Intent to Issue Air Emission Permit to Enviro-Chem Inc ... Permit - 053004… · Enviro-Chem...

Draft Air Individual Permit

State Reissuance 05300411-101

Permittee: Enviro-Chem Inc - Plant 1

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

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

Signature: [ ] This document has been electronically signed. for the Minnesota Pollution Control Agency

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

Permit issued: [month day, year] 05300411-101 Permit expires: [month day, year] of 26

Table of Contents

Page

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

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


1. Permit applications table

Permit applications: Title description Application receipt date Action number State Reissuance 11/22/2011, with supplemental

information received on 11/08/2019 05300411-101

Minor Amendment 07/28/2016 05300411-101 Reopening 02/11/2011 05300411- 101


2. Where to send submittals

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

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

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

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

Send any application for a permit or permit amendment to:

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

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

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

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

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

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

mailto:[email protected]

mailto:[email protected]

http://www.pca.state.mn.us/nwqh472


3. Facility description

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


4. Summary of subject items

SI ID: Description

Relationship type

Related SI ID: Description

TFAC 1: Enviro-Chem Inc - Plant 1

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

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

EQUI 9: Smelting Furnace - Medium Crucible Furnace

sends to STRU 2: General emissions (roof vent)

EQUI 10: Smelting Furnace - Tilt Furnace #1

sends to STRU 1: Baghouse emissions




is controlled by

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

EQUI 12: Smelting Furnace - Medium Tilt Furnace





is controlled by


EQUI 17: Waste Combustor Film #1



is controlled by

TREA 6: Direct Flame Afterburner


is controlled by

TREA 17: Fabric Filter - Medium Temperature

SI ID: Description

Relationship type

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




is controlled by



is controlled by





is controlled by



is controlled by





is controlled by



is controlled by


EQUI 21: Waste Combustor (Assay, Small Lot)



is controlled by



is controlled by

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


SI ID: Description

Relationship type

Related SI ID: Description F<T<250 F




is controlled by



is controlled by


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

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


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


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


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

EQUI 24: Afterburner Temp Probe (TREA 6)


EQUI 26: Baghouse Inlet Temperature

SI ID: Description

Relationship type

Related SI ID: Description

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

STRU 1: Baghouse emissions

STRU 2: General emissions (roof vent)

STRU 3: Precipitation emissions


is monitored by



is controlled in series by



is monitored by



is controlled in series by



is monitored by

EQUI 26: Baghouse Inlet Temperature Probe (TREA 17)


is monitored by

EQUI 27: Baghouse Pressure Drop Probe (TREA 17)

Permit Issued: [month day, year] 05300411-101 Permit Expires: [month day, year] of 26

5. Limits and other requirements

Requirement number Requirement and citation TFAC 1 Enviro-Chem Inc - Plant 1 5.1.1 Permit Appendices: This permit contains appendices as listed in the permit Table of Contents. The

Permittee shall comply with all requirements contained in Appendix A: Insignificant Activities and Applicable Requirements, Appendix B: Industrial Solid Waste Management Plan, Appendix C: Ash Management Plan, and Appendix D: Mercury Waste Separation Plan. [Minn. R. 7007.0800, subp. 2]

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

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

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

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

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

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

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

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

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

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


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

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

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

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

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

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

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

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

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


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

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

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

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

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

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

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

5.1.26 Emission Fees: due 30 days after receipt of an MPCA bill. [Minn. R. 7002.0005-7002.0085] COMG 1 Six Class IV Waste Combustors


Requirement number Requirement and citation 5.2.1 Particulate Matter <= 0.035 grains per dry standard cubic foot corrected to 7% oxygen on a dry

volume basis. [Minn. R. 7011.1225, subp. 5] 5.2.2 Opacity <= 20 percent opacity. [Minn. R. 7011.1225, subp. 5] 5.2.3 Carbon Monoxide <= 50 parts per million corrected to 7% oxygen on a dry volume basis. [Minn. R.

