Technical Support Document for Draft Air Emission Permit No

Transcription

1 Technical Support Document for Draft Air Emission Permit No This technical support document (TSD) is intended for all parties interested in the draft 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 , 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 preliminary draft permit. 1. General information 1.1 Applicant and stationary source location Table 1. Applicant and source address Applicant/Address Henkel Corporation 1 Henkel Way Rocky Hill, Connecticut Contact: Dave Bance Phone: ext5408 Stationary source/address (SIC Code: Electronic Components, Not Elsewhere Classified) Bergquist Co - Cannon Falls 301 Washington St W Cannon Falls, MN Facility description The Bergquist Company manufactures silicone rubber insulation products. The process involves silicone milling, dispersion mixing, web coating, parts cleaning, and assembly operations. The following emission units have total enclosure: Tower Coater PX-1, Tower Coater PX-2, Lab Coater PX-3, Drum Mixing Area, and Primer Coater/Laminator (PX-4). The facility has four thermal oxidizers that control emissions from the coating lines and drum mixing area. The emission units are routed to the thermal oxidizers as follows: - Tower Coater PX-1 (EQUI 2) - Thermal Oxidizer (TREA 3 and TREA 4) - Tower Coater PX-2 (EQUI 4) - Thermal Oxidizer (TREA 1) - Lab Coater PX-3 (EQUI 3) and Primer Coater/Laminator PX-4 (EQUI 1) - Thermal Oxidizer (TREA 7) - Drum Mixing Area (EQUI 5) - Thermal Oxidizer (TREA 3) The thermal oxidizers are required to maintain an overall control efficiency for Volatile Organic Compounds (VOC) and Hazardous Air Pollutants (HAP) of greater than or equal to 95 percent. In order to achieve this control efficiency on a continuous basis, the thermal oxidizers are required to maintain minimum combustion temperatures that are set based on compliant performance tests. HAPs of concern from this facility include xylene, toluene, glycol ether, and ethyl benzene. 1.3 Description of the activities allowed by this permit action This permit action is a Part 70 Reissuance. In addition to updates listed in Section 1.6, this permit action includes the following three items: 1. Incorporate notification for replacement of control equipment, thermal oxidizer (TREA 5), with a higher efficiency regenerative thermal oxidizer (TREA 7). 2. Incorporate reopenings initiated by the MPCA to revise minimum thermal oxidizer temperature limits based on approved performance tests. 3. Incorporate an administrative amendment for a one-time 120-day deadline extension of a performance test to measure the VOC destruction efficiency of TREA 5. Subsequent to the

2 extension request and prior to the revised test due date, TREA 5 was replaced by TREA 7. Following initial startup of TREA 7, a performance test is to be conducted for VOC destruction efficiency. 1.4 Description of notifications and applications included in this action Table 2. Notifications and applications included in this action Date received Application/Notification type and description 03/02/2018 Notification Replacement of air pollution control Equipment with listed control equipment 11/03/2017 Administrative Amendment (IND ) 09/12/2016 Part 70 Reissuance (IND ) 1.5 Facility emissions Table 3. Total facility potential to emit summary PM tpy PM10 tpy PM2.5 tpy SO2 tpy NOx tpy CO tpy CO2e tpy VOC tpy Single HAP tpy All HAPs tpy Total facility limited potential emissions , Total facility actual emissions (2016) * 7.55 * *Not reported in Minnesota emission inventory. Table 4. Facility classification Classification Major Synthetic minor/area Minor/Area New Source Review X Part 70 X Part 63 X 1.6 Changes to permit The MPCA has a combined operating and construction permitting program under Minnesota Rules Chapter 7007, and under Minn. R , the MPCA has the authority to include additional requirements in a permit. Under that authority, the following changes, in addition to those discussed previously in Section 1.3 are made through this permit action: New equipment identification for Tempo (MPCA s new database). Attachment 4 to this TSD contains a table of the identifications from Delta (MPCA s previous database) and from Tempo. The permit has been updated to reflect current MPCA templates and standard citation formatting. Updated general requirements at the Total Facility Level. Corrected typos. Replaced TREA 5, a thermal oxidizer, with TREA 7, a thermal oxidizer with heat exchanger. A notification for this replacement, replacement of a control equipment with listed control equipment, was received March 2, Relocated requirements that are applicable to each subject item individually, but were previously housed in GP 001, GP 002, and GP 003. These requirements have been moved to the applicable EQUI or TREA subject item. GP 002 and GP 003 have been removed. GP 001 is now COMG 1. Some requirements have been reordered to help with clarity.

