Program Review
of
Iowa Department of Natural Resources'
Air Permitting Programs
Conducted: July 2021 & November 2021
U.S. EPA, Region 7
Air Permitting and Standards Branch
Air and Radiation Division
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Iowa Air Quality Bureau Permitting Program Review Report Contents
Contents
A. INTRODUCTION 1
B. SUMMARY of FINDINGS and CONCLUSIONS from PERMIT FILE REVIEW 2
C. SUMMARY of FINDINGS and CONCLUSIONS for TITLE V FEE REVIEW 8
D. SPECIFIC PERMIT FILE REVIEW FINDINGS 10
1. Staffing 10
2. Permit Project File Review 10
ATTACHMENT A: List of Construction Permit Files Reviewed 11
ATTACHMENT B: Completed NSR Questionnaire 13
ATTACHMENT C: Completed Title V Questionnaire 202
ATTACHMENT D: Fee Attachment 1084
ATTACHMENT E: Entrance Meeting Attendees 1085
ATTACHMENT F: Exit Meeting Attendees 1086
ATTACHMENT G: IDNR's Response Letter Regarding the Draft Report 1087
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IOWA DEPARTMENT OF NATURAL RESOURCES
AIR QUALITY BUREAU
AIR PERMITTING PROGRAMS
PROGRAM REVIEW REPORT
A. INTRODUCTION
The comprehensive review of the Iowa Department of Natural Resources' (IDNR's) air
permitting programs was part of the U.S. Environmental Protection Agency Region 7's efforts to
fulfill the EPA's oversight responsibility to ensure adequate implementation of the Clean Air Act
(CAA). The overall scope of this review included assessment of the state agency's performance
regarding: 1) Prevention of Significant Deterioration (PSD)/New Source Review (NSR)
construction permitting including synthetic minor construction permitting, 2) Title V operating
permitting, 3) New Source Performance Standards (NSPS) and National Emission Standards for
Hazardous Air Pollutants (NESHAP) determinations, 4) the establishment of enforceable permit
conditions, and 5) the collection and use of Title V operating permit fees. Although PSD
permitting and Title V operating permitting were a component of this program review, these
permitting programs are regularly reviewed as part of the routine oversight of IDNR's air
permitting program and were not the primary focus of the permit file review. The focus of the
file review was on synthetic minor construction permitting and the collection and use of Title V
operating permit fees.
The review was initiated by a letter from the EPA to the IDNR dated April 12, 2021. In that
letter, the EPA requested a list of construction permits issued by the IDNR over the previous
three years. The EPA also requested that the IDNR complete two questionnaires, one for NSR
and one for Title V. The EPA requested that the IDNR submit responses to both questionnaires
prior to our review of the selected permitting files. We also requested that the IDNR complete
Attachment C from the March 27, 2018, guidance "Program and Fee Evaluation Strategy and
Guidance for 40 CFR Part 70." EPA Region 7 has historically conducted air permit program
reviews at the office of the state under review, but due to the COVID-19 pandemic, this permit
program review was conducted through video meetings and off-site review of electronic
permitting documents. The majority of the documents that the EPA reviewed were available
from the IDNR's website.
A program review entrance meeting was held virtually on July 14, 2021. Attachment E lists the
attendees of the meeting. The EPA staff reviewed permit project files from approximately July
19 to July 30, 2021. The following EPA Region 7 staff participated in the review of the
permitting files: Ward Burns, Bob Cheever, David Peter, Pat Scott and Bob Webber. A total of
46 construction permitting project files were reviewed regarding the above-mentioned actions
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(see Attachment A). The EPA summarized our initial findings and provided the next steps
associated with the review during a recurring monthly permit meeting between the IDNR and the
EPA on August 17, 2021. Attachment F lists the attendees of that meeting. The EPA conducted a
review of the Title V fee information in the months of October and November 2021. Kathy
Finazzo coordinated the EPA's review of the IDNR's Title V fee information.
IDNR staff assisted the review team by ensuring access to the requested electronic permit files,
providing financial information related to Title V fees and answering questions that arose from
the review team during the review. The review team appreciates all of the assistance that IDNR
staff provided during the permit program review.
B. SUMMARY of FINDINGS and CONCLUSIONS from PERMIT FILE REVIEW
The permit review team concluded that IDNR implements adequate construction and operating
permit programs. In general, we found that the projects we reviewed were permitted
appropriately. We made the following observations during our permit file review. These
observations are in no particular order.
1. The following observations are related to the evaluation of the application:
a. IDNR appears to use appropriate emission factors when evaluating the increase in
emissions from the project being evaluated.
b. IDNR appears to adequately document the source of the emission factors used as
part of the permit application evaluation.
c. It appears that the NSPS and NESHAP applicability determinations that were
made as part of the permitting actions that we reviewed were correct.
d. We reviewed the construction permitting records for evidence that the IDNR was
considering the impact to air quality when issuing permits. 40 CFR §51.160(a)
states: "Each plan must set forth legally enforceable procedures that enable the
State or local agency to determine whether the construction or modification of a
facility, building, structure or installation, or combination of these will result in—
(1) A violation of applicable portions of the control strategy; or (2) Interference
with attainment or maintenance of a national standard in the State in which the
proposed source (or modification) is located or in a neighboring State. " EPA
notes that IDNR developed a modeling guidance document that establishes which
projects require a modeling analysis and how that modeling analysis is to be
conducted. IDNR appears to conduct modeling analyses in accordance with its
modeling guidance document as part of the construction permit application review
process to ensure compliance with the National Ambient Air Quality Standards
(NAAQS).
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e. IDNR recently implemented an online permit application titled Iowa EASY Air.
The EPA recognizes that Iowa EASY Air has numerous benefits in relation to the
permit application process. One significant benefit that IDNR identified in
Question (A)(1) of the Title V Questionnaire is that the online application system
has mandatory field entry and a completeness check which has all but eliminated
incomplete applications. The EPA commends IDNR for undertaking the
implementation of this online application system.
f. In response to the Title V Questionnaire Question (A)(6)(c), IDNR identifies
several other benefits of the Iowa EASY Air online application system. These
benefits include less data entry, accurate data, streamlined permitting process,
online fee payment, saving time and resources, data sharing capabilities, and
improvements to the emission inventory process. The EPA agrees that this system
appears to have numerous benefits to both IDNR and the permittee.
g. In response to Title V Questionnaire question (I), the IDNR describes a "Trello"
visualization board that is utilized to allow IDNR staff and management to
quickly and easily track permit application status. IDNR identified several
benefits from the use of this tracking system. EPA reviewed the tracking system
and agrees that system provides many benefits. The EPA commends IDNR for
implementing this permit tracking system.
2. The following observations are related to the development and use of technical support
documents and other permit record documentation:
a. In general, it appears that the Fact Sheets/Technical Support Documents that
IDNR develops as part of the permitting action adequately explain the state's
rationale for permitting and regulatory decisions, including NSPS and NESHAP
applicability determinations.
b. IDNR appears to appropriately rely on and implement EPA guidance documents
to determine the projects' permit and air regulatory applicability.
c. It appears that the permitting record for the projects we reviewed include all of the
relevant documents associated with the permitting action, including all relevant
email correspondence.
d. IDNR provides access to permitting documents to the public. IDNR's electronic
records system, "DocDNA", appears to include most of the relevant permitting
documents associated with the facility. In addition to DocDNA, IDNR provides
access to permitting documents on its construction and operating permits websites
and the newly developed Iowa EASY Air. The combination of these resources
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provides the public an inexpensive and quick resource to obtain air permitting
documents related to permitted facilities.
3. The following observations are related to the permit contents:
a. The permits that we reviewed appeared to adequately identify the equipment that
was being installed or modified.
b. The permits that we reviewed appeared to include the appropriate conditions to
ensure that the limits were enforceable as a practical matter, including conditions
to ensure ongoing compliance demonstration.
c. IDNR's construction permits appropriately include a condition that describes
when construction must commence and when construction must be completed.
d. IDNR's construction permits appear to adequately describe what constitutes
excess emissions and the appropriate actions the permittee must take if excess
emissions occur.
e. It appears that construction permits receive an adequate amount of peer review.
f. For the permits that we reviewed, the averaging period of emission limits
included in the permit appear to align with the averaging period of the NAAQS
when appropriate.
4. The following observations are related to the permit issuance timeliness:
a. The permits we reviewed appeared to be issued in a timely manner, although there
is no regulatory deadline for permit issuance of synthetic minor construction
permits.
b. IDNR has a relatively small amount of "backlogged" Title V permits. EPA
recognizes that IDNR made efforts beginning in 2014 to reduce the Title V permit
backlog. The EPA also recognizes that staff turnover in the last year or so has
resulted in a slight increase in the backlog over that period. However, since
February 2021, IDNR's Title V permit program has been fully staffed and IDNR
has indicated that it plans to reduce the backlog by over 50% in 2022.
5. The following observations are related to the permit staff training:
a. As discussed in Question (I)(B)(7) of the NSR Questionnaire, although IDNR
indicated that they have little turnover, it appears that the agency has a robust
training program for new employees. This robust training program would likely
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decrease the time for a newly hired permit reviewer to begin reviewing and
processing permit applications.
b. The EPA recognizes the various activities that IDNR has undertaken to ensure
continuous improvement in their Title V program including developing a defined
training program for new employees and initiating several Kaizen and other
process improvement activities. IDNR listed these activities in Question (A)(4) of
Title V Questionnaire. EPA commends IDNR for undertaking these activities and
encourages IDNR to continue these activities in the future.
6. The following observation is related to IDNR's coordination with EPA on PSD permit
applications. IDNR adequately informs EPA of pending PSD permitting projects,
including providing modeling analyses and permit applications prior to the permits being
placed on public notice. Further, IDNR typically invites EPA staff to PSD pre-application
meetings. EPA appreciates being informed of these projects early in the permitting
process and believes that such coordination usually results in a more efficient permit
issuance process.
EPA also made the following observations as part of this program review. These observations, in
general, highlight potential areas of improvement and do not necessarily indicate program
deficiencies.
1. The majority of the permits that EPA reviewed that included 12-month rolling limits
didn't specify the consequences of exceeding the limit in the first months the limit applies
(for example, the limit is exceeded in the 9th month after the limit is applicable).
Although EPA believes that it would not be a compelling argument, an argument could
be made that a violation couldn't possibly occur until the 12th month of operating under
the limit, since one could argue that a full 12-month period is needed to compare to the
12-month rolling limit. The EPA recommends that IDNR consider including a statement
in the permit that an exceedance at any point in the first 11 months that the limit applies
would constitute a violation of the limit at the time that the limit is exceeded.
2. IDNR indicated in Question (II)(B)(3)(4) and (VI)(A)(1) that environmental justice issues
are currently not generally considered in its permitting issuance process. We recognize
that Iowa does not have any EJ legislation, policy, or general guidance related to
permitting. We further recognize that IDNR interprets the Clean Air Act (Act) and their
State Implementation Plan (SIP) to not address EJ in permitting actions. However, other
states with similar SIPs have received comments alleging that a minor construction
permit violated Title VI of the Civil Rights Act of 1964. Therefore, we encourage the
IDNR to consider EJ issues and engage with communities as appropriate. Further, EPA
R7 is aware of IDNR's interest in potentially utilizing EJ considerations in the future. To
that extent, EPA encourages IDNR to consider potential EJ concerns in future permitting
activities. IDNR did state that they work diligently to ensure their work is transparent to
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the public. They have several ways the public can stay informed about proposed
construction or Title V permit applications in their area. Iowa EASY Air does provide the
public access to applications and issued permits. They also have a website that allows the
public to search construction permits by criteria such as city or county and provides
access to issued permits and applications under review. They have a similar site for Title
V permits. Both provide the direct contact information for the staff member assigned to
review the permit so the public can directly contact them for questions or submit
comments. Also, IDNR recently released a new GIS-based method the public can use to
search for active applications. The Environmental Services Dashboard allows the public
to use a map tool to target areas of interest and display active construction and Title V
permit applications in those areas along with a link to Iowa EASY Air to further view the
application information. The dashboard also provides summary information for the public
on the number of active applications by submission type and review status in the selected
areas of interest.
In addition to their public permit information, the IDNR maintains a public participation
website that lists all opportunities for the public to make recommendations on
rulemakings and planning activities, including meetings and workgroups.
IDNR has also recently launched an environmental justice website that outlines IDNR's
language and disability plans and reflect IDNR's commitment to serving Iowans of all
backgrounds and cultures, including individuals with limited English proficiency and
providing individuals with disabilities the opportunity for full participation in its
programs, services, and activities. To further that effort the following language has
recently been added to our air quality public notices:
"Individuals with disabilities or limited English proficiency are encouraged to
participate in all DNR activities, including submitting public comments. If a
reasonable accommodation or language services are needed to participate, contact the
Air Quality Bureau staff member listed or Relay Iowa TTY Service at 800-735-7942
in advance to advise them of your specific needs. DNR's language access and
disability nondiscrimination plans are available at https://www.iowadnr.gov/About-
DNR/Environmental-Justice"
3. As part of this permit review, the EPA determined that IDNR appeared to appropriately
identify all of the applicable requirements, including the applicable NSPS and NESHAP
subparts, in the permitting actions that we reviewed. As part of our routine review of
Title V permits proposed for issuance by IDNR, EPA also has determined that the IDNR,
in general, identifies all of the appropriate applicable requirements. However, we do note
that the level of detail of the applicable requirements in Title V permits has not
necessarily been consistent from permit to permit, sometimes even for the same subpart.
The EPA recognizes that there are several approaches to incorporating applicable
requirements from an applicable subpart. On one end of the spectrum, the permit could
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simply indicate the facility or affected source is subject to a certain subpart and refer the
permittee to the Code of Federal Regulations. On the other end, the permit could include
the entire subpart verbatim, with no identification of the specific paragraphs that apply to
the affected source. The EPA recognizes that there are issues with both of these extreme
approaches, as neither approach adequately informs the permittee or the public of the
specific applicable requirements that the permittee is required to comply with. Typically,
the most useful approach would be one that is a balance of these two extremes. The EPA
recommends that IDNR work toward achieving consistency in how applicable
requirements are included in the draft permit, especially for permits with affected sources
subject to the same subpart. This approach would ensure that the permittee and the public
are made aware of the applicable requirements in a clear and consistent manner.
4. IDNR has included the phrase "of the source category" when indicating that the facility is
subject to certain NSPS and NESHAP subparts in Title V permits. IDNR staff have
indicated in the past that the reason this phrase was used for certain subparts was because
the IDNR has not adopted that federal rule and that they have no authority to determine
whether the rule applies or doesn't. Regardless of the rationale for the use of its phrase,
the phrase leads to ambiguity on whether the rule actually applies or not. As stated at 567
IAC 22.108(l)(f), the Title V permit should clearly identify all applicable requirements.
Should IDNR have any question whether a federal rule that IDNR has not adopted is
applicable, IDNR should coordinate with EPA Region 7 for a determination such that the
Title V permit will clearly identify whether the rule is applicable to the facility. In
response to this observation, the IDNR stated that this language was discontinued in
January 2013 and that any use of that language in any current Title V permit is an
oversight.
5. During routine reviews of IDNR's proposed draft Title V permits and follow-up
discussions with IDNR staff, it is EPA's understanding that the statement of basis or Title
V permit writer notes typically only address changes that occurred since the previous
Title V was issued (such as physical changes at the facility or changes in the applicable
requirements). While this approach likely has benefits, such as highlighting the changes
to the previous permit so that the focus of the review can be on those changes, it also
doesn't provide a complete summary of the rationale for all applicable requirement
determinations for the facility. As Title V permits are generally renewed every five years,
there is the likelihood that interested parties including the public and permitting staff
from IDNR, EPA and the affected facility may not have been involved in the drafting and
issuance of the previous Title V permit. Therefore, EPA recommends that the statement
of basis or permit writer notes reference the previous statement of basis in some manner.
A couple of options that EPA identified, but there are certainly others, include making the
previous statement of basis part of the permitting record for the renewal permit or clearly
indicate where the public or other entities can easily obtain the previous statement of
basis.
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6. In response to Title V Questionnaire question (E)(2), the IDNR stated that Title V permit
modifications are not being prioritized primarily due to the fact that IDNR is not
authorized to charge application fees for modifications. The EPA recognizes this
challenge. However, Title V permit modifications often have significance to the
permittee and the public. For example, 567 IAC 22.105(l)(a)(8) and 567 IAC 22.113(3)
state in cases in which an existing Title V permit would prohibit such construction or
change in operation, the owner or operator must obtain a Title V permit revision before
commencing operation. Further 567 IAC 22.113(3) states that unless the director
determines otherwise, review of significant Title V permit modification applications shall
be completed within nine months of receipt of a complete application, which is consistent
with 40 CFR 70.7(e)(4)(ii) which states that "the permitting authority shall design and
implement this review process to complete review on the majority of significant permit
modifications within 9 months after receipt of a complete application." The EPA
recommends that IDNR investigate opportunities to assess application fees for significant
modification applications such that this potentially important component of the Title V
permit program is fully implemented.
C. SUMMARY of FINDINGS and CONCLUSIONS for TITLE V FEE REVIEW
Section 502(b)(3)(A) of the Clean Air Act (Act) requires Title V operating permit
programs to fund all "reasonable direct and indirect costs" of the permit programs
through fees collected from Title V sources and requires the fees to be sufficient to cover
all reasonable Title V permit program costs. 40 CFR §70.9(a) requires state Title V
programs to collect fees sufficient to cover the permit program costs and "ensure that any
fee required by this section will be used solely for permit program costs."
In response to an EPA Office of Inspector General 2014 report, regarding the importance
of enhanced EPA oversight of state, local, and tribal fee practices under Title V of the
Act, the EPA issued a March 27, 2018 guidance titled "Program and Fee Evaluation
Strategy Guidance for 40 CFR Part 70." This guidance recommends the EPA seek
internal assistance for fee evaluations from staff with governmental accounting, financial,
or economics expertise, who work outside the Part 70 program. For this review, Kathy
Finazzo from the EPA Region 7's Resources and Financial Management Branch in the
Mission Support Division provided assistance.
IDNR's Title V permit program is funded by two sources - annual emission fees and
hourly application fees. The current annual emissions fee is $70 per ton for the first 4,000
tons of each regulated air pollutant. The current hourly application fee is $100 per hour
for initial Title V permits and Title V renewals. IDNR is currently not authorized to
assess fees for Title V permit modifications. Annual emissions are reported to IDNR
using SLEIS and fees received are tracked by IDNR using a Microsoft Access Database.
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The Iowa fiscal year runs from July 1 to June 30. The EPA's presumptive Title V fee that
applied during Iowa's 2020 fiscal year was $52.03 per ton. The total emissions from Iowa
sources during Iowa's 2020 fiscal year that were used for the presumptive fee calculation
were 102,814 tons. Therefore, the presumptive minimum fee collection amount is
calculated to be $5,349,415 (102,814 tons x $52.03/ton). Iowa actually collected
$12,388,558, which included a carryover from the previous fiscal year. Therefore, Iowa
collected an amount greater than or equal to the presumptive fee required by the EPA and
is therefore presumed to have adequate fees to fund the Title V program. Further, Iowa
spent $7,115,259 to fund the Title V program in FY 2020, which is less that the amount
collected for FY 2020.
As is expected, the largest expense of IDNR's permit program is personnel cost. IDNR
Title V permit writers work exclusively on Title V permits, Certain other IDNR staff,
such as compliance, legal, field office, IT and program support, may also work on Title
V-related issues. Personnel time spent working on Title V permits and other Title V
permit activities is tracked in the Iowa EASY Air system. Application fee statements are
sent to the facility based on the hours included in the Iowa EASY Air system. There are
currently five Title V permit writers, two lead workers, and approximately one FTE
shared by Linn and Polk counties.
Based on our review of IDNR's financial data, it does not appear that IDNR is using
funds designated for Title V activities for any other purposes. Nor did it appear that
IDNR uses non-Title V funds for Title V activities. However, EPA does recommend that
IDNR ensure that the "Workday" Title V work tags are sufficiently descriptive to
demonstrate that the activities and expenses being claimed for Title V activities actually
qualify as valid Title V activities. IDNR believes the work tags combined with staff time
use data provides IDNR with adequate information that the activity and expenses qualify
as valid Title V activities.
In addition, the amount of regulated air emissions in Iowa that are covered under the
emissions fee program are trending down. Therefore, Iowa informed the EPA that it is
considering potential actions that it may need to take in response to this reduction to
ensure that the Title V permit program is adequately funded.
In summary, the EPA did not observe any significant concerns with how IDNR is
managing the Title V program in relation to the use of Title V fees and the ability for the
state to adequately fund the Title V permit program at the current time.
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D.
SPECIFIC PERMIT FILE REVIEW FINDINGS
Staffing
The IDNR air permitting program is divided into two groups - Construction Permit
Section and Operating Permits and Emissions Inventory Section.
Based on information provided by IDNR as part of the NSR Questionnaire, the
Construction Permit Section has a total of 14 staff positions. This includes a one
supervisor, five senior engineers, and nine engineers. The average length of NSR
permitting experience is over 17 years.
Based on information provided by IDNR as part of the Title V Questionnaire, the
Operating Permit and Emissions Inventory Section has a total of eight staff positions
related to Title V permit development. This includes one supervisor, two senior
environmental specialists, and five environmental specialists. The average length of
operating permitting experience is over nine years.
Permit Project File Review
1. For AGP Eagle Grove project 17-314, it appears that the emission factors for certain
units associated with the project are developed from stack testing. We recommend
that, in future permitting actions, IDNR provide more detail in either the permit writer
notes or the permit itself on the specific procedure from converting stack test results
to an emission factor that will be used in compliance demonstrations.
2. For Flint Hills Menlo project 20-282, section 6 of permit indicates that a CEMS was
not required by the permit. However, it appears that to demonstrate compliance with
certain NOx limits, a CEMS is utilized.
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ATTACHMENT A: List of Construction Permit Files Reviewed
Facility Name
Project ID
Location
3M
19-218
Knoxville
3M
19-268
Knoxville
3M
20-241
Knoxville
ADM Clinton Corn Processing
19-419
Clinton
Ag Processing, Inc. Eagle Grove
17-314
Eagle Grove
Ag Processing, Inc. Eagle Grove
19-040
Eagle Grove
Ag Processing, Inc. Sergeant Bluff
18-027
Sergeant Bluff
American Popcorn Company
18-492
Sioux City
Anamosa State Penitentiary - Iowa Prison Industries
18-406
Anamosa
Burke Corporation
18-490
Nevada
Cambrex Charles City, Inc.
19-006
Charles City
Cargill, Inc. - Sioux City
20-092
Sioux City
Cemstone Concrete Material
19-368
North wood
CHI Health Mercy Council Bluffs
18-459
Council Bluffs
Climax Molybdenum Company
20-024
Fort Madison
City of Eagle Grove
18-119
Eagle Grove
Farmers Feed and Supply
19-197
Boyden
Fletcher Wood Products
19-338
Fort Dodge
Flint Hills Resources Menlo, LLC
20-282
Menlo
Grain Processing Corporation
18-269
Muscatine
Gregory Manufacturing
19-039
Fort Madison
Hawkeye Pedershaab Concrete Technologies, Inc.
18-397
Mediapolis
Karl Chevrolet of Stuart Collision Center
19-030
Stuart
Kent Nutrition Group
19-095
Sheldon
Kiliper Corporation
19-191
Ames
Lincolnway Energy
19-078
Nevada
Muscatine Water & Resource Recovery
19-383
Muscatine
NEW Corporative, Inc. - Cooper
20-281
Jefferson
Pella Corporation - Carroll Division
20-217
Carroll
Pella Corporation - Sioux Center Operations
20-063
Sioux Center
REG Ralston, LLC
20-034
Ralston
Responsible Transportation LLC
19-332
Sigourney
Sabre Towers and Poles
18-432
Sioux City
Seabee - Hampton Hydraulics
19-310
Hampton
Siouxland Energy Cooperative
19-278
Sioux Center
Smithfield Fresh Meats Corp.
18-302
Denison
TCC Materials
20-172
Muscatine
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Facility Name
Project ID
Location
Tyson Fresh Meats, Inc.
20-208
Waterloo
University of Iowa - Oakdale Utility Power Plant
18-261
Coral ville
University of Northern Iowa - Power Plant
19-429
Cedar Falls
University of Northern Iowa - Power Plant
18-273
Cedar Falls
City of Waterloo, Wastewater Treatment Plant
17-211
Waterloo
Wausau Supply Company
20-033
Stuart
Whirlpool Corporation - Amana Appliance Division
19-169
Amana
Whirlpool Corporation - Amana Appliance Division
20-021
Amana
Whirlpool Corporation - Amana Appliance Division
18-022
Amana
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ATTACHMENT B:
Completed NSR Questionnaire
Returned by IDNR prior to Audit.
[ see the attached copy ]
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NSR Program
Self-Evaluation Questionnaire
Last Updated: December 5, 2006
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Instructions for completing the
New Source Review (NSR) Permit Program
Self-Evaluation Questionnaire
• When answering Yes or No questions, please add explanation as
appropriate to clarify your response.
• This self-evaluation questionnaire does not address implementation of
changes made to the federal major NSR rules in EPA's rulemaking on
December 31, 2002 (as amended November 7, 2003)
• Please skip any sections of the self-evaluation questionnaire that do not
apply within your permitting jurisdiction rather than answering
hypothetically. For example, skip the nonattainment major NSR
sections if you do not have any nonattainment areas.
• If you have a written policy or guidance document that substantially
answers any question in this self-evaluation questionnaire, please so
indicate and either attach a hardcopy to your response or point to a
specific URL on your public web server where the document may be
found.
• This self-evaluation questionnaire was developed by EPA Headquarters
and Regions to assist in the agency's NSR oversight program. As part
of its peer review process, EPA sought review and comment from
STAPPA-ALAPCO. While this questionnaire has undergone a make-
over from the original, the scope and detail of the questions asked
remains the same for all agencies.
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Table of Contents
I. 3
A. NSR Permits
B. Staff and Training
C. NSR Implementation
D. Public Participation
E. Program Benefits
II. 19
A. 19
B. 26
C. Nonattainment Major NSR Permitting
III. 39
A. 39
B. 42
C. Circumvention/Aggregation
D. Synthetic Minor Permit Limits
E. 46
IV. 47
V. 49
A. 49
B. 54
C. Minor Source Modeling
D. Increment Tracking
VI. 58
A. Environmental Justice (EJ)
B. Endangered Species Act (ESA)
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6
7
8
10
19
26
27
32
33
35
36
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I. Overview of New Source Review (NSR) Permitting Program
A. NSR Permits
1. Permit Tracking
YDN8 1. Do you have an established procedure for tracking synthetic minor
permits?
If yes, please describe how your permits are being tracked (e.g., in an
electronic database)
Y ~ N M 2. Do you have an established procedure for tracking major NSR permits?
If yes, please describe how your permits are being tracked (e.g., in an
electronic database)
2. Permit Issuance Rates
Note: 2020 was an abnormally slow year for permit issuance due to the global
pandemic. In a more typical year, Iowa DNR reviews between 460 to 500 projects
and issues between 1700 and 2200 permits annually.
1. How many PSD permits did you issue last year?
In 2020, Iowa DNR completed 16 PSD projects, issuing 152 permits in
those projects. (Note: not all of these permits were PSD permits. A file
review of each project would be necessary to identify how many permits
were actually PSD permits)
a. If none, when was the last PSD permit issued?
2. How many nonattainment major NSR permits did you issue last year?
None
a. If none, when was the last nonattainment Major NSR permit issued?
Unknown, prior to the year 2000.
3. How many synthetic minor NSR permits did you issue last year?
Iowa DNR does not track synthetic minor and true minor permits
separately. In 2020, Iowa DNR completed 356 non-PSD projects, issuing
1080 permits and making 27 determinations.
4. How many true minor NSR permits did you issue last year?
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As stated in response to question #3 above, Iowa DNR does not track
synthetic minor and true minor permits separately. In 2020, Iowa DNR
completed 356 non-PSD projects, issuing 1080 permits and making 27
determinations.
5. How many "as built" NSR permits did you issue last year?
Iowa DNR does not track "as-built" projects specifically. These permits
would be included in the total number of permits listed above.
6. Did you issue any waivers or variances allowing a source to commence
construction prior to receiving a permit?
Y ~
N E
a.
For any PSD projects? If so, how many?
Y ~
N E
b.
For any major source non-attainment projects? If so, how many?
Y M
N ~
c.
For any synthetic minor NSR projects? If so, how many?
Y M
N ~
d.
For any true minor NSR projects? If so, how many?
7. What is the average time, in months, it takes you to issue the following
types of permits, starting from the time the application was determined
complete?
Note: Iowa DNR does not track a date when the application is deemed
complete. All of the Construction Permit Section's performance tracking
metrics are calculated from the date the application is initially received to
the date the permits are issued.
a. PSD permits
PSD permits are taking us approximately 100 days (1.3 months) on
average to complete. This includes new major sources and major
modifications at existing major sources.
b. Nonattainment major NSR permits?
NA, none have been issued.
c. Non-major/synthetic and minor permits?
Projects reviewed in this category are tracked in two different
groups. Most (approximately 90%) of the projects in this category
are what I DNR refers to as "standard" projects. The lead time for
these "standard" projects averages approximately 40 days (1.3
months).
The remainder of the projects in this category are considered "other
complex" projects and include:
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• projects associated with SIP maintenance areas;
• projects associated with compliance or other legal issues;
• complex Title V synthetic minors;
• complex PSD synthetic minors;
• complex greenfield facilities;
• netting projects.
Other complex projects take us an average of 180 days or
approximately 6 month to complete.
d. "As built" permits?
"As-built" projects are not currently tracked separately and are
included in the reported lead times for the appropriate category
reported above.
8. Please provide an Excel spreadsheet listing all of the NSR projects
permitted in the three calendar years preceding the program review. For
example, if the review takes place in 2007, include data for calendar years
2004, 2005, and 2006. To the extent available, include 1) the source
name, 2) general location, 3) general description of project, 4) standard
industrial classification code (SIC), 5) date application received, 6) date
permit issued, 7) the type of permit issued, 8) any identification codes (e.g.
AFS source number, project number, permit number) that facilitate retrieval
of the permit record, and 9) any NSPS, NESHAP, or MACT subparts
triggered by the project. Also identify all projects where the permit was
issued after the project had already commenced construction.
Provided as attachment (Document titled Section I.A_Question 2.8
permitting projects completed CY18-CY20).
3. Effective Permit Writing
Do your NSR permits:
Y [x] |\| ~ 1- Identify each emissions unit regulated?
Y M N ~ 2. Establish emissions standards or other operational limits that must be met,
including appropriate averaging times for numeric limits?
Y [x] |\| ~ 3. Include specific methods for determining compliance and excess
emissions, including reporting, record keeping, monitoring, and testing
requirements?
Y [x] |\| ~ 4. Outline procedures necessary to maintain continuous compliance with
emission limits?
Y [x] |\| ~ 5. Establish specific, clear, concise, and enforceable permit conditions?
Y [x] |\| ~ 6. Include conditions necessary for a source to avoid otherwise applicable
requirements (e.g., keeping a modification "minor")?
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7. Describe the consequences, if any, for failing to meet any permit limit taken
to avoid a substantive requirement (e.g. an emission cap taken to avoid
PSD, a number-of-hours restriction to avoid more stringent BACT)?
If so, describe the nature of the permit condition and what those
consequences might be.
The consequences of failing to meet a permit requirement depend on the
requirement that is violated.
Y [x] |\| ~ 8. Establish the "enabling legislative" and "legal" basis to issue and enforce
the conditions of the permit?
PERMIT ISSUANCE
Iowa Code section 455B.134 states that the director shall:
3. Grant, modify, suspend, terminate, revoke, reissue, or deny permits for
the construction or operation of new, modified, or existing air
contaminant sources and for related control equipment subject to the
rules adopted by the commission. The department shall furnish
necessary application forms for such permits.
a. No air contaminant source shall be installed, altered so that it
significantly affects emissions, or placed in use unless a
construction permit has been issued for the source.
b. The condition of expected performance shall be reasonably detailed
in the construction permit.
c. All applications for permits shall be subject to such notice and public
participation as may be provided by rule by the commission. Upon
denial or limitation of a permit, the applicant shall be notified of such
denial and informed of the reason or reasons therefor, and such
applicant shall be entitled to a hearing before the commission.
567 Iowa Administrative Code section states:
567—22.1(455B) Permits required for new or existing stationary sources.
22.1(1) Permit required. Unless exempted in subrule 22.1(2) or to meet the
parameters established in paragraph "c" of this subrule, no person shall
construct, install, reconstruct or alter any equipment, control equipment or
anaerobic lagoon without first obtaining a construction permit, or permit
pursuant to rule 567—22.8(455B). or permits required pursuant to rules
567—22.4(455BV 567—22.5(455BV 567—31,3(455BV and 567—
33.3(455B) as required in this subrule. A permit shall be obtained prior to
the initiation of construction, installation or alteration of any portion of the
stationary source or anaerobic lagoon.
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22.1(3) Construction permits. The owner or operator of a new or modified
stationary source shall apply for a construction permit.
567—22.3(455B) Issuing permits.
22.3(1) Stationary sources other than anaerobic lagoons. In no case shall a
construction permit which results in an increase in emissions be issued to
any facility which is in violation of any condition found in a permit involving
PSD, NSPS, NESHAP or a provision of the Iowa state implementation plan.
If the facility is in compliance with a schedule for correcting the violation
and that schedule is contained in an order or permit condition, the
department may consider issuance of a construction permit. A construction
permit shall be issued when the director concludes that the preceding
requirement has been met and:
a. That the required plans and specifications represent equipment
which reasonably can be expected to comply with all applicable
emission standards, and
b. That the expected emissions from the proposed source or
modification in conjunction with all other emissions will not prevent
the attainment or maintenance of the ambient air quality standards
specified in 567—Chapter 28. and
c. That the applicant has not relied on emission limits based on stack
height that exceeds good engineering practice or any other
dispersion techniques as defined in 567—subrule 23.1(6), and
d. That the applicant has met all other applicable requirements.
22.3(2) Anaerobic lagoons. A construction permit for an industrial
anaerobic lagoon shall be issued when the director concludes that the
application for permit represents an approach to odor control that can
reasonably be expected to comply with the criteria in 567—subrule 23.5(2).
A construction permit for an animal feeding operation using an anaerobic
lagoon shall be issued when the director concludes that the application has
met the requirements of rule 567—65.15(455B).
22.3(3) Conditions of approval. A permit may be issued subject to
conditions which shall be specified in writing. Such conditions may include
but are not limited to emission limits, operating conditions, fuel
specifications, compliance testing, continuous monitoring, and excess
emission reporting.
a. Each permit shall specify the date on which it becomes void if work
on the installation for which it was issued has not been initiated.
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b. Each permit shall list the requirements for notifying the department
of the dates of intended startup, start of construction and actual
equipment startup. All notifications shall be in writing and include
the following information:
(1) The date or dates required by 22.3(3Y'b" for which the notice is
being submitted.
(2) Facility name.
(3) Facility address.
(4) DNR facility number.
(5) DNR air construction permit number.
(6) The name or the number of the emission unit or units in the
notification.
(7) The emission point number or numbers in the notification.
(8) The name and signature of a company official.
(9) The date the notification was signed.
c. Each permit shall specify that no review has been undertaken on the
various engineering aspects of the equipment other than the
potential of the equipment for reducing air contaminant emissions.
d. Rescinded IAB 3/18/15. effective 4/22/15.
e. If changes in the final plans and specifications are proposed by the
permittee after a construction permit has been issued, a
supplemental permit shall be obtained.
f. A permit is not transferable from one location to another or from one
piece of equipment to another unless the equipment is portable.
When portable equipment for which a permit has been issued is to
be transferred from one location to another, the department shall be
notified in writing at least 7 days prior to the transfer of the portable
equipment to the new location. Written notification shall be submitted
to the department through one of the following methods: electronic
mail (email), mail delivery service (including U.S. Mail), hand
delivery, facsimile (fax), or by electronic format specified by the
department (at such time as an Internet-based submittal system or
other, similar electronic submittal system becomes available).
However, if the owner or operator is relocating the portable
equipment to an area currently classified as nonattainment for
ambient air quality standards or to an area under a maintenance
plan for ambient air quality standards, the owner or operator shall
notify the department at least 14 days prior to transferring the
portable equipment to the new location. A list of nonattainment and
maintenance areas may be obtained from the department, upon
request, or on the department's Internet website. The owner or
operator will be notified by the department at least 10 days prior to
the scheduled relocation if said relocation will prevent the attainment
or maintenance of ambient air quality standards and thus require a
more stringent emission standard and the installation of additional
control equipment. In such a case, the owner or operator shall obtain
a supplemental permit prior to the initiation of construction,
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installation, or alteration of such additional control equipment.
g. The issuance of a permit (approval to construct) shall not relieve any
owner or operator of the responsibility to comply fully with applicable
provisions of the state implementation plan and any other
requirement under local, state or federal law.
ENFORCEMENT
Iowa Code section 455B.138 states:
Resolution of violations — appeal.
1. When the director has evidence that a violation of any provision of
division II of this chapter or chapter 459, subchapter II, or rule,
standard, or permit established or issued under division II or chapter
459, subchapter II, has occurred, the director shall notify the alleged
violator and, by informal negotiation, attempt to resolve the problem. If
the negotiations fail to resolve the problem within a reasonable period
of time, the director shall issue an order directing the violator to prevent,
abate, or control the emissions or air pollution involved. The order shall
prescribe the date by which the violation shall cease and may prescribe
timetables for necessary action to prevent, abate, or control the
emissions of air pollution. The order may be appealed to the
commission. The applicable time frames for the issuance and appeal of
the order are defined in section 455B.110.
2. After the hearing on appeal, the commission may affirm, modify, or
rescind the order of the director.
3. The director shall keep a complete record of the hearings and
proceeding and the record shall be open to public inspection, subject to
section 455B.137. Upon request, a copy of the transcript shall be
furnished to the violator or alleged violator at the violator's or alleged
violator's expense.
4. An appeal to the commission under this section shall be conducted as a
contested case under chapter 17A.
Iowa Code section 455B.140 states:
Judicial review. Judicial review of actions of the commission or of the
director may be sought in accordance with the terms of the Iowa
administrative procedure Act, chapter 17A. Notwithstanding the terms of
said Act, petitions for judicial review may be filed in the district court of the
county in which the alleged offense was committed
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Iowa Code section 455B.146 states:
Civil action for compliance — local program actions. If any order, permit, or
rule of the department is being violated, the attorney general shall, at the
request of the department or the director, institute a civil action in any
district court for injunctive relief to prevent any further violation of the order,
permit, or rule, or for the assessment of a civil penalty as determined by the
court, not to exceed ten thousand dollars per day for each day such
violation continues, or both such injunctive relief and civil penalty.
Notwithstanding sections 331.302 and 331.307, a city or county which
maintains air pollution control programs authorized by certificate of
acceptance under this division may provide civil penalties consistent with
the amount established for such penalties under this division.
Iowa Code section 455B.146A states:
Criminal action — penalties. 1. A person who knowingly violates any
provision of division II of this chapter, any permit, rule, standard, or order
issued under division II of this chapter, or any condition or limitation
included in any permit issued under division II of this chapter, is guilty of an
aggravated misdemeanor. A conviction for a violation is punishable by a
fine of not more than ten thousand dollars for each day of violation or by
imprisonment for not more than two years, or both. If the conviction is for a
second or subsequent violation committed by a person under this section,
however, the conviction is punishable by a fine of not more than twenty
thousand dollars for each day of violation or by imprisonment for not more
than four years, or by both.
4. Project Discovery System
As a permitting program matures, it should have a comprehensive system in place for informing
potential applicants about the NSR permitting process and for assuring that the bulk of
applicants obtain permits prior to construction. "As built" permits, for example, are an
indicator of gaps in this discovery system.
1. What steps does your program take to inform sources of the need to obtain
permits prior to commencing construction?
The Iowa DNR has developed relationships with both the Association of
Business and Industry and Economic Development Authority and
frequently works with those organizations to provide assistance and
outreach to affected industrial categories and specific businesses. The
Iowa DNR gives presentations at different business or industry association
meetings. The Iowa DNR has also created a thorough website that
discusses the need for air construction permits and has several fact sheets
to assist facilities in determining which permits or requirements might apply.
Additionally, the Air Quality Bureau maintains a toll-free construction permit
assistance helpline to answer basic permitting questions and assist with
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application completion.
The Iowa DNR has created a business liaison that assists applicants with
all environmental permitting needs, including air quality. In addition, the
Iowa DNR participates in those meetings by providing assistance to those
companies that may need NSR permits.
Y m N ~ 2. Do you work with other agencies, for example economic development,
zoning, or code departments to learn about the potential for new projects?
If so, please describe.
The Iowa DNR frequently works with the Iowa Economic Development
Authority (I EDA) as they work with prospective businesses looking to locate
in Iowa.
Y [x] n ~ 3. Do you act on other information you might gather through newspaper
articles or other trade press announcements?
If so, please describe.
For prospective businesses, Construction Permitting staff will usually alert the
DNR business liaison about the article and see if they can find a contact to
reach out to the company to offer environmental permitting assistance. For
companies that have already started or completed construction, the local
DNR Field Office will usually be alerted so they can go on-site and provide
compliance assistance and follow-up.
B. Staff and Training
1. What is the total number of staff dedicated to permitting for your NSR
program? Please provide an organizational chart.
For questions 1 - 3 see organizational chart attachments.
2. For your NSR permitting program, please show a breakdown of staff by
different job functions (e.g., number of modelers, review engineers,
technicians, environmental scientists, clerical, supervisory, enforcement).
For questions 1 - 3 see organizational chart attachments.
3. Using the organizational chart provided above, please indicate the number
of years of experience for each person involved with the NSR permitting
program and summarize the total years of experience for your program.
For questions 1 - 3 see organizational chart attachments.
Y ~ N El 4. Does the department hire consultants or use other non-departmental staff
to assist in permitting activities?
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If yes, explain the scope of these activities including the types of projects
reviewed, the fraction of time spent as a percentage of total resources
dedicated to the state NSR program, the approximate cost to the
department and whether these costs are recovered through permit fees.
Y ~ N S 5. Does staff turnover affect the ability of the department to issue timely
permits?
If so, does the department have any initiatives underway to reduce the level
of turnover?
Y M N ~ 6. Is the NSR program fully funded and staffed?
If not, please indicate the current level of staffing (e.g. 80% staffed with 16
of 20 positions filled).
7. Please describe your training program for new and existing staff that work
on NSR permitting and issues. List any materials you use or training
courses you try to attend.
For the new employee training, please see the document titled Section
I.B._Question 7_New Employee Training Checklist. Existing engineering
employees are required to complete a minimum of five training classes
each year. A five-year development plan is created for each employee
taking into account their specific training needs and development goals.
Also, see response to question V.1.9 regarding modeling.
8. Describe any additional training that you believe would be beneficial.
Y [x] n ~ a- Would it be helpful if EPA provided more NSR training?
It would be helpful if EPA updated its existing training and provided
training on additional topics, especially NSR applicability and
NESHAP standards. See the document titled Section I.B._Question
8.a_Additional Training for more details on suggested training.
Y [x] N ~ 9. Do you provide NSR program training opportunities for the public, including
the regulated community?
If yes, please describe.
Annually, the Iowa DNR provides training to the public on a number of
topics based on current needs, and this includes NSR training. Most
recently Air Quality staff provided training on the Iowa Easy Air electronic
application system (4 training sessions in the past two years) and used this
training to provide training on the application process, including NSR
topics.
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The Iowa DNR also reviews recent NSR rule makings and guidance
documents and decides if training is needed for the public. If it is
determined it is necessary, the training will be provided either in person or
as a webinar. The Air Quality Bureau also has a biannual client contact
meeting. These meetings provide training on various permitting topics,
including NSR. In these meetings the regulated community and the public
are invited to attend via the Iowa DNR webpage and the AQ technical
listserv (over 23,000 people). This is often a good opportunity to provide
training on recent rule makings and guidance documents.
The Iowa DNR also develops a summary of important NSR topics or new
guidance and provides the regulated community with a fact sheet on our
website. These fact sheets contain staff contact information for further
information on these topics.
The Iowa DNR also provides ongoing training through its permitting
projects. Each project is an opportunity to teach the regulated community
about NSR topics that are relevant in the project. In depth explanations of
the concepts, relevant guidance, and rule requirements along with pertinent
reference documents are provided as part of these projects.
C. NSR Implementation
Y [x] N ~ 1- Do you implement EPA issued program guidance and policy for NSR?
If not, please explain.
Y m N ~ 2. Are you familiar with EPA's web-based NSR Policy & Guidance Database
(https://www.epa.gov/nsr/new-source-review-policy-and-guidance-
document-index) and do you use it? [NOTE: address updated by Iowa
DNR]
Y ~ N El 3. Does the department implement any NSR-related policies or guidance that
deviate substantially from EPA's?
a. If yes, do you seek peer review from staff, applicants, EPA and the
public when developing the policy or guidance document?
b. How do you make these documents available to staff, applicants,
EPA, and the public?
4. In general, how do you learn about rule changes in the Federal NSR
program?
DNR staff learn of rule changes through various mechanisms. These
include, but are not limited to:
• Monthly calls between EPA staff and DNR staff,
• Federal Register notice emails,
• National Association of Clean Air Agency (NACAA) calls which are
held typically monthly, and
• Central States Air Resource Agencies (CenSARA).
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YSND
a. Do you use EPA's website at http://www.epa.qov/nsr/ to monitor
NSR program changes and implementation issues?
D. Public Participation
1. What criteria are used to determine if a permit is public noticed?
Iowa DNR uses the criteria detailed in Iowa Administrative Code to
determine if a permit is publicly noticed. This criteria is specified in Iowa
Administrative Code at 567IAC33.3(17), 567IAC31.20(10), and
567IAC22.2(2).
2. Identify which of the following types of permits are noticed:
Y [x] |\| ~ a. PSD permits
Y lx] n ~ b. Major nonattainment NSR permits
Y [x] N ~ c' synthetic minor permits
NOTE: For proposed synthetic minor projects received by the Iowa
DNR only the applications are posted to the Webpage for
comment. All of the proposed synthetic minor projects are
available for public inspection and comment which are
directed to the applicable review engineer. A formal public
review period is made available upon request from the
public or other interested parties.
^, d. minor permits
y m n ~ K
NOTE: For proposed minor projects received by the Iowa DNR only
the applications are posted to the Webpage for comment.
All of the proposed minor projects are available for public
inspection and comment which are directed to the
applicable review engineer. A formal public review period
is made available upon request from the public or other
interested parties.
Y El N ~ 3. Do you publish notices on draft NSR permits in a newspaper of general
circulation?
The Iowa DNR publishes notices in a newspaper of general circulation in
limited circumstances. These circumstances include draft NSR permits that
affect NAAQS maintenance and nonattainment areas.
Y [x] N ~ 4. Do you use a state or other publication designed to give general public
notice?
If yes, please describe.
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EcoNewsWire Publication. EcoNewsWire is an electronic publication for
Iowa DNR environmental topics that is provided to news outlets, interested
subscribers and to social media outlets. In May of 2021, the
EcoNewsWire Publication was sent to approximately 42,000 subscribers.
Y [x] |\| ~ 5. Do you have procedures for notifying the public when major NSR permit
applications are received?
Yes, see attached public notice checklists used by the Iowa DNR to
determine the necessary notifications as part of the NSR review process.
Y [x] N ~ 6. Do you develop a mailing list of interested parties for NSR permit actions
(e.g., public officials, concerned environmentalists, citizens)?
Any interested parties may request to be added to the NSR mailing list.
This request may be submitted to the Iowa DNR as a verbal, written or
electronic communication request.
Y [x] N ~ 7. Aside from methods described above, do you use other means for public
notification?
If yes, what are they {e.g., post notices on your webpage, email)?
All proposed air construction permit applications (projects) received by the
DNR are posted to the Webpage in numerous locations such as the public
participation page (https://www.iowadnr.gov/Environmental-Protection/Air-
Quality/Public-Participation). All proposed projects are available for public
inspection and comment which are directed to the applicable review
engineer. Other electronic means of communication are also utilized to
inform the public such as email, AIR News, calendar of events and other
notification methods if needed.
Y [x] N ~ 8. Do your public notices clearly state when the public comment period begins
and ends?
9. What is your opinion on the most effective ways to provide public notice?
The Iowa DNR does not measure the effectiveness of its public notices or
compare alternative methods, so there is no empirical information to
provide.
Y ~ N lx] 10. Do you provide notices in languages besides English?
If yes, in which languages?
Y ~ N lx] 11. Have you ever been asked by the public to extend a public comment
period?
If yes, did you grant the extension?
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If not, please explain why you didn't grant the extension?
12. What percentage (approximately) of your major NSR permits are revised
due to public comments?
The Iowa DNR does not track this metric. It is estimated that less than five
percent are revised.
13. If a draft permit is revised, what criteria do you use to determine if a permit
should be re-issued in draft?
The Iowa DNR uses the criteria detailed in Iowa Administrative Code to
determine if a permit should be reissued as draft or may be issued as final.
If the permit revision is not considered an administrative amendment as
defined in 567 IAC 33.3(21) then the procedure defined in
567IAC33.3(17)"e" Reopening of the public comment period is followed.
567 IAC 33.3(17)"e" Reopening of the public comment period. If comments
are submitted during the public comment period raise substantial new
issues concerning the permit, the department may, at its discretion, take
one or the following actions:
(1) prepare a new draft permit, appropriately modified;
(2) prepare revised fact sheet; prepare a revised fact sheet and reopen
the public comment period; or reopen or extend the public comment
period to provide interested parties an opportunity to comment on
the comments submitted.
567 IAC 33.3(21) Administrative amendments. Upon request for an
administrative amendment, the department may take final action on any
such request and may incorporate the requested changes without providing
notice to the public or to affected states, provided that the department
designates any such permit revisions as having pursuant to subrule
33.3(21). "b" An administrative amendment is a permit revision that does
the following:
(1) Corrects typographical errors;
(2) Corrects word processing errors;
(3) Identifies a change in name, address or telephone number of any
person identified in the permit or provides similar minor
administrative change at the source; or
(4) allows for a change in ownership or operational control of a source
where the department determines that no other change in the
permit is necessary, provided a written agreement that contains a
specific date for transfer of the permit responsibility, coverage, and
liability between the current permittee and the new permittee has
been submitted to the department.
14. What type of comments or other concerns trigger a public hearing?
If requested by the public or interested parties, the Iowa DNR will provide
the opportunity for a public hearing. This information is provided as part of
the public notification process.
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15.
How are public hearings noticed?
Notification of public hearing is provided to the public through electronic
notification on Iowa DNR website, EcoNewsWire, email, Iowa Events
calendar or by certified letter if electronic means are not available. All
notifications of proposed public hearing are provided to all interested
parties.
a. How much notice is given?
As specified in Iowa Administrative Code, 567IAC33.3(17)(5), 30
day notification is provided prior to the proposed public hearing
date.
16. What is your process for the public to obtain permit-related information
(such as permit applications, draft permits, deviation reports, monitoring
reports) especially during the public comment period?
All information on the project and draft permits is available in the affected
areas, such at the local library, on the Iowa DNR website, and EASY Air
application portal. Compliance reports and other facility records are
available on the Iowa DNR electronic records system (DOCDNA) or
through the public records center.
Y [x] n ~ 17. Do you have a website for the public to get permit-related documents?
If yes, please answer the following:
a. What is available online?
b. How often is the website updated?
c. Is there information on how the public can be involved?
Y ~ N lx] 18. Do you provide training to citizens on public participation in NSR?
If yes, approximately how many training opportunities have been provided
in the last five years?
19. How do you notify affected States (including tribes) of draft major source
permits?
The Iowa DNR sends an email notification or by certified letter if electronic
means are not available.
Y [x] N ~ 20. Do public notices for PSD permits specifically state the amount of
increment consumed?
Y [x] N ~ 21. Are public notices for PSD permits sent to each party identified in 40 CFR
51.166(q)(2)(iv)?
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E. Program Benefits
Y [x] |\| ~ 1- In your opinion, is the NSR program (both PSD and nonattainment Major
NSR) an incentive to reduce emissions below major source levels?
In some circumstances it is. For example, if a business has a long range
business plan that does not include any significant changes in operation or
increases in volume, the facility may install additional controls to remain a
minor source.
YDN8 2. In your opinion, have NSR permits been used as the authority to implement
other priorities such as toxic emission reductions and improved monitoring
and reporting?
NSR permitting has not been used as the authority to implement other
priorities beyond ensuring that permits contain practicably enforceable
limits as to comply with applicable Clean Air Act regulations.
Y [x] n ~ 3. In your opinion, does the case-by-case nature of a NSR permit allow you to
implement emission reducing programs or controls more quickly than
rulemaking?
YDN8 4. In your opinion, does the NSR program provide communities a mechanism
to be involved in improving their own air quality?
Y S N ~ 5. In your opinion, has the PSD program contributed to sustaining good air
quality?
It not only sustains good air quality but assures that as better emission
reduction methods are developed and adopted by some, that other similar
projects must meet those standards also.
Y S N ~ 6. In your opinion, have the nonattainment Major NSR requirements
contributed to reducing emissions or avoiding emissions increases in
nonattainment areas?
II. Major NSR Permitting
a.
A. Applicability
1. Stationary Source Determinations
Y ~ N lx] 1. Do your SIP-approved rules define stationary source differently than 40
CFR 51.165 or 51.166?
If yes, please explain.
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Y lx] N ~ 2. When determining if emissions units are contiguous or adjacent, do you
assess whether emissions units under common ownership or control may
be a single stationary source regardless of the distance between the
emissions units?
If yes, please explain.
See "Single Source Discussion" after Question 4 for a complete discussion.
Y lx] N ~ 3. Do you assess facilities' financial, personnel, and contractual relationships
to determine common ownership or control?
Y IX] N ~ 4. Do you assess whether sources with different first two-digit SIC codes (i.e.,
emissions units not in the same industrial grouping) may qualify as
separate stationary sources?
Single Source Discussion:
DNR conducts a case-by-case analysis in those situations where the single
source status comes into question for NSR, Title V, and/or NESHAP. The
analysis considers all criteria (i.e. common control, SIC Code,
contiguous/adjacent). In addition, all relevant and current EPA rules and
guidance is used as part of the determination. Finally, in order to maintain
consistency in determinations, one senior engineer signs off on all single
source determinations.
When there is a question regarding the single source status, the process
followed is:
(1) A Single Source Questionnaire is sent to the company or
companies in question. A copy of the Single Source Questionnaire
is labeled "Section II.A._Questions 1-4_Single Source
Questionnaire".
(2) Once the Single Source Questionnaire is returned it is reviewed by
an engineer.
(3) The engineer drafts a determination using the single source memo
template. A copy of the template is attached as "Section
II.A._Questions 1-4_single source memo template".
(4) The draft determination is sent to the senior engineer for
approval. There could be some discussion between the senior
engineer and the permit writer.
(5) The company/companies are notified once the determination is
approved.
The questionnaire is updated after new rules and guidance has been
issued by EPA and there are no outstanding legal actions.
It should be noted that past single source determinations are not
reevaluated based on new guidance unless circumstances/operating
conditions have changed that would result in a reevaluation.
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2. PTE Calculations
1. How do you determine if emissions factors {e.g., AP-42) are acceptable for
NSR applicability purposes?
The Iowa DNR often uses emission factors to make emission estimates
because it may be the best source of information available. In all cases, the
Construction Permit staff reviews the emission factors and assesses the
appropriateness of the emission factor for the application. The Iowa DNR
understands even the best emission factor is an average of the considered
source tests.
This assessment is made by understanding the limitations in the emission
factors. This is accomplished by reviewing the information associated with
the emissions factor. For AP-42, this includes reading the associated
section for the source category. The data used to develop the emission
factor is also reviewed along with any supplemental information provided
(background documents). Specifically, the things considered are:
• Is the emission factor representative of the emission unit being
evaluated?
• What is the emission factor's rating/ranking?
• How many tests were done to develop the emission factor?
• What is the quality of the data collected (appropriate test methods
done, testing conditions etc.)?
• What is the age of the data?
• Were the source test data taken from many randomly chosen
facilities in the industry population?
• Is the source category population for the emission unit specific or
broad?
• What is the variability in sources tested and in emissions from the
unit itself?
• Were the operating parameters evaluated and similar to the current
case? If not, how will they affect the emissions?
The appropriateness for the application is assessed based on a review of
these factors.
Additional data, testing done at the site or in the state on similar units, or
information obtained from the manufacturer is often used to back up an
emission factor if it is determined that the emission factor is of insufficient
quality or not specific enough for the studied case. Material balance or
other engineering estimates may be performed. In addition, if the data is
not of sufficient quality or specific enough, a compliance margin is added to
the emission factor or additional testing is required.
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In addition, the use of the emission factor often depends on how close the
estimate is to an emission limitation or threshold. If the data shows it is well
below all applicable standards and thresholds it may be of enough quality
to use for the project. If the estimates are close, additional data or stack
testing would generally be required.
Y lx] N ~ 2. Does the department routinely require sources to document whether
emissions factors are appropriate and representative of emissions from the
actual emission unit being permitted?
If yes, how is this information documented in the permit record.
If no, please explain why such documentation is not made.
The Iowa DNR routinely requires sources to document whether factors are
appropriate and representative of emissions from the actual emission unit
being permitted. This information is then reviewed as part of our project
review using the procedures described in the previous question. A detailed
discussion on the use of any emission factors (source, appropriateness,
quality/limitations, derivation, etc.) is provided, as well as whether
additional testing is required for validation, in the project engineering
evaluation, which is required for each permit issued.
Y lx] N ~ 3. Do you include PM10 condensible emissions in the total amount of PM10
emissions when determining NSR applicability, BACT/LAER evaluations,
PSD increment consumption, and compliance with the NAAQS?
Y lx] n ~ a- When PM10 testing is required do you include a permit condition that
requires testing and specifies testing methods for PM10
condensibles?
3. Fugitive Emissions
1. Please provide your regulatory definition of "fugitive" emissions for major
NSR applicability purposes.
Per 567 IAC 33.3(1) Definitions, "Fugitive emissions" means those
emissions which could not reasonably pass through a stack, chimney, vent,
or other functionally equivalent opening.
Y8ND 2. Do you make a distinction between "fugitive" emissions and "uncontrolled"
emissions?
If yes, please explain.
As defined in the Iowa Construction Permit Manual, page 5-13,
"Uncontrolled emissions" are emitted while operating at the maximum
design capacity and absent any federally enforceable operating
restrictions. This means the unit is operating 8,760 hours per year without
any control equipment.
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Y lx] N ~ 3. Do you include fugitive emissions in major NSR applicability determinations
for new sources?
For PSD applicability determinations, fugitive emissions are included if the
source belongs to one of the the 28 listed source categories or source
categories subject to an NSPS or NESHAP promulgated prior to August 7,
1980, per 567 IAC 33.3(1), definition of a "Major source", paragraph
"3". Once a pollutant triggers PSD, all emissions are subject to BACT and
ambient air review.
Y lx] n ~ a- For modified sources?
Existing PSD major sources include fugitive emissions for PSD
applicability determinations, per 567 IAC 33.3(1), definitions of
"baseline actual emissions" paragraph 1(a) and 2(a), and the
definition of "projected actual emissions" paragraph 2. i.e., "The
average rate shall include fugitive emissions to the extent
quantifiable and emissions associated with startups, shutdowns,
and malfunctions"
YIND 4. Do you allow major sources to use reductions in fugitive emissions for
netting purposes?
If yes, please describe how you determine the fugitive emissions "baseline"
used for netting.
If allowed, it relies on the company having sufficient documentation
available to calculate previous actual emissions [for example, several silt
loading tests in conjunction with records of vehicle miles traveled (VMT)].
5. Please provide a description of your guidelines or calculation methodology
used to quantify fugitive emissions.
If there is a standard calculation method, such as AP-42 for estimating haul
road emissions, or EPA's Protocol for Equipment Leak Emission Estimates
(EPA-453/R-95-017) that is used, otherwise engineering judgement.
Y8ND 6. Do your permits contain conditions for fugitive emissions consistent with
requirements for BACT/LAER (i.e., specific emission limits, control
methods, and/or work practice standards)?
4. Debottlenecking/lncreased Utilization
Y8ND 1. When determining if proposed modifications are subject to major NSR, do
you include emissions increases from existing emissions units that are not
physically modified (i.e., units that will be debottlenecked or have increased
utilization such as boilers)?
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Y IX] N ~ 3
5. Netting
YIND 1
2
YIND 3
YDNI 4
YDNI 5
YDNI 6
What method is used to determine the emissions increase from these
emissions units?
Any emissions increase that is a result of the project is included in the NSR
determination. This includes unmodified units, debottlenecked units, and
increased utilization.
a. What EPA guidance do you consider for this issue?
EPA NSR database for debottlenecked sources
https://www.epa.gov/nsr/debottlenecked-sources. and the 1990
draft NSR workshop manual.
Do you train your permitting staff to include such emissions increases when
determining if a modification is major for NSR?
Is netting approved in your NSR SIP for determining whether modifications
at major stationary sources are subject to major NSR (PSD or
nonattainment Major NSR, as applicable)?
If not, please explain.
What is the contemporaneous time period for netting in your SIP?
As defined in 567 IAC Chapters 31 (567 IAC 31.3(1)) and 33 (567 IAC
33.3(1)), "Net emissions increase" is 5 years before construction on the
particular change commences and forward in time to the date that the
increase from the particular change occurs.
For determining the baseline from which emission reductions are
calculated, do you require the applicant to submit the actual emissions from
the units along with any permit limits that apply?
Do you allow an applicant to receive emission reduction netting credit for
reducing allowable emissions instead of actual emissions?
If yes, please explain.
Do you allow an applicant to receive emission reduction credit for reducing
any portion of actual emissions that resulted because the source was
operating out of compliance?
If yes, please explain.
Do you allow an applicant to receive emission reduction credit for an
emissions unit that has not been constructed or operated?
If yes, please explain.
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Y ~ N lx] 7. Are emissions reductions to meet MACT requirements eligible for netting
credits?
If yes, under what conditions? (See EPA's November 12, 1997 memo from
John Seitz entitled "Crediting of Maximum Achievable Control Technology
(MACT) Emission Reductions for New Source Review (NSR) Netting and
Offsets".)
Y lx] N ~ 8. When any emissions decreases are claimed as part of a proposed
modification, do you require that all stationary, source-wide, creditable and
contemporaneous emissions increases and decreases of the pollutant be
included in the major NSR applicability determination?
If not, please explain.
9. To avoid "double counting" of emissions reductions, what process do you
use to determine if emissions reductions considered for netting have
already been relied upon in issuing a major NSR permit for the source?
The Iowa DNR conducts a complete facility review to determine if emission
reductions have been relied upon in issuing a NSR permit.
Y ~ N IX] 10. Do you have a process to track projects that use credits to net out of major
NSR?
If yes, please explain.
Y IX] N ~ 11. Do you require that emissions reductions (e.g., reductions from unit
shutdowns) must be enforceable to be creditable for netting?
If not, please explain.
Y ~ N IX] 12. Have you had public concerns regarding the netting analysis and
procedures used for any issued permits that avoided major NSR?
If yes, please describe.
Y ~ N IX] 13. Do you allow inter-pollutant trading when netting (e.g., allow a source to
use NOx or PM credits for netting out of VOC increases)?
If yes, please explain.
14. What process do you have to verify that a source's emissions reductions
considered for netting, including emissions reductions that may have been
"banked," are not already used by the source, or another source, as
nonattainment Major NSR offsets?
The Iowa DNR conducts a complete facility review to determine if emission
reductions have been relied upon in issuing a NSR permit.
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B. Prevention of Significant Deterioration (PSD) Permitting
1. BACTDeterminations
Y lx] N ~ 1. Do you require permit applicants to use the "top-down" method for
determining BACT?
If no, what approach do you require?
Y lx] N ~ 2. Do you commonly use information resources other than the
RACT/BACT/LAER Clearinghouse to identify control options, costs, etc.?
If yes, what resources do you commonly use and rate the usefulness of
each one?
The RACT/BACT/LAER Clearinghouse (RBLC) has several issues which
limits the reliability and usefulness of the information contained within the
RBLC. These issues are well known by all agencies, including EPA, so
they will not be discussed here. Due to these issues, the DNR staff have to
use other resources which include:
(a) Internet research of process equipment and control equipment
used around the world,
(b) Vendor information on control equipment (technical specifications
and cost),
(c) Review of permits from other states (both major and minor), and
(d) Discussion with other regulatory agencies, including other
countries.
The usefulness of each of these depends on the project and the type of the
equipment. For example, when permitting was done for the nitrogen
fertilizer plants, vendor information and internet research was the best
source since there hadn't been a new fertilizer plant in the US in about 30
years. On the other hand equipment such as coal-fired boilers, Selective
Catalytic Reduction (SCR), etc. are more common so discussion with other
agencies and internet review can provide all of the necessary information.
Y IX] N ~ 3. Do you provide a detailed documentation/explanation of draft BACT
determinations in the public record?
Y IX] N ~ 4. In your public record for draft BACT determinations, do you provide an
economic rationale if a BACT option is rejected as being prohibitively
expensive?
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5. What procedures do you use to calculate baseline emission rates for
calculation of cost effectiveness values?
The Iowa DNR guidelines instruct applicants to determine baseline
emissions by calculating the upper bound uncontrolled emissions which is
based on EPA's October 1990 Draft New Source Review Workshop
Manual. The DNR recommends an applicant use one of the following
methods for calculating emissions:
(a) Continuous emissions monitoring system (CEMS)
(b) A stack test
(c) Material or mass balance
(d) Emission limits and test data from EPA documents, including
background information documents for New Source Performance
Standards (NSPS), National Emission Standards for Hazardous Air
Pollutants (NESHAP), and Section 111 d standards
(e) Emission factors from technical literature
(f) Information from comparable sources
(g) EPA or State approved emission factors
(h) Vendor supplied emission factors or emissions data
(i) Engineering estimation.
The applicant is required to submit supporting documentation regardless of
the method used.
a. What do you view as "uncontrolled" emissions?
Uncontrolled emissions for the purpose of a BACT review are
emissions emitted without consideration of the application of control
equipment, NSPS/NESHAP requirements, or other controls
necessary to comply with State or local regulations.
However, inherently lower polluting processes and inherent physical
or operational controls can also be considered with appropriate
documentation. Examples include a natural gas boiler considering
only natural gas combustion or a painting process only using low
VOC paints.
Y lx] N ~ 6. Do you consider combinations of controls when identifying and ranking
BACT options (e.g., low organic solvent coatings plus thermal oxidation)?
7. Do you ever re-group the emissions units included in a cost evaluation in
either of the following ways?
Y |x] N ~ a. If an applicant's approach is to evaluate the cost of controlling each
unit separately, do you ever consider combining units for control by
one control device?
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Y |x] N ~ b. If an applicant combines all units for control by one control device
and concludes this approach is too expensive, do you ever consider
controlling individual units or a small group of units that have the
greatest percentage of total emissions?
Y lx] N ~ 8. Do your PSD permits specify emissions limits and control methods
consistent with the basis (and capabilities) of the selected BACT options?
9. How do you establish the compliance averaging times for BACT emissions
limits?
BACT averaging times are established on a case-by-case basis. The
following is an excerpt from the Iowa Air Quality Bureau Construction
Permitting Manual:
"An averaging time is critical for an emission limit. Without a specified
averaging time the listed number is merely an emission rate. For
example, 1.5 Ib/hr does not have an hourly or instantaneous averaging
time unless such an averaging period is assigned to it. Without an
averaging time an emission limit is not enforceable as a practical
matter.
The purpose of the averaging time is to match the limit to the impact
(e.g., SO2 emissions to health impacts) or to ensure compliance. EPA
has stated in guidance that it wants potential violations to be frequent
enough to deter noncompliance. EPA believes that one violation a year
(such as a ton per calendar year limit) is not enough. Once per month
is the minimum considered effective by EPA. Therefore, the form of the
limit, including the averaging time must result in at least potential
monthly violations.1
Various factors weigh in favor of allowing a long term rolling average
such as historically unpredictable emissions. Other factors may weigh
in favor of a shorter term limit such as the inability to set interim limits
during the first year or no ability to continuously track emissions. The
engineer must make a determination as to what monitoring and
averaging period is warranted for the particular emission unit/emission
point in light of how close the allowable emissions would be to the
applicability threshold.2
EPA has several policy memos that state determinations allowing an
annual rolling average versus a shorter term limit must be made a on a
case-by-case basis. Those memos are:
o "Guidance on Limiting Potential to Emit," June 29, 1992,
o "Use of Long Term Rolling Averages to Limit Potential to Emit,"
from John Rasnic to David Kee, February 24, 1992, and
1 This policy was explained in a March 13, 1987 memo from John Seitzto Bruce Miller of Region IV.
2 "Guidance on Enforceability Requirements for Limiting Potential to Emit through SIP and §112 Rules
and General Permits " Kathie A. Stein; January 25, 1995.
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o "Policy Determination on Limiting Potential to Emit for Koch
Refining Company Clean Fuels Project," from John B. Rasnicto
David Kee, March 13, 1992."
Y lx] N ~ 10. Do you make sure that permit conditions impose restrictions consistent with
BACT evaluation assumptions? (e.g., if the annual emissions used in a
BACT cost evaluation are based on an assumption of less than continuous
operation and/or operation at less than maximum capacity, do permit
conditions contain limits based on the assumption used?)
2. BACT Cost Evaluations
Y ~ N lx] 1. Do you allow deviation from EPA's recommended cost evaluation
procedures?
If yes, please explain.
2. Do you place primary reliance on total or incremental cost effectiveness
values?
The Iowa DNR primarily relies on total cost effectiveness.
a. If you give greatest (or equal) weight to incremental costs, what is
your basis for doing so?
3. Do you place primary reliance on a comparative cost approach or a
"bright line" test?
A comparative cost approach looking at previous determinations.
Y ~ N IX] 4. If you place greatest importance on a comparative cost approach, do you
try to obtain cost data for projects outside your permitting jurisdiction?
5. If you use what can be described as a "bright line" test, what is the basis of
your "bright line" cost effectiveness value and do you change the value
over time to account for inflation?
Y IX] N ~ 6. Do you use a different cost approach for different pollutants?
If yes, please explain.
The Iowa DNR considers a different cost effectiveness value for
greenhouse gas (GHG) emissions than what is used for criteria pollutants.
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7. Under what circumstances do you conduct a BACT cost evaluation
independent of the cost evaluation provided by the applicant? (An
independent evaluation could entail obtaining additional vendor quotes.)
If the Iowa DNR requires additional documentation (such as vendor
quotes), a request is made for the company provide the additional
documentation. Examples of these types of requests include, but are
limited to:
• An applicant's cost evaluation relies the Office of Air Quality
Planning and Standards (OAQPS) Cost Control Manual or other
such documents instead of actual vendor quotes
• The estimated cost per ton of pollutant removed is on the upper end
of what the Iowa DNR considers economically feasible, based on
previous determinations.
Y ~ N lx] 8. Are cost estimates required to be referenced to a common base year (e.g.,
1998) so that cost estimates can be easily compared?
Y ~ N lx] 9. Are other agencies contacted to determine if their cost estimates need to
be normalized before comparisons can be made?
Y IX] N ~ 10. Do you perform a BACT assessment for all new/modified emissions units
or activities emitting a pollutant subject to PSD review, no matter how small
the emissions from an affected unit or activity?
Y IX] N ~ 11. Do you consider increases or decreases in corollary toxic/hazardous air
pollutants as part of a BACT evaluation? [This question addresses
implementation of EPA's "North County Resource Recovery Remand"
memo dated September 22, 1987.]
If yes, please give a specific example.
The Iowa DNR does not have a specific example from the last five years,
but in the past, the Iowa DNR has asked companies to look at specific
alternative controls, or choose between two alternatives that have similar
cost and technological effectiveness, but different environmental impacts.
Y IX] N ~ 12. Do you provide BACT evaluation training to new (or newly-assigned) new
source review (NSR) permitting staff (other than on-the-job training)?
If yes, describe the nature of the training provided.
Several of the Construction Permitting staff have attended a class (BACT
Workshop) in the past, but based on an online search it does not appear
this class is available as a standalone class any longer.
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Y lx] N ~ 13. Do you provide BACT evaluation refresher training to experienced NSR
permitting staff?
If yes, how frequently do you provide this training and what is the nature of
the training provided?
As noted above the BACT Workshop class does not appear to be available
as a standalone class, but is part of the various NSR classes available.
Staff are encouraged to take training classes as they become available.
Y ~ N lx] 14. Do you provide an information outreach program on BACT evaluations for
owners of regulated sources?
If yes, how frequently do you provide such information and how do you
provide it?
Y ~ N IX] 15. Do you provide an information outreach program on BACT evaluations to
the public?
If yes, how frequently do you provide such information and how do you
provide it?
Y IX] N ~ 16. Do you enter each BACT determination in the RACT/BACT/LAER
Clearinghouse?
Y IX] N ~ 17. Before establishing BACT as work practice, design, or operational
standards, do you determine that emissions limits (e.g., Ibs/mmBTU, Ibs/hr)
are not feasible?
If no, please explain.
Y IX] N ~ 18. Do you apply BACT to fugitive emissions?
If no, please explain.
3. Additional Impacts (soils, vegetation, visibility, growth)
Y ~ N IX] 1. Do your PSD application forms specifically require information regarding
additional impacts?
If yes, include a copy of the forms.
Y IX] N ~ 2. If no, do you require applicants to submit sufficient information necessary to
complete an additional impact analysis?
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3.
What resources do you use for researching additional impacts?
The Iowa DNR expects applicants to conduct a document search as part of
the evaluation and the Iowa DNR staff reviews the references provided.
The Iowa DNR has a tool for evaluating the impact on soils and vegetation
that is based on the following documents from EPA:
• "A Screening Procedure for the Impacts of Air Pollution Sources on
Plants, Soils, and Animals"
• "Air Quality Criteria for Oxides of Nitrogen"
The Iowa DNR also provides a tool that automates the level 2 screening
procedures described in the VISCREEN manual. All of these references
and tools are available on the Iowa DNR website at
https://www.iowadnr.gov/Environmental-Protection/Air-
Quality/Modeling/Dispersion-Modeling
Y ~ N lx] 4. Do you include environmental justice issues in your analysis?
Y ~ N lx] 5. Has an additional impact analysis in the last 5 years been a cause for
concern in an issuance of a PSD permit?
If yes, please explain.
Y ~ N IX] 6. Do you generally allow arguments that the protection of the NAAQS will
assure protection of vegetation?
If yes, please explain.
Sometimes applicants will state this in the report, but arguments that
protection of the NAAQS will assure protection of vegetation alone is not
sufficient.
Y IX] N ~ 7. Do you require that predicted short-term impacts (e.g., one hour NOx
impacts) be used to assess impacts on vegetation for pollutants which do
not have short term ambient standards?
If no, please explain.
This is included in the Iowa DNR's Soils and Vegetation tool, available on
the Iowa DNR website here at https://www.iowadnr.gov/Environmental-
Protection/Air-Qualitv/Modeling/Dispersion-Modeling
Y IX] N ~ 8. Regarding visibility impacts, do you require assessments for vistas (e.g.,
parks, airports) near the proposed source or modification?
If no, please explain.
The Iowa DNR typically picks the nearest airport and state park and ask
applicants to evaluate those. More could be selected if there are a large
number in the area.
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4. Preconstruction Monitoring
Y lx] N ~ 1. Do you have formal preconstruction monitoring requirements?
The requirements are described in Iowa DNR's PSD Modeling Guidelines
and require applicants to use either existing data (with justification) or
establish site-specific monitoring network. The guidelines are available on
the Iowa DNR website at https://www.iowadnr.gov/Environmental-
Protection/Air-Quality/Modeling/Dispersion-Modeling
Y lx] N ~ 2. Do you have a formal public participation process regarding requirements
for preconstruction monitoring for specific proposed projects?
This would be part of the public comment period for the project.
Y ~ N IX] 3. Have you ever consulted with the Federal Land Manager (FLM) regarding
preconstruction monitoring requirements for a proposed source or
modification?
Generally no, due to the State of Iowa's distance from surrounding Class I
areas, but the FLMs were contacted the last time the Iowa DNR received
an application for a new coal-fired power plant (NOTE: this facility was
never permitted)
Y ~ N IX] 4. In the last five years have you ever required an applicant applying for a
PSD permit to conduct preconstruction ambient monitoring or
meteorological monitoring?
Y ~ N IX] 5. Do you have a formal approval/denial process at the conclusion of
preconstruction monitoring?
Not at this time. A process would be developed on a case by case basis if
preconstruction monitoring was required.
Y ~ N IX] 6. Do you have a formal process during preconstruction monitoring for
resolving conflicts between the FLM and the applicant?
If yes, please explain.
Y IX] N ~ 7. Do you routinely provide ambient monitoring data in lieu of requiring
applicants to perform preconstruction monitoring?
If yes, please briefly describe the monitoring network used and the basis for
the monitoring value selected.
Refer to the Background Concentration TSD, available here:
https://www.iowadnr.gov/Environmental-Protection/Air-
Qualitv/Modeling/Dispersion-Modeling/Background-Data
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Y lx] N ~ 8. Do you follow EPA guidance {e.g., siting, equipment, data validation,
audits) regarding collection of preconstruction monitoring data?
9. Under what circumstances would you require post construction ambient
monitoring as a condition of a PSD permit?
A determination regarding post-construction monitoring is made by the
permit writer on a case-by-case basis. The Iowa DNR's "Air Dispersion
Modeling Guidelines for PSD Projects" states:
EPA's Ambient Monitoring Guidelines for Prevention of Significant
Deterioration (May 1987), recommends post construction monitoring be
done when there is a valid reason, such as when predicted
concentrations are close to the NAAQS and when there are
uncertainties in the data modeled. A decision by permitting staff to
require post-construction monitoring would be made after the PSD
application has been thoroughly reviewed.
The document can be found at https://www.iowadnr.gov/Environmental-
Protection/Air-Qualitv/Modelinq/Dispersion-Modelinq#249516-psd-
modelinq-quidance.
The Iowa DNR has not required post-construction monitoring in the last five
years. In the past post-construction monitoring has been required if there
were no monitors from the existing monitoring network nearby and/or the
predicted concentrations were close to the NAAQS.
C. Nonattainment Major NSR Permitting
The State of Iowa currently has one non-attainment area located in Muscatine, Iowa for the
1-hr SO2 standard. The Iowa DNR has not conducted a major nonattainment NSR
permitting project since 2000. Therefore, the Iowa DNR does not have contemporaneous
information regarding these questions at this time.
1. Offsets
Y ~ N ~ 1.
Y ~ N ~ 2.
Y ~ N ~ 3.
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Do you have an emissions "bank" for offsets?
If no, go directly to 10.
Is the bank a database used for emissions trading?
If yes, please explain how the trading works.
Do you, as the reviewing authority, control the trading of credits in the
"bank"?
If no, who controls the trading?
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Y ~ N ~ 4. Are the credits certified "creditable" (including surplus for attainment
planning purposes and other Clean Air Act requirements) by you at time of
entry into the bank?
Y ~ N ~ 5. Are the credits evaluated and certified "creditable" (including currently
surplus) at the time of withdrawal and use?
If not, please explain.
6. How long are the "offsets" valid from time of reduction?
Y ~ N ~ 7. Are the banked credits included in the attainment demonstration and
inventory as "real emissions" (i.e., emissions being emitted into the air)?
Y ~ N ~ 8. Are the banked credits used for NSR offsets only?
If not, what are the other uses?
Y ~ N ~ 9. Are the banked credits discounted with time?
If yes, please explain the discounting procedures.
10. How do you determine that the reductions being used are properly included
in the attainment demonstration?
Y ~ N ~ 11. Are the emissions reductions available for NSR offsets only allowed from
the same nonattainment area as the proposed source or modification?
If not, please explain.
12. What procedures do you use to determine the baseline to quantify the
reductions?
a. How do you quantify the amount of creditable reduction?
Y ~ N ~ 13. Are the records for determining actual emissions available for review by
you?
Y ~ N ~ 14. Are copies of permits required as part of the permit application to determine
if the reductions from other sources being proposed as NSR offsets are
federally enforceable?
15. How do you verify that the reductions proposed for NSR offsets are
"surplus" to other Clean Air Act requirements and are "real," (i.e.,
reductions in emissions that were actually emitted into the air)?
16. What process do you use to verify that the reductions were not used in a
previously issued permit?
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Y ~ N ~ 17. Do you allow inter-pollutant trading for NSR offsets?
If yes, please describe this trading procedure (e.g., pollutants allowed, ratio
of reductions required, eligibility criteria, etc.).
Y ~ N ~ 18. For serious and severe ozone nonattainment areas do you allow "internal
offsets" instead of lowest achievable emissions rate (LAER)?
If yes, what is the offset ratio?
Y ~ N ~ 19. Do you allow credits used for netting to be used as nonattainment Major
NSR offsets?
Y ~ N ~ 20. Do your nonattainment Major NSR rules require the offset ratios prescribed
in the Clean Air Act?
If no, please explain what other ratios are used?
Y ~ N ~ 21. Do you require that applicants proposing to use NSR offsets include a "net
air quality benefit" modeling analysis as part of their permit application?
If yes, please describe what information is required.
2. LAER Determinations
Y ~ N ~ 1. Do you require permit applicants to use a top-down approach to determine
the most stringent control option available for LAER?
If not, what approach do you require?
Y ~ N ~ 2. Do you require a permit applicant to identify all available control options?
If yes, do you require the applicant to identify control options as being:
Y ~ N ~ a- Achieved in practice?
Y ~ N ~ k- Contained within the SIP of any other state or local reviewing
authority?
YDND c. Technologically feasible?
Y ~ N ~ d. Cost effective?
Y ~ N ~ 3. Do you use information sources other than the RACT/BACT/LAER
Clearinghouse to identify control options?
If yes, please describe what information sources you commonly use and
the usefulness of each?
4. Please describe under what circumstances you would conduct a l_AER
analysis independent of the analysis conducted by the permit applicant.
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Y ~ N ~ 5. Do you submit your LAER determinations to the EPA's RACT/BACT/LAER
Clearinghouse?
Y ~ N ~ 6. Do you consider technology transfer in your LAER determinations?
7. If you consider cost effectiveness in l_AER determinations, please describe
the procedures used. (For example, describe the procedures used to
calculate the baseline emission rate in the cost effectiveness
determination.) For each criteria pollutant, provide the dollar/ton threshold
used to determine whether a control option is cost effective (and state
whether this is total or incremental cost).
Y ~ N ~ 8. Do you use a different cost approach for different pollutants?
If yes, please explain.
Y ~ N ~ 9. Do you provide detailed documentation or explanations of proposed LAER
determinations in the technical support document (TSD) or public record?
Y ~ N ~ 10. Do you provide an economic rationale in the TSD or public record if a
LAER option is rejected as being prohibitively expensive?
Y ~ N ~ 11. Do you consider combinations of controls when identifying and ranking
LAER options?
Y ~ N ~ 12. Do you perform a LAER assessment for all new/modified emission units or
activities emitting a nonattainment pollutant subject to major NSR review no
matter how small the emissions from an affected unit or activity?
13. Please describe how your LAER analysis includes "time of' considerations?
(For example, if a new or modified source had constructed without a permit
and at a later time went through nonattainment Major NSR review, would
you consider LAER at the time of permit issuance or at the time of emission
unit construction/ modification?)
Y ~ N ~ 14. Do your permits contain conditions requiring specific emission limits/
control method conditions/work practice standards consistent with the basis
(and capabilities) of the selected LAER option?
15. Please describe how you establish compliance averaging times for LAER
emission limits.
Y ~ N ~ 16. Do your permits contain conditions requiring emissions testing, monitoring,
recordkeeping, and reporting so that inspectors and enforcement personnel
can easily determine compliance with LAER requirements?
If not, please explain.
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Y ~ N ~ 17. Do you ensure that permit conditions impose restrictions consistent with the
LAER determination? (For example, if emissions used in the LAER
determination are based on an assumption of less than continuous
operation and/or operation at less than maximum capacity, do permit
conditions contain limits/restrictions based on the assumptions used?)
18. Please describe how you incorporate public comments into your LAER
determinations.
Y ~ N ~ 19. Do you provide LAER evaluation training to new (or newly-assigned) NSR
permitting staff other than on-the-job training?
If yes, please describe the nature of the training provided.
Y ~ N ~ 20. Do you provide LAER evaluation refresher training to experienced NSR
permitting staff?
If yes, how frequently do you provide this training and what is the nature of
the training provided?
Y ~ N ~ 21. Do you provide an information outreach program on LAER evaluations for
owners or operators of regulated sources?
If yes, how frequently do you provide such information and how do you
provide it?
Y ~ N ~ 22. Do you provide an information outreach program on LAER evaluations to
the general public?
If yes, how frequently do you provide such information and how do you
provide it?
3. Alternatives Analysis
Y ~ N ~ 1. Does each nonattainment Major NSR permit action address the
alternatives analysis as required by section 173(a)(5) of the Clean Air Act?
Y ~ N ~ ^ yes, is this alternatives analysis a specific requirement of your
nonattainment Major NSR rules?
Y ~ N ~ 2. Do you have criteria that would address the depth of analysis required for a
specific project?
Y ~ N ~ 3. Do you include project-specific environmental justice issues that are raised
as part of this analysis?
Y ~ N ~ 4. Do you know of any projects where this analysis resulted in changes to
proposed projects?
If yes, what changes resulted?
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4. Compliance
Y ~ N ~ 1. Do you require the permit applicant to demonstrate that all major stationary
sources owned or operated by the applicant in your State are subject to
emission limitations and are in compliance, or on a schedule for
compliance, with all applicable emission limitations and standards?
2. Please describe the following:
a. the criteria used by an applicant in a statewide compliance
demonstration
b. when in the permitting process you require the applicant to make
the statewide compliance demonstration.
Y ~ N ~ 3. Do you include project-specific environmental justice issues that are raised
as part of this analysis?
Y ~ N ~ 4. Do you know of any projects where this analysis resulted in changes to
proposed projects?
If yes, what changes resulted?
III. NSR Avoidance
b.
A. RMRR (Routine Maintenance, Repair and Replacement) exemption
Y lx] N ~ 1. Do you have knowledge of:
(a) the EPA letter dated May 23, 2000, to Henry Nickel of Hunton &
Williams concerning Detroit Edison and
(b) the Wisconsin Electric Power Company (WEPCO) case RMRR
documents?
2. What other documents do you rely upon when making RMRR exemption
determinations?
In addition to WEPCO, the DNR used the following court cases to develop
a list of questions it asks companies requesting an RMRR determination:
• United States v. Southern Indiana Gas and Electric Company
(Southern District of Indiana, February 13, 2003)
• United States v. Ohio Edison (Southern District of Ohio, 2003)
• United States, et al., v. Duke Energy Corporation (Middle District of
North Carolina, 2003)
• United States, et al., v. Cinergy Corp. (Southern District of Indiana,
2007)
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The WEPCO decision and the listed court cases were also used to develop
guidance for staff when considering a company's answer to each question.
Y lx] N ~ 3. Do you have a formal protocol for making RMRR exemption
determinations?
If yes, describe the protocol.
The DNR has an RMRR Questionnaire (See attachment titled "Section
III.A._Questions 1-11_RMRR Questions) that is sent to a company
requesting a determination. The questions can also be found on the
internet at:
https://www.iowadnr.gov/Environmental-Protection/Air-
Qualitv/Construction-Permits/Construction-Permittinq-Materials#258778-
psdcomplex-permits
Their request then goes through our normal permitting process. The
reviewer uses a 2010 RMRR memo to assess the request. The 2010
memo was written to provide guidance for DNR staff on each question
asked in the RMRR Questionnaire. The guidance was written based on the
WEPCO decision and the court cases listed in Question 2. See the
attachment titled "Section III.A._Questions 1-11_2010 RMRR Guidance
Memo.
It should be noted that all factors (nature & extent, purpose, frequency, and
cost) are considered equally and no more weight is provided to one factor
over another.
Each RMRR decision is brought to the attention of EPA Region VII on
monthly calls with the regional office in addition to any discussions while
the project is under review.
4. Approximately how many formal RMRR exemption determinations have
you made in the last five years?
The DNR does not specifically track RMRR determinations, but based on
discussions with the staff it is less than five over the last five years.
As discussed in Question 3 of this section each RMRR decision is brought
to the attention of the regional office. Also, it is worth noting that an RMRR
determination is rarely needed by a company as the use of Baseline Actual
Emissions (BAE) to Projected Actual Emissions (PAE) is a simpler process.
a. Using any one such determination as an example, describe the
example, state the conclusion you reached, and discuss how you
reached the conclusion.
Northern Natural Gas Company requested an RMRR determination
under NSPS Subparts GG and KKKK concerning a turbine core
changeout performed at one of its compressor stations.
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The process described in Question 3 was followed for this review
and EPA Region VII was provided an opportunity to comment on
the draft determination.
It was determined that the combustion core changeout was not
considered routine maintenance, repair, or replacement. The
following materials from that determination are attached:
• RMRR determination letter (Section III.A._Question
4.a._RMRR determination)
• Engineering Evaluation (Section III.A._Question 4.a._RMRR
evaluation)
• Northern Natural Gas Company's questionnaire answers
(Section III.A._Question 4.a._Northern Natural Gas
Questionnaire Answers)
Y lx] N ~ 5. Do you keep documentation of formal RMRR exemption determinations?
All permits, determinations, and documentation related to those decisions
are placed in the records maintained by the DNR.
Y lx] N ~ 6. Do you restrict the RMRR exemption to units being modified and exclude
replacement of entire units from RMRR exemption consideration?
Y ~ N IX] 7. Regarding the "purpose" evaluation factor in an RMRR exemption
evaluation, do you exclude projects from the RMRR exemption that result
in an increase in production capacity?
The DNR does not specifically exclude projects that result in an increase in
production capacity from requesting an RMRR determination. However, an
increase in the production capacity would indicate the project is not
routine. This is discussed in the internal DNR guidance memo ("Section
III.A._Questions 1-11_2010 RMRR Guidance Memo).
8. Regarding the "frequency" evaluation factor in an RMRR exemption
evaluation, which of the following do you consider:
Y IX] N ~ a. the history of the specific unit(s) in question.
Y lx] n ~ b. the history of other similar units at the same facility.
Y ixi N ~ c. the history of similar units at other facilities in the same industry,
d. some combination of these histories.
Y K N ~
Please see the internal DNR guidance memo ("Section III.A._Questions 1-
11_2010 RMRR Guidance Memo) on how the frequency factor is reviewed.
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9.
Regarding the "cost" evaluation factor in an RMRR exemption evaluation,
what procedure do you follow to take cost into account?
As is discussed in the internal DNR guidance memo ("Section
III.A._Questions 1-11_2010 RMRR Guidance Memo), the DNR evaluates
whether the funding is:
• A capital expenditure vs. operation & maintenance (O&M) and
• Capitalized vs. expensed.
As is discussed in the memo, projects that fall under normal O&M budgets
and are expensed tend to be routine in nature while projects that are part of
a capital expenditure budget and are capitalized are typically not routine.
Y ~ N lx] 10. Do you provide RMRR exemption evaluation training to NSR permitting
staff employees (other than on-the-job training)?
If yes, describe the nature of the training provided.
Y ~ N lx] 11. Do you provide an information outreach program on RMRR exemption
evaluations for owners of regulated sources?
If yes, how frequently do you provide such information and how do you
provide it?
The DNR does not provide an information outreach program on RMRR
mostly due to the very limited number of projects. However, as mentioned
above, the DNR RMRR Questionnaire is available online and if a company
wishes to pursue an RMRR determination, the staff will devote as much
time as necessary to answer questions and explain its determination.
B. PCP (Pollution Control Projects) Exemption
NOTE: Federal pollution control project (PCP) exemption rules and policies were vacated
by the U.S. Court of Appeals for the District of Columbia as of June 24, 2005. Please
address the following questions for projects approved prior to this decision.
The Iowa DNR has not use the PCP exemption since the vacatur by the Court. The
answers supplied below are based on the Iowa DNR practices prior to the vacatur.
Y [x] N ~ 1 ¦ Do you have standard permitting procedures or rules that allow for certain
changes at non-utility emissions units to be designated as PCP, which are
excluded from major NSR?
The DNR did have PCP procedures until the Court vacated the PCP
exemption. It is believed that no non-utility emission units used the option
while it was available.
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2. How many PCP exclusions have been granted for "feed" or "fuel" switches?
PCP projects for the Iowa DNR appear to have been limited to utility boilers
adding NOx controls such as low-NOx burners, overtired air, or combustion
controls.
3. What process do you use to determine if the project is "environmentally
beneficial" and not just "economically efficient"?
The project in question had to meet the following criteria:
(1) The project could not render the unit less environmentally
beneficial,
(2) The pollution control project would not result in a significant net
increase in representative actual annual emissions of any criteria
pollutant over levels used for that source in the most recent air
quality impact analysis in the area conducted for the purpose of
Title 1, and
(3) The increase would not cause or contribute to a violation of any
national ambient air quality standard (NAAQS) or PSD increment, or
visibility limitation.
4. How are the collateral emission increases evaluated? Do you require a
modeling analysis to demonstrate insignificant impacts from emissions
increases?
Modeling was required if any emissions increased over the PSD significant
threshold for the criteria pollutant in question.
5. How do you handle collateral increases in hazardous air pollutants (HAP)?
The Iowa DNR did not have a state toxic air pollution program at that
time. Currently, all HAPs are regulated through the National Emission
Standards for Hazardous Air Pollutants (NESHAP).
Y ~ N El 6. Are the emission reduction credits from PCP available for netting or NSR
offsets? Please explain.
The projects involved were initiated as a result of the requirements to lower
NOx emissions under the 1990 Clean Air Act Amendments, and are
therefore not available for credit.
7. Which add-on control devices are most frequently involved in PCP
exclusion requests?
The most common project was the installation of Low-NOx burners.
Another company (Alliant Energy) permitted projects for six of its facilities
which involved the addition such things as wind box air flow adjustments,
improved burner and/or combustion controls, coal feed modifications, etc.
It should be noted four of the facilities permitted for the change did not
make the allowed changes.
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8. Which types of industrial sources typically request PCP exclusions from
major NSR?
When the Iowa DNR permitted pollution control projects it was typically for
boilers at utilities.
Y ~ N El 9. Does your NSR SIP include the PCP exclusion for electric utility steam
generating units (often referred to as the WEPCO exclusion)?
The Court vacatur of the PCP exemption led to the SIP being rewritten to
remove that option.
C. Circumvention/Aggregation
Y lx] N ~ 1. When you review a modification to determine if it is major for NSR, do you
consider aggregating prior minor emissions increases at the stationary
source?
2. Please provide any criteria you may use to determine if a series of minor
modifications or projects needs to be aggregated for NSR applicability
purposes?
In the past the Iowa DNR had evaluated the aggregation of projects based
on EPA guidance using a combination of timing and technical factors. The
Iowa DNR had evaluated EPA's final rulemaking that was published in the
Federal Register in November 2018 (See documents titled Section
III.C._Question 2_Project Aggregation summary 2019 and Section
III.C._Question 2_Project Aggregation Comparison). However, no decision
had been made on how the Iowa DNR would approach project aggregation
decisions since the Natural Resources Defense Council (NRDC) had filed a
petition for review with the D.C. Circuit Court in 2019.
Just recently the Iowa DNR discovered this petition had been dropped so
the Iowa DNR needs to determine how it will proceed with project
aggregation decisions especially since this guidance is involved in the
Project Emissions Accounting (PEA) rule.
Y ~ N El 3. When requests are made to permit new or modified emissions units as
separate minor changes over time, do you evaluate whether the permitting
process is purposely staged as minor when the changes are really one
permitting action subject to major NSR?
D. Synthetic Minor Permit Limits
Y ~ N El 1. Do you keep a list of synthetic minor sources (i.e., sources that would
otherwise be major for NSR but are considered minor because of
emissions limits or other limiting conditions in their permits) that is available
for review by the public and EPA?
If yes, please explain how.
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2.
Describe your formal process for establishing or designating a synthetic
minor source.
The construction permit process reviews the facility PTE and establishes
enforceable limits as needed in permits used to designate a facility as a
synthetic minor.
Y lx] N ~ 3. For synthetic minor sources, do your permits include enforceable limits to
keep the sources minor?
Permits include short term and long term emission limits and operating
limits as needed. Footnotes on the limits specify that the basis of limits is
for synthetic minor status.
If not, please explain why.
4. Please describe how compliance with the synthetic minor limits is tracked
over time?
Emission limits may have a stack test to confirm. Operating limits have
daily, monthly, and 12-month or 365-day rolling tracking and recording, as
needed.
Y lx] N ~ 5. Are you satisfied that your tracking activities are sufficient to ensure that
sources getting synthetic minor permits to avoid major NSR review are not
actually operating above the applicable major source threshold?
Facilities nearing major thresholds are required to have more frequent
calculations to ensure status.
Y IX] N ~ 6. Do you include in your synthetic minor permits conditions requiring sources
to notify you if and when the major source threshold is reached?
Y ~ N [x] 7. Do you perform (or require) modeling for sources seeking synthetic minor
permits to determine impacts on PSD increments?
Y ~ N [x] 8. Do you consider visibility issues in Class I areas, if applicable, when
reviewing synthetic minor applications?
Y IX] N ~ 9. Do you include "prompt deviation" reporting requirements in synthetic minor
source permits?
If yes, how do you define "prompt deviation"?
567 IAC 24.1(2), An incident of excess emission shall be reported within
eight hours of, or at the start of the first working day following, the onset of
the incident.
Y IX] N ~ 10. Do permit applications reviewed by your agency and permits issued identify
the requirements (e.g., PSD, nonattainment Major NSR, Title V, NESHAP)
being avoided by keeping the source minor?
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E. Relaxation
1. Describe your knowledge of the "relaxation" regulatory provisions of 40
CFR 51.165(a)(5)(H), 51.166(r)(2), and 52.21 (r)(4).
The Iowa DNR interprets the relaxation provisions of CFR 51.165(a)(5)(H),
51.166(r)(2), and 52.21 (r)(4) to mean that any relaxation in any enforceable
limitation would require the facility to reevaluate the project as if it were new
construction. Thus, the company must return to the original project (or
when the limitation was taken) and reevaluate the emission increases. If
this causes the source to become major or a major modification, the project
must undergo PSD review as if it was a new project at the time the
relaxation is requested.
2. What types of changes do you consider potentially subject to relaxation
assessments?
The Iowa DNR considers any increase in any enforceable limitation
potentially subject to relaxation assessments. These would include, among
other things, emission limits, production limits, production capacity, hours of
operation, and types of materials or material contents.
Y ~ N El 3. Do you have a written policy on relaxation assessments?
4. Approximately how many relaxation assessments have you made in the
last five years?
The Iowa DNR does not track relaxation assessments. Recently, a request
was made to relax synthetic minor limits for a facility that became a minor
source for PSD. The company obtained the limits when they were major,
then became minor, and then asked to relax the limits since they are now a
minor source.
The Iowa DNR is working with EPA region 7 and headquarters on the
determination. The details of the determination are attached in the
document titled NSR Relaxation Determination for review.
Y lx] N ~ 5. Do you include specific permit conditions to make potential future relaxation
possibilities more identifiable?
For any emission limitation, a footnote is added in the permit to indicate the
limitation was added to avoid PSD review. For all limitations, the
Construction Permitting staff thoroughly document the reason for the
limitation in the engineering evaluation, which is required for each project.
As part of each review, the permit reviewer must review all information
pertinent to the review of existing units, which includes the engineering
evaluation and all limitations established for the unit.
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6. What is your understanding of the appropriate circumstances under which
an existing minor source is allowed a 100/250-tons-per-year emissions
increase without triggering relaxation provisions?
If a facility was originally limited to 100/250 tpy to be a synthetic minor
source, they would be allowed a one-time doubling of 100/250 tpy.
However, both emission limits would stand and the facility would have to
show compliance with both limits. The facility would not be allowed to
remove (relax) the original limit and have one 200/500 tpy limit.
Y lx] N ~ 7. Do you provide relaxation evaluation training to NSR permitting staff
employees (other than on-the-job training)?
If yes, describe the nature of the training provided.
All staff are required to perform five training courses annually, which
includes PSD training (external or internal). The Iowa DNR also periodically
provides NSR training to the construction permitting staff, which includes
the topic of relaxation provisions. In addition, information concerning the
relaxation of PSD limits is part of the Construction Permitting Section's
Construction Permit Manual, which is used for all projects.
IV. Minor Source Construction Permitting Program
Y lx] N ~ 1. Do you require monitoring or reporting requirements for minor sources?
a. If so, do you establish these requirements based on a rule or a
general policy of effective permit writing?
Effective permit writing requirements are that any operating limit
should have a corresponding monitoring and recordkeeping
requirement.
Y IX] N ~ 2. Does the application or permitting process require modeling for minor
sources?
It can, based on the size of the increased emissions, or previous modeling
which demonstrated predicted model results near the NAAQS for that
pollutant. See application Form MD for details.
Y ~ N [x] 3. Does your minor source permit program include a technology component
similar to BACT in the PSD program?
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Y lx] N ~ 4. Do you require minor sources with Federally applicable permit limits for
MACT, NSPS, or NESHAP to report compliance?
Yes, for those sources obtaining an air quality construction permit, all
reporting requirements are referenced in the air quality construction
permits. However; sources are expected to meet their reporting
requirements as specified by the rule.
More generally, the Iowa DNR implements the NSPS and NESHAP rules
by reviewing the rules with each project and adding the requirements of the
rule to the permits. In general, the Iowa DNR tries to add all of the
requirements of the rule to the permits. However, in some cases it is better
to provide a summary of the rule. In all cases, the permit contains
language that states that the facility must comply with all of the conditions
of the rule, and, at a minimum, provide the citations of the major
requirements in the rule. This includes reporting requirements.
The Iowa DNR also makes rule determinations and provides detailed
responses to the regulated community. In both cases, the Iowa DNR
thoroughly reviews the rules, has internal discussions, and, if necessary,
works with EPA to ensure the rules are applied correctly and consistently.
The Iowa DNR also has a designated staff member to be the main contact
for these determinations and to oversee what should be included in the
permits to ensure they are consistent and correct to the best of the
knowledge of the Iowa DNR staff.
In addition, the Iowa DNR has designated a number of staff to act as the
main contact for certain rules that are commonly regulated. Regular
meetings are held to ensure the effort is coordinated and complete. This
group follows updates in rules coming from EPA, the Air Quality Bureau's
Program Development section, and external groups such as NACAA.
The Iowa DNR also provides ongoing training for NESHAP and NSPS rules
to staff and the public. For any new or modified NSPS or NESHAP rules
the Iowa DNR uses the following procedure:
• Review the new and revised NSPS and NESHAP regulations.
• Write summary of new or revised NSPS and NESHAP regulation for
use by supervisor and other engineering staff.
• Make recommendation to supervisor on if a workgroup should be
formed to handle any NSPS or NESHAP regulation changes.
• Make recommendation to supervisor on if any assistance materials
or outreach should be made to affected facilities.
• Make recommendations to supervisor if any training is needed for
internal staff on new or revised NSPS or NESHAP.
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• If training is recommended, create training presentation and present
to staff, as appropriate.
A couple of recent examples of this procedure is how the new MACT Major
to Area Source Rule (MM2A Rule) and all of the changes in the NESHAP
rules due to Risk and Technology Review (RTR) review were handled.
For the new MM2A guidance and the new rule, the Iowa DNR developed a
summary of the guidance and provided the staff and public with a fact
sheet covering the requirements of the guidance/rule and how it would be
implemented. Training was provided for the MM2A rule. A presentation on
the changes in the guidance, proposed rule, and final rule were prepared
and presented to staff at an internal meeting and to stakeholders at a client
contact meeting. The information was then made available to the public on
the Iowa DNR website.
All of the NESHAP rules that were modified for RTR were also reviewed.
The Iowa DNR summarized the changes and provided links to the new
rules. This information was made available to the public via the AQ
technical listserv (over 23,000 people). The summary provided contact
numbers for the public and stakeholders if there were additional questions
on the changes.
Annually, the Iowa DNR provides training to the public on a number of
topics based on current needs. This includes training on NSPS and
NESHAP rules. If the the Iowa DNR believes training is needed on any
modified or existing rules it can be provided during annual training sessions
or more frequently if needed.
These efforts are undertaken to ensure the regulated community is
complying with all aspects of the rules and regulations including reporting
requirements.
V. Modeling
c.
A. PSD Modeling
1. General
Y lx] N ~ 1. Do you follow EPA's modeling guidelines in 40 CFR Part 51 Appendix W?
Y lx] N ~ 2. Are deviations from the modeling guidelines in Appendix W subjected to
public comment and submitted to the regional EPA office for approval?
The Dispersion Modeling staff would consult with EPA and the public would
have an opportunity during the public comment period for the project.
Y IX] N ~ 3. Do you ask applicants to submit a modeling protocol for approval prior to
submitting modeling?
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Y lx] N ~ 4. Is the protocol provided to other interested organizations {e.g., EPA,
Federal Land Manager)?
Yes, if there is interest in the project the Iowa DNR would provide a copy of
the modeling protocol.
Y lx] N ~ 5. Is the effect of downwash modeled if stacks are less than good engineering
practice (GEP) height?
Y IX] N ~ 6. Are modeling analyses available for public review?
Y8ND 7. Do you review modeling submittals to determine if option switches are
correct?
8. When off-site meteorological data are used, what years are typically used?
Currently 2015-2019. The meteorological data is updated every five years.
9. How do you train/re-train your modeling staff?
There is a training plan for new employees (attached). Existing staff attend
ongoing training as needed (APTI, Censara, etc). The Dispersion Modeling
group regularly QA projects conducted internally, which may reveal
opportunities for additional training.
Y IX] N ~ 10. Do you follow The Air Quality Analysis, Additional Impacts Analysis, and
Class I Area Impact Analysis guidance provided in the New Source Review
Workshop Manual (Draft October 1990)?
11. For cumulative national ambient air quality standards (NAAQS) and PSD
increment compliance assessment:
a. How are the appropriate emission inventories of other sources
developed?
See Modeling Inventory Procedures (attached)
b. What are the reasons used to identify and/or eliminate emission
sources?
See Modeling Inventory Procedures (attached)
c. How are PSD increment consuming/expanding sources identified
and tracked?
Permit and start of operation dates are used to identify sources. The
results are recorded in the modeling memo and kept in the record
for future reference.
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12. What is the basis {e.g., allowable, maximum or average actual short-term
emissions, last two year period, etc.) of the emission rates provided in the
NAAQS and PSD increment consuming inventories of other sources?
NAAQS: allowable
Increment: the Iowa DNR will generally start by conservatively assuming
the full allowable emission rates. A switch is made to actual emissions if
allowable emission rates show a problem in the modeling analysis. The
average from the previous two years is used if the source reports annually,
otherwise the most recent year. The actual emission rates are calculated
using the reported actual ton/yr converted to Ib/hr using reported actual
hr/yr.
13. How do you ensure that the controlling concentrations reported by the
applicant for each pollutant and averaging period were appropriately
determined?
A full review of all model inputs is conducted and reevaluation of the
analysis is performed if it is determined that the modeled concentrations
were not appropriately determined.
Y lx] N ~ 14. Are the impact modeling analyses reviewed to ensure that they are
accurate and complete, and that appropriate modeling procedures (e.g.,
modeled to 100-m resolution, fence line and not property line, nearest
modeled receptors, etc.) were followed?
Y lx] N ~ 15. Is complex terrain an issue in your region?
If yes, what modeling procedures are used to address impacts in complex
terrain?
Generally not, but there are some river valleys that affect flow and/or can
result in plume impaction on terrain. Met data representivity analysis is
used to determine that the correct data is used. NED files are used to
capture terrain elevations. The model is rarely run without terrain
elevations.
Y ~ N IX] 16. Are pollutants without NAAQS and/or PSD increments addressed in the air
quality impact assessments?
If yes, what threshold concentrations {e.g., acceptable ambient
concentrations) are used to evaluate impacts?
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Y lx] N ~ 17. Do you have written agency-specific air quality modeling guidance for use
by applicants?
Y lx] n ~ If yes, has the guidance been provided to other concerned organizations
(e.g., regional EPA, appropriate FLM, etc.) for review and comment?
The Iowa DNR releases drafts of proposed changes to guidance
documents to the public for review before finalizing the changes.
Notifications of the availability of draft guidance documents for public
review are made through the AQ technical listserv (over 23,000 people)
and at AQ Client Contact meetings.
If yes, is your guidance available on the internet?
YSND
18. How do you determine the appropriateness of proposed meteorological
data for an application?
a. When are "on-site" meteorological data required for an application?
If the applicant does not wish to use the data the Iowa DNR has
determined is representative, or an alternative conservative
approach as discussed on page 17 of the meteorological data TSD,
which is available at https://www.iowadnr.gov/Environmental-
Protection/Air-Qualitv/Modelinq/Dispersion-
Modelinq/Meteoroloqical-Data
YIND b. Are "on-site" meteorological data validated and accepted if recovery
is less than 90 percent?
Generally no. However, if the data would be superior to anything
else available the Iowa DNR would consider it on a case-by-case
basis and in consultation with EPA.
19. When an applicant's air quality modeling reveals NAAQS and/or PSD
increment violations, what is required to grant the permit and how are the
violations resolved?
Iowa DNR requires (567 IAC 22.3(1)"b") mitigation of the exceedances in
the model or a demonstration that the project being evaluated is
insignificant at every predicted exceedance prior to issuance of the
permit(s).
YIND 20. Do your regulations include the federal definition of ambient air?
If no, what is your definition of ambient air?
21. Discuss your procedures for modeling "hot spots," including minimum
receptor spacing?
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Receptors are required in Iowa DNR's Modeling Guidelines to be spaced at
50-meter intervals along, and within 500 meters of, the ambient air
boundary, as well as any other areas with elevated concentration. The
Guidelines are available here:
https://www.iowadnr.gov/Environmental-Protection/Air-
Quality/Modeling/Dispersion-Modeling
22. How do you determine if background air quality data are representative?
The Iowa DNR uses a conservative default, or a case-by-case value
proposed by the applicant and approved by the DNR. This is described in
the Iowa DNR's background concentration TSD available at
https://www.iowadnr.gov/Environmental-Protection/Air-
Qualitv/Modeling/Dispersion-Modeling/Background-Data
Y lx] N ~ 23. Do you use the same NAD for stack, receptor, and building UTM
coordinates?
2. Class I Areas
This section is currently not applicable for projects in Iowa. There are no Class I areas within
100 km of Iowa's borders.
1. How do you determine which proposed projects need a Class I impacts
analysis, including consideration of distance of the source from Class I
areas (e.g., maximum distance criteria)?
Y ~ N ~ 2. For new or modified sources within 10 kilometers of Class I areas, do you
require sources to submit an impact analysis for all pollutants to determine
if any have impacts greater than 1 ug/m3?
Y ~ N ~ 3. Do you require applicants to submit a Class I increment analysis for each
pollutant subject to PSD review for which an increment exists?
Y ~ N ~ 4. Do you require applicants to identify and provide a cumulative impacts
analysis (maximum impact within Class I areas) for all Class I areas
impacted by the source?
Y ~ N ~ 5. Do you have a formal procedure for notifying Federal Land Managers
(FLMs)?
If yes, please explain.
Y ~ N ~ 6. Do your permitting procedures require the applicants to notify Federal Land
Managers?
If yes, please explain.
Y ~ N ~ 7. Is there communication, consultation, and discussion between you and
FLMs?
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If yes, to what extent (e.g., high, moderate, minimal).
Y ~ N ~ 8. Is there communication, consultation, and discussion between the applicant
and FLMs?
If yes, to what extent (e.g., high, moderate, minimal)?
Y ~ N ~ 9. Do you actively seek input from FLMs during the permitting process?
Y ~ N ~ 10. Is the applicant required to address potential adverse impacts on air quality
related values (AQRVs) that are identified by the FLM during the
notification process?
Y ~ N ~ 11. Do you require prior approval of Class I area impact analysis procedures
that applicants plan to use?
Y ~ N ~ 12. Do you require applicants to perform a visibility analysis for Class I areas?
Y ~ N ~ 13. If visibility impairment is indicated, do you require the applicant to notify the
appropriate FLM for the Class I area?
Y ~ N ~ 14. Is the applicant required to address potential effects on scenic vistas
associated with Class I areas that may have been identified by the FLM
during the notification process?
Y ~ N ~ 15. Do you have a formal process for handling Class I area increment
violations if predicted?
Y ~ N ~ 16. Have you issued PSD permits where the FLM objected?
If yes, please explain and identify the projects.
B. Nonattainment Major NSR Modeling
Y lx] N ~ 1. Do you require modeling to ensure that emission offsets provide a positive
net air quality benefit? (Only applies to sulfur dioxide, particulate matter,
and carbon monoxide nonattainment areas.)
C. Minor Source Modeling
Y ~ N lx] 1. Are minor permit actions (i.e., proposed new and modified minor sources),
evaluated to determine if modeling for PSD increments is needed?
a. Under what circumstances is increment modeling triggered for
these minor permit actions?
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Y IX] N ~ 2.
Do you use modeling to assure that minor sources and minor modifications
will not violate the NAAQS?
If so, at what emission thresholds?
The Ib/hr equivalents of the PSD significant emission rates (assuming 8760
hr/yr). The Iowa DNR will also evaluate projects at facilities with previous
modeling that is within 1 SIL of the NAAQS. The Iowa DNR minor source
modeling determination procedures are described in detail on Form MD,
which is available at
https://www.iowadnr.qov/Portals/idnr/uploads/forms/5420948.pdf
Modeling was used to define permit limits for asphalt, concrete, and
aggregate plants, resulting in permit templates that applicants can use
without additional modeling.
https://www.iowadnr.gov/Environmental-Protection/Air-
Qualitv/Construction-Permits/Construction-Permittinq-Materials
Y lx] N ~ 3. Based on any modeling results, do you require installation of air quality
monitors or establish other permit conditions to assure protection of the
NAAQS and increment?
Permit conditions such as operational limits are often included in
construction permits in order to mitigate predicted exceedances of the
NAAQS.
Y lx| N ~ 4. For the pollutants with PSD increments established do you have a list of
areas where the minor source baseline has been triggered?
Y lx| N ~ 5. Do you model minor sources for PSD increments if the minor source
baseline is triggered?
But only as part of a PSD application in the vicinity at another source, not
as a result of a non-PSD application.
Y lx| N ~ 6. Do you have procedures in place to identify minor sources that consume or
expand PSD increment?
Refer to modeling inventory procedures (attached).
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D. Increment Tracking
1. What method do you use to assign baseline dates {e.g., county-specific,
region-specific, or entire state)?
The method depends on the pollutant. For PM10 Iowa DNR uses the
previous TSP nonattainment areas, which can be municipal boundaries or
townships, then remainders of the counties in which these are located, and
finally the remainder of the state. For PM2.5 Iowa DNR uses counties. For
NO2 and SO2 Iowa DNR uses the entire state.
Y lx] N ~ 2. Do you have a list of the minor source baseline dates for each area?
If yes, please provide a copy.
This is available on the Iowa DNR website under the "PSD Modeling
Guidance" tab: https://www.iowadnr.gov/Environmental-Protection/Air-
Quality/Modeling/Dispersion-Modeling
Y lx] N ~ 3. Do you have an understanding of receptor location dependence vs. source
location dependence for increment tracking?
Y IX] N ~ 4. Do you have a program for tracking increment consumption?
If yes, please describe the program and whether it is a formal or an
informal program?
Iowa DNR uses a formal source location dependent method of tracking
increment. The maximum concentration indicated in PSD increment
modeling analyses is recorded in the analysis review memo.
Y ~ N IX] 5. Do you maintain and update a computerized emission source database for
increment tracking that includes minor sources that affect increment?
If yes, does the database include the information needed for modeling
(e.g., source locations, stack parameters, emissions)?
6. Do you use allowable or actual emissions for increment tracking purposes?
Iowa DNR generally starts with allowable emissions unless doing so
causes predicted exceedances. In these instances Iowa DNR would revert
to actuals for all or a subset of the sources in the analysis.
a. If actual emissions, how do you calculate emissions for each
averaging period covered by the increments?
Actual emissions are calculated using the most recent 2 years of
emissions data (reported actual ton/yr and actual hr/yr are used to
determine the Ib/hr rate).
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Y IX] N ~ 7.
Are area sources included in increment tracking analyses {e.g., growth-
related and transportation-related emissions)?
These emissions are considered part of the background. Growth affects are
considered in the additional impact analysis.
8. How frequently is increment consumption evaluated - on a scheduled basis
or just when occasioned by a new permit application?
When a PSD application that will result in a significant concentration is
reviewed.
9. How "transparent" {i.e., understandable) is the emission source inventory
used for PSD modeling? {i.e., could an outside reviewer (such as a
member of the public) clearly identify the sources included {e.g., name,
location, stack parameters) and the sources excluded in a modeling
analysis?)
Iowa DNR uses a standardized review memo that summarizes all source
parameters in tables that are readily understandable to the public.
10. How do you handle interstate increment tracking (for state reviewing
authorities) or inter-jurisdiction tracking (for local reviewing authorities),
including consistency of tracking across jurisdiction boundaries?
If a project will be located near a state border the Iowa DNR will contact the
neighboring state(s) and request source inventories from them to include in
the analysis. For the Linn and Polk county local programs, Iowa DNR
maintains the increment tracking for each county.
11. What procedure do you follow in planning for and incorporating new
modeling tools?
Y ~ N lx] 12. Do you provide increment tracking training to NSR permitting staff (other
than on-the-job training)?
If yes, describe the nature of the training provided.
Y ~ N lx| 13. Are mobile sources modeled for increment compliance?
14. How does the public access a list of sources that affect PSD increments?
The public can review previous project memos through the DocDNA
electronic records system (https://www.iowadnr.gov/Environmental-
Protection/Air-Qualitv/Public-Records-Air-Qualitv) or request an inventory
list from Iowa DNR at the time of an application.
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VI. Other Program Elements
d.
A. Environmental Justice (EJ)
e. Note: By EJ analysis we refer to any procedures applied during the permitting process,
regardless of whether they are called EJ, that consider demographics (race, income,
nationality, etc.), cumulative effects, (burden, exposure, risk), comparative effects or
modifications to the public involvement processes to address unique characteristics of the
project.
Y ~ N lx] 1. Do you consider EJ issues during the permitting process? If yes, please
provide a description of the criteria, guidelines, or screening procedures
used to address EJ issues.
Y ~ N ~ 2. Regarding section 173(a)(5) of the Clean Air Act, do you conduct an
alternatives analysis as part of your nonattainment area permitting
process? If yes, please provide a description of the EJ criteria or
guidelines used for this analysis.
DNR has not conducted a major nonattainment NSR permitting project
since 2000. Therefore, DNR does not have contemporaneous information
regarding this question at this time.
Y lx] N ~ 3. Regarding section 165(a)(2) of the Clean Air Act, does your NSR permitting
program and public comment process for PSD regulated pollutants provide
for consideration of alternatives?
4. How are the demographics of the affected community taken into account in
the permitting process?
Demographics are not taken into account.
5. How are cumulative effects and/or pre-existing burden addressed in the
permitting process?
Cumulative dispersion modeling is conducted in accordance with federal
regulations.
6. What additional community information and/or demographics (for example
- children, the elderly) do you consider important for an EJ analysis?
See answer to Q1 of this section.
Y ~ N ~ 7. Do you allow public involvement during an EJ analysis? If yes,
a. What stakeholder groups do you try to involve?
b. At what point in the EJ analysis or permitting process do
stakeholders become involved?
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c. To what degree and in what manner do stakeholders or the
community influence the permit decision making process?
d. To what degree do you know about how stakeholders or the
affected community participated in the permit decision making
process?
e. Describe how you make information available to stakeholders and
the affected community. (For example - translation of information,
understandable and accessible materials, personal contacts, clearly
explained technical information including potential risk, distribution
of information, public meetings, etc.)
Not Applicable.
Y ~ N ~ 8. In the EJ analysis, do you consider direct and indirect benefits and burdens
from the proposed actions? If yes,
a. Describe what benefits you consider in the EJ analysis. (For
example - economic, social, cultural, health, environmental, etc.)
b. Describe what burdens you consider in the EJ analysis. (For
example - economic, social, cultural, health, environmental, etc.)
Not Applicable.
Y ~ N ~ 9. In the EJ analysis, do you consider comparative and disproportionate
impacts? If yes,
a. Describe the criteria or procedures used to determine any potential
or actual adverse health or environmental effects or impacts.
b. Describe the criteria or procedures used to determine whether
evidence exists to describe these effects or impacts.
c. Describe the criteria or procedures used to determine whether the
proposed project complies with all applicable environmental laws.
Not Applicable.
f.
B. Endangered Species Act (ESA)
Y ~ N ~ 1. If you have a delegated PSD program, do you notify PSD permit applicants
of their ESA obligations?
If so, please provide a copy or description of your notice.
Not Applicable.
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Y ~ N ~ 2. If you have a delegated PSD program, do you advise applicants,
concerning their ESA obligations, to consult with a.) EPA; b.) The U.S. Fish
and Wildlife Service; and/or c.) Federal Land Manager?
If yes, please explain, and describe what information you provide to
applicants concerning their ESA obligations.
Not Applicable.
Y ~ N lx] 3. If you have a SIP approved PSD program, do you have any responsibilities
under your state law to carry out an endangered species analysis?
If so, please briefly describe the scope of the program. If no, please so
indicate.
The Iowa air quality regulations do not specifically require an analysis of
endangered species as part of the SIP approved PSD program. However,
Iowa does have an endangered and threatened species law which was
enacted in 1975 (See Iowa Code Chapter 481B). This program is
managed by the Conservation Division of the Iowa DNR
(https://www.iowadnr.gov/conservation/iowas-wildlife/threatened-and-
endanqered). A current list of endangered, threatened, and special
concern species can be found in 571 IAC 77.2 (list of animals) and 571 I AC
77.3 (list of plants).
In past PSD projects, applicants have been asked to provide a list of those
species in 571 IAC 77.2 and 571 IAC 77.3 that are within the impact area of
concern for the project along with any potential impacts. That information
is provided as part of the Technical Support Document so the public can be
made aware of the impacts during the public comment process.
Y ~ N ~ 4. If you carry out a federal or state ESA review, does the consultation affect
the timing of your issuance of a proposed or final permit?
If yes, please explain.
Not Applicable.
C. State & Local Agency Coordination
1.
1. How do the local and state agencies coordinate permitting-related
responsibilities?
Polk County issues minor NSR permits including synthetic minor permits.
State reviews and issues major PSD projects. Linn County issues minor
NSR permits including synthetic minor permits. Linn County reviews and
drafts PSD permits. The State issues final PSD permits.
2. How does the department overview the local agency's permitting activities?
Each county program is audited every two years.
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Y lx] N ~ 3. Does the local agency routinely send draft and final permits to the state
agency for review, comment, and concurrence?
If yes, please explain the details.
The contracts with the local programs require the following draft permit
types to be reviewed for concurrence:
Prior to issuance, the Local Program shall submit to DNR for
concurrence a copy of each draft construction permit, if the draft or
related determinations have not been previously reviewed by DNR,
containing or using the criteria listed below in the proposed final
determination.
a. Criteria requiring DNR concurrence:
1) NESHAP, MACT or NSPS requirements at greenfield sites
except for tanks, generators, natural gas only boilers, or
paint booths at minor sources;
2) Limits to avoid PSD major source review (synthetic minors);
3) Netting conducted under Step 2 of the NSR applicability
analysis;
4) Routine maintenance or replacement (RMRR) decisions;
5) Capable of accommodating or demand growth emission
exclusion decisions;
6) BAE to PAE calculations resulting in a reasonable possibility
as defined in 567 IAC 33.3(18)T(8); and
7) Major source reclassification decisions under CAAA §112.
4. How often does the local agency provide the state with information on its
permitting activities?
Bi-weekly staff meetings and on other specific projects as consultation is
needed or as required by the contracts.
5. Do you interact with other state environmental media programs (e.g. water,
RCRA, waste) when permitting complicated projects?
Yes, in the past the Construction Permitting Section has worked with other
state environmental media programs such as the Solid Waste Section and
the various sections within the Water Quality Bureau when working on
complex permitting projects. In addition, the section has worked with the
Iowa Economic Development Authority on some large projects.
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Please provide a copy of the most recent program review you have
completed for each local agency with all or a portion of the NSR permitting
responsibilities in the state.
The final reports for Linn County (document titled Section VI.C.6 -
FinalReport_Linn2019ProgReview) and Polk County (document titled
Section VI.C.6 -Final Report_2020PolkProgramReview) are attached.
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Compliance & Monitoring Section
Air Quality Bureau, Wallace State Office Building , 502 E 9th Street, Des Moines, IA 50319-0034
Catharine Fitzsimmons, Bureau Chief
Kayla Lyon, Director Alex Moon, Deputy Director Ed Tormey, Division Administrator
Jason Marcel
Bureau Chief,
Field Services and Compliance Bureau
Years of Service = 23
Kurt Levetzow
Supervisor
Years of Service = 23
Brian Hutchins
Supervisor
Compliance & Monitoring Section
Years of Service = 25
Tamara Mullen
Bureau Chief
Legal Services Bureau
Years of Service = 13
Kayla Beck
Environmental Specialist
Years of Service = 2
Bryan Bunton
Environmental Specialist
Years of Service = 20
Caroline Davis
Environmental Specialist
Years of Service = 1
Bill Gross
Environmental Specialist Sr
Years of Service = 37
Mark Heiderscheit
Environmental Specialist
Years of Service = 27
David Knoll
Environmental Specialist Sr
Years of Service = 20
Michelle Sabatini-Rosaker
Environmental Specialist
Years of Service = 8
Thad Nanfito
Environmental Specialist
Years of Service = 20
Jon Ryk
Environmental Specialist
Years of Service = 13
Clark Ott
Environmental Specialist Sr
Years of Service = 30
David Miller
Environmental Specialist
Years of Service = 10
Cindy Martens
Environmental Specialist Sr
Years of Service = 30
Amber Wolf
Environmental Specialist
Years of Service = 13
Wendy Wittrock
Environmental Specialist
Years of Service = 6
Brenda Streicher
Environmental Specialist
Years of Service = 33
Holly Vandemark
Environmental Specialist Sr
Years of Service = 24
Ryan Stouder
Environmental Specialist Sr
Years of Service = 21
Jeff Theobald
Environmental Specialist
Years of Service = 26
Julie Duke
Environmental Specialist
Compliance
Years of Service = 8
Mark Fields
Environmental Specialist Sr
Compliance & Stack Testing
Years of Service = 14
Sarah Mousel
Environmental Specialist
Compliance
Years of Service = 1
Alex Randall
Environmental Specialist
Stack Testing
Years of Service = 7
Kristofer Schult
Environmental Specialist
Stack Testing
Years of Service = 1
Lucas Tenborg
Environmental Specialist
Compliance
Years of Service = 0
Kelli Book
Attorney
Years of Service = 22
Anne Preziosi
Attorney
Years of Service = 32
Legal Services Bureau
Years of Service = 67
Air Quality Bureau - Compliance Section
Year of Service = 56
Field Office Service Years = 387
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Construction Permits Section
Air Quality Bureau, Wallace State Office Building , 502 E 9th Street, Des Moines, IA 50319-0034
Catharine Fitzsimmons, Bureau Chief
Kayla Lyon, Director
Alex Moon, Deputy Director
Ed Tormey, Division Administrator
Sarah Piziali, Supervisor
Construction Permits Section
Years of Service = 19
Jim McGraw, Supervisor
Program Development & Support Section
Years of Service = 24
Shawn Corbin
Environmental Engineer
Construction Permit Review
Years of Service = 20
John Curtin
Environmental Engineer
Construction Permit Review
Years of Service = 21
Corey Detter
Environmental Engineer
Construction Permit Review
Years of Service = 25
Ashley Dvorak
Environmental Engineer
Construction Permit Review
Years of Service =7
Michael Hermsen
Environmental Engineer Sr
PSD, NSPS, & NESHAP
Years of Service = 22
Karen Kuhn
Environmental Engineer Sr
PSD Permit Review
Years of Service = 26
Priyanka Painuly
Environmental Engineer
Construction Permit Review
Years of Service = 20
Rachel Quill
Environmental Engineer
Construction Permit Review
Years of Service = 17
Chris Roling
Environmental Engineer Sr
PSD Permit Review
Years of Service = 25
Gary Smith
Environmental Engineer Sr
PSD Permit Review
Years of Service = 25
Nate Tatar
Environmental Engineer
Construction Permit Review
Years of Service = 3
Peter Zayudis
Environmental Engineer Sr
PSD, SIP, & Nonattainment
Years of Service = 23
Danjin Zulic
Environmental Engineer
Construction Permit Review
Years of Service = 7
Years of Service for the Construction Permit Section = 241
Program Development
Jessica Reese Mclntyre
Environmental Specialist
Records Support & Data
Entry
Years of Service = 5
Virun Rongkavilt
Environmental Specialist
Records Support & Data
Entry
Years of Service = 29
Dispersion Modeling
Brad Ashton
Environmental Specialist Sr
Dispersion Modeling & SIPs
Years of Service = 20
Alyssa Jensen
Environmental Specialist
Dispersion Modeling
Years of Service = 8
Support
Kevin Connolly
Environmental Specialist Sr
SLEIS/EASY Air Help Desk
Years of Service = 25
Jason Dowie
IT Support Worker 4
SLEIS/EASY Air Help Desk
Years of Service =13
Tammy Friedman
IT Support Worker 2
Construction Permit Data
Entry & Support Services
Years of Service = 20
Years of Service for the Program Development Section = 120
Total Years of Service = 361
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NSR Relaxation Determination
John Deere submitted a letter dated June 27, 2019. The facility wanted to simplify the air permitting for
the John Deere Dubuque Works facility by requesting the DNR remove the individual paint booth
synthetic minor VOC emission limits set while the facility was a major stationary source.
John Deere and their consultant (RTP Environmental) claimed the permit change was not subject to the
source obligation rule and also claimed this was consistent with prior EPA decisions.
However, that viewpoint is different from NSR training the DNR staff had received over the years,
including training conducted by RTP. The DNR did review the EPA decisions referenced by John Deere
and an additional decision by the State of Colorado.
After reviewing the past decisions the DNR sent an email with an attached document to EPA Region VII
on June 19, 2020. This document provided a history of the New Source Review (NSR) program and 40
CFR §52.21(r)(4), the company's background, the request, the permitting cases we reviewed, a brief Iowa
DNR analysis, and questions for EPA (last page).
The email stated "The State of Iowa has adopted the PSD regulations into its State Implementation Plan
(SIP), but removal and relaxation of synthetic minor limits is not an "Iowa only issue" and is a "program
issue." Therefore, it is most appropriate to have the Environmental Protection Agency (EPA) address the
questions related to this issue for the sake of consistency of applicability within the PSD program."
This request was sent to EPA Headquarters and as of this date we still have not received an official
answer from EPA regarding the relaxation of PSD synthetic minor limits in cases where the facility
becomes a minor stationary source.
At this time, the Department has not removed or relaxed these limits. The Department will wait for a
determination from EPA before proceeding with the project.
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Making Your Comments Count
The public plays an important role when the Iowa Department of Natural Resources (DNR) prepares air quality permits
or updates state rules. DNR strives to ensure all projects meet federal and state standards. While DNR staff have the
technical expertise, the public may identify other issues—protecting everyone's air quality.
KEYS TO AN EFFECTIVE COMMENT
©Point Out Unintended Consequences
Well-intended rules or permitting
actions sometimes result in unintended
consequences. Thoughtful public feedback
may reveal these effects.
Provide Technical Information
Comments and assumptions supported by
technical information are more helpful than
general statements or form letters.
©Suggest Alternative Solutions
Explain your concerns as clearly as possible
and, if appropriate, suggest alternative
requirements or different language.
©Ask Questions
DNR staff welcome your questions.
Understanding technical requirements can
help you develop a meaningful comment
or address your concerns. If you have
questions, find DNR's experts on the public
participation page or call 515-725-8200.
COMMON COMMENT MISTAKES
®The Comment Process is Not a Vote
One well-supported comment is often
more effective than a hundred generic
emails or form letters. DNR will respond
to similar comments as a group.
Comments Not Specific to Proposal
Read and understand the proposal you are
commenting on. Make sure the comment
is relevant to the issue or action the DNR
is proposing.
Comments Beyond DNR's Authority
You may have a great suggestion to
improve Iowa's air, but it may not be
within the authority granted to DNR by
the legislature or Governor. The DNR is
unable to address issues regarding odor,
noise, light pollution and other factors not
regulated under federal or state air quality
standards.
QU
READY TO MAKE YOUR VOICE HEARD?
Stay informed by signing up for DNR's Air Quality Technical listserv. Check the public participation page regularly to
learn about opportunities to become involved and make public comments.
Comment periods and public hearings provide opportunities for you to comment. DNR will not present information
or answer questions during the formal part of a public hearing—that's for your input. However, there may be time for
questions before or after the hearing. Your voice improves DNR decisions through public notice and comment.
Iowa has made tremendous progress toward improving statewide air quality in the last 25 years.
Together we can ensure Iowa's air quality for the future.
Leading Iowans in Caring for Our Natural ResourcesIwww.iowacleanair.gov
March 2018
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Training Checklist
The following checklist is a list of training for the first two (2) months of employment. The list will be updated as
needed.
Week 1
~ With mentor assistance get safety shoes, hard hat, & safety glasses
~ Schedule a facility outreach visit with CP staff
~ Review department website www.iowacleanair.aov
Assignment:
~ Register/Review/Complete APTI SI422 - Air Pollution Control Orientation Course
~ Begin review of IAC rules Chapters 20, 22.1 - 22.99, 23, 25, 31, and 33
Week 2
~ Discuss with mentors the scope of the Department's air quality rules
~ Review Construction permit application forms and instructions
~ Review example of completed forms (completeness review example)
Assignment:
~ Register/Review/Complete SI460 - Introduction to Permitting
~ Register/Review/Complete RE 100 (module 1-4) - Basic Concepts in Environmental Sciences
~ Start review of Construction Permit Manual
~ Continue review of IAC rules
~ Begin reading EPA's NSR Workshop Manual (chapters A. H. and I)
Week 3
~ Discuss with mentors the Construction permit application forms and instructions.
~ Discuss EPA's NSR Workshop Manual with mentors
Assignment:
~ Register/Review/Complete RE100 (modules 5-7) - Basic Concepts in Environmental Sciences
~ Register/Review/Complete SI413 - Control of Particulate Matter Emissions
~ Register/Review/Complete SI431 - Air Pollution Control Systems for Selected Industries
~ Review "Estimation of Emissions" guide that is provided with Form EC
~ Continue review of CP Manual
Week 4
~ Discuss with mentors the CP manual
~ Review Other References (see list on next page)
Assignment:
~ Review/Complete SI482 (Chapters 1 through 3, and 13) - Sources and Control of Volatile
Organic Air Pollutants
~ Start review of Example Project #1 (basic)
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Week 5
~ Discuss with mentors your review of Example Project # 1
~ Discuss with mentors the CP manual
~ Schedule facility inspection with F05 staff
Assignment:
~ Start review of Example Project #2 (stack testing)
~ Review stack testing methods (see list on next page)
Week 6
~ Discuss with mentors your review of Example Project #2
~ Begin work on first CP project
~ Discuss stack testing with lead stack tester
~ Schedule facility stack test observation with stack testing staff
Assignment:
~ Take Effective Permit Writing class from senior engineering staff
Week 7
~ Continue work on CP projects
~ Review Form MD and Reference Guide for CP Engineers
Assignment:
~ Discuss Form MD and modeling process with lead dispersion modeler
~ Register/Review/Complete APTI SI423 Precursor Materials for Air Pollution Dispersion
Models-AERMOD
Week 8
~ Discuss with mentors your review of Example Project #3
~ Continue work on CP projects
~ Schedule meetings with Supervisors of each AQB section and attend a meeting with each AQB
section
Assignment:
~ Start review of Example Project #3 (modeling)
~ Register/Review/Complete SI-437: Module 7 - Fabric Filters
~ Register/Review/Complete SI-437: Module 6 - Wet Scrubbers
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Week 4 - list of References:
• Air Pollution Engineering Manual - Provided to you in your cube.
• Iowa Administrative Code: https://www.legis.iowa.gov/law/administrativeRules/agencies
• Iowa DNR Air Quality: http://www.iowadnr.gov/Environmental-Protection/Air-Oualitv
• DocDNA: https://dnal.documentdna.com/index.isp?URL CONTEXT=/iowadnr
• AP-42: https://www.epa.gov/air-emissions-factors-and-quantification/ap-42-compilation-air-emission-
factors
• WebFIRE fire: https://cfpub.epa.gov/webfire/
• Stack Test Login: https://programs.iowadnr.gov/stacktest/pages/home
• FO Compliance Database: https://programs.iowadnr.gov/focomp/
• 40 CFR
o eCFR: https://www.ecfr.gov/cgi-bin/text-
idx?gp=&SID=9844abdab93db2d7bbf5377f966b519e&mc=true&tpl=/ecfrbrowse/Title40/40CIs
ubchapC.tpl
o Cornell law: https://www.law.cornel!.edu/cfr/text/4O/chapter-I/subchapter-C
• EPA Technical Air Pollution Resources: https://www.epa.gov/technical-air-pollution-resources
• APTI, EPA, and CenSARA classes: https://epaapti.csod.com/client/epaapti/default.aspx
• EPA website of NESHAPs: https://www.epa.gov/stationarv-sources-air-pollution/national-emission-
standards-hazardous-air-pollutants-neshap-9
• EPA website of NSPSs: https://www.epa.gov/stationarv-sources-air-pollution/new-source-performance-
standards
• NSPS (from Texas): https://www.tceq .texas.gov/permitting/air/rules/federal/60/60hmpg.html
• NESHAP (from Texas): https://www.tceq.texas.gov/permitting/air/rules/federal/63/63hmpg.html
• Applicability Determination Index (ADI): https://cfbub.epa. gov/adi/
• Conversions: http://www.onlineconversion.com/
• Standard Industrial Classification (SIC) System: https://www.osha.gov/pls/imis/sicsearch.html
• North American Industry Classification System (NAICS): https://www.naics.com/search/
Week 5 - List of test Methods:
Opacity - 40 CFR 60, Appendix A, Method 9; 40 CFR 60, Appendix A, Method 22
PM/PM10/PM2.5 - 40 CFR 60, Appendix A, Method 5; 40 CFR 51 Appendix M Method 202; 40 CFR 51,
Appendix M, 201A with 202
VOC/HAP - 40 CFR 63, Appendix A, Method 320; 40 CFR 60, Appendix A, Method 18; 40 CFR 60,
Appendix A, Method 25
S02 - 40 CFR 60, Appendix A, Method 6C
NOx - 40 CFR 60, Appendix A, Method 7E
CO - 40 CFR 60, Appendix A, Method 10
Supplemental APTI Courses (should vou feel additional information is necessary):
• SI409 - Basic Air Pollution Meteorology
• SI418 - Control of NOx Emissions
• SI412B - Electrostatic Precipitator Plan Review
• SI437 - Air Pollution Control Technology Series (additional information to SI431)
• SI473A - Beginning Environmental Statistical Techniques
• SI474 - Introduction to Environmental Statistical Techniques
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SI476B - Continuous Emission Monitoring Systems - Operation & Maintenance of Gas Monitors
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EPA Training Suggestions
May 19, 2021
Background
There is a long list of classes Air Pollution Training Institute (APTI), National Air Compliance Training (NACT),
and Self-Instructional (SI) classes that can be found on EPA's Learning Management System (LMS). The
problem is not with the types of classes offered, but with the content as many of these courses have not been
updated in years and much of the information is out of date plus the way the information is presented needs to be
modernized.
In addition, staff also have access to Central States Air Resource Agencies (CenSARA) classes and some of these
classes overlap with the NACT and APTI classes. If possible, it would be good to combine some of these classes
to become more efficient and save resources. Also, it can provide more consistent training to everyone.
Besides updating the content and modernizing the presentation materials, the biggest area of need is training on
various National Emission Standards for Hazardous Air Pollutant (NESHAP) standards. NESHAP training is not
only important for permitting staff, but inspectors, companies, the public, etc. Using NESHAP rules as an
example, EPA should consider training on every new rule/regulation it develops because permit writers are too
often trying to figure out what EPA meant by certain conditions, has to then ask EPA, and wait for a response
which can delay permit issuance. Add in the possibility of a different agency making a different determination
and confusion is the result for agencies and stakeholders.
It should be noted, EPA made a strong first step with its new training course "Setting Enforceable Potential to
Emit (PTE) Limits in New Source Review Permits" (APTI SI-NSR201; October 2020) and its announcement of
future mini courses on NSR. There are likely ways to simplify and improve the course, which is true of any
training materials, but it is a great way to start providing updated and important content on Air Quality issues.
Following are the suggestions taking these factors into consideration:
First Level of Classes to be Updated
The most important thing for any training program is to lay a solid foundation. Therefore, the first three classes to
be updated would be the Introduction to Air Quality, Air Pollution Control Basics, and Effective Permit Writing
Classes. The reasons are provided below:
(1) Introduction to Air Quality
This would be a new class combining APTI 452 (Principles and Practices of Air Pollution) and 101
CenSARA (Clearing the Air). The class would be an entry level course that would explain the history of
air pollution, the history of the Clean Air Act, other laws and regulations related to air pollution, the types
of air pollution, the impacts of air pollution, dispersion modeling basics, measurement and control
equipment basics, the roles of EPA and state/local agencies, the rulemaking process, and current air
pollution topics
REASON: Having a strong foundation is the most important thing any of us can have in anything we do so
having a high-quality and informative introductory class is one of the most important things that can be
provided to anyone starting in air quality. The class may have to be 3 - 4 days in order to cover so much
material, but it is important to give new employees and even experienced veterans looking for a refresher the
best information available.
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(2) Air Pollution Control Devices Basics
This would replace NACT #299 (Air Pollution Control Devices) which is described as an "introduction
to air pollution control equipment and methods used to control particulate and gaseous air emissions. "
This course is a good idea, but needs to be updated with current information on various types of control
equipment. The course shouldn't spend too much time on individual types of control as there are specific
classes for baghouses, ESPs, etc. It should talk about the theory of various control devices, but not too
much as that can be handled in the specific classes. The control types the class should discuss should be
for the various pollutants like particulate (PM/PM10/PM2 5), SO2, NOx, VOC, CO, mercury, GHGs, etc.
Also, it would be good to provide information on where people can find the most up-to-date information
on various control technologies in order to stay current.
REASON: This is another class that is important in setting a strong foundation for people working in air
pollution. We need to ensure to discuss the most important control technologies of the day with the most
current information. It won't be possible to talk about every type of control device, but it is important to talk
about the pollutants we deal with and their most common control measures. Classes on individual control
measures can go into more detail.
(3) Effective Permit Writing
This would replace NACT #334 (Permit Practices). It can be done as a combination intro and
intermediate effective permit writing. The class should cover why we write permits, the types of air
quality permits, proper language to use in a permit, formatting of permits, and how to read a permit. It
should also cover how to review an application, the types of requirements to put in a permit, and how to
write a proper permit writer evaluation.
REASON: This goes along the whole theme of a strong foundation. All of us in the air quality arena have to
deal with permits whether it is writing, reading, or enforcing them. Therefore, it is fundamental to our jobs
that we have a class that gives everyone a strong background in permitting.
Second Level of Classes to be Updated:
After that first group the next collection of classes that need to be updated are the ones related to common
industry types, control equipment types, and measurement techniques. This group includes:
• APTI 413 (Control of Particulate Emissions) [NOTE: combine with NACT 281 (ESPs) and NACT
282 (Baghouses)]
• APTI 418 (Controls of NOx Emissions)
• APTI 482 (Sources and Control of VOC Air Pollutants) [NOTE: combine with NACT 284 (VOC
Control Devices)]
• APTI 415 (SO2 controls) [NOTE: the class is currently for gaseous emissions, but no reason to have it
cover all gaseous pollutants since there is already a class on NOx and one on VOCs]
• APTI 427 (Combustion Evaluation)
• APTI 474 (Continuous Emission Monitoring) [NOTE: Combine with NACT 221 (Continuous
Emission Monitoring)]
• APTI 468 (Stack Testing) [NOTE: Combine with NACT 224 (Observing Source Tests)
• APTI 470 (Quality Assurance)
• NACT 290 (MACT Basics)
• CenSARA 210 (Technical Writing)
• CenSARA 220 (Public Relations and Risk Communications)
These are all foundation type classes to help people understand air pollution. As you will note, there is a
suggestion to combine some of the classes. There may be ones that were missed, but the idea is to avoid
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redundancy in classes. This will make it more efficient as presentations will not have to be maintained for
multiple classes that cover the same basic materials. The Technical Writing Class should updated to have
students actually write documents as the best way to become a better writer is to actually write.
Third Level of Classes to be Updated:
These are the industry specific classes that need to be updated after the foundational classes have been updated:
• NACT 245 (Cement Plants)
• NACT 246 (Aggregate, Concrete, and Hot Mix Asphalt Plants) [NOTE: combine with NACT 242
(Hot Mix Asphalt Facilities), NACT 243 (Aggregate Plants), and NACT 244 (Concrete Batch Plants)]
• NACT 271 (Stationary Reciprocating Engines)
• NACT 273 (Industrial Boilers)
• NACT 270 (Incinerators)
• NACT 272 (Power Plants)
These are the most common types of facilities we deal with in Iowa. You will note some of these classes have
been combined to avoid the redundancy. The idea is that these classes would cover not only the fundamentals of
how these operations work, but also the regulations that apply. Too often these classes don't go into enough
detail on the regulations.
Suggested Classes to Develop
There are several areas to look at for the development of new classes. The biggest area is on classes specific to
individual regulations. Those classes in order are:
(1) New Source Review/BACT Workshop
NOTE: There are NSR/PSD classes available from private companies, but EPA does not seem to be
involved in them. Maybe EPA doesn't need to develop these classes, but it would be very
helpful to have EPA staff attend these classes to ensure information being provided correctly
reflects EPA's interpretations.
Also, several Iowa DNR staff attended a workshop specifically designed for BACT review, but
it is not clear if this workshop is still available or just part of the NSR classes. A separate BACT
class could still have value.
(2) National Emission Standards for Hazardous Air Pollutants (NESHAP) training
(a) Subpart FFFF [Miscellaneous Organic Chemical Manufacturing (MON)]
(b) Hazardous Organic NESHAPs (Subparts F, G, H, and I)
(c) Surface Coating NESHAPs
(d) Boiler and Utility NESHAPs
(e) Pharmaceutical NESHAP
(3) Communication
NOTE: All of us can become better communicators which includes writing. The better we are at
communication the better we can become better at Public Relations and Risk Communication.
Some of the things that need to be covered are presentation skills, communicating with the public,
understanding how to write for different groups, etc.
(4) GHGs/Global Warming/Climate Change
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(5) Wet & Dry Scrubbers
NOTE: Scrubbers can be used for particulates or gasses. The class could cover the types of scrubbers
and their theory along with the proper uses.
(6) Seed Oil Extraction Processing
(7) Grain Processing (Examples: Wet vs. Dry Corn Mill Operations, Oats Processing, etc.)
(8) Ethanol Plants
(9) Nitrogen Fertilizer Processing
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Stationary Source Determinations
BACKGROUND:
One question that continues to come up in permitting is "What is a single stationary source?''' This question is
occurring more and more as companies do some of the following to improve their business practices:
• Outsource some operations (i.e. boiler operation, painting, backup generators, etc.). These operations
could be at their own building or at another nearby site.
• Move some operations to an existing building nearby rather than build a new building on existing
property.
• Partner with another company to produce a new product.
• Have subsidiaries of the same parent company locate on property owned by the parent company.
The Prevention of Significant Deterioration (PSD) and Title V regulations apply to "major stationary sources''' as
defined in their individual regulations. The National Emission Standards for Hazardous Air Pollutants
(NESHAP) applies to "major sources''' and "area sources''' as defined in its regulations. In all of these cases the
regulations refer back to the definition of "stationary source
The definition of "stationary source" is very similar for all of these regulations:
• PSD:
"Stationary source" means any building, structure, facility, or installation which emits or may emit a
regulated NSRpollutant. 567 IAC 33.3(1).
• Title V:
"Stationary source " means any building, structure, facility, or installation that emits or may emit any
regulated air pollutant or any pollutant listed under Section 112(b) of the Act. 567 IAC 22.100.
• NESHAP:
Stationary source means any building, structure, facility, or installation which emits or may emit any air
pollutant. 40CFR§63.2.
A closer review of the regulations shows the criteria used for each regulation in determining a stationary source:
• PSD:
"Building, structure, facility, or installation'' means all of the pollutant-emitting activities which belong
to the same industrial grouping, are located on one of more contiguous or adjacent properties and are
under the control of the same person (or persons under common control) except the activities of any
vessel. Pollutant-emitting activities shall be considered as part of the same industrial grouping if they
belong to the same major group (i.e., which have the same two-digit code) as described in the Standard
Industrial Classification Manual, 1972, as amended by the 1977 Supplement (U.S. Government Printing
Office stock numbers 4101-0066 and 003-005-00176-0, respectively). [567 IAC 33.3(1)]
• Title V:
"Major source" means any stationary source (or any group of stationary sources located on one or more
contiguous or adjacent properties and under common control of the same person or of persons under
common control) belonging to a single major industrial grouping that is any of the following:
1. A major stationary source of air pollutants, as defined in Section 302 of the Act...
2. A major stationary source of air pollutants according to Section 112 of the Act...
3. A major stationary source as defined in Part D of Title I of the Act...
(567 IAC 22.100)
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• NESHAP:
Major source means any stationary source of group of stationary sources located within a contiguous area
and under common control that emits or has the potential to emit...
and
Area source means any stationary source of hazardous air pollutants that is not a major source as defined
in this part.
(40 CFR §63.2)
Based on these definitions, there are three (3) criteria for a single stationary source for PSD and Title V are:
• Same 2-digit Standard Industrial Classification (SIC) code,
• Common control, and
• On contiguous or adjacent properties.
For the purposes of the NESHAP program there are only two (2) criteria:
• Common control and
• Located within a contiguous area
EPA has never provided definitions for any of these criteria. However, EPA has provided numerous guidance
documents in the form of case-by-case determinations to help agencies in making single stationary source
decisions.
The Department often needs to make single stationary source determinations. Most of these determinations are
for either PSD or NESHAP purposes. In order to reduce the amount of time needed to make these case-by-case
determinations the Department has developed a list of questions based on EPA guidance that, at a minimum, must
be answered by the company or companies involved along with any supporting documentation. The Department
may still request additional information, but by providing answers to these questions an applicant(s) will reduce
the majority of back and forth the Department encounters during its review of the case-by-case single stationary
source determinations.
These questions are based on EPA's guidance documents and letters. The questions are grouped under the
specific criteria. There is a brief explanation given under each of the criteria so an applicant has a better
understanding of what the Department is looking for and why the question is being asked. The questions are not
an exhaustive list, but a very good screening tool.
Some of the questions may repeat as it may cover two (2) or more of the criteria. The reason for this is that the
questions may not have to be answered for all of the criteria as it is often the case that only one of the criteria is in
question. For example, the two (2) operations could have the same owner and 2-digit SIC code so the only
question would be concerning whether the operations are contiguous or adjacent. If this is the case an applicant
would only need to answer the questions under the heading of "contiguous or adjacent". In other cases all three
(3) criteria may be in question and then an applicant would answer all of the questions.
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QUESTIONS:
General Information:
In order for the Department to gain a better understanding of the operations involved and what each operation
does the following questions shall be answered:
1) Please describe the nature of the business conducted by each operation.
2) Please describe in detail the manner in which either of the two (2) operations supports or contributes to
the output or production which occurs at the other operation.
Common Control:
EPA's regulations which the Department has adopted do not provide a definition for "common controF. Webster's
Ninth New Collegiate Dictionary defines control as:
• "to exercise restraining or directing influence over: Regulate"
• "to have power over: Rule"
• "an act or instance of controlling; also: power or authority to guide or manage"
• "the regulation of economic activity esp. by government directive"
Obviously common ownership constitutes common control. However, common ownership is not the only evidence
of control. EPA has used three (3) types of mechanisms for establishing common control. Those mechanisms are:
• Ownership of multiple operations by the same parent corporation or by a parent and a subsidiary of the parent
corporation.
• One entity has the power to direct the management and policies of a second entity, thus controlling the
operations through a contractual agreement or a voting interest.
• There is a contract for service relationship between the two (2) operations or if a support/dependency
relationship exists between the two (2) operations.
In 2018, EPA came out with new guidance interpreting the second item above to controlling the air pollution control
operations instead of the production operations (Meadowbrook letter). Therefore, in order to make a
determination on common control the following information is required:
1) Please state whether the operations are commonly owned or share common ownership in any way.
2) Please detail the current management structure of each operation. A flowchart is acceptable. Please
identify the following:
• Details from CEO & Board of Directors down to the Plant Manager
• Any common CEO(s)
• Any common Board of Directors members
• Any other common manager such as Plant Manager, Environmental Manager, etc.
• Any managers that at one time were shared by the two (2) operations.
• Any manager or other person in a decision making capacity that is responsible to the same third
parties or to third parties who are mutually owned or directed by the same parent or subsidiary
owners, by partial owners or by voting stockholders.
3) Please identify whether common workforces or security forces are now or ever have been shared by these
two (2) operations.
4) Please identify any equipment, control equipment or other property is now or ever has been shared by the
two (2) operations.
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5) Please state whether these two (2) operations share now or ever have shared common payroll activities,
employee benefits, health plans, retirement funds, insurance coverage, or other administrative functions.
6) Is there a contract or type of agreement, in writing or otherwise, between the two (2) operations?
• If there is a written agreement please provide a copy to the Department.
• The following questions are required to be answered in regards to any agreements between the two
(2) operations:
o What do any agreements between the two (2) operations specify with regard to pollution control
responsibilities at the two (2) operations?
o Can the managing entity of one of the operations make decisions that affect pollution control at
the other operation?
o Who accepts the responsibility for compliance with air quality control requirements and for
violations at the two (2) operations?
o Can either of the two (2) operations purchase raw materials from or sell products or byproducts to
customers other than the other operation?
o What are the arrangements for providing goods and services?
o What are the financial arrangements between the two (2) operations?
o What is the timeframe of any existing contractual or leasing relationships between the two (2)
operations?
o Is either operation responsible for legal duties of the other?
o Is either of the operations restricted by the other operation or due to its relationship with the other
operation from contracting with a third party to perform work for third parties?
7) Please state whether a change in the production levels at either one of the operations could or would
influence the production or operational levels at the other operation.
8) Please identify any administrative order or other governmental directive (such as a court order) that
dictates the control or independence of either of the two (2) operations or any other similarly situated
operations owned by either of these two (2) operations. Please attach copies of any relevant orders or
other governmental directives.
9) If either of the operations were to shut down, please state any limitations on the other facility to pursue
outside business interests.
10) Please state whether either of these operations is now or ever has been owned or otherwise controlled, in
whole or in part, by the other operation or both an owner thereof. If so, please state the nature of the
control and the beginning and ending dates.
11) Please disclose any interest, actual or prospective, that either of these operations has in property,
equipment, or other assets that the other operation possesses, requires, or uses for the operation of its
business.
12) Is the primary relationship between the two (2) operations that of tenant-landlord or lessor-lessee?
SIC Code:
Each individual emission unit at a plant can be assigned an SIC code. According to the August 7, 1980 Federal
Register (FR) preamble for the PSD regulations it was EPA's opinion:
".. .the December opinion of the court in Alabama Power sets the following boundaries on the definition
for PSD purposes of the component terms of "source": (1) it must carry out reasonably the purposes of
PSD; (2) it must approximate a common sense notion of "plant"; and (3) it must avoid aggregating
pollutant-emitting activities that as a group would not fit within the ordinary meaning of "building,"
"structure," "facility," or "installation." 45 FR 52694.
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EPA believed the two (2) digit SIC categories were narrow enough to separate sets of activities into common
sense groupings, but also broad enough to minimize the likelihood of artificially dividing a set of activities that
does constitute a "plant" into more than one (1) group.
In the August 7, 1980 preamble EPA further detailed its assigning of SIC codes for the purposes of PSD. It
stated:
"Each source is to be classified according to its primary activity, which is determined by its principal
product or group of products produced or distributed, or services rendered. Thus, one source
classification encompasses both primary and support facilities, even when the latter includes units with a
different two-digit SIC code. Support facilities are typically those which convey, store, or otherwise
assist in the production of the principal product. Where a single unit is used to support two otherwise
distinct sets of activities, the unit is to be included within the source which relies most heavily on the
support. For example, a boiler might be used to generate process steam for both a commonly controlled
and located kraft pulp mill and plywood manufacturing plant. If the yearly boiler output is used primarily
by the pulp mill, the total emissions of the boiler should be attributed to the mill." 45 FR 52695
So even though some equipment/emission units within a facility may not have the same 2-digit SIC code the
emissions from those operations cannot be excluded if they assist in the production of the primary product.
A classic example are boilers as boilers can supply steam and/or electricity to a company, but utility type
operations have their own 2-digit SIC code. Since the steam and electricity are used to assist in the
production of a product a company must consider its boilers as part of the stationary source even though the
2-digit SIC code is different. This concept is true for all operations and not just boilers. Some other
common examples are painting operations and grain receiving & handling equipment.
SIC codes can be viewed at http://www.osha.gov/oshstats/sicser.html. The process for identifying the 2-
digit SIC code at an operation is:
• Step 1 - Identify the primary activities at the site: the primary activity is determined based on the
services rendered or the principal product or group of products produced or distributed. There may
be more than one primary activity and each primary activity is considered a separate source.
• Step 2 - Identify any emission units at the site that could be classified 2-digit SIC code different
than that of the primaty activity.
• Step 3 - Assess the role of each of these units: Units that convey, store, or otherwise assist in the
production of the principal product are considered part of the primary activity. If the unit is used
for multiple activities then an assessment is required to determine which activity the unit is
assigned.
In order to make the assessment on the 2-digit SIC code the following questions are required to be
answered:
1) What is the two (2) digit SIC code(s) for each operation?
2) Please list all emission units with a different 2-digit SIC code then that stated in Question 1 along with its
2-digit SIC code.
3) Please detail the role of each emission unit in Question 2.
4) Please state whether any goods, including but not limited to raw materials or products (finished or
unfinished) are transferred between the two (2) operations on a routine or occasional basis. For each
instance of transfer, please describe the goods transferred, the frequency of transfer, and the method of
transfer (for example: truck, conveyor belt, pipe system, etc.).
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5) Please state whether the operations now or ever have shared intermediates, products, byproducts, or other
manufacturing equipment.
6) Please state whether either of these operations conducts business with any entity other than the other
operation. For each operation, state the percentage of business transacted with other entities.
7) Please state whether either of the two (2) operations purchases any of its raw materials or other products
from the other operation. If the answer is yes, then please state the raw materials or other products
purchased, and the history of such purchases.
Contiguous or Adjacent:
The issue of "contiguous or adjacent' tends to be the most controversial of the three (3) criteria. The reason for
the controversy is not just the fact that EPA has not defined the terms, but also because the guidance is all over the
board. One will find determinations where 50 miles was considered to be contiguous/adjacent and then other
decisions where less than 5 miles was not contiguous/adjacent.
The terms "contiguous" and "adjacent" are defined in Webster's Ninth New Collegiate Dictionary as:
• Contiguous
o "being in actual contact: touching along a boundary or at a point"
o "of angles: adjacent"
o "next or near in time or sequence"
o "touching or connected throughout in an unbroken sequence"
• Adjacent
o "not distant: nearby"
o "having a common endpoint or border"
o "immediately preceding or following"
Webster's goes on to state that adjacent, contiguous, adjoining, and juxtaposed are synonyms and mean in close
proximity. This leads to the inevitable question of "What does EPA consider close proximity?". EPA has not
defined this other than to say the question of "contiguous or adjacent" is a case-by-case determination and is not
be judged on physical distance alone as that is only one (1) factor. The question really becomes whether the
operations are close enough to act as one operation. In order to make this determination the following questions
are required to be answered:
1) Do these operations share a common boundary?
2) What is the straight line distance (property line to property line) between the two (2) operations?
3) Please state whether either of these operations are now or ever have been located on property owned by
the other operation or an owner thereof. If the answer is yes, please state the beginning and ending dates
of the relationship.
