AIR EMISSION PERMIT NO IS ISSUED TO. Polaris Industries Inc.

Transcription

1 AIR EMISSION PERMIT NO IS ISSUED TO Polaris Industries Inc. Polaris Industries, Inc. - Wyoming 7290 Viking Boulevard East Wyoming, Chisago County, MN 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 Application Date Total Facility Operating Permit December 30, 2003 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 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. Permit Type: State; Limits to Avoid Pt 70/Limits to Avoid NSR Issue Date: March 30, 2004 Expiration: Permit Does Not Expire All Title I Conditions do not expire. Ann M. Foss Major Facilities Section Manager Majors and Remediation Division for Sheryl A. Corrigan Commissioner Minnesota Pollution Control Agency AMF/JSC:lh TDD (for hearing and speech impaired only): (651) Printed on recycled paper containing at least 10% fibers from paper recycled by consumers

2 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 - None 2

3 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) Outside Metro Area TTY (651) The rules governing these programs are contained in Minn. R. chs Written questions may be sent to: Minnesota Pollution Control Agency, 520 Lafayette Road North, St. Paul, Minnesota 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 , 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 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. 3

4 FACILITY DESCRIPTION: The primary sources of emissions at this facility are the engine test stands. Polaris will be testing primarily 4-stroke ATV, motorcycle or personal watercraft engines. Snowmobile engines may also be tested. All of these engines use gasoline or diesel. In addition, this facility will have a coating booth for research and development purpose, two natural gas fired units to provide building heat, and a diesel fired emergency generator. This is a state permit with limits to avoid being a major source under the New Source Review Program and Part 70 Permit Program and to avoid being a major source of HAP emissions. The National Emission Standards for Hazardous Air Pollutants: Engine Test Cells/Stands 40 CFR Part 63 Subpart PPPPP does not apply to this facility as it is not a major source of HAP emissions. 4

5 TABLE A: LIMITS AND OTHER REQUIREMENTS 03/30/04 Facility Name: Polaris Industries Inc - Wyoming Permit Number: Table A contains limits and other requirements with which your facility must comply. The limits are located in the first column of the table (What To do). The limits can be emission limits or operational limits. This column also contains the actions that you must take and the records you must keep to show that you are complying with the limits. The second column of Table A (Why to do it) lists the regulatory basis for these limits. Appendices included as conditions of your permit are listed in Table A under total facility requirements. Subject Item: Total Facility What to do This permit establishes limits on the facility to keep it a minor source under 40 CFR Section 52.21, 40 CFR Section 70.2, and 40 CFR Section The Permittee can not make any changes at the source that would make the source a major source under 40 CFR Section 63.2 until a major amendment has been issued. This includes changes that might otherwise qualify as insignificant modifications and minor or moderate permit amendments. TOTAL EMISSIONS from the facility (operations such as: Coating, Engine Testing, Boiler Fuel Usage, and Emergency Generators) shall not exceed the limits stated below in any 12-month period: Carbon Monoxide (CO): 95 tons/yr Total Particulate Matter (PM): 95 tons/yr Particulate Matter less than 10 microns in size (PM10): 95 tons/yr Nitrogen Oxides (NOx): 95 tons/yr Sulfur Dioxide (SO2): 15.0 ton/yr Volatile Organic Compounds: 95 tons/yr Any Single HAP: 9.0 tons/yr All HAPs Combined: 23.0 tons /yr Why to do it Title I Condition: Limit to avoid classification as major source or modification under 40 CFR Section and under 40 CFR Section 63.2; and to avoid major source classification under 40 CFR Section 70.2 Title I Condition: Limit to avoid classification as major source or modification under 40 CFR Section and under 40 CFR Section 63.2; and to avoid major source classification under 40 CFR Section 70.2 Diesel Fuel Usage: less than or equal to 9,000 gallons/year using 12-month Rolling Sum Equipment Labeling: The Permittee shall permanently affix a unique number to each emissions unit for tracking purposes. The numbers shall correlate the unit to the appropriate EU and GP numbers used in this permit. The number can be affixed by placard, stencil, or other means. The number shall be maintained so that it is readable and visible at all times from a safe distance. Equipment Inventory List: The Permittee shall maintain a written list of each emission unit on site. The list shall include the type of equipment, manufacturer and model number (if available), unique ID number (assigned and affixed as required by this permit), the corresponding control equipment number used to control the unit (if applicable), and the dates of installation, modification, and construction. Title I Condition: Limit to avoid classification as major source or modification under 40 CFR Section and under 40 CFR Section 63.2; and to avoid major source classification under 40 CFR Section 70.2 Minn. R , subp. 2 Minn. R , subp. 2 The Permittee shall update the list to include any replaced, modified, or changed equipment prior to making the pre-authorized change. For equipment that is replaced, modified or changed, the Permittee shall complete an evaluation as detailed below and shall include a record of the evaluation as part of the equipment list. Equipment Inventory List continued: Minn. R , subp. 2 Prior to making the change, the Permittee shall determine and keep a record of the following: 1) Evaluate whether the permit contains all applicable requirements that would apply to the planned change and 2) Re-evaluate whether the facility will continue to comply with all permit limits (e.g. annual limits for Criteria Pollutants, HAP limits, Minn. R. ch. 7011, Standards of Performance, etc.) If the answer to either is "no", the Permittee shall apply for and obtain the appropriate permit amendment as required by Minn. R. ch These rule requirements may require that the permit amendment be issued prior to making the proposed change. A-1

