# • 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 TIV 

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



## July 29, 2010
Ms. Susan Hedman Regional Administrator (R-19J) U.S. Environmental Protection Agency Region V 77 West Jackson Boulevard Chicago, Illinois 60604

RE: Proposed Amendment to Minnesota's State Implementation Plan for Lead

Dear Ms. Hedman:
The Minnesota Pollution Control Agency (MPCA) hereby submits to the U.S. Environmental Protection Agency (EPA) a request for revision of Minnesota's State Implementation Plan (SIP).
The revision concerns Gopher Resource, LLC, part of Minnesota's SIP for lead in Dakota County. Minnesota's SIP currently includes an Administrative Order issued to the facility (then known as Gopher Smelting and Refining), which contains emission limits and other conditions necessary to attain the National Ambient Air Quality Standard. The MPCA hereby submits Air Emission Permit No. 03700016- 003 as a joint Title I/Title V document, and requests that the conditions labeled "Title I Condition: SIP for Lead" replace the Administrative Order as the enforceable SIP conditions for the facility.
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,

# ,?~~-ePaul Eger Commissioner
PE/CN:sth
Enclosures

cc: Kathleen 

## 0' Agostino, EPA Region V (with enclosures) 

# RECEIVED 

# AUG**O~** 

# 2010

l.

... 

### OFFICE OHEGJONALADMJIS i 

### Kill O!?

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

# Background Information for SIP Revision Gopher Resource, LLC, Eagan, MN This document provides background informa tion on the State Implementation Plan (SIP) revision for the Dakota County lead maintenance area. Gopher Resource, LLC (formerly known as Gopher Smelting and Refining Company), loca ted at 3385 South Highway 149 in Eagan, is the only culpable source in the lead maintenance area. The subject area of Dakota Count y was designated as non-attainme nt with the primary lead National Ambient Air Quality Standard (NAAQS) of 1.5 μ g/m 3 

# on January 6, 1992. The U.S. Environmental Protection Agency (EPA) granted approval of a SIP revi sion and redesignation request on October 18, 1994 (50 FR 52531). The revision included an Administrative Order (Order) containing emission limits and other requi rements for Gopher, which ensured attainment with the NAAQS. On November 18, 2002, the MPCA submitted a SI P revision including a maintenance plan update for the area and a request for a change in enforceable document for Gopher, from the Order to a joint Title I/Title V doc ument. EPA did not act on this submittal due to concerns that the joint document did not contain some necessa ry requirements. On November 19, 2007, the MPCA formally withdrew the request to replac e the Order with the joint document, but asked that EPA consider the maintenance plan update. On June 3, 2008, EPA pub lished a direct final approval of the maintenance plan (73 FR 31614). On November 12, 2008 (73 FR 66964), EPA published a final rule revising the NAAQS for lead. The new NAAQS is 0.15 μ g/m 3 

# . In October 2010, EPA will designa te areas as in attainment or non-attainment with the new NAAQS. It is quite likely that the area surrounding Gopher Resource will be designated non-a ttainment with the new standa rd. However, the current NAAQS of 1.5 μ g/m 3 

# , remains in effect until one year afte r the designations for the new standard are finalized. Therefore, the MPCA is submitting this SIP revision under the maintenance requirements for the 1978 NAAQS. Minnesota houses the conditions necessary to atta in and maintain the NAAQS in facility permits, denoting the required SIP conditions with the no tation “Title I Condition: SIP for <pollutant> NAAQS.” The permit then serves as a join t Title I/Title V document, with conditions established under both Minnesota’s Clean Air Act Title I authority and Title V permitting authority. The MPCA and EPA are now in agreement as to what is required to be included in a joint document in order to allow the joint document to re place the existing Order. Therefore, in this SIP revision, the MPCA is submitting the Title V permit for Gopher Resource, LLC, to serve as a joint Title I/Title V document and replace the ex isting administrative order for the facility. This SIP revision is being submitted in conjunction with reissuance of the facility’s operating permit (Air Emission Permit No. 03700016-003). Th e permit and its technical support document (TSD) provide information on Gopher’s operations. This document concentrates on the relevant changes to the facility’s T itle I SIP conditions for lead.

# Reason for SIP Revision This SIP revision is being submitted to update the f acility’s enforceable document in the SIP, in conjunction with reissuance of the facility’s Titl e V operating permit. The reissuance of the Title V operating permit does not allow for any new emi ssion units or any increase in emissions from the facility’s operations. MPCA had previously submitted Air Emission Permit No. 03700016-001 as a SIP revision, with a request to replace the Order with that join t document. However, that SIP revision was withdrawn by the MPCA. The MPCA is awar e that EPA had several concerns about the previous permit, particularly in regards to reco rdkeeping and contingency measure requirements. In drafting this joint documen t (Air Emission Permit No. 03700016-003), the MPCA has ensured that those recordkeeping and con tingency plan requirements from the original Order have been included in the joint document. Changes Made in this SIP Revision Compared to the Administrative Order currentl y approved in the SIP, however, some changes have been made. The facility name has been updated to Gopher Resource, LLC. General SIP conditions, such as those that describe when f acility changes require a SIP revision, have been reworded or clarified to fit w ith the MPCA’s current format fo r such conditions. SIP conditions where the facility was originally offered a ch oice of multiple compliance options have been updated to document the compliance choice made by Gopher Resource. In addition, the joint document organizes and names em ission units differently than in the original Order. Some changes have also been made to supporting SIP requirements, such as the requirement for annual stack emission testing. This requirement has been changed to be consistent with the testing requirement for the National Emissi ons Standards for Hazardous Air Pollutants (NESHAP) program. The NESHAP a llows facilities with lead emissions less than a certain threshold to move to biannual stack testing. Si nce the NESHAP lead limit is more restrictive than the SIP lead limit, and Gopher Resource’s emissions are well below the threshold allowing biannual testing for the purpose of the NESHAP, the MPCA believes that this is an appropriate change that will not affect the stringency of the SIP. A few more substantial changes have been made to emission units. Some emission units or processes have been removed, such as the flue agglomeration. Some additional emission units have added – for instance, the facility now has 10 refining kettles rather than the six refining kettles listed in the Order and approved in the current SIP. However, the SIP-approved emission limits on the stacks have been maintained. Ther efore, although specifics of the emission units have changed, overall emissions from the facility have not changed. The reissuance of the Title V permit does not add a ny emission units at the facility, compared to current operations, and the SIP revision does not request any changes to the emission limits allowed from the facility. However, this SIP revision does account for some new emission units, as described above, and two new baghouses and a new stack at the facility. A SCREEN3 analysis was done to show that these additions do not negatively affect the modeled compliance with the lead NAAQS.

# The facility as described in the Administrative Order was modeled to be in compliance with the lead NAAQS of 1.5 μ g/m 3 

# . The following are the modeled parameters:
Parameter Main Stack (SV003) 1 

## Existing Torit Stack (SV002) 2 

## Stack Height (ft) 199 80 Stack Diameter (ft) 6 8 Exhaust Temp (° F) 154 68

Flow Rate (acfm) 119000 166000 

# Gopher is adding a second Torit stack (SV008) and two additional Torit dust collectors, collecting fugitive lead emissions from raw ma terial handling, the battery breaking dock, material transfer rooms, and the furnace areas ; these dust collectors wi ll exhaust to the new SV008. The purpose of these dust colle ctors is to control dust that was observed to “leak” from various points, dust that had been assumed to be going to the existing Torit stack (SV002). Thus, there will be no new emissions resulting from the addition of SV008. Rather, the permitted emissions that before were assumed to all be going to SV002 will now be split between SV002 and SV008. Exactly how much is going to each st ack is not known. There will be no effect on the emissions of SV003. To show that the addition of SV008 (which will emit some fraction of the emissions previously modeled at SV002) does not have a negative impact on the modeled concen tration of ambient lead, EPA’s screen modeling application S CREEN3 was used to model 3 scenarios: Scenario 1: The permitted (and allowed by the Admini strative Order) lead emissions were modeled from SV002, using the stack paramete rs from the original Title V permit. Scenario 2: The same permitted (and allowed by th e Administrative Order) lead emissions were modeled from the new SV008 instead of SV002, using SV008 parameters provided by Gopher. Scenario 3: A reduced lead emission rate (emissi ons limited by NESHAP Subpart X, which was not in effect at the time of development of the Administrative Order, but will apply to SV008, and in fact applies to SV002 at this time) was modeled from SV008, using stack parameters provided by Gopher. The results of the SCREEN3 analysis showed that the addition of SV008 will not result in negative ambient impacts. The same mass emissi on rate, when modeled from SV008 instead of SV002, resulted in lower modeled maximum ambien t impacts. As the modeled impacts from SV002 using refined modeling tools (rather than a screening model) show attainment with the applicable lead NAAQS, and the SCREEN3 impact s from the new stack (SV008) are less than the SCREEN3 impacts from SV002, the impact of adding SV008 would not cause a violation of the NAAQS. In addition, Gopher Resources was modeled as pa rt of the MPCA’s 2010 Source-oriented Lead Monitoring Plan for Minnesota. That modeling, reviewed by the MPCA, demonstrated that the area of maximum impact, on a monthly average level, is 0.78 μg/m 3 

# , clearly below the 1.5 μg/m 3

1 

## This stack was described as Emission Point/Stack 1 in the Administrative Order 2 

## This stack was described as Emission Po int/Stack 3 in the Administrative Order.

# level of the 1978 standard. This modeling incl uded a preliminary characterization of the emissions from the new Torit stack.

Adding this stack, without adding any emissi ons, is likely to result in lower ambient concentrations. Monitoring data around the facility has consiste ntly indicated compliance with the 1978 standard. Therefore, the MPCA is confiden t that this SIP revision will allow the area to continue to attain the existing NAAQS of 1.5 μ g/m 3



# .

# Attachments to Background Document Attachment 1: Permit No. 03700016-003; joint Title I/Title V document Attachment 2: Permit No. 03700016-003 technical support document Attachment 3: Permit No. 03700016-003; Title I SIP conditions only Attachment 4: Marked up Administrative Order Attachment 5: Rescission of Administrative Order Attachment 6: Public notice Attachment 7: Completeness Review
This summary was prepared by Catherine Neus chler, Environmental Analysis and Outcomes Division of the MPCA.

# Attachment 1: Permit No. 03700016-003; joint Title I/Title V document

## AIR EMISSION PERMIT NO. 03700016-003
IS ISSUED TO 

# Gopher Resource, LLC
GOPHER RESOURCE, LLC 3385 South 

# Highway 149 

# Eagan, Dakota County, MN 55121

The emission units, control equipment and emission stacks at the stationary source authorized in this permit are as described in the Permit Applications Tab]e: This permit supersedes Air Emission Permit No. 037000]6-002, and authorizes the Permittee to operate and modify the stationary source at the address listed above unless otherwise noted in Tab]e A. The Permittee must comply with aU the conditions of the permit. Any changes or modifications to the stationary source must be performed in compliance with Minn. R. 7007.1150 to 7007.1500. Any additions or changes to conditions incorporated into Minnesota's State Imp]ementation Plan (SIP) under 40 CFR § 52.1220, designated "Title I: SIP for Lead" must go through the federal SIP approval process before becoming effective. Terms used in the permit are as defined in the state air pollution control rules unless the term is

, explicitly defined in the permit.

Unless otherwise indicated, a]] the Minnesota rules cited as the origin of the permit terms are incorporated into the SIP under 40 CFR 

## § 52.1220, and as such as are enforceable by U.S. Envirorimental Protection Agency (EPA) Administrator or citizens under the Clean Air Act. 

## Permit Type: Federal; Pt 70lIncorporates Existing NSR Conditions; Title I SIP Conditions for Lead 

## Operating Permit Issue Date: 

## June 29. 2010 Expiration Date: 

## June 29. 2015 All Title I Conditions do not expire. Each new or revised condition designated "Title I Condition: SIP for Lead" is not effective or enforceable until approved by EPA as a SIP revision under Title I of the Clean Air Act.

# ~jty11.A**\%'(Al~** 

# 'icrDon Smith, P .E., Manager Air Quality Permits Section Industrial Division

for Paul Eger Commissioner Minnesota Pollution Control Agency

TDD (for hearing and speec;h 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-Reissuance 2/16/2007 003

TABLE OF CONTENTS

Notice to the Permittee
Permit Shield Facility Description
Table A: Limits and Other Requirements
Table B: Submittals
Table C: not used in this permit Appendix A: not used in this permit Appendix B: Parameters Relied Upon in Modeling Appendix C: Insignificant Activities and Applicable Requirements Appendix D: Smelting Raw Material Warehouse and Process Side of the Raw Material Processing Area Appendix E: Areas of the Building Under Negative Pressure Appendix F: Fence/Gate Map Appendix G: SIP-Required Testing and Maintenan ce of Pressure Drop Gauges and Broken Media Detectors and Alarm Response Procedures Appendix H: SIP-Required Negative Pressure System Testing Appendix I: SIP-Required Smoke Testing Methodology for Negative Pressure System Testing Appendix J: Paved Areas Appendix K: Maintenance Plan for Baghouses and Cartridge Filters

# NOTICE TO THE PERMITTEE: Your stationary source may be subject to the requi rements 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 Lafa yette Road North, St. Paul, Minnesota 55155-4194. Questions about this air emission permit or about ai r 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, complia nce 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 specifyi ng compliance practices for applicable requirements, any person (including the Permittee) may also use ot her credible evidence to establish compliance or noncompliance with applicable requirements.



# FACILITY DESCRIPTION: Gopher Resource, LLC (Gopher) owns and operates a secondary lead smelter facility located at 3385 South Highway 149, Eagan, Dakota County, Minnesota. The facility includes the following four major operations and miscellaneous sources: scrap pret reatment, smelting, refining and casting. Lead is recovered from lead-acid batteries, scrap from batte ry manufacturing plants, and miscellaneous lead bearing materials. The recovered lead is refined into alloys that are sold to a variety of customers. The main emissions from Gopher Resource Corp are Carbon Monoxide (CO); Particulate Matter (PM), including Particulate Matter less than 10 microns (PM 10 

## ) and Particulate Matter less than 2.5 microns (PM 2.5 

## ); Nitrogen Oxide (NO x 

## ), Sulfur Dioxide (SO 2 

## ) and Lead. Gopher is subject to the provisions of an administrative order, as amended on September 13, 1994. This was incorporated into Minnesota’s State Implem entation Plan (SIP), through the October 18, 1994, Federal Register. Gopher must comply with the pr ovisions of the administrative order as a condition of compliance with the National Ambient Ai r Quality Standards (NAAQS) for lead. This permit includes all of the provisions of the ad ministrative order, and upon inclusion in Minnesota’s SIP, will replace the administrative order.

## On October 15, 2008, the NAAQS for lead was changed from 1.5 μ g/m 3 

## to 0.15 μ g/m 3 

## . By October 15, 2009, The MPCA was required to submit to EPA, by Octobe r 15, 2009. a request for designation of areas of the State, including the area around Gopher, as either in atta inment or nonattainment (or unclassifiable) with the lead NAAQS based on monitoring data for 2006 through 2008. EPA must now formally designate the area as either in attainment or nonattainment with the revised standard by October 15, 2010. If the designation is "nonattainment," MPCA must work with Gopher to deve lop a plan for achieving attainment with the revised standard. The State Implementation Plan is due 18 months after final designation by EPA. States with nonattainment areas will be required to attain the standard as 'expeditiously as practicable', but no later than five years from the effective date of the nonattainme nt designation (October 2015). Gopher is already taking steps toward meeting the revised standard; this permit incorporates two additional fabric filters that are used to collect additional fugitive lead emissions.

