•

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 ofMinnesota's State Implementation Plan (SIP).

The revision concerns Gopher Resource, LLC, part ofMinnesota'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 ofthe joint documents issued to each facility and supporting technical

documentation. A full electronic copy of all the enclosed materials comprising this SIP submittal is

included on the accompanying compact discs.

Please contact Catherine Neuschler, of our staff, at 651-757-2607, ifyou 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 OHEGJONALADMJISiKill 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 information 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), located at 3385 South Highway 149 in Eagan, is 

the only culpable source in the lead maintenance area. 

The subject area of Dakota County was designated as non-attainment with the primary lead 

National Ambient Air Quality Standard (NAAQS) of 1.5 μg/m3 on January 6, 1992. The U.S. 

Environmental Protection Agency (EPA) granted approval of a SIP revision and redesignation 

request on October 18, 1994 (50 FR 52531). The revision included an Administrative Order 

(Order) containing emission limits and other requirements for Gopher, which ensured attainment 

with the NAAQS. 

On November 18, 2002, the MPCA submitted a SIP 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 document. EPA did not act on this submittal due to concerns that 

the joint document did not contain some necessary requirements. On November 19, 2007, the 

MPCA formally withdrew the request to replace the Order with the joint document, but asked 

that EPA consider the maintenance plan update. On June 3, 2008, EPA published 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 μg/m3

. In October 2010, EPA will designate 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-attainment with the new standard. However, the current 

NAAQS of 1.5 μg/m3

, remains in effect until one year after 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 attain and maintain the NAAQS in facility permits, 

denoting the required SIP conditions with the notation “Title I Condition: SIP for <pollutant> 

NAAQS.” The permit then serves as a joint 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 replace 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 existing 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). The permit and its technical support document 

(TSD) provide information on Gopher’s operations. This document concentrates on the relevant 

changes to the facility’s Title I SIP conditions for lead. 
Reason for SIP Revision 

This SIP revision is being submitted to update the facility’s enforceable document in the SIP, in 

conjunction with reissuance of the facility’s Title V operating permit. The reissuance of the Title 

V operating permit does not allow for any new emission 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 joint document. However, that SIP revision was 

withdrawn by the MPCA. The MPCA is aware that EPA had several concerns about the 

previous permit, particularly in regards to recordkeeping and contingency measure requirements. 

In drafting this joint document (Air Emission Permit No. 03700016-003), the MPCA has ensured 

that those recordkeeping and contingency plan requirements from the original Order have been 

included in the joint document. 

Changes Made in this SIP Revision 

Compared to the Administrative Order currently 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 facility changes require a SIP revision, have been 

reworded or clarified to fit with the MPCA’s current format for such conditions. SIP conditions 

where the facility was originally offered a choice of multiple compliance options have been 

updated to document the compliance choice made by Gopher Resource. In addition, the joint 

document organizes and names emission 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 Emissions Standards for Hazardous Air Pollutants 

(NESHAP) program. The NESHAP allows facilities with lead emissions less than a certain 

threshold to move to biannual stack testing. Since 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. Therefore, 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 any 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 μg/m3

. 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 material handling, the battery breaking dock, 

material transfer rooms, and the furnace areas; these dust collectors will exhaust to the new 

SV008. The purpose of these dust collectors 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 stack 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 concentration of ambient 

lead, EPA’s screen modeling application SCREEN3 was used to model 3 scenarios: 

Scenario 1: The permitted (and allowed by the Administrative Order) lead emissions were 

modeled from SV002, using the stack parameters from the original Title V permit. 

Scenario 2: The same permitted (and allowed by the 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 (emissions 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 emission rate, when modeled from SV008 instead of 

SV002, resulted in lower modeled maximum ambient 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 impacts 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 part 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/m3, clearly below the 1.5 μg/m3

 

1

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

2

 This stack was described as Emission Point/Stack 3 in the Administrative Order. 
level of the 1978 standard. This modeling included a preliminary characterization of the 

emissions from the new Torit stack. 

 

Adding this stack, without adding any emissions, is likely to result in lower ambient 

concentrations. Monitoring data around the facility has consistently indicated compliance with 

the 1978 standard. Therefore, the MPCA is confident that this SIP revision will allow the area to 

continue to attain the existing NAAQS of 1.5 μg/m3

. 
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 Neuschler, 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 ofthe 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 ofthe 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 ofthe 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 recycledpaper containing at least 10% fibersfrom 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 Maintenance 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 requirements of the Minnesota Pollution Control Agency’s 

(MPCA) solid waste, hazardous waste, and water quality programs. If you wish to obtain information on 

these programs, including information on obtaining any required permits, please contact the MPCA 

general information number at: 

 Metro Area 651-296-6300 

 Outside Metro Area 1-800-657-3864 

 TTY 651-282-5332 

The rules governing these programs are contained in Minn. R. chs. 7000-7105. Written questions may be 

sent to: Minnesota Pollution Control Agency, 520 Lafayette Road North, St. Paul, Minnesota 55155-4194. 

Questions about this air emission permit or about air quality requirements can also be directed to the 

telephone numbers and address listed above. 

