air emission permit no. 10900102-004 is issued to geotek€¦ · air emission permit no. 10900102 -...

TDD (for hearing and speech impaired only): (651) 282-5332 Printed on recycled paper containing at least 10% fibers from paper recycled by consumers

AIR EMISSION PERMIT NO. 10900102 - 004 Administrative Amendment

IS ISSUED TO

Geotek Acquisition Co LLC

GEOTEK

1421 2nd Avenue Northwest Stewartville, Olmsted County, MN 55976

The emission units, control equipment and emission stacks at the stationary source authorized in this permit amendment are as described in the Permit Applications Table below. This permit amendment supersedes Air Emission Permit No. 10900102-003 and authorizes the Permittee to operate the stationary source at the address listed above unless otherwise noted in Table A. The Permittee must comply with all the conditions of the permit. Any changes or modifications to the stationary source must be performed in compliance with Minn. R. 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 State Implementation Plan 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. Permit Type: Federal; Pt 70/Limits to Avoid NSR Operating Permit Issue Date: April 21, 2008 Administrative Amendment Issue Date: December 23, 2009 Expiration Date: April 21, 2013

– Title I Conditions do not expire. Don Smith, P.E., Manager Air Quality Permits Section Industrial Division for Paul Eger Commissioner Minnesota Pollution Control Agency

Permit Applications Table

Permit Type Application Date Permit Action

Total Facility Operating Permit – Reissuance, Supplemental Submittal #1

August 1, 2007, December 14, 2007 003

Administrative Amendment January 30, 2009 004

TABLE OF CONTENTS

Notice to the Permittee Permit Shield Facility Description Amendment Description Table A: Limits and Other Requirements Table B: Submittals Table C: Not used in this permit Appendix I: Insignificant Activities Appendix II: Emissions Factors for VOC Calculations Appendix III: Maximum Content of Materials, Coating Appendix IV: Part 63, Subpart PPPP Compliance Equations

NOTICE TO THE PERMITTEE: Your stationary source may be subject to the requirements of the Minnesota Pollution Control Agency’s (MPCA) solid waste, hazardous waste, and water quality programs. If you wish to obtain information on these programs, including information on obtaining any required permits, please contact the MPCA general information number at: Metro Area 651-296-6300 Outside Metro Area 1-800-657-3864 TTY 651-282-5332 The rules governing these programs are contained in Minn. R. chs. 7000-7105. Written questions may be sent to: Minnesota Pollution Control Agency, 520 Lafayette Road North, St. Paul, Minnesota 55155-4194. Questions about this air emission permit or about air quality requirements can also be directed to the telephone numbers and address listed above. PERMIT SHIELD: Subject to the limitations in Minn. R. 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.

FACILITY DESCRIPTION: Geotek (Facility) is a manufacturer of fiberglass reinforced fencing products. The Facility consists of a pultrusion line, coating, and various cutting operations. The Facility also has several activities that qualify as insignificant activities under Minn. R. 7007.1300, subp. 3 (see Appendix I to the permit). The Facility is currently a minor source under the New Source Review (NSR) program (40 CFR § 52.21). However, the Facility is a major source under the federal operation permits program (40 CFR pt. 70) and the National Emissions Standards for Hazardous Air Pollutants (NESHAPs, 40 CFR pt. 63). The permit contains limits that keep the Facility a minor source under NSR as well as requirements to control Particulate Matter (PM)/PM smaller than 10 microns emissions from the spray booth and cutting operations. AMENDMENT DESCRIPTION: PERMIT ACTION - 004 This permit action is an administrative amendment for a change in ownership and operator for the facility. The new owner and operator is Geotek Acquisition Company LLC. The name of the facility has changed from Geotek, Inc. to Geotek.

TABLE A: LIMITS AND OTHER REQUIREMENTS 12/23/09

Geotek

10900102 - 004

Facility Name:

Permit Number:

A-1

Table A contains limits and other requirements with which your facility must comply. The limits are located in the first column ofthe table (What To do). The limits can be emission limits or operational limits. This column also contains the actions that you musttake and the records you must keep to show that you are complying with the limits. The second column of Table A (Why to do it)lists the regulatory basis for these limits. Appendices included as conditions of your permit are listed in Table A under total facilityrequirements.

Subject Item: Total Facility

What to do Why to do itSITE-SPECIFIC REQUIREMENTS hdr

This permit establishes limits on the facility to keep it a minor source under NewSource Review. The Permittee cannot make any change at the source that wouldmake the source a major source under New Source Review until a permitamendment has been issued. This includes changes that might otherwise qualifyas insignificant modifications and minor or moderate amendments.

Title I Condition: Limit to avoid classification as majorsource or modification under 40 CFR Section 52.21and Minn. R. 7007.3000

Permit Appendices: This permit contains four appendices as listed in the permitTable of Contents. The Permittee shall comply with all requirements contained inthe appendices.

Minn. R. 7007.0800, subp. 2

Equipment Labeling and Inventory: The Permittee shall permanently affix a uniquenumber to each emissions unit for tracking purposes. The numbers shall correlatethe unit to the appropriate EU and GP numbers used in this permit. The numbercan be affixed by placard, stencil, or other means. The number shall be maintainedso that it is readable and visible at all times from a safe distance.

The Permittee shall maintain a written list of all emissions units on site. The listshall correlate the units to the numbers used in this permit (EU, GP, and CE) andshall include the data on MPCA permit application forms GI-04, GI-05A, GI-05B,and GI-05C. The Permittee shall update the list to include any new, replaced, ormodified equipment prior to making the change.

Minn. R. 7007.0800, subp. 2

OPERATIONAL REQUIREMENTS hdr

The Permittee shall comply with National Primary and Secondary Ambient AirQuality Standards, 40 CFR pt. 50, and the Minnesota Ambient Air QualityStandards, Minn. R. 7009.0010 to 7009.0080. Compliance shall be demonstratedupon written request by the MPCA.

40 CFR pt. 50; Minn. Stat. Section 116.07, subds. 4a &9; Minn. R. 7007.0100, subps. 7A, 7L & 7M; Minn. R.7007.0800, subps. 1, 2 & 4; Minn. R.7009.0010-7009.0080

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

Minn. R. 7011.0020

Air Pollution Control Equipment: Operate all pollution control equipment wheneverthe corresponding process equipment and emission units are operated, unlessotherwise noted in Table A.

Minn. R. 7007.0800, subp. 2; Minn. R. 7007.0800,subp. 16(J)

Operation and Maintenance Plan: Retain at the stationary source an operation andmaintenance plan for all air pollution control equipment. At a minimum, the O & Mplan shall identify all air pollution control equipment and control practices and shallinclude a preventative maintenance program for the equipment and practices, adescription of (the minimum but not necessarily the only) corrective actions to betaken to restore the equipment and practices to proper operation to meet applicablepermit conditions, a description of the employee training program for properoperation and maintenance of the control equipment and practices, and the recordskept to demonstrate plan implementation.

Minn. R. 7007.0800, subps. 14 and 16(J)

Operation Changes: In any shutdown, breakdown, or deviation the Permittee shallimmediately take all practical steps to modify operations to reduce the emission ofany regulated air pollutant. The Commissioner may require feasible and practicalmodifications in the operation to reduce emissions of air pollutants. No emissionsunits that have an unreasonable shutdown or breakdown frequency of process orcontrol equipment shall be permitted to operate.

Minn. R. 7019.1000, subp. 4

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

Minn. R. 7011.0150

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 orcitizens under the Clean Air Act.

Minn. R. 7030.0010 - 7030.0080

Inspections: The Permittee shall comply with the inspection procedures andrequirements as found in Minn. R. 7007.0800, subp. 9(A).

Minn. R. 7007.0800, subp. 9(A)

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

Minn. R. 7007.0800, subp. 16


Geotek

10900102 - 004

Facility Name:

Permit Number:

A-2

MONITORING REQUIREMENTS hdr

Monitoring Equipment Calibration: Annually calibrate all required monitoringequipment (any requirements applying to continuous emission monitors are listedseparately in this permit).

Minn. R. 7007.0800, subp. 4(D)

Operation of Monitoring Equipment: Unless otherwise noted in Tables A, B, and/orC, monitoring a process or control equipment connected to that process is notnecessary during periods when the process is shutdown, or during checks of themonitoring systems, such as calibration checks and zero and span adjustments. Ifmonitoring records are required, they should reflect any such periods of processshutdown or checks of the monitoring system.

Minn. R. 7007.0800, subp. 4(D)

RECORDKEEPING hdr

Recordkeeping: Retain all records at the stationary source for a period of five (5)years from the date of monitoring, sample, measurement, or report. Records whichmust be retained at this location include all calibration and maintenance records, alloriginal recordings for continuous monitoring instrumentation, and copies of allreports required by the permit. Records must conform to the requirements listed inMinn. R. 7007.0800, subp. 5(A).

Minn. R. 7007.0800, subp. 5(C)

Recordkeeping: Maintain records describing any insignificant modifications (asrequired by Minn. R. 7007.1250, subp. 3) or changes contravening permit terms (asrequired by Minn. R. 7007.1350, subp. 2), including records of the emissionsresulting from those changes.

Minn. R. 7007.0800, subp. 5(B)

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

Minn. R. 7007.1200, subp. 4

REPORTING/SUBMITTALS hdr

Shutdown Notifications: Notify the Commissioner at least 24 hours in advance of aplanned shutdown of any control equipment or process equipment if the shutdownwould cause any increase in the emissions of any regulated air pollutant. If theowner or operator does not have advance knowledge of the shutdown, notificationshall be made to the Commissioner as soon as possible after the shutdown.However, notification is not required in the circumstances outlined in Items A, Band C of Minn. R. 7019.1000, subp. 3.

At the time of notification, the owner or operator shall inform the Commissioner ofthe cause of the shutdown and the estimated duration. The owner or operator shallnotify the Commissioner when the shutdown is over.

