TECHNICAL SUPPORT DOCUMENT For DRAFT AIR EMISSION …

Technical Support Document, Permit Action Number: 14500176 ‐ 002 Page 1 of 4

TECHNICAL SUPPORT DOCUMENT For

DRAFT AIR EMISSION PERMIT NO. 14500176‐002 This technical support document (TSD) is intended for all parties interested in the draft permit and to meet the requirements that have been set forth by the federal and state regulations (40 CFR § 70.7(a)(5) and Minn. R. 7007.0850, subp. 1). The purpose of this document is to provide the legal and factual justification for each applicable requirement or policy decision considered in the preliminary determination to issue the draft permit. 1. General Information 1.1 Applicant and Stationary Source Location:

Table 1. Applicant and Source Address

Applicant/Address Stationary Source/Address

(SIC Code: 2051)

Pan‐O‐Gold Baking Co. 444 St Germain St E St. Cloud, Minnesota 56304

Pan‐O‐Gold Baking Co.444 St Germain St E St. Cloud, Sherburne County, Minnesota 56304

Contact: Robert Gartland, VP of EngineeringPhone: 320‐247‐3001

1.2 Facility Description Pan‐O‐Gold Baking Company is a bakery facility that manufactures bread, buns, and other bakery products. Wheat and white flour are received at the facility and transferred to the mixing operations. Primary emissions at the facility are volatile organic compounds (VOC), which result from the fermentation of sugars while dough is “rising.” Existing facility consists of three baking lines with natural gas burners. VOC emissions from the facility are controlled using a Catalytic Oxidizer. Other emissions are from combustion of natural gas (primary fuel) in the baking ovens, air makeup units, and boilers. 1.3 Description of the Activities Allowed by this Permit Action This permit action is a mandatory reopening under Minn. R. 7007.1600, subp. 1(D). No construction is being authorized. On November 18, 2010, a performance test for VOC control efficiency was conducted while operating at a rate of 19,770 pounds per hour of baked goods produced with the catalytic oxidizer (CE 001) operating with an inlet temperature of 614 degrees Fahrenheit. The compliant result was 98.6%. The minimum temperature inlet for the catalytic oxidizer, which is a Title I Condition, was incorporated with this permit action; therefore, it is a major amendment under Minn. R. 7007.1500, subp. 1(C). Also, recurring stack testing for VOC control efficiency was added under GP 001. Worst case testing conditions and EPA Reference Methods required were added to the requirement. Other changes to the permit: ‐‐Corrected typos in citations. ‐‐Updated Total Facility general requirements boilerplate language. ‐‐Removed Initial Performance Test from GP 001 since it was completed. ‐‐Removed Notification of the Actual Date of Initial Startup from EU 005 since it has started up.


‐‐“CAAA of 1990” was added to all of the Title I Conditions. Per MPCA guidance, limits that resulted from injunctive relief are cited in this manner. ‐‐The requirement to vent emissions to control equipment was made its own requirement. ‐‐Daily recordkeeping/production logs were added. ‐‐The PM limit under GP 002 was changed from 0.4 lb/mmbtu to 0.40 lb/mmbtu. 1.4 Facility Emissions: Facility emissions do not change with this permit action; however, Greenhouse Gasses have become a regulated pollutant since the last permit action. The MPCA prepared calculations to determine if the facility’s status with respect to regulatory programs has changed as a result. These calculations can be found in Attachment 3 to this TSD and in the Central file of Delta. The PTE of Carbon Dioxide Equivalents is 26,018 tons per year which is less than the major source thresholds for PSD and the Part 70 Permit Program.

Table 2. Facility Classification Classification Major Synthetic Minor/Area Minor/Area

PSD X

Part 70 Permit Program X

Part 63 NESHAP X

2. Technical Information 2.1 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 considered the following:

the likelihood of the facility violating the applicable requirements;

whether add‐on controls are necessary to meet the emission limits;

the variability of emissions over time;

the type of monitoring, process, maintenance, or control equipment data already available for the emission unit;

the technical and economic feasibility of possible periodic monitoring methods; and

the kind of monitoring found on similar units elsewhere. The table below summarizes the monitoring requirements associated with this amendment.