6 TABLE A: LIMITS AND OTHER REQUIREMENTS 03/30/04 Facility Name: Polaris Industries Inc - Wyoming Permit Number: Changes: The Permittee may replace listed emission units (engine test stands), move emission units, or add new units similar to those listed in the groups, provided VOC, HAP, PM and PM less than 10 microns, NOx, and CO emissions are tracked and calculated directly from fuel usage, material usage and hours of operation (emergency generator only). All changes must meet the requirements idetified in the groups. If a proposed change triggers an applicable requirement that is not contained in this permit, the change must go through the apppropriate procedure in Minn. R. ch OPERATIONAL REQUIREMENTS 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. Air Pollution Control Equipment: Operate all pollution control equipment whenever the corresponding process equipment and emission units are operated, unless otherwise noted in Table A. 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 shall include a preventative maintenance program for that equipment, a description of (the minimum but not necessarily the only) corrective actions to be taken to restore the equipment 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 the records kept to demonstrate plan implementation. 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. 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 Noise: The Permittee shall comply with the noise standards set forth in Minn. R to at all times during the operation of any emission units. This is a state only requirement and is not enforceable by the EPA Administrator or citizens under the Clean Air Act. Inspections: The Permittee shall comply with the inspection procedures and requirements as found in Minn. R , subp. 9(A). The Permittee shall comply with the General Conditions listed in Minn. R , subp. 16. RECORDKEEPING Recordkeeping: The 12-month rolling sum (calculated by the 15th day of each month for the previous 12-month period as described in this permit) of CO, PM, PM10, NOx, and SO2 emissions for the previous 12-month period calculated by summing the monthly emissions data (based on fuel usage calculations: [emission factor x quantitiy of fuel]) for the previous 12 months for each pollutant. Title I Condition: Limit to avoid classification of described changes as major source or modification under 40 CFR Section and under 40 CFR Section 63.2; and to avoid major source classification under 40 CFR Section 70.2 hdr Minn. R Minn. R , subp. 2; Minn. R , subp. 16(J) Minn. R , subp. 14 and Minn. R , subp. 16(J) Minn. R , subp. 4 Minn. R Minn. R Minn. R , subp. 9(A) Minn. R , subp. 16 hdr Title I Condition: Recordkeeping for a limit to avoid classification as major source or modification under 40 CFR Section and 40 CFR Section 63.2; to avoid major source classification under 40 CFR Section 70.2 VOC, Single HAP, and Combined HAP emissions for the previous 12-month period by summing the monthly emissions data (based on daily records of VOC/HAP usage) for the previous 12 months for each pollutant. The 12-month rolling sum (calculated by the 15th day of each month for the previous 12-month period as described in this permit) of Diesel and Gasoline fuel used for the previous 12-month period calculated by summing the monthly fuel data for the previous 12 months for each fuel. Recordkeeping Continued...: Emission factors to be used from EPA's AP-42, Table 3.3-1, 10/96, until the most recent EPA's AP-42 emission factors are available, or emission factors based on site specific testing (already have been approved by the Commissioner). Title I Condition: Recordkeeping for a limit to avoid classification as major source or modification under 40 CFR Section and 40 CFR Section 63.2; to avoid major source classification under 40 CFR Section 70.2 If the Permittee wants to use a different emission factor for compliance, it needs to be approved by the Commissioner before the emission factor can be used. A-2

