Air Emission Permit No. 04900039-002 Is Issued to SB Foot ... · This amendment changes the...

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. 04900039- 002

IS ISSUED TO

SB Foot Tanning Company

SB FOOT TANNING COMPANY 805 Bench Street

Red Wing, Goodhue County, MN 55066 The emission units, control equipment and emission stacks at the stationary source authorized in this permit are as described in the following permit application(s): Permit Type Application Date Issuance Date Action Number Total Facility Operating Permit June 12, 1995 January 29, 2004 001 Major Amendment February 3, 2005 See below 002

This permit 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.

Permit Type: Major Amendment to a Federal; Pt 70/Limits to Avoid NSR

Issue Date: July 27, 2005

Expiration: January 29, 2009 Title I Conditions do not expire. Richard J. Sandberg, Manager Air Quality Permits Section Industrial Division for Sheryl A. Corrigan Commissioner Minnesota Pollution Control Agency

TABLE OF CONTENTS

Notice to the Permittee Permit Shield Facility Description Table A: Limits and Other Requirements Table B: Submittals

Appendix I: Emission Unit and Control Equipment Description Appendix II: Insignificant Activities Appendix III: Control Equipment Requirements for GP 004 Appendix IV: Control and Transfer Efficiencies to be Used in Demonstrating

Compliance with GP 001’s PM/PM10 Limit

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: SB Foot Tanning Company (SB Foot) processes leather used in clothing, footwear, furniture and shelter. The main processes include buffing, buffing dust transport, surface coating & drying, and the combustion of natural gas and fuel oil. The facility also has several insignificant activities (see Appendix II of this permit). The buffers and dust transport emit Particulate Matter (PM), Particulate Matter less than 10 microns (PM10) and chromium dust, a particulate Hazardous Air Pollutant (HAP), and are currently controlled with two fabric filter systems. The coating operations emit Volatile Organic Compounds (VOC), several HAPs, and PM/PM10. They have either wall filters or water curtains to control PM/PM10, and the two vacuum dryers have vapor condensers to control VOCs and HAPs. Because potential emissions of a single HAP, methyl isobutyl ketone, are greater than 10 tons per year (tpy), and total HAP potentials are greater than 25 tpy, the facility is major for Part 70 and is subject to a promulgated National Emissions Standard for Hazardous Air Pollutants (NESHAP) for Leather Finishing Operations (40 CFR pt. 63, subp. TTTT). Recordkeeping requirements under the NESHAP become effective February 27, 2004, and the emission limits take effect February 27, 2005. For New Source Review (NSR), this facility is not among the 28 industrial source categories listed in the Prevention of Significant Deterioration (PSD) rules (40 CFR § 52.21). Therefore, under PSD rules, the major source threshold is 250 tons per year of any single regulated (criteria) pollutant. The permit contains operational and control requirements that limit emissions of VOCs, HAPs, and PM/PM10 below 250 tons per year. Major Amendment, Action 002: This amendment changes the pressure drop requirements for the cyclone (CE001), a baghouse (CE002), and a cartridge filter (CE015). The pressure drop requirements were set prior to measuring the pressure drop during operation. This amendment changes the requirements to reflect actual operation and manufacturer’s recommendations.

TABLE A: LIMITS AND OTHER REQUIREMENTS 07/27/05

SB Foot Tanning Co

04900039 - 002

Facility Name:

Permit Number:

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 itFLEXIBLE PERMIT CONDITIONS and 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 52.21;Minn. R. 7007.3000

Equipment Labeling: The Permittee shall permanently affix a unique number toeach emission unit for tracking purposes. The numbers shall correlate the unit tothe appropriate EU and GP numbers used in this permit. The number can beaffixed by placard, stencil, or other means. The number shall be maintained so thatit is readable and visible at all times from a safe distance.

Minn. R. 7007.0800, subp. 2

Equipment Inventory: The Permittee shall maintain a written list of all emissionsunits and control equipment on site. The Permittee shall update the list to includeany replaced, modified, or new equipment to making the pre-authorized change.

The list shall correlate the units to the numbers used in this permit (EU, GP, CE)and shall include the data in Appendix I of this permit. The date of constructionshall be the date the change was made for replaced, modified, or new equipment.

Minn. R. 7007.0800, subp. 2

Annual Report: due 30 days after the end of each calendar year following PermitIssuance. The Permittee shall submit an annual report by January 31 thatdescribes the changes made at the facility during the pervious calendar year. Thereport shall document: 1) the VOC and HAP 12-Month Rolling Sum calculations forthe previous year, and 2) any equipment that is moved, modified, replaced orbrought in, including its capacity. The report shall be submitted with the AnnualCompliance Certification listed in Table B. As part of the Annual Report, thePermittee shall verify and certify that the facility has maintained its minor sourcestatus under New Source Review.

Minn. R. 7007.0800, subp. 2

The Permittee shall not begin construction of any single project or projects that areconnected or phased which will cause a total increase in actual emissions ofgreater than 99 tons per year for any criteria pollutant without first getting a permitamendment to authorize the project. Connected and phased have meanings asdefined in Minn. R. 4410.0200 subps. 9B and 60. The Permittee shall not beginconstruction of any other project which is listed in Minn. R. 4410.4300 or Minn. R.4410.4400 without first getting a permit amendment to authorize the project. Suchprojects may require the completion of an Environmental Assessment Worksheet oran Environmental Impact Statement prior to the amendment being issued. This is astate only requirement and is not federally enforceable.

Minn. R. 4410.4300 & Minn. R. 4410.4400

OPERATIONAL REQUIREMENTS hdr

Operation and Maintenance Plan: Retain at the stationary source an operation andmaintenance plan for all air pollution control equipment.

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

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 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

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Facility Name:

Permit Number:

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

NOTIFICATION REQUIREMENTS 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 thebreakdown is 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

MONITORING EQUIPMENT 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 and/or B,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)

PERFORMANCE TESTING REQUIREMENTS hdr

Performance Testing: Conduct all performance tests in accordance with Minn. R.ch. 7017 unless otherwise noted in Tables A and/or B.

Minn. R. ch. 7017

Performance Test Notifications and Submittals:

Performance Tests are due as outlined in Tables A and B of the permit. See TableB for additional testing requirements.

Performance Test Notification (written): due 30 days before each Performance TestPerformance Test Plan: due 30 days before each Performance TestPerformance Test Pre-test Meeting: due 7 days before each Performance TestPerformance Test Report: due 45 days after each Performance TestPerformance Test Report - Microfiche Copy: due 105 days after each PerformanceTest

Minn. R. 7017.2030, subp. 1-4 & Minn. R. 7017.2035,subp. 1-2

Limits set as a result of a performance test (conducted before or after permitissuance) apply until superseded as specified by Minn. R. 7017.2025 followingformal review of a subsequent performance test on the same unit.

Minn. R. 7017.2025

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SB Foot Tanning Co

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Facility Name:

Permit Number:

RECORDKEEPING REQUIREMENTS hdr

Recordkeeping: Maintain records describing any insignificant modifications (asrequired by Minn. R. 7007. 1250, subp. 3) or changes contravening permit terms(as required by Minn. R. 7007.1350 subp. 2), including records of the emissionsresulting from those changes.

Minn. R. 7007. 0800, subp. 5(B)

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)

The Permittee shall keep records of fuel purchases for the facility on a monthlybasis.