7011.1225, subp. 5] 5.2.4 Use of Auxiliary Fuel: Auxiliary fuel shall be used to maintain the operating temperatures required

below from the time the solid waste feed has been discontinued until the combustion chamber is clear of combustible material or active combustion ceases to exist in the combustion chamber. [Minn. R. 7011.1235, subp. 2a]

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

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

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

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

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

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

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


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

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

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

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

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

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

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


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

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

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

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

EQUI 9 Smelting Furnace - Medium Crucible Furnace 5.3.1 Particulate Matter <= 0.4 pounds per million Btu heat input. The potential to emit from the unit is

0.21 lb/MMBtu due to equipment design and allowable fuels. [Minn. R. 7011.0515, subp. 1] 5.3.2 Opacity <= 20 percent opacity except for one six-minute period per hour of not more than 60 percent

opacity. [Minn. R. 7011.0515, subp. 2]


Requirement number Requirement and citation 5.3.3 Fuel type: Natural gas only, by design. [Minn. R. 7005.0100, subp. 35a] 5.3.4 The Permittee shall keep records of fuel purchases showing fuel types. [Minn. R. 7007.0800, subp. 5] EQUI 10 Smelting Furnace - Tilt Furnace #1 5.4.1 Particulate Matter <= 0.4 pounds per million Btu heat input. The potential to emit from the unit is


opacity. [Minn. R. 7011.0515, subp. 2] 5.4.3 Fuel type: Natural gas only, by design. [Minn. R. 7005.0100, subp. 35a] 5.4.4 The Permittee shall keep records of fuel purchases showing fuel types. [Minn. R. 7007.0800, subp. 5] 5.4.5 The Permittee shall vent emissions from EQUI 10 to control equipment meeting the requirements of

TREA 17 whenever EQUI 10 operates. [Minn. R. 7007.0800, subp. 2] 5.4.6 Hood Certification and Evaluation: The Permittee shall maintain the most current record of the hood

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

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

EQUI 12 Smelting Furnace - Medium Tilt Furnace 5.5.1 Particulate Matter <= 0.4 pounds per million Btu heat input. The potential to emit from the unit is


opacity. [Minn. R. 7011.0515, subp. 2] 5.5.3 Fuel type: Natural gas only, by design. [Minn. R. 7005.0100, subp. 35a] 5.5.4 The Permittee shall keep records of fuel purchases showing fuel types. [Minn. R. 7007.0800, subp. 5] 5.5.5 The Permittee shall vent emissions from EQUI 12 to control equipment meeting the requirements of

TREA 17 whenever EQUI 12 operates. [Minn. R. 7007.0800, subp. 2] 5.5.6 Hood Certification and Evaluation: The Permittee shall maintain the most current record of the hood

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

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


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

EQUI 17 Waste Combustor Film #1 5.6.1 The Permittee shall vent emissions from EQUI 17 to control equipment meeting the requirements of

TREA 6 and TREA 17 in series whenever EQUI 17 operates. [Minn. R. 7007.0800, subp. 2, Minn. R. 7011.1235, subp. 2]







EQUI 21 Waste Combustor (Assay, Small Lot) 5.10.1 The Permittee shall vent emissions from EQUI 21 to control equipment meeting the requirements of




STRU 1 Baghouse emissions 5.12.1 Particulate Matter <= 2.0 pounds per hour. [Minn. R. 7007.0800, subp. 2] TREA 6 Direct Flame Afterburner 5.13.1 The Permittee shall operate and maintain control equipment such that it achieves an overall

efficiency for Carbon Monoxide >= 95.0 percent control efficiency. [Minn. R. 7007.0800, subp. 2] 5.13.2 The Permittee shall operate and maintain control equipment such that it achieves an overall control

efficiency for, Volatile Organic Compounds >= 99.0 percent control efficiency. [Minn. R. 7007.0800, subp. 2]

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

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

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


Requirement number Requirement and citation 5.13.6 If the Permittee replaces TREA 6, the replacement control must meet or exceed the control efficiency

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

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

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

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

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

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

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

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

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


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

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

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

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

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

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

TREA 8 Direct Flame Afterburner 5.14.1 The Permittee shall operate and maintain control equipment such that it achieves an overall control

efficiency for Carbon Monoxide >= 95.0 percent control efficiency. [Minn. R. 7007.0800, subp. 2] 5.14.2 The Permittee shall operate and maintain control equipment such that it achieves an overall control

efficiency for, Volatile Organic Compounds >= 99.0 percent control efficiency. [Minn. R. 7007.0800, subp. 2]

