Air Individual Permit, State Permit Reissuance No. …...Fiscal Services – 6th Floor Minnesota...

Air Individual Permit

State Reissuance 05300411-101

Permittee: Enviro-Chem Inc - Plant 1

Facility name: Enviro-Chem Inc - Plant 1 21821 Industrial Blvd Rogers, 55374-9575 Hennepin County, Minnesota

Expiration date: March 11, 2025 * All Title I Conditions do not expire State Reissuance: March 11, 2020 Permit characteristics: State; Nonmajor for Part 70/ True minor for NSR The emission units, control equipment and emission stacks at the stationary source authorized in this permit reissuance are as described in the submittals listed in the Permit Applications Table. This permit reissuance supersedes Air Emission Permit No. 05300411- 001 and authorizes the Permittee to operate the stationary source at the address listed above unless otherwise noted in the permit. The Permittee must comply with all the conditions of the permit. Any changes or modifications to the stationary source must be performed in compliance with Minn. R. 7007.1150 to 7007.1500. Terms used in the permit are as defined in the state air pollution control rules unless the term is explicitly defined in the permit. Unless otherwise indicated, all the Minnesota rules cited as the origin of the permit terms are incorporated into the SIP under 40 CFR § 52.1220 and as such are enforceable by U.S. Environmental Protection Agency (EPA) Administrator or citizens under the Clean Air Act.

Signature: Toni Volkmeier This document has been electronically signed. for the Minnesota Pollution Control Agency

for Carolina Espejel-Schutt, P.E., Acting Manager Air Quality Permits Section Industrial Division

Permit issued: March 11, 2020 05300411-101 Permit expires: March 11, 2025 Page 2 of 26

Table of Contents

Page

1. Permit applications table ............................................................................................................................................. 3 2. Where to send submittals ............................................................................................................................................ 4 3. Facility description ....................................................................................................................................................... 5 5. Limits and other requirements .................................................................................................................................... 8 6. Submittal/action requirements ................................................................................................................................. 21 7. Compliance schedule ................................................................................................................................................. 23 8. Appendices ................................................................................................................................................................. 24

Appendix A. Insignificant activities and general applicable requirements .............................................................. 24 Appendix B: Industrial Solid Waste Management Plan ........................................................................................... 25 Appendix C: Ash Management Plan ......................................................................................................................... 26 Appendix D: Mercury Waste Separation Plan ......................................................................................................... 26


1. Permit applications table

Permit applications:

Title description Application receipt date Action number

State Reissuance 11/22/2011, with supplemental information received on 11/08/2019

05300411-101

Minor Amendment 07/28/2016 05300411-101

Reopening 02/11/2011 05300411- 101


2. Where to send submittals

Send submittals that are required to be submitted to the EPA regional office to: Chief Air Enforcement Air and Radiation Branch EPA Region V 77 West Jackson Boulevard Chicago, Illinois 60604

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

Send submittals that are required by the Acid Rain Program to:

U.S. Environmental Protection Agency Clean Air Markets Division 1200 Pennsylvania Avenue NW (6204N) Washington, D.C. 20460

Send any application for a permit or permit amendment to:

Fiscal Services – 6th Floor Minnesota Pollution Control Agency 520 Lafayette Road North St. Paul, Minnesota 55155-4194

Also, where required by an applicable rule or permit condition, send to the Permit Document Coordinator notices of:

a. Accumulated insignificant activities b. Installation of control equipment c. Replacement of an emissions unit, and d. Changes that contravene a permit term

Unless another person is identified in the applicable Table, send all other submittals to:

AQ Compliance Tracking Coordinator Industrial Division Minnesota Pollution Control Agency 520 Lafayette Road North St. Paul, Minnesota 55155-4194

Or Email a signed and scanned PDF copy to: [email protected] (for submittals related to stack testing) [email protected] (for other compliance submittals) (See complete email instructions in “Routine Air Report Instructions Letter” at http://www.pca.state.mn.us/nwqh472.)


3. Facility description

The Enviro-Chem Inc - Plant 1 (Facility) is located at 21821 Industrial Boulevard in Rogers, Hennepin County, Minnesota. Enviro-Chem operates six incinerator units that combust film to recover the silver. These units qualify as Class IV waste combustors. Film is combusted three times a week (one day of incineration followed by one day of cooling). After about a month, the silver-rich ash is collected from the incinerators and sold. The incinerators are ducted into a baghouse. The main pollutants of concern are particulate matter (PM), particulate matter 10 micrometers or less in diameter (PM10), particulate matter 2.5 micrometers or less in diameter (PM2.5), carbon monoxide (CO), and volatile organic compounds (VOCs). The incinerators are vented to afterburners to control CO and VOCs, and then are vented to a baghouse to control PM, PM10, and PM2.5. The smelting operations consist of three crucible furnaces. Miscellaneous metal scraps and metal powders are smelted to recover the precious metals and copper. The main pollutants of concern are PM, PM10, PM2.5, and VOCs. The smelting furnaces EQUI 10 and EQUI 12 vent to a baghouse (TREA 17) to control PM, PM10 and PM2.5.


4. Summary of subject items

SI ID: Description

Relationship type

Related SI ID: Description

TFAC 1: Enviro-Chem Inc - Plant 1

ACTV 3: All IAs COMG 1: Six Class IV Waste Combustors

has members EQUI 17, EQUI 18, EQUI 19, EQUI 20, EQUI 21, EQUI 22, STRU 1, TREA 6, TREA 8

EQUI 9: Smelting Furnace - Medium Crucible Furnace

sends to STRU 2: General emissions (roof vent)

EQUI 10: Smelting Furnace - Tilt Furnace #1

sends to STRU 1: Baghouse emissions




is controlled by

TREA 17: Fabric Filter - Medium Temperature i.e., 180 F<T<250 F

EQUI 12: Smelting Furnace - Medium Tilt Furnace





is controlled by


EQUI 17: Waste Combustor Film #1



is controlled by

TREA 6: Direct Flame Afterburner


is controlled by

TREA 17: Fabric Filter - Medium Temperature

SI ID: Description

Relationship type

Related SI ID: Description i.e., 180 F<T<250 F




is controlled by



is controlled by





is controlled by



is controlled by





is controlled by



is controlled by


EQUI 21: Waste Combustor (Assay, Small Lot)



is controlled by



is controlled by

TREA 17: Fabric Filter - Medium Temperature i.e., 180


SI ID: Description

Relationship type

Related SI ID: Description F<T<250 F




is controlled by



is controlled by


EQUI 23: Afterburner TREA 6 & TREA 8 Temperature, Baghouse TREA 17 Temperature & Baghouse TREA 17 Pressure Drop Monitor

receives from EQUI 24: Afterburner Temp Probe (TREA 6)


receives from EQUI 25: Afterburner Temp Probe (TREA 6)


receives from EQUI 26: Baghouse Inlet Temperature Probe (TREA 17)


receives from EQUI 27: Baghouse Pressure Drop Probe (TREA 17)

EQUI 24: Afterburner Temp Probe (TREA 6)


EQUI 26: Baghouse Inlet Temperature

SI ID: Description

Relationship type

Related SI ID: Description

Probe (TREA 17) EQUI 27: Baghouse Pressure Drop Probe (TREA 17)

STRU 1: Baghouse emissions

STRU 2: General emissions (roof vent)

STRU 3: Precipitation emissions


is monitored by



is controlled in series by



is monitored by



is controlled in series by



is monitored by

EQUI 26: Baghouse Inlet Temperature Probe (TREA 17)


is monitored by

EQUI 27: Baghouse Pressure Drop Probe (TREA 17)

Permit Issued: March 11, 2020 05300411-101 Permit Expires: March 11, 2025 Page 8 of 26

5. Limits and other requirements

Requirement number Requirement and citation

TFAC 1 Enviro-Chem Inc - Plant 1

5.1.1 Permit Appendices: This permit contains appendices as listed in the permit Table of Contents. The Permittee shall comply with all requirements contained in Appendix A: Insignificant Activities and Applicable Requirements, Appendix B: Industrial Solid Waste Management Plan, Appendix C: Ash Management Plan, and Appendix D: Mercury Waste Separation Plan. [Minn. R. 7007.0800, subp. 2]

5.1.2 PERMIT SHIELD: Subject to the limitations in Minn. R. 7007.1800, compliance with the conditions of this permit shall be deemed compliance with the specific provision of the applicable requirement identified in the permit as the basis of each condition. Subject to the limitations of Minn. R. 7007.1800 and 7017.0100, subp. 2, notwithstanding the conditions of this permit specifying compliance practices for applicable requirements, any person (including the Permittee) may also use other credible evidence to establish compliance or noncompliance with applicable requirements. This permit shall not alter or affect the liability of the Permittee for any violation of applicable requirements prior to or at the time of permit issuance. [Minn. R. 7007.1800(A)(2)]

5.1.3 Circumvention: Do not install or use a device or means that conceals or dilutes emissions, which would otherwise violate a federal or state air pollution control rule, without reducing the total amount of pollutant emitted. [Minn. R. 7011.0020]

5.1.4 Air Pollution Control Equipment: Operate all pollution control equipment whenever the corresponding process equipment and emission units are operated. [Minn. R. 7007.0800, subp. 16(J), Minn. R. 7007.0800, subp. 2]

5.1.5 Operation and Maintenance Plan: Retain at the stationary source an operation and maintenance plan for all air pollution control equipment. At a minimum, the O & M plan shall identify all air pollution control equipment and control practices and shall include a preventative maintenance program for the equipment and practices, a description of (the minimum but not necessarily the only) corrective actions to be taken to restore the equipment and practices to proper operation to meet applicable permit conditions, a description of the employee training program for proper operation and maintenance of the control equipment and practices, and the records kept to demonstrate plan implementation. [Minn. R. 7007.0800, subp. 14, Minn. R. 7007.0800, subp. 16(J)]

5.1.6 Operation Changes: In any shutdown, breakdown, or deviation the Permittee shall immediately take all practical steps to modify operations to reduce the emission of any regulated air pollutant. The Commissioner may require feasible and practical modifications in the operation to reduce emissions of air pollutants. No emissions units that have an unreasonable shutdown or breakdown frequency of process or control equipment shall be permitted to operate. [Minn. R. 7019.1000, subp. 4]

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

5.1.8 Noise: The Permittee shall comply with the noise standards set forth in Minn. R. 7030.0010 to 7030.0080 at all times during the operation of any emission units. This is a state only requirement and is not enforceable by the EPA Administrator or citizens under the Clean Air Act. [Minn. R. 7030.0010-7030.0080]

5.1.9 Inspections: The Permittee shall comply with the inspection procedures and requirements as found in Minn. R. 7007.0800, subp. 9(A). [Minn. R. 7007.0800, subp. 9(A)]

5.1.10 The Permittee shall comply with the General Conditions listed in Minn. R. 7007.0800, subp. 16. [Minn. R. 7007.0800, subp. 16]

5.1.11 Performance Testing: Conduct all performance tests in accordance with Minn. R. ch. 7017 unless


Requirement number Requirement and citation otherwise noted in this permit. [Minn. R. ch. 7017]

5.1.12 Performance Test Notifications and Submittals: Performance Test Notification and Plan: due 30 days before each Performance Test Performance Test Pre-test Meeting: due 7 days before each Performance Test Performance Test Report: due 45 days after each Performance Test The Notification, Test Plan, and Test Report must be submitted in a format specified by the commissioner. [Minn. R. 7017.2017, Minn. R. 7017.2030, subps. 1-4, Minn. R. 7017.2035, subps. 1-2]

5.1.13 Limits set as a result of a performance test (conducted before or after permit issuance) apply until superseded as stated in the MPCA's Notice of Compliance letter granting preliminary approval. Preliminary approval is based on formal review of a subsequent performance test on the same unit as specified by Minn. R. 7017.2025, subp. 3. The limit is final upon issuance of a permit amendment incorporating the change. [Minn. R. 7017.2025, subp. 3]

5.1.14 Monitoring Equipment Calibration - The Permittee shall either: 1. Calibrate or replace required monitoring equipment every 12 months; or 2. Calibrate at the frequency stated in the manufacturer's specifications. For each monitor, the Permittee shall maintain a record of all calibrations, including the date conducted, and any corrective action that resulted. The Permittee shall include the calibration frequencies, procedures, and manufacturer's specifications (if applicable) in the Operations and Maintenance Plan. [Minn. R. 7007.0800, subp. 4(D)]

5.1.15 Operation of Monitoring Equipment: Unless noted elsewhere in this permit, monitoring a process or control equipment connected to that process is not necessary during periods when the process is shutdown, or during checks of the monitoring systems, such as calibration checks and zero and span adjustments. If monitoring records are required, they should reflect any such periods of process shutdown or checks of the monitoring system. [Minn. R. 7007.0800, subp. 4(D)]

5.1.16 Recordkeeping: Retain all records at the stationary source, unless otherwise specified within this permit, for a period of five (5) years from the date of monitoring, sample, measurement, or report. Records which must be retained at this location include all calibration and maintenance records, all original recordings for continuous monitoring instrumentation, and copies of all reports required by the permit. Records must conform to the requirements listed in Minn. R. 7007.0800, subp. 5(A). [Minn. R. 7007.0800, subp. 5(C)]

5.1.17 Recordkeeping: Maintain records describing any insignificant modifications (as required by Minn. R. 7007.1250, subp. 3) or changes contravening permit terms (as required by Minn. R. 7007.1350, subp. 2), including records of the emissions resulting from those changes. [Minn. R. 7007.0800, subp. 5(B)]

5.1.18 If the Permittee determines that no permit amendment or notification is required prior to making a change, the Permittee must retain records of all calculations required under Minn. R. 7007.1200. For expiring permits, these records shall be kept for a period of five years from the date the change was made or until permit reissuance, whichever is longer. The records shall be kept at the stationary source for the current calendar year of operation and may be kept at the stationary source or office of the stationary source for all other years. The records may be maintained in either electronic or paper format. [Minn. R. 7007.1200, subp. 4]

5.1.19 Shutdown Notifications: Notify the Commissioner at least 24 hours in advance of a planned shutdown of any control equipment or process equipment if the shutdown would cause any increase in the emissions of any regulated air pollutant. If the owner or operator does not have advance knowledge of the shutdown, notification shall be made to the Commissioner as soon as possible after the


Requirement number Requirement and citation shutdown. However, notification is not required in the circumstances outlined in items A, B, and C of Minn. R. 7019.1000, subp. 3. At the time of notification, the owner or operator shall inform the Commissioner of the cause of the shutdown and the estimated duration. The owner or operator shall notify the Commissioner when the shutdown is over. [Minn. R. 7019.1000, subp. 3]

5.1.20 Breakdown Notifications: Notify the Commissioner within 24 hours of a breakdown of more than one hour duration of any control equipment or process equipment if the breakdown causes any increase in the emissions of any regulated air pollutant. The 24-hour time period starts when the breakdown was discovered or reasonably should have been discovered by the owner or operator. However, notification is not required in the circumstances outlined in items A, B, and C of Minn. R. 7019.1000, subp. 2. At the time of notification or as soon as possible thereafter, the owner or operator shall inform the Commissioner of the cause of the breakdown and the estimated duration. The owner or operator shall notify the Commissioner when the breakdown is over. [Minn. R. 7019.1000, subp. 2]

5.1.21 Notification of Deviations Endangering Human Health or the Environment: As soon as possible after discovery, notify the Commissioner or the state duty officer, either orally or by facsimile, of any deviation from permit conditions which could endanger human health or the environment. [Minn. R. 7019.1000, subp. 1]

5.1.22 Notification of Deviations Endangering Human Health or the Environment Report: Within 2 working days of discovery, notify the Commissioner in writing of any deviation from permit conditions which could endanger human health or the environment. Include the following information in this written description: 1. the cause of the deviation; 2. the exact dates of the period of the deviation, if the deviation has been corrected; 3. whether or not the deviation has been corrected; 4. the anticipated time by which the deviation is expected to be corrected, if not yet corrected; and 5. steps taken or planned to reduce, eliminate, and prevent reoccurrence of the deviation. [Minn. R. 7019.1000, subp. 1]

5.1.23 Application for Permit Amendment: If a permit amendment is needed, submit an application in accordance with the requirements of Minn. R. 7007.1150 through Minn. R. 7007.1500. Submittal dates vary, depending on the type of amendment needed. Upon adoption of a new or amended federal applicable requirement, and if there are 3 or more years remaining in the permit term, the Permittee shall file an application for an amendment within nine months of promulgation of the applicable requirement, pursuant to Minn. R. 7007.0400, subp. 3. [Minn. R. 7007.0400, subp. 3, Minn. R. 7007.1150 - 7007.1500]

5.1.24 Extension Requests: The Permittee may apply for an Administrative Amendment to extend a deadline in a permit by no more than 120 days, provided the proposed deadline extension meets the requirements of Minn. R. 7007.1400, subp. 1(H). Performance testing deadlines from the General Provisions of 40 CFR pt. 60 and pt. 63 are examples of deadlines for which the MPCA does not have authority to grant extensions and therefore do not meet the requirements of Minn. R. 7007.1400, subp. 1(H). [Minn. R. 7007.1400, subp. 1(H)]

5.1.25 Emission Inventory Report: due on or before April 1 of each calendar year following permit issuance. Submit in a format specified by the Commissioner. [Minn. R. 7019.3000-7019.3100]

5.1.26 Emission Fees: due 30 days after receipt of an MPCA bill. [Minn. R. 7002.0005-7002.0085]

COMG 1 Six Class IV Waste Combustors



5.2.1 Particulate Matter <= 0.035 grains per dry standard cubic foot corrected to 7% oxygen on a dry volume basis. [Minn. R. 7011.1225, subp. 5]

5.2.2 Opacity <= 20 percent opacity. [Minn. R. 7011.1225, subp. 5]

5.2.3 Carbon Monoxide <= 50 parts per million corrected to 7% oxygen on a dry volume basis. [Minn. R. 7011.1225, subp. 5]

5.2.4 Use of Auxiliary Fuel: Auxiliary fuel shall be used to maintain the operating temperatures required below from the time the solid waste feed has been discontinued until the combustion chamber is clear of combustible material or active combustion ceases to exist in the combustion chamber. [Minn. R. 7011.1235, subp. 2a]

5.2.5 Start-up on Waste Prohibited: During start-up from a cold furnace, auxiliary fuels shall be used to achieve combustion chamber operating temperature. [Minn. R. 7011.1240, subp. 3]

5.2.6 Stack Exit Height shall be equal to or greater than (H + 0.5L), where H is the height of the building and L is the lesser of the building height or the maximum projected width of the building. The existing stack height of 38 feet meets this requirement. [Minn. R. 7011.1235, subp. 1]

5.2.7 Range of Operation: No owner or operator of a waste combustor shall operate the waste combustor while combusting solid waste at a level above 110% of the maximum demonstrated capacity of the combustion system, without conducting a performance test under Minn. R. 7011.1265, which demonstrates compliance with the emission limitations of Minn. R. 7011.1225 at greater than 110% of the maximum demonstrated capacity. [Minn. R. 7011.1240, subp. 5]

5.2.8 General Waste Combustor Facility Requirements: The owner or operator of a facility shall design, construct, and operate the facility in compliance with the solid waste management requirements as set forth in items listed below. Plans required in these items shall identify those required portions of the plan which are not applicable. - Security requirements in Minn. R. 7035.2535, subp. 3; - General inspection requirements in Minn. R. 7035.2535, subp. 4; - Emergency preparedness and prevention plans and emergency procedures prepared in accordance with Minn. R. 7035.2595 and 7035.2605; - Contingency action plans in Minn. R. 7035.2615; and - Closure plans in Minn. R. 7035.2625, closure procedures in Minn. R. 7035.2635. [Minn. R. 7011.1245]

5.2.9 Presence of Certified Operator: An operator supervisor shall be present at the waste combustor facility at all times when solid waste is being combusted. The operator supervisor shall hold a certificate as described in Minn. R. 7011.1280. [Minn. R. 7011.1240, subp. 1]

5.2.10 Personnel Training: Waste combustor facility personnel described below shall complete a program of instruction and on-the-job training based on the operating manual described in Minn. R. 7011.1275, subp. 3. The training program shall require: - an initial review of the operating manual prior to assumption of any job-related activities affecting air emissions; - review of the operating manual relevant to a newly assigned position before assumption of new job-related activities affecting air emissions; - those without waste combustor or boiler operation experience, initially review the operating manual and work under the direct supervision of a certified operator or a certified operator's designee for 12 hours before assumption of job-related activities affecting air emissions; and - annual review of the operating manual. [Minn. R. 7011.1275]

5.2.11 Personnel Who Shall be Trained: The training program shall train waste combustor personnel who have responsibilities which affect the operation of the waste combustor, including, but not limited to, chief facility operators, shift supervisors, operator supervisors, control room personnel, ash handlers,


Requirement number Requirement and citation maintenance personnel, and crane/load handlers. [Minn. R. 7011.1275, subp. 2]

5.2.12 Operator Certification: The operator supervisor shall be certified through the process established in Minn. R. 7011.1280. The certified operator shall: (1) hold a high school diploma or equivalent, or demonstrate five years of experience in incinerator operation, general industry, industry process, or power plant operation; (2) complete at least 16 hours of training approved by the commissioner which are designed to ensure competency to operate a Class IV waste combustor; (3) complete the certification process described in Minn. R. 7011.1280, subp. 4; and (4) pass the examination required in Minn. R. 7011.1280, subp. 5. Certificates are valid for three years. [Minn. R. 7011.1280]

5.2.13 Operator Certification Renewal: A certified operator shall apply for certificate renewal 30 days prior to certificate expiration. The application renewal shall include evidence that the person has, during the preceding three years, earned credit for attending training courses offered by the MPCA or other training courses approved by the commissioner, including personnel training described in Minn. R. 7011.1275, for at least 8 hours. [Minn. R. 7011.1280, subp. 7]

5.2.14 Industrial Waste Management Plan: The owner or operator shall prepare a plan for the management of industrial solid waste in accordance with Minn. R. 7035.2535, subp. 5, items A and B. The plan shall also include the contents listed in Minn. R. 7035.2535, subp. 2. The owner shall modify the plan whenever the management practices or solid waste identified in the plan have changed. The owner or operator shall submit the amended plan to the commissioner for approval. This Plan has been submitted and is in Appendix B of this permit. [Minn. R. 7011.1250, subp. 1, Minn. R. 7011.1250, subp. 3]

5.2.15 Mercury Waste Separation Plan: the permit application for a waste combustor shall contain a plan to separate solid wastes which contain mercury in accordance with Minn. R. 7011.1255. This Plan has been submitted and is included in Appendix D of this permit. [Minn. R. 7007.0501, subp. 5]

5.2.16 Ash Management Plan: the permit application for a waste combustor shall contain a plan for disposal of the ash generated by the waste combustor, treatment of water generated from quenching the ash at the facility, and any plans which the applicant has for ash utilization. This Plan has been submitted and is included in Appendix C of this permit. [Minn. R. 7007.0501, subp. 7]

5.2.17 Operating Manual: The owner or operator of a waste combustor shall develop and update on a yearly basis a site specific operating manual that shall, at a minimum, address the following elements of waste combustor unit operation: - a summary of the applicable state rules and federal regulations to the activities described in this permit; - a description of basic combustion theory applicable to the facility's waste combustor unit; - procedures for receiving, handling, and feeding solid waste; - waste combustor unit start-up, shutdown, and malfunction procedures; - procedures for maintaining proper combustion air levels; - procedures for operating the waste combustor within the standards established in Minn. R. 7011.1201 to 1290; - procedures for responding to periodic upset or off-specification conditions; - procedures for minimizing particulate matter carryover; - procedures for monitoring the degree of solid waste burnout; - procedures for handling ash; - procedures for monitoring waste combustor emissions; - procedures for reporting and recordkeeping; - timetables and procedures for routine inspection and maintenance of equipment affecting air


Requirement number Requirement and citation emissions; - procedures for activating communications and alarm systems; and - procedures to implement the facility's industrial waste management plan. The operating manual shall be kept in a location easily accessed by the waste combustor personnel. [Minn. R. 7011.1275, subp. 3]

5.2.18 Operating Records: The owner or operator of a waste combustor shall maintain records and submit reports as required in Minn. R. 7011.1285. The owner or operator is also subject to the recordkeeping and reporting requirements in Minn. R. 7007.0800, subps. 5 and 6. Records shall be retained for a minimum of five years. [Minn. R. 7011.1285, subp. 1]

5.2.19 Daily Operating Record: The owner or operator shall maintain a daily record of the operation of the waste combustor. The record shall contain: -the calendar date; -the hours of operation; -the weight of solid waste combusted; -the weight of solid waste requiring disposal at a solid waste land disposal facility, including separated non-combustibles, excess solid waste, and ash; -the amount and description of industrial solid waste received each day, the generator's name, and the method of handling; -the measurements and determination of emissions averages as required in Minn. R. 7011.1260, subp. 6; -the results of performance tests conducted as required in Minn. R. 7011.1270; -the names of persons who have completed initial review of subsequent annual review of the operating manual; -reasons for exceeding any of the operating parameters specified under Minn. R. 7011.1260, subp. 6(C) and a description of corrective actions taken; and -reasons for not obtaining the minimum number of hours of operational data for the temperature monitoring equipment and a description of corrective actions taken. [Minn. R. 7011.1285, subp. 2]

5.2.20 Exceedances of Emission Limits: if accurate and valid data results of a performance test demonstrate an exceedance of the Particulate Matter or Carbon Monoxide emission limit or the opacity limit, the owner or operator shall undertake the actions below: -The owner or operator shall immediately report the exceedance to the commissioner and shall comply with the applicable reporting provisions of Minn. R. 7011.0800, sub.6; -The owner or operator shall undertake appropriate steps to return the waste combustor to compliance, and shall demonstrate compliance within 60 days of the initial report of the exceedance; - If the commissioner determines that compliance has not been achieved within 60 days of the initial report of exceedance, the waste combustor shall be shut down; and -If the shutdown was required as described above, the waste combustor may be restarted under the conditions specified by the commissioner. The owner or operator shall notify the commissioner in writing of the date on which the owner or operator plans to start-up and begin compliance testing. Notification shall be at least 10 days in advance of the compliance test date. [Minn. R. 7011.1265, subp. 11]

EQUI 9 Smelting Furnace - Medium Crucible Furnace

5.3.1 Particulate Matter <= 0.4 pounds per million Btu heat input. The potential to emit from the unit is 0.21 lb/MMBtu due to equipment design and allowable fuels. [Minn. R. 7011.0515, subp. 1]

5.3.2 Opacity <= 20 percent opacity except for one six-minute period per hour of not more than 60 percent opacity. [Minn. R. 7011.0515, subp. 2]



5.3.3 Fuel type: Natural gas only, by design. [Minn. R. 7005.0100, subp. 35a]

5.3.4 The Permittee shall keep records of fuel purchases showing fuel types. [Minn. R. 7007.0800, subp. 5]

EQUI 10 Smelting Furnace - Tilt Furnace #1





5.4.5 The Permittee shall vent emissions from EQUI 10 to control equipment meeting the requirements of TREA 17 whenever EQUI 10 operates. [Minn. R. 7007.0800, subp. 2]

5.4.6 Hood Certification and Evaluation: The Permittee shall maintain the most current record of the hood evaluation and certification on site. The control device hood must be evaluated by a testing company as specified in Minn. R. 7011.0072, subp. 2(A) and must conform to the design and operating requirements listed in Minn. R. 7011.0072, subps. 2(B) and 3. The hood certification must address how cross-drafts are accommodated in the design (e.g., higher face velocity, oversized hood, etc.) and the Permittee shall certify this as specified in Minn. R. 7011.0072, subps. 2 and 3. [Minn. R. 7007.0800, subp. 2]