## TABLE A: LIMITS AND OTHER REQUIREMENTS 06/29/10 Gopher Resource LLC 03700016 - 003 Facility Name: Permit Number: A-1

Table A contains limits and other requirements with which your facility must comply. The limits are located in the first column 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 STATE IMPLEMENTATION PLAN (SIP) REQUIREMENTS hdr For any changes that affect any modeled parameter or lead emission rate documented in Appendix B, the Permittee shall demonstrate that the lead dispersion characteristics following the change will be equivalent to or better than the lead dispersion characteristics modeled using the parameters in Appendix B. The information submitted must include stacks, locations and dimensions of nearby buildings, the velocity and temperature of the gasses emitted, and the lead emission rates. If the information does not demonstrate equivalent or better dispersion characteristics, or if such a conclusion cannot be readily made, the Permittee must remodel. Any increase in lead emissions beyond modeled conditions associated with emission units in the SIP shall also be modeled. Modeling shall be conducted at the new predicted lead emission rates and stack parameters to determine the impact on the lead NAAQS. This requirement applies whether or not a permit amendment is required for the proposed change. Title I Condition: State Implementation Plan (SIP) for Lead NAAQS; 40 CFR pt. 50; 40 CFR pt. 51; 40 CFR pt. 52, subp. Y; MN SIP

A CTIVITIES NOT REQUIRING A MODIFICATION OF THE SIP: The Permittee may make changes to the facility without obtaining a modification as long as the change does not do or result in any of the following:
A . an exceedance of the limitations associated with the emission units in the SIP; B. a physical change of the equipment that affects the stack parameters described in Appendix B; or C. an increase of a maximum potential lead emission rate by less than or equal to 0.025 pound per hour for any installation, modification, or operation of lead process or control equipment. The Permittee may replace, install and operate additional CEMs and CMS, so long as the new or replaced CEMs and CMSs are properly certified and comply with Minn. R. 7017.1002 - 1220. Title I Condition: State Implementation Plan (SIP) for Lead NAAQS; 40 CFR pt. 50; 40 CFR pt. 51; 40 CFR pt. 52, subp. Y; MN SIP

A CTIVITIES REQUIRING A MODIFICATION OF THE SIP: A . any modification to the design of the equipment that decreases the stack gas volumetric flow rate below that contained in Appendix B; B. any modification to the design of the equipment that decreases the stack gas exit temperature below that contained in Appendix B; C. any modification to the design of the equipment that reduces the stack height below that contained in Appendix B; D. any construction or modification of structures that increase the effective structural dimensions as they are used in the building wake effects algorithm in the ISC Air Dispersion Model, or its successor; or E. any increase of a maximum potential lead emission rate by more than 0.025 pound per hour. Title I Condition: State Implementation Plan (SIP) for Lead 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 Permittee shall operate and maintain the process equipment described in Appendix B according to the parameters set forth in Appendix B. The parameters were used in the computer modeling performed to demonstrate that the lead maintenance area attains compliance with the National Ambient Air Quality Standard (NAAQS) for lead. Title I Condition: State Implementation Plan (SIP) for Lead NAAQS; 40 CFR pt. 50; 40 CFR pt. 51; 40 CFR pt. 52, subp. Y; MN SIP

Property Access Restrictions: The Permittee shall limit access to the portion of the property shown in Appendix F with fencing that continuously encloses that portion of the Facility property, excluding access points. The Permittee shall limit access to the portion of the property indicated in Appendix F with gates at each access point. The Permittee shall operate security cameras that monitor access to the main gate, shown in Appendix F during office hours. At all other times, the Permittee shall keep the main gate locked when not in use. At all times, the Permittee shall keep locked all other gates when not in use. The Permittee shall post NO TRESPASSING signs at all access points. Title I Condition: State Implementation Plan (SIP) for Lead NAAQS; 40 CFR pt. 50; 40 CFR pt. 51; 40 CFR pt. 52, subp. Y; MN SIP

Property Access Monitoring: The Permittee shall demonstrate compliance with the property access restrictions by monthly inspecting the fencing and gates, and repairing and maintaining the fencing and gates. The Permittee shall complete all repairs to the fencing and gates within 30 days after the Permittee has access to information that indicates repair is needed. Title I Condition: State Implementation Plan (SIP) for Lead NAAQS; 40 CFR pt. 50; 40 CFR pt. 51; 40 CFR pt. 52, subp. Y; MN SIP

## TABLE A: LIMITS AND OTHER REQUIREMENTS 06/29/10 Gopher Resource LLC 03700016 - 003 Facility Name: Permit Number: A-2

Property Access Recordkeeping: The Permittee shall generate and maintain records containing information associated with the Facility property access restrictions requirements. At the minimum, the Permittee shall retain records containing the following information: 1. Inspections: Records of the date of inspection, name of the person conducting the inspection, identification of each section of fence and each gate inspected, trespassers or evidence of trespassers, and identification of each location where repair or maintenance is required. 2. Repairs: Records of the date of repair or maintenance, a description of the repair and maintenance conducted, and the locations where repair and maintenance occurred. Title I Condition: State Implementation Plan (SIP) for Lead NAAQS; 40 CFR pt. 50; 40 CFR pt. 51; 40 CFR pt. 52, subp. Y; MN SIP

FUGITIVES CONTROL: Other lead emission sources at the Facility include building openings, reentrained dust from truck traffic at the Facility and wind erosion of unpaved, or otherwise uncovered, areas on the around the Facility site. The Permittee shall limit the amount of fugitive lead emissions by, at a minimum, performing the activities indicated below (Items A - E) (continued below) Title I Condition: State Implementation Plan (SIP) for Lead NAAQS; 40 CFR pt. 50; 40 CFR pt. 51; 40 CFR pt. 52, subp. Y; MN SIP

(continued from above)
A . Building Openings: The Permittee shall keep closed all barriers on outside openings of the Smelting, Raw Material Warehouse and process side of the Raw Material Processing Area, shown in Appendix D of this permit, at all times except during ingress and egress through the building opening, except that some outside doors may be kept open to provide additional makeup air. Whenever an outside door is kept open, the Permittee shall demonstrate that negative pressure is still maintained, using a method described in Appendix H of this permit. If negative pressure cannot be demonstrated with open doors, the doors shall be closed immediately and negative pressure demonstrated with the doors closed. Records shall be kept of all such events and demonstrations. The Permittee shall keep closed all rail loading doors in the Refining area, shown in Appendix D of this permit, at all times except when a rail car is being loaded.

(continued below) Title I Condition: State Implementation Plan (SIP) for Lead NAAQS; 40 CFR pt. 50; 40 CFR pt. 51; 40 CFR pt. 52, subp. Y; MN SIP

(continued from above) The Permittee shall monthly inspect all barriers on outside openings for damage which would result in lead emissions escaping the building. Any time that damage to the outside openings which would result in lead emissions escaping the building is detected, the owner or operator shall repair the damage within two weeks of the detection. The Permittee shall prevent fugitive lead from emitting through outside openings by operating and maintaining a negative pressure system that puts the areas shown in A ppendix E under negative pressure, and a ventilation system that collects lead bearing air from the negative pressure areas shown in Appendix E of this permit and routes it through a cartridge filter. (continued below) Title I Condition: State Implementation Plan (SIP) for Lead NAAQS; 40 CFR pt. 50; 40 CFR pt. 51; 40 CFR pt. 52, subp. Y; MN SIP

(continued from above) B. Sweeping The Permittee shall sweep all paved outdoor areas, as indicated in Appendix J of this permit, with a vacuum equipped road sweeper. If there was a 0.1 inch rainfall during the previous 24 hours, or if these areas are covered with snow the Permittee is exempt from sweeping uncovered outside areas during the subsequent 24 hours. The owner or operator shall collect manually record rainfall data with an on-site rain gauge. The Permittee shall immediately (as soon as is reasonably possible after giving consideration to plant and personnel safety) clean up spills of lead containing materials, flue dust, or slag with a vacuum equipped road sweeper, or by hand vacuuming or wet sweeping. The Permittee shall store swept lead bearing material in the Raw Material Warehouse and recycle the swept lead bearing material in the furnaces. (continued below) Title I Condition: State Implementation Plan (SIP) for Lead NAAQS; 40 CFR pt. 50; 40 CFR pt. 51; 40 CFR pt. 52, subp. Y; MN SIP

## TABLE A: LIMITS AND OTHER REQUIREMENTS 06/29/10 Gopher Resource LLC 03700016 - 003 Facility Name: Permit Number: A-3

(continued from above)
C. Traffic Limitations The Permittee shall limit mobile equipment traffic to the paved outdoor areas, shown in Appendix J, except for lawn mowing equipment on vegetative (grass covered) areas and maintenance and inspection activities. D. Equipment Handling and Cleaning Bag and Cartridge Replacement: The Permittee shall immediately deposit used bags and cartridge filters in leak-proof containers when replacing the baghouse or cartridge filters for the control equipment listed in Appendix B. The owner or operator shall recycle the used bags or cartridge filters in the furnaces. (continued below) Title I Condition: State Implementation Plan (SIP) for Lead NAAQS; 40 CFR pt. 50; 40 CFR pt. 51; 40 CFR pt. 52, subp. Y; MN SIP

(continued from above) Mobile Equipment: The Permittee shall daily clean all mobile equipment used in the containment building. Mobile equipment includes, but not limited to vacuum sweepers, forklifts, and front end loader(s). Cleaning shall be conducted by hand vacuuming, scrubbing or pressure washing with water in the wash bays indicated in A ppendix D of this permit. The Permittee shall keep the barriers on outside openings closed during cleaning. The Permittee shall store vacuumed lead bearing material in the Raw Material Warehouse shown in Appendix D of this permit, and recycle the vacuumed material in the furnaces, described in Appendix B. The Permittee shall dispose of any water laden with lead in the Facility Water Treatment Plant. (continued below) Title I Condition: State Implementation Plan (SIP) for Lead NAAQS; 40 CFR pt. 50; 40 CFR pt. 51; 40 CFR pt. 52, subp. Y; MN SIP

(continued from above) Ventilation System: The Permittee shall on a monthly basis, inspect the ventilation system for holes and negative static pressure with an electronic or magnehelic pressure gauge. The Permittee shall clean and/or repair the ventilation systems if there are visible holes and/or positive static pressure. The owner or operator shall monthly test the magnehelic gauges for accuracy, and repair or replace defective gauges as prescribed by the manufacturer. Hazardous Material: The Permittee shall store material inside the Facility building. The Permittee shall apply water to hazardous material prior to loading it into trucks that haul the slag material outside the Facility building. Water application is not required when the air temperature outside is at or below 32 degree F. The Permittee shall cover all trucks hauling hazardous residue outside the Facility building. (continued below) Title I Condition: State Implementation Plan (SIP) for Lead NAAQS; 40 CFR pt. 50; 40 CFR pt. 51; 40 CFR pt. 52, subp. Y; MN SIP

(continued from above)
E. Wind Erosion Prevention Vegetative Cover: The Permittee shall maintain continuous vegetative cover (grasses) over all areas that are not paved or otherwise continuously covered. Paved Areas: The Permittee shall retain and maintain all paved areas. Soil Removal: If the Permittee removes lead bearing soil to comply with Resource Conservation Recovery Act (RCRA) corrective action requirements, the Permittee shall remove and handle the soil in accordance to a corrective action plan approved by the MPCA Hazardous Waste Program. If as a part of the corrective action plan the Permittee replaces lead bearing soil with clean fill (without lead) that bars remaining lead bearing soil from exposure to the air, the Permittee is exempt from vegetative cover and paved areas requirements in those areas on which clean fill is in place. Title I Condition: State Implementation Plan (SIP) for Lead NAAQS; 40 CFR pt. 50; 40 CFR pt. 51; 40 CFR pt. 52, subp. Y; MN SIP

Recordkeeping for the MN State Implementation for Lead: Retain all records at the stationary source for a period of five (5) years from the date of the required monitoring, sample, measurement, or report that corresponds with the MN State Implementation Plan Title I Condition. Title I Condition: State Implementation Plan (SIP) for Lead NAAQS; 40 CFR pt. 50; 40 CFR pt. 51; 40 CFR pt. 52, subp. Y; MN SIP
NEGATIVE PRESSURE TESTING: The owner or operator shall monthly conduct Negative Pressure testing in accordance with Appendices H and I of this permit. Title I Condition: State Implementation Plan (SIP) for Lead NAAQS; 40 CFR pt. 50; 40 CFR pt. 51; 40 CFR pt. 52, subp. Y; MN SIP

## TABLE A: LIMITS AND OTHER REQUIREMENTS 06/29/10 Gopher Resource LLC 03700016 - 003 Facility Name: Permit Number: A-4

CONTINGENCY PLAN REQUIREMENTS: In the event that the maintenance area in which the Facility is located fails to maintain compliance with the lead NAAQS of 1.5 microgram per cubic meter, the following contingency plan measures shall be implemented by the Permittee. These measures shall be implemented by the owner or operator within 30 days following formal determination and notification by the MPCA or the EPA.
A . The Permittee shall daily sweep with a wet sweeper the paved outdoor areas that are shown in Appendix D as areas that are daily swept. B. The Permittee shall daily sweep with a vacuum equipped road sweeper the paved outdoor areas that are shown in Appendix D as areas that are swept at least once a week and at least every three weeks. (continued below) Title I Condition: State Implementation Plan (SIP) for Lead NAAQS; 40 CFR pt. 50; 40 CFR pt. 51; 40 CFR pt. 52, subp. Y; MN SIP

(continued from above) C. If ice will form on the paved outdoor areas while sweeping with a wet sweeper, the Permittee shall sweep twice daily with a vacuum equipped road sweeper the paved outdoor areas that are shown in Appendix D as areas that are daily swept. D. The Permittee is exempt from sweeping if there was a 0.1 inch rainfall during the previous 24 hours, or if the paved outdoor areas are covered with snow. The Permittee shall collect rainfall data with an onsite rain gauge. In the event that the contingency plan is implemented, the Permittee shall maintain a record of all sweeping events, records of rainfall and snow cover for times not swept because of snow cover, and records of days that dry sweeping replaced wet sweeping because of ice formation on the paved outdoor areas. Title I Condition: State Implementation Plan (SIP) for Lead NAAQS; 40 CFR pt. 50; 40 CFR pt. 51; 40 CFR pt. 52, subp. Y; MN SIP

RECORDKEEPING The Permittee shall keep and maintain all required documents, records, reports, and plans in a form suitable to allow the EPA or MPCA staff to determine compliance with SIP requirements. The Permittee shall maintain the information onsite in files which are easily accessible for inspection by EPA or MPCA staff. (continued below) Title I Condition: State Implementation Plan (SIP) for Lead NAAQS; 40 CFR pt. 50; 40 CFR pt. 51; 40 CFR pt. 52, subp. Y; MN SIP

(continued from above)
A t a minimum, the Permittee shall retain records containing the following information: 1. Building Openings: all monthly negative pressure testing results, monthly inspection reports of all damage to barriers on inside and outside openings, and the corrective action taken. If no damage occurred, the record shall state that no damage occurred. Records shall be kept of damage and subsequent repair or replacement of barriers on inside and outside openings detected or that occur at times other than during the monthly inspection. The records shall also include the installation of any new building openings and barriers for the openings. 2. Sweeping: records of daily and weekly sweeping events, spills of lead containing materials, cleanup of these spills, records of sweeping equipment breakdowns and repairs, and records of rainfall and snow cover for times not swept because of the presence of rainfall or snow cover. (continued below) Title I Condition: State Implementation Plan (SIP) for Lead NAAQS; 40 CFR pt. 50; 40 CFR pt. 51; 40 CFR pt. 52, subp. Y; MN SIP

(continued from above) 3. Equipment Handling and Cleaning: daily records of mobile equipment cleaning and repairs, and record of monthly ventilation system inspections, and magnahelic gauge repair and replacement. 4. Wind Erosion Prevention: inspection records of vegetative cover and pavement, and repairs to these areas. A record of any lead contaminated soil corrective action (under RCRA) at the facility, and of areas covered with clean fill. Title I Condition: State Implementation Plan (SIP) for Lead NAAQS; 40 CFR pt. 50; 40 CFR pt. 51; 40 CFR pt. 52, subp. Y; MN SIP

OTHER SOURCE-SPECIFIC REQUIREMENTS hdr

## TABLE A: LIMITS AND OTHER REQUIREMENTS 06/29/10 Gopher Resource LLC 03700016 - 003 Facility Name: Permit Number: A-5

The parameters used in SO2 modeling for permit number 03700016-003 are listed in Appendix B of this permit. 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 DETERMINING IF A PROJECT/MODIFICATION IS SUBJECT TO NEW SOURCE REVIEW hdr These requirements apply where there is a reasonable possibility (as defined in 40 CFR Section 52.21(r)(6)(vi)) that a proposed project, analyzed using the actual-to-projected-actual (ATPA) test (either by itself or as part of the hybrid test described in Section 52.21(a)(2)(iv)(f)) and found to not be part of a major modification, may result in a significant emissions increase. If the ATPA test is not used for a particular project, or if there is not a reasonable possibility that the proposed project could result in a significant emissions increase, then these requirements do not apply to that project. Even though a particular modification is not subject to New Source Review, or where there isn't a reasonable possibility that a proposed project could result in a significant emissions increase, a permit amendment, recordkeeping, or notification may still be required under Minn. R. 7007.1150 - 7007.1500. Title I Condition: 40 CFR Section 52.21(r)(6); Minn. R. 7007.3000; Minn. R. 7007.0800, subp. 2

Preconstruction Documentation -- Before beginning actual construction on a project, the Permittee shall document the following: 1. Project description 2. Identification of any emission unit (EU) whose emissions of an NSR pollutant could be affected 3. Pre-change potential emissions of any affected existing EU, and the projected post-change potential emissions of any affected existing or new EU. 4. A description of the applicability test used to determine that the project is not a major modification for any regulated NSR pollutant, including the baseline actual emissions, the projected actual emissions, the amount of emissions excluded due to increases not associated with the modification and that the EU could have accommodated during the baseline period, an explanation of why the amounts were excluded, and any creditable contemporaneous increases and decreases that were considered in the determination.
The Permittee shall maintain records of this documentation. Title I Condition: 40 CFR Section 52.21(r)(6); Minn. R. 7007.3000; Minn. R. 7007.1200, subp. 4; Minn. R. 7007.0800, subps. 4 & 5

