Air Emission Permit No. 05300028-003 Is Issued to Electric ... · Electric Machinery Company Inc...

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. 05300028-003 Major Amendment

IS ISSUED TO

Converteam Inc.

Electric Machinery Company Inc.

800 Northeast Central Avenue Minneapolis, Hennepin County, MN 55413

The emission units, control equipment and emission stacks at the stationary source authorized in this permit amendment are as described in the Permit Applications Table. This permit amendment supersedes Air Emission Permit No. 05300028-002 and authorizes the Permittee to operate and modify the stationary source at the address listed above unless otherwise noted in Table A. The Permittee must comply with all the conditions of the permit. Any changes or modifications to the stationary source must be performed in compliance with Minn. R. 7007.1150 to 7007.1500. Terms used in the permit are as defined in the state air pollution control rules unless the term is explicitly defined in the permit. Unless otherwise indicated, all the Minnesota rules cited as the origin of the permit terms are incorporated into the SIP under 40 CFR § 52.1220, and as such as are enforceable by U.S. Environmental Protection Agency (EPA) Administrator or citizens under the Clean Air Act. Permit Type: State; Limits to Avoid Pt 70/Limits to Avoid NSR

Operating Permit Issue Date: June 27, 1997

Major Amendment Issue Date: October 12, 2009

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

Permit Applications Table

Permit Type Application Date Permit Action

Total Facility Operating Permit June 15, 1995 001 Administrative Amendment April 4, 1999 002 Major Amendment August 3, 2009 003

TABLE OF CONTENTS

Notice to the Permittee Permit Shield Facility Description Amendment Description Table A: Limits and Other Requirements Table B: Submittals Table C: Not used in this permit

Appendix I: Insignificant Activities Appendix II: Maximum Materials Contents and Application Rates

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: Electric Machinery Company Inc (formerly Dresser-Rand Electric Machinery) manufactures customized electric motors and generators for domestic and foreign markets, which are used in all types of industries, including electric utilities, petrochemicals, and mining. Motors and generators are made for the 500 to 50,000 horsepower service range and weigh 2,000 to 200,000 pounds. Plant activities include welding, machining, epoxy impregnating and curing, painting, assembly and testing. AMENDMENT DESCRIPTION: Permit Action 002:

This administrative amendment was to change the name of the facility from Dresser-Rand Electric Machinery to Electric Machinery Company, Inc. The owner is now Ideal Electric Holding Company.

Permit Action 003:

This major amendment is for the construction of a new paint booth at the facility. The paint booth was added under the existing emissions limit; therefore, there may be a lb/hr increase in emissions but there will be no increase in tons per year of emissions. Precap language was also added to allow the replacement and addition of paint booths to GP 001 without automatically requiring a major amendment. EU’s 016, 017, 021, 023, and 024 were moved to the insignificant activities list. The new owner of the facility is Converteam Inc.

TABLE A: LIMITS AND OTHER REQUIREMENTS 10/12/09

Electric Machinery Co Inc

05300028 - 003

Facility Name:

Permit Number:

A-1

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

Subject Item: Total Facility

What to do Why to do itSOURCE-SPECIFIC REQUIREMENTS hdr

Permit Appendices: This permit contains appendices as listed in the permit Table ofContents. The Permittee shall comply with all requirements contained in theappendices.

Minn. R. 7007.0800, subp. 2

OPERATIONAL REQUIREMENTS hdr

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.

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

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

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

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

Minn. R. 7019.1000, subp. 4

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

Minn. R. 7011.0150

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

Minn. R. 7030.0010 - 7030.0080

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

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

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

Minn. R. 7007.0800, subp. 16

PERFORMANCE TESTING 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 Table A of the permit.See Table B 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

The Notification, Test Plan, and Test Report may be submitted in alternative formatas allowed by Minn. R. 7017.2018.

Minn. R. 7017.2018;Minn. R. 7017.2030, subps. 1-4;Minn. R. 7017.2035, subps. 1-2



05300028 - 003

Facility Name:

Permit Number:

A-2

Limits set as a result of a performance test (conducted before or after permitissuance) apply until superseded as stated in the MPCA's Notice of Complianceletter granting preliminary approval. Preliminary approval is based on formal reviewof 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 amendmentincorporating the change.

