DRAFT Air Individual Permit Part 70 Reissuance

Transcription

1 DRAFT Air Individual Permit Part 70 Reissuance Permittee: Facility name: Polaris Industries Inc - Roseau Polaris Industries Inc - Roseau 301 5th Ave SW Roseau, MN56751 Roseau County Expiration date: < > * All Title I Conditions do not expire Part 70 Reissuance: < > Permit characteristics: Federal; Part 70/ Limits to avoid NSR; Limits to avoid NSR 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 and authorizes the Permittee to operate and modify the stationary source at the address listed above unless otherwise noted in the permit. The Permittee must comply with all the conditions of the permit. Any changes or modifications to the stationary source must be performed in compliance with Minn. R to 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 and as such as are enforceable by EPA Administrator or citizens under the Clean Air Act. Signature: [ ] for This document has been electronically signed. Don Smith, P.E., Manager Air Quality Permits Section Industrial Division for the Minnesota Pollution Control Agency

2 Table of Contents 1. Permit applications table Where to send submittals Facility description Summary of subject items Limits and other requirements Submittal/action requirements Appendices Appendix A. Insignificant Activities and General Applicable Requirements Appendix B. PreCap Compliance Calculations Appendix C. Maximum Material Contents and Application Rates Appendix D. Part 63 Subpart MMMM Compliance Equations Appendix E. Part 63 Subpart PPPP Compliance Equations Appendix F. List of Air Make-up Units (EQUI 086) and Exhaust Units (EQUI 081) Appendix G. Modeling Parameters for NO 2 Dispersion Modeling Analysis for Peak Shaving Generator Appendix H. 40 CFR Part 63 Subpart A General Provisions Applicable to 40 CFR part 63 Subpart PPPPP (COMG 014 & COMG 015) Appndix I. 40 CFR Part 63 Subpart A General Provisions Applicable to 40 CFR Part 63 Subpart ZZZZ (EQUI 043 & EQUI 044) Page

3 Permit issued: [month day, year] Permit expires: [month day, year] Page 3 of Permit applications table Subsequent permit applications: Title description Application receipt date Action number Major Amendment 09/24/ Part 70 Reissuance 11/19/ Notification of Install of Controls 07/02/ Minor Amendment 06/06/

4 Permit issued: [month day, year] Permit expires: [month day, year] Page 4 of Where to send submittals Send submittals that are required to be submitted to the U.S. EPA regional office to: Chief Air Enforcement Air and Radiation Branch EPA Region V 77 West Jackson Boulevard Chicago, Illinois Each submittal must be postmarked or received by the date specified in the applicable Table. Those submittals required by Minn. R to must be certified by a responsible official, defined in Minn. R , 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 Send any application for a permit or permit amendment to: Fiscal Services 6 th Floor Minnesota Pollution Control Agency 520 Lafayette Road North St. Paul, Minnesota Also, where required by an applicable rule or permit condition, send to the Permit Document Coordinator notices of: a. Accumulated insignificant activities b. Installation of control equipment c. Replacement of an emissions unit, and d. Changes that contravene a permit term Unless another person is identified in the applicable Table, send all other submittals to: AQ Compliance Tracking Coordinator Industrial Division Minnesota Pollution Control Agency 520 Lafayette Road North St. Paul, Minnesota

5 Permit issued: [month day, year] Permit expires: [month day, year] Page 5 of Facility description The Polaris Industries Inc - Roseau (Facility) is located at 301 5th Ave SW in Roseau, MN, Roseau County, Minnesota. Polaris Industries, Inc. located in Roseau, Minnesota designs, engineers, and manufactures off-road vehicles, including all-terrain vehicles and snowmobiles for recreational and utility use. The main emissions sources at the facility are coating operations, engine testing operations, and miscellaneous combustion sources. The permit limits the emissions from the facility such that the facility is classified as a minor source under Federal New Source Review regulations. These limits include limits on CO and VOC emissions at 20 tons per month based on a 12-month rolling average, and limits on PM, PM10, PM2.5 and NOx at 15 tons per month based on 12-month rolling average. The facility operates panel filters to control PM, PM10, and PM2.5 emissions from the spray booths and a thermal oxidizer to control CO and VOC emissions from engine testing operations. This permit action incorporates a major amendment received on September 24, 2015 and a minor amendment received on June 6, The major amendment authorizes the construction of two R&D engine test cells and a second thermal oxidizer. The amendment also adds the requirements for 40 CFR pt. 63, subp. PPPPP the NESHAP for Engine Test Cells/Stands. At the time of permit issuance, the Permittee is not subject to subp. PPPPP because the facility is an existing affected source as defined by the regulations. However, the Permittee anticipates the potential to trigger reconstruction under 40 CFR pt. 63 through future modifications or additions of engine test cells. Upon reconstruction, the Permittee would become subject to 40 CFR pt. 63, subp. PPPPP. The minor amendment adds a paint booth and associated make-up air unit.