Table 3. Monitoring Subject Item*

Requirement (rule basis) Monitoring Discussion


Subject Item*

Requirement (rule basis) Monitoring Discussion

GP 001 (Baking Lines and Direct Heating Equipment)

VOC ≤ 48.0 tons/year using Other Method. (Title I Condition: CAAA of 1990; To avoid classification as a major source and modification under 40 CFR Section 52.21 and Minn. R. 7007.3000; to avoid major source classification under 40 CFR Section 70.2 and Minn. R. 7007.0200)

Performance Test: due before end of each calendar 60 months starting 11/18/2010 to measure VOC emissions overall control efficiency from all three baking ovens at the facility.

Control efficiency of greater than 95% appears in the permit under CE 001. This efficiency along with the daily records of bread/buns baked is used in the accounting period calculations to ensure that the facility remains below the 48.0 tpy limit. The testing frequency of every 60 months is appropriate according to the MPCA Testing Frequency Guidance by the following rationale: ‐‐The test result was 98.6% control efficiency; ‐‐100% ‐ 98.6 % is 1.4%; ‐‐1.4% is 28% of 5%; and ‐‐28% is less than the 60% threshold for requiring a more frequent testing of every 36 months.

CE 001 (Catalytic Oxidizer)

Inlet Temperature ≥ 614 °F (Title I Condition: CAAA of 1990; To avoid classification as a major source and modification under 40 CFR Section 52.21 and Minn. R. 7007.3000; to avoid major source classification under 40 CFR Section 70.2 and Minn. R. 7007.0200; Minn. R. 7017.2025, subp. 3)

Continuous Temperature monitoring, Recordkeeping, O & M, inspections

Monitoring based on the Minnesota Performance Standard for Control Equipment is adequate to have a reasonable assurance of compliance.

*Location of the requirement in the permit (e.g., EU, SV, GP, etc.). 3. Comments Received

Public Notice Period: EPA 30‐day Review Period: 4. Permit Fee Assessment


Attachment 2 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 is a reopening which is not a chargeable activity. 5. Conclusion Based on the information provided by Pan‐O‐Gold Baking Co., the MPCA has reasonable assurance that the proposed operation of the emission facility, as described in the Air Emission Permit No. 14500176‐002 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 engineer)

David Crowell (enforcement) Ladislaus Strzok (compliance) Kelsey Suddard (peer reviewer) Beckie Olson (permit writing assistant) Laurie O’Brien (administrative support)

AQ File No. 4293; DQ 3377 Attachments: 1. Facility Description and CD‐01 Forms

2. Points Calculator 3. GHG Calculations

Attachment 1: 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 Records

PER 002

14500176

Pan-O-Gold Baking Co

FACILITY DESCRIPTION: GROUPS (GP)

6 October, 2014 08:20

ID No. AddedBy

(Action)

RetiredBy

(Action)

Includein EI

OperatorID

for Item

Group Description Group ItemsGroupStatus

1 GP 001 PER 001 Baking Lines and Direct Heating Equipment CE 001, EU 001, EU 003, EU 005, EU 011, SV 007Active

2 GP 002 PER 001 Indirect Heating Equipment EU 002, EU 004, EU 006, EU 007, EU 008, EU 009, EU 010Active

3 GP 003 PER 001 Combustion EmissionsActive

Page 1 of 1

ST. PAUL, MN 55155-4194

Show: Pending Records Only

Action: PER 002

AQD Facility ID: 14500176

Facility Name:

MINNESOTA POLLUTION CONTROL AGENCYAIR QUALITY520 LAFAYETTE ROAD

6 October, 2014 08:21

FACILITY DESCRIPTION: EMISSION UNIT (EU)