3 Updated VOC content of applied materials (Appendix B). Monitoring conditions for the thermal oxidizer temperature limits were revised to contain a protocol for re-setting the limit via an Approved Replicable Methodology, or ARM. (discussed further in Section 3.3) Moved monthly HAP emission calculation equations to COMG 1 from Appendix I. Removed monthly VOC calculation equations because there is no annual VOC emissions cap for which the calculation would be needed. Added HAP to the thermal oxidizer temperature limit at each thermal oxidizer such that the requirement now reads: If the recorded 3-hour rolling average temperature is below the Minimum Temperature Limit, the VOC and HAP used during that time shall be considered uncontrolled until the average temperature is above the Minimum Temperature Limit... This has been changed because the TOs also control HAP emissions from the coating operations. Corrected total enclosure monitoring requirement. The previous requirement stated readings equal to or greater than 0.0 inches indicates a proper negative pressure is being maintained; however, negative pressure is maintained when the pressure differential gauges read negative. Therefore, the requirement has been corrected to readings less than 0.0 inches indicates a proper negative pressure is being maintained. Added annual HAP emissions report and certification that the Facility maintained area source status under 40 CFR pt. 63 for the previous year to COMG 1. Discussed further in Section 2.4. Updated 40 CFR pt. 60, subp. VVV quarterly/semiannual reporting requirement to improve clarity. This requirement exists at each TREA. 2. Regulatory and/or statutory basis 2.1 New source review (NSR) The permit carries forward federally-enforceable conditions limiting the Potential to Emit (PTE) of volatile organic compounds (VOCs) from the coating and mixing operations. These limits are in the form of control efficiency requirements and are in place to ensure the facility will remain a minor source under NSR. EQUI 1 through EQUI 5 each have a Title I condition of total enclosure with 95% destruction efficiency to avoid major source classification. For the overall facility using these restrictions, calculations demonstrate that the total facility limited PTE for VOCs is 146 tpy. Hence, it is not plausible for the facility to exceed the PSD threshold of 250 tpy. This is supported by 2016 actual VOC emissions of 7.55 tpy. 2.2 Part 70 permit program The facility is a major source under the Part 70 permit program because limited potential emissions of VOCs are above the 100 tpy threshold. 2.3 New source performance standards (NSPS) The facility operates mixing, coating, and drying process equipment that are subject to 40 CFR pt. 60 subp. VVV, Standards of Performance for Polymeric Coating of Supporting Substrate Facilities. Affected facilities are Primer Coater/Laminator (EQUI 1), Tower Coater #2 (EQUI 4), and the Drum Mixing Station (EQUI 5), which were constructed, modified, or reconstructed after April 30, The Tower Coater #1 (EQUI 2) and Lab Coater (EQUI 3) are not subject to this NSPS because they were constructed and in operation prior to April 30, EQUI 1, EQUI 4, and EQUI 5 are subject to NSPS requirements of total enclosure with 95% destruction efficiency. Lab Coater The TSD to the 2006 total facility operating permit No explains that the Lab Coater (EQUI 3) was constructed or under contract prior to April 30, However, the 2006 permit goes on to discuss that

4 the initial Part 70 operating permit subjects the Lab Coater to 40 CFR pt. 60, subp. VVV without explanation as to why. Permit No carried forward requirements implying that the Lab Coater was subject to sub. VVV. An investigation into the history of the Lab Coater confirmed that EQUI 3 was constructed prior to April 30, 1987 and has not been modified or reconstructed after such date; therefore, the Lab Coater is not subject to the requirements of subp. VVV. Furthermore, while the Lab Coater is not subject to subp. VVV, the associated thermal oxidizer is subject to the requirements of subp. VVV because the control equipment also receives emissions from the Primer Coater/Laminator (EQUI 1) which is subject to the NSPS. 2.4 National emission standards for hazardous air pollutants (NESHAP) The facility accepted limits on HAP emissions such that it is an area source under 40 CFR pt. 63. Thus, no major source NESHAPs apply. In addition, the Permittee has stated that no area source NESHAPs apply to the facility. 2.5 Compliance assurance monitoring (CAM) The table below lists the sources subject to CAM, the control equipment used, whether the source is a large or other pollutant-specific emissions unit (PSEU), and the pollutants triggering CAM. Table 5. CAM summary Unit Control CAM applicability Pollutant EQUI 1 TREA 7 Regenerative Thermal Oxidizer Other HAP single/hap total/voc EQUI 3 TREA 7 Regenerative Thermal Oxidizer Other HAP single/hap total EQUI 2 TREA 3 Thermal Oxidizer (50% flow) Other HAP single/hap total/voc TREA 4 Thermal Oxidizer (50% flow) EQUI 4 TREA 1 Thermal Oxidizer Other HAP single/hap total/voc EQUI 5 TREA 3 Thermal Oxidizer Other HAP single/hap total/voc For large pollutant specific emission units, records of the monitored parameter must be made at a minimum of four times per hour, or once every 15 minutes. For other PSEUs (not large), records must be made at a minimum of once per 24 hours. For each thermal oxidizer there is continuous temperature monitoring and recordkeeping, daily operational checks, corrective actions requirements, periodic inspections, and maintenance requirements. See Attachment 3 to this document for the CAM Plan submitted by the applicant. 2.6 Regulatory overview Table 6. Regulatory overview of facility Subject item* Applicable Regulations Rationale COMG 1 - Air Component Group EQUI 1 and EQUI 4 - Coating Lines Title I Condition: Avoid major source under 40 CFR 63 Title I limits on single and total HAP emissions to avoid major source classification under the NESHAP program. 40 CFR pt. 60 subp. VVV Standards of Performance for Polymeric Coating of Supporting Substrates. These coating lines were constructed after April 30, 1987, therefore, they are subject to 40 CFR pt. 60, subp. VVV. Each of these affected facilities use more than 95 Mg of VOCs per 12-month period and are defined as coating operations under the standard. 40 CFR and 40 CFR 63.2 PSD and NESHAPs. To avoid major source classification under PSD and NESHAP, total enclosure and venting requirements related to emission caps for VOCs and HAPs.