6 Permit issued: [month day, year] Permit expires: [month day, year] Page 6 of Summary of subject items SI ID: Description ACTV4: All IA's COMG11: Miscellaneous Industrial Process Equipment COMG13: Process Heaters (NESHAP DDDDD) COMG14: Thermal Oxidizer(s) (After Reconstruction) COMG15: Catalytic Oxidizer(s) (After Reconstruction) COMG16: Engine Test Cells for Uninstalled Engines (After Reconstruction) Relationshi p Type has members has members has members has members has members Related SI ID: Description EQUI5, EQUI10, EQUI11, EQUI41, EQUI42 EQUI41, EQUI42 EQUI14, EQUI15, EQUI16, EQUI19, EQUI20, EQUI21, EQUI22, EQUI23, EQUI25, EQUI26, EQUI27, EQUI28, EQUI36, EQUI37, EQUI38, EQUI39, EQUI40, EQUI79, EQUI80, TREA8, TREA13 TREA9 EQUI14, EQUI15, EQUI16, EQUI19, EQUI20, EQUI21, EQUI22, EQUI23, EQUI25, EQUI26, EQUI27, EQUI28, EQUI36, EQUI37, SI ID: Description COMG17: Panel Filters with Certified Hoods COMG1: PreCap Requirements Relationshi p Type has members has members Related SI ID: Description EQUI38, EQUI39, EQUI40, EQUI79, EQUI80 TREA4 EQUI1, EQUI2, EQUI3, EQUI4, EQUI5, EQUI7, EQUI8, EQUI9, EQUI12, EQUI14, EQUI15, EQUI16, EQUI18, EQUI19, EQUI20, EQUI21, EQUI22, EQUI23, EQUI24, EQUI25, EQUI26, EQUI27, EQUI28, EQUI30, EQUI31, EQUI36, EQUI37, EQUI38, EQUI39, EQUI40, EQUI41, EQUI42, EQUI43, EQUI44, EQUI77, EQUI78, EQUI79, EQUI80, EQUI82, EQUI83, EQUI84, TREA1, TREA2, TREA3, TREA4,

7 Permit Expires: [month day, year] Page 7 of 148 SI ID: Description COMG2: Engine Test Stations COMG3: Coating Booths COMG4: Filter Requirements COMG5: Thermal Oxidizer(s) (Before Reconstruction) COMG6: Catalytic Oxidizer(s) (Before Reconstruction) COMG7: Surface Coating of Metal Parts (NESHAP MMMM) COMG8: Surface Coating of Plastic Relationshi p Type has members has members has members has members has members has members has members Related SI ID: Description TREA5, TREA8, TREA9, TREA11, TREA12, TREA13 EQUI12, EQUI14, EQUI15, EQUI16, EQUI18, EQUI19, EQUI20, EQUI21, EQUI22, EQUI23, EQUI24, EQUI25, EQUI26, EQUI27, EQUI28, EQUI31, EQUI36, EQUI37, EQUI38, EQUI39, EQUI40, EQUI79, EQUI80, EQUI82 EQUI1, EQUI2, EQUI3, EQUI4, EQUI30, EQUI77 TREA1, TREA2, TREA3, TREA4, TREA5, TREA11, TREA12 TREA8, TREA13 TREA9 EQUI5, EQUI8, EQUI9, EQUI10, EQUI41 EQUI1, EQUI2, EQUI3, EQUI4, SI ID: Description Parts (NESHAP PPPP) COMG9: Direct Heating Equipment EQUI10: Metal Cool Tunnel (Metal Painting) EQUI10: Metal Cool Tunnel (Metal Painting) EQUI10: Metal Cool Tunnel (Metal Painting) EQUI10: Metal Cool Tunnel (Metal Painting) EQUI11: Paint Kitchen EQUI11: Paint Kitchen EQUI12: Production Engine Test C-Line EQUI14: R & D Engine Test Room RD 06B EQUI15: R & D Engine Test Room RD 07 EQUI16: R & D Engine Test Room RC 02 EQUI18: Production Engine Testing C-Line Prod EQUI19: R & D Engine Test Room RD 01 EQUI1: Primer Booth (Plastic Relationshi p Type has members sends to sends to sends to sends to sends to sends to sends to sends to sends to sends to sends to sends to sends to Related SI ID: Description EQUI7, EQUI11, EQUI30, EQUI42, EQUI77 EQUI7, EQUI8, EQUI9, EQUI78, EQUI81, EQUI86, TREA8, TREA9, TREA13 STRU12: Metal Cool Tunnel STRU13: Metal Cool Tunnel STRU14: Metal Cool Tunnel STRU15: Metal Cool Tunnel STRU16: Paint Kitchen STRU17: Paint Kitchen STRU25: Production Engine Test Stations C-Line STRU46: R & D Engine Test Room RD 06B STRU47: R & D Engine Test Room RD 07 STRU31: R & D Engine Test Room RC 02 STRU9: Production Engine Station C-Line STRU18: R & D Engine Test RD 01 STRU36: Primer Booth

