DRAFT Air Individual Permit Part 70 Reissuance

Transcription

1 DRAFT Air Individual Permit Part 70 Reissuance Permittee: Facility name: Badger Foundry Co Badger Foundry Co 1058 E Mark St Winona, MN55987 Winona County Expiration date: < > * All Title I Conditions do not expire Part 70 Reissuance: < > Permit characteristics: Federal; Part 70/ Major for NSR The emission units, control equipment and emission stacks at the stationary source authorized in this permit reissuance are as described in the Permit Applications Table. This permit reissuance supersedes Air Emission Permit No and authorizes the Permittee to operate the stationary source at the address listed above unless otherwise noted in the permit. The Permittee must comply with all the conditions of the permit. Any changes or modifications to the stationary source must be performed in compliance with Minn. R to Terms used in the permit are as defined in the state air pollution control rules unless the term is explicitly defined in the permit. Unless otherwise indicated, all the Minnesota rules cited as the origin of the permit terms are incorporated into the SIP under 40 CFR and as such are enforceable by EPA Administrator or citizens under the Clean Air Act. Signature: [ ] for This document has been electronically signed. Don Smith, P.E., Manager Air Quality Permits Section Industrial Division for the Minnesota Pollution Control Agency

2 Table of Contents 1. Permit applications table Where to send submittals Facility description Summary of subject items Limits and other requirements Submittal/action requirements Appendices Appendix A. Insignificant Activities and General Applicable Requirements Appendix B. PM10 Modeling Parameters Appendix C. VOC and HAP Emission Factors for Pouring/Cooling (EQUI 23) Appendix D. VOC and HAP Evaporation Rates for Sand/Resin/Catalyst Mixing Appendix E. Maximum Content of Materials Appendix F. 40 CFR Subpart A General Provisions Page

3 Permit issued: [month day, year] Permit expires: [month day, year] Page 3 of Permit applications table Subsequent permit applications: Title description Application receipt date Action number Part 70 Reissuance 12/30/

4 Permit issued: [month day, year] Permit expires: [month day, year] Page 4 of Where to send submittals Send submittals that are required to be submitted to the U.S. EPA regional office to: Chief Air Enforcement Air and Radiation Branch EPA Region V 77 West Jackson Boulevard Chicago, Illinois Each submittal must be postmarked or received by the date specified in the applicable Table. Those submittals required by Minn. R to must be certified by a responsible official, defined in Minn. R , subp. 21. Other submittals shall be certified as appropriate if certification is required by an applicable rule or permit condition. Send submittals that are required by the Acid Rain Program to: U.S. Environmental Protection Agency Clean Air Markets Division 1200 Pennsylvania Avenue NW (6204N) Washington, D.C Send any application for a permit or permit amendment to: Fiscal Services 6 th Floor Minnesota Pollution Control Agency 520 Lafayette Road North St. Paul, Minnesota Also, where required by an applicable rule or permit condition, send to the Permit Document Coordinator notices of: a. Accumulated insignificant activities b. Installation of control equipment c. Replacement of an emissions unit, and d. Changes that contravene a permit term Unless another person is identified in the applicable Table, send all other submittals to: AQ Compliance Tracking Coordinator Industrial Division Minnesota Pollution Control Agency 520 Lafayette Road North St. Paul, Minnesota Or a signed and scanned PDF copy to: submitstacktest.pca@state.mn.us (for submittals related to stack testing) AQRoutineReport.PCA@state.mn.us (for other compliance submittals) (See complete instructions in Routine Air Report Instructions Letter at

5 Permit issued: [month day, year] Permit expires: [month day, year] Page 5 of Facility description The Badger Foundry Co (Facility) is located at 1058 E Mark St in Winona, Winona County, Minnesota. Badger Foundry operates a gray iron foundry with one cupola and electric melt furnace, supporting machine operations, and natural gas combustion units. The foundry is currently dedicated to making gray iron and ductile iron castings. Badger Foundry uses primarily green sand molds and phenolic urethane cores. In general, the major emissions from foundries are particulate matter (PM), including particulate matter less than ten microns (PM10) and particulate matter less than 2.5 microns (PM2.5); and volatile organic compounds (VOC). Particulate matter is generated from virtually all of the operations at a foundry. VOCs are generated when the molten metal comes in contact with the green sand molds and the cores, and when mold and core sand is mixed with binders. The PM emissions from the blasting cabinets that clean the castings are controlled by baghouses. PM emissions from sand handling are controlled by the moisture content of the sand. The PM from the shake-out area and the mold sand muller are controlled by baghouses. PM emissions from the cupola are controlled by a venturi scrubber and VOC emissions from the cupola are controlled by an afterburner. The primary sources of HAP emissions are the mixing of sand with resin and catalyst to make molds and cores, and the emissions released when molten iron is poured into the molds.

