# Minnesota Pollution Control Agency

520 Lafayette Road North 

### I St. Paul, MN 55155-4194 

### I 651-296-6300 

### I 800-657-3864 

### I 651-282-5332 TTY 

### I www.pca.state.mn.us



### May 7, 2010

Ms. Susan Hedman Regional Administrator (R-19J) U.S. Environmental Protection Agency Region V 77 West Jackson Boulevard Chicago, Illinois 60604 

## RE C'E.\\f'E.O

## \JI~ ,

## 11~\~

RE: Proposed Amendments to Minnesota's State Implementation Plan for Particulate Matter and Sulfur Dioxide

Dear Ms. Hedman:

The Minnesota Pollution Control Agency (MPCA) hereby submits to the U.S. Environmental Protection Agency (EPA) two requests for revision of Minnesota's State Implementation Plan (SIP).

The first revision concerns the Metropolitan Wastewater Treatment Plant, part of Minnesota's SIP for particulate matter (PM IO ) 

### in Ramsey County. Minnesota's SIP currently includes Title I SIP conditions from ajoint document issued to the facility, Air Emission Permit No. 12300053-001. The MPCA hereby submits Air Emission Permit No. 12300053-006 as ajoint document and requests that the conditions labeled "Title I Condition: SIP for PM IO " 

### replace the current SIP conditions for the facility.

The second revision concerns the United Defense facility, part of Minnesota's SIP for sulfur dioxide (S02) in the Twin Cities. Minnesota's SIP currently includes Title I SIP conditions from the joint document issued to the facility, Air Emission Permit No. 00300020-00 I. The MPCA hereby submits Air Emission Permit No. 00300245-001, reflecting changed ownership of the facility, as a joint document and requests that those conditions labeled "Title I Condition: SIP for S02" replace the Title I SIP conditions from Air Emission Permit No. 00300020-00 I.

This submittal includes copies of the joint documents issued to each facility and supporting technical documentation. A full electronic copy of all the enclosed materials comprising this SIP submittal is included on the accompanying compact discs.

Please contact Catherine Neuschler, of our staff, at 651-757-2607, if you have any questions regarding this submittal.

Sincerely,

# ~~~~ Commissioner

PE/CN:km

Enclosures

cc: Kathleen D' Agostino, EPA Region V (with enclosures)

St. Paul 

### I Brainerd 

### I Detroit Lakes 

### I Duluth 

### I Mankato 

### I Marshall 

### I Rochester 

### I Willmar 

### I Printed on 100% post-consumer recycled paper

### 1 Background Information for SIP Revision ELT Minneapolis – River Road Industr ial Facility, Fridley, Minnesota

This document provides background information on the submittal of Air Emission Permit No. 00300245-001 as the State Implementation Plan (SIP) enforceable document for the ELT Minneapolis – River Road Indus trial Facility (ELT) at 4800 Ri ver Road in Fridley, Anoka County, Minnesota. This facili ty is included in Minnesota’s SIP for sulfur dioxide (SO 2 

### ).

Reasons for Changes and Placing Applicable Conditions into Joint Title I/FESOP Document

ELT owns and operates boilers and emergency ge nerators. These were part of a purchase agreement dated November 22, 2005, between BAE Systems Land and Armaments (formerly United Defense, LP), Inc and ELT.

Minnesota’s SO 2 

### SIP for the Twin Cities area currently in cludes Title I SIP conditions for these boilers and generators. Thos e Title I SIP conditions are f ound in Air Emission Permit No. 00300020-003, issued to United Defense, LP in November 2002. In August 2004, EPA published a direct final notice a pproving the Title I SIP conditions into Minnesota’s SIP (69 FR 51181).

However, EPA’s notice describes the incorporat ed joint document as Air Emission Permit No. 00300020-001. It appears that the cover page to the incorporated join t document listed the permit with this number, although the MPCA’s pe rmit tracking system and the remaining pages in the joint document list the document as Air Emission Permit 00300020-003.

This SIP revision serves to generally update the facility in the SIP. First, it serves to resolve the issue of which joint document is included in the SIP, ensuring that the correctly numbered permit is incorporated into the SIP as the joint documen t. It also accounts for the change in ownership of the facility, and some changes in how the em issions units and groups are described. Boilers 1, 2, and 3 were listed in the joint document i ssued to United Defense as EU001, EU002, and EU003 and associated with the stacks SV026 and SV027 under GP002. These are now grouped under GP001, with the stacks numbered SV001 and SV 002. Similar changes were made for the emergency generators. The changes ar e further described in Attachment 4.

Finally, the incorporation of th e current joint document includes several Title I conditions that are not related to the SIP. With this SIP revi sion, the MPCA is request ing that these conditions be removed. Many of these non-SIP Title I conditions relate to emission units that are not owned by ELT.

This revision does not involve any substantiv e changes to the SIP conditions. All fuel restrictions and SO 2 

### emission limits that apply to the boi lers and emergency generators remain the same as those currently approved into the SI P. Some changes to the SIP conditions were made in order to be consistent with the MPCA’s current practices for joint documents, but these changes are administrative and provide detail clar ifying for the facility when SIP revisions are required.

### 2 No new authorizations are pa rt of this SIP revision, a nd no modeling was conducted as no emission limits or stack parameters have changed.

The MPCA requests that EPA include the Title I SIP conditions from Air Emission Permit No. 00300245-001, issued to ELT and serving as a joint doc ument, into Minnesota’s SIP to replace the Title I conditions from Air Emission Permit No. 00300020-001.

Attachments to Background Document
Attachment 1: Permit No. 00300245-001; joint Title I/FESOP document Attachment 2: Permit technical support document Attachment 3: Permit No. 00300245-001; Title I SIP conditions only Attachment 4: Marked up United Defense currently approved joint document
Attachment 5: Public notice Attachment 6: Completeness Review

This summary was prepared by Catherine Neus chler, Environmental Analysis and Outcomes Division of the MPCA.

### Attachment 1: Permit No. 00300245-001; joint Title I/FESOP document

### Am EMISSION PERMIT 

### NO.**0030~Z45-** 

### 001 Total Facility Operating Permit

IS ISSUED TO

,EL T Minneapolis LLC

RIVER ROAD INDUSTRIAL CENTER 4800-4898 East River Road Fridley, Anoka County, MN 55421

The emission units, control equipment and emission stacks at the stationary source authorized in this

, permit are as described in the Permit Applications Table.

This permit, Air Emission Permit No.00300245-001, authorizes the Permittee to operate the stationary

source at the address listed abQve unless otherwise noted in Table A: The Permittee t:J1ust coinply with all the conditions of the permit. Any changes or modifications to the stationary source must be performed in

,compliance with Minn. R. 7007 r.l150 to 7007.1500. Any additions or changes to conditions incorporated into Minnesota's State Implementation Plan (SIP) under 40 CFR § 52.1220, designated "Title I: SIP for sulfur dioxide 

### (S02) must go through the federal SlP approval process before becoming 'effective. Terms' used in the permit are as defined in, the state air po))ution control rules unless the term is exp.Hcitly defined in the permit.

Unless otherwise indicated, an the Minnesota rules cited as the origin of the permit terms are ,

, incorporated into the SW under 40 CFR § 52. 122(), and as such as are enforceable by U.S. Environmerital Protection Agency (EPA) Administtatoror citizens under the Clean Air Act. '

, .

. Permit Type: State; Limits t9 Avoid 

### Pt 70/Limits to Avoid NS'R; Title} SIP Conditions 

### (80 2 ) Operating Permit Issue: Date: 

### 'April'S,**20~O** 

### '
Expiration Date: Non-Expiring

- All Title I Conditions do not expire.

.. ," . Each neW or revised condition designated Title I Condition: SIP for S02 is not-effective or enforceable until approved by EPA 'as a SIP revision under Title I of the Clean Air Act. '

....... .

.....

. ' .'

.

,

# ~?''-;'''-I¥~:::lJ~f-''-'-' ------- 

# Jr,,' nager........ Air QualityPeimits Section Industrial Division

" for Paul Eger

, Commissioner

Minnesota Pollution Control Agency', '.

"TDD (for hearing and speech impaired only): (651)282-5332 Printed on recycled paper containing at least 10'% fibers from paper recycled by consumers

### Permit Applications Table

Permit Type Application Date Permit Action
Total Facility Operating Permit July 17, 2007 Revised: June 24, 2010 001

### TABLE OF CONTENTS

Notice to the Permittee

Permit Shield

Facility Description

Table A: Limits and Other Requirements

Table B: Submittals

Appendices:

Appendix I: Insignificant Activities and General Applicable Requirements

Appendix II: Title I Condition: SIP for Sulfur Dioxide (SO 2 

### ) Modeling Parameters Relied Upon to Demonstrate Compliance with NAAQS

### 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 pr ovision 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:

ELT Minneapolis, LLC owns and operates boilers and emergency generators in the city of Fridley, which was part of the purchase agreement dated November 22, 2005, between BAE Systems Land and Armaments (formerly United Defense, LP), Inc and ELT Minneapolis, LLC (ELT). The company is a heat and steam distributor. The boilers and emergency generators were permitted under Air Emission Permit No. 00300020-001. The Minnesota Pollution Control Agency (MPCA) received their permit application on July 17, 2007. ELT did not submit any information that was claimed to be confidential verbally or in written correspondence.