Minn. R. 7007.0800, subp. 5

REPORTING REQUIREMENTS hdr

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

Minn. R. 7007.1150 through Minn. R. 7007.1500

Extension Requests: The Permittee may apply for an Administrative Amendmentto extend 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 91 days after end of each calendar year followingpermit issuance (April 1). To be submitted on a form approved by theCommissioner.

Minn. R. 7019.3000 through Minn. R. 7019.3010

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

AMBIENT STANDARDS hdr

The Permittee shall comply and demonstrate compliance with National Primary andSecondary Ambient Air Quality Standards, 40 CFR pt. 50 and the MinnesotaAmbient Air Quality Standards, Minn. R. 7009.0010 to 7009.0800.

40 CFR pt. 50, Minn. Stat. sec. 116.07, subps. 4 and 9,Minn. R. 7007.0100, subps. 7A, 7L, and 7M, and Minn.R. 7007.0800, subp. 1, 2, and 4

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SB Foot Tanning Co

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Facility Name:

Permit Number:

Subject Item: GP 001 Total Facility VOC and PM/PM10 Limits

Associated Items: EU 007 Buffer 3 BUFF-SIDE-021

EU 009 Buffer 3 DRM-B DRM-3HEAD-0023

EU 010 Buffer 4 BUFF-SIDE-024

EU 012 Buffing Dust Transport

EU 013 Top Oil Coater KK-2

EU 020 Wet Stock Dryer

EU 023 Cleanup Hood

EU 024 AB-12 Spray Booth

EU 025 AB-12 Dryer


EU 027 AB-13 Dryer


EU 031 AB-15 Dryer


EU 033 AB-16 Dryer

EU 035 Roller Coater 1 Dryer

EU 038 Spray Hide Booth 1




EU 042 Spray Hide Dryer 1




EU 048 Buffer 1

EU 049 Buffer 1 DRM

EU 050 Buffer 2

EU 051 Buffer 2 DRM

EU 052 Buffer 4 DRMB

EU 053 Reverse Roll Coater Impregnation

EU 054 Vacuum Dryer 1


EU 056 Reverse Roll Coater 1

EU 057 New Buffer

EU 058 New Dust Removal Machine

EU 059 New Spray Booth No. 1

EU 060 New Dryer No. 1



What to do Why to do itEMISSION LIMITS hdr

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SB Foot Tanning Co

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Facility Name:

Permit Number:

Volatile Organic Compounds: less than or equal to 200 tons/year using 12-monthRolling Sum to be calculated by the 15th day of each month for the previous12-month period as described later in this permit.

All emission units or stacks added to GP 001 as allowed in this permit shall beincluded in this calculation. VOC contents for each VOC-containing material shallbe determined as described under the Material Content requirement in GP 001.

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

The Permittee shall vent emissions from EUs 054 and 055 to control equipmentmeeting the requirements of GP 010.


Total Particulate Matter: less than or equal to 200 tons/year using 12-month RollingSum to be calculated by the 15th day of each month for the previous 12-monthperiod as described later in this permit.

All emission units or stacks added to GP 001 as allowed in this permit shall beincluded in this calculation. Solids contents for each solids-containing material shallbe determined as described under the Material Content requirement in GP 001.


Particulate Matter < 10 micron: less than or equal to 200 tons/year using 12-monthRolling Sum to be calculated by the 15th day of each month for the previous12-month period as described later in this permit.

All emission units or stacks added to GP 001 as allowed in this permit shall beincluded in this calculation. Solids contents for each solids-containing material shallbe determined as described under the Material Content requirement in GP 001.


The Permittee shall vent emissions from all spray booths to control equipmentmeeting the requirements of either GP 005 and 006; and shall vent emissions fromall buffers, dust removal machines and buffing dust transport equipment to controlequipment meeting the requirements of GP 004 and/or CE 003.

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

PRE-AUTHORIZED CHANGES hdr

The Permittee is pre-authorized to make the following changes:

1) Move or modify (e.g., replace spray guns) GP 001 listed emission units;2) Replace listed emission units with ones similar to those listed in GP 001; and3) Add two new spray booths and dryers, add one new buffer and a dust removalmachine (see GP 009 for specific limitations), and replace the buffing operations'fabric filter baghouse with a high efficiency catridge filter with a capacity less thanor equal to 33,000 acfm.

Provided the following conditions are met:

1) The proposed change does not constitute reconstruction as defined by 40 CFR63.1;2) For replacement units or spray guns: the capacity is less than or equal to the unitor spray gun it replaces and the application method achieves the same or bettertransfer efficiency;

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

3) VOC and PM/PM10 emissions are tracked and calculated as specified in thispermit; and4) All equipment must meet the requirements for GP 001.

If a proposed change triggers an applicable requirement that is not contained in thispermit, the change must be permitted using the appropriate procedure in Minn. R.ch. 7007.

(continued from above)

RECORDKEEPING REQUIREMENTS (Pre-Authorized Changes) hdr

Recordkeeping of Changes: Prior to making any pre-authorized change, thePermittee shall document that the proposed change meets the criteria listed in thispermit and is therefore pre-authorized. The Permittee shall maintain thisdocumentation on-site.

Minn. R. 7007.0800, subp. 4 & 5

RECORDKEEPING REQUIREMENTS (Total Facility VOC and PM/PM10 Limits) hdr

Daily Recordkeeping:

Once during each day of operation, the Permittee shall record and maintain thequantity of each material used when ever the material is dispensed. This shall bebased on written or electronic usage logs, flowmeters, and/or delivery records.

Title I Condition: Monitoring for limit to avoidclassification as a major source and modification under40 CFR Section 52.21 and Minn. R. 7007.3000

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Facility Name:

Permit Number:

Monthly VOC Emissions Recordkeeping:

By the 15th of the month, the Permittee shall calculate and record the following:

1) The total usage of VOC containing materials for the previous calendar monthusing the material usage records. This record shall also include the VOC contentsof each material as determined by the Material Content requirement of this permit.

2) The VOC emissions for the previous month using the formulas specified in thispermit.

3) The 12-month rolling sum VOC emissions for the previous 12-month period bysumming the monthly VOC emissions data for the previous 12 months.

Minn. R. 7007.0800, subp. 4 & 5

Monthly VOC Emissions Calculation:

The Permitee shall calculate VOC emissions using the following equation:

VOC = [(A1 x B1) + (A2 x B2) + (A3 x B3) +...+ (An x Bn)] / 2000

where:

VOC = monthly VOC emissions (tons/month);A# = amount of each VOC containing material used (gallons/month);B# = amount VOC in A# (pounds/gallon)

Minn. R. 7007.0800, subp. 4 & 5

Monthly PM Emissions Recordkeeping:


1) The total usage of PM containing materials for the previous calendar monthusing the material usage records. This record shall also include the PM contents ofeach material as determined by the Material Content requirement of this permit.

2) The PM emissions for the previous month using the formulas specified below inthis permit, and the capture, control and transfer efficiencies specified in AppendixIV.

3) The 12-month rolling sum PM emissions for the previous 12-month period bysumming the monthly PM emissions data for the previous 12 months.

