R. 7007.0800, subp. 2 and 14; also meets 40 CFRSection 64 requirements (CAM)

Monitoring Equipment: The Permittee shall install and maintain the necessarymonitoring equipment for measuring and recording pressure drop as required bythis permit. The monitoring equipment must be installed, in use, and properlymaintained when the monitored fabric filter is in operation.

Minn. R. 7007.0800, subp. 4; also meets 40 CFRSection 64 requirements (CAM)

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

Minn. R. 7007.0800, subp. 14; also meets 40 CFRSection 64 requirements (CAM)

Periodic Inspections: At least once per calendar quarter, or more frequently asrequired by the manufacturing specifications, the Permittee shall inspect the controlequipment components. The Permittee shall maintain a written record of theseinspections.

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


Dura Supreme Inc

17100009 - 006

Facility Name:

Permit Number:

A-15

Corrective Actions: The Permittee shall take corrective action as soon as possible ifany of the following occur:- visible emissions are observed;- the recorded pressure drop is outside the required operating range; or- the fabric filter or any of its components are found during the inspections to needrepair.Corrective actions shall return the pressure drop to within the permitted range,eliminate visible emissions, and/or include completion of necessary repairsidentified during the inspection, as applicable. Corrective actions include, but arenot limited to, those outlined in the O & M Plan for the fabric filter. The Permitteeshall keep a record of the type and date of any corrective action taken for each filter.

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


Dura Supreme Inc

17100009 - 006

Facility Name:

Permit Number:

A-16

Subject Item: GP 007 Wood Working Operations (Subject to CAM)

Associated Items: EU 041 25 Table Saws

EU 042 4 Radial Arm Saws

EU 043 18 Power Miter Saws

EU 044 5 Under Cut Off Saws

EU 045 5 Panel Saws

EU 046 2 Notching Saws

EU 047 4 Band Saws

EU 048 21 Sanders

EU 049 8 Drill Presses

EU 050 8 Hinge Drills/Hingers

EU 051 3 Planers

EU 052 3 Edge Banders

EU 053 7 Boring Machines

EU 054 3 Dado Machines

EU 055 2 Castle Machines

EU 056 9 Routers

EU 057 24 Shapers

EU 058 5 Tenoners

EU 059 2 Jointers

EU 060 3 Mortisers

EU 061 Singel End Dovetailer

EU 062 4 Coping Machines

EU 063 3 Optimizers

EU 064 2 Micro Joint

EU 065 2 Wood Grinders/Hogs

EU 066 2 Moulders

SV 026 Wood Working Operations 1 (CE 017)




What to do Why to do itEMISSION AND OPERATIONAL LIMITS hdr


Dura Supreme Inc

17100009 - 006

Facility Name:

Permit Number:

A-17

The Permittee is pre-authorized to make the following changes to GP 007equipment at any time during the life of the permit:

1). Replace or move existing wood working equipment or add additional woodworking equipment, provided:

a). All equipment must meet the requirements of GP 007

b). Any replaced wood working equipment must have an equivalent or bettercapture efficiency than the capture efficiency of the unit it replaces.

c). Added wood working equipment must have the greatest capture efficiencyavailable for that equipment.

d). All equipment must be controlled by control equipment meeting therequirements of GP 006 at all times that they are in operation.

If a proposed change triggers an applicable requirement that is not contained in thispermit, the change must be permitted using the appropriate procedure in Minn. R.ch. 7007.

Title I Condition: Limit to avoidclassification as a major sourceand modification under 40 CFR52.21 and Minn. R. 7007.3000

Recordkeeping of Equipment Changes: The Permittee shall keep and maintain alist of equipment vented to each baghouse and the required airflows for each pieceof equipment. The record shall show that the total airflow requirements for eachbaghouse system are less than the limits given in Table A of this permit, listed atCE 017, CE 018, and CE 025.

This list shall be updated each time a piece of equipment is added, moved, orreplaced. The record shall include the date the change was made, a briefdescription of the equipment, the required airflow for each piece of equipment, theCE (control equipment) number of the baghouse where the unit will be vented, andthe total airflow for all equipment vented to each baghouse.

Title I Condition: Limit to avoidclassification as a major sourceand modification under 40 CFR52.21 and Minn. R. 7007.3000

Total Particulate Matter: less than or equal to 0.3 grains/dry standard cubic foot ofexhaust gas unless required to further reduce emissions to comply with the lessstringent limit of either Minn. R. 7011.0730 or Minn. R. 7011.0735.