This permit is a Joint Title I/Title V Federally Enforceable State Operating Permit, as it includes non-expiring Title I Conditions to implement the State Implementation Plan (SIP), pursuant to 40 CFR pt. 50, 40 CFR pt. 51, 40 CFR § 

### 52.1220, Minn. R. 7007.0100, subp. 25B, and Minn. R. 7007.1050, subp. 4.

The facility is part of the SIP to reach attainment of SO 2 

### National Ambient Air Quality Standards (NAAQS) in Twin Cities 7-County Area. This permit will be resubmitted to EPA for inclusion into the SIP, and will replace United Defense, LP (formerly FMC/U.S.Navy) Air Emission Permit No. 00300020-001, which was State effective November 25, 2002, and EPA approved August 18, 2004, registered in the Federal Register No. 51181, as Title I Conditions only.

The main sources of potential emissions are SO 2 

### and nitrogen oxides (NOx). The permit limits the emissions of the facility such that the f acility is classified as a non-major source under federal Operating Program (40 CFR pt. 70) and non-major under federal New Source Review regulations (40 CFR § 52.21). The facility is an area source under federal National Emission Standards for Hazardous Air Pollutants (40 CFR pt. 63).TABLE A: LIMITS AND OTHER REQUIREMENTS 04/08/10

River Road Industrial Center

00300245 - 001 Facility Name:

Permit Number: A-1

Table A contains limits and other requirements with which your facility must comply. The limits are located in the first colum n of the table (What To do). The limits can be emission limits or operational limits. This column also contains the actions that y ou must take 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 tota l facility requirements.

Subject Item: Total Facility

What to do Why to do it
SOURCE-SPECIFIC REQUIREMENTS hdr

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

STATE IMPLEMENTATION PLAN (SIP) REQUIREMENTS hdr

A CTIVITIES NOT REQUIRING A MODIFICATION TO THE SIP: The Permittee is authorized to make changes to the facility without obtaining a modification to the SIP as long as the change does not do or result in any of the following: 1. An exceedance of the limitations at which sulfur dioxide is emitted from any emission unit at the facility; 2. A physical change of the equipment that affects the stack parameters described in Appendix II; and 3. Any construction or modification of building structures greater than 56 feet above grade elevation if within 280 feet of Emission Units 1, 2 or 3. Title I Condition: State Implementation Plan (SIP) for SO2 NAAQS; 40 CFR pt. 50; 40 CFR pt. 51; 40 CFR pt. 52, subp. Y; MN SIP

A CTIVITIES REQUIRING A MODIFICATION TO THE SIP: A ctivities requiring a modification of the SIP prior to the Permittee commencing the activity include, but are not limited to, the following: 1. Any decrease in the design and/or maximum stack gas volumetric flow rate below that contained in Appendix II; 2. Any decrease in the design and/or maximum stack gas exit temperature below that contained in Appendix II; 3. Any reduction in stack height below that contained in Appendix II; 4. Any increase in stack exit diameter above that contained in Appendix II; and 5. Any construction or modification of structures that increase the effective structural dimensions. Title I Condition: State Implementation Plan (SIP) for SO2 NAAQS; 40 CFR pt. 50; 40 CFR pt. 51; 40 CFR pt. 52, subp. Y; MN SIP

Construction and Operation of SIP Emission Unit: The Permittee may begin actual construction of a new emission unit or modification to existing emission unit upon permit issuance. However, the Permittee shall not operate any new emission unit or modified emission unit until any required SIP amendment is approved by US EPA. Title I Condition: State Implementation Plan (SIP) for SO2 NAAQS; 40 CFR pt. 50; 40 CFR pt. 51; 40 CFR pt. 52, subp. Y; MN SIP

General Operating and Maintenance Requirements for the SIP: The owner or operator shall operate and maintain the process equipment described in Appendix II according to the parameters set forth in Appendix II. The parameters were used in the computer modeling performed to demonstrate that the SO2 maintenance area will attain compliance with the SO2 NAAQS. Title I Condition: State Implementation Plan (SIP) for SO2 NAAQS; 40 CFR pt. 50; 40 CFR pt. 51; 40 CFR pt. 52, subp. Y; MN SIP

Non-Permanent Records for SIP: The Permittee shall retain all records at the facility for a minimum of six years following the date of the required monitoring, sample, measurement, or report that corresponds with the SIP Title I Condition. All required documents, records, reports and plans in a form suitable for determination of the facility's compliance with the SIP by EPA or MPCA staff. The Permittee shall maintain the information at the facility in files which are easily accessible of inspections by EPA or MPCA staff, and are available for inspection. Title I Condition: State Implementation Plan (SIP) for SO2 NAAQS; 40 CFR pt. 50; 40 CFR pt. 51; 40 CFR pt. 52, subp. Y; MN SIP

Reporting: The Permittee may undertake certain changes to the facility without obtaining a modification to the SIP. However, if the Permittee does make a change, and if the change in any way affects SO2 emissions, the Permittee shall notify the Commissioner in writing at least 30 days prior to undertaking the change. The notification shall describe the change and why it does not require a modification to the SIP. Title I Condition: State Implementation Plan (SIP) for SO2 NAAQS; 40 CFR pt. 50; 40 CFR pt. 51; 40 CFR pt. 52, subp. Y; MN SIP

A nnual Report for SIP: due 30 days after end of each calendar year following Permit Issuance to the Commissioner. The report shall contain the following information: a record of data used in calculating SO2 emissions, and calculations of the SO2 emissions; a record of each unscheduled startup, shutdown, and breakdown of process equipment; a summary record of excess SO2 emissions (or the Permittee shall state if no exceedances, and noncompliance conditions occurred in the calendar year). Title I Condition: State Implementation Plan (SIP) for SO2 NAAQS; 40 CFR pt. 50; 40 CFR pt. 51; 40 CFR pt. 52, subp. Y; MN SIP

TOTAL FACILITY EMISSION LIMITS AND RECORDKEEPING hdrTABLE A: LIMITS AND OTHER REQUIREMENTS 04/08/10

River Road Industrial Center

00300245 - 001 Facility Name:

Permit Number: A-2

This permit establishes limits on the facility to keep it a minor source under 40 CFR Section 70.2. The Permittee cannot make any change at the source that would make the source a major source under 40 CFR Section 70.2 until a permit amendment has been issued. This includes changes that might otherwise qualify as insignificant modifications and minor or moderate amendments. Title I Condition: To avoid major source classification under 40 CFR Section 70.2, Minn. R. 7007.0200

Nitrogen Oxides: less than or equal to 90 tons/year using 12-month Rolling Sum to be calculated by the 28th day of each month for the previous 12-month period. Title I Condition: To avoid major source classification under 40 CFR Section 70.2, Minn. R. 7007.0200 Recordkeeping for NOx Emissions: The Permittee shall calculate and maintain records of NOx emissions using the following equation:

NOx total = NOx natural gas + NOx distillate fuel oil

The Permittee shall use the most recent EPA AP-42 emission factors or other MPCA approved emission factors. Title I Condition: To avoid major source classification under 40 CFR Section 70.2, Minn. R. 7007.0200

OPERATIONAL REQUIREMENTS hdr

The Permittee shall comply with National Primary and Secondary Ambient Air Quality Standards, 40 CFR pt. 50, and the Minnesota Ambient Air Quality Standards, Minn. R. 7009.0010 to 7009.0080. Compliance shall be demonstrated upon written request by the MPCA. 40 CFR pt. 50; 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
Circumvention: Do not install or use a device or means that conceals or dilutes emissions, which would otherwise violate a federal or state air pollution control rule, without reducing the total amount of pollutant emitted. Minn. R. 7011.0020

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

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

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

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

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

PERFORMANCE TESTING hdr

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

Performance Test Notifications and Submittals:

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

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

The Notification, Test Plan, and Test Report may be submitted in alternative format as allowed by Minn. R. 7017.2018. Minn. R. 7017.2018; Minn. R. 7017.2030, subps. 1-4, Minn. R. 7017.2035, subps. 1-2

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

MONITORING REQUIREMENTS hdr

Monitoring Equipment Calibration: The Permittee shall calibrate all required monitoring equipment at least once every 12 months (any requirements applying to continuous emission monitors are listed separately in this permit). Minn. R. 7007.0800, subp. 4(D)TABLE A: LIMITS AND OTHER REQUIREMENTS 04/08/10

River Road Industrial Center

00300245 - 001 Facility Name:

Permit Number: A-3

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

RECORDKEEPING hdr

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

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

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

REPORTING/SUBMITTALS hdr

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

A t the time of notification, the owner or operator shall inform the Commissioner of the cause of the shutdown and the estimated duration. The owner or operator shall notify the Commissioner when the shutdown is over. Minn. R. 7019.1000, subp. 3

Breakdown Notifications: Notify the Commissioner within 24 hours of a breakdown of more than one hour duration of any control equipment or process equipment if the breakdown causes any increase in the emissions of any regulated air pollutant. The 24-hour time period starts when the breakdown was discovered or reasonably should have been discovered by the owner or operator. However, notification is not required in the circumstances outlined in Items A, B and C of Minn. R. 7019.1000, subp. 2.