Minn. R. 7019.1000, subp. 3

Breakdown Notifications: Notify the Commissioner within 24 hours of a breakdownof more than one hour duration of any control equipment or process equipment ifthe breakdown causes any increase in the emissions of any regulated air pollutant.The 24-hour time period starts when the breakdown was discovered or reasonablyshould have been discovered by the owner or operator. However, notification is notrequired 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 operatorshall inform the Commissioner of the cause of the breakdown and the estimatedduration. The owner or operator shall notify the Commissioner when the breakdownis over.

Minn. R. 7019.1000, subp. 2

Notification of Deviations Endangering Human Health or the Environment: As soonas possible after discovery, notify the Commissioner or the state duty officer, eitherorally or by facsimile, of any deviation from permit conditions which could endangerhuman health or the environment.

Minn. R. 7019.1000, subp. 1

Notification of Deviations Endangering Human Health or the Environment Report:Within 2 working days of discovery, notify the Commissioner in writing of anydeviation from permit conditions which could endanger human health or theenvironment. 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 yetcorrected; and5. steps taken or planned to reduce, eliminate, and prevent reoccurrence of thedeviation.

Minn. R. 7019.1000, subp. 1


Geotek

10900102 - 004

Facility Name:

Permit Number:

A-3

For changes that do not require a permit amendment:- The Permittee shall submit a Part 1 MACT application within 30 days of startup ofany 112(j) affected source. The application shall meet the requirements of 40 CFRSection 63.53(a).- The Permittee shall submit a Part 2 MACT application within 90 days of startup ofany 112(j) affected source. The application shall meet the requirements of 40 CFRSection 63.53(b).112(j) affected source is defined in 40 CFR Section 63.51. As of permit issuance,112(j) affected sources include industrial, commercial, and institutional boilers andprocess heaters; brick and structural clay products manufacturing; clay ceramicsmanufacturing.

40 CFR Section 63.52(b)(1) and 63.52(e)(1)

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

Minn. R. 7007.1150 through Minn. R. 7007.1500

Extension Requests: The Permittee may apply for an Administrative Amendment toextend a deadline in a permit by no more than 120 days, provided the proposeddeadline extension meets the requirements of Minn. R. 7007.1400, subp. 1(H).

Minn. R. 7007.1400, subp. 1(H)

Emission Inventory Report: due on or before April 1 of each calendar year following4/21/2008. The Permittee shall submit this on a form approved by theCommissioner.

Minn. R. 7019.3000 through Minn. R. 7019.3100

Emission Fees: due 60 days after receipt of an MPCA bill. Minn. R. 7002.0005 through Minn. R. 7002.0095


Geotek

10900102 - 004

Facility Name:

Permit Number:

A-4

Subject Item: GP 001 VOC Limit

Associated Items: EU 001 Pultrusion Line

EU 002 Mix Room

EU 003 Solvent Booth (Parts Washer)

EU 004 Paint Booth

TK 001 Polyester Resin

TK 002 Styrene


What to do Why to do itUnless otherwise noted, the requirements of GP 001 apply separately to each unitin GP 001.

Minn. R. 7007.0800, subp. 2

EMISSION AND OPERATIONAL LIMITS hdr

Volatile Organic Compounds: less than or equal to 90 tons/year using 12-monthRolling Sum to be calculated by the 15th day of each month for the previous12-month period.

All noncombustion VOC-emitting equipment at the Facility is subject to this limitexcept for those listed in Appendix I of this permit. If the Permittee replaces anyexisting VOC-emitting equipment, adds new VOC-emitting equipment, or modifiesthe existing equipment, such equipment is subject to this permit limit as well as allof the requirements of this permit. Prior to making such a change, the Permitteeshall apply for and obtain the appropriate permit amendment, as applicable. ThePermittee is not required to complete VOC calculations described in Minn. R.7007.1200, subp. 2.

A permit amendment will still be needed regardless of the emissions increase if thechange will be subject to a new applicable requirement or requires revisions to thelimits or monitoring and recordkeeping in this permit.


Total Particulate Matter: less than or equal to 0.3 grains/dry standard cubic foot ofexhaust gas unless required to further reduce emissions to comply with the lessstringent limit of either Minn. R. 7011.0730 or Minn. R. 7011.0735.

Minn. R. 7011.0715, subp. 1(A)

Opacity: less than or equal to 20 percent opacity Minn. R. 7011.0715, subp. 1(B)

MONITORING AND RECORDKEEPING hdr

Daily Recordkeeping. On each day of operation, the Permittee shall calculate,record, and maintain the total quantity of all coatings and other VOC-containingmaterials used at the facility. This shall be based on written usage logs and/ordelivery records.

Title I Condition: Limit to avoid classification as majorsource or modification under 40 CFR Section 52.21and Minn. R. 7007.3000; Minn. R. 7007.0800, subp. 4and 5

Monthly Recordkeeping - VOC Emissions. By the 15th of each month, thePermittee shall calculate and record the following:1. The total quantity of each VOC-containing material used for the previous month;2. The styrene content and VOC content of each VOC-containing material used inthe previous month, as determined by the Material Content requirement of thissection;3. The VOC emissions for the previous month using the formulas specified in thispermit; and4. The 12-month rolling sum of VOC emissions for the previous 12 months.

Minn. R. 7007.0800, subps. 4 & 5


Geotek

10900102 - 004

Facility Name:

Permit Number:

A-5

Monthly Calculations - VOC Emissions

The Permittee shall calculate VOC emissions using the following equations:

VOC = VOC(P) + VOC(O) - R (equation 1)

where:

VOC = monthly VOC emissions, in tons/month

VOC(P) = VOC emissions from the pultrusion line, including the resin bath andflowcoater, in tons/month

VOC(O) = VOC emissions from all other processes, including but not limited to thesolvent booth, paint booth, and mixer, in tons/month

R = (optional) quantity of VOC shipped offsite for recycling, in tons/month. Mustconform to the requirements for "Waste Credit" below.

Minn. R. 7007.0800, subps. 4 & 5

Monthly Calculations - VOC Emissions, continued

VOC(P) = VOC(B) + VOC(F) (equation 2)

VOC(B) = VOC emissions from the resin bath on the pultrusion line= {[MAT1 x EF(S1)] + [MAT2 x EF(S2)] + [MAT3 x EF(S3)].....} x (1-EN) + {[MAT1 xEF(V1)] + [MAT2 x EF(V2)] + [MAT3 x EF(V3)] + ....} (equation 3)

VOC(F) = VOC emissions from the flowcoater on the pultrusion line={MAT1 x EF(V1)} + {MAT2 x EF(V2)} + {MAT3 x EF(V3)} ... (equation 4)

VOC(O) = {MAT1 x [EF(V1) + EF(M1)]} + {MAT2 x [EF(V2) + EF(M2)]} + {MAT3 x[EF(V3) + EF(M3)]} + ... (equation 5)

Minn. R. 7007.0800, subps. 4 & 5 (continued fromabove)

Monthly Calculations - VOC Emissions, continued

where for each operation:

EF(M#) = the emission factor for VOC (including styrene) from the resin mixingprocess, from Appendix II of this permit, in tons per ton of material used.

EF(S#) = the emission factor for styrene for pultrusion from Appendix II of thispermit, in tons per ton of material used.

EF(V#) = the emission factor for VOC other than styrene for pultrusion or for totalVOC (including styrene ) for all other operations, from Appendix II of this permit, intons per ton of material used.

MAT# = amount of each VOC-containing material used, in tons/month

EN = Enclosure credit for styrene emissions in the pultrusion bath, 60% or 0.60

The 12-month rolling sum shall be calculated by summing the total VOC emissionsfrom the previous 12 months.

Minn. R. 7007.0800, subps. 4 & 5 (continued fromabove)

Material Content: VOC and HAP contents in materials shall be determined by theMaterial Safety Data Sheet (MSDS) provided by the supplier for each materialused. If a material content range is given on the MSDS, the highest number in therange shall be used in all compliance calculations. Other alternative methodsapproved by the MPCA may be used to determine the VOC and HAP contents. TheCommissioner reserves the right to require the Permittee to determine the VOCand HAP 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 MSDS.

Minn. R. 7007.0800, subps. 4 & 5

Waste Credit: If the Permittee elects to obtain credit for VOC shipped in wastematerials, the Permittee shall either use item 1 or 2 to determine the VOC contentfor each credited shipment.1) The Permittee shall analyze a composite sample of each waste shipment todetermine the weight content of VOC, excluding water.2) The Permittee may use supplier data for raw materials to determine the VOCcontent of each waste shipment, using the same content data used to determinethe content of raw materials. If the waste contains several materials, the content ofmixed waste shall be assumed to be the lowest VOC content of any of thematerials.

Minn. R. 7007.0800, subps. 4 & 5


Geotek

10900102 - 004

Facility Name:

Permit Number:

A-6

Maximum Contents of Materials: The Permittee assumed certain worst-casecontents of materials when determining the annual and short term potential to emitof units in GP001. These assumptions are listed in Appendix III of this permit.Changing to a material that has a higher content of any of the given pollutants isconsidered a change in method of operation that must be evaluated under Minn. R.7007.1200, subp. 3 to determine if a permit amendment or notification is requiredunder Minn. R. 7007.1150.

Minn. R. 7005.0100, subp. 35a


Geotek

10900102 - 004

Facility Name:

Permit Number:

A-7

Subject Item: GP 004 Cutting/Sanding Sources

Associated Items: EU 005 Pultrustion Saw

EU 006 Rod Pointer

EU 008 Multihead Drill

EU 009 Bridgeport

EU 010 Chop Saw

EU 011 Hand Pointer

EU 012 Soda Blaster

EU 013 Dual Angle Drill

EU 017 Crossarm Drill

What to do Why to do itUnless otherwise noted, the requirements of GP 004 apply separately to each unitin GP 004.

