TECHNICAL SUPPORT DOCUMENT For DRAFT/PROPOSED AIR EMISSION PERMIT NO

Transcription

1 TECHNICAL SUPPORT DOCUMENT For DRAFT/PROPOSED AIR EMISSION PERMIT NO This technical support document (TSD) is intended for all parties interested in the draft/proposed 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 draft/proposed permit. 1. General Information 1.1 Applicant and Stationary Source Location Table 1. Applicant and Source Address Stationary Source/Address Applicant/Address (SIC Code: 3732) Brunswick Corporation Lund Boat Co 1 North Field Court 318 West Gilman Ave Lake Forest, IL New York Mills Otter Tail County, Minnesota Contact: Tina Holden Phone: Facility Description Contact: Tina Holden Phone: Lund Boat Company (Brunswick New York Mills Operations) operates a boat manufacturing plant located on West Centennial Drive in New York Mills, Minnesota. The plant has been in operation as a manufacturer of aluminum boats since The primary capability of the facility consists of the manufacture and repair of aluminum fishing boats with models ranging in size from 12 to 24 feet. All phases of the manufacturing process are conducted at this facility, from the receipt of coiled aluminum, marine grade plywood, upholstery materials and inboard engines to the finished product, ready for shipment to boat dealers. Limited repair activities are also conducted at this site for boats manufactured at this facility that have suffered damage in shipment or handling. Brunswick New York Mills Operations has 18 emission units that are associated with stack emissions. These emission units include: nine paint spray booths, a woodshop dust collection system, four upholstery areas, two cleaning areas, and two finishing areas. Volatile Organic Compounds (VOC), particulate matter (PM), particulate matter with an aerodynamic diameter less than 10 microns (PM 10 ), Particulate Matter with a diameter less than 2.5 microns (PM 2.5 ), and hazardous air pollutants (HAPs) are emitted from these emission units. Along with the pollutants listed above, insignificant activities emit Sulfur Dioxide (SO 2 ), Nitrogen Oxides (NO x ), Carbon Monoxide (CO), and Carbon Dioxide (CO 2 e). Particulate matter control equipment is used on the nine paint spray booths and the woodshop dust collection system. There is no VOC control equipment at the facility. The unlimited, uncontrolled VOC and PM/PM 10 /PM 2.5 potential emissions from all emission units exceed 250 tons per year. The draft permit limits facility-wide VOC emissions and PM/PM 10 /PM 2.5 emissions below 225 tons per year due to an emissions cap on specific emission units. The limit on VOC emissions will not necessarily limit the Technical Support Document, Permit Action Number: Page 1 of 12

2 PM/PM 10 /PM 2.5 emissions from the spray booths since the solid content of the coatings varies with material usage. A cap on PM/PM 10 /PM 2.5 emissions was added in order to track and ensure that PM/PM 10 /PM 2.5 emissions don t exceed major source thresholds under PSD. The previous total facility permit issued ( ) allowed the facility to make pre-authorized changes based on FlexCap language in the permit. This permit reissuance changes the FlexCap requirements to PreCap requirements. A PreCap permit allows the facility to make certain changes without calculating Title I emission changes according to Minn. R , subp. 2 for determining the amendment needed. Rather, emission changes are calculated according to Minn. R , subp Description of the Activities Allowed by this Permit Action This permit action is a reissuance of the total facility permit. The previous FlexCap permit allowed the facility to install certain emission units without a permit amendment. The new units were automatically subject to the requirements already specified within the permit. The following preauthorized emission units were added since the last permit reissuance: Paint Spray Booth 5 (EU 015) Paint Spray Booth 6 (EU 017) Paint Spray Booth 7 (EU 018) Rework Booth 2 (EU 020) Upholstery Area - West (EU 016) Upholstery Area (EU 021) Upholstery Area - South (EU 022) Cleaning Area (EU 023) Finishing Area (EU 024) The following Insignificant Activities were added since the last permit reissuance: Paint Line Ovens 3 and 4 Foam Area Flash Off Area Auto Wash Booth Auto Wash Oven Engine Rigging Area Additional Space Heaters Woodshop Sanding Unit Technical Support Document, Permit Action Number: Page 2 of 12

3 1.4 Facility Emissions PM tpy Table 2. Total Facility to Emit Summary PM 10 tpy PM 2.5 tpy SO 2 tpy NO x tpy CO tpy CO 2 e tpy VOC tpy Single HAP tpy Total Facility Limited Emissions , Total Facility Actual Emissions (2012) * * *Not reported in MN emission inventory. Table 3. Facility Classification Classification Major Synthetic Minor/Area Minor/Area PSD X Part 70 Permit Program X Part 63 NESHAP X 1.5 Changes to Permit In addition to preauthorized specific modifications, the MPCA has a combined operating and construction permitting program under Minnesota Rules Chapter 7007, and under Minn. R , the MPCA has authority to include additional requirements in a permit. Under that authority, the following changes to the permit are also made through this permit action: The permit has been updated to reflect current MPCA templates and standard citation formatting. The preexisting Fabric Filter (CE 005) was added as an associated item to the Woodshop Dust Control System (EU 006). The requirement for the notification of compliance status for 40 CFR pt. 63 subp. VVVV has been removed because it has been submitted. EU 015 through EU 018 and EU 020 through EU 024 have been added to the permit to reflect preauthorized changes that have occurred since the previous permit reissuance. New Insignificant Activities added to during the permit during the term of PER 002 have been added to Appendix I. A table of the maximum contents of materials has been added as Appendix II of this permit. This is to document the worst-case scenario material that was used when determining hourly potential to emit. Changing to material that has a higher content of any of the given pollutants is considered a change in method of operation that must be evaluated under Minn. R , subp. 3 to determine if the change requires a permit amendment under Minn. R or a notification under Minn. R VOC and PM/PM 10 /PM 2.5 PreCap permit language was added. Previous permit VOC FlexCap language was removed. The MPCA is moving away from permitting FlexCap language in permits, therefore PreCap permit language was used in place of FlexCap permit language. Language was added allowing the receive credit for VOC and PM/PM 10 /PM 2.5 waste that is shipped off site. Due to the consistency of materials used, the facility is able to a representative of each waste stream rather than a composite sample of each waste shipment. All HAPs tpy Technical Support Document, Permit Action Number: Page 3 of 12

4 2. Regulatory and/or Statutory Basis New Source Review (NSR) The permit limits potential emissions to less than major source levels as defined by the applicable NSR program for the area, 40 CFR The source is located in an attainment area and is not among the 28 industrial categories listed in the rule. The PSD major source threshold is 250 tpy. Emission caps are set at 225 tpy for VOC and 200 tpy for pollutants PM, PM 10, and PM 2.5 with compliance based on a 12- month rolling sum. Part 70 Permit Program The facility is a major source under the pt. 70 permit program because its permitted VOC, PM 10, and PM 2.5 emissions are above the major source thresholds. New Source Performance Standards (NSPS) There are no New Source Performance Standards applicable for the operations at this facility. National Emission Standards for Hazardous Air Pollutants (NESHAP) The facility is a major source of HAPs. The facility is subject to 40 CFR pt. 63, subp. VVVV National Emission Standards for Hazardous Air Pollutants for Boat Manufacturing. Standards for carpet and fabric adhesive operations and aluminum recreational boat surface coating apply to the facility. The facility complies with the combined aluminum surface coating and aluminum wipedown solvents limit. This facility has a woodshop where certain components of the boats are prepared. Brunswick New York Mills Operation s Standard Industrial Classification Code is 3732 (boat manufacturing) and therefore, 40 CFR pt. 63, subp. JJ National Emission Standards for Wood Furniture Manufacturing Operations does not apply to this facility. Compliance Assurance Monitoring (CAM) The facility contains control equipment in the form of panel filters for the paint booths and a fabric filter for the woodshop. The pre-controlled potential emissions of the regulated pollutants PM, PM 10, and PM 2.5 for each emission unit are below the major source threshold for Pt. 70 sources. Therefore, the facility is not subject to CAM. The spray booths contain multiple paint guns that could be used simultaneously. The facility only uses one gun at a time to limit the possibility of contamination. The facility accepted a requirement to operate only one paint gun at a time. The limit on paint gun usage keeps uncontrolled emissions below tons per year for all particulate matter pollutants for each spray booth. Minnesota State Rules Portions of the facility are subject to the following Minnesota Standards of Performance: Minn. R Standards of Performance for Post-1969 Industrial Process Equipment Minn. R Standards of Performance for Fossil Fuel Burning Direct Heating Equipment Correspondence with Tribal Governments Since this permit action is a reissuance of a Pt. 70 permit, and Pt. 70 reissuance is one of the triggers for inclusion of Minnesota Indian Tribes in the permitting process, the MPCA must offer to meet and share information on the permit application and project schedule with tribes that have interest in the project. The facility is located in Ottertail County. Leach Lake, White Earth, and Mille Lacs tribal governments Technical Support Document, Permit Action Number: Page 4 of 12