A t the time of notification or as soon as possible thereafter, the owner or operator shall inform the Commissioner of the cause of the breakdown and the estimated duration. The owner or operator shall notify the Commissioner when the breakdown is over. Minn. R. 7019.1000, subp. 2

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

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

A pplication for Permit Amendment: If a permit amendment is needed, submit an application in accordance with the requirements of Minn. R. 7007.1150 through Minn. R. 7007.1500. Submittal dates vary, depending on the type of amendment needed. Minn. R. 7007.1150 - 7007.1500TABLE A: LIMITS AND OTHER REQUIREMENTS 04/08/10

River Road Industrial Center

00300245 - 001 Facility Name:

Permit Number: A-4

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

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

Emission Fees: due 60 days after receipt of an MPCA bill. Minn. R. 7002.0005 - 7002.0095TABLE A: LIMITS AND OTHER REQUIREMENTS 04/08/10

River Road Industrial Center

00300245 - 001 Facility Name:

Permit Number: A-5

Subject Item: GP 001 Boilers Subject to SIP and NSPS

Associated Items: EU 001 Boiler 1

EU 002 Boiler 2

EU 003 Boiler 3 (81098)

SV 001 Boiler 1

SV 002 Boiler 2 and 3

What to do Why to do it The limits below apply to each boiler separately listed in GP 001. hdr

EMISSION LIMIT hdr

Opacity: less than or equal to 20 percent opacity (6-minute average), except for one 6-minute period per hour of not more than 27 percent opacity. This limit becomes effective on and after the dates January 7, 13 and 20-21, 1994, for boilers 1, 2,and 3 respectively.

The opacity standard applies at all times, except during periods of startup, shutdown, or malfunction. 40 CFR Section 60.43c(c) and (d); Minn. R. 7011.0570

OTHER LIMITS AND REQUIREMENTS hdr

Sulfur Content of Fuel: less than or equal to 0.05 percent by weight of No. 2 fuel oil. (This limit is more stringent than the NSPS limit.) Title I Condition: State Implementation Plan (SIP) for SO2 NAAQS, 40 CFR pt. 50; 40 CFR pt. 51; 40 CFR pt. 52, subp. Y; MN SIP Sulfur Content of Fuel: less than or equal to 0.05 percent by weight of No. 2 fuel oil. Title I Condition: To avoid classification as major source and modification under 40 CFR Section 52.21, Minn. R. 7007.3000; To avoid major source classification under 40 CFR Section 70.2, Minn. R. 7007.0200 Sulfur Content of Fuel: less than or equal to 0.5 percent by weight or 0.50 lb/mmBtu 40 CFR Section 60.42c(d); Minn. R. 7011.0570

The SO2 emission limits, fuel oil sulfur limits, and percent reduction requirements under 40 CFR Section 60.42c apply at all times, including periods of startup, shutdown, and malfunction. 40 CFR Section 60.42c(i); Minn. R. 7011.0570

MONITORING AND RECORDKEEPING REQUIREMENTS hdr

Fuel Supplier Certification: The Permittee shall obtain and maintain written fuel supplier certification from the fuel supplier for each shipment of distillate fuel oil delivered to the facility. Each fuel certification shall include the following information: the name of the fuel oil supplier; the sulfur content of the fuel oil; and method used to determine the sulfur content of the fuel oil. Title I Condition: State Implementation Plan (SIP) for SO2 NAAQS, 40 CFR pt. 50; 40 CFR pt. 51; 40 CFR pt. 52, subp. Y; MN SIP

Fuel Supplier Certification: The Permittee shall determine compliance with the fuel oil sulfur limits based on a certification from the fuel supplier. 40 CFR Section 60.42c(h)(1); Minn. R. 7011.0570

Fuel Supplier Certification Requirements: The certification shall include the following information for distillate fuel oil: 1. The name of the oil supplier; 2. A statement from the oil supplier that the oil complies with the specifications under the definition of distillate oil in 40 CFR Section 60.41c; and 3. The sulfur content of the oil. This certification shall be obtained for each delivery of distillate fuel oil. 40 CFR Section 60.48c(f)(1); Minn. R. 7011.0570

Fuel Restriction: The Permittee is authorized to burn natural gas and distillate fuel oil only. Title I Condition: State Implementation Plan (SIP) for SO2 NAAQS, 40 CFR pt. 50; 40 CFR pt. 51; 40 CFR pt. 52, subp. Y; MN SIP The Permittee shall keep records of fuel type and usage on a monthly basis for these units by the 28th day of each month. Minn. R. 7007.0800, subp. 5

Opacity Compliance: Demonstrate compliance with opacity standards using Reference Method 9. 40 CFR Section 60.11; Minn. R. 7017.2015TABLE A: LIMITS AND OTHER REQUIREMENTS 04/08/10

River Road Industrial Center

00300245 - 001 Facility Name:

Permit Number: A-6

Subject Item: GP 002 Standby Generators

Associated Items: EU 005 Standby Generator-Sub 3(W)

EU 006 Standby Generator-Sub 3(E)

EU 007 Standby Generator-Sub 1

EU 008 Standby Generator-Boiler

SV 004 Cummins Standby Gen-Sub 3(W)

SV 005 Cummins Standby Gen-Sub 3(E)

SV 006 Caterpillar Standby Gen-Sub 1

SV 007 Caterpillar Standby Gen-Boiler

What to do Why to do it The limits below apply to each boiler separately listed in GP 002. hdr

EMISSION LIMITS hdr

Sulfur Dioxide: less than or equal to 0.50 lbs/million Btu heat input using 3-hour Rolling Average . The potential to emit from each unit is 0.29 lb/mmBtu based on the maximum capacity to equipment design and allowable fuel. Minn. R. 7011.2300, subp. 2

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

OTHER LIMITS AND REQUIREMENTS hdr

Sulfur Content of Fuel: less than or equal to 0.05 percent by weight of diesel fuel. Title I Condition: State Implementation Plan (SIP) for SO2 NAAQS, 40 CFR pt. 50; 40 CFR pt. 51; 40 CFR pt. 52, subp. Y; MN SIP Fuel Restriction: The Permittee is authorized to burn diesel fuel only. Title I Condition: State Implementation Plan (SIP) for SO2 NAAQS, 40 CFR pt. 50; 40 CFR pt. 51; 40 CFR pt. 52, subp. Y; MN SIP Fuel Supplier Certification: The Permittee shall obtain and maintain written fuel supplier certification from the fuel supplier for each shipment of diesel fuel oil delivered to the facility. Each fuel certification shall include the following information: the name of the fuel oil supplier; the sulfur content of the fuel oil and method used to determine the sulfur content of the fuel oil. Tilte I Condition: State Implentation Plan (SIP) for SO2 NAAQS, 40 CFR pt. 50; 40 CFR pt. 51; 40 CFR pt. 5, subp. Y; MN SIP

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

The Permittee shall keep records of fuel type and usage on a monthly basis for these units by the 28th day of each month. Minn. R. 7007.0800, subp. 5TABLE A: LIMITS AND OTHER REQUIREMENTS 04/08/10

River Road Industrial Center

00300245 - 001 Facility Name:

Permit Number: A-7

Subject Item: EU 004 Boiler No. 4

Associated Items: SV 003 Boiler No. 4

What to do Why to do it Recordkeeping: By the last day of each calendar month, the Permittee shall record the amount of natural gas combusted in the boiler during the previous calendar month. These records shall consist of purchase records, receipts, or fuel meter readings. 40 CFR Section 60.48c(g); Minn. R. 7011.0570

Fuel Restriction: The Permittee is authorized to burn natural gas only. Minn. R. 7005.0100, subp. 35aAPPENDIX II:Facility Name: River Road Industrial CenterPermit Number: 00300245-001Title I Condition: State Implementation Plan (SIP) for SO2National Ambient Air Quality Standards (NAAQS)SO2Modeling Parameters Relied Upon to Demonstrate Compliance with NAAQSSource Name EmissionUnitNumberSV ID StackHeight(feet)StackHeight(m)StackDia.(feet)StackDia.(m)StackVelocity(m/s)ExitTemp(F)Modeled andMaximum HeatInput(million Btu/hr)Flow Rate atTop(ACFM)Boiler 1001001140437.02.13.932569.829,466Boiler 2 & 3002003002140438.52.41.832569.8 & 35.119,677StandbyGeneratorSub 3(w)and 3(e)00500600400536110.590.18584402.962.963,100StandbyGenerator –Sub 1007006247.30.590.18554403.462,955StandbyGenerator –Boiler andBdg 37008007298.80.490.15484402.11,793

### Attachment 2: Permit technical support documentTechnical Support Document, Permit Action Number: 00300245-001 Page 1 of 15 Date: 4/16/2010 

### TECHNICAL SUPPORT DOCUMENT For AIR EMISSION PERMIT NO. 00300245-001

This technical support document (TSD) is intended for all parties interested in the permit and to meet the requirements that have been set fort h 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 permit.

1. General Information 1.1 Applicant and Stationary Source Location: Table 1. Applicant and Source Address
Applicant/Address Stationary Source/Address (SIC Code: 4961) ELT Minneapolis, LLC 1650 Des Peres Road, Suite 306 St. Louis, MO 63131 River Road Industrial Center 4800 East River Road Fridley Anoka County Contact: Thomas Vierling Phone: 763-571-7215
1.2 Facility Description ELT Minneapolis, LLC owns and operates boilers and emergency generators in the city of Fridley, which was part of the purchase agreement dated November 22, 2005, between BAE Systems Land and Armaments (formerly United Defense, LP), Inc and ELT Minneapolis, LLC (ELT). The company is a heat and steam distributor. The boilers and emergency generators were permitted under Air Emission Permit No. 00300020-001. The Minnesota Pollution Control Agency (MPCA) received their permit application on July 17, 2007. ELT did not submit any information that was claimed to be confidential verbally or in written correspondence.

