Permit Applications Table Permit Type Application Date · Permit Applications Table Permit Type Application Date Permit Action Total Facility Operating Permit June 26, 2007 (withdrawn)

Permit Applications Table

Permit Type Application Date Permit Action

Total Facility Operating Permit June 26, 2007 (withdrawn)

Revised February 15, 2008 (withdrawn) Resubmitted April 21, 2008

001

Minor Amendment December 28, 2007 & incorporated into April 21, 2008 resubmittal 001

Moderate Amendment February 14, 2008 & incorporated into April 21, 2008 resubmittal 001

TABLE OF CONTENTS

Notice to the Permittee Permit Shield Facility Description Table A: Limits and Other Requirements Table B: Submittals Table C: Not used in this permit Appendices Appendix I: Insignificant Activities and General Applicable Requirements Appendix II: Part 63 Subpart PPPP Compliance Equations Appendix III: Assumptions Used in Hourly PTE Calculations

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:

Suzlon Rotor Corporation (SRC) is a manufacturer of wind turbine rotor blades and nose cones. The Facility consists of blade mould preparation and repair; blade, structural web, and other components moulding; adhesive application of blade elements; blade tooling, sanding, and coating; and hot-wire foam cutting. The Facility also has an on-site diesel-fired emergency generator and has several activities that qualify as insignificant activities under Minn. R. 7007.1300, subp. 3 (see Appendix I to the permit). The main emissions are volatile organic compounds (VOC) and hazardous air pollutants (HAP).

SRC has conducted sandblasting in the past, which emitted significant amounts of particulate matter (PM), particulate matter smaller than 10 microns (PM10), and particulate matter smaller than 2.5 microns (PM2.5). Sandblasting is no longer conducted at the Facility.

This permit action is the issuance of a first time Part 70 Total Facility Permit. SRC is an existing facility with no prior air permit and was originally built with three blade production lines in 2006. Two of the blade production lines were used to produce “V2” blades and the third was used to produce slightly larger “V3” blades. This permit incorporates requests made in two amendment applications received since the first Total Facility Permit application was received on June 26, 2007. The minor amendment application, received December 28, 2007, sought to convert the two V2 lines to V3 lines and the moderate amendment application, received February 14, 2008, sought to add a fourth V3 blade production line.

This permit does not allow sandblasting and includes language directing the Permittee on how to proceed, should plans arise to conduct sandblasting in the future. In addition, this permit requires the Permittee to submit an Applicability Determination and receive a response from MPCA for any insignificant, minor, or moderate modification it wishes to make at the Pipestone Facility until June 24, 2012.

TABLE A: LIMITS AND OTHER REQUIREMENTSSuzlon Rotor Corp

11700025 - 001

Facility Name:

Permit Number:

09/21/11A-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

Maximum Contents of Materials: The Permittee assumed certain worst-casecontents of materials, method of materials application, and time required forapplication and curing of materials when determining the short term potential toemit of emission units EU 001, EU 002, EU 003, EU 004, EU 005, EU 006, EU 007,EU 008, and EU 009. These assumptions are listed in Appendix III of this permit.Changing any of these assumptions to increase short term potential to emit isconsidered a change in method of operation that must be evaluated under Minn. R.7007.1200, subp. 3 to determine if a permit amendment or notification is requiredunder Minn. R. 7007.1150.

Minn. R. 7005.0100, subp. 35a

Production: less than or equal to 4 process output blades per day. The Permitteeshall not operate the facility in any capacity other than for the purpose of producingor repairing up to four wind turbine blades per day. This includes but is not limitedto painting operations and use of the hot wire cutter.The Permittee shall keep a daily record of blades produced.

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

Sandblasting is not allowed under this permit. Prior to conducting any sandblastingactivities, the Permittee must submit a permit amendment application inaccordance with the requirements of Minn. R. 7007.1150 through Minn. R.7007.1500 and install a baghouse with a total enclosure around all sandblastingactivities.

Title I Condition: To avoid classification as a majorsource under 40 CFR Section 52.21 & Minn. R.7007.3000; Consent Decree para. 30 A

The Permittee shall submit a request for an applicability determination to the MPCAfor any insignificant, minor, or moderate modification it wishes to make for a periodof 24 months from June 24, 2010.

Title I Condition: To avoid classification as a majorsource under 40 CFR Section 52.21 & Minn. R.7007.3000; Consent Decree para. 30 B

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

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

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

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

Minn. R. 7011.0020

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

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

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

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

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

Minn. R. 7019.1000, subp. 4

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

Minn. R. 7011.0150


11700025 - 001

Facility Name:

Permit Number:

09/21/11A-2

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, B, and/or C.

Minn. R. ch. 7017

Performance Test Notifications and Submittals:

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

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

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

Minn. Rs. 7017.2030, subp. 1-4, 7017.2018 and Minn.R. 7017.2035, subp. 1-2

Limits set as a result of a performance test (conducted before or after permitissuance) apply until superseded as 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: Annually calibrate all required monitoringequipment (any requirements applying to continuous emission monitors are listedseparately in this permit).

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

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

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

RECORDKEEPING hdr

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

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

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

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

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

Minn. R. 7007.1200, subp. 4

REPORTING/SUBMITTALS hdr


11700025 - 001

Facility Name:

Permit Number:

09/21/11A-3

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, B,and C of Minn. R. 7019.1000, subp. 3.

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

Minn. R. 7019.1000, subp. 3

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

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

Minn. R. 7019.1000, subp. 2

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

Minn. R. 7019.1000, subp. 1

Notification of Deviations Endangering Human Health or the Environment Report:Within 2 working days of discovery, notify the Commissioner in writing of anydeviation from permit conditions which could endanger human health or theenvironment. Include the following information in this written description:1. the cause of the deviation;2. the exact dates of the period of the deviation, if the deviation has been corrected;3. whether or not the deviation has been corrected;4. the anticipated time by which the deviation is expected to be corrected, if not yet corrected; and5. steps taken or planned to reduce, eliminate, and prevent reoccurrence of the deviation.

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 through Minn. R. 7007.1500

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

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

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

Minn. R. 7019.3000 through Minn. R. 7019.3100

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

The Permittee must submit a Risk Management Plan (RMP) under 40 CFR pt. 68.Each owner or operator of a stationary source, at which a regulated substance ispresent above a threshold quantity in a process, shall design and implement anaccidental release prevention program. An initial RMP must be submitted no laterthan the latest of the following dates: 1) June 21, 1999; 2) Three years after thedate on which a regulated substance is first listed under 40 CFR Section 68.130; or3) The date on which a regulated substance is first present above a thresholdquantity in a process. A full update and resubmission of the RMP is required atleast once every five years. The five-year anniversary date is reset whenever yourfacility fully updates and resubmits their RMP. Submit RMPs to the RiskManagement Plan Reporting Center, P.O. Box 1515, Lanham-Seabrook, Maryland20703-1515. RMP information may be obtained at http://www.epa.gov/swercepp orby calling 1-800-424-9346.

40 CFR pt. 68


11700025 - 001

Facility Name:

Permit Number:

09/21/11A-4

Subject Item: GP 001 Coating Operations Subject to NESHAP Subp. PPPP

Associated Items: EU 003 Mold Repair & Release

EU 004 Adhesive Application (Production and Repair)

EU 005 Roller Coating

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

40 CFR Section 63.4491; Minn. R. 7011.8130

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

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

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


Unless otherwise noted, all equations for 40 CFR pt 63, subp. PPPP referenced inthe requirements of GP 001 can be found in Appendix II of this permit.

Minn. R. 7007.0800, subp. 4 and 5

EMISSION LIMIT hdr

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

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

COMPLIANCE REQUIREMENTS hdr

The Permittee must include all coatings (as defined in 40 CFR Section 63.4581),thinners and/or other additives, and cleaning materials used in the affected sourcewhen determining whether the HAP emission rate is equal to or less than the HAPemission limit. To make this determination, the Permittee must use at least one ofthe three compliance options listed in paragraphs (a) through (c) of 40 CFR Section63.4491.As stated earlier, this permit only includes the requirements associated with thecompliant material and the emission rate without add-on controls options specifiedin 40 CFR Section 63.4491(a) and (b).


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

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

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

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


11700025 - 001

Facility Name:

Permit Number:

09/21/11A-5

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

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

Continued:2) Method 24 (appendix A to 40 CFR pt. 60). For coatings, the Permittee may useMethod 24 to determine the mass fraction of nonaqueous volatile matter and usethat value as a substitute for mass fraction of organic HAP. For reactive adhesivesin which some of the HAP react to form solids and are not emitted to theatmosphere, the Permittee may use the alternative method described in appendix Ato 40 CFR pt. 63, subp. PPPP, rather than Method 24. The Permittee may use thevolatile fraction that is emitted, as measured by the alternative method in appendixA to 40 CFR pt. 63, subp. PPPP, as a substitute for the mass fraction of organicHAP;3) Alternative Method. The Permittee may use an alternative test method fordetermining the mass fraction of organic HAP once the Administrator has approvedit. The Permittee must follow the procedure in 40 CFR Section 63.7(f) to submit analternative test method for approval;

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

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


Continued:5) Solvent blends. Solvent blends may be listed as single components for somematerials in data provided by manufacturers or suppliers. Solvent blends maycontain organic HAP which must be counted toward the total organic HAP massfraction of the materials. When test data and manufacturer's data for solvent blendsare not available, the Permittee may use the default values for the mass fraction oforganic HAP in these solvent blends listed in Table 3 or 4 of 40 CFR pt. 63, subp.PPPP.


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


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

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


11700025 - 001

Facility Name:

Permit Number:

09/21/11A-6

Continued:3) Information from the supplier or manufacturer of the material. The mass fractionof coating solids for each coating may be obtained from the supplier ormanufacturer. If there is a disagreement between such information and the testmethod results, then the test method results will take precedence unless, afterconsultation it is demonstrated to the satisfaction of the MPCA that the formulationdata are correct.

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

Compliant Material Requirements hdr

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

40 CFR Section 63.4491(a), Minn. R. 7011.8130

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


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


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


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

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

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

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

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

40 CFR Section 63.4542(a); Minn. R. 7011.8130

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


Emission Rate Without Add-On Controls Requirements hdr


11700025 - 001

Facility Name:

Permit Number:

09/21/11A-7

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


The Permittee must complete the initial compliance demonstration for the initialcompliance period according to the requirements of 40 CFR Section 63.4551. Theinitial compliance period begins on April 19, 2007 and ends on April 30, 2008.The Permittee must determine the mass of organic HAP emissions and mass ofcoating solids used each month and then calculate an organic HAP emission rateat the end of the initial compliance period. The initial compliance demonstrationincludes the calculations according to 40 CFR Section 63.4551 and supportingdocumentation showing that during the initial compliance period the organic HAPemission rate was equal to or less than the HAP emission limit.


The Permittee may use the emission rate without add-on controls option for anyindividual coating operation, for any group of coating operations in the affectedsource, or for all the coating operations in the affected source. The Permittee mustuse either the compliant material option or the emission rate with add-on controlsoption for any coating operation in the affected source for which the Permittee doesnot use this option. To demonstrate initial compliance using the emission ratewithout add-on controls option, the coating operation or group of coating operationsmust meet the applicable HAP emission limit.The Permittee must conduct a separate initial compliance demonstration for eachgeneral use coating operation. The Permittee must meet all the requirements of 40CFR Section 63.4551.


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


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


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

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

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

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

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

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


11700025 - 001

Facility Name:

Permit Number:

09/21/11A-8

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

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

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

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

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

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

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

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

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

40 CFR Section 63.4552(a); Minn. R. 7011.8130

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


RECORDKEEPING hdr

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

40 CFR Sections 63.4530, 63.4542(d), and63.4552(d); Minn. R. 7011.8130

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



11700025 - 001

Facility Name:

Permit Number:

09/21/11A-9

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


Continued:9) If the Permittee uses an allowance in Equation 2 for organic HAP contained inwaste materials sent to or designated for shipment to a treatment, storage, anddisposal facility (TSDF) according to 40 CFR Section 63.4551(e)(4), the Permitteemust keep records of the information specified in paragraphs 40 CFR Section63.4530(g)(1) through (3); and10) Records of the date, time and duration of each deviation.


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


SUBMITTALS hdr

Notification 40 CFR Section 63.4510(c); Minn. R. 7011.8130

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

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

Content of Notification of Compliance Status, continued:6) If the Permittee had a deviation, include the following information:- A description and statement of the cause of the deviation.- If the Permittee failed to meet the HAP emission limit, include all the calculationsused to determine the kg (lb) of organic HAP emitted per kg (lb) coating solidsused. The Permittee does not need to submit information provided by the materials'suppliers or manufacturers, or test reports;7) For each of the data items listed below, include an example of how the Permitteedetermined the value, including calculations and supporting data. Supporting datamay include a copy of the information provided by the supplier or manufacturer ofthe example coating or material. The Permittee does not need to submit copies ofany test reports

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

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



11700025 - 001

Facility Name:

Permit Number:

09/21/11A-10

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


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

40 CFR Section 63.4540(a)(3); Minn. R. 7011.8130

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


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


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


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



11700025 - 001

Facility Name:

Permit Number:

09/21/11A-11

Subject Item: EU 007 Hot Wire Cutter

Associated Items: SV 010 Hot Wire Cutter, Bldg B

What to do Why to do itEMISSION LIMIT hdr

Total Particulate Matter: less than or equal to 0.30 grains/dry standard cubic foot ofexhaust gas unless required to further reduce emissions to comply with the lessstringent limit of either Minn. R. 7011.0730 or Minn. R. 7011.0735.

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

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


11700025 - 001

Facility Name:

Permit Number:

09/21/11A-12

Subject Item: EU 008 Emergency Generator

Associated Items: SV 012 Emergency Generator

What to do Why to do itEMISSION LIMITS hdr

Opacity: less than or equal to 20 percent opacity once operating temperatures havebeen attained.

Minn. R. 7011.2300, subp. 1

Sulfur Dioxide: less than or equal to 0.50 lbs/million Btu heat input . The potential toemit from the unit is 0.49 lb/MMBtu due to equipment design, allowable fuel, andlimited sulfur content of fuel.

Minn. R. 7011.2300, subp. 2

Sulfur Content of Fuel: less than or equal to 0.49 percent by weight Minn. R. 7007.0800, subps. 4 & 5

OPERATING CONDITIONS hdr

Fuel type: No. 2 fuel oil only by design. Minn. R. 7005.0100, subp. 35a

Operating Hours: less than or equal to 500 hours/year using 12-month Rolling Sumto be calculated by the 15th day of each month.

Minn. R. 7007.0800, subp. 4 & 5

RECORDKEEPING REQUIREMENTS hdr

Hours of Operation: The Permittee shall maintain documentation on site that theunit is an emergency generator by design that qualifies under the U.S. EPAmemorandum entitled "Calculating Potential to Emit (PTE) for EmergencyGenerators" dated September 6, 1995, limiting operation to 500 hours per year.

Minn. R. 7007.0800, subp. 4 & 5

Fuel Supplier Certification: The Permittee shall obtain and maintain a fuel suppliercertification for each shipment of No. 2 fuel oil, certifying that the sulfur contentdoes not exceed 0.49% by weight. The certification must include the name of thefuel oil supplier and the maximum sulfur content of the fuel.

Minn. R. 7007.0800, subps. 4 & 5

The Permittee shall keep records of fuel type and usage on a monthly basis. Minn. R. 7007.0800, subp. 5

TABLE B: SUBMITTALSFacility Name: Suzlon Rotor Corp

Permit Number: 11700025 - 001

09/21/11B-1

Also, where required by an applicable rule or permit condition, send to the Permit Document Coordinator notices of:- accumulated insignificant activities,- installation of control equipment,- replacement of an emissions unit, and- changes that contravene a permit term.

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

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

Send any application for a permit or permit amendment to:

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

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

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

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

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

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

TABLE B: ONE TIME SUBMITTALS OR NOTIFICATIONSFacility Name: Suzlon Rotor Corp


09/21/11B-2

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

Permit.Total Facility

TABLE B: RECURRENT SUBMITTALSFacility Name: Suzlon Rotor Corp


09/21/11B-3

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

half-year following Permit IssuanceGP001

Semiannual Deviations Report due 30 days after end of each calendarhalf-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

Compliance Certification due 30 days after end of each calendar yearfollowing Permit Issuance (for the previouscalendar year). The Permittee shall submitthis on a form approved by the Commissioner,both to the Commissioner and to the US EPAregional office in Chicago. This report coversall deviations experienced during the calendaryear.