Minn. R. 7007.0800, subp. 4 & 5

Monthly PM Emissions Calculation:

The Permittee shall calculate PM emissions from the spray booths and buffingoperations using the following equations:

PM = [S x (1-CapEs) x (1-TEs) - W] + [(BUFFno x EFpm) x (1-CapEb) +(BUFFno x EFpm) x (CapEb) x (1-ConEb)] / (2000)

Where,

PM = monthly PM emissions (tons/month);S = (A1 x B1) + (A2 x B2) + (A3 x B3) + .....;W = (C1 x D1) + (C2 x D2) + (C3 x D3) + .....;BUFFno = number of hides processed (sides/month);EFpm = PM emission factors for GP 003 and EU 012 based on the most recentperformance testing (pounds/side);CapEb = capture efficiency of the buffing operation's control equipment (as afraction);ConEb = control efficiency of the buffing operation's control equipment (as afraction)

Minn. R. 7007.0800, subp. 4 & 5

and where:

S = total solids (as PM) used (tons/month);ConEs = overall minimum control efficiency for each spray booth (as a fraction);TEs = minimum transfer efficiency of each spray booth (as a fraction);A# = amount of each solids containing material sprayed (tons/month);B# = weight percent solids in A# (as a fraction);W = amount of solids shipped in waste (tons/month);C# = amount of each solids containing waste material shipped (tons/month)If the Permittee chooses to not take credit for waste shipments, Parameter C#would be zero; andD# = weight percent of solids in C# (as a fraction)


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Facility Name:

Permit Number:

Monthly PM10 Emissions Recordkeeping:


1) The total usage of PM10 containing materials for the previous calendar monthusing the material usage records. This record shall also include the PM10 contentsof each material as determined by the Material Content requirement of this permit.

2) The PM10 emissions for the previous month using the formulas specified belowin this permit, and the capture, control and transfer efficiencies specified inAppendix IV.

3) The 12-month rolling sum PM10 emissions for the previous 12-month period bysumming the monthly PM10 emissions data for the previous 12 months.

Minn. R. 7007.0800, subp. 4 & 5

Monthly PM10 Emissions Calculation:

The Permittee shall calculate PM10 emissions from the spray booths and buffingoperations using the following equations:

PM = [S x (1-CapEs) x (1-TEs) - W] + [(BUFFno x EFpm10) x (1-CapEb) +(BUFFno x EFpm10) x (CapEb) x (1-ConEb)] / (2000)

Where,

PM10 = monthly PM10 emissions (tons/month);S = (A1 x B1) + (A2 x B2) + (A3 x B3) + .....;W = (C1 x D1) + (C2 x D2) + (C3 x D3) + .....;BUFFno = number of hides processed (sides/month);EFpm10 = PM10 emission factors for GP 003 and EU 012 based on the mostrecent performance testing (pounds/side);CapEb = capture efficiency of the buffing operation's control equipment (as afraction);ConEb = control efficiency of the buffing operation's control equipment (as afraction)

Minn. R. 7007.0800, subp. 4 & 5

and where:

S = total solids (as PM10) used (tons/month);ConEs = overall minimum control efficiency for each spray booth (as a fraction);TEs = minimum transfer efficiency of each spray booth (as a fraction);A# = amount of each solids containing material sprayed (tons/month);B# = weight percent solids in A# (as a fraction);W = amount of solids shipped in waste (tons/month);C# = amount of each solids containing waste material shipped (tons/month)If the Permittee chooses to not take credit for waste shipments, Parameter C#would be zero; andD# = weight percent of solids in C# (as a fraction)


Material Content: The VOC and solids (PM/PM10) contents in materials shall bedetermined by the Material Safety Data Sheet (MSDS) or Certified Product DataSheet (CPDS) provided by the supplier for each material used. If a material contentrange is given, the highest number in the range shall be used in all compliancecalculations. Other alternative methods approved by the MPCA may be used todetermine the contents. The Commissioner reserves the right to require thePermittee to determine the VOC and PM/PM10 contents of any material, accordingto EPA of ASTM reference methods. If an EPA or ASTM reference method is usedfor material content determination, the data obtained shall supersede the MSDS orCPDS.

Minn. R. 7007.0800, subp. 4 & 5

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SB Foot Tanning Co

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Facility Name:

Permit Number:

Subject Item: GP 002 Sources Subject to Leather Finishing NESHAP

Associated Items: EU 007 Buffer 3 BUFF-SIDE-021



EU 012 Buffing Dust Transport

EU 013 Top Oil Coater KK-2

EU 020 Wet Stock Dryer

EU 023 Cleanup Hood


EU 025 AB-12 Dryer


EU 027 AB-13 Dryer


EU 031 AB-15 Dryer


EU 033 AB-16 Dryer

EU 035 Roller Coater 1 Dryer









EU 048 Buffer 1

EU 049 Buffer 1 DRM

EU 050 Buffer 2

EU 051 Buffer 2 DRM


EU 053 Reverse Roll Coater Impregnation



EU 056 Reverse Roll Coater 1

What to do Why to do itMACT EMISSION LIMITS(The following emission limits become effective February 27, 2005.)

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Hazardous air pollutant (HAP) means any substance or mixture of substanceslisted as a hazardous air pollutant under section 112(b) of the Clean Air Act.

40 CFR Section 63.5460

HAP Emission Limit for ULlt4: 6.8 lbs of HAP per 1,000 square feet of leatherprocessed.

Where,ULlt4 = Upholstery Leather with less than 4 grams of add-on per square foot asdetermined by 40 CFR Section 63.5345.

40 CFR Section 63.5305 and Table 1 of 40 CFR pt. 63,subp. TTTT

HAP Emission Limit for WRSL: 5.6 lbs of HAP per 1,000 square feet of leatherprocessed.

Where,WRSL = Water-Resistant / Specialty Leather as determined by 40 CFR Section63.5350.


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Facility Name:

Permit Number:

HAP Emission Limit for NWRL: 3.7 lbs of HAP per 1,000 square feet of leatherprocessed.

Where,NWRL = Non-Water-Resistant Leather as determined by 40 CFR Section 63.5350.


INDUSTRIAL PROCESS EQUIPMENT LIMITS hdr

Total Particulate Matter: less than or equal to 0.30 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. This limitapplies separately to each piece of industrial process equipment.

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

Opacity: less than or equal to 20 percent opacity. This limit applies separately toeach piece of industrial process equipment.

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


The Permittee shall operate and maintain air pollution control and monitoringequipment in accordance with 40 CFR Section 63.6(e)(1)(i).

40 CFR Sections 63.6(e)(1)(i) and 63.5320(b)

MONITORING and RECORDKEEPING REQUIREMENTS(The following recordkeeping requirements become effective February 27, 2004.)

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The HAP content of each finish will be determined in accordance with 40 CFRSection 63.5390; the density of each finish will be determined in accordance with40 CFR Section 63.5395; and, the quantity of leather processed will be determinedin accordance with 40 CFR Section 63.5400.

40 CFR Sections 63.5390, 63.5395 and 63.5400

The Permittee shall keep an inventory log to record monthly the pounds of eachtype of finish applied for each leather product process operation and the massfraction of HAP in each applied finish. The inventory recording method mustachieve the same results as the example method specified in 40 CFR 63.5335(b)would.

40 CFR Section 63.5320(c)(4)

The Permittee shall keep an inventory log to record monthly the surface area ofleather processed in 1,000's of square feet for each product process operation. Theinventory recording method must achieve the same result as the example methodspecified in Sec. 63.5430(f) would.