This permit is a Joint Title I/Title V Federally Enforceable State Operating Permit, as it includes non-expiring Title I Conditions to implement the State Implementation Plan (SIP), pursuant to 40 CFR pt. 50, 40 CFR pt. 51, 40 CFR § 

### 52.1220, Minn. R. 7007.0100, subp. 25B, and Minn. R. 7007.1050, subp. 4.

The facility is part of the SIP to r each attainment of sulfur dioxide (SO 2 

### ) National Ambient Air Quality Standards (NAAQS) in Twin Cities 7-County Area. This permit will be resubmitted to U.S. Environmental Protection Agency (EPA) for inclusion into the SIP, and will replace United Defense, LP (formerly FMC/U.S.Navy) Air Emission Permit No. 00300020-001, which was State effective November 25, 2002, and EPA approved August 18, 2004, registered in the Federal Register No. 51181, as Title I Conditions only.Technical Support Document, Permit Action Number: 00300245-001 Page 2 of 15 Date: 4/16/2010 

### The main sources of potential emissions are SO 2 

### and nitrogen oxides (NOx). The permit limits the emissions of the facility such that the f acility is classified as a non-major source under federal Operating Program (40 CFR pt. 70) a nd non-major under federal New Source Review regulations (40 CFR § 52.21). The facility is an area source under federal National Emission Standards for Hazardous Air Pollutants (40 CFR pt. 63).

1.3 Description of any Changes Allowed with this Permit Issuance

This permit does not authorize any new emission units or allow for increase in emissions. As a conservative estimate, PM 10 

### is assumed to be a conservative estimate of PM 2.5. 

### 1.4 Permit History

Permit Number and Issuance Date Action Authorized

SO 2 

### Administrative Order for the State Implementation Plan (SIP) The emission limits, the operating restrictions, and requirements to demonstrative compliance for SO 2 

### were found in the Administrative Order (Order). The modeling parameters were included in the SIP. The Order was revoked and replaced with Air Emission Permit No. 00300020-001, issued November 25, 2002. All the SIP conditions were cited in Air Emission Permit No. 00300020-003, therefore the SIP will be updated to reflect the correctly numbered permit.
1.5 Facility Emissions:

Table 2. Total Facility Potential to Emit Summary

PM tpy PM 10 

### tpy PM 2.5 

### tpy SO 2 

### tpy NO x 

### tpy CO tpy VOC tpy Single HAP

tpy All HAPs

tpy Total Facility Limited Potential Emissions 20 20 20 42 90 69 5.4 0.52 1.4

Total Facility Actual Emissions (2008) 0.065 0.065 0.065 0.072 0.53 0.36 0.037 HAPs not reported in emission inventoryTechnical Support Document, Permit Action Number: 00300245-001 Page 3 of 15 Date: 4/16/2010 

### Table 3. Facility Classification
Classification Major/Affected Source Synthetic Minor Minor

PSD SO 2 

### PM, PM 10 

### , PM 2.5 

### , CO, NOx, VOC Part 70 Permit Program NOx, SO 2 

### PM, PM 10 

### , PM 2.5 

### , CO, VOC Part 63 NESHAP HAP

2. Regulatory and/or Statutory Basis

New Source ReviewThe facility is limited based on SIP requirements; therefore, the facility is an existing nonmajor source under New Source Review regulations (40 CFR § 52.21). No changes are authorized by this permit. Part 70 Permit Program The facility has accepted limits; therefore the f acility is a non-major source under the Part 70 permit program. New Source Performance Standards (NSPS)The facility is subject to the New Source Performance Standards for Small IndustrialCommercial-Institutional Steam Generating Units (40 CFR pt. 60, subp. Dc). National Emission Standards for Hazardous Air Pollutants (NESHAP) The facility is non- major source under 40 CFR pt. 63. Thus, no NESHAPs apply. In addition, the Permittee has stated that no area source NESHAPs apply to the facility. Compliance Assurance Monitoring (CAM) CAM does not apply, since the facility is not subject to Title V permitting requirements. State Implementation Plan (SIP) The SIP revision serves to generally update this facility in the SIP. First, this SIP revision accounts for the change in ownership of the facility. Secondly, although the joint document currently incorporated into the SIP is listed as Air Emission Permit No. 00300020-001, it appears that the SIP conditions were from Air Emission Permit No. 00300020-003. This update will ensure that the correctly numbered permit is incorporated into the SIP as the joint document. Finally, the incorporation of the current joint document includes several Title I conditions that are not related to the SIP. With this SIP revision, the MPCA will request that these conditions beTechnical Support Document, Permit Action Number: 00300245-001 Page 4 of 15 Date: 4/16/2010 

### removed. Many of these non-SIP Title I conditions relate to emission units that are not owned by ELT.

This revision does not involve any substantive changes to the SIP conditions, which includes the modeling requirements. All fuel restrictions, SO 2 

### emission limits and modeling parameters will remain the same. Some changes to the SIP conditions were made in order to be consistent with the MPCA’s current practices for joint documents, but these changes are administrative and provide detail clarifying for the facility when SIP revisions are required.

Environmental Review & AERA There are no changes required; therefore, the applicant is not required to perform an Air Emissions Risk Analysis (AERA).

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

• Minn. R. 7011.2300 Standards of Performance for Stationary Internal Combustion Engines Table 4. Regulatory Overview of Facility
Level* Applicable Regulations Comments:

Total Facility (TF) Title I Condition: 40 CFR pt. 50; 40 CFR pt. 51; 40 CFR pt. 52, subp. Y; Applicable requirements for SO 2 

### associated with the total facility, boilers and standby generators for the SIP. This permit now contains the conditions previously expressed in Air Emission Permit No. 00300020-001, BAE Systems in the SIP. GP 001 and GP 002 Title I Condition: SIP for SO2 NAAQS, 40 CFR pt. 50; 40 CFR pt. 51; 40 CFR pt. 52, subp. Y; MN SIP The company shall attain, demonstrate and maintain compliance with the applicable state and federal Ambient Air Quality Standards for SO 2 

### as noted in Appendix II of this permit.

TF Minn. R. chs. 7002, 7007, 7009, 7011, 7019, and 7030 Table A contains some requirements that apply to all facilities in Minnesota. Reporting and monitoring requirements are contained in Table B of this permit. TF 40 CFR pt. 50, Minn. R. 7009.0010-0080 Modeling requirements to ensure emissions do not cause a violation of the National Ambient Air Quality Standards (NAQQS) GP 001 40 CFR pt. 60, subp. Dc; Minn. R. 7011.0515; 40 CFR § 52.21 and Minn. R. 7007.3000 Standards of Performance for Small IndustrialCommercial-Institutional Steam Generating Units. Determination of applicable limits from rule:

• The units were constructed in 1993;Technical Support Document, Permit Action Number: 00300245-001 Page 5 of 15 Date: 4/16/2010 

### • The heat input capacity are 69.8 and 35.1mmBtu/hr, respectively; and

• The fuels burned are natural gas and distillate oil.

Prevention of Significant Deterioration. Operational limit taken to keep the potential emissions increase of SO 2 

### from the boilers to less than significant as defined by 40 CFR § 52.21EU 004 40 CFR pt. 60, subp. Dc; Standards of Performance for Small IndustrialCommercial-Institutional Steam Generating Units. Determination of applicable limits from rule:

• The unit was constructed in 2003;

• The heat input capacity is 10.5 mmBtu/hr; and

• The fuel burned is natural gas.

GP 002 Minn. R. 7011.2300 Standards of Performance for Stationary Internal Combustion Engines. The emergency standby generators are considered stationary internal combustion engines. The rule limits opacity and SO 2 

### (sulfur content of the fuel), and requires recordkeeping. Total Facility Minn. R. 7030.0010- 7030.0080 Noise Standards, which applies to all facilities in Minnesota. This is a state-only requirement and is not enforceable by the U.S. Environmental Protection Agency (EPA) Administrator and citizens under the Clean Air Act' refers to permit requirements that are mandated by state law rather than by the federal Clean Air Act. The language is to clarify the distinction between permit conditions that are required by federal law and those that are required by state law. State law requirements are not enforceable by the EPA or by citizens under the federal Clean Air Act, but are fully enforceable by the MPCA and citizens under provisions of state law.