Total Facility

APPENDIX MATERIAL Facility Name: Suzlon Rotor Corp Permit Number: 11700025-001

Appendix I: Insignificant Activities and General Applicable Requirements

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

Minn. R.

Rule Description of the Activity General Applicable Requirement

7007.1300, subp.

3(E)(2)

Storage Tanks: Nonhazardous air pollutant VOC storage tankage capacity of not more than 10,000 gallons of nonhazardous air pollutant VOCs and with a vapor pressure of not more than 1.0 psia at 60 degrees Fahrenheit. Suzlon listed a diesel storage tank with a capacity of 1250 gallons.

Minn. R. 7011.1505 (permanent submerged fill pipe) No requirements for 2,000 gal tank or less

7007.1300, subp. 3(I)

Individual emissions units at a stationary source, each of which have a potential to emit the following pollutants in amounts less than: 1. 4,000 lbs/year of carbon monoxide; and 2. 2,000 lbs/year each of nitrogen oxide, sulfur dioxide, particulate matter, particulate matter less than ten microns, volatile organic compounds (including hazardous air pollutant-containing VOC), and ozone. 3. 1,000 tons/year of CO2e. Suzlon listed several natural gas combustion units with individual capacities of less than 2 MMBtu/hr and a total capacity of 7.96936 MMBtu/hr and stenciling spray can usage under this subpart.

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

7007.1300, subp. 3(J)

Fugitive dust emissions from unpaved entrance roads and parking lots. Suzlon listed an unpaved blade storage area, to which blades are transported by fork lift.

Minn. R. 7011.0150 (PM)

7008.4110 Equipment venting PM/PM10 inside a building, provided that emissions from the equipment are:

a) filtered through an air cleaning system; and b) vented inside of the building 100% of the time

(Conditionally Insignificant Activities) Suzlon listed several hand sanding vacuum carts with filters, a band saw with a cyclone, two CNC units with cyclones, and a central vacuum system.

Minn. R. 7011.0715 (PM and opacity)

Appendix II: Part 60 Subpart PPPP Compliance Equations

EQUATION 1

c

cc S

WH =

Where:

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

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

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

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

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

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

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

EQUATION 2A

( )( )( )icic

m

iic WDVolA ,,

1,∑

=

=

Where:

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

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

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

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

m = Number of different coatings used during the month.

EQUATION 2B

( )( )( )jtjt

n

jjt WDVolB ,,

1,∑

=

=

Where:

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

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

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

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

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

EQUATION 2C

( )( )( )ksks

p

kks WDVolC ,,

1

,∑=

=

Where:

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

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

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

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

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

EQUATION 3

( )( )( )isic

m

iicst MDVolM ,,

1,∑

=

=

Where:

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

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

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

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

m = Number of coatings used during the month.

EQUATION 4

∑

∑

=

== n

yst

n

ye

yr

M

HH

1

1

Where:

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

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

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

y = Identifier for months.

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

Appendix III: Assumptions used in hourly PTE Calculations

Air Quality Board Modified Permit Application Form520 Lafayette Road General Emissions Calculations FormSt. Paul, MN 55155-4194

3/25/2003

1) AQ Facility ID Number: Not Assigned2) Facility Name Suzlon Rotor Corporation3) Emission Unit Identification Number(s): EU 001 Hand Layup4) Stack/Vent Designation Number(s): SV 001(M), 002, 003, 004, 005, 006, 007, 008, 011(P)5) Control Equipment ID Number(s): N/A

6) Calculations Summary using Material Content:

Discussion:1. VOC content (% by wt.) from the 9/26/07 VOC Weight Determination report for "Hand-Lay": 1.70%2. VOC concentrations assumed equal for all materials.

10.255. There are no HAPs present in the Hand Layup materials. Therefore assume no HAPs emitted for purposes of determining PTE.6. Resin Usage per V3 blade: 153.4 lb/blade 1460.0 blades 223903.7 lb/yr7. Hardener Usage per V3 blade 41.8 lb/blade 1460.0 blades 61034.5 lb/yr8. MSDS Nos: 103, 101, 102

Potential to Emit Calculation

MaterialFuture Potential

Usagea

(lbs/yr)

Potential Emissions(tons/yr)

Potential VOC Emissions

(lbs/yr)

Curing VOC Emissionsb

(lb/blade)

Potential No. Blades Produced

(blades/day)

VOC Emissions

(lbs/hr)Hand Layup Resins 223,903.7 1.90 3,806.36 2.61 1.02Hand Layup Hardeners 61,034.5 0.52 1,037.59 0.71 0.28Total --- 2.42 4,843.95 3.32 1.29a Projected to potential operation at 4 production lines and 486.67 blade sets per year.b Emissions, lbs/blade, calculated based on lbs/yr emissions and potential production of 1,460 blades/yr.

4

EC-01

3. Potential operation is 4 blades per day or 1.33 blade sets per day; potential annual production is 1,460 blades or 486.67 blade-sets. A worst-case blade set consists of three V3 blades.4. Cure time per blade, hours, assumed equal to resin cure time for EU002:

EU001 Hand Layup

Resin 2007 Usage 27000 kg59535 lb

297x+108y= 59535y=1.06(x)297x+114.5x = 59535411.5x=75763.8

x= 144.7 lb/V2 bladey= 153.4 lb/V3 blade

Hardener 2007 Usage 7360.0 kg16229 lb

297x+108y= 16229y=1.06(x)297x+114.5x = 16229411.5x=16229



3/25/2003

1) AQ Facility ID Number: Not Assigned2) Facility Name Suzlon Rotor Corporation3) Emission Unit Identification Number(s): EU 002 Infusion Molding, Blade & Structural Web4) Stack/Vent Designation Number(s): SV 001 (M), 002, 006, 008 (P)5) Control Equipment ID Number(s): N/A


Discussion:1. VOC (% by wt.) from the 9/26/07 VOC Weight Determination report for "Infusion": 1.18%2. VOC content is assumed equal for all materials.

4. Resin cure time, in hours per blade: 10.255. There are no HAPS in the resin materials. Therefore assume no HAPs emitted for purposes of determining PTE.6.) Resin as applied is 74.6% by wt resin and 25.4% by wt. hardener.7. Resin Usage per Blade: 5162 lb/blade 1460.0 blades 7536213.9 lb/yr8. Hardener Usage per Blade: 1757 lb/blade 1460.0 blades 2565949.5 lb/yr9. MSDS Nos. 19, 17, 78



Usagea

(lbs/yr)

Potential VOC Emissions(tons/yr)


(lbs)

Curing Emissionsb

(lb/blade)

Potential No. Blades Produced Simultaneously

Curing Emissions

(lbs/hr)Infusion Molding Resin 7,536,213.9 44.28 88,550.51 60.65 4 23.67Infusion Molding Hardeners 2,565,949.5 15.07 30,149.91 20.65 4 8.06Total --- 59.35 118,700.42 --- --- 31.73a Projected to potential operation at 4 production lines and 486.67 blade sets per year.b Emissions, lbs/blade, calculated based on lbs/yr emissions and potential production of 1,460 blades/yr.

EC-01

3. Potential operation is 4 blades per day or 1.33 blade sets per day; potential annual production is 1,460 blades or 486.67 blade-sets. A worst-case blade set consists of three V3 blades.

EU002 Infusion MoldingMax. Resin per blade was determined based on the maximum number of material used per day and calculating the number of blades produced for that day.

Max. Resin/blade3138 kg6919 lb total5162 lb resin1757 lb hardeners


3/25/2003

1) AQ Facility ID Number: Not Assigned2) Facility Name Suzlon Rotor Corporation3) Emission Unit Identification Number(s): EU 003 Mold Repair & Release4) Stack/Vent Designation Number(s): SV 001 (M), 008 (P)5) Control Equipment ID Number(s): N/A


Discussion1. VOC loss from Mold Repair and Mold Release product use (by weight): 100%2. VOC loss from Mold Sealer product use (by weight): 96.46%3. VOC content is assumed equal for all materials.

5. Process time per blade set from actual opreration at Suzlon.6. Mold Release Solvent 12.48 lb/ blade 1460 blades/yr 18227 lb/yr7. Mold Repair Solvent Usage 0.25 lb/ blade 1460 blades/yr 358 lb/yr8. Mold Sealer Usage 0.30 lb/ blade 1460 blades/yr 435 lb/yr9. MSDS Nos. 10,11,9

Potential to Emit Hourly calculation Annual Calculation

MaterialProcess Time per Blade Set

(hrs)

Potential VOC Emissionsa

(lbs/hr)

Potential HAP Emissionsa

(lbs/hr)

Potential Annual

Production(sets/yr)

Existing Potential Usageb

(lbs/yr)


Potential HAP Emissionsc

(tons/yr)

Mold Release Solvent 6.83 7.31 0.00 18,227 9.11 0.00Mold Repair Solvent 1.00 0.98 0.59 358 0.18 0.11Mold Sealer 1.00 1.15 0.00 435 0.21 0.00Total --- 9.44 0.59 --- 9.50 0.11a Emissions, lbs/hr, calculated assuming all 4 blades (1.33 blade sets) are produced at the same time, and the listed process time per blade.b Projected to potential operation at 4 production lines and 486.67 blade sets per year.c No HAPs identif ied in the MSDSs for the Mold Release Solvent or Mold Sealer; Toluene is the only HAP, at a maximum of 60%, in the Mold Repair Solvent.

EC-01

486.67


EU003 Mold Repair And Release

DensityRelease Solvent 2915 L 0.754 kg/L 2198 kg 4846 lb

Repair Solvent 60.6 L 0.712 kg/L 43.1 kg 95.1 lbSealent 68.1 L 0.77 kg/L 52.4 kg 115.6 lb

Release Solvent411.5x = 4846

x= 11.8 lb/V2bladey= 12.5 lb/V3blade

Repair Solvent411.5x=95.1


Sealent411.5x=115.6



3/25/2003

1) AQ Facility ID Number: Not Assigned2) Facility Name Suzlon Rotor Corporation3) Emission Unit Identification Number(s): EU 004 Adhesive Application4) Stack/Vent Designation Number(s): SV 002 (M), 003, 004, 006, 007, 0085) Control Equipment ID Number(s): N/A


Discussion:

2. Conservatively, adhesives HAPs and Solids percentages are estimated at 1% and 99%, respectively.

4. Adhesive Resin Components 1339.8 lb/ blade 1460 blades/yr 1956164 lb/yr5. Application and cure time per blade (hrs) 7.336. MSDS Nos. 25, 24

Potential to Emit


Usagea

(lbs/yr)

Potential HAPb

Emissions(tons/yr)

Potential HAPb,c

Emissions(lbs/hr)

Adhesive resin Components 1,956,164 9.78 7.31a Usage is projected to potential operation of 486.67 rotor sets per year w ith 4 production lines.b Assuming Total HAPs from all adhesive application use is 1% by w eight.c Emissions, lbs/hr, calculated assuming all 4 blades (1.33 blade sets) are produced at the same time, and the listed process time per blade.

EC-01

1. There are no VOCs emitted during curing of adhesive materials, as reported in the 9/26/07 VOC Weight Determination report for Adhesive.

3. Potential production is 4 blades per day or 1.33 blade sets per day; potential annual production is 1,460 blades or 486.67 blade-sets. A worst-case blade set consists of three V3 blades.

EU004 Adhesive Application

2007 Usage 235889.0 kg520135 lb

297x+108y= 520135y=1.06(x)297x+114.5x = 520135411.5x=520135


Air Quality Board Modified Permit Application Form520 Lafayette RoadSt. Paul, MN 55155-4194

3/25/2003

1) AQ Facility ID Number: Not Assigned2) Facility Name Suzlon Rotor Corporation3) Emission Unit Identification Number(s): EU 005 Roller Coating4) Stack/Vent Designation Number(s): SV 003, SV 007 (P), SV 011 (P)5) Control Equipment ID Number(s): N/A6) Application Method: Rollers7) Number of Spray Ports in the Booth: N/A8) Oven Curing, if applicable N/A

Discussion:

1. Transfer efficiency is assumed equal to 100%. Paint is applied using rollers, not spray guns. Therefore, no PM/PM10 emissions will occur.2. No pollution control is used.3. Paint Usage per Blade: 22.2 gal/blade 1460.0 blades 32401.6 gal/yr4. Hardener Usage per Blade: 5.28 gal/blade 1460.0 blades 7714.7 gal/yr

7. MSDS No. 33, 29

Material Properties: Current Material Used

MaterialVOC Content(% by weight)

Density(lbs/gal) VOC (lb/gal)

V3 Blade Use(gal/blade)

Paint 42.0% 11.68 4.38 22.19Hardener 61.0% 8.34 4.59 5.28As Applied --- 11.01 4.42 27.48

Current Material Used

MaterialTotal HAP Contenta

(% by weight)

Xylene Content (% by

weight)

Ethyl benzene (% by weight)

Cumene (% by weight)

Glycol Ethers (% by weight)

Paint 16.20% 12.6% 3.00% 0.60% ---Hardener 10.04% 0.02% --- 0.02% 10.0%

CURRENT COATIINGPotential to Emit Hourly Calculation Annual calculation

MaterialV3 Blades Produced

(blades/day)

VOC Emissions(lbs/day)

VOC Emissions

(lbs/hr)


Coating - As Applied 4 486.01 64.80 88.70

HAPs Hourly Calculation Annual calculation

xylene lbs/hr cumenelbs/hr

ethyl-benzenelbs/hr

glycol etherslbs/hr

HAPs Emissions(lbs/day)

HAP Emissions

(lbs/hr)

xylenetpy

cumenetpy

ethyl-benzenetpy

glycol etherstpy

Potential HAP Emissions(tons/yr)

17.42 0.83 4.15 0.00 167.97 22.40 23.84 1.14 5.68 0.00 30.650.005 0.005 0.000 2.35 17.70 2.36 0.01 0.01 0.00 3.22 3.2317.42 0.83 4.15 2.35 185.67 24.76 23.85 1.14 5.68 3.22 33.88

EC-07PAINTING/COATING OPERATIONS CALCULATION

Calculated based on Current Coating

a Coating HAPs are 12.5% xylene, 3% ethylbenzene, and 0.5% cumene; solvent naptha contributes an additional 0.1% of cumene and 0.1% xylene. Hardener HAPs are 10% glycol ethers; solvent naphtha contributes an additional 0.02% cumene and 0.02% xylene.

5. Each blade or nosecone requires approximately 7.5 hours of process time.

6. Potential annual production is 1,460 blades or 486.67 blade-sets. Potential usage accounts for nose cones.

a Coating HAPs are 12.5% xylene, 3% ethylbenzene, and 0.5% cumene; solvent naptha contributes an additional 0.1% of cumene and 0.1% xylene. Hardener HAPs are 10% glycol ethers; solvent naphtha contributes an additional 0.02% cumene and 0.02% xylene.

Time to CompleteOne Blade or Cone

7.5

EU005 Roller CoatingCoating

Based on the Amount of Coating Dispensed per Blade - In actuality the total amount dispensed is not used.

Usage Per Blade84.00 l3.79 l/gal

22.19 gal/blade

Hardener

Based on the Amount of Hardener Dispensed per Blade - In actuality the total amount dispensed is not used.

Usage Per Blade20.00 l3.79 l/gal5.28 gal/blade

Suzlon Rotor Corporation

The MPCA has requested that Suzlon review alternative coatings to determine PTE. The Original PPG is a coating that Suzlon originally used when the plant was constructed. The current PPG Selemix is the coating Suzlon is currently using and the proposed coating is a coating that Suzlon is evaluating for use.