MaxFuelInput

(mil Btu)

Pan-O-Gold Baking Co

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 Bread Oven 1 - Dryer/Oven,unknown firing method

EU 001 Active PER 002 CE 001SV 001 (B)SV 007 (M)

Hr 2051Baker Perkins 970-48 6.75 Ton

5.942 Bread Oven 1 Burner -Dryer/Oven, direct fired


Hr 2051Baker Perkins Tri Zone Mmbtu

3 Bun Oven 2 - Dryer/Oven,unknown firing method


Hr 2051APV 970-33 3.75 Ton

5.774 Bun Oven 2 Burner -Dryer/Oven, direct fired


Hr 2051APV Tri Zone Mmbtu

5 Bread and Bun Oven 3 -Dryer/Oven, unknown firingmethod


Hr 2051Stewart Baking System 6.75 Ton

5.946 Bread and Bun Oven 3 Burner- Dryer/Oven, direct fired

EU 006 Active PER 002 CE 001SV 006 (P)SV 007 (M)

Hr 2051Stewart Baking System 2 Port Ribbon Burners Mmbtu

10.4617 Boiler # 1 - BoilerEU 007 Active PER 002 Hr 2051 Mmbtu

5.238 Boiler # 2 - BoilerEU 008 Active PER 002 Hr 2051 Mmbtu

6.29 Existing Air Makeup Units -Other Combustion

EU 009 Active PER 002 Hr 2051 Mmbtu

6.810 New Air Makeup Units - OtherCombustion

EU 010 Active PER 002 Hr 2051 Mmbtu

2.511 Control Equipment - OtherCombustion

EU 011 Active PER 002 CE 001SV 007 (M) Hr VOC 2051The CMM Group. LLC C-12000-70-M 150 Lb

Page 1 of 1 (a)

6 October, 2014 08:21

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 002 01/01/198301/01/1983Active

2 EU 002 PER 002 01/01/198301/01/1983Active

3 EU 003 PER 002 01/01/198901/01/1989Active

4 EU 004 PER 002 01/01/198901/01/1989Active

5 EU 005 PER 002Active


7 EU 007 PER 002 01/01/198301/01/1983Active

8 EU 008 PER 002 01/01/200501/01/2005Active

9 EU 009 PER 002 01/01/198301/01/1983Active

10 EU 010 PER 002 01/10/200601/02/2006Active


Page 1 of 1 (b)


Show: Active and Pending Records

Action: PER 002


Facility Name: Pan-O-Gold Baking Co

6 October, 2014 08:21

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 Up, No CapManufacturer15024001437EIS 001 Stack for EU 001Active




5 SV 005 Up, No CapEstimate16016001237EIS 001 Stack for EU 005Active

6 SV 006 Up, No CapEstimate16016001237EIS 001 Stack for EU 006Active

7 SV 007 Up, No CapManufacturer20011,0002.338PER 001 Stack for CE 001Active

Page 1 of 1


Show: Active and Pending Records

Action: PER 002



6 October, 2014 08:21

FACILITY DESCRIPTION: CONTROL EQUIPMENT (CE)

ID No. AddedBy

(Action)

RetiredBy

(Action)

OperatorID

for Item

Control

Equip.Type

Control Equipment Description ModelControlEquip.Status

Manufacturer PollutantsControlled

AfterburnerCombustionParameters

CaptureEfficiency

(%)

Destruction/CollectionEfficiency

(%)

1 CE 001 PER 001 109 Catalytic OxidizerActive VOC 100 95

Page 1 of 1

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


Permit Number: 14500176 - 002

6 Oct, 2014 08:21Page 1 of 8

Subject Item: Total Facility

NC/CA

Type Citation Requirement

CD hdr SOURCE-SPECIFIC REQUIREMENTS1.0

CD Minn. R. 7007.0800, subp. 2 Permit Appendix: This permit contains an appendix as listed in the permit Table ofContents. The Permittee shall comply with all requirements contained in theappendix.

