air emission permit no. 13500008- 001 is … · roseau highway 89 south roseau, roseau county, mn...

TDD (for hearing and speech impaired only): (612)282-5332 Printed on recycled paper containing at least 10% fibers from paper recycled by consumers

AIR EMISSION PERMIT NO. 13500008- 001 IS ISSUED TO

POLARIS IDUSTRIES, INC.- Roseau

Highway 89 South Roseau, Roseau County, MN 56751

The emission units, control equipment and emission stacks at the stationary source authorized in this permit are as described in the following permit application(s): Permit Type Application Date Total Facility Operating Permit 06/15/1995 Minor Permit 09/25/2000 This permit authorizes the Permittee to 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 as defined are in the state air pollution control rules unless the term is explicitly defined in the permit.

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

Issue Date: August 2, 2001

Expiration: August 2, 2006 All Title I Conditions do not expire. Richard J. Sandberg, Manager Major Facilities Section Metro District for Karen A. Studders Commissioner Minnesota Pollution Control Agency

Permit No. 13500008- 001

TABLE OF CONTENTS

Notice to the Permittee Permit Shield Facility Description Table A: Limits and Other Requirements Table B: Submittals Table C: Not used in this Permit Appendices: Appendix A: Operator’s Summary Appendix B: Insignificant Emission Units

Permit No. 13500008- 001

NOTICE TO THE PERMITTEE: Your stationary source may be subject to the requirements of the Minnesota Pollution Control Agency’s (MPCA) solid waste, hazardous waste, and water quality programs. If you wish to obtain information on these programs, including information on obtaining any required permits, please contact the MPCA general information number at: Metro Area (651) 296-6300 Outside Metro Area 1-800-657-3864 TTY (651) 282-5332 The rules governing these programs are contained in Minn. R. chs. 7000-7105. Written questions may be sent to: Minnesota Pollution Control Agency, 520 Lafayette Road North, St. Paul, Minnesota 55155-4194. Questions about this air emission permit or about air quality requirements can also be directed to the telephone numbers and address listed above. PERMIT SHIELD: Subject to the limitations in Minn. R. 7007.1800, compliance with the conditions of this permit shall be deemed compliance with the specific provision of the applicable requirement identified in the permit as the basis of each condition. Subject to the limitations of Minn. R. 7007.1800 and 7017.0100, subp. 2, notwithstanding the conditions of this permit specifying compliance practices for applicable requirements, any person (including the Permittee) may also use other credible evidence to establish compliance or noncompliance with applicable requirements. FACILITY DESCRIPTION: Polaris Industries (Polaris) operates a manufacturing facility in the city Roseau, Roseau County, in Minnesota. Polaris manufactures snowmobiles, all-terrain vehicles, and personal watercraft. The stationary source consists of injection molding, fabrication and machining, spray painting and engine testing.

TABLE A: LIMITS AND OTHER REQUIREMENTS 08/02/01

Polaris Industries Inc - Roseau

13500008 - 001

Facility Name:

Permit Number:

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 itFLEXCAP EMISSION LIMITS hdr

This permit establishes limits on the stationary source to keep it a minor sourceunder New Source Review. The Permittee cannot make any change at the sourcethat would make the source a major source under New Source Review until a majorpermit amendment has been issued. This includes changes that might otherwisequalify as insignificant modifications and minor or moderate amendments.

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

Definition: 12-month rolling average means a monthly calculation where the owneror operator of the stationary source calculates the average emissions of the currentmonth and the previous 11 consecutive months. This must be less than or equal tothe monthly limit.

Minn. R. 7007.0800, subp. 2

Total Particulate Matter: less than or equal to 15 tons/month using 12-monthRolling Average to be calculated by the 15th day of each month. All emission units,except those deemed to be insignificant activities under Minn. R. 7007.1300, andthose added as allowed in this permit shall be included in this calculation. Solidscontents for each material will be determined as described under the MaterialContent requirement.

Title I Condition: Limit to avoid classification as a majorsource or modification under 40 CFR Section 52.21

Particulate Matter < 10 micron: less than or equal to 15 tons/month using 12-monthRolling Average to be calculated by the 15th day of each month. All emission units,except those deemed to be insignificant activities under Minn. R. 7007.1300, andthose added as allowed in this permit shall be included in this calculation. Allparticulate matter shall be conservatively assumed to be particulate matter lessthan 10 microns. Soilds contents for each material will be determined as describedunder the Material Content requirement.


Volatile Organic Compounds: less than or equal to 20 tons/month using 12-monthRolling Average to be calculated by the 15th day of each month. All emission units,except those deemed to be insignificant activities under Minn. R. 7007.1300, andthose added as allowed in this permit shall be included in this calculation. VOCcontents for each VOC-containing material shall be determined as described underthe Material Content requirement.

Title I Condition: Limit to avoid classification as a majorsource or modifications under 40 CFR Section 52.21and Minn. R. 7007.3000

Nitrogen Oxides: less than or equal to 15 tons/month using 12-month RollingAverage to be calculated by the 15th day of each month. All emission units, exceptthose deemed to be insignificant activities under Minn. R. 7007.1300, and thoseadded to the facility as allowed in this permit shall be included in this calculation.


Carbon Monoxide: less than or equal to 20 tons/month using 12-month RollingAverage to be calculated by the 15th day of each month. All emission units, exceptthose deemed to be insignificant activities under Minn. R. 7007.1300, and thoseadded to the facility as allowed in this permit shall be included in this calculation.


OPERATIONAL REQUIREMENTS hdr

Operation and Maintenance Plan: At a minimum, the Operation and Maintenance(O & M) plan shall identify all air pollution control equipment and shall include apreventative maintenance program for that equipment, a description of ( theminimum but not necessarily the only) corrective actions to be taken to restore theequipment to proper operation to meet applicable permit conditions, a description ofthe employee training program for proper operation and maintenance of the controlequipment, and the records kept to demonstrate plan implementation.

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

Monitoring Equipment: Install or make needed repairs to monitoring equipmentwithin 60 days of issuance of the permit if monitoring equipment is not installed andoperational on the date the permit is issued.

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).

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

Operation of Monitoring Equipment: Unless otherwise noted in Tables A, B, and/orC, 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)

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Facility Name:

Permit Number:

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

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

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

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)

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

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 through Minn. R. 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)

Recordkeeping: Maintain records describing any insignificant modifications (asrequired by Minn. R. 7007. 1250, subp. 3) or changes contravening permit terms(as required by Minn. R. 7007.1350 subp. 2), including records of the emissionsresulting from those changes.

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

Record keeping: Retain all records at the stationary source for a period of five (5)years from the date of monitoring, sample, measurement, or report. Records whichmust be retained at this location include all calibration and maintenance records, alloriginal recordings for continuous monitoring instrumentation, and copies of allreports required by the permit. Records must conform to the requirements listed inMinn. R. 7007.0800, subp. 5(A).

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

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Facility Name:

Permit Number:

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

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

Minn. R. 7007.0800, subp. 16

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)

Emission Inventory Report: due 91 days after end of each calendar year followingpermit issuance (April 1). To be submitted on a form approved by theCommissioner.

