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

REC'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 ofMinnesota's SIP for

particulate matter (PMIO) 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 PMIO" replace the current SIP conditions for the facility.

The second revision concerns the United Defense facility, part ofMinnesota'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 ofthe 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 ofthe 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 Industrial 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 Industrial Facility (ELT) at 4800 River Road in Fridley, Anoka 

County, Minnesota. This facility is included in Minnesota’s SIP for sulfur dioxide (SO2). 

Reasons for Changes and Placing Applicable Conditions into 

Joint Title I/FESOP Document 

ELT owns and operates boilers and emergency generators. 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 SO2 SIP for the Twin Cities area currently includes Title I SIP conditions for these 

boilers and generators. Those Title I SIP conditions are found in Air Emission Permit No. 

00300020-003, issued to United Defense, LP in November 2002. In August 2004, EPA 

published a direct final notice approving the Title I SIP conditions into Minnesota’s SIP (69 FR 

51181). 

However, EPA’s notice describes the incorporated joint document as Air Emission Permit No. 

00300020-001. It appears that the cover page to the incorporated joint document listed the 

permit with this number, although the MPCA’s permit 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 document. It also accounts for the change in ownership 

of the facility, and some changes in how the emissions units and groups are described. Boilers 1, 

2, and 3 were listed in the joint document issued 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 SV002. Similar changes were made for the 

emergency generators. The changes are further described in Attachment 4. 

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 is requesting 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 substantive changes to the SIP conditions. All fuel 

restrictions and SO2 emission limits that apply to the boilers and emergency generators remain 

the same as those currently approved into the SIP. 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. 
 

2

No new authorizations are part of this SIP revision, and 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 document, 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 Neuschler, 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 FacilityOperating Permit 

IS ISSUED TO 

,ELT 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, AirEmission Permit No.00300245-001, authorizes the Permittee to operate the stationary 

source at the address listed abQve unless otherwise notedin 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. 7007r.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 ofthe 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 (802) 

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 ofthe Clean Air Act. ' 

....... ..... .

. ' .' . 

, ~?''-;'''-I¥~:::lJ~f-''-'-'------- Jr,,' nager........ 

Air QualityPeimits Section 

Industrial Division 

"for PaulEger 

, Commissioner 

Minnesota Pollution Control Agency', '. 

"TDD (for hearing and speechimpaired only): (651)282-5332 

Printed on recycledpaper containing atleast 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 (SO2) 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 provision of the applicable requirement identified 

in the permit as the basis of each condition. Subject to the limitations of Minn. R. 7007.1800, 

and 7017.0100, subp. 2, notwithstanding the conditions of this permit specifying compliance 

practices for applicable requirements, any person (including the Permittee) may also use other 

credible evidence to establish compliance or noncompliance with applicable requirements. 
FACILITY DESCRIPTION: 

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 SO2 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 SO2 and nitrogen oxides (NOx). The permit limits 

the emissions of the facility such that the facility 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

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

ACTIVITIES 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

ACTIVITIES REQUIRING A MODIFICATION TO THE SIP:

Activities 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

Annual 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 hdr
TABLE 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.

At the time of notification, the owner or operator shall inform the Commissioner of

the cause of the shutdown and the estimated duration. The owner or operator shall

notify the Commissioner when the shutdown is over.

Minn. R. 7019.1000, subp. 3

Breakdown Notifications: Notify the Commissioner within 24 hours of a breakdown

of more than one hour duration of any control equipment or process equipment if

the breakdown causes any increase in the emissions of any regulated air pollutant.

The 24-hour time period starts when the breakdown was discovered or reasonably

should have been discovered by the owner or operator. However, notification is not

required in the circumstances outlined in Items A, B and C of Minn. R. 7019.1000,

subp. 2.

At the time of notification or as soon as possible thereafter, the owner or operator

shall inform the Commissioner of the cause of the breakdown and the estimated

duration. The owner or operator shall notify the Commissioner when the breakdown

is over.

Minn. R. 7019.1000, subp. 2

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

Application for Permit Amendment: If a permit amendment is needed, submit an

application in accordance with the requirements of Minn. R. 7007.1150 through

Minn. R. 7007.1500. Submittal dates vary, depending on the type of amendment

needed.

Minn. R. 7007.1150 - 7007.1500
TABLE 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 - 7002.0095
TABLE 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. 7017.2015
TABLE 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. 5
TABLE 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. 35a
APPENDIX II: 

Facility Name: River Road Industrial Center 

Permit Number: 00300245-001 

Title I Condition: State Implementation Plan (SIP) for SO2 National Ambient Air Quality Standards (NAA

SO2 Modeling Parameters Relied Upon to Demonstrate Compliance with NAAQS 

Source Name Emission 

Unit 

Number 

SV ID Stack 

Height 

(feet) 

Stack 

Height 

(m) 

Stack 

Dia. 

(feet) 

Stack 

Dia. 