7 TABLE A: LIMITS AND OTHER REQUIREMENTS 03/30/04 Facility Name: Polaris Industries Inc - Wyoming Permit Number: 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 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). 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. REPORTING/SUBMITTALS Shutdown Notifications: Notify the Commissioner at least 24 hours in advance of a planned shutdown of any control equipment or process equipment if the shutdown would cause any increase in the emissions of any regulated air pollutant. If the owner or operator does not have advance knowledge of the shutdown, notification shall be made to the Commissioner as soon as possible after the shutdown. However, notification is not required in the circumstances outlined in Items A, B and C of Minn. R , 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. Breakdown Notifications: Notify the Commissioner within 24 hours of a breakdown of more than one hour duration of any control equipment or process equipment if the breakdown causes any increase in the emissions of any regulated air pollutant. The 24-hour time period starts when the breakdown was discovered or reasonably should have been discovered by the owner or operator. However, notification is not required in the circumstances outlined in Items A, B and C of Minn. R , subp. 2. Minn. R , subp. 5(C) Minn. R , subp. 5(B) hdr Minn. R , subp. 3 Minn. R , subp. 2 At the time of notification or as soon as possible thereafter, the owner or operator shall inform the Commissioner of the cause of the breakdown and the estimated duration. The owner or operator shall notify the Commissioner when the breakdown is over. Notification of Deviations Endangering Human Health or the Environment: As soon Minn. R , subp. 1 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. Notification of Deviations Endangering Human Health or the Environment Report: Minn. R , subp. 1 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. Application for Permit Amendment: If a permit amendment is needed, submit an Minn. R through Minn. R application in accordance with the requirements of Minn. R through Minn. R Submittal dates vary, depending on the type of amendment needed. Extension Requests: The Permittee may apply for an Administrative Amendment Minn. R , subp. 1(H) 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). Emission Inventory Report: due 91 days after end of each calendar year following Minn. R through Minn. R permit issuance (April 1). To be submitted on a form approved by the Commissioner. Emission Fees: due 60 days after receipt of an MPCA bill. Minn. R through Minn. R A-3

8 TABLE A: LIMITS AND OTHER REQUIREMENTS 03/30/04 Facility Name: Polaris Industries Inc - Wyoming Permit Number: Subject Item: Associated Items: GP 001 Engine Testing Stands EU 001 Engine Test Stand EU 002 Engine Test Stand EU 003 Engine Test Stand EU 004 Engine Test Stand EU 005 Engine Test Stand EU 006 Engine Test Stand EU 007 Engine Test Cell (Endurance 4 test stands) EU 008 Engine Test Stand EU 009 Engine Test Stand EU 010 Work Bay Engine Exhausts (Intermittent Use) What to do EMISSION LIMIT - Applies to each emission unit in this Group hdr Why to do it Opacity: less than or equal to 20 percent opacity once operating temperatures have Minn. R , subp. 1 been attained. Sulfur Dioxide: less than or equal to 0.5 lbs/million Btu heat input Minn. R , subp. 2 Fuel Type: Gasoline (includes Gasoline and 2-cycle oil mixtures) and Diesel only Minn. R , subp. 35a A-4

9 TABLE A: LIMITS AND OTHER REQUIREMENTS 03/30/04 Facility Name: Polaris Industries Inc - Wyoming Permit Number: Subject Item: GP 002 Boilers Associated Items: EU 012 Natural Gas Fired Boiler (#1) EU 013 Natural Gas Fired Boiler (#2) What to do Why to do it Total Particulate Matter: less than or equal to 0.4 lbs/million Btu heat input. PTE Minn. R , subp. 1 based on fuel type is less than this limit. Sulfur Dioxide: less than or equal to 2.0 lbs/million Btu heat input. PTE based on Minn. R , subp. 1 fuel type is less than this limit. Opacity: less than or equal to 20 percent opacity except for one six-minute period Minn. R , subp. 2 per hour of not more than 60 percent opacity. Fuel Type: Natural Gas, and Propane only. Minn. R , subp. 2 A-5