5 have historically expressed interest in permitting project in this county. An was sent to the tribal governments notifying the start of the permitting process. No interest was expressed in this permit action, therefore no further action on engagement was taken. Environmental Justice Environmental Justice (EJ) is the fair treatment and meaningful involvement of all people regardless of race, color, national origin, or income with respect to the development, implementation, and enforcement of environmental laws, regulations, and policies. EPA has this goal for all communities and persons across the U.S.A. It will be achieved when everyone enjoys the same degree of protection from environmental and health hazards and equal access to the decision-making process to have a healthy environment in which to live, learn, and work. As part of this permitting process, the MPCA contacts US E.P.A. Region 5 staff to verify if there are any possible EJ issues for the facility location that need to be addressed in the permit action. For this project the MPCA staff contacted EPA Region 5 on October 23, According to the EPA, Environmental Justice Concerns are unlikely for Brunswick New York Mills Operations. Table 4. Regulatory Overview of Facility Subject Item* Applicable Regulations Rationale Title I Condition: To Avoid classification as a major source under 40 CFR 52.21; Minn. R GP 001 (Spray Painting) GP 002 (PreCap: VOCs) GP 003 (Sources Subject to Subp. VVVV) GP 004 (PreCap: Particulate Matter) EU 006 (Woodshop Dust Control System) Title I Condition: To Avoid classification as a major source under 40 CFR 52.21; Minn. R CFR pt. 63 subp. VVVV; Minn. R Title I Condition: To avoid classification as a major source under 40 CFR 52.21; Minn. R Minn. R Minn. R *Location of the requirement in the permit (e.g., EU, SV, GP, etc.). PSD. Control efficiency and other operating parameter requirements are needed to limit PM, PM 10, and PM 2.5 emissions to avoid major source classification. PSD. All VOC emitting emission units in GP 002 are subject to an emission limit in the form of an emissions cap. The limit is placed in the permit to prevent VOC emissions from exceeding the major source threshold of 250 tpy VOC as defined by 40 CFR National Emission Standards for Hazardous Air Pollutants for Boat Manufacturing. The facility is subject to these standards because: the facility builds aluminum boats, and the facility is a major source of HAPs as defined by 40 CFR PSD. All PM, PM 10, and PM 2.5 emitting emission units in GP 004 are subject to an emission limit in the form on an emissions cap. The limit is placed in the permit to prevent PM, PM 10, and PM 2.5 emissions from exceeding the 250 tpy major source threshold as defined by 40 CFR Standards of Performance for Post-1969 Industrial Process Equipment. Particulate matter and opacity emitted from the woodshop is limited by Minnesota standards. EU 006 is subject to no visible emissions. This restriction was carried forward from PER 002 and reflects that capability of a low level temperature fabric filter. Technical Support Document, Permit Action Number: Page 5 of 12

6 3. Technical Information 3.1 Calculations of to Emit Attachment 1 to this TSD contains detailed calculations and supporting information prepared by the Permittee and the MPCA. Application of boat coatings are the main source of emissions at the facility. Cleaning areas, paint booths, finishing areas, and rework booths all use coating material. The coating material consists of VOCs, HAPs, and, in the case of the paint booths, solids (particulates). Particulates that aren t transferred to the boat surface are assumed to be vented through a panel filter to the atmosphere. The upholstery areas are sources of VOC emissions due to material usage. The woodshop is a source of PM, PM 10, and PM 2.5 emissions. Paint Booth Emissions: The PTE calculations for the paint booths are based on mass balance approach using the maximum solids, VOC, and HAP contents in the coatings used at each booth. An example for a paint booth (EU 001) is located below: Mass Balance for VOC emissions (EU 001) Maximum Paint application rate (per gun) = 9.51 gal/hr Guns operate at once per booth = 1 Maximum VOC Content of Material = 5.34 lbs/gal Unlimited PTE VOC = (9.51 gal/hr) * (1 gun) * (5.34 lbs/gal) * (8760 hours/yr) * (1 ton/2000 lbs) Unlimited PTE VOC = tons VOC/yr Mass Balance for HAP (xylene) emissions (EU 001) Maximum Xylene content of Material = 2.57 lb/gal Unlimited PTE Xylene = (9.51 gal/hr) * (1 gun) * (2.57 lb/gal) Unlimited PTE Xylene = lb Xylene/hr Unlimited PTE Xylene = ton Xylene/yr Mass Balance for PM/PM10/PM2.5 emissions (EU 001) Maximum Gun Flow Rate = 9.51 gal/hr Guns operate at once per booth = 1 Density of Paint = lb/gal Solid Content = 73.48% by weight Solid Content = (12.10 lb/gal) * (73.48%) = 8.89 lb/gal Transfer Efficiency of Application Method = 75% Control Efficiency of Panel Filter = 85% A control efficiency of 85% was derived from the Minnesota Control Equipment rule (Minn. R ). The control efficiency for panel filters with a total enclosure is 85% for PM and Technical Support Document, Permit Action Number: Page 6 of 12

7 PM 10. The rule doesn t contain control efficiencies for PM 2.5. Since it is conservatively assumed the PM = PM 10 = PM 2.5, the control efficiencies for PM and PM 10 can be used for PM 2.5. Uncontrolled PTE for PM = (9.51 gal/hr) *(1 gun) * (8.89 lb/gal) * (% - 75%) * (8760/2000) Uncontrolled PTE for PM = tons PM/yr Controlled PTE for PM = (92.59 tons PM/yr) * (% - 85%) Controlled PTE for PM = tons PM/yr Maximum Material Contents and Application Rates: The worst-case VOC content, solids content, and application rates for all units are documented in Appendix II of the permit. The VOC and solid content values were taken from the Material Safety Data Sheet (MSDS) of the coating materials. The application rate and transfer efficiency were taken from spray gun information. The Permittee can freely change formulations or solutions of materials used, but changing to a material that has a higher content of any of the pollutants listed or increasing the application rate is considered a change in the method of operation that must be evaluated to determine if a permit amendment or notification is required. The emission increase (lb/hr) is compared to the thresholds in Minn. R and Minn. R to determine if an amendment or notification is needed. The maximum material contents and application rates are used in determining the potential to emit for the facility. Paint Line Oven Emissions: After the aluminum boat is coated with paint, it is moved directly into the paint line oven. The paint line oven dries the coat of paint so additional paint or finishing solvent may be added. The remaining VOCs contained within the original coating are released at this point. In order to simplify calculations, all VOCs contained within the paint are assumed emitted from the paint booth, even though the emissions may be split between booth and oven. The paint line ovens burn natural gas. The emissions from natural gas are below the threshold for insignificant activities in Minn. R , subp. 3(I). Cleaning and Finishing Areas: Cleaning areas apply solvent to the aluminum boats prior to paint application. The finishing areas apply a solvent to aluminum boats after paint application. The solvents contain VOCs and HAPs. It is assumed all VOC and HAP emissions are vented to the atmosphere. These areas are subject to the emission cap and material usage is recorded. The material isn t applied to the boats by spray guns or other equipment with a known application rate. The potential emissions are calculated by extrapolating the average actual material usage rate over 8760 hours, as shown below. A safety factor of 2 is used as well. The cleaning and finishing areas are subject to the VOC PreCap. Mass Balance for VOC emissions Average Weight of VOCs emitted from Material ( ) = tons Average Numbers of Hours of Operation ( ) = 4360 PTE VOC = [(21.00 tons) * (2) / (4360 hours)] * (8760 hours/year) PTE VOC = tons VOC/yr Upholstery Shop: The facility contains four upholstery areas. The upholstery areas use material that contains VOCs. It is assumed that all VOCs contained within the material are vented to the atmosphere. Technical Support Document, Permit Action Number: Page 7 of 12

8 These areas are subject to the emission cap and material usage is recorded. The potential emissions from this area are calculated using average actual material usage and extrapolating it out over 8,760 hours per year, similar to the calculations for the cleaning and finishing areas. The upholstery shop is subject to the PreCap. Woodshop: The woodshop emits particulate matter. It is assumed that all PM and PM 10 emissions are PM 2.5. The potential emissions were calculated using the Industrial Process Equipment Rule located in Minn. R This rule limits the quantity of PM that can be emitted to the atmosphere. The flow rate of the source gas in the woodshop dust collection system is 6,400 acfm. The PM concentration limit is 0. gr/dscf. The concentration is converted to an emission rate (lb/hr and tpy). The actual emissions from the woodshop are much lower than the potential emissions due the use of a fabric filter. The fabric filter is not used in calculating the PTE from the woodshop. The particulate emissions from the woodshop were subtracted from 225 tons per year to arrive at a PreCap limit of 200 tpy for PM 2.5, PM 10, and PM emissions. Other VOC Emissions: Various Insignificant Activities contribute to the facility VOC emissions. Sources include paint line ovens, the flashoff process, space heaters, and foaming areas. The VOC emissions from these sources have been quantified and used in determining the VOC limit for emissions units subject to the PreCap. Other VOC emission sources account for less than 2 tons per year VOCs. The VOC PreCap limit is 225 tpy VOC. 3.2 Monitoring In accordance with the Clean Air Act, it is the responsibility of the owner or operator of a facility to have sufficient knowledge of the facility to certify that the facility is in compliance with all applicable requirements. In evaluating the monitoring included in the permit, the MPCA considered the following: the likelihood of the facility violating the applicable requirements; whether add-on controls are necessary to meet the emission limits; the variability of emissions over time; the type of monitoring, process, maintenance, or control equipment data already available for the emission unit; the technical and economic feasibility of possible periodic monitoring methods; and the kind of monitoring found on similar units elsewhere. Table 5 summarizes the monitoring requirements (see next page). Technical Support Document, Permit Action Number: Page 8 of 12

