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PROPOSED

AIR EMISSION PERMIT NO. 16300002- 005

Major Amendment

IS ISSUEDTO

3M COTTAGE GROVE SPECIALTYADDITIVES

10746 Innovation Road

Cottage Grove, Washington County, Minnesota 55016

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

amendment are as described in the Permit Applications Table.

The conditions included in Stage 1 of this permit action are effective on the Stage 1 Issuance Date shown below.

Stage 1 conditions authorize construction of the facility and the operation of the emissions units at the address listed

above until final action is taken on Stage 2. Air Emission Permit No. 16300002-004, remains effective until the Stage 2

Issue Date shown below.

Beginning on the Stage 2 Issue Date shown below, Air Emission Permit No. 16300002-005, supersedes Air Emission

Permit No. 16300002-004 and authorizes the Permittee to operate the stationary source at the address listed

above unless otherwise noted in Table A. The Permittee must comply with all the conditions of the permit. Any

changes or modifications to the stationary source must be performed in compliance with Minn. R. 7007.1150 to

7007.1500. 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, all the Minnesota rules cited as the origin of the permit terms are incorporated into

the State Implementation Plan under 40 CFR 9 52.1220 and as such are enforceable by U.S. Environmental

Protection Agency (EPA) Administrator or citizens under the Clean Air Act.

Permit Type: Federal; Part 70/Limits to Avoid NSR;

Operating Permit Issue Date: March 24, 2005

Stage 1 Issue Date - Authorization to Construct and Operate: March 26, 2013

Stage 2 Issue Date - Major Amendment: April 9, 2013Operating Permit Expiration: March 24, 2010* -- All Title I Conditions do not expire.

* The Permittee may continue to operate this facility after the expiration date of the permit, per the provision under Minn.

R. 7007.0450, subp. 3. (Title V Reissuance Application was received September 28,2009.)

Stage 2 Issuance:

~ Don S th, P.E., Manager

Air Quality Permits Section

Industrial Division

for John Line Stine

Commissioner

Minnesota Pollution Control Agency

for John Line Stine

Commissioner

Minnesota Pollution Control Agency

TDD (for hearing and speech impaired only): (651) 282-5332

Printed on recycled poper containing at leost 10% fibers from paper recycled by consumers

Permit Applications Table

Permit Type Application Date Permit Action

Total Facility Operating Permit April 17, 1995 001

Major Amendment December 15, 2005 003

Major Amendment August 19, 2009; March 22, 2012

(Supplemental information August 31, 2012 004

Major Amendment September 20, 2012 005

(Permit Action 002 – application withdrawn)

TABLE OF CONTENTS

Notice to the Permittee Permit Shield Facility Description Amendment Description Table A: Limits and Other Requirements Table B: Submittals

Appendix I – Insignificant Activities and General Applicable Requirements Appendix II – Computer Dispersion Modeling Parameters

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. However, the permit shield does not apply to any national ambient air quality standard adopted under section 109 of the Clean Air Act and any state ambient air quality standard under Minn. R. ch. 7009. 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: The 3M Cottage Grove Specialty Additives facility manufactures specialty glass products. The operations cover by this permit (buildings 74, 101 and 110) together with the operations covered the permits for 3M Cottage Grove – Abrasive Systems Division (Building 112) and 3M Cottage Grove – Building 19 & 111, constitute a single source under Prevention of Significant Degredation (PSD) regulations. Emissions from the Specialty Additives facility result from raw material handling, fuel combustion, and

from production processes. Direct electrical heating is used on the glass melter with natural gas used to

heat the start‐up of the melter and diesel used for the back‐up generator. Natural gas is used on the

glass bubble makers.

AMENDMENT DESCRIPTION: The application seeks authorization to expand the glass furnace (EU022), to increase the hourly

throughput capacity of the furnace and the associated fritting system (EU024), and to modify the fan

associated with the fabric filter that currently controls the fritting system (CE025).

TABLE A: LIMITS AND OTHER REQUIREMENTS3M Cottage Grove Specialty Additives

16300002 - 005

Facility Name:

Permit Number:

04/10/13A-1

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

Subject Item: Total Facility

What to do Why to do it

This facility, along with 3M Cottage Grove Abrasive Systems Division (ID16300017) and 3M Cottage Grove Building 19 and 111 (ID 16300133) constitute asingle source under PSD regulations.

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NAAQS/MAAQS MODELING REQUIREMENTS hdr

This permit requires modeling to demonstrate compliance with the NationalAmbient Air Quality Standards (NAAQS). The Permittee may not make any changeat the source that would result in an increase in SO2 emissions until it can bedemonstrated that emissions from the facility as permitted do not cause anexceedance of the NAAQS. This includes changes that might otherwise qualify asinsignificant modifications and minor or moderate amendments. This is a state-onlyrequirement and is not enforceable by the EPA Administrator or citizens under theClean Air Act.

40 CFR pt. 50; Minn. Stat. Section 116.07, subds. 4a &9; Minn. R. 7007.0100, subp. 7(A), 7(L) & 7(M); Minn.R. 7007.0800, subps. 1, 2 & 4; Minn. R.7009.0010-7009.0080

The parameters used in PM < 10 micron modeling are listed in Appendix II of thispermit. The purpose of listing the parameters in the appendix is to provide abenchmark for future changes.


Modeling Triggers: For changes that do not require a permit amendment and affectany modeled parameter or emission rate documented in Appendix III, or are anaddition to the information documented in Appendix III, a Remodeling Submittalrequirement is not triggered at the time of the change. The Permittee shall keepupdated records on site of all parameters and emission rates. The Permittee shallsubmit any changes to parameters and emission rates with the next requiredRemodeling Submittal.

For changes that require a minor, moderate, or major permit amendment and affectany modeled parameter or emission rate documented in Appendix III, or are anaddition to the information documented in Appendix III, a Remodeling Submittalrequirement is triggered. The Permittee shall include previously made changes toparameters and emission rates that did not trigger a Remodeling Submittal.


Remodeling Submittal: The Permittee must submit to the MPCA for approvalchanges meeting the above criteria and must wait for a written approval beforemaking such changes (see introduction of Table B of this permit for MPCA mailinginformation). For minor amendments, written approval of the modeling may begiven before permit issuance; however, this approval applies only to the modelingand not to any other changes. The information submitted must include, for stackand vent sources, source emission rate, location, height, diameters, exit velocity,exit temperature, discharge direction, use of rain caps or rain hats, and, ifapplicable, locations and dimensions of nearby buildings. For non-stack/ventsources, this includes the source emissions rate, location, size and shape, releaseheight, and, if applicable, any emissions rate scalars, and the initial lateraldimensions and initial vertical dimensions and adjacent building heights.


Remodeling Submittal, continued:The plume dispersion characteristics due to the revisions of the information mustbe equivalent to or better than the dispersion characteristics modeled based on the10/26/2011 modeling report submittal. The Permittee shall demonstrate thisequivalency in the proposal. If the information does not demonstrate equivalent orbetter dispersion characteristics, or if a conclusion cannot readily be made aboutthe dispersion, the Permittee must submit full remodeling.


EMISSION CAP LIMITS hdr

This permit establishes limits on PM, PM < 10 microns, PM < 2.5 microns, SO2,NOx and VOC to keep the facility a minor source under New Source Review. ThePermittee cannot make any change at the source that would make the source amajor source under New Source Review until a permit amendment has beenissued. This includes changes that might otherwise qualify as insignificantmodifications and minor or moderate amendments.

Title I Condition: To avoid classification as a majorsource and modification under 40 CFR Section 52.21and Minn. R. 7007.3000

OPERATIONAL REQUIREMENTS hdr


16300002 - 005

Facility Name:

Permit Number:

04/10/13A-2

The Permittee shall comply with National Primary and Secondary Ambient AirQuality Standards, 40 CFR pt. 50, and the Minnesota Ambient Air QualityStandards, Minn. R. 7009.0010 to 7009.0080. Compliance shall be demonstratedupon written request by the MPCA.

40 CFR pt. 50; Minn. Stat. Section 116.07, subds. 4a &9; Minn. R. 7007.0100, subp. 7(A), 7(L), & 7(M); Minn.R. 7007.0800, subps. 1, 2 & 4; Minn. R.7009.0010-7009.0080

Circumvention: Do not install or use a device or means that conceals or dilutesemissions, which would otherwise violate a federal or state air pollution control rule,without reducing the total amount of pollutant emitted.

Minn. R. 7011.0020

Air Pollution Control Equipment: Operate all pollution control equipment wheneverthe corresponding process equipment and emission units are operated, unlessotherwise 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 andmaintenance plan for all air pollution control equipment. At a minimum, the O & Mplan shall identify all air pollution control equipment and control practices and shallinclude a preventative maintenance program for the equipment and practices, adescription of (the minimum but not necessarily the only) corrective actions to betaken to restore the equipment and practices to proper operation to meet applicablepermit conditions, a description of the employee training program for properoperation and maintenance of the control equipment and practices, and the recordskept to demonstrate plan implementation.

Minn. R. 7007.0800, subps. 14 and 16(J)

Operation Changes: In any shutdown, breakdown, or deviation the Permittee shallimmediately take all practical steps to modify operations to reduce the emission ofany regulated air pollutant. The Commissioner may require feasible and practicalmodifications in the operation to reduce emissions of air pollutants. No emissionsunits that have an unreasonable shutdown or breakdown frequency of process orcontrol equipment shall be permitted to operate.

Minn. R. 7019.1000, subp. 4

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

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 orcitizens under the Clean Air Act.

Minn. R. 7030.0010 - 7030.0080

Inspections: The Permittee shall comply with the inspection procedures andrequirements 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 or B.

Minn. R. ch. 7017

Performance Test Notifications and Submittals:

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

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

The Notification, Test Plan, and Test Report may be submitted in alternative formatas allowed by Minn. R. 7017.2018.

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

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

Minn. R. 7017.2025, subp. 3

MONITORING REQUIREMENTS hdr

Monitoring Equipment Calibration: Annually calibrate all required monitoringequipment (any requirements applying to continuous emission monitors are listedseparately in this permit).

Minn. R. 7007.0800, subp. 4(D)


16300002 - 005

Facility Name:

Permit Number:

04/10/13A-3

Operation of Monitoring Equipment: Unless otherwise noted in Tables A or B,monitoring a process or control equipment connected to that process is notnecessary during periods when the process is shutdown, or during checks of themonitoring systems, such as calibration checks and zero and span adjustments. Ifmonitoring records are required, they should reflect any such periods of processshutdown or checks of the monitoring system.

Minn. R. 7007.0800, subp. 4(D);40 CFR Section 70.6(a)(3)(i)(C)

RECORDKEEPING hdr

Recordkeeping: Retain all records required by this permit for a period of at leastfive (5) years from the date of monitoring, sample, measurement, or report.Records shall be retained at the stationary source for at least two (2) years, afterwhich they may be transferred to and retained at the 3M Center for at least three(3) years. Records which must be retained at this location for at least two (2) yearsinclude all calibration and maintenance records, all original recordings forcontinuous monitoring instrumentation, and copies of all reports required by thepermit. Records must conform to the requirements listed in Minn. R. 7007.0800,subp. 5(A).

Minn. R. 7007.0800, subp. 5(C)

Recordkeeping: Maintain records describing any insignificant modifications (asrequired by Minn. R. 7007. 1250, subp. 3) including records of the emissionsresulting from those changes.

Minn. R. 7007. 0800, subp. 5(B)

Recordkeeping: Maintain records describing any changes contravening permitterms (as required by Minn. R. 7007.1350 subp. 2), including records of theemissions resulting from those changes.

Minn. R. 7007. 0800, subp. 5(B);40 CFR Section 70.4(b)(12)

If the Permittee determines that no permit amendment or notification is requiredprior to making a change, the Permittee must retain records of all calculationsrequired under Minn. R. 7007.1200. For expiring permits, these records shall bekept for a period of five years from the date the change was made or until permitreissuance, whichever is longer. The records shall be kept at the stationary sourcefor the current calendar year of operation and may be kept at the stationary sourceor office of the stationary source for all other years. The records may be maintainedin either electronic or paper format.

Minn. R. 7007.1200, subp. 4

REPORTING and SUBMITTALS hdr

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

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

Minn. R. 7019.1000, subp. 3

Breakdown Notifications: Notify the Commissioner within 24 hours of a breakdownof more than one hour duration of any control equipment or process equipment ifthe breakdown causes any increase in the emissions of any regulated air pollutant.The 24-hour time period starts when the breakdown was discovered or reasonablyshould have been discovered by the owner or operator. However, notification is notrequired in the circumstances outlined in Items A, B and C of Minn. R. 7019.1000,subp. 2.

At the time of notification or as soon as possible thereafter, the owner or operatorshall inform the Commissioner of the cause of the breakdown and the estimatedduration. The owner or operator shall notify the Commissioner when thebreakdown is over.

Minn. R. 7019.1000, subp. 2

Notification of Deviations Endangering Human Health or the Environment: As soonas possible after discovery, notify the Commissioner or the state duty officer, eitherorally or by facsimile, of any deviation from permit conditions which could endangerhuman health or the environment.

Minn. R. 7019.1000, subp. 1

Notification of Deviations Endangering Human Health or the Environment Report:Within 2 working days of discovery, notify the Commissioner in writing of anydeviation from permit conditions which could endanger human health or theenvironment. Include the following information in this written description:1. the cause of the deviation;2. the exact dates of the period of the deviation, if the deviation has been corrected;3. whether or not the deviation has been corrected;4. the anticipated time by which the deviation is expected to be corrected, if not yetcorrected; and5. steps taken or planned to reduce, eliminate, and prevent reoccurrence of thedeviation.

Minn. R. 7019.1000, subp. 1


16300002 - 005

Facility Name:

Permit Number:

04/10/13A-4

Application for Permit Amendment: If a permit amendment is needed, submit anapplication in accordance with the requirements of Minn. R. 7007.1150 throughMinn. R. 7007.1500. Submittal dates vary, depending on the type of amendmentneeded.

Minn. R. 7007.1150 - 7007.1500

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

Minn. R. 7007.1400, subp. 1(H)

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

Minn. R. 7019.3000 - 7019.3100

Emission Fees: due 60 days after receipt of an MPCA bill. Minn. R. 7002.0005 - 7002.0095


16300002 - 005

Facility Name:

Permit Number:

04/10/13A-5

Subject Item: GP 001 Fabric Filter Requirements (CAM)

Associated Items: CE 004 Fabric Filter - Medium Temperature i.e., 180 F<T<250 F

CE 024 Fabric Filter - High Temperature, i.e., T>250 Degrees F

CE 025 Fabric Filter - Medium Temperature i.e., 180 F<T<250 F

CE 026 Fabric Filter - Low Temperature, i.e., T<180 Degrees F





The Permittee shall operate and maintain each fabric filter in GP001 at all timesthat an emission unit in GP002 that exhausts to a fabric filter is in operation. ThePermittee shall document periods of non-operation of the control equipment.

The requirements of this group apply individually to each fabric filter in GP001,including all new, modified, or replaced fabric filters added as allowed by GP001.


If the Permittee replaces any existing fabric filter, adds a new fabric filter, ormodifies an existing fabric filter listed in GP001, such equipment is subject to all ofthe requirements of GP001. Prior to making such a change, the Permittee shallapply for and obtain the appropriate permit amendment, as applicable. A permitamendment is required if the change will be subject to a newly applicablerequirement or requires revisions to the limits or monitoring and recordkeeping inthis permit.

Title I Condition: To avoid classification as majorsource and modification under 40 CFR Section 52.21& Minn. R. 7007.3000

EMISSION LIMITATIONS hdr

The Permittee shall operate and maintain each fabric filter such that it achieves acontrol efficiency for Total Particulate Matter: greater than or equal to 99 percentcontrol efficiency


The Permittee shall operate and maintain each fabric filter equipment such that itachieves a control efficiency for PM < 10 micron: greater than or equal to 93percent control efficiency


The Permittee shall operate and maintain each fabric filter such that it achieves acontrol efficiency for PM < 2.5 micron: greater than or equal to 93 percent controlefficiency


OPERATING REQUIREMENTS hdr

The Permittee shall operate and maintain the fabric filters in accordance with theOperation and Maintenance (O & M) Plan. The Permittee shall keep copies of theO & M Plan available onsite for use by staff and MPCA staff.

Minn. R. 7007.0800, subp. 14

Replacing Control Devices: The Permittee shall operate and maintain any new,modified, or replaced fabric filter according to the manufacturer's specifications untila new pressure drop limit is set pursuant to Minn. R. 7017.2025, subp. 3.

Minn. R. 7007.0800, subps. 4, 5 and 14

See individual CE level (CE 004, 024, 025, 026, 027, 034, or 035) for requiredpressure drop ranges for each fabric filter.

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MONITORING AND RECORDKEEPING hdr

Pressure Drop Recordkeeping: The Permittee shall, once every 24 hours, read andrecord the pressure drop across the fabric filter. The Permittee shall record the timeand date of each pressure drop reading, and whether or not the observed pressuredrop was within the range specified in this permit. Recorded values outside therange specified in this permit are considered Deviations as defined by Minn. R.7007.0100, subp. 8a.

The Permittee shall also record and maintain the date of each bag replacement forall fabric filters.

Title I Condition: To avoid classification as a majorsource and modification under 40 CFR Section 52.21and Minn. R. 7007.3000; 40 CFR Section 64.3; Minn.R. 7017.0200

Visible Emissions: The Permittee shall check each fabric filter stack for any visibleemissions using Method 22, daily during periods of daylight operation when themonitored pressure drop is outside of the range specified in the permit or duringperiods of inoperation of pressure drop monitoring equipment.

Minn. R. 7007.0800, subp. 4 and 14

Recordkeeping: The Permittee shall record the time and date of each visibleemission inspection, and whether or not any visible emissions were observed. Anyvisible emissions are considered Deviations as defined by Minn. R. 7007.0100,subp. 8a. If the emission unit is not operating, the Permittee shall record that theprocess is not operating.