The Permittee shall monitor the actual emissions of any regulated NSR pollutant that could increase as a result of the project and that were analyzed using the A TPA test, and the potential emissions of any regulated NSR pollutant that could increase as a result of the project and that were analyzed using potential emissions in the hybrid test. The Permittee shall calculate and maintain a record of the sum of the actual and potential (if the hybrid test was used in the analysis) emissions of the regulated pollutant, in tons per year on a calendar year basis, for a period of 5 years following resumption of regular operations after the change, or for a period of 10 years following resumption of regular operations after the change if the project increases the design capacity of or potential to emit of any unit associated with the project. Title I Condition: 40 CFR Section 52.21(r)(6); Minn. R. 7007.3000; Minn. R. 7007.0800, subps. 4 & 5

The Permittee must submit a report to the Agency if the annual summed (actual, plus potential if used in hybrid test) emissions differ from the preconstruction projection and exceed the baseline actual emissions by a significant amount as listed at 40 CFR Section 52.21(b)(23). Such report shall be submitted to the A gency within 60 days after the end of the year in which the exceedances occur. The report shall contain: a. The name and ID number of the facility, and the name and telephone number of the facility contact person b. The annual emissions (actual, plus potential if any part of the project was analyzed using the hybrid test) for each pollutant for which the preconstruction projection and significant emissions increase are exceeded. c. Any other information, such as an explanation as to why the summed emissions differ from the preconstruction projection. Title I Condition: 40 CFR Section 52.21(r)(6); Minn. R. 7007.3000; Minn. R. 7007.0800, subps. 4 & 5

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, subps. 7A, 7L & 7M; Minn. R. 7007.0800, subps. 1, 2 & 4; Minn. R. 7009.0010-7009.0080 Circumvention: Do not install or use a device or means that conceals or 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

## TABLE A: LIMITS AND OTHER REQUIREMENTS 06/29/10 Gopher Resource LLC 03700016 - 003 Facility Name: Permit Number: A-6

A ir Pollution Control Equipment: Operate all pollution control equipment whenever the corresponding process equipment and emission units are operated, unless otherwise noted in Table A. Minn. R. 7007.0800, subp. 2; Minn. R. 7007.0800, subp. 16(J) Operation and Maintenance Plan: Retain at the stationary source an operation and maintenance plan for all air pollution control equipment. At a minimum, the O & M plan shall identify all air pollution control equipment and control practices and shall include a preventative maintenance program for the equipment and practices, a description of (the minimum but not necessarily the only) corrective actions to be taken to restore the equipment and practices to proper operation to meet applicable permit conditions, a description of the employee training program for proper operation and maintenance of the control equipment and practices, and the records kept to demonstrate plan implementation. Minn. R. 7007.0800, subps. 14 and 16(J)

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, B, and/or C. Minn. R. ch. 7017
Performance Test Notifications and Submittals: Performance Tests are due as outlined in Tables A and B of the permit. See 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. Rs. 7017.2030, subp. 1-4, 7017.2018 and Minn. R. 7017.2035, subp. 1-2

Limits set as a result of a performance test (conducted before or after 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: Annually calibrate all required monitoring equipment (any requirements applying to continuous emission monitors are listed separately in this permit). Minn. R. 7007.0800, subp. 4(D)

Operation of Monitoring Equipment: Unless otherwise noted in Tables A and/or B, monitoring a process or control equipment connected to that process is 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

## TABLE A: LIMITS AND OTHER REQUIREMENTS 06/29/10 Gopher Resource LLC 03700016 - 003 Facility Name: Permit Number: A-7

Recordkeeping: Retain all records at the stationary source for a period of five (5) years from the date of monitoring, sample, measurement, or report. Records 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)

When 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. These records shall be kept for a period of five years from the date the change was made or until permit reissuance, whichever is longer. 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 through Minn. R. 7007.1500

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. The Permittee shall submit this 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 through Minn. R. 7002.0095

## TABLE A: LIMITS AND OTHER REQUIREMENTS 06/29/10 Gopher Resource LLC 03700016 - 003 Facility Name: Permit Number: A-8

RECORDKEEPING AND REPORTING REQUIREMENTS FOR 40 CFR 63, Subpart X hdr (a) The owner or operator of a secondary lead smelter shall comply with all of the recordkeeping requirements under Sec. 63.10 of the General Provisions. In addition, each owner or operator of a secondary lead smelter shall maintain for a period of 5 years, records of the information listed in paragraphs (a)(1) through (a)(6) of this section. (1) An identification of the date and time of all bag leak detection system alarms, their cause, and an explanation of the corrective actions taken. (2) Monitoring the reverberatory natural gas flow on a continuous basis. (3) (superseded by alternative monitoring, see Subject Items GP001 and CE007) (4) Any recordkeeping required as part of the practices described in the standard operating procedures manual required under Sec. 63.545(a) for the control of fugitive dust emissions. (5) Any recordkeeping required as part of the practices described in the standard operating procedures manual for baghouses required under Sec. 63.548(a). 40 CFR Section 63.550(a); Minn. R. 7011.7240

(b) The owner or operator of a secondary lead smelter shall comply with all of the reporting requirements under Sec. 63.10 of the General Provisions. The submittal of reports shall be no less frequent than specified under Sec. 63.10(e)(3) of the General Provisions. Once a source reports a violation of the standard or excess emissions, the source shall follow the reporting format required under Sec. 63.10(e)(3) until a request to reduce reporting frequency is approved. (c) In addition to the information required under Sec. 63.10 of the General Provisions, reports required under paragraph (b) of this section shall include the information specified in paragraphs (c)(1) through (c)(6) of this section. (1) The reports shall include records of all alarms from the bag leak detection system specified in Sec. 63.548(e). (2) The reports shall include a description of the procedures taken following each bag leak detection system alarm pursuant to Sec. 63.548 (f)(1) and (2). 40 CFR Section 63.550(b) and (c); Minn. R. 7011.7240

(4) The reports shall contain a summary of the records maintained as part of the practices described in the standard operating procedures manual for baghouses required under Sec. 63.548(a), including an explanation of the periods when the procedures were not followed and the corrective actions taken. (6) The reports shall contain a summary of the fugitive dust control measures performed during the required reporting period, including an explanation of the periods when the procedures outlined in the standard operating procedures manual pursuant to Sec. 63.545(a) were not followed and the corrective actions taken. The reports shall not contain copies of the daily records required to demonstrate compliance with the requirements of the standard operating procedures manuals required under Secs. 63.545(a) and 63.548(a). 40 CFR Section 63.550(c); Minn. R. 7011.7240

## TABLE A: LIMITS AND OTHER REQUIREMENTS 06/29/10 Gopher Resource LLC 03700016 - 003 Facility Name: Permit Number: A-9

Subject Item: GP 001 Process Sources under NESHAP Subpart X
Associated Items: EU 004 West Reverberatory Furnace EU 007 East Reverberatory Furnace
EU 009 Blast Furnace

What to do Why to do it EMISSION LIMITS hdr Lead Compounds: less than 0.00087 grains/dry standard cubic foot using 3-hour A verage (3-hour arithmetic average) for East Reverberatory and Blast Furnace [2.0 milligrams per dry standard cubic meter (mg/dscm)] 40 CFR Section 63.543(a); Minn. R. 7011.7240

THC (Total Hydrocarbons): less than 20 parts per million by volume, expressed as propane corrected to 4 percent carbon dioxide to correct for dilution, based on a 3-hour arithmetic average. This limit applies during the periods when the collocated blast and reverberatory furnaces are both operating. 40 CFR Section 63.543(c); Minn. R. 7011.7240

THC (Total Hydrocarbons): less than 360 parts per million by volume, expressed as propane corrected to 4 percent carbon dioxide to correct for dilution, based on a 3-hour arithmetic average. This limit applies during the periods when the reveberatory furnaces are not operating. 40 CFR Section 63.543(c)(1); Minn. R. 7011.7240

CONTROL REQUIREMENTS - See also Subject Items GP004, CE004, CE005, and CE007 hdr The Permittee shall operate and maintain the fabric filters CE004 and CE005 at all times that any emission unit controlled by the fabric filter is in operation. The Permittee shall document periods of non-operation of the control equipment. Minn. R. 7007.0800, subps. 2 and 14

The Permittee shall operate and maintain the afterburner CE007 at all time that EU007 and EU009 are both operating. The Permittee shall document periods of operation of CE007, and EU007 and EU009 (both individually and simultaneously). Minn. R. 7007.0800, subps. 2 and 14

THC MONITORING REQUIREMENTS hdr The owner or operator of a blast furnace or collocated blast furnace and reverberatory furnace subject to the total hydrocarbon standards in 40 CFR Section 63.543(c), (d), or (e) must comply with the requirements of either 40 CFR Section 63.548(j)(1) or (j)(2), to demonstrate continuous compliance with the total hydrocarbon emission standards. The Permittee proposed an alternative monitoring plan of monitoring reverberatory furnace natural gas flow instead of continuous temperature. This plan was approved by the EPA on June 29, 1998. 40 CFR Section 63.548(j); Minn. R. 7011.7240

The Permittee shall continuously monitor and record the natural gas or propane usage of EU007. 40 CFR Section 63.8 (f) [Alternative Monitoring Method, EPA letter dated 7/29/1998] Whenever the blast furnace (EU009) and the east reverberatory furnace (EU007) are both operating, the Permittee shall show compliance with the THC standard of 20 ppm as follows: 1. Maintain the natural gas usage at or above the arithmetic average established in most recent MPCA approved compliance test.
OR 2. Maintain the propane usage at or above the arithmetic average established in most recent MPCA approved compliance test. 40 CFR Section 63.8 (f) [Alternative Monitoring Method, EPA letter dated 7/29/1998]

The Permittee shall report to U.S. EPA and copy to the MPCA on a semiannual basis whether any 3-hour arithmetic average natural gas usage or propane usage is less than the arithmetic average established in the most recent MPCA approved compliance test. Once any 3-hour usage is less than the established average, report on a quarterly basis until a request to reduce reporting frequency is approved by the EPA. 40 CFR Section 63.8 (f) [Alternative Monitoring Method, EPA letter dated 7/29/1998]

Calibration of Continuous Monitoring Device: The Permittee shall service and calibrate the monitoring instrument at 1-year intervals and keep records of all calibrations for at least 5 years. 40 CFR Section 63.8 (f) [Alternative Monitoring Method, EPA letter dated 7/29/1998] PERFORMANCE TESTING REQUIREMENTS - See Subject Item SV003 hdr

## TABLE A: LIMITS AND OTHER REQUIREMENTS 06/29/10 Gopher Resource LLC 03700016 - 003 Facility Name: Permit Number: A-10

Subject Item: GP 002 Process Fugitive Sources under NESHAP Subpart X
Associated Items: EU 006 Scrap Dryer EU 011 Refining Kettle No. 1 EU 012 Refining Kettle No. 2 EU 013 Refining Kettle No. 3 EU 014 Refining Kettle No. 4 EU 015 Refining Kettle No. 5 EU 016 Refining Kettle No. 6 EU 017 Refining Kettle No. 7 EU 018 Refining Kettle No. 8 EU 019 Refining Kettle No. 9 EU 020 Refining Kettle No. 10 FS 001 Furnace Area Process Fugitives FS 002 West Reverberatory Furnace Process Fugitives FS 003 East Reverberatory Furnace Process Fugitives FS 004 Blast Furnace Process Fugitives FS 005 Casting Machine Process Fugitives FS 006 Refining Area Fugitive Dust Sources

What to do Why to do it EMISSION AND OPERATING LIMITS hdr Lead Compounds: less than or equal to 0.00087 grains/dry standard cubic foot using 3-hour Average ( 3-hour arithmetic average) (2.0 mg/dscm). The ventilation air from all enclosures hoods and total enclosures shall be conveyed to a control device. 40 CFR Section 63.544(c); 40 CFR Section 63.544(d); Minn. R. 7011.7240

Process Fugitive Emission Sources (as defined at 40 CFR Section 63.544(a)) shall be located in a total enclosure subject to general ventilation that maintains the building at a lower than ambient pressure to ensure in-draft through any doorway opening. (1) All process fugitive enclosure hoods (except those for refining kettles and dryer transition pieces) shall be ventilated to maintain a face velocity of at least 300 feet per minute at all hood openings. (2) Process fugitive enclosure hoods required for refining kettles shall be ventilated to maintain a face velocity of at least 250 feet per minute. (3) Process fugitive enclosure hoods required for dryer transition pieces shall be ventilated to maintain a face velocity of at least 350 feet per minute. 40 CFR Section 63.544(b); Minn. R. 7011.7240

Ventilation air from all enclosures, hoods, and total enclosures shall be conveyed to a control device. (See also Subject Items CE002, CE003, CE004, CE005, and GP004) 40 CFR Section 63.544(c); Minn. R. 7011.7240

A ll dryer emission vents shall be ventilated to a control device. (See also Subject Item CE005) 40 CFR Section 63.544(d); Minn. R. 7011.7240

PERFORMANCE TESTING REQUIREMENTS - See Subject Item SV002 hdr

## TABLE A: LIMITS AND OTHER REQUIREMENTS 06/29/10 Gopher Resource LLC 03700016 - 003 Facility Name: Permit Number: A-11

Subject Item: GP 003 Fugitive Dust Sources under NESHAP Subpart X
Associated Items: EU 001 Raw Material Processing Operation EU 002 Raw Material Handling Operation FS 006 Refining Area Fugitive Dust Sources

What to do Why to do it EMISSION AND OPERATING LIMITS hdr Lead Compounds: less than or equal to 0.00087 grains/dry standard cubic foot using 3-hour Average ( 3-hour arithmetic average) (2.0 mg/dscm). The ventilation air from all enclosures hoods and total enclosures shall be conveyed to a control device. 40 CFR Section 63.545(e); Minn. R. 7011.7240

The Permittee shall prepare and at all times operate according to a standard operating procedures manual that describes in detail the measures that will be put in place to control fugitive dust emission sources within the areas of the secondary lead smelter listed below: (1) Plant roadways; (2) Battery breaking area; (3) Furnace area; (4) Refining and casting area; and (5) Materials storage and handling area. 40 CFR Section 63.545(a); Minn. R. 7011.7240

The standard operating procedures manual shall be submitted to the Administrator or delegated authority for review and approval. 40 CFR Section 63.545(b); Minn. R. 7011.7240

The controls specified in the standard operating procedures manual shall at a minimum include the following: (1) Plant roadways - paving of all areas subject to vehicle traffic and pavement cleaning twice per day of those areas, except on days when natural precipitation makes cleaning unnecessary or when sand or a similar material has been spread on plant roadways to provide traction on ice or snow. (2) Battery breaking area - total enclosure of the battery breaking area. (3) Furnace area - total enclosure and ventilation of the enclosure to a control device. (4) Refining and casting area - total enclosure and ventilation of the enclosure to a control device. (5) Materials storage and handling area - total enclosure of the area and ventilation of the enclosure to a control device, and a vehicle wash at each exit. 40 CFR Section 63.545(c); Minn. R. 7011.7240

Standard Operating Procedures (SOP) Manual: The SOP manual shall require that daily records be maintained of all wet suppression, pavement cleaning, and vehicle washing activities performed to control fugitive dust emissions. 40 CFR Section 63.545(d); Minn. R. 7011.7240

PERFORMANCE TESTING REQUIREMENTS - See Subject Items SV001 and SV002 hdr

## TABLE A: LIMITS AND OTHER REQUIREMENTS 06/29/10 Gopher Resource LLC 03700016 - 003 Facility Name: Permit Number: A-12

Subject Item: GP 004 NESHAP Subpart X Control Equipment Monitoring Requirements
Associated Items: CE 002 Fabric Filter - Low Temperature, i.e., T<180 Degrees F CE 003 Fabric Filter - Low Temperature, i.e., T<180 Degrees F CE 004 Fabric Filter - High Temperature, i.e., T>250 Degrees F CE 005 Fabric Filter - High Temperature, i.e., T>250 Degrees F CE 008 Fabric Filter - Low Temperature, i.e., T<180 Degrees F CE 009 Fabric Filter - Low Temperature, i.e., T<180 Degrees F

What to do Why to do it (a) The Permittee shall prepare, and at all times operate according to, a standard operating procedures manual that describes in detail procedures for inspection, maintenance, and bag leak detection and corrective action plans for all baghouses (fabric filters) that are used to control process, process fugitive, or fugitive dust emissions from any source subject to the lead emission standards in 40 CFR Sections 63.543, 63.544, and 63.545, including those used to control emissions from building ventilation. (b) The standard operating procedures (SOP) manual for baghouses required by paragraph (a) of this section shall be submitted to the Administrator or delegated authority for review and approval. 40 CFR Section 63.548(a) and (b); Minn. R. 7011.7240

(c) The procedures specified in the standard operating procedures manual for inspections and routine maintenance shall, at a minimum, include the requirements of paragraphs (c)(1) through (c)(9) of this section. (1) Daily monitoring of pressure drop across each baghouse cell. (2) Weekly confirmation that dust is being removed from hoppers through visual inspection, or equivalent means of ensuring the proper functioning of removal mechanisms. (3) Daily check of compressed air supply for pulse-jet baghouses. (4) An appropriate methodology for monitoring cleaning cycles to ensure proper operation. (5) Monthly check of bag cleaning mechanisms for proper functioning through visual inspection or equivalent means. (6) Monthly check of bag tension on reverse air and shaker-type baghouses. Such checks are not required for shaker-type baghouses using self-tensioning (spring loaded) devices. 40 CFR Section 63.548(c); Minn. R. 7011.7240