9 Table 5. Monitoring Subject Item* Requirement (basis) Monitoring Discussion GP 001 (Spray Painting) PM/PM 10 /PM 2.5 control efficiency: > 85% GP 002 (PreCap: VOCs) GP 003 (Paint Booths, Upholstery Shops) (Title I Condition: to avoid classification as a major source under 40 CFR 52.21; Minn. R ) VOC 225 tons per year, on a 12 month rolling basis (Title I Condition: to avoid classification as a major source under 40 CFR 52.21; Minn. R ) Organic HAP 5.0 wt % for carpet and fabric adhesives Organic HAP < 0.33 kg/l of total coating solids applied for aluminum wipedown solvents AND Organic HAP < 1.22 kg/l of total coating solids applied for aluminum boat surface coatings OR Organic HAP 1.55 kg/l of combined aluminum wipedown solvents and surface coatings (40 CFR pt. 63, subp. VVVV; Minn. R. 7370) Daily inspections, quarterly inspections, recordkeeping, use of operation and maintenance plan, corrective actions Recordkeeping: Daily usage records for coating material and related products; Monthly recordkeeping including total usage of VOCcontaining material Determine HAP content of carpet and fabric adhesives. Determine HAP and solids contents of coating materials. Recordkeeping: Monthly records of surface coating and wipedown material use and the solid and HAP content of material. Inspections, recordkeeping, and corrective actions ensure that the control equipment is operating up to standards and PM, PM 10, and PM 2.5 emissions are controlled. Daily usage records are used in determining monthly usage of VOC-containing material. Daily records are only kept for coating material and related products (reducers and additives). It was determined that it would be overly burdensome for all VOC-containing materials to be recorded daily. The 12-month rolling sum ensures that the VOC limit of 225 tons per year is met. The facility has the option to comply with individual limits for aluminum wipedown solvents and surface coatings separately or a combined limit. The facility has historically chosen the option to comply with a combined limit of 1.55 kg of organic HAPs per liter of total coating solids. Recordkeeping of material usages ensures that the limits on HAPs are being met. The equations used to determine the HAP content of the material are listed in the permit appendix and also within 40 CFR pt. 63, subp. VVVV. Technical Support Document, Permit Action Number: Page 9 of 12

10 Subject Item* Requirement (basis) Monitoring Discussion GP 004 (PreCap: Particulate Matter Pollutants) PM/PM 10 /PM 2.5 < 200 tons per year, on a 12 month rolling basis. EU 006 (Woodsho p Dust Control System) (Title I Condition: to avoid classification as a major source under 40 CFR 52.21; Minn. R ) PM: 0.10 grains/dscf Opacity: No visible emissions (Minn. R , subp. 2) Recordkeeping: Daily usage records for coating material and related material; monthly recordkeeping including total usage of PM/PM 10 /PM 2.5 containing material Daily Inspection for visible emissions, periodic inspections of control equipment, corrective actions. *Location of the requirement in the permit (e.g., EU, SV, GP, etc.). Daily usage records are used in determining monthly usage of VOC-containing material. The 12-month rolling sum ensures that the VOC limit of 225 tons per year is met. The Permittee shall check fabric filter and record when any visible emissions are present. Periodic inspections of control equipment also occur. And Operation and Maintenance Plan shall be followed and kept on site. Maintaining the control equipment ensures that the PM and Opacity requirements are met. 3.3 Insignificant Activities Brunswick New York Mills Operations has several operations which are classified as insignificant activities under the MPCA s permitting rules. These are listed in Appendix I of this permit. The insignificant activities VOC emissions were considered when determining the GP tpy cap. This creates a large enough buffer to account for margin of error. This will prevent the facility from emitting more than the 250 tpy threshold for major source under New Source Review. The permit requires the Facility to evaluate all potential emission increases from insignificant activities. emissions from insignificant activities were calculated and considered when determining the VOC emissions cap. Insignificant Activity Welding and cutting equipment Table 6. Insignificant Activities General Applicable Emission limit Discussion PM, variable depending For these units, based on EPA published emissions on airflow factors, it is highly unlikely that they could violate Opacity 20% the applicable requirement. In addition, these units (Minn. R ) are typically operated and vented inside a building, so testing for PM or opacity is not feasible. Technical Support Document, Permit Action Number: Page 10 of 12

11 Insignificant Activity Individual units with potential emissions less than 4000 lb/yr CO, 0 ton/yr CO2e, and 2000 lb/year of the following pollutants: NOx, SO2, PM, PM10, and VOCs (including HAP containing VOCs). Fugitive Emissions from unpaved roads and parking lots Individual units with potential emissions less than 5.7 lbs/yr CO; 2.28 lbs/yr of the following pollutants: NOx, SO2, PM, PM10, and VOCs; and 25% or less of hazardous air pollutant threshold listed in Minn. R , subp. 5 Individual units, each of which has: emissions of 2.28 lbs/hr of VOCs and 25 percent or less of hazardous air pollutant threshold listed in Minn. R , subp. 5. General Applicable Emission limit PM, variable depending on airflow Opacity 20% (with exceptions) (Minn. R and Minn. R ;) PM: > 0.4 lb/mmbtu Opacity < 20% (with exceptions) (Minn. R ) SO 2, < 0.5 lb/mmbtu Opacity < 20% (Minn. R ) Requirement to take reasonable measures to prevent PM from becoming airborne (Minn. R ) PM, variable depending on airflow Opacity 20% (with exceptions) (Minn. R and Minn. R ) PM: > 0.4 lb/mmbtu Opacity < 20% (with exceptions) (Minn. R for made-up air unit) PM, variable depending on airflow Opacity < 20% (Minn. R ) Discussion There are natural gas combustion heating units, four natural gas fired paint drying ovens, four flotation foam application areas, an auto wash oven, limited engine testing, aerosol spray paint can touch up use, parts area dust control, woodshop sanding unit, and aluminum grinding and machining operations. The aerosol spray paint can touch-up uses less than 1 ton of material per year. A summary of the PTE for these Insignificant Activities is located in Attachment 1. Nearly all surfaces are currently paved. Made Up Air Unit and 11 natural gas combustion heating units have the potential to emit over 2000 lb/year of NOx. The potential to emit of these units is less than 2.28 lbs/hr. The auto wash booth doesn t emit VOCs or other criteria pollutants. It has the potential to emit hydrofluoric acid. 25 percent of the threshold for hydrofluoric acid is 50 lbs/yr. The auto was booth s potential emissions are less than 50 lbs/yr. The calculations are in Attachment Permit Organization In general, the permit meets the MPCA Delta Guidance for ordering and grouping of requirements. One area where this permit deviates slightly from Delta guidance is in the use of appendices. While appendices are fully enforceable parts of the permit, in general, any requirement that the MPCA thinks should be electronically tracked (e.g., limits, submittals, etc.), should be in Table A or B of the permit. The main reason is that the appendices are word processing sections and are not part of the electronic tracking system. Violation of the appendices can be enforced, but the computer system will not automatically generate the necessary enforcement notices or documents. Technical Support Document, Permit Action Number: Page 11 of 12

12 3.5 Comments Received This section will be filled in after the Public Notice and EPA 45-day Review Period. Public Notice Period: EPA 45-day Review Period: 4. Permit Fee Assessment This permit action is the reissuance of an individual Part 70; therefore, no application fees apply under Minn. R , subp. 1. There are no additional fees. 5. Conclusion Based on the information provided by Brunswick, 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: Zachary Tauer (permit engineer) Rachel Studanski (enforcement) Ladislaus Strzok (compliance) Marshall Cole (peer reviewer) Beckie Olson (permit writing assistant) Laurie O Brien (administrative support) AQ File No. 2806; DQ 3060 Attachments: 1. PTE Summary Calculation Spreadsheets 2. Facility Description and CD-01 Forms Technical Support Document, Permit Action Number: Page 12 of 12