Coatings Comparison

Original PPG PropositionCurrent PPG Selemix

SystemProposed Low VOC Selemix

SystemTopcoat Color Code AUE-100 N220 (7-533) 7-543Topcoat VOC (lb/gal) 4.66 4.38 3.76Topcoat Parts (vol) in Mix 7 4 6Curing Agent Code AUE-101 N270 9-070 HS 9-075 HSCuring Agent VOC(lb/gal) 2.21 4.59 2.39Parts Vol. in Mix 1 1 1RFU VOC (lb/gal) 4.36 4.42 3.56RTU Density (lb/gal) 9.83 11.06 11.41RTU Volume Solids (%) 41.5 48 53.8RTU Solids (lb/gal) 5.47 6.64 7.85Current Coating Rqd (gal/blade) *** 27.5 ***Solids Vol (gal/blade) 13 13 13Vol. Rqd per Blade (gal) 31.8 27.5 24.5VOC (lb/blade) 138.6 121.4 87.3PTE. Blades (4/day) (tpy) 101.2 88.7 63.7PTE Blades (3/day) (tpy) 75.9 66.5 47.8

Air Quality Board Modified Permit Application Form520 Lafayette Road General Emissions Calculations Form

St. Paul, MN 55155-41943/25/2003

1) AQ Facility ID Number: Not Assigned2) Facility Name Suzlon Rotor Corporation3) Emission Unit Identification Number(s): EU 006 Resin Tool Cleaner4) Stack/Vent Designation Number(s): SV 0095) Control Equipment ID Number(s): N/A


Discussion

4. MSDS No. 117

Future Potential to Emit

MaterialPotential Usagea

(lbs/yr)

Potential VOCsb

(lbs/yr)Potential VOCsc

(lbs/hr)Potential VOCsb

(tons/yr)

Resin Tool Cleanup Product 11,208.5 7,061.3 0.81 3.53a Projected to potential operation of 486.67 rotor sets per year.b MSDS for product identif ies product as 63% volatile by w eight; therefore, assumed VOC emissions equal to 63% of potential usage.c Emissions, lbs/hr, back-calculated from tons/yr values, based on 8,760 hours/yr. (assumes continuous operation.)

EC-01

1. Potential operation is 4 blades per day or 1.33 blade sets per day; potential annual production is 1,460 blades or 486.67 blade-sets. A worst-case blade set consists of three V3 blades.3. The MSDS for the resin tool cleaner product identifies product as 63% volatile by weight; therefore, assumed VOC emissions equal to 63% of potential usage. The MSDS indicates no HAPs.

EU006 Resin Tool Cleaner

2007 Usage 2180.0 L1351.6 kg

2980 lb297x+108y=2980y=1.06(x)297x+114.5x = 2980411.5x=2980

x= 7.2 lb/V2 bladey= 7.7 lb/V3 bladey= 0.92 gal/V3 blade


3/25/2003

1) AQ Facility ID Number: Not Assigned2) Facility Name Suzlon Rotor Corporation3) Emission Unit Identification Number(s): EU 007 Hot Wire Cutter4) Stack/Vent Designation Number(s): SV 0105) Control Equipment ID Number(s): N/A


Discussion1. Suzlon can potentially produce up to a total of 4 blades per day, independent of type.2. Each V2 blade cuts 22,530,676 mm3 of foam (approx. 0.0225 m3).3. Each V3 blade cuts 24,755,026 mm3 of foam (approx. 0.0248 m3); therefore, V3 blade production is worst-case.4. The foam density is 70 kg/m3 (approx. 154.3 lbs/m3)5. All foam cut is assumed to be emitted.6. Foam MSDS No. 87.) 20% Safety factor included to account for inefficiencies.


MaterialFoam Cut per

Blade(lbs)

No. Produced per Daya

Potential PM/PM10

Emissions(lbs/hr)

No. Produced per Yeara

Potential PM/PM10

Emissionsa

(tons/yr)V3 Blade 4.59 4 0.77 1,460 3.35a Potential operation is 486.67 rotor sets per year (1,460 blades). (Assumes continuous operation.)

EC-01


3/25/2003

1) AQ Facility ID Number: Not Assigned2) Facility Name Suzlon Rotor Corporation3) Emission Unit Identification Number(s): EU 009 Putty Use4) Stack/Vent Designation Number(s): SV 001(M), 002, 003, 004, 005, 006, 007, 008, 011(P)5) Control Equipment ID Number(s): N/A


Discussion1. MSDS Nos. 69, 104, 111,115,113,116

2. For MSDS 69, 111,115,113 and 116 VOC Emission Factor 2% HAP Emission Factor 0.00%Note These putties involve a chemical reaction. The VOC emission factor is thought to be a connservative factor.There are no HAPs contained in these materials. Therefore HAP emissions are assumed to be 03. For MSDS 104 VOC/HAP Emission Factor 18%Note: This is conservatively based on the fact that this resin contains a max. of 18% styrene (VOC) a strict mass balance was applied.4. Process time per blade set from actual opreration at Suzlon. 2.00 hrs per blade5. Calculations assume that 4 blades are produced at once.6. Putty Use 104 7.75 lb/ blade 1460 blades/yr 11315 lb/yr

111 47.37 lb/ blade 1460 blades/yr 69155 lb/yr113 1.97 lb/blade 1460 blades/yr 2877 lb/yr

Hardener Use 69 0.14 lb/blade 1460 blades/yr 212 lb/yr115 8.92 lb/blade 1460 blades/yr 13024 lb/yr116 0.88 lb/blade 1460 blades/yr 1288 lb/yr


Material

Process Time per

Blade(hrs)

Potential VOC

Emissions(lbs/hr)

Potential HAP

Emissions(lbs/hr)

Existing Potential Usage(lbs/yr)

Potential VOC

Emissions(tons/yr)

Potential HAP

Emissions(tons/yr)

Putty Use 104 2.00 2.79 2.79 11,315 1.02 1.02111 2.00 1.89 0.00 69,155 0.69 0.00113 2.00 0.08 0.00 2,877 0.03 0.00

Hardener Use 69 2.00 0.006 0.000 212 0.002 0.00115 2.00 0.36 0.00 13,024 0.13 0.00116 2.00 0.04 0.00 1,288 0.01 0.00

Total --- 5.16 2.79 -- 1.88 1.02

EC-01

EU009 PuttiesMaterialNameMSDS # 104 69 111 115 113 116Part # 1000024 10000023 MANK102 MANK103 MANK100 MANK101Density (kg/L) 1.8 1.15 N/A N/A N/A N/AHAPs (% by wt.) 18.00% 1.00% 1.00% 1.00% 1.00% 1.00%Solids (% by wt.) 82.00% 99.00% 99.00% 99.00% 99.00% 99.00%2007 Usage 95.7 L 2.8 L 8700 kg 1638.5 kg 362 kg 162 kgUsage (lb) 380 7.10 19184 3613 798 357Blades (#) 405 405 405 405 405 405lb/blade* 0.94 0.02 47.4 8.92 1.97 0.88lb/blade ** 7.75 0.14*Assumes no difference betw een V2 and V3 blades.** The usage of this putty is changing. The purpose of this change is to use the chemical up. After it is used up it w ill no longerbe used. Because of this it is probably not correct to base the usage rate based on historical data. Instead usage w as based on the useof 1.5 containers per nose cone. The hardener use w as calculated by multiplying the reation of projected putty use to 2007 use.

ThinPutty

Thin Hardener

Polyester Putty

Polyester Hardener Thick Putty

Thick Hardener

Insignificant Activities Emission CalculationsDecal Spray Can Use

Usage: 30 cansBlades Produced: 155 BladesCans per Blade: 0.19 cans per bladeSafety Factor: 2 (Used because w e did not have a full years w orth of data.)Cans per Blade: 0.39 cans per bladeWt per can: 340 grams

0.34 kg0.75 lbs

Wt. per blade: 0.29 lb/bladeMax Use (lb/hr) 1.16 (assumes production of 4 blades simultaneously.)Max. Use (lb/yr) 418 (assumes production of 1440 blades per year.)

Stencil Paint for Finished Blades

Material

VOC Content(% by

weight)

Solids Content

Density(lbs/gal)

VOC Emissions

(lb/hr)

PM/PM10 (lb/hr)

VOC Emission

s (tpy)

PM/PM10 (tpy)

Paint 61.8% 39.2% 6.29 0.72 0.46 0.13 0.08

Note: Particulate Matter calculation conservatively assumes 0% transfer efficiency.

Material

Total HAP Contenta

(% by weight)

Toluene Content (% by

weight)


Carbon Black (% by weight)

Paint 34.7% 22.0% 12.0% 0.70%PTE (lb/hr) 0.40 0.26 0.14 0.01PTE (tpy) 0.07 0.05 0.03 0.001Note: Carbon Black calculation conservatively assumes 0% transfer efficiency.

Technical Support Document, Permit Action Number: 11700025-001 Page 1 of 14 Date: 9/20/2011

TECHNICAL SUPPORT DOCUMENT For

AIR EMISSION PERMIT NO. 11700025-001 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: 3511)

Suzlon Rotor Corporation 1711 South Highway 75 Pipestone, MN 56164

Suzlon Rotor Corporation 1711 S Highway 75 Pipestone Pipestone County

Contact: Mark Cronin Engineering Manager Phone: 507-562-6706 Fax: 507-562-6800

1.2 Facility Description

Suzlon Rotor Corporation (SRC) is a manufacturer of wind turbine rotor blades and nose cones. The Facility consists of blade mould preparation and repair; blade, structural web, and other components moulding; adhesive application of blade elements; blade tooling, sanding, and coating; and hot-wire foam cutting. The Facility also has an on-site diesel-fired emergency generator and has several activities that qualify as insignificant activities under Minn. R. 7007.1300, subp. 3 (see Appendix I to the permit). The main emissions are volatile organic compounds (VOC) and hazardous air pollutants (HAP).

SRC has conducted sandblasting in the past, which emitted significant amounts of particulate matter (PM), particulate matter smaller than 10 microns (PM10), and particulate matter smaller than 2.5 microns (PM2.5). Sandblasting is no longer conducted at the Facility.

1.3 Description of any Changes Allowed with this Permit Issuance

This permit action is the issuance of a first time Part 70 Total Facility Permit. SRC is an existing facility with no prior air permit and was originally built with three blade production lines in 2006. Two of the blade production lines were used to produce “V2” blades and the third was used to produce slightly larger “V3” blades. This permit incorporates requests made in two


amendment applications received since the first Total Facility Permit application was received on June 26, 2007. The minor amendment application, received December 28, 2007, sought to convert the two V2 lines to V3 lines and the moderate amendment application, received February 14, 2008, sought to add a fourth V3 blade production line.

This permit does not allow sandblasting and includes language directing the Permittee on how to proceed, should plans arise to conduct sandblasting in the future. In addition, this permit requires the Permittee to submit an Applicability Determination and receive a response from the MPCA for any insignificant, minor, or moderate modification it wishes to make at the Pipestone Facility until June 24, 2012.

1.4 Facility Emissions:

Table 2. Total Facility Potential to Emit Summary

PM tpy

PM10 tpy

PM2.5tpy

SO2 tpy

NOx tpy

CO tpy

CO2etpy

VOC tpy

Single HAP tpy

All HAPs

tpy Total Facility Limited Potential Emissions

3.49 3.49 3.49 0.80 4.75 1.09 4,351 165.5 23.85 44.79

Total Facility Actual Emissions (2008)

1.21 1.21 1.21 .01 .09 .02 * 119.53 *

*Not reported in MN emission inventory in 2008.

Table 3. Facility Classification

Classification Major/Affected Source

Synthetic Minor/Area

Minor/Area

PSD VOC PM, PM10, SO2, NOx, CO, CO2e

Part 70 Permit Program VOC PM, PM10, SO2, NOx, CO, CO2e

Part 63 NESHAP Xylene & Total HAPs

2. Regulatory and/or Statutory Basis

New Source Review


The facility is non-major under New Source Review regulations. See “Technical Information” later in this TSD for discussion.

Part 70 Permit Program

The facility is a major source under the Part 70 permit program due to total HAP PTE at or above 25 tpy, xylene PTE at or above 10 tpy, and VOC PTE at or above 100 tpy.

New Source Performance Standards (NSPS)

There are no New Source Performance Standards applicable to the operations at this facility. The emergency generator was manufactured on August 4, 2005; therefore, NSPS subpart IIII does not apply. (See Attachment 3 of this TSD for EPA confirmation.)

National Emission Standards for Hazardous Air Pollutants (NESHAP)

The facility is major for HAPs under 40 CFR part 63. Two NESHAPs apply. National Emission Standards for Hazardous Air Pollutants for Surface Coating of Plastic Parts and Products, 40 CFR part 63, subpart PPPP, applies to a majority of the facility operations. National Emission Standards for Hazardous Air Pollutants for Reciprocating Internal Combustion Engines, 40 CFR part 63, subpart ZZZZ, applies to the emergency generator. (Note: 40 CFR part 63, subpart WWWW does not apply because the only material with styrene is a putty, which is excluded from the applicability.)

Compliance Assurance Monitoring (CAM)

This facility is not subject to CAM because there are no units at the facility that use a control device to meet an applicable emission limitation and have potential pre-control device emissions greater than 100 tpy of any criteria pollutant, 25 tpy of combined HAPs, and/or 10 tpy of any single HAP.

Environmental Review & AERA

The limited PTE of all criteria pollutants is below 250 tpy; therefore, this facility is not subject to Environmental Review and was not required to perform an Air Emissions Risk Analysis (AERA).

Minnesota State Rules

The hot wire cutter (EU007) is subject to the following Minnesota Standard of Performance:

• Minn. R. 7011.0715 Standards of Performance for Post-1969 Industrial Process Equipment

The emergency generator (EU 008) is subject to the following Minnesota Standard of Performance:

• Minn. R. 7011.2300 Standards of Performance for Stationary Internal Combustion Engines

Table 4. Regulatory Overview of Facility


EU, GP, or SV

Applicable Regulations Comments:

GP 001 40 CFR pt. 63, subp. PPPP

National Emission Standards for the Surface Coating of Plastic Parts and Products. This is a new source under this rule, (commenced construction after 12/04/02), and is subject to the “general use coating” limit. The source may use the compliant material option or the emission rate without add-on controls option to demonstrate compliance.

EU 007 Minn. R. 7011.0715

The emissions are minimal and will not violate performance standards.

EU 008 40 CFR pt. 63, subp. ZZZZ; Minn. R. 7011.2300

The facility must comply with this subpart by complying with NSPS Subpart IIII but there are no requirements for this engine other than the initial notification.

3. Technical Information

NSR/PSD

The facility constructed and operated without a permit; hence, there were no limits in place to ensure NSR/PSD thresholds were not crossed. Technically, the PTE for criteria pollutants would be unlimited but MPCA agreed to consider the buildings in which blades are produced, as well as the highest VOC content of materials that are technically feasible to use in blade production, to justify not seeking injunctive relief.

In addition, sandblasting of blades was conducted onsite, which produced a PTE of particulate matter over the NSR/PSD thresholds. The Permittee halted sandblasting operations and is not allowed to conduct those activities. Should the Permittee wish to resume sandblasting, it must apply for and receive a permit amendment and install a baghouse with total enclosure before doing so.

Additional information can be found in the Consent Decree between the State of MN and SRC in Court File No. CS-01-1653.

Emergency Generator

The Fuel Oil Certification is used as a monitoring requirement in permits to ensure that the sulfur content of distillate fuel oils is less than 0.49% by weight. Fuel oil with a sulfur content of less than 0.49% by weight will produce emissions of less than 0.50 lb SO2 per mmBTU heat input and will be in compliance with the limit set out in Minn. R. 7011.2300, subp. 2. The MPCA developed the Fuel Oil Certification permit requirement in order to monitor compliance with the sulfur dioxide emission limit. The requirement is modeled after 40 CFR 60 Subpart Dc - Standards of Performance for Small Industrial-Commercial-Institutional Steam Generating Units. Although Subpart Dc does not apply to this facility, the use of a similar, but abbreviated, version of the fuel oil certification meets the requirements of Minn. R. 7007.0800, subps. 4 and 5 to provide for periodic monitoring and recordkeeping for the sulfur emissions limit. The


certification with each shipment of distillate fuel oil must include the name of the supplier and the maximum sulfur content of the fuel oil. Greenhouse Gases

As of January 2, 2010, the United States Environmental Protection Agency (USEPA) began regulating Greenhouse Gases (GHGs) in terms of carbon dioxide equivalents, or CO2-e. A source’s emissions of GHGs are quantified in two steps: first, the potential emissions of each of the chemicals in 40 CFR pt. 98, Appendix A, Table 1 are multiplied by their respective global warming potential; second, the results of each calculation in step 1 are summed together to arrive at a single numeric value in the units of CO2-e. In order to be considered a major source of GHGs under the Title V operating permit program and New Source Review program, a source must have a potential to emit exceeding 100,000 tons per year of CO2-e. If a source’s emissions of GHG do not exceed this value, then, as of the date of this permit, there are no additional GHG-related permitting requirements beyond this calculation. This is the case for SRC, since the CO2-e PTE is 4351 tpy.