8 Permit Expires: [month day, year] Page 8 of 148 SI ID: Description Painting) EQUI1: Primer Booth (Plastic Painting) EQUI1: Primer Booth (Plastic Painting) EQUI20: R & D Engine Test Room RD 02 EQUI21: R & D Engine Test Room RD 03 EQUI22: R & D Engine Test Room RD 04 EQUI23: R & D Engine Test Room RD 05 EQUI24: Production Engine Test A/B Line EQUI24: Production Engine Test A/B Line EQUI24: Production Engine Test A/B Line EQUI25: R & D Engine Test Room RC 01 EQUI26: R & D Engine Test Room RD 08 EQUI27: R & D Engine Test Room RD 09 EQUI28: R&D Engine Test Room RS 011 Relationshi p Type sends to is controlled by sends to sends to sends to sends to sends to sends to sends to sends to sends to sends to sends to Related SI ID: Description (Plastic Painting) & Plastic Paint (Primer Booth) STRU37: Primer Booth (Plastic Painting) TREA1: Mat or Panel Filter STRU19: R & D Engine Test RD 02 STRU20: R & D Engine Test RD 03 STRU21: R & D Engine Test Station RD 04 STRU22: R & D Engine Test RD 05 STRU10: Production Engine Station A/B Line STRU23: Production Engine Testing A/B Line STRU24: Production Engine Testing A/B Line STRU29: R & D Engine Test Stations Room RC-01 STRU27: R & D Engine Test Stations Room RD 08 STRU28: R & D Engine Test Room RD 09 STRU30: R & D Engine Test Room RS 011 EQUI2: Base Coat sends to STRU38: Base SI ID: Description Booth (Plastic Painting) EQUI2: Base Coat Booth (Plastic Painting) EQUI2: Base Coat Booth (Plastic Painting) EQUI30: Flex Primer Booth EQUI30: Flex Primer Booth EQUI30: Flex Primer Booth EQUI31: Production Engine Testing Pilot EQUI36: R & D Engine Test Room Chassis Dyno R01 EQUI37: R & D Engine Test Room RV 01 EQUI38: R & D Engine Test Room RV 02 EQUI39: R & D Engine Test Room RV 03 EQUI3: Top Coat Booth (Plastic Painting) EQUI3: Top Coat Booth (Plastic Painting) EQUI3: Top Coat Booth (Plastic Painting) Relationshi p Type sends to is controlled by sends to is controlled by is controlled by sends to sends to sends to sends to sends to sends to sends to is controlled by Related SI ID: Description Coat Booth (Plastic Painting) STRU39: Base Coat Booth (Plastic Painting) TREA2: Mat or Panel Filter STRU11: Flex Primer Booth TREA4: Mat or Panel Filter TREA5: Mat or Panel Filter STRU33: Production Engine Testing Pilot STRU4: R&D Engine Test Station Room Chassis Dyno R 01 STRU5: R&D Engine Test Station Room RV 01 STRU6: R&D Engine Test Station Room RV 02 STRU7: R&D Engine Test Station Room RV 03 STRU40: Top Coat Booth (Plastic Painting) STRU41: Top Coat Booth (Plastic Painting) TREA3: Mat or Panel Filter

9 Permit Expires: [month day, year] Page 9 of 148 SI ID: Description EQUI40: R & D Engine Test Room RV 04 EQUI41: metal parts wash system EQUI42: plastic parts wash system EQUI43: Peak Shaving Generator 1 (North) EQUI43: Peak Shaving Generator 1 (North) EQUI44: Peak Shaving Generator 2 (South) EQUI44: Peak Shaving Generator 2 (South) EQUI4: Clear Coat Booth (Plastic Painting) EQUI4: Clear Coat Booth (Plastic Painting) EQUI4: Clear Coat Booth (Plastic Painting) EQUI5: E-Coat Dip Tank EQUI77: Paint Booth EQUI77: Paint Booth EQUI77: Paint Booth EQUI77: Paint Booth EQUI78: Paint Booth Make-up Air Unit Relationshi p Type sends to sends to is controlled by sends to is controlled by sends to sends to is controlled by Related SI ID: Description STRU8: R&D Engine Test Station Room RV 04 STRU1: Peak Shaving Generator 1 (North) TREA14: Oxidation Catalyst STRU2: Peak Shaving Generator 2 (South) TREA15: Oxidation Catalyst STRU42: Clear Coat Booth (Plastic Painting) STRU43: Clear Coat Booth (Plastic Painting) TREA4: Mat or Panel Filter sends to STRU49: E- Coat Dip Tank sends to STRU56: Paint Booth Stack 1 sends to STRU57: Paint Booth Stack 2 is TREA11: Wall controlled Filter in parallel by is controlled in parallel by sends to TREA12: Wall Filter STRU56: Paint Booth Stack 1 SI ID: Relationshi Description p Type EQUI78: Paint sends to Booth Make-up Air Unit EQUI79: R&D sends to Engine Test Cell EQUI7: Plastic sends to Oven (Plastic Painting) EQUI7: Plastic sends to Oven (Plastic Painting) EQUI80: R&D sends to Engine Test Cell EQUI81: Exhaust Units EQUI82: sends to Production Engine Testing QA/QC EQUI83: Emergency Engine EQUI84: Emergency Engine EQUI85: Emergency Engine EQUI86: Air Makeup Units EQUI8: E-Coat Oven EQUI8: E-Coat Oven EQUI8: E-Coat Oven EQUI9: Powder Cure Oven (Powder Painting) EQUI9: Powder Cure Oven (Powder Painting) EQUI9: Powder Cure Oven (Powder Painting) STRU10: Production Engine Station A/B Line STRU11: Flex Primer Booth Related SI ID: Description STRU57: Paint Booth Stack 2 STRU60: Engine Test STRU44: Plastic Paint Bake Oven STRU45: Plastic Paint Bake Oven STRU61: Engine Test STRU35: Production Engine Testing QA/QC sends to STRU50: E- Coat Oven sends to STRU51: E- Coat Oven sends to STRU52: E- Coat Oven sends to sends to sends to STRU53: Powder Cure Oven (Powder Painting) STRU54: Powder Cure Oven (Powder Painting) STRU55: Powder Cure Oven (Powder Painting)