Minn. R. 7007.0800, subps. 2 and 14


16300002 - 005

Facility Name:

Permit Number:

04/10/13A-6

Periodic Inspections: At least once per calendar quarter, or more frequently asrequired by the manufacturing specifications, the Permittee shall inspect the controlequipment components. The Permittee shall maintain a written record of theseinspections.

40 CFR Section 64.3; Minn. R. 7017.0200

Corrective Actions: The Permittee shall take corrective action as soon as possible ifany 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 needrepair.Corrective actions shall return the pressure drop to within the permitted range,and/or include completion of necessary repairs identified during the inspection, asapplicable. Corrective actions include, but are not limited to, those outlined in the O& M Plan for the fabric filter. The Permittee shall keep a record of the type and dateof 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 necessarymonitoring equipment for measuring and recording pressure drop as required bythis permit. The monitoring equipment must be installed, in use, and properlymaintained when the monitored fabric filter is in operation.

40 CFR Section 64.7(b); Minn. R. 7017.0200

The Permittee shall calibrate the pressure gauge at least once every 12 monthsand 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 achievecompliance with an emission limitation or standard for which the monitoring did notprovide an indication of an excursion or exceedance while providing valid data, orthe results of compliance or performance testing document a need to modify theexisting pressure drop range, the Permittee shall promptly notify the MPCA and, ifnecessary, submit a permit amendment application to address the necessarymonitoring change.

40 CFR Section 64.7(e); Minn. R. 7017.0200

PERFORMANCE TESTS hdr

Performance Test: due 365 days after Startup of a new, modified, or replacedcontrol device to measure Particulate Matter emissions to demonstrate compliancewith applicable emission limitations.

Minn. R. 7017.2020, subp. 1

Performance Test: due 365 days after Startup of a new, modified, or replacedcontrol device to measure Opacity to demonstrate compliance with applicableemission limitations.

Minn. R. 7017.2020, subp. 1


16300002 - 005

Facility Name:

Permit Number:

04/10/13A-7

Subject Item: GP 002 Emission Cap Limits






EU 003 Glass Bubble Maker #18



EU 022 Glass Furnace #74-04A

EU 023 Glass Furnace #74-04B

EU 024 Fritting Systems #74-05

EU 025 Impact Mill

EU 026 Agglomerator System #74-04

EU 034 Emergency Backup Generator #55



Total Particulate Matter: less than or equal to 110 tons/year using 12-month RollingSum to be calculated by the 21st day of each month for the previous 12-monthperiod.

All PM-emitting equipment in GP002 and insignificant activities under Minn. R.7007.1300 are subject to this limit.


PM < 10 micron: less than or equal to 110 tons/year using 12-month Rolling Sum tobe calculated by the 21st day of each month for the previous 12-month period.

All PM < 10 microns-emitting equipment in GP002 and insignificant activities underMinn. R. 7007.1300 are subject to this limit.


PM < 2.5 micron: less than or equal to 110 tons/year using 12-month Rolling Sumto be calculated by the 21st day of each month for the previous 12-month period.

All PM < 2.5 microns-emitting equipment in GP002 and insignificant activities underMinn. R. 7007.1300 are subject to this limit.


Sulfur Dioxide: less than or equal to 120 tons/year using 12-month Rolling Sum tobe calculated by the 21st day of each month for the previous 12-month period.

All SO2-emitting equipment in GP002 and insignificant activities under Minn. R.7007.1300 are subject to this limit.


Nitrogen Oxides: less than or equal to 135 tons/year using 12-month Rolling Sumto be calculated by the 21st day of each month for the previous 12-month period.

All NOx-emitting equipment in GP002 and insignificant activities under Minn. R.7007.1300 are subject to this limit.


Volatile Organic Compounds: less than or equal to 110 tons/year using 12-monthRolling Sum to be calculated by the 21st day of each month for the previous12-month period as described later in this permit.

All VOC-emitting equipment in GP002 and insignificant activities under Minn. R.7007.1300 are subject to this limit.



The Permittee shall vent emissions from EU003, EU004, EU005, EU022, EU024,EU025, and EU026 to a control device meeting the permit requirements for GP001at all times EU003, EU004, EU005, EU022, EU024, EU025, and EU026 are inoperation.



16300002 - 005

Facility Name:

Permit Number:

04/10/13A-8

Equipment Labeling: The Permittee shall permanently affix a unique number toeach control equipment for tracking purposes. The numbers shall correlate the unitto the appropriate CE and GP numbers used in this permit. The number can beaffixed by placard, stencil, or other means. The number shall be maintained so thatit is readable and visible at all times from a safe distance. If equipment is added, itshall be given a new unique number; numbers from replaced or removedequipment shall not be reused.

Minn. R. 7007.0800, subp. 2

RECORDKEEPING REQUIREMENTS hdr

Daily Recordkeeping: Once each day of operation, the Permittee shall calculaterecord, and maintain records of the total quantity of all materials processed or usedat the facility which results in emission of PM, PM < 10 microns, PM < 2.5 microns,SO2, NOx, or VOC. For combustion equipment in GP 002 the Permittee shallmaintain daily records of the amount of fuel used. For the glass bubble makingprocess equipment in GP 002 (EUs 003-005, 022-026), the Permittee shallmaintain daily records of the production rate or process throughput. Alternatively,the Permittee may record the hours of operation of PM, PM < 10 microns, PM < 2.5microns, SO2, NOx, and VOC-emitting units. The records must provide adequatedata to calculate emissions of PM, PM < 10 microns, PM < 2.5 microns, SO2, NOx,and VOC.


Monthly Recordkeeping: By the 21st day of each month, the Permittee shallcalculate and record the PM, PM < 10 microns, PM < 2.5 microns, SO2, NOx, andVOC emissions for the previous month and the 12-month rolling sum emissions forthe previous 12 month period by summing the monthly emissions data for theprevious 12 months.


Material Content: Material content shall be determined by either a material SafetyData Sheet (MSDS) or a Letter of Certification, provided by the supplier for eachmaterial used, or other agency approved method. If a material content range isgiven, the highest number in the range shall be used in all compliance calculations.When using the MSDS as the basis of calculating Particulate Matter emissions, thePermittee shall assume that Particulate Matter consists entirely of PM < 10microns. Documentation of material content shall be maintained on-site andprovided when requested.

Minn. R. 7007.0800, subps. 4 and 5

Calculation Records:

For combustion equipment in GP 001 the Permittee shall calculate emissionsbased on fuel usage and emission factors specific to the type of combustionequipment in GP 002.

For the glass bubble making process equipment in GP 002 (EUs 003-005,022-026), the Permittee shall calculate emissions based on production rate orprocess throughput of each unit and emission factors specific to each unit in GP002.

The Permittee shall maintain an up to date list of all emission factors used in the12-month rolling sum calculations for all equipment in GP 002. For emissionfactors that are based on material content, the Permittee shall comply with theMaterial Content requirement of GP 002.

(continued below)

Minn. R. 7007.0800, subps. 4 and 5

Calculation Records continued:

If the Permittee uses uncontrolled emission factors in calculating the emissionsfrom units in GP 002 that are controlled as required by this permit by fabric filtersmeeting the requirements of GP 001, the Permittee may take credit for the controlefficiencies required by GP 001 when calculating PM, PM < 10 micron, and PM <2.5 micron emissions.

If the Permittee uses hours of operation for calculating the emissions from the unitsin GP002, the maximum permitted production rate shall be used to determineemissions for PM, PM < 10 microns, PM < 2.5 microns, SO2, NOx, and VOCs ifactual production rates are not available.

Minn. R. 7007.0800, subps. 4 and 5

Insignificant Activities: The Permittee shall evaluate the emissions from changesmade under Minn. R. 7007.1300 on a monthly basis, and shall include emissionsfrom insignificant activities in the monthly rolling sum. The Permittee shall maintainan up-to-date list of all insignificant activities on site.

All changes made in accordance with Minn. R. 7007.1300 and Minn. R. 7007.1250subp. 1A are subject to the requirements of GP002.



16300002 - 005

Facility Name:

Permit Number:

04/10/13A-9

Subject Item: EU 003 Glass Bubble Maker #18


GP 002 Emission Cap Limits

SV 003 052 Vent for Fabric Filter for Former 18


EMISSION LIMITS hdr

Total Particulate Matter: less than or equal to 0.053 grains/dry standard cubic footof exhaust gas unless required to further reduce emissions to comply with the lessstringent limit of either Minn. R. 7011.0730 or Minn. R. 7011. 0735.

Title I Condition: Limit taken to avoid classification asa major source or major modification under 40 CFRSection 52.21 & Minn. R. 7007.3000; Minn. R.7011.0715, subp. 1(A)

Opacity: less than or equal to 20 percent opacity Minn. R. 7011.0715, subp. 1(B)

CONTROL EQUIPMENT REQUIREMENTS (see GP001 and CE004 for additionalcontrol equipment requirements)

hdr

The Permittee shall operate and maintain a fabric filter that meets the requirementsof GP001 at all times that EU 003 is in operation.

Title I Condition: Limit taken to avoid classification asa major source or major modification under 40 CFRSection 52.21 & Minn. R. 7007.3000; Minn. R.7007.0800, subp. 2 and 14

RECORDKEEPING (see GP002 for recordkeeping requirements) hdr


16300002 - 005

Facility Name:

Permit Number:

04/10/13A-10


Associated Items: CE 034 Fabric Filter - Low Temperature, i.e., T<180 Degrees F


SV 004 054 Vent for fabric Filter for Former 20


EMISSION LIMITS hdr

Total Particulate Matter: less than or equal to 0.05 grains/dry standard cubic foot ofexhaust gas.



CONTROL EQUIPMENT REQUIREMENTS (see GP001 and CE034 for additionalcontrol equipment requirements)

hdr

The Permittee shall operate and maintain fabric filter a fabric filter that meets therequirements of GP001 at all times EU 004 is in operation.

Title I Condition: Limit taken to avoid classification asa major source or major modification under 40 CFRSection 52.21 & 7007.3000; Minn. R. 7007.0800,subp. 2 and 14



16300002 - 005

Facility Name:

Permit Number:

04/10/13A-11




SV 013 Maker 21 Fabric Filter Stack


EMISSION LIMITS hdr

Total Particulate Matter: less than or equal to 0.057 grains/dry standard cubic footof exhaust gas.



CONTROL EQUIPMENT REQUIREMENTS (See GP001, CE005 and CE035 foradditional control equipment requirements)

hdr

The Permittee shall operate and maintain a fabric filter that meets the requirementsof GP001 at all times EU 005 is in operation.

Title I Condition: Limit taken to avoid classification asa major source or major modification under 40 CFRSection 52.21 & 7007.3000; Minn. R. 7007.0800,subp. 2 and 14



16300002 - 005

Facility Name:

Permit Number:

04/10/13A-12

Subject Item: EU 022 Glass Furnace #74-04A

Associated Items: CE 024 Fabric Filter - High Temperature, i.e., T>250 Degrees F


SV 007 065 Vent for Fabric Filter for Reject Hopper, Remelt Feeder, and Glass Furnace


The Permittee is authorized to expand EU022 at any time during the life of permit16300002-005.

Minn. R. 7007.0800, subp. 2

EMISSION LIMITS hdr

Total Particulate Matter: less than or equal to 0.010 grains/dry standard cubic footof exhaust gas. Applicable during electric heating.

Title I Condition: limit to avoid classification as a majorsource or major modification under 40 CFR Section52.21 & Minn. R. 7007.3000; most stringent, meetslimit set by Minn. R. 7011.0715, subp. 1(A)

PM < 10 micron: less than or equal to 0.010 grains/dry standard cubic foot ofexhaust gas. Applicable during electric heating.

Title I Condition: limit to avoid classification as a majorsource or major modification under 40 CFR Section52.21 & Minn. R. 7007.3000; Minn. R. 7017.2025,subp. 3(C)



The Permittee shall not operate EU022 and EU023 simultaneously. EU022represents normal production operation with electric heating.

Title I Condition: limit to avoid classification as a majorsource or major modification under 40 CFR Section52.21& Minn. R. 7007.3000

Production: less than or equal to 4,400 lbs/hour using 24-hour Block Average . Thislimit applies after Computer Dispersion Modeling Protocol and ComputerDispersion Modeling Results demonstrating compliance with the SO2 NAAQS havebeen approved by the MPCA.


Production: less than or equal to 3530 lbs/hour using 24-hour Block Average . Title I Condition: limit to avoid classification as a majorsource or major modification under 40 CFR Section52.21 & Minn. R. 7007.3000; Minn. R. 7017.2025,subp. 3(C)




Performance Test: due 180 days after Computer Dispersion Modeling Resultsdemonstrating compliance with SO2 NAAQS have been approved by the MPCA.

The Performance Test shall measure Total Particulate Matter emissions.

Minn. R. 7017.2020, subp. 1


The Performance Test shall measure PM < 10 micron emissions.

Minn. R. 7017.2020, subp. 1


The Performance Test shall measure PM < 2.5 micron emissions.

Minn. R. 7017.2020, subp. 1

RECORDKEEPING (see GP002 for additional recordkeeping requirements) hdr

For each startup and shutdown of operation of EU022 the Permittee shall record:1. the date and time of each startup2. the date and time of each shutdown3. a statement documenting whether EU023 is also in operation

Minn. R. 7007.0800, subps. 4 and 5

Recordkeeping: On each day of operation, the Permittee shall maintain records ofthe weight of each product container and hours of production in each 24-hourperiod.

Title I Condition: limit to avoid classification as a majorsource or major modification under 40 CFR Section52.21 & Minn. R. 7007.3000; Minn. R. 7007.0800,subps. 4 and 5

Recordkeeping: By the 21st day of each month, the Permittee shall calculate theblock average pounds/hour production rate for each calendar day in the previousmonth from the daily records of product weight and hours of production.

Minn. R. 7007.0800, subps. 4 and 5

CONTROL EQUIPMENT REQUIREMENTS (See GP 001 and CE 024 for furthercontrol equipment requirements)

hdr


16300002 - 005

Facility Name:

Permit Number:

04/10/13A-13

Subject Item: EU 023 Glass Furnace #74-04B

Associated Items: GP 002 Emission Cap Limits

SV 008 066 Vent for Bypass for Glass Furnace



Total Particulate Matter: less than or equal to 0.30 grains/dry standard cubic foot ofexhaust gas unless required to further reduce emissions to comply with the lessstringent limit of either Minn. R. 7011.0730 or Minn. R. 7011.0735.

Minn. R. 7011.0610, subp. 1(A)(1)

Opacity: less than or equal to 20 percent opacity except for one six-minute periodper hour of not more than 60 percent opacity.

Minn. R. 7011.0610, subp. 1(A)(2)

Sulfur Dioxide: less than or equal to 2.0 lbs/million Btu heat input . The potential toemit from the unit is 0.0006 lb/MMBtu due to equipment design and allowable fuels.

Minn. R. 7011.0610, subp. 2(A)(2)


The Permittee shall not operate EU022 and EU023 simultaneously. EU023 bypassis used only during warm-up of this unit with natural gas. No raw materials are fedto this unit during this time.

Title I Condition: limit to avoid classification as a majorsource or major modification under 40 CFR Section52.21 & Minn. R. 7007.3000

Fuel Usage: less than or equal to 2.88 million cubic feet/year using 12-monthRolling Sum using only natural gas for fuel for startup. Electric heating is used fornormal operation after startup.

Title I Condition: limit to avoid classification as a majorsource or major modification under 40 CFR Section52.21 & Minn. R. 7007.3000

Fuel type: natural gas only. Minn. R. 7005.0100, subp. 35a



Minn. R. 7007.0800, subps. 4 and 5


Minn. R. 7007.0200; Minn. R. 7007.0800, subps. 2 and14

Daily Recordkeeping. For each day of operation with natural gas, the Permitteeshall record the total quantity of natural gas used.

Title I Condition: recordkeeping for limit to avoidclassification as a major source under 40 CFR Section52.21 & Minn. R. 7007.3000

Monthly Recordkeeping. By the 21st of the month, the Permittee shall calculate andrecord the following:1)The total natural gas usage in EU 023 for the previous calendar month using thedaily fuel usage records.3) The 12-month rolling sum fuel usage for the previous 12-month period bysumming the monthly fuel usage data for the previous 12 months.

Minn. R. 7007.0800, subps. 4 and 5


16300002 - 005

Facility Name:

Permit Number:

04/10/13A-14

Subject Item: EU 024 Fritting Systems #74-05



SV 009 067 Vent for Fabric Filter for Fritting System



Minn. R. 7007.0800, subp. 2

EMISSION LIMITS hdr



PM < 10 micron: less than or equal to 0.0140 grains/dry standard cubic foot ofexhaust gas.






Production: less than or equal to 3530 lbs/hour using 24-hour Block Average . Title I Condition: limit to avoid classification as a majorsource or major modification under 40 CFR Section52.21 & Minn. R. 7007.3000; Minn. R. 7017.2025,subp. 3(C)

The Permittee shall operate and maintain a fabric filter the meets the requirementsof GP001 at all times EU024 is in operation.





Minn. R. 7017.2020, subp. 1



Minn. R. 7017.2020, subp. 1



Minn. R. 7017.2020, subp. 1



Title I Condition: limit to avoid classification as a majorsource or major modification under 40 CFR Section52.21 & Minn. R. 7007.3000; Minn. R. 7007.0800,subps. 4 and 5


Minn. R. 7007.0800, subps. 4 and 5

CONTROL EQUIPMENT REQUIREMENTS (See GP001 and CE025 for additionalcontrol equipment requirements)

hdr


16300002 - 005

Facility Name:

Permit Number:

04/10/13A-15

Subject Item: EU 025 Impact Mill



SV 010 068 Vent for Fabric Filter for Impact Mill


EMISSION LIMITS hdr





hdr





16300002 - 005

Facility Name:

Permit Number:

04/10/13A-16

Subject Item: EU 026 Agglomerator System #74-04



SV 011 069 Vent for Fabric Filter for Cyclone and Dryer/Agglomerator System


EMISSION LIMITS hdr


Title I Condition: limit to avoid classification as a majorsource under 40 CFR Section 52.21 & Minn. R.7007.3000; most stringent, meets limit set by Minn. R.7011.0715, subp. 1(A)


Production limit: The emission unit shall be operated at an hourly production rateless than or equal to 5,980 lb/h, calculated as a daily average as specified below,unless a new range is set by permit reopening or permit amendment, based on thevalues recorded during the most recent MPCA approved performance test wherecompliance was demonstrated.