5.4.7 Annual Hood Evaluation: The Permittee shall measure and record at least once every 12 months the fan rotation speed, fan power draw, or face velocity of each hood, or other comparable air flow parameter that was measured during the most recent hood certification to verify the hood design and operation parameters meet or exceed the parameters measured during the most recent hood evaluation conducted according to Minn. R. 7011.0072, subps. 2 & 3 as required by Minn. R. 7011.0072, subp. 4. The Permittee shall maintain a copy of the annual evaluations on site for 5 years. [Minn. R. 7007.0800, subp. 2]

EQUI 12 Smelting Furnace - Medium Tilt Furnace





5.5.5 The Permittee shall vent emissions from EQUI 12 to control equipment meeting the requirements of TREA 17 whenever EQUI 12 operates. [Minn. R. 7007.0800, subp. 2]

5.5.6 Hood Certification and Evaluation: The Permittee shall maintain the most current record of the hood evaluation and certification on site. The control device hood must be evaluated by a testing company as specified in Minn. R. 7011.0072, subp. 2(A) and must conform to the design and operating requirements listed in Minn. R. 7011.0072, subps. 2(B) and 3. The hood certification must address how cross-drafts are accommodated in the design (e.g., higher face velocity, oversized hood, etc.) and the Permittee shall certify this as specified in Minn. R. 7011.0072, subps. 2 and 3. [Minn. R. 7007.0800, subp. 2]

5.5.7 Annual Hood Evaluation: The Permittee shall measure and record at least once every 12 months the fan rotation speed, fan power draw, or face velocity of each hood, or other comparable air flow parameter that was measured during the most recent hood certification to verify the hood design and operation parameters meet or exceed the parameters measured during the most recent hood


Requirement number Requirement and citation evaluation conducted according to Minn. R. 7011.0072, subps. 2 & 3 as required by Minn. R. 7011.0072, subp. 4. The Permittee shall maintain a copy of the annual evaluations on site for 5 years. [Minn. R. 7007.0800, subp. 2]

EQUI 17 Waste Combustor Film #1

5.6.1 The Permittee shall vent emissions from EQUI 17 to control equipment meeting the requirements of TREA 6 and TREA 17 in series whenever EQUI 17 operates. [Minn. R. 7007.0800, subp. 2, Minn. R. 7011.1235, subp. 2]







EQUI 21 Waste Combustor (Assay, Small Lot)




STRU 1 Baghouse emissions

5.12.1 Particulate Matter <= 2.0 pounds per hour. [Minn. R. 7007.0800, subp. 2]

TREA 6 Direct Flame Afterburner

5.13.1 The Permittee shall operate and maintain control equipment such that it achieves an overall efficiency for Carbon Monoxide >= 95.0 percent control efficiency. [Minn. R. 7007.0800, subp. 2]

5.13.2 The Permittee shall operate and maintain control equipment such that it achieves an overall control efficiency for, Volatile Organic Compounds >= 99.0 percent control efficiency. [Minn. R. 7007.0800, subp. 2]

5.13.3 Combustion Chamber Temperature >= 1800 degrees Fahrenheit 4-hour block average. [Minn. R. 7007.0800, subp. 14, Minn. R. 7007.0800, subp. 2, Minn. R. 7011.1235, subp. 2]

5.13.4 Combustion Chamber: the final Combustion Chamber shall be designed and operated to maintain combustion gases at a minimum of 1800 degrees F for one second in a zone after the last overfire or secondary air has entered the combustion chamber. [Minn. R. 7011.1235, subp. 2]

5.13.5 The Permittee shall vent emissions from EQUI 17, EQUI 18, EQUI 19, EQUI 20, and EQUI 22 to TREA 6 whenever EQUI 17, EQUI 18, EQUI 19, EQUI 20, and EQUI 22 operates, and operate and maintain TREA 6 at all times that any emissions are vented to TREA 6. The Permittee shall document periods of non-operation of the control equipment TREA 6 whenever EQUI 17, EQUI 18, EQUI 19, EQUI 20, and EQUI 22 is operating. [Minn. R. 7007.0800, subp. 14, Minn. R. 7007.0800, subp. 2]



5.13.6 If the Permittee replaces TREA 6, the replacement control must meet or exceed the control efficiency requirements of TREA 6 as well as comply with all other requirements of TREA 6. Prior to making such a change, the Permittee shall apply for and obtain the appropriate permit amendment, as applicable. If no amendment is needed for the replacement, the Permittee shall submit an electronic notice to the Agency using Form CR-05. The notice must be received by the Agency seven working days prior to the commencement/start of replacement. [Minn. R. 7007.0800, subp. 2]

5.13.7 Combustion Chamber Temperature Monitor: The owner or operator shall install and operate at all times temperature monitors that continuously read and record the temperature at the point in the combustion unit one second downstream of the entrance of the last overfire or secondary air injection. The owner or operator may elect to place temperature monitors at another point downstream in accordance with Minn. R. 7011.1260, subp. 1. The averaging period for combustion chamber temperatures shall be four-hour arithmetic block averages calculated from four one-hour arithmetic averages. Each one-hour arithmetic average shall consist of at least ten data points equally spaced in time. [Minn. R. 7011.1260, subp. 1]

5.13.8 Installation and Operation of Continuous Monitors: The owner or operator shall comply with the requirements of Minn. R. 7017.1002 to Minn. R. 7017.1220, except as provided below: Continuous monitors shall be operated so as to measure and record data for at least 75% of the hours per day for 90% of the days of the calendar quarter that the waste combustor is operating and combusting solid waste. [Minn. R. 7011.1260, subp. 5]

5.13.9 Recording Data from Continuous Monitoring: The owner or operator shall maintain a permanent record of the information listed below. Waste combustors shall maintain a record of continuously measured parameters. The record of monitoring shall contain: - the calendar date; - combustion chamber temperature and particulate matter control device temperatures recorded in a manner that allows the data to be immediately accessed upon inspection; and - four-hour block arithmetic average particulate matter control device inlet temperatures. [Minn. R. 7011.1260, subp. 6]

5.13.10 Periodic Inspections: At least once per calendar year, or more frequently as required by the manufacturing specifications, the Permittee shall inspect the control equipment internal and external system components. The Permittee shall maintain a written record of the inspection and any corrective actions taken resulting from the inspection. [Minn. R. 7007.0800, subp. 14, Minn. R. 7007.0800, subps. 4-5]

5.13.11 The Permittee shall operate and maintain the afterburner in accordance with the Operation and Maintenance (O & M) Plan. The Permittee shall keep copies of the O & M Plan available onsite for use by staff and MPCA staff. [Minn. R. 7007.0800, subp. 14]

5.13.12 Temperature Monitoring: The Permittee shall maintain and operate a thermocouple monitoring device that continuously indicates and records the combustion chamber temperature of the afterburner. The monitoring device shall have a margin of error less than the greater of +/- 0.75 percent of the temperature being measured or +/- 4.5 degrees Fahrenheit. The recording device shall also calculate the four-hour rolling average combustion chamber temperature. Recorded values outside the range specified in this permit are considered Deviations as defined by Minn. R. 7007.0100, subp. 8a. [Minn. R. 7007.0800, subps. 4-5, Minn. R. 7011.1235, subp. 2]

5.13.13 Daily Monitoring: The Permittee shall physically verify the operation of the temperature recording device at least once each operating day to verify that it is working and recording properly. The Permittee shall maintain a written record of the daily verifications. [Minn. R. 7007.0800, subps. 4-5]

5.13.14 Monitoring Equipment: The Permittee shall install and maintain thermocouples to conduct


Requirement number Requirement and citation temperature monitoring required by this permit. The monitoring equipment must be installed, in use, and properly maintained whenever operation of the monitored control equipment is required. [Minn. R. 7007.0800, subps. 4-5]

5.13.15 The Permittee shall maintain a continuous hard copy readout or computer disk file of the temperature readings and calculated four hour rolling average temperatures for the combustion chamber. [Minn. R. 7007.0800, subps. 4-5]

5.13.16 Annual Calibration: The Permittee shall calibrate the temperature monitor at least once every 12 months and shall maintain a written record of the calibration and any action resulting from the calibration. [Minn. R. 7007.0800, subp. 14, Minn. R. 7007.0800, subp. 4, Minn. R. 7007.0800, subp. 5]

5.13.17 Quarterly Inspections: At least once per calendar quarter, the Permittee shall inspect the control equipment internal and external system components, including but not limited to the refractory, heat exchanger, and electrical systems. The Permittee shall maintain a written record of the inspection and any corrective actions taken resulting from the inspection. [Minn. R. 7007.0800, subp. 14, Minn. R. 7007.0800, subp. 4, Minn. R. 7007.0800, subp. 5]

5.13.18 Annual Inspection: At least once per calendar year, the Permittee shall conduct an internal inspection of the control device that includes all operating systems of the control device. The Permittee shall maintain a written record of the inspection and any action resulting from the inspection. [Minn. R. 7007.0800, subp. 14, Minn. R. 7007.0800, subp. 4, Minn. R. 7007.0800, subp. 5]

5.13.19 Corrective Actions: If the temperature is below the minimum specified by this permit or if the afterburner or any of its components are found during the inspections to need repair, the Permittee shall take corrective action as soon as possible. Corrective actions shall return the temperature to at least the permitted minimum and/or include completion of necessary repairs identified during the inspection, as applicable. Corrective actions include, but are not limited to, those outlined in the O & M Plan for the afterburner. The Permittee shall keep a record of the type and date of any corrective action taken. [Minn. R. 7007.0800, subp. 14, Minn. R. 7007.0800, subp. 2(A), Minn. R. 7007.0800, subp. 5]

TREA 8 Direct Flame Afterburner

5.14.1 The Permittee shall operate and maintain control equipment such that it achieves an overall control efficiency for Carbon Monoxide >= 95.0 percent control efficiency. [Minn. R. 7007.0800, subp. 2]

5.14.2 The Permittee shall operate and maintain control equipment such that it achieves an overall control efficiency for, Volatile Organic Compounds >= 99.0 percent control efficiency. [Minn. R. 7007.0800, subp. 2]

5.14.3 Combustion Chamber Temperature >= 1800 degrees Fahrenheit 4-hour block average. [Minn. R. 7007.0800, subp. 14, Minn. R. 7007.0800, subp. 2, Minn. R. 7011.1235, subp. 2]

5.14.4 Combustion Chamber: the final Combustion Chamber shall be designed and operated to maintain combustion gases at a minimum of 1800 degrees F for one second in a zone after the last overfire or secondary air has entered the combustion chamber. [Minn. R. 7011.1235, subp. 2]

5.14.5 The Permittee shall vent emissions from EQUI 21 to TREA 8 whenever EQUI 21 operates, and operate and maintain EQUI 21 at all times that any emissions are vented to EQUI 21. The Permittee shall document periods of non-operation of the control equipment EQUI 21 whenever EQUI 21 is operating. [Minn. R. 7007.0800, subp. 14, Minn. R. 7007.0800, subp. 2]

5.14.6 If the Permittee replaces TREA 8, the replacement control must meet or exceed the control efficiency requirements of TREA 8 as well as comply with all other requirements of TREA 8. Prior to making such a change, the Permittee shall apply for and obtain the appropriate permit amendment, as applicable. If no amendment is needed for the replacement, the Permittee shall submit an electronic notice to the Agency using Form CR-05. The notice must be received by the Agency seven working days prior to


Requirement number Requirement and citation the commencement/start of replacement. [Minn. R. 7007.0800, subp. 2]

5.14.7 Combustion Chamber Temperature Monitor: The owner or operator shall install and operate at all times temperature monitors that continuously read and record the temperature at the point in the combustion unit one second downstream of the entrance of the last overfire or secondary air injection. The owner or operator may elect to place temperature monitors at another point downstream in accordance with Minn. R. 7011.1260, subp. 1. The averaging period for combustion chamber temperatures shall be four-hour arithmetic block averages calculated from four one-hour arithmetic averages. Each one-hour arithmetic average shall consist of at least ten data points equally spaced in time. [Minn. R. 7011.1260, subp. 1]

5.14.8 Installation and Operation of Continuous Monitors: The owner or operator shall comply with the requirements of Minn. R. 7017.1002 to Minn. R. 7017.1220, except as provided below: Continuous monitors shall be operated so as to measure and record data for at least 75% of the hours per day for 90% of the days of the calendar quarter that the waste combustor is operating and combusting solid waste. [Minn. R. 7011.1260, subp. 5]

5.14.9 Recording Data from Continuous Monitoring: The owner or operator shall maintain a permanent record of the information listed below. Waste combustors shall maintain a record of continuously measured parameters. The record of monitoring shall contain: - the calendar date; - combustion chamber temperature and particulate matter control device temperatures recorded in a manner that allows the data to be immediately accessed upon inspection; and - four-hour block arithmetic average particulate matter control device inlet temperatures. [Minn. R. 7011.1260, subp. 6]

5.14.10 Periodic Inspections: At least once per calendar year, or more frequently as required by the manufacturing specifications, the Permittee shall inspect the control equipment internal and external system components. The Permittee shall maintain a written record of the inspection and any corrective actions taken resulting from the inspection. [Minn. R. 7007.0800, subp. 14, Minn. R. 7007.0800, subps. 4-5]

5.14.11 The Permittee shall operate and maintain the afterburner in accordance with the Operation and Maintenance (O & M) Plan. The Permittee shall keep copies of the O & M Plan available onsite for use by staff and MPCA staff. [Minn. R. 7007.0800, subp. 14]

5.14.12 Temperature Monitoring: The Permittee shall maintain and operate a thermocouple monitoring device that continuously indicates and records the combustion chamber temperature of the afterburner. The monitoring device shall have a margin of error less than the greater of +/- 0.75 percent of the temperature being measured or +/- 4.5 degrees Fahrenheit. The recording device shall also calculate the four-hour rolling average combustion chamber temperature. Recorded values outside the range specified in this permit are considered Deviations as defined by Minn. R. 7007.0100, subp. 8a. [Minn. R. 7007.0800, subps. 4-5, Minn. R. 7011.1235, subp. 2]

5.14.13 Daily Monitoring: The Permittee shall physically verify the operation of the temperature recording device at least once each operating day to verify that it is working and recording properly. The Permittee shall maintain a written record of the daily verifications. [Minn. R. 7007.0800, subps. 4-5]

5.14.14 Monitoring Equipment: The Permittee shall install and maintain thermocouples to conduct temperature monitoring required by this permit. The monitoring equipment must be installed, in use, and properly maintained whenever operation of the monitored control equipment is required. [Minn. R. 7007.0800, subps. 4-5]

5.14.15 The Permittee shall maintain a continuous hard copy readout or computer disk file of the temperature readings and calculated four hour rolling average temperatures for the combustion chamber. [Minn. R. 7007.0800, subps. 4-5]



5.14.16 Annual Calibration: The Permittee shall calibrate the temperature monitor at least once every 12 months and shall maintain a written record of the calibration and any action resulting from the calibration. [Minn. R. 7007.0800, subp. 14, Minn. R. 7007.0800, subp. 4, Minn. R. 7007.0800, subp. 5]

5.14.17 Quarterly Inspections: At least once per calendar quarter, the Permittee shall inspect the control equipment internal and external system components, including but not limited to the refractory, heat exchanger, and electrical systems. The Permittee shall maintain a written record of the inspection and any corrective actions taken resulting from the inspection. [Minn. R. 7007.0800, subp. 14, Minn. R. 7007.0800, subp. 4, Minn. R. 7007.0800, subp. 5]

5.14.18 Annual Inspection: At least once per calendar year, the Permittee shall conduct an internal inspection of the control device that includes all operating systems of the control device. The Permittee shall maintain a written record of the inspection and any action resulting from the inspection. [Minn. R. 7007.0800, subp. 14, Minn. R. 7007.0800, subp. 4, Minn. R. 7007.0800, subp. 5]

5.14.19 Corrective Actions: If the temperature is below the minimum specified by this permit or if the afterburner or any of its components are found during the inspections to need repair, the Permittee shall take corrective action as soon as possible. Corrective actions shall return the temperature to at least the permitted minimum and/or include completion of necessary repairs identified during the inspection, as applicable. Corrective actions include, but are not limited to, those outlined in the O & M Plan for the afterburner. The Permittee shall keep a record of the type and date of any corrective action taken. [Minn. R. 7007.0800, subp. 14, Minn. R. 7007.0800, subp. 2(A), Minn. R. 7007.0800, subp. 5]

TREA 17 Fabric Filter - Medium Temperature i.e., 180 F<T<250 F

5.15.1 The Permittee shall operate and maintain control equipment such that it achieves a control efficiency for Particulate Matter >= 99.0 percent control efficiency. [Minn. R. 7007.0800, subp. 2]

5.15.2 The Permittee shall operate and maintain control equipment such that it achieves a control efficiency for PM < 10 micron >= 93.0 percent control efficiency. [Minn. R. 7007.0800, subp. 2(A)]

5.15.3 The Permittee shall operate and maintain control equipment such that it achieves a control efficiency for PM < 2.5 micron >= 93.0 percent control efficiency. [Minn. R. 7007.0800, subp. 2(A)]

5.15.4 Pressure Drop >= 0.5 and <= 4.5 inches of water, unless a new range is set pursuant to Minn. R. 7017.2025, subp. 3 based on the values recorded during the most recent MPCA-approved performance test where compliance was demonstrated. The new range shall be implemented upon receipt of the Notice of Compliance letter granting preliminary approval. The range is final upon issuance of a permit amendment incorporating the change. If the recorded pressure drop is outside the required range, the emissions during that time shall be considered uncontrolled until the pressure drop is once again within the required range. The period of time for which the pressure drop is considered out of range shall be reported as a deviation. The Permittee shall record the pressure drop at least once every 24 hours when in operation. [Minn. R. 7007.0800, subp. 2(A)]

5.15.5 The Permittee shall vent emissions from EQUI 10, EQUI 12, EQUI 17, EQUI 18, EQUI 19, EQUI 20, EQUI 21, and EQUI 22 to TREA 17 whenever EQUI 10, EQUI 12, EQUI 17, EQUI 18, EQUI 19, EQUI 20, EQUI 21, and EQUI 22 operates, and operate and maintain TREA 17 at all times that any emissions are vented to EQUI 17. The Permittee shall document periods of non-operation of the control equipment TREA 17 whenever EQUI 10, EQUI 12, EQUI 17, EQUI 18, EQUI 19, EQUI 20, EQUI 21, and EQUI 22 is operating. [Minn. R. 7007.0800, subp. 2(A)]

5.15.6 If the Permittee replaces TREA 17, the replacement control must meet or exceed the control efficiency requirements of TREA 17 as well as comply with all other requirements of TREA 17. Prior to making such a change, the Permittee shall apply for and obtain the appropriate permit amendment,


Requirement number Requirement and citation as applicable. If no amendment is needed for the replacement, the Permittee shall submit an electronic notice to the Agency using Form CR-05. The notice must be received by the Agency seven working days prior to the commencement/start of replacement. [Minn. R. 7007.0800, subp. 2(A)]

5.15.7 Particulate Matter Control Device Temperature Monitors: The owner or operator shall install, calibrate, maintain, and operate at all times temperature monitors that continuously read and record the temperatures of the flue gas at the inlet of each particulate matter control device. [Minn. R. 7011.1260, subp. 2]

5.15.8 Monitoring Equipment: The Permittee shall install and maintain the necessary monitoring equipment for measuring and recording pressure drop as required by this permit. The monitoring equipment must be installed, in use, and properly maintained when the monitored fabric filter is in operation. [Minn. R. 7007.0800, subp. 4]

5.15.9 Averaging Periods: Except as provided below and in Minn. R. 7011.1260, subps. 4, 4a, and 5, the requirements in Minn. R. 7017.1002 to 7017.1220 apply to continuous monitoring data collection, reduction, and averaging periods. For particulate matter control device inlet temperature monitoring, four-hour arithmetic block averages calculated from four consecutive one-hour arithmetic averages. [Minn. R. 7011.1260, subp. 4]

5.15.10 The Permittee shall calibrate or replace the pressure drop monitor at least once every 12 months and shall maintain a written record of any action resulting from the calibration. [Minn. R. 7007.0800, subp. 14, Minn. R. 7007.0800, subp. 4, Minn. R. 7007.0800, subp. 5]

5.15.11 Pressure Drop: Recordkeeping. The Permittee shall record the time and date of each pressure drop reading and whether or not the recorded pressure drop was within the range specified in this permit. [Minn. R. 7007.0800, subps. 4-5]

5.15.12 Periodic Inspections: At least once per calendar quarter, or more frequently as required by the manufacturing specifications, the Permittee shall inspect the control equipment components. The Permittee shall maintain a written record of these inspections. [Minn. R. 7007.0800, subp. 14, Minn. R. 7007.0800, subp. 4, Minn. R. 7007.0800, subp. 5]

5.15.13 The Permittee shall operate and maintain the fabric filter in accordance with the Operation and Maintenance (O & M) Plan. The Permittee shall keep copies of the O & M Plan available onsite for use by staff and MPCA staff. [Minn. R. 7007.0800, subp. 14]

5.15.14 Corrective Actions: The Permittee shall take corrective action as soon as possible if any of the following occur: - the recorded pressure drop is outside the required operating range; or - the fabric filter or any of its components are found during the inspections to need repair. Corrective actions shall return the pressure drop to within the permitted range, eliminate visible emissions, and/or include completion of necessary repairs identified during the inspection, as applicable. Corrective actions include, but are not limited to, those outlined in the O & M Plan for the fabric filter. The Permittee shall keep a record of the type and date of any corrective action taken for each filter. [Minn. R. 7007.0800, subp. 14, Minn. R. 7007.0800, subp. 2(A), Minn. R. 7007.0800, subp. 5]


6. Submittal/action requirements

This section lists most of the submittals required by this permit. Please note that some submittal requirements may appear in the Limits and Other Requirements section, or, if applicable, within a Compliance Schedule section.


TFAC 1 Enviro-Chem Inc - Plant 1

6.1.1 The Permittee shall submit a semiannual deviations report : Due semiannually, by the 30th of January and July. The first semiannual report submitted by the Permittee shall cover the calendar half-year in which the permit is issued. The first report of each calendar year covers January 1 - June 30. The second report of each calendar year covers July 1 - December 31. Submit this on form DRF-2 (Deviation Reporting Form). If no deviations have occurred, submit the signed report certifying that there were no deviations. [Minn. R. 7007.0800, subp. 6(A)(2)]

6.1.2 The Permittee shall submit a compliance schedule progress report : Due semiannually, by the 30th of January and July The Compliance Schedule Progress Report shall contain the information specified in Minn. R. 7007.0800, subp. 6(B) and shall be submitted on a form approved by the Commissioner in accordance with the Compliance Schedule contained in this permit. Progress Reports will not be needed upon completion of all activities contained in the Compliance Schedule. [Minn. R. 7007.0800, subp. 6(B)]

6.1.3 The Permittee shall submit a compliance certification : Due annually, by the 31st of January (for the previous calendar year). Submit this on form CR-04 (Annual Compliance Certification Report). This report covers all deviations experienced during the calendar year. If no deviations have occurred, submit the signed report certifying that there were no deviations. [Minn. R. 7007.0800, subp. 6(C)]

COMG 1 Six Class IV Waste Combustors

6.2.1 Ash Testing: due before end of each 60 months starting 1/19/2025; The Permittee shall conduct testing for ash in accordance with Minn. R. 7045.0131 for toxic characteristic leach procedure for arsenic, barium, cadmium, chromium, lead, mercury, selenium and nickel. The Permittee shall include the weight percent of arsenic, barium, cadmium, chromium, lead, mercury, selenium and nickel with the ash test results. [Minn. R. 7011.1270(D)]

6.2.2 Plans and Specifications: due before May 23, 2022 and every 60 months thereafter. Mercury Waste Separation Plan shall be revised every five years. The Plan shall be updated to improve identification, separation, and collection before combustion of mercury from the solid waste stream. [Minn. R. 7007.0501, subp. 5, Minn. R. 7011.1255, subp. 1, Minn. R. 7011.1255, subp. 3]

6.2.3 The Permittee shall submit an Annual Report: due April 30th of each year. The owner or operator shall submit the following information to the commissioner in the annual report: - the daily operating records in Minn. R. 7011.1285, subp. 2 summarized to reflect annual totals; - a summary report of any excess emissions that occurred during the year; and - a compliance certification as required in Minn. R. 7007.0800, subp. (6), item (C). [Minn. R. 7011.1285, subp. 4]

6.2.4 Particulate Matter: The Permittee shall conduct a performance test due before 1/19/2025 and every 60 months thereafter to measure emissions. The first test is due by the date specified above and all subsequent tests shall be completed every 60 months thereafter by the due date (month and day) and as described below. The performance test shall be conducted at worst-case conditions, with EQUI 10, EQUI 12, EQUI 17, EQUI 18, EQUI 19, EQUI 20, EQUI 21, and EQUI 22 operating simultaneously, defined at Minn. R. 7017.2005, subp. 8 or at the operating conditions described at Minn. R. 7017.2025, subp. 2, using EPA Reference Methods 5 and 202, or other method approved by MPCA in the performance test plan approval.


Requirement number Requirement and citation Testing conducted during the 60 days prior to the performance test due date will not reset the test due date for future testing as required by this permit or within a Notice of Compliance letter. Testing conducted more than 60 days prior to the performance test due date satisfies this test due date requirement but will reset future performance test due dates based on the performance test date. [Minn. R. 7007.0800, subp. 2, Minn. R. 7011.1265, subp. 5, Minn. R. 7011.1270, D, Minn. R. 7017.2020, subp. 1]

6.2.5 Cadmium: The Permittee shall conduct a performance test due before 1/19/2025 and every 60 months thereafter to measure emissions as required by Minn. R. 7011.1265, subp. 5. The first test is due by the date specified above and all subsequent tests shall be completed every 60 months thereafter by the due date (month and day) and as described below. The performance test shall be conducted at worst-case conditions, with EQUI 17, EQUI 18, EQUI 19, EQUI 20, EQUI 21, and EQUI 22 operating simultaneously, defined at Minn. R. 7017.2005, subp. 8 or at the operating conditions described at Minn. R. 7017.2025, subp. 2, using EPA Reference Method 29, or other method approved by MPCA in the performance test plan approval. Testing conducted during the 60 days prior to the performance test due date will not reset the test due date for future testing as required by this permit or within a Notice of Compliance letter. Testing conducted more than 60 days prior to the performance test due date satisfies this test due date requirement but will reset future performance test due dates based on the performance test date. [Minn. R. 7011.1265, subp. 5, Minn. R. 7011.1270, D, Minn. R. 7017.2020, subp. 1]

6.2.6 Lead: The Permittee shall conduct a performance test due before 1/19/2025 and every 60 months thereafter to measure emissions as required by Minn. R. 7011.1265, subp. 5. The first test is due by the date specified above and all subsequent tests shall be completed every 60 months thereafter by the due date (month and day) and as described below. The performance test shall be conducted at worst-case conditions, with EQUI 17, EQUI 18, EQUI 19, EQUI 20, EQUI 21, and EQUI 22 operating simultaneously, defined at Minn. R. 7017.2005, subp. 8 or at the operating conditions described at Minn. R. 7017.2025, subp. 2, using EPA Reference Method 29, or other method approved by MPCA in the performance test plan approval. Testing conducted during the 60 days prior to the performance test due date will not reset the test due date for future testing as required by this permit or within a Notice of Compliance letter. Testing conducted more than 60 days prior to the performance test due date satisfies this test due date requirement but will reset future performance test due dates based on the performance test date. [Minn. R. 7011.1265, subp. 5, Minn. R. 7011.1270, D, Minn. R. 7017.2020, subp. 1]

6.2.7 Mercury: The Permittee shall conduct a performance test due before 1/19/2025 and every 60 months thereafter to measure emissions as required by Minn. R. 7011.1265, subp. 5. The first test is due by the date specified above and all subsequent tests shall be completed every 60 months thereafter by the due date (month and day) and as described below. The performance test shall be conducted at worst-case conditions, with EQUI 17, EQUI 18, EQUI 19, EQUI 20, EQUI 21, and EQUI 22 operating simultaneously, defined at Minn. R. 7017.2005, subp. 8 or at the operating conditions described at Minn. R. 7017.2025, subp. 2, using EPA Reference Method 29, or other method approved by MPCA in the performance test plan approval.