10 Permit Expires: [month day, year] Page 10 of 148 SI ID: Description STRU12: Metal Cool Tunnel STRU13: Metal Cool Tunnel STRU14: Metal Cool Tunnel STRU15: Metal Cool Tunnel STRU16: Paint Kitchen STRU17: Paint Kitchen STRU18: R & D Engine Test RD 01 STRU19: R & D Engine Test RD 02 STRU1: Peak Shaving Generator 1 (North) STRU20: R & D Engine Test RD 03 STRU21: R & D Engine Test Station RD 04 STRU22: R & D Engine Test RD 05 STRU23: Production Engine Testing A/B Line STRU24: Production Engine Testing A/B Line STRU25: Production Engine Test Stations C- Line STRU27: R & D Engine Test Stations Room RD 08 STRU28: R & D Engine Test Room RD 09 STRU29: R & D Engine Test Stations Room RC- 01 STRU2: Peak Shaving Generator 2 (South) Relationshi p Type Related SI ID: Description SI ID: Description STRU30: R & D Engine Test Room RS 011 STRU31: R & D Engine Test Room RC 02 STRU33: Production Engine Testing Pilot STRU35: Production Engine Testing QA/QC STRU36: Primer Booth (Plastic Painting) & Plastic Paint (Primer Booth) STRU37: Primer Booth (Plastic Painting) STRU38: Base Coat Booth (Plastic Painting) STRU39: Base Coat Booth (Plastic Painting) STRU40: Top Coat Booth (Plastic Painting) STRU41: Top Coat Booth (Plastic Painting) STRU42: Clear Coat Booth (Plastic Painting) STRU43: Clear Coat Booth (Plastic Painting) STRU44: Plastic Paint Bake Oven STRU45: Plastic Paint Bake Oven STRU46: R & D Engine Test Room RD 06B STRU47: R & D Engine Test Room RD 07 STRU49: E-Coat Dip Tank Relationshi p Type Related SI ID: Description

11 Permit Expires: [month day, year] Page 11 of 148 SI ID: Description STRU4: R&D Engine Test Station Room Chassis Dyno R 01 STRU50: E-Coat Oven STRU51: E-Coat Oven STRU52: E-Coat Oven STRU53: Powder Cure Oven (Powder Painting) STRU54: Powder Cure Oven (Powder Painting) STRU55: Powder Cure Oven (Powder Painting) STRU56: Paint Booth Stack 1 STRU57: Paint Booth Stack 2 STRU58: Thermal Oxidizer Stack STRU59: Primary Thermal Oxidizer Stack STRU5: R&D Engine Test Station Room RV 01 STRU60: Engine Test STRU61: Engine Test STRU62: Main Plan Building STRU63: Injection Molding Plant Building STRU64: Northern Distribution Center Building STRU65: Barrel Relationshi p Type Related SI ID: Description SI ID: Description Shed Building STRU6: R&D Engine Test Station Room RV 02 STRU7: R&D Engine Test Station Room RV 03 STRU8: R&D Engine Test Station Room RV 04 STRU9: Production Engine Station C- Line TFAC1: Polaris Industries Inc - Roseau TREA11: Wall Filter TREA12: Wall Filter TREA13: Thermal Oxidizer - Primary TREA14: Oxidation Catalyst TREA15: Oxidation Catalyst TREA1: Mat or Panel Filter TREA2: Mat or Panel Filter TREA3: Mat or Panel Filter TREA4: Mat or Panel Filter TREA5: Mat or Panel Filter TREA8: Thermal Oxidizer TREA9: Catalytic Oxidizer Relationshi p Type Related SI ID: Description

12 Permit Expires: [month day, year] Page 12 of Limits and other requirements TFAC Polaris Industries Inc - Roseau 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: Avoid major modification under 40 CFR 52.21(b)(2) and Minn. R , Title I Condition: Avoid major source under 40 CFR 52.21(b)(1)(i) and Minn. R ] Permit Appendices: This permit contains appendices as listed in the permit Table of Contents. The Permittee shall comply with all requirements contained in Appendices: Appendix A: Insignificant Activities and General Applicable Requirements Appendix B: PreCap Compliance Calculation Equations Appendix C: Maximum Material Contents and Application Rates Appendix D: Part 63 Subpart MMMM Compliance Equations Appendix E: Part 63 Subpart PPPP Compliance Equations Appendix F: List of Air Make-up Units (EQUI 046) and Exhaust Units (EQUI 081) Appendix H: 40 CFR Part 63 Subpart A General Provisions Applicable to 40 CFR Part 63 Subpart PPPPP (COMG 014 & COMG 015) Appendix I: 40 CFR Part 63 Subpart A General Provisions Applicable to 40 CFR Part 63 Subpart ZZZZ (EQUI 043 & EQUI 044) Modeling parameters in Appendix G: Modeling Parameters for NO2 Dispersion Modeling Analysis for Peak Shaving Generators are included for reference only as described elsewhere in this permit. [Minn. R , subp. 2] PERMIT SHIELD: to the limitations in Minn. R , 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. to the limitations of Minn. R and , subp. 2, notwithstanding the conditions of this permit specifying compliance practices for applicable requirements, any person (including the Permittee) may also use other credible evidence to establish compliance or noncompliance with applicable requirements. This permit shall not alter or affect the liability of the Permittee for any violation of applicable requirements prior to or at the time of permit issuance. [Minn. R (A)] Modeling Parameters for NO2: The parameters used in the NO2 for the peak shaving generators (EQUI 043 and EQUI 044) required by