(m) 

Stack 

Velocit

y 

(m/s) 

Exit 

Temp 

(F) 

Modeled and 

Maximum Heat 

Input 

(million Btu/hr) 

Flo

(A

Boiler 1 001 001 140 43 7.0 2.1 3.9 325 69.8 2Boiler 2 & 3 002 

003 

002 140 43 8.5 2.4 1.8 325 69.8 & 35.1 1

Standby GeneratorSub 3(w) and 3(e) 

005 006 

004 005 

36 11 0.59 0.18 58 440 2.96 

2.96 

Standby Generator –Sub 1 007 006 24 7.3 0.59 0.18 55 440 

3.46 

Standby Generator –Boiler and Bdg 37 

008 007 29 8.8 0.49 0.15 48 440 2.1 
 

Attachment 2: Permit technical support document 

 
Technical 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 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 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 reach attainment of sulfur dioxide (SO2) 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 SO2 and nitrogen oxides (NOx). The permit limits 

the emissions of the facility such that the facility 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). 

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, PM10 is assumed to be a conservative estimate of PM2.5. 

1.4 Permit History

Permit Number and 

Issuance Date

Action Authorized

SO2 Administrative Order for 

the State Implementation Plan 

(SIP) 

 The emission limits, the operating restrictions, and 

requirements to demonstrative compliance for SO2 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 

PM10

tpy 

PM2.5

tpy 

SO2

tpy 

NOx

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 

inventory 
Technical 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 SO2 PM, PM10, PM2.5, 

CO, NOx, VOC 

Part 70 Permit Program NOx, SO2 PM, PM10, PM2.5, 

CO, VOC 

Part 63 NESHAP HAP 

2. Regulatory and/or Statutory Basis

New Source Review

The 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 facility 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 be 
Technical 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, SO2 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 SO2 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 SO2 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 SO2 from 

the boilers to less than significant as defined by 40 CFR § 

52.21 

EU 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 SO2 (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 SO2 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 responsibility of the owner or operator of a facility 

to have sufficient knowledge of the facility to certify that the facility is in compliance with all 

applicable requirements. 

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

• The likelihood of violating the applicable requirements; 

• Whether add-on controls are necessary to meet the emission limits; 

• The variability of emissions over time; 

• The type of monitoring, process, maintenance, or control equipment data already 

available for the emission unit; 

• The technical and economic feasibility of possible periodic monitoring methods; and 

• The kind of monitoring found on similar units elsewhere. 

Table 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 due 
Technical 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. SO2: 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 

SO2: 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 necessary 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 FacilityOperating Permit 

IS ISSUED TO 

,ELT 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, AirEmission Permit No.00300245-001, authorizes the Permittee to operate the stationary 

source at the address listed abQve unless otherwise notedin 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. 7007r.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 ofthe 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 (802) 

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 ofthe Clean Air Act. ' 

....... ..... .

. ' .' . 

, ~?''-;'''-I¥~:::lJ~f-''-'-'------- Jr,,' nager........ 

Air QualityPeimits Section 

Industrial Division 

"for PaulEger 

, Commissioner 

Minnesota Pollution Control Agency', '. 

"TDD (for hearing and speechimpaired only): (651)282-5332 

Printed on recycledpaper containing atleast 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 (SO2) 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 provision of the applicable requirement identified 

in the permit as the basis of each condition. Subject to the limitations of Minn. R. 7007.1800, 

and 7017.0100, subp. 2, notwithstanding the conditions of this permit specifying compliance 

practices for applicable requirements, any person (including the Permittee) may also use other 

credible evidence to establish compliance or noncompliance with applicable requirements. 
FACILITY DESCRIPTION: 

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 SO2 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 SO2 and nitrogen oxides (NOx). The permit limits 

the emissions of the facility such that the facility 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

ACTIVITIES 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

ACTIVITIES REQUIRING A MODIFICATION TO THE SIP:

Activities 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

Annual 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 hdr
TABLE 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 SIP
TABLE 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 SIP
APPENDIX II: 

Facility Name: River Road Industrial Center 

Permit Number: 00300245-001 

Title I Condition: State Implementation Plan (SIP) for SO2 National Ambient Air Quality Standards (NAA

SO2 Modeling Parameters Relied Upon to Demonstrate Compliance with NAAQS 

Source Name Emission 

Unit 

Number 

SV ID Stack 

Height 

(feet) 

Stack 

Height 

(m) 

Stack 

Dia. 

(feet) 

Stack 

Dia. 

(m) 

Stack 

Velocit

y 

(m/s) 

Exit 

Temp 

(F) 

Modeled and 

Maximum Heat 

Input 

(million Btu/hr) 

Flo

(A

Boiler 1 001 001 140 43 7.0 2.1 3.9 325 69.8 2Boiler 2 & 3 002 

003 

002 140 43 8.5 2.4 1.8 325 69.8 & 35.1 1

Standby GeneratorSub 3(w) and 3(e) 

005 006 

004 005 

36 11 0.59 0.18 58 440 2.96 

2.96 

Standby Generator –Sub 1 007 006 24 7.3 0.59 0.18 55 440 

3.46 

Standby Generator –Boiler and Bdg 37 

008 007 29 8.8 0.49 0.15 48 440 2.1 
 

Attachment 4: Marked up United Defense currently approved joint document 

 
1
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 -001

1

2345

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 Quality Standards (NAAQS) for sulfur dioxide (SO2). 