Minn. R. 7007.0800, subp. 2

The Permittee shall vent emissions from all cutting and sanding units, includingexisting, modified, or new cutting and sanding units, to control equipment meetingthe requirements of CE 006.

Title I Condition: Limit to avoid major source ormodification classification under 40 CFR Section 52.21and Minn. R. 7007.3000

Total Particulate Matter: less than or equal to 0.3 grains/dry standard cubic foot ofexhaust gas unless required to further reduce emissions to comply with the lessstringent limit of either Minn. R. 7011.0730 or Minn. R. 7011.0735.

Minn. R. 7011.0715, subp. 1(A)

Opacity: less than or equal to 20 percent opacity Minn. R. 7011.0715, subp. 1(B)


Geotek

10900102 - 004

Facility Name:

Permit Number:

A-8

Subject Item: GP 005 Equipment Subject to 40 CFR pt. 63, subp. WWWW


EU 002 Mix Room

EU 003 Solvent Booth (Parts Washer)


TK 002 Styrene


What to do Why to do itBased on the current and expected operations of the affected source, this permitincludes the wet area enclosure and resin drip collection system compliance optionfor pultrusion specified in 40 CFR Section 63.5830(a). If the Permittee laterchooses to switch to the other compliance options allowed in the standard, thePermittee shall comply with all applicable portions of 40 CFR pt. 63, subp. WWWWfor that option. In addition, the Permittee shall apply for a permit amendment, asappropriate (e.g., to add applicable NESHAP language, for installation of anoxidizer, etc.).

40 CFR Section 63.5830; Minn. R. 7007.1150; Minn.R. 7011.8090

The Permittee shall comply with the Maximum Achievable Control Technology(MACT) Standard for Reinforced Plastic Composites Production by April 21, 2006(the Compliance Date). If the Permittee uses the organic HAP emissions standardbased on a 12-month rolling average, they must begin collecting data by theCompliance Date.

40 CFR Section 63.5800; Minn. R. 7011.7800

EMISSION LIMITS AND WORK PRACTICE STANDARDS hdr

The Permittee shall reduce emissions of Total HAPs - Organic: greater than orequal to 60.0 percent by weight

40 CFR Section 63.5805(b); 40 CFR pt. 63, subp.WWWW, Table 3; Minn. R. 7011.7800

The Permittee shall not use cleaning solvents that contain HAP, except that styrenemay be used as a cleaner in closed systems, and organic HAP-containing cleanersmay be used to clean cured resin from application equipment. Applicationequipment includes any equipment that directly contacts resin.

40 CFR Section 63.5805(b); 40 CFR pt. 63, subp.WWWW, Table 4, item 2; Minn. R. 7011.7800

HAP-containing materials storage: The Permittee shall keep containers that storeHAP-containing materials closed or covered except during the addition or removalof materials. Bulk HAP-containing materials storage tanks may be vented asnecessary for safety.

40 CFR Section 63.5805(b); 40 CFR pt. 63, subp.WWWW, Table 4, item 3; Minn. R. 7011.7800

All Mixing Operations: The Permittee shall:- use mixer covers with no visible gaps present in the mixer covers, except thatgaps of up to 1 inch are permissible around mixer shafts and any requiredinstrumentation;- close any mixer vents when actual mixing is occurring, except that venting isallowed during addition of materials, or as necessary prior to adding materials oropening the cover for safety; and- keep the mixer covers closed while actual mixing is occurring except when addingmaterials or changing covers to the mixing vessels.

40 CFR Section 63.5805(b); 40 CFR pt. 63, subp.WWWW, Table 4, items 6-8; Minn. R. 7011.7800

The Permittee shall design, install, and operate wet area enclosures and resin dripcollection systems on pultrusion machines that meet the following criteria:1) The enclosure must cover and enclose the open resin bath and the forming areain which reinforcements are pre-wet or wet-out and moving toward the die(s). Thesurfaces of the enclosure must be closed except for openings to allow material toenter and exit the enclosure.2) the enclosure must extend from the beginning of the resin bath to within 0.5inches or less of the die entrance;3) The total open area of the enclosure must not exceed two times the crosssectional area of the puller window(s) and must comply with the followingrequirements: -- All areas that are open need to be included in the total open area calculationwith the exception of access panels, doors, and/or hatches that are part of theenclosure. -- The area that is displaced by entering reinforcement or exiting product isconsidered open, and

40 CFR Section 63.5830(b); Minn. R. 7011.7800


Geotek

10900102 - 004

Facility Name:

Permit Number:

A-9

Continued: -- Areas that are covered by brush covers are considered closed;4) Open areas for level control devices, monitoring devices, agitation shafts, and fillhoses must have no more than 1.0 inch clearance;5) The access panels, doors, and/or hatches that are part of the enclosure mustclose tightly. Damaged access panels, doors, and/or hatches that do not closetightly must be replaced;6) The enclosure may not be removed from the pultrusion line, and access panels,doors, and/or hatches that are part of the enclosure must remain closed wheneverresin is in the bath, except for the time period discussed in item 7 below;

40 CFR Section 63.5830(b); Minn. R. 7011.7800(cont.)

Continued:7) The maximum length of time the enclosure may be removed from the pultrusionline or the access panels, doors, and/or hatches and may be open, is 30 minutesper 8 hour shift, 45 minutes per 12 hour shift, or 90 minutes per day if the machineis operated for 24 hours in a day. The time restrictions do not apply if the opendoors or panels do not cause the limit of two times the puller window area to beexceeded. Facilities may average the times that access panels, doors, and/orhatches are open across all operating lines. In that case the average must notexceed the times shown in this paragraph. All lines included in the average musthave operated the entire time period being averaged; AND8) No fans, blowers, and/or air lines may be allowed within the enclosure. Theenclosure must not be ventilated.


The Permittee must always operate and maintain the affected source, including airpollution control and monitoring equipment, according to the provisions in 40 CFRSection 63.6(e)(1)(i).

40 CFR Section 63.5835(c); Minn. R. 7011.7800

Proper Operation and Maintenance: At all times, including periods of startup,shutdown and malfunction, the Permittee shall operate and maintain the emissionunit subject to 40 CFR pt. 63, subp. WWWW and its associated monitoringequipment in a manner consistent with safety and good air pollution controlpractices for minimizing emissions at least to the levels required by all relevantstandards.

40 CFR Section 63.6(e)(1)(i); Minn. R. 7011.7000

Malfunctions shall be corrected as soon as practicable after their occurrence. 40 CFR Section 63.6(e)(1)(ii); Minn. R. 7011.7000

COMPLIANCE REQUIREMENTS hdr

The Permittee must demonstrate initial compliance with each organic HAPemissions standard in paragraphs (a) through (h) of 40 CFR Section 63.5805 usingthe procedures in Tables 8 and 9 of 40 CFR pt. 63, subp. WWWW.

40 CFR Section 63.5860(a); Minn. R. 7011.7800

The Permittee must monitor and collect data as follows:1) Except for monitoring malfunctions, associated repairs, and required qualityassurance or control activities (including, as applicable, calibration checks andrequired zero and span adjustments), the Permittee must conduct all monitoring incontinuous operation (or collect data at all required intervals) at all timesthat the affected source is operating.2) The Permittee may not use data recorded during monitoring malfunctions,associated repairs, and required quality assurance or control activities for purposesto this subpart, including data averages and calculations, or fulfilling a minimumdata availability requirement, if applicable. The Permittee must use all the datacollected during all other periods in assessing the operation of the control deviceand ssociated control system.


Continued:3) At all times, the Permittee must maintain necessary parts for routine repairs ofthe monitoring equipment.4) A monitoring malfunction is any sudden, infrequent, not reasonably preventablefailure of the monitoring equipment to provide valid data. Monitoring failures thatare caused in part by poor maintenance or careless operation are not malfunctions.


Resin/Gel Coat Usage Recordkeeping: The Permittee shall collect and keeprecords of resin and gel coat use, organic HAP content, and operation where resinis used. Resin use records may be based on purchase records if the Permittee canreasonably estimate how the resin is applied. The organic HAP content recordsmay be based on MSDS or on resin specifications supplied by the resin supplier.


For each pultrusion machine, the Permittee must record all times that wet areaenclosures doors or covers are open and there is resin present in the resin bath.

40 CFR Section 63.5895(e); Minn. R. 7011.7800

Compliance with work practice standards in this permit is demonstrated bycomplying with the required work practice for the Permittee's operation.

40 CFR Section 63.5900(a)(4); Minn. R. 7011.7800

During periods of startup, shutdown, and malfunction, the Permittee must meet theapplicable organic HAP emissions limits and work practice standards.


RECORDKEEPING hdr


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10900102 - 004

Facility Name:

Permit Number:

A-10

The Permittee must keep a copy of each notification and report submitted tocomply with 40 CFR pt. 63 subp. WWWW, including all documentation supportingany Initial Notification or Notification of Compliance Status submitted according tothe requirements in 40 CFR Section 63.10(b)(2)(xiv).


The Permittee must keep all data, assumptions, and calculations used to determineorganic HAP emissions factors or average organic HAP contents for operations inGP 005.


The Permittee must keep a certified statement that the facility is in compliance withthe work practice requirements in this permit.

40 CFR Section 63.5915(d); Minn. R. 7011.7800

The Permittee must maintain all applicable records in such a manner that they canbe readily accessed and are suitable for inspection according to 40 CFR Section63.10(b)(1).


As specified in 40 CFR Section 63.10(b)(1), the Permittee must keep each recordfor 5 years following the date of each occurrence, measurement, maintenance,corrective action, report, or record.

The Permittee must keep each record onsite for at least 2 years after the date ofeach occurrence, measurement, maintenance, corrective action, report, or record,according to 40 CFR Section 63.10(b)(1). The Permittee can keep the recordsoffsite for the remaining 3 years.