5 Subject item* Applicable Regulations Rationale EQUI 2 and EQUI 3 - Coating Lines EQUI 5 - Mixing Equipment TREA 1 and TREA 3 22 Direct Flame Afterburner 40 CFR pt. 64 Compliance Assurance Monitoring (CAM): These emissions units: are subject to a standard or emission limit, uses a control device to meet the standard, Minn. R CFR and 40 CFR 63.2 have a pre-controlled PTE of HAP and VOC greater than the major source threshold, and have post-controlled PTE less than the major source threshold, therefore, an other PSEU. Standards of Performance for Post 1969 Industrial Process Equipment. There is no other standard of performance that has been promulgated for these units and the units were not in operation before July 9, The facility was constructed in PSD and NESHAPs. To avoid major source classification under PSD and NESHAP, total enclosure and venting requirements related to emission caps for VOCs and HAPs. 40 CFR pt. 64 Compliance Assurance Monitoring (CAM): These emissions units: are subject to a standard or emission limit, uses a control device to meet the standard, have a pre-controlled PTE greater than the major source threshold for HAP (EQUI 2 and 3) and VOC (EQUI 2 only), and have post-controlled PTE less than the major source threshold, therefore, an other PSEU. 40 CFR pt. 60 subp. VVV Standards of Performance for Polymeric Coating of Supporting Substrates. The drum mixing area was constructed after April 30, 1987, therefore, it is subject to 40 CFR pt. 60, subp. VVV. This affected facility uses more than 95 Mg of VOCs per 12- month period and is defined as coating mix preparation equipment under the standard. 40 CFR and 40 CFR 63.2 PSD and NESHAPs. To avoid major source classification under PSD and NESHAP, total enclosure and venting requirements related to emission caps for VOCs and HAPs. 40 CFR pt. 64 Compliance Assurance Monitoring (CAM): This emissions unit: is subject to a standard or emission limit, uses a control device to meet the standard, has a pre-controlled PTE of HAP and VOC greater than the major source threshold, and has post-controlled PTE less than the major source threshold, therefore, an other PSEU. 40 CFR pt. 60 subp. VVV Standards of Performance for Polymeric Coating of Supporting Substrates. Emission units that vent to these thermal oxidizers are affected facilities under 40 CFR pt. 60, subp. VVV and requires 95% control efficiency for VOCs.

6 Subject item* Applicable Regulations Rationale TREA Direct Flame Afterburner TREA Direct Flame Afterburners w/ Heat Exchanger 40 CFR and 40 CFR 63.2 PSD and NESHAPs. Requirements to operate control equipment and meet capture and destruction efficiencies to reduce VOC and HAP emissions to avoid major source status under New Source Review and National emission Standards for Hazardous Air Pollutants, respectively. 40 CFR pt. 64 CAM: Requirements to operate and maintain control equipment that receives emissions from at least one emission unit that is subject to CAM. Minn. R , subp. 35a Allowed fuels to support PTE calculations. 40 CFR and 40 CFR 63.2 PSD and NESHAPs. Requirements to operate control equipment and meet capture and destruction efficiencies to reduce VOC and HAP emissions to avoid major source status under New Source Review and National emission Standards for Hazardous Air Pollutants, respectively. 40 CFR pt. 64 CAM: Requirements to operate and maintain control equipment that receives emissions from at least one emission unit that is subject to CAM. Minn. R , subp. 35a Allowed fuels to support PTE calculations. 40 CFR pt. 60 subp. VVV Standards of Performance for Polymeric Coating of Supporting Substrates. Emission units that vent to these thermal oxidizers are affected facilities under 40 CFR pt. 60, subp. VVV and equires 95% control efficiency for VOCs. 40 CFR and 40 CFR 63.2 PSD and NESHAPs. Requirements to operate control equipment and meet capture and destruction efficiencies to reduce VOC and HAP emissions to avoid major source status under New Source Review and National emission Standards for Hazardous Air Pollutants, respectively. 40 CFR pt. 64 CAM: Requirements to operate and maintain control equipment that receives emissions from at least one emission unit that is subject to CAM. Minn. R , subp. 35a Allowed fuels to support PTE calculations. *Location of the requirement in the permit (e.g., EQUI 1, STRU 2, etc.). 3. Technical information 3.1 Performance Tests Table 7 presents the results of the most recent performance tests to measure VOC destruction efficiency in the thermal oxidizers. Also included in Table 7 are the established test frequencies and the minimum temperature limits. As discussed below in Section 3.3, approved replicable methodology requirements have been included in the permit as the mechanism for future revisions to the thermal oxidizer temperature limit. Table 7. Performance Tests Results and Minimum Temperature Limits for Thermal Oxidizers Control Equipment ID Date Performed VOC Destruction Efficiency Required VOC Destruction Efficiency Achieved Observed Temperature ( F) Established Test Frequency Minimum Temperature Limit ( F) TREA 1 11/16/ % 99.4% Months 1270 TREA 3 11/18/ % 98.4% Months 1235 TREA 4 11/17/ % 97.9% Months 1425 TREA 7 5/1/ % 98.9% Months 1385 Thermal Oxidizer Minimum Combustion Temperature Limit