13 Permit Expires: [month day, year] Page 13 of are listed in Appendix G of this permit. The parameters describe the operation of the peak shaving generators at maximum permitted capacity. The purpose of listing the parameters in the appendix is to provide a benchmark for future changes. [Minn. R , subp. 7(A), 7(L), & 7(M), Minn. R , subp. 4, Minn. R , subps. 1-2, Minn. R , Minn. Stat , subd. 4a, Minn. Stat , subd. 9] 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 to Compliance shall be demonstrated upon written request by the MPCA. [Minn. R , subp. 7(A), 7(L), & 7(M), Minn. R , subp. 4, Minn. R , subps. 1-2, Minn. Stat , subd. 4a, Minn. Stat , subd. 9] 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 ] Air Pollution Control Equipment: Operate all pollution control equipment whenever the corresponding process equipment and emission units are operated unless otherwise specified elsewhere in the permit. [Minn. R , subp. 16(J), Minn. R , subp. 2] 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, calibration frequencies, procedures, and manufacturer's specifications (if applicable) for each monitor, and the records kept to demonstrate plan implementation. [Minn. R , subp. 14, Minn. R , subp. 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 , 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 [Minn. R ] Noise: The Permittee shall comply with the noise standards set forth in Minn. R to at all times during the operation of any

14 Permit Expires: [month day, year] Page 14 of 148 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 ] Inspections: The Permittee shall comply with the inspection procedures and requirements as found in Minn. R , subp. 9(A). [Minn. R , subp. 9(A)] The Permittee shall comply with the General Conditions listed in Minn. R , subp. 16. [Minn. R , subp. 16] Performance Testing: Conduct all performance tests in accordance with Minn. R. ch unless otherwise noted in this permit. [Minn. R. ch. 7017] Performance Test Notifications and Submittals: Performance Tests are due as outlined in this permit. Performance Test Notification (written): due 30 days before each Performance Test Performance Test Plan: due 30 days before each Performance Test Performance Test Pre-test Meeting: due 7 days before each Performance Test Performance Test Report: due 45 days after each Performance Test Performance Test Report - Microfiche Copy: due 105 days after each Performance Test The Notification, Test Plan, and Test Report may be submitted in an alternative format as allowed by Minn. R [Minn. R , Minn. R , subps. 1-4, Minn. R , subps. 1-2] 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 , subp. 3. The limit is final upon issuance of a permit amendment incorporating the change. [Minn. R , subp. 3] Monitoring Equipment Calibration - The Permittee shall either: 1. Calibrate or replace required monitoring equipment every 12 months; or 2. Calibrate at the frequency stated in the manufacturer's specifications. For each monitor, the Permittee shall maintain a record of all calibrations, including the date conducted, and any corrective action that resulted. The Permittee shall include the calibration frequencies, procedures, and manufacturer's specifications (if applicable) in the Operations and Maintenance Plan. Any requirements applying to continuous emission monitors are listed separately in this permit. [Minn. R , subp. 4(D)] Operation of Monitoring Equipment: Unless noted elsewhere in this permit, monitoring a process or control equipment connected to that process is not necessary during periods when the process is shutdown,

15 Permit Expires: [month day, year] Page 15 of 148 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 , subp. 4(D)] Recordkeeping: Retain all records at the stationary source, unless otherwise specified within this permit, for a period of five (5) years from the date of monitoring, sample, measurement, or report. Records which must be retained at this location include all calibration and maintenance records, all original recordings for continuous monitoring instrumentation, and copies of all reports required by the permit. Records must conform to the requirements listed in Minn. R , subp. 5(A). [Minn. R , subp. 5(C)] Recordkeeping: Maintain records describing any insignificant modifications (as required by Minn. R , subp. 3) or changes contravening permit terms (as required by Minn. R , subp. 2), including records of the emissions resulting from those changes. [Minn. R , 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 [For expiring permits, 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. ][For non-expiring permits, these records shall be kept for a period of five years from the date that the change was made.] 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 , subp. 4] 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 s A, B and C of Minn. R , 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 , 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 s A, B and C of Minn. R , subp. 2.