6 Permit issued: [month day, year] Permit expires: [month day, year] Page 6 of Summary of subject items SI ID: Description TFAC 1: Badger Foundry Co ACTV 3: All Insignificant Activities COMG 3: 2 % or greater moisture COMG 4: Direct Heating Equipment Relationshi p Type has members has members COMG 5: Core Dip Tanks has BACT Limits members COMG 6: Units Subject has to IPER members COMG 7: HAP's-Limit has members COMG 8: 40 CFR pt. 63, subp. ZZZZZ has members COMG 10: No-bake sand has reclaim system members COMG 11: Omega- has Kloster Line members COMG 12: Core Making has Machines members Related SI ID: Description EQUI 11, EQUI 12, EQUI 13, EQUI 14, EQUI 15, EQUI 16, EQUI 17, EQUI 24 EQUI 8, EQUI 36, EQUI 37, EQUI 38, EQUI 41 EQUI 39, EQUI 42 EQUI 1, EQUI 2, EQUI 3, EQUI 4, EQUI 7, EQUI 9, EQUI 10, EQUI 11, EQUI 12, EQUI 13, EQUI 14, EQUI 15, EQUI 16, EQUI 17, EQUI 18, EQUI 19, EQUI 20, EQUI 21, EQUI 22, EQUI 23, EQUI 24, EQUI 26, EQUI 27, EQUI 28, EQUI 29 EQUI 3, EQUI 4, EQUI 7, EQUI 10, EQUI 22, EQUI 23, EQUI 44, EQUI 45 EQUI 7, EQUI 10 EQUI 20, EQUI 21, EQUI 22 EQUI 3, EQUI 4 EQUI 3, EQUI 4, EQUI 22, EQUI 44, EQUI SI ID: Description EQUI 1: Melt Charge Handling-Material Handling Equipment EQUI 2: Casting Shakeout/Mold Dump - Casting Equipment EQUI 2: Casting Shakeout/Mold Dump - Casting Equipment EQUI 3: Chemically Set Core (350) - Mixing Equipment EQUI 4: Chemically Set Core (75) - Mixing Equipment EQUI 7: Cupola - Other Emission Unit EQUI 7: Cupola - Other Emission Unit EQUI 7: Cupola - Other Emission Unit EQUI 8: Cupola Start Up Torch-Other Emission Unit EQUI 8: Cupola Start Up Torch-Other Emission Unit EQUI 8: Cupola Start Up Torch-Other Emission Unit Relationshi p Type sends to Related SI ID: Description 45 STRU 7: Melt Charge Yard Door sends to STRU 15: Baghouse Stack for Pouring, Cooling, Shakeout, Mullor, Wheelabrator P/A is controlled by TREA 19: Fabric Filter - Low Temperature, i.e., T<180 Degrees F - Wheelabrator P/A sends to STRU 17: Cupola Emission Stack is controlled in series by is controlled in series by TREA 14: Venturi Scrubber TREA 15: Afterburner - Thermal Oxidizer sends to STRU 17: Cupola Emission Stack is controlled in series by is controlled in series by TREA 14: Venturi Scrubber TREA 15: Afterburner - Thermal Oxidizer EQUI 9: Ductile sends to STRU 14:

7 Permit Expires: [month day, year] Page 7 of 148 SI ID: Description Treatment Operations - Casting Equipment EQUI 9: Ductile Treatment Operations - Casting Equipment EQUI 10: Electric Induction Melting Furnace-Furnace EQUI 10: Electric Induction Melting Furnace-Furnace EQUI 11: Green Sand Mold-Making Machines (A1)-Molding Equipment EQUI 12: Green Sand Mold-Making Machines (A2)-Molding Equipment EQUI 13: Green Sand Mold-Making Machines (B1)-Molding Equipment EQUI 14: Green Sand Mold-Making Machines (B2)-Molding Equipment EQUI 15: Green Sand Mold-Making Machine (C1)-Molding Equipment EQUI 16: Green Sand Mold-Making Machines (C2)-Molding Equipment EQUI 17: Green Sand Mold Mullor-Molding Equipment Relationshi Related SI ID: p Type Description Baghouse Stack for No- Bake Sand (Ultra) is TREA 18: controlled Fabric Filter - by Low Temperature, i.e., T<180 Degrees F - Ultra sends to STRU 14: Baghouse Stack for No- Bake Sand (Ultra) is controlled by is controlled by is controlled by is controlled by is controlled by is controlled by is controlled by TREA 18: Fabric Filter - Low Temperature, i.e., T<180 Degrees F - Ultra TREA 13: 2% or greater moisture TREA 13: 2% or greater moisture TREA 13: 2% or greater moisture TREA 13: 2% or greater moisture TREA 13: 2% or greater moisture TREA 13: 2% or greater moisture sends to STRU 15: Baghouse Stack for Pouring, Cooling, Shakeout, Mullor, Wheelabrator P/A SI ID: Description EQUI 17: Green Sand Mold Mullor-Molding Equipment EQUI 18: Mold Dump - Molding Equipment EQUI 18: Mold Dump - Molding Equipment EQUI 19: Multiple Hand Grinding Stations (SC/LC)-Grinder EQUI 20: No-Bake Vibra Mill Reclaimer - Material Handling Equipment EQUI 20: No-Bake Vibra Mill Reclaimer - Material Handling Equipment EQUI 21: No-Bake Sand Handling System- Material Handling Equipment EQUI 21: No-Bake Sand Handling System- Material Handling Equipment Relationshi Related SI ID: p Type Description is TREA 19: controlled Fabric Filter - by Low Temperature, i.e., T<180 Degrees F - Wheelabrator P/A sends to STRU 15: Baghouse Stack for Pouring, Cooling, Shakeout, Mullor, Wheelabrator P/A is controlled by TREA 19: Fabric Filter - Low Temperature, i.e., T<180 Degrees F - Wheelabrator P/A sends to STRU 14: Baghouse Stack for No- Bake Sand (Ultra) is controlled by TREA 18: Fabric Filter - Low Temperature, i.e., T<180 Degrees F - Ultra sends to STRU 14: Baghouse Stack for No- Bake Sand (Ultra) is controlled by TREA 18: Fabric Filter - Low Temperature, i.e., T<180