7 40 CFR Section (d)(4), NSPS Subpart VVV allows for the thermal oxidizer combustion temperature to be 28 degrees Celsius below the average combustion temperature observed during the most recent performance test. However, to demonstrate ongoing compliance with the Title I limits to avoid major source designation under 40 CFR 52.21(b)(1)(i) and 40 CFR 63.2, minimum temperature limits have been established a few degrees below the combustion temperature that was observed during the compliant performance test, as shown in Table 7. The 28 degree Celsius variance allowed by the NSPS does not apply to the Title I minimum temperature limits. VOC and HAP Destruction Efficiency The VOC destruction efficiency for these thermal oxidizers is representative of the destruction efficiency of the HAPs used in this facility. HAPs used at this facility include xylene, toluene, glycol ether, and ethylbenzene. Toluene has the highest autoignition temperature of these HAPs at 896 F and is therefore the most resilient to oxidation. The minimum operating temperature for the thermal oxidizers at the facility is in excess of 300 F above the autoignition temperature of toluene. Because the thermal oxidizers operate at temperatures at least 200 F to 300 F above the autoignition temperature of the most difficult to oxidize compound, it is a reasonable assumption that the destruction efficiency achieved for VOCs is representative of the HAP destruction efficiency. 3.2 Calculations of potential to emit (PTE) Attachment 1 to this TSD contains detailed spreadsheets and supporting information, which summarizes the emissions of the facility, prepared by the MPCA and the Permittee. Changes to PTE from the previous permit renewal is a result of refining the calculation methodology and not due to changes or modifications at the facility. The one exception to this is a slight reduction in PTE due to the replacement of TREA 5, which had a burner capacity of 4.2 MMBtu/hr, with TREA 7, which has a burner capacity of 1 MMBtu/hr. Coating Lines Maximum coating usage is the result of many process characteristics including maximum coating area, maximum substrate feed rate, and maximum coating thickness. These parameters can vary for each coating material used. Bergquist submitted PTE calculations from the coating operations for the combination of coating materials and maximum application rates for each coating line that would result in the highest potential emissions for each pollutant. The calculations assume continuous operation, i.e., 8760 hours/year, and all HAPs and VOCs contained in the applied coating materials are emitted during the coating process. The resulting VOC application rates based on the assumptions for the highest emitting combination of coating application rate and coating pollutant content are contained in Appendix B of the permit. The Permittee operates total enclosures around the coating lines and emissions are controlled by thermal oxidizers that achieve a minimum destruction efficiency of 95%. Mixing Equipment Section of AP-42, fifth edition addresses emissions from the portion of total solvent that evaporates during the mixing process. In the absence of a measured value for a liquid balance across the mixing area, a value of 10 percent of the total solvent entering the mixing area can be assumed emitted during the mixing process. Solvent emitted from the mixing process is captured by a total enclosure that is maintained around the mixing area and controlled by a thermal oxidizer with a minimum destruction efficiency of 95%. 3.3 Monitoring In accordance with the Clean Air Act, it is the responsibility of the owner or operator of a facility to have sufficient knowledge of the facility to certify that the facility is in compliance with all applicable requirements.

8 In evaluating the monitoring included in the permit, the MPCA considered the following: the likelihood of the facility violating the applicable requirements; whether add-on controls are necessary to meet the emission limits; the variability of emissions over time; the type of monitoring, process, maintenance, or control equipment data already available for the emission unit; the technical and economic feasibility of possible periodic monitoring methods; and the kind of monitoring found on similar units elsewhere. Table 8 summarizes the monitoring requirements. Table 8. Monitoring Subject Item* COMG 1 HAP Sources EQUI 1, EQUI 2, EQUI 3, EQUI 4, EQUI 5, EQUI 2 and EQUI 3 Requirement (basis) Single HAP less than or equal to 9.0 tpy, and total HAP less than or equal to 22.5 tpy 12- month rolling sum basis (Title I Limits to avoid part 63 major source levels) Total enclosure requirements (Title I Requirement to avoid part 63 major source, 40 CFR Section and for EQUI 1- EQUI 4, required by part 60, subp. VVV) Particulate matter less than or equal to 0.30 grains per dry standard cubic foot Opacity less than or equal to 20% (Minn. R , subp. 1) What is the monitoring? Daily recordkeeping of material usage with monthly calculation of emissions Daily monitoring and recordkeeping of pressure differential and proper operation of self-closing doors None Why is this monitoring adequate? Daily records of material usage with a monthly calculation of the 12-month rolling sum will ensure that the limit is met. HAP content of materials used will be determined from Material Safety Data Sheets (MSDS). Monitoring of pressure differential indicates proper negative pressure is maintained for the total enclosures. Daily pressure monitoring and inspection of self-closing doors compliments the design requirements of the enclosure to ensure that a total enclosure is maintained and all pollutants are routed to the control equipment. Units are web coating operations in which a substrate is rolled through a bath of coating material and the solvent is driven off in an electric oven. Based on the nature of this operation, the likelihood of creating airborne particulate matter is very small with almost no potential of violating the limit.

9 Subject Item* TREA 1, TREA 3, TREA 4, TREA 7 Requirement (basis) What is the monitoring? Why is this monitoring adequate? 95% destruction efficiency for VOCs and HAPs. (Title I Limit to avoid part 63 major source, 40 CFR Section 52.21, and required by 40 CFR Part 60, subp. VVV) Thermal oxidizer temperature monitoring, O & M, inspections, calibration, corrective actions, and performance tests TREA 1, 3, 4, and 7 are other PSEUs, so they are subject to monitoring at least 1 time per 24-hour period. This is accomplished using continuous temperature monitoring. In addition, performance testing for control efficiency is required every 5 years based on MPCA guidance and previous testing on these thermal oxidizers. Compliance with the control efficiency limit and the temperature limit were verified during the last MPCA approved performance tests performed between November 16 and 18, 2015 for TREA 1, TREA 3, and TREA 4. For TREA 7, compliance with the control efficiency limit was verified and the temperature limit was established during the most recent MPCA performance test on May 1, Monitoring based on the Minnesota Performance Standard for Control Equipment and the approved CAM plan is adequate to have a reasonable assurance of compliance. ARM per MPCA guidance, when the initial control equipment parameter is known or can reasonably be determined upfront AND where the permit includes periodic testing which will re-set the parameter, the permit should contain the limit as well as an ARM for revising the limit through testing. In this instance, as long as the Permittee is implementing the ARM as required by the permit, the permit does not need to be reopened to revise the control equipment parameter limit. The Notice of Compliance that approves the new limit using an ARM will be filed with the permit in OnBase. Every level of permit action (from admin to major) can be used to incorporate revised parameter limits that were approved via an ARM. The establishment or revision of the ARM requires a major amendment process under Minn. R , likely triggering one or all of: subp. 1(A) (revision to monitoring), 1(B) (case-by-case limit), and 1(C) (used for assuring compliance with a limit taken to avoid an applicable requirement). *Location of the requirement in the permit (e.g., EQUI 1, STRU 2, etc.). 3.4 Insignificant activities Bergquist Co - Cannon Falls has several operations which are classified as insignificant activities under the MPCA s permitting rules. These are listed in Appendix A to the permit. The permit is required to include periodic monitoring for all emissions units, including insignificant activities, per EPA guidance. The insignificant activities at this Facility are only subject to general applicable requirements. Using the criteria