Minn. R. 7017.2025, subp. 3(C)

Recordkeeping: The Permittee shall maintain records of the weight of each productcontainer and the hours of production in each 24-hour period. By the 21st day ofeach month, the Permittee shall calculate an average pounds/hour production ratefor each calendar day in the previous month from this data.

Minn. R. 7007.0800. subp. 4(B)


hdr


Title I Condition: Limit taken to avoid classification asa major source and modification under 40 CFR Section52.21 & Minn. R. 7007.3000; Minn. R. 7007.0800,subp. 2 and 14



16300002 - 005

Facility Name:

Permit Number:

04/10/13A-17

Subject Item: EU 034 Emergency Backup Generator #55


SV 012 073 Vent for Emergency Generator


Opacity: less than or equal to 20 percent opacity Minn. R. 7011.2300, subp. 1

Sulfur Dioxide: less than or equal to 0.5 lbs/million Btu heat input . This limit is metwith fuel oil containing less than or equal to 0.5 % sulfur by weight.

Minn. R. 7011.2300, subp. 2

Fuel type: No. 2 fuel oil only. Minn. R. 7005.0100, subp. 35a

Daily Inspections: The Permittee shall check SV012 for any visible emissions onceeach day of operation during daylight hours.



Fuel Supplier Certification: Obtain and maintain a fuel supplier certification foreach shipment of No. 2 fuel oil, certifying the Sulfur Content of Fuel: less than orequal to 0.5 percent by weight

Minn. R. 7007.0800, subps. 4 & 5

Hours of Operation: The Permittee shall maintain documentation of hours ofoperation on site that the unit is an emergency diesel generator by design thatqualifies under the U.S. EPA memorandum entitled "Calculating Potential to Emit(PTE) for Emergency Generators" dated September 6, 1995, based on operation ofno more than 500 hours per year.

Minn. R. 7007.0800, subp. 4 & 5

The Permittee shall keep records of fuel type and usage on a monthly basis. Minn. R. 7007.0800, subp. 5




16300002 - 005

Facility Name:

Permit Number:

04/10/13A-18

Subject Item: CE 004 Fabric Filter - Medium Temperature i.e., 180 F<T<250 F

Associated Items: EU 003 Glass Bubble Maker #18

GP 001 Fabric Filter Requirements (CAM)



See GP 001 for baghouse control, monitoring, recordkeeping, reporting, and otherrequirements.

hdr

The Permittee shall operate and maintain a fabric filter that meets the requirementsof GP001 at all times that any emission unit controlled by the fabric filter (EU 003)is in operation. The Permittee shall document periods of non-operation of thecontrol equipment.


Pressure Drop: greater than or equal to 1 inches of water column and less than 30inches 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-approvedperformance test where compliance was demonstrated. The new range shall beimplemented upon receipt of the Notice of Compliance letter granting preliminaryapproval. The range is final upon issuance of a permit amendment incorporatingthe change. The Permittee shall record the pressure drop at least once every 24hours.

Pressure drop less than the minimum above, when due to replacement of filterbags is not a deviation and should not be reported on the semiannual deviationreports. After bag replacement, the pressure drop must return to at least theminimum within 21 working days, or corrective action must be taken.



16300002 - 005

Facility Name:

Permit Number:

04/10/13A-19



CE005 is being replaced by CE035. Once CE035 is in operation this unit will beretired or removed.

hdr


hdr







16300002 - 005

Facility Name:

Permit Number:

04/10/13A-20

Subject Item: CE 024 Fabric Filter - High Temperature, i.e., T>250 Degrees F

Associated Items: EU 022 Glass Furnace #74-04A





hdr







16300002 - 005

Facility Name:

Permit Number:

04/10/13A-21


Associated Items: EU 024 Fritting Systems #74-05





hdr







16300002 - 005

Facility Name:

Permit Number:

04/10/13A-22

Subject Item: CE 026 Fabric Filter - Low Temperature, i.e., T<180 Degrees F

Associated Items: EU 025 Impact Mill





hdr







16300002 - 005

Facility Name:

Permit Number:

04/10/13A-23


Associated Items: EU 026 Agglomerator System #74-04





hdr







16300002 - 005

Facility Name:

Permit Number:

04/10/13A-24






hdr







16300002 - 005

Facility Name:

Permit Number:

04/10/13A-25






hdr

The Permittee is authorized to install the piece of control equipment described inthis permit as CE 035 and vent EU 005 to CE 035. CE035 is replacing CE005.

The Permittee shall operate, and maintain a fabric filter that meets therequirements of GP001 at all times that any emission unit controlled by the fabricfilter (EU 005) is in operation. The Permittee shall document periods ofnon-operation of the control equipment.





TABLE B: SUBMITTALSFacility Name: 3M Cottage Grove Specialty Additives

Permit Number: 16300002 - 005

04/10/13B-1

Each submittal must be postmarked or received by the date specified in the applicable Table. Those submittals required by parts7007.0100 to 7007.1850 must be certified by a responsible official, defined in Minn. R. 7007.0100, subp. 21. Other submittals shallbe certified as appropriate if certification is required by an applicable rule or permit condition.

Send submittals that are required to be submitted to the U.S. EPA regional office to:

Chief Air Enforcement Air and Radiation Branch EPA Region V 77 West Jackson Boulevard Chicago, Illinois 60604

Table B lists most of the submittals required by this permit. Please note that some submittal requirements may appear in Table Aor, if applicable, within a compliance schedule located in Table C. Table B is divided into two sections in order to separately listone-time only and recurrent submittal requirements.

Send submittals that are required by the Acid Rain Program to:

U.S. Environmental Protection Agency Clean Air Markets Division 1200 Pennsylvania Avenue NW (6204N) Washington, D.C. 20460

Send any application for a permit or permit amendment to:

Fiscal Services Minnesota Pollution Control Agency 520 Lafayette Road North St. Paul, Minnesota 55155-4194

Also, where required by an applicable rule or permit condition, send to the Permit Document Coordinator notices of:- accumulated insignificant activities,- installation of control equipment,- replacement of an emissions unit, and- changes that contravene a permit term.

Unless another person is identified in the applicable Table, send all other submittals to:

AQ Compliance Tracking Coordinator Industrial Division Minnesota Pollution Control Agency 520 Lafayette Road North St. Paul, Minnesota 55155-4194

TABLE B: ONE TIME SUBMITTALS OR NOTIFICATIONSFacility Name: 3M Cottage Grove Specialty Additives


04/10/13B-2

What to send When to send Portion of Facility Affected

Application for Permit Reissuance due 180 days before expiration of ExistingPermit

Total Facility

Computer Dispersion Modeling Protocol due before Startup of operations at EU022and EU024 at increased production rate of4400 lb/hr. for SO2. This protocol will describethe proposed modeling methodology andinput data, in accordance with MPCAmodeling guidance for Title V air dispersionmodeling analyses.

Total Facility

Computer Dispersion Modeling Results due before Startup of operations at EU022and EU024 at increased production rate of4400 lb/hr for SO2. The submittal shouldadhere to MPCA modeling guidance for TitleV air dispersion modeling analyses and theinformation approved by the MPCA in themodeling protocol.

Total Facility

Notification of the Actual Date of Initial Startup due 15 days after Initial Startup of CE035. CE035

TABLE B: RECURRENT SUBMITTALSFacility Name: 3M Cottage Grove Specialty Additives


04/10/13B-3

What to send When to send Portion of Facility Affected

Semiannual Deviations Report due 30 days after end of each calendarhalf-year starting 03/24/2005. The firstsemiannual report submitted by the Permitteeshall cover the calendar half-year in which thepermit is issued. The first report of eachcalendar year covers January 1 - June 30.The second report of each calendar yearcovers July 1 - December 31. If no deviationshave occurred, the Permittee shall submit thereport stating no deviations.

Total Facility

Annual Report due 31 days after end of each year followingPermit Issuance. The Permittee shall submitan annual report by January 31st thatdescribes the changes made at the facilityduring the previous calendar year using thelatest MPCA application forms. The reportshall include the emission unit, stack/vent,group, and control equipment data for anynew or replaced units or control devices. Thereport shall document the PM, PM < 10micron, PM < 2.5 micron, SO2, NOx and VOC12-month rolling sum calculations for theprevious calendar year. The report shall besubmitted with the annual ComplianceCertification listed in Table B. As part of theAnnual Report, the Permittee shall verify andcertify that the facility has maintained minorsource status for New Source Review.

GP002

Compliance Certification due 30 days after end of each calendar yearstarting 03/24/2005 (for the previous calendaryear). To be submitted on a form approved bythe Commissioner, both to the Commissionerand to the US EPA regional office in Chicago.This report covers all deviations experiencedduring the calendar year.

Total Facility

APPENDIX MATERIAL – APPENDIX I INSIGNIFICANT ACTIVITIES AND GENERAL APPLICABLE REQUIREMENTS Facility Name: 3M Cottage Grove Specialty Additives Permit Number: 16300002‐005

Appendix I – Insignificant Activities and General Applicable Requirements

Minn. R. Rule Description of the Activity General Applicable

Requirement

7007.1300 subp. 3(I)

Individual emissions units at a stationary source, each of which have a potential to emit the following pollutants in amounts less than: 1) 2 tpy of carbon monoxide and 2) 1 tpy of each nitrogen oxide, sulfur dioxide, particulate matter, particulate matter less than ten microns, volatile organic compounds (including hazardous air pollutant‐containing VOC), and ozone. 3M Cottage Grove Specialty Additives has 2 screeners that are designated insignificant activities under this subpart

Minn. R. 7011.0715 (PM and opacity)

7007.1300 subp. 4

Emission units with emissions less than 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

3M Cottage Grove Specialty Additives has the following emission units/activities that qualify as insignificant activities under this subpart: product storage silos, lime storage silo, raw material bins, bag dump stations, reject hopper material collection, additive bag feeders, bag baler, dryer, packaging room, powder pusher, silica storage silo, trailer loading


7007.4110 Equipment venting PM/PM10 inside a building, provided that emissions from the equipment are filtered through an air cleaning system and vented inside of the building 100% of the time. 3M Cottage Grove Specialty Additives has the following emission units/activities that qualify as insignificant activities under this subpart: blend hopper, offline packaging systems, nuisance dust system, bins, blenders, remelt feeder, reject hopper, mill product collection, remelt transport, floated products line, oversize box, weigh hoppers


APPENDIX MATERIAL – APPENDIX I INSIGNIFICANT ACTIVITIES AND GENERAL APPLICABLE REQUIREMENTS Facility Name: 3M Cottage Grove Specialty Additives Permit Number: 16300002‐005

Appendix II – Stack Modeled Parameters

Stack Modeled Parameters

Type Modeling

ID* SV # EU # Description

Stack Height (m)

Stack Diameter

(m)

Exit Velocity (m/s)

Exit Temperatu

re (K)

PM10 Emission Rate (g/sec)

PM10

Emission Rate (lb/hr)

POINT CGTAP009 009

009, 010, 011 Maker 11 Oxidizer 18.1 0.915 54.266 672.039 0.066 0.523818

POINT CGTAP010 010 012, 014 Maker 14 Oxidizer 18.3 0.915 54.266 672.039 0.066 0.523818

POINT CGTAP012 012 011B Maker 11 Zone 1 Exhaust 12.3 0.534 17.952 366.483 0.012 0.09524









POINT CGTAPGEN IA IA Emergency Generator ‐ IA 0.4 0.102 37.95 857.59 0.03 0.238099

POINT CGBUB052 003 003 Maker 18 12.8 1.22 22.638 366.483 0.19 1.507962



POINT CGBUB056 006

007, 008, 009, 010

Blend Hoppers and Tote to Bin Transfer 13.6 0.305 48.51 293.15 0 0

POINT CGBUB065 007

021, 022, 035

Glass Furnace #74‐04A, Remelt Feeder, Reject Hopper 13.2 0.446 18.521 408.15 0.048 0.380959

POINT CGBUB066 008 023 Glass Furnace Bypass 12.2 2.219 1.832 588.706 0.000126 0.001

POINT CGBUB067 009 024 Fritting Systems #74‐05 13.1 0.286 51.536 380.372 0.082 0.650805

APPENDIX MATERIAL – APPENDIX II STACK MODELED PARAMETERS Facility Name: 3M Cottage Grove Specialty Additives Permit Number: 16300002‐005


Type Modeling


Stack Height (m)

Stack Diameter

(m)

Exit Velocity (m/s)

Exit Temperatu

re (K)


PM10


POINT CGBUB068 010 025 Impact Mill 25.3 0.61 29.915 322.039 0.291 2.309563

POINT CGBUB069 011 026 Dryer/Agglomerator System 18.8 0.357 18.9 388.706 0.095 0.753981

POINT CGBUB073 012 034 Emergency Generator 9.1 0.204 43.226 294.261 0 0

POINT CGBUBIA1 NA NA Dryer – IA 11.2 0.152 2.665 316.483 0.044 0.349212

POINT CGBUBIA2 NA NA Packaging Station ‐ IA 8.2 0.152 64.37 294.261 0 0

POINT CGBUBIA3 NA NA Silica Storage Silo – IA 18 0.204 0.001 294.261 0.009 0.07143

POINT CGBUB062 NA 062 Lime Storage Silo – IA 20.3 0.204 0.001 294.261 0.027 0.214289

POINT CGBUB063 NA 063 Raw Material Bins (7), Weigh Hoppers (4) 31.4 0.204 12.608 294.261 0.167 1.325419

POINT CGBUB064 NA 064 Bag Dump Stations (4) 13.5 0.253 0.001 294.261 0 0

POINT CGBUBIA4 NA 013 Product Storage Silo 13.7 0.356 0.001 294.261 0.034 0.269846


POINT CGBUBIA6 NA NA Packaging Room 8.2 0.152 64.37 294.261 0.095 0.753981

POINT CGINC010 010 008 Incinerator Stack (Kiln) 50.1 1.601 14.503 349.539 0.226 1.793681

POINT CGAUT001 001 001 Feeder System 3.7 0.344 6.234 283.706 0.001 0.007937

POINT CGAUT002 002 004 Grinder 3.7 0.305 0.001 303.15 0.001 0.007937

POINT CGAUT003 003 002 Extruder 10.3 0.233 22.174 322.039 0.001 0.007937

POINT CGAUT004 004 002, 003 Extruder/Casting Die 13.7 0.344 6.975 307.039 0.019 0.150796

POINT CGAUT005 005 005 Corona Treater 9.3 0.152 0.001 290.928 0 0

POINT CGAUT006 006 006 Laminator Casting Die 11.4 0.525 0.001 294.261 0.006 0.04762

POINT CGAUT007 007 007 Oven 11.4 0.525 0.001 287.594 0 0

POINT CGAUT008 008 007 Oven 10.8 0.788 0.001 280.372 0 0

POINT CGAUT009 009 008, 009 Corona Treater, Duster 11 0.23 0.001 297.594 0.006 0.04762

POINT CGAUT010 010

010‐019, 024‐027 Dust Collector 8.3 0.91 14.535 294.261 0.001 0.007937



Type Modeling


Stack Height (m)

Stack Diameter

(m)

Exit Velocity (m/s)

Exit Temperatu

re (K)


PM10


POINT CGAUT011 011 020 Heating Equipment 9.9 0.736 10.516 326.483 0 0


POINT CGAUT014 014 028 PM‐4 Dryer and Heating Equipment 9.9 0.873 1.419 322.039 0 0

POINT CGAUT015 015 029 PM‐2 Dryer 14.6 0.381 7.451 322.039 0 0

POINT CGAUT016 016 030 Roof Gas Heater 10.7 0.267 9.318 1144.26 0.005 0.039683

POINT CGAUT017 017 031 Baghouse Emissions 8.3 0.909 14.535 294.261 0 0







POINT AB112001 001 001 Batch Oven #1 13.1 0.457 10.061 435.928 0.03 0.238099

POINT AB112002 002 002 Batch Oven #2 13.1 0.915 2.875 435.928 0.03 0.238099

POINT AB112003 003 003 Small Cartridge Filter 6.6 0.305 12.936 293.15 0.008 0.063493

POINT AB112004 004 004 Large Cartridge Filter 6.6 0.457 17.823 293.15 0.126 1.000017

POINT AB112005 005 005 Prefire Kiln 14.6 0.254 13.982 305.372 0.003 0.02381

POINT AB112006 006 006 Old Kiln 12.8 0.305 2.264 755.372 0.05 0.396832

POINT AB112007 007 007 New Kiln #3 19.8 0.343 20.442 560.928 0.405 3.21434

POINT AB112008 008 008 Kiln #1 Burner 19.8 1.067 0.001 866.483 0.004 0.031747

POINT AB112009 009 009 Kiln #2 Burner 19.8 1.067 0.001 866.483 0.004 0.031747

POINT AB112010 010 010 Kilns #1 & #2 19.8 0.61 2.07 330.372 0.001 0.007937

POINT AB112018 018 018 New Emergency Generator 3 0.152 37.903 880.372 0.057 0.452389

POINT AB112024 024 026 Oven #3 13.1 0.915 2.875 435.928 0.076 0.603185

POINT AB112026 026

029‐031, 038‐042,

New Crushing & Screening Room 22.8 0.843 11.853 293.15 0.266 2.111147



Type Modeling


Stack Height (m)

Stack Diameter

(m)

Exit Velocity (m/s)

Exit Temperatu

re (K)


PM10


048‐050

POINT AB112036 036 043 Dust Collector 11.9 0.393 18.268 293.15 0.004 0.031747

POINT AB112037 037 033 Oven #4 13.1 0.915 7.187 435.928 0.076 0.603185

POINT AB112038 038 047 Emergency Generator 2.4 0.098 27.729 749.261 0.002 0.015873