16 Permit Expires: [month day, year] Page 16 of 148 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 , 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 , 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 , subp. 1] Application for Permit Amendment: If a permit amendment is needed, submit an application in accordance with the requirements of Minn. R through Minn. R Submittal dates vary, depending on the type of amendment needed. Upon adoption of a new or amended federal applicable requirement, and if there are more than 3 years remaining in the permit term, the Permittee shall file an application for an amendment within nine months of promulgation of the applicable requirement, pursuant to Minn. R , subp. 3. The preceding sentence does not apply if the effective date of the requirement is later than the date on which the permit is due to expire. [Minn. R , subp. 3, Minn. R ] 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 , 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 , subp. 1(H). The agency may do an administrative amendment to extend a testing deadline in a permit up to 365 days if the agency finds that the extension is needed to allow the Permittee to test at worst case conditions as

17 Permit Expires: [month day, year] Page 17 of 148 required by Minn. R , subp. 2. [Minn. R , 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 ] Emission Fees: due 30 days after receipt of an MPCA bill. [Minn. R ] The Permittee shall not have engines that meet section (1)(iii) under the definition of Nonroad Engine at 40 CFR Section in one location within the stationary source for more than 12 consecutive months. A location is any single site at a building, structure, facility, or installation. Any engine, or engines, that replaces an engine at a location and that is intended to perform the same or similar function as the engine it replaced will be included in calculating the consecutive time period. [40 CFR ] For a nonroad engine that is excluded from any requirements of 40 CFR Part 1068 because it is a stationary engine, the Permittee may not move it or install it in any mobile equipment, except as allowed by the provisions of 40 CFR Part The Permittee may not circumvent or attempt to circumvent the residence-time requirements of Section (2)(iii) of the Nonroad Engine definition at 40 CFR Section [40 CFR (b)(3)] The Permittee shall conduct an inventory of all engines on-site that meet section (1)(iii) under the definition of Nonroad Engine at 40 CFR Section This applies to nonroad engines that are owned by the Permittee, or rented and operated by the Permittee, or brought onsite and operated by a vendor or contractor. The inventory shall include the following: 1) Date that the nonroad engine is inventoried. 2) Identification number. 3) Function of the nonroad engine (e.g. compressor, welder). 4) Location of the engine within the stationary source. 5) Statement that the nonroad engine has not been located in a single location for 12 consecutive months, and movement between locations has not been for purposes of circumvention of residence time requirements of section (2)(iii) under the definition of Nonroad Engine at 40 CFR Section The Permittee shall update the inventory each calendar year and within 15 calendar days of the date a new engine is brought on-site that meets section (1)(ii) under the definition of Nonrad Engine at 40 CFR Section [40 CFR (nonrd engn)(1)(iii), Minn. R , subps. 4-5]

18 Permit Expires: [month day, year] Page 18 of A nonroad engine ceases to be a nonroad engine and becomes a new stationary engine if: 1. At any time, it meets the criteria specified in section (2)(iii) under the definition of Nonroad Engine in 40 CFR Section For example, a portable generator engine ceases to be a nonroad engine if it is used or will be used in a single specific location for 12 months or longer. If the Administrator or the Permitting authority determines that an engine will be or has been used in a single specific location for 12 months or longer, it ceased to be a nonroad engine when it was placed in that location. OR 2. It is otherwise regulated by a federal New Source Performance Standard promulgated under section 111 of the Clean Air Act (42 U.S.C. 7411). [40 CFR (e)] 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 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. If the Permittee uses unique numbers that are not the numbers, a document that correlates the unique numbers to the numbers shall be maintained and kept on site at all times. [Minn. R , 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. COMG 1 GP001 PreCap Requirements PreCap: The list shall correlate the units to the numbers used in this permit and shall include the data on GI-04, GI-05B, and GI-05C or equivalent. The date of construction shall be the date the change was made for replaced, modified, or new equipment. The Permittee shall also maintain a list of all natural gas and/or propane fired ovens, dryers, heaters, makeup air units, and exhaust units that qualify as insignificant activities under Minn. R , subp. 3 or 4 and update the list to include any replaced, modified, or new equipment meeting the above criteria prior to making the change. The list shall include manufacturer, model number, heating capacity, and date of construction and modification of the equipment. [Minn. R , subp. 2]

19 Permit Expires: [month day, year] Page 19 of 148 For the purposes of this permit, PreCap equipment is defined as coating equipment (equipment used to apply coating to a substrate); VOCcontaining material usage, engine testing equipment; diesel-fired emergency engines; and natural gas and/or propane fired ovens, dryers, heaters, wash systems, oxidizers makeup air units, and exhaust units. The coating equipment, VOC-containing material usage and natural gas and/or propane fired ovens, dryers, heaters, makeup air units, and exhaust units include insignificant activities that qualify under Minn. R , subp. 3 or 4. If the Permittee: 1) replaces any PreCap equipment, 2) adds new PreCap equipment, or 3) modifies the existing PreCap equipment, such equipment is subject to: a) the limits and requirements for COMG 001 in Section 5, b) reporting requirements for COMG 001 in Section 6, and c) any applicable requirements for the PreCap equipment contained elsewhere in this permit. Prior to making such a change, the Permittee shall apply for and obtain the appropriate permit amendment, as applicable. For modifications that solely involve equipment covered by the PreCaps, the Permittee is not required to complete the calculations described in Minn. R , 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: Avoid major modification under 40 CFR 52.21(b)(2) and Minn. R , Title I Condition: Avoid major source under 40 CFR 52.21(b)(1)(i) and Minn. R ] The Permittee shall limit emissions of Carbon Monoxide <= 20.0 tons per month 12-month rolling average to be calculated by the 15th day of each month for the previous 12-month period as described in Appendix B of this permit. All PreCap equipment in COMG 001, Appendix A, and all PreCap equipment added to COMG 001, including all natural gas and/or propane fired ovens, dryers, heaters, makeup air units, and exhaust units that qualify as insignificant activities under Minn. R subp. 3 shall be included in this calculation. [Title I Condition: Avoid major modification under 40 CFR 52.21(b)(2) and Minn. R , Title I Condition: Avoid major source under 40 CFR 52.21(b)(1)(i) and Minn. R ] The Permittee shall limit emissions of Volatile Organic Compounds <= 20.0 tons per month 12-month rolling average to be calculated by the 15th day of each month for the previous 12-month period as described in Appendix B of this permit. All PreCap equipment in COMG 001, Appendix A, and all PreCap