8 Permit Expires: [month day, year] Page 8 of 148 SI ID: Description EQUI 22: No-Bake Mold Mixer (450) - Mixing Equipment EQUI 23: Pouring/Cooling-Other Emission Unit EQUI 24: Sand Handling System-Material Handling Equipment EQUI 24: Sand Handling System-Material Handling Equipment EQUI 26: Shot Blaster - 1 Wheel-Abrasive Equipment EQUI 26: Shot Blaster - 1 Wheel-Abrasive Equipment EQUI 27: Shot Blaster - 2 Wheel-Abrasive Equipment EQUI 27: Shot Blaster - 2 Wheel-Abrasive Equipment EQUI 28: Shot Blaster - 4 Wheel-Abrasive Equipment Relationshi p Type Related SI ID: Description Degrees F - Ultra sends to STRU 8: Baghouse Stack for 1 & 2 Wheel Shot Blasters, AAF. is controlled by TREA 16: Fabric Filter - Low Temperature, i.e., T<180 Degrees F - AAF sends to STRU 8: Baghouse Stack for 1 & 2 Wheel Shot Blasters, AAF. is controlled by TREA 16: Fabric Filter - Low Temperature, i.e., T<180 Degrees F - AAF sends to STRU 8: Baghouse Stack for 1 & 2 Wheel Shot Blasters, AAF. is controlled by TREA 16: Fabric Filter - Low Temperature, i.e., T<180 Degrees F - AAF sends to STRU 9: Baghouse Stack for 4 Wheel Shot Blaster, Wheelabrator SI ID: Description EQUI 28: Shot Blaster - 4 Wheel-Abrasive Equipment EQUI 29: Shot Blaster - 3 wheel-abrasive Equipment EQUI 29: Shot Blaster - 3 wheel-abrasive Equipment EQUI 36: Make Up Air Unit/Core Dept - Other Combustion EQUI 37: Make Up Air Unit/Green Sand Cleaning Dept - Other Combustion EQUI 38: Make Up Air Unit/4 Wheel Blaster Building - Other Combustion EQUI 39: Core/Mold Dip Tank B - Dipping Equipment EQUI 41: Cupola Start Up Torch - Other Emission Unit EQUI 41: Cupola Start Up Torch - Other Emission Unit EQUI 41: Cupola Start Up Torch - Other Emission Unit EQUI 42: Core/Mold Dip Tank A (Flow Coat) - Dipping Equipment EQUI 44: Chemically Set Core (150) - Mixing Relationshi p Type is controlled by Related SI ID: Description Shaker TREA 17: Fabric Filter - Low Temperature, i.e., T<180 Degrees F - Wheelabrator Shaker sends to STRU 14: Baghouse Stack for No- Bake Sand (Ultra) is controlled by TREA 18: Fabric Filter - Low Temperature, i.e., T<180 Degrees F - Ultra sends to STRU 17: Cupola Emission Stack is controlled by is controlled by TREA 14: Venturi Scrubber TREA 15: Afterburner - Thermal Oxidizer

9 Permit Expires: [month day, year] Page 9 of 148 SI ID: Description Equipment EQUI 45: Chemically Set Core (250) - Mixing Equipment STRU 7: Melt Charge Yard Door STRU 8: Baghouse Stack for 1 & 2 Wheel Shot Blasters, AAF. STRU 9: Baghouse Stack for 4 Wheel Shot Blaster, Wheelabrator Shaker STRU 14: Baghouse Stack for No-Bake Sand (Ultra) STRU 15: Baghouse Stack for Pouring, Cooling, Shakeout, Mullor, Wheelabrator P/A STRU 17: Cupola Emission Stack STRU 25: Main Building with Peaked Roof STRU 26: Cupola Building with Peaked Roof STRU 27: Charge Handling with Peaked Relationshi p Type Related SI ID: Description SI ID: Description Roof STRU 28: West side of Main Building STRU 29: Sand Handling and Roof Access TREA 13: 2% or greater moisture TREA 14: Venturi Scrubber TREA 15: Afterburner - Thermal Oxidizer TREA 16: Fabric Filter - Low Temperature, i.e., T<180 Degrees F - AAF TREA 17: Fabric Filter - Low Temperature, i.e., T<180 Degrees F - Wheelabrator Shaker TREA 18: Fabric Filter - Low Temperature, i.e., T<180 Degrees F - Ultra TREA 19: Fabric Filter - Low Temperature, i.e., T<180 Degrees F - Wheelabrator P/A Relationshi p Type Related SI ID: Description

10 Permit Expires: [month day, year] Page 10 of Limits and other requirements Subject Item Sec.SI.Reqt SI des:si desc Requirement & Citation TFAC Badger Foundry Co This permit establishes limits on the facility to keep it a minor source under 40 CFR The Permittee cannot make any change at the source that would make the source a major source under 40 CFR 63.2 until a permit amendment has been issued. This includes changes that might otherwise qualify as insignificant modifications and minor or moderate amendments. [Title I Condition: Avoid major source under 40 CFR 63.2] Equipment Inventory: The Permittee shall maintain a written list of all emissions units and control equipment on site. The Permittee shall update the list to include any replaced, modified, or new equipment prior to making the change. The list shall correlate the units to the numbers used in this permit (EQUI, COMG, TREA) and shall include the data on GI-04, GI-05B, and GI-05C. The date of construction shall be the date the change was made for replaced, modified, or new equipment. [Minn. R , subp. 2] Equipment Labeling: The Permittee shall permanently affix a unique number to each emission unit or in the vicinity of multiple activities and emission units described by a single EQUI designation. The numbers shall correlate the unit to the appropriate EQUI and COMG numbers used in this permit. The number can be affixed by placard, stencil, or other means. The number shall be maintained so that it is readable and visible at all times from a safe distance. If equipment is added, it shall be given a new unique number; numbers from replaced or removed equipment shall not be reused. [Minn. R , subp. 2] 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; Appendix C: VOC and HAP Emission Factors for Pouring/Cooling (EQUI 23); Appendix D: VOC and HAP Evaporation Rates for Sand/Resin/Catalyst Mixing; and Appendix E: Maximum Content of Materials. Modeling parameters in Appendix B: PM10 Modeling Parameters are included for reference only as described elsewhere in this permit. [Minn. R , subp. 2] PERMIT SHIELD: Subject to the limitations in Minn. R , compliance with the conditions of this permit shall be deemed compliance with the specific provision of the applicable requirement identified in the permit as the basis of each condition. Subject to the limitations of Minn. R and , subp. 2, notwithstanding the conditions of this permit specifying compliance practices for applicable requirements, any person