Minn. R. 7019.3000 through Minn. R. 7019.3010

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

Construction Requirements: The Permittee shall not begin construction of anysingle project or projects that are connected or phased which will cause a totalincrease in actual emissions of greater than 99 tons per year for any criteriapollutant without first getting a permit amendment to authorize the project.Connected and phased have meanings as defined in Minn. R. 4410.2000, subp. 9band 60. The Permittee shall not begin construction of any other project which islisted in Minn. R. 4410.4300 or Minn. R. 4410.4400 without first getting a permitamendment to authorize the project. Such projects may require the completion ofan Environmental Assessment Worksheet or an Environmental Impact Statementprior to the amendment being issued. This is a state only requirement and is notenforceable by EPA Administrator or citizens under the Clean Air Act.

Minn. R. 4410.4300 and Minn. R. 4410.4400

RECORDKEEPING REQUIREMENTS hdr

Emissions Unit Labeling: The Permittee shall permanently affix a unique number toeach emission unit for tracking purposes. The number will correlate the unit to theappropriate EU and GP number used in the permit. The number can be affixed byplacard, stencil, or other means. The number shall be maintained so that it isreadable and visible at all times from a safe distance.

Minn. R. 7007.0800, subp. 2

Equipment Inventory List: The Permittee shall maintain a written list of eachemission unit on site. The list will include: the type of equipment, manufacturer andmodel number (if available), unique ID number, the corresponding controlequipment number used to control the unit (if applicable), and dates of installation,modification, and construction.

The Permittee shall update the list to include any new, modified, or changedequipment prior to making the pre-authorized change. For equipment that is new,modified or changed, the Permittee shall complete an evaluation as detailed belowand shall include a record of the evaluation as part of the equipment list.

Minn. R. 7007.0800, subp. 2

Equipment Inventory List Continued:

Prior to making the change, the Permittee determine and keep a record of thefollowing:

1.) Evaluate whether the permit contains all applicable requirements that wouldapply to the planned change; and2.) Re-evaluate whether the facility will continue to comply with all permit limits.

If the answer to either of these is "no" the Permittee shall apply for and obtain theappropriate permit amendment as required by Minn. R. ch. 7007.

Minn. R. 7007.0800, subp. 2

Pre-authorized Changes: The Permittee shall replace listed emission units withemission units similar to those listed below or may install additional units that aresimilar to those listed below provided emissions are tracked and calculated asspecified in the permit.

Coating operations including but not limited to the following: spray guns, sprayingand coating booths, E-coat tanks, powder paint booths, wash tanks, cleaning ofsurfaces, welding booths, injection molding machines, dip tanks, space heatingunits, ovens and engine test cells.

If a proposed change triggers an applicable requirement that is not contained in thispermit, the change must go through the appropriate procedure in Minn. R. ch.7007.


Daily Recordkeeping: On each day of operation, the Permittee shall record, andmaintain the total quantity of each coating and other VOC and solids containingmaterials used at the facility except fuel usages which will be track on a monthlybasis. This will be based on either written usage logs or records of materialdeliveries to the process or facility.


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Facility Name:

Permit Number:

Monthly Recordkeeping: By the 15th of the month, the Permittee shall calculate andrecord the following:

1) The total usage of each solids and VOC containing material for the previouscalendar month using the daily usage records. This record will also include theVOC and solids contents of each material as determined by the Material Contentrequirement.2) The VOC, PM/PM10, NOx and CO emissions for the previous month using theformulas specified in this permit.3) The 12-month rolling average VOC, PM/PM10, NOx and CO emissions for theprevious 12-month period by summing the monthly VOC, PM/PM10, NOx and COemissions data for the previous 12 months.

Title I Condition: Limit to avoid classification as a majorsource or modification under 40 CFR Section 52.21nad Minn. R. 7007.3000

Monthly Calculation - VOC Emissions. The Permittee shall calculate and record thetotal VOC emissions using the following equations below:Total VOC Emissions:VOCtotal = VOCcoating + VOCengtest + VOCnatgas +VOCpropane

VOC Emissions from Coatings, Paints and SolventsVOC = [(Summation (Ai Vi ))+(Summation(Bj Zj))]x[(100-%control)/100]x0.0005-CYWhere:i =denotes each separate material used for painting or coatingj =denotes each separate material used for cleanupAi =amount of VOC containing materials used for painting/coating as purchased,gal/monthVi =VOC in Ai as applied, lb/galBj =amount of VOC containing materials used for cleaning as purchased, gal/month.Zj =VOC in Bj as applied, lb/gal%control=control efficiency VOC control equipment0.0005=conversion factor ton/lbC=amount of each VOC containing material shipped off-site as hazardous waste,tons/monthY= weight percent of VOC, as a fraction

Minn. R. 7007.0800, subps. 4 and 5

VOC Emissions from Engine Testing Operations:

VOC(engtest)=[(EFgasoline xQgasoline) + (EFdiesel fuel x Q diesel fuel)]x[(100-%control)/100)] x 0.0005

where:EFgasoline =VOC engine testing emission factor (lb/gal), approved by theCommissioner March 24, 1997 per Air Emission Permit No. 13500008-007 basedon source specified. The emission factor was 1.64 lb/gal. If the Permittee wantsto use a different emission factor for compliance, it needs to be approved by theCommissioner before the emission factor can be used.Qgasoline=amount of gasoline used (gal/month)EF diesel fuel = EPA's AP-42 Section 3.3 emission factor until the most recentEPA's AP-42 emission factors are published.Qdiesel fuel = amount of diesel fuel used (gal/month)% control = control efficiency of VOC control equipment0.0005=conversion factor, ton/lb

Minn. R. 7007.0800, subps. 4 and 5

VOC Emissions from Natural Gas/Propane Combustion:

VOC(natgas)=[[EF(natgas)xQ(natgas)] + [EF(propane)xQ(propane)]] x 0.0005Where:EF(natgas)=VOC emission factor, lb/cf or lb/gal shall used EPA's AP42 Section 1.4on natural gas dated July 1998 until the most recent EPA's AP-42 emissionsfactors are published. If the Permittee wants to use a different emission factor forcompliance, it needs to be approved by the Commissioner before the emissionfactor can be used.Q(natgas)=amount of fuel combusted, cf/month or gal/monthEF(propane)=VOC emission factor, lb/gal shall used EPA's AP42 Section 1.5 onliquid petroleum gas combustion dated October 1996 until the most recent EPA'sAP-42 emissions factors are published. If the Permittee wants to use a differentemission factorQ(propane)= amount of fuel combusted, gal/month0.0005=conversion factor, ton/lb

Minn. R. 7007.0800, subps. 4 and 5

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Facility Name:

Permit Number:

Monthly Calculation - PM/PM10 Emissions. The Permittee shall will maintainrecords and calculate the PM/PM10 emissions from the applicable emission unitsusing the following equations:Total PM/PM10 Emissions (PM/PM10 total) =PM/PM10 coating + PM/PM10 engtest + PM/PM10 natgas + PM/PM10 propane

PM/PM10 Emissions from Coatings, Paints and SolventsPM/PM10(coating)=[(1-TE)[(CE)(Summation (AiVi))[100-%control)/100]x0.0005+(1-CE)(Summation(AiVi))x0.0005]Where:CE = Capture efficiency. CE will equal 1.0 if the booth is considered a totalenclosure otherwise CE will equal 0.8TE = transfer efficiency-minimumi = denotes each separate material used for spray painting or spray coatingAi = amount of solid containing materials used for spray painting/coating aspurchased, gal/monthVi=Solids in A, as applied, lb/gal%control=92% control efficiency0.0005=conversion factor, ton/lb