4) Please state whether these two (2) operations would have been located, would be located now, and would
continue to be located at their present sites if the other facility were not situated at its location.
5) If the facilities were sited further apart, would that significantly affect the degree to which they might be
dependent on each other?
6) Please state whether the operations now or ever have shared intermediates, products, byproducts, or other
manufacturing equipment.
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7) Please state whether any goods, including but not limited to raw materials or products (finished or
unfinished) are transferred between the two (2) operations on a routine or occasional basis. For each
instance of transfer, please describe the goods transferred, the frequency of transfer, and the method of
transfer (for example: truck, conveyor belt, pipe system, etc.).
8) Please state whether a change in the production levels at either one of the operations could or would
influence the production or operational levels at the other operation.
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IOWA DEPARTMENT OF NATURAL RESOURCES
Environmental Services Division
Air Quality Bureau
Construction Permitting Section
Memorandum
TO: Christopher A. Roling, CPM, MPA, PE
C:
FROM:
DATE:
RE:
Background:
[Provide background brief background on the companies/sites involved such as their plant numbers, addresses,
and their request (i.e. TV, PSD, NESHAP, etc.)]
Single Source Discussion:
[What are they requesting for a determination?]
• Common Control
In the past, EPA used three (3) types of mechanisms for establishing common control. Those mechanisms are:
(1) Ownership of multiple sources by the same parent corporation or by a parent and a subsidiary of the
parent corporation.
(2) One entity has the power to direct the management and policies of a second entity, thus controlling the
operations through a contractual agreement or a voting interest.
(3) There is a contract for service relationship between the two (2) companies or if a support/dependency
relationship exists between the two (2) companies.
In 2018, EPA came out with new guidance interpreting the second item above to controlling the air
pollution control operations instead of the production operations (i.e. Meadowbrook letter).
[Provide analysis of the companies/sites and whether there is common control based on the regulations and
EPA's guidance. This does include your proposed determination on common control. You may need to
obtain contracts between the companies and have Legal review them to make this determination.]
• SIC Code
Each individual emission unit at a plant can be assigned an SIC code. According to the August 7, 1980
Federal Register (FR) preamble for the PSD regulations it was EPA's opinion:
"... the December opinion of the court in Alabama Power sets the following boundaries on the
definition for PSD purposes of the component terms of "source (1) it must carry out reasonably
the purposes of PSD; (2) it must approximate a common sense notion of "plant"; and (3) it must
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avoid aggregating pollutant-emitting activities that as a group would not fit within the ordinary
meaning of "building, " "structure, " "facility, "or "installation. " 45 FR 52694.
EPA believed the two (2) digit SIC categories were narrow enough to separate sets of activities into
common sense groupings, but also broad enough to minimize the likelihood of artificially dividing a set
of activities that does constitute a "plant" into more than one (1) group.
In the August 7, 1980 preamble EPA further detailed its assigning of SIC codes for the purposes of PSD.
It stated:
"Each source is to be classified according to its primary activity, which is determined by its principal
product or group of products produced or distributed, or services rendered. Thus, one source
classification encompasses both primary and support facilities, even when the latter includes units
with a different two-digit SIC code. Support facilities are typically those which convey, store, or
otherwise assist in the production of the principal product. Where a single unit is used to support two
otherwise distinct sets of activities, the unit is to be included within the source which relies most
heavily on the support. For example, a boiler might be used to generate process steam for both a
commonly controlled and located kraft pulp mill and phnvood manufacturing plant. If the yearly
boiler output is used primarily by the pulp mill, the total emissions of the boiler should be attributed
to the mill. " 45 FR 52695
So even though some equipment/emission units within a facility may not have the same 2-digit SIC code
the emissions from those operations cannot be excluded if they assist in the production of the primary
product. A classic example are boilers as boilers can supply steam and/or electricity to a company, but
utility type operations have their own 2-digit SIC code. Since the steam and electricity are used to assist
in the production of a product a company must consider its boilers as part of the stationary source even
though the 2-digit SIC code is different. This concept is true for all operations and not just boilers. Some
other common examples are painting operations and grain receiving & handling equipment.
SIC codes can be viewed at https://www.osha.gov/pls/imis/sicsearch.html. The process for identifying
the 2-digit SIC code at an operation is:
o Step 1 - Identity the primary activities at the site: the primary activity is determined based on the
services rendered or the principal product or group of products produced or distributed. There may be
more than one primary activity and each primary activity is considered a separate source,
o Step 2 - Identity any emission units at the site that could be classified 2-digit SIC code different than
that of the primary activity.
o Step 3 - Assess the role of each of these units: Units that convey, store, or otherwise assist in the
production of the principal product are considered part of the primary activity. If the unit is used for
multiple activities then an assessment is required to determine which activity the unit is assigned.
[Provide discussion and analysis on whether the sites have the same 2-digit SIC code or should be
considered to be supporting operations.]
2
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• Contiguous or Adjacent
In the past the actual distance between two (2) or more sites was a factor in whether the sites were considered
adjacent/contiguous. EPA also looked at the inter-relationship between the sites to see if the sites acted as one
(1) source (i.e. did they meet the "common sense notion of a plant") to make a determination. However, that
changed with the August 7, 2012 Sixth Circuit Court decision regarding Summit Petroleum Corporation
[SummitPetroleum vs. USEPA, 690 F.3d 733 at 737 (6th Cir. 2012)]. In that 2-1 decision the majority ruled:
"... activities should be aggregated only if they are located on physically contiguous or adjacent properties. "
The issue of "contiguous or adjacent' has always been the most controversial of the three (3) criteria and
this court decision did not resolve the controversy. The main reason for the controversy is the fact that
EPA has never defined the terms "contiguous" and "adjacent" in its rules.
The terms "contiguous" and "adjacent" are defined in Webster's Ninth New Collegiate Dictionary as:
~ Contiguous
"being in actual contact: touching along a boundary or at a point"
"of angles: adjacent"
"next or near in time or sequence"
"touching or connected throughout in an unbroken sequence"
~ Adjacent
"not distant: nearby"
"having a common endpoint or border"
"immediately preceding or following"
Webster's goes on to state that adjacent, contiguous, adjoining, and juxtaposed are synonyms and mean in
close proximity. So in the past the inevitable question was "What does EPA consider close proximity? "
EPA never defined this other than to say the question of "contiguous or adjacent" is a case-by-case
determination and was not to be judged on the physical distance alone as that is only one (1) factor. The
question was whether the operations were close enough to act as one operation.
Now the question is " What does the Court consider close proximity or nearby? " since distance is the only
factor that is to be considered based on the court decision. EPA provided draft guidance in 2018 for sources
other than the oil and gas industry as they have a distance requirement in the rule. For all other industries
EPA is proposing that agencies should look only at distance and not consider any interactions between sites.
EPA did not say how far apart was too far in the draft guidance document, but did say a dedicated road,
conveyor belt and/or piping between the properties could be enough to consider the properties to be
considered in close proximity to one another. Finally, EPA said agencies should consider whether sites
meet the "common sense notion of a plant." Please note, this last statement by EPA confuses the issue as
"common sense notion of a plant" is not a distance criteria, but an interaction criteria. The Iowa Air Quality
Bureau did comment on the draft guidance document about this apparent contradiction.
[Provide a discussion on why the sites are or are not adjacent/contiguous]
Conclusion:
3
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[Provide your final conclusion on whether the sites/operations are considered one. They could be a single source
or multiple sources for all programs or maybe a single source for NESHAP, but not for TV/PSD. Also, they have
to meet all of the criteria to be a single source.]
This determination regarding sole source status has been made based on the specific facts addressed in the current
case. If the information changes or is incorrect this determination could also change. In addition, this
determination shall not be used to bind the Department in any other case.
4
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Questions:
Nature & Extent
Provide a detailed description of the project. This description must list all changes to be made during
the project (overhaul of engine). Also, please provide a percentage of the unit that is being repaired or
replaced. For this question, please provide a detailed description of what is being done during the
overhaul.
The turbine exchange project involves removing the existing engine (gas producer and power turbine)
from the skid and exchanging these components with used refurbished parts and some new parts that
are like-for-like overhauled components. These are the same parts that would be replaced if the turbine
was overhauled in place. There are no physical changes made to the unit. The components come from a
third-party's central exchange component fleet. The exchange components are those which have been
completely disassembled and inspected for damage, wear, or other signs of deterioration. Repairs are
conducted, as necessary, and the components reassembled and tested to ensure original thermodynamic
and mechanical performance. The original turbine package, including all auxiliary components and
associated systems (control system, fuel system, lubrication system, driven equipment, structure,
enclosures, skids, inlet and exhaust ducting, etc.), are reused. No changes, modifications, or upgrades are
made during a turbine exchange. It is a like-for-like exchange of the original turbine equipment with
exchange turbine equipment of the same make and model with identical horsepower and emission
characteristics compared to original turbine design.
Like many engine overhauls the overhaul of this turbine consists of a majority of refurbished parts and
consumable parts replaced with new components. This puts the percentage of the unit being repaired or
replaced between 40% and 60% depending on component condition.
How long will the project take to complete? The turbine component exchange work normally takes 4
days and is conducted by Northern Natural Gas (Northern) and original equipment manufacturer
personnel jointly.
How long is your normal maintenance shutdown period? Northern normally schedules 4-7 days to
complete the turbine component exchange work, as this work is often combined with other unit
maintenance or unit project work.
Are the replacement components of the same design as the components they are replacing? No
changes, modifications, or upgrades are made during a turbine exchange. It is a like-for-like exchange of
the original turbine equipment with exchange turbine equipment of the same make and model with
identical horsepower and emission characteristics compared to original turbine design.
What is done on a shorter-term basis (annual, etc.) to these units and who does this maintenance? For
this type of turbine, exchanges routinely are completed approximately every 30,000 hours of run-time
consistent with manufacturer's recommendations. Actual turbine run-time is highly variable over time
and depends on turbine location, weather, and customer loads. In the case of the turbine located at the
Oakland Compressor Station (Oakland), EP-T1, this was the first turbine exchange since the original
turbine was installed in 2006. On an annual basis, and in between turbine exchanges, Northern conducts
routine preventative maintenance such as air/oil/fuel filter replacements, instrument calibration, internal
cleaning, oil sampling, etc. A borescope inspection of the unit is also conducted to assess internal
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condition. Other non-routine maintenance such as control module or instrument replacements are
conducted on an as needed basis. Northern field operations personnel conduct this work with assistance
from a field services representative from the original equipment manufacturer, if required.
How long does it take? Routine annual maintenance typically takes a few days per year.
What percentage of the unit is replaced or repaired. Typically, only very minor and very low cost
replacement parts are required on an annual basis in between turbine exchanges such as, but not limited
to, filter elements, field instruments, or control modules.
Purpose
Please provide a brief description of why this project is being undertaken at this time. The unit reached
the original equipment manufacturer's recommended time for an engine overhaul (30,000 hours). In
Northern's experience, turbine reliability is unpredictable past this threshold, and the risk of catastrophic
equipment failure and extended unplanned unit downtime increases. Thus, the turbine was exchanged 1)
to ensure safe operation of the equipment for Northern's personnel and 2) to ensure reliable and cost
effective service to the public.
What was the expected lifetime of the unit (the entire turbine and the core) when it was first installed?
Life expectancy of an entire turbine unit is highly variable depending on a number of factors including
historical operating and maintenance practices, environmental factors, industry support, availability of
spare parts, etc. It can range anywhere from 30 to 80 years depending on the circumstances so long as
the original equipment manufacturers operating, maintenance, and turbine component exchange
recommendations are followed.
Will the changes increase availability or reliability of the unit? In Northern's experience, in the absence
of conducting the routine, manufacturer's recommended overhaul, turbine reliability is unpredictable
past the 30,000-hour operation threshold, and the risk of catastrophic equipment failure and extended
unplanned unit downtime increases. Thus, the turbine was exchanged 1) to ensure safe operation of the
equipment for Northern's personnel, and 2) to ensure reliable and cost effective service to the public.
Northern is conducting industry standard, routine maintenance through completing these overhauls.
Will the changes extend the lifetime of the unit (entire turbine)? There are no physical changes made
to the unit. Exchange of the gas producer and power turbine every 30,000 run-hours in accordance with
the manufacturer's routine maintenance recommendations is necessary to ensure safe, reliable
operation, mitigate risk of significant unplanned downtime, and ensure reliable service to the public.
What was the original maximum rated capacity of the unit? 15,000 Horsepower.
What is the current capacity of the unit? 15,000 Horsepower.
Will the changes restore the unit to its original rated capacity? The design capacity of the current
exchange turbine and the original turbine is the same. There are no physical changes made to the unit.
The purpose of the overhaul is to return the gas turbine to the original thermodynamic and mechanical
performance. Routine overhaul of the modules is a fundamental assumption of the product design.
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For combustion units:
What was the original efficiency of the unit? 34.41% design thermal efficiency
What is the current efficiency of the unit? 34.41% design thermal efficiency
Will the changes restore the unit to its original efficiency? The design thermal efficiency of the original
turbine and current exchange turbine is the same. There are no physical changes made to the unit. The
purpose of the overhaul is to return the gas turbine to the original thermodynamic and mechanical
performance. Routine overhaul of the modules is a fundamental assumption of the product design.
Frequency
Gas turbines, like any engine, are designed with requirements for certain maintenance and/or repair
activities to maintain the life expectancy of the engine. In accordance with manufacturer's
recommendations, one such maintenance/repair activity is to overhaul the gas producer and power
turbine modules at ~30,000 operating hour intervals.
Cost
What annual operation and maintenance budget for the unit? Annual operation and maintenance
expenses for the Oakland turbine are included within the annual budget for the Oakland facility and
surrounding pipeline infrastructure and are not broken out per unit. A very rough estimate for annual
operation and maintenance costs for this type of unit between turbine exchanges is approximately
$75,000 per year excluding fuel and utilities.
What is the cost of this project (overhaul of engine)? The estimated cost of the exchange components
(gas producer and power turbine) is $1,938,624. According to the original equipment manufacturer, the
replacement of the gas producer and power turbine with exchange components would typically cost 17-
32% of comparable new equipment.
Where will the funding from this project come from (i.e. O&M budget or capital expenditure)? Capital
Does your company follow Generally Accepted Accounting Principles (GAAP)? Yes
Is this project being capitalized or expensed? Capitalized - Financial accounting guidance requires that
when a plant retirement unit is replaced, the original unit must be retired and the replacement unit
capitalized. The exchange of a used turbine with a like-like refurbished/overhauled spare turbine falls
under this guidance. Accounting guidance requires that when a retirement unit is overhauled (and NOT
replaced), the cost of the overhaul is to be expensed. Though these maintenance expenses may be
capitalized or expensed depending on the exact nature of the work in accordance with prevailing
accounting rules, maintenance/overhaul work is performed on the exchange turbine in the exact same
manner and per the same manufacturer's guidelines in both cases. The only difference is the exchange
program allows for a fully overhauled turbine to be ready for immediate installation when the original
used turbine is removed, thus reducing down time of the unit to a few days instead of a few months of
down time that would otherwise be required to wait for the original turbine to be overhauled and
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reinstalled. This substantial reduction in unit down time achieved by turbine exchange versus in place
overhaul is necessary for continuity of reliable and cost effective service to the public.
Although this activity is classified as a capital expenditure, it does not result in an increase to the capacity
of the unit, and it is Northern's understanding that this does not meet the definition of modification under
NSPS.
What is the cost of overhauling this engine compared to buying a new one? The estimated cost of the
exchange components (gas producer and power turbine) is $1,938,624. If the same gas producer and
power turbine were purchased outright as new components, independent of an exchange, the cost would
be approximately $5,500,000 (35%). According to the original equipment manufacturer, the replacement
of the gas producer and power turbine with exchange components would typically cost 17-32% of
comparable new equipment.
Since the costs for the turbine overhaul does not exceed 50% of the costs to install a new turbine,
Northern understands that this does not meet the definition of reconstruction under NSPS.
What is the cost of the engine compared to the overall turbine unit? The estimated cost of the exchange
components (gas producer and power turbine) is $1,938,624. If the existing Oakland turbine including all
auxiliaries, supporting systems, and infrastructure were entirely replaced, the cost would exceed
$26,000,000.
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ENGINEERING EVALUATION
Date: October 29, 2020 Project Number: 20-115
Plant Number: 78-04-006 Field Office: 4
Determination
Facility: Northern Natural Gas Company- Oakland Compressor Station
Project Description:
The Department received an applicability determination request from Northern Natural Gas Company for
their Oakland Compressor Station on April 21, 2020. This was a determination for NSPS subparts GG
and KKKK (Standards of Performance for Stationary Combustion Turbines) concerning a turbine core
changeout performed at the Oakland Compressor Station. Specifically, the facility requested a
determination on whether this changeout is considered routine maintenance, repair and replacement
(RMRR) activities under the NSPS regulations.
It is the Department's opinion that the turbine change-out project is not considered routine maintenance,
repair or replacement under the NSPS regulations. The determination along with supporting justification
is given below.
Discussion
As noted in the request, a turbine at the Oakland Compressor Station was exchanged with an existing like-
for-like overhauled unit. Based on the information supplied to the Department; the project included the
following:
"The turbine exchange project involves removing the existing engine (gas producer and power
turbine) from the skid and exchanging these components with used refurbished parts and some
new parts that are like-for-like overhauled components. These are the same parts that would be
replaced if the turbine was overhauled in place. These are the same parts that would be replaced
if the turbine was overhauled in place. There are no physical changes made to the unit. The
components come from a third-party's central exchange component fleet. The exchange
components are those which have been completely disassembled and inspected for damage, wear,
or other signs of deterioration. Repairs are conducted, as necessary, and the components
reassembled and tested to ensure original thermodynamic and mechanical performance. The
original turbine package, including all auxiliary components and associated systems (control
system, fuel, system, lubrication system, driven equipment, structure, enclosures, skids, inlet and
exhaust ducting, etc.), are reused. No changes, modifications, or upgrades are made during a
turbine exchange. It is a like-for-like exchange of the original turbine equipment with exchange
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Northern Natural Gas Company- Oakland Compressor Station
Project Number: 20-115
Page 2 of 5
turbine equipment of the same make and model with identical horsepower and emission
characteristics compared to original turbine design. "
In the request, Northern Natural Gas requested that the Iowa DNR concur with the opinion that this
activity is considered RMMR, and thus not considered a modification under the NSPS regulations.
Under the NSPS regulations any physical changes or changes in method of operations must be reviewed.
The definition of modification under the New Source Performance Standards (NSPS) is:
"any physical change in, or change in the method of operation of a stationary source which
increases the amount of any air pollutant emitted by such source or which results in the emission
of any air pollutant not previously emitted." (see 40 CFR 60.2)
However, an activity that is considered RMRR is not considered a modification (see 40 CFR 60.14(e)(1)).
"Maintenance, repair, and replacement which the Administrator determines to be routine for a
source category, subject to the provisions ofparagraph (c) of this section and §60.15. "
The NSPS regulations do not specify the kinds of activities included as RMRR. Rather, eligibility for the
RMRR exemption is determined based on a case-by-case analysis, "weighing the nature, extent, purpose,
frequency, and cost of the proposed work, as well as other relevant factors, to arrive at a common-sense
determination." This review process is based on EPA's longstanding guidance affirmed through a number
of court cases. See the attached Department Memo labeled Routine Maintenance, Repair, and
Replacement for a list of these cases.
It should be noted, EPA has stated in previous opinions that the routine activity exception has a narrow
scope and should generally be applied only to actions that are regular, frequent, inexpensive, or done for
the purpose of maintaining the facility in its present condition. See the September 9, 1988 Memorandum
from Don R. Clay, Acting Assistant Administrator for Air and Radiation to David A. Kee, Director, Air
and Radiation Division, Region V (Clay Memorandum) at page three, states that the clear intent of the
PSD regulations is to construe "physical change" very broadly, to cover virtually any significant
alteration to an existing plant and to interpret the exclusion related to routine maintenance, repair and
replacement narrowly.
After carefully reviewing all the information submitted in light of the relevant factors, IDNR determined
that the turbine core changeout is not routine. A review of the four factors used to make this
determination is given below.
In most cases engine core changeouts are not considered a modification under NSPS because there is not
an increase in emissions. In these cases, it would not be a modification because there is not an increase in
the amount of any air pollutant emitted by the source or which results in the emission of any air pollutant
not previously emitted. In this case, however, there was an increase in emissions, causing it to be a
modification under NSPS. And, as was determined here, a turbine core changes out cannot be considered
RMRR to exclude it as a modification.
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Northern Natural Gas Company- Oakland Compressor Station
Project Number: 20-115
Page 3 of 5
Nature & Extent
Based on the information supplied, the turbine core exchange project required extensive changes. In this
project, the entire gas producer and turbine sections were replaced or repaired. As noted, this results in
between 40% and 60% of the unit being modified. This differs from the regular maintenance done on an
annual or as needed basis, and in between turbine exchanges, such as air/oil/fuel filter replacements,
instrument calibration, internal cleaning, oil sampling, etc. Also, in this case, this was the first turbine
exchange since the original turbine was installed in 2006. Replacing up to 60% of the unit is much more
extensive than the regular maintenance done on the unit annually. Hence, the turbine core replacement is
much more extensive than the regular routine maintenance that is done on the unit, suggesting it is not
routine.
In addition, the work was performed with the assistance of outside contractors, instead of being done solely
by plant personal. A third-party's central exchange component fleet was used to make the exchange. Also,
this work was conducted by Northern Natural Gas (Northern) and original equipment manufacturer
personnel jointly. The use of outside contractors to perform the work suggests that this is not a routine
activity. See the attached Department Memo labeled Routine Maintenance, Repair, and Replacement.
Considering all of these factors, the turbine core replacement project required extensive changes indicating
that it is not a routine activity.
Purpose
As stated in the request, the purpose of the overhaul was to return the gas turbine to the original
thermodynamic and mechanical performance. Hence, this activity did not increase the capacity or efficiency
of the unit, which may suggest it is a routine activity.
Frequency
As stated in the request, the turbine core change out was done in accordance with manufacturer's
recommendations, one such maintenance/repair activity is to overhaul the gas producer and power turbine
modules at approximately 30,000 operating hour intervals. Being done at regular intervals may suggest that
it is routine activity, in isolation. However, this was the first turbine exchange since the original turbine was
installed in 2006, which suggests it is not a routine activity.
Cost
After reviewing the costs of the project, the project costs are relatively high, suggesting it is not routine.
This conclusion was drawn based on the following facts:
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Northern Natural Gas Company- Oakland Compressor Station
Project Number: 20-115
Page 4 of 5
• The estimated cost of the exchange components (gas producer and power turbine) is $ 1,93 8,624.
According to the original equipment manufacturer, the replacement of the gas producer and
power turbine with exchange components would typically cost 17-32% of comparable new
equipment. In this case, the replacement cost will be approximately 35% of a new unit. A cost of
this magnitude suggests that the replacement was not routine.
• The annual maintenance budget for this unit was estimated at $75,000 (or $225,000 over three
years). The cost of the turbine replacement is $1,938,624, which is approximately nine times the
annual budget extended over three years. A cost of this size in comparison to regular annual
maintenance suggests that the replacement was not routine.
• The project is capitalized. EPA and the courts have in the past consistently considered accounting
characterization as one factor to be considered. The courts have strongly indicated that charging a
project to the capital budget may be enough to disqualify it from the RMRR exclusion. In
addition, the IDNRhas also historically not viewed projects that are capitalized to not be routine.
See the attached Department Memo labeled Routine Maintenance, Repair, and Replacement.
• Also, a cost of nearly two million is well within the range which EPA has determined to not be
routine in previous decisions. See attached determination for Tennessee Department of
Environment and Conservation, dated September 14, 2001 as one example.
Considering all of cost factors, the project is relatively expensive, which indicates that it is not a routine
activity.
Other consideration
The project under review in this determination resulted in an increase in emissions. Performance testing
done on the replaced unit showed an increase in NOx emissions greater than 80%. An increase in
emissions of this magnitude suggests that the replacement was not routine.
Conclusion
The turbine core changeout project required a significant undertaking to complete. In particular, the
changes are relatively extensive and expensive compared to other routine maintenance activities
performed on the unit. In addition, the project resulted in an increase in emissions for the unit. Therefore,
weighing all of the factors, the Department does not consider this turbine change-out project routine
maintenance, repair, and replacement.
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Northern Natural Gas Company- Oakland Compressor Station
Project Number: 20-115
Page 5 of 5
Attachments to Evaluation:
x Correspondence (emails or letters)
x
Other Supporting Documentation
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Fields of Opportunities
STATE OF IOWA
Chester J. Culver, governor
Patty Judge. Lt. governor
DEPARTMENT OF NATURAL RESOURCES
RICHARD A. LEOPOLD, DIRECTOR
ir Quality Bureau
Memo
To: Dave Phelps
From: Christopher A. Roling, PE
Date: 04/08/10
Re: Routine Maintenance, Repair, and Replacement (RMRR)
As the equipment at companies continues to age they will have to make a decision on whetherto replace the old
equipment with newer equipment or perform repairs to keep the equipment running. This means more and more
applicants will be requesting a determination related to the Routine Maintenance, Repair, and Replacement
(RMRR) provisions under the Prevention of Significant Deterioration (PSD) regulations. Therefore, the
Department will continue to see the RMRR question and needs to have a plan in place to handle these
determinations on a consistent basis.
Background:
The Clean Air Act (CAA) was enacted in 1970 "to protect and enhance the quality of the nation's air resources so
as to promote the public health and welfare and the productive capacity of its population." 42 U.S.C. § 7401 (b).
The CAA defines a new source as
"any stationary source, the construction or modification of which is commenced after the publication of
regulations (or, if earlier, proposed regulations) prescribing a standard of performance under this section
which will be applicable to such source." 42 U.S.C. § 7411(a)(2)
A stationary source is "any building, structure, facility, or installation which emits or may emit any air pollutant." 42
U.S.C. § 7411(a)(3) with the term modification being defined as
"any physical change in, or change in the method of operation or, a stationary source which increases
the amount of any air pollutant emitted by such source or which results in the emission of any air pollutant
not previously emitted." 42 U.S.C. § 7411(a)(4)
Therefore, a plant constructed before the CAA is not required to obtain a permit until it undergoes a modification.
The CAA was amended in 1977 to add two (2) programs. One of these programs was the Prevention of
Significant Deterioration (PSD) program. The combination of the PSD program and the Non-Attainment New
Source Review Requirements (NNSR) are collectively referred to as New Source Review (NSR) Program.
NSR applies to both new and modified sources of air pollution and requires major sources of air pollution to obtain
permits prior to construction. Based on the above definitions it is clear Congress chose to "grandfather" existing
7900 Hickman Road, Suite 1 / Windsor Heights, Iowa 50324
515-242-5100 FAX 515-242-5094 http://www.iowacleanair.com/
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sources from NSR underthe CAA. However, it is also clear that Congress did not intend that existing sources be
forever grandfathered as compliance with the CAA is triggered when an existing source makes a modification
which results in an increase in emissions unless there is a regulatory exemption that applies.
The definition of modification underthe NSR Program in the CAA is the same as that used for the New Source
Performance Standards (NSPS) which is:
"any physical change in, or change in the method of operation of, a stationary source which increases
the amount of any air pollutant emitted by such source or which results in the emission of any air pollutant
not previously emitted." 42 U.S.C. § 7411(a)(4)
EPA defined major modification underthe PSD regulations as:
"any physical change in or change in the method of operation of a major stationary source that would
result in a significant net emissions increase of any pollutant subject to regulation underthe Act." 40 CFR
§52.21 (b)(2)®
There are several exceptions to the definition of "physical change in or change in the method of operation". One
of those exclusions is "routine maintenance, repair and replacement (RMRR)" [40 CFR §52.21 (b)(2)(iii)(a)]. The
Department has adopted these rules in 567 IAC Chapter 33. There is no regulatory definition of what is
considered "routine" and this has been one of the main issues in several court cases.
Court Cases:
There have been several court decisions concerning RMRR over the last 5-6 years. However, all of these
decisions relate back to one (1) utility case which is Wisconsin Electric Power Co. v. Reilly (7th Circuit 1990) which
is referred to as WEPCO.
One of the main items from the WEPCO decision was the "Multi-factor Test' for determining RMRR. The Multi-
factor test is a case-by-case analysis of each activity looking at:
¦ Nature & extent
¦ Frequency
¦ Purpose
¦ Cost
The court cases following WEPCO have provided additional guidance when conducting the case-by-case Multi-
factor Test. The main cases that EPA cites are:
• United States v. Southern Indiana Gas and Electric Company (Southern District of Indiana, February 13,
2003)
• United States v. Ohio Edison (Southern District of Ohio, 2003)
• United States, et al., v. Duke Energy Corporation (Middle District of North Carolina, 2003)
• United States, et al., v. Cinergy Corp. (Southern District of Indiana, 2007)
All of these cases combined give a person insight on both the scope of the regulation and the types of issues a
person needs to look at when making RMRR determinations.
Page | 2
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Questions to Ask Company for RMRR Determinations:
Two (2) items are very clear from the court decisions:
1.) The courts have agreed that a case-by-case analysis for RMRR determinations is reasonable and
2.) The four factors to consider are the nature & extent of the project, the purpose of the project, the
frequency of the project, and the cost of the project.
In order forthe Department to obtain the best information possible in order to make its determination the following
information, at a minimum, must be supplied by the company along with supporting documentation to backup
their answers:
~ Nature & Extent
o Provide a detailed description of the project. This description must list aM changes to be made
during the project. Also, please provide a percentage of the unit that is being repaired or
replaced.
o Will the project be done by in-house maintenance staff or outside contractors?
o Have there been any planning studies prepared in preparation for the project? If so, please
provide a copy of all studies.
o How long will the project take to complete? How long is your normal maintenance shutdown
period?
o Are the replacement components of the same design as the components they are replacing?
~ Purpose
o Please provide a brief description of why this project is being undertaken at this time,
o What was the expected lifetime of the unit when it was first installed?
o What is the unit's current age?
o Will the changes increase availability or reliability of the unit?
o Will the changes extend the lifetime of the unit?
o What was the original maximum rated capacity of the unit?
o What is the current capacity of the unit?
o Will the changes restore the unit to its original rated capacity?
o For combustion units:
¦ What was the original efficiency of the unit?
¦ What is the current efficiency of the unit?
¦ Will the changes restore the unit to its original efficiency?
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Frequency
o Are the components being repaired/replaced the original components?
o How often are these changes made to the unit during its lifetime?
o How often are these changes made to similar units elsewhere?
Cost
What is your company's annual operation and maintenance (O&M) budget?
What is the cost of this project?
Where will the funding from this project come from (i.e. O&M budget or capital expenditure)?
Does your company follow Generally Accepted Accounting Principles (GAAP)?
Is this project being capitalized or expensed?
Guidance:
Based on the court cases there are some general concepts that need to be followed when making determinations
on RMRR:
> The term "modification" was defined broadly in the CAA by Congress.
> The need for some repairs during the lifetime of a unit is a given in determining the life expectancy of a
plant whether those repairs are annually or only a couple of times in its lifetime.
> Changes that are not frequent, come at a great cost, extend the lifetime of the unit, and require the unit
to be out of service for an extended period of time (i.e. months) are not considered to be "routine".
> RMRR is to be interpreted narrowly on a case-by-case basis. The WEPCO court pointed out that the
CAA should not be interpreted in a way that "would open vistas of indefinite immunity from the provisions
ofNSPS and PSD." WEPCO, 893 F.2d at 909.
> A case-by-case analysis taking into account the nature & extent of the activity as well as its purpose,
frequency, and cost has been considered a reasonable approach. The courts have taken into
consideration several things under each of these factors for determining whether the change is "routine":
o Nature & Extent:
¦ Use of outside contractors: A company's maintenance group is responsible for day-to-
day maintenance of plant equipment. The maintenance staff will also generally perform
work during scheduled planned outages. In contrast, the work performed during
extended outages is generally beyond the capacity of the in-house maintenance staff.
¦ Several multi-volume planning studies: The use of multiple and extensive planning
studies can be an indication of a project that is not "routine".
¦ Amount of time to complete the project: A project that is "routine" is typically going to
be done during a scheduled shutdown for maintenance which is typically a week to
maybe a month depending on the type of unit. In contrast, a non-routine project will
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generally have its own shutdown period and be for an extended amount of time such
as several months.
¦ A majority of the unit was modified, replaced, redesigned or upgraded: If a large portion
of the unit is being changed then that is an indication of the change not being "routine".
¦ Not like-kind replacements: If the components going in are not of the same design then
that would be an indication the change is not "routine". An example of this is in the case
of the Ohio Edison case. One of the changes Ohio Edison made was to replace and
redesign its entire vertical tube furnace with a spiral tube furnace which was the first of
its kind in the United States. The Court said this redesign was clearly not "routine".
o Purpose:
¦ Do the repairs reduce the number of forced outages or improve availability & reliability?:
Changes to reduce forced outages or improve the availability or reliability of a unit are
not considered "routine". If the changes were done on a routine basis then a person
would anticipate not having forced outages or reduced availability or reduced reliability.
Basically, if a company has waited this long then its changes cannot be considered
"routine".
¦ Do the changes extend the lifetime of the unit?: Every piece of equipment has an
anticipated lifetime considering routine maintenance, replacement, and repair of
components. If the changes being made will extend the lifetime of the unit beyond that
point then the changes are no longer "routine". An example is if the unit has a 30 year
lifetime, but the changes will allow it to operate an additional 30 years for a total of 60
years.
¦ Do the changes restore the unit to its original capacity or efficiency?: If changes are
truly "routine" in nature it is anticipated that the capacity or efficiency would not degrade
to the point that it would have to be restored. Therefore, changes to restore the capacity
or efficiency are a strong indication that they are not of a "routine" nature.
o Frequency:
¦ Are the original components being replaced?: If the original components are being
replaced for the first time in the lifetime of the unit then that can be an indication of a
non-routine change especially if the unit is near the end of its expected lifetime.
¦ How freguentlv are the changes made on the unit and within the industry?: This is
probably the most confusing question overall. It is also the most scrutinized. EPA has
stated that one should only consider activities that are routine for the unit and that if the
change only occurs once or twice during the lifetime of the unit then it cannot be
"routine".
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In a couple of the court cases the courts have agreed with EPA. For example, in the
Ohio Edison case the court said:
"It is the frequency of an activity at a particular unit that is most instructive..."
And
" Types of activities undertaken within the industry as a whole have little bearing
on the issue if an activity is performed at a unit only once or twice in the lifetime
of that unit."
However, in the Southern Indiana Gas & Electric case the court said the frequency of
similar projects within an industry can inform the analysis so long as the exemption does
not "swallow the modification rule".
In the Duke Energy case the court evaluated what was routine within the industry and
stated:
"Determination of RMRR cannot turn exclusively on whether a particular
replacement project has ever occurred in the industry. If this were dispositive,
it would render the PSD program a nullity."
Fortunately, there is middle ground on this issue. It is apparent that one needs to look
at frequency both on the individual unit and within the industry. As stated earlier every
unit has an anticipated lifetime. So if a unit has a 30 year lifetime there are many repairs
& maintenance activities that will occur during its lifetime. Some will be annually, others
every 2-5 years, and others possibly only a couple of times during its lifetime.
The fact that a repair or replacement occurs only once or twice in the lifetime is not a
reason to automatically call it non-routine. For example, if there are components that
one would anticipate having to replace once in a unit's 30 year lifetime because that is
normal for the industry then one would expect the replacement to occur around the 15
year period. However, ifthat replacement occurred in year25 then it is a clear indication
the change was not "routine", but rather a way to extend the lifetime of the equipment.
Similarly, if the change occurs in year 5 then it is also not likely to be a "routine" change.
Basically, the frequency of the change for both the unit and within the industry needs to
be considered along with the age of the unit in order to make the determination on
whether or not it is considered RMRR.
o Cost:
¦ Capital expenditure vs. operation & maintenance (O&IVD: If the funding for the project
comes from the normal O&M budget then it is a strong indication of the project being
"routine" whereas if the project is non-routine it will likely be funded from a capital
expenditure budget.
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¦ Capitalized vs. expensed: If the company follows Generally Accepted Accounting
Principles (GAAP) then costs incurred to achieve greater future benefits are capitalized
whereas costs that simply maintain a given level of service are expensed. In order for
a cost to be capitalized one (1) of three (3) conditions must be present
1.) The useful life of the asset must be increased,
2.) The quantity of units produced from the asset must be increased, or
3.) The quality of the units produced must be enhanced
An ordinary repair that simply maintains an asset does not satisfy these criteria and
therefore, would be treated as an expense. A capital improvement involves a benefit
lasting more than one (1) year.
> Even though frequency is the most scrutinized factor all four (4) factors must be taken into consideration
when making a RMRR determination.
Conclusions:
There is no single answer for RMRR and all four (4) factors need to be weighed evenly since it is a case-by-case
analysis, but between the "Questions" and "Guidance" above the engineering staff will have the tools to make a
proper RMRR assessment.
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Routine Maintenance, Repair, and Replacement Questions
Background:
EPA defined a major modification under the Prevention of Significant Deterioration (PSD)
regulations is as:
"any physical change in or change in the method of operation of a major stationary
source that would result in a significant net emissions increase of any pollutant subject to
regulation under the Act." 40 CFR §52.21 (b)(2)(i)
There are several exceptions to the definition of"physical change in or change in the method of
operation". One of those exclusions is "routine maintenance, repair and replacement (RMRR)"
[40 CFR §52.21 (b)(2)(iii)(a)]. The Department has adopted these rules in 567 IAC Chapter 33.
There is no regulatory definition of what is considered "routine".
There have been several court decisions concerning RMRR over the last 5-6 years. However,
all of these decisions relate back to one (1) utility case which is Wisconsin Electric Power Co. v.
Reilly (7th Circuit 1990) which is referred to as WEPCO.
One of the main items from the WEPCO decision was the "Multi-factor Test' for determining
RMRR. The Multi-factor test is a case-by-case analysis of each activity looking at:
• Nature & extent
• Frequency
• Purpose
• Cost
The court cases following WEPCO have provided additional guidance when conducting the
case-by-case Multi-factor Test. The main cases that EPA cites are:
• United States v. Southern Indiana Gas and Electric Company (Southern District of
Indiana, February 13, 2003)
• United States v. Ohio Edison (Southern District of Ohio, 2003)
• United States, et al., v. Duke Energy Corporation (Middle District of North Carolina,
2003)
• United States, etal., v. Cinergy Corp. (Southern District of Indiana, 2007)
All of these cases combined give a person insight on both the scope of the regulation and the
types of issues a person needs to look at when making RMRR determinations.
The Department is often asked for determinations on whether projects are classified as RMRR
under the Prevention of Significant Deterioration (PSD) regulations. In order to reduce the
amount of time needed to make these determinations the Department has developed a list of
questions that, at a minimum, must be answered by the company along with any supporting
documentation. The Department may still request additional information, but by providing
answers to these questions an applicant will reduce the majority of back and forth the
Department encounters during its review of RMRR determinations.
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Questions:
• Nature & Extent
o Provide a detailed description of the project. This description must list aM changes to
be made during the project. Also, please provide a percentage of the unit that is
being repaired or replaced,
o Will the project be done by in-house maintenance staff or outside contractors?
o Have there been any planning studies prepared in preparation for the project? If so,
please provide a copy of all studies,
o How long will the project take to complete? How long is your normal maintenance
shutdown period?
o Are the replacement components of the same design as the components they are
replacing?
• Purpose
o Please provide a brief description of why this project is being undertaken at this time,
o What was the expected lifetime of the unit when it was first installed?
o What is the unit's current age?
o Will the changes increase availability or reliability of the unit?
o Will the changes extend the lifetime of the unit?
o What was the original maximum rated capacity of the unit?
o What is the current capacity of the unit?
o Will the changes restore the unit to its original rated capacity?
o For combustion units:
¦ What was the original efficiency of the unit?
¦ What is the current efficiency of the unit?
¦ Will the changes restore the unit to its original efficiency?
• Frequency
o Are the components being repaired/replaced the original components?
o How often are these changes made to the unit during its lifetime?
o How often are these changes made to similar units elsewhere?
• Cost
o What is your company's annual operation and maintenance (O&M) budget?
o What is the cost of this project?
o Where will the funding from this project come from (i.e. O&M budget orcapital
expenditure)?
o Does your company follow Generally Accepted Accounting Principles (GAAP)?
o Is this project being capitalized or expensed?
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Comparison of Project Aggregation Guidance
Factor
New EPA Guidance
Iowa Guidance
Timing
Timing was a factor to consider in the past guidance. Now EPA says the following
regarding timing:
(1) Not to be used as sole basis for aggregating projects.
(2) Could be basis to not aggregate projects.
(3) Rebuttal presumption against aggregating projects that occur three (3) or more years
apart. Has to be a demonstration of a substantial relationship in order to rebut the
presumption of nonaggregation. Rebuttal Example: a company intends to undertake a
phased capital improvement project where specific timeframes are known.
(1) Timing not used as sole basis, but as indicator that projects are related.
(2) The timing triggers are:
• Less than 1 year: multiple projects submitted within a year for a single source
is a strong indicator that the projects should be considered as a single project.
• 1-2 years: multiple projects submitted over a year apart, but within 2 years of
each other need a closer review to determine whether they should be grouped as
a single project. This is more a gray area and comes down to how strong of a
technical dependence exists between the projects.
• More than 2 years: multiple projects submitted more than 2 years apart are
likely separate projects. There would have to be extenuating circumstances
such as a company stating the projects are part of an overall phased construction
process.
Technical
Dependence
EPA has always considered technical dependence. They provided the following indicators
in the most recent guidance:
(1) One project cannot operate within its maximum design parameters for an extended
period of time without the other project(s).
(2) A source cannot achieve its maximum production without the implementation of both
projects.
(3) The intention for a project is to make a new product and absence of another project
would not allow for the full production of the new product.
(4) Projects occurring in unrelated parts of the source are generally not technically
dependent.
(1) No set criteria.
(2) Case-by-case determination that applies reasonable engineering assumptions to the
information provided by the company to determine how much of an interrelationship
there is between multiple projects. Examples: (a) Are the projects on the same
process line or different process lines? (b) Are the projects needed to get to a
maximum production rate, but need to done at different times due to other issues
such as funding or scheduled downtime?
Economic
Dependence
EPA has always suggested economic dependence be considered. They provided the
following indicators in the most recent guidance:
(1) Activities are dependent on each other for their economic viability if the economic
revenues or "Return on Investment (ROI) " associated with the project could not be
realized without the completion of the other project.
(2) Generally evidenced when a particular project that may indeed be capable of operating
technically independent from the other planned projects is nevertheless planned or
integrated as part of a larger project goal and is interrelated to such an extent that it is
not economically viable as a stand-alone project because both (or all) the projects are
necessary for the larger project to achieve the operational level that justifies the
investment of the planned project.
Iowa has not considered the economic factors for the following reasons:
(1) The type of data EPA suggests to be used is not readily available and is not data
companies would necessarily want to share to be placed in the public record.
(2) The construction permitting staff are not the experts on the economic viability of a
project for a company. If a company proposes to do any project it is assumed they
believe the project is economically viable. The construction permitting staff s
expertise is on technical issues and permitting.
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Iowa Department of Natural Resources
Training Outline for Air Dispersion Modelers
This outline is to be used by the lead worker in training new employees as dispersion
modelers. The training outline was developed so that all dispersion modelers will have a
uniform and thorough background. The self-paced training will depend on the
individual's previous air quality experience and educational background, and may take
up to six months to complete.
Familiarization with DNR/AQB
• Work with supervisor to complete Human Resources paperwork and items as
assigned from the Iowa DNR Supervisor's New Employee Checklist.
• Review the regulatory and environmental Air Quality portions of the DNR web
page.
• Review the DNR intranet (provide user name and password) including the DNR
Employee Manual.
• Schedule training on Doc DNA, Records Section, and additional DNR training
opportunities.
• Sign up for any applicable NACAA committees.
• Review organization of modeling information and guidance on the P drive.
Background (optional, depending on the individual)
Addresses the importance of air quality and why we perform dispersion modeling.
• Complete APTI SI-422 Air Pollution Control Orientation Course (hard copy)
• Read chapters 1-7 of "Fundamentals of Air Pollution" 3rd Edition (Boubel, Fox,
Turner, and Stern) and answer selected questions at the end of each chapter:
o Chapter 2: questions 5 and 7
o Chapter 3: questions 1 - 5
o Chapter 4: questions 2 and 6
o Chapter 5: question 1
o Chapter 7: questions 1 - 7
• Complete APTI SI-431: Air Pollution Control Systems for Selected Industries self-
instructional course.
Meteorology Overview and Data
Covers wind, turbulence, vertical structure, plume types, mixing height, boundary layer,
stability class, transport, and dispersion of pollutants.
• Complete APTI SI-409: Basic Air Pollution Meteorology (employees with a
meteorology background can skip this)
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• Complete the following sections of the online Air Quality Meteorology course:
o Section 1, all parts*
o Section 2, all parts*
o Section 3, all parts
o Section 4, all parts*
o Section 5, parts 2,3,4, and 5
o Section 6, all parts
o Section 7, all parts
o Section 8, parts 1,2, and 3
*Those with a background in meteorology may "test out"
• Review parameters in meteorological files with lead worker.
• Familiarization with DNR meteorological data sets and "representativeness"
document on AQ website. AERMET familiarization (when applicable to the
trainee).
Introduction to Dispersion Modeling
Covers significant impact levels, averaging periods, NAAQS, H2H concept, TTN and
SCRAM websites.
• Review the information available on EPA's SCRAM website.
• Complete APTI SI-410: Introduction to Dispersion Modeling This is a somewhat
outdated course. Review Lessons 1, 2, 4, 5, and 6.
• Complete Section 9, Parts 1, 2, 4 and 5 of the online Air Quality Meteorology
course.
• Read appropriate sections from the most recent version of Fundamentals of Air
Dispersion Modeling by Trinity Consultants
AERMOD
Includes editing an existing input file, creating an input file from scratch, reading output
files, source types, and modeling front-end software.
• Review typical AERMOD input file via text editor with lead worker.
• Read the "User's Guide for the AMS/EPA Regulatory Model - AERMOD", Volume
I - User Instructions (EPA-454/B-03-001) September 2004. Read chapters and
addendum, skim appendices.
• Read AERMOD: Description of Model Formulation AERMOD Implementation
Guide
• Familiarization with Trinity's BREEZE software.
o Overview with lead worker
o Read help contents
• Read the "Users Guide for the AERMOD Terrain Preprocessor (AERMAP)". Read
chapters and addendum, skim appendices.
• Overview of the modeling array with lead worker
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• Read modeling array user guide
Downwash/Good Engineering Practice
Covers concept of building downwash, GEP, dispersion techniques and merged stacks.
• Read "User's Guide to the Building Profile Input Program" (EPA-454/R-93-038),
Chapters 1-3.
• Read "Guideline for Determination of Good Engineering Practice Stack Height
(Technical Support Document for the Stack Height Regulations)" Revised June
1985 (EPA-450/4-80-023R) Chapter 1.
• Complete downwash exercise and answer questions.
Construction Permit Project Procedures
• Walk through a basic construction permit modeling analysis with the lead
worker.
• Review internal modeling checklist and memo template
• Discuss CP forms with one of the senior engineers.
• Read DNR "Air Dispersion Modeling Guidelines for Non-PSD Pre-Construction
Permit Applications".
• Read DNR "Air Dispersion Modeling Evaluation Checklist" and "Air Dispersion
Modeling Checklist for Non-PSD Construction Permit Applications".
Begin working on "simple" construction permitting projects with oversight. This
includes archiving of projects on the P drive. In the absence of appropriate
construction permitting projects, exercises can be assigned from practice projects
found at: P:\Program_Development\Modeling\TRAINING.
Attend Trinity's BREEZE training course
Review course materials prior to attending the training course.
Existing Modeling Guidance/Regulations/Resources
Includes an overview of Code of Federal Regulations (CFR), Iowa Code (IAC), State
Implementation Plans (SIPs), New Source Review, and EPA Region 7.
• 40 CFR 51 Appendix W, take quiz provided by lead worker
• 40 CFR 50 (50.1-50.18)
• Obtain copy of Iowa Administrative Code (IAC) from records
• Read applicable portions of 567 IAC Chapters 20, 22.1-22.3, 22.100-22.101,
23.2-23.4, 28, and 33..Read DNR "Air Dispersion Modeling Guidelines for PSD
Projects".
• Read "Draft New Source Review Workshop Manual" Chapter C.
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Modeling Inventory Procedures
The following modeling inventory procedures are pollutant specific and apply to all comprehensive SO2 modeling
(PSD and non-PSD) as well as comprehensive CO, NO2, PIVtesand PM10 PSD modeling.
Identification of Facilities to Include
1. Determine the inventory search radius for each pollutant
A. 10km + SIA radius or 20km radius, whichever is greater
i. The SIA used here is the largest SIA for each pollutant. Example: For 1-hour NO2 the SIA
is 12 km and for annual NO2 the SIA is 3 km. The 12 km distance would be used as the
NO2 SIA making the NO2 inventory search radius 22 km.
2. If any of the inventory search radii will include an adjacent state, begin coordination with the state(s) to
obtain a source inventory from them for the affected pollutants (see contact information below).
A. Be sure to only ask for Title V facilities within the inventory search radius determined in step 1
Add all adjacent facilities to the draft inventory regardless of potential emissions for all pollutants. Adjacent
is defined as abutting properties or properties separated by a road, railway, right-of-way, stream, etc.
Develop a list of Title V facilities within each inventory search radius (determined in step 1)
A. Make a circle around facility in Google Earth (centered on tallest source)
B. Develop list of all counties the circle intersects
C. Open TV database
D. Click on Title V List (under Queries)
E. Filter by counties determined above
F. Enter each address into Google Earth to determine if facility is inside the circle
G. Add all facilities within the circle to the draft inventory
5. Screen out non-adjacent facilities based on potential emissions for each pollutant
SPARS OPTION
A. Open SPARS
B. Click reports under the reports tab in upper left hand corner
C. Under report categories highlight "Operating"
D. Under list of reports for the category selected highlight "Potential emissions..."
E. Enter Site ID (12 number SPARS ID)
F. Click Run Report
G. Look for latest emission data (IT MAY NOT BE THE FIRST ONE LISTED!!!!)
H. Remove facilities from the draft inventory whose facility-wide potential emissions are less than the
applicable SER
TITLE V OPTION
A. Go to FINAL.TV file on N drive
B. The facility folders are listed by EIQ numbers, click on the correct folder
C. Click on the latest renewal folder (if applicable) or initial folder
D. Click on the Public Notice folder
E. Find the pdf with an f at the end of the name or the pdf called fact sheet
F. A summary of potential emissions is on the first page
Please note that SLEIS does not have potential emissions
Revised 3-2016
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6. For the facilities remaining in the draft inventory, screen out facilities based on the potential extent of their
significant concentration gradients for each pollutant. See Figure 1 as an example.
A. Determine the location of each facility.
i. Use the coordinates of the tallest source as the facility location.
ii. If source information is not available use the center of the facility as the facility location.
B. Determine the height of the tallest source at all facilities for each pollutant. If source height
information is not available for a particular facility, skip this step for that facility.
C. Calculate the distance between the facility of interest and the location of all other facilities using the
locations determined in step A.
D. Determine the facility radius for each facility.
i. Facility radius (meters) = 330x0 5, where x = stack height (in feet) of the tallest source for
the applicable pollutant (if the source height is not available assume the facility radius is
equal to 10 km). For a further explanation on this equation, please see appendix A.
ii. For the facility of interest, if the SIA is greater than the facility radius calculated above, use
the SIA as the facility radius instead.
E. Add the facility radius for the facility of interest to each of the other facility radii.
F. For each facility in the draft inventory, determine if the facility radius intersects with the facility
radius for the facility of interest.
i. If the distance between facilities (step C) is greater than the sum of the facility radii from
step E then the radii do not intersect.
ii. If the distance between facilities (step C) is less than or equal to the number calculated in
step E then the radii do intersect.
G. Remove each facility from the draft inventory whose facility radius does not intersect the facility
radius of the facility of interest.
7. The complete inventory list includes all facilities from step 3 (adjacent), step 6 (non-adjacent) and step 2
(adjacent state), if applicable.
A. Sources from an adjacent state will need to be screened through steps 5 & 6
8. Subjectively check inventory list
A. Compare the facilities in the complete inventory to the original draft before any facilities were
screened out.
B. Some facilities that were screened out may still warrant inclusion in the final inventory on a case-
by-case basis. 8Bi and 8Bii are two examples but in no way an exhaustive list.
i. Nearby facilities whose potential emissions are just below the SER
ii. Distant facilities with very high potential emission levels, and/or a facility radius that almost
intersects the facility radius of the facility of interest
C. Some facilities may warrant exclusion based on other screening criteria. Again 8Ci, 8Cii, and 8Ciii
are examples and not a comprehensive list.
i. Adjacent facilities with very low potential emissions
ii. Facilities known to be shutting down or dramatically decreasing allowable emissions, but
for which the data is not yet available.
iii. If the majority of emissions from a facility come from sources that will not be modeled.
D. Consult with Dispersion Modeling lead worker before finalizing an inventory that may include or
exclude a facility(s) based on the subjectivity criteria in 8B and 8C.
9. The remaining list of facilities constitutes the final modeling inventory.
Revised 3-2016
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Obtaining individual source parameters and emission rates
After completing the steps listed above, go through individual permits and previous modeling files to obtain stack
parameter and emissions information for each emission point at each facility that will be included in the cumulative
analysis. Completion of this additional step will significantly reduce the time it will take to review the submitted
analysis.
Previous modeling files are one of the easiest methods of obtaining this information, but it is important to ensure that
the correct emission rates are used (some analyses may have been conducted using actuals). Otherwise it is
generally necessary to review the permits for each source. For major facilities the Title V permit will conveniently list
the construction permit for each emission point. As a last resort the report feature in Facility Explorer or SPARS can
be used, but the quality of the data from these resources varies widely and should be verified if possible. Several
resources that can be used are listed below. To find emission point characteristics in SPARS, search for the newest
construction permit application and select the "Form MI-2" tab. Select the desired emission point from the list and
click the "Emissions Point Specifications" button. Theoretically these values should match those provided by facility
explorer. Facility Explorer will provide a more convenient listing and SPARS can be used to cross-check for accuracy
if needed.
Emission point characteristics can also be found in SLEIS. Log into SLEIS and enter the facility name or number at
the bottom of the welcome screen under Find Facility. Click on the release points button at the top of the page. A list
of all emission points will appear. To download a CSV file with the entire list of emission points, click the export
button in the lower left. For more information on a particular emission point click on the magnifying glass on the left
hand side. Stack parameter and location information will appear.
When developing source-specific data for an inventory, non-point source emissions such as haul roads and storage
piles only need to be included at adjacent facilities. As such, volume and area sources may be screened out of the
list of sources at more distant facilities. Also, emergency equipment from distant sources may be excluded as well.
The emissions from sources that are outside of the SIA can be lumped into the tallest stack at the facility and
modeled without downwash. This eliminates the need to find individual stack parameters and building dimensions for
these more distant sources. Additionally, for sources in which no modeling has been previously performed and actual
stack locations are difficult to determine, the location for each stack can be modeled at a coordinate representing the
center of the facility. For large power plants with two or more similarly-sized large stacks, model them individually.
Revised 3-2016
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Information Resources
General
• Facility Explorer - Be sure to verify data obtained from here
• Title V Database
• Records (hard copy)
• SPARS - Electronically accessible version of many hard copy records
• Google Earth - Aerial photography and distance measurement tool
• Binq Maps - Good source of high-resolution aerial photography
• DocDNA - searchable hard copy records
• Class I Area Q over D Calculator - Use to determine distance to nearest Class I Area for information
purposes in the modeling report.
• SLEIS - Iowa DNR State and Local Emissions Inventory System (only actual emissions data)
Construction Permits
• Online construction permit search
• Current permits on the N drive
• Old permits on the N drive - Good resource for determining old emission limits for increment
Operating Permits
• Online operating permit search
• Title V permits and other information on the N drive - Fact sheets useful for facility-wide potential emissions
Emissions Inventory
• SPARS Data Download
• The emissions inventory group has created Google Earth maps and spreadsheet summaries of facility-wide
actual emissions for us to use in the past. If there is a specific group of information needed, it is possible
that they may be a resource. Contact Jason Marcel for assistance with any request to the El group.
Modeling Files
• Previous construction permitting modeling files on the N drive
• Previous modeling files from Title V modeling analyses - Contains some modeling for facilities that may
have no construction permit modeling files, the data is older though
State Contact Information
• Minnesota
Jim Sullivan : 651-757-2769
• Wisconsin
John Roth: (608) 267-0805
• Illinois
Jeff Sprague: (217) 524-4692
• Missouri
Dawn Froning
• Nebraska
Lisa Alam: (402)471-2925
• South Dakota
Jim Anderson: (605) 773-3151
Revised 3-2016
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Figure 1. Example of Intersecting Radii
Fb, Fc, Fd = Facilities wi
Search Radius
Key:
Fa = Facility of Interest
Search Radius
In this example the green circles are the distances calculated from the equation and centered on the tallest source for
the specific pollutant at each facility. Fd is within the facility of interest radius therefore will be included in the
inventory. Fb and Fa have intersecting radii, Fb will be included in the inventory. Fc radius does not intersect Fa
radius, Fc will not be included in the inventory.
Revised 3-2016
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Appendix A
In order to define and determine a significant concentration gradient a modeling analysis was completed with the
following setup:
• Emission points were given the same emission rate (1 g/s), temperature (600°F), diameter (12 inches), and
flow rate (2,500 acfm). These parameters were chosen to represent a source with a realistically large
amount of plume rise and therefore a more extensive area of significant gradient.
• Stack heights were evaluated from 10-100 feet (incremented by 10 feet) through 150-600 feet (incremented
by 50 feet). 600 feet was chosen as the cutoff because no source in Iowa is above 600 feet.
• The grid was set up as 0-3,000m at 50m spacing, 3,000-5,000m at 100m spacing, 5,000-20,000m at 500m
spacing, and 20,000-50,000m at 1,000m spacing.
• All emission points were evaluated across all 19 meteorological stations currently used in Iowa for
permitting.
For each stack height across all 19 meteorological stations, the maximum concentration at every distance was used
to calculate the gradient. The gradient was calculated at each receptor by dividing the change in concentration per
unit distance at that location by the maximum change in concentration per unit distance over the entire domain. The
distance at which the concentration gradient equaled 1% was used as the cutoff for a significant concentration
gradient. This value was used as a conservative assumption to ensure that all significant concentration is being
captured.
Table 1 reflects the distance to a 1% gradient based on the stack height.
Table 1. Stack Height vs. Distance Results
Stack Height (ft.)
Distance (m)
10
500
20
850
30
1,200
40
1,550
50
1,900
60
1,800
70
2,150
80
2,300
90
2,500
100
2,650
150
3,400
200
4,600
250
5,000
300
5,000
350
5,500
400
6,000
450
5,500
500
6,000
550
5,000
600
6,500
Table 1 was plotted in Figure 2 below. The red curve fit line was used to conservatively capture the distance where
each stack height equaled 1% of the concentration gradient. The red curve fit line is the equation listed in step 6D.
Revised 3-2016
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Figure 2. Distance to 1% of Concentration Gradient
Significant Concentration Gradient
9000
7000
<3 6000
4000
3?
O
2000
1000
i
•
1
•
•
a
>
• A d
...1
y = 330x°-5
•
••
/ ••
/ •
/ •
' •
•
100
200 300 400 500
Stack Height (ft)
600
700
Revised 3-2016
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2020 Program Review
Air Quality Division
Polk County Public Works
FINAL REPORT
Program Review Performed by:
Iowa Department of Natural Resources
Air Quality Bureau
October 2020
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SFY 2020 PROGRAM REVIEW CONTENTS
Executive Summary
I. Introduction
II. Program Management Provisions
A. Personnel
B. Fiscal Reporting
C. Initial Contract Review
D. Final Contract Review
E. Information Technology
F. Legal Authority
G. Minority and Women Business Enterprise
K. Intergovernmental Cooperation
III. Construction Permitting Provisions
A. Construction Permit Activities
B. Permit/Modeling Procedures
C. Reporting Requirements
D. DNR Responsibilities
IV. Title V Permitting Provisions
A. Title V Permit Activities
B. Application Review
C. Permit Drafting Procedures
D. Public Notice of Intent to Issue
E. Final Permit Issuance
F. Permit Renewal
G. Re-opening Issued Title V Permits
H. Permit Changes
I. Reporting Requirements
V. Compliance and Inspection Provisions
File Review Procedures
A. Compliance
B. Stack Tests
C. Inspections
D. Variances
E. Data Management
F. Emissions Data
VI. Ambient Air Monitoring Provisions
Commendation
A. Finding/Recommendation #1
B. Finding/Recommendation #2
C. Finding/Recommendation #3
D. Finding/Recommendation #4
E. Finding/Recommendation #5
F. Finding/Recommendation #6
G. Finding/Recommendation #7
H. Finding/Recommendation #8
I. Finding/Recommendation #9
Attachment A: Comments on Specific
Polk County Construction Permits
Attachment B: Polk County Employee Training
Attachment C: Summary of Polk Precision
and Bias
Attachment D: Polk County Comments
and DNR Responses
Attachment E: Polk County-Identified CMS
80% SM Facilities
2020 Polk County Program Review
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Executive Summary
The Iowa Department of Natural Resources (DNR) performed a program review of the Polk County Public Works
Department, Air Quality Division (POLK) between October 5-8, 2020. Due to Covid-19 restrictions, the program review
was completed using digital files and email communications, and all meetings were held virtually. The review was for
the period of July 1, 2019, through June 30, 2020. The final SFY 2020 Contract (Contract) was used as a guide to
evaluate the program. This Executive Summary summarizes the findings of the DNR.
Program Management - POLK maintained the required full time equivalents (FTEs) and continues to meet the
requirements regarding knowledge, skills, and abilities required for POLK personnel who perform visible emissions
observations, dispersion modeling, facility inspections, ambient monitoring, and permit reviews. POLK maintained
familiarity with changing procedures and new air quality developments by participation in various training, webinars,
workshops, and conferences. POLK staff took advantage of opportunities to attend conferences and training virtually
that otherwise may not have been possible in person.
POLK provided timely and complete information (reports, invoices, etc.) by the Contract due dates. DNR appreciates
POLK's rapid follow-up and resolution when requested. POLK is commended for working with their accounting staff to
streamline the invoice review process. POLK is encouraged to use the report feature in EASY Air to check billable hours
against the hours being submitted in the billable hours documentation to DNR.
POLK worked with their county IT staff to implement a new Polk County Public Works website with an updated look and
organization. The updated website allows users to quickly find information on ambient air monitoring, open burning,
and construction permitting.
POLK assisted in developing a SIP submittal addendum to DNR's January 2019 request to include POLK's 2018 rule
updates in the SIP. The addendum requested that previously finalized POLK rule updates (prior to 2018) be included in
the SIP and also clarified the 2018 rule changes submitted for SIP inclusion. POLK worked with DNR to develop a revised
rule review and submittal process to prevent similar issues from occurring in the future.
POLK is commended for their collaboration with DNR and EPA and rapid action to address ethylene oxide (EtO)
emissions from a source in the county.
POLK assisted as requested by DNR with testing and implementation of the EASY Air system. For a possible POLK
module to EASY Air, POLK completed a scoping questionnaire and reviewed a draft project proposal provided by
enfoTech. A second proposal was under review by POLK when the contract period ended.
Construction Permitting and Dispersion Modeling
Construction Permitting - POLK overall produces well written permits and evaluations and provides specific guidance
to facilities on NESHAP compliance obligations. DNR identified just a handful of instances of permit procedures used by
POLK during this review period that either differed from the latest version of the DNR Construction Permit Manual or
current standing EPA guidance as discussed later in the report.
Dispersion Modeling - POLK staff trained in dispersion modeling exhibit an understanding of current EPA and DNR
modeling guidelines, have the ability to perform and review dispersion modeling analyses, are able to use the modeling
output to determine compliance with the applicable ambient air quality standards, and understand the strategies and
control measures used. POLK requests assistance from the DNR in reviewing modeling analyses, as appropriate, and is
encouraged to continue to contact DNR staff for assistance related to dispersion modeling.
The majority of the projects that were reviewed did not require a modeling analysis. Those that were modeled contained
no modeling errors that would have negatively impacted the resulting permits. The permit review notes consistently
2020 Polk County Program Review
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included comments regarding modeling applicability and why it was, or was not, required and there were logical
exclusions from modeling when the modeling determination form may have otherwise indicated modeling was required.
The DNR recommends POLK verify model inputs and settings in the BEEST software to avoid errors. When relaxing
operating limits for sources classified as intermittent consider the full hourly emission rate when determining if modeling
should be required. Make sure the correct information is included in the permit record and follow up on modeling that
needs to be reevaluated as a result of reviewing the analyses.
Title V - The quality of work performed by the POLK technical staff has been very good and there continues to be
consistency between POLK and DNR Title V operating permits. The performance criteria for POLK was to draft for issuance
or denial a minimum of four initial or renewal title V operating permits during SFY 2020. Three permits were drafted
during this review period, but only one was issued due to timing or compliance issues. During the audit, POLK and DNR
staff discussed ways to improve and increase communication regarding the time schedule for issuing permits to meet the
performance criteria. The DNR appreciates participation of POLK in development and testing of the new EASY Air
electronic permitting system and participation in the regularly scheduled Title V section meetings.
Compliance and Inspection -The DNR AQB Compliance Unit staff chose to review file documentation for SFYs 2019-
2020 for six POLK files. DNR staff also reviewed Integrated Compliance Information System (ICIS) data entry with POLK,
going over facility information as it relates to the Compliance Monitoring Strategy (CMS), criteria pollutant entry,
applicable air programs, enforcement actions, case files, Semi Annual Monitoring Reports and Title V Annual
Certifications. Data verification of data for ICIS was also discussed with Polk.
The file review showed POLK runs an effective compliance program. POLK is doing a very good job evaluating, tracking,
and documenting the compliance status with major, synthetic minor and minor facilities. POLK met all timelines
established in the Contract for submitting compliance reports and the CMS to the DNR.
The Microsoft Corporation file reviewed contained several stack tests for PM10 and NOx. All Stack tests summaries and
response letters were reviewed by DNR. DNR chose a failed test report to spot check calculations and follow-up to a
violation. POLK ensured the correct test methods were followed, documented relevant process and test information.
POLK identified a violation, worked through a compliance plan with the facility, and ensured the source was returned to
compliance. DNR conducted two joint stack test observations with POLK during 2019. Due to COVID-19 concerns and
lack of opportunity, no joint observations had been completed in 2020 at the time of this report.
During the 2018 audit, DNR recommended that stack test acceptance letters to the company include results calculated
by POLK. POLK has modified their letters to include their calculated test results in all acceptance letters and the Notice
of Violation (NOV) reviewed.
POLK uses a modified form of the Title V permit to conduct the Full Compliance Evaluation (FCE) at major sources. The
major source FCE reports were well documented, though no deviations were identified. DNR reviewed two minor
source inspection reports. The minor inspection reports were not clear if the facility's classification was SM80 or minor.
It was recommended that some mechanism be added to the minor source inspection reports to identify the facility
classification so there is no confusion. Facility classification is important since the classification is used when
determining violation types and reporting requirements.
EPA requires information be logged in the ICIS database and POLK is required to enter the minimum data requirements
(MDRs) for all inspections, stack tests, annual Title V certifications, NOVs, and other CMS-related activities in a timely
manner. Based on the file review, POLK is meeting the EPA's MDR's by entering the results from the FCEs within 60
days of the inspection. POLK is also meeting the requirements to review and enter the Title V Annual Compliance
certifications.
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Corrective Action Required
NOVs, stack tests, and Air Programs are compliance activities that POLK is required to report in ICIS. During the ICIS
data review, DNR noted that Air Programs were missing for two of the facilities and for one facility an NOV, Case File
and some stack tests had not been entered. These items need to be reviewed for completeness to ensure required
information for the facility are entered and accurate. The DNR is requiring that POLK take corrective action to address
these data management issues. It was agreed that DNR would provide POLK with an ICIS manual used for data entry.
Mark Fields of DNR held follow-up training on NOV/Case File entry with Bridget McNerney of POLK on October 15,
2020.
Deficiencies Identified
CMS Category (Major or SM80) and facility criteria pollutants are compliance activities that POLK is required to report
in the ICIS database. These two categories were identified for corrective action in the 2018 report. The DNR found that
one of the six facilities reviewed had the incorrect CMS source categories listed, thus creating incorrect inspection
schedule dates within ICIS. Additionally, four of the six facilities reviewed had air pollutants missing or incorrectly
categorized in the required criteria pollutant list.
Plan Required
POLK will provide DNR with a written plan specifically addressing how the CMS Category and facility criteria pollutants
data will be corrected for the Major and SM80 facilities in the ICIS database. This plan will include dates by which the
identified deficiencies will be addressed. The written plan shall be submitted to DNR by February 1, 2021 (or by an
agreed upon alternative date).
The Compliance and Inspection section of this report includes detailed explanations of the DNR's review, findings,
suggestions, required corrective actions, deficiencies identified, and the required plan.
Ambient Air Monitoring -DNR commends POLK for doing an excellent job running their air monitoring network. For
data collected in 2018 and 2019, all POLK criteria pollutant monitors evaluated by EPA were recommended for
certification. The final results of audits done on POLK's gas and particulate samplers by EPA Region 7 were well within
acceptance limits. Precision and bias stats for data collected in the most recent complete calendar year were reviewed,
and the results were very good. POLK has also been responsive to suggestions made in previous audits conducted by
DNR and SHL.
DNR and POLK discussed deployment of the new "49 iQ" generation of Thermo ozone analyzers, and how some display
erratic behavior when the ambient dew point is close to the trailer temperature. DNR emphasized the need to develop
an ozone SOP that adequately covers the differences between the older "\" model and the new "iQ" version. DNR
stressed the importance of frequently tracking agreement between collocated monitors and taking corrective action
before a significant amount of questionable data is collected. DNR continues to recommend that POLK add language to
their BAM SOP describing how an investigation will be required if excessive bias between collocated PM2.5 monitors is
observed.
DNR and POLK also discussed options for, and alternatives to, developing a log that summarizes substantive changes to
POLK QA documents. DNR encouraged POLK to document the steps they already take to verify data processing and
polling software, as well as expand their testing of software as needed to conform to "Data Trail Audit" procedures
outlined in the Redbook. DNR asked POLK to continue following EPA's request to upload all precision checks to AQS
including those that failed, as well as those where the calibration system itself was deemed to be defective.
2020 Polk County Program Review
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I. Introduction
POLK has been delegated the responsibility of implementing the State of Iowa air pollution control implementation
plan within POLK. To assure that the implementation plan is carried out, the DNR negotiated a 28E Contract (Contract)
with the Polk County Board of Supervisors for the period of July 1, 2019, through June 30, 2020. The purpose of the
Contract was to control and prevent air pollution within POLK. Particular emphasis was placed on the collection and
assessment of information regarding air quality, the permitting of sources of air emissions, the enforcement of
emission limits, and the attainment and maintenance of ambient air quality standards.
The purpose of the program review is to help in the development and improvement of the air pollution program in
POLK by providing guidance, identifying areas where more support is needed from DNR, and to foster a good working
relationship. As a means to verify that POLK fulfilled the terms of the Contract, DNR staff performed a program review
between October 5 and October 8, 2020. The review was divided into the following five categories: program
management, construction permitting, Title V permitting, compliance and inspection, and ambient air monitoring. DNR
staff performed a comprehensive review of each category. The findings of this review are discussed by category
throughout this report.
The program review team consisted of the following DNR staff members (by section):
• Brian Hutchins, Compliance and Ambient Air Monitoring Section Supervisor
• Mark Fields, Compliance Unit
• Reid Bermel, Compliance Unit
• John Gering, Ambient Air Monitoring Unit
• Jasmine Bootman, Ambient Air Monitoring Unit
• Sarah Piziali, Construction Permitting Section Supervisor
• Karen Kuhn, Construction Permitting Section
• Marnie Stein, Operating Permits/Title V Section Supervisor
• Jeremy Arndt, Operating Permits/Title V Section
• Jim McGraw, Program Development & Support Section Supervisor
• Brad Ashton, Program Development & Support Section
• Christine Paulson, Program Development & Support Section
II. Program Management Provisions
A. Personnel
1^1 Acceptable Q Corrective Action Needed Q Deficient Q Not evaluated
Comments: Section 5.A.1.1 of the Contract requires POLK to employ sufficient personnel to perform the services of
the Contract during the period of agreement. POLK staff met the requirements specified in Section 5.A.1.1 regarding
knowledge, skills, and abilities required for POLK personnel who perform visible emissions observations, dispersion
modeling, facility inspections, ambient monitoring, and permit reviews.
POLK committed to operate the program with a staff level of approximately 9.0 FTE. The quarterly activity reports
submitted to DNR for SFY 2020 included summaries of staff time utilization and show that POLK met this staffing level
commitment.
POLK is required to have at least two staff certified in visible emissions observations and one staff trained in conducting
air dispersion modeling. POLK has six staff certified in visible emissions observations and one staff trained in conducting
air dispersion modeling. POLK staff are cross-trained among several air quality disciplines.
2020 Polk County Program Review
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During SFY 2020, POLK staff maintained familiarity with applicable air quality permitting, inspection, and monitoring
procedures, techniques, and technologies, and changing procedures and new air quality developments by attending
pertinent EPA, NACAA, and DNR meetings, webinars, training classes, workshops, and conferences. The table in
Attachment B provides a summary of the training courses attended by POLK staff (as provided in POLK's end-of-year
report).
The training completed was consistent with the POLK SFY 2020 training plan and relevant to the job duties of each staff
member working under the Contract. POLK staff took advantage of opportunities to attend conferences and training
virtually that otherwise may not have been possible in person.
B. Fiscal Reporting
1^1 Acceptable Q Corrective Action Needed Q Deficient Q Not evaluated
Comments: Quarterly expense reports, itemized based on line items provided in the Contract, were submitted with
request for payment per Section 7.5. This included supporting documentation in accordance with Section 7.5/2 for
reimbursement of expenses associated with billable hours. All invoices were submitted on time and three of the four
invoices contained no errors. POLK rapidly addressed and resubmitted the one invoice that contain an error.
POLK is commended for working with their accounting staff to streamline the invoice review process and have DNR
review draft invoices and supporting billable hours documentation before sending the invoice to the Board of
Supervisors Chair for signature.
The billable hours documentation for quarter 3 included 4.25 hours of operating permit application review time
between two facilities that was not included in EASY Air. POLK is encouraged to use the report feature in EASY Air to
check billable hours against the hours being submitted in the billable hours documentation to DNR to ensure that all of
the billable hours are included for the generation of invoices to send to the applicable facilities.
POLK expended all pass through funds in SFY20. POLK exceeded their Local Program Match by $46,296.
C. Initial Contract Review
1^1 Acceptable Q Corrective Action Needed Q Deficient Q Not evaluated
Comments: POLK met all budget information request timelines and their responses to additional information
requests were always provided timely.
D. Final Contract Review
1^1 Acceptable Q Corrective Action Needed Q Deficient Q Not evaluated
Comments: POLK addressed questions quickly and provided timely responses to DNR. POLK moved the Contract
through the signatory process in an efficient manner and provided documentation that the Contract went through the
proper channels for approval.
E. Information Technology
[Xl Acceptable Q Corrective Action Needed Q Deficient Q Not evaluated
Comments: POLK maintains a user friendly, up-to-date web site and reviews the Website at least quarterly and
makes updates as needed. A webpage for POLK fee advisory group meetings is up-to-date with information for a public
participation period scheduled to occur in December 2020.
2020 Polk County Program Review
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County IT staff implemented a new Polk County Public Works website with an updated look and organization that
provides a quick and easy way for users to find information on ambient air monitoring, open burning, and construction
permitting. Open burning fact sheets for each user category help the public better understand the burning rules that
apply to them. The open burning webpage also conveniently includes links to the open burning ordinances for all
municipalities in the county.
F. Legal Authority
1^1 Acceptable Q Corrective Action Needed Q Deficient Q Not evaluated
Comments: POLK confers with DNR on the need, content and timing of revisions and updates to Chapter V of the
POLK rules as required in the Contract. POLK collects ideas for rulemakings through the year and combines these ideas
with applicable federal and state regulation changes.
POLK completed their last Chapter V update in November 2018. DNR submitted the rule updates to EPA for inclusion in
the State Implementation Plan (SIP) in January 2019. Subsequent review of the rule updates by POLK, DNR, and EPA
staff determined that misinterpretations of POLK's rulemaking process had occurred in the past, resulting in previous
POLK rule changes being unintentionally omitted from the SIP. POLK worked with DNR and EPA staff to develop a SIP
submittal addendum to request that previously finalized POLK rule updates (prior to 2018) be included in the SIP and
also clarified the 2018 rule changes submitted for SIP inclusion. The resulting 12 page SIP addendum was submitted to
EPA in July 2020.
POLK worked with DNR to develop a revised rule review and submittal process to prevent similar issues from occurring
in the future. Under the revised process, POLK will provide DNR the tracked version of the proposed rules provided for
public comment, as well as a tracked version of the final Board approved and published rules. DNR will provide the
tracked version of the final rules in its SIP revision request to EPA.
POLK plans to initiate their next rules update in the first half of SFY 2022, and anticipates the Polk County Board of
Supervisors approval early in the second half of SFY 2022. This will allow time for the SIP submittal currently under
review by EPA to be finalized and published. It will also allow POLK to have new staff involved in the rule change
process.
G. Minority and Women Business Enterprise (MBE/WBE)
[Xl Acceptable Q Corrective Action Needed Q Deficient Q Not evaluated
Comments: Reports were completed and provided timely.
H. Intergovernmental Cooperation
[Xl Acceptable Q Corrective Action Needed Q Deficient Q Not evaluated
Comments: POLK participated in an annual local program meeting held in September 2019. The meeting included
discussions on budget and personnel planning for the next fiscal year, updates on EASY Air implementation, and
updates and discussions on permitting and monitoring topics.
POLK is commended for their collaboration with DNR and EPA and rapid action to address ethylene oxide (EtO)
emissions from a source in the county. POLK also shared their permit templates with the State of Wisconsin to assist
them in addressing a similar situation.
POLK assisted as requested by DNR with testing and implementation of the EASY Air system. POLK uses EASY Air to
track time spent on processing Title V applications using procedures as provided by DNR.
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For a POLK EASY Air module, POLK completed and submitted a scoping questionnaire document to enfoTech. POLK
reviewed a draft project proposal provided by enfoTech in June 2020, and requested a revised project proposal that
would include only the online construction permit component of the POLK program. POLK was reviewing the revised
proposal when the contract period ended.
III. Construction Permitting and Dispersion Modeling Provisions
A. Construction Permit Activities (Source Review, Permit Issuance, Draft Permit Review, Permit Transfer)
[Xl Acceptable Q Corrective Action Needed Q Deficient Q Not evaluated
Comments: See Attachment A for comments on application review.
B. Permit/Modeling Procedures
[Xl Acceptable Q Corrective Action Needed Q Deficient Q Not evaluated
Permit Comments: POLK is excellent at reviewing and noting all applicable NESHAP in their issued permits. Additionally,
the peer review process is continuing to catch errors prior to permit issuance and the engineering evaluations are well
written and explanatory. DNR finds that POLK could improve consistency in a few areas:
1. When setting plant-wide synthetic minor limits, even for minor sources, POLK needs to ensure that all HAPs are
counted towards the limit, not just the surface coating HAPs. Alternatively, non-surface coating HAPs could be
separated from the surface coating HAP limit, if the facility-wide surface coating HAP limit is reduced
proportionately.
2. If a company is currently not subject to a NESHAP because it is not using a target HAP, the DNR suggests that
POLK note the company is not subject to the NESHAP unless it is using the target HAP or else set an operating
limit forbidding the use of the HAP.
3. DNR would recommend the use of emission factors in estimating the actual emissions of a unit rather than
calculations based on an assumed control equipment grain loading, as control equipment can be overloaded.
4. DNR would recommend always including the expected stack characteristics in a permit, instead of requiring the
company to modify the permit once the unit is built.
See Attachment A for other comments.
Modeling Comments: POLK staff trained in dispersion modeling exhibit an understanding of current EPA and DNR
modeling guidelines, have the ability to perform and review dispersion modeling analyses, are able to use the modeling
output to determine compliance with the applicable ambient air quality standards, and understand the strategies and
control measures used to mitigate modeled exceedances of these standards.
POLK requests assistance from DNR in reviewing modeling analyses, as appropriate, and is encouraged to continue to
contact DNR staff for assistance related to dispersion modeling. DNR will continue to assist POLK by conducting a
quality assurance (QA) review of each modeling project conducted or reviewed by POLK. DNR will provide an updated
OA checklist to use for this purpose.
The majority of the projects that were reviewed did not require a modeling analysis. Those that were modeled
contained no modeling errors that would have negatively impacted the resulting permits.
There are several good items to note:
1. POLK continues to review the impact from air toxics.
2. Modeling determinations are well documented, especially as it relates to project emissions levels.
3. POLK correctly waives modeling analyses in cases where emission reductions offset new sources.
2020 Polk County Program Review
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4. Previous applications are considered when determining if projects should be aggregated for modeling
determinations.
5. POLK uses MERPs to address secondary formation.
Some areas for improvement include:
1. Verify use of correct version of the model (check settings in BEEST each time the model is run).
2. Verify that the current version of the meteorological data are used and that the correct base elevation is applied
(there can be different versions of the same five-year set of meteorology; the newest version should be
downloaded from the DNR website at the time of analysis).
3. Make sure to use the correct scale when inputting model objects (LCS Holdings).
4. Verify correct modeling information is provided in the record (the Siculus checklist in the record was for the
previous project).
5. Follow up on revisions to modeling (Siculus) due to discrepancies noted during review of submitted analyses. Make
sure final modeling files are included in the record.
6. Relaxation of the operating limits for intermittent sources needs to be considered when determining if modeling
will be necessary for 1-hour N02 (DMMW).
See Attachment A for other comments.
C. Reporting Requirements
[Xl Acceptable Q Corrective Action Needed Q Deficient Q Not evaluated
Comments: No comments.
D. DNR Responsibilities
I | Acceptable Q Corrective Action Needed Q Deficient
Comments: No comments.
IV. Title V Permitting Provisions
A. Title V Permit Activities
[Xl Acceptable Q Corrective Action Needed Q Deficient Q Not evaluated
Comments:
The performance criteria for POLK was to draft for issuance or denial a minimum of four initial or renewal Title V
Operating Permits during SFY 2020. During this review period, three permits were drafted: ADM - Des Moines Soybean,
John Deere Des Moines Works, and Quality Manufacturing Corporation. POLK billed 474.50 hours of work on these three
permits during SFY 2020, but due to compliance and other timing issues, only the permit for Quality Manufacturing
Corporation was issued during SFY 2020.
POLK billed 111.25 hours for Quality Manufacturing during SFY 2020, and the permit was issued in May 6, 2020.
POLK billed 245.00 hours for John Deere Des Moines Works during SFY 2020, but issuance of the permit was delayed until
August 2020. The first public notice period was from June 4, 2020 - July 4, 2020, but the facility submitted a revised
Compliance Assurance Monitoring (CAM) Plan during the initial public comment period. Because the changes to the CAM
plan were a relaxation of visible emissions observations, the permit was required to be public noticed a second time from
July 16, 2020 - August 15, 2020. The permit was then issued on August 16, 2020.
POLK billed 118.25 hours during SFY 2020 and 112.0 hours during SFY 2019 for ADM - Des Moines Soybean, but POLK was
not able to issue the permit because the facility did not demonstrate compliance with several emission limits during stack
X Not evaluated
2020 Polk County Program Review
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testing and may need to modify a large number of PSD construction permits. It is possible that ADM may need to submit
an entirely new Title V renewal application for this facility, so it did not make sense to issue the Title V permit with an
extensive compliance plan.
A proposed schedule identifying the Title V permits POLK intended to issue was submitted timely (quarterly) to DNR, and
the POLK permit staff, POLK Supervisor, DNR Lead Worker, and DNR Supervisor communicated about possible delays via
email during the review period. However, some of this communication was lost in the turnover of employees at DNR.
During the audit, POLK and DNR staff discussed ways to improve and increase communication between quarterly reports.
If the issuance of a permit will be delayed, POLK staff will notify DNR as soon as possible and not wait until the quarterly
report to notify DNR. In turn, DNR will check-in with POLK staff more often regarding the time schedule for issuing permits
and any possible delays.
B. Application Review
1^1 Acceptable Q Corrective Action Needed Q Deficient Q Not evaluated
Comments: Completeness reviews were conducted by POLK in a timely manner to ensure that the applications were not
deemed complete by default.
C. Permit Drafting Procedures
Comments: POLK completes the technical reviews and prepares draft permits according to 567 IAC 22.108 and
generally follows the DNR Title V Review Manual, Title V Permit Review Check Sheet and Completeness Review
Checklist. There continues to be appropriate coordination and consistency between the two programs.
D. Public Notice Intent to Issue
[Xl Acceptable Q Corrective Action Needed Q Deficient Q Not evaluated
Comments: POLK is following the new electronic notification process, and at a minimum, posts a notice on a publically
available website and in Iowa EASY Air.
E. Final Permit Issuance
1^1 Acceptable Q Corrective Action Needed Q Deficient Q Not evaluated
Comments: No comments. DNR reviews draft POLK permits prior to the public notice period.
F. Permit Renewals
1^1 Acceptable Q Corrective Action Needed Q Deficient Q Not evaluated
Comments: POLK drafts renewal permits using the same procedures that apply to initial issuance.
G. Reopening Issued Title V Permits
[Xl Acceptable Q Corrective Action Needed Q Deficient Q Not evaluated
Comments: No permits were re-opened during this period.
H. Permit Changes
1^1 Acceptable Q Corrective Action Needed Q Deficient Q Not evaluated
Comments: No comments. DNR reviews draft POLK permits prior to the public notice period.
I. Reporting Requirements
1^1 Acceptable Q Corrective Action Needed Q Deficient Q Not evaluated
Comments: POLK submitted quarterly status reports with the required information on active Title V permit applications.
As noted above under "A. Title V Permit Activities", POLK and DNR staff will work to improve and increase communication
between quarterly reports.
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V. Compliance and Inspection Provisions
File Review Procedures
DNR AQB Compliance Unit staff chose to review six POLK files. The six files reviewed were a sufficient number to
sample the POLK enforcement and compliance program. DNR chose to review file documentation for SFYs 2019-2020.
DNR reviewed the following files:
Major Sources:
MidAmerican Energy Sycamore - 77-09-002
Principal Life Insurance - 77-01-174
Titan Tire Company - 77-01-003
E.P.S. Products Inc. - 77-01-175
Minor Sources
Amcor/Bemis - 77-01-001
Microsoft Corporation - 02086
Prior to the onsite audit, DNR staff requested and reviewed the files sent electronically to the DNR. Additional files were
requested after the initial review. POLK provided the additional files requested very timely. On October 5 and 9, 2020, DNR
staff conferred with POLK staff regarding the inspection reports, ACC and SAMR reports, specific enforcement actions at
one facility, stack testing, ICIS database, and data verification.
A. Compliance
1^1 Acceptable Q Corrective Action Needed Q Deficient Q Not evaluated
Comments: Overall, the files were easily located, well organized and contained the inspection reports, Title V
Annual Certification, and Semi-Annual Reports, as well as other correspondences. The file review showed POLK runs an
effective compliance program. POLK is doing a very good job evaluating, tracking, and documenting the compliance
status with major, synthetic minor and minor facilities.
One NOV for a stack test violation was included for Microsoft Corporation. POLK provided timely responses and
ensured facility follow up pertaining to the noncompliance situation, further detail is provided in the stack test section
of the report. POLK also met all timelines established in the Contract for submitting compliance reports, as well as for
submitting the annual CMS to the DNR for review and approval. DNR received copies of other compliance
correspondences, as required in the Contract.
B. Stack Tests
1^1 Acceptable Q Corrective Action Needed Q Deficient Q Not evaluated
Comments: The Microsoft file contained several stack tests from 2019 for PM/PM10, NOx and CO.
POLK reviews the reports and generates a summary sheet using their own calculations. POLK's results agreed with
results provided by the stack test company. DNR staff noted that acceptance letters included results calculated by POLK
as recommended during the 2018 review. The stack test review included one NOV for emission limit violations. POLK
required a compliance plan, sent a compliance plan acceptance letter and a test acceptance letter for the retest of the
source that demonstrated compliance. The entire procedure from the identification of the violation through the return
to compliance by retesting was well documented.
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DNR also conducted two joint stack test observations with POLK during 2019. A joint observation between POLK and
DNR was conducted on February 20, 2019 at ADM Des Moines and March 19, 2019 at AE Dairy. POLK arrived timely,
ensured the correct test methods were followed, documented relevant process and test information, was available for
testing questions and made method alternative decisions while onsite. No joint observations had been conducted in
2020 as of the drafting of this report due to COVID 19 restricting most observation activities. A joint observation is
currently being scheduled for November 2020.
C. Inspections
1^1 Acceptable Q Corrective Action Needed Q Deficient Q Not evaluated
Comments: POLK uses a modified form of the Title V permit to conduct the Full Compliance Evaluation (FCE) at
major facilities. This provides the inspector with all the information and requirements for each emission point. The
inspection form contains the inspector's on site observations, notes, and source's compliance status. The major source
FCE reports were well documented and clear on how any deviations were addressed. Only one deviation was noted in
an inspection report for follow up but the response due date was outside the review period of this audit.
DNR reviewed two minor source inspection reports in which information was found pertaining to each source at the
facility and if/how compliance was being maintained. No deviations or violations were identified for follow up. DNR
suggested that POLK add a mechanism to clearly identify if a source is an SM80 or true minor.
As required by the Contracts, DNR conducted two joint inspections with POLK in SFY 2019 and in SFY 2020.
D. Variances
I | Acceptable Q Corrective Action Needed Q Deficient Not evaluated
Comments: No variances were included in the files reviewed.
E. Data Management
I | Acceptable ^ Corrective Action Needed Deficient Q Not evaluated
Comments: EPA requires information be logged in ICIS tracking database and POLK is required to enter the MDRs
for all inspections, stack tests, NOVs, Annual Title V Compliance Certifications, and other CMS-related activities in a
timely manner.
Based on the file review, POLK is meeting the MDR requirements entering the FCE within 60 days of the inspection and
entering the Annual Title V Compliance Certification received and review dates.
NOVs, stack tests, Case Files, and Air Programs are compliance monitoring activities POLK is required to report in ICIS.
Two of the six Facilities reviewed had incorrect or missing Air Programs. One of the six facilities reviewed did not have
data entered for an NOV, a Case File, and three stack tests. This is an area where POLK needs improvement and DNR
recommends corrective action.
CMS Category (Major or SM80) and facility criteria pollutants are compliance monitoring activities POLK is required to
report in ICIS. These categories were marked for corrective action in the 2018 Audit report. These categories were
again found to be incomplete or incorrect. As a result, POLK was found deficient in entering data for the required CMS
and Air Pollutants categories.
One of six facilities reviewed had the incorrect CMS source categories listed, thus creating incorrect inspection schedule
dates within ICIS. During the 2018 audit, POLK indicated that the FCE inspection lists are being derived from the
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EnerGov database and not ICIS, so all inspections were done on time. DNR recommends that POLK compare the
EnerGov list generated to the ICIS CMS schedule to determine if the CMS source category is correct. Four of the six
facilities reviewed, Principal Life Insurance, Iowa EPS, MidAmerican Energy Sycamore, and Microsoft Corporation had
pollutants missing or incorrectly identified in the required criteria pollutant list. These items need to be reviewed for
completeness to ensure all pollutants for the facility are entered. DNR is requiring that POLK take corrective action to
address these data management issues.
DNR has agreed to supply a screen shot ICIS manual that DNR follows to provide information in ICIS. Also, POLK
requested training on the entry of NOVs and Case Files which was conducted on October 15, 2020.
Data verification was discussed with POLK to ensure the efforts they are putting forth to update ICIS are being counted
on the federal level. Data verification is voluntary but a way to ensure data is being documented in the correct
locations.
Plan Required
POLK will provide DNR with a written plan, specifically addressing how the CMS Category and facility criteria pollutants
data will be corrected for the Major and SM80 facilities in the ICIS database. This plan will include dates by which the
identified deficiencies will be addressed. The written plan shall be submitted to DNR by February 1, 2021 (or by an
agreed upon alternative date).
F. Emissions Data
1^1 Acceptable Q Corrective Action Needed Q Deficient Q Not evaluated
Comments: POLK requires and observes stack testing at facilities within Polk County. POLK also requires the use of
federal test methods for compliance demonstrations. POLK enters their stack test observations in ICIS which is then
provided to DNR in the compliance report updates. POLK reviews the stack test reports and generates a summary sheet
prior to entering data into the ICIS database. The Microsoft file contained several stack test reports for review. The file
review showed POLK is conducting thorough reviews of stack test reports, performing their own calculation of results,
and sending acceptance letters with results calculated by Polk.
VI. Ambient Air Monitoring Provisions
The program review interview was conducted with the POLK field and QA staff (Brent Blanchard, Jennifer Bradley, Chad
Hines, Jessica Moeller, and Jim Voigt). The review team (Brian Hutchins and John Gering) would like to thank POLK staff
for their helpfulness and candor during the program review.
Commendation
DNR appreciates all the good work that POLK staff have done running their monitoring network over the last two years.
For data collected in 2018 and 2019, all POLK criteria pollutant monitors evaluated by EPA were recommended for
certification. This certification is based on having both good data quality and completeness. Precision and bias stats for
data collected in the most recent complete calendar year were reviewed, and POLK typically met the associated goals.
Eight days prior to DNR's last audit of POLK in October 2018, EPA Region 7 audited all gas and PM samplers at the
Health Dept. site, so official results were not available at that time. Both ozone analyzers were also audited by EPA at
Sheldahl in July 2019. The results from those audits of gas and particulate samplers were well within acceptance limits.
POLK is the only reporting organization in the state running the Beta Attenuation Method (BAM) 1022 samplers for PM
2.5. (SHL and Linn County operate the model 1020 version of the BAM samplers.)
Aside from a site at Lake Sugema, POLK runs the only other N02 monitor in the state.
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POLK has been responsive to suggestions made in previous audits conducted by DNR, and SHL. Some examples include:
• Ongoing participation in EPA's Protocol Gas Verification Program;
• Adding language to their ozone SOP, requiring action in the event of excessive collocated differences;
• Documenting the distance between collocated particulate samplers in their network plans;
• Revising SOPs to assign equal weight to all three levels (zero, precision, and span) in the validation of data
based on daily auto-check results; and
• Editing organizational charts to ensure they are consistent with one another.
Brent Blanchard is retiring after years of service as an ambient monitoring Quality Assurance officer. DNR would like to
express our appreciation and gratitude for his work, and wish him well retirement.
A. Finding/Recommendation #1:
Finding: In the spring of 2017, POLK began running their BAM 1022 PM 2.5 samplers with Very Sharp Cut Cyclone
inlets. Use of that type of inlet made them a Federally Equivalent Method. In 2018, the POC 4 BAM was replaced twice.
It was replaced again in June 2020. Since its start date with the Very Sharp Cut inlet, the POC 3 BAM has shown good
agreement and correlations with the FRM method.
At the audit two years ago, DNR recommended adding validation criteria to the BAM SOP, based on a more than usual
level of disagreement between one BAM and the other, as well as the FRM; and on the duration of such disagreement.
Specifically, DNR recommended a threshold based on a monthly average disagreement between the two samplers of
more than 2.0 ug/m3.
The SHL BAM 1020 SOP also has a section discussing ongoing substantive disagreement between any two PM 2.5
analyzers at a site, and how that will trigger an investigation. The SHL SOP does not mention a specific numerical
threshold, but references a review of 24-hour averages performed every month.
Recommendation: DNR continues to recommend that POLK add language to their BAM SOP describing how excessive
bias between the BAM analyzers, or the BAM analyzers and the FRM, will be defined; and that an investigation will be
required if excessive bias is observed.
B. Finding/Recommendation #2:
Finding: 40 CFR Part 53 defines Class III Acceptance Criteria for continuous PM2.5 monitors. When the 24-hour
averages from the continuous monitor are plotted against the corresponding values from an FRM monitor, the slope
and intercept from the resulting regression line have to meet certain conditions in order for the continuous monitor to
be truly NAAQS comparable. In 2018, both POCs met these criteria, while in 2019 only the POC 3 analyzer met the
standard.
Recommendation: During SLAMs certification in the early part of 2021, DNR will review data collected in 2020 to
determine if POLK's continuous PM2.5 monitors meet Class III Acceptance Criteria. If data is invalidated from
continuous PM2.5 samplers in FEM configuration; the proposal to do so will need to be included in Iowa's Network
Plan, which is put out for public review, and ultimately subject to approval or disapproval by EPA. POLK should work
with DNR and EPA to assign or remove exclusion flags for NAAQS comparability in EPA's AQS database if necessary.
C. Finding/Recommendation #3:
Finding: Prior to the last DNR audit, POLK replaced their mechanical Wind Speed and Wind Direction sensors with
ultrasonic sensors. Ultrasonic wind sensors are a newer technology compared to the traditional sensors that use a vane
to measure wind direction and rotating cups to measure speed. EPA rules for checks and audits were relatively straight
forward and well worked out for traditional WS/WD sensors. However, the QC/QA criteria for ultrasonic sensors is still
onerous and in a process of development.
POLK noted that that Met One Instruments no longer makes the model 50.5 ultrasonic WS/WD sensors they are
currently using. The current POLK budget allocates 10K for purchasing "meteorological sensors". POLK indicated that
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this refers to purchasing a suitable replacement for the ultrasonic WS/WD sensors (rather than temperature or
humidity probes). POLK is uncertain at this point who the vendor will be. The current POLK budget also allocates 8K for
vendor training. POLK has not yet identified a focus for this training. (POLK indicated that at this point, in person
training will probably not be an option because of the Corona virus pandemic.)
Recommendation: DNR suggested that POLK consider training on the ultrasonic met sensors, from the vendor they will
be getting them from. POLK should collaborate with DNR to identify an appropriate training topic for the current fiscal
year.
D. Finding/Recommendation #4:
Finding: In 2017, EPA expanded the options for the types of QC/QA data that the AQS national database stores for gas
analyzers. When a check is performed, both the calibration system and the analyzer might be functioning properly, but
there are two other possible scenarios.
• Scenario #1: the calibration system is working, and the analyzer is not.
• Scenario #2: the calibration system is malfunctioning, and therefore the analyzer only appears to "fail"
Redbook acceptance criteria.
Prior to 2017, Iowa Reporting Organizations didn't record either of these two cases in the precision check portion of
AQS. EPA issued a memo with coding guidance in August 2017, and DNR asked its reporting organizations to implement
the memo starting at the beginning of 2018.
The memo indicated that for the first scenario, the AMP 504 should show both the known and measured check
concentrations without a null code, while data is withheld from the AMP 501 using a null code. For scenario #2 the AMP
504 should show neither check concentration, and a "1C" null code; while the AMP 501 will show valid raw data. POLK
implemented the memo starting at the beginning of 2018.
Recommendation: DNR requests that POLK continue to follow the memo for data collected in 2020. Although
excessive use of the "1C" flag is not a problem in Polk County, DNR indicated that the "1C" flag is not appropriate in
cases where the check was not even initiated. (This would be especially true for a multi-day interval, where it's
established after the first day that the equipment is not functional.) For single day instances, if a check was started and
it failed midway through the check, the 1C flag may be appropriate on a case by case basis.
E. Finding/Recommendation #5:
Finding: In their February 2019 TSA audit of POLK, SHL suggested that POLK "Implement software testing
documentation".
An air quality network typically involves a number of data processing steps. The analyzer itself puts out short term
averages, while an on-site data logger rolls up the short-term averages into a one-hour average, and stores the hourly
average. Then a polling computer located in a central office gathers in all the hourly averages from the on-site data
loggers. Finally, the values that are stored on the polling computer get uploaded into EPA's national AQS data base. One
element of software testing is to verify this process and trace some short-term averages from the time they are
generated by the analyzer, all the way out to the final step of what actually got uploaded into AQS.
POLK monthly reports indicate that the QA officer already performs a "data trail audit" regarding the flow checks, and
collocated concentrations, from PM samplers; and manual bi-weekly checks on gas analyzers. Data from a source prior
to the AQS upload, is compared to the results in the AMP 251. POLK reported they already installed the necessary TEI
software on a laptop that enables them to read values directly from Thermo gas analyzers, and successfully compared
them to hourly averages for N02 in EPA's national database.
Recommendation: DNR recommends that POLK more fully document the steps they are already taking. During the
audit, DNR shared section 14.1.3 of the January 2017 QA Handbook Vol II (Redbook) which contained a description of
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how to perform a Data Trail Audit. DNR also suggested that POLK review the "data trail audit" procedures described in
the Redbook, and expand their own data processing audits to conform to those guidelines as needed.
F. Finding/Recommendation #6:
Finding: An issue that was mentioned in both of the last two SHL TSA audits of POLK was to resume and standardize
the document change log procedure, especially for SOPs. In January 2020, POLK created two files for documenting
changes to their Ozone and N02 SOPs. These were files that were separate from the SOP's themselves and where
stored on a Polk County shared drive. A few weeks ago POLK forwarded copies of these to files to DNR. Some changes
were made to SOPs (e.g. the BAM 1022 SOP) that were not recorded in a log. POLK indicated that this suggestion had
been met with some resistance in their organization, and thought that another option might be submitting SOPs with
track changes enabled.
Recommendation: DNR requests that POLK adopt either of the following two options, in response to SHL's suggestion
to initiate a document change log:
• One option would be to add a concise summary of substantive changes somewhere in the SOP, QAPP, or QMP
itself (e.g. either immediately after the Table of Contents or at the end). This approach may save POLK staff
time in tracking revisions. (DNR provided POLK with an example of a log of changes from a Linn County BAM
SOP during the audit.)
• Alternatively, in future submissions of QA documents to DNR, POLK would submit two versions of each
document. One version would be in MS Word format showing tracked changes since the last version sent to
DNR. A second copy would be "clean" and with all changes accepted.
G. Finding/Recommendation #7:
Finding: Each year (typically in December), POLK performs an on-site SOP operator review where POLK's own QA
officer compares procedures actually used in the field to the written procedures in the SOPs. In this internal audit, the
POLK QA officer indicated that POLK needs to continue working on developing the 49iQ SOP.
The POLK network currently utilizes two generations of Thermo ozone analyzers (the older "\" series, and the newest
"iQ" series). In mid-June 2020, all of POLK's field analyzers were iQ series, while the older "\" series were used as ozone
calibrators. Since June, POLK had to withdraw its iQ field analyzers from the Health Dept. and the only iQ units currently
in the POLK network are two collocated field analyzers at Sheldahl.
In the summer of 2020, DNR (in conjunction with SHL & Thermo) observed erratic behavior in the 1-minute
concentration averages when the trailer temperature was close to the ambient dew point. This problem was
characteristic of some 49iQ analyzers, but was generally not a problem for older "\" series. Due to the unreliability of
the new "iQ" series ozone analyzers, SHL always uses an older "\" series as the primary monitor, and deploys the less
reliable "iQ" monitors only as a secondary monitor.
In April 2020, POLK submitted an SOP related to Ozone with a file name of "Ozone 49iQ SOP 2020". It references both
49i as well as 49iQ instruments (although references to the former appear to be limited to the transfer standards).
Forms 5 and 10 are Field Sheets that have separate fields for the flow through cell A and cell B [see box labeled
"Diagnostic Check (Site Analyzer)"]. While this is appropriate for the 49i transfer standards, the 49iQ field analyzers no
longer have separate flow sensors for each cell. The acceptable flow rate on Forms 5 and 10 is given as 0.4-1.6 LPM.
Although this applies to the 49i instruments, the 49iQflow rate would be higher (1.0-2.5 LPM) since it is the sum of the
flow through both cells. (The same issue probably arises with respect to Form 7, although it's less clear if it's in
reference to the monitor that collects the raw data, the transfer standard, or both.) Section 3.10.1.2 refers to a yearly
verification of the pressure sensors, but does not provide any acceptable limits.
Other states also saw problems with the "iQ" series during times when the ambient dew point was near the trailer
temperature. It's anticipated that EPA will release a memo approving the use of Nafion dryers (to dry the ambient air
going into ozone analyzers). The memo is expected to indicate that the addition of such a drier will not void the Federal
Equivalency status of the monitors.
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Recommendation: DNR encouraged POLK to continue the development and finalization of SOPs and Field Data Sheets
that adequately account for the differences between the two generations of Thermo model 49 ozone analyzers. DNR
suggests that POLK continue to communicate with DNR, Thermo, and EPA and monitor developments for resolving the
49iQ problems. DNR also requests that Polk deploy a 49i as the primary at Sheldahl until the 49iQ issues are resolved.
The design value at Sheldahl might be lost if both 49iQ's experience oscillations in the 1-minute data.
H. Finding/Recommendation #8:
Finding: There were a few other changes recommended by the POLK QA officer as a result of matching procedures
used in the field to the written procedures in the SOPs.
• Two changes were requested and made to the BAM 1022 SOP.
• The OA officer referenced a section of POLK's SOP for wind speed sensors, and noted that the units for the
wind speed span test should be MPH rather than meters per second. In the SOP that DNR received in April
2020, the units are still m/s.
• The OA officer also noted that an update should be made in the SOP for discrete PM2.5 and PM10 samplers.
This was in reference to adding information and instructions about "new automated data collection procedures
for data validation". The specific section of the SOP the QA officer referred to (Section 4.14 on Validation and
Reporting of Data) was not updated in the SOP that DNR received in April 2020.
Recommendation: POLK should verify what the appropriate units are for the wind speed span test and update the SOP
as necessary. POLK should also add information and instructions about new automated data collection procedures for
data validation to their SOP for discrete PM2.5 and PM10 samplers.
I. Finding/Recommendation #9:
Finding: DNR and POLK reviewed the 2019 precision and bias statistics (See Attachment C). The results were good. In
isolated cases where goals were not met, the results were comparable to other states, as well as other reporting
organizations within Iowa.
Recommendation: No additional comments.
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Attachment A
Comments on Specific Polk County Construction Permits
The purpose of the construction permit evaluation was to determine if the program is being conducted in a manner
consistent with the Contract. The investigation looked specifically at the following permit actions, which were intended
to be representative.
Airgas USA
Permit 3431
Ankeny Glass
Permit 3396
Billion FT Des Moines
Permits 3413 and 3414
Construction Products
Permits 3507 and 3508
D&J Plating
Permit 3393
Des Moines Metro Wastewater
Permit 2888 through 2890
Permit 2891 modified
Permit 3405
Flint Hills Resources
Permit 3484
Permit 3504
Helena Industries
Permit 3490 through 3499
Katecho Inc.
Permit 2590
Permit 3033 modified
Permit 3218 modified
Permit 3429
LCS Holdings
Permit 3399
Norwalk Ready Mix
Permits 3476 through 3480
Pioneer Hybrid
Permit 2612 modified
Permit 2743 modified #2
Permit 2808 modified #2
Permit 3398
Permit 3445
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Permits 3453 through 3455
Permit 3512
Quick Steel Fabricators
Permits 3425 through 3427
Siculus
Permits 3064 thru 3249
Titan Tire
Permit 0855 modified #26
Permit 2015 modified #7
Permit 3424
Permit 3442
Permit 3488
Permit 3500
Permit 3502
Permit 3503
The following general issues were noted:
1) Plant-wide synthetic minor limits need to account for all emissions from the facility, either through
recordkeeping or specific limits. For sources that use recordkeeping and have VOC or HAP-emitting sources
(such as boilers or welding) along with surface coating, a facility may find it helpful if the recordkeeping
excludes non-surface coating emissions, with the surface-coating limit adjusted as necessary to keep them a
synthetic minor.
2) Emission calculations should not be based on an expected outlet concentration from a control device. Instead,
emission factors such as AP-42 should be used, with the expected control device efficiency used to determine if
the emission unit can meet the emission limit set in the permit.
3) If a company is currently not subject to a NESHAP because it is not using a target HAP, the DNR suggests either
adding an operating condition forbidding the use of the target HAP, or else noting that the company is not
subject to the NESHAP unless it is using the target HAP.
The following are permit specific issues:
Facility Name:
Flint Hills Resources - Permit 3484. The header of the emission limit table "The following emission limits shall not be
exceeded: For Temporary Emission Units: FT-1 - FT-12 GB-1 and PT-1" could be read as meaning the limit is for each
unit rather than as a combined limit.
Helena Industries - General comments. DNR understands that Helena Industries intends to switch operating
conditions from each permit with a specific HAP limit to a plantwide HAP limit. In these cases, DNR recommends
modifying all affected permits in one project. This ensures that the operating limits do not conflict with each other and
are consistent across the plant. DNR also notes that a facility might find it useful to eliminate sources with minimal HAP
emissions, such as natural gas boilers, from facility wide calculations. For example, if combustion sources at a facility
have a PTE of 0.1 tpy HAP, set the facility wide limit at 9.3 and 24.3 tpy HAP and specify that limit as for non-
combustion sources only. If POLK has any questions about how to handle complex projects such as this, Gary Smith of
the DNR would be happy to help. POLK can also bring up any questions at DNR's regular staff meetings.
Katecho - Permit 3218 modified. In cases such as this, where the material usage limit (713,640 Ibs/yr of acrylic acid)
does not have a clear connection with the VOC limit (5.41 tpy), DNR would suggest including additional information. For
example, a footnote to the VOC limit stating that it is based on the material usage limit in the operating conditions and
using the assumptions in (citation).
2020 Polk County Program Review: Attachment A
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Katecho - Permit 3429. For coating lines, even if a plant is not intending to use a material which contains HAPs, it's
helpful to set a requirement that no HAPs shall be used anyway for area sources, because otherwise VOC limits are also
HAP limits.
Pioneer Hybrid - Permit 3455. If PM10 and PM2.5 limits need to be lower than PM limits due to NAAQS or modeling
concerns over the project, DNR recommends adding a footnote listing either the project number or the rest of the
emission units, to ensure that if a limit for one permit is later raised, the NAAQS will be re-evaluated.
Quick Steel Fabricators - Permit 3426. In the evaluation, the allowable limit for the unit should not be used as an
emission factor.
Quick Steel Fabricators - Permits 3425 and 3427. Permit 3425 has a single HAP/total HAP limit of 0.07 tpy. Permit
3427 has a material usage limit of 2,000 gal/yr with a single HAP limit of 9.4 lbs/gal and a total HAP limit of 24.4 lbs/gal.
DNR would recommend rewriting the material usage limit to 9.33 lb single HAP/gal and 24.33 lb total HAP/gal, in order
to keep the facility a synthetic minor.
Titan Tire - Permits 3487 and 3488. Both of these permits have "To Be Determined" in Condition 9, with an operating
limit that the company must modify the permit with the correct stack characteristics by a due date. Even for VOC-only
sources, DNR would recommend using the most likely characteristics for the original permit.
Modeling Comments
DMMW:
Permits 2890mod and 2891mod: The annual tpy was well below 40, and the Ib/hr rate was not changing, but this
project relaxed the operating limit to 1000 hr/yr. The original permitting for these sources relied on the assumption
that these were intermittent sources (1-hour NOx was not evaluated). The new operating limit excluded these sources
from being classified as intermittent. The full hourly emission rates from these sources should have been compared to
the short term SER (9.13 Ib/hr). This project should have been modeled for N02. It is possible that this error has since
been somewhat offset by emissions reductions in permits 2888 Modified and 2889 Modified.
LCS Holdings:
Permit #3399: The scale used to input the data appears to be off. The aerial photo in the record has the correct UTM
measurements listed for the corners of the image, which would have been imported into BEEST, but the actual model
inputs are about half the size they should be and are shifted about 200 feet NW from their actual location. The
meteorological data is not the correct version. Version B was used instead of E (the current version at the time of the
modeling analysis). In addition, the wrong base elevation was used. These discrepancies were also noted by the
consultant during the permitting process as they corresponded about the analysis.
DNR reran the model with the current version of AERMOD and correcting the various issues noted above and the result
was slightly lower (2.01 ng/m3). The discrepancies were conservative. Smaller buildings created more compact wakes
which decreased initial dispersion at the property line, and the property line was closer to the source. The limit that
was included in the permit is supported by this revised analysis.
2020 Polk County Program Review: Attachment A
3
-------
Attachment B
Polk County Employee Training SFY 2020
Course/Meeting
Location
Date(s)
Attendee(s)
NACAA Monitoring Committee
Conference Call
4/16/20
Jim Voigt
NACAA 2020 Virtual Spring Meeting
Online
5/18/20-5/19/20
Jim Voigt
NACAA discussion on EPA's PM NAAQS Proposal
Conference Call
6/1/20
Jim Voigt
NACAA Monitoring Committee
Conference Call
6/18/20
Jim Voigt
Visible Emissions Evaluation
Des Moines
10/22/2019
Brent Blanchard
NACAA Permitting & Compliance Workshop
St. Louis, MO
2/25 - 2/26/2020
Brent Blanchard
NACAA Spring Membership Meeting
Teleconference
5/18 - 5/19/2020
Brent Blanchard
NACAA Enforcement Committee Call
Conference Call
7/3/2019
Jeremy Becker
EPA Webinar Air Toxics
Webinar
7/24/2019
Jeremy Becker
NACAA Enforcement Committee Call
Conference Call
9/4/2019
Jeremy Becker
IDPH Environmental Health Update
Conference Call
9/16/2019
Jeremy Becker
EPA Webinar on Proposed Oil & Gas NSPS
Webinar
9/26/2019
Jeremy Becker
Budget Review-Polk County
Presentation
10/10/2019
Jeremy Becker
48th Annual Governor's Safety & Health Conference
Conference
Altoona
10/29-11/1/2019
Jeremy Becker
NACAA Enforcement Committee Call
Conference Call
11/6/2019
Jeremy Becker
Title V- EasyAir Training
Go To Meeting
12/12/2019
Jeremy Becker
Major/Minor Fee Advisory Meetings- Local Program
Meeting
12/19/2019
Jeremy Becker
Presentations
ECHO-EPA Webinar
Webinar
2/18/2020
Jeremy Becker
EPA/Iowa DNR/Polk/Linn Discussion - ETO Sterilization
Meeting
2/20/2020
Jeremy Becker
EGov Online Review
Meeting
2/27/2020
Jeremy Becker
Air Quality Website Design Review & Discussion
Meeting
3/9/2020
Jeremy Becker
COVID-19
Meeting
3/17/2020
Jeremy Becker
Umbraco Training
Zoom Meeting
3/30/2020
Jeremy Becker
EPA & Covid 19 Briefing
Conference Call
4/6/2020
Jeremy Becker
Riskpro Accident Reporting Process Review
Zoom Meeting
4/30/2020
Jeremy Becker
Air Quality and Healthy Hearts: Progress and Remaining
Webinar
5/28/20
Jeremy Becker
Challenges
COVID-19 Planning &Telework Progress Review
Zoom Meeting
6/4/2020
Jeremy Becker
NACAA Membership Call
Conference Call
8/12/19
Jennifer Bradley
Easy Air Training
IDNR
9/24/19
Jennifer Bradley
NACAA Air Toxics Committee
Conference Call
10/3/19
Jennifer Bradley
Smoke School
West Des
Moines
10/23/19
Jennifer Bradley
Winter Driving
Polk County
11/8/19
Jennifer Bradley
NACAA Air Sensors Monitoring
Conference Call
12/4/19
Jennifer Bradley
NACAA Permitting & NSR Committee
Conference Call
1/15/20
Jennifer Bradley
IDNR Fee Advisory Meeting-Minor Source
IDNR
1/28/20
Jennifer Bradley
APTI Learning Management System
Webinar
4/15/20
Jennifer Bradley
NACAA Monitoring Committee
Conference Call
4/16/20
Jennifer Bradley
NACAA 2020 Spring Meeting
Webinar
5/18-5/19/2020
Jennifer Bradley
EPA Expands Research on SARS-CoV-2 in the Environment
Webinar
5/27/20
Jennifer Bradley
Air Quality and Healthy Hearts: Progress and Remaining
Webinar
5/28/20
Jennifer Bradley
Challenges
NACAA discussion on EPA's PM NAAQS Proposal
Conference Call
6/1/20
Jennifer Bradley
-------
Course/Meeting
Location
Date(s)
Attendee(s)
Sensor Data on AirNow's Fire and Smoke Map
Webinar
6/9/20
Jennifer Bradley
Environmental Protection Commission
Conference Call
6/16/20
Jennifer Bradley
NACAA Monitoring Committee
Conference Call
6/18/20
Jennifer Bradley
NACAA Criteria Pollutants Committee
Conference Call
6/24/20
Jennifer Bradley
DNRTitle V Meeting
Des Moines, IA
7/24/2019
Jeff Gabby
DNRTitle V Meeting
Des Moines, IA
8/22/2019
Jeff Gabby
First Air/CPR/AED Training
Des Moines, IA
9/17/2019
Jeff Gabby
EASY Air Title VTraining
Des Moines, IA
9/25/2019
Jeff Gabby
DIETING SPOOFS IN AMERICA presentation by Andrew
Des Moines, IA
10/17/2019
Jeff Gabby
Mettille, HR Analyst/Wellness Coordinator
Winter Driving Training
Des Moines, IA
11/8/2019
Jeff Gabby
DNRTitle V Meeting
Des Moines, IA
11/14/2019
Jeff Gabby
DNRTitle V Meeting/EASY Air Training
Des Moines, IA
12/12/2019
Jeff Gabby
DNRTitle V Meeting
Des Moines, IA
1/9/2020
Jeff Gabby
NACAA PERMITTING AND NEW SOURCE REVIEW COMMITTEE
Des Moines, IA
1/15/2020
Jeff Gabby
Conference Call
Lunch & Learn: Stress and Laughter, Drew Mettille
Des Moines, IA
1/16/2020
Jeff Gabby
Major Source Construction Permitting & Title V Fee Advisory
Des Moines, IA
1/28/2020
Jeff Gabby
Group Meeting
DNRTitle V Meeting
Des Moines, IA
2/6/2020
Jeff Gabby
EPA ECHO Training: Enforcement and Compliance History
Des Moines, IA
2/18/2020
Jeff Gabby
Online
DNRTitle V Meeting
Des Moines, IA
3/5/2020
Jeff Gabby
DNRTitle V Meeting
Des Moines, IA
4/2/2020
Jeff Gabby
DNRTitle V Meeting
Des Moines, IA
4/30/2020
Jeff Gabby
DNRTitle V Meeting
Des Moines, IA
5/28/2020
Jeff Gabby
DNRTitle V Meeting
Des Moines, IA
6/25/2020
Jeff Gabby
49 IQTraining
Coralville
8/27/19
Jessica Moeller
American Heart Association CPR/AED Training
Des Moines
9/18/19
Jessica Moeller
Visible Emission Training
Des Moines
10/22/19
Jessica Moeller
Agilaire
Des Moines
10/29-10/30/19
Jessica Moeller
Defensive Driving
Des Moines
11/8/19
Jessica Moeller
NDPTC - PER 343 Social Media Engagement Strategies
Des Moines
2/4/20
Jessica Moeller
NDPTC - PER 344 Social Media Tools and Techniques
Des Moines
2/5/20
Jessica Moeller
APTI SI - 460
Online
5/16/20
Jessica Moeller
NACAA 2020 Virtual Spring Meeting
Online
5/18/20-5/19/20
Jessica Moeller
EPA-Air Quality & Healthy Hearts: Progress and Remaining
Online
5/28/20
Jessica Moeller
Challenges
EPA-PM NAAQS
Online
6/1/20
Jessica Moeller
CenSARA -NACT 335 Environmental Compliance
IDNR
8/6 - 8/8
Bridget
McNerney
First Aid/CPR
Polk County
9/18/19
Bridget
McNerney
Smoke School
Method 9
10/22/19
Bridget
McNerney
ECHO Webinar-Search tools
Computer
Bridget
McNerney
ECHO Webinar-enforcement and compliance history online
Computer
11/12/19
Bridget
McNerney
NAACA Annual Conference
Remote
computer/phone
5/18/20
Bridget
McNerney
2020 Polk County Program Review: Attachment B
2
-------
Course/Meeting
Location
Date(s)
Attendee(s)
NAACA Annual
Remote
5/19/20
Bridget
Conference
computer/phone
McNerney
49 IQTraining
Coralville
8/27/19
Chad Hines
Visible Emission Training
Des Moines
10/22/19
Chad Hines
Agilaire
Des Moines
10/29-10/30/19
Chad Hines
Defensive Driving
Des Moines
11/8/19
Chad Hines
NACAA Permitting and Enforcement Workshop
St. Louis - MO
2/25-2/27/20
Chad Hines
NACAA 2020 Virtual Spring Meeting
Online
5/18/20-5/19/20
Chad Hines
NSR/PSD Workshop
Online
6/8-6/12/20
Chad Hines
EPA-PM NAAQS
Online
6/1/20
Chad Hines
2020 Polk County Program Review: Attachment B
3
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Attachment C.
Summary of POLK Precision and Bias*
*Results from DNR's SLAMS certification review for 2019
PM2.5 FRM routine co-located pairs:
Goal for CV< 10.1%.
PM2.5FRM PEP concentration pairs:
Is the "Bias" < 10.1%?
Polk 19-153-0030
4.19%
Polk 19-153-0030
-18.43%
PM2.5 FRM PEP concentration pairs: Is the absolute value o
Polk 19-153-0030
-30.74% to -6.12%
PM10 routine co-located pairs:
Goal for CV< 10.1%.
both LCL and UCL for "Bias" < 10.1%?
PMcoarse routine co-located pairs:
Goal for CV< 10.1%
Polk 19-153-0030
6.93%
Polk 19-153-0030
13.58%
Audit limits should fall into confidence limits obtained from routine checks. As a goal, ninety-five percent of the
individual percent differences (all audit concentration levels, from all monitors) should be captured within the
probability intervals for the same primary quality assurance organization (from bi-weekly checks done on all
monitors). Yellow highlight indicates values <75%. (Note that this statistic does not account for the uncertainty in
the known value of the audit gas, and the uncertainty in the known value of the routine calibration gas. Also, smal
and consistent percent differences during automated daily and manual bi-weekly checks narrow the confidence
limits making it more difficult to attain the goal. (EPA dropped this assessment in their April 2016 revisions to 40
CFR Part 58.)
Pollutant
Polk
CO
58%
N02
94%
Ozone
69%
PM2.5 (FRM & BAM)
75%
PM10 Discrete
88%
For bias, the sign should be neutral (+/-) instead of positive (+) or negative (-). The magnitude of the bias for
pollutants other than ozone and NO2 should be less than 10.1%. For NO2 the magnitude of the bias should be less
than 15.1%, and for ozone it should be less than 7.1%. The bias results for the POLK reporting organization are
presented in the table below:
Pollutant
Sign of Bias
Magnitude of Bias
CO:
+/-
1.75%
N02:
+/-
2.66%
Ozone:
+/-
1.02%
PM2.5 FRM & BAM:
+/-
0.89%
PM10 Discrete:
+/-
1.22%
PM Coarse:
+/-
12.18%
All the bias signs were neutral. In addition the magnitude of the bias almost always met the associated goal.
-------
Attachment D
Polk County Comments and DNR Responses
III. Construction Permitting and Dispersion Modeling Provisions
Modeling Comments: POLK staff trained in dispersion modeling exhibit an understanding of current EPA and DNR
modeling guidelines, have the ability to perform and review dispersion modeling analyses, are able to use the modeling
output to determine compliance with the applicable ambient air quality standards, and understand the strategies and
control measures used to mitigate modeled exceedances of these standards.
POLK requests assistance from DNR in reviewing modeling analyses, as appropriate, and is encouraged to continue to
contact DNR staff for assistance related to dispersion modeling. DNR will continue to assist POLK by conducting a
quality assurance (OA) review of each modeling project conducted or reviewed by POLK. DNR will provide an updated
OA checklist to use for this purpose.
The majority of the projects that were reviewed did not require a modeling analysis. Those that were modeled
contained no modeling errors that would have negatively impacted the resulting permits.
There are several good items to note:
6. POLK continues to review the impact from air toxics.
7. Modeling determinations are well documented, especially as it relates to project emissions levels.
8. POLK correctly waives modeling analyses in cases where emission reductions offset new sources.
9. Previous applications are considered when determining if projects should be aggregated for modeling
determinations.
10. POLK uses MERPs to address secondary formation.
Some areas for improvement include:
7. Verify use of correct version of the model (check settings in BEEST each time the model is run).
8. Verify that the current version of the meteorological data are used and that the correct base elevation is applied
(there can be different versions of the same five-year set of meteorology; the newest version should be
downloaded from the DNR website at the time of analysis).
9. Make sure to use the correct scale when inputting model objects (LCS Holdings).
10. Verify correct modeling information is provided in the record (the Siculus checklist in the record was for the
previous project).
11. Follow up on revisions to modeling (Siculus) due to discrepancies noted during review of submitted analyses. Make
sure final modeling files are included in the record.
12. Relaxation of the operating limits for intermittent sources needs to be considered when determining if modeling
will be necessary for 1-hour N02 (DMMW).
Polk County Comment: We agree with the findings and recommendations for improvement and have begun to
implement the suggestions.
DNR Response: No response or report changes are needed.
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V. Compliance and Inspection Provisions
G. Data Management
I | Acceptable Corrective Action Needed
Comments:
One of six facilities reviewed had the incorrect CMS source categories listed, thus creating incorrect inspection schedule
dates within ICIS. During the 2018 audit, POLK indicated that the FCE inspection lists are being derived from the
EnerGov database and not ICIS, so all inspections were done on time. DNR recommends that POLK compare the
EnerGov list generated to the ICIS CMS schedule to determine if the CMS source category is correct. Four of the six
facilities reviewed, Principal Life Insurance, Iowa EPS, MidAmerican Energy Sycamore, and Microsoft Corporation had
pollutants missing or incorrectly identified in the required criteria pollutant list. These items need to be reviewed for
completeness to ensure all pollutants for the facility are entered. DNR is requiring that POLK take corrective action to
address these data management issues.
DNR has agreed to supply a screen shot ICIS manual that DNR follows to provide information in ICIS. Also, POLK
requested training on the entry of Notice of Violations (NOVs) and Case Files which was conducted on October 15,
2020.
Data verification was discussed with POLK to ensure the efforts they are putting forth to update ICIS are being counted
on the Federal level. Data verification is voluntary but a way to ensure data is being documented in the correct
locations.
Plan Required
POLK will provide DNR with a written plan, specifically addressing how the CMS Category and facility criteria pollutants
data will be corrected for the Major and SM80 facilities in the ICIS Database. This plan will include dates by which the
identified deficiencies will be addressed. The written plan shall be submitted to DNR by January 1, 2021 or an
alternatively agreed upon date. [Note: The due date for the written plan has been changed in the body of the Report
from the date indicated above in response to POLK comments and DNR review, as explained below.]
Polk County Comments:
Polk County addressed the CMS category and facility criteria pollutant data in ICIS-Air for Major and SM80 facilities
located in Polk County. A summary of pollutant classifications for Title V facilities are detailed in the table below.
DNR Response: No response or Report changes are needed.
Polk County Title V Major Facilities in ICIS-Air:
As of November 16, 2020, the Polk County Title V facility annual PTE by pollutant totals are shown in the table below.
The compliance monitoring strategy (CMS) for Major facility criteria pollutants are updated to correspond with the
major/minor pollutant designations provided by Title V staff and reported in ICIS-Air air pollutants categories.
DNR Response: No response or Report changes are needed.
X Deficient rj Not evaluated
2020 Polk County Program Review: Attachment D
2
-------
AIRS#
FACILITY
PM10
TPY
S02
TPY
NOX
TPY
voc
(HAPs) ** TPY
CO
TPY
Lead
TPY
00530
AD.M.
1935 E. Euclid Ave., Des Moines
145.68
163.94
363.97
853.16
(962.77)
171.31
0.57
03677
Quality Manufacturing Corp.
4300 Urbandale Drive, Urbandale
48.15
0.02
3.60
227.48
(24.40)
3.03
"
03199
Siegwerk USA, Inc.
129 SE 18th Street, Des Moines
20.29
"
~
306.53
(2.94)
~
~
00147
Siegwerk USA, Inc.
SW 56th Street, Des Moines
5.23
0.29
5.19
104.01
3.39
0
00216
Construction Products
1625 E. Broadway, Des Moines
30.87
0.20
1.01
113.56
(89.11)
0.58
-
00380
Iowa EPS Products, Inc.
5554 NE 16th Street,
Des Moines
37.15
0.06
9.70
240.54
(3.41)
8.14
00250
Bridgestone Americas Tire
nd
2 Avenue & Hoffman Road, Des Moines
947.08
18.58
351.77
684.20
(24.4)
213.15
~
00187
Des Moines Metropolitan Reclamation Waste Authority
3000 Vandalia Road, Des Moines
12.70
7.95
92.35
59.51
(10.57)
192.12
-
00390
John Deere Des Moines Works
Highway 415 N., Ankeny
42.34
3.11
97.64
226.41
(15.66)
65.28
-
00387
MidAmerican: Pleasant Hill / GDMEC CTs
4401 Carlisle Road, Pleasant Hill
687.08
65.80
508.32
80.51
(11.40)
755.74
0.01
00386
MidAmerican: Sycamore CTs
6141 NW Beaver Dr., Johnston
1,747.62
3,914.80
6,990.60
17.82
(10.20)
696.06
0.12
00385
MidAmerican: River Hills CTs
nd
2 and Grand Avenue, Des Moines
2,467.20
4,152.40
7,499.34
27.44
(10.80)
755.50
0.07
00490
CB&I Constructors, Inc.
9600 Hickman Road, Clive
441.22
-
639.51
(506.20)
00050
Titan Tire Corporation
2345 E. Market Street, Des Moines
318.57
1226.58
221.02
698.45
(82.01)
46.29
"
00851
Metro Methane Recovery
1216112th Ave. NE, Mitchel 1 ville
21.31
54.28
221.55
33.0
(13.70)
452.94
~
00426
Metro Park East Landfill
1218112th Ave. NE, Mitchel 1 vil le
0
0
0
21.00
(13.30)
0
~
02874
Megellan Pipeline Co., L.P.
2503 SE 43 d Street, Des Moines
8.43
0
3.90
392.92
(24.4)
4.37
~
02021
Principal Life Insurance Co.
616 10th Street, Des Moines
11.65
98.59
255.85
9.90
(1.47)
55.12
~
02450
Siculus, Inc.
100 Share Way, Altoona
1.55
0.16
249.00
3.34
(0.16)
23.29
"
Polk County SM80 facilities in ICIS-Air:
As of November 17, 2020, Polk County has identified 309 SM80 facilities and staff is currently processing annual
operating permit applications and will update out-of-business status and facility SM80 classification for inclusion in
future CMS plans. A current Polk County SM80 list is provided in appendix D.
DNR Response: No response or Report changes are needed. Note that the POLK SM80 list is provided in Attachment E
of the Final Report.
2020 Polk County Program Review: Attachment D
3
-------
Polk County Comments for Plan Required: If DNR agrees that the deficiencies are corrected, in substitution of a
written plan Polk County is working on creating an ICIS-Air SOP for CMS/facility/NOVs/Stack tests/Case Files/Air
Programs workflows to help ensure future data entry compliance and anticipates a draft version will be completed by
February 29, 2021 for Iowa DNR review.
DNR Response: DNR agrees with POLK's approach. However, POLK shall submit a separate written plan to DNR by
February 1, 2021 (or an agreed upon alternative date), detailing the approach and deadline that POLK has proposed in
the above comment. DNR has updated the body of the Final Report to indicate the revised due date for POLK's plan.
VI. Ambient Air Monitoring Provisions
C. Finding/Recommendation #3:
Finding: Prior to the last DNR audit, POLK replaced their mechanical Wind Speed and Wind Direction sensors with
ultrasonic sensors. Ultrasonic wind sensors are a newer technology compared to the traditional sensors that use a vane
to measure wind direction and rotating cups to measure speed. EPA rules for checks and audits were relatively straight
forward and well worked out for traditional WS/WD sensors. However, the QC/QA criteria for ultrasonic sensors is still
onerous and in a process of development.
POLK noted that that Met One Instruments no longer makes the model 50.5 ultrasonic WS/WD sensors they are
currently using. The current POLK budget allocates 10K for purchasing "meteorological sensors". POLK indicated that
this refers to purchasing a suitable replacement for the ultrasonic WS/WD sensors (rather than temperature or
humidity probes). POLK is uncertain at this point who the vendor will be. The current POLK budget also allocates 8K for
vendor training. POLK has not yet identified a focus for this training. (POLK indicated that at this point, in person
training will probably not be an option because of the Corona virus pandemic.)
Recommendation: DNR suggested that POLK consider training on the ultrasonic met sensors, from the vendor they will
be getting them from. POLK should collaborate with DNR to identify an appropriate training topic for the current fiscal
year.
Polk County Comments: Polk County will continue to research the WS/WD sensors available. Once a new sensor has
been chosen Polk County will coordinate with IDNR on specific training for sensors.
DNR Response: No response or Report changes are needed.
D. Finding/Recommendation #4:
Finding: In 2017, EPA expanded the options for the types of QC/QA data that the AQS national database stores for gas
analyzers. When a check is performed, both the calibration system and the analyzer might be functioning properly, but
there are two other possible scenarios.
• Scenario #1: the calibration system is working, and the analyzer is not.
• Scenario #2: the calibration system is malfunctioning, and therefore the analyzer only appears to "fail"
Redbook acceptance criteria.
Prior to 2017, Iowa Reporting Organizations didn't record either of these two cases in the precision check portion of
AQS. EPA issued a memo with coding guidance in August 2017, and DNR asked its reporting organizations to implement
the memo starting at the beginning of 2018.
The memo indicated that for the first scenario, the AMP 504 should show both the known and measured check
concentrations without a null code, while data is withheld from the AMP 501 using a null code. For scenario #2, the
AMP 504 should show neither check concentration, and a "1C" null code; while the AMP 501 will show valid raw data.
POLK implemented the memo starting at the beginning of 2018.
Recommendation: DNR requests that POLK continue to follow the memo for data collected in 2020. Although
excessive use of the "1C" flag is not a problem in Polk County, DNR indicated that the "1C" flag is not appropriate in
cases where the check was not even initiated. (This would be especially true for a multi-day interval, where it's
2020 Polk County Program Review: Attachment D 4
-------
established after the first day that the equipment is not functional.) For single day instances, if a check was started and
it failed midway through the check, the 1C flag may be appropriate on a case by case basis.
Polk County Comments: Polk County agrees with this recommendation
DNR Response: No response or Report changes are needed.
F. Finding/Recommendation #6:
Finding: An issue that was mentioned in both of the last two SHL TSA audits of POLK was to resume and standardize
the document change log procedure, especially for SOPs. In January 2020, POLK created two files for documenting
changes to their Ozone and N02 SOPs. These were files that were separate from the SOP's themselves and where
stored on a Polk County shared drive. A few weeks ago, POLK forwarded copies of these to files to DNR. Some changes
were made to SOPs (e.g. the BAM 1022 SOP) that were not recorded in a log. POLK indicated that this suggestion had
been met with some resistance in their organization, and thought that another option might be submitting SOPs with
track changes enabled.
Recommendation: DNR requests that POLK adopt either of the following two options, in response to SHL's suggestion
to initiate a document change log:
• One option would be to add a concise summary of substantive changes somewhere in the SOP, QAPP, or QMP
itself (e.g. either immediately after the Table of Contents or at the end). This approach may save POLK staff
time in tracking revisions. (DNR provided POLK with an example of a log of changes from a Linn County BAM
SOP during the audit.)
• Alternatively, in future submissions of QA documents to DNR, POLK would submit two versions of each
document. One version would be in MS Word format showing tracked changes since the last version sent to the
DNR. A second copy would be "clean" and with all changes accepted.
Polk County Comments: Polk County has already instituted the document change log to several SOPs. Polk County will
continue to create one for each document.
DNR Response: No response or Report changes are needed.
G. Finding/Recommendation #7:
Finding: Each year (typically in December) POLK performs an on-site SOP operator review where POLK's own QA officer
compares procedures actually used in the field to the written procedures in the SOPs. In this internal audit, the POLK
QA officer indicated that POLK needs to continue working on developing the 49iQ SOP.
The POLK network currently utilizes two generations of Thermo ozone analyzers (the older "\" series, and the newest
"iQ" series). In mid-June 2020, all of POLK's field analyzers were iQ series, while the older "\" series were used as ozone
calibrators. Since June, POLK had to withdraw its iQ field analyzers from the Health Dept. and the only iQ units currently
in the POLK network are two collocated field analyzers at Sheldahl.
In the summer of 2020, DNR (in conjunction with SHL & Thermo) observed erratic behavior in the 1-minute
concentration averages when the trailer temperature was close to the ambient dew point. This problem was
characteristic of some 49iQ analyzers, but was generally not a problem for older "\" series. Due to the unreliability of
the new "iQ" series ozone analyzers, SHL always uses an older "\" series as the primary monitor, and deploys the less
reliable "iQ" monitors only as a secondary monitor.
In April 2020, POLK submitted only one SOP related to Ozone. It references both 49i as well as 49iQ instruments. Forms
5 and 10 are Field Sheets that have separate fields for the flow through cell A and cell B [see box labeled "Diagnostic
Check (Site Analyzer)"]. While this is appropriate for the 49i transfer standards, the 49iQ field analyzers no longer have
separate flow sensors for each cell. The acceptable flow rate on Forms 5 and 10 is given as 0.4-1.6 LPM. Although this
applies to the 49i instruments, the 49iQflow rate would be higher (1.0-2.5 LPM) since it is the sum of the flow through
both cells. (The same issue probably arises with respect to Form 7, although it's less clear if it's in reference to the
monitor that collects the raw data, the transfer standard, or both.) Section 3.10.1.2 refers to a yearly verification of the
pressure sensors, but does not provide any acceptable limits.
2020 Polk County Program Review: Attachment D
5
-------
Other states also saw problems with the "iQ" series during times when the ambient dew point was near the trailer
temperature. It's anticipated that EPA will release a memo approving the use of Nafion dryers (to dry the ambient air
going into ozone analyzers). The memo is expected to indicate that the addition of such a drier will not void the Federal
Equivalency status of the monitors.
Recommendation: DNR encouraged POLK to continue the development and finalization of SOPs and Field Data Sheets
that adequately account for the differences between the two generations of Thermo model 49 ozone analyzers. DNR
suggests that POLK continue to communicate with the DNR, Thermo, and EPA and monitor developments for resolving
the 49iQ problems. DNR also requests that Polk deploy a 49i as the primary at Sheldahl until the 49iQ issues are
resolved. The design value at Sheldahl might be lost if both 49iQ's experience oscillations in the 1-minute data.
Polk County Comments: Polk County currently has two separate SOPs for the ozone monitors. Polk County will update
field sheets for 49 iQ parameters. Starting with the 2021 Ozone season, Polk County will have a 49i deployed at
Sheldahl for the primary monitor.
DNR Response: POLK is correct in stating that they submitted two ozone SOPs on April 30, 2020. (The first submission
of their Annual Review in March 2020 contained some outdated documents and included only one ozone SOP which
appears to apply to both the 49i and 49iQ.) The second submission of Polk's Annual Review (from April 30, 2020)
contained two ozone SOPs, one pertaining exclusively to the 49i series, and another with a file name of "Ozone 49iQ
SOP 2020". The body of the Final Report, third paragraph in Finding/Recommendation #7, has been updated for the
changes shown below. DNR apologizes for any confusion in DNR's Finding.
In April, 2020 POLK submitted only ono SOP rolatod to Ozono. It roforoncos both <19i as woll as <19iQ
instruments. In April 2020, POLK submitted an SOP related to Ozone with a file name of "Ozone 49iQ SOP
2020". It references both 49i as well as 49iQ instruments (although references to the former appear to be
limited to the transfer standards). Forms 5 and 10 are Field Sheets that have separate fields for the flow
through cell A and cell B [see box labeled "Diagnostic Check (Site Analyzer)"]. While this is appropriate for the
49i transfer standards, the 49iQfield analyzers no longer have separate flow sensors for each cell. The
acceptable flow rate on Forms 5 and 10 is given as 0.4-1.6 LPM. Although this applies to the 49i instruments,
the 49iQflow rate would be higher (1.0-2.5 LPM) since it is the sum of the flow through both cells. (The same
issue probably arises with respect to Form 7, although it's less clear if it's in reference to the monitor that
collects the raw data, the transfer standard, or both.) Section 3.10.1.2 refers to a yearly verification of the
pressure sensors, but does not provide any acceptable limits.
H. Finding/Recommendation #8:
Finding: There were a few other changes recommended by the POLK QA officer as a result of matching procedures
used in the field to the written procedures in the SOPs.
• Two changes were requested, and made, to the BAM 1022 SOP.
• The QA officer referenced a section of POLK's SOP for wind speed sensors, and noted that the units for the
wind speed span test should be MPH rather than meters per second. In the SOP that DNR received in April
2020, the units are still m/s.
• The QA officer also noted that an update should be made in the SOP for discrete PM2.5 and PM10 samplers.
This was in reference to adding information and instructions about "new automated data collection procedures
for data validation". The specific section of the SOP the QA officer referred to (Section 4.14 on Validation and
Reporting of Data) was not updated in the SOP that DNR received in April 2020.
Recommendation: POLK should verify what the appropriate units are for the wind speed span test and update the SOP
as necessary. POLK should also add information and instructions about new automated data collection procedures for
data validation to their SOP for discrete PM2.5 and PM10 samplers.
Polk County Comments: Polk County will update the SOPs to reflect the changes found during SOP operator reviews.
DNR Response: No response or Report changes are needed.
2020 Polk County Program Review: Attachment D
6
-------
Polk Comments and DNR Responses for Attachment A
The following general issues were noted:
1) Plant-wide synthetic minor limits need to account for all emissions from the facility, either through
recordkeeping or specific limits. For sources that use recordkeeping and have VOC or HAP-emitting sources
(such as boilers or welding) along with surface coating, a facility may find it helpful if the recordkeeping
excludes non-surface coating emissions, with the surface-coating limit adjusted as necessary to keep them a
synthetic minor.
Polk Comments: When facility wide emission limits are included for VOC and HAP emissions, sources that can
be subtracted out from facility wide totals and their associated recordkeeping requirements will be excluded.
DNR Response: No response or Report changes are needed.
2) Emission calculations should not be based on an expected outlet concentration from a control device. Instead,
emission factors such as AP-42 should be used, with the expected control device efficiency used to determine if
the emission unit can meet the emission limit set in the permit.
Polk Comments: Moving forward, we will use emission factors to evaluate emission limits.
DNR Response: No response or Report changes are needed.
3) If a company is currently not subject to a NESHAP because it is not using a target HAP, DNR suggests either
adding an operating condition forbidding the use of the target HAP, or else noting that the company is not
subject to the NESHAP unless it is using the target HAP.
Polk Comments: When applicable, it is our intention to include an operating condition as stated above. It
would only be excluded as an oversight. We will be more diligent about making sure this condition is included
moving forward.
DNR Response: No response or Report changes are needed.
The following are permit specific issues:
Facility Name:
Flint Hills Resources - Permit 3484. The header of the emission limit table "The following emission limits shall not be
exceeded: For Temporary Emission Units: FT-1 - FT-12 GB-1 and PT-1" could be read as meaning the limit is for each
unit rather than as a combined limit.
Polk Comments: The header will be changed to clarify that the limit applies to all combined units.
DNR Response: No response or Report changes are needed.
Helena Industries - General comments. DNR understands that Helena Industries intends to switch operating
conditions from each permit with a specific HAP limit to a plantwide HAP limit. In these cases, DNR recommends
modifying all affected permits in one project. This ensures that the operating limits do not conflict with each other and
are consistent across the plant. DNR also notes that a facility might find it useful to eliminate sources with minimal HAP
emissions, such as natural gas boilers, from facility wide calculations. For example, if combustion sources at a facility
have a PTE of 0.1 tpy HAP, set the facility wide limit at 9.3 and 24.3 tpy HAP and specify that limit as for non-
combustion sources only. If POLK has any questions about how to handle complex projects such as this, Gary Smith of
the DNR would be happy to help. POLK can also bring up any questions at DNR's regular staff meetings.
Polk Comments: Helena's Operating Permit will be revised to insert facility wide HAP limits where applicable,
subtracting out minor combustion sources. If problems are found with these revisions, Gary Smith will be contacted for
assistance.
DNR Response: No response or Report changes are needed.
Quick Steel Fabricators - Permit 3426. In the evaluation, the allowable limit for the unit should not be used as an
emission factor.
Polk Comments: Moving forward, we will use emission factors to evaluate emission limits.
DNR Response: No response or Report changes are needed.
2020 Polk County Program Review: Attachment D
7
-------
Quick Steel Fabricators - Permits 3425 and 3427. Permit 3425 has a single HAP/total HAP limit of 0.07 tpy. Permit
3427 has a material usage limit of 2,000 gal/yr with a single HAP limit of 9.4 lbs/gal and a total HAP limit of 24.4 lbs/gal.
DNR would recommend rewriting the material usage limit to 9.33 lb single HAP/gal and 24.33 lb total HAP/gal, in order
to keep the facility a synthetic minor.
Polk Comments: Permits will be revised per your recommendation.
DNR Response: No response or Report changes are needed.
Modeling Comments
DMMW:
Permits 2890mod and 2891mod: The annual tpy was well below 40, and the Ib/hr rate was not changing, but this
project relaxed the operating limit to 1000 hr/yr. The original permitting for these sources relied on the assumption
that these were intermittent sources (1-hour NOx was not evaluated). The new operating limit excluded these sources
from being classified as intermittent. The full hourly emission rates from these sources should have been compared to
the short term SER (9.13 Ib/hr). This project should have been modeled for N02. It is possible that this error has since
been somewhat offset by emissions reductions in permits 2888 Modified and 2889 Modified.
Polk Comments: The facility is planning to submit permit modifications for the four generators so that they all have a
500 hour/year limit and are all intermittent sources.
DNR Response: No response or Report changes are needed.
2020 Polk County Program Review: Attachment D
8
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Attachment E
Polk County-Identified CMS 80% SM Facilities
Polk Comments: As of November 17, 2020, Polk County has identified 309 SM80 facilities and staff is currently
processing annual operating permit applications and will update out-of-business status and facility SM80 classification
for inclusion in future CMS plans.
AIRName
SoureelD
AIRStreet
AIRCity
AIRState
Al RCmsCategoryDesc
ABSOLUT DRY CLEANERS
IAPLK0001915304060
917 E 1ST ST
ANKENY
IA
80% Synthetic Minor
ACHESONAUTO BODY
IAPLK0001915303028
1103 SW 63 RD ST
DES MOINES
IA
80% Synthetic Minor
ACHESONAUTO WORKS
IAPLK0001915303030
8000 UNIVERSITY BLVD
DES MOINES
IA
80% Synthetic Minor
ADOCAR AUTO BODY & PAINT
IAPLK0001915303848
1605 E MADISON
DES MOINES
IA
80% Synthetic Minor
AIRGAS USA LLC
IAPLK0001915303052
410 SE CREEKVIEW DR
ANKENY
IA
80% Synthetic Minor
ALTOONA AUTO BODY INC
IAPLK0001915303070
5011ST AVE N
ALTOONA
IA
80% Synthetic Minor
ALTOONA, CITY OF
IAPLK0001915302108
90117 AVENUE SW
ALTOONA
IA
80% Synthetic Minor
AMERICAN AND FOREIGN BODYWORKS
IAPLK0001915303075
2812 4TH ST
DES MOINES
IA
80% Synthetic Minor
AMERICAN CONTRACT SYSTEMS INC
IAPLK0001915300022
1601 SE GATEWAY DR. SUITE 120
GRIMES
IA
80% Synthetic Minor
ANKENYAUTO BODY INC
IAPLK0001915303084
1501 SE CORTINA DR
ANKENY
IA
80% Synthetic Minor
ANKENY CLEANERS
IAPLK0001915304080
122 S ANKENY BLVD
ANKENY
IA
80% Synthetic Minor
ANKENY GLASS, INC
IAPLK0001915301049
6335 NE INDUSTRY DR.
DES MOINES
IA
80% Synthetic Minor
APE CONGNITION AND COMMUNICATION
INSTITUTE
IAPLK0001915302134
4200 EVERGREEN AVE
DES MOINES
IA
80% Synthetic Minor
ARAMARK UNIFORM & CAREER APPAREL
IAPLK0001915300418
2500 DELAWARE AVE
DES MOINES
IA
80% Synthetic Minor
ARNOLD MOTOR SUPPLY
IAPLK0001915303002
610 N ANKENY BLVD
ANKENY
IA
80% Synthetic Minor
ARTISTIC IRON WORKS
IAPLK0001915300052
519 SE 4 STREET
DES MOINES
IA
80% Synthetic Minor
AT&T
IAPLK0001915300056
4157 109TH ST
URBAN DALE
IA
80% Synthetic Minor
ATLANTIC BOTTLING COMPANY
IAPLK0001915302177
3600 ARMY POST RD
DES MOINES
IA
80% Synthetic Minor
ATM TED'S BODY SHOP INC
IAPLK0001915303011
1007 8TH ST. SW
ALTOONA
IA
80% Synthetic Minor
AUTO CARE LLC DBA MINOR WRECK EXPRESS
IAPLK0001915303078
5530 NW BEAVER DR UNIT 400
JOHNSTON
IA
80% Synthetic Minor
BARTON SOLVENTS INC
IAPLK0001915300060
1970 NE BROADWAY
DES MOINES
IA
80% Synthetic Minor
BERG LAND SHEET METAL CONTRACTORS INC
IAPLK0001915300070
10210 DENNIS DRIVE
URBAN DALE
IA
80% Synthetic Minor
BERKLEY TECHNOLOGY SERVICES
IAPLK0001915302005
3840 109TH ST
URBAN DALE
IA
80% Synthetic Minor
BICKEL MOTORS
IAPLK0001915303164
2507 NE 46TH AVE
DES MOINES
IA
80% Synthetic Minor
BLAKE'S AUTO BODY & EXHAUST
IAPLK0001915303903
1210 E 29TH ST
DES MOINES
IA
80% Synthetic Minor
BOB BROWN CHEVROLET
IAPLK0001915303189
3600 111TH ST
URBAN DALE
IA
80% Synthetic Minor
BODY PARTS STORE, THE
IAPLK0001915300018
1863 NE 54TH AVE
DES MOINES
IA
80% Synthetic Minor
BOMBELA HOLDING COMPANINES, LLC DBA
UNITED TRUCK & BODY
IAPLK0001915303869
5129 NE 17TH ST
DES MOINES
IA
80% Synthetic Minor
BONDURANTAUTO BODY
IAPLK0001915303169
3300 HENRY ST SW STE 6
BONDURANT
IA
80% Synthetic Minor
BORGEN SYSTEMS
IAPLK0001915300650
1901 BELL AVE
DES MOINES
IA
80% Synthetic Minor
BRAD'S COLLISION CENTER INC
IAPLK0001915303087
4700 SE 14TH ST
DES MOINES
IA
80% Synthetic Minor
BRIGGS MEDICAL SERVICE COMPANY
IAPLK0001915300335
7855 UNIVERSITY BLVD
DES MOINES
IA
80% Synthetic Minor
BROADLAWNS MEDICAL CENTER
IAPLK0001915301046
1801 HICKMAN RD
DES MOINES
IA
80% Synthetic Minor
BUCKEYE TERMINALS LLC-DES MOINES
IAPLK0001915303076
1501 NW 86 STREET
WEST DES MOINES
IA
80% Synthetic Minor
BUD LEMKE MASONRY
IAPLK0001915303082
5805 NW 54TH CT
JOHNSTON
IA
80% Synthetic Minor
CABRERA'S AUTO BODY
IAPLK0001915303300
4425 NW 2ND ST
DES MOINES
IA
80% Synthetic Minor
CAMPUS CLEANERS
IAPLK0001915304135
3401 UNIVERSITY AVE
DES MOINES
IA
80% Synthetic Minor
CAPTIVE PLASTICS LLC
IAPLK0001915300295
2201 BELL AVENUE
DES MOINES
IA
80% Synthetic Minor
CAR MAX #6004
IAPLK0001915303020
10315 HICKMAN RD
URBAN DALE
IA
80% Synthetic Minor
CARDINAL CLEANERS INC
IAPLK0001915304241
1245 21ST STREET
DES MOINES
IA
80% Synthetic Minor
CARNOCK CREATIONS., LLC
IAPLK0001915303293
4905 HUBBELL AVE.
DES MOINES
IA
80% Synthetic Minor
CEDAR VALLEY CORP LLC
IAPLK0001915300035
PORTABLE
DES MOINES
IA
80% Synthetic Minor
CENTRAL SERVICE & SUPPLY INC
IAPLK0001915300208
4219 E 50TH ST
DES MOINES
IA
80% Synthetic Minor
CENTURY TRUCK & BODY
IAPLK0001915303261
4554 NE 22ND ST
DES MOINES
IA
80% Synthetic Minor
CENTURYLINK
IAPLK0001915300997
4550 CARLISLE ROAD
DES MOINES
IA
80% Synthetic Minor
CENTURYLINK
IAPLK0001915300775
101 SE 7TH ST
DES MOINES
IA
80% Synthetic Minor
CENTURYLINK
IAPLK0001915302664
2103 E UNIVERSITY
DES MOINES
IA
80% Synthetic Minor
CENTURYLINK
IAPLK0001915302665
925 HIGH ST
DES MOINES
IA
80% Synthetic Minor
CENTURYLINK
IAPLK0001915302663
6008 SW 9TH ST
DES MOINES
IA
80% Synthetic Minor
CENTURYLINK
IAPLK0001915302667
3841 70TH ST
URBAN DALE
IA
80% Synthetic Minor
CENTURYLINK
IAPLK0001915302668
1051 35TH ST
WEST DES MOINES
IA
80% Synthetic Minor
CHAM NESS TECHNOLOGY INC
IAPLK0001915302128
PORTABLE
DES MOINES
IA
80% Synthetic Minor
CHARLES GABUS FORD
IAPLK0001915304023
4410 MERLE HAR RD
URBAN DALE
IA
80% Synthetic Minor
CHARLES GABUS FORD INC
IAPLK0001915303371
4545 MERLE HAY ROAD
DES MOINES
IA
80% Synthetic Minor
-------
AIRName
SoureelD
AIRStreet
AIRCity
AIRState
Al RCmsCategoryDesc
CHEMORSELTD
IAPLK0001915300163
1650 NE 58TH AVE
DES MOINES
IA
80% Synthetic Minor
CHESTNUT SIGN CO INC
IAPLK0001915303238
971 NE BROADWAY
DES MOINES
IA
80% Synthetic Minor
CITY OF WEST DES MOINES PUBLIC SERVICES
IAPLK0001915303066
227 63RDST.
DES MOINES
IA
80% Synthetic Minor
CLARK LI FT OF DES MOINES INC
IAPLK0001915303245
1625 E EUCLID AVE
DES MOINES
IA
80% Synthetic Minor
COGNIZANT
IAPLK0001915303162
666 GRAND AVE
DES MOINES
IA
80% Synthetic Minor
COLOR KING
IAPLK0001915303626
2910 E 9TH ST
DES MOINES
IA
80% Synthetic Minor
CONTINENTAL CEMENT
IAPLK0001915302238
275 S 11TH ST
WEST DES MOINES
IA
80% Synthetic Minor
COOPER WOODWORKING
IAPLK0001915303085
302 SE 2ND ST
GRIMES
IA
80% Synthetic Minor
CORN STATES METAL FABRICATORS INC
IAPLK0001915300143
1323 MAPLE ST
WEST DES MOINES
IA
80% Synthetic Minor
CORRELL RECYCLING
IAPLK0001915300139
1300 LINCOLN ST
WEST DES MOINES
IA
80% Synthetic Minor
COUNTRY CABOOSE REFINISHING
IAPLK0001915303262
113 5TH STREET
WEST DES MOINES
IA
80% Synthetic Minor
CREATIVE WERKSINC
IAPLK0001915303119
1430 E FLEMING AVE
DES MOINES
IA
80% Synthetic Minor
CREATIVISON, INC. DBA PERFORMANCE DISPLAY
& MILL WORK
IAPLK0001915300320
1400 SE 11TH ST
GRIMES
IA
80% Synthetic Minor
CROWN CLEANERS INC
IAPLK0001915304401
5018 EP TRUE PARKWAY
WEST DES MOINES
IA
80% Synthetic Minor
CRYSTAL KLEAR BODY SHOP
IAPLK0001915303470
65 NW 46TH AVE
DES MOINES
IA
80% Synthetic Minor
CUSTOM CABINETS OF IOWA INC
IAPLK0001915303235
2006 SE HULSIZER
ANKENY
IA
80% Synthetic Minor
CUSTOM CONVEYOR & EQUIMENT CORP
IAPLK0001915300217
109 1ST ST
POLK CITY (HISTORICAL)
IA
80% Synthetic Minor
CUSTOM FINISH AUTO BODY
IAPLK0001915303282
550 NE 46TH AVE
DES MOINES
IA
80% Synthetic Minor
CUSTOM FIRESCREEN INC
IAPLK0001915303285
108 JEFFERSON AVE
DES MOINES
IA
80% Synthetic Minor
D& J PLATING INC
IAPLK0001915300183
206 SE MAGAZINE RD
ANKENY
IA
80% Synthetic Minor
DALI INC
IAPLK0001915304700
779 N HICKORY BLVD
PLEASANT HILL
IA
80% Synthetic Minor
DEE ZEE
IAPLK0001915303290
1572 NE 58 AVE
DES MOINES
IA
80% Synthetic Minor
DEERFIELD RETIREMENT COMMUNITY
IAPLK0001915302362
13731 HICKMAN RD
URBAN DALE
IA
80% Synthetic Minor
DELAVAN INC
IAPLK0001915300170
2200 DELAVAN DRIVE
WEST DES MOINES
IA
80% Synthetic Minor
DELAVAN, INC.