10 outlined earlier in this TSD, the following table documents the justification why no additional periodic monitoring is necessary for the current insignificant activities. Table 9. Insignificant activities Insignificant activity Infrared electric ovens Storage tanks: nonhazardous air pollutant VOC storage tanks with a combined total tankage capacity of 10,000 gallons or less and a vapor pressure of 1.0 psia or less at 60 F. Emissions from a laboratory, as defined in Minn. R , subp. 3(G) Individual units with potential emissions less than 2000 lb/year of certain pollutants General applicable emission limit PM, variable depending on airflow Opacity <= 20% (Minn. R ) PM, variable depending on airflow, Opacity <= 20% (Minn. R ) PM, variable depending on airflow Opacity <= 20% (Minn. R ) PM, variable depending on airflow Opacity <= 20% (with exceptions) (Minn. R ) or PM <= 0.4 lb/mmbtu Opacity <= 20% (with exceptions) (Minn. R ) PM, variable depending on airflow Opacity <= 20% (Minn. R Discussion Bergquist has five infrared electric ovens for curing. These units are not likely to have any emissions of particulate matter (used to dry off VOCs) and do not emit VOCs themselves. Emissions from the curing process are encompassed by the coating line emission units contained in the permit. It is highly unlikely that they could violate the applicable requirement. Bergquist has one 2,000 gallon nonhazardous air pollutant VOC storage tank containing mineral spirits. There are no standards of performance promulgated under Minn. R , Standards of Performance for Storage Vessels, for storage vessels with a storage capacity of 2,000 gallon or less. Therefore, Minn. R applies. Due to the nature of storage vessels, the tank is not expected to emit particulate matter or exhibit opacity. These are very small, intermittent, bench-top operations that typically do not have emissions and include tests such as viscosity analyses. It is highly unlikely that they could violate the applicable requirement. Bergquist operates 3 space heaters and 12 HVAC units fueled by natural gas. Individually, potential emissions from these units are under the thresholds in Minn. R , subp. 3(I), but have a combined heating capacity over 420,000 Btu per hour. For these units, based on the fuels used and EPA published emissions factors, it is highly unlikely that they could violate the applicable requirement. Bergquist has one 2000 gallon storage tank containing 65% xylene, 20% ethylbenzene, and 15% naphtha with potential emissions under thresholds in Minn. R , subp. 3(I). There are no standards of performance under Minn. R for storage vessels with a storage capacity of 2,000 gallons or less. Due to the nature of a storage vessel, it is highly unlikely that they could violate the applicable requirement. PM, variable depending on airflow Opacity <= 20% (Minn. R ) Bergquist has six parts washers, each with potential emissions under the thresholds in Minn. R , subp. 3(I). Due to the nature of emissions from the parts washers, it is highly unlikely they could violate the applicable standard.

11 Insignificant activity Fugitive dust emissions from unpaved entrance roads and parking lots Infrequent use of spray paint equipment for routine housekeeping or plant upkeep activities not associated with primary production processes at the stationary source Equipment venting PM/PM10 inside a building, provided that emissions from the equipment are: a) filtered through an air cleaning system; and b) vented inside of the building 100% of the time General applicable emission limit Opacity <= 20% (Minn. R ) PM, variable depending on airflow Opacity <= 20% (Minn. R ) Requirement to take reasonable measures to prevent PM from becoming airborne (Minn. R ) PM, variable depending on airflow Opacity <= 20% (Minn. R ) PM, variable depending on airflow Opacity <= 20% (Minn. R ) Discussion Bergquist uses small amounts of isopropanol for wipe cleaning. Due to the nature of this activity emissions from infrequent isopropanol use for cleaning, it is highly unlikely they could violate the applicable standard. Bergquist operates a laser to cut films before packaging. Due to the nature of the laser cutting process, it is unlikely they could violate the applicable standard. The Facility has paved parking lots and few private roads. Nearly all surfaces are currently paved. The permit does contain a general requirement that this standard must be met. It is unlikely that any additional unpaved surfaces will be added in the future. While spray equipment will have the potential to emit particulate matter, these particular activities are those not associated with production, so they would be infrequent and usually occur outdoors. Testing or monitoring is not feasible. For the powder handling equipment controlled with cyclone and baghouse, it is highly unlikely that they could violate the applicable requirement. In addition, these units are vented inside a building, so testing for PM or opacity is not feasible. 3.5 Permit organization In General, this permit meets the MPCA Tempo Guidance for ordering and grouping of requirements as well as the use of permit appendices. In this permit, federal requirements from the NSPS are included in two different formats. The requirements for 40 CFR pt. 60, subp. VVV are incorporated into the permit as individual permit requirements, which has historically been MPCA s standard practice. However, the NSPS general requirements, 40 CFR pt. 60, subp. A are included in a different way. For this rule, limits and submittal/actions are included individually in the permit like other standards. For the remaining portions of the rule, a requirement in Section 5 of the permit lists the citations of all applicable parts of the standard along with a reference to the permit appendix where the full text of the standard is included. 40 CFR pt. 60, subp. A is included in Appendix C. 3.6 Comments received This section will be completed after the reference review periods. Public Notice Period: [start date] [end date] EPA 45-day Review Period: [start date] [end date] 4. Permit fee assessment