40 CFR Section 63.5320(c)(5)

The Permittee shall determine their compliance ratio each month in accordancewith Equation 1 below.

Equation 1:

CR = (ActHL) / (AllHL)

Where,

CR = Compliance Ratio

ActHL = Actual HAP Loss (lbs of actual HAP loss for the previous 12 months,as determined in accordance with 40 CFR Section 63.5335)

AllHL = Allowable HAP Loss (lbs of actual HAP loss for the previous 12 months,as determined in accordance with 40 CFR Section 63.5340)

40 CFR Sections 63.5320(c)(6), 63.5320(c)(7) and63.5320(c)(8)

Recordkeeping: The Permittee shall:

1. Keep the plan for demonstrating compliance as required by Section 63.5325onsite and readily available as long as the source is operational. Changes made tothe plan for demonstrating compliance must be kept and made readily available forinspection for at least 5 years after the change.

2. Keep a copy of each notification and report that the Permittee is required tosubmit in accordance with 40 CFR pt. 63, subp. TTTT.

3. Keep records of performance tests in accordance with 40 CFR pt. 63, subp.TTTT.

4. Record and maintain a continuous log of finish usage as specified in Section63.5335(b).

40 CFR Section 63.5430(a) through 63.5430(g)

A-9


SB Foot Tanning Co

04900039 - 002

Facility Name:

Permit Number:

5. Maintain all necessary records to document the methods used and the results ofall HAP content measurements of each applied finish.

6. For each leather product process operation, the Permittee must maintain amonthly log of the :

- Dates for each leather product process operation.- Total surface area of leather processed for each leather product processoperation.

7. Keep records of monitoring data for air pollution control equipment as specifiedin 40 CFR pt. 63, subp. SS.


The Permittee shall maintain all records for a period of 5 years and, at a minimum,the most recent 2 years of data shall be retained on site. The records including allrequired reports shall be in a form suitable and readily available for expeditiousinspection and review.

40 CFR Sections 63.5435 and 63.10(b)(1)

REPORTING REQUIREMENTS hdr

The Permittee shall submit an Initial Notification, Notification of Compliance Status,Annual Compliance Certifications and Deviation Notification Reports in accordancewith the procedures and timelines in Sections 63.5415 and 63.5420.

40 CFR Sections 63.5415 and 63.5420

A-10


SB Foot Tanning Co

04900039 - 002

Facility Name:

Permit Number:

Subject Item: GP 003 Buffers and Dust Removal Machines (DRMs)

Associated Items: CE 001 Centrifugal Collector - Medium Efficiency

CE 002 Fabric Filter - Low Temperature, i.e., T<180 Degrees F




EU 048 Buffer 1

EU 049 Buffer 1 DRM

EU 050 Buffer 2

EU 051 Buffer 2 DRM


SV 003

What to do Why to do itOPERATIONAL REQUIREMENTS hdr

The Permittee shall vent emissions from all buffers and dust removal machines tocontrol equipment meeting the requirements of GP 004.


EMISSION LIMITS FOR UNITS IN OPERATION BEFORE JULY 9, 1969 hdr

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. Although thislimit applies separately to each piece of industrial process equipment in GP 003,each EU in GP 003 shares the same stack (SV 003 or SV 038). Minn. R.7011.0735 limits emissions from GP 003 at SV 003 or SV 038 to 16.96 lbs/hr, andpotential emissions from GP 001 at SV 003 (or SV 038) are 0.67 lbs/hr.

Minn. R. 7011.0710, subp. 1(A)

Opacity: less than or equal to 20 percent opacity except for one six-minute periodper hour of not more than 60 percent opacity. This limit applies separately to eachpiece of industrial process equipment.

Minn. R. 7011.0710, subp. 1(B)

LIMITS FOR UNITS NOT IN OPERATION BEFORE JULY 9, 1969 hdr

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. Although thislimit applies separately to each piece of industrial process equipment in GP 003,each EU in GP 003 shares the same stack (SV 003 or SV 038). Minn. R.7011.0735 limits emissions from GP 003 at SV 003 or SV 038 to 16.96 lbs/hr, andpotential emissions from GP 003 at SV 003 (or SV 038) are 0.67 lbs/hr.

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

Opacity: less than or equal to 20 percent opacity . This limit applies separately toeach piece of industrial process equipment.

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

A-11


SB Foot Tanning Co

04900039 - 002

Facility Name:

Permit Number:

Subject Item: GP 004 Buffing Operations Control Equipment

Associated Items: CE 001 Centrifugal Collector - Medium Efficiency

CE 002 Fabric Filter - Low Temperature, i.e., T<180 Degrees F

CE 015 High Efficiency Cartridge Filter

SV 003

SV 038 New Cartidge Filter Stack

What to do Why to do itFUTURE CONSTRUCTION AUTHORIZATION

hdrThis Permit authorizes the replacement of CE 002 with CE 015 to control emissionsfrom CE 001 within 30 days following Permit Issuance.

Title I Condition: Limit to avoid major modificationclassification under 40 CFR Section 52.21

CE 001 EMISSION LIMITS hdr

The Permittee shall operate and maintain CE 001 such that is achieves a controlefficiency for Total Particulate Matter: greater than or equal to 50 percent controlefficiency

Title I Condition: Limit taken to avoid classification as amajor source and modification under 40 CFR Section52.21 and Minn. R. 7007.3000; Minn. R. 7011.0065,subp. 1(A)

The Permittee shall operate and maintain CE 001 such that is achieves a controlefficiency for Particulate Matter < 10 micron: greater than or equal to 50 percentcontrol efficiency


Pressure Drop: greater than or equal to 0.5 inches of water column and less than orequal to 6 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 Permitteeshall record the pressure drop across CE 001 once every 24 hours when inoperation.

Title I Condition: Limit taken to avoid classification as amajor source and modification under 40 CFR Section52.21 and Minn. R. 7007.3000







Title I Condition: Limit taken to avoid classification as amajor source and modification under 40 CFR Section52.21 and Minn. R. 7007.3000; Minn. R. 7011.0080







Title I Condition: Limit taken to avoid classification as amajor source and modification under 40 CFR Section52.21 and Minn. R. 7007.3000; Minn. R. 7011.0080


The Permittee shall vent emissions from the buffing operations to CE 001 and CE002 and/or CE 015 at all times that the buffers and their dust removal machines arein operation to meet applicable PM and PM10 limits. The Permittee shall operateand maintain the cyclone, fabric filter and cartridge filter at all times that the buffersand their dust removal machines are in operation.


A-12


SB Foot Tanning Co

04900039 - 002

Facility Name:

Permit Number:

Minimum Stack Height: The Permittee shall determine and install a stack (SV 038)of a height meeting the requirements of 40 CFR 51.100(ii) for GEP (GoodEngineering Practice) that will not cause pollutant concentrations at ground levelsto exceed any applicable ambient air quality standard or rule. The determination ofthe ground level concentrations shall be based upon applicable dispersioncalculations and/or modeling results approved by the Agency.

40 CFR Sections 50.1 through 50.12 and 51.100(ii)and Minn. R. 7009.0080

MONITORING AND RECORDKEEPING hdr

Visible Emissions: The Permittee shall check SV 003 and SV 038 for any visibleemissions once each day during daylight hours.