11 Permit Expires: [month day, year] Page 11 of 148 Subject Item Sec.SI.Reqt SI des:si desc Requirement & Citation (including the Permittee) may also use other credible evidence to establish compliance or noncompliance with applicable requirements. This permit shall not alter or affect the liability of the Permittee for any violation of applicable requirements prior to or at the time of permit issuance. [Minn. R , (A)(2)] These requirements apply if a reasonable possibility (RP) as defined in 40 CFR Section 52.21(r)(6)(vi) exists that a proposed project, analyzed using the actual-to-projected-actual (ATPA) test (either by itself or as part of the hybrid test at Section 52.21(a)(2)(iv)(f)) and found to not be part of a major modification, may result in a significant emissions increase (SEI). If the ATPA test is not used for the project, or if there is no RP that the proposed project could result in a SEI, these requirements do not apply to that project. The Permittee is only subject to the Preconstruction Documentation requirement for a project where a RP occurs only within the meaning of Section 52.21(r)(6)(vi)(b). Even though a particular modification is not subject to New Source Review (NSR), or where there isn't a RP that a proposed project could result in a SEI, a permit amendment, recordkeeping, or notification may still be required by Minn. R [Minn. R , subp. 2, Title I Condition: 40 CFR 52.21(r)(6) and Minn. R ] Preconstruction Documentation -- Before beginning actual construction on a project, the Permittee shall document the following: 1. Project description 2. Identification of any emission unit whose emissions of an NSR pollutant could be affected 3. Pre-change potential emissions of any affected existing emission unit, and the projected post-change potential emissions of any affected existing or new emission unit. 4. A description of the applicability test used to determine that the project is not a major modification for any regulated NSR pollutant, including the baseline actual emissions, the projected actual emissions, the amount of emissions excluded due to increases not associated with the modification and that the emission unit could have accommodated during the baseline period, an explanation of why the amounts were excluded, and any creditable contemporaneous increases and decreases that were considered in the determination. The Permittee shall maintain records of this documentation. [Minn. R , subps. 4-5, Minn. R , subp. 4, Title I Condition: 40 CFR 52.21(r)(6) and Minn. R ] The Permittee shall monitor the actual emissions of any regulated NSR pollutant that could increase as a result of the project and that were analyzed using the ATPA test, and the potential emissions of

12 Permit Expires: [month day, year] Page 12 of 148 Subject Item Sec.SI.Reqt SI des:si desc Requirement & Citation any regulated NSR pollutant that could increase as a result of the project and that were analyzed using potential emissions in the hybrid test. The Permittee shall calculate and maintain a record of the sum of the actual and potential (if the hybrid test was used in the analysis) emissions of the regulated pollutant, in tons per year on a calendar year basis, for a period of 5 years following resumption of regular operations after the change, or for a period of 10 years following resumption of regular operations after the change if the project increases the design capacity of or potential to emit of any unit associated with the project. [Minn. R , subps. 4-5, Title I Condition: 40 CFR 52.21(r)(6) and Minn. R ] The Permittee must submit a report to the Agency if the annual summed (actual, plus potential if used in hybrid test) emissions differ from the preconstruction projection and exceed the baseline actual emissions by a significant amount as listed at 40 CFR Section 52.21(b)(23). Such report shall be submitted to the Agency within 60 days after the end of the year in which the exceedances occur. The report shall contain: a. The name and ID number of the Facility, and the name and telephone number of the Facility contact person. b. The annual emissions (actual, plus potential if any part of the project was analyzed using the hybrid test) for each pollutant for which the preconstruction projection and significant emissions increase are exceeded c. Any other information, such as an explanation as to why the summed emissions differ from the preconstruction projection. [Minn. R , subps. 4-5, Title I Condition: 40 CFR 52.21(r)(6) and Minn. R ] For any project which does not include any EUSGU, the Permittee must submit a report to the Agency if the annual summed (actual, plus potential used in hybrid test) emissions differ from the preconstruction projection and exceed the baseline actual emissions by a significant amount as listed at 40 CFR Section 52.21(b)(23). Such report shall be submitted to the Agency within 60 days after the end of the year in which the exceedances occur. The report shall contain: a. The name and ID number of the facility, and the name and telephone number of the facility contact person. b. The annual emissions (actual, plus potential if any part of the project was analyzed using the hybrid test) for each pollutant for which the preconstruction projection and significant emissions rate is exceeded. c. Any other information, such as an explanation as to why the summed emissions differ from the preconstruction projection. [Minn. R , subps. 4-5, Title I Condition: 40 CFR 52.21(r)(6) and Minn. R ] The Permittee shall comply with National Primary and Secondary Ambient Air Quality Standards, 40 CFR pt. 50, and the Minnesota Ambient Air Quality Standards, Minn. R to Compliance shall be demonstrated upon written request by the