(continued from above) (7) Quarterly confirmation of the physical integrity of the baghouse through visual inspection of the baghouse interior for air leaks. (8) Quarterly inspection of fans for wear, material buildup, and corrosion through visual inspection, vibration detectors, or equivalent means. (9) Except as provided in paragraphs (g) and (h) of this section, continuous operation of a bag leak detection system. 40 CFR Section 63.548(c); Minn. R. 7011.7240

(d) The procedures specified in the standard operating procedures manual for maintenance shall, at a minimum, include a preventative maintenance schedule that is consistent with the baghouse manufacturer's instructions for routine and long-term maintenance. 40 CFR Section 63.548(d); Minn. R. 7011.7240

## TABLE A: LIMITS AND OTHER REQUIREMENTS 06/29/10 Gopher Resource LLC 03700016 - 003 Facility Name: Permit Number: A-13

(e) The bag leak detection system required by 40 CFR Section 63.548(c)(9) shall meet the specification and requirements of paragraphs (e)(1) through (e)(8) of this section. (1) The bag leak detection system must be certified by the manufacturer to be capable of detecting particulate matter emissions at concentrations of 10 milligram per actual cubic meter (0.0044 grains per actual cubic foot) or less. (2) The bag leak detection system sensor must provide output of relative particulate matter loadings. (3) The bag leak detection system must be equipped with an alarm system that will alarm when an increase in relative particulate loadings is detected over a preset level. 40 CFR Section 63.548(e); Minn. R. 7011.7240

(continued from above) (4) The bag leak detection system shall be installed and operated in a manner consistent with available written guidance from the U.S. Environmental Protection A gency or, in the absence of such written guidance, the manufacturer's written specifications and recommendations for installation, operation, and adjustment of the system. (5) The initial adjustment of the system shall, at a minimum, consist of establishing the baseline output by adjusting the sensitivity (range) and the averaging period of the device, and establishing the alarm set points and the alarm delay time. 40 CFR Section 63.548(e); Minn. R. 7011.7240

(continued from above) (6) Following initial adjustment, the owner or operator shall not adjust the sensitivity or range, averaging period, alarm set points, or alarm delay time, except as detailed in the approved SOP required under 40 CFR Section 63.548(a). In no event shall the sensitivity be increased by more than 100 percent or decreased more than 50 percent over a 365 day period unless such adjustment follows a complete baghouse inspection which demonstrates the baghouse is in good operating condition. (7) For negative pressure, induced air baghouses, and positive pressure baghouses that are discharged to the atmosphere through a stack, the bag leak detector must be installed downstream of the baghouse and upstream of any wet acid gas scrubber. (8) Where multiple detectors are required, the system's instrumentation and alarm may be shared among detectors. 40 CFR Section 63.548(e); Minn. R. 7011.7240

(f) The standard operating procedures manual required by 40 CFR Section 63.548(a) shall include a corrective action plan that specifies the procedures to be followed in the case of a bag leak detection system alarm. The corrective action plan shall include, at a minimum, the procedures used to determine and record the time and causeof the alarm as well as the corrective actions taken to correct the control device malfunction or minimize emissions as specified in paragraphs (f)(1) and (f)(2) of this section. (1) The procedures used to determine the cause of the alarm must be initiated within 30 minutes of the alarm. 40 CFR Section 63.548(f); Minn. R. 7011.7240

(continued from above) (2) The cause of the alarm must be alleviated by taking the necessary corrective action(s) which may include, but not be limited to, 40 CFR Section 63.548(f)(2)(i)-(vi). (i) Inspecting the baghouse for air leaks, torn or broken filter elements, or any other malfunction that may cause an increase in emissions. (ii) Sealing off defective bags or filter media. (iii) Replacing defective bags or filter media, or otherwise repairing the control device. (iv) Sealing off a defective baghouse compartment. (v) Cleaning the bag leak detection system probe, or otherwise repairing the bag leak detection system. (vi) Shutting down the process producing the particulate emissions. 40 CFR Section 63.548(f); Minn. R. 7011.7240

## TABLE A: LIMITS AND OTHER REQUIREMENTS 06/29/10 Gopher Resource LLC 03700016 - 003 Facility Name: Permit Number: A-14

(h) Baghouses that are used exclusively for the control of fugitive dust emissions from any source subject to the lead emissions standard in 40 CFR Section 63.545 are exempt from the requirement in 40 CFR Section 63.548(c)(9) to be equipped with a bag leak detector. 40 CFR Section 63.548 (h); Minn. R. 7011.7240

## TABLE A: LIMITS AND OTHER REQUIREMENTS 06/29/10 Gopher Resource LLC 03700016 - 003 Facility Name: Permit Number: A-15

Subject Item: GP 005 Emergency Diesel Generators
Associated Items: EU 023 Diesel-Powered Electrical Generator EU 024 Diesel-Powered Electrical Generator SV 006 Diesel Electrical Generator SV 007 Diesel Electrical Generator

What to do Why to do it EMISSION LIMITS hdr Sulfur Dioxide: less than or equal to 0.5 lbs/million Btu heat input . This limit applies individually to each generator listed in GP005. The potential emissions of these units are approximatly 0.29 lbs/million Btu heat input. Minn. R. 7011.2300, subp. 2

Opacity: less than or equal to 20 percent opacity once operating temperatures have been attained (visible air contaminants). This limit applies individually to each generator listed in GP005. Minn. R. 7011.2300, subp. 1

OTHER LIMITS AND REQUIREMENTS hdr Fuel Restriction: Burn diesel fuel only Minn. R. 7007.0800, subp. 2 Operating Hours: less than or equal to 500 hours/year using 12-month Rolling Sum Minn. R. 7007.0800, subp. 2; EPA Policy Memo dated September 6, 1995 Recordkeeping of Fuel Restriction: The Permittee shall record and maintain records of the amount of fuel combustion in the units on a monthly basis by the 15th day of each month for the previous month. The record shall be in the form of fuel bills or meter reading, for example. Minn. R. 7007.0800, subp. 5

Recordkeeping for Operating Hours: The Permitteee shall calculate and record the 12-month rolling sum of the hours of operation by 15th day of each month for the previous month. Minn. R. 7007.0800, subp. 5

## TABLE A: LIMITS AND OTHER REQUIREMENTS 06/29/10 Gopher Resource LLC 03700016 - 003 Facility Name: Permit Number: A-16

Subject Item: GP 006 Furnaces Subject to NSPS Subpart L
Associated Items: EU 007 East Reverberatory Furnace
EU 009 Blast Furnace

What to do Why to do it EMISSION LIMITS hdr Total Particulate Matter: less than or equal to 0.022 grains/dry standard cubic foot using 3-hour Average [50 mg/dscm]. This limit applies individually to each unit listed as an Associated Item. 40 CFR Section 60.122(a)(1); Minn. R. 7011.1820(A)

Opacity: less than or equal to 20 percent opacity . This limit applies individually to each unit listed as an Associated Item. 40 CFR Section 60.122(a)(2); Minn. R. 7011.1820(A)

CONTROL REQUIREMENTS - See Subject Items CE004 and CE005 hdr PERFORMANCE TESTING REQUIREMENTS - See Subject Item SV003 hdr

## TABLE A: LIMITS AND OTHER REQUIREMENTS 06/29/10 Gopher Resource LLC 03700016 - 003 Facility Name: Permit Number: A-17

Subject Item: GP 007 Torit Stacks
Associated Items: SV 002 SIP Source 3 (CE003 and CE002) SV 008 Fugitive Emission Collection

What to do Why to do it Lead: less than 3.45 lbs/hour using 3-hour Average . This limit applies to the combined emissions from SV002 and SV008. Title I Condition: State Implementation Plan (SIP) for Lead NAAQS, 40 CFR pt. 50; 40 CFR pt. 51; 40 CFR pt. 52, subp. Y; MN SIP Performance Test: due before end of each calendar 24 months following Permit Issuance to measure lead emissions from SV002 and SV008, combined, unless more frequent testing is required for SV002 (see Subject Item SV002). Demonstration of compliance with the GP007 limit shall be required each time SV002 is required to be tested for lead and/or lead compound emissions. Title I Condition: State Implementation Plan (SIP) for Lead NAAQS, 40 CFR pt. 50; 40 CFR pt. 51; 40 CFR pt. 52, subp. Y; MN SIP

## TABLE A: LIMITS AND OTHER REQUIREMENTS 06/29/10 Gopher Resource LLC 03700016 - 003 Facility Name: Permit Number: A-18

Subject Item: GP 008 Torit Filter Banks
Associated Items: CE 002 Fabric Filter - Low Temperature, i.e., T<180 Degrees F CE 003 Fabric Filter - Low Temperature, i.e., T<180 Degrees F CE 008 Fabric Filter - Low Temperature, i.e., T<180 Degrees F CE 009 Fabric Filter - Low Temperature, i.e., T<180 Degrees F

What to do Why to do it The Permittee shall operate and maintain the dust collectors (Torit #1 & 2/CE002, Torit #3/CE003, Torit #4/CE008, and Torit #5/CE009) at all times that any emission unit controlled by the dust collector is in operation, unless negative pressure in the building can be maintained while the collector is not in operation. If two or more Torit dust collectors/filters are not operating while any process listed as an A ssociated Item under CE002, CE003, CE008, and/or CE009 is operating, the Permittee shall follow the procedures in Appendix H for demonstrating that the building is under negative pressure. Minn. R. 7007.0800, subps. 2 and 14

Each day of operation, the Permittee shall record the times of any torit filter downtime, and if two or more were down at any one time, the results of the building negative pressure test. The Permittee shall document periods of non-operation of the control equipment that result in loss of building negative pressure, and take immediate corrective action as described in Appendix H. Minn. R. 7007.0800, subps. 2 and 14

## TABLE A: LIMITS AND OTHER REQUIREMENTS 06/29/10 Gopher Resource LLC 03700016 - 003 Facility Name: Permit Number: A-19

Subject Item: SV 001 Raw Material Processing (CE001)
Associated Items: EU 001 Raw Material Processing Operation

What to do Why to do it Lead Compounds: less than 0.00087 grains/dry standard cubic foot using 3-hour A verage ( 3-hour arithmetic average) from any gases into the atmosphere from any building or enclosure ventilation system. [ 2.0 mg/dscm] 40 CFR Section 63.545(e); Minn. R. 7011.7240

Total Particulate Matter: less than or equal to 0.3 grains/dry standard cubic foot of exhaust gas unless required to further reduce emissions to comply with the less stringent limit of either Minn. R. 7011.0730 or Minn. R. 7011.0735. Minn. R. 7011.0715, subp. 1(A)

Opacity: less than or equal to 20 percent opacity Minn. R. 7011.0715, subp. 1(B) CONTROL REQUIREMENTS - See also Subject Item CE001 hdr The Permittee shall operate and maintain the control device (CE001) at all times that any emission unit controlled by the device is in operation. The Permittee shall document periods of non-operation of the control equipment. Minn. R. 7007.0800, subps. 2 and 14

The Permittee shall operate and maintain the control equipment such that it achieves an overall control efficiency for Total Particulate Matter: greater than or equal to 90 percent Minn. R. 7007.0800, subps. 2 and 14

The Permittee shall operate and maintain the control equipment such that it achieves an overall control efficiency for PM < 10 micron: greater than or equal to 90 percent Minn. R. 7007.0800, subps. 2 and 14

TESTING REQUIREMENTS hdr Initial Performance Test: due 180 days after Permit Issuance to measure lead compound emissions. 40 CFR Section 63.7; Minn. R. 7017.2020, subp. 1

## TABLE A: LIMITS AND OTHER REQUIREMENTS 06/29/10 Gopher Resource LLC 03700016 - 003 Facility Name: Permit Number: A-20

Subject Item: SV 002 SIP Source 3 (CE003 and CE002)
Associated Items: GP 007 Torit Stacks

What to do Why to do it Lead: less than 0.0025 grains/dry standard cubic foot using 3-hour Average Title I Condition: State Implementation Plan (SIP) for Lead NAAQS, 40 CFR pt. 50; 40 CFR pt. 51; 40 CFR pt. 52, subp. Y; MN SIP Opacity: less than or equal to 5 percent opacity Title I Condition: State Implementation Plan (SIP) for Lead NAAQS, 40 CFR pt. 50; 40 CFR pt. 51; 40 CFR pt. 52, subp. Y; MN SIP Lead Compounds: less than or equal to 0.00087 grains/dry standard cubic foot using 3-hour Average ( 3-hour arithmetic average) [2.0 mg/dscm]. The ventilation air from all enclosures hoods and total enclosures shall be conveyed to a control device. 40 CFR Section 63.544(c); 40 CFR Section 63.544(d); 40 CFR Section 63.545(e); Minn. R. 7011.7240

PERFORMANCE TESTING REQUIREMENT hdr Performance Test: due before end of each calendar 24 months starting 11/30/1999 to measure lead emissions. Title I Condition: State Implementation Plan (SIP) for Lead NAAQS, 40 CFR pt. 50; 40 CFR pt. 51; 40 CFR pt. 52, subp. Y; MN SIP Performance Test: due before end of each calendar 24 months starting 11/30/1999 to measure opacity, unless annual testing of lead or lead compounds is required. Opacity testing shall take place each time lead and/or lead compounds are tested. Title I Condition: State Implementation Plan (SIP) for Lead NAAQS, 40 CFR pt. 50; 40 CFR pt. 51; 40 CFR pt. 52, subp. Y; MN SIP Performance Test: due before end of each calendar year starting 11/30/1999 to measure emissions of lead compounds. Performance test frequency may be reduced to 24 calendar months, if lead compounds are emitted at a rate of 0.00044 gr/dscf or less. Use applicable Test Methods described in 40 CFR Section 63.547. 40 CFR Section 63.544(e); 40 CFR Section 63.544(f); Minn. R. 701.7240

## TABLE A: LIMITS AND OTHER REQUIREMENTS 06/29/10 Gopher Resource LLC 03700016 - 003 Facility Name: Permit Number: A-21

Subject Item: SV 003 Main Stack (CE004, CE005) (SIP Source 1)
Associated Items: EU 004 West Reverberatory Furnace EU 006 Scrap Dryer EU 007 East Reverberatory Furnace
EU 009 Blast Furnace EU 011 Refining Kettle No. 1 EU 012 Refining Kettle No. 2 EU 013 Refining Kettle No. 3 EU 014 Refining Kettle No. 4 EU 015 Refining Kettle No. 5 EU 016 Refining Kettle No. 6 EU 017 Refining Kettle No. 7 EU 018 Refining Kettle No. 8 EU 019 Refining Kettle No. 9 EU 020 Refining Kettle No. 10 EU 025 Thermal Oxidizer (aka CE007) MR 001 SO2 CEMS

What to do Why to do it Note that EU007 and EU009 are also subject to the requirements listed at Subject Items: GP001 and GP006. hdr
EMISSION LIMITS hdr Lead: less than 0.00306 grains/dry standard cubic foot using 3-hour Average [7mg/dscm]. This limit applies to the emissions of SV003. Title I Condition: State Implementation Plan (SIP) for Lead NAAQS, 40 CFR pt. 50; 40 CFR pt. 51; 40 CFR pt. 52, subp. Y; MN SIP Lead Compounds: less than or equal to 0.00087 grains/dry standard cubic foot [2.0 mg/dscm]. This limit applies to the emissions of SV003. 40 CFR Section 63.543(a); 40 CFR Section 63.544(c); 40 CFR Section 63.544(d); Minn. R. 7011.7240

Opacity: less than or equal to 5 percent opacity . This limit applies to all units exhausting through SV003. Title I Condition: State Implementation Plan (SIP) for Lead NAAQS, 40 CFR pt. 50; 40 CFR pt. 51; 40 CFR pt. 52, subp. Y; MN SIP Opacity: less than or equal to 20 percent opacity 40 CFR Section 60.122(a)(2); Minn. R. 7011.1820(A); Minn. R. 7011.0610, subp. 1(A)(2) Sulfur Dioxide: less than 530 lbs/hour using 24-hour Block Average Minn. R. 7009.0020 [Stipulation Agreement] Total Particulate Matter: less than or equal to 0.022 grains/dry standard cubic foot using 3-hour Average [50 mg/dscm]. 40 CFR Section 60.122(a)(1); Minn. R. 7011.1820(A) THC (Total Hydrocarbons): less than 20 parts per million by volume, expressed as propane corrected to 4 percent carbon dioxide to correct for dilution, based on a 3-hour arithmetic average. This limit applies during the periods when the collocated blast furnace and reverberatory furnaces are both operating. 40 CFR Section 63.543(c); Minn. R. 7011.7240

THC (Total Hydrocarbons): less than 360 parts per million by volume, expressed as propane corrected to 4 percent carbon dioxide to correct for dilution, based on a 3-hour arithmetic average. This limit applies during the periods when the reveberatory furnace is not operating. 40 CFR Section 63.543(c); Minn. R. 7011.7240

OPERATING LIMITS [Emission units listed above as Associated Items] hdr (No Slag) Production: less than or equal to 26.1 tons/hour using 8-hour Block A verage Minn. R. 7017.2025, subp. 3 MONITORING REQUIREMENTS - See also Subject Item MR001 hdr