3. Technical Information

3.1 Calculations of Potential to Emit Attachment 1 to this TSD contains detailed spreadsheet prepared by River Road Industrial Center and audited by the MPCA using information provided to show the potential to emit calculations for each unit. Total emissions for all criteria pollutants and HAPs except NOx and SO 2 

### are true minors; therefore source-wide limits were not established for those pollutants.Technical Support Document, Permit Action Number: 00300245-001 Page 6 of 15 Date: 4/16/2010 

### The potential to emit calculations for the four (4) boilers are dependent on the type of fuel combusted and the maximum heat input of each boiler. Emissions from these boilers are created from either natural gas or distillate fuel. The following references were used to calculate the emissions:

• EPA AP-42, Section 1.4 : Natural Gas Combustion (Tables 1.4-1 through 1.4.2(9/1998))

• EPA AP-42, Section 1.3: Fuel Oil Combustion (Tables 1.3-1 through 1.3-3(9/1998))

• SIP limit: Sulfur Content of the Fuel The potential to emit from the emergency generators were calculated using diesel combustion emission factors from EPA AP-42, Section 3.3(10/ 1996), Tables 3.3-1. Note: the potential to emit is based on a maximum of 500 operating hours per year as EPA defines emergency generators as those that operate for no more than 500 hours per year (see EPA memorandum titled “Calculating Potential to Emit (PTE) for Emergency Generators”, dated September 6, 1995.).
3.2 Periodic Monitoring
In accordance with the Clean Air Act, it is the re sponsibility of the owner or operator of a facility to have sufficient knowledge of the facility to cer tify 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 5 summarizes the periodic monitoring requirements for those emission units for which the monitoring required by the applicable requirement is nonexistent or inadequate.
Table 5. Periodic Monitoring
Level* Requirement (basis) Additional Monitoring Discussion

TF NOx: less than or equal to 90 tons per year based on a 12-month rolling

sum (limit to avoid Part 70) Recordkeeping: Monthly records and emission calculations

On-going recordkeeping to verify and certify on The company will keep records and provide calculations of emissions on a monthly basis of the 12-month rolling sum for NOx. A 12- month rolling sum is warranted for the facility dueTechnical Support Document, Permit Action Number: 00300245-001 Page 7 of 15 Date: 4/16/2010



### Level* Requirement (basis) Additional Monitoring Discussion

an annual basis to maintain the source in a non major status. to the substantial and unpredictically of the source.

GP 001 a. Opacity: ≤ 20% except for one 6-minute per hour of not more than 27% opacity (40 CFR Section 60.43c and Minn. R. 7011.0570

b. Sulfur Content of Fuel: ≤ 0.05 percent by weight (SIP for SO2 NAAQS, 40 CFR pt. 50; 40 CFR pt. 51; 40 CFR pt. 52, subp. Y; MN SIP; limit to avoid NSR)

c. Sulfur Content of Fuel: ≤ 0.5 percent by weight or 0.50 lb/mmBtu (40 CFR Section 60.42c(i) and Minn. R. 7011.0570)

d. Fuel Type: Natural Gas and Distillate Fuel Oil. (MN SIP) Recordkeeping: Records of the type of fuel burned and usage on a monthly basis.

Monitoring: Sulfur content of fuel using fuel supplier certification. The fuel Oil Certification is used as a monitoring requirement to ensure that the sulfur content of the distillate fuel oil is less than 0.05 percent by weight to satisfy the MN SIP and to avoid major source threshold. The 0.05 percent is more stringent than the NSPS limit for subp. Dc, which is 0.5 percent; therefore the source will be in compliance as long as the sulfur content in the fuel is less than 0.05percent by weight. The certification of each shipment of distillate fuel oil which includes the name of the supplier and the maximum sulfur content of the fuel oil will be retained on site.

Since the boilers will be fired with natural gas and very low sulfur diesel fuel of 0.05% or less, there should be no significant visible emissions. Therefore while there is an applicable requirement, the Permittee, can demonstrate that each emission unit is and will continue to operate such that the emissions are well below the emission limits

GP 002 Sulfur Content of Fuel: ≤ 0.05 percent by weight (SIP for SO2 NAAQS, 40 CFR pt. 50; 40 CFR pt. Fuel oil certification for each shipment and recordkeeping of hours of operation to Written documentation of each shipment of diesel fuel oil will be retained on site.Technical Support Document, Permit Action Number: 00300245-001 Page 8 of 15 Date: 4/16/2010



### Level* Requirement (basis) Additional Monitoring Discussion

51; 40 CFR pt. 52, subp. Y; MN SIP)

b. SO 2 

### : 0.50 lbs/mmBtu heat input (Minn. R. 7011.2300)

c. Opacity: ≤ 20% opacity once operating temperatures are attained (Minn. R. 7011.2300)

d. Fuel Type: Diesel Fuel (MN SIP)

e. Hours of Operations:< 500 hours/yr determine that the generators qualify as emergency generators. This monitoring is adequate because the generators will be used on an emergency basis only.

EU 004 Fuel Restriction: Natural Gas only Recordkeeping: Record the amount of fuel combusted in the unit Based on the NSPS, subp. Dc, this unit is highly unlikely to generate significant amount of emissions. Recordkeeping based on purchase records, receipts or fuel meter reading is adequate compliance. *Where the requirement appears in the permit (e.g., TF, EU, SV, GP, etc.).
3.3 Insignificant Activities River Road Industrial Center 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 I of this TSD for PTE information for the insignificant activities.Technical Support Document, Permit Action Number: 00300245-001 Page 9 of 15 Date: 4/16/2010 

### Table 6. Insignificant Activities

Insignificant Activity General Applicable Emission limit Discussion
Storage Tanks (two 30,000 gallons No. 2 fuel and 4,000 gallons diesel fuel) Install a permanent submerged fill pipe. Minn. R. 7011.1505, subp. 3(B) This requires installation of certain equipment and does not set an emission limit; therefore, periodic monitoring of these tanks is not
necessary Storage Tank (one 250 gallons diesel fuel) Minn. R. 7011.1505, subp. 3(B) There are no standard of performance for this tank; therefore, periodic monitoring of this tank is not
necessary. Emergency Fire Water Pump Diesel Engine SO 2 

### : 0.50 lbs/mmBtu heat input

Opacity: ≤ 20% opacity once operating temperatures are attained

(Minn. R. 7011.2300) The fire pump will be used on an emergency basis only. The PTE of all the pollutants are well below 1 ton/yr. Based on EPA published AP-42 emission factors; it is highly unlikely that the unit will violate the applicable requirements.

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 nece ssary enforcement notices or documents. Staff must generate these

3. 5 Comments Received Public Notice Period: February 19, 2010- March 22, 2010 EPA 30-day Review Period: February 19, 2010- March 22, 2010 No comments were received during the public notice and EPA review period.

### Attachment 3: Permit No. 00300245-001; Title I SIP conditions only

### Am EMISSION PERMIT 

### NO.**0030~Z45-** 

### 001 Total Facility Operating Permit

IS ISSUED TO

,EL T Minneapolis LLC

RIVER ROAD INDUSTRIAL CENTER 4800-4898 East River Road Fridley, Anoka County, MN 55421

The emission units, control equipment and emission stacks at the stationary source authorized in this

, permit are as described in the Permit Applications Table.

This permit, Air Emission Permit No.00300245-001, authorizes the Permittee to operate the stationary

source at the address listed abQve unless otherwise noted in Table A: The Permittee t:J1ust coinply with all the conditions of the permit. Any changes or modifications to the stationary source must be performed in

,compliance with Minn. R. 7007 r.l150 to 7007.1500. Any additions or changes to conditions incorporated into Minnesota's State Implementation Plan (SIP) under 40 CFR § 52.1220, designated "Title I: SIP for sulfur dioxide 

### (S02) must go through the federal SlP approval process before becoming 'effective. Terms' used in the permit are as defined in, the state air po))ution control rules unless the term is exp.Hcitly defined in the permit.

Unless otherwise indicated, an the Minnesota rules cited as the origin of the permit terms are ,

, incorporated into the SW under 40 CFR § 52. 122(), and as such as are enforceable by U.S. Environmerital Protection Agency (EPA) Administtatoror citizens under the Clean Air Act. '

, .

. Permit Type: State; Limits t9 Avoid 

### Pt 70/Limits to Avoid NS'R; Title} SIP Conditions 

### (80 2 ) Operating Permit Issue: Date: 

### 'April'S,**20~O** 

### '
Expiration Date: Non-Expiring

- All Title I Conditions do not expire.

.. ," . Each neW or revised condition designated Title I Condition: SIP for S02 is not-effective or enforceable until approved by EPA 'as a SIP revision under Title I of the Clean Air Act. '

....... .

.....

. ' .'

.

,

# ~?''-;'''-I¥~:::lJ~f-''-'-' ------- 

# Jr,,' nager........ Air QualityPeimits Section Industrial Division

" for Paul Eger

, Commissioner

Minnesota Pollution Control Agency', '.

"TDD (for hearing and speech impaired only): (651)282-5332 Printed on recycled paper containing at least 10'% fibers from paper recycled by consumers

### Permit Applications Table

Permit Type Application Date Permit Action
Total Facility Operating Permit July 17, 2007 Revised: June 24, 2010 001

### TABLE OF CONTENTS

Notice to the Permittee

Permit Shield

Facility Description

Table A: Limits and Other Requirements

Table B: Submittals

Appendices:

Appendix I: Insignificant Activities and General Applicable Requirements

Appendix II: Title I Condition: SIP for Sulfur Dioxide (SO 2 

### ) Modeling Parameters Relied Upon to Demonstrate Compliance with NAAQS

### 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 pr ovision 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:

ELT Minneapolis, LLC owns and operates boilers and emergency generators in the city of Fridley, which was part of the purchase agreement dated November 22, 2005, between BAE Systems Land and Armaments (formerly United Defense, LP), Inc and ELT Minneapolis, LLC (ELT). The company is a heat and steam distributor. The boilers and emergency generators were permitted under Air Emission Permit No. 00300020-001. The Minnesota Pollution Control Agency (MPCA) received their permit application on July 17, 2007. ELT did not submit any information that was claimed to be confidential verbally or in written correspondence.