10 TABLE A: LIMITS AND OTHER REQUIREMENTS 03/30/04 Facility Name: Polaris Industries Inc - Wyoming Permit Number: Subject Item: EU 011 Coating Booth Associated Items: CE 001 Mat or Panel Filter SV 011 Coating Booth What to do Total Particulate Matter: less than or equal to 0.3 grains/dry standard cubic foot of exhaust gas unless required to further reduce emissions to comply with the less stringent limit of either Minn. R or Minn. R Opacity: less than or equal to 20 percent opacity Why to do it Minn. R , subp. 1(A) Minn. R , subp. 1(B) A-6

11 TABLE A: LIMITS AND OTHER REQUIREMENTS 03/30/04 Facility Name: Polaris Industries Inc - Wyoming Permit Number: Subject Item: EU 014 Emergency Generator (Diesel Fired) Associated Items: SV 014 Emergency Generator What to do Why to do it Opacity: less than or equal to 20 percent opacity once operating temperatures have Minn. R , subp. 1 been attained. Sulfur Dioxide: less than or equal to 0.5 lbs/million Btu heat input Minn. R , subp. 2 Fuel Type: Diesel only Fuel Supplier Certification: Obtain and maintain a fuel supplier certification for each shipment of diesel, certifying that the sulfur content does not exceed 0.05% by weight. Operating Hours: less than or equal to 500 hours/year using 12-month Rolling Sum to be calculated by the 15th day of each month. The Permittee shall maintain documentation on site that the unit is an emergency diesel generator by design that qualifies under the U.S. EPA memorandum entitled "Calculating Potential to Emit (PTE) for Emergency Generators" dated September 6, 1995, limiting operation to 500 hours per year. Minn. R , subp. 35a Minn. R , subps. 4 & 5 Minn. R , subp. 4 & 5 A-7

12 TABLE A: LIMITS AND OTHER REQUIREMENTS 03/30/04 Facility Name: Polaris Industries Inc - Wyoming Permit Number: Subject Item: CE 001 Mat or Panel Filter Associated Items: EU 011 Coating Booth What to do The Permittee shall operate and maintain the control equipment such that it achieves an overall control efficiency, for Total Particulate Matter: greater than or equal to 92 percent control efficiency The Permittee shall operate and maintain the control equipment such that it achieves an overall control efficiency, for Particulate Matter < 10 micron: greater than or equal to 92 percent control efficiency The Permittee shall operate and maintain the panel filters any time that any process equipment controlled by the panel filters is in operation. Daily Inspections: Once each operating day, the Permittee shall visually inspect the condition of each panel filter with respect to alignment, saturation, tears, holes and any other condition that may affect the filter's performance. The Permittee shall maintain a daily written record of filter inspections. Periodic Inspections: At least once per calendar quarter, or more frequently as required by the manufacturing specifications, the Permittee shall inspect the control equipment components. The Permittee shall maintain a written record of these inspections. Corrective Actions: If the filters or any of their components are found during the inspections to need repair, the Permittee shall take corrective action as soon as possible. Corrective actions shall include completion of necessary repairs identified during the inspection, as applicable. Corrective actions include, but are not limited to, those outlined in the O & M Plan for the filter. The Permittee shall keep a record of the type and date of any corrective action taken for each filter. Operation and Maintenance of Filters: The Permittee shall operate and maintain each filter in accordance with the Operation and Maintenance (O & M) Plan. The Permittee shall keep copies of the O & M Plan available onsite for use by staff and MPCA staff. Hood Certification and Evaluation: The control device hood must conform to the requirements listed in Minn. R , subp. 1, and the Permittee shall certify this as specified in Minn. R , subp. 3. The Permittee shall maintain a copy of the certification on site, as well as an annual record of fan rotation speed, fan power draw, or face velocity of each hood, or other comparable air flow indication method. Why to do it Title I Condition: Limit taken to avoid classification as a major source and modification under 40 CFR Section 52.21; Minn. R , subp. 2 and 14 Title I Condition: Limit taken to avoid classification as a major source and modification under 40 CFR Section 52.21; to avoid classification as a major source under 40 CFR Section 70.2; Minn. R , subp. 2 and 14 Title I Condition: Limit taken to avoid classification as a major source and modification under 40 CFR Section 52.21; to avoid classification as a major source under 40 CFR Section 70.2; Minn. R , subp. 2 and 14 Title I Condition: Monitoring for Limit taken to avoid classification as a major source and modification under 40 CFR Section 52.21; to avoid classification as a major source under 40 CFR Section 70.2; Minn. R , subp. 4 and 5 Minn. R , subp. 4, 5, and 14 Minn. R , subp. 4, 5, and 14 Minn. R , subp. 14 Minn. R , subp. 4, 5, and 14 A-8