Minn. R. 7007.0800, subps. 4 and 5

PM10 Emissions from Engine Testing Operations:

PM10(engtest)=[EF(engtest)xQ(gasoline)]x0.0005

Where:

EF(engtest)=PM10 engine testing emission factor, lb/gal from EPA's AP42 Section3.3 for Gasoline or Diesel Fired Engines dated October 1996. If the Permitteewants to use a different emission factor for compliance, it needs to be approved bythe Commissioner before the emission factor can be used.Q(gasoline)=amount of gasoline or diesel fuel used (gal/month)0.0005=conversion factor, ton/lb

Minn. R. 7007.0800, subps. 4 and 5

PM/PM10 Emissions from Natural Gas Combustion:

PM/PM10(natgas)=[(EFnatgas xQnatgas)] x 0.0005Where:EF(natgas)= PM/PM10 emission factor, lb/cf from EPA's AP42 Section 1.4 onnatural gas combustion July 1998 until the most recent EPA's AP-42 emissionfactors are published. If the Permittee wants to use a different emission factor forcompliance, it needs to be approved by the Commissioner before the emissionfactor can be used.Q(natgas)=amount of fuel combusted, cf/month0.0005=conversion factor, ton/lb

Minn. R. 7007.0800, subps. 4 and 5

PM/PM10 Emissions from Propane Combustion:

PM/PM10propane = [(EFpropane x Qpropane)]x0.0005whereEF propane = PM/PM10 emission factor, lb/gal from EPA's AP42 on Section 1.5 onliquid petroleum gas combustion dated July 1998 until the most recent EPA'sAP-42 emission factors are published. If the Permittee wants to use a differentemission factor for compliance, it needs to be approved by the Commissionerbefore the emission factor can be used.Qpropane = amount of fuel combusted, gal/month0.0005=conversion factor, ton/lb

Minn. R. 7007.0800, subps. 4 and 5

Monthly Calculation - Carbon Monoxide Emissions. The Permittee shall maintainrecords and calculate CO emissions using the following equations:

COtotal = COengtest + COnatgas + COpropane

CO(engtest)=[[(EFgasoline xQgasoline) + (EFdiesel fuel x Q dieselfuel)]x[(100-%control)/100]] x 0.0005

where:EFgasoline = CO engine testing emission factor (lb/gal), approved by theCommissioner March 24, 1997 per Air Emission Permit No. 13500008-007 basedon source specified. The emission factor was 3.5 lb/gal. If the Permittee wants touse a different emission factor for compliance, it needs to be approved by theCommissioner before the emission factor can be used.Qgasoline = amount of gasoline used (gal/month)EF diesel fuel = EPA's AP-42 Section 3.3 emission factor until the most recentEPA's AP-42 emission factors are published.Qdiesel fuel = amount of diesel fuel used (gal/month)%control = control efficiency CO control equipment0.0005=conversion factor, ton/lb

Minn. R. 7007.0800, subps. 4 and 5

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Facility Name:

Permit Number:

Carbon Monoxide Emissions from Natural Gas Combustion:

CO(natgas)=[(EFnatgas xQnatgas)] x 0.0005Where:EF(natgas)= CO emission factor, lb/cf from EPA's AP42 Section 1.4 on natural gascombustion July 1998 until the most recent EPA's AP-42 emission factors arepublished. If the Permittee wants to use a different emission factor for compliance,it needs to be approved by the Commissioner before the emission factor can beused.Q(natgas)=amount of fuel combusted, cf/month0.0005=conversion factor, ton/lb

Minn. R. 7007.0800, subps. 4 and 5

Carbon Monoxide Emissions from Propane Combustion:

CO(propane) =[(EFpropane x Qpropane)]x0.0005whereEF propane = CO emission factor, lb/gal from EPA's AP42 on Section 1.5 on liquidpetroleum gas combustion dated July 1998 until the most recent EPA's AP-42emission factors are published. If the Permittee wants to use a different emissionfactor for compliance, it needs to be approved by the Commissioner before theemission factor can be used.Qpropane = amount of fuel combusted, gal/month0.0005=conversion factor, ton/lb

Minn. R. 7007.0800, subps. 4 and 5

Monthly Calculation - Nitrogen Oxide Emissions. The Permittee shall maintainrecords and calculate Nitrogen Oxide emissions using the following equations:NOxtotal = NOx engtest + NOx natgas + NOx propane

Nitrogen Oxide Emissions from Engine Testing Operations

NOx (engtest)=[(EFgasoline xQgasoline) + (EFdiesel fuel x Q diesel fuel) x 0.0005where:EFgasoline =NOxengine testing emission factor (lb/gal),EPA's AP-42 Section 3.3dated October 1996 until the most recent EPA's AP-42 emission factors arepublished. If the Permittee wants to use a different emission factor for compliance,it needs to be approved by the Commissioner before the emission factor can beused.Qgasoline = amount of gasoline used (gal/month)EF diesel fuel = EPA's AP-42 Section 3.3 emission factors until the most recentEPA's AP-42 emission factors are published.Qdiesel fuel = amount of diesel fuel used (gal/month)0.0005 = conversion factor, ton/lb

Minn. R. 7007.0800, subps. 4 and 5

Nitrogen Oxide Emissions from Natural Gas Combustion:

Nitrogen Oxide(natgas)=[EF(natgas)xQ(natgas)]x0.0005

Where:EF(natgas)=NOx emission factor, lb/cf from EPA's AP42 Section 1.4 on natural gascombustion July 1998 until the most recent EPA's AP-42 emission factors arepublished. If the Permittee wants to use a different emission factor for compliance,it needs to be approved by the Commissioner before the emission factor can beused.Q(natgas)=amount of fuel combusted, cf/month0.0005=conversion factor, ton/lb

Minn. R. 7007.0800, subps. 4 and 5

Nitrogen Oxide Emissions from Propane Combustion:

NOx propane = [(EFpropane x Qpropane)]x0.0005whereEF propane = NOx emission factor, lb/gal from EPA's AP42 on Section 1.5 on liquidpetroleum gas combustion dated July 1998 until the most recent EPA's AP-42emission factors are published. If the Permittee wants to use a different emissionfactor for compliance, it needs to be approved by the Commissioner before theemission factor can be used.Qpropane = amount of fuel combusted, gal/month0.0005=conversion factor, ton/lb

Minn. R. 7007.0800, subps. 4 and 5

Material Content: VOC and Solids (PM and PM10 ) contents in all materials will bedetermined by the Material Safety Data Sheet (MSDS) or Certificate of Analysis(COA) provided by the supplier for each material used. If a material content rangeis given on the MSDS or COA, the highest number in the range will be used in allpermit calculations for GP001. When using the MSDS or COA as the basis ofcalculating particulate emissions, the conservative assumption is made that PMconsists entirely of PM less than 10 microns. Other alternative methods approvedby the MPCA may be used to determine the VOC and Solids contents. If an EPA ofASTM reference method is used for material content determination, the dataobtained will supersede the MSDS or COA.