This permit is a Joint Title I/Title V Federally Enforceable State Operating Permit, as it includes non-expiring Title I Conditions to implement the State Implementation Plan (SIP), pursuant to 40 CFR pt. 50, 40 CFR pt. 51, 40 CFR § 

### 52.1220, Minn. R. 7007.0100, subp. 25B, and Minn. R. 7007.1050, subp. 4.

The facility is part of the SIP to reach attainment of SO 2 

### National Ambient Air Quality Standards (NAAQS) in Twin Cities 7-County Area. This permit will be resubmitted to EPA for inclusion into the SIP, and will replace United Defense, LP (formerly FMC/U.S.Navy) Air Emission Permit No. 00300020-001, which was State effective November 25, 2002, and EPA approved August 18, 2004, registered in the Federal Register No. 51181, as Title I Conditions only.

The main sources of potential emissions are SO 2 

### and nitrogen oxides (NOx). The permit limits the emissions of the facility such that the f acility is classified as a non-major source under federal Operating Program (40 CFR pt. 70) and non-major under federal New Source Review regulations (40 CFR § 52.21). The facility is an area source under federal National Emission Standards for Hazardous Air Pollutants (40 CFR pt. 63).TABLE A: LIMITS AND OTHER REQUIREMENTS 04/08/10

River Road Industrial Center

00300245 - 001 Facility Name:

Permit Number: A-1

Table A contains limits and other requirements with which your facility must comply. The limits are located in the first column of the table (What To do). The limits can be emission limits or operational limits. This column also contains the actions that you must take 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 facility requirements.

Subject Item: Total Facility

What to do Why to do it
SOURCE-SPECIFIC REQUIREMENTS hdr

STATE IMPLEMENTATION PLAN (SIP) REQUIREMENTS hdr

A CTIVITIES NOT REQUIRING A MODIFICATION TO THE SIP: The Permittee is authorized to make changes to the facility without obtaining a modification to the SIP as long as the change does not do or result in any of the following: 1. An exceedance of the limitations at which sulfur dioxide is emitted from any emission unit at the facility; 2. A physical change of the equipment that affects the stack parameters described in Appendix II; and 3. Any construction or modification of building structures greater than 56 feet above grade elevation if within 280 feet of Emission Units 1, 2 or 3. Title I Condition: State Implementation Plan (SIP) for SO2 NAAQS; 40 CFR pt. 50; 40 CFR pt. 51; 40 CFR pt. 52, subp. Y; MN SIP

A CTIVITIES REQUIRING A MODIFICATION TO THE SIP: A ctivities requiring a modification of the SIP prior to the Permittee commencing the activity include, but are not limited to, the following: 1. Any decrease in the design and/or maximum stack gas volumetric flow rate below that contained in Appendix II; 2. Any decrease in the design and/or maximum stack gas exit temperature below that contained in Appendix II; 3. Any reduction in stack height below that contained in Appendix II; 4. Any increase in stack exit diameter above that contained in Appendix II; and 5. Any construction or modification of structures that increase the effective structural dimensions. Title I Condition: State Implementation Plan (SIP) for SO2 NAAQS; 40 CFR pt. 50; 40 CFR pt. 51; 40 CFR pt. 52, subp. Y; MN SIP

Construction and Operation of SIP Emission Unit: The Permittee may begin actual construction of a new emission unit or modification to existing emission unit upon permit issuance. However, the Permittee shall not operate any new emission unit or modified emission unit until any required SIP amendment is approved by US EPA. Title I Condition: State Implementation Plan (SIP) for SO2 NAAQS; 40 CFR pt. 50; 40 CFR pt. 51; 40 CFR pt. 52, subp. Y; MN SIP

General Operating and Maintenance Requirements for the SIP: The owner or operator shall operate and maintain the process equipment described in Appendix II according to the parameters set forth in Appendix II. The parameters were used in the computer modeling performed to demonstrate that the SO2 maintenance area will attain compliance with the SO2 NAAQS. Title I Condition: State Implementation Plan (SIP) for SO2 NAAQS; 40 CFR pt. 50; 40 CFR pt. 51; 40 CFR pt. 52, subp. Y; MN SIP

Non-Permanent Records for SIP: The Permittee shall retain all records at the facility for a minimum of six years following the date of the required monitoring, sample, measurement, or report that corresponds with the SIP Title I Condition. All required documents, records, reports and plans in a form suitable for determination of the facility's compliance with the SIP by EPA or MPCA staff. The Permittee shall maintain the information at the facility in files which are easily accessible of inspections by EPA or MPCA staff, and are available for inspection. Title I Condition: State Implementation Plan (SIP) for SO2 NAAQS; 40 CFR pt. 50; 40 CFR pt. 51; 40 CFR pt. 52, subp. Y; MN SIP

Reporting: The Permittee may undertake certain changes to the facility without obtaining a modification to the SIP. However, if the Permittee does make a change, and if the change in any way affects SO2 emissions, the Permittee shall notify the Commissioner in writing at least 30 days prior to undertaking the change. The notification shall describe the change and why it does not require a modification to the SIP. Title I Condition: State Implementation Plan (SIP) for SO2 NAAQS; 40 CFR pt. 50; 40 CFR pt. 51; 40 CFR pt. 52, subp. Y; MN SIP

A nnual Report for SIP: due 30 days after end of each calendar year following Permit Issuance to the Commissioner. The report shall contain the following information: a record of data used in calculating SO2 emissions, and calculations of the SO2 emissions; a record of each unscheduled startup, shutdown, and breakdown of process equipment; a summary record of excess SO2 emissions (or the Permittee shall state if no exceedances, and noncompliance conditions occurred in the calendar year). Title I Condition: State Implementation Plan (SIP) for SO2 NAAQS; 40 CFR pt. 50; 40 CFR pt. 51; 40 CFR pt. 52, subp. Y; MN SIP

TOTAL FACILITY EMISSION LIMITS AND RECORDKEEPING hdrTABLE A: LIMITS AND OTHER REQUIREMENTS 04/08/10

River Road Industrial Center

00300245 - 001 Facility Name:

Permit Number: A-5

Subject Item: GP 001 Boilers Subject to SIP and NSPS

Associated Items: EU 001 Boiler 1

EU 002 Boiler 2

EU 003 Boiler 3 (81098)

SV 001 Boiler 1

SV 002 Boiler 2 and 3

What to do Why to do it The limits below apply to each boiler separately listed in GP 001. hdr

EMISSION LIMIT hdr

OTHER LIMITS AND REQUIREMENTS hdr

Sulfur Content of Fuel: less than or equal to 0.05 percent by weight of No. 2 fuel oil. (This limit is more stringent than the NSPS limit.) Title I Condition: State Implementation Plan (SIP) for SO2 NAAQS, 40 CFR pt. 50; 40 CFR pt. 51; 40 CFR pt. 52, subp. Y; MN SIP

MONITORING AND RECORDKEEPING REQUIREMENTS hdr

Fuel Supplier Certification: The Permittee shall obtain and maintain written fuel supplier certification from the fuel supplier for each shipment of distillate fuel oil delivered to the facility. Each fuel certification shall include the following information: the name of the fuel oil supplier; the sulfur content of the fuel oil; and method used to determine the sulfur content of the fuel oil. Title I Condition: State Implementation Plan (SIP) for SO2 NAAQS, 40 CFR pt. 50; 40 CFR pt. 51; 40 CFR pt. 52, subp. Y; MN SIP

Fuel Restriction: The Permittee is authorized to burn natural gas and distillate fuel oil only. Title I Condition: State Implementation Plan (SIP) for SO2 NAAQS, 40 CFR pt. 50; 40 CFR pt. 51; 40 CFR pt. 52, subp. Y; MN SIPTABLE A: LIMITS AND OTHER REQUIREMENTS 04/08/10

River Road Industrial Center

00300245 - 001 Facility Name:

Permit Number: A-6

Subject Item: GP 002 Standby Generators

Associated Items: EU 005 Standby Generator-Sub 3(W)

EU 006 Standby Generator-Sub 3(E)

EU 007 Standby Generator-Sub 1

EU 008 Standby Generator-Boiler

SV 004 Cummins Standby Gen-Sub 3(W)

SV 005 Cummins Standby Gen-Sub 3(E)

SV 006 Caterpillar Standby Gen-Sub 1

SV 007 Caterpillar Standby Gen-Boiler

What to do Why to do it The limits below apply to each boiler separately listed in GP 002. hdr

EMISSION LIMITS hdr

OTHER LIMITS AND REQUIREMENTS hdr

Sulfur Content of Fuel: less than or equal to 0.05 percent by weight of diesel fuel. Title I Condition: State Implementation Plan (SIP) for SO2 NAAQS, 40 CFR pt. 50; 40 CFR pt. 51; 40 CFR pt. 52, subp. Y; MN SIP Fuel Restriction: The Permittee is authorized to burn diesel fuel only. Title I Condition: State Implementation Plan (SIP) for SO2 NAAQS, 40 CFR pt. 50; 40 CFR pt. 51; 40 CFR pt. 52, subp. Y; MN SIP Fuel Supplier Certification: The Permittee shall obtain and maintain written fuel supplier certification from the fuel supplier for each shipment of diesel fuel oil delivered to the facility. Each fuel certification shall include the following information: the name of the fuel oil supplier; the sulfur content of the fuel oil and method used to determine the sulfur content of the fuel oil. Tilte I Condition: State Implentation Plan (SIP) for SO2 NAAQS, 40 CFR pt. 50; 40 CFR pt. 51; 40 CFR pt. 5, subp. Y; MN SIPAPPENDIX II:Facility Name: River Road Industrial CenterPermit Number: 00300245-001Title I Condition: State Implementation Plan (SIP) for SO2National Ambient Air Quality Standards (NAAQS)SO2Modeling Parameters Relied Upon to Demonstrate Compliance with NAAQSSource Name EmissionUnitNumberSV ID StackHeight(feet)StackHeight(m)StackDia.(feet)StackDia.(m)StackVelocity(m/s)ExitTemp(F)Modeled andMaximum HeatInput(million Btu/hr)Flow Rate atTop(ACFM)Boiler 1001001140437.02.13.932569.829,466Boiler 2 & 3002003002140438.52.41.832569.8 & 35.119,677StandbyGeneratorSub 3(w)and 3(e)00500600400536110.590.18584402.962.963,100StandbyGenerator –Sub 1007006247.30.590.18554403.462,955StandbyGenerator –Boiler andBdg 37008007298.80.490.15484402.11,793