13 TABLE B: SUBMITTALS Facility Name: Polaris Industries Inc - Wyoming Permit Number: /30/04 Table B lists most of the submittals required by this permit. Please note that some submittal requirements may appear in Table A or, if applicable, within a compliance schedule located in Table C. Table B is divided into two sections in order to separately list one-time only and recurrent submittal requirements. Each submittal must be postmarked or received by the date specified in the applicable Table. Those submittals required by parts 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 any application for a permit or permit amendment to: Permit Technical Advisor Permit Section Air Quality Division 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 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: Supervisor Compliance Determination Unit Air Quality Division Minnesota Pollution Control Agency 520 Lafayette Road North St. Paul, Minnesota 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 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 B-1

14 TABLE B: RECURRENT SUBMITTALS Facility Name: Polaris Industries Inc - Wyoming 03/30/04 Permit Number: What to send When to send Portion of Facility Affected Semiannual Deviations Report due 30 days after end of each calendar Total Facility half-year following Permit Issuance. The first semiannual report submitted by the Permittee shall cover the calendar half-year in which the permit is issued. The first report of each calendar year covers January 1 - June 30. The second report of each calendar year covers July 1 - December 31. If no deviations have occured, the Permittee shall submit the report stating no deviations. Annual Report due 30 days after end of each year following Total Facility Permit Issuance. The Permittee shall submit an annual report by January 30th of each year that describes the changes made at the facility during the previous calendar year using the lastest MPCA application forms (GI-04 and GI-05 Series). The report shall include the emission unit, stack/vent, group, and control equipment data for any new or replaced units or control devices. The report shall be submitted with the annual Compliance Certification listed in Table B. As part of the Annual Report, the Permittee shall verify and certify that the facility has maintained minor source status for New Source Review and Title V Permit Program. Compliance Certification due 31 days after end of each calendar year Total Facility following Permit Issuance (for the previous calendar year). To be submitted to the Commissioner on a form approved by the Commissioner. This report covers all deviations experienced during the calendar year. Equipment List due 30 days after end of each calendar year following Permit Issuance. If there are no changes to the facility, the Permittee shall submit the List stating that no changes were made to my facility. Total Facility B-2

15 TECHNICAL SUPPORT DOCUMENT For AIR EMISSION PERMIT NO This technical support document is intended for all parties interested in the draft permit and to meet the requirements that have been set forth by the federal regulations and Minn. R. (40 CFR, Section 70.7(a)(5) and Minn. R , subp.1). The purpose of this document is to provide the legal and factual justification for each applicable requirement or policy decision considered in the preliminary determination to issue the draft permit. 1. General Information 1.1. Applicant and Stationary Source Location: Applicant/Address Polaris Industries, Inc Highway 55 Medina, MN Contact: Jim Pederson (218) Stationary Source/Address (SIC Code: 3799) Polaris Industries, Inc. - Wyoming 7290 Viking Boulevard East Wyoming, MN Chisago County 1.2. Description of the Permit Action The primary sources of emissions at this facility are the engine test stands. Polaris will be testing primarily 4-stroke ATV, motorcycle or personal watercraft engines. Snowmobile engines may also be tested. All of these engines use gasoline or diesel. In addition, this facility will have a coating booth for research and development purpose, two natural gas fired units to provide building heat, and a diesel fired emergency generator. This is a state permit with limits to avoid being a major source under the New Source Review Program and Part 70 Permit Program and to avoid being a major source of HAP emissions. The National Emission Standards for Hazardous Air Pollutants: Engine Test Cells/Stands 40 CFR Part 63 Subpart PPPPP does not apply to this facility as it is not a major source of HAP emissions. Technical Support Document, Permit Action Number: Page 1 of 5, JSC Date: 4/19/2004