13 Attachment 1 PTE Summary and Emissions Increase Calculation Spreadsheets

14 Methyl 2- Ethyl Isobutyl Butoxyeth Xylene Cumene benzene Toluene Ketone m-xylene Styrene anol (112- EU001/EU EU003/EU EU012 EU015 Methyl 2- ( ( ) (-41-4) ( ) ( ) ( ) ( ) 07-2) 002 (SBs 004 (SBs (Rework (Fish VOC Solids Ehtyl Isobutyl Butoxyeth VOC Solid Total HAPs 7) HAPs HAPs HAPs HAPs HAPs HAPs HAPs HAPs 1 &2) 3 &4) Booth) Boats SB) Content Content Total HAPs Xylene Cumene benzene Toluene Ketone m-xylene Styrene anol Density Content Content Content Content (% Content (% Content (% Content (% Content (% Content (% Content (% Content (% Coating Catalyst Reducer Additive (lb/gal) (lb/gal) (lb/gal) (lb/gal) (lb/gal) (lb/gal) (lb/gal) (lb/gal) (lb/gal) (lb/gal) (lb/gal) (lb/gal) (wt%) (wt%) (%) wt) wt) wt) wt) wt) wt) wt) wt)) Coatings AS APPLIED Paint, Sierra Olive Drab, K-1264 no additive % 38.46% 35.60% 14.00% 21.60% 90% 10% Paint, Sierra Interior Boat Gray, 12 no additive % 44.23% 28.00% 9.80% 18.20% 25% 75% Paint, Sierra Blk Vinyl Topcoat, no additive % 40.55% 28.60% 1% 10.00% 17.40% % Paint, PPG Primer, DP40LF DP401LF 2:1 885 reducer 2: % 39.39% 23.00% 11.75% 0.25% 0.75% 6.75% 3.50% 0.00% 0.00% 0.00% 58% 2% 40% Paint, HS Polyurethane Clear, DCU :1 885 reducer 2:1 5:1: % 46.57% 37.29% 29.57% 0.00% 5.14% 1.86% 0.00% 0.00% 0.71% 0.00% % Paint, Fleck Black 2K no additive % 56.3% 1.50% 2% 25% 75% Paint, FleckWhite 2K no additive % 56.3% 1.55% 1.55% 25% 75% Paint, Fleck/Mdm Gray no additive % 56.36% 0.00% 12% Paint, Blk Pux HSL A :1 885 reducer 2:1 5:1: % 48.70% 3.00% 1.00% 0.00% 0.14% 1.86% 0.00% 0.00% 0.00% 0.00% 82% 10% 8% Paint, Majestic Red HSL61983A :1 885 reducer 2:1 5:1: % 45.94% 3.00% 1.00% 0.00% 0.14% 1.86% 0.00% 0.00% 0.00% 0.00% 90% 10% Paint, Met Charcoal HSL936054Q :1 885 reducer 2:1 5:1: % 47.57% 3.00% 1.00% 0.00% 0.14% 1.86% 0.00% 0.00% 0.00% 0.00% 95% 5% Paint, Vapor Mist HSL A :1 885 reducer 2:1 5:1: % 46.31% 3.00% 1.00% 0.00% 0.14% 1.86% 0.00% 0.00% 0.00% 0.00% 88% 12% Paint, Satin Beige HSL :1 885 reducer 2:1 5:1: % 49.31% 3.00% 1.00% 0.00% 0.14% 1.86% 0.00% 0.00% 0.00% 0.00% 90% 10% Paint, HSL Slvr Stone :1 885 reducer 2:1 5:1: % 44.76% 3.00% 1.00% 0.00% 0.14% 1.86% 0.00% 0.00% 0.00% 0.00% 90% 10% Paint, Gry Granite HSL :1 885 reducer 2:1 5:1: % 45.41% 3.00% 1.00% 0.00% 0.14% 1.86% 0.00% 0.00% 0.00% 0.00% 90% 10% Paint, Flame Red Metallic HSL :1 885 reducer 2:1 5:1: % 48.08% 3.00% 1.00% 0.00% 0.14% 1.86% 0.00% 0.00% 0.00% 0.00% 96% 2% 2% Paint, HSL925347A Sport Red :1 885 reducer 2:1 5:1: % 48.22% 3.00% 1.00% 0.00% 0.14% 1.86% 0.00% 0.00% 0.00% 0.00% 96% 4% Paint, Wildfire Red HSL :1 885 reducer 2:1 5:1: % 48.70% 3.00% 1.00% 0.00% 0.14% 1.86% 0.00% 0.00% 0.00% 0.00% 38% 2% 60% Paint, Pebble HSL925339A :1 885 reducer 2:1 5:1: % 55.44% 3.00% 1.00% 0.00% 0.14% 1.86% 0.00% 0.00% 0.00% 0.00% 95% 5% Paint, Cobalt Blue HSL A :1 885 reducer 2:1 5:1: % 47.91% 3.00% 1.00% 0.00% 0.14% 1.86% 0.00% 0.00% 0.00% 0.00% 92% 5% 3% Paint, Alt Storm Blue HSL936057Q :1 885 reducer 2:1 5:1: % 47.22% 3.00% 1.00% 0.00% 0.14% 1.86% 0.00% 0.00% 0.00% 0.00% 95% 5% Paint, Bay Blue HSL925344A :1 885 reducer 2:1 5:1: % 48.86% 3.00% 1.00% 0.00% 0.14% 1.86% 0.00% 0.00% 0.00% 0.00% 96% 4% Paint, Artic White HSL A :1 885 reducer 2:1 5:1: % 60.11% 3.00% 1.00% 0.00% 0.14% 1.86% 0.00% 0.00% 0.00% 0.00% 92% 5% 3% Paint, Lund Red HSL935928Q :1 885 reducer 2:1 5:1: % 48.72% 3.00% 1.00% 0.00% 0.14% 1.86% 0.00% 0.00% 0.00% 0.00% 90% 10% Paint, Blue Flame HSL :1 885 reducer 2:1 5:1: % 47.19% 3.00% 1.00% 0.00% 0.14% 1.86% 0.00% 0.00% 0.00% 0.00% 98% 2% Paint, Wilderness Grn HSL935927Q :1 885 reducer 2:1 5:1: % 48.68% 3.00% 1.00% 0.00% 0.14% 1.86% 0.00% 0.00% 0.00% 0.00% 91% 8% 1% Paint, Silver Bay HSL925537A :1 885 reducer 2:1 5:1: % 43.70% 3.00% 1.00% 0.00% 0.14% 1.86% 0.00% 0.00% 0.00% 0.00% 92% 8% Primer, PPG 63229A GXM350 6:1 4% % 46.87% 1.44% 1.23% 0.00% 0.21% 0.00% 0.00% 0.00% 0.00% 0.00% % HS Storm Blue :1 885 reducer 2:1 5:1: % 47.67% 3.00% 1.00% 0.00% 0.14% 1.86% 0.00% 0.00% 0.00% 0.00% 98% 2% Primer, Gray Epoxy no addtive % 73.48% Catalysts % 73.48% 37.29% 29.57% 0.25% 5.14% 14.00% 21.60% 1.55% 0.71% 0.00% Additive, Activator Epoxy Primer Catalyst, 58% 2% 40% DP401LF catalyst for dp % 29.77% 31.00% 30% 1% Primer, 2000 catalyst for % 34.49% 0.00% Catalyst Wash % Additive, Paint Slow Catalyst catalyst for paint % 80.00% 0.00% % 5% 10% Reducers EZ Blend Plus no additive % 4.19% 54.00% % 17% 3% 34% Additive, Reducer no additive % 0.00% 30.00% 75% DT870 mix w paint 1:2 30% 25% Urethane Reducer DT 895 no additive mix w paint 1: % 0.00% 39.50% 7% 2% 1% 30% 90% 10% 4% mixture w/sep 98% 2% Solvent, Spectra thin Reducer no additive primer % 0.00% 0.00% Reducer, LV Med, DT885 no additive mix w paint 1: % 0.00% 21.00% 7% 1% 13% 98% 2% Additives Paint, Aluminum Coarse, DMC-983 we are discarding % 43.25% 46.50% 30% 5% 10% % 2% Paint, Urethane Hardener, DDH525 no additive % 57.84% 0.00% % mix with paint 1/2 % Paint, Blue Shade Phthalo Green, DMC936 we are discarding % 48.10% 26.50% 10% 5% 10% 2%

15 PTE All Spray Booths Freshwater Boats / New York Mills, MN SPRAY BOOTHS EU001 EU002 EU003 EU004 EU012 EU015 EU017 (New Building) EU018 (New Building) EU020 (New Building) Total Booth 1 Booth 2 Booth 3 Booth 4 Rework Booth Fish Boats (Booth 5) Booth 6 Booth 7 Re-Work Booth #2 All Booths Coatings and other Materials Max Gun Flow Rate in gals/hr Average Number of Hours Worked Annually over Last 2 Years Max VOC Content of Coating as applied (lb/gal ) Maximum Total HAPs (lb/gal) Maximum Xylene (lb/gal) Maximum Toluene (lb/gal) Maximum Ethyl Benzene (lb/gal) Maximum MIK (lb/gal) Maximum Cumene (lb/gal) Maximum m-xylene (lb/gal) Maximum Styrene (lb/gal)

16 PTE All Spray Booths Freshwater Boats / New York Mills, MN SPRAY BOOTHS EU001 EU002 EU003 EU004 EU012 EU015 EU017 (New Building) EU018 (New Building) EU020 (New Building) Total Hourly from Coatings based on Spray Gun Flow Rate Booth 1 Booth 2 Booth 3 Booth 4 Rework Booth Fish Boats (Booth 5) Booth 6 Booth 7 Re-Work Booth #2 All Booths VOC Hourly from Coatings (lbs/hr) HAP Hourly from Coatings (lbs/hr) Xylene Hourly from Coatings (lbs/hr) Toluene Hourly from Coatings (lbs/hr) Ethyl Benzene Hourly from Coatings (lbs/hr) MIK Hourly from Coatings (lbs/hr) Cumene Hourly from Coatings (lbs/hr) m-xylene Hourly from Coatings (lbs/hr) Styrene Hourly from Coatings (lbs/hr)