## TABLE A: LIMITS AND OTHER REQUIREMENTS 06/29/10 Gopher Resource LLC 03700016 - 003 Facility Name: Permit Number: A-22

Sulfur Dioxide Emissions Recordkeeping: The owner or operator shall maintain data records for stack velocity, temperature, sulfur dioxide concentration and pounds per hour (lb/hr SO2). The owner or operator shall prepare one-hour averages for all parameters. Minn. R. 7009.0020 [Stipulation Agreement]

Sulfur Dioxide Monitoring: Calibrate, operate and maintain continuous emissions monitoring systems (CEMS) which measures sulfur dioxide emissions. Minn. R. 7009.0020 [Stipulation Agreement]
PERFORMANCE TESTING REQUIREMENT hdr Performance Test: due before end of each calendar 24 months starting 11/30/1999 to measure lead emissions. Title I Condition: State Implementation Plan (SIP) for Lead NAAQS, 40 CFR pt. 50; 40 CFR pt. 51; 40 CFR pt. 52, subp. Y; MN SIP Performance Test: due before end of each calendar 24 months starting 11/30/1999 to measure opacity, unless annual testing of lead or lead compounds is required. Opacity testing shall also take place each time lead and/or lead compounds are tested. Title I Condition: State Implementation Plan (SIP) for Lead NAAQS, 40 CFR pt. 50; 40 CFR pt. 51; 40 CFR pt. 52, subp. Y; MN SIP Performance Test: due before end of each calendar year starting 11/30/1999 to measure for lead compounds. Performance test frequency may be reduced to 24 calendar months, if lead compounds are emitted at a rate of 0.00044 gr/dscf or less. Use applicable Test Methods described in 40 CFR Section 63.547. 40 CFR Section 63.543(h); 40 CFR Section 63.543(i); 40 CFR Section 63.544(e); 40 CFR Section 63.544(f); Minn. R. 7011.7240 Performance Test: due 180 days after Permit Issuance to measure Total Particulate Matter (PM) emissions. Minn. R. 7017.2020, subp. 1 Performance Test: due 180 days after Permit Issuance to measure THC emissions when EU007 and EU009 are both operating. During the test, measure and record at 15 minute intervals (a) natural gas or propane combusted in EU007; and (b) afterburner temperature with a hand-held monitoring device, for the duration of the performance test. Calculate the arithmetic average of the fuel usage and temperature from the 15-minute readings. 40 CFR Section 63.8 (f) [Alternative Monitoring Method, EPA letter dated 7/29/1998]

## TABLE A: LIMITS AND OTHER REQUIREMENTS 06/29/10 Gopher Resource LLC 03700016 - 003 Facility Name: Permit Number: A-23

Subject Item: SV 008 Fugitive Emission Collection
Associated Items: EU 002 Raw Material Handling Operation GP 007 Torit Stacks

What to do Why to do it Opacity: less than or equal to 5 percent opacity Title I Condition: State Implementation Plan (SIP) for Lead NAAQS, 40 CFR pt. 50; 40 CFR pt. 51; 40 CFR pt. 52, subp. Y; MN SIP Lead Compounds: less than or equal to 0.00087 grains/dry standard cubic foot using 3-hour Average ( 3-hour arithmetic average). The ventilation air from all enclosures hoods and total enclosures shall be conveyed to a control device. 40 CFR Section 63.544(c); 40 CFR Section 63.544(d); 40 CFR Section 63.545(e); Minn. R. 7011.7240 PERFORMANCE TESTING REQUIREMENT (See also GP007) hdr Performance Test: due before end of each calendar 24 months following Permit Issuance to measure opacity, unless annual testing of lead or lead compounds is required. Opacity testing shall take place each time lead and/or lead compounds are tested. Title I Condition: State Implementation Plan (SIP) for Lead NAAQS, 40 CFR pt. 50; 40 CFR pt. 51; 40 CFR pt. 52, subp. Y; MN SIP Performance Test: due before end of each calendar year following Permit Issuance to measure emissions of lead compounds. Performance test frequency may be reduced to 24 calendar months, if lead compounds are emitted at a rate of 0.00044 gr/dscf or less. Use applicable Test Methods described in 40 CFR Section 63.547. 40 CFR Section 63.544(e); 40 CFR Section 63.544(f); Minn. R. 701.7240

## TABLE A: LIMITS AND OTHER REQUIREMENTS 06/29/10 Gopher Resource LLC 03700016 - 003 Facility Name: Permit Number: A-24

Subject Item: EU 021 Soda Ash Storage Bin
Associated Items: CE 006 Fabric Filter - Low Temperature, i.e., T<180 Degrees F SV 004 Soda Ash Storage Bin

What to do Why to do it EMISSION LIMITS hdr Total Particulate Matter: less than or equal to 0.3 grains/dry standard cubic foot of exhaust gas unless required to further reduce emissions to comply with the less stringent limit of either Minn. R. 7011.0730 or Minn. R. 7011.0735. Minn. R. 7011.0715, subp. 1(A)

Total Particulate Matter: less than or equal to 0.01 grains/dry standard cubic foot (basis for calculated potential emissions) Minn. R. 7005.0100, subp. 35a PM < 10 micron: less than or equal to 0.01 grains/dry standard cubic foot (basis for calculated potential emissions) Minn. R. 7005.0100, subp. 35a Opacity: less than or equal to 20 percent opacity Minn. R. 7011.0715, subp. 1(B) CONTROL REQUIREMENTS - See also Subject Item CE006 hdr The Permittee shall operate and maintain the fabric filter at all times that any emission unit controlled by the fabric filter is in operation. The Permittee shall document periods of non-operation of the control equipment. Minn. R. 7007.0800, subps. 2 and 14

## TABLE A: LIMITS AND OTHER REQUIREMENTS 06/29/10 Gopher Resource LLC 03700016 - 003 Facility Name: Permit Number: A-25

Subject Item: CE 001 Wet Scrubber-High Efficiency
Associated Items: EU 001 Raw Material Processing Operation

What to do Why to do it The Permittee shall operate and maintain the scrubber (CE001) at any time that the process equipment controlled by the scrubber (EU001) is in operation. The Permittee shall document periods of non-operation of the control equipment. Minn. R. 7007.0800, subps. 2 and 14

The Permittee shall operate and maintain the scrubber in accordance with the Operation and Maintenance (O & M) Plan. The Permittee shall keep copies of the O & M Plan available for use by staff and MPCA staff. Minn. R. 7007.0800, subp. 14

Pressure Drop: greater than or equal to 0.10 inches of water column and less than or equal to 6.0 inches of water column , unless a new range is set pursuant to Minn. R. 7017.2025, subp. 3 based on the values recorded during the most recent MPCA-approved performance test where compliance was demonstrated. The new range shall be implemented upon receipt of the Notice of Compliance letter granting preliminary approval. The range is final upon issuance of a permit amendment incorporating the change. The Permittee shall record the pressure drop at least once every 24 hours when in operation. Minn. R. 7007.0800, subps. 2 and 14

Water flow rate: greater than or equal to 8.0 gallons/minute and less than or equal to 9.0 gallons/minute , unless a new range is set pursuant to Minn. R. 7017.2025, subp. 3 based on the values recorded during the most recent MPCA-approved performance test where compliance was demonstrated. The new range shall be implemented upon receipt of the Notice of Compliance letter granting preliminary approval. The range is final upon issuance of a permit amendment incorporating the change. The Permittee shall record the water flow rate at least once every 24 hours when in operation. Minn. R. 7007.0800, subps. 2 and 14

Recordkeeping of Pressure Drop. The Permittee shall record the time and date of each pressure drop reading and whether or not the recorded pressure drop was within the range specified in this permit. Recorded values outside the range specified in this permit are considered Deviations as defined by Minn. R. 7007.0100, subp. 8a. Minn. R. 7007.0800, subps. 4 and 5

Recordkeeping of Water Flow Rate. The Permittee shall record the time and date of each water flow rate reading and whether or not the recorded water flow rate was within the range specified in this permit. Recorded values outside the range specified in this permit are considered Deviations as defined by Minn. R. 7007.0100, subp. 8a. Minn. R. 7007.0800, subps. 4 and 5

Monitoring Equipment: The Permittee shall install and maintain the necessary monitoring equipment for measuring and recording pressure drops, water pressures, and water flow rates required by this permit. The monitoring equipment must be installed, in use, and properly maintained when the monitored scrubber is in operation. Minn. R. 7007.0800, subp. 4

Periodic Inspections: At least once per calendar quarter, or more frequently as required by the manufacturing specifications, the Permittee shall inspect the control equipment components. The Permittee shall maintain a written record of these inspections. Minn. R. 7007.0800, subps. 4, 5 and 14

Corrective Actions: The Permittee shall take corrective action as soon as possible if any of the following occur: - the recorded pressure drop is outside the required operating range; - the recorded water flow rate is outside the required operating range; - the recorded water pressure is outside the required operating range; or - the scrubber or any of its components are found during the inspections to need repair. Corrective actions shall return the pressure drop, water flow rate, and/or water pressure to within the permitted range; and/or include completion of necessary repairs identified during the inspection, as applicable. Corrective actions include, but are not limited to, those outlined in the O & M Plan for the scrubber. The Permittee shall keep a record of the type and date of any corrective action taken for the scrubber. Minn. R. 7007.0800, subps. 4, 5, and 14

## TABLE A: LIMITS AND OTHER REQUIREMENTS 06/29/10 Gopher Resource LLC 03700016 - 003 Facility Name: Permit Number: A-26

Subject Item: CE 002 Fabric Filter - Low Temperature, i.e., T<180 Degrees F
Associated Items: FS 001 Furnace Area Process Fugitives FS 005 Casting Machine Process Fugitives FS 006 Refining Area Fugitive Dust Sources GP 004 NESHAP Subpart X Control Equipment Monitoring Requirements GP 008 Torit Filter Banks

What to do Why to do it The Permittee shall operate and maintain the fabric filter in accordance with the Operation and Maintenance (O & M) Plan. The Permittee shall keep copies of the O & M Plan available onsite for use by staff and MPCA staff. Minn. R. 7007.0800, subp. 14; 40 CFR Section 63.548(a); Minn. R. 7011.7240

A ir Pollution Control Equipment Monitors: The owner or operator shall operate and maintain pressure drop gauges and broken media detectors, to measure pressure drop across the cartridge filters and baghouse cells in inches of water and an increase in particulate grain loading at each baghouse and cartridge filter outlet. Each broken media detector shall be equipped with a device that continually records grain loading, and an alarm that alerts the owner or operator of increases in grain loading.
A larm Triggers: In the event that the alarm on a broken media detector is triggered, the owner or operator shall immediately isolate the cartridge bank or baghouse cell for which the alarm was triggered as described in Appendix G of this permit. See Also Subject Item GP004, for additional broken media detection requirements (NESHAP Subpart X) Title I Condition: State Implementation Plan (SIP) for Lead NAAQS; 40 CFR pt. 50; 40 CFR pt. 51; 40 CFR pt. 52, subp. Y; MN SIP

Broken media detectors are not required for cartridge collectors used exclusively for the control of fugitive dust emissions from any source subject to the lead emissions standard in 40 CFR Section 63.545. (THIS REQUIREMENT WILL BECOME EFFECTIVE THE DATE EPA APPROVES THE REVISION INTO THE SIP.) Title I Condition: State Implementation Plan (SIP) for Lead NAAQS; 40 CFR pt. 50; 40 CFR pt. 51; 40 CFR pt. 52, subp. Y; MN SIP; 40 CFR Section 63.548(h)

The Permittee shall operate and maintain the control equipment such that it achieves an overall control efficiency for Total Particulate Matter: greater than or equal to 99 percent control efficiency Minn. R. 7007.0800, subps. 2 and 14

The Permittee shall operate and maintain the control equipment such that it achieves an overall control efficiency for PM < 10 micron: greater than or equal to 99 percent control efficiency Minn. R. 7007.0800, subps. 2 and 14

The Permittee shall operate and maintain the control equipment such that it achieves an overall control efficiency for PM < 2.5 micron: greater than or equal to 99 percent control efficiency Minn. R. 7007.0800, subps. 2 and 14

Pressure Drop: greater than or equal to 0.5 inches of water column and less than or equal to 15.0 inches of water column , unless a new range is set pursuant to Minn. R. 7017.2025, subp. 3 based on the values recorded during the most recent MPCA-approved performance test where compliance was demonstrated. The new range shall be implemented upon receipt of the Notice of Compliance letter granting preliminary approval. The range is final upon issuance of a permit amendment incorporating the change. Title I Condition: State Implementation Plan (SIP) for Lead NAAQS; 40 CFR pt. 50; 40 CFR pt. 51; 40 CFR pt. 52, subp. Y; MN SIP

Daily Inspections: The Permittee shall read and record the pressure drop across the fabric filter, once every 24 hours. Minn. R. 7007.0800, subps. 2 and 14; Minn. R. 7017.0200; 40 CFR Section 63.548(c)(1) Recordkeeping of Pressure Drop: The Permittee shall record the time and date of each pressure drop reading, and whether or not the observed pressure drop was within the range specified in this permit. Recorded values outside the range specified in this permit are considered Deviations as defined by Minn. R. 7007.0100, subp. 8a. Minn. R. 7007.0800, subps. 2 and 14

Periodic Inspections: The Permittee shall inspect the fabric filter as described in A ppendix K. Title I Condition: State Implementation Plan (SIP) for Lead NAAQS; 40 CFR pt. 50; 40 CFR pt. 51; 40 CFR pt. 52, subp. Y; MN SIP Corrective Actions: The Permittee shall take corrective action as soon as possible if any of the following occur: - the recorded pressure drop is outside the required operating range; or - the filter or any of its components are found during the inspections to need repair. Corrective actions shall return the pressure drop to within the permitted range, and/or include completion of necessary repairs identified during the inspection, as applicable. Corrective actions include, but are not limited to, those outlined in the O & M Plan for the filter. The Permittee shall keep a record of the type and date of any corrective action taken for each filter. Minn. R. 7007.0800, subps. 4, 5, and 14

## TABLE A: LIMITS AND OTHER REQUIREMENTS 06/29/10 Gopher Resource LLC 03700016 - 003 Facility Name: Permit Number: A-27

The Permittee shall monthly test each pressure drop gauge and broken media detector, clean the broken media detector, and repair and replace gauges and detectors in accordance with Appendix G. The Permittee shall maintain records of such testing and actions taken as a result of the testing. Title I Condition: State Implementation Plan (SIP) for Lead NAAQS; 40 CFR pt. 50; 40 CFR pt. 51; 40 CFR pt. 52, subp. Y; MN SIP

## TABLE A: LIMITS AND OTHER REQUIREMENTS 06/29/10 Gopher Resource LLC 03700016 - 003 Facility Name: Permit Number: A-28

Subject Item: CE 003 Fabric Filter - Low Temperature, i.e., T<180 Degrees F
Associated Items: FS 001 Furnace Area Process Fugitives GP 004 NESHAP Subpart X Control Equipment Monitoring Requirements GP 008 Torit Filter Banks

What to do Why to do it The Permittee shall operate and maintain the fabric filter in accordance with the Operation and Maintenance (O & M) Plan. The Permittee shall keep copies of the O & M Plan available onsite for use by staff and MPCA staff. Minn. R. 7007.0800, subp. 14; 40 CFR Section 63.548(a); Minn. R. 7011.7240

A ir Pollution Control Equipment Monitors: The owner or operator shall operate and maintain pressure drop gauges and broken media detectors, to measure pressure drop across the cartridge filters and baghouse cells in inches of water and an increase in particulate grain loading at each baghouse and cartridge filter outlet. Each broken media detector shall be equipped with a device that continually records grain loading, and an alarm that alerts the owner or operator of increases in grain loading.
A larm Triggers: In the event that the alarm on a broken media detector is triggered, the owner or operator shall immediately isolate the cartridge bank or baghouse cell for which the alarm was triggered as described in Appendix G of this permit. See Also Subject Item GP004, for additional broken media detection requirements (NESHAP Subpart X) Title I Condition: State Implementation Plan (SIP) for Lead NAAQS; 40 CFR pt. 50; 40 CFR pt. 51; 40 CFR pt. 52, subp. Y; MN SIP

The Permittee shall operate and maintain the control equipment such that it achieves an overall control efficiency for Total Particulate Matter: greater than or equal to 99 percent control efficiency Minn. R. 7007.0800, subps. 2 and 14

The Permittee shall operate and maintain the control equipment such that it achieves an overall control efficiency for PM < 10 micron: greater than or equal to 99 percent control efficiency Minn. R. 7007.0800, subps. 2 and 14

The Permittee shall operate and maintain the control equipment such that it achieves an overall control efficiency for PM < 2.5 micron: greater than or equal to 99 percent control efficiency Minn. R. 7007.0800, subps. 2 and 14

Pressure Drop: greater than or equal to 0.5 inches of water column and less than or equal to 15.0 inches of water column , unless a new range is set pursuant to Minn. R. 7017.2025, subp. 3 based on the values recorded during the most recent MPCA-approved performance test where compliance was demonstrated. The new range shall be implemented upon receipt of the Notice of Compliance letter granting preliminary approval. The range is final upon issuance of a permit amendment incorporating the change. Title I Condition: State Implementation Plan (SIP) for Lead NAAQS; 40 CFR pt. 50; 40 CFR pt. 51; 40 CFR pt. 52, subp. Y; MN SIP