POINT CGABIA1 NA 015 Old Area Mixer – IA 10.1 0.254 14.53 319.261 0.01 0.079366

POINT CGABIA2 NA 028 New Dryer – IA 17.2 0.254 14.53 305.372 0.033 0.261909

POINT CGABIA3 NA NA Mineral Treatment – IA 5.5 0.102 0.001 293.15 0.021 0.166669

POINT CGABIA4 NA NA Mineral Blender ‐ IA 9.1 0.203 0.001 293.15 0.076 0.603185

POINT CGTSS01 001

001, 002, 022, 025, 026 HMC/SAE Line 10.2 0.649 12.575 305.372 0 0

POINT CGTSS05 006

007‐014, 024 Pilot Coater, Oven, TO 14.3 1.015 12.282 1033.15 0.021 0.166669

POINT CGTSS06 006 005 Emergency Generator 12.8 0.102 14.553 422.039 0.0000126 0.0001

POINT CGTSS07 007 006 Emergency Generator 11.1 0.102 14.553 422.039 0.0000126 0.0001

POINT CGTSS08 008 015 Glass Maker 15.2 0.447 7.515 533.15 0.064 0.507945

POINT CGTSS09 009 016, 023 TCP Unit 15.2 0.256 16.592 378.706 0.001 0.007937

POINT CGTSSIA1 NA ISO041 Vibrating Screen (Rotex) 9.91 1.264 3.123 294.261 0.126 1.000017

POINT CGTSSIA2 NA ISO042 Vibrating Screen (Tysifter) 9.91 1.264 3.123 294.261 0.126 1.000017

POINT CGTSSIA3 NA ISO044 HIS Web Cleaner (Hoffman) 14.3 1.02 12.28 1033.15 0.025 0.198416

POINT CGTSSIA4 NA ISO045 Waft Web Cleaner (Herbert) 14.3 1.02 12.28 1033.15 0.025 0.198416

POINT CGCHM182 182 099 Bldg 4 Eclipse Boiler Vent 15.6 0.152 6.468 533.15 0.004 0.031747

POINT CGCHM117 117 100 Bldg 4 Heatec Boiler Vent 14.2 0.152 6.468 533.15 0.003 0.02381



Type Modeling


Stack Height (m)

Stack Diameter

(m)

Exit Velocity (m/s)

Exit Temperatu

re (K)


PM10


POINT CGCHM097 97 101 Bldg 25 Emergency Generator 2.2 0.12 0.001 533.15 0.005 0.039683

POINT CGCHM236 236 050 Bldg 70 Emergency Generator 2.56 0.152 0.001 533.15 0.003 0.02381

POINT CGCMGEN IA IA Emergency Generator ‐ IA 1.6 0.102 0.001 857.59 0.03 0.238099

POINT CGOPT001 001 001 Vent for Mixing Hood 8.99 0.31 6.254 293.15 0.000125998 0.001

POINT CGOPT003 003 003, 004

Vent for Mixing Hood/Tape Casting 14.2 0.526 0.001 293.15 0.0000576 0.000457

POINT CG19IA1 NA NA Laser Fan – IA 9.6 0.199 11.12 293.15 0.011 0.087303

POINT CG19IA2 NA NA Sinter Press 1 – IA 10.7 0.445 5.019 293.15 0.003 0.02381

POINT CG19IA3 NA NA Grinding Room – IA 5.8 0.344 0.001 293.15 0.006 0.04762

POINT CG19IA4 NA NA BL Area – IA 10.1 0.339 15.677 293.15 0.002 0.015873

POINT CG19IA5 NA NA Sinter Press 2 – IA 11.3 0.396 15.5 293.15 0.093 0.738108

POINT CG111IA1 NA NA Segmented Assembly – IA 10.4 0.426 8.278 293.15 0.144 1.142876

POINT CG111IA2 NA NA R‐Press Oven Fan – IA 13.4 0.542 0.001 293.15 0.003 0.02381

POINT CG111IA3 NA NA R‐Press Spray Hood Fan –IA 13.3 0.409 5.01 293.15 0.014 0.111113

POINT CG111IA4 NA NA BL‐OG Room Fan – IA 9.9 0.305 3.667 293.15 0.002 0.015873

POINT CGSS003 003 003 Emergency Generator WWTP, Building 137 1.1 0.089 0.001 394.26 0.001 0.007937

POINT CGSS005 IA IA Emergency Generator Building 111 3.048 0.152 0.001 394.261 0.06665289 0.529

POINT CGSSIA01 IA IA Fire Pump Building 113 ‐ IA 4.6 0.152 55.625 648.706 0.08454457 0.671

POINT CGSSIA02 IA IA Fire Pump Building 109 ‐ IA 3.4 0.127 56.108 730.372 0.08038665 0.638

POINT CGSSIA03 IA IA Emergency Generator Building 115 ‐ IA 2.896 0.051 0.001 394.261 0.001007983 0.008



POINT CGSSIA07 IA IA Emergency Generator 2.438 0.051 0.001 394.261 0.002897952 0.023



Type Modeling


Stack Height (m)

Stack Diameter

(m)

Exit Velocity (m/s)

Exit Temperatu

re (K)


PM10


Building 144 ‐ IA

VOLUME CGTAPIA IA IA Building 110 IAs 6.4 0.02 0.158733

VOLUME CGINCIA1 NA NA B47 Natural Gas Furnace ‐ IA 11 0.000282 0.002238

VOLUME CGINCIA2 NA NA

B145 Natural Gas Furnace, B145 Emergency Generator, Lime Silo ‐ IA 18.4 0.4 3.174657

VOLUME CGCHEMB4

003‐006, 009, 016‐024

052, 055, 056 Building 4 Sources 15.2 0.163 1.293673

VOLUME CGCHEMB6 032, 051‐054 007 Building 6 Sources 12.1 0.023 0.182543

VOLUME CGCHEMB7

082, 087, 092‐095, 064, 066‐069

015, 069 Building 7 Sources 14.9 0.016 0.126986

VOLUME CGPA_1 NA NA Paved Haul Road A 2.59 0.00017 0.001349
















Type Modeling


Stack Height (m)

Stack Diameter

(m)

Exit Velocity (m/s)

Exit Temperatu

re (K)


PM10













VOLUME CGPB_1 NA NA Paved Haul Road B 2.59 0.000442 0.003508









VOLUME CGPC_1 NA NA Paved Haul Road C 2.59 0.00012 0.000952











Type Modeling


Stack Height (m)

Stack Diameter

(m)

Exit Velocity (m/s)

Exit Temperatu

re (K)


PM10


VOLUME CGPD_1 NA NA Paved Haul Road D 2.59 0.00237 0.01881































Type Modeling


Stack Height (m)

Stack Diameter

(m)

Exit Velocity (m/s)

Exit Temperatu

re (K)


PM10


VOLUME CGPE_1 NA NA Paved Haul Road E 2.59 0.000525 0.004167





VOLUME CGPF_1 NA NA Paved Haul Road F 2.59 0.000364 0.002889







VOLUME CGPG_1 NA NA Paved Haul Road G 2.59 0.000161 0.001278



















Type Modeling


Stack Height (m)

Stack Diameter

(m)

Exit Velocity (m/s)

Exit Temperatu

re (K)


PM10






























VOLUME CGPH_1 NA NA Paved Haul Road H 2.59 0.00161 0.012778



Type Modeling


Stack Height (m)

Stack Diameter

(m)

Exit Velocity (m/s)

Exit Temperatu

re (K)


PM10















VOLUME CGPI_1 NA NA Paved Haul Road I 2.59 0.00184 0.014603








VOLUME CGPJ_1 NA NA Paved Haul Road J 2.59 0.00179 0.014207










Type Modeling


Stack Height (m)

Stack Diameter

(m)

Exit Velocity (m/s)

Exit Temperatu

re (K)


PM10










VOLUME CGPK_1 NA NA Paved Haul Road K 2.59 0.000451 0.003579



















VOLUME CGPL_1 NA NA Paved Haul Road L 2.59 0.00179 0.014207




Type Modeling


Stack Height (m)

Stack Diameter

(m)

Exit Velocity (m/s)

Exit Temperatu

re (K)


PM10
















VOLUME CGPM_1 NA NA Paved Haul Road M 2.59 0.000601 0.00477

















Type Modeling


Stack Height (m)

Stack Diameter

(m)

Exit Velocity (m/s)

Exit Temperatu

re (K)


PM10












VOLUME CGPN_1 NA NA Paved Haul Road N 2.59 0.00108 0.008572









VOLUME CGPO_1 NA NA Paved Haul Road O 2.59 0.000117 0.000929






VOLUME CGPP_1 NA NA Paved Haul Road P 2.59 0.00225 0.017857






Type Modeling


Stack Height (m)

Stack Diameter

(m)

Exit Velocity (m/s)

Exit Temperatu

re (K)


PM10










VOLUME CGPQ_1 NA NA Paved Haul Road Q 2.59 0.000277 0.002198







VOLUME CGPR_1 NA NA Paved Haul Road R 2.59 0.00169 0.013413










VOLUME CGPS_1 NA NA Paved Haul Road S 2.59 0.000322 0.002556






Type Modeling


Stack Height (m)

Stack Diameter

(m)

Exit Velocity (m/s)

Exit Temperatu

re (K)


PM10

































Type Modeling


Stack Height (m)

Stack Diameter

(m)

Exit Velocity (m/s)

Exit Temperatu

re (K)


PM10



VOLUME CGPT_1 NA NA Paved Haul Road T 2.59 0.000877 0.00696




















VOLUME CGPU_1 NA NA Paved Haul Road U 2.59 0.000877 0.00696










Type Modeling


Stack Height (m)

Stack Diameter

(m)

Exit Velocity (m/s)

Exit Temperatu

re (K)


PM10














VOLUME CGUV_1 NA NA Paved Haul Road V 2.59 0.0036 0.028572



















Type Modeling


Stack Height (m)

Stack Diameter

(m)

Exit Velocity (m/s)

Exit Temperatu

re (K)


PM10


VOLUME CGUG_1 NA NA Unpaved Haul Road G 2.59 0.000674 0.005349































Type Modeling


Stack Height (m)

Stack Diameter

(m)

Exit Velocity (m/s)

Exit Temperatu

re (K)


PM10

































Type Modeling


Stack Height (m)

Stack Diameter

(m)

Exit Velocity (m/s)

Exit Temperatu

re (K)


PM10



* Key: CGTAP = 3M Cottage Grove Tape Manufacturing CGBUB = 3M Cottage Grove Specialty Additives CGINC = 3M Cottage Grove Corporate Incinerator CGAUT = 3M Cottage Grove Building 17 AB112 = 3M Cottage Grove Abrasives Systems Division CGAB = 3M Cottage Grove Abrasives Systems Division CGTSS = 3M Cottage Grove TCM Division CGCHM = 3M Cottage Grove Film and Materials Resource Division CGOPT = 3M Cottage Grove Optical Division CG19 = 3M Cottage Grove Building 19 CG111 = 3M Cottage Grove Building 111 CGSS = 3M Cottage Grove Center Utilities

APPENDIX MATERIAL – APPENDIX III 3M COTTAGE GROVE SPECIALTY ADDITIVES STACK MODELED PARAMETERS Facility Name: 3M Cottage Grove Specialty Additives Permit Number: 16300002‐005

Appendix III – 3M Cottage Grove Specialty Additives Stack Modeled Parameters


Type Modeling


Stack Height (m)

Stack Diameter

(m)

Exit Velocity (m/s)

Exit Temperature

(K)


PM10





POINT CGBUB056 006

007, 008, 009, 010

Blend Hoppers and Tote to Bin Transfer 13.6 0.305 48.51 293.15 0 0

POINT CGBUB065 007

021, 022, 035

Glass Furnace #74‐04A, Remelt Feeder, Reject Hopper 13.2 0.446 18.521 408.15 0.048 0.380959

POINT CGBUB066 008 023 Glass Furnace Bypass 12.2 2.219 1.832 588.706 0.000126 0.001

POINT CGBUB067 009 024 Fritting Systems #74‐05 13.1 0.286 51.536 380.372 0.082 0.650805

POINT CGBUB068 010 025 Impact Mill 25.3 0.61 29.915 322.039 0.291 2.309563

POINT CGBUB069 011 026 Dryer/Agglomerator System 18.8 0.357 18.9 388.706 0.095 0.753981

POINT CGBUB073 012 034 Emergency Generator 9.1 0.204 43.226 294.261 0 0

POINT CGBUBIA1 NA NA Dryer – IA 11.2 0.152 2.665 316.483 0.044 0.349212

POINT CGBUBIA2 NA NA Packaging Station ‐ IA 8.2 0.152 64.37 294.261 0 0

POINT CGBUBIA3 NA NA Silica Storage Silo – IA 18 0.204 0.001 294.261 0.009 0.07143

POINT CGBUB062 NA 062 Lime Storage Silo – IA 20.3 0.204 0.001 294.261 0.027 0.214289

POINT CGBUB063 NA 063 Raw Material Bins (7), Weigh Hoppers (4) 31.4 0.204 12.608 294.261 0.167 1.325419

POINT CGBUB064 NA 064 Bag Dump Stations (4) 13.5 0.253 0.001 294.261 0 0



POINT CGBUBIA6 NA NA Packaging Room 8.2 0.152 64.37 294.261 0.095 0.753981

Technical Support Document, Permit Action Number: 16300002‐005 Page 1 of 12 Date: 4/10/2013

TECHNICAL SUPPORT DOCUMENT

For

AIR EMISSION PERMIT NO. 16300002‐005

This technical support document (TSD) is intended for all parties interested in the permit and to meet

the requirements that have been set forth by the federal and state regulations (40 CFR § 70.7(a)(5) and

Minn. R. 7007.0850, subp. 1). The purpose of this document is to provide the legal and factual

justification for each applicable requirement or policy decision considered in the determination to issue

the permit.

1. General Information

1.1 Applicant and Stationary Source Location:

Table 1. Applicant and Source Address

Applicant/Address Stationary Source/Address

(SIC Code: 3229)

3M Company

Building 224‐5W‐03

St. Paul, MN 55144

3M Cottage Grove Specialty Additives

10746 Innovation Rd

Cottage Grove

Washington County

Contact: Tina Mumm

Phone: 651‐737‐3606

1.2 Facility Description

The 3M Cottage Grove Specialty Additives facility manufactures specialty glass products. The operations

cover by this permit (buildings 74, 101 and 110) together with the operations covered the permits for

3M Cottage Grove – Abrasive Systems Division (Building 112) and 3M Cottage Grove – Building 19 & 111,

constitute a single source under Prevention of Significant Degradation (PSD) regulations.

Emissions from the Specialty Additives facility result from raw material handling, fuel combustion, and

from production processes. Direct electrical heating is used on the glass melter with natural gas used to

heat the start‐up of the melter and diesel used for the back‐up generator. Natural gas is used on the

glass bubble makers.

1.3 Description of the Activities Allowed by this Permit Action

This permit action is a major amendment to expand the glass furnace (EU022) and increase the hourly

production limit of the glass furnace (EU022) and the fritting systems (EU024) from 3,530 lb/hr to 4,400

lb/hr. The facility also plans to modify the fan associated with the fabric filter that currently controls the

fritting system (CE025). Existing limits for PM and PM10 are not changing as part of this permit action,


therefore, there is no increase in potential to emit (PTE) for PM or PM10. Increases of other criteria

pollutants are listed in Table 3 below.

The capacity of the natural gas glass furnace (EU023) is not changing. This unit is used for startup and

shutdown of EU022 and is not physically capable of producing any product.

Additional Changes made to permit:

Moved “Emission Cap Limits” from facility level to GP002 in the permit. Revised language to

reflect current PreCap language for control equipment.

Additional monitoring and recordkeeping requirements were added for limits taken to avoid

PSD

Included limits on PM10 for EU022 and EU024. These PM10 emissions limits were used for

emissions calculating purposes. In order to avoid an increase in PM10 emissions and trigger re‐

modeling, the facility has accepted limits on PM 10.

1.4. Facility Emissions:

Table 2. Title I Emissions Increase Summary

Pollutant

Unlimited Potential

Emissions from the

Modification (tpy)

Limited Potential

Emissions from

the Modification

(tpy)

NSR/112(g) Threshold

for New Major Source

(tpy)

NSR/ 112(g) Review

Required? (Yes/No)

PM 5.70 5.70 250 No

PM10 5.70 5.70 250 No

PM2.5 3.85 3.85 250 No

NOx 4.63 4.63 250 No

SO2 16.38 16.38 250 No

CO 0 0 250 No

Ozone (VOC) 0 0 250 No

CO2e* 0 0 100,000 No

Total HAPs 0 0 10/25 0

*Carbon dioxide equivalents as defined in Minn. R. 7007.0100.

Table 3. Non‐Title I Emissions Increase Summary

Pollutant

After

Change

(lb/hr)

Before

Change

(lb/hr)

Net Change

(lb/hr)

Insignificant

Modification

Thresholds

(lb/hr <)

Minor and

Moderate

Amendment

Thresholds

(lb/hr < or >)

Type of

Amendment

(Minor or

Moderate)


Pollutant

After

Change

(lb/hr)

Before

Change

(lb/hr)

Net Change

(lb/hr)

Insignificant

Modification

Thresholds

(lb/hr <)

Minor and

Moderate

Amendment

Thresholds

(lb/hr < or >)

Type of

Amendment

(Minor or

Moderate)

PM10 1.3 1.3 0 0.855 3.42 NA

NOx 1.6 0.84 0.22 2.28 9.13 NA

SO2 3.74 2.98 0.77 2.28 9.13 NA

Table 4. Facility Classification*

Classification Major/Affected Source Synthetic Minor/Area Minor/Area

PSD PM, PM10, PM2.5, SO2, NOx, VOC

CO

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

CO

Part 63 NESHAP X

*This classification is based on the aggregate PTE of the operations cover by this permit (buildings 74, 101 and 110) together with the permit for 3M Cottage Grove – Abrasive Systems Division (Building 112) and 3M Cottage Grove – Building 19 & 111.