Requirement number Requirement and citation Testing conducted during the 60 days prior to the performance test due date will not reset the test due date for future testing as required by this permit or within a Notice of Compliance letter. Testing conducted more than 60 days prior to the performance test due date satisfies this test due date requirement but will reset future performance test due dates based on the performance test date. [Minn. R. 7011.1265, subp. 5, Minn. R. 7011.1270, D, Minn. R. 7017.2020, subp. 1]

6.2.8 Opacity: The Permittee shall conduct a performance test due before1/19/2025 and every 60 months thereafter to measure opacity. The first test is due by the date specified above and all subsequent tests shall be completed every 60 months thereafter by the due date (month and date) and as described below. The performance test shall be conducted at worst-case conditions with EQUI 17, EQUI 18, EQUI 19, EQUI 20, EQUI 21, and EQUI 22 operating simultaneously, defined at Minn. R. 7017.2005, subp. 8 or at the operating conditions described at Minn. R. 7017.2025, subp. 2, using EPA Reference Methods 9, or other method approved by MPCA in the performance test plan approval. Testing conducted during the 60 days prior to the performance test due date will not reset the test due date for future testing as required by this permit or within a Notice of Compliance letter. Testing conducted more than 60 days prior to the performance test due date satisfies this test due date requirement but will reset future performance test due dates based on the performance test date. [Minn. R. 7011.1265, subp. 5, Minn. R. 7011.1270, D, Minn. R. 7017.2020, subp. 1]

6.2.9 Carbon Monoxide: The Permittee shall conduct a performance test due before 1/19/2025 and every 60 months thereafter to measure emissions. The first test is due by the date specified above and all subsequent tests shall be completed every 60 months thereafter by the due date (month and day) and as described below. The performance test shall be conducted at worst-case conditions with EQUI 17, EQUI 18, EQUI 19, EQUI 20, EQUI 21, and EQUI 22 operating simultaneously, defined at Minn. R. 7017.2005, subp. 8 or at the operating conditions described at Minn. R. 7017.2025, subp. 2, using EPA Reference Methods 10, or other method approved by MPCA in the performance test plan approval. Testing conducted during the 60 days prior to the performance test due date will not reset the test due date for future testing as required by this permit or within a Notice of Compliance letter. Testing conducted more than 60 days prior to the performance test due date satisfies this test due date requirement but will reset future performance test due dates based on the performance test date. [Minn. R. 7011.1265, subp. 5, Minn. R. 7011.1270, D, Minn. R. 7017.2020, subp. 1]

7. Compliance schedule

This section of the permit contains the compliance schedule required by Minn. R. 7007.0500, subp. 2(K). You must complete the actions required in this section by the dates listed. All submittals must be postmarked or received by the date specified in the table, and certified by a responsible official, defined in Minn. R. 7007.0100, subp. 21.


Requirement number Requirement and Citation

EQUI 10 Smelting Furnace - Tilt Furnace #1

7.1.1 The Permittee shall submit a report: Due 30 calendar days after permit issuance that certifies that the hood conforms to the requirements identified in the Hood Certification and Evaluation requirement in this permit. The Permittee shall submit the results of the evaluation and certification on form CR-02, along with any other information required by the forms for MPCA review. [Corrective Action, Minn. R. 7007.0800, subp. 2]

EQUI 12 Smelting Furnace - Medium Tilt Furnace

7.2.1 The Permittee shall submit a report: Due 30 calendar days after permit issuance that certifies that the hood conforms to the requirements identified in the Hood Certification and Evaluation requirement in this permit. The Permittee shall submit the results of the evaluation and certification on form CR-02, along with any other information required by the forms for MPCA review. [Corrective Action, Minn. R. 7007.0800, subp. 2]

8. Appendices

Appendix A. Insignificant activities and general applicable requirements The table below lists the insignificant activities that are currently at the Facility and their associated general applicable requirements.

Minn. R. Rule description of the activity General applicable requirement

Minn. R. 7007.1300, subp. 3(D) Emissions from a laboratory, as defined in Minn. R. 7007.1300, subp. 3(D).

The Permittee operates a laboratory for quality control purposes.

The Permittee operates an assay smelting furnace where small quantities of sample are smelted and tested in the laboratory.

PM <= 0.30 grains per dry standard cubic foot of exhaust gas Opacity <= 20 percent opacity.

(Minn. R. 7011.0715)

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

Minn. R. 7007.1300, subp. 3(F) Individual units with potential emissions less than 2000 lb/year of certain pollutants

The Permittee operates five natural gas fired heaters, a natural gas fired office furnace, a natural gas fired make-up air unit, and a natural gas fired water heater.

The Permittee operates a small hammermill / screening operation for grinding silver oxide button batteries.

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

PM <= 0.30 grains per dry standard cubic foot of exhaust gas Opacity <= 20 percent opacity.

(Minn. R. 7011.0715)


Appendix B: Industrial Solid Waste Management Plan


Ash Management Plan & Mercury Separation Plan

Appendix C: Ash Management Plan

Ash Management Plan All ash generated from the waste combustion activities at ECI is considered a viable product. The ash contains a large amount of precious metals. The ash is pulled from the waste combustors and placed into steel containers for cooling. After 2-3 days of cooling, the ash is transferred into lined gaylord boxes and transported to metal recovery companies who further extract metals from the ash and pay ECI based on the recovery.

Appendix D: Mercury Waste Separation Plan

Mercury Waste Separation Plan All mercury containing material accepted by ECI is separated and placed in steel drums until an accumulation is ready to be sent to a proper mercury processing facility. Occasionally tests need to be run in Enviro-Chem’s laboratory operations in which samples of circuit boards are incinerated & smelted to gage metal contents on a laboratory scale. Some older circuit boards contain small amounts of mercury inside switches that ECI removes before processing. The laboratory operations are listed in the air permit application as an insignificant activity.

Technical Support Document, Permit Number: 05300411-101 Page 1 of 13

Technical Support Document for

Air Emission Permit No. 05300411-101 This technical support document (TSD) is intended for all parties interested in the permit and to meet the requirements that have been set forth by the federal and state regulations (40 CFR § 70.7(a)(5) and Minn. R. 7007.0850, subp. 1). The purpose of this document is to provide the legal and factual justification for each applicable requirement or policy decision considered in the determination to issue the permit. 1. General information

1.1 Applicant and stationary source location Table 1. Applicant and source address

Applicant/Address Stationary source/Address (SIC Code: 5093 - Scrap and Waste Materials)

Enviro-Chem Inc 21821 Industrial Blvd Rogers, Minnesota 55374-9575

Enviro-Chem Inc - Plant 1 21821 Industrial Blvd Rogers, MN 55374-9575

Contact: Todd Meyer Phone: 763-428-4002

1.2 Facility description

Enviro-Chem operates six incinerator units that combust film to recover the silver. These units qualify as Class IV waste combustors. Film is combusted three times a week (one day of incineration followed by one day of cooling). After about a month, the silver-rich ash is collected from the incinerators and sold. The incinerators are ducted into a baghouse. The main pollutants of concern are particulate matter (PM), particulate matter 10 micrometers or less in diameter (PM10), particulate matter 2.5 micrometers or less in diameter (PM2.5), carbon monoxide (CO), and volatile organic compounds (VOCs). The incinerators are vented to afterburners to control CO and VOCs, and then are vented to a baghouse to control PM, PM10, and PM2.5. The smelting operations consist of three crucible furnaces. Miscellaneous metal scraps and metal powders are smelted to recover the precious metals and copper. The main pollutants of concern are PM, PM10, PM2.5, and VOCs. The smelting furnaces EQUI 10 and EQUI 12 vent to a baghouse (TREA 17) to control PM, PM10 and PM2.5.

1.3 Description of the activities allowed by this permit action

This permit action is a State Reissuance.

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

07/28/2016 Minor Amendment (IND20160001) - Permittee requested to align performance testing dates, and to change the pressure drop for the baghouse. These changes are being made through the reissuance permit action.

11/22/2011 State Reissuance (IND20110002)

2/11/2011 Permit Reopening (IND20110001) – Verified production operating limits for baghouse (TREA 17)


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 9.24 6.46 6.46 0.90 5.23 7.18 5630 2.77 0.08 0.106

Total facility actual emissions 0.569 0.572 0.517 0.163 0.464 0.159 414 0.04 0.0002 0.0003

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 permit does not authorize any specific modifications, however, the MPCA has a combined operating and construction permitting program under Minnesota Rules Chapter 7007, and under Minn. R. 7007.0800, 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.

Completed requirements and the requirements for equipment that has been removed have been deleted.

EQUI 11 was removed from the permit because it has been removed from the facility.

COMG 2 was removed from the permit and the requirements for the smelting units were moved to EQUI 9, EQUI 10, and EQUI 12.

Baghouse (TREA 17) pressure drop range was changed to reflect the specification of the manufacturer.

Performance testing dates for cadmium, lead, and mercury were revised to align with the other required performance testing.

Afterburner requirements were moved to the individual control equipment level at TREA 6 and TREA 8.

Ash testing requirements were updated to require reporting of weight percent of each pollutant in ash so that results can be considered in developing emission factors.

Silver precipitation operation removed from insignificant activities because no emissions are expected to occur from this process.

EQUI 15 (gold precipitation operations) was removed from permit as no emissions are expected to occur from this process.

Baghouse (TREA 17) control efficiency for PM10 and PM2.5 added to the permit.

Requirements added for EQUI 10 and EQUI 12 to operate in certified ventilation hoods to take credit for baghouse (TREA 17 control).

PM emission limit of 2.0 lbs/hr set at STRU 1.

PM performance testing requirements were updated to require operation of EQUI 10 and EQUI 12 during test.


2. Regulatory and/or statutory basis 2.1 New source review (NSR)

The facility is a non-major source under the New Source Review program. No changes are authorized by this permit.

2.2 Part 70 permit program The Facility is a nonmajor source under the Part 70 permit program. Although PM PTE is over 100 tpy, PM is not considered a “regulated pollutant” within the definition of a major source in 40 CFR § 70.2. According to the EPA guidance document dated October 19, 1995, with subject line Definition of Regulated Pollutant for Particulate Matter for Purpose of Title V, written by Lydia N. Wegman, Deputy Director, a Title V operating permit is not required if the only pollutant that would make the source major is particulate matter.

2.3 New source performance standards (NSPS)

The Permittee states that no New Source Performance Standards apply to the operations at this facility. Per 40 CFR 60.2875, these incinerators are not subject to 40 CFR Subpart DDDD—Emissions Guidelines and Compliance Times for Commercial and Industrial Solid Waste Incineration Units.

2.4 National emission standards for hazardous air pollutants (NESHAP) The facility is an area source under 40 CFR pt.63. The Permittee states that no NESHAPS apply.

2.5 Regulatory Overview

Table 5. Regulatory overview of facility

Subject item* Applicable regulations Rationale

COMG 1 - Air Component Group

Minn. R. 7011.1201- 7011.1294

Standards of Performance for Waste Combustors. The design capacity for each waste combustor in COMG 1 is less than 3.0 x 106 Btu/hr; thus the facility is classified as a Class IV waste combustor, specifically, a metals recovery furnace. This is a state-only requirement and is not enforceable by the EPA Administrator and citizens under the Clean Air Act.

EQUI 9 – Med. Crucible Furnace.

EQUI 10 – Tilt Furn. #1

EQUI 12 – Med. Tilt Furn.

Minn. R. 7011.0515 Standards of Performance for New Indirect Heating Equipment. The limit applies to both the combustion emissions and the process emissions from the smelting units. Determination of applicable limit from rule

• construction of the unit was on or after January 31, 1977 (commenced October 1, 1997);

• the unit burns gaseous fuels;

• the facility is located within the MSP air quality control region in Table II of the rule;

• the unit capacity is less than or equal to 250 MMBtu/hr; and

• the facility has less than or equal to 250 MMBtu/hr of indirect heating equipment.


Subject item* Applicable regulations Rationale

TREA 6 and TREA 8 Minn. R. 7011.1201- 7011.1294


TREA 17 - Fabric Filter - Med Temp, 180 F<T<250 F

Minn. R. 7011.1201- 7011.1294


STRU 1 – Baghouse Stack

Minn. R. 7007.0800, subp. 2 To make enforceable limited PTE from previous permit actions.

*Location of the requirement in the permit (e.g., EQUI 1, STRU 2, etc.).

3. Technical information

3.1 Calculations of potential to emit (PTE) Attachment 1 to this TSD contains a summary of the PTE of the Facility, and contains detailed spreadsheets and supporting information prepared by the MPCA and the Permittee. Previous permit calculations methodology was deemed inappropriate and more appropriate calculations were drafted for this permit action. Incinerators Potential emissions from the natural gas incinerators (waste combustors) include emissions from the waste combustion process and from the combustion of the natural gas. To determine permit program applicability, the waste combustor rule PM limit of 0.035 gr/dscf was applied at each incinerator individuality. The airflow rate between the individual incinerators is unknown so the baghouse airflow measurement (in dscf) from the 2015 performance test plan was conservatively used. This method of calculating PTE is conservative and led to the facility having an unreasonably large growth in permit allowable PM emissions from the 2007 permit. No changes have been made to the facility so an emission limit was set for PM to maintain the permit allowable emissions to the same approximate levels as in the previous permit. This limit encompasses all emission units controlled by the baghouse which include the 6 incinerators and 2 smelters (EQUI 10 and EQUI 12). The emission limit of 2.0 lbs/hr for PM was set at the baghouse stack (STRU 1). It is highly unlikely that the facility can violate the limit. Potential emission rates for PM10, PM2.5, CO, Lead, Cd, and Hg were determined using emission factors from the results of the October 2015 and January 2016 performance tests. Permit requires testing for PM and emission factors for PM10 and PM2.5 assume PM = PM10 = PM2.5. The largest tested values from these tests multiplied by a safety factor of 20% were used. These results are conservative as they represent all waste combustors being run at maximum capacity but are applied to each waste combustor individually for CO, PM10, PM2.5, Lead, and Cd. The performance test results are used only for the waste combustors and are conservative as natural gas combustion is likely occurring during the performance test. These emission factor will have to reevaluated during the next permit action as performance testing in 2025 will also include emissions from smelting units (EQUI 10 and 12). Emissions from the combustion of natural gas from each of these units are based on their maximum fuel combustion capacity. Natural gas and GHG emission factors are from AP-42 chapter 1.4. Emissions for selenium and nickel are based on ash testing. No information about fabric filter control efficiencies for HAP’s were provided by the Permittee so it was assumed that there are none.


Smelting Potential emissions for PM, PM10, PM2.5, VOCs, and SO2 are calculated using the furnace capacity and AP-42 values for Secondary Copper Production - /Crucible and Pot Furnace, Charge with brass and bronze. This is a reasonable assumption for this operation as copper is the main metal recovered. The smelting operations are a batch process, according to Enviro-Chem, three hours is the shortest timeframe for each melt, resulting in a conservative assumption for emission calculations. PTE calculations for Mercury, Nickel, and Selenium are based on the results from previous ash testing. The record of the testing is not clear so values submitted by the Permittee will be used in this permit action and reevaluated after the next ash test in 2020. EQUI 10 and EQUI 12 are to be operated in certified hoods and emissions are ducted to the baghouse (TREA 17) and are accounted for under the PM emission limit set at the stack. As of the date of permit issuance, these hoods are in the process of being certified with a permit requirement for the process to be completed within 30 days. EQUI 9 is not operated in a certified hood and emissions are assumed to vent internally at the facility. Insignificant Activities There are five natural fired heaters, a natural gas fired office furnace, a natural gas fired make-up air unit and a natural gas fired water heater at the facility that qualify as insignificant activities under MN. R. 7007.1300 Subpart 3(f). Natural gas emission factors were obtained from AP-42 Chapter 1.4. There is also a Small hammermill/screening operation for grinding silver oxide batteries. An emission factor could not be located for a battery grinding in a hammermill. Therefore, a conservative assumption was that the battery hammermill particulate emissions are similar to Crushed Stone Fines Crushing. AP-42 Table 11.19.2-2 details emission factors for Fines Crushing.

3.2 Mercury Rule

In 2015 Enviro-Chem received a notice that it appeared to be a “mercury emission source” based on the MPCA’s 2011 Air Toxics Inventory. This source is no longer a mercury emissions source as its actual mercury emissions have been under the 3 lb/yr threshold since 2014 as required by Minn. R. 7007.0502. Actual mercury emissions listed in table 6 are from the facility’s annual emission inventory. Table 6. Actual Mercury Emissions

2011 2012 2013 2014 2015 2016 2017 2018

Mercury Emissions (lbs)

3.86 5.60 4.75 2.99 0.24 0.18 0.15 0.18

3.3 Removal of Silver Precipitation Operation from Permit

Enviro-chem uses an evaporator to remove water from spent cyanide solution that it receives from vendors. The solution received is approximately 3 vol% Potassium Silver Cyanide solution, and the balance of the solution is greater than 96.5 vol% water. This solution is fed to an evaporation vessel, where heat is added and the water is evaporated away. Potassium Silver Cyanide is soluble in liquid water, but not as a vapor. As the water is evaporated away, the Potassium Silver Cyanide remains behind in a sludge that is then sold for the silver content. This process hasn’t been used since 2016 but the equipment is also used for gold recovery operations. As the only emissions from this process is water vapor, this activity was removed from the insignificant activities list.

3.4 Removal of Gold Precipitation Operation from Permit

Enviro-chem uses a precipitation tank and the same evaporator from the silver recovery operation to reclaim gold from spent cyanide solution. The solution received is approximately 1.5 vol% Potassium Gold Cyanide solution, and the balance of the solution is greater than 98 vol% water. This solution is transferred to a precipitation tank where aluminum powder is added to precipitate out the gold. The solution is strained to remove the precipitant and fed to an evaporation vessel. Potassium Gold Cyanide is soluble in liquid


water, but not as a vapor. As the water is evaporated away the Potassium Gold Cyanide remains behind in a sludge that is sold for the gold content. This process is used infrequently. As the only emissions from this process is water vapor, this activity was removed from the permit.

3.5 Performance Testing Results Since Last Total Facility Permit Table 7. Performance Testing Results

Emission unit tested Test Date(s) Pollutant Limit Test result

Test Result % of Limit

Compliance status

Incinerator Baghouse

Stack

1/23/2007 PM <=0.035 gr/DSCF at 7% O2

0.0147 dr/dscf at 7% O2

42 Compliant

CO 50 ppm at 7% O2 4.8 ppm at 7% O2

10 Compliant

Opacity <= 20% 3.75% 19 Compliant


Stack

11/3/2010 PM <=0.035 gr/dscf at 7% O2

0.011 gr/dscf at 7% O2

31 Compliant

CO 50 ppm at 7% O2 18 ppm at 7% O2

36 Compliant

Opacity <= 20% 0% 0 Compliant

Cadmium N/A 0.090 ug/dscm

N/A Verified

Lead N/A 3.8 ug/dscm N/A Verified

Mercury N/A 21.6 ug/dscm N/A Verified


Stack

10/22/2015 and

12/09/2015

PM <=0.035 gr/dscf at 7% O2

0.0135 gr/dscf 39 Compliant

CO 50 ppm at 7% O2 67.9 ppm at 7% O2

135 Noncompliant*

Opacity <= 20% 0% 0 Compliant

Cadmium N/A 4.46 ug/dscm N/A Verified

Lead N/A 3.62 ug/dscm N/A Verified

Mercury N/A 1.47 ug/dscm N/A Verified


Stack

1/7/2016 CO 50 ppm at 7% O2 30.1 ppm at 7% O2

60 Compliant

Ash Test 10/29/2015 Mercury N/A 1.9 mg/l N/A Verified

Arsenic N/A 0.45 mg/l N/A Verified

Barium N/A 1.35 mg/l N/A Verified

Cadmium N/A 186 mg/l N/A Verified

Chromium N/A 0.45 mg/l N/A Verified

Lead N/A 13.0 mg/l N/A Verified

Nickle N/A 9.35 mg/l N/A Verified

Selenium N/A 0.45 mg/l N/A Verified

Silver N/A 0.45 mg/l N/A Verified

* The October 2015 performance tests of the Incinerator baghouse stack for CO showed non-compliance with the limit. The Permittee retested in January 2016 and was in compliance with the limit.


3.6 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 8 summarizes the monitoring requirements.


Table 8. Monitoring

Subject Item* Requirement (basis)

What is the monitoring? Why is this monitoring adequate?

COMG 1 - Six Class IV Waste Combustors

Opacity <= 20% opacity;

PM <= 0.035 gr/dscf, corrected to 7% oxygen on a dry volume basis;

CO <= 50 ppm, corrected to 7% oxygen on a dry volume basis;

Combustion Chamber Temperature >= 1800 degrees F, 4-hour block average.

[Minn. R. 7011.1225, subp. 5]

Ash management plan

[7007.0501, subp. 7]

Mercury waste separation plan

[Minn. R. 7007.0501, subp. 5]

Industrial waste management plan

[7007.0801, subps. 1 and 3]

Performance testing, continuous temperature monitoring,

Daily operating records, Recordkeeping,

Annual reports

Compliance with the operational, testing, and recordkeeping requirements of the Minnesota Standards of Performance for Waste Combustors is sufficient to ensure compliance with the emission limits established in the standard. Performance testing, as required under Minn. R. 7011.1260, subp. 5 is required for lead, cadmium, and mercury every 60 months. Additionally, each waste combustor vents to an afterburner, either TREA 6 or 8. Therefore, the operation and monitoring requirements of the afterburners ensure that the limits are met.




EQUI 9 - Med. Crucible Furn.

EQU I10 - Tilt Furn. #1

EQUI 12 - Med. Tilt Furn.

PM <= 0.40 lb/MMBtu heat input.

Opacity <= 20 % except for one six-minute period per hour of not more than 27 percent opacity.

[Minn. R. 7011.0515, subp. 1 and 2]

Recordkeeping

Emissions from these units include both process emissions and natural gas combustion emissions. These units use natural gas; therefore, the likelihood of violating either of the emission limits is very small. The Permittee can demonstrate that these units will continue to operate such that emissions are well below the emission limits by only burning natural gas.

Design based PTE for EQUI 9, using AP-42, is 0.21 lbs/MMBtu of PM compared to the rule limit of 0.4 lbs/MMBtu of PM.

EQUI 10 and 12 are required to vent to a baghouse (TREA 17). Therefore, the control efficiency and associated monitoring ensure the limits can be met.

TREA 6 – Thermal Oxidizer

TREA 8 – Thermal Oxidizer

Temperature >= 1800 degrees F 4-hour rolling average

[Minn. R. 7011.1235, subp. 2]

Continuous Temperature monitoring, Recordkeeping, O & M, inspections

Monitoring based on the Minnesota Waste Combustion Rules is adequate to have a reasonable assurance of compliance.

TREA 17 - Fabric Filter - Med Temp, 180 F<T<250 F

PM < 2.5 >= 93 % control efficiency.

PM < 10 >= 93 % control efficiency.

Particulate Matter >= 99 % control efficiency.

Pressure Drop 0.5 >= and <= 4.5 inches of water,

[Minn. R. 7011.0070,

Minn. R. 7011.1260, subp. 2]

Continuous Monitor,

Daily and periodic inspections, operation and maintenance, corrective actions, and recordkeeping

Monitoring based on the Minnesota Performance Standard for Control Equipment is adequate to have a reasonable assurance of compliance.




STRU 1 – Baghouse Stack

Particulate Matter <=2.0 lbs/hr

[Minn. R. 7007.0800, subp. 2]

Performance testing

TREA 17 is the sole contributor to STRU 1. TREA 17 controls all six incinerators and smelting units EQUI 10 and EQUI 12. The highest 2015 PM performance test results for the incinerators (0.15lb/hr) and the PTE for EQUI 10 (0.22 lb/hr) and EQUI 12 (0.13lb/hr) suggest that the facility will meet this limit. Combined these emissions are 0.50 lb/yr which is 25% of the permit limit. This limit relies on TREA 17’s 99% PM control efficiency. All associated monitoring and recordkeeping for TREA 17 and performance testing on a 60-month frequency are adequate to have a reasonable assurance of compliance.

*Location of the requirement in the permit (e.g., EQUI 1, STRU 2, etc.).

3.7 Insignificant activities

Enviro-Chem Inc - Plant 1 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 outlined earlier in this TSD, the following table documents the justification why no additional periodic monitoring is necessary for the current insignificant activities. See Attachment 1 of this TSD for PTE information for the insignificant activities. Table 9. Insignificant activities

Insignificant activity General applicable emission limit

Discussion

Emissions from a laboratory, as defined in Minn. R. 7007.1300, subp. 3(d).

PM <= 0.4 lb/MMBtu; Opacity <= 20%

(Minn. R. 7011.0515)

Small assay smelting furnace where small quantities of sample are smelted and tested in the laboratory. This furnace is designed to be a quality control furnace and is much smaller than the production furnaces. All activities are conducted on a laboratory scale and nothing is manufactured or produced for profit. For this unit, 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


PM, variable depending on airflow

Opacity <= 20%

(Minn. R. 7011.0715)

A laboratory used for quality control. These are very small, intermittent, bench-top operations that typically do not even have any emissions. It is highly unlikely that they could violate the applicable requirement.

Individual units with potential emissions less than 2000 lb/year of certain pollutants


Opacity <= 20%

(Minn. R. 7011.0715)

Small hammermill/screening operations for grinding silver oxide batteries. This unit has a PTE of 0.019 lb/hr. Applicable rule limit at maximum process rate is 1.7 lb/hr. For these units, 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.


Insignificant activity General applicable emission limit

Discussion



(Minn. R. 7011.0515)

Small assay smelting furnace where small quantities of sample are smelted and tested in the laboratory. This furnace is designed to be a quality control furnace and is much smaller than the production furnaces. All activities are conducted on a laboratory scale and nothing is manufactured or produced for profit. For this unit, 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



Opacity <= 20%

(Minn. R. 7011.0715)

A laboratory used for quality control. These are very small, intermittent, bench-top operations that typically do not even have any emissions. It is highly unlikely that they could violate the applicable requirement.

Individual units with potential emissions less than 2000 lb/year of certain pollutants


(Minn. R. 7011.0515)

Five natural fired heaters, a natural gas fired office furnace, a natural gas fired make-up air unit and a natural gas fired water heater. For the natural gas units, based on the fuels used and EPA published emissions factors, it is highly unlikely that they could violate the applicable requirement. In addition, all of these units are operated and vented inside a building, so testing for PM or opacity is not feasible.