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

Opacity: less than or equal to 20 percent opacity. Minn. R. 7011.0715, subp. 1(B)





Dura Supreme Inc

17100009 - 006

Facility Name:

Permit Number:

A-18

Subject Item: GP 008 Performance Test Requirements

Associated Items: CE 017 Fabric Filter - Low Temperature, i.e., T<180 Degrees F








What to do Why to do itThe permittee is to test the control device from this group that is controlling thegreatest amount of particulate emissions from the facility. See Group 006 forControl Equipment Requirements.

Minn. R. 7007.0800, subp. 2

PEFORMANCE TESTING hdr

Performance Test: due 270 days after 05/15/2006 to verify compliance with the PMemission limits and to establish an air flow operational limit to be used for perodicmonitoring purposes.

Minn. R. 7017.2020, subp. 1

Performance Test: due 270 days after 05/15/2006 to verify compliance with thePM10 emission limits and to establish an air flow operational limit to be used forperodic monitoring purposes.

Minn. R. 7017.2020, subp. 1


Dura Supreme Inc

17100009 - 006

Facility Name:

Permit Number:

A-19

Subject Item: CE 017 Fabric Filter - Low Temperature, i.e., T<180 Degrees F





EU 045 5 Panel Saws


EU 047 4 Band Saws

EU 048 21 Sanders



EU 051 3 Planers





EU 056 9 Routers

EU 057 24 Shapers

EU 058 5 Tenoners

EU 059 2 Jointers

EU 060 3 Mortisers



EU 063 3 Optimizers



EU 066 2 Moulders

GP 006 Control Equipment: Fabric Filters

GP 008 Performance Test Requirements

What to do Why to do itAir Flow Rate: less than or equal to 36,000 actual cubic feet/minute for CE 017.The permittee shall keep the fabric filter design specifications showing thecalculated maximum airflow on-site.

Title I Condition: Limit taken to avoid classification asa major source and modification under 40 CFR Section52.21 and Minn. R. 7007.3000; also meets 40 CFRSection 64 requirements (CAM)


See GP 008 for performance testing requirements. Minn. R. 7007.0800, subp. 2


Dura Supreme Inc

17100009 - 006

Facility Name:

Permit Number:

A-20






EU 045 5 Panel Saws


EU 047 4 Band Saws

EU 048 21 Sanders



EU 051 3 Planers





EU 056 9 Routers

EU 057 24 Shapers

EU 058 5 Tenoners

EU 059 2 Jointers

EU 060 3 Mortisers



EU 063 3 Optimizers



EU 066 2 Moulders








Dura Supreme Inc

17100009 - 006

Facility Name:

Permit Number:

A-21






EU 045 5 Panel Saws


EU 047 4 Band Saws

EU 048 21 Sanders



EU 051 3 Planers





EU 056 9 Routers

EU 057 24 Shapers

EU 058 5 Tenoners

EU 059 2 Jointers

EU 060 3 Mortisers



EU 063 3 Optimizers



EU 066 2 Moulders








Dura Supreme Inc

17100009 - 006

Facility Name:

Permit Number:

A-22






EU 045 5 Panel Saws


EU 047 4 Band Saws

EU 048 21 Sanders



EU 051 3 Planers





EU 056 9 Routers

EU 057 24 Shapers

EU 058 5 Tenoners

EU 059 2 Jointers

EU 060 3 Mortisers



EU 063 3 Optimizers



EU 066 2 Moulders







TABLE B: SUBMITTALSFacility Name: Dura Supreme Inc

Permit Number: 17100009 - 006

12/15/06B-1

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

Each submittal must be postmarked or received by the date specified in the applicable Table. Those submittals required by parts7007.0100 to 7007.1850 must be certified by a responsible official, defined in Minn. R. 7007.0100, subp. 21. Other submittals shallbe certified as appropriate if certification is required by an applicable rule or permit condition.