Minn. R. 7007.0800, subps. 4 and 5

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Facility Name:

Permit Number:

Fuel Usage:The Permittee shall be limited to combusting only natural gas, propane,gasoline or diesel fuel in its combustion units. The Permittee may combust otherfuels by submitting a request to the MPCA for approval 60 days prior to combustingan alternative fuel. The submittal will contain a description of the fuel, in which unitsthe Permittee will be combusting the proposed fuel and a sample calculation of theresulting emissions from combusting the proposed fuel. The Permittee shall alsoproceed with the fuel change in accordance with permit amendment rules Minn. R.7007.1200- 7007.1500.

Minn. R. 7007.0800, subps. 4 and 5

Waste Credit: If the Permittee elects to obtain credit for VOC shipped in wastematerials, the Permittee will either use item 1 or 2 to determine the VOC content foreach credited shipment.

1)The Permittee shall analyze a composite sample of each waste stream todetermine the weight content of VOC, excluding water.2) The Permittee shall use supplier data (e.g. MSDS) for raw materials to determinethe VOC content of each waste stream using the same content data used todetermine the content of raw materials. If the waste contains several materials, thecontent of mixed waste will be the lowest VOC content of any of the materials.

Minn. R. 7007.0800, subps. 4 and 5

Capture Efficiency: The capture efficiency used to calculate PM/PM10 emissionswill be determined based on the procedures specified in Minn. R. 7011.0070, subp.1.

Minn. R. 7007.0800, subps. 4 and 5

National Emission Standard for Hazardous Air Pollutants (NESHAP)REQUIREMENTS

hdr

The Permitteee shall not "construct or reconstruct" a major source of hazardous airpollutants as defined in 40 CFR pt. 63, subp. B without first obtaining apreconstruction permit.

40 CFR Section 63.5 (b)(3)

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Facility Name:

Permit Number:

Subject Item: GP 001 Coating Booths

Associated Items: CE 001 Mat or Panel Filter

CE 002 Mat or Panel Filter





EU 001 Primer Booth (Plastic Painting)

EU 002 Base Coat Booth (Plastic Painting)

EU 003 Top Coat Booth (Plastic Painting)

EU 004 Clear Coat Booth (Plastic Painting)

EU 030 Plastic Paint (Primer Booth)

EU 034 Camouflage Primer Booth

What to do Why to do itTotal Particulate Matter: less than or equal to 0.07 grains/dry standard cubic foot ofexhaust gas, unless required to further reduce emissions to comply with the lessstrigent limit of either Minn. R 7011.0730 or Minn. R. 7011.0735. This limit appliesseparately to each emission unit listed in GP 001.

Minn. R. 7011.0715, subp. 1(A); Minn. R. 7011.0730;Minn. R. 7011.0735

Opacity: less than or equal to 20 percent opacity . This limit applies separately toeach unit listed in GP 001.

Minn. R. 7011.0715, subp. 1(B)

A-8



13500008 - 001

Facility Name:

Permit Number:

Subject Item: GP 002 Engine Test Stations

Associated Items: CE 007 Other(Oxidizer)

EU 011 R & D Engine Test Station





EU 020 R & D Engine Test Stations




EU 026 2 R & D Engine Test Stations

EU 027 5-R&D Engine Test Stations


What to do Why to do itA. POLLUTANT LIMITS hdr

Total Particulate Matter: less than or equal to 0.1 grains/dry standard cubic foot ofexhaust gas, unless required to further reduce emission to comply with the lessstrigent limit of either Minn. R. 7011.0730 or Minn. R. 7011.0735. This limit appliesseparately to each emission unit listed in GP 002.

Minn. R. 7011.0715, subp. 1 (A); Minn. R. 7011.0730;Minn. R. 7011.0735

Sulfur Dioxide: less than or equal to 0.5 lbs/million Btu heat input using 3-hourRolling Average (For Engine Testing)

Minn. R. 7011.2300, subp. 2

Opacity: less than or equal to 20 percent opacity once operating temperature havebeen attained. (Visible air contaminants) (For Engine Testing)

Minn. R. 7011.2300, subp. 1

B. OTHER LIMITS AND REQUIREMENTS hdr

Fuel Restriction: Authorized to burn gasoline and diesel fuel only. Minn. R. 7007.0800, subp. 2

Recordkeeping: Record and maintain records of each fuel combusted in the uniton a monthly basis by the 15th of each month after the completion of the month.

Minn. R. 7007.0800, subps. 4 and 5

Visible Emissions: The Permittee shall check the stacks associated with theengine testing for visible emissions using Method 22, if the engine is tested formore than a month.

Minn. R. 7007.0800, subps. 4

Recordkeeping of Visible Emissions (VE): The Permittee shall keep records on thetime and date of VE inspection, whether or not any VEs were observed, and ifcorrective action was needed.

Minn. R. 7007.0800, subps. 5

A-9



13500008 - 001

Facility Name:

Permit Number:

Subject Item: GP 003 Production Engine Testing Stations

Associated Items: EU 016 Production Engine Test Stations

EU 017 Production Engine Test Stations



EU 029 Vertification Area Engine Exhaust

EU 031 Pilot Area Engine Exhaust

EU 032 Rolling Road Engine Exhaust

EU 033 QA/QC Engine Exhaust

What to do Why to do itTotal Particulate Matter: less than or equal to 0.07 grains/dry standard cubic foot ofexhaust gas, unless required to further reduce emissions to comply with the lessstrigent limit of either Minn. R 7011.0730 or Minn. R. 7011.0735. This limit appliesseparately to each emission unit listed in GP 003.

Minn. R. 7011.0715, subp. 1(A)

Opacity: less than or equal to 20 percent opacity . This limit applies separately toeach unit listed in GP 003.

Minn. R. 7011.0715, subp. 1(B)

A-10



13500008 - 001

Facility Name:

Permit Number:

Subject Item: GP 004 Ovens

Associated Items: EU 007 E-Coat Oven

EU 008 Powder Cure Oven (Powder Painting)

What to do Why to do itTotal Particulate Matter: less than or equal to 0.10 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. This limitapplies separately to each emission unit listed in GP 004.

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. This limit applies separately to eachunit listed in GP 004.

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

A-11



13500008 - 001

Facility Name:

Permit Number:

Subject Item: GP 005 Filter Requirements

Associated Items: CE 001 Mat or Panel Filter






What to do Why to do itTotal Particulate Matter: greater than or equal to 73.6 percent control efficiency(capture efficiency of the booth x collection efficiency of the filter)

Title I Condition: Limit taken to avoid classification as amajor source and modification under 40 CFR Section52.21 and 40 CFR 7007.3000

Particulate Matter < 10 micron: greater than or equal to 73.6 percent controlefficiency (capture efficiency of the booth x collection efficiency of the filter)


Operation of Pollution Control Equipment: The Permittee shall operate andmaintain the panel filters any time the process equipment controlled by the panelfilters is (are) in operation.


Operation and Maintenance of Filters: The Permittee shall operate and maintaineach filter in accordance with the Operation and Maintenance (O & M) Plan. ThePermittee shall keep copies of the O & M Plan available onsite for use by staff andMPCA staff.

Minn. R. 7007.0800, subp. 2 and 14

MONITORING AND RECORDKEEPING hdr

Daily Inspections: Once each operating day, the Permittee shall visually inspect thecondition of each panel filter with respect to alignment, saturation, tears, holes andany other condition that may affect the filter's performance. The Permittee shallmaintain a daily written record of filter inspections.

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

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.