2.0

CD 40 CFR pt. 82 The facility currently uses ozone-depleting substances as defined in 40 CFR pt. 82.Sections 601-618 of the 1990 Clean Air Act Amendments and 40 CFR pt. 82 mayapply to your facility. Read Sections 601-618 and 40 CFR pt. 82 to determine allthe requirements that apply to your facility.

3.0

CD hdr OPERATIONAL REQUIREMENTS4.0

CD Minn. Stat. Section 116.07, subds.4a & 9; Minn. R. 7007.0100, subp.7(A), 7(L), & 7(M); 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.

5.0

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.

6.0

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.

7.0

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.

8.0

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.

9.0

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.

10.0

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.

11.0

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).

12.0

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

13.0

CD hdr PERFORMANCE TESTING14.0

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.

15.0




6 Oct, 2014 08:21Page 2 of 8

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

Performance Test Notifications and Submittals:

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

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

The Notification, Test Plan, and Test Report may be submitted in an alternativeformat as allowed by Minn. R. 7017.2018.

16.0

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.

17.0

CD hdr MONITORING REQUIREMENTS18.0

CD Minn. R. 7007.0800, subp. 4(D) Monitoring Equipment Calibration - The Permittee shall either:

1. Calibrate or replace required monitoring equipment every 12 months; or2. Calibrate at the frequency stated in the manufacturer's specifications.

For each monitor, the Permittee shall maintain a record of all calibrations, includingthe date conducted, and any corrective action that resulted. The Permittee shallinclude the calibration frequencies, procedures, and manufacturer's specifications(if applicable) in the Operations and Maintenance Plan. Any requirements applyingto continuous emission monitors are listed separately in this permit.

19.0

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.

20.0

CD hdr RECORDKEEPING21.0

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

22.0

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.

23.0

CD Minn. R. 7007.1200, subp. 4 If the Permittee determines that no permit amendment or notification is requiredprior to making a change, the Permittee must retain records of all calculationsrequired under Minn. R. 7007.1200.For nonexpiring permits, these records shall bekept for a period of five years from the date that the change was made. The recordsshall be kept at the stationary source for the current calendar year of operation andmay be kept at the stationary source or office of the stationary source for all otheryears. The records may be maintained in either electronic or paper format.

24.0

CD hdr REPORTING/SUBMITTALS25.0




6 Oct, 2014 08:21Page 3 of 8

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, Band C of Minn. R. 7019.1000, subp. 3.

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

26.0

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.

27.0

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.

28.0

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 yetcorrected; and5. steps taken or planned to reduce, eliminate, and prevent reoccurrence of thedeviation.

29.0

S/A Minn. R. 7007.0800, subp. 6(A)(2) Semiannual Deviations Report: due 30 days after end of each calendar half-yearstarting 09/24/2008. The first semiannual report submitted by the Permittee shallcover the calendar half-year in which the permit 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 deviations have occurred, the Permittee shallsubmit the report stating no deviations.

30.0

CD Minn. R. 7007.1150 - 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.

31.0

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).Performance testing deadlines from the General Provisions of 40 CFR pt. 60 andpt. 63 are examples of deadlines for which the MPCA does not have authority togrant extensions and therefore do not meet the requirements of Minn. R.7007.1400, subp. 1(H).

32.0

S/A Minn. R. 7007.0800, subp. 6(C) Compliance Certification: due 31 days after end of each calendar year starting09/24/2008 (for the previous calendar year). The Permittee shall submit this to theCommissioner on a form approved by the Commissioner. This report covers alldeviations experienced during the calendar year.

33.0

CD Minn. R. 7019.3000 - 7019.3100 Emission Inventory Report: due on or before April 1 of each calendar year followingpermit issuance, to be submitted on a form approved by the Commissioner.