PERMIT SHIELD: 

Subject to the limitations in Minn. R. 7007.1800, compliance with the conditions of this permit shall be 

deemed compliance with the specific provision of the applicable requirement identified in the permit as 

the basis of each condition. Subject to the limitations of Minn. R. 7007.1800 and 7017.0100, subp. 2, 

notwithstanding the conditions of this permit specifying compliance practices for applicable requirements, 

any person (including the Permittee) may also use other credible evidence to establish compliance or 

noncompliance with applicable requirements. 

FACILITY DESCRIPTION: 

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 pretreatment, smelting, refining and casting. Lead is 

recovered from lead-acid batteries, scrap from battery 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 (PM10) and Particulate Matter less than 2.5 microns 

(PM2.5); Nitrogen Oxide (NOx), Sulfur Dioxide (SO2) 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 Implementation Plan (SIP), through the October 18, 1994, 

Federal Register. Gopher must comply with the provisions of the administrative order as a condition of 

compliance with the National Ambient Air Quality Standards (NAAQS) for lead. 

This permit includes all of the provisions of the administrative 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 μg/m3

 to 0.15 μg/m3. By October 15, 2009, 

The MPCA was required to submit to EPA, by October 15, 2009. a request for designation of areas of the 

State, including the area around Gopher, as either in attainment 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 develop 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 nonattainment 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

ACTIVITIES 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

ACTIVITIES 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

Appendix 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

Appendix 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)

At 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

ATPA 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

Agency 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

Air 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.

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

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

notify the Commissioner when the shutdown is over.

Minn. R. 7019.1000, subp. 3

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

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

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

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

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

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

subp. 2.

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

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

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

breakdown is over.

Minn. R. 7019.1000, subp. 2

Notification of Deviations Endangering Human Health or the Environment: As soon

as possible after discovery, notify the Commissioner or the state duty officer, either

orally or by facsimile, of any deviation from permit conditions which could endanger

human health or the environment.

Minn. R. 7019.1000, subp. 1

Notification of Deviations Endangering Human Health or the Environment Report:

Within 2 working days of discovery, notify the Commissioner in writing of any

deviation from permit conditions which could endanger human health or the

environment. Include the following information in this written description:

1. the cause of the deviation;

2. the exact dates of the period of the deviation, if the deviation has been corrected;

3. whether or not the deviation has been corrected;

4. the anticipated time by which the deviation is expected to be corrected, if not yet

corrected; and

5. steps taken or planned to reduce, eliminate, and prevent reoccurrence of the

deviation.

Minn. R. 7019.1000, subp. 1

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

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

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

needed.

Minn. R. 7007.1150 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

Average (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

All 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

Agency 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

Associated 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

Average ( 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

Average

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

Air 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.

Alarm 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

Appendix 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

Air 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.

Alarm 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

Appendix 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

Air 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.

Alarm 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

Appendix 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

As 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

Air 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.

Alarm 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

Appendix 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

As 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 SO2 Modeling 

Source 

SV 

ID 

Stack Height 

(feet) 

Stack Height 

(m) 

Stack Dia. 

(feet) 

Stack Dia. 

(m) 

Flow Rate 

(acfm) 

Exit 

Temp 

(F) 

Modeled SO2

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 activities 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: 03700016-003 
WA ER

TREA MENT

o \

SPARE PARTS

MAINTENANCE

o

o

MTR

~o 0

RAW MATERIAL

\XAREHOUSE

I

FURNAGES -

rI

I

I

I

I

I __ J

--------,I

I

-----------

-----0---

Z

(L

(L

I

if)

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

,,;;:: GATE

o

Cl

o

---l

OJ

I

I c9

u

3

c9

B

GATE

~~~

7 51" '7° 'To 27°

SCALE IN FEET

APPENDIX F

FENCE/GATE MAP, GOPHER RESOURCE CORP.
Appendix G: SIP-Required Testing and Maintenance of Pressure 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 electronic 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 all 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 signed 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 Appendix 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 all 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 the 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 consists of sensing probes, cables and a signal processing unit. Probes are 

installed immediately upstream of each emissions control fan. When the probes are inserted in a stream of 

particles, a continual transfer of charge takes place as particles collide with the probe. Because an 

electrical path to ground is provided, an essentially 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 Broken Media Detectors to notify personnel of possible 

increases in grain loading. The alarm shall be calibrated 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 Gopher Resource Corporation are designed to place certain 

areas of the processing building (Raw Materials Handling Operations, the Furnace (smelting) and the Refining areas) 

under negative pressure. The negative pressure system is comprised of a ventilation system that vents air from certain 

areas of Building B (the processing building) through five banks 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 maintenance 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. Documentation 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 performing 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 effectiveness 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-doors 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 Furnace area should be towards the Furnaces) 

II. If using smoke tubes to verify negative pressure, the Company 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 described 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 the 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 any 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 after 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 building, 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 periodically 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 Ventilation Smoke Tube or similar tube which provides a visible 

indication of air flow direction. Both ends of the tube are 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 location, pull out a portion of the fiberglass blanket wrapped 

around the cables and blow smoke near the opening. Record the 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 the 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 conditions (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 under 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 Negative Pressure Test to insure that all locations are 

negative pressure. Record in the Field Notes section the problem 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 dailym

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

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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 below for each baghouse and cartridge filter described in 

Appendix B of this permit (Exhibit 1 of the Administrative 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 for 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 accumulation of free dust and clean as necessary. 

F. Once per week, inspect baghouse inlet 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)