3.8 Permit organization

This permit meets the MPCA Tempo Guidance for ordering and grouping of requirements as well as the use of permit appendices.

3.9 Comments received

No comments were received from the public during the public notice period and no changes were made to the permit since placing it on public notice. Public Notice Period: 02/06/2020 – 3/06/2020 EPA Review Period: 02/06/2020 – 03/06/2020

4. Permit fee assessment This permit action is the reissuance of an individual state permit; therefore, no application fees apply under Minn. R. 7002.0016, subp. 1.

5. Conclusion Based on the information provided by Enviro-Chem Inc - Plant 1 the MPCA has reasonable assurance that the proposed operation of the emission facility, as described in the Air Emission Permit No. 05300411-101 and this TSD, will not cause or contribute to a violation of applicable federal regulations and Minnesota Rules. Staff members on permit team: Mose McLain (permit engineer)

Bruce Braaten (peer reviewer) Beckie Olson (permit writing assistant) Laurie O’Brien (administrative support) Michaela Leach (data coordinator) Marc Severin (compliance)

Brent Rohne (enforcement)


TEMPO360 Activities: Minor Amendment (IND20160001), State Reissuance (IND20110002), Permit Reopening (IND20110001)

Attachments: 1. PTE summary calculation spreadsheets 2. SI Details Report and Requirements Summary

Attachment 1:

PTE summary calculation spreadsheets

Permit Emission CalculationsEnviro-ChemRogers, MN

Potential Emission Summary

Emission Unit EU ID Lb/HrUnrestricted

tpyLimited

tpy Lb/HrUnrestricted

tpyLimited


tpyLimited


tpyLimited

tpyAssay WC EQUI21 19.118 0.195 11.328 0.854 0.195 11.328 0.854 2.72E-02 1.19E-01 1.19E-01Film Negative WC 1 EQUI17 19.157 0.204 11.367 0.893 0.204 11.367 0.893 2.79E-02 1.22E-01 1.22E-01Film Negative WC 2 EQUI18 19.079 0.186 11.289 0.815 0.186 11.289 0.815 2.65E-02 1.16E-01 1.16E-01Film Negative WC 3 EQUI19 19.079 0.186 11.289 0.815 0.186 11.289 0.815 2.65E-02 1.16E-01 1.16E-01Film Negative WC 4 EQUI20 19.079 0.186 11.289 0.815 0.186 11.289 0.815 2.65E-02 1.16E-01 1.16E-01Film Negative WC 5 EQUI22 19.079 0.186 11.289 0.815 0.186 11.289 0.815 2.65E-02 1.16E-01 1.16E-01Med. Melt. Furn. #1 EQUI9 0.109 0.476 0.476 6.57E-02 0.288 0.288 6.57E-02 0.288 0.288 2.79E-03 1.22E-02 1.22E-02Tilt Furn. #1 EQUI10 4.64 0.168 2.75 0.734 0.168 2.75 0.734 2.57E-02 0.113 0.113Med. Tilt Furn. #1 EQUI12 2.71 9.85E-02 1.61 0.432 9.85E-02 1.61 0.432 1.51E-02 6.59E-02 6.59E-02Baghouse Stack STRU 1 2.000 8.760TOTALS: 2.11 122.42 9.24 1.47 72.50 6.46 1.47 72.50 6.46 0.20 0.90 0.90


Emission Unit EU ID Lb/HrUnrestricted

tpyLimited


tpyLimited


tpyLimited


tpyLimited

tpyAssay WC EQUI21 2.65E-04 1.16E-03 1.16E-03 3.26E-04 1.43E-03 1.43E-03 6.04E-08 6.04E-06 2.64E-07Film Negative WC 1 EQUI17 2.66E-04 1.16E-03 1.16E-03 3.27E-04 1.43E-03 1.43E-03 8.86E-08 6.16E-06 3.88E-07Film Negative WC 2 EQUI18 2.64E-04 1.16E-03 1.16E-03 3.25E-04 1.42E-03 1.42E-03 3.21E-08 5.92E-06 1.41E-07Film Negative WC 3 EQUI19 2.64E-04 1.16E-03 1.16E-03 3.25E-04 1.42E-03 1.42E-03 3.21E-08 5.92E-06 1.41E-07Film Negative WC 4 EQUI20 2.64E-04 1.16E-03 1.16E-03 3.25E-04 1.42E-03 1.42E-03 3.21E-08 5.92E-06 1.41E-07Film Negative WC 5 EQUI22 2.64E-04 1.16E-03 1.16E-03 3.25E-04 1.42E-03 1.42E-03 3.21E-08 5.92E-06 1.41E-07Med. Melt. Furn. #1 EQUI9 9.91E-07 4.34E-06 4.34E-06 3.10E-05 1.36E-04 1.36E-04 1.40E-07 6.13E-07 6.13E-07 1.95E-08 8.56E-08 8.56E-08Tilt Furn. #1 EQUI10 2.14E-06 9.37E-06 3.52E-05 6.46E-05 2.83E-04 1.34E-03 4.32E-07 1.45E-06 1.45E-06 4.44E-08 4.64E-07 1.94E-07Med. Tilt Furn. #1 EQUI12 1.30E-06 5.68E-06 2.08E-05 3.78E-05 1.66E-04 7.82E-04 2.77E-07 9.60E-07 9.60E-07 2.83E-08 2.81E-07 1.24E-07Component Group 1 COMG1 1.94E-04 8.51E-04 8.51E-04TOTALS: 1.59E-03 6.98E-03 7.02E-03 2.09E-03 9.14E-03 1.08E-02 1.95E-04 8.54E-04 8.54E-04 3.70E-07 3.67E-05 1.62E-06

PM PM10 PM2.5 SO2

Lead Cadmium Mercury Selenium



Emission Unit EU IDAssay WC EQUI21Film Negative WC 1 EQUI17Film Negative WC 2 EQUI18Film Negative WC 3 EQUI19Film Negative WC 4 EQUI20Film Negative WC 5 EQUI22Med. Melt. Furn. #1 EQUI9Tilt Furn. #1 EQUI10Med. Tilt Furn. #1 EQUI12Baghouse Stack STRU 1TOTALS:


Emission Unit EU IDAssay WC EQUI21Film Negative WC 1 EQUI17Film Negative WC 2 EQUI18Film Negative WC 3 EQUI19Film Negative WC 4 EQUI20Film Negative WC 5 EQUI22Med. Melt. Furn. #1 EQUI9Tilt Furn. #1 EQUI10Med. Tilt Furn. #1 EQUI12Component Group 1 COMG1TOTALS:

Lb/HrUnrestricted

tpyLimited


tpyLimited


tpyLimited


tpy

Unrestricted tpy

0.217 0.950 0.950 0.012 0.732 0.054 0.288 11.55 1.26 236 1033 10330.335 1.465 1.465 0.019 0.760 0.082 0.387 12.0 1.70 377 1652 16520.099 0.435 0.435 0.006 0.703 0.026 0.189 11.12 0.830 94.3 413 4130.099 0.435 0.435 0.006 0.703 0.026 0.189 11.12 0.830 94.3 413 4130.099 0.435 0.435 0.006 0.703 0.026 0.189 11.12 0.830 94.3 413 4130.099 0.435 0.435 0.006 0.703 0.026 0.189 11.12 0.830 94.3 413 413

4.90E-02 0.215 0.215 3.62E-02 0.159 0.159 4.12E-02 0.180 0.180 58.9 258 2580.118 0.515 0.515 0.341 1.50 1.50 9.882E-02 0.433 0.433 141 620 620

7.84E-02 0.344 0.344 0.200 0.875 0.875 6.59E-02 0.289 0.289 94.3 413 413

1.19 5.23 5.23 0.63 6.83 2.77 1.64 68.90 7.18 1,285.01 5,628.32 5,628.32

Lb/HrUnrestricted

tpyLimited


tpyLimited


tpyLimited


tpyLimited

tpy5.61E-06 6.72E-04 2.46E-05 4.28E-03 2.06E-02 1.88E-02 2.35E-06 1.03E-05 1.03E-05 1.47E-04 6.44E-04 6.44E-048.08E-06 6.83E-04 3.54E-05 6.50E-03 3.03E-02 2.85E-02 3.76E-06 1.65E-05 1.65E-05 2.35E-04 1.03E-03 1.03E-033.14E-06 6.62E-04 1.38E-05 2.07E-03 1.09E-02 9.05E-03 9.41E-07 4.12E-06 4.12E-06 5.88E-05 2.58E-04 2.58E-043.14E-06 6.62E-04 1.38E-05 2.07E-03 1.09E-02 9.05E-03 9.41E-07 4.12E-06 4.12E-06 5.88E-05 2.58E-04 2.58E-043.14E-06 6.62E-04 1.38E-05 2.07E-03 1.09E-02 9.05E-03 9.41E-07 4.12E-06 4.12E-06 5.88E-05 2.58E-04 2.58E-043.14E-06 6.62E-04 1.38E-05 2.07E-03 1.09E-02 9.05E-03 9.41E-07 4.12E-06 4.12E-06 5.88E-05 2.58E-04 2.58E-041.90E-06 8.33E-06 8.33E-06 9.56E-04 4.19E-03 4.19E-03 5.88E-07 2.58E-06 2.58E-06 3.68E-05 1.61E-04 1.61E-044.28E-06 4.90E-05 1.88E-05 2.28E-03 1.00E-02 1.11E-02 1.41E-06 6.18E-06 6.18E-06 8.82E-05 3.86E-04 3.86E-042.70E-06 2.95E-05 1.18E-05 1.52E-03 6.67E-03 7.27E-03 9.41E-07 4.12E-06 4.12E-06 5.88E-05 2.58E-04 2.58E-04

1.94E-04 8.51E-04 8.51E-043.51E-05 4.09E-03 1.54E-04 2.40E-02 0.116 0.107 1.28E-05 5.62E-05 5.62E-05 8.01E-04 3.51E-03 3.51E-03

Formaldehyde

CONOx VOC CO2e

Nickel HAPs Dichlorobenzene



Emission Unit EU IDAssay WC EQUI21Film Negative WC 1 EQUI17Film Negative WC 2 EQUI18Film Negative WC 3 EQUI19Film Negative WC 4 EQUI20Film Negative WC 5 EQUI22Med. Melt. Furn. #1 EQUI9Tilt Furn. #1 EQUI10Med. Tilt Furn. #1 EQUI12Baghouse Stack STRU 1TOTALS:


Emission Unit EU IDAssay WC EQUI21Film Negative WC 1 EQUI17Film Negative WC 2 EQUI18Film Negative WC 3 EQUI19Film Negative WC 4 EQUI20Film Negative WC 5 EQUI22Med. Melt. Furn. #1 EQUI9Tilt Furn. #1 EQUI10Med. Tilt Furn. #1 EQUI12Component Group 1 COMG1TOTALS:

Lb/HrUnrestrict

ed Limited

tpy Lb/HrUnrestric

ted Limited

tpy Lb/HrUnrestrict

ed Limited

tpy Lb/HrUnrestrict

ed Limited

tpy3.53E-03 1.55E-02 1.55E-02 1.20E-06 5.24E-06 5.24E-06 6.67E-06 2.92E-05 2.92E-05 1.63E-07 7.15E-07 7.15E-075.65E-03 2.47E-02 2.47E-02 1.91E-06 8.38E-06 8.38E-06 1.07E-05 4.67E-05 4.67E-05 2.61E-07 1.14E-06 1.14E-061.41E-03 6.18E-03 6.18E-03 4.78E-07 2.10E-06 2.10E-06 2.67E-06 1.17E-05 1.17E-05 6.53E-08 2.86E-07 2.86E-071.41E-03 6.18E-03 6.18E-03 4.78E-07 2.10E-06 2.10E-06 2.67E-06 1.17E-05 1.17E-05 6.53E-08 2.86E-07 2.86E-071.41E-03 6.18E-03 6.18E-03 4.78E-07 2.10E-06 2.10E-06 2.67E-06 1.17E-05 1.17E-05 6.53E-08 2.86E-07 2.86E-071.41E-03 6.18E-03 6.18E-03 4.78E-07 2.10E-06 2.10E-06 2.67E-06 1.17E-05 1.17E-05 6.53E-08 2.86E-07 2.86E-078.82E-04 3.86E-03 3.86E-03 2.99E-07 1.31E-06 1.31E-06 1.67E-06 7.30E-06 7.30E-06 4.08E-08 1.79E-07 1.79E-072.12E-03 9.28E-03 9.28E-03 7.18E-07 3.14E-06 3.14E-06 4.00E-06 1.75E-05 1.75E-05 9.79E-08 4.29E-07 4.29E-071.41E-03 6.18E-03 6.18E-03 4.78E-07 2.10E-06 2.10E-06 2.67E-06 1.17E-05 1.17E-05 6.53E-08 2.86E-07 2.86E-07

1.92E-02 8.43E-02 8.43E-02 6.52E-06 2.86E-05 2.86E-05 3.63E-05 1.59E-04 1.59E-04 8.89E-07 3.89E-06 3.89E-06

Hexane Naphthalene Toluene POMs


Incinerator Emissions

Waste Combustor EU ID

Baghouse PM Control

(%)

Baghouse PM10 / PM2.5

Control (%)

Afterburner CO Control

(%)

Afterburner VOC Efficiency

(%)

WCR PM Limit

(gr/dscf)Airflow (1)

(dscfm)

Potential Material

Incinerated (2) (tpy)

Unrestricted WCR PM

Emissions (3) (lb/hr)

Unrestricted WCR PM Emissions

(tpy)

Permit Allowable Emissions (4) (lb/hr)

Permit Allowable Emissions Emissions (gr/dscf)

Permit Allowable Emissions (ton/yr)


Unrestricted Emissions (ton/yr)


Assay WC EQUI21 99.0% 93.0% 95.0% 99.0% 0.035 14,500.0 91.3 4.35 19.1 0.180 11.26 0.788Film Negative WC 1 EQUI17 99.0% 93.0% 95.0% 99.0% 0.035 14,500.0 91.3 4.35 19.1 0.180 11.26 0.788Film Negative WC 2 EQUI18 99.0% 93.0% 95.0% 99.0% 0.035 14,500.0 91.3 4.35 19.1 0.180 11.26 0.788Film Negative WC 3 EQUI19 99.0% 93.0% 95.0% 99.0% 0.035 14,500.0 91.3 4.35 19.1 0.180 11.26 0.788Film Negative WC 4 EQUI20 99.0% 93.0% 95.0% 99.0% 0.035 14,500.0 91.3 4.35 19.1 0.180 11.26 0.788Film Negative WC 5 EQUI22 99.0% 93.0% 95.0% 99.0% 0.035 14,500.0 91.3 4.35 19.1 0.180 11.26 0.788Component Group 1 COMG1 14,500.0

Baghouse Stack STRU 1 14,500.0 2.00 0.0161 8.76TOTALS 114 2.00 8.76 67.6 4.73

Notes

6. The baghouse dust was analyzed for TCLP metal contents. The results indicated 0.00083% Nickel and 0.0000074% Selenium.7. SO2, VOC and NOx Emission factors are from AP-42: Solid Waste Disposal Table 2.1-12, Combusters Other Than Municipal Waste, Industrial/Commercial, Single Chamber.

from January 7, 2016 stack test. Assumes PM = PM10 = PM2.5

4. PM emission limit set at stack to avoid Pt. 70, (ecompasing all EQUI's that are controlled by baghouse)

Calculation Parameters PM PM10

1. Stack airflow from October 22, 2015 stack test plan aproval measurements2. Maximum Capacity = 1000 lb capacity * 365 days/2days operating per batch/2000 lbs/ton = 91.25 ton/yr.3. Unrestricted PM emissions calculated from Waste Combustor Rule limit for permit applicability determination.

5. PM10, PM2.5, Lead, Cadmium, and Mercury emissions factors from highest result from October 22, 2015 stack test multiplied by a saftey factor of 20%. CO is



Waste Combustor EU IDAssay WC EQUI21

Film Negative WC 1 EQUI17Film Negative WC 2 EQUI18Film Negative WC 3 EQUI19Film Negative WC 4 EQUI20Film Negative WC 5 EQUI22Component Group 1 COMG1

Baghouse Stack STRU 1TOTALS
















Emission Composition

(6)

Permit Allowable Emissions

(lb/hr)



0.180 11.26 0.788 0.124 10.83 0.541 2.64E-04 1.16E-03 1.16E-03 3.24E-04 0.00142 0.00142 0.0000074% 1.33E-08 5.83E-06 5.83E-080.180 11.26 0.788 0.124 10.83 0.541 2.64E-04 1.16E-03 1.16E-03 3.24E-04 0.00142 0.00142 0.0000074% 1.33E-08 5.83E-06 5.83E-080.180 11.26 0.788 0.124 10.83 0.541 2.64E-04 1.16E-03 1.16E-03 3.24E-04 0.00142 0.00142 0.0000074% 1.33E-08 5.83E-06 5.83E-080.180 11.26 0.788 0.124 10.83 0.541 2.64E-04 1.16E-03 1.16E-03 3.24E-04 0.00142 0.00142 0.0000074% 1.33E-08 5.83E-06 5.83E-080.180 11.26 0.788 0.124 10.83 0.541 2.64E-04 1.16E-03 1.16E-03 3.24E-04 0.00142 0.00142 0.0000074% 1.33E-08 5.83E-06 5.83E-080.180 11.26 0.788 0.124 10.83 0.541 2.64E-04 1.16E-03 1.16E-03 3.24E-04 0.00142 0.00142 0.0000074% 1.33E-08 5.83E-06 5.83E-08

1.92E-04 8.41E-04 8.41E-04

67.6 4.73 65.0 3.25 0.00694 0.00694 0.00851 0.00851 8.41E-04 8.41E-04 3.50E-05 3.50E-07

SeleniumPM2.5 CO Lead Cadmium Mercury



Waste Combustor EU IDAssay WC EQUI21

Film Negative WC 1 EQUI17Film Negative WC 2 EQUI18Film Negative WC 3 EQUI19Film Negative WC 4 EQUI20Film Negative WC 5 EQUI22Component Group 1 COMG1

Baghouse Stack STRU 1TOTALS

Emission Composition (6)


(lb/hr)



Emission Factor (7)

(lb/ton burned)


(lb/hr)



Emission Factor (7)

(lb/ton burned)


(lb/hr)



Emission Factor (7)

(lb/ton burned)


(lb/hr)




(lb/hr)



0.00083% 1.49E-06 6.54E-04 6.54E-06 2.50 0.0260 0.114 0.114 15.0 1.56E-03 0.684 6.84E-03 2.00 2.08E-02 0.0913 0.0913 5.90E-04 3.24E-03 2.58E-030.00083% 1.49E-06 6.54E-04 6.54E-06 2.50 0.0260 0.114 0.114 15.0 1.56E-03 0.684 6.84E-03 2.00 2.08E-02 0.0913 0.0913 5.90E-04 3.24E-03 2.58E-030.00083% 1.49E-06 6.54E-04 6.54E-06 2.50 0.0260 0.114 0.114 15.0 1.56E-03 0.684 6.84E-03 2.00 2.08E-02 0.0913 0.0913 5.90E-04 3.24E-03 2.58E-030.00083% 1.49E-06 6.54E-04 6.54E-06 2.50 0.0260 0.114 0.114 15.0 1.56E-03 0.684 6.84E-03 2.00 2.08E-02 0.0913 0.0913 5.90E-04 3.24E-03 2.58E-030.00083% 1.49E-06 6.54E-04 6.54E-06 2.50 0.0260 0.114 0.114 15.0 1.56E-03 0.684 6.84E-03 2.00 2.08E-02 0.0913 0.0913 5.90E-04 3.24E-03 2.58E-030.00083% 1.49E-06 6.54E-04 6.54E-06 2.50 0.0260 0.114 0.114 15.0 1.56E-03 0.684 6.84E-03 2.00 2.08E-02 0.0913 0.0913 5.90E-04 3.24E-03 2.58E-03

1.92E-04 8.41E-04 8.41E-04

3.93E-03 3.93E-05 0.684 0.684 4.11 4.11E-02 0.548 0.548 0.019 0.015

Nickel VOC HAPsNoxSO2


Smelting Furnaces EU ID

Furnace Capacity (tpy) (3)

PM Control Effciency (%)

PM10/PM2.5

Control Effciency

(%)

Hood Capture

Efficiency

SOx Emission

Factor (lb/ton

charge) (1)

Unrestricted SOx

Emissions (lb/hr)

Unrestricted SOx

Emissions (tpy)

Permit Allowable

SOx Emissions

(tpy)

VOC Emission

Factor (lb/ton

charge) (1)

Unrestricted VOC

Emissions (lb/hr)

Unrestricted VOC Emissions

(tpy)

Permit Allowable

VOC Emissions

(tpy)Med. Melt. Furn. #1 EQUI9 0.005 0% 0% 0% 0.50 2.50E-03 1.10E-02 1.10E-02 6.70 0.034 0.147 0.147

Tilt Furn. #1 EQUI10 0.050 99% 93% 80% 0.50 2.50E-02 0.110 0.110 6.70 0.335 1.47 1.47Med. Tilt Furn. #1 EQUI12 0.029 99% 93% 80% 0.50 1.46E-02 6.39E-02 6.39E-02 6.70 0.195 0.856 0.856

TOTALS 0.08 4.21E-02 0.184 0.184 20.1 0.564 2.47 2.47

Smelting Furnaces EU ID

Emission Lead composition

(2)

Unrestricted Lead

Emissions (lb/hr)

Unrestrict

ed Lead Emissions

(tpy)

Permit Allowable

Lead Emissions

(lb/hr)

Permit Allowable

Lead Emissions

(tpy)

Emission Cadmium % composition

(2)

Unrestricted Cadmium Emissions

(lb/hr)

Unrestricted

Cadmium Emissions

(tpy)

Permit Allowable Cadmium Emissions

(lb/hr)

Permit Allowable Cadmium Emissions

(tpy)Med. Melt. Furn. #1 EQUI9 0.00071% 7.46E-07 3.27E-06 7.46E-07 3.27E-06 0.029% 3.05E-05 1.33E-04 3.05E-05 1.33E-04

Tilt Furn. #1 EQUI10 0.00071% 7.46E-06 3.27E-05 1.55E-06 6.79E-06 0.029% 3.05E-04 1.33E-03 6.33E-05 2.77E-04Med. Tilt Furn. #1 EQUI12 0.00071% 4.35E-06 1.90E-05 9.05E-07 3.96E-06 0.029% 1.78E-04 7.78E-04 3.69E-05 1.62E-04

TOTALS 1.25E-05 5.50E-05 3.20E-06 1.40E-05 5.13E-04 2.25E-03 1.31E-04 5.73E-04

Notes: 1. AIRS emission factor for Secondary Copper Production - Crucible & Pot Furnace, Charge w/brass and bronze was used to calculate potential emissions from the smelting furnaces.2. The baghouse dust was analyzed for TCLP metal contents. The results indicated 0.00071% Lead, 0.029% Cadmium, 0.000012% Mercury, 0.00083% Nickel, and 0.0000074% Selenium.3. Furnace capacities are based upon the following: EQUI9 Capacity =30 lb. Minimum Melt Cycle = 3 hrs. EQUI10 Capacity = 300 lb. Minimum Melt Time = 3 hrs. EQUI12 Capacity = 175 lb. Minimum Melt Time = 3 hrs.

4. EQUI 10 and EQUI 12 vent to baghouse and are subject to PM emission limit set at STRU 1 (see Incinerator emissions tab)

5. Controlled PM calculated to demonstrate compliance with Minn. R. 7011.0550 Table II: New Indirect Heating Equipment


Smelting Furnaces EU IDMed. Melt. Furn. #1 EQUI9

Tilt Furn. #1 EQUI10Med. Tilt Furn. #1 EQUI12

TOTALS

Smelting Furnaces EU IDMed. Melt. Furn. #1 EQUI9

Tilt Furn. #1 EQUI10Med. Tilt Furn. #1 EQUI12

TOTALS

PM Emission Factor (lb/ton

charge) (1)

Unrestricted PM

Emissions (lb/hr)

Unrestricted PM

Emissions (tpy)

Controlled PM

Emsissions (lb/hr) (5)

Permit Allowable PM

Emissions (lb/hr) (4)

Permit Allowable PM

Emissions (tpy) (4)

PM10/PM2.5 Emission

Factor (lb/ton

charge) (1)

Unrestricted PM10 / PM2.5

Emissions (lb/hr)

Unrestricted PM10/PM2.5

Emissions (tpy)

Permit Allowable PM10 / PM2.5

Emissions (lb/hr)

Permit Allowable

PM10/PM2.5 Emissions

(tpy)21 0.105 0.460 0.105 0.105 0.460 12.4 0.062 0.272 6.20E-02 0.27221 1.05 4.60 0.218 0.000 0.000 12.4 0.620 2.72 0.159 0.69521 0.613 2.68 0.127 0.000 0.000 12.4 0.362 1.58 9.26E-02 0.406

1.77 7.74 0.105 0.46 1.04 4.57 0.313 1.37

Emission Mercury

composition (2)

Unrestricted Mercury

Emissions (lb/hr)

Unrestricted

Mercury Emissions

(tpy)

Permit Allowable Mercury

Emissions (lb/hr)

Permit Allowable Mercury

Emissions (tpy)

Emission Selenium

composition (2)

Unrestricted

Selenium Emissions

(lb/hr)

Unrestricted Selenium Emissions

(tpy)

Permit Allowable Selenium Emissions

(lb/hr)

Permit Allowable Selenium Emissions

(tpy)

Emission Nickel

composition (2)

Unrestricted Nickel

Emissions (lb/hr)

Unrestricted Nickel

Emissions (tpy)

Permit Allowable

Nickel Emissions

(lb/hr)

Permit Allowable

Nickel Emissions

(tpy)0.000012% 1.26E-08 5.52E-08 1.26E-08 5.52E-08 0.0000074% 7.77E-09 3.40E-08 7.77E-09 3.40E-08 0.00083% 8.72E-07 3.82E-06 8.72E-07 3.82E-060.000012% 1.26E-07 5.52E-07 2.62E-08 1.15E-07 0.0000074% 7.77E-08 3.40E-07 1.62E-08 7.08E-08 0.00083% 8.72E-06 3.82E-05 1.81E-06 7.94E-060.000012% 7.35E-08 3.22E-07 1.53E-08 6.70E-08 0.0000074% 4.53E-08 1.99E-07 9.43E-09 4.13E-08 0.00083% 5.08E-06 2.23E-05 1.06E-06 4.63E-06