3.1 Calculations of Potential to Emit

The PTE was based on producing 4 blades/day simultaneously, which is a production limit under Total Facility requirements. The calculations assume all of the VOCs in each material are emitted. This is a conservative assumption considering that the facility has never been able to produce 4 blades per day. Also, the company is continually looking for lower VOC materials.

The hourly emissions are estimated by dividing the VOCs emitted by the number of hours it takes to cure the blades with each step in the process.

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.

Table 4 summarizes the periodic monitoring requirements for those emission units for which the monitoring required by the applicable requirement is nonexistent or inadequate.

Table 4. Periodic Monitoring


Emission Unit or Group

Requirement (basis)

Additional Monitoring

Discussion

Total Facility

Title I Condition: To avoid classification as a major source under 40 CFR Section 52.21 & MN. Rule 7007.3000

The Permittee shall keep a daily record of blades produced.

Blade production records and material usage records ensure minor source status under PSD.

GP 001 Plastic Coating

Total HAP < 0.16 kg/kg of coating solids used (12-month rolling limit) (40 CFR pt. 63, subp. PPPP)

None The NESHAP is considered to have adequate monitoring to assure compliance with applicable limit.

EU 008 Opacity ≤ 20% Sulfur Dioxide ≤ .5 lb/MMBtu (MN. Rule 7011.2300)

Fuel type & usage records, fuel supplier certifications

Ensures compliance with both limits.

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

3.3 Insignificant Activities

Suzlon Rotor Corp has several operations which are classified as insignificant activities. These are listed in Appendix I to the permit. The permit is required to include periodic monitoring for all emissions units, including insignificant activities, per EPA guidance. The insignificant activities at this Facility are only subject to general applicable requirements. Using the criteria outlined earlier in this TSD, the following table documents the justification why no additional periodic monitoring is necessary for the current insignificant activities. See Attachment 1 of this TSD for PTE information for the insignificant activities.

The following table discusses insignificant activities that may or may not occur at the facility and the applicable requirements, along with justification for no additional


monitoring. The insignificant activities currently conducted are listed in Appendix I to the permit.

Table 5. Insignificant Activities

Insignificant Activity

General Applicable Emission limit

Discussion

Fuel use: space heaters fueled by, kerosene, natural gas, or propane

PM < 0.6 or 0.4 lb/MMBtu, depending on year constructed Opacity < 20% with exceptions

(Minn. R. 7011.0510/515)

For this unit, based on the fuels used and EPA published emissions factors, it is highly unlikely that it could violate the applicable requirement. In addition, these types of units are typically operated and vented inside a building, so testing for PM or opacity is not feasible.

Fuel burning equipment with a capacity less than 500,000 Btu/hour, etc.

PM < 0.6 or 0.4, depending on year constructed Opacity < 20% with exceptions

(Minn. R. 7011.0510/515)

For these units, based on the fuels used and EPA published emissions factors, it is highly unlikely that they could violate the applicable requirements.

Gasoline storage tanks with a combined total tankage capacity of not more than 10,000 gallons and nonhazardous air pollutant VOC storage tanks with a combined total tankage of not more than 10,000 gallons and with a vapor pressure of not more than 1.0 psia at 60 degrees Fahrenheit.

Minn. R. 7011.0710/0715

The rule requires a permanent submerged fill pipe which can be demonstrated upon inspection.

Equipment used for hydraulic or hydrostatic testing

PM, variable depending on airflow Opacity < 20%

While no known emissions estimation method exists for these units, based on general knowledge of how they operate, it




Discussion

(Minn. R. 7011.0710/715)

is highly unlikely that they could generate particulate matter. In addition, these units would be operated and vented directly into a building, so testing is not feasible.

Brazing, soldering or welding equipment


(Minn. R. 7011.0710/715)

For these units, based on EPA published emissions factors, it is highly unlikely that they could violate the applicable requirement. In addition, these units are typically operated and vented inside a building, so testing for PM or opacity is not feasible.

Blueprint copiers and photographic processes

Opacity < 20%

(Minn. R. 7011.0105 or 7011.0110))

While no known emissions estimation method exists for these units, based on general knowledge of how they operate, it is highly unlikely that they could generate visible emissions. In addition, these units would be operated and vented directly into an office area, so monitoring or testing is not feasible.

Cleaning operations: alkaline/phosphate cleaners and associated cleaners and associated burners


(Minn. R. 7011.0610+ Minn. R. 7011.0710/715)

For these units, there are some factors available for the burners, but very little information regarding the cleaning operation itself. However, based on general knowledge of how they operate, it is highly unlikely that they could violate the applicable requirement or that testing would be feasible.

Individual units with actual emissions less than 2000 lb/year of certain pollutants

PM, variable depending on airflow Opacity < 20% (with exceptions)

(Minn. R. 7011.0715 and Minn. R. 7011.610)

or

SO2 < 0.5 lb/MMBtu Opacity < 20%

(Minn. R. 7011.2300)

These are 4 natural gas combustion units, an emergency generator, and a specialty mixing area. For the natural gas units and generator, based on the fuels used and EPA published emissions factors, it is highly unlikely that they could violate the applicable requirement. In addition, all of these units are operated and vented inside a building, so testing for PM or opacity is not feasible. The mixing area is not expected to generate particulate matter.




Discussion

Fugitive Emissions from unpaved roads and parking lots

Requirement to take reasonable measures to prevent PM from becoming airborne (Minn. R. 7011.0150)

The Facility is located in the Metro area and has all paved parking lots and few private roads. Nearly all surfaces are currently paved. The draft/proposed permit does contain a general requirement that this standard must be met. The Permittee has stated that no additional unpaved surfaces will be added in the future.

Infrequent use of spray paint equipment for routine housekeeping or plant upkeep activities not associated with primary production processes at the stationary source

PM, variable depending on airflow or process weight rate Opacity < 20%

(Minn. R. 7011.0715)

While spray equipment will have the potential to emit particulate matter, these particular activities are those not associated with production, so they would be infrequent and usually occur outdoors. Testing or monitoring is not feasible.

Equipment venting PM/PM10 inside a building, provided that emissions from the equipment are:

a). filtered through an air cleaning system; and

b). vented inside of the building 100% of the time


(Minn. R. 7011.0715)

For these units, it is highly unlikely that they could violate the applicable requirement. In addition, these units are vented inside a building, so testing for PM or opacity is not feasible.

3.4 Permit Organization

In general, the permit meets the MPCA Delta Guidance for ordering and grouping of requirements. One area where this permit deviates slightly from Delta guidance is in the use of appendices. While appendices are fully enforceable parts of the permit, in general, any requirement that the MPCA thinks should be tracked (e.g., limits, submittals, etc.), should be in Table A or B. The main reason is that the appendices are word processing sections and are not part of the tracking system. Violation of the appendices can be enforced, but the computer system will not automatically generate the necessary enforcement notices or documents. Staff must generate these

3.5 Comments Received

No comments were received.


Public Notice Period: July 1, 2011 - August 1, 2011 EPA 45-day Review Period: July 1, 2011 - August 15, 2011

4. Permit Fee Assessment

This permit action is the issuance of an individual Part 70 permit based on an application received June 26, 2007. The application fees apply under Minn. R. 7002.0019. Attachment 4 to this TSD contains the MPCA’s assessment of Application and Additional Points used to determine the permit application fee for this permit action as required by Minn. R. 7002.0019. The permit action includes two NESHAPs for which additional points apply.

5. Conclusion

Based on the information provided by Suzlon Rotor Corp, the MPCA has reasonable assurance that the proposed operation of the emission facility, as described in the Air Emission Permit No. 11700025-001 and this TSD, will not cause or contribute to a violation of applicable federal regulations and Minnesota Rules.

Staff Members on Permit Team: Jessica Forsberg (permit writer/engineer) Sarah Kilgriff (enforcement) Jennifer Lovett (enforcement) Kelsey Suddard (peer reviewer)

AQ File No. 4366; DQ 1580, 1825, 1907 Attachments: 1. PTE Summary Calculation Spreadsheets

2. Facility Description and CD-01 Forms 3. NSPS Subpart IIII Applicability Determination 4. Points Calculator


Attachment 1: PTE Calculation Spreadsheets

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(lbs/

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EU

007

Hot

Wir

e C

utte

r

EU

008

Em

erge

ncy

Gen

erat

or

EU

009

Putt

y U

se

PM--

---

---

---

---

---

-0.

770.

55--

-1.

32PM

10--

---

---

---

---

---

-0.

770.

55--

-1.

32SO

2--

---

---

---

---

---

---

-3.

20--

-3.

20N

Ox

---

---

---

---

---

---

---

18.9

9--

-18

.99

CO

---

---

---

---

---

---

---

4.35

---

4.35

VO

C1.

2931

.73

9.44

---

64.8

00.

81--

-0.

515.

1611

3.74

Lead

---

---

---

---

---

---

---

NA

---

0.00

Sing

le H

AP1

---

---

0.00

0.00

17.4

2--

---

-0.

005

0.00

17.4

3To

tal H

APs

---

---

0.59

7.31

24.7

6--

---

-0.

012.

7935

.45

1 Max

imum

sing

le h

ap is

Xyl

enes

, fro

m R

olle

r Coa

ting;

a z

ero

valu

e in

dica

tes a

n em

issi

on u

nit t

hat d

oes n

ot e

mit

xyle

nes.

Pollu

tant

Tot

alE

mis

sion

sIn

crea

se

Tab

le 2

-1.

T

otal

Fac

ility

Pot

entia

l Ann

ual E

mis

sion

s Sum

mar

y (t

ons/

yr)

Pollu

tant

Tot

alE

mis

sion

sIn

crea

se(t

ons/

yr)

Tab

le 2

-2.

T

otal

Fac

ility

Pot

entia

l Hou

rly

Em

issi

ons S

umm

ary

C:\D

ocum

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tings

\jfor

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Loca

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\Tem

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\EG

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EC G

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11_

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).xls

2-2

Suzlon Rotor Corporation - Pipestone MNTotal Facility Permit Update 3-Blades Per DayPotential to Emit

Potential Emissions (lbs/hr)Emissions from Insignificant Activities are not Included

Pollutant

EU 001HandLayup(lb/hr)

EU 002InfusionMolding(lbs/hr)

EU 003Mold

Repair & Release(lbs/hr)

EU 004Adhesive

Application(lbs/hr)

EU 005Roller

Coating(lbs/hr)

EU 006Resin Tool

Cleaner(lbs/hr)

EU 007Hot Wire

Cutter(lbs/hr)

EU008EmergencyGenerator

(lb/hr)

EU009 Putty Use (lb/hr)

TotalEmissions

(lb/hr)

PM --- --- --- --- --- --- 0.57 0.55 --- 1.13PM10 --- --- --- --- --- --- 0.57 0.55 --- 1.13SO2 --- --- --- --- --- --- --- 3.20 --- 3.20NOx --- --- --- --- --- --- --- 18.99 --- 18.99CO --- --- --- --- --- --- --- 4.35 --- 4.35

VOC 0.97 23.80 7.08 --- 48.60 0.60 --- 0.51 3.87 85.43Lead --- --- --- --- --- --- --- NA --- 0.00

Single HAP* --- --- 0.44 0.00 13.07 --- --- 0.005 2.09 13.07Total HAPS --- --- 0.44 5.48 18.57 --- --- 0.01 2.09 26.59

* Maximum single hap is Xylene from Roller Coating. Emission units which do not emit xylenes are not included in total.

Potential to Emit (tons/yr)Emissions from Insignificant Activities are not Included

Pollutant

EU 001HandLayup

(tons/yr)

EU 002InfusionMolding(tons/yr)

EU 003Mold

Repair & Release(tons/yr)

EU 004Adhesive

Application(tons/yr)

EU 005Roller

Coating(tons/yr)

EU 006Resin Tool

Cleaner(tons/yr)

EU 007Hot Wire

Cutter(tons/yr)

EU008EmergencyGenerator(tons/yr)

EU009 Putty Use

(tons/yr)

PotentialEmissions(tons/yr)

PM --- --- --- --- --- --- 2.51 0.14 --- 2.65PM10 --- --- --- --- --- --- 2.51 0.14 --- 2.65SO2 --- --- --- --- --- --- --- 0.80 --- 0.80NOx --- --- --- --- --- --- --- 4.75 --- 4.75CO --- --- --- --- --- --- --- 1.09 --- 1.09

VOC 1.82 44.51 7.13 --- 66.52 2.65 --- 0.13 1.41 124.2Lead --- --- --- --- --- --- --- NA --- 0.00

Single HAP* --- --- 0.00 0.00 17.89 --- --- 1.17E-03 0.76 17.89Total HAPS --- --- 0.08 7.34 25.41 --- --- 2.37E-03 0.76 33.60

* Maximum single hap is Xylene from Roller Coating. Emission units which do not emit xylenes are not included.

C:\Documents and Settings\jforsbe\Local Settings\Temporary Internet Files\Content.Outlook\EGLCHT62\EC GI-07 Forms - DRAFT 11_05_08 (2).xlsA-10

Suzlon Rotor Corporation - Pipestone MNTotal Facility Permit Update 4-Blades Per DayPotential to Emit

Potential Emissions (lbs/hr)Emissions from Insignificant Activities are not Included

Pollutant

EU 001HandLayup(lb/hr)

EU 002InfusionMolding(lbs/hr)

EU 003Mold

Repair & Release(lbs/hr)

EU 004Adhesive

Application(lbs/hr)

EU 005Roller

Coating(lbs/hr)

EU 006Resin Tool

Cleaner(lbs/hr)

EU 007Hot Wire

Cutter(lbs/hr)

EU008EmergencyGenerator

(lb/hr)

EU009 Putty Use (lb/hr)

TotalEmissions

(lb/hr)

PM --- --- --- --- --- --- 0.77 0.55 --- 1.32PM10 --- --- --- --- --- --- 0.77 0.55 --- 1.32SO2 --- --- --- --- --- --- --- 3.20 --- 3.20NOx --- --- --- --- --- --- --- 18.99 --- 18.99CO --- --- --- --- --- --- --- 4.35 --- 4.35

VOC 1.29 31.73 9.44 --- 64.80 0.81 --- 0.51 5.16 113.74Lead --- --- --- --- --- --- --- NA --- 0.00

Single HAP* --- --- 0.59 0.00 17.42 --- --- 0.005 2.79 17.42Total HAPS --- --- 0.59 7.31 24.76 --- --- 0.01 2.79 35.45

* Maximum single hap is Xylene from Roller Coating. Emission units which do not emit xylenes are not included in total.

Potential to Emit (tons/yr)Emissions from Insignificant Activities are not Included

Pollutant

EU 001HandLayup

(tons/yr)

EU 002InfusionMolding(tons/yr)

EU 003Mold

Repair & Release(tons/yr)

EU 004Adhesive

Application(tons/yr)

EU 005Roller

Coating(tons/yr)

EU 006Resin Tool

Cleaner(tons/yr)

EU 007Hot Wire

Cutter(tons/yr)

EU008EmergencyGenerator(tons/yr)

EU009 Putty Use

(tons/yr)

PotentialEmissions(tons/yr)

PM --- --- --- --- --- --- 3.35 0.14 --- 3.49PM10 --- --- --- --- --- --- 3.35 0.14 --- 3.49SO2 --- --- --- --- --- --- --- 0.80 --- 0.80NOx --- --- --- --- --- --- --- 4.75 --- 4.75CO --- --- --- --- --- --- --- 1.09 --- 1.09

VOC 2.42 59.35 9.50 --- 88.70 3.53 --- 0.13 1.88 165.5Lead --- --- --- --- --- --- --- NA --- 0.00

Single HAP* --- --- 0.00 0.00 23.85 --- --- 1.17E-03 1.02 23.85Total HAPS --- --- 0.11 9.78 33.88 --- --- 2.37E-03 1.02 44.79

* Maximum single hap is Xylene from Roller Coating. Emission units which do not emit xylenes are not included.