IAPLK0001915300171
811 4TH ST
WEST DES MOINES
IA
80% Synthetic Minor
DENT ELIMINATORS
IAPLK0001915303378
5913 MEREDITH DRIVE
URBAN DALE
IA
80% Synthetic Minor
DENT ELIMINATORS INC
IAPLK0001915303380
2121114TH ST
CLIVE
IA
80% Synthetic Minor
DES MOINES AREA COMMUNITY COLLEGE
IAPLK0001915302016
2006 S ANKENY BOULEVARD
ANKENY
IA
80% Synthetic Minor
DES MOINES AREA REGIONAL TRANSIT AUTH
IAPLK0001915300144
1100 DART WAY
DES MOINES
IA
80% Synthetic Minor
DES MOINES DIESEL INC
IAPLK0001915303291
3211 DELAWARE AVE
DES MOINES
IA
80% Synthetic Minor
DES MOINES FEED COMPANY
IAPLK0001915300185
2010 & 2015 HUBBELL AVE
DES MOINES
IA
80% Synthetic Minor
DES MOINES INTERNATIONAL AIRPORT
IAPLK0001915302190
5800 FLEUR DR
DES MOINES
IA
80% Synthetic Minor
DES MOINES PUBLIC SCHOOLS - CENTRAL
IAPLK0001915301040
1800 GRAND AVE
DES MOINES
IA
80% Synthetic Minor
DES MOINES PUBLIC SCHOOLS - OPERATIONS
IAPLK0001915302176
1917 DEAN AVE
DES MOINES
IA
80% Synthetic Minor
DES MOINES RADIO GROUP
IAPLK0001915302428
1200 NE 126TH ST.
ALLEMAN
IA
80% Synthetic Minor
DES MOINES UNIVERSITY
IAPLK0001915301005
3200 GRAND AVE
DES MOINES
IA
80% Synthetic Minor
DES MOINES WATER WORKS
IAPLK0001915302248
12223 MAFFITT LAKE RD
DES MOINES
IA
80% Synthetic Minor
DES MOINES WATER WORKS
IAPLK0001915302249
6500 NW 26TH ST
DES MOINES
IA
80% Synthetic Minor
DES MOINES WATER WORKS
IAPLK0001915301039
5470 WILLOW CREEK AVE
WEST DES MOINES
IA
80% Synthetic Minor
DES MOINES WATER WORKS
IAPLK0001915302247
408 FLEUR DR
DES MOINES
IA
80% Synthetic Minor
DES MOINES, CITY OF
IAPLK0001915302975
1313 SE 1SR ST
DES MOINES
IA
80% Synthetic Minor
DES MOINES, CITY OF
IAPLK0001915302973
1413 SE 4TH ST
DES MOINES
IA
80% Synthetic Minor
DES MOINES, CITY OF
IAPLK0001915300266
1813 2ND AVE
DES MOINES
IA
80% Synthetic Minor
DES MOINES, CITY OF
IAPLK0001915303241
212 SE RACCOON ST
DES MOINES
IA
80% Synthetic Minor
DES MOINES, CITY OF
IAPLK0001915302971
210 SE 1ST ST
DES MOINES
IA
80% Synthetic Minor
DES MOINES, CITY OF
IAPLK0001915300859
1609 SE 9TH ST
IOWA
IA
80% Synthetic Minor
DEWEY COLLISION CENTER
IAPLK0001915302939
3225 SE DELAWARE AVE.
ANKENY
IA
80% Synthetic Minor
DEWEY FORD INC
IAPLK0001915303315
3055 SE DELAWARE AVE
ANKENY
IA
80% Synthetic Minor
DIAMOND ANIMAL HEALTH
IAPLK0001915300205
2538 SE 43RD ST
PLEASANT HILL
IA
80% Synthetic Minor
DIAMOND OIL COMPANY
IAPLK0001915305080
310 SE 7TH ST
DES MOINES
IA
80% Synthetic Minor
DICO INC
IAPLK0001915300210
200 SW 16TH ST
DES MOINES
IA
80% Synthetic Minor
DON IS AUTO BODY SHOP
IAPLK0001915303950
5701 NW 2ND AVE
DES MOINES
IA
80% Synthetic Minor
DRAKE UNIVERSITY
IAPLK0001915302304
2817 FOREST AVE
DES MOINES
IA
80% Synthetic Minor
DYNAMIC AUTO DETAILING, LLC. DBA AUTO
ARTISTS
IAPLK0001915302387
6055 AURORA AVE
URBAN DALE
IA
80% Synthetic Minor
EAGLE SIGN CO
IAPLK0001915303329
605 SW 37TH ST.
DES MOINES
IA
80% Synthetic Minor
EDGE BUSINESS CONTINUITY CENTER LLC
IAPLK0001915300227
1435 NORTH RIDGE CIRCLE NE
ALTOONA
IA
80% Synthetic Minor
ELECTRICAL ENGINEERING & EQUIPMENT CO
IAPLK0001915300218
1808 DELAWARE
DES MOINES
IA
80% Synthetic Minor
ELECTRICAL POWER PRODUCTS
IAPLK0001915303098
4240 ARMY POST RD
DES MOINES
IA
80% Synthetic Minor
EMPLOYERS MUTUAL CASUALTY CO
IAPLK0001915302361
700 & 717 MULBERRY 700 WALNUT
DES MOINES
IA
80% Synthetic Minor
EUROFINS SCIENTIFIC INC
IAPLK0001915300206
2200 RITTENHOUSE ST STE 175
DES MOINES
IA
80% Synthetic Minor
EXTREME AUTO BODY
IAPLK0001915302386
655 NE BROADWAY
DES MOINES
IA
80% Synthetic Minor
FAUST BODY SHOP INC
IAPLK0001915303350
1824 2ND AVENUE
DES MOINES
IA
80% Synthetic Minor
FERRELLGAS
IAPLK0001915300248
4415 NE 14TH ST
DES MOINES
IA
80% Synthetic Minor
FINASTRA
IAPLK0001915302420
13300 HICKMAN ROAD STE 100
CLIVE
IA
80% Synthetic Minor
2020 Polk County Program Review: Attachment E
2
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AIRName
SoureelD
AIRStreet
AIRCity
AIRState
Al RCmsCategoryDesc
FINE LINE WOODWORKS INC
IAPLK0001915303355
1008 2ND ST NE
BONDURANT
IA
80% Synthetic Minor
FINISHLINE BODY & PAINT INC
IAPLK0001915303367
1001 N MAIN STREET SUITE D
GRIMES
IA
80% Synthetic Minor
FISHER BODY PAINT INC
IAPLK0001915303364
1955 E HUBBELL
DES MOINES
IA
80% Synthetic Minor
FOOD BANK OF IOWA
IAPLK0001915302443
2220 E. 17TH ST.
DES MOINES
IA
80% Synthetic Minor
FORTERRA
IAPLK0001915300161
2825 MAURY STREET
DES MOINES
IA
80% Synthetic Minor
FURNITURE PROFESSIONALS,THE
IAPLK0001915303332
5346 MERLE HAY RD
URBAN DALE
IA
80% Synthetic Minor
GABUS AUTOMOTIVE
IAPLK0001915300860
4475 MERLE HAY RD
DES MOINES
IA
80% Synthetic Minor
GATROF DES MOINES
IAPLK0001915303670
1517 EAST AURORA
DES MOINES
IA
80% Synthetic Minor
GENERAL MILLS OPERATIONS INC
IAPLK0001915300280
6101 SE 52ND ST
CARLISLE
IA
80% Synthetic Minor
GRACE LABEL INC
IAPLK0001915300296
6201 WATROUSAVE
DES MOINES
IA
80% Synthetic Minor
GRAHAM BODY SHOP
IAPLK0001915303805
4730 MERLE HAY RD
DES MOINES
IA
80% Synthetic Minor
GRAHAM COLLISION CENTER
IAPLK0001915303170
10168 HICKMAN COURT
CLIVE
IA
80% Synthetic Minor
GRAHAM GROUP
IAPLK0001915303460
6812 SE DELAWARE AVE
ANKENY
IA
80% Synthetic Minor
GRIMES ASPHALT & PAVING
IAPLK0001915300268
2118 NE 51ST PL
DES MOINES
IA
80% Synthetic Minor
GRIMES, CITY OF
IAPLK0001915302104
1801 N JAMES ST
GRIMES
IA
80% Synthetic Minor
GUIDEONE INSURANCE
IAPLK0001915302930
1025 & 1111 ASH WORTH RD
WEST DES MOINES
IA
80% Synthetic Minor
HALL'S AUTO BODY
IAPLK0001915303400
4995 NW 6TH DR
DES MOINES
IA
80% Synthetic Minor
HALLETT MATERIALS
IAPLK0001915300304
1300 SE 36TH ST
DES MOINES
IA
80% Synthetic Minor
HALLETT MATERIALS
IAPLK0001915300298
PORTABLE
POLK COUNTY
IA
80% Synthetic Minor
HANSSEN'S COMMERCIAL LAUNDRY SERVICE
IAPLK0001915304506
2545 1/2 E EUCLID
DES MOINES
IA
80% Synthetic Minor
HARVEY PALLETS, INC
IAPLK0001915300037
2420 GRAND AVE
WEST DES MOINES
IA
80% Synthetic Minor
HAWK METAL PRODUCTS INC
IAPLK0001915303420
625 S 19TH ST
WEST DES MOINES
IA
80% Synthetic Minor
HEARTLAND COOP
IAPLK0001915300219
4300 NE 94TH AVE
ELKHART
IA
80% Synthetic Minor
HEARTLAND COOP
IAPLK0001915300234
118 SE 18TH ST
DES MOINES
IA
80% Synthetic Minor
HEARTLAND COOP
IAPLK0001915300231
204 E HANCOCK ST
RUNNELLS
IA
80% Synthetic Minor
HEARTLAND COOP
IAPLK0001915300235
5550 E 64TH ST
CARLISLE
IA
80% Synthetic Minor
HELENA AGRl-ENTERPRISES, LLC
IAPLK0001915302385
4546 CORPORATE DR STE 170
WEST DES MOINES
IA
80% Synthetic Minor
HELENA INDUSTRIES, LLC
IAPLK0001915300310
3525 VAN DALIA ROAD
DES MOINES
IA
80% Synthetic Minor
HOLMES RADIATOR, LLC
IAPLK0001915303422
1616 NE BROADWAY
DES MOINES
IA
80% Synthetic Minor
HOLT SALES AND SERVICE LLC
IAPLK0001915302934
2345 DEAN AVE
DES MOINES
IA
80% Synthetic Minor
HOWARD MARTIN AUTO BODY
IAPLK0001915303560
3700 SW 61ST ST
DES MOINES
IA
80% Synthetic Minor
HUSSMANN SERVICES CORP
IAPLK0001915303823
4360 112TH ST
URBAN DALE
IA
80% Synthetic Minor
HY-VEE PHARMACY FULFILLMENT CENTER 4016
IAPLK0001915303681
4707 FLEUR DR.
DES MOINES
IA
80% Synthetic Minor
HYDRO-KLEAN LLC
IAPLK0001915300323
333 NW 49TH PL
DES MOINES
IA
80% Synthetic Minor
HYKES FURNITURE SERVICES
IAPLK0001915303294
218 SW MAPLE STREET
ANKENY
IA
80% Synthetic Minor
IFBF PROPERTY MANAGEMENT INC
IAPLK0001915302635
5400 UNIVERSITY AVE
WEST DES MOINES
IA
80% Synthetic Minor
INCOTEC INNOVATION CENTER
IAPLK0001915301048
4725 121ST STREET
URBAN DALE
IA
80% Synthetic Minor
INLAND TRUCK PARTS & SERVICE
IAPLK0001915303447
5678 NE 14TH ST
DES MOINES
IA
80% Synthetic Minor
INROADS, LLC
IAPLK0001915302286
1409 NW LAUREL AVE.
ELKHART
IA
80% Synthetic Minor
IOWA AIR GUARD
IAPLK0001915302136
3100 MCKINLEY AVENUE
DES MOINES
IA
80% Synthetic Minor
IOWA ARMY NATIONAL GUARD
IAPLK0001915302137
7105 NW 70TH AVENUE
JOHNSTON
IA
80% Synthetic Minor
IOWA EVENTS CENTER
IAPLK0001915300481
730 3RD ST
DES MOINES
IA
80% Synthetic Minor
IOWA LAW EN FORCE ME NT ACADEMY
IAPLK0001915302144
7105 NW 70TH AVE
JOHNSTON
IA
80% Synthetic Minor
IOWA METHODIST MEDICAL CENTER
IAPLK0001915300421
1200 PLEASANT STREET
DES MOINES
IA
80% Synthetic Minor
IOWA NETWORK SERVICES
IAPLK0001915302180
312 8TH ST
DES MOINES
IA
80% Synthetic Minor
ITS INC
IAPLK0001915302146
6700 PIONEER PARKWAY
JOHNSTON
IA
80% Synthetic Minor
J & M COLLISION CENTERS
IAPLK0001915302308
2100 SE GATEWAY DR., STE. 100
GRIMES
IA
80% Synthetic Minor
J &S BODY SHOP
IAPLK0001915303455
2328 HUBBELL
DES MOINES
IA
80% Synthetic Minor
J. PETTICORD, INC.
IAPLK0001915300071
1200 PRAIRIE DRIVE SW
BONDURANT
IA
80% Synthetic Minor
J. PETTI ECO RD, INC.
IAPLK0001915300073
1200 PRAIRIE DR. SW
BONDURANT
IA
80% Synthetic Minor
JACOBSENAUTO BODY
IAPLK0001915303459
1916 FULLER ROAD
WEST DES MOINES
IA
80% Synthetic Minor
JCTOLAND PAINTING
IAPLK0001915303473
395 NW 43RD PL
DES MOINES
IA
80% Synthetic Minor
JONES LANG LASALLE
IAPLK0001915300778
4741121ST ST
URBAN DALE
IA
80% Synthetic Minor
KARL CHEVROLET INC
IAPLK0001915303483
1101 SE ORALABOR ROAD
ANKENY
IA
80% Synthetic Minor
KCCI DES MOINES HEARST TELEVISION INC
IAPLK0001915302158
888 9TH ST
DES MOINES
IA
80% Synthetic Minor
KELDERMAN LIME
IAPLK0001915300396
3400 SE GRANGER
DES MOINES
IA
80% Synthetic Minor
KEMIN INDUSTRIES INC
IAPLK0001915300394
2100 MAURY ST
DES MOINES
IA
80% Synthetic Minor
KENT NUTRITION GROUP - ALTOONA
IAPLK0001915300395
203 1ST AVENUE N
ALTOONA
IA
80% Synthetic Minor
KEYSTONE ELECTRICAL MAUFACTURING CO
IAPLK0001915303490
2511 BELL AVE
DES MOINES
IA
80% Synthetic Minor
KNAPP PROPERTIES
IAPLK0001915302921
1776 WEST LAKES PKWY
WEST DES MOINES
IA
80% Synthetic Minor
KRAUSE HOLINGS, INC.
IAPLK0001915303106
1459 GRAND AVE
DES MOINES
IA
80% Synthetic Minor
L & K HOLDINGS
IAPLK0001915300826
2123 NE 46TH AVE
DES MOINES
IA
80% Synthetic Minor
LACK'S BODY & PAINT CENTER
IAPLK0001915303493
1300 N SHADYVIEW BLVD
PLEASANT HILL
IA
80% Synthetic Minor
LANDUS
IAPLK0001915300225
102 FIRST AVENUE N
ALTOONA
IA
80% Synthetic Minor
LANDUS
IAPLK0001915300230
102 LINCOLN STREET NE
BONDURANT
IA
80% Synthetic Minor
2020 Polk County Program Review: Attachment E
3
-------
AIRName
SoureelD
AIRStreet
AIRCity
AIRState
Al RCmsCategoryDesc
LANDUS COOPERATIVE
IAPLK0001915300158
1700 PLEASANT HILL BLVD
PLEASANT HILL
IA
80% Synthetic Minor
LARSEN'S SOUTH SIDE AUTO BODY
IAPLK0001915303497
2516 GEORGE FLAGG PARKWAY
DES MOINES
IA
80% Synthetic Minor
LEMAR INDUSTRIES CORP
IAPLK0001915303491
2070 NE 60TH AVE
DES MOINES
IA
80% Synthetic Minor
LEYDENS AUTOMOTIVE
IAPLK0001915304747
5211 NE 17TH ST
DES MOINES
IA
80% Synthetic Minor
LISTER INDUSTRIES
IAPLK0001915300404
300 NW 48TH PLACE
DES MOINES
IA
80% Synthetic Minor
LITHIA BODY & PAINT OF DES MOINES
IAPLK0001915303022
9943 HICKMAN RD
URBANDALE
IA
80% Synthetic Minor
LOPEZ AUTO & REPAIR, INC. DBA CENTRAL
AUTO & REPAIR, INC
IAPLK001915302251
125 NE 47TH PL.
DES MOINES
IA
80% Synthetic Minor
MANATTS
IAPLK0001915302199
PORTABLE
BONDURANT
IA
80% Synthetic Minor
MANATTS INC
IAPLK0001915300458
PORTABLE CRUSHER
ANKENY
IA
80% Synthetic Minor
MANATTS INC
IAPLK0001915300372
PORTABLE
ANKENY
IA
80% Synthetic Minor
MARTIN MARIETTA MATERIALS INC
IAPLK0001915303565
1591 NW 54TH AVE
DES MOINES
IA
80% Synthetic Minor
MARZETTI FROZEN PASTA
IAPLK0001915300995
803 8TH ST
ALTOONA
IA
80% Synthetic Minor
MAXIM TRUCKING & MATERIALS
IAPLK0001915303171
1601 FIFIELD DR.
DES MOINES
IA
80% Synthetic Minor
MAXWELL NEEDHAM COLLISION CENTER
IAPLK0001915303609
2440 EASTON BLVD
DES MOINES
IA
80% Synthetic Minor
MCCALLAY MECHANICS, INC
IAPLK0001915302223
5264 NE 14TH ST.
DES MOINES
IA
80% Synthetic Minor
MCCONNELL AUTO BODY INC
IAPLK0001915303509
113 MILL STREET SW
MITCHELLVILLE
IA
80% Synthetic Minor
MCFARLIN BODY SHOP
IAPLK0001915303511
2729 DELAWARE
DES MOINES
IA
80% Synthetic Minor
MDM EQUITY 2010, LLC
IAPLK0001915302147
6109 WILLOWMERE DRIVE
DES MOINES
IA
80% Synthetic Minor
MERCY MEDICAL CENTER
IAPLK0001915301018
1111 6TH AVE
DES MOINES
IA
80% Synthetic Minor
MERCY MEDICAL CENTER WEST LAKES
IAPLK0001915301020
1755 59TH PL
WEST DES MOINES
IA
80% Synthetic Minor
MEREDITH CORPORATION
IAPLK0001915302589
1716 LOCUST ST
DES MOINES
IA
80% Synthetic Minor
MICROSOFT CORP
IAPLK0001915302086
550 WHITE CRANE RD
DES MOINES
IA
80% Synthetic Minor
MID-IOWA SOLID WASTE EQUIP CO INC
IAPLK0001915303570
5105 NW BEAVER DR
JOHNSTON
IA
80% Synthetic Minor
MIDAMERICAN
IAPLK0001915302164
4299 NW URBANDALE DR
URBANDALE
IA
80% Synthetic Minor
MIDAMERICAN
IAPLK0001915302165
3500 104TH ST
URBANDALE
IA
80% Synthetic Minor
MIDAMERICAN
IAPLK0001915300379
3500 104TH ST
URBANDALE
IA
80% Synthetic Minor
MIDAMERICAN
IAPLK0001915302621
2291 STATE ST
DES MOINES
IA
80% Synthetic Minor
MLK RIVERPARK
IAPLK0001915300996
405 SW 5TH ST
DES MOINES
IA
80% Synthetic Minor
MTSIOWA, INC.
IAPLK0001915303546
503 1ST AVENUE NORTH
ALTOONA
IA
80% Synthetic Minor
MURRAY MOTORS
IAPLK0001915303585
2602 NE BROADWAY
DES MOINES
IA
80% Synthetic Minor
NATIONAL CARWASH SOLUTIONS
IAPLK0001915300508
1500 SE 37TH ST
GRIMES
IA
80% Synthetic Minor
NATIONWIDE INSURANCE
IAPLK0001915302031
1200 LOCUST ST
DES MOINES
IA
80% Synthetic Minor
NATIONWIDE INSURANCE
IAPLK0001915302034
204 12TH ST
DES MOINES
IA
80% Synthetic Minor
NATIONWIDE INSURANCE
IAPLK0001915302004
1100 WALNUT ST
DES MOINES
IA
80% Synthetic Minor
NCMIC GROUP INC
IAPLK0001915300440
14001 UNIVERSITY
CLIVE
IA
80% Synthetic Minor
NOAH'S CLEANERS INC
IAPLK0001915303625
6115SW9TH ST
DES MOINES
IA
80% Synthetic Minor
NORTH DES MOINES TRUCK AND AUTO BODY
LLC
IAPLK0001915303359
5329 NW 2ND ST
DES MOINES
IA
80% Synthetic Minor
NORTH SIDE AUTO BODY
IAPLK0001915303363
4230 NW 2ND ST
DES MOINES
IA
80% Synthetic Minor
NORTH STAR POWER, LLC
IAPLK0001915302225
7301 SE NORTH STAR DR.
ANKENY
IA
80% Synthetic Minor
O'HALLORAN INTERNATIONAL
IAPLK0001915303628
3311 ADVENTURE LAND
ALTOONA
IA
80% Synthetic Minor
O'MARA AG SERVICES INC
IAPLK0001915303709
1626 DELAWARE AVENUE
DES MOINES
IA
80% Synthetic Minor
OCHO-70
IAPLK0001915303010
25 NW BROADWAY
DES MOINES
IA
80% Synthetic Minor
OLD DOMINION FREIGHT LINE, INC.
IAPLK0001915302305
6925 SE FOURMILE DR.
ANKENY
IA
80% Synthetic Minor
OMG MIDWEST INC
IAPLK0001915302937
5109 NW BEAVER DR.
JOHNSTON
IA
80% Synthetic Minor
ONEOK NORTH SYSTEM LLC
IAPLK0001915300330
4401 VAN DALIA ROAD
PLEASANT HILL
IA
80% Synthetic Minor
PAUL'S PAINT & BODY CO INC
IAPLK0001915303637
4328 NE HUBBELL
DES MOINES
IA
80% Synthetic Minor
PERISHABLE DISTRIBUTORS OF IOWA INC
IAPLK0001915302010
2741 SE PDI DR
ANKENY
IA
80% Synthetic Minor
PETERSON CONTRACTORS INC
IAPLK0001915300472
PORTABLE
DES MOINES
IA
80% Synthetic Minor
PETERSON CONTRACTORS INC
IAPLK0001915300447
PORTABLE
DES MOINES
IA
80% Synthetic Minor
PETERSON CONTRACTORS INC.
IAPLK0001915300801
1-80 & HYWY 65
ALTOONA
IA
80% Synthetic Minor
PHILLIPS 66 COMPANY
IAPLK0001915302860
4500 VAN DALI A RD
PLEASANT HILL
IA
80% Synthetic Minor
PIONEER
IAPLK0001915300482
7000 NW 62ND AVE
JOHNSTON
IA
80% Synthetic Minor
PIONEER
IAPLK0001915303651
6501 NW BEAVER
JOHNSTON
IA
80% Synthetic Minor
PLEASANT HILL AUTO BODY INC
IAPLK0001915303656
5245 E UNIVERSITY
PLEASANT HILL
IA
80% Synthetic Minor
POLK COUNTY GENERAL SERVICES
IAPLK0001915300486
111 COURT AVE
DES MOINES
IA
80% Synthetic Minor
POLK COUNTY GENERAL SERVICES
IAPLK0001915300524
2309 EUCLID AVE
DES MOINES
IA
80% Synthetic Minor
POLK COUNTY GENERAL SERVICES
IAPLK0001915303561
70 COLLEGE
DES MOINES
IA
80% Synthetic Minor
POLK COUNTY SHERIFF'S OFFICE - JAIL
IAPLK0001915300484
1985 NE 51ST PL
DES MOINES
IA
80% Synthetic Minor
PPG INDUSTRIES
IAPLK0001915300371
4525 NE 14TH ST
DES MOINES
IA
80% Synthetic Minor
PRAIRIE MEADOWS RACE TRACK AND CASINO
IAPLK0001915302631
1 PRAIRIE MEADOWS DRIVE
ALTOONA
IA
80% Synthetic Minor
PRECISION BODY & METAL SHAPING
IAPLK0001915303665
225 NE 47TH PL
DES MOINES
IA
80% Synthetic Minor
PRINCIPAL
IAPLK0001915302073
12000 MEREDITH DR
URBANDALE
IA
80% Synthetic Minor
PRINCIPAL LIFE INSURANCE
IAPLK0001915302727
6701 CORPORATE DR
JOHNSTON
IA
80% Synthetic Minor
PYRO GRAPHICS
IAPLK0001915300770
132 S 11TH ST
WEST DES MOINES
IA
80% Synthetic Minor
2020 Polk County Program Review: Attachment E
4
-------
AIRName
SoureelD
AIRStreet
AIRCity
AIRState
Al RCmsCategoryDesc
QUALITY CLEANERS
IAPLK0001915304049
109 8TH ST SW
ALTOONA
IA
80% Synthetic Minor
QUICK STEEL FABRICATION INC
IAPLK0001915303690
5360 MERLE HAY RD
DES MOINES
IA
80% Synthetic Minor
R & R REALTY
IAPLK0001915302184
4700 WESTOWN PARKWAY
WEST DES MOINES
IA
80% Synthetic Minor
R JONES COLLISION SPECIALISTS
IAPLK0001915303686
4416 MERLE HAY ROAD
DES MOINES
IA
80% Synthetic Minor
RAMSEY COLLISION CENTER
IAPLK0001915303700
9625 HICKMAN RD
URBANDALE
IA
80% Synthetic Minor
RCS MILL WORK INC
IAPLK0001915300494
1554 NE 69TH PL
ANKENY
IA
80% Synthetic Minor
REG MARKETING AND LOGISTICS, DBA, KECK
ENERGY
IAPLK0001915306001
1434 OHIO ST.
DES MOINES
IA
80% Synthetic Minor
REXCO EQUIPMENT INC
IAPLK0001915303704
5900 SW 56TH ST
DES MOINES
IA
80% Synthetic Minor
RITE WAY
IAPLK0001915303707
718 E BROADWAY
DES MOINES
IA
80% Synthetic Minor
ROLLMASTER, INC
IAPLK0001915303440
2041 E. WALNUT ST.
DES MOINES
IA
80% Synthetic Minor
RUSTER SPORTS, LLC
IAPLK0001915304026
600 SW 7TH ST.
DES MOINES
IA
80% Synthetic Minor
RYAN COMPANIES
IAPLK0001915300321
6400 NW 86TH ST
JOHNSTON
IA
80% Synthetic Minor
SALVADOR BENETEZ BODY SHOP
IAPLK0001915303161
575 NE 48TH PL
DES MOINES
IA
80% Synthetic Minor
SAM'S WEST DBA SAM'S CLUB #6979
IAPLK0001915305166
4615 SE DELAWARE AVE
ANKENY
IA
80% Synthetic Minor
SAMMON'S FINANCIAL GROUP
IAPLK0001915302644
4350 WESTOWN PKWY
WEST DES MOINES
IA
80% Synthetic Minor
SCHLARBAUM AUTO BODY
IAPLK0001915303729
2215 SUNSET RD
DES MOINES
IA
80% Synthetic Minor
SCHMIDT ENT. DBA MAACO PAINT& BODY
WORKS
IAPLK0001915303525
1998 NW 92NDCT
CLIVE
IA
80% Synthetic Minor
SCOTTY'S BODY SHOP
IAPLK0001915303744
504 SE 6TH ST.
DES MOINES
IA
80% Synthetic Minor
SCOTTY'S BODY SHOP INC
IAPLK0001915303526
59 UNIVERSITY
DES MOINES
IA
80% Synthetic Minor
SEM INTERPRISES, LLC
IAPLK0001915302451
5304 SE 14TH ST.
DES MOINES
IA
80% Synthetic Minor
SKEFFINGTON'S FORMAL WEAR
IAPLK0001915304760
2453 SW 9TH ST
DES MOINES
IA
80% Synthetic Minor
SMITH'S COLLISION AND PAINT
IAPLK0001915303777
1407 SW ORDNANCE ROAD
ANKENY
IA
80% Synthetic Minor
SNYDER CUSTOM AUTO
IAPLK0001915303786
1529 E MADISON
DES MOINES
IA
80% Synthetic Minor
SPECIALTY ENTERPRISES
IAPLK0001915303767
245 NW 52ND AVE
DES MOINES
IA
80% Synthetic Minor
STATE OF IOWA ADM IN SERVICES
IAPLK0001915300810
150 DES MOINES STREET
DES MOINES
IA
80% Synthetic Minor
STATE OF IOWA DAS
IAPLK0001915302235
109 SE 13TH ST
DES MOINES
IA
80% Synthetic Minor
STEW HANSEN DODGE
IAPLK0001915303412
12103 HICKMAN ROAD
URBANDALE
IA
80% Synthetic Minor
STEW HANSEN HYUNDAI COLLISION CENTER
IAPLK0001915303441
2094 114TH ST
CLIVE
IA
80% Synthetic Minor
SUMMIT PRODUCTS
IAPLK0001915303201
6750 NE41ST AVE
ALTOONA
IA
80% Synthetic Minor
SUPERIOR AUTO SALES LLC
IAPLK0001915303810
835 RAILROAD
WEST DES MOINES
IA
80% Synthetic Minor
SYSCO FOOD SERVICES
IAPLK0001915300921
1 SYSCO PLACE
ANKENY
IA
80% Synthetic Minor
TED'S BODY SHOP INC
IAPLK0001915303826
5571 NW 2ND ST
DES MOINES
IA
80% Synthetic Minor
TILLEY CUSTOM RESTORATION, LLC
IAPLK0001915300211
690 NE 91ST ST
RUNNELLS
IA
80% Synthetic Minor
TONG PLAZA CLEANERS
IAPLK0001915304735
3816 70TH
URBANDALE
IA
80% Synthetic Minor
TONY MORO COLLISION CENTER INC
IAPLK0001915303588
2321 2ND AVE
DES MOINES
IA
80% Synthetic Minor
UNITED CONTRACTORS INC
IAPLK0001915300981
3101 SW BROOKSIDE DR
GRIMES
IA
80% Synthetic Minor
UNITED FLEET TWO
IAPLK0001915303480
1500 NE 56TH ST
PLEASANT HILL
IA
80% Synthetic Minor
UNITY POINT IOWA LUTHERAN HOSPITAL
IAPLK0001915301012
700 E UNIVERSITY AVE
DES MOINES
IA
80% Synthetic Minor
URBANDALE AUTO BODY SERVICE
IAPLK0001915303875
3833 70TH STREET
URBANDALE
IA
80% Synthetic Minor
US POSTAL SERVICE
IAPLK0001915302241
1145 2ND AVE
DES MOINES
IA
80% Synthetic Minor
USCOC OF GREATER IOWA LLC
IAPLK0001915302653
5404 NW 96TH ST
JOHNSTON
IA
80% Synthetic Minor
VA CENTRAL IA HEALTH CARE SYSTEMS
IAPLK0001915301033
3600 30 STREET
DES MOINES
IA
80% Synthetic Minor
VALLEY VIEW VILLAGE
IAPLK0001915301016
2571 GUTHRIE AVENUE
DES MOINES
IA
80% Synthetic Minor
VERIZON BUSINESS
IAPLK0001915302900
4500 A CARLISLE RD
PLEASANT HILL
IA
80% Synthetic Minor
VICTORIA CLEANERS
IAPLK0001915304877
2164 NW 108TH
CLIVE
IA
80% Synthetic Minor
WALDINGER CORP, THE
IAPLK0001915300565
2601 BELL AVENUE
DES MOINES
IA
80% Synthetic Minor
WASTE CONNECTIONS OF IOWA INC
IAPLK0001915303092
4705 NE 22 STREET
DES MOINES
IA
80% Synthetic Minor
WASTE MANAGEMENT OF IOWA
IAPLK0001915300850
201 SE 18TH ST
DES MOINES
IA
80% Synthetic Minor
WATZY'S AUTO SALES, LLC
IAPLK0001915303110
705 SE 14TH ST
DES MOINES
IA
80% Synthetic Minor
WELLMARK BLUE CROSS & BLUE SHIELD
IAPLK0001915302098
1331 GRAND AVE
DES MOINES
IA
80% Synthetic Minor
WELLS FARGO
IAPLK0001915300998
801 WALNUT STREET
DES MOINES
IA
80% Synthetic Minor
WELLS FARGO
IAPLK0001915300982
206 8TH ST
DES MOINES
IA
80% Synthetic Minor
WELLS FARGO
IAPLK0001915302880
800 WALNUT
DES MOINES
IA
80% Synthetic Minor
WELTER AUTO BODY
IAPLK0001915303890
117 MILL STREET
MITCHELLVILLE
IA
80% Synthetic Minor
WESJARNIGAN INC
IAPLK0001915303462
6395 NW BEAVER
JOHNSTON
IA
80% Synthetic Minor
WESLEY ACRES RETIREMENT SERVICES
IAPLK0001915302863
3520 GRAND AVENUE
DES MOINES
IA
80% Synthetic Minor
WEST DES MOINES WATER WORKS
IAPLK0001915300855
1505 RAILROAD AVENUE
IOWA
IA
80% Synthetic Minor
WEST SIDE AUTO BODY INC
IAPLK0001915303893
1838 FULLER ROAD
WEST DES MOINES
IA
80% Synthetic Minor
WILLIS AUTO CAMPUS
IAPLK0001915303154
2121 NW 100TH ST
CLIVE
IA
80% Synthetic Minor
WINDSOR WINDOWS & DOORS
IAPLK0001915300581
900 S 19TH STREET
WEST DES MOINES
IA
80% Synthetic Minor
WRECKAMENDED COLLISION CENTER
IAPLK0001915303911
1500 NE 46TH AVE
DES MOINES
IA
80% Synthetic Minor
ZIEGLER INC
IAPLK0001915302113
1500 ZIEGLER DRIVE
ALTOONA
IA
80% Synthetic Minor
2020 Polk County Program Review: Attachment E
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2019 Program Review
Air Quality Division
Linn County Public Health
FINAL REPORT
Program Review Performed by:
Iowa Department of Natural Resources
Air Quality Bureau
January 2020
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SFY 2019 PROGRAM REVIEW CONTENTS
Executive Summary
I. Introduction
II. Program Management Provisions
A. Personnel
B. Fiscal Reporting
C. Contract Review
D. Information Technology
E. Legal Authority
F. Minority and Women Business Enterprise
G. Intergovernmental Cooperation
III. Construction Permitting Provisions
A. Construction Permit Activities
B. Permit/Modeling Procedures
C. PSD Permit Activities
D. PSD Pre-application
E. PSD Permit Application Review
F. PSD Permit Drafting Procedures
G. PSD Public Notice/Intent to Issue
H. Final PSD Permit Issuance
I. PSD Permit Modifications
J. Reporting Requirements
K. DNR Responsibilities
IV. Title V Permitting Provisions
A. Title V Permit Activities
B. Permit Application Review
C. Permit Drafting Procedures
D. Public Notice Intent to Issue
E. Final Permit Issuance
F. Permit Renewal
G. Re-opening Issued Title V Permits
H. Permit Changes
I. Reporting Requirements
V. Compliance and Inspection Provisions
File Review Procedures
A. Compliance
B. Stack Tests
C. Inspections
D. Variances
E. Data Management
F. Emissions Data
VI. Ambient Air Monitoring Provisions
Commendation
A. Finding/Recommendation #1
B. Finding/Recommendation #2
C. Finding/Recommendation #3
D. Finding/Recommendation #4
E. Finding/Recommendation #5
F. Finding/Recommendation #6
G. Finding/Recommendation #7
H. Finding/Recommendation #8
I. Finding/Recommendation #9
J. Finding/Recommendation #10
K. Finding/Recommendation #11
L. Finding/Recommendation #12
Attachment A:
Comments on Specific Construction Permits
Attachment B:
Summary of LINN Precision and Bias
Attachment C:
Staff Training Summary
Attachment D:
Responsiveness Summary
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Executive Summary
The Iowa Department of Natural Resources (DNR) performed a program review of the Linn County Public
Health Air Quality Section (LINN) on October 10, 2019. The review was for the period of July 1, 2018 through
June 30, 2019. The DNR used the SFY 2019 28E Contract to evaluate the program.
Executive Summary
Program Management - LINN employs sufficient personnel to perform the services of the Contract and uses a
wide variety of training options, including webinars and conference calls, to minimize the cost of obtaining
training while also increasing training opportunities for staff.
The SFY 2019 expenditure reports were submitted quarterly using the format provided by DNR. DNR
appreciates LINN's rapid responses in addressing questions regarding the submitted expenditure reports.
LINN's implementation of improved QA checks of expenditure reports and billable hours documentation has
significantly reduced the number of errors in both documents.
As part of the 2019 Contract review, LINN submitted the proposed salary and non-salary programmatic
budgets for SFY 2019 with thorough justification. DNR appreciates LINN's timely responses to DNR requests
for additional information, including budget scenarios, during the contract development process.
LINN confers with the DNR on the need, content and timing of revisions and updates to air quality ordinances.
During the SFY 2020 contract period, LINN will discuss with DNR plans to begin drafting updates to local air
quality ordinances.
LINN provided insightful comments and recommendations during a three-day requirements workshop with
the consultant for DNR's new electronic air permit application system (EASY Air). LINN's participation during
the workshop and in follow-up meetings and emails has been helpful to ensuring that LINN staff will be able to
use the system in their review and time tracking for Title V operating permit applications and PSD applications.
Construction Permitting - LINN overall produces well written permits and evaluations and provides
outstanding guidance to facilities on NESHAP compliance obligations. DNR identified just a handful of
instances of permit procedures used by LINN during this review period that either differed from the latest
version of the DNR Construction Permit Manual or current standing EPA guidance as discussed below. LINN
does not appear to be providing DNR a copy of all draft permits for NESHAP (National Emission Standards for
Hazardous Air Pollutants), NSPS (New Source Performance Standards), or PSD (Prevention of Significant
Deterioration) synthetic minor sources as required by the contract and should ensure going forward that DNR
is appraised of these project types and given the chance to review or waive review.
Title V - The quality of work performed by the LINN technical staff has been very good and there continues to
be consistency between LINN and DNR Title V operating permits. The performance criteria for LINN was to
draft for issuance or denial a minimum of four initial or renewal title V operating permits annually. Four
permits were issued during this review period. The DNR appreciates participation of LINN in development and
testing of the new EASY Air electronic permitting system and participation in the regularly scheduled Title V
section meetings.
Compliance and Inspection - LINN runs a very effective compliance program; putting emphasis on all aspects
of compliance and has done an excellent job tracking and documenting compliance at facilities, along with
effectively returning facilities to compliance when violations are discovered. LINN's response to violations is
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timely and appropriate. Inspections are thorough and well documented. Correspondence with facilities is
concise and easy to understand.
The SFY 2017 audit identified missing information and corrections needed to the Integrated Compliance
Information System (ICIS). The current audit (2019) shows LINN is now meeting all ICIS data entry
requirements.
Ambient Air Monitoring - The DNR commends LINN for doing an excellent job running their air monitoring
network. Precision and bias statistics for data collected in the most recent complete calendar year were
reviewed, and the results were excellent. LINN has also been very responsive to suggestions made in previous
audits conducted by the DNR and SHL. Since the last audit, LINN updated the Method Quality Objective tables
in their Standard Operating Procedures (SOPs) to reflect the latest (March 2017) version of EPA's Quality
Assurance handbook. Roof repair was completed on the Health Department shelter in the last part of October
of 2018. LINN also indicated that it will not be necessary to move this shelter even a short distance after
moving their offices to their new (permanent) location in November 2019.
At the end of 2018, LINN's Quality Assurance (QA) officer retired. In the next contract period (July 2020 to
June 2021) LINN is potentially facing two more retirements of staff with long standing experience. The DNR
stressed the importance of continuing to make succession plans for the new vacancies. Agreement between
LINN's Federal Equivalent Method (FEM) for PM2.5 (particles with a diameter of 2.5 micrometers or less, also
known as "fine particles") monitors versus the Federal Reference Method (FRM) was excellent in 2017, but
declined in 2018 and the first eight months of 2019. At the beginning of September 2019, LINN switched one
of their continuous PM2.5 monitors to a "T640" sampler that utilizes a newer light scattering technology. The
DNR indicated that if the new method works out well, eventual replacement of the second continuous PM2.5
monitor would leave LINN without a backup T640.
The DNR shared with LINN the results of its correspondence and discussions with EPA about which flow
(transfer standard vs. the flow measured by the monitor itself) should be compared to the design flow rate on
particulate matter (PM) samplers when the acceptance criteria is +/- 5.1%. LINN agreed to conform their SOPs
to EPA's position on this.
I. Introduction
LINN has been delegated the responsibility of implementing the State of Iowa air pollution control
implementation plan within Linn County. To assure that the implementation plan is carried out, the DNR
negotiated a 28E Contract with the LINN for the period of July 1, 2018 through June 30, 2019. The purpose of
the Contract was to control and prevent air pollution within Linn County. Particular emphasis was placed on
the collection and assessment of information regarding air quality, the permitting of sources of air emissions,
the enforcement of emission limits and the attainment and maintenance of ambient air quality standards.
The purpose of the program review is to help in the development and improvement of the air pollution
program in Linn County by providing guidance, identifying areas where more support is needed from the DNR,
and to foster a good working relationship. As a means to verify that LINN fulfilled the terms of the Contract,
the DNR staff performed an onsite program review on October 10, 2019. (Preceding the onsite review, DNR
conducted a review of electronic files including SFY 2018-2019 reports submitted by LINN, as well as
documents requested by DNR.) This review was divided into the following five categories: program
management, construction permitting, Title V permitting, compliance and inspection, and ambient air
monitoring. The DNR staff performed a comprehensive review of each category. The findings of this review are
discussed by category throughout this report.
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The program review team consisted of the following DNR staff members (by section):
• Brian Hutchins, Compliance & Ambient Air Monitoring Section Supervisor
• John Gering, Ambient Air Monitoring Unit
• Mark Fields, Compliance Unit
• Julie Duke, Compliance Unit
• Brenda Streicher, Field Office 1 (Manchester)
• Sarah Piziali, Construction Permitting Section Supervisor
• Karen Kuhn, Construction Permitting Section
• Lori Hanson, Operating Permits/Title V Section Supervisor
• Jim McGraw, Program Development Section Supervisor
• Brad Ashton, Program Development Section
• Christine Paulson, Program Development Section (unavailable for the onsite portion of the review)
Program Management Provisions
A. Personnel
Acceptable Q Corrective Action Needed Q Deficient Q Not evaluated
Comments: The SFY 2019 Contract (Section 5A.1.1) requires LINN to employ sufficient personnel to perform
the services of the Contract during the period of agreement. This section also specifies the knowledge, skills,
and abilities required for LINN personnel who perform visible emissions observations, dispersion modeling,
facility inspections, ambient monitoring, and permit reviews.
LINN is required to have at least two staff members certified in visible emission observations and at least one
staff member trained in conducting dispersion modeling. LINN had two staff members certified in visible
emission observations and one staff member trained in conducting air dispersion modeling during SFY 2019.
Additionally, LINN is training a second staff member to serve as a back-up modeler.
LINN submitted timely to DNR the quarterly program activity reports for SFY 2019, which included summaries
of staff time utilization. LINN maintains an updated list of activity codes with associated descriptions that aid
staff in appropriately allotting their time to specific activities. LINN uses queries in Time Tracker to generate
the quarterly reports. The table below summarizes staff time utilization based on the information LINN
provided in the submitted quarterly reports.
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STAFF TIME EXPENDED REPORT SFY 2019
Activity
Budgeted FTEs
(Programmatic
Budget)
Actual FTEs
(Averaged over
four quarters)
Administration & Management
0.73
1.48
Construction Permits
2.00
1.34
Minor source
Major source (includes PSD)
Title V operating permits
0.4
0.16
Ambient Air Monitoring
2.98
2.74
Compliance Inspections
1.70
1.96
Minor source
Major source
Training/Conferences
0.61
0.50
Program Development
0.5
0.30
Dispersion Modeling
0.15
0.08
Minor source
Major source (includes PSD)
TOTAL
9.07
8.56
LINN committed to operate the program with a staff level of 8.98 FTE, as specified in the staffing/personnel
requirements in Table 1 of the SFY 2019 Contract. Due to rounding inherent in the SFY 2019 Programmatic
Budget included in the Contract, however, the total budgeted FTE level is 9.07. The actual staff level for SFY
2019 (averaged over four quarters) was 8.56 FTE.
The lower actual staffing level (0.51 FTE less than budgeted) was due primarily to less than anticipated minor
source construction permitting work and Title V operating permit work, as well as slightly less than anticipated
program development activities and major source inspections. However, LINN experienced somewhat higher
than estimated staff needs for administration and management and minor source compliance inspections.
Budget projections are based on the best estimates of expenses without knowing the scope of future permit
application submittals and associated review time, as well as unanticipated compliance activities and staffing
changes.
During SFY 2019, LINN staff maintained familiarity with applicable air quality permitting, inspection, planning,
and monitoring procedures, techniques, and technologies by attending pertinent EPA, DNR, and other public
and private training classes, workshops and conferences. The training completed was consistent with the LINN
SFY 2019 training plan and relevant to the job duties of each staff member working under the Contract. DNR
commends LINN for using a variety of training formats and options, such as taking advantage of classroom
courses and utilizing webinars and conference calls, which minimize the cost of obtaining training while also
increasing training opportunities for staff. A summary to LINN training that occurred in SFY 2019, based on
LINN's end-of-year report, is included in Attachment C.
B. Fiscal Reporting
Acceptable Q Corrective Action Needed Q Deficient Q Not evaluated
Comments: The SFY 2019 expenditure reports were submitted quarterly using the format provided by DNR.
DNR appreciates LINN's rapid responses in addressing questions regarding the submitted expenditure reports,
which facilitated the review and processing of the invoices. LINN's improved QA checks of each expenditure
report before it is submitted has greatly reduced the number of errors previously noted on the expenditure
reports. Similarly, differences in the requested billable hours payments and the supporting billable hours
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documentation report have been greatly reduced by the improved QA checks.
C. Contract Review
[Xl Acceptable Q Corrective Action Needed Q Deficient Q Not evaluated
Comments: LINN timely submitted the proposed salary and non-salary programmatic budgets for SFY 2020
with thorough justification. As part of the budget development process, LINN convened a fee advisory group
meeting (as required in Section 5A.3 of the Contract), reviewed the draft budget and calculated estimates of
fees that will be received, and received recommendations regarding establishing or adjusting fees.
LINN provided timely responses to the various requests for information - including budget scenarios. LINN
met all timelines requested by DNR, and always responded to DNR requests for meetings and additional
information.
LINN worked seamlessly with DNR to review and provide comments on the final draft SFY 2020 Contract, as
specified in Section 5A.3 of the Contract.
D. Information Technology
1X1 Acceptable Q Corrective Action Needed Q Deficient Q Not evaluated
Comments: LINN maintained a website to disseminate information regarding the air program and updated
the website as needed during SFY 2019. LINN provided quarterly reports that detailed site usage data such as
hourly, weekday and monthly totals for site visits and page views, and breakdowns of this information for the
top 10 pages, directories, documents, downloads, images, files and IP addresses. LINN uses this information to
identify what types of information are of interest and importance to website visitors, and to decide on future
upgrades to the website.
LINN has initiated work with county IT staff to migrate the Air Quality website to the same website platform
(CivicPlus) that is currently used by the rest of Linn County government. This switch is expected to occur
during SFY2021, and will make it easier and faster for the public to access information on the website while at
the same time allowing for improved IT support for the website.
E. Legal Authority
1X1 Acceptable Q Corrective Action Needed Q Deficient Q Not evaluated
Comments: LINN regularly confers with the DNR on the need, content and timing of revisions and updates to
the Linn County Code of Ordinance (LCCO) on an as needed basis. LINN maintains a "red-line" version of the
LCCO, which LINN updates as DNR completes changes to the IAC. This tracking technique allows LINN to
capture all applicable updates to the IAC as they are made, decreasing the amount of staff time needed to
draft updates to the LCCO.
A county-wide reorganization of the LCCO was completed in 2018. A SIP revision to incorporate the LCCO
changes to the air quality ordinance provisions was submitted to EPA in July 2018, and, on November 21,
2019, was published in the Federal Register as a proposal for public comment.
LINN plans to begin drafting updates to the LCCO during calendar year 2020 to adopt applicable provisions
from a DNR rulemaking completed in 2019 and another rulemaking anticipated for completion in mid-2020.
F. Minority and Women Business Enterprise (MBE/WBE)
1X1 Acceptable Q Corrective Action Needed Q Deficient Q Not evaluated
Comments: LINN provided accurate and timely reports.
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G. Intergovernmental Cooperation
1^1 Acceptable Q Corrective Action Needed Q Deficient Q Not evaluated
Comments: LINN management staff participated in a Local Program/DNR meeting conducted during SFY
2019. LINN agenda topics for the meeting included the VW Settlement, LINN Solar Group buy, LINN Wood
Appliance Change-out funding, and facilitating Citizen Science.
LINN actively participated in a three-day requirements workshop with the consultant for DNR's new electronic
air permit application system (EASY Air). The insightful comments and recommendations provided by LINN
staff during this workshop and in follow-up meetings and emails has been helpful to ensuring that LINN staff
will be able to use the system in their review and time tracking for Title V operating permit applications and
PSD applications.
III. Construction Permitting Provisions
A. Construction Permit Activities (Source Review, Permit Issuance, Draft Permit Review, Permit Transfer)
[Xl Acceptable Q Corrective Action Needed Q Deficient Q Not evaluated
Comments: See Attachment A for general and specific comments on application review. LINN should ensure
DNR is appraised of project types requiring draft DNR review and given the chance to review or waive review
as mutually agreed.
B. Permit/Modeling Procedures
1X1 Acceptable Q Corrective Action Needed Q Deficient Q Not evaluated
Permit Comments: LINN is excellent at reviewing and noting all applicable NESHAP in their issued permits.
Additionally, the peer review process is continuing to catch most errors prior to permit issuance and the
engineering evaluations are well written and explanatory. DNR finds that LINN could improve consistency in a
few areas:
1. When setting plant-wide synthetic minor limits, even for minor sources, LINN should still require
recordkeeping to make the limits enforceable as a practical matter. If LINN believes that the source is
actually a true minor, the DNR suggests setting specific Hazardous Air Pollutant (HAP) limits for each
unit, and then documenting that the plant remains a minor source in the evaluation.
2. If setting a plant-wide limit in tons per year and requiring a daily recordkeeping trigger above 80% of
the limit, LINN should provide justification for the higher trigger in the evaluation. DNR practice and
guidance is to set the trigger at 80% unless otherwise justified.
3. If a company is currently not subject to a NESHAP because it is not using a target HAP, but may in the
future, the DNR suggests that LINN note the company is not subject to the NESHAP unless it is using
the target HAP. It is less confusing than forbidding the use of a target HAP, then allowing it if the
company follows the NESHAP requirements.
4. If LINN is basing synthetic minor or modeling decisions on grain/dry standard cubic foot (gr/dscf) limits
and the PTE is close to the threshold, the DNR suggests LINN establish a pound/hour (Ib/hr) limit in
addition to the gr/dscf limit. Airflows are allowed to vary by +/- 25% without requiring a permit
modification which could cause unintended issues with a synthetic minor limit or result in a different
modeling determination.
See Attachment A for other general and specific comments.
Dispersion Modeling Comments: LINN staff is very knowledgeable about modeling procedures and has
performed a significant number of analyses which helps maintain their skill. LINN shows a good understanding
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of the more complex aspects of modeling, including ambient air, intermittent sources, operating factors, and
downwash. LINN leverages tools to make modeling analyses more accurate and consistent. LINN consistently
performs a thorough review when modeling analyses are submitted by the applicant.
Concerns regarding the implementation of DNR modeling guidance for specific projects are summarized in
Attachment A. Two issues were noted that affect the modeling analyses in general:
1. The secondary formation of PM2.5 (particulate matter that have a diameter of less than 2.5
micrometers) and Ozone needs to be considered in projects with NO2 (Nitrogen Dioxide), SO2 (Sulfur
Dioxide), or VOC (Volatile Organic Compound) emissions. If emissions are less than the applicable
Significant Emission Rates (SERs), a simple statement explaining this fact is sufficient. For projects with
higher levels of emissions, EPA's Modeled Emission Rates for Precursors (MERPs) can be used.
2. The DNR has concluded that emissions from neighboring sources will generally cause a significant
concentration gradient in their vicinity, and are therefore generally not adequately represented by the
background concentration. Groups of contiguous facilities should generally be modeled together.
C. PSD Permit Activities
1X1 Acceptable Q Corrective Action Needed Q Deficient Q Not evaluated
Comments: See Attachment A for general and specific comments.
D. PSD Pre-application (Pre-application Meeting, Review of Pre-application Materials)
I | Acceptable Q Corrective Action Needed Q Deficient Not evaluated
Comments: No comments.
E. PSD Permit Application Review (Application Processing, Decision to Deny a Permit Application)
Acceptable Q Corrective Action Needed Q Deficient Q Not evaluated
Comments: See Attachment A for general and specific comments.
F. PSD Permit Drafting Procedures (Permit Content, Fact Sheet, PSD Permit Review by DNR, Facility Review
of PSD Permit)
Acceptable Q Corrective Action Needed Q Deficient Q Not evaluated
Comments: See comment on permit procedures above and attachment A for general and specific comments.
G. Public Notice Intent to Issue (PSD Permit Review by EPA, Public Notice and Public Participation,
Publication and Availability of Notice, Public Comment Period, Public Hearing, Response to Comments)
Acceptable Q Corrective Action Needed Q Deficient Q Not evaluated
Comments: No comments.
H. Final PSD Permit Issuance (Changes to Draft Permit, Conveyance of Proposed Final Permit to DNR, Re-
notification of Permit, Conveyance of Final Permit)
Acceptable Q Corrective Action Needed Q Deficient Q Not evaluated
Comments: No comments.
I. PSD Permit Modifications
Acceptable Q Corrective Action Needed Q Deficient Q Not evaluated
Comments: See Attachment A for general and specific comments.
J. Reporting Requirements
[Xl Acceptable Q Corrective Action Needed Q Deficient Q Not evaluated
Comments: No comments.
9
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K. DNR Responsibilities
I | Acceptable Q Corrective Action Needed Q Deficient ^ Not evaluated
Comments:
IV. Title V Permitting Provisions
A. Title V Permit Activities
1^1 Acceptable Q Corrective Action Needed Q Deficient Q Not evaluated
Comments: The performance criteria for LINN was to draft for issuance or denial a minimum of four initial or
renewal Title V Operating Permits annually. During this review period, four permits were issued: IPL Prairie Creek
Generating Station, Cedar Rapids WPCF, Cargill Inc., and GM Cereal Properties Inc. A proposed schedule
identifying the Title V permits LINN intended to issue was submitted timely.
B. Application Review
1X1 Acceptable Q Corrective Action Needed Q Deficient Q Not evaluated
Comments: Completeness reviews were conducted by LINN in a timely manner to ensure that the applications
were not deemed complete by default.
C. Permit Drafting Procedures
1X1 Acceptable Q Corrective Action Needed Q Deficient Q Not evaluated
Comments: LINN completes the technical reviews and prepares draft permits according to 567 IAC 22.108
and generally follows the DNR Title V Review Manual, Title V Permit Review Check Sheet and Completeness
Review Checklist. There continues to be appropriate coordination and consistency between the two programs.
D. Public Notice Intent to Issue
1X1 Acceptable Q Corrective Action Needed Q Deficient Q Not evaluated
Comments: LINN is following the new electronic notification process, and at a minimum, posts a notice on a
publically available website.
E. Final Permit Issuance
1X1 Acceptable Q Corrective Action Needed Q Deficient Q Not evaluated
Comments: No comments.
F. Permit Renewals
Acceptable Q Corrective Action Needed Q Deficient Q Not evaluated
Comments: LINN drafts renewal permits using the same procedures that apply to initial issuance.
G. Reopening Issued Title V Permits
1X1 Acceptable Q Corrective Action Needed Q Deficient Q Not evaluated
Comments: No permits were re-opened during this period.
H. Permit Changes
1X1 Acceptable Q Corrective Action Needed Q Deficient Q Not evaluated
Comments: No comments.
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I. Reporting Requirements
1^1 Acceptable Q Corrective Action Needed Q Deficient Q Not evaluated
Comments: LINN submitted quarterly status reports with the required information on active Title V permit
applications.
V. Compliance and Inspection Provisions
File Review Procedures
The DNR AQB Compliance Unit staff reviewed ten (10) LINN files. The ten files reviewed were a sufficient number
to sample the LINN enforcement and compliance program. DNR chose to review file documentation for [4th
Quarter 2017 -2019]. The files that were reviewed were as follows:
Major Sources:
Bio Springer 57-01-226
Diamond V Mills-North 57-01-045
Cedar Rapids WPCF 57-01-077
General Mills-GM Cereal Properties 57-01-012
International Paper 57-01-153
IPL Prairie Creek Generating Station 57-01-042
Minor Sources
JRS Pharma LP-MCCII 57-01-150
Frey Pet Hospital 57-01-165
ReConserve of Iowa 57-01-245
J. Rettenmaier USA LP 57-01-224
Prior to the onsite audit, DNR staff requested and reviewed the files sent electronically to the DNR. On the day of
the audit, DNR staff conferred with LINN staff regarding the inspection reports, specific enforcement actions at
some facilities, stack testing, and the ICIS Database.
A. Compliance
Acceptable Q Corrective Action Needed Q Deficient Q Not evaluated
Comments:
It is evident from the file review and discussions with LINN staff that LINN runs a very effective compliance
program. LINN staff do an excellent job tracking, evaluating, and documenting compliance at facilities within Linn
County and takes appropriate and timely action to address air quality violations. The compliance correspondence
with facilities is concise, easy to understand, and includes follow up dates when needed.
The electronic files were well organized and contained the inspection reports, Notices of Violation (NOVs), excess
emission reports, NESHAP reports, stack tests, and other correspondence.
LINN is providing a copy of all Letters of Noncompliance (LNC) and NOV to the DNR compliance section. LINN is
also providing the required Compliance and ICIS reports to DNR on a quarterly basis.
LINN adequately meets the compliance provisions agreed upon in the Contract.
B. Stack Tests
Acceptable Q Corrective Action Needed Q Deficient Q Not evaluated
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Comments:
LINN conducts a review of all stack test reports submitted and generates a summary sheet. LINN also sends
the facility a compliance letter at the conclusion of reviewing the report. DNR reviewed some of the LINN stack
test reports as part of this audit and found LINN stack test reviews to be accurate and complete. LINN staff are
very knowledgeable of the federal stack test reference methods and application to different types of sources.
LINN's stack test review process is also well documented. DNR suggested LINN require the use of Methods 18
or 320 to the extent possible for VOC testing as this is the preferred method to best characterize total VOC
emissions.
LINN and DNR completed a joint stack test observation and evaluation at a Cargill facility in LINN in 2019. LINN
staff are very competent and followed similar procedures to DNR while onsite.
C. Inspections
1X1 Acceptable Q Corrective Action Needed Q Deficient Q Not evaluated
Comments:
The LINN inspection reports were very thorough and included a determination of compliance status and
recorded observations. In addition, any needed corrective action was also identified. The use of the Title V Permit
and Construction Permits as the template for the inspection makes it easy to verify applicable requirements and
document compliance.
LINN submits its Compliance Monitoring Strategy (CMS) plan to DNR each year. LINN is conducting inspections in
accordance with the schedule included in the CMS.
Joint inspections were evaluated by DNR Field Office 1 and no issues were identified.
D. Variances
I I Acceptable Q Corrective Action Needed Q Deficient
Comments: N/A
E. Data Management
1X1 Acceptable Q Corrective Action Needed Q Deficient Q Not evaluated
Comments:
Compliance and enforcement information for federally reportable sources must be entered in EPA's ICIS
database. LINN implemented a data entry plan for ICIS following issues identified by DNR in the 2017 audit.
DNR's review of ICIS for the 2019 audit showed all facility information was accurate and complete. It was
apparent from discussions with LINN staff that they are following their data entry manual and are very
knowledgeable of the ICIS system and data requirements.
DNR recommended LINN participate in the annual EPA ICIS data verification process to ensure the accuracy of
EPA reported data and metrics.
F. Emissions Data
1X1 Acceptable Q Corrective Action Needed Q Deficient Q Not evaluated
Comments:
LINN requires and observes stack testing at facilities within LINN. LINN requires the use of federal test methods
for compliance demonstrations. LINN is also reporting stack test results to EPA through the ICIS database.
Not evaluated
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VI: Ambient Air Monitoring Provisions
Commendation:
LINN does an excellent job running their monitoring network. For data collected in 2017 and 2018, all LINN
criteria pollutant monitors were recommended for certification by EPA. This certification is based on having
both good data quality and completeness. Precision and bias statistics for data collected in the most recent
complete calendar year were reviewed, and LINN met the associated goals. In the fall of 2018 EPA conducted
through the probe audits on LINN's gas analyzers at the Health Department. This involved CO (Carbon
Monoxide), SO2, and ozone. Audit results in the Air Quality System (AQS) database show that LINN passed at
all levels. In spite of their small staff and the retirement of their QA officer at the end of 2018, LINN has
continued to collect high quality data.
In April of 2018 the first small citizen science ("Purple Air") monitors started in the LINN network. A major
repair was done on the roof of the Health Department shelter in the last half of October 2018 with minimal
data loss. Since the last DNR audit of LINN, the Method Quality Objective tables in the LINN SOPs have been
updated to reflect EPA's latest (March 2017) version.
A. Finding/Recommendation #1:
Finding: The ambient monitoring section of LINN is potentially facing two retirements (Jeff Lake and Kyle
Lundberg) in the next contract period (July 2020 to June 2021). In light of the small size of their staff and the
extensive experience of these two individuals, their possible retirement will pose a major challenge for the
monitoring program. LINN mentioned that their QA officer (Riley Mullins), whose time is currently split
between the air and water program, might transition to full time air monitoring work.
Recommendation: The DNR encourages LINN to continue to develop succession plans.
B. Finding/Recommendation #2:
Finding: The March 2017 revision of the Redbook Validation Templates, elevated the importance of results
from one of the three flow rate verifications done during monthly checks on PM2.5 samplers and low volume
samplers for PM10 (particles with a diameter of 10 micrometers or less). This refers to the flow check where
the sampler is in normal sampling configuration, the Flow Transfer Standard (FTS) is off, and the flow
measured by the sampler has to be within 2.1% of the 16.7 liters per minute (Ipm) design flow rate. EPA raised
the status of this check from an Operational Criteria to a Critical Criteria. The DNR noted that section 3.11.1.5
of the LINN SOP for collecting PM2.5 and PM10 on the Thermo 2025 sampler does not reflect this update.
Recommendation: LINN should revise this section of their SOP for discrete PM accordingly.
C. Finding/Recommendation #3:
Finding: In the fall of 2018, EPA conducted "through the probe" audits on gas analyzers at the Health
Department site (for CO, SO2, and ozone). Based on values already in AQS, all analyzers passed at all levels.
Recommendation: The DNR would appreciate if LINN would forward the final results when they receive
them from EPA.
D. Finding/Recommendation #4:
Finding: In November 2018, EPA conducted a technical systems audit of the LINN air monitoring program. A
draft preliminary report of the audit findings involved:
1. EPA recommends that the design flow rate calculation be included on the PM10 Flow Audit form.
2. EPA recommends that the expiration date of the Standards used be included in the Met Station
Quarterly Audit form.
13
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3. EPA recommends that the expiration date of the calibrator and cylinder used be included in the SO2
Calibration form.
4. EPA recommends that the criteria used on the Calibrator Flow Verification shall be changed to 2%
from 4%. (Reference: Quality Assurance Handbook for Air Pollution Measurements Systems, Volume II:
Ambient Air Quality Monitoring Program, EPA-454/B-13-003, May 2013).
Item 1 may be related to the question of whether the flow from the portable transfer standard, or the
sampler's own flow meter, should be compared to the design flow rate. (See a detailed discussion of this in
Finding H.) The Met Station Quarterly Audit form includes lines to enter the serial numbers of the audit
standards, but does not include a line for the expiration date of such standards. For the calibration of gas
analyzers, LINN uses some spreadsheets that were generated by EPA that are "password protected" and
cannot be edited by the states. LINN indicated that some of these spreadsheets do not include a field for
expiration dates. LINN also indicated that the expiration dates for calibration standards are recorded in the
site logbook during calibrations, checks, audits. The 4th item pertains to the quarterly flow verifications for the
Mass Flow Controllers (MFCs) on the Thermo 146 gas dilution calibrator. LINN already addressed this, since
the acceptance criteria for this check was changed from 4% (March 2018 SOP) to 2% (March 2019 SOP). At
lower flows the 2% acceptance criteria is only slightly more lenient than the accuracy specification of the
instrument. LINN reported that although adoption of the tighter criteria occasionally resulted in more
frequent calibrations of the MFCs, it has not been too much of a burden so far.
Recommendation: The DNR would appreciate if LINN would forward the final results of this audit when
they receive them from EPA. The DNR recommends that LINN collaborate with the DNR and EPA to address
any ambiguities concerning the revision of Field Data Sheets (FDS) that are not resolved in the final report.
The DNR recommends that LINN add fields for the expiration dates of the calibration standards to the FDS
that are referenced in the audit, to the extent that EPA generated spreadsheets are editable. The DNR also
recommends that LINN add fields for the expiration dates of the calibration standards to their own internally
generated FDS that are referenced in the audit.
E. Finding/Recommendation #5:
Finding: The State Hygienic Lab (SHL) conducts an annual technical systems audit of LINN air monitoring
activities. No remedial actions were required as a result of the audit covering calendar year 2017, but one
suggestion was noted. SHL suggested that LINN ensure transfer checks of the data acquisition system are done
at least annually. LINN indicated that they had historically done this, but omitted the cross check in 2017. LINN
put reminders on their calendar, and showed the results of the check done in 2018, to SHL auditors at the
following SHL audit.
Recommendation: The DNR encourages LINN to continue its present practice.
F. Finding/Recommendation #6:
Finding: SHL conducts an annual technical systems audit of LINN air monitoring activities. No remedial actions
were required as a result of the audit covering calendar year 2018, but two suggestions were noted. In recent
years, Iowa has reported both the hourly average SO2 value and the largest 5-minute S02 average for each
hour. SHL suggested that LINN initiate plans to track the hourly maximum 5-minute averages that are less than
the full hourly average on a quarterly basis. LINN has already addressed the first suggestion by creating a
tracking spreadsheet. The second suggestion involved editing section 6.1 of the Quality Management Plan
(QMP) for clarity, and updating the QMP to reflect the fact that Quality Improvement (Ql) Analyst software
has been replaced by Envista. LINN indicated their agency will be doing these updates at the time of their next
routine QMP review/update.
Recommendation: The DNR encourages LINN to make this revision in the QMP they submit as part of the
Annual Review in March of 2020.
14
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G. Finding/Recommendation #7:
Finding: In May 2019 LINN received a Thermo 146iQ Gas Dilution Calibrator with three MFCs. The gas dilution
calibrators that LINN has historically operated used only 2 MFC, one for the zero air and another connected to
the pollutant stock cylinder. The new 146iQ model has 2 pollutant MFCs that allow for a much broader
dilution range. In the course of reviewing this SOP, the DNR also noted some issues with two of the associated
FDS. On the "Flow Verification/Audit" form, the last column shows a value of 2.50% as passing. Also, in the
"Zero Air" tier of rows, flow should be entered from highest to lowest, so only the lowest (below 20% of the
full scale range) is not subject to the test criteria. (In the image of the FDS attached to the SOP, it's the highest
flow that's not subject to the acceptance criteria.) The same inversion appears in the "Zero Air" tier of the
form for verifications that immediately follow a calibration.
Recommendation: LINN will need to make some modifications to their SOP for gas dilution calibrators to
make it applicable to the new instrument. (Since the 146iQ with three MFC is not currently deployed, LINN
plans to defer the SOP updates arising from the new instrument until after training. Plans are to have the
training occur after the move to the new building.)
H. Finding/Recommendation #8:
Finding: About 2 months after the last audit, the DNR had a conference call with Region 7 regarding some
ambiguity in EPA guidance for operating PM2.5 FRM samplers. One of the criteria for monthly verifications and
quarterly audits was that something should be within 5% of the 16.7 Ipm design flow rate of the size separator
on the sampler. There are two possible flows that could be compared to the design flow rate. One would be
the flow measured by the sampler's own flow meter. The other would be the flow measured by a portable
NIST traceable FTS that the operator or auditor attaches the sampler. After considerable discussion EPA
decided in favor of the latter. In other words, the flow measured by the portable FTS should be within 5% of
16.7 Ipm. The scope of the DNR's discussions on this issue was initially limited to monthly flow verifications
and quarterly audits for PM2.5 FRM samplers. However, the March 2017 Redbook uses identical criteria for
flow rate verifications and audits for PM2.5 FRM samplers, continuous PM2.5 samplers, and low volume filter
based PM10 samplers. Therefore, the DNR concluded that EPA's verdict applies to flow checks and audits for all
the pollutant/method combinations just mentioned. The DNR conveyed these developments to LINN at the
time of the audit, and also noted that EPA committed to work towards removing ambiguity on this in both the
Redbook and Guidance Document 2.12.
Recommendation: The LINN SOPs for their BAM 1020 and Teledyne T640 continuous PM2.5 samplers
appear to be already in line with EPA's position. LINN has a combined SOP for both discrete PM2.5 and PM10
sampling (since they are collected on the same instrument with different size separators). That SOP requires
some minor modifications to conform to EPA's position, particularly in section 3.11.1.5. LINN should revise
the latter SOP accordingly.
I. Finding/Recommendation #9:
Finding: Starting at the very end of 2016, LINN configured their continuous BAM 1020 PM2.5 samplers as FEM
instruments. For data collected in 2017 agreement between these samplers and the discrete Federal
Reference Method (FRM) samplers was excellent. (Both BAMs were in the "Hanley Box" for 2017.) The
agreement between the two methods deteriorated for data collected in 2018, as well as for the first eight
months of 2019, and neither BAM met the "Hanley Box" equivalence criteria for these time frames. The POC 3
BAM sampler was replaced with a T640 analyzer on 9/1/2019. The measurement principle of a T640 is based
on the scattering of polychromatic light, and samplers of this type have not been previously used in Linn
County. LINN set flags in EPA's AQS database that will exclude both BAMs from contributing to determinations
about National Ambient Air Quality Standards (NAAQS) attainment, starting on 1/1/2018 and going out to the
indefinite future. This was indicated in the DNR's 2019 Network Plan. A few days after the audit (on 10/18/19)
the DNR was informed that EPA approved the Network Plan, which indicates their concurrence with the
exclusion flags.
15
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Recommendation: LINN should continue to track the performance of their continuous PM2.5 samplers
relative to the FRM. If the T640 demonstrates good agreement with the FRM, it may be advisable to replace
the POC 4 BAM with a T640 as well, perhaps between 7/1/2020 and 1/1/2021.
J. Finding/Recommendation #10:
Finding: DNR and LINN discussed equipment needs. LINN is in the process of purchasing a Thermo 2025i
sampler, as indicated in the final equipment list for the FY2020 contract. LINN currently has a total of two T640
analyzers. If the POC 4 BAM was replaced by a T640, LINN would not have a backup T640. LINN also indicated
that some of their flow transfer standards are getting old and malfunction occasionally. LINN thought that a
3D printer might be required to configure inlets for the heated Purple Air samplers they are developing.
Recommendation: LINN should continue to monitor the age and condition of the equipment in their
network, and availability of backup parts and equipment. The DNR and LINN will continue to work together
to ensure sufficient funding is available for these purchases. LINN should explore the possibility of working
work with Polk County or SHL, to get a 3D printout of an inlet blueprint that LINN drafted.
K. Finding/Recommendation #11:
Finding: LINN performs daily-automated checks at three levels: 1) "0 level" using pollutant free air, 2) mid-
range (the precision level) and 3) high concentration (the span level). EPA currently only requires the precision
level results be uploaded to the AQS database. However, EPA has already developed slots for results from the
zero and span level, and it is anticipated that EPA will require all three levels to be uploaded in the future
Recommendation:
LINN should plan for eventually being asked to do this.
L. Finding/Recommendation #12:
Finding: DNR and LINN discussed LINN's 2018 precision and bias statistics (please see Attachment B). EPA
goals were not only met, but the LINN network generally passes the goal by a wide margin.
Recommendation: The DNR encourages LINN to continue its present practice.
16
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Attachment A: Comments on Specific Linn County Construction Permits
The purpose of the construction permit evaluation was to determine if the program is being conducted in a
manner consistent with the Contract. The investigation looked specifically at the following permit actions,
which were intended to be representative.
ADM
project 15-215, LCPH 2173,
project 2337, ATI 6974 to 6976-
project 2508, ATI 7167, 7168
project 18-374, 07-A-543-P4, 07-A-544-P4
project 4545, ATI 7120
project 18-477, 07-A-541-P2
project 4568, ATI 7225
Betenbender Manufacturing,
project 2503, ATI 7202 thru 7204, 7215
Cargill Corn Milling
project 3541, ATI 7212, 7213
project 2526, ATI 7196
project 2505, ATI 7124.
project 2480, ATI 7111
project 2423, ATI 7064, 7065
Cargill East Bean
Project 2472, ATI 7099
Cargill West Bean
project 4577, ATI 7242
project 2478, ATI 7108
Corn Fed Automotive
project 4553, ATI 7220
Croell
project 2487, ATI 7115, 7116
Danisco
project 4613, ATI 7260
project 2519, ATI 7187 thru 7193
project 2517, ATI 7187 to 7189
project 2466, ATI 7098
project 2439, ATI 5133, 5116, 5329, 5572, 5573
project 2429, ATI 5328
project 2410, ATI 4947
project 2375, ATI 7020
Diamond V North
project 4599, ATI 7255
17
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Diamond V South
project 2367, ATI 6783, 6784 .
project 4615, ATI 7262
project 4580, ATI 7244
project 4559, ATI 7230 thru 7239
project 2468, ATI 7100
Diamond V South
project 2463, ATI 7092
Electro-Coatings of Iowa
project 2452, ATI 7084.
project 2473, ATI 6225.
General Mills
project
2414,
ATI
7060, 7061
project
2426,
ATI
7066
project
2438,
ATI
7076
project
2510,
ATI
7169
project
4547,
ATI
7228
project
4576,
ATI
7240, 7241
project
4598,
ATI
7254
Ingredion Inc.
project 4583, ATI 7245 and 7246.
project 4614, ATI 7261
International Paper,
project 4551, ATI 7126, 7127, 7218.
project 3533, ATI 7107, 7127, 7208
PMX Industries
project 2475, ATI 7105, 7106. .
Red Star Yeast
project 2194, ATls 6822-6936.
project 2304, ATI 6927 thru 6929
project 2313, ATI 6935.
project 2485, ATI 7113, 6822
RELCO Locomotive,
project 4596, PTO 5388-R1
project 4617, PTO 7267-
Rockwell Collins
project 4586, ATI 7272,
project 4586, ATI 7247.
project 2448, ATI 7082.
-------
The following general issues were noted:
1) Plant-wide synthetic minor limits, even for minor sources, still require recordkeeping to make the limits
enforceable as a practical matter. If LINN believes that the source is actually a true minor, the DNR
suggests setting specific HAP limits for each unit, and then documenting that the plant remains a minor
source in the evaluation.
2) If setting a plant-wide limit in tons per year, the DNR notes that setting anything above 80% of the limit
as the trigger point to switch to daily recordkeeping needs to be justified in the evaluation.
3) If a company is currently not subject to a NESHAP because it is not using a target HAP, but may in the
future, the DNR suggests noting that the company is not subject to the NESHAP unless it is using the
target HAP. It is less confusing than forbidding the use of a target HAP, then allowing it if the company
follows the NESHAP.
4) When basing synthetic minor or modeling decisions on the potential-to-emit (PTE) based on grain/dry
standard cubic food (gr/dscf) limits, the DNR notes that airflows can vary by +/- 25% without requiring
a permit modification. If the PTE is close to the threshold, the DNR suggests using a pound/hour (Ib/hr)
limit to clarify matters.
General Modeling Comments
Two issues were noted that affect the modeling analyses in general:
1. The secondary formation of PM2.5 and Ozone needs to be considered in projects with NO2, SO2, or VOC
emissions. If emissions are less than the applicable Significant Emission Rates (SERs) a simple
statement explaining this fact is sufficient. For projects with higher levels of emissions EPA's Modeled
Emission Rates for Precursors (MERPs) can be used.
2. The DNR has concluded that emissions from neighboring sources will generally cause a significant
concentration gradient in their vicinity, and are therefore generally not adequately represented by the
background concentration. Groups of contiguous facilities should generally be modeled together.
The following are permit specific issues:
Facility Name:
Cargill Corn Processing - Project 2505, ATI 7124. The DNR notes that monitoring frequency is a factor in
setting operating parameters, as continuous monitoring might require a larger allowable range in the
measured parameter to account for all operating conditions, while a once a week recording may be better off
with an allowable range for normal operating conditions.
Danisco - As noted above in the general issues section, a plant-wide synthetic minor HAP limit of 9.4/243.4
tpy requires recordkeeping to make it practically enforceable.
Electro-Coatings of Iowa - Project 2473, ATI 6225. The evaluation of this project noted "DNR does not
identify HCI (hydrochloric acid) as a VOC or PM HAP." The DNR does consider HCI a PM HAP.
Electro-Coatings of Iowa - Project 2452, ATI 7084. Condition 5.E states "The emission of any of the following
plating and polishing metal HAPs through this emission point (EP004) as defined in 40 CFR 63.11511, are
prohibited: cadmium (Cd), chromium (Cr), lead (Pb), manganese (Mn) and nickel (Ni). Or, as an alternative, the
owner or operator can elect to comply with the requirements on NESHAP Subpart WWWWWW by meeting
the applicable Standards of Compliance requirements...." The DNR suggests that it would be clearer if HAPs
are allowed if the condition stated that the owner or operator must follow the applicable requirements of
WWWWWW if they use of any of the HAPs (list) in this emission unit.
19
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Ingredion Inc - Project 4583, ATI 7245 and 7246. There is emission limit table for "Alternative Operating
Scenario", but the permit did not define when the alternative operating scenario was allowed.
RELCO Locomotive - Project 4617, PTO 7267. When this booth was relocated, it looks like the Ib/hr limit was
removed. It appears that the Ib/hr limit was originally based on modeling guidance, and the reviewer decided
that no PM10 or PM2.5 limits were necessary since the particulate PTE based on the gr/dscf limit and airflow
was below PSD significant thresholds. The DNR would note that if the airflow was nearer 125% of the
permitted rate, the PTE would be over 10 tons per year.
Rockwell Collins - Project 2448, ATI 7082. The VOC and HAP limit recordkeeping seem to be inconsistent, in
that the VOC plantwide limit does not include VOC emissions from combustion and storage tanks, but the HAP
limits are facility wide and do apparently include emissions from combustion and storage tanks.
Specific Modeling Comments
ADM #4567 - When reevaluating PSD permits, it is generally necessary to reevaluate all components of the air
quality analysis. For this project the NAAQS analysis was reevaluated but the Increment was not. Also, the
additional impact analysis was not reevaluated. Oftentimes, small changes to the permits will still allow the
same additional impact analysis to be used, but it should still be replicated in the project so that the analysis
record is complete. The Increment analysis should have been reevaluated, but based on the changes being
made, and based on the results of the NAAQS analysis that was completed, the conclusion of the analysis
would not have changed in this case.
20
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Attachment B. Summary of LINN Precision and Bias*
*Results from DNR's SLAMS certification review for 2018
PM2.5 FRM routine co-located pairs: PM2.5 FRM PEP concentration pairs:
Is the "Bias" < 10.1%?
LINN 19-113-0040
3.41%
PM2.5 FRM PEP concentration pairs: Is the absolute value of both LCL and UCL for "Bias" < 10.1%?
Goal for CV< 10.1%.
LINN 19-113-0040
4.30%
LINN 19-113-0040
-6.50% to 13.31%
PM10 routine co-located pairs:
Goal for CV< 10.1%.
PMcoarse routine co-located pairs:
Goal for CV< 15.1%
LINN 19-113-0040
5.68
LINN 19-113-0040
8.70%
Audit limits should fall into confidence limits obtained from routine checks. As a goal, ninety-five percent of the
individual percent differences (all audit concentration levels, from all monitors) should be captured within the
probability intervals for the same primary quality assurance organization (from bi-weekly checks done on all
monitors). Yellow highlight indicates values <75%. (Note that this statistic does not account for the uncertainty in
the known value of the audit gas, and the uncertainty in the known value of the routine calibration gas. Also, small
and consistent percent differences during bi-weekly checks narrow the confidence limits making it more difficult to
attain the goal. EPA dropped this assessment in their April 2016 revisions to 40 CFR Part 58.)
Pollutant
LINN
CO
92%
Ozone
94%
S02
11%
PM2.5 (FRM & BAM)
88%
PM10 Discrete
88%
For bias, the sign should be neutral (+/-) instead of positive (+) or negative (-). The magnitude of the bias for
pollutants other than ozone and NO2 should be less than 10.1%. For NO2 the magnitude of the bias should be less
than 15.1%, and for ozone it should be less than 7.1%. The bias results for the LINN reporting organization are
presented in the table below:
Pollutant
Sign of Bias
Magnitude of Bias
CO:
+/-
2.78%
Ozone:
+/-
1.33%
S02:
+/-
1.19%
PM2.5 FRM & BAM:
+/-
0.86%
PM10 Discrete:
-
1.48%
PM Coarse:
+/-
8.93%
Almost all the bias signs were neutral. In addition, the magnitude of the bias always met the associated goal.
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Attachment C. Staff Training Summary
Title
Employee(s) Attending
Training Delivery
First Date(s) of Training
EPA Low Cost Air
Sensors Webinar
Burns, Dave
Computer/Electronic Based:
webinars, on-line, phone
4/17/2019
Retigo Tutorial
Webinar
Burns, Dave
Computer/Electronic Based:
webinars, on-line, phone
4/16/2019
NACAA Air Sensors
Conference Call
Burns, Dave
Computer/Electronic Based:
webinars, on-line, phone
3/11/2019
NACAA Monitoring
Conference call
Burns, Dave and Mullins,
Riley
Computer/Electronic Based:
webinars, on-line, phone
11/1/2018
AQS Ask The Experts
Burns, Dave
Computer/Electronic Based:
webinars, on-line, phone
11/1/2018
Air pollution exposure
and health risk
Burns, Dave and Dodge,
Shane
Computer/Electronic Based:
webinars, on-line, phone
9/28/2018
Thermo Air Monitor
Training Summit
Burns, Dave; Lake, Jeff;
Mullins, Riley; and Otto,
Jon
;Conference/Meeting/Traini
ng: Physically attend
9/18/2018
Air Toxics 2014 NATA
Data preview
Burns, Dave and
Daugherty, Anthony
Computer/Electronic Based:
webinars, on-line, phone
8/20/2018
EPA National Ambient
Air Monitoring Conference
Burns, Dave
Conference/Meeting/Trainin
g: Physically attend
8/13/2018
Air Sensors Webinar
Burns, Dave; Lundberg,
Kyle; and Mullins, Riley
Computer/Electronic Based:
webinars, on-line, phone
8/2/2018
NACAA Criteria
Pollutants Call
Daugherty, Anthony
Computer/Electronic Based:
webinars, on-line, phone
6/26/2019 and 9/13/18
DNR Construction
Permit Meeting Call
Daugherty, Anthony;
Dodge, Shane; and
Drahos, Amy
Computer/Electronic Based:
webinars, on-line, phone
2019: 6/25, 5/14, 4/2, 3/5,
2/4 and 1/8. 2018: 12/11,
11/13, 10/30, 8/21, 8/7 and
7/24.
NACAA Permitting
Success Stories
Daugherty, Anthony
Computer/Electronic Based:
webinars, on-line, phone
6/24/2019
NACAA Permitting & NSR
Call
Daugherty, Anthony
Computer/Electronic Based:
webinars, on-line, phone
2019: 6/11, 5/8, 3/13, 2/13.
2018: 11/14, 9/12, and
7/11
NACAA Emission & Modeling
Call
Daugherty, Anthony
Computer/Electronic Based:
webinars, on-line, phone
2019: 6/4 and 4/2. 2018:
12/4, 10/2, and 8/7.
Air Quality Client
Contact Meeting
Daugherty, Anthony
Computer/Electronic Based:
webinars, on-line, phone
5/23/2019
NACAA Permitting &
NSR Call
Daugherty, Anthony
Computer/Electronic Based:
webinars, on-line, phone
5/8/2019
Power Sector's Planning
Process/Agency
Participation
Daugherty, Anthony and
Drahos, Amy
Computer/Electronic Based:
webinars, on-line, phone
4/4/2019
NACAA: Air
Quality Regulations
Daugherty, Anthony
Computer/Electronic Based:
webinars, on-line, phone
3/26/2019
22
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Title
Employee(s) Attending
Training Delivery
First Date(s) of Training
EPA Webinar - Recent
Enhancements to the CMAQ
Modeling System
Daugherty, Anthony
Computer/Electronic Based:
webinars, on-line, phone
2/27/2019
NACAA Briefing Call on
National Compliance
Initiatives
Daugherty, Anthony;
Dodge, Shane; and
White, Janell
Computer/Electronic Based:
webinars, on-line, phone
2/14/2019
Easy Air E-Application Call
Daugherty, Anthony
Computer/Electronic Based:
webinars, on-line, phone
1/14/2019
DNR Title V Call
Daugherty, Anthony
Computer/Electronic Based:
webinars, on-line, phone
2019:1/10/2019. 2018:
12/13, 11/15, 10/18, 9/20,
and 8/22.
Introduction to the
Power Sector
Daugherty, Anthony
Computer/Electronic Based:
webinars, on-line, phone
12/13/2018
NACAA Air Toxics
Committee Call
Daugherty, Anthony
Computer/Electronic Based:
webinars, on-line, phone
12/6/2018 and 7/11/2018
EPA Briefing NACAA
on Residential Wood
Heating NPRM and ANPRM.
Daugherty, Anthony and
Drahos, Amy
Computer/Electronic Based:
webinars, on-line, phone
12/6/2018
EPA Webinar: 2015 Ozone
NAAQS
SIP Requirements Rule
Daugherty, Anthony
Computer/Electronic Based:
webinars, on-line, phone
11/20/2018
DNR Air Quality Client
Contact Meeting
Daugherty, Anthony
Computer/Electronic Based:
webinars, on-line, phone
11/8/2018
EPA GHGRP Reporting Year
2017 Data Release
Daugherty, Anthony
Computer/Electronic Based:
webinars, on-line, phone
10/24/2018
NACAA Enforcement
Call
Daugherty, Anthony and
Dodge, Shane
Computer/Electronic Based:
webinars, on-line, phone
9/13/2018
4-State Permitting Call
Daugherty, Anthony and
Dodge, Shane
Computer/Electronic Based:
webinars, on-line, phone
7/17/2018
EPA's Report on the
Environment
Dodge, Shane and
Drahos, Amy
Computer/Electronic Based:
webinars, on-line, phone
6/12/2019
2019 NACAA Spring
Meeting
Dodge, Shane and
Hodina, James
Conference/Meeting/Trainin
g: Physically attend
4/29/2019
EPA Draft FY 2020 -2021
National Program Guidance
Dodge, Shane
Computer/Electronic Based:
webinars, on-line, phone
4/24/2019
DNR AQ/FO Meeting
Dodge, Shane and White,
Janell
Conference/Meeting/Trainin
g: Physically attend
4/23/2019
EPA 4-State Call
Dodge, Shane
Computer/Electronic Based:
webinars, on-line, phone
4/16/2019
EPA Region VII
Permitting & Compliance
Meeting
Dodge, Shane and
Timmerman, Jia
Conference/Meeting/Trainin
g: Physically attend
10/10/2018
DNR Fall Local
Program Meeting
Dodge, Shane
Conference/Meeting/Trainin
g: Physically attend
8/29/2018
23
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Title
Employee(s) Attending
Training Delivery
First Date(s) of Training
NACAA Global Warming
Computer/Electronic Based:
6/12/2019 and 12/12/2018
Committed
Drahos, Amy
webinars, on-line, phone
NACAA Public Outreach and
Computer/Electronic Based:
Education Committee
Drahos, Amy
webinars, on-line, phone
6/11/2019
NACAA Ad Hoc Committee
Computer/Electronic Based:
2019: 6/5, 5/1, 3/7, and
on Resilience and
Drahos, Amy
webinars, on-line, phone
2/6. 2018:12/5 and 11/7
Air Pollution Dispersion
Computer/Electronic Based:
Around
Drahos, Amy
webinars, on-line, phone
4/25/2019
Existing Infrastructure
Delving Into Passive
Computer/Electronic Based:
Techniques for Air Pollution
Drahos, Amy
webinars, on-line, phone
3/28/2019
Mitigation
Learning Institute - Air
HR Training: Arranged
Quality
Drahos, Amy
with/by Human Resources
3/7/2019
Computer/Electronic Based:
2019:3/7 and 2/7. 2018:
TV Conference Call
Drahos, Amy
webinars, on-line, phone
9/20
IDNR Fee Advisory
Computer/Electronic Based:
Group Meeting - Minor
Drahos, Amy
webinars, on-line, phone
2/22/2019
Source
NACAA Residential
Computer/Electronic Based:
Wood Heating Devices NSPS
Drahos, Amy
webinars, on-line, phone
1/16/2019
NACAA-2015 NSPS
Computer/Electronic Based:
Residential Wood Heater
Drahos, Amy
webinars, on-line, phone
12/13/2018
Rulemaking Discussion
Air Quality Flag
Computer/Electronic Based:
Program
Drahos, Amy
webinars, on-line, phone
8/28/2018
IEHA2108 Fall
Conference/Meeting/Trainin
Conference
Hodina, James
g: Physically attend
10/10/2018
Training Plan - Air
Computer/Electronic Based:
Quality Scientist
Lamphier, Carole
webinars, on-line, phone
8/20/2018
Training Plan Air
Computer/Electronic Based:
Quality Scientist
Lamphier, Carole
webinars, on-line, phone
8/13/2018
Training Plan Air
Computer/Electronic Based:
Quality Scientist
Lamphier, Carole
webinars, on-line, phone
8/6/2018
Training Plan - Air
HR Training: Arranged
Quality Scientist
Lamphier, Carole
with/by Human Resources
7/30/2018
Training Plan Air
Computer/Electronic Based:
Quality Scientist
Lamphier, Carole
webinars, on-line, phone
7/23/2018
NACAA Conference
Computer/Electronic Based:
Call
Lundberg, Kyle and
Mullins, Riley
webinars, on-line, phone
4/23/2019
EPA National Air
Conference/Meeting/Trainin
Monitoring Conference
Burns, Dave; Lundberg,
Kyle; and Mullins, Riley
g: Physically attend
8/13/2018
DNR Field Office 6
Conference/Meeting/Trainin
Roundtable
Mullins, Riley
g: Physically attend
2/28/2019
Ambient Air
Conference/Meeting/Trainin
2019: 9/6. 2018: 12/19,
Monitoring
Mullins, Riley
g: Physically attend
11/13, 10/11, 9/26, 9/13,
and 8/30
Conference/Meeting/Trainin
EPA Audits
Mullins, Riley
g: Physically attend
11/6/2018
-------
Title
Employee(s) Attending
Training Delivery
First Date(s) of Training
Air Monitoring
Training
Mullins, Riley
Conference/Meeting/Trainin
g: Physically attend
11/1/2018
Quality Assurance
Mullins, Riley
Conference/Meeting/Trainin
g
7/19/2018
Fugitive Dust,
Incinerators, and Biomass
Boilers
Timmerman, Jia
Conference/Meeting/Trainin
g: Physically attend
5/6/2019
Smoke School
Timmerman, Jia and
White, Janell
Computer/Electronic Based:
webinars, on-line, phone
3/19/2019
MACTTraining
Timmerman, Jia and
White, Janell
Conference/Meeting/Trainin
g: Physically attend
7/12/2018
Asbestos Inspector
Refresher Training
White, Janell
Conference/Meeting/Trainin
g: Physically attend
10/5/2018
Smoke School
White, Janell
Conference/Meeting/Trainin
g: Physically attend
9/18/2018
-------
Attachment D
2019 Linn County (LINN) Program Review: Responsiveness Summary
II. Program Management Provisions
H. Personnel - Staff time Expended Report SFY 2019 (table)
LINN Comment: Linn noted that the 1.05 budgeted FTE indicated for Dispersion Modeling should be 0.15
FTE.
DNR Response: Linn is correct. The 1.05 indicated in the Draft Report is in error and should be 0.15. DNR has
made the correction in the Final Report.
III. Construction Permitting Provisions
L. Construction Permit Activities
DNR Comment: See Attachment A for general and specific comments on application review. For draft permit
review, it does not appear that LINN has provided to DNR a copy of draft permits for NESHAP, NSPS, or PSD
synthetic minors as detailed in the contract, see Rockwell Collins and Diamond V South. LINN should ensure
going forward that DNR is appraised of these project types and given the chance to review or waive review.
LINN Comment: The expectation for NESHAP, MACT or NSPS at greenfield sites is pretty clear. DNR's
comments appear to be directed at PSD synthetic minor projects at Rockwell Collins and Diamond V
Mills South. However, the projects referenced for these facilities were synthetic minor limits to avoid
Title V, not PSD. Is the intention to expand the scope of this expectation to include SM limits for Title V
as well?
We value DNR's input and have a great working relationship with Gary, just want to make sure that we
not adding unnecessary work to him and extending turnaround times
DNR Response: LINN is correct. The projects referenced here are TV synthetic minor and not PSD synthetic
minor. It is not DNR's intention to expand the requirement to include TV synthetic minors. DNR has deleted
the reference to draft permit review and changed the applicable DNR Comment in the Final Report to the
following:
Comments: See Attachment A for general and specific comments on application review. LINN should
ensure DNR is appraised of project types requiring draft DNR review and given the chance to review or
waive review as mutually agreed.
V. Compliance and Inspection Provisions
E. Data Management
DNR Comments: DNR recommends that LINN participate in the annual EPA ICIS data verification process to
ensure the accuracy of EPA reported data and metrics.
LINN Comment: Shane Dodge and Janelle White are now both on the ECHO data verification email list,
and Janelle will be conducting the yearly verification process for Linn County.
DNR Response: The DNR concurs with LINN's comments. No changes made to the Final Report.
26
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VI: Ambient Air Monitoring Provisions
Linn Comments: LINN suggested several minor grammatical changes throughout this section.
DNR Response: The DNR concurs with LINN's suggested changes and has made the changes to the Final
Report.
Attachment A: Comments on Specific Construction Permits
The following general issues were noted:
DNR Comment:
2) If setting a plant-wide limit in tons per year, the DNR notes that setting anything above 80% of the limit
as the trigger point to switch to daily recordkeeping needs to be justified in the evaluation.
LINN Comments: The Department justifies setting the daily recordkeeping trigger higher than 80% for
the sole reason that one of two air programs the facility is avoiding is becoming subject to Title V.
Once a source becomes subject to Title V, the company has 12 months to submit an initial application.
It seems punitive to require daily recordkeeping in these instances, with such a lengthy window to
comply with the Title V permitting requirements.
The second air program the facility is avoiding is being a 'major' source of HAPs. Again, once the
facility triggers the threshold, the facility is responsible for complying with any applicable MACT. This
will involve an Initial Notification, so the Department will be notified in a timely manner pursuant to 40
CFR 63 Subpart A. Regardless whether or not a MACT applies, the facility still has 12 months to apply
for a Title V permit to comply with the Title V permitting requirements.
Review of minor source EIQs, quarterly reports, and regular compliance inspections are enforcement
tools the Department uses to assess current actual emissions at facilities which are potentially
approaching the applicable thresholds.
DNR Response: DNR agrees that it is likely that LINN would discover sources that exceeded their synthetic
minor limits through EIQs, reports, etc. DNR sets the trigger value at 80% to ensure that as the company
approaches the limit they do not unintentionally have a violation. Additionally, EPA guidance requires daily
recordkeeping and DNR has set a policy to reduce the stringency of that requirement when they are not likely
to exceed the limit.
No changes made to the Final Report.
DNR Comment:
4) When basing synthetic minor or modeling decisions on the potential-to-emit (PTE) based on grain/dry
standard cubic foot (gr/dscf) limits, the DNR notes that airflows can vary by +/- 25% without requiring a permit
modification. If the PTE is close to the threshold, the DNR suggests using a pound/hour (Ib/hr) limit to clarify
matters.
LINN Comments: Evaluating PTE for sources based on the potential 25% increase in flow is not
standard practice when reviewing construction permits. The DNR Construction Permit Manual makes
no mention of this practice being conducted, only mentioning that airflows ±25% requires a new
27
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evaluation. Nonetheless, a Ib/hr PM/PM10 limit permit will be added to the RELCO permit prior to PTO
issuance.
DNR Response: DNR agrees with LINN that the manual does not mention this practice. However, when a
facility is close to a threshold it is important to consider the range of compliance allowed. Limits based on
airflow are inherently variable and in some cases may not be suitable for some bright line tests, such as
synthetic minors.
No changes made to the Final Report.
The following are permit specific issues:
DNR Comment:
Cargill Corn Processing - Project 2505, ATI 7124. The DNR notes that monitoring frequency is a factor in
setting operating parameters, as continuous monitoring might require a larger allowable range in the
measured parameter to account for all operating conditions, while a once a week recording may be better off
with an allowable range for normal operating conditions.
LINN Comments: DNR's point is well taken, but in this particular case the facility has continuous
monitoring for differential pressure and scrubber flows for most of its air pollution controls. The
expanded range is appropriate because the facility captures differential pressure over a much wider
range of operating conditions. Common operating conditions that expand the differential pressure
range include bag replacement and the use of a variable frequency drives to balance airflow with
process demand. This is not unique the Cargill. Many Title V sources request expanded differential
pressure drop ranges due to the risk of incurring reportable deviations for conditions that are outside
of the "normal range", but not necessarily indicative of improper operation.
DNR Response: Compliance monitoring is always a case by case decision based on the equipment and
operational needs of the company. DNR generally addresses slight exceedances of normal operational
parameters through the use of averaging times instead of larger range of limits or reduced frequency of
monitoring. The average time allows for short term fluctuations but does not set such a large range that
compliance is not certain, nor allow the company to only record values infrequently that are within range.
DNR does want companies to notice that there might be operational issues occurring and check into it. Ranges
may need to be adjusted as more understanding occurs on normal equipment operation.
No changes made to the Final Report.
Attachment C: Staff Training Summary SFY 2019
LINN Comment: Linn corrected one of the training course entries to indicate that an additional staff
member attended the course.
DNR Response: DNR has made the correction in the Final Report.
28
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PSD PUBLIC PARTICIPATION CHECKLIST
Public participation is a requirement under the Prevention of Significant Deterioration (PSD) program.
This checklist is provided in order to ensure we meet our obligations under 567 IAC 33.3(17), our work
plan with EPA, and our internal requirements. Do not use this checklist for PSD permit rescissions.
Preliminary Determination
1. Notify the applicant(s) within thirty (30) days as to the completeness of the application or any
deficiency in the application or information submitted. In the event of a deficiency, the date of
receipt of the application shall be the date on which all required information is received.
2. Email a copy of the application to EPA for review, or upload to the website in Step 4(j) and send
them the link.
3. Within one (1) year after receipt of a complete application, make a preliminary determination as
to whether construction should be approved or disapproved.
Public Comment Period
4. If the application is approved:
(a) Email a copy of all materials submitted by the applicant, a copy of the preliminary
determination (draft permits. Technical Support Document/Fact Sheet, etc.), and a copy
of other materials, if any, considered in making the preliminary determination to EPA
Region VII. For large files, you can upload them to the Iowa DNR public comment
search page (see Step 4(g)). EPA must receive all materials at least ten (10) days prior
to the start of the public comment period.
(b) Set the beginning date and the ending date of the public notice period. The period
must begin on or after each Thursday (the day EcoNewsWire is published) of every
week. At least thirty (30) days shall be provided for the public comment period and for
notification of the public hearing, if any
(c) Notify the public by using the EcoNewsWire. Send the EcoNewsWire notification to
Jason Dowie by the end of the Tuesday prior to the start of the public comment period,
with a subject line of "eco-wire news wire notification". If Jason is out of the office,
Don Peterson is the backup. Use the document called Final_Ecowire_Notice found in
the \\iowa.qov.state.ia.us\data\DNR AQ Shared\Con-Perm\Library\General
lnformation\EcoNewsWire as a template for your notification.
(d) Print the relevant pages of the eco-news wire publication for the project file. An
example is the document called ProofofPublication_example found in the
\\iowa.aov.state.ia.us\data\DNR AQ Shared\Con-Perm\Librarv\General
lnformation\EcoNewsWire folder.
(e) Create the notice of public comment document. The notice must contain:
notice of the application
CPDPVPIantVMMDDYYYYVProjecti
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notice of the preliminary determination
notice of the degree of increment consumption that is expected from the source or
modification
notice of the opportunity for comment at a public hearing (if any) as well as written
public comment. You may want to limit comments on modified units to what has
been modified in the permit. If a public hearing will be held, also include where
and when the hearing will be held (usually set towards the end of the public
comment period, to provide 30 days notice). Consider holding the hearing at a
nearby state park, if appropriate facilities are available. If a hearing date is not set
in the original public notice, include a statement that "A request for a public
hearing must be received by [date, usually set halfway into the public comment
period]. If a public hearing is set, you will need to notify the public again.
where additional information on the project may be found (iowacleanair.gov and
the address of the local library (or other location) where the project documents
were sent
notice that any written comments should be sent to you (include both mail and
email addresses).
(f) Make the project documents available for public inspection in at least one location
(usually a public library) where the project will happen. This includes such things as
the public notice, application, draft permits. Technical Support Document/Fact Sheet, a
copy of other materials, if any, considered in the project, etc. If a public computer is
available for use at the location, it's preferable to send a link to the files on our website
for library download, otherwise send a CD or flash drive with the files. Check with the
location prior to sending a link or CD/flash drive that this is okay. If none of those
options is available, or there is little paper involved in the file, send paper copies. The
cover letter/packet must be certified, and should also state the documents only need to
be available until [35 days after ending date of the public comment period].
(g) Send a copy of the notice of public comment to the following - emails are preferable:
the applicant
the Administrator (EPA Region VII)
Field Office
officials and agencies having interest in the location where the proposed
construction would occur as follows:
any other EPA Regional office. State, or local air pollution control agencies
within the impact area, which is generally within 30 miles of the source
(certified. Local programs include Linn and Polk Counties in Iowa, and the
City of Omaha in Nebraska)
City of Omaha - email oaac(5)ci.omaha.ne.us
Illinois - email brad.frost(5)illinois.gov
Minnesota - email Beckie.olson(5)state.mn.us
Missouri - email Kendall.hale(5)dnr.mo.gov
Nebraska - email ndeq.airquality (Snebraska.gov
South Dakota - email airgualitvreporting(5)state.sd.us
Wisconsin - email kristin.hart(5)wisconsin.gov
the chief executives of the city and county where the source would be located
(i.e. mayor, city administrator, board of supervisors, health department, etc.)
(if email addresses are available on city website, email city councilors a copy
as well)
CPDPVPIantVMMDDYYYYVProjecti
-------
any comprehensive regional land use planning agency (website address is
http://www.iarcoa.com/FindCOG.htm)
any State Land Manager whose lands may be affected by the emissions from
the source or modification
any Federal Land Manager whose lands may be affected by the emissions
from the source or modification (certified)
any Indian Governing body whose lands may be affected by the emissions
from the source or modification (certified. Indian Governing bodies could
include the Omaha, Winnebago, and Meskwaki tribes)
Meskwaki Nation - email director.mdnr@meskwaki-nsn.aov
Coordinator.mdnr@meskwaki-nsn.aov
(h) Email a copy of the notice to Air Quality managers and Air Quality attorneys.
(i) Upload public comment documents (public comment notice, draft permits. Technical
Support Document/Fact Sheet, correspondence, etc) to the website at
https://proarams.iowadnr.aov/airaualitvconstructionpermits/Paaes/Common/Loain.asp
x
(j) Print the screen shot of the webpage containing the public comment documents
available on the web for your project. Note that you will need to be in Google Chrome
rather than Internet Explorer. The webpage screen shot containing the document date
located in the upper right hand corner must be printed prior to the start of the public
comment period.
(k) If you schedule a public hearing, email Jason Dowie a request to post the public
hearing on the website in the email subject line. Include the subject of the meeting, the
date, the start time and expected end time, the location, a brief description of the
meeting, and any relevant web sites/links for information concerning the project in the
email. You can attach a copy of the public notice to the email as well. You will need to
specify that the public hearing should be placed on the state calendar as well as the
DNR/AQB calendar.
(I) If, after consultation with management, the public notice is printed in newspapers,
email a copy of the public notice to a newspaper of general circulation in each region
in which the proposed source would be constructed. Ensure that the date the notice is
published falls on or before the start of the public notice. Department policy is to
publish the notice in the following:
Des Moines Register*, Legal Publications, email to legals@dmreg.com
Legal Publications of local paper with largest circulation
*The Gannett Company (Des Moines Register, etc) requires payment at the time the
order is placed. You will need to either transfer the newspaper representative to
Norma Gentry if using a phone to place the order, or copy her on the email to the
newspaper.
** Tear sheets should be sent to Norma Gentry.** (ask newspaper to notify you if the
legal notice will cost more than $50 before publishing)
(m) If you print a public notice in a newspaper, add one hour in the project tracker database
under "Technical Review Phase" to account for public notice costs for the public
comment period.
Final Determination/Project Administration
CPDPVPIantVMMDDYYYYVProjecti
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5. At the end of the 30 day public notice period (plus about 2-3 days to ensure nothing is coming
in the mail), make a final determination on whether construction should be approved or
disapproved.
(a) Consider all written comments submitted during the dates specified in the notice of
public comment and all comments received at the public hearing(s) in making a final
decision on the approvability of the application. Write a response to all comments
received letter (or a letter that no comments were received).
(b) Notify applicant in writing of the final determination. Also, send a copy of the
response to comments to applicant. Include the Polk County local program if the
facility is located there.
(c) Notify EPA Region VII of the final determination. Also, email a copy of the response to
comments and final permits to EPA Region VII.
(d) Send a copy of the response to comments to anyone other than the applicant and EPA
Region VII that commented during the public comment period.
(e) Make all comments received and final determination notification available for public
inspection at the same location(s) where the preconstruction information relating to
the source were made available, (by certified letter). Include a date after which the
information no longer needs to be available (usually 35 days after it's mailed).
(f) Upload the final determination (cover letter, response to comments, final permits, etc.)
to
https://proarams.iowadnr.aov/airqualityconstructionpermits/Paaes/Common/Loain.asp
x. Place all the project files on the N drive
(Wiowa.gov.state.ia.us\data\DNR_AQ_Shared\Con-Perm\public comment permits/facility
number/projectnumber).
(g) Enter BACT determinations into RACT/BACT/LAER Clearinghouse.
CPDPVPIantVMMDDYYYYVProjecti
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PUBLIC NOTICE CHECKLIST (Non-PSP)
This checklist is provided in order to ensure we meet our obligations under 567 IAC 22.2(2), Public
notice and participation.
1. Set the beginning date and ending date of the 30-day public notice period. The period must
begin on or after the Thursday that the notice is published on the EcoNewsWire. If the notice is
published in a newspaper as well, the beginning date must also be on or after the date the
notice is published in the newspaper: You will need to find out from the newspaper when the
notice will be published after it is emailed to them.
(a) The public notice must contain:
notice of the application
notice of the preliminary determination
notice of the SIP, Consent Decree or other legal requirements that are being met by
the
project.
notice of the opportunity for comment at a public hearing (if any) as well as written
public comment. If a public hearing will be held, also include where and when the
hearing will be held (usually set towards the end of the public comment period, to
provide 30 days notice for the hearing). Consider holding the hearing at a nearby
state park, if appropriate facilities are available. If a hearing date is not set in the
original public notice, include a statement that "A request for a public hearing
must be received by [date, usually set halfway into the public comment period for
non-SIP projects and at the end of the public comment period for SIP projects]. If a
public hearing is set as a result of a request, you will need to notify the public
again and allow 30 days notice for the public hearing if it is a SIP project,
where additional information on the project may be found (iowacleanair.gov and
the address of the local library (or other location) where the project documents
were sent
notice that any written comments should be sent to you (include both mail and
email addresses).
2. Notify the public by using the EcoNewsWire. Send the EcoNewsWire notification to Jason
Dowie by the end of the Tuesday prior to the start of the public comment period, with a subject
line of "eco-wire news wire notification." If Jason is out of the office, Don Peterson is the
backup. Use the document called Final_Ecowire_Notice found in the
\\iowa.aov.state.ia.us\data\DNR AQ Shared\Con-Perm\Library\General
lnformation\EcoNewsWire as a template for your notification.
(a) A SIP public notice, (or other non-PSD projects after consultation with management),
shall also be published in a local newspaper of general circulation in the region in
which the project will happen. You will need to email the public notice to the Legal
Publications section of the newspaper*
*The Gannett Company (Des Moines Register, etc.) requires payment at the time the
order is placed. You will need to either transfer the newspaper representative to
CPDPVPIantVMMDDYYYYVProjecti
-------
Norma Gentry if using a phone to place the order, or copy her on the email to the
newspaper.
** Tear sheets should be sent to Norma Gentry.** (ask newspaper to notify you if the
legal notice will cost more than $75 before publishing).
(b). Upload public comment documents (public comment notice, draft permits. Technical
Support Document/Fact Sheet, correspondence, etc) to the website at
https://proarams.iowadnr.aov/airqualityconstructionpermits/Paaes/Common/Loain.asp
x
(c) Print the screen shot of the webpage containing the documents available on the web
for your project. Note that you will need to be in Google Chrome rather than Internet
Explorer to print the screen shot. The webpage screen shot containing the document
date located in the upper right hand corner must be printed prior to the start of the
public comment period.
(d). Print the relevant pages of the eco-news wire publication for the project file. An
example is the document called ProofofPublication_example found in the
\\iowa.aov.state.ia.us\data\DNR AQ Shared\Con-Perm\Librarv\General
lnformation\EcoNewsWire folder.
(e). Send copies of the public notice to any person or organization which has expressed an
interest in the project. For SIP projects, ask Program Development if these additional
notifications are necessary.
(f) Make the project documents available for public inspection in at least one location
(usually a public library) where the project will happen. This includes such things as
the public notice, application, draft permits. Technical Support Document/Fact Sheet, a
copy of other materials, if any, considered in the project, etc. If a public computer is
available for use at the location, it's preferable to send a link to the files on our website
for library download, otherwise send a CD or flash drive with the files. Check with the
location prior to sending a link or CD/flash drive that this is okay. If none of those
options is available, send paper copies. The cover letter/packet must be certified, and
should also state the documents only need to be available until [35 days after ending
date of the public comment period].
(g) If you print a public notice in a newspaper, add one hour in the project tracker database
under "Technical Review Phase" to account for public notice costs for the public
comment period.
(h) If you schedule a public hearing, email Jason Dowie a request to post the public
hearing on the website in the email subject line. Include the subject of the meeting, the
date, the start time and expected end time, the location, a brief description of the
meeting, and any relevant web sites/links for information concerning the project in the
email. You can attach a copy of the public notice to the email as well. You will need to
specify that the public hearing should be placed on the state calendar as well as the
DNR/AQB calendar.
CPDPVPIantVMMDDYYYYVProjecti
-------
3. At the end of the 30 day public notice period (plus about 2-3 days to ensure nothing is coming
in the mail)
(a) Make all comments received and final determination notification available for public
inspection at the same location(s) where the preconstruction information relating to
the source were made available, (by certified letter). Include a date after which the
information no longer needs to be available (usually 35 days after it's mailed).
(b) Upload the final determination (cover letter, response to comments, final permits, etc.)
to
https://proarams.iowadnr.aov/airqualityconstructionpermits/Paaes/Common/Loain.asp
x. Place all the project files on the N drive
(Wiowa.gov.state.ia.us\data\DNR_AQ_Shared\Con-Perm\public comment permits/facility
number/projectnumber).
CPDPVPIantVMMDDYYYYVProjecti
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ATTACHMENT C: Completed Title V Questionnaire
Returned by IDNR prior to Audit.
[ see the attached copy ]
202
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Title V Program
Self-Evaluation
Questionnaire
Iowa Department of Natural Resources
Air Quality Bureau
July 6, 2021
1
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Instructions for completing the
Title V Permit Program
Self-Evaluation Questionnaire
• When answering Yes or No questions, please add an explanation as appropriate to
clarify your response.
• Please skip any sections of the self-evaluation questionnaire that do not apply within
your permitting jurisdiction rather than answering hypothetically.
• If you have a written policy or guidance document that substantially answers any
question in this self-evaluation questionnaire, please indicate and either attach a
hardcopy to your response or point to a specific URL on your public web server
where the document may be found.
• This self-evaluation questionnaire was developed by EPA Headquarters and
Regions to assist in the agency's Title V oversight program. As part of its peer
review process, EPA sought review and comment from STAPPA-ALAPCO. While
this questionnaire has undergone a makeover from the original, the scope and detail
of the questions asked remains the same for all agencies.
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Table of Contents
Table of Contents 3
A. Title V Permit Preparation and Content 4
B.General Permits 10
C.Monitoring 11
D.Public Participation and Affected State Review 12
Public Notification Process 12
Public Comments 13
EPA 45-day Review 15
Permittee Comments 15
Public Hearings 16
Availability of Public Information 16
Affected State Review and Review by Indian Tribes 20
E.Permit Issuance / Revision / Renewal 21
Initial Permit Issuance 21
Permit Revisions 22
Permit Renewal or Reopening 24
F.Compliance 29
G.Resources & Internal Management Support 35
Environmental Justice Resources 41
H.Title V Benefits 42
I.Good Practices not addressed elsewhere in this questionnaire 49
Small Source Operating Permits 49
Trello Data Visualization Board 49
J.EPA assistance not addressed elsewhere in this questionnaire 51
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A.Title V Permit Preparation and Content
Please note - additional documents referenced in some answers are available in the Iowa
Title V Program Review Google Drive folder.
1. What % of your initial applications contained sufficient information so the permit
could be drafted without seeking additional information? What efforts were taken to
improve the quality of applications if this % was low?
We do not have statistics on the percentage of initial applications that contained
sufficient information. However, as described in Question E.19 below, we do have
statistics for 2020 - current. We received 79 initial and renewal applications during
this time deeming 13 of 79 (16%) applications to be incomplete. Through the years,
we have strived to improve the quality of application through training for permittees
and continuous improvements to our application forms. Furthermore, the
implementation of Iowa EASY Air has improved the quality of applications as the
system includes mandatory data fields and data validation, which prevents the
submission of applications with missing or invalid information.
2. For those title V sources with an application on file, do you require the sources to
update their applications in a timely fashion if a significant amount of time has
passed between application submittal and the time you draft the permit? Yes.
a. Do you require a new compliance certification? Yes.
3. Do you verify that the source is in compliance before a permit is issued and if so,
how?
Yes. Our information requests to other sections help document any non-compliance
issues, active construction projects or known issues. The permit writer follows up
with the compliance section prior to permit issuance as a last check of recent
compliance issues. This is part of our review manual and review checklist for drafting
Title V permits. Copies of the review manual and checklist are also available in the
Iowa Title V Program Review Google Drive folder.
a. In cases where the facility is out of compliance, are specific milestones and dates
for returning to compliance included in the permit, or do you delay issuance until
compliance is attained? Yes. We have done both in the past. It depends on the
situation and the length of time the delay in the issuance of the permit will be.
4. What have you done over the years to improve your permit writing and processing
time?
• We have a defined training plan for new employees. We have used the Kaizen process
and value stream mapping several times to review our permitting process and make
improvements. These events resulted in changes to our application forms and
refinements of our permit review process:
• October 2016 Process Improvement - Representatives from manufacturing, grain
processing and utilities participated in a four-day event to improve the Title V permitting
process. Six key deliverables were identified and addressed:
• Offer optional pre-application meetings to provide hands-on assistance with the
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application (addressed in 2017 with stakeholder assistance)
• Offer optional post-application meetings to speed permit issuance ((addressed in 2017
with stakeholder assistance))
• Simplify application forms to reduce unnecessary duplicative information requested in
application ((addressed in 2017 with stakeholder assistance))
• Clarify critical application elements to make it easier for businesses to provide needed
information (completed within 30 days)
• Use business data outputs to reduce duplication (completed within 30 days)
• Reduce lag time by streamlining data sharing between air quality sections (completed
within 30 days)
• August 2017 - after considerable input from stakeholders, DNR revised more than 20
forms to improve the Title V Operating Permit application process.
We also have a review manual and review check sheet to aid permit writers in the
process of drafting Title V permit. There are a large number of templates used in
drafting the Title V permit to promote a consistent final product and speed the permit
writing process. Since the inception of the Title V section, we have promoted innovation
and a team spirit. We do not need formal events to correct any issues identified in our
processes. Once an issue is identified, we brainstorm on solutions and implement the
change as soon as possible. These changes in processes are passed along to all
permit writers and documented in our review manual.
5. Do you have a process for quality assuring your permits before issuance? Please
explain.
Yes. An Environmental Specialist Senior reviews all draft permits before they are
sent to the facility for facility review. After the Senior Review is complete, the permit
writer makes any corrections, and then a draft of the permit is sent to the facility for
review. The permit is prepared for public notice after any acceptable corrections
suggested by the facility are incorporated. It is our intention that the draft permit on
public notice is as close to what the final permit will be as possible.
6. Do you utilize any streamlining strategies in preparing the permit such as:
a. Incorporating test methods, major and minor New Source Review permits,
MACTs, other Federal requirements into the Title V permit by referencing the
permit number, FR citation, or rule? Explain.
Yes. Federal standards adopted into Iowa rules as well as federal standards
under litigation or not incorporated into our state rules are referenced using a
general citation paragraph for the rule. Links to the Federal Register notice for
the final rule are included in the appendix of the Title V permit.
b. Streamlining multiple applicable requirements on the same emission unit(s) (i.e.,
grouping similar units, listing the requirements of the most stringent applicable
requirements)? Describe.
Our Title V permits are customized to each facility. When it is appropriate, we will
combine like sources subject to similar conditions into tables in the Title V permit.
If using tables for large groups of sources makes it difficult to understand,
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implement and comply with the Title permit requirements, we will look for
alternatives such as breaking the tables up into small groups or reformatting
them to improve clarity. We issued the first Title V permit using tables to
consolidate similar emission sources in 2001 to Vermeer Manufacturing. At that
time, the facility had 347 emission units and their initial Title V permit (99-TV-052)
was 600 pages long. They applied for a modification to add new equipment and
remove old equipment, and the assigned permit writer identified dozens of the
Vermeer's units (e.g. flame cutters, plasma cutters, welders, etc.) that were of
identical size and subject to the same emission requirements. She developed a
new format to list the equipment in the Title V permit in tables of equipment
groups. This reduced the Vermeer Title V permit (99-TV-052-M001) to 159 pages
and made it much easier for the facility, public, and field office inspectors to read.
For large facilities that have multiple functional groups supervised by multiple
individuals, we have issued separate Title V permits to each functional group. An
example would be the universities with power plant operations and campus
operations. The intent is to aid in compliance with the permit conditions by
breaking the permit up so that each facility manager is responsible for the
operations they have control over.
c. Describe any other streamlining efforts.
Title V Fee Portal
In 2020, the DNR introduced a new payment portal for Title V annual emission
fees. Facilities now have the convenience of paying Title V emissions fees
online. The online portal utilizes a secure, industry compliant payment page
provided by US Bank's Elavon payment processing division. The fees can be
paid by credit card or electronic check. Credit card and bank account information
is encrypted and is never stored in DNR IT systems. No login is required, and no
additional paperwork is necessary. No Form 5.0 is required as the emissions
information is provided by State and Local Emissions Inventory System (SLEIS).
DNR still accepts payments by mail, but the mail process is not as streamlined as
the electronic portal as a paper signed Form 5.0 must accompany each check
that is mailed in from SLEIS.
Iowa EASY Air
On December 5, 2019, the DNR introduced a new online permit application
system called Iowa EASY Air (Environmental Application SYstem) for air quality
permit applications. A fact sheet explaining the history of Iowa EASY Air is saved
in the Iowa Title V Program Review Google Drive folder. The many benefits of
using Iowa EASY Air to submit Title V permit applications include:
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• Less data entry. Existing emission points, emissions units and control equipment
are prefilled for applicants' convenience.
• Accurate data. Guided data entry limits errors and missing data. Built-in data
validation helps industries submit accurate, complete applications.
• Streamlines permitting process. Accurate, complete applications cut down time
spent calling and emailing between facility, consultant and DNR—speeding the
permitting process. While paper applications are still accepted, DNR must enter
the data and verification may involve extra steps, slowing the permit issuance.
• Online fee payment. Three options available for paying online.
• Saves time and money. Submitting applications online reduces the facility's
internal handoffs and time spent collecting signatures.
• Data sharing. When data is shared between construction permits and operating
(Title V) permits, applying for or modifying a permit is easier.
• Inventorying and reporting emissions will be streamlined, too, as SLEIS data is
automatically updated when permits are modified or added.
DNR has done extensive marketing of Iowa EASY Air to facility users, and it has
high usage rates. The most recent statistics for Title V applications are below in
Table 1:
Table 1: Title V permit applications: (12-month rolling total ending June 24)
Submittal Method
Initial & Renewal
Applications
Minor & Significant
Modifications
Total
Iowa EASY Air
85%
48%
65%
Paper
15%
52%
35%
Iowa EASY Air
(current month only)
100%
75%
80%
In 2021, DNR staff conducted an extensive engagement survey of Iowa EASY
Air users and facilities that chose not to use Iowa EASY Air. A copy of the survey
results is saved in the Iowa Title V Program Review Google Drive folder, but in
summary:
• Of first-time users, 70% gave Iowa EASY Air a rating of "7 - Very Satisfied" to
"10 - Extremely Satisfied".
• All Iowa EASY Air users indicated that they would be willing to continue to
use Iowa EASY Air for their next permit application.
• Comments from the survey included:
o "Painless and much easier than anticipated. Tutorials were good."
o "I liked the EASY Air system. Particularly the validation part to check and
make sure all the forms were there and complete."
o "Fastest way to get a permit."
1. What do you believe are the strengths and weaknesses of the format of the permits
(i.e. length, readability, facilitates compliance certifications, etc.)? Why? The format
of our permits continuously evolves as new regulations are promulgated and we
receive feedback from facilities. We think our current format is a good balance
between making the permits as succinct as possible while including all applicable
requirements to which a facility is subject.
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8. How do you fulfill the requirement for a statement of basis? Please provide examples.
Our statement of basis is the combination of our fact sheet and our permit writer
notes, and we title them as "Fact Sheet". This combination was done at the
recommendation of EPA in its 2005 review of our Title V program. Fact sheets for
permits currently on public notice may be found on our Title V Draft & Final Permits
website and in the Iowa EASY Air Public Inquiry Portal. We use various fact sheet
templates (aka Statements of Basis) that differ by situation - initial permit, renewal,
subject due to NESHAP or NSPS only, significant modification, etc. The most
frequently used fact sheet template is for renewals.
9. Does the statement of basis1 explain?
a. The rationale for monitoring (whether based on the underlying standard or
monitoring added in the permit)? Yes.
b. Applicability and exemptions, if any? Yes.
c. Streamlining (if applicable)? We often streamline the permits by switching the
format of the permit from listing every emission source individually into a tabular
format that lists similar or like emission sources with similar emission
requirements in tables. If we make this formatting change, we do not specifically
point this out in the statement of basis. See Question A.6.b for more information
about the tabular format.
10. Do you provide training and/or guidance to your permit writers on the content of the
statement of basis? Yes.
11. Do any of the following affect your ability to issue timely initial title V permits:
a. SIP backlog (i.e., EPA approval still awaited for proposed SIP revisions?) No.
b. Pending revisions to underlying NSR permits Yes - occasionally - see answer to
Question D.22.
c. Compliance/enforcement issues Yes - occasionally - see answer to Question
D.22.
d. EPA rule promulgation awaited (MACT, NSPS, etc.) No.
e. Issues with EPA on interpretation of underlying applicable requirements No.
f. Permit renewals and permit modification (i.e., competing priorities) Yes -
occasionally - see answer to Question D.22.
g. Awaiting EPA guidance? No.
i. If yes, what type of guidance? Not applicable.
ii. If yes, have you communicated this to EPA? Not applicable.
A. If yes, how did you request the guidance? Not applicable.
B. If yes, please specify what type of EPA guidance, and how you requested the
guidance? Not applicable.
12. Any additional comments on permit preparation or content?
1 The Statement of Basis sets forth the legal and factual basis for the permit as required by 70.7(a)(5).
The permitting authority might use another name for this document such as Technical Support Document,
Determination of Compliance, Fact Sheet.
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The Title V section strives to issue high quality, technically correct permits in a timely
fashion. The section is currently fully staffed and has a strategy in place to issue
permits within 9 months of being assigned to a permit writer. We are continuously
working to improve our permit writing process, improve Iowa EASY Air, and improve
the public notice process.
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B.General Permits
The Iowa DNR does not issue General Title Permits. We have a section that covers
general permits in our Iowa Administrative Code under 567 IAC 22.109, but have never
implemented it. We do offer Small Source Operating Permits as described in section I of
this document below.
1. Do you issue general permits? No.
a. If no, go to next section
b. If yes, list the source categories and/or emission units covered by general
permits.
2. In your agency, can a title V source be subject to multiple general permits and/or a
general permit and a standard "site-specific" Title V permit?
a. What percentage of your title V sources have one or more general permits?
%
3. Do the general permits receive public notice in accordance with 70.7(h)?
a. How does the public or regulated community know what general permits have
been written? (E.g., are the general permits posted on a website, available upon
request, published somewhere?)
4. Is the 5-year permit expiration date based:
a. On the date the general permit is issued?
b. On the date you issue the authorization for the source to operate under the
general permit?
5. Any additional comments on general permits?
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C. Monitoring
1. How do you ensure that your operating permits contain adequate monitoring (i.e.,
the monitoring required in §§ 70.6(a)(3) and 70.6(c)(1)) if monitoring is not specified
in the underlying standard or CAM? Our permit writers evaluate the adequacy of
monitoring in the Title V permit by following DNR rules under 567 IAC 22.108(3) and
DNR's Periodic Monitoring Guidance. In situations where the associated
construction permit (such as a permit for a paint booth) contains an operating limit
that does not have sufficient monitoring requirements, we may add extra
recordkeeping and/or reporting.
a. Have you developed criteria or guidance regarding how monitoring is selected for
permits? If yes, please provide the guidance. Yes. The guidance is available at
https://www.iowadnr.gov/portals/idnr/uploads/air/insidednr/operpermit/tv periodic
monitoring.pdf
2. Do you provide training to your permit writers on monitoring? (e.g., periodic and/or
sufficiency monitoring; CAM; monitoring QA/QC procedures including for CEMS; test
methods; establishing parameter ranges) Yes. We provide initial training during the
first six months of employment, then provide additional training throughout the year
as questions arise.
3. How often do you "add" monitoring not required by underlying requirements? Have
you seen any effects of the monitoring in your permits such as better source
compliance? We include additional monitoring requirements in almost every Title V
permit that includes control equipment. When transitioning from initial permits with
Agency O&M plans to renewals that include CAM, many facilities find the change
relatively seamless since they have already been doing the monitoring for five years.
The primary difference between the monitoring in initial Title V permits versus
renewal Title V permits is the frequency of measurements typically increases. While
we do not have a clear correlation between compliance and additional monitoring,
anecdotally, we have seen an improvement in compliance.
4. Are you incorporating CAM monitoring into your permits? Yes. We also provide
permittees with specific CAM instructions2 and CAM Calculation spreadsheet to help
determine CAM applicability.
2 Starting on p. 71 of 77.
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D.Public Participation and Affected State Review
Public Notification Process
1. Do you publish notices on proposed title V permits in a newspaper of general
circulation? No, we historically published notices for one day in the local newspaper,
but in approximately April 2018 we stopped doing this and switched to electronic
public notices as described in Question D.2 below.
2. Do you use a state publication designed to give general public notice? The public
notices are sent out on our EcoNews environmental media subscriber list of more
than 37,500 and on our Air Quality Technical Listserv that has a subscriber list of
more than 22,000.
3. On average, how much does it cost to publish a public notice in the newspaper (or
state publication)? Not applicable - we no longer publish notices in newspapers.
4. Have you published a notice for one permit in more than one paper? No.
a. If so, how many times have you used multiple notices for a permit? Not
applicable.
b. How do you determine which publications to use? Not applicable.
c. What cost-effective approaches have you utilized for public publication? Not
applicable.
5. Have you developed a mailing list of people you think might be interested in title V
permits you propose? [e.g., public officials, concerned environmentalists, citizens]
We currently do not have an active mailing list, but did have one in the past. We
encourage interested parties to subscribe to the Air Quality Technical Listserv to
receive public notices via the EcoNews instead of maintaining a separate mailing
list.
a. How does a person get on the list? Anyone can subscribe to the Air Quality
Technical Listserv via our website or by contacting Wendy Walker at
wendy.walker@dnr.iowa.gov.
b. How does the list get updated? Subscriptions are updated upon request.
c. How long is the list maintained for a particular source? Subscribers remain active
until they specifically unsubscribe from the list.
d. What do you send to those on the mailing list? In addition to public notices, Air
Quality Bureau (AQB) technical staff and COM staff make regular contributions to
send targeted emails regarding air quality issues, information on DNR's
electronic reporting services, and options for public participation.
6. Aside from publications described above, do you use other means of public
notification? If yes, what are they (e.g., post notices on your webpage, e-mail)?
Yes. Public notices and materials are also available on the Iowa EASY Air Public
Inquiry Portal and on the Title V Draft & Final Permit website.
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7. Do you reach out to specific communities (e.g., environmental justice communities)
beyond the standard public notification processes? Not at this time.
8. Do your public notices clearly state when the public comment period begins and
ends? Yes. The dates are clearly stated in public notice document, on the website,
and on the Iowa EASY Air Public Inquiry Portal. The public notice materials
automatically disappear from the portal when the public notice comment period
ends.
9. What is your opinion on the most effective avenues for public notice?
a. Are the approaches you use for public notice effective? We believe our current
public notice practices are effective and reach a much wider audience than
printing a one-day notice in the newspaper. However, we are always looking for
ways to improve our processes.
10. Do you provide notices in languages besides English? Not at this time. However,
the AQB permitting supervisors met with staff from DNR's Communications Bureau
in May 2021 to brainstorm how to address this issue. We are currently researching
how other states and other State of Iowa posting issues in other languages. We are
also researching the cost and availability of translation services.
Public Comments
11. Have you ever been asked by the public to extend a public comment period? Yes.
a. If yes, did you normally grant them? Yes.
b. If not, what would be the reason(s)?
12. Has the public ever suggested improvements to the contents of your public notice,
improvements to your public participation process, or other ways to notify them of
draft permits? Describe. No.
13. Do you provide the public a copy of the statement of basis if they request it? If not,
explain.
Yes, we will email it to them upon request. As mentioned above, it is also available
on the Title V Draft & Final Permits website and is available on the Iowa EASY Air
Public Inquiry Portal.
14. What percentage of your permits have received public comments? It is quite rare
for the public to comment on our permits. We have received citizen comments on
less than 1% of all issued Title V permits. Staff can recall receiving public comments
on the following five permits as shown in Table 2:
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Table 2: Public Comments on Draft Title V Permits
Year
Facility Name
Type(s) of Comments
1998
IPL - Lansing Generating Station
citizen comments on odor and particulate matter
deposition
1999
Snap-On Tools Manufacturing
citizen asking general air quality and compliance
questions
2012
IPL - Burlington Generating Station
comments on level of monitoring, and stringency/
enforceability of emission limits, level of monitoring
2015
Climax Molybdenum
citizen comments on odor, effects on wildlife, and
health concerns
2020
University of Iowa
citizen comments on health effects and climate change
15. Over the years, has there been an increase in the number of public comments you
receive on title V permits? Is there any pattern to types of sources getting
comments? We have not seen an increase in the number of public comments. Three
of five facilities that received public comments as shown in Question D.14 had coal-
fired boilers at the time the comments were received.
16. Have you noticed any trends in the type of comments you have received? Please
explain. It is hard to discern a pattern when less than 1% of draft permits receive
public comments. Of the five facilities discussed above in Question D.14, two of the
five facilities received comments on odor and two facilities received comments
pertaining to the health effects of air pollution.
a. What percentage of your permits change due to public comments?
Few, if any, as the many of the handful of citizen comments received have not
pertained directly to requirements in the Title V permit.
17. Have specific communities (e.g., environmental justice communities) been active in
commenting on permits? Not particularly. However, the 2012 comments on IPL -
Burlington Generating Station draft permit were organized by the Sierra Club, and
the 2020 comments on the University of Iowa draft permit were organized by the
Iowa Climate Strike group.
18. Do your rules require that any change to the draft permit be re-proposed for public
comment? No.
a. If not, what type of changes would require you to re-propose (and re-notice) a
permit for comment? If the changes rise to the level of a significant modification,
the permit will be re-noticed for those changes. In general, changes have not
required re-notice and are documented in the proposed Title V permit and
responsive summary that is sent to all commenters. We issue the final Title V
permit once EPA approves the changes.
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EPA 45-day Review
19. Do you have an arrangement with the EPA region for its 45-day review to start at
the same time the 30-day public review starts? What could cause the EPA 45-day
review period to restart (i.e., if public comments received, etc.)? Yes. If EPA
requests their full 45 days, we wait the extra time before proposing the permit and
then issuing the final permit.
a. How does the public know if EPA's review is concurrent? It is stated in our public
notice. Here is an example of the language in the public notice:
"The public comment period for the draft permit will run from May 6, 2021 through June 5, 2021.
During the public comment period, anyone may submit written comments on the permit. Mail signed
comments to Taylor Dailey at the DNR address shown above. The beginning date of this public
comment period also serves as the beginning of the U.S. Environmental Protection Agency's (EPA)
45-day review period, provided the EPA does not seek a separate review period."
20. is this concurrent review process memorialized in your rules, a MO A or some other
arrangement? We have a verbal understanding with EPA Region 7.
Permittee Comments
21. Do you work with the permittees prior to public notice? Yes. Our process is to
inform the facility when we start the technical review of the application. This
introduces them to the assigned permit writer and asks if any changes have taken
place since the application was submitted. Usually, if questions arise during the
permit review, the permit writer will get in contact with the facility. Once the draft is
complete, it is sent to the facility for review. Our default timing is 15 days, but we will
extend that when requested.
22. Do permittees provide comments/corrections on the permit during the public
comment period? Any trends in the type of comments? How do these types of
comments or other permittee requests, such as changes to underlying NSR permits,
affect your ability to issue a timely permit?
Yes. We receive very few comments from permittees during the public notice period
because we provide the facility with a facility review period prior to public notice. The
comments we receive from permittees typically focus on typographical errors,
periodic monitoring requirements, odor, and questions on construction permit
conditions. If a facility has a pending NSR permit or other construction permit
pending, we will work with the facility and our construction permitting section to
evaluate and determine if it would be advantageous to delay issuance of the Title V
permit until the NSR or construction permits are issued.
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Public Hearings
23. What triggers a public hearing on a title V permit? Public hearings may be
scheduled upon written request. However, the request must merit a public hearing.
Our public notice states:
"Written requests for a public hearing concerning the permit may also be submitted during the
comment period. Any hearing request must state the person's interest in the subject matter, and the
nature of the issues proposed to be raised at the hearing. DNR will hold a public hearing upon finding,
on the basis of requests, a significant degree of relevant public interest in a draft permit. Mail hearing
requests to cinsert permit writer's name> at the DNR address shown above."
Staff can only recall holding public hearings for one draft Title V permit. Two
hearings were held in 2015 for the Climax Molybdenum facility. More detail is
provided in the answer to Question D.27.C below.
a. Do you ever plan the public hearing yourself, in anticipation of public interest?
We have not done this so far.
Availability of Public Information
24. Do you charge the public for copies of permit-related documents?
Yes, we charge per the DNR Records Center Schedule of Fees.
If yes, what is the cost per page? We provide estimates of the fee and time required
to complete the request prior to completing the request. Please refer to the DNR
Records Center Schedule of Fees for details. In general, for file search/research,
retrieving /preparation, and copying/scanning, the first hour is free, and then it is $20
per additional hour. The first 10 paper copies are free and then 10 cents per page.
However, the most recent Title V permit for each facility is available on the Title V
Draft & Final Permits website and all Title V permits issued since January 1, 2020
are available in the Iowa EASY Air Public Inquiry Portal. In addition, we are currently
prepping the most recent (previous permit cycle) Title V application and permit paper
documents for scanning and uploading into the new OpenText electronic document
system.
a. Are there exceptions to this cost (e.g., the draft permit requested during the
public comment period, or for non-profit organizations)? There are no exemptions
to the schedule of fees.
b. Do your title V permit fees cover this cost? If not, why not?
Title V fees provide sufficient revenue to cover the cost of Title V and Emission
Inventory staff assisting Records staff with public records requests. Title V and
Emissions Inventory staff report all time spent processing information requests.
Requests for minor sources are tracked to the minor source cost center 7220 and
requests for Title V sources are tracked to the cost center 7230 for Title V
emissions fees. Title V fees provide sufficient revenue to cover the cost of Title V
staff assisting Records staff public records requests.
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25. What is your process for the public to obtain permit-related information (such as
permit applications, draft permits, deviation reports, 6-month monitoring reports,
compliance certifications, statement of basis) especially during the public comment
period?
All construction permitting, stack testing, and compliance documents, including
deviation reports, 6-month monitoring reports, and annual compliance certifications,
are typically scanned and posted on the DocDNA public portal within 60 days of
receipt. This fall DNR will be transferring all documents from DocDNA to the new
Open Text system.
The most recent Title V permit for each facility is available on the Title V Draft &
Final Permits website and all Title V permits issued since January 1, 2020 are
available in the Iowa EASY Air Public Inquiry Portal. In addition, we are currently
prepping the most recent (previous permit cycle) Title V application and permit paper
documents for scanning and uploading into the new OpenText electronic document
system.
Please see our Records Center website for more information on how to submit a
records request.
a. Are any of the documents available locally (e.g., public libraries, field offices)
during the public comment period? Explain.
A hard copy of the public notice is mailed to the local library. The notice includes
information on where the fact sheet and draft permit can be accessed
electronically. A copy of the letter to the library is saved in the Iowa Title V
Review Googled Drive folder.
26. How long does it take to respond to requests for information for permits in the
public comment period? Typically, we can respond to information requests in 24
hours or less. However, Iowa Administrative Code 561 Chapter 2 allows up to ten
days to respond to a request.
27. Have you ever extended your public comment period as a result of information
requests? No.
a. Where is this information stored?
NextRequest is an Iowa Department of Administrative Services open records
system that is used to track all public information requests made to State of Iowa
agencies. Our AQB records staff tracks and logs all public information requests in
the NextRequest and generate a monthly report of public information requests
that is provided to the Supervisor of the AQB Program Development Section for
review.
b. Do information requests, either during or outside of the public comment period,
affect your ability to issue timely permits? No.
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c. Have you ever extended the public comment period because of a request for a
public hearing? Yes, in 2015 we received a petition with 40 citizen signatures
requesting a public hearing for the draft permit for Climax Molybdenum facility.
The original comment period was 03/17/15 - 04/16/15. The public hearing was
held 06/25/15. A second public comment period was required due to the facility's
discovery of 5 sources subject to Part 63 NESHAPs. The second public comment
period was 10/19/2015 - 11/24/2015 and a second public hearing was held
11/24/15.
28. Do you have a website for the public to get permit-related documents? Yes. See
answers for Question D.25.
a. What is available online? See answers for Questions D.25 and D.27.
b. How often is the website updated? Is there information on how the public can be
involved? The website is continuously updated on a regular basis as permits are
placed on public notices. AQB's Public Participation website also includes
information on how the public can be involved.
29. Have other ideas for improved public notification, process, and/or access to
information been considered? If yes, please describe.
Yes. As mentioned above, we are always looking for ways to improve our
processes. We are currently researching ways to provide notices in other languages
(see Question D.10 above) and looking at adding additional language for ADA
accessibility.
30. Do you have a process for notifying the public as to when the 60-day citizen petition
period starts? If yes, please describe. We have not developed a formal process as
we have yet to receive a citizen petition. If we did receive a petition, we would follow
the process outlined in 40 CFR Part 70.
31. Do you have any resources available to the public on public participation (booklets,
pamphlets, and webpages)? Yes. The AQB provides and continuously updates a
public participation website. This site includes information on how to "Make Your
Comments Count", public meetings, workgroups, and other opportunities for public
input.
32. Do you provide training to citizens on public participation or on title V? Not at this
time.
33. Do you have staff dedicated to public participation, relations, or liaison?
Yes. They include:
• Legal and technical specialists who answer specific questions about compliance, and
provide guidance to individuals and businesses on technical issues and new online
applications. They also survey customer satisfaction; answer frequently asked
questions, develop new rules and new online applications. They host public
meetings, and meet with stakeholders at DNR-hosted public meetings, highlight
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display booths and speak at commodity trade shows and meetings.
• Communications and marketing staff who assist with press releases, fact sheets,
web pages, layout and design of publications and displays, communications
planning, and outreach materials. They develop survey instruments to aid in
assessing customer satisfaction or needs, provide advice on handling public
meetings or contentious issues, edit documents to translate them from the scientific
or regulatory to a level understood by the public, including articles for Iowa Outdoors
magazine that take an environmental angle. They work with technical staff to fine-
tune everything from talking points to PowerPoint presentations. The bureau chief or
communications specialist in each topic area responds to media queries on sensitive
issues.
a. Where are they in the organization?
They are located in the DNR Communications, Outreach & Marketing (COM)
Bureau. A copy of the table of organization for the COM Bureau is included in
the Iowa Title V Program Review Google Drive folder.
b. What is their primary function ?
See above answer to Question D.33.a.
In addition, both Air Quality Bureau (AQB) technical staff and COM staff make
regular contributions to send targeted emails through three GovDelivery
products devoted to air quality issues. These products are targeted to specific
customer groups with subscriber lists of more than 22,000 people. Public
notices are sent almost every week alerting subscribers and the public of
permits and soliciting comments on those permits. The public notices are sent
out on our EcoNews environmental media subscriber list of more than 37,500.
COM staff also reach out to the public to inform them of the importance of
good air quality and to provide the tools to assess air quality. For example,
during the recent Air Quality Awareness Week in May, we posted:
• a banner on the DNR homepage
• two news releases to about 37,500 subscribers: Smoky Air? Protect yourself
from wildfires and Low cost air sensors-adding to our knowledge to about
37,500 subscribers:, and
• a blog 6 Ways to Keep Air Healthy resulting in a potential reach of nearly 1.6
million people through traditional news media outlets, resulting in two broadcast
interviews, and open rates of 19 percent (7,397 people) with a 1 percent click-
through rate.
• a Facebook post reaching 13,836 people,
• an Instagram story had 2,047 impressions reaching 1,923 people, and
• a tweet resulting in 2,171 impressions with a potential reach of 24,084.
Furthermore, technical, scientific, legal and support staff in the AQB reach out
to customers on a one-on-one basis every day, including some who regularly
speak at trade group and other stakeholder meetings, providing regulatory
and compliance information to customers, along with the latest updates in our
online technology. Dedicated staff in the Field Office Bureau reach out to
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customers every day, providing down-to-earth explanations on compliance
issues as they conduct inspections, provide technical assistance and respond
to complaints. AQB and Field Office staff both respond to media queries
about technical issues.
Affected State Review and Review by Indian Tribes
34. How do you notify affected States of draft permits? We send affected states an
email that includes the name of the facility, location, date of public comment period,
and a hyperlink to the Title V Draft & Final Permits website where the draft permit,
public notice, and fact sheet are posted.
a. How do you determine what States qualify as "affected States" for your draft
permits? We have identified all our facilities' geographic location and created a
query in our Microsoft Access database that identifies which states are within the
50-mile radius of a particular state's border.
35. How do you notify tribes of draft permits? We have not made specific outreach to
tribes.
36. What percentage of your permits get comments from affected States? from Tribes?
We cannot recall ever receiving any comments from affected states or tribes.
37. Is there any pattern to the type of draft permit that gets affected State / Tribal
comment? Are there common themes in comments from affected States or Tribes?
We cannot recall ever receiving any comments from affected states or tribes.
38. Suggestions to improve your notification process? None at this time.
Any additional comments and public notification?
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E. Permit Issuance / Revision / Renewal
Initial Permit Issuance
1. If not all initial permits have been issued, do you have a plan to ensure your permits
are issued in a reasonable timeframe? If not, what can EPA do to help?
In 2015 DNR developed a Title V Permit Issuance Strategy. A copy of the strategy is
saved in the Iowa Title V Review Google Drive folder. We currently have seven initial
permit applications in house. As shown below in Table 3, six of these applications
are currently being worked on, and we expect to issue them within eighteen months
of receiving them, except for two permits that we are holding to correct compliance
issues. The seventh facility has been mothballed but has not withdrawn its
application.
Table 3: Initial Permit Applications in House as of 07/01/2021
Facility #
Facility Name
Date
Received
Date
Assigned
Current Status
DNR
Issuance
Goal
07-01-107
ConAgra Foods
01/21/20
08/07/20
Public notice completed.
Waiting for construction
permit modification to be
issued to resolve
compliance issues.
05/07/21
14-07-002
Templeton Rye Spirits,
LLC
11/22/19
12/02/19
In technical review.
Waiting for construction
permit modifications to be
issued to resolve
compliance issues.
09/02/20
24-01-035
Continental Carbonic
Products
06/08/20
03/22/20
In senior review.
12/21/21
40-01-011
VanDiest Supply
Company
03/13/20
04/18/20
In technical review.
01/17/21
72-03-002
POET Biorefining -
Ashton
02/06/20
09/29/20
In technical review.
06/29/21
75-05-006
Prairie Sun Foods, LLC
01/02/13
09/10/15
Facility is mothballed.
not
applicable
94-01-015
Gold Bond Building
Products, LLC
08/24/20
09/29/20
Under facility review.
06/29/21
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Permit Revisions
2. Did you follow your regulations on how to process permit modifications based on a
list or description of what changes can qualify for:
Senate File 488 (signed by Governor Branstad on May 15, 2015) granted the
Environmental Protection Commission authority to establish application fees for
construction and operation of air pollution emitting equipment and fees for asbestos
notifications. The Commission adopted rules (567 IAC 30) and a Fee Schedule on
December 15, 2015. The fees became effective on January 15, 2016.
Senate File 488 did not give us the authority to charge hourly fees for Title V
modifications; we can only bill for initial and renewal applications. Therefore, we
have not prioritized issuing modifications since the billable hours rules took effect for
initial and renewal applications submitted on or after 01/15/2016.
Any modifications that we have issued since 01/15/2016 have either been done as a
training tool for staff or done because there was a specific need such as avoiding
non-compliance. Since 01/15/2016, we have issued 102 of the 588 permit
modification requests we have received.
a. Administrative amendment? (See § 70.7(d)(vi)) - Yes - see 567 IAC 22.111.
b. §502(b)(10) changes? (See §70.4(b)(12)) - Yes - see 567 IAC 22.110.
c. Significant and/or minor permit modification? (See §70.7(e)) - Yes - see 567 IAC
22.112 and 22.113.
d. Group processing of minor modifications? - Yes, when issuing a permit we try to
resolve all minor modification requests on file.
3. If the EPA Regional office has formally asked you to reopen a permit, were you able
to provide EPA with a proposed determination within 90 days? (40 CFR 70.7(g)(2))
If not, why not? We have not been formally asked by EPA Region 7 to reopen a
permit.
4. For those permits that have been issued, and where the permitted facility has
undergone a change, how many changes to the title V permit have you processed?
Historically, we have issued 588 total permit modifications.
a. What percentage of changes at the facilities are processed as:
i. Significant -
• As of 06/01/21, we have 17 applications from 14 unique facilities for significant
modifications in house that we are not acting on.
• Historically, we have issued 118 significant permit modifications, which is 20% of all
issued modifications. Only 32 of those 118 have been issued since the billable hours
rules took effect for initial and renewal applications submitted on or after 01/15/16.
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ii. Minor-
• As of 06/01/21, we have 65 applications from 43 unique facilities for minor
modifications in house that we are not acting on.
• Historically, we have issued 286 minor permit modifications, which is 49% of all
issued modifications. Only 53 of those 286 have been issued since the billable hour
rules took effect for initial and renewal applications submitted on or after 01/15/16.
iii. Administrative -
• As of 06/01/21, we have 84 applications from 62 unique facilities in house that we
are not acting on.
• Historically, we have issued 160 administrative permit modifications, which is 27% of
all issued modifications. Only 17 of those 160 have been issued since the billable
hour rules took effect for initial and renewal applications submitted on or after
01/15/16.
b. Of all changes that you have, how many (or what percentages) were:
i. Off-permit - We rarely process off-permit changes. We have issued 24, which
is 4% of all issued modifications. The last off-permit change was issued in
2006.
ii. 502(b)(10) - It is unclear what EPA considers to be the difference between
off-permits and permits issued under 502(b)(10).
5. How many days, on average, does it take to process (from application receipt to final
permit amendment):
a. a significant permit revision?
b. a minor revision?
c. an administrative revision?
This question is not applicable as we are not currently processing permit revisions.
6. Have you taken longer than the part 70 timeframes of 18 months for significant
revision, 90 days for minor permit revisions and 60 days for administrative? Explain.
Yes. See answer to Question E.2 above.
7. What have you done to streamline the issuance of revisions?
See answer to Question E.2 above.
8. What process do you use to track permit revision applications moving through your
system? Historically, we have tracked permit revision applications and processing
milestones in a Microsoft Access database. As use of Iowa EASY Air is currently
voluntary, we continue to receive some paper revision applications. Therefore, as we
transition to using Iowa EASY Air, we use the Access database to track both paper
and electronic revision applications.
9. Have you developed guidance to assist permit writers and sources in evaluating
whether a proposed revision qualifies as an administrative amendment, off-permit
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change, significant or minor revision, or requires that the permit be reopened? If so,
provide a copy. Yes, we have developed a Title V Operating Permit Modification
Quick Reference Sheet that explains the differences between administrative
amendments, minor modifications, and significant modifications. It does not address
off-permit changes as we rarely, if ever, process those. In addition, our application
requires the permittee to identify the type of modification that they are applying for.
10. Do you require that source applications for minor and significant permit
modifications include the source's proposed changes to the permit?
No. We have discussed using this in the past and some facilities will provide a
redline/strikeout version. It can be more work for the permit writer to proofread their
changes than just modifying the previous permit or drafting a new permit.
a. For minor modifications, do you require sources to explain their change and how
it affects their applicable requirements? Yes.
11. Do you require applications for minor permit modifications to contain a certification
by a responsible official, consistent with 70.5(d), that the proposed modification
meets the criteria for use of minor permit modification procedures and a request that
such procedures be used?
Yes. All of our application forms, including the Title V Form EZ MOD require
certification by the responsible official.
12. When public noticing proposed permit revisions, how do you identify which portions
of the permit are being revised? (e.g., narrative description of change, highlighting,
different fonts).
Yes. They are described in the permit writer notes, which are attached to the bottom
of the fact sheet.
13. When public noticing proposed permit revisions, how do you clarify that only the
proposed permit revisions are open to comment? It is mentioned in the last
paragraph of our public notice language:
"DNR will keep a record of the issues raised during the public participation process, and will
prepare written responses to all comments received. The comments and responses will be
compiled into a responsiveness summary document. After the close of the public comment
period, DNR will make a final decision on the application for permit modification. The
responsiveness summary and the final permit will be available to the public upon request."
Permit Renewal or Reopening
14. Have you begun to issue permit renewals? Yes. As of July 1, 2021, we have 269
active issued final Title V permits as listed below in Table 4. A list of these permits is
also included in the Iowa Title V Review Google Drive folder.
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Table 4: Final Title V Permits as of 07/01/2021
Current Version
Number of Permits
Initial
32
Renewal 1
55
Renewal 2
64
Renewal 3
105
Renewal 4
13
Total
269
15. What are your plans for timely issuance of the renewals? We have a detailed
Title V Permit Issuance Strategy. In short, our goal is to issue Title V Permits within
nine months of assignment to the permit writer. The EPA goal is for permits to be
issued within eighteen months of receiving the application. A copy of the strategy is
saved in the Iowa Title V Review Google Drive folder. We currently have twelve
renewal applications in house that are older than eighteen months as shown in
Table 5 below:
Table 5: Renewal Applications older than 18 months
Facility #
Facility Name
Renewal
Type
Date
Received
Current Status
78-01-012
Griffin Pipe Products CO., LLC
Renewal (2)
12/20/11
Facility is
mothballed but
maintaining its
permits.
90-01-023
Praxis Mid America
Renewal (2)
09/07/11
Facility is
mothballed but
maintaining its
permits.
23-01-006
ADM Corn Processing - Clinton
Renewal (1)
06/03/11
ADM will submit
updated application
by 6/30/2022.
68-09-001
Cargill, Inc. - Eddyville, IA
Renewal (1)
04/15/11
Technical Review
94-01-010
Georgia-Pacific Gypsum LLC
Renewal (3)
12/29/16
Holding for
construction
permits to be
issued.
Construction app
submitted
5/21/2021.
88-01-021
ZFS Creston, LLC
Renewal (2)
11/14/16
Technical Review
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Table 5 (continued)
Facility #
Facility Name
Renewal
Type
Date
Received
Current Status
07-02-005
Cedar Falls Municipal Electric
Utility
Renewal (3)
04/25/18
Facility Review
31-01-009
John Deere Dubuque Works
Renewal (3)
12/10/18
Technical Review -
held for nearly a
year waiting for
determination
request sent to EPA
in May 2020, but
decided in Feb.
2021 to proceed.
77-01-045
ADM - Des Moines Soybean
Renewal (2)
10/19/18
Holding while
compliance and
construction
permitting issues
are resolved.
78-01-085
Bunge Corporation
Renewal (3)
10/18/18
Facility Review
82-02-004
Sivyer Steel Castings LLC
Renewal (2)
10/01/18
Facility Review
63-01-001
3M (Minnesota Mining &
Manufacturing Co.)
Renewal (3)
11/08/19
Facility Review
16. Do you have a different application form for a permit renewal compared to that for
an original application? (e.g., are your application renewal forms different from the
forms for initial permits?) No. It is the same process as the initial permit process and
requires a complete resubmittal of all application materials. Using Iowa EASY Air
instead of submitting a paper application should simplify the process. There is some
additional data entry the first time the applicant uses Iowa EASY Air, but it simplifies
the renewal process as the information within the application and any construction
permits are carried forward to the next renewal application.
b. If yes, what are the differences? Are first time requirements (like CAM, off permit
changes, etc.) in a renewal application being included in the renewal? As
discussed in the answer to Question E.16, there are no differences. Yes, first
time requirements such as CAM are included in the renewal.
17. Has issuance of renewal permits been "easier" than the original permits? Explain.
No. We had hoped renewals would be easier, but it has not turned out to be the
case. New regulations that had been promulgated since the initial Title V permits
were issued have introduced delays in the processing of applications. Many required
the creation of new application forms for engines and boilers. As staff have become
more experienced, the identification of issues with applications and past permitting
problems have delayed permit processing. Additional scrutiny by EPA on permit
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limits and recordkeeping have also caused slow-downs. These were warranted as
the comments addressed some past permitting practices that are not adequate in
being practically enforceable. Turnover in both in DNR permit writers and lead
workers as well as permittee environmental professionals has also added to the
problem. Some of the issue just comes down to facilities making lots of changes in
the five-year permit term and not being able to keep the Title V current.
18. How are you implementing the permit renewal process (i.e. guidance, checklist to
provide to permit applicants)?
It is the same process as the initial permit process and requires a complete
resubmittal of all application materials. Using Iowa EASY Air instead of submitting a
paper application should simplify the process. There is some additional data entry
the first time the applicant uses Iowa EASY Air, but it simplifies the renewal process
as the information within the application and any construction permits is carried
forward to the next renewal application.
19. What % of renewal applications have you found to be timely and complete?
It is rare to have a late renewal application, but it does happen. If that happens, we
work with our Compliance Assistance section and the facility to get a complete
application as soon as possible. The Title V permit staff then work to ensure that the
permit renewal is issued before the previous permit expires.
Regarding completeness, we do not have statistics on the total number of renewal
applications that contained sufficient information to be deemed complete. However,
we do have statistics for 2020 - June 7, 2021. We received a 79 initial and renewal
applications during this time period deeming 13 of 79 (16%) as incomplete. There
does not seem to be a clear pattern to why the applications are incomplete. Different
types of information are missing in each application. These include missing
signatures, missing pages of general facility requirements, missing Part 2 forms,
missing insignificant emission units, etc. Applications submitted on paper tend to be
incomplete more often than applications submitted in Iowa EASY Air, as Iowa EASY
Air requires mandatory fields to be completed and data validated prior to
submission.
20. How many complete applications for renewals do you presently have in-house
ready to process? As of June 7, 2021, we have 65 renewal applications in-house
and all have been deemed complete.
21. Have you been able to or plan to process these renewals within the part 70
timeframe of 18 months? If not, what can EPA do to help?
Nine of the 65 renewal applications in-house have exceeded the 18-month timeline.
This is primarily due to the turnover of Title V staff or outstanding compliance issues.
We intend to issue the majority of these permits in the next year. One facility, ADM
Corn Processing - Clinton, is planning to submit an updated application in the next
year. Two of the renewal applications are for mothballed facilities. We are not aware
of any assistance needed from EPA at this time.
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22. Have you ever determined that an issued permit must be revised or revoked to
assure compliance with the applicable requirements?
No, not that we can recall. Some permits have needed modification later if
applicability changed due to a rule change or additional information has been
discovered that affected applicability.
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F. Compliance
1. Deviation reporting:
a. Which deviations do you require to be reported prior to the semi-annual
monitoring report? Describe.
Excess emissions, Continuous Emissions Monitoring deviations (quarterly), and
deviation reporting required by federal regulations (i.e. NESHAP and NSPS),
must be reported prior to the Semi-Annual Monitoring Report (SAMR). Unless
more frequent deviation reporting is specified in the permit, all other deviations
that take place during the reporting period are documented in the SAMR.
Monitoring required under a Title V Permit typically includes, but is not limited to,
recordkeeping, stack testing, visible emissions observations, and operation and
maintenance (O&M) plans.
b. Do you require that some deviations be reported by telephone?
Title V Permit General Condition G14: Written Reporting of Excess Emissions
allows an initial reporting of excess emissions be reported by email, in person, or
by telephone.
c. If yes, do you require a followup written report? If yes, within what timeframe?
Yes. Per Title V General Condition G14: Written Reporting of Excess Emissions,
a written report of an incident of excess emission shall be submitted as a follow-
up to all required initial reports to the department within seven days of the onset
of the upset condition.
b. Do you require that all deviation reports be certified by a responsible official
(RO)? (If not, describe which deviation reports are not certified).
No, deviation reports are not required to be certified by the RO. However, the
Title V Annual Certification and Semi-Annual Monitoring Reports require RO
certification.
i. Do you require all certifications at the time of submittal? Yes, the certification
must be signed by the RO when the Title V certifications and reports are
submitted.
ii. If not, do you allow the responsible official to "back certify" deviation reports?
If you allow the responsible official to "back certify" deviation reports, what
timeframe do you allow for the followup certifications (e.g., within 30 days; at
the time of the semi-annual deviation reporting)? Not applicable.
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2. How does your program define deviation? A deviation is any failure to meet a term,
condition or applicable requirement in the permit. Reporting requirements for
deviations that result in a hazardous release or excess emissions have been
indicated in Title V General Conditions G13. Hazardous Release and G14. Written
Reporting of Excess Emissions. Unless more frequent deviation reporting is
specified in the permit, any other deviation shall be documented in the semi-annual
monitoring report and the annual compliance certification. See also Title V General
Conditions G4. Annual Compliance Certification and G5. Semi-Annual Monitoring
Report and 567 IAC 22.108(5V'b".
c. Do you require only violations of permit terms to be reported as deviations? No.
d. Which of the following do you require to be reported as a deviation (Check all
that apply):
i. excess emissions excused due to emergencies (pursuant to 70.6(g))?
Yes, per Title V General Condition G14(3):
"G14.(3) Emergency Defense for Excess Emissions. For the purposes of this permit, an
"emergency" means any situation arising from sudden and reasonably unforeseeable
events beyond the control of the source, including acts of God, which situation requires
immediate corrective action to restore normal operation, and that causes the source to
exceed a technology-based emission limitation under the permit due to unavoidable
increases in emissions attributable to the emergency. An emergency shall not include
non-compliance, to the extent caused by improperly designed equipment, lack of
preventive maintenance, careless or improper operation or operator error. An emergency
constitutes an affirmative defense to an action brought for non-compliance with
technology based limitations if it can be demonstrated through properly signed
contemporaneous operating logs or other relevant evidence that:
a. An emergency occurred and that the permittee can identify the cause(s) of the
emergency;
b. The facility at the time was being properly operated;
c. During the period of the emergency, the permittee took all reasonable steps to
minimize levels of emissions that exceeded the emissions standards or other
requirements of the permit; and
d. The permittee submitted notice of the emergency to the director by certified mail
within two working days of the time when the emissions limitations were exceeded
due to the emergency. This notice fulfills the requirement of paragraph 22.108(5)"b."
- See G15. This notice must contain a description of the emergency, any steps taken
to mitigate emissions, and corrective actions taken.
In any enforcement proceeding, the permittee seeking to establish the occurrence of an
emergency has the burden of proof. This provision is in addition to any emergency or
upset provision contained in any applicable requirement." 567 IAC 22.108(16)
ii. excess emissions excused due to SIP provisions (cite the specific state
rule)? No. 567 IAC 24.1(1) has specific requirements for excess emission
during periods of startup, shutdown, or cleaning control equipment:
"Excess emission during a period of startup, shutdown, or cleaning of control equipment
is not a violation of the emission standard if the startup, shutdown or cleaning is
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accomplished expeditiously and in a manner consistent with good practice for minimizing
emissions. Cleaning of control equipment which does not require the shutdown of the
process equipment shall be limited to one six-minute period per one-hour period."
iii. excess emissions allowed under NSPS or MACT SSM provisions? Yes
and no. It depends on the SSM provisions in the specific NSPS or MACT.
iv. excursions from specified parameter ranges where such excursions are
not a monitoring violation (as defined in CAM)? Yes.
v. excursions from specified parameter ranges where such excursions are
credible evidence of an emission violation? Yes.
vi. failure to collect data/conduct monitoring where such failure is "excused"?