40 CFR Section 63.5920(b) and (c); Minn. R.7011.7800; 40 CFR Section 63.10(b)(1); Minn. R.7019.0100, subp. 2(B)

The Permittee may keep records in hard copy or computer readable form including,but not limited to, paper, microfilm, computer floppy disk, magnetic tape, ormicrofiche.


NOTIFICATIONS AND REPORTING hdr

Notifications: If the Permittee changes any information submitted in any notificationunder 40 CFR Section 63.5905(a), the Permittee shall submit the changes inwriting to the Administrator within 15 calendar days after the change.


Compliance Report Content: The compliance report must contain the followinginformation:1) Company name and address;2) Statement by responsible official with that official's name, title, and signature,certifying the truth, accuracy, and completeness of the content of the report;3) Date of the report and beginning and ending dates of the reporting period;4) If there are no deviations from any applicable organic HAP emissions limitations,and there are no deviations from work practice standards in this permit, a statementthat there were no deviations from the organic HAP emission limitations or workpractice standards during the reporting period;


continued:5) For each deviation from an organic HAP emissions limitation and for eachdeviation from the requirements for work practice standards, the compliance reportmust also contain the following information;- The total operating time of each affected source during the reporting period.- Information on the number, duration, and cause of deviations (including unknowncause, if applicable), as applicable and the corrective action taken;6) The Permittee must state if they have changed compliance options since the lastcompliance report; and7) The Permittee must state if they changed compliance options since the lastcompliance report.

40 CFR Section 63.5910(d) and (i); Minn. R.7011.7800 (cont.)


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10900102 - 004

Facility Name:

Permit Number:

A-11

Subject Item: GP 006 Equipment Subject to 40 CFR pt. 63, subp. PPPP


EU 004 Paint Booth

What to do Why to do itBased on the current and expected operations of the affected source, this permitincludes both the compliant material option specified in 40 CFR Section 63.4491(a)and the emission rate without add-on control option specified in 40 CFR Section63.4491(b). If the Permittee later chooses to switch to the other compliance optionallowed in the standard, the Permittee shall comply with all applicable portions of40 CFR pt. 63, subp. PPPP for that option. In addition, the Permittee shall apply fora permit amendment, as appropriate (e.g., to add applicable NESHAP language,for installation of an oxidizer, etc.).


The affected source is the collection of all of the items listed below that are used forsurface coating of plastic parts and products:1) All coating operations as defined in 40 CFR Section 63.4581;2) All storage containers and mixing vessels in which coatings, thinners and/orother additives, and cleaning materials are stored or mixed;3) All manual and automated equipment and containers used for conveyingcoatings, thinners and/or other additives, and cleaning materials; and4) All storage containers and all manual and automated equipment and containersused for conveying waste materials generated by a coating operation.

40 CFR Sedition 63.4482(b); Minn. R. 7011.8130

The Permittee shall comply with the Maximum Achievable Control Technology(MACT) Standard for Surface Coating of Plastic Parts and Products as of April 19,2007 (the Compliance Date).


Unless otherwise noted, all equations for 40 CFR pt 63, subp. PPPP referenced inthe requirements of GP 006 can be found in Appendix IV of this permit.

Minn. R. 7007.0800, subp. 4 and 5

EMISSION LIMIT hdr

HAPs - Total: less than or equal to 0.16 kilograms/kilograms of coating solids usedduring each 12-month compliance period (HAP emission limit).

40 CFR Section 63.4490(b)(1); Minn. R. 7011.8130

COMPLIANCE REQUIREMENTS hdr

The Permittee must include all coatings (as defined in 40 CFR Section 63.4581),thinners and/or other additives, and cleaning materials used in the affected sourcewhen determining whether the HAP emission rate is equal to or less than the HAPemission limit. To make this determination, the Permittee must use at least one ofthe three compliance options listed in paragraphs (a) through (c) of 40 CFR Section63.4491.

As stated earlier, this permit only includes the requirements associated with thecompliant material and the emission rate without add-on controls options specifiedin 40 CFR Section 63.4491(a) and (b).


Continued:Even so, the Permittee may apply any of the compliance options to an individualcoating operation, or to multiple coating operations as a group, or to the entireaffected source. The Permittee may use different compliance options for differentcoating operations, or at different times on the same coating operation. ThePermittee may employ different compliance options when different coatings areapplied to the same part, or when the same coating is applied to different parts.However, the Permittee may not use different compliance options at the same timeon the same coating operation. If the Permittee switches between complianceoptions for any coating operation or group of coating operations, the Permitteemust document this switch as required by 40 CFR Section 63.4530(c), and thePermittee must report it in the next semiannual compliance report listed in Table Bof this permit.

CFR Section 63.4491; Minn. R. 7011.8130 (cont.)

The Permittee must be in compliance with the emission limitations as specifiedbelow:1) Any coating operation(s) for which the Permittee uses the compliant materialoption or the emission rate without add-on controls option, as specified in 40 CFRSection 63.4491(a) and (b), must be in compliance with the HAP emission limit atall times.2) The Permittee must always operate and maintain the affected source accordingto the provisions in 40 CFR Section 63.6(e)(1)(i).

40 CFR Section 63.4500(a)(1) and(b); Minn. R.7011.8130


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10900102 - 004

Facility Name:

Permit Number:

A-12

Organic HAP Mass Fraction: The Permittee must determine the mass fraction oforganic HAP for each coating, thinner and/or other additive, and cleaning materialused during the compliance period by using one of the following options:1) Method 311 (appendix A to 40 CFR pt. 63). The Permittee may use Method 311for determining the mass fraction of organic HAP. To use Method 311, count eachorganic HAP that is measured to be present at 0.1 percent by mass fraction ormore for Occupational Safety and Health Administration (OSHA)-definedcarcinogens as specified in 40 CFR Section 1910.1200(d)(4) and at 1.0 percent bymass or more for other compounds. Calculate the total mass fraction of organicHAP in the test material by adding up the individual organic HAP mass fractionsand truncating the result to three places after the decimal point;

40 CFR Sections 63.4541(a) and 63.4551(a); Minn. R.7011.8130

Continued2) Method 24 (appendix A to 40 CFR pt. 60). For coatings, the Permittee may useMethod 24 to determine the mass fraction of nonaqueous volatile matter and usethat value as a substitute for mass fraction of organic HAP. For reactive adhesivesin which some of the HAP react to form solids and are not emitted to theatmosphere, the Permittee may use the alternative method described in appendix Ato 40 CFR pt. 63, subp. PPPP, rather than Method 24. The Permittee may use thevolatile fraction that is emitted, as measured by the alternative method in appendixA to 40 CFR pt. 63, subp. PPPP, as a substitute for the mass fraction of organicHAP;3) Alternative Method. The Permittee may use an alternative test method fordetermining the mass fraction of organic HAP once the Administrator has approvedit. The Permittee must follow the procedure in 40 CFR Section 63.7(f) to submit analternative test method for approval;

40 CFR Sections 63.4541(a) and 63.4551(a); Minn. R.7011.8130 (cont)

Continued4) Information from the supplier or manufacturer of the material. The Permittee mayrely on information other than that generated by the previous three paragraphs,such as manufacturer's formulation data, if it represents each organic HAP that ispresent in 0.1 percent by mass or more for OSHA-defined carcinogens as specifiedin 40 CFR Section 1910.1200(d)(4) and at 1.0 percent by mass or more for theother compounds. For reactive adhesives in which some of the HAP react to formsolids and are not emitted to the atmosphere, the Permittee may rely onmanufacturer's data that expressly states the organic HAP or volatile matter massfraction emitted. If there is a disagreement between such information and theresults of a test conducted in according to 40 CFR Section 63.4541(a)(1) through(3), then the test method results will take precedence unless, after consultation thePermittee demonstrates to the satisfaction of the MPCA that the formulation dataare correct; or


Continued5) Solvent blends. Solvent blends may be listed as single components for somematerials in data provided by manufacturers or suppliers. Solvent blends maycontain organic HAP which must be counted toward the total organic HAP massfraction of the materials. When test data and manufacturer's data for solvent blendsare not available, the Permittee may use the default values for the mass fraction oforganic HAP in these solvent blends listed in Table 3 or 4 of 40 CFR pt. 63, subp.PPPP.


ContinuedIf the tables are used, the values in Table 3 of 40 CFR pt. 63, subp. PPPP for allsolvent blends that match the entries according to the instructions for Table 3 maybe used, and Table 4 of 40 CFR pt. 63, subp. PPPP may be used only if the solventblends in materials that are used are known and they do not match any of thesolvent blends in Table 3 and it is known only whether the blend is aliphatic oraromatic. However, if the results of a Method 311 (appendix A to 40 CFR pt. 63)test indicate higher values than those listed in Tables 3 or 4, the Method 311results will take precedence unless, after consultation it is determined to thesatisfaction of the MPCA that the formulation data are correct.


Solids Mass Fraction: The Permittee must determine the mass fraction of coatingsolids kg(lb) per kg(lb) of coating for each coating used during the complianceperiod by a test, by information provided by the supplier or the manufacturer of thematerial, or by calculation, as specified by the following options:1) Method 24 (appendix A to 40 CFR pt. 60). Use Method 24 for determining themass fraction of coating solids. For reactive adhesives in which some of the liquidfraction reacts to form solids, the alternative method contained in Appendix A to 40CFR pt. 63, subp. PPPP, rather than Method 24, may be used to determine themass fraction of coating solids;2) Alternative method. An alternative test method may be used for determining thesolids content of each coating once the Administrator has approved it. Theprocedure in 40 CFR Section 63.7(f) must be followed to submit an alternative testmethod for approval; or

40 CFR Sections 63.4541(b) and 63.4551(b); Minn. R.7011.8130


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10900102 - 004

Facility Name:

Permit Number:

A-13

Continued3) Information from the supplier or manufacturer of the material. The mass fractionof coating solids for each coating may be obtained from the supplier ormanufacturer. If there is a disagreement between such information and the testmethod results, then the test method results will take precedence unless, afterconsultation it is demonstrated to the satisfaction of the MPCA that the formulationdata are correct.