Send any application for a permit or permit amendment to:

AQ Permit Technical Advisor Industrial Division 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 Technical Advisor 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

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

Mr. George Czerniak Air and Radiation Branch EPA Region V 77 West Jackson Boulevard Chicago, Illinois 60604

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

TABLE B: ONE TIME SUBMITTALS OR NOTIFICATIONSFacility Name: Dura Supreme Inc


12/15/06B-2

What to send When to send Portion of Facility AffectedApplication for Permit Reissuance due 180 days before expiration of Existing

PermitTotal Facility

Computer Dispersion Modeling Information due 1,096 days after 05/15/2006. Submitmodeling data as specified in MPCA guidancefor Modeling Information Requests (forPM-10). This modeling information is for datacollection purposes, no modeling analysis isrequired at this time. This is a state onlyrequirement and is not enforceable by theEPA Administrator or citizens under the CleanAir Act.

Total Facility

Submittal due 15 days before Permit Issuance. ThePermittee shall submit the list of equipmentvented to each baghouse and the requiredairflows for each piece of equipment. Thisrecord shall show that the total airflowrequirements for each baghouse system areless than the limits given in Table A of thispermit, listed at CE 017, CE 018, CE 025 andCE 026.

This list is the list that shall be updated eachtime a piece of equipment is added, moved, orreplaced. The record shall include the datethe change was made, a brief description ofthe equipment, the required airflow for eachpiece of equipment, theCE (control equipment) number of thebaghouse where the unit will be vented, andthe total airflow for all equipment vented toeach baghouse.

Total Facility

Testing Frequency Plan due 60 days after Initial Performance Test toverify compliance with the PM emission limitsand to establish an air flow operational limit tobe used for perodic monitoring purposes. Theplan shall specify a testing frequency basedon the test data and MPCA guidance. Futureperformance tests based on one-year (12month), 36 month, and 60 month intervals, oras applicable, shall be required upon writtenapproval of the MPCA.

GP008

Testing Frequency Plan due 60 days after Initial Performance Test toverify compliance with the PM-10 emissionlimits and to establish an air flow operationallimit to be used for perodic monitoringpurposes. The plan shall specify a testingfrequency based on the test data and MPCAguidance. Future performance tests based onone-year (12 month), 36 month, and 60 monthintervals, or as applicable, shall be requiredupon written approval of the MPCA.

GP008

TABLE B: RECURRENT SUBMITTALSFacility Name: Dura Supreme Inc


12/15/06B-3

What to send When to send Portion of Facility AffectedCompliance Status Report due 30 days after end of each calendar

half-year starting 05/15/2006 The Permitteeshall submit a semiannual ContinuousCompliance Report. At a minimum, the reportshall include:

1) results of averaging calculation of VHAPfrom finishing operation for each month withinthat semiannual period using above equation"E";

2) a compliance certification stating the "E"value was always less than 1.0, compliantstrippable spray booth coatings have beenused each day, and WPIP being followed. Thecertification must be signed by a responsibleofficial of the facility. If the Permittee is out ofcompliance with any of the requirements inthe NESHAP, the Permittee shall state themeasures taken to bring them back tocompliance.

GP001

Semiannual Deviations Report due 30 days after end of each calendarhalf-year starting 05/15/2006. The firstsemiannual report submitted by the Permitteeshall cover the calendar half-year in which thepermit is issued. The first report of eachcalendar year covers January 1 - June 30.The second report of each calendar yearcovers July 1 - December 31. If no deviationshave occured, the Permittee shall submit thereport stating no deviations.

Total Facility

Annual Report due 30 days after end of each calendar yearstarting 05/15/2006. The Permittee shallsubmit an annual report by January 30 eachyear that describes the changes made at thefacility during the previous calendar yearusing a format that either uses or replicatesthe latest MPCA application forms (GI-04 andGI-05 series). The report shall document theVOC 12 accounting period rolling sumcalculations for the previous calendar yearand any equipment that was added, changedor removed. It shall also include the definedaccounting periods for the next calendar year.The report shall be submitted with the annualCompliance Certification listed in Table B. Aspart of the Annual Report, the Permittee shallverify and certify that the facility hasmaintained minor source status for NewSource Review.

Total Facility

Compliance Certification due 31 days after end of each calendar yearstarting 05/15/2006 (for the previous calendaryear). To be submitted on a form approved bythe Commissioner, both to the Commissionerand to the US EPA regional office in Chicago.This report covers all deviations experiencedduring the calendar year.

Total Facility

Emissions Inventory Report due 91 days after end of each calendar yearstarting 05/15/2006. To be submitted on aform approved by the Commissioner.