Daily Inspections: The Permittee shall read and record the pressure drop across the fabric filter, once every 24 hours. Minn. R. 7007.0800, subps. 2 and 14; Minn. R. 7017.0200; 40 CFR Section 63.548(c)(1) Recordkeeping of Pressure Drop: The Permittee shall record the time and date of each pressure drop reading, and whether or not the observed pressure drop was within the range specified in this permit. Recorded values outside the range specified in this permit are considered Deviations as defined by Minn. R. 7007.0100, subp. 8a. Minn. R. 7007.0800, subps. 2 and 14

Periodic Inspections: The Permittee shall inspect the fabric filter as described in A ppendix K. Title I Condition: State Implementation Plan (SIP) for Lead NAAQS; 40 CFR pt. 50; 40 CFR pt. 51; 40 CFR pt. 52, subp. Y; MN SIP Corrective Actions: The Permittee shall take corrective action as soon as possible if any of the following occur: - the recorded pressure drop is outside the required operating range; or - the filter or any of its components are found during the inspections to need repair. Corrective actions shall return the pressure drop to within the permitted range, and/or include completion of necessary repairs identified during the inspection, as applicable. Corrective actions include, but are not limited to, those outlined in the O & M Plan for the filter. The Permittee shall keep a record of the type and date of any corrective action taken for each filter. Minn. R. 7007.0800, subps. 4, 5, and 14

The Permittee shall monthly test each pressure drop gauge and broken media detector, clean the broken media detector, and repair and replace gauges and detectors in accordance with Appendix G. The Permittee shall maintain records of such testing and actions taken as a result of the testing. Title I Condition: State Implementation Plan (SIP) for Lead NAAQS; 40 CFR pt. 50; 40 CFR pt. 51; 40 CFR pt. 52, subp. Y; MN SIP

## TABLE A: LIMITS AND OTHER REQUIREMENTS 06/29/10 Gopher Resource LLC 03700016 - 003 Facility Name: Permit Number: A-29

Subject Item: CE 004 Fabric Filter - High Temperature, i.e., T>250 Degrees F
Associated Items: EU 004 West Reverberatory Furnace EU 007 East Reverberatory Furnace
EU 009 Blast Furnace EU 011 Refining Kettle No. 1 EU 012 Refining Kettle No. 2 EU 013 Refining Kettle No. 3 EU 014 Refining Kettle No. 4 EU 015 Refining Kettle No. 5 EU 016 Refining Kettle No. 6 EU 017 Refining Kettle No. 7 EU 018 Refining Kettle No. 8 EU 019 Refining Kettle No. 9 EU 020 Refining Kettle No. 10 FS 003 East Reverberatory Furnace Process Fugitives FS 004 Blast Furnace Process Fugitives GP 004 NESHAP Subpart X Control Equipment Monitoring Requirements

What to do Why to do it The Permittee shall operate and maintain the fabric filters (CE004 and CE005) at all times that any associated emission unit is in operation, unless negative pressure in the building can be maintained while the filter is not in operation. If either of CE004 or CE005 is one of two or more filters that are not operating while any unit listed above under "Associated Items" is operating, the Permittee shall follow the procedures in Appendix H for demonstrating that the building is under negative pressure. The Permittee shall document periods of non-operation of the control equipment that result in loss of building negative pressure, and take immediate corrective action as described in Appendix H. Minn. R. 7007.0800, subps. 2 and 14

The Permittee shall operate and maintain the fabric filter in accordance with the Operation and Maintenance (O & M) Plan. The Permittee shall keep copies of the O & M Plan available onsite for use by staff and MPCA staff. Minn. R. 7007.0800, subp. 14; 40 CFR Section 63.548(a); Minn. R. 7011.7240

A ir Pollution Control Equipment Monitors: The Permittee shall operate and maintain pressure drop gauges and broken media detectors, to measure pressure drop across the cartridge filters and baghouse cells in inches of water and an increase in particulate grain loading at each baghouse and cartridge filter outlet. Each broken media detector shall be equipped with a device that continually records grain loading, and an alarm that alerts the owner or operator of increases in grain loading.
A larm Triggers: In the event that the alarm on a broken media detector is triggered, the owner or operator shall immediately isolate the cartridge bank or baghouse cell for which the alarm was triggered as described in Appendix G of this permit. See Also Subject Item GP004, for additional broken media detection requirements (NESHAP Subpart X) Title I Condition: State Implementation Plan (SIP) for Lead NAAQS; 40 CFR pt. 50; 40 CFR pt. 51; 40 CFR pt. 52, subp. Y; MN SIP

The Permittee shall operate and maintain the control equipment such that it achieves an overall control efficiency for Total Particulate Matter: greater than or equal to 99 percent control efficiency Minn. R. 7007.0800, subps. 2 and 14

The Permittee shall operate and maintain the control equipment such that it achieves an overall control efficiency for PM < 10 micron: greater than or equal to 99 percent control efficiency Minn. R. 7007.0800, subps. 2 and 14

The Permittee shall operate and maintain the control equipment such that it achieves an overall control efficiency for PM < 2.5 micron: greater than or equal to 99 percent control efficiency Minn. R. 7007.0800, subps. 2 and 14

## TABLE A: LIMITS AND OTHER REQUIREMENTS 06/29/10 Gopher Resource LLC 03700016 - 003 Facility Name: Permit Number: A-30

Pressure Drop: greater than or equal to 1.0 inches of water column and less than or equal to 10.0 inches of water column , unless a new range is set pursuant to Minn. R. 7017.2025, subp. 3 based on the values recorded during the most recent MPCA-approved performance test where compliance was demonstrated. The new range shall be implemented upon receipt of the Notice of Compliance letter granting preliminary approval. The range is final upon issuance of a permit amendment incorporating the change. Title I Condition: State Implementation Plan (SIP) for Lead NAAQS; 40 CFR pt. 50; 40 CFR pt. 51; 40 CFR pt. 52, subp. Y; MN SIP

Daily Inspections: The Permittee shall read and record the pressure drop across the fabric filter, once every 24 hours. Minn. R. 7007.0800, subps. 2 and 14; 40 CFR Section 64.3; Minn. R. 7017.0200; 40 CFR Section 63.548(c)(1) Recordkeeping of Pressure Drop: The Permittee shall record the time and date of each pressure drop reading, and whether or not the observed pressure drop was within the range specified in this permit. Recorded values outside the range specified in this permit are considered Deviations as defined by Minn. R. 7007.0100, subp. 8a. Minn. R. 7007.0800, subps. 2 and 14; 40 CFR Section 64.3; Minn. R. 7017.0200

Periodic Inspections: The Permittee shall inspect the fabric filter as described in A ppendix K. Title I Condition: State Implementation Plan (SIP) for Lead NAAQS; 40 CFR pt. 50; 40 CFR pt. 51; 40 CFR pt. 52, subp. Y; MN SIP; 40 CFR Section 64.3; Minn. R. 7017.0200 Corrective Actions: The Permittee shall take corrective action as soon as possible if any of the following occur: - the recorded pressure drop is outside the required operating range; or - the fabric filter or any of its components are found during the inspections to need repair. Corrective actions shall return the pressure drop to within the permitted range, and/or include completion of necessary repairs identified during the inspection, as applicable. Corrective actions include, but are not limited to, those outlined in the O & M Plan for the fabric filter. The Permittee shall keep a record of the type and date of any corrective action taken for each filter. 40 CFR Section 64.7(d); Minn. R. 7017.0200

Monitoring Equipment: The Permittee shall install and maintain the necessary monitoring equipment for measuring and recording pressure drop as required by this permit. The monitoring equipment must be installed, in use, and properly maintained when the monitored fabric filter is in operation. 40 CFR Section 64.7(b); Minn. R. 7017.0200

The Permittee shall monthly test each pressure drop gauge and broken media detector, clean the broken media detector, and repair and replace gauges and detectors in accordance with Appendix G. The Permittee shall maintain records of such testing and actions taken as a result of the testing. Title I Condition: State Implementation Plan (SIP) for Lead NAAQS; 40 CFR pt. 50; 40 CFR pt. 51; 40 CFR pt. 52, subp. Y; MN SIP The Permittee shall calibrate the pressure gauge at least once every 12 months and shall maintain a written record of any action resulting from the calibration. 40 CFR Section 64.3; Minn. R. 7017.0200 Documentation of Need for Improved Monitoring: If the Permittee fails to achieve compliance with an emission limitation or standard for which the monitoring did not provide an indication of an excursion or exceedance while providing valid data, or the results of compliance or performance testing document a need to modify the existing pressure drop range, the Permittee shall promptly notify the MPCA and, if necessary, submit a permit amendment application to address the necessary monitoring change. 40 CFR Section 64.7(e); Minn. R. 7017.0200

A s required by 40 CFR Section 64.9(a)(2), for the Semi-Annual Deviations Report listed in Table B of this permit and/or the Notification of Deviations Endangering Human Health and the Environment listed earlier in Table A of this permit, as applicable, the Permittee shall include the following related to the monitoring identified as required by 40 CFR pt. 64: 1) Summary information on the number, duration, and cause of excursions or exceedances, as applicable, and the corrective action taken; and 2) Summary information on the number, duration, and cause for monitor downtime incidents. 40 CFR Section 64.9(a)(2); Minn. R. 7017.0200

The Permittee shall maintain records of monitoring data, monitor performance data, corrective actions taken, and other supporting information required to be maintained. The Permittee may maintain records on alternative media, such as microfilm, computer files, magnetic tape disks, or microfiche, provided that the use of such alternative media allows for expeditious inspection and review, and does not conflict with other applicable recordkeeping requirements. 40 CFR Section 64.9(b); Minn. R. 7017.0200

## TABLE A: LIMITS AND OTHER REQUIREMENTS 06/29/10 Gopher Resource LLC 03700016 - 003 Facility Name: Permit Number: A-31

Subject Item: CE 005 Fabric Filter - High Temperature, i.e., T>250 Degrees F
Associated Items: EU 004 West Reverberatory Furnace EU 006 Scrap Dryer EU 007 East Reverberatory Furnace
EU 009 Blast Furnace FS 002 West Reverberatory Furnace Process Fugitives FS 003 East Reverberatory Furnace Process Fugitives GP 004 NESHAP Subpart X Control Equipment Monitoring Requirements

What to do Why to do it The Permittee shall operate and maintain the fabric filters (CE004 and CE005) at all times that any associated emission unit is in operation, unless negative pressure in the building can be maintained while the filter is not in operation. If either of CE004 or CE005 is one of two or more filters that are not operating while any unit listed above under "Associated Items" is operating, the Permittee shall follow the procedures in Appendix H for demonstrating that the building is under negative pressure. The Permittee shall document periods of non-operation of the control equipment that result in loss of building negative pressure, and take immediate corrective action as described in Appendix H. Minn. R. 7007.0800, subps. 2 and 14

The Permittee shall operate and maintain the fabric filter in accordance with the Operation and Maintenance (O & M) Plan. The Permittee shall keep copies of the O & M Plan available onsite for use by staff and MPCA staff. Minn. R. 7007.0800, subp. 14; 40 CFR Section 63.548(a); Minn. R. 7011.7240

A ir Pollution Control Equipment Monitors: The Permittee shall operate and maintain pressure drop gauges and broken media detectors, to measure pressure drop across the cartridge filters and baghouse cells in inches of water and an increase in particulate grain loading at each baghouse and cartridge filter outlet. Each broken media detector shall be equipped with a device that continually records grain loading, and an alarm that alerts the owner or operator of increases in grain loading.
A larm Triggers: In the event that the alarm on a broken media detector is triggered, the owner or operator shall immediately isolate the cartridge bank or baghouse cell for which the alarm was triggered as described in Appendix G of this permit. See Also Subject Item GP004, for additional broken media detection requirements (NESHAP Subpart X) Title I Condition: State Implementation Plan (SIP) for Lead NAAQS; 40 CFR pt. 50; 40 CFR pt. 51; 40 CFR pt. 52, subp. Y; MN SIP

The Permittee shall operate and maintain the control equipment such that it achieves an overall control efficiency for Total Particulate Matter: greater than or equal to 99 percent control efficiency Minn. R. 7007.0800, subps. 2 and 14

The Permittee shall operate and maintain the control equipment such that it achieves an overall control efficiency for PM < 10 micron: greater than or equal to 99 percent control efficiency Minn. R. 7007.0800, subps. 2 and 14

The Permittee shall operate and maintain the control equipment such that it achieves an overall control efficiency for PM < 2.5 micron: greater than or equal to 99 percent control efficiency Minn. R. 7007.0800, subps. 2 and 14

Pressure Drop: greater than or equal to 1.0 inches of water column and less than or equal to 10.0 inches of water column , unless a new range is set pursuant to Minn. R. 7017.2025, subp. 3 based on the values recorded during the most recent MPCA-approved performance test where compliance was demonstrated. The new range shall be implemented upon receipt of the Notice of Compliance letter granting preliminary approval. The range is final upon issuance of a permit amendment incorporating the change. Title I Condition: State Implementation Plan (SIP) for Lead NAAQS; 40 CFR pt. 50; 40 CFR pt. 51; 40 CFR pt. 52, subp. Y; MN SIP

Daily Inspections: The Permittee shall read and record the pressure drop across the fabric filter, once every 24 hours. Minn. R. 7007.0800, subps. 2 and 14; 40 CFR Section 64.3; Minn. R. 7017.0200; 40 CFR Section 63.548(c)(1) Recordkeeping of Pressure Drop: The Permittee shall record the time and date of each pressure drop reading, and whether or not the observed pressure drop was within the range specified in this permit. Recorded values outside the range specified in this permit are considered Deviations as defined by Minn. R. 7007.0100, subp. 8a. Minn. R. 7007.0800, subps. 2 and 14; 40 CFR Section 64.3; Minn. R. 7017.0200

Periodic Inspections: The Permittee shall inspect the fabric filter as described in A ppendix K. Title I Condition: State Implementation Plan (SIP) for Lead NAAQS; 40 CFR pt. 50; 40 CFR pt. 51; 40 CFR pt. 52, subp. Y; MN SIP; 40 CFR Section 64.3; Minn. R. 7017.0200

## TABLE A: LIMITS AND OTHER REQUIREMENTS 06/29/10 Gopher Resource LLC 03700016 - 003 Facility Name: Permit Number: A-32

Corrective Actions: The Permittee shall take corrective action as soon as possible if any of the following occur: - the recorded pressure drop is outside the required operating range; or - the fabric filter or any of its components are found during the inspections to need repair. Corrective actions shall return the pressure drop to within the permitted range, and/or include completion of necessary repairs identified during the inspection, as applicable. Corrective actions include, but are not limited to, those outlined in the O & M Plan for the fabric filter. The Permittee shall keep a record of the type and date of any corrective action taken for each filter. 40 CFR Section 64.7(d); Minn. R. 7017.0200

Monitoring Equipment: The Permittee shall install and maintain the necessary monitoring equipment for measuring and recording pressure drop as required by this permit. The monitoring equipment must be installed, in use, and properly maintained when the monitored fabric filter is in operation. 40 CFR Section 64.7(b); Minn. R. 7017.0200

The Permittee shall monthly test each pressure drop gauge and broken media detector, clean the broken media detector, and repair and replace gauges and detectors in accordance with Appendix G. The Permittee shall maintain records of such testing and actions taken as a result of the testing. Title I Condition: State Implementation Plan (SIP) for Lead NAAQS; 40 CFR pt. 50; 40 CFR pt. 51; 40 CFR pt. 52, subp. Y; MN SIP The Permittee shall calibrate the pressure gauge at least once every 12 months and shall maintain a written record of any action resulting from the calibration. 40 CFR Section 64.3; Minn. R. 7017.0200 Documentation of Need for Improved Monitoring: If the Permittee fails to achieve compliance with an emission limitation or standard for which the monitoring did not provide an indication of an excursion or exceedance while providing valid data, or the results of compliance or performance testing document a need to modify the existing pressure drop range, the Permittee shall promptly notify the MPCA and, if necessary, submit a permit amendment application to address the necessary monitoring change. 40 CFR Section 64.7(e); Minn. R. 7017.0200

A s required by 40 CFR Section 64.9(a)(2), for the Semi-Annual Deviations Report listed in Table B of this permit and/or the Notification of Deviations Endangering Human Health and the Environment listed earlier in Table A of this permit, as applicable, the Permittee shall include the following related to the monitoring identified as required by 40 CFR pt. 64: 1) Summary information on the number, duration, and cause of excursions or exceedances, as applicable, and the corrective action taken; and 2) Summary information on the number, duration, and cause for monitor downtime incidents. 40 CFR Section 64.9(a)(2); Minn. R. 7017.0200

The Permittee shall maintain records of monitoring data, monitor performance data, corrective actions taken, and other supporting information required to be maintained. The Permittee may maintain records on alternative media, such as microfilm, computer files, magnetic tape disks, or microfiche, provided that the use of such alternative media allows for expeditious inspection and review, and does not conflict with other applicable recordkeeping requirements. 40 CFR Section 64.9(b); Minn. R. 7017.0200