Minn. R. 7017.2025, subp. 3

MONITORING REQUIREMENTS hdr

Monitoring Equipment Calibration: The Permittee shall calibrate all requiredmonitoring equipment at least once every 12 months.

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)

RECORDKEEPING hdr

Recordkeeping: Retain all records at the stationary source, unless otherwisespecified 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 locationinclude all calibration and maintenance records, all original recordings forcontinuous monitoring instrumentation, and copies of all reports required by thepermit. Records must conform to the requirements listed in Minn. R. 7007.0800,subp. 5(A).

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

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

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

If the Permittee determines that no permit amendment or notification is requiredprior to making a change, the Permittee must retain records of all calculationsrequired under Minn. R. 7007.1200. These records shall be kept for a period of fiveyears from the date that the change was made. The records shall be kept at thestationary source for the current calendar year of operation and may be kept at thestationary source or office of the stationary source for all other years. The recordsmay be maintained in either electronic or paper format.

Minn. R. 7007.1200, subp. 4

REPORTING/SUBMITTALS hdr

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

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

Minn. R. 7019.1000, subp. 3

Breakdown Notifications: Notify the Commissioner within 24 hours of a breakdownof more than one hour duration of any control equipment or process equipment ifthe breakdown causes any increase in the emissions of any regulated air pollutant.The 24-hour time period starts when the breakdown was discovered or reasonablyshould have been discovered by the owner or operator. However, notification is notrequired in the circumstances outlined in Items A, B and C of Minn. R. 7019.1000,subp. 2.

At the time of notification or as soon as possible thereafter, the owner or operatorshall inform the Commissioner of the cause of the breakdown and the estimatedduration. The owner or operator shall notify the Commissioner when 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



05300028 - 003

Facility Name:

Permit Number:

A-3

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

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

Minn. R. 7007.1150 - 7007.1500

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

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

Emission Inventory Report: due on or before April 1 of each calendar year followingpermit issuance, to be submitted on a form approved by the Commissioner.

Minn. R. 7019.3000 - 7019.3100

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



05300028 - 003

Facility Name:

Permit Number:

A-4

Subject Item: GP 001 Painting, Curing, and Cleanup

Associated Items: CE 001 Mat or Panel Filter

CE 002 Mat or Panel Filter






EU 013 Primer Paint Booth

EU 014 Paint Booth #7

EU 015 Topcoat Paint Booth

EU 025 Paint Booth

What to do Why to do itThe Permittee is authorized to construct EU 025 and CE 009. The constructionauthorization expires 18 months after permit issuance. The Permittee must keep arecord of the dates of installation and start-up on site. The Permittee may apply foran extension of the construction authorization deadline by following theAdministrative Amendment provisions in Minn. R. 7007.1400.

Minn. R. 7007.0800, subp. 2

EMISSION 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 lessstringent limit of either Minn. R. 7011.0730 or Minn. R. 7011.0735. This limitapplies to each unit individually.

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

Opacity: less than or equal to 20 percent opacity . This limit applies to each unitindividually.

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

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: To avoid classification as a majorsource and modification under 40 CFR Section 52.21and Minn. R. 7007.3000

Volatile Organic Compounds: less than or equal to 35.0 tons/year using 12-monthRolling Sum . Monthly purchases of VOC-containing materials and the 12-monthrolling sum shall be computed and recorded by the 15th day of the following month.VOC content shall be determined as described under the Material Contentrequirement. All VOC-emitting equipment at the Facility is subject to this limit.If the Permittee replaces any existing VOC-emitting equipment, adds newVOC-emitting equipment, or modifies the existing equipment, such equipment issubject to this permit limit as well as all of the requirements of GP 001. Prior tomaking such a change, the Permittee shall apply for and obtain the appropriatepermit amendment, as applicable. The Permittee is not required to complete VOCcalculations described in Minn. R. 7007.1200, subp. 2. A permit amendment willstill be needed regardless of the emissions increase if the change will be subject toa new applicable requirement or requires revisions to the limits or monitoring andrecordkeeping in this permit.