12 This permit action is the reissuance of an individual Part 70; therefore, no application fees apply under Minn. R , subp. 1. Reopenings that are rolled into this permit action are not charged to the Permittee nor do they result in additional points. The administrative amendment for a 120-day deadline extension did not result in additional points beyond the application fee that has already been paid by the Permittee. Finally, the notification for replacement of control equipment with listed control equipment also does not result in additional points. 5. Conclusion Based on the information provided by Bergquist Co - Cannon Falls the MPCA has reasonable assurance that the proposed operation of the emission facility, as described in the Air Emission Permit No and this TSD, will not cause or contribute to a violation of applicable federal regulations and Minnesota Rules. Staff members on permit team: Owen Seltz (permit engineer) Adriane Lorsung (peer reviewer) Jenna Ness (enforcement) Curtis Stock (compliance) Beckie Olsen (permit writing assistant) Michaela Leach (data coordinator) Laurie O'Brien (administrative support) TEMPO360 Activities: Permit Reopening, Notification of Replacement of Controls, Administrative Amendment (IND ), Part 70 Reissuance (IND ) Attachments: 1. PTE summary and calculation spreadsheets 2. Subject item inventory and facility requirements 3. CAM Plan submitted by Bergquist Co. 4. Mapped IDs from Delta to Temp

13 Attachment 1 PTE summary and calculation spreadsheet

14 Emissions Calculations Spreadsheet AQ Facility ID No AQ File No Facility Name The Bergquist Company Total Facility PTE Pollutant PM PM 10 PM 2.5 SO 2 NO x CO CO 2 e VOC Single HAP* Total HAP* Total Facility Limited Potential Emissions (TPY) , Total Facility Limited Potential Emissions Pre , Modification (TPY) Emissions Change** , *HAP emissions from coating lines are limited to 9 tpy of any single HAP and 22.5 tpy of Total HAPs. **Emission change is due to replacement of TREA 5 having a burner capacity of 4.2 MMBtu/hr with TREA 7 having a burner capacity of 1 MMBtu/hr Notes: Changes to PTE from previous permit renewals is a result of refinement to coating line emission calculation methodology and not due to changes or modifications at the facility, other than replacement of one thermal oxidizer (TREA 5 with TREA 7). The calculation follows the printing emissions formula for "Sheet-fed" processes ( where: - the sheet area (C) is fixed at 1 square foot, and - maximum speed (S) is expressed in square feet per hour Coating materials used in the HAPs/VOCs emissions calculations represent the materials that generate the maximum uncontrolled potential emissions.

15 Thermal Oxidizers w/propane (backup fuel) The Bergquist Company, Cannon Falls PM/PM 10/PM2.5 Burner Capacity (MMBtu/hr) Heating Value, Propane 1 (MMBtu/10 3 gal) Emission factor 2 (lb/10 3 gal) Hourly PTE (lbs/hr) Annual PTE 3 (tpy) TREA 4 (CE001) TREA 1 (CE002) TREA 5 (CE003) TREA 3 (CE005) TREA Sum of PM/PM10/PM2.5 (pre-mod) Sum of PM/PM10/PM2.5 (post-mod) SO2 Burner Capacity (MMBtu/hr) Heating Value, Propane 1 (MMBtu/10 3 gal) Emission factor 2 (lb/10 3 gal) Hourly PTE (lbs/hr) Annual PTE 3 (tpy) TREA 4 (CE001) TREA 1 (CE002) TREA 5 (CE003) TREA 3 (CE005) TREA sum S02 (pre-mod) sum S02 (post-mod) NOx Burner Capacity (MMBtu/hr) Heating Value, Propane 1 (MMBtu/10 3 gal) Emission factor 2 (lb/10 3 gal) Hourly PTE (lbs/hr) Annual PTE 3 (tpy) TREA 4 (CE001) TREA 1 (CE002) TREA 5 (CE003) TREA 3 (CE005) TREA Sum NOx (pre-mod) Sum NOx (post-mod) CO Burner Capacity (MMBtu/hr) Heating Value, Propane 1 (MMBtu/10 3 gal) Emission factor 2 (lb/10 3 gal) Hourly PTE (lbs/hr) Annual PTE 3 (tpy) TREA 4 (CE001) TREA 1 (CE002) TREA 5 (CE003) TREA 3 (CE005) TREA sum CO (pre-mod) sum CO (post-mod) VOC Burner Capacity (MMBtu/hr) Heating Value, Propane 1 (MMBtu/10 3 gal) Emission factor 2 (lb/10 3 gal) Hourly PTE (lbs/hr) Annual PTE 3 (tpy) TREA 4 (CE001) TREA 1 (CE002) TREA 5 (CE003) TREA 3 (CE005) TREA Sum VOC (pre-mod) Sum VOC (post-mod) AP-42, Section 1.5, Table 1.5-1, footnote a: Heat input conversion value for propane is 91.5 MMBtu/1000 gal. 2 AP-42, Section 1.5, Table 1.5-1: Emission factors for propane combustion with heat input capacities less than 10 MMBtu/hr. SO2 emission factor assumes sulfur content of 0.18 gr/100 cf. 3 Annual PTE based on continuous operation (8760 hrs/yr) and conversion of lbs to tons (2000 lbs/ton). 4 TREA 5 was replaced by TREA 7 since the last permit reissuance and its inclusion here is to describe the resulting emissions change. 5 Emissions of Lead calculated using NG emission factors since propane emission factors are not readily available. See "Thermal Oxidizers NG" tab for Lead emission calculations.