C:\Documents and Settings\jforsbe\Local Settings\Temporary Internet Files\Content.Outlook\EGLCHT62\EC GI-07 Forms - DRAFT 11_05_08 (2).xlsA-11

Suzl

on R

otor

Cor

pora

tion

The

MP

CA

has

requ

este

d th

at S

uzlo

n re

view

alte

rnat

ive

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ings

to d

eter

min

e P

TE. T

he O

rigin

al P

PG

is a

coa

ting

that

Suz

lon

orig

inal

ly u

sed

whe

n th

e pl

ant

was

con

stru

cted

. Th

e cu

rren

t PP

G S

elem

ix is

the

coat

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Suz

lon

is c

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ntly

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ng a

nd th

e pr

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g is

a c

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g th

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n is

eva

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se.

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Com

paris

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Orig

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Pro

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Low

VO

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C (l

b/ga

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383.

76To

pcoa

t Par

ts (v

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46

Cur

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Age

nt C

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AU

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270

9-07

0 H

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HS

Cur

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Age

nt V

OC

(lb/g

al)

2.21

4.59

2.39

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ts V

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n M

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11

RFU

VO

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l)4.

364.

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ty (l

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l)9.

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11.4

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olum

e S

olid

s (%

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53.8

RTU

Sol

ids

(lb/g

al)

5.47

6.64

7.85

Cur

rent

Coa

ting

Rqd

(gal

/bla

de)

***

27.5

***

Sol

ids

Vol

(gal

/bla

de)

1313

13V

ol. R

qd p

er B

lade

(gal

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OC

(lb/

blad

e)13

8.6

121.

487

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TE. B

lade

s (4

/day

) (tp

y)10

1.2

88.7

63.7

PTE

Bla

des

(3/d

ay) (

tpy)

75.9

66.5

47.8


3/25/2003

1) AQ Facility ID Number: Not Assigned2) Facility Name Suzlon Rotor Corporation3) Emission Unit Identification Number(s): EU 001 Hand Layup4) Stack/Vent Designation Number(s): SV 001(M), 002, 003, 004, 005, 006, 007, 008, 011(P)5) Control Equipment ID Number(s): N/A


Discussion:1. VOC content (% by wt.) from the 9/26/07 VOC Weight Determination report for "Hand-Lay": 1.70%2. VOC concentrations assumed equal for all materials.

10.255. There are no HAPs present in the Hand Layup materials. Therefore assume no HAPs emitted for purposes of determining PTE.6. Resin Usage per V3 blade: 153.4 lb/blade 1460.0 blades 223903.7 lb/yr7. Hardener Usage per V3 blade: 41.8 lb/blade 1460.0 blades 61034.5 lb/yr8. MSDS Nos: 103, 101, 102



Usagea

(lbs/yr)

Potential Emissions(tons/yr)


(lbs/yr)

Curing VOC Emissionsb

(lb/blade)

Potential No. Blades Produced

(blades/day)

VOC Emissions

(lbs/hr)Hand Layup Resins 223,903.7 1.90 3,806.36 2.61 1.02Hand Layup Hardeners 61,034.5 0.52 1,037.59 0.71 0.28Total --- 2.42 4,843.95 3.32 1.29a Projected to potential operation at 4 production lines and 486.67 blade sets per year.b Emissions, lbs/blade, calculated based on lbs/yr emissions and potential production of 1,460 blades/yr.

4

EC-01

3. Potential operation is 4 blades per day or 1.33 blade sets per day; potential annual production is 1,460 blades or 486.67 blade-sets. A worst-case blade set consists of three V3 blades.4. Cure time per blade, hours, assumed equal to resin cure time for EU002:

C:\Documents and Settings\jforsbe\Local Settings\Temporary Internet Files\Content.Outlook\EGLCHT62\EC GI-07 Forms - DRAFT 11_05_08 (2).xlsA-13 EU001


3/25/2003

1) AQ Facility ID Number: Not Assigned2) Facility Name Suzlon Rotor Corporation3) Emission Unit Identification Number(s): EU 002 Infusion Molding, Blade & Structural Web4) Stack/Vent Designation Number(s): SV 001 (M), 002, 006, 008 (P)5) Control Equipment ID Number(s): N/A


Discussion:1. VOC (% by wt.) from the 9/26/07 VOC Weight Determination report for "Infusion": 1.18%2. VOC content is assumed equal for all materials.

4. Resin cure time, in hours per blade: 10.255. There are no HAPS in the resin materials. Therefore assume no HAPs emitted for purposes of determining PTE.6.) Resin as applied is 74.6% by wt resin and 25.4% by wt. hardener.7. Resin Usage per Blade: 5162 lb/blade 1460.0 blades 7536213.9 lb/yr8. Hardener Usage per Blade: 1757 lb/blade 1460.0 blades 2565949.5 lb/yr9. MSDS Nos. 19, 17, 78



Usagea

(lbs/yr)



(lbs)

Curing Emissionsb

(lb/blade)

Potential No. Blades Produced Simultaneously

Curing Emissions

(lbs/hr)Infusion Molding Resin 7,536,213.9 44.28 88,550.51 60.65 4 23.67Infusion Molding Hardeners 2,565,949.5 15.07 30,149.91 20.65 4 8.06Total --- 59.35 118,700.42 --- --- 31.73a Projected to potential operation at 4 production lines and 486.67 blade sets per year.b Emissions, lbs/blade, calculated based on lbs/yr emissions and potential production of 1,460 blades/yr.

EC-01




3/25/2003

1) AQ Facility ID Number: Not Assigned2) Facility Name Suzlon Rotor Corporation3) Emission Unit Identification Number(s): EU 003 Mold Repair & Release4) Stack/Vent Designation Number(s): SV 001 (M), 008 (P)5) Control Equipment ID Number(s): N/A


Discussion1. VOC loss from Mold Repair and Mold Release product use (by weight): 100%2. VOC loss from Mold Sealer product use (by weight): 96.46%3. VOC content is assumed equal for all materials.

5. Process time per blade set from actual opreration at Suzlon.6. Mold Release Solvent 12.48 lb/ blade 1460 blades/yr 18227 lb/yr7. Mold Repair Solvent Usage 0.25 lb/ blade 1460 blades/yr 358 lb/yr8. Mold Sealer Usage 0.30 lb/ blade 1460 blades/yr 435 lb/yr9. MSDS Nos. 10,11,9


MaterialProcess Time per Blade Set

(hrs)

Potential VOC Emissionsa

(lbs/hr)

Potential HAP Emissionsa

(lbs/hr)

Potential Annual

Production(sets/yr)

Existing Potential Usageb

(lbs/yr)


Potential HAP Emissionsc

(tons/yr)

Mold Release Solvent 6.83 7.31 0.00 18,227 9.11 0.00Mold Repair Solvent 1.00 0.98 0.59 358 0.18 0.11Mold Sealer 1.00 1.15 0.00 435 0.21 0.00Total --- 9.44 0.59 --- 9.50 0.11a Emissions, lbs/hr, calculated assuming all 4 blades (1.33 blade sets) are produced at the same time, and the listed process time per blade.b Projected to potential operation at 4 production lines and 486.67 blade sets per year.

EC-01

486.67


Projected to potential operation at 4 production lines and 486.67 blade sets per year.c No HAPs identified in the MSDSs for the Mold Release Solvent or Mold Sealer; Toluene is the only HAP, at a maximum of 60%, in the Mold Repair Solvent.



3/25/2003

1) AQ Facility ID Number: Not Assigned2) Facility Name Suzlon Rotor Corporation3) Emission Unit Identification Number(s): EU 004 Adhesive Application4) Stack/Vent Designation Number(s): SV 002 (M), 003, 004, 006, 007, 0085) Control Equipment ID Number(s): N/A


Discussion:

2. Conservatively, adhesives HAPs and Solids percentages are estimated at 1% and 99%, respectively.

4. Adhesive Resin Components 1339.8 lb/ blade 1460 blades/yr 1956164 lb/yr5. Application and cure time per blade (hrs) 7.336. MSDS Nos. 25, 24

Potential to Emit


Usagea

(lbs/yr)

Potential HAPb

Emissions(tons/yr)

Potential HAPb,c

Emissions(lbs/hr)

Adhesive resin Components 1,956,164 9.78 7.31a Usage is projected to potential operation of 486.67 rotor sets per year with 4 production lines.b Assuming Total HAPs from all adhesive application use is 1% by weight.c Emissions, lbs/hr, calculated assuming all 4 blades (1.33 blade sets) are produced at the same time, and the listed process time per blade.

EC-01

1. There are no VOCs emitted during curing of adhesive materials, as reported in the 9/26/07 VOC Weight Determination report for Adhesive.

3. Potential production is 4 blades per day or 1.33 blade sets per day; potential annual production is 1,460 blades or 486.67 blade-sets. A worst-case blade set consists of three V3 blades.


Air

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Ass

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d2)

Fac

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Nam

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Rot

or C

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Rol

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Sta

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2. N

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used

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Pai

nt U

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per

Bla

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22.2

gal/b

lade

1460

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ades

3240

1.6

gal/y

r4.

Har

dene

r Usa

ge p

er B

lade

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28ga

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14.7

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Mat

eria

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pert

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Cur

rent

Mat

eria

l Use

d

Mat

eria

lV

OC

Con

tent

(% b

y w

eigh

t)D

ensi

ty(lb

s/ga

l)V

OC

(lb/

gal)

V3

Bla

de U

se(g

al/b

lade

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aint

42.0

%11

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4.38

22.1

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arde

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61.0

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s A

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11.0

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INTI

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OPE

RA

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LATI

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Cal

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base

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Cur

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5. E

ach

blad

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nos

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e re

quire

s ap

prox

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7.5

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pro

cess

tim

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6. P

oten

tial a

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ion

is 1

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bla

des

or 4

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7 bl

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sets

. P

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lTo

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AP

C

onte

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(% b

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eigh

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Xyle

ne

Con

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(% b

y w

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t)

Eth

yl b

enze

ne

(% b

y w

eigh

t)C

umen

e (%

by

wei

ght)

Gly

col

Eth

ers

(%

by w

eigh

t)P

aint

16.2

0%12

.6%

3.00

%0.

60%

---H

arde

ner

10.0

4%0.

02%

---0.

02%

10.0

%

a Coa

ting

HAP

s ar

e 12

.5%

xyl

ene,

3%

eth

ylbe

nzen

e, a

nd 0

.5%

cum

ene;

sol

vent

nap

tha

cont

ribut

es a

n ad

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nal 0

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of c

umen

e an

d 0.

1% x

ylen

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are

10%

gly

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add

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cum

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and

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ylen

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Not

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d2)

Fac

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Nam

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zlon

Rot

or C

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ratio

n3)

Em

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Num

ber(s

):EU

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g4)

Sta

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SV 0

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7 (P

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(P)

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ipm

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N/A

6) A

pplic

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Num

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Mat

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lV

3 B

lade

s P

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ced

(bla

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VO

C

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Air Quality Board Modified Permit Application Form520 Lafayette Road General Emissions Calculations Form

St. Paul, MN 55155-41943/25/2003

1) AQ Facility ID Number: Not Assigned2) Facility Name Suzlon Rotor Corporation3) Emission Unit Identification Number(s): EU 006 Resin Tool Cleaner4) Stack/Vent Designation Number(s): SV 0095) Control Equipment ID Number(s): N/A


Discussion

4. MSDS No. 117


MaterialPotential Usagea

(lbs/yr)

Potential VOCsb

(lbs/yr)Potential VOCsc

(lbs/hr)Potential VOCsb

(tons/yr)

Resin Tool Cleanup Product 11,208.5 7,061.3 0.81 3.53a Projected to potential operation of 486.67 rotor sets per year.b MSDS for product identifies product as 63% volatile by weight; therefore, assumed VOC emissions equal to 63% of potential usage.c Emissions, lbs/hr, back-calculated from tons/yr values, based on 8,760 hours/yr. (assumes continuous operation.)

EC-01

1. Potential operation is 4 blades per day or 1.33 blade sets per day; potential annual production is 1,460 blades or 486.67 blade-sets. A worst-case blade set consists of three V3 blades.3. The MSDS for the resin tool cleaner product identifies product as 63% volatile by weight; therefore, assumed VOC emissions equal to 63% of potential usage. The MSDS indicates no HAPs.


MINNESOTA POLLUTION CONTROL AGENCY PERMIT APPLICATION FORM EC-13CAIR QUALITY DIVISION HAZARDOUS AIR POLLUTANTS520 LAFAYETTE ROAD CALCULATION FORM (FUEL COMBUSTION)ST. PAUL, MN 55155-4194 5/27/1998

1) AQD Facility ID No.: Not Assigned2) Facility Name: Suzlon Rotor Corporation3) Emission Unit Identification No.: EU 008 Emergency Back-Up Generator4) Stack/Vent Designation No.: SV 0125) Maximum Rated Equipment Capacity: 590.0 kW6) Control Equipment: N/A7) Fuel Parameters

7a) 7b) 7c) 7d)

Fuel Type % Sulfur % Ash Heat Value Units Units

Diesel 0.50 137,000 btu/gal gal/hrWhen calculating Potential Emissions, use items 8a, 8b, 8d, 8e, 8g, 8h, and 8i (if a limit is proposed in item 12). When calculating Actual Emissions, use items 8a, 8b, 8c, 8f, 8g, and 8j.

8) Calculations Summary - Primary Fuel : Diesel8b) 8c) 8d) 8e) 8f) 8g) 8h) 8j)

Uncontrolled Limited Actual Maximum Actual Pollution Maximum ActualEmission Annual Emission Uncontrolled Uncontrolled Control Controlled Controlled

Factor1 Fuel Use Rate Emissions Emissions Efficiency Emissions Emissions(lbs/MMBtu) (MMBtu/yr) (lbs/hr) (tons/yr) (tons/yr) (%) (tons/yr) (tons/yr)

Acetaldehyde [534-15-6] 2.52E-05 3,007 1.52E-04 3.79E-05 3.79E-05 0.00% 3.79E-05 NAAcrolein [107-02-8] 7.88E-06 3,007 4.74E-05 1.18E-05 1.18E-05 0.00% 1.18E-05 NABenzene [71-43-2] 7.76E-04 3,007 4.67E-03 1.17E-03 1.17E-03 0.00% 1.17E-03 NAFormaldehyde [50-00-0] 7.89E-05 3,007 4.75E-04 1.19E-04 1.19E-04 0.00% 1.19E-04 NA

Naphthalene [91-20-3] 1.30E-04 3,007 7.82E-04 1.95E-04 1.95E-04 0.00% 1.95E-04 NAPOM2 2.12E-04 3,007 1.28E-03 3.19E-04 3.19E-04 0.00% 3.19E-04 NAToluene [108-88-3] 2.81E-04 3,007 1.69E-03 4.23E-04 4.23E-04 0.00% 4.23E-04 NA

(CAS)

Maximum Fuel Consumption Rate

7e)

43.9

8a)HAP Name

Xylenes [1330-20-7] 1.93E-04 3,007 1.16E-03 2.90E-04 2.90E-04 0.00% 2.90E-04 NA9.47E-03 2.37E-03 2.37E-03 2.37E-03

1 Emission factors from AP-42, Section 1.4 (07/98)2Total POM emission factor is equal to the sum of the individual POM compounds, includes Naphthalene

10) additional backup fuel - not used11) Worse-Case Potential-to-Emit Summary: (Ignore this item if filling out this form for a Registration Pemit Option D)

Before After Before After Before After Actual

Operating Operating Operating Operating Operating Operating Estimated

Limits Limits Limits Limits Limits Limits Emissions

Controlled Controlled Uncontrolled Uncontrolled Controlled Controlled Controlled

(lb/hr) (lb/hr) (ton/yr) (ton/yr) (ton/yr) (ton/yr) (tons/year)

Acetaldehyde [534-15-6] 1.52E-04 NA 3.79E-05 NA 3.79E-05 NA NAAcrolein [107-02-8] 4.74E-05 NA 1.18E-05 NA 1.18E-05 NA NABenzene [71-43-2] 4.67E-03 NA 1.17E-03 NA 1.17E-03 NA NAFormaldehyde [50-00-0] 4.75E-04 NA 1.19E-04 NA 1.19E-04 NA NA

Naphthalene [91-20-3] 7.82E-04 NA 1.95E-04 NA 1.95E-04 NA NAPOM2 1.28E-03 NA 3.19E-04 NA 3.19E-04 NA NAToluene [108-88-3] 1.69E-03 NA 4.23E-04 NA 4.23E-04 NA NAXylenes [1330-20-7] 1.16E-03 NA 2.90E-04 NA 2.90E-04 NA NA

Totals 9.47E-03 2.37E-03 2.37E-031Nahpthalene is included in the POM emissions and is not double-counted in the total HAPs.