Yes.
A. during scheduled routine maintenance or calibration checks: 567 IAC
24.1(1) has specific requirements for excess emission during periods of
startup, shutdown, or cleaning control equipment:
"Excess emission during a period of startup, shutdown, or cleaning of control equipment
is not a violation of the emission standard if the startup, shutdown or cleaning is
accomplished expeditiously and in a manner consistent with good practice for minimizing
emissions. Cleaning of control equipment which does not require the shutdown of the
process equipment shall be limited to one six-minute period per one-hour period."
B. where less than 100% data collection is allowed by the permit? Yes.
C. due to an emergency? Yes.
D. Other? Not applicable.
3. Do your deviation reports include:
a. The probable cause of the deviation? Yes.
b. Any corrective actions taken? Yes.
c. The magnitude and duration of the deviation? Yes.
4. Do you define "prompt" reporting of deviations as more frequent than semi-annual?
Yes.
5. Do you require a written report for deviations? Yes.
6. Do you require that a responsible official certify all deviation reports? No.
7. What is your procedure for reviewing and following up on:
a. deviation reports? DNR Compliance staff review to ensure the required
information is provided and the facility has taken action to correct the issue.
b. semi-annual monitoring reports (SAMR)?
DNR Compliance staff review the reports following these six steps:
1. Review the indicated current compliance status. If the facility is not currently
in compliance, a compliance plan is required to be submitted with the Annual
Compliance Certification (ACC) or SAMR.
2. Cross check the Compliance Tracking database, Field Office Compliance
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Database (FOCD), and most recent inspection for compliance issues that
should be included in the report. If deviations are found that are not identified
in the ACC/SAMR, the facility should be contacted for an updated report or a
justification for not reporting the information.
3. Review previous ACC or SAMR to determine if the same deviations were
reported previously.
4. Enter the report into the TV Compliance Report database.
5. For ACC's only, enter the report into ICIS as a compliance monitoring activity.
6. Update the Compliance Tracking Database with any provided compliance
plans and/or any NOVs issued as a result of disclosed deviations.
c. annual compliance certifications (ACC)? See above. Same procedures as for
reviewing SAMR.
8. What percentage of the following reports do you review?
a. deviation reports? All deviation reports received are reviewed. However, if the
issue appears to be resolved and emissions were minimal, there will not be any
follow up by DNR Compliance staff.
b. semi-annual monitoring reports? 100% are reviewed.
c. annual compliance certifications? 100% are reviewed.
9. Compliance certifications
a. Have you developed a compliance certification form? If no, go to Question F. 1.
Yes, we have developed both an ACC and a SAMR form.
i. Is the certification form consistent with your rules? Yes
ii. Is compliance based on whether compliance is continuous or intermittent or
whether the compliance monitoring method is continuous or intermittent? Yes
- both.
iii. Do you require sources to use the form? No.
What percentage do? We do not track this. Many facilities use their own
Microsoft Excel documents that allow them to easily update their ACC.
iv. Does the form account for the use of credible evidence?
Title V General Condition G11 allows use of any credible evidence as follows:
"G11. Evidence used in establishing that a violation has oris occurring. Notwithstanding any
other provisions of these rules, any credible evidence may be used for the purpose of
establishing whether a person has violated or is in violation of any provisions herein.
1. Information from the use of the following methods is presumptively credible evidence of
whether a violation has occurred at a source:
a. A monitoring method approved for the source and incorporated in an operating
permit pursuant to 567 Chapter 22:
b. Compliance test methods specified in 567 Chapter 25: or
c. Testing or monitoring methods approved for the source in a construction permit
issued pursuant to 567 Chapter 22.
2. The following testing, monitoring or information gathering methods are presumptively
credible testing, monitoring, or information gathering methods:
a. Any monitoring or testing methods provided in these rules; or
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b. Other testing, monitoring, or information gathering methods that produce information
comparable to that produced by any method in subrule 21.5(1) or this subruie." 567
I AC 21,5(1)-567 IAC 21.5(2)"
v. Does the form require the source to specify the monitoring method used to
determine compliance where there are options for monitoring, including which
method was used where more than one method exists? Yes, we require all
requirements to be reported, including monitoring methods.
10. Excess emissions provisions:
a. Does your program include an emergency defense provision as provided in
70.6(g)? Yes, the Iowa rule 567 IAC 22.108(16) is the same as 70.6(g) and is
included in the Title V General Conditions in G14(3):
"G14.(3) Emergency Defense for Excess Emissions. For the purposes of this permit, an
"emergency" means any situation arising from sudden and reasonably unforeseeable events
beyond the control of the source, including acts of God, which situation requires immediate
corrective action to restore normal operation, and that causes the source to exceed a technology-
based emission limitation under the permit due to unavoidable increases in emissions attributable
to the emergency. An emergency shall not include non-compliance, to the extent caused by
improperly designed equipment, lack of preventive maintenance, careless or improper operation
or operator error. An emergency constitutes an affirmative defense to an action brought for non-
compliance with technology based limitations if it can be demonstrated through properly signed
contemporaneous operating logs or other relevant evidence that:
a. An emergency occurred and that the permittee can identify the cause(s) of the
emergency;
b. The facility at the time was being properly operated;
c. During the period of the emergency, the permittee took all reasonable steps to minimize
levels of emissions that exceeded the emissions standards or other requirements of the
permit; and
d. The permittee submitted notice of the emergency to the director by certified mail within
two working days of the time when the emissions limitations were exceeded due to the
emergency. This notice fulfills the requirement of paragraph 22.108(5)"b." - See G15.
This notice must contain a description of the emergency, any steps taken to mitigate
emissions, and corrective actions taken.
In any enforcement proceeding, the permittee seeking to establish the occurrence of an
emergency has the burden of proof. This provision is in addition to any emergency or upset
provision contained in any applicable requirement." 567 IAC 22.108(16)
If yes, does it:
i. Provide relief from penalties? No, same as 70.6(g).
ii. Provide injunctive relief? No, same as 70.6(g).
iii. Excuse noncompliance? No, same as 70.6(g).
b. Does your program include a SIP excess emissions provision? Yes.
If no, go to 6.c. If yes does it:
iv. Provide relief from penalties? No.
v. Provide injunctive relief? No.
vi. Excuse noncompliance? No.
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c. Do you require the source to obtain a written concurrence from the PA before the
source can qualify for:
i. the emergency defense provision? Yes and no. It depends on the
circumstance.
ii. the SIP excess emissions provision? No.
iii. NSPS/NESHAP SSM excess emissions provisions? No.
11. Is your compliance certification rule based on:
a. the '97 revisions to part 70 - i.e., is the compliance certification rule based on
whether the compliance monitoring method is continuous or intermittent; or:
b. the '92 part 70 rule - i.e., is the compliance certification rule based on whether
compliance was continuous or intermittent? It is based on both revisions.
12. Any additional comments on compliance?
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G. Resources & Internal Management Support
1. Are there any competing resource priorities for your "title V" staff in issuing Title V
permits?
a. If so, what are they?
Not for the Title V permit writers as their primary job duties are reviewing and
issuing Title V permits (see Question G.9 below). Staff in the Program
Development (PD) & Support and Compliance sections support the Title V
program as part of normal job duties, but they do have other job duties:
• Support staff running the Iowa EASY Air Help Desk staff provide assistance to both
the Title V and Construction Permitting portions of Iowa EASY Air.
• PD & Support staff assisting with records and the financial components of Title V
work in other activities within the Bureau.
• Compliance staff also support activities across the Bureau.
2. Are there any initiatives instituted by your management that recognize/reward your
permit staff for getting past barriers in implementing the title V program that you
would care to share?
We do not have a formal recognition or reward program, but outstanding
performance or compliments by facilities are documented in emails shared with the
Bureau Chief (BC), Division Administrator and upper management. It is also
documented in the permit writer's annual performance evaluation.
3. How is management kept up to date on permit issuance?
The supervisor meets with the Bureau Chief (BC) on a weekly basis and writes a
detailed bi-weekly report for the BC. The BC then passes that information on to
upper management. In addition, the Title V staff continuously tracks permit issuance
in real time using a data visualization board called Trello. The BC has access to the
Trello board and can check it at any time. Representatives from the local programs,
Compliance section, and Construction Permitting section also have access to the
Trello board. For more details, please see Good Practices not addressed elsewhere
in this questionnaire.
4. Do you meet on a regular basis to address issues and problems related to permit
writing?
Yes as follows:
• Each permit writer has impromptu Google Chats and Google Meets with their
assigned leader as necessary.
• The supervisor and two lead workers meet weekly to discuss permit writing.
• Each permit writer has an individual meeting every 3-4 weeks with the supervisor
and their assigned lead worker.
• All Title V staff and representatives from the local programs, Program Development
section, Compliance Section, Construction Permitting section meet at least once a
month to discuss issues and problems.
• A representative from the Title V and Emissions Inventory also attends the other
sections' staff meetings to ensure we are working collaboratively.
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5. Do you charge Title V fees based on emission volume?
a. if not, what is the basis for your fees?
The Title V emission fee is calculated by dividing the estimated Title V emission
budget by the chargeable emissions as reported by facilities each March 31. Per
Iowa Code 455B.133B and 567 IAC 30.4, the Title V emission fee is assessed on
the first 4,000 tons of each regulated air pollutant emitted each year from each
major stationary source in the state. Regulated pollutants include: particulate
matter less than 10 micrometers in diameter (PM10), sulfur dioxide (S02),
nitrogen oxides (NOx), volatile organic compounds (VOC), lead (Pb), and
hazardous air pollutants (HAP). Greenhouse gas emissions are not subject to
Title V fees.
In 2015, the Iowa General Assembly amended Iowa Code 455B.133B to
authorize application fees. The Environmental Protection Commission adopted
rules (567 IAC 30) and a Fee Schedule on December 15, 2015. The application
fees became effective on January 15, 2016.
b. What is your Title V fee?
The Title V emission fee is $70/ton on the first 4,000 tons of each regulated air
pollutant. The Title V application fee is $100/hour.
6. How do you track title V expenses?
Personnel expenses are the largest Title V expenses. Staff use activity codes to
track activities. Reports are generated frequently and provided to management for
review. Non-personnel expenses are tracked by the DNR's Budget & Finance
Bureau. Expense reports are provided monthly, and the Program Development staff
review the reports for accuracy.
7. How do you track title V fee revenue?
Fees are received by mail, online payment, or by credit card over the phone. Mailed
fees and fees paid by phone are sent to the cashier for processing. Program
Development staff review payments prior to depositing to ensure the funds are
placed into the appropriate account. Online payments are automatically deposited
into appropriate accounts. While daily reports are accessible, a monthly summary of
deposits is provided to the Bureau. The current revenue report is included in the
Iowa Title V Program Google Drive folder.
8. How many Title V permit writers does the agency have on staff (number of FTE)?
Five full-time equivalent (FTE) positions for Title V permit writers (environmental
specialists) and two FTE positions for Title V lead workers (environmental specialist
seniors) are budgeted on an annual basis. FTE reports are available upon request.
In addition, the Polk County and Linn County local programs have FTE assigned to
Title V permit writing. The allocation for Linn County is 0.33 for SFY 2021 and 0.37
for SFY 2022. Polk County's allocation is 0.67 for SFY 2021 and 0.59 for SFY 2022.
It is important to note that the budgeted FTE allocations vary year to year for both
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local programs depending on the number of expected initial and renewal
applications and permit complexity. Polk has a dedicated staff person, so their FTE
allocation is higher than Linn County's. The actual FTE allocation each year depends
on actual circumstances at the time.
9. Do the permit writers work full time on Title V?
Yes, however since all five permit writers were hired in the past fourteen months,
they spent a large percentage of time on training as shown below in Question G.9.a.
a. If not, describe their main activities and percentage of time on title V permits.
For the time period July 1, 2020 - May 27, 2021, the five permit writers spent
76% of their working hours on permit writing and 21 % on training as shown
below in Table 6. The remaining 3% of their time was spent on unspecified
activities such as bureau and department meetings. These figures do not include
vacation, sick leave, or breaks.
Table 6: Title V Permit Writer Work Activities
Activity
Hours Worked
Percentage of Total
Hours
Permit Writing - Billable Hours
3,585.75
44%
Permit Writing - Non-Billable Hours
2,419.50
30%
Permit Writing - Modifications
130.00
2%
Training
1,718.50
21%
Unspecified (such as bureau meetings,
department meetings, etc.)
248.75
3%
Total
8,107.5
100%
b. How do you track the time allocated to Title V activities versus other non-title V
activities?
Staff code every hour of their work time to a specific activity code for what they
are working on. These hours and codes are reported on their biweekly
timesheets. They also track the daily billable hours for each billable Title V
activity in Iowa EASY Air. The supervisor reviews all timesheets and billable
hours in Iowa EASY Air for each two week period prior to approving timesheets
and the billable hours in Iowa EASY Air. The hours for each code and staff
member are tracked in an Excel spreadsheet. Work activities and billable hours
are reported quarterly by the local programs and reviewed.
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10. Are you currently fully staffed? Yes, the Title V section has been fully staffed since
February 2021. A table of organization for the section is saved in the Iowa Title V
Review Google Drive folder.
11. What is the ratio of permits to permit writers? As of June 1, 2021, the ratio of initial &
renewal permit applications to permit writers is 25:1.
12. Describe staff turnover.
Staff turnover in the past has been very high, but has stabilized since February
2020. Over sixty different permit writers have worked in the section at some point.
Previously, the union contract allowed for fairly easy transfers among DNR bureaus
based on seniority, but that option has been removed from the union contract in the
past three years. The entire Title V section except for two staff members turned over
in 2019 - 2020 due to retirements, promotions, or employment outside of DNR.
As the program has matured, there are now more applications for permit renewals
than for initial permits and the time it takes to issue permits has on average declined.
In 2017, DNR re-evaluated staffing levels and the role of senior staff, and
recommended a re-alignment of staffing levels to more closely match the current
work-load. Following feedback from the 2017 stakeholder Funding Work Group,
three Title V permit writers were laid off November 13, 2017. Reevaluating which
services provided real added value led to rebalancing staff assignments and has
resulted in a doubling of staff time spent on the primary activities of drafting initial
and renewal permits and modifications.
a. How does this impact permit issuance?
Turnover significantly reduces permit issuance as it may take several months to
fill a vacant position and then up to six months to train the new employee. Our
permit issuance for goals for 2019 and 2020 were 56 permits each year, but we
were only able to issue 49 in 2019 and 34 in 2020 due to high staff turnover.
b. How does the permitting authority minimize turnover?
One factor that leads to turnover is the nature of Title V permit writing. It takes a
long time to issue a Title V permit, which can lead to feelings of a lack of short
term rewards or success. We try to assign small special projects to each permit
writer to keep them engaged and encourage them to receive training in areas
that interest them. We also strive to continuously improve the Title V permitting
process and are careful to solicit and value input from the permit writers.
13. Do you have a career ladder for permit writers?
a. If so, please describe.
All of our permit writers are classified as environmental specialists. The next
promotion level available is environmental specialist senior, which typically does
not turn over very often, and when it does, is extremely competitive. There are
also opportunities for environmental specialists in other AQB sections and DNR
bureaus.
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14. Do you have the flexibility to offer competitive salaries?
No. When we hire staff we are required to start them at the bottom of the salary
range for that job classification. If the staff person is a current DNR employee that is
being promoted and currently earns more than the bottom of the pay range, we can
generally offer them a 5% pay increase. The salary ranges for each job class are set
by the Department of Administrative Services.
15. Can you hire experienced people with commensurate salaries?
In general, no we cannot. Experienced applicants with direct air quality experience
typically earn more in the private sector than the bottom of the DNR pay range.
However, the low health insurance cost, excellent retirement, and other good
benefits help make our jobs attractive to applicants. We recently offered a Title V
environmental specialist position to the environmental contact at a Title V facility,
and he declined as he is making $30,000 more than what we offered him.
16. Describe the type of training given to your new and existing permit writers.
New permit writers receive both the standard training for all new DNR employees as
well as specific air quality training. The majority of the standard DNR training is
completed within the first two weeks of employment and includes the following
topics:
• Safety,
• ADA/508 Compliance,
• Disability Awareness,
• Unleashing the Power of Diversity,
• Preventing Sexual Harassment,
• Equal Employment Opportunity & Affirmative Action,
• IT Security Training,
• State Policies, and
• Most Valuable Resource - Career Empowerment.
Each new employee is also partnered with a DNR mentor for at least one year. The
air quality-specific training is then started and takes several months. The first three
months of training are spent reading instructional materials, taking on-line courses,
and discussing on-the-job permitting activities. An example training plan is provided
in the Iowa Title V Program Review Google Drive folder. Training classes include,
but are not limited to:
• SI-422 Air Pollution Control Orientation,
• APTI 460: Introduction to Permitting,
• SI-431: Air Pollution Control Systems for Selected Industries,
• RE-100: Basic Concepts in Environmental Sciences - Module 6 Air Pollutants and
Control Techniques, and
• S1-437: modules for fabric filters, electrostatic precipitators, and wet scrubbers.
New employees work with their lead worker throughout this time period and also
attend section meetings of the other AQB groups - Construction Permitting,
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Compliance Assistance, Program Development, Emissions Inventory, and Support -
to learn the role of those sections within the AQB and how they interact with the Title
V group.
Then the new employees begin hands-on training several times a week with their
lead worker to learn about air quality rules, instructions, forms, Iowa EASY Air,
permitting templates, periodic, monitoring, CAM, etc. We had four new employees
start within two months of each other in Feb - April 2020, so the Title V lead workers
held bi-weekly group training sessions with them for over nine months. A fifth permit
writer was added in February 2021. He meets several times a week with his lead
worker, and now group training sessions with all five permit writers are held a few
times a month.
Staff are also encouraged to participate in on-going training throughout the year.
These classes may include but are not limited to:
• Software training such as Excel, Access, Pivot Tables, etc.
• Professional Development Seminars,
• CAM Workshop
• New Source Review Workshop
• Control of Particulate Emissions
• Control of Gaseous Emissions,
• NOX Control Technology, and
• Technical Writing.
Finally, each employee has a 5-year Professional Development & Training Plan.
This plan is reviewed at least annually with the employee's performance evaluation.
11. Does your training cover:
a. how to develop periodic and/or sufficiency monitoring in permits? Yes.
b. how to ensure that permit terms and conditions are enforceable as a practical
matter? Yes.
c. how to write a Statement of Basis? Yes.
18. Is there anything that the EPA can do to assist/improve your training? Please
describe.
The transition from the APTI registration site to the new EPA LMS training system
has not been smooth. Several APTI classes are not in the LMS or have been
renamed/renumbered. CenSARA started requiring registration for their classes to be
done in the LMS, but it did not work correctly, so CenSARA has returned to its own
registration system.
19. How has the permitting authority organized itself to address Title V permit issuance?
The DNR established a Title V Operating Permit section. The staff in the section
focus on the review of Title V applications and issuance of Title V permits. Currently
the section has five environmental specialists who write Title V permits and perform
completeness reviews. The section also has two environmental specialist seniors
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who review draft permits, write Title V permits, train staff, and perform other duties.
The DNR also established a Title V Permit Issuance Strategy. In short, our goal is to
issue Title V Permits within 9 months of assignment to the permit writer. A copy of
the strategy is saved in the Iowa Title V Review Google Drive folder.
20. Overall, what is the biggest internal roadblock to permit issuance from the
perspective of Resources and Internal Management Support? The two biggest
roadblocks are staff turnover and the inability to charge billable hour permitting fees
for permit modification. The union contract no longer allows staff to transfer between
positions in the Department, so we are hopeful that staff will stay in their current
positions longer.
Environmental Justice Resources
21. Do you have Environmental Justice (EJ) legislation, policy or general guidance
which helps to direct permitting efforts? I f so, may EPA obtain copies of appropriate
documentation? No, not at this time.
22. Do you have an in-house EJ office or coordinator, charged with oversight of EJ
related activities? Yes, Catharine Fitzsimmons, Air Quality Bureau Chief, and
Tamara Macintosh, DNR General Counsel and Legal Services Bureau Chief.
23. Have you provided EJ training/guidance to your permit writers?
No, we have not provided specific training to the permit writers but have recently been
discussing the topic to raise their awareness of EJ issues. We are closely following
the EJ comments that Missouri DNR has been receiving. One of our staff attended a
public training that Minnesota put on last year.
The Title V Supervisor has received some training on EJ issues and EPA's
EJSCREEN: Environmental Justice Screening and Mapping Tool as part of her
former position leading DNR's efforts to implement the Clean Power Plan and Clean
Energy Incentive Program.
24. Do the permit writers have access to demographic information necessary for EJ
assessments? (e.g., socio-economic status, minority populations, etc.) EPA's
EJSCREEN tool is available to all permit writers, but they have not received training
on the tool.
25. When reviewing an initial or renewal application, is any screening for potential EJ
issues performed? If so, please describe the process and/or attach guidance. No,
not at this time, but we acknowledge that screening for potential EJ issues will
become more important in the future.
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H.Title V Benefits
1. Compared to the period before you began implementing the Title V program, does
the Title V staff generally have a better understanding of:
a. NSPS requirements?
b. The stationary source requirements in the SIP?
c. The minor NSR program?
d. The major NSR/PSD program?
e. How to design monitoring terms to assure compliance?
f. How to write enforceable permit terms?
Most of the current staff were not working in the air permitting program prior to
implementing the Title V program, so we cannot speak to the situation before the
Title V program was implemented. However, as described above in Section A. Title
V Permit Preparation and Content, our staff receive extensive training on NSPS,
NSR, PSD, monitoring, and writing enforceable permit terms at the beginning or their
employment in the Title V program. They also receive additional training throughout
their career.
2. Compared to the period before you began implementing the Title V program, do you
have better/more complete information about:
a. Your source universe including additional sources previously unknown to you?
b. Your source operations (e.g., better technical understanding of source
operations; more complete information about emission units and/or control
devices; etc.)?
c. Your stationary source emissions inventory?
d. Applicability and more enforceable (clearer) permits?
As mentioned above, most of the current staff were not working in the air permitting
program prior to implementing the Title V program, so we cannot speak to the
situation before the Title V program was implemented. However, we can say with
certainty that the Air Quality Bureau has greatly improved its "source universe". In
approximately 2000 - 2001, the Air Quality Bureau created a separate Emissions
Inventory (El) section. The El staff maintain lists of both our minor and major
sources of emissions inventories. Each year minor sources in one-third of the state
are inventoried. This process starts with the Emission Inventory lead worker
generating a list of all emission sources in that section of the state. The list is then
narrowed down by removing sources that emit below or specific emission thresholds
or belong to a certain nonpoint emission source category. The narrowed-down list is
then reviewed by Compliance and Field Office staff to add any new facilities and
remove any closed facilities.
Minor sources that are required to submit an inventory may use the State and Local
Emissions Inventory System (SLEIS) to report their emissions, or they may submit
on paper. All data submitted on paper is entered into SLEIS by the El staff. The El
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staff then conducts reviews of inventories that show "outliers". El staff is currently
conducting QA/QC checks on minor source emission inventories that reported actual
emissions in 2019 that are higher than the Title V applicability thresholds (7 facilities)
or reported unusually high emissions for a minor source (18 facilities). Staff are also
reviewing 8 sources that may show an elevated health risk for lead or HAPs in the
National Air Toxics Assessment (NATA).
Major source facilities are required to report their actual emissions annually in
SLEIS. The El staff then conducts fee audits of facilities that report significant
increases or decreases in their reported emissions from the previous year. This
year, the El staff has audited 35 facilities so far, resulting in corrections of 1,779
tons. The current reported total pollutants subject to fee is 80,289 tons.
3. In issuing the Title V permits
a. Have you noted inconsistencies in how sources had previously been regulated
(e.g., different emission limits or frequency of testing for similar units)? If yes,
describe
b. Have you taken (or are you taking) steps to assure better regulatory consistency
within source categories and/or between sources? If yes, describe.
• The Title V staff works cooperatively with the Construction Permitting and
Compliance sections to assure regulatory consistency between sources and
within source categories in the following ways:
• Representatives from the Title V section attend each of the Construction
Permitting and Compliance section meetings and vice versa. Notes from each
meeting are taken and distributed to the Bureau (except for Compliance
meetings which require confidentiality due to the nature of enforcement
actions).
• Title V applications that have compliance or construction permitting issues are
flagged as "priority" on the Title V data visualization board and construction
permitting and compliance section regularly update the board with the status
of the project. This board is a Trello Board, and is further discussed in Good
Practices not addressed elsewhere in this questionnaire.
• As part of the technical review process, the Title V permit writer sends out an
Information Request form to the other sections. Staff in the other sections
then fill out the Information Request form, noting if the facility is in/out of
compliance, has current construction permit applications in house, is
expected to submit construction permit applications in the future, has
outstanding stack tests, etc.. An example of the Information Request for
facility 92-5221 Van Diest is saved in the Iowa Title V Program Review
Google Drive folder.
• If the Title V permit writer discovers a compliance or construction permitting
issue during their technical review, they may fill out a Work Request and send
it to the other sections. A copy of the Work Request form is also saved in the
Iowa Title V Program Review Google Drive folder.
• When the construction permit engineers are working on a project, they check
the Title V database to see if Title V is currently reviewing an application. If
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so, the construction permit engineer provides draft copies of the construction
permits for the Title V permit writer to look at before the construction permits
are issued.
• Email notices are sent to a "Permits Notify" distribution list every time a
construction permit or Title V permit is issued.
• The Title V Supervisor and Construction Permit Supervisor frequently meet to
discuss permit consistency and other issues that may affect the other
section's work.
4. Based on your experience, estimate the frequency with which potential compliance
problems were identified through the permit issuance process (never, occasionally,
frequently, or often)?
a. prior to submitting an application - occasionally
b. prior to issuing a draft permit - frequently
c. after issuing a final permit - occasionally
5. Based on your experience with sources addressing compliance problems identified
through the Title V permitting process, estimate the general rate of compliance with
the following requirements prior to implementing Title V (never, occasionally,
frequently, or often)?
a. NSPS requirements (including failure to identify an NSPS as applicable)?
b. SIP requirements?
c. Minor NSR requirements (including the requirement to obtain a permit)?
d. Major NSR/PSD requirements (including the requirement to obtain a permit)?
As mentioned above, most of the current staff were not working in the air permitting
program prior to implementing the Title V program, so we cannot speak to the
situation before the Title V program was implemented.
6. What changes in compliance behavior on the part of sources have you seen in
response to Title V? (Check all that apply.)
a. increased use of self-audits? Frequently.
b. increased use of environmental management systems? Frequently.
c. increased staff devoted to environmental management? Frequently.
d. increased resources devoted to environmental control systems (e.g., maintenance
of control equipment; installation of improved control devices; etc.)? Frequently.
e. increased resources devoted to compliance monitoring? Frequently.
f. better awareness of compliance obligations? Frequently.
h. Other? Describe. The DNR and facilities have worked together over the years to
improve permit requirements, provide clarification with frequently asked
questions (FAQ) documents, standard procedures, and templates and forms to
enhance information sharing.
7. Have you noted a reduction in emissions due to the Title V program?
a. Did that lead to a change in the total fees collected either due to sources getting
out of title V or improving their compliance?
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b. Did that lead to a change in the fee rate (dollars/ton rate)?
The total Title V emissions subject to fees decreased 33% from 2015 - 2019.
Table 7 below shows the changes in tons and fees from 2015 - 2019. This
reduction is not directly due to the Title V program, but is due to other factors
affecting the regulated facilities such as the economy. A majority of the decrease
has been in the electric power sector. This is due to other regulations affecting
utilities (e.g. CSAPR) and Iowa utilities switching from coal to natural gas or wind,
or shutting down. These shutdowns and fuel switching may be due to their
facility's environmental plans or because of consent agreements with
environmental organizations (e.g. Sierra Club).
Table 7: Title V Emissions Subject to Fees and Fee per Ton
Year
Tons Subject to Fees
Fee ($/ton)
2015
119,819
67.50
2016
99,179
70.00
2017
98,350
70.00
2018
102,814
70.00
2019
94,014
70.00
2020
80,289
70.00
As discussed earlier, Iowa Code 455B.133B and our rules (567 IAC 30) cap the
total revenue that the DNR can generate and the maximum Title V emissions fee
per ton that we can charge, so the emissions fee has not changed since 2016.
8. Has title V resulted in improved implementation of your air program in any of the
following areas due to Title V:
a. netting actions
b. emission inventories
c. past records management (e.g., lost permits)
d. enforceability of PTE limits (e.g., consistent with guidance on enforceability of
PTE limits such as the June 13, 1989 guidance)
e. identifying source categories or types of emission units with pervasive or
persistent compliance problems; etc.
f. clarity and enforceability of NSR permit terms
g. better documentation of the basis for applicable requirements (e.g., emission
limit in NSR permit taken to avoid PSD; throughput limit taken to stay under
MACT threshold)
h. emissions trading programs
/'. emission caps
j. other (describe)
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The Title V program has improved the implementation of our air program as the Title V
permit writers perform a holistic review of all air emission requirements that a facility is
subject to. In effect, the Title V permit review serves as a second look at the emission
limits, monitoring, recordkeeping, and reporting set in the construction permits.
The close collaboration between the Title V section and the Construction Permits
section has improved both permitting programs. When writing NSR permits, the
construction permit engineers consider what additional monitoring may be required by
Title V, especially CAM, and try to make the permits compatible. They also provide draft
construction permits to the Title V section for review prior to issuance.
The compliance status of the facility is also reviewed in detail during the Title V review,
and Title V permits are not issued to facilities that are out-of-compliance unless the
facility has a DNR-approved compliance plan in place. Through this process we have
not identified a pattern of noncompliance with any specific industry type; overall,
compliance has been good. The ethanol industry has experienced recurring compliance
issues with testing and monitoring, but those requirements are set first in the facility
construction permits and not driven by the Title V permit.
Title V's use of a tabular format to group similar emission sources inspired the
construction permitting section to develop two new consolidated permit types called the
Group of Identical Air Permits (GIP) and the Collection of Air Permits (CAP). The GIP
consolidates the permits for identical emission units into one document. The CAP
consolidates the permitting requirements for similar units with identical limits, units with
combined limits, units that are part of a single production lime or units that have the
same NESHAP or NSPS requirements into one CAP document. Each emission point
receives a permit number. The first GIP was issued in April 2015 and the first CAP was
issued in May 2016.
Title V emissions fees have also been used to implement and improve the air quality
program. For example, these fees have been used to implement the State and Local
Emissions Inventory System (SLEIS) for emissions inventory, to implement Iowa EASY
Air, and to scan and upload nearly 4 million pages of air quality documents to the
DocDNA electronic records system.
9. If yes to any of the above, would you care to share how this improvement came
about? (E.g., Increased training; outreach; targeted enforcement)? Not applicable.
10. Has Title V changed the way you conduct business?
a. Are there aspects of the Title V program that you have extended to other
program areas (e.g., require certification of accuracy and completeness forpre-
construction permit applications and reports; increased records retention;
inspection entry requirement language in NSR permits). If yes, describe.
b. Have you made changes in how NSR permits are written and documented as a
result of lessons learned in Title V (e.g., permit terms more clearly written; use of
a statement of basis to document decision making)? If yes, describe.
46
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c. Do you work more closely with the sources? If yes, describe.
d. Do you devote more resources to public involvement? If yes, describe.
e. Do you use information from Title V to target inspections and/or enforcement?
f. Other ways? If yes, describe.
As described above, the Title V program has led to more involvement with
stakeholders and permittees through workgroups, lean events, and one-on-one
communication. The Title V program has also led to more collaboration between the
sections within the AQB (Compliance, Emissions Inventory, Construction Permitting,
Stack Testing, and Program Development) and with the field offices. We have
learned to do more long-term planning and be proactive, not reactive, as we have
strived to continuously improve the program.
11. Has the Title V fee money been helpful in running the program? Have you been
able to provide:
a. better training?
b. more resources for your staff such as CFRs and computers?
c. better funding for travel to sources?
d. stable funding despite fluctuations in funding for other state programs?
e. incentives to hire and retain good staff?
f. are there other benefits of the fee program? Describe.
Title V emissions fee money has been critical in running the program. Staff have
been able to receive adequate training, and the emissions fees have provided
sufficient funds for equipment and program resources. It is unclear how the
projected future declines in emissions will impact the program.
To help offset declining revenues from declining emissions, the Iowa General
Assembly added Title V application fees in 2016. The application account in the Title
V Fund (325C) had run a negative balance since its inception. However, the
application account (Title V Operating Permit Fee (325C)) has a positive balance as
of June 2021.
12. Have you received positive feedback from citizens? We have, but can't provide
examples of any specific feedback.
13. Has industry expressed a benefit of Title V? If so, describe.
Industry has repeatedly expressed support for the state's implementation of the Title
V program. AQB staff are frequently invited to speak at industry conference where
participants voice their appreciation. Industry staff participating in AQB workgroups
and lean events have also complimented the permit program. Some examples are:
"We certainly value having open dialogue with the Department, and we appreciate the fact that
you and your colleagues regularly take the time and make the effort to not only bring your
expertise to our members, but also to listen to and address our specific questions, feedback and
concerns."
Grant Menke, Iowa Renewable Fuels Association, 2013
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"My experience with the Iowa DNR permitting group in the past has been outstanding - actually
one of the best states I have worked with. Customer service is excellent.. .In this event, I saw the
same effort, sincere customer service and knowledge expressed throughout the meeting..."
Bruce Stainbrook, Altec, 2016
"The initial draft of the Operations Permit was still unwieldy. Jeremy Arndt consolidated the
information from construction permits into an operating permit that is much more manageable,
reducing the length by hundreds of pages."
Jake Steil, Transco Railway Products, 2018
14. Do you perceive other benefits as a result of the Title V program? If so, describe.
The Title V program benefits the permittee, citizens, EPA, field office inspectors, and
many others because it provides an all-encompassing look at all of the air pollution
sources at a facility, as well as the requirements those sources are subject to. In
addition, many facilities have not taken the time to understand/review the
requirements in their construction permits until they have been incorporated into
their Title V permits and have to certify compliance with the conditions.
Because Title V permit writers perform a holistic review of all air emission
requirements, the Title V permit review serves as a second look at the emission
limits, monitoring, recordkeeping, and reporting set in the construction permits and
may add additional monitoring to protect ambient air quality standards and emission
limits.
The Title V review may identify conflicts in language or limits among construction
permits that have been issued over several years or decades. As part of the Title V
review process, permit writers try to point these conflicts out to the facilities and
suggest they request that their construction permit conditions be harmonized to be
enforceable, clear, and help assure compliance.
Improved routine maintenance of control equipment is also driven by our periodic
monitoring guidance rule and compliance assurance monitoring (CAM) requirements
that are incorporated into the Title V permits.
15. Other comments on the benefits of title V?
Because we are in more frequent dialogue with facilities about all of their air
pollution-emitting activities through the Title V program, we are better prepared to
provide them with assistance on NSR permit modifications and large projects.
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I. Good Practices not addressed elsewhere in this
questionnaire
Are any of the practices employed that improve the quality of the permits, or other
aspects of title V program that are not addressed elsewhere in this questionnaire?
Small Source Operating Permits
DNR offers Small Source Operating Permits to facilities whose potential emissions
exceed the major source thresholds for Title V, but whose actual emissions are less
than fifty percent of the major source thresholds for every 12-month rolling period. By
registering for a Small Source Operating Permit, the owner agrees to limit plant-wide
actual emissions of each regulated air pollutant to below fifty percent of the major
source thresholds. Facilities eligible for a Small Source Operating Permit may also
qualify for reduced record keeping requirements through classification as a "de
minimus" emissions source as defined in 567 IAC 22.300(4). A list of the 70 facilities
currently registered as small sources is saved in the Iowa Title V Program Review
Google Drive folder.
Trello Data Visualization Board
In 2021, Title V staff created a new Trello data visualization board to track Title V
applications and due dates throughout the Title V permitting process. Staff historically
used a Microsoft Access database for tracking, but the database requires a network
connection to open it, and frequently throws errors if more than one person is working in
the database at the same time. In addition, Polk and Linn County Title V staff are unable
to open the database.
The new Trello board is easier to use and is web-based so it may be opened without a
network connection. Each permit application is shown on the board on an individual
"card". The cards are sorted into the following ten categories and are moved from
category to category as the application moves through the process:
• Apps Due in 2021
• In Completeness Review
• To Be Assigned
• In Tech Review
• In Senior Review
• Facility Review
• Public Notice
• Priority for Construction or Compliance
• Issued
• Not Operating or Hold
Cards are labeled with the type of application (e.g. Initial, Renewal 1, Renewal 2, etc.)
and the permit writer assigned to the application. Cards also contain the application
due date, received date, assigned date, DNR issuance goal date, and issued date. The
Bureau Chief, local program staff, and Compliance and Construction Permitting section
49
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staff have access to the board. A screenshot of the board is shown below. David Peter
at EPA Region 7 was sent an invitation to access the board.
Title V Tracking
foe A Workspace visible jCK ffip1
Apps Due in 2021
In Completeness Review
J0Hr Deere TCAO
Received Date; iun 30. 2020
John Deere Waterloo Wortcs - Drive
Train Operations
S Received Dae Sep 18, 2020
Mid American Energy - Merle Parr CTs
— Received Oae Oct 29. 2020
Valero Albert City
* Received Date Nov4 2020
LOPAREX
^ Received Date Dec 11 2020
Climax Molybdenum
= Received D3te Dec i V 2020
Des Moines Metropolitan WRA
" Received Date: Dec 11 2020
+ Add another card Q
In Tech Review
Aitec Osceola Body P ant
® 9 P 2 B 0/21
Received Date Dec 17 2020
Assigned Date: Jan 10
DNS issuance goal: Mar 11 2022
Bridgestone Americas Tire
Operations
® = Q 2
Received Date Dec 1 2020
Cargil!, Inc. - Eddyvine
@ = P1
Received Date Apr 5.2011
CF industries Nitrogen, LLC - Port
Neai Nitrogen Complex
b Add another card
In Senior Review
BrandFX
9 8 0/21
Received Date May 21 2020
Assigned Date Mar 17
DNR issuance goat Dec 16
o
Continental Carbon ics
S Pi Received Date Jm
n 8.2020
Assigned Date Mar 22
DNR issuance goat Dec 21
John Deere Engine Wcrics
™ Q 1 Received Date: Apr 1.
Assigned Date Aug 26 2020
0NR issuance goat May 26
o
©
OSI Industries, LLC
+ Add another card S3
3M
™ CD 1 Received Date: Nc
Assigned Date: Jun 1.2020
DNR issuance goal: Mar 1
Atlas Molded Productions
™ Received Date Jul 23 202
Assigned Date May <1
DNR issuance goal: Feb 2, 202;
Surge Corporation
m ® = pi
Received Date: Oct 18 2018
Assigned Date Oct 18.2018
DNR issuance goat Jul 18.2015
Iowa Army Ammunition Pis
+ Add another card
Vantage Com Processors LLC
©Jul 5 9
NuStar Le Mars Term na
ADM (Cedar Rapids
© jui s 9
Jonr Deere Foundry Waterloo
© Jul 8 9
Golden Grain Energy
© Sep 5 =
Add another card
50
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J. EPA assistance not addressed elsewhere in this
questionnaire
Is there anything else EPA can do to help your title V program?
Not at this time. We appreciate the friendly, transparent, collaborative relationship we
have with the staff in the EPA Region 7 office. We feel comfortable contacting R7 staff
with questions and requests for assistance. David Peter is very fair in his review of our
draft permits and is open to discussion on topics we disagree on, and the monthly
permitting calls between Iowa DNR and EPA R7 are very helpful.
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Iowa Department of Natural Resources
IgKlOfe
Governor Kim Reynolds
Lt. Governor Adam Gregg
Acting Director Bruce Trautman
Date
Director
Library Name
Library Address
Library Address
Dear Director:
Enclosed is a copy of the Public Notice for Facility Name located in Facility City, Iowa. The permit deals
with air emissions and emission limits for the facility.
I am requesting that you keep the Public Notice in an area that the public can either view it, such as the
circulation desk, or request to view it. The documents should be available to the public from Pub. Notice
Start Date Pub, Notice End Date. At the end of the viewing period, you may dispose of the document as
you see fit. Thank you.
If you have any questions concerning the permit please contact me at (515) 725-####.
Sincerely,
Peter, David
Environmental Specialist
Air Operating Permits Section
Enclosures: Public Notice
Phone: 515-725-8200
WALLACE BUILDING, 502 E 9™ ST, DES MOINES IA 50319
www.lowaDNR.gov
Fax: 515-725-9501
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Title V Permit Review Checksheet
New Part 2
The purpose of this checksheet is to guide the Title V permit writer through the numerous steps involved in
issuing a Title V permit. It should be used for each application reviewed. For a more detailed discussion of
each of these steps, see the Title V Permit Review Manual.
Facility Name
" EIQ #
Facility #
~i. APPLICATION COMPLETENESS REVIEW
I |A. Confirm the completeness review was finalized.
~il. APPLICATION REVIEW
The application will be assigned to you for technical review by a supervisor or a senior through EASYAir
and you will receive an email notification. Enter the date the project was assigned to you in the access
database.
~A. Title V request for information. (Complete the Title V Facility Info Request form and send it
to dnr aqb tv info request@dnr.iowa.gov .)
Enter the date you send the info request in both EASYAir and access.
I IB. Send facility notification that we intend to begin reviewing their application, cc field office.
Enter the date you start the technical review in both EASYAir and access.
I IC. Schedule outreach visit to discuss application and tour facility (optional)
~D. Inform field office via phone or e-mail about outreach visit
I IE. Review entire construction file and the rescission database
I IF. Confirm Title V Applicability
I 11. Check PTE calculations - is it a major source (100 tpy, 10/25 tpy)?
I la. acceptable assumptions?
I lb. acceptable emission factors?
I Ic. acceptable control efficiencies?
I Id. acceptable math?
I IG. Check for any other basis for claiming Title V applicability
I 11. affected source under Title IV?
I |2. subject to NSPS?
I |3. subject to NESHAP (Parts 61 & 63)?
~4. solid waste incinerator subject to section 129(e) of the Act?
~H. Confirm "insignificant activities" meet requirements specified in 567 IAC 22.103
~I. Review Actual Emissions calculations from most recent emissions inventory as it relates to
an evaluation of Periodic Monitoring.
I 11. Acceptable assumptions?
I \l. Acceptable emission factors?
~3. Acceptable control efficiencies?
~4. Acceptable math?
~J. Review the most recent inventory audit for any recurring problems with actual emissions
calculations. (It is possible the facility has not been audited. See manual for links to audit
database and folders.)
I IK. Review Applicable Requirements (Part 2 of application)
I 11. Review requirements (General Facility Requirements Form) for claimed
applicability of various air programs and confirm that all are identified
N:\DNR Shared Perm\Templates\AQ\Operatiiig PermitsVTV Checksheet E-Notice_verl.dotx
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l
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~2.
~a.
~b.
~c.
~d.
~e.
~f.
~3.
~b.
~c.
~4.
~b
~c
~d
~e
~f.
NSPS
NESHAP - Part 61
NESHAP - Part 63
Acid Rain/CSAPR
Stratospheric Ozone
CAM
Check applicable requirements claimed by applicant against existing construction
permits (for those sources that have permits)
H|a. Confirm all construction permits are identified & requirements included
Confirm that construction permit emission limits are federally enforceable
(enforceable "as a practical matter", i.e. is there recordkeeping to support the
limit)
Confirm any outstanding stack test requirements
Check applicable requirements claimed by an applicant against the staff judgment of
requirements for grandfathered / unpermitted / exempted sources (does not have a
construction permit)
I la. Particulate Matter - 23.3(2)
Fugitive Dust - 23.3(2)"c"
Visible Emissions - 23.3(2)"d"
S02 - 23.3(3)
Specific Processes - 23.4
Provisions of any existing court orders, administrative orders
Confirm source has all necessary construction permits, meets an exemption, are
grandfathered or not generally permitted (indoor vented source) and verify all
exemptions from construction permitting
~L. Review Compliance Status
I 11. Confirm that facility is "in compliance" if applicant claims to be on Emission Point
Information Forms
I la. Check records for variances from applicable rules (567 IAC 21.2)
Confirm that facility is "on schedule" if non-compliance is claimed and a
compliance schedule is provided
Review compliance schedule for acceptability (is it timely?)
If necessary, complete Title V Facility Work Request form and discuss any
compliance issues and schedules with Compliance Unit.
Review most recent field office inspection report
~m. Review Proposed Limits, if any have been included
I 11. Check calculations for acceptable assumptions, math, etc.
I |2. Confirm that proposed limits would constitute "Federally Enforceable
Permit Limits"
~n. Review Periodic Monitoring/CAM Proposals (evaluate according to Periodic Monitoring
Guidance and acceptable CAM plans)
I 11. Confirm monitoring has been proposed for all sources meeting the criteria
I |2. Confirm acceptability of proposed monitoring
I |3. Develop draft monitoring for those affected sources for which none was
proposed or which was determined to be unacceptable
Send outreach follow-up letter via certified mail with request for any additional information
(If a site visit was done.)
Deadline date for response:
~p. Update tracking information in Title V database including all information requests to the
facility
~2.
~3.
~4.
~5.
~o.
~ill. DRAFT TITLE V OPERATING PERMIT
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2
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See review manual for guidance on what to look for in draft construction permits sent for review by the
construction permitting section.
I |A. Incorporate all "generally applicable requirements" into draft permit
I IB. Incorporate all source specific applicable requirements into draft permit
I IC. Incorporate approved "proposed limits" (if any) for specific sources into draft
I ID. Incorporate approved compliance schedule (if any) into draft permit
I IE. Incorporate periodic monitoring & CAM conditions for those sources meeting criteria
I IF. Confirm, after federal deadline of June 20, 1999, that sources subject to Risk Management
Plans - Sec. 112(r), have submitted their plan to EPA (See Chris for confirmation, as he is an
EPA authorized recipient of this information.)
I IG. Attach and cross-reference any necessary appendices (i.e. Acid Rain Permit, consent orders,
NESHAPs (web links), etc.)
~H. Incorporate any "state only" or "local only" limitations or requirements and identify
them as such
I ll. For renewal applications, review semi-annual monitoring reports & annual compliance
certifications submitted during past permit term
I I J. Prepare Fact Sheet, Permit Writer's Notes & Spreadsheets that discuss the review decisions
~K. Give the Draft Permit, Fact Sheet, & Permit Writer's Notes to your senior for review prior to
sending the documents to the facility. Once a senior has reviewed the documents, make any
necessary corrections prior to sending the information to the facility.
The senior will enter the date they complete their review into EASYAir.
~L. Send Draft Permit, Fact Sheet, & Permit Writer's Notes to responsible official and plant
contact (7/15-day informal facility review period)
Deadline Date for Response:
Enter the date you send the draft permit to the facility in both EASYAir and access.
I IM. Schedule outreach visit during facility review period if the facility wishes to
discuss draft permit (notify field office if the visit is to take place at the facility)
I IN. Update tracking information in Title V database including all information requests to the
facility
I lO. Confirm with compliance that there are no current compliance actions with the facility prior
to proceeding to the public notice phase.
~iV. PUBLIC NOTICE INTENT TO ISSUE TITLE V PERMIT
~A. If comments are received during facility review period, make any necessary
changes to permit documents
I IB. Send draft permit to & solicit comments from:
I 11. EPA (via e-mail) - public notice, fact sheet, permit writer's notes, spreadsheets and
draft permit (45-day EPA review begins when public comment starts)
Date 45-day EPA review period ends:
I \l. Post on AQB's web site - (Monday before the notice date.) (30-day public comment
period starts when published (Thursday))
I la. E-mail Jason Dowie (web master) and CC: Brad (backup Brad Ashton)
PDF's of public notice, fact sheet (with permit writer notes attached), and
draft permit. Also include the text for the web master to send to the
EcoNewsWire contacts.
I lb. Don will email the EcoNewsWire contacts the information for posting on
Tuesday with the subject line "AQ Permits for EcoNewsWire on ##.##.####
of Eco"
Contacts: Primary Jessie.Brown@dnr.iowa.gov and CC:
Karen.Grimes@dnr.iowa.gov and Alex. Murphv@dnr.iowa.gov
I Ic. Date public comment period begins:
I Id. Date public comment period ends:
3
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I le. Print a copy of the Title V draft webpage on the first day of the public
notice. Ensure there is a date stamp on the printed page. A suggestion is to
print this to a pdf to maintain a copy with electronic permitting documents
on our network drives.
I |3. Post in local library-
I la. Send via first class mail - Cover letter and public notice
~4. Facility -
I la. Mail via first class to responsible official & permit contact (may e-mail) -
public notice, fact sheet, permit writer's notes, spreadsheets and draft permit
I |5. Surrounding states - E-mail public notice (if applicable)
I |6. Affected local programs (Omaha) - Mail public notice (if applicable)
I |7. Field Office - E-mail public notice, fact sheet, permit writer's notes, spreadsheets
and draft permit
I |8. E-mail public notice to persons who have requested to be on a mailing list
I IC. Update tracking information in Title V database
Enter the starting date of the public notice in both EASYAir and access.
I ID. Schedule outreach visit during public comment period if the facility wishes to
discuss draft permit (notify field office if the visit is to take place at the facility) (optional)
I IE. If a public hearing is held, e-mail the required information to be posted on the State Public
Meeting Calendar
~V. ISSUE TITLE V PERMIT
I 1a. If comments were received during the public comment/EPA review period:
I 11. Develop Responsiveness Summary
I |2. Make necessary changes to permit documents
I |3. Send a copy of the revised documents to EPA, all commenters, field office and
facility.
I IB. Before issuing final permit, confirm with EPA that it is acceptable to do so. If EPA requests
it, give additional 45-days for their review of the proposed permit.
~C. Remove "DRAFT" or "Proposed" from permit, get permit number, add dates for permit,
change dates of stack tests to correspond with permit dates, and get signature
I ID. Mail final permit, permit writer's notes, spreadsheets (if necessary) and responsiveness
summary (if one was created) to the following:
I 11. Facility - responsible official (via certified mail) & permit contact (may e-mail)
I |2. EPA (via e-mail)
I |3. Field Office (via e-mail)
I |4. All commenters (via e-mail)
I IE. Send e-mail notification with a completed form regarding permit issuance to "TV Permits
Notify" group in Google Mail using template (see manual). Enter the date you send the
permits notify email into EASYAir.
I IF. Copy all electronic files associated with permit review including e-mails to:
\\iowa.gov.state.ia.us\data\DNR_AQ_Shared\Operating Permits\final.tv\[last 4 digits of eiq#]
I IG. E-mail Jason Dowie (backup Brad Ashton) a PDF of the final permit for posting on AQB's
web site
I IH. Update tracking information in Title V database including hyperlink to permit, update or
enter the permit number and enter stack tests in the stack test database. Enter the issuance
date and permit duration dates in EASYAir.
~I. Schedule outreach visit if the facility wishes to discuss the final permit (notify field office if
the visit is to take place at the facility) (optional)
I I J. Bind permit and include the following (start a new binder for renewed permits):
I la. final permit
4
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~b. review check sheet
I Ic. fact sheet
I Id. public notice with proof of publication (print out of webpage)
~e. responsiveness summary (if one was created)
I If. permit writer's notes & spreadsheets
I |g. correspondence
I IK. Upload a PDF version of the Title V permit and permit writer notes to EASYAir
~VI. CLEAN-UP TITLE V RECORDS
Once you have completed the file cleanup process enter the date into EASYAir.
I 1a. Stage records for long-term storage using the record file cleanup procedure for Title V.(see
manual)
~B. Recycle extra copies of emissions inventories and applications (there should only be one
copy of each)
5
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Record file cleanup procedure for Title V, Con 10-1-5 documents. Con 10-1-5 documents consist of
Emission Inventory, Fee and Miscellaneous Documentation. Records that are older than 15 years old may be
recycled. The exception will be critical correspondence that is important to the permitting history of a
facility. See the TM section below for more detail.
I I Recycle duplicate copies of documents in the file.
EI & FD - Emission inventory (EI folder) and fee (FD folder) documents
I I Stage anything with a date more than 5 years prior to the previous December 1st. (For 2007 this
would be anything older than December 1st, 2002.)
I I Group all documents or packets together that meet the Con 10-1-5 record series definition. They
should be separated into a stack of EI documents and FD documents.
I I Attach a "Title V State Record Center coversheet" to the FD stack and EI stack. Code them for the
Con 10-1-5 record series and the appropriate document code. (Check the Public or Confidential
check box)
I I Give the documents for archiving to the Records Center.
TM - Miscellaneous Documents (These documents will remain in records)
I I Remove the critical correspondence from the previous Title V permit and place it in the TM (Misc.)
records folder. Critical correspondence would include one-source determinations, Title V
applicability and NSPS orNESHAP determinations. General correspondence that is older than 15
years old may be recycled. This would include form letters such as the EIQ reminder letter, mass
mailings from the Department, renewal reminder letters and non-critical correspondence.
If any of the documents above have been granted confidentiality they must be kept separate from the public
record documents.
Packet = collection of individual document of similar coding.
Bundle = all packets and loose documents of similar coding that is stage to be sent to the State Records
Center (SRC) in a single box.
Based on the example above the process cut-off date on the "Title V State Record Center Cover Page" should
be December 1st. 2002.
6
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Record file cleanup procedure for Title V, Con 10-1-4 documents. Con 10-1-4 documents consist of Title V
applications and permit packets
I I Recycle duplicate copies of documents in the file.
TA - Applications
I I Stage all application submittals received prior to the renewal application to be sent to the State
Records Center.
I I Group all applications that meet the Con 10-1-4 record series definition.
I I Attach a "Title V State Records Center coversheet" to the bundle and code it for the Con 10-1-4
record series and the TA document code. (Check the Public or Confidential check box) Use the
date stamp for the renewal application as the cutoff date for the TA documents.
PP - Title V Permits
I I Remove critical correspondence from the previous Title V permit and place it in the TM file.
See Con 10-1-5 instructions above for the correspondence.
I I Confirm that a copy of the permit writer notes exists in the appropriate N: drive folder on the
network.
I I Attach a "Title V State Records Center coversheet" to the permit packet. Label it for the Con 10-1-4
record series and PP document code. (Check the Public or Confidential check box) Use the date
stamp for the renewal application as the cutoff date for the PP documents.
Title V permit packet contents in order.
I I All signed Title V permit cover pages
I I Most recent version of the previous Title V permit
~ Review check sheet
I I Fact sheet
I I Public notice with proof of publication
I I Responsiveness summary (if one was created)
I I Permit writer's notes & spreadsheets
I I Correspondence
I I Stage permit packet to be sent to the State Records Center by giving the documents for
archiving to records staff in the Records Center.
If any of the documents above have been granted confidentiality they must be kept separate from the public
record documents.
Packet = collection of individual document of similar coding.
Bundle = all packets and loose documents of similar coding that is staged to be sent to the State Records
Center (SRC) in a single box.
7
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Tips & Hints for AQ Permit Listings Template
1. Provide to Communications by the day before EcoNews goes out - usually on a Thursday
a. Send to Jessie Brown at Jessie .Brown@dnr.iowa. gov, primary editor
b. cc Karen Grimes and Alex Murphy, backup editors
c. Ideally, all projects would come in in one document. Is that possible? I could combine them, or is
there someone else in AQ who could or would do that each week? If so, that would be the first step.
If we go that route, it would be helpful to save the file as dateAQpermitsECO. Date would be two-
digit month, two-digit day, two-digit year, e.g., 04.20.18.
2. Use the Subject Line: (whatever Chris designated, I think it was
AO Permits for EcoNewsWire on DATE ofEco)
3. Please use Associated Press Style* for addresses, months and time.
a. Dates: When used with a specific date, abbreviate months Jan., Feb., Aug., Sept., Oct., Nov., and
Dec., e.g., Jan. 2. Use the numeral for a date, e.g., Sept. 10 not Sept. 10th. I don't think we need the
year, unless the start time of the comment period ends in one year and the end time is in another.
b. Time: Use colon to separate hour and minutes, e.g., 11:30; but do not need minutes when
referring just to the hour, e.g., 11 a.m. Use lower case for a.m. and p.m.
c. Addresses:
1. List the County where facility is located.
2. Use abbreviations Ave., Blvd. and St. with a numbered address. Spell out alley, drive and
road.
3. Always use a figure for an address number, e.g, 9 Morningside Circle.
4. Spell out First through Ninth when part of a street name; use figures for 10th and above,
e.g., 122 First St., 103 22nd St.
5. Abbreviate compass points: 222 E. Campus Drive or 143 Green St. N. W.
6.1 don't think we need the state or zip code.
4. Descriptions: Keep it short and sweet. For media and for interested people, the key will most likely be the
location of the project. If they are interested, they will go to the link and look at the project. For some, it will
be the name of the facility. Again, if they are interested in all the projects one company has, they will go to
the link for more information.
5. Paste project description into the appropriate template, Title V or PSD permits.
* A really old, 1987, dark blue Associated Press Stylebook is located in the wire rack on the left side of my
cubicle. Feel free to use it.
N:\DNR Shared Perm\Templates\AQ\Operatiiig PermitsYTV Checksheet E-Notice_verl.dotx
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8
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TITLE V REVIEW MANUAL
New Part 2
Created August 11, 1998
Revised May 11, 2007
Revised November 30, 2011
Revised December 20, 2011
Revised July 29, 2013
Revised July 31, 2014
Revised January 14, 2015
Revised March 2, 2016
Revised January 12, 2017
Revised April 10, 2018
Revised May 31, 2018 E-notice
Revised July 1, 2018
Revised February 28, 2020
Iowa DNR - Air Quality Bureau
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Table of Contents
I. INTRODUCTION/APPLICATION COMPLETENESS REVIEW
3
II. APPLICATION REVIEW
4
III. DRAFT TITLE V OPERATING PERMIT
13
IV. PUBLIC NOTICE INTENT TO ISSUE TITLE V PERMIT
17
V. ISSUE TITLE V PERMIT
20
VI. CLEAN-UP TITLE V RECORDS
22
VII. APPENDICES
24
A. Affected States/Local Programs
B. Field Office Locations for Iowa Counties
C. DNR's Periodic Monitoring Guidance
D. Guidance on Limiting Potential to Emit in New Source Permitting
E. Newspaper Process
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INTRODUCTION
The purpose of the Title V Review Manual is to serve as a supplement to the Title V Permit Review Checksheet.
The review manual discusses each permitting step in detail, and gives locations of important documents and
reference materials. The Title V review process involves complex issues and a teamwork approach is
encouraged.
~i. APPLICATION COMPLETENESS REVIEW
The application will be assigned to you for completeness review by a supervisor or a senior through EASYAir
and you will receive an email notification. Enter the date the completeness review was assigned to you in the
access database.
~A. Confirm that correct forms were used, all applicable forms submitted, key fields
completed, etc.
This should be completed within 60 days of receipt of the application, otherwise the
application will automatically be deemed complete [22.107(l)"d"]. The completeness
review should be done using the Completeness Review Checklist (N:\DNR Shared
Perm\Templates\AQ\Operating Permits\Permit\Completeness Review
Checksheet2018new.dotx). The Completeness Review Checklist is used to ensure that all
the appropriate forms have been submitted, and that all necessary information has been
provided. This does not mean the information is accurate, only that the facility has provided
a value. After finishing the Completeness Review, a copy of the Completeness Review
Checklist should be placed in the Title V file, along with the record copy of the application.
I IB. Send facility completeness determination letter
Work with your lead worker to determine whether the application is incomplete.
If the application is deemed incomplete (i.e. there are any missing or incomplete forms):
• Establish a deadline by which the supplemental information must be submitted
(usually 2 weeks).
• Call the facility contact, and discuss why the application is incomplete.
• Send a certified letter to the responsible official (copy the facility contact)
requesting the supplemental information.
If the application is deemed complete:
• Send the facility a form letter confirming that the application has been received, and
deemed administratively complete.
Form letters for completeness determinations are available in one of the review category
folders at: Wiowa.gov.state.ia.us\data\DNR_AQ_Shared\Operating
Permits\Correspondence\Completeness Reviews\
~C. Save a copy of the completeness determination letter to the appropriate category folder:
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\\iowa.gov.state.ia.us\data\DNR_AQ_Shared\Operating
Permits\Correspondence\Completeness Reviews\
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~il. APPLICATION REVIEW
The application will be assigned to you for technical review by a supervisor or a senior through EASYAir and
you will receive an email notification. Enter the date the project was assigned to you in the access database.
~A. Title V request for information. (Complete the Title V Facility Info Request form and
send it to dnr aab tv info reauest@dnr.iowa.gov .)
Enter the date you send the info request in both EASYAir and access.
I IB. Send facility notification that we intend to begin reviewing their application, cc field office
Enter the date you start the technical review in both EASYAir and access.
The permit writer usually sends this notice to the facility after the application has been assigned
to a permit writer. The letters are located in the appropriate category folder at
\\iowa.gov.state.ia.us\data\DNR_AQ_Shared\Operating
Permits\Correspondence\30day_renewals\
~C. Schedule outreach visit to discuss application and tour facility (optional)
An outreach visit to the facility may be scheduled after the permit writer has had time to
complete an initial review of the application (normally within 30-60 days after sending the
notification letter). Enough time should be allowed to do a detailed review prior to the
outreach visit. During the outreach visit, the permit writer will point out any deficiencies in
the application, ask any relevant questions concerning the application, observe the emission
sources and control equipment, and answer any questions the facility might have. The
permit writer will pay particular attention to incidents of noncompliance and maintenance,
or lack of maintenance to control equipment. Attention should also be given to emission
sources not included in the application. A camera is available to take with you on outreach
visits if you wish to document some of the equipment for your review notes.
~D. Inform field office via phone or e-mail about outreach visit
The field office that covers the area the facility is located in should be informed of the date
and time of the outreach visit. This allows field office personnel to schedule time to attend if
they wish, and prevents them from scheduling an inspection on the same day. Contact the
appropriate field office supervisor and environmental specialist senior (ESS) listed below.
See Appendix B for a list of counties and the corresponding Field Office if you need to
confirm which Field Office to contact.
• FOl (Manchester): Supervisor ~ Joe Sanfilippo, ESS ~ Clark Ott
• F02 (Mason City): Supervisor ~ Jeff Vansteenburg, ESS ~ Glenn Carper
• F03 (Spencer): Supervisor ~ Ken Hessenius, ESS ~ Cindy Martens
• F04 (Atlantic): Supervisor - Jessica Montana, ESS ~ Holly Vandemark
• F05 (Des Moines): Supervisor ~ Ted Petersen, ESS ~ Bill Gross
• F06 (Washington): Supervisor - Deb Quade, ESS — Kurt Levetzow
I IE. Obtain copies of all construction permits and review entire construction file
Check out all construction and Title V files from records (This may include SPARS and
DocDNA electronic records). Documents should be kept in chronological order. Older permits
and documents may only be available on microfiche or roll film. See records steward for
instructions on viewing microfiche or roll film.
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SPARS applications may be printed to a PDF file format to make the review easier. Emissions
data for actual and potentials emissions maybe exported from SPARS by using the instructions
located: N:\DNR Shared Perm\Templates\AQ\Operating Permits\Instructions for using the
SPARS Reports.docx
The DocDNA system is available through the internet, and the link to the webpage is posted on
the AQB's intranet site.
Electronic copies of construction permits may be available in the following locations:
1. \\iowa.gov.state.ia.us\data\DNR_AQ_Shared\Con-Perm\con_perm_FINAL\ (where
current construction permits are placed after they are posted on AQB's webpage)
2. \\iowa.gov.state.ia.us\data\DNR_AQ_Shared\Con-Perm\final 2\ (where current
construction permits are placed before they are posted on AQB's webpage; permits are
removed from this location after they are posted on the web)
3. \\iowa.gov.state.ia.us\data\DNR_AQ_Shared\Con-Perm\tiff images not on web
(tiff images of older construction permits can sometimes be found here)
4. AQB Webpage (pdf s available at
http://www.iowadnr.gov/InsideDNR/RegulatoryAir/ConstructionPermits/PermitSearch.aspx
)
When there is a discrepancy between the electronic version of a permit and the signed paper
copy of a permit, the signed paper copy is the enforceable document. The status of current
construction projects can be searched via SPARS on AQB's webpage. Also, the Title V
database has information on completed construction permit projects since 2001 (Form -
"Construction Projects for TV Sources"). When a permit cannot be found in-house, it may be
necessary to ask the appropriate Field Office if they have a copy. If all else fails, ask the facility
for a copy.
Confirm Title V Applicability
Facilities are considered a major source under Title V if their potential emissions exceed 100
tpy (tons per year) of any criteria pollutant or 10 tpy of any single HAP (hazardous air
pollutant) or 25 tpy of any combination of HAPs. There were 189 listed hazardous air
pollutants in the Clean Air Act Amendments of 1990. Caprolactum and methyl ethyl ketone
(MEK) were removed from the list leaving 187 HAPs. For a current listing of HAPs see Title V
application instructions. (Wiowa.gov.state.ia.us\data\DNR_AQ_Shared\Operating
Permits\Forms\Instructions\ Instructions_T5_Revl-16.doc), Appendix A: Table A-l/A-2, or the
definition of "hazardous air pollutant" found in 22.100. Facilities with potential emissions less
than the major source thresholds may also be required to obtain a Title V permit for the reasons
outlined in section II. G.
I ll. Check PTE calculations - is it a major source (100 tpy, 10/25 tpy)?
Read the definition of "potential to emit" (PTE) found in 22.100. PTE is one of the most
commonly misunderstood and debated terms in air quality permitting.
In general. PTE for a given pollutant should be estimated as follows:
1. if applicable, use construction permit limits or an applicable emission standard from
state or federal rules;
2. if no applicable limit or standard exists, approved stack test data, mass balance, EPA
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approved emission factors, engineering judgement, etc. are normally used and based
on 8760 hours of operation per year (note: the above is listed in order of
preference).
One main exception to the above is if the unit is physically not capable of emitting anywhere
near its limit or standard. For example, AP-42 emission factors may be used for a natural gas-
fired unit where the only emissions are from the products of combustion, and the unit is only
subject to the general emission limits from Chapter 23 of the Iowa Administrative Code (IAC).
Emission factors can be used in this instance because they are highly rated, and because the
maximum capacity of this type of unit to emit particulate matter and SO2 do not come anywhere
near the general particulate matter and SO2 standards (0.1 gr/scf, 0.6 lb/MMBtu, 500 ppmv).
Examples of calculating PTE may be found in the document named "Potential and Allowable
Emissions Calculations" (Wiowa.gov.state.ia.us\data\DNR_AQ_Shared\Operating
Permits\Reference Documents\Calculation Documents \POT-ALLW.docx).
I la. acceptable assumptions?
Do the assumptions made in the emissions calculations appear to be reasonable? The phrase
"based on engineering judgment" needs to be qualified and quantified. The statement should be
explained on Form CA-01 using valid information such as stack tests on similar equipment, a
mass balance, or reasonable assumptions based on information published by EPA or a
recognized trade publication. Material from trade publications will require more scrutiny than
information provided by EPA.
I lb. acceptable emission factors?
Are the emission factors from an accepted published source? Examples of such sources would
be EPA's WebFIRE, AP-42, or source specific EPA reports
(http://www.epa.gov/ttn/chief/efpac/index.html). If a mass balance has been done for
VOC/HAPs in a material such as paint, the material safety data sheet (MSDS) or certified
product data sheet (CPDS) for the paint should be checked. Checking the MSDS or CPDS is
also useful for verifying what is in the raw materials going into a process.
Note: Emission factors based on stack test data will be after-control emission factors. Check the
calculations presented on Form CA-01 to make sure the control efficiency has not been applied
to the emissions shown on Forms 3.0 or 4.0. If you need to calculate the 95% confidence
interval of a stack test see the 95percent.xls file located on the n: drive
(Wiowa.gov.state.ia.us\data\DNR_AQ_Shared\Operating Permits\Forms\Spreadsheets\95percent
2 through 6 runs.xls).
I Ic. acceptable control efficiencies?
Note: If the point has no construction permit, associated control equipment may not be used to
estimate potential emissions.
Compare the control efficiencies claimed with the values in the "Iowa Title V Operating Permit
Control Efficiency Table" (Wiowa.gov.state.ia.us\data\DNR_AQ_Shared\Operating
Permits\Reference Documents\Guidance\ControlEfficiency.doc). Facilities may use control
efficiencies higher than those found in the table if they have supporting data. Vendor
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guarantees are not acceptable. Stack test data documenting the efficiency of the control
equipment at the facility or similar equipment at another facility is acceptable. Similar
equipment means the operating conditions are close to the same and the pollutant being
controlled is the same. The stack test must have been performed using Iowa specific or EPA
methods, and observed by a state or federal agency.
I Id. acceptable math?
Assumptions made in calculating emissions should be documented on CA-01 forms. Do the
calculations make sense?
Check for any other basis for claiming Title V applicability
Facilities with potentials emissions less than the major source thresholds may also be subject to
Title V for the reasons outlined below.
I ll. affected source under Title IV?
Facilities subject to Title IV (Acid Rain) are subject to Title V even if their potential emissions
are not above the major source thresholds. Electric utilities are the primary sources affected by
Title IV. Some backup generators that act as a substitute for power from the grid may be
subject to Acid Rain requirements. If the unit has a "New Unit Exemption", it is not subject to
Title V unless the potential emissions are greater than the major source thresholds. Units that
have a nameplate rating under 25 MW/hr and burn fuel with 0.05% sulfur or less by weight may
qualify for the exemption. Contact Chris Kj. with questions or visit EPA's Acid Rain web site
(http://www.epa.gov/airmarkets/index.html).
I 12. subject to NSPS?
Title V application General Facility Requirements Form should list any New Source
Performance Standards (NSPS) that a facility is subject to.
Sources subject to an NSPS are subject to Title V permitting requirements [22.101(l)"c"].
However, if the facility is a minor source (potential emissions below the major source
thresholds) and the NSPS does not directly state that a Title V permit is required, they have
been permanently deferred [22.101(2)]. For those minor sources required to get a permit by the
NSPS the source would be required to have a Title V permit covering only the unit(s) subject to
the NSPS.
New Source Performance Standards in general, cover industrial source types and specific
processes. Check the construction/modification dates for the emission unit to see if it is subject
to a specific NSPS. If a modification did not produce an increase in emissions of a regulated air
pollutant, it may not be covered under a specific NSPS [40 CFR 60.14(a)].
~3. subject to NESHAP (Parts 61 & 63)?
Title V application General Facility Requirements Form should list any National Emission
Standard for Hazardous Air Pollutants (NESHAPs) that a facility might be subject to.
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Sources subject to NESHAPs are subject to Title V permitting requirements [22.101(l)"c"].
However, if the facility is a minor source (potential emissions below the major source
thresholds) and the NESHAP does not directly state that a Title V permit is required, they are
permanently deferred [22.101(2)]. EPA action ending the deferral, would require a Title V
permit covering only the unit(s) subject to the NESHAP.
In general, Part 63 NESHAPs cover industrial source types and Part 61 NESHAPs cover
specific hazardous air pollutants. For more information on completed and upcoming
NESHAPs, visit EPA's Air Toxics web site (http://www.epa.gov/ttn/atw/eparules.html).
I 14. solid waste incinerator subject to section 129(e) of the Act?
Solid waste incinerators subject to section 129(e) of the Act are subject to Title V permitting
requirements. Currently, municipal waste combustors and medical waste incinerators are the
only source categories subject to these regulations. For more information, visit the EPA's Air
Toxics web site.
Confirm "insignificant activities" meet requirements specified in 567 IAC 22.103
Insignificant activities must meet the requirements specified in rule 22.103. Subrule 22.103(1)
lists activities that do not need to be included in the application. Subrule 22.103(2) lists
insignificant activities that do need to be included in the application.
Review Actual Emissions calculations from most recent emissions inventory as it relates to
an evaluation of Periodic Monitoring.
Review the emissions inventory for the most recent year available. Check for gross variations
in total emissions from year to year as an indication of changes in operation. Should this
increase or decrease cause additional scrutiny during the evaluation of Periodic Monitoring?
This is not intended to be a detailed audit the inventory by the Title V staff. Significant errors
in the emissions data should be referred to the emission inventory section for an audit.
In general, the preferred method of estimating actual emissions is as follows (listed in order of
preference): CEMs data, stack test data, mass balance, EPA approved emission factors,
engineering judgement, etc.
Things to keep in mind:
• If actual emissions are close to the PTE more monitoring may be warranted. If actual
emissions are over the PTE this may indicate a violation.
• Emissions reductions due to control equipment may be used to estimate actual emissions.
whether the equipment has a construction permit or not.
• Information that is more detailed may be needed to verify the values reported. Sometimes
the original application will have this information (i.e. MSDS).
• As mentioned previously, if the control efficiency is higher than the value shown in the
Iowa Title V Operating Permit Control Efficiency Table, it must be documented.
• If the facility has under-reported or over-reported emissions, we will evaluate what action to
take on a case-by-case basis. This may trigger an audit by the emissions inventory section.
I ll. Acceptable assumptions?
I \2. Acceptable emission factors?
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I |3. Acceptable control efficiencies?
I 14. Acceptable math?
I I J. Review the most recent inventory audit for any recurring problems with actual emissions
calculations. (It is possible the facility has not been audited. See links below to audit
database and folders.)
• Emissions inventory Title V audit tracking database:
\\iowa.gov.state.ia.us\data\DNR_AQ_Shared\AQBureau\Database\Emissions
Inventory\Title V Inventory Review Database.accdb
• Title V Fee Audit reports: Wiowa.gov.state.ia.us\data\DNR_AQ_Shared\Emissions
Inventory\Title V Fee Audits
• Title V Inventory reviews - reports:
\\iowa.gov.state.ia.us\data\DNR_AQ_Shared\Emissions Inventory\Title V Reviews
~K. Review Applicable Requirements (General Facility Requirements Form)
I ll. Check requirements review forms (General Facility Requirements) for claimed
applicability of various air programs, and confirm that all are identified
Has the facility checked the appropriate boxes on the General Facility Requirements form for
the type of operations that exist at the facility? What type of facility is it? What types of
pollutants are emitted? When were the emission units constructed or last modified?
~a. NSPS
~b. NESHAP - Part 61
~c. NESHAP - Part 63
I Id. Acid Rain/CSAPR
I le. Stratospheric Ozone
The State of Iowa does not have the authority to enforce the stratospheric ozone rules.
However, we do ask facilities to identify if they are subject to this rule. Applicability is
triggered by the use or manufacture of chlorofluorocarbons (CFCs). This is normally the use of
CFCs in refrigeration and air conditioning systems, including vehicle maintenance done on site.
The General Conditions of the Title V permit will list the basic requirements for sources subject
to this rule.
~f. CAM
The Compliance Assurance Monitoring (CAM) rule is found in 40 CFR 64 (promulgated
10/22/97). Only units with control equipment and an enforceable emission limitation or
standard are potentially subject to this rule. Most units will not be required to submit a
CAM plan until their permit is renewed. Examples of approved CAM plans may be found at
Wiowa.gov.state.ia.us\data\DNR_AQ_Shared\Operating Permits\Reference
Documents\CAM
I 12. Check applicable requirements (Emission Point Information Forms) claimed by
applicant against existing construction permits (for those sources that have
permits)
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When reviewing applicable requirements for an emission point, first look at the pollutant. Does
it have an applicable requirement? Next, consider what type of facility the application covers.
Are there any state or federal regulations that specifically cover this type of facility or a specific
operation? Does this point have a construction permit limit for a specific pollutant? What
applicable requirements have been referenced in the construction permit?
Depending on when the construction permit was written, you may see the following citations
from older versions of our rules: 400 IAC 4.3(2)"a" or 900 IAC 23.3(2)"a". The current citation
of the above rule is 567 IAC 23.3(2)"a".
I la. Confirm all construction permits are identified & requirements included
If the facility did not identify the construction permit for the emission point in the application
(Form 3.0 or Emission Point Information Forms), it may be possible to match the point and
permit by looking at the construction permit and emission unit description. If you have
difficulty matching up emission points with the appropriate construction permit numbers, you
should ask for a list from the facility. You may also need to ask for documentation as to why
certain units do not have construction permits. A list of current construction permits may also
be found in the latest Field Office inspection report.
I lb. Confirm that construction permit emission limits are federally enforceable
"as a practical matter"
Emissions limits placed in either construction permits or operating permits should be
enforceable as a practical matter. This means there has to be a tangible way of demonstrating
compliance. For example, compliance with a VOC ton/year limit could be demonstrated by
tracking the amount of material used per month and assuring that the VOC content of the
material was under a certain value.
An example of a limit that is not enforceable as a practical matter would be a ton per year
emission limit with no specific short-term verification such as daily, weekly or monthly
monitoring. The facility would not be able to confirm its compliance status until the end of the
year when they calculate the annual total. For a more detailed discussion on federal
enforceability issues, read EPA's guidance on limiting potential to emit in new source
permitting (Appendix D).
I Ic. Confirm any outstanding stack testing requirements
Review the information resulting from the Title V information request.
I 13. Check applicable requirements (Emission Point Information Forms) claimed by
applicant against the staff judgment of requirements for grandfathered /
unpermitted / exempted sources
Check to make sure the facility has identified all the requirements to which the emission point
or facility is subject. It is possible that the facility listed requirements that they may not be
subject to. Below is a list of general applicable requirements that an emission point may be
subject to.
I la. Particulate Matter - 23.3(2)
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I lb. Fugitive Dust - 23.3(2)"c"
I Ic. Visible Emissions - 23.3(2)"d"
~d. S02 - 23.3(3)
I le. Specific Processes - 23.4
I If. Provisions of any existing court orders, administrative orders
I |4. Confirm source has all necessary construction permits and verify all
exemptions from construction permitting
Look at the construction/modification dates on Form 3.0 to determine whether a construction
permit is required. If the unit was constructed or modified after September 23, 1970, it should
have a construction permit unless it was exempt or a VOC-only source. A VOC-only source
constructed after April 22, 1987 should have a construction permit, unless it was exempt.
L. Review Compliance Status
Look through the Emission Point Information forms for any points or rules that the facility
states they were not in compliance with at the time the application was submitted.
I ll. Confirm that facility is "in compliance" if applicant claims to be on Emission
Point Information Forms
I la. Check records for variances from applicable rules (567 IAC 21.2)
Look through the facility file for copies of any variances that have been issued to the facility. If
the facility has claimed a variance that you cannot find in our records or on the n: drive
(Wiowa.gov.state.ia.us\data\DNR_AQ_Shared\Compliance\Variances), ask the compliance
section or request a copy from the facility.
I 12. Confirm that facility is "on schedule" if non-compliance is claimed and a
compliance schedule is provided
I 13. Review compliance schedule for acceptability (is it timely?)
I |4. If necessary, complete Title V Facility Work Request form and discuss any
compliance issues and schedules with Compliance Unit
The Request for Enforcement Action form is located on the n: drive (N:\DNR Shared
Perm\Templates\AQ\Operating Permits\Title V Facility Work Request3.dotx).
I |5. Review most recent field office inspection report
HHM. Review Proposed Limits, if any have been included
Because of the grain mediation discussions, we no longer incorporate short-term (lb/hr)
limits into Title V permits. If the facility wishes to propose a short-term limit, they must go
through construction permitting. Otherwise, if the facility can demonstrate compliance
with a proposed annual limit by material balance or by tracking hours of operation, it can
usually be incorporated into the Title V permit.
I ll. Check calculations for acceptable assumptions, math, etc.
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Were realistic assumptions made in calculating the limit proposed by the facility? Does it
appear, based on past actual emissions, can they realistically comply with the proposed limit?
Facilities may try to propose limits that would reduce a unit's emissions to levels below those
requiring a stack test or O&M Plan. However, keep in mind that proposed limits might require
additional monitoring or testing to demonstrate compliance.
I |2. Confirm that proposed limits would constitute "Federally Enforceable
Permit Limits"
In general, annual emission caps are not considered federally enforceable without the
appropriate monitoring requirements (see Appendix D).
~N. Review Periodic Monitoring/CAM Proposals
Periodic Monitoring:
Review the emissions data for each point and compare this with DNR's Periodic Monitoring
Guidance Document (Appendix C). If the matrix found in Attachment 1 of DNR's Periodic
Monitoring Guidance requires an Agency Operation & Maintenance (O&M) Plan, the facility is
required to submit an O&M plan. DNR is required to review and approve or deny it. Compare
the proposed O&M Plan with the examples found on the n: drive
(Wiowa.gov.state.ia.us\data\DNR_AQ_Shared\Operating PermitsYReference
Documents\AGENCYOM). Are the plans similar to the examples on the p: drive? The
evaluation should also take into account the compliance history of the emission point and the
facility. Source should also be evaluated for any stack testing based on the guidelines found in
the Periodic Monitoring Guidance Document (Appendix C) notes.
CAM:
If the facility has any pollutant-specific emission units subject to CAM, the CAM requirements
will take the place of periodic monitoring requirements. Review the proposed CAM plan to
ensure it meets the requirements of 40 CFR 64.3 and 64.4. Example CAM plans are available
on EPA's Emissions Measurement Center (EMC) web site
(htto://www.epa.gov/ttn/cmc/cam.htm 1) or
\\iowa.gov.state.ia.us\data\DNR_AQ_Shared\Operating PermitsYReference DocumentsYCAM
Please document your decision with regard to periodic monitoring and CAM in the Title V
review
I ll. Confirm monitoring has been proposed for all sources meeting the criteria
I 12. Confirm acceptability of proposed monitoring
I 13. Develop draft monitoring for those affected sources for which none was
proposed, or for which the proposal was determined to be unacceptable
If no plans were submitted by the facility or their plan was unacceptable, prepare a sample plan
based on the examples found on the n: drive
(Wiowa.gov.state.ia.us\data\DNR_AQ_Shared\Operating PermitsYReference
DocumentsYAGENCY OM) or YYiowa.gov.state.ia.usYdataYDNR_AQ_SharedYOperating
PermitsYReference DocumentsYCAM as well as EPA's examples
(http://www.epa.gov/ttn/emc/cam.html or http://www.epa.gov/ttn/atw/utrain.html). Take into
account the operating parameters of the control equipment at the facility.
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~o. Send outreach follow-up letter via certified mail with request for any additional
information (If a site visit was done.)
Deadline date for response:
Send a follow-up letter to the responsible official, and copy the permit contact person and
field office. For a more detailed discussion of what to include in the follow-up letter, see
the follow-up letter guidance located on the n: drive
(Wiowa.gov.state.ia.us\data\DNR_AQ_Shared\Operating PermitsYReference
Documents\Guidance\FollowUp Letters. docx).
I I P. Update tracking information in Title V database including all information requests to the
facility
The Title V database is located on the
(Wiowa.gov.state.ia.us\data\DNR_AQ_Shared\AQBureau\Database\Operating Permits
\permits.mdb). Tracking information can be updated by opening the "Title V Data Entry
Form," searching for the facility you are working on, and then clicking on the "Review" tab.
The following milestones are tracked:
¦ date the project is assigned ("Assigned")
¦ date the TV information request is sent ("TVInfoRq")
¦ date the technical review starts (i.e. 30day letter is sent to facility) ("TechRvw")
¦ date the draft permit is sent to the facility for review prior to public notice
("FacilityRvw")
¦ date the public comment period begins ("Notice")
¦ date permit is issued ("Issued")
¦ date permit expires ("Expiration")
Other information that should be updated in the database includes the permit # and contact
information. See Weston if you have any questions.
~ill. DRAFT TITLE V OPERATING PERMIT
What to look for in draft construction permits sent for review by the construction permitting
section.
Is the language in a plant wide limit consistent across all construction permits you have
identified during your review while drafting the Title V permit.
Is it a true plant wide limit or is it covering a particular set of processes. Would it be
helpful to note in the construction permit that combustion sources are not included?
Look for conflicting permit conditions in several different construction permits.
Updated stack characteristics.
Correct emission point, emission unit and process description as compared to the Title V
application. We will go with the Title V application values, but this is an opportunity to
identify conflicts.
Are the NSPS and NESHAP applicability determinations still valid today?
Testing requirements - are completed stack tests noted in the revised construction permit,
are the correct EPA test methods being referenced.
Templates used to draft the Title V permit are available on the n: drive (N:\DNR Shared
Perm\Templates\AQ\Operating Permits\). Below is a description of each file:
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Permit:
[Permit\TV Permit CoverPage2c_permit#_initials.dotx] = cover page
[Permit\Table of Contentspermit#_initials.dotx] = table of contents and abbreviations page
[PermitYEquipment Listpermit#_initials.dotx] or [PermitYEquipment List w Small Unit
Notepermit#_initials.dotx] = permit equipment list (2 different styles)
[Permit\ Plant-wide Conditions3permit#_initials.dotx] = plant-wide conditions
[Permit\EP Specific Conditions w CAMinitialpermit#_initials.dotx] or [PermitYEP Specific
Conditions w CAMrenewal_facility 0&Mprmt#_int.dotx] = emission point-specific
conditions (duplicate for each emission point)
[Permit\General Conditions v27.dotx] = general conditions
Other Documents:
Directory of N:\DNR Shared Perm\Templates\AQ\Operating PermitsYFactsheets Folder for
Factsheet templates
Directory of N:YDNR Shared PermYTemplatesYAQYOperating PermitsYPublic Notice Folder
for Public Notice templates
Directory of NYDNR Shared PermYTemplatesYAQYOperating Permits Folder for various
Title V templates
Master index of Title V templates see N:YDNR Shared PermYTemplatesYAQYOperating
PermitsYTemplateMasterList.docx
~A. Incorporate all "generally applicable requirements" into draft permit
These are part of the permit template, but there may be cases where a facility-wide limit has
been set. If a facility-wide limit exists, it should be placed in the plant-wide conditions section
of the permit. An example would be a facility-wide cap on VOCs.
I IB. Incorporate all source specific applicable requirements into draft permit
These may include construction permit conditions, pollutant specific requirements from the
Iowa Administrative Code (IAC) and source specific standards such as Acid Rain, NSPS or
NESHAP standards. Some facilities may also have conditions set forth in Administrative
Orders that should be incorporated into the permit.
Iowa AG's Office htto://www.iowaattornevgeneral.org/latest news/
Administrative Orders are filed in the construction folders. Administrative orders issued from
1983 through 2002 are posted at
YYiowa.gov.state.ia.usYdataYDNR_AQ_SharedYAQBureauYLegalYAdministrative Orders ProjectY.
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Incorporate approved "proposed limits" (if any) for specific sources into draft
Proposed limits are limits that have been requested by the facility. 567 IAC 22.108(14) should
be cited as the authority for requirement for requested limits. Note that past Title V permits
may have used 22.108(13) instead.
Incorporate approved compliance schedule (if any) into draft permit
If the facility is out of compliance with an applicable requirement at the time of permit issuance,
a timeline for coming into compliance should be incorporated into the permit. For example, the
facility needs to apply for a construction permit by a specific date. Read subparagraphs
22.105(2)"h" and "j" for more information regarding compliance schedules.
All compliance plans should be discussed with the compliance section before incorporating
them into the draft permit.
Incorporate periodic monitoring & CAM conditions for those sources meeting criteria
Use DNR's Periodic Monitoring Guidance document to evaluate the monitoring conditions for
emission points and incorporate the appropriate conditions into the permit or the CAM criteria
for CAM affected sources.
Confirm, after federal deadline of June 20,1999, that sources subject to Risk Mgt. Plans,
112(r), have submitted their plan to EPA (General Facility Requirements Form)
Iowa does not enforce the section 112(r) regulations. However, we are required to confirm that
affected facilities have filed their plans with EPA - Region 7. See Chris Kj. for a list of
facilities that have submitted Risk Management Plans (RMPs).
Attach and cross-reference any necessary appendices (i.e. Acid Rain Permit, orders,
NESHAPs, etc.)
If the facility is subject to Acid Rain, the applicable requirements (SOx and NOx) are
documented by referencing the appropriate Acid Rain permit in the Operating permit. See the
example cut and paste page on the n: drive (N:\DNR Shared Perm\Templates\AQ\Operating
Permits\Permit\TV Permit Condition Cut & Paste Page v8a.dotx). Any administrative order
that is attached must have the signatures of the Director and the facility.
Incorporate any "state only" or "local only" limitations or requirements and
identify them as such
An example of a "state only" limitation/requirement would be a provision in a DNR issued
variance from an applicable requirement, or the open burning requirements listed in the general
conditions. Mercury testing and monitoring of coal fired electric utilities is another example of
"state only".
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For renewal applications, review semi-annual monitoring reports & annual compliance
certifications submitted during past permit term
The previous permit term's Title V compliance reports should be available in the facility file
folders. A summary of all the Title V compliance reports received is available in one of the
compliance section's access databases
(Wiowa.gov.state.ia.us\data\DNR_AQ_Shared\AQBureau\Database\Compliance\ TV-
ComplianceReports. accdb).
Prepare Fact Sheet, Permit Writer Notes & Spreadsheets that discuss the review decisions
Fill out the Fact Sheet template with the appropriate information.
Permit Writer Notes are intended to document the thought process of the permit writer and
include the decisions made during the drafting of the permit. Periodic monitoring decisions,
compliance status and compliance plans should be discussed, as well as applicability of federal
regulations such as NSPS, NESHAP, Stratospheric Ozone, CAM, PSD, etc. Currently there is
no standard template for Permit Writer Notes, but all should contain the basic information noted
above.
Spreadsheets are often a useful way to summarize the facility's potential and actual emissions
from each emission point. If the facility's calculated values differ from the calculations done by
the permit writer, the reason for the difference should be noted.
Give the Draft Permit, Fact Sheet, & Permit Writer's Notes to your senior for review
prior to sending the documents to the facility. Once a senior has reviewed the documents,
make any necessary corrections prior to sending the information to the facility.
The senior will enter the date they complete their review into EASYAir.
A senior should conform to the following guidelines for this review:
a) General format of the permit: The draft permit should conform to the most current format
version.
b) Title V applicability: The Title V applicability must be documented, such as whether a
facility is a major source for criteria/HAP/GHG pollutants.
1. For a minor source required to have a TV permit, the review notes must document the
reason for the TV permit and the units that should be included in the TV permit.
2. For a facility that is a single stationary source with other facilities, the review notes should
identify all the facilities under the one-source determination and specify the related program
applicability issues, such as whether all the facilities together are a major source for
criteria/HAP pollutants.
c) Insignificant activities: The qualification of insignificant activities should be checked and
their capacities (combustion sources and storage tanks) should be specified.
d) Applicable construction permits: For an initial TV permit, all applicable construction
permits should be checked; but for a renewal TV permit, only the construction permits
issued after last TV permit was issued should be checked.
e) Applicable federal rules: For all the federal rules, such as NSPS, NESHAP, and Acid
Rain/CSAPR, the applicability determination should be documented in the review notes.
Related, but non-applicable, rules should be documented as to why the rules are not
applicable to the facility at this time.
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f) Periodic monitoring/CAM: The type and level of periodic monitoring should be based on
the PMG Guidance and must be sufficiently documented in the review notes and/or
calculation spreadsheet. The selection, range, and the monitoring frequency of indicators in
a CAM plan should be justified and documented.
g) Other issues: Other issues could be identified during the review and these issues should be
evaluated and discussed with the permit writer.
The level of review details and thoroughness could be different depending on the specific
permits under review and the experience and expertise of the permit writer.
I IL. Send Draft Permit, Fact Sheet, & Permit Writer's Notes to responsible official and plant
contact (7/15-day informal facility review period)
Deadline Date for Response:
Enter the date you send the draft permit to the facility in both EASYAir and access.
Insert the end date of facility review period. It is acceptable to extend the review period if it is a
complex permit, or there is sufficient justification for an extension. To expedite the facility
review period, it is acceptable to e-mail these documents.
Schedule outreach visit during facility review period if the facility wishes to
discuss draft permit (notify field office if the visit is to take place at the facility) (optional)
The purpose of this visit is to discuss any concerns the facility has with the draft permit and try
to come to some kind of resolution.
Update tracking information in Title V database including all information requests to the
facility
Confirm with compliance that there are no current compliance actions with the facility
prior to proceeding to the public notice phase.
This step was added to avoid putting a permit on notice that has an active compliance action but
no compliance plan incorporated in to the Title V permit.
~IV. PUBLIC NOTICE INTENT TO ISSUE TITLE V PERMIT
The E-notice process will revolve around the normal publication of the EcoNewsWire which
goes out every Thursday. Information that goes to the listserve can be emailed as late as mid-
day Wednesday if necessary. The standard process will be to email the information to the
website folks (Don or Brad) on Monday. This will allow enough time for the two day turn
around for the web posting and be in plenty of time for the listserve. Public notices will start on
a Thursday for the E-notice process. This process will be revisited in the future to see how
things are working. It is also possible to post the information through the Air Quality Technical
listserve by contacting Wendy, but the EcoNewsWire is the preferred method. A print out of
the Title Draft Permit webpage on the first day of the public comment period will act as the
proof of publication. Ensure the print out has a date stamp.
~A. If comments are received during facility review period, make any necessary
changes to permit documents
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~m.
~n.
~o.
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It may not always be possible to incorporate all facility comments. If we cannot incorporate the
suggested changes, we should explain in the review notes or in correspondence why changes
they requested are not possible under current regulations or department policy.
Send draft permit to & solicit comments from:
I ll. EPA (via email) - public notice, fact sheet, permit writer's notes, spreadsheets and
draft permit (concurrent 45-day EPA review begins when public comment starts)
Date 45-day EPA review period ends:
E-mail draft permit documents to Peter.David@epamail.epa.gov. Send PDF or Word files.
Excel spreadsheets should be converted to PDF. Remember to print a copy of the e-mail, and
insert it into the bound record copy of the final title v permit as correspondence because this
will be our documentation that it was sent to EPA for their 45-day review.
Example e-mail text:
Attached are the draft permit and associated review documents for [Facility Name XYZ], The
public comment period starts on [xx/xx/xx] and ends on [xx/xx/xx].
The Iowa DNR considers EPA's 45-dav review period required by 40 CFR 70.8 to begin at the
start of the public comment period. Accordingly, the close of EPA's 45-dav review period of
this draft permit is [xx/xx/xx]. Any comments received during the public comment period will-
be forwarded to EPA, and EPA's 45-dav review period will be extended if requested.
Please let me know if you have any questions or concerns regarding the draft permit.
[insert contact info]
I 12. Post on AQB's web site - (Monday before the notice date.) (30-day public
comment period starts when published (Thursday))
I la. E-mail Jason Dowie and CC: Brad (backup Brad Ashton) PDF's of public
notice, fact sheet (with permit writer notes attached), and draft permit.
Also include the text for Don to send to the EcoNewsWire contacts.
The above documents should be e-mailed to Jason Dowie in PDF format. See Chris Kj. or
Weston if you need assistance creating a PDF file. Remember to attach the permit writer notes
to the factsheet before you send the documents. Follow these guidelines when sending the draft
permits:
Include the name of the facility (exactly as it is to be posted on the web), city location of the
facility, and its EIQ number (XX-XXXX)
Send the public notice, fact sheet and draft permit with the following naming scheme
(replacing the pound signs with the 4-digit portion of the facility's EIQ number):
[####p.pdf] for the public notice
[####f.pdf] for the fact sheet
[####d.pdf] for the draft permit
Include the End Date of the Public Notice
* Allow a minimum of 2 working days for completion. If Jason Dowie will be unavailable for two or
more business days, send your request to Brad Ashton.
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Use the template language (posting text) from the Access database email switchboard or the
EcoNewsWire template under the Public Notice folder for Operating Permit templates.
Please use Associated Press Style for addresses, months and time for EcoNewsWire
publication.
a. Dates: When used with a specific date, abbreviate months Jan., Feb., Aug.,
Sept., Oct., Nov., and Dec., e.g., Jan. 2. Use the numeral for a date, e.g., Sept. 10
not Sept. 10th. We probably don't need the year, unless the start time of the
comment period ends in one year and the end time is in another.
b. Time: Use colon to separate hour and minutes, e.g., 11:30; but do not need
minutes when referring just to the hour, e.g., 11 a.m. Use lower case for a.m.
and p.m.
c. Addresses:
1. List the County where facility is located.
2. Use abbreviations Ave., Blvd. and St. with a numbered address. Spell out
alley, drive and road.
3. Always use a figure for an address number, e.g, 9Morningside Circle.
4. Spell out First through Ninth when part of a street name; use figures for
10th and above, e.g., 122 First St., 103 22nd St.
5. Abbreviate compass points: 222 E. Campus Drive or 143 Green St. N. W.
6. Don't list the state or zip code.
I lb. Don will email the EcoNewsWire contacts the information for posting on
Tuesday with the subject line "AQ Permits for EcoNewsWire on
MMMM of Eco"
Contacts: Primary Jessie.Brown@dnr.iowa.gov and CC:
Karen.Grimes@dnr.iowa.gov and Alex. Murphv@dnr.iowa.gov
I Ic. Date public comment period begins:
I Id. Date public comment period ends:
I le. Print a copy of the Title V draft webpage on the first day of the public
notice. Ensure there is a date stamp on the printed page. A suggestion is to
print this to a pdf to maintain a copy with electronic permitting documents on
our network drives.
I 13. Post in local library -
This information may be found in the Iowa Library Directory's web site
(http://www.statelibraryofiowa.org/ld/c-d/directories).
I la. Send via first class mail - Cover letter and public notice
The above documents should be available at the information desk of the library. There may
be locations that do not have a library. Other places that may be used to post public notices
are city hall, post offices, fire stations or other public buildings.
An example cover letter is located at (N:\DNR Shared Perm\Templates\AQ\Operating
Permits\Public NoticeYPublicNotice to Library LtrRe_Tra Enotice.dotx).
I |4. Facility -
I la. Mail via first class to responsible official & permit contact - public notice,
fact sheet, permit writer's notes, spreadsheets and draft permit
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I 15. Surrounding states - E-mail public notice (if applicable)
For facilities that are within 50 miles of the border of another state, we are required to give
notice to the affected state or local programs (Omaha, NE). Use the "Title V Public Comment
Email Notify" form in the Title V database switchboard
(Wiowa.gov.state.ia.us\data\DNR_AQ_Shared\AQBureau\Database\Operating Permits \permits.
accdb) to generate a notice to affected states and people who have requested a notification.
I 16. Affected local programs (Omaha) - Mail public notice (if applicable)
I 17. Field Office - E-mail public notice, fact sheet, permit writer's notes, spreadsheets
and draft permit
E-mail the above documents to the appropriate Field Office Supervisor and lead air person
(listed in section II. C).
See Appendix B for a list of counties and the corresponding Field Office if you need to confirm
which Field Office to send the documents to. You can also use the "Affected States" query in
the title v database to locate the appropriate field office.
I 18. E-mail public notice to persons who have requested to be on a mailing list
Use the "Title V Public Comment Email Notify" form in the Title V database switchboard
(Wiowa.gov.state.ia.us\data\DNR_AQ_Shared\AQBureau\Database\Operating Permits \permits.
accdb) to generate a notice to affected states and people who have requested a notification.
~C. Update tracking information in Title V database
Enter the starting date of the public notice in both EASYAir and access.
~D. Schedule outreach visit during public comment period if the facility wishes to
discuss proposed permit (notify field office if the visit is to take place at the facility)
(optional)
I IE. If a public hearing is held, e-mail the required information to be posted on the State
Public Meeting Calendar
Use the form posted at Wiowa.gov.state.ia.us\data\DNR_AQ_Shared\Operating
Permits\Procedure\Public meeting calendar memo.docx in order to organize the information to
be posted on the state's Public Meeting web site (https://www.iowa.gov/pmc/pmc.php).
~V. ISSUE TITLE V PERMIT
~A. If comments were received during the public comment/EPA review period:
I ll. Develop Responsiveness Summary
The responsiveness summary is used to address all comments received during the public
comment period. This should be written in a specific format. Use the same format as the
example on the n: drive (N:\DNR Shared Perm\Templates\AQ\Operating
Permits\Permit\Responsiveness Summary.dotx).
I 12. Make necessary changes to permit documents
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We will not necessarily incorporate all public, facility, or EPA comments. This is done on a
case-by-case basis. Discuss this with Weston or Chris Kj.
I |3. Provide Responsiveness Summary and any revised permit documents to all
commenters, EPA, field office and facility (depending on the type of comments,
this may be done with the final permit)
Before issuing final permit, confirm with EPA that it is acceptable to do so based on the
proposed permit. If EPA requests it, give additional 45-days for their review of the
proposed permit.
Call or e-mail David Peter to confirm whether EPA intends to review the draft permit, or
wishes to have an additional 45-days. E-mail a list of any changes to the permit,
telephone: (913) 551-7397
E-mail: peter.david@epa.gov
Remove "draft" or "proposed" from permit, get permit number, add dates for permit
term, change dates of stack tests to correspond with permit dates, and get signature
The permit number list is located in Weston's cubicle. The permit term should be five (5)
years. The expiration date will be one day prior to the day the permit was issued (i.e. Issue
Date: March 21, 2003; Expiration Date: March 20, 2008). If this seems confusing, think of
a calendar year. One year is Jan. 1 to Dec. 31. The next Jan. 1 starts the next year. Use can
also use the Title V Permitting Dates form in the Title V database switchboard
(P:\Database\Title_V\ permits.mdb click on the "Title V Permitting Dates" tab) to get the
proper dates for the permit.
The following format will be used for permit renewals:
##-TV-###R#
1. Keep the original permit number.
2. Add the renewal designation ("R#").
3. Remove the modification designation if the permit had been modified ("-M###"). We
will add the modification designation back to the permit number, starting with "-M001"
if the renewed permit is modified during the new permit term.
4. The footer should show permit writer initials (left) - page number (center) - issuance
date and permit number (right).
Mail final permit, permit writer's notes, spreadsheets (if necessary) and Responsiveness
Summary (if one was created) to the following:
H|l. Facility - responsible official (via certified mail) & permit contact (e-mail)
~2. EPA (via e-mail)
H|3. Field Office (via e-mail)
H|4. All commenters (via e-mail)
An example cover letter is available on the n: drive
(N:\DNR Shared Perm\Templates\AQ\Operating
Permits\Permit\FinalPermit CoverLtr2aBRGipp.dotx).
Send e-mail notification with a completed form regarding permit issuance to "TV Permits
Notify" group in Google Mail
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Enter the date you send the permits notify email into EASYAir.
Your e-mail should include the following information:
Are there any stack tests required? If yes, list the affected emission point #'s.
Are there any compliance plans? If yes, briefly describe the non-compliance issue and the
affected emission point #'s.
Are there any NESHAP or NSPS affected units? If yes, list the affected emission point #'s.
Location of the final permit and review notes on the p: drive.
The format and an example is available on the p: drive (N:\DNR Shared
Perm\Templates\AQ\Operating Permits\Permit\TV Permits Notify.dotx).
I IF. Copy all electronic files associated with permit review including e-mails to:
\\iowa.gov.state.ia.us\data\DNR AQ Sharcd'Qperating Permits\FINAL.TV\riast 4 digits of
eiq#]
It is important for staff to be able to distinguish between electronic files for initial permits,
modified permits, and renewed permits. Below is an example of how folders should be named.
Subfolders can be created, if necessary.
\\iowa.gov.state.ia.us\data\DNR AO Shared\Qperating Permits\FINAL.TV\9999\
\initial\
\modl\
\mod2\
\mod3\
\renewall\
\modl\
\renewal2\
\modl\
\mod2\
~G. E-mail Jason Dowie (backup Brad Ashton) a PDF of the final permit for posting on AQB's
web site
In your e-mail:
include the name of the facility (as it is to be on the web), the city in which it is located, the
permit number, and the EIQ number the name of the file should be the permit number with
all letters being capitalized (i.e. "02-TV-005M002.pdf')
If Applicable - identify the previous name of the facility if it has changed names.
* Allow a minimum of 2 working days for completion. If Jason Dowie will be unavailable for two or
more business days, send your request to Brad Ashton.
~H. Update tracking information in Title V database, including the hyperlink, update or enter
the permit number and enter stack tests in the stack test database. Enter the issuance
date and permit duration dates in
EASYAir.(https://programs.iowadnr.gov/stacktest/pages/login.aspx). Instruction for the stack
test database are here N:\DNR Shared Perm\Templates\AQ\Operating Permits\SOP for Entering
Title V Tests into Stack Test Database2.dotx.
I ll. Schedule outreach visit if the facility wishes to discuss the final permit (notify field office if
the visit is to take place at the facility) (optional)
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I I J. Bind Permit and include the following (start a new binder for renewed permits or a large
clip can be used):
I la. final permit
~b. review check sheet
I Ic. fact sheet
I Id. public notice with proof of publication (print out of webpage)
I le. responsiveness summary (if one was created)
I If. permit writer's notes & spreadsheets
I lg. correspondence
~k.
~vi. CLEAN-UP TITLE V RECORDS
Once you have completed the file cleanup process enter the date into EASYAir.
~A. Stage records for long-term storage. (N:\DNR Shared Perm\Templates\AQ\Operating
Permits\Record file cleanup procedure for Title V June 2018_v2.dotx)
I IB. Recycle extra copies of emissions inventories and applications (there should only be one
copy of each)
The order of the documents listed above is the same general order in which the record copy of
the final permit should be put together. Binders and labels are available in the office supply
area or a large metal clip may be used instead. A template for the label is available on the
N:drive (N:\DNR Shared Perm\Templates\AQ\Operating Permits\Permit\TV Permit
Label.dotx).
Upload a PDF version of the Title V permit and permit writer notes to EASYAir
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APPENDICES
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AFFECTED STATES/LOCAL PROGRAMS
(5/10/2007)
See Title V database switchboard form "Title V Public Comment Email Notify"
p:\title_v\corresp\AffectedStates\List.doc
-------
FIELD
CO#
COUNTY
FO#
01
Adair
4
02
Adams
4
03
Allamakee
1
04
Appanoose
5
05
Audubon
4
06
Benton
1
07
Black Hawk
1
08
Boone
5
09
Bremer
1
10
Buchanan
1
11
Buena Vista
3
12
Butler
2
13
Calhoun
3
14
Carroll
4
15
Cass
4
16
Cedar
6
17
Cerro Gordo
2
18
Cherokee
3
19
Chickasaw
1
20
Clarke
5
21
Clay
3
22
Clayton
1
23
Clinton
6
24
Crawford
4
25
Dallas
5
26
Davis
6
27
Decatur
5
28
Delaware
1
29
Des Moines
6
30
Dickinson
3
31
Dubuque
1
32
Emmet
3
33
Fayette
1
LOCATIONS FOR IOWA
CO#
COUNTY
FO#
34
Floyd
2
35
Franklin
2
36
Fremont
4
37
Greene
4
38
Grundy
2
39
Guthrie
4
40
Hamilton
2
41
Hancock
2
42
Hardin
2
43
Harrison
4
44
Henry
6
45
Howard
1
46
Humboldt
2
47
Ida
3
48
Iowa
6
49
Jackson
1
50
Jasper
5
51
Jefferson
6
52
Johnson
6
53
Jones
1
54
Keokuk
6
55
Kossuth
2
56
Lee
6
57
Linn
1
58
Louisa
6
59
Lucas
5
60
Lyon
3
61
Madison
5
62
Mahaska
5
63
Marion
5
64
Marshall
5
65
Mills
4
66
Mitchell
2
>UNT]
[ES
CO#
COUNTY
FO#
67
Monona
4
68
Monroe
5
69
Montgomery
4
70
Muscatine
6
71
O'Brien
3
72
Osceola
3
73
Page
4
74
Palo Alto
3
75
Plymouth
3
76
Pocahontas
3
77
Polk
5
78
Pottawattamie
4
79
Poweshiek
5
80
Ringgold
4
81
Sac
3
82
Scott
6
83
Shelby
4
84
Sioux
3
85
Story
5
86
Tama
5
87
Taylor
4
88
Union
4
89
Van Buren
6
90
Wapello
6
91
Warren
5
92
Washington
6
93
Wayne
5
94
Webster
2
95
Winnebago
2
96
Winneshiek
1
97
Woodbury
3
98
Worth
2
99
Wright
2
p:\title_v\RefDoc\County-FO List.doc
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Link to DNR's Periodic Monitoring Guidance:
Wiowa.gov.state.ia.us\data\DNR AO Shared\Operating Permits\Reference Documents\Periodic
Monitoring\Pmguide3updatedM5.doc
Link to EPA's Guidance on Limiting Potential to Emit in New Source Permitting:
Wiowa.gov.state.ia.us\data\DNR AO Shared\Operating Permits\Reference
Documents\Guidance\Limiting PTE in NSR.pdf
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Appendix E.
I ll. Alt Method - Newspaper - (30-day public comment period starts when published)
The public notice must be published for one day in the newspaper of record for the area the
facility is located. The newspaper of record is the paper with the largest number of readers in
the area. The newspaper of record can normally be found at the Iowa Newspaper Association's
website (http://www.inanews.com/). For renewals you should be able to look at the bound
copy of the previous permit for the newspaper in which the public notice had been published.
I la. Contact local Newspaper by phone
You need to ask the newspaper if they publish on a daily or weekly basis, and what days they
publish. You should also ask how far in advance they must receive the public notice in order for
it to be published on the day you are planning.
I lb. Inquire about the approximate cost of a legal notice
If it is more than $50, you will need supervisor approval. Note that the Omaha World Herald
may be too expensive.
I Ic. E-mail public notice
I Id. Date public comment period begins:
I le. Date public comment period ends:
Special Processing:
Gannett Company (DM Register,USA Today,Press Citizen, etc...) now requests payment at the time a
public notice order is placed. If staff need to publish a public notice in a Gannett Company publication
a P-card will need to be used for payment when they place the order.
1. Staff member contacts publication representative and places order.
2. Payment Process:
a. By phone- transfer publication representative to Norma for payment. If Norma is out,
publication representative can leave a message and Norma will call them back to make
payment.
b. By email- copy Norma on email to publication representative. Norma will call the
publication representative to make payment.
3. Norma will use the bureau P-card to process the payment request on the phone and request that
an invoice be sent to her showing that the payment was made.
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Iowa Department of Natural Resources
Draft Title V Operating Permit Fact Sheet
This document has been prepared to fulfill the public participation requirements of 40 CFR Part
70 and 567 Iowa Administrative Code (IAC) 22.107(6). 40 CFR Part 70 contains operating
permit regulations pursuant to Title V of the Clean Air Act.
The Iowa Department of Natural Resources (DNR) finds that:
1. Facility Name, located at Address, city, IA zip has applied to renew their Title V Operating
Permit. The designated responsible official of this facility is RO Name.
2. Facility Name is a facility description. This facility consists of # emission units with potential
emissions of:
Pollutant
Abbreviation
Potential Emissions
(Tons per Year)
Particulate Matter (< 2.5 |j,m)
PM2.5
Particulate Matter (<10 |xm)
PM10
Particulate Matter
PM
Sulfur Dioxide
S02
Nitrogen Oxides
NOx
Volatile Organic Compounds
VOC
Carbon Monoxide
CO
Lead
Lead
Hazardous Air Pollutants (1)
HAP
(1)May include the following: List all HAPs (If over 25 reference application).
3. Facility submitted a Title V Operating Permit renewal application on Date and any additional
information describing the facility on Date. Based on the information provided in these
documents, DNR has made an initial determination that the facility meets all the applicable
criteria for the issuance of an operating permit specified in 567 IAC 22.107.
4. DNR has complied with the procedures set forth in 567 IAC 22.107, including those
regarding public notice, opportunity for public hearing, and notification of EPA and
surrounding state and local air pollution programs.
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DNR procedures for reaching a final decision on the draft permit:
1. The public comment period for the draft permit will run from Publication Date through End
Date. During the public comment period, anyone may submit written comments on the
permit. Mail signed comments to Permit Writer at the DNR address shown below. The
beginning date of this public comment period also serves as the beginning of the U.S.
Environmental Protection Agency's (EPA) 45-day review period, provided the EPA does not
seek a separate review period.
2. Written requests for a public hearing concerning the permit may also be submitted during the
comment period. Any hearing request must state the person's interest in the subject matter,
and the nature of the issues proposed to be raised at the hearing. DNR will hold a public
hearing upon finding, on the basis of requests, a significant degree of relevant public interest
in a draft permit. Mail hearing requests to Permit Writer at the DNR address shown below.
3. DNR will keep a record of the issues raised during the public participation process, and will
prepare written responses to all comments received. The comments and responses will be
compiled into a responsiveness summary document. After the close of the public comment
period, DNR will make a final decision on the renewal application. The responsiveness
summary and the final permit will be available to the public upon request.
Permit Writer
Iowa Department of Natural Resources - Air Quality Bureau
Wallace State Office Building
502 E 9th St.
Des Moines, Iowa 50319-0034
Phone: (515) Phone Number
E-mail: Name@dnr.iowa.gov
DNR concludes that:
1. DNR has authority under 455B.133 Code of Iowa to promulgate rules contained in 567 IAC
Chapters 20-35, including, but not limited to, rules containing emission limits, providing for
compliance schedules, compliance determination methods and issuance of permits.
2. DNR has the authority to issue operating permits for air contaminant sources and to include
conditions in such permits under 455B.134 Code of Iowa.
3. The emission limits included in this permit are authorized by 455B. 133 Code of Iowa and 567
IAC Chapters 20-35.
4. DNR is required to comply with 567 IAC Chapter 22 in conjunction with issuing a Title V
Operating Permit.
5. The issuance of this permit does not preclude the DNR from pursuing enforcement action for
any violation.
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IV. General Conditions
This permit is issued under the authority of the Iowa Code subsection 455B. 133(8) and in
accordance with 567 Iowa Administrative Code chapter 22.
Gl. Duty to Comply
1. The permittee must comply with all conditions of the Title V permit. Any permit noncompliance
constitutes a violation of the Act and is grounds for enforcement action; for a permit termination,
revocation and reissuance, or modification; or for denial of a permit renewal application. 567IAC
22.108(9) "a"
2. Any compliance schedule shall be supplemental to, and shall not sanction noncompliance with,
the applicable requirements on which it is based. 567IAC 22.105 (2) "h"(3)
3. Where an applicable requirement of the Act is more stringent than an applicable requirement of
regulations promulgated under Title IV of the Act, both provisions shall be enforceable by the
administrator and are incorporated into this permit. 567IAC 22.108 (l)"b"
4. Unless specified as either "state enforceable only" or "local program enforceable only", all terms
and conditions in the permit, including provisions to limit a source's potential to emit, are
enforceable by the administrator and citizens under the Act. 567 IAC 22.108 (14)
5. It shall not be a defense for a permittee, in an enforcement action, that it would have been
necessary to halt or reduce the permitted activity in order to maintain compliance with the
conditions of the permit. 567 IAC 22.108 (9)"b"
6. For applicable requirements with which the permittee is in compliance, the permittee shall
continue to comply with such requirements. For applicable requirements that will become effective
during the permit term, the permittee shall meet such requirements on a timely basis. 567 IAC
22.108(15)"c"
G2. Permit Expiration
1. Except as provided in rule 567—22.104(455B), permit expiration terminates a source's right to
operate unless a timely and complete application for renewal has been submitted in accordance with
rule 567—22.105(455B). 567IAC 22.116(2)
2. To be considered timely, the owner, operator, or designated representative (where applicable) of
each source required to obtain a Title V permit shall submit on forms or electronic format specified
by the Department to the Air Quality Bureau, Iowa Department of Natural Resources, Air Quality
Bureau, Wallace State Office Building, 502 E 9th St., Des Moines, IA 50319-0034, two copies
(three if your facility is located in Linn or Polk county) of a complete permit application, at least 6
months but not more than 18 months prior to the date of permit expiration. An additional copy must
also be sent to U.S. EPA Region VII, Attention: Chief of Air Permitting & Standards Branch, 11201
Renner Blvd., Lenexa, KS 66219. Additional copies to local programs or EPA are not required for
application materials submitted through the electronic format specified by the Department. The
application must include all emission points, emission units, air pollution control equipment, and
monitoring devices at the facility. All emissions generating activities, including fugitive emissions,
must be included. The definition of a complete application is as indicated in 567 IAC 22.105(2).
567 IAC 22.105
G3. Certification Requirement for Title V Related Documents
Any application, report, compliance certification or other document submitted pursuant to this
permit shall contain certification by a responsible official of truth, accuracy, and completeness. All
certifications shall state that, based on information and belief formed after reasonable inquiry, the
statements and information in the document are true, accurate, and complete. 567 IAC 22.107 (4)
G4. Annual Compliance Certification
By March 31 of each year, the permittee shall submit compliance certifications for the previous
calendar year. The certifications shall include descriptions of means to monitor the compliance
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status of all emissions sources including emissions limitations, standards, and work practices in
accordance with applicable requirements. The certification for a source shall include the
identification of each term or condition of the permit that is the basis of the certification; the
compliance status; whether compliance was continuous or intermittent; the method(s) used for
determining the compliance status of the source, currently and over the reporting period consistent
with all applicable department rules. For sources determined not to be in compliance at the time of
compliance certification, a compliance schedule shall be submitted which provides for periodic
progress reports, dates for achieving activities, milestones, and an explanation of why any dates
were missed and preventive or corrective measures. The compliance certification shall be submitted
to the administrator, director, and the appropriate DNR Field office. 567IAC 22.108 (15) "e "
G5. Semi-Annual Monitoring Report
By March 31 and September 30 of each year, the permittee shall submit a report of any monitoring
required under this permit for the 6 month periods of July 1 to December 31 and January 1 to June
30, respectively. All instances of deviations from permit requirements must be clearly identified in
these reports, and the report must be signed by a responsible official, consistent with 567 IAC
22.107(4). The semi-annual monitoring report shall be submitted to the director and the appropriate
DNR Field office. 567 IAC 22.108 (5)
G6. Annual Fee
1. The permittee is required under subrule 567 IAC 22.106 to pay an annual fee based on the total
tons of actual emissions of each regulated air pollutant. Beginning July 1, 1996, Title V operating
permit fees will be paid on July 1 of each year. The fee shall be based on emissions for the previous
calendar year.
2. The fee amount shall be calculated based on the first 4,000 tons of each regulated air pollutant
emitted each year. The fee to be charged per ton of pollutant will be available from the department
by June 1 of each year. The Responsible Official will be advised of any change in the annual fee per
ton of pollutant.
3. The emissions inventory shall be submitted annually by March 31 with forms specified by the
department documenting actual emissions for the previous calendar year.
4. The fee shall be submitted annually by July 1 with forms specified by the department.
5. If there are any changes to the emission calculation form, the department shall make revised
forms available to the public by January 1. If revised forms are not available by January 1, forms
from the previous year may be used and the year of emissions documented changed. The
department shall calculate the total statewide Title V emissions for the prior calendar year and make
this information available to the public no later than April 30 of each year.
6. Phase I acid rain affected units under section 404 of the Act shall not be required to pay a fee for
emissions which occur during the years 1993 through 1999 inclusive.
7. The fee for a portable emissions unit or stationary source which operates both in Iowa and out of
state shall be calculated only for emissions from the source while operating in Iowa.
8. Failure to pay the appropriate Title V fee represents cause for revocation of the Title V permit as
indicated in 567 IAC 22.115(l)"d".
G7. Inspection of Premises, Records, Equipment, Methods and Discharges
Upon presentation of proper credentials and any other documents as may be required by law, the
permittee shall allow the director or the director's authorized representative to:
1. Enter upon the permittee's premises where a Title V source is located or emissions-related
activity is conducted, or where records must be kept under the conditions of the permit;
2. Have access to and copy, at reasonable times, any records that must be kept under the conditions
of the permit;
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3. Inspect, at reasonable times, any facilities, equipment (including monitoring and air pollution
control equipment), practices, or operations regulated or required under the permit; and
4. Sample or monitor, at reasonable times, substances or parameters for the purpose of ensuring
compliance with the permit or other applicable requirements. 567IAC 22.108 (15)"b"
G8. Duty to Provide Information
The permittee shall furnish to the director, within a reasonable time, any information that the
director may request in writing to determine whether cause exists for modifying, revoking and
reissuing, or terminating the permit or to determine compliance with the permit. Upon request, the
permittee also shall furnish to the director copies of records required to be kept by the permit, or for
information claimed to be confidential, the permittee shall furnish such records directly to the
administrator of EPA along with a claim of confidentiality. 567 IAC 22.108 (9)"e"
G9. General Maintenance and Repair Duties
The owner or operator of any air emission source or control equipment shall:
1. Maintain and operate the equipment or control equipment at all times in a manner consistent with
good practice for minimizing emissions.
2. Remedy any cause of excess emissions in an expeditious manner.
3. Minimize the amount and duration of any excess emission to the maximum extent possible
during periods of such emissions. These measures may include but not be limited to the use of clean
fuels, production cutbacks, or the use of alternate process units or, in the case of utilities, purchase
of electrical power until repairs are completed.
4. Schedule, at a minimum, routine maintenance of equipment or control equipment during periods
of process shutdowns to the maximum extent possible. 567 IAC 24.2(1)
G10. Recordkeeping Requirements for Compliance Monitoring
1. In addition to any source specific recordkeeping requirements contained in this permit, the
permittee shall maintain the following compliance monitoring records, where applicable:
a. The date, place and time of sampling or measurements
b. The date the analyses were performed.
c. The company or entity that performed the analyses.
d. The analytical techniques or methods used.
e. The results of such analyses; and
f. The operating conditions as existing at the time of sampling or measurement.
g. The records of quality assurance for continuous compliance monitoring systems
(including but not limited to quality control activities, audits and calibration drifts.)
2. The permittee shall retain records of all required compliance monitoring data and support
information for a period of at least 5 years from the date of compliance monitoring sample,
measurement report or application. Support information includes all calibration and maintenance
records and all original strip chart recordings for continuous compliance monitoring, and copies of
all reports required by the permit.
3. For any source which in its application identified reasonably anticipated alternative operating
scenarios, the permittee shall:
a. Comply with all terms and conditions of this permit specific to each alternative scenario.
b. Maintain a log at the permitted facility of the scenario under which it is operating.
c. Consider the permit shield, if provided in this permit, to extend to all terms and conditions
under each operating scenario. 567 IAC 22.108(4), 567 IAC 22.108(12)
Gil. Evidence used in establishing that a violation has or is occurring.
Notwithstanding any other provisions of these rules, any credible evidence may be used for the
purpose of establishing whether a person has violated or is in violation of any provisions herein.
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1. Information from the use of the following methods is presumptively credible evidence of whether
a violation has occurred at a source:
a. A monitoring method approved for the source and incorporated in an operating permit
pursuant to 567 Chapter 22;
b. Compliance test methods specified in 567 Chapter 25; or
c. Testing or monitoring methods approved for the source in a construction permit issued
pursuant to 567 Chapter 22.
2. The following testing, monitoring or information gathering methods are presumptively credible
testing, monitoring, or information gathering methods:
a. Any monitoring or testing methods provided in these rules; or
b. Other testing, monitoring, or information gathering methods that produce information
comparable to that produced by any method in subrule 21.5(1) or this subrule. 567IAC
21.5(l)-567 IAC 21.5(2)
G12. Prevention of Accidental Release: Risk Management Plan Notification and Compliance
Certification
If the permittee is required to develop and register a risk management plan pursuant to section
112(r) of the Act, the permittee shall notify the department of this requirement. The plan shall be
filed with all appropriate authorities by the deadline specified by EPA. A certification that this risk
management plan is being properly implemented shall be included in the annual compliance
certification of this permit. 567 IAC 22.108(6)
G13. Hazardous Release
The permittee must report any situation involving the actual, imminent, or probable release of a
hazardous substance into the atmosphere which, because of the quantity, strength and toxicity of the
substance, creates an immediate or potential danger to the public health, safety or to the
environment. A verbal report shall be made to the department at (515) 725-8694 and to the local
police department or the office of the sheriff of the affected county as soon as possible but not later
than six hours after the discovery or onset of the condition. This verbal report must be followed up
with a written report as indicated in 567 IAC 131.2(2). 567 IAC Chapter 131-State Only
G14. Excess Emissions and Excess Emissions Reporting Requirements
1. Excess Emissions. Excess emission during a period of startup, shutdown, or cleaning of control
equipment is not a violation of the emission standard if the startup, shutdown or cleaning is
accomplished expeditiously and in a manner consistent with good practice for minimizing
emissions. Cleaning of control equipment which does not require the shutdown of the process
equipment shall be limited to one six-minute period per one-hour period. An incident of excess
emission (other than an incident during startup, shutdown or cleaning of control equipment) is a
violation. If the owner or operator of a source maintains that the incident of excess emission was
due to a malfunction, the owner or operator must show that the conditions which caused the incident
of excess emission were not preventable by reasonable maintenance and control measures.
Determination of any subsequent enforcement action will be made following review of this report.
If excess emissions are occurring, either the control equipment causing the excess emission shall be
repaired in an expeditious manner or the process generating the emissions shall be shutdown within
a reasonable period of time. An expeditious manner is the time necessary to determine the cause of
the excess emissions and to correct it within a reasonable period of time. A reasonable period of
time is eight hours plus the period of time required to shut down the process without damaging the
process equipment or control equipment. A variance from this subrule may be available as provided
for in Iowa Code section 455B.143. In the case of an electric utility, a reasonable period of time is
eight hours plus the period of time until comparable generating capacity is available to meet
consumer demand with the affected unit out of service, unless, the director shall, upon investigation,
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reasonably determine that continued operation constitutes an unjustifiable environmental hazard and
issue an order that such operation is not in the public interest and require a process shutdown to
commence immediately.
2. Excess Emissions Reporting
a. Initial Reporting of Excess Emissions. An incident of excess emission (other than an
incident of excess emission during a period of startup, shutdown, or cleaning) shall be
reported to the appropriate field office of the department within eight hours of, or at the start
of the first working day following the onset of the incident. The reporting exemption for an
incident of excess emission during startup, shutdown or cleaning does not relieve the owner
or operator of a source with continuous monitoring equipment of the obligation of
submitting reports required in 567-subrule 25.1(6). An initial report of excess emission is
not required for a source with operational continuous monitoring equipment (as specified in
567-subrule 25.1(1) ) if the incident of excess emission continues for less than 30 minutes
and does not exceed the applicable emission standard by more than 10 percent or the
applicable visible emission standard by more than 10 percent opacity. The initial report may
be made by electronic mail (E-mail), in person, or by telephone and shall include as a
minimum the following:
i. The identity of the equipment or source operation from which the excess emission
originated and the associated stack or emission point.
ii. The estimated quantity of the excess emission.
iii. The time and expected duration of the excess emission.
iv. The cause of the excess emission.
v. The steps being taken to remedy the excess emission.
vi. The steps being taken to limit the excess emission in the interim period.
b. Written Reporting of Excess Emissions. A written report of an incident of excess
emission shall be submitted as a follow-up to all required initial reports to the department
within seven days of the onset of the upset condition, and shall include as a minimum the
following:
i. The identity of the equipment or source operation point from which the excess
emission originated and the associated stack or emission point.
ii. The estimated quantity of the excess emission.
iii. The time and duration of the excess emission.
iv. The cause of the excess emission.
v. The steps that were taken to remedy and to prevent the recurrence of the incident
of excess emission.
vi. The steps that were taken to limit the excess emission.
vii. If the owner claims that the excess emission was due to malfunction,
documentation to support this claim. 567IAC 24.1(l)-567 IAC 24.1(4)
3. Emergency Defense for Excess Emissions. For the purposes of this permit, an "emergency"
means any situation arising from sudden and reasonably unforeseeable events beyond the control of
the source, including acts of God, which situation requires immediate corrective action to restore
normal operation, and that causes the source to exceed a technology-based emission limitation
under the permit due to unavoidable increases in emissions attributable to the emergency. An
emergency shall not include non-compliance, to the extent caused by improperly designed
equipment, lack of preventive maintenance, careless or improper operation or operator error. An
emergency constitutes an affirmative defense to an action brought for non-compliance with
technology based limitations if it can be demonstrated through properly signed contemporaneous
operating logs or other relevant evidence that:
5
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a. An emergency occurred and that the permittee can identify the cause(s) of the emergency;
b. The facility at the time was being properly operated;
c. During the period of the emergency, the permittee took all reasonable steps to minimize
levels of emissions that exceeded the emissions standards or other requirements of the
permit; and
d. The permittee submitted notice of the emergency to the director by certified mail within
two working days of the time when the emissions limitations were exceeded due to the
emergency. This notice fulfills the requirement of paragraph 22.108(5)"b." - See G15. This
notice must contain a description of the emergency, any steps taken to mitigate emissions,
and corrective actions taken.
In any enforcement proceeding, the permittee seeking to establish the occurrence of an
emergency has the burden of proof. This provision is in addition to any emergency or upset
provision contained in any applicable requirement. 567IAC 22.108(16)
G15. Permit Deviation Reporting Requirements
A deviation is any failure to meet a term, condition or applicable requirement in the permit.
Reporting requirements for deviations that result in a hazardous release or excess emissions have
been indicated above (see G13 and G14). Unless more frequent deviation reporting is specified in
the permit, any other deviation shall be documented in the semi-annual monitoring report and the
annual compliance certification (see G4 and G5). 567IAC 22.108(5)"b"
G16. Notification Requirements for Sources That Become Subject to NSPS and NESHAP
Regulations
During the term of this permit, the permittee must notify the department of any source that becomes
subject to a standard or other requirement under 567-subrule 23.1(2) (standards of performance of
new stationary sources) or section 111 of the Act; or 567-subrule 23.1(3) (emissions standards for
hazardous air pollutants), 567-subrule 23.1(4) (emission standards for hazardous air pollutants for
source categories) or section 112 of the Act. This notification shall be submitted in writing to the
department pursuant to the notification requirements in 40 CFR Section 60.7, 40 CFR Section
61.07, and/or 40 CFR Section 63.9. 567IAC 23.1(2), 567IAC 23.1(3), 567IAC 23.1(4)
G17. Requirements for Making Changes to Emission Sources That Do Not Require Title V
Permit Modification
1. Off Permit Changes to a Source. Pursuant to section 502(b)(10) of the CAAA, the permittee may
make changes to this installation/facility without revising this permit if:
a. The changes are not major modifications under any provision of any program required by
section 110 of the Act, modifications under section 111 of the act, modifications under
section 112 of the act, or major modifications as defined in 567 IAC Chapter 22.
b. The changes do not exceed the emissions allowable under the permit (whether expressed
therein as a rate of emissions or in terms of total emissions);
c. The changes are not modifications under any provisions of Title I of the Act and the
changes do not exceed the emissions allowable under the permit (whether expressed therein
as a rate of emissions or as total emissions);
d. The changes are not subject to any requirement under Title IV of the Act (revisions
affecting Title IV permitting are addressed in rules 567—22.140(455B) through 567 -
22.144(455B));.
e. The changes comply with all applicable requirements.
f. For each such change, the permitted source provides to the department and the
administrator by certified mail, at least 30 days in advance of the proposed change, a written
notification, including the following, which must be attached to the permit by the source, the
department and the administrator:
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i. A brief description of the change within the permitted facility,
ii. The date on which the change will occur,
iii. Any change in emission as a result of that change,
iv. The pollutants emitted subject to the emissions trade
v. If the emissions trading provisions of the state implementation plan are invoked,
then Title V permit requirements with which the source shall comply; a description
of how the emissions increases and decreases will comply with the terms and
conditions of the Title V permit.
vi. A description of the trading of emissions increases and decreases for the purpose
of complying with a federally enforceable emissions cap as specified in and in
compliance with the Title V permit; and
vii. Any permit term or condition no longer applicable as a result of the change.
567IAC 22.110(1)
2. Such changes do not include changes that would violate applicable requirements or contravene
federally enforceable permit terms and conditions that are monitoring (including test methods),
record keeping, reporting, or compliance certification requirements. 567 IAC 22.110(2)
3. Notwithstanding any other part of this rule, the director may, upon review of a notice, require a
stationary source to apply for a Title V permit if the change does not meet the requirements of
subrule 22.110(1). 567 IAC 22.110(3)
4. The permit shield provided in subrule 22.108(18) shall not apply to any change made pursuant to
this rule. Compliance with the permit requirements that the source will meet using the emissions
trade shall be determined according to requirements of the state implementation plan authorizing the
emissions trade. 567 IAC 22.110(4)
5. No permit revision shall be required, under any approved economic incentives, marketable
permits, emissions trading and other similar programs or processes, for changes that are provided
for in this permit. 567 IAC 22.108(11)
G18. Duty to Modify a Title V Permit
1. Administrative Amendment.
a. An administrative permit amendment is a permit revision that does any of the following:
i. Correct typographical errors
ii. Identify a change in the name, address, or telephone number of any person
identified in the permit, or provides a similar minor administrative change at the
source;
iii. Require more frequent monitoring or reporting by the permittee; or
iv. Allow for a change in ownership or operational control of a source where the
director determines that no other change in the permit is necessary, provided that a
written agreement containing a specific date for transfer of permit responsibility,
coverage and liability between the current and new permittee has been submitted to
the director.
b. The permittee may implement the changes addressed in the request for an administrative
amendment immediately upon submittal of the request. The request shall be submitted to the
director.
c. Administrative amendments to portions of permits containing provisions pursuant to Title
IV of the Act shall be governed by regulations promulgated by the administrator under Title
IV of the Act.
2. Minor Title V Permit Modification.
a. Minor Title V permit modification procedures may be used only for those permit
modifications that satisfy all of the following:
7
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i. Do not violate any applicable requirement;
ii. Do not involve significant changes to existing monitoring, reporting or
recordkeeping requirements in the Title V permit;
iii. Do not require or change a case by case determination of an emission limitation
or other standard, or an increment analysis;
iv. Do not seek to establish or change a permit term or condition for which there is
no corresponding underlying applicable requirement and that the source has assumed
in order to avoid an applicable requirement to which the source would otherwise be
subject. Such terms and conditions include any federally enforceable emissions caps
which the source would assume to avoid classification as a modification under any
provision under Title I of the Act; and an alternative emissions limit approved
pursuant to regulations promulgated under section 112(i)(5) of the Act;
v. Are not modifications under any provision of Title I of the Act; and
vi. Are not required to be processed as significant modification under rule 567 -
22.113(455B).
b. An application for minor permit revision shall be on the minor Title V modification
application form and shall include at least the following:
i. A description of the change, the emissions resulting from the change, and any new
applicable requirements that will apply if the change occurs;
ii. The permittee's suggested draft permit;
iii. Certification by a responsible official, pursuant to 567 IAC 22.107(4), that the
proposed modification meets the criteria for use of minor permit modification
procedures and a request that such procedures be used; and
iv. Completed forms to enable the department to notify the administrator and the
affected states as required by 567 IAC 22.107(7).
c. The permittee may make the change proposed in its minor permit modification application
immediately after it files the application. After the permittee makes this change and until the
director takes any of the actions specified in 567 IAC 22.112(4) "a" to "c", the permittee
must comply with both the applicable requirements governing the change and the proposed
permit terms and conditions. During this time, the permittee need not comply with the
existing permit terms and conditions it seeks to modify. However, if the permittee fails to
comply with its proposed permit terms and conditions during this time period, the existing
permit terms and conditions it seeks to modify may be enforced against the facility.
3. Significant Title V Permit Modification.
Significant Title V modification procedures shall be used for applications requesting Title V permit
modifications that do not qualify as minor Title V modifications or as administrative amendments.
These include but are not limited to all significant changes in monitoring permit terms, every
relaxation of reporting or recordkeeping permit terms, and any change in the method of measuring
compliance with existing requirements. Significant Title V modifications shall meet all
requirements of 567 IAC Chapter 22, including those for applications, public participation, review
by affected states, and review by the administrator, as those requirements that apply to Title V
issuance and renewal.
The permittee shall submit an application for a significant permit modification not later than three
months after commencing operation of the changed source unless the existing Title V permit would
prohibit such construction or change in operation, in which event the operation of the changed
source may not commence until the department revises the permit. 567IAC 22.111-567 IAC 22.113
8
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G19. Duty to Obtain Construction Permits
Unless exempted in 567 IAC 22.1(2) or to meet the parameters established in 567 IAC 22. l(l)"c",
the permittee shall not construct, install, reconstruct or alter any equipment, control equipment or
anaerobic lagoon without first obtaining a construction permit, or conditional permit, or permit
pursuant to rule 567 IAC 22.8, or permits required pursuant to rules 567 IAC 22.4, 567 IAC 22.5,
567 IAC 31.3, and 567 IAC 33.3 as required in 567 IAC 22.1(1). A permit shall be obtained prior to
the initiation of construction, installation or alteration of any portion of the stationary source or
anaerobic lagoon. 567 IAC 22.1(1)
G20. Asbestos
The permittee shall comply with 567 IAC 23.1(3)"a", and 567 IAC 23.2(3)"g" when activities
involve asbestos mills, surfacing of roadways, manufacturing operations, fabricating, insulating,
waste disposal, spraying applications, demolition and renovation operations (567 IAC 23.1(3)"a");
training fires and controlled burning of a demolished building (567 IAC 23.2).
G21. Open Burning
The permittee is prohibited from conducting open burning, except as provided in 567 IAC 23.2. 567
IAC 23.2 except 23.2(3) "j"; 567IAC 23.2(3) "j" - State Only
G22. Acid Rain (Title IV) Emissions Allowances
The permittee shall not exceed any allowances that it holds under Title IV of the Act or the
regulations promulgated there under. Annual emissions of sulfur dioxide in excess of the number of
allowances to emit sulfur dioxide held by the owners and operators of the unit or the designated
representative of the owners and operators is prohibited. Exceedences of applicable emission rates
are prohibited. "Held" in this context refers to both those allowances assigned to the owners and
operators by USEPA, and those allowances supplementally acquired by the owners and operators.
The use of any allowance prior to the year for which it was allocated is prohibited. Contravention of
any other provision of the permit is prohibited. 567 IAC 22.108(7)
G23. Stratospheric Ozone and Climate Protection (Title VI) Requirements
1. The permittee shall comply with the standards for labeling of products using ozone-depleting
substances pursuant to 40 CFR Part 82, Subpart E:
a. All containers in which a class I or class II substance is stored or transported, all products
containing a class I substance, and all products directly manufactured with a class I
substance must bear the required warning statement if it is being introduced into interstate
commerce pursuant to § 82.106.
b. The placement of the required warning statement must comply with the requirements
pursuant to § 82.108.
c. The form of the label bearing the required warning statement must comply with the
requirements pursuant to § 82.110.
d. No person may modify, remove, or interfere with the required warning statement except
as described in § 82.112.
2. The permittee shall comply with the standards for recycling and emissions reduction pursuant to
40 CFR Part 82, Subpart F, except as provided for MVACs in Subpart B:
a. Persons opening appliances for maintenance, service, repair, or disposal must comply
with the required practices pursuant to § 82.156.
b. Equipment used during the maintenance, service, repair, or disposal of appliances must
comply with the standards for recycling and recovery equipment pursuant to § 82.158.
c. Persons performing maintenance, service, repair, or disposal of appliances must be
certified by an approved technician certification program pursuant to § 82.161.
d. Persons disposing of small appliances, MVACs, and MVAC-like appliances must comply
with reporting and recordkeeping requirements pursuant to § 82.166. ("MVAC-like
9
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appliance" as defined at § 82.152)
e. Persons owning commercial or industrial process refrigeration equipment must comply
with the leak repair requirements pursuant to § 82.156.
f. Owners/operators of appliances normally containing 50 or more pounds of refrigerant
must keep records of refrigerant purchased and added to such appliances pursuant to §
82.166.
3. If the permittee manufactures, transforms, imports, or exports a class I or class II substance, the
permittee is subject to all the requirements as specified in 40 CFR part 82, Subpart A, Production
and Consumption Controls.
4. If the permittee performs a service on motor (fleet) vehicles when this service involves ozone-
depleting substance refrigerant (or regulated substitute substance) in the motor vehicle air
conditioner (MVAC), the permittee is subject to all the applicable requirements as specified in 40
CFR part 82, Subpart B, Servicing of Motor Vehicle Air Conditioners. The term "motor vehicle" as
used in Subpart B does not include a vehicle in which final assembly of the vehicle has not been
completed. The term "MVAC" as used in Subpart B does not include the air-tight sealed
refrigeration system used as refrigerated cargo, or system used on passenger buses using HCFC-22
refrigerant,
5. The permittee shall be allowed to switch from any ozone-depleting or greenhouse gas generating
substances to any alternative that is listed in the Significant New Alternatives Program (SNAP)
promulgated pursuant to 40 CFR part 82, Subpart G, Significant New Alternatives Policy Program.
40 CFR part 82
G24. Permit Reopenings
1. This permit may be modified, revoked, reopened, and reissued, or terminated for cause. The
filing of a request by the permittee for a permit modification, revocation and reissuance, or
termination, or of a notification of planned changes or anticipated noncompliance does not stay any
permit condition. 5671AC 22.108(9)"c"
2. Additional applicable requirements under the Act become applicable to a major part 70 source
with a remaining permit term of 3 or more years. Revisions shall be made as expeditiously as
practicable, but not later than 18 months after the promulgation of such standards and regulations.
a. Reopening and revision on this ground is not required if the permit has a remaining term
of less than three years;
b. Reopening and revision on this ground is not required if the effective date of the
requirement is later than the date on which the permit is due to expire, unless the original
permit or any of its terms and conditions have been extended pursuant to 40 CFR
70.4(b)(10)(i) or (ii) as amended to May 15, 2001.
c. Reopening and revision on this ground is not required if the additional applicable
requirements are implemented in a general permit that is applicable to the source and the
source receives approval for coverage under that general permit. 567IAC 22.108(17)"a",
567IAC 22.108(17) "b"
3. A permit shall be reopened and revised under any of the following circumstances:
a. The department receives notice that the administrator has granted a petition for
disapproval of a permit pursuant to 40 CFR 70.8(d) as amended to July 21, 1992, provided
that the reopening may be stayed pending judicial review of that determination;
b. The department or the administrator determines that the Title V permit contains a material
mistake or that inaccurate statements were made in establishing the emissions standards or
other terms or conditions of the Title V permit;
c. Additional applicable requirements under the Act become applicable to a Title V source,
provided that the reopening on this ground is not required if the permit has a remaining term
10
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of less than three years, the effective date of the requirement is later than the date on which
the permit is due to expire, or the additional applicable requirements are implemented in a
general permit that is applicable to the source and the source receives approval for coverage
under that general permit. Such a reopening shall be complete not later than 18 months after
promulgation of the applicable requirement.
d. Additional requirements, including excess emissions requirements, become applicable to
a Title IV affected source under the acid rain program. Upon approval by the administrator,
excess emissions offset plans shall be deemed to be incorporated into the permit.
e. The department or the administrator determines that the permit must be revised or revoked
to ensure compliance by the source with the applicable requirements. 567IAC 22.114(1)
4. Proceedings to reopen and reissue a Title V permit shall follow the procedures applicable to
initial permit issuance and shall effect only those parts of the permit for which cause to reopen
exists. 567 IAC 22.114(2)
5. A notice of intent shall be provided to the Title V source at least 30 days in advance of the date
the permit is to be reopened, except that the director may provide a shorter time period in the case
of an emergency. 567 IAC 22.114(3)
G25. Permit Shield
1. The director may expressly include in a Title V permit a provision stating that compliance with
the conditions of the permit shall be deemed compliance with any applicable requirements as of the
date of permit issuance, provided that:
a. Such applicable requirements are included and are specifically identified in the permit; or
b. The director, in acting on the permit application or revision, determines in writing that
other requirements specifically identified are not applicable to the source, and the permit
includes the determination or a concise summary thereof.
2. A Title V permit that does not expressly state that a permit shield exists shall be presumed not to
provide such a shield.
3. A permit shield shall not alter or affect the following:
a. The provisions of Section 303 of the Act (emergency orders), including the authority of
the administrator under that section;
b. The liability of an owner or operator of a source for any violation of applicable
requirements prior to or at the time of permit issuance;
c. The applicable requirements of the acid rain program, consistent with Section 408(a) of
the Act;
d. The ability of the department or the administrator to obtain information from the facility
pursuant to Section 114 of the Act. 567 IAC 22.108 (18)
G26. Severability
The provisions of this permit are severable and if any provision or application of any provision is
found to be invalid by this department or a court of law, the application of such provision to other
circumstances, and the remainder of this permit, shall not be affected by such finding. 567 IAC
22.108(8)
G27. Property Rights
The permit does not convey any property rights of any sort, or any exclusive privilege. 567 IAC
22.108 (9)"d"
G28. Transferability
This permit is not transferable from one source to another. If title to the facility or any part of it is
transferred, an administrative amendment to the permit must be sought consistent with the
requirements of 567 IAC 22.111(1). 567IAC 22.111 (l)"d"
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G29. Disclaimer
No review has been undertaken on the engineering aspects of the equipment or control equipment
other than the potential of that equipment for reducing air contaminant emissions. 567IAC
22.3(3)"c"
G30. Notification and Reporting Requirements for Stack Tests or Monitor Certification
The permittee shall notify the department's stack test contact in writing not less than 30 days before
a required test or performance evaluation of a continuous emission monitor is performed to
determine compliance with applicable requirements of 567 - Chapter 23 or a permit condition. Such
notice shall include the time, the place, the name of the person who will conduct the test and other
information as required by the department. If the owner or operator does not provide timely notice
to the department, the department shall not consider the test results or performance evaluation
results to be a valid demonstration of compliance with applicable rules or permit conditions. Upon
written request, the department may allow a notification period of less than 30 days. At the
department's request, a pretest meeting shall be held not later than 15 days prior to conducting the
compliance demonstration. A testing protocol shall be submitted to the department no later than 15
days before the owner or operator conducts the compliance demonstration. A representative of the
department shall be permitted to witness the tests. Results of the tests shall be submitted in writing
to the department's stack test contact in the form of a comprehensive report within six weeks of the
completion of the testing. Compliance tests conducted pursuant to this permit shall be conducted
with the source operating in a normal manner at its maximum continuous output as rated by the
equipment manufacturer, or the rate specified by the owner as the maximum production rate at
which the source shall be operated. In cases where compliance is to be demonstrated at less than
the maximum continuous output as rated by the equipment manufacturer, and it is the owner's intent
to limit the capacity to that rating, the owner may submit evidence to the department that the source
has been physically altered so that capacity cannot be exceeded, or the department may require
additional testing, continuous monitoring, reports of operating levels, or any other information
deemed necessary by the department to determine whether such source is in compliance.
Stack test notifications, reports and correspondence shall be sent to:
Stack Test Review Coordinator
Iowa DNR, Air Quality Bureau
Wallace State Office Building
502 E 9th St.
Des Moines, IA 50319-0034
(515) 725-9545
Within Polk and Linn Counties, stack test notifications, reports and correspondence shall also be
directed to the supervisor of the respective county air pollution program.
567IAC 25.1(7) "a", 567 IAC 25.1(9)
G31. Prevention of Air Pollution Emergency Episodes
The permittee shall comply with the provisions of 567 IAC Chapter 26 in the prevention of
excessive build-up of air contaminants during air pollution episodes, thereby preventing the
occurrence of an emergency due to the effects of these contaminants on the health of persons. 567
IAC 26.1(1)
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G32. Contacts List
The current address and phone number for reports and notifications to the EPA administrator is:
Iowa Compliance Officer
Air Branch
Enforcement and Compliance Assurance Division
U.S. EPA Region 7
11201 RennerBlvd.
Lenexa, KS 66219
(913)551-7020
The current address and phone number for reports and notifications to the department or the
Director is:
Chief, Air Quality Bureau
Iowa Department of Natural Resources
Wallace State Office Building
502 E 9th St.
Des Moines, IA 50319-0034
(515) 725-8200
Reports or notifications to the DNR Field Offices or local programs shall be directed to the
supervisor at the appropriate field office or local program. Current addresses and phone numbers
are:
Field Office 1
Field Office 2
2300-15th St., SW
Mason City, IA 50401
(641)424-4073
1101 Commercial Court, Suite 10
Manchester, IA 52057
(563) 927-2640
Field Office 3
1900 N. Grand Ave
Spencer, IA 51301
(712) 262-4177
1401 Sunnyside Lane
Atlantic, IA 50022
(712) 243-1934
Field Office 4
Field Office 5
Wallace State Office Building
502 E 9th St.
Des Moines, IA 50319-0034
(515) 725-0268
Field Office 6
1023 West Madison Street
Washington, IA 52353-1623
(319)653-2135
Polk County Public Works Dept.
Air Quality Division
Linn County Public Health
Air Quality Branch
1020 6th Street SE
Cedar Rapids, IA 52401
(319) 892-6000
5885 NE 14th St.
Des Moines, IA 50313
(515)286-3351
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Title V Fee Revenue Report
2016-2021
Title V Fund Fees
Emission Fee
0325 / 325B
State Fiscal Year
2016
2017
2018
2019
2020
2021
July
5,673,386
135,794
785,917
2,223
40,436
3,397,553
August
0
6,212
-1,925
385
18,624
103,213
September
6,223
1,706
3,445
6,136
29,356
7,431
October
1,583
16,676
7,841
10,186
29,234
2,026
November
5,787
7,147
5,549
12,969
20,269
2,003
December
4,984
-9,101
5,152
9,287
10,235
1,398
January
3,178
3,579
4,142
8,270
17,439
4,694
February
2,823
3,366
7,131
10,653
9,248
428
March
1,888
39,342
5,742
11,184
12,846
-6,546
April
4,779
-26,240
4,338
10,739
9,566
1,189
May
-5,049
3,405
39,583
10,232
12,533
130,388
June
6,288,693
5,701,287
6,248,901
3,689,250
2,731,856
July
1,749,090
442,253
460,857
3,474,372
331,174
August
1,186
16,335
23,812
7,745
-8,960
September
-2,000
-159
-12,389
-2,295
0
TOTAL
13,736,551
6,341,602
7,588,096
7,261,337
3,263,856
3,643,777
Fees:
13,707,702
6,297,984
7,532,180
7,153,277
3,147,136
3,625,416
Reg Fees/Reimb/Rev:
564
1,173
1,082
124
182
4,273
Interest:
28,285
42,446
54,834
107,936
116,537
14,088
Operating Permit Application Fee
0325 / 325C
2016
2017
2018
2019
2020
2021
July
0
-1,925
250
0
2,350
August
0
1,925
16,125
0
-2,350
September
0
37,325
-3,675
29,600
19,400
October
0
18,200
3,250
29,458
725
November
18,400
50,025
87,425
73,050
7,600
December
14,600
73,075
76,300
99,095
119,175
January
0
12,000
0
3,100
56,250
February
0
22,325
65,088
0
34,351
March
0
101,150
85,613
103,700
168,240
April
325
43,525
13,350
12,916
42,100
17,150
May
400
29,575
70,200
133,059
2,275
173,800
June
2,700
19,850
184,425
221,072
3,925
July
14,464
13,825
25,300
-97,822
85,875
August
-3,489
44,375
163,675
86,100
47,108
September
1,575
13,500
36,850
61,650
0
TOTAL
15,975
197,650
807,900
747,350
519,286
596,691
Fees:
15,975
197,650
807,900
747,350
519,286
596,691
Regis Fees/ Reimb:
Interest:
TOTAL FUND
13,752,526
6,539,252
8,395,996
8,008,687
3,783,142
4,240,468
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Final Title V Permits Total # of Active Permits: 269
Facility Name
Site City
EIQ#
Facility #
Permit #
Issued
Expiration
3M (Minnesota Mining & Manufacturing Co.)
Knoxville
92-3629
63-01-001
01-TV-025R2-M002
11/9/2016
6/16/2020
Absolute Energy, LLC
Saint Ansgar
92-6948
66-10-001
13-TV-007R1
1/2/2019
1/1/2024
ADM Clinton BioProcessing
Clinton
92-6805
23-01-006
17-TV-002
5/19/2017
5/18/2022
ADM Corn Processing - Clinton
Clinton
92-0265
23-01-006
06-TV-007
12/5/2006
12/4/2011
ADM Corn Processing / COGEN Plant - Clinto
Clinton
92-6795
23-01-006
11-TV-007R1
3/30/2017
3/29/2022
Ag Processing Inc - Algona, IA
Algona
92-6977
55-01-032
15-TV-008R1
6/1/2020
5/31/2025
Ag Processing Inc - Eagle Grove, IA
Eagle Grove
92-0050
99-01-001
05-TV-005R2
10/27/2017
10/26/2022
Ag Processing Inc - Emmetsburg, IA
Emmetsburg
92-6862
74-01-012
04-TV-013R1
3/10/2017
3/9/2022
Ag Processing Inc - Manning, IA
Manning
92-0051
14-02-003
11-TV-004R1
5/5/2017
5/4/2022
Ag Processing Inc - Mason City, IA
Mason City
92-0052
17-01-027
12-TV-003R1
3/30/2017
3/29/2022
Ag Processing Inc - Sergeant Bluff, IA
Sergeant Bluff
92-0053
97-04-005
99-TV-004R2
11/1/2017
10/31/2022
Ag Processing Inc - Sheldon, IA
Sheldon
92-0054
71-01-001
12-TV-001R1
7/14/2017
7/13/2022
Ajinomoto Animal Nutrition North America, In
Eddyville
92-2456
68-09-002
00-TV-028R3
8/19/2019
8/18/2024
Alliance Pipeline L. P./Manchester 27-A Compr
Manchester
92-6899
28-01-026
03-TV-014R3
9/9/2019
9/8/2024
Altec Osceola Body Plant
Osceola
92-4329
20-01-018
09-TV-003R1-M001
9/1/2017
7/10/2021
American Packaging Corporation
Story City
92-0209
85-03-003
00-TV-058R3-M001
11/4/2016
8/21/2021
Amsted Rail Company, Inc.
Keokuk
92-2304
56-01-023
02-TV-014R3
9/9/2019
9/8/2024
ANR Pipeline Company - Birmingham Compre
Birmingham
92-0251
51-03-001
99-TV-033R4
7/25/2016
ANR Pipeline Company - Lineville Compresso
Lineville
92-0252
93-05-001
00-TV-025R3
7/19/2017
7/18/2022
Archer Daniels Midland - Des Moines Soybean
Des Moines
92-6313
77-01-045
04-TV-020R1
4/23/2014
4/22/2019
Archer Daniels Midland Company
Cedar Rapids
92-9062
57-01-080
08-TV-004R1-M002
1/1/2020
1/5/2022
Arconic Davenport Works (formerly Alcoa)
Riverdale
92-0132
82-01-002
03-TV-025R3
2/4/2021
2/3/2026
Arcosa Wind Towers, Inc.
Newton
92-6937
50-01-049
15-TV-012R1
6/9/2021
6/8/2026
Ashley Industrial Molding, Inc.
Oelwein
92-6974
33-01-003
14-TV-009R1
5/13/2019
5/12/2024
Atlas Molded Productions A Division of Atlas
Washington
92-6865
92-01-021
99-TV-041R3
2/12/2016
2/11/2021
Bayer CropScience LP
Muscatine
92-3670
70-01-008
04-TV-002R2-M002
3/23/2017
7/27/2021
Bayer CropScience LP
Muscatine
92-6908
70-01-008
04-TV-006R2
6/15/2016
6/14/2021
Bayer CropScience LP
Muscatine
92-6909
70-01-008
04-TV-010R2-M001
10/17/2018
6/6/2022
Bemis Company, Inc. - Centerville
Centerville
92-5276
04-01-002
01-TV-001R3
2/27/2018
2/26/2023
Bertch Cabinet, LLC
Jesup
92-6884
10-02-008
01-TV-003R3
3/26/2019
3/25/2024
Bertch Cabinet, LLC
Oelwein
92-6863
33-01-020
99-TV-051R3
1/2/2018
1/1/2023
Bertch Cabinet, LLC
Waterloo
92-0468
07-01-063
03-TV-009R3
9/15/2020
9/14/2025
Bertch Cabinet, LLC
Waterloo
92-0712
07-01-086
03-TV-026R3
4/6/2020
4/5/2025
Big River Resources West Burlington, LLC
West Burlington
92-7013
29-02-012
09-TV-005R1-M001
12/11/2019
8/15/2021
Big River United Energy, LLC - Dyersville
Dyersville
92-6957
28-12-001
14-TV-010R1
6/17/2019
6/16/2024
BioSpringer North America Corporation
Cedar Rapids
92-9063
57-01-226
12-TV-005R1
5/9/2017
5/8/2022
Wednesday, June 30, 2021
Page 1 of 8
-------
Facility Name
Site City
EIQ#
Facility #
Permit #
Issued
Expiration
Black Hawk County Sanitary Landfill
Waterloo
92-6871
07-01-121
99-TV-054R3
6/1/2017
5/31/2022
BrandFX, LLC
Pocahontas
92-6923
76-01-014
06-TV-002R2-M001
10/15/2019
2/27/2023
BrandFX, LLC
Swea City
92-1990
55-03-004
99-TV-027R3
12/7/2015
12/6/2020
Bridgestone Americas Tire Operations
Des Moines
92-6246
77-01-022
05-TV-008R1
6/2/2016
6/1/2021
Bunge Corporation
Council Bluffs
92-6880
78-01-085
02-TV-017R2-M001
7/20/2016
4/17/2019
Cambrex Charles City, Inc.
Charles City
92-4536
34-01-015
15-TV-007
5/18/2020
6/3/2020
Cargill - Vitamin E
Eddyville
92-6901
68-09-005
04-TV-004R3
3/30/2021
3/29/2026
Cargill Soybean East Plant
Cedar Rapids
92-9015
57-01-003
99-TV-044R3
6/23/2017
6/22/2022
Cargill Soybean West Plant
Cedar Rapids
92-9010
57-01-002
07-TV-010R2
1/1/2020
12/31/2024
Cargill, Inc.
Cedar Rapids
92-9020
57-01-004
07-TV-006R2
6/19/2019
6/18/2024
Cargill, Inc. - Eddyville, IA
Eddyville
92-0752
68-09-001
06-TV-006
10/17/2006
10/16/2011
Cargill, Inc. - Fort Dodge
Fort Dodge
92-6615
94-01-080
17-TV-003-M001
11/1/2019
11/26/2022
Cargill, Inc. - Iowa Falls
Iowa Falls
92-0760
42-01-003
99-TV-050R4
7/6/2020
7/5/2025
Cargill, Inc. - Sioux City
Sioux City
92-0769
97-01-001
99-TV-013R4
1/13/2020
1/12/2025
CB&I LLC.
Clive
92-6752
77-10-002
01-TV-011R3
12/7/2020
12/6/2025
CDI, LLC - Charles City
Charles City
92-6921
34-01-035
14-TV-012R1
5/20/2019
5/19/2024
CDI, LLC - Forest City
Forest City
92-6912
95-01-012
06-TV-004R2
9/1/2017
8/31/2022
Cedar Falls Municipal Electric Utility
Cedar Falls
92-0815
07-02-005
98-TV-005R2
10/15/2013
10/15/2018
Cedar Falls Municipal Electric Utility - CTS
Cedar Falls
92-5630
07-02-005
01-TV-006R3
7/8/2019
7/7/2024
Cedar Falls Municipal Water Utility
Cedar Falls
92-6822
07-02-005
11-TV-006R1
7/25/2016
7/24/2021
Cedar Rapids Linn County Solid Waste Agenc
Marion
92-9984
57-01-130
12-TV-006R1
6/23/2017
6/22/2022
Cedar Rapids WPCF
Cedar Rapids
92-9044
57-01-077
05-TV-001R2
6/14/2019
6/13/2024
Central Disposal Systems, Inc.
Lake Mills
92-6854
95-02-012
02-TV-020R3
9/23/2019
9/22/2024
Central Iowa Power Coop/Summit Lake Facilit
Creston
92-0871
88-01-004
99-TV-003R3
4/13/2017
4/12/2022
Central Iowa Renewable Energy (CORN) LP
Goldfield
92-3132
99-05-003
10-TV-004R2
6/15/2020
6/14/2025
CertainTeed Gypsum
Fort Dodge
92-0844
94-01-002
99-TV-028R3
8/21/2019
8/20/2024
CF Industries Nitrogen, LLC - Port Neal Nitrog
Sergeant Bluff
92-4988
97-01-030
99-TV-024R3
11/17/2015
11/16/2020
City of Ames Combustion Turbine Station
Ames
92-5831
85-01-006
99-TV-022R3
12/13/2016
12/12/2021
City of Ames Steam Electric Plant
Ames
92-0224
85-01-006
97-TV-008R3
5/16/2018
5/15/2023
City of Shenandoah - Shenandoah Sanitation, I
Shenandoah
92-6814
73-01-026
11-TV-002R2
3/16/2021
3/15/2026
Climax Molybdenum Company
Fort Madison
92-0970
56-02-021
03-TV-001R2
6/14/2016
6/13/2021
Clow Valve Company - Foundry
Oskaloosa
92-3484
62-01-001
10-TV-002R1-M001
7/1/2021
12/6/2020
Clow Valve Company - Machine Shop
Oskaloosa
92-0980
62-01-001
10-TV-003R2
5/13/2021
5/12/2026
CNH Industrial America LLC
Burlington
92-2802
29-01-006
02-TV-008R3
3/16/2021
3/15/2026
Construction Products, Inc.