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

Recordkeeping of Visible Emissions and Pressure Drop. The Permittee shall recordthe time and date of each visible emissions inspection and pressure drop readingon CE 001, CE 002 and CE 015, and whether or not any visible emissions wereobserved, and whether the recorded pressure drop was within the range specifiedin this permit.

Minn. R. 7007.0800, subp. 5

Corrective Actions: The Permittee shall take corrective action as soon as possible ifany of the following occur:

- visible emissions are observed; or- the recorded pressure drop is outside the required operating range; or- the cyclone (CE 001), fabric filter baghouse (CE 002), cartridge filter (CE 015) orany of their components are found during the inspections to need repair.

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 Plans for the cyclone, fabric filter baghouse and cartridge filter. The Permitteeshall keep a record of the type and date of any corrective action taken for eachpiece of control equipment.

Minn. R. 7007.0800, subp. 4, 5 & 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 cyclone, fabric filter and cartridge filter are inoperation.

Minn. R. 7011.0075, subp. 3

Periodic Inspections: As required by Minn. R. 7011.0075, subp. 2(A) to 2(I) andincluded with this permit as Appendix III, at least once per calendar quarter, ormore frequently as required by the manufacturing specifications, the Permittee shallinspect the components of CE 001, CE 002 and CE 015, and shall maintain awritten record of these inspections. The Permittee shall maintain each piece ofcontrol equipment according to the manufacturer's specification, and keepdocumentation of those actions.

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

A-13


SB Foot Tanning Co

04900039 - 002

Facility Name:

Permit Number:

Subject Item: GP 005 Water Curtains

Associated Items: CE 004 Water Curtain - Use for Water Wash Paint Booths

CE 005 Water Curtain - Use for Water Wash Paint Booths



What to do Why to do itThe requirements of GP 005 apply separately to each control device listed in GP005 (i.e., CE 004 through CE 008)

Minn. R. 7007.0800, subp. 2

EMISSION LIMITS hdr

The Permittee shall operate and maintain the control equipment such that itachieves an overall combined capture and collection efficiency for Total ParticulateMatter: greater than or equal to 73.6 percent


The Permittee shall operate and maintain the control equipment such that itachieves an overall combined capture and collection efficiency for ParticulateMatter < 10 micron: greater than or equal to 73.6 percent



The Permittee shall operate and maintain each water curtain any time that anyprocess equipment controlled by the water curtains is (are) in operation.

Title I Condition: Limit taken to avoid classification as amajor source and modification under 40 CFR Section52.21 & Minn. R. 7007.3000

MONITORING AND RECORDKEEPING REQUIREMENTS hdr

Once during each day of operation, the Permittee shall inspect on each watercurtain:

- Spray nozzles for proper operation (i.e., no clogged nozzles)- Whether the correct water level is maintained to adequately filter exhaust airaccording to manufacturer's specifications.- Whether the water is re-circulating according to manufacturer's specifications.- That the water curtain remains continuous all the way across the wall of the boothwith no flow inconsistencies.- Whether water leaks from anywhere in the curtain.

The Permittee shall maintain a written record of these inspections.

Title I Condition: Monitoring for limit taken to avoidclassification as a major source and modification under40 CFR Section 52.21 and Minn. R. 7007.3000

The Permittee shall inspect monthly, or as required by the manufacturer'sspecification, each water curtain components that are subject to wear such asbearings, belts, hoses, fans, and ducts.


Minn. R. 7007.0800, subp. 4


- spray nozzles are clogged; or- the water level falls below what is needed to adequately filter exhaust air or is notre-circulating according to manufacturer's specifications; or- the water curtain is not continuous across the wall of the booth; orleaks are found; or- the water curtains or any of their components are found during the inspections toneed repair.

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

Corrective actions shall include completion of necessary repairs identified duringthe inspection, as applicable. Corrective actions include, but are not limited to,those outlined in the O & M Plans for the water curtains. The Permittee shall keep arecord of the type and date of any corrective action taken for each piece of controlequipment.


Hood Certification and Evaluation: Each control device hood must conform to therequirements listed in Minn. R. 7011.0070, subp. 1, and the Permittee shall certifythis as specified in Minn. R. 7011.0070, subp. 3. The Permittee shall maintain acopy of the certification on site, as well as an annual record of fan rotation speed,fan power draw, or face velocity of each hood, or other comparable airflowindication method.

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

A-14


SB Foot Tanning Co

04900039 - 002

Facility Name:

Permit Number:

Subject Item: GP 006 Panel Filters

Associated Items: CE 009 Mat or Panel Filter

CE 012 Mat or Panel Filter




The requirements of GP 006 apply separately to each control device listed in GP006 (i.e., CE 009 and CE 012-014).

Minn. R. 7007.0800, subp. 2

The Permittee shall operate and maintain the control equipment such that itachieves an overall capture and control efficiency, for Total Particulate Matter:greater than or equal to 92 percent


The Permittee shall operate and maintain the control equipment such that itachieves an overall capture and control efficiency, for Particulate Matter < 10micron: greater than or equal to 92 percent



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



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.

Title I Condition: Monitoring for limit taken to avoidclassification as a major source and modification under40 CFR Section 52.21 & Minn. R. 7007.3000; Minn. R.7007.0800, subp. 4 & 5

Periodic Inspections: At least once per calendar quarter, or more frequently asrequired by the manufacturing specifications, the Permittee shall shall inspect thecontrol equipment components for each panel filter. The Permittee shall maintain awritten record of these inspections.

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

Operations 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 by staff andMPCA staff.

Minn. R. 7007.0800, subp. 14

A-15


SB Foot Tanning Co

04900039 - 002

Facility Name:

Permit Number:

Subject Item: GP 007 Indirect Heating Equipment

Associated Items: EU 002 Boiler 3

EU 021 Boiler FD-1 A-86

EU 022 Boiler FD-2 A-87

EU 046 Steam Generation Boiler 1

EU 047 Steam Generation Boiler 2


Total Particulate Matter: less than or equal to 0.4 lbs/million Btu heat input . Thisapplies separately to each piece of indirect heating equipment. Based on allowablefuels and equipment capacity, the potential to emit of each unit is:

EU 002: 0.0236 lb/million Btu heat inputEU 021: 0.0239 lb/million Btu heat inputEU 022: 0.0239 lb/million Btu heat inputEU 046: 0.0242 lb/million Btu heat inputEU 047: 0.0242 lb/million Btu heat input

Minn. R. 7011.0515, subp. 1

Sulfur Dioxide: less than or equal to 2.0 lbs/million Btu heat input . This appliesseparately to each piece of indirect heating equipment. Based on allowable fuelsand equipment capacity, the potential to emit of each unit is:

EU 002: 0.0514 lb/million Btu heat inputEU 021: 0.0511 lb/million Btu heat inputEU 022: 0.0508 lb/million Btu heat inputEU 046: 0.0508 lb/million Btu heat inputEU 047: 0.0508 lb/million Btu heat input

Minn. R. 7011.0515, subp. 1

Opacity: less than or equal to 20 percent opacity except for one six-minute periodper hour of not more than 60 percent opacity. This applies separately to each pieceof indirect heating equipment.

Minn. R. 7011.0515, subp. 2

Fuel Type: natural gas or distillate fuel oil only, by design. Minn. R. 7005.0100, subp. 35a

A-16


SB Foot Tanning Co

04900039 - 002

Facility Name:

Permit Number:

Subject Item: GP 008 Direct Heating Equipment

Associated Items: EU 042 Spray Hide Dryer 1





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 lessstrigent limit of either Minn. R. 7011.0730 or Minn. R. 7011.0735. This limit appliesseparately to each direct heating unit.