## TABLE A: LIMITS AND OTHER REQUIREMENTS 06/29/10 Gopher Resource LLC 03700016 - 003 Facility Name: Permit Number: A-33

Subject Item: CE 006 Fabric Filter - Low Temperature, i.e., T<180 Degrees F
Associated Items: EU 021 Soda Ash Storage Bin

What to do Why to do it The Permittee shall operate and maintain the fabric filter at all times that any emission unit controlled by the fabric filter is in operation. The Permittee shall document periods of non-operation of the control equipment. Minn. R. 7007.0800, subps. 2 and 14

The Permittee shall operate and maintain the fabric filter in accordance with the Operation and Maintenance (O & M) Plan. The Permittee shall keep copies of the O & M Plan available onsite for use by staff and MPCA staff. Minn. R. 7007.0800, subp. 14

The Permittee shall operate and maintain the control equipment such that it achieves an overall control efficiency for Total Particulate Matter: greater than or equal to 99 percent control efficiency Minn. R. 7007.0800, subps. 2 and 14

The Permittee shall operate and maintain the control equipment such that it achieves an overall control efficiency for PM < 10 micron: greater than or equal to 99 percent control efficiency Minn. R. 7007.0800, subps. 2 and 14

The Permittee shall operate and maintain the control equipment such that it achieves an overall control efficiency for PM < 2.5 micron: greater than or equal to 99 percent control efficiency Minn. R. 7007.0800, subps. 2 and 14

Monitoring Equipment: The Permittee shall install and maintain the necessary monitoring equipment for measuring and recording pressure drop as required by this permit. The monitoring equipment must be installed, in use, and properly maintained when the monitored fabric filter is in operation. Minn. R. 7007.0800, subp. 4

Visible Emissions: The Permittee shall check the fabric filter stack (SV004) for any visible emissions once each day of operation during daylight hours. During inclement weather, the Permittee shall read and record the pressure drop across the fabric filter, once each day of operation. Minn. R. 7007.0800, subps. 4 and 5

Pressure Drop: greater than or equal to 1.0 inches of water column and less than or equal to 7.0 inches of water column , unless a new range is set pursuant to Minn. R. 7017.2025, subp. 3 based on the values recorded during the most recent MPCA-approved performance test where compliance was demonstrated. The new range shall be implemented upon receipt of the Notice of Compliance letter granting preliminary approval. The range is final upon issuance of a permit amendment incorporating the change. Minn. R. 7007.0800, subps. 2 and 14

Recordkeeping of Visible Emissions and Pressure Drop. The Permittee shall record the time and date of each visible emission inspection and pressure drop reading, and whether or not any visible emissions were observed, and whether or not the observed pressure drop was within the range specified in this permit Minn. R. 7007.0800, subps. 4 and 5

Periodic Inspections: At least once per calendar quarter, or more frequently as required by the manufacturing specifications, the Permittee shall inspect the control equipment components. The Permittee shall maintain a written record of these inspections. Minn. R. 7007.0800, subps. 4, 5 and 14

Corrective Actions: The Permittee shall take corrective action as soon as possible if any of the following occur: - visible emissions are observed; - the recorded pressure drop is outside the required operating range; or - the fabric filter or any of its components are found during the inspections to need repair. Corrective actions shall return the pressure drop to within the permitted range, eliminate visible emissions, and/or include completion of necessary repairs identified during the inspection, as applicable. Corrective actions include, but are not limited to, those outlined in the O & M Plan for the fabric filter. The Permittee shall keep a record of the type and date of any corrective action taken for the filter. Minn. R. 7007.0800, subps. 4, 5, and 14

## TABLE A: LIMITS AND OTHER REQUIREMENTS 06/29/10 Gopher Resource LLC 03700016 - 003 Facility Name: Permit Number: A-34

Subject Item: CE 007 Afterburner
Associated Items: EU 007 East Reverberatory Furnace
EU 009 Blast Furnace

What to do Why to do it CE007 MONITORING REQUIREMENTS hdr The owner or operator of a blast furnace or collocated blast furnace and reverberatory furnace subject to the total hydrocarbon standards in 40 CFR Section 63.543(c), (d), or (e) must comply with the requirements of either 40 CFR Section 63.548(j)(1) or (j)(2), to demonstrate continuous compliance with the total hydrocarbon emission standards. The Permittee proposed an alternative monitoring plan of monitoring reverberatory furnace natural gas flow instead of continuous temperature. This plan was approved by the EPA on July 29, 1998. 40 CFR Section 63.548(j); Minn. R. 7011.7240

Gopher Resource shall continuously record and monitor the natural gas or propane usage for the east reverberatory furnace. 40 CFR Section 63.8(f) [Alternative Monitoring Method] Methodology: The owner or operator shall calculate 3-hour arithmetic average of the natural gas usage and the afterburner temperature from the 15-minute readings. The compliance demonstration shall follow the test protocol, and show compliance with the 20 ppm THC standard when the blast furnace and the east reverberatory furnace both operate. 40 CFR Section 63.8(f) [Alternative Monitoring Method]

Whenever the blast furnace and the east reverberatory furnace both operating to show compliance with the THC standard of 20 ppm, Gopher Resource shall: 1. Maintain the natural gas usage at or above the arithmetic average established in most recent EPA and MPCA approved compliance test.
OR 2. Maintain the propane usage at or above the arithmetic average established in most recent EPA and MPCA approved compliance test. 40 CFR Section 63.8(f) [Alternative Monitoring Method]

Reporting: The owner or operator shall report to U.S. EPA and copy to the MPCA on a semiannually basis whether any 3-hour arithmetic average natural gas usage or propane usage is less than the arithmetic average established in the most EPA and MPCA approved compliance test. Once any 3-hour usage is less than the established average, report on a quarterly basis until a request to reduce reporting frequency is approved by the EPA. 40 CFR Section 63.8(f) [Alternative Monitoring Method]

Calibration of Continuous Monitoring Device: The Company shall service and calibrate the monitoring instrument at 1-year intervals and keep records of all calibrations for at least 5 years. 40 CFR Section 63.8(f) [Alternative Monitoring Method]

## TABLE A: LIMITS AND OTHER REQUIREMENTS 06/29/10 Gopher Resource LLC 03700016 - 003 Facility Name: Permit Number: A-35

Subject Item: CE 008 Fabric Filter - Low Temperature, i.e., T<180 Degrees F
Associated Items: EU 002 Raw Material Handling Operation FS 001 Furnace Area Process Fugitives GP 004 NESHAP Subpart X Control Equipment Monitoring Requirements GP 008 Torit Filter Banks

What to do Why to do it The Permittee shall operate and maintain the fabric filter in accordance with the Operation and Maintenance (O & M) Plan. The Permittee shall keep copies of the O & M Plan available onsite for use by staff and MPCA staff. Minn. R. 7007.0800, subp. 14; 40 CFR Section 63.548(a); Minn. R. 7011.7240 The Permittee shall operate and maintain the control equipment such that it achieves an overall control efficiency for Total Particulate Matter: greater than or equal to 99 percent control efficiency Minn. R. 7007.0800, subps. 2 and 14

The Permittee shall operate and maintain the control equipment such that it achieves an overall control efficiency for PM < 10 micron: greater than or equal to 99 percent control efficiency Minn. R. 7007.0800, subps. 2 and 14

The Permittee shall operate and maintain the control equipment such that it achieves an overall control efficiency for PM < 2.5 micron: greater than or equal to 99 percent control efficiency Minn. R. 7007.0800, subps. 2 and 14

Monitoring Equipment: The Permittee shall install and maintain the necessary monitoring equipment for measuring and recording pressure drop as required by this permit. The monitoring equipment must be installed, in use, and properly maintained when the monitored fabric filter is in operation. Minn. R. 7007.0800, subp. 4

Pressure Drop: greater than or equal to 0.5 inches of water column and less than or equal to 15.0 inches of water column , unless a new range is set pursuant to Minn. R. 7017.2025, subp. 3 based on the values recorded during the most recent MPCA-approved performance test where compliance was demonstrated. The new range shall be implemented upon receipt of the Notice of Compliance letter granting preliminary approval. The range is final upon issuance of a permit amendment incorporating the change. Minn. R. 7007.0800, subps. 2 and 14

The Permittee shall record the pressure drop at least once every 24 hours when in operation. Minn. R. 7007.0800, subps. 2 and 14; 40 CFR Section 63.548(c)(1); Minn. R. 7011.7240 Recordkeeping of Pressure Drop. The Permittee shall record the time and date of each pressure drop reading and whether or not the recorded pressure drop was within the range specified in this permit. Minn. R. 7007.0800, subps. 4 and 5

Periodic Inspections: At least once per calendar quarter, or more frequently as required by the manufacturing specifications and/or 40 CFR Section 63.548(c), the Permittee shall inspect the control equipment components. The Permittee shall maintain a written record of these inspections. Minn. R. 7007.0800, subps. 4, 5 and 14; 40 CFR Section 63.548(c); Minn. R. 7011.7240

Corrective Actions: The Permittee shall take corrective action as soon as possible if any of the following occur: - the recorded pressure drop is outside the required operating range; or - the fabric filter or any of its components are found during the inspections to need repair. Corrective actions shall return the pressure drop to within the permitted range, and/or include completion of necessary repairs identified during the inspection, as applicable. Corrective actions include, but are not limited to, those outlined in the O & M Plan for the fabric filter. The Permittee shall keep a record of the type and date of any corrective action taken for each filter. Minn. R. 7007.0800, subps. 4, 5, and 14

## TABLE A: LIMITS AND OTHER REQUIREMENTS 06/29/10 Gopher Resource LLC 03700016 - 003 Facility Name: Permit Number: A-36

Subject Item: CE 009 Fabric Filter - Low Temperature, i.e., T<180 Degrees F
Associated Items: EU 002 Raw Material Handling Operation GP 004 NESHAP Subpart X Control Equipment Monitoring Requirements GP 008 Torit Filter Banks

What to do Why to do it The Permittee shall operate and maintain the fabric filter in accordance with the Operation and Maintenance (O & M) Plan. The Permittee shall keep copies of the O & M Plan available onsite for use by staff and MPCA staff. Minn. R. 7007.0800, subp. 14; 40 CFR Section 63.548(a); Minn. R. 7011.7240 The Permittee shall operate and maintain the control equipment such that it achieves an overall control efficiency for Total Particulate Matter: greater than or equal to 99 percent control efficiency Minn. R. 7007.0800, subps. 2 and 14

The Permittee shall operate and maintain the control equipment such that it achieves an overall control efficiency for PM < 10 micron: greater than or equal to 99 percent control efficiency Minn. R. 7007.0800, subps. 2 and 14

The Permittee shall operate and maintain the control equipment such that it achieves an overall control efficiency for PM < 2.5 micron: greater than or equal to 99 percent control efficiency Minn. R. 7007.0800, subps. 2 and 14

Monitoring Equipment: The Permittee shall install and maintain the necessary monitoring equipment for measuring and recording pressure drop as required by this permit. The monitoring equipment must be installed, in use, and properly maintained when the monitored fabric filter is in operation. Minn. R. 7007.0800, subp. 4

Pressure Drop: greater than or equal to 0.5 inches of water column and less than or equal to 15.0 inches of water column , unless a new range is set pursuant to Minn. R. 7017.2025, subp. 3 based on the values recorded during the most recent MPCA-approved performance test where compliance was demonstrated. The new range shall be implemented upon receipt of the Notice of Compliance letter granting preliminary approval. The range is final upon issuance of a permit amendment incorporating the change. Minn. R. 7007.0800, subps. 2 and 14

The Permittee shall record the pressure drop at least once every 24 hours when in operation. Minn. R. 7007.0800, subps. 2 and 14; 40 CFR Section 63.548(c)(1); Minn. R. 7011.7240 Recordkeeping of Pressure Drop. The Permittee shall record the time and date of each pressure drop reading and whether or not the recorded pressure drop was within the range specified in this permit. Minn. R. 7007.0800, subps. 4 and 5

Periodic Inspections: At least once per calendar quarter, or more frequently as required by the manufacturing specifications and/or 40 CFR Section 63.548(c), the Permittee shall inspect the control equipment components. The Permittee shall maintain a written record of these inspections. Minn. R. 7007.0800, subps. 4, 5 and 14; 40 CFR Section 63.548(c); Minn. R. 7011.7240

Corrective Actions: The Permittee shall take corrective action as soon as possible if any of the following occur: - the recorded pressure drop is outside the required operating range; or - the fabric filter or any of its components are found during the inspections to need repair. Corrective actions shall return the pressure drop to within the permitted range, and/or include completion of necessary repairs identified during the inspection, as applicable. Corrective actions include, but are not limited to, those outlined in the O & M Plan for the fabric filter. The Permittee shall keep a record of the type and date of any corrective action taken for each filter. Minn. R. 7007.0800, subps. 4, 5, and 14

## TABLE A: LIMITS AND OTHER REQUIREMENTS 06/29/10 Gopher Resource LLC 03700016 - 003 Facility Name: Permit Number: A-37

Subject Item: MR 001 SO2 CEMS
Associated Items: CM 001 SO2 monitoring system SV 003 Main Stack (CE004, CE005) (SIP Source 1)

What to do Why to do it Continuous Operation: CEMS must be operated and data recorded during all periods of emission unit operation including periods of emission unit start-up, shutdown, or malfunction except for periods of acceptable monitor downtime. This requirement applies whether or not a numerical emission limit applies during these periods. A CEMS must not be bypassed except in emergencies where failure to bypass would endanger human health, safety, or plant equipment. Minn. R. 7017.1090, subp. 1

Monitoring Data: All data points collected by a CEMS shall be used to calculate individual hourly emission averages unless another applicable requirement requires more frequent averaging. In order for an hour of data to be considered, it must contain the following minimum number of data points: A . four data points, equally spaced, if the emission unit operated during the entire hour; B. two data points, at least 15 minutes apart, during periods of monitor calibration or routine maintenance; C. one data point if the emission unit operated for 15 minutes or less during the hour. Minn. R. 7017.1160, subp. 1 and 2

QA Plan: Develop and implement a written quality assurance plan that covers each CEMS. The plan shall be on site and available for inspection within 30 days after monitor certification. The plan shall contain all of the information required by 40 CFR Part 60, Appendix F, section 3. The plan shall include the manufacturer's spare parts list for each CEMS and require that those parts be kept at the facility unless the Commissioner gives written approval to exclude specific spare parts from the list. Minn. R. 7017.1170, subp. 2

CEMS Daily Calibration Drift (CD) Test: The CD shall be quantified and recorded at zero (low-level) and upscale (high-level) gas concentrations at least once daily according to the procedures listed in Minn. R. 7017.1170, subp. 3(A) or (B) and 40 CFR Section 60.13(d)(1) for each pollutant concentration, each diluent monitor, and for each monitor range. The CEMS shall be adjusted whenever the CD exceeds twice the specification of 40 CFR pt. 60, Appendix B. If no span value is specified in the applicable requirement or in a compliance document, the Permittee shall use a span value equivalent to 1.5 times the emission limit. 40 CFR pt. 60, Appendix F, shall be used to determine out-of-control periods for CEMS. Follow the procedures in 40 CFR pt. 60, Appendix F. Minn. R. 7017.1170, subp. 3

CEMS Cylinder Gas Audit (CGA): due before end of each calendar half-year starting 01/31/2003, except that a CGA is not required during any calendar half year in which a RATA was performed. The CGAs shall be conducted at least three months apart but no more than eight months apart. A CGA shall be conducted according to the procedures in 40 CFR pt. 60, Appendix F, section 5.1.2. If the monitored emission unit was operated for less than 24 hours during the calendar half year, a CGA is not required for that calendar half year. Minn. R. 7017.1170, subp. 4

CEMS Relative Accuracy Test Audit (RATA): due before end of each calendar year starting 01/31/2003. A RATA is not required in any calendar year if a RATA conducted in the previous year demonstrated a relative accuracy value of less than 15 percent or if the associated emissions unit operated less than 48 hours during the calendar year. If the exception is used, the next RATA shall be conducted during the first half of the following calendar year. RATAs shall be conducted at least 3 months apart according to 40 CFR pt. 60, Appendix F, section 5.1.1. Minn. R. 7017.1170, subp. 5

Recordkeeping: The owner or operator must retain records of all CEMS monitoring data and support information for a period of five years from the date of the monitoring sample, measurement or report. Records shall be kept at the source. Minn. R. 7017.1130

## Appendix B: Parameters Relied Upon in Modeling Facility Name: Gopher Resource Corporation Permit Number: 03700016-003 

# B.1 Lead Modeling

Source SV ID Stack Height (feet) Stack Height (m) Stack Dia. (feet) Stack Dia. (m) Flow Rate (acfm) Exit Temp

(F) Main Stack (Administrative Order Source #1) 003 199 60.65 6.0 1.83 119,000 190

Torit Stack (Administrative Order Source #3) 002 80 24.38 8.0 2.44 166,000 120

Torit Stack (new) 008 80 24.38 7.0 2.13 133,000 120

Control/Monitoring Equipment Control Equipment

Number SV ID No. of Bags Pressure Drop Range

(inches of

water) Filter Ratio Maximum Rated Design Capacity

(acfm) Maximum Inlet Temperature

(degree F)