### Attachment 4: Marked up United Defe nse currently approved joint document1

# Summary of Comments on Marked Up United Defense Permit.pdf

Page: 1

Number: 1 Author: cneusch Subject: Sticky Note Date: 2/5/2010 10:50:08 AM -06'00' Cover Page shows action -0011

2

3

4

5

6

# Page: 3

Number: 1 Author: cneusch Subject: Sticky Note Date: 2/5/2010 10:50:29 AM -06'00' Subsequent pages show permit number -003
Number: 2 Author: cneusch Subject: Sticky Note Date: 2/5/2010 10:53:33 AM -06'00' Applied to emission unit groups on Page A-5 and A-6.
Number: 3 Author: cneusch Subject: Sticky Note Date: 2/5/2010 10:53:35 AM -06'00' No longer necessary. Cover page of new permit states that all SIP conditions continue to apply until EPA approves.
Number: 4 Author: cneusch Subject: Sticky Note Date: 2/5/2010 10:53:37 AM -06'00' Page A-1
Number: 5 Author: cneusch Subject: Sticky Note Date: 2/5/2010 10:53:39 AM -06'00' Page A-1, wording revised to meet new MPCA permit guidance. Now a six year requirement.
Number: 6 Author: cneusch Subject: Sticky Note Date: 2/5/2010 10:54:03 AM -06'00' None of these are SIP conditions and therefore should be removed.1

# Page: 4

Number: 1 Author: cneusch Subject: Sticky Note Date: 2/5/2010 10:54:14 AM -06'00' Not a SIP condition.1

2

# Page: 5

Number: 1 Author: cneusch Subject: Sticky Note Date: 2/5/2010 10:58:13 AM -06'00' Now GP001 with SV001 and SV002. Boilers have not changed.
Number: 2 Author: cneusch Subject: Sticky Note Date: 2/5/2010 10:58:50 AM -06'00' All these conditions are included on page A-5.1

2

# Page: 6

Number: 1 Author: cneusch Subject: Sticky Note Date: 2/5/2010 11:00:26 AM -06'00' Now GP002. Generators renumbered as EU005 - EU008, and SV004 - 007. One generator removed.
Number: 2 Author: cneusch Subject: Sticky Note Date: 2/5/2010 11:00:59 AM -06'00' All conditions maintained on page A-6.1

# Page: 7

Number: 1 Author: cneusch Subject: Sticky Note Date: 2/5/2010 11:01:15 AM -06'00' None of these are SIP conditions and should be removed.1

# Page: 8

Number: 1 Author: cneusch Subject: Sticky Note Date: 2/5/2010 11:01:33 AM -06'00' None of these are SIP conditions and should be removed.

### Attachment 5: Public notice

### MINNESOTA POLLUTION CONTROL AGENCY PUBLIC NOTICE ON DRAFT/PROPOSED AIR EMISSION FACILITY PERMIT

NOTICE IS HEREBY GIVEN , that the Commissioner of the Minnesota Pollution Control Agency (MPCA) proposes to issue Air Emission Permit No. 00300245-001, to ELT Minneapolis LLC (ELT) for their facility River Road Industrial Center located at 4800 East River Road, Fridley, Anoka County, Minnesota.
In addition, NOTICE IS HEREBY GIVEN that the Commissioner has determined that the State Implementation Plan (SIP) conditions for this facility should be amended. This permit incorporates Title I requirements for ELT which are included in Minnesota’s SIP and are necessary to demonstrate compliance with the National Ambient Air Qua lity Standards (NAAQS) for sulfur dioxide (SO 2 

### ).

Title V of the federal Clean Air Act Amendments of 1990, requires that all applicable requirements to a stationary source must be incorporated into its opera ting permit. Title I conditions associated with the SIP are considered applicable requirements; therefor e, this operating permit incorporates these Title I requirements for ELT that were originally included in United Defense, LP (formerly FMC/U.S.Navy) Air Emission Permit No. 00300020-001, which was St ate effective November 25, 2002, and EPA approved August 18, 2004, registered in the Federal Register No. 51181, as Title I Conditions only. These Title I SIP conditions are necessary to demonstrate compliance with the NAAQS for SO 2 

### . 1) Proposed Permit
The permit action is for issuance of state operating total facility permit; therefore, the draft/proposed Federal Enforceable State Operating Permit (FESOP) has been placed on public notice for 30-day period. The MPCA is providing the draft permit to U.S. Environmental Protection Agency’s (EPA) at the same time of the EPA’s 30-day review period, which w ill begin with the 30-day public review period.

A summary of the Potential to Emit (PTE) in tons per year is as follows:

Pollutant PM PM 10 

### PM 2.5 

### SO 2 

### NO x 

### VOCs CO HAP Total Facility PTE 20 20 20 42 90 5.4 69 1.4

PM = Particulate Matter PM 10 

### = PM smaller than 10 microns PM 2.5 

### = PM smaller than 2.5 microns SO 2 

### = Sulfur Dioxide NO x 

### = Nitrogen Oxides VOCs = Volatile Organic Compounds CO = Carbon Monoxide HAP = Hazardous Air Pollutant

The Permittee is not required to submit a pollution prevention progress report pursuant to Minn. Stat. § 115D.08.

2) Proposed SIP Changes
Under its Title I authority, the MPCA is revising the SIP conditions to update the facility as the result of the new ownership. This SIP revision does not make any changes to any SO 2 

### emission limits already included in the SIP. Therefore, the MPCA believ es this action will not have an adverse impact on compliance with the NAAQS for SO 2 

### . The MPCA will be formally requesting that the EPA amend Minnesota’s SIP to include the new and revised Title I SIP conditions from Air Emission Permit No. 00300245-001, which will serve as a joint Title I SI P/Title V document. These Title I conditions do not expire.
After its issuance, this permit will be submitted to th e EPA for its inclusion into Minnesota’s SIP. Air Emission Permit No. 00300020-001, that includes these requirements will then be rescinded, since the requirements are now included in this permit. Until th e time that EPA accepts this permit as part of the2 

### SIP, the Title I SIP requirements in Air Emission Permit No. 00300020-001, are in full effect and the Permittee must comply with them.

3) Public Participation
The preliminary determination to issue the air emissi on permit and submit the SIP revision is tentative. There are four formal procedures for public particip ation in the MPCA’s consideration of the permit application and SIP. Interested persons may (1 ) submit written comments on the proposed permit; (2) request that the MPCA hold a public information m eeting; (3) request the MPCA hold a contested case hearing; and/or (4) submit a petition to the Commi ssioner requesting that the MPCA Citizens’ Board (Board) consider the permit matter.
The decision whether to issue the permit and submit the SIP revision and, if so, under what terms, will be presented to the Board for decision if: (1) the Co mmissioner grants the petition requesting the matter be presented to the Board; (2) an Board member re quests to hear the matter prior to the time the Commissioner makes a final decision on the permit; or (3) a request for a contested case hearing is pending. Otherwise, the Commissioner will make the decision.
Persons who submit comments or petitions to the MPCA must state (1) their interest in the permit application or the draft permit and proposed SIP revi sion; (2) the action they wish the MPCA to take, including specific references to the section of the dr aft permit and proposed SIP revision they believe should be changed; and (3) the reas ons supporting their position, stated with sufficient specificity as to allow the MPCA to investigate the merits of the position.
As described in Minn. R. 7000.1800, persons who submit requests for a contested case hearing must also state the issues they propose to address in a contest ed case hearing, the specific relief requested or resolution of the matter, and the reasons (which ma y be in the form of proposed findings) supporting an MPCA decision to hold a contested case hearing. Failure to comply with these rules exactly may result in a denial of the request. The decision whether to hold a contested case hearing will be made under Minn. R. 7000.1900. Most public libraries throughout the state have copies of the current Minnesota Rules. They are also available on the Intern et at www.revisor.leg.state.mn.us.
The public comment period for the permit and SIP revision commences February 26, 2010, and terminates March 29, 2010. Comments, including requests for a public meeting, must be received in writing at the MPCA by 4:30 p.m. on March 29, 2010. Evidence of timely receipt includes a date/time stamp imprinted on the first page of the written co mments by the first floor information and reception area of the MPCA or by the Industrial Division or EAO support staff, or receipt by fax or email.
A public information meeting will only be held if one is requested by 4:30 p.m. on March 29, 2010. If such a meeting is requested, it will be held from 3:00 p.m. to 4:00 p.m. on Thursday, April 1, 2010, at the MPCA St. Paul Office, 520 Lafayette Road North, Minnesota. To find out if a public meeting will be held, please call Catherine Neuschler at 651-757-2607, after March 22, 2010. The public information meeting, if one is requested, will provide informati on, receive public input, and answer questions about both the draft/proposed permit and SIP revision. If th e public information meeting is help, additional written comments on the proposed documents will be accepted until 4:30 p.m. on April 15, 2010, following the same guidelines described above.3 