Minn. R. 7011.0610, subp. 1(A)(1)

Opacity: less than or equal to 20 percent opacity except for one six-minute periodper hour of not more than 60 percent opacity. This applies separately to each pieceof indirect heating equipment.

Minn. R. 7011.0610, subp. 1(A)(2)

Fuel Type: natural gas only, by design. Minn. R. 7005.0100, subp. 35a

A-17


SB Foot Tanning Co

04900039 - 002

Facility Name:

Permit Number:

Subject Item: GP 009 New Equipment

Associated Items: EU 057 New Buffer

EU 058 New Dust Removal Machine





What to do Why to do itAuthorization for New Buffing and Coating Equipment: The Permittee may installthe units listed in GP 009 at any time during the life of the permit provided thefollowing conditions are met:

1) The capacity of the unit is no greater than that listed in Appendix I of this permit;2) The dryers can only burn natural gas;3) The spray booths use application methods that achieve the same or bettertransfer efficiency as the current booths; and4) All other permit limits are met (e.g., controls, emissions limits, etc.).

If a proposed change triggers an applicable requirement that is not contained in thispermit, the change must be permitted using the appropriate procedure in Minn. R.ch. 7007.

Title I Condition: Limit taken to avoid clasification asmajor source and modification under 40 CFR Section52.21 and Minn. R. 7007.3000

A-18


SB Foot Tanning Co

04900039 - 002

Facility Name:

Permit Number:

Subject Item: GP 010 Condensors

Associated Items: CE 010 Vapor Recovery System-Condensers, Hoods, & Other Enclosures

CE 011 Vapor Recovery System-Condensers, Hoods, & Other Enclosures


The Permittee shall operate and maintain the control equipment in GP 010 suchthat it achieves a control efficiency for Volatile Organic Compounds: greater than85 percent control efficiency


Temperature: less than or equal to 80 degrees F (or 26.67 degrees C) at the outletof CE 010 (Primary Condenser) unless a new maximum is set pursuant to Minn. R.7017.2025, subp. 3, based on the temperature recorded during the most recentMPCA approved performance test where compliance for VOC emissions wasdemonstrated. If the temperature is above the maximum temperature limit, the VOCused during that time shall be considered uncontrolled until the temperature isbelow the maximum temperature limit. This shall be reported as a deviation.


Temperature: less than or equal to 50 degrees F (or 10 degrees C) of the coldwater feed line to CE 011 (Secondary Condenser) unless a new maximum is setpursuant to Minn. R. 7017.2025, subp. 3, based on the temperature recordedduring the most recent MPCA approved performance test where compliance forVOC emissions was demonstrated. If the temperature is above the maximumtemperature limit, the VOC used during that time shall be considered uncontrolleduntil the temperature is below the maximum temperature limit. This shall bereported as a deviation.



The Permittee shall operate and maintain each condenser any time that anyprocess equipment controlled by the condensers is (are) in operation.

Title I Condition: Operational requirment for limit takento avoid classification as a major source andmodification under 40 CFR Section 52.21 & Minn. R.7007.3000

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

Minn. R. 7007.0800, subp. 14


Daily Inspections: Once each operating day, the Permittee shall:

1) Visually inspect each condenser for evidence of:

- vibration;- leaks from ducts, pipes or seals; and- broken gauges and monitors.

2) Physically check the temperature recording device to verify that it is working andrecording properly.

The Permittee shall maintain a written record of the above inspections.

3) Read and record the primary condenser's outlet temperature and the secondarycondenser's cold water feed line temperature.

The Permittee shall maintain either a continuous hard copy readout of the primarycondenser's outlet temperature and the secondary condenser's cold water feed linetemperature, or maintain a hard copy of manual readings taken at least once perday of operation.

Title I Condition: Monitoring for limit taken to avoidclassification as a major source and modification under40 CFR Section 52.21 & Minn. R. 7007.3000; Minn. R.7007.0800, subp. 4 & 5

The Permittee shall maintain and operate a thermocouple monitoring device thatcontinuously indicates the primary condenser's outlet temperature and thesecondary condenser's cold water feed line temperature. The monitoring deviceshall have a margin of error less than the greater of +/- 0.75 percent of thetemperature being measured or +/- 2.5 degrees Celsius.

Minn. R. 7007.0800, subps. 4 & 5

Monthly Inspections: At least once per month, or more frequently as required by themanufacturing specifications, the Permittee shall inspect the components for eachcondenser including:

1) visual appearance of pumps and valves;2) housing conditions and seals of, and vibration or abnormal noise from, fans andcompressors


Minn. R. 7007.0800, subps. 4, 5 & 14

A-19


SB Foot Tanning Co

04900039 - 002

Facility Name:

Permit Number:

Annual Inspections: At least once per calendar year, or more frequently as requiredby the manufacturing specifications, the Permittee shall:

1) Inspect the conditions for each condenser including evidence of rust, cracks orleaks on or from the foundation, fire supression system, hangers and groundingstraps.2) Calibrate the thermocouples and review temperature logs for trends.3) Check for leaks, abnormal noise or vibration from fans, pumps and compressors.4) Inspect the internals for fouling, plugging or corrosion and replace tubes andshell where neccessary.


Minn. R. 7007.0800, subps. 4, 5 & 14

Corrective Actions: If the temperature is above the maximum, or if the condensersor any of their components are found during the inspections to need repair, thePermittee shall take corrective action as soon as possible.

Corrective actions shall return the temperature to below the specified limits and/orinclude completion of necessary repairs identified during the inspection, asapplicable. Corrective actions include, but are not limited to, those outlined in theO & M Plan for the condensers.

The Permittee shall keep a record of the type and date of any corrective actiontaken for each condenser.

Minn. R. 7007.0800, subps. 4, 5 & 14

A-20


SB Foot Tanning Co

04900039 - 002

Facility Name:

Permit Number:

Subject Item: EU 012 Buffing Dust Transport

Associated Items: CE 003 Fabric Filter - Low Temperature, i.e., T<180 Degrees F

GP 001 Total Facility VOC and PM/PM10 Limits

GP 002 Sources Subject to Leather Finishing NESHAP

SV 004

What to do Why to do itOPERATIONAL REQUIREMENTS hdr

The Permittee shall vent emissions from the buffing dust transport system to controlequipment meeting the requirements of CE 003.


EMISSIONS LIMITS hdr

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.7011.0735 limits emissions from EU 012 at SV 004 to 2.05 lbs/hr, and potentialemissions from EU 012 at SV 004 are 0.66 lbs/hr.

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

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

A-21


SB Foot Tanning Co

04900039 - 002

Facility Name:

Permit Number:

Subject Item: CE 003 Fabric Filter - Low Temperature, i.e., T<180 Degrees F

Associated Items: EU 012 Buffing Dust Transport









The Permittee shall vent emissions from EU 012 to CE 003 at all times that EU 012is in operation to meet applicable PM and PM10 limits. The Permittee shall operateand maintain the fabric filter at all times that EU 012 is in operation.


MONITORING AND RECORDKEEPING hdr

Visible Emissions: The Permittee shall check CE 003's stack (SV 004) for anyvisible emissions once each day during daylight hours.