Des Moines
92-1064
77-01-109
99-TV-006R3
7/26/2018
7/25/2023
Continental Cement Company - Davenport Pla
Buffalo
92-3093
82-04-005
04-TV-007R2
11/9/2017
11/8/2022
Corn Belt Power Coop/Wisdom Generation Sta
Spencer
92-1120
21-01-003
98-TV-002R3
7/16/2018
7/15/2023
CURRIES Division of AADG, Inc. - 12th Stree
Mason City
92-6755
17-01-087
00-TV-032R3
4/29/2019
4/28/2024
Wednesday, June 30, 2021
Page 2 of 8
-------
Facility Name
Site City
EIQ#
Facility #
Permit #
Issued
Expiration
Des Moines County Regional Sanitary Landfill
West Burlington
92-6898
29-02-010
18-TV-002
1/17/2018
1/16/2023
Des Moines Metropolitan Wastewater Reclama
Des Moines
92-6801
77-01-317
16-TV-007
6/30/2016
6/29/2021
Donaldson Company, Inc.
Cresco
92-1417
45-01-003
99-TV-043R3-M001
6/24/2019
9/5/2023
Dubuque Metropolitan Sanitary Landfill
Dubuque
92-6939
31-01-151
11-TV-003R2
5/13/2021
5/13/2021
Eagle Window & Door, Inc.
Dubuque
92-1510
31-01-061
03-TV-015R3
10/9/2018
10/8/2023
Eddyville Chlor-Alkali, LLC
Eddyville
92-6997
68-09-008
19-TV-004
8/5/2019
8/4/2024
Elite Octane, LLC
Atlantic
92-6985
15-01-042
9/11/2020
9/10/2025
Enterprise Products Operating LLC - Iowa City
Iowa City
92-5677
52-01-032
01-TV-007R3
5/6/2019
5/5/2024
Equistar Chemicals, LP
Clinton
92-4291
23-01-004
04-TV-008R2
4/25/2017
4/24/2022
Faircast, Inc.
Fairfield
92-1370
51-01-005
99-TV-058R3
3/23/2020
3/22/2025
Flint Hills Resources Fairbank, LLC
Fairbank
92-6958
10-04-007
15-TV-010R1
3/9/2020
3/8/2025
Flint Hills Resources Menlo, LLC
Menlo
92-6956
39-06-002
15-TV-006R1
3/23/2020
3/22/2025
Fres-co System USA, INC.
Red Oak
92-6928
69-01-020
07-TV-007R2
6/5/2018
6/4/2023
Gable Corporation
Council Bluffs
92-6982
78-01-121
16-TV-002-M001
8/17/2016
1/27/2021
Georgia-Pacific Gypsum LLC
Fort Dodge
92-2162
94-01-010
99-TV-035R2
7/6/2012
7/5/2017
Gerdau Ameristeel US Inc. - Wilton Mill
Wilton
92-3862
70-03-003
03-TV-006R2
8/8/2016
8/7/2021
GKN Armstrong Wheels
Armstrong
92-0281
32-02-004
99-TV-020R3
8/17/2016
8/16/2021
GKN Armstrong Wheels, Inc.
Estherville
92-6803
32-01-016
99-TV-019R3
3/21/2017
3/20/2022
GM Cereal Properties, Inc.
Cedar Rapids
92-9085
57-01-012
04-TV-016R2
6/27/2019
6/26/2024
Golden Grain Energy, LLC
Mason City
92-6927
17-01-100
09-TV-002R1
3/6/2017
3/5/2022
Grain Processing Corporation
Muscatine
92-2259
70-01-004
03-TV-029R1
3/13/2017
3/12/2022
Green Plains Shenandoah, LLC
Shenandoah
92-6961
36-10-001
13-TV-004R1
1/8/2019
1/7/2024
Green Plains Superior LLC
Superior
92-6954
30-08-002
13-TV-005R1-M001
10/14/2019
9/3/2023
Green Valley Chemical Corporation
Creston
92-2288
88-01-017
99-TV-002R4
12/26/2019
12/25/2024
Griffin Pipe Products CO., LLC d/b/aU.S. Pipe
Council Bluffs
92-2303
78-01-012
00-TV-016R1
6/21/2007
6/20/2012
GROWMARK, Inc - Fort Dodge Terminal
Duncombe
92-5492
94-07-001
97-TV-004R4-M001
8/19/2019
8/27/2023
Guardian Industries, LLC
Dewitt
92-6864
23-02-013
99-TV-059R3-M001
6/12/2020
9/25/2023
Guardian Industries, LLC
Dewitt
92-6864
23-02-013
99-TV-059R3-M001
6/12/2020
9/25/2023
Harsco Metals
Muscatine
92-2868
70-01-054
07-TV-008R2
4/27/2018
4/26/2023
Henniges Automotive Iowa, Inc.
Keokuk
92-4582
56-01-008
04-TV-015R2-M001
9/13/2017
8/27/2022
HNI Corporation - Central Campus
Muscatine
92-2531
70-01-006
02-TV-028R1
5/31/2018
5/30/2023
HNI Corporation - North Campus
Muscatine
92-2535
70-01-050
03-TV-032R1
6/26/2017
6/25/2022
Homeland Energy Solutions, LLC
Lawler
92-6930
19-04-002
14-TV-001R1
11/19/2018
11/18/2023
Indianola Municipal Utilities
Indianola
92-2656
91-01-002
13-TV-002R1
5/9/2018
5/8/2023
Indianola Water Pollution Control Department
Indianola
92-6949
91-01-015
13-TV-003R1
5/16/2018
5/15/2023
Industrial Energy Applications, Inc.
Cresco
92-6780
45-01-007
18-TV-006
9/6/2018
9/5/2023
Industrial Energy Applications, Inc. - Industrial
Postville
92-6769
03-02-007
21-TV-003
5/18/2021
5/18/2026
Industrial Energy Applications, Inc. - JBS USA
Marshalltown
92-6761
64-01-045
15-TV-002R1
1/13/2020
1/12/2025
Wednesday, June 30, 2021
Page 3 of 8
-------
Facility Name
Site City
EIQ#
Facility #
Permit #
Issued
Expiration
Industrial Laminates/Norplex, Inc.
Postville
92-3842
03-02-001
99-TV-039R3
12/9/2019
12/8/2024
Ingredion Incorporated
Cedar Rapids
92-9185
57-01-025
04-TV-001R2
1/1/2018
12/31/2022
International Paper - Cedar River Mill
Cedar Rapids
92-9025
57-01-153
15-TV-005-R1
5/1/2021
Iowa Army Ammunition Plant
Middletown
92-3457
29-01-004
04-TV-019R2
7/1/2016
6/30/2021
Iowa City Sanitary Landfill
Iowa City
92-6853
52-01-053
00-TV-007R3
7/23/2018
7/22/2023
Iowa E.P.S. Products, Inc.
Des Moines
92-6998
77-01-337
21-TV-004
6/28/2021
6/27/2026
Iowa Fertilizer Company
Wever
92-6976
56-10-001
20-TV-001
2/10/2020
2/9/2025
Iowa State University
Ames
92-6867
85-01-007
04-TV-014R3
8/19/2020
4/21/2024
IPL - Burlington Generating Station
Burlington
92-2773
29-01-013
98-TV-023R3
6/4/2018
6/3/2023
IPL - Emery Generating Station
Clear Lake
92-6915
17-02-016
07-TV-011R2
8/22/2017
8/21/2022
IPL - Lansing Generating Station
Lansing
92-2686
03-03-001
98-TV-016R2
8/20/2018
8/19/2023
IPL - Lime Creek Combustion Turbines Station
Mason City
92-2687
17-01-066
98-TV-003R4
5/21/2019
5/20/2024
IPL - Marshalltown Generating Station
Marshalltown
92-6250
64-01-012
98-TV-010R3
5/9/2018
5/8/2023
IPL - Ottumwa Generating Station
Ottumwa
92-2774
90-07-001
98-TV-009R2-M002
10/31/2019
8/26/2023
IPL - Prairie Creek Generating Station
Cedar Rapids
92-9050
57-01-042
99-TV-010R2-M001
5/28/2019
2/19/2024
JBS USA LLC
Marshalltown
92-3662
64-01-015
15-TV-004R1
1/13/2020
1/12/2025
John Deere Coating Service Center
Waterloo
92-6873
07-01-111
99-TV-038R3
10/9/2020
10/8/2025
John Deere Davenport Works
Davenport
92-1314
82-01-043
01-TV-008R3-M001
6/27/2019
7/22/2023
John Deere Des Moines Works
Ankeny
92-6800
77-01-035
04-TV-017R2
8/17/2020
8/16/2025
John Deere Dubuque Works
Dubuque
92-1315
31-01-009
01-TV-021R2-M005
3/15/2017
6/8/2019
John Deere Engine Works
Waterloo
92-1318
07-01-091
04-TV-018R2-M001
7/25/2016
11/30/2020
John Deere Foundry Waterloo
Waterloo
92-1317
07-01-010
02-TV-012R2-M002
11/4/2019
2/12/2022
John Deere Ottumwa Works
Ottumwa
92-1316
90-01-003
03-TV-028R3
12/4/2019
12/3/2024
John Deere Product Engineering Center
Cedar Falls
92-5615
07-01-087
05-TV-004R2
3/11/2016
3/10/2021
John Deere Waterloo Works - Drive Train Oper
Waterloo
92-1319
07-01-077
03-TV-027R2-M001
4/13/2016
3/23/2021
John Deere Waterloo Works - Tractor & Cab A
Waterloo
92-5614
07-01-085
02-TV-024R2-M001
2/6/2018
4/18/2021
Keokuk Mills, LLC. (dba Keokuk Steel Casting
Keokuk
92-3000
56-01-025
04-TV-012R2-M001
9/12/2017
7/24/2021
Koch Fertilizer Ft. Dodge, LLC
Duncombe
92-1932
94-01-005
OO-TV-010R3-M001
4/14/2017
10/20/2021
KraflHeinz - Muscatine
Muscatine
92-2344
70-01-005
01-TV-020R3
12/17/2019
12/16/2024
Landfill of North Iowa
Clear Lake
92-6941
17-02-024
12-TV-002R2
4/22/2021
4/21/2026
Latham Pool Products, Inc.
DeWitt
92-6989
23-02-028
19-TV-002
9/23/2019
9/22/2024
Lehigh Cement Company LLC
Mason City
92-3163
17-01-005
04-TV-011R2
5/19/2017
5/18/2022
Lincolnway Energy, LLC
Nevada
92-5064
85-02-017
14-TV-002R1
11/1/2018
10/31/2023
Linde Inc. - Fort Dodge, IA Carbon Dioxide Pla
Duncombe
92-6929
94-07-004
08-TV-002R2
6/20/2018
6/19/2023
Linwood Mining & Minerals Corporation
Davenport
92-3207
82-01-015
04-TV-005R2
9/3/2019
9/2/2024
Little Sioux Corn Processors, LLC
Marcus
92-7002
18-02-006
10-TV-005R1-M001
10/19/2016
7/18/2021
Loess Hills Regional Sanitary Landfill
Malvern
92-6986
65-02-005
17-TV-001
4/7/2017
4/6/2022
LOPAREX LLC
Iowa City
92-2346
52-01-037
01-TV-005R2
11/16/2020
6/12/2021
Wednesday, June 30, 2021
Page 4 of 8
-------
Facility Name
Site City
EIQ#
Facility #
Permit #
Issued
Expiration
Magellan Pipeline Company, L.P. - Des Moine
Pleasant Hill
92-6788
77-01-114
98-TV-019R3
5/23/2019
5/22/2024
Magellan Pipeline Company, L.P. - Dubuque T
Dubuque
92-5491
31-01-034
03-TV-003R3
8/6/2019
8/5/2024
Magellan Pipeline Company, L.P. - Iowa City
Coralville
92-5490
52-02-006
03-TV-010R3
8/6/2019
8/5/2024
Magellan Pipeline Company, L.P. - Mason City
Clear Lake
92-5489
17-02-002
98-TV-006R3
11/30/2020
11/8/2020
Magellan Pipeline Company, L.P. - Milford Ter
Milford
92-5493
30-02-004
03-TV-004R3-M001
7/2/2020
8/5/2024
Magellan Pipeline Company, L.P. - Sioux City
Sioux City
92-5494
97-01-118
98-TV-018R3
10/14/2016
10/13/2021
Magellan Pipeline Company, L.P. - Waterloo T
Waterloo
92-5495
07-01-040
97-TV-005R3
10/5/2015
10/4/2020
Manly Terminal LLC
Manly
92-6614
98-02-004
09-TV-004R2
9/28/2020
9/27/2025
Maquoketa Municipal Electric Utility
Maquoketa
92-3383
49-01-013
04-TV-009R3
2/19/2020
2/18/2025
MasterBrand Cabinets Waterloo Operations
Waterloo
92-3949
07-01-061
00-TV-055R3
12/21/2020
3/31/2024
MetoKote Corporation - Plant 15
Cedar Falls
92-6834
07-02-023
99-TV-032R3
10/31/2017
10/30/2022
Metro Methane Recovery Facility
Mitchellville
92-6791
77-14-002
03-TV-005R2
11/30/2016
11/29/2021
Metro Park East Landfill
Mitchellville
92-6849
77-14-003
03-TV-033R2
7/5/2017
7/4/2022
MidAmerican Energy Co. - Coralville Turbines
Coralville
92-2728
52-02-001
00-TV-015R3
8/8/2016
8/7/2021
MidAmerican Energy Co. - Electrifarm Turbin
Waterloo
92-5852
07-01-038
99-TV-034R3
8/15/2016
8/14/2021
MidAmerican Energy Co. - George Neal North
Sergeant Bluff
92-2761
97-04-010
97-TV-002R3
5/15/2018
5/14/2023
MidAmerican Energy Co. - George Neal South
Salix
92-3599
97-04-011
97-TV-003R3-M001
5/20/2019
5/22/2023
MidAmerican Energy Co. - Knoxville Power St
Knoxville
92-6889
63-01-017
01-TV-028R2 M002
10/9/2018
8/18/2018
MidAmerican Energy Co. - Louisa Station
Muscatine
92-2730
58-07-001
98-TV-029R3-M001
9/12/2018
8/7/2023
MidAmerican Energy Co. - Merl Parr CTs
Charles City
92-5851
34-01-023
98-TV-033R3
5/2/2016
5/1/2021
MidAmerican Energy Co. - Pleasant Hill CTs/
Pleasant Hill
92-5848
77-13-002
97-TV-006R3
11/10/2020
11/9/2025
MidAmerican Energy Co. - River Hills Turbine
Des Moines
92-5850
77-01-054
98-TV-015R3
5/16/2018
5/15/2023
MidAmerican Energy Co. - Riverside Station
Bettendorf
92-2692
82-02-006
98-TV-004R3
9/26/2018
9/25/2023
MidAmerican Energy Co. - Shenandoah Power
Shenandoah
92-6888
73-01-018
01-TV-024R3
8/1/2018
7/31/2023
MidAmerican Energy Co. - Sycamore Turbines
Johnston
92-5849
77-09-002
98-TV-014R3
4/3/2018
4/2/2023
MidAmerican Energy Co. - Walter Scott Jr. En
Council Bluffs
92-3600
78-01-026
97-TV-001R3
4/19/2018
4/18/2023
MidAmerican Energy Co. - Waterloo Lundquis
Waterloo
92-6887
07-01-133
01-TV-027R2
10/3/2018
8/18/2018
Muscatine Power & Water
Muscatine
92-3726
70-01-011
98-TV-021R4
2/11/2021
2/10/2021
National Centers for Animal Health
Ames
92-5201
85-01-017
02-TV-001R3
9/26/2019
9/25/2024
Natural Gas Pipeline Co. of America/Station 10
Emerson
92-3763
65-04-001
99-TV-012R4
4/13/2020
4/12/2025
Natural Gas Pipeline Co. of America/Station 10
Truro
92-3765
91-06-001
00-TV-003R3
7/5/2016
7/4/2021
Natural Gas Pipeline Co. of America/Station 10
Harper
92-3764
54-10-001
00-TV-049R3
4/10/2018
4/9/2023
Natural Gas Pipeline Co. of America/Station 19
Knoxville
92-6302
63-01-013
99-TV-048R4
12/9/2020
12/8/2025
Natural Gas Pipeline Co. of America/Station 19
Letts
92-6043
58-04-002
00-TV-006R4
2/22/2021
2/21/2026
Natural Gas Pipeline Co. of America/Station 20
Columbus Junction
92-3762
58-02-007
00-TV-024R3
8/17/2020
9/6/2022
Natural Gas Pipeline Co. of America/Station 20
Keota
92-5624
92-10-001
00-TV-048R3
8/8/2018
8/7/2023
Naturally Recycled Proteins of Iowa, LLC
Steamboat Rock
92-6945
42-08-003
12-TV-004R1
8/15/2016
8/14/2021
Nichols Aluminum - Davenport Rolling
Davenport
92-3824
82-01-017
00-TV-060R3
8/19/2019
8/18/2024
Wednesday, June 30, 2021
Page 5 of 8
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Facility Name
Site City
EIQ#
Facility #
Permit #
Issued
Expiration
Nichols Aluminum, LLC - Davenport Casting
Davenport
92-4290
82-01-089
03-TV-017R2
2/3/2016
2/2/2021
North Central Iowa Regional Solid Waste Agen
Fort Dodge
92-6846
94-01-079
20-TV-002
4/6/2020
4/5/2025
Northern Natural Gas Company - Oakland
Oakland
92-3874
78-04-006
98-TV-017R4
6/22/2020
8/23/2024
Northern Natural Gas Company - Oakland
Oakland
92-3874
78-04-006
98-TV-017R4
6/22/2020
8/23/2024
Northern Natural Gas Company - Ogden
Ogden
92-3875
08-03-004
98-TV-028R3-M001
4/6/2021
2/24/2021
Northern Natural Gas Company - Paullina
Paullina
92-3876
18-06-002
99-TV-011R3
10/17/2017
10/16/2022
Northern Natural Gas Company - Redfield
Redfield
92-3879
25-05-002
OO-TV-014R3-M001
7/25/2018
6/7/2023
Northern Natural Gas Company - Ventura
Garner
92-3873
41-02-005
00-TV-044R3
7/11/2017
7/10/2022
Northern Natural Gas Company - Waterloo
Waterloo
92-3877
07-01-057
01-TV-016R3-M002
10/9/2019
5/22/2023
NSK Clarinda
Clarinda
92-3910
73-02-010
12-TV-007R1
9/25/2017
9/24/2022
NuStar Council Bluffs Terminal
Council Bluffs
92-3761
78-01-092
99-TV-040R3
6/8/2017
6/7/2022
NuStar Le Mars Terminal
Le Mars
92-2944
75-01-018
00-TV-011R3-M001
1/4/2017
12/18/2021
NuStar Milford Terminal
Milford
92-2945
30-02-010
OO-TV-012R3
12/27/2016
12/26/2021
NuStar Rock Rapids Terminal
Rock Rapids
92-2946
60-01-012
OO-TV-013R3
1/9/2017
1/8/2022
OSI Industries, LLC
Oakland
92-6979
78-04-001
16-TV-001
1/14/2016
1/13/2021
Pella Corporation - Pella Division
Pella
92-4047
63-02-003
00-TV-030R3
3/6/2018
3/5/2023
Pella West Substation
Pella
92-6893
63-02-023
98-TV-011R3
4/28/2016
4/27/2021
Pine Lake Corn Processors
Steamboat Rock
92-6962
42-08-001
19-TV-001
7/15/2019
7/14/2024
PMX Industries Inc.
Cedar Rapids
92-9186
57-01-095
02-TV-022R3
5/16/2018
5/15/2023
POET Biorefining - Arthur, LLC
Arthur
92-6807
47-04-001
10-TV-008R1-M002
3/29/2017
10/25/2020
POET Biorefining - Coon Rapids, LLC
Coon Rapids
92-6922
39-11-001
07-TV-001R2-M002
10/4/2019
8/6/2022
POET Biorefining - Corning
Corning
92-6966
02-05-001
14-TV-007R1
3/25/2019
3/24/2024
POET Biorefining - Emmetsburg
Emmetsburg
92-6932
74-01-022
14-TV-003R1
4/1/2019
3/31/2024
POET Biorefining - Gowrie
Gowrie
92-6963
94-02-004
18-TV-008-M001
7/22/2019
12/2/2023
POET Biorefining - Hanlontown
Hanlontown
92-6964
98-07-004
21-TV-001
2/11/2021
2/10/2026
POET Biorefining - Iowa Falls, LLC
Iowa Falls
92-6959
42-01-019
19-TV-005
9/10/2019
9/9/2024
POET Biorefining - Jewell, LLC
Jewell
92-6943
40-02-002
18-TV-004-M001
8/26/2019
5/29/2023
POET Biorefining - Shell Rock, LLC
Shell Rock
92-6960
12-04-007
15-TV-003R1
3/2/2020
3/1/2025
Polaris Industries, Inc.
Spirit Lake
92-6845
30-01-012
00-TV-023R3-M002
9/20/2017
9/29/2021
Praxis Mid America
Ottumwa
92-5186
90-01-023
00-TV-038R1
5/4/2007
5/3/2012
Precision Tank & Equipment Company
Humboldt
92-6980
46-01-034
15-TV-011-R1
11/4/2020
Principal Life Insurance Company
Des Moines
92-6877
77-01-174
02-TV-019R2
6/2/2016
6/1/2021
Quaker Manufacturing LLC
Cedar Rapids
92-9200
57-01-027
03-TV-022R2
6/30/2021
10/31/2020
Quality Manufacturing Corporation
Urbandale
92-6975
77-03-014
14-TV-013-R1
5/6/2020
Ram Development
Portable
92-6984
PP183-000
18-TV-005-M001
6/18/2019
6/10/2023
Red Star Yeast Company, LLC
Cedar Rapids
92-6919
57-01-226
10-TV-006R1
9/30/2020
9/29/2020
Riley Industrial Painting
West Burlington
92-2813
29-01-079
00-TV-021R3
4/3/2018
4/2/2023
Robertson Ceco II dba Star Building Systems
Monticello
92-4432
53-02-008
00-TV-037R3
6/18/2018
6/17/2023
Wednesday, June 30, 2021
Page 6 of 8
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Facility Name
Site City
EIQ#
Facility #
Permit #
Issued
Expiration
Roquette America, Inc.
Keokuk
92-2568
56-01-009
08-TV-006R1
9/27/2016
9/26/2021
Scott County Landfill
Davenport
92-6872
82-01-121
02-TV-003R3
11/12/2019
11/11/2024
Siculus, Inc.
Altoona
92-6988
77-07-010
18-TV-007
10/29/2018
10/28/2023
SiegwerkUSACo. - 129 SE 18th St
Des Moines
92-5668
77-01-169
03-TV-023R2
3/23/2017
3/22/2022
Siegwerk USA Co. - SW 56th St.
Des Moines
92-6987
77-01-285
18-TV-001
1/18/2018
1/17/2023
Siemens Gamesa Renewable Energy, Inc.
Fort Madison
92-6809
56-02-053
11-TV-001R2
2/22/2021
2/21/2026
Silgan Containers Mfg. Corp. - Fort Dodge
Fort Dodge
92-4664
94-01-040
00-TV-035R3
4/9/2018
4/8/2023
Silgan Containers Mfg. Corp. - Fort Madison
Fort Madison
92-4665
56-02-030
00-TV-036R3
12/21/2017
12/20/2022
Sivyer Steel Castings LLC
Bettendorf
92-4700
82-02-004
02-TV-015R1
4/1/2014
3/31/2019
Smithfield Fresh Meats Corp.
Denison
92-1927
24-01-001
20-TV-003
4/27/2020
4/26/2025
Smithfield Packaged Meats Corp - Sioux City,
Sioux City
92-1228
97-01-193
16-TV-003-M001
9/15/2016
4/12/2021
Southwest Iowa Renewable Energy
Council Bluffs
92-6062
78-01-110
14-TV-014R1
10/29/2019
10/28/2024
SSAB Iowa Inc.
Muscatine
92-6869
70-08-002
07-TV-004R2
4/20/2018
4/19/2023
Stellar Industries, Inc. - Garner Plant
Garner
92-4819
41-02-011
01-TV-009R3
6/30/2020
9/30/2023
Tama Paperboard, LLC
Tama
92-3992
86-01-001
00-TV-051R3
3/21/2018
3/20/2023
The Andersons Marathon Holdings, LLC
Denison
92-4602
24-01-007
14-TV-011R1
7/29/2019
7/28/2024
Titan Tire Corporation
Des Moines
92-6802
77-01-003
02-TV-013R2
4/14/2016
4/13/2021
Transco Railway Products Inc.
Oelwein
92-6832
33-01-016
18-TV-003
5/11/2018
5/10/2023
Union Tank Car Co.-Muscatine
Muscatine
92-5154
70-01-048
03-TV-002R3
10/19/2020
10/18/2025
United States Gypsum Company
Fort Dodge
92-5175
94-01-017
03-TV-019R3
12/28/2020
12/27/2025
United States Gypsum Company
Mediapolis
92-5176
29-06-001
03-TV-012R3
5/11/2021
5/11/2026
University of Iowa
Iowa City
92-6571
52-01-005
00-TV-002R3
8/21/2020
8/20/2025
University of Northern Iowa - Main Campus
Cedar Falls
92-5628
07-02-006
02-TV-016R3
7/9/2019
7/8/2024
University of Northern Iowa - Power Plant
Cedar Falls
92-5192
07-02-006
04-TV-022R2
6/20/2018
6/19/2023
Unverferth Manufacturing Co. Inc.
Shell Rock
92-5194
12-04-005
00-TV-022R3
3/25/2019
3/24/2024
Valero Albert City Plant
Albert City
92-6951
11-05-004
16-TV-006
5/9/2016
5/8/2021
Valero Charles City Plant
Charles City
92-6933
34-01-040
15-TV-009R1
5/4/2020
5/3/2025
Valero Fort Dodge Plant
Fort Dodge
92-6952
94-01-073
16-TV-005
4/26/2016
4/25/2021
Valero Hartley Plant
Hartley
92-6953
71-02-010
16-TV-004
4/19/2016
4/18/2021
Valero Renewable Fuels Company. LLC d/b/a
Lakota
92-6852
55-09-003
10-TV-001R1-M003
4/25/2017
8/5/2020
Vantage Corn Processors LLC
Cedar Rapids
92-9080
57-01-246
08-TV-007R1-M001
1/1/2020
Veolia Water NA - Davenport
Bettendorf
92-5810
82-02-052
10-TV-007R2
3/30/2021
3/29/2026
Vermeer Corporation
Pella
92-5246
63-02-004
99-TV-052R3
6/11/2019
6/10/2024
Wacker Chemical Corporation
Eddyville
92-6917
68-09-006
05-TV-003R2
3/8/2016
3/7/2021
Waverly Municipal Electric Utility dba Waverl
Waverly
92-5348
09-01-013
05-TV-006R2
3/13/2017
3/12/2022
WDC Acquisition LLC
Creston
92-5380
88-01-002
99-TV-018R3
8/22/2017
8/21/2022
Webster City Combustion Turbine
Webster City
92-5367
40-01-003
98-TV-020R4
6/3/2019
6/2/2024
Western Minnesota Municipal Power Agency -
Brayton
92-6920
05-04-002
06-TV-003R2
5/2/2017
5/1/2022
Wednesday, June 30, 2021
Page 7 of 8
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Facility Name
Site City
EIQ#
Facility #
Permit #
Issued
Expiration
Winnebago Industries, Inc. - Charles City
Charles City
92-6914
34-01-027
08-TV-003R2
5/20/2019
5/19/2024
Winnebago Industries, Inc. - Forest City
Forest City
92-5528
95-01-001
05-TV-002R2-M001
8/8/2017
4/20/2021
Woodharbor Custom Cabinetry
Mason City
92-6876
17-01-068
00-TV-027R3-M001
10/30/2020
11/24/2024
Xerxes Corporation
Tipton
92-5586
16-01-004
99-TV-049R3
6/26/2017
6/25/2022
ZFS Creston, LLC
Creston
92-6881
88-01-021
03-TV-016R1
5/15/2012
5/14/2017
Wednesday, June 30, 2021
Page 8 of 8
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Iowa Department of Natural Resources
Title V Operating Permit
Name of Permitted Facility: Vermeer Manufacturing Co.
Facility Location: Plant 3.5
1610 Vermeer Road East
Pella, IA 50219
Air Quality Operating Permit Number: 99-TV-052
Expiration Date: October 18, 2004
EIQ Number: 92-5246
Facility File Number: 63-02-004
Responsible Official
Name: Terry Butler
Title: Vice President of Facilities
Mailing Address: Plant 3.5
1610 Vermeer Road East
Pella, IA 50219
Phone #: (515) 621-7762
Permit Contact Person for the Facility
Name: Terry Butler
Title: Vice President of Facilities
Mailing Address: Plant 3.5
1610 Vermeer Road East
Pella, IA 50219
Phone #: (515) 621-7762
This permit is issued in accordance with 567 Iowa Administrative Code Chapter 22, and
is issued subject to the terms and conditions contained in this permit.
For the Director of the Department of Natural Resources
Christine Spackman, Supervisor of Air Operating Permits Section
Date
-------
Table of Contents
I. Facility Description and Equipment List
4
II. Facility - Wide Conditions
13
III. Emission Point Specific Conditions
17
IV. General Conditions
589
G1. Duty to Comply
G2. Permit Expiration
G3. Certification Requirement for Title V Related Documents
G4. Annual Compliance Certification
G5. Semi-Annual Monitoring Report
G6. Annual Fee
G7. Inspection of Premises, Records, Equipment, Methods and Discharges
G8. Duty to Provide Information
G9. General Maintenance and Repair Duties
G10. Recordkeeping Requirements for Compliance Monitoring
G11. Prevention of Accidental Release: Risk Management Plan Notification and
Compliance Certification
G12. Hazardous Release
G13. Excess Emissions and Excess Emissions Reporting Requirements
G14. Permit Deviation Reporting Requirements
G15. Notification Requirements for Sources That Become Subject to NSPS and
HAP Regulations
G16. Requirements for Making Changes to Emission Sources That Do Not Require
Title V Permit Modification
G17. Duty to Modify a Title V Permit
G18. Duty to Obtain Construction Permits
G19. Asbestos
G20. Open Burning
G21. Acid Rain (Title IV) Emissions Allowances
G22. Stratospheric Ozone and Climate Protection (Title VI) Requirements
G23. Permit Reopenings
G24. Permit Shield
G25. Severability
G26. Property Rights
G27. Transferability
G28. Disclaimer
G29. Notification and Reporting Requirements for Stack Tests or Monitor Certification
G30. Prevention of Air Pollution Emergency Episodes
G31. Contacts List
2
-------
V. Appendix: State of Iowa, ex rel., Iowa DNR vs. Vermeer Manufacturing
Company, 99AG23542, District Court, Marion County, Law No.
LACV087889
Abbreviation
acfm actual cubic feet per minute
CFR Code of Federal Regulations
°F degrees Fahrenheit
EIQ emissions inventory questionnaire
gr./dscf grains per dry standard cubic foot
gr./lOO cf grains per one hundred cubic feet
IAC Iowa Administrative Code
Iowa DNR Iowa Department of Natural Resources
LPG Liquified Petroleum Gas (Propane)
MMcf. Million cubic feet
MSDS Material Safety Data Sheet
MVAC Motor Vehicle Air Conditioner
NAAQS National Ambient Air Quality Standard
NSPS New Source Performance Standard
PSD Prevention of Significant Deterioration
ppm parts per million
ppmv parts per million by volume
lb./hr pounds per hour
lb./MMBtu pounds per million British thermal units
SEP Supplemental Environmental Project
TPY Tons per year
USEPA United States Environmental Protection Agency
Pollutants
PMio particulate matter less than ten (10) microns in size
PM particulate matter (same as TSP, Total Suspended Particulate)
SO2 sulfur dioxide
NOx nitrogen oxide
VOC volatile organic compound
CO carbon monoxide
HAP hazardous air pollutant
3
-------
I. Facility Description and Equipment List
Facility Name: Vermeer Manufacturing Co.
Permit Number: 99-TV-052
Facility Description: Manufacturer of Farm Machinery and Equipment and Construction
Equipment
Equipment List
Emission Point
Associated
Associated Emission Unit Description
Number
Emission Unit
Number (s)
l.AA
l.AA
Non-Production Heating Unit
l.AC
LAC
Non-Production Heating Unit
l.AD
l.AD
Non-Production Heating Unit
l.AF
l.AF
Non-Production Heating Unit
1.AG1
LAG
Plant 1 Finish Paint Booth
1.AG2
LAG
Plant 1 Finish Paint Booth
l.AH
l.AH
Production Engine Testing Unit
l.AJ
l.AJ
Production Engine Testing Unit
l.AP
l.AP
Paint Kitchen
l.AQ
1.AQ1
Paint Kitchen
l.AQ
1.AQ2
Paint Kitchen
l.AR
l.AR
Production Engine Testing Unit
1.AS
LAS
Production Engine Testing Unit
l.AT
l.AT
Production Engine Testing Unit
l.AU
l.AU
Production Engine Testing Unit
l.C
l.C
Non-Production Heating Unit
l.D
l.D
Hot Water Heater
1.FLAME 1
1.FLAME 1
Plant 1 Flamecutting Unit (Fugitive)
1.FLAME2
1.FLAME2
Plant 1 Flamecutting Unit (Fugitive)
l.J
l.J
Plant 1 Paint Oven
l.K
l.K
Plant 1 Parts Paint Booth
l.O
l.O
Non-Production Heating Unit
1.PLASMA1
1.PLASMA1
Plant 1 Plasmacutter (Fugitive)
l.PRTWSH
l.PRTWSH
Five (5) Safety Kleen Parts Washers (Fugitive)
l.T
l.T
Steel Shot Metal Blast Booth
1.TORCH
1.TORCH
Nine (9) Torchcutting Units (Fugitive)
l.U
l.U
Hot Water Heater
l.V
l.V
Non-Production Heating Unit
1. WELDING
1. WELDING
37 Gas-Metal Arc Welders (Fugitive)
l.WELDPLS
l.WELDPLS
19 Pulse Current Gas-Metal Arc Welders (Fugitive)
4
-------
Equipment List (continued)
Emission Point
Associated
Associated Emission Unit Description
Number
Emission Unit
Number (s)
l.Y
l.Y
Non-Production Heating Unit
2.AB
2.AB
Production Engine Testing Unit
2.AF
2.AF1
Paint Kitchen
2.AF
2.AF2
Paint Kitchen
2.AG
2.AG
Paint Kitchen
2.AI1
2.AI
Plant 2 Finish Paint Booth
2.AI2
2.AI
Plant 2 Finish Paint Booth
2.AJ
2.AJ
Plant 2 Finish Paint Booth Air Intake Heater
2.B
2.B
Non-Production Heating Unit
2.E
2.E
Production Engine Testing Unit
2.F1
2.F
Plant 2 Finish Paint Booth
2.F2
2.F
Plant 2 Finish Paint Booth
2.FLAME1
2.FLAME1
Plant 2 Flamecutting Unit (Fugitive)
2.FLAME2
2.FLAME2
Plant 2 Flamecutting Unit (Fugitive)
2.G
2.G
Production Engine Testing Unit
2.H
2.H
Plant 2 Parts Paint Booth
2.1
2.1
Plant 2 Paint Oven
2.J
2.J
Production Engine Testing Unit
2.P
2.P
Non-Production Heating Unit
2.PLASMA1
2.PLASMA1
Plant 2 Plasmacutter (Fugitive)
2.PLASMA2
2.PLASMA2
Plant 2 Plasmacutter (Fugitive)
2.PLASMA3
2.PLASMA3
Plant 2 Whitney Plasmacutter (Fugitive)
2.PLASMA4
2.PLASMA4
Plant 2 Whitney Plasmacutter (Fugitive)
2.PLASMA5
2.PLASMA5
Plant 2 Whitney Plasmacutter (Fugitive)
2.PRTWSH
2.PRTWSH
Four (4) Safety Kleen Parts Washers (Fugitive)
2.Q
2.Q
Hot Water Heater
2.T
2.T
Non-Production Heating Unit
2.TORCH
2.TORCH
Nine (9) Torchcutting Units (Fugitive)
2. VI
2. VI
Non-Production Heating Unit
2.V2
2.V2
Non-Production Heating Unit
2. WELDING
2. WELDING
45 Gas-Metal Arc Welders (Fugitive)
2.WELDPLS
2.WELDPLS
8 Pulse Current Gas-Metal Arc Welders (Fugitive)
2.X
2.X
Non-Production Heating Unit
2.Y1
2.Y1
Non-Production Heating Unit
3.A1
3.A1
Production Engine Testing Unit
3.A2
3.A2
Production Engine Testing Unit
3.AA
3.AA
Metal Parts Preheating Oven
5
-------
Equipment List (continued)
Emission Point
Associated
Associated Emission Unit Description
Number
Emission Unit
Number (s)
3.B
3.B
Plant 3 Finish Paint Oven
3.BB
3.BB
Non-Production Heating Unit
3.C
3.C
Non-Production Heating Unit
3.D1
3.D1
Production Engine Testing Unit
3.D2
3.D2
Production Engine Testing Unit
3.D3
3.D3
Production Engine Testing Unit
3.EE
3.EE
Non-Production Heating Unit
3.F1
3.F1
Plant 3 Finish Paint Booth
3.F2
3.F2
Plant 3 Finish Paint Booth
3.FLAME1
3.FLAME1
Plant 3 Flamecutting Unit (Fugitive)
3.FLAME2
3.FLAME2
Plant 3 Flamecutting Unit (Fugitive)
3.FLAME3
3.FLAME3
Plant 3 Flamecutting Unit (Fugitive)
3.FLAME4
3.FLAME4
Plant 3 Flamecutting Unit (Fugitive)
3.FLAME5
3.FLAME5
Plant 3 Flamecutting Unit (Fugitive)
3.G
3.G
Plant 3 Parts Paint Booth
3.GG
3.GG
Non-Production Heating Unit
3.GH
3.GH
Paint Kitchen
3.GI
3.GI
Paint Kitchen
3.H
3.H
Hot Water Heater
3.HH
3.HH
Plant 3 Paint Booth
3.1
3.1
Plant 3 Paint Oven
3.II
3.II
Plant 3 Paint Booth
3.JJ
3.JJ
Plant 3 Paint Oven
3.KK
3.KK
Paint Kitchen
3.M
3.M
Hot Water Heater
3.N2
3.N2
Non-Production Heating Unit
3.P
3.P
Non-Production Heating Unit
3.PLASMA1
3.PLASMA1
Plant 3 Plasmacutter (Fugitive)
3.PLASMA2
3.PLASMA2
Plant 3 Plasmacutter (Fugitive)
3.PLASMA3
3.PLASMA3
Plant 3 Plasmacutter (Fugitive)
3.PLASMA4
3.PLASMA4
Plant 3 Whitney Plasmacutter (Fugitive)
3.PLASMA5
3.PLASMA5
Plant 3 Whitney Plasmacutter (Fugitive)
3.PLASMA6
3.PLASMA6
Plant 3 Whitney Plasmacutter (Fugitive)
3.PRTWSH
3.PRTWSH
Three (3) Safety Kleen Parts Washers (Fugitive)
3.S
3.S
Production Engine Testing Unit
3.T
3.T
Non-Production Heating Unit
-------
Equipment List (continued)
Emission Point
Associated
Associated Emission Unit Description
Number
Emission Unit
Number (s)
3.TORCH
3.TORCH
Seventeen (17) Torchcutting Units (Fugitive)
3.W
3.W
Non-Production Heating Unit
3. WELDING
3. WELDING
64 Gas-Metal Arc Welders (Fugitive)
3.WELDPLS
3.WELDPLS
16 Pulse Current Gas-Metal Arc Welders (Fugitive)
3.X1
3.X1
Non-Production Heating Unit
3.X2
3.X2
Non-Production Heating Unit
3.Y1
3.Y1
Non-Production Heating Unit
3.Z
3.Z
Production Engine Testing Unit
4.A1
4.A1
Non-Production Heating Unit
4.A2
4.A2
Non-Production Heating Unit
4.A3
4.A3
Non-Production Heating Unit
4.AA
4.AA
Non-Production Heating Unit
4.BB
4.BB
Non-Production Heating Unit
4.CD
4.CD
Paint Kitchen
4.CE
4.CE1
Paint Kitchen
4.CE
4.CE2
Paint Kitchen
4.D
4.D
Hot Water Heater
4.E
4.E
Plant 4 Paint Oven
4.F
4.F
Plant 4 Parts Paint Booth
4.FLAME1
4.FLAME1
Plant 4 Flamecutting Unit (Fugitive)
4.FLAME2
4.FLAME2
Plant 4 Flamecutting Unit (Fugitive)
4.FLAME3
4.FLAME3
Plant 4 Flamecutting Unit (Fugitive)
4.G1
4.G
Plant 4 Finish Paint Booth
4.G2
4.G
Plant 4 Finish Paint Booth
4.H2
4.H2
Non-Production Heating Unit
4.1
4.1
Production Engine Testing Unit
4.J
4.J
Production Engine Testing Unit
4.K2
4.K2
Non-Production Heating Unit
4.L
4.L
Non-Production Heating Unit
4.LASER
4.LASER
Plant 4 Laser cutting Unit (Fugitive)
4.PLASMA1
4.PLASMA1
Plant 4 Plasmacutter (Fugitive)
4.PLASMA2
4.PLASMA2
Plant 4 Plasmacutter (Fugitive)
4.PLASMA3
4.PLASMA3
Plant 4 Plasmacutter (Fugitive)
4.PLASMA4
4.PLASMA4
Plant 4 Whitney Plasmacutter (Fugitive)
4.PLASMA5
4.PLASMA5
Plant 4 Whitney Plasmacutter (Fugitive)
4.PRTWSH
4.PRTWSH
Seven (7) Safety Kleen Parts Washers (Fugitive)
4.R
4.R
Non-Production Heating Unit
7
-------
Equipment List (continued)
Emission Point
Number
4.S
4.T
4.TORCH
4. WELDING
4.WELDPLS
4.Z
5.A
5.AA
5.B1
5.B2
5.BB
5.BB
5.CC
5.CC
5.DD
5.E
5.EE
5.FF
5.FLAME1
5.G1
5.G2
5.GG
5.H
5.HH
5.1
5.II
5.J
5.K
5.M
5.N
5.PLASMA1
5.PLASMA2
5.PLASMA3
5.PLASMA4
5.PRTWSH
5.R
5.T
Associated
Emission Unit
Number (s)
4S
4.T
4.TORCH
4. WELDING
4.WELDPLS
4.Z
5.A
5.AA
5.B1
5.B2
5.BB1
5.BB2
5.CC1
5.CC2
5.DD
5.E
5.EE
5.FF
5.FLAME1
5.G
5.G
5.GG
5.H
5.HH
5.1
5.II
5.J
5.K
5.M
5.N
5.PLASMA1
5.PLASMA2
5.PLASMA3
5.PLASMA4
5.PRTWSH
5.R
5.T
Associated Emission Unit Description
Production Engine Testing Unit
Non-Production Heating Unit
Thirteen (13) Torchcutting Units (Fugitive)
66 Gas-Metal Arc Welders (Fugitive)
30 Pulse Current Gas-Metal Arc Welders (Fugitive)
Hot Water Heater
Non-Production Heating Unit
Non-Production Heating Unit
Non-Production Heating Unit
Non-Production Heating Unit
Paint Kitchen
Paint Kitchen
Paint Kitchen
Paint Kitchen
Paint Kitchen
Hot Water Heater
Non-Production Heating Unit
Non-Production Heating Unit
Plant 5 Flamecutting Unit (Fugitive)
Plant 5 Finish Paint Booth
Plant 5 Finish Paint Booth
Non-Production Heating Unit
Non-Production Heating Unit
Non-Production Heating Unit
Plant 5 Paint Oven
Non-Production Heating Unit
Plant 5 Parts Paint Booth
Non-Production Heating Unit
Non-Production Heating Unit
Production Engine Testing Unit
Plant 5 Plasmacutter (Fugitive)
Plant 5 Plasmacutter (Fugitive)
Plant 5 Whitney Plasmacutter (Fugitive)
Plant 5 Whitney Plasmacutter (Fugitive)
Two (2) Safety Kleen Parts Washers (Fugitive)
Hot Water Heater
Production Engine Testing Unit
8
-------
Equipment List (continued)
Emission Point
Associated
Associated Emission Unit Description
Number
Emission Unit
Number (s)
5.TORCH
5.TORCH
Seven (7) Torchcutting Units (Fugitive)
5.W
5.W
Production Engine Testing Unit
5. WELDING
5. WELDING
62 Gas-Metal Arc Welders (Fugitive)
5.WELDPLS
5.WELDPLS
45 Pulse Current Gas-Metal Arc Welders (Fugitive)
6.AB
6.AB
Non-Production Heating Unit
6.AC
6.AC
Non-Production Heating Unit
6.AD
6.AD
Non-Production Heating Unit
6.AE
6.AE
Non-Production Heating Unit
6.AF
6.AF
Non-Production Heating Unit
6.AG
6.AG
Non-Production Heating Unit
6.C
6.C
Non-Production Heating Unit
6.D
6.D
Production Engine Testing Unit
6.DD
6.DD
Non-Production Heating Unit
6.F
6.F
Plant 6 Paint Oven
6.FF
6.FF
Paint Kitchen
6.GG
6.GG
Paint Kitchen
6.H
6.H
Hot Water Heater
6.HH
6.HH
Plant 6 Primer Paint Booth
6.JJ
6.JJ
Paint Booth Air Intake
6.K
6.K
Production Engine Testing Unit
6.KK
6.KK
Paint Booth Air Intake
6.L
6.L
Non-Production Heating Unit
6.LL
6.LL
Production Engine Testing Unit
6.M1
6.M1
Plant 6 Finish Paint Booth
6.M2
6.M2
Plant 6 Finish Paint Booth
6.MM
6.MM
Production Engine Testing Unit
6.N
6.N
Plant 6 Parts Paint Booth
6.PLASMA1
6.PLASMA1
Plant 6 Plasmacutter (Fugitive)
6.PRTWSH
6.PRTWSH
Two (2) Safety Kleen Parts Washers (Fugitive)
6.Q
6.Q
Hot Water Heater
6.QQ
6.QQ
Stage 1 Washer
6.R
6.R
Non-Production Heating Unit
6.RR
6.RR
Stage 1 Burner
6.S
6.S
Plant 6 Finish Paint Booth
6.SS
6.SS
Stage 3 Burner
6.T
6.T
Non-Production Heating Unit
6.TORCH
6.TORCH
Ten (10) Torchcutting Units (Fugitive)
-------
Equipment List (continued)
Emission Point
Associated
Associated Emission Unit Description
Number
Emission Unit
Number (s)
6.TT
6.TT
Stage 5 Burner
6.UU
6.UU
Stage 5 Washer
6.W
6.W
Paint Kitchen
6.W
6.W
Plant 6 Paint Oven
6. WW
6. WW
Paint Kitchen
6. WELDING
6. WELDING
19 Gas-Metal Arc Welders (Fugitive)
6.WELDPLS
6.WELDPLS
10 Pulse Current Gas-Metal Arc Welders (Fugitive)
6.XX
6.XX
Production Engine Testing Unit
7.B1
7.B1
Non-Production Heating Unit
7.B2
7.B2
Non-Production Heating Unit
7.B3
7.B3
Non-Production Heating Unit
7.B4
7.B4
Non-Production Heating Unit
7.D
7.D
Non-Production Heating Unit
7.FLAME1
7.FLAME1
Plant 7 Flamecutting Unit (Fugitive)
7.FLAME2
7.FLAME2
Plant 7 Flamecutting Unit (Fugitive)
7.FLAME3
7.FLAME3
Plant 7 Flamecutting Unit (Fugitive)
7.FLAME4
7.FLAME4
Plant 7 Flamecutting Unit (Fugitive)
7.FLAME5
7.FLAME5
Plant 7 Flamecutting Unit (Fugitive)
7.FLAME6
7.FLAME6
Plant 7 Flamecutting Unit (Fugitive)
7.G
7.G
Production Engine Testing Unit
7.H
7.H
Production Engine Testing Unit
7.1
7.1
Production Engine Testing Unit
7.K
7.K
Non-Production Heating Unit
7.L
7.L
Non-Production Heating Unit
7.LASER
7.LASER
Four (4) Plant 7 Laser cutting Units (Fugitive)
7.M
7.M
Non-Production Heating Unit
7.N
7.N
Non-Production Heating Unit
7.0
7.0
Non-Production Heating Unit
7.P
7.P
Non-Production Heating Unit
7.PLASMA1
7.PLASMA1
Plant 7 Plasmacutter (Fugitive)
7.PLASMA2
7.PLASMA2
Plant 7 Plasmacutter (Fugitive)
7.PLASMA3
7.PLASMA3
Plant 7 Plasmacutter (Fugitive)
7.PLASMA4
7.PLASMA4
Plant 7 Plasmacutter (Fugitive)
7.PLASMA5
7.PLASMA5
Plant 7 Plasmacutter (Fugitive)
7.PLASMA6
7.PLASMA6
Plant 7 Plasmacutter (Fugitive)
7.PRTWSH
7.PRTWSH
Three (3) Safety Kleen Parts Washers (Fugitive)
7.Q
7.Q
Non-Production Heating Unit
-------
Equipment List (continued)
Emission Point
Associated
Associated Emission Unit Description
Number
Emission Unit
Number (s)
7.R
7.R
One (1) Safety Kleen Parts Washer (Fugitive)
7.S
7.S
Non-Production Heating Unit
7.T
7.T
Non-Production Heating Unit
7.TORCH
7.TORCH
Ten (10) Torchcutting Units (Fugitive)
7.U
7.U
Non-Production Heating Unit
7.V
7.V
Non-Production Heating Unit
7. WELDING
7. WELDING
61 Gas-Metal Arc Welders (Fugitive)
7.WELDPLS
7.WELDPLS
47 Pulse Current Gas-Metal Arc Welders (Fugitive)
8.A1
8.A1
Non-Production Heating Unit
8.A2
8.A2
Non-Production Heating Unit
8.A3
8.A3
Non-Production Heating Unit
8.A4
8.A4
Non-Production Heating Unit
8.A5
8.A5
Non-Production Heating Unit
8.A6
8.A6
Non-Production Heating Unit
8.A7
8.A7
Non-Production Heating Unit
8.A8
8.A8
Non-Production Heating Unit
8.A9
8.A9
Non-Production Heating Unit
8.A10
8.A10
Non-Production Heating Unit
8. All
8. All
Non-Production Heating Unit
8.A12
8.A12
Non-Production Heating Unit
8.B
8.B
Production Engine Testing Unit
DSLTANK2
DSLTANK2
1,000 Gallon #2 Diesel Fuel Storage Tank
DSLTANK4
DSLTANK4
1,000 Gallon #2 Diesel Fuel Storage Tank
DSLTANK8
DSLTANK8
1,000 Gallon #2 Diesel Fuel Storage Tank
DSLTANK9
DSLTANK9
1,000 Gallon #2 Diesel Fuel Storage Tank
GASTANK3
GASTANK3
1,000 Gallon Gasoline Storage Tank
GASTANK7
GASTANK7
1,000 Gallon Gasoline Storage Tank
HB.A
HB.A
Production Engine Testing Unit
P.A1
P.A1
Non-Production Heating Unit
P.A2
P.A2
Non-Production Heating Unit
P.C1
P.C1
Non-Production Heating Unit
P.C2
P.C2
Non-Production Heating Unit
P.D1
P.D1
Non-Production Heating Unit
P.D2
P.D2
Non-Production Heating Unit
P.D3
P.D3
Non-Production Heating Unit
P.E
P.E
Non-Production Heating Unit
P.O
P.O
Two (2) Safety Kleen Parts Washers (Fugitive)
11
-------
Equipment List (continued)
Emission Point
Associated
Associated Emission Unit Description
Number
Emission Unit
Number (s)
P.PRTWSH
P.PRTWSH
Four (4) Safety Kleen Parts Washers (Fugitive)
P.TORCH
P.TORCH
Two (2) Parts Plant Torchcutting Units (Fugitive)
P. WELDING
P. WELDING
2 Gas-Metal Arc Welders (Fugitive)
Q.A
Q.A
Non-Production Heating Unit
W.A1
W.A1
Non-Production Heating Unit
W.B
W.B
Natural Gas Hotsey Washer
W.E
W.E
Waste Management Hook Burn-Off Oven
W.F1
W.F1
Waste Solvent Still
W.F2
W.F2
Waste Solvent Still
W.H
W.H
Aerosol Can Crusher
W.M
W.M
One (1) Safety Kleen Parts Washer (Fugitive)
F.SAND
F.SAND
Sand Blasting Unit (Fugitive)
F.SODA
F.SODA
Soda Blasting Unit (Fugitive)
PROPANE
PROPANE
Three (3) 6,000 gallon Propane Storage Tanks
PROPYLENE
PROPYLENE
Three (3) 1,000 gallon Propylene Storage Tanks
OILTANK
OILTANK
One (1) 5,000 gallon Used Oil Storage Tank
Insignificant Equipment List
Insignificant Emission Insignificant Emission Unit Description
Unit Number
1.METAL
2.METAL
3.METAL
4.METAL
5.METAL
6.METAL
Plant 1 Metal Drilling, Machining, and Grinding Operations
Plant 2 Metal Drilling, Machining, and Grinding Operations
Plant 3 Metal Drilling, Machining, and Grinding Operations
Plant 4 Metal Drilling, Machining, and Grinding Operations
Plant 5 Metal Drilling, Machining, and Grinding Operations
Plant 6 Metal Drilling, Machining, and Grinding Operations
12
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II. Facility-Wide Conditions
Facility Name: Vermeer Manufacturing Co.
Permit Number: 99-TV-052
Permit conditions are established in accord with 567 Iowa Administrative Code rule
22.108
Permit Duration
The term of this permit is: .... 5 years
Commencing on: October 19, 1999
Ending on: October 18, 2004
Amendments, modifications and reopenings of the permit shall be obtained in accordance
with 567 Iowa Administrative Code rules 22.110 - 22.114. Permits may be suspended,
terminated, or revoked as specified in 567 Iowa Administrative Code Rules 22.115.
Emission Limits
The atmospheric emissions from the facility and the specified units shall not exceed the
following:
Pollutant: Nitrogen Oxides (NOx) Facility-wide limit
Emission Rate (tons/yr.): 249
Authority for Requirement: Iowa DNR Construction Permit 97-A-298-S3
Pollutant: Volatile Organic Compound (VOC) Facility-wide limit
Emission Rate (tons/yr.): 249
Authority for Requirement: Iowa DNR Construction Permit 96-A-1216-S3
Reporting & Recordkeeping:
All records, as required in the following, shall be satisfactory for demonstrating
compliance with all applicable emission limits.
Records shall be kept on-site for five years and shall be available for inspection by
the Department. Records shall be maintained in a legible and orderly manner and
shall indicate the following:
A. The amount of each paint and solvent used in all painting operations, other than
architectural, in gallons. Calculate and record monthly and 12-month rolling
totals for each paint and solvent.
B. The VOC content of any paint and solvent used in all painting operations, other
than architectural, in pounds per gallon.
C. The amount of paint and solvent waste sent off-site for disposal from all painting
operations, other than architectural, in gallons. Calculate and record monthly and
12-month rolling totals for each waste stream.
13
-------
D. The VOC content of any paint and solvent waste from production operations,
other than architectural, sent off site for disposal, in pounds per gallon.
E. The amount of solvent recycled for re-use in all painting operations, other than
architectural, in gallons.
F. The VOC content of any solvent recycled for reuse in all painting operations,
other than architectural, in pounds per gallon.
G. Calculate and record monthly and 12-month rolling totals of VOC emissions from
all painting operations, other than architectural, at this source, in tons.
H. Calculate and record monthly and 12-month rolling totals of VOC emissions from
all emission units at this source, in tons.
Authority for Requirement: Iowa DNR Construction Permit 97-A-972-S3
A. The amount of diesel fuel used in all production test units, in gallons. Calculate
and record monthly and 12-month rolling totals.
B. The amount of gasoline used in all production test units, in gallons. Calculate and
record monthly and 12-month rolling totals.
C. The sulfur content of any fuel used in this unit, in weight percent.
D. The amount of VOC emitted by the production test units, in tons. Calculate and
record monthly and 12-month rolling totals. Emissions must be based on total
gallons used and AP-42 factors for engines less than 600 hp.
E. The amount of NOx emitted by the production test units, in tons. Calculate and
record monthly and 12-month rolling totals. Emissions must be based on total
gallons used and AP-42 factors for engines less than 600 hp.
F. Calculate and record monthly and 12-month rolling totals of NOx emissions from
all production test units at this source, in tons.
G. Calculate and record monthly and 12-month rolling totals of VOC emissions from
all production test units at this source, in tons.
H. Calculate and record monthly and 12-month rolling totals of NOx emissions from
all emission units at this source, in tons.
I. Calculate and record monthly and 12-month rolling totals of VOC emissions from
all emission units at this source, in tons.
Authority for Requirement: Iowa DNR Construction Permit 97-A-299-S3
A. The amount of natural gas used in all units, in cubic feet. Calculate and record
monthly and 12-month rolling totals.
B. The amount of propane used in all units, in gallons. Calculate and record monthly
and 12-month rolling totals.
C. The amount VOC emitted by all natural gas and propane fired units, in tons.
Calculate and record monthly and 12-month rolling totals.
D. The amount NOx emitted by all natural gas and propane fired units, in tons.
Calculate and record monthly and 12-month rolling totals.
Authority for Requirement: Iowa DNR Construction Permit 98-A-094-S1
14
-------
Facility-Wide Operational Limits
The facility as a whole shall adhere to the following:
Process Throughput:
A. The sulfur content of any diesel fuel used at this facility shall not exceed 0.4% by
weight.
Reporting & Record keeping: See the previous Emission Limits section requirements.
Authority for Requirement: Iowa DNR Construction Permit 97-A-l 100-S2
Process Throughput:
A. The sulfur content of any number one or number two diesel fuel combusted at this
facility shall not exceed 0.5% by weight.
Reporting & Record keeping: See the previous Emission Limits section requirements.
Authority for Requirement: 567 IAC 23.3(3)
Process Throughput:
A. The sulfur content of natural gas or LPG combusted at this facility shall not
exceed 123 ppm by weight.
Reporting & Record keeping:
All records, as required in the following, shall demonstrate compliance with all
applicable limits on LPG.
All records shall be made available for inspection upon request by representatives of
the Iowa DNR. The records, as a minimum, shall consist of the following:
A. The amount of LPG purchased by this facility, in gallons. Calculate and record
monthly and twelve (12) month rolling totals.
B. The owner/operator shall obtain two reports per year from the LPG supplier, one
in July and one in December, to verify the sulfur content of the LPG.
Authority for Requirement: Part 7a. of State of Iowa, ex rel., Iowa DNR vs. Vermeer
Manufacturing Company, 99AG23542
District Court, Marion County, Law No. LACV087889
Unless specified otherwise in the Source Specific Conditions, the following limitations
and supporting regulations apply to all emission points at this facility:
Opacity (visible emissions'): 40% opacity
Authority for Requirement: 567 IAC 23.3(2)"d"
SO?: 500 parts per million
Authority for Requirement: 567 IAC 23.3(3)"e"
Particulate Matter: Shall not exceed the amount determined from Table I (process weight
rate) of Chapter 23 of the rules. If the director determines that a process complying with
the emission rates specified in Table I is causing or will cause air pollution in a specific
area of the state, an emission standard of 0.1 grain per standard cubic foot of exhaust gas
may be imposed.
Authority for Requirement: 567 IAC 23.3(2)"a"
15
-------
Fugitive Dust: Attainment and Unclassified Areas - No person shall allow, cause or
permit any materials to be handled, transported or stored; or a building, its appurtenances
or a construction haul road to be used, constructed, altered repaired or demolished, with
the exception of farming operations or dust generated by ordinary travel on unpaved
public roads, without taking reasonable precautions to prevent particulate matter in
quantities sufficient to create a nuisance, as defined in Iowa Code section 657.1, from
becoming airborne. All persons, with the above exceptions, shall take reasonable
precautions to prevent the discharge of visible emissions of fugitive dusts beyond the lot
line of the property on which the emissions originate. The highway authority shall be
responsible for taking corrective action in those cases where said authority has received
complaints of or has actual knowledge of dust conditions that require abatement pursuant
to this subrule. Reasonable precautions may include, but not limited to, the following
procedures.
1. Use, where practical, of water or chemicals for control of dusts in the demolition
of existing buildings or structures, construction operations, the grading of roads or
the clearing of land.
2. Application of suitable materials, such as but not limited to asphalt, oil, water or
chemicals on unpaved roads, material stockpiles, race tracks and other surfaces
which can give rise to airborne dusts.
3. Installation and use of containment or control equipment, to enclose or otherwise
limit the emissions resulting from the handling and transfer of dusty materials,
such as but not limited to grain, fertilizers or limestone.
4. Covering at all times when in motion, open-bodied vehicles transporting materials
likely to give rise to airborne dusts.
5. Prompt removal of earth or other material from paved streets or to which earth or
other material has been transported by trucking or earth-moving equipment,
erosion by water or other means.
Authority for Requirement: 567--IAC 23.3(2)"c"
16
-------
III. Emission Point-Specific Conditions
Facility Name: Vermeer Manufacturing Co.
Permit Number: 99-TV-052
Emission Point ID Number: l.AA
Associated Equipment
Associated Emission Unit ID Numbers (if multiple units vent thru this EP): 1. AA
Applicable Requirements
(If more than one emission unit vents through this emission point subdivide the applicable requirements by emission
unit.)
Emission Unit vented through this Emission Point: 1.AA
Emission Unit Description: Non-Production Heating Unit
Raw Material/Fuel: Propane (LPG) or Natural Gas
Rated Capacity: 0.35 MMBtu/hr.
Emission Limits (lb./hr. gr./dscf. lb./MMBtu. % opacity, etc.):
The emissions from this emission point shall not exceed the following specified levels.
Pollutant: Opacity
Emission Limit(s): 40 %
Authority for Requirement: 567 IAC 23.3(2)"d"
Pollutant: Particulate Matter (TSP)
Emission Limit(s): 15.3 lb./MMCF of LPG or Natural Gas
Authority for Requirement: Part 7a. of State of Iowa, ex rel., Iowa DNR vs. Vermeer
Manufacturing Company, 99AG23542
District Court, Marion County, Law No. LACV087889
Pollutant: Particulate Matter (TSP)
Emission Limits: 0.8 lb./MMBtu
Authority for Requirement: 567 IAC 23.3(2)"b"
Pollutant: Sulfur Dioxide (SO2)
Emission Limits: 500 ppmv
Authority for Requirement: 567 IAC 23.3(3)"e"
Pollutant: Nitrogen Oxides (NOx)
Emission Limit(s): See Facility-Wide Conditions
Authority for Requirement: Iowa DNR Construction Permit 98-A-003-S1
17
-------
Emission Limits (continued):
Pollutant: Volatile Organic Compounds (VOC)
Emission Limit: See Facility-Wide Conditions
Authority for Requirement: Iowa DNR Construction Permit 98-A-003-S1
Operational Limits & Requirements:
The owner/operator of this equipment shall comply with the following operational limits
and requirements.
Process throughput:
A. The sulfur content of natural gas or LPG combusted by this source is not to
exceed 123 ppm by weight.
Reporting & Recordkeeping: See Facility-Wide Operational Limits
Authority for Requirement: Part 7b. of State of Iowa, ex rel., Iowa DNR vs. Vermeer
Manufacturing Company, 99AG23542
District Court, Marion County, Law No. LACV087889
Compliance Plan:
The owner/operator of this equipment shall comply with the following applicable
requirements.
This point is in compliance with all applicable requirements and shall continue to comply
with all such requirements. For those applicable requirements which will become
effective during the permit term, this source will comply with such requirements in a
timely manner.
Periodic Monitoring Requirements:
The owner/operator of this equipment shall comply with the following periodic
monitoring requirements.
Agency Approved Operation & Maintenance Plan Required? Yes ~ No Kl
Facility Maintained Operation & Maintenance Plan Required? Yes ~ No Kl
Authority for Requirement: 567 IAC 22.108(3)"b"
18
-------
Emission Point ID Number: l.AC
Associated Equipment
Associated Emission Unit ID Numbers (if multiple units vent thru this EP):
l.AC
Applicable Requirements
(If more than one emission unit vents through this emission point subdivide the applicable requirements by emission
unit.)
Emission Unit vented through this Emission Point: 1 .AC
Emission Unit Description: Non-Production Heating Unit
Raw Material/Fuel: Propane (LPG) or Natural Gas
Rated Capacity: 0.35 MMBtu/hr.
Emission Limits (lb./hr. gr./dscf. lb./MMBtu. % opacity, etc.):
The emissions from this emission point shall not exceed the following specified levels.
Pollutant: Opacity
Emission Limit(s): 40 %
Authority for Requirement: 567 IAC 23.3(2)"d"
Pollutant: Particulate Matter (TSP)
Emission Limit(s): 15.3 lb./MMCF of LPG or Natural Gas
Authority for Requirement: Part 7a. of State of Iowa, ex rel., Iowa DNR vs. Vermeer
Manufacturing Company, 99AG23542
District Court, Marion County, Law No. LACV087889
Pollutant: Particulate Matter (TSP)
Emission Limits: 0.8 lb./MMBtu
Authority for Requirement: 567 IAC 23.3(2)"b"
Pollutant: Sulfur Dioxide (SO2)
Emission Limits: 500 ppmv
Authority for Requirement: 567 IAC 23.3(3)"e"
Pollutant: Nitrogen Oxides (NOx)
Emission Limit(s): See Facility-Wide Conditions
Authority for Requirement: Iowa DNR Construction Permit 98-A-003-S1
Pollutant: Volatile Organic Compounds (VOC)
Emission Limit: See Facility-Wide Conditions
Authority for Requirement: Iowa DNR Construction Permit 98-A-003-S1
19
-------
Operational Limits & Requirements:
The owner/operator of this equipment shall comply with the following operational limits
and requirements.
Process throughput:
A. The sulfur content of natural gas or LPG combusted by this source is not to
exceed 123 ppm by weight.
Reporting & Recordkeeping: See Facility-Wide Operational Limits
Authority for Requirement: Part 7b. of State of Iowa, ex rel., Iowa DNR vs. Vermeer
Manufacturing Company, 99AG23542
District Court, Marion County, Law No. LACV087889
Compliance Plan:
The owner/operator of this equipment shall comply with the following applicable
requirements.
This point is in compliance with all applicable requirements and shall continue to comply
with all such requirements. For those applicable requirements which will become
effective during the permit term, this source will comply with such requirements in a
timely manner.
Periodic Monitoring Requirements:
The owner/operator of this equipment shall comply with the following periodic
monitoring requirements.
Agency Approved Operation & Maintenance Plan Required? Yes ~ No IXI
Facility Maintained Operation & Maintenance Plan Required? Yes ~ No Kl
Authority for Requirement: 567 IAC 22.108(3)"b"
20
-------
Emission Point ID Number: l.AD
Associated Equipment
Associated Emission Unit ID Numbers (if multiple units vent thru this EP):
l.AD
Applicable Requirements
(If more than one emission unit vents through this emission point subdivide the applicable requirements by emission
unit.)
Emission Unit vented through this Emission Point: 1 .AD
Emission Unit Description: Non-Production Heating Unit
Raw Material/Fuel: Propane (LPG) or Natural Gas
Rated Capacity: 0.18 MMBtu/hr.
Emission Limits (lb./hr. gr./dscf. lb./MMBtu. % opacity, etc.):
The emissions from this emission point shall not exceed the following specified levels.
Pollutant: Opacity
Emission Limit(s): 40 %
Authority for Requirement: 567 IAC 23.3(2)"d"
Pollutant: Particulate Matter (TSP)
Emission Limit(s): 15.3 lb./MMCF of LPG or Natural Gas
Authority for Requirement: Part 7a. of State of Iowa, ex rel., Iowa DNR vs. Vermeer
Manufacturing Company, 99AG23542
District Court, Marion County, Law No. LACV087889
Pollutant: Particulate Matter (TSP)
Emission Limits: 0.8 lb./MMBtu
Authority for Requirement: 567 IAC 23.3(2)"b"
Pollutant: Sulfur Dioxide (SO2)
Emission Limits: 500 ppmv
Authority for Requirement: 567 IAC 23.3(3)"e"
Pollutant: Nitrogen Oxides (NOx)
Emission Limit(s): See Facility-Wide Conditions
Authority for Requirement: Iowa DNR Construction Permit 98-A-003-S1
Pollutant: Volatile Organic Compounds (VOC)
Emission Limit: See Facility-Wide Conditions
Authority for Requirement: Iowa DNR Construction Permit 98-A-003-S1
21
-------
Operational Limits & Requirements:
The owner/operator of this equipment shall comply with the following operational limits
and requirements.
Process throughput:
A. The sulfur content of natural gas or LPG combusted by this source is not to
exceed 123 ppm by weight.
Reporting & Recordkeeping: See Facility-Wide Operational Limits
Authority for Requirement: Part 7b. of State of Iowa, ex rel., Iowa DNR vs. Vermeer
Manufacturing Company, 99AG23542
District Court, Marion County, Law No. LACV087889
Compliance Plan:
The owner/operator of this equipment shall comply with the following applicable
requirements.
This point is in compliance with all applicable requirements and shall continue to comply
with all such requirements. For those applicable requirements which will become
effective during the permit term, this source will comply with such requirements in a
timely manner.
Periodic Monitoring Requirements:
The owner/operator of this equipment shall comply with the following periodic
monitoring requirements.
Agency Approved Operation & Maintenance Plan Required? Yes ~ No IXI
Facility Maintained Operation & Maintenance Plan Required? Yes ~ No Kl
Authority for Requirement: 567 IAC 22.108(3)"b"
22
-------
Emission Point ID Number: l.AF
Associated Equipment
Associated Emission Unit ID Numbers (if multiple units vent thru this EP):
l.AF
Applicable Requirements
(If more than one emission unit vents through this emission point subdivide the applicable requirements by emission
unit.)
Emission Unit vented through this Emission Point: 1.AF
Emission Unit Description: Non-Production Heating Unit
Raw Material/Fuel: Propane (LPG) or Natural Gas
Rated Capacity: 1.95 MMBtu/hr.
Emission Limits (lb./hr. gr./dscf. lb./MMBtu. % opacity, etc.):
The emissions from this emission point shall not exceed the following specified levels.
Pollutant: Opacity
Emission Limit(s): 40 %
Authority for Requirement: 567 IAC 23.3(2)"d"
Pollutant: Particulate Matter (TSP)
Emission Limit(s): 15.3 lb./MMCF of LPG or Natural Gas
Authority for Requirement: Part 7a. of State of Iowa, ex rel., Iowa DNR vs. Vermeer
Manufacturing Company, 99AG23542
District Court, Marion County, Law No. LACV087889
Pollutant: Particulate Matter (TSP)
Emission Limits: 0.8 lb./MMBtu
Authority for Requirement: 567 IAC 23.3(2)"b"
Pollutant: Sulfur Dioxide (SO2)
Emission Limits: 500 ppmv
Authority for Requirement: 567 IAC 23.3(3)"e"
Pollutant: Nitrogen Oxides (NOx)
Emission Limit(s): See Facility-Wide Conditions
Authority for Requirement: Iowa DNR Construction Permit 98-A-003-S1
Pollutant: Volatile Organic Compounds (VOC)
Emission Limit: See Facility-Wide Conditions
Authority for Requirement: Iowa DNR Construction Permit 98-A-003-S1
23
-------
Operational Limits & Requirements:
The owner/operator of this equipment shall comply with the following operational limits
and requirements.
Process throughput:
A. The sulfur content of natural gas or LPG combusted by this source is not to
exceed 123 ppm by weight.
Reporting & Recordkeeping: See Facility-Wide Operational Limits
Authority for Requirement: Part 7b. of State of Iowa, ex rel., Iowa DNR vs. Vermeer
Manufacturing Company, 99AG23542
District Court, Marion County, Law No. LACV087889
Compliance Plan:
The owner/operator of this equipment shall comply with the following applicable
requirements.
This point is in compliance with all applicable requirements and shall continue to comply
with all such requirements. For those applicable requirements which will become
effective during the permit term, this source will comply with such requirements in a
timely manner.
Periodic Monitoring Requirements:
The owner/operator of this equipment shall comply with the following periodic
monitoring requirements.
Agency Approved Operation & Maintenance Plan Required? Yes ~ No IXI
Facility Maintained Operation & Maintenance Plan Required? Yes ~ No Kl
Authority for Requirement: 567 IAC 22.108(3)"b"
24
-------
Emission Point ID Number: 1.AG1
Associated Equipment
Associated Emission Unit ID Numbers (if multiple units vent thru this EP): 1 .AG
Emissions Control Equipment ID Number: 1 .AG
Emissions Control Equipment Description: Paper Filter
Applicable Requirements
(If more than one emission unit vents through this emission point subdivide the applicable requirements by emission
unit.)
Emission Unit vented through this Emission Point: 1 .AG
Emission Unit Description: Finish Paint Booth
Raw Material/Fuel: Paints, Primers, and Solvents
Rated Capacity: 15 gal./hr.
Emission Limits (lb./hr. gr./dscf. lb./MMBtu. % opacity, etc.):
The emissions from this emission point shall not exceed the following specified levels.
Pollutant: Opacity
Emission Limits: 40%
Indicator Opacity: (1)
(1) If visible emissions are observed other than startup, shutdown or malfunction, a stack
test may be required to demonstrate compliance with the particulate standard.
Authority for Requirement: Iowa DNR Construction Permit 97-A-972-S3
567 IAC23.3(2)"d"
Pollutant: PMio
Emission Limit(s): 1.0 lb./hr.
Authority for Requirement: Iowa DNR Construction Permit 97-A-972-S3
Pollutant: Particulate Matter (TSP)
Emission Limit(s): 0.01 gr./dscf
Authority for Requirement: Iowa DNR Construction Permit 97-A-972-S3
567 IAC 23.4(13)
Pollutant: Volatile Organic Compounds (VOC)
Emission Limit: See Facility-Wide Conditions
Authority for Requirement: Iowa DNR Construction Permit 97-A-972-S3
25
-------
Operational Limits & Requirements:
The owner/operator of this equipment shall comply with the following operational limits
and requirements.
Supplemental Environmental Project:
Equipment parameters:
The emission unit associated with this emission point will maintain a Graco, multi-
color, precision mix system with two gun flush boxes, solvent meters, and solvent
valves. The system will be supplied with a microprocessor which will control
solvent, paint, and catalyst flow to a mixing tube adjacent to the emission unit and
record the cumulative amount of the exact volume or weight of paint, solvent, or
catalyst utilized in the emission unit. The system will be interlocked with the two
Graco gun flush boxes, and the guns will be interlocked with the fans of the paint
spray booth.
Authority for Requirement: Paragraph 3b. of State of Iowa, ex rel., Iowa DNR vs.
Vermeer Manufacturing Company, 99AG23542
District Court, Marion County, Law No. LACV087889
Operational term: This SEP will be maintained for the life of this permit.
Authority for Requirement: Paragraph 3i. of State of Iowa, ex rel., Iowa DNR vs.
Vermeer Manufacturing Company, 99AG23542
District Court, Marion County, Law No. LACV087889
Reporting & Record keeping:
Vermeer shall submit to the DNR an annual performance report covering the required
period of use and maintenance of this SEP documenting the actual use and
maintenance of this SEP. The report shall evaluate the performance of the
SEP and document the extent of VOC emissions reductions. Vermeer shall conduct
cumulative mass balance calculations to determine the actual effect measured against
the 1997 baseline of 122.94 tons of VOC emitted per year. The reports shall be
submitted on or before March 1, for the preceding calendar year, commencing on
March 1, 1999. For additional reporting and recordkeeping see the Facility-Wide
Conditions.
Authority for Requirement: Paragraph 3j. of State of Iowa, ex rel., Iowa DNR vs.
Vermeer Manufacturing Company, 99AG23542
District Court, Marion County, Law No. LACV087889
Iowa DNR Construction Permit 97-A-972-S3
Compliance Plan:
The owner/operator of this equipment shall comply with the following applicable
requirements.
This point is in compliance with all applicable requirements and shall continue to comply
with all such requirements. For those applicable requirements which will become
effective during the permit term, this source will comply with such requirements in a
timely manner.
26
-------
Additional Requirements:
This emission point shall conform to the following conditions.
The source is to be connected to the stack of the following detailed description.
Stack Height (feet): 43.5
Stack Diameter (inches): 36.0
Stack Exhaust Flow Rate (acfm): .... 24,000
Stack Temperature (°F): 70
Vertical, Unobstructed Discharge Required: Yes ^ No ~
Authority for Requirement: Iowa DNR Construction Permit 97-A-972-S3
Periodic Monitoring Requirements:
The owner/operator of this equipment shall comply with the following periodic
monitoring requirements.
Stack Testing:
Pollutant: Particulate Matter (TSP)
Stack Test to be Completed by (date): October 18, 2001
Test Method: Iowa Compliance Sampling Manual
Authority for Requirement: 567 IAC 22.108(3)
The higher of the results for emissions from the compliance stack testing of emission
points 1.AG1 and 1.AG2 will be used to calculate actual emissions for this source until
such time as more recent data becomes available. If the source test does not demonstrate
compliance this permit will be reopened to add a compliance plan and operation and
maintenance requirements.
The owner of this equipment or the owner's authorized agent shall provide written notice
to the Director, not less than 30 days before a required stack test or performance
evaluation of a continuous emission monitor. Results of the test shall be submitted in
writing to the Director in the form of a comprehensive report within 6 weeks of the
completion of the testing. 567 IAC 25.1(7)
Opacity Monitoring:
The facility shall observe the opacity weekly during a period when the emission unit
associated with this emission point is at or near full capacity and record the reading
indicating if visible emissions were observed. The records shall be maintained for five
years. If weather conditions prevent the observer from conducting an opacity
observation, the observer shall note such conditions on the data observation sheet. At
least three attempts shall be made to retake opacity readings at approximately 2-hour
intervals throughout the day. If all observation attempts for a week have been
unsuccessful due to weather, an observation shall be made the next operating day where
weather permits.
Maintain a written record of the observation and any action resulting from the
observation.
27
-------
Agency Approved Operation & Maintenance Plan Required? Yes ~ No Kl
Facility Maintained Operation & Maintenance Plan Required? Yes Kl NoQ
Facility operation and maintenance plans must be sufficient to yield reliable data from
the relevant time period that are representative of the source's compliance with the
applicable requirements.
Facility operation and maintenance plans are to be developed by the facility within six
(6) months of the issuance date of this permit and the data pertaining to the plan
maintained on site for at least 5 years. The plan and associated recordkeeping provides
documentation of this facility's implementation of its obligation to operate according to
good air pollution control practice.
Good air pollution control practice is achieved by adoption of quality control standards
in the operation and maintenance procedures for air pollution control that are
comparable to industry quality control standards for the production processes associated
with this emission point.
Authority for Requirement: 567 IAC 22.108(3)"b"
28
-------
Emission Point ID Number: 1.AG2
Associated Equipment
Associated Emission Unit ID Numbers (if multiple units vent thru this EP): 1 .AG
Emissions Control Equipment ID Number: 1 .AG
Emissions Control Equipment Description: Paper Filter
Applicable Requirements
(If more than one emission unit vents through this emission point subdivide the applicable requirements by emission
unit.)
Emission Unit vented through this Emission Point: 1 .AG
Emission Unit Description: Finish Paint Booth
Raw Material/Fuel: Paints, Primers, and Solvents
Rated Capacity: 15 gal./hr.
Emission Limits (lb./hr. gr./dscf. lb./MMBtu. % opacity, etc.):
The emissions from this emission point shall not exceed the following specified levels.
Pollutant: Opacity
Emission Limits: 40%
Indicator Opacity: (1)
(1) If visible emissions are observed other than startup, shutdown or malfunction, a stack
test may be required to demonstrate compliance with the particulate standard.
Authority for Requirement: Iowa DNR Construction Permit 97-A-973-S3
567 IAC23.3(2)"d"
Pollutant: PMio
Emission Limit(s): 1.0 lb./hr.
Authority for Requirement: Iowa DNR Construction Permit 97-A-973-S3
Pollutant: Particulate Matter (TSP)
Emission Limit(s): 0.01 gr./dscf
Authority for Requirement: Iowa DNR Construction Permit 97-A-973-S3
567 IAC 23.4(13)
Pollutant: Volatile Organic Compounds (VOC)
Emission Limit: See Facility-Wide Conditions
Authority for Requirement: Iowa DNR Construction Permit 97-A-973-S3
29
-------
Operational Limits & Requirements:
The owner/operator of this equipment shall comply with the following operational limits
and requirements.
Supplemental Environmental Project:
Equipment parameters:
The emission unit associated with this emission point will maintain a Graco, multi-
color, precision mix system with two gun flush boxes, solvent meters, and solvent
valves. The system will be supplied with a microprocessor which will control
solvent, paint, and catalyst flow to a mixing tube adjacent to the emission unit and
record the cumulative amount of the exact volume or weight of paint, solvent, or
catalyst utilized in the emission unit. The system will be interlocked with the two
Graco gun flush boxes, and the guns will be interlocked with the fans of the paint
spray booth.
Authority for Requirement: Paragraph 3b. of State of Iowa, ex rel., Iowa DNR vs.
Vermeer Manufacturing Company, 99AG23542
District Court, Marion County, Law No. LACV087889
Operational term: This SEP will be maintained for the life of this permit.
Authority for Requirement: Paragraph 3i. of State of Iowa, ex rel., Iowa DNR vs.
Vermeer Manufacturing Company, 99AG23542
District Court, Marion County, Law No. LACV087889
Reporting & Record keeping:
Vermeer shall submit to the DNR an annual performance report covering the required
period of use and maintenance of this SEP documenting the actual use and
maintenance of this SEP. The report shall evaluate the performance of the SEP and
document the extent of VOC emissions reductions. Vermeer shall conduct
cumulative mass balance calculations to determine the actual effect measured against
the 1997 baseline of 122.94 tons of VOC emitted per year. The reports shall be
submitted on or before March 1, for the preceding calendar year, commencing on
March 1, 1999. For additional reporting and recordkeeping see the Facility-Wide
Conditions.
Authority for Requirement: Paragraph 3j. of State of Iowa, ex rel., Iowa DNR vs.
Vermeer Manufacturing Company, 99AG23542
District Court, Marion County, Law No. LACV087889
Iowa DNR Construction Permit 97-A-973-S3
Compliance Plan:
The owner/operator of this equipment shall comply with the following applicable
requirements.
This point is in compliance with all applicable requirements and shall continue to comply
with all such requirements. For those applicable requirements which will become
effective during the permit term, this source will comply with such requirements in a
timely manner.
30
-------
Additional Requirements:
This emission point shall conform to the following conditions.
The source is to be connected to the stack of the following detailed description.
Stack Height (feet): 43.5
Stack Diameter (inches): 36.0
Stack Exhaust Flow Rate (acfm): .... 24,000
Stack Temperature (°F): 70
Vertical, Unobstructed Discharge Required: Yes ^ No ~
Authority for Requirement: Iowa DNR Construction Permit 97-A-973-S3
Periodic Monitoring Requirements:
The owner/operator of this equipment shall comply with the following periodic
monitoring requirements.
Stack Testing:
Pollutant: Particulate Matter (TSP)
Stack Test to be Completed by (date): October 18, 2001
Test Method: Iowa Compliance Sampling Manual
Authority for Requirement: 567 IAC 22.108(3)
The higher of the results for emissions from the compliance stack testing of emission
points 1.AG1 and 1.AG2 will be used to calculate actual emissions for this source until
such time as more recent data becomes available. If the source test does not demonstrate
compliance this permit will be reopened to add a compliance plan and operation and
maintenance requirements.
The owner of this equipment or the owner's authorized agent shall provide written notice
to the Director, not less than 30 days before a required stack test or performance
evaluation of a continuous emission monitor. Results of the test shall be submitted in
writing to the Director in the form of a comprehensive report within 6 weeks of the
completion of the testing. 567 IAC 25.1(7)
Opacity Monitoring:
The facility shall observe the opacity weekly during a period when the emission unit
associated with this emission point is at or near full capacity and record the reading
indicating if visible emissions were observed. The records shall be maintained for five
years. If weather conditions prevent the observer from conducting an opacity
observation, the observer shall note such conditions on the data observation sheet. At
least three attempts shall be made to retake opacity readings at approximately 2-hour
intervals throughout the day. If all observation attempts for a week have been
unsuccessful due to weather, an observation shall be made the next operating day where
weather permits.
Maintain a written record of the observation and any action resulting from the
observation.
31
-------
Agency Approved Operation & Maintenance Plan Required? Yes ~ No Kl
Facility Maintained Operation & Maintenance Plan Required? Yes Kl NoQ
Facility operation and maintenance plans must be sufficient to yield reliable data from
the relevant time period that are representative of the source's compliance with the
applicable requirements.
Facility operation and maintenance plans are to be developed by the facility within six
(6) months of the issuance date of this permit and the data pertaining to the plan
maintained on site for at least 5 years. The plan and associated recordkeeping provides
documentation of this facility's implementation of its obligation to operate according to
good air pollution control practice.
Good air pollution control practice is achieved by adoption of quality control standards
in the operation and maintenance procedures for air pollution control that are
comparable to industry quality control standards for the production processes associated
with this emission point.
Authority for Requirement: 567 IAC 22.108(3)"b"
32
-------
Emission Point ID Number: l.AH
Associated Equipment
Associated Emission Unit ID Numbers (if multiple units vent thru this EP):
1.AH1
Applicable Requirements
(If more than one emission unit vents through this emission point subdivide the applicable requirements by emission
unit.)
Emission Unit vented through this Emission Point: 1.AH1
Emission Unit Description: Production Engine Testing Unit
Raw Material/Fuel: #2 Diesel Fuel and Gasoline
Rated Capacity: 49.1 gal./hr.
Emission Limits (lb./hr. gr./dscf. lb./MMBtu. % opacity, etc.):
The emissions from this emission point shall not exceed the following specified levels.
Pollutant: Opacity
Emission Limit(s): 40 %
Authority for Requirement: 567 IAC 23.3(2)"d"
Pollutant:
Emission Limits:
Authority for Requirement:
Particulate Matter (TSP)
0.1 gr./dscf
567 IAC 23.3(2)"a"
Pollutant: Sulfur Dioxide (SO2)
Emission Limits: 2.5 lb./MMBtu
Authority for Requirement: 567 IAC 23.3(3)"b"
Pollutant: Nitrogen Oxides (NOx)
Emission Limit(s): See Facility-Wide Conditions
Authority for Requirement: Iowa DNR Construction Permit 97-A-299-S2
Pollutant: Volatile Organic Compounds (VOC)
Emission Limit: See Facility-Wide Conditions
Authority for Requirement: Iowa DNR Construction Permit 97-A-299-S2
33
-------
Operational Limits & Requirements:
The owner/operator of this equipment shall comply with the following operational limits
and requirements.
Process Throughput:
A. The sulfur content of any diesel fuel used in this source shall not exceed 0.4% by
weight.
Reporting & Recordkeeping: See Facility-Wide Emission and Operational Limits
Authority for Requirement: Iowa DNR Construction Permit 97-A-299-S2
Compliance Plan:
The owner/operator of this equipment shall comply with the following applicable
requirements.
This point is in compliance with all applicable requirements and shall continue to comply
with all such requirements. For those applicable requirements which will become
effective during the permit term, this source will comply with such requirements in a
timely manner.
Periodic Monitoring Requirements:
The owner/operator of this equipment shall comply with the following periodic
monitoring requirements.
Agency Approved Operation & Maintenance Plan Required? Yes ~ No Kl
Facility Maintained Operation & Maintenance Plan Required? Yes ~ No Kl
Authority for Requirement: 567 IAC 22.108(3)"b"
34
-------
Emission Point ID Number: l.AJ
Associated Equipment
Associated Emission Unit ID Numbers (if multiple units vent thru this EP):
l.AJ
Applicable Requirements
(If more than one emission unit vents through this emission point subdivide the applicable requirements by emission
unit.)
Emission Unit vented through this Emission Point: 1.AJ
Emission Unit Description: Production Engine Testing Unit
Raw Material/Fuel: #2 Diesel Fuel and Gasoline
Rated Capacity: 49.1 gal./hr.
Emission Limits (lb./hr. gr./dscf. lb./MMBtu. % opacity, etc.):
The emissions from this emission point shall not exceed the following specified levels.
Pollutant: Opacity
Emission Limit(s): 40 %
Authority for Requirement: 567 IAC 23.3(2)"d"
Pollutant:
Emission Limits:
Authority for Requirement:
Particulate Matter (TSP)
0.1 gr./dscf
567 IAC 23.3(2)"a"
Pollutant: Sulfur Dioxide (SO2)
Emission Limits: 2.5 lb./MMBtu
Authority for Requirement: 567 IAC 23.3(3)"b"
Pollutant: Nitrogen Oxides (NOx)
Emission Limit(s): See Facility-Wide Conditions
Authority for Requirement: Iowa DNR Construction Permit 97-A-299-S2
Pollutant: Volatile Organic Compounds (VOC)
Emission Limit: See Facility-Wide Conditions
Authority for Requirement: Iowa DNR Construction Permit 97-A-299-S2
35
-------
Operational Limits & Requirements:
The owner/operator of this equipment shall comply with the following operational limits
and requirements.
Process Throughput:
A. The sulfur content of any diesel fuel used in this source shall not exceed 0.4% by
weight.
Reporting & Recordkeeping: See Facility-Wide Emission and Operational Limits
Authority for Requirement: Iowa DNR Construction Permit 97-A-299-S2
Compliance Plan:
The owner/operator of this equipment shall comply with the following applicable
requirements.
This point is in compliance with all applicable requirements and shall continue to comply
with all such requirements. For those applicable requirements which will become
effective during the permit term, this source will comply with such requirements in a
timely manner.
Periodic Monitoring Requirements:
The owner/operator of this equipment shall comply with the following periodic
monitoring requirements.
Agency Approved Operation & Maintenance Plan Required? Yes ~ No Kl
Facility Maintained Operation & Maintenance Plan Required? Yes ~ No Kl
Authority for Requirement: 567 IAC 22.108(3)"b"
36
-------
Emission Point ID Number: l.AP
Associated Equipment
Associated Emission Unit ID Numbers (if multiple units vent thru this EP):
l.AP
Applicable Requirements
(If more than one emission unit vents through this emission point subdivide the applicable requirements by emission
unit.)
Emission Unit vented through this Emission Point: 1.AP
Emission Unit Description: Paint Kitchen
Raw Material/Fuel: Paints, Primers, and Solvents
Rated Capacity: 3 Barrels
Emission Limits (lb./hr. gr./dscf. lb./MMBtu. % opacity, etc.):
The emissions from this emission point shall not exceed the following specified levels.
Pollutant: Volatile Organic Compounds (VOC)
Emission Limit: See Facility-Wide Conditions
Authority for Requirement: Iowa DNR Construction Permit 98-A-089-S1
Compliance Plan:
The owner/operator of this equipment shall comply with the following applicable
requirements.
This point is in compliance with all applicable requirements and shall continue to comply
with all such requirements. For those applicable requirements which will become
effective during the permit term, this source will comply with such requirements in a
timely manner.
Additional Requirements:
This emission point shall conform to the following conditions.
The source is to be connected to the stack of the following detailed description.
Stack Height (feet): 41
Stack Diameter (inches): 15
Stack Exhaust Flow Rate (acfm): .... 3,500
Stack Temperature (°F): 70
Vertical, Unobstructed Discharge Required: Yes ^ No ~
Authority for Requirement: Iowa DNR Construction Permit 98-A-089-S1
37
-------
Periodic Monitoring Requirements:
The owner/operator of this equipment shall comply with the following periodic
monitoring requirements.
Agency Approved Operation & Maintenance Plan Required? Yes ~ No Kl
Facility Maintained Operation & Maintenance Plan Required? Yes ~ No Kl
Authority for Requirement: 567 IAC 22.108(3)"b"
38
-------
Emission Point ID Number: l.AQ
Associated Equipment
Associated Emission Unit ID Numbers (if multiple units vent thru this EP):
1.AQ1, 1.AQ2
Applicable Requirements
(If more than one emission unit vents through this emission point subdivide the applicable requirements by emission
unit.)
Emission Unit vented through this Emission Point: 1.AQ1
Emission Unit Description: Paint Kitchen
Raw Material/Fuel: Paints, Primers, and Solvents
Rated Capacity: 3 Barrels
Emission Unit vented through this Emission Point: 1.AQ2
Emission Unit Description: Paint Kitchen
Raw Material/Fuel: Paints, Primers, and Solvents
Rated Capacity: 3 Barrels
Emission Limits (lb./hr. gr./dscf. lb./MMBtu. % opacity, etc.):
The emissions from this emission point shall not exceed the following specified levels.
Pollutant: Volatile Organic Compounds (VOC)
Emission Limit: See Facility-Wide Conditions
Authority for Requirement: Iowa DNR Construction Permit 98-A-090-S1
Compliance Plan:
The owner/operator of this equipment shall comply with the following applicable
requirements.
This point is in compliance with all applicable requirements and shall continue to comply
with all such requirements. For those applicable requirements which will become
effective during the permit term, this source will comply with such requirements in a
timely manner.
Additional Requirements:
This emission point shall conform to the following conditions.
The source is to be connected to the stack of the following detailed description.
Stack Height (feet): 41
Stack Diameter (inches): 20
Stack Exhaust Flow Rate (acfm): .... 7,000
Stack Temperature (°F): 70
Vertical, Unobstructed Discharge Required: Yes ^ No ~
Authority for Requirement: Iowa DNR Construction Permit 98-A-090-S1
39
-------
Periodic Monitoring Requirements:
The owner/operator of this equipment shall comply with the following periodic
monitoring requirements.
Agency Approved Operation & Maintenance Plan Required? Yes ~ No Kl
Facility Maintained Operation & Maintenance Plan Required? Yes ~ No Kl
Authority for Requirement: 567 IAC 22.108(3)"b"
40
-------
Emission Point ID Number: l.AR
Associated Equipment
Associated Emission Unit ID Numbers (if multiple units vent thru this EP):
l.AR
Applicable Requirements
(If more than one emission unit vents through this emission point subdivide the applicable requirements by emission
unit.)
Emission Unit vented through this Emission Point: 1.AR
Emission Unit Description: Production Engine Testing Unit
Raw Material/Fuel: #2 Diesel Fuel and Gasoline
Rated Capacity: 60.6 gal./hr.
Emission Limits (lb./hr. gr./dscf. lb./MMBtu. % opacity, etc.):
The emissions from this emission point shall not exceed the following specified levels.
Pollutant: Opacity
Emission Limit(s): 40 %
Authority for Requirement: 567 IAC 23.3(2)"d"
Pollutant:
Emission Limits:
Authority for Requirement:
Particulate Matter (TSP)
0.1 gr./dscf
567 IAC 23.3(2)"a"
Pollutant: Sulfur Dioxide (SO2)
Emission Limits: 2.5 lb./MMBtu
Authority for Requirement: 567 IAC 23.3(3)"b"
Pollutant: Nitrogen Oxides (NOx)
Emission Limit(s): See Facility-Wide Conditions
Authority for Requirement: Iowa DNR Construction Permit 97-A-299-S2
Pollutant: Volatile Organic Compounds (VOC)
Emission Limit: See Facility-Wide Conditions
Authority for Requirement: Iowa DNR Construction Permit 97-A-299-S2
41
-------
Operational Limits & Requirements:
The owner/operator of this equipment shall comply with the following operational limits
and requirements.
Process Throughput:
A. The sulfur content of any diesel fuel used in this source shall not exceed 0.4% by
weight.
Reporting & Recordkeeping: See Facility-Wide Emission and Operational Limits
Authority for Requirement: Iowa DNR Construction Permit 97-A-299-S2
Compliance Plan:
The owner/operator of this equipment shall comply with the following applicable
requirements.
This point is in compliance with all applicable requirements and shall continue to comply
with all such requirements. For those applicable requirements which will become
effective during the permit term, this source will comply with such requirements in a
timely manner.
Periodic Monitoring Requirements:
The owner/operator of this equipment shall comply with the following periodic
monitoring requirements.
Agency Approved Operation & Maintenance Plan Required? Yes ~ No Kl
Facility Maintained Operation & Maintenance Plan Required? Yes ~ No Kl
Authority for Requirement: 567 IAC 22.108(3)"b"
42
-------
Emission Point ID Number: l.AS
Associated Equipment
Associated Emission Unit ID Numbers (if multiple units vent thru this EP):
l.AS
Applicable Requirements
(If more than one emission unit vents through this emission point subdivide the applicable requirements by emission
unit.)
Emission Unit vented through this Emission Point: 1 .AS
Emission Unit Description: Production Engine Testing Unit
Raw Material/Fuel: #2 Diesel Fuel and Gasoline
Rated Capacity: 60.6 gal./hr.
Emission Limits (lb./hr. gr./dscf. lb./MMBtu. % opacity, etc.):
The emissions from this emission point shall not exceed the following specified levels.
Pollutant: Opacity
Emission Limit(s): 40 %
Authority for Requirement: 567 IAC 23.3(2)"d"
Pollutant:
Emission Limits:
Authority for Requirement:
Particulate Matter (TSP)
0.1 gr./dscf
567 IAC 23.3(2)"a"
Pollutant: Sulfur Dioxide (SO2)
Emission Limits: 2.5 lb./MMBtu
Authority for Requirement: 567 IAC 23.3(3)"b"
Pollutant: Nitrogen Oxides (NOx)
Emission Limit(s): See Facility-Wide Conditions
Authority for Requirement: Iowa DNR Construction Permit 97-A-299-S2
Pollutant: Volatile Organic Compounds (VOC)
Emission Limit: See Facility-Wide Conditions
Authority for Requirement: Iowa DNR Construction Permit 97-A-299-S2
43
-------
Operational Limits & Requirements:
The owner/operator of this equipment shall comply with the following operational limits
and requirements.
Process Throughput:
A. The sulfur content of any diesel fuel used in this source shall not exceed 0.4% by
weight.
Reporting & Recordkeeping: See Facility-Wide Emission and Operational Limits
Authority for Requirement: Iowa DNR Construction Permit 97-A-299-S2
Compliance Plan:
The owner/operator of this equipment shall comply with the following applicable
requirements.
This point is in compliance with all applicable requirements and shall continue to comply
with all such requirements. For those applicable requirements which will become
effective during the permit term, this source will comply with such requirements in a
timely manner.
Periodic Monitoring Requirements:
The owner/operator of this equipment shall comply with the following periodic
monitoring requirements.
Agency Approved Operation & Maintenance Plan Required? Yes ~ No Kl
Facility Maintained Operation & Maintenance Plan Required? Yes ~ No Kl
Authority for Requirement: 567 IAC 22.108(3)"b"
44
-------
Emission Point ID Number: l.AT
Associated Equipment
Associated Emission Unit ID Numbers (if multiple units vent thru this EP):
l.AT
Applicable Requirements
(If more than one emission unit vents through this emission point subdivide the applicable requirements by emission
unit.)
Emission Unit vented through this Emission Point: 1 .AT
Emission Unit Description: Production Engine Testing Unit
Raw Material/Fuel: #2 Diesel Fuel and Gasoline
Rated Capacity: 60.6 gal./hr.
Emission Limits (lb./hr. gr./dscf. lb./MMBtu. % opacity, etc.):
The emissions from this emission point shall not exceed the following specified levels.
Pollutant: Opacity
Emission Limit(s): 40 %
Authority for Requirement: 567 IAC 23.3(2)"d"
Pollutant:
Emission Limits:
Authority for Requirement:
Particulate Matter (TSP)
0.1 gr./dscf
567 IAC 23.3(2)"a"
Pollutant: Sulfur Dioxide (SO2)
Emission Limits: 2.5 lb./MMBtu
Authority for Requirement: 567 IAC 23.3(3)"b"
Pollutant: Nitrogen Oxides (NOx)
Emission Limit(s): See Facility-Wide Conditions
Authority for Requirement: Iowa DNR Construction Permit 97-A-299-S2
Pollutant: Volatile Organic Compounds (VOC)
Emission Limit: See Facility-Wide Conditions
Authority for Requirement: Iowa DNR Construction Permit 97-A-299-S2
45
-------
Operational Limits & Requirements:
The owner/operator of this equipment shall comply with the following operational limits
and requirements.
Process Throughput:
A. The sulfur content of any diesel fuel used in this source shall not exceed 0.4% by
weight.
Reporting & Recordkeeping: See Facility-Wide Emission and Operational Limits
Authority for Requirement: Iowa DNR Construction Permit 97-A-299-S2
Compliance Plan:
The owner/operator of this equipment shall comply with the following applicable
requirements.
This point is in compliance with all applicable requirements and shall continue to comply
with all such requirements. For those applicable requirements which will become
effective during the permit term, this source will comply with such requirements in a
timely manner.
Periodic Monitoring Requirements:
The owner/operator of this equipment shall comply with the following periodic
monitoring requirements.
Agency Approved Operation & Maintenance Plan Required? Yes ~ No Kl
Facility Maintained Operation & Maintenance Plan Required? Yes ~ No Kl
Authority for Requirement: 567 IAC 22.108(3)"b"
46
-------
Emission Point ID Number: l.AU
Associated Equipment
Associated Emission Unit ID Numbers (if multiple units vent thru this EP):
l.AU
Applicable Requirements
(If more than one emission unit vents through this emission point subdivide the applicable requirements by emission
unit.)
Emission Unit vented through this Emission Point: 1.AU
Emission Unit Description: Production Engine Testing Unit
Raw Material/Fuel: #2 Diesel Fuel and Gasoline
Rated Capacity: 50.5 gal./hr.
Emission Limits (lb./hr. gr./dscf. lb./MMBtu. % opacity, etc.):
The emissions from this emission point shall not exceed the following specified levels.
Pollutant: Opacity
Emission Limits: 40%
Indicator Opacity: 25%(1)
(1) If visible emissions are observed that exceed the indicator opacity other than startup,
shutdown or malfunction, a stack test may be required to demonstrate compliance with
the particulate standard.
Authority for Requirement: Iowa DNR Construction Permit 97-A-l 107-S3
567 IAC 23.3(2)"d"
Pollutant: Particulate Matter (TSP)
Emission Limits: 0.1 gr./dscf
Authority for Requirement: Iowa DNR Construction Permit 97-A-l 107-S3
567 IAC 23.3(2)"a"
Pollutant: Sulfur Dioxide (SO2)
Emission Limits: 2.5 lb./MMBtu
Authority for Requirement: Iowa DNR Construction Permit 97-A-l 107-S3
567 IAC 23.3(3)"b"
Pollutant: Nitrogen Oxides (NOx)
Emission Limit(s): See Facility-Wide Conditions
Authority for Requirement: Iowa DNR Construction Permit 97-A-l 107-S3
Pollutant: Volatile Organic Compounds (VOC)
Emission Limit: See Facility-Wide Conditions
Authority for Requirement: Iowa DNR Construction Permit 97-A-l 107-S3
47
-------
Operational Limits & Requirements:
The owner/operator of this equipment shall comply with the following operational limits
and requirements.
Process Throughput:
A. The sulfur content of any diesel fuel used in this source shall not exceed 0.4% by
weight.
Reporting & Recordkeeping: See Facility-Wide Emission and Operational Limits
Authority for Requirement: Iowa DNR Construction Permit 97-A-l 107-S3
Compliance Plan:
The owner/operator of this equipment shall comply with the following applicable
requirements.
This point is in compliance with all applicable requirements and shall continue to comply
with all such requirements. For those applicable requirements which will become
effective during the permit term, this source will comply with such requirements in a
timely manner.
Additional Requirements:
This emission point shall conform to the following conditions.
The source is to be connected to the stack of the following detailed description.
Stack Height (feet): 38
Stack Diameter (inches): 12
Stack Exhaust Flow Rate (acfm): .... 5,750
Stack Temperature (°F): 759
Vertical, Unobstructed Discharge Required: Yes ^ No ~
Authority for Requirement: Iowa DNR Construction Permit 97-A-1107-S3
Periodic Monitoring Requirements:
The owner/operator of this equipment shall comply with the following periodic
monitoring requirements.
Opacity Monitoring:
The facility shall observe the opacity weekly during a period when the emission unit
associated with this emission point is at or near full capacity and record the reading
indicating if visible emissions were observed. The records shall be maintained for five
years. If weather conditions prevent the observer from conducting an opacity
observation, the observer shall note such conditions on the data observation sheet. At
least three attempts shall be made to retake opacity readings at approximately 2-hour
intervals throughout the day. If all observation attempts for a week have been
unsuccessful due to weather, an observation shall be made the next operating day where
weather permits.
Maintain a written record of the observation and any action resulting from the
observation.
48
-------
Agency Approved Operation & Maintenance Plan Required? Yes ~ No Kl
Facility Maintained Operation & Maintenance Plan Required? Yes ~ No Kl
Authority for Requirement: 567 IAC 22.108(3)"b"
49
-------
Emission Point ID Number: l.C
Associated Equipment
Associated Emission Unit ID Numbers (if multiple units vent thru this EP):
l.C
Applicable Requirements
(If more than one emission unit vents through this emission point subdivide the applicable requirements by emission
unit.)
Emission Unit vented through this Emission Point: l.C
Emission Unit Description: Non-Production Heating Unit
Raw Material/Fuel: Propane (LPG) or Natural Gas
Rated Capacity: 2.5 MMBtu/hr.
Emission Limits (lb./hr. gr./dscf. lb./MMBtu. % opacity, etc.):
The emissions from this emission point shall not exceed the following specified levels.
Pollutant: Opacity
Emission Limit(s): 40 %
Authority for Requirement: 567 IAC 23.3(2)"d"
Pollutant: Particulate Matter (TSP)
Emission Limit(s): 15.3 lb./MMCF of LPG or Natural Gas
Authority for Requirement: Part 7a. of State of Iowa, ex rel., Iowa DNR vs. Vermeer
Manufacturing Company, 99AG23542
District Court, Marion County, Law No. LACV087889
Pollutant: Particulate Matter (TSP)
Emission Limits: 0.8 lb./MMBtu
Authority for Requirement: 567 IAC 23.3(2)"b"
Pollutant: Sulfur Dioxide (SO2)
Emission Limits: 500 ppmv
Authority for Requirement: 567 IAC 23.3(3)"e"
Pollutant: Nitrogen Oxides (NOx)
Emission Limit(s): See Facility-Wide Conditions
Authority for Requirement: Iowa DNR Construction Permit 98-A-003-S1
Pollutant: Volatile Organic Compounds (VOC)
Emission Limit: See Facility-Wide Conditions
Authority for Requirement: Iowa DNR Construction Permit 98-A-003-S1
50
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Operational Limits & Requirements:
The owner/operator of this equipment shall comply with the following operational limits
and requirements.
Process throughput:
A. The sulfur content of natural gas or LPG combusted by this source is not to
exceed 123 ppm by weight.
Reporting & Recordkeeping: See Facility-Wide Operational Limits
Authority for Requirement: Part 7b. of State of Iowa, ex rel., Iowa DNR vs. Vermeer
Manufacturing Company, 99AG23542
District Court, Marion County, Law No. LACV087889
Compliance Plan:
The owner/operator of this equipment shall comply with the following applicable
requirements.
This point is in compliance with all applicable requirements and shall continue to comply
with all such requirements. For those applicable requirements which will become
effective during the permit term, this source will comply with such requirements in a
timely manner.
Periodic Monitoring Requirements:
The owner/operator of this equipment shall comply with the following periodic
monitoring requirements.
Agency Approved Operation & Maintenance Plan Required? Yes ~ No IXI
Facility Maintained Operation & Maintenance Plan Required? Yes ~ No Kl
Authority for Requirement: 567 IAC 22.108(3)"b"
51
-------
Emission Point ID Number: l.D
Associated Equipment
Associated Emission Unit ID Numbers (if multiple units vent thru this EP):
l.D
Applicable Requirements
(If more than one emission unit vents through this emission point subdivide the applicable requirements by emission
unit.)
Emission Unit vented through this Emission Point: 1 .D
Emission Unit Description: Hot Water Heater
Raw Material/Fuel: Propane (LPG) or Natural Gas
Rated Capacity: 0.28 MMBtu/hr.
Emission Limits (lb./hr. gr./dscf. lb./MMBtu. % opacity, etc.):
The emissions from this emission point shall not exceed the following specified levels.
Pollutant: Opacity
Emission Limit(s): 40 %
Authority for Requirement: 567 IAC 23.3(2)"d"
Pollutant: Particulate Matter (TSP)
Emission Limit(s): 15.3 lb./MMCF of LPG or Natural Gas
Authority for Requirement: Part 7a. of State of Iowa, ex rel., Iowa DNR vs. Vermeer
Manufacturing Company, 99AG23542
District Court, Marion County, Law No. LACV087889
Pollutant: Particulate Matter (TSP)
Emission Limits: 0.8 lb./MMBtu
Authority for Requirement: 567 IAC 23.3(2)"b"
Pollutant: Sulfur Dioxide (SO2)
Emission Limits: 500 ppmv
Authority for Requirement: 567 IAC 23.3(3)"e"
Pollutant: Nitrogen Oxides (NOx)
Emission Limit(s): See Facility-Wide Conditions
Authority for Requirement: Iowa DNR Construction Permit 98-A-003-S1
Pollutant: Volatile Organic Compounds (VOC)
Emission Limit: See Facility-Wide Conditions
Authority for Requirement: Iowa DNR Construction Permit 98-A-003-S1
52
-------
Operational Limits & Requirements:
The owner/operator of this equipment shall comply with the following operational limits
and requirements.
Process throughput:
A. The sulfur content of natural gas or LPG combusted by this source is not to
exceed 123 ppm by weight.
Reporting & Recordkeeping: See Facility-Wide Operational Limits
Authority for Requirement: Part 7b. of State of Iowa, ex rel., Iowa DNR vs. Vermeer
Manufacturing Company, 99AG23542
District Court, Marion County, Law No. LACV087889
Compliance Plan:
The owner/operator of this equipment shall comply with the following applicable
requirements.
This point is in compliance with all applicable requirements and shall continue to comply
with all such requirements. For those applicable requirements which will become
effective during the permit term, this source will comply with such requirements in a
timely manner.
Periodic Monitoring Requirements:
The owner/operator of this equipment shall comply with the following periodic
monitoring requirements.
Agency Approved Operation & Maintenance Plan Required? Yes ~ No IXI
Facility Maintained Operation & Maintenance Plan Required? Yes ~ No Kl
Authority for Requirement: 567 IAC 22.108(3)"b"
53
-------
Emission Point ID Number: 1.FLAME 1
Associated Equipment
Associated Emission Unit ID Numbers (if multiple units vent thru this EP): 1 .FLAME1
Emissions Control Equipment ID Number: 1 .FLAME1
Emissions Control Equipment Description: Water Table
Applicable Requirements
(If more than one emission unit vents through this emission point subdivide the applicable requirements by emission
unit.)
Emission Unit vented through this Emission Point: 1 .FLAME1 (Fugitive)
Emission Unit Description: Single Cutting Head Oxyacetylene
Torch Unit
Raw Material/Fuel: Sheet Steel
Rated Capacity: 660 inches of metal cut/hr.
Emission Limits (lb./hr. gr./dscf. lb./MMBtu. % opacity, etc.):
The emissions from this emission point shall not exceed the following specified levels.
Pollutant: Fugitive Dust
Emission Limit: No person shall allow, cause or permit any materials to be handled,
transported or stored; or a building, its appurtenances or a construction haul road to
be used, constructed, altered , repaired or demolished, without taking reasonable
precautions to prevent a nuisance. All persons shall take reasonable precautions to
prevent the discharge of visible emissions of fugitive dusts beyond the lot line of the
property on which the emissions originate.
Authority for Requirement: 567 IAC 23.3(2)"c"
Compliance Plan:
The owner/operator of this equipment shall comply with the following applicable
requirements.
This point is in compliance with all applicable requirements and shall continue to comply
with all such requirements. For those applicable requirements which will become
effective during the permit term, this source will comply with such requirements in a
timely manner.
Periodic Monitoring Requirements:
The owner/operator of this equipment shall comply with the following periodic
monitoring requirements.
Agency Approved Operation & Maintenance Plan Required? Yes ~ No Kl
Facility Maintained Operation & Maintenance Plan Required? Yes ~ No Kl
Authority for Requirement: 567 IAC 22.108(3)"b"
54
-------
Emission Point ID Number: 1.FLAME2
Associated Equipment
Associated Emission Unit ID Numbers (if multiple units vent thru this EP): 1 .FLAME2
Emissions Control Equipment ID Number: 1 .FLAME2
Emissions Control Equipment Description: Water Table
Applicable Requirements
(If more than one emission unit vents through this emission point subdivide the applicable requirements by emission
unit.)
Emission Unit vented through this Emission Point: 1 .FLAME2 (Fugitive)
Emission Unit Description: Single Cutting Head Oxyacetylene
Torch Unit
Raw Material/Fuel: Sheet Steel
Rated Capacity: 660 inches of metal cut/hr.
Emission Limits (lb./hr. gr./dscf. lb./MMBtu. % opacity, etc.):
The emissions from this emission point shall not exceed the following specified levels.
Pollutant: Fugitive Dust
Emission Limit: No person shall allow, cause or permit any materials to be handled,
transported or stored; or a building, its appurtenances or a construction haul road to
be used, constructed, altered , repaired or demolished, without taking reasonable
precautions to prevent a nuisance. All persons shall take reasonable precautions to
prevent the discharge of visible emissions of fugitive dusts beyond the lot line of the
property on which the emissions originate.
Authority for Requirement: 567 IAC 23.3(2)"c"
Compliance Plan:
The owner/operator of this equipment shall comply with the following applicable
requirements.
This point is in compliance with all applicable requirements and shall continue to comply
with all such requirements. For those applicable requirements which will become
effective during the permit term, this source will comply with such requirements in a
timely manner.
Periodic Monitoring Requirements:
The owner/operator of this equipment shall comply with the following periodic
monitoring requirements.
Agency Approved Operation & Maintenance Plan Required? Yes ~ No Kl
Facility Maintained Operation & Maintenance Plan Required? Yes ~ No Kl
Authority for Requirement: 567 IAC 22.108(3)"b"
55
-------
Emission Point ID Number: 1. J
Associated Equipment
Associated Emission Unit ID Numbers (if multiple units vent thru this EP):
l.J
Applicable Requirements
(If more than one emission unit vents through this emission point subdivide the applicable requirements by emission
unit.)
Emission Unit vented through this Emission Point: 1 .J
Emission Unit Description: Paint Oven
Raw Material/Fuel: Natural Gas
Rated Capacity: 2.0 MMBtu/hr.
Emission Limits (lb./hr. gr./dscf. lb./MMBtu. % opacity, etc.):
The emissions from this emission point shall not exceed the following specified levels.
Pollutant: Opacity
Emission Limits: 40%
Indicator Opacity: (1)
(1) If visible emissions are observed other than startup, shutdown or malfunction, a stack
test may be required to demonstrate compliance with the particulate standard.
Authority for Requirement: Iowa DNR Construction Permit 98-A-094-S1
567 IAC23.3(2)"d"
Pollutant: Particulate Matter (TSP)
Emission Limit(s): 15.3 lb./MMCF of LPG or Natural Gas
Authority for Requirement: Part 7a. of State of Iowa, ex rel., Iowa DNR vs. Vermeer
Manufacturing Company, 99AG23542
District Court, Marion County, Law No. LACV087889
Pollutant: Particulate Matter (TSP)
Emission Limit(s): 0.01 gr./dscf
Authority for Requirement: Iowa DNR Construction Permit 98-A-094-S1
567 IAC 23.4(13)
Pollutant: Sulfur Dioxide (SO2)
Emission Limits: 500 ppmv
Authority for Requirement: 567 IAC 23.3(3)"e"
Pollutant: Nitrogen Oxides (NOx)
Emission Limit(s): See Facility-Wide Conditions
Authority for Requirement: Iowa DNR Construction Permit 98-A-094-S1
56
-------
Emission Limits (continued):
Pollutant: Volatile Organic Compounds (VOC)
Emission Limit: See Facility-Wide Conditions
Authority for Requirement: Iowa DNR Construction Permit 98-A-094-S1
Operational Limits & Requirements:
The owner/operator of this equipment shall comply with the following operational limits
and requirements.
Process throughput:
A. This oven shall be fired by natural gas or propane only.
Reporting & Recordkeeping: See Facility-Wide Emission Limits
Authority for Requirement: Iowa DNR Construction Permit 98-A-094-S1
Process throughput:
A. The sulfur content of natural gas or LPG combusted by this source is not to
exceed 123 ppm by weight.
Reporting & Recordkeeping: See Facility-Wide Operational Limits
Authority for Requirement: Part 7b. of State of Iowa, ex rel., Iowa DNR vs. Vermeer
Manufacturing Company, 99AG23542
District Court, Marion County, Law No. LACV087889
Compliance Plan:
The owner/operator of this equipment shall comply with the following applicable
requirements.
This point is in compliance with all applicable requirements and shall continue to comply
with all such requirements. For those applicable requirements which will become
effective during the permit term, this source will comply with such requirements in a
timely manner.
Additional Requirements:
This emission point shall conform to the following conditions.
The source is to be connected to the stack of the following detailed description.
Stack Height (feet): 35
Stack Diameter (inches): 12
Stack Exhaust Flow Rate (acfm): .... 1153
Stack Temperature (°F): 106
Vertical, Unobstructed Discharge Required: Yes ^ No ~
Authority for Requirement: Iowa DNR Construction Permit 98-A-094-S1
57
-------
Periodic Monitoring Requirements:
The owner/operator of this equipment shall comply with the following periodic
monitoring requirements.
Opacity Monitoring:
Opacity shall be observed once a week during a period when the emission unit
associated with this emission point is at or near full capacity and record if visible
emissions were present.
Agency Approved Operation & Maintenance Plan Required? Yes ~ No Kl
Facility Maintained Operation & Maintenance Plan Required? Yes ~ No Kl
Authority for Requirement: 567 IAC 22.108(3)"b"
58
-------
Emission Point ID Number: l.K
Associated Equipment
Associated Emission Unit ID Numbers (if multiple units vent thru this EP): 1 .K
Emissions Control Equipment ID Number: 1 K
Emissions Control Equipment Description: Paper Filter
Applicable Requirements
(If more than one emission unit vents through this emission point subdivide the applicable requirements by emission
unit.)
Emission Unit vented through this Emission Point: 1 .K
Emission Unit Description: Parts Paint Booth
Raw Material/Fuel: Paints, Primers, and Solvents
Rated Capacity: 15 gal./hr.
Emission Limits (lb./hr. gr./dscf. lb./MMBtu. % opacity, etc.):
The emissions from this emission point shall not exceed the following specified levels.
Pollutant: Opacity
Emission Limits: 40%
Indicator Opacity: (1)
(1) If visible emissions are observed other than startup, shutdown or malfunction, a stack
test may be required to demonstrate compliance with the particulate standard.
Authority for Requirement: Iowa DNR Construction Permit 97-A-974-S3
567 IAC23.3(2)"d"
Pollutant: Particulate Matter (TSP)
Emission Limit(s): 0.01 gr./dscf
Authority for Requirement: Iowa DNR Construction Permit 97-A-974-S3
567 IAC 23.4(13)
Pollutant: Volatile Organic Compounds (VOC)
Emission Limit: See Facility-Wide Conditions
Authority for Requirement: Iowa DNR Construction Permit 97-A-974-S3
59
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Operational Limits & Requirements:
The owner/operator of this equipment shall comply with the following operational limits
and requirements.
Supplemental Environmental Project:
Equipment parameters:
The emission unit associated with this emission point will maintain a Graco, multi-
color, precision mix system with two gun flush boxes, solvent meters, and solvent
valves. The system will be supplied with a microprocessor which will control
solvent, paint, and catalyst flow to a mixing tube adjacent to the emission unit and
record the cumulative amount of the exact volume or weight of paint, solvent, or
catalyst utilized in the emission unit. The system will be interlocked with the two
Graco gun flush boxes, and the guns will be interlocked with the fans of the paint
spray booth.
Authority for Requirement: Paragraph 3b. of State of Iowa, ex rel., Iowa DNR vs.
Vermeer Manufacturing Company, 99AG23542
District Court, Marion County, Law No. LACV087889
Operational term: This SEP will be maintained for the life of this permit.
Authority for Requirement: Paragraph 3i. of State of Iowa, ex rel., Iowa DNR vs.
Vermeer Manufacturing Company, 99AG23542
District Court, Marion County, Law No. LACV087889
Reporting & Record keeping:
Vermeer shall submit to the DNR an annual performance report covering the required
period of use and maintenance of this SEP documenting the actual use and
maintenance of this SEP. The report shall evaluate the performance of the SEP and
document the extent of VOC emissions reductions. Vermeer shall conduct
cumulative mass balance calculations to determine the actual effect measured against
the 1997 baseline of 122.94 tons of VOC emitted per year. The reports shall be
submitted on or before March 1, for the preceding calendar year, commencing on
March 1, 1999. For additional reporting and recordkeeping see the Facility-Wide
Conditions.
Authority for Requirement: Paragraph 3j. of State of Iowa, ex rel., Iowa DNR vs.
Vermeer Manufacturing Company, 99AG23542
District Court, Marion County, Law No. LACV087889
Iowa DNR Construction Permit 97-A-974-S3
Compliance Plan:
The owner/operator of this equipment shall comply with the following applicable
requirements.
This point is in compliance with all applicable requirements and shall continue to comply
with all such requirements. For those applicable requirements which will become
effective during the permit term, this source will comply with such requirements in a
timely manner.
60
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Additional Requirements:
This emission point shall conform to the following conditions.
The source is to be connected to the stack of the following detailed description.
Stack Height (feet): 42.1
Stack Diameter (inches): 34.0
Stack Exhaust Flow Rate (acfm): ....21,195
Stack Temperature (°F): 70
Vertical, Unobstructed Discharge Required: Yes ^ No ~
Authority for Requirement: Iowa DNR Construction Permit 97-A-974-S3
Periodic Monitoring Requirements:
The owner/operator of this equipment shall comply with the following periodic
monitoring requirements.
Stack Testing:
Pollutant: Particulate Matter (TSP)
Stack Test to be Completed by (date): October 18, 2001
Test Method: Iowa Compliance Sampling Manual
Authority for Requirement: 567 IAC 22.108(3)
This stack test will represent the compliance testing for emission points l.K, 2.H, 3.G,
and 5. J. In the event that a stack test of one of the other listed emission points is more
suitable it may be tested to fulfill the requirements. Suitability will be determined by the
Stack Test Observation Coordinator of the Air Quality Bureau Compliance Assistance
Section. The results of the compliance stack testing will be used to calculate actual
emissions for the listed sources until such time as more recent data becomes available. If
the source test does not demonstrate compliance this permit will be reopened to add a
compliance plan and operation and maintenance requirements.
The owner of this equipment or the owner's authorized agent shall provide written notice
to the Director, not less than 30 days before a required stack test or performance
evaluation of a continuous emission monitor. Results of the test shall be submitted in
writing to the Director in the form of a comprehensive report within 6 weeks of the
completion of the testing. 567 IAC 25.1(7)
61
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Periodic Monitoring Requirements (continued):
Opacity Monitoring:
The facility shall observe the opacity weekly during a period when the emission unit
associated with this emission point is at or near full capacity and record the reading
indicating if visible emissions were observed. The records shall be maintained for five
years. If weather conditions prevent the observer from conducting an opacity
observation, the observer shall note such conditions on the data observation sheet. At
least three attempts shall be made to retake opacity readings at approximately 2-hour
intervals throughout the day. If all observation attempts for a week have been
unsuccessful due to weather, an observation shall be made the next operating day where
weather permits.
Maintain a written record of the observation and any action resulting from the
observation.
Agency Approved Operation & Maintenance Plan Required? Yes ~ No Kl
Facility Maintained Operation & Maintenance Plan Required? Yes Kl NoQ
Facility operation and maintenance plans must be sufficient to yield reliable data from
the relevant time period that are representative of the source's compliance with the
applicable requirements.
Facility operation and maintenance plans are to be developed by the facility within six(6)
months of the issuance date of this permit and the data pertaining to the plan maintained
on site for at least 5 years. The plan and associated recordkeeping provides
documentation of this facility's implementation of its obligation to operate according to
good air pollution control practice.
Good air pollution control practice is achieved by adoption of quality control standards
in the operation and maintenance procedures for air pollution control that are
comparable to industry quality control standards for the production processes associated
with this emission point.
Authority for Requirement: 567 IAC 22.108(3)"b"
62
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Emission Point ID Number: l.O
Associated Equipment
Associated Emission Unit ID Numbers (if multiple units vent thru this EP):
1.0
Applicable Requirements
(If more than one emission unit vents through this emission point subdivide the applicable requirements by emission
unit.)
Emission Unit vented through this Emission Point: 1.0
Emission Unit Description: Non-Production Heating Unit
Raw Material/Fuel: Propane (LPG) or Natural Gas
Rated Capacity: 2.0 MMBtu/hr.
Emission Limits (lb./hr. gr./dscf. lb./MMBtu. % opacity, etc.):
The emissions from this emission point shall not exceed the following specified levels.
Pollutant: Opacity
Emission Limit(s): 40 %
Authority for Requirement: 567 IAC 23.3(2)"d"
Pollutant: Particulate Matter (TSP)
Emission Limit(s): 15.3 lb./MMCF of LPG or Natural Gas
Authority for Requirement: Part 7a. of State of Iowa, ex rel., Iowa DNR vs. Vermeer
Manufacturing Company, 99AG23542
District Court, Marion County, Law No. LACV087889
Pollutant: Particulate Matter (TSP)
Emission Limits: 0.8 lb./MMBtu
Authority for Requirement: 567 IAC 23.3(2)"b"
Pollutant: Sulfur Dioxide (SO2)
Emission Limits: 500 ppmv
Authority for Requirement: 567 IAC 23.3(3)"e"
Pollutant: Nitrogen Oxides (NOx)
Emission Limit(s): See Facility-Wide Conditions
Authority for Requirement: Iowa DNR Construction Permit 98-A-003-S1
Pollutant: Volatile Organic Compounds (VOC)
Emission Limit: See Facility-Wide Conditions
Authority for Requirement: Iowa DNR Construction Permit 98-A-003-S1
63
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Operational Limits & Requirements:
The owner/operator of this equipment shall comply with the following operational limits
and requirements.
Process throughput:
A. The sulfur content of natural gas or LPG combusted by this source is not to
exceed 123 ppm by weight.
Reporting & Recordkeeping: See Facility-Wide Operational Limits
Authority for Requirement: Part 7b. of State of Iowa, ex rel., Iowa DNR vs. Vermeer
Manufacturing Company, 99AG23542
District Court, Marion County, Law No. LACV087889
Compliance Plan:
The owner/operator of this equipment shall comply with the following applicable
requirements.
This point is in compliance with all applicable requirements and shall continue to comply
with all such requirements. For those applicable requirements which will become
effective during the permit term, this source will comply with such requirements in a
timely manner.
Periodic Monitoring Requirements:
The owner/operator of this equipment shall comply with the following periodic
monitoring requirements.
Agency Approved Operation & Maintenance Plan Required? Yes ~ No IXI
Facility Maintained Operation & Maintenance Plan Required? Yes ~ No Kl
Authority for Requirement: 567 IAC 22.108(3)"b"
64
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Emission Point ID Number: 1.PLASMA1
Associated Equipment
Associated Emission Unit ID Numbers (if multiple units vent thru this EP): 1 .PLASMA1
Applicable Requirements
(If more than one emission unit vents through this emission point subdivide the applicable requirements by emission
unit.)
Emission Unit vented through this Emission Point: 1 .PLASMA1 (Fugitive)
Emission Unit Description: Single Head Plasma Cutting
Machine
Raw Material/Fuel: Sheet Steel
Rated Capacity: 4,500 inches of metal cut/hr.
Emission Limits (lb./hr. gr./dscf. lb./MMBtu. % opacity, etc.):
The emissions from this emission point shall not exceed the following specified levels.
Pollutant: Fugitive Dust
Emission Limit: No person shall allow, cause or permit any materials to be handled,
transported or stored; or a building, its appurtenances or a construction haul road to
be used, constructed, altered , repaired or demolished, without taking reasonable
precautions to prevent a nuisance. All persons shall take reasonable precautions to
prevent the discharge of visible emissions of fugitive dusts beyond the lot line of the
property on which the emissions originate.
Authority for Requirement: 567 IAC 23.3(2)"c"
Compliance Plan:
The owner/operator of this equipment shall comply with the following applicable
requirements.
This point is in compliance with all applicable requirements and shall continue to comply
with all such requirements. For those applicable requirements which will become
effective during the permit term, this source will comply with such requirements in a
timely manner.
Periodic Monitoring Requirements:
The owner/operator of this equipment shall comply with the following periodic
monitoring requirements.
Agency Approved Operation & Maintenance Plan Required? Yes ~ No IXI
Facility Maintained Operation & Maintenance Plan Required? Yes ~ No Kl
Authority for Requirement: 567 IAC 22.108(3)"b"
65
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Emission Point ID Number: l.PRTWSH
Associated Equipment
Associated Emission Unit ID Numbers (if multiple units vent thru this EP): 1 .PRTWSH
Applicable Requirements
(If more than one emission unit vents through this emission point subdivide the applicable requirements by emission
unit.)
Emission Unit vented through this Emission Point: 1 .PRTWSH (Fugitive)
Emission Unit Description: Five (5) Safety Kleen Parts Washers
Raw Material/Fuel: Stoddard Solvent
Rated Capacity: 55 Gallons Solvent per Washer
Emission Limits (lb./hr. gr./dscf. lb./MMBtu. % opacity, etc.):
The emissions from this emission point shall not exceed the following specified levels.
Pollutant: Volatile Organic Compounds (VOC)
Emission Limit: See Facility-Wide Conditions
Authority for Requirement: Iowa DNR Construction Permit 98-A-003-S1
Compliance Plan:
The owner/operator of this equipment shall comply with the following applicable
requirements.
This point is in compliance with all applicable requirements and shall continue to comply
with all such requirements. For those applicable requirements which will become
effective during the permit term, this source will comply with such requirements in a
timely manner.
Periodic Monitoring Requirements:
The owner/operator of this equipment shall comply with the following periodic
monitoring requirements.
Agency Approved Operation & Maintenance Plan Required? Yes ~ No IEI
Facility Maintained Operation & Maintenance Plan Required? Yes ~ No Kl
Authority for Requirement: 567 IAC 22.108(3)"b"
66
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Emission Point ID Number: l.T
Associated Equipment
Associated Emission Unit ID Numbers (if multiple units vent thru this EP): l.T
Emissions Control Equipment ID Number: l.T-1
Emissions Control Equipment Description: Baghouse
Applicable Requirements
(If more than one emission unit vents through this emission point subdivide the applicable requirements by emission
unit.)
Emission Unit vented through this Emission Point: l.T
Emission Unit Description: Wheelabrator Shot Blast Booth
Raw Material/Fuel: Steel Parts
Rated Capacity: 40 lb./hr of Abrasive Shot
Emission Limits (lb./hr. gr./dscf. lb./MMBtu. % opacity, etc.):
The emissions from this emission point shall not exceed the following specified levels.
Pollutant: Opacity
Emission Limit(s): 40 %
Authority for Requirement: 567 IAC 23.3(2)"d"
Pollutant: Particulate Matter (TSP)
Emission Limit(s): 0.05 gr./dscf
Authority for Requirement: Iowa DNR Construction Permit 79-A-108
567 IAC 23.4(13)
Compliance Plan:
The owner/operator of this equipment shall comply with the following applicable
requirements.
This point is in compliance with all applicable requirements and shall continue to comply
with all such requirements. For those applicable requirements which will become
effective during the permit term, this source will comply with such requirements in a
timely manner.
Periodic Monitoring Requirements:
The owner/operator of this equipment shall comply with the following periodic
monitoring requirements.
Agency Approved Operation & Maintenance Plan Required? Yes ~ No Kl
Facility Maintained Operation & Maintenance Plan Required? Yes ~ No Kl
Authority for Requirement: 567 IAC 22.108(3)"b"
67
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Emission Point ID Number: 1.TORCH
Associated Equipment
Associated Emission Unit ID Numbers (if multiple units vent thru this EP): 1 .TORCH
Applicable Requirements
(If more than one emission unit vents through this emission point subdivide the applicable requirements by emission
unit.)
Emission Unit vented through this Emission Point: 1 .TORCH (Fugitive)
Emission Unit Description: Nine (9) Single Cutting Head
Oxyacetylene Torch Units
Raw Material/Fuel: Sheet Steel
Rated Capacity: 840 inches of metal cut/hr. per Head
Emission Limits (lb./hr. gr./dscf. lb./MMBtu. % opacity, etc.):
The emissions from this emission point shall not exceed the following specified levels.
Pollutant: Fugitive Dust
Emission Limit: No person shall allow, cause or permit any materials to be handled,
transported or stored; or a building, its appurtenances or a construction haul road to
be used, constructed, altered , repaired or demolished, without taking reasonable
precautions to prevent a nuisance. All persons shall take reasonable precautions to
prevent the discharge of visible emissions of fugitive dusts beyond the lot line of the
property on which the emissions originate.
Authority for Requirement: 567 IAC 23.3(2)"c"
Compliance Plan:
The owner/operator of this equipment shall comply with the following applicable
requirements.
This point is in compliance with all applicable requirements and shall continue to comply
with all such requirements. For those applicable requirements which will become
effective during the permit term, this source will comply with such requirements in a
timely manner.
Periodic Monitoring Requirements:
The owner/operator of this equipment shall comply with the following periodic
monitoring requirements.
Agency Approved Operation & Maintenance Plan Required? Yes ~ No IXI
Facility Maintained Operation & Maintenance Plan Required? Yes ~ No Kl
Authority for Requirement: 567 IAC 22.108(3)"b"
68
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Emission Point ID Number: l.U
Associated Equipment
Associated Emission Unit ID Numbers (if multiple units vent thru this EP):
l.U
Applicable Requirements
(If more than one emission unit vents through this emission point subdivide the applicable requirements by emission
unit.)
Emission Unit vented through this Emission Point: 1 .U
Emission Unit Description: Hot Water Heater
Raw Material/Fuel: Propane (LPG) or Natural Gas
Rated Capacity: 0.528 MMBtu/hr.
Emission Limits (lb./hr. gr./dscf. lb./MMBtu. % opacity, etc.):
The emissions from this emission point shall not exceed the following specified levels.
Pollutant: Opacity
Emission Limit(s): 40 %
Authority for Requirement: 567 IAC 23.3(2)"d"
Pollutant: Particulate Matter (TSP)
Emission Limit(s): 15.3 lb./MMCF of LPG or Natural Gas
Authority for Requirement: Part 7a. of State of Iowa, ex rel., Iowa DNR vs. Vermeer
Manufacturing Company, 99AG23542
District Court, Marion County, Law No. LACV087889
Pollutant: Particulate Matter (TSP)
Emission Limits: 0.8 lb./MMBtu
Authority for Requirement: 567 IAC 23.3(2)"b"
Pollutant: Sulfur Dioxide (SO2)
Emission Limits: 500 ppmv
Authority for Requirement: 567 IAC 23.3(3)"e"
Pollutant: Nitrogen Oxides (NOx)
Emission Limit(s): See Facility-Wide Conditions
Authority for Requirement: Iowa DNR Construction Permit 98-A-003-S1
Pollutant: Volatile Organic Compounds (VOC)
Emission Limit: See Facility-Wide Conditions
Authority for Requirement: Iowa DNR Construction Permit 98-A-003-S1
69
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Operational Limits & Requirements:
The owner/operator of this equipment shall comply with the following operational limits
and requirements.
Process throughput:
A. The sulfur content of natural gas or LPG combusted by this source is not to
exceed 123 ppm by weight.
Reporting & Recordkeeping: See Facility-Wide Operational Limits
Authority for Requirement: Part 7b. of State of Iowa, ex rel., Iowa DNR vs. Vermeer
Manufacturing Company, 99AG23542
District Court, Marion County, Law No. LACV087889
Compliance Plan:
The owner/operator of this equipment shall comply with the following applicable
requirements.
This point is in compliance with all applicable requirements and shall continue to comply
with all such requirements. For those applicable requirements which will become
effective during the permit term, this source will comply with such requirements in a
timely manner.
Periodic Monitoring Requirements:
The owner/operator of this equipment shall comply with the following periodic
monitoring requirements.
Agency Approved Operation & Maintenance Plan Required? Yes ~ No IXI
Facility Maintained Operation & Maintenance Plan Required? Yes ~ No Kl
Authority for Requirement: 567 IAC 22.108(3)"b"
70
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Emission Point ID Number: l.V
Associated Equipment
Associated Emission Unit ID Numbers (if multiple units vent thru this EP):
l.V
Applicable Requirements
(If more than one emission unit vents through this emission point subdivide the applicable requirements by emission
unit.)
Emission Unit vented through this Emission Point: 1 .V
Emission Unit Description: Non-Production Heating Unit
Raw Material/Fuel: Propane (LPG) or Natural Gas
Rated Capacity: 2.0 MMBtu/hr.
Emission Limits (lb./hr. gr./dscf. lb./MMBtu. % opacity, etc.):
The emissions from this emission point shall not exceed the following specified levels.
Pollutant: Opacity
Emission Limit(s): 40 %
Authority for Requirement: 567 IAC 23.3(2)"d"
Pollutant: Particulate Matter (TSP)
Emission Limit(s): 15.3 lb./MMCF of LPG or Natural Gas
Authority for Requirement: Part 7a. of State of Iowa, ex rel., Iowa DNR vs. Vermeer
Manufacturing Company, 99AG23542
District Court, Marion County, Law No. LACV087889
Pollutant: Particulate Matter (TSP)
Emission Limits: 0.8 lb./MMBtu
Authority for Requirement: 567 IAC 23.3(2)"b"
Pollutant: Sulfur Dioxide (SO2)
Emission Limits: 500 ppmv
Authority for Requirement: 567 IAC 23.3(3)"e"
Pollutant: Nitrogen Oxides (NOx)
Emission Limit(s): See Facility-Wide Conditions
Authority for Requirement: Iowa DNR Construction Permit 98-A-003-S1
Pollutant: Volatile Organic Compounds (VOC)
Emission Limit: See Facility-Wide Conditions
Authority for Requirement: Iowa DNR Construction Permit 98-A-003-S1
71
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Operational Limits & Requirements:
The owner/operator of this equipment shall comply with the following operational limits
and requirements.
Process throughput:
A. The sulfur content of natural gas or LPG combusted by this source is not to
exceed 123 ppm by weight.
Reporting & Recordkeeping: See Facility-Wide Operational Limits
Authority for Requirement: Part 7b. of State of Iowa, ex rel., Iowa DNR vs. Vermeer
Manufacturing Company, 99AG23542
District Court, Marion County, Law No. LACV087889
Compliance Plan:
The owner/operator of this equipment shall comply with the following applicable
requirements.
This point is in compliance with all applicable requirements and shall continue to comply
with all such requirements. For those applicable requirements which will become
effective during the permit term, this source will comply with such requirements in a
timely manner.
Periodic Monitoring Requirements:
The owner/operator of this equipment shall comply with the following periodic
monitoring requirements.
Agency Approved Operation & Maintenance Plan Required? Yes ~ No IXI
Facility Maintained Operation & Maintenance Plan Required? Yes ~ No Kl
Authority for Requirement: 567 IAC 22.108(3)"b"
72
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Emission Point ID Number: l.WELDING
Associated Equipment
Associated Emission Unit ID Numbers (if multiple units vent thru this EP):
l.WELDING
Applicable Requirements
(If more than one emission unit vents through this emission point subdivide the applicable requirements by emission
unit.)
Emission Unit vented through this Emission Point: 1 .WELDING (Fugitive)
Emission Unit Description: 37 GMAW Units
Raw Material/Fuel: E70S Weld Wire
Rated Capacity: 19 lb. ofWire/hr. per Unit
Emission Limits (lb./hr. gr./dscf. lb./MMBtu. % opacity, etc.):
The emissions from this emission point shall not exceed the following specified levels.
Pollutant: Fugitive Dust
Emission Limit: No person shall allow, cause or permit any materials to be handled,
transported or stored; or a building, its appurtenances or a construction haul road to
be used, constructed, altered , repaired or demolished, without taking reasonable
precautions to prevent a nuisance. All persons shall take reasonable precautions to
prevent the discharge of visible emissions of fugitive dusts beyond the lot line of the
property on which the emissions originate.
Authority for Requirement: 567 IAC 23.3(2)"c"
Compliance Plan:
The owner/operator of this equipment shall comply with the following applicable
requirements.
This point is in compliance with all applicable requirements and shall continue to comply
with all such requirements. For those applicable requirements which will become
effective during the permit term, this source will comply with such requirements in a
timely manner.
Periodic Monitoring Requirements:
The owner/operator of this equipment shall comply with the following periodic
monitoring requirements.
Agency Approved Operation & Maintenance Plan Required? Yes ~ No Kl
Facility Maintained Operation & Maintenance Plan Required? Yes ~ No Kl
Authority for Requirement: 567 IAC 22.108(3)"b"
73
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Emission Point ID Number: l.WELDPLS
Associated Equipment
Associated Emission Unit ID Numbers (if multiple units vent thru this EP):
l.WELDPLS
Applicable Requirements
(If more than one emission unit vents through this emission point subdivide the applicable requirements by emission
unit.)
Emission Unit vented through this Emission Point: 1 .WELDPLS (Fugitive)
Emission Unit Description: 19 Pulse Current GMAW Units
Raw Material/Fuel: E70S Weld Wire
Rated Capacity: 19 lb. ofWire/hr. per Unit
Emission Limits (lb./hr. gr./dscf. lb./MMBtu. % opacity, etc.):
The emissions from this emission point shall not exceed the following specified levels.
Pollutant: Fugitive Dust
Emission Limit: No person shall allow, cause or permit any materials to be handled,
transported or stored; or a building, its appurtenances or a construction haul road to
be used, constructed, altered , repaired or demolished, without taking reasonable
precautions to prevent a nuisance. All persons shall take reasonable precautions to
prevent the discharge of visible emissions of fugitive dusts beyond the lot line of the
property on which the emissions originate.
Authority for Requirement: 567 IAC 23.3(2)"c"
Compliance Plan:
The owner/operator of this equipment shall comply with the following applicable
requirements.
This point is in compliance with all applicable requirements and shall continue to comply
with all such requirements. For those applicable requirements which will become
effective during the permit term, this source will comply with such requirements in a
timely manner.
Periodic Monitoring Requirements:
The owner/operator of this equipment shall comply with the following periodic
monitoring requirements.
Agency Approved Operation & Maintenance Plan Required? Yes ~ No Kl
Facility Maintained Operation & Maintenance Plan Required? Yes ~ No Kl
Authority for Requirement: 567 IAC 22.108(3)"b"
74
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Emission Point ID Number: l.Y
Associated Equipment
Associated Emission Unit ID Numbers (if multiple units vent thru this EP):
l.Y
Applicable Requirements
(If more than one emission unit vents through this emission point subdivide the applicable requirements by emission
unit.)
Emission Unit vented through this Emission Point: 1.Y
Emission Unit Description: Non-Production Heating Unit
Raw Material/Fuel: Propane (LPG) or Natural Gas
Rated Capacity: 8.0 MMBtu/hr.
Emission Limits (lb./hr. gr./dscf. lb./MMBtu. % opacity, etc.):
The emissions from this emission point shall not exceed the following specified levels.
Pollutant: Opacity
Emission Limit(s): 40 %
Authority for Requirement: 567 IAC 23.3(2)"d"
Pollutant: Particulate Matter (TSP)
Emission Limit(s): 15.3 lb./MMCF of LPG or Natural Gas
Authority for Requirement: Part 7a. of State of Iowa, ex rel., Iowa DNR vs. Vermeer
Manufacturing Company, 99AG23542
District Court, Marion County, Law No. LACV087889
Pollutant: Particulate Matter (TSP)
Emission Limits: 0.8 lb./MMBtu
Authority for Requirement: 567 IAC 23.3(2)"b"
Pollutant: Sulfur Dioxide (SO2)
Emission Limits: 500 ppmv
Authority for Requirement: 567 IAC 23.3(3)"e"
Pollutant: Nitrogen Oxides (NOx)
Emission Limit(s): See Facility-Wide Conditions
Authority for Requirement: Iowa DNR Construction Permit 98-A-003-S1
Pollutant: Volatile Organic Compounds (VOC)
Emission Limit: See Facility-Wide Conditions
Authority for Requirement: Iowa DNR Construction Permit 98-A-003-S1
75
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Operational Limits & Requirements:
The owner/operator of this equipment shall comply with the following operational limits
and requirements.
Process throughput:
A. The sulfur content of natural gas or LPG combusted by this source is not to
exceed 123 ppm by weight.
Reporting & Recordkeeping: See Facility-Wide Operational Limits
Authority for Requirement: Part 7b. of State of Iowa, ex rel., Iowa DNR vs. Vermeer
Manufacturing Company, 99AG23542
District Court, Marion County, Law No. LACV087889
Compliance Plan:
The owner/operator of this equipment shall comply with the following applicable
requirements.
This point is in compliance with all applicable requirements and shall continue to comply
with all such requirements. For those applicable requirements which will become
effective during the permit term, this source will comply with such requirements in a
timely manner.
Periodic Monitoring Requirements:
The owner/operator of this equipment shall comply with the following periodic
monitoring requirements.
Agency Approved Operation & Maintenance Plan Required? Yes ~ No IXI
Facility Maintained Operation & Maintenance Plan Required? Yes ~ No Kl
Authority for Requirement: 567 IAC 22.108(3)"b"
76
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Emission Point ID Number: 2.AB
Associated Equipment
Associated Emission Unit ID Numbers (if multiple units vent thru this EP): 2. AB
Applicable Requirements
(If more than one emission unit vents through this emission point subdivide the applicable requirements by emission
unit.)
Emission Unit vented through this Emission Point: 2.AB
Emission Unit Description: Production Engine Testing Unit
Raw Material/Fuel: #2 Diesel Fuel and Gasoline
Rated Capacity: 51.7 gal./hr.
Emission Limits (lb./hr. gr./dscf. lb./MMBtu. % opacity, etc.):
The emissions from this emission point shall not exceed the following specified levels.
Pollutant: Opacity
Emission Limit(s): 40 %
Authority for Requirement: 567 IAC 23.3(2)"d"
Pollutant:
Emission Limits:
Authority for Requirement:
Particulate Matter (TSP)
0.1 gr./dscf
567 IAC 23.3(2)"a"
Pollutant: Sulfur Dioxide (SO2)
Emission Limits: 2.5 lb./MMBtu
Authority for Requirement: 567 IAC 23.3(3)"b"
Pollutant: Nitrogen Oxides (NOx)
Emission Limit(s): See Facility-Wide Conditions
Authority for Requirement: Iowa DNR Construction Permit 97-A-299-S2
Pollutant: Volatile Organic Compounds (VOC)
Emission Limit: See Facility-Wide Conditions
Authority for Requirement: Iowa DNR Construction Permit 97-A-299-S2
77
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Operational Limits & Requirements:
The owner/operator of this equipment shall comply with the following operational limits
and requirements.
Process Throughput:
A. The sulfur content of any diesel fuel used in this source shall not exceed 0.4% by
weight.
Reporting & Recordkeeping: See Facility-Wide Emission and Operational Limits
Authority for Requirement: Iowa DNR Construction Permit 97-A-299-S2
Compliance Plan:
The owner/operator of this equipment shall comply with the following applicable
requirements.
This point is in compliance with all applicable requirements and shall continue to comply
with all such requirements. For those applicable requirements which will become
effective during the permit term, this source will comply with such requirements in a
timely manner.
Periodic Monitoring Requirements:
The owner/operator of this equipment shall comply with the following periodic
monitoring requirements.
Agency Approved Operation & Maintenance Plan Required? Yes ~ No Kl
Facility Maintained Operation & Maintenance Plan Required? Yes ~ No Kl
Authority for Requirement: 567 IAC 22.108(3)"b"
78
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Emission Point ID Number: 2.AF
Associated Equipment
Associated Emission Unit ID Numbers (if multiple units vent thru this EP): 2.AF1, 2.AF2
Applicable Requirements
(If more than one emission unit vents through this emission point subdivide the applicable requirements by emission
unit.)
Emission Units vented through this Emission Point: 2.AF1
Emission Unit Description: Paint Kitchen
Raw Material/Fuel: Paints, Primers, and Solvents
Rated Capacity: 3 Barrels
Emission Units vented through this Emission Point: 2. AF2
Emission Unit Description: Paint Kitchen
Raw Material/Fuel: Paints, Primers, and Solvents
Rated Capacity: 3 Barrels
Emission Limits (lb./hr. gr./dscf. lb./MMBtu. % opacity, etc.):
The emissions from this emission point shall not exceed the following specified levels.
Pollutant: Volatile Organic Compounds (VOC)
Emission Limit: See Facility-Wide Conditions
Authority for Requirement: Iowa DNR Construction Permit 98-A-073-S1
Compliance Plan:
The owner/operator of this equipment shall comply with the following applicable
requirements.
This point is in compliance with all applicable requirements and shall continue to comply
with all such requirements. For those applicable requirements which will become
effective during the permit term, this source will comply with such requirements in a
timely manner.
Additional Requirements:
This emission point shall conform to the following conditions.
The source is to be connected to the stack of the following detailed description.
Stack Height (feet): 41
Stack Diameter (inches): 20
Stack Exhaust Flow Rate (acfm): .... 7,000
Stack Temperature (°F): 70
Vertical, Unobstructed Discharge Required: Yes ^ No ~
Authority for Requirement: Iowa DNR Construction Permit 98-A-073-S1
79
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Periodic Monitoring Requirements:
The owner/operator of this equipment shall comply with the following periodic
monitoring requirements.
Agency Approved Operation & Maintenance Plan Required? Yes ~ No Kl
Facility Maintained Operation & Maintenance Plan Required? Yes ~ No Kl
Authority for Requirement: 567 IAC 22.108(3)"b"
80
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Emission Point ID Number: 2.AG
Associated Equipment
Associated Emission Unit ID Numbers (if multiple units vent thru this EP): 2. AG
Applicable Requirements
(If more than one emission unit vents through this emission point subdivide the applicable requirements by emission
unit.)
Emission Unit vented through this Emission Point: 2.AG
Emission Unit Description: Paint Kitchen
Raw Material/Fuel: Paints, Primers, and Solvents
Rated Capacity: 3 Barrels
Emission Limits (lb./hr. gr./dscf. lb./MMBtu. % opacity, etc.):
The emissions from this emission point shall not exceed the following specified levels.
Pollutant: Volatile Organic Compounds (VOC)
Emission Limit: See Facility-Wide Conditions
Authority for Requirement: Iowa DNR Construction Permit 98-A-074-S1
Compliance Plan:
The owner/operator of this equipment shall comply with the following applicable
requirements.
This point is in compliance with all applicable requirements and shall continue to comply
with all such requirements. For those applicable requirements which will become
effective during the permit term, this source will comply with such requirements in a
timely manner.
Additional Requirements:
This emission point shall conform to the following conditions.
The source is to be connected to the stack of the following detailed description.
Stack Height (feet): 41
Stack Diameter (inches): 15
Stack Exhaust Flow Rate (acfm): .... 3,500
Stack Temperature (°F): 70
Vertical, Unobstructed Discharge Required: Yes ^ No ~
Authority for Requirement: Iowa DNR Construction Permit 98-A-074-S1
81
-------
Periodic Monitoring Requirements:
The owner/operator of this equipment shall comply with the following periodic
monitoring requirements.
Agency Approved Operation & Maintenance Plan Required? Yes ~ No Kl
Facility Maintained Operation & Maintenance Plan Required? Yes ~ No Kl
Authority for Requirement: 567 IAC 22.108(3)"b"
82
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Emission Point ID Number: 2AI1
Associated Equipment
Associated Emission Unit ID Numbers (if multiple units vent thru this EP): 2. AI
Emissions Control Equipment ID Number: 2.AI
Emissions Control Equipment Description: Paper Filter
Applicable Requirements
(If more than one emission unit vents through this emission point subdivide the applicable requirements by emission
unit.)
Emission Unit vented through this Emission Point: 2.AI
Emission Unit Description: Finish Paint Booth
Raw Material/Fuel: Paints, Primers, and Solvents
Rated Capacity: 15 gal./hr.
Emission Limits (lb./hr. gr./dscf. lb./MMBtu. % opacity, etc.):
The emissions from this emission point shall not exceed the following specified levels.
Pollutant: Opacity
Emission Limits: 40%
Indicator Opacity: (1)
(1) If visible emissions are observed other than startup, shutdown or malfunction, a stack
test may be required to demonstrate compliance with the particulate standard.
Authority for Requirement: Iowa DNR Construction Permit 98-A-859-S2
567 IAC 23.3(2)"d"
Pollutant: Particulate Matter (TSP)
Emission Limit(s): 0.01 gr./dscf
Authority for Requirement: Iowa DNR Construction Permit 98-A-859-S2
567 IAC 23.4(13)
Pollutant: Volatile Organic Compounds (VOC)
Emission Limit: See Facility-Wide Conditions
Authority for Requirement: Iowa DNR Construction Permit 98-A-859-S2
Compliance Plan:
The owner/operator of this equipment shall comply with the following applicable
requirements.
This point is in compliance with all applicable requirements and shall continue to comply
with all such requirements. For those applicable requirements which will become
effective during the permit term, this source will comply with such requirements in a
timely manner.
83
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Additional Requirements:
This emission point shall conform to the following conditions.
The source is to be connected to the stack of the following detailed description.
Stack Height (feet): 36.2
Stack Diameter (inches): 42.0
Stack Exhaust Flow Rate (acfm): .... 16,875
Stack Temperature (°F): 70
Vertical, Unobstructed Discharge Required: Yes ^ No ~
Authority for Requirement: Iowa DNR Construction Permit 98-A-859-S2
Periodic Monitoring Requirements:
The owner/operator of this equipment shall comply with the following periodic
monitoring requirements.
Stack Testing:
Pollutant: Particulate Matter (TSP)
Stack Test to be Completed by (date): October 18, 2001
Test Method: Iowa Compliance Sampling Manual
Authority for Requirement: 567 IAC 22.108(3)
The higher of the results for emissions from the compliance stack testing of emission
points 2.All and 2.AI 2 will be used to calculate actual emissions for this source until
such time as more recent data becomes available. If the source test does not demonstrate
compliance this permit will be reopened to add a compliance plan and operation and
maintenance requirements.
The owner of this equipment or the owner's authorized agent shall provide written notice
to the Director, not less than 30 days before a required stack test or performance
evaluation of a continuous emission monitor. Results of the test shall be submitted in
writing to the Director in the form of a comprehensive report within 6 weeks of the
completion of the testing. 567 IAC 25.1(7)
Opacity Monitoring:
The facility shall observe the opacity weekly during a period when the emission unit
associated with this emission point is at or near full capacity and record the reading
indicating if visible emissions were observed. The records shall be maintained for five
years. If weather conditions prevent the observer from conducting an opacity
observation, the observer shall note such conditions on the data observation sheet. At
least three attempts shall be made to retake opacity readings at approximately 2-hour
intervals throughout the day. If all observation attempts for a week have been
unsuccessful due to weather, an observation shall be made the next operating day where
weather permits.
Maintain a written record of the observation and any action resulting from the
observation.
84
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Agency Approved Operation & Maintenance Plan Required? Yes ~ No
Facility Maintained Operation & Maintenance Plan Required? Yes Kl NoQ
Facility operation and maintenance plans must be sufficient to yield reliable data from
the relevant time period that are representative of the source's compliance with the
applicable requirements.
Facility operation and maintenance plans are to be developed by the facility within six(6)
months of the issuance date of this permit and the data pertaining to the plan maintained
on site for at least 5 years. The plan and associated recordkeeping provides
documentation of this facility's implementation of its obligation to operate according to
good air pollution control practice.
Good air pollution control practice is achieved by adoption of quality control standards
in the operation and maintenance procedures for air pollution control that are
comparable to industry quality control standards for the production processes associated
with this emission point.
Authority for Requirement: 567 IAC 22.108(3)"b"
85
-------
Emission Point ID Number: 2.AI2
Associated Equipment
Associated Emission Unit ID Numbers (if multiple units vent thru this EP): 2. AI
Emissions Control Equipment ID Number: 2.AI
Emissions Control Equipment Description: Paper Filter
Applicable Requirements
(If more than one emission unit vents through this emission point subdivide the applicable requirements by emission
unit.)
Emission Unit vented through this Emission Point: 2.AI
Emission Unit Description: Finish Paint Booth
Raw Material/Fuel: Paints, Primers, and Solvents
Rated Capacity: 15 gal./hr.
Emission Limits (lb./hr. gr./dscf. lb./MMBtu. % opacity, etc.):
The emissions from this emission point shall not exceed the following specified levels.
Pollutant: Opacity
Emission Limits: 40%
Indicator Opacity: (1)
(1) If visible emissions are observed other than startup, shutdown or malfunction, a stack
test may be required to demonstrate compliance with the particulate standard.
Authority for Requirement: Iowa DNR Construction Permit 98-A-860-S2
567 IAC 23.3(2)"d"
Pollutant: Particulate Matter (TSP)
Emission Limit(s): 0.01 gr./dscf
Authority for Requirement: Iowa DNR Construction Permit 98-A-860-S2
567 IAC 23.4(13)
Pollutant: Volatile Organic Compounds (VOC)
Emission Limit: See Facility-Wide Conditions
Authority for Requirement: Iowa DNR Construction Permit 98-A-860-S2
Compliance Plan:
The owner/operator of this equipment shall comply with the following applicable
requirements.
This point is in compliance with all applicable requirements and shall continue to comply
with all such requirements. For those applicable requirements which will become
effective during the permit term, this source will comply with such requirements in a
timely manner.
86
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Additional Requirements:
This emission point shall conform to the following conditions.
The source is to be connected to the stack of the following detailed description.
Stack Height (feet): 36.2
Stack Diameter (inches): 42.0
Stack Exhaust Flow Rate (acfm): .... 16,875
Stack Temperature (°F): 70
Vertical, Unobstructed Discharge Required: Yes ^ No ~
Authority for Requirement: Iowa DNR Construction Permit 98-A-860-S2
Periodic Monitoring Requirements:
The owner/operator of this equipment shall comply with the following periodic
monitoring requirements.
Stack Testing:
Pollutant: Particulate Matter (TSP)
Stack Test to be Completed by (date): October 18, 2001
Test Method: Iowa Compliance Sampling Manual
Authority for Requirement: 567 IAC 22.108(3)
The higher of the results for emissions from the compliance stack testing of emission
points 2.All and 2.AI 2 will be used to calculate actual emissions for this source until
such time as more recent data becomes available. If the source test does not demonstrate
compliance this permit will be reopened to add a compliance plan and operation and
maintenance requirements.
The owner of this equipment or the owner's authorized agent shall provide written notice
to the Director, not less than 30 days before a required stack test or performance
evaluation of a continuous emission monitor. Results of the test shall be submitted in
writing to the Director in the form of a comprehensive report within 6 weeks of the
completion of the testing. 567 IAC 25.1(7)
Opacity Monitoring:
The facility shall observe the opacity weekly during a period when the emission unit
associated with this emission point is at or near full capacity and record the reading
indicating if visible emissions were observed. The records shall be maintained for five
years. If weather conditions prevent the observer from conducting an opacity
observation, the observer shall note such conditions on the data observation sheet. At
least three attempts shall be made to retake opacity readings at approximately 2-hour
intervals throughout the day. If all observation attempts for a week have been
unsuccessful due to weather, an observation shall be made the next operating day where
weather permits.
Maintain a written record of the observation and any action resulting from the
observation.
87
-------
Agency Approved Operation & Maintenance Plan Required? Yes ~ No
Facility Maintained Operation & Maintenance Plan Required? Yes Kl NoQ
Facility operation and maintenance plans must be sufficient to yield reliable data from
the relevant time period that are representative of the source's compliance with the
applicable requirements.