11) Operating Limitations, if applicable: (Ignore this item if filling out this form for a Registration Pemit Option D):Limited to 500 hours of operation per year of operation per EPA's Memorandum, dated September 6, 1995 from John Seitz to the Directors of EPA Regions I through X.

HAP Name (CAS)

Totals

C:\Documents and Settings\jforsbe\Local Settings\Temporary Internet Files\Content.Outlook\EGLCHT62\EC GI-07 Forms - DRAFT 11_05_08 (2).xlsA-21 EU008 HAPs


3/25/2003

1) AQ Facility ID Number: Not Assigned2) Facility Name Suzlon Rotor Corporation3) Emission Unit Identification Number(s): EU 007 Hot Wire Cutter4) Stack/Vent Designation Number(s): SV 0105) Control Equipment ID Number(s): N/A


Discussion1. Suzlon can potentially produce up to a total of 4 blades per day, independent of type.2. Each V2 blade cuts 22,530,676 mm3 of foam (approx. 0.0225 m3).3. Each V3 blade cuts 24,755,026 mm3 of foam (approx. 0.0248 m3); therefore, V3 blade production is worst-case.4. The foam density is 70 kg/m3 (approx. 154.3 lbs/m3)5. All foam cut is assumed to be emitted.6. Foam MSDS No. 87.) 20% Safety factor included to account for inefficiencies.


MaterialFoam Cut per

Blade(lbs)

No. Produced per Daya

Potential PM/PM10

Emissions(lbs/hr)

No. Produced per Yeara

Potential PM/PM10

Emissionsa

(tons/yr)V3 Blade 4.59 4 0.77 1,460 3.35a Potential operation is 486.67 rotor sets per year (1,460 blades). (Assumes continuous operation.)

EC-01


Midtown EcoMINNESOTA POLLUTION CONTROL AGENCY PERMIT APPLICATION FORM EC-03AIR QUALITY DIVISION INTERNAL COMBUSTION ENGINE520 LAFAYETTE ROAD (SINGLE-FUEL) FORMST. PAUL, MN 55155-4194 PART 1: EMISSION CALCULATIONS

C:\Documents and Settings\jforsbe\Local Settings\Temporary Internet Files\Content.Outlook\EGLCHT62\[EC GI-07 Forms - DRAFT 11_ 02/17/05

- Fill out Part 1 of this form for each fuel burned in each engine, or attach sheets with equivalent information. If the engine emits Hazardous Air Pollutants (HAPs), fill out and attach form EC-13C. Fill out Part 2 of this form only if you are installing a generator to be used for other than emergencies.

1) AQD Facility ID No.: Not Assigned2) Facility Name: Suzlon Rotor Corporation3) Emission Unit Identification Number: EU 008 Emergency Back-Up Generator4) Stack/Vent Designation Number: SV 0125) Control Equipment Identification Number: N/A6) Engine Type: Reciprocating Turbine Other7) Engine is Used For: Non-Emergency use Emergency use only

(If you check this box, you must complete Part 2 of this form.)

8) Rated Heat Input: 590 kW9) Rated Mechanical Output: 791 bHP@ 100% Operating Load10) Fuel Type: Diesel @ 0.50 %Sulfur

Assumed 0.5% fuel sulfur content

11) Fuel Consumption Rate: 43.9 gal/hr (gal/hr or cf/hr)12) Calculations Summary

12a) 12b) 12c) 12d) 12e) 12f) 12g) 12h)Maximum Pollution Maximum Limited Actual


Maximum Pollution Maximum Limited ActualPollutant Emission Emission Uncontrolled Control Controlled Controlled Controlled

Factor Rate Emissions Efficiency Emissions Emissions Emissions(lbs/hp-hr)a (lbs/hr) (tons/yr)b (%) (tons/yr)b (tons/yr) (tons/yr)

PM 7.00E-04 0.55 0.14 0.0% 0.14 N/A N/APM10 7.00E-04 0.55 0.14 0.0% 0.14 N/A N/ASOx 4.05E-03 3.20 0.80 0.0% 0.80 N/A N/ANOx 2.40E-02 18.99 4.75 0.0% 4.75 N/A N/AVOC 6.42E-04 0.51 0.13 0.0% 0.13 N/A N/ACO 5.50E-03 4.35 1.09 0.0% 1.09 N/A N/ALead ND NA NA NA NA N/A N/A

ND=No Data Available in AP-42

13) Operating Limitations, if applicable:

b Generator is for emergency back-up power only. Therefore, calculations are based on 500 hours per year of operation per EPA's Memorandum, dated September 6, 1995 from John Seitz to the Directors of EPA Regions I through X.

Limited to 500 hours of operation per year of operation per EPA's Memorandum, dated September 6, 1995 from John Seitz to the Directors of EPA Regions I through X.

a Emission factors from AP-42, Section 3.4 "Large Stationary Diesel and All Stationary Dual-Fuel Engines", Table 3.4-1 (10/96). Generator capacity converted from KW to HP using a factor of 1.341 HP/KW as provided by AP-42 Appendix A. PM10 assumed equal to PM. AP-42, Section 3.4, contains no data on lead emissions from diesel-fueled generators.



3/25/2003

1) AQ Facility ID Number: Not Assigned2) Facility Name Suzlon Rotor Corporation3) Emission Unit Identification Number(s): EU 009 Putty Use4) Stack/Vent Designation Number(s): SV 001(M), 002, 003, 004, 005, 006, 007, 008, 011(P)5) Control Equipment ID Number(s): N/A


Discussion1. MSDS Nos. 69, 104, 111,115,113,116

2. For MSDS 69, 111,115,113 and 116 VOC Emission Factor 2% HAP Emission Factor 0.00%Note These putties involve a chemical reaction. The VOC emission factor is thought to be a connservative factor.There are no HAPs contained in these materials. Therefore HAP emissions are assumed to be 03. For MSDS 104 VOC/HAP Emission Factor 18%Note: This is conservatively based on the fact that this resin contains a max. of 18% styrene (VOC) a strict mass balance was applied.4. Process time per blade set from actual opreration at Suzlon. 2.00 hrs per blade5. Calculations assume that 4 blades are produced at once.6. Putty Use 104 7.75 lb/ blade 1460 blades/yr 11315 lb/yr

111 47.37 lb/ blade 1460 blades/yr 69155 lb/yr113 1.97 lb/blade 1460 blades/yr 2877 lb/yr

Hardener Use 69 0.14 lb/blade 1460 blades/yr 212 lb/yr115 8.92 lb/blade 1460 blades/yr 13024 lb/yr116 0.88 lb/blade 1460 blades/yr 1288 lb/yr


Material

Process Time per

Blade(hrs)

Potential VOC

Emissions(lbs/hr)

Potential HAP

Emissions(lbs/hr)

Existing Potential Usage(lbs/yr)

Potential VOC

Emissions(tons/yr)

Potential HAP

Emissions(tons/yr)

Putty Use 104 2.00 2.79 2.79 11,315 1.02 1.02111 2.00 1.89 0.00 69,155 0.69 0.00113 2.00 0.08 0.00 2,877 0.03 0.00

Hardener Use 69 2.00 0.006 0.000 212 0.002 0.00115 2.00 0.36 0.00 13,024 0.13 0.00116 2.00 0.04 0.00 1,288 0.01 0.00

Total --- 5.16 2.79 -- 1.88 1.02

EC-01

C:\Documents and Settings\jforsbe\Local Settings\Temporary Internet Files\Content.Outlook\EGLCHT62\EC GI-07 Forms - DRAFT 11_05_08 (2).xls A-24 EU009

Insignificant Activities Emission CalculationsDecal Spray Can Use

Usage: 30 cansBlades Produced: 155 BladesCans per Blade: 0.19 cans per bladeSafety Factor: 2 (Used because we did not have a full years worth of data.)Cans per Blade: 0.39 cans per bladeWt per can: 340 grams

0.34 kg0.75 lbs

Wt. per blade: 0.29 lb/bladeMax Use (lb/hr) 1.16 (assumes production of 4 blades simultaneously.)Max. Use (lb/yr) 418 (assumes production of 1440 blades per year.)

Stencil Paint for Finished Blades

Material

VOC Content(% by

weight)

Solids Content

Density(lbs/gal)

VOC Emissions

(lb/hr)

PM/PM10 (lb/hr)

VOC Emissions

(tpy)

PM/PM10 (tpy)

Paint 61.8% 39.2% 6.29 0.72 0.46 0.13 0.08

Note: Particulate Matter calculation conservatively assumes 0% transfer efficiency.

Material

Total HAP Contenta

(% by weight)

Toluene Content (% by

weight)


Carbon Black (% by

weight)

Paint 34.7% 22.0% 12.0% 0.70%PTE (lb/hr) 0.40 0.26 0.14 0.01PTE (tpy) 0.07 0.05 0.03 0.001Note: Carbon Black calculation conservatively assumes 0% transfer efficiency.

C:\Documents and Settings\jforsbe\Local Settings\Temporary Internet Files\Content.Outlook\EGLCHT62\EC GI-07 Forms - DRAFT 11_05_08 (2).xls A-25 Insignificant Activity

MATERIAL USAGEs

EU001 Hand Layup

Resin 2007 Usage 27000 kg59535 lb

297x+108y= 59535y=1.06(x)297x+114.5x = 59535411.5x=75763.8


Hardener 2007 Usage 7360.0 kg16229 lb

297x+108y= 16229y=1.06(x)297x+114.5x = 16229411.5x=16229


EU002 Infusion MoldingMax. Resin per blade was determined based on the maximum number of material used per day and calculating the number of blades produced for that day.

Max. Resin/blade3138 kg6919 lb total5162 lb resin1757 lb hardeners

EU003 Mold Repair And ReleaseDensity

Release Solvent 2915 L 0.754 kg/L 2198 kg 4846 lbRepair Solvent 60.6 L 0.712 kg/L 43.1 kg 95.1 lb

Sealent 68.1 L 0.77 kg/L 52.4 kg 115.6 lbRelease Solvent

411.5x = 4846x= 11.8 lb/V2bladey= 12.5 lb/V3blade

Repair Solvent411.5x=95.1


Sealent411.5x=115.6


C:\Documents and Settings\jforsbe\Local Settings\Temporary Internet Files\Content.Outlook\EGLCHT62\EC GI-07 Forms - DRAFT 11_05_08 (2).xls A-26 Material Usages

MATERIAL USAGEs

EU004 Adhesive Application2007 Usage 235889.0 kg

520135 lb297x+108y= 520135y=1.06(x)297x+114.5x = 520135411.5x=520135


EU005 Roller CoatingCoating

Based on the Amount of Coating Dispensed per Blade - In actuality the total amount dispensed is not used.

Usage Per Blade84.00 l3.79 l/gal

22.19 gal/blade

Hardener

Based on the Amount of Hardener Dispensed per Blade - In actuality the total amount dispensed is not used.

Usage Per Blade20.00 l3.79 l/gal5.28 gal/blade

EU006 Resin Tool Cleaner2007 Usage 2180.0 L

1351.6 kg2980 lb

297x+108y=2980y=1.06(x)297x+114.5x = 2980411.5x=2980

x= 7.2 lb/V2 bladey= 7.7 lb/V3 bladey= 0.92 gal/V3 blade

EU009 PuttiesMaterialNameMSDS # 104 69 111 115 113 116Part # 1000024 10000023 MANK102 MANK103 MANK100 MANK101Density (kg/L) 1.8 1.15 N/A N/A N/A N/AHAPs (% by wt.) 18.00% 1.00% 1.00% 1.00% 1.00% 1.00%Solids (% by wt.) 82.00% 99.00% 99.00% 99.00% 99.00% 99.00%2007 Usage 95.7 L 2.8 L 8700 kg 1638.5 kg 362 kg 162 kgUsage (lb) 380 7.10 19184 3613 798 357Blades (#) 405 405 405 405 405 405lb/blade* 0.94 0.02 47.4 8.92 1.97 0.88lb/blade ** 7.75 0.14*Assumes no difference between V2 and V3 blades.** The usage of this putty is changing. The purpose of this change is to use the chemical up. After it is used up it will no longerbe used. Because of this it is probably not correct to base the usage rate based on historical data. Instead usage was based on the useof 1.5 containers per nose cone. The hardener use was calculated by multiplying the reation of projected putty use to 2007 use.

ThinPutty

Thin Hardener

Polyester Putty

Polyester Hardener Thick Putty

Thick Hardener

C:\Documents and Settings\jforsbe\Local Settings\Temporary Internet Files\Content.Outlook\EGLCHT62\EC GI-07 Forms - DRAFT 11_05_08 (2).xls A-27 Material Usages

Midtown Eco-EMINNESOTA POLLUTION CONTROL AGENCY PERMIT APPLICATION FORM EC-02AIR QUALITY DIVISION SUBSTITUTE EXTERNAL COMBUSTION (BOILER)520 LAFAYETTE ROAD CALCULATION FORMST. PAUL, MN 55155-4194

C:\Documents and Settings\jforsbe\Local Settings\Temporary Internet Files\Content.Outlook\EGLCHT62\[EC GI-07 Forms - DRAFT 11_05_08 (2).xls]GI-07

AQD Facility ID No.: Not AssignedFacility Name: Suzlon Rotor CorporationEmission Unit Identification No.: N/A - Space heaters insignificant under Minn. R. 7007.1300 Subp. 3(I)Stack/Vent Designation No.: N/AMaximum Rated Boiler Capacity: 8.0 MMBtu/hr (Total of all units)

Control Equipment: NoneBoiler Type: N/A

Expected Operational Schedule

Fuel Parameters

% Moisture Heat Value Units

N/A 1,020 Btu/scf 7.8E-03 106 scf/hr

Calculations - Fuel : Natural Gas

PollutantEmission Factor1

Uncontrolled Emission

R t

Maximum Uncontrolled

E i i

Pollution Control

Effi i

Controlled Emission

R t

Maximum Controlled E i i

Limited Controlled E i i

Actual Emissions

Natural Gas AP-42

POTENTIAL TO EMIT

Fuel Consumption Rate(value) (units)

Data SourcesFuel Type

Pollutant Factor(lb/106scf)

Rate(lbs/hr)

Emissions(tons/yr)

Efficiency(%)

Rate(lbs/hr)

Emissions(tons/yr)

Emissions(tons/yr)

Emissions(tons/yr)

PM 7.6 0.1 0.3 0.0% 0.1 0.3 0.3PM10 7.6 0.1 0.3 0.0% 0.1 0.3 0.3SO2 0.6 4.7E-03 2.1E-02 0.0% 4.7E-03 2.1E-02 2.1E-02NOx 100 0.8 3.4 0.0% 0.8 3.4 3.4

CO 84 0.7 2.9 0.0% 0.7 2.9 2.9

VOC 5.5 4.3E-02 0.2 0.0% 4.3E-02 0.2 0.2

Lead 5.0E-04 3.9E-06 1.7E-05 0.0% 3.9E-06 1.7E-05 1.7E-051 Emission factors from AP-42, Section 1.4, "Natural Gas Combustion".

Worse-Case Potential-to-Emit Summary:

Pollutant

Controlled Emission

Rate(lb/hr)

Maximum Controlled Emissions(ton/yr)

Limited Controlled Emissions(tons/yr)

PM 0.1 0.3 0.3PM10 0.1 0.3 0.3SO2 0.0 0.0 0.0NOx 0.8 3.4 3.4CO 0.7 2.9 2.9VOC 0.0 0.2 0.2Lead 0.0 0.0 0.0

C:\Documents and Settings\jforsbe\Local Settings\Temporary Internet Files\Content.Outlook\EGLCHT62\EC GI-07 Forms - DRAFT 11_05_08 (2).xlsA-28 NatGas Boilers

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3.78

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Sheet1

GI-07 for GHG Emissions

1a) AQ Facility ID No.: 11700025 1b) AQ File No.: 4366 2) Facility Name: Suzlon Rotor Corporation

3a) 3b) 3c) CAS#: ---Emission Emission 3d) Pollutant Name: CO2eSource Source 3e) 3f)Type ID No. Potential Actual

Lbs per Hr Unrestricted tpyLimited

tpy Tons per yr

Emergency Generator EU008 1005 251 251 NANatural Gas Combustion IA 936 4100 4100 NA

4) Potential ActualTotal Unrestricted Limited Tons/year

Facility 4,351 4,351 NA

5) Compact disc containing editable calculation speadsheet(s) included in the application package

Editable calculation spreadsheet(s) will be emailed to the MPCA upon request

Page 1Page 1

Sheet1

Page 2Page 2

Suzlon Rotor CorporationGreenhouse Gas Potential Emissions Evaluation

Selection of GHG Emission FactorsEmission Factor Source 2: §98 Subpart C

Fuel HHV 1 Pollutant

EF (kg/MMBtu

)EF

(lb/MMBtu) NotesIndustrial Boilers & Dryers - Fuel CombustionNatural Gas 1020 btu/scf CO2 53.02 116.89

CH4 1.00E-03 2.20E-03N2O 1.00E-04 2.20E-04

N2O - Low NOx Burners 1.00E-04 2.20E-04

Diesel 140 CO2 73.96 163.05CH4 3.00E-03 6.61E-03N2O 6.00E-04 1.32E-03

1 - Higher Heat Values (HHV) from previous permit applications.2 - Emission Factor Sources: 40 CFR Part 98 Subpart C (EPA GHG Mandatory Reporting Rule).