Title I Condition: To avoid major source classificationunder 40 CFR Section 52.21 and Minn. R. 7007.3000;To avoid major source classification under 40 CFRSection 70.2 and 40 CFR Section 63.2

HAPs - Total: less than or equal to 22.0 tons/year using 12-month Rolling Sum .Monthly purchases of HAP-containing materials and the 12-month rolling sum shallbe computed and recorded by the 15th day of the following month. HAP contentshall be determined as described under the Material Content requirement. AllHAP-emitting equipment at the Facility is covered by this limit.If the Permittee replaces any existing HAP-emitting equipment or adds newHAP-emitting equipment, such equipment is subject to this permit limit as well as allof the requirements of GP 001. Prior to making such a change, the Permittee shallapply for and obtain the appropriate permit amendment, as applicable. A permitamendment may be needed if the change will be subject to a new applicablerequirement or requires revisions to limits or the monitoring and recordkeeping inthis permit.

Limit to avoid major classification under 40 CFRSection 70.2 and 40 CFR Section 63.2



05300028 - 003

Facility Name:

Permit Number:

A-5

Single HAP Usage: less than or equal to 9.0 tons/year using 12-month Rolling Sum. Monthly purchases of Individual HAP-containing materials and the 12-monthrolling sum shall be computed and recorded by the 15th day of the following month.HAP content shall be determined as described under the Material Contentrequirement. All HAP-emitting equipment at the Facility is covered by this limit.If the Permittee replaces any existing HAP-emitting equipment or adds newHAP-emitting equipment, such equipment is subject to this permit limit as well as allof the requirements of GP 001. Prior to making such a change, the Permittee shallapply for and obtain the appropriate permit amendment, as applicable. A permitamendment may be needed if the change will be subject to a new applicablerequirement or requires revisions to limits or the monitoring and recordkeeping inthis permit.

Limit to avoid major source classification under 40CFR Section 70.2 and 40 CFR Section 63.2

Maximum Contents of Materials and Application Rate: The Permittee assumedcertain materials contents and application rates when determining the annual andshort term potential to emit of units in GP 001. These assumptions are listed inAppendix II of this permit. Changing to a material that has a higher content ofVOCs or solids, or increasing the application rate is considered a change in methodof operation that must be evaluated under Minn. R. 7007.1200, subp. 3 todetermine if a permit amendment or notification is required under Minn. R.7007.1150.

Minn. R. 7005.0100, subp. 35a

CONTROL EQUIPMENT hdr

The Permittee shall vent emissions from GP 001, including existing, modified, ornew units, to mat or panel filters meeting the permit requirements for GP 001.

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

If the Permittee replaces any existing panel filter, adds new panel filters, or modifiesthe panel filter listed in GP 001, such equipment is subject to all of therequirements of GP 001. Prior to making such a change, the Permittee shall applyfor and obtain the appropriate permit amendment, as applicable.

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

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

Minn. R. 7007.0800, subps. 2 and 14

The Permittee shall operate and maintain the control equipment such that itachieves an overall control efficiency, for PM < 10 micron: greater than or equal to68 percent control efficiency

Minn. R. 7007.0800, subps. 2 and 14

The Permittee shall operate and maintain the control equipment such that itachieves an overall control efficiency, for PM < 2.5 micron: greater than or equal to68.0 percent control efficiency

Minn. R. 7007.0800, subps. 2 and 14

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.

Minn. R. 7007.0800, subps. 4 and 5

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

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

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

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

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

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

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

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

MONITORING AND RECORDKEEPING hdr

Monthly Recordkeeping. Each month of operation, the Permittee shall calculate,record, and maintain the total quantity of all coatings and other VOC and HAPcontaining materials used at the facility. This shall be based on written usage logs.




05300028 - 003

Facility Name:

Permit Number:

A-6

Monthly Recordkeeping -- VOC Emissions.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 monthly usage records. This record shall also include the VOC and solidscontents of each material as determined by the Material Content requirement of thispermit;

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

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, subps. 4 and 5

Monthly Calculation -- VOC Emissions.The Permittee shall calculate VOC emissions using the following equations:

VOC (tons/month) = V - WV = (A1 x B1) + (A2 x B2) + (A3 x B3) + .....W = (C1 x D1) + (C2 x D2) + C3 x D3) + .....

where:V = total VOC used in tons/month;A# = amount of each VOC-containing material used, in tons/month;B# = weight percent VOC in A#, as a fraction;W = the amount of VOC shipped in waste, in tons/month;C# = amount, in tons/month, of each VOC-containing waste material shipped. If thePermittee chooses to not take credit for waste shipments, this parameter would bezero; andD# = weight percent of VOC in C#, as a fraction.