34.0

CD Minn. R. 7002.0005 - 7002.0095 Emission Fees: due 30 days after receipt of an MPCA bill.35.0




6 Oct, 2014 08:21Page 4 of 8

Subject Item: GP 001 Baking Lines and Direct Heating Equipment

Associated Items: CE 001 Catalytic Oxidizer

EU 001 Bread Oven 1 - Dryer/Oven, unknown firing method

EU 003 Bun Oven 2 - Dryer/Oven, unknown firing method

EU 005 Bread and Bun Oven 3 - Dryer/Oven, unknown firing method

EU 011 Control Equipment - Other Combustion

SV 007 Stack for CE 001

NC/CA


LIMIT Title I Condition: CAAA of 1990;To avoid classification as a majorsource and modification under 40CFR Section 52.21 & Minn. R.7007.3000; To avoid majorsource classification under 40CFR Section 70.2 and Minn. R.7007.0200

Volatile Organic Compounds: less than or equal to 48.0 tons/year using OtherMethod - based on a 13-accounting (4 week) period rolling sum as described laterin this permit. Limit of 48.0 tons applies only if using the Adjustment Factor of 1.6 orthe Limit of 34.0 tons per year without the 1.6 factor. Limit to be calculated usingoverall control efficiency (capture and control) of VOC emissions from all threebaking ovens at the facility.

1.0

CD Title I Condition: CAAA of 1990;To avoid major sourceclassification under 40 CFRSection 52.21 and Minn. R.7007.3000; to avoid major sourceclassification under 40 CFRSection 70.2 and Minn. R.7007.0200

The Permittee shall vent all vents from the baking lines to control equipmentmeeting the requirements of CE 001 at all times the baking lines are in operation.

2.0

LIMIT Minn. R. 7011.0610, subp. 1(A)(1) Total Particulate Matter: less than or equal to 0.3 grains/dry standard cubic foot ofexhaust gas unless required to further reduce emissions to comply with the lessstringent limit of either Minn. R. 7011.0730 or Minn. R. 7011. 0735.This limit applies to each emission unit individually in GP 001.

3.0

LIMIT Minn. R. 7011.0610, subp. 1(A)(2) Opacity: less than or equal to 20 percent opacity except for one six-minute periodper hour of not more than 60 percent opacity.This limit applies to each emission unit individually in GP 001.

4.0

CD Minn. R. 7005.0100, subp. 35a Fuel Type: Natural Gas only, by design.5.0

S/A Minn. R. 7017.2020, subp. 1 Performance Test: due before end of each calendar 60 months starting 11/18/2010to measure VOC emissions overall control efficiency from all three baking ovens atthe facility. Testing conducted during the two months prior to the performance testdue date satisfies the performance test due date, and will not reset the test duedate for future testing as required by: 1) this permit, 2) by the most recentlyapproved Performance Test Frequency Plan, or 3) if specified within a Notice ofCompliance letter. Testing conducted more than two months prior to theperformance test due date does not satisfy this test due date requirement and willbe considered an additional test. The performance test shall be conducted at worstcase conditions as defined at Minn. R. 7017.2005, subp. 8, using EPA ReferenceMethods 1-4 and Modified EPA Method 25/Modified EPA Method 18, or othermethod approved by MPCA in the performance test plan approval. The Permitteeshall operate all three ovens during the performance test.

CONTROL EQUIPMENT REQUIREMENTS - SEE CE 001

6.0

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

Performance Test Notifications and Submittals;

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 day before each Performance TestPerformance Test Report: due 45 days after each Performance TestPerformance Test Report - Microfiche Copy or CD: due 105 day after eachPerformance Test.The Notification, Test Plan, and Test Report may be submitted in alternate formatas allowed by Minn. R. 7017.2018.