13 Permit Expires: [month day, year] Page 13 of 148 Subject Item Sec.SI.Reqt SI des:si desc Requirement & Citation MPCA. [Minn. R , subp. 7(A), 7(L), & 7(M), Minn. R , subp. 4, Minn. R , subps. 1-2, Minn. R , Minn. Stat , subd. 4a, Minn. Stat , subd. 9] Circumvention: Do not install or use a device or means that conceals or dilutes emissions, which would otherwise violate a federal or state air pollution control rule, without reducing the total amount of pollutant emitted. [Minn. R ] Air Pollution Control Equipment: Operate all pollution control equipment whenever the corresponding process equipment and emission units are operated. [Minn. R , subp. 16(J), Minn. R , subp. 2] Operation and Maintenance Plan: Retain at the stationary source an operation and maintenance plan for all air pollution control equipment. At a minimum, the O & M plan shall identify all air pollution control equipment and control practices and shall include a preventative maintenance program for the equipment and practices, a description of (the minimum but not necessarily the only) corrective actions to be taken to restore the equipment and practices to proper operation to meet applicable permit conditions, a description of the employee training program for proper operation and maintenance of the control equipment and practices, and the records kept to demonstrate plan implementation. [Minn. R , subp. 14, Minn. R , subp. 16(J)] Operation Changes: In any shutdown, breakdown, or deviation the Permittee shall immediately take all practical steps to modify operations to reduce the emission of any regulated air pollutant. The Commissioner may require feasible and practical modifications in the operation to reduce emissions of air pollutants. No emissions units that have an unreasonable shutdown or breakdown frequency of process or control equipment shall be permitted to operate. [Minn. R , subp. 4] Fugitive Emissions: Do not cause or permit the handling, use, transporting, or storage of any material in a manner which may allow avoidable amounts of particulate matter to become airborne. Comply with all other requirements listed in Minn. R [Minn. R ] Noise: The Permittee shall comply with the noise standards set forth in Minn. R to at all times during the operation of any emission units. This is a state only requirement and is not enforceable by the EPA Administrator or citizens under the Clean Air Act. [Minn. R ] Inspections: The Permittee shall comply with the inspection procedures and requirements as found in Minn. R , subp. 9(A). [Minn. R , subp. 9(A)] The Permittee shall comply with the General Conditions listed in Minn. R , subp. 16. [Minn. R , subp. 16] Performance Testing: Conduct all performance tests in accordance with Minn. R. ch unless otherwise noted in this permit. [Minn.

14 Permit Expires: [month day, year] Page 14 of 148 Subject Item Sec.SI.Reqt SI des:si desc Requirement & Citation R. ch. 7017] 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 , Minn. R , subps. 1-4, Minn. R , subps. 1-2] Limits set as a result of a performance test (conducted before or after permit issuance) apply until superseded as stated in the MPCA's Notice of Compliance letter granting preliminary approval. Preliminary approval is based on formal review of a subsequent performance test on the same unit as specified by Minn. R , subp. 3. The limit is final upon issuance of a permit amendment incorporating the change. [Minn. R , subp. 3] Monitoring Equipment Calibration - The Permittee shall either: 1. Calibrate or replace required monitoring equipment every 12 months; or 2. Calibrate at the frequency stated in the manufacturer's specifications. For each monitor, the Permittee shall maintain a record of all calibrations, including the date conducted, and any corrective action that resulted. The Permittee shall include the calibration frequencies, procedures, and manufacturer's specifications (if applicable) in the Operations and Maintenance Plan. Any requirements applying to continuous emission monitors are listed separately in this permit. [Minn. R , subp. 4(D)] Operation of Monitoring Equipment: Unless noted elsewhere in this permit, monitoring a process or control equipment connected to that process is not necessary during periods when the process is shutdown, or during checks of the monitoring systems, such as calibration checks and zero and span adjustments. If monitoring records are required, they should reflect any such periods of process shutdown or checks of the monitoring system. [Minn. R , subp. 4(D)] Recordkeeping: Retain all records at the stationary source, unless otherwise specified within this permit, for a period of five (5) years from the date of monitoring, sample, measurement, or report. Records which must be retained at this location include all calibration and maintenance records, all original recordings for continuous monitoring instrumentation, and copies of all reports required by the permit. Records must conform to the requirements listed in Minn. R , subp. 5(A). [Minn. R , subp. 5(C)] Recordkeeping: Maintain records describing any insignificant

15 Permit Expires: [month day, year] Page 15 of 148 Subject Item Sec.SI.Reqt SI des:si desc Requirement & Citation modifications (as required by Minn. R , subp. 3) or changes contravening permit terms (as required by Minn. R , subp. 2), including records of the emissions resulting from those changes. [Minn. R , subp. 5(B)] If the Permittee determines that no permit amendment or notification is required prior to making a change, the Permittee must retain records of all calculations required under Minn. R 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 , subp. 4] Shutdown Notifications: Notify the Commissioner at least 24 hours in advance of a planned shutdown of any control equipment or process equipment if the shutdown would cause any increase in the emissions of any regulated air pollutant. If the owner or operator does not have advance knowledge of the shutdown, notification shall be made to the Commissioner as soon as possible after the shutdown. However, notification is not required in the circumstances outlined in Items A, B and C of Minn. R , subp. 3. At the time of notification, the owner or operator shall inform the Commissioner of the cause of the shutdown and the estimated duration. The owner or operator shall notify the Commissioner when the shutdown is over. [Minn. R , subp. 3] Breakdown Notifications: Notify the Commissioner within 24 hours of a breakdown of more than one hour duration of any control equipment or process equipment if the breakdown causes any increase in the emissions of any regulated air pollutant. The 24- hour time period starts when the breakdown was discovered or reasonably should have been discovered by the owner or operator. However, notification is not required in the circumstances outlined in Items A, B and C of Minn. R , subp. 2. At the time of notification or as soon as possible thereafter, the owner or operator shall inform the Commissioner of the cause of the breakdown and the estimated duration. The owner or operator shall notify the Commissioner when the breakdown is over. [Minn. R , subp. 2] Notification of Deviations Endangering Human Health or the Environment: As soon as possible after discovery, notify the Commissioner or the state duty officer, either orally or by facsimile, of any deviation from permit conditions which could endanger human health or the environment. [Minn. R , subp. 1] Notification of Deviations Endangering Human Health or the Environment Report: Within 2 working days of discovery, notify the Commissioner in writing of any deviation from permit conditions