17 PTE All Spray Booths Freshwater Boats / New York Mills, MN SPRAY BOOTHS EU001 EU002 EU003 EU004 EU012 EU015 EU017 (New Building) EU018 (New Building) EU020 (New Building) Total PTE from Coatings based on Spray Gun Flow Rate Booth 1 Booth 2 Booth 3 Booth 4 Rework Booth Fish Boats (Booth 5) Booth 6 Booth 7 Re-Work Booth #2 All Booths Theoretical Annual PTE of VOCs from Coatings (tons/year) Theoretical Annual PTE of HAPs from Coatings (tons/year) Theoretical Annual PTE of Xylene from Coatings (tons/year) Theoretical Annual PTE of Toluene from Coatings (tons/year) Theoretical Annual PTE of Ethyl Benzene from Coatings (tons/year) Theoretical Annual PTE of MIK from Coatings (tons/year) Theoretical Annual PTE of Cumene from Coatings (tons/year) Theoretical Annual PTE of m-xylene from Coatings (tons/year) Theoretical Annual PTE of Styene from Coatings (tons/year) , ,

18 PTE All Spray Booths Freshwater Boats / New York Mills, MN SPRAY BOOTHS EU001 EU002 EU003 EU004 EU012 EU015 EU017 (New Building) EU018 (New Building) EU020 (New Building) Total Guncleaner Solvent (no HAPS are present in the Guncleaner Solvent) Booth 1 Booth 2 Booth 3 Booth 4 Rework Booth Fish Boats (Booth 5) Booth 6 Booth 7 Re-Work Booth #2 All Booths Actual Weight of VOCs emitted from Guncleaner Solvent over last 2 years (tons) Average Annual Actual Weight of VOCs emitted from Guncleaner Solvent over last 2 years (tons) Theoretical Annual PTE of VOCs from Guncleaner Solvent (tons/year) Hourly from Gunclear based on 2 year average usage at 8,760 hrs VOC Hourly from Guncleaner (lbs/hr)

19 PTE All Spray Booths Freshwater Boats / New York Mills, MN SPRAY BOOTHS EU001 EU002 EU003 EU004 EU012 EU015 EU017 (New Building) EU018 (New Building) EU020 (New Building) Total Hourly from Coatings and Guncleaner (no HAPs in Guncleaner) Booth 1 Booth 2 Booth 3 Booth 4 Rework Booth Fish Boats (Booth 5) Booth 6 Booth 7 Re-Work Booth #2 All Booths VOC Hourly from Coatings (lbs/hr) HAP Hourly from Coatings (lbs/hr) Xylene Hourly from Coatings (lbs/hr) Toluene Hourly from Coatings (lbs/hr) Ethyl Benzene Hourly from Coatings (lbs/hr) MIK Hourly from Coatings (lbs/hr) Cumene Hourly from Coatings (lbs/hr) m-xylene Hourly from Coatings (lbs/hr) Styrene Hourly from Coatings (lbs/hr)

20 PTE All Spray Booths Freshwater Boats / New York Mills, MN SPRAY BOOTHS EU001 EU002 EU003 EU004 EU012 EU015 EU017 (New Building) EU018 (New Building) EU020 (New Building) Total Totals Booth 1 Booth 2 Booth 3 Booth 4 Rework Booth Fish Boats (Booth 5) Booth 6 Booth 7 Re-Work Booth #2 All Booths All Booths Theoretical Annual PTE of VOCs from Coatings and Guncleaner (tons/year) Theoretical Annual PTE of HAPs from Coatings (tons/year) Theoretical Annual PTE of Xylene from Coatings HAP sources (tons/year) Theoretical Annual PTE of Toluene from Coatings HAP sources (tons/year) Theoretical Annual PTE of Ethyl Benzene from Coatings HAP sources (tons/year) Theoretical Annual PTE of MIK from Coatings HAP sources (tons/year) Theoretical Annual PTE of Cumene from Coatings HAP sources (tons/year) Theoretical Annual PTE of m-xylene from Coatings HAP sources (tons/year) Theoretical Annual PTE of Styrene from Coatings HAP sources (tons/year)

21 PTE Cleaning, Finish and Upholstery Areas Freshwater Boats / New York Mills, MN CLEANING AREAS FINISHING AREAS UPHOLSTERY AREAS EU009 EU023 EU010 EU024 EU011 EU016 EU021 EU022 Cleaning Area Cleaning Area Finishing Area Finishing Area Upholstery Upholstery Upholstery Upholstery Area - East Area - West Area - South Area To Emit Maximum Number of Hours per Year Actual Number of Hours Worked in 2012 and Average Number of Hours Worked Annually over Last 2 Years All other VOC/HAP containing Cleaning, Finishing, Upholstery Materials Actual Weight of VOCs emitted from Materials over last 2 years (tons) Average Annual Actual Weight of VOCs emitted from Materials over last 2 years (tons) Average Annual Actual Weight of VOCs emitted from Materials over last 2 years (tons) (Safety Factor = 2) Average % VOC in Materials 65.00% 65.00% 45.67% 45.67% 44.40% 44.40% 44.40% 44.40% Theoretical Annual Weight of Coatings and other Material VOC sources (tons/year) Actual Weight of HAPs emitted over last 2 years (%) 0.54% 0.54% 3.32% 3.32% Actual Weight of Xylenes emitted over last 2 years (%) 0.54% 0.54% 2.77% 2.77% Actual Weight of Ethyl Benzene emitted over last 2 years (%) 0.00% 0.00% 0.54% 0.54% Hourly VOC Hourly (lbs/hr) HAP Hourly (lbs/hr) Xylene Hourly (lbs/hr) Ethyl Benzene Hourly (lbs/hr) PTE Totals (Hourly X 8,760 hrs) Theoretical Annual PTE of VOCs from all VOC sources (tons/year) Theoretical Annual PTE of HAPs from all sources (tons/year) Theoretical Annual PTE of Xylene from all sources HAP sources (tons/year) Theoretical Annual PTE of Ethyl Benzene from all sources HAP sources (tons/year)

22 PTE PM All Spray Booths Freshwater Boats / New York Mills, MN SPRAY BOOTHS EU001 EU002 EU003 EU004 EU012 EU015 EU017 (New Building) EU018 (New Building) EU020 (New Building) Total Booth 1 Booth 2 Booth 3 Booth 4 Rework Booth Fish Boats (Booth 5) Booth 6 Booth 7 Re-Work Booth #2 All Booths Coatings and other Materials Max Gun Flow Rate in gals/hr Max Solid Content of Coating as applied (lb/gal ) Transfer Efficiency 75% 75% 75% 75% 75% 75% 75% 75% 75% Theoretical Annual PTE of Solids from Coatings (tons/year) UNCONTROLLED Controll Efficiency 85% 85% 85% 85% 85% 85% 85% 85% 85% Theoretical Annual PTE of Solids from Coatings (tons/year) CONTROLLED

23 Estimated Actual Emissions: Woodshop EU 006, SV 006 PTE PM Freshwater Boats / New York Mills, MN Woodshop PM Emissions Estimated from Woodwaste Shipped Offsite, assuming a full 20 yd 3 Rolloff, sawdust weighing 459 lbs/yd 3 (Thomas J. Glover, Pocket Ref, pg. 435), 260 shipments per year, 99% control efficiency (AP42) for fabric filter: Rolloff Size yd) (cu Weight/ roll off (tons) Total off site shipment TPY (4.59 tons X 26 shipments /yr) total dust/year (tpy) (= total offsite shipment /0.99) total dust roll off (tons) (= weight rolloff/ 0.99) emissions /roll off (= dust/rolloff * (1 - CE (99%))) emissions/yr (=emissions /rolloff * 26) Emissions: Woodshop EU 006, SV 006 Flow rate = 6400 acfm Table 2 limit = 0.1 gr/dscf (Minn. R ) PM = 5.49 lb/hour tpy Assume all PM10 = 5.49 lb/hour tpy Assume all PM2.5 = 5.49 lb/hour tpy Emissions: Spray Booths A A B B C D B A A EU001 EU002 EU003 EU004 EU012 EU015 EU017 EU018 EU020 PTE Controlled tpy PTE all booths tpy