40 CFR Sections 63.4541(b) and 63.4551(b); Minn. R.7011.8130 (cont)

Compliant Material Requirements hdr

Compliant Material Option: The Permittee shall demonstrate that the organic HAPcontent of each coating used in the coating operation(s) is less than or equal to0.16 kg organic HAP emitted per kg coating solids used during each 12-monthcompliance period, and that each thinner and/or other additive, and cleaningmaterial used contains no organic HAP. The Permittee must meet all therequirements of 40 CFR Sections 63.4540, 63.4541, and 63.4542 to demonstratecompliance with the HAP emission limit using the compliant material option.


Initial Compliance Demonstration: The Permittee must complete the initialcompliance demonstration for the initial compliance period according to 40 CFRSection 63.4541. The initial compliance period begins on April 19, 2007 and endson April 30, 2008. The initial compliance demonstration includes the calculationsaccording to 40 CFR Section 63.4541 and supporting documentation showing thatduring the initial compliance period, no coating with an organic HAP content thatexceeded the HAP emission limit was used, and that no thinners and/or otheradditives, or cleaning materials that contained organic HAP as determinedaccording to 40 CFR Section 63.4541(a) were used.


The Permittee may use the compliant material option for any individual coatingoperation, for any group of coating operations in the affected source, or for all thecoating operations in the affected source. The Permittee must use either theemission rate without add-on controls option or the emission rate with add-oncontrols option for any coating operation in the affected source for which it does notuse this option. To demonstrate initial compliance using the compliant materialoption, the coating operation or group of coating operations must use no coatingwith an organic HAP content that exceeds the HAP emission limit and must use nothinner and/or other additive, or cleaning material that contains organic HAP asdetermined according to 40 CFR Section 63.4541. The Permittee must conduct aseparate initial compliance demonstration for each general use coating.


ContinuedThe Permittee does not need to redetermine the organic HAP content or coatings,thinners and/or other additives, and cleaning materials that are reclaimed on-site(or reclaimed off-site if the Permittee has documentation that the same materialsthat the same materials that were sent off-site were received back) and reused inthe coating operation for which the compliant material option is being used,provided these materials in their condition as received were demonstrated tocomply with the compliant material option.

40 CFR Section 63.4541; Minn. R. 7011.8130 (cont)

HAP Content Calculation: By the end of each calendar month, the Permittee shallcalculate the organic HAP content, kg(lb) organic HAP emitted per kg(lb) coatingsolids used, of each coating used during the compliance period using the followingEquation 1 in Appendix IV to this permit.


Compliance Demonstration: The calculated organic HAP content for each coatingused during the initial compliance period must be less than or equal to the HAPemission limit; and each thinner and/or other additive, and cleaning material usedduring the initial compliance period may contain no organic HAP, determinedaccording to 40 CFR Section 63.4541(a). All records must be kept as required by40 CFR Sections 63.4530 and 63.4531.


For each compliance period to demonstrate continuous compliance, the Permitteemust use no coating for which the organic HAP content (determined using Equation1) exceeds the HAP emission limit and must use no thinner and/or other additive,or cleaning material that contains organic HAP, determined according to 40 CFRSection 63.4541(a). A compliance period consists of 12 months. Each month, afterthe end of the initial compliance period described in 40 CFR Section 63.4540, is theend of a compliance period consisting of that month and the preceding 11 months.


Deviation: If the Permittee chooses to comply with the emission limitations usingthe compliant material option, the use of any coating, thinner and/or other additive,or cleaning material that does not meet the criteria specified in 40 CFR Section63.4542(a) is a deviation from the emission limitations that must be reported asspecified in 40 CFR Sections 63.4510(c)(6) and 63.4520(a)(5).


Emission Rate Without Add-On Controls Requirements hdr


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10900102 - 004

Facility Name:

Permit Number:

A-14

Emission rate without add-on controls option. The Permittee shall demonstrate that,based on the coatings, thinners and/or other additives, and cleaning materials usedin the coating operation(s), the organic HAP emission rate for the coatingoperation(s) is less than or equal to the HAP emission limit, calculated as a rolling12-month emission rate and determined on a monthly basis. The Permittee mustmeet all the requirements of 40 CFR Sections 63.4550, 63.4551, and 63.4552 todemonstrate compliance with the emission limit using this option.


The Permittee must complete the initial compliance demonstration for the initialcompliance period according to the requirements of 40 CFR Section 63.4551. Theinitial compliance period begins on April 19, 2007 and ends on April 30, 2008.

The Permittee must determine the mass of organic HAP emissions and mass ofcoating solids used each month and then calculate an organic HAP emission rateat the end of the initial compliance period. The initial compliance demonstrationincludes the calculations according to 40 CFR Section 63.4551 and supportingdocumentation showing that during the initial compliance period the organic HAPemission rate was equal to or less than the HAP emission limit.


The Permittee may use the emission rate without add-on controls option for anyindividual coating operation, for any group of coating operations in the affectedsource, or for all the coating operations in the affected source. The Permittee mustuse either the compliant material option or the emission rate with add-on controlsoption for any coating operation in the affected source for which the Permittee doesnot use this option. To demonstrate initial compliance using the emission ratewithout add-on controls option, the coating operation or group of coating operationsmust meet the applicable HAP emission limit.

The Permittee must conduct a separate initial compliance demonstration for eachgeneral use coating operation. The Permittee must meet all the requirements of 40CFR Section 63.4551.


When calculating the organic HAP emission rate, do not include any coatings,thinners and/or other additives, or cleaning materials used on coating operations forwhich the Permittee uses the compliant material option or the emission rate withadd-on controls option.


The Permittee does not need to redetermine the mass of organic HAP in coatings,thinners and/or other additives, or cleaning materials that have been reclaimedon-site (or reclaimed off-site if the Permittee has documentation showing that theyreceived back the exact same materials that were sent off-site) and reused in thecoating operation for which the Permittee uses the emission rate without add-oncontrols option. If the Permittee uses coatings, thinners and/or other additives, orcleaning materials that have been reclaimed on-site, the amount of each used in amonth may be reduced by the amount of each that is reclaimed. That is, theamount used may be calculated as the amount consumed to account for materialsthat are reclaimed.


The Permittee shall determine the density of each liquid coating, thinner and/orother additive, and cleaning material used during each month from test resultsusing ASTM Method D1475-98, "Standard Test Method for Density of LiquidCoatings, Inks, and Related Products" (incorporated by reference, see 40 CFRSection 63.14), information from the supplier or manufacturer of the material, orreference sources providing density or specific gravity data for pure materials.


ContinuedIf there is disagreement between ASTM Method D1475-98 and other suchinformation sources, the test results will take precedence unless, after consultationthe Permittee demonstrates to the satisfaction of the Agency that the formulationdata are correct. If the Permittee purchases materials or monitor consumption byweight instead of volume, the Permittee does not need to determine materialdensity. Instead, the Permittee may use the material weight in place of thecombined terms for density and volume in Equations 2A, 2B, 2C, and 3 in AppendixIV to this permit.

40 CFR Section 63.4551(c); Minn. R. 7011.8130 (cont)

The Permittee shall determine the volume (liters) of each coating, thinner and/orother additive, and cleaning material used during each month by measurement orusage records. If the Permittee purchases materials or monitors consumption byweight instead of volume, the Permittee does not need to determine the volume ofeach material used. Instead, the Permittee may use the material weight in place ofthe combined terms for density and volume in Equations 2A, 2B, 2C and 3 inAppendix IV to this permit.



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10900102 - 004

Facility Name:

Permit Number:

A-15

The mass of organic HAP emissions is the combined mass of organic HAPcontained in all coatings, thinners and/or other additives, and cleaning materialsused during each month minus the organic HAP in certain waste materials. ThePermittee shall calculate the following using the referenced equations in AppendixIV of this permit:1) Calculate the mass of organic HAP emissions using Equation 2.2) Calculate the kg organic HAP in the coatings used during the month usingEquation 2A.3) Calculate the kg of organic HAP in the thinners and/or other additives usedduring the month using Equation 2B.4) Calculate the kg organic HAP in the cleaning materials used during the monthusing Equation 2C.5) If the Permittee chooses to account for the mass of organic HAP contained inwaste materials sent or designated for shipment to a hazardous waste TSDF inEquation 2, then the Permittee must determine the mass according to 40 CFRSection 63.4551(e)(4)(i) through (iv).

40 CFR Section 63.4551(e); Minn. R. 7011.8130

The Permittee shall determine the total mass of coating solids used, kg, which isthe combined mass of coating solids for all the coatings used during each month,using Equation 3.

40 CFR Section 63.4551(f); Minn. R. 7011.8130

The Permittee shall calculate the organic HAP emission rate for the complianceperiod, kg (lb) organic HAP emitted per kg (lb) coating solids used, using Equation4.

40 CFR Section 63.4551(g); Minn. R. 7011.8130

The organic HAP emission rate for the initial compliance period calculated usingEquation 4 must be less than or equal to the HAP emission limit. The Permitteemust keep all records as required by 40 CFR Sections 63.4530 and 63.4531. Aspart of the notification of compliance status required by 40 CFR Section 63.4510,the Permittee must identify the coating operation(s) for which the Permittee usedthe emission rate without add-on controls option and submit a statement that thecoating operation(s) was (were) in compliance with the emission limitations duringthe initial compliance period because the organic HAP emission rate was less thanor equal to the HAP emission limit, determined according to the procedures in 40CFR Section 63.4551.