7.0




6 Oct, 2014 08:21Page 5 of 8

CD Title I Condition: CAAA of 1990;To avoid major sourceclassification under 40 CFRSection 52.21 and Minn. R.7007.3000; to avoid major sourceclassification under 40 CFRSection 70.2 and Minn. R.7007.0200

The Permittee shall maintain daily records or production logs of the amount ofbread/buns baked and the type of bread/buns baked.

8.0

CD Title I Condition: CAAA of 1990;To avoid classification as a majorsource and modification under 40CFR Section 52.21 & Minn. R.7007.3000; To avoid majorsource classification under 40CFR Section 70.2 and Minn. R.7007.0200

Accounting Period Recordkeeping -- VOC Emissions: By the 15th day of eachaccounting period, the Permittee shall calculate and record the following:1. The total VOC emissions for the previous accounting period using daily records(or production logs) of VOC containing materials processed at the facility (eachproduct type and amount of bread/buns baked), applying overall control efficiencyof the control equipment, and the AP-42 equation shown below.2. The 13-accounting period rolling sum VOC emissions for the previous 13accounting periods by summing the 4-week VOC emissions data for the previousperiods.

Definition of Accounting Period: The VOC emission limit is based on 13 accountingperiods in a calendar year. The starting and ending dates of each accountingperiod (4 weeks) shall be included in the Annual Report that is due January 30th ofeach year.

9.0

CD Title I Condition: CAAA of 1990;To avoid classification as a majorsource and modification under 40CFR Section 52.21 & Minn. R.7007.3000; To avoid major sourceclassification under 40 CFRSection 70.2 and Minn. R.7007.0200; Minn. R. 7007. 0800.subp. 4-5

VOC Emission Calculation:

VOC Emissions in pounds = EF * tons of bread baked * (100 - Percent Efficiency)

VOC Emissions in tons = VOC Emissions in pounds * 1/2000

EF = Maximum VOC emission factor, pounds VOC/ton bread bakedUsing equation specified in AP-42, shown below

VOC EF = (0.95Yi+0.195ti-0.51S-0.86ts+1.90)

Yi = initial baker's percent of yeastti = total yeast action time in hoursS = final (spike) baker's percent of yeastts = spiking time in hoursAdjustment factor = 1.6 (only if applicable)Percent Efficiency = Catalytic Oxidizer Overall Control efficiency, based on captureand control from the most recent performance test

10.0

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).

11.0




6 Oct, 2014 08:21Page 6 of 8

Subject Item: GP 002 Indirect Heating Equipment

Associated Items: EU 002 Bread Oven 1 Burner - Dryer/Oven, direct fired

EU 004 Bun Oven 2 Burner - Dryer/Oven, direct fired

EU 006 Bread and Bun Oven 3 Burner - Dryer/Oven, direct fired

EU 007 Boiler # 1 - Boiler

EU 008 Boiler # 2 - Boiler

EU 009 Existing Air Makeup Units - Other Combustion

EU 010 New Air Makeup Units - Other Combustion

NC/CA


LIMIT Minn. R. 7011.0515, subp. 1 Total Particulate Matter: less than or equal to 0.40 lbs/million Btu heat input .Design based PTE for each unit, using AP-42, is 0.0072 compared to the rule limitof 0.4 lb/MMBtu.This limit applies to each emission unit individually in GP 002.

1.0

LIMIT Minn. R. 7011.0515, subp. 2 Opacity: less than or equal to 20 percent opacity except for one six-minute periodper hour of not more than 60 percent opacity.This limit applies to each emission unit individually in GP 002.