24 Natural Gas Combustion Insignificant Source Calculations Freshwater Boats / New York Mills, MN NOx CO Lead (Pb) PM SO2 VOC lbs/1,000,000 cubic feet (ft3) natural gas 84 lbs/1,000,000 ft3 natural gas lbs/1,000,000 ft3 natural gas 7.6 lbs/1,000,000 ft3 natural gas 0.6 lbs/1,000,000 ft3 natural gas 5.5 lbs/1,000,000 ft3 natural gas Current Heating Units Pollutant Calculations Location Description Mfg. Model No. Serial No. Rate Input (Btu/hr) NOx (lbs per year) CO (lbs per year) Lead (Pb) (lbs per year) PM (lbs per year) SO2 (lbs per year) VOC (lbs per year) Assembly Unit Heater Reznor FT-150 AXD71U2U61813X 150, Assembly Unit Heater Reznor FT-150 AXD71U2N61793X 150, Assembly Unit Heater Reznor FT-150 AYA71U2N30516X 150, Assembly Unit Heater Reznor FT-150 AXC71U2N57923X 150, Main Office Forced Air Rheem RGEB-12EE-JS HN5D307 F , Main Office Forced Air Rheem RGEB-12EE-JS F , Main Office Forced Air Rheem RGEB-12EE-JS F , Maintenance Unit Heater Reznor UDAP75 BBD79X7N55946X 75, Maintenance Unit Heater Reznor UDAP75 BBD79X7N55948X 75, Parts Roof Top Trane Lochinvar YCD090c3HCBE R D 90, Parts MUA Titan TA-225NGH2H G904 3,630,000 3, , Parts Unit Heater Reznor UDAP150 BME796EN , Parts Unit Heater Reznor 250, Foam Room Unit Heater Reznor B125-E BIL95M4N28121X 125, Proto Shop Forced Air Bryant 350MAJ A6 110, Proto Shop Unit Heater Lennox G8-110C 5169B 110, Proto Shop Unit Heater Modive PAE145C , Respirator CLN - Crestliner Assembly - Life Breath GO ELE PFFC , Shipping / receiving Boiler UNK RBN , Shipping / receiving Unit Heater Reznor FT-150 AYA71U2n29942X 150, Shipping / receiving Unit Heater Reznor FT-200 AYA71U2N30507X 200, Test Tank Building Unit Heater ADP CUHN-75A K , Test Tank Building Unit Heater ADP CUHN-75A K , Wood Shop Boiler UNK EBN300 I , Wood Shop Unit Heater Reznor Lochinvar FT-150 AYI71U2N91306X 150, Paint Booth 1 - EU001 Paint Booth 2 - EU002 Paint Booth 3 - EU003 Paint Booth 4 - EU004 Paint Booth 5 - EU015 Air Makeup Air Makeup Titan Tecor Inc NG HRH DA AR TT 218 HHR ,080,000 1,663,200 2, , , , Rework - EU012 Air Makeup Titan TA-225NG HRH DA ,630,000 3, , Autowash Oven Air Makeup Eclipse AH ,000,000 1, , Paint Line Oven 1 Air Makeup Air Heat 1ABXR ,300,000 1, Paint Line Oven 2 Air Makeup Eclipse ,300,000 1, Paint Line Oven 3 Air Makeup Tecor Inc. AR TT 218 HHL Indoor ,458,000 1, , South pass Unit Heater Reznor SCVV3 UDAP150 UNK 150, South pass Unit Heater Reznor SCVV3 UDAP150 UNK 150, Finishing Unit Heater Reznor UDAP150 BLH79Y3N71227X 250, Finishing Unit Heater Advanced Dist. SEP-175A K , Finishing West Unit Heater Reznor UDAP200 BKE79U2N00289X 200, Finishing West Unit Heater Reznor UDAP200 BKE79U2N00290X 200, Warehouse Loading Unit Heater Lennox LF-300A-M , Warehouse Loading Unit Heater Reznor FE165 AVE66M4N , Warehouse Offices Forced Air Bryant 350MAVO AIU973 80, Westbay Unit Heater Reznor UDAP250 BIJ79Y3Ni655X 250, Receiving Forced Air Bryant 350MAVO A , Proposed Heating Units - New Building South Buildout Up Gas Furnace Carrier 595C5A 0414A , South Buildout Down Gas Furnace Carrier 595C5A 0114A , North Buildout Up Gas Furnace Carrier 595C5A 0114A , North Buildout Down Gas Furnace Carrier 595C5A 5013A , North Air Exchange Air Exchange Titan TA130 NG HRH ,750,000 2, , South Air Exchange Air Exchange Titan TA130 NG HRH ,750,000 2, , NW Finishing Unit Heater Reznor UDAP200 BNA796EN68859X 200, NW Finishing 2 Unit Heater Reznor UDAP200 BNA796EN68861X 200, Loading Unit Heater Reznor UDAP200 BNA796EN68776X 200, NE Finishing Unit Heater Reznor UDAP200 BML796EN65657X 200, N Assembly Unit Heater Reznor UDAP200 BNA796EN68812X 200, S Assembly Unit Heater Reznor UDAP200 BNA796EN68816X 200, Loading Water Heater AO Smith BTH M , Loading Side Boiler Prestige Solo 175 PT , Paint Booth 7 - EU018 Air Makeup Global Finishing SoluRam /2 2,592,000 2, , Paint Booth 6 - EU017 Air Makeup Global Finishing SoluRam /2 2,592,000 2, , Paint Oven Air Makeup Global Finishing SoluGBO TM 1,500,000 1, , Rework Booth #2 (EU020) Proposed TBD TBD TBD 1,300,000 1, Total NOx (tpy) CO (tpy) Lead (Pb) (tpy) PM (tpy) SO2 (tpy) VOC (tpy) Totals 38,727,

25 PTE CO2 and CO 2e Calculations Freshwater Boats / New York Mills, MN #/hr MMBTU CO 2 #/hr MMBTU CH 4 #/hr MMBTU N 20 CO2e GWP CO2e GWP CO2e GWP Current Heating Units Location Description Mfg. Model No. Serial No. Rate Input (Btu/hr) CO 2 Emis tons CH 4 Emis tons N 20 Emis tons CO 2 as CO2e CH 4 as CO2e N 20 as CO2e Assembly Unit Heater Reznor FT-150 AXD71U2U61813X 150, Assembly Unit Heater Reznor FT-150 AXD71U2N61793X 150, Assembly Unit Heater Reznor FT-150 AYA71U2N30516X 150, Assembly Unit Heater Reznor FT-150 AXC71U2N57923X 150, Main Office Forced Air Rheem RGEB-12EE-JS HN5D307 F , Main Office Forced Air Rheem RGEB-12EE-JS F , Main Office Forced Air Rheem RGEB-12EE-JS F , Maintenance Unit Heater Reznor UDAP75 BBD79X7N55946X 75, Maintenance Unit Heater Reznor UDAP75 BBD79X7N55948X 75, Parts Roof Top Trane Lochinvar YCD090c3HCBE R D 90, Parts MUA Titan TA-225NGH2H G904 3,630,000 1, , Parts Unit Heater Reznor UDAP150 BME796EN , Parts Unit Heater Reznor 250, Foam Room Unit Heater Reznor B125-E BIL95M4N28121X 125, Proto Shop Forced Air Bryant 350MAJ A6 110, Proto Shop Unit Heater Lennox G8-110C 5169B 110, Proto Shop Unit Heater Modive PAE145C , Respirator CLN - Crestliner Assembly - Life Breath GO ELE PFFC , Shipping / receiving Boiler UNK RBN , Shipping / receiving Unit Heater Reznor FT-150 AYA71U2n29942X 150, Shipping / receiving Unit Heater Reznor FT-200 AYA71U2N30507X 200, Test Tank Building Unit Heater ADP CUHN-75A K , Test Tank Building Unit Heater ADP CUHN-75A K , Wood Shop Boiler UNK EBN300 I , Wood Shop Unit Heater Reznor Lochinvar FT-150 AYI71U2N91306X 150, Paint Booth 1 - EU001 Paint Booth 2 - EU002 Paint Booth 3 - EU003 Paint Booth 4 - EU004 Paint Booth 5 - EU015 (West Bay) Air Makeup Air Makeup Titan Tecor Inc NG HRH DA AR TT 218 HHR ,080,000 1,663,200 1, , Rework - EU012 Air Makeup Titan TA-225NG HRH DA ,630,000 1, , Autowash Oven Air Makeup Eclipse AH ,000,000 1, , Paint Line Oven 1 Air Makeup Air Heat 1ABXR ,300, Paint Line Oven 2 Air Makeup Eclipse ,300, Paint Line Oven 3 Air Makeup Tecor Inc. AR TT 218 HHL Indoor ,458, South pass Unit Heater Reznor SCVV3 UDAP150 UNK 150, South pass Unit Heater Reznor SCVV3 UDAP150 UNK 150, Finishing Unit Heater Reznor UDAP150 BLH79Y3N71227X 250, Finishing Unit Heater Advanced Dist. SEP-175A K , Finishing West Unit Heater Reznor UDAP200 BKE79U2N00289X 200, Finishing West Unit Heater Reznor UDAP200 BKE79U2N00290X 200, Warehouse Loading Unit Heater Lennox LF-300A-M , Warehouse Loading Unit Heater Reznor FE165 AVE66M4N , Warehouse Offices Forced Air Bryant 350MAVO AIU973 80, Westbay Unit Heater Reznor UDAP250 BIJ79Y3Ni655X 250, Receiving Forced Air Bryant 350MAVO A , Proposed Heating Units - New Building South Buildout Up Gas Furnace Carrier 595C5A 0414A South Buildout Down Gas Furnace Carrier 595C5A 0114A , North Buildout Up Gas Furnace Carrier 595C5A 0114A , North Buildout Down Gas Furnace Carrier 595C5A 5013A , North Air Exchange Air Exchange Titan TA130 NG HRH ,750,000 1, , South Air Exchange Air Exchange Titan TA130 NG HRH ,750,000 1, , NW Finishing Unit Heater Reznor UDAP200 BNA796EN68859X 200, NW Finishing 2 Unit Heater Reznor UDAP200 BNA796EN68861X 200, Loading Unit Heater Reznor UDAP200 BNA796EN68776X 200, NE Finishing Unit Heater Reznor UDAP200 BML796EN65657X 200, N Assembly Unit Heater Reznor UDAP200 BNA796EN68812X 200, S Assembly Unit Heater Reznor UDAP200 BNA796EN68816X 200, Loading Water Heater AO Smith BTH M , Loading Side Boiler Prestige Solo 175 PT , Paint Booth 7 - EU018 Air Makeup Global Finishing Solutions Ram /2 2,592,000 1, , Paint Booth 6 - EU019 Air Makeup Global Finishing Solutions Ram /2 2,592,000 1, , Paint Oven Air Makeup Global Finishing Solutions GBO TM 1,500, Repaint Booth (EU020) Proposed TBD TBD TBD 1,300, Total 38,727,600 19, , , tons lb/hr 4, , , Metric tons