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

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

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

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


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

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

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

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

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

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

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

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

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

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


Requirement number Requirement and citation 5.14.16 Annual Calibration: The Permittee shall calibrate the temperature monitor at least once every 12

months and shall maintain a written record of the calibration and any action resulting from the calibration. [Minn. R. 7007.0800, subp. 14, Minn. R. 7007.0800, subp. 4, Minn. R. 7007.0800, subp. 5]

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

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

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

TREA 17 Fabric Filter - Medium Temperature i.e., 180 F<T<250 F 5.15.1 The Permittee shall operate and maintain control equipment such that it achieves a control efficiency

for Particulate Matter >= 99.0 percent control efficiency. [Minn. R. 7007.0800, subp. 2] 5.15.2 The Permittee shall operate and maintain control equipment such that it achieves a control efficiency

for PM < 10 micron >= 93.0 percent control efficiency. [Minn. R. 7007.0800, subp. 2(A)] 5.15.3 The Permittee shall operate and maintain control equipment such that it achieves a control efficiency

for PM < 2.5 micron >= 93.0 percent control efficiency. [Minn. R. 7007.0800, subp. 2(A)] 5.15.4 Pressure Drop >= 0.5 and <= 4.5 inches of water, unless a new range is set pursuant to Minn. R.

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

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

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


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

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

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

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

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

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

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

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

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


6. Submittal/action requirements

This section lists most of the submittals required by this permit. Please note that some submittal requirements may appear in the Limits and Other Requirements section, or, if applicable, within a Compliance Schedule section. Requirement number Requirement and citation TFAC 1 Enviro-Chem Inc - Plant 1 6.1.1 The Permittee shall submit a semiannual deviations report : Due semiannually, by the 30th of January

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

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

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

COMG 1 Six Class IV Waste Combustors 6.2.1 Ash Testing: due before end of each 60 months starting 1/19/2025; The Permittee shall conduct

testing for ash in accordance with Minn. R. 7045.0131 for toxic characteristic leach procedure for arsenic, barium, cadmium, chromium, lead, mercury, selenium and nickel. The Permittee shall include the weight percent of arsenic, barium, cadmium, chromium, lead, mercury, selenium and nickel with the ash test results. [Minn. R. 7011.1270(D)]

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

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

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


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

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

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

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


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

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

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

7. Compliance schedule

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


Requirement number Requirement and Citation EQUI 10 Smelting Furnace - Tilt Furnace #1 7.1.1 The Permittee shall submit a report: Due 30 calendar days after permit issuance that certifies that the

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

EQUI 12 Smelting Furnace - Medium Tilt Furnace 7.2.1 The Permittee shall submit a report: Due 30 calendar days after permit issuance that certifies that the

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

8. Appendices

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

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

Minn. R. 7007.1300, subp. 3(D) Emissions from a laboratory, as defined in Minn. R. 7007.1300, subp. 3(D). The Permittee operates a laboratory for quality control purposes. The Permittee operates an assay smelting furnace where small quantities of sample are smelted and tested in the laboratory.

PM <= 0.30 grains per dry standard cubic foot of exhaust gas Opacity <= 20 percent opacity. (Minn. R. 7011.0715) PM <= 0.4 lb/MMBtu Opacity <= 20% with exceptions (Minn. R. 7011.0515)

Minn. R. 7007.1300, subp. 3(F) Individual units with potential emissions less than 2000 lb/year of certain pollutants The Permittee operates five natural gas fired heaters, a natural gas fired office furnace, a natural gas fired make-up air unit, and a natural gas fired water heater. The Permittee operates a small hammermill / screening operation for grinding silver oxide button batteries.

PM <= 0.4 lb/MMBtu Opacity <= 20% with exceptions (Minn. R. 7011.0515) PM <= 0.30 grains per dry standard cubic foot of exhaust gas Opacity <= 20 percent opacity. (Minn. R. 7011.0715)


Appendix B: Industrial Solid Waste Management Plan


Ash Management Plan & Mercury Separation Plan

Appendix C: Ash Management Plan

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

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

Intent to Issue Air Emission Permit to Enviro-Chem Inc ... Permit - 053004… · Enviro-Chem...

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