Facility operation and maintenance plans are to be developed by the facility within six(6)
months of the issuance date of this permit and the data pertaining to the plan maintained
on site for at least 5 years. The plan and associated recordkeeping provides
documentation of this facility's implementation of its obligation to operate according to
good air pollution control practice.
Good air pollution control practice is achieved by adoption of quality control standards
in the operation and maintenance procedures for air pollution control that are
comparable to industry quality control standards for the production processes associated
with this emission point.
Authority for Requirement: 567 IAC 22.108(3)"b"
88
-------
Emission Point ID Number: 2.AJ
Associated Equipment
Associated Emission Unit ID Numbers (if multiple units vent thru this EP): 2. AJ
Applicable Requirements
(If more than one emission unit vents through this emission point subdivide the applicable requirements by emission
unit.)
Emission Unit vented through this Emission Point: 2.AJ
Emission Unit Description: Paint Booth Air Intake
Raw Material/Fuel: Propane (LPG) or Natural Gas
Rated Capacity: 3.28 MMBtu/hr.
Emission Limits (lb./hr. gr./dscf. lb./MMBtu. % opacity, etc.):
The emissions from this emission point shall not exceed the following specified levels.
Pollutant: Opacity
Emission Limit(s): 40 %
Authority for Requirement: 567 IAC 23.3(2)"d"
Pollutant: Particulate Matter (TSP)
Emission Limit(s): 15.3 lb./MMCF of LPG or Natural Gas
Authority for Requirement: Part 7a. of State of Iowa, ex rel., Iowa DNR vs. Vermeer
Manufacturing Company, 99AG23542
District Court, Marion County, Law No. LACV087889
Pollutant: Particulate Matter (TSP)
Emission Limits: 0.8 lb./MMBtu
Authority for Requirement: 567 IAC 23.3(2)"b"
Pollutant: Sulfur Dioxide (SO2)
Emission Limits: 500 ppmv
Authority for Requirement: 567 IAC 23.3(3)"e"
Pollutant: Nitrogen Oxides (NOx)
Emission Limit(s): See Facility-Wide Conditions
Authority for Requirement: Iowa DNR Construction Permit 98-A-003-S1
Pollutant: Volatile Organic Compounds (VOC)
Emission Limit: See Facility-Wide Conditions
Authority for Requirement: Iowa DNR Construction Permit 98-A-003-S1
89
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Operational Limits & Requirements:
The owner/operator of this equipment shall comply with the following operational limits
and requirements.
Process throughput:
A. The sulfur content of natural gas or LPG combusted by this source is not to
exceed 123 ppm by weight.
Reporting & Recordkeeping: See Facility-Wide Operational Limits
Authority for Requirement: Part 7b. of State of Iowa, ex rel., Iowa DNR vs. Vermeer
Manufacturing Company, 99AG23542
District Court, Marion County, Law No. LACV087889
Compliance Plan:
The owner/operator of this equipment shall comply with the following applicable
requirements.
This point is in compliance with all applicable requirements and shall continue to comply
with all such requirements. For those applicable requirements which will become
effective during the permit term, this source will comply with such requirements in a
timely manner.
Periodic Monitoring Requirements:
The owner/operator of this equipment shall comply with the following periodic
monitoring requirements.
Agency Approved Operation & Maintenance Plan Required? Yes ~ No IXI
Facility Maintained Operation & Maintenance Plan Required? Yes ~ No Kl
Authority for Requirement: 567 IAC 22.108(3)"b"
90
-------
Emission Point ID Number: 2.B
Associated Equipment
Associated Emission Unit ID Numbers (if multiple units vent thru this EP): 2.B
Applicable Requirements
(If more than one emission unit vents through this emission point subdivide the applicable requirements by emission
unit.)
Emission Unit vented through this Emission Point: 2.B
Emission Unit Description: Non-Production Heating Unit
Raw Material/Fuel: Propane (LPG) or Natural Gas
Rated Capacity: 0.35 MMBtu/hr.
Emission Limits (lb./hr. gr./dscf. lb./MMBtu. % opacity, etc.):
The emissions from this emission point shall not exceed the following specified levels.
Pollutant: Opacity
Emission Limit(s): 40 %
Authority for Requirement: 567 IAC 23.3(2)"d"
Pollutant: Particulate Matter (TSP)
Emission Limit(s): 15.3 lb./MMCF of LPG or Natural Gas
Authority for Requirement: Part 7a. of State of Iowa, ex rel., Iowa DNR vs. Vermeer
Manufacturing Company, 99AG23542
District Court, Marion County, Law No. LACV087889
Pollutant: Particulate Matter (TSP)
Emission Limits: 0.8 lb./MMBtu
Authority for Requirement: 567 IAC 23.3(2)"b"
Pollutant: Sulfur Dioxide (SO2)
Emission Limits: 500 ppmv
Authority for Requirement: 567 IAC 23.3(3)"e"
Pollutant: Nitrogen Oxides (NOx)
Emission Limit(s): See Facility-Wide Conditions
Authority for Requirement: Iowa DNR Construction Permit 98-A-003-S1
Pollutant: Volatile Organic Compounds (VOC)
Emission Limit: See Facility-Wide Conditions
Authority for Requirement: Iowa DNR Construction Permit 98-A-003-S1
91
-------
Operational Limits & Requirements:
The owner/operator of this equipment shall comply with the following operational limits
and requirements.
Process throughput:
A. The sulfur content of natural gas or LPG combusted by this source is not to
exceed 123 ppm by weight.
Reporting & Recordkeeping: See Facility-Wide Operational Limits
Authority for Requirement: Part 7b. of State of Iowa, ex rel., Iowa DNR vs. Vermeer
Manufacturing Company, 99AG23542
District Court, Marion County, Law No. LACV087889
Compliance Plan:
The owner/operator of this equipment shall comply with the following applicable
requirements.
This point is in compliance with all applicable requirements and shall continue to comply
with all such requirements. For those applicable requirements which will become
effective during the permit term, this source will comply with such requirements in a
timely manner.
Periodic Monitoring Requirements:
The owner/operator of this equipment shall comply with the following periodic
monitoring requirements.
Agency Approved Operation & Maintenance Plan Required? Yes ~ No IXI
Facility Maintained Operation & Maintenance Plan Required? Yes ~ No Kl
Authority for Requirement: 567 IAC 22.108(3)"b"
92
-------
Emission Point ID Number: 2.E
Associated Equipment
Associated Emission Unit ID Numbers (if multiple units vent thru this EP): 2.E
Applicable Requirements
(If more than one emission unit vents through this emission point subdivide the applicable requirements by emission
unit.)
Emission Unit vented through this Emission Point: 2.E
Emission Unit Description: Production Engine Testing Unit
Raw Material/Fuel: #2 Diesel Fuel and Gasoline
Rated Capacity: 49.1 gal./hr.
Emission Limits (lb./hr. gr./dscf. lb./MMBtu. % opacity, etc.):
The emissions from this emission point shall not exceed the following specified levels.
Pollutant: Opacity
Emission Limit(s): 40 %
Authority for Requirement: 567 IAC 23.3(2)"d"
Pollutant:
Emission Limits:
Authority for Requirement:
Particulate Matter (TSP)
0.1 gr./dscf
567 IAC 23.3(2)"a"
Pollutant: Sulfur Dioxide (SO2)
Emission Limits: 2.5 lb./MMBtu
Authority for Requirement: 567 IAC 23.3(3)"b"
Pollutant: Nitrogen Oxides (NOx)
Emission Limit(s): See Facility-Wide Conditions
Authority for Requirement: Iowa DNR Construction Permit 97-A-299-S2
Pollutant: Volatile Organic Compounds (VOC)
Emission Limit: See Facility-Wide Conditions
Authority for Requirement: Iowa DNR Construction Permit 97-A-299-S2
93
-------
Operational Limits & Requirements:
The owner/operator of this equipment shall comply with the following operational limits
and requirements.
Process Throughput:
A. The sulfur content of any diesel fuel used in this source shall not exceed 0.4% by
weight.
Reporting & Recordkeeping: See Facility-Wide Emission and Operational Limits
Authority for Requirement: Iowa DNR Construction Permit 97-A-299-S2
Compliance Plan:
The owner/operator of this equipment shall comply with the following applicable
requirements.
This point is in compliance with all applicable requirements and shall continue to comply
with all such requirements. For those applicable requirements which will become
effective during the permit term, this source will comply with such requirements in a
timely manner.
Periodic Monitoring Requirements:
The owner/operator of this equipment shall comply with the following periodic
monitoring requirements.
Agency Approved Operation & Maintenance Plan Required? Yes ~ No Kl
Facility Maintained Operation & Maintenance Plan Required? Yes ~ No Kl
Authority for Requirement: 567 IAC 22.108(3)"b"
94
-------
Emission Point ID Number: 2.F1
Associated Equipment
Associated Emission Unit ID Numbers (if multiple units vent thru this EP): 2.F
Emissions Control Equipment ID Number: 2.F
Emissions Control Equipment Description: Paper Filter
Applicable Requirements
(If more than one emission unit vents through this emission point subdivide the applicable requirements by emission
unit.)
Emission Unit vented through this Emission Point: 2.F
Emission Unit Description: Finish Paint Booth
Raw Material/Fuel: Paints, Primers, and Solvents
Rated Capacity: 15 gal./hr.
Emission Limits (lb./hr. gr./dscf. lb./MMBtu. % opacity, etc.):
The emissions from this emission point shall not exceed the following specified levels.
Pollutant: Opacity
Emission Limits: 40%
Indicator Opacity: (1)
(1) If visible emissions are observed other than startup, shutdown or malfunction, a stack
test may be required to demonstrate compliance with the particulate standard.
Authority for Requirement: Iowa DNR Construction Permit 98-A-075-S2
567 IAC 23.3(2)"d"
Pollutant: PMio
Emission Limit(s): 0.9 lb./hr.
Authority for Requirement: Iowa DNR Construction Permit 98-A-075-S2
Pollutant: Particulate Matter (TSP)
Emission Limit(s): 0.01 gr./dscf
Authority for Requirement: Iowa DNR Construction Permit 98-A-075-S2
567 IAC 23.4(13)
Pollutant: Volatile Organic Compounds (VOC)
Emission Limit: See Facility-Wide Conditions
Authority for Requirement: Iowa DNR Construction Permit 98-A-075-S2
95
-------
Compliance Plan:
The owner/operator of this equipment shall comply with the following applicable
requirements.
This point is in compliance with all applicable requirements and shall continue to comply
with all such requirements. For those applicable requirements which will become
effective during the permit term, this source will comply with such requirements in a
timely manner.
Additional Requirements:
This emission point shall conform to the following conditions.
The source is to be connected to the stack of the following detailed description.
Stack Height (feet): 46.2
Stack Diameter (inches): 42.0
Stack Exhaust Flow Rate (acfm): .... 21,000
Stack Temperature (°F): 70
Vertical, Unobstructed Discharge Required: Yes E No ~
Authority for Requirement: Iowa DNR Construction Permit 98-A-075-S2
Periodic Monitoring Requirements:
The owner/operator of this equipment shall comply with the following periodic
monitoring requirements.
Opacity Monitoring:
The facility shall observe the opacity weekly during a period when the emission unit
associated with this emission point is at or near full capacity and record the reading
indicating if visible emissions were observed. The records shall be maintained for five
years. If weather conditions prevent the observer from conducting an opacity
observation, the observer shall note such conditions on the data observation sheet. At
least three attempts shall be made to retake opacity readings at approximately 2-hour
intervals throughout the day. If all observation attempts for a week have been
unsuccessful due to weather, an observation shall be made the next operating day where
weather permits.
Maintain a written record of the observation and any action resulting from the
observation.
Agency Approved Operation & Maintenance Plan Required? Yes ~ No Kl
Facility Maintained Operation & Maintenance Plan Required? Yes Kl NoQ
Facility operation and maintenance plans must be sufficient to yield reliable data from
the relevant time period that are representative of the source's compliance with the
applicable requirements.
96
-------
Facility operation and maintenance plans are to be developed by the facility within six(6)
months of the issuance date of this permit and the data pertaining to the plan maintained
on site for at least 5 years. The plan and associated recordkeeping provides
documentation of this facility's implementation of its obligation to operate according to
good air pollution control practice.
Good air pollution control practice is achieved by adoption of quality control standards
in the operation and maintenance procedures for air pollution control that are
comparable to industry quality control standards for the production processes associated
with this emission point.
Authority for Requirement: 567 IAC 22.108(3)"b"
97
-------
Emission Point ID Number: 2.F2
Associated Equipment
Associated Emission Unit ID Numbers (if multiple units vent thru this EP): 2.F
Emissions Control Equipment ID Number: 2.F
Emissions Control Equipment Description: Paper Filter
Applicable Requirements
(If more than one emission unit vents through this emission point subdivide the applicable requirements by emission
unit.)
Emission Unit vented through this Emission Point: 2.F
Emission Unit Description: Finish Paint Booth
Raw Material/Fuel: Paints, Primers, and Solvents
Rated Capacity: 15 gal./hr.
Emission Limits (lb./hr. gr./dscf. lb./MMBtu. % opacity, etc.):
The emissions from this emission point shall not exceed the following specified levels.
Pollutant: Opacity
Emission Limits: 40%
Indicator Opacity: (1)
(1) If visible emissions are observed other than startup, shutdown or malfunction, a stack
test may be required to demonstrate compliance with the particulate standard.
Authority for Requirement: Iowa DNR Construction Permit 98-A-076-S2
567 IAC 23.3(2)"d"
Pollutant: PMio
Emission Limit(s): 0.9 lb./hr.
Authority for Requirement: Iowa DNR Construction Permit 98-A-076-S2
Pollutant: Particulate Matter (TSP)
Emission Limit(s): 0.01 gr./dscf
Authority for Requirement: Iowa DNR Construction Permit 98-A-076-S2
567 IAC 23.4(13)
Pollutant: Volatile Organic Compounds (VOC)
Emission Limit: See Facility-Wide Conditions
Authority for Requirement: Iowa DNR Construction Permit 98-A-076-S2
98
-------
Compliance Plan:
The owner/operator of this equipment shall comply with the following applicable
requirements.
This point is in compliance with all applicable requirements and shall continue to comply
with all such requirements. For those applicable requirements which will become
effective during the permit term, this source will comply with such requirements in a
timely manner.
Additional Requirements:
This emission point shall conform to the following conditions.
The source is to be connected to the stack of the following detailed description.
Stack Height (feet): 46.2
Stack Diameter (inches): 42.0
Stack Exhaust Flow Rate (acfm): .... 21,000
Stack Temperature (°F): 70
Vertical, Unobstructed Discharge Required: Yes E No ~
Authority for Requirement: Iowa DNR Construction Permit 98-A-076-S2
Periodic Monitoring Requirements:
The owner/operator of this equipment shall comply with the following periodic
monitoring requirements.
Opacity Monitoring:
The facility shall observe the opacity weekly during a period when the emission unit
associated with this emission point is at or near full capacity and record the reading
indicating if visible emissions were observed. The records shall be maintained for five
years. If weather conditions prevent the observer from conducting an opacity
observation, the observer shall note such conditions on the data observation sheet. At
least three attempts shall be made to retake opacity readings at approximately 2-hour
intervals throughout the day. If all observation attempts for a week have been
unsuccessful due to weather, an observation shall be made the next operating day where
weather permits.
Maintain a written record of the observation and any action resulting from the
observation.
Agency Approved Operation & Maintenance Plan Required? Yes ~ No Kl
Facility Maintained Operation & Maintenance Plan Required? Yes Kl NoQ
Facility operation and maintenance plans must be sufficient to yield reliable data from
the relevant time period that are representative of the source's compliance with the
applicable requirements.
99
-------
Facility operation and maintenance plans are to be developed by the facility within six(6)
months of the issuance date of this permit and the data pertaining to the plan maintained
on site for at least 5 years. The plan and associated recordkeeping provides
documentation of this facility's implementation of its obligation to operate according to
good air pollution control practice.
Good air pollution control practice is achieved by adoption of quality control standards
in the operation and maintenance procedures for air pollution control that are
comparable to industry quality control standards for the production processes associated
with this emission point.
Authority for Requirement: 567 IAC 22.108(3)"b"
100
-------
Emission Point ID Number: 2.FLAME1
Associated Equipment
Associated Emission Unit ID Numbers (if multiple units vent thru this EP): 2.FLAME1
Applicable Requirements
(If more than one emission unit vents through this emission point subdivide the applicable requirements by emission
unit.)
Emission Unit vented through this Emission Point: 2.FLAME1 (Fugitive)
Emission Unit Description: Single Cutting Head Oxyacetylene
Torch Unit
Raw Material/Fuel: Sheet Steel
Rated Capacity: 660 inches of metal cut/hr.
Emission Limits (lb./hr. gr./dscf. lb./MMBtu. % opacity, etc.):
The emissions from this emission point shall not exceed the following specified levels.
Pollutant: Fugitive Dust
Emission Limit: No person shall allow, cause or permit any materials to be handled,
transported or stored; or a building, its appurtenances or a construction haul road to
be used, constructed, altered , repaired or demolished, without taking reasonable
precautions to prevent a nuisance. All persons shall take reasonable precautions to
prevent the discharge of visible emissions of fugitive dusts beyond the lot line of the
property on which the emissions originate.
Authority for Requirement: 567 IAC 23.3(2)"c"
Compliance Plan:
The owner/operator of this equipment shall comply with the following applicable
requirements.
This point is in compliance with all applicable requirements and shall continue to comply
with all such requirements. For those applicable requirements which will become
effective during the permit term, this source will comply with such requirements in a
timely manner.
Periodic Monitoring Requirements:
The owner/operator of this equipment shall comply with the following periodic
monitoring requirements.
Agency Approved Operation & Maintenance Plan Required? Yes ~ No IXI
Facility Maintained Operation & Maintenance Plan Required? Yes ~ No Kl
Authority for Requirement: 567 IAC 22.108(3)"b"
101
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Emission Point ID Number: 2.FLAME2
Associated Equipment
Associated Emission Unit ID Numbers (if multiple units vent thru this EP): 2.FLAME2
Applicable Requirements
(If more than one emission unit vents through this emission point subdivide the applicable requirements by emission
unit.)
Emission Unit vented through this Emission Point: 2.FLAME2 (Fugitive)
Emission Unit Description: Single Cutting Head Oxyacetylene
Torch Unit
Raw Material/Fuel: Sheet Steel
Rated Capacity: 660 inches of metal cut/hr.
Emission Limits (lb./hr. gr./dscf. lb./MMBtu. % opacity, etc.):
The emissions from this emission point shall not exceed the following specified levels.
Pollutant: Fugitive Dust
Emission Limit: No person shall allow, cause or permit any materials to be handled,
transported or stored; or a building, its appurtenances or a construction haul road to
be used, constructed, altered , repaired or demolished, without taking reasonable
precautions to prevent a nuisance. All persons shall take reasonable precautions to
prevent the discharge of visible emissions of fugitive dusts beyond the lot line of the
property on which the emissions originate.
Authority for Requirement: 567 IAC 23.3(2)"c"
Compliance Plan:
The owner/operator of this equipment shall comply with the following applicable
requirements.
This point is in compliance with all applicable requirements and shall continue to comply
with all such requirements. For those applicable requirements which will become
effective during the permit term, this source will comply with such requirements in a
timely manner.
Periodic Monitoring Requirements:
The owner/operator of this equipment shall comply with the following periodic
monitoring requirements.
Agency Approved Operation & Maintenance Plan Required? Yes ~ No IXI
Facility Maintained Operation & Maintenance Plan Required? Yes ~ No Kl
Authority for Requirement: 567 IAC 22.108(3)"b"
102
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Emission Point ID Number: 2.G
Associated Equipment
Associated Emission Unit ID Numbers (if multiple units vent thru this EP): 2.G
Applicable Requirements
(If more than one emission unit vents through this emission point subdivide the applicable requirements by emission
unit.)
Emission Unit vented through this Emission Point: 2.G
Emission Unit Description: Production Engine Testing Unit
Raw Material/Fuel: #2 Diesel Fuel and Gasoline
Rated Capacity: 49.1 gal./hr.
Emission Limits (lb./hr. gr./dscf. lb./MMBtu. % opacity, etc.):
The emissions from this emission point shall not exceed the following specified levels.
Pollutant: Opacity
Emission Limit(s): 40 %
Authority for Requirement: 567 IAC 23.3(2)"d"
Pollutant:
Emission Limits:
Authority for Requirement:
Particulate Matter (TSP)
0.1 gr./dscf
567 IAC 23.3(2)"a"
Pollutant: Sulfur Dioxide (SO2)
Emission Limits: 2.5 lb./MMBtu
Authority for Requirement: 567 IAC 23.3(3)"b"
Pollutant: Nitrogen Oxides (NOx)
Emission Limit(s): See Facility-Wide Conditions
Authority for Requirement: Iowa DNR Construction Permit 97-A-299-S2
Pollutant: Volatile Organic Compounds (VOC)
Emission Limit: See Facility-Wide Conditions
Authority for Requirement: Iowa DNR Construction Permit 97-A-299-S2
103
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Operational Limits & Requirements:
The owner/operator of this equipment shall comply with the following operational limits
and requirements.
Process Throughput:
A. The sulfur content of any diesel fuel used in this source shall not exceed 0.4% by
weight.
Reporting & Recordkeeping: See Facility-Wide Emission and Operational Limits
Authority for Requirement: Iowa DNR Construction Permit 97-A-299-S2
Compliance Plan:
The owner/operator of this equipment shall comply with the following applicable
requirements.
This point is in compliance with all applicable requirements and shall continue to comply
with all such requirements. For those applicable requirements which will become
effective during the permit term, this source will comply with such requirements in a
timely manner.
Periodic Monitoring Requirements:
The owner/operator of this equipment shall comply with the following periodic
monitoring requirements.
Agency Approved Operation & Maintenance Plan Required? Yes ~ No Kl
Facility Maintained Operation & Maintenance Plan Required? Yes ~ No Kl
Authority for Requirement: 567 IAC 22.108(3)"b"
104
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Emission Point ID Number: 2.H
Associated Equipment
Associated Emission Unit ID Numbers (if multiple units vent thru this EP): 2.H
Emissions Control Equipment ID Number: 2.H
Emissions Control Equipment Description: Paper Filter
Applicable Requirements
(If more than one emission unit vents through this emission point subdivide the applicable requirements by emission
unit.)
Emission Unit vented through this Emission Point: 2.H
Emission Unit Description: Parts Paint Booth
Raw Material/Fuel: Paints, Primers, and Solvents
Rated Capacity: 15 gal./hr.
Emission Limits (lb./hr. gr./dscf. lb./MMBtu. % opacity, etc.):
The emissions from this emission point shall not exceed the following specified levels.
Pollutant: Opacity
Emission Limits: 40%
Indicator Opacity: (1)
(1) If visible emissions are observed other than startup, shutdown or malfunction, a stack
test may be required to demonstrate compliance with the particulate standard.
Authority for Requirement: Iowa DNR Construction Permit 98-A-077-S2
567 IAC 23.3(2)"d"
Pollutant: Particulate Matter (TSP)
Emission Limit(s): 0.01 gr./dscf
Authority for Requirement: Iowa DNR Construction Permit 98-A-077-S2
567 IAC 23.4(13)
Pollutant: Volatile Organic Compounds (VOC)
Emission Limit: See Facility-Wide Conditions
Authority for Requirement: Iowa DNR Construction Permit 98-A-077-S2
Compliance Plan:
The owner/operator of this equipment shall comply with the following applicable
requirements.
This point is in compliance with all applicable requirements and shall continue to comply
with all such requirements. For those applicable requirements which will become
effective during the permit term, this source will comply with such requirements in a
timely manner.
105
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Additional Requirements:
This emission point shall conform to the following conditions.
The source is to be connected to the stack of the following detailed description.
Stack Height (feet): 42.5
Stack Diameter (inches): 42.0
Stack Exhaust Flow Rate (acfm): ....21,195
Stack Temperature (°F): 70
Vertical, Unobstructed Discharge Required: Yes ~ No Kl
Authority for Requirement: Iowa DNR Construction Permit 98-A-077-S2
Periodic Monitoring Requirements:
The owner/operator of this equipment shall comply with the following periodic
monitoring requirements.
Opacity Monitoring:
The facility shall observe the opacity weekly during a period when the emission unit
associated with this emission point is at or near full capacity and record the reading
indicating if visible emissions were observed. The records shall be maintained for five
years. If weather conditions prevent the observer from conducting an opacity
observation, the observer shall note such conditions on the data observation sheet. At
least three attempts shall be made to retake opacity readings at approximately 2-hour
intervals throughout the day. If all observation attempts for a week have been
unsuccessful due to weather, an observation shall be made the next operating day where
weather permits.
Maintain a written record of the observation and any action resulting from the
observation.
Agency Approved Operation & Maintenance Plan Required? Yes ~ No Kl
Facility Maintained Operation & Maintenance Plan Required? Yes IE NoQ
Facility operation and maintenance plans must be sufficient to yield reliable data from
the relevant time period that are representative of the source's compliance with the
applicable requirements.
Facility operation and maintenance plans are to be developed by the facility within six(6)
months of the issuance date of this permit and the data pertaining to the plan maintained
on site for at least 5 years. The plan and associated recordkeeping provides
documentation of this facility's implementation of its obligation to operate according to
good air pollution control practice.
Good air pollution control practice is achieved by adoption of quality control standards
in the operation and maintenance procedures for air pollution control that are
comparable to industry quality control standards for the production processes associated
with this emission point.
Authority for Requirement: 567 IAC 22.108(3)"b"
106
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Emission Point ID Number: 2.1
Associated Equipment
Associated Emission Unit ID Numbers (if multiple units vent thru this EP): 2.1
Applicable Requirements
(If more than one emission unit vents through this emission point subdivide the applicable requirements by emission
unit.)
Emission Unit vented through this Emission Point: 2.1
Emission Unit Description: Paint Oven
Raw Material/Fuel: Propane (LPG) or Natural Gas
Rated Capacity: 0.108 MMBtu/hr.
Emission Limits (lb./hr. gr./dscf. lb./MMBtu. % opacity, etc.):
The emissions from this emission point shall not exceed the following specified levels.
Pollutant: Opacity
Emission Limits: 40%
Indicator Opacity: (1)
(1) If visible emissions are observed other than startup, shutdown or malfunction, a stack
test may be required to demonstrate compliance with the particulate standard.
Authority for Requirement: Iowa DNR Construction Permit 98-A-078-S1
567 IAC 23.3(2)"d"
Pollutant: Particulate Matter (TSP)
Emission Limit(s): 15.3 lb./MMCF of LPG or Natural Gas
Authority for Requirement: Part 7a. of State of Iowa, ex rel., Iowa DNR vs. Vermeer
Manufacturing Company, 99AG23542
District Court, Marion County, Law No. LACV087889
Pollutant: Particulate Matter (TSP)
Emission Limits: 0.1 gr./dscf
Authority for Requirement: Iowa DNR Construction Permit 98-A-078-S1
567 IAC 23.3(2)"a"
Pollutant: Sulfur Dioxide (SO2)
Emission Limits: 500 ppmv
Authority for Requirement: 567 IAC 23.3(3)"e"
Pollutant: Nitrogen Oxides (NOx)
Emission Limit(s): See Facility-Wide Conditions
Authority for Requirement: Iowa DNR Construction Permit 98-A-078-S1
107
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Emission Limits (continued):
Pollutant: Volatile Organic Compounds (VOC)
Emission Limit: See Facility-Wide Conditions
Authority for Requirement: Iowa DNR Construction Permit 98-A-078-S1
Operational Limits & Requirements:
The owner/operator of this equipment shall comply with the following operational limits
and requirements.
Process throughput:
A. This oven shall be fired by natural gas or propane only.
Reporting & Recordkeeping: See Facility-Wide Operational Limits
Authority for Requirement: Iowa DNR Construction Permit 98-A-078-S1
Process throughput:
A. The sulfur content of natural gas or LPG combusted by this source is not to
exceed 123 ppm by weight.
Reporting & Recordkeeping: See Facility-Wide Operational Limits
Authority for Requirement: Part 7b. of State of Iowa, ex rel., Iowa DNR vs. Vermeer
Manufacturing Company, 99AG23542
District Court, Marion County, Law No. LACV087889
Compliance Plan:
The owner/operator of this equipment shall comply with the following applicable
requirements.
This point is in compliance with all applicable requirements and shall continue to comply
with all such requirements. For those applicable requirements which will become
effective during the permit term, this source will comply with such requirements in a
timely manner.
Additional Requirements:
This emission point shall conform to the following conditions.
The source is to be connected to the stack of the following detailed description.
Stack Height (feet): 34
Stack Diameter (inches): 12
Stack Exhaust Flow Rate (acfm): .... 1275
Stack Temperature (°F): 150
Vertical, Unobstructed Discharge Required: Yes ^ No ~
Authority for Requirement: Iowa DNR Construction Permit 98-A-078-S1
108
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Periodic Monitoring Requirements:
The owner/operator of this equipment shall comply with the following periodic
monitoring requirements.
Opacity Monitoring:
The facility shall observe the opacity weekly during a period when the emission unit
associated with this emission point is at or near full capacity and record the reading
indicating if visible emissions were observed. The records shall be maintained for five
years. If weather conditions prevent the observer from conducting an opacity
observation, the observer shall note such conditions on the data observation sheet. At
least three attempts shall be made to retake opacity readings at approximately 2-hour
intervals throughout the day. If all observation attempts for a week have been
unsuccessful due to weather, an observation shall be made the next operating day where
weather permits.
Maintain a written record of the observation and any action resulting from the
observation.
Agency Approved Operation & Maintenance Plan Required? Yes ~ No IEI
Facility Maintained Operation & Maintenance Plan Required? Yes ~ No Kl
Authority for Requirement: 567 IAC 22.108(3)"b"
109
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Emission Point ID Number: 2. J
Associated Equipment
Associated Emission Unit ID Numbers (if multiple units vent thru this EP): 2. J
Applicable Requirements
(If more than one emission unit vents through this emission point subdivide the applicable requirements by emission
unit.)
Emission Unit vented through this Emission Point: 2.J
Emission Unit Description: Production Engine Testing Unit
Raw Material/Fuel: #2 Diesel Fuel and Gasoline
Rated Capacity: 49.1 gal./hr.
Emission Limits (lb./hr. gr./dscf. lb./MMBtu. % opacity, etc.):
The emissions from this emission point shall not exceed the following specified levels.
Pollutant: Opacity
Emission Limit(s): 40 %
Authority for Requirement: 567 IAC 23.3(2)"d"
Pollutant:
Emission Limits:
Authority for Requirement:
Particulate Matter (TSP)
0.1 gr./dscf
567 IAC 23.3(2)"a"
Pollutant: Sulfur Dioxide (SO2)
Emission Limits: 2.5 lb./MMBtu
Authority for Requirement: 567 IAC 23.3(3)"b"
Pollutant: Nitrogen Oxides (NOx)
Emission Limit(s): See Facility-Wide Conditions
Authority for Requirement: Iowa DNR Construction Permit 97-A-299-S2
Pollutant: Volatile Organic Compounds (VOC)
Emission Limit: See Facility-Wide Conditions
Authority for Requirement: Iowa DNR Construction Permit 97-A-299-S2
110
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Operational Limits & Requirements:
The owner/operator of this equipment shall comply with the following operational limits
and requirements.
Process Throughput:
A. The sulfur content of any diesel fuel used in this source shall not exceed 0.4% by
weight.
Reporting & Recordkeeping: See Facility-Wide Emission and Operational Limits
Authority for Requirement: Iowa DNR Construction Permit 97-A-299-S2
Compliance Plan:
The owner/operator of this equipment shall comply with the following applicable
requirements.
This point is in compliance with all applicable requirements and shall continue to comply
with all such requirements. For those applicable requirements which will become
effective during the permit term, this source will comply with such requirements in a
timely manner.
Periodic Monitoring Requirements:
The owner/operator of this equipment shall comply with the following periodic
monitoring requirements.
Agency Approved Operation & Maintenance Plan Required? Yes ~ No Kl
Facility Maintained Operation & Maintenance Plan Required? Yes ~ No Kl
Authority for Requirement: 567 IAC 22.108(3)"b"
111
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Emission Point ID Number: 2.P
Associated Equipment
Associated Emission Unit ID Numbers (if multiple units vent thru this EP): 2.P
Applicable Requirements
(If more than one emission unit vents through this emission point subdivide the applicable requirements by emission
unit.)
Emission Unit vented through this Emission Point: 2.P
Emission Unit Description: Non-Production Heating Unit
Raw Material/Fuel: Propane (LPG) or Natural Gas
Rated Capacity: 6.33 MMBtu/hr.
Emission Limits (lb./hr. gr./dscf. lb./MMBtu. % opacity, etc.):
The emissions from this emission point shall not exceed the following specified levels.
Pollutant: Opacity
Emission Limit(s): 40 %
Authority for Requirement: 567 IAC 23.3(2)"d"
Pollutant: Particulate Matter (TSP)
Emission Limit(s): 15.3 lb./MMCF of LPG or Natural Gas
Authority for Requirement: Part 7a. of State of Iowa, ex rel., Iowa DNR vs. Vermeer
Manufacturing Company, 99AG23542
District Court, Marion County, Law No. LACV087889
Pollutant: Particulate Matter (TSP)
Emission Limits: 0.8 lb./MMBtu
Authority for Requirement: 567 IAC 23.3(2)"b"
Pollutant: Sulfur Dioxide (SO2)
Emission Limits: 500 ppmv
Authority for Requirement: 567 IAC 23.3(3)"e"
Pollutant: Nitrogen Oxides (NOx)
Emission Limit(s): See Facility-Wide Conditions
Authority for Requirement: Iowa DNR Construction Permit 98-A-003-S1
Pollutant: Volatile Organic Compounds (VOC)
Emission Limit: See Facility-Wide Conditions
Authority for Requirement: Iowa DNR Construction Permit 98-A-003-S1
112
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Operational Limits & Requirements:
The owner/operator of this equipment shall comply with the following operational limits
and requirements.
Process throughput:
A. The sulfur content of natural gas or LPG combusted by this source is not to
exceed 123 ppm by weight.
Reporting & Recordkeeping: See Facility-Wide Operational Limits
Authority for Requirement: Part 7b. of State of Iowa, ex rel., Iowa DNR vs. Vermeer
Manufacturing Company, 99AG23542
District Court, Marion County, Law No. LACV087889
Compliance Plan:
The owner/operator of this equipment shall comply with the following applicable
requirements.
This point is in compliance with all applicable requirements and shall continue to comply
with all such requirements. For those applicable requirements which will become
effective during the permit term, this source will comply with such requirements in a
timely manner.
Periodic Monitoring Requirements:
The owner/operator of this equipment shall comply with the following periodic
monitoring requirements.
Agency Approved Operation & Maintenance Plan Required? Yes ~ No IXI
Facility Maintained Operation & Maintenance Plan Required? Yes ~ No Kl
Authority for Requirement: 567 IAC 22.108(3)"b"
113
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Emission Point ID Number: 2.PLASMA1
Associated Equipment
Associated Emission Unit ID Numbers (if multiple units vent thru this EP): 2.PLASMA1
Applicable Requirements
(If more than one emission unit vents through this emission point subdivide the applicable requirements by emission
unit.)
Emission Unit vented through this Emission Point: 2.PLASMA1 (Fugitive)
Emission Unit Description: Single Head Plasma Cutting
Machine
Raw Material/Fuel: Sheet Steel
Rated Capacity: 4,500 inches of metal cut/hr.
Emission Limits (lb./hr. gr./dscf. lb./MMBtu. % opacity, etc.):
The emissions from this emission point shall not exceed the following specified levels.
Pollutant: Fugitive Dust
Emission Limit: No person shall allow, cause or permit any materials to be handled,
transported or stored; or a building, its appurtenances or a construction haul road to
be used, constructed, altered , repaired or demolished, without taking reasonable
precautions to prevent a nuisance. All persons shall take reasonable precautions to
prevent the discharge of visible emissions of fugitive dusts beyond the lot line of the
property on which the emissions originate.
Authority for Requirement: 567 IAC 23.3(2)"c"
Compliance Plan:
The owner/operator of this equipment shall comply with the following applicable
requirements.
This point is in compliance with all applicable requirements and shall continue to comply
with all such requirements. For those applicable requirements which will become
effective during the permit term, this source will comply with such requirements in a
timely manner.
Periodic Monitoring Requirements:
The owner/operator of this equipment shall comply with the following periodic
monitoring requirements.
Agency Approved Operation & Maintenance Plan Required? Yes ~ No IXI
Facility Maintained Operation & Maintenance Plan Required? Yes ~ No Kl
Authority for Requirement: 567 IAC 22.108(3)"b"
114
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Emission Point ID Number: 2.PLASMA2
Associated Equipment
Associated Emission Unit ID Numbers (if multiple units vent thru this EP): 2.PLASMA2
Applicable Requirements
(If more than one emission unit vents through this emission point subdivide the applicable requirements by emission
unit.)
Emission Unit vented through this Emission Point: 2.PLASMA2 (Fugitive)
Emission Unit Description: Single Head Plasma Cutting
Machine
Raw Material/Fuel: Sheet Steel
Rated Capacity: 4,500 inches of metal cut/hr.
Emission Limits (lb./hr. gr./dscf. lb./MMBtu. % opacity, etc.):
The emissions from this emission point shall not exceed the following specified levels.
Pollutant: Fugitive Dust
Emission Limit: No person shall allow, cause or permit any materials to be handled,
transported or stored; or a building, its appurtenances or a construction haul road to
be used, constructed, altered , repaired or demolished, without taking reasonable
precautions to prevent a nuisance. All persons shall take reasonable precautions to
prevent the discharge of visible emissions of fugitive dusts beyond the lot line of the
property on which the emissions originate.
Authority for Requirement: 567 IAC 23.3(2)"c"
Compliance Plan:
The owner/operator of this equipment shall comply with the following applicable
requirements.
This point is in compliance with all applicable requirements and shall continue to comply
with all such requirements. For those applicable requirements which will become
effective during the permit term, this source will comply with such requirements in a
timely manner.
Periodic Monitoring Requirements:
The owner/operator of this equipment shall comply with the following periodic
monitoring requirements.
Agency Approved Operation & Maintenance Plan Required? Yes ~ No IXI
Facility Maintained Operation & Maintenance Plan Required? Yes ~ No Kl
Authority for Requirement: 567 IAC 22.108(3)"b"
115
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Emission Point ID Number: 2.PLASMA3
Associated Equipment
Associated Emission Unit ID Numbers (if multiple units vent thru this EP): 2.PLASMA3
Emissions Control Equipment ID Number: 2.PLASMA3
Emissions Control Equipment Description: Baghouse
Applicable Requirements
(If more than one emission unit vents through this emission point subdivide the applicable requirements by emission
unit.)
Emission Unit vented through this Emission Point: 2.PLASMA3 (Fugitive)
Emission Unit Description: Single Head Whitney Plasma Cutting
Machine
Raw Material/Fuel: Sheet Steel
Rated Capacity: 12,000 inches of metal cut/hr.
Emission Limits (lb./hr. gr./dscf. lb./MMBtu. % opacity, etc.):
The emissions from this emission point shall not exceed the following specified levels.
Pollutant: Fugitive Dust
Emission Limit: No person shall allow, cause or permit any materials to be handled,
transported or stored; or a building, its appurtenances or a construction haul road to
be used, constructed, altered , repaired or demolished, without taking reasonable
precautions to prevent a nuisance. All persons shall take reasonable precautions to
prevent the discharge of visible emissions of fugitive dusts beyond the lot line of the
property on which the emissions originate.
Authority for Requirement: 567 IAC 23.3(2)"c"
Compliance Plan:
The owner/operator of this equipment shall comply with the following applicable
requirements.
This point is in compliance with all applicable requirements and shall continue to comply
with all such requirements. For those applicable requirements which will become
effective during the permit term, this source will comply with such requirements in a
timely manner.
Periodic Monitoring Requirements:
The owner/operator of this equipment shall comply with the following periodic
monitoring requirements.
Agency Approved Operation & Maintenance Plan Required? Yes ~ No Kl
Facility Maintained Operation & Maintenance Plan Required? Yes ~ No Kl
Authority for Requirement: 567 IAC 22.108(3)"b"
116
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Emission Point ID Number: 2.PLASMA4
Associated Equipment
Associated Emission Unit ID Numbers (if multiple units vent thru this EP): 2.PLASMA4
Emissions Control Equipment ID Number: 2.PLASMA4
Emissions Control Equipment Description: Baghouse
Applicable Requirements
(If more than one emission unit vents through this emission point subdivide the applicable requirements by emission
unit.)
Emission Unit vented through this Emission Point: 2.PLASMA4 (Fugitive)
Emission Unit Description: Single Head Whitney Plasma Cutting
Machine
Raw Material/Fuel: Sheet Steel
Rated Capacity: 12,000 inches of metal cut/hr.
Emission Limits (lb./hr. gr./dscf. lb./MMBtu. % opacity, etc.):
The emissions from this emission point shall not exceed the following specified levels.
Pollutant: Fugitive Dust
Emission Limit: No person shall allow, cause or permit any materials to be handled,
transported or stored; or a building, its appurtenances or a construction haul road to
be used, constructed, altered , repaired or demolished, without taking reasonable
precautions to prevent a nuisance. All persons shall take reasonable precautions to
prevent the discharge of visible emissions of fugitive dusts beyond the lot line of the
property on which the emissions originate.
Authority for Requirement: 567 IAC 23.3(2)"c"
Compliance Plan:
The owner/operator of this equipment shall comply with the following applicable
requirements.
This point is in compliance with all applicable requirements and shall continue to comply
with all such requirements. For those applicable requirements which will become
effective during the permit term, this source will comply with such requirements in a
timely manner.
Periodic Monitoring Requirements:
The owner/operator of this equipment shall comply with the following periodic
monitoring requirements.
Agency Approved Operation & Maintenance Plan Required? Yes ~ No Kl
Facility Maintained Operation & Maintenance Plan Required? Yes ~ No Kl
Authority for Requirement: 567 IAC 22.108(3)"b"
117
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Emission Point ID Number: 2.PLASMA5
Associated Equipment
Associated Emission Unit ID Numbers (if multiple units vent thru this EP): 2.PLASMA5
Emissions Control Equipment ID Number: 2.PLASMA5
Emissions Control Equipment Description: Baghouse
Applicable Requirements
(If more than one emission unit vents through this emission point subdivide the applicable requirements by emission
unit.)
Emission Unit vented through this Emission Point: 2.PLASMA5 (Fugitive)
Emission Unit Description: Single Head Whitney Plasma Cutting
Machine
Raw Material/Fuel: Sheet Steel
Rated Capacity: 12,000 inches of metal cut/hr.
Emission Limits (lb./hr. gr./dscf. lb./MMBtu. % opacity, etc.):
The emissions from this emission point shall not exceed the following specified levels.
Pollutant: Fugitive Dust
Emission Limit: No person shall allow, cause or permit any materials to be handled,
transported or stored; or a building, its appurtenances or a construction haul road to
be used, constructed, altered , repaired or demolished, without taking reasonable
precautions to prevent a nuisance. All persons shall take reasonable precautions to
prevent the discharge of visible emissions of fugitive dusts beyond the lot line of the
property on which the emissions originate.
Authority for Requirement: 567 IAC 23.3(2)"c"
Compliance Plan:
The owner/operator of this equipment shall comply with the following applicable
requirements.
This point is in compliance with all applicable requirements and shall continue to comply
with all such requirements. For those applicable requirements which will become
effective during the permit term, this source will comply with such requirements in a
timely manner.
Periodic Monitoring Requirements:
The owner/operator of this equipment shall comply with the following periodic
monitoring requirements.
Agency Approved Operation & Maintenance Plan Required? Yes ~ No Kl
Facility Maintained Operation & Maintenance Plan Required? Yes ~ No Kl
Authority for Requirement: 567 IAC 22.108(3)"b"
118
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Emission Point ID Number: 2.PRTWSH
Associated Equipment
Associated Emission Unit ID Numbers (if multiple units vent thru this EP): 2.PRTWSH
Applicable Requirements
(If more than one emission unit vents through this emission point subdivide the applicable requirements by emission
unit.)
Emission Unit vented through this Emission Point: 2.PRTWSH (Fugitive)
Emission Unit Description: Four (4) Safety Kleen Parts Washers
Raw Material/Fuel: Stoddard Solvent
Rated Capacity: 55 Gallons Solvent per Washer
Emission Limits (lb./hr. gr./dscf. lb./MMBtu. % opacity, etc.):
The emissions from this emission point shall not exceed the following specified levels.
Pollutant: Volatile Organic Compounds (VOC)
Emission Limit: See Facility-Wide Conditions
Authority for Requirement: Iowa DNR Construction Permit 98-A-003-S1
Compliance Plan:
The owner/operator of this equipment shall comply with the following applicable
requirements.
This point is in compliance with all applicable requirements and shall continue to comply
with all such requirements. For those applicable requirements which will become
effective during the permit term, this source will comply with such requirements in a
timely manner.
Periodic Monitoring Requirements:
The owner/operator of this equipment shall comply with the following periodic
monitoring requirements.
Agency Approved Operation & Maintenance Plan Required? Yes ~ No Kl
Facility Maintained Operation & Maintenance Plan Required? Yes ~ No Kl
Authority for Requirement: 567 IAC 22.108(3)"b"
119
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Emission Point ID Number: 2.Q
Associated Equipment
Associated Emission Unit ID Numbers (if multiple units vent thru this EP): 2.Q
Applicable Requirements
(If more than one emission unit vents through this emission point subdivide the applicable requirements by emission
unit.)
Emission Unit vented through this Emission Point: 2.Q
Emission Unit Description: Hot Water Heater
Raw Material/Fuel: Propane (LPG) or Natural Gas
Rated Capacity: 0.528 MMBtu/hr.
Emission Limits (lb./hr. gr./dscf. lb./MMBtu. % opacity, etc.):
The emissions from this emission point shall not exceed the following specified levels.
Pollutant: Opacity
Emission Limit(s): 40 %
Authority for Requirement: 567 IAC 23.3(2)"d"
Pollutant: Particulate Matter (TSP)
Emission Limit(s): 15.3 lb./MMCF of LPG or Natural Gas
Authority for Requirement: Part 7a. of State of Iowa, ex rel., Iowa DNR vs. Vermeer
Manufacturing Company, 99AG23542
District Court, Marion County, Law No. LACV087889
Pollutant: Particulate Matter (TSP)
Emission Limits: 0.8 lb./MMBtu
Authority for Requirement: 567 IAC 23.3(2)"b"
Pollutant: Sulfur Dioxide (SO2)
Emission Limits: 500 ppmv
Authority for Requirement: 567 IAC 23.3(3)"e"
Pollutant: Nitrogen Oxides (NOx)
Emission Limit(s): See Facility-Wide Conditions
Authority for Requirement: Iowa DNR Construction Permit 98-A-003-S1
Pollutant: Volatile Organic Compounds (VOC)
Emission Limit: See Facility-Wide Conditions
Authority for Requirement: Iowa DNR Construction Permit 98-A-003-S1
120
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Operational Limits & Requirements:
The owner/operator of this equipment shall comply with the following operational limits
and requirements.
Process throughput:
A. The sulfur content of natural gas or LPG combusted by this source is not to
exceed 123 ppm by weight.
Reporting & Recordkeeping: See Facility-Wide Operational Limits
Authority for Requirement: Part 7b. of State of Iowa, ex rel., Iowa DNR vs. Vermeer
Manufacturing Company, 99AG23542
District Court, Marion County, Law No. LACV087889
Compliance Plan:
The owner/operator of this equipment shall comply with the following applicable
requirements.
This point is in compliance with all applicable requirements and shall continue to comply
with all such requirements. For those applicable requirements which will become
effective during the permit term, this source will comply with such requirements in a
timely manner.
Periodic Monitoring Requirements:
The owner/operator of this equipment shall comply with the following periodic
monitoring requirements.
Agency Approved Operation & Maintenance Plan Required? Yes ~ No IXI
Facility Maintained Operation & Maintenance Plan Required? Yes ~ No Kl
Authority for Requirement: 567 IAC 22.108(3)"b"
121
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Emission Point ID Number: 2.T
Associated Equipment
Associated Emission Unit ID Numbers (if multiple units vent thru this EP): 2.T
Applicable Requirements
(If more than one emission unit vents through this emission point subdivide the applicable requirements by emission
unit.)
Emission Unit vented through this Emission Point: 2.T
Emission Unit Description: Non-Production Heating Unit
Raw Material/Fuel: Propane (LPG) or Natural Gas
Rated Capacity: 8.0 MMBtu/hr.
Emission Limits (lb./hr. gr./dscf. lb./MMBtu. % opacity, etc.):
The emissions from this emission point shall not exceed the following specified levels.
Pollutant: Opacity
Emission Limit(s): 40 %
Authority for Requirement: 567 IAC 23.3(2)"d"
Pollutant: Particulate Matter (TSP)
Emission Limit(s): 15.3 lb./MMCF of LPG or Natural Gas
Authority for Requirement: Part 7a. of State of Iowa, ex rel., Iowa DNR vs. Vermeer
Manufacturing Company, 99AG23542
District Court, Marion County, Law No. LACV087889
Pollutant: Particulate Matter (TSP)
Emission Limits: 0.8 lb./MMBtu
Authority for Requirement: 567 IAC 23.3(2)"b"
Pollutant: Sulfur Dioxide (SO2)
Emission Limits: 500 ppmv
Authority for Requirement: 567 IAC 23.3(3)"e"
Pollutant: Nitrogen Oxides (NOx)
Emission Limit(s): See Facility-Wide Conditions
Authority for Requirement: Iowa DNR Construction Permit 98-A-003-S1
Pollutant: Volatile Organic Compounds (VOC)
Emission Limit: See Facility-Wide Conditions
Authority for Requirement: Iowa DNR Construction Permit 98-A-003-S1
122
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Operational Limits & Requirements:
The owner/operator of this equipment shall comply with the following operational limits
and requirements.
Process throughput:
A. The sulfur content of natural gas or LPG combusted by this source is not to
exceed 123 ppm by weight.
Reporting & Recordkeeping: See Facility-Wide Operational Limits
Authority for Requirement: Part 7b. of State of Iowa, ex rel., Iowa DNR vs. Vermeer
Manufacturing Company, 99AG23542
District Court, Marion County, Law No. LACV087889
Compliance Plan:
The owner/operator of this equipment shall comply with the following applicable
requirements.
This point is in compliance with all applicable requirements and shall continue to comply
with all such requirements. For those applicable requirements which will become
effective during the permit term, this source will comply with such requirements in a
timely manner.
Periodic Monitoring Requirements:
The owner/operator of this equipment shall comply with the following periodic
monitoring requirements.
Agency Approved Operation & Maintenance Plan Required? Yes ~ No IXI
Facility Maintained Operation & Maintenance Plan Required? Yes ~ No Kl
Authority for Requirement: 567 IAC 22.108(3)"b"
123
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Emission Point ID Number: 2.TORCH
Associated Equipment
Associated Emission Unit ID Numbers (if multiple units vent thru this EP): 2.TORCH
Applicable Requirements
(If more than one emission unit vents through this emission point subdivide the applicable requirements by emission
unit.)
Emission Unit vented through this Emission Point: 2.TORCH (Fugitive)
Emission Unit Description: Nine (9) Single Cutting Head
Oxyacetylene Torch Units
Raw Material/Fuel: Sheet Steel
Rated Capacity: 840 inches of metal cut/hr. per Head
Emission Limits (lb./hr. gr./dscf. lb./MMBtu. % opacity, etc.):
The emissions from this emission point shall not exceed the following specified levels.
Pollutant: Fugitive Dust
Emission Limit: No person shall allow, cause or permit any materials to be handled,
transported or stored; or a building, its appurtenances or a construction haul road to
be used, constructed, altered , repaired or demolished, without taking reasonable
precautions to prevent a nuisance. All persons shall take reasonable precautions to
prevent the discharge of visible emissions of fugitive dusts beyond the lot line of the
property on which the emissions originate.
Authority for Requirement: 567 IAC 23.3(2)"c"
Compliance Plan:
The owner/operator of this equipment shall comply with the following applicable
requirements.
This point is in compliance with all applicable requirements and shall continue to comply
with all such requirements. For those applicable requirements which will become
effective during the permit term, this source will comply with such requirements in a
timely manner.
Periodic Monitoring Requirements:
The owner/operator of this equipment shall comply with the following periodic
monitoring requirements.
Agency Approved Operation & Maintenance Plan Required? Yes ~ No IXI
Facility Maintained Operation & Maintenance Plan Required? Yes ~ No Kl
Authority for Requirement: 567 IAC 22.108(3)"b"
124
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Emission Point ID Number: 2.VI
Associated Equipment
Associated Emission Unit ID Numbers (if multiple units vent thru this EP): 2. VI
Applicable Requirements
(If more than one emission unit vents through this emission point subdivide the applicable requirements by emission
unit.)
Emission Unit vented through this Emission Point: 2.VI
Emission Unit Description: Non-Production Heating Unit
Raw Material/Fuel: Propane (LPG) or Natural Gas
Rated Capacity: 0.18 MMBtu/hr.
Emission Limits (lb./hr. gr./dscf. lb./MMBtu. % opacity, etc.):
The emissions from this emission point shall not exceed the following specified levels.
Pollutant: Opacity
Emission Limit(s): 40 %
Authority for Requirement: 567 IAC 23.3(2)"d"
Pollutant: Particulate Matter (TSP)
Emission Limit(s): 15.3 lb./MMCF of LPG or Natural Gas
Authority for Requirement: Part 7a. of State of Iowa, ex rel., Iowa DNR vs. Vermeer
Manufacturing Company, 99AG23542
District Court, Marion County, Law No. LACV087889
Pollutant: Particulate Matter (TSP)
Emission Limits: 0.8 lb./MMBtu
Authority for Requirement: 567 IAC 23.3(2)"b"
Pollutant: Sulfur Dioxide (SO2)
Emission Limits: 500 ppmv
Authority for Requirement: 567 IAC 23.3(3)"e"
Pollutant: Nitrogen Oxides (NOx)
Emission Limit(s): See Facility-Wide Conditions
Authority for Requirement: Iowa DNR Construction Permit 98-A-003-S1
Pollutant: Volatile Organic Compounds (VOC)
Emission Limit: See Facility-Wide Conditions
Authority for Requirement: Iowa DNR Construction Permit 98-A-003-S1
125
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Operational Limits & Requirements:
The owner/operator of this equipment shall comply with the following operational limits
and requirements.
Process throughput:
A. The sulfur content of natural gas or LPG combusted by this source is not to
exceed 123 ppm by weight.
Reporting & Recordkeeping: See Facility-Wide Operational Limits
Authority for Requirement: Part 7b. of State of Iowa, ex rel., Iowa DNR vs. Vermeer
Manufacturing Company, 99AG23542
District Court, Marion County, Law No. LACV087889
Compliance Plan:
The owner/operator of this equipment shall comply with the following applicable
requirements.
This point is in compliance with all applicable requirements and shall continue to comply
with all such requirements. For those applicable requirements which will become
effective during the permit term, this source will comply with such requirements in a
timely manner.
Periodic Monitoring Requirements:
The owner/operator of this equipment shall comply with the following periodic
monitoring requirements.
Agency Approved Operation & Maintenance Plan Required? Yes ~ No IXI
Facility Maintained Operation & Maintenance Plan Required? Yes ~ No Kl
Authority for Requirement: 567 IAC 22.108(3)"b"
126
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Emission Point ID Number: 2.V2
Associated Equipment
Associated Emission Unit ID Numbers (if multiple units vent thru this EP): 2. V2
Applicable Requirements
(If more than one emission unit vents through this emission point subdivide the applicable requirements by emission
unit.)
Emission Unit vented through this Emission Point: 2.V2
Emission Unit Description: Non-Production Heating Unit
Raw Material/Fuel: Propane (LPG) or Natural Gas
Rated Capacity: 0.18 MMBtu/hr.
Emission Limits (lb./hr. gr./dscf. lb./MMBtu. % opacity, etc.):
The emissions from this emission point shall not exceed the following specified levels.
Pollutant: Opacity
Emission Limit(s): 40 %
Authority for Requirement: 567 IAC 23.3(2)"d"
Pollutant: Particulate Matter (TSP)
Emission Limit(s): 15.3 lb./MMCF of LPG or Natural Gas
Authority for Requirement: Part 7a. of State of Iowa, ex rel., Iowa DNR vs. Vermeer
Manufacturing Company, 99AG23542
District Court, Marion County, Law No. LACV087889
Pollutant: Particulate Matter (TSP)
Emission Limits: 0.8 lb./MMBtu
Authority for Requirement: 567 IAC 23.3(2)"b"
Pollutant: Sulfur Dioxide (SO2)
Emission Limits: 500 ppmv
Authority for Requirement: 567 IAC 23.3(3)"e"
Pollutant: Nitrogen Oxides (NOx)
Emission Limit(s): See Facility-Wide Conditions
Authority for Requirement: Iowa DNR Construction Permit 98-A-003-S1
Pollutant: Volatile Organic Compounds (VOC)
Emission Limit: See Facility-Wide Conditions
Authority for Requirement: Iowa DNR Construction Permit 98-A-003-S1
127
-------
Operational Limits & Requirements:
The owner/operator of this equipment shall comply with the following operational limits
and requirements.
Process throughput:
A. The sulfur content of natural gas or LPG combusted by this source is not to
exceed 123 ppm by weight.
Reporting & Recordkeeping: See Facility-Wide Operational Limits
Authority for Requirement: Part 7b. of State of Iowa, ex rel., Iowa DNR vs. Vermeer
Manufacturing Company, 99AG23542
District Court, Marion County, Law No. LACV087889
Compliance Plan:
The owner/operator of this equipment shall comply with the following applicable
requirements.
This point is in compliance with all applicable requirements and shall continue to comply
with all such requirements. For those applicable requirements which will become
effective during the permit term, this source will comply with such requirements in a
timely manner.
Periodic Monitoring Requirements:
The owner/operator of this equipment shall comply with the following periodic
monitoring requirements.
Agency Approved Operation & Maintenance Plan Required? Yes ~ No IXI
Facility Maintained Operation & Maintenance Plan Required? Yes ~ No Kl
Authority for Requirement: 567 IAC 22.108(3)"b"
128
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Emission Point ID Number: 2.WELDING
Associated Equipment
Associated Emission Unit ID Numbers (if multiple units vent thru this EP): 2. WELDING
Applicable Requirements
(If more than one emission unit vents through this emission point subdivide the applicable requirements by emission
unit.)
Emission Unit vented through this Emission Point: 2.WELDING (Fugitive)
Emission Unit Description: 45 GMAW Units
Raw Material/Fuel: E70S Weld Wire
Rated Capacity: 19 lb. ofWire/hr. per Unit
Emission Limits (lb./hr. gr./dscf. lb./MMBtu. % opacity, etc.):
The emissions from this emission point shall not exceed the following specified levels.
Pollutant: Fugitive Dust
Emission Limit: No person shall allow, cause or permit any materials to be handled,
transported or stored; or a building, its appurtenances or a construction haul road to
be used, constructed, altered , repaired or demolished, without taking reasonable
precautions to prevent a nuisance. All persons shall take reasonable precautions to
prevent the discharge of visible emissions of fugitive dusts beyond the lot line of the
property on which the emissions originate.
Authority for Requirement: 567 IAC 23.3(2)"c"
Compliance Plan:
The owner/operator of this equipment shall comply with the following applicable
requirements.
This point is in compliance with all applicable requirements and shall continue to comply
with all such requirements. For those applicable requirements which will become
effective during the permit term, this source will comply with such requirements in a
timely manner.
Periodic Monitoring Requirements:
The owner/operator of this equipment shall comply with the following periodic
monitoring requirements.
Agency Approved Operation & Maintenance Plan Required? Yes ~ No Kl
Facility Maintained Operation & Maintenance Plan Required? Yes ~ No Kl
Authority for Requirement: 567 IAC 22.108(3)"b"
129
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Emission Point ID Number: 2.WELDPLS
Associated Equipment
Associated Emission Unit ID Numbers (if multiple units vent thru this EP): 2. WELDPLS
Applicable Requirements
(If more than one emission unit vents through this emission point subdivide the applicable requirements by emission
unit.)
Emission Unit vented through this Emission Point: 2.WELDPLS (Fugitive)
Emission Unit Description: 8 Pulse Current GMAW Units
Raw Material/Fuel: E70S Weld Wire
Rated Capacity: 19 lb. ofWire/hr. per Unit
Emission Limits (lb./hr. gr./dscf. lb./MMBtu. % opacity, etc.):
The emissions from this emission point shall not exceed the following specified levels.
Pollutant: Fugitive Dust
Emission Limit: No person shall allow, cause or permit any materials to be handled,
transported or stored; or a building, its appurtenances or a construction haul road to
be used, constructed, altered , repaired or demolished, without taking reasonable
precautions to prevent a nuisance. All persons shall take reasonable precautions to
prevent the discharge of visible emissions of fugitive dusts beyond the lot line of the
property on which the emissions originate.
Authority for Requirement: 567 IAC 23.3(2)"c"
Compliance Plan:
The owner/operator of this equipment shall comply with the following applicable
requirements.
This point is in compliance with all applicable requirements and shall continue to comply
with all such requirements. For those applicable requirements which will become
effective during the permit term, this source will comply with such requirements in a
timely manner.
Periodic Monitoring Requirements:
The owner/operator of this equipment shall comply with the following periodic
monitoring requirements.
Agency Approved Operation & Maintenance Plan Required? Yes ~ No Kl
Facility Maintained Operation & Maintenance Plan Required? Yes ~ No Kl
Authority for Requirement: 567 IAC 22.108(3)"b"
130
-------
Emission Point ID Number: 2.X
Associated Equipment
Associated Emission Unit ID Numbers (if multiple units vent thru this EP): 2.X
Applicable Requirements
(If more than one emission unit vents through this emission point subdivide the applicable requirements by emission
unit.)
Emission Unit vented through this Emission Point: 2.X
Emission Unit Description: Non-Production Heating Unit
Raw Material/Fuel: Propane (LPG) or Natural Gas
Rated Capacity: 0.10 MMBtu/hr.
Emission Limits (lb./hr. gr./dscf. lb./MMBtu. % opacity, etc.):
The emissions from this emission point shall not exceed the following specified levels.
Pollutant: Opacity
Emission Limit(s): 40 %
Authority for Requirement: 567 IAC 23.3(2)"d"
Pollutant: Particulate Matter (TSP)
Emission Limit(s): 15.3 lb./MMCF of LPG or Natural Gas
Authority for Requirement: Part 7a. of State of Iowa, ex rel., Iowa DNR vs. Vermeer
Manufacturing Company, 99AG23542
District Court, Marion County, Law No. LACV087889
Pollutant: Particulate Matter (TSP)
Emission Limits: 0.8 lb./MMBtu
Authority for Requirement: 567 IAC 23.3(2)"b"
Pollutant: Sulfur Dioxide (SO2)
Emission Limits: 500 ppmv
Authority for Requirement: 567 IAC 23.3(3)"e"
Pollutant: Nitrogen Oxides (NOx)
Emission Limit(s): See Facility-Wide Conditions
Authority for Requirement: Iowa DNR Construction Permit 98-A-003-S1
Pollutant: Volatile Organic Compounds (VOC)
Emission Limit: See Facility-Wide Conditions
Authority for Requirement: Iowa DNR Construction Permit 98-A-003-S1
131
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Operational Limits & Requirements:
The owner/operator of this equipment shall comply with the following operational limits
and requirements.
Process throughput:
A. The sulfur content of natural gas or LPG combusted by this source is not to
exceed 123 ppm by weight.
Reporting & Recordkeeping: See Facility-Wide Operational Limits
Authority for Requirement: Part 7b. of State of Iowa, ex rel., Iowa DNR vs. Vermeer
Manufacturing Company, 99AG23542
District Court, Marion County, Law No. LACV087889
Compliance Plan:
The owner/operator of this equipment shall comply with the following applicable
requirements.
This point is in compliance with all applicable requirements and shall continue to comply
with all such requirements. For those applicable requirements which will become
effective during the permit term, this source will comply with such requirements in a
timely manner.
Periodic Monitoring Requirements:
The owner/operator of this equipment shall comply with the following periodic
monitoring requirements.
Agency Approved Operation & Maintenance Plan Required? Yes ~ No IXI
Facility Maintained Operation & Maintenance Plan Required? Yes ~ No Kl
Authority for Requirement: 567 IAC 22.108(3)"b"
132
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Emission Point ID Number: 2.Y1
Associated Equipment
Associated Emission Unit ID Numbers (if multiple units vent thru this EP): 2. Y1
Applicable Requirements
(If more than one emission unit vents through this emission point subdivide the applicable requirements by emission
unit.)
Emission Unit vented through this Emission Point: 2.Y1
Emission Unit Description: Non-Production Heating Unit
Raw Material/Fuel: Propane (LPG) or Natural Gas
Rated Capacity: 0.15 MMBtu/hr.
Emission Limits (lb./hr. gr./dscf. lb./MMBtu. % opacity, etc.):
The emissions from this emission point shall not exceed the following specified levels.
Pollutant: Opacity
Emission Limit(s): 40 %
Authority for Requirement: 567 IAC 23.3(2)"d"
Pollutant: Particulate Matter (TSP)
Emission Limit(s): 15.3 lb./MMCF of LPG or Natural Gas
Authority for Requirement: Part 7a. of State of Iowa, ex rel., Iowa DNR vs. Vermeer
Manufacturing Company, 99AG23542
District Court, Marion County, Law No. LACV087889
Pollutant: Particulate Matter (TSP)
Emission Limits: 0.8 lb./MMBtu
Authority for Requirement: 567 IAC 23.3(2)"b"
Pollutant: Sulfur Dioxide (SO2)
Emission Limits: 500 ppmv
Authority for Requirement: 567 IAC 23.3(3)"e"
Pollutant: Nitrogen Oxides (NOx)
Emission Limit(s): See Facility-Wide Conditions
Authority for Requirement: Iowa DNR Construction Permit 98-A-003-S1
Pollutant: Volatile Organic Compounds (VOC)
Emission Limit: See Facility-Wide Conditions
Authority for Requirement: Iowa DNR Construction Permit 98-A-003-S1
133
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Operational Limits & Requirements:
The owner/operator of this equipment shall comply with the following operational limits
and requirements.
Process throughput:
A. The sulfur content of natural gas or LPG combusted by this source is not to
exceed 123 ppm by weight.
Reporting & Recordkeeping: See Facility-Wide Operational Limits
Authority for Requirement: Part 7b. of State of Iowa, ex rel., Iowa DNR vs. Vermeer
Manufacturing Company, 99AG23542
District Court, Marion County, Law No. LACV087889
Compliance Plan:
The owner/operator of this equipment shall comply with the following applicable
requirements.
This point is in compliance with all applicable requirements and shall continue to comply
with all such requirements. For those applicable requirements which will become
effective during the permit term, this source will comply with such requirements in a
timely manner.
Periodic Monitoring Requirements:
The owner/operator of this equipment shall comply with the following periodic
monitoring requirements.
Agency Approved Operation & Maintenance Plan Required? Yes ~ No IXI
Facility Maintained Operation & Maintenance Plan Required? Yes ~ No Kl
Authority for Requirement: 567 IAC 22.108(3)"b"
134
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Emission Point ID Number: 3.A1
Associated Equipment
Associated Emission Unit ID Numbers (if multiple units vent thru this EP): 3. A1
Applicable Requirements
(If more than one emission unit vents through this emission point subdivide the applicable requirements by emission
unit.)
Emission Unit vented through this Emission Point: 3.A1
Emission Unit Description: Production Engine Testing Unit
Raw Material/Fuel: #2 Diesel Fuel and Gasoline
Rated Capacity: 54.5 gal./hr.
Emission Limits (lb./hr. gr./dscf. lb./MMBtu. % opacity, etc.):
The emissions from this emission point shall not exceed the following specified levels.
Pollutant: Opacity
Emission Limits: 40%
Indicator Opacity: 25%(1)
(1) If visible emissions are observed that exceed the indicator opacity other than startup,
shutdown or malfunction, a stack test may be required to demonstrate compliance with
the particulate standard.
Authority for Requirement: Iowa DNR Construction Permit 97-A-l 100-S2
567 IAC 23.3(2)"d"
Pollutant: Particulate Matter (TSP)
Emission Limits: 0.1 gr./dscf
Authority for Requirement: Iowa DNR Construction Permit 97-A-l 100-S2
567 IAC 23.3(2)"a"
Pollutant: Sulfur Dioxide (SO2)
Emission Limits: 2.5 lb./MMBtu
Authority for Requirement: Iowa DNR Construction Permit 97-A-l 100-S2
567 IAC 23.3(3)"b"
Pollutant: Nitrogen Oxides (NOx)
Emission Limit(s): See Facility-Wide Conditions
Authority for Requirement: Iowa DNR Construction Permit 97-A-l 100-S2
Pollutant: Volatile Organic Compounds (VOC)
Emission Limit: See Facility-Wide Conditions
Authority for Requirement: Iowa DNR Construction Permit 97-A-l 100-S2
135
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Operational Limits & Requirements:
The owner/operator of this equipment shall comply with the following operational limits
and requirements.
Process Throughput:
A. The sulfur content of any diesel fuel used in this source shall not exceed 0.4% by
weight.
Reporting & Recordkeeping: See Facility-Wide Emission and Operational Limits
Authority for Requirement: Iowa DNR Construction Permit 97-A-l 100-S2
Compliance Plan:
The owner/operator of this equipment shall comply with the following applicable
requirements.
This point is in compliance with all applicable requirements and shall continue to comply
with all such requirements. For those applicable requirements which will become
effective during the permit term, this source will comply with such requirements in a
timely manner.
Additional Requirements:
This emission point shall conform to the following conditions.
The source is to be connected to the stack of the following detailed description.
Stack Height (feet): 27
Stack Diameter (inches): 12
Stack Exhaust Flow Rate (acfm): .... 6210
Stack Temperature (°F): 759
Vertical, Unobstructed Discharge Required: Yes ^ No ~
Authority for Requirement: Iowa DNR Construction Permit 97-A-l 100-S2
Periodic Monitoring Requirements:
The owner/operator of this equipment shall comply with the following periodic
monitoring requirements.
Opacity Monitoring:
The facility shall observe the opacity weekly during a period when the emission unit
associated with this emission point is at or near full capacity and record the reading
indicating if visible emissions were observed. The records shall be maintained for five
years. If weather conditions prevent the observer from conducting an opacity
observation, the observer shall note such conditions on the data observation sheet. At
least three attempts shall be made to retake opacity readings at approximately 2-hour
intervals throughout the day. If all observation attempts for a week have been
unsuccessful due to weather, an observation shall be made the next operating day where
weather permits.
Maintain a written record of the observation and any action resulting from the
observation.
136
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Agency Approved Operation & Maintenance Plan Required? Yes ~ No Kl
Facility Maintained Operation & Maintenance Plan Required? Yes ~ No Kl
Authority for Requirement: 567 IAC 22.108(3)"b"
137
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Emission Point ID Number: 3.A2
Associated Equipment
Associated Emission Unit ID Numbers (if multiple units vent thru this EP): 3. A2
Applicable Requirements
(If more than one emission unit vents through this emission point subdivide the applicable requirements by emission
unit.)
Emission Unit vented through this Emission Point: 3.A2
Emission Unit Description: Production Engine Testing Unit
Raw Material/Fuel: #2 Diesel Fuel and Gasoline
Rated Capacity: 54.5 gal./hr.
Emission Limits (lb./hr. gr./dscf. lb./MMBtu. % opacity, etc.):
The emissions from this emission point shall not exceed the following specified levels.
Pollutant: Opacity
Emission Limits: 40%
Indicator Opacity: 25%(1)
(1) If visible emissions are observed that exceed the indicator opacity other than startup,
shutdown or malfunction, a stack test may be required to demonstrate compliance with
the particulate standard.
Authority for Requirement: Iowa DNR Construction Permit 97-A-1101-S2
567 IAC 23.3(2)"d"
Pollutant: Particulate Matter (TSP)
Emission Limits: 0.1 gr./dscf
Authority for Requirement: Iowa DNR Construction Permit 97-A-1101-S2
567 IAC 23.3(2)"a"
Pollutant: Sulfur Dioxide (SO2)
Emission Limits: 2.5 lb./MMBtu
Authority for Requirement: Iowa DNR Construction Permit 97-A-1101-S2
567 IAC 23.3(3)"b"
Pollutant: Nitrogen Oxides (NOx)
Emission Limit(s): See Facility-Wide Conditions
Authority for Requirement: Iowa DNR Construction Permit 97-A-1101-S2
Pollutant: Volatile Organic Compounds (VOC)
Emission Limit: See Facility-Wide Conditions
Authority for Requirement: Iowa DNR Construction Permit 97-A-1101-S2
138
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Operational Limits & Requirements:
The owner/operator of this equipment shall comply with the following operational limits
and requirements.
Process Throughput:
A. The sulfur content of any diesel fuel used in this source shall not exceed 0.4% by
weight.
Reporting & Recordkeeping: See Facility-Wide Emission and Operational Limits
Authority for Requirement: Iowa DNR Construction Permit 97-A-1101-S2
Compliance Plan:
The owner/operator of this equipment shall comply with the following applicable
requirements.
This point is in compliance with all applicable requirements and shall continue to comply
with all such requirements. For those applicable requirements which will become
effective during the permit term, this source will comply with such requirements in a
timely manner.
Additional Requirements:
This emission point shall conform to the following conditions.
The source is to be connected to the stack of the following detailed description.
Stack Height (feet): 30
Stack Diameter (inches): 12
Stack Exhaust Flow Rate (acfm): .... 6210
Stack Temperature (°F): 759
Vertical, Unobstructed Discharge Required: Yes ^ No ~
Authority for Requirement: Iowa DNR Construction Permit 97-A-1101-S2
Periodic Monitoring Requirements:
The owner/operator of this equipment shall comply with the following periodic
monitoring requirements.
Opacity Monitoring:
The facility shall observe the opacity weekly during a period when the emission unit
associated with this emission point is at or near full capacity and record the reading
indicating if visible emissions were observed. The records shall be maintained for five
years. If weather conditions prevent the observer from conducting an opacity
observation, the observer shall note such conditions on the data observation sheet. At
least three attempts shall be made to retake opacity readings at approximately 2-hour
intervals throughout the day. If all observation attempts for a week have been
unsuccessful due to weather, an observation shall be made the next operating day where
weather permits.
Maintain a written record of the observation and any action resulting from the
observation.
139
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Agency Approved Operation & Maintenance Plan Required? Yes ~ No Kl
Facility Maintained Operation & Maintenance Plan Required? Yes ~ No Kl
Authority for Requirement: 567 IAC 22.108(3)"b"
140
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Emission Point ID Number: 3.AA
Associated Equipment
Associated Emission Unit ID Numbers (if multiple units vent thru this EP): 3. AA
Applicable Requirements
(If more than one emission unit vents through this emission point subdivide the applicable requirements by emission
unit.)
Emission Unit vented through this Emission Point: 3.AA
Emission Unit Description: Parts Heating Oven
Raw Material/Fuel: Natural Gas
Rated Capacity: 0.35 MMBtu/hr.
Emission Limits (lb./hr. gr./dscf. lb./MMBtu. % opacity, etc.):
The emissions from this emission point shall not exceed the following specified levels.
Pollutant: Opacity
Emission Limit(s): 40%
Authority for Requirement: 567 IAC 23.3(2)"d"
Pollutant: Particulate Matter (TSP)
Emission Limit(s): 15.3 lb./MMCF of LPG or Natural Gas
Authority for Requirement: Part 7a. of State of Iowa, ex rel., Iowa DNR vs. Vermeer
Manufacturing Company, 99AG23542
District Court, Marion County, Law No. LACV087889
Pollutant: Particulate Matter (TSP)
Emission Limits: 0.8 lb./MMBtu
Authority for Requirement: 567 IAC 23.3(2)"b"
Pollutant: Sulfur Dioxide (SO2)
Emission Limits: 500 ppmv
Authority for Requirement: 567 IAC 23.3(3)"e"
Pollutant: Nitrogen Oxides (NOx)
Emission Limit(s): See Facility-Wide Conditions
Authority for Requirement: Iowa DNR Construction Permit 98-A-094
Pollutant: Volatile Organic Compounds (VOC)
Emission Limit: See Facility-Wide Conditions
Authority for Requirement: Iowa DNR Construction Permit 98-A-094
141
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Operational Limits & Requirements:
The owner/operator of this equipment shall comply with the following operational limits
and requirements.
Process throughput:
A. The sulfur content of natural gas or LPG combusted by this source is not to
exceed 123 ppm by weight.
Reporting & Recordkeeping: See Facility-Wide Operational Limits
Authority for Requirement: Part 7b. of State of Iowa, ex rel., Iowa DNR vs. Vermeer
Manufacturing Company, 99AG23542
District Court, Marion County, Law No. LACV087889
Compliance Plan:
The owner/operator of this equipment shall comply with the following applicable
requirements.
This point is in compliance with all applicable requirements and shall continue to comply
with all such requirements. For those applicable requirements which will become
effective during the permit term, this source will comply with such requirements in a
timely manner.
Periodic Monitoring Requirements:
The owner/operator of this equipment shall comply with the following periodic
monitoring requirements.
Agency Approved Operation & Maintenance Plan Required? Yes ~ No IXI
Facility Maintained Operation & Maintenance Plan Required? Yes ~ No Kl
Authority for Requirement: 567 IAC 22.108(3)"b"
142
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Emission Point ID Number: 3.B
Associated Equipment
Associated Emission Unit ID Numbers (if multiple units vent thru this EP): 3 .B
Applicable Requirements
(If more than one emission unit vents through this emission point subdivide the applicable requirements by emission
unit.)
Emission Unit vented through this Emission Point: 3.B
Emission Unit Description: Finish Paint Oven
Raw Material/Fuel: Natural Gas
Rated Capacity: 2.0 MMBtu/hr.
Emission Limits (lb./hr. gr./dscf. lb./MMBtu. % opacity, etc.):
The emissions from this emission point shall not exceed the following specified levels.
Pollutant: Opacity
Emission Limits: 40%
Indicator Opacity: (1)
(1) If visible emissions are observed other than startup, shutdown or malfunction, a stack
test may be required to demonstrate compliance with the particulate standard.
Authority for Requirement: Iowa DNR Construction Permit 98-A-003-S1
567 IAC 23.3(2)"d"
Pollutant: Particulate Matter (TSP)
Emission Limit(s): 15.3 lb./MMCF of LPG or Natural Gas
Authority for Requirement: Part 7a. of State of Iowa, ex rel., Iowa DNR vs. Vermeer
Manufacturing Company, 99AG23542
District Court, Marion County, Law No. LACV087889
Pollutant: Particulate Matter (TSP)
Emission Limits: 0.1 gr./dscf
Authority for Requirement: Iowa DNR Construction Permit 98-A-003-S1
567 IAC 23.3(2)"a"
Pollutant: Sulfur Dioxide (SO2)
Emission Limits: 500 ppmv
Authority for Requirement: 567 IAC 23.3(3)"e"
Pollutant: Nitrogen Oxides (NOx)
Emission Limit(s): See Facility-Wide Conditions
Authority for Requirement: Iowa DNR Construction Permit 98-A-003-S1
143
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Emission Limits (continued):
Pollutant: Volatile Organic Compounds (VOC)
Emission Limit: See Facility-Wide Conditions
Authority for Requirement: Iowa DNR Construction Permit 98-A-003-S1
Operational Limits & Requirements:
The owner/operator of this equipment shall comply with the following operational limits
and requirements.
Process throughput:
A. This oven shall be fired by natural gas or propane only.
Reporting & Recordkeeping: See Facility-Wide Operational Limits
Authority for Requirement: Iowa DNR Construction Permit 98-A-003-S1
Process throughput:
A. The sulfur content of natural gas or LPG combusted by this source is not to
exceed 123 ppm by weight.
Reporting & Recordkeeping: See Facility-Wide Operational Limits
Authority for Requirement: Part 7b. of State of Iowa, ex rel., Iowa DNR vs. Vermeer
Manufacturing Company, 99AG23542
District Court, Marion County, Law No. LACV087889
Compliance Plan:
The owner/operator of this equipment shall comply with the following applicable
requirements.
This point is in compliance with all applicable requirements and shall continue to comply
with all such requirements. For those applicable requirements which will become
effective during the permit term, this source will comply with such requirements in a
timely manner.
Additional Requirements:
This emission point shall conform to the following conditions.
The source is to be connected to the stack of the following detailed description.
Stack Height (feet): 35.5
Stack Diameter (inches): 12.0
Stack Exhaust Flow Rate (acfm): .... 900
Stack Temperature (°F): 90
Vertical, Unobstructed Discharge Required: Yes ^ No ~
Authority for Requirement: Iowa DNR Construction Permit 98-A-003-S1
144
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Periodic Monitoring Requirements:
The owner/operator of this equipment shall comply with the following periodic
monitoring requirements.
Opacity Monitoring:
The facility shall observe the opacity weekly during a period when the emission unit
associated with this emission point is at or near full capacity and record the reading
indicating if visible emissions were observed. The records shall be maintained for five
years. If weather conditions prevent the observer from conducting an opacity
observation, the observer shall note such conditions on the data observation sheet. At
least three attempts shall be made to retake opacity readings at approximately 2-hour
intervals throughout the day. If all observation attempts for a week have been
unsuccessful due to weather, an observation shall be made the next operating day where
weather permits.
Maintain a written record of the observation and any action resulting from the
observation.
Agency Approved Operation & Maintenance Plan Required? Yes ~ No IEI
Facility Maintained Operation & Maintenance Plan Required? Yes ~ No Kl
Authority for Requirement: 567 IAC 22.108(3)"b"
145
-------
Emission Point ID Number: 3.BB
Associated Equipment
Associated Emission Unit ID Numbers (if multiple units vent thru this EP): 3 .BB
Applicable Requirements
(If more than one emission unit vents through this emission point subdivide the applicable requirements by emission
unit.)
Emission Unit vented through this Emission Point: 3.BB
Emission Unit Description: Non-Production Heating Unit
Raw Material/Fuel: Natural Gas
Rated Capacity: 1.30 MMBtu/hr.
Emission Limits (lb./hr. gr./dscf. lb./MMBtu. % opacity, etc.):
The emissions from this emission point shall not exceed the following specified levels.
Pollutant: Opacity
Emission Limit(s): 40 %
Authority for Requirement: 567 IAC 23.3(2)"d"
Pollutant: Particulate Matter (TSP)
Emission Limit(s): 15.3 lb./MMCF of LPG or Natural Gas
Authority for Requirement: Part 7a. of State of Iowa, ex rel., Iowa DNR vs. Vermeer
Manufacturing Company, 99AG23542
District Court, Marion County, Law No. LACV087889
Pollutant: Particulate Matter (TSP)
Emission Limits: 0.8 lb./MMBtu
Authority for Requirement: 567 IAC 23.3(2)"b"
Pollutant: Sulfur Dioxide (SO2)
Emission Limits: 500 ppmv
Authority for Requirement: 567 IAC 23.3(3)"e"
Pollutant: Nitrogen Oxides (NOx)
Emission Limit(s): See Facility-Wide Conditions
Authority for Requirement: Iowa DNR Construction Permit 98-A-003-S1
Pollutant: Volatile Organic Compounds (VOC)
Emission Limit: See Facility-Wide Conditions
Authority for Requirement: Iowa DNR Construction Permit 98-A-003-S1
146
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Operational Limits & Requirements:
The owner/operator of this equipment shall comply with the following operational limits
and requirements.
Process throughput:
A. The sulfur content of natural gas or LPG combusted by this source is not to
exceed 123 ppm by weight.
Reporting & Recordkeeping: See Facility-Wide Operational Limits
Authority for Requirement: Part 7b. of State of Iowa, ex rel., Iowa DNR vs. Vermeer
Manufacturing Company, 99AG23542
District Court, Marion County, Law No. LACV087889
Compliance Plan:
The owner/operator of this equipment shall comply with the following applicable
requirements.
This point is in compliance with all applicable requirements and shall continue to comply
with all such requirements. For those applicable requirements which will become
effective during the permit term, this source will comply with such requirements in a
timely manner.
Periodic Monitoring Requirements:
The owner/operator of this equipment shall comply with the following periodic
monitoring requirements.
Agency Approved Operation & Maintenance Plan Required? Yes ~ No IXI
Facility Maintained Operation & Maintenance Plan Required? Yes ~ No Kl
Authority for Requirement: 567 IAC 22.108(3)"b"
147
-------
Emission Point ID Number: 3.C
Associated Equipment
Associated Emission Unit ID Numbers (if multiple units vent thru this EP): 3 C
Applicable Requirements
(If more than one emission unit vents through this emission point subdivide the applicable requirements by emission
unit.)
Emission Unit vented through this Emission Point: 3 C
Emission Unit Description: Non-Production Heating Unit
Raw Material/Fuel: Natural Gas
Rated Capacity: 2.0 MMBtu/hr.
Emission Limits (lb./hr. gr./dscf. lb./MMBtu. % opacity, etc.):
The emissions from this emission point shall not exceed the following specified levels.
Pollutant: Opacity
Emission Limit(s): 40 %
Authority for Requirement: 567 IAC 23.3(2)"d"
Pollutant: Particulate Matter (TSP)
Emission Limit(s): 15.3 lb./MMCF of LPG or Natural Gas
Authority for Requirement: Part 7a. of State of Iowa, ex rel., Iowa DNR vs. Vermeer
Manufacturing Company, 99AG23542
District Court, Marion County, Law No. LACV087889
Pollutant: Particulate Matter (TSP)
Emission Limits: 0.8 lb./MMBtu
Authority for Requirement: 567 IAC 23.3(2)"b"
Pollutant: Sulfur Dioxide (SO2)
Emission Limits: 500 ppmv
Authority for Requirement: 567 IAC 23.3(3)"e"
Pollutant: Nitrogen Oxides (NOx)
Emission Limit(s): See Facility-Wide Conditions
Authority for Requirement: Iowa DNR Construction Permit 98-A-003-S1
Pollutant: Volatile Organic Compounds (VOC)
Emission Limit: See Facility-Wide Conditions
Authority for Requirement: Iowa DNR Construction Permit 98-A-003-S1
148
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Operational Limits & Requirements:
The owner/operator of this equipment shall comply with the following operational limits
and requirements.
Process throughput:
A. The sulfur content of natural gas or LPG combusted by this source is not to
exceed 123 ppm by weight.
Reporting & Recordkeeping: See Facility-Wide Operational Limits
Authority for Requirement: Part 7b. of State of Iowa, ex rel., Iowa DNR vs. Vermeer
Manufacturing Company, 99AG23542
District Court, Marion County, Law No. LACV087889
Compliance Plan:
The owner/operator of this equipment shall comply with the following applicable
requirements.
This point is in compliance with all applicable requirements and shall continue to comply
with all such requirements. For those applicable requirements which will become
effective during the permit term, this source will comply with such requirements in a
timely manner.
Periodic Monitoring Requirements:
The owner/operator of this equipment shall comply with the following periodic
monitoring requirements.
Agency Approved Operation & Maintenance Plan Required? Yes ~ No IXI
Facility Maintained Operation & Maintenance Plan Required? Yes ~ No Kl
Authority for Requirement: 567 IAC 22.108(3)"b"
149
-------
Emission Point ID Number: 3.D1
Associated Equipment
Associated Emission Unit ID Numbers (if multiple units vent thru this EP): 3 D1
Applicable Requirements
(If more than one emission unit vents through this emission point subdivide the applicable requirements by emission
unit.)
Emission Unit vented through this Emission Point: 3.D1
Emission Unit Description: Production Engine Testing Unit
Raw Material/Fuel: #2 Diesel Fuel and Gasoline
Rated Capacity: 54.5 gal./hr.
Emission Limits (lb./hr. gr./dscf. lb./MMBtu. % opacity, etc.):
The emissions from this emission point shall not exceed the following specified levels.
Pollutant: Opacity
Emission Limits: 40%
Indicator Opacity: 25%(1)
(1) If visible emissions are observed that exceed the indicator opacity other than startup,
shutdown or malfunction, a stack test may be required to demonstrate compliance with
the particulate standard.
Authority for Requirement: Iowa DNR Construction Permit 97-A-l 102-S2
567 IAC 23.3(2)"d"
Pollutant: Particulate Matter (TSP)
Emission Limits: 0.1 gr./dscf
Authority for Requirement: Iowa DNR Construction Permit 97-A-l 102-S2
567 IAC 23.3(2)"a"
Pollutant: Sulfur Dioxide (SO2)
Emission Limits: 2.5 lb./MMBtu
Authority for Requirement: Iowa DNR Construction Permit 97-A-l 102-S2
567 IAC 23.3(3)"b"
Pollutant: Nitrogen Oxides (NOx)
Emission Limit(s): See Facility-Wide Conditions
Authority for Requirement: Iowa DNR Construction Permit 97-A-l 102-S2
Pollutant: Volatile Organic Compounds (VOC)
Emission Limit: See Facility-Wide Conditions
Authority for Requirement: Iowa DNR Construction Permit 97-A-l 102-S2
150
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Operational Limits & Requirements:
The owner/operator of this equipment shall comply with the following operational limits
and requirements.
Process Throughput:
A. The sulfur content of any diesel fuel used in this source shall not exceed 0.4% by
weight.
Reporting & Recordkeeping: See Facility-Wide Emission and Operational Limits
Authority for Requirement: Iowa DNR Construction Permit 97-A-l 102-S2
Compliance Plan:
The owner/operator of this equipment shall comply with the following applicable
requirements.
This point is in compliance with all applicable requirements and shall continue to comply
with all such requirements. For those applicable requirements which will become
effective during the permit term, this source will comply with such requirements in a
timely manner.
Additional Requirements:
This emission point shall conform to the following conditions.
The source is to be connected to the stack of the following detailed description.
Stack Height (feet): 37.4
Stack Diameter (inches): 12
Stack Exhaust Flow Rate (acfm): .... 6210
Stack Temperature (°F): 759
Vertical, Unobstructed Discharge Required: Yes ^ No ~
Authority for Requirement: Iowa DNR Construction Permit 97-A-l 102-S2
Periodic Monitoring Requirements:
The owner/operator of this equipment shall comply with the following periodic
monitoring requirements.
Opacity Monitoring:
The facility shall observe the opacity weekly during a period when the emission unit
associated with this emission point is at or near full capacity and record the reading
indicating if visible emissions were observed. The records shall be maintained for five
years. If weather conditions prevent the observer from conducting an opacity
observation, the observer shall note such conditions on the data observation sheet. At
least three attempts shall be made to retake opacity readings at approximately 2-hour
intervals throughout the day. If all observation attempts for a week have been
unsuccessful due to weather, an observation shall be made the next operating day where
weather permits.
Maintain a written record of the observation and any action resulting from the
observation.
151
-------
Agency Approved Operation & Maintenance Plan Required? Yes ~ No Kl
Facility Maintained Operation & Maintenance Plan Required? Yes ~ No Kl
Authority for Requirement: 567 IAC 22.108(3)"b"
152
-------
Emission Point ID Number: 3.D2
Associated Equipment
Associated Emission Unit ID Numbers (if multiple units vent thru this EP): 3 D2
Applicable Requirements
(If more than one emission unit vents through this emission point subdivide the applicable requirements by emission
unit.)
Emission Unit vented through this Emission Point: 3D2
Emission Unit Description: Production Engine Testing Unit
Raw Material/Fuel: #2 Diesel Fuel and Gasoline
Rated Capacity: 54.5 gal./hr.
Emission Limits (lb./hr. gr./dscf. lb./MMBtu. % opacity, etc.):
The emissions from this emission point shall not exceed the following specified levels.
Pollutant: Opacity
Emission Limits: 40%
Indicator Opacity: 25%(1)
(1) If visible emissions are observed that exceed the indicator opacity other than startup,
shutdown or malfunction, a stack test may be required to demonstrate compliance with
the particulate standard.
Authority for Requirement: Iowa DNR Construction Permit 97-A-l 103-S2
567 IAC 23.3(2)"d"
Pollutant: Particulate Matter (TSP)
Emission Limits: 0.1 gr./dscf
Authority for Requirement: Iowa DNR Construction Permit 97-A-l 103-S2
567 IAC 23.3(2)"a"
Pollutant: Sulfur Dioxide (SO2)
Emission Limits: 2.5 lb./MMBtu
Authority for Requirement: Iowa DNR Construction Permit 97-A-l 103-S2
567 IAC 23.3(3)"b"
Pollutant: Nitrogen Oxides (NOx)
Emission Limit(s): See Facility-Wide Conditions
Authority for Requirement: Iowa DNR Construction Permit 97-A-l 103-S2
Pollutant: Volatile Organic Compounds (VOC)
Emission Limit: See Facility-Wide Conditions
Authority for Requirement: Iowa DNR Construction Permit 97-A-l 103-S2
153
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Operational Limits & Requirements:
The owner/operator of this equipment shall comply with the following operational limits
and requirements.
Process Throughput:
A. The sulfur content of any diesel fuel used in this source shall not exceed 0.4% by
weight.
Reporting & Recordkeeping: See Facility-Wide Emission and Operational Limits
Authority for Requirement: Iowa DNR Construction Permit 97-A-l 103-S2
Compliance Plan:
The owner/operator of this equipment shall comply with the following applicable
requirements.
This point is in compliance with all applicable requirements and shall continue to comply
with all such requirements. For those applicable requirements which will become
effective during the permit term, this source will comply with such requirements in a
timely manner.
Additional Requirements:
This emission point shall conform to the following conditions.
The source is to be connected to the stack of the following detailed description.
Stack Height (feet): 38.1
Stack Diameter (inches): 12
Stack Exhaust Flow Rate (acfm): .... 6210
Stack Temperature (°F): 759
Vertical, Unobstructed Discharge Required: Yes ^ No ~
Authority for Requirement: Iowa DNR Construction Permit 97-A-l 103-S2
Periodic Monitoring Requirements:
The owner/operator of this equipment shall comply with the following periodic
monitoring requirements.
Opacity Monitoring:
The facility shall observe the opacity weekly during a period when the emission unit
associated with this emission point is at or near full capacity and record the reading
indicating if visible emissions were observed. The records shall be maintained for five
years. If weather conditions prevent the observer from conducting an opacity
observation, the observer shall note such conditions on the data observation sheet. At
least three attempts shall be made to retake opacity readings at approximately 2-hour
intervals throughout the day. If all observation attempts for a week have been
unsuccessful due to weather, an observation shall be made the next operating day where
weather permits.
Maintain a written record of the observation and any action resulting from the
observation.
154
-------
Agency Approved Operation & Maintenance Plan Required? Yes ~ No Kl
Facility Maintained Operation & Maintenance Plan Required? Yes ~ No Kl
Authority for Requirement: 567 IAC 22.108(3)"b"
155
-------
Emission Point ID Number: 3.D3
Associated Equipment
Associated Emission Unit ID Numbers (if multiple units vent thru this EP): 3 ,D3
Applicable Requirements
(If more than one emission unit vents through this emission point subdivide the applicable requirements by emission
unit.)
Emission Unit vented through this Emission Point: 3,D3
Emission Unit Description: Production Engine Testing Unit
Raw Material/Fuel: #2 Diesel Fuel and Gasoline
Rated Capacity: 54.5 gal./hr.
Emission Limits (lb./hr. gr./dscf. lb./MMBtu. % opacity, etc.):
The emissions from this emission point shall not exceed the following specified levels.
Pollutant: Opacity
Emission Limits: 40%
Indicator Opacity: 25%(1)
(1) If visible emissions are observed that exceed the indicator opacity other than startup,
shutdown or malfunction, a stack test may be required to demonstrate compliance with
the particulate standard.
Authority for Requirement: Iowa DNR Construction Permit 97-A-l 104-S2
567 IAC 23.3(2)"d"
Pollutant: Particulate Matter (TSP)
Emission Limits: 0.1 gr./dscf
Authority for Requirement: Iowa DNR Construction Permit 97-A-l 104-S2
567 IAC 23.3(2)"a"
Pollutant: Sulfur Dioxide (SO2)
Emission Limits: 2.5 lb./MMBtu
Authority for Requirement: Iowa DNR Construction Permit 97-A-l 104-S2
567 IAC 23.3(3)"b"
Pollutant: Nitrogen Oxides (NOx)
Emission Limit(s): See Facility-Wide Conditions
Authority for Requirement: Iowa DNR Construction Permit 97-A-l 104-S2
Pollutant: Volatile Organic Compounds (VOC)
Emission Limit: See Facility-Wide Conditions
Authority for Requirement: Iowa DNR Construction Permit 97-A-l 104-S2
156
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Operational Limits & Requirements:
The owner/operator of this equipment shall comply with the following operational limits
and requirements.
Process Throughput:
A. The sulfur content of any diesel fuel used in this source shall not exceed 0.4% by
weight.
Reporting & Recordkeeping: See Facility-Wide Emission and Operational Limits
Authority for Requirement: Iowa DNR Construction Permit 97-A-l 104-S2
Compliance Plan:
The owner/operator of this equipment shall comply with the following applicable
requirements.
This point is in compliance with all applicable requirements and shall continue to comply
with all such requirements. For those applicable requirements which will become
effective during the permit term, this source will comply with such requirements in a
timely manner.
Additional Requirements:
This emission point shall conform to the following conditions.
The source is to be connected to the stack of the following detailed description.
Stack Height (feet): 35
Stack Diameter (inches): 12
Stack Exhaust Flow Rate (acfm): .... 6210
Stack Temperature (°F): 759
Vertical, Unobstructed Discharge Required: Yes ^ No ~
Authority for Requirement: Iowa DNR Construction Permit 97-A-l 104-S2
Periodic Monitoring Requirements:
The owner/operator of this equipment shall comply with the following periodic
monitoring requirements.
Opacity Monitoring:
The facility shall observe the opacity weekly during a period when the emission unit
associated with this emission point is at or near full capacity and record the reading
indicating if visible emissions were observed. The records shall be maintained for five
years. If weather conditions prevent the observer from conducting an opacity
observation, the observer shall note such conditions on the data observation sheet. At
least three attempts shall be made to retake opacity readings at approximately 2-hour
intervals throughout the day. If all observation attempts for a week have been
unsuccessful due to weather, an observation shall be made the next operating day where
weather permits.
Maintain a written record of the observation and any action resulting from the
observation.
157
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Agency Approved Operation & Maintenance Plan Required? Yes ~ No Kl
Facility Maintained Operation & Maintenance Plan Required? Yes ~ No Kl
Authority for Requirement: 567 IAC 22.108(3)"b"
158
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Emission Point ID Number: 3.EE
Associated Equipment
Associated Emission Unit ID Numbers (if multiple units vent thru this EP): 3 .EE
Applicable Requirements
(If more than one emission unit vents through this emission point subdivide the applicable requirements by emission
unit.)
Emission Unit vented through this Emission Point: 3.EE
Emission Unit Description: Non-Production Heating Unit
Raw Material/Fuel: Natural Gas
Rated Capacity: 0.14 MMBtu/hr.
Emission Limits (lb./hr. gr./dscf. lb./MMBtu. % opacity, etc.):
The emissions from this emission point shall not exceed the following specified levels.
Pollutant: Opacity
Emission Limit(s): 40 %
Authority for Requirement: 567 IAC 23.3(2)"d"
Pollutant: Particulate Matter (TSP)
Emission Limit(s): 15.3 lb./MMCF of LPG or Natural Gas
Authority for Requirement: Part 7a. of State of Iowa, ex rel., Iowa DNR vs. Vermeer
Manufacturing Company, 99AG23542
District Court, Marion County, Law No. LACV087889
Pollutant: Particulate Matter (TSP)
Emission Limits: 0.8 lb./MMBtu
Authority for Requirement: 567 IAC 23.3(2)"b"
Pollutant: Sulfur Dioxide (SO2)
Emission Limits: 500 ppmv
Authority for Requirement: 567 IAC 23.3(3)"e"
Pollutant: Nitrogen Oxides (NOx)
Emission Limit(s): See Facility-Wide Conditions
Authority for Requirement: Iowa DNR Construction Permit 98-A-003-S1
Pollutant: Volatile Organic Compounds (VOC)
Emission Limit: See Facility-Wide Conditions
Authority for Requirement: Iowa DNR Construction Permit 98-A-003-S1
159
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Operational Limits & Requirements:
The owner/operator of this equipment shall comply with the following operational limits
and requirements.
Process throughput:
A. The sulfur content of natural gas or LPG combusted by this source is not to
exceed 123 ppm by weight.
Reporting & Recordkeeping: See Facility-Wide Operational Limits
Authority for Requirement: Part 7b. of State of Iowa, ex rel., Iowa DNR vs. Vermeer
Manufacturing Company, 99AG23542
District Court, Marion County, Law No. LACV087889
Compliance Plan:
The owner/operator of this equipment shall comply with the following applicable
requirements.
This point is in compliance with all applicable requirements and shall continue to comply
with all such requirements. For those applicable requirements which will become
effective during the permit term, this source will comply with such requirements in a
timely manner.
Periodic Monitoring Requirements:
The owner/operator of this equipment shall comply with the following periodic
monitoring requirements.
Agency Approved Operation & Maintenance Plan Required? Yes ~ No IXI
Facility Maintained Operation & Maintenance Plan Required? Yes ~ No Kl
Authority for Requirement: 567 IAC 22.108(3)"b"
160
-------
Emission Point ID Number: 3.F1
Associated Equipment
Associated Emission Unit ID Numbers (if multiple units vent thru this EP): 3 .F
Emissions Control Equipment ID Number: 3.F
Emissions Control Equipment Description: Paper Filter
Applicable Requirements
(If more than one emission unit vents through this emission point subdivide the applicable requirements by emission
unit.)
Emission Unit vented through this Emission Point: 3.F
Emission Unit Description: Finish Paint Booth
Raw Material/Fuel: Paints, Primers, and Solvents
Rated Capacity: 15 gal./hr.
Emission Limits (lb./hr. gr./dscf. lb./MMBtu. % opacity, etc.):
The emissions from this emission point shall not exceed the following specified levels.
Pollutant: Opacity
Emission Limits: 40%
Indicator Opacity: (1)
(1) If visible emissions are observed other than startup, shutdown or malfunction, a stack
test may be required to demonstrate compliance with the particulate standard.
Authority for Requirement: Iowa DNR Construction Permit 98-A-004-S2
567 IAC 23.3(2)"d"
Pollutant: PMio
Emission Limit(s): 0.9 lb./hr.
Authority for Requirement: Iowa DNR Construction Permit 98-A-004-S2
Pollutant: Particulate Matter (TSP)
Emission Limit(s): 0.01 gr./dscf
Authority for Requirement: Iowa DNR Construction Permit 98-A-004-S2
567 IAC 23.4(13)
Pollutant: Volatile Organic Compounds (VOC)
Emission Limit: See Facility-Wide Conditions
Authority for Requirement: Iowa DNR Construction Permit 98-A-004-S2
161
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Compliance Plan:
The owner/operator of this equipment shall comply with the following applicable
requirements.
This point is in compliance with all applicable requirements and shall continue to comply
with all such requirements. For those applicable requirements which will become
effective during the permit term, this source will comply with such requirements in a
timely manner.
Additional Requirements:
This emission point shall conform to the following conditions.
The source is to be connected to the stack of the following detailed description.
Stack Height (feet): 39
Stack Diameter (inches): 42.0
Stack Exhaust Flow Rate (acfm): .... 21,000
Stack Temperature (°F): 70
Vertical, Unobstructed Discharge Required: Yes E No ~
Authority for Requirement: Iowa DNR Construction Permit 98-A-004-S2
Periodic Monitoring Requirements:
The owner/operator of this equipment shall comply with the following periodic
monitoring requirements.
Opacity Monitoring:
The facility shall observe the opacity weekly during a period when the emission unit
associated with this emission point is at or near full capacity and record the reading
indicating if visible emissions were observed. The records shall be maintained for five
years. If weather conditions prevent the observer from conducting an opacity
observation, the observer shall note such conditions on the data observation sheet. At
least three attempts shall be made to retake opacity readings at approximately 2-hour
intervals throughout the day. If all observation attempts for a week have been
unsuccessful due to weather, an observation shall be made the next operating day where
weather permits.
Maintain a written record of the observation and any action resulting from the
observation.
Agency Approved Operation & Maintenance Plan Required? Yes ~ No Kl
Facility Maintained Operation & Maintenance Plan Required? Yes Kl NoQ
Facility operation and maintenance plans must be sufficient to yield reliable data from
the relevant time period that are representative of the source's compliance with the
applicable requirements.
162
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Facility operation and maintenance plans are to be developed by the facility within six(6)
months of the issuance date of this permit and the data pertaining to the plan maintained
on site for at least 5 years. The plan and associated recordkeeping provides
documentation of this facility's implementation of its obligation to operate according to
good air pollution control practice.
Good air pollution control practice is achieved by adoption of quality control standards
in the operation and maintenance procedures for air pollution control that are
comparable to industry quality control standards for the production processes associated
with this emission point.
Authority for Requirement: 567 IAC 22.108(3)"b"
163
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Emission Point ID Number: 3.F2
Associated Equipment
Associated Emission Unit ID Numbers (if multiple units vent thru this EP): 3 .F
Emissions Control Equipment ID Number: 3.F
Emissions Control Equipment Description: Paper Filter
Applicable Requirements
(If more than one emission unit vents through this emission point subdivide the applicable requirements by emission
unit.)
Emission Unit vented through this Emission Point: 3.F
Emission Unit Description: Finish Paint Booth
Raw Material/Fuel: Paints, Primers, and Solvents
Rated Capacity: 15 gal./hr.
Emission Limits (lb./hr. gr./dscf. lb./MMBtu. % opacity, etc.):
The emissions from this emission point shall not exceed the following specified levels.
Pollutant: Opacity
Emission Limits: 40%
Indicator Opacity: (1)
(1) If visible emissions are observed other than startup, shutdown or malfunction, a stack
test may be required to demonstrate compliance with the particulate standard.
Authority for Requirement: Iowa DNR Construction Permit 98-A-005-S2
567 IAC 23.3(2)"d"
Pollutant: PMio
Emission Limit(s): 0.9 lb./hr.
Authority for Requirement: Iowa DNR Construction Permit 98-A-005-S2
Pollutant: Particulate Matter (TSP)
Emission Limit(s): 0.01 gr./dscf
Authority for Requirement: Iowa DNR Construction Permit 98-A-005-S2
567 IAC 23.4(13)
Pollutant: Volatile Organic Compounds (VOC)
Emission Limit: See Facility-Wide Conditions
Authority for Requirement: Iowa DNR Construction Permit 98-A-005-S2
164
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Compliance Plan:
The owner/operator of this equipment shall comply with the following applicable
requirements.
This point is in compliance with all applicable requirements and shall continue to comply
with all such requirements. For those applicable requirements which will become
effective during the permit term, this source will comply with such requirements in a
timely manner.
Additional Requirements:
This emission point shall conform to the following conditions.
The source is to be connected to the stack of the following detailed description.
Stack Height (feet): 39
Stack Diameter (inches): 42.0
Stack Exhaust Flow Rate (acfm): .... 21,000
Stack Temperature (°F): 70
Vertical, Unobstructed Discharge Required: Yes E No ~
Authority for Requirement: Iowa DNR Construction Permit 98-A-005-S2
Periodic Monitoring Requirements:
The owner/operator of this equipment shall comply with the following periodic
monitoring requirements.
Opacity Monitoring:
The facility shall observe the opacity weekly during a period when the emission unit
associated with this emission point is at or near full capacity and record the reading
indicating if visible emissions were observed. The records shall be maintained for five
years. If weather conditions prevent the observer from conducting an opacity
observation, the observer shall note such conditions on the data observation sheet. At
least three attempts shall be made to retake opacity readings at approximately 2-hour
intervals throughout the day. If all observation attempts for a week have been
unsuccessful due to weather, an observation shall be made the next operating day where
weather permits.
Maintain a written record of the observation and any action resulting from the
observation.
Agency Approved Operation & Maintenance Plan Required? Yes ~ No Kl
Facility Maintained Operation & Maintenance Plan Required? Yes Kl NoQ
Facility operation and maintenance plans must be sufficient to yield reliable data from
the relevant time period that are representative of the source's compliance with the
applicable requirements.
165
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Facility operation and maintenance plans are to be developed by the facility within six(6)
months of the issuance date of this permit and the data pertaining to the plan maintained
on site for at least 5 years. The plan and associated recordkeeping provides
documentation of this facility's implementation of its obligation to operate according to
good air pollution control practice.
Good air pollution control practice is achieved by adoption of quality control standards
in the operation and maintenance procedures for air pollution control that are
comparable to industry quality control standards for the production processes associated
with this emission point.
Authority for Requirement: 567 IAC 22.108(3)"b"
166
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Emission Point ID Number: 3.FLAME1
Associated Equipment
Associated Emission Unit ID Numbers (if multiple units vent thru this EP): 3 .FLAME1
Emissions Control Equipment ID Number: 3.FLAME1
Emissions Control Equipment Description: Water Table
Applicable Requirements
(If more than one emission unit vents through this emission point subdivide the applicable requirements by emission
unit.)
Emission Unit vented through this Emission Point: 3.FLAME1 (Fugitive)
Emission Unit Description: Single Cutting Head Oxyacetylene
Torch Unit
Raw Material/Fuel: Sheet Steel
Rated Capacity: 660 inches of metal cut/hr.
Emission Limits (lb./hr. gr./dscf. lb./MMBtu. % opacity, etc.):
The emissions from this emission point shall not exceed the following specified levels.
Pollutant: Fugitive Dust
Emission Limit: No person shall allow, cause or permit any materials to be handled,
transported or stored; or a building, its appurtenances or a construction haul road to
be used, constructed, altered , repaired or demolished, without taking reasonable
precautions to prevent a nuisance. All persons shall take reasonable precautions to
prevent the discharge of visible emissions of fugitive dusts beyond the lot line of the
property on which the emissions originate.
Authority for Requirement: 567 IAC 23.3(2)"c"
Compliance Plan:
The owner/operator of this equipment shall comply with the following applicable
requirements.
This point is in compliance with all applicable requirements and shall continue to comply
with all such requirements. For those applicable requirements which will become
effective during the permit term, this source will comply with such requirements in a
timely manner.
Periodic Monitoring Requirements:
The owner/operator of this equipment shall comply with the following periodic
monitoring requirements.
Agency Approved Operation & Maintenance Plan Required? Yes ~ No Kl
Facility Maintained Operation & Maintenance Plan Required? Yes ~ No Kl
Authority for Requirement: 567 IAC 22.108(3)"b"
167
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Emission Point ID Number: 3.FLAME2
Associated Equipment
Associated Emission Unit ID Numbers (if multiple units vent thru this EP): 3 .FLAME2
Emissions Control Equipment ID Number: 3.FLAME2
Emissions Control Equipment Description: Water Table
Applicable Requirements
(If more than one emission unit vents through this emission point subdivide the applicable requirements by emission
unit.)
Emission Unit vented through this Emission Point: 3.FLAME2 (Fugitive)
Emission Unit Description: Eight (8) Cutting Head
Oxyacetylene Torch Unit
Raw Material/Fuel: Sheet Steel
Rated Capacity: 660 inches of metal cut/hr. per Head
Emission Limits (lb./hr. gr./dscf. lb./MMBtu. % opacity, etc.):
The emissions from this emission point shall not exceed the following specified levels.
Pollutant: Fugitive Dust
Emission Limit: No person shall allow, cause or permit any materials to be handled,
transported or stored; or a building, its appurtenances or a construction haul road to
be used, constructed, altered , repaired or demolished, without taking reasonable
precautions to prevent a nuisance. All persons shall take reasonable precautions to
prevent the discharge of visible emissions of fugitive dusts beyond the lot line of the
property on which the emissions originate.
Authority for Requirement: 567 IAC 23.3(2)"c"
Compliance Plan:
The owner/operator of this equipment shall comply with the following applicable
requirements.
This point is in compliance with all applicable requirements and shall continue to comply
with all such requirements. For those applicable requirements which will become
effective during the permit term, this source will comply with such requirements in a
timely manner.
Periodic Monitoring Requirements:
The owner/operator of this equipment shall comply with the following periodic
monitoring requirements.
Agency Approved Operation & Maintenance Plan Required? Yes ~ No Kl
Facility Maintained Operation & Maintenance Plan Required? Yes ~ No Kl
Authority for Requirement: 567 IAC 22.108(3)"b"
168
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Emission Point ID Number: 3.FLAME3
Associated Equipment
Associated Emission Unit ID Numbers (if multiple units vent thru this EP): 3 .FLAME3
Emissions Control Equipment ID Number: 3.FLAME3
Emissions Control Equipment Description: Water Table
Applicable Requirements
(If more than one emission unit vents through this emission point subdivide the applicable requirements by emission
unit.)
Emission Unit vented through this Emission Point: 3.FLAME3 (Fugitive)
Emission Unit Description: Eight (8) Cutting Head
Oxyacetylene Torch Unit
Raw Material/Fuel: Sheet Steel
Rated Capacity: 660 inches of metal cut/hr. per Head
Emission Limits (lb./hr. gr./dscf. lb./MMBtu. % opacity, etc.):
The emissions from this emission point shall not exceed the following specified levels.
Pollutant: Fugitive Dust
Emission Limit: No person shall allow, cause or permit any materials to be handled,
transported or stored; or a building, its appurtenances or a construction haul road to
be used, constructed, altered , repaired or demolished, without taking reasonable
precautions to prevent a nuisance. All persons shall take reasonable precautions to
prevent the discharge of visible emissions of fugitive dusts beyond the lot line of the
property on which the emissions originate.
Authority for Requirement: 567 IAC 23.3(2)"c"
Compliance Plan:
The owner/operator of this equipment shall comply with the following applicable
requirements.
This point is in compliance with all applicable requirements and shall continue to comply
with all such requirements. For those applicable requirements which will become
effective during the permit term, this source will comply with such requirements in a
timely manner.
Periodic Monitoring Requirements:
The owner/operator of this equipment shall comply with the following periodic
monitoring requirements.
Agency Approved Operation & Maintenance Plan Required? Yes ~ No Kl
Facility Maintained Operation & Maintenance Plan Required? Yes ~ No Kl
Authority for Requirement: 567 IAC 22.108(3)"b"
169
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Emission Point ID Number: 3.FLAME4
Associated Equipment
Associated Emission Unit ID Numbers (if multiple units vent thru this EP): 3 .FLAME4
Applicable Requirements
(If more than one emission unit vents through this emission point subdivide the applicable requirements by emission
unit.)
Emission Unit vented through this Emission Point: 3.FLAME4 (Fugitive)
Emission Unit Description: Single Cutting Head Oxyacetylene
Torch Unit
Raw Material/Fuel: Sheet Steel
Rated Capacity: 660 inches of metal cut/hr.
Emission Limits (lb./hr. gr./dscf. lb./MMBtu. % opacity, etc.):
The emissions from this emission point shall not exceed the following specified levels.
Pollutant: Fugitive Dust
Emission Limit: No person shall allow, cause or permit any materials to be handled,
transported or stored; or a building, its appurtenances or a construction haul road to
be used, constructed, altered , repaired or demolished, without taking reasonable
precautions to prevent a nuisance. All persons shall take reasonable precautions to
prevent the discharge of visible emissions of fugitive dusts beyond the lot line of the
property on which the emissions originate.
Authority for Requirement: 567 IAC 23.3(2)"c"
Compliance Plan:
The owner/operator of this equipment shall comply with the following applicable
requirements.
This point is in compliance with all applicable requirements and shall continue to comply
with all such requirements. For those applicable requirements which will become
effective during the permit term, this source will comply with such requirements in a
timely manner.
Periodic Monitoring Requirements:
The owner/operator of this equipment shall comply with the following periodic
monitoring requirements.
Agency Approved Operation & Maintenance Plan Required? Yes ~ No IXI
Facility Maintained Operation & Maintenance Plan Required? Yes ~ No Kl
Authority for Requirement: 567 IAC 22.108(3)"b"
170
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Emission Point ID Number: 3.FLAME5
Associated Equipment
Associated Emission Unit ID Numbers (if multiple units vent thru this EP): 3 .FLAME5
Applicable Requirements
(If more than one emission unit vents through this emission point subdivide the applicable requirements by emission
unit.)
Emission Unit vented through this Emission Point: 3.FLAME5 (Fugitive)
Emission Unit Description: Single Cutting Head Oxyacetylene
Torch Unit
Raw Material/Fuel: Sheet Steel
Rated Capacity: 660 inches of metal cut/hr.
Emission Limits (lb./hr. gr./dscf. lb./MMBtu. % opacity, etc.):
The emissions from this emission point shall not exceed the following specified levels.
Pollutant: Fugitive Dust
Emission Limit: No person shall allow, cause or permit any materials to be handled,
transported or stored; or a building, its appurtenances or a construction haul road to
be used, constructed, altered , repaired or demolished, without taking reasonable
precautions to prevent a nuisance. All persons shall take reasonable precautions to
prevent the discharge of visible emissions of fugitive dusts beyond the lot line of the
property on which the emissions originate.
Authority for Requirement: 567 IAC 23.3(2)"c"
Compliance Plan:
The owner/operator of this equipment shall comply with the following applicable
requirements.
This point is in compliance with all applicable requirements and shall continue to comply
with all such requirements. For those applicable requirements which will become
effective during the permit term, this source will comply with such requirements in a
timely manner.
Periodic Monitoring Requirements:
The owner/operator of this equipment shall comply with the following periodic
monitoring requirements.
Agency Approved Operation & Maintenance Plan Required? Yes ~ No IXI
Facility Maintained Operation & Maintenance Plan Required? Yes ~ No Kl
Authority for Requirement: 567 IAC 22.108(3)"b"
171
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Emission Point ID Number: 3.G
Associated Equipment
Associated Emission Unit ID Numbers (if multiple units vent thru this EP): 3 G
Emissions Control Equipment ID Number: 3.G
Emissions Control Equipment Description: Paper Filter
Applicable Requirements
(If more than one emission unit vents through this emission point subdivide the applicable requirements by emission
unit.)
Emission Unit vented through this Emission Point: 3 G
Emission Unit Description: Parts Paint Booth
Raw Material/Fuel: Paints, Primers, and Solvents
Rated Capacity: 15 gal./hr.
Emission Limits (lb./hr. gr./dscf. lb./MMBtu. % opacity, etc.):
The emissions from this emission point shall not exceed the following specified levels.
Pollutant: Opacity
Emission Limits: 40%
Indicator Opacity: (1)
(1) If visible emissions are observed other than startup, shutdown or malfunction, a stack
test may be required to demonstrate compliance with the particulate standard.
Authority for Requirement: Iowa DNR Construction Permit 98-A-006-S2
567 IAC 23.3(2)"d"
Pollutant: Particulate Matter (TSP)
Emission Limit(s): 0.01 gr./dscf
Authority for Requirement: Iowa DNR Construction Permit 98-A-006-S2
567 IAC 23.4(13)
Pollutant: Volatile Organic Compounds (VOC)
Emission Limit: See Facility-Wide Conditions
Authority for Requirement: Iowa DNR Construction Permit 98-A-006-S2
Compliance Plan:
The owner/operator of this equipment shall comply with the following applicable
requirements.
This point is in compliance with all applicable requirements and shall continue to comply
with all such requirements. For those applicable requirements which will become
effective during the permit term, this source will comply with such requirements in a
timely manner.
172
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Additional Requirements:
This emission point shall conform to the following conditions.
The source is to be connected to the stack of the following detailed description.
Stack Height (feet): 43.1
Stack Diameter (inches): 42.0
Stack Exhaust Flow Rate (acfm): .... 19,320
Stack Temperature (°F): 70
Vertical, Unobstructed Discharge Required: Yes E No ~
Authority for Requirement: Iowa DNR Construction Permit 98-A-006-S2
Periodic Monitoring Requirements:
The owner/operator of this equipment shall comply with the following periodic
monitoring requirements.
Opacity Monitoring:
The facility shall observe the opacity weekly during a period when the emission unit
associated with this emission point is at or near full capacity and record the reading
indicating if visible emissions were observed. The records shall be maintained for five
years. If weather conditions prevent the observer from conducting an opacity
observation, the observer shall note such conditions on the data observation sheet. At
least three attempts shall be made to retake opacity readings at approximately 2-hour
intervals throughout the day. If all observation attempts for a week have been
unsuccessful due to weather, an observation shall be made the next operating day where
weather permits.
Maintain a written record of the observation and any action resulting from the
observation.
Agency Approved Operation & Maintenance Plan Required? Yes ~ No Kl
Facility Maintained Operation & Maintenance Plan Required? Yes Kl NoQ
Facility operation and maintenance plans must be sufficient to yield reliable data from
the relevant time period that are representative of the source's compliance with the
applicable requirements.
Facility operation and maintenance plans are to be developed by the facility within six(6)
months of the issuance date of this permit and the data pertaining to the plan maintained
on site for at least 5 years. The plan and associated recordkeeping provides
documentation of this facility's implementation of its obligation to operate according to
good air pollution control practice.
Good air pollution control practice is achieved by adoption of quality control standards
in the operation and maintenance procedures for air pollution control that are
comparable to industry quality control standards for the production processes associated
with this emission point.
Authority for Requirement: 567 IAC 22.108(3)"b"
173
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Emission Point ID Number: 3.GG
Associated Equipment
Associated Emission Unit ID Numbers (if multiple units vent thru this EP): 3 .GG
Applicable Requirements
(If more than one emission unit vents through this emission point subdivide the applicable requirements by emission
unit.)
Emission Unit vented through this Emission Point: 3.GG
Emission Unit Description: Non-Production Heating Unit
Raw Material/Fuel: Natural Gas
Rated Capacity: 0.05 MMBtu/hr.
Emission Limits (lb./hr. gr./dscf. lb./MMBtu. % opacity, etc.):
The emissions from this emission point shall not exceed the following specified levels.
Pollutant: Opacity
Emission Limit(s): 40 %
Authority for Requirement: 567 IAC 23.3(2)"d"
Pollutant: Particulate Matter (TSP)
Emission Limit(s): 15.3 lb./MMCF of LPG or Natural Gas
Authority for Requirement: Part 7a. of State of Iowa, ex rel., Iowa DNR vs. Vermeer
Manufacturing Company, 99AG23542
District Court, Marion County, Law No. LACV087889
Pollutant: Particulate Matter (TSP)
Emission Limits: 0.8 lb./MMBtu
Authority for Requirement: 567 IAC 23.3(2)"b"
Pollutant: Sulfur Dioxide (SO2)
Emission Limits: 500 ppmv
Authority for Requirement: 567 IAC 23.3(3)"e"
Pollutant: Nitrogen Oxides (NOx)
Emission Limit(s): See Facility-Wide Conditions
Authority for Requirement: Iowa DNR Construction Permit 98-A-003-S1
Pollutant: Volatile Organic Compounds (VOC)
Emission Limit: See Facility-Wide Conditions
Authority for Requirement: Iowa DNR Construction Permit 98-A-003-S1
174
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Operational Limits & Requirements:
The owner/operator of this equipment shall comply with the following operational limits
and requirements.
Process throughput:
A. The sulfur content of natural gas or LPG combusted by this source is not to
exceed 123 ppm by weight.
Reporting & Recordkeeping: See Facility-Wide Operational Limits
Authority for Requirement: Part 7b. of State of Iowa, ex rel., Iowa DNR vs. Vermeer
Manufacturing Company, 99AG23542
District Court, Marion County, Law No. LACV087889
Compliance Plan:
The owner/operator of this equipment shall comply with the following applicable
requirements.
This point is in compliance with all applicable requirements and shall continue to comply
with all such requirements. For those applicable requirements which will become
effective during the permit term, this source will comply with such requirements in a
timely manner.
Periodic Monitoring Requirements:
The owner/operator of this equipment shall comply with the following periodic
monitoring requirements.
Agency Approved Operation & Maintenance Plan Required? Yes ~ No IXI
Facility Maintained Operation & Maintenance Plan Required? Yes ~ No Kl
Authority for Requirement: 567 IAC 22.108(3)"b"
175
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Emission Point ID Number: 3.GH
Associated Equipment
Associated Emission Unit ID Numbers (if multiple units vent thru this EP): 3 GH
Applicable Requirements
(If more than one emission unit vents through this emission point subdivide the applicable requirements by emission
unit.)
Emission Units vented through this Emission Point: 3.GH
Emission Unit Description: Paint Kitchen
Raw Material/Fuel: Paints, Primers, and Solvents
Rated Capacity: 3 Barrels
Emission Limits (lb./hr. gr./dscf. lb./MMBtu. % opacity, etc.):
The emissions from this emission point shall not exceed the following specified levels.
Pollutant: Volatile Organic Compounds (VOC)
Emission Limit: See Facility-Wide Conditions
Authority for Requirement: Iowa DNR Construction Permit 98-A-007-S1
Compliance Plan:
The owner/operator of this equipment shall comply with the following applicable
requirements.
This point is in compliance with all applicable requirements and shall continue to comply
with all such requirements. For those applicable requirements which will become
effective during the permit term, this source will comply with such requirements in a
timely manner.
Additional Requirements:
This emission point shall conform to the following conditions.
The source is to be connected to the stack of the following detailed description.
Stack Height (feet): 41
Stack Diameter (inches): 15
Stack Exhaust Flow Rate (acfm): .... 3,500
Stack Temperature (°F): 70
Vertical, Unobstructed Discharge Required: Yes ^ No ~
Authority for Requirement: Iowa DNR Construction Permit 98-A-007-S1
176
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Periodic Monitoring Requirements:
The owner/operator of this equipment shall comply with the following periodic
monitoring requirements.
Agency Approved Operation & Maintenance Plan Required? Yes ~ No Kl
Facility Maintained Operation & Maintenance Plan Required? Yes ~ No Kl
Authority for Requirement: 567 IAC 22.108(3)"b"
177
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Emission Point ID Number: 3.GI
Associated Equipment
Associated Emission Unit ID Numbers (if multiple units vent thru this EP): 3 GI
Applicable Requirements
(If more than one emission unit vents through this emission point subdivide the applicable requirements by emission
unit.)
Emission Unit vented through this Emission Point: 3.GI
Emission Unit Description: Paint Kitchen
Raw Material/Fuel: Paints, Primers, and Solvents
Rated Capacity: 3 Barrels
Emission Limits (lb./hr. gr./dscf. lb./MMBtu. % opacity, etc.):
The emissions from this emission point shall not exceed the following specified levels.
Pollutant: Volatile Organic Compounds (VOC)
Emission Limit: See Facility-Wide Conditions
Authority for Requirement: Iowa DNR Construction Permit 98-A-008-S1
Compliance Plan:
The owner/operator of this equipment shall comply with the following applicable
requirements.
This point is in compliance with all applicable requirements and shall continue to comply
with all such requirements. For those applicable requirements which will become
effective during the permit term, this source will comply with such requirements in a
timely manner.
Additional Requirements:
This emission point shall conform to the following conditions.
The source is to be connected to the stack of the following detailed description.
Stack Height (feet): 41
Stack Diameter (inches): 15
Stack Exhaust Flow Rate (acfm): .... 3,500
Stack Temperature (°F): 70
Vertical, Unobstructed Discharge Required: Yes ^ No ~
Authority for Requirement: Iowa DNR Construction Permit 98-A-008-S1
178
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Periodic Monitoring Requirements:
The owner/operator of this equipment shall comply with the following periodic
monitoring requirements.
Agency Approved Operation & Maintenance Plan Required? Yes ~ No Kl
Facility Maintained Operation & Maintenance Plan Required? Yes ~ No Kl
Authority for Requirement: 567 IAC 22.108(3)"b"
179
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Emission Point ID Number: 3.H
Associated Equipment
Associated Emission Unit ID Numbers (if multiple units vent thru this EP): 3 .H
Applicable Requirements
(If more than one emission unit vents through this emission point subdivide the applicable requirements by emission
unit.)
Emission Unit vented through this Emission Point: 3.H
Emission Unit Description: Hot Water Heater
Raw Material/Fuel: Natural Gas
Rated Capacity: 0.528 MMBtu/hr.
Emission Limits (lb./hr. gr./dscf. lb./MMBtu. % opacity, etc.):
The emissions from this emission point shall not exceed the following specified levels.
Pollutant: Opacity
Emission Limit(s): 40 %
Authority for Requirement: 567 IAC 23.3(2)"d"
Pollutant: Particulate Matter (TSP)
Emission Limit(s): 15.3 lb./MMCF of LPG or Natural Gas
Authority for Requirement: Part 7a. of State of Iowa, ex rel., Iowa DNR vs. Vermeer
Manufacturing Company, 99AG23542
District Court, Marion County, Law No. LACV087889
Pollutant: Particulate Matter (TSP)
Emission Limits: 0.8 lb./MMBtu
Authority for Requirement: 567 IAC 23.3(2)"b"
Pollutant: Sulfur Dioxide (SO2)
Emission Limits: 500 ppmv
Authority for Requirement: 567 IAC 23.3(3)"e"
Pollutant: Nitrogen Oxides (NOx)
Emission Limit(s): See Facility-Wide Conditions
Authority for Requirement: Iowa DNR Construction Permit 98-A-003-S1
Pollutant: Volatile Organic Compounds (VOC)
Emission Limit: See Facility-Wide Conditions
Authority for Requirement: Iowa DNR Construction Permit 98-A-003-S1
180
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Operational Limits & Requirements:
The owner/operator of this equipment shall comply with the following operational limits
and requirements.
Process throughput:
A. The sulfur content of natural gas or LPG combusted by this source is not to
exceed 123 ppm by weight.
Reporting & Recordkeeping: See Facility-Wide Operational Limits
Authority for Requirement: Part 7b. of State of Iowa, ex rel., Iowa DNR vs. Vermeer
Manufacturing Company, 99AG23542
District Court, Marion County, Law No. LACV087889
Compliance Plan:
The owner/operator of this equipment shall comply with the following applicable
requirements.
This point is in compliance with all applicable requirements and shall continue to comply
with all such requirements. For those applicable requirements which will become
effective during the permit term, this source will comply with such requirements in a
timely manner.
Periodic Monitoring Requirements:
The owner/operator of this equipment shall comply with the following periodic
monitoring requirements.
Agency Approved Operation & Maintenance Plan Required? Yes ~ No IXI
Facility Maintained Operation & Maintenance Plan Required? Yes ~ No Kl
Authority for Requirement: 567 IAC 22.108(3)"b"
181
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Emission Point ID Number: 3.HH
Associated Equipment
Associated Emission Unit ID Numbers (if multiple units vent thru this EP): 3 .HH
Emissions Control Equipment ID Number: 3.HH
Emissions Control Equipment Description: Paper Filter
Applicable Requirements
(If more than one emission unit vents through this emission point subdivide the applicable requirements by emission
unit.)
Emission Unit vented through this Emission Point: 3.HH
Emission Unit Description: Paint Booth
Raw Material/Fuel: Paints, Primers, and Solvents
Rated Capacity: 5.625 gal./hr.
Emission Limits (lb./hr. gr./dscf. lb./MMBtu. % opacity, etc.):
The emissions from this emission point shall not exceed the following specified levels.
Pollutant: Opacity
Emission Limits: 40%
Indicator Opacity: (1)
(1) If visible emissions are observed other than startup, shutdown or malfunction, a stack
test may be required to demonstrate compliance with the particulate standard.
Authority for Requirement: Iowa DNR Construction Permit 99-A-688-S1
567 IAC 23.3(2)"d"
Pollutant: Particulate Matter (TSP)
Emission Limit(s): 0.01 gr./dscf
Authority for Requirement: Iowa DNR Construction Permit 99-A-688-S1
567 IAC 23.4(13)
Pollutant: Volatile Organic Compounds (VOC)
Emission Limit: See Facility-Wide Conditions
Authority for Requirement: Iowa DNR Construction Permit 99-A-688-S1
182
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Compliance Testing Requirements
TSP Iowa Compliance Sampling Manual
The owner shall verify compliance with the emission limitations contained in
Construction Permit 99-A-688-S1 within sixty (60) days after achieving maximum
production rate and no later than one hundred eighty (180) days after the startup date of
the proposed equipment. The test shall be conducted with the equipment operating in a
manner representative of full rated capacity. Failure to test at this maximum may be
cause to limit the source to operating at the level at which the compliance tests were
conducted.
The owner shall furnish the DNR the following written notifications:
1. The date of intended startup at least ten (10) days before the equipment or control
equipment involved is placed into operation.
2. The actual date of startup postmarked within fifteen (15) days following the start
of operation.
Authority for Requirement: Iowa DNR Construction Permit 99-A-688-S1
Operational Limits & Requirements:
The owner/operator of this equipment shall comply with the following operational limits
and requirements.
Reporting & Recordkeeping: See Facility-Wide Emission Limits
Authority for Requirement: Iowa DNR Construction Permit 99-A-688-S1
Compliance Plan:
The owner/operator of this equipment shall comply with the following applicable
requirements.
This point is in compliance with all applicable requirements and shall continue to comply
with all such requirements. For those applicable requirements which will become
effective during the permit term, this source will comply with such requirements in a
timely manner.
Additional Requirements:
This emission point shall conform to the following conditions.
The source is to be connected to the stack of the following detailed description.
Stack Height (feet): 37.5
Stack Diameter (inches): 48.0
Stack Exhaust Flow Rate (acfm): .... 24,000
Stack Temperature (°F): ambient
Vertical, Unobstructed Discharge Required: Yes ^ No ~
Authority for Requirement: Iowa DNR Construction Permit 99-A-688-S1
183
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Periodic Monitoring Requirements:
The owner/operator of this equipment shall comply with the following periodic
monitoring requirements.
Opacity Monitoring:
The facility shall observe the opacity weekly during a period when the emission unit
associated with this emission point is at or near full capacity and record the reading
indicating if visible emissions were observed. The records shall be maintained for five
years. If weather conditions prevent the observer from conducting an opacity
observation, the observer shall note such conditions on the data observation sheet. At
least three attempts shall be made to retake opacity readings at approximately 2-hour
intervals throughout the day. If all observation attempts for a week have been
unsuccessful due to weather, an observation shall be made the next operating day where
weather permits.
Maintain a written record of the observation and any action resulting from the
observation.
Agency Approved Operation & Maintenance Plan Required? Yes ~ No Kl
Facility Maintained Operation & Maintenance Plan Required? Yes Kl NoQ
Facility operation and maintenance plans must be sufficient to yield reliable data from
the relevant time period that are representative of the source's compliance with the
applicable requirements.
Facility operation and maintenance plans are to be developed by the facility within six(6)
months of the issuance date of this permit and the data pertaining to the plan maintained
on site for at least 5 years. The plan and associated recordkeeping provides
documentation of this facility's implementation of its obligation to operate according to
good air pollution control practice.
Good air pollution control practice is achieved by adoption of quality control standards
in the operation and maintenance procedures for air pollution control that are
comparable to industry quality control standards for the production processes associated
with this emission point.
Authority for Requirement: 567 IAC 22.108(3)"b"
184
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Emission Point ID Number: 3.1
Associated Equipment
Associated Emission Unit ID Numbers (if multiple units vent thru this EP): 3.1
Applicable Requirements
(If more than one emission unit vents through this emission point subdivide the applicable requirements by emission
unit.)
Emission Unit vented through this Emission Point: 3.1
Emission Unit Description: Paint Oven
Raw Material/Fuel: Natural Gas
Rated Capacity: 2.0 MMBtu/hr.
Emission Limits (lb./hr. gr./dscf. lb./MMBtu. % opacity, etc.):
The emissions from this emission point shall not exceed the following specified levels.
Pollutant: Opacity
Emission Limits: 40%
Indicator Opacity: (1)
(1) If visible emissions are observed other than startup, shutdown or malfunction, a stack
test may be required to demonstrate compliance with the particulate standard.
Authority for Requirement: Iowa DNR Construction Permit 98-A-009-S1
567 IAC 23.3(2)"d"
Pollutant: Particulate Matter (TSP)
Emission Limit(s): 15.3 lb./MMCF of LPG or Natural Gas
Authority for Requirement: Part 7a. of State of Iowa, ex rel., Iowa DNR vs. Vermeer
Manufacturing Company, 99AG23542
District Court, Marion County, Law No. LACV087889
Pollutant: Particulate Matter (TSP)
Emission Limits: 0.1 gr./dscf
Authority for Requirement: Iowa DNR Construction Permit 98-A-009-S1
567 IAC 23.3(2)"a"
Pollutant: Sulfur Dioxide (SO2)
Emission Limits: 500 ppmv
Authority for Requirement: 567 IAC 23.3(3)"e"
Pollutant: Nitrogen Oxides (NOx)
Emission Limit(s): See Facility-Wide Conditions
Authority for Requirement: Iowa DNR Construction Permit 98-A-009-S1
185
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Emission Limits (continued):
Pollutant: Volatile Organic Compounds (VOC)
Emission Limit: See Facility-Wide Conditions
Authority for Requirement: Iowa DNR Construction Permit 98-A-009-S1
Operational Limits & Requirements:
The owner/operator of this equipment shall comply with the following operational limits
and requirements.
Process throughput:
A. This oven shall be fired by natural gas or propane only.
Reporting & Recordkeeping: See Facility-Wide Operational Limits
Authority for Requirement: Iowa DNR Construction Permit 98-A-009-S1
Process throughput:
A. The sulfur content of natural gas or LPG combusted by this source is not to
exceed 123 ppm by weight.
Reporting & Recordkeeping: See Facility-Wide Operational Limits
Authority for Requirement: Part 7b. of State of Iowa, ex rel., Iowa DNR vs. Vermeer
Manufacturing Company, 99AG23542
District Court, Marion County, Law No. LACV087889
Compliance Plan:
The owner/operator of this equipment shall comply with the following applicable
requirements.
This point is in compliance with all applicable requirements and shall continue to comply
with all such requirements. For those applicable requirements which will become
effective during the permit term, this source will comply with such requirements in a
timely manner.
Additional Requirements:
This emission point shall conform to the following conditions.
The source is to be connected to the stack of the following detailed description.
Stack Height (feet): 31.5
Stack Diameter (inches): 12.0
Stack Exhaust Flow Rate (acfm): .... 2,050
Stack Temperature (°F): 143
Vertical, Unobstructed Discharge Required: Yes ^ No ~
Authority for Requirement: Iowa DNR Construction Permit 98-A-009-S1
186
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Periodic Monitoring Requirements:
The owner/operator of this equipment shall comply with the following periodic
monitoring requirements.
Opacity Monitoring:
The facility shall observe the opacity weekly during a period when the emission unit
associated with this emission point is at or near full capacity and record the reading
indicating if visible emissions were observed. The records shall be maintained for five
years. If weather conditions prevent the observer from conducting an opacity
observation, the observer shall note such conditions on the data observation sheet. At
least three attempts shall be made to retake opacity readings at approximately 2-hour
intervals throughout the day. If all observation attempts for a week have been
unsuccessful due to weather, an observation shall be made the next operating day where
weather permits.
Maintain a written record of the observation and any action resulting from the
observation.
Agency Approved Operation & Maintenance Plan Required? Yes ~ No IEI
Facility Maintained Operation & Maintenance Plan Required? Yes ~ No Kl
Authority for Requirement: 567 IAC 22.108(3)"b"
187
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Emission Point ID Number: 3.II
Associated Equipment
Associated Emission Unit ID Numbers (if multiple units vent thru this EP): 3 .II
Emissions Control Equipment ID Number: 3.II
Emissions Control Equipment Description: Paper Filter
Applicable Requirements
(If more than one emission unit vents through this emission point subdivide the applicable requirements by emission
unit.)
Emission Unit vented through this Emission Point: 3.II
Emission Unit Description: Paint Booth
Raw Material/Fuel: Paints, Primers, and Solvents
Rated Capacity: 5.625 gal./hr.
Emission Limits (lb./hr. gr./dscf. lb./MMBtu. % opacity, etc.):
The emissions from this emission point shall not exceed the following specified levels.
Pollutant: Opacity
Emission Limits: 40%
Indicator Opacity: (1)
(1) If visible emissions are observed other than startup, shutdown or malfunction, a stack
test may be required to demonstrate compliance with the particulate standard.
Authority for Requirement: Iowa DNR Construction Permit 99-A-689-S1
567 IAC 23.3(2)"d"
Pollutant: Particulate Matter (TSP)
Emission Limit(s): 0.01 gr./dscf
Authority for Requirement: Iowa DNR Construction Permit 99-A-689-S1
567 IAC 23.4(13)
Pollutant: Volatile Organic Compounds (VOC)
Emission Limit: See Facility-Wide Conditions
Authority for Requirement: Iowa DNR Construction Permit 99-A-689-S1
188
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Compliance Testing Requirements
TSP Iowa Compliance Sampling Manual
The owner shall verify compliance with the emission limitations contained in
Construction Permit 99-A-689-S1 within sixty (60) days after achieving maximum
production rate and no later than one hundred eighty (180) days after the startup date of
the proposed equipment. The test shall be conducted with the equipment operating in a
manner representative of full rated capacity. Failure to test at this maximum may be
cause to limit the source to operating at the level at which the compliance tests were
conducted.
The owner shall furnish the DNR the following written notifications:
1. The date of intended startup at least ten (10) days before the equipment or control
equipment involved is placed into operation.
2. The actual date of startup postmarked within fifteen (15) days following the start
of operation.
Authority for Requirement: Iowa DNR Construction Permit 99-A-689-S1
Compliance Plan:
The owner/operator of this equipment shall comply with the following applicable
requirements.
This point is in compliance with all applicable requirements and shall continue to comply
with all such requirements. For those applicable requirements which will become
effective during the permit term, this source will comply with such requirements in a
timely manner.
Additional Requirements:
This emission point shall conform to the following conditions.
The source is to be connected to the stack of the following detailed description.
Stack Height (feet): 37.5
Stack Diameter (inches): 48.0
Stack Exhaust Flow Rate (acfm): .... 24,000
Stack Temperature (°F): ambient
Vertical, Unobstructed Discharge Required: Yes ^ No ~
Authority for Requirement: Iowa DNR Construction Permit 99-A-689-S1
189
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Periodic Monitoring Requirements:
The owner/operator of this equipment shall comply with the following periodic
monitoring requirements.
Opacity Monitoring:
The facility shall observe the opacity weekly during a period when the emission unit
associated with this emission point is at or near full capacity and record the reading
indicating if visible emissions were observed. The records shall be maintained for five
years. If weather conditions prevent the observer from conducting an opacity
observation, the observer shall note such conditions on the data observation sheet. At
least three attempts shall be made to retake opacity readings at approximately 2-hour
intervals throughout the day. If all observation attempts for a week have been
unsuccessful due to weather, an observation shall be made the next operating day where
weather permits.
Maintain a written record of the observation and any action resulting from the
observation.
Agency Approved Operation & Maintenance Plan Required? Yes ~ No Kl
Facility Maintained Operation & Maintenance Plan Required? Yes Kl NoQ
Facility operation and maintenance plans must be sufficient to yield reliable data from
the relevant time period that are representative of the source's compliance with the
applicable requirements.
Facility operation and maintenance plans are to be developed by the facility within six(6)
months of the issuance date of this permit and the data pertaining to the plan maintained
on site for at least 5 years. The plan and associated recordkeeping provides
documentation of this facility's implementation of its obligation to operate according to
good air pollution control practice.
Good air pollution control practice is achieved by adoption of quality control standards
in the operation and maintenance procedures for air pollution control that are
comparable to industry quality control standards for the production processes associated
with this emission point.
Authority for Requirement: 567 IAC 22.108(3)"b"
190
-------
Emission Point ID Number: 3.JJ
Associated Equipment
Associated Emission Unit ID Numbers (if multiple units vent thru this EP): 3. JJ
Applicable Requirements
(If more than one emission unit vents through this emission point subdivide the applicable requirements by emission
unit.)
Emission Unit vented through this Emission Point: 3.JJ
Emission Unit Description: Finish Paint Oven
Raw Material/Fuel: Natural Gas
Rated Capacity: 1.728 MMBtu/hr.
Emission Limits (lb./hr. gr./dscf. lb./MMBtu. % opacity, etc.):
The emissions from this emission point shall not exceed the following specified levels.
Pollutant: Opacity
Emission Limits: 40%
Indicator Opacity: (1)
(1) If visible emissions are observed other than startup, shutdown or malfunction, a stack
test may be required to demonstrate compliance with the particulate standard.
Authority for Requirement: Iowa DNR Construction Permit 99-A-686
567 IAC 23.3(2)"d"
Pollutant: Particulate Matter (TSP)
Emission Limit(s): 15.3 lb./MMCF of LPG or Natural Gas
Authority for Requirement: Part 7a. of State of Iowa, ex rel., Iowa DNR vs. Vermeer
Manufacturing Company, 99AG23542
District Court, Marion County, Law No. LACV087889
Pollutant: Particulate Matter (TSP)
Emission Limits: 0.1 gr./dscf
Authority for Requirement: Iowa DNR Construction Permit 99-A-686
567 IAC 23.3(2)"a"
Pollutant: Sulfur Dioxide (SO2)
Emission Limits: 500 ppmv
Authority for Requirement: 567 IAC 23.3(3)"e"
Pollutant: Nitrogen Oxides (NOx)
Emission Limit(s): See Facility-Wide Conditions
Authority for Requirement: Iowa DNR Construction Permit 99-A-686
191
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Emission Limits (continued):
Pollutant: Volatile Organic Compounds (VOC)
Emission Limit: See Facility-Wide Conditions
Authority for Requirement: Iowa DNR Construction Permit 99-A-686
Operational Limits & Requirements:
The owner/operator of this equipment shall comply with the following operational limits
and requirements.
Process throughput:
A. This oven shall be fired by natural gas or propane only.
Reporting & Recordkeeping: See Facility-Wide Operational Limits
Authority for Requirement: Iowa DNR Construction Permit 99-A-686
Process throughput:
A. The sulfur content of natural gas or LPG combusted by this source is not to
exceed 123 ppm by weight.
Reporting & Recordkeeping: See Facility-Wide Operational Limits
Authority for Requirement: Part 7b. of State of Iowa, ex rel., Iowa DNR vs. Vermeer
Manufacturing Company, 99AG23542
District Court, Marion County, Law No. LACV087889
Compliance Plan:
The owner/operator of this equipment shall comply with the following applicable
requirements.
This point is in compliance with all applicable requirements and shall continue to comply
with all such requirements. For those applicable requirements which will become
effective during the permit term, this source will comply with such requirements in a
timely manner.
Additional Requirements:
This emission point shall conform to the following conditions.
The source is to be connected to the stack of the following detailed description.
Stack Height (feet): 35.5
Stack Diameter (inches): 10.0
Stack Exhaust Flow Rate (acfm): .... 446
Stack Temperature (°F): 180
Vertical, Unobstructed Discharge Required: Yes ^ No ~
Authority for Requirement: Iowa DNR Construction Permit 99-A-686
192
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Periodic Monitoring Requirements:
The owner/operator of this equipment shall comply with the following periodic
monitoring requirements.
Opacity Monitoring:
The facility shall observe the opacity weekly during a period when the emission unit
associated with this emission point is at or near full capacity and record the reading
indicating if visible emissions were observed. The records shall be maintained for five
years. If weather conditions prevent the observer from conducting an opacity
observation, the observer shall note such conditions on the data observation sheet. At
least three attempts shall be made to retake opacity readings at approximately 2-hour
intervals throughout the day. If all observation attempts for a week have been
unsuccessful due to weather, an observation shall be made the next operating day where
weather permits.
Maintain a written record of the observation and any action resulting from the
observation.
Agency Approved Operation & Maintenance Plan Required? Yes ~ No IEI
Facility Maintained Operation & Maintenance Plan Required? Yes ~ No Kl
Authority for Requirement: 567 IAC 22.108(3)"b"
193
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Emission Point ID Number: 3.KK
Associated Equipment
Associated Emission Unit ID Numbers (if multiple units vent thru this EP): 3 .KK
Applicable Requirements
(If more than one emission unit vents through this emission point subdivide the applicable requirements by emission
unit.)
Emission Unit vented through this Emission Point: 3.KK
Emission Unit Description: Paint Kitchen
Raw Material/Fuel: Paints, Primers, and Solvents
Rated Capacity: 6 Barrels
Emission Limits (lb./hr. gr./dscf. lb./MMBtu. % opacity, etc.):
The emissions from this emission point shall not exceed the following specified levels.
Pollutant: Volatile Organic Compounds (VOC)
Emission Limit: See Facility-Wide Conditions
Authority for Requirement: Iowa DNR Construction Permit 99-A-684
Compliance Plan:
The owner/operator of this equipment shall comply with the following applicable
requirements.
This point is in compliance with all applicable requirements and shall continue to comply
with all such requirements. For those applicable requirements which will become
effective during the permit term, this source will comply with such requirements in a
timely manner.
Additional Requirements:
This emission point shall conform to the following conditions.
The source is to be connected to the stack of the following detailed description.
Stack Height (feet): 42
Stack Diameter (inches): 24
Stack Exhaust Flow Rate (acfm): .... 7,000
Stack Temperature (°F): ambient
Vertical, Unobstructed Discharge Required: Yes ^ No ~
Authority for Requirement: Iowa DNR Construction Permit 99-A-684
194
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Periodic Monitoring Requirements:
The owner/operator of this equipment shall comply with the following periodic
monitoring requirements.
Agency Approved Operation & Maintenance Plan Required? Yes ~ No Kl
Facility Maintained Operation & Maintenance Plan Required? Yes ~ No Kl
Authority for Requirement: 567 IAC 22.108(3)"b"
195
-------
Emission Point ID Number: 3.M
Associated Equipment
Associated Emission Unit ID Numbers (if multiple units vent thru this EP): 3 .M
Applicable Requirements
(If more than one emission unit vents through this emission point subdivide the applicable requirements by emission
unit.)
Emission Unit vented through this Emission Point: 3.M
Emission Unit Description: Hot Water Heater
Raw Material/Fuel: Natural Gas
Rated Capacity: 0.528 MMBtu/hr.
Emission Limits (lb./hr. gr./dscf. lb./MMBtu. % opacity, etc.):
The emissions from this emission point shall not exceed the following specified levels.
Pollutant: Opacity
Emission Limit(s): 40 %
Authority for Requirement: 567 IAC 23.3(2)"d"
Pollutant: Particulate Matter (TSP)
Emission Limit(s): 15.3 lb./MMCF of LPG or Natural Gas
Authority for Requirement: Part 7a. of State of Iowa, ex rel., Iowa DNR vs. Vermeer
Manufacturing Company, 99AG23542
District Court, Marion County, Law No. LACV087889
Pollutant: Particulate Matter (TSP)
Emission Limits: 0.8 lb./MMBtu
Authority for Requirement: 567 IAC 23.3(2)"b"
Pollutant: Sulfur Dioxide (SO2)
Emission Limits: 500 ppmv
Authority for Requirement: 567 IAC 23.3(3)"e"
Pollutant: Nitrogen Oxides (NOx)
Emission Limit(s): See Facility-Wide Conditions
Authority for Requirement: Iowa DNR Construction Permit 98-A-003-S1
Pollutant: Volatile Organic Compounds (VOC)
Emission Limit: See Facility-Wide Conditions
Authority for Requirement: Iowa DNR Construction Permit 98-A-003-S1
196
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Operational Limits & Requirements:
The owner/operator of this equipment shall comply with the following operational limits
and requirements.
Process throughput:
A. The sulfur content of natural gas or LPG combusted by this source is not to
exceed 123 ppm by weight.
Reporting & Recordkeeping: See Facility-Wide Operational Limits
Authority for Requirement: Part 7b. of State of Iowa, ex rel., Iowa DNR vs. Vermeer
Manufacturing Company, 99AG23542
District Court, Marion County, Law No. LACV087889
Compliance Plan:
The owner/operator of this equipment shall comply with the following applicable
requirements.
This point is in compliance with all applicable requirements and shall continue to comply
with all such requirements. For those applicable requirements which will become
effective during the permit term, this source will comply with such requirements in a
timely manner.
Periodic Monitoring Requirements:
The owner/operator of this equipment shall comply with the following periodic
monitoring requirements.
Agency Approved Operation & Maintenance Plan Required? Yes ~ No IXI
Facility Maintained Operation & Maintenance Plan Required? Yes ~ No Kl
Authority for Requirement: 567 IAC 22.108(3)"b"
197
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Emission Point ID Number: 3.N2
Associated Equipment
Associated Emission Unit ID Numbers (if multiple units vent thru this EP): 3 ,N2
Applicable Requirements
(If more than one emission unit vents through this emission point subdivide the applicable requirements by emission
unit.)
Emission Unit vented through this Emission Point: 3,N2
Emission Unit Description: Non-Production Heating Unit
Raw Material/Fuel: Natural Gas
Rated Capacity: 4.86 MMBtu/hr.
Emission Limits (lb./hr. gr./dscf. lb./MMBtu. % opacity, etc.):
The emissions from this emission point shall not exceed the following specified levels.
Pollutant: Opacity
Emission Limit(s): 40 %
Authority for Requirement: 567 IAC 23.3(2)"d"
Pollutant: Particulate Matter (TSP)
Emission Limit(s): 15.3 lb./MMCF of LPG or Natural Gas
Authority for Requirement: Part 7a. of State of Iowa, ex rel., Iowa DNR vs. Vermeer
Manufacturing Company, 99AG23542
District Court, Marion County, Law No. LACV087889
Pollutant: Particulate Matter (TSP)
Emission Limits: 0.8 lb./MMBtu
Authority for Requirement: 567 IAC 23.3(2)"b"
Pollutant: Sulfur Dioxide (SO2)
Emission Limits: 500 ppmv
Authority for Requirement: 567 IAC 23.3(3)"e"
Pollutant: Nitrogen Oxides (NOx)
Emission Limit(s): See Facility-Wide Conditions
Authority for Requirement: Iowa DNR Construction Permit 98-A-003-S1
Pollutant: Volatile Organic Compounds (VOC)
Emission Limit: See Facility-Wide Conditions
Authority for Requirement: Iowa DNR Construction Permit 98-A-003-S1
198
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Operational Limits & Requirements:
The owner/operator of this equipment shall comply with the following operational limits
and requirements.
Process throughput:
A. The sulfur content of natural gas or LPG combusted by this source is not to
exceed 123 ppm by weight.
Reporting & Recordkeeping: See Facility-Wide Operational Limits
Authority for Requirement: Part 7b. of State of Iowa, ex rel., Iowa DNR vs. Vermeer
Manufacturing Company, 99AG23542
District Court, Marion County, Law No. LACV087889
Compliance Plan:
The owner/operator of this equipment shall comply with the following applicable
requirements.
This point is in compliance with all applicable requirements and shall continue to comply
with all such requirements. For those applicable requirements which will become
effective during the permit term, this source will comply with such requirements in a
timely manner.
Periodic Monitoring Requirements:
The owner/operator of this equipment shall comply with the following periodic
monitoring requirements.
Agency Approved Operation & Maintenance Plan Required? Yes ~ No IXI
Facility Maintained Operation & Maintenance Plan Required? Yes ~ No Kl
Authority for Requirement: 567 IAC 22.108(3)"b"
199
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Emission Point ID Number: 3.P
Associated Equipment
Associated Emission Unit ID Numbers (if multiple units vent thru this EP): 3 .P
Applicable Requirements
(If more than one emission unit vents through this emission point subdivide the applicable requirements by emission
unit.)
Emission Unit vented through this Emission Point: 3.P
Emission Unit Description: Non-Production Heating Unit
Raw Material/Fuel: Natural Gas
Rated Capacity: 6.25 MMBtu/hr.
Emission Limits (lb./hr. gr./dscf. lb./MMBtu. % opacity, etc.):
The emissions from this emission point shall not exceed the following specified levels.
Pollutant: Opacity
Emission Limit(s): 40 %
Authority for Requirement: 567 IAC 23.3(2)"d"
Pollutant: Particulate Matter (TSP)
Emission Limit(s): 15.3 lb./MMCF of LPG or Natural Gas
Authority for Requirement: Part 7a. of State of Iowa, ex rel., Iowa DNR vs. Vermeer
Manufacturing Company, 99AG23542
District Court, Marion County, Law No. LACV087889
Pollutant: Particulate Matter (TSP)
Emission Limits: 0.8 lb./MMBtu
Authority for Requirement: 567 IAC 23.3(2)"b"
Pollutant: Sulfur Dioxide (SO2)
Emission Limits: 500 ppmv
Authority for Requirement: 567 IAC 23.3(3)"e"
Pollutant: Nitrogen Oxides (NOx)
Emission Limit(s): See Facility-Wide Conditions
Authority for Requirement: Iowa DNR Construction Permit 98-A-003-S1
Pollutant: Volatile Organic Compounds (VOC)
Emission Limit: See Facility-Wide Conditions
Authority for Requirement: Iowa DNR Construction Permit 98-A-003-S1
200
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Operational Limits & Requirements:
The owner/operator of this equipment shall comply with the following operational limits
and requirements.
Process throughput:
A. The sulfur content of natural gas or LPG combusted by this source is not to
exceed 123 ppm by weight.
Reporting & Recordkeeping: See Facility-Wide Operational Limits
Authority for Requirement: Part 7b. of State of Iowa, ex rel., Iowa DNR vs. Vermeer
Manufacturing Company, 99AG23542
District Court, Marion County, Law No. LACV087889
Compliance Plan:
The owner/operator of this equipment shall comply with the following applicable
requirements.
This point is in compliance with all applicable requirements and shall continue to comply
with all such requirements. For those applicable requirements which will become
effective during the permit term, this source will comply with such requirements in a
timely manner.
Periodic Monitoring Requirements:
The owner/operator of this equipment shall comply with the following periodic
monitoring requirements.
Agency Approved Operation & Maintenance Plan Required? Yes ~ No IXI
Facility Maintained Operation & Maintenance Plan Required? Yes ~ No Kl
Authority for Requirement: 567 IAC 22.108(3)"b"
201
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Emission Point ID Number: 3.PLASMA1
Associated Equipment
Associated Emission Unit ID Numbers (if multiple units vent thru this EP): 3 .PLASMA1
Applicable Requirements
(If more than one emission unit vents through this emission point subdivide the applicable requirements by emission
unit.)
Emission Unit vented through this Emission Point: 3.PLASMA1 (Fugitive)
Emission Unit Description: Single Head Plasma Cutting
Machine
Raw Material/Fuel: Sheet Steel
Rated Capacity: 4,500 inches of metal cut/hr.
Emission Limits (lb./hr. gr./dscf. lb./MMBtu. % opacity, etc.):
The emissions from this emission point shall not exceed the following specified levels.
Pollutant: Fugitive Dust
Emission Limit: No person shall allow, cause or permit any materials to be handled,
transported or stored; or a building, its appurtenances or a construction haul road to
be used, constructed, altered , repaired or demolished, without taking reasonable
precautions to prevent a nuisance. All persons shall take reasonable precautions to
prevent the discharge of visible emissions of fugitive dusts beyond the lot line of the
property on which the emissions originate.
Authority for Requirement: 567 IAC 23.3(2)"c"
Compliance Plan:
The owner/operator of this equipment shall comply with the following applicable
requirements.
This point is in compliance with all applicable requirements and shall continue to comply
with all such requirements. For those applicable requirements which will become
effective during the permit term, this source will comply with such requirements in a
timely manner.
Periodic Monitoring Requirements:
The owner/operator of this equipment shall comply with the following periodic
monitoring requirements.
Agency Approved Operation & Maintenance Plan Required? Yes ~ No IXI
Facility Maintained Operation & Maintenance Plan Required? Yes ~ No Kl
Authority for Requirement: 567 IAC 22.108(3)"b"
202
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Emission Point ID Number: 3.PLASMA2
Associated Equipment
Associated Emission Unit ID Numbers (if multiple units vent thru this EP): 3 .PLASMA2
Applicable Requirements
(If more than one emission unit vents through this emission point subdivide the applicable requirements by emission
unit.)
Emission Unit vented through this Emission Point: 3.PLASMA2 (Fugitive)
Emission Unit Description: Single Head Plasma Cutting
Machine
Raw Material/Fuel: Sheet Steel
Rated Capacity: 4,500 inches of metal cut/hr.
Emission Limits (lb./hr. gr./dscf. lb./MMBtu. % opacity, etc.):
The emissions from this emission point shall not exceed the following specified levels.
Pollutant: Fugitive Dust
Emission Limit: No person shall allow, cause or permit any materials to be handled,
transported or stored; or a building, its appurtenances or a construction haul road to
be used, constructed, altered , repaired or demolished, without taking reasonable
precautions to prevent a nuisance. All persons shall take reasonable precautions to
prevent the discharge of visible emissions of fugitive dusts beyond the lot line of the
property on which the emissions originate.
Authority for Requirement: 567 IAC 23.3(2)"c"
Compliance Plan:
The owner/operator of this equipment shall comply with the following applicable
requirements.