2. Regulatory and/or Statutory Basis

New Source Review

The changes authorized by this amendment do not increase carbon dioxide equivalent (CO2e) emissions,

and therefore are not subject to regulation under NSR for CO2e (“subject to regulation” is defined in 40

CFR § 52.21(b)(49)). In addition, the existing facility is subject to limits such that all other NSR regulated

air pollutants are less than the major source thresholds for NSR (40 CFR § 52.21(b)(1)). Therefore, as

defined by the federal rules, the facility is not considered an existing major source for NSR.

The underlying definition of stationary source for PSD requires grouping all facilities under common

ownership or control which are on contiguous or adjacent property and which also have the same first

two‐digit SIC Code. At Cottage Grove, the Specialty Additives facility is classified as SIC Code 32xx as are

the Abrasives Division facility and Building 19 and 111. Together with the limits established in the

permits for these other two facilities, the entire stationary source (the three facilities combined)

remains below major source thresholds under the PSD program.

Part 70 Permit Program

The facility is a major source under the Part 70 permit program.


New Source Performance Standards (NSPS)

For the operations covered by this permit, there are no applicable New Source Performance Standards.

National Emission Standards for Hazardous Air Pollutants (NESHAP)

The entire 3M Cottage Grove campus is considered a single major source under 40 CFR Part 63;

however, there are no major source NESHAPs that apply to the operations covered by this permit.

Compliance Assurance Monitoring (CAM)

CAM currently applies to the facility. This permit action does not affect CAM applicability. The most

recent CAM plan is attached to this TSD (see Attachment 4).

Environmental Review & AERA

The facility does not trigger any of the requirements for the need to conduct environmental review, i.e.

an Environmental Assessment Worksheet (EAW), and is not required to perform an AERA.

Minnesota State Rules

No newly applicable Minnesota Standards of Performance are triggered by this permit action.

Table 6. Regulatory Overview of Units Affected by the Modification/Permit Amendment

Level* Applicable Regulations Comments:

Total

Facility

40 CFR pt. 50; Minn. Stat.

Section 116.07, subds, 4a & 9;

Minn. R. 7007.0100, subp. 7(A),

7(L) & 7(M); Minn. R.

7007.0800, subps. 1, 2 & 4;

Minn. R. 7009.0010‐7009.0080

The Facility has been identified as possibly contributing to a violation

of the SO2 National Ambient Air Quality Standard (NAAQS). As a

result, the Facility is required to submit a computer dispersion

modeling protocol before increasing emissions of SO2.

Total

Facility



Minn. R. 7007.0100, subp. 7(A),

7(L) & 7(M); Minn. R.

7007.0800, subps. 1, 2 & 4;

Minn. R. 7009.0010‐7009.0080

The Facility has been identified as possibly contributing to a violation

of the SO2 NAAQS. As a result, the Facility is required to submit a

computer dispersion modeling results demonstrating compliance

with the SO2 NAAQS before increasing emissions of SO2.

Total

Facility



Minn. R. 7007.0100, subp. 7(A),

7(L) & 7(M); Minn. R.

7007.0800, subps. 1, 2 & 4;

Minn. R. 7009.0010‐7009.0080

The Facility completed computer dispersion modeling to

demonstrate compliance with the PM10 NAAQS. The parameters

used in PM10 modeling are listed in Appendix II of this permit. Based

on the results of the modeling, the Permittee is required to re‐model

when changes that require a minor, moderate or major permit

amendment affect any modeled parameter or emission rate

documented in Appendix II.

GP001

Title I Condition: To avoid

classification as a major source

and modification under 40 CFR

The Permittee has taken limits to avoid major source status under 40

CFR Section 52.21 (see GP002). The requirements in this group allow

the Permittee flexibility in replacing, modifying, or adding new fabric


Level* Applicable Regulations Comments:

Section 52.21 and Minn. R.

7007.3000

filters. The requirements in this group apply to existing fabric filters

in this group and any replaced, modified or new fabric filters. The

Permittee is still required to obtain the appropriate amendment, as

applicable, before making a change.

GP 002

Title I limit to avoid




7007.3000

Facility wide limits taken to avoid major source status under 40 CFR

Section 52.21.

EU 022





7007.3000

The Facility has previously taken limits in calculating PM10 emissions

to avoid major source and major modification status under 40 CFR

Section 52.21 and Minn. R. 7007.3000. This permit action

incorporates that limit into the permit.





7007.3000

Modified production limit. This limit is being increased as part of this

permit action. The facility is required to conduct a performance test

to demonstrate that the existing particulate limit can be met at the

increased production rate. The facility is allowed to construct this

unit at the increased production rate; however, the facility cannot

begin operation at the increased production rate until compliance

with the SO2 NAAQS has been demonstrated.

EU 024





7007.3000

The Facility has previously taken limits in calculating PM10 emissions

to avoid major source and major modification status under 40 CFR

Section 52.21 and Minn. R. 7007.3000. This permit action

incorporates that limit into the permit.





7007.3000

Modified production limit. This limit is being increased as part of this

permit action. The facility is required to conduct a performance test

to demonstrate that the existing particulate limit can be met at the

increased production rate. The facility is allowed to construct this

unit at the increased production rate; however, the facility cannot

begin operation at the increased production rate until compliance

with the SO2 NAAQS has been demonstrated.

*Where the requirement appears in the permit (e.g., EU, SV, GP, etc.).

3. Technical Information

3.1 Emissions Increase Analysis

Attachment 1 to this TSD contains spreadsheets and supporting information prepared by the Minnesota

Pollution Control Agency (MPCA) and the Permittee.

Calculation of PM/PM10 PTE


The permit contains limits for PM and incorporates limits for PM10 for EU022 and EU024. These limits

were used to calculate the PTE for these units.

Calculation of PM2.5 and NOx PTE

Emission factors from AP‐42 Table 11.15‐1 were used to calculate PM2.5 and NOx emissions. For NOx,

the combustion related NOx emissions were subtracted from the emission factor because EU022 is an

electric furnace.

Calculation of SO2 and HAPs PTE

A materials mass balance was used to calculate SO2 and HAP emissions. The highest SO2 emitting

material has a 0.024% SO2 content. For HAPs, the PTE calculation was based on the MSDS assumption of

1*10‐5 for the weight fraction of PM emissions equal to HAP.

3.2 Dispersion Modeling In 2004, through a cursory screening analysis of a number of facilities, the MPCA identified a number of

facilities, including 3M Cottage Grove Specialty Additives, that may be exceeding the NAAQS. In order to

resolve the potential NAAQS issue the facility conducted PM10 dispersion modeling for the entire 3M

Cottage Grove campus. Based on the modeling results and MPCA guidance, the facility is subject to “Tier

3” modeling requirements. Tier 3 requires the Permittee to submit a remodeling submittal for changes

that requires a minor, moderate, or major amendment that affects any modeled parameter or emission

rate has been added to the permit. The determination as to whether or not limits taken for modeling

purposes are required to be listed as permit requirements is outside the scope of this permit action. As a

result, no limits based on modeling are being incorporated into the permit as part of this permit action;

limits based on modeling may be incorporated into the permit in future permit actions. Per MPCA

practice, a table of the modeled parameters has been added to the permit as an appendix (see Appendix

II). Although the applicability of any modeling‐based PM10 limits were not evaluated in this permit

action, the combination of the Tier 3 remodeling submittal requirements and the modeling parameter

appendix are reasonable at this time to ensure that the Permittee shall not increase emissions

significantly above the rates used to demonstrate compliance with the NAAQS and MAAQS until the

time at which PM10 limits are incorporated, as applicable.

Table 7: NAAQS/MAAQS PM10 Modeling Results

Pollutant Averaging Period

NAAQS Standard (µg/m3)

MAAQS Standard (µg/m3)

Total Modeled Concentration (includes background and nearby sources) (µg/m3)

Percent of Standard (%)

NAAQS MAAQS

PM10 24‐hour 150 150 136.68 91.12% 91.12%

Annual ‐‐ 50 37.42 ‐‐ 74.84%


This NAAQS screening also identified 3M Cottage Grove Specialty Additives as possibly exceeding the

NAAQS for SO2. The Facility is required to demonstrate compliance with the SO2 NAAQS through

computer dispersion modeling before beginning operations at the increased production rate for EU022

and EU024. The Facility may construct EU022 to handle the increased production rate before

demonstrating compliance with the SO2 NAAQS. Additionally, the Facility may continue to operate

EU022 and EU024 at the previously permitted production rate (3530 lb/hr). Once the Facility

demonstrates compliance with the SO2 NAAQS, the Facility may begin operation of EU022 and EU024 at

the increased production rate (4400 lb/hr).

3.3 Periodic Monitoring and CAM

In accordance with the Clean Air Act, it is the responsibility of the owner or operator of a facility to have

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

requirements.

For CAM, the Permittee submitted a CAM proposal as required by 40 CFR § 64.3. It can be found in

Attachment 4 to this TSD. Further discussion of decisions about CAM can be found in Table 8.

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

The likelihood of the facility violating the applicable requirements;

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

The variability of emissions over time;

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

the emission unit;

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

The kind of monitoring found on similar units elsewhere.

The table below summarizes the periodic monitoring requirements for those emission units for which

the monitoring required by the applicable requirement is nonexistent or inadequate or where CAM

applies.

Table 8. Changes to Periodic Monitoring as a Result of this Permit Action

Level* Requirement (rule

basis)

Additional Monitoring Discussion

GP001

PM/PM10 ≤ various

gr/DSCF

Opacity ≤ 20%

(Title I Condition To

avoid classification as

major source and

modification under 40

CFR 52.21 & Minn. R.

Performance testing

for PM and opacity

The emissions cap language (listed under GP002) was

modified as part of this permit action. The new

PreCap language limits all criteria pollutants to below

major source thresholds but allows the Permittee to

modify or install new control equipment that meets

the requirements of GP001. Performance testing is

required after modifying existing or installing new

control equipment to demonstrate compliance with



basis)


7007.3000; Minn. R.

7017.2020, subp. 1)

existing emissions limitations.

GP001

Control Efficiency: PM

≥ 99%, PM10/PM2.5 ≥

93%

PM/PM10 ≤ various

gr/DSCF

Opacity ≤ 20%

(Title I Condition To


major source and


CFR 52.21 & Minn. R.

7007.3000; Minn. R.

7007.0800, subp. 4 and

14)

Visible emission

checks

The Permittee is now required to perform visible

emission checks in the event that a fabric filter is

operating outside the permitted range, or the

pressure drop monitoring equipment for a fabric

filter is not in operation.

GP002

12 month rolling sum

limits on PM, PM10,

PM2.5, SO2, NOx, & VOC

≤ various tpy (Title I

Condition: To avoid

classification as major

source and


CFR Section 52.21 &

Minn. R. 7007.3000)

Daily and monthly

recordkeeping of

emissions of criteria

pollutants and hours

of operation, 12‐

month rolling sum

calculations, on‐going

material content

records

In order to demonstrate compliance with limits on

criteria pollutants, the Permittee is required to

calculate and record emissions of criteria pollutants

daily and use daily records of emissions to calculate

the 12‐month rolling sum of emissions of criteria

pollutants monthly. These calculations are based off

of the quantity of material produced, hours of

operation and material content records.

EU022

PM/ PM10 ≤ 0.01

gr/DSCF, Opacity ≤ 20%

Minn. R. 7017.2020,

subp. 1

Performance testing

for PM, PM10 and

opacity

The Permittee shall conduct a one time performance

test to demonstrate compliance with PM, PM10, and

opacity limits. This unit is subject to the requirements

of CAM, therefore a one‐time test is sufficient to

demonstrate compliance with applicable limits.

Production ≤ 4,400

lb/hr

(Title I Condition: To


major source and


CFR Section 52.21 &

Minn. R. 7007.3000,

Minn. R. 7007.0800,

subps. 4 & 5)

Recordkeeping In order to demonstrate compliance with the

production limit, the Permittee is required to record

and maintain records of weight of materials

produced and hours of operation.



basis)


EU024

PM/ PM10 ≤ 0.014

gr/DSCF, Opacity ≤ 20%



major source and


CFR Section 52.21 &

Minn. R. 7007.3000,

Minn. R. 7017.2020,

subp. 1)

Performance testing

for PM, PM10 and

opacity

The Permittee shall conduct a one time performance

test to demonstrate compliance with PM, PM10, and

opacity limits. This unit is subject to the requirements

of CAM, therefore a one‐time test is sufficient to

demonstrate compliance with applicable limits.

Production ≤ 4,400

lb/hr



major source and


CFR Section 52.21 &

Minn. R. 7007.3000

Minn. R. 7007.0800,

subps. 4 & 5)

Recordkeeping In order to demonstrate compliance with the

production limit, the Permittee is required to record

and maintain records of weight of materials

produced and hours of operation.

*Where the requirement appears in the permit (e.g., EU, SV, GP, etc.).

3.4 Insignificant Activities

3M Cottage Grove Specialty Additives has several operations which are classified as insignificant

activities under the MPCA’s permitting rules. These are listed in Appendix A to the permit.

The permit is required to include periodic monitoring for all emissions units, including insignificant

activities, per EPA guidance. The insignificant activities at this Facility are only subject to general

applicable requirements. Using the criteria outlined earlier in this TSD, the following table documents

the justification why no additional periodic monitoring is necessary for the current insignificant

activities.

Table 9. Insignificant Activities

Insignificant Activity

General Applicable Emission limit Discussion

Individual emissions units with a PTE less than: 1) 2 tpy of CO and 2) 1 tpy of each NOx, SO2, PM, PM10, and VOCs

PM, variable depending on airflow or process weight rate Opacity < 20% (with exceptions) (Minn. R. 7011.0715 and Minn. R. 7011.610)

The units at the 3M Cottage Grove Specialty Additives facility that qualify under this subpart are not expected to generate a significant amount of particulate matter.


Insignificant Activity

General Applicable Emission limit Discussion

Emission units with emissions less than PTE of 5.7 pounds per hour or actual emissions of 2 tpy CO; PTE of 2.28 lb/hr or actual emissions of 1 tpy for NOx, SO2, PM, PM10, and VOCs

PM, variable depending on airflow or process weight rate Opacity < 20% (with exceptions)

(Minn. R. 7011.0715 and Minn. R. 7011.610)

For the units at the 3M Cottage Grove Specialty Additives facility that qualify under this subpart, it is highly unlikely that they could violate the applicable requirement.

Equipment venting PM/PM10 inside a building, provided that emissions from the equipment are:

a). filtered through an air cleaning system; and

b). vented inside of the building 100% of the time

PM, variable depending on airflow Opacity < 20%

(Minn. R. 7011.0715)

For the units at the 3M Cottage Grove Specialty Additives facility that qualify under this subpart, it is highly unlikely that they could violate the applicable requirement. In addition, these units are vented inside a building, so testing for PM or opacity is not feasible.

3.5 Community Involvement

3M Cottage Grove provides community interaction through several avenues, including participation at

City Council and Commission meetings, recurring community publications, and responding to direct

inquiries from members of the public with information and tours. With regard to the permit

amendment application for the melter rebuild (EU022), the most likely avenue of interaction will be

through the City of Cottage Grove Environmental Commission. This commission is a formal body of nine

members which advises the city council on environmental issues. 3M Cottage Grove interacts with the

commission though attendance at its regular meetings and through informal meetings with commission

members. Pending and recently issued permits are a common topic of discussion at these meetings.

3.6 Permit Organization

In general, the permit meets the MPCA Delta Guidance for ordering and grouping of requirements. One

area where this permit deviates slightly from Delta guidance is in the use of appendices. While

appendices are fully enforceable parts of the permit, in general, any requirement that the MPCA thinks

should be electronically tracked (e.g., limits, submittals, etc.), should be in Table A or B of the permit.

The main reason is that the appendices are word processing sections and are not part of the electronic

tracking system. Violation of the appendices can be enforced, but the computer system will not

automatically generate the necessary enforcement notices or documents. Staff must generate these.

Two‐stage Issuance:


The Minnesota permitting rules (Minn. R. 7007.0750, supb. 7) allow the MPCA to separate the issuance

of the construction provisions from the operation provisions of a permit. This approach allows a

Permittee to commence construction after the completion of the 30‐day public comment period, but

prior to the completion of EPA’s 45‐day review period required by Part 70. Minn. R. 7007.0750, subp. 7

indicates that amendments to Part 70 permits that authorize construction or modification and include

enforceable limitation(s) assumed to avoid being subject to a new source review program under part C

or D of the act are eligible for two‐stage issuance. This permit is eligible for 2‐stage issuance because it

is a major amendment to a Part 70 permit that authorizes a modification to EU 022 and an increase in

production for EU022 and EU024. The production limits are Title I conditions assumed to avoid

classification as a major source under the PSD program. Therefore, the modification of EU022 and the

increase in production of EU022 and EU024 can be authorized after the 30‐day public notice. Conditions

that will be issued after the 30‐day comment period, but prior to the completion of the EPA 45‐day

review period are marked with “[Stage I]” in the citation field.

3.6 Comments Received

The MPCA plans to issue this permit under the provisions of Minn. R. 7007.0750, subp. 7. This rule

allows the MPCA to issue permits in two stages. The requirements issued in the first stage – the Stage 1

conditions – are the portions of the permit that relate to the construction activities authorized by the

permit.

Examples of Stage 1 conditions include emissions limits, restrictions on hours of operation and the

recordkeeping associated with that restriction, and requirements to demonstrate initial compliance. In

this permit, Stage 1 conditions are identified as Title I Conditions to avoid classification as a major

modification and can be found listed under EU022 and EU024 requirements. During the public comment

period and prior to final permit issuance, the Stage 1 conditions are denoted in the permit by

“[Stage 1].” These designations will be removed in Stage 2 (final) permit issuance.

This section will be completed after the conclusion of the referenced review periods.