26 hp Pollutant Number of units* 2013 hp-hr 2 min per boat) , , , , , , Subtotal 116 1, , Emission Factor (lb/hp-hr) lbs/year emissions NOx CO 6.96E SOx 5.91E PM E Aldehydes 4.85E CO Engine Testing Calculations Insignificant Activity Freshwater Boats / New York Mills, MN Page 13

27 Metal Conditioner F-10-LF consists of: 9.1% Hydrogen Flouride 10% Hydrochloric Acid 25% Phosphoric Acid 56% water solution F-10-LF Annual Air Emission - NYM Metal Conditioner Solution Makeup 38 gallons metal conditioner mixed into a 877 gallon solution with water Results in Solution with 4.33% Metal Conditioners and 95.67% water Assumptions The liquid vapor (water plus solution) being emitted from the stack of the AutoWash System is identical to the makeup of the conditioner solution. This would be the extreme situtation, and probably not possible, but used for overly conservative calculation purposes. Humidity at 50% Temperature at 20 degrees C Other Info Spraying of Conditioner solution in the AutoWash process occurs 120 seconds of a 18 minute cycle. Additional 1 minute to move completed boat out and new boat into AutoWash system Blower capacity at 1500 cfm Calculation Weight of Water Vapor at 50% humidity and 20 degrees C = 8.7 grams per cubic meter = lbs per cubic foot X X X X lb/cubic foot Weight of water vapor in System 1500 cfm Blower Capacity lb/minute Mixture (water & acid) 525,600 minutes Number of Minutes in 1 Year 427,312.8 lb per year Weight of water vapor emitted from System annually (without considering Cycle Time Percentage) percent Percentage of Time Solution in Sprayed and Emitted per Cycle 44, lb per year Weight of water vapor emitted from System annually (with Cycle Time Percentage) percent Percentage of Cleaner in Solution 1, lb per year Weight of Cleaner Solution emitted from System annually percent Percentage of Hydrogen Fluoride in Cleaner in Solution lb per year Total Weight of Hyrdorgen Fluoride Emitted from System annually MPCA Deminimis Limit for Hydrogen Fluoride Emission ( ) = 0.1 tons per year = 200 pounds per year Emission is Insignificant

28 Summary Unlimited Emissions (tpy) PM PM10 PM2.5 VOC NOx SO2 CO CO2e Cumene Ethylbenzene MIK Styrene Tolune Xylene Total HAPS Paint Booths , Cleaning Area Finishing Area Upholstery Area Woodshop Insignificant Activities , Total , , ,214 1,165 Unlimited Emissions (lb/hr) PM PM10 PM2.5 VOC NOx SO2 CO CO2e Cumene Ethylbenzene MIK Styrene Tolune Xylene Total HAPS Paint Booths Cleaning Area Finishing Area Upholstery Area Woodshop Insignificant Activities , Total , Limited Controlled Emissions (tpy) PM PM10 PM2.5 VOC NOx SO2 CO CO2e Total HAPS Paint Booths Cleaning Area Finishing Area Upholstery Area Woodshop Insignificant Activities ,879 0 Total ,

29 Attachment 2 Facility Description and CD-01 Forms

30 MINNESOTA POLLUTION CONTROL AGENCY AIR QUALITY 520 LAFAYETTE ROAD ST. PAUL, MN October, :17 FACILITY DESCRIPTION: BUILDINGS (BG) Show: Active and Pending Records Action: PER 003 AQD Facility ID: Facility Name: Lund Boat Co ID No. Added Retired Operator ID for Item Length (feet) Width (feet) Roof Height from Ground (feet) Description/Comment Building Status 1 BG 001 PER Parts/Aluminum Routing Area Active 2 BG 002 PER Painting Area Active 3 BG 003 PER Wood Shop Carpet Area Active 4 BG 004 PER Assembly Welding Area Active 5 BG 005 PER Assembly Foaming Area Active 6 BG 006 PER Proto Shop Active 7 BG 007 PER Finishing/Cleaning Area Active 8 BG 008 PER Fish Boat Production, Shipping, Kitting Active 9 BG 009 PER New Manufacturing Building Active Page 1 of 1

31 MINNESOTA POLLUTION CONTROL AGENCY AIR QUALITY 520 LAFAYETTE ROAD ST. PAUL, MN October, :17 FACILITY DESCRIPTION: GROUPS (GP) Show: Action: AQD Facility ID: Facility Name: Active and Pending Records PER Lund Boat Co ID No. Group Status Added Retired Include in EI Operator ID for Item Group Description Group Items 1 GP 001 Active PER 002 Spray painting CE 001, CE 002, CE 003, CE 004, CE 007, EU 001, EU 002, EU 003, EU 004, EU 007, EU GP 001 Active PER 003 Spray Booth Control Equipment Requirements CE 001, CE 002, CE 003, CE 004, CE 007, CE 008, CE 009, CE 010, CE 012, EU 001, EU 002, EU 003, EU 004, EU 007, EU 012, EU 015, EU 017, EU 018, EU 019, EU GP 002 PER 002 Surface coating, cleaning, and adhesives application EU 001, EU 002, EU 003, EU 004, EU 009, EU 010, EU 011, EU 012 Active 4 GP 002 Active PER 003 PreCap: VOCs EU 001, EU 002, EU 003, EU 004, EU 009, EU 010, EU 011, EU 012, EU 015, EU 016, EU 017, EU 018, EU 019, EU 020, EU 021, EU 022, EU 023, EU GP 003 PER 002 Sources Subject to Subp. VVVV EU 001, EU 002, EU 003, EU 004, EU 011, EU 012 Active 6 GP 003 Active PER 003 Sources Subject to Subp. VVVV EU 001, EU 002, EU 003, EU 004, EU 011, EU 012, EU 015, EU 016, EU 017, EU 018, EU 019, EU 020, EU 021, EU GP 004 Active PER 003 PreCap: Particulate Matter EU 001, EU 002, EU 003, EU 004, EU 012, EU 015, EU 017, EU 018, EU 019, EU GP 005 PER 003 Insignificant Activity Emissions Active Page 1 of 1

32 MINNESOTA POLLUTION CONTROL AGENCY AIR QUALITY 520 LAFAYETTE ROAD ST. PAUL, MN October, :18 FACILITY DESCRIPTION: STACK/VENTS (SV) Show: Active and Pending Records Action: PER 003 AQD Facility ID: Facility Name: Lund Boat Co ID No. Stack/ Vent Status Added Retired Operator ID for Item Operators Description Height of Opening From Ground (feet) Inside Dimensions Diameter or Length (feet) Width (feet) Design Flow Rate at Top (ACFM) Exit Gas Temperature at Top (ºF) Flow Rate/ Temperature Information Source Discharge Direction 1 SV 001 Active PER Test Up, With Cap 2 SV 002 Active PER Test Up, With Cap 3 SV 003 Active PER Test Up, With Cap 4 SV 004 Active PER Test Up, With Cap 5 SV 005 Active PER Manufacturer Up, With Cap 6 SV 005 Removed PER Manufacturer Up, With Cap 7 SV 006 Active PER Manufacturer Up, With Cap 8 SV 006 Active PER Manufacturer Up, No Cap 9 SV 007 Active PER Manufacturer Up, With Cap 10 SV 007 Removed PER Manufacturer Up, With Cap 11 SV 008 Active PER Test Up, With Cap 12 SV 009 Active PER Test Up, With Cap 13 SV 010 Active PER Test Up, With Cap 14 SV 011 Active PER 002 Paint Line Oven 15 SV 011 Active PER 003 Rework Booth Test Up, With Cap 16 SV 012 Active PER 003 Paint Spray Booth Manufacturer Up, With Cap 17 SV 014 Active PER 003 Upholstery Area-West Manufacturer Up, With Cap 18 SV 015 Active PER 003 Upholstery Area-West Manufacturer Up, With Cap 19 SV 018 Active PER 003 Paint Spray Booth Manufacturer Up, With Cap 20 SV 019 Active PER 003 Paint Spray Booth Manufacturer Up, With Cap 21 SV 024 Active PER 003 Rework Booth 2 22 SV 025 Active PER 003 Upholstery Area Manufacturer Horizontal 23 SV 026 Active PER 003 Page 1 of 1