20 Permit Expires: [month day, year] Page 20 of 148 equipment added to COMG 001, including coating equipment, VOCmaterial usage, and natural gas and/or propane fired ovens, dryers, heaters, makeup air units, and exhaust units that qualify as insignificant activities under Minn. R subp. 3 shall be included in this calculation. VOC contents for each VOC-containing material shall be determined as described under the Material Content requirement in COMG 001. The calculation of VOCs used may take into account recovered/recycled VOCs as described under the Waste Credit requirement in COMG 001. [Title I Condition: Avoid major modification under 40 CFR 52.21(b)(2) and Minn. R , Title I Condition: Avoid major source under 40 CFR 52.21(b)(1)(i) and Minn. R ] The Permittee shall limit emissions of Total Particulate Matter <= 15.0 tons per month 12-month rolling average to be calculated by the 15th day of each month for the previous 12-month period as described in Appendix B of this permit. All PreCap equipment in COMG 001, Appendix A, and all PreCap equipment added to COMG 001, including coating equipment and natural gas and/or propane fired ovens, dryers, heaters, makeup air units, and exhaust units that qualify as insignificant activities under Minn. R subp. 3 and shall be included in this calculation. Solids contents for each material shall be determined as described under the Material Content requirement in COMG 001. The calculation of solids used may take into account recovered/recycled solids as described under the Waste Credit requirement in COMG 001. [Title I Condition: Avoid major modification under 40 CFR 52.21(b)(2) and Minn. R , Title I Condition: Avoid major source under 40 CFR 52.21(b)(1)(i) and Minn. R ] The Permittee shall limit emissions of PM < 10 micron <= 15.0 tons per month 12-month rolling average to be calculated by the 15th day of each month for the previous 12-month period as described in Appendix B of this permit. All PreCap equipment in COMG 001, Appendix A, and all PreCap equipment added to COMG 001, including coating equipment and natural gas and/or propane fired ovens, dryers, heaters, makeup air units, and exhaust units that qualify as insignificant activities under Minn. R subp. 3 and shall be included in this calculation. Solids contents for each material shall be determined as described under the Material Content requirement in COMG 001. The calculation of solids used may take into account recovered/recycled solids as described under the Waste Credit requirement in COMG 001. [Title I Condition: Avoid major modification under 40 CFR 52.21(b)(2) and Minn. R , Title I Condition: Avoid major source under 40 CFR 52.21(b)(1)(i) and Minn. R ] The Permittee shall limit emissions of PM < 2.5 micron <= 15.0 tons per month 12-month rolling average to be calculated by the 15th day of each month for the previous 12-month period as described in Appendix B of this permit.

21 Permit Expires: [month day, year] Page 21 of 148 All PreCap equipment in COMG 001, Appendix A, and all PreCap equipment added to COMG 001, including coating equipment and natural gas and/or propane fired ovens, dryers, heaters, makeup air units, and exhaust units that qualify as insignificant activities under Minn. R subp. 3 and shall be included in this calculation. Solids contents for each material shall be determined as described under the Material Content requirement in COMG 001. The calculation of solids used may take into account recovered/recycled solids as described under the Waste Credit requirement in COMG 001. [Title I Condition: Avoid major modification under 40 CFR 52.21(b)(2) and Minn. R , Title I Condition: Avoid major source under 40 CFR 52.21(b)(1)(i) and Minn. R ] The Permittee shall limit emissions of Nitrogen Oxides <= 15.0 tons per month 12-month rolling average to be calculated by the 15th day of each month for the previous 12-month period as described in Appendix B of this permit. All PreCap equipment in COMG 001, Appendix A, and all PreCap equipment added to COMG 001, including all natural gas and/or propane fired ovens, dryers, heaters, makeup air units, and exhaust units that qualify as insignificant activities under Minn. R subp. 3 shall be included in this calculation. [Title I Condition: Avoid major modification under 40 CFR 52.21(b)(2) and Minn. R , Title I Condition: Avoid major source under 40 CFR 52.21(b)(1)(i) and Minn. R ] Coating Operations Recordkeeping (As of permit issuance: EQUIs , 005, 030, 077): On each day of operation, the Permittee shall record and maintain the total quantity of each coating and other VOC and solids containing material used at the facility. The record shall include the VOC and solids content of each coating. This shall be based on written usage logs, flowmeters, or purchase/delivery records. If the Permittee elects to use purchase/delivery records, the amount of coating and other VOC and solids containing material is considered used on the day it is received. Coating operations include coating equipment that qualify as insignificant activities under Minn. R subp. 3 or 4. [Minn. R , subps. 4-5, Title I Condition: Avoid major modification under 40 CFR 52.21(b)(2) and Minn. R , Title I Condition: Avoid major source under 40 CFR 52.21(b)(1)(i) and Minn. R ] Engine Testing Recordkeeping (As of permit issuance: EQUIs 012, , , 031, , 079, 080, 082): On each day of operation, the Permittee shall record the: i) test station used, ii) fuel type used at each test station, iii) the total amount of fuel used in engine test stations not vented to an oxidizer,