Total Facility

APPENDIX MATERIAL Facility Name: Dura Supreme Inc Permit Number: 17100009-006 Work Practice Implementation Plan At a minimum, a work practice implementation plan (WPIP) shall contain the following:

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

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

2) outline of all training materials;

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

4) documentation of successful completion of training.

B. Inspection and maintenance plan - A written leak inspection and maintenance plan shall be followed. At a minimum this plan shall specify the following:

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

2) an inspection schedule;

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

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

C. Cleaning and washoff solvent accounting system - An accounting system shall be maintained to record the following:

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

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

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

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

E. Spray booth cleaning - VOC content of cleaning spray booth components shall not exceed 8 percent by weight. This limit does not apply to cleaning conveyors, continuous coaters and total enclosures, or metal filters. If the Permittee is replacing the spray booth coating or other protective material used to cover the booth, no more than 1 gallon of organic solvent per booth to prepare the surface of the booth prior to applying the booth coating.

F. Storage requirements - use normally closed containers for storing finishing, gluing, cleaning, and washoff materials.

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

H. Line Cleaning - pump or drain all organic solvent used for line cleaning into a normally closed containers.

I. Gun cleaning - collect all organic solvent used to clean spray guns into a normally closed container.

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

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

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 General Applicable Requirement

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

Dura Supreme has a parts washer and a sawdust handling systems that qualify under this subpart. In addition, various plant-wide small scale activities Latex spraying with hand-held aerosol cans and miscellaneous adhesive use.

Minn. R. 7011.0715 (PM and opacity)

Under Minn. R. 7007.1250, subp. 1(A), the Permittee may add insignificant activities to the stationary source throughout the term of the permit without getting permit amendments. Certain exclusions apply and are listed in Minn. R. 7007.1250, subp. 2. In addition, this permit specifically prohibits the Permittee from making any modifications that would make the source major under NSR. The following table is a listing of the insignificant activities that the Permittee is somewhat likely to add and their associated applicable requirements.

Minn. R. 7007.1300,

subp. Rule Description of the Activity

General Applicable

Requirement(s)

3(A) Fuel use: space heaters fueled by kerosene, natural gas, or propane.

Minn. R. 7011.0610 (PM and opacity)

3(B) Furnaces, boilers, and incinerators:

1. infrared electric ovens; and Minn. R. 7011.0110 (opacity)

3(H) Miscellaneous:

4. brazing, soldering or welding equipment; Minn. R. 7011.0715 (PM and opacity)

5. blueprint copiers and photographic processes; Minn. R. 7011.0110 (opacity)

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

Minn. R. 7011.0610 + Minn. R. 7011.0715 (PM and opacity)

3(J) Fugitive Emissions from roads and parking lots. Minn. R. 7011.0150

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. 7011.0710/0715

EU 033 Miscellaneous Heating Sources Number

Size Each

(Btu/hr) Size Total (Btu/hr)

Roof Top Furnaces E. Office upper floor Lennox GSC20V-413-50-1Y 1998-2002 1 50,000 50,000

E. office lower floor Lennox GSC16-953-200-6Y 1998-2002 1 200,000 200,000

Lunch Room Lennox LGA 210 SS1G 1998-2002 1 260,000 260,000

Center Office Lennox LAG 180 SS1G 1998-2002 1 260,000 260,000

Training Room Lennox LGA 072 SS1G 1998-2002 1 78,000 78,000

Space Heaters

Finish Lab (former Maintenance Area)

G.E. BLHY 120E 960DO 1990 1 120,000 120,000

Center West Office (former West Office Area)

Heil N HE 100 AHO4 1990 2 100,000 200,000

Center Office (former East Office Area)

Rheem RGUH-09EA-AR 1990 2 95,000 190,000

Maintenance (former Lunchroom)