2.12E-07 9.29E-07 5.41E-08 2.37E-07 1.31E-07 5.73E-07 3.34E-08 1.46E-07 1.47E-05 6.43E-05 3.74E-06 1.64E-05


Combustion PTE 1,020 * Btu high heat value based on EPA value (U.S. average, AP-42, Volume 1, Chapter 1.4.1)EU ID# Unit Description MMBtu/hr

lb/hr tpy lb/hr tpy lb/hr tpy lb/hr tpy lb/hr tpy lb/hr tpyEQUI21 Assay WC 2.000 1.49E-02 6.53E-02 1.96E-01 8.59E-01 1.08E-02 4.72E-02 1.18E-03 5.15E-03 1.65E-01 7.21E-01 9.80E-07 4.29E-06EQUI17 Film Negative WC 1 3.200 2.38E-02 1.04E-01 3.14E-01 1.37E+00 1.73E-02 7.56E-02 1.88E-03 8.24E-03 2.64E-01 1.15E+00 1.57E-06 6.87E-06EQUI18 Film Negative WC 2 0.800 5.96E-03 2.61E-02 7.84E-02 3.44E-01 4.31E-03 1.89E-02 4.71E-04 2.06E-03 6.59E-02 2.89E-01 3.92E-07 1.72E-06EQUI19 Film Negative WC 3 0.800 5.96E-03 2.61E-02 7.84E-02 3.44E-01 4.31E-03 1.89E-02 4.71E-04 2.06E-03 6.59E-02 2.89E-01 3.92E-07 1.72E-06EQUI20 Film Negative WC 4 0.800 5.96E-03 2.61E-02 7.84E-02 3.44E-01 4.31E-03 1.89E-02 4.71E-04 2.06E-03 6.59E-02 2.89E-01 3.92E-07 1.72E-06EQUI22 Film Negative WC 5 0.800 5.96E-03 2.61E-02 7.84E-02 3.44E-01 4.31E-03 1.89E-02 4.71E-04 2.06E-03 6.59E-02 2.89E-01 3.92E-07 1.72E-06EQUI9 Med. Melt. Furn. #1 0.500 3.73E-03 1.63E-02 4.90E-02 2.15E-01 2.70E-03 1.18E-02 2.94E-04 1.29E-03 4.12E-02 1.80E-01 2.45E-07 1.07E-06

EQUI10 Tilt Furn. #1 1.200 8.94E-03 3.92E-02 1.18E-01 5.15E-01 6.47E-03 2.83E-02 7.06E-04 3.09E-03 9.88E-02 4.33E-01 5.88E-07 2.58E-06EQUI12 Med. Tilt Furn. #1 0.800 5.96E-03 2.61E-02 7.84E-02 3.44E-01 4.31E-03 1.89E-02 4.71E-04 2.06E-03 6.59E-02 2.89E-01 3.92E-07 1.72E-06

3.56E-01 4.68E+00 2.57E-01 2.81E-02 3.93E+00 2.34E-05

IA Lennox Warehouse Heater 0.150 1.12E-03 4.90E-03 1.47E-02 6.44E-02 8.09E-04 3.54E-03 8.82E-05 3.86E-04 1.24E-02 5.41E-02 7.35E-08 3.22E-07IA Schwank Tube Heater 1 0.130 9.69E-04 4.24E-03 1.27E-02 5.58E-02 7.01E-04 3.07E-03 7.65E-05 3.35E-04 1.07E-02 4.69E-02 6.37E-08 2.79E-07IA Schwank Tube Heater 2 0.130 9.69E-04 4.24E-03 1.27E-02 5.58E-02 7.01E-04 3.07E-03 7.65E-05 3.35E-04 1.07E-02 4.69E-02 6.37E-08 2.79E-07IA Schwank Tube Heater 3 0.130 9.69E-04 4.24E-03 1.27E-02 5.58E-02 7.01E-04 3.07E-03 7.65E-05 3.35E-04 1.07E-02 4.69E-02 6.37E-08 2.79E-07IA Schwank Tube Heater 4 0.130 9.69E-04 4.24E-03 1.27E-02 5.58E-02 7.01E-04 3.07E-03 7.65E-05 3.35E-04 1.07E-02 4.69E-02 6.37E-08 2.79E-07IA Bryant Office Furnace 0.080 5.96E-04 2.61E-03 7.84E-03 3.44E-02 4.31E-04 1.89E-03 4.71E-05 2.06E-04 6.59E-03 2.89E-02 3.92E-08 1.72E-07IA Titan Make Up Air Unit 1.012 7.54E-03 3.30E-02 9.92E-02 4.35E-01 5.46E-03 2.39E-02 5.95E-04 2.61E-03 8.33E-02 3.65E-01 4.96E-07 2.17E-06IA Rheem Water Heater 0.060 4.47E-04 1.96E-03 5.88E-03 2.58E-02 3.24E-04 1.42E-03 3.53E-05 1.55E-04 4.94E-03 2.16E-02 2.94E-08 1.29E-07

5.95E-02 7.82E-01 4.30E-02 4.69E-03 6.57E-01 3.91E-064.15E-01 5.46E+00 3.00E-01 3.28E-02 4.59E+00 2.73E-05

Notes 1. Emission Factors for PTE can be found in the "Emission Fatcors for Combustion" tab

Insignificant Activity Demonstration

EU ID# Unit Description MMBtu/hr PM/PM10/PM2.5 NOx VOC SO2 CO CO2elb/yr lb/yr lb/yr lb/yr lb/yr tpy

Insignificant Activity Threshold 2000 2000 2000 2000 4000 1000

IA Lennox Warehouse Heater 0.150 42.9 129 7.09 0.773 108 77.5IA Schwank Tube Heater 1 0.130 37.2 112 6.14 0.670 94 67.1IA Schwank Tube Heater 2 0.130 37.2 112 6.14 0.670 94 67.1IA Schwank Tube Heater 3 0.130 37.2 112 6.14 0.670 94 67.1IA Schwank Tube Heater 4 0.130 37.2 112 6.14 0.670 94 67.1IA Bryant Office Furnace 0.080 22.9 69 3.78 0.412 58 41.3IA Titan Make Up Air Unit 1.012 289.3 869 47.80 5.215 730 522.6IA Rheem Water Heater 0.060 17.2 52 2.83 0.309 43 31.0

Emission Unit Totals

PM/PM10/PM2.5 NOx VOC Lead

Insignificant Activity TotalsAll Combustion Units

COSO2


Combustion PTE 1,020 EU ID# Unit Description MMBtu/hr

EQUI21 Assay WC 2.000EQUI17 Film Negative WC 1 3.200EQUI18 Film Negative WC 2 0.800EQUI19 Film Negative WC 3 0.800EQUI20 Film Negative WC 4 0.800EQUI22 Film Negative WC 5 0.800EQUI9 Med. Melt. Furn. #1 0.500

EQUI10 Tilt Furn. #1 1.200EQUI12 Med. Tilt Furn. #1 0.800

IA Lennox Warehouse Heater 0.150IA Schwank Tube Heater 1 0.130IA Schwank Tube Heater 2 0.130IA Schwank Tube Heater 3 0.130IA Schwank Tube Heater 4 0.130IA Bryant Office Furnace 0.080IA Titan Make Up Air Unit 1.012IA Rheem Water Heater 0.060



lb/hr tpy lb/hr tpy lb/hr tpy lb/hr tpy lb/hr tpy lb/hr tpy lb/hr tpy lb/hr tpy2.35E+02 1.03E+03 1.25E-03 5.50E-03 4.51E-03 1.98E-02 2.36E+02 1.03E+03 3.92E-07 1.72E-06 2.35E-08 1.03E-07 2.16E-06 9.45E-06 2.75E-06 1.20E-053.76E+02 1.65E+03 2.01E-03 8.79E-03 7.22E-03 3.16E-02 3.77E+02 1.65E+03 6.27E-07 2.75E-06 3.76E-08 1.65E-07 3.45E-06 1.51E-05 4.39E-06 1.92E-059.41E+01 4.12E+02 5.02E-04 2.20E-03 1.80E-03 7.90E-03 9.43E+01 4.13E+02 1.57E-07 6.87E-07 9.41E-09 4.12E-08 8.63E-07 3.78E-06 1.10E-06 4.81E-069.41E+01 4.12E+02 5.02E-04 2.20E-03 1.80E-03 7.90E-03 9.43E+01 4.13E+02 1.57E-07 6.87E-07 9.41E-09 4.12E-08 8.63E-07 3.78E-06 1.10E-06 4.81E-069.41E+01 4.12E+02 5.02E-04 2.20E-03 1.80E-03 7.90E-03 9.43E+01 4.13E+02 1.57E-07 6.87E-07 9.41E-09 4.12E-08 8.63E-07 3.78E-06 1.10E-06 4.81E-069.41E+01 4.12E+02 5.02E-04 2.20E-03 1.80E-03 7.90E-03 9.43E+01 4.13E+02 1.57E-07 6.87E-07 9.41E-09 4.12E-08 8.63E-07 3.78E-06 1.10E-06 4.81E-065.88E+01 2.58E+02 3.14E-04 1.37E-03 1.13E-03 4.94E-03 5.89E+01 2.58E+02 9.80E-08 4.29E-07 5.88E-09 2.58E-08 5.39E-07 2.36E-06 6.86E-07 3.01E-061.41E+02 6.18E+02 7.53E-04 3.30E-03 2.71E-03 1.19E-02 1.41E+02 6.20E+02 2.35E-07 1.03E-06 1.41E-08 6.18E-08 1.29E-06 5.67E-06 1.65E-06 7.21E-069.41E+01 4.12E+02 5.02E-04 2.20E-03 1.80E-03 7.90E-03 9.43E+01 4.13E+02 1.57E-07 6.87E-07 9.41E-09 4.12E-08 8.63E-07 3.78E-06 1.10E-06 4.81E-06

5.62E+03 3.00E-02 1.08E-01 5.63E+03 9.36E-06 5.62E-07 5.15E-05 6.55E-05

1.76E+01 7.73E+01 9.41E-05 4.12E-04 3.38E-04 1.48E-03 1.77E+01 7.75E+01 2.94E-08 1.29E-07 1.76E-09 7.73E-09 1.62E-07 7.09E-07 2.06E-07 9.02E-071.53E+01 6.70E+01 8.16E-05 3.57E-04 2.93E-04 1.28E-03 1.53E+01 6.71E+01 2.55E-08 1.12E-07 1.53E-09 6.70E-09 1.40E-07 6.14E-07 1.78E-07 7.82E-071.53E+01 6.70E+01 8.16E-05 3.57E-04 2.93E-04 1.28E-03 1.53E+01 6.71E+01 2.55E-08 1.12E-07 1.53E-09 6.70E-09 1.40E-07 6.14E-07 1.78E-07 7.82E-071.53E+01 6.70E+01 8.16E-05 3.57E-04 2.93E-04 1.28E-03 1.53E+01 6.71E+01 2.55E-08 1.12E-07 1.53E-09 6.70E-09 1.40E-07 6.14E-07 1.78E-07 7.82E-071.53E+01 6.70E+01 8.16E-05 3.57E-04 2.93E-04 1.28E-03 1.53E+01 6.71E+01 2.55E-08 1.12E-07 1.53E-09 6.70E-09 1.40E-07 6.14E-07 1.78E-07 7.82E-079.41E+00 4.12E+01 5.02E-05 2.20E-04 1.80E-04 7.90E-04 9.43E+00 4.13E+01 1.57E-08 6.87E-08 9.41E-10 4.12E-09 8.63E-08 3.78E-07 1.10E-07 4.81E-071.19E+02 5.21E+02 6.35E-04 2.78E-03 2.28E-03 9.99E-03 1.19E+02 5.23E+02 1.98E-07 8.69E-07 1.19E-08 5.21E-08 1.09E-06 4.78E-06 1.39E-06 6.08E-067.06E+00 3.09E+01 3.76E-05 1.65E-04 1.35E-04 5.93E-04 7.07E+00 3.10E+01 1.18E-08 5.15E-08 7.06E-10 3.09E-09 6.47E-08 2.83E-07 8.24E-08 3.61E-07

9.39E+02 5.01E-03 1.80E-02 940.81 1.56E-06 9.39E-08 8.61E-06 1.10E-056.56E+03 3.50E-02 0.13 6,569.13 1.09E-05 6.56E-07 6.01E-05 7.65E-05

CO2eCH4N2OCO2 Arsenic Beryllium Cadmium Cobalt








lb/hr tpy lb/hr tpy lb/hr tpy lb/hr tpy lb/hr tpy lb/hr tpy lb/hr tpy lb/hr tpy1.65E-07 7.21E-07 7.45E-07 3.26E-06 5.10E-07 2.23E-06 4.12E-06 1.80E-05 4.71E-08 2.06E-07 3.70E-03 1.62E-02 4.71E-08 2.06E-07 3.53E-09 1.55E-082.64E-07 1.15E-06 1.19E-06 5.22E-06 8.16E-07 3.57E-06 6.59E-06 2.89E-05 7.53E-08 3.30E-07 5.92E-03 2.59E-02 7.53E-08 3.30E-07 5.65E-09 2.47E-086.59E-08 2.89E-07 2.98E-07 1.31E-06 2.04E-07 8.93E-07 1.65E-06 7.21E-06 1.88E-08 8.24E-08 1.48E-03 6.49E-03 1.88E-08 8.24E-08 1.41E-09 6.18E-096.59E-08 2.89E-07 2.98E-07 1.31E-06 2.04E-07 8.93E-07 1.65E-06 7.21E-06 1.88E-08 8.24E-08 1.48E-03 6.49E-03 1.88E-08 8.24E-08 1.41E-09 6.18E-096.59E-08 2.89E-07 2.98E-07 1.31E-06 2.04E-07 8.93E-07 1.65E-06 7.21E-06 1.88E-08 8.24E-08 1.48E-03 6.49E-03 1.88E-08 8.24E-08 1.41E-09 6.18E-096.59E-08 2.89E-07 2.98E-07 1.31E-06 2.04E-07 8.93E-07 1.65E-06 7.21E-06 1.88E-08 8.24E-08 1.48E-03 6.49E-03 1.88E-08 8.24E-08 1.41E-09 6.18E-094.12E-08 1.80E-07 1.86E-07 8.16E-07 1.27E-07 5.58E-07 1.03E-06 4.51E-06 1.18E-08 5.15E-08 9.25E-04 4.05E-03 1.18E-08 5.15E-08 8.82E-10 3.86E-099.88E-08 4.33E-07 4.47E-07 1.96E-06 3.06E-07 1.34E-06 2.47E-06 1.08E-05 2.82E-08 1.24E-07 2.22E-03 9.73E-03 2.82E-08 1.24E-07 2.12E-09 9.28E-096.59E-08 2.89E-07 2.98E-07 1.31E-06 2.04E-07 8.93E-07 1.65E-06 7.21E-06 1.88E-08 8.24E-08 1.48E-03 6.49E-03 1.88E-08 8.24E-08 1.41E-09 6.18E-09

3.93E-06 1.78E-05 1.22E-05 9.83E-05 1.12E-06 8.84E-02 1.12E-06 8.43E-08

1.24E-08 5.41E-08 5.59E-08 2.45E-07 3.82E-08 1.67E-07 3.09E-07 1.35E-06 3.53E-09 1.55E-08 2.78E-04 6.49E-03 3.53E-09 1.55E-08 2.65E-10 1.16E-091.07E-08 4.69E-08 4.84E-08 2.12E-07 3.31E-08 1.45E-07 2.68E-07 1.17E-06 3.06E-09 1.34E-08 2.41E-04 0.00E+00 3.06E-09 1.34E-08 2.29E-10 1.00E-091.07E-08 4.69E-08 4.84E-08 2.12E-07 3.31E-08 1.45E-07 2.68E-07 1.17E-06 3.06E-09 1.34E-08 2.41E-04 0.00E+00 3.06E-09 1.34E-08 2.29E-10 1.00E-091.07E-08 4.69E-08 4.84E-08 2.12E-07 3.31E-08 1.45E-07 2.68E-07 1.17E-06 3.06E-09 1.34E-08 2.41E-04 1.22E-03 3.06E-09 1.34E-08 2.29E-10 1.00E-091.07E-08 4.69E-08 4.84E-08 2.12E-07 3.31E-08 1.45E-07 2.68E-07 1.17E-06 3.06E-09 1.34E-08 2.41E-04 1.05E-03 3.06E-09 1.34E-08 2.29E-10 1.00E-096.59E-09 2.89E-08 2.98E-08 1.31E-07 2.04E-08 8.93E-08 1.65E-07 7.21E-07 1.88E-09 8.24E-09 1.48E-04 1.05E-03 1.88E-09 8.24E-09 1.41E-10 6.18E-108.33E-08 3.65E-07 3.77E-07 1.65E-06 2.58E-07 1.13E-06 2.08E-06 9.13E-06 2.38E-08 1.04E-07 1.87E-03 1.05E-03 2.38E-08 1.04E-07 1.79E-09 7.82E-094.94E-09 2.16E-08 2.24E-08 9.79E-08 1.53E-08 6.70E-08 1.24E-07 5.41E-07 1.41E-09 6.18E-09 1.11E-04 1.05E-03 1.41E-09 6.18E-09 1.06E-10 4.64E-10

6.57E-07 2.97E-06 2.03E-06 1.64E-05 1.88E-07 1.19E-02 1.88E-07 1.41E-084.59E-06 2.08E-05 1.42E-05 1.15E-04 1.31E-06 1.00E-01 1.31E-06 9.83E-08

Combined HAPs 2-Methylnphthalene 3-MethylcholanthreneNickel SeleniumChromium MercuryManganese








lb/hr tpy lb/hr tpy lb/hr tpy lb/hr tpy lb/hr tpy lb/hr tpy lb/hr tpy lb/hr tpy3.14E-08 1.37E-07 3.53E-09 1.55E-08 3.53E-09 1.55E-08 4.71E-09 2.06E-08 3.53E-09 1.55E-08 4.12E-06 1.80E-05 2.35E-09 1.03E-08 3.53E-09 1.55E-085.02E-08 2.20E-07 5.65E-09 2.47E-08 5.65E-09 2.47E-08 7.53E-09 3.30E-08 5.65E-09 2.47E-08 6.59E-06 2.89E-05 3.76E-09 1.65E-08 5.65E-09 2.47E-081.25E-08 5.50E-08 1.41E-09 6.18E-09 1.41E-09 6.18E-09 1.88E-09 8.24E-09 1.41E-09 6.18E-09 1.65E-06 7.21E-06 9.41E-10 4.12E-09 1.41E-09 6.18E-091.25E-08 5.50E-08 1.41E-09 6.18E-09 1.41E-09 6.18E-09 1.88E-09 8.24E-09 1.41E-09 6.18E-09 1.65E-06 7.21E-06 9.41E-10 4.12E-09 1.41E-09 6.18E-091.25E-08 5.50E-08 1.41E-09 6.18E-09 1.41E-09 6.18E-09 1.88E-09 8.24E-09 1.41E-09 6.18E-09 1.65E-06 7.21E-06 9.41E-10 4.12E-09 1.41E-09 6.18E-091.25E-08 5.50E-08 1.41E-09 6.18E-09 1.41E-09 6.18E-09 1.88E-09 8.24E-09 1.41E-09 6.18E-09 1.65E-06 7.21E-06 9.41E-10 4.12E-09 1.41E-09 6.18E-097.84E-09 3.44E-08 8.82E-10 3.86E-09 8.82E-10 3.86E-09 1.18E-09 5.15E-09 8.82E-10 3.86E-09 1.03E-06 4.51E-06 5.88E-10 2.58E-09 8.82E-10 3.86E-091.88E-08 8.24E-08 2.12E-09 9.28E-09 2.12E-09 9.28E-09 2.82E-09 1.24E-08 2.12E-09 9.28E-09 2.47E-06 1.08E-05 1.41E-09 6.18E-09 2.12E-09 9.28E-091.25E-08 5.50E-08 1.41E-09 6.18E-09 1.41E-09 6.18E-09 1.88E-09 8.24E-09 1.41E-09 6.18E-09 1.65E-06 7.21E-06 9.41E-10 4.12E-09 1.41E-09 6.18E-09

7.49E-07 8.43E-08 8.43E-08 1.12E-07 8.43E-08 9.83E-05 5.62E-08 8.43E-08

2.35E-09 1.03E-08 2.65E-10 1.16E-09 2.65E-10 1.16E-09 3.53E-10 1.55E-09 2.65E-10 1.16E-09 3.09E-07 1.35E-06 1.76E-10 7.73E-10 2.65E-10 1.16E-092.04E-09 8.93E-09 2.29E-10 1.00E-09 2.29E-10 1.00E-09 3.06E-10 1.34E-09 2.29E-10 1.00E-09 2.68E-07 1.17E-06 1.53E-10 6.70E-10 2.29E-10 1.00E-092.04E-09 8.93E-09 2.29E-10 1.00E-09 2.29E-10 1.00E-09 3.06E-10 1.34E-09 2.29E-10 1.00E-09 2.68E-07 1.17E-06 1.53E-10 6.70E-10 2.29E-10 1.00E-092.04E-09 8.93E-09 2.29E-10 1.00E-09 2.29E-10 1.00E-09 3.06E-10 1.34E-09 2.29E-10 1.00E-09 2.68E-07 1.17E-06 1.53E-10 6.70E-10 2.29E-10 1.00E-092.04E-09 8.93E-09 2.29E-10 1.00E-09 2.29E-10 1.00E-09 3.06E-10 1.34E-09 2.29E-10 1.00E-09 2.68E-07 1.17E-06 1.53E-10 6.70E-10 2.29E-10 1.00E-091.25E-09 5.50E-09 1.41E-10 6.18E-10 1.41E-10 6.18E-10 1.88E-10 8.24E-10 1.41E-10 6.18E-10 1.65E-07 7.21E-07 9.41E-11 4.12E-10 1.41E-10 6.18E-101.59E-08 6.95E-08 1.79E-09 7.82E-09 1.79E-09 7.82E-09 2.38E-09 1.04E-08 1.79E-09 7.82E-09 2.08E-06 9.13E-06 1.19E-09 5.21E-09 1.79E-09 7.82E-099.41E-10 4.12E-09 1.06E-10 4.64E-10 1.06E-10 4.64E-10 1.41E-10 6.18E-10 1.06E-10 4.64E-10 1.24E-07 5.41E-07 7.06E-11 3.09E-10 1.06E-10 4.64E-10

1.25E-07 1.41E-08 1.41E-08 1.88E-08 1.41E-08 1.64E-05 9.39E-09 1.41E-088.74E-07 9.83E-08 9.83E-08 1.31E-07 9.83E-08 1.15E-04 6.56E-08 9.83E-08

Anthracene Benz(a)anthracene Benzene Benzo(a)pyrene Benzo(b)fluoranthen7,12-Dimethylbenz(a)anthracene Acenaphthene Acenapthylene








lb/hr tpy lb/hr tpy lb/hr tpy lb/hr tpy lb/hr tpy lb/hr tpy lb/hr tpy lb/hr tpy lb/hr tpy2.35E-09 1.03E-08 3.53E-09 1.55E-08 3.53E-09 1.55E-08 2.35E-09 1.03E-08 2.35E-06 1.03E-05 5.88E-09 2.58E-08 5.49E-09 2.40E-08 1.47E-04 6.44E-04 3.53E-03 1.55E-023.76E-09 1.65E-08 5.65E-09 2.47E-08 5.65E-09 2.47E-08 3.76E-09 1.65E-08 3.76E-06 1.65E-05 9.41E-09 4.12E-08 8.78E-09 3.85E-08 2.35E-04 1.03E-03 5.65E-03 2.47E-029.41E-10 4.12E-09 1.41E-09 6.18E-09 1.41E-09 6.18E-09 9.41E-10 4.12E-09 9.41E-07 4.12E-06 2.35E-09 1.03E-08 2.20E-09 9.62E-09 5.88E-05 2.58E-04 1.41E-03 6.18E-039.41E-10 4.12E-09 1.41E-09 6.18E-09 1.41E-09 6.18E-09 9.41E-10 4.12E-09 9.41E-07 4.12E-06 2.35E-09 1.03E-08 2.20E-09 9.62E-09 5.88E-05 2.58E-04 1.41E-03 6.18E-039.41E-10 4.12E-09 1.41E-09 6.18E-09 1.41E-09 6.18E-09 9.41E-10 4.12E-09 9.41E-07 4.12E-06 2.35E-09 1.03E-08 2.20E-09 9.62E-09 5.88E-05 2.58E-04 1.41E-03 6.18E-039.41E-10 4.12E-09 1.41E-09 6.18E-09 1.41E-09 6.18E-09 9.41E-10 4.12E-09 9.41E-07 4.12E-06 2.35E-09 1.03E-08 2.20E-09 9.62E-09 5.88E-05 2.58E-04 1.41E-03 6.18E-035.88E-10 2.58E-09 8.82E-10 3.86E-09 8.82E-10 3.86E-09 5.88E-10 2.58E-09 5.88E-07 2.58E-06 1.47E-09 6.44E-09 1.37E-09 6.01E-09 3.68E-05 1.61E-04 8.82E-04 3.86E-031.41E-09 6.18E-09 2.12E-09 9.28E-09 2.12E-09 9.28E-09 1.41E-09 6.18E-09 1.41E-06 6.18E-06 3.53E-09 1.55E-08 3.29E-09 1.44E-08 8.82E-05 3.86E-04 2.12E-03 9.28E-039.41E-10 4.12E-09 1.41E-09 6.18E-09 1.41E-09 6.18E-09 9.41E-10 4.12E-09 9.41E-07 4.12E-06 2.35E-09 1.03E-08 2.20E-09 9.62E-09 5.88E-05 2.58E-04 1.41E-03 6.18E-03

5.62E-08 8.43E-08 8.43E-08 5.62E-08 5.62E-05 1.40E-07 1.31E-07 3.51E-03 8.43E-02

1.76E-10 7.73E-10 2.65E-10 1.16E-09 2.65E-10 1.16E-09 1.76E-10 7.73E-10 1.76E-07 7.73E-07 4.41E-10 1.93E-09 4.12E-10 1.80E-09 1.10E-05 4.83E-05 2.65E-04 1.16E-031.53E-10 6.70E-10 2.29E-10 1.00E-09 2.29E-10 1.00E-09 1.53E-10 6.70E-10 1.53E-07 6.70E-07 3.82E-10 1.67E-09 3.57E-10 1.56E-09 9.56E-06 4.19E-05 2.29E-04 1.00E-031.53E-10 6.70E-10 2.29E-10 1.00E-09 2.29E-10 1.00E-09 1.53E-10 6.70E-10 1.53E-07 6.70E-07 3.82E-10 1.67E-09 3.57E-10 1.56E-09 9.56E-06 4.19E-05 2.29E-04 1.00E-031.53E-10 6.70E-10 2.29E-10 1.00E-09 2.29E-10 1.00E-09 1.53E-10 6.70E-10 1.53E-07 6.70E-07 3.82E-10 1.67E-09 3.57E-10 1.56E-09 9.56E-06 4.19E-05 2.29E-04 1.00E-031.53E-10 6.70E-10 2.29E-10 1.00E-09 2.29E-10 1.00E-09 1.53E-10 6.70E-10 1.53E-07 6.70E-07 3.82E-10 1.67E-09 3.57E-10 1.56E-09 9.56E-06 4.19E-05 2.29E-04 1.00E-039.41E-11 4.12E-10 1.41E-10 6.18E-10 1.41E-10 6.18E-10 9.41E-11 4.12E-10 9.41E-08 4.12E-07 2.35E-10 1.03E-09 2.20E-10 9.62E-10 5.88E-06 2.58E-05 1.41E-04 6.18E-041.19E-09 5.21E-09 1.79E-09 7.82E-09 1.79E-09 7.82E-09 1.19E-09 5.21E-09 1.19E-06 5.21E-06 2.98E-09 1.30E-08 2.78E-09 1.22E-08 7.44E-05 3.26E-04 1.79E-03 7.82E-037.06E-11 3.09E-10 1.06E-10 4.64E-10 1.06E-10 4.64E-10 7.06E-11 3.09E-10 7.06E-08 3.09E-07 1.76E-10 7.73E-10 1.65E-10 7.21E-10 4.41E-06 1.93E-05 1.06E-04 4.64E-04