2.0

CD Minn. R. 7005.0100, subp. 35a Fuel Type: Natural Gas only, by design.3.0




6 Oct, 2014 08:21Page 7 of 8

Subject Item: CE 001 Catalytic Oxidizer

Associated Items: EU 001 Bread Oven 1 - Dryer/Oven, unknown firing method

EU 002 Bread Oven 1 Burner - Dryer/Oven, direct fired

EU 003 Bun Oven 2 - Dryer/Oven, unknown firing method

EU 004 Bun Oven 2 Burner - Dryer/Oven, direct fired

EU 005 Bread and Bun Oven 3 - Dryer/Oven, unknown firing method

EU 006 Bread and Bun Oven 3 Burner - Dryer/Oven, direct fired

EU 011 Control Equipment - Other Combustion

GP 001 Baking Lines and Direct Heating Equipment

NC/CA


LIMIT Title I Condition: CAAA of 1990;To avoid classification as a majorsource and modification under 40CFR Section 52.21 & Minn. R.7007.3000; to avoid major sourceclassification under 40 CFRSection 70.2 and Minn. R.7007.0200; Minn. R. 7011.0070,subp. 1

The Permittee shall operate and maintain the control equipment such that itachieves an overall control efficiency for Volatile Organic Compounds: greater thanor equal to 95 percent control efficiency

1.0

LIMIT Title I Condition: CAAA of 1990;To avoid classification as a majorsource and modification under 40CFR Section 52.21 and Minn. R.7007.3000; To avoid classificationas a major source under 40 CFRSection 70.2 and Minn. R.7007.0200; Minn. R. 7011.0080;Minn. R. 7017.2025, subp. 3

Temperature: greater than or equal to 614 degrees F using 3-hour Rolling Averageat the oxidizer inlet as determined during the Initial performance test, unless a newlimit is set pursuant to Minn. R. 7017.2025, subp. 3 based on the values recordedduring the most recent MPCA-approved performance test where compliance wasdemonstrated. The new limit shall be implemented upon receipt of the Notice ofCompliance letter granting preliminary approval. The limit is final upon issuance ofa permit amendment incorporating the change. If the 3-hour rolling averagetemperature is below the minimum temperature limit, the VOC used during thattime shall be considered uncontrolled until the average temperature is above theminimum temperature limit. This shall be reported as a deviation.

The Performance Testing Requirement is under GP 001.

2.0

CD Title I Condition: CAAA of 1990;To avoid classification as a majorsource and modification under 40CFR Section 52.21 and Minn. R.7007.3000; To avoid classificationas a major source under 40 CFRSection 70.2 and Minn. R.7007.0200; Minn. R. 7011.0065,subp. 2(A)

The control equipment is considered listed control equipment under Minn. R.7011.0060 to 7011.0080. The Permittee shall operate and maintain the catalyticoxidizer at all times that any process equipment controlled by the catalytic oxidizeris operating. The Permittee shall document periods of non-operation of the controlequipment.

3.0

CD Title I Condition: CAAA of 1990;To avoid classification as a majorsource and modification under 40CFR Section 52.21 and Minn. R.7007.3000; To avoid classificationas a major source under 40 CFRSection 70.2 and Minn. R.7007.0200; Minn. R. 7011.0080

Catalyst Reactivity: The Permittee shall verify the catalyst reactivity per themanufacturer's specifications or every 12-months, and shall maintain a record ofthe results. The Permittee shall maintain a copy of the manufacturer'sspecifications/operation and maintenance manual on-site.

The Permittee shall send a representative sample of the catalyst to a laboratory totest the catalyst's destruction efficiency. If test results show a destruction efficiencyof less than 95%, the Permittee shall follow the corrective actions contained in theOperation and Maintenance Plan.

4.0

CD Title I Condition: CAAA of 1990;To avoid classification as a majorsource and modification under 40CFR Section 52.21 and Minn. R.7007.3000; To avoid classificationas a major source under 40 CFRSection 70.2 and Minn. R.7007.0200; Minn. R. 7011.0080

The Permittee shall maintain either a continuous hard copy or electronic readout ofthe inlet and outlet temperatures and the calculated three-hour rolling average inlettemperature, or maintain a hard copy of manual readings taken at least every 15minutes.