22 Permit Expires: [month day, year] Page 22 of 148 iv) the total amount of fuel used un engine test stations vented to an oxidizer meeting the requirements of COMG 005 or COMG 006 (prior to reconstruction as defined in 40 CFR pt. 63, subp. PPPPP) or meeting the requirements of COMG 014 and COMG 015 (after reconstruction as defined in 40 CFR pt. 63, subp. PPPPP), and The Permittee shall maintain monthly records of fuel use based on purchase, delivery, and returns records. [Minn. R , subps. 4-5, Title I Condition: Avoid major modification under 40 CFR 52.21(b)(2) and Minn. R , Title I Condition: Avoid major source under 40 CFR 52.21(b)(1)(i) and Minn. R ] Combustion Equipment Recordkeeping (As of permit issuance: EQUIs 008, 009, , 078, , TREAs 008, 009, 013): For all combustion equipment, not including the engine test stations, the Permittee shall maintain monthly records of fuel use and fuel type based on purchase, delivery, and returns records. [Minn. R , subps. 4-5, Title I Condition: Avoid major modification under 40 CFR 52.21(b)(2) and Minn. R , Title I Condition: Avoid major source under 40 CFR 52.21(b)(1)(i) and Minn. R ] Monthly Recordkeeping By the 15th of the month, the Permittee shall calculate and record the following: 1) a) total usage of VOC-containing coating materials and solidscontaining coating materials for the previous calendar month using daily usage records. This record shall also include the VOC and solids contents of each material as determined by the Material Content requirement of this permit, b) total quantity of fuels combusted in the controlled engine test stations using daily records, c) total quantity of fuels combusted in the uncontrolled engine test stations using daily records, and d) total quantity of fuels combusted in the other combustion equipment listed in COMG 001 using monthly records, 2) The CO, VOC, PM, PM10, PM2.5, and NOx emissions for the previous month using the formulas specified in Appendix B of this permit; and 3) The 12-month rolling average CO, VOC, PM, PM10, PM2.5, and NOx emissions for the previous 12-month period by averaging the monthly CO, VOC, PM, PM10, PM2.5 and NOx emissions data for the previous 12 months. [Minn. R , subps. 4-5] Material Content. VOC and Solids (PM, PM<10 microns, and PM<2.5 microns) contents in coating materials shall be determined by an EPA or ASTM reference method or the Safety Data Sheet (SDS), the Material Safety Data Sheet (MSDS), or the Technical Data Sheet (TDS) provided by the supplier for each material used. If a material content range is given on the SDS, the MSDS or the TDS, the highest number in the range shall be used in all compliance calculations. If there is information provided in the Regulatory Section of the SDS, the highest number in the range of that section may be used. When using the MSDS, SDS, or TSD as the basis

23 Permit Expires: [month day, year] Page 23 of 148 of calculating particulate emissions, the conservative assumption is made that PM consists entirely of PM less than 10 microns or less than 2.5 microns. Other alternative methods approved by the MPCA may be used to determine the VOC, HAPs, and solids contents. The Commissioner reserves the right to require the Permittee to determine the VOC, HAP, and solids contents of any material, according to EPA or ASTM reference methods. If an EPA or ASTM reference method is used for material content determination, the data obtained shall supersede the SDS, MSDS, or TDS. [Minn. R , subps. 4-5] Waste Credit: If the Permittee elects to obtain credit for solids and/or VOC shipped in waste materials, the Permittee shall either use item 1 or 2 to determine the VOC and/or solids content for each credited shipment. 1) The Permittee shall analyze a composite sample of each waste shipment to determine the weight content of VOC and/or solids excluding water. 2) The Permittee may use supplier data for raw materials to determine the VOC and/or solids 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 and/or solids content of any of the materials. [Minn. R , subps. 4-5] Maximum Contents of Materials: The Permittee assumed certain worstcase contents of materials, application rates, and transfer efficiencies when determining the short term potential to emit of coating units in COMG 001. These assumptions are listed in Appendix C of this permit. Changing to a material that has a higher content of any of the given pollutants, increasing the application rate, or decreasing the transfer efficiency is considered a change in method of operation that must be evaluated under Minn. R , subp. 3 to determine if a permit amendment or notification is required under Minn. R [Minn. R , subp. 35a] COMG 2 GP002 Engine Test Stations Opacity <= 20 percent opacity once operating temperatures have been attained. This limit applies individually to each unit in COMG 002 including any new or replaced engine testing unit. [Minn. R , subp. 1] Sulfur Dioxide <= 0.50 pounds per million Btu heat input. This limit applies individually to each unit in COMG 002 including new or replaced engine testing units. The potential to emit from each unit is less than or equal to 0.29 lb/mmbtu due to equipment design and allowable fuels. [Minn. R , subp. 2] Fuel type: gasoline, diesel fuel, jet fuel only. [Minn. R , subp. 35a] COMG 3 GP003 Coating Booths The Permittee shall vent emissions from all totally enclosed coating