Public Notice Period: February 22, 2013 – March 22, 2013

Comments were not received from the public during the public notice period.

EPA 45‐day Review Period: February 22, 2013 – April 8, 2013

Comments were not received from EPA during their review period.

4. Permit Fee Assessment

Attachment 3 to this TSD contains the MPCA’s assessment of Application and Additional Points used to

determine the permit application fee for this permit action as required by Minn. R. 7002.0019. The


permit action includes one permit application, received after the effective date of the rule (July 1, 2009).

The permit does not include any additional chargeable activities.

5. Conclusion

Based on the information provided by 3M Cottage Grove Specialty Additives, the MPCA has reasonable

assurance that the operation of the emission facility, as described in the Air Emission Permit No.

16300002‐005 and this TSD, will not cause or contribute to a violation of applicable federal regulations

and Minnesota Rules.

Staff Members on Permit Team: Cindy Schafer (permit writer/engineer)

Sarah Kilgriff (enforcement)

Curt Stock (stack testing)

Kelsey Suddard (peer reviewer)

AQ File No. 23AS; DQ 4125

Attachments: 1. Emissions Increase Calculation Spreadsheets

2. CD‐01 Forms

3. Points Calculator

4. CAM Plan

ATTACHMENT 1

EMISSIONS INCREASE CALCULATION SPREADSHEETS

Emissions Calculations

3M Cottage Grove Specialty Additives (Bldgs 74, 101, 110)

Furnace Rebuild Project ‐ Existing Emissions

Uncontrolled Pollution Controlled Controlled

Emission Emission Potential to Control Potential to Potential to

Unit Maximum Rate Emission Factor Estimation Rate Emit (PTE) Efficiency Emit (PTE) Emit (PTE)

Unit ID Stack ID Name Pollutant (units/hr) units (lb/units) (ref) Method (lb/hr) (ton/yr) (%) (lb/hr) (ton/yr) Notes

022 065 Glass Furnace PM 3500 lb 1.078E‐04 3 MN Rule 7011.0715 0.38 1.65 0 0.38 1.65 0.01 gr/dscf, permit limit

022 065 Glass Furnace PM10 3500 lb 1.078E‐04 3 MN Rule 7011.0715 0.38 1.65 0 0.38 1.65 0.01 gr/dscf, permit limit

022 065 Glass Furnace PM2.5 3500 lb 1.000E‐04 3 AP‐42 0.35 1.53 0 0.35 1.53

022 065 Glass Furnace NOx 3500 lb 8.500E‐04 3 AP‐42 2.98 13.03 0 2.98 13.03

022 065 Glass Furnace SO2 3500 lb 2.400E‐04 3 Mass Balance 0.84 3.68 0 0.84 3.68

022 065 Glass Furnace HAPs 3500 lb 1.00E‐05 3 Mass Balance 0.000004 0.000017 0.000004 0.000017

024 067 Fritting System PM 3500 lb 2.643E‐04 4 MN Rule 7011.0715 0.92 4.05 0 0.92 4.05 0.014 gr/dscf, permit limit

024 067 Fritting System PM10 3500 lb 2.643E‐04 4 MN Rule 7011.0715 0.92 4.05 0 0.92 4.05 0.014 gr/dscf, permit limit

024 067 Fritting System PM2.5 3500 lb 1.000E‐04 4 AP‐42 0.35 1.53 0 0.35 1.53

TOTAL PM EMISSIONS 5.70 5.70

TOTAL PM10 EMISSIONS 5.70 5.70

TOTAL PM2.5 EMISSIONS 3.07 3.07

TOTAL SO2 EMISSIONS 3.68 3.68

TOTAL NOx EMISSIONS 13.03 13.03

TOTAL HAP EMISSIONS 0.000017 0.000017

Notes:

1 ‐ Air flow for the current Glass Furnace is 6125 acfm (or 4400 dscfm).

2 ‐ Air flow for the current fritting system is 7000 acfm (or 5396 dscfm).

Emission Factor References:

3 ‐ Glass Furnace

VOC: Unlike some glass production facilities, this facility does not use raw materials containing VOC. The emission factor for process emissions of VOC cited in the reference is therefore not applicable

SO2: SO2 emissions are estimated using a mass balance. Based on the product emitting the highest SO2, 0.024% of SO2 in feed will be emitted.

PM, PM10: Based on permit limit of 0.01 gr/dscf.

PM2.5: Based on AP‐42, Table 11.15‐1, Pressed and Blown Glass Melting Furnace for baghouse control.

HAP: Weight fraction of 1E‐05 of PM emissions equal HAP, based on MSDS.

Control: Control efficiency of baghouse in 99% for PM and PM10 (capture efficiency of 100 percent and collection efficiency of 99 percent).

4 ‐ Fritting System

VOC: AIRS, Frit Manufacturer (3‐05‐013‐01). Unlike some glass production facilities, this facility does not use raw materials containing VOC

PM, PM10: Based on permit limit of 0.014 gr/dscf



CO: AP‐42, Table 11.15‐1, Pressed and Blown Glass Melting Furnance. This furnace is electric, so there is no fuel combusted. It was assumed the CO emissions from glass melting are solely due to fuel combustion. So there are no CO emissions

from the furnace.

NOx: AP‐42, Table 11.15‐1, Pressed and Blown Glass Melting Furnance. This furnace is electric, so there is no fuel combusted. A correction was applied to the NOx emission factor to account for the portion of NOx emission due to fuel bound

nitrogen. The fuel consumption rate for a similarly sized gas fired melting furance can be estimated by 0.2 lb/ton glass producted / 21 lb/MMscf burned = 0.0009524 MMscf/ton glass produced. An average nitrogen content of natural gas of 0.46%

was found in Perry's. The NO2 emissions from fuel bound nitrogen is then: 0.0009525 MMscf/ton produced * 1,000,000 scf/MMscf * (1 lbmole N2 / 385.3 scf) * (2 lbmole NO / lbmole * N2) * (30 lb NO/lbmole) = 6.82 lb/ton produced. If this

emission factor is subtracted from the NOx emission factor from Table 11.15‐1 of AP‐42, the new emission factor is: 8.5 lb/ton ‐ 6.8 lb/ton = 1.7 lb/ton.

Emissions Calculations

3M Cottage Grove Specialty Additives (Bldgs 74, 101, 110)

Furnace Rebuild Project ‐ Proposed Scenario

Uncontrolled Pollution Controlled Controlled

Emission Emission Potential to Control Potential to Potential to

Unit Maximum Rate Emission Factor Estimation Rate Emit (PTE) Efficiency Emit (PTE) Emit (PTE)

Unit ID Stack ID Name Pollutant (units/hr) units (lb/units) (ref) Method (lb/hr) (ton/yr) (%) (lb/hr) (ton/yr) Notes

022 065 Glass Furnace PM 4400 lb 8.571E‐05 3 MN Rule 7011.0715 0.38 1.65 0 0.38 1.65 0.01 gr/dscf, permit limit

022 065 Glass Furnace PM10 4400 lb 8.571E‐05 3 MN Rule 7011.0715 0.38 1.65 0 0.38 1.65 0.01 gr/dscf, permit limit

022 065 Glass Furnace PM2.5 4400 lb 1.000E‐04 3 AP‐42 0.44 1.93 0 0.44 1.93

022 065 Glass Furnace NOx 4400 lb 8.500E‐04 3 AP‐42 3.74 16.38 0 3.74 16.38

022 065 Glass Furnace SO2 4400 lb 2.400E‐04 3 Mass Balance 1.06 4.63 0 1.06 4.63

022 065 Glass Furnace HAPs 4400 lb 1.00E‐05 3 Mass Balance 0.000004 0.000017 0.000004 0.000017

024 067 Fritting System PM 4400 lb 2.102E‐04 4 MN Rule 7011.0715 0.92 4.05 0 0.92 4.05 0.014 gr/dscf, permit limit

024 067 Fritting System PM10 4400 lb 2.102E‐04 4 MN Rule 7011.0715 0.92 4.05 0 0.92 4.05 0.014 gr/dscf, permit limit

024 067 Fritting System PM2.5 4400 lb 1.000E‐04 4 AP‐42 0.44 1.93 0 0.44 1.93

TOTAL PM EMISSIONS 5.70 5.70

TOTAL PM10 EMISSIONS 5.70 5.70

TOTAL PM2.5 EMISSIONS 3.85 3.85

TOTAL SO2 EMISSIONS 4.63 4.63

TOTAL NOx EMISSIONS 16.38 16.38

TOTAL HAP EMISSIONS 0.000017 0.000017

Notes:

2 ‐ Air flow for the Glass Furnace will not change as part of the project (Air flow = 4400 dscfm).

2 ‐ Air flow for the fritting system post project is 10,000 acfm (or 7708 dscfm).

Emission Factor References:

3 ‐ Glass Furnace

VOC: Unlike some glass production facilities, this facility does not use raw materials containing VOC. The emission factor for process emissions of VOC cited in the reference is therefore not applicable

SO2: SO2 emissions are estimated using a mass balance. Based on the product emitting the highest SO2, 0.024% of SO2 in feed will be emitted. Please see Title V renewal

PM, PM10: Based on permit limit of 0.01 gr/dscf.


HAP: Weight fraction of 1E‐05 of PM emissions equal HAP, based on MSDS.


4 ‐ Fritting System

VOC: AIRS, Frit Manufacturer (3‐05‐013‐01). Unlike some glass production facilities, this facility does not use raw materials containing VOC

PM, PM10: Based on permit limit of 0.014 gr/dscf



NOx: AP‐42, Table 11.15‐1, Pressed and Blown Glass Melting Furnace. This furnace is electric, so there is no fuel combusted. A correction was applied to the NOx emission factor to account for the portion of NOx emission due to fuel bound

nitrogen. The fuel consumption rate for a similarly sized gas fired melting furnace can be estimated by 0.2 lb/ton glass produced / 21 lb/MMscf burned = 0.009524 MMscf/ton glass produced. An average nitrogen content of natural gas of 0.46%

was found in Perry's. The NO2 emissions from fuel bound nitrogen is then: 0.009525 MMscf/ton produced * 1,000,000 scf/MMscf * (1 lbmole N2 / 385.3 scf) * (2 lbmole NO / lbmole) * 0.46% N2 * (30 lb NO/lbmole) = 6.82 lb/ton produced. If this

emission factor is subtracted from the NOx emission factor from Table 11.15‐1 of AP‐42, the new emission factor is: 8.5 lb/ton ‐ 6.8 lb/ton = 1.7 lb/ton. CO: AP‐42, Table 11.15‐1, Pressed and Blown Glass Melting Furnance. This furnace is electric, so there is no fuel combusted. It was assumed the CO emissions from glass melting are solely due to fuel combustion. So there are no CO emissions

from the furnace.

Emissions Calculations3M Cottage Grove Specialty Additives (Bldgs 74, 101, 110)Furnace Rebuild Project ‐ Emissions Comparison

Annual Emissions (tons per year)

Pollutant Pre Project Post Project Difference

PSD

Modification

Threshold

Above PSD

Threshold?PM 5.70 5.70 0.00 25 NoPM10 5.70 5.70 0.00 15 NoPM2.5 3.07 3.85 0.79 10 NoNOx 3.68 4.63 0.95 40 NoSO2 13.03 16.38 3.35 40 NoHAPs 0.00 0.00 0.00 10/25 No

Hourly Emissions (lb/hr)Pollutant Pre Project Post Project Difference

PM 1.30 1.30 0.00PM10 1.30 1.30 0.00PM2.5 0.70 0.88 0.18NOx 0.84 1.06 0.22SO2 2.98 3.74 0.77HAPs 0.00 0.00 0.00

ATTACHMENT 2

CD‐01 FORMS

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

Facility Name: 3M Cottage Grove Specialty Additives


19 Feb, 2013 11:00Page 1 of 28

Subject Item: Total Facility

NC/CA

Type Citation Requirement

CD hdr This facility, along with 3M Cottage Grove Abrasive Systems Division (ID16300017) and 3M Cottage Grove Building 19 and 111 (ID 16300133) constitute asingle source under PSD regulations.

1.0

CD hdr NAAQS/MAAQS MODELING REQUIREMENTS2.0

S/A 40 CFR pt. 50; Minn. Stat. Section116.07, 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

Computer Dispersion Modeling Protocol: due before Startup of operations atEU022 and EU024 at increased production rate of 4400 lb/hr. for SO2. Thisprotocol will describe the proposed modeling methodology and input data, inaccordance with MPCA modeling guidance for Title V air dispersion modelinganalyses.

3.0

S/A 40 CFR pt. 50; Minn. Stat. Section116.07, 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

Computer Dispersion Modeling Results: due before Startup of operations at EU022and EU024 at increased production rate of 4400 lb/hr for SO2. The submittalshould adhere to MPCA modeling guidance for Title V air dispersion modelinganalyses and the information approved by the MPCA in the modeling protocol.

4.0

CD 40 CFR pt. 50; Minn. Stat. Section116.07, 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

This permit requires modeling to demonstrate compliance with the NationalAmbient Air Quality Standards (NAAQS). The Permittee may not make any changeat the source that would result in an increase in SO2 emissions until it can bedemonstrated that emissions from the facility as permitted do not cause anexceedance of the NAAQS. This includes changes that might otherwise qualify asinsignificant modifications and minor or moderate amendments. This is a state-onlyrequirement and is not enforceable by the EPA Administrator or citizens under theClean Air Act.

5.0


The parameters used in PM < 10 micron modeling are listed in Appendix II of thispermit. The purpose of listing the parameters in the appendix is to provide abenchmark for future changes.

6.0


Modeling Triggers: For changes that do not require a permit amendment and affectany modeled parameter or emission rate documented in Appendix III, or are anaddition to the information documented in Appendix III, a Remodeling Submittalrequirement is not triggered at the time of the change. The Permittee shall keepupdated records on site of all parameters and emission rates. The Permittee shallsubmit any changes to parameters and emission rates with the next requiredRemodeling Submittal.

For changes that require a minor, moderate, or major permit amendment and affectany modeled parameter or emission rate documented in Appendix III, or are anaddition to the information documented in Appendix III, a Remodeling Submittalrequirement is triggered. The Permittee shall include previously made changes toparameters and emission rates that did not trigger a Remodeling Submittal.

7.0


Remodeling Submittal: The Permittee must submit to the MPCA for approvalchanges meeting the above criteria and must wait for a written approval beforemaking such changes (see introduction of Table B of this permit for MPCA mailinginformation). For minor amendments, written approval of the modeling may begiven before permit issuance; however, this approval applies only to the modelingand not to any other changes. The information submitted must include, for stackand vent sources, source emission rate, location, height, diameters, exit velocity,exit temperature, discharge direction, use of rain caps or rain hats, and, ifapplicable, locations and dimensions of nearby buildings. For non-stack/ventsources, this includes the source emissions rate, location, size and shape, releaseheight, and, if applicable, any emissions rate scalars, and the initial lateraldimensions and initial vertical dimensions and adjacent building heights.

8.0


Remodeling Submittal, continued:The plume dispersion characteristics due to the revisions of the information mustbe equivalent to or better than the dispersion characteristics modeled based on the10/26/2011 modeling report submittal. The Permittee shall demonstrate thisequivalency in the proposal. If the information does not demonstrate equivalent orbetter dispersion characteristics, or if a conclusion cannot readily be made aboutthe dispersion, the Permittee must submit full remodeling.

9.0




19 Feb, 2013 11:00Page 2 of 28

CD hdr EMISSION CAP LIMITS10.0

CD Title I Condition: To avoidclassification as a major sourceand modification under 40 CFRSection 52.21 and Minn. R.7007.3000

This permit establishes limits on the facility to keep it a minor source under NewSource Review for PM, PM < 10 microns, PM < 2.5 microns, SO2, NOx and VOC.The Permittee cannot make any change at the source that would make the sourcea major source under New Source Review until a permit amendment has beenissued. This includes changes that might otherwise qualify as insignificantmodifications and minor or moderate amendments.

11.0

CD hdr OPERATIONAL REQUIREMENTS12.0

CD 40 CFR pt. 50; Minn. Stat. Section116.07, subds. 4a & 9; Minn. R.7007.0100, subp. 7(A), 7(L), &7(M); Minn. R. 7007.0800, subps.1, 2 & 4; Minn. R.7009.0010-7009.0080

The Permittee shall comply with National Primary and Secondary Ambient AirQuality Standards, 40 CFR pt. 50, and the Minnesota Ambient Air QualityStandards, Minn. R. 7009.0010 to 7009.0080. Compliance shall be demonstratedupon written request by the MPCA.

13.0

CD Minn. R. 7011.0020 Circumvention: Do not install or use a device or means that conceals or dilutesemissions, which would otherwise violate a federal or state air pollution control rule,without reducing the total amount of pollutant emitted.

14.0

CD Minn. R. 7007.0800, subp. 2;Minn. R. 7007.0800, subp. 16(J)

Air Pollution Control Equipment: Operate all pollution control equipment wheneverthe corresponding process equipment and emission units are operated, unlessotherwise noted in Table A.

15.0

CD Minn. R. 7007.0800, subps. 14and 16(J)

Operation and Maintenance Plan: Retain at the stationary source an operation andmaintenance plan for all air pollution control equipment. At a minimum, the O & Mplan shall identify all air pollution control equipment and control practices and shallinclude a preventative maintenance program for the equipment and practices, adescription of (the minimum but not necessarily the only) corrective actions to betaken to restore the equipment and practices to proper operation to meet applicablepermit conditions, a description of the employee training program for properoperation and maintenance of the control equipment and practices, and the recordskept to demonstrate plan implementation.

16.0

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

17.0

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

18.0

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

19.0

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

20.0

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

21.0

CD hdr PERFORMANCE TESTING22.0

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

23.0

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

Performance Test Notifications and Submittals:

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

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

The Notification, Test Plan, and Test Report may be submitted in alternative formatas allowed by Minn. R. 7017.2018.