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

Corrective Actions: If the filters or any of their components are found during theinspections to need repair, the Permittee shall take corrective action as soon aspossible. Corrective actions shall include completion of necessary repairs identifiedduring the inspection, as applicable. Corrective actions include, but are not limitedto, those outlined in the O & M Plan for the filter. The Permittee shall keep a recordof the type and date of any corrective action taken for each filter.

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

Hood Certification and Evaluation: The control device hood (booth) must conform tothe requirements listed in Minn. R. 7011.0070, subp. 1, and the Permittee shallcertify this as specified in Minn. R. 7011.0070, subp. 3. The Permittee shallmaintain a copy of the certification on site, as well as an annual record of fanrotation speed, fan power draw, or face velocity of each hood (booth), or othercomparable air flow indication method.

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

A-12



13500008 - 001

Facility Name:

Permit Number:

Subject Item: CE 007 Other(Oxidizer)

Associated Items: GP 002 Engine Test Stations

What to do Why to do itA. ALTERNATIVE OPERATING SCENARIO hdr

This Permit authorizes the Permittee to install and operate a thermal or catalyticoxidizer(s) which is not a requirement to meet any applicable emission limits at thistime of permit issuance.

Minn. R. 7007.0800, subp. 11

The operation of this piece of control equipment is not necessary in order for theprocess to meet applicable emissions limits. However, the Permittee wishes totake credit for its operation for the purposes of reporting actual emissions foremission inventory or may wish to take credit for emission reductions indetermining compliance with limits contained in the permit. Therefore, in order forthe VOC or CO emissions to be considered controlled for the purposes ofemissions inventory or emissions reductions in determining compliance with limitscontained in the permit, the oxidizer (thermal or catalytic oxidizer) shall comply withthe requirements of this permit during the time credit for control is taken.

Minn. Stat. 116.07, subd. 4a; Equipment used underMinn. R. 7019.3020 (F) and Minn. R. 7019.3050

B. MONITORING AND RECORDKEEPING hdr

The Permittee shall operate and maintain the control equipment such that itachieves an overall control efficiency for Carbon Monoxide and Volatile OrganicCompounds: greater than or equal to 90 percent control efficiency

Title I Condition: Limit taken to avoid classification as amajor source and modification under 40 CFR Section52.21; Minn. R. 7002.0800, subp. 2 and 14

Temperature: The temperature (combustion chamber for the thermal oxidizer andthe inlet and outlet for the catalytic oxidizer) shall be greater than or equal to thetemperature recommended by the vendor. After the Oxidizer has been in operationfor one week and before the end of the first month, the Permittee shall observe andrecord the normal operating temperature in the Operation and Maintenance Planuntil a new minimum is set puruant to Minn. R. 7017.2025, subp. 3, based on theaverage temperature recorded during the most recent MPCA approvedperformance test where complaince for VOC and CO emissions was demonstrated.If the three hour rolling average temperature drops below the minimum temperaturelimit, the VOC and CO used during that time be considered uncontrolled until theaverage minimum temperature limit is once again achieved for determiningcompliance with VOC and CO emission limits.


CONTINUED

If the three hour rolling average temperature drops below the minimum temperaturelimit, the VOC and CO used during that time be considered uncontrolled until theaverage minimum temperature limit is once again achieved for determiningcompliance with VOC and CO emission limits. Temperature excursions shall notbe considered a deviation unless total emissions of VOCs or CO from thr facility,calculated as specified, exceed their respective limits.


The Permittee shall operate and maintain the oxidizer any time operation isnecessary to comply with VOC and CO permit emission limits.

Minn. R. 7007.0800, subps. 2 and 14

The Permittee shall maintain a continuous hard copy readout or computer disk fileof the temperature readings and calculated three hour rolling averagetemperatures.

Minn. R. 7007.0800, subps. 4 and 5

Daily Monitoring: The Permittee shall physically check the temperature recordingdevice at least once each operating day to verify that it is working and recordingproperly, if in operation.

Minn. R. 7007.0800, subps. 4 and 5

Monitoring Equipment: The Permittee shall install and maintain thermocouples toconduct temperature monitoring required by this permit. The monitoring equipmentmust be installed, in use, and properly maintained whenever operation of themonitored control equipment is required.

Minn. R. 7007.0800, subp. 4

The Permittee shall maintain and operate a thermocouple monitoring device thatcontinuously indicates and records the temperature of the oxidizer. The monitoringdevice shall have a margin of error less than the greater of +/- 0.75 percent of thetemperature being measured or +/- 2.5 degrees Celsius. The recording deviceshall also calculate the three-hour rolling average temperature.

Minn. R. 7007.0800, subps. 4 and 5

Quarterly Inspections: At least once per calendar quarter, the Permittee shallinspect the control equipment internal and external system components, includingbut not limited to the refractory, heat exchanger, and electrical systems. ThePermittee shall maintain a written record of the inspection and any correctiveactions taken resulting from the inspection.

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

Annual Calibration: The Permittee shall calibrate the temperature monitor at leastannually and shall maintain a written record of the calibration and any actionresulting from the calibration.

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

A-13



13500008 - 001

Facility Name:

Permit Number:

Corrective Actions: If the temperature is below the minimum specified by this permitor any of its components are found during the inspections to need repair, thePermittee shall take corrective action as soon as possible. Corrective actions shallreturn the temperature to at least the permitted minimum and/or include completionof necessary repairs identified during the inspection, as applicable. Correctiveactions include, but are not limited to, those outlined in the O & M Plan for theoxidizer. The Permittee shall keep a record of the type and date of any correctiveaction taken.

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

The Permittee shall operate and maintain the oxidizer 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

Hood Certification and Evaluation: The control device hood must conform to therequirements listed in Minn. R. 7011.0070, subp. 1, and the Permittee shall certifythis as specified in Minn. R. 7011.0070, subp. 3. The Permittee shall maintain acopy of the certification on site, as well as an annual record of fan rotation speed,fan power draw, or face velocity of each hood, or other comparable air flowindication method.

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

Monthly Monitoring: If applicable, at least once each month during normaloperation, the Permittee shall record the temperature rise across the catalyst (outlettemp. - inlet temp.) while the process is running. If it is determined that the catalystreactivity has been impaired, by comparison of the observed temperature rise tothe past temperature rise records, the Permittee shall follow the corrective actionsin the Operation and Maintenance Plan. The Permittee shall maintain writtenrecords of the monitoring and any corrective actions taken.

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

Catalyst Reactivity: If applicable, at least once each 24 month period followingpermit issuance, the Permittee shall send a sample of the catalyst to a laboratory totest the catalyst's destruction efficiency. If the test results show a destructionefficiency of less that 90%, the Permittee shall follow the corrective actionscontained in the Operation and Maintenance Plan.

Title I Condition: Limit taken to avoid classification asa major source and modification under 40 CFR Section52.21; Minn. r. 7007.0800, subps. 4, 5, and 14

The Permittee will choose the applicable requirement: For periods when thethermal or catalytic oxidizer is operated above the minimum combustion chambertemperature or the minimum inlet temperature, the Permittee shall use either one ofthe following when completing calculations as required elsewhere in this permit:a. The overall control efficiency limit specified in this permit for this equipment 90%;orb. The overall control efficiency determined during the most recent MPCA approvedperformance test. If the tested efficiency is less than the efficiency limit in thispermit, the Permittee must use the tested value in all calculations until theefficiency is demonstrated to be above the permit limit through a new test.