40 CFR Section 63.4551(h); Minn. R. 7011.8130

To demonstrate continuous compliance, the organic HAP emission rate for eachcompliance period, determined according to 40 CFR Section 63.4551(a) through(g), must be less than or equal to the HAP emission limit. A compliance periodconsists of 12 months. Each month after the end of the initial compliance perioddescribed in 40 CFR Section 63.4550 is the end of a compliance period consistingof that month and the preceding 11 months. The Permittee must perform thecalculations in 40 CFR Section 63.4551(a) through (g) on a monthly basis usingdata from the previous 12 months of operation.


Deviation: If the organic HAP emission rate for any 12-month compliance periodexceeded the HAP emission limit, this is a deviation from the emission limitation forthat compliance period and must be reported as specified in 40 CFR Sections63.4510(c)(6) and 63.4520(a)(6).


RECORDKEEPING hdr

The Permittee shall collect and keep records of the data and information specifiedbelow. Failure to collect and keep these records is a deviation from the standard.1) A copy of each notification and report that was submitted to comply with 40 CFRpt. 63, subp. PPPP, and the documentation supporting each notification and report;2) A current copy of information provided by materials suppliers or manufacturer'sformulation data, or test data used to determine the mass fraction of organic HAPand density for each coating, thinner and/or other additive, and cleaning material,and the mass fraction of coating solids for each coating. If a test was conducted todetermine the mass fraction of organic HAP, density, or mass fraction of coatingsolids, keep a copy of the complete test report. If the information provided by themanufacturer or supplier that was based on testing was used, keep the summarysheet of results provided by the supplier.

40 CFR Sections 63.4530, 63.4542(d), and 4552(d);Minn. R. 7011.8130


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10900102 - 004

Facility Name:

Permit Number:

A-16

ContinuedThe Permittee is not required to obtain the test report or other documentation fromthe manufacturer or supplier;3) A record of the coating operations on which the Permittee used each complianceoption and the time periods (beginning and ending dates) for each option that wasused;4) For the compliant material option, a record of the calculation of the organic HAPcontent for each coating, using Equation 1 in this permit;5) For the emission rate without add-on controls option:- a record of the calculation of the total mass of organic HAP emissions for thecoatings, thinners and/or other additives, and cleaning materials used each monthusing Equations 2, 2A through 2C, and 3, and, if applicable, the calculation used todetermine mass of organic HAP in waste materials according to 40 CFR Section63.4551(e)(4)

40 CFR Sections 63.4530, 63.4542(d), and 4552(d);Minn. R. 7011.8130 (cont)

Continued- the calculation of the total mass of coating solids used each month using Equation3; and- the calculation of each 12-month organic HAP emission rate using Equation 4;6) A record of the name and mass of each coating, thinner and/or other additive,and cleaning material used during each compliance period. If the Permittee usesthe compliant material option for all coatings at the facility, purchase records foreach material used may be kept instead of recording the mass used during eachcompliance period;7) A record of the mass fraction of organic HAP for each coating, thinner and/orother additive, and cleaning material used during each compliance period;8) A record of the mass fraction of coating solids for each coating used during eachcompliance period;


Continued9) If the Permittee uses an allowance in Equation 2 for organic HAP contained inwaste materials sent to or designated for shipment to a treatment, storage, anddisposal facility (TSDF) according to 40 CFR Section 63.4551(e)(4), the Permitteemust keep records of the information specified in paragraphs 40 CFR Section63.4530(g)(1) through (3); and10) Records of the date, time and duration of each deviation.


The Permittee's records must be in a form suitable and readily viewable forexpeditious review according to 40 CFR Section 63.10(b)(1). Where appropriate,the records may be maintained as electronic spreadsheets or as a database. Asspecified in 40 CFR Section 63.10(b)(1), each record must be kept for 5 yearsfollowing the date of each occurrence, measurement, maintenance, correctiveaction, report, or record. The record must be kept on-site for at least 2 years afterthe date of each occurrence, measurement, maintenance, corrective action, report,or record according to 40 CFR Section 63.10(b)(1). The remaining records may bekept off-site for the remaining 3 years.

40 CFR Sections 63.4531, 63.4542(d), and 4552(d);Minn. R. 7011.8130

SUBMITTALS hdr

Content of Notification of Compliance Status: The notification of compliance statusmust contain the following information as well as the information specified in 40CFR Section 63.9(h):1) Company name and address;2) Statement by a responsible official with that official's name, title, and signature,certifying the truth, accuracy, and completeness of the content of the report;3) Date of the report and beginning and ending dates of the reporting period. Thereporting period is the initial compliance period described in 40 CFR Sections63.4540 and/or 63.4550;4) Identification of the compliance option or options specified in 40 CFR Section63.4491 that were used on each coating operation in the affected source during theinitial compliance period;5) Statement of whether or not the affected source achieved the emissionlimitations for the initial compliance period;

40 CFR Section 63.4510(c)(1)-(8); Minn. R. 7011.8130

Content of Notification of Compliance Status, continued6) If the Permittee had a deviation, include the following information:- A description and statement of the cause of the deviation.- If the Permittee failed to meet the HAP emission limit, include all the calculationsused to determine the kg (lb) of organic HAP emitted per kg (lb) coating solidsused. The Permittee does not need to submit information provided by the materials'suppliers or manufacturers, or test reports;7) For each of the data items listed below, include an example of how the Permitteedetermined the value, including calculations and supporting data. Supporting datamay include a copy of the information provided by the supplier or manufacturer ofthe example coating or material. The Permittee does not need to submit copies ofany test reports.

40 CFR Section 63.4510(c)(1)-(8); Minn. R. 7011.8130(cont.)


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10900102 - 004

Facility Name:

Permit Number:

A-17

Content of Notification of Compliance Status, continued- Mass fraction of organic HAP for one coating, for one thinner and/or otheradditive, and for one cleaning material.- Mass fraction of coating solids for one coating.- Density for one coating, one thinner and/or other additive, and one cleaningmaterial, except that if the Permittee uses the compliant material option, only theexample coating density is required;- The amount of waste materials and the mass of organic HAP contained in thewaste materials for which the Permittee claimed an allowance in Equation 2; and8) The calculation of kg (lb) of organic HAP emitted per kg (lb) coating solids usedfor the compliance options used:- for the compliant material option, provide an example calculation of the organicHAP content for one coating using Equation 1.


Content of Notification of Compliance Status, continued- for the emission rate without add-on controls option, provide the calculation of thetotal mass of organic HAP emissions for each month; the calculation of the totalmass of coating solids used each month; and the calculation of the 12-monthorganic HAP emission rate using Equations 2 and 2A through 2C, 3, and 4.


Semiannual Compliance Report Content: The semiannual compliance report mustcontain the following information:i) Company name and address.ii) Statement by a responsible official with that official's name, title, and signature,certifying the truth, accuracy, and completeness of the content of the report.iii) Date of report and beginning and ending dates of the reporting period. Thereporting period is the 6-month period ending on June 30 or December 31. Notethat the information reported for each of the 6 months in the reporting period will bebased on the last 12 months of data prior to the date of each monthly calculation.iv) Identification of the compliance option or options specified in 40 CFR Section63.4491 that was used on each coating operation during the reporting period. If thecompliance option was changed during the reporting period, the report mustcontain beginning and ending dates for each option that was used; and


Semiannual Compliance Report Content, continued:v) If the Permittee used the emission rate without add-on controls option, thecalculation results for each rolling 12-month organic HAP emission rate during the6-month reporting period.

40 CFR Section 63.4520(a)(3); Minn. R. 7011.8130(cont.)

If there were no deviations from the emissions limitations in 40 CFR Sections63.4490, 63.4492, and 63.4493 that apply, the semiannual compliance report mustcontain a statement that there were no deviations from the emission limitationsduring the reporting period.


Compliant Material Option - Deviation Report Requirement: If there was a deviationfrom the applicable organic HAP content requirements in 40 CFR Section 63.4490,the semiannual compliance report must contain the following information:i) Identification of each coating used that deviated from the applicable emissionlimit, and each thinner and/or other additive, and cleaning material used thatcontained organic HAP, and the dates and time periods each was used.ii) The calculation of the organic HAP content (using Equation 1 of this permit) foreach coating identified in item (i) above. The Permittee does not need to submitbackground data supporting this calculation.iii) The determination of mass fraction of organic HAP for each thinner and/or otheradditive, and cleaning material identified in item (i) above must also be included inthis report.iv) A statement of the cause of each deviation.


Emission rate without add-on controls option - Deviation Report Requirements: Ifthere was a deviation from the HAP emission limit, the semiannual compliancereport must contain the following information:i) The beginning and ending dates of each compliance period during which the12-month organic HAP emission rate exceeded the HAP emission limit.ii) The calculations used to determine the 12-month organic HAP emission rate forthe compliance period in which the deviation occurred. The Permittee must submitthe calculations for Equations 2, 2A through 2C, 3, and 4; and if applicable, thecalculation used to determine mass of organic HAP in waste materials according to40 CFR Section 63.4551(e)(4). The Permittee does not need to submit backgrounddata supporting these calculations ( e.g., information provided by materialssuppliers or manufacturers, or test reports).iii) A statement of the cause of each deviation.



Geotek

10900102 - 004

Facility Name:

Permit Number:

A-18

Subject Item: EU 004 Paint Booth

Associated Items: CE 001 Mat or Panel Filter

GP 001 VOC Limit

GP 006 Equipment Subject to 40 CFR pt. 63, subp. PPPP

SV 006 Paint Booth Vent

What to do Why to do itThe Permittee shall vent emissions from all spray booths, including existing,modified, or new spray booths, to control equipment meeting the requirements ofCE 001.

Title I Condition: Limit to avoid classification as majorsource or modification under 40 CFR Section 52.21 &Minn. R. 7007.3000


Geotek

10900102 - 004

Facility Name:

Permit Number:

A-19

Subject Item: CE 001 Mat or Panel Filter

Associated Items: EU 004 Paint Booth

What to do Why to do itEMISSION AND OPERATING LIMITS hdr

The Permittee shall operate and maintain the control equipment such that itachieves an overall control efficiency, for Total Particulate Matter: greater than orequal to 68 percent control efficiency


The Permittee shall operate and maintain the control equipment such that itachieves an overall control efficiency, for Particulate Matter < 10 micron: greaterthan or equal to 68 percent control efficiency


The Permittee shall operate and maintain the panel filters any time that anyprocess equipment controlled by the panel filters is in operation.