33 MINNESOTA POLLUTION CONTROL AGENCY AIR QUALITY 520 LAFAYETTE ROAD ST. PAUL, MN October, :19 FACILITY DESCRIPTION: EMISSION UNIT (EU) Show: Action: PER 003 AQD Facility ID: Facility Name: ID No. Active and Pending Records Lund Boat Co Emission Unit Status Added Retired Insignificant Activity Operator ID for Item Stack/ Vent ID No(s). Control Equip. ID No(s). Operator Description 1 EU 001 Active PER 001 SV 001 (M) CE 001 Paint Booth No 1 2 EU 001 Active PER 003 SV 001 (M) CE 001 Paint Booth No. 1 - Spray Booth/Coating Line 3 EU 002 Active PER 001 SV 002 (M) CE 002 Paint Booth No 2 4 EU 002 Active PER 003 SV 002 (M) CE 002 Paint Booth No. 2 - Spray Booth/Coating Line 5 EU 003 Active PER 001 SV 003 (M) CE 003 Paint Booth No 3 6 EU 003 Active PER 003 SV 003 (M) CE 003 Paint Booth No 3. - Spray Booth/Coating Line 7 EU 004 Active PER 001 SV 004 (M) CE 004 Paint Booth No 4 8 EU 004 Active PER 003 SV 004 (M) CE 004 Paint Booth No 4. - Spray Booth/Coating Line Manufacturer Model Number SIC Max. Design Capacity Materials Maximum Design Capacity Binks Gal Binks Gal Binks Gal Binks Gal Binks Gal Binks Gal Binks Gal Binks Gal Units n Units d 9 EU 005 Active PER 002 Paint Line Oven Wisconsin Oven Product Each Hr 10 EU 005 Removed PER 003 Paint Line Oven Wisconsin Oven Product Each Hr 11 EU 006 Active PER 001 SV 006 (M) Woodshop Dust Control Dust Vent 23T Ft3(s) Min System 12 EU 006 Active PER 003 SV 006 (M) CE 005 Woodshop Dust Control System Weima WLK Ft3(s) 13 EU 007 Removed PER 002 SV 007 (M) Woodshop Spray Booth NA Gal Hr 14 EU 007 Removed PER 003 SV 007 (M) Woodshop Spray Booth - NA Gal Hr Sawing Equipment 15 EU 008 Active PER 002 SV 002 (P) Foaming Area SV 003 (P) SV 004 (P) 16 EU 008 Removed PER 003 SV 002 (P) Foaming Area SV 003 (P) SV 004 (P) 17 EU 009 Active PER 001 SV 001 (P) SV 002 (P) SV 003 (P) SV 004 (P) Cleaning Area NA Product Each NA Product Each NA Product Each 18 EU 009 Active PER 003 Cleaning Area - Cleaning NA Product Each Hr Hours Equipment Hr Hr Hr Hr Hr Hr Hr Hr Min Hr Hr Hr Max Fuel Input (mil Btu) Page 1 of 2 (a)

34 7 October, :19 FACILITY DESCRIPTION: EMISSION UNIT (EU) ID No. Emission Unit Status Added Commence Const. Date Initial Startup Date Removal Date Firing Method Pct. Fuel/ Space Heat Bottleneck Elevator Type 1 EU 001 Active PER /31/ EU 001 Active PER /31/ EU 002 Active PER /31/ EU 002 Active PER /31/ EU 003 Active PER /31/ EU 003 Active PER /31/ EU 004 Active PER /30/ EU 004 Active PER /30/ EU 005 Active PER /15/1975 Whole Facility 10 EU 005 Removed PER /15/1975 Whole Facility 11 EU 006 Active PER EU 006 Active PER /15/ EU 007 Removed PER /15/ /31/ EU 007 Removed PER /15/ /31/ EU 008 Active PER /31/ EU 008 Removed PER /31/ EU 009 Active PER /31/ EU 009 Active PER /31/1980 Page 1 of 2 (b)

35 MINNESOTA POLLUTION CONTROL AGENCY AIR QUALITY 520 LAFAYETTE ROAD ST. PAUL, MN October, :19 FACILITY DESCRIPTION: EMISSION UNIT (EU) Show: Active and Pending Records Action: PER 003 AQD Facility ID: Facility Name: Lund Boat Co ID No. Emission Unit Status Added Retired Insignificant Activity Operator ID for Item Stack/ Vent ID No(s). Control Equip. ID No(s). 19 EU 010 Active PER 001 SV 001 (P) SV 002 (P) SV 003 (P) SV 004 (P) Finishing Area Operator Description Manufacturer Model Number SIC Max. Design Capacity Materials Maximum Design Capacity NA Gal Units n Units d 20 EU 010 Active PER 003 Finishing Area - Finishing NA Gal Hr Equipment 21 EU 011 Active PER 001 SV 008 (P) Upholstery Shop SV 009 (P) NA Gal 22 EU 011 Active PER 003 SV 008 (P) Upholstery Area - East - NA Gal Hr Adhesion Equipment 23 EU 012 Active PER 001 SV 010 (M) CE 007 Re-work Booth 24 EU 012 Active PER 003 SV 010 (M) CE 007 Re-work Booth No. 1 - Spray SV 011 Booth/Coating Line Binks Gal Binks Gal 25 EU 013 Active PER 002 SV 007 (M) Dip Tank EU 013 Removed PER 003 Dip Tank EU 014 Active PER 002 Paint Line Oven EU 014 Removed PER 003 Paint Line Oven EU 015 Active PER 003 SV 012 (M) CE 008 Paint Spray Booth No. 5 - Spray Booth/Coating Line 30 EU 016 Active PER 003 SV 014 (M) Upholstery Area West - SV 015 (M) Adhesion Equipment TECOR Gal N/A Gal 31 EU 017 Active PER 003 SV 019 (M) CE 009 Paint Spray Booth No. 6 - Global Finishing 3732 Spray Booth/Coating Line 32 EU 018 Active PER 003 SV 018 (M) CE 010 Paint Spray Booth No. 7 - Spray Booth/Coating Line 33 EU 020 Active PER 003 SV 024 (M) CE 012 Re-Work Booth No. 2 - Spray Booth/Coating Line Global Finishing Gal TBD Gal 34 EU 021 Active PER 003 SV 025 Upholstery Area - Adhesion 3732 Equipment 35 EU 022 Active PER 003 Upholstery Area - South Adhesion Equipment 36 EU 023 Active PER 003 Cleaning Area - Cleaning 3732 Equipment 37 EU 024 Active PER 003 Finishing Area - Finishing 3732 Equipment Hr Hr Hr Hr Hr Hr Hr Hr Max Fuel Input (mil Btu) Page 2 of 2 (a)

36 7 October, :19 FACILITY DESCRIPTION: EMISSION UNIT (EU) ID No. Emission Unit Status Added Commence Const. Date Initial Startup Date Removal Date Firing Method Pct. Fuel/ Space Heat Bottleneck Elevator Type 19 EU 010 Active PER /31/ EU 010 Active PER /31/ EU 011 Active PER /15/ EU 011 Active PER /15/ EU 012 Active PER /01/ /01/ EU 012 Active PER /01/ /01/ EU 013 Active PER EU 013 Removed PER /07/ EU 014 Active PER EU 014 Removed PER EU 015 Active PER /01/ /15/ EU 016 Active PER /01/ EU 017 Active PER /22/ EU 018 Active PER /22/ EU 020 Active PER EU 021 Active PER /22/ EU 022 Active PER /01/ EU 023 Active PER /22/ EU 024 Active PER /22/2013 Page 2 of 2 (b)

37 MINNESOTA POLLUTION CONTROL AGENCY AIR QUALITY 520 LAFAYETTE ROAD ST. PAUL, MN October, :19 FACILITY DESCRIPTION: CONTROL EQUIPMENT (CE) Show: Active and Pending Records Action: PER 003 AQD Facility ID: Facility Name: Lund Boat Co ID No. Control Equip. Status Added Retired Operator ID for Item Control Equip. Type Control Equipment Description Manufacturer Model Pollutants Controlled Capture Efficiency (%) Destruction/ Collection Efficiency (%) Afterburner Combustion Parameters 1 CE 001 Active PER Mat or Panel Filter 2 CE 001 Active PER Mat or Panel Filter 3 CE 002 Active PER Mat or Panel Filter 4 CE 002 Active PER Mat or Panel Filter 5 CE 003 Active PER Mat or Panel Filter 6 CE 003 Active PER Mat or Panel Filter 7 CE 004 Active PER Mat or Panel Filter 8 CE 004 Active PER Mat or Panel Filter 9 CE 005 Active PER Fabric Filter - Low Temperature, i.e., T<180 Degrees F PM CE 006 Removed PER Mat or Panel Filter PM CE 007 Active PER Mat or Panel Filter 12 CE 007 Active PER Mat or Panel Filter 13 CE 008 Active PER Mat or Panel Filter 14 CE 009 Active PER Mat or Panel Filter PM10 PM PM2.5 PM10 PM10 PM PM PM10 PM PM2.5 PM10 PM10 PM PM PM10 PM PM2.5 PM10 PM10 PM PM PM10 PM PM2.5 PM10 PM10 PM PM PM10 PM PM2.5 PM10 PM10 PM PM PM2.5 PM10 PM Page 1 of 2

38 MINNESOTA POLLUTION CONTROL AGENCY AIR QUALITY 520 LAFAYETTE ROAD ST. PAUL, MN October, :19 FACILITY DESCRIPTION: CONTROL EQUIPMENT (CE) Show: Active and Pending Records Action: PER 003 AQD Facility ID: Facility Name: Lund Boat Co ID No. Control Equip. Status Added Retired Operator ID for Item Control Equip. Type Control Equipment Description Manufacturer Model Pollutants Controlled Capture Efficiency (%) Destruction/ Collection Efficiency (%) Afterburner Combustion Parameters 15 CE 010 Active PER Mat or Panel Filter PM2.5 PM10 PM CE 012 Active PER Mat or Panel Filter PM2.5 PM10 PM Page 2 of 2