### Comments, requests and petitions should be sent to:
Draft/Proposed Air Emission Permit Amrill Okonkwo, Air Quality Permits Section Industrial Division, Minnesota Pollution Control Agency 520 Lafayette Road North, St. Paul, MN 55155 651-757-2623 – Voice - 651-296-8717 – Fax Amrill.okonkwo@state.mn.us-email SIP Revision Catherine Neuschler EAO Division, Minnesota Pollution Control Agency 520 Lafayette Road North, St. Paul, MN 55155 651-757-2607 – Voice - 651-297-8324 – Fax Catherine.neuschler@state.mn.us-email

A copy of the draft/proposed permit w ill available on the MPCA’s website at http://www.pca.state.mn.us/news/data/index.cfm?PN=1, or will also be mailed to any interested person upon the MPCA's receipt of a written request. Informati on on the SIP revision will be available on the MPCA’s website at http://www.pca.state.mn.us/air/sip.html. Add itional materials relating to the issuance of this permit are available for inspection by appointment at the Minnesota Pollution Control Agency, 520 Lafayette Road North, St. Paul, Minnesota 55155, phone 651-757-2623, between the hours of 8:00 a.m. and 4:30 p.m., Monday through Friday. All MPCA offices may be reached by calling 1-800-657-3864.

DATED: February 9, 2010

Don Smith, P.E., Manager Air Quality Permits Section Industrial Division

### Attachment 6: Completeness Review A. Administrative Materials (40 CFR pt. 51, Appendix V, Part 2.1)

The EPA’s Criteria for Determining the Comple teness of Plan Submittals, published at 40 CFR pt. 51, Appendix V (2001), requires st ates to provide the basic documents that show that the State has properly followed th e administrative requirements called for by the CAA for the adoption of SIPs. The requirements, and how this SIP revision complies with these requirements, are discussed here:

1) Formal Letter of Submittal:

“A formal letter of submittal from the Governor or his designee, requesting EPA approval of the plan or revision thereof.”

Attached to this SIP revision request is a formal letter of submittal from the MPCA Commissioner, Paul Eger, to the Acting EPA Re gion V Administrator, Bharat Mathur. The office of the Commissioner of the MPCA is statutorily created at Minnesota Statute § 116.03, subd. 1 (a) (2000). The Commissioner is appoin ted by the Governor, and the duties of the position include acting as the state agent to “apply for, receive, and disburse federal funds made available to the state by federa l law or rule and regulations promulgated thereunder for any purpose related to the power and duties of the MPCA or the Commissioner. The Commissioner shall comply with any and all re quirements of such federal law or such rules and regulations promulgated thereunder to facilitate application fo r, receipt, and disbursement of such funds.” Minn. Stat. § 116.03 subd. 3 (2000).

2) Evidence of State Adoption of Plan and Issuance of Orders in Final Form

“Evidence that the State has adopted the plan in the State code or body of regulations; or issued the permit, order, consent agreement (hereafter ‘document’) in final form. That evidence shall include the date of adoption or fi nal issuance as well as the effective date of the plan, if different from the adoption/issuance date.”

Attachment 1 contains the joint Title I/FESOP document, which consists of Air Emission Permit No. 00300245-001, which includes relevant SIP condi tions, labeled “Title I Condition: SIP for SO2 NAAQS.” This Air Emission Permit became e ffective at the state level as soon as it was signed. All Title I conditi ons are non-expiring.

3) Legal Authority Documentation:

“Evidence that the State has the necessary le gal authority under St ate law to adopt and implement the plan.”

This SIP revision request is based on the MPCA’s Twin Cities Area SO 2 

### SIP submitted on May 29, 1992 and updated July 12, 1993, which containe d an Administrative Order for United Defense, LP. In December 2002, the MPCA submitted United Defense’s Air Emission Permit No. 00300020–00, issued November 25, 2002, as a joint document containing SIP conditions to

### replace the Order. EPA approved this join t document into Minnesota’s SIP on August 18, 2004 (69 FR 51181).

Appendix C of the original May 1992 submittal documents MPCA’s legal authority to adopt ambient air quality standards for SO 2 

### , issue orders to sources to control their emissions, and to enforce those rules and orders.

On May 2, 1995, EPA approved MPCA’s revised ope rating permit program as a SIP revision (60 FR 21447). MPCA submitted the operating permit progr am for inclusion in the SIP in part so that permits issued under the program could be considered federally enforceable vehicles for imposing emissions limitations on culpable sources located in nonattainment areas.

EPA’s conclusion that MPCA has the authority to issue permits with non-expiring Title I SIP conditions in order to replace Admi nistrative Orders has been further documented in an April 4, 1997 letter from Michael Sandusky of the MPCA to David Kee of EPA Region 5, a July 3, 1997 letter from David Kee of EP A Region 5 to Michael Sandusky of the MPCA and in a June 15, 2006 letter from Jay Bortzer of EPA Region 5 to David Thornton of the MPCA. Copies of these letters have been submitted with previous SIP revisions.

4) Compliance with State Procedures:

“Evidence that the state followed all of the pr ocedural requirements of the State’s laws and constitution in conducting and completi ng the adoption/issuance of the plan.”

MPCA complied with all relevant state procedures for issuing the permit as well as the SIP revision.

5) Public Notice:

“Evidence that public notice was given of the pr oposed change consistent with the procedures approved by the EPA, including the date of the publication of the notice.”

The public notice for the permit and associated SIP revision was published in the St. Paul Pioneer Press on February 17, 2010, with the pub lic comment period commencing on February 26, 2010 and ending on March 29, 2010. During the public comment period, a copy of the permit and SIP revision request was made availabl e at the MPCA office lo cated in St. Paul and on the MPCA’s website. A copy of the public notice is a ttached. (Attachment 5).

6) Public Hearing Certification

“Certification that public hearin g(s) were held in accordance w ith the information provided in the public notice and the State’s laws and constitution, if applicable.” The public notice states: “A public information m eeting will only be held if one is requested during the public comment period. If such a meeting is requested, it will be held from 3:00 pm to 4:00 pm on Thursday, April 1, 2010, at the MPCA St. Paul Office, 520 Lafayette Road North, Minnesota. To find out if a public meeting will be held, please call Catherine Neuschler at 651-

### 757-2607, after the close of the public comment period. The public information meeting will provide information, receive public input, and an swer questions about both the proposed permit and SIP revision.”

No public meeting was requested.

7) Public Comments and State Response:

“Compilation of the public comments and State’s response thereto.”

No public comments were received on the SIP or the proposed permit.

B. Technical Support:

1) Pollutants Regulated:

“Identification of all regulated po llutants affect by the plan.”

The regulated pollutant subject to this SIP revision request is SO 2


### .
2) Source Identification

“Identification of the locations of affected so urces including the EPA attainment/nonattainment designation of the locations and the state of the Attainment Pl an for the affected area(s).”

The affected source within the former Twin Cities SO 2 

### nonattainment area is ELT Minneapolis, LLC, River Road Industrial. Further informati on on the facility is incl uded in the attached Technical Support Document.

3) Emissions Quantification:

“Quantification of the changes in the plan; allowable emission s from the affected sources; estimates of changes in current actual emissions from affected sources or, where appropriate, quantification of the cha nges in actual emissions through calculations of the differences between certain baseline levels and allowable emissions anticipated as a result of the revision.”

The changes allowed in this SIP revision do not impact overall emissions from the facility.

4) NAAQS Protections:

“The State’s demonstration that the NAAQS, prevention of signifi cant deterioration increments, reasonable further progress demonstration, and visibi lity, as applicable, are protected if the plan is approved and implemented.”

Because the SIP revision does not allow any incr ease in emissions, the facility impact on the NAAQS will not change.

### 5) Modeling Information

“Modeling information required to support the proposed revision, including input data, output data, models used, justification of the mode l selections, ambient monitoring data used, meteorological data used, justifi cation for use of off-site data (where used), modes of models used, assumptions, and other information relevant to the determination of adequacy of the modeling analysis.”

Modeling was not done because there were not changes at the facility.

6) Continuous Emission Reduction

“Evidence, where necessary, that emission limitations are based on continuous emission reduction technology.”

These requirements are included in the permit and joint Title I/Title V document issued to the source. This document is attached as Attachment 1.

7) Emission Level Assurance

“Evidence that the plan contains emissi on limitations, work practice standards and recordkeeping/requirements, where nece ssary, to ensure emissions levels.”

Again, the above requirements are addressed in th e permit and joint Title I/Title V document as shown in Attachment 1.

8) Compliance/Enforcement

“Compliance and enforcement strategies, incl uding how compliance will be determined in practice.”

The above requirements are addressed in the perm it and joint Title I/Title V document as shown in Attachment 1.

9) Special Economic and Tec hnological Justifications:

“Special economic and technological justifications required by a ny applicable EPA policies, or an explanation of why such justifications are not necessary.”

This requirement does not apply to this submittal.

Conclusion

The MPCA expects that the Twin Cities ar ea will remain in compliance with the SO 2 

### NAAQS.