16 Permit Expires: [month day, year] Page 16 of 148 Subject Item Sec.SI.Reqt SI des:si desc Requirement & Citation which could endanger human health or the environment. Include the following information in this written description: 1. the cause of the deviation; 2. the exact dates of the period of the deviation, if the deviation has been corrected; 3. whether or not the deviation has been corrected; 4. the anticipated time by which the deviation is expected to be corrected, if not yet corrected; and 5. steps taken or planned to reduce, eliminate, and prevent reoccurrence of the deviation. [Minn. R , subp. 1] Application for Permit Amendment: If a permit amendment is needed, submit an application in accordance with the requirements of Minn. R through Minn. R Submittal dates vary, depending on the type of amendment needed. Upon adoption of a new or amended federal applicable requirement, and if there are more than 3 years remaining in the permit term, the Permittee shall file an application for an amendment within nine months of promulgation of the applicable requirement, pursuant to Minn. R , subp. 3. [Minn. R , subp. 3, Minn. R ] Extension Requests: The Permittee may apply for an Administrative Amendment to extend a deadline in a permit by no more than 120 days, provided the proposed deadline extension meets the requirements of Minn. R , subp. 1(H). Performance testing deadlines from the General Provisions of 40 CFR pt. 60 and pt. 63 are examples of deadlines for which the MPCA does not have authority to grant extensions and therefore do not meet the requirements of Minn. R , subp. 1(H). [Minn. R , subp. 1(H)] Emission Inventory Report: due on or before April 1 of each calendar year following permit issuance, to be submitted on a form approved by the Commissioner. [Minn. R ] Emission Fees: due 30 days after receipt of an MPCA bill. [Minn. R ] The Permittee must submit a Risk Management Plan (RMP) under 40 CFR pt. 68. Each owner or operator of a stationary source, at which a regulated substance is present above a threshold quantity in a process, shall design and implement an accidental release prevention program. An initial RMP must be submitted no later than the latest of the following dates: 1) June 21, 1999; 2) Three years after the date on which a regulated substance is first listed under 40 CFR Section ; or 3) The date on which a regulated substance is first present above a threshold quantity in a process. A full update and resubmission of the RMP is required at least once every five years. The five-year anniversary date is reset whenever the Permittee fully updates and resubmits their RMP. Submit RMPs to the Risk Management Plan Reporting Center, P.O. Box 1515, Lanham-Seabrook, Maryland RMP information may be obtained at or by calling

17 Permit Expires: [month day, year] Page 17 of 148 Subject Item Sec.SI.Reqt SI des:si desc Requirement & Citation [40 CFR pt. 68] Modeled Parameters for PM10: The parameters used in PM10 modeling for permit number are listed in Appendix B of this permit. The parameters describe the operation of the facility at maximum permitted capacity. The purpose of listing the parameters in the appendix is to provide a benchmark for future changes. [Minn. R , subp. 7(A), 7(L), & 7(M), Minn. R , subp. 4, Minn. R , subps. 1-2, Minn. R , Minn. Stat , subd. 4a, Minn. Stat , subd. 9] Equivalent or Better Dispersion (EBD) Modeling Triggers (Modeling Not Required) for PM10: Changes that do not require a permit amendment or that require a minor or administrative permit amendment do not trigger the EBD Modeling Submittal requirement. The Permittee shall keep updated records on site of all modeled PM10 parameters and emission rates listed in Appendix B. The Permittee shall submit any changes to modeled PM10 parameters and emission rates with the next required modeling submittal. [Minn. R , subp. 7(A), 7(L), & 7(M), Minn. R , subp. 4, Minn. R , subps. 1-2, Minn. R , Minn. Stat , subd. 4a, Minn. Stat , subd. 9] EBD Modeling Triggers (Modeling Required) for PM10: Changes that require, or would require, a moderate or major permit amendment due to an increase in PM10 emissions and affect any modeled PM10 parameter or emission rate listed in Appendix B, or an addition to the information documented in Appendix B, trigger the EBD Remodeling Submittal requirement. The Permittee shall include previously made changes to modeled PM10 parameters and emission rates listed in Appendix B that did not previously trigger the EBD Modeling Submittal requirement with this modeling submittal. [Minn. R , subp. 7(A), 7(L), & 7(M), Minn. R , subp. 4, Minn. R , subps. 1-2, Minn. R , Minn. Stat , subd. 4a, Minn. Stat , subd. 9] EBD Modeling Submittal for PM10: For changes meeting the criteria in the EBD Modeling Triggers (Modeling Required) requirement, the Permittee shall submit an EBD modeling submittal in accordance with the current version of the MPCA Air Dispersion Modeling Guidance and shall wait for written approval (for major amendments, in the form of an issued permit amendment; for moderate amendments, in the form of a construction authorization letter) before making such changes. [Minn. R , subp. 7(A), 7(L), & 7(M), Minn. R , subp. 4, Minn. R , subps. 1-2, Minn. R , Minn. Stat , subd. 4a, Minn. Stat , subd. 9] EBD Modeling Submittal Content for PM10: The information submitted must include, for stack and vent sources, source emission rate, location, height, diameters, exit velocity, exit temperature, discharge direction, use of rain caps or rain hats, and, if applicable,