This point is in compliance with all applicable requirements and shall continue to comply
with all such requirements. For those applicable requirements which will become
effective during the permit term, this source will comply with such requirements in a
timely manner.
Periodic Monitoring Requirements:
The owner/operator of this equipment shall comply with the following periodic
monitoring requirements.
Agency Approved Operation & Maintenance Plan Required? Yes ~ No IXI
Facility Maintained Operation & Maintenance Plan Required? Yes ~ No Kl
Authority for Requirement: 567 IAC 22.108(3)"b"
203
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Emission Point ID Number: 3.PLASMA3
Associated Equipment
Associated Emission Unit ID Numbers (if multiple units vent thru this EP): 3 .PLASMA3
Applicable Requirements
(If more than one emission unit vents through this emission point subdivide the applicable requirements by emission
unit.)
Emission Unit vented through this Emission Point: 3.PLASMA3 (Fugitive)
Emission Unit Description: Single Head Plasma Cutting
Machine
Raw Material/Fuel: Sheet Steel
Rated Capacity: 4,500 inches of metal cut/hr.
Emission Limits (lb./hr. gr./dscf. lb./MMBtu. % opacity, etc.):
The emissions from this emission point shall not exceed the following specified levels.
Pollutant: Fugitive Dust
Emission Limit: No person shall allow, cause or permit any materials to be handled,
transported or stored; or a building, its appurtenances or a construction haul road to
be used, constructed, altered , repaired or demolished, without taking reasonable
precautions to prevent a nuisance. All persons shall take reasonable precautions to
prevent the discharge of visible emissions of fugitive dusts beyond the lot line of the
property on which the emissions originate.
Authority for Requirement: 567 IAC 23.3(2)"c"
Compliance Plan:
The owner/operator of this equipment shall comply with the following applicable
requirements.
This point is in compliance with all applicable requirements and shall continue to comply
with all such requirements. For those applicable requirements which will become
effective during the permit term, this source will comply with such requirements in a
timely manner.
Periodic Monitoring Requirements:
The owner/operator of this equipment shall comply with the following periodic
monitoring requirements.
Agency Approved Operation & Maintenance Plan Required? Yes ~ No IXI
Facility Maintained Operation & Maintenance Plan Required? Yes ~ No Kl
Authority for Requirement: 567 IAC 22.108(3)"b"
204
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Emission Point ID Number: 3.PLASMA4
Associated Equipment
Associated Emission Unit ID Numbers (if multiple units vent thru this EP): 3 .PLASMA4
Emissions Control Equipment ID Number: 3.PLASMA4
Emissions Control Equipment Description: Baghouse
Applicable Requirements
(If more than one emission unit vents through this emission point subdivide the applicable requirements by emission
unit.)
Emission Unit vented through this Emission Point: 3.PLASMA4 (Fugitive)
Emission Unit Description: Single Head Whitney Plasma Cutting
Machine
Raw Material/Fuel: Sheet Steel
Rated Capacity: 12,000 inches of metal cut/hr.
Emission Limits (lb./hr. gr./dscf. lb./MMBtu. % opacity, etc.):
The emissions from this emission point shall not exceed the following specified levels.
Pollutant: Fugitive Dust
Emission Limit: No person shall allow, cause or permit any materials to be handled,
transported or stored; or a building, its appurtenances or a construction haul road to
be used, constructed, altered , repaired or demolished, without taking reasonable
precautions to prevent a nuisance. All persons shall take reasonable precautions to
prevent the discharge of visible emissions of fugitive dusts beyond the lot line of the
property on which the emissions originate.
Authority for Requirement: 567 IAC 23.3(2)"c"
Compliance Plan:
The owner/operator of this equipment shall comply with the following applicable
requirements.
This point is in compliance with all applicable requirements and shall continue to comply
with all such requirements. For those applicable requirements which will become
effective during the permit term, this source will comply with such requirements in a
timely manner.
Periodic Monitoring Requirements:
The owner/operator of this equipment shall comply with the following periodic
monitoring requirements.
Agency Approved Operation & Maintenance Plan Required? Yes ~ No Kl
Facility Maintained Operation & Maintenance Plan Required? Yes ~ No Kl
Authority for Requirement: 567 IAC 22.108(3)"b"
205
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Emission Point ID Number: 3.PLASMA5
Associated Equipment
Associated Emission Unit ID Numbers (if multiple units vent thru this EP): 3 .PLASMA5
Emissions Control Equipment ID Number: 3.PLASMA5
Emissions Control Equipment Description: Baghouse
Applicable Requirements
(If more than one emission unit vents through this emission point subdivide the applicable requirements by emission
unit.)
Emission Unit vented through this Emission Point: 3.PLASMA5 (Fugitive)
Emission Unit Description: Single Head Whitney Plasma Cutting
Machine
Raw Material/Fuel: Sheet Steel
Rated Capacity: 12,000 inches of metal cut/hr.
Emission Limits (lb./hr. gr./dscf. lb./MMBtu. % opacity, etc.):
The emissions from this emission point shall not exceed the following specified levels.
Pollutant: Fugitive Dust
Emission Limit: No person shall allow, cause or permit any materials to be handled,
transported or stored; or a building, its appurtenances or a construction haul road to
be used, constructed, altered , repaired or demolished, without taking reasonable
precautions to prevent a nuisance. All persons shall take reasonable precautions to
prevent the discharge of visible emissions of fugitive dusts beyond the lot line of the
property on which the emissions originate.
Authority for Requirement: 567 IAC 23.3(2)"c"
Compliance Plan:
The owner/operator of this equipment shall comply with the following applicable
requirements.
This point is in compliance with all applicable requirements and shall continue to comply
with all such requirements. For those applicable requirements which will become
effective during the permit term, this source will comply with such requirements in a
timely manner.
Periodic Monitoring Requirements:
The owner/operator of this equipment shall comply with the following periodic
monitoring requirements.
Agency Approved Operation & Maintenance Plan Required? Yes ~ No Kl
Facility Maintained Operation & Maintenance Plan Required? Yes ~ No Kl
Authority for Requirement: 567 IAC 22.108(3)"b"
206
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Emission Point ID Number: 3.PLASMA6
Associated Equipment
Associated Emission Unit ID Numbers (if multiple units vent thru this EP): 3 .PLASMA6
Emissions Control Equipment ID Number: 3.PLASMA6
Emissions Control Equipment Description: Water Table
Applicable Requirements
(If more than one emission unit vents through this emission point subdivide the applicable requirements by emission
unit.)
Emission Unit vented through this Emission Point: 3.PLASMA6 (Fugitive)
Emission Unit Description: Single Head Whitney Plasma Cutting
Machine
Raw Material/Fuel: Sheet Steel
Rated Capacity: 12,000 inches of metal cut/hr.
Emission Limits (lb./hr. gr./dscf. lb./MMBtu. % opacity, etc.):
The emissions from this emission point shall not exceed the following specified levels.
Pollutant: Fugitive Dust
Emission Limit: No person shall allow, cause or permit any materials to be handled,
transported or stored; or a building, its appurtenances or a construction haul road to
be used, constructed, altered , repaired or demolished, without taking reasonable
precautions to prevent a nuisance. All persons shall take reasonable precautions to
prevent the discharge of visible emissions of fugitive dusts beyond the lot line of the
property on which the emissions originate.
Authority for Requirement: 567 IAC 23.3(2)"c"
Compliance Plan:
The owner/operator of this equipment shall comply with the following applicable
requirements.
This point is in compliance with all applicable requirements and shall continue to comply
with all such requirements. For those applicable requirements which will become
effective during the permit term, this source will comply with such requirements in a
timely manner.
Periodic Monitoring Requirements:
The owner/operator of this equipment shall comply with the following periodic
monitoring requirements.
Agency Approved Operation & Maintenance Plan Required? Yes ~ No Kl
Facility Maintained Operation & Maintenance Plan Required? Yes ~ No Kl
Authority for Requirement: 567 IAC 22.108(3)"b"
207
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Emission Point ID Number: 3.PRTWSH
Associated Equipment
Associated Emission Unit ID Numbers (if multiple units vent thru this EP): 3 .PRTWSH
Applicable Requirements
(If more than one emission unit vents through this emission point subdivide the applicable requirements by emission
unit.)
Emission Unit vented through this Emission Point: 3.PRTWSH (Fugitive)
Emission Unit Description: Three (3) Safety Kleen Parts
Washers
Raw Material/Fuel: Stoddard Solvent
Rated Capacity: 55 Gallons Solvent per Washer
Emission Limits (lb./hr. gr./dscf. lb./MMBtu. % opacity, etc.):
The emissions from this emission point shall not exceed the following specified levels.
Pollutant: Volatile Organic Compounds (VOC)
Emission Limit: See Facility-Wide Conditions
Authority for Requirement: Iowa DNR Construction Permit 98-A-003-S1
Compliance Plan:
The owner/operator of this equipment shall comply with the following applicable
requirements.
This point is in compliance with all applicable requirements and shall continue to comply
with all such requirements. For those applicable requirements which will become
effective during the permit term, this source will comply with such requirements in a
timely manner.
Periodic Monitoring Requirements:
The owner/operator of this equipment shall comply with the following periodic
monitoring requirements.
Agency Approved Operation & Maintenance Plan Required? Yes ~ No Kl
Facility Maintained Operation & Maintenance Plan Required? Yes ~ No Kl
Authority for Requirement: 567 IAC 22.108(3)"b"
208
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Emission Point ID Number: 3.S
Associated Equipment
Associated Emission Unit ID Numbers (if multiple units vent thru this EP): 3. S
Applicable Requirements
(If more than one emission unit vents through this emission point subdivide the applicable requirements by emission
unit.)
Emission Unit vented through this Emission Point: 3.S
Emission Unit Description: Production Engine Testing Unit
Raw Material/Fuel: #2 Diesel Fuel and Gasoline
Rated Capacity: 54.5 gal./hr.
Emission Limits (lb./hr. gr./dscf. lb./MMBtu. % opacity, etc.):
The emissions from this emission point shall not exceed the following specified levels.
Pollutant: Opacity
Emission Limits: 40%
Indicator Opacity: 25%(1)
(1) If visible emissions are observed that exceed the indicator opacity other than startup,
shutdown or malfunction, a stack test may be required to demonstrate compliance with
the particulate standard.
Authority for Requirement: Iowa DNR Construction Permit 97-A-l 105-S2
567 IAC 23.3(2)"d"
Pollutant: Particulate Matter (TSP)
Emission Limits: 0.1 gr./dscf
Authority for Requirement: Iowa DNR Construction Permit 97-A-l 105-S2
567 IAC 23.3(2)"a"
Pollutant: Sulfur Dioxide (SO2)
Emission Limits: 2.5 lb./MMBtu
Authority for Requirement: Iowa DNR Construction Permit 97-A-l 105-S2
567 IAC 23.3(3)"b"
Pollutant: Nitrogen Oxides (NOx)
Emission Limit(s): See Facility-Wide Conditions
Authority for Requirement: Iowa DNR Construction Permit 97-A-l 105-S2
Pollutant: Volatile Organic Compounds (VOC)
Emission Limit: See Facility-Wide Conditions
Authority for Requirement: Iowa DNR Construction Permit 97-A-l 105-S2
209
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Operational Limits & Requirements:
The owner/operator of this equipment shall comply with the following operational limits
and requirements.
Process Throughput:
A. The sulfur content of any diesel fuel used in this source shall not exceed 0.4% by
weight.
Reporting & Recordkeeping: See Facility-Wide Emission and Operational Limits
Authority for Requirement: Iowa DNR Construction Permit 97-A-l 105-S2
Compliance Plan:
The owner/operator of this equipment shall comply with the following applicable
requirements.
This point is in compliance with all applicable requirements and shall continue to comply
with all such requirements. For those applicable requirements which will become
effective during the permit term, this source will comply with such requirements in a
timely manner.
Additional Requirements:
This emission point shall conform to the following conditions.
The source is to be connected to the stack of the following detailed description.
Stack Height (feet): 37
Stack Diameter (inches): 12
Stack Exhaust Flow Rate (acfm): .... 6210
Stack Temperature (°F): 759
Vertical, Unobstructed Discharge Required: Yes ^ No ~
Authority for Requirement: Iowa DNR Construction Permit 97-A-l 105-S2
Periodic Monitoring Requirements:
The owner/operator of this equipment shall comply with the following periodic
monitoring requirements.
Opacity Monitoring:
The facility shall observe the opacity weekly during a period when the emission unit
associated with this emission point is at or near full capacity and record the reading
indicating if visible emissions were observed. The records shall be maintained for five
years. If weather conditions prevent the observer from conducting an opacity
observation, the observer shall note such conditions on the data observation sheet. At
least three attempts shall be made to retake opacity readings at approximately 2-hour
intervals throughout the day. If all observation attempts for a week have been
unsuccessful due to weather, an observation shall be made the next operating day where
weather permits.
Maintain a written record of the observation and any action resulting from the
observation.
210
-------
Agency Approved Operation & Maintenance Plan Required? Yes ~ No Kl
Facility Maintained Operation & Maintenance Plan Required? Yes ~ No Kl
Authority for Requirement: 567 IAC 22.108(3)"b"
211
-------
Emission Point ID Number: 3.T
Associated Equipment
Associated Emission Unit ID Numbers (if multiple units vent thru this EP): 3 T
Applicable Requirements
(If more than one emission unit vents through this emission point subdivide the applicable requirements by emission
unit.)
Emission Unit vented through this Emission Point: 3 T
Emission Unit Description: Non-Production Heating Unit
Raw Material/Fuel: Natural Gas
Rated Capacity: 0.18 MMBtu/hr.
Emission Limits (lb./hr. gr./dscf. lb./MMBtu. % opacity, etc.):
The emissions from this emission point shall not exceed the following specified levels.
Pollutant: Opacity
Emission Limit(s): 40 %
Authority for Requirement: 567 IAC 23.3(2)"d"
Pollutant: Particulate Matter (TSP)
Emission Limit(s): 15.3 lb./MMCF of LPG or Natural Gas
Authority for Requirement: Part 7a. of State of Iowa, ex rel., Iowa DNR vs. Vermeer
Manufacturing Company, 99AG23542
District Court, Marion County, Law No. LACV087889
Pollutant: Particulate Matter (TSP)
Emission Limits: 0.8 lb./MMBtu
Authority for Requirement: 567 IAC 23.3(2)"b"
Pollutant: Sulfur Dioxide (SO2)
Emission Limits: 500 ppmv
Authority for Requirement: 567 IAC 23.3(3)"e"
Pollutant: Nitrogen Oxides (NOx)
Emission Limit(s): See Facility-Wide Conditions
Authority for Requirement: Iowa DNR Construction Permit 98-A-003-S1
Pollutant: Volatile Organic Compounds (VOC)
Emission Limit: See Facility-Wide Conditions
Authority for Requirement: Iowa DNR Construction Permit 98-A-003-S1
212
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Operational Limits & Requirements:
The owner/operator of this equipment shall comply with the following operational limits
and requirements.
Process throughput:
A. The sulfur content of natural gas or LPG combusted by this source is not to
exceed 123 ppm by weight.
Reporting & Recordkeeping: See Facility-Wide Operational Limits
Authority for Requirement: Part 7b. of State of Iowa, ex rel., Iowa DNR vs. Vermeer
Manufacturing Company, 99AG23542
District Court, Marion County, Law No. LACV087889
Compliance Plan:
The owner/operator of this equipment shall comply with the following applicable
requirements.
This point is in compliance with all applicable requirements and shall continue to comply
with all such requirements. For those applicable requirements which will become
effective during the permit term, this source will comply with such requirements in a
timely manner.
Periodic Monitoring Requirements:
The owner/operator of this equipment shall comply with the following periodic
monitoring requirements.
Agency Approved Operation & Maintenance Plan Required? Yes ~ No IXI
Facility Maintained Operation & Maintenance Plan Required? Yes ~ No Kl
Authority for Requirement: 567 IAC 22.108(3)"b"
213
-------
Emission Point ID Number: 3.TORCH
Associated Equipment
Associated Emission Unit ID Numbers (if multiple units vent thru this EP): 3 .TORCH
Applicable Requirements
(If more than one emission unit vents through this emission point subdivide the applicable requirements by emission
unit.)
Emission Unit vented through this Emission Point: 3.TORCH (Fugitive)
Emission Unit Description: Seventeen (17) Single Cutting Head
Oxyacetylene Torch Units
Raw Material/Fuel: Sheet Steel
Rated Capacity: 840 inches of metal cut/hr. per Head
Emission Limits (lb./hr. gr./dscf. lb./MMBtu. % opacity, etc.):
The emissions from this emission point shall not exceed the following specified levels.
Pollutant: Fugitive Dust
Emission Limit: No person shall allow, cause or permit any materials to be handled,
transported or stored; or a building, its appurtenances or a construction haul road to
be used, constructed, altered , repaired or demolished, without taking reasonable
precautions to prevent a nuisance. All persons shall take reasonable precautions to
prevent the discharge of visible emissions of fugitive dusts beyond the lot line of the
property on which the emissions originate.
Authority for Requirement: 567 IAC 23.3(2)"c"
Compliance Plan:
The owner/operator of this equipment shall comply with the following applicable
requirements.
This point is in compliance with all applicable requirements and shall continue to comply
with all such requirements. For those applicable requirements which will become
effective during the permit term, this source will comply with such requirements in a
timely manner.
Periodic Monitoring Requirements:
The owner/operator of this equipment shall comply with the following periodic
monitoring requirements.
Agency Approved Operation & Maintenance Plan Required? Yes ~ No IXI
Facility Maintained Operation & Maintenance Plan Required? Yes ~ No Kl
Authority for Requirement: 567 IAC 22.108(3)"b"
214
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Emission Point ID Number: 3.W
Associated Equipment
Associated Emission Unit ID Numbers (if multiple units vent thru this EP): 3. W
Applicable Requirements
(If more than one emission unit vents through this emission point subdivide the applicable requirements by emission
unit.)
Emission Unit vented through this Emission Point: 3.W
Emission Unit Description: Non-Production Heating Unit
Raw Material/Fuel: Natural Gas
Rated Capacity: 1.5 MMBtu/hr.
Emission Limits (lb./hr. gr./dscf. lb./MMBtu. % opacity, etc.):
The emissions from this emission point shall not exceed the following specified levels.
Pollutant: Opacity
Emission Limit(s): 40 %
Authority for Requirement: 567 IAC 23.3(2)"d"
Pollutant: Particulate Matter (TSP)
Emission Limit(s): 15.3 lb./MMCF of LPG or Natural Gas
Authority for Requirement: Part 7a. of State of Iowa, ex rel., Iowa DNR vs. Vermeer
Manufacturing Company, 99AG23542
District Court, Marion County, Law No. LACV087889
Pollutant: Particulate Matter (TSP)
Emission Limits: 0.8 lb./MMBtu
Authority for Requirement: 567 IAC 23.3(2)"b"
Pollutant: Sulfur Dioxide (SO2)
Emission Limits: 500 ppmv
Authority for Requirement: 567 IAC 23.3(3)"e"
Pollutant: Nitrogen Oxides (NOx)
Emission Limit(s): See Facility-Wide Conditions
Authority for Requirement: Iowa DNR Construction Permit 98-A-003-S1
Pollutant: Volatile Organic Compounds (VOC)
Emission Limit: See Facility-Wide Conditions
Authority for Requirement: Iowa DNR Construction Permit 98-A-003-S1
215
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Operational Limits & Requirements:
The owner/operator of this equipment shall comply with the following operational limits
and requirements.
Process throughput:
A. The sulfur content of natural gas or LPG combusted by this source is not to
exceed 123 ppm by weight.
Reporting & Recordkeeping: See Facility-Wide Operational Limits
Authority for Requirement: Part 7b. of State of Iowa, ex rel., Iowa DNR vs. Vermeer
Manufacturing Company, 99AG23542
District Court, Marion County, Law No. LACV087889
Compliance Plan:
The owner/operator of this equipment shall comply with the following applicable
requirements.
This point is in compliance with all applicable requirements and shall continue to comply
with all such requirements. For those applicable requirements which will become
effective during the permit term, this source will comply with such requirements in a
timely manner.
Periodic Monitoring Requirements:
The owner/operator of this equipment shall comply with the following periodic
monitoring requirements.
Agency Approved Operation & Maintenance Plan Required? Yes ~ No IXI
Facility Maintained Operation & Maintenance Plan Required? Yes ~ No Kl
Authority for Requirement: 567 IAC 22.108(3)"b"
216
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Emission Point ID Number: 3.WELDING
Associated Equipment
Associated Emission Unit ID Numbers (if multiple units vent thru this EP): 3 .WELDING
Applicable Requirements
(If more than one emission unit vents through this emission point subdivide the applicable requirements by emission
unit.)
Emission Unit vented through this Emission Point: 3.WELDING (Fugitive)
Emission Unit Description: 64 GMAW Units
Raw Material/Fuel: E70S Weld Wire
Rated Capacity: 19 lb. ofWire/hr. per Unit
Emission Limits (lb./hr. gr./dscf. lb./MMBtu. % opacity, etc.):
The emissions from this emission point shall not exceed the following specified levels.
Pollutant: Fugitive Dust
Emission Limit: No person shall allow, cause or permit any materials to be handled,
transported or stored; or a building, its appurtenances or a construction haul road to
be used, constructed, altered , repaired or demolished, without taking reasonable
precautions to prevent a nuisance. All persons shall take reasonable precautions to
prevent the discharge of visible emissions of fugitive dusts beyond the lot line of the
property on which the emissions originate.
Authority for Requirement: 567 IAC 23.3(2)"c"
Compliance Plan:
The owner/operator of this equipment shall comply with the following applicable
requirements.
This point is in compliance with all applicable requirements and shall continue to comply
with all such requirements. For those applicable requirements which will become
effective during the permit term, this source will comply with such requirements in a
timely manner.
Periodic Monitoring Requirements:
The owner/operator of this equipment shall comply with the following periodic
monitoring requirements.
Agency Approved Operation & Maintenance Plan Required? Yes ~ No Kl
Facility Maintained Operation & Maintenance Plan Required? Yes ~ No Kl
Authority for Requirement: 567 IAC 22.108(3)"b"
217
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Emission Point ID Number: 3.WELDPLS
Associated Equipment
Associated Emission Unit ID Numbers (if multiple units vent thru this EP): 3. WELDPLS
Applicable Requirements
(If more than one emission unit vents through this emission point subdivide the applicable requirements by emission
unit.)
Emission Unit vented through this Emission Point: 3.WELDPLS (Fugitive)
Emission Unit Description: 16 Pulse Current GMAW Units
Raw Material/Fuel: E70S Weld Wire
Rated Capacity: 19 lb. ofWire/hr. per Unit
Emission Limits (lb./hr. gr./dscf. lb./MMBtu. % opacity, etc.):
The emissions from this emission point shall not exceed the following specified levels.
Pollutant: Fugitive Dust
Emission Limit: No person shall allow, cause or permit any materials to be handled,
transported or stored; or a building, its appurtenances or a construction haul road to
be used, constructed, altered , repaired or demolished, without taking reasonable
precautions to prevent a nuisance. All persons shall take reasonable precautions to
prevent the discharge of visible emissions of fugitive dusts beyond the lot line of the
property on which the emissions originate.
Authority for Requirement: 567 IAC 23.3(2)"c"
Compliance Plan:
The owner/operator of this equipment shall comply with the following applicable
requirements.
This point is in compliance with all applicable requirements and shall continue to comply
with all such requirements. For those applicable requirements which will become
effective during the permit term, this source will comply with such requirements in a
timely manner.
Periodic Monitoring Requirements:
The owner/operator of this equipment shall comply with the following periodic
monitoring requirements.
Agency Approved Operation & Maintenance Plan Required? Yes ~ No Kl
Facility Maintained Operation & Maintenance Plan Required? Yes ~ No Kl
Authority for Requirement: 567 IAC 22.108(3)"b"
218
-------
Emission Point ID Number: 3.X1
Associated Equipment
Associated Emission Unit ID Numbers (if multiple units vent thru this EP): 3 .XI
Applicable Requirements
(If more than one emission unit vents through this emission point subdivide the applicable requirements by emission
unit.)
Emission Unit vented through this Emission Point: 3.XI
Emission Unit Description: Non-Production Heating Unit
Raw Material/Fuel: Natural Gas
Rated Capacity: 0.13 MMBtu/hr.
Emission Limits (lb./hr. gr./dscf. lb./MMBtu. % opacity, etc.):
The emissions from this emission point shall not exceed the following specified levels.
Pollutant: Opacity
Emission Limit(s): 40 %
Authority for Requirement: 567 IAC 23.3(2)"d"
Pollutant: Particulate Matter (TSP)
Emission Limit(s): 15.3 lb./MMCF of LPG or Natural Gas
Authority for Requirement: Part 7a. of State of Iowa, ex rel., Iowa DNR vs. Vermeer
Manufacturing Company, 99AG23542
District Court, Marion County, Law No. LACV087889
Pollutant: Particulate Matter (TSP)
Emission Limits: 0.8 lb./MMBtu
Authority for Requirement: 567 IAC 23.3(2)"b"
Pollutant: Sulfur Dioxide (SO2)
Emission Limits: 500 ppmv
Authority for Requirement: 567 IAC 23.3(3)"e"
Pollutant: Nitrogen Oxides (NOx)
Emission Limit(s): See Facility-Wide Conditions
Authority for Requirement: Iowa DNR Construction Permit 98-A-003-S1
Pollutant: Volatile Organic Compounds (VOC)
Emission Limit: See Facility-Wide Conditions
Authority for Requirement: Iowa DNR Construction Permit 98-A-003-S1
219
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Operational Limits & Requirements:
The owner/operator of this equipment shall comply with the following operational limits
and requirements.
Process throughput:
A. The sulfur content of natural gas or LPG combusted by this source is not to
exceed 123 ppm by weight.
Reporting & Recordkeeping: See Facility-Wide Operational Limits
Authority for Requirement: Part 7b. of State of Iowa, ex rel., Iowa DNR vs. Vermeer
Manufacturing Company, 99AG23542
District Court, Marion County, Law No. LACV087889
Compliance Plan:
The owner/operator of this equipment shall comply with the following applicable
requirements.
This point is in compliance with all applicable requirements and shall continue to comply
with all such requirements. For those applicable requirements which will become
effective during the permit term, this source will comply with such requirements in a
timely manner.
Periodic Monitoring Requirements:
The owner/operator of this equipment shall comply with the following periodic
monitoring requirements.
Agency Approved Operation & Maintenance Plan Required? Yes ~ No IXI
Facility Maintained Operation & Maintenance Plan Required? Yes ~ No Kl
Authority for Requirement: 567 IAC 22.108(3)"b"
220
-------
Emission Point ID Number: 3.X2
Associated Equipment
Associated Emission Unit ID Numbers (if multiple units vent thru this EP): 3 ,X2
Applicable Requirements
(If more than one emission unit vents through this emission point subdivide the applicable requirements by emission
unit.)
Emission Unit vented through this Emission Point: 3,X2
Emission Unit Description: Non-Production Heating Unit
Raw Material/Fuel: Natural Gas
Rated Capacity: 0.13 MMBtu/hr.
Emission Limits (lb./hr. gr./dscf. lb./MMBtu. % opacity, etc.):
The emissions from this emission point shall not exceed the following specified levels.
Pollutant: Opacity
Emission Limit(s): 40 %
Authority for Requirement: 567 IAC 23.3(2)"d"
Pollutant: Particulate Matter (TSP)
Emission Limit(s): 15.3 lb./MMCF of LPG or Natural Gas
Authority for Requirement: Part 7a. of State of Iowa, ex rel., Iowa DNR vs. Vermeer
Manufacturing Company, 99AG23542
District Court, Marion County, Law No. LACV087889
Pollutant: Particulate Matter (TSP)
Emission Limits: 0.8 lb./MMBtu
Authority for Requirement: 567 IAC 23.3(2)"b"
Pollutant: Sulfur Dioxide (SO2)
Emission Limits: 500 ppmv
Authority for Requirement: 567 IAC 23.3(3)"e"
Pollutant: Nitrogen Oxides (NOx)
Emission Limit(s): See Facility-Wide Conditions
Authority for Requirement: Iowa DNR Construction Permit 98-A-003-S1
Pollutant: Volatile Organic Compounds (VOC)
Emission Limit: See Facility-Wide Conditions
Authority for Requirement: Iowa DNR Construction Permit 98-A-003-S1
221
-------
Operational Limits & Requirements:
The owner/operator of this equipment shall comply with the following operational limits
and requirements.
Process throughput:
A. The sulfur content of natural gas or LPG combusted by this source is not to
exceed 123 ppm by weight.
Reporting & Recordkeeping: See Facility-Wide Operational Limits
Authority for Requirement: Part 7b. of State of Iowa, ex rel., Iowa DNR vs. Vermeer
Manufacturing Company, 99AG23542
District Court, Marion County, Law No. LACV087889
Compliance Plan:
The owner/operator of this equipment shall comply with the following applicable
requirements.
This point is in compliance with all applicable requirements and shall continue to comply
with all such requirements. For those applicable requirements which will become
effective during the permit term, this source will comply with such requirements in a
timely manner.
Periodic Monitoring Requirements:
The owner/operator of this equipment shall comply with the following periodic
monitoring requirements.
Agency Approved Operation & Maintenance Plan Required? Yes ~ No IXI
Facility Maintained Operation & Maintenance Plan Required? Yes ~ No Kl
Authority for Requirement: 567 IAC 22.108(3)"b"
222
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Emission Point ID Number: 3.Y1
Associated Equipment
Associated Emission Unit ID Numbers (if multiple units vent thru this EP): 3. Y1
Applicable Requirements
(If more than one emission unit vents through this emission point subdivide the applicable requirements by emission
unit.)
Emission Unit vented through this Emission Point: 3.Y1
Emission Unit Description: Non-Production Heating Unit
Raw Material/Fuel: Natural Gas
Rated Capacity: 4.86 MMBtu/hr.
Emission Limits (lb./hr. gr./dscf. lb./MMBtu. % opacity, etc.):
The emissions from this emission point shall not exceed the following specified levels.
Pollutant: Opacity
Emission Limit(s): 40 %
Authority for Requirement: 567 IAC 23.3(2)"d"
Pollutant: Particulate Matter (TSP)
Emission Limit(s): 15.3 lb./MMCF of LPG or Natural Gas
Authority for Requirement: Part 7a. of State of Iowa, ex rel., Iowa DNR vs. Vermeer
Manufacturing Company, 99AG23542
District Court, Marion County, Law No. LACV087889
Pollutant: Particulate Matter (TSP)
Emission Limits: 0.8 lb./MMBtu
Authority for Requirement: 567 IAC 23.3(2)"b"
Pollutant: Sulfur Dioxide (SO2)
Emission Limits: 500 ppmv
Authority for Requirement: 567 IAC 23.3(3)"e"
Pollutant: Nitrogen Oxides (NOx)
Emission Limit(s): See Facility-Wide Conditions
Authority for Requirement: Iowa DNR Construction Permit 98-A-003-S1
Pollutant: Volatile Organic Compounds (VOC)
Emission Limit: See Facility-Wide Conditions
Authority for Requirement: Iowa DNR Construction Permit 98-A-003-S1
223
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Operational Limits & Requirements:
The owner/operator of this equipment shall comply with the following operational limits
and requirements.
Process throughput:
A. The sulfur content of natural gas or LPG combusted by this source is not to
exceed 123 ppm by weight.
Reporting & Recordkeeping: See Facility-Wide Operational Limits
Authority for Requirement: Part 7b. of State of Iowa, ex rel., Iowa DNR vs. Vermeer
Manufacturing Company, 99AG23542
District Court, Marion County, Law No. LACV087889
Compliance Plan:
The owner/operator of this equipment shall comply with the following applicable
requirements.
This point is in compliance with all applicable requirements and shall continue to comply
with all such requirements. For those applicable requirements which will become
effective during the permit term, this source will comply with such requirements in a
timely manner.
Periodic Monitoring Requirements:
The owner/operator of this equipment shall comply with the following periodic
monitoring requirements.
Agency Approved Operation & Maintenance Plan Required? Yes ~ No IXI
Facility Maintained Operation & Maintenance Plan Required? Yes ~ No Kl
Authority for Requirement: 567 IAC 22.108(3)"b"
224
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Emission Point ID Number: 3.Z
Associated Equipment
Associated Emission Unit ID Numbers (if multiple units vent thru this EP): 3 Z
Applicable Requirements
(If more than one emission unit vents through this emission point subdivide the applicable requirements by emission
unit.)
Emission Unit vented through this Emission Point: 3Z
Emission Unit Description: Production Engine Testing Unit
Raw Material/Fuel: #2 Diesel Fuel and Gasoline
Rated Capacity: 54.5 gal./hr.
Emission Limits (lb./hr. gr./dscf. lb./MMBtu. % opacity, etc.):
The emissions from this emission point shall not exceed the following specified levels.
Pollutant: Opacity
Emission Limits: 40%
Indicator Opacity: 25%(1)
(1) If visible emissions are observed that exceed the indicator opacity other than startup,
shutdown or malfunction, a stack test may be required to demonstrate compliance with
the particulate standard.
Authority for Requirement: Iowa DNR Construction Permit 97-A-l 106-S2
567 IAC 23.3(2)"d"
Pollutant: Particulate Matter (TSP)
Emission Limits: 0.1 gr./dscf
Authority for Requirement: Iowa DNR Construction Permit 97-A-l 106-S2
567 IAC 23.3(2)"a"
Pollutant: Sulfur Dioxide (SO2)
Emission Limits: 2.5 lb./MMBtu
Authority for Requirement: Iowa DNR Construction Permit 97-A-l 106-S2
567 IAC 23.3(3)"b"
Pollutant: Nitrogen Oxides (NOx)
Emission Limit(s): See Facility-Wide Conditions
Authority for Requirement: Iowa DNR Construction Permit 97-A-l 106-S2
Pollutant: Volatile Organic Compounds (VOC)
Emission Limit: See Facility-Wide Conditions
Authority for Requirement: Iowa DNR Construction Permit 97-A-l 106-S2
225
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Operational Limits & Requirements:
The owner/operator of this equipment shall comply with the following operational limits
and requirements.
Process Throughput:
A. The sulfur content of any diesel fuel used in this source shall not exceed 0.4% by
weight.
Reporting & Recordkeeping: See Facility-Wide Emission and Operational Limits
Authority for Requirement: Iowa DNR Construction Permit 97-A-l 106-S2
Compliance Plan:
The owner/operator of this equipment shall comply with the following applicable
requirements.
This point is in compliance with all applicable requirements and shall continue to comply
with all such requirements. For those applicable requirements which will become
effective during the permit term, this source will comply with such requirements in a
timely manner.
Additional Requirements:
This emission point shall conform to the following conditions.
The source is to be connected to the stack of the following detailed description.
Stack Height (feet): 30.8
Stack Diameter (inches): 12
Stack Exhaust Flow Rate (acfm): .... 6210
Stack Temperature (°F): 759
Vertical, Unobstructed Discharge Required: Yes ^ No ~
Authority for Requirement: Iowa DNR Construction Permit 97-A-l 106-S2
Periodic Monitoring Requirements:
The owner/operator of this equipment shall comply with the following periodic
monitoring requirements.
Opacity Monitoring:
The facility shall observe the opacity weekly during a period when the emission unit
associated with this emission point is at or near full capacity and record the reading
indicating if visible emissions were observed. The records shall be maintained for five
years. If weather conditions prevent the observer from conducting an opacity
observation, the observer shall note such conditions on the data observation sheet. At
least three attempts shall be made to retake opacity readings at approximately 2-hour
intervals throughout the day. If all observation attempts for a week have been
unsuccessful due to weather, an observation shall be made the next operating day where
weather permits.
Maintain a written record of the observation and any action resulting from the
observation.
226
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Agency Approved Operation & Maintenance Plan Required? Yes ~ No Kl
Facility Maintained Operation & Maintenance Plan Required? Yes ~ No Kl
Authority for Requirement: 567 IAC 22.108(3)"b"
227
-------
Emission Point ID Number: 4.A1
Associated Equipment
Associated Emission Unit ID Numbers (if multiple units vent thru this EP): 4. A1
Applicable Requirements
(If more than one emission unit vents through this emission point subdivide the applicable requirements by emission
unit.)
Emission Unit vented through this Emission Point: 4.A1
Emission Unit Description: Non-Production Heating Unit
Raw Material/Fuel: Natural Gas
Rated Capacity: 2.0 MMBtu/hr.
Emission Limits (lb./hr. gr./dscf. lb./MMBtu. % opacity, etc.):
The emissions from this emission point shall not exceed the following specified levels.
Pollutant: Opacity
Emission Limit(s): 40 %
Authority for Requirement: 567 IAC 23.3(2)"d"
Pollutant: Particulate Matter (TSP)
Emission Limit(s): 15.3 lb./MMCF of LPG or Natural Gas
Authority for Requirement: Part 7a. of State of Iowa, ex rel., Iowa DNR vs. Vermeer
Manufacturing Company, 99AG23542
District Court, Marion County, Law No. LACV087889
Pollutant: Particulate Matter (TSP)
Emission Limits: 0.8 lb./MMBtu
Authority for Requirement: 567 IAC 23.3(2)"b"
Pollutant: Sulfur Dioxide (SO2)
Emission Limits: 500 ppmv
Authority for Requirement: 567 IAC 23.3(3)"e"
Pollutant: Nitrogen Oxides (NOx)
Emission Limit(s): See Facility-Wide Conditions
Authority for Requirement: Iowa DNR Construction Permit 98-A-003-S1
Pollutant: Volatile Organic Compounds (VOC)
Emission Limit: See Facility-Wide Conditions
Authority for Requirement: Iowa DNR Construction Permit 98-A-003-S1
228
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Operational Limits & Requirements:
The owner/operator of this equipment shall comply with the following operational limits
and requirements.
Process throughput:
A. The sulfur content of natural gas or LPG combusted by this source is not to
exceed 123 ppm by weight.
Reporting & Recordkeeping: See Facility-Wide Operational Limits
Authority for Requirement: Part 7b. of State of Iowa, ex rel., Iowa DNR vs. Vermeer
Manufacturing Company, 99AG23542
District Court, Marion County, Law No. LACV087889
Compliance Plan:
The owner/operator of this equipment shall comply with the following applicable
requirements.
This point is in compliance with all applicable requirements and shall continue to comply
with all such requirements. For those applicable requirements which will become
effective during the permit term, this source will comply with such requirements in a
timely manner.
Periodic Monitoring Requirements:
The owner/operator of this equipment shall comply with the following periodic
monitoring requirements.
Agency Approved Operation & Maintenance Plan Required? Yes ~ No IXI
Facility Maintained Operation & Maintenance Plan Required? Yes ~ No Kl
Authority for Requirement: 567 IAC 22.108(3)"b"
229
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Emission Point ID Number: 4.A2
Associated Equipment
Associated Emission Unit ID Numbers (if multiple units vent thru this EP): 4. A2
Applicable Requirements
(If more than one emission unit vents through this emission point subdivide the applicable requirements by emission
unit.)
Emission Unit vented through this Emission Point: 4.A2
Emission Unit Description: Non-Production Heating Unit
Raw Material/Fuel: Natural Gas
Rated Capacity: 2.0 MMBtu/hr.
Emission Limits (lb./hr. gr./dscf. lb./MMBtu. % opacity, etc.):
The emissions from this emission point shall not exceed the following specified levels.
Pollutant: Opacity
Emission Limit(s): 40 %
Authority for Requirement: 567 IAC 23.3(2)"d"
Pollutant: Particulate Matter (TSP)
Emission Limit(s): 15.3 lb./MMCF of LPG or Natural Gas
Authority for Requirement: Part 7a. of State of Iowa, ex rel., Iowa DNR vs. Vermeer
Manufacturing Company, 99AG23542
District Court, Marion County, Law No. LACV087889
Pollutant: Particulate Matter (TSP)
Emission Limits: 0.8 lb./MMBtu
Authority for Requirement: 567 IAC 23.3(2)"b"
Pollutant: Sulfur Dioxide (SO2)
Emission Limits: 500 ppmv
Authority for Requirement: 567 IAC 23.3(3)"e"
Pollutant: Nitrogen Oxides (NOx)
Emission Limit(s): See Facility-Wide Conditions
Authority for Requirement: Iowa DNR Construction Permit 98-A-003-S1
Pollutant: Volatile Organic Compounds (VOC)
Emission Limit: See Facility-Wide Conditions
Authority for Requirement: Iowa DNR Construction Permit 98-A-003-S1
230
-------
Operational Limits & Requirements:
The owner/operator of this equipment shall comply with the following operational limits
and requirements.
Process throughput:
A. The sulfur content of natural gas or LPG combusted by this source is not to
exceed 123 ppm by weight.
Reporting & Recordkeeping: See Facility-Wide Operational Limits
Authority for Requirement: Part 7b. of State of Iowa, ex rel., Iowa DNR vs. Vermeer
Manufacturing Company, 99AG23542
District Court, Marion County, Law No. LACV087889
Compliance Plan:
The owner/operator of this equipment shall comply with the following applicable
requirements.
This point is in compliance with all applicable requirements and shall continue to comply
with all such requirements. For those applicable requirements which will become
effective during the permit term, this source will comply with such requirements in a
timely manner.
Periodic Monitoring Requirements:
The owner/operator of this equipment shall comply with the following periodic
monitoring requirements.
Agency Approved Operation & Maintenance Plan Required? Yes ~ No IXI
Facility Maintained Operation & Maintenance Plan Required? Yes ~ No Kl
Authority for Requirement: 567 IAC 22.108(3)"b"
231
-------
Emission Point ID Number: 4.A3
Associated Equipment
Associated Emission Unit ID Numbers (if multiple units vent thru this EP): 4. A3
Applicable Requirements
(If more than one emission unit vents through this emission point subdivide the applicable requirements by emission
unit.)
Emission Unit vented through this Emission Point: 4.A3
Emission Unit Description: Non-Production Heating Unit
Raw Material/Fuel: Natural Gas
Rated Capacity: 2.0 MMBtu/hr.
Emission Limits (lb./hr. gr./dscf. lb./MMBtu. % opacity, etc.):
The emissions from this emission point shall not exceed the following specified levels.
Pollutant: Opacity
Emission Limit(s): 40 %
Authority for Requirement: 567 IAC 23.3(2)"d"
Pollutant: Particulate Matter (TSP)
Emission Limit(s): 15.3 lb./MMCF of LPG or Natural Gas
Authority for Requirement: Part 7a. of State of Iowa, ex rel., Iowa DNR vs. Vermeer
Manufacturing Company, 99AG23542
District Court, Marion County, Law No. LACV087889
Pollutant: Particulate Matter (TSP)
Emission Limits: 0.8 lb./MMBtu
Authority for Requirement: 567 IAC 23.3(2)"b"
Pollutant: Sulfur Dioxide (SO2)
Emission Limits: 500 ppmv
Authority for Requirement: 567 IAC 23.3(3)"e"
Pollutant: Nitrogen Oxides (NOx)
Emission Limit(s): See Facility-Wide Conditions
Authority for Requirement: Iowa DNR Construction Permit 98-A-003-S1
Pollutant: Volatile Organic Compounds (VOC)
Emission Limit: See Facility-Wide Conditions
Authority for Requirement: Iowa DNR Construction Permit 98-A-003-S1
232
-------
Operational Limits & Requirements:
The owner/operator of this equipment shall comply with the following operational limits
and requirements.
Process throughput:
A. The sulfur content of natural gas or LPG combusted by this source is not to
exceed 123 ppm by weight.
Reporting & Recordkeeping: See Facility-Wide Operational Limits
Authority for Requirement: Part 7b. of State of Iowa, ex rel., Iowa DNR vs. Vermeer
Manufacturing Company, 99AG23542
District Court, Marion County, Law No. LACV087889
Compliance Plan:
The owner/operator of this equipment shall comply with the following applicable
requirements.
This point is in compliance with all applicable requirements and shall continue to comply
with all such requirements. For those applicable requirements which will become
effective during the permit term, this source will comply with such requirements in a
timely manner.
Periodic Monitoring Requirements:
The owner/operator of this equipment shall comply with the following periodic
monitoring requirements.
Agency Approved Operation & Maintenance Plan Required? Yes ~ No IXI
Facility Maintained Operation & Maintenance Plan Required? Yes ~ No Kl
Authority for Requirement: 567 IAC 22.108(3)"b"
233
-------
Emission Point ID Number: 4.AA
Associated Equipment
Associated Emission Unit ID Numbers (if multiple units vent thru this EP): 4. AA
Applicable Requirements
(If more than one emission unit vents through this emission point subdivide the applicable requirements by emission
unit.)
Emission Unit vented through this Emission Point: 4.AA
Emission Unit Description: Non-Production Heating Unit
Raw Material/Fuel: Natural Gas
Rated Capacity: 2.0 MMBtu/hr.
Emission Limits (lb./hr. gr./dscf. lb./MMBtu. % opacity, etc.):
The emissions from this emission point shall not exceed the following specified levels.
Pollutant: Opacity
Emission Limit(s): 40 %
Authority for Requirement: 567 IAC 23.3(2)"d"
Pollutant: Particulate Matter (TSP)
Emission Limit(s): 15.3 lb./MMCF of LPG or Natural Gas
Authority for Requirement: Part 7a. of State of Iowa, ex rel., Iowa DNR vs. Vermeer
Manufacturing Company, 99AG23542
District Court, Marion County, Law No. LACV087889
Pollutant: Particulate Matter (TSP)
Emission Limits: 0.8 lb./MMBtu
Authority for Requirement: 567 IAC 23.3(2)"b"
Pollutant: Sulfur Dioxide (SO2)
Emission Limits: 500 ppmv
Authority for Requirement: 567 IAC 23.3(3)"e"
Pollutant: Nitrogen Oxides (NOx)
Emission Limit(s): See Facility-Wide Conditions
Authority for Requirement: Iowa DNR Construction Permit 98-A-003-S1
Pollutant: Volatile Organic Compounds (VOC)
Emission Limit: See Facility-Wide Conditions
Authority for Requirement: Iowa DNR Construction Permit 98-A-003-S1
234
-------
Operational Limits & Requirements:
The owner/operator of this equipment shall comply with the following operational limits
and requirements.
Process throughput:
A. The sulfur content of natural gas or LPG combusted by this source is not to
exceed 123 ppm by weight.
Reporting & Recordkeeping: See Facility-Wide Operational Limits
Authority for Requirement: Part 7b. of State of Iowa, ex rel., Iowa DNR vs. Vermeer
Manufacturing Company, 99AG23542
District Court, Marion County, Law No. LACV087889
Compliance Plan:
The owner/operator of this equipment shall comply with the following applicable
requirements.
This point is in compliance with all applicable requirements and shall continue to comply
with all such requirements. For those applicable requirements which will become
effective during the permit term, this source will comply with such requirements in a
timely manner.
Periodic Monitoring Requirements:
The owner/operator of this equipment shall comply with the following periodic
monitoring requirements.
Agency Approved Operation & Maintenance Plan Required? Yes ~ No IXI
Facility Maintained Operation & Maintenance Plan Required? Yes ~ No Kl
Authority for Requirement: 567 IAC 22.108(3)"b"
235
-------
Emission Point ID Number: 4.BB
Associated Equipment
Associated Emission Unit ID Numbers (if multiple units vent thru this EP): 4.BB
Applicable Requirements
(If more than one emission unit vents through this emission point subdivide the applicable requirements by emission
unit.)
Emission Unit vented through this Emission Point: 4.BB
Emission Unit Description: Non-Production Heating Unit
Raw Material/Fuel: Natural Gas
Rated Capacity: 2.0 MMBtu/hr.
Emission Limits (lb./hr. gr./dscf. lb./MMBtu. % opacity, etc.):
The emissions from this emission point shall not exceed the following specified levels.
Pollutant: Opacity
Emission Limit(s): 40 %
Authority for Requirement: 567 IAC 23.3(2)"d"
Pollutant: Particulate Matter (TSP)
Emission Limit(s): 15.3 lb./MMCF of LPG or Natural Gas
Authority for Requirement: Part 7a. of State of Iowa, ex rel., Iowa DNR vs. Vermeer
Manufacturing Company, 99AG23542
District Court, Marion County, Law No. LACV087889
Pollutant: Particulate Matter (TSP)
Emission Limits: 0.8 lb./MMBtu
Authority for Requirement: 567 IAC 23.3(2)"b"
Pollutant: Sulfur Dioxide (SO2)
Emission Limits: 500 ppmv
Authority for Requirement: 567 IAC 23.3(3)"e"
Pollutant: Nitrogen Oxides (NOx)
Emission Limit(s): See Facility-Wide Conditions
Authority for Requirement: Iowa DNR Construction Permit 98-A-003-S1
Pollutant: Volatile Organic Compounds (VOC)
Emission Limit: See Facility-Wide Conditions
Authority for Requirement: Iowa DNR Construction Permit 98-A-003-S1
236
-------
Operational Limits & Requirements:
The owner/operator of this equipment shall comply with the following operational limits
and requirements.
Process throughput:
A. The sulfur content of natural gas or LPG combusted by this source is not to
exceed 123 ppm by weight.
Reporting & Recordkeeping: See Facility-Wide Operational Limits
Authority for Requirement: Part 7b. of State of Iowa, ex rel., Iowa DNR vs. Vermeer
Manufacturing Company, 99AG23542
District Court, Marion County, Law No. LACV087889
Compliance Plan:
The owner/operator of this equipment shall comply with the following applicable
requirements.
This point is in compliance with all applicable requirements and shall continue to comply
with all such requirements. For those applicable requirements which will become
effective during the permit term, this source will comply with such requirements in a
timely manner.
Periodic Monitoring Requirements:
The owner/operator of this equipment shall comply with the following periodic
monitoring requirements.
Agency Approved Operation & Maintenance Plan Required? Yes ~ No IXI
Facility Maintained Operation & Maintenance Plan Required? Yes ~ No Kl
Authority for Requirement: 567 IAC 22.108(3)"b"
231
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Emission Point ID Number: 4.CD
Associated Equipment
Associated Emission Unit ID Numbers (if multiple units vent thru this EP): 4.CD
Applicable Requirements
(If more than one emission unit vents through this emission point subdivide the applicable requirements by emission
unit.)
Emission Units vented through this Emission Point: 4.CD
Emission Unit Description: Paint Kitchen
Raw Material/Fuel: Paints, Primers, and Solvents
Rated Capacity: 3 Barrels
Emission Limits (lb./hr. gr./dscf. lb./MMBtu. % opacity, etc.):
The emissions from this emission point shall not exceed the following specified levels.
Pollutant: Volatile Organic Compounds (VOC)
Emission Limit: See Facility-Wide Conditions
Authority for Requirement: Iowa DNR Construction Permit 98-A-029-S1
Compliance Plan:
The owner/operator of this equipment shall comply with the following applicable
requirements.
This point is in compliance with all applicable requirements and shall continue to comply
with all such requirements. For those applicable requirements which will become
effective during the permit term, this source will comply with such requirements in a
timely manner.
Additional Requirements:
This emission point shall conform to the following conditions.
The source is to be connected to the stack of the following detailed description.
Stack Height (feet): 43
Stack Diameter (inches): 15
Stack Exhaust Flow Rate (acfm): .... 3,500
Stack Temperature (°F): 70
Vertical, Unobstructed Discharge Required: Yes ^ No ~
Authority for Requirement: Iowa DNR Construction Permit 98-A-029-S1
238
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Periodic Monitoring Requirements:
The owner/operator of this equipment shall comply with the following periodic
monitoring requirements.
Agency Approved Operation & Maintenance Plan Required? Yes ~ No Kl
Facility Maintained Operation & Maintenance Plan Required? Yes ~ No Kl
Authority for Requirement: 567 IAC 22.108(3)"b"
239
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Emission Point ID Number: 4.CE
Associated Equipment
Associated Emission Unit ID Numbers (if multiple units vent thru this EP): 4.CE1, 4.CE2
Applicable Requirements
(If more than one emission unit vents through this emission point subdivide the applicable requirements by emission
unit.)
Emission Unit vented through this Emission Point: 4.CE1
Emission Unit Description: Paint Kitchen
Raw Material/Fuel: Paints, Primers, and Solvents
Rated Capacity: 3 Barrels
Emission Unit vented through this Emission Point: 4.CE2
Emission Unit Description: Paint Kitchen
Raw Material/Fuel: Paints, Primers, and Solvents
Rated Capacity: 3 Barrels
Emission Limits (lb./hr. gr./dscf. lb./MMBtu. % opacity, etc.):
The emissions from this emission point shall not exceed the following specified levels.
Pollutant: Volatile Organic Compounds (VOC)
Emission Limit: See Facility-Wide Conditions
Authority for Requirement: Iowa DNR Construction Permit 98-A-030-S1
Compliance Plan:
The owner/operator of this equipment shall comply with the following applicable
requirements.
This point is in compliance with all applicable requirements and shall continue to comply
with all such requirements. For those applicable requirements which will become
effective during the permit term, this source will comply with such requirements in a
timely manner.
Additional Requirements:
This emission point shall conform to the following conditions.
The source is to be connected to the stack of the following detailed description.
Stack Height (feet): 43
Stack Diameter (inches): 20
Stack Exhaust Flow Rate (acfm): .... 7,000
Stack Temperature (°F): 70
Vertical, Unobstructed Discharge Required: Yes ^ No ~
Authority for Requirement: Iowa DNR Construction Permit 98-A-030-S1
240
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Periodic Monitoring Requirements:
The owner/operator of this equipment shall comply with the following periodic
monitoring requirements.
Agency Approved Operation & Maintenance Plan Required? Yes ~ No Kl
Facility Maintained Operation & Maintenance Plan Required? Yes ~ No Kl
Authority for Requirement: 567 IAC 22.108(3)"b"
241
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Emission Point ID Number: 4.D
Associated Equipment
Associated Emission Unit ID Numbers (if multiple units vent thru this EP): 4.D
Applicable Requirements
(If more than one emission unit vents through this emission point subdivide the applicable requirements by emission
unit.)
Emission Unit vented through this Emission Point: 4.D
Emission Unit Description: Hot Water Heater
Raw Material/Fuel: Natural Gas
Rated Capacity: 0.528 MMBtu/hr.
Emission Limits (lb./hr. gr./dscf. lb./MMBtu. % opacity, etc.):
The emissions from this emission point shall not exceed the following specified levels.
Pollutant: Opacity
Emission Limit(s): 40 %
Authority for Requirement: 567 IAC 23.3(2)"d"
Pollutant: Particulate Matter (TSP)
Emission Limit(s): 15.3 lb./MMCF of LPG or Natural Gas
Authority for Requirement: Part 7a. of State of Iowa, ex rel., Iowa DNR vs. Vermeer
Manufacturing Company, 99AG23542
District Court, Marion County, Law No. LACV087889
Pollutant: Particulate Matter (TSP)
Emission Limits: 0.8 lb./MMBtu
Authority for Requirement: 567 IAC 23.3(2)"b"
Pollutant: Sulfur Dioxide (SO2)
Emission Limits: 500 ppmv
Authority for Requirement: 567 IAC 23.3(3)"e"
Pollutant: Nitrogen Oxides (NOx)
Emission Limit(s): See Facility-Wide Conditions
Authority for Requirement: Iowa DNR Construction Permit 98-A-003-S1
Pollutant: Volatile Organic Compounds (VOC)
Emission Limit: See Facility-Wide Conditions
Authority for Requirement: Iowa DNR Construction Permit 98-A-003-S1
242
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Operational Limits & Requirements:
The owner/operator of this equipment shall comply with the following operational limits
and requirements.
Process throughput:
A. The sulfur content of natural gas or LPG combusted by this source is not to
exceed 123 ppm by weight.
Reporting & Recordkeeping: See Facility-Wide Operational Limits
Authority for Requirement: Part 7b. of State of Iowa, ex rel., Iowa DNR vs. Vermeer
Manufacturing Company, 99AG23542
District Court, Marion County, Law No. LACV087889
Compliance Plan:
The owner/operator of this equipment shall comply with the following applicable
requirements.
This point is in compliance with all applicable requirements and shall continue to comply
with all such requirements. For those applicable requirements which will become
effective during the permit term, this source will comply with such requirements in a
timely manner.
Periodic Monitoring Requirements:
The owner/operator of this equipment shall comply with the following periodic
monitoring requirements.
Agency Approved Operation & Maintenance Plan Required? Yes ~ No IXI
Facility Maintained Operation & Maintenance Plan Required? Yes ~ No Kl
Authority for Requirement: 567 IAC 22.108(3)"b"
243
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Emission Point ID Number: 4.E
Associated Equipment
Associated Emission Unit ID Numbers (if multiple units vent thru this EP): 4.E
Applicable Requirements
(If more than one emission unit vents through this emission point subdivide the applicable requirements by emission
unit.)
Emission Unit vented through this Emission Point: 4.E
Emission Unit Description: Paint Oven
Raw Material/Fuel: Natural Gas
Rated Capacity: 1.08 MMBtu/hr.
Emission Limits (lb./hr. gr./dscf. lb./MMBtu. % opacity, etc.):
The emissions from this emission point shall not exceed the following specified levels.
Pollutant: Opacity
Emission Limits: 40%
Indicator Opacity: (1)
(1) If visible emissions are observed other than startup, shutdown or malfunction, a stack
test may be required to demonstrate compliance with the particulate standard.
Authority for Requirement: Iowa DNR Construction Permit 98-A-031 -S1
567 IAC23.3(2)"d"
Pollutant: Particulate Matter (TSP)
Emission Limit(s): 15.3 lb./MMCF of LPG or Natural Gas
Authority for Requirement: Part 7a. of State of Iowa, ex rel., Iowa DNR vs. Vermeer
Manufacturing Company, 99AG23542
District Court, Marion County, Law No. LACV087889
Pollutant: Particulate Matter (TSP)
Emission Limits: 0.1 gr./dscf
Authority for Requirement: Iowa DNR Construction Permit 98-A-031 -S1
567 I AC 23.3 (2) "a"
Pollutant: Sulfur Dioxide (SO2)
Emission Limits: 500 ppmv
Authority for Requirement: 567 IAC 23.3(3)"e"
Pollutant: Nitrogen Oxides (NOx)
Emission Limit(s): See Facility-Wide Conditions
Authority for Requirement: Iowa DNR Construction Permit 98-A-031 -S1
244
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Emission Limits (continued):
Pollutant: Volatile Organic Compounds (VOC)
Emission Limit: See Facility-Wide Conditions
Authority for Requirement: Iowa DNR Construction Permit 98-A-031 -S1
Operational Limits & Requirements:
The owner/operator of this equipment shall comply with the following operational limits
and requirements.
Process throughput:
A. This oven shall be fired by natural gas or propane only.
Reporting & Recordkeeping: See Facility-Wide Operational Limits
Authority for Requirement: Iowa DNR Construction Permit 98-A-031 -S1
Process throughput:
A. The sulfur content of natural gas or LPG combusted by this source is not to
exceed 123 ppm by weight.
Reporting & Recordkeeping: See Facility-Wide Operational Limits
Authority for Requirement: Part 7b. of State of Iowa, ex rel., Iowa DNR vs. Vermeer
Manufacturing Company, 99AG23542
District Court, Marion County, Law No. LACV087889
Compliance Plan:
The owner/operator of this equipment shall comply with the following applicable
requirements.
This point is in compliance with all applicable requirements and shall continue to comply
with all such requirements. For those applicable requirements which will become
effective during the permit term, this source will comply with such requirements in a
timely manner.
Additional Requirements:
This emission point shall conform to the following conditions.
The source is to be connected to the stack of the following detailed description.
Stack Height (feet): 31
Stack Diameter (inches): 12.0
Stack Exhaust Flow Rate (acfm): .... 1,335
Stack Temperature (°F): 125
Vertical, Unobstructed Discharge Required: Yes ^ No ~
Authority for Requirement: Iowa DNR Construction Permit 98-A-031 -S1
245
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Periodic Monitoring Requirements:
The owner/operator of this equipment shall comply with the following periodic
monitoring requirements.
Opacity Monitoring:
The facility shall observe the opacity weekly during a period when the emission unit
associated with this emission point is at or near full capacity and record the reading
indicating if visible emissions were observed. The records shall be maintained for five
years. If weather conditions prevent the observer from conducting an opacity
observation, the observer shall note such conditions on the data observation sheet. At
least three attempts shall be made to retake opacity readings at approximately 2-hour
intervals throughout the day. If all observation attempts for a week have been
unsuccessful due to weather, an observation shall be made the next operating day where
weather permits.
Maintain a written record of the observation and any action resulting from the
observation.
Agency Approved Operation & Maintenance Plan Required? Yes ~ No IEI
Facility Maintained Operation & Maintenance Plan Required? Yes ~ No Kl
Authority for Requirement: 567 IAC 22.108(3)"b"
246
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Emission Point ID Number: 4.F
Associated Equipment
Associated Emission Unit ID Numbers (if multiple units vent thru this EP): 4.F
Emissions Control Equipment ID Number: 4.F
Emissions Control Equipment Description: Paper Filter
Applicable Requirements
(If more than one emission unit vents through this emission point subdivide the applicable requirements by emission
unit.)
Emission Unit vented through this Emission Point: 4.F
Emission Unit Description: Parts Paint Booth
Raw Material/Fuel: Paints, Primers, and Solvents
Rated Capacity: 15 gal./hr.
Emission Limits (lb./hr. gr./dscf. lb./MMBtu. % opacity, etc.):
The emissions from this emission point shall not exceed the following specified levels.
Pollutant: Opacity
Emission Limits: 40%
Indicator Opacity: (1)
(1) If visible emissions are observed other than startup, shutdown or malfunction, a stack
test may be required to demonstrate compliance with the particulate standard.
Authority for Requirement: Iowa DNR Construction Permit 98-A-032-S2
567 IAC23.3(2)"d"
Pollutant: Particulate Matter (TSP)
Emission Limit(s): 0.01 gr./dscf
Authority for Requirement: Iowa DNR Construction Permit 98-A-032-S2
567 IAC 23.4(13)
Pollutant: Volatile Organic Compounds (VOC)
Emission Limit: See Facility-Wide Conditions
Authority for Requirement: Iowa DNR Construction Permit 98-A-032-S2
Compliance Plan:
The owner/operator of this equipment shall comply with the following applicable
requirements.
This point is in compliance with all applicable requirements and shall continue to comply
with all such requirements. For those applicable requirements which will become
effective during the permit term, this source will comply with such requirements in a
timely manner.
247
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Additional Requirements:
This emission point shall conform to the following conditions.
The source is to be connected to the stack of the following detailed description.
Stack Height (feet): 39.5
Stack Diameter (inches): 42.0
Stack Exhaust Flow Rate (acfm): .... 28,000
Stack Temperature (°F): 70
Vertical, Unobstructed Discharge Required: Yes ^ No ~
Authority for Requirement: Iowa DNR Construction Permit 98-A-032-S2
Periodic Monitoring Requirements:
The owner/operator of this equipment shall comply with the following periodic
monitoring requirements.
Stack Testing:
Pollutant: Particulate Matter (TSP)
Stack Test to be Completed by (date): October 18, 2001
Test Method: Iowa Compliance Sampling Manual
Authority for Requirement: 567 IAC 22.108(3)
The results of the compliance stack testing will be used to calculate actual emissions for
this source until such time as more recent data becomes available. If the source test does
not demonstrate compliance this permit will be reopened to add a compliance plan and
operation and maintenance requirements.
The owner of this equipment or the owner's authorized agent shall provide written notice
to the Director, not less than 30 days before a required stack test or performance
evaluation of a continuous emission monitor. Results of the test shall be submitted in
writing to the Director in the form of a comprehensive report within 6 weeks of the
completion of the testing. 567 IAC 25.1(7)
Opacity Monitoring:
The facility shall observe the opacity weekly during a period when the emission unit
associated with this emission point is at or near full capacity and record the reading
indicating if visible emissions were observed. The records shall be maintained for five
years. If weather conditions prevent the observer from conducting an opacity
observation, the observer shall note such conditions on the data observation sheet. At
least three attempts shall be made to retake opacity readings at approximately 2-hour
intervals throughout the day. If all observation attempts for a week have been
unsuccessful due to weather, an observation shall be made the next operating day where
weather permits.
Maintain a written record of the observation and any action resulting from the
observation.
248
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Agency Approved Operation & Maintenance Plan Required? Yes ~ No
Facility Maintained Operation & Maintenance Plan Required? Yes Kl NoQ
Facility operation and maintenance plans must be sufficient to yield reliable data from
the relevant time period that are representative of the source's compliance with the
applicable requirements.
Facility operation and maintenance plans are to be developed by the facility within six(6)
months of the issuance date of this permit and the data pertaining to the plan maintained
on site for at least 5 years. The plan and associated recordkeeping provides
documentation of this facility's implementation of its obligation to operate according to
good air pollution control practice.
Good air pollution control practice is achieved by adoption of quality control standards
in the operation and maintenance procedures for air pollution control that are
comparable to industry quality control standards for the production processes associated
with this emission point.
Authority for Requirement: 567 IAC 22.108(3)"b"
249
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Emission Point ID Number: 4.FLAME1
Associated Equipment
Associated Emission Unit ID Numbers (if multiple units vent thru this EP): 4.FLAME1
Emissions Control Equipment ID Number: 4.FLAME1
Emissions Control Equipment Description: Water Table
Applicable Requirements
(If more than one emission unit vents through this emission point subdivide the applicable requirements by emission
unit.)
Emission Unit vented through this Emission Point: 4.FLAME1 (Fugitive)
Emission Unit Description: Two (2) Cutting Head Oxyacetylene
Torch Unit
Raw Material/Fuel: Sheet Steel
Rated Capacity: 660 inches of metal cut/hr. per Head
Emission Limits (lb./hr. gr./dscf. lb./MMBtu. % opacity, etc.):
The emissions from this emission point shall not exceed the following specified levels.
Pollutant: Fugitive Dust
Emission Limit: No person shall allow, cause or permit any materials to be handled,
transported or stored; or a building, its appurtenances or a construction haul road to
be used, constructed, altered , repaired or demolished, without taking reasonable
precautions to prevent a nuisance. All persons shall take reasonable precautions to
prevent the discharge of visible emissions of fugitive dusts beyond the lot line of the
property on which the emissions originate.
Authority for Requirement: 567 IAC 23.3(2)"c"
Compliance Plan:
The owner/operator of this equipment shall comply with the following applicable
requirements.
This point is in compliance with all applicable requirements and shall continue to comply
with all such requirements. For those applicable requirements which will become
effective during the permit term, this source will comply with such requirements in a
timely manner.
Periodic Monitoring Requirements:
The owner/operator of this equipment shall comply with the following periodic
monitoring requirements.
Agency Approved Operation & Maintenance Plan Required? Yes ~ No Kl
Facility Maintained Operation & Maintenance Plan Required? Yes ~ No Kl
Authority for Requirement: 567 IAC 22.108(3)"b"
250
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Emission Point ID Number: 4.FLAME2
Associated Equipment
Associated Emission Unit ID Numbers (if multiple units vent thru this EP): 4.FLAME2
Applicable Requirements
(If more than one emission unit vents through this emission point subdivide the applicable requirements by emission
unit.)
Emission Unit vented through this Emission Point: 4.FLAME2 (Fugitive)
Emission Unit Description: Single Cutting Head Oxyacetylene
Torch Unit
Raw Material/Fuel: Sheet Steel
Rated Capacity: 660 inches of metal cut/hr.
Emission Limits (lb./hr. gr./dscf. lb./MMBtu. % opacity, etc.):
The emissions from this emission point shall not exceed the following specified levels.
Pollutant: Fugitive Dust
Emission Limit: No person shall allow, cause or permit any materials to be handled,
transported or stored; or a building, its appurtenances or a construction haul road to
be used, constructed, altered , repaired or demolished, without taking reasonable
precautions to prevent a nuisance. All persons shall take reasonable precautions to
prevent the discharge of visible emissions of fugitive dusts beyond the lot line of the
property on which the emissions originate.
Authority for Requirement: 567 IAC 23.3(2)"c"
Compliance Plan:
The owner/operator of this equipment shall comply with the following applicable
requirements.
This point is in compliance with all applicable requirements and shall continue to comply
with all such requirements. For those applicable requirements which will become
effective during the permit term, this source will comply with such requirements in a
timely manner.
Periodic Monitoring Requirements:
The owner/operator of this equipment shall comply with the following periodic
monitoring requirements.
Agency Approved Operation & Maintenance Plan Required? Yes ~ No IXI
Facility Maintained Operation & Maintenance Plan Required? Yes ~ No Kl
Authority for Requirement: 567 IAC 22.108(3)"b"
251
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Emission Point ID Number: 4.FLAME3
Associated Equipment
Associated Emission Unit ID Numbers (if multiple units vent thru this EP): 4.FLAME3
Applicable Requirements
(If more than one emission unit vents through this emission point subdivide the applicable requirements by emission
unit.)
Emission Unit vented through this Emission Point: 4.FLAME3 (Fugitive)
Emission Unit Description: Single Cutting Head Oxyacetylene
Torch Unit
Raw Material/Fuel: Sheet Steel
Rated Capacity: 660 inches of metal cut/hr.
Emission Limits (lb./hr. gr./dscf. lb./MMBtu. % opacity, etc.):
The emissions from this emission point shall not exceed the following specified levels.
Pollutant: Fugitive Dust
Emission Limit: No person shall allow, cause or permit any materials to be handled,
transported or stored; or a building, its appurtenances or a construction haul road to
be used, constructed, altered , repaired or demolished, without taking reasonable
precautions to prevent a nuisance. All persons shall take reasonable precautions to
prevent the discharge of visible emissions of fugitive dusts beyond the lot line of the
property on which the emissions originate.
Authority for Requirement: 567 IAC 23.3(2)"c"
Compliance Plan:
The owner/operator of this equipment shall comply with the following applicable
requirements.
This point is in compliance with all applicable requirements and shall continue to comply
with all such requirements. For those applicable requirements which will become
effective during the permit term, this source will comply with such requirements in a
timely manner.
Periodic Monitoring Requirements:
The owner/operator of this equipment shall comply with the following periodic
monitoring requirements.
Agency Approved Operation & Maintenance Plan Required? Yes ~ No IXI
Facility Maintained Operation & Maintenance Plan Required? Yes ~ No Kl
Authority for Requirement: 567 IAC 22.108(3)"b"
252
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Emission Point ID Number: 4.G1
Associated Equipment
Associated Emission Unit ID Numbers (if multiple units vent thru this EP): 4.G
Emissions Control Equipment ID Number: 4.G
Emissions Control Equipment Description: Paper Filter
Applicable Requirements
(If more than one emission unit vents through this emission point subdivide the applicable requirements by emission
unit.)
Emission Unit vented through this Emission Point: 4.G
Emission Unit Description: Finish Paint Booth
Raw Material/Fuel: Paints, Primers, and Solvents
Rated Capacity: 15 gal./hr.
Emission Limits (lb./hr. gr./dscf. lb./MMBtu. % opacity, etc.):
The emissions from this emission point shall not exceed the following specified levels.
Pollutant: Opacity
Emission Limits: 40%
Indicator Opacity: (1)
(1) If visible emissions are observed other than startup, shutdown or malfunction, a stack
test may be required to demonstrate compliance with the particulate standard.
Authority for Requirement: Iowa DNR Construction Permit 98-A-033-S2
567 IAC23.3(2)"d"
Pollutant: PMio
Emission Limit(s): 0.9 lb./hr.
Authority for Requirement: Iowa DNR Construction Permit 98-A-033-S2
Pollutant: Particulate Matter (TSP)
Emission Limit(s): 0.01 gr./dscf
Authority for Requirement: Iowa DNR Construction Permit 98-A-033-S2
567 IAC 23.4(13)
Pollutant: Volatile Organic Compounds (VOC)
Emission Limit: See Facility-Wide Conditions
Authority for Requirement: Iowa DNR Construction Permit 98-A-033-S2
253
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Compliance Plan:
The owner/operator of this equipment shall comply with the following applicable
requirements.
This point is in compliance with all applicable requirements and shall continue to comply
with all such requirements. For those applicable requirements which will become
effective during the permit term, this source will comply with such requirements in a
timely manner.
Additional Requirements:
This emission point shall conform to the following conditions.
The source is to be connected to the stack of the following detailed description.
Stack Height (feet): 39.5
Stack Diameter (inches): 42.0
Stack Exhaust Flow Rate (acfm): .... 21,000
Stack Temperature (°F): 70
Vertical, Unobstructed Discharge Required: Yes ^ No ~
Authority for Requirement: Iowa DNR Construction Permit 98-A-033-S2
Periodic Monitoring Requirements:
The owner/operator of this equipment shall comply with the following periodic
monitoring requirements.
Stack Testing:
Pollutant: Particulate Matter (TSP)
Stack Test to be Completed by (date): October 18, 2001
Test Method: Iowa Compliance Sampling Manual
Authority for Requirement: 567 IAC 22.108(3)
This stack test will represent the compliance testing for emission points 2.F1, 2.F2, 3.F1,
3.F2, 4.G1, and 4.G2. In the event that a stack test of one of the other listed emission
points is more suitable it may be tested to fulfill the requirements. Suitability will be
determined by the Stack Test Observation Coordinator of the Air Quality Bureau
Compliance Assistance Section. The higher of the results for emissions from the
compliance stack testing of emission points 4.G1 and 4.G2 will be used to calculate
actual emissions for the listed sources until such time as more recent data becomes
available. If the source test does not demonstrate compliance this permit will be
reopened to add a compliance plan and operation and maintenance requirements.
The owner of this equipment or the owner's authorized agent shall provide written notice
to the Director, not less than 30 days before a required stack test or performance
evaluation of a continuous emission monitor. Results of the test shall be submitted in
writing to the Director in the form of a comprehensive report within 6 weeks of the
completion of the testing. 567 IAC 25.1(7)
254
-------
Periodic Monitoring Requirements (continued):
Opacity Monitoring:
The facility shall observe the opacity weekly during a period when the emission unit
associated with this emission point is at or near full capacity and record the reading
indicating if visible emissions were observed. The records shall be maintained for five
years. If weather conditions prevent the observer from conducting an opacity
observation, the observer shall note such conditions on the data observation sheet. At
least three attempts shall be made to retake opacity readings at approximately 2-hour
intervals throughout the day. If all observation attempts for a week have been
unsuccessful due to weather, an observation shall be made the next operating day where
weather permits.
Maintain a written record of the observation and any action resulting from the
observation.
Agency Approved Operation & Maintenance Plan Required? Yes ~ No Kl
Facility Maintained Operation & Maintenance Plan Required? Yes Kl NoQ
Facility operation and maintenance plans must be sufficient to yield reliable data from
the relevant time period that are representative of the source's compliance with the
applicable requirements.
Facility operation and maintenance plans are to be developed by the facility within six(6)
months of the issuance date of this permit and the data pertaining to the plan maintained
on site for at least 5 years. The plan and associated recordkeeping provides
documentation of this facility's implementation of its obligation to operate according to
good air pollution control practice.
Good air pollution control practice is achieved by adoption of quality control standards
in the operation and maintenance procedures for air pollution control that are
comparable to industry quality control standards for the production processes associated
with this emission point.
Authority for Requirement: 567 IAC 22.108(3)"b"
255
-------
Emission Point ID Number: 4.G2
Associated Equipment
Associated Emission Unit ID Numbers (if multiple units vent thru this EP): 4.G
Emissions Control Equipment ID Number: 4.G
Emissions Control Equipment Description: Paper Filter
Applicable Requirements
(If more than one emission unit vents through this emission point subdivide the applicable requirements by emission
unit.)
Emission Unit vented through this Emission Point: 4.G
Emission Unit Description: Finish Paint Booth
Raw Material/Fuel: Paints, Primers, and Solvents
Rated Capacity: 15 gal./hr.
Emission Limits (lb./hr. gr./dscf. lb./MMBtu. % opacity, etc.):
The emissions from this emission point shall not exceed the following specified levels.
Pollutant: Opacity
Emission Limits: 40%
Indicator Opacity: (1)
(1) If visible emissions are observed other than startup, shutdown or malfunction, a stack
test may be required to demonstrate compliance with the particulate standard.
Authority for Requirement: Iowa DNR Construction Permit 98-A-034-S2
567 IAC23.3(2)"d"
Pollutant: PMio
Emission Limit(s): 0.9 lb./hr.
Authority for Requirement: Iowa DNR Construction Permit 98-A-034-S2
Pollutant: Particulate Matter (TSP)
Emission Limit(s): 0.01 gr./dscf
Authority for Requirement: Iowa DNR Construction Permit 98-A-034-S2
567 IAC 23.4(13)
Pollutant: Volatile Organic Compounds (VOC)
Emission Limit: See Facility-Wide Conditions
Authority for Requirement: Iowa DNR Construction Permit 98-A-034-S2
256
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Compliance Plan:
The owner/operator of this equipment shall comply with the following applicable
requirements.
This point is in compliance with all applicable requirements and shall continue to comply
with all such requirements. For those applicable requirements which will become
effective during the permit term, this source will comply with such requirements in a
timely manner.
Additional Requirements:
This emission point shall conform to the following conditions.
The source is to be connected to the stack of the following detailed description.
Stack Height (feet): 39.5
Stack Diameter (inches): 42.0
Stack Exhaust Flow Rate (acfm): .... 21,000
Stack Temperature (°F): 70
Vertical, Unobstructed Discharge Required: Yes ^ No ~
Authority for Requirement: Iowa DNR Construction Permit 98-A-034-S2
Periodic Monitoring Requirements:
The owner/operator of this equipment shall comply with the following periodic
monitoring requirements.
Stack Testing:
Pollutant: Particulate Matter (TSP)
Stack Test to be Completed by (date): October 18, 2001
Test Method: Iowa Compliance Sampling Manual
Authority for Requirement: 567 IAC 22.108(3)
This stack test will represent the compliance testing for emission points 2.F1, 2.F2, 3.F1,
3.F2, 4.G1, and 4.G2. In the event that a stack test of one of the other listed emission
points is more suitable it may be tested to fulfill the requirements. Suitability will be
determined by the Stack Test Observation Coordinator of the Air Quality Bureau
Compliance Assistance Section. The higher of the results for emissions from the
compliance stack testing of emission points 4.G1 and 4.G2 will be used to calculate
actual emissions for the listed sources until such time as more recent data becomes
available. If the source test does not demonstrate compliance this permit will be
reopened to add a compliance plan and operation and maintenance requirements.
The owner of this equipment or the owner's authorized agent shall provide written notice
to the Director, not less than 30 days before a required stack test or performance
evaluation of a continuous emission monitor. Results of the test shall be submitted in
writing to the Director in the form of a comprehensive report within 6 weeks of the
completion of the testing. 567 IAC 25.1(7)
257
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Periodic Monitoring Requirements (continued):
Opacity Monitoring:
The facility shall observe the opacity weekly during a period when the emission unit
associated with this emission point is at or near full capacity and record the reading
indicating if visible emissions were observed. The records shall be maintained for five
years. If weather conditions prevent the observer from conducting an opacity
observation, the observer shall note such conditions on the data observation sheet. At
least three attempts shall be made to retake opacity readings at approximately 2-hour
intervals throughout the day. If all observation attempts for a week have been
unsuccessful due to weather, an observation shall be made the next operating day where
weather permits.
Maintain a written record of the observation and any action resulting from the
observation.
Agency Approved Operation & Maintenance Plan Required? Yes ~ No Kl
Facility Maintained Operation & Maintenance Plan Required? Yes Kl NoQ
Facility operation and maintenance plans must be sufficient to yield reliable data from
the relevant time period that are representative of the source's compliance with the
applicable requirements.
Facility operation and maintenance plans are to be developed by the facility within six(6)
months of the issuance date of this permit and the data pertaining to the plan maintained
on site for at least 5 years. The plan and associated recordkeeping provides
documentation of this facility's implementation of its obligation to operate according to
good air pollution control practice.
Good air pollution control practice is achieved by adoption of quality control standards
in the operation and maintenance procedures for air pollution control that are
comparable to industry quality control standards for the production processes associated
with this emission point.
Authority for Requirement: 567 IAC 22.108(3)"b"
258
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Emission Point ID Number: 4.H2
Associated Equipment
Associated Emission Unit ID Numbers (if multiple units vent thru this EP): 4.H2
Applicable Requirements
(If more than one emission unit vents through this emission point subdivide the applicable requirements by emission
unit.)
Emission Unit vented through this Emission Point: 4.H2
Emission Unit Description: Non-Production Heating Unit
Raw Material/Fuel: Natural Gas
Rated Capacity: 5.35 MMBtu/hr.
Emission Limits (lb./hr. gr./dscf. lb./MMBtu. % opacity, etc.):
The emissions from this emission point shall not exceed the following specified levels.
Pollutant: Opacity
Emission Limit(s): 40 %
Authority for Requirement: 567 IAC 23.3(2)"d"
Pollutant: Particulate Matter (TSP)
Emission Limit(s): 15.3 lb./MMCF of LPG or Natural Gas
Authority for Requirement: Part 7a. of State of Iowa, ex rel., Iowa DNR vs. Vermeer
Manufacturing Company, 99AG23542
District Court, Marion County, Law No. LACV087889
Pollutant: Particulate Matter (TSP)
Emission Limits: 0.8 lb./MMBtu
Authority for Requirement: 567 IAC 23.3(2)"b"
Pollutant: Sulfur Dioxide (SO2)
Emission Limits: 500 ppmv
Authority for Requirement: 567 IAC 23.3(3)"e"
Pollutant: Nitrogen Oxides (NOx)
Emission Limit(s): See Facility-Wide Conditions
Authority for Requirement: Iowa DNR Construction Permit 98-A-003-S1
Pollutant: Volatile Organic Compounds (VOC)
Emission Limit: See Facility-Wide Conditions
Authority for Requirement: Iowa DNR Construction Permit 98-A-003-S1
259
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Operational Limits & Requirements:
The owner/operator of this equipment shall comply with the following operational limits
and requirements.
Process throughput:
A. The sulfur content of natural gas or LPG combusted by this source is not to
exceed 123 ppm by weight.
Reporting & Recordkeeping: See Facility-Wide Operational Limits
Authority for Requirement: Part 7b. of State of Iowa, ex rel., Iowa DNR vs. Vermeer
Manufacturing Company, 99AG23542
District Court, Marion County, Law No. LACV087889
Compliance Plan:
The owner/operator of this equipment shall comply with the following applicable
requirements.
This point is in compliance with all applicable requirements and shall continue to comply
with all such requirements. For those applicable requirements which will become
effective during the permit term, this source will comply with such requirements in a
timely manner.
Periodic Monitoring Requirements:
The owner/operator of this equipment shall comply with the following periodic
monitoring requirements.
Agency Approved Operation & Maintenance Plan Required? Yes ~ No IXI
Facility Maintained Operation & Maintenance Plan Required? Yes ~ No Kl
Authority for Requirement: 567 IAC 22.108(3)"b"
260
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Emission Point ID Number: 4.1
Associated Equipment
Associated Emission Unit ID Numbers (if multiple units vent thru this EP): 4.1
Applicable Requirements
(If more than one emission unit vents through this emission point subdivide the applicable requirements by emission
unit.)
Emission Unit vented through this Emission Point: 4.1
Emission Unit Description: Production Engine Testing Unit
Raw Material/Fuel: #2 Diesel Fuel and Gasoline
Rated Capacity: 60.6 gal./hr.
Emission Limits (lb./hr. gr./dscf. lb./MMBtu. % opacity, etc.):
The emissions from this emission point shall not exceed the following specified levels.
Pollutant: Opacity
Emission Limits: 40%
Indicator Opacity: 25%(1)
(1) If visible emissions are observed that exceed the indicator opacity other than startup,
shutdown or malfunction, a stack test may be required to demonstrate compliance with
the particulate standard.
Authority for Requirement: Iowa DNR Construction Permit 97-A-l 108-S2
567 IAC 23.3(2)"d"
Pollutant: Particulate Matter (TSP)
Emission Limits: 0.1 gr./dscf
Authority for Requirement: Iowa DNR Construction Permit 97-A-l 108-S2
567 IAC 23.3(2)"a"
Pollutant: Sulfur Dioxide (SO2)
Emission Limits: 2.5 lb./MMBtu
Authority for Requirement: Iowa DNR Construction Permit 97-A-l 108-S2
567 IAC 23.3(3)"b"
Pollutant: Nitrogen Oxides (NOx)
Emission Limit(s): See Facility-Wide Conditions
Authority for Requirement: Iowa DNR Construction Permit 97-A-l 108-S2
Pollutant: Volatile Organic Compounds (VOC)
Emission Limit: See Facility-Wide Conditions
Authority for Requirement: Iowa DNR Construction Permit 97-A-l 108-S2
261
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Operational Limits & Requirements:
The owner/operator of this equipment shall comply with the following operational limits
and requirements.
Process Throughput:
A. The sulfur content of any diesel fuel used in this source shall not exceed 0.4% by
weight.
Reporting & Recordkeeping: See Facility-Wide Emission and Operational Limits
Authority for Requirement: Iowa DNR Construction Permit 97-A-l 108-S2
Compliance Plan:
The owner/operator of this equipment shall comply with the following applicable
requirements.
This point is in compliance with all applicable requirements and shall continue to comply
with all such requirements. For those applicable requirements which will become
effective during the permit term, this source will comply with such requirements in a
timely manner.
Additional Requirements:
This emission point shall conform to the following conditions.
The source is to be connected to the stack of the following detailed description.
Stack Height (feet): 36
Stack Diameter (inches): 12
Stack Exhaust Flow Rate (acfm): .... 7,386.8
Stack Temperature (°F): 845
Vertical, Unobstructed Discharge Required: Yes ^ No ~
Authority for Requirement: Iowa DNR Construction Permit 97-A-l 108-S2
Periodic Monitoring Requirements:
The owner/operator of this equipment shall comply with the following periodic
monitoring requirements.
Opacity Monitoring:
The facility shall observe the opacity weekly during a period when the emission unit
associated with this emission point is at or near full capacity and record the reading
indicating if visible emissions were observed. The records shall be maintained for five
years. If weather conditions prevent the observer from conducting an opacity
observation, the observer shall note such conditions on the data observation sheet. At
least three attempts shall be made to retake opacity readings at approximately 2-hour
intervals throughout the day. If all observation attempts for a week have been
unsuccessful due to weather, an observation shall be made the next operating day where
weather permits.
Maintain a written record of the observation and any action resulting from the
observation.
262
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Agency Approved Operation & Maintenance Plan Required? Yes ~ No Kl
Facility Maintained Operation & Maintenance Plan Required? Yes ~ No Kl
Authority for Requirement: 567 IAC 22.108(3)"b"
263
-------
Emission Point ID Number: 4. J
Associated Equipment
Associated Emission Unit ID Numbers (if multiple units vent thru this EP): 4. J
Applicable Requirements
(If more than one emission unit vents through this emission point subdivide the applicable requirements by emission
unit.)
Emission Unit vented through this Emission Point: 4.J
Emission Unit Description: Production Engine Testing Unit
Raw Material/Fuel: #2 Diesel Fuel and Gasoline
Rated Capacity: 37.3 gal./hr.
Emission Limits (lb./hr. gr./dscf. lb./MMBtu. % opacity, etc.):
The emissions from this emission point shall not exceed the following specified levels.
Pollutant: Opacity
Emission Limit(s): 40 %
Authority for Requirement: 567 IAC 23.3(2)"d"
Pollutant:
Emission Limits:
Authority for Requirement:
Particulate Matter (TSP)
0.1 gr./dscf
567 IAC 23.3(2)"a"
Pollutant: Sulfur Dioxide (SO2)
Emission Limits: 2.5 lb./MMBtu
Authority for Requirement: 567 IAC 23.3(3)"b"
Pollutant: Nitrogen Oxides (NOx)
Emission Limit(s): See Facility-Wide Conditions
Authority for Requirement: Iowa DNR Construction Permit 97-A-299-S2
Pollutant: Volatile Organic Compounds (VOC)
Emission Limit: See Facility-Wide Conditions
Authority for Requirement: Iowa DNR Construction Permit 97-A-299-S2
264
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Operational Limits & Requirements:
The owner/operator of this equipment shall comply with the following operational limits
and requirements.
Process Throughput:
A. The sulfur content of any diesel fuel used in this source shall not exceed 0.4% by
weight.
Reporting & Recordkeeping: See Facility-Wide Emission and Operational Limits
Authority for Requirement: Iowa DNR Construction Permit 97-A-299-S2
Compliance Plan:
The owner/operator of this equipment shall comply with the following applicable
requirements.
This point is in compliance with all applicable requirements and shall continue to comply
with all such requirements. For those applicable requirements which will become
effective during the permit term, this source will comply with such requirements in a
timely manner.
Periodic Monitoring Requirements:
The owner/operator of this equipment shall comply with the following periodic
monitoring requirements.
Agency Approved Operation & Maintenance Plan Required? Yes ~ No Kl
Facility Maintained Operation & Maintenance Plan Required? Yes ~ No Kl
Authority for Requirement: 567 IAC 22.108(3)"b"
265
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Emission Point ID Number: 4.K2
Associated Equipment
Associated Emission Unit ID Numbers (if multiple units vent thru this EP): 4.K2
Applicable Requirements
(If more than one emission unit vents through this emission point subdivide the applicable requirements by emission
unit.)
Emission Unit vented through this Emission Point: 4.K2
Emission Unit Description: Non-Production Heating Unit
Raw Material/Fuel: Natural Gas
Rated Capacity: 5.35 MMBtu/hr.
Emission Limits (lb./hr. gr./dscf. lb./MMBtu. % opacity, etc.):
The emissions from this emission point shall not exceed the following specified levels.
Pollutant: Opacity
Emission Limit(s): 40 %
Authority for Requirement: 567 IAC 23.3(2)"d"
Pollutant: Particulate Matter (TSP)
Emission Limit(s): 15.3 lb./MMCF of LPG or Natural Gas
Authority for Requirement: Part 7a. of State of Iowa, ex rel., Iowa DNR vs. Vermeer
Manufacturing Company, 99AG23542
District Court, Marion County, Law No. LACV087889
Pollutant: Particulate Matter (TSP)
Emission Limits: 0.8 lb./MMBtu
Authority for Requirement: 567 IAC 23.3(2)"b"
Pollutant: Sulfur Dioxide (SO2)
Emission Limits: 500 ppmv
Authority for Requirement: 567 IAC 23.3(3)"e"
Pollutant: Nitrogen Oxides (NOx)
Emission Limit(s): See Facility-Wide Conditions
Authority for Requirement: Iowa DNR Construction Permit 98-A-003-S1
Pollutant: Volatile Organic Compounds (VOC)
Emission Limit: See Facility-Wide Conditions
Authority for Requirement: Iowa DNR Construction Permit 98-A-003-S1
266
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Operational Limits & Requirements:
The owner/operator of this equipment shall comply with the following operational limits
and requirements.
Process throughput:
A. The sulfur content of natural gas or LPG combusted by this source is not to
exceed 123 ppm by weight.
Reporting & Recordkeeping: See Facility-Wide Operational Limits
Authority for Requirement: Part 7b. of State of Iowa, ex rel., Iowa DNR vs. Vermeer
Manufacturing Company, 99AG23542
District Court, Marion County, Law No. LACV087889
Compliance Plan:
The owner/operator of this equipment shall comply with the following applicable
requirements.
This point is in compliance with all applicable requirements and shall continue to comply
with all such requirements. For those applicable requirements which will become
effective during the permit term, this source will comply with such requirements in a
timely manner.
Periodic Monitoring Requirements:
The owner/operator of this equipment shall comply with the following periodic
monitoring requirements.
Agency Approved Operation & Maintenance Plan Required? Yes ~ No IXI
Facility Maintained Operation & Maintenance Plan Required? Yes ~ No Kl
Authority for Requirement: 567 IAC 22.108(3)"b"
267
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Emission Point ID Number: 4.L
Associated Equipment
Associated Emission Unit ID Numbers (if multiple units vent thru this EP): 4.L
Applicable Requirements
(If more than one emission unit vents through this emission point subdivide the applicable requirements by emission
unit.)
Emission Unit vented through this Emission Point: 4.L
Emission Unit Description: Non-Production Heating Unit
Raw Material/Fuel: Natural Gas
Rated Capacity: 0.24 MMBtu/hr.
Emission Limits (lb./hr. gr./dscf. lb./MMBtu. % opacity, etc.):
The emissions from this emission point shall not exceed the following specified levels.
Pollutant: Opacity
Emission Limit(s): 40 %
Authority for Requirement: 567 IAC 23.3(2)"d"
Pollutant: Particulate Matter (TSP)
Emission Limit(s): 15.3 lb./MMCF of LPG or Natural Gas
Authority for Requirement: Part 7a. of State of Iowa, ex rel., Iowa DNR vs. Vermeer
Manufacturing Company, 99AG23542
District Court, Marion County, Law No. LACV087889
Pollutant: Particulate Matter (TSP)
Emission Limits: 0.8 lb./MMBtu
Authority for Requirement: 567 IAC 23.3(2)"b"
Pollutant: Sulfur Dioxide (SO2)
Emission Limits: 500 ppmv
Authority for Requirement: 567 IAC 23.3(3)"e"
Pollutant: Nitrogen Oxides (NOx)
Emission Limit(s): See Facility-Wide Conditions
Authority for Requirement: Iowa DNR Construction Permit 98-A-003-S1
Pollutant: Volatile Organic Compounds (VOC)
Emission Limit: See Facility-Wide Conditions
Authority for Requirement: Iowa DNR Construction Permit 98-A-003-S1
268
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Operational Limits & Requirements:
The owner/operator of this equipment shall comply with the following operational limits
and requirements.
Process throughput:
A. The sulfur content of natural gas or LPG combusted by this source is not to
exceed 123 ppm by weight.
Reporting & Recordkeeping: See Facility-Wide Operational Limits
Authority for Requirement: Part 7b. of State of Iowa, ex rel., Iowa DNR vs. Vermeer
Manufacturing Company, 99AG23542
District Court, Marion County, Law No. LACV087889
Compliance Plan:
The owner/operator of this equipment shall comply with the following applicable
requirements.
This point is in compliance with all applicable requirements and shall continue to comply
with all such requirements. For those applicable requirements which will become
effective during the permit term, this source will comply with such requirements in a
timely manner.
Periodic Monitoring Requirements:
The owner/operator of this equipment shall comply with the following periodic
monitoring requirements.
Agency Approved Operation & Maintenance Plan Required? Yes ~ No IXI
Facility Maintained Operation & Maintenance Plan Required? Yes ~ No Kl
Authority for Requirement: 567 IAC 22.108(3)"b"
269
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Emission Point ID Number: 4.LASER
Associated Equipment
Associated Emission Unit ID Numbers (if multiple units vent thru this EP): 4.LASER
Emissions Control Equipment ID Number: 4.LASER
Emissions Control Equipment Description: Baghouse
Applicable Requirements
(If more than one emission unit vents through this emission point subdivide the applicable requirements by emission
unit.)
Emission Unit vented through this Emission Point: 4.LASER (Fugitive)
Emission Unit Description: Single Head Laser Cutting Machine
Raw Material/Fuel: Sheet Steel
Rated Capacity: 8,268 inches of metal cut/hr.
Emission Limits (lb./hr. gr./dscf. lb./MMBtu. % opacity, etc.):
The emissions from this emission point shall not exceed the following specified levels.
Pollutant: Fugitive Dust
Emission Limit: No person shall allow, cause or permit any materials to be handled,
transported or stored; or a building, its appurtenances or a construction haul road to
be used, constructed, altered , repaired or demolished, without taking reasonable
precautions to prevent a nuisance. All persons shall take reasonable precautions to
prevent the discharge of visible emissions of fugitive dusts beyond the lot line of the
property on which the emissions originate.
Authority for Requirement: 567 IAC 23.3(2)"c"
Compliance Plan:
The owner/operator of this equipment shall comply with the following applicable
requirements.
This point is in compliance with all applicable requirements and shall continue to comply
with all such requirements. For those applicable requirements which will become
effective during the permit term, this source will comply with such requirements in a
timely manner.
Periodic Monitoring Requirements:
The owner/operator of this equipment shall comply with the following periodic
monitoring requirements.
Agency Approved Operation & Maintenance Plan Required? Yes ~ No Kl
Facility Maintained Operation & Maintenance Plan Required? Yes ~ No Kl
Authority for Requirement: 567 IAC 22.108(3)"b"
270
-------
Emission Point ID Number: 4.PLASMA1
Associated Equipment
Associated Emission Unit ID Numbers (if multiple units vent thru this EP): 4.PLASMA1
Applicable Requirements
(If more than one emission unit vents through this emission point subdivide the applicable requirements by emission
unit.)
Emission Unit vented through this Emission Point: 4.PLASMA1 (Fugitive)
Emission Unit Description: Single Head Plasma Cutting
Machine
Raw Material/Fuel: Sheet Steel
Rated Capacity: 4,500 inches of metal cut/hr.
Emission Limits (lb./hr. gr./dscf. lb./MMBtu. % opacity, etc.):
The emissions from this emission point shall not exceed the following specified levels.
Pollutant: Fugitive Dust
Emission Limit: No person shall allow, cause or permit any materials to be handled,
transported or stored; or a building, its appurtenances or a construction haul road to
be used, constructed, altered , repaired or demolished, without taking reasonable
precautions to prevent a nuisance. All persons shall take reasonable precautions to
prevent the discharge of visible emissions of fugitive dusts beyond the lot line of the
property on which the emissions originate.
Authority for Requirement: 567 IAC 23.3(2)"c"
Compliance Plan:
The owner/operator of this equipment shall comply with the following applicable
requirements.
This point is in compliance with all applicable requirements and shall continue to comply
with all such requirements. For those applicable requirements which will become
effective during the permit term, this source will comply with such requirements in a
timely manner.
Periodic Monitoring Requirements:
The owner/operator of this equipment shall comply with the following periodic
monitoring requirements.
Agency Approved Operation & Maintenance Plan Required? Yes ~ No IXI
Facility Maintained Operation & Maintenance Plan Required? Yes ~ No Kl
Authority for Requirement: 567 IAC 22.108(3)"b"
271
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Emission Point ID Number: 4.PLASMA2
Associated Equipment
Associated Emission Unit ID Numbers (if multiple units vent thru this EP): 4.PLASMA2
Applicable Requirements
(If more than one emission unit vents through this emission point subdivide the applicable requirements by emission
unit.)
Emission Unit vented through this Emission Point: 4.PLASMA2 (Fugitive)
Emission Unit Description: Single Head Plasma Cutting
Machine
Raw Material/Fuel: Sheet Steel
Rated Capacity: 4,500 inches of metal cut/hr.
Emission Limits (lb./hr. gr./dscf. lb./MMBtu. % opacity, etc.):
The emissions from this emission point shall not exceed the following specified levels.
Pollutant: Fugitive Dust
Emission Limit: No person shall allow, cause or permit any materials to be handled,
transported or stored; or a building, its appurtenances or a construction haul road to
be used, constructed, altered , repaired or demolished, without taking reasonable
precautions to prevent a nuisance. All persons shall take reasonable precautions to
prevent the discharge of visible emissions of fugitive dusts beyond the lot line of the
property on which the emissions originate.
Authority for Requirement: 567 IAC 23.3(2)"c"
Compliance Plan:
The owner/operator of this equipment shall comply with the following applicable
requirements.
This point is in compliance with all applicable requirements and shall continue to comply
with all such requirements. For those applicable requirements which will become
effective during the permit term, this source will comply with such requirements in a
timely manner.
Periodic Monitoring Requirements:
The owner/operator of this equipment shall comply with the following periodic
monitoring requirements.
Agency Approved Operation & Maintenance Plan Required? Yes ~ No IXI
Facility Maintained Operation & Maintenance Plan Required? Yes ~ No Kl
Authority for Requirement: 567 IAC 22.108(3)"b"
272
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Emission Point ID Number: 4.PLASMA3
Associated Equipment
Associated Emission Unit ID Numbers (if multiple units vent thru this EP): 4.PLASMA3
Applicable Requirements
(If more than one emission unit vents through this emission point subdivide the applicable requirements by emission
unit.)
Emission Unit vented through this Emission Point: 4.PLASMA3 (Fugitive)
Emission Unit Description: Single Head Plasma Cutting
Machine
Raw Material/Fuel: Sheet Steel
Rated Capacity: 4,500 inches of metal cut/hr.
Emission Limits (lb./hr. gr./dscf. lb./MMBtu. % opacity, etc.):
The emissions from this emission point shall not exceed the following specified levels.
Pollutant: Fugitive Dust
Emission Limit: No person shall allow, cause or permit any materials to be handled,
transported or stored; or a building, its appurtenances or a construction haul road to
be used, constructed, altered , repaired or demolished, without taking reasonable
precautions to prevent a nuisance. All persons shall take reasonable precautions to
prevent the discharge of visible emissions of fugitive dusts beyond the lot line of the
property on which the emissions originate.
Authority for Requirement: 567 IAC 23.3(2)"c"
Compliance Plan:
The owner/operator of this equipment shall comply with the following applicable
requirements.
This point is in compliance with all applicable requirements and shall continue to comply
with all such requirements. For those applicable requirements which will become
effective during the permit term, this source will comply with such requirements in a
timely manner.
Periodic Monitoring Requirements:
The owner/operator of this equipment shall comply with the following periodic
monitoring requirements.
Agency Approved Operation & Maintenance Plan Required? Yes ~ No IXI
Facility Maintained Operation & Maintenance Plan Required? Yes ~ No Kl
Authority for Requirement: 567 IAC 22.108(3)"b"
273
-------
Emission Point ID Number: 4.PLASMA4
Associated Equipment
Associated Emission Unit ID Numbers (if multiple units vent thru this EP): 4.PLASMA4
Emissions Control Equipment ID Number: 4.PLASMA4
Emissions Control Equipment Description: Baghouse
Applicable Requirements
(If more than one emission unit vents through this emission point subdivide the applicable requirements by emission
unit.)
Emission Unit vented through this Emission Point: 4.PLASMA4 (Fugitive)
Emission Unit Description: Single Head Whitney Plasma Cutting
Machine
Raw Material/Fuel: Sheet Steel
Rated Capacity: 12,000 inches of metal cut/hr.
Emission Limits (lb./hr. gr./dscf. lb./MMBtu. % opacity, etc.):
The emissions from this emission point shall not exceed the following specified levels.
Pollutant: Fugitive Dust
Emission Limit: No person shall allow, cause or permit any materials to be handled,
transported or stored; or a building, its appurtenances or a construction haul road to
be used, constructed, altered , repaired or demolished, without taking reasonable
precautions to prevent a nuisance. All persons shall take reasonable precautions to
prevent the discharge of visible emissions of fugitive dusts beyond the lot line of the
property on which the emissions originate.
Authority for Requirement: 567 IAC 23.3(2)"c"
Compliance Plan:
The owner/operator of this equipment shall comply with the following applicable
requirements.
This point is in compliance with all applicable requirements and shall continue to comply
with all such requirements. For those applicable requirements which will become
effective during the permit term, this source will comply with such requirements in a
timely manner.
Periodic Monitoring Requirements:
The owner/operator of this equipment shall comply with the following periodic
monitoring requirements.
Agency Approved Operation & Maintenance Plan Required? Yes ~ No Kl
Facility Maintained Operation & Maintenance Plan Required? Yes ~ No Kl
Authority for Requirement: 567 IAC 22.108(3)"b"
274
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Emission Point ID Number: 4.PLASMA5
Associated Equipment
Associated Emission Unit ID Numbers (if multiple units vent thru this EP): 4.PLASMA5
Emissions Control Equipment ID Number: 4.PLASMA5
Emissions Control Equipment Description: Baghouse
Applicable Requirements
(If more than one emission unit vents through this emission point subdivide the applicable requirements by emission
unit.)
Emission Unit vented through this Emission Point: 4.PLASMA5 (Fugitive)
Emission Unit Description: Single Head Whitney Plasma Cutting
Machine
Raw Material/Fuel: Sheet Steel
Rated Capacity: 12,000 inches of metal cut/hr.
Emission Limits (lb./hr. gr./dscf. lb./MMBtu. % opacity, etc.):
The emissions from this emission point shall not exceed the following specified levels.
Pollutant: Fugitive Dust
Emission Limit: No person shall allow, cause or permit any materials to be handled,
transported or stored; or a building, its appurtenances or a construction haul road to
be used, constructed, altered , repaired or demolished, without taking reasonable
precautions to prevent a nuisance. All persons shall take reasonable precautions to
prevent the discharge of visible emissions of fugitive dusts beyond the lot line of the
property on which the emissions originate.
Authority for Requirement: 567 IAC 23.3(2)"c"
Compliance Plan:
The owner/operator of this equipment shall comply with the following applicable
requirements.
This point is in compliance with all applicable requirements and shall continue to comply
with all such requirements. For those applicable requirements which will become
effective during the permit term, this source will comply with such requirements in a
timely manner.
Periodic Monitoring Requirements:
The owner/operator of this equipment shall comply with the following periodic
monitoring requirements.
Agency Approved Operation & Maintenance Plan Required? Yes ~ No Kl
Facility Maintained Operation & Maintenance Plan Required? Yes ~ No Kl
Authority for Requirement: 567 IAC 22.108(3)"b"
275
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Emission Point ID Number: 4.PRTWSH
Associated Equipment
Associated Emission Unit ID Numbers (if multiple units vent thru this EP): 4.PRTWSH
Applicable Requirements
(If more than one emission unit vents through this emission point subdivide the applicable requirements by emission
unit.)
Emission Unit vented through this Emission Point: 4.PRTWSH (Fugitive)
Emission Unit Description: Seven (7) Safety Kleen Parts
Washers
Raw Material/Fuel: Stoddard Solvent
Rated Capacity: 55 Gallons Solvent per Washer
Emission Limits (lb./hr. gr./dscf. lb./MMBtu. % opacity, etc.):
The emissions from this emission point shall not exceed the following specified levels.
Pollutant: Volatile Organic Compounds (VOC)
Emission Limit: See Facility-Wide Conditions
Authority for Requirement: Iowa DNR Construction Permit 98-A-003-S1
Compliance Plan:
The owner/operator of this equipment shall comply with the following applicable
requirements.
This point is in compliance with all applicable requirements and shall continue to comply
with all such requirements. For those applicable requirements which will become
effective during the permit term, this source will comply with such requirements in a
timely manner.
Periodic Monitoring Requirements:
The owner/operator of this equipment shall comply with the following periodic
monitoring requirements.
Agency Approved Operation & Maintenance Plan Required? Yes ~ No Kl
Facility Maintained Operation & Maintenance Plan Required? Yes ~ No Kl
Authority for Requirement: 567 IAC 22.108(3)"b"
276
-------
Emission Point ID Number: 4.R
Associated Equipment
Associated Emission Unit ID Numbers (if multiple units vent thru this EP): 4.R
Applicable Requirements
(If more than one emission unit vents through this emission point subdivide the applicable requirements by emission
unit.)
Emission Unit vented through this Emission Point: 4.R
Emission Unit Description: Non-Production Heating Unit
Raw Material/Fuel: Natural Gas
Rated Capacity: 3.24 MMBtu/hr.
Emission Limits (lb./hr. gr./dscf. lb./MMBtu. % opacity, etc.):
The emissions from this emission point shall not exceed the following specified levels.
Pollutant: Opacity
Emission Limit(s): 40 %
Authority for Requirement: 567 IAC 23.3(2)"d"
Pollutant: Particulate Matter (TSP)
Emission Limit(s): 15.3 lb./MMCF of LPG or Natural Gas
Authority for Requirement: Part 7a. of State of Iowa, ex rel., Iowa DNR vs. Vermeer
Manufacturing Company, 99AG23542
District Court, Marion County, Law No. LACV087889
Pollutant: Particulate Matter (TSP)
Emission Limits: 0.8 lb./MMBtu
Authority for Requirement: 567 IAC 23.3(2)"b"
Pollutant: Sulfur Dioxide (SO2)
Emission Limits: 500 ppmv
Authority for Requirement: 567 IAC 23.3(3)"e"
Pollutant: Nitrogen Oxides (NOx)
Emission Limit(s): See Facility-Wide Conditions
Authority for Requirement: Iowa DNR Construction Permit 98-A-003-S1
Pollutant: Volatile Organic Compounds (VOC)
Emission Limit: See Facility-Wide Conditions
Authority for Requirement: Iowa DNR Construction Permit 98-A-003-S1
277
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Operational Limits & Requirements:
The owner/operator of this equipment shall comply with the following operational limits
and requirements.
Process throughput:
A. The sulfur content of natural gas or LPG combusted by this source is not to
exceed 123 ppm by weight.
Reporting & Recordkeeping: See Facility-Wide Operational Limits
Authority for Requirement: Part 7b. of State of Iowa, ex rel., Iowa DNR vs. Vermeer
Manufacturing Company, 99AG23542
District Court, Marion County, Law No. LACV087889
Compliance Plan:
The owner/operator of this equipment shall comply with the following applicable
requirements.
This point is in compliance with all applicable requirements and shall continue to comply
with all such requirements. For those applicable requirements which will become
effective during the permit term, this source will comply with such requirements in a
timely manner.
Periodic Monitoring Requirements:
The owner/operator of this equipment shall comply with the following periodic
monitoring requirements.
Agency Approved Operation & Maintenance Plan Required? Yes ~ No IXI
Facility Maintained Operation & Maintenance Plan Required? Yes ~ No Kl
Authority for Requirement: 567 IAC 22.108(3)"b"
278
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Emission Point ID Number: 4.S
Associated Equipment
Associated Emission Unit ID Numbers (if multiple units vent thru this EP): 4. S
Applicable Requirements
(If more than one emission unit vents through this emission point subdivide the applicable requirements by emission
unit.)
Emission Unit vented through this Emission Point: 4.S
Emission Unit Description: Production Engine Testing Unit
Raw Material/Fuel: #2 Diesel Fuel and Gasoline
Rated Capacity: 60.6 gal./hr.
Emission Limits (lb./hr. gr./dscf. lb./MMBtu. % opacity, etc.):
The emissions from this emission point shall not exceed the following specified levels.
Pollutant: Opacity
Emission Limits: 40%
Indicator Opacity: 25%(1)
(1) If visible emissions are observed that exceed the indicator opacity other than startup,
shutdown or malfunction, a stack test may be required to demonstrate compliance with
the particulate standard.
Authority for Requirement: Iowa DNR Construction Permit 97-A-l 109-S2
567 IAC 23.3(2)"d"
Pollutant: Particulate Matter (TSP)
Emission Limits: 0.1 gr./dscf
Authority for Requirement: Iowa DNR Construction Permit 97-A-l 109-S2
567 IAC 23.3(2)"a"
Pollutant: Sulfur Dioxide (SO2)
Emission Limits: 2.5 lb./MMBtu
Authority for Requirement: Iowa DNR Construction Permit 97-A-l 109-S2
567 IAC 23.3(3)"b"
Pollutant: Nitrogen Oxides (NOx)
Emission Limit(s): See Facility-Wide Conditions
Authority for Requirement: Iowa DNR Construction Permit 97-A-l 109-S2
Pollutant: Volatile Organic Compounds (VOC)
Emission Limit: See Facility-Wide Conditions
Authority for Requirement: Iowa DNR Construction Permit 97-A-l 109-S2
279
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Operational Limits & Requirements:
The owner/operator of this equipment shall comply with the following operational limits
and requirements.
Process Throughput:
A. The sulfur content of any diesel fuel used in this source shall not exceed 0.4% by
weight.
Reporting & Recordkeeping: See Facility-Wide Emission and Operational Limits
Authority for Requirement: Iowa DNR Construction Permit 97-A-l 109-S2
Compliance Plan:
The owner/operator of this equipment shall comply with the following applicable
requirements.
This point is in compliance with all applicable requirements and shall continue to comply
with all such requirements. For those applicable requirements which will become
effective during the permit term, this source will comply with such requirements in a
timely manner.
Additional Requirements:
This emission point shall conform to the following conditions.
The source is to be connected to the stack of the following detailed description.
Stack Height (feet): 36
Stack Diameter (inches): 12
Stack Exhaust Flow Rate (acfm): .... 7,386.8
Stack Temperature (°F): 845
Vertical, Unobstructed Discharge Required: Yes ^ No ~
Authority for Requirement: Iowa DNR Construction Permit 97-A-l 109-S2
Periodic Monitoring Requirements:
The owner/operator of this equipment shall comply with the following periodic
monitoring requirements.
Opacity Monitoring:
The facility shall observe the opacity weekly during a period when the emission unit
associated with this emission point is at or near full capacity and record the reading
indicating if visible emissions were observed. The records shall be maintained for five
years. The facility shall use EPA Method 22 for the monitoring method. If weather
conditions prevent the observer from conducting an opacity observation, the observer
shall note such conditions on the data observation sheet. At least three attempts shall
be made to retake opacity readings at approximately 2-hour intervals throughout the
day. If all observation attempts for a week have been unsuccessful due to weather, an
observation shall be made the next operating day where weather permits.
Maintain a written record of the observation and any action resulting from the
observation.
280
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Agency Approved Operation & Maintenance Plan Required? Yes ~ No Kl
Facility Maintained Operation & Maintenance Plan Required? Yes ~ No Kl
Authority for Requirement: 567 IAC 22.108(3)"b"
281
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Emission Point ID Number: 4.T
Associated Equipment
Associated Emission Unit ID Numbers (if multiple units vent thru this EP): 4.T
Applicable Requirements
(If more than one emission unit vents through this emission point subdivide the applicable requirements by emission
unit.)
Emission Unit vented through this Emission Point: 4.T
Emission Unit Description: Non-Production Heating Unit
Raw Material/Fuel: Natural Gas
Rated Capacity: 0.09 MMBtu/hr.
Emission Limits (lb./hr. gr./dscf. lb./MMBtu. % opacity, etc.):
The emissions from this emission point shall not exceed the following specified levels.
Pollutant: Opacity
Emission Limit(s): 40 %
Authority for Requirement: 567 IAC 23.3(2)"d"
Pollutant: Particulate Matter (TSP)
Emission Limit(s): 15.3 lb./MMCF of LPG or Natural Gas
Authority for Requirement: Part 7a. of State of Iowa, ex rel., Iowa DNR vs. Vermeer
Manufacturing Company, 99AG23542
District Court, Marion County, Law No. LACV087889
Pollutant: Particulate Matter (TSP)
Emission Limits: 0.8 lb./MMBtu
Authority for Requirement: 567 IAC 23.3(2)"b"
Pollutant: Sulfur Dioxide (SO2)
Emission Limits: 500 ppmv
Authority for Requirement: 567 IAC 23.3(3)"e"
Pollutant: Nitrogen Oxides (NOx)
Emission Limit(s): See Facility-Wide Conditions
Authority for Requirement: Iowa DNR Construction Permit 98-A-003-S1
Pollutant: Volatile Organic Compounds (VOC)
Emission Limit: See Facility-Wide Conditions
Authority for Requirement: Iowa DNR Construction Permit 98-A-003-S1
282
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Operational Limits & Requirements:
The owner/operator of this equipment shall comply with the following operational limits
and requirements.
Process throughput:
A. The sulfur content of natural gas or LPG combusted by this source is not to
exceed 123 ppm by weight.
Reporting & Recordkeeping: See Facility-Wide Operational Limits
Authority for Requirement: Part 7b. of State of Iowa, ex rel., Iowa DNR vs. Vermeer
Manufacturing Company, 99AG23542
District Court, Marion County, Law No. LACV087889
Compliance Plan:
The owner/operator of this equipment shall comply with the following applicable
requirements.
This point is in compliance with all applicable requirements and shall continue to comply
with all such requirements. For those applicable requirements which will become
effective during the permit term, this source will comply with such requirements in a
timely manner.
Periodic Monitoring Requirements:
The owner/operator of this equipment shall comply with the following periodic
monitoring requirements.
Agency Approved Operation & Maintenance Plan Required? Yes ~ No IXI
Facility Maintained Operation & Maintenance Plan Required? Yes ~ No Kl
Authority for Requirement: 567 IAC 22.108(3)"b"
283
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Emission Point ID Number: 4.TORCH
Associated Equipment
Associated Emission Unit ID Numbers (if multiple units vent thru this EP): 4.TORCH
Applicable Requirements
(If more than one emission unit vents through this emission point subdivide the applicable requirements by emission
unit.)
Emission Unit vented through this Emission Point: 4.TORCH (Fugitive)
Emission Unit Description: Thirteen (13) Single Cutting Head
Oxyacetylene Torch Units
Raw Material/Fuel: Sheet Steel
Rated Capacity: 840 inches of metal cut/hr. per Head
Emission Limits (lb./hr. gr./dscf. lb./MMBtu. % opacity, etc.):
The emissions from this emission point shall not exceed the following specified levels.
Pollutant: Fugitive Dust
Emission Limit: No person shall allow, cause or permit any materials to be handled,
transported or stored; or a building, its appurtenances or a construction haul road to
be used, constructed, altered , repaired or demolished, without taking reasonable
precautions to prevent a nuisance. All persons shall take reasonable precautions to
prevent the discharge of visible emissions of fugitive dusts beyond the lot line of the
property on which the emissions originate.
Authority for Requirement: 567 IAC 23.3(2)"c"
Compliance Plan:
The owner/operator of this equipment shall comply with the following applicable
requirements.
This point is in compliance with all applicable requirements and shall continue to comply
with all such requirements. For those applicable requirements which will become
effective during the permit term, this source will comply with such requirements in a
timely manner.
Periodic Monitoring Requirements:
The owner/operator of this equipment shall comply with the following periodic
monitoring requirements.
Agency Approved Operation & Maintenance Plan Required? Yes ~ No IXI
Facility Maintained Operation & Maintenance Plan Required? Yes ~ No Kl
Authority for Requirement: 567 IAC 22.108(3)"b"
284
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Emission Point ID Number: 4.WELDING
Associated Equipment
Associated Emission Unit ID Numbers (if multiple units vent thru this EP): 4. WELDING
Applicable Requirements
(If more than one emission unit vents through this emission point subdivide the applicable requirements by emission
unit.)
Emission Unit vented through this Emission Point: 4.WELDING (Fugitive)
Emission Unit Description: 66 GMAW Units
Raw Material/Fuel: E70S Weld Wire
Rated Capacity: 19 lb. ofWire/hr. per Unit
Emission Limits (lb./hr. gr./dscf. lb./MMBtu. % opacity, etc.):
The emissions from this emission point shall not exceed the following specified levels.
Pollutant: Fugitive Dust
Emission Limit: No person shall allow, cause or permit any materials to be handled,
transported or stored; or a building, its appurtenances or a construction haul road to
be used, constructed, altered , repaired or demolished, without taking reasonable
precautions to prevent a nuisance. All persons shall take reasonable precautions to
prevent the discharge of visible emissions of fugitive dusts beyond the lot line of the
property on which the emissions originate.
Authority for Requirement: 567 IAC 23.3(2)"c"
Compliance Plan:
The owner/operator of this equipment shall comply with the following applicable
requirements.
This point is in compliance with all applicable requirements and shall continue to comply
with all such requirements. For those applicable requirements which will become
effective during the permit term, this source will comply with such requirements in a
timely manner.
Periodic Monitoring Requirements:
The owner/operator of this equipment shall comply with the following periodic
monitoring requirements.
Agency Approved Operation & Maintenance Plan Required? Yes ~ No Kl
Facility Maintained Operation & Maintenance Plan Required? Yes ~ No Kl
Authority for Requirement: 567 IAC 22.108(3)"b"
285
-------
Emission Point ID Number: 4.WELDPLS
Associated Equipment
Associated Emission Unit ID Numbers (if multiple units vent thru this EP): 4. WELDPLS
Applicable Requirements
(If more than one emission unit vents through this emission point subdivide the applicable requirements by emission
unit.)
Emission Unit vented through this Emission Point: 4.WELDPLS (Fugitive)
Emission Unit Description: 30 Pulse Current GMAW Units
Raw Material/Fuel: E70S Weld Wire
Rated Capacity: 19 lb. ofWire/hr. per Unit
Emission Limits (lb./hr. gr./dscf. lb./MMBtu. % opacity, etc.):
The emissions from this emission point shall not exceed the following specified levels.
Pollutant: Fugitive Dust
Emission Limit: No person shall allow, cause or permit any materials to be handled,
transported or stored; or a building, its appurtenances or a construction haul road to
be used, constructed, altered , repaired or demolished, without taking reasonable
precautions to prevent a nuisance. All persons shall take reasonable precautions to
prevent the discharge of visible emissions of fugitive dusts beyond the lot line of the
property on which the emissions originate.
Authority for Requirement: 567 IAC 23.3(2)"c"
Compliance Plan:
The owner/operator of this equipment shall comply with the following applicable
requirements.
This point is in compliance with all applicable requirements and shall continue to comply
with all such requirements. For those applicable requirements which will become
effective during the permit term, this source will comply with such requirements in a
timely manner.
Periodic Monitoring Requirements:
The owner/operator of this equipment shall comply with the following periodic
monitoring requirements.
Agency Approved Operation & Maintenance Plan Required? Yes ~ No Kl
Facility Maintained Operation & Maintenance Plan Required? Yes ~ No Kl
Authority for Requirement: 567 IAC 22.108(3)"b"
286
-------
Emission Point ID Number: 4.Z
Associated Equipment
Associated Emission Unit ID Numbers (if multiple units vent thru this EP): 4.Z
Applicable Requirements
(If more than one emission unit vents through this emission point subdivide the applicable requirements by emission
unit.)
Emission Unit vented through this Emission Point: 4.Z
Emission Unit Description: Hot Water Heater
Raw Material/Fuel: Propane (LPG) or Natural Gas
Rated Capacity: 0.50 MMBtu/hr.
Emission Limits (lb./hr. gr./dscf. lb./MMBtu. % opacity, etc.):
The emissions from this emission point shall not exceed the following specified levels.
Pollutant: Opacity
Emission Limit(s): 40 %
Authority for Requirement: 567 IAC 23.3(2)"d"
Pollutant: Particulate Matter (TSP)
Emission Limit(s): 15.3 lb./MMCF of LPG or Natural Gas
Authority for Requirement: Part 7a. of State of Iowa, ex rel., Iowa DNR vs. Vermeer
Manufacturing Company, 99AG23542
District Court, Marion County, Law No. LACV087889
Pollutant: Particulate Matter (TSP)
Emission Limits: 0.8 lb./MMBtu
Authority for Requirement: 567 IAC 23.3(2)"b"
Pollutant: Sulfur Dioxide (SO2)
Emission Limits: 500 ppmv
Authority for Requirement: 567 IAC 23.3(3)"e"
Pollutant: Nitrogen Oxides (NOx)
Emission Limit(s): See Facility-Wide Conditions
Authority for Requirement: Iowa DNR Construction Permit 98-A-003-S1
Pollutant: Volatile Organic Compounds (VOC)
Emission Limit: See Facility-Wide Conditions
Authority for Requirement: Iowa DNR Construction Permit 98-A-003-S1
287
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Operational Limits & Requirements:
The owner/operator of this equipment shall comply with the following operational limits
and requirements.
Process throughput:
A. The sulfur content of natural gas or LPG combusted by this source is not to
exceed 123 ppm by weight.
Reporting & Recordkeeping: See Facility-Wide Operational Limits
Authority for Requirement: Part 7b. of State of Iowa, ex rel., Iowa DNR vs. Vermeer
Manufacturing Company, 99AG23542
District Court, Marion County, Law No. LACV087889
Compliance Plan:
The owner/operator of this equipment shall comply with the following applicable
requirements.
This point is in compliance with all applicable requirements and shall continue to comply
with all such requirements. For those applicable requirements which will become
effective during the permit term, this source will comply with such requirements in a
timely manner.
Periodic Monitoring Requirements:
The owner/operator of this equipment shall comply with the following periodic
monitoring requirements.
Agency Approved Operation & Maintenance Plan Required? Yes ~ No IXI
Facility Maintained Operation & Maintenance Plan Required? Yes ~ No Kl
Authority for Requirement: 567 IAC 22.108(3)"b"
288
-------
Emission Point ID Number: 5.A
Associated Equipment
Associated Emission Unit ID Numbers (if multiple units vent thru this EP): 5 .A
Applicable Requirements
(If more than one emission unit vents through this emission point subdivide the applicable requirements by emission
unit.)
Emission Unit vented through this Emission Point: 5.A
Emission Unit Description: Non-Production Heating Unit
Raw Material/Fuel: Natural Gas
Rated Capacity: 3.58 MMBtu/hr.
Emission Limits (lb./hr. gr./dscf. lb./MMBtu. % opacity, etc.):
The emissions from this emission point shall not exceed the following specified levels.
Pollutant: Opacity
Emission Limit(s): 40 %
Authority for Requirement: 567 IAC 23.3(2)"d"
Pollutant: Particulate Matter (TSP)
Emission Limit(s): 15.3 lb./MMCF of LPG or Natural Gas
Authority for Requirement: Part 7a. of State of Iowa, ex rel., Iowa DNR vs. Vermeer
Manufacturing Company, 99AG23542
District Court, Marion County, Law No. LACV087889
Pollutant: Particulate Matter (TSP)
Emission Limits: 0.8 lb./MMBtu
Authority for Requirement: 567 IAC 23.3(2)"b"
Pollutant: Sulfur Dioxide (SO2)
Emission Limits: 500 ppmv
Authority for Requirement: 567 IAC 23.3(3)"e"
Pollutant: Nitrogen Oxides (NOx)
Emission Limit(s): See Facility-Wide Conditions
Authority for Requirement: Iowa DNR Construction Permit 98-A-003-S1
Pollutant: Volatile Organic Compounds (VOC)
Emission Limit: See Facility-Wide Conditions
Authority for Requirement: Iowa DNR Construction Permit 98-A-003-S1
289
-------
Operational Limits & Requirements:
The owner/operator of this equipment shall comply with the following operational limits
and requirements.
Process throughput:
A. The sulfur content of natural gas or LPG combusted by this source is not to
exceed 123 ppm by weight.
Reporting & Recordkeeping: See Facility-Wide Operational Limits
Authority for Requirement: Part 7b. of State of Iowa, ex rel., Iowa DNR vs. Vermeer
Manufacturing Company, 99AG23542
District Court, Marion County, Law No. LACV087889
Compliance Plan:
The owner/operator of this equipment shall comply with the following applicable
requirements.
This point is in compliance with all applicable requirements and shall continue to comply
with all such requirements. For those applicable requirements which will become
effective during the permit term, this source will comply with such requirements in a
timely manner.
Periodic Monitoring Requirements:
The owner/operator of this equipment shall comply with the following periodic
monitoring requirements.
Agency Approved Operation & Maintenance Plan Required? Yes ~ No IXI
Facility Maintained Operation & Maintenance Plan Required? Yes ~ No Kl
Authority for Requirement: 567 IAC 22.108(3)"b"
290
-------
Emission Point ID Number: 5.AA
Associated Equipment
Associated Emission Unit ID Numbers (if multiple units vent thru this EP): 5 .A
Applicable Requirements
(If more than one emission unit vents through this emission point subdivide the applicable requirements by emission
unit.)
Emission Unit vented through this Emission Point: 5.AA
Emission Unit Description: Non-Production Heating Unit
Raw Material/Fuel: Propane (LPG) or Natural Gas
Rated Capacity: 0.25 MMBtu/hr.
Emission Limits (lb./hr. gr./dscf. lb./MMBtu. % opacity, etc.):
The emissions from this emission point shall not exceed the following specified levels.
Pollutant: Opacity
Emission Limit(s): 40 %
Authority for Requirement: 567 IAC 23.3(2)"d"
Pollutant: Particulate Matter (TSP)
Emission Limit(s): 15.3 lb./MMCF of LPG or Natural Gas
Authority for Requirement: Part 7a. of State of Iowa, ex rel., Iowa DNR vs. Vermeer
Manufacturing Company, 99AG23542
District Court, Marion County, Law No. LACV087889
Pollutant: Particulate Matter (TSP)
Emission Limits: 0.8 lb./MMBtu
Authority for Requirement: 567 IAC 23.3(2)"b"
Pollutant: Sulfur Dioxide (SO2)
Emission Limits: 500 ppmv
Authority for Requirement: 567 IAC 23.3(3)"e"
Pollutant: Nitrogen Oxides (NOx)
Emission Limit(s): See Facility-Wide Conditions
Authority for Requirement: Iowa DNR Construction Permit 98-A-003-S1
Pollutant: Volatile Organic Compounds (VOC)
Emission Limit: See Facility-Wide Conditions
Authority for Requirement: Iowa DNR Construction Permit 98-A-003-S1
291
-------
Operational Limits & Requirements:
The owner/operator of this equipment shall comply with the following operational limits
and requirements.
Process throughput:
A. The sulfur content of natural gas or LPG combusted by this source is not to
exceed 123 ppm by weight.
Reporting & Recordkeeping: See Facility-Wide Operational Limits
Authority for Requirement: Part 7b. of State of Iowa, ex rel., Iowa DNR vs. Vermeer
Manufacturing Company, 99AG23542
District Court, Marion County, Law No. LACV087889
Compliance Plan:
The owner/operator of this equipment shall comply with the following applicable
requirements.
This point is in compliance with all applicable requirements and shall continue to comply
with all such requirements. For those applicable requirements which will become
effective during the permit term, this source will comply with such requirements in a
timely manner.
Periodic Monitoring Requirements:
The owner/operator of this equipment shall comply with the following periodic
monitoring requirements.
Agency Approved Operation & Maintenance Plan Required? Yes ~ No IXI
Facility Maintained Operation & Maintenance Plan Required? Yes ~ No Kl
Authority for Requirement: 567 IAC 22.108(3)"b"
292
-------
Emission Point ID Number: 5.B1
Associated Equipment
Associated Emission Unit ID Numbers (if multiple units vent thru this EP): 5 B1
Applicable Requirements
(If more than one emission unit vents through this emission point subdivide the applicable requirements by emission
unit.)
Emission Unit vented through this Emission Point: 5.B1
Emission Unit Description: Non-Production Heating Unit
Raw Material/Fuel: Natural Gas
Rated Capacity: 2.0 MMBtu/hr.
Emission Limits (lb./hr. gr./dscf. lb./MMBtu. % opacity, etc.):
The emissions from this emission point shall not exceed the following specified levels.
Pollutant: Opacity
Emission Limit(s): 40 %
Authority for Requirement: 567 IAC 23.3(2)"d"
Pollutant: Particulate Matter (TSP)
Emission Limit(s): 15.3 lb./MMCF of LPG or Natural Gas
Authority for Requirement: Part 7a. of State of Iowa, ex rel., Iowa DNR vs. Vermeer
Manufacturing Company, 99AG23542
District Court, Marion County, Law No. LACV087889
Pollutant: Particulate Matter (TSP)
Emission Limits: 0.8 lb./MMBtu
Authority for Requirement: 567 IAC 23.3(2)"b"
Pollutant: Sulfur Dioxide (SO2)
Emission Limits: 500 ppmv
Authority for Requirement: 567 IAC 23.3(3)"e"
Pollutant: Nitrogen Oxides (NOx)
Emission Limit(s): See Facility-Wide Conditions
Authority for Requirement: Iowa DNR Construction Permit 98-A-003-S1
Pollutant: Volatile Organic Compounds (VOC)
Emission Limit: See Facility-Wide Conditions
Authority for Requirement: Iowa DNR Construction Permit 98-A-003-S1
293
-------
Operational Limits & Requirements:
The owner/operator of this equipment shall comply with the following operational limits
and requirements.
Process throughput:
A. The sulfur content of natural gas or LPG combusted by this source is not to
exceed 123 ppm by weight.
Reporting & Recordkeeping: See Facility-Wide Operational Limits
Authority for Requirement: Part 7b. of State of Iowa, ex rel., Iowa DNR vs. Vermeer
Manufacturing Company, 99AG23542
District Court, Marion County, Law No. LACV087889
Compliance Plan:
The owner/operator of this equipment shall comply with the following applicable
requirements.
This point is in compliance with all applicable requirements and shall continue to comply
with all such requirements. For those applicable requirements which will become
effective during the permit term, this source will comply with such requirements in a
timely manner.
Periodic Monitoring Requirements:
The owner/operator of this equipment shall comply with the following periodic
monitoring requirements.
Agency Approved Operation & Maintenance Plan Required? Yes ~ No IXI
Facility Maintained Operation & Maintenance Plan Required? Yes ~ No Kl
Authority for Requirement: 567 IAC 22.108(3)"b"
294
-------
Emission Point ID Number: 5.B2
Associated Equipment
Associated Emission Unit ID Numbers (if multiple units vent thru this EP): 5 B2
Applicable Requirements
(If more than one emission unit vents through this emission point subdivide the applicable requirements by emission
unit.)
Emission Unit vented through this Emission Point: 5.B2
Emission Unit Description: Non-Production Heating Unit
Raw Material/Fuel: Natural Gas
Rated Capacity: 2.0 MMBtu/hr.
Emission Limits (lb./hr. gr./dscf. lb./MMBtu. % opacity, etc.):
The emissions from this emission point shall not exceed the following specified levels.
Pollutant: Opacity
Emission Limit(s): 40 %
Authority for Requirement: 567 IAC 23.3(2)"d"
Pollutant: Particulate Matter (TSP)
Emission Limit(s): 15.3 lb./MMCF of LPG or Natural Gas
Authority for Requirement: Part 7a. of State of Iowa, ex rel., Iowa DNR vs. Vermeer
Manufacturing Company, 99AG23542
District Court, Marion County, Law No. LACV087889
Pollutant: Particulate Matter (TSP)
Emission Limits: 0.8 lb./MMBtu
Authority for Requirement: 567 IAC 23.3(2)"b"
Pollutant: Sulfur Dioxide (SO2)
Emission Limits: 500 ppmv
Authority for Requirement: 567 IAC 23.3(3)"e"
Pollutant: Nitrogen Oxides (NOx)
Emission Limit(s): See Facility-Wide Conditions
Authority for Requirement: Iowa DNR Construction Permit 98-A-003-S1
Pollutant: Volatile Organic Compounds (VOC)
Emission Limit: See Facility-Wide Conditions
Authority for Requirement: Iowa DNR Construction Permit 98-A-003-S1
295
-------
Operational Limits & Requirements:
The owner/operator of this equipment shall comply with the following operational limits
and requirements.
Process throughput:
A. The sulfur content of natural gas or LPG combusted by this source is not to
exceed 123 ppm by weight.
Reporting & Recordkeeping: See Facility-Wide Operational Limits
Authority for Requirement: Part 7b. of State of Iowa, ex rel., Iowa DNR vs. Vermeer
Manufacturing Company, 99AG23542
District Court, Marion County, Law No. LACV087889
Compliance Plan:
The owner/operator of this equipment shall comply with the following applicable
requirements.
This point is in compliance with all applicable requirements and shall continue to comply
with all such requirements. For those applicable requirements which will become
effective during the permit term, this source will comply with such requirements in a
timely manner.
Periodic Monitoring Requirements:
The owner/operator of this equipment shall comply with the following periodic
monitoring requirements.
Agency Approved Operation & Maintenance Plan Required? Yes ~ No IXI
Facility Maintained Operation & Maintenance Plan Required? Yes ~ No Kl
Authority for Requirement: 567 IAC 22.108(3)"b"
296
-------
Emission Point ID Number: 5.BB
Associated Equipment
Associated Emission Unit ID Numbers (if multiple units vent thru this EP): 5 .BB1, 5 .BB2
Applicable Requirements
(If more than one emission unit vents through this emission point subdivide the applicable requirements by emission
unit.)
Emission Unit vented through this Emission Point: 5.BB1
Emission Unit Description: Paint Kitchen
Raw Material/Fuel: Paints, Primers, and Solvents
Rated Capacity: 3 Barrels
Emission Unit vented through this Emission Point: 5.BB2
Emission Unit Description: Paint Kitchen
Raw Material/Fuel: Paints, Primers, and Solvents
Rated Capacity: 3 Barrels
Emission Limits (lb./hr. gr./dscf. lb./MMBtu. % opacity, etc.):
The emissions from this emission point shall not exceed the following specified levels.
Pollutant: Volatile Organic Compounds (VOC)
Emission Limit: See Facility-Wide Conditions
Authority for Requirement: Iowa DNR Construction Permit 97-A-1028-S1
Compliance Plan:
The owner/operator of this equipment shall comply with the following applicable
requirements.
This point is in compliance with all applicable requirements and shall continue to comply
with all such requirements. For those applicable requirements which will become
effective during the permit term, this source will comply with such requirements in a
timely manner.
Additional Requirements:
This emission point shall conform to the following conditions.
The source is to be connected to the stack of the following detailed description.
Stack Height (feet): 43.5
Stack Diameter (inches): 20
Stack Exhaust Flow Rate (acfm): .... 7,000
Stack Temperature (°F): 70
Vertical, Unobstructed Discharge Required: Yes ^ No ~
Authority for Requirement: Iowa DNR Construction Permit 97-A-1028-S 1
297
-------
Periodic Monitoring Requirements:
The owner/operator of this equipment shall comply with the following periodic
monitoring requirements.
Agency Approved Operation & Maintenance Plan Required? Yes ~ No Kl
Facility Maintained Operation & Maintenance Plan Required? Yes ~ No Kl
Authority for Requirement: 567 IAC 22.108(3)"b"
298
-------
Emission Point ID Number: 5.CC
Associated Equipment
Associated Emission Unit ID Numbers (if multiple units vent thru this EP): 5.CC1, 5.CC2
Applicable Requirements
(If more than one emission unit vents through this emission point subdivide the applicable requirements by emission
unit.)
Emission Unit vented through this Emission Point: 5.CC1
Emission Unit Description: Paint Kitchen
Raw Material/Fuel: Paints, Primers, and Solvents
Rated Capacity: 3 Barrels
Emission Unit vented through this Emission Point: 5.CC2
Emission Unit Description: Paint Kitchen
Raw Material/Fuel: Paints, Primers, and Solvents
Rated Capacity: 3 Barrels
Emission Limits (lb./hr. gr./dscf. lb./MMBtu. % opacity, etc.):
The emissions from this emission point shall not exceed the following specified levels.
Pollutant: Volatile Organic Compounds (VOC)
Emission Limit: See Facility-Wide Conditions
Authority for Requirement: Iowa DNR Construction Permit 97-A-1029-S1
Compliance Plan:
The owner/operator of this equipment shall comply with the following applicable
requirements.
This point is in compliance with all applicable requirements and shall continue to comply
with all such requirements. For those applicable requirements which will become
effective during the permit term, this source will comply with such requirements in a
timely manner.
Additional Requirements:
This emission point shall conform to the following conditions.
The source is to be connected to the stack of the following detailed description.
Stack Height (feet): 43.5
Stack Diameter (inches): 20
Stack Exhaust Flow Rate (acfm): .... 7,000
Stack Temperature (°F): 70
Vertical, Unobstructed Discharge Required: Yes ^ No ~
Authority for Requirement: Iowa DNR Construction Permit 97-A-1029-S1
299
-------
Periodic Monitoring Requirements:
The owner/operator of this equipment shall comply with the following periodic
monitoring requirements.
Agency Approved Operation & Maintenance Plan Required? Yes ~ No Kl
Facility Maintained Operation & Maintenance Plan Required? Yes ~ No Kl
Authority for Requirement: 567 IAC 22.108(3)"b"
300
-------
Emission Point ID Number: 5.DD
Associated Equipment
Associated Emission Unit ID Numbers (if multiple units vent thru this EP): 5 .DD
Applicable Requirements
(If more than one emission unit vents through this emission point subdivide the applicable requirements by emission
unit.)
Emission Unit vented through this Emission Point: 5.DD
Emission Unit Description: Paint Kitchen
Raw Material/Fuel: Paints, Primers, and Solvents
Rated Capacity: 3 Barrels
Emission Limits (lb./hr. gr./dscf. lb./MMBtu. % opacity, etc.):
The emissions from this emission point shall not exceed the following specified levels.
Pollutant: Opacity
Emission Limit(s): 40 %
Authority for Requirement: 567 IAC 23.3(2)"d"
Pollutant: Volatile Organic Compounds (VOC)
Emission Limit: See Facility-Wide Conditions
Authority for Requirement: Iowa DNR Construction Permit 98-A-091 -S1
Compliance Plan:
The owner/operator of this equipment shall comply with the following applicable
requirements.
This point is in compliance with all applicable requirements and shall continue to comply
with all such requirements. For those applicable requirements which will become
effective during the permit term, this source will comply with such requirements in a
timely manner.
Additional Requirements:
This emission point shall conform to the following conditions.
The source is to be connected to the stack of the following detailed description.
Stack Height (feet): 43.5
Stack Diameter (inches): 15
Stack Exhaust Flow Rate (acfm): .... 3,500
Stack Temperature (°F): 70
Vertical, Unobstructed Discharge Required: Yes ^ No ~
Authority for Requirement: Iowa DNR Construction Permit 98-A-091 -S1
301
-------
Periodic Monitoring Requirements:
The owner/operator of this equipment shall comply with the following periodic
monitoring requirements.
Agency Approved Operation & Maintenance Plan Required? Yes ~ No Kl
Facility Maintained Operation & Maintenance Plan Required? Yes ~ No Kl
Authority for Requirement: 567 IAC 22.108(3)"b"
302
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Emission Point ID Number: 5.E
Associated Equipment
Associated Emission Unit ID Numbers (if multiple units vent thru this EP): 5 .E
Applicable Requirements
(If more than one emission unit vents through this emission point subdivide the applicable requirements by emission
unit.)
Emission Unit vented through this Emission Point: 5.E
Emission Unit Description: Hot Water Heater
Raw Material/Fuel: Natural Gas
Rated Capacity: 0.528 MMBtu/hr.
Emission Limits (lb./hr. gr./dscf. lb./MMBtu. % opacity, etc.):
The emissions from this emission point shall not exceed the following specified levels.
Pollutant: Opacity
Emission Limit(s): 40 %
Authority for Requirement: 567 IAC 23.3(2)"d"
Pollutant: Particulate Matter (TSP)
Emission Limit(s): 15.3 lb./MMCF of LPG or Natural Gas
Authority for Requirement: Part 7a. of State of Iowa, ex rel., Iowa DNR vs. Vermeer
Manufacturing Company, 99AG23542
District Court, Marion County, Law No. LACV087889
Pollutant: Particulate Matter (TSP)
Emission Limits: 0.8 lb./MMBtu
Authority for Requirement: 567 IAC 23.3(2)"b"
Pollutant: Sulfur Dioxide (SO2)
Emission Limits: 500 ppmv
Authority for Requirement: 567 IAC 23.3(3)"e"
Pollutant: Nitrogen Oxides (NOx)
Emission Limit(s): See Facility-Wide Conditions
Authority for Requirement: Iowa DNR Construction Permit 98-A-003-S1
Pollutant: Volatile Organic Compounds (VOC)
Emission Limit: See Facility-Wide Conditions
Authority for Requirement: Iowa DNR Construction Permit 98-A-003-S1
303
-------
Operational Limits & Requirements:
The owner/operator of this equipment shall comply with the following operational limits
and requirements.
Process throughput:
A. The sulfur content of natural gas or LPG combusted by this source is not to
exceed 123 ppm by weight.
Reporting & Recordkeeping: See Facility-Wide Operational Limits
Authority for Requirement: Part 7b. of State of Iowa, ex rel., Iowa DNR vs. Vermeer
Manufacturing Company, 99AG23542
District Court, Marion County, Law No. LACV087889
Compliance Plan:
The owner/operator of this equipment shall comply with the following applicable
requirements.
This point is in compliance with all applicable requirements and shall continue to comply
with all such requirements. For those applicable requirements which will become
effective during the permit term, this source will comply with such requirements in a
timely manner.
Periodic Monitoring Requirements:
The owner/operator of this equipment shall comply with the following periodic
monitoring requirements.
Agency Approved Operation & Maintenance Plan Required? Yes ~ No IXI
Facility Maintained Operation & Maintenance Plan Required? Yes ~ No Kl
Authority for Requirement: 567 IAC 22.108(3)"b"
304
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Emission Point ID Number: 5.EE
Associated Equipment
Associated Emission Unit ID Numbers (if multiple units vent thru this EP): 5 .EE
Applicable Requirements
(If more than one emission unit vents through this emission point subdivide the applicable requirements by emission
unit.)
Emission Unit vented through this Emission Point: 5.EE
Emission Unit Description: Non-Production Heating Unit
Raw Material/Fuel: Propane (LPG) or Natural Gas
Rated Capacity: 0.052 MMBtu/hr.
Emission Limits (lb./hr. gr./dscf. lb./MMBtu. % opacity, etc.):
The emissions from this emission point shall not exceed the following specified levels.
Pollutant: Opacity
Emission Limit(s): 40 %
Authority for Requirement: 567 IAC 23.3(2)"d"
Pollutant: Particulate Matter (TSP)
Emission Limit(s): 15.3 lb./MMCF of LPG or Natural Gas
Authority for Requirement: Part 7a. of State of Iowa, ex rel., Iowa DNR vs. Vermeer
Manufacturing Company, 99AG23542
District Court, Marion County, Law No. LACV087889
Pollutant: Particulate Matter (TSP)
Emission Limits: 0.8 lb./MMBtu
Authority for Requirement: 567 IAC 23.3(2)"b"
Pollutant: Sulfur Dioxide (SO2)
Emission Limits: 500 ppmv
Authority for Requirement: 567 IAC 23.3(3)"e"
Pollutant: Nitrogen Oxides (NOx)
Emission Limit(s): See Facility-Wide Conditions
Authority for Requirement: Iowa DNR Construction Permit 98-A-003-S1
Pollutant: Volatile Organic Compounds (VOC)
Emission Limit: See Facility-Wide Conditions
Authority for Requirement: Iowa DNR Construction Permit 98-A-003-S1
305
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Operational Limits & Requirements:
The owner/operator of this equipment shall comply with the following operational limits
and requirements.
Process throughput:
A. The sulfur content of natural gas or LPG combusted by this source is not to
exceed 123 ppm by weight.
Reporting & Recordkeeping: See Facility-Wide Operational Limits
Authority for Requirement: Part 7b. of State of Iowa, ex rel., Iowa DNR vs. Vermeer
Manufacturing Company, 99AG23542
District Court, Marion County, Law No. LACV087889
Compliance Plan:
The owner/operator of this equipment shall comply with the following applicable
requirements.
This point is in compliance with all applicable requirements and shall continue to comply
with all such requirements. For those applicable requirements which will become
effective during the permit term, this source will comply with such requirements in a
timely manner.
Periodic Monitoring Requirements:
The owner/operator of this equipment shall comply with the following periodic
monitoring requirements.
Agency Approved Operation & Maintenance Plan Required? Yes ~ No IXI
Facility Maintained Operation & Maintenance Plan Required? Yes ~ No Kl
Authority for Requirement: 567 IAC 22.108(3)"b"
306
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Emission Point ID Number: 5.FF
Associated Equipment
Associated Emission Unit ID Numbers (if multiple units vent thru this EP): 5 .FF
Applicable Requirements
(If more than one emission unit vents through this emission point subdivide the applicable requirements by emission
unit.)
Emission Unit vented through this Emission Point: 5.FF
Emission Unit Description: Non-Production Heating Unit
Raw Material/Fuel: Propane (LPG) or Natural Gas
Rated Capacity: 0.052 MMBtu/hr.
Emission Limits (lb./hr. gr./dscf. lb./MMBtu. % opacity, etc.):
The emissions from this emission point shall not exceed the following specified levels.
Pollutant: Opacity
Emission Limit(s): 40 %
Authority for Requirement: 567 IAC 23.3(2)"d"
Pollutant: Particulate Matter (TSP)
Emission Limit(s): 15.3 lb./MMCF of LPG or Natural Gas
Authority for Requirement: Part 7a. of State of Iowa, ex rel., Iowa DNR vs. Vermeer
Manufacturing Company, 99AG23542
District Court, Marion County, Law No. LACV087889
Pollutant: Particulate Matter (TSP)
Emission Limits: 0.8 lb./MMBtu
Authority for Requirement: 567 IAC 23.3(2)"b"
Pollutant: Sulfur Dioxide (SO2)
Emission Limits: 500 ppmv
Authority for Requirement: 567 IAC 23.3(3)"e"
Pollutant: Nitrogen Oxides (NOx)
Emission Limit(s): See Facility-Wide Conditions
Authority for Requirement: Iowa DNR Construction Permit 98-A-003-S1
Pollutant: Volatile Organic Compounds (VOC)
Emission Limit: See Facility-Wide Conditions
Authority for Requirement: Iowa DNR Construction Permit 98-A-003-S1
307
-------
Operational Limits & Requirements:
The owner/operator of this equipment shall comply with the following operational limits
and requirements.
Process throughput:
A. The sulfur content of natural gas or LPG combusted by this source is not to
exceed 123 ppm by weight.
Reporting & Recordkeeping: See Facility-Wide Operational Limits
Authority for Requirement: Part 7b. of State of Iowa, ex rel., Iowa DNR vs. Vermeer
Manufacturing Company, 99AG23542
District Court, Marion County, Law No. LACV087889
Compliance Plan:
The owner/operator of this equipment shall comply with the following applicable
requirements.
This point is in compliance with all applicable requirements and shall continue to comply
with all such requirements. For those applicable requirements which will become
effective during the permit term, this source will comply with such requirements in a
timely manner.
Periodic Monitoring Requirements:
The owner/operator of this equipment shall comply with the following periodic
monitoring requirements.
Agency Approved Operation & Maintenance Plan Required? Yes ~ No IXI
Facility Maintained Operation & Maintenance Plan Required? Yes ~ No Kl
Authority for Requirement: 567 IAC 22.108(3)"b"
308
-------
Emission Point ID Number: 5.FLAME1
Associated Equipment
Associated Emission Unit ID Numbers (if multiple units vent thru this EP): 5.FLAME1
Applicable Requirements
(If more than one emission unit vents through this emission point subdivide the applicable requirements by emission
unit.)
Emission Unit vented through this Emission Point: 5.FLAME1 (Fugitive)
Emission Unit Description: Single Cutting Head Oxyacetylene
Torch Unit
Raw Material/Fuel: Sheet Steel
Rated Capacity: 660 inches of metal cut/hr.
Emission Limits (lb./hr. gr./dscf. lb./MMBtu. % opacity, etc.):
The emissions from this emission point shall not exceed the following specified levels.
Pollutant: Fugitive Dust
Emission Limit: No person shall allow, cause or permit any materials to be handled,
transported or stored; or a building, its appurtenances or a construction haul road to
be used, constructed, altered , repaired or demolished, without taking reasonable
precautions to prevent a nuisance. All persons shall take reasonable precautions to
prevent the discharge of visible emissions of fugitive dusts beyond the lot line of the
property on which the emissions originate.
Authority for Requirement: 567 IAC 23.3(2)"c"
Compliance Plan:
The owner/operator of this equipment shall comply with the following applicable
requirements.
This point is in compliance with all applicable requirements and shall continue to comply
with all such requirements. For those applicable requirements which will become
effective during the permit term, this source will comply with such requirements in a
timely manner.
Periodic Monitoring Requirements:
The owner/operator of this equipment shall comply with the following periodic
monitoring requirements.
Agency Approved Operation & Maintenance Plan Required? Yes ~ No IXI
Facility Maintained Operation & Maintenance Plan Required? Yes ~ No Kl
Authority for Requirement: 567 IAC 22.108(3)"b"
309
-------
Emission Point ID Number: 5.G1
Associated Equipment
Associated Emission Unit ID Numbers (if multiple units vent thru this EP): 5.G
Emissions Control Equipment ID Number: 5.G
Emissions Control Equipment Description: Paper Filter
Applicable Requirements
(If more than one emission unit vents through this emission point subdivide the applicable requirements by emission
unit.)
Emission Unit vented through this Emission Point: 5.G
Emission Unit Description: Finish Paint Booth
Raw Material/Fuel: Paints, Primers, and Solvents
Rated Capacity: 15 gal./hr.
Emission Limits (lb./hr. gr./dscf. lb./MMBtu. % opacity, etc.):
The emissions from this emission point shall not exceed the following specified levels.
Pollutant: Opacity
Emission Limits: 40%
Indicator Opacity: (1)
(1) If visible emissions are observed other than startup, shutdown or malfunction, a stack
test may be required to demonstrate compliance with the particulate standard.
Authority for Requirement: Iowa DNR Construction Permit 97-A-1030-S2
567 IAC23.3(2)"d"
Pollutant: PMio
Emission Limit(s): 1.22 lb./hr.
Authority for Requirement: Iowa DNR Construction Permit 97-A-1030-S2
Pollutant: Particulate Matter (TSP)
Emission Limit(s): 0.01 gr./dscf
Authority for Requirement: Iowa DNR Construction Permit 97-A-1030-S2
567 IAC 23.4(13)
Pollutant: Volatile Organic Compounds (VOC)
Emission Limit: See Facility-Wide Conditions
Authority for Requirement: Iowa DNR Construction Permit 97-A-1030-S2
310
-------
Operational Limits & Requirements:
The owner/operator of this equipment shall comply with the following operational limits
and requirements.
Supplemental Environmental Project:
Equipment parameters:
The emission unit associated with this emission point will maintain a Graco, multi-
color, precision mix system with two gun flush boxes, solvent meters, and solvent
valves. The system will be supplied with a microprocessor which will control
solvent, paint, and catalyst flow to a mixing tube adjacent to the emission unit and
record the cumulative amount of the exact volume or weight of paint, solvent, or
catalyst utilized in the emission unit. The system will be interlocked with the two
Graco gun flush boxes, and the guns will be interlocked with the fans of the paint
spray booth.
Authority for Requirement: Paragraph 3c. of State of Iowa, ex rel., Iowa DNR vs.
Vermeer Manufacturing Company, 99AG23542
District Court, Marion County, Law No. LACV087889
Operational term: This SEP will be maintained for the life of this permit.
Authority for Requirement: Paragraph 3i. of State of Iowa, ex rel., Iowa DNR vs.
Vermeer Manufacturing Company, 99AG23542
District Court, Marion County, Law No. LACV087889
Reporting & Record keeping:
Vermeer shall submit to the DNR an annual performance report covering the required
period of use and maintenance of this SEP documenting the actual use and
maintenance of this SEP. The report shall evaluate the performance of the SEP and
document the extent of VOC emissions reductions. Vermeer shall conduct
cumulative mass balance calculations to determine the actual effect measured against
the 1997 baseline of 122.94 tons of VOC emitted per year. The reports shall be
submitted on or before March 1, for the preceding calendar year, commencing on
March 1, 1999. For additional reporting and recordkeeping see the Facility-Wide
Conditions
Authority for Requirement: Paragraph 3j. of State of Iowa, ex rel., Iowa DNR vs.
Vermeer Manufacturing Company, 99AG23542
District Court, Marion County, Law No. LACV087889
Iowa DNR Construction Permit 97-A-1030-S2
Compliance Plan:
The owner/operator of this equipment shall comply with the following applicable
requirements.
This point is in compliance with all applicable requirements and shall continue to comply
with all such requirements. For those applicable requirements which will become
effective during the permit term, this source will comply with such requirements in a
timely manner.
311
-------
Additional Requirements:
This emission point shall conform to the following conditions.
The source is to be connected to the stack of the following detailed description.
Stack Height (feet): 40.5
Stack Diameter (inches): 42.0
Stack Exhaust Flow Rate (acfm): .... 29,000
Stack Temperature (°F): 70
Vertical, Unobstructed Discharge Required: Yes ^ No ~
Authority for Requirement: Iowa DNR Construction Permit 97-A-1030-S2
Periodic Monitoring Requirements:
The owner/operator of this equipment shall comply with the following periodic
monitoring requirements.
Stack Testing:
Pollutant: Particulate Matter (TSP)
Stack Test to be Completed by (date): October 18, 2001
Test Method: Iowa Compliance Sampling Manual
Authority for Requirement: 567 IAC 22.108(3)
This stack test will represent the compliance testing for emission points 5.G1, 5G2, 6.Ml,
and 6.M2. In the event that a stack test of one of the other listed emission points is more
suitable it may be tested to fulfill the requirements. Suitability will be determined by the
Stack Test Observation Coordinator of the Air Quality Bureau Compliance Assistance
Section. The higher of the results for emissions from the compliance stack testing of
emission points 5.G1 and 5.G2 will be used to calculate actual emissions for the listed
sources until such time as more recent data becomes available. If the source test does not
demonstrate compliance this permit will be reopened to add a compliance plan and
operation and maintenance requirements.
The owner of this equipment or the owner's authorized agent shall provide written notice
to the Director, not less than 30 days before a required stack test or performance
evaluation of a continuous emission monitor. Results of the test shall be submitted in
writing to the Director in the form of a comprehensive report within 6 weeks of the
completion of the testing. 567 IAC 25.1(7)
312
-------
Periodic Monitoring Requirements (continued):
Opacity Monitoring:
The facility shall observe the opacity weekly during a period when the emission unit
associated with this emission point is at or near full capacity and record the reading
indicating if visible emissions were observed. The records shall be maintained for five
years. If weather conditions prevent the observer from conducting an opacity
observation, the observer shall note such conditions on the data observation sheet. At
least three attempts shall be made to retake opacity readings at approximately 2-hour
intervals throughout the day. If all observation attempts for a week have been
unsuccessful due to weather, an observation shall be made the next operating day where
weather permits.
Maintain a written record of the observation and any action resulting from the
observation.
Agency Approved Operation & Maintenance Plan Required? Yes ~ No Kl
Facility Maintained Operation & Maintenance Plan Required? Yes Kl NoQ
Facility operation and maintenance plans must be sufficient to yield reliable data from
the relevant time period that are representative of the source's compliance with the
applicable requirements.
Facility operation and maintenance plans are to be developed by the facility within six(6)
months of the issuance date of this permit and the data pertaining to the plan maintained
on site for at least 5 years. The plan and associated recordkeeping provides
documentation of this facility's implementation of its obligation to operate according to
good air pollution control practice.
Good air pollution control practice is achieved by adoption of quality control standards
in the operation and maintenance procedures for air pollution control that are
comparable to industry quality control standards for the production processes associated
with this emission point.
Authority for Requirement: 567 IAC 22.108(3)"b"
313
-------
Emission Point ID Number: 5.G2
Associated Equipment
Associated Emission Unit ID Numbers (if multiple units vent thru this EP): 5.G
Emissions Control Equipment ID Number: 5.G
Emissions Control Equipment Description: Paper Filter
Applicable Requirements
(If more than one emission unit vents through this emission point subdivide the applicable requirements by emission
unit.)
Emission Unit vented through this Emission Point: 5.G
Emission Unit Description: Finish Paint Booth
Raw Material/Fuel: Paints, Primers, and Solvents
Rated Capacity: 15 gal./hr.
Emission Limits (lb./hr. gr./dscf. lb./MMBtu. % opacity, etc.):
The emissions from this emission point shall not exceed the following specified levels.
Pollutant: Opacity
Emission Limits: 40%
Indicator Opacity: (1)
(1) If visible emissions are observed other than startup, shutdown or malfunction, a stack
test may be required to demonstrate compliance with the particulate standard.
Authority for Requirement: Iowa DNR Construction Permit 97-A-1031-S2
567 IAC23.3(2)"d"
Pollutant: PMio
Emission Limit(s): 1.22 lb./hr.
Authority for Requirement: Iowa DNR Construction Permit 97-A-1031-S2
Pollutant: Particulate Matter (TSP)
Emission Limit(s): 0.01 gr./dscf
Authority for Requirement: Iowa DNR Construction Permit 97-A-1031-S2
567 IAC 23.4(13)
Pollutant: Volatile Organic Compounds (VOC)
Emission Limit: See Facility-Wide Conditions
Authority for Requirement: Iowa DNR Construction Permit 97-A-1031-S2
314
-------
Operational Limits & Requirements:
The owner/operator of this equipment shall comply with the following operational limits
and requirements.
Supplemental Environmental Project:
Equipment parameters:
The emission unit associated with this emission point will maintain a Graco, multi-
color, precision mix system with two gun flush boxes, solvent meters, and solvent
valves. The system will be supplied with a microprocessor which will control
solvent, paint, and catalyst flow to a mixing tube adjacent to the emission unit and
record the cumulative amount of the exact volume or weight of paint, solvent, or
catalyst utilized in the emission unit. The system will be interlocked with the two
Graco gun flush boxes, and the guns will be interlocked with the fans of the paint
spray booth.
Authority for Requirement: Paragraph 3b. of State of Iowa, ex rel., Iowa DNR vs.
Vermeer Manufacturing Company, 99AG23542
District Court, Marion County, Law No. LACV087889
Operational term: This SEP will be maintained for the life of this permit.
Authority for Requirement: Paragraph 3i. of State of Iowa, ex rel., Iowa DNR vs.