Title I Condition: Limit taken to avoid classification as amajor source and modification under 40 CFR Section52.21; Minn. R. 7007.0800, subps. 4 and 5

C. PERFORMANCE TESTING REQUIREMENTS hdr

Initial Performance Test: due 180 days after Startup of the oxidizer(s) to measuredestruction efficiency for VOC and CO.

Minn. R. 7017.2020, subp.

Performance Test Notification: due 30 days before each performance test Minn. R. 7017.2030, subp. 1

Performance Test Plan: due 30 days before each performance test. Minn. R. 7017.2030, subp. 2 & 3

Performance Test Pretest Meeting: due 7 days before each performance test. Minn. R. 7017.2030, subp. 4

Performance Test Report: due 45 days after each performance test Minn. R. 7017.2035, subp. 1 & 2

Performance Test Report - Microfiche Copy: due 105 days after each performancetest.

Minn. R. 7017.2035, subp. 2

Testing Frequency Plan: due 60 days after Initial Performance Test for destructionefficiency for VOC and CO emissions. The plan shall specify a testing frequencybased on the test data and MPCA guidance. Future performance tests based onone-year (12 month), 36 month, and 60 month intervals, or as applicable, shall berequired upon written approval of the MPCA.

Minn. R. 7017.2020, subp. 1

A-14

TABLE B: SUBMITTALSFacility Name: Polaris Industries Inc - Roseau

Permit Number: 13500008 - 001

08/02/01

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.

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 any application for a permit or permit amendment to:

Permit Technical AdvisorPermit SectionAir Quality DivisionMinnesota Pollution Control Agency520 Lafayette Road NorthSt. Paul, Minnesota 55155-4194

Also, where required by an applicable rule or permit condition, send to the Permit Technical Advisor 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:

SupervisorCompliance Determination UnitAir Quality DivisionMinnesota Pollution Control Agency520 Lafayette Road NorthSt. Paul, Minnesota 55155-4194

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

Mr. George CzerniakAir and Radiation BranchEPA Region V77 West Jackson BoulevardChicago, Illinois 60604

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

U.S. Environmental Protection AgencyClean Air Markets Division1200 Pennsylvania Avenue NW (6204N)Washington, D.C. 20460

B-1

TABLE B: ONE TIME SUBMITTALS OR NOTIFICATIONSFacility Name: Polaris Industries Inc - Roseau


08/02/01

What to send When to send Portion of Facility AffectedApplication for Permit Reissuance due 180 days before expiration of Existing

PermitTotal Facility

Computer Dispersion Modeling Results due 1,462 days after Permit Issuance forPM10 and NOx. This data will includeinformation specified in MPCA modelingguidance for modeling information requests.This is a state-only requirement and is notenforceable by the EPA Administrator orcitizens under the Clean Air Act.

Total Facility

Notification due 7 days after Initial Startup of the thermalor catalytic oxidizer(s).

CE007

B-2

TABLE B: RECURRENT SUBMITTALSFacility Name: Polaris Industries Inc - Roseau


08/02/01

What to send When to send Portion of Facility AffectedSemiannual Deviations Report due 30 days after end of each calendar

half-year following Permit Issuance. 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 occured, the Permittee shall submit thereport stating no deviations.

Total Facility

Annual Report due 30 days after end of each calendar yearfollowing Permit Issuance (January 30th).The Permittee shall submit this report thatdescribes the changes made at the facilityduring the previous calendar year using thelatest MPCA application forms (GI-04 nadGI-05). The report will document anyequipment that was added, replaced, modifiedor changed. The report will be submitted withthe annual compliance Certification. As partof the Report, the Permittee shall verify andcertify that the facility has maintained minorsource status for New Source Review.

Total Facility

Compliance Certification due 31 days after end of each calendar yearfollowing Permit Issuance (for the previouscalendar year). To be submitted on a formapproved by the Commissioner , both to theCommissioner, and to the U.S. EPA regionaloffice in Chicago. This report covers alldeviations experienced during the calendaryear. The EPA copy shall be sent to: Mr.George Czerniak, Chief, Air Enforcement andCompliance Assurance Branch, Air andRadiation Division, EPA Region V, 77 WestJackson Boulevard, Chicago, Illinois 60604.

Total Facility

B-3

APPENDIX B Facility Name: Polaris Industries Inc - Roseau Permit Number: 13500008-001

Insignificant Activities and Applicable Requirements

Minn. R. 7007.1300,

subpart Rule Description of the Activity Likely Applicable Requirement

subpart 3(A) Fuel use: space heaters fueled by, kerosene, natural gas, or propane. • 4 Roof Top Units • 11 Space Heaters • 3 Duct Heaters • 2 Radiator Heaters

Minn. R. 7011.0515

subpart 3(H)(4) Brazing, soldering or welding equipment: • Miscellaneous welding machines Minn. R. 7011.0150

subpart 3(H) Cleaning operations: • Dip wash systems –pre-weld • Stage #1 Washer (plastic painting) • Stage #2 Washer (plastic painting) • Stage #1 Washer (metal painting) • Stage # 3 Washer (metal painting)

Minn. R. 7011.0150

subpart 3(I) Individual emission units at a stationary source each of which have a potential to emit the following pollutants in amount less than:

• Natural gas fired power washer • Several natural gas/propane fired air makeup units with

heat inputs less than 2.27 MMBTU per hour. • Laboratory Area

Minn. R. 7011.0515

subpart 3(J) Fugitive dust emissions from unpaved entrance roads and parking lots:

• Fugitive emissions from entrance and parking lot.

Minn. R. 7011.0150

subpart 3(K) Infrequent use of spray paint equipment........and other supporting equipment:

• One spray booth located in the maintenance area used to spray paint equipment or building components.

Minn. R. 7011.0715

subpart 4

Insignificant Activities Required to be listed in a part 70 application: • Booth # 1 Powder Painting • Booth # 2 Powder Painting • 1.5 MMBTU/hr Paint Burn-off Oven (Natural

gas/propane) • Rework Booth (Sanding Machine)

Minn. R. 7011.0715 Minn. R. 7011.0715 Minn. R. 7011.0515

Minn. R. 7007.1300,

subpart Rule Description of the Activity Likely Applicable Requirement

Subpart 4

• Rework Booth • Laminating Object Manufacturing • Injection Molding Machines • Miscellaneous Natural Gas/Propane fired Air Makeup

Units • Fabrication Shop

Minn. R. 7011.0715 Minn. R. 7011.0715 Minn. R. 7011.0715 Minn. R. 7011.0715 Minn. R. 7011.0515 Minn. R. 7011.0150

Permit Action Number: 001 Date: 2/17/2004 Page 1

TECHNICAL SUPPORT DOCUMENT For

DRAFT AIR EMISSION PERMIT NO. 13500008-001 This technical support document is for all the interested parties of the draft permit. The purpose of this document is to set forth the legal and factual basis for the draft permit conditions, including references to the applicable statutory or regulatory provisions. 1. General Information 1.1. Applicant and Stationary Source Location:

Owner and Operator Address and Phone Number (list both if different)

Facility Address (SIC Code: 3799)

Polaris Industries, Inc Route 1, Box 35-A Roseau, Minnesota 56751-9779 Phone Number: (218) 463-4489

Polaris Industries, Inc Highway 89 South, Roseau, Minnesota 56751-9779 Roseau County