Minn. R. 7007.0800, subps. 4 and 5

Waste Credit: If the Permittee elects to obtain credit for HAPs, solids, and/or VOCshipped in waste materials, the Permittee shall either use item 1 or 2 to determinethe VOC, solids, and/or total and individual HAP content for each credited shipment.

1) The Permittee shall analyze a composite sample of each waste shipment todetermine the weight content of VOC, solids, total HAP, and each individual HAP,excluding water.

2) The Permittee may use supplier data for raw materials to determine the VOC,solids, and total and individual HAP contents of each waste shipment, using thesame content data used to determine the content of raw materials. If the wastecontains several materials, the content of mixed waste shall be assumed to be thelowest VOC, solids, and total and individual HAP content of any of the materials.

Minn. R. 7007.0800, subps. 4 and 5

Material Content: HAP and VOC content shall be determined by the Material SafetyData Sheet (MSDS) provided by the supplier for each material used. If a materialcontent range is given on the MSDS, the highest number in the range shall be usedin all calculations. Other alternative methods approved by the MPCA may also beused to determine the VOC and HAP content. The Division Manager reserves theright to require the Permittee to take samples of the VOC and HAP containingmaterials, and to conduct analysis of VOC and HAP content as per EPA referencemethods. If the EPA reference method is used, it shall supersede the MSDS.


Equipment Labeling: The Permittee shall permanently affix a unique number toeach emissions 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. If equipment is added, itshall be given a new unique number; numbers from replaced or removedequipment shall not be reused.

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 prior to making the pre-authorizedchange.

The list shall correlate the units to the numbers used in this permit (EU, GP, CE)and shall include the data on GI-04, GI-05B, and GI-05C. The date of constructionshall be the date the change was made for replaced, modified, or new equipment.

Minn. R. 7007.0800, subp. 2



05300028 - 003

Facility Name:

Permit Number:

A-7

Subject Item: GP 002 Boilers

Associated Items: EU 003 Boiler #6

EU 004 Boiler #7

What to do Why to do itTotal Particulate Matter: less than or equal to 0.40 lbs/million Btu heat input . Thislimit applies to each unit individually. The potential to emit from either unit is 0.013lb/MMBtu due to equipment design and allowable fuels.

Minn. R. 7011.0510, subp. 1

Sulfur Dioxide: less than or equal to 2.0 lbs/million Btu heat input . This limitapplies to each unit individually when burning liquid fuel.. The potential to emitfrom either unit is 0.05 lb/MMBtu due to equipment design and allowable fuels.

Minn. R. 7011.0510, 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 limit applies to each unitindividually.

Minn. R. 7011.0510, subp. 2

Fuel Type: Natural gas and No. 2 Fuel Oil only. Minn. R. 7005.0100, subp. 35a



05300028 - 003

Facility Name:

Permit Number:

A-8

Subject Item: GP 003 Ovens

Associated Items: EU 005 Welding bake oven

EU 006 Shrink oven

EU 007 Curing oven

EU 008 Curing oven

EU 009 Curing oven

EU 010 Curing oven

EU 011 Curing oven

EU 012 Curing oven

EU 018 Curing oven

EU 019 Coil forming oven

EU 020 Stress oven

EU 022 Heat treatment oven

What to do Why to do itTotal Particulate Matter: less than or equal to 0.30 grains/dry standard cubic footunless required to further reduce emissions to comply with less stringent limit ofeither Minn. R. 7011.0730 or Minn. R. 7011.0735. This limit applies to each unitindividually.

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 limit applies to each unitindividually.

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



05300028 - 003

Facility Name:

Permit Number:

A-9

Subject Item: EU 026 Space Heaters

What to do Why to do itThis group includes the space heaters identified in the application as "insignificantactivities." These emission units qualify individually as insignificant activities;however, when combined they are a significant source of emissions. The permitincludes emission limits such that the facility is a non-major source under NSR, andthe potential emissions of the units must be included in the permit and emissioninventory.