18 Permit Expires: [month day, year] Page 18 of 148 Subject Item Sec.SI.Reqt SI des:si desc Requirement & Citation locations and dimensions of nearby buildings. For non-stack/vent sources, this includes the source emission rate, location, size and shape, release height, and, if applicable, any emission rate scalars, and the initial lateral dimensions and initial vertical dimensions and adjacent building heights. [Minn. R , subp. 7(A), 7(L), & 7(M), Minn. R , subp. 4, Minn. R , subps. 1-2, Minn. R , Minn. Stat , subd. 4a, Minn. Stat , subd. 9] Outdated EBD Baseline Modeling for PM10: Prior to conducting the EBD analysis, the Permittee shall use the current version of the MPCA Air Dispersion Modeling Guidance to determine if the Baseline Modeling (the most recent refined modeling demonstration) is outdated. If the Baseline Modeling is outdated, the Permittee shall update the Baseline Modeling to be consistent with the current version of the MPCA Air Dispersion Modeling Guidance. The updated modeling will become the new Baseline Modeling. This requirement does not require the Permittee to complete a new refined modeling demonstration using the revisions made for the EBD demonstration. [Minn. R , subp. 7(A), 7(L), & 7(M), Minn. R , subp. 4, Minn. R , subps. 1-2, Minn. R , Minn. Stat , subd. 4a, Minn. Stat , subd. 9] EBD Modeling Results for PM10: The dispersion characteristics due to the revisions of the information in Appendix B must be equivalent to or better than the dispersion characteristics modeled in The Permittee shall demonstrate this equivalency in the proposal. [Minn. R , subp. 7(A), 7(L), & 7(M), Minn. R , subp. 4, Minn. R , subps. 1-2, Minn. R , Minn. Stat , subd. 4a, Minn. Stat , subd. 9] Computer Dispersion Modeling Triggers for PM10: The Permittee shall conduct a refined remodeling analysis in accordance with the Computer Dispersion Modeling requirements of this permit and the current version of the MPCA Air Dispersion Modeling Guidance if: (1) the results of the EBD modeling analysis do not demonstrate equivalent or better dispersion characteristics; (2) a conclusion cannot readily be made about the dispersion, or (3) the criteria in the EBD Modeling Triggers requirement are met and the Permittee has previously conducted three successive EBD analyses using the same Baseline Modeling. [Minn. R , subp. 7(A), 7(L), & 7(M), Minn. R , subp. 2, Minn. Stat , subd. 4a, Minn. Stat , subd. 9] Computer Dispersion Modeling Protocol: due 180 days after receipt of written MPCA request for PM10 refined modeling. The Permittee shall submit a Computer Dispersion Modeling Protocol that is complete and approvable by MPCA by the deadline in this requirement. This protocol will describe the proposed modeling methodology and input data, in accordance with the current version of the MPCA Air Dispersion Modeling Guidance. [Minn. R.

19 Permit Expires: [month day, year] Page 19 of 148 Subject Item Sec.SI.Reqt SI des:si desc Requirement & Citation , subp. 7(A), 7(L), & 7(M), Minn. R , subp. 2, Minn. Stat , subd. 4a, Minn. Stat , subd. 9] Computer Dispersion Modeling Protocol: due 60 days after receipt of written MPCA request for revisions to the submitted protocol for PM10 modeling. [Minn. R , subp. 7(A), 7(L), & 7(M), Minn. R , subp. 2, Minn. Stat , subd. 4a, Minn. Stat , subd. 9] Computer Dispersion Modeling Results: due 180 days after receipt of written MPCA approval of Computer Dispersion Modeling Protocol for PM10. The Permittee shall submit a final Computer Dispersion Modeling Report that is complete and approvable by MPCA by the deadline in this requirement. The submittal shall adhere to the current version of the MPCA Air Dispersion Modeling Guidance and the approved Computer Dispersion Modeling Protocol. [Minn. R , subp. 7(A), 7(L), & 7(M), Minn. R , subp. 2, Minn. Stat , subd. 4a, Minn. Stat , subd. 9] COMG 3 GP013 2 % or greater moisture Mold Sand Moisture Content >= 2 percent by weight. [Title I Condition: Avoid major modification under 40 CFR 52.21(b)(2)and Minn. R ] Daily Recordkeeping: Each day of operation, record the minimum (worst case) moisture content (percent by weight) of each batch of green mold sand after mixing. This shall be recorded in written or electronic usage logs. Maintain the records on site for 5 years from the date of recording. [Minn. R , subps. 4-5, Title I Condition: Avoid major modification under 40 CFR 52.21(b)(2)& Minn. R ] COMG 4 GP012 Direct Heating Equipment Fuel type: Natural gas or propane backup fuel only, by design. [Minn. R , subp. 35a] Opacity <= 20 percent opacity except for one six-minute period per hour of not more than 60 percent opacity. [Minn. R , subp. 1(A)(2)] Total Particulate Matter <= 0.30 grains per dry standard cubic foot of exhaust gas unless required to further reduce emissions to comply with the less stringent limit of either Minn. R or Minn. R [Minn. R , subp. 1(A)(1)] COMG 5 GP001 Core Dip Tanks BACT Limits The Permittee shall limit VOC-content of core dipping mixture: Volatile Organic Compounds <= 5.0 percent by weight of core dipping mixture. VOC contents for each VOC-containing material

20 Permit Expires: [month day, year] Page 20 of 148 Subject Item Sec.SI.Reqt SI des:si desc Requirement & Citation shall be determined as described under the Material Content requirement in this section. [Title I Condition: 40 CFR 52.21(j)(BACT) and Minn. R ] Core Dipping Mixture Material Usage <= 1066 tons per year 12- month rolling sum. [Title I Condition: 40 CFR 52.21(j)(BACT) & Minn. R ] Daily Recordkeeping. On each day of operation, the Permittee shall calculate, record, and maintain the following, based on written or electronic usage logs. 1. the total quantity of VOC-containing core dipping mixture (in lbs). 2. the VOC content of each VOC-containing core dipping mixture (percent by weight). [Minn. R , subps. 4-5, Title I Condition: 40 CFR 52.21(j)(BACT) and Minn. R ] Volatile Organic Compounds: Monthly Recordkeeping. By the 28th of the month, the Permittee shall calculate and record the following: 1) The total usage of core dipping mixtures for the previous calendar month using the daily usage records; and 2) The 12-month rolling sum of core dipping mixtures for the previous 12-month period by summing the monthly core dipping mixture data for the previous 12 months. [Minn. R , subps. 4-5] Material Content. VOC contents in core dipping mixture shall be determined by the Safety Data Sheet (SDS) or the Material Safety Data Sheet (MSDS) provided by the supplier for each material used. If a material content range is given on the SDS or the MSDS, the highest number in the range shall be used in all compliance calculations. If information is provided in the Regulatory Section of the SDS, the highest number in the range of that section may be used. Other alternative methods approved by the MPCA may be used to determine the VOC contents. The Commissioner reserves the right to require the Permittee to determine the VOC contents of any material, according to EPA or ASTM reference methods. If an EPA or ASTM reference method is used for material content determination, the data obtained shall supersede the SDS or the MSDS. [Minn. R , subps. 4-5] Maximum Contents of Materials: The Permittee assumed certain worst-case contents of materials when determining the short term potential to emit of units in COMG 5. These assumptions are listed in Appendix E of this permit. Changing to a material that has a higher content of any of the given pollutants is considered a change in method of operation that must be evaluated under Minn. R , subp. 3 to determine if a permit amendment or notification is required under Minn. R [Minn. R , subp. 35a] COMG 6 GP010 Units Subject to IPER Opacity <= 20 percent opacity. [Minn. R , subp. 1(B)]