§98 Subpart C - final rule published in Federal Register 10/30/09

MMBtu/ Mgal

EC-17Greenhouse Gas Emissions

Air Quality Permit ProgramDoc Type: Permit Application

1a) AQ Facility ID No.: 11700025 1b) AQ File No.: 43662) Facility Name: Suzlon Rotor Corporation3) Emission unit ID number: EU008 Emergency Generator4) Stack/Vent designation number(s):5) Control equipment number(s): N/A6) Operating Limitations, if applicable: None7) Greenhouse Gas Emissions Summary.

791 bHP 590 kW 43.9 gal/hrMaximum Rated Capacity: 791.0Fuel Parameters: Fuel Type Heat Value Fuel Consumption Rate

Diesel 140 MMBtu/Mgal 0.044 Mgal/hrDiesel

7a) 7b) 7c) 7d) 7e) 7f) 7g) 7h)

Emission Factor

Uncontrolled Emission Rate

Pollution Control

Efficiency

Controlled Emission Rate

Limited and ControlledEmission Rate

Expected Actual Controlled

Emission Rate(lb/MMbtu)1 (lb/hr) (tpy) CO2e (tpy) (%) (lb/hr) (tpy) CO2e (tpy) (lb/hr) (tpy) CO2e (tpy) (tpy) CO2e (tpy)

CO 1 163 05 1 002 251 251 0 0% 1 002 251 251 1 002 251 251 NA NA

GHG Pollutant GWP

CO2 1 163.05 1,002 251 251 0.0% 1,002 251 251 1,002 251 251 NA NACH4 21 6.61E-03 0.041 1.02E-02 0.213 0.0% 4.06E-02 1.02E-02 0.2 4.06E-02 1.02E-02 0.213 NA NAN2O 310 1.32E-03 0.008 2.03E-03 0.630 0.0% 8.13E-03 2.03E-03 0.6 8.13E-03 2.03E-03 0.630 NA NAHFCs N/A -- -- -- -- -- -- -- -- -- -- -- --PFCs N/A -- -- -- -- -- -- -- -- -- -- -- --SF6 23,900 N/A -- -- -- -- -- -- -- -- -- -- -- --Total GHG (CO2e) 251 251 251 NA1 - See the Emission Factor sheet for additional information on the emission factor. Emissions factors from 40 CFR 98, subp. C.

Note: This is an emergency unit only. Therefore the calculation annual emissions are calculated based on the unit operated 500 hours per year.

EC-17Greenhouse Gas Emissions

Air Quality Permit ProgramDoc Type: Permit Application

1a) AQ Facility ID No.: 11700025 1b) AQ File No.: 43662) Facility Name: Suzlon Rotor Corporation3) Emission unit ID number: Natural Gas Combustion Units Insignificant Activities4) Stack/Vent designation number(s):5) Control equipment number(s): N/A6) Operating Limitations, if applicable: None7) Greenhouse Gas Emissions Summary.

Maximum Rated Capacity: 8.00 MMBtu/hrFuel Parameters: Fuel Type Heat Value Fuel Consumption Rate

Natural Gas 1,020 btu/scf 7,843 cf/hrNatural Gas

7a) 7b) 7c) 7d) 7e) 7f) 7g) 7h)

Emission Factor

Uncontrolled Emission Rate

Pollution Control

Efficiency

Controlled Emission Rate

Limited and ControlledEmission Rate

Expected Actual Controlled

Emission Rate(lb/MMbtu)1 (lb/hr) (tpy) CO2e (tpy) (%) (lb/hr) (tpy) CO2e (tpy) (lb/hr) (tpy) CO2e (tpy) (tpy) CO2e (tpy)

CO 1 116 89 935 4 096 4 096 0 0% 935 4 096 4 096 935 4 096 4 096 NA NA

GHG Pollutant GWP

CO2 1 116.89 935 4,096 4,096 0.0% 935 4,096 4,096 935 4,096 4,096 NA NACH4 21 2.20E-03 1.76E-02 7.72E-02 1.6 0.0% 1.76E-02 7.72E-02 1.6 1.76E-02 7.72E-02 1.6 NA NAN2O 310 2.20E-04 1.76E-03 7.72E-03 2.4 0.0% 1.76E-03 7.72E-03 2.4 1.76E-03 7.72E-03 2.4 NA NAHFCs N/A -- -- -- -- -- -- -- -- -- -- -- --PFCs N/A -- -- -- -- -- -- -- -- -- -- -- --SF6 23,900 N/A -- -- -- -- -- -- -- -- -- -- -- --Total GHG (CO2e) 4,100 4,100 4,100 NA1 - See the Emission Factor sheet for additional information on the emission factor. Emissions factors from 40 CFR 98, subp. C.

Note: These are the natural gas heating units identified in the original permit application.


Attachment 2: Facility Description and CD-01 Forms

MINNESOTA POLLUTION CONTROL AGENCYAIR QUALITY520 LAFAYETTE ROADST. PAUL, MN 55155-4194

Show:Action:AQD Facility ID:Facility Name:

Active and Pending RecordsPER 00111700025Suzlon Rotor Corp

FACILITY DESCRIPTION: GROUPS (GP)

13 December, 2010 15:02

ID No. AddedBy

(Action)

RetiredBy

(Action)

Includein EI

OperatorID

for Item

Group Description Group ItemsGroupStatus

1 GP 001 PER 001 Coating Operations Subject to NESHAP Subp. PPPP EU 003, EU 004, EU 005Active

Page 1 of 1

MINNESOTA POLLUTION CONTROL AGENCYAIR QUALITY520 LAFAYETTE ROADST. PAUL, MN 55155-4194

Show: Active and Pending RecordsAction: PER 001AQD Facility ID: 11700025Facility Name: Suzlon Rotor Corp

13 December, 2010 15:03

FACILITY DESCRIPTION: STACK/VENTS (SV)

ID No. Discharge DirectionFlow Rate/Temperature

Information Source

Exit GasTemperature

at Top(ºF)

DesignFlow Rate

at Top(ACFM)

Width(feet)

Diameteror Length

(feet)

Inside DimensionsHeight ofOpening

FromGround(feet)

AddedBy

(Action)

RetiredBy

(Action)

OperatorID

for Item

Operators DescriptionStack/Vent

Status

1 SV 001 HorizontalEstimate72300003.54.537PER 001 EF7 EF7, Bldg AActive








9 SV 009 HorizontalEstimate7212781.335PER 001 Waste Storage Area, Resin Tool WasherActive

10 SV 010 HorizontalEstimate7210002.332.338PER 001 Hot Wire Cutter, Bldg BActive

11 SV 011 72150003.03.025PER 001 EF18 EF18, Proposed Nose Cone Area; Bldg BActive

12 SV 012 Up, unknown CapEstimate100047000.6711.5PER 001 Emergency GeneratorActive

Page 1 of 1

ST. PAUL, MN 55155-4194

Show: Pending Records OnlyAction: PER 001AQD Facility ID: 11700025Facility Name:

MINNESOTA POLLUTION CONTROL AGENCYAIR QUALITY520 LAFAYETTE ROAD

13 December, 2010 15:04

FACILITY DESCRIPTION: EMISSION UNIT (EU)

MaxFuelInput

(mil Btu)

Suzlon Rotor Corp

RetiredBy

(Action)

Operator DescriptionID No. EmissionUnit

Status

AddedBy

(Action)

ControlEquip.

ID No(s).

Stack/Vent

ID No(s).

OperatorID

for Item

Insignif-icant

Activity

SICManufacturer ModelNumber

Max.Design

Capacity

MaximumDesign

Capacity

Materials Units n Units d

1 Hand Layup (HLU)EU 001 Active PER 001 SV 001 (M)SV 002 (P)SV 003 (P)SV 004 (P)SV 005 (P)SV 006 (P)SV 007 (P)SV 008 (P)SV 011 (P)

3511

2 Infusion MoldingEU 002 Active PER 001 SV 001 (M)SV 002 (P)SV 006 (P)SV 008 (P)

3511

3 Mold Repair & ReleaseEU 003 Active PER 001 SV 001 (M)SV 008 (P)

3511

4 Adhesive Application(Production and Repair)

EU 004 Active PER 001 SV 002 (M)SV 003 (P)SV 004 (P)SV 006 (P)SV 007 (P)SV 008 (P)

3511

5 Roller CoatingEU 005 Active PER 001 SV 003 (M)SV 007 (P)SV 011 (P)

3511

6 Resin Tool CleanerEU 006 Active PER 001 SV 009 (M) 3511

7 Hot Wire CutterEU 007 Active PER 001 SV 010 (M) 3511

8 Emergency GeneratorEU 008 Active PER 001 SV 012 (M) Elect Energy3511Caterpillar 3412 590 Kw

Page 1 of 1 (a)

13 December, 2010 15:04

FACILITY DESCRIPTION: EMISSION UNIT (EU)

ID No. ElevatorType

BottleneckPct.Fuel/

SpaceHeat

Firing MethodAddedBy

(Action)

RemovalDate

InitialStartup

Date

Comm-ence

Const.Date

EmissionUnit

Status

1 EU 001 PER 001 11/29/200603/01/2006Active

2 EU 002 PER 001 11/29/200603/01/2006Active

3 EU 003 PER 001 11/29/200603/01/2006Active

4 EU 004 PER 001 11/29/200603/01/2006Active

5 EU 005 PER 001 11/29/200603/01/2006Active

6 EU 006 PER 001 11/29/200603/01/2006Active

7 EU 007 PER 001 11/29/200603/01/2006Active

8 EU 008 PER 001 11/29/200603/01/2006Active

Page 1 of 1 (b)

MINNESOTA POLLUTION CONTROL AGENCYAIR QUALITY520 LAFAYETTE ROADST. PAUL, MN 55155-4194 COMPLIANCE PLAN CD-01

Facility Name: Suzlon Rotor Corp


29 Jun, 2011 10:52Page 1 of 14

Subject Item: Total Facility

NC/CA

Type Citation Requirement

CD hdr SOURCE SPECIFIC REQUIREMENTS1.0

CD Minn. R. 7005.0100, subp. 35a Maximum Contents of Materials: The Permittee assumed certain worst-casecontents of materials, method of materials application, and time required forapplication and curing of materials when determining the short term potential toemit of emission units EU 001, EU 002, EU 003, EU 004, EU 005, EU 006, EU 007,EU 008, and EU 009. These assumptions are listed in Appendix III of this permit.Changing any of these assumptions to increase short term potential to emit isconsidered a change in method of operation that must be evaluated under Minn. R.7007.1200, subp. 3 to determine if a permit amendment or notification is requiredunder Minn. R. 7007.1150.

2.0

LIMIT Title I Condition: To avoidclassification as a major sourceunder 40 CFR Section 52.21 &Minn. R. 7007.3000

Production: less than or equal to 4 process output blades per day. The Permitteeshall not operate the facility in any capacity other than for the purpose of producingor repairing up to four wind turbine blades per day. This includes but is not limitedto painting operations and use of the hot wire cutter.The Permittee shall keep a daily record of blades produced.

3.0

CD Title I Condition: To avoidclassification as a major sourceunder 40 CFR Section 52.21 &Minn. R. 7007.3000; ConsentDecree para. 30 A

Sandblasting is not allowed under this permit. Prior to conducting any sandblastingactivities, the Permittee must submit a permit amendment application inaccordance with the requirements of Minn. R. 7007.1150 through Minn. R.7007.1500 and install a baghouse with a total enclosure around all sandblastingactivities.

4.0

CD Title I Condition: To avoidclassification as a major sourceunder 40 CFR Section 52.21 &Minn. R. 7007.3000; ConsentDecree para. 30 B

The Permittee shall submit a request for an applicability determination to the MPCAfor any insignificant, minor, or moderate modification it wishes to make for a periodof 24 months from June 24, 2010.

5.0

CD Minn. R. 7007.0800, subp. 2 Permit Appendices: This permit contains appendices as listed in the permit Table ofContents. The Permittee shall comply with all requirements contained in theappendices.

6.0

CD hdr OPERATIONAL REQUIREMENTS7.0

CD 40 CFR pt. 50; Minn. Stat. Section116.07, subds. 4a & 9; Minn. R.7007.0100, subps. 7A, 7L & 7M;Minn. R. 7007.0800, subps. 1, 2 &4; Minn. R. 7009.0010 -7009.0080

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

8.0

CD Minn. R. 7011.0020 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.

9.0

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

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

10.0

CD Minn. R. 7007.0800, subps. 14and 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.

11.0

CD Minn. R. 7019.1000, subp. 4 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.

12.0

CD Minn. R. 7011.0150 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.

13.0




29 Jun, 2011 10:52Page 2 of 14

CD Minn. R. 7030.0010 - 7030.0080 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.

14.0

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

15.0

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

16.0

CD hdr PERFORMANCE TESTING17.0

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

18.0

CD Minn. Rs. 7017.2030, subp. 1-4,7017.2018 and Minn. R.7017.2035, subp. 1-2

Performance Test Notifications and Submittals:

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

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

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

19.0

CD Minn. R. 7017.2025, subp. 3 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.

20.0

CD hdr MONITORING REQUIREMENTS21.0

CD Minn. R. 7007.0800, subp. 4(D) Monitoring Equipment Calibration: Annually calibrate all required monitoringequipment (any requirements applying to continuous emission monitors are listedseparately in this permit).

22.0

CD Minn. R. 7007.0800, subp. 4(D) Operation of Monitoring Equipment: Unless otherwise noted in Tables A, B, and/orC, monitoring a process or control equipment connected to that process is notnecessary during periods when the process is shutdown, or during checks of themonitoring systems, such as calibration checks and zero and span adjustments. Ifmonitoring records are required, they should reflect any such periods of processshutdown or checks of the monitoring system.

23.0

CD hdr RECORDKEEPING24.0

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

25.0

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

26.0

CD Minn. R. 7007.1200, subp. 4 When the Permittee determines that no permit amendment or notification isrequired prior to making a change, the Permittee must retain records of allcalculations required under Minn. R. 7007.1200. For expiring permits, theserecords shall be kept for a period of five years from the date the change was madeor until permit reissuance, whichever is longer. For nonexpiring permits, theserecords shall be kept for a period of five years from the date that the change wasmade. The records shall be kept at the stationary source for the current calendaryear of operation and may be kept at the stationary source or office of thestationary source for all other years. The records may be maintained in eitherelectronic or paper format.

27.0

CD hdr REPORTING/SUBMITTALS28.0




29 Jun, 2011 10:52Page 3 of 14

CD Minn. R. 7019.1000, subp. 3 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, B,and 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.

29.0

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

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

30.0

CD Minn. R. 7019.1000, subp. 1 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.

31.0

CD Minn. R. 7019.1000, subp. 1 Notification of Deviations Endangering Human Health or the Environment Report:Within 2 working days of discovery, notify the Commissioner in writing of anydeviation from permit conditions which could endanger human health or theenvironment. Include the following information in this written description:1. the cause of the deviation;2. the exact dates of the period of the deviation, if the deviation has been corrected;3. whether or not the deviation has been corrected;4. the anticipated time by which the deviation is expected to be corrected, if not yet corrected; and5. steps taken or planned to reduce, eliminate, and prevent reoccurrence of the deviation.