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

Recordkeeping of Visible Emissions and Pressure Drop. The Permittee shall recordthe time and date of each visible emissions inspection and pressure drop readingon CE 003, and whether or not any visible emissions were observed, and whetherthe recorded pressure drop was within the range specified in this permit.

Minn. R. 7007.0800, subp. 5


- visible emissions are observed;- the recorded pressure drop is outside the required operating range; or- CE 002 or any of its components are found during the inspections to need repair.

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 Plans for the fabric filter baghouse. The Permittee shall keep a record of thetype and date of any corrective action taken for the control equipment.

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

A-22

TABLE B: SUBMITTALSFacility Name: SB Foot Tanning Co

Permit Number: 04900039 - 002

07/27/05

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.

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 any application for a permit or permit amendment to:

Permit Technical AdvisorPermit SectionAir Quality DivisionMinnesota Pollution Control Agency520 Lafayette Road NorthSt. 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:

SupervisorCompliance Determination UnitAir Quality DivisionMinnesota Pollution Control Agency520 Lafayette Road NorthSt. Paul, Minnesota 55155-4194

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

Mr. George CzerniakAir and Radiation BranchEPA Region V77 West Jackson BoulevardChicago, Illinois 60604

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

U.S. Environmental Protection AgencyClean Air Markets Division1200 Pennsylvania Avenue NW (6204N)Washington, D.C. 20460

B-1

TABLE B: ONE TIME SUBMITTALS OR NOTIFICATIONSFacility Name: SB Foot Tanning Co


07/27/05

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

Permit.Total Facility

Computer Dispersion Modeling Information due 1096 days after 01/29/2004 . Submitmodeling data as specified in MPCA guidancefor Modeling Information Requests (forPM10). This modeling information is for datacollection purposes, no modeling analysis isrequired at this time. This is a state onlyrequirement and is not enforceable by theEPA Administrator or citizens under the CleanAir Act.

Total Facility

B-2

TABLE B: RECURRENT SUBMITTALSFacility Name: SB Foot Tanning Co


07/27/05

What to send When to send Portion of Facility AffectedSemiannual Deviations Report due 30 days after end of each calendar

half-year starting 01/29/2004 . 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 occured, the Permittee shall submit thereport stating no deviations.

Total Facility

Annual Report due 30 days after end of each calendar yearstarting 01/29/2004 . The Permittee shallsubmit an annual report by January 31 thatdescribes the changes made at the facilityduring the pervious calendar year. The reportshall document: 1) the VOC and HAP12-Month Rolling Sum calculations for theprevious year, and 2) any equipment that ismoved, modified, replaced or brought,including its capacity. The report shall besubmitted with the Annual ComplianceCertification. As part of the Annual Report, thePermittee shall verify and certify that thefacility has maintained its minor source statusunder New Source Review.

Total Facility

Compliance Certification due 31 days after end of each calendar yearstarting 01/29/2004 (for the previous calendaryear). To be submitted on a form approvedby the Commissioner <, both to theCommissioner, and to the U.S. EPA regionaloffice in Chicago>. This report covers alldeviations experienced during the calendaryear. < The EPA copy shall be sent to: Mr.George Czerniak, Chief, Air Enforcement andCompliance Assurance Branch, Air andRadiation Division, EPA Region V, 77 WestJackson Boulevard, Chicago, Illinois 60604>

Total Facility

B-3

The DELTA forms that follow constitute Appendix I. (paper copy only)

Under Minn. R. 7007.1250, subp. 1(A), the Permittee may add insignificant activities to the stationary source throughout the term of the permit without getting permit amendments. Certain exclusions apply and are listed in Minn. R. 7007.1250, subp. 2. In addition, this permit specifically prohibits the Permittee from making any modifications that would make the source major under NSR. The following sources at the Permittee’s facility qualify as insignificant activities under Minn. R. 7007.1300, subps. 2, 3 and 4 and are not required to be listed in the permit. Subject Item: Insignificant Activities

Minn. R. 7007.1300, subp.

Rule Description of the Activity and Comments General Applicable Requirement

2(D)(3) Miscellaneous fabricating equipment such as drills, grinders, saws, etc. Minn. R. 7011.0715 (PM and opacity)

3(A) Space heaters fueled by kerosene, natural gas, or propane.

These are the three warehouse and the three makeup air space heaters.

Minn. R. 7011.0715 (PM and opacity)

3(D)(2) Miscellaneous fabricating equipment such as drills, grinders, saws, etc.

These are the:

leather buffer dust removal machine No. 3HEAD-003;

leather box brush dirt removal machines; and

splitting machines.


3(E)(2) VOC tanks with less than 10,000 gallons storage capacity and 1.0 psi vapor pressure.

The tank’s capacity is 2000 gallons and the vapor pressure of the material stored is 0.47 psi.


3(G), 4(B) and 4(C) Laboratory equipment

These are five hoods located in the main plant used for quality assurance and quality control, and a small hand spray coater used to test coatings on small samples of leather which is not sold.


3(H)(1) Miscellaneous Minn. R. 7011.0715 (PM and opacity)

3(H)(4) Brazing, soldering, and welding

This equipment is used for maintenance purposes only.


3(H)(5) Blueprint and photographic process

This equipment is located in an administrative part of the plant.


3(H)(6) Equipment used exclusively for melting or application of wax.

The reverse roll coater is used solely for coating wax onto leather.


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.

SB Foot has several of these individual emissions units, the largest of which have had their emissions calculated by SB Foot and MPCA staff. These are:

12 mmBtu/hr water heater;

a 350 hp emergency diesel fire pump; and,

two leather tumbling mills.

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

or


APPENDIX II: INSIGNIFICANT ACTIVITIES 01/29/04 Facility Name: SB Foot Tanning Co Permit Number: 04900039-001

Subp. 3(J) Fugitive emissions from roads and parking lots Minn. R. 7011.0715 (PM and opacity)

4(A), (B) and (C) Individual emissions units at a stationary source, each of which have a potential to emit the following pollutants in amounts less than:

A. potential emissions of 5.7 lbs/hr or actual emissions of two tons per year of carbon monoxide;

B. potential emissions of 2.28 lbs/hr or actual emissions of one ton per year of nitrogen oxide, sulfur dioxide, particulate matter, particulate matter less than ten microns, or volatile organic compounds

C. individual emissions units that have actual emissions of less than or equal to 1 ton per year of the criteria pollutants, and for hazardous air pollutants, emissions units with potential emissions of less than certain thresholds listed in Minn. R. 7007.1300, subps. 4(C)(1) and (2).

SB Foot has several of these individual emissions units, the largest of which have had their emissions calculated by SB Foot and MPCA staff. These are:

three pasting dryers; toggling dryer; three radio frequency dryers; two air off rooms; and, Cartigliano conditioning dryer.