21 Permit Expires: [month day, year] Page 21 of 148 Subject Item Sec.SI.Reqt SI des:si desc Requirement & Citation Total Particulate Matter <= 0.30 grains per dry standard cubic foot of exhaust gas unless required to further reduce emissions to comply with the less stringent limit of either Minn. R or Minn. R [Minn. R , subp. 1(A)] COMG 7 GP011 HAP's-Limit The Permittee shall limit emissions of HAPs - Total <= 22.5 tons per year 12-month rolling sum to be calculated by the 28th day of each month for the previous 12-month period. [Title I Condition: Avoid major source under 40 CFR 63.2] The Permittee shall limit emissions of HAPs - Single <= 9.0 tons per year 12-month rolling sum to be calculated by the 28th day of each month for the previous 12-month period. [Title I Condition: Avoid major source under 40 CFR 63.2] HAPs: Monthly Recordkeeping. By the 28th of the month, the Permittee shall calculate and record the following using the formulas specified in this permit: 1) The individual HAP (IHAP) emissions for the previous month using the formula for IHAP specified below; 2) The total HAP emissions for the previous month by summing the IHAP values calculated for the previous month; 3) The 12-month rolling sum each individual HAP (IHAP) emissions for the previous 12-month period by summing the monthly emissions calculated for each IHAP for the previous 12 months; and 4) The 12-month rolling sum of total HAP emissions for the previous 12-month period by summing the total HAP emissions calculated for each of the previous 12 months. IHAP = IH(c) + IH(23) + IH(10) + IH(7) Where: IHAP = the total emissions of the individual HAP for the previous month, in tons IH(c) = the emissions of the individual HAP from core making for the previous month, in tons, calculated as described under Subject Item COMG 12. IH(23) = the emissions of the individual HAP that occurred at EQUI 23 during the previous month, in tons, calculated as described under Subject Item EQUI 23. IH(10) = the emissions of the individual HAP that occurred at EQUI 10 during the previous month, in tons, calculated as described under Subject Item EQUI 10. IH(7) = the emissions of the individual HAP that occurred at EQUI 7 during the previous month, in tons, calculated as described under Subject Item EQUI 7. [Minn. R , subps. 4-5] COMG 8 GP CFR pt. 63, subp. ZZZZZ This facility meets the definition of an existing iron and steel foundry. The Permittee shall comply with the standards in 40 CFR

22 Permit Expires: [month day, year] Page 22 of 148 Subject Item Sec.SI.Reqt SI des:si desc Requirement & Citation pt. 63, subp. ZZZZZ. [40 CFR (a)(b)(1), 40 CFR (a)(1)(2), 40 CFR (d)(1)(i), 40 CFR ] Following the initial determination for an existing affected source required in (f), (1) Beginning January 1, 2010, if the annual metal melt production of your small foundry exceeds 20,000 tons during the preceding calendar year, you must submit a notification of foundry reclassification to the Administrator within 30 days and comply with the requirements in paragraphs (d)(1)(i) or (ii) of this section, as applicable. (i) If your small foundry has never been classified as a large foundry, you must comply with the requirements for a large foundry no later than 2 years after the date of your foundry's notification that the annual metal melt production exceeded 20,000 tons. [40 CFR (a)(b)(1), 40 CFR (d)(1)(i), 40 CFR ] For each segregated metallic scrap storage area, bin or pile, the Permittee must comply with the following materials acquisition requirements. The Permittee must keep a copy of the material specifications onsite and readily available to all personnel with material acquisition duties, and provide a copy to each scrap provider. Restricted metallic scrap. The Permittee must prepare and operate at all times according to written material specifications for the purchase and use of only metal ingots, pig iron, slitter, or other materials that do not include post-consumer automotive body scrap, post-consumer engine blocks, post-consumer oil filters, oily turnings, lead components, chlorinated plastics, or free liquids. "Free liquids" is defined as material that fails the paint filter test by EPA Method 9095B, "Paint Filter Liquids Test" (revision 2), November 2004 (incorporated by reference-see 40 CFR Section 63.14). The requirements for no free liquids do not apply if the Permittee can demonstrate that the free liquid is water that resulted from scrap exposure to rain. [40 CFR (a)(1)] The Permittee must prepare and operate at all times according to written material for the purchase and use of only iron and steel scrap that has been depleted (to the extent practicable) of organics and HAP metals in the charge materials used by the iron and steel foundry. The materials specifications must include at a minimum the information specified in 40 CFR Section (a)(2)(i) or 40 CFR Section (a)(ii). [40 CFR (a)(2)] Except as provided in 40 CFR Section (a)(2)(ii), specifications for metallic scrap materials charged to a scrap perheater or metal melting furnace to be depleted (to the extent practicable) of the presence of used oil filters, chlorinated plastic parts, accessible lead-containing components (such as batteries and wheel weights), and a program to ensure the scrap materials are drained of free liquids. [40 CFR (a)(2)(i)] For scrap charged to a cupola metal melting furnace that is equipped with an afterburner, specifications for metallic scrap