16 1.3. Facility Emissions: Table 1. Total Facility Potential to Emit Summary: Total Facility Limited Emissions PM tpy PM 10 tpy SO 2 tpy NO x tpy CO tpy VOC tpy Single HAP tpy All HAPs tpy Table 2. Facility Classification Classification Major/Affected Synthetic Minor Minor Source PSD PM, PM 10, SO 2, NO X, VOC, and CO Part 70 Permit Program PM 10, NO X, VOC, CO, and HAPs SO 2 2. Regulatory and/or Statutory Basis New Source Review Polaris Industries Inc. - Wyoming facility is a non-major source under New Source Review regulations. Part 70 Permit Program This facility is a non-major source under the Part 70 permit program. 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) This facility has accepted limits on HAP usage such that it is a non-major source under 40 CFR 63. Thus, no NESHAPs apply. Environmental Review Applicability: This permit limits the facility PTE below 100 tons per year for each of the criteria pollutants and HAPs; therefore, the Permittee is not required to prepare an Environmental Assessment Worksheet (EAW) or Environmental Impact Statement (EIS). Minnesota State Rules Technical Support Document, Permit Action Number: Page 2 of 5, JSC Date: 4/19/2004

17 Portions of the facility are subject to the following Minnesota Standards of Performance: Minn. R Standards of Performance for New Indirect Heating Equipment - Boilers Minn. R Standards of Performance for Post-1969 Industrial Process Equipment Coating Booth Minn. R Standards of Performance for Stationary Internal Combustion Engines Engine Test Stands TF, EU, GP, or CE TF Applicable Regulations Title I limit to avoid being a major source per 40 CFR 52.21, 40 CFR Section 70.2, and 40 CFR Section 63.2 (NESHAPs) Table 3. Regulatory Overview of Facility Comments: Limit set on PM, PM 10, SO 2, NO X, VOC, CO, and HAPs (see Table 1). GP 001 Minn. R Standards of Performance for Stationary Internal Combustion Engines; Limits for Sulfur Dioxide and Opacity. GP 002 Minn. R Standards of Performance for New Indirect Heating Equipment; Limits for Particulate Matter, Sulfur Dioxide and Opacity. EU 011 Minn. R Standards of Performance for New Industrial Process Equipment; Limits for Particulate Matter and Opacity. EU 014 Minn. R Standards of Performance for Stationary Internal Combustion Engines; Limits for Sulfur Dioxide and Opacity. Limits on Operating Hours < 500 per year. CE 001 Title I limit to avoid being a major source per 40 CFR 52.21, 40 CFR Section 70.2, and 40 CFR Section 63.2 (NESHAPs) Pollution Control Equipment Operation and Maintenance Requirements 3. Technical Information Technical Support Document, Permit Action Number: Page 3 of 5, JSC Date: 4/19/2004

18 3.1 Modeling The Permittee submitted modeling analysis for PM 10, SO 2, NO X, and CO emissions as outlined in form EC-03. The results of modeling shown that the worst-case impacts are below the EC-03 target values for each of the pollutants listed above. Note: EC-03 Ambient Impacts Analysis documents for this facility are in the AQ files. 3.2 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: Summary of the periodic monitoring requirements for those emission units for which the monitoring required by the applicable requirement is nonexistent or inadequate: VOC/HAP emissions limit - Daily records of VOC/HAP usage. Diesel and Gasoline Usage Monthly fuel data 3.3 Insignificant Activities Miscellaneous space heaters, welding booths, fuel storage tanks each with potential VOC emissions less than 2000 pounds, and miscellaneous parts washers. 3.4 Permit Organization In general, the permit meets the MPCA Delta Guidance for ordering and grouping of requirements. 3.5 Comments Received: The Mille Lacs Band of Ojibwe Indians sent a letter encouraging Polaris Industries, Inc., operate their facility in an environmentally friendly manner. Note: The MPCA staff will send a response to the commenter that the Permittee was notified of their comments on the draft permit public notice. 4. Conclusion Technical Support Document, Permit Action Number: Page 4 of 5, JSC Date: 4/19/2004

19 Based on the information provided by Polaris Industries, Inc., the MPCA has reasonable assurance that the proposed operation of the emission facility, as described in the Air Emission Permit No and this technical support document, will not cause or contribute to a violation of applicable federal regulations and Minnesota Rules. Staff Members on Permit Team: John Chikkala (permit engineer) Betsy Randt (enforcement) Toni Volkmeier (peer reviewer) Attachments: 1. PTE Summary and Calculation Spreadsheets 2. Facility Description and CD-01 Forms Technical Support Document, Permit Action Number: Page 5 of 5, JSC Date: 4/19/2004