Lennox G50UH-36B-90-01 (replaces GE BLH 080E936D0) 2001 2 88,000 176,000

Lennox LF24-150S-3 (not installed) 2003 1 150,000 150,000

Manufacturing Area

East

Solaronics ST-60-20N (replaces Co-Ray-Vac CRVA-4) 1999-2002 7 75,000 525,000

Center

Co-Ray-Vac CRV5-40 (replaces Co-Ray-Vac CRVA-4) 1999-2002 14 40,000 560,000

West

Co-Ray-Vac CRV-A8 (replaces Co-Ray-Vac CRVA-4) 1999-2002 9 80,000 720,000

Shipping

Roberts-Gordon ETBH-40 (replaces Co-Ray-Vac CRVA-4) 1999-2002 7 80,000 560,000

Addition

Solaronics ST-60-20N 1999 1 60,000 60,000

Warehouse - West

Solaronics ST-105 40/50N 2000 2 105,000 210,000

Lennox F4-24-200S-2 2000 1 200,000 200,000

Warehouse - Center

Lennox LF24-125S-1 2000 2 125,000 250,000

Total Miscellaneous Space Heating Units 4,769,000

Technical Support Document, Permit Action Number: 17100009 - 006 Page 1 of 11 Date: 12/28/2006

TECHNICAL SUPPORT DOCUMENT For

AIR EMISSION PERMIT NO. 17100009-006 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:

Owner/Operator Address

Facility Address (SIC Code: 2434)

Dura Supreme Dura Supreme 300 Dura Drive P.O. Box K

300 Dura Drive P.O. Box K

Howard Lake, MN 55349 Howard Lake, MN 55349 1.2. Description of the Permit Action This expedited permitting action authorizes the addition of four new drying ovens (EU 067- EU 070) and an additional baghouse (CE 026) as a major amendment to an existing Part 70 Operating Permit. This permitting action will be incorporated into the permitting format established by the Part 70 Operating Permit. Additionally, administrative updates are occurring through this permitting action. The permit applications for this permitting action were received by the Minnesota Pollution Control Agency (MPCA) in June and August of 2006. Dura Supreme updated these applications through the completion of this permitting action. 1.3 Description of any Changes Allowed with this Permit Issuance This permit authorizes a major amendment to the facility to add four new drying ovens (EU 067- EU 070) and an additional baghouse (CE 026). The Part 70 Operating Permit pre-authorizes specific activities that may occur over the life of the permit. Section 3.1 discusses the pre-authorized activities.


1.4 Description of Permit Activity Permit Number and Issuance Date

Action Authorized

17100009-005 May 15, 2006

Total Facility Permit. Authorized a major amendment to the facility to add an integrated, high-speed glaze coating line and pre-authorized specific activities that may occur over the life of the permit.

17100009-004 Not Issued

Not Issued

17100009-003 March 15, 2001

Authorizes the external venting of PM and PM10 emissions from woodworking operations and includes changes that were pre-authorized.

17100009-002 September 30, 1998

Decreased cap limit for PM10 to 99 tons per year from 125 tons per year.

1.5. Facility Emissions:

Table 1. Title I Emissions Increase Summary:

Emissions Increases from the modification

(tpy)

Pollutant

Significant Thresholds for minor sources

Review Required?

(Yes or No)

PM 18.82 250 No PM10 18.82 250 No

SO2 0.01 250 No

NOx 0.37 250 No

CO 1.38 250 No VOC 0.09 250 No Lead 0 250 No


Table 2. Total Facility Potential to Emit Summary:

PM tpy

PM10 tpy

SO2 tpy

NOx tpy

CO tpy

VOC tpy

Lead tpy

Single HAP tpy

Total HAPs

tpy Total Facility Limited Potential Emissions

138.70 138.70 0.09 12.37 11.98 205.78 0 100.20 150.89

Total Facility Actual Emissions (2004)

13.13 13.13 0.01 1.05 0.88 156.28 0 2.49* 4.79*

* provided by facility

Table 3. Facility Classification

Classification Major/Affected Source

Synthetic Minor Minor

PSD PM, PM10, VOC NOx, SO2, CO Part 70 Permit Program PM10, VOCs NOx, SO2, CO Part 63 NESHAP X 2. Regulatory and/or Statutory Basis

New Source Review

The Facility has chosen limits to avoid major source classification for New Source Review (40 CFR § 52.21).

Part 70 Permit Program

The Facility is a major source under the federal operating permits program (40 CFR pt. 70).

New Source Performance Standards (NSPS)

There are no New Source Performance Standards applicable to the operations at this facility.

National Emission Standards for Hazardous Air Pollutants (NESHAP) The facility is subject to 40 CFR pt. 63 Subpart JJ--National Emissions Standards for Wood Furniture Manufacturing Operations.