9.39E-09 1.41E-08 1.41E-08 9.39E-09 9.39E-06 2.35E-08 2.19E-08 5.87E-04 1.41E-026.56E-08 9.83E-08 9.83E-08 6.56E-08 6.56E-05 1.64E-07 1.53E-07 4.10E-03 9.83E-02

Formaldehyde HexaneBenzo(k)fluoranthen Chrysene Dibenzo(a,h)anthrac Dichlorobenzene Fluoranthene FluoreneBenzo(g,h,i)perylene








lb/hr tpy lb/hr tpy lb/hr tpy lb/hr tpy lb/hr tpy lb/hr tpy3.53E-09 1.55E-08 1.20E-06 5.24E-06 3.33E-08 1.46E-07 9.80E-09 4.29E-08 6.67E-06 2.92E-05 1.63E-07 7.15E-075.65E-09 2.47E-08 1.91E-06 8.38E-06 5.33E-08 2.34E-07 1.57E-08 6.87E-08 1.07E-05 4.67E-05 2.61E-07 1.14E-061.41E-09 6.18E-09 4.78E-07 2.10E-06 1.33E-08 5.84E-08 3.92E-09 1.72E-08 2.67E-06 1.17E-05 6.53E-08 2.86E-071.41E-09 6.18E-09 4.78E-07 2.10E-06 1.33E-08 5.84E-08 3.92E-09 1.72E-08 2.67E-06 1.17E-05 6.53E-08 2.86E-071.41E-09 6.18E-09 4.78E-07 2.10E-06 1.33E-08 5.84E-08 3.92E-09 1.72E-08 2.67E-06 1.17E-05 6.53E-08 2.86E-071.41E-09 6.18E-09 4.78E-07 2.10E-06 1.33E-08 5.84E-08 3.92E-09 1.72E-08 2.67E-06 1.17E-05 6.53E-08 2.86E-078.82E-10 3.86E-09 2.99E-07 1.31E-06 8.33E-09 3.65E-08 2.45E-09 1.07E-08 1.67E-06 7.30E-06 4.08E-08 1.79E-072.12E-09 9.28E-09 7.18E-07 3.14E-06 2.00E-08 8.76E-08 5.88E-09 2.58E-08 4.00E-06 1.75E-05 9.79E-08 4.29E-071.41E-09 6.18E-09 4.78E-07 2.10E-06 1.33E-08 5.84E-08 3.92E-09 1.72E-08 2.67E-06 1.17E-05 6.53E-08 2.86E-07

8.43E-08 2.86E-05 7.96E-07 2.34E-07 1.59E-04 3.89E-06

2.65E-10 1.16E-09 8.97E-08 3.93E-07 2.50E-09 1.10E-08 7.35E-10 3.22E-09 5.00E-07 2.19E-06 1.22E-08 5.36E-082.29E-10 1.00E-09 7.77E-08 3.41E-07 2.17E-09 9.49E-09 6.37E-10 2.79E-09 4.33E-07 1.90E-06 1.06E-08 4.64E-082.29E-10 1.00E-09 7.77E-08 3.41E-07 2.17E-09 9.49E-09 6.37E-10 2.79E-09 4.33E-07 1.90E-06 1.06E-08 4.64E-082.29E-10 1.00E-09 7.77E-08 3.41E-07 2.17E-09 9.49E-09 6.37E-10 2.79E-09 4.33E-07 1.90E-06 1.06E-08 4.64E-082.29E-10 1.00E-09 7.77E-08 3.41E-07 2.17E-09 9.49E-09 6.37E-10 2.79E-09 4.33E-07 1.90E-06 1.06E-08 4.64E-081.41E-10 6.18E-10 4.78E-08 2.10E-07 1.33E-09 5.84E-09 3.92E-10 1.72E-09 2.67E-07 1.17E-06 6.53E-09 2.86E-081.79E-09 7.82E-09 6.05E-07 2.65E-06 1.69E-08 7.39E-08 4.96E-09 2.17E-08 3.37E-06 1.48E-05 8.25E-08 3.62E-071.06E-10 4.64E-10 3.59E-08 1.57E-07 1.00E-09 4.38E-09 2.94E-10 1.29E-09 2.00E-07 8.76E-07 4.89E-09 2.14E-08

1.41E-08 4.77E-06 1.33E-07 3.91E-08 2.66E-05 6.51E-079.83E-08 3.33E-05 9.29E-07 2.73E-07 1.86E-04 4.55E-06

Toluene POMsIndeno(1,2,3-cd)pyrene Naphthalene Phenanathrene Pyrene

Combustion Emission Factors

(lb/MMSCF) (lb/MMSCF) (lb/MMSCF)PM 7.6 2-Methylnphthalene 0.000024 Naphthalene 0.00061

PM10 7.6 3-Methylcholanthrene 0.0000018 Phenanathrene 0.000017PM2.5 7.6 7,12-Dimethylbenz(a)anthracene 0.000016 Pyrene 0.000005NOx 100 Acenaphthene 0.0000018 Toluene 0.0034SO2 0.6 Acenapthylene 0.0000018CO 84 Anthracene 0.0000024

VOC 5.5 Benz(a)anthracene 0.0000018Lead 0.0005 Benzene 0.0021CO2 120000 Benzo(a)pyrene 0.0000012N2O 0.64 Benzo(b)fluoranthene 0.0000018

Arsenic 0.0002 Benzo(g,h,i)perylene 0.0000012Beryllium 0.000012 Benzo(k)fluoranthene 0.0000018Cadmium 0.0011 Chrysene 0.0000018Chromium 0.0014 Dibenzo(a,h)anthracene 0.0000012

Cobalt 0.000084 Dichlorobenzene 0.0012Manganese 0.00038 Fluoranthene 0.000003

Mercury 0.00026 Fluorene 0.0000028Nickel 0.0021 Formaldehyde 0.075

Selenium 0.000024 Hexane 1.8CH4 2.3 Indeno(1,2,3-cd)pyrene 0.0000018

Emission Factors Emission Factors Emission Factors

Natural Gas emission factors obtained from EPA AP-42, Volume I, Chapter 1.4, Table 1.4-1 small boilers (NOx & CO), Table 1.4-2 (PM, SO2, Lead, VOC, Methane,

N20, & CO2), table 1.4-3 (Organic HAPs), and table 1.4-4 (Metal HAPs).

Natural Gas (<100 MMBtu/hr) Natural Gas (<100 MMBtu/hr) Natural Gas (<100 MMBtu/hr)

Potential Emissions - Hammermill - Silver Oxide Button Battery Grinding (Hammermill)

Maximum Capacity (3) (lb/hr)

PM Emission Factor (1) (lb/ton)

Uncontrolled PM Emissions (lb/hr)

Uncontrolled PM Emissions (tpy)

PM10/PM2.5 Emission

Factor (lb/ton)

Uncontrolled PM10/PM2.5

Emissions (lb/hr)


Emissions (tpy)

Maximum Manganese

Oxide Content (2) (%)

Uncontrolled Manganese

Oxide Emissions

(lb/hr)


Oxide Emissions (tpy)

600 0.04 1.17E-02 5.12E-02 1.50E-02 4.50E-03 1.97E-02 40% 1.80E-03 7.88E-03

Potential Emissions - Hammermill - Silver Oxide Button Battery Screening

Maximum Capacity (3) (lb/hr)

PM Emission Factor (1) (lb/ton)

Uncontrolled PM Emissions (lb/hr)

Uncontrolled PM Emissions (tpy)

PM10/PM2.5 Emission

Factor (lb/ton)


Emissions (lb/hr)


Emissions (tpy)

Maximum Manganese

Oxide Content (2) (%)


Oxide Emissions

(lb/hr)


Oxide Emissions (tpy)

600 0.025 7.50E-03 3.29E-02 8.70E-03 2.61E-03 1.14E-02 40% 3.00E-03 1.31E-02

Silver Oxide Battery Potential Emissions Summary

PM Emissions (lb/hr) PM Emissions (tpy)PM Emissions

(lb/yr) (4)PM10 / PM2.5

Emissions (lb/hr)

PM10 / PM2.5 Emissions (lb/yr) (4)

PM10 / PM2.5 Emissions (tpy)

Manganese Oxide Emissions

(lb/hr)

Manganese Oxide

Emissions (tpy)1.92E-02 8.41E-02 168 7.11E-03 62.3 3.11E-02 4.80E-03 2.10E-02

Insignificant Activity DemonstrationEmissions (lb/yr) Threshold (lb/yr) Qualify (4) (Y/N)

PM 168 2000 YesPM10 62.3 2000 Yes

Notes:1. Emission factors could not be found specifically for hammermill grinding and screening. Therefore, it is assumed that these activities are similar to Crushed Stone Fines Crushing and Screening, and emission factors from AP-42 Table 11.19.2-2 are being used.2. The silver oxide button cell batteries can contain up to 40% maganese oxide.3. Maximum capacity is 10/lb/min. Enviro-Chem states that they operate the equipment at approximately 3 lb/min4. This activity qualifies as an insignificant activity under Minn. R. 7007.1300 Subpart 3(F).

Attachment 2:

SI Details Report and Requirements Summary

SI ID Sequence Requirement

TFAC 1 1240

Permit Appendices: This permit contains appendices as listed in the permit Table of Contents. The Permittee shall comply with all requirements contained in Appendix A: Insignificant Activities and Applicable Requirements, Appendix B: Industrial Solid Waste Management Plan, Appendix C: Ash Management Plan, and Appendix D: Mercury Waste Separation Plan. [Minn. R. 7007.0800, subp. 2]

TFAC 1 1260

PERMIT SHIELD: Subject to the limitations in Minn. R. 7007.1800, compliance with the conditions of this permit shall be deemed compliance with the specific provision of the applicable requirement identified in the permit as the basis of each condition. Subject to the limitations of Minn. R. 7007.1800 and 7017.0100, subp. 2, notwithstanding the conditions of this permit specifying compliance practices for applicable requirements, any person (including the Permittee) may also use other credible evidence to establish compliance or noncompliance with applicable requirements. This permit shall not alter or affect the liability of the Permittee for any violation of applicable requirements prior to or at the time of permit issuance. [Minn. R. 7007.1800(A)(2)]

TFAC 1 1380

Circumvention: Do not install or use a device or means that conceals or dilutes emissions, which would otherwise violate a federal or state air pollution control rule, without reducing the total amount of pollutant emitted. [Minn. R. 7011.0020]

TFAC 1 1390Air Pollution Control Equipment: Operate all pollution control equipment whenever the corresponding process equipment and emission units are operated. [Minn. R. 7007.0800, subp. 16(J), Minn. R. 7007.0800, subp. 2]

TFAC 1 1400

Operation and Maintenance Plan: Retain at the stationary source an operation and maintenance plan for all air pollution control equipment. At a minimum, the O & M plan shall identify all air pollution control equipment and control practices and shall include a preventative maintenance program for the equipment and practices, a description of (the minimum but not necessarily the only) corrective actions to be taken to restore the equipment and practices to proper operation to meet applicable permit conditions, a description of the employee training program for proper operation and maintenance of the control equipment and practices, and the records kept to demonstrate plan implementation. [Minn. R. 7007.0800, subp. 14, Minn. R. 7007.0800, subp. 16(J)]

TFAC 1 1410

Operation Changes: In any shutdown, breakdown, or deviation the Permittee shall immediately take all practical steps to modify operations to reduce the emission of any regulated air pollutant. The Commissioner may require feasible and practical modifications in the operation to reduce emissions of air pollutants. No emissions units that have an unreasonable shutdown or breakdown frequency of process or control equipment shall be permitted to operate. [Minn. R. 7019.1000, subp. 4]

TFAC 1 1420

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

TFAC 1 1430

Noise: The Permittee shall comply with the noise standards set forth in Minn. R. 7030.0010 to 7030.0080 at all times during the operation of any emission units. This is a state only requirement and is not enforceable by the EPA Administrator or citizens under the Clean Air Act. [Minn. R. 7030.0010-7030.0080]

TFAC 1 1440Inspections: The Permittee shall comply with the inspection procedures and requirements as found in Minn. R. 7007.0800, subp. 9(A). [Minn. R. 7007.0800, subp. 9(A)]

TFAC 1 1450The Permittee shall comply with the General Conditions listed in Minn. R. 7007.0800, subp. 16. [Minn. R. 7007.0800, subp. 16]

TFAC 1 1460Performance Testing: Conduct all performance tests in accordance with Minn. R. ch. 7017 unless otherwise noted in this permit. [Minn. R. ch. 7017]

TFAC 1 1470

Performance Test Notifications and Submittals:

Performance Test Notification and Plan: due 30 days before each Performance TestPerformance Test Pre-test Meeting: due 7 days before each Performance TestPerformance Test Report: due 45 days after each Performance Test

The Notification, Test Plan, and Test Report must be submitted in a format specified by the commissioner. [Minn. R. 7017.2017, Minn. R. 7017.2030, subps. 1-4, Minn. R. 7017.2035, subps. 1-2]


TFAC 1 1480

Limits set as a result of a performance test (conducted before or after permit issuance) apply until superseded as stated in the MPCA's Notice of Compliance letter granting preliminary approval. Preliminary approval is based on formal review of a subsequent performance test on the same unit as specified by Minn. R. 7017.2025, subp. 3. The limit is final upon issuance of a permit amendment incorporating the change. [Minn. R. 7017.2025, subp. 3]

TFAC 1 1490

Monitoring Equipment Calibration - The Permittee shall either:

1. Calibrate or replace required monitoring equipment every 12 months; or2. Calibrate at the frequency stated in the manufacturer's specifications.

For each monitor, the Permittee shall maintain a record of all calibrations, including the date conducted, and any corrective action that resulted. The Permittee shall include the calibration frequencies, procedures, and manufacturer's specifications (if applicable) in the Operations and Maintenance Plan. [Minn. R. 7007.0800, subp. 4(D)]

TFAC 1 1500

Operation of Monitoring Equipment: Unless noted elsewhere in this permit, monitoring a process or control equipment connected to that process is not necessary during periods when the process is shutdown, or during checks of the monitoring systems, such as calibration checks and zero and span adjustments. If monitoring records are required, they should reflect any such periods of process shutdown or checks of the monitoring system. [Minn. R. 7007.0800, subp. 4(D)]

TFAC 1 1510

Recordkeeping: Retain all records at the stationary source, unless otherwise specified within this permit, for a period of five (5) years from the date of monitoring, sample, measurement, or report. Records which must be retained at this location include all calibration and maintenance records, all original recordings for continuous monitoring instrumentation, and copies of all reports required by the permit. Records must conform to the requirements listed in Minn. R. 7007.0800, subp. 5(A). [Minn. R. 7007.0800, subp. 5(C)]

TFAC 1 1520

Recordkeeping: Maintain records describing any insignificant modifications (as required by Minn. R. 7007.1250, subp. 3) or changes contravening permit terms (as required by Minn. R. 7007.1350, subp. 2), including records of the emissions resulting from those changes. [Minn. R. 7007.0800, subp. 5(B)]

TFAC 1 1530

If the Permittee determines that no permit amendment or notification is required prior to making a change, the Permittee must retain records of all calculations required under Minn. R. 7007.1200. For expiring permits, these records shall be kept for a period of five years from the date the change was made or until permit reissuance, whichever is longer. The records shall be kept at the stationary source for the current calendar year of operation and may be kept at the stationary source or office of the stationary source for all other years. The records may be maintained in either electronic or paper format. [Minn. R. 7007.1200, subp. 4]

TFAC 1 1610

Shutdown Notifications: Notify the Commissioner at least 24 hours in advance of a planned shutdown of any control equipment or process equipment if the shutdown would cause any increase in the emissions of any regulated air pollutant. If the owner or operator does not have advance knowledge of the shutdown, notification shall be made to the Commissioner as soon as possible after the shutdown. However, notification is not required in the circumstances outlined in items A, B, and C of Minn. R. 7019.1000, subp. 3. At the time of notification, the owner or operator shall inform the Commissioner of the cause of the shutdown and the estimated duration. The owner or operator shall notify the Commissioner when the shutdown is over. [Minn. R. 7019.1000, subp. 3]

TFAC 1 1620

Breakdown Notifications: Notify the Commissioner within 24 hours of a breakdown of more than one hour duration of any control equipment or process equipment if the breakdown causes any increase in the emissions of any regulated air pollutant. The 24-hour time period starts when the breakdown was discovered or reasonably should have been discovered by the owner or operator. However, notification is not required in the circumstances outlined in items A, B, and C of Minn. R. 7019.1000, subp. 2. At the time of notification or as soon as possible thereafter, the owner or operator shall inform the Commissioner of the cause of the breakdown and the estimated duration. The owner or operator shall notify the Commissioner when the breakdown is over. [Minn. R. 7019.1000, subp. 2]


TFAC 1 1630

Notification of Deviations Endangering Human Health or the Environment: As soon as possible after discovery, notify the Commissioner or the state duty officer, either orally or by facsimile, of any deviation from permit conditions which could endanger human health or the environment. [Minn. R. 7019.1000, subp. 1]

TFAC 1 1640

Notification of Deviations Endangering Human Health or the Environment Report: Within 2 working days of discovery, notify the Commissioner in writing of any deviation from permit conditions which could endanger human health or the environment. Include the following information in this written description:1. the cause of the deviation; 2. the exact dates of the period of the deviation, if the deviation has been corrected;3. whether or not the deviation has been corrected; 4. the anticipated time by which the deviation is expected to be corrected, if not yet corrected; and 5. steps taken or planned to reduce, eliminate, and prevent reoccurrence of the deviation. [Minn. R. 7019.1000, subp. 1]

TFAC 1 1650

The Permittee shall submit a semiannual deviations report : Due semiannually, by the 30th of January and July. The first semiannual report submitted by the Permittee shall cover the calendar half-year in which the permit is issued. The first report of each calendar year covers January 1 - June 30. The second report of each calendar year covers July 1 - December 31. Submit this on form DRF-2 (Deviation Reporting Form). If no deviations have occurred, submit the signed report certifying that there were no deviations. [Minn. R. 7007.0800, subp. 6(A)(2)]

TFAC 1 1670

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

Upon adoption of a new or amended federal applicable requirement, and if there are 3 or more years remaining in the permit term, the Permittee shall file an application for an amendment within nine months of promulgation of the applicable requirement, pursuant to Minn. R. 7007.0400, subp. 3. [Minn. R. 7007.0400, subp. 3, Minn. R. 7007.1150 - 7007.1500]

TFAC 1 1680

Extension Requests: The Permittee may apply for an Administrative Amendment to extend a deadline in a permit by no more than 120 days, provided the proposed deadline extension meets the requirements of Minn. R. 7007.1400, subp. 1(H). Performance testing deadlines from the General Provisions of 40 CFR pt. 60 and pt. 63 are examples of deadlines for which the MPCA does not have authority to grant extensions and therefore do not meet the requirements of Minn. R. 7007.1400, subp. 1(H). [Minn. R. 7007.1400, subp. 1(H)]

TFAC 1 1690

The Permittee shall submit a compliance schedule progress report : Due semiannually, by the 30th of January and July The Compliance Schedule Progress Report shall contain the information specified in Minn. R. 7007.0800, subp. 6(B) and shall be submitted on a form approved by the Commissioner in accordance with the Compliance Schedule contained in this permit. Progress Reports will not be needed upon completion of all activities contained in the Compliance Schedule. [Minn. R. 7007.0800, subp. 6(B)]

TFAC 1 1700

The Permittee shall submit a compliance certification : Due annually, by the 31st of January (for the previous calendar year). Submit this on form CR-04 (Annual Compliance Certification Report). This report covers all deviations experienced during the calendar year. If no deviations have occurred, submit the signed report certifying that there were no deviations. [Minn. R. 7007.0800, subp. 6(C)]

TFAC 1 1730Emission Inventory Report: due on or before April 1 of each calendar year following permit issuance. Submit in a format specified by the Commissioner. [Minn. R. 7019.3000-7019.3100]

TFAC 1 1740 Emission Fees: due 30 days after receipt of an MPCA bill. [Minn. R. 7002.0005-7002.0085]

COMG 1 1Particulate Matter <= 0.035 grains per dry standard cubic foot corrected to 7% oxygen on a dry volume basis. [Minn. R. 7011.1225, subp. 5]

COMG 1 3 Opacity <= 20 percent opacity. [Minn. R. 7011.1225, subp. 5]

COMG 1 4Carbon Monoxide <= 50 parts per million corrected to 7% oxygen on a dry volume basis. [Minn. R. 7011.1225, subp. 5]


COMG 1 7

Use of Auxiliary Fuel: Auxiliary fuel shall be used to maintain the operating temperatures required below from the time the solid waste feed has been discontinued until the combustion chamber is clear of combustible material or active combustion ceases to exist in the combustion chamber. [Minn. R. 7011.1235, subp. 2a]

COMG 1 8Start-up on Waste Prohibited: During start-up from a cold furnace, auxiliary fuels shall be used to achieve combustion chamber operating temperature. [Minn. R. 7011.1240, subp. 3]

COMG 1 9

Stack Exit Height shall be equal to or greater than (H + 0.5L), where H is the height of the building and L is the lesser of the building height or the maximum projected width of the building. The existing stack height of 38 feet meets this requirement. [Minn. R. 7011.1235, subp. 1]

COMG 1 10

Range of Operation: No owner or operator of a waste combustor shall operate the waste combustor while combusting solid waste at a level above 110% of the maximum demonstrated capacity of the combustion system, without conducting a performance test under Minn. R. 7011.1265, which demonstrates compliance with the emission limitations of Minn. R. 7011.1225 at greater than 110% of the maximum demonstrated capacity. [Minn. R. 7011.1240, subp. 5]

COMG 1 11

General Waste Combustor Facility Requirements: The owner or operator of a facility shall design, construct, and operate the facility in compliance with the solid waste management requirements as set forth in items listed below. Plans required in these items shall identify those required portions of the plan which are not applicable. - Security requirements in Minn. R. 7035.2535, subp. 3; - General inspection requirements in Minn. R. 7035.2535, subp. 4; - Emergency preparedness and prevention plans and emergency procedures prepared in accordance with Minn. R. 7035.2595 and 7035.2605; - Contingency action plans in Minn. R. 7035.2615; and - Closure plans in Minn. R. 7035.2625, closure procedures in Minn. R. 7035.2635. [Minn. R. 7011.1245]

COMG 1 12

Presence of Certified Operator: An operator supervisor shall be present at the waste combustor facility at all times when solid waste is being combusted. The operator supervisor shall hold a certificate as described in Minn. R. 7011.1280. [Minn. R. 7011.1240, subp. 1]

COMG 1 33

Ash Testing: due before end of each 60 months starting 1/19/2025; The Permittee shall conduct testing for ash in accordance with Minn. R. 7045.0131 for toxic characteristic leach procedure for arsenic, barium, cadmium, chromium, lead, mercury, selenium and nickel. The Permittee shall include the weight percent of arsenic, barium, cadmium, chromium, lead, mercury, selenium and nickel with the ash test results. [Minn. R. 7011.1270(D)]

COMG 1 38

Personnel Training: Waste combustor facility personnel described below shall complete a program of instruction and on-the-job training based on the operating manual described in Minn. R. 7011.1275, subp. 3. The training program shall require:- an initial review of the operating manual prior to assumption of any job-related activities affecting air emissions;- review of the operating manual relevant to a newly assigned position before assumption of new job-related activities affecting air emissions;- those without waste combustor or boiler operation experience, initially review the operating manual and work under the direct supervision of a certified operator or a certified operator's designee for 12 hours before assumption of job-related activities affecting air emissions; and- annual review of the operating manual. [Minn. R. 7011.1275]

COMG 1 39

Personnel Who Shall be Trained: The training program shall train waste combustor personnel who have responsibilities which affect the operation of the waste combustor, including, but not limited to, chief facility operators, shift supervisors, operator supervisors, control room personnel, ash handlers, maintenance personnel, and crane/load handlers. [Minn. R. 7011.1275, subp. 2]


COMG 1 40

Operator Certification: The operator supervisor shall be certified through the process established in Minn. R. 7011.1280. The certified operator shall:

(1) hold a high school diploma or equivalent, or demonstrate five years of experience in incinerator operation, general industry, industry process, or power plant operation; (2) complete at least 16 hours of training approved by the commissioner which are designed to ensure competency to operate a Class IV waste combustor; (3) complete the certification process described in Minn. R. 7011.1280, subp. 4; and(4) pass the examination required in Minn. R. 7011.1280, subp. 5.