1.2. Description of the Permit Action This Part 70 Permit is an Air Emission Operating Permit required by Title V of the federal Clean Air Act Amendments of 1990, codified in 40 CFR pt. 70. “Part 70” is a section in the Code of Federal Regulations for the Protection of the Environment. Previously, the facility operated under a state only Total Facility Operating Air Emission Permit issued on November 12, 1992. Since the expiration of the Total Facility Operating permit on November 12, 1997, Polaris Industries, Inc. (Polaris) has continued to operate its facility under the conditions of the expired permit as is required by Minn. R. 7001.0160, Continuation of Expired Permit. Polaris’ Part 70 Operating Permit will be a consolidation of all existing conditions from the expired Total Facility Operating Permit, amendments, installation and operational permits. The permit will incorporate more detailed specifications of the emission units, pollution control equipment and all new rules and existing regulations that will apply to Polaris at the time of the issuance of this permit. The permit will also meet all requirements of Minn. R. 7007.0800, that specifies requirements for the content of Part 70 Permits. The permit application for the issuance of Polaris’ Part 70 Total Facility Operating Permit was received on June 15, 1995, in accordance with its deadline. Polaris did not submit any information that was claimed to be confidential verbally or in written correspondence.


1.3. Stationary Source Description Polaris Industries (Polaris) operates a manufacturing facility in the city of Roseau, Roseau County, in Minnesota. Polaris manufactures snowmobiles, all-terrain vehicles, and personal watercraft. The stationary source consists of fabrication and machining, injection molding, spray painting and engine testing. The main emissions for the stationary source are Volatile Organic Compounds (VOC), Hazardous Air Pollutants (HAP), Particulate Matter (PM), Particulate Matter less than 10 microns (PM10) and Carbon Monoxide (CO). The permit limits VOC and CO emissions to 20 tons per month based on a 12-month rolling average; and PM, PM10 and NOx to15 tons per month based on 12-month rolling average. By limiting VOC emissions, it inherently limits volatile HAP emission to 20 tons per month as well. The permit also contains requirements to use filters to control PM and PM10 emissions from the spray booths. The permit limits the emissions of the facility such that the facility is classified as non-major under federal New Source Review regulations. Polaris also proposed an alternative operating scenario which allows them to install and operate an oxidizer. The permit also allows operating flexibility by authorizing the installation, replacement, and removal of equipment without a permit amendment, so long as the source remains in compliance with its permit. The Permittee will not “construct or reconstruct a major source of HAPS” as defined in 40 CFR pt. 63, subp. B, without first obtaining a preconstruction permit.

1.4. Description of all amendments issued since the issuance of the last total facility permit and to be included in the Part 70 Permit.

Permit Number and Issuance Date

Action Authorized

AQD 2469-92-OT-1 November 11,1992

Total Facility Permit

Amendment 1 to AQD 2469-92-OT-1 January 26, 1994

Operational Permit to increase VOC emissions from 186 tons per year to 249 tons per year

13500008-006 October 12, 1995

Installation and Operation Permit for Engine Testing Stations

13500008-008 Amendment 2 to AQD 2469-92-OT-1 April 13, 1998

Installation and Operation Permit for a new injection molding facility


1.5. Facility Emissions:

Table 1. Total Facility Potential to Emit Summary (in tons per year):

PM tpy

PM10tpy

SO2 tpy

NOx tpy

CO tpy

VOC tpy

Pb tpy

Combined Total HAPs

tpy Total Facility Limited Potential Emissions*

180.0 180.0 9.62 180.0 240.0 240.0 0.0 240.0

Total Facility Actual Emissions*

4.36 4.36 0.32 10.91 184.42 192.79 0.0 Not Available

*These are the limited potential emissions from column 3 in GI-07 from Delta. They differ from those in the permit application sent by Polaris in that they have been verified and corrected as need be by MPCA staff. These are the potential emissions that would appear in a public notice. .

Table 2. Total Facility (TF) and Permit Classification

Classification (put x in appropriate box)

Major/Affected Source

*Synthetic Minor *Minor

Prevention of Significant Deterioration (PSD)

PM, PM10, NOx,

CO, VOC

SO2

Non Attainment Area Review (NAAR)

N/A

N/A

N/A

Part 70 Permit Program

PM10, NOx, CO, VOC,

HAP

SO2

* Refers to potential emissions that are less than those specified as major by 40 CFR § 52.21, 40 CFR pt. 51 Appendix S, and 40 CFR pt. 70. 2. Regulatory and/or Statutory Basis Polaris has taken limits to avoid major source classification for New Source Review (40 CFR § 52.21). However, Polaris is a major source under the federal operation permit program (40 CFR pt. 70) and the National Emission Standards for Hazardous Air Pollutants (NESHAPs, 40 CFR pt. 63). Polaris may be subject to The NESHAPs for Engine Test Facilities and Plastic Parts (surface coating).


Regulatory Overview of Facility

* Level Applicable Regulations ** Comments:

Total Facility 40 CFR § 52.21; Minn. R. 7011.0715

Title I Conditions: Prevention of Significant Deterioration (PSD) and Standards of Performance for Pre 1969 Industrial Equipment. Limits taken to avoid major source classification under PSD for all emissions of VOC limits and PM/PM10 to meet the Minnesota Performance Standard.

Total Facility Minn. R. chs. 7002, 7007, 7009, 7011, 7019, 7030, 40 CFR § 52.21, and 40 CFR pt. 51, Appendix S

A contains requirements that apply to all facilities in Minnesota. It also contains source-wide limits, which limits carbon monoxide to less than 20 tons per month and nitrogen oxides to less than 15 tons per month based on a 12-month rolling average. Following the limits are other requirements including record keeping and monitoring related to the limits. Reporting requirements are contained in Table B of the permit.

EU 001-003, 005-011, 015, 019, 020, 024-033

Minn. R. 7011.0700- 7011.0735

Standards of Performance for Industrial Equipment This standard includes limits for particulate matter and opacity.

Ovens EU007-008

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

Standards of Performance for Direct Heating Equipment The ovens are used to speed up the coating drying process. Natural gas is used to provide the heat. This rule specifies limits for particulate matter, opacity and sulfur dioxide.

Engine Testing EU 011-015 020-028, 031-033

Minn. R. 7011.2300 Standards of Performance for Stationary Internal Combustion Engines Engines operated for testing are subject to Minnesota Rules for internal combustion engines. The rules specify a limit for opacity and for the amount of sulfur dioxide emitted. Sulfur dioxide is produced from sulfur in the fuel; thus, limiting the fuel type which essentially limits the sulfur dioxide emissions.

Panel Filters (CE 001-006)

Minn. R. 7011.0600-7011.0080

Air Pollution Control Equipment The Permittee will operate and maintain each piece of the listed pollution control equipment according to the control equipment manufacturers specifications, will comply with the requirements specified in the permit, and will maintain the operation and maintenance plan


on-site in accordance with Minn. R. 7011.0075, subp. 2.

Thermal or Catalytic Oxidizer (CE 007)

Minn. R. 7007.0800, subp. 11

The Permittee will operate and maintain this piece of control equipment according to the operating scenario listed in the permit.