If the Permittee replaces any existing panel filter, adds new panel filters, or modifiesthe panel filters, such equipment is subject to all of the requirements of CE 001.Prior to making such a change, the Permittee shall apply for and obtain theappropriate permit amendment, as applicable.



Daily Inspections: Once each operating day, the Permittee shall visually inspect thecondition of each panel filter with respect to alignment, saturation, tears, holes andany other condition that may affect the filter's performance. The Permittee shallmaintain a daily written record of filter inspections.


Periodic Inspections: At least once per calendar quarter, or more frequently asrequired by the manufacturing specifications, the Permittee shall inspect the controlequipment components. The Permittee shall maintain a written record of theseinspections.

Minn. R. 7007.0800, subp. 4, 5, and 14

Corrective Actions: If the filters or any of their components are found during theinspections to need repair, the Permittee shall take corrective action as soon aspossible. Corrective actions shall include completion of necessary repairs identifiedduring the inspection, as applicable. Corrective actions include, but are not limitedto, those outlined in the O & M Plan for the filter. The Permittee shall keep a recordof the type and date of any corrective action taken for each filter.

Minn. R. 7007.0800, subp. 4, 5, and 14

Operation and Maintenance of Filters: The Permittee shall operate and maintaineach filter in accordance with the Operation and Maintenance (O & M) Plan. ThePermittee shall keep copies of the O & M Plan available onsite for use byemployees and MPCA staff.

Minn. R. 7007.0800, subp. 14

Initial Hood Certification and Evaluation: The control device hood must conform tothe requirements listed in Minn. R. 7011.0072, subp. 2(B), and the Permittee shallcertify this as specified in Minn. R. 7011.0072, subps. 2 and 3. The Permittee shallmaintain a copy of the evaluation and certification on site.

Minn. R. 7007.0800, subp. 4, 5, and 14

Annual Hood Evaluation: The Permittee shall measure and record at least onceevery 12 months the fan rotation speed, fan power draw, or face velocity of eachhood, or other comparable air flow indication method. The Permittee shall maintaina copy of the annual evaluation on site.

Minn. R. 7007.0800, subp. 4, 5, and 14


Geotek

10900102 - 004

Facility Name:

Permit Number:

A-20

Subject Item: CE 006 Fabric Filter - Low Temperature, i.e., T<180 Degrees F

Associated Items: EU 005 Pultrustion Saw

EU 006 Rod Pointer

EU 008 Multihead Drill

EU 009 Bridgeport

EU 010 Chop Saw

EU 011 Hand Pointer

EU 012 Soda Blaster

EU 013 Dual Angle Drill

EU 017 Crossarm Drill

What to do Why to do itIf the Permittee replaces any existing fabric filter, adds new fabric filters, or modifiesthe fabric filter, such equipment is subject to all of the requirements listed at CE006. Prior to making such a change, the Permittee shall apply for and obtain theappropriate permit amendment, as applicable.

Title I Condition: Limit to avoid classification as majorsource or modification under 40 CFR Section 52.21 &Minn. R. 7007.3000

EMISSION AND OPERATING LIMITS hdr

The Permittee shall operate and maintain the control equipment such that itachieves an overall control efficiency for Total Particulate Matter: greater than orequal to 79 percent control efficiency


The Permittee shall operate and maintain the control equipment such that itachieves an overall control efficiency for Particulate Matter < 10 micron: greaterthan or equal to 74 percent control efficiency


The Permittee shall operate and maintain the fabric filter at all times that anyemission unit controlled by the fabric filter is in operation.



Pressure Drop: greater than or equal to 1.0 inches of water column and less than orequal to 8.0 inches of water column , unless a new range is set pursuant to Minn.R. 7017.2025, subp. 3, based on the values recorded during the most recent MPCAapproved performance test where compliance was demonstrated. The new rangeshall be implemented upon receipt of the Notice of Compliance letter grantingpreliminary approval. The range is final upon issuance of a permit amendmentincorporating the change.

The Permittee shall record the pressure drop once every 24 hours when inoperation.


Recordkeeping of Pressure Drop. The Permittee shall record the time and date ofeach pressure drop reading and whether or not the recorded pressure drop waswithin the range specified in this permit.


Corrective Actions: The Permittee shall take corrective action as soon as possible ifany 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 needrepair.Corrective actions shall return the pressure drop to within the permitted rangeand/or include completion of necessary repairs identified during the inspection, asapplicable. 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 dateof any corrective action taken for the filter.

Minn. R. 7007.0800, subp. 4, 5, and 14

Monitoring Equipment: The Permittee shall install and maintain the necessarymonitoring equipment for measuring and recording pressure drop as required bythis permit. The monitoring equipment must be installed, in use, and properlymaintained when the monitored fabric filter is in operation.

Minn. R. 7007.0800, subp. 4

Periodic Inspections: At least once per calendar quarter, or more frequently asrequired by the manufacturing specifications, the Permittee shall inspect the controlequipment components. The Permittee shall maintain a written record of theseinspections.

Minn. R. 7007.0800, subp. 4, 5, and 14


Geotek

10900102 - 004

Facility Name:

Permit Number:

A-21

The Permittee shall operate and maintain the fabric filter in accordance with theOperation and Maintenance (O & M) Plan. The Permittee shall keep copies of theO & M Plan available onsite for use by employees and MPCA staff.

Minn. R. 7007.0800, subp. 14

Initial Hood Certification and Evaluation: Each control device hood must conform tothe requirements listed in Minn. R. 7011.0072, subp. 2(B), and the Permittee shallcertify this as specified in Minn. R. 7011.0072, subps. 2 and 3. The Permittee shallmaintain a copy of the evaluation and certification on site.

Minn. R. 7007.0800, subp. 4, 5, and 14

Annual Hood Evaluation: The Permittee shall measure and record at least onceevery 12 months the fan rotation speed, fan power draw, or face velocity of eachhood, or other comparable air flow indication method. The Permittee shall maintaina copy of the annual evaluation on site.

Minn. R. 7007.0800, subp. 4, 5, and 14

TABLE B: SUBMITTALSFacility Name: Geotek

Permit Number: 10900102 - 004

12/23/09B-1

Each submittal must be postmarked or received by the date specified in the applicable Table. Those submittals required by parts7007.0100 to 7007.1850 must be certified by a responsible official, defined in Minn. R. 7007.0100, subp. 21. Other submittals shallbe certified as appropriate if certification is required by an applicable rule or permit condition.

Send submittals that are required to be submitted to the U.S. EPA regional office to:

Mr. George Czerniak Air and Radiation Branch EPA Region V 77 West Jackson Boulevard Chicago, Illinois 60604

Table B lists most of the submittals required by this permit. Please note that some submittal requirements may appear in Table Aor, if applicable, within a compliance schedule located in Table C. Table B is divided into two sections in order to separately listone-time only and recurrent submittal requirements.

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:

AQ Permit Technical Advisor Industrial Division 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 Technical Advisor notices of:- accumulated insignificant activities,- installation of control equipment,- replacement of an emissions unit, and- changes that contravene a permit term.

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

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

TABLE B: ONE TIME SUBMITTALS OR NOTIFICATIONSFacility Name: Geotek


12/23/09B-2

What to send When to send Portion of Facility AffectedApplication for Permit Reissuance due 180 days before expiration of Existing

PermitTotal Facility

Notification of compliance status due before 05/30/2008. The report shallcontain the information specified in Table A ofthis permit, under GP006.

GP006

TABLE B: RECURRENT SUBMITTALSFacility Name: Geotek


12/23/09B-3

What to send When to send Portion of Facility AffectedSemiannual Compliance Report due 31 days after end of each calendar

half-year starting 05/01/2008. The report shallcontain the information specified in Table A ofthis permit, under GP006.

The first semiannual compliance report mustcover the first semiannual reporting periodwhich begins 5/1/08 and ends on 6/30/08 andbe submitted by July 31, 2008.

Each subsequent semiannual compliancereport must cover the subsequent semiannualreporting period from January 1 through June30 or the semiannual reporting period fromJuly 1 through December 31.

This report may be submitted with theSemiannual Deviations Report also listed inTable B of this permit.

GP006

Semiannual Compliance Report due 31 days after end of each calendarhalf-year starting 07/01/2006. The report shallcontain the information specified in Table A ofthis permit, under GP005.

The first semiannual compliance report mustcover the first semiannual reporting periodwhich begins 4/26/06 and ends on 12/31/06.

Each subsequent semiannual compliancereport must cover the subsequent semiannualreporting period from January 1 through June30 or the semiannual reporting period fromJuly 1 through December 31. Eachsubsequent compliance report must bepostmarked or delivered no later than July 31or January 31, whichever date is the first datefollowing the semiannual reporting period.

This report may be submitted with theSemiannual Deviations Report also listed inTable B of this permit.

GP005

Semiannual Deviations Report due 30 days after end of each calendarhalf-year starting 04/21/2008 . The firstsemiannual report submitted by the Permitteeshall cover the calendar half-year in which thepermit is issued. The first report of eachcalendar year covers January 1 - June 30.The second report of each calendar yearcovers July 1 - December 31. If no deviationshave occurred, the Permittee shall submit thereport stating no deviations.

Total Facility

Annual Report due 31 days after end of each calendar yearstarting 04/21/2008 . The Permittee shallsubmit an annual report by January 31st thatdescribes the changes made at the facilityduring the previous calendar year using thelatest MPCA application forms. The reportshall include the emission unit, stack/vent,group, and control equipment data for anynew or replaced units or control devices. Thereport shall document the VOC 12-monthrolling sum calculations for the previouscalendar year. The report shall be submittedwith the annual Compliance Certification listedin Table B. As part of the Annual Report, thePermittee shall verify and certify that thefacility has maintained minor source status forNew Source Review.