The Permittee shall maintain a written list of all emissions units included in EU 026(see Appendix I). The Permittee shall update the list to include any replaced,modified, or new equipment prior to making the change. The list shall contain theManufacturer, Model Number, and Heating Capacity of the space heater. The dateof construction shall be the date the change was made for replaced, modified, ornew equipment.

Minn. R. 7007.0800, subp. 2

TABLE B: SUBMITTALSFacility Name: Electric Machinery Co Inc

Permit Number: 05300028 - 003

10/12/09B-1

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.

Send any application for a permit or permit amendment to:

AQ Permit Technical Advisor Industrial Division Minnesota Pollution Control Agency 520 Lafayette Road North St. Paul, Minnesota 55155-4194

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.

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

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

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

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

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

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

TABLE B: RECURRENT SUBMITTALSFacility Name: Electric Machinery Co Inc

Permit Number: 05300028 - 003

10/12/09B-2

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

half-year following Permit Issuance. The firstsemiannual report submitted by the Permitteeshall cover the calendar half-year in which thepermit is issued. The first report of eachcalendar year covers January 1 - June 30.The second report of each calendar yearcovers July 1 - December 31. If no deviationshave occurred, the Permittee shall submit thereport stating no deviations.

Total Facility

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

GP001

Compliance Certification due 31 days after end of each calendar yearfollowing Permit Issuance (for the previouscalendar year). The Permittee shall submitthis to the Commissioner on a form approvedby the Commissioner. This report covers alldeviations experienced during the calendaryear.

Total Facility

APPENDIX I Facility Name: Electric Machinery Company Inc. Permit Number: 05300028-003

Insignificant Activities and Applicable Requirements Minn. R.

7007.1300, subpart

Rule Description of the Activity Applicable Requirement

3(A) Fuel Use: Space Heaters Btu/hr • Rupp CFAM-233 5,465,000 • Mammoth 72126 2,925,000 • Dispatch DMAS-25 3,750,000 • Rupp DCU-22 1,925,000 • National Champion FA-18-HRS 750,000 • National Champion RA-22-FIRS 1,100,000 • Rupp CFA-l5 495,000 • National Champion PH-27-HRS 2,310,000 • National Champion MA-30-HRS 5,500,000 • Dispatch DMHS36HBR 7,500,000 Total: 31,720,000

Minn. R. 7007.0600

3(G) Emissions from a laboratory, as defined in the subpart. • Water testing agents used in the laboratory

Minn. R. 7011.0710/0715

3(H) Miscellaneous: 4. brazing, soldering or welding equipment; • Facility operates brazing and welding equipment

Minn. R. 7011.0710/0715

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. • Four - Horizontal vacuum pressure impregnation

(VPI) chambers • Silver Plating Booth • Electric Tinning Unit • Parts Washer • Internal Cleaning/Painting • Fiberglass Machining • Sandblasting • Emergency Generator

Minn. R. 7011.0110 Minn. R. 7011.0110 Minn. R. 7011.0110 Minn. R. 7011.0515 Minn. R. 7011.0715 Minn. R. 7011.0715 Minn. R. 7011.0715 Minn. R. 7011.2300

Appendix II: Maximum Materials Contents and Application Rates

Facility Name: Electric Machinery Company Inc. Permit Number: 05300028-003 The table below gives the maximum application rate and maximum materials contents (at the time of permit issuance) used in calculating potential to emit for units listed in GP 004. The values listed in the table are not limits; however, changing to a material that has a higher VOC or solids content, or increasing the application rate, is considered a change in method of operation that must be evaluated under Minn. R. 7007.1200, subp. 3 to determine if a permit amendment or notification is required under Minn R. 7007.1150.