24.0




19 Feb, 2013 11:00Page 3 of 28

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

25.0

CD hdr MONITORING REQUIREMENTS26.0

CD Minn. R. 7007.0800, subp. 4(D) Monitoring Equipment Calibration: Annually calibrate all required monitoringequipment (any requirements applying to continuous emission monitors are listedseparately in this permit).

27.0

CD Minn. R. 7007.0800, subp. 4(D);40 CFR Section 70.6(a)(3)(i)(C)

Operation of Monitoring Equipment: Unless otherwise noted in Tables A or B,monitoring a process or control equipment connected to that process is notnecessary during periods when the process is shutdown, or during checks of themonitoring systems, such as calibration checks and zero and span adjustments. Ifmonitoring records are required, they should reflect any such periods of processshutdown or checks of the monitoring system.

28.0

CD hdr RECORDKEEPING29.0

CD Minn. R. 7007.0800, subp. 5(C) Recordkeeping: Retain all records required by this permit for a period of at leastfive (5) years from the date of monitoring, sample, measurement, or report.Records shall be retained at the stationary source for at least two (2) years, afterwhich they may be transferred to and retained at the 3M Center for at least three(3) years. Records which must be retained at this location for at least two (2) yearsinclude all calibration and maintenance records, all original recordings forcontinuous monitoring instrumentation, and copies of all reports required by thepermit. Records must conform to the requirements listed in Minn. R. 7007.0800,subp. 5(A).

30.0

CD Minn. R. 7007. 0800, subp. 5(B) Recordkeeping: Maintain records describing any insignificant modifications (asrequired by Minn. R. 7007. 1250, subp. 3) including records of the emissionsresulting from those changes.

31.0

CD Minn. R. 7007. 0800, subp. 5(B);40 CFR Section 70.4(b)(12)

Recordkeeping: Maintain records describing any changes contravening permitterms (as required by Minn. R. 7007.1350 subp. 2), including records of theemissions resulting from those changes.

32.0

CD Minn. R. 7007.1200, subp. 4 If the Permittee determines that no permit amendment or notification is requiredprior to making a change, the Permittee must retain records of all calculationsrequired under Minn. R. 7007.1200. For expiring permits, these records shall bekept for a period of five years from the date the change was made or until permitreissuance, whichever is longer. The records shall be kept at the stationary sourcefor the current calendar year of operation and may be kept at the stationary sourceor office of the stationary source for all other years. The records may be maintainedin either electronic or paper format.

33.0

CD hdr REPORTING and SUBMITTALS34.0

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

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

35.0

CD Minn. R. 7019.1000, subp. 2 Breakdown Notifications: Notify the Commissioner within 24 hours of a breakdownof more than one hour duration of any control equipment or process equipment ifthe breakdown causes any increase in the emissions of any regulated air pollutant.The 24-hour time period starts when the breakdown was discovered or reasonablyshould have been discovered by the owner or operator. However, notification is notrequired in the circumstances outlined in Items A, B and C of Minn. R. 7019.1000,subp. 2.

At the time of notification or as soon as possible thereafter, the owner or operatorshall inform the Commissioner of the cause of the breakdown and the estimatedduration. The owner or operator shall notify the Commissioner when thebreakdown is over.

36.0




19 Feb, 2013 11:00Page 4 of 28

CD Minn. R. 7019.1000, subp. 1 Notification of Deviations Endangering Human Health or the Environment: As soonas possible after discovery, notify the Commissioner or the state duty officer, eitherorally or by facsimile, of any deviation from permit conditions which could endangerhuman health or the environment.

37.0

CD Minn. R. 7019.1000, subp. 1 Notification of Deviations Endangering Human Health or the Environment Report:Within 2 working days of discovery, notify the Commissioner in writing of anydeviation from permit conditions which could endanger human health or theenvironment. Include the following information in this written description:1. the cause of the deviation;2. the exact dates of the period of the deviation, if the deviation has been corrected;3. whether or not the deviation has been corrected;4. the anticipated time by which the deviation is expected to be corrected, if not yetcorrected; and5. steps taken or planned to reduce, eliminate, and prevent reoccurrence of thedeviation.

38.0

S/A Minn. R. 7007.0800, subp. 6(A)(2) Semiannual Deviations Report: due 30 days after end of each calendar half-yearstarting 03/24/2005. The first semiannual report submitted by the Permittee shallcover the calendar half-year in which the permit is issued. The first report of eachcalendar year covers January 1 - June 30. The second report of each calendaryear covers July 1 - December 31. If no deviations have occurred, the Permitteeshall submit the report stating no deviations.

39.0

CD Minn. R. 7007.1150 - 7007.1500 Application for Permit Amendment: If a permit amendment is needed, submit anapplication in accordance with the requirements of Minn. R. 7007.1150 throughMinn. R. 7007.1500. Submittal dates vary, depending on the type of amendmentneeded.

40.0

S/A Minn. R. 7007.0400, subp. 2 Application for Permit Reissuance: due 180 days before expiration of ExistingPermit

41.0

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

42.0

S/A Minn. R. 7007.0800, subp. 6(C) Compliance Certification: due 30 days after end of each calendar year starting03/24/2005 (for the previous calendar year). To be submitted on a form approvedby the Commissioner, both to the Commissioner and to the US EPA regional officein Chicago. This report covers all deviations experienced during the calendar year.

43.0

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

44.0

CD Minn. R. 7002.0005 - 7002.0095 Emission Fees: due 60 days after receipt of an MPCA bill.45.0




19 Feb, 2013 11:00Page 5 of 28

Subject Item: GP 001 Fabric Filter Requirements (CAM)








NC/CA



The Permittee shall operate and maintain each fabric filter in GP001 at all timesthat an emission unit in GP002 that exhausts to a fabric filter is in operation. ThePermittee shall document periods of non-operation of the control equipment.

The requirements of this group apply individually to each fabric filter in GP001,including all new, modified, or replaced fabric filters added as allowed by GP001.

1.0

CD Title I Condition: To avoidclassification as major source andmodification under 40 CFRSection 52.21 & Minn. R.7007.3000

If the Permittee replaces any existing fabric filter, adds a new fabric filter, ormodifies an existing fabric filter listed in GP001, such equipment is subject to all ofthe requirements of GP001. Prior to making such a change, the Permittee shallapply for and obtain the appropriate permit amendment, as applicable. A permitamendment is required if the change will be subject to a newly applicablerequirement or requires revisions to the limits or monitoring and recordkeeping inthis permit.

2.0

CD hdr EMISSION LIMITATIONS3.0

LIMIT Title I Condition: To avoidclassification as a major sourceand modification under 40 CFRSection 52.21 and Minn. R.7007.3000

The Permittee shall operate and maintain each fabric filter such that it achieves acontrol efficiency for Total Particulate Matter: greater than or equal to 99 percentcontrol efficiency

4.0


The Permittee shall operate and maintain each fabric filter equipment such that itachieves a control efficiency for PM < 10 micron: greater than or equal to 93percent control efficiency

5.0


The Permittee shall operate and maintain each fabric filter such that it achieves acontrol efficiency for PM < 2.5 micron: greater than or equal to 93 percent controlefficiency

6.0

CD hdr OPERATING REQUIREMENTS7.0

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

8.0

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

Replacing Control Devices: The Permittee shall operate and maintain any new,modified, or replaced fabric filter according to the manufacturer's specifications untila new pressure drop limit is set pursuant to Minn. R. 7017.2025, subp. 3.

9.0

CD hdr See individual CE level (CE 004, 024, 025, 026, 027, 034, or 035) for requiredpressure drop ranges for each fabric filter.

10.0

CD hdr MONITORING AND RECORDKEEPING11.0

CD Title I Condition: To avoidclassification as a major sourceand modification under 40 CFRSection 52.21 and Minn. R.7007.3000; 40 CFR Section 64.3;Minn. R. 7017.0200

Pressure Drop Recordkeeping: The Permittee shall, once every 24 hours, read andrecord the pressure drop across the fabric filter. The Permittee shall record the timeand date of each pressure drop reading, and whether or not the observed pressuredrop was within the range specified in this permit. Recorded values outside therange specified in this permit are considered Deviations as defined by Minn. R.7007.0100, subp. 8a.

The Permittee shall also record and maintain the date of each bag replacement forall fabric filters.

12.0




19 Feb, 2013 11:00Page 6 of 28

CD Minn. R. 7007.0800, subp. 4 and14

Visible Emissions: The Permittee shall check each fabric filter stack for any visibleemissions using Method 22, daily during periods of daylight operation when themonitored pressure drop is outside of the range specified in the permit or duringperiods of inoperation of pressure drop monitoring equipment.

13.0

CD Minn. R. 7007.0800, subps. 2 and14


14.0

CD 40 CFR Section 64.3; Minn. R.7017.0200

Periodic Inspections: At least once per calendar quarter, or more frequently asrequired by the manufacturing specifications, the Permittee shall inspect the controlequipment components. The Permittee shall maintain a written record of theseinspections.

15.0

CD 40 CFR Section 64.7(d); Minn. R.7017.0200

Corrective Actions: The Permittee shall take corrective action as soon as possible ifany 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 needrepair.Corrective actions shall return the pressure drop to within the permitted range,and/or include completion of necessary repairs identified during the inspection, asapplicable. Corrective actions include, but are not limited to, those outlined in the O& M Plan for the fabric filter. The Permittee shall keep a record of the type and dateof any corrective action taken for each filter.

16.0

CD 40 CFR Section 64.7(b); Minn. R.7017.0200

Monitoring Equipment: The Permittee shall install and maintain the necessarymonitoring equipment for measuring and recording pressure drop as required bythis permit. The monitoring equipment must be installed, in use, and properlymaintained when the monitored fabric filter is in operation.

17.0

CD 40 CFR Section 64.3; Minn. R.7017.0200

The Permittee shall calibrate the pressure gauge at least once every 12 monthsand shall maintain a written record of any action resulting from the calibration.

18.0

CD 40 CFR Section 64.7(e); Minn. R.7017.0200

Documentation of Need for Improved Monitoring: If the Permittee fails to achievecompliance with an emission limitation or standard for which the monitoring did notprovide an indication of an excursion or exceedance while providing valid data, orthe results of compliance or performance testing document a need to modify theexisting pressure drop range, the Permittee shall promptly notify the MPCA and, ifnecessary, submit a permit amendment application to address the necessarymonitoring change.

19.0

CD hdr PERFORMANCE TESTS20.0

S/A Minn. R. 7017.2020, subp. 1 Performance Test: due 365 days after Startup of a new, modified, or replacedcontrol device to measure Particulate Matter emissions to demonstrate compliancewith applicable emission limitations.

21.0

S/A Minn. R. 7017.2020, subp. 1 Performance Test: due 365 days after Startup of a new, modified, or replacedcontrol device to measure Opacity to demonstrate compliance with applicableemission limitations.

22.0




19 Feb, 2013 11:00Page 7 of 28

Subject Item: GP 002 Emission Cap Limits









EU 022 Glass Furnace #74-04A

EU 023 Glass Furnace #74-04B

EU 024 Fritting Systems #74-05

EU 025 Impact Mill

EU 026 Agglomerator System #74-04

EU 034 Emergency Backup Generator #55

NC/CA




Total Particulate Matter: less than or equal to 110 tons/year using 12-month RollingSum to be calculated by the 21st day of each month for the previous 12-monthperiod.

All PM-emitting equipment in GP002 and insignificant activities under Minn. R.7007.1300 are subject to this limit.

2.0


PM < 10 micron: less than or equal to 110 tons/year using 12-month Rolling Sum tobe calculated by the 21st day of each month for the previous 12-month period.

All PM < 10 microns-emitting equipment in GP002 and insignificant activities underMinn. R. 7007.1300 are subject to this limit.

3.0


PM < 2.5 micron: less than or equal to 110 tons/year using 12-month Rolling Sumto be calculated by the 21st day of each month for the previous 12-month period.

All PM < 2.5 microns-emitting equipment in GP002 and insignificant activities underMinn. R. 7007.1300 are subject to this limit.

4.0


Sulfur Dioxide: less than or equal to 120 tons/year using 12-month Rolling Sum tobe calculated by the 21st day of each month for the previous 12-month period.

All SO2-emitting equipment in GP002 and insignificant activities under Minn. R.7007.1300 are subject to this limit.

5.0


Nitrogen Oxides: less than or equal to 135 tons/year using 12-month Rolling Sumto be calculated by the 21st day of each month for the previous 12-month period.

All NOx-emitting equipment in GP002 and insignificant activities under Minn. R.7007.1300 are subject to this limit.

6.0


Volatile Organic Compounds: less than or equal to 110 tons/year using 12-monthRolling Sum to be calculated by the 21st day of each month for the previous12-month period as described later in this permit.

All VOC-emitting equipment in GP002 and insignificant activities under Minn. R.7007.1300 are subject to this limit.

7.0



The Permittee shall vent emissions from EU003, EU004, EU005, EU022, EU024,EU025, and EU026 to a control device meeting the permit requirements for GP001at all times EU003, EU004, EU005, EU022, EU024, EU025, and EU026 are inoperation.

9.0




19 Feb, 2013 11:00Page 8 of 28

CD Minn. R. 7007.0800, subp. 2 Equipment Labeling: The Permittee shall permanently affix a unique number toeach control equipment for tracking purposes. The numbers shall correlate the unitto the appropriate CE and GP numbers used in this permit. The number can beaffixed by placard, stencil, or other means. The number shall be maintained so thatit is readable and visible at all times from a safe distance. If equipment is added, itshall be given a new unique number; numbers from replaced or removedequipment shall not be reused.

10.0

CD hdr RECORDKEEPING REQUIREMENTS11.0


Daily Recordkeeping: Once each day of operation, the Permittee shall calculaterecord, and maintain records of the total quantity of all materials processed or usedat the facility which results in emission of PM, PM < 10 microns, PM < 2.5 microns,SO2, NOx, or VOC. For combustion equipment in GP 002 the Permittee shallmaintain daily records of the amount of fuel used. For the glass bubble makingprocess equipment in GP 002 (EUs 003-005, 022-026), the Permittee shallmaintain daily records of the production rate or process throughput. Alternatively,the Permittee may record the hours of operation of PM, PM < 10 microns, PM < 2.5microns, SO2, NOx, and VOC-emitting units. The records must provide adequatedata to calculate emissions of PM, PM < 10 microns, PM < 2.5 microns, SO2, NOx,and VOC.

12.0


Monthly Recordkeeping: By the 21st day of each month, the Permittee shallcalculate and record the PM, PM < 10 microns, PM < 2.5 microns, SO2, NOx, andVOC emissions for the previous month and the 12-month rolling sum emissions forthe previous 12 month period by summing the monthly emissions data for theprevious 12 months.

13.0


Material Content: Material content shall be determined by either a material SafetyData Sheet (MSDS) or a Letter of Certification, provided by the supplier for eachmaterial used, or other agency approved method. If a material content range isgiven, the highest number in the range shall be used in all compliance calculations.When using the MSDS as the basis of calculating Particulate Matter emissions, thePermittee shall assume that Particulate Matter consists entirely of PM < 10microns. Documentation of material content shall be maintained on-site andprovided when requested.

14.0


Calculation Records:

For combustion equipment in GP 001 the Permittee shall calculate emissionsbased on fuel usage and emission factors specific to the type of combustionequipment in GP 002.

For the glass bubble making process equipment in GP 002 (EUs 003-005,022-026), the Permittee shall calculate emissions based on production rate orprocess throughput of each unit and emission factors specific to each unit in GP002.

The Permittee shall maintain an up to date list of all emission factors used in the12-month rolling sum calculations for all equipment in GP 002. For emissionfactors that are based on material content, the Permittee shall comply with theMaterial Content requirement of GP 002.

(continued below)

15.0


Calculation Records continued:

If the Permittee uses uncontrolled emission factors in calculating the emissionsfrom units in GP 002 that are controlled as required by this permit by fabric filtersmeeting the requirements of GP 001, the Permittee may take credit for the controlefficiencies required by GP 001 when calculating PM, PM < 10 micron, and PM <2.5 micron emissions.

If the Permittee uses hours of operation for calculating the emissions from the unitsin GP002, the maximum permitted production rate shall be used to determineemissions for PM, PM < 10 microns, PM < 2.5 microns, SO2, NOx, and VOCs ifactual production rates are not available.

16.0




19 Feb, 2013 11:00Page 9 of 28


Insignificant Activities: The Permittee shall evaluate the emissions from changesmade under Minn. R. 7007.1300 on a monthly basis, and shall include emissionsfrom insignificant activities in the monthly rolling sum. The Permittee shall maintainan up-to-date list of all insignificant activities on site.

All changes made in accordance with Minn. R. 7007.1300 and Minn. R. 7007.1250subp. 1A are subject to the requirements of GP002.

17.0

S/A Minn. R. 7007.0800, subp. 2 Annual Report: due 31 days after end of each year following Permit Issuance. ThePermittee shall submit an annual report by January 31st that describes the changesmade at the facility during the previous calendar year using the latest MPCAapplication forms. The report shall include the emission unit, stack/vent, group, andcontrol equipment data for any new or replaced units or control devices. The reportshall document the PM, PM < 10 micron, PM < 2.5 micron, SO2, NOx and VOC12-month rolling sum calculations for the previous calendar year. The report shallbe submitted with the annual Compliance Certification listed in Table B. As part ofthe Annual Report, the Permittee shall verify and certify that the facility hasmaintained minor source status for New Source Review.

18.0




19 Feb, 2013 11:00Page 10 of 28




SV 003 052 Vent for Fabric Filter for Former 18

NC/CA


CD hdr EMISSION LIMITS1.0

LIMIT Title I Condition: Limit taken toavoid classification as a majorsource or major modificationunder 40 CFR Section 52.21 &Minn. R. 7007.3000; Minn. R.7011.0715, subp. 1(A)

Total Particulate Matter: less than or equal to 0.053 grains/dry standard cubic footof exhaust gas unless required to further reduce emissions to comply with the lessstringent limit of either Minn. R. 7011.0730 or Minn. R. 7011. 0735.