5.0




6 Oct, 2014 08:21Page 8 of 8

CD Minn. R. 7011.0075, subp. 3 Monitoring Equipment: The Permittee shall install and maintain thermocouples formeasuring and recording the temperature as required by this permit. Themonitoring equipment must be installed, in use, and properly maintained whenoperation of the monitored control equipment is required.

6.0

CD Title I Condition: CAAA of 1990;To avoid classification as a majorsource and modification under 40CFR Section 52.21 and Minn. R.7007.3000; To avoid classificationas a major source under 40 CFRSection 70.2 and Minn. R.7007.0200; Minn. R. 7011.0070,subp. 2

For periods when the catalytic oxidizer is operated above the minimum inlettemperature, the Permittee shall use one of the following when completingcalculations as required elsewhere in this permit:a. The overall control efficiency limit specified in this permit for this equipment(95%);b. If the Permittee chooses to use an alternative control efficiency as allowed inMinn. R. 7011.0070, subp. 2, that new alternative control efficiency; orc. The overall control efficiency determined during the most recent MPCA approvedperformance test. If the tested efficiency is less than the efficiency limit in thispermit, the Permittee must use the tested value in all calculations until theefficiency is demonstrated to be above the permit limit through a new test.

7.0

CD Minn. R. 7011.0075, subp. 2 The Permittee shall maintain each piece of control equipment according to themanufacturer's specification, shall conduct inspections, and maintaindocumentation of those actions as required by Minn. R. 7011.0075, subp. 2(A) to2(I).

8.0

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

Corrective Actions: If the temperature is below the minimum specified by this permitor if the catalytic oxidizer or any of its components are found during the inspectionsto need repair, the Permittee shall take corrective action as soon as possible.Corrective actions shall return the temperature to at least the permitted minimumand/or include completion of necessary repairs identified during the inspection, asapplicable. Corrective actions include, but are not limited to, those outlined in the O& M Plan for the catalytic oxidizer. The Permittee shall keep a record of the typeand date of any corrective action taken.

9.0

Attachment 2: Points Calculator

Points Calculator

1) AQ Facility ID No.: 14500176 Total Points 02) Facility Name: Pan-O-Gold Baking Co.3) Small business? y/n? n 4) DQ Numbers (including all rolled) : 4293 5) Date of each Application Received: 1/27/116) Final Permit No. 14500176-0027) 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 10 0Case-by-case MACT Review 20 0Netting 10 0Limits to remain below threshold 10 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 0

NOTES:

Reopening-Not a chargeable activity.

(DQ DQ# 3377)

Attachment 3: GHG Calculations

Emission Unit Description MMBtu/hr CO2 lb/mmBtu CH4 lb/mmBtu N2O lb/mmBtu lb/hr CO2*GWP lb/hr CH4* GWP lb/hr N2O*GWP tpy total

EU 002 Bread Oven Burner 5.94 116.89 0.0022 0.00022 694.3266 27.717228 0.405108 3164.32634

EU 004 Bun Oven Burner 5.77 116.89 0.0022 0.00022 674.4553 26.923974 0.393514 3073.764811

EU 006 Bread and Bun Oven Burner 5.94 116.89 0.0022 0.00022 694.3266 27.717228 0.405108 3164.32634

EU 007 Boiler #1 10.461 116.89 0.0022 0.00022 1222.78629 48.8131182 0.7134402 5572.730276

EU 008 Boiler #2 5.23 116.89 0.0022 0.00022 611.3347 24.404226 0.356686 2786.098781

EU 009 Air Makeup Unit 6.2 116.89 0.0022 0.00022 724.718 28.93044 0.42284 3302.832206

EU 010 Air Makeup Unit 6.8 116.89 0.0022 0.00022 794.852 31.73016 0.46376 3622.46113

EU 011 Catalytic Oxidizer 2.5 116.89 0.0022 0.00022 292.225 11.6655 0.1705 1331.78718

GWPs GHG Total tpy 26018.32706

CO2 = 1

CH4 = 21

N2O = 310

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