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

APPENDIX II: INSIGNIFICANT ACTIVITIES (continued) 01/29/04 Facility Name: SB Foot Tanning Co Permit Number: 04900039-001

Minn. R. 7011.0075, subps. 2(A) through 2(I) (Maintenance of control equipment) The owner or operator of a stationary source shall maintain each piece of listed control equipment according to the control equipment manufacturer's specifications, shall comply with source-specific maintenance requirements specified in a part 70, state, or general permit, and shall perform the following on each piece of listed control equipment:

A. maintain an inventory of spare parts that are subject to frequent replacement, as required by the

manufacturing specification or documented in records under items H and I;

B. train staff on the operation and monitoring of control equipment and troubleshooting, and train and require staff to respond to indications of malfunctioning equipment, including alarms and other indicators of abnormal operation;

C. thoroughly inspect all control equipment at least annually, or as required by the manufacturing

specification (this often requires shutting down temporarily);

D. inspect monthly, or as required by the manufacturing specification, components that are subject to wear or plugging, for example: bearings, belts, hoses, fans, nozzles, orifices, and ducts;

E. inspect quarterly, or as required by the manufacturing specification, components that are not

subject to wear including structural components, housings, ducts, and hoods;

F. check daily, or as required by the manufacturing specification, monitoring equipment, for example: pressure gauges, chart recorders, temperature indicators, and recorders;

G. calibrate annually, or as required by the manufacturing specification, all monitoring equipment;

H. maintain a record of activities conducted in items A to G consisting of the activity completed, the

date the activity was completed, and any corrective action taken; and

I. maintain a record of parts replaced, repaired, or modified for the previous five years.

APPENDIX III: CONTROL EQUIPMENT REQUIREMENTS FOR GP 004 01/29/04

Facility Name: SB Foot Tanning Co Permit Number: 04900039-001

Capture, Control and Transfer Efficiencies to be Used in PM/PM10 Compliance Demonstration Calculations for GP 001 Unit

Capture Efficiency

(%)

Collection Efficiency (%)

Overall Control Efficiency (%)

Water Curtains PM PM10 PM PM10

CE 004 80 95 92 76 73.6

CE 005 80 95 92 76 73.6

CE 006 80 95 92 76 73.6

CE 007 80 95 92 76 73.6

Panel Filters PM/PM10 PM/PM10

CE 009 100 92 92

CE 012 100 92 92

CE 013 100 92 92

CE 014 100 92 92

Buffing Equipment Cyclone & Filters

PM/PM10 PM/PM10

CE 001 100 50 50

CE 002 100 99 99

CE 003 100 99 99

CE 015 100 99 99 Unit

Transfer Efficiency (%)

Spray Booths

EU 024 (AB-12) 30

EU 026 (AB-13) 45

EU 031 (AB-15) 45

EU 032 (AB-16) 45

Spray Hide Line

EU 038 65

EU 039 65

EU 040 65

EU 041 65

APPENDIX IV: CAPTURE, CONTROL AND TRANSFER EFFICIENCIES TO BE USED FOR GP 001 01/29/04

Facility Name: SB Foot Tanning Co Permit Number: 04900039-001

Technical Support Document, Permit Action Number: {facility_id} - {action_id} Page 1 of 4 Date: 7/28/2005

TECHNICAL SUPPORT DOCUMENT For

DRAFT/PROPOSED AIR EMISSION PERMIT NO. 04900039-002 This Technical Support Document (TSD) is intended for all parties interested in the draft/proposed permit and to meet the requirements that have been set forth by the federal and state regulations (40 CFR § 70.7(a)(5) and Minn. R. 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 preliminary determination to issue the draft/proposed permit. 1. General Information 1.1. Applicant and Stationary Source Location:

Applicant/Address Stationary Source/Address (SIC Code: 3111)

S B Foot Tanning Company 805 and 1875 Bench Street Red Wing, MN 55066-0073

805 Bench Street Red Wing

Goodhue County Contact: John Smith

Phone: (651) 388-4731

1.2. Description of the Permit Action SB Foot Tanning Company (SB Foot) processes leather used in clothing, footwear, furniture and shelter. The main processes include buffing, buffing dust transport, surface coating & drying, and the combustion of natural gas and fuel oil. The facility also has several insignificant activities (see Appendix II of this permit). The buffers and dust transport emit Particulate Matter (PM), Particulate Matter less than 10 microns (PM10) and chromium dust, a particulate Hazardous Air Pollutant (HAP), and are currently controlled with two fabric filter systems. The coating operations emit Volatile Organic Compounds (VOC), several HAPs, and PM/PM10. They have either wall filters or water curtains to control PM/PM10, and the two vacuum dryers have vapor condensers to control VOCs and HAPs.

Because potential emissions of a single HAP, methyl isobutyl ketone, are greater than 10 tons per year (tpy), and total HAP potentials are greater than 25 tpy, the facility is major for Part 70 and is subject to a promulgated National Emissions Standard for Hazardous Air Pollutants (NESHAP) for Leather Finishing Operations (40 CFR pt. 63, subp. TTTT). Recordkeeping requirements under the NESHAP become effective February 27, 2004, and the emission limits take effect February 27, 2005.

For New Source Review (NSR), this facility is not among the 28 industrial source categories listed in the Prevention of Significant Deterioration (PSD) rules (40 CFR § 52.21). Therefore, under PSD rules, the major source threshold is 250 tons per year of any single regulated (criteria)


pollutant. The permit contains operational and control requirements that limit emissions of VOCs, HAPs, and PM/PM10 below 250 tons per year.


1.3 Description of the Activities Allowed by this Permit Action

This amendment changes the pressure drop requirements for the cyclone (CE001), a baghouse (CE002), and a cartridge filter (CE015). The pressure drop requirements were set prior to measuring the pressure drop during operation. This amendment changes the requirements to reflect actual operation and manufacturer’s recommendations. 1.4. Facility Emissions: No emission changes will result from the permit changes. 2. Regulatory and/or Statutory Basis The proposed changes do not change the status of the facility, or subject it or any emission units to any changes in any applicable regulations.

Table 5. Regulatory Overview of Units Affected by the Modification/Permit Amendment

EU, GP, or SV

Applicable Regulations

Comments:

GP 004 Includes CE001, CE002, and CE015

40 CFR § 52.21

Pressure drop limits on control equipment are set as Title I Conditions to keep the facility non-major under the federal new source review program. This amendment changes those limits. Emissions are not affected.

3. Technical Information SB Foot has submitted information that more accurately reflects the proper operating conditions of its control equipment (see attached.) For CE001, a cyclone, the pressure drop is consistent with the manner in which it has historically been operated. The previous permit set the lower operating limit at 1 inch water column. Once installed, however, the pressure gauge showed that the cyclone typically operates at 0.88 to 1.03 inches water column. This permit amendment changes the lower operating limit to 0.5 inches water column. For CE002, a baghouse, the manufacturer of a similar SB Foot baghouse recommends an operating range of 0.5 to 4 inches water column. The previous permit set the lower operating limit at 2 inches of water column. This amendment changes that lower limit to 0.5 inches water column.


For CE003, a cartridge filter, the manufacturer has recommended an operating range of 0.5 inches to 5 inches water column. The previous permit set the lower operating limit at 2 inches water column. This amendment changes the lower limit to 0.5 inches water column. 3.1 Comments Received Public Notice Period: <start date> - <end date> EPA 45-day Review Period: <start date> - <end date> 4. Conclusion Based on the information provided by SB Foot, the MPCA has reasonable assurance that the proposed operation of the emission facility, as described in the Air Emission Permit No. 04900039-002, and this TSD, will not cause or contribute to a violation of applicable federal regulations and Minnesota Rules. Staff Members on Permit Team: Jenny Reinertsen (permit writer/engineer) Greg Berger (enforcement) Daniel P. Sullivan (peer reviewer)

Attachments: Information submitted by SB Foot

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