Certificates are valid for three years. [Minn. R. 7011.1280]

COMG 1 41

Operator Certification Renewal: A certified operator shall apply for certificate renewal 30 days prior to certificate expiration. The application renewal shall include evidence that the person has, during the preceding three years, earned credit for attending training courses offered by the MPCA or other training courses approved by the commissioner, including personnel training described in Minn. R. 7011.1275, for at least 8 hours. [Minn. R. 7011.1280, subp. 7]

COMG 1 43

Industrial Waste Management Plan: The owner or operator shall prepare a plan for the management of industrial solid waste in accordance with Minn. R. 7035.2535, subp. 5, items A and B. The plan shall also include the contents listed in Minn. R. 7035.2535, subp. 2. The owner shall modify the plan whenever the management practices or solid waste identified in the plan have changed. The owner or operator shall submit the amended plan to the commissioner for approval. This Plan has been submitted and is in Appendix B of this permit. [Minn. R. 7011.1250, subp. 1, Minn. R. 7011.1250, subp. 3]

COMG 1 44

Mercury Waste Separation Plan: the permit application for a waste combustor shall contain a plan to separate solid wastes which contain mercury in accordance with Minn. R. 7011.1255. This Plan has been submitted and is included in Appendix D of this permit. [Minn. R. 7007.0501, subp. 5]

COMG 1 45

Plans and Specifications: due before May 23, 2022 and every 60 months thereafter. Mercury Waste Separation Plan shall be revised every five years. The Plan shall be updated to improve identification, separation, and collection before combustion of mercury from the solid waste stream. [Minn. R. 7007.0501, subp. 5, Minn. R. 7011.1255, subp. 1, Minn. R. 7011.1255, subp. 3]

COMG 1 46

Ash Management Plan: the permit application for a waste combustor shall contain a plan for disposal of the ash generated by the waste combustor, treatment of water generated from quenching the ash at the facility, and any plans which the applicant has for ash utilization. This Plan has been submitted and is included in Appendix C of this permit. [Minn. R. 7007.0501, subp. 7]

COMG 1 47

Operating Manual: The owner or operator of a waste combustor shall develop and update on a yearly basis a site specific operating manual that shall, at a minimum, address the following elements of waste combustor unit operation:- a summary of the applicable state rules and federal regulations to the activities described in this permit;- a description of basic combustion theory applicable to the facility's waste combustor unit;- procedures for receiving, handling, and feeding solid waste;- waste combustor unit start-up, shutdown, and malfunction procedures;- procedures for maintaining proper combustion air levels;- procedures for operating the waste combustor within the standards established in Minn. R. 7011.1201 to 1290;- procedures for responding to periodic upset or off-specification conditions;- procedures for minimizing particulate matter carryover;- procedures for monitoring the degree of solid waste burnout;- procedures for handling ash; - procedures for monitoring waste combustor emissions;- procedures for reporting and recordkeeping;- timetables and procedures for routine inspection and maintenance of equipment affecting air emissions;- procedures for activating communications and alarm systems; and- procedures to implement the facility's industrial waste management plan. The operating manual shall be kept in a location easily accessed by the waste combustor personnel. [Minn. R. 7011.1275, subp. 3]


COMG 1 50

Operating Records: The owner or operator of a waste combustor shall maintain records and submit reports as required in Minn. R. 7011.1285. The owner or operator is also subject to the recordkeeping and reporting requirements in Minn. R. 7007.0800, subps. 5 and 6. Records shall be retained for a minimum of five years. [Minn. R. 7011.1285, subp. 1]

COMG 1 51

Daily Operating Record: The owner or operator shall maintain a daily record of the operation of the waste combustor. The record shall contain:-the calendar date;-the hours of operation;-the weight of solid waste combusted;-the weight of solid waste requiring disposal at a solid waste land disposal facility, including separated non-combustibles, excess solid waste, and ash;-the amount and description of industrial solid waste received each day, the generator's name, and the method of handling;-the measurements and determination of emissions averages as required in Minn. R. 7011.1260, subp. 6;-the results of performance tests conducted as required in Minn. R. 7011.1270;-the names of persons who have completed initial review of subsequent annual review of the operating manual;-reasons for exceeding any of the operating parameters specified under Minn. R. 7011.1260, subp. 6(C) and a description of corrective actions taken;and-reasons for not obtaining the minimum number of hours of operational data for the temperature monitoring equipment and a description of corrective actions taken. [Minn. R. 7011.1285, subp. 2]

COMG 1 52

Exceedances of Emission Limits: if accurate and valid data results of a performance test demonstrate an exceedance of the Particulate Matter or Carbon Monoxide emission limit or the opacity limit, the owner or operator shall undertake the actions below: -The owner or operator shall immediately report the exceedance to the commissioner and shall comply with the applicable reporting provisions of Minn. R. 7011.0800, sub.6; -The owner or operator shall undertake appropriate steps to return the waste combustor to compliance, and shall demonstrate compliance within 60 days of the initial report of the exceedance; - If the commissioner determines that compliance has not been achieved within 60 days of the initial report of exceedance, the waste combustor shall be shut down; and -If the shutdown was required as described above, the waste combustor may be restarted under the conditions specified by the commissioner. The owner or operator shall notify the commissioner in writing of the date on which the owner or operator plans to start-up and begin compliance testing. Notification shall be at least 10 days in advance of the compliance test date. [Minn. R. 7011.1265, subp. 11]

COMG 1 53

The Permittee shall submit an Annual Report: due April 30th of each year. The owner or operator shall submit the following information to the commissioner in the annual report:- the daily operating records in Minn. R. 7011.1285, subp. 2 summarized to reflect annual totals;- a summary report of any excess emissions that occurred during the year; and- a compliance certification as required in Minn. R. 7007.0800, subp. (6), item (C). [Minn. R. 7011.1285, subp. 4]


COMG 1 20040

Particulate Matter: The Permittee shall conduct a performance test due before 1/19/2025 and every 60 months thereafter to measure emissions. The first test is due by the date specified above and all subsequent tests shall be completed every 60 months thereafter by the due date (month and day) and as described below. The performance test shall be conducted at worst-case conditions, with EQUI 10, EQUI 12, EQUI 17, EQUI 18, EQUI 19, EQUI 20, EQUI 21, and EQUI 22 operating simultaneously, defined at Minn. R. 7017.2005, subp. 8 or at the operating conditions described at Minn. R. 7017.2025, subp. 2, using EPA Reference Methods 5 and 202, or other method approved by MPCA in the performance test plan approval. Testing conducted during the 60 days prior to the performance test due date will not reset the test due date for future testing as required by this permit or within a Notice of Compliance letter. Testing conducted more than 60 days prior to the performance test due date satisfies this test due date requirement but will reset future performance test due dates based on the performance test date. [Minn. R. 7011.1265, subp. 5, Minn. R. 7011.1270, D, Minn. R. 7017.2020, subp. 1, To avoid major source under 40 CFR 70.2 & Minn. R. 7007.0200]

COMG 1 20041

Cadmium: The Permittee shall conduct a performance test due before 1/19/2025 and every 60 months thereafter to measure emissions as required by Minn. R. 7011.1265, subp. 5. The first test is due by the date specified above and all subsequent tests shall be completed every 60 months thereafter by the due date (month and day) and as described below. The performance test shall be conducted at worst-case conditions, with EQUI 10, EQUI 12, EQUI 17, EQUI 18, EQUI 19, EQUI 20, EQUI 21, and EQUI 22 operating simultaneously, defined at Minn. R. 7017.2005, subp. 8 or at the operating conditions described at Minn. R. 7017.2025, subp. 2, using EPA Reference Method 29, or other method approved by MPCA in the performance test plan approval. Testing conducted during the 60 days prior to the performance test due date will not reset the test due date for future testing as required by this permit or within a Notice of Compliance letter. Testing conducted more than 60 days prior to the performance test due date satisfies this test due date requirement but will reset future performance test due dates based on the performance test date. [Minn. R. 7011.1265, subp. 5, Minn. R. 7011.1270, D, Minn. R. 7017.2020, subp. 1]

COMG 1 20042

Lead: The Permittee shall conduct a performance test due before 1/19/2025 and every 60 months thereafter to measure emissions as required by Minn. R. 7011.1265, subp. 5. The first test is due by the date specified above and all subsequent tests shall be completed every 60 months thereafter by the due date (month and day) and as described below. The performance test shall be conducted at worst-case conditions, with EQUI 10, EQUI 12, EQUI 17, EQUI 18, EQUI 19, EQUI 20, EQUI 21, and EQUI 22 operating simultaneously, defined at Minn. R. 7017.2005, subp. 8 or at the operating conditions described at Minn. R. 7017.2025, subp. 2, using EPA Reference Method 29, or other method approved by MPCA in the performance test plan approval. Testing conducted during the 60 days prior to the performance test due date will not reset the test due date for future testing as required by this permit or within a Notice of Compliance letter. Testing conducted more than 60 days prior to the performance test due date satisfies this test due date requirement but will reset future performance test due dates based on the performance test date. [Minn. R. 7011.1265, subp. 5, Minn. R. 7011.1270, D, Minn. R. 7017.2020, subp. 1]


COMG 1 20044

Mercury: The Permittee shall conduct a performance test due before 1/19/2025 and every 60 months thereafter to measure emissions as required by Minn. R. 7011.1265, subp. 5. The first test is due by the date specified above and all subsequent tests shall be completed every 60 months thereafter by the due date (month and day) and as described below. The performance test shall be conducted at worst-case conditions, with EQUI 10, EQUI 12, EQUI 17, EQUI 18, EQUI 19, EQUI 20, EQUI 21, and EQUI 22 operating simultaneously, defined at Minn. R. 7017.2005, subp. 8 or at the operating conditions described at Minn. R. 7017.2025, subp. 2, using EPA Reference Method 29, or other method approved by MPCA in the performance test plan approval. Testing conducted during the 60 days prior to the performance test due date will not reset the test due date for future testing as required by this permit or within a Notice of Compliance letter. Testing conducted more than 60 days prior to the performance test due date satisfies this test due date requirement but will reset future performance test due dates based on the performance test date. [Minn. R. 7011.1265, subp. 5, Minn. R. 7011.1270, D, Minn. R. 7017.2020, subp. 1]

COMG 1 20045

Opacity: The Permittee shall conduct a performance test due before1/19/2025 and every 60 months thereafter to measure opacity. The first test is due by the date specified above and all subsequent tests shall be completed every 60 months thereafter by the due date (month and date) and as described below. The performance test shall be conducted at worst-case conditions with EQUI 10, EQUI 12, EQUI 17, EQUI 18, EQUI 19, EQUI 20, EQUI 21, and EQUI 22 operating simultaneously, defined at Minn. R. 7017.2005, subp. 8 or at the operating conditions described at Minn. R. 7017.2025, subp. 2, using EPA Reference Methods 9, or other method approved by MPCA in the performance test plan approval. Testing conducted during the 60 days prior to the performance test due date will not reset the test due date for future testing as required by this permit or within a Notice of Compliance letter. Testing conducted more than 60 days prior to the performance test due date satisfies this test due date requirement but will reset future performance test due dates based on the performance test date. [Minn. R. 7011.1265, subp. 5, Minn. R. 7011.1270, D, Minn. R. 7017.2020, subp. 1]

COMG 1 20050

Carbon Monoxide: The Permittee shall conduct a performance test due before 1/19/2025 and every 60 months thereafter to measure emissions. The first test is due by the date specified above and all subsequent tests shall be completed every 60 months thereafter by the due date (month and day) and as described below. The performance test shall be conducted at worst-case conditions with EQUI 10, EQUI 12, EQUI 17, EQUI 18, EQUI 19, EQUI 20, EQUI 21, and EQUI 22 operating simultaneously, defined at Minn. R. 7017.2005, subp. 8 or at the operating conditions described at Minn. R. 7017.2025, subp. 2, using EPA Reference Methods 10, or other method approved by MPCA in the performance test plan approval. Testing conducted during the 60 days prior to the performance test due date will not reset the test due date for future testing as required by this permit or within a Notice of Compliance letter. Testing conducted more than 60 days prior to the performance test due date satisfies this test due date requirement but will reset future performance test due dates based on the performance test date. [Minn. R. 7011.1265, subp. 5, Minn. R. 7011.1270, D, Minn. R. 7017.2020, subp. 1]

EQUI 9 3570Particulate Matter <= 0.4 pounds per million Btu heat input. The potential to emit from the unit is 0.21 lb/MMBtu due to equipment design and allowable fuels. [Minn. R. 7011.0515, subp. 1]

EQUI 9 3580Opacity <= 20 percent opacity except for one six-minute period per hour of not more than 60 percent opacity. [Minn. R. 7011.0515, subp. 2]

EQUI 9 3632 Fuel type: Natural gas only, by design. [Minn. R. 7005.0100, subp. 35a]

EQUI 9 3637 The Permittee shall keep records of fuel purchases showing fuel types. [Minn. R. 7007.0800, subp. 5]






EQUI 10 3638The Permittee shall vent emissions from EQUI 10 to control equipment meeting the requirements of TREA 17 whenever EQUI 10 operates. [To avoid major source under 40 CFR 70.2 & Minn. R. 7007.0200]

EQUI 10 3639

Hood Certification and Evaluation: The Permittee shall maintain the most current record of the hood evaluation and certification on site. The control device hood must be evaluated by a testing company as specified in Minn. R. 7011.0072, subp. 2(A) and must conform to the design and operating requirements listed in Minn. R. 7011.0072, subps. 2(B) and 3. The hood certification must address how cross-drafts are accommodated in the design (e.g., higher face velocity, oversized hood, etc.) and the Permittee shall certify this as specified in Minn. R. 7011.0072, subps. 2 and 3. [Minn. R. 7007.0800, subp. 2, To avoid major source under 40 CFR 70.2 & Minn. R. 7007.0200]

EQUI 10 3640

Annual Hood Evaluation: The Permittee shall measure and record at least once every 12 months the fan rotation speed, fan power draw, or face velocity of each hood, or other comparable air flow parameter that was measured during the most recent hood certification to verify the hood design and operation parameters meet or exceed the parameters measured during the most recent hood evaluation conducted according to Minn. R. 7011.0072, subps. 2 & 3 as required by Minn. R. 7011.0072, subp. 4. The Permittee shall maintain a copy of the annual evaluations on site for 5 years. [Minn. R. 7007.0800, subp. 2, To avoid major source under 40 CFR 70.2 & Minn. R. 7007.0200]

EQUI 10 3641

The Permittee shall submit a report: Due 30 calendar days after permit issuance that certifies that the hood conforms to the requirements identified in the Hood Certification and Evaluation requirement in this permit. The Permittee shall submit the results of the evaluation and certification on form CR-02, along with any other information required by the forms for MPCA review. [Corrective Action, Minn. R. 7007.0800, subp. 2]





EQUI 12 3638The Permittee shall vent emissions from EQUI 12 to control equipment meeting the requirements of TREA 17 whenever EQUI 12 operates. [To avoid major source under 40 CFR 70.2 & Minn. R. 7007.0200]

EQUI 12 3639

Hood Certification and Evaluation: The Permittee shall maintain the most current record of the hood evaluation and certification on site. The control device hood must be evaluated by a testing company as specified in Minn. R. 7011.0072, subp. 2(A) and must conform to the design and operating requirements listed in Minn. R. 7011.0072, subps. 2(B) and 3. The hood certification must address how cross-drafts are accommodated in the design (e.g., higher face velocity, oversized hood, etc.) and the Permittee shall certify this as specified in Minn. R. 7011.0072, subps. 2 and 3. [Minn. R. 7007.0800, subp. 2, To avoid major source under 40 CFR 70.2 & Minn. R. 7007.0200]

EQUI 12 3640

Annual Hood Evaluation: The Permittee shall measure and record at least once every 12 months the fan rotation speed, fan power draw, or face velocity of each hood, or other comparable air flow parameter that was measured during the most recent hood certification to verify the hood design and operation parameters meet or exceed the parameters measured during the most recent hood evaluation conducted according to Minn. R. 7011.0072, subps. 2 & 3 as required by Minn. R. 7011.0072, subp. 4. The Permittee shall maintain a copy of the annual evaluations on site for 5 years. [Minn. R. 7007.0800, subp. 2, To avoid major source under 40 CFR 70.2 & Minn. R. 7007.0200]

EQUI 12 3641

The Permittee shall submit a report: Due 30 calendar days after permit issuance that certifies that the hood conforms to the requirements identified in the Hood Certification and Evaluation requirement in this permit. The Permittee shall submit the results of the evaluation and certification on form CR-02, along with any other information required by the forms for MPCA review. [Corrective Action, Minn. R. 7007.0800, subp. 2]


EQUI 17 19650

The Permittee shall vent emissions from EQUI 17 to control equipment meeting the requirements of TREA 6 and TREA 17 in series whenever EQUI 17 operates. [Minn. R. 7011.1235, subp. 2, To avoid major source under 40 CFR 70.2 & Minn. R. 7007.0200]

EQUI 18 19650


EQUI 19 19650


EQUI 20 19650


EQUI 21 19650


EQUI 22 19650


STRU 1 2 Particulate Matter <= 2.0 pounds per hour. [To avoid major source under 40 CFR 70.2 & Minn. R. 7007.0200]

TREA 6 1The Permittee shall operate and maintain control equipment such that it achieves an overall efficiency for Carbon Monoxide >= 95.0 percent control efficiency. [Minn. R. 7007.0800, subp. 2]

TREA 6 5The Permittee shall operate and maintain control equipment such that it achieves an overall control efficiency for, Volatile Organic Compounds >= 99.0 percent control efficiency. [Minn. R. 7007.0800, subp. 2]

TREA 6 6Combustion Chamber Temperature >= 1800 degrees Fahrenheit 4-hour block average. [Minn. R. 7007.0800, subp. 14, Minn. R. 7007.0800, subp. 2, Minn. R. 7011.1235, subp. 2]

TREA 6 14

Combustion Chamber: the final Combustion Chamber shall be designed and operated to maintain combustion gases at a minimum of 1800 degrees F for one second in a zone after the last overfire or secondary air has entered the combustion chamber. [Minn. R. 7011.1235, subp. 2]

TREA 6 18

The Permittee shall vent emissions from EQUI 17, EQUI 18, EQUI 19, EQUI 20, and EQUI 22 to TREA 6 whenever EQUI 17, EQUI 18, EQUI 19, EQUI 20, and EQUI 22 operates, and operate and maintain TREA 6 at all times that any emissions are vented to TREA 6. The Permittee shall document periods of non-operation of the control equipment TREA 6 whenever EQUI 17, EQUI 18, EQUI 19, EQUI 20, and EQUI 22 is operating. [Minn. R. 7007.0800, subp. 14, Minn. R. 7007.0800, subp. 2]

TREA 6 22

If the Permittee replaces TREA 6, the replacement control must meet or exceed the control efficiency requirements of TREA 6 as well as comply with all other requirements of TREA 6. Prior to making such a change, the Permittee shall apply for and obtain the appropriate permit amendment, as applicable. If no amendment is needed for the replacement, the Permittee shall submit an electronic notice to the Agency using Form CR-05. The notice must be received by the Agency seven working days prior to the commencement/start of replacement. [Minn. R. 7007.0800, subp. 2]

TREA 6 23

Combustion Chamber Temperature Monitor: The owner or operator shall install and operate at all times temperature monitors that continuously read and record the temperature at the point in the combustion unit one second downstream of the entrance of the last overfire or secondary air injection. The owner or operator may elect to place temperature monitors at another point downstream in accordance with Minn. R. 7011.1260, subp. 1.

The averaging period for combustion chamber temperatures shall be four-hour arithmetic block averages calculated from four one-hour arithmetic averages. Each one-hour arithmetic average shall consist of at least ten data points equally spaced in time. [Minn. R. 7011.1260, subp. 1]

TREA 6 17610

Installation and Operation of Continuous Monitors: The owner or operator shall comply with the requirements of Minn. R. 7017.1002 to Minn. R. 7017.1220, except as provided below:Continuous monitors shall be operated so as to measure and record data for at least 75% of the hours per day for 90% of the days of the calendar quarter that the waste combustor is operating and combusting solid waste. [Minn. R. 7011.1260, subp. 5]


TREA 6 17615

Recording Data from Continuous Monitoring: The owner or operator shall maintain a permanent record of the information listed below. Waste combustors shall maintain a record of continuously measured parameters. The record of monitoring shall contain: - the calendar date;- combustion chamber temperature and particulate matter control device temperatures recorded in a manner that allows the data to be immediately accessed upon inspection; and- four-hour block arithmetic average particulate matter control device inlet temperatures. [Minn. R. 7011.1260, subp. 6]

TREA 6 18740

Periodic Inspections: At least once per calendar year, or more frequently as required by the manufacturing specifications, the Permittee shall inspect the control equipment internal and external system components. The Permittee shall maintain a written record of the inspection and any corrective actions taken resulting from the inspection. [Minn. R. 7007.0800, subp. 14, Minn. R. 7007.0800, subps. 4-5]

TREA 6 18750

The Permittee shall operate and maintain the afterburner in accordance with the Operation and Maintenance (O & M) Plan. The Permittee shall keep copies of the O & M Plan available onsite for use by staff and MPCA staff. [Minn. R. 7007.0800, subp. 14]

TREA 6 18760

Temperature Monitoring: The Permittee shall maintain and operate a thermocouple monitoring device that continuously indicates and records the combustion chamber temperature of the afterburner. The monitoring device shall have a margin of error less than the greater of +/- 0.75 percent of the temperature being measured or +/- 4.5 degrees Fahrenheit. The recording device shall also calculate the four-hour rolling average combustion chamber temperature. Recorded values outside the range specified in this permit are considered Deviations as defined by Minn. R. 7007.0100, subp. 8a. [Minn. R. 7007.0800, subps. 4-5, Minn. R. 7011.1235, subp. 2]

TREA 6 18770

Daily Monitoring: The Permittee shall physically verify the operation of the temperature recording device at least once each operating day to verify that it is working and recording properly. The Permittee shall maintain a written record of the daily verifications. [Minn. R. 7007.0800, subps. 4-5]

TREA 6 18780

Monitoring Equipment: The Permittee shall install and maintain thermocouples to conduct temperature monitoring required by this permit. The monitoring equipment must be installed, in use, and properly maintained whenever operation of the monitored control equipment is required. [Minn. R. 7007.0800, subps. 4-5]

TREA 6 18790

The Permittee shall maintain a continuous hard copy readout or computer disk file of the temperature readings and calculated four hour rolling average temperatures for the combustion chamber. [Minn. R. 7007.0800, subps. 4-5]

TREA 6 18800

Annual Calibration: The Permittee shall calibrate the temperature monitor at least once every 12 months and shall maintain a written record of the calibration and any action resulting from the calibration. [Minn. R. 7007.0800, subp. 14, Minn. R. 7007.0800, subp. 4, Minn. R. 7007.0800, subp. 5]

TREA 6 18810

Quarterly Inspections: At least once per calendar quarter, the Permittee shall inspect the control equipment internal and external system components, including but not limited to the refractory, heat exchanger, and electrical systems. The Permittee shall maintain a written record of the inspection and any corrective actions taken resulting from the inspection. [Minn. R. 7007.0800, subp. 14, Minn. R. 7007.0800, subp. 4, Minn. R. 7007.0800, subp. 5]

TREA 6 18830

Annual Inspection: At least once per calendar year, the Permittee shall conduct an internal inspection of the control device that includes all operating systems of the control device. The Permittee shall maintain a written record of the inspection and any action resulting from the inspection. [Minn. R. 7007.0800, subp. 14, Minn. R. 7007.0800, subp. 4, Minn. R. 7007.0800, subp. 5]

TREA 6 18900

Corrective Actions: If the temperature is below the minimum specified by this permit or if the afterburner or any of its components are found during the inspections to need repair, the Permittee shall take corrective action as soon as possible. Corrective actions shall return the temperature to at least the permitted minimum and/or include completion of necessary repairs identified during the inspection, as applicable. Corrective actions include, but are not limited to, those outlined in the O & M Plan for the afterburner. The Permittee shall keep a record of the type and date of any corrective action taken. [Minn. R. 7007.0800, subp. 14, Minn. R. 7007.0800, subp. 2(A), Minn. R. 7007.0800, subp. 5]

TREA 8 1The Permittee shall operate and maintain control equipment such that it achieves an overall control efficiency for Carbon Monoxide >= 95.0 percent control efficiency. [Minn. R. 7007.0800, subp. 2]


TREA 8 5The Permittee shall operate and maintain control equipment such that it achieves an overall control efficiency for, Volatile Organic Compounds >= 99.0 percent control efficiency. [Minn. R. 7007.0800, subp. 2]

TREA 8 6Combustion Chamber Temperature >= 1800 degrees Fahrenheit 4-hour block average. [Minn. R. 7007.0800, subp. 14, Minn. R. 7007.0800, subp. 2, Minn. R. 7011.1235, subp. 2]

TREA 8 14

Combustion Chamber: the final Combustion Chamber shall be designed and operated to maintain combustion gases at a minimum of 1800 degrees F for one second in a zone after the last overfire or secondary air has entered the combustion chamber. [Minn. R. 7011.1235, subp. 2]

TREA 8 18

The Permittee shall vent emissions from EQUI 21 to TREA 8 whenever EQUI 21 operates, and operate and maintain EQUI 21 at all times that any emissions are vented to EQUI 21. The Permittee shall document periods of non-operation of the control equipment EQUI 21 whenever EQUI 21 is operating. [Minn. R. 7007.0800, subp. 14, Minn. R. 7007.0800, subp. 2]

TREA 8 22

If the Permittee replaces TREA 8, the replacement control must meet or exceed the control efficiency requirements of TREA 8 as well as comply with all other requirements of TREA 8. Prior to making such a change, the Permittee shall apply for and obtain the appropriate permit amendment, as applicable. If no amendment is needed for the replacement, the Permittee shall submit an electronic notice to the Agency using Form CR-05. The notice must be received by the Agency seven working days prior to the commencement/start of replacement. [Minn. R. 7007.0800, subp. 2]

TREA 8 23

Combustion Chamber Temperature Monitor: The owner or operator shall install and operate at all times temperature monitors that continuously read and record the temperature at the point in the combustion unit one second downstream of the entrance of the last overfire or secondary air injection. The owner or operator may elect to place temperature monitors at another point downstream in accordance with Minn. R. 7011.1260, subp. 1.

The averaging period for combustion chamber temperatures shall be four-hour arithmetic block averages calculated from four one-hour arithmetic averages. Each one-hour arithmetic average shall consist of at least ten data points equally spaced in time. [Minn. R. 7011.1260, subp. 1]

TREA 8 17610

Installation and Operation of Continuous Monitors: The owner or operator shall comply with the requirements of Minn. R. 7017.1002 to Minn. R. 7017.1220, except as provided below:Continuous monitors shall be operated so as to measure and record data for at least 75% of the hours per day for 90% of the days of the calendar quarter that the waste combustor is operating and combusting solid waste. [Minn. R. 7011.1260, subp. 5]

TREA 8 17615

Recording Data from Continuous Monitoring: The owner or operator shall maintain a permanent record of the information listed below. Waste combustors shall maintain a record of continuously measured parameters. The record of monitoring shall contain: - the calendar date;- combustion chamber temperature and particulate matter control device temperatures recorded in a manner that allows the data to be immediately accessed upon inspection; and- four-hour block arithmetic average particulate matter control device inlet temperatures. [Minn. R. 7011.1260, subp. 6]

TREA 8 18740

Periodic Inspections: At least once per calendar year, or more frequently as required by the manufacturing specifications, the Permittee shall inspect the control equipment internal and external system components. The Permittee shall maintain a written record of the inspection and any corrective actions taken resulting from the inspection. [Minn. R. 7007.0800, subp. 14, Minn. R. 7007.0800, subps. 4-5]

TREA 8 18750

The Permittee shall operate and maintain the afterburner in accordance with the Operation and Maintenance (O & M) Plan. The Permittee shall keep copies of the O & M Plan available onsite for use by staff and MPCA staff. [Minn. R. 7007.0800, subp. 14]

TREA 8 18760

Temperature Monitoring: The Permittee shall maintain and operate a thermocouple monitoring device that continuously indicates and records the combustion chamber temperature of the afterburner. The monitoring device shall have a margin of error less than the greater of +/- 0.75 percent of the temperature being measured or +/- 4.5 degrees Fahrenheit. The recording device shall also calculate the four-hour rolling average combustion chamber temperature. Recorded values outside the range specified in this permit are considered Deviations as defined by Minn. R. 7007.0100, subp. 8a. [Minn. R. 7007.0800, subps. 4-5, Minn. R. 7011.1235, subp. 2]


TREA 8 18770

Daily Monitoring: The Permittee shall physically verify the operation of the temperature recording device at least once each operating day to verify that it is working and recording properly. The Permittee shall maintain a written record of the daily verifications. [Minn. R. 7007.0800, subps. 4-5]

TREA 8 18780

Monitoring Equipment: The Permittee shall install and maintain thermocouples to conduct temperature monitoring required by this permit. The monitoring equipment must be installed, in use, and properly maintained whenever operation of the monitored control equipment is required. [Minn. R. 7007.0800, subps. 4-5]

TREA 8 18790

The Permittee shall maintain a continuous hard copy readout or computer disk file of the temperature readings and calculated four hour rolling average temperatures for the combustion chamber. [Minn. R. 7007.0800, subps. 4-5]

TREA 8 18800

Annual Calibration: The Permittee shall calibrate the temperature monitor at least once every 12 months and shall maintain a written record of the calibration and any action resulting from the calibration. [Minn. R. 7007.0800, subp. 14, Minn. R. 7007.0800, subp. 4, Minn. R. 7007.0800, subp. 5]

TREA 8 18810

Quarterly Inspections: At least once per calendar quarter, the Permittee shall inspect the control equipment internal and external system components, including but not limited to the refractory, heat exchanger, and electrical systems. The Permittee shall maintain a written record of the inspection and any corrective actions taken resulting from the inspection. [Minn. R. 7007.0800, subp. 14, Minn. R. 7007.0800, subp. 4, Minn. R. 7007.0800, subp. 5]

TREA 8 18830

Annual Inspection: At least once per calendar year, the Permittee shall conduct an internal inspection of the control device that includes all operating systems of the control device. The Permittee shall maintain a written record of the inspection and any action resulting from the inspection. [Minn. R. 7007.0800, subp. 14, Minn. R. 7007.0800, subp. 4, Minn. R. 7007.0800, subp. 5]

TREA 8 18900

Corrective Actions: If the temperature is below the minimum specified by this permit or if the afterburner or any of its components are found during the inspections to need repair, the Permittee shall take corrective action as soon as possible. Corrective actions shall return the temperature to at least the permitted minimum and/or include completion of necessary repairs identified during the inspection, as applicable. Corrective actions include, but are not limited to, those outlined in the O & M Plan for the afterburner. The Permittee shall keep a record of the type and date of any corrective action taken. [Minn. R. 7007.0800, subp. 14, Minn. R. 7007.0800, subp. 2(A), Minn. R. 7007.0800, subp. 5]

TREA 17 15

The Permittee shall operate and maintain control equipment such that it achieves a control efficiency for Particulate Matter >= 99.0 percent control efficiency. [To avoid major source under 40 CFR 70.2 & Minn. R. 7007.0200]

TREA 17 16The Permittee shall operate and maintain control equipment such that it achieves a control efficiency for PM < 10 micron >= 93.0 percent control efficiency. [Minn. R. 7007.0800, subp. 2(A)]

TREA 17 17610The Permittee shall operate and maintain control equipment such that it achieves a control efficiency for PM < 2.5 micron >= 93.0 percent control efficiency. [Minn. R. 7007.0800, subp. 2(A)]

TREA 17 17615

Pressure Drop >= 0.5 and <= 4.5 inches of water, unless a new range is set pursuant to Minn. R. 7017.2025, subp. 3 based on the values recorded during the most recent MPCA-approved performance test where compliance was demonstrated. The new range shall be implemented upon receipt of the Notice of Compliance letter granting preliminary approval. The range is final upon issuance of a permit amendment incorporating the change.