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 operating permit. Title I conditions associated with the SIP 

are considered applicable requirements; therefore, 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 State 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 SO2. 

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 will 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 PM10 PM2.5 SO2 NOx VOCs CO HAP 

Total Facility PTE 20 20 20 42 90 5.4 69 1.4 

 PM = Particulate Matter PM10 = PM smaller than 10 microns 

 PM2.5 = PM smaller than 2.5 microns SO2 = Sulfur Dioxide 

NOx = 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 SO2 emission limits already 

included in the SIP. Therefore, the MPCA believes this action will not have an adverse impact on 

compliance with the NAAQS for SO2. 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 SIP/Title V document. These Title I conditions do 

not expire. 

After its issuance, this permit will be submitted to the 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 the time that EPA accepts this permit as part of the 
2 

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 emission permit and submit the SIP revision is tentative. 

There are four formal procedures for public participation 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 meeting; (3) request the MPCA hold a contested case 

hearing; and/or (4) submit a petition to the Commissioner 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 Commissioner grants the petition requesting the matter be 

presented to the Board; (2) an Board member requests 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 revision; (2) the action they wish the MPCA to take, 

including specific references to the section of the draft permit and proposed SIP revision they believe 

should be changed; and (3) the reasons 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 contested case hearing, the specific relief requested or 

resolution of the matter, and the reasons (which may 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 Internet 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 comments 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 information, receive public input, and answer questions about 

both the draft/proposed permit and SIP revision. If the 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 will 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. Information on the SIP revision will be available on the MPCA’s 

website at http://www.pca.state.mn.us/air/sip.html. Additional 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 Completeness of Plan Submittals, published at 40 CFR 

pt. 51, Appendix V (2001), requires states to provide the basic documents that show that the 

State has properly followed the 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 Region 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 appointed 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 federal 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 requirements of such federal law or such rules and regulations 

promulgated thereunder to facilitate application for, 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 final 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 conditions, labeled “Title I Condition: SIP for 

SO2 NAAQS.” This Air Emission Permit became effective at the state level as soon as it was 

signed. All Title I conditions are non-expiring. 

3) Legal Authority Documentation: 

“Evidence that the State has the necessary legal authority under State law to adopt and 

implement the plan.” 

This SIP revision request is based on the MPCA’s Twin Cities Area SO2 SIP submitted on May 

29, 1992 and updated July 12, 1993, which contained 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 joint 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 SO2, issue orders to sources to control their emissions, and to 

enforce those rules and orders. 

On May 2, 1995, EPA approved MPCA’s revised operating permit program as a SIP revision (60 

FR 21447). MPCA submitted the operating permit program 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 Administrative 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 EPA 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 procedural requirements of the State’s laws and 

constitution in conducting and completing 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 proposed 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 public 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 available at the MPCA office located in St. Paul and 

on the MPCA’s website. A copy of the public notice is attached. (Attachment 5). 

6) Public Hearing Certification 

“Certification that public hearing(s) were held in accordance with the information provided in 

the public notice and the State’s laws and constitution, if applicable.” 

The public notice states: “A public information meeting 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 answer 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 pollutants affect by the plan.” 

The regulated pollutant subject to this SIP revision request is SO2. 

2) Source Identification 

“Identification of the locations of affected sources including the EPA attainment/nonattainment 

designation of the locations and the state of the Attainment Plan for the affected area(s).” 

The affected source within the former Twin Cities SO2 nonattainment area is ELT Minneapolis, 

LLC, River Road Industrial. Further information on the facility is included in the attached 

Technical Support Document. 

3) Emissions Quantification: 

“Quantification of the changes in the plan; allowable emissions from the affected sources; 

estimates of changes in current actual emissions from affected sources or, where appropriate, 

quantification of the changes 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 significant deterioration increments, 

reasonable further progress demonstration, and visibility, as applicable, are protected if the plan 

is approved and implemented.” 

Because the SIP revision does not allow any increase 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 model selections, ambient monitoring data used, 

meteorological data used, justification 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 emission limitations, work practice standards and 

recordkeeping/requirements, where necessary, to ensure emissions levels.” 

Again, the above requirements are addressed in the permit and joint Title I/Title V document as 

shown in Attachment 1. 

8) Compliance/Enforcement 

“Compliance and enforcement strategies, including how compliance will be determined in 

practice.” 

The above requirements are addressed in the permit and joint Title I/Title V document as shown 

in Attachment 1. 

9) Special Economic and Technological Justifications: 

“Special economic and technological justifications required by any 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 area will remain in compliance with the SO2 NAAQS.