16 Thermal Oxidizers w/ Natural Gas (primary fuel) The Bergquist Company, Cannon Falls PM/PM 10/PM2.5 Burner Capacity (MMBtu/hr) Heating Value, NG 1 (Btu/scf) Emission factor 2 (lb/10 6 scf) Hourly PTE (lbs/hr) Annual PTE 3 (tpy) TREA 4 (CE001) TREA 1 (CE002) TREA 5 (CE003) TREA 3 (CE005) TREA Sum PM/PM10/PM2.5 (pre-mod) Sum PM/PM10/PM2.5 (post-mod) SO2 Burner Capacity (MMBtu/hr) Heating Value, NG 1 (Btu/scf) Emission factor 2 (lb/10 6 scf) Hourly PTE (lbs/hr) Annual PTE 3 (tpy) TREA 4 (CE001) TREA 1 (CE002) TREA 5 (CE003) TREA 3 (CE005) TREA sum S02 (pre-mod) sum S02 (post-mod) NOx Burner Capacity (MMBtu/hr) Heating Value, NG 1 (Btu/scf) Emission factor 2 (lb/10 6 scf) Hourly PTE (lbs/hr) Annual PTE 3 (tpy) TREA 4 (CE001) TREA 1 (CE002) TREA 5 (CE003) TREA 3 (CE005) TREA Sum NOx (pre-mod) Sum NOx (post-mod) CO Burner Capacity (MMBtu/hr) Heating Value, NG 1 (Btu/scf) Emission factor 2 (lb/10 6 scf) Hourly PTE (lbs/hr) Annual PTE 3 (tpy) TREA 4 (CE001) TREA 1 (CE002) TREA 5 (CE003) TREA 3 (CE005) TREA sum CO (pre-mod) sum CO (post-mod) VOC Burner Capacity (MMBtu/hr) Heating Value, NG 1 (Btu/scf) Emission factor 2 (lb/10 6 scf) Hourly PTE (lbs/hr) Annual PTE 3 (tpy) TREA 4 (CE001) TREA 1 (CE002) TREA 5 (CE003) TREA 3 (CE005) TREA Sum VOC (pre-mod) Sum VOC (post-mod) Lead Burner Capacity (MMBtu/hr) Heating Value, NG 1 (Btu/scf) Emission factor 2 (lb/10 6 scf) Hourly PTE (lbs/hr) Annual PTE 3 (tpy) TREA 4 (CE001) E E-05 TREA 1 (CE002) E E-05 TREA 5 (CE003) E E-06 TREA 3 (CE005) E E-05 TREA E E-06 Sum Lead (pre-mod) 1.2E E-05 Sum Lead (post-mod) 1.0E E-05 1 AP-42, Table 1.4-1, footnote a: Heat input conversion value for NG is 1,020 Btu/scf. 2 AP-42, Tables and 1.4-2: Emission factors for NG combustion for small boilers (<100 MMBtu/hr heat input). 3 Annual PTE based on continuous operation (8760 hrs/yr) and conversion of lbs to tons (2000 lbs/ton). 4 TREA 5 was replaced by TREA 7 since the last permit reissuance and its inclusion here is to describe the resulting emissions change.

17 Thermal Oxidizers w/ Natural Gas (primary fuel) The Bergquist Company, Cannon Falls Total Current Capacity 23.7 MMBtu/hr Thermal Oxidizer Burner Capacity (MMBtu/hr) Total Post-modification Capacity 20.5 MMBtu/hr TREA 4 (CE001) 5.8 Heating Value Conversion 1020 Btu/scf TREA 1 (CE002) 8.7 HAP emissions calculated with NG emission factors (no HAP factors TREA 5 (CE003)* 4.2 available for propane) TREA 3 (CE005) 5 TREA 7 1 TREA 1 (CE002) HAP Name (CAS) CAS Emission Factor (lb/mmscf) Hourly Emissions (lb/hr) Annual Emissions (ton/yr) Arsenic E E E-06 Benzene E E E-05 Beryllium E E E-07 Cadmium E E E-05 Chromium E E E-05 Cobalt E E E-06 Dichlorobenzene E E E-05 Formaldehyde E E E-03 Lead E E E-05 Manganese E E E-05 Mercury E E E-06 N-Hexane E E E-02 Naphthalene E E E-05 Nickel E E E-05 Polycyclic Organic Matter** NA 8.64E E E-06 Selenium E E E-07 Toluene E E E-04 Sum Maximum Single HAP TREA 3 (CE005) HAP Name (CAS) CAS Emission Factor (lb/mmscf) Hourly Emissions (lb/hr) Annual Emissions (ton/yr) Arsenic E E E-06 Benzene E E E-05 Beryllium E E E-07 Cadmium E E E-05 Chromium E E E-05 Cobalt E E E-06 Dichlorobenzene E E E-05 Formaldehyde E E E-03 Lead E E E-05 Manganese E E E-06 Mercury E E E-06 N-Hexane E E E-02 Naphthalene E E E-05 Nickel E E E-05 Polycyclic Organic Matter** NA 8.64E E E-06 Selenium E E E-07 Toluene E E E-05 Sum Maximum Single HAP