Minnesota State Rules

Portions of the facility are subject to the following Minnesota Standards of Performance: • Minn. R. 7011.0020 Circumvention

• Minn. R. 7011.0150 Standards of Performance for control of fugitive Particulate Matter

• Minn. R. 7011.0515 Standards of Performance for New Indirect Heating Equipment

• Minn. R. 7011.0610 Standards of Performance for Fossil-Fuel-Burning Direct Heating Equipment

• Minn. R. 7011.0715 Standards of Performance for Post-1969 Industrial Process Equipment

Compliance Assurance Monitoring

This permit action is a re-issuance of a Part 70 permit. Therefore CAM applies to any emission units with air pollution control equipment which meet the CAM applicability requirements. CAM applies to emission units identified in GP 007. The requirements identified in GP 006 satisfy CAM.


Table 3. Regulatory Overview of Facility

EU, GP, or SV Applicable Regulations Comments:

Total Facility

a) 40 CFR pt. 50; Minn. Stat. § 116.07, subds. 4a and 9; Minn. R. 7007.0100; Minn. R. 7007.0800 Minn. R. 7009.0010-.0080;

If requested, the Permittee shall demonstrate compliance with air quality standards.

GP 001 Painting/Coating Operations (NEHSAP requirements)

a) 40 CFR pt. 63, subp. JJ b) Title I Condition to avoid classification as a major source under 40 CFR § 52.21 Minn. R. 7007.0800

a) NESHAP emission and operating requirements. b) Pollution control requirements to avoid major source classification under 40 CFR § 52.21.

GP 002 Panel Filters with hoods

a) Title I Condition to avoid classification as a major source under 40 CFR § 52.21 Minn. R. 7007.0800 b) Minn. R. 7007.0800

a) Control efficiency limits and operational requirements taken to avoid major source classification under 40 CFR § 52.21. b) Monitoring and recordkeeping requirements ensure proper operation and compliance.

GP 003 Direct Heating Units

a) Minn. R. 7011.0610 b) Minn. R. 7007.0800

a) Standards of Performance for Fossil-Fuel Burning Direct Heating Equipment. b) Fuel restriction ensures compliance.

GP 004 Indirect Heating Units

a) Minn. R. 7011.0510 b) Minn. R. 7007.0800

a) Standards of performance limits for particulate matter and opacity for existing indirect heating equipment. b) Fuel restriction ensures compliance.

GP 005 Painting/Coating Operations (VOC requirements)

a) Title I Condition to avoid classification as a major source under 40 CFR § 52.21 Minn. R. 7007.0800

a) A rolling 12-month VOC usage limit allows the facility to avoid classification as a major source. The VOC limit also inherently limits PM/PM10 emissions.

Facility may replace listed emissions


units with emission units similar to those listed.

Pollution control requirements to avoid major source classification under 40 CFR § 52.21.

GP 006 Fabric Filters

Title I Condition to avoid classification as a major source under 40 CFR § 52.21 Minn. R. 7007.3000


GP 007 Wood Working Operations

Title I Condition to avoid classification as a major source under 40 CFR § 52.21; Minn. R. 7007.3000 Minn. R. 7007.0800

Facility may replace, move or add emission units.



Minn. R. 7007.0800

The permittee is to test the control device from this group that is controlling the greatest amount of particulate emissions from the facility. Although air flow rates may differ, the emission rate result is assumed to be representative of the rate for the other baghouses.

3. Technical Information 3.1 Pre-authorized Changes

The Permittee is pre-authorized (see GP 007) to replace, move or add certain emissions units as long as they are controlled at all times and the pre-authorization does not trigger new applicable requirements and the conditions of the permit continue to be met (see permit for specific information). If the conditions of the preceding statement are achieved, the pre-authorization will not cause an emissions increase under Minn. R. 7007.1200, subp. 3 (calculating emissions increases for non-Title I changes), therefore, the pre-authorizations are allowed without the need for an amendment.

3.2 Emission Calculations

Supporting emission calculations are attached.


3.3 Periodic 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 considers the following:

• The likelihood of 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 4 summarizes the periodic monitoring requirements for those emission units for which the monitoring required by the applicable requirement is nonexistent or inadequate.