RMPC Scrubber CE 001 001 NA 0.1-6.0 NA 15,000 120

Torit Cartridge Filter No. 1 & 2 CE 002 002 No. of filters elements: 320 0.5-15.0 1. 3:1 100,000 150

Torit Cartridge Filter No. 3 CE 003 002 No. of filters elements: 160 0.5-15.0 2. 4:1 66,000 150

East Baghouse CE 004 003 720 1-10 1.82:1 55,000 250 West Baghouse CE 005 003 720 1-10 1.82:1 55,000 450 Soda Ash Bin Baghouse CE 006 004 6 @ 6 inch diameter 1.0-7.0 6:1 Cloth Area: 174 sq. feet Torit Cartridge Filter No. 4 CE008 008 192 0.5-15. 0 1.8:1 66,000 150 Torit Cartridge Filter No. 5 CE009 008 192 0.5-15. 0 1.8:1 66,000 150



## B.2 SO 2 

## Modeling

Source SV ID Stack Height (feet) Stack Height (m) Stack Dia. (feet) Stack Dia. (m) Flow Rate (acfm) Exit Temp

(F) Modeled SO 2 

### Emission Rate (lb/hr) Main Stack 003 199 60. 65 6.0 1.83 119,000 190 2080
Scrubber Stack 001 50 15. 24 3.0 0.91 15,000 85 0.2

## Appendix C: Insignificant Activities and Applicable Requirements Facility Name: Gopher Resource Corporation Permit Number: 03700016-003
The table below lists the insignificant activ ities that are currently at the facility and their associated general applicable requirements.
Minn. R. 7007.1300,

subpart Rule Description of the Activity Likely Applicable Requirement

3(G) Emissions from a laboratory, as defined in the subpart. Minn. R. 7011.0510/0515; Minn. R. 7011.0610; Minn. R. 7011.0710/0715 3(H) Miscellaneous: 3. brazing, soldering or welding equipment; Minn. R. 7011.0710/0715 4 Individual emissions units at a stationary source, each of which has: A. Potential emissions of 5.7 pounds per hour or actual emissions of two tons per year of carbon monoxide; B. Potential emissions of 2.28 pounds per hour or actual emissions of one ton per year for particulate matter, particulate matter less than ten microns, nitrogen oxide, sulfur dioxide, and VOCs; and C. For hazardous air pollutants, emissions units with: (1) potential emissions of 25 percent or less of the hazardous air pollutant thresholds listed in subp. 5; or (2) combined HAP actual emissions of one ton per year unless the emissions unit emits one or more of the HAPs listed in this subpart.

 Operation of acetylene and chem-o-lene cutting torches in scrap pretreatment area.

 Operation of one Safety-Kleen solvent station

 Use of VOC –containing materials in water treatment plant

 Operation of cooling tower Minn. R. 7011.0710/0715

 Material handling of coke Minn. R. 7011.0150

 HVAC #20 RMPC Make-up Air

 HVAC #21 RMPC Make-up Air

 HVAC #30 Old Plastics Make-up Air

 HVAC #33 RMPC Dock Make-up Air

 HVAC #34 WWT Tank Farm Make-up Air

 HVAC#49 Refining Make-up Air

 HVAC #54 Furnace Make-up Air

 HVAC #36 Warehouse D Make-up Air

 HVAC # 37 Warehouse D Make-up Air Minn. R. 7011.0510/0515

## Minn. R. 7007.1300,

subpart Rule Description of the Activity Likely Applicable Requirement

 HVAC #47 Warehouse D Make-up Air

 HVAC #48 Warehouse D Make-up Air

 HVAC #32 Maintenance Shop Make-up Air

 RMPC Dock Infrared heaters (3 @ 60000 Btu)

 Old Plastics, WWT, RMPC Dock, Soda Ash Slurry Room, and Refining Infrared heaters (11 @ 90000 Btu)

 Old Plastics, WWT, RMPC Dock, and MTR Infrared heaters (8 @ 160000 Btu)

 Plant Wash Bay, Mobile Shop, Maintenance Shop Wash Bay, Maintenance Shop, Receiving, and Electrical Shop Tube Heaters (6 @ 150000 Btu)

## Appendix D: Smelting Raw Material Warehouse and Process Side of the Raw Material Processing Area Facility Name: Gopher Resource Corporation Permit Number: 03700016-003WA ER TREA MENT 

# o 

# \

SPARE PARTS



## MAINTENANCE 

# o o MTR

## ~o 0 RAW MATERIAL \XAREHOUSE



### I FURNAGES

-

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## -----------


# -----0--- Z (L (L 

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# APPENDIX D Smelting Raw Material Warehouse and Process Side of the Raw Material Processing Area

## Appendix E: Areas of the Building Under Negative Pressure Facility Name: Gopher Resource Corporation Permit Number: 03700016-003

## Appendix F: Fence/Gate Map Facility Name: Gopher Resource Corporation Permit Number: 03700016-003

# .. v
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# o Cl 

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# I c9 

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# B

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SCALE IN FEET


# APPENDIX F FENCE/GATE MAP, GOPHER RESOURCE CORP.

## Appendix G: SIP-Required Testing and Maintenance of Pressu re Drop Gauges and Broken Media Detectors and Alarm Response Procedures Facility Name: Gopher Resource Corporation Permit Number: 03700016-003

I. Pressure Drop Gauges (Magnehelics) A. Portable Magnehelic Gauges: 1. The Company shall monthly determine the accuracy of the portable magnehelic gauges, described in the Ventilation System of this Permit, with an el ectronic manometer (such as Dwyer’s model #475) to measure the static pressure at the magnehelic’s access point. 2. The Company shall immediately remove and replace a ll magnehelic gauges that show a static pressure deviation from the electronic manometer of greater than 10 percent. 3. The Company shall keep a record of all accuracy testing, removal and replacement if gauges, and items referred to in this permit. The record shall be si gned by the person conducting the testing and the person removing and replacing the gauges. 4. The company shall maintain the electronic manometer as recommended by the manufacturer (zero before each use, etc.) B. Fixed Pressure Drop Gauges (described in Appe ndix B as monitoring pressure drop on the baghouses and cartridge filters) 1. The company shall monthly determine the accuracy of the pressure drop gauges, with an electronic manometer to measure to measure the static pressure at the magnehelic’s access point. 2. The Company shall immediately remove and replace a ll magnehelic gauges that show a static pressure deviation from the electronic manometer of greater than 10 percent. 3. The Company shall keep a record of all accuracy testing, and removal and replacement of gauges. The record shall be signed by the person conducting th e testing and the person removing and replacing the gauges. II. Broken Media Detectors (TRIBOFLOW units that monitor increases in grain loading on the baghouses and cartridge filters.) A. The Company shall monthly clean the probes on each Broken Media Detector as indicated below and retain records of all cleaning. The record shall be signed by the person conducting the cleaning. 1. Disconnect the center conductor wire. 2. Remove the sensor and clean the sensor an insulator with a clean dry rag. 3. Reinstall the sensor and reconnect the center conductor wire. 4. Check the digital printout unit to ensure that the unit is operating and levels are within normal operating range (The TRIBOFLOW unit consis ts of sensing probes, cables and a signal processing unit. Probes are installed immediately upstream of each emissions contro l fan. When the probes are inserted in a stream of particles, a continual transfer of charge tak es place as particles collide with the probe. Because an electrical path to ground is provided, an essentia lly continuous signal is produced. The TRIBOFLOW monitors the character and level of this signal, which correlates with the actual flow rate.) B. The Company shall calibrate the alarms on the Br oken Media Detectors to notify personnel of possible increases in grain loading. The alarm shall be calibra ted to alert personnel at 20 milliamps for each Broken Media Detector. C. The Company shall repair or replace all Broken Media Detectors that do not signal grain loading or alarm as described above.
III. TRIBOFLOW Alarms A. In the event that the TRIBOFLOW alarms, the Company shall conduct the following steps.

## 1. Company personnel shall immediately determine which probe caused the alarm to sound. 2. Company personnel shall immediately observe the top of the stack for an increase in opacity. 3. If an increase in opacity has occurred, the Company shall shut off the cartridge bank or baghouse cells one at a time until the problem cell has been identified. The Company shall shutdown the problem cell until repairs are made or cell is replaced.

## Appendix H: SIP-Required Negative Pressure System Testing Facility Name: Gopher Resource Corporation Permit Number: 03700016-003

Control Equipment Units CE002, 003, 008, and 009 at Gophe r Resource Corporation are designed to place certain areas of the processing building (Raw Materials Handling Op erations, the Furnace (smelting) and the Refining areas) under negative pressure. The negative pressure system is comp rised of a ventilation system that vents air from certain areas of Building B (the processing building) through five ba nks of cartridge filters ducting into two common stacks (SV 002 & SV 008). In order to insure that these areas remain under negative pressure, the Permittee shall document on a monthly basis that negative pressure is maintained. When any of these filter banks are taken down for routine ma intenance or emergency repairs (filter change-out, auger or air lock repairs, etc.), the Company shall verify that the remaining operational filter banks are maintaining negative pressure on the required areas. The five filter banks are rated at 314,000 acfm so negative can be maintained on the building with only two of the banks operating. Documentati on of negative pressure will only be required if more than two of the banks are down at once. Monthly verification of negative pressure can be done by pe rforming smoke testing of outside openings or using some other method of verification that the Company may elect to use. This could include an electronic magnahelic system or a hand-held anemometer unit. I. The Company shall determine the eff ectiveness of the negative pressure system by testing various outside and inside openings where negative pressure is required. These locations shall include, but are not limited to, the following areas: a) Openings around closed overhead doors; b) Air flow direction when outside man-door s or outside overhead doors are opened; c) Air flow from adjacent building areas through connecting doorways (for example, air flow in the door separating the Refining area from the Furn ace area should be towards the Furnaces) II. If using smoke tubes to verify negative pressure, the Co mpany shall conduct the smoke testing as described in Appendix I of this permit. An electronic magnehelic system or hand-held anemometer system of documentation will have electronic records or actual flow rates noted. III. The Company shall record the monthly testing describ ed above on a map of Building B using arrows to indicate the air flow direction. The map shall also include a description of the outside openings, the date and time of the test, weather conditions during th e test, and process equipment operating and control equipment operating during the time of the test. The record shall be signed by the person conducting the test. IV. The Company shall immediately determine the cause of an y positive pressure test results, and repair the cause. V. If any positive pressure is detected and the cause repaired , the Company shall repeat the smoke test described above and record the results.

a 

## Immediately shall mean as soon as reasonably possible afte r giving consideration to Facility and personnel safety.

## Appendix I: SIP-Required Smoke Testing Methodology for Negative Pressure System Testing Facility Name: Gopher Resource Corporation Permit Number: 03700016-003
Prior to performing the negative pressure in the buildi ng, the following issues must be checked and recorded: 1. Insure that all doors (over-head & mandoors) in the furnace and containment areas are closed. If not, close them before continuing the test and check periodica lly throughout the test that they remain closed. 2. Record the settings on the five Torit Cartridge Unit Controllers. These settings should be recorded at the top of the Negative Pressure Test Sheet. The smoke test is to be controlled using s MSA Ventilati on Smoke Tube or similar tube which provides a visible indication of air flow direction. Both ends of the tube ar e to be broken off (use the supplied tube to prevent injuries) and one end inserted into the rubber bulb. Squeeze the bulb to insure that tube’s effectiveness. If sufficient smoke is generated, the specified overhead doors, mandoors and roof openings can be checked in the furnace and containment
rooms. TESTING A MANDOOR : Open the door approximately one foot and, while standing to one side, blow smoke vertically at three different heights within the opening (top, middle & bottom of the door). The smoke at all three locations should move into the furnace/containment rooms. If they do, indicate on the “Negative Pressure Test” sheet with an arrow pointing inwards and move on to the next opening. If the smoke blows out of the furnace/containment rooms, indicate again with an arrow pointing out of the rooms and move on to the next opening. TESTING AN OVERHEAD DOOR : Activate the door opener and move quickly to the middle of the opening. Begin blowing smoke near the bottom as it opens and continue blowing smoke following the action of the door as it moves up. When completely open, the smoke should continue to flow into the furnace/containment rooms. Indicate the direction of air flow on the “Negative Pressure Test” sheet and move on to the next opening. TESTING AND OPENING (OTHER THAN DOORS): Certain roof opening require smoke testing to insure the designated portions of the building remain under a negative pressure. One location is the metal cover where the stack support cables pass through the roof. In order to test this lo cation, pull out a portion of the fiberglass blanket wrapped around the cables and blow smoke near the opening. Record th e direction of air flow on the sheet and then replace the fiberglass blanket. The other roof opening that require checking are the gaps in the tin shed over the blast where ventilation ducting passes through them. Check a number of these openings with th e smoke tube. If all locations indicated the smoke is being pulled into the building, indicted that on the sheet. If otherwise, note positive flow. ACCEPTABLE TEST: If all tested locations indicated negative pressure within the furnace/containment rooms, finish filling out the report including processes operating, weather c onditions (wind direction and velocity and approximate temperature) and any additional field notes you feel are relevant to the test. UNACCEPTABLE TEST : If any of the tested locations indicated positive pressure, recheck the Torit controller settings and that all overhead doors are closed. Repeat the test and document air flow direction. If this test is acceptable, then complete the items listed above unde r the ACCEPTABLE TEST heading. If openings are still found to be positive, contact the Health and Safety Manager or Plant Manager for assistance in determining the cause of the positive pressure. Once corrected, again go through the entire Nega tive Pressure Test to insure that all locations are negative pressure. Record in the Field Notes section the pr oblem and solution and keep all copies of the Negative Pressure Test on file. CAUTION: The ends of any used smoke tubes are extremely jagged and should be handled with extreme caution to prevent injury to yourself or others. Used smoke tubes should be thrown directly into the large dumpster to eliminate a potential injury to janitorial personnel emptying garbage cans. The rubber bulb, tip snapper and any unused tubes should be returned to their case in the main storeroom. The complete Negative Pressure Test sheet should be returned to the Maintenance Supervisor for review and filing. NOTE : If Gopher Resource decides to seal gaps then smoke testing will not be required.

## Appendix J: Paved Roads Facility Name: Gopher Resource Corporation Permit Number: 03700016-003

# GOPHER RESOURCE CORPORATION SITE LAYOUT

The company sholl sweep these areas daily 

# m

The company sholl sweep these areas at least once each week.

The company shall sweep these areas at • least once every three weeks



# •

EXHIBIT 7 PAVEMENT SWEEPING QJ
C) 

# o ........J 

### QJ

## Appendix K: Maintenance Plan for Baghouses and Cartridge Filters Facility Name: Gopher Resource Corporation Permit Number: 03700016-003
I. The Company shall conduct the activities as indicated belo w for each baghouse and cartridge filter described in Appendix B of this permit (Exhibit 1 of the Administrativ e Order). Records of these activities shall be signed by the person that performed the inspection. A. Visually check for emissions at the top of each stack a minimum of once per shift. B. Inspect each baghouse cell once a week. Inspect fo r holes or other problems. Replace any bag as necessary. Record the reason for replacing the bag. C. Once per week, inspect the baghouse hopper for any buildup and clean as necessary. D. Once per week, inspect the baghouse and cartridge filter broken media detectors and pressure drop gauges as described in Appendix G (Exhibit 8 of the Administrative Order). E. Once per week, check each baghouse cell for accu mulation of free dust and clean as necessary. F. Once per week, inspect baghouse inle t dampers and clean as necessary. G. Once per shift, inspect all baghouse mechanical shakers. H. Once per shift, check magnehelic gauge and once per shift record readings. II. The Company shall maintain the spare parts inventory as indicated below: A. CE004 and CE005 (Baghouse #1 and Baghouse #1 as described in Administrative Order; East Baghouse and West Baghouse as described in Appendix B) QUANTITY PART NUMBER DESCRIPTION 120 232050 8” x 20’ 0” Filtron Bag 120 222069 Tube Hook

4 194206 V-Block 1 203695 Eccentric Shaft 4 191207 Pin 1 203740 End Shaft 1 203741 End Shaft 4 186183 Knife-Edge Assembly 4 191575 Arm 2 231969 Shaker Bar 4 191014 Gasket 4 191013 Felt Seal 4 187121 Flangette Bearing 2 98262 1 1⁄2” Pillow Bearing 2 133852 1 7/16” Eccentric Bearing 10 1/8” x 1 1/2” Cotter Pin 15 1 7/16” - 14 Self Locking Nuts 15 1 7/16” N.C.C.P. Hex Nuts B. CE002 and CE003 (Cartridge Filter #4 #5 as described in Administrative Order, or Cartridge Filters 1-3 as described in Appendix B) QUANTITY PART NUMBER DESCRIPTION 12 8PP-42058-00 Ultra Web FR Filter Element 3 8PP-24277-00 Diaphragm Valve RCA 25DD 3 8PP-24636-00 Solenoid Valve Rebuild Kit 3 8PP-25409-00 Solenoid Replacement Coil Torit Relacement Parts for Torit Downflo II Unit as Recommended by Manufacturer (Donaldson)