32.0

S/A Minn. R. 7007.0800, subp. 6(A)(2) Semiannual Deviations Report: due 30 days after end of each calendar half-yearfollowing Permit Issuance. The first semiannual report submitted by the Permitteeshall cover the calendar half-year in which the permit is issued. The first report ofeach calendar year covers January 1 - June 30. The second report of eachcalendar year covers July 1 - December 31. If no deviations have occurred, thePermittee shall submit the report stating no deviations.

33.0

CD Minn. R. 7007.1150 through Minn.R. 7007.1500

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.

34.0

S/A Minn. R. 7007.0400, subp. 2 Application for Permit Reissuance: due 180 days before expiration of ExistingPermit.

35.0

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

36.0

S/A Minn. R. 7007.0800, subp. 6(C) Compliance Certification: due 30 days after end of each calendar year followingPermit Issuance (for the previous calendar year). The Permittee shall submit this ona form approved by the Commissioner, both to the Commissioner and to the USEPA regional office in Chicago. This report covers all deviations experienced duringthe calendar year.

37.0


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

38.0


Emission Fees: due 60 days after receipt of an MPCA bill.39.0




29 Jun, 2011 10:52Page 4 of 14

CD 40 CFR pt. 68 The Permittee must submit a Risk Management Plan (RMP) under 40 CFR pt. 68.Each owner or operator of a stationary source, at which a regulated substance ispresent above a threshold quantity in a process, shall design and implement anaccidental release prevention program. An initial RMP must be submitted no laterthan the latest of the following dates: 1) June 21, 1999; 2) Three years after thedate on which a regulated substance is first listed under 40 CFR Section 68.130; or3) The date on which a regulated substance is first present above a thresholdquantity in a process. A full update and resubmission of the RMP is required atleast once every five years. The five-year anniversary date is reset whenever yourfacility fully updates and resubmits their RMP. Submit RMPs to the RiskManagement Plan Reporting Center, P.O. Box 1515, Lanham-Seabrook, Maryland20703-1515. RMP information may be obtained at http://www.epa.gov/swercepp orby calling 1-800-424-9346.

40.0




29 Jun, 2011 10:52Page 5 of 14

Subject Item: GP 001 Coating Operations Subject to NESHAP Subp. PPPP

Associated Items: EU 003 Mold Repair & Release

EU 004 Adhesive Application (Production and Repair)

EU 005 Roller Coating

NC/CA


CD 40 CFR Section 63.4491; Minn. R.7011.8130

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

1.0

CD 40 CFR Section 63.4482(b); Minn.R. 7011.8130

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

2.0


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

3.0

CD Minn. R. 7007.0800, subp. 4 and 5 Unless otherwise noted, all equations for 40 CFR pt 63, subp. PPPP referenced inthe requirements of GP 001 can be found in Appendix II of this permit.

4.0

CD hdr EMISSION LIMIT5.0

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

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

6.0

CD hdr COMPLIANCE REQUIREMENTS7.0


The Permittee must include all coatings (as defined in 40 CFR Section 63.4581),thinners and/or other additives, and cleaning materials used in the affected sourcewhen determining whether the HAP emission rate is equal to or less than the HAPemission limit. To make this determination, the Permittee must use at least one ofthe three compliance options listed in paragraphs (a) through (c) of 40 CFR Section63.4491.As stated earlier, this permit only includes the requirements associated with thecompliant material and the emission rate without add-on controls options specifiedin 40 CFR Section 63.4491(a) and (b).

8.0

CD 40 CFR Section 63.4491; Minn. R.7011.8130 (cont.)

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

9.0

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

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

10.0




29 Jun, 2011 10:52Page 6 of 14

CD 40 CFR Sections 63.4541(a) and63.4551(a); Minn. R. 7011.8130

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

11.0

CD 40 CFR Sections 63.4541(a) and63.4551(a); Minn. R. 7011.8130(cont.)

Continued:2) Method 24 (appendix A to 40 CFR pt. 60). For coatings, the Permittee may useMethod 24 to determine the mass fraction of nonaqueous volatile matter and usethat value as a substitute for mass fraction of organic HAP. For reactive adhesivesin which some of the HAP react to form solids and are not emitted to theatmosphere, the Permittee may use the alternative method described in appendix Ato 40 CFR pt. 63, subp. PPPP, rather than Method 24. The Permittee may use thevolatile fraction that is emitted, as measured by the alternative method in appendixA to 40 CFR pt. 63, subp. PPPP, as a substitute for the mass fraction of organicHAP;3) Alternative Method. The Permittee may use an alternative test method fordetermining the mass fraction of organic HAP once the Administrator has approvedit. The Permittee must follow the procedure in 40 CFR Section 63.7(f) to submit analternative test method for approval;

12.0


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

13.0


Continued:5) Solvent blends. Solvent blends may be listed as single components for somematerials in data provided by manufacturers or suppliers. Solvent blends maycontain organic HAP which must be counted toward the total organic HAP massfraction of the materials. When test data and manufacturer's data for solvent blendsare not available, the Permittee may use the default values for the mass fraction oforganic HAP in these solvent blends listed in Table 3 or 4 of 40 CFR pt. 63, subp.PPPP.

14.0


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

15.0

CD 40 CFR Sections 63.4541(b) and63.4551(b); Minn. R. 7011.8130

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

16.0




29 Jun, 2011 10:52Page 7 of 14

CD 40 CFR Sections 63.4541(b) and63.4551(b); Minn. R. 7011.8130(cont.)

Continued:3) Information from the supplier or manufacturer of the material. The mass fractionof coating solids for each coating may be obtained from the supplier ormanufacturer. If there is a disagreement between such information and the testmethod results, then the test method results will take precedence unless, afterconsultation it is demonstrated to the satisfaction of the MPCA that the formulationdata are correct.

17.0

CD hdr Compliant Material Requirements18.0

CD 40 CFR Section 63.4491(a), Minn.R. 7011.8130

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

19.0


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

20.0


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

21.0


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

22.0

CD 40 CFR Section 63.4541(c); Minn.R. 7011.8130

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

23.0

CD 40 CFR Section 63.4541(d); Minn.R. 7011.8130

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

24.0

CD 40 CFR Section 63.4542(a); Minn.R. 7011.8130

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

25.0


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

26.0

CD hdr Emission Rate Without Add-On Controls Requirements27.0




29 Jun, 2011 10:52Page 8 of 14


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

28.0


The Permittee must complete the initial compliance demonstration for the initialcompliance period according to the requirements of 40 CFR Section 63.4551. Theinitial compliance period begins on April 19, 2007 and ends on April 30, 2008.The Permittee must determine the mass of organic HAP emissions and mass ofcoating solids used each month and then calculate an organic HAP emission rateat the end of the initial compliance period. The initial compliance demonstrationincludes the calculations according to 40 CFR Section 63.4551 and supportingdocumentation showing that during the initial compliance period the organic HAPemission rate was equal to or less than the HAP emission limit.

29.0


The Permittee may use the emission rate without add-on controls option for anyindividual coating operation, for any group of coating operations in the affectedsource, or for all the coating operations in the affected source. The Permittee mustuse either the compliant material option or the emission rate with add-on controlsoption for any coating operation in the affected source for which the Permittee doesnot use this option. To demonstrate initial compliance using the emission ratewithout add-on controls option, the coating operation or group of coating operationsmust meet the applicable HAP emission limit.The Permittee must conduct a separate initial compliance demonstration for eachgeneral use coating operation. The Permittee must meet all the requirements of 40CFR Section 63.4551.

30.0


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

31.0


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

32.0


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

33.0

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

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

34.0

CD 40 CFR Section 63.4551(d); Minn.R. 7011.8130

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

35.0




29 Jun, 2011 10:52Page 9 of 14

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

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

36.0

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

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

37.0

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

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

38.0

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

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

39.0

CD 40 CFR Section 63.4552(a); Minn.R. 7011.8130

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

40.0


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

41.0

CD hdr RECORDKEEPING42.0

CD 40 CFR Sections 63.4530,63.4542(d), and 63.4552(d); Minn.R. 7011.8130

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

43.0




29 Jun, 2011 10:52Page 10 of 14


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

44.0


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

45.0


Continued:9) If the Permittee uses an allowance in Equation 2 for organic HAP contained inwaste materials sent to or designated for shipment to a treatment, storage, anddisposal facility (TSDF) according to 40 CFR Section 63.4551(e)(4), the Permitteemust keep records of the information specified in paragraphs 40 CFR Section63.4530(g)(1) through (3); and10) Records of the date, time and duration of each deviation.

46.0


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

47.0

CD hdr SUBMITTALS48.0


Notification49.0

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

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

50.0




29 Jun, 2011 10:52Page 11 of 14

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

Content of Notification of Compliance Status, continued:6) If the Permittee had a deviation, include the following information:- A description and statement of the cause of the deviation.- If the Permittee failed to meet the HAP emission limit, include all the calculationsused to determine the kg (lb) of organic HAP emitted per kg (lb) coating solidsused. The Permittee does not need to submit information provided by the materials'suppliers or manufacturers, or test reports;7) For each of the data items listed below, include an example of how the Permitteedetermined the value, including calculations and supporting data. Supporting datamay include a copy of the information provided by the supplier or manufacturer ofthe example coating or material. The Permittee does not need to submit copies ofany test reports

51.0


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

52.0


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

53.0

S/A 40 CFR Section 63.4520(a)(1)(i),(ii), and (iv); Minn. R. 7011.8130

Semiannual Compliance Report: due 31 days after end of each calendar half-yearfollowing Permit Issuance

54.0

CD 40 CFR Section 63.4540(a)(3);Minn. R. 7011.8130

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

55.0


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

56.0


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

57.0


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

58.0




29 Jun, 2011 10:52Page 12 of 14


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

59.0




29 Jun, 2011 10:52Page 13 of 14

Subject Item: EU 007 Hot Wire Cutter

Associated Items: SV 010 Hot Wire Cutter, Bldg B

NC/CA


CD hdr EMISSION LIMIT1.0

LIMIT Minn. R. 7011.0715, subp. 1(A) Total Particulate Matter: less than or equal to 0.30 grains/dry standard cubic foot ofexhaust gas unless required to further reduce emissions to comply with the lessstringent limit of either Minn. R. 7011.0730 or Minn. R. 7011.0735.

2.0

LIMIT Minn. R. 7011.0715, subp. 1(B) Opacity: less than or equal to 20 percent opacity3.0




29 Jun, 2011 10:52Page 14 of 14

Subject Item: EU 008 Emergency Generator

Associated Items: SV 012 Emergency Generator

NC/CA


CD hdr EMISSION LIMITS1.0

LIMIT Minn. R. 7011.2300, subp. 1 Opacity: less than or equal to 20 percent opacity once operating temperatures havebeen attained.

2.0

LIMIT Minn. R. 7011.2300, subp. 2 Sulfur Dioxide: less than or equal to 0.50 lbs/million Btu heat input . The potential toemit from the unit is 0.49 lb/MMBtu due to equipment design, allowable fuel, andlimited sulfur content of fuel.

3.0

LIMIT Minn. R. 7007.0800, subps. 4 & 5 Sulfur Content of Fuel: less than or equal to 0.49 percent by weight4.0

CD hdr OPERATING CONDITIONS5.0

CD Minn. R. 7005.0100, subp. 35a Fuel type: No. 2 fuel oil only by design.6.0

LIMIT Minn. R. 7007.0800, subp. 4 & 5 Operating Hours: less than or equal to 500 hours/year using 12-month Rolling Sumto be calculated by the 15th day of each month.

7.0

CD hdr RECORDKEEPING REQUIREMENTS8.0

CD Minn. R. 7007.0800, subp. 4 & 5 Hours of Operation: The Permittee shall maintain documentation on site that theunit is an emergency generator by design that qualifies under the U.S. EPAmemorandum entitled "Calculating Potential to Emit (PTE) for EmergencyGenerators" dated September 6, 1995, limiting operation to 500 hours per year.

9.0

CD Minn. R. 7007.0800, subps. 4 & 5 Fuel Supplier Certification: The Permittee shall obtain and maintain a fuel suppliercertification for each shipment of No. 2 fuel oil, certifying that the sulfur contentdoes not exceed 0.49% by weight. The certification must include the name of thefuel oil supplier and the maximum sulfur content of the fuel.

10.0

CD Minn. R. 7007.0800, subp. 5 The Permittee shall keep records of fuel type and usage on a monthly basis.11.0


Attachment 3: NSPS Subpart IIII Applicability Determination

1

Forsberg, Jessica (MPCA)

From: [email protected]: Wednesday, March 19, 2008 8:36 AMTo: Forsberg, JessicaCc: [email protected]: Re: NSPS IIII applicability

That's correct Jessica. If the engine was built prior to 4/1/06 then it is not covered by Subpart IIII regardless of the date it was ordered. Thanks, Jaime "Forsberg, Jessica" <Jessica.Forsber To [email protected]> Jaime Pagan/RTP/USEPA/US@EPA cc 03/18/2008 02:59 PM Subject NSPS IIII applicability Dear Mr. Pagan: The current operators of a facility for which I am writing an air permit has been unable to determine the date their emergency generator was ordered. Since it was manufactured before April 1, 2006, it seems reasonable that it doesn't matter when the order was placed in determining NSPS Subpart IIII applicability. I am inclined to agree with the Permittee's determination copied below. Senior staff I've discussed this with have agreed, as has supervisor, Carolina Schutt. She recommended that I contact you for concurrence. Thank you for your attention to this matter. Sincerely, Jessica L. Forsberg Engineer Air Quality Permit Section Minnesota Pollution Control Agency 651-296-7796 -----Original Message----- From: Lori A. Bartels [mailto:[email protected]]

2

Sent: Monday, March 17, 2008 2:36 PM To: Forsberg, Jessica Cc: [email protected] Subject: Suzlon Emergency Generator Jessica We have been unable to determine the date that Suzlon commenced construction of the emergency generator (ordered). However, from Ziegler, the engine manufacturer we have been able to determine the date that the engine was manufactured. It was manufactured on August 4, 2005. Based on this date and 40 CFR 60.4200 (a)(2)(i) we believe that the generator is not subject to the NSPS. 60.4200 Am I subject to this subpart? (a) The provisions of this subpart are applicable to manufacturers, owners, and operators of stationary compression ignition (CI) internal combustion engines (ICE) as specified in paragraphs (a)(1) through (3) of this section. For the purposes of this subpart, the date that construction commences is the date the engine is ordered by the owner or operator… ...(2) Owners and operators of stationary CI ICE that commence construction after July 11, 2005 where the stationary CI ICE are: (i) Manufactured after April 1, 2006 and are not fire pump engines, or Please let us know if this you agree with this determination or need any further information. Lori


Attachment 4: Points Calculator

Points Calculator

1) AQ Facility ID No.: 11700025 Total Points 302) Facility Name: Suzlon Rotor Corporation3) Small business? y/n? n 4) DQ Numbers (including all rolled) : 1580, 1825, 1907 5) Date of each Application Received: 6/26/07, 12/28/07, 2/14/08, 4/21/086) Final Permit No. 11700025-0017) Permit Staff Jessica Forsberg8) "Work completed" in which .xls file (i.e. unit 2b, unit 1a, biofuels)?

TotalApplication Type DQ No. Qty. Points Points DetailsAdministrative Amendment 1 0Minor Amendment 4 0Applicability Request 10 0Moderate Amendment 15 0Major Amendment 25 0Individual State Permit (not reissuance) 50 0Individual Part 70 Permit (not reissuance) 75 0

Additional PointsModeling Review 15 0

BACT Review 15 0LAER Review 15 0CAIR/Part 75 CEM analysis 10 0NSPS Review 10 0NESHAP Review 1580 2 10 20 PPPP, ZZZZCase-by-case MACT Review 20 0Netting 10 0Limits to remain below threshold 1580 1 10 10 PSDPlantwide Applicability Limit (PAL) 20 0Plantwide Applicability Limit (PAL) 20 0AERA review 15 0Variance request under 7000.7000 35 0Confidentiality request under 7000.1300 2 0EAW reviewPart 4410.4300, subparts 18, item A; and 29 15 0Part 4410.4300, subparts 8, items A & B; 10, items A to C; 16, items A & D; 17, items A to C & E to G; and 18, items B & C

35 0

Part 4410.4300, subparts 4; 5 items A & B; 13; 15; 16, items B & C; and 17 item D

70 0

Add'l Points 30

NOTES: NOTES: The 4/21/08 application was a resubmittal that included all previous applications and did not get assigned a DQ number. It is considered an upddate to DQ 1580.

(DQ DQ#)