3. Technical Information Emission Calculations for Polaris 3.1 (a) Unrestricted Potential to Emit (PTE) Polaris calculated emissions for each emission unit operating at 8760 hours per year and arrived at the following PTE in tons per year for the stationary source: PM PM10 SO2 NOx CO VOC Combined

HAP * 249 * 249 9.62 187.89 ** 239 *249 249 * Polaris received a total facility permit in 1992 that limited its VOC and PM/PM10 emissions not to exceed 249 tons/year ** Polaris received a permit in 1997 that limit its CO emission to 239 tons/year 3.1 (b) Actual Emissions Polaris’ actual annual emissions in tons per year as reported in the Emission Inventory for 1998. PM PM10 SO2 NOx CO VOC Combined

HAP 4.36 4.36 0.32 10.91 184.42 192.79 Not

Available 3.1 (c) Limited Potential to emit Polaris’ Part 70 operating permit limits emissions as a 12-month rolling average. PM PM10 SO2 NOx CO VOC Combined

HAP 180 180 9.62 180 240 240 240 3.1 (d) Calculation of a 12-month Rolling Average


The source-wide limits in this permit are expressed as a 12-month rolling average. In a case where emissions are limited as a 12-month rolling average, the emissions that results from fuel use, as an example, are calculated as the average of the current month from the fuel used and the previous 11 consecutive months must be less than or equal to the monthly limit.

3.3 Periodic Monitoring Section 70.6(a)(3) of the Title V regulations specified the standard monitoring and related record keeping and reporting requirements that each Title V permit must contain. One important element of the monitoring, record keeping, and reporting requirement of Title V is that each permit must contain periodic monitoring sufficient to yield reliable data from relevant time period that is representative of the facility’s compliance with the permit. Under Minn. R. 7007.0800, subp. 4, the MPCA will require 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. To achieve this objective, the MPCA staff considered all the relevant factors approved by EPA periodic monitoring requirements for permitted sources. In evaluating the monitoring included in the permit, the MPCA considered the following: 1. the likelihood of violating the applicable requirements; 2. whether add-on controls are necessary to meet the emission limit; 3. the variability of emissions over time; 4. the type of monitoring, process, maintenance, or control equipment data already available for

the emission unit; 5. the technical and economic feasibility of possible periodic monitoring method, and 6. The kind of monitoring found on similar units.

TF/EU/GP/CE Emission Limit (Basis)

Additional Monitoring

Discussion

Total Facility (TF)

a. PM/PM10 ≤ 15 tons based on a 12-month rolling average (limit to avoid NSR) b. VOC ≤ 20 tons per month based on a 12-month rolling average (limit to avoid NSR) c. NOx ≤ 15 tons per month based on a 12-month rolling average (limit to avoid NSR) d. CO ≤ 20 tons per

a. Recordkeeping: Monthly records of material use, ongoing records of Solid content; Monthly calculations of Solid emissions. b. Recordkeeping: Monthly records of material use, ongoing records of VOC content; Monthly calculation of

This stationary source currently has a tracking system in place for calculations of PM/PM10, VOC, NOx and CO emissions.


month based on a 12-month rolling average (limit to avoid NSR)

VOC emissions. c and d. Recodkeeping; Monthly records based on fuel usage. Monthly calculations of NOx and CO emissions

GP 001 units; Coating Booths (EU 001, 002, 003, 004, 030, and 034) GP 005 units; Panel Filters (CE 001-006)

a. PM/PM10: variable depending on the airflow. (Minn. R. 7011.0715) b. Opacity ≤ 20% (Minn. R. 7011.0715) c. PM/PM10: Booths with panel filter systems must be maintained to achieve 73.6% control efficiency (Minn. R. 7011.0070, control equipment rule, required to remain below NSR threshold.

Recordkeeping, O & M Inspections and Certification of the hood (booth) performance in accordance with the control equipment rule, if applicable.

a. The engineering calculations showed that the PM emissions would be less than what is allowed under Minn. R. 7011.0715. Non-compliance is unlikely therefore, no additional periodic monitoring will be required. c. Monitoring based on the Minnesota Performance Standard for Control Equipment is adequate to have a reasonable assurance of compliance (daily, and periodic inspections, and correction actions)

GP 002 units; Engine Testing (EU 011-015, EU 020-028)

a. PM/PM10: variable depending on the airflow. (Minn. R. 7011.0715) b. SO2 ≤ 0.5 lb/MMBtu with a 3-hour basis. (Minn. R. 7001.2300) c. Opacity ≤ 20% (Minn. R. 7011.2300)

a. Recordkeeping: Maintain records of fuel combusted in the units; b. Visible emissions if engine is tested for more than one month

a. The likelihood of violating the SO2, PM/PM10, and opacity emission standard is impossible as long as the units are properly maintained, therefore, there is no periodic monitoring is required.


d. Fuel Restriction on the type of fuel.

b. Will check for visible emissions on a monthly basis if the engine is tested for more than a month. This monitoring is adequate because the engine will be tested on a temporary basis only.

GP 003 units Production Engine Testing Stations (EU 016-019, 029, 031-033)

a. PM/PM10: variable depending on the airflow. (Minn. R. 7011.0715) b. Opacity ≤ 20% (Minn. R. 7011.0715)

None No visible emissions are expected for these stations, therefore no additional periodic monitoring is warranted.

GP 004 units Ovens, (EU 007, 008)

a. PM /PM10: variable depending on the airflow (Minn. R. 7011.0610) b. Opacity ≤ 20% except for one six-minute period per hour of not more than 60 percent opacity. (Minn. R. 7011.0610)

None No visible emissions are expected from these units, therefore no periodic monitoring is warranted.


Catalytic or Thermal Oxidizer (EC 007)

VOC and CO: Control Efficiency of 90% or greater

Recordkeeping, O & M Inspections and Performance Testing.

Installation this control equipment will be an alternative operating scenario for Polaris. The control equipment will be use as needed to comply with the monthly emissions limits of the permit or to otherwise reduce emissions as desired by Polaris. Installation or operation of the oxidizer is not a requirement to meet any applicable emission limits. Performance Testing in addition to monitoring based on the Minnesota Performance Standard for Control Equipment is adequate to have a reasonable assurance of compliance (daily and periodic inspections, correction actions, O & M and temperature records.

3.4 Insignificant Emission Units (IEU) The IEU are in the Appendix B of the permit. These IEU are subject to the state general applicable requirements. It is our belief that IEU’s listed in Appendix B of the permit associated with inconsequential environmental impacts and present little potential for violations of generally applicable requirements, therefore no monitoring will be required.


4. Conclusion Based on the information provided by Polaris, Inc., the MPCA has reasonable assurance that the proposed operation of the emission facility, as described in the Air Emission Permit No. 13500008-001 and this technical support document, will not cause or contribute to a violation of applicable federal regulations and Minnesota Rules. Staff Members on Permit Team: Staff Engineer: Amrill Okonkwo at (651)296-7009 Enforcement Staff: Cary Hernandez at (218) 846-0746 Attachment: A. Form GI-07 (Facility Emission Summary) B. Form CD-01 (Compliance Form) C. MPCA and Pemittee’s Emission Calculations Amrill Okonkwo, April 12, 2001


ATTACHMENT A

FORM GI-07 (Facility Emission Summary)


ATTACHMENT B FORM CD-01 (Compliance Form)


ATTACHMENT C

MPCA and Permittee’ Calculations (Paper Copy)

air emission permit no. 13500008- 001 is … · roseau highway 89 south roseau, roseau county, mn...

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