Total Facility

TABLE B: RECURRENT SUBMITTALSFacility Name: Geotek


12/23/09B-4

Compliance Certification due 31 days after end of each calendar yearstarting 04/21/2008 (for the previous calendaryear). The Permittee shall submit this on aform approved by the Commissioner, both tothe Commissioner and to the US EPAregional office in Chicago. This report coversall deviations experienced during the calendaryear.

Total Facility

APPENDIX I Facility Name: Geotek

Permit Number: 10900102-004

Appendix I, Page 1

Insignificant Activities and General Applicable Requirements The table below lists the insignificant activities that are at the facility as of permit issuance and their associated general applicable requirements.

Minn. R.

Rule Description of the Activity General Applicable Requirement

7007.1300, subp.

3(B)(1)

Infrared electric oven Minn. R. 7011.0715 (PM and opacity)

7007.1300, subp. 3(G)

Laboratory equipment Minn. R. 7011.0715 (PM and opacity)

7007.1300, subp.

3(H)(3)

Welding equipment Minn. R. 7011.0715 (PM and opacity)

7007.1300, subp. 3(I)

Individual emissions units at a stationary source, each of which have a potential to emit the following pollutants in amounts less than: 1. 4,000 lbs/year of carbon monoxide; and 2. 2,000 lbs/year each of nitrogen oxide, sulfur dioxide, particulate matter, particulate matter less than ten microns, volatile organic compounds (including hazardous air pollutant-containing VOC), and ozone. Geotek listed several natural gas combustion units with a total capacity of 3.347 MMBtu/hr and spray paint can usage under this subpart.

Minn. R. 7011.0515 (PM, SO2, and opacity) or Minn. R. 7011.0715 (PM and opacity)

APPENDIX II Facility Name: Geotek


Appendix II, Page 1

Emission Factors for VOC Calculations Emission Factor for VOC Emissions (including styrene) from a covered mixer (EF(M)):

[0.25% x (% VOC1 by weight)] ton per ton of resin Emission Factor for Styrene Emissions from Pultrusion Bath (EF(S)):

[7% x (% styrene1 by weight)] ton per ton of resin, or most recent EPA-approved factor Emission Factor all other VOCs (excluding styrene) used in Pultrusion Bath (EF(V)):

[99.75% x (% VOC1 by weight)] ton per ton of resin that was mixed in a covered mixer Emission Factor for all VOCs from all other VOC-containing Materials or Operations (non-pultrusion bath VOCs) (EF(V)):

(% VOC1 by weight) ton per ton of VOC-containing material

1 For example, if the content by weight is 25%, use 0.25

APPENDIX III Facility Name: Geotek


Appendix III, Page 1

Maximum Content of Materials All contents are “as applied” or after mixing.

Emissions Unit Maximum VOC Content (% by wt)

Maximum Solids Content (lb/gal)

EU 001, resin mix 57.3% 52% EU 001 flowcoater mix 35.3% NA

EU 004 21.2% 78.8%

APPENDIX IV Facility Name: Geotek


Appendix IV, Page 1

1. PART 63 SUBPART PPPP COMPLIANCE EQUATIONS EQUATION 1

c

cc S

WH =

Where:

Hc= Organic HAP content of the coating, kg (lb) of organic HAP emitted per kg (lb) coating solids used.

Wc= Mass fraction of organic HAP in the coating, kg organic HAP per kg coating, determined according to 40 CFR § 63.4541(a).

Sc= Mass fraction of coating solids, kg coating solids per kg coating, determined according to 40 CFR § 63.4541(b).

EQUATION 2 He = A + B + C -Rw Where:

He = Total mass of organic HAP emissions during the month, kg.

A = Total mass of organic HAP in the coatings used during the month, kg, as calculated in Equation 2A.

B = Total mass of organic HAP in the thinners and/or other additives used during the month, kg, as calculated in Equation 2B. C = Total mass of organic HAP in the cleaning materials used during the month, kg, as calculated in Equation 2C. Rw = Total mass of organic HAP in waste materials sent or designated for shipment to a hazardous waste TSDF for treatment or disposal during the month, kg, determined according to 40 CFR § 63.4551(e)(4). (The Permittee may assign a value of zero to Rw if the Permittee does not wish to use this allowance.)

EQUATION 2A

( )( )( )icic

m

iic WDVolA ,,

1,∑

=

=

Where:

A = Total mass of organic HAP in the coatings used during the month, kg.

Volc,i = Total volume of coating, i, used during the month, liters.



Appendix IV, Page 2

Dc,i = Density of coating, i, kg coating per liter coating.

Wc,i = Mass fraction of organic HAP in coating, i, kg organic HAP per kg coating. For reactive adhesives as defined in 40 CFR § 63.4581, use the mass fraction of organic HAP that is emitted as determined using the method in appendix A to 40 CFR pt. 63, subp. PPPP.

m = Number of different coatings used during the month.

EQUATION 2B

( )( )( )jtjt

n

jjt WDVolB ,,

1,∑

=

=

Where:

B = Total mass of organic HAP in the thinners and/or other additives used during the month, kg.

Volt,j = Total volume of thinner and/or other additive, j, used during the month, liters.

Dt,j = Density of thinner and/or other additive, j, kg per liter.

Wt,j = Mass fraction of organic HAP in thinner and/or other additive, j, kg organic HAP per kg thinner and/or other additive. For reactive adhesives as defined in 40 CFR § 63.4581, use the mass fraction of organic HAP that is emitted as determined using the method in appendix A to 40 CFR pt. 63, subp. PPPP.

n = Number of different thinners and/or other additives used during the month.

EQUATION 2C

( )( )( )ksks

p

kks WDVolC ,,

1

,∑=

=

Where:

C = Total mass of organic HAP in the cleaning materials used during the month, kg.

Vols,k = Total volume of cleaning material, k, used during the month, liters.

Ds,k = Density of cleaning material, k, kg per liter.

Ws,k = Mass fraction of organic HAP in cleaning material, k, kg organic HAP per kg material.

p = Number of different cleaning materials used during the month.



Appendix IV, Page 3

EQUATION 3

( )( )( )isic

m

iicst MDVolM ,,

1,∑

=

=

Where:

Mst = Total mass of coating solids used during the month, kg.

Volc,i = Total volume of coating, i, used during the month, liters.

Dc,i = Density of coating, i, kgs per liter coating, determined according to 40 CFR § 63.4551(c).

Ms,i = Mass fraction of coating solids for coating, i, kgs solids per kg coating, determined according to 40 CFR § 63.4541(b).

m = Number of coatings used during the month.

EQUATION 4

∑

∑

=

== n

yst

n

ye

yr

M

HH

1

1

Where:

Hyr = Average organic HAP emission rate for the compliance period, kg organic HAP emitted per kg coating solids used.

He = Total mass of organic HAP emissions from all materials used during month, y, kg, as calculated by Equation 2.

Mst = Total mass of coating solids used during month, y, kg, as calculated by Equation 3.

y = Identifier for months.

n = Number of full or partial months in the compliance period (for the initial compliance period, n equals 12 if the compliance date falls on the first day of a month; otherwise n equals 13; for all following compliance periods, n equals 12).

Technical Support Document, Permit Action Number: 10900102-004 Page 1 of 2 Date: 12/24/2009

TECHNICAL SUPPORT DOCUMENT For

DRAFT AIR EMISSION PERMIT NO. 10900102-004 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 draft permit.

1. General Information 1.1 Applicant and Stationary Source Location

Table 1. Applicant and Source Address

Applicant/Address Stationary Source/Address (SIC Code: 3082)

Geotek Acquisition Company, LLC 122 12th Avenue North, Suite 201 St. Cloud, MN 56303

Geotek, Inc 1421 2nd Ave NW Stewartville, MN 55976 Olmsted County

Contact: Arthur Monaghan Phone: 612-605-8017

1.2 Facility Description

Geotek is a manufacturer of fiberglass reinforced fencing products. The Facility consists of a pultrusion line, coating, and various cutting operations. The Facility also has several activities that qualify as insignificant activities under Minn. R. 7007.1300, subp. 3 (see Appendix I to the permit). The main emissions are volatile organic compounds (VOC), hazardous air pollutants (HAP), and particulate matter (PM/PM10).

1.3 Description of the Permit Action

An administrative amendment application was received October 3, 2008, in accordance with Minn. R. 7007.1400, subp. 1 (E) for a transfer of ownership and operational control. The new owner and operator of the facility is Geotek Acquisition Company located at 122 12th Avenue North, Suite 201, St Cloud, MN 56303. The facility name has changed from Geotek Inc. to Geotek this permit action. The transfer of ownership and operational control was effective February 4, 2009. Updates were made to the permit to reflect current MPCA policy. Completed requirements were removed from the permit. A requirement that is included in all permits for sources that are major for HAPs was added.

Technical Support Document, Permit Action Number: 10900102-004 Page 2 of 2 Date: 12/24/2009

1.4 Facility Emissions There are no increases in air emissions associated with this permit action.

2. Conclusion

Based on the information provided by Geotek Acquisition Company, the MPCA has reasonable assurance that the proposed operation of the emission facility, as described in the Air Emission Permit No. 10900102-004 and this TSD, will not cause or contribute to a violation of applicable federal regulations and Minnesota Rules.

Staff Members on Permit Team: Sarah Sevcik (permit writer/engineer) Ben Klismith (peer reviewer) Jennifer Lovett (enforcement)

AQ File No. 3933; DQ 2427 Attachments: 1. Facility Description and CD-01 Forms

air emission permit no. 10900102-004 is issued to geotek€¦ · air emission permit no. 10900102 -...

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