Emission Unit(s) Max Application Rate

Max Solids Contents

Max VOC Contents

13 10.31 gal/hr/gun 5.20 lb/gal 7.43 lb/gal 14 10.31 gal/hr/gun 5.30 lb/gal 7.26 lb/gal 15 10.31 gal/hr/gun 8.63 lb/gal 7.26 lb/gal 25 7.92 gal/hr/gun 5.00 lb/gal 5.48 lb/gal

Technical Support Document, Permit Action Number: 05300028-003 Page 1 of 5 Date: 11/19/2009

TECHNICAL SUPPORT DOCUMENT For

AIR EMISSION PERMIT NO. 05300028-003 This technical support document (TSD) is intended for all parties interested in the permit and to meet the requirements that have been set forth by the federal and state regulations (40 CFR § 70.7(a)(5) and Minn. R. 7007.0850, subp. 1). The purpose of this document is to provide the legal and factual justification for each applicable requirement or policy decision considered in the determination to issue the permit.

1. General Information 1.1 Applicant and Stationary Source Location:

Table 1. Applicant and Source Address

Applicant/Address Stationary Source/Address (SIC Code: 3621)

Converteam Inc 610 Epsilon Drive Pittsburgh, PA 15238

Electric Machinery Company Inc. 800 Northeast Central Avenue Minneapolis Hennepin County

Contact: Eric Severson Phone: 612-378-8919

1.2 Facility Description

Electric Machinery Company Inc (formerly Dresser-Rand Electric Machinery) manufactures customized electric motors and generators for domestic and foreign markets, which are used in all types of industries, including electric utilities, petrochemicals, and mining. Motors and generators are made for the 500 to 50,000 horsepower service range and weigh 2,000 to 200,000 pounds. Plant activities include welding, machining, epoxy impregnating and curing, painting, assembly and testing. 1.3 Description of the Activities Allowed by this Permit Action

This major amendment is for the construction of a new paint booth at the facility. The paint booth was added under the existing emissions limit; therefore, there may be a lb/hr increase in emissions but there will be no increase in tons per year of emissions. Precap language was also added to allow the replacement and addition of paint booths to GP 001 without automatically requiring a major amendment. EU’s 016, 017, 021, 023, and 024 were moved to the insignificant activities list. The new owner of the facility is Converteam Inc.

Several units were reorganized into groups and several requirements and citations were also updated according to current MPCA policy. The PTE of the facility was also recalculated.

1.4. Facility Emissions:


Table 2. Total Facility Potential to Emit Summary (tpy)

PM PM1

0 PM2.5 SO2 NOx CO VOC Single

HAP All

HAPsTotal Facility Limited Potential Emissions

8.58 8.58 8.58 1.39 17.33 13.30 37.81 9.0 22.0

Total Facility Actual 2007 Emissions

0.17 0.17 0.17 0.01 3.10 1.94 24.77 HAPs not reported in emission inventory

Table 3. Facility Classification

Classification Major/Affected Source Synthetic Minor Minor PSD VOC PM, PM10, PM2.5

Part 70 Permit Program VOC, PM, PM10, PM2.5 SOX, NOX, CO

Part 63 NESHAP X

2. Regulatory and/or Statutory Basis

New Source Review

The facility has taken limits to be a non-major source under New Source Review regulations. No changes are authorized by this permit.

Part 70 Permit Program

The facility is a non-major source under the Part 70 permit program.

New Source Performance Standards (NSPS)

There are no New Source Performance Standards applicable to the operations at this facility.

National Emission Standards for Hazardous Air Pollutants (NESHAP)

The facility has accepted limits on HAP emissions such that it is an area source under 40 CFR pt. 63. Thus, no major source NESHAPs apply. In addition, the Permittee has stated that no area source NESHAPs apply to the facility.

Compliance Assurance Monitoring (CAM)

CAM does not apply to the this permit, since no emission units qualify as large or other pollutant specific emission units (PSEU).

Environmental Review & AERA

The facility has accepted limits on production such that it is not subject to environmental review, i.e. an Environmental Assessment Worksheet (EAW,) and is not required to perform an Air Emissions Risk Analysis (AERA).

Minnesota State Rules

Portions of the facility are subject to the following Minnesota Standards of Performance:


• Minn. R. 7011.0510 Standards of Performance for Existing Indirect Heating Equipment • Minn. R. 7011.0610 Standards of Performance for Fossil-Fuel-Burning Direct Heating

Equipment • Minn. R. 7011.0715 Standards of Performance for Post-1969 Industrial Process Equipment • Minn. R. 7011.2300 Standards of Performance for Stationary Internal Combustion Engines

Table 4. Regulatory Overview of Units Affected by the Modification/Permit Amendment

Level* Applicable Regulations Comments: GP 001 Title I Condition “PreCap” language allows the facility to make changes

to units contained in GP 001 without automatically requiring a major amendment. The panel filters are not subject to Title I Conditions because PM emissions will not exceed thresholds due to the VOC limit.