2.0

LIMIT Minn. R. 7011.0715, subp. 1(B) Opacity: less than or equal to 20 percent opacity3.0

CD hdr CONTROL EQUIPMENT REQUIREMENTS (see GP001 and CE004 for additionalcontrol equipment requirements)

4.0

CD Title I Condition: Limit taken toavoid classification as a majorsource or major modificationunder 40 CFR Section 52.21 &Minn. R. 7007.3000; Minn. R.7007.0800, subp. 2 and 14


5.0

CD hdr RECORDKEEPING (see GP002 for recordkeeping requirements)6.0




19 Feb, 2013 11:00Page 11 of 28




SV 004 054 Vent for fabric Filter for Former 20

NC/CA




Total Particulate Matter: less than or equal to 0.05 grains/dry standard cubic foot ofexhaust gas.

2.0


CD hdr CONTROL EQUIPMENT REQUIREMENTS (see GP001 and CE034 for additionalcontrol equipment requirements)

4.0

CD Title I Condition: Limit taken toavoid classification as a majorsource or major modificationunder 40 CFR Section 52.21 &7007.3000; Minn. R. 7007.0800,subp. 2 and 14

The Permittee shall operate and maintain fabric filter a fabric filter that meets therequirements of GP001 at all times EU 004 is in operation.

5.0





19 Feb, 2013 11:00Page 12 of 28




SV 013 Maker 21 Fabric Filter Stack

NC/CA





2.0


CD hdr CONTROL EQUIPMENT REQUIREMENTS (See GP001, CE005 and CE035 foradditional control equipment requirements)

4.0

CD Title I Condition: Limit taken toavoid classification as a majorsource or major modificationunder 40 CFR Section 52.21 &7007.3000; Minn. R. 7007.0800,subp. 2 and 14


5.0





19 Feb, 2013 11:00Page 13 of 28

Subject Item: EU 022 Glass Furnace #74-04A

Associated Items: CE 024 Fabric Filter - High Temperature, i.e., T>250 Degrees F


SV 007 065 Vent for Fabric Filter for Reject Hopper, Remelt Feeder, and Glass Furnace

NC/CA


CD [Stage 1] Minn. R. 7007.0800,subp. 2


1.0


LIMIT Title I Condition: limit to avoidclassification as a major source ormajor modification under 40 CFRSection 52.21 & Minn. R.7007.3000; most stringent, meetslimit set by Minn. R. 7011.0715,subp. 1(A)

Total Particulate Matter: less than or equal to 0.010 grains/dry standard cubic footof exhaust gas. Applicable during electric heating.

3.0

LIMIT Title I Condition: limit to avoidclassification as a major source ormajor modification under 40 CFRSection 52.21 & Minn. R.7007.3000; Minn. R. 7017.2025,subp. 3(C)

PM < 10 micron: less than or equal to 0.010 grains/dry standard cubic foot ofexhaust gas. Applicable during electric heating.

4.0



CD Title I Condition: limit to avoidclassification as a major source ormajor modification under 40 CFRSection 52.21& Minn. R.7007.3000

The Permittee shall not operate EU022 and EU023 simultaneously. EU022represents normal production operation with electric heating.

7.0

LIMIT [Stage 1] Title I Condition: limit toavoid classification as a majorsource or major modificationunder 40 CFR Section 52.21 &Minn. R. 7007.3000; Minn. R.7017.2025, subp. 3(C)


8.0


Production: less than or equal to 3530 lbs/hour using 24-hour Block Average .9.0



10.0


S/A Minn. R. 7017.2020, subp. 1 Performance Test: due 180 days after Computer Dispersion Modeling Resultsdemonstrating compliance with SO2 NAAQS have been approved by the MPCA.


12.0



13.0



14.0




19 Feb, 2013 11:00Page 14 of 28

CD hdr RECORDKEEPING (see GP002 for additional recordkeeping requirements)15.0



16.0

CD Title I Condition: limit to avoidclassification as a major source ormajor modification under 40 CFRSection 52.21 & Minn. R.7007.3000; Minn. R. 7007.0800,subps. 4 and 5


17.0



18.0

CD hdr CONTROL EQUIPMENT REQUIREMENTS (See GP 001 and CE 024 for furthercontrol equipment requirements)

19.0




19 Feb, 2013 11:00Page 15 of 28

Subject Item: EU 023 Glass Furnace #74-04B


SV 008 066 Vent for Bypass for Glass Furnace

NC/CA



LIMIT Minn. R. 7011.0610, subp. 1(A)(1) Total Particulate Matter: less than or equal to 0.30 grains/dry standard cubic foot ofexhaust gas unless required to further reduce emissions to comply with the lessstringent limit of either Minn. R. 7011.0730 or Minn. R. 7011.0735.

2.0

LIMIT Minn. R. 7011.0610, subp. 1(A)(2) Opacity: less than or equal to 20 percent opacity except for one six-minute periodper hour of not more than 60 percent opacity.

3.0

LIMIT Minn. R. 7011.0610, subp. 2(A)(2) Sulfur Dioxide: less than or equal to 2.0 lbs/million Btu heat input . The potential toemit from the unit is 0.0006 lb/MMBtu due to equipment design and allowable fuels.

4.0


CD Title I Condition: limit to avoidclassification as a major source ormajor modification under 40 CFRSection 52.21 & Minn. R.7007.3000

The Permittee shall not operate EU022 and EU023 simultaneously. EU023 bypassis used only during warm-up of this unit with natural gas. No raw materials are fedto this unit during this time.

6.0

LIMIT Title I Condition: limit to avoidclassification as a major source ormajor modification under 40 CFRSection 52.21 & Minn. R.7007.3000

Fuel Usage: less than or equal to 2.88 million cubic feet/year using 12-monthRolling Sum using only natural gas for fuel for startup. Electric heating is used fornormal operation after startup.

7.0

CD Minn. R. 7005.0100, subp. 35a Fuel type: natural gas only.8.0




10.0

CD Minn. R. 7007.0200; Minn. R.7007.0800, subps. 2 and 14


11.0

CD Title I Condition: recordkeeping forlimit to avoid classification as amajor source under 40 CFRSection 52.21 & Minn. R.7007.3000

Daily Recordkeeping. For each day of operation with natural gas, the Permitteeshall record the total quantity of natural gas used.

12.0


Monthly Recordkeeping. By the 21st of the month, the Permittee shall calculate andrecord the following:1)The total natural gas usage in EU 023 for the previous calendar month using thedaily fuel usage records.3) The 12-month rolling sum fuel usage for the previous 12-month period bysumming the monthly fuel usage data for the previous 12 months.

13.0




19 Feb, 2013 11:00Page 16 of 28

Subject Item: EU 024 Fritting Systems #74-05



SV 009 067 Vent for Fabric Filter for Fritting System

NC/CA


CD [Stage 1] Minn. R. 7007.0800,subp. 2


1.0




3.0

LIMIT Title I Condition: limit to avoidclassification as a major source ormajor modification under 40 CFRSection 52.21 & Minn. R.7007.3000; Minn. R. 7017.2025,subp. 3(C)

PM < 10 micron: less than or equal to 0.0140 grains/dry standard cubic foot ofexhaust gas.

4.0





7.0


Production: less than or equal to 3530 lbs/hour using 24-hour Block Average .8.0


The Permittee shall operate and maintain a fabric filter the meets the requirementsof GP001 at all times EU024 is in operation.

9.0




11.0



12.0



13.0





19 Feb, 2013 11:00Page 17 of 28

CD Title I Condition: limit to avoidclassification as a major source ormajor modification under 40 CFRSection 52.21 & Minn. R.7007.3000; Minn. R. 7007.0800,subps. 4 and 5


15.0



16.0

CD hdr CONTROL EQUIPMENT REQUIREMENTS (See GP001 and CE025 for additionalcontrol equipment requirements)

17.0




19 Feb, 2013 11:00Page 18 of 28

Subject Item: EU 025 Impact Mill



SV 010 068 Vent for Fabric Filter for Impact Mill

NC/CA





2.0



4.0



5.0





19 Feb, 2013 11:00Page 19 of 28

Subject Item: EU 026 Agglomerator System #74-04



SV 011 069 Vent for Fabric Filter for Cyclone and Dryer/Agglomerator System

NC/CA



LIMIT Title I Condition: limit to avoidclassification as a major sourceunder 40 CFR Section 52.21 &Minn. R. 7007.3000; moststringent, meets limit set by Minn.R. 7011.0715, subp. 1(A)


2.0


CD Minn. R. 7017.2025, subp. 3(C) Production limit: The emission unit shall be operated at an hourly production rateless than or equal to 5,980 lb/h, calculated as a daily average as specified below,unless a new range is set by permit reopening or permit amendment, based on thevalues recorded during the most recent MPCA approved performance test wherecompliance was demonstrated.

4.0

CD Minn. R. 7007.0800. subp. 4(B) Recordkeeping: The Permittee shall maintain records of the weight of each productcontainer and the hours of production in each 24-hour period. By the 21st day ofeach month, the Permittee shall calculate an average pounds/hour production ratefor each calendar day in the previous month from this data.

5.0


6.0

CD Title I Condition: Limit taken toavoid classification as a majorsource and modification under 40CFR Section 52.21 & Minn. R.7007.3000; Minn. R. 7007.0800,subp. 2 and 14


7.0





19 Feb, 2013 11:00Page 20 of 28

Subject Item: EU 034 Emergency Backup Generator #55


SV 012 073 Vent for Emergency Generator

NC/CA


LIMIT Minn. R. 7011.2300, subp. 1 Opacity: less than or equal to 20 percent opacity1.0

LIMIT Minn. R. 7011.2300, subp. 2 Sulfur Dioxide: less than or equal to 0.5 lbs/million Btu heat input . This limit is metwith fuel oil containing less than or equal to 0.5 % sulfur by weight.

2.0

CD Minn. R. 7005.0100, subp. 35a Fuel type: No. 2 fuel oil only.3.0


Daily Inspections: The Permittee shall check SV012 for any visible emissions onceeach day of operation during daylight hours.

4.0


LIMIT Minn. R. 7007.0800, subps. 4 & 5 Fuel Supplier Certification: Obtain and maintain a fuel supplier certification foreach shipment of No. 2 fuel oil, certifying the Sulfur Content of Fuel: less than orequal to 0.5 percent by weight

6.0

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

7.0

CD Minn. R. 7007.0800, subp. 5 The Permittee shall keep records of fuel type and usage on a monthly basis.8.0



9.0




19 Feb, 2013 11:00Page 21 of 28





NC/CA


CD hdr See GP 001 for baghouse control, monitoring, recordkeeping, reporting, and otherrequirements.

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NC/CA


CD hdr CE005 is being replaced by CE035. Once CE035 is in operation this unit will beretired or removed.

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3.0




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19 Feb, 2013 11:00Page 23 of 28

Subject Item: CE 024 Fabric Filter - High Temperature, i.e., T>250 Degrees F

Associated Items: EU 022 Glass Furnace #74-04A



NC/CA



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19 Feb, 2013 11:00Page 24 of 28


Associated Items: EU 024 Fritting Systems #74-05



NC/CA



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19 Feb, 2013 11:00Page 25 of 28


Associated Items: EU 025 Impact Mill



NC/CA



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19 Feb, 2013 11:00Page 26 of 28


Associated Items: EU 026 Agglomerator System #74-04



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1.0


The Permittee is authorized to install the piece of control equipment described inthis permit as CE 035 and vent EU 005 to CE 035. CE035 is replacing CE005.

The Permittee shall operate, and maintain a fabric filter that meets therequirements of GP001 at all times that any emission unit controlled by the fabricfilter (EU 005) is in operation. The Permittee shall document periods ofnon-operation of the control equipment.

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3.0

S/A Minn. R. 7007.0800, subp. 16(L) Notification of the Actual Date of Initial Startup: due 15 days after Initial Startup ofCE035.

4.0

ATTACHMENT 3

POINTS CALCULATOR

Points Calculator

1) AQ Facility ID No.: 16300002 Total Points 252) Facility Name: 3M Cottage Grove - Specialty Additives3) Small business? y/n? n 4) DQ Numbers (including all rolled) : 4125 5) Date of each Application Received: Sep. 20, 20126) Final Permit No. 16300002-0057) Permit Staff Cindy Schafer

8) "Work completed" in which .xls file (i.e. unit 2b, unit 1a, biofuels)?

TotalApplication Type DQ No. Qty. Points Points DetailsAdministrative Amendment 1 0Minor Amendment 4 0Applicability Request 10 0Moderate Amendment 15 0Major Amendment 4125 1 25 25Individual State Permit (not reissuance) 50 0Individual Part 70 Permit (not reissuance) 75 0

Additional PointsModeling Review 15 0

BACT Review 15 0LAER Review 15 0CAIR/Part 75 CEM analysis 10 0NSPS Review 10 0NESHAP Review 10 0Case-by-case MACT Review 20 0Netting 10 0Limits to remain below threshold 10 0Plantwide Applicability Limit (PAL) 20 0AERA review 15 0Variance request under 7000.7000 35 0Confidentiality request under 7000.1300 2 0EAW reviewPart 4410.4300, subparts 18, item A; and 29 15 0Part 4410.4300, subparts 8, items A & B; 10, items A to C; 16, items A & D; 17, items A to C & E to G; and 18, items B & C

35 0

Part 4410.4300, subparts 4; 5 items A & B; 13; 15; 16, items B & C; and 17 item D

70 0

Add'l Points 0

NOTES:

(DQ DQ#)

ATTACHMENT 4

CAM PLAN

Compliance Assurance Monitoring (CAM) Plan Operation of Fabric Filters for Particulate Control

Total Facility Title V Operating Permit AQ Facility ID No.: 16300002

3M Company

3M Cottage Grove Specialty Additives, MN 3M Cottage Grove Materials Resource Division

February 2013 CAM Applicability Determination: The following criteria were evaluated to determine what sources are subject to CAM (40 CFR Part 64).

• The facility is a major source facility and is required to have Title V permit. • All sources subject to CAM have an emission limitation or standard for the

applicable regulated air pollutant that is NOT exempt. • All sources use an add-on control device to achieve compliance with an emission

limitation or standard. • All sources have potential pre-control device emissions of the applicable

regulated air pollutant that are equal to or greater than major source threshold levels.

• All sources are NOT exempt backup utility power emission units that are municipally owned.

CAM Monitoring Approach The following control equipment (CE) or baghouses are used to control particulate emissions from major sources for particulate emissions: CE 004, CE 005, CE 024, CE 025, CE 026, CE 027, & CE 034. As a part of this monitoring approach, each baghouse is monitored by overall baghouse pressure drop readings. The frequency and limits of the monitoring mechanism for all sources are explained below. General Criteria: Compliance Indicators for Particulate Matter Emission Limitations 1. Pressure drop (inches of water) Indicator Ranges Indicator - The measurement devices used to monitor and measure pressure drop across the baghouses. The facility has set the indicator ranges in inches of water for each baghouse. If the pressure drop is outside of the acceptable ranges listed below, corrective action and preventive maintenance is performed on the baghouse, in accordance with the facility’s on-site baghouse standard operating procedures and baghouse preventative maintenance plans.

Acceptable Baghouse or Control Equipment (CE) Pressure Drop Ranges

CE No. EU Overall Pressure Drop (in wc)

Min Max 004

EU-003 Bubble Maker # 18 1 30

005


035


024

EU-022 Glass Furnace 1 10

025

EU-024 Fritting System 1 10

026

EU-025 Impact Mill 1 10

027

EU-026 Agglomerator 1 10

034


A pressure drop less than the minimum above, when due to replacement of filter bags, is not a deviation and should not be reported on the semi-annual deviation reports. After bag replacement, the pressure drop must return to at least the minimum within 14 working days, or corrective actions must be taken. The one exception is for CE 027, the baghouse for EU 026. For this baghouse, the pressure drop must return to at least the minimum within 21 working days or corrective action must be taken. The justification for this longer time period is that this is a secondary baghouse is receives a lower loading rate than the other baghouses, and therefore it takes a longer time period to build up the pressure drop. Performance Criteria: Specifications for Obtaining Representative Data Representative data Data is collected at any time during the shift that the process is running. By not specifying a time or triggering event data collected is assumed to be random and reasonably represents the operation of the equipment. Verification Procedures Pressure Drop: Once a pressure drop reading is taken and the reading is determined to be out of the range, Maintenance will be directed to verify that the reading is accurate using their electronic test

equipment. Once confirmation that the pressure drop is out of range, the emission unit (EU) served by this baghouse and the baghouse itself are immediately shut down, an incident report is created, and corrective action is initiated. Following the corrective action, The EU and its baghouse are brought back on line and pressure drops are taken to demonstrate that the CE is back in proper operation. In addition, monthly, a qualified employee shall perform a records review. The recorded data is checked for omissions or excursions of allowable ranges. This information is then reviewed by the environmental engineer for any follow-up action. Quality Assurance and Quality Control (QA/QC) Practices Pressure Drop: Routine preventative maintenance is completed quarterly in accordance with the facility’s standard operating procedures and preventative maintenance plans, which includes an inspection of the baghouse systems to ensure proper operation of the equipment and that there are no obstructions in the pressure sensor lines going to the measurement devices. Monitoring Frequency Pressure drop readings are conducted at least once each day of operation by employees operating emission units. A continuous data acquisition and collection system generates records of pressure drop values in report form every two hours each day of operation. Records of the pressure drop readings are kept at the facility. Rationale and Justification Indicators and Monitoring Approach Pressure drop - Indicator Pressure drop was selected as one of the performance indicators because it is indicative of good operation and maintenance of a baghouse. When the baghouse is operating properly, it is pulsing between proper filter cleaning set points. Detecting pressure drop reading above or below the permitted or specified range is an indicator of potential operational problems. Instrument set points are set in between the permitted range to allow for corrective action and maintenance prior to exceeding the permitted ranges. Once repair maintenance is completed and the operation has restarted, a second pressure drop reading is taken to confirm compliance with the set point ranges. References/Information Sources 1. CAM Technical Guidance Document Review Draft (9/12/97)-EPA

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