18 TREA 4 (CE001) HAP Name (CAS) CAS Emission Factor (lb/mmscf) Hourly Emissions (lb/hr) Annual Emissions (ton/yr) Arsenic E E E-06 Benzene E E E-05 Beryllium E E E-07 Cadmium E E E-05 Chromium E E E-05 Cobalt E E E-06 Dichlorobenzene E E E-05 Formaldehyde E E E-03 Lead E E E-05 Manganese E E E-06 Mercury E E E-06 N-Hexane E E E-02 Naphthalene E E E-05 Nickel E E E-05 Polycyclic Organic Matter** NA 8.64E E E-06 Selenium E E E-07 Toluene E E E-05 Sum Maximum Single HAP TREA 5 (CE003)* HAP Name (CAS) CAS Emission Factor (lb/mmscf) Hourly Emissions (lb/hr) Annual Emissions (ton/yr) Arsenic E E E-06 Benzene E E E-05 Beryllium E E E-07 Cadmium E E E-05 Chromium E E E-05 Cobalt E E E-06 Dichlorobenzene E E E-05 Formaldehyde E E E-03 Lead E E E-06 Manganese E E E-06 Mercury E E E-06 N-Hexane E E E-02 Naphthalene E E E-05 Nickel E E E-05 Polycyclic Organic Matter** NA 8.64E E E-06 Selenium E E E-07 Toluene E E E-05 Sum Maximum Single HAP TREA 7 HAP Name (CAS) CAS Emission Factor (lb/mmscf) Hourly Emissions (lb/hr) Annual Emissions (ton/yr) Arsenic E E E-07 Benzene E E E-06 Beryllium E E E-08 Cadmium E E E-06 Chromium E E E-06 Cobalt E E E-07

19 Dichlorobenzene E E E-06 Formaldehyde E E E-04 Lead E E E-06 Manganese E E E-06 Mercury E E E-06 N-Hexane E E E-03 Naphthalene E E E-06 Nickel E E E-06 Polycyclic Organic Matter** NA 8.64E E E-07 Selenium E E E-07 Toluene E E E-05 Sum Maximum Single HAP * TREA 5 was replaced by TREA 7 since the last permit reissuance and its inclusion here is to describe the resulting emissions change. ** POM = Sum of HAPs identified as POM in AP-42, Table Acenaphthene E-06 Acenaphthylene E-06 Anthracene E-06 Benz(a)anthracene E-06 Benzo(a)pyrene E-06 Benzo(b,k)fluoranthene E-06 Benzo(g,h,i)perylene E-06 Chrysene E-06 Dibenzo(a,h)anthrancene E-06 7,12-Dimethylbenz(a)anthracene E-05 Fluoranthene E-06 Fluorene E-06 Indo(1,2,3-ed)pyrene E-06 2-Methylnaphthalene E-05 3-Methylchloranthrene E-06 Phenanthrene E-05 Pyrene E-06 Sum 8.64E-05

20 Coating HAPs The Bergquist Company, Cannon Falls Toluene Control Equipment Max Speed (Sq Ft/hr) Max Coating Coverage (lbs/sq Ft) Application Rate (lb coating/hr) Max Pollutant Content of Coating (wt%) Toluene (lb/hr) Uncontrolled Controlled Toluene (tpy) Minimum Overall Control Efficiency EQUI 2 (EU001) TREA 4/TREA 3 (CE001/CE005) % % EQUI 4 (EU002) TREA 1 (CE002) % % EQUI 3 (EU003) TREA % % EQUI 1 (EU005) TREA % % EQUI 5 (EU004) 1 TREA 3 (CE005) % Sum Toluene Toluene (lb/hr) Toluene (tpy) Xylene Control Equipment Max Speed (Sq Ft/hr) Max Coating Coverage (lbs/sq Ft) Application Rate (lb coating/hr) Max Pollutant Content of Coating (wt%) Xylene (lb/hr) Uncontrolled Controlled Xylene (tpy) Minimum Overall Control Efficiency EQUI 2 (EU001) TREA 4/TREA 3 (CE001/CE005) % % EQUI 4 (EU002) TREA 1 (CE002) % % EQUI 3 (EU003) TREA % % EQUI 1 (EU005) TREA % % EQUI 5 (EU004) 1 TREA 3 (CE005) % Sum Xylene Xylene (lb/hr) Xylene (tpy) Glycol Ether Control Equipment Max Speed (Sq Ft/hr) Max Coating Coverage (lbs/sq Ft) Application Rate (lb coating/hr) Max Pollutant Content of Coating (wt%) Glycol Ether (lb/hr) Uncontrolled Controlled Glycol Ether (tpy) Minimum Overall Control Efficiency Glycol Ether (lb/hr) EQUI 2 (EU001) TREA 4/TREA 3 (CE001/CE005) % - - EQUI 4 (EU002) TREA 1 (CE002) % % EQUI 3 (EU003) TREA % - - EQUI 1 (EU005) TREA % - - EQUI 5 (EU004) 1 TREA 3 (CE005) % Sum Glycol Ether Glycol Ether (tpy) Ethylbenzene Control Equipment Max Speed (Sq Ft/hr) Max Coating Coverage (lbs/sq Ft) Application Rate (lb coating/hr) Max Pollutant Content of Coating (wt%) Ethylbenzene (lb/hr) Uncontrolled Controlled Ethylbenzene (tpy) Minimum Overall Control Efficiency Ethylbenzene (lb/hr) EQUI 2 (EU001) TREA 4/TREA 3 (CE001/CE005) % % EQUI 4 (EU002) TREA 1 (CE002) % % EQUI 3 (EU003) TREA % % EQUI 1 (EU005) TREA % % EQUI 5 (EU004) 1 TREA 3 (CE005) % Sum Ethylbenzene Ethylbenzene (tpy) Controlled Total HAPs PTE (tpy) 3 : Controlled Single HAP PTE (tpy) 3 : AP-42 Section assumes 10% of total solvent entering mixing area is emitted during the mixing process. 2 Calculations based on the combination of coating application rate and coating pollutant content that results in worst-case emissions of HAPs from each coating line. The facility uses coatings that contain higher pollutant contents on a weight percent basis, but the coating is applied at a lower rate which results in lower overall emission rates than presented in these calculations. 3 The permit contains Title I limits on total HAPs (22.5 tpy) and individual HAPs (9 tpy) to remain below major source thresholds under 40 CFR pt