If the recorded pressure drop is outside the required range, the emissions during that time shall be considered uncontrolled until the pressure drop is once again within the required range. The period of time for which the pressure drop is considered out of range shall be reported as a deviation. The Permittee shall record the pressure drop at least once every 24 hours when in operation. [Minn. R. 7007.0800, subp. 2(A), To avoid major source under 40 CFR 70.2 & Minn. R. 7007.0200]

TREA 17 18480

The Permittee shall vent emissions from EQUI 10, EQUI 12, EQUI 17, EQUI 18, EQUI 19, EQUI 20, EQUI 21, and EQUI 22 to TREA 17 whenever EQUI 10, EQUI 12, EQUI 17, EQUI 18, EQUI 19, EQUI 20, EQUI 21, and EQUI 22 operates, and operate and maintain TREA 17 at all times that any emissions are vented to EQUI 17. The Permittee shall document periods of non-operation of the control equipment TREA 17 whenever EQUI 10, EQUI 12, EQUI 17, EQUI 18, EQUI 19, EQUI 20, EQUI 21, and EQUI 22 is operating. [Minn. R. 7007.0800, subp. 2(A), To avoid major source under 40 CFR 70.2 & Minn. R. 7007.0200]


TREA 17 18490

If the Permittee replaces TREA 17, the replacement control must meet or exceed the control efficiency requirements of TREA 17 as well as comply with all other requirements of TREA 17. Prior to making such a change, the Permittee shall apply for and obtain the appropriate permit amendment, as applicable. If no amendment is needed for the replacement, the Permittee shall submit an electronic notice to the Agency using Form CR-05. The notice must be received by the Agency seven working days prior to the commencement/start of replacement. [Minn. R. 7007.0800, subp. 2(A), To avoid major source under 40 CFR 70.2 & Minn. R. 7007.0200]

TREA 17 18500

Particulate Matter Control Device Temperature Monitors: The owner or operator shall install, calibrate, maintain, and operate at all times temperature monitors that continuously read and record the temperatures of the flue gas at the inlet of each particulate matter control device. [Minn. R. 7011.1260, subp. 2]

TREA 17 18510

Monitoring Equipment: The Permittee shall install and maintain the necessary monitoring equipment for measuring and recording pressure drop as required by this permit. The monitoring equipment must be installed, in use, and properly maintained when the monitored fabric filter is in operation. [Minn. R. 7007.0800, subp. 4]

TREA 17 18530

Averaging Periods: Except as provided below and in Minn. R. 7011.1260, subps. 4, 4a, and 5, the requirements in Minn. R. 7017.1002 to 7017.1220 apply to continuous monitoring data collection, reduction, and averaging periods.

For particulate matter control device inlet temperature monitoring, four-hour arithmetic block averages calculated from four consecutive one-hour arithmetic averages. [Minn. R. 7011.1260, subp. 4]

TREA 17 18550

The Permittee shall calibrate or replace the pressure drop monitor at least once every 12 months and shall maintain a written record of any action resulting from the calibration. [Minn. R. 7007.0800, subp. 14, Minn. R. 7007.0800, subp. 4, Minn. R. 7007.0800, subp. 5]

TREA 17 18560

Pressure Drop: Recordkeeping. The Permittee shall record the time and date of each pressure drop reading and whether or not the recorded pressure drop was within the range specified in this permit. [Minn. R. 7007.0800, subps. 4-5, To avoid major source under 40 CFR 70.2 & Minn. R. 7007.0200]

TREA 17 18565

Periodic Inspections: At least once per calendar quarter, or more frequently as required by the manufacturing specifications, the Permittee shall inspect the control equipment components. The Permittee shall maintain a written record of these inspections. [Minn. R. 7007.0800, subp. 14, Minn. R. 7007.0800, subp. 4, Minn. R. 7007.0800, subp. 5]

TREA 17 18570

The Permittee shall operate and maintain the fabric filter in accordance with the Operation and Maintenance (O & M) Plan. The Permittee shall keep copies of the O & M Plan available onsite for use by staff and MPCA staff. [Minn. R. 7007.0800, subp. 14]

TREA 17 19640

Corrective Actions: The Permittee shall take corrective action as soon as possible if any of the following occur:- the recorded pressure drop is outside the required operating range; or- the fabric filter or any of its components are found during the inspections to need repair.Corrective actions shall return the pressure drop to within the permitted range, eliminate visible emissions, and/or include completion of necessary repairs identified during the inspection, as applicable. Corrective actions include, but are not limited to, those outlined in the O & M Plan for the fabric filter. The Permittee shall keep a record of the type and date of any corrective action taken for each filter. [Minn. R. 7007.0800, subp. 14, Minn. R. 7007.0800, subp. 2(A), Minn. R. 7007.0800, subp. 5]

Agency Interest Name Subject Item ID Subject Item Designation Subject Item Description

Enviro-Chem Inc - Plant1

ACTV3 Null All IAs

AISI4321 Null Null

COMG1 GP001Six Class IV WasteCombustors

EQUI9 EU009Smelting Furnace - MediumCrucible Furnace

EQUI10 EU010Smelting Furnace - TiltFurnace #1

EQUI12 EU012Smelting Furnace - MediumTilt Furnace

EQUI17 EU005 Waste Combustor Film #1




EQUI21 EU013Waste Combustor (Assay,Small Lot)


EQUI23 NullAfterburner TREA 6 & TREA8 Temperature, Baghouse..

EQUI24 NullAfterburner Temp Probe(TREA 6)


EQUI26 NullBaghouse InletTemperature Probe (TREA..

EQUI27 Null Baghouse Pressure DropProbe (TREA 17)

List of SIs

Agency Interest: Enviro-Chem Inc - Plant 1Agency Interest ID: 4321Activity: IND20110002 (State Reissuance)

Details for:SI Category: NoneSI Type: All

Agency Interest Name Subject Item ID Subject Item Designation Subject Item DescriptionEnviro-Chem Inc - Plant1

EQUI26 Null

Baghouse InletTemperature Probe (TREA..

EQUI27 NullBaghouse Pressure DropProbe (TREA 17)

STRU1 SV001 Baghouse emissions

STRU2 SV002General emissions (roofvent)

STRU3 SV003 Precipitation emissions

TFAC1 05300411 Enviro-Chem Inc - Plant 1

TREA6 CE006 Direct Flame Afterburner

TREA8 CE008 Direct Flame Afterburner

TREA17 CE017Fabric Filter - MediumTemperature i.e., 180 F<T..

List of SIs


Details for:SI Category: NoneSI Type: All

Agency Interest Na.. Activity ID Subject Ite..Subject Item Type Description Subject Item ID Subject Ite..Subject Ite..Status Desc..Sub Attribute Description

Enviro-Chem Inc -Plant 1

IND201100..Activity Insignificant Air Emissions Activity ACTV3 Null All IAs Active /Existing

Minn. R. 7007.1300, subp. 3(D)

Minn. R. 7007.1300, subp. 3(F)

Insignificant air emissions activity


Details for:SI Category: ActivitySI Type: Insignificant Air Emissions Activity

Agency Interest Name Subject Item ID Subject Item DesignationSubject Item Description Group Member ID (padded)

Enviro-Chem Inc - Plant1

COMG1 GP001 Six Class IV WasteCombustors

EQUI17

EQUI18

EQUI19

EQUI20

EQUI21

EQUI22

STRU1

TREA6

TREA8

Component Group (Members)

Agency Interest: Enviro-Chem Inc - Plant 1Agency Interest ID: 4321Activity: None (State Reissuance)

Details for:SI Category: Component GroupSI Type: Air Component Group

Subject ItemCategory Description

Subject Item TypeDescription Subject Item ID

Subject ItemDesignation Subject Item Description Pollutant

Potential (lbs/hr)

Unrestricted Potential

(tons/yr)

Potential Limited

(tons/yr)

Actual Emissions

(tons/yr)

Component Group Air Component Group COMG1 GP001 Six Class IV WasteCombustors

HAPs - Total

Mercury Co..

Equipment Incinerator EQUI17 EU005 Waste Combustor Film #1 Cadmium c..

Carbon Dio..

Carbon Dio..

Carbon Mo..

Chromium c..

Formaldehy..

HAPs - Total

Hexane

Lead

Mercury Co..

Methane

Naphthalene

Nickel com..

Nitrogen O..

Nitrous Oxi..

Particulate ..

PM < 2.5 mi..

PM < 10 mic..

Polycyclic o..

Selenium co..

Sulfur Dioxi..

Toluene

Volatile Org..

EQUI18 EU006 Waste Combustor Film #2 Cadmium c..

Carbon Dio..

Carbon Dio..

Carbon Mo..

Chromium c..

Formaldehy..

HAPs - Total

Hexane

Lead

Mercury Co..

Methane

Naphthalene

Nickel com..

Nitrogen O..

Nitrous Oxi..

Particulate ..

PM < 2.5 mi..

PM < 10 mic..

Polycyclic o..

Selenium co..

Sulfur Dioxi..

Toluene

Volatile Org..


Carbon Dio..

Carbon Dio..

Carbon Mo..

Chromium c..

Formaldehy..

HAPs - Total

Hexane

Lead

Mercury Co..

Methane

Naphthalene

0.0008510.000851

0.0008510.000851

0.0001940.000194

0.08244.67e-05

0.123.88e-071.14e-060.8930.8930.569

0.008791.47

3.54e-058.38e-060.0316

00.001160.02470.02850.00103

01.7

1,6521,649

0.00143

0.764.67e-05

0.126.16e-061.14e-06

11.411.419.2

0.008791.47

0.0006838.38e-060.0316

00.001160.02470.03030.00103

012

1,6521,649

0.00143

0.01881.07e-050.02798.86e-082.61e-070.2040.2040.13

0.002010.33

8.08e-061.91e-060.00722

00.0002660.005650.0065

0.0002350

0.387377376

0.000327

0.02571.17e-05

0.121.41e-072.86e-070.5960.815

00

0.431.38e-052.1e-060.0079

00.001160.006180.009050.000258

00.83413412

0.00142

0.7031.17e-05

0.125.92e-062.86e-07

8.1611.319.10

0.430.0006622.1e-060.0079

00.001160.006180.0109

0.0002580

11.1413412

0.00142

0.005882.67e-060.02653.21e-086.53e-080.1860.186

000.1

3.14e-064.78e-070.0018

00.0002640.001410.002075.88e-05

00.18994.394.1

0.000325

0.02571.17e-05

0.121.41e-072.86e-070.5960.815

00

0.431.38e-052.1e-060.0079

00.001160.006180.009050.000258

00.83413412

0.00142

0.7031.17e-05

0.125.92e-062.86e-07

8.1611.319.10

0.430.0006622.1e-060.0079

00.001160.006180.0109

0.0002580

11.1413412

0.00142

0.005882.67e-060.02653.21e-086.53e-080.1860.186

000.1

3.14e-064.78e-070.0018

00.0002640.001410.002075.88e-05

00.18994.394.1

0.000325

PTE by subject item

Agency Interest: NoneAgency Interest ID: 4321Activity: None (State Reissuance)

Details for:SI Category: AllSI Type: All




Potential (lbs/hr)


(tons/yr)

Potential Limited

(tons/yr)

Actual Emissions

(tons/yr)

Equipment Incinerator EQUI19 EU007 Waste Combustor Film #3Methane

Naphthalene

Nickel com..

Nitrogen O..

Nitrous Oxi..

Particulate ..

PM < 2.5 mi..

PM < 10 mic..

Polycyclic o..

Selenium co..

Sulfur Dioxi..

Toluene

Volatile Org..


Carbon Dio..

Carbon Dio..

Carbon Mo..

Chromium c..

Formaldehy..

HAPs - Total

Hexane

Lead

Mercury Co..

Methane

Naphthalene

Nickel com..

Nitrogen O..

Nitrous Oxi..

Particulate ..

PM < 2.5 mi..

PM < 10 mic..

Polycyclic o..

Selenium co..

Sulfur Dioxi..

Toluene

Volatile Org..

EQUI21 EU013 Waste Combustor (Assay,Small Lot)

Cadmium c..

Carbon Dio..

Carbon Dio..

Carbon Mo..

Chromium c..

Formaldehy..

HAPs - Total

Hexane

Lead

Mercury Co..

Methane

Naphthalene

Nickel com..

Nitrogen O..

Nitrous Oxi..

Particulate ..

PM < 2.5 mi..

PM < 10 mic..

Polycyclic o..

Selenium co..

Sulfur Dioxi..

Toluene

Volatile Org..


Carbon Dio..

0.02571.17e-05

0.121.41e-072.86e-070.5960.815

00

0.431.38e-052.1e-060.0079

00.001160.006180.009050.000258

00.83413412

0.00142

0.7031.17e-05

0.125.92e-062.86e-07

8.1611.319.10

0.430.0006622.1e-060.0079

00.001160.006180.0109

0.0002580

11.1413412

0.00142

0.005882.67e-060.02653.21e-086.53e-080.1860.186

000.1

3.14e-064.78e-070.0018

00.0002640.001410.002075.88e-05

00.18994.394.1

0.000325

0.02571.17e-05

0.121.41e-072.86e-070.5960.815

00

0.431.38e-052.1e-060.0079

00.001160.006180.009050.000258

00.83413412

0.00142

0.7031.17e-05

0.125.92e-062.86e-07

8.1611.319.10

0.430.0006622.1e-060.0079

00.001160.006180.0109

0.0002580

11.1413415

0.00142

0.005882.67e-060.02653.21e-086.53e-080.1860.186

000.1

3.14e-064.78e-070.0018

00.0002640.001410.002075.88e-05

00.18994.394.1

0.000325

0.0547.15e-070.119

2.64e-077.15e-070.5870.587

00.950.95

2.46e-055.24e-060.0198

00.001160.01550.0188

0.0006440

1.261,0331,031

0.00143

0.737.15e-070.119

6.04e-067.15e-07

11.311.319.10.950.95

0.0006725.24e-060.0198

00.001160.01550.0206

0.0006440

11.51,0331,031

0.00143

0.0181.63e-070.02726.04e-081.63e-070.1950.195

00.2170.217

5.61e-061.2e-060.00451

00.0002650.003530.004280.000147

00.288236235

0.000326

0.001420.001420.000325

PTE by subject item






Potential (lbs/hr)


(tons/yr)

Potential Limited

(tons/yr)

Actual Emissions

(tons/yr)

Equipment Incinerator EQUI22 EU014 Waste Combustor Film #5Cadmium c..

Carbon Dio..

Carbon Dio..

Carbon Mo..

Chromium c..

Formaldehy..

HAPs - Total

Hexane

Lead

Mercury Co..

Methane

Naphthalene

Nickel com..

Nitrogen O..

Nitrous Oxi..

Particulate ..

PM < 2.5 mi..

PM < 10 mic..

Polycyclic o..

Selenium co..

Sulfur Dioxi..

Toluene

Volatile Org..

Smelting Equipment EQUI9 EU009 Smelting Furnace -Medium Crucible Furnace

Cadmium c..

Carbon Dio..

Carbon Dio..

Carbon Mo..

Chromium c..

Formaldehy..

HAPs - Total

Hexane

Lead

Mercury Co..

Methane

Naphthalene

Nickel com..

Nitrogen O..

Nitrous Oxi..

Particulate ..

PM < 2.5 mi..

PM < 10 mic..

Polycyclic o..

Selenium co..

Sulfur Dioxi..

Toluene

Volatile Org..

EQUI10 EU010 Smelting Furnace - TiltFurnace #1

Cadmium c..

Carbon Dio..

Carbon Dio..

Carbon Mo..

Chromium c..

Formaldehy..

HAPs - Total

Hexane

Lead

Mercury Co..

Methane

Naphthalene

Nickel com..

Nitrogen O..

Nitrous Oxi..

0.02571.17e-05

0.121.41e-072.86e-070.5960.815

00

0.431.38e-052.1e-060.0079

00.001160.006180.009050.000258

00.83413412

0.00142

0.7031.17e-05

0.125.92e-062.86e-07

8.1611.319.10

0.430.0006622.1e-060.0079

00.001160.006180.0109

0.0002580

11.1413412

0.00142

0.005882.67e-060.02653.21e-086.53e-080.1860.186

000.1

3.14e-064.78e-070.0018

00.0002640.001410.002075.88e-05

00.18994.394.1

0.000325

0.1597.3e-060.01228.56e-081.79e-070.2720.290.476

0.001370.21

8.33e-061.31e-060.004946.13e-073.27e-060.003860.004190.000161

00.18258258

0.000133

0.1597.3e-060.01228.56e-081.79e-07

0.290.290.476

0.001370.21

8.33e-061.31e-060.004946.13e-074.34e-060.003860.004180.000161

00.18258258

0.000133

0.0361.67e-060.002791.95e-084.08e-08

0.070.070.11

0.0003140.0491.9e-062.99e-070.001131.4e-079.91e-070.0008820.0009563.68e-05

00.041158.958.8

3.05e-05

1.51.75e-05

0.111.94e-074.29e-070.7340.70

0.00330.52

1.88e-053.14e-060.01191.45e-063.52e-050.009280.01

0.0003860

0.43620618

0.00134

1.51.75e-05

0.114.64e-074.29e-07

2.752.754.64

0.00330.52

4.9e-053.14e-060.01191.45e-069.37e-060.009280.0111

0.0003860

0.43620618

0.000283

0.3424e-060.03

4.44e-089.79e-080.1680.160

0.0007530.12

4.28e-067.18e-070.002714.32e-072.14e-060.002120.002288.82e-05

00.0982141141

6.46e-05

PTE by subject item






Potential (lbs/hr)


(tons/yr)

Potential Limited

(tons/yr)

Actual Emissions

(tons/yr)

Equipment Smelting Equipment EQUI10 EU010 Smelting Furnace - TiltFurnace #1

Nitrogen O..

Nitrous Oxi..

Particulate ..

PM < 2.5 mi..

PM < 10 mic..

Polycyclic o..

Selenium co..

Sulfur Dioxi..

Toluene

Volatile Org..

EQUI12 EU012 Smelting Furnace -Medium Tilt Furnace

Cadmium c..

Carbon Dio..

Carbon Dio..

Carbon Mo..

Chromium c..

Formaldehy..

HAPs - Total

Hexane

Lead

Mercury Co..

Methane

Naphthalene

Nickel com..

Nitrogen O..

Nitrous Oxi..

Particulate ..

PM < 2.5 mi..

PM < 10 mic..

Polycyclic o..

Selenium co..

Sulfur Dioxi..

Toluene

Volatile Org..

Structure Stack/Vent STRU1 SV001 Baghouse emissions Particulate ..

1.51.75e-05

0.111.94e-074.29e-070.7340.70

0.00330.52

1.88e-053.14e-060.01191.45e-063.52e-050.009280.01

0.0003860

0.43620618

0.00134

1.51.75e-05

0.114.64e-074.29e-07

2.752.754.64

0.00330.52

4.9e-053.14e-060.01191.45e-069.37e-060.009280.0111

0.0003860

0.43620618

0.000283

0.3424e-060.03

4.44e-089.79e-080.1680.160

0.0007530.12

4.28e-067.18e-070.002714.32e-072.14e-060.002120.002288.82e-05

00.0982141141

6.46e-05

0.881.17e-05

0.071.24e-072.86e-07

0.430.430

0.00220.33

1.18e-052.1e-060.00799.6e-072.08e-050.006180.006650.000258

00.29413412

0.000782

0.881.17e-05

0.072.81e-072.86e-07

1.611.612.71

0.00220.33

2.95e-052.1e-060.00799.6e-075.68e-060.006180.007290.000258

00.29413412

0.000166

0.1992.67e-06

0.022.83e-086.53e-080.0930.093

00.000502

0.082.7e-064.78e-070.00182.77e-071.3e-060.001410.001525.88e-05

00.066294.394.1

3.78e-05

8.7602

PTE by subject item



Equipment Data AcquisitionSystem

EQUI23 Null AfterburnerTREA 6 &TREA 8Temperatur..

receivesfrom

EQUI24 Null Parametric Monitor 9/1/2005 Null




Incinerator EQUI17 EU005 WasteCombustorFilm #1

is controlledby

TREA6 100021-Direct FlameAfterburner

6/2/2000 Null

TREA17 0017-Fabric Filter - MedTemp, 180 F<T<250 F

6/2/2000 Null

sends to STRU1 100 Stack/Vent 5/23/2007 Null

EQUI18 EU006 WasteCombustorFilm #2

is controlledby


5/23/2007 Null


5/23/2007 Null



is controlledby


5/23/2007 Null


5/23/2007 Null



is controlledby


5/23/2007 Null


5/23/2007 Null


EQUI21 EU013 WasteCombustor(Assay,Small Lot)

is controlledby


5/23/2007 Null


5/23/2007 Null



is controlledby


5/23/2007 Null


5/23/2007 Null


SmeltingEquipment

EQUI9 EU009SmeltingFurnace - M..


EQUI10 EU010 SmeltingFurnace - TiltFurnace #1

is controlledby


5/23/2007 Null


STRU2 50 Stack/Vent 5/23/2007 Null

EQUI12 EU012 SmeltingFurnace -Medium TiltFurnace

is controlledby


5/23/2007 Null


STRU2 50 Stack/Vent 5/23/2007 Null

Treatment 017-Fabric Filter -Med Temp, 180F<T<250 F

TREA17 CE017 Fabric Filter -MediumTemperaturei.e., 180 F<..

is monitoredby



021-Direct FlameAfterburner

TREA6 CE006 Direct FlameAfterburner

is controlledin series by


5/23/2007 Null

is monitoredby


TREA8 CE008 Direct FlameAfterburner

is controlledin series by


5/23/2007 Null

is monitoredby


SI - SI relationships



SmeltingEquipment

EQUI9 EU009SmeltingFurnace -Medium Cr..

OwnerManufactured

N/A 30 pounds each Metal 11/1/1984 12/1/1984 Null

EQUI10 EU010SmeltingFurnace - TiltFurnace #1

McEngleranSpeedy MeltT-200

300 pounds each Metal 5/1/1985 6/1/1985 Null

EQUI12 EU012SmeltingFurnace -Medium Tilt..

N/A N/A 175 pounds each Metal 2/1/1996 5/1/1996 Null

Emission Units 1


Details for:SI Category: NoneSI Type: Smelting Equipment

Incinerator EQUI17 EU005WasteCombustor ..

Atlas CFA-72 1000 pounds cycle Solid Waste 7/1/1985 9/1/1985 Null

EQUI18 EU006WasteCombustor ..





Multi Service CFA-72 1000 pounds cycle Solid Waste 7/1/1989 9/1/1989 Null


Atlas PH50 1000 pounds cycle Solid Waste 5/1/1987 6/1/1987 Null


Multi Service CFA-72 1000 pounds cycle Solid Waste 7/1/1989 9/1/1989 Null

Emission Units 2


Details for:SI Category: EquipmentSI Type: Incinerator


Subject ItemDesignation

Subject ItemDescription

FiringMethod Engine Use

EngineDisplacement

EngineDisplacementUnits

Subject toCSAPR?

ElectricGeneratingCapacity(MW)

Incinerator EQUI17 EU005WasteCombustor ..

Not coalburning

Null Null Null N Null


Not coalburning

Null Null Null Null Null


Not coalburning



Not coalburning



Not coalburning



Not coalburning


Emission Units 2 (continued)


Details for:SI Category: EquipmentSI Type: Incinerator

Subject Item IDSubject ItemDesignation Subject Item Description Manufacturer Model Serial Number

Parameter Monitored(Parametric)

BypassCapability?(parametric)

Install Date(parametric)


Honeywell TVE2-4-6-G-OBO 06054669317400001 Temperature No 9/1/2005


Krumor Inc. A4010-16KP14B Null Temperature No 9/1/2005

EQUI26 NullBaghouse InletTemperature Probe (TREA..

PyromationJ68U-012-00-8HN63 Type J

Null Temperature No 12/29/2005

EQUI27 NullBaghouse Pressure DropProbe (TREA 17)

Farr DCP100A Null Pressure Drop No 9/1/2005

Parametric Mon, General


Details for:SI Category: EquipmentSI Type: Parametric Monitor

Subject Item IDSubject ItemDesignation Subject Item Description Manufacturer Model Serial Number

Primary orBackup? (DASs) Install Date (DASs)

EQUI23 NullAfterburner TREA 6 & TREA8 Temperature, Baghouse..

Null Null Null Primary 9/1/2005

Data Acquisition System, General


Details for:SI Category: EquipmentSI Type: Data Acquisition System

Stack/Vent STRU1 SV001Baghouseemissions

38 3.17 Null Null 16000 170 Manufactur..Upwards with no cap onstack/vent

STRU2 SV002Generalemissions (..

31 Null 2.2 1.6 3500 70 EstimateUpwards with no cap onstack/vent

STRU3 SV003Precipitationemissions

30 2 Null Null 3000 70 EstimateUpwards with no cap onstack/vent

Stack/Vent, General


Details for:SI Category: StructureSI Type: Stack/Vent

017-FabricFilter - MedTemp, 180F<T<250 F

TREA17 CE017 Fabric Filter -MediumTemperaturei.e., 180F<T<250 F

Farr GS-20 NullParticulateMatter

100 99 No Null Other 0.5 4.5 No

PM < 2.5micron


PM < 10micron


Fabric Filters, General


Details for:SI Category: TreatmentSI Type: 017-Fabric Filter - Med Temp, 180 F<T<250 F

021-Direct Flame Afterburner, TREA6 CE006Direct Flame Afterburner

Atlas/MultiService

CFA-723..Null Carbon Monoxide 100 95 No Null Other Null Null Null 1800 4.5

Volatile OrganicCompounds

100 99 No Null Other Null Null Null 1800 4.5

021-Direct Flame Afterburner, TREA8 CE008Direct Flame Afterburner

Multi Service PH50 Null Carbon Monoxide 100 95 No Null Other Null Null Null 1800 2.3

Volatile OrganicCompounds

100 99 No Null Other Null Null Null 1800 2.3

Direct Flame Afterburners, General


Details for:SI Category: TreatmentSI Type: 021-Direct Flame Afterburner

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