GP 002 Minn. R. 7011.0510 Indirect Heating Equipment Rule: Several boilers were moved to GP 002 because they were all subject to identical limits under this rule.

GP 003 Minn. R. 7011.0610 Direct Heating Equipment Rule: Several ovens were moved to GP 003 because they were all subject to identical limits under this rule.

EU 026 Minn. R. 7007.0800 subp. 2 Several space heaters are being tracked as an emission unit.

*Where the requirement appears in the permit (e.g., EU, SV, GP, etc.).

3. Technical Information

3.1 Calculations of Potential to Emit Attachment 1 to this TSD contains detailed spreadsheets and supporting information prepared by the MPCA and the Permittee.


3.2 Periodic Monitoring

In accordance with the Clean Air Act, it is the responsibility of the owner or operator of a facility to have sufficient knowledge of the facility to certify that the facility is in compliance with all applicable requirements.

In evaluating the monitoring included in the permit, the MPCA considers the following:

• The likelihood of violating the applicable requirements; • Whether add-on controls are necessary to meet the emission limits; • The variability of emissions over time; • The type of monitoring, process, maintenance, or control equipment data already

available for the emission unit; • The technical and economic feasibility of possible periodic monitoring methods; and • The kind of monitoring found on similar units elsewhere.

The table below summarizes the periodic monitoring requirements for those emission units for which the monitoring required by the applicable requirement is nonexistent or inadequate.

Table 5. Periodic Monitoring

Level* Requirement (rule basis) Additional Monitoring Discussion GP 001 VOC Limit ≤ 35 TPY

Single HAP ≤ 9.0 TPY Total HAPs ≤ 22.0 TPY (Title I Condition)

12-month rolling sum, daily visual inspections, monthly recordkeeping, material content based on MSDS’s

Material content limits are in Appendix II. Usage logs are kept as paint is checked out for each individual job and monthly recordkeeping was deemed sufficient.

GP 002 PM Limit ≤ 0.40 lbs/MMBtu SO2 Limit ≤ 2.0 lbs/MMBtu Opacity Limit ≤ 20% (Minn. R. 70011.0510 subp. 1)

Fuel type limits Unlikely to exceed limits based on design and fuel types.

GP 003 PM Limit ≤ 0.30 lbs/MMBtu Opacity Limit ≤ 20% (Minn. R. 70011.0610 subp. 1)

None Unlikely to exceed limits based on design and fuel types.

*Where the requirement appears in the permit (e.g., EU, SV, GP, etc.).

3.3 Insignificant Activities

Electric Machinery Company Inc. has several operations which are classified as insignificant activities. These are listed in Appendix I to the permit. The space heaters listed in Appendix I are also tracked in the permit as EU 026 because when combined their emissions are significant. See Attachment 1 of this TSD for PTE information for the insignificant activities.

3.4 Permit Organization


In general, the permit meets the MPCA Delta Guidance for ordering and grouping of requirements.

3.5 Comments Received

EPA/Public Notice Period: 9/10/2009 – 10/9/2009

Comments were not received from the public during the public notice period.

4. Conclusion

Based on the information provided by Electric Machinery Company Inc, the MPCA has reasonable assurance that the proposed operation of the emission facility, as described in the Air Emission Permit No. 05300028-003, and this TSD, will not cause or contribute to a violation of applicable federal regulations and Minnesota Rules.

Staff Members on Permit Team: Chris Buntjer (permit writer/engineer) Brent Rohne (enforcement) Shanda Fisher (stack testing) Peggy Bartz (peer reviewer)

AQ File No. 348; DQ 2774 Attachments: 1. Calculation Spreadsheets

2. CD-01 Forms

Air Emission Permit No. 05300028-003 Is Issued to Electric ... · Electric Machinery Company Inc...

Documents

Transcript of Air Emission Permit No. 05300028-003 Is Issued to Electric ... · Electric Machinery Company Inc...