Table 4. Periodic Monitoring Emission Unit or Group

Requirement (basis) Additional Monitoring

Discussion

GP 001 Painting/Coating Operations (NEHSAP

NEHAP Requirements

(40 CFR pt. 63, subp. JJ)

None NESHAP monitoring and recordkeeping requirements ensure compliance

GP 002 Panel Filters with hoods

PM/PM10 – Overall Collection Efficiency of 74 Percent

(Title I condition)

Recordkeeping of Operation, Maintenance and Inspection of Equipment.

Monitoring Based on Minnesota Performance Standard for Control equipment is adequate for reasonable assurance of compliance (daily and periodic inspections, corrective actions, O&M, and hood design)

GP 003 Direct Heating Units

PM/PM10: ≤ 0.3 gr/dscf of exhaust gas

Opacity: ≤ 20% with exceptions,

(Minn. R. 7011.0610)

None All units use natural gas (with propane back up). Therefore, the likelihood of violating either the particulate or the opacity limits is very small.


GP 004 Indirect Heating Units

PM: < 0.4 lb/MMBtu Opacity: < 20 % with exceptions (Minn. R. 7011.0515)

None All units use natural gas (with propane back up). Therefore, the likelihood of violating either the particulate or the opacity limits is unlikely.

GP 005 Painting/Coating Operations (VOC requirements)

VOC: ≤ 205 tons per rolling 12 month period. (limit to avoid NSR, inherently limits PM/PM10)

PM: < 0.3 gr/dscf Opacity: < 20 % (Minn. R. 7011.0715)

Recordkeeping: Daily records of coating usage; On-going MSDS records of coating contents; Monthly emissions calculations. None

Credit is allowed for waste materials collected and shipped off-site (used - waste = emissions) for the VOC and HAP limits. The permit provides 2 options for determining VOC and/or solids content for each credited shipment. Calculating emissions more frequently than monthly may result in large spikes (while waste is accumulating) and dips (when waste is shipped) - resulting in possible paperwork violations and days with negative emissions. For these reasons, 12-month rolling limits are reasonable for this Facility. Venting of emissions to control equipment ensures compliance.

GP 006 Fabric Filters

PM/PM10 < 0.020 gr/dscf

(Title I condition)

Recordkeeping of Operation, Maintenance and Inspection of Equipment, Performance Testing (see GP 008).

Monitoring Based on Minnesota Performance Standard for Control equipment is adequate for reasonable assurance of compliance (daily and periodic inspections, corrective actions, O&M). Also satisfies CAM.

GP 007 Wood Working Operations

PM: < 0.3 gr/dscf Opacity: < 20 % (Minn. R. 7011.0715)

None Venting of emissions to control equipment ensures compliance.


Minn. R. 7007.0800

Performance Testing

The permittee is to test the control device from this group that is controlling the greatest amount of particulate emissions from the facility. Although air flow rates may differ, the emission rate result is assumed to be representative of the rate for the other baghouses.


3.4 Insignificant Activities The Permittee has several operations, which are classified as insignificant activities. These are listed in the Appendix of the permit. These Insignificant Emission Units (IEU) are subject to the state general applicable requirements. It is our belief that IEU’s listed in the Appendix to the permit associated with inconsequential environmental impacts and present little potential for violations of generally applicable requirements, therefore no monitoring will be required.

3.3 Comments Received No comments were received during the comment period. The permit was administratively edited for clarification purposes. Public Notice Period: October 20, 2006 – November 20, 2006. EPA 45-day Review Period: March 24, 2006 – December 05, 2006. 4. Conclusion Based on the information provided, the MPCA has reasonable assurance that the proposed operation of the emission facility, as described in the Air Emission Permit No. 17100009-006, and this TSD, will not cause or contribute to a violation of applicable federal regulations and Minnesota Rules. This permit is being issued under issuance goals. Staff Members on Permit Team: Steven Gorg, M.S., P.E. (permit writer/engineer) Emily Hansen (enforcement) Curtis Stock (stack testing) Dan Sullivan (peer reviewer)

Laurie O’Brien (Support Staff) Beckie Olson (Support Staff)

Attachments: 1. PTE Summary and Emissions Increase Calculation Spreadsheets

2. Facility Description and CD-01 Forms


Attachments 1: PTE Summary and Emissions Increase Calculation Spreadsheets


Attachments 2: Facility Description and CD-01 Forms

Documents

Air Emission Permit No. 17100009-006 Is Issued to Dura