Vermeer Manufacturing Company, 99AG23542
District Court, Marion County, Law No. LACV087889
Reporting & Record keeping:
Vermeer shall submit to the DNR an annual performance report covering the required
period of use and maintenance of this SEP documenting the actual use and
maintenance of this SEP. The report shall evaluate the performance of the SEP and
document the extent of VOC emissions reductions. Vermeer shall conduct
cumulative mass balance calculations to determine the actual effect measured against
the 1997 baseline of 122.94 tons of VOC emitted per year. The reports shall be
submitted on or before March 1, for the preceding calendar year, commencing on
March 1, 1999. For additional reporting and recordkeeping see the Facility-Wide
Conditions
Authority for Requirement: Paragraph 3j. of State of Iowa, ex rel., Iowa DNR vs.
Vermeer Manufacturing Company, 99AG23542
District Court, Marion County, Law No. LACV087889
Iowa DNR Construction Permit 97-A-1031-S2
Compliance Plan:
The owner/operator of this equipment shall comply with the following applicable
requirements.
This point is in compliance with all applicable requirements and shall continue to comply
with all such requirements. For those applicable requirements which will become
effective during the permit term, this source will comply with such requirements in a
timely manner.
315
-------
Additional Requirements:
This emission point shall conform to the following conditions.
The source is to be connected to the stack of the following detailed description.
Stack Height (feet): 40.5
Stack Diameter (inches): 42.0
Stack Exhaust Flow Rate (acfm): .... 29,000
Stack Temperature (°F): 70
Vertical, Unobstructed Discharge Required: Yes ^ No ~
Authority for Requirement: Iowa DNR Construction Permit 97-A-1031-S2
Periodic Monitoring Requirements:
The owner/operator of this equipment shall comply with the following periodic
monitoring requirements.
Stack Testing:
Pollutant: Particulate Matter (TSP)
Stack Test to be Completed by (date): October 18, 2001
Test Method: Iowa Compliance Sampling Manual
Authority for Requirement: 567 IAC 22.108(3)
This stack test will represent the compliance testing for emission points 5.G1, 5.G2,
6.Ml, and 6.M2. In the event that a stack test of one of the other listed emission points is
more suitable it may be tested to fulfill the requirements. Suitability will be determined
by the Stack Test Observation Coordinator of the Air Quality Bureau Compliance
Assistance Section. The higher of the results for emissions from the compliance stack
testing of emission points 5.G1 and 5.G2 will be used to calculate actual emissions for
the listed sources until such time as more recent data becomes available. If the source
test does not demonstrate compliance this permit will be reopened to add a compliance
plan and operation and maintenance requirements.
The owner of this equipment or the owner's authorized agent shall provide written notice
to the Director, not less than 30 days before a required stack test or performance
evaluation of a continuous emission monitor. Results of the test shall be submitted in
writing to the Director in the form of a comprehensive report within 6 weeks of the
completion of the testing. 567 IAC 25.1(7)
316
-------
Periodic Monitoring Requirements (continued):
Opacity Monitoring:
The facility shall observe the opacity weekly during a period when the emission unit
associated with this emission point is at or near full capacity and record the reading
indicating if visible emissions were observed. The records shall be maintained for five
years. If weather conditions prevent the observer from conducting an opacity
observation, the observer shall note such conditions on the data observation sheet. At
least three attempts shall be made to retake opacity readings at approximately 2-hour
intervals throughout the day. If all observation attempts for a week have been
unsuccessful due to weather, an observation shall be made the next operating day where
weather permits.
Maintain a written record of the observation and any action resulting from the
observation.
Agency Approved Operation & Maintenance Plan Required? Yes ~ No Kl
Facility Maintained Operation & Maintenance Plan Required? Yes Kl NoQ
Facility operation and maintenance plans must be sufficient to yield reliable data from
the relevant time period that are representative of the source's compliance with the
applicable requirements.
Facility operation and maintenance plans are to be developed by the facility within six(6)
months of the issuance date of this permit and the data pertaining to the plan maintained
on site for at least 5 years. The plan and associated recordkeeping provides
documentation of this facility's implementation of its obligation to operate according to
good air pollution control practice.
Good air pollution control practice is achieved by adoption of quality control standards
in the operation and maintenance procedures for air pollution control that are
comparable to industry quality control standards for the production processes associated
with this emission point.
Authority for Requirement: 567 IAC 22.108(3)"b"
317
-------
Emission Point ID Number: 5.GG
Associated Equipment
Associated Emission Unit ID Numbers (if multiple units vent thru this EP): 5.GG
Applicable Requirements
(If more than one emission unit vents through this emission point subdivide the applicable requirements by emission
unit.)
Emission Unit vented through this Emission Point: 5.GG
Emission Unit Description: Non-Production Heating Unit
Raw Material/Fuel: Propane (LPG) or Natural Gas
Rated Capacity: 0.052 MMBtu/hr.
Emission Limits (lb./hr. gr./dscf. lb./MMBtu. % opacity, etc.):
The emissions from this emission point shall not exceed the following specified levels.
Pollutant: Opacity
Emission Limit(s): 40 %
Authority for Requirement: 567 IAC 23.3(2)"d"
Pollutant: Particulate Matter (TSP)
Emission Limit(s): 15.3 lb./MMCF of LPG or Natural Gas
Authority for Requirement: Part 7a. of State of Iowa, ex rel., Iowa DNR vs. Vermeer
Manufacturing Company, 99AG23542
District Court, Marion County, Law No. LACV087889
Pollutant: Particulate Matter (TSP)
Emission Limits: 0.8 lb./MMBtu
Authority for Requirement: 567 IAC 23.3(2)"b"
Pollutant: Sulfur Dioxide (SO2)
Emission Limits: 500 ppmv
Authority for Requirement: 567 IAC 23.3(3)"e"
Pollutant: Nitrogen Oxides (NOx)
Emission Limit(s): See Facility-Wide Conditions
Authority for Requirement: Iowa DNR Construction Permit 98-A-003-S1
Pollutant: Volatile Organic Compounds (VOC)
Emission Limit: See Facility-Wide Conditions
Authority for Requirement: Iowa DNR Construction Permit 98-A-003-S1
318
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Operational Limits & Requirements:
The owner/operator of this equipment shall comply with the following operational limits
and requirements.
Process throughput:
A. The sulfur content of natural gas or LPG combusted by this source is not to
exceed 123 ppm by weight.
Reporting & Recordkeeping: See Facility-Wide Operational Limits
Authority for Requirement: Part 7b. of State of Iowa, ex rel., Iowa DNR vs. Vermeer
Manufacturing Company, 99AG23542
District Court, Marion County, Law No. LACV087889
Compliance Plan:
The owner/operator of this equipment shall comply with the following applicable
requirements.
This point is in compliance with all applicable requirements and shall continue to comply
with all such requirements. For those applicable requirements which will become
effective during the permit term, this source will comply with such requirements in a
timely manner.
Periodic Monitoring Requirements:
The owner/operator of this equipment shall comply with the following periodic
monitoring requirements.
Agency Approved Operation & Maintenance Plan Required? Yes ~ No IXI
Facility Maintained Operation & Maintenance Plan Required? Yes ~ No Kl
Authority for Requirement: 567 IAC 22.108(3)"b"
319
-------
Emission Point ID Number: 5.H
Associated Equipment
Associated Emission Unit ID Numbers (if multiple units vent thru this EP): 5 .H
Applicable Requirements
(If more than one emission unit vents through this emission point subdivide the applicable requirements by emission
unit.)
Emission Unit vented through this Emission Point: 5.H
Emission Unit Description: Non-Production Heating Unit
Raw Material/Fuel: Natural Gas
Rated Capacity: 6.33 MMBtu/hr.
Emission Limits (lb./hr. gr./dscf. lb./MMBtu. % opacity, etc.):
The emissions from this emission point shall not exceed the following specified levels.
Pollutant: Opacity
Emission Limit(s): 40 %
Authority for Requirement: 567 IAC 23.3(2)"d"
Pollutant: Particulate Matter (TSP)
Emission Limit(s): 15.3 lb./MMCF of LPG or Natural Gas
Authority for Requirement: Part 7a. of State of Iowa, ex rel., Iowa DNR vs. Vermeer
Manufacturing Company, 99AG23542
District Court, Marion County, Law No. LACV087889
Pollutant: Particulate Matter (TSP)
Emission Limits: 0.8 lb./MMBtu
Authority for Requirement: 567 IAC 23.3(2)"b"
Pollutant: Sulfur Dioxide (SO2)
Emission Limits: 500 ppmv
Authority for Requirement: 567 IAC 23.3(3)"e"
Pollutant: Nitrogen Oxides (NOx)
Emission Limit(s): See Facility-Wide Conditions
Authority for Requirement: Iowa DNR Construction Permit 98-A-003-S1
Pollutant: Volatile Organic Compounds (VOC)
Emission Limit: See Facility-Wide Conditions
Authority for Requirement: Iowa DNR Construction Permit 98-A-003-S1
320
-------
Operational Limits & Requirements:
The owner/operator of this equipment shall comply with the following operational limits
and requirements.
Process throughput:
A. The sulfur content of natural gas or LPG combusted by this source is not to
exceed 123 ppm by weight.
Reporting & Recordkeeping: See Facility-Wide Operational Limits
Authority for Requirement: Part 7b. of State of Iowa, ex rel., Iowa DNR vs. Vermeer
Manufacturing Company, 99AG23542
District Court, Marion County, Law No. LACV087889
Compliance Plan:
The owner/operator of this equipment shall comply with the following applicable
requirements.
This point is in compliance with all applicable requirements and shall continue to comply
with all such requirements. For those applicable requirements which will become
effective during the permit term, this source will comply with such requirements in a
timely manner.
Periodic Monitoring Requirements:
The owner/operator of this equipment shall comply with the following periodic
monitoring requirements.
Agency Approved Operation & Maintenance Plan Required? Yes ~ No IXI
Facility Maintained Operation & Maintenance Plan Required? Yes ~ No Kl
Authority for Requirement: 567 IAC 22.108(3)"b"
321
-------
Emission Point ID Number: 5.HH
Associated Equipment
Associated Emission Unit ID Numbers (if multiple units vent thru this EP): 5 .HH
Applicable Requirements
(If more than one emission unit vents through this emission point subdivide the applicable requirements by emission
unit.)
Emission Unit vented through this Emission Point: 5.HH
Emission Unit Description: Non-Production Heating Unit
Raw Material/Fuel: Propane (LPG) or Natural Gas
Rated Capacity: 0.052 MMBtu/hr.
Emission Limits (lb./hr. gr./dscf. lb./MMBtu. % opacity, etc.):
The emissions from this emission point shall not exceed the following specified levels.
Pollutant: Opacity
Emission Limit(s): 40 %
Authority for Requirement: 567 IAC 23.3(2)"d"
Pollutant: Particulate Matter (TSP)
Emission Limit(s): 15.3 lb./MMCF of LPG or Natural Gas
Authority for Requirement: Part 7a. of State of Iowa, ex rel., Iowa DNR vs. Vermeer
Manufacturing Company, 99AG23542
District Court, Marion County, Law No. LACV087889
Pollutant: Particulate Matter (TSP)
Emission Limits: 0.8 lb./MMBtu
Authority for Requirement: 567 IAC 23.3(2)"b"
Pollutant: Sulfur Dioxide (SO2)
Emission Limits: 500 ppmv
Authority for Requirement: 567 IAC 23.3(3)"e"
Pollutant: Nitrogen Oxides (NOx)
Emission Limit(s): See Facility-Wide Conditions
Authority for Requirement: Iowa DNR Construction Permit 98-A-003-S1
Pollutant: Volatile Organic Compounds (VOC)
Emission Limit: See Facility-Wide Conditions
Authority for Requirement: Iowa DNR Construction Permit 98-A-003-S1
322
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Operational Limits & Requirements:
The owner/operator of this equipment shall comply with the following operational limits
and requirements.
Process throughput:
A. The sulfur content of natural gas or LPG combusted by this source is not to
exceed 123 ppm by weight.
Reporting & Recordkeeping: See Facility-Wide Operational Limits
Authority for Requirement: Part 7b. of State of Iowa, ex rel., Iowa DNR vs. Vermeer
Manufacturing Company, 99AG23542
District Court, Marion County, Law No. LACV087889
Compliance Plan:
The owner/operator of this equipment shall comply with the following applicable
requirements.
This point is in compliance with all applicable requirements and shall continue to comply
with all such requirements. For those applicable requirements which will become
effective during the permit term, this source will comply with such requirements in a
timely manner.
Periodic Monitoring Requirements:
The owner/operator of this equipment shall comply with the following periodic
monitoring requirements.
Agency Approved Operation & Maintenance Plan Required? Yes ~ No IXI
Facility Maintained Operation & Maintenance Plan Required? Yes ~ No Kl
Authority for Requirement: 567 IAC 22.108(3)"b"
323
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Emission Point ID Number: 5.1
Associated Equipment
Associated Emission Unit ID Numbers (if multiple units vent thru this EP): 5.1
Applicable Requirements
(If more than one emission unit vents through this emission point subdivide the applicable requirements by emission
unit.)
Emission Unit vented through this Emission Point: 5.1
Emission Unit Description: Paint Oven
Raw Material/Fuel: Natural Gas
Rated Capacity: 1.5 MMBtu/hr.
Emission Limits (lb./hr. gr./dscf. lb./MMBtu. % opacity, etc.):
The emissions from this emission point shall not exceed the following specified levels.
Pollutant: Opacity
Emission Limits: 40%
Indicator Opacity: (1)
(1) If visible emissions are observed other than startup, shutdown or malfunction, a stack
test may be required to demonstrate compliance with the particulate standard.
Authority for Requirement: Iowa DNR Construction Permit 97-A-1032-S1
567 IAC23.3(2)"d"
Pollutant: Particulate Matter (TSP)
Emission Limit(s): 15.3 lb./MMCF of LPG or Natural Gas
Authority for Requirement: Part 7a. of State of Iowa, ex rel., Iowa DNR vs. Vermeer
Manufacturing Company, 99AG23542
District Court, Marion County, Law No. LACV087889
Pollutant: Particulate Matter (TSP)
Emission Limits: 0.1 gr./dscf
Authority for Requirement: Iowa DNR Construction Permit 97-A-1032-S1
567 I AC 23.3 (2) "a"
Pollutant: Sulfur Dioxide (SO2)
Emission Limits: 500 ppmv
Authority for Requirement: 567 IAC 23.3(3)"e"
Pollutant: Nitrogen Oxides (NOx)
Emission Limit(s): See Facility-Wide Conditions
Authority for Requirement: Iowa DNR Construction Permit 97-A-1032-S1
324
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Emission Limits (continued):
Pollutant: Volatile Organic Compounds (VOC)
Emission Limit: See Facility-Wide Conditions
Authority for Requirement: Iowa DNR Construction Permit 97-A-1032-S1
Operational Limits & Requirements:
The owner/operator of this equipment shall comply with the following operational limits
and requirements.
Process throughput:
A. This oven shall be fired by natural gas or propane only.
Reporting & Recordkeeping: See Facility-Wide Operational Limits
Authority for Requirement: Iowa DNR Construction Permit 97-A-1032-S1
Process throughput:
A. The sulfur content of natural gas or LPG combusted by this source is not to
exceed 123 ppm by weight.
Reporting & Recordkeeping: See Facility-Wide Operational Limits
Authority for Requirement: Part 7b. of State of Iowa, ex rel., Iowa DNR vs. Vermeer
Manufacturing Company, 99AG23542
District Court, Marion County, Law No. LACV087889
Compliance Plan:
The owner/operator of this equipment shall comply with the following applicable
requirements.
This point is in compliance with all applicable requirements and shall continue to comply
with all such requirements. For those applicable requirements which will become
effective during the permit term, this source will comply with such requirements in a
timely manner.
Additional Requirements:
This emission point shall conform to the following conditions.
The source is to be connected to the stack of the following detailed description.
Stack Height (feet): 31.5
Stack Diameter (inches): 14.0
Stack Exhaust Flow Rate (acfm): .... 143 5
Stack Temperature (°F): 102
Vertical, Unobstructed Discharge Required: Yes ^ No ~
Authority for Requirement: Iowa DNR Construction Permit 97-A-1032-S1
325
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Periodic Monitoring Requirements:
The owner/operator of this equipment shall comply with the following periodic
monitoring requirements.
Opacity Monitoring:
The facility shall observe the opacity weekly during a period when the emission unit
associated with this emission point is at or near full capacity and record the reading
indicating if visible emissions were observed. The records shall be maintained for five
years. If weather conditions prevent the observer from conducting an opacity
observation, the observer shall note such conditions on the data observation sheet. At
least three attempts shall be made to retake opacity readings at approximately 2-hour
intervals throughout the day. If all observation attempts for a week have been
unsuccessful due to weather, an observation shall be made the next operating day where
weather permits.
Maintain a written record of the observation and any action resulting from the
observation.
Agency Approved Operation & Maintenance Plan Required? Yes ~ No IEI
Facility Maintained Operation & Maintenance Plan Required? Yes ~ No Kl
Authority for Requirement: 567 IAC 22.108(3)"b"
326
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Emission Point ID Number: 5.II
Associated Equipment
Associated Emission Unit ID Numbers (if multiple units vent thru this EP): 5 .II
Applicable Requirements
(If more than one emission unit vents through this emission point subdivide the applicable requirements by emission
unit.)
Emission Unit vented through this Emission Point: 5.II
Emission Unit Description: Non-Production Heating Unit
Raw Material/Fuel: Propane (LPG) or Natural Gas
Rated Capacity: 0.052 MMBtu/hr.
Emission Limits (lb./hr. gr./dscf. lb./MMBtu. % opacity, etc.):
The emissions from this emission point shall not exceed the following specified levels.
Pollutant: Opacity
Emission Limit(s): 40 %
Authority for Requirement: 567 IAC 23.3(2)"d"
Pollutant: Particulate Matter (TSP)
Emission Limit(s): 15.3 lb./MMCF of LPG or Natural Gas
Authority for Requirement: Part 7a. of State of Iowa, ex rel., Iowa DNR vs. Vermeer
Manufacturing Company, 99AG23542
District Court, Marion County, Law No. LACV087889
Pollutant: Particulate Matter (TSP)
Emission Limits: 0.8 lb./MMBtu
Authority for Requirement: 567 IAC 23.3(2)"b"
Pollutant: Sulfur Dioxide (SO2)
Emission Limits: 500 ppmv
Authority for Requirement: 567 IAC 23.3(3)"e"
Pollutant: Nitrogen Oxides (NOx)
Emission Limit(s): See Facility-Wide Conditions
Authority for Requirement: Iowa DNR Construction Permit 98-A-003-S1
Pollutant: Volatile Organic Compounds (VOC)
Emission Limit: See Facility-Wide Conditions
Authority for Requirement: Iowa DNR Construction Permit 98-A-003-S1
327
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Operational Limits & Requirements:
The owner/operator of this equipment shall comply with the following operational limits
and requirements.
Process throughput:
A. The sulfur content of natural gas or LPG combusted by this source is not to
exceed 123 ppm by weight.
Reporting & Recordkeeping: See Facility-Wide Operational Limits
Authority for Requirement: Part 7b. of State of Iowa, ex rel., Iowa DNR vs. Vermeer
Manufacturing Company, 99AG23542
District Court, Marion County, Law No. LACV087889
Compliance Plan:
The owner/operator of this equipment shall comply with the following applicable
requirements.
This point is in compliance with all applicable requirements and shall continue to comply
with all such requirements. For those applicable requirements which will become
effective during the permit term, this source will comply with such requirements in a
timely manner.
Periodic Monitoring Requirements:
The owner/operator of this equipment shall comply with the following periodic
monitoring requirements.
Agency Approved Operation & Maintenance Plan Required? Yes ~ No IXI
Facility Maintained Operation & Maintenance Plan Required? Yes ~ No Kl
Authority for Requirement: 567 IAC 22.108(3)"b"
328
-------
Emission Point ID Number: 5. J
Associated Equipment
Associated Emission Unit ID Numbers (if multiple units vent thru this EP): 5 .J
Emissions Control Equipment ID Number: 5.J
Emissions Control Equipment Description: Paper Filter
Applicable Requirements
(If more than one emission unit vents through this emission point subdivide the applicable requirements by emission
unit.)
Emission Unit vented through this Emission Point: 5.J
Emission Unit Description: Parts Paint Booth
Raw Material/Fuel: Paints, Primers, and Solvents
Rated Capacity: 15 gal./hr.
Emission Limits (lb./hr. gr./dscf. lb./MMBtu. % opacity, etc.):
The emissions from this emission point shall not exceed the following specified levels.
Pollutant: Opacity
Emission Limits: 40%
Indicator Opacity: (1)
(1) If visible emissions are observed other than startup, shutdown or malfunction, a stack
test may be required to demonstrate compliance with the particulate standard.
Authority for Requirement: Iowa DNR Construction Permit 97-A-1033-S2
567 IAC23.3(2)"d"
Pollutant: Particulate Matter (TSP)
Emission Limit(s): 0.01 gr./dscf
Authority for Requirement: Iowa DNR Construction Permit 97-A-1033-S2
567 IAC 23.4(13)
Pollutant: Volatile Organic Compounds (VOC)
Emission Limit: See Facility-Wide Conditions
Authority for Requirement: Iowa DNR Construction Permit 97-A-1033-S2
329
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Operational Limits & Requirements:
The owner/operator of this equipment shall comply with the following operational limits
and requirements.
Supplemental Environmental Project:
Equipment parameters:
The emission unit associated with this emission point will maintain a Graco, multi-
color, precision mix system with two gun flush boxes, solvent meters, and solvent
valves. The system will be supplied with a microprocessor which will control
solvent, paint, and catalyst flow to a mixing tube adjacent to the emission unit and
record the cumulative amount of the exact volume or weight of paint, solvent, or
catalyst utilized in the emission unit. The system will be interlocked with the two
Graco gun flush boxes, and the guns will be interlocked with the fans of the paint
spray booth.
Authority for Requirement: Paragraph 3c. of State of Iowa, ex rel., Iowa DNR vs.
Vermeer Manufacturing Company, 99AG23542
District Court, Marion County, Law No. LACV087889
Operational term: This SEP will be maintained for the life of this permit.
Authority for Requirement: Paragraph 3i. of State of Iowa, ex rel., Iowa DNR vs.
Vermeer Manufacturing Company, 99AG23542
District Court, Marion County, Law No. LACV087889
Reporting & Record keeping:
Vermeer shall submit to the DNR an annual performance report covering the required
period of use and maintenance of this SEP documenting the actual use and
maintenance of this SEP. The report shall evaluate the performance of the SEP and
document the extent of VOC emissions reductions. Vermeer shall conduct
cumulative mass balance calculations to determine the actual effect measured against
the 1997 baseline of 122.94 tons of VOC emitted per year. The reports shall be
submitted on or before March 1, for the preceding calendar year, commencing on
March 1, 1999. For additional reporting and recordkeeping see the Facility-Wide
Conditions
Authority for Requirement: Paragraph 3j. of State of Iowa, ex rel., Iowa DNR vs.
Vermeer Manufacturing Company, 99AG23542
District Court, Marion County, Law No. LACV087889
Iowa DNR Construction Permit 97-A-1033-S2
Compliance Plan:
The owner/operator of this equipment shall comply with the following applicable
requirements.
This point is in compliance with all applicable requirements and shall continue to comply
with all such requirements. For those applicable requirements which will become
effective during the permit term, this source will comply with such requirements in a
timely manner.
330
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Additional Requirements:
This emission point shall conform to the following conditions.
The source is to be connected to the stack of the following detailed description.
Stack Height (feet): 43.8
Stack Diameter (inches): 42.0
Stack Exhaust Flow Rate (acfm): .... 20,000
Stack Temperature (°F): 70
Vertical, Unobstructed Discharge Required: Yes ^ No ~
Authority for Requirement: Iowa DNR Construction Permit 97-A-1033-S2
Periodic Monitoring Requirements:
The owner/operator of this equipment shall comply with the following periodic
monitoring requirements.
Opacity Monitoring:
The facility shall observe the opacity weekly during a period when the emission unit
associated with this emission point is at or near full capacity and record the reading
indicating if visible emissions were observed. The records shall be maintained for five
years. If weather conditions prevent the observer from conducting an opacity
observation, the observer shall note such conditions on the data observation sheet. At
least three attempts shall be made to retake opacity readings at approximately 2-hour
intervals throughout the day. If all observation attempts for a week have been
unsuccessful due to weather, an observation shall be made the next operating day where
weather permits.
Maintain a written record of the observation and any action resulting from the
observation.
Agency Approved Operation & Maintenance Plan Required? Yes ~ No IXI
Facility Maintained Operation & Maintenance Plan Required? Yes Kl NoQ
Facility operation and maintenance plans must be sufficient to yield reliable data from
the relevant time period that are representative of the source's compliance with the
applicable requirements.
Facility operation and maintenance plans are to be developed by the facility within six(6)
months of the issuance date of this permit and the data pertaining to the plan maintained
on site for at least 5 years. The plan and associated recordkeeping provides
documentation of this facility's implementation of its obligation to operate according to
good air pollution control practice.
Good air pollution control practice is achieved by adoption of quality control standards
in the operation and maintenance procedures for air pollution control that are
comparable to industry quality control standards for the production processes associated
with this emission point.
Authority for Requirement: 567 IAC 22.108(3)"b"
331
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Emission Point ID Number: 5.K
Associated Equipment
Associated Emission Unit ID Numbers (if multiple units vent thru this EP): 5 .K
Applicable Requirements
(If more than one emission unit vents through this emission point subdivide the applicable requirements by emission
unit.)
Emission Unit vented through this Emission Point: 5.K
Emission Unit Description: Non-Production Heating Unit
Raw Material/Fuel: Natural Gas
Rated Capacity: 2.35 MMBtu/hr.
Emission Limits (lb./hr. gr./dscf. lb./MMBtu. % opacity, etc.):
The emissions from this emission point shall not exceed the following specified levels.
Pollutant: Opacity
Emission Limit(s): 40 %
Authority for Requirement: 567 IAC 23.3(2)"d"
Pollutant: Particulate Matter (TSP)
Emission Limit(s): 15.3 lb./MMCF of LPG or Natural Gas
Authority for Requirement: Part 7a. of State of Iowa, ex rel., Iowa DNR vs. Vermeer
Manufacturing Company, 99AG23542
District Court, Marion County, Law No. LACV087889
Pollutant: Particulate Matter (TSP)
Emission Limits: 0.8 lb./MMBtu
Authority for Requirement: 567 IAC 23.3(2)"b"
Pollutant: Sulfur Dioxide (SO2)
Emission Limits: 500 ppmv
Authority for Requirement: 567 IAC 23.3(3)"e"
Pollutant: Nitrogen Oxides (NOx)
Emission Limit(s): See Facility-Wide Conditions
Authority for Requirement: Iowa DNR Construction Permit 98-A-003-S1
Pollutant: Volatile Organic Compounds (VOC)
Emission Limit: See Facility-Wide Conditions
Authority for Requirement: Iowa DNR Construction Permit 98-A-003-S1
332
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Operational Limits & Requirements:
The owner/operator of this equipment shall comply with the following operational limits
and requirements.
Process throughput:
A. The sulfur content of natural gas or LPG combusted by this source is not to
exceed 123 ppm by weight.
Reporting & Recordkeeping: See Facility-Wide Operational Limits
Authority for Requirement: Part 7b. of State of Iowa, ex rel., Iowa DNR vs. Vermeer
Manufacturing Company, 99AG23542
District Court, Marion County, Law No. LACV087889
Compliance Plan:
The owner/operator of this equipment shall comply with the following applicable
requirements.
This point is in compliance with all applicable requirements and shall continue to comply
with all such requirements. For those applicable requirements which will become
effective during the permit term, this source will comply with such requirements in a
timely manner.
Periodic Monitoring Requirements:
The owner/operator of this equipment shall comply with the following periodic
monitoring requirements.
Agency Approved Operation & Maintenance Plan Required? Yes ~ No IXI
Facility Maintained Operation & Maintenance Plan Required? Yes ~ No Kl
Authority for Requirement: 567 IAC 22.108(3)"b"
333
-------
Emission Point ID Number: 5.M
Associated Equipment
Associated Emission Unit ID Numbers (if multiple units vent thru this EP): 5 .M
Applicable Requirements
(If more than one emission unit vents through this emission point subdivide the applicable requirements by emission
unit.)
Emission Unit vented through this Emission Point: 5.M
Emission Unit Description: Non-Production Heating Unit
Raw Material/Fuel: Natural Gas
Rated Capacity: 0.76 MMBtu/hr.
Emission Limits (lb./hr. gr./dscf. lb./MMBtu. % opacity, etc.):
The emissions from this emission point shall not exceed the following specified levels.
Pollutant: Opacity
Emission Limit(s): 40 %
Authority for Requirement: 567 IAC 23.3(2)"d"
Pollutant: Particulate Matter (TSP)
Emission Limit(s): 15.3 lb./MMCF of LPG or Natural Gas
Authority for Requirement: Part 7a. of State of Iowa, ex rel., Iowa DNR vs. Vermeer
Manufacturing Company, 99AG23542
District Court, Marion County, Law No. LACV087889
Pollutant: Particulate Matter (TSP)
Emission Limits: 0.8 lb./MMBtu
Authority for Requirement: 567 IAC 23.3(2)"b"
Pollutant: Sulfur Dioxide (SO2)
Emission Limits: 500 ppmv
Authority for Requirement: 567 IAC 23.3(3)"e"
Pollutant: Nitrogen Oxides (NOx)
Emission Limit(s): See Facility-Wide Conditions
Authority for Requirement: Iowa DNR Construction Permit 98-A-003-S1
Pollutant: Volatile Organic Compounds (VOC)
Emission Limit: See Facility-Wide Conditions
Authority for Requirement: Iowa DNR Construction Permit 98-A-003-S1
334
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Operational Limits & Requirements:
The owner/operator of this equipment shall comply with the following operational limits
and requirements.
Process throughput:
A. The sulfur content of natural gas or LPG combusted by this source is not to
exceed 123 ppm by weight.
Reporting & Recordkeeping: See Facility-Wide Operational Limits
Authority for Requirement: Part 7b. of State of Iowa, ex rel., Iowa DNR vs. Vermeer
Manufacturing Company, 99AG23542
District Court, Marion County, Law No. LACV087889
Compliance Plan:
The owner/operator of this equipment shall comply with the following applicable
requirements.
This point is in compliance with all applicable requirements and shall continue to comply
with all such requirements. For those applicable requirements which will become
effective during the permit term, this source will comply with such requirements in a
timely manner.
Periodic Monitoring Requirements:
The owner/operator of this equipment shall comply with the following periodic
monitoring requirements.
Agency Approved Operation & Maintenance Plan Required? Yes ~ No IXI
Facility Maintained Operation & Maintenance Plan Required? Yes ~ No Kl
Authority for Requirement: 567 IAC 22.108(3)"b"
335
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Emission Point ID Number: 5.N
Associated Equipment
Associated Emission Unit ID Numbers (if multiple units vent thru this EP): 5 .N
Applicable Requirements
(If more than one emission unit vents through this emission point subdivide the applicable requirements by emission
unit.)
Emission Unit vented through this Emission Point: 5.N
Emission Unit Description: Production Engine Testing Unit
Raw Material/Fuel: #2 Diesel Fuel and Gasoline
Rated Capacity: 51.7 gal./hr.
Emission Limits (lb./hr. gr./dscf. lb./MMBtu. % opacity, etc.):
The emissions from this emission point shall not exceed the following specified levels.
Pollutant: Opacity
Emission Limit(s): 40 %
Authority for Requirement: 567 IAC 23.3(2)"d"
Pollutant:
Emission Limits:
Authority for Requirement:
Particulate Matter (TSP)
0.1 gr./dscf
567 IAC 23.3(2)"a"
Pollutant: Sulfur Dioxide (SO2)
Emission Limits: 2.5 lb./MMBtu
Authority for Requirement: 567 IAC 23.3(3)"b"
Pollutant: Nitrogen Oxides (NOx)
Emission Limit(s): See Facility-Wide Conditions
Authority for Requirement: Iowa DNR Construction Permit 97-A-299-S2
Pollutant: Volatile Organic Compounds (VOC)
Emission Limit: See Facility-Wide Conditions
Authority for Requirement: Iowa DNR Construction Permit 97-A-299-S2
336
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Operational Limits & Requirements:
The owner/operator of this equipment shall comply with the following operational limits
and requirements.
Process Throughput:
A. The sulfur content of any diesel fuel used in this source shall not exceed 0.4% by
weight.
Reporting & Recordkeeping: See Facility-Wide Emission and Operational Limits
Authority for Requirement: Iowa DNR Construction Permit 97-A-299-S2
Compliance Plan:
The owner/operator of this equipment shall comply with the following applicable
requirements.
This point is in compliance with all applicable requirements and shall continue to comply
with all such requirements. For those applicable requirements which will become
effective during the permit term, this source will comply with such requirements in a
timely manner.
Periodic Monitoring Requirements:
The owner/operator of this equipment shall comply with the following periodic
monitoring requirements.
Agency Approved Operation & Maintenance Plan Required? Yes ~ No Kl
Facility Maintained Operation & Maintenance Plan Required? Yes ~ No Kl
Authority for Requirement: 567 IAC 22.108(3)"b"
337
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Emission Point ID Number: 5.PLASMA1
Associated Equipment
Associated Emission Unit ID Numbers (if multiple units vent thru this EP): 5 .PLASMA1
Applicable Requirements
(If more than one emission unit vents through this emission point subdivide the applicable requirements by emission
unit.)
Emission Unit vented through this Emission Point: 5.PLASMA1 (Fugitive)
Emission Unit Description: Single Head Plasma Cutting
Machine
Raw Material/Fuel: Sheet Steel
Rated Capacity: 4,500 inches of metal cut/hr.
Emission Limits (lb./hr. gr./dscf. lb./MMBtu. % opacity, etc.):
The emissions from this emission point shall not exceed the following specified levels.
Pollutant: Fugitive Dust
Emission Limit: No person shall allow, cause or permit any materials to be handled,
transported or stored; or a building, its appurtenances or a construction haul road to
be used, constructed, altered , repaired or demolished, without taking reasonable
precautions to prevent a nuisance. All persons shall take reasonable precautions to
prevent the discharge of visible emissions of fugitive dusts beyond the lot line of the
property on which the emissions originate.
Authority for Requirement: 567 IAC 23.3(2)"c"
Compliance Plan:
The owner/operator of this equipment shall comply with the following applicable
requirements.
This point is in compliance with all applicable requirements and shall continue to comply
with all such requirements. For those applicable requirements which will become
effective during the permit term, this source will comply with such requirements in a
timely manner.
Periodic Monitoring Requirements:
The owner/operator of this equipment shall comply with the following periodic
monitoring requirements.
Agency Approved Operation & Maintenance Plan Required? Yes ~ No IXI
Facility Maintained Operation & Maintenance Plan Required? Yes ~ No Kl
Authority for Requirement: 567 IAC 22.108(3)"b"
338
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Emission Point ID Number: 5.PLASMA2
Associated Equipment
Associated Emission Unit ID Numbers (if multiple units vent thru this EP): 5 .PLASMA2
Applicable Requirements
(If more than one emission unit vents through this emission point subdivide the applicable requirements by emission
unit.)
Emission Unit vented through this Emission Point: 5.PLASMA2 (Fugitive)
Emission Unit Description: Single Head Plasma Cutting
Machine
Raw Material/Fuel: Sheet Steel
Rated Capacity: 4,500 inches of metal cut/hr.
Emission Limits (lb./hr. gr./dscf. lb./MMBtu. % opacity, etc.):
The emissions from this emission point shall not exceed the following specified levels.
Pollutant: Fugitive Dust
Emission Limit: No person shall allow, cause or permit any materials to be handled,
transported or stored; or a building, its appurtenances or a construction haul road to
be used, constructed, altered , repaired or demolished, without taking reasonable
precautions to prevent a nuisance. All persons shall take reasonable precautions to
prevent the discharge of visible emissions of fugitive dusts beyond the lot line of the
property on which the emissions originate.
Authority for Requirement: 567 IAC 23.3(2)"c"
Compliance Plan:
The owner/operator of this equipment shall comply with the following applicable
requirements.
This point is in compliance with all applicable requirements and shall continue to comply
with all such requirements. For those applicable requirements which will become
effective during the permit term, this source will comply with such requirements in a
timely manner.
Periodic Monitoring Requirements:
The owner/operator of this equipment shall comply with the following periodic
monitoring requirements.
Agency Approved Operation & Maintenance Plan Required? Yes ~ No IXI
Facility Maintained Operation & Maintenance Plan Required? Yes ~ No Kl
Authority for Requirement: 567 IAC 22.108(3)"b"
339
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Emission Point ID Number: 5.PLASMA3
Associated Equipment
Associated Emission Unit ID Numbers (if multiple units vent thru this EP): 5 .PLASMA3
Emissions Control Equipment ID Number: 5.PLASMA3
Emissions Control Equipment Description: Baghouse
Applicable Requirements
(If more than one emission unit vents through this emission point subdivide the applicable requirements by emission
unit.)
Emission Unit vented through this Emission Point: 5.PLASMA3 (Fugitive)
Emission Unit Description: Single Head Whitney Plasma Cutting
Machine
Raw Material/Fuel: Sheet Steel
Rated Capacity: 12,000 inches of metal cut/hr.
Emission Limits (lb./hr. gr./dscf. lb./MMBtu. % opacity, etc.):
The emissions from this emission point shall not exceed the following specified levels.
Pollutant: Fugitive Dust
Emission Limit: No person shall allow, cause or permit any materials to be handled,
transported or stored; or a building, its appurtenances or a construction haul road to
be used, constructed, altered , repaired or demolished, without taking reasonable
precautions to prevent a nuisance. All persons shall take reasonable precautions to
prevent the discharge of visible emissions of fugitive dusts beyond the lot line of the
property on which the emissions originate.
Authority for Requirement: 567 IAC 23.3(2)"c"
Compliance Plan:
The owner/operator of this equipment shall comply with the following applicable
requirements.
This point is in compliance with all applicable requirements and shall continue to comply
with all such requirements. For those applicable requirements which will become
effective during the permit term, this source will comply with such requirements in a
timely manner.
Periodic Monitoring Requirements:
The owner/operator of this equipment shall comply with the following periodic
monitoring requirements.
Agency Approved Operation & Maintenance Plan Required? Yes ~ No Kl
Facility Maintained Operation & Maintenance Plan Required? Yes ~ No Kl
Authority for Requirement: 567 IAC 22.108(3)"b"
340
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Emission Point ID Number: 5.PLASMA4
Associated Equipment
Associated Emission Unit ID Numbers (if multiple units vent thru this EP): 5 .PLASMA4
Emissions Control Equipment ID Number: 5.PLASMA4
Emissions Control Equipment Description: Baghouse
Applicable Requirements
(If more than one emission unit vents through this emission point subdivide the applicable requirements by emission
unit.)
Emission Unit vented through this Emission Point: 5.PLASMA4 (Fugitive)
Emission Unit Description: Single Head Whitney Plasma Cutting
Machine
Raw Material/Fuel: Sheet Steel
Rated Capacity: 12,000 inches of metal cut/hr.
Emission Limits (lb./hr. gr./dscf. lb./MMBtu. % opacity, etc.):
The emissions from this emission point shall not exceed the following specified levels.
Pollutant: Fugitive Dust
Emission Limit: No person shall allow, cause or permit any materials to be handled,
transported or stored; or a building, its appurtenances or a construction haul road to
be used, constructed, altered , repaired or demolished, without taking reasonable
precautions to prevent a nuisance. All persons shall take reasonable precautions to
prevent the discharge of visible emissions of fugitive dusts beyond the lot line of the
property on which the emissions originate.
Authority for Requirement: 567 IAC 23.3(2)"c"
Compliance Plan:
The owner/operator of this equipment shall comply with the following applicable
requirements.
This point is in compliance with all applicable requirements and shall continue to comply
with all such requirements. For those applicable requirements which will become
effective during the permit term, this source will comply with such requirements in a
timely manner.
Periodic Monitoring Requirements:
The owner/operator of this equipment shall comply with the following periodic
monitoring requirements.
Agency Approved Operation & Maintenance Plan Required? Yes ~ No Kl
Facility Maintained Operation & Maintenance Plan Required? Yes ~ No Kl
Authority for Requirement: 567 IAC 22.108(3)"b"
341
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Emission Point ID Number: 5.PRTWSH
Associated Equipment
Associated Emission Unit ID Numbers (if multiple units vent thru this EP): 5.PRTWSH
Applicable Requirements
(If more than one emission unit vents through this emission point subdivide the applicable requirements by emission
unit.)
Emission Unit vented through this Emission Point: 5.PRTWSH (Fugitive)
Emission Unit Description: Two (2) Safety Kleen Parts
Washers
Raw Material/Fuel: Stoddard Solvent
Rated Capacity: 55 Gallons Solvent per Washer
Emission Limits (lb./hr. gr./dscf. lb./MMBtu. % opacity, etc.):
The emissions from this emission point shall not exceed the following specified levels.
Pollutant: Volatile Organic Compounds (VOC)
Emission Limit: See Facility-Wide Conditions
Authority for Requirement: Iowa DNR Construction Permit 98-A-003-S1
Compliance Plan:
The owner/operator of this equipment shall comply with the following applicable
requirements.
This point is in compliance with all applicable requirements and shall continue to comply
with all such requirements. For those applicable requirements which will become
effective during the permit term, this source will comply with such requirements in a
timely manner.
Periodic Monitoring Requirements:
The owner/operator of this equipment shall comply with the following periodic
monitoring requirements.
Agency Approved Operation & Maintenance Plan Required? Yes ~ No Kl
Facility Maintained Operation & Maintenance Plan Required? Yes ~ No Kl
Authority for Requirement: 567 IAC 22.108(3)"b"
342
-------
Emission Point ID Number: 5.R
Associated Equipment
Associated Emission Unit ID Numbers (if multiple units vent thru this EP): 5 .R
Applicable Requirements
(If more than one emission unit vents through this emission point subdivide the applicable requirements by emission
unit.)
Emission Unit vented through this Emission Point: 5.R
Emission Unit Description: Hot Water Heater
Raw Material/Fuel: Natural Gas
Rated Capacity: 0.528 MMBtu/hr.
Emission Limits (lb./hr. gr./dscf. lb./MMBtu. % opacity, etc.):
The emissions from this emission point shall not exceed the following specified levels.
Pollutant: Opacity
Emission Limit(s): 40 %
Authority for Requirement: 567 IAC 23.3(2)"d"
Pollutant: Particulate Matter (TSP)
Emission Limit(s): 15.3 lb./MMCF of LPG or Natural Gas
Authority for Requirement: Part 7a. of State of Iowa, ex rel., Iowa DNR vs. Vermeer
Manufacturing Company, 99AG23542
District Court, Marion County, Law No. LACV087889
Pollutant: Particulate Matter (TSP)
Emission Limits: 0.8 lb./MMBtu
Authority for Requirement: 567 IAC 23.3(2)"b"
Pollutant: Sulfur Dioxide (SO2)
Emission Limits: 500 ppmv
Authority for Requirement: 567 IAC 23.3(3)"e"
Pollutant: Nitrogen Oxides (NOx)
Emission Limit(s): See Facility-Wide Conditions
Authority for Requirement: Iowa DNR Construction Permit 98-A-003-S1
Pollutant: Volatile Organic Compounds (VOC)
Emission Limit: See Facility-Wide Conditions
Authority for Requirement: Iowa DNR Construction Permit 98-A-003-S1
343
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Operational Limits & Requirements:
The owner/operator of this equipment shall comply with the following operational limits
and requirements.
Process throughput:
A. The sulfur content of natural gas or LPG combusted by this source is not to
exceed 123 ppm by weight.
Reporting & Recordkeeping: See Facility-Wide Operational Limits
Authority for Requirement: Part 7b. of State of Iowa, ex rel., Iowa DNR vs. Vermeer
Manufacturing Company, 99AG23542
District Court, Marion County, Law No. LACV087889
Compliance Plan:
The owner/operator of this equipment shall comply with the following applicable
requirements.
This point is in compliance with all applicable requirements and shall continue to comply
with all such requirements. For those applicable requirements which will become
effective during the permit term, this source will comply with such requirements in a
timely manner.
Periodic Monitoring Requirements:
The owner/operator of this equipment shall comply with the following periodic
monitoring requirements.
Agency Approved Operation & Maintenance Plan Required? Yes ~ No IXI
Facility Maintained Operation & Maintenance Plan Required? Yes ~ No Kl
Authority for Requirement: 567 IAC 22.108(3)"b"
344
-------
Emission Point ID Number: 5.T
Associated Equipment
Associated Emission Unit ID Numbers (if multiple units vent thru this EP): 5.T
Applicable Requirements
(If more than one emission unit vents through this emission point subdivide the applicable requirements by emission
unit.)
Emission Unit vented through this Emission Point: 5.T
Emission Unit Description: Production Engine Testing Unit
Raw Material/Fuel: #2 Diesel Fuel and Gasoline
Rated Capacity: 51.7 gal./hr.
Emission Limits (lb./hr. gr./dscf. lb./MMBtu. % opacity, etc.):
The emissions from this emission point shall not exceed the following specified levels.
Pollutant: Opacity
Emission Limit(s): 40 %
Authority for Requirement: 567 IAC 23.3(2)"d"
Pollutant:
Emission Limits:
Authority for Requirement:
Particulate Matter (TSP)
0.1 gr./dscf
567 IAC 23.3(2)"a"
Pollutant: Sulfur Dioxide (SO2)
Emission Limits: 2.5 lb./MMBtu
Authority for Requirement: 567 IAC 23.3(3)"b"
Pollutant: Nitrogen Oxides (NOx)
Emission Limit(s): See Facility-Wide Conditions
Authority for Requirement: Iowa DNR Construction Permit 97-A-299-S2
Pollutant: Volatile Organic Compounds (VOC)
Emission Limit: See Facility-Wide Conditions
Authority for Requirement: Iowa DNR Construction Permit 97-A-299-S2
345
-------
Operational Limits & Requirements:
The owner/operator of this equipment shall comply with the following operational limits
and requirements.
Process Throughput:
A. The sulfur content of any diesel fuel used in this source shall not exceed 0.4% by
weight.
Reporting & Recordkeeping: See Facility-Wide Emission and Operational Limits
Authority for Requirement: Iowa DNR Construction Permit 97-A-299-S2
Compliance Plan:
The owner/operator of this equipment shall comply with the following applicable
requirements.
This point is in compliance with all applicable requirements and shall continue to comply
with all such requirements. For those applicable requirements which will become
effective during the permit term, this source will comply with such requirements in a
timely manner.
Periodic Monitoring Requirements:
The owner/operator of this equipment shall comply with the following periodic
monitoring requirements.
Agency Approved Operation & Maintenance Plan Required? Yes ~ No Kl
Facility Maintained Operation & Maintenance Plan Required? Yes ~ No Kl
Authority for Requirement: 567 IAC 22.108(3)"b"
346
-------
Emission Point ID Number: 5.TORCH
Associated Equipment
Associated Emission Unit ID Numbers (if multiple units vent thru this EP): 5.TORCH
Applicable Requirements
(If more than one emission unit vents through this emission point subdivide the applicable requirements by emission
unit.)
Emission Unit vented through this Emission Point: 5.TORCH (Fugitive)
Emission Unit Description: Seven (7) Single Cutting Head
Oxyacetylene Torch Units
Raw Material/Fuel: Sheet Steel
Rated Capacity: 840 inches of metal cut/hr. per Head
Emission Limits (lb./hr. gr./dscf. lb./MMBtu. % opacity, etc.):
The emissions from this emission point shall not exceed the following specified levels.
Pollutant: Fugitive Dust
Emission Limit: No person shall allow, cause or permit any materials to be handled,
transported or stored; or a building, its appurtenances or a construction haul road to
be used, constructed, altered , repaired or demolished, without taking reasonable
precautions to prevent a nuisance. All persons shall take reasonable precautions to
prevent the discharge of visible emissions of fugitive dusts beyond the lot line of the
property on which the emissions originate.
Authority for Requirement: 567 IAC 23.3(2)"c"
Compliance Plan:
The owner/operator of this equipment shall comply with the following applicable
requirements.
This point is in compliance with all applicable requirements and shall continue to comply
with all such requirements. For those applicable requirements which will become
effective during the permit term, this source will comply with such requirements in a
timely manner.
Periodic Monitoring Requirements:
The owner/operator of this equipment shall comply with the following periodic
monitoring requirements.
Agency Approved Operation & Maintenance Plan Required? Yes ~ No IXI
Facility Maintained Operation & Maintenance Plan Required? Yes ~ No Kl
Authority for Requirement: 567 IAC 22.108(3)"b"
347
-------
Emission Point ID Number: 5.W
Associated Equipment
Associated Emission Unit ID Numbers (if multiple units vent thru this EP): 5. W
Applicable Requirements
(If more than one emission unit vents through this emission point subdivide the applicable requirements by emission
unit.)
Emission Unit vented through this Emission Point: 5.W
Emission Unit Description: Production Engine Testing Unit
Raw Material/Fuel: #2 Diesel Fuel and Gasoline
Rated Capacity: 51.7 gal./hr.
Emission Limits (lb./hr. gr./dscf. lb./MMBtu. % opacity, etc.):
The emissions from this emission point shall not exceed the following specified levels.
Pollutant: Opacity
Emission Limit(s): 40 %
Authority for Requirement: 567 IAC 23.3(2)"d"
Pollutant:
Emission Limits:
Authority for Requirement:
Particulate Matter (TSP)
0.1 gr./dscf
567 IAC 23.3(2)"a"
Pollutant: Sulfur Dioxide (SO2)
Emission Limits: 2.5 lb./MMBtu
Authority for Requirement: 567 IAC 23.3(3)"b"
Pollutant: Nitrogen Oxides (NOx)
Emission Limit(s): See Facility-Wide Conditions
Authority for Requirement: Iowa DNR Construction Permit 97-A-299-S2
Pollutant: Volatile Organic Compounds (VOC)
Emission Limit: See Facility-Wide Conditions
Authority for Requirement: Iowa DNR Construction Permit 97-A-299-S2
348
-------
Operational Limits & Requirements:
The owner/operator of this equipment shall comply with the following operational limits
and requirements.
Process Throughput:
A. The sulfur content of any diesel fuel used in this source shall not exceed 0.4% by
weight.
Reporting & Recordkeeping: See Facility-Wide Emission and Operational Limits
Authority for Requirement: Iowa DNR Construction Permit 97-A-299-S2
Compliance Plan:
The owner/operator of this equipment shall comply with the following applicable
requirements.
This point is in compliance with all applicable requirements and shall continue to comply
with all such requirements. For those applicable requirements which will become
effective during the permit term, this source will comply with such requirements in a
timely manner.
Periodic Monitoring Requirements:
The owner/operator of this equipment shall comply with the following periodic
monitoring requirements.
Agency Approved Operation & Maintenance Plan Required? Yes ~ No Kl
Facility Maintained Operation & Maintenance Plan Required? Yes ~ No Kl
Authority for Requirement: 567 IAC 22.108(3)"b"
349
-------
Emission Point ID Number: 5.WELDING
Associated Equipment
Associated Emission Unit ID Numbers (if multiple units vent thru this EP): 5 .WELDING
Applicable Requirements
(If more than one emission unit vents through this emission point subdivide the applicable requirements by emission
unit.)
Emission Unit vented through this Emission Point: 5.WELDING (Fugitive)
Emission Unit Description: 62 GMAW Units
Raw Material/Fuel: E70S Weld Wire
Rated Capacity: 19 lb. ofWire/hr. per Unit
Emission Limits (lb./hr. gr./dscf. lb./MMBtu. % opacity, etc.):
The emissions from this emission point shall not exceed the following specified levels.
Pollutant: Fugitive Dust
Emission Limit: No person shall allow, cause or permit any materials to be handled,
transported or stored; or a building, its appurtenances or a construction haul road to
be used, constructed, altered , repaired or demolished, without taking reasonable
precautions to prevent a nuisance. All persons shall take reasonable precautions to
prevent the discharge of visible emissions of fugitive dusts beyond the lot line of the
property on which the emissions originate.
Authority for Requirement: 567 IAC 23.3(2)"c"
Compliance Plan:
The owner/operator of this equipment shall comply with the following applicable
requirements.
This point is in compliance with all applicable requirements and shall continue to comply
with all such requirements. For those applicable requirements which will become
effective during the permit term, this source will comply with such requirements in a
timely manner.
Periodic Monitoring Requirements:
The owner/operator of this equipment shall comply with the following periodic
monitoring requirements.
Agency Approved Operation & Maintenance Plan Required? Yes ~ No Kl
Facility Maintained Operation & Maintenance Plan Required? Yes ~ No Kl
Authority for Requirement: 567 IAC 22.108(3)"b"
350
-------
Emission Point ID Number: 5.WELDPLS
Associated Equipment
Associated Emission Unit ID Numbers (if multiple units vent thru this EP): 5. WELDPLS
Applicable Requirements
(If more than one emission unit vents through this emission point subdivide the applicable requirements by emission
unit.)
Emission Unit vented through this Emission Point: 5.WELDPLS (Fugitive)
Emission Unit Description: 45 Pulse Current GMAW Units
Raw Material/Fuel: E70S Weld Wire
Rated Capacity: 19 lb. ofWire/hr. per Unit
Emission Limits (lb./hr. gr./dscf. lb./MMBtu. % opacity, etc.):
The emissions from this emission point shall not exceed the following specified levels.
Pollutant: Fugitive Dust
Emission Limit: No person shall allow, cause or permit any materials to be handled,
transported or stored; or a building, its appurtenances or a construction haul road to
be used, constructed, altered , repaired or demolished, without taking reasonable
precautions to prevent a nuisance. All persons shall take reasonable precautions to
prevent the discharge of visible emissions of fugitive dusts beyond the lot line of the
property on which the emissions originate.
Authority for Requirement: 567 IAC 23.3(2)"c"
Compliance Plan:
The owner/operator of this equipment shall comply with the following applicable
requirements.
This point is in compliance with all applicable requirements and shall continue to comply
with all such requirements. For those applicable requirements which will become
effective during the permit term, this source will comply with such requirements in a
timely manner.
Periodic Monitoring Requirements:
The owner/operator of this equipment shall comply with the following periodic
monitoring requirements.
Agency Approved Operation & Maintenance Plan Required? Yes ~ No Kl
Facility Maintained Operation & Maintenance Plan Required? Yes ~ No Kl
Authority for Requirement: 567 IAC 22.108(3)"b"
351
-------
Emission Point ID Number: 6.AB
Associated Equipment
Associated Emission Unit ID Numbers (if multiple units vent thru this EP): 6. AB
Applicable Requirements
(If more than one emission unit vents through this emission point subdivide the applicable requirements by emission
unit.)
Emission Unit vented through this Emission Point: 6.AB
Emission Unit Description: Non-Production Heating Unit
Raw Material/Fuel: Propane (LPG) or Natural Gas
Rated Capacity: 2.75 MMBtu/hr.
Emission Limits (lb./hr. gr./dscf. lb./MMBtu. % opacity, etc.):
The emissions from this emission point shall not exceed the following specified levels.
Pollutant: Opacity
Emission Limit(s): 40 %
Authority for Requirement: 567 IAC 23.3(2)"d"
Pollutant: Particulate Matter (TSP)
Emission Limit(s): 15.3 lb./MMCF of LPG or Natural Gas
Authority for Requirement: Part 7a. of State of Iowa, ex rel., Iowa DNR vs. Vermeer
Manufacturing Company, 99AG23542
District Court, Marion County, Law No. LACV087889
Pollutant: Particulate Matter (TSP)
Emission Limits: 0.8 lb./MMBtu
Authority for Requirement: 567 IAC 23.3(2)"b"
Pollutant: Sulfur Dioxide (SO2)
Emission Limits: 500 ppmv
Authority for Requirement: 567 IAC 23.3(3)"e"
Pollutant: Nitrogen Oxides (NOx)
Emission Limit(s): See Facility-Wide Conditions
Authority for Requirement: Iowa DNR Construction Permit 98-A-003-S1
Pollutant: Volatile Organic Compounds (VOC)
Emission Limit: See Facility-Wide Conditions
Authority for Requirement: Iowa DNR Construction Permit 98-A-003-S1
352
-------
Operational Limits & Requirements:
The owner/operator of this equipment shall comply with the following operational limits
and requirements.
Process throughput:
A. The sulfur content of natural gas or LPG combusted by this source is not to
exceed 123 ppm by weight.
Reporting & Recordkeeping: See Facility-Wide Operational Limits
Authority for Requirement: Part 7b. of State of Iowa, ex rel., Iowa DNR vs. Vermeer
Manufacturing Company, 99AG23542
District Court, Marion County, Law No. LACV087889
Compliance Plan:
The owner/operator of this equipment shall comply with the following applicable
requirements.
This point is in compliance with all applicable requirements and shall continue to comply
with all such requirements. For those applicable requirements which will become
effective during the permit term, this source will comply with such requirements in a
timely manner.
Periodic Monitoring Requirements:
The owner/operator of this equipment shall comply with the following periodic
monitoring requirements.
Agency Approved Operation & Maintenance Plan Required? Yes ~ No IXI
Facility Maintained Operation & Maintenance Plan Required? Yes ~ No Kl
Authority for Requirement: 567 IAC 22.108(3)"b"
353
-------
Emission Point ID Number: 6.AC
Associated Equipment
Associated Emission Unit ID Numbers (if multiple units vent thru this EP): 6. AC
Applicable Requirements
(If more than one emission unit vents through this emission point subdivide the applicable requirements by emission
unit.)
Emission Unit vented through this Emission Point: 6.AC
Emission Unit Description: Non-Production Heating Unit
Raw Material/Fuel: Propane (LPG) or Natural Gas
Rated Capacity: 2.75 MMBtu/hr.
Emission Limits (lb./hr. gr./dscf. lb./MMBtu. % opacity, etc.):
The emissions from this emission point shall not exceed the following specified levels.
Pollutant: Opacity
Emission Limit(s): 40 %
Authority for Requirement: 567 IAC 23.3(2)"d"
Pollutant: Particulate Matter (TSP)
Emission Limit(s): 15.3 lb./MMCF of LPG or Natural Gas
Authority for Requirement: Part 7a. of State of Iowa, ex rel., Iowa DNR vs. Vermeer
Manufacturing Company, 99AG23542
District Court, Marion County, Law No. LACV087889
Pollutant: Particulate Matter (TSP)
Emission Limits: 0.8 lb./MMBtu
Authority for Requirement: 567 IAC 23.3(2)"b"
Pollutant: Sulfur Dioxide (SO2)
Emission Limits: 500 ppmv
Authority for Requirement: 567 IAC 23.3(3)"e"
Pollutant: Nitrogen Oxides (NOx)
Emission Limit(s): See Facility-Wide Conditions
Authority for Requirement: Iowa DNR Construction Permit 98-A-003-S1
Pollutant: Volatile Organic Compounds (VOC)
Emission Limit: See Facility-Wide Conditions
Authority for Requirement: Iowa DNR Construction Permit 98-A-003-S1
354
-------
Operational Limits & Requirements:
The owner/operator of this equipment shall comply with the following operational limits
and requirements.
Process throughput:
A. The sulfur content of natural gas or LPG combusted by this source is not to
exceed 123 ppm by weight.
Reporting & Recordkeeping: See Facility-Wide Operational Limits
Authority for Requirement: Part 7b. of State of Iowa, ex rel., Iowa DNR vs. Vermeer
Manufacturing Company, 99AG23542
District Court, Marion County, Law No. LACV087889
Compliance Plan:
The owner/operator of this equipment shall comply with the following applicable
requirements.
This point is in compliance with all applicable requirements and shall continue to comply
with all such requirements. For those applicable requirements which will become
effective during the permit term, this source will comply with such requirements in a
timely manner.
Periodic Monitoring Requirements:
The owner/operator of this equipment shall comply with the following periodic
monitoring requirements.
Agency Approved Operation & Maintenance Plan Required? Yes ~ No IXI
Facility Maintained Operation & Maintenance Plan Required? Yes ~ No Kl
Authority for Requirement: 567 IAC 22.108(3)"b"
355
-------
Emission Point ID Number: 6.AD
Associated Equipment
Associated Emission Unit ID Numbers (if multiple units vent thru this EP): 6. AD
Applicable Requirements
(If more than one emission unit vents through this emission point subdivide the applicable requirements by emission
unit.)
Emission Unit vented through this Emission Point: 6.AD
Emission Unit Description: Non-Production Heating Unit
Raw Material/Fuel: Propane (LPG) or Natural Gas
Rated Capacity: 2.75 MMBtu/hr.
Emission Limits (lb./hr. gr./dscf. lb./MMBtu. % opacity, etc.):
The emissions from this emission point shall not exceed the following specified levels.
Pollutant: Opacity
Emission Limit(s): 40 %
Authority for Requirement: 567 IAC 23.3(2)"d"
Pollutant: Particulate Matter (TSP)
Emission Limit(s): 15.3 lb./MMCF of LPG or Natural Gas
Authority for Requirement: Part 7a. of State of Iowa, ex rel., Iowa DNR vs. Vermeer
Manufacturing Company, 99AG23542
District Court, Marion County, Law No. LACV087889
Pollutant: Particulate Matter (TSP)
Emission Limits: 0.8 lb./MMBtu
Authority for Requirement: 567 IAC 23.3(2)"b"
Pollutant: Sulfur Dioxide (SO2)
Emission Limits: 500 ppmv
Authority for Requirement: 567 IAC 23.3(3)"e"
Pollutant: Nitrogen Oxides (NOx)
Emission Limit(s): See Facility-Wide Conditions
Authority for Requirement: Iowa DNR Construction Permit 98-A-003-S1
Pollutant: Volatile Organic Compounds (VOC)
Emission Limit: See Facility-Wide Conditions
Authority for Requirement: Iowa DNR Construction Permit 98-A-003-S1
356
-------
Operational Limits & Requirements:
The owner/operator of this equipment shall comply with the following operational limits
and requirements.
Process throughput:
A. The sulfur content of natural gas or LPG combusted by this source is not to
exceed 123 ppm by weight.
Reporting & Recordkeeping: See Facility-Wide Operational Limits
Authority for Requirement: Part 7b. of State of Iowa, ex rel., Iowa DNR vs. Vermeer
Manufacturing Company, 99AG23542
District Court, Marion County, Law No. LACV087889
Compliance Plan:
The owner/operator of this equipment shall comply with the following applicable
requirements.
This point is in compliance with all applicable requirements and shall continue to comply
with all such requirements. For those applicable requirements which will become
effective during the permit term, this source will comply with such requirements in a
timely manner.
Periodic Monitoring Requirements:
The owner/operator of this equipment shall comply with the following periodic
monitoring requirements.
Agency Approved Operation & Maintenance Plan Required? Yes ~ No IXI
Facility Maintained Operation & Maintenance Plan Required? Yes ~ No Kl
Authority for Requirement: 567 IAC 22.108(3)"b"
357
-------
Emission Point ID Number: 6.AE
Associated Equipment
Associated Emission Unit ID Numbers (if multiple units vent thru this EP): 6. AE
Applicable Requirements
(If more than one emission unit vents through this emission point subdivide the applicable requirements by emission
unit.)
Emission Unit vented through this Emission Point: 6.AE
Emission Unit Description: Non-Production Heating Unit
Raw Material/Fuel: Propane (LPG) or Natural Gas
Rated Capacity: 2.75 MMBtu/hr.
Emission Limits (lb./hr. gr./dscf. lb./MMBtu. % opacity, etc.):
The emissions from this emission point shall not exceed the following specified levels.
Pollutant: Opacity
Emission Limit(s): 40 %
Authority for Requirement: 567 IAC 23.3(2)"d"
Pollutant: Particulate Matter (TSP)
Emission Limit(s): 15.3 lb./MMCF of LPG or Natural Gas
Authority for Requirement: Part 7a. of State of Iowa, ex rel., Iowa DNR vs. Vermeer
Manufacturing Company, 99AG23542
District Court, Marion County, Law No. LACV087889
Pollutant: Particulate Matter (TSP)
Emission Limits: 0.8 lb./MMBtu
Authority for Requirement: 567 IAC 23.3(2)"b"
Pollutant: Sulfur Dioxide (SO2)
Emission Limits: 500 ppmv
Authority for Requirement: 567 IAC 23.3(3)"e"
Pollutant: Nitrogen Oxides (NOx)
Emission Limit(s): See Facility-Wide Conditions
Authority for Requirement: Iowa DNR Construction Permit 98-A-003-S1
Pollutant: Volatile Organic Compounds (VOC)
Emission Limit: See Facility-Wide Conditions
Authority for Requirement: Iowa DNR Construction Permit 98-A-003-S1
358
-------
Operational Limits & Requirements:
The owner/operator of this equipment shall comply with the following operational limits
and requirements.
Process throughput:
A. The sulfur content of natural gas or LPG combusted by this source is not to
exceed 123 ppm by weight.
Reporting & Recordkeeping: See Facility-Wide Operational Limits
Authority for Requirement: Part 7b. of State of Iowa, ex rel., Iowa DNR vs. Vermeer
Manufacturing Company, 99AG23542
District Court, Marion County, Law No. LACV087889
Compliance Plan:
The owner/operator of this equipment shall comply with the following applicable
requirements.
This point is in compliance with all applicable requirements and shall continue to comply
with all such requirements. For those applicable requirements which will become
effective during the permit term, this source will comply with such requirements in a
timely manner.
Periodic Monitoring Requirements:
The owner/operator of this equipment shall comply with the following periodic
monitoring requirements.
Agency Approved Operation & Maintenance Plan Required? Yes ~ No IXI
Facility Maintained Operation & Maintenance Plan Required? Yes ~ No Kl
Authority for Requirement: 567 IAC 22.108(3)"b"
359
-------
Emission Point ID Number: 6.AF
Associated Equipment
Associated Emission Unit ID Numbers (if multiple units vent thru this EP): 6. AF
Applicable Requirements
(If more than one emission unit vents through this emission point subdivide the applicable requirements by emission
unit.)
Emission Unit vented through this Emission Point: 6.AF
Emission Unit Description: Non-Production Heating Unit
Raw Material/Fuel: Propane (LPG) or Natural Gas
Rated Capacity: 2.75 MMBtu/hr.
Emission Limits (lb./hr. gr./dscf. lb./MMBtu. % opacity, etc.):
The emissions from this emission point shall not exceed the following specified levels.
Pollutant: Opacity
Emission Limit(s): 40 %
Authority for Requirement: 567 IAC 23.3(2)"d"
Pollutant: Particulate Matter (TSP)
Emission Limit(s): 15.3 lb./MMCF of LPG or Natural Gas
Authority for Requirement: Part 7a. of State of Iowa, ex rel., Iowa DNR vs. Vermeer
Manufacturing Company, 99AG23542
District Court, Marion County, Law No. LACV087889
Pollutant: Particulate Matter (TSP)
Emission Limits: 0.8 lb./MMBtu
Authority for Requirement: 567 IAC 23.3(2)"b"
Pollutant: Sulfur Dioxide (SO2)
Emission Limits: 500 ppmv
Authority for Requirement: 567 IAC 23.3(3)"e"
Pollutant: Nitrogen Oxides (NOx)
Emission Limit(s): See Facility-Wide Conditions
Authority for Requirement: Iowa DNR Construction Permit 98-A-003-S1
Pollutant: Volatile Organic Compounds (VOC)
Emission Limit: See Facility-Wide Conditions
Authority for Requirement: Iowa DNR Construction Permit 98-A-003-S1
360
-------
Operational Limits & Requirements:
The owner/operator of this equipment shall comply with the following operational limits
and requirements.
Process throughput:
A. The sulfur content of natural gas or LPG combusted by this source is not to
exceed 123 ppm by weight.
Reporting & Recordkeeping: See Facility-Wide Operational Limits
Authority for Requirement: Part 7b. of State of Iowa, ex rel., Iowa DNR vs. Vermeer
Manufacturing Company, 99AG23542
District Court, Marion County, Law No. LACV087889
Compliance Plan:
The owner/operator of this equipment shall comply with the following applicable
requirements.
This point is in compliance with all applicable requirements and shall continue to comply
with all such requirements. For those applicable requirements which will become
effective during the permit term, this source will comply with such requirements in a
timely manner.
Periodic Monitoring Requirements:
The owner/operator of this equipment shall comply with the following periodic
monitoring requirements.
Agency Approved Operation & Maintenance Plan Required? Yes ~ No IXI
Facility Maintained Operation & Maintenance Plan Required? Yes ~ No Kl
Authority for Requirement: 567 IAC 22.108(3)"b"
361
-------
Emission Point ID Number: 6.AG
Associated Equipment
Associated Emission Unit ID Numbers (if multiple units vent thru this EP): 6. AG
Applicable Requirements
(If more than one emission unit vents through this emission point subdivide the applicable requirements by emission
unit.)
Emission Unit vented through this Emission Point: 6.AG
Emission Unit Description: Non-Production Heating Unit
Raw Material/Fuel: Propane (LPG) or Natural Gas
Rated Capacity: 2.75 MMBtu/hr.
Emission Limits (lb./hr. gr./dscf. lb./MMBtu. % opacity, etc.):
The emissions from this emission point shall not exceed the following specified levels.
Pollutant: Opacity
Emission Limit(s): 40 %
Authority for Requirement: 567 IAC 23.3(2)"d"
Pollutant: Particulate Matter (TSP)
Emission Limit(s): 15.3 lb./MMCF of LPG or Natural Gas
Authority for Requirement: Part 7a. of State of Iowa, ex rel., Iowa DNR vs. Vermeer
Manufacturing Company, 99AG23542
District Court, Marion County, Law No. LACV087889
Pollutant: Particulate Matter (TSP)
Emission Limits: 0.8 lb./MMBtu
Authority for Requirement: 567 IAC 23.3(2)"b"
Pollutant: Sulfur Dioxide (SO2)
Emission Limits: 500 ppmv
Authority for Requirement: 567 IAC 23.3(3)"e"
Pollutant: Nitrogen Oxides (NOx)
Emission Limit(s): See Facility-Wide Conditions
Authority for Requirement: Iowa DNR Construction Permit 98-A-003-S1
Pollutant: Volatile Organic Compounds (VOC)
Emission Limit: See Facility-Wide Conditions
Authority for Requirement: Iowa DNR Construction Permit 98-A-003-S1
362
-------
Operational Limits & Requirements:
The owner/operator of this equipment shall comply with the following operational limits
and requirements.
Process throughput:
A. The sulfur content of natural gas or LPG combusted by this source is not to
exceed 123 ppm by weight.
Reporting & Recordkeeping: See Facility-Wide Operational Limits
Authority for Requirement: Part 7b. of State of Iowa, ex rel., Iowa DNR vs. Vermeer
Manufacturing Company, 99AG23542
District Court, Marion County, Law No. LACV087889
Compliance Plan:
The owner/operator of this equipment shall comply with the following applicable
requirements.
This point is in compliance with all applicable requirements and shall continue to comply
with all such requirements. For those applicable requirements which will become
effective during the permit term, this source will comply with such requirements in a
timely manner.
Periodic Monitoring Requirements:
The owner/operator of this equipment shall comply with the following periodic
monitoring requirements.
Agency Approved Operation & Maintenance Plan Required? Yes ~ No IXI
Facility Maintained Operation & Maintenance Plan Required? Yes ~ No Kl
Authority for Requirement: 567 IAC 22.108(3)"b"
363
-------
Emission Point ID Number: 6.C
Associated Equipment
Associated Emission Unit ID Numbers (if multiple units vent thru this EP): 6.C
Applicable Requirements
(If more than one emission unit vents through this emission point subdivide the applicable requirements by emission
unit.)
Emission Unit vented through this Emission Point: 6.C
Emission Unit Description: Non-Production Heating Unit
Raw Material/Fuel: Natural Gas
Rated Capacity: 7.43 MMBtu/hr.
Emission Limits (lb./hr. gr./dscf. lb./MMBtu. % opacity, etc.):
The emissions from this emission point shall not exceed the following specified levels.
Pollutant: Opacity
Emission Limit(s): 40 %
Authority for Requirement: 567 IAC 23.3(2)"d"
Pollutant: Particulate Matter (TSP)
Emission Limit(s): 15.3 lb./MMCF of LPG or Natural Gas
Authority for Requirement: Part 7a. of State of Iowa, ex rel., Iowa DNR vs. Vermeer
Manufacturing Company, 99AG23542
District Court, Marion County, Law No. LACV087889
Pollutant: Particulate Matter (TSP)
Emission Limits: 0.8 lb./MMBtu
Authority for Requirement: 567 IAC 23.3(2)"b"
Pollutant: Sulfur Dioxide (SO2)
Emission Limits: 500 ppmv
Authority for Requirement: 567 IAC 23.3(3)"e"
Pollutant: Nitrogen Oxides (NOx)
Emission Limit(s): See Facility-Wide Conditions
Authority for Requirement: Iowa DNR Construction Permit 98-A-003-S1
Pollutant: Volatile Organic Compounds (VOC)
Emission Limit: See Facility-Wide Conditions
Authority for Requirement: Iowa DNR Construction Permit 98-A-003-S1
364
-------
Operational Limits & Requirements:
The owner/operator of this equipment shall comply with the following operational limits
and requirements.
Process throughput:
A. The sulfur content of natural gas or LPG combusted by this source is not to
exceed 123 ppm by weight.
Reporting & Recordkeeping: See Facility-Wide Operational Limits
Authority for Requirement: Part 7b. of State of Iowa, ex rel., Iowa DNR vs. Vermeer
Manufacturing Company, 99AG23542
District Court, Marion County, Law No. LACV087889
Compliance Plan:
The owner/operator of this equipment shall comply with the following applicable
requirements.
This point is in compliance with all applicable requirements and shall continue to comply
with all such requirements. For those applicable requirements which will become
effective during the permit term, this source will comply with such requirements in a
timely manner.
Periodic Monitoring Requirements:
The owner/operator of this equipment shall comply with the following periodic
monitoring requirements.
Agency Approved Operation & Maintenance Plan Required? Yes ~ No IXI
Facility Maintained Operation & Maintenance Plan Required? Yes ~ No Kl
Authority for Requirement: 567 IAC 22.108(3)"b"
365
-------
Emission Point ID Number: 6.D
Associated Equipment
Associated Emission Unit ID Numbers (if multiple units vent thru this EP): 6.D
Applicable Requirements
(If more than one emission unit vents through this emission point subdivide the applicable requirements by emission
unit.)
Emission Unit vented through this Emission Point: 6.D
Emission Unit Description: Production Engine Testing Unit
Raw Material/Fuel: #2 Diesel Fuel and Gasoline
Rated Capacity: 52.5 gal./hr.
Emission Limits (lb./hr. gr./dscf. lb./MMBtu. % opacity, etc.):
The emissions from this emission point shall not exceed the following specified levels.
Pollutant: Opacity
Emission Limits: 40%
Indicator Opacity: 25%(1)
(1) If visible emissions are observed that exceed the indicator opacity other than startup,
shutdown or malfunction, a stack test may be required to demonstrate compliance with
the particulate standard.
Authority for Requirement: Iowa DNR Construction Permit 97-A-299-S3
567 IAC 23.3(2)"d"
Pollutant: Particulate Matter (TSP)
Emission Limits: 0.1 gr./dscf
Authority for Requirement: Iowa DNR Construction Permit 97-A-299-S3
567 IAC 23.3(2)"a"
Pollutant: Sulfur Dioxide (SO2)
Emission Limits: 2.5 lb./MMBtu
Authority for Requirement: Iowa DNR Construction Permit 97-A-299-S3
567 IAC 23.3(3)"b"
Pollutant: Nitrogen Oxides (NOx)
Emission Limit(s): See Facility-Wide Conditions
Authority for Requirement: Iowa DNR Construction Permit 97-A-299-S3
Pollutant: Volatile Organic Compounds (VOC)
Emission Limit: See Facility-Wide Conditions
Authority for Requirement: Iowa DNR Construction Permit 97-A-299-S3
366
-------
Operational Limits & Requirements:
The owner/operator of this equipment shall comply with the following operational limits
and requirements.
Process Throughput:
A. The sulfur content of any diesel fuel used in this source shall not exceed 0.4% by
weight.
Reporting & Recordkeeping: See Facility-Wide Emission and Operational Limits
Authority for Requirement: Iowa DNR Construction Permit 97-A-299-S3
Compliance Plan:
The owner/operator of this equipment shall comply with the following applicable
requirements.
This point is in compliance with all applicable requirements and shall continue to comply
with all such requirements. For those applicable requirements which will become
effective during the permit term, this source will comply with such requirements in a
timely manner.
Additional Requirements:
This emission point shall conform to the following conditions.
The source is to be connected to the stack of the following detailed description.
Stack Height (feet): 30.5
Stack Diameter (inches): 12
Stack Exhaust Flow Rate (acfm): .... 5,980
Stack Temperature (°F): 759
Vertical, Unobstructed Discharge Required: Yes ^ No ~
Authority for Requirement: Iowa DNR Construction Permit 97-A-299-S3
Periodic Monitoring Requirements:
The owner/operator of this equipment shall comply with the following periodic
monitoring requirements.
Opacity Monitoring:
The facility shall observe the opacity weekly during a period when the emission unit
associated with this emission point is at or near full capacity and record the reading
indicating if visible emissions were observed. The records shall be maintained for five
years. If weather conditions prevent the observer from conducting an opacity
observation, the observer shall note such conditions on the data observation sheet. At
least three attempts shall be made to retake opacity readings at approximately 2-hour
intervals throughout the day. If all observation attempts for a week have been
unsuccessful due to weather, an observation shall be made the next operating day where
weather permits.
Maintain a written record of the observation and any action resulting from the
observation.
367
-------
Agency Approved Operation & Maintenance Plan Required? Yes ~ No Kl
Facility Maintained Operation & Maintenance Plan Required? Yes ~ No Kl
Authority for Requirement: 567 IAC 22.108(3)"b"
368
-------
Emission Point ID Number: 6.DD
Associated Equipment
Associated Emission Unit ID Numbers (if multiple units vent thru this EP): 6.DD
Applicable Requirements
(If more than one emission unit vents through this emission point subdivide the applicable requirements by emission
unit.)
Emission Unit vented through this Emission Point: 6.DD
Emission Unit Description: Non-Production Heating Unit
Raw Material/Fuel: Natural Gas
Rated Capacity: 0.05 MMBtu/hr.
Emission Limits (lb./hr. gr./dscf. lb./MMBtu. % opacity, etc.):
The emissions from this emission point shall not exceed the following specified levels.
Pollutant: Opacity
Emission Limit(s): 40 %
Authority for Requirement: 567 IAC 23.3(2)"d"
Pollutant: Particulate Matter (TSP)
Emission Limit(s): 15.3 lb./MMCF of LPG or Natural Gas
Authority for Requirement: Part 7a. of State of Iowa, ex rel., Iowa DNR vs. Vermeer
Manufacturing Company, 99AG23542
District Court, Marion County, Law No. LACV087889
Pollutant: Particulate Matter (TSP)
Emission Limits: 0.8 lb./MMBtu
Authority for Requirement: 567 IAC 23.3(2)"b"
Pollutant: Sulfur Dioxide (SO2)
Emission Limits: 500 ppmv
Authority for Requirement: 567 IAC 23.3(3)"e"
Pollutant: Nitrogen Oxides (NOx)
Emission Limit(s): See Facility-Wide Conditions
Authority for Requirement: Iowa DNR Construction Permit 98-A-003-S1
Pollutant: Volatile Organic Compounds (VOC)
Emission Limit: See Facility-Wide Conditions
Authority for Requirement: Iowa DNR Construction Permit 98-A-003-S1
369
-------
Operational Limits & Requirements:
The owner/operator of this equipment shall comply with the following operational limits
and requirements.
Process throughput:
A. The sulfur content of natural gas or LPG combusted by this source is not to
exceed 123 ppm by weight.
Reporting & Recordkeeping: See Facility-Wide Operational Limits
Authority for Requirement: Part 7b. of State of Iowa, ex rel., Iowa DNR vs. Vermeer
Manufacturing Company, 99AG23542
District Court, Marion County, Law No. LACV087889
Compliance Plan:
The owner/operator of this equipment shall comply with the following applicable
requirements.
This point is in compliance with all applicable requirements and shall continue to comply
with all such requirements. For those applicable requirements which will become
effective during the permit term, this source will comply with such requirements in a
timely manner.
Periodic Monitoring Requirements:
The owner/operator of this equipment shall comply with the following periodic
monitoring requirements.
Agency Approved Operation & Maintenance Plan Required? Yes ~ No IXI
Facility Maintained Operation & Maintenance Plan Required? Yes ~ No Kl
Authority for Requirement: 567 IAC 22.108(3)"b"
370
-------
Emission Point ID Number: 6.F
Associated Equipment
Associated Emission Unit ID Numbers (if multiple units vent thru this EP): 6.F
Applicable Requirements
(If more than one emission unit vents through this emission point subdivide the applicable requirements by emission
unit.)
Emission Unit vented through this Emission Point: 6.F
Emission Unit Description: Paint Oven
Raw Material/Fuel: Natural Gas
Rated Capacity: 0.9 MMBtu/hr.
Emission Limits (lb./hr. gr./dscf. lb./MMBtu. % opacity, etc.):
The emissions from this emission point shall not exceed the following specified levels.
Pollutant: Opacity
Emission Limits: 40%
Indicator Opacity: (1)
(1) If visible emissions are observed other than startup, shutdown or malfunction, a stack
test may be required to demonstrate compliance with the particulate standard.
Authority for Requirement: Iowa DNR Construction Permit 98-A-1217-S3
567 IAC23.3(2)"d"
Pollutant: Particulate Matter (TSP)
Emission Limit(s): 15.3 lb./MMCF of LPG or Natural Gas
Authority for Requirement: Part 7a. of State of Iowa, ex rel., Iowa DNR vs. Vermeer
Manufacturing Company, 99AG23542
District Court, Marion County, Law No. LACV087889
Pollutant: Particulate Matter (TSP)
Emission Limits: 0.1 gr./dscf
Authority for Requirement: Iowa DNR Construction Permit 98-A-1217-S3
567 I AC 23.3 (2) "a"
Pollutant: Sulfur Dioxide (SO2)
Emission Limits: 500 ppmv
Authority for Requirement: 567 IAC 23.3(3)"e"
Pollutant: Nitrogen Oxides (NOx)
Emission Limit(s): See Facility-Wide Conditions
Authority for Requirement: Iowa DNR Construction Permit 98-A-1217-S3
371
-------
Emission Limits (continued):
Pollutant: Volatile Organic Compounds (VOC)
Emission Limit: See Facility-Wide Conditions
Authority for Requirement: Iowa DNR Construction Permit 98-A-1217-S3
Operational Limits & Requirements:
The owner/operator of this equipment shall comply with the following operational limits
and requirements.
Process throughput:
A. This oven shall be fired by natural gas or propane only.
Reporting & Recordkeeping: See Facility-Wide Operational Limits
Authority for Requirement: Iowa DNR Construction Permit 98-A-1217-S3
Process throughput:
A. The sulfur content of natural gas or LPG combusted by this source is not to
exceed 123 ppm by weight.
Reporting & Recordkeeping: See Facility-Wide Operational Limits
Authority for Requirement: Part 7b. of State of Iowa, ex rel., Iowa DNR vs. Vermeer
Manufacturing Company, 99AG23542
District Court, Marion County, Law No. LACV087889
Compliance Plan:
The owner/operator of this equipment shall comply with the following applicable
requirements.
This point is in compliance with all applicable requirements and shall continue to comply
with all such requirements. For those applicable requirements which will become
effective during the permit term, this source will comply with such requirements in a
timely manner.
Additional Requirements:
This emission point shall conform to the following conditions.
The source is to be connected to the stack of the following detailed description.
Stack Height (feet): 28.6
Stack Diameter (inches): 11.0
Stack Exhaust Flow Rate (acfm): .... 2,225
Stack Temperature (°F): 325
Vertical, Unobstructed Discharge Required: Yes ^ No ~
Authority for Requirement: Iowa DNR Construction Permit 98-A-1217-S3
372
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Periodic Monitoring Requirements:
The owner/operator of this equipment shall comply with the following periodic
monitoring requirements.
Opacity Monitoring:
The facility shall observe the opacity weekly during a period when the emission unit
associated with this emission point is at or near full capacity and record the reading
indicating if visible emissions were observed. The records shall be maintained for five
years. If weather conditions prevent the observer from conducting an opacity
observation, the observer shall note such conditions on the data observation sheet. At
least three attempts shall be made to retake opacity readings at approximately 2-hour
intervals throughout the day. If all observation attempts for a week have been
unsuccessful due to weather, an observation shall be made the next operating day where
weather permits.
Maintain a written record of the observation and any action resulting from the
observation.
Agency Approved Operation & Maintenance Plan Required? Yes ~ No IEI
Facility Maintained Operation & Maintenance Plan Required? Yes ~ No Kl
Authority for Requirement: 567 IAC 22.108(3)"b"
373
-------
Emission Point ID Number: 6.FF
Associated Equipment
Associated Emission Unit ID Numbers (if multiple units vent thru this EP): 6.FF
Applicable Requirements
(If more than one emission unit vents through this emission point subdivide the applicable requirements by emission
unit.)
Emission Units vented through this Emission Point: 6.FF
Emission Unit Description: Paint Kitchen
Raw Material/Fuel: Paints, Primers, and Solvents
Rated Capacity: 3 Barrels
Emission Limits (lb./hr. gr./dscf. lb./MMBtu. % opacity, etc.):
The emissions from this emission point shall not exceed the following specified levels.
Pollutant: Volatile Organic Compounds (VOC)
Emission Limit: See Facility-Wide Conditions
Authority for Requirement: Iowa DNR Construction Permit 98-A-156-S1
Compliance Plan:
The owner/operator of this equipment shall comply with the following applicable
requirements.
This point is in compliance with all applicable requirements and shall continue to comply
with all such requirements. For those applicable requirements which will become
effective during the permit term, this source will comply with such requirements in a
timely manner.
Additional Requirements:
This emission point shall conform to the following conditions.
The source is to be connected to the stack of the following detailed description.
Stack Height (feet): 41
Stack Diameter (inches): 15
Stack Exhaust Flow Rate (acfm): .... 3,500
Stack Temperature (°F): 70
Vertical, Unobstructed Discharge Required: Yes ^ No ~
Authority for Requirement: Iowa DNR Construction Permit 98-A-156-S 1
374
-------
Periodic Monitoring Requirements:
The owner/operator of this equipment shall comply with the following periodic
monitoring requirements.
Agency Approved Operation & Maintenance Plan Required? Yes ~ No Kl
Facility Maintained Operation & Maintenance Plan Required? Yes ~ No Kl
Authority for Requirement: 567 IAC 22.108(3)"b"
375
-------
Emission Point ID Number: 6.GG
Associated Equipment
Associated Emission Unit ID Numbers (if multiple units vent thru this EP): 6.GG
Applicable Requirements
(If more than one emission unit vents through this emission point subdivide the applicable requirements by emission
unit.)
Emission Units vented through this Emission Point: 6.GG
Emission Unit Description: Paint Kitchen
Raw Material/Fuel: Paints, Primers, and Solvents
Rated Capacity: 3 Barrels
Emission Limits (lb./hr. gr./dscf. lb./MMBtu. % opacity, etc.):
The emissions from this emission point shall not exceed the following specified levels.
Pollutant: Volatile Organic Compounds (VOC)
Emission Limit: See Facility-Wide Conditions
Authority for Requirement: Iowa DNR Construction Permit 98-A-157-S1
Compliance Plan:
The owner/operator of this equipment shall comply with the following applicable
requirements.
This point is in compliance with all applicable requirements and shall continue to comply
with all such requirements. For those applicable requirements which will become
effective during the permit term, this source will comply with such requirements in a
timely manner.
Additional Requirements:
This emission point shall conform to the following conditions.
The source is to be connected to the stack of the following detailed description.
Stack Height (feet): 41
Stack Diameter (inches): 15
Stack Exhaust Flow Rate (acfm): .... 3,500
Stack Temperature (°F): 70
Vertical, Unobstructed Discharge Required: Yes ^ No ~
Authority for Requirement: Iowa DNR Construction Permit 98-A-157-S 1
376
-------
Periodic Monitoring Requirements:
The owner/operator of this equipment shall comply with the following periodic
monitoring requirements.
Agency Approved Operation & Maintenance Plan Required? Yes ~ No Kl
Facility Maintained Operation & Maintenance Plan Required? Yes ~ No Kl
Authority for Requirement: 567 IAC 22.108(3)"b"
377
-------
Emission Point ID Number: 6.H
Associated Equipment
Associated Emission Unit ID Numbers (if multiple units vent thru this EP): 6.H
Applicable Requirements
(If more than one emission unit vents through this emission point subdivide the applicable requirements by emission
unit.)
Emission Unit vented through this Emission Point: 6.H
Emission Unit Description: Hot Water Heater
Raw Material/Fuel: Natural Gas
Rated Capacity: 0.528 MMBtu/hr.
Emission Limits (lb./hr. gr./dscf. lb./MMBtu. % opacity, etc.):
The emissions from this emission point shall not exceed the following specified levels.
Pollutant: Opacity
Emission Limit(s): 40 %
Authority for Requirement: 567 IAC 23.3(2)"d"
Pollutant: Particulate Matter (TSP)
Emission Limit(s): 15.3 lb./MMCF of LPG or Natural Gas
Authority for Requirement: Part 7a. of State of Iowa, ex rel., Iowa DNR vs. Vermeer
Manufacturing Company, 99AG23542
District Court, Marion County, Law No. LACV087889
Pollutant: Particulate Matter (TSP)
Emission Limits: 0.8 lb./MMBtu
Authority for Requirement: 567 IAC 23.3(2)"b"
Pollutant: Sulfur Dioxide (SO2)
Emission Limits: 500 ppmv
Authority for Requirement: 567 IAC 23.3(3)"e"
Pollutant: Nitrogen Oxides (NOx)
Emission Limit(s): See Facility-Wide Conditions
Authority for Requirement: Iowa DNR Construction Permit 98-A-003-S1
Pollutant: Volatile Organic Compounds (VOC)
Emission Limit: See Facility-Wide Conditions
Authority for Requirement: Iowa DNR Construction Permit 98-A-003-S1
378
-------
Operational Limits & Requirements:
The owner/operator of this equipment shall comply with the following operational limits
and requirements.
Process throughput:
A. The sulfur content of natural gas or LPG combusted by this source is not to
exceed 123 ppm by weight.
Reporting & Recordkeeping: See Facility-Wide Operational Limits
Authority for Requirement: Part 7b. of State of Iowa, ex rel., Iowa DNR vs. Vermeer
Manufacturing Company, 99AG23542
District Court, Marion County, Law No. LACV087889
Compliance Plan:
The owner/operator of this equipment shall comply with the following applicable
requirements.
This point is in compliance with all applicable requirements and shall continue to comply
with all such requirements. For those applicable requirements which will become
effective during the permit term, this source will comply with such requirements in a
timely manner.
Periodic Monitoring Requirements:
The owner/operator of this equipment shall comply with the following periodic
monitoring requirements.
Agency Approved Operation & Maintenance Plan Required? Yes ~ No IXI
Facility Maintained Operation & Maintenance Plan Required? Yes ~ No Kl
Authority for Requirement: 567 IAC 22.108(3)"b"
379
-------
Emission Point ID Number: 6.HH
Associated Equipment
Associated Emission Unit ID Numbers (if multiple units vent thru this EP): 6.HH
Emissions Control Equipment ID Number: 6.HH
Emissions Control Equipment Description: Paper Filter
Applicable Requirements
(If more than one emission unit vents through this emission point subdivide the applicable requirements by emission
unit.)
Emission Unit vented through this Emission Point: 6.HH
Emission Unit Description: Primer Paint Booth
Raw Material/Fuel: Paints, Primers, and Solvents
Rated Capacity: 15 gal./hr.
Emission Limits (lb./hr. gr./dscf. lb./MMBtu. % opacity, etc.):
The emissions from this emission point shall not exceed the following specified levels.
Pollutant: Opacity
Emission Limits: 40%
Indicator Opacity: (1)
(1) If visible emissions are observed other than startup, shutdown or malfunction, a stack
test may be required to demonstrate compliance with the particulate standard.
Authority for Requirement: Iowa DNR Construction Permit 97-A-975-S3
567 IAC23.3(2)"d"
Pollutant: PMio
Emission Limit(s): 0.9 lb./hr.
Authority for Requirement: Iowa DNR Construction Permit 97-A-975-S3
Pollutant: Particulate Matter (TSP)
Emission Limit(s): 0.01 gr./dscf
Authority for Requirement: Iowa DNR Construction Permit 97-A-975-S3
567 IAC 23.4(13)
Pollutant: Volatile Organic Compounds (VOC)
Emission Limit: See Facility-Wide Conditions
Authority for Requirement: Iowa DNR Construction Permit 97-A-975-S3
380
-------
Operational Limits & Requirements:
The owner/operator of this equipment shall comply with the following operational limits
and requirements.
Supplemental Environmental Project:
Equipment parameters:
The emission unit associated with this emission point will consist of the booth, an
exhaust fan, and a duct extending from a sixteen (16) foot long by four (4) foot wide
by six (6) foot deep exhaust pit to ten (10) feet above the peak of the roof. The
emission unit will maintain a Binks microprocessor controlled, multi-color, precision
mix system with two gun flush boxes, solvent meters, and solvent valves. The system
will be panel mounted approximately five (5) feet from the nearest opening and will
control solvent, paint, and catalyst flow to a mixing tube adjacent to the emission unit
and record the cumulative amount of the exact volume or weight of primer, paint,
solvent, or catalyst utilized in the emission unit. The system will be interlocked with
the two Graco gun flush boxes, and the guns will be interlocked with the fan mix
system and electronic generators of the paint spray booth.
Authority for Requirement: Paragraph 3e. of State of Iowa, ex rel., Iowa DNR vs.
Vermeer Manufacturing Company, 99AG23542
District Court, Marion County, Law No. LACV087889
Operational term: This SEP will be maintained for the life of this permit.
Authority for Requirement: Paragraph 3i. of State of Iowa, ex rel., Iowa DNR vs.
Vermeer Manufacturing Company, 99AG23542
District Court, Marion County, Law No. LACV087889
Reporting & Record keeping:
Vermeer shall submit to the DNR an annual performance report covering the required
period of use and maintenance of this SEP documenting the actual use and
maintenance of this SEP. The report shall evaluate the performance of the SEP and
document the extent of VOC emissions reductions. Vermeer shall conduct
cumulative mass balance calculations to determine the actual effect measured against
the 1997 baseline of 122.94 tons of VOC emitted per year. The reports shall be
submitted on or before March 1, for the preceding calendar year, commencing on
March 1, 1999. For additional reporting and recordkeeping see the Facility-Wide
Conditions
Authority for Requirement: Paragraph 3j. of State of Iowa, ex rel., Iowa DNR vs.
Vermeer Manufacturing Company, 99AG23542
District Court, Marion County, Law No. LACV087889
Iowa DNR Construction Permit 97-A-975-S3
381
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Compliance Plan:
The owner/operator of this equipment shall comply with the following applicable
requirements.
This point is in compliance with all applicable requirements and shall continue to comply
with all such requirements. For those applicable requirements which will become
effective during the permit term, this source will comply with such requirements in a
timely manner.
Additional Requirements:
This emission point shall conform to the following conditions.
The source is to be connected to the stack of the following detailed description.
Stack Height (feet): 44.5
Stack Diameter (inches): 42.0
Stack Exhaust Flow Rate (acfm): .... 20,000
Stack Temperature (°F): 70
Vertical, Unobstructed Discharge Required: Yes ^ No ~
Authority for Requirement: Iowa DNR Construction Permit 97-A-975-S3
Periodic Monitoring Requirements:
The owner/operator of this equipment shall comply with the following periodic
monitoring requirements.
Stack Testing:
Pollutant: Particulate Matter (TSP)
Stack Test to be Completed by (date): October 18, 2001
Test Method: Iowa Compliance Sampling Manual
Authority for Requirement: 567 IAC 22.108(3)
This stack test will represent the compliance testing for emission points 6.HH and 6.S. In
the event that a stack test of the other listed emission point is more suitable it may be
tested to fulfill the requirements. Suitability will be determined by the Stack Test
Observation Coordinator of the Air Quality Bureau Compliance Assistance Section. The
results of the compliance stack testing will be used to calculate actual emissions for the
listed sources until such time as more recent data becomes available. If the source test
does not demonstrate compliance this permit will be reopened to add a compliance plan
and operation and maintenance requirements.
The owner of this equipment or the owner's authorized agent shall provide written notice
to the Director, not less than 30 days before a required stack test or performance
evaluation of a continuous emission monitor. Results of the test shall be submitted in
writing to the Director in the form of a comprehensive report within 6 weeks of the
completion of the testing. 567 IAC 25.1(7)
382
-------
Periodic Monitoring Requirements (continued):
Opacity Monitoring:
The facility shall observe the opacity weekly during a period when the emission unit
associated with this emission point is at or near full capacity and record the reading
indicating if visible emissions were observed. The records shall be maintained for five
years. If weather conditions prevent the observer from conducting an opacity
observation, the observer shall note such conditions on the data observation sheet. At
least three attempts shall be made to retake opacity readings at approximately 2-hour
intervals throughout the day. If all observation attempts for a week have been
unsuccessful due to weather, an observation shall be made the next operating day where
weather permits.
Maintain a written record of the observation and any action resulting from the
observation.
Agency Approved Operation & Maintenance Plan Required? Yes ~ No Kl
Facility Maintained Operation & Maintenance Plan Required? Yes Kl NoQ
Facility operation and maintenance plans must be sufficient to yield reliable data from
the relevant time period that are representative of the source's compliance with the
applicable requirements.
Facility operation and maintenance plans are to be developed by the facility within six(6)
months of the issuance date of this permit and the data pertaining to the plan maintained
on site for at least 5 years. The plan and associated recordkeeping provides
documentation of this facility's implementation of its obligation to operate according to
good air pollution control practice.
Good air pollution control practice is achieved by adoption of quality control standards
in the operation and maintenance procedures for air pollution control that are
comparable to industry quality control standards for the production processes associated
with this emission point.
Authority for Requirement: 567 IAC 22.108(3)"b"
383
-------
Emission Point ID Number: 6.JJ
Associated Equipment
Associated Emission Unit ID Numbers (if multiple units vent thru this EP): 6. JJ
Applicable Requirements
(If more than one emission unit vents through this emission point subdivide the applicable requirements by emission
unit.)
Emission Unit vented through this Emission Point: 6.JJ
Emission Unit Description: Paint Booth Air Intake
Raw Material/Fuel: Natural Gas
Rated Capacity: 2.16 MMBtu/hr.
Emission Limits (lb./hr. gr./dscf. lb./MMBtu. % opacity, etc.):
The emissions from this emission point shall not exceed the following specified levels.
Pollutant: Opacity
Emission Limit(s): 40 %
Authority for Requirement: 567 IAC 23.3(2)"d"
Pollutant: Particulate Matter (TSP)
Emission Limit(s): 15.3 lb./MMCF of LPG or Natural Gas
Authority for Requirement: Part 7a. of State of Iowa, ex rel., Iowa DNR vs. Vermeer
Manufacturing Company, 99AG23542
District Court, Marion County, Law No. LACV087889
Pollutant: Particulate Matter (TSP)
Emission Limits: 0.8 lb./MMBtu
Authority for Requirement: 567 IAC 23.3(2)"b"
Pollutant: Sulfur Dioxide (SO2)
Emission Limits: 500 ppmv
Authority for Requirement: 567 IAC 23.3(3)"e"
Pollutant: Nitrogen Oxides (NOx)
Emission Limit(s): See Facility-Wide Conditions
Authority for Requirement: Iowa DNR Construction Permit 98-A-003-S1
Pollutant: Volatile Organic Compounds (VOC)
Emission Limit: See Facility-Wide Conditions
Authority for Requirement: Iowa DNR Construction Permit 98-A-003-S1
384
-------
Operational Limits & Requirements:
The owner/operator of this equipment shall comply with the following operational limits
and requirements.
Process throughput:
A. The sulfur content of natural gas or LPG combusted by this source is not to
exceed 123 ppm by weight.
Reporting & Recordkeeping: See Facility-Wide Operational Limits
Authority for Requirement: Part 7b. of State of Iowa, ex rel., Iowa DNR vs. Vermeer
Manufacturing Company, 99AG23542
District Court, Marion County, Law No. LACV087889
Compliance Plan:
The owner/operator of this equipment shall comply with the following applicable
requirements.
This point is in compliance with all applicable requirements and shall continue to comply
with all such requirements. For those applicable requirements which will become
effective during the permit term, this source will comply with such requirements in a
timely manner.
Periodic Monitoring Requirements:
The owner/operator of this equipment shall comply with the following periodic
monitoring requirements.
Agency Approved Operation & Maintenance Plan Required? Yes ~ No IXI
Facility Maintained Operation & Maintenance Plan Required? Yes ~ No Kl
Authority for Requirement: 567 IAC 22.108(3)"b"
385
-------
Emission Point ID Number: 6.K
Associated Equipment
Associated Emission Unit ID Numbers (if multiple units vent thru this EP): 6.K
Applicable Requirements
(If more than one emission unit vents through this emission point subdivide the applicable requirements by emission
unit.)
Emission Unit vented through this Emission Point: 6.K
Emission Unit Description: Production Engine Testing Unit
Raw Material/Fuel: #2 Diesel Fuel and Gasoline
Rated Capacity: 60.6 gal./hr.
Emission Limits (lb./hr. gr./dscf. lb./MMBtu. % opacity, etc.):
The emissions from this emission point shall not exceed the following specified levels.
Pollutant: Opacity
Emission Limits: 40%
Indicator Opacity: 25%(1)
(1) If visible emissions are observed that exceed the indicator opacity other than startup,
shutdown or malfunction, a stack test may be required to demonstrate compliance with
the particulate standard.
Authority for Requirement: Iowa DNR Construction Permit 97-A-300-S4
567 IAC 23.3(2)"d"
Pollutant: Particulate Matter (TSP)
Emission Limits: 0.1 gr./dscf
Authority for Requirement: Iowa DNR Construction Permit 97-A-300-S4
567 IAC 23.3(2)"a"
Pollutant: Sulfur Dioxide (SO2)
Emission Limits: 2.5 lb./MMBtu
Authority for Requirement: Iowa DNR Construction Permit 97-A-300-S4
567 IAC 23.3(3)"b"
Pollutant: Nitrogen Oxides (NOx)
Emission Limit(s): See Facility-Wide Conditions
Authority for Requirement: Iowa DNR Construction Permit 97-A-300-S4
Pollutant: Volatile Organic Compounds (VOC)
Emission Limit: See Facility-Wide Conditions
Authority for Requirement: Iowa DNR Construction Permit 97-A-300-S4
386
-------
Operational Limits & Requirements:
The owner/operator of this equipment shall comply with the following operational limits
and requirements.
Process Throughput:
A. The sulfur content of any diesel fuel used in this source shall not exceed 0.4% by
weight.
Reporting & Recordkeeping: See Facility-Wide Emission and Operational Limits
Authority for Requirement: Iowa DNR Construction Permit 97-A-300-S4
Compliance Plan:
The owner/operator of this equipment shall comply with the following applicable
requirements.
This point is in compliance with all applicable requirements and shall continue to comply
with all such requirements. For those applicable requirements which will become
effective during the permit term, this source will comply with such requirements in a
timely manner.
Additional Requirements:
This emission point shall conform to the following conditions.
The source is to be connected to the stack of the following detailed description.
Stack Height (feet): 30.5
Stack Diameter (inches): 12
Stack Exhaust Flow Rate (acfm): .... 11,500
Stack Temperature (°F): 845
Vertical, Unobstructed Discharge Required: Yes ^ No ~
Authority for Requirement: Iowa DNR Construction Permit 97-A-300-S4
Periodic Monitoring Requirements:
The owner/operator of this equipment shall comply with the following periodic
monitoring requirements.
Opacity Monitoring:
The facility shall observe the opacity weekly during a period when the emission unit
associated with this emission point is at or near full capacity and record the reading
indicating if visible emissions were observed. The records shall be maintained for five
years. If weather conditions prevent the observer from conducting an opacity
observation, the observer shall note such conditions on the data observation sheet. At
least three attempts shall be made to retake opacity readings at approximately 2-hour
intervals throughout the day. If all observation attempts for a week have been
unsuccessful due to weather, an observation shall be made the next operating day where
weather permits.
Maintain a written record of the observation and any action resulting from the
observation.
387
-------
Agency Approved Operation & Maintenance Plan Required? Yes ~ No Kl
Facility Maintained Operation & Maintenance Plan Required? Yes ~ No Kl
Authority for Requirement: 567 IAC 22.108(3)"b"
388
-------
Emission Point ID Number: 6.KK
Associated Equipment
Associated Emission Unit ID Numbers (if multiple units vent thru this EP): 6.KK
Applicable Requirements
(If more than one emission unit vents through this emission point subdivide the applicable requirements by emission
unit.)
Emission Unit vented through this Emission Point: 6.KK
Emission Unit Description: Paint Booth Air Intake
Raw Material/Fuel: Natural Gas
Rated Capacity: 2.16 MMBtu/hr.
Emission Limits (lb./hr. gr./dscf. lb./MMBtu. % opacity, etc.):
The emissions from this emission point shall not exceed the following specified levels.
Pollutant: Opacity
Emission Limit(s): 40 %
Authority for Requirement: 567 IAC 23.3(2)"d"
Pollutant: Particulate Matter (TSP)
Emission Limit(s): 15.3 lb./MMCF of LPG or Natural Gas
Authority for Requirement: Part 7a. of State of Iowa, ex rel., Iowa DNR vs. Vermeer
Manufacturing Company, 99AG23542
District Court, Marion County, Law No. LACV087889
Pollutant: Particulate Matter (TSP)
Emission Limits: 0.8 lb./MMBtu
Authority for Requirement: 567 IAC 23.3(2)"b"
Pollutant: Sulfur Dioxide (SO2)
Emission Limits: 500 ppmv
Authority for Requirement: 567 IAC 23.3(3)"e"
Pollutant: Nitrogen Oxides (NOx)
Emission Limit(s): See Facility-Wide Conditions
Authority for Requirement: Iowa DNR Construction Permit 98-A-003-S1
Pollutant: Volatile Organic Compounds (VOC)
Emission Limit: See Facility-Wide Conditions
Authority for Requirement: Iowa DNR Construction Permit 98-A-003-S1
389
-------
Operational Limits & Requirements:
The owner/operator of this equipment shall comply with the following operational limits
and requirements.
Process throughput:
A. The sulfur content of natural gas or LPG combusted by this source is not to
exceed 123 ppm by weight.
Reporting & Recordkeeping: See Facility-Wide Operational Limits
Authority for Requirement: Part 7b. of State of Iowa, ex rel., Iowa DNR vs. Vermeer
Manufacturing Company, 99AG23542
District Court, Marion County, Law No. LACV087889
Compliance Plan:
The owner/operator of this equipment shall comply with the following applicable
requirements.
This point is in compliance with all applicable requirements and shall continue to comply
with all such requirements. For those applicable requirements which will become
effective during the permit term, this source will comply with such requirements in a
timely manner.
Periodic Monitoring Requirements:
The owner/operator of this equipment shall comply with the following periodic
monitoring requirements.
Agency Approved Operation & Maintenance Plan Required? Yes ~ No IXI
Facility Maintained Operation & Maintenance Plan Required? Yes ~ No Kl
Authority for Requirement: 567 IAC 22.108(3)"b"
390
-------
Emission Point ID Number: 6.L
Associated Equipment
Associated Emission Unit ID Numbers (if multiple units vent thru this EP): 6.L
Applicable Requirements
(If more than one emission unit vents through this emission point subdivide the applicable requirements by emission
unit.)
Emission Unit vented through this Emission Point: 6.L
Emission Unit Description: Non-Production Heating Unit
Raw Material/Fuel: Natural Gas
Rated Capacity: 0.11 MMBtu/hr.
Emission Limits (lb./hr. gr./dscf. lb./MMBtu. % opacity, etc.):
The emissions from this emission point shall not exceed the following specified levels.
Pollutant: Opacity
Emission Limit(s): 40 %
Authority for Requirement: 567 IAC 23.3(2)"d"
Pollutant: Particulate Matter (TSP)
Emission Limit(s): 15.3 lb./MMCF of LPG or Natural Gas
Authority for Requirement: Part 7a. of State of Iowa, ex rel., Iowa DNR vs. Vermeer
Manufacturing Company, 99AG23542
District Court, Marion County, Law No. LACV087889
Pollutant: Particulate Matter (TSP)
Emission Limits: 0.8 lb./MMBtu
Authority for Requirement: 567 IAC 23.3(2)"b"
Pollutant: Sulfur Dioxide (SO2)
Emission Limits: 500 ppmv
Authority for Requirement: 567 IAC 23.3(3)"e"
Pollutant: Nitrogen Oxides (NOx)
Emission Limit(s): See Facility-Wide Conditions
Authority for Requirement: Iowa DNR Construction Permit 98-A-003-S1
Pollutant: Volatile Organic Compounds (VOC)
Emission Limit: See Facility-Wide Conditions
Authority for Requirement: Iowa DNR Construction Permit 98-A-003-S1
391
-------
Operational Limits & Requirements:
The owner/operator of this equipment shall comply with the following operational limits
and requirements.
Process throughput:
A. The sulfur content of natural gas or LPG combusted by this source is not to
exceed 123 ppm by weight.
Reporting & Recordkeeping: See Facility-Wide Operational Limits
Authority for Requirement: Part 7b. of State of Iowa, ex rel., Iowa DNR vs. Vermeer
Manufacturing Company, 99AG23542
District Court, Marion County, Law No. LACV087889
Compliance Plan:
The owner/operator of this equipment shall comply with the following applicable
requirements.
This point is in compliance with all applicable requirements and shall continue to comply
with all such requirements. For those applicable requirements which will become
effective during the permit term, this source will comply with such requirements in a
timely manner.
Periodic Monitoring Requirements:
The owner/operator of this equipment shall comply with the following periodic
monitoring requirements.
Agency Approved Operation & Maintenance Plan Required? Yes ~ No IXI
Facility Maintained Operation & Maintenance Plan Required? Yes ~ No Kl
Authority for Requirement: 567 IAC 22.108(3)"b"
392
-------
Emission Point ID Number: 6.LL
Associated Equipment
Associated Emission Unit ID Numbers (if multiple units vent thru this EP): 6.LL
Applicable Requirements
(If more than one emission unit vents through this emission point subdivide the applicable requirements by emission
unit.)
Emission Unit vented through this Emission Point: 6.LL
Emission Unit Description: Production Engine Testing Unit
Raw Material/Fuel: #2 Diesel Fuel and Gasoline
Rated Capacity: 60.6 gal./hr.
Emission Limits (lb./hr. gr./dscf. lb./MMBtu. % opacity, etc.):
The emissions from this emission point shall not exceed the following specified levels.
Pollutant: Opacity
Emission Limits: 40%
Indicator Opacity: 25%(1)
(1) If visible emissions are observed that exceed the indicator opacity other than startup,
shutdown or malfunction, a stack test may be required to demonstrate compliance with
the particulate standard.
Authority for Requirement: Iowa DNR Construction Permit 98-A-865-S2
567 IAC 23.3(2)"d"
Pollutant: Particulate Matter (TSP)
Emission Limits: 0.1 gr./dscf
Authority for Requirement: Iowa DNR Construction Permit 98-A-865-S2
Pollutant: Sulfur Dioxide (SO2)
Emission Limits: 2.5 lb./MMBtu
Authority for Requirement: Iowa DNR Construction Permit 98-A-865-S2
567 IAC 23.3(3)"b"
Pollutant: Nitrogen Oxides (NOx)
Emission Limit(s): See Facility-Wide Conditions
Authority for Requirement: Iowa DNR Construction Permit 98-A-865-S2
Pollutant: Volatile Organic Compounds (VOC)
Emission Limit: See Facility-Wide Conditions
Authority for Requirement: Iowa DNR Construction Permit 98-A-865-S2
393
-------
Operational Limits & Requirements:
The owner/operator of this equipment shall comply with the following operational limits
and requirements.
Process Throughput:
A. The sulfur content of any diesel fuel used in this source shall not exceed 0.4% by
weight.
Reporting & Recordkeeping: See Facility-Wide Emission and Operational Limits
Authority for Requirement: Iowa DNR Construction Permit 98-A-865-S1
Compliance Plan:
The owner/operator of this equipment shall comply with the following applicable
requirements.
This point is in compliance with all applicable requirements and shall continue to comply
with all such requirements. For those applicable requirements which will become
effective during the permit term, this source will comply with such requirements in a
timely manner.
Additional Requirements:
This emission point shall conform to the following conditions.
The source is to be connected to the stack of the following detailed description.
Stack Height (feet): 38
Stack Diameter (inches): 12
Stack Exhaust Flow Rate (acfm): .... 7,387
Stack Temperature (°F): 845
Vertical, Unobstructed Discharge Required: Yes ~ No
Authority for Requirement: Iowa DNR Construction Permit 98-A-865-S1
Periodic Monitoring Requirements:
The owner/operator of this equipment shall comply with the following periodic
monitoring requirements.
Opacity Monitoring:
The facility shall observe the opacity weekly during a period when the emission unit
associated with this emission point is at or near full capacity and record the reading
indicating if visible emissions were observed. The records shall be maintained for five
years. If weather conditions prevent the observer from conducting an opacity
observation, the observer shall note such conditions on the data observation sheet. At
least three attempts shall be made to retake opacity readings at approximately 2-hour
intervals throughout the day. If all observation attempts for a week have been
unsuccessful due to weather, an observation shall be made the next operating day where
weather permits.
Maintain a written record of the observation and any action resulting from the
observation.
E
394
-------
Agency Approved Operation & Maintenance Plan Required? Yes ~ No Kl
Facility Maintained Operation & Maintenance Plan Required? Yes ~ No Kl
Authority for Requirement: 567 IAC 22.108(3)"b"
395
-------
Emission Point ID Number: 6.M1
Associated Equipment
Associated Emission Unit ID Numbers (if multiple units vent thru this EP): 6.M
Emissions Control Equipment ID Number: 6.M
Emissions Control Equipment Description: Paper Filter
Applicable Requirements
(If more than one emission unit vents through this emission point subdivide the applicable requirements by emission
unit.)
Emission Unit vented through this Emission Point: 6.M
Emission Unit Description: Finish Paint Booth
Raw Material/Fuel: Paints, Primers, and Solvents
Rated Capacity: 15 gal./hr.
Emission Limits (lb./hr. gr./dscf. lb./MMBtu. % opacity, etc.):
The emissions from this emission point shall not exceed the following specified levels.
Pollutant: Opacity
Emission Limits: 40%
Indicator Opacity: (1)
(1) If visible emissions are observed other than startup, shutdown or malfunction, a stack
test may be required to demonstrate compliance with the particulate standard.
Authority for Requirement: Iowa DNR Construction Permit 97-A-295-S3
567 IAC23.3(2)"d"
Pollutant: PMio
Emission Limit(s): 1.22 lb./hr.
Authority for Requirement: Iowa DNR Construction Permit 97-A-295-S3
Pollutant: Particulate Matter (TSP)
Emission Limit(s): 0.01 gr./dscf
Authority for Requirement: Iowa DNR Construction Permit 97-A-295-S3
567 IAC 23.4(13)
Pollutant: Volatile Organic Compounds (VOC)
Emission Limit: See Facility-Wide Conditions
Authority for Requirement: Iowa DNR Construction Permit 97-A-295-S3
396
-------
Operational Limits & Requirements:
The owner/operator of this equipment shall comply with the following operational limits
and requirements.
Supplemental Environmental Project:
Equipment parameters:
The emission unit associated with this emission point will consist of the booth, an
exhaust fan, and a duct extending from a sixteen (16) foot long by four (4) foot wide
by six (6) foot deep exhaust pit to ten (10) feet above the peak of the roof. The
emission unit will maintain a Binks microprocessor controlled, multi-color, precision
mix system with two gun flush boxes, solvent meters, and solvent valves. The system
will be panel mounted approximately five (5) feet from the nearest opening and will
control solvent, paint, and catalyst flow to a mixing tube adjacent to the emission unit
and record the cumulative amount of the exact volume or weight of primer, paint,
solvent, or catalyst utilized in the emission unit. The system will be interlocked with
the two Graco gun flush boxes, and the guns will be interlocked with the fan mix
system and electronic generators of the paint spray booth.
Authority for Requirement: Paragraph 3e. of State of Iowa, ex rel., Iowa DNR vs.
Vermeer Manufacturing Company, 99AG23542
District Court, Marion County, Law No. LACV087889
Operational term: This SEP will be maintained for the life of this permit.
Authority for Requirement: Paragraph 3i. of State of Iowa, ex rel., Iowa DNR vs.
Vermeer Manufacturing Company, 99AG23542
District Court, Marion County, Law No. LACV087889
Reporting & Record keeping:
Vermeer shall submit to the DNR an annual performance report covering the required
period of use and maintenance of this SEP documenting the actual use and
maintenance of this SEP. The report shall evaluate the performance of the SEP and
document the extent of VOC emissions reductions. Vermeer shall conduct
cumulative mass balance calculations to determine the actual effect measured against
the 1997 baseline of 122.94 tons of VOC emitted per year. The reports shall be
submitted on or before March 1, for the preceding calendar year, commencing on
March 1, 1999. For additional reporting and recordkeeping see the Facility-Wide
Conditions
Authority for Requirement: Paragraph 3j. of State of Iowa, ex rel., Iowa DNR vs.
Vermeer Manufacturing Company, 99AG23542
District Court, Marion County, Law No. LACV087889
Iowa DNR Construction Permit 97-A-295-S3
397
-------
Compliance Plan:
The owner/operator of this equipment shall comply with the following applicable
requirements.
This point is in compliance with all applicable requirements and shall continue to comply
with all such requirements. For those applicable requirements which will become
effective during the permit term, this source will comply with such requirements in a
timely manner.
Additional Requirements:
This emission point shall conform to the following conditions.
The source is to be connected to the stack of the following detailed description.
Stack Height (feet): 43.5
Stack Diameter (inches): 42.0
Stack Exhaust Flow Rate (acfm): .... 28,620
Stack Temperature (°F): 70
Vertical, Unobstructed Discharge Required: Yes E No ~
Authority for Requirement: Iowa DNR Construction Permit 97-A-295-S3
Periodic Monitoring Requirements:
The owner/operator of this equipment shall comply with the following periodic
monitoring requirements.
Opacity Monitoring:
The facility shall observe the opacity weekly during a period when the emission unit
associated with this emission point is at or near full capacity and record the reading
indicating if visible emissions were observed. The records shall be maintained for five
years. If weather conditions prevent the observer from conducting an opacity
observation, the observer shall note such conditions on the data observation sheet. At
least three attempts shall be made to retake opacity readings at approximately 2-hour
intervals throughout the day. If all observation attempts for a week have been
unsuccessful due to weather, an observation shall be made the next operating day where
weather permits.
Maintain a written record of the observation and any action resulting from the
observation.
Agency Approved Operation & Maintenance Plan Required? Yes ~ No Kl
Facility Maintained Operation & Maintenance Plan Required? Yes Kl NoQ
Facility operation and maintenance plans must be sufficient to yield reliable data from
the relevant time period that are representative of the source's compliance with the
applicable requirements.
398
-------
Facility operation and maintenance plans are to be developed by the facility within six(6)
months of the issuance date of this permit and the data pertaining to the plan maintained
on site for at least 5 years. The plan and associated recordkeeping provides
documentation of this facility's implementation of its obligation to operate according to
good air pollution control practice.
Good air pollution control practice is achieved by adoption of quality control standards
in the operation and maintenance procedures for air pollution control that are
comparable to industry quality control standards for the production processes associated
with this emission point.
Authority for Requirement: 567 IAC 22.108(3)"b"
399
-------
Emission Point ID Number: 6.M2
Associated Equipment
Associated Emission Unit ID Numbers (if multiple units vent thru this EP): 6.M
Emissions Control Equipment ID Number: 6.M
Emissions Control Equipment Description: Paper Filter
Applicable Requirements
(If more than one emission unit vents through this emission point subdivide the applicable requirements by emission
unit.)
Emission Unit vented through this Emission Point: 6.M
Emission Unit Description: Primer Paint Booth
Raw Material/Fuel: Paints, Primers, and Solvents
Rated Capacity: 15 gal./hr.
Emission Limits (lb./hr. gr./dscf. lb./MMBtu. % opacity, etc.):
The emissions from this emission point shall not exceed the following specified levels.
Pollutant: Opacity
Emission Limits: 40%
Indicator Opacity: (1)
(1) If visible emissions are observed other than startup, shutdown or malfunction, a stack
test may be required to demonstrate compliance with the particulate standard.
Authority for Requirement: Iowa DNR Construction Permit 97-A-296-S3
567 IAC23.3(2)"d"
Pollutant: PMio
Emission Limit(s): 1.22 lb./hr.
Authority for Requirement: Iowa DNR Construction Permit 97-A-296-S3
Pollutant: Particulate Matter (TSP)
Emission Limit(s): 0.01 gr./dscf
Authority for Requirement: Iowa DNR Construction Permit 97-A-296-S3
567 IAC 23.4(13)
Pollutant: Volatile Organic Compounds (VOC)
Emission Limit: See Facility-Wide Conditions
Authority for Requirement: Iowa DNR Construction Permit 97-A-296-S3
400
-------
Operational Limits & Requirements:
The owner/operator of this equipment shall comply with the following operational limits
and requirements.
Supplemental Environmental Project:
Equipment parameters:
The emission unit associated with this emission point will consist of the booth, an
exhaust fan, and a duct extending from a sixteen (16) foot long by four (4) foot wide
by six (6) foot deep exhaust pit to ten (10) feet above the peak of the roof. The
emission unit will maintain a Binks microprocessor controlled, multi-color, precision
mix system with two gun flush boxes, solvent meters, and solvent valves. The system
will be panel mounted approximately five (5) feet from the nearest opening and will
control solvent, paint, and catalyst flow to a mixing tube adjacent to the emission unit
and record the cumulative amount of the exact volume or weight of primer, paint,
solvent, or catalyst utilized in the emission unit. The system will be interlocked with
the two Graco gun flush boxes, and the guns will be interlocked with the fan mix
system and electronic generators of the paint spray booth.
Authority for Requirement: Paragraph 3e. of State of Iowa, ex rel., Iowa DNR vs.
Vermeer Manufacturing Company, 99AG23542
District Court, Marion County, Law No. LACV087889
Operational term: This SEP will be maintained for the life of this permit.
Authority for Requirement: Paragraph 3i. of State of Iowa, ex rel., Iowa DNR vs.
Vermeer Manufacturing Company, 99AG23542
District Court, Marion County, Law No. LACV087889
Reporting & Record keeping:
Vermeer shall submit to the DNR an annual performance report covering the required
period of use and maintenance of this SEP documenting the actual use and
maintenance of this SEP. The report shall evaluate the performance of the SEP and
document the extent of VOC emissions reductions. Vermeer shall conduct
cumulative mass balance calculations to determine the actual effect measured against
the 1997 baseline of 122.94 tons of VOC emitted per year. The reports shall be
submitted on or before March 1, for the preceding calendar year, commencing on
March 1, 1999. For additional reporting and recordkeeping see the Facility-Wide
Conditions
Authority for Requirement: Paragraph 3j. of State of Iowa, ex rel., Iowa DNR vs.
Vermeer Manufacturing Company, 99AG23542
District Court, Marion County, Law No. LACV087889
Iowa DNR Construction Permit 97-A-296-S3
401
-------
Compliance Plan:
The owner/operator of this equipment shall comply with the following applicable
requirements.
This point is in compliance with all applicable requirements and shall continue to comply
with all such requirements. For those applicable requirements which will become
effective during the permit term, this source will comply with such requirements in a
timely manner.
Additional Requirements:
This emission point shall conform to the following conditions.
The source is to be connected to the stack of the following detailed description.
Stack Height (feet): 43.5
Stack Diameter (inches): 42.0
Stack Exhaust Flow Rate (acfm): .... 28,620
Stack Temperature (°F): 70
Vertical, Unobstructed Discharge Required: Yes E No ~
Authority for Requirement: Iowa DNR Construction Permit 97-A-296-S3
Periodic Monitoring Requirements:
The owner/operator of this equipment shall comply with the following periodic
monitoring requirements.
Opacity Monitoring:
The facility shall observe the opacity weekly during a period when the emission unit
associated with this emission point is at or near full capacity and record the reading
indicating if visible emissions were observed. The records shall be maintained for five
years. If weather conditions prevent the observer from conducting an opacity
observation, the observer shall note such conditions on the data observation sheet. At
least three attempts shall be made to retake opacity readings at approximately 2-hour
intervals throughout the day. If all observation attempts for a week have been
unsuccessful due to weather, an observation shall be made the next operating day where
weather permits.
Maintain a written record of the observation and any action resulting from the
observation.
Agency Approved Operation & Maintenance Plan Required? Yes ~ No Kl
Facility Maintained Operation & Maintenance Plan Required? Yes Kl NoQ
Facility operation and maintenance plans must be sufficient to yield reliable data from
the relevant time period that are representative of the source's compliance with the
applicable requirements.
402
-------
Facility operation and maintenance plans are to be developed by the facility within six(6)
months of the issuance date of this permit and the data pertaining to the plan maintained
on site for at least 5 years. The plan and associated recordkeeping provides
documentation of this facility's implementation of its obligation to operate according to
good air pollution control practice.
Good air pollution control practice is achieved by adoption of quality control standards
in the operation and maintenance procedures for air pollution control that are
comparable to industry quality control standards for the production processes associated
with this emission point.
Authority for Requirement: 567 IAC 22.108(3)"b"
403
-------
Emission Point ID Number: 6.MM
Associated Equipment
Associated Emission Unit ID Numbers (if multiple units vent thru this EP): 6.MM
Applicable Requirements
(If more than one emission unit vents through this emission point subdivide the applicable requirements by emission
unit.)
Emission Unit vented through this Emission Point: 6.MM
Emission Unit Description: Production Engine Testing Unit
Raw Material/Fuel: #2 Diesel Fuel and Gasoline
Rated Capacity: 60.6 gal./hr.
Emission Limits (lb./hr. gr./dscf. lb./MMBtu. % opacity, etc.):
The emissions from this emission point shall not exceed the following specified levels.
Pollutant: Opacity
Emission Limits: 40%
Indicator Opacity: 25%(1)
(1) If visible emissions are observed that exceed the indicator opacity other than startup,
shutdown or malfunction, a stack test may be required to demonstrate compliance with
the particulate standard.
Authority for Requirement: Iowa DNR Construction Permit 98-A-866-S2
567 IAC 23.3(2)"d"
Pollutant: Particulate Matter (TSP)
Emission Limits: 0.1 gr./dscf
Authority for Requirement: Iowa DNR Construction Permit 98-A-866-S2
567 IAC 23.3(2)"a"
Pollutant: Sulfur Dioxide (SO2)
Emission Limits: 2.5 lb./MMBtu
Authority for Requirement: Iowa DNR Construction Permit 98-A-866-S2
567 IAC 23.3(3)"b"
Pollutant: Nitrogen Oxides (NOx)
Emission Limit(s): See Facility-Wide Conditions
Authority for Requirement: Iowa DNR Construction Permit 98-A-866-S2
Pollutant: Volatile Organic Compounds (VOC)
Emission Limit: See Facility-Wide Conditions
Authority for Requirement: Iowa DNR Construction Permit 98-A-866-S2
404
-------
Operational Limits & Requirements:
The owner/operator of this equipment shall comply with the following operational limits
and requirements.
Process Throughput:
A. The sulfur content of any diesel fuel used in this source shall not exceed 0.4% by
weight.
Reporting & Recordkeeping: See Facility-Wide Emission and Operational Limits
Authority for Requirement: Iowa DNR Construction Permit 98-A-866-S1
Compliance Plan:
The owner/operator of this equipment shall comply with the following applicable
requirements.
This point is in compliance with all applicable requirements and shall continue to comply
with all such requirements. For those applicable requirements which will become
effective during the permit term, this source will comply with such requirements in a
timely manner.
Additional Requirements:
This emission point shall conform to the following conditions.
The source is to be connected to the stack of the following detailed description.
Stack Height (feet): 38
Stack Diameter (inches): 12
Stack Exhaust Flow Rate (acfm): .... 7,387
Stack Temperature (°F): 845
Vertical, Unobstructed Discharge Required: Yes ~ No
Authority for Requirement: Iowa DNR Construction Permit 98-A-866-S1
Periodic Monitoring Requirements:
The owner/operator of this equipment shall comply with the following periodic
monitoring requirements.
Opacity Monitoring:
The facility shall observe the opacity weekly during a period when the emission unit
associated with this emission point is at or near full capacity and record the reading
indicating if visible emissions were observed. The records shall be maintained for five
years. If weather conditions prevent the observer from conducting an opacity
observation, the observer shall note such conditions on the data observation sheet. At
least three attempts shall be made to retake opacity readings at approximately 2-hour
intervals throughout the day. If all observation attempts for a week have been
unsuccessful due to weather, an observation shall be made the next operating day where
weather permits.
Maintain a written record of the observation and any action resulting from the
observation.
E
405
-------
Agency Approved Operation & Maintenance Plan Required? Yes ~ No Kl
Facility Maintained Operation & Maintenance Plan Required? Yes ~ No Kl
Authority for Requirement: 567 IAC 22.108(3)"b"
406
-------
Emission Point ID Number: 6.N
Associated Equipment
Associated Emission Unit ID Numbers (if multiple units vent thru this EP): 6.N
Emissions Control Equipment ID Number: 6.N
Emissions Control Equipment Description: Paper Filter
Applicable Requirements
(If more than one emission unit vents through this emission point subdivide the applicable requirements by emission
unit.)
Emission Unit vented through this Emission Point: 6.N
Emission Unit Description: Parts Paint Booth
Raw Material/Fuel: Paints, Primers, and Solvents
Rated Capacity: 15 gal./hr.
Emission Limits (lb./hr. gr./dscf. lb./MMBtu. % opacity, etc.):
The emissions from this emission point shall not exceed the following specified levels.
Pollutant: Opacity
Emission Limits: 40%
Indicator Opacity: (1)
(1) If visible emissions are observed other than startup, shutdown or malfunction, a stack
test may be required to demonstrate compliance with the particulate standard.
Authority for Requirement: Iowa DNR Construction Permit 97-A-297-S2
567 IAC23.3(2)"d"
Pollutant: PMio
Emission Limit(s): 1.22 lb./hr.
Authority for Requirement: Iowa DNR Construction Permit 97-A-297-S2
Pollutant: Particulate Matter (TSP)
Emission Limit(s): 0.01 gr./dscf
Authority for Requirement: Iowa DNR Construction Permit 97-A-297-S2
567 IAC 23.4(13)
Pollutant: Volatile Organic Compounds (VOC)
Emission Limit: See Facility-Wide Conditions
Authority for Requirement: Iowa DNR Construction Permit 97-A-297-S2
407
-------
Compliance Plan:
The owner/operator of this equipment shall comply with the following applicable
requirements.
This point is in compliance with all applicable requirements and shall continue to comply
with all such requirements. For those applicable requirements which will become
effective during the permit term, this source will comply with such requirements in a
timely manner.
Additional Requirements:
This emission point shall conform to the following conditions.
The source is to be connected to the stack of the following detailed description.
Stack Height (feet): 40.2
Stack Diameter (inches): 42.0
Stack Exhaust Flow Rate (acfm): .... 16,000
Stack Temperature (°F): 70
Vertical, Unobstructed Discharge Required: Yes ~ No
Authority for Requirement: Iowa DNR Construction Permit 97-A-297-S2
Periodic Monitoring Requirements:
The owner/operator of this equipment shall comply with the following periodic
monitoring requirements.
Stack Testing:
Pollutant: Particulate Matter (TSP)
Stack Test to be Completed by (date): October 18, 2001
Test Method: Iowa Compliance Sampling Manual
Authority for Requirement: 567 IAC 22.108(3)
The results of the compliance stack testing will be used to calculate actual emissions for
this source until such time as more recent data becomes available. If the source test does
not demonstrate compliance this permit will be reopened to add a compliance plan and
operation and maintenance requirements.
The owner of this equipment or the owner's authorized agent shall provide written notice
to the Director, not less than 30 days before a required stack test or performance
evaluation of a continuous emission monitor. Results of the test shall be submitted in
writing to the Director in the form of a comprehensive report within 6 weeks of the
completion of the testing. 567 IAC 25.1(7)
z
408
-------
Periodic Monitoring Requirements (continued):
Opacity Monitoring:
The facility shall observe the opacity weekly during a period when the emission unit
associated with this emission point is at or near full capacity and record the reading
indicating if visible emissions were observed. The records shall be maintained for five
years. If weather conditions prevent the observer from conducting an opacity
observation, the observer shall note such conditions on the data observation sheet. At
least three attempts shall be made to retake opacity readings at approximately 2-hour
intervals throughout the day. If all observation attempts for a week have been
unsuccessful due to weather, an observation shall be made the next operating day where
weather permits.
Maintain a written record of the observation and any action resulting from the
observation.
Agency Approved Operation & Maintenance Plan Required? Yes ~ No Kl
Facility Maintained Operation & Maintenance Plan Required? Yes Kl NoQ
Facility operation and maintenance plans must be sufficient to yield reliable data from
the relevant time period that are representative of the source's compliance with the
applicable requirements.
Facility operation and maintenance plans are to be developed by the facility within six(6)
months of the issuance date of this permit and the data pertaining to the plan maintained
on site for at least 5 years. The plan and associated recordkeeping provides
documentation of this facility's implementation of its obligation to operate according to
good air pollution control practice.
Good air pollution control practice is achieved by adoption of quality control standards
in the operation and maintenance procedures for air pollution control that are
comparable to industry quality control standards for the production processes associated
with this emission point.
Authority for Requirement: 567 IAC 22.108(3)"b"
409
-------
Emission Point ID Number: 6.PLASMA1
Associated Equipment
Associated Emission Unit ID Numbers (if multiple units vent thru this EP): 6.PLASMA1
Applicable Requirements
(If more than one emission unit vents through this emission point subdivide the applicable requirements by emission
unit.)
Emission Unit vented through this Emission Point: 6.PLASMA1 (Fugitive)
Emission Unit Description: Single Head Plasma Cutting
Machine
Raw Material/Fuel: Sheet Steel
Rated Capacity: 4,500 inches of metal cut/hr.
Emission Limits (lb./hr. gr./dscf. lb./MMBtu. % opacity, etc.):
The emissions from this emission point shall not exceed the following specified levels.
Pollutant: Fugitive Dust
Emission Limit: No person shall allow, cause or permit any materials to be handled,
transported or stored; or a building, its appurtenances or a construction haul road to
be used, constructed, altered , repaired or demolished, without taking reasonable
precautions to prevent a nuisance. All persons shall take reasonable precautions to
prevent the discharge of visible emissions of fugitive dusts beyond the lot line of the
property on which the emissions originate.
Authority for Requirement: 567 IAC 23.3(2)"c"
Compliance Plan:
The owner/operator of this equipment shall comply with the following applicable
requirements.
This point is in compliance with all applicable requirements and shall continue to comply
with all such requirements. For those applicable requirements which will become
effective during the permit term, this source will comply with such requirements in a
timely manner.
Periodic Monitoring Requirements:
The owner/operator of this equipment shall comply with the following periodic
monitoring requirements.
Agency Approved Operation & Maintenance Plan Required? Yes ~ No IXI
Facility Maintained Operation & Maintenance Plan Required? Yes ~ No Kl
Authority for Requirement: 567 IAC 22.108(3)"b"
410
-------
Emission Point ID Number: 6.PRTWSH
Associated Equipment
Associated Emission Unit ID Numbers (if multiple units vent thru this EP): 6.PRTWSH
Applicable Requirements
(If more than one emission unit vents through this emission point subdivide the applicable requirements by emission
unit.)
Emission Unit vented through this Emission Point: 6.PRTWSH (Fugitive)
Emission Unit Description: Two (2) Safety Kleen Parts
Washers
Raw Material/Fuel: Stoddard Solvent
Rated Capacity: 55 Gallons Solvent per Washer
Emission Limits (lb./hr. gr./dscf. lb./MMBtu. % opacity, etc.):
The emissions from this emission point shall not exceed the following specified levels.
Pollutant: Volatile Organic Compounds (VOC)
Emission Limit: See Facility-Wide Conditions
Authority for Requirement: Iowa DNR Construction Permit 98-A-003-S1
Compliance Plan:
The owner/operator of this equipment shall comply with the following applicable
requirements.
This point is in compliance with all applicable requirements and shall continue to comply
with all such requirements. For those applicable requirements which will become
effective during the permit term, this source will comply with such requirements in a
timely manner.
Periodic Monitoring Requirements:
The owner/operator of this equipment shall comply with the following periodic
monitoring requirements.
Agency Approved Operation & Maintenance Plan Required? Yes ~ No Kl
Facility Maintained Operation & Maintenance Plan Required? Yes ~ No Kl
Authority for Requirement: 567 IAC 22.108(3)"b"
411
-------
Emission Point ID Number: 6.Q
Associated Equipment
Associated Emission Unit ID Numbers (if multiple units vent thru this EP): 6.Q
Applicable Requirements
(If more than one emission unit vents through this emission point subdivide the applicable requirements by emission
unit.)
Emission Unit vented through this Emission Point: 6.Q
Emission Unit Description: Hot Water Heater
Raw Material/Fuel: Natural Gas
Rated Capacity: 0.528 MMBtu/hr.
Emission Limits (lb./hr. gr./dscf. lb./MMBtu. % opacity, etc.):
The emissions from this emission point shall not exceed the following specified levels.
Pollutant: Opacity
Emission Limit(s): 40 %
Authority for Requirement: 567 IAC 23.3(2)"d"
Pollutant: Particulate Matter (TSP)
Emission Limit(s): 15.3 lb./MMCF of LPG or Natural Gas
Authority for Requirement: Part 7a. of State of Iowa, ex rel., Iowa DNR vs. Vermeer
Manufacturing Company, 99AG23542
District Court, Marion County, Law No. LACV087889
Pollutant: Particulate Matter (TSP)
Emission Limits: 0.8 lb./MMBtu
Authority for Requirement: 567 IAC 23.3(2)"b"
Pollutant: Sulfur Dioxide (SO2)
Emission Limits: 500 ppmv
Authority for Requirement: 567 IAC 23.3(3)"e"
Pollutant: Nitrogen Oxides (NOx)
Emission Limit(s): See Facility-Wide Conditions
Authority for Requirement: Iowa DNR Construction Permit 98-A-003-S1
Pollutant: Volatile Organic Compounds (VOC)
Emission Limit: See Facility-Wide Conditions
Authority for Requirement: Iowa DNR Construction Permit 98-A-003-S1
412
-------
Operational Limits & Requirements:
The owner/operator of this equipment shall comply with the following operational limits
and requirements.
Process throughput:
A. The sulfur content of natural gas or LPG combusted by this source is not to
exceed 123 ppm by weight.
Reporting & Recordkeeping: See Facility-Wide Operational Limits
Authority for Requirement: Part 7b. of State of Iowa, ex rel., Iowa DNR vs. Vermeer
Manufacturing Company, 99AG23542
District Court, Marion County, Law No. LACV087889
Compliance Plan:
The owner/operator of this equipment shall comply with the following applicable
requirements.
This point is in compliance with all applicable requirements and shall continue to comply
with all such requirements. For those applicable requirements which will become
effective during the permit term, this source will comply with such requirements in a
timely manner.
Periodic Monitoring Requirements:
The owner/operator of this equipment shall comply with the following periodic
monitoring requirements.
Agency Approved Operation & Maintenance Plan Required? Yes ~ No IXI
Facility Maintained Operation & Maintenance Plan Required? Yes ~ No Kl
Authority for Requirement: 567 IAC 22.108(3)"b"
413
-------
Emission Point ID Number: 6.QQ
Associated Equipment
Associated Emission Unit ID Numbers (if multiple units vent thru this EP): 6.QQ
Applicable Requirements
(If more than one emission unit vents through this emission point subdivide the applicable requirements by emission
unit.)
Emission Unit vented through this Emission Point: 6.QQ
Emission Unit Description: Stage 1 Washer
Raw Material/Fuel: Hot Alkaline Cleaner
Rated Capacity: 300 gal./hr.
Emission Limits (lb./hr. gr./dscf. lb./MMBtu. % opacity, etc.):
The emissions from this emission point shall not exceed the following specified levels.
Pollutant: Opacity
Emission Limits: 40%
Indicator Opacity: (1)
(1) If visible emissions are observed other than startup, shutdown or malfunction, a stack
test may be required to demonstrate compliance with the particulate standard.
Authority for Requirement: Iowa DNR Construction Permit 98-A-868-S1
567 IAC23.3(2)"d"
Pollutant: Particulate Matter (TSP)
Emission Limit(s): 0.1 gr./dscf
Authority for Requirement: Iowa DNR Construction Permit 98-A-868-S1
567 IAC 23.4(13)
Operational Limits & Requirements:
The owner/operator of this equipment shall comply with the following operational limits
and requirements.
Supplemental Environmental Project:
Equipment parameters:
As part of a multi-stage washer system the emission unit associated with this
emission point will consist of a heated alkaline cleaner solution utilizing a sequenced
manifold of spray nozzle tips to clean the metal parts in preparation for polyurethane
coating. An extended drain zone will be provided to prevent chemical drag out to the
second stage, a clean water rinse. A power and free conveyer system will be utilized
to supply parts to and from the washer system. The entire washer system shall be
approximately 150 feet long, 8 to 10 feet wide, and constructed of mild and stainless
steel.
414
-------
Operational Limits & Requirements (continued):
Authority for Requirement: Paragraph 3d. of State of Iowa, ex rel., Iowa DNR vs.
Vermeer Manufacturing Company, 99AG23542
District Court, Marion County, Law No. LACV087889
Operational term: This SEP will be maintained for the life of this permit.
Authority for Requirement: Paragraph 3i. of State of Iowa, ex rel., Iowa DNR vs.
Vermeer Manufacturing Company, 99AG23542
District Court, Marion County, Law No. LACV087889
Reporting & Record keeping:
Vermeer shall submit to the DNR an annual performance report covering the required
period of use and maintenance of this SEP documenting the actual use and
maintenance of this SEP. The reports shall be submitted on or before March 1, for the
preceding calendar year, commencing on March 1, 1999.
Authority for Requirement: Paragraph 3j. of State of Iowa, ex rel., Iowa DNR vs.
Vermeer Manufacturing Company, 99AG23542
District Court, Marion County, Law No. LACV087889
Compliance Plan:
The owner/operator of this equipment shall comply with the following applicable
requirements.
This point is in compliance with all applicable requirements and shall continue to comply
with all such requirements. For those applicable requirements which will become
effective during the permit term, this source will comply with such requirements in a
timely manner.
Additional Requirements:
This emission point shall conform to the following conditions.
The source is to be connected to the stack of the following detailed description.
Stack Height (feet): 36
Stack Diameter (inches): 12.0
Stack Exhaust Flow Rate (acfm): .... 6,000
Stack Temperature (°F): 70
Vertical, Unobstructed Discharge Required: Yes ^ No ~
Authority for Requirement: Iowa DNR Construction Permit 98-A-868-S1
415
-------
Periodic Monitoring Requirements:
The owner/operator of this equipment shall comply with the following periodic
monitoring requirements.
Opacity Monitoring:
The facility shall observe the opacity weekly during a period when the emission unit
associated with this emission point is at or near full capacity and record the reading
indicating if visible emissions were observed. The records shall be maintained for five
years. If weather conditions prevent the observer from conducting an opacity
observation, the observer shall note such conditions on the data observation sheet. At
least three attempts shall be made to retake opacity readings at approximately 2-hour
intervals throughout the day. If all observation attempts for a week have been
unsuccessful due to weather, an observation shall be made the next operating day where
weather permits.
Maintain a written record of the observation and any action resulting from the
observation.
Agency Approved Operation & Maintenance Plan Required? Yes ~ No IEI
Facility Maintained Operation & Maintenance Plan Required? Yes ~ No Kl
Authority for Requirement: 567 IAC 22.108(3)"b"
416
-------
Emission Point ID Number: 6.R
Associated Equipment
Associated Emission Unit ID Numbers (if multiple units vent thru this EP): 6.R
Applicable Requirements
(If more than one emission unit vents through this emission point subdivide the applicable requirements by emission
unit.)
Emission Unit vented through this Emission Point: 6.R
Emission Unit Description: Non-Production Heating Unit
Raw Material/Fuel: Natural Gas
Rated Capacity: 4.68 MMBtu/hr.
Emission Limits (lb./hr. gr./dscf. lb./MMBtu. % opacity, etc.):
The emissions from this emission point shall not exceed the following specified levels.
Pollutant: Opacity
Emission Limit(s): 40 %
Authority for Requirement: 567 IAC 23.3(2)"d"
Pollutant: Particulate Matter (TSP)
Emission Limit(s): 15.3 lb./MMCF of LPG or Natural Gas
Authority for Requirement: Part 7a. of State of Iowa, ex rel., Iowa DNR vs. Vermeer
Manufacturing Company, 99AG23542
District Court, Marion County, Law No. LACV087889
Pollutant: Particulate Matter (TSP)
Emission Limits: 0.8 lb./MMBtu
Authority for Requirement: 567 IAC 23.3(2)"b"
Pollutant: Sulfur Dioxide (SO2)
Emission Limits: 500 ppmv
Authority for Requirement: 567 IAC 23.3(3)"e"
Pollutant: Nitrogen Oxides (NOx)
Emission Limit(s): See Facility-Wide Conditions
Authority for Requirement: Iowa DNR Construction Permit 98-A-003-S1
Pollutant: Volatile Organic Compounds (VOC)
Emission Limit: See Facility-Wide Conditions
Authority for Requirement: Iowa DNR Construction Permit 98-A-003-S1
417
-------
Operational Limits & Requirements:
The owner/operator of this equipment shall comply with the following operational limits
and requirements.
Process throughput:
A. The sulfur content of natural gas or LPG combusted by this source is not to
exceed 123 ppm by weight.
Reporting & Recordkeeping: See Facility-Wide Operational Limits
Authority for Requirement: Part 7b. of State of Iowa, ex rel., Iowa DNR vs. Vermeer
Manufacturing Company, 99AG23542
District Court, Marion County, Law No. LACV087889
Compliance Plan:
The owner/operator of this equipment shall comply with the following applicable
requirements.
This point is in compliance with all applicable requirements and shall continue to comply
with all such requirements. For those applicable requirements which will become
effective during the permit term, this source will comply with such requirements in a
timely manner.
Periodic Monitoring Requirements:
The owner/operator of this equipment shall comply with the following periodic
monitoring requirements.
Agency Approved Operation & Maintenance Plan Required? Yes ~ No IXI
Facility Maintained Operation & Maintenance Plan Required? Yes ~ No Kl
Authority for Requirement: 567 IAC 22.108(3)"b"
418
-------
Emission Point ID Number: 6.RR
Associated Equipment
Associated Emission Unit ID Numbers (if multiple units vent thru this EP): 6.RR
Applicable Requirements
(If more than one emission unit vents through this emission point subdivide the applicable requirements by emission
unit.)
Emission Unit vented through this Emission Point: 6.RR
Emission Unit Description: Stage 1 Burner
Raw Material/Fuel: Natural Gas
Rated Capacity: 3.8 MMBtu/hr.
Emission Limits (lb./hr. gr./dscf. lb./MMBtu. % opacity, etc.):
The emissions from this emission point shall not exceed the following specified levels.
Pollutant: Opacity
Emission Limit(s): 40 %
Authority for Requirement: 567 IAC 23.3(2)"d"
Pollutant: Particulate Matter (TSP)
Emission Limit(s): 15.3 lb./MMCF of LPG or Natural Gas
Authority for Requirement: Part 7a. of State of Iowa, ex rel., Iowa DNR vs. Vermeer
Manufacturing Company, 99AG23542
District Court, Marion County, Law No. LACV087889
Pollutant: Particulate Matter (TSP)
Emission Limits: 0.8 lb./MMBtu
Authority for Requirement: 567 IAC 23.3(2)"b"
Pollutant: Sulfur Dioxide (SO2)
Emission Limits: 500 ppmv
Authority for Requirement: 567 IAC 23.3(3)"e"
Pollutant: Nitrogen Oxides (NOx)
Emission Limit(s): See Facility-Wide Conditions
Authority for Requirement: Iowa DNR Construction Permit 98-A-003-S1
Pollutant: Volatile Organic Compounds (VOC)
Emission Limit: See Facility-Wide Conditions
Authority for Requirement: Iowa DNR Construction Permit 98-A-003-S1
419
-------
Operational Limits & Requirements:
The owner/operator of this equipment shall comply with the following operational limits
and requirements.
Supplemental Environmental Project:
Equipment parameters:
As part of a multi-stage washer system the emission unit associated with this
emission point will consist of a 3.8 MMBtu/hr. heater for the hot alkaline washer
system in Stage 1. An extended drain zone will be provided to prevent chemical drag
out to the second stage, a clean water rinse. A power and free conveyer system will
be utilized to supply parts to and from the washer system. The entire washer system
shall be approximately 150 feet long, 8 to 10 feet wide, and constructed of mild and
stainless steel.
Authority for Requirement: Paragraph 3d. of State of Iowa, ex rel., Iowa DNR vs.
Vermeer Manufacturing Company, 99AG23542
District Court, Marion County, Law No. LACV087889
Operational term: This SEP will be maintained for the life of this permit.
Authority for Requirement: Paragraph 3i. of State of Iowa, ex rel., Iowa DNR vs.
Vermeer Manufacturing Company, 99AG23542
District Court, Marion County, Law No. LACV087889
Reporting & Record keeping:
Vermeer shall submit to the DNR an annual performance report covering the required
period of use and maintenance of this SEP documenting the actual use and
maintenance of this SEP. The reports shall be submitted on or before March 1, for the
preceding calendar year, commencing on March 1, 1999.
Authority for Requirement: Paragraph 3j. of State of Iowa, ex rel., Iowa DNR vs.
Vermeer Manufacturing Company, 99AG23542
District Court, Marion County, Law No. LACV087889
Process throughput:
A. The sulfur content of natural gas or LPG combusted by this source is not to
exceed 123 ppm by weight.
Reporting & Recordkeeping: See Facility-Wide Operational Limits
Authority for Requirement: Part 7b. of State of Iowa, ex rel., Iowa DNR vs. Vermeer
Manufacturing Company, 99AG23542
District Court, Marion County, Law No. LACV087889
Compliance Plan:
The owner/operator of this equipment shall comply with the following applicable
requirements.
This point is in compliance with all applicable requirements and shall continue to comply
with all such requirements. For those applicable requirements which will become
effective during the permit term, this source will comply with such requirements in a
timely manner.
420
-------
Periodic Monitoring Requirements:
The owner/operator of this equipment shall comply with the following periodic
monitoring requirements.
Agency Approved Operation & Maintenance Plan Required? Yes ~ No Kl
Facility Maintained Operation & Maintenance Plan Required? Yes ~ No Kl
Authority for Requirement: 567 IAC 22.108(3)"b"
421
-------
Emission Point ID Number: 6.S
Associated Equipment
Associated Emission Unit ID Numbers (if multiple units vent thru this EP): 6. S
Emissions Control Equipment ID Number: 6.S
Emissions Control Equipment Description: Paper Filter
Applicable Requirements
(If more than one emission unit vents through this emission point subdivide the applicable requirements by emission
unit.)
Emission Unit vented through this Emission Point: 6.S
Emission Unit Description: Finish Paint Booth
Raw Material/Fuel: Paints, Primers, and Solvents
Rated Capacity: 15 gal./hr.
Emission Limits (lb./hr. gr./dscf. lb./MMBtu. % opacity, etc.):
The emissions from this emission point shall not exceed the following specified levels.
Pollutant: Opacity
Emission Limits: 40%
Indicator Opacity: (1)
(1) If visible emissions are observed other than startup, shutdown or malfunction, a stack
test may be required to demonstrate compliance with the particulate standard.
Authority for Requirement: Iowa DNR Construction Permit 96-A-1216-S4
567 IAC23.3(2)"d"
Pollutant: Particulate Matter (TSP)
Emission Limit(s): 0.01 gr./dscf
Authority for Requirement: Iowa DNR Construction Permit 96-A-1216-S4
567 IAC 23.4(13)
Pollutant: Volatile Organic Compounds (VOC)
Emission Limit: See Facility-Wide Conditions
Authority for Requirement: Iowa DNR Construction Permit 96-A-1216-S4
Compliance Plan:
The owner/operator of this equipment shall comply with the following applicable
requirements.
This point is in compliance with all applicable requirements and shall continue to comply
with all such requirements. For those applicable requirements which will become
effective during the permit term, this source will comply with such requirements in a
timely manner.
422
-------
Additional Requirements:
This emission point shall conform to the following conditions.
The source is to be connected to the stack of the following detailed description.
Stack Height (feet): 44.5
Stack Diameter (inches): 42.0
Stack Exhaust Flow Rate (acfm): .... 20,000
Stack Temperature (°F): 70
Vertical, Unobstructed Discharge Required: Yes E No ~
Authority for Requirement: Iowa DNR Construction Permit 96-A-1216-S4
Periodic Monitoring Requirements:
The owner/operator of this equipment shall comply with the following periodic
monitoring requirements.
Opacity Monitoring:
The facility shall observe the opacity weekly during a period when the emission unit
associated with this emission point is at or near full capacity and record the reading
indicating if visible emissions were observed. The records shall be maintained for five
years. If weather conditions prevent the observer from conducting an opacity
observation, the observer shall note such conditions on the data observation sheet. At
least three attempts shall be made to retake opacity readings at approximately 2-hour
intervals throughout the day. If all observation attempts for a week have been
unsuccessful due to weather, an observation shall be made the next operating day where
weather permits.
Maintain a written record of the observation and any action resulting from the
observation.
Agency Approved Operation & Maintenance Plan Required? Yes ~ No Kl
Facility Maintained Operation & Maintenance Plan Required? Yes Kl NoQ
Facility operation and maintenance plans must be sufficient to yield reliable data from
the relevant time period that are representative of the source's compliance with the
applicable requirements.
Facility operation and maintenance plans are to be developed by the facility within six(6)
months of the issuance date of this permit and the data pertaining to the plan maintained
on site for at least 5 years. The plan and associated recordkeeping provides
documentation of this facility's implementation of its obligation to operate according to
good air pollution control practice.
Good air pollution control practice is achieved by adoption of quality control standards
in the operation and maintenance procedures for air pollution control that are
comparable to industry quality control standards for the production processes associated
with this emission point.
Authority for Requirement: 567 IAC 22.108(3)"b"
423
-------
Emission Point ID Number: 6.SS
Associated Equipment
Associated Emission Unit ID Numbers (if multiple units vent thru this EP): 6. SS
Applicable Requirements
(If more than one emission unit vents through this emission point subdivide the applicable requirements by emission
unit.)
Emission Unit vented through this Emission Point: 6.SS
Emission Unit Description: Stage 3 Burner
Raw Material/Fuel: Natural Gas
Rated Capacity: 2.5 MMBtu/hr.
Emission Limits (lb./hr. gr./dscf. lb./MMBtu. % opacity, etc.):
The emissions from this emission point shall not exceed the following specified levels.
Pollutant: Opacity
Emission Limit(s): 40 %
Authority for Requirement: 567 IAC 23.3(2)"d"
Pollutant: Particulate Matter (TSP)
Emission Limit(s): 15.3 lb./MMCF of LPG or Natural Gas
Authority for Requirement: Part 7a. of State of Iowa, ex rel., Iowa DNR vs. Vermeer
Manufacturing Company, 99AG23542
District Court, Marion County, Law No. LACV087889
Pollutant: Particulate Matter (TSP)
Emission Limits: 0.8 lb./MMBtu
Authority for Requirement: 567 IAC 23.3(2)"b"
Pollutant: Sulfur Dioxide (SO2)
Emission Limits: 500 ppmv
Authority for Requirement: 567 IAC 23.3(3)"e"
Pollutant: Nitrogen Oxides (NOx)
Emission Limit(s): See Facility-Wide Conditions
Authority for Requirement: Iowa DNR Construction Permit 98-A-003-S1
Pollutant: Volatile Organic Compounds (VOC)
Emission Limit: See Facility-Wide Conditions
Authority for Requirement: Iowa DNR Construction Permit 98-A-003-S1
424
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Operational Limits & Requirements:
The owner/operator of this equipment shall comply with the following operational limits
and requirements.
Supplemental Environmental Project:
Equipment parameters:
As part of a multi-stage washer system the emission unit associated with this
emission point will consist of a 2.5 MMBtu/hr. heater for the hot iron phosphate
washer system in Stage 3. An extended drain zone will be provided to prevent
chemical drag out to the fourth stage, a clean water rinse. A power and free conveyer
system will be utilized to supply parts to and from the washer system. The entire
washer system shall be approximately 150 feet long, 8 to 10 feet wide, and
constructed of mild and stainless steel.
Authority for Requirement: Paragraph 3d. of State of Iowa, ex rel., Iowa DNR vs.
Vermeer Manufacturing Company, 99AG23542
District Court, Marion County, Law No. LACV087889
Operational term: This SEP will be maintained for the life of this permit.
Authority for Requirement: Paragraph 3i. of State of Iowa, ex rel., Iowa DNR vs.
Vermeer Manufacturing Company, 99AG23542
District Court, Marion County, Law No. LACV087889
Reporting & Record keeping:
Vermeer shall submit to the DNR an annual performance report covering the required
period of use and maintenance of this SEP documenting the actual use and
maintenance of this SEP. The reports shall be submitted on or before Marchl, for the
preceding calendar year, commencing on March 1, 1999.
Authority for Requirement: Paragraph 3j. of State of Iowa, ex rel., Iowa DNR vs.
Vermeer Manufacturing Company, 99AG23542
District Court, Marion County, Law No. LACV087889
Process throughput:
A. The sulfur content of natural gas or LPG combusted by this source is not to
exceed 123 ppm by weight.
Reporting & Recordkeeping: See Facility-Wide Operational Limits
Authority for Requirement: Part 7b. of State of Iowa, ex rel., Iowa DNR vs. Vermeer
Manufacturing Company, 99AG23542
District Court, Marion County, Law No. LACV087889
Compliance Plan:
The owner/operator of this equipment shall comply with the following applicable
requirements.
This point is in compliance with all applicable requirements and shall continue to comply
with all such requirements. For those applicable requirements which will become
effective during the permit term, this source will comply with such requirements in a
timely manner.
425
-------
Periodic Monitoring Requirements:
The owner/operator of this equipment shall comply with the following periodic
monitoring requirements.
Agency Approved Operation & Maintenance Plan Required? Yes ~ No Kl
Facility Maintained Operation & Maintenance Plan Required? Yes ~ No Kl
Authority for Requirement: 567 IAC 22.108(3)"b"
426
-------
Emission Point ID Number: 6.T
Associated Equipment
Associated Emission Unit ID Numbers (if multiple units vent thru this EP): 6.T
Applicable Requirements
(If more than one emission unit vents through this emission point subdivide the applicable requirements by emission
unit.)
Emission Unit vented through this Emission Point: 6.T
Emission Unit Description: Non-Production Heating Unit
Raw Material/Fuel: Natural Gas
Rated Capacity: 0.12 MMBtu/hr.
Emission Limits (lb./hr. gr./dscf. lb./MMBtu. % opacity, etc.):
The emissions from this emission point shall not exceed the following specified levels.
Pollutant: Opacity
Emission Limit(s): 40 %
Authority for Requirement: 567 IAC 23.3(2)"d"
Pollutant: Particulate Matter (TSP)
Emission Limit(s): 15.3 lb./MMCF of LPG or Natural Gas
Authority for Requirement: Part 7a. of State of Iowa, ex rel., Iowa DNR vs. Vermeer
Manufacturing Company, 99AG23542
District Court, Marion County, Law No. LACV087889
Pollutant: Particulate Matter (TSP)
Emission Limits: 0.8 lb./MMBtu
Authority for Requirement: 567 IAC 23.3(2)"b"
Pollutant: Sulfur Dioxide (SO2)
Emission Limits: 500 ppmv
Authority for Requirement: 567 IAC 23.3(3)"e"
Pollutant: Nitrogen Oxides (NOx)
Emission Limit(s): See Facility-Wide Conditions
Authority for Requirement: Iowa DNR Construction Permit 98-A-003-S1
Pollutant: Volatile Organic Compounds (VOC)
Emission Limit: See Facility-Wide Conditions
Authority for Requirement: Iowa DNR Construction Permit 98-A-003-S1
427
-------
Operational Limits & Requirements:
The owner/operator of this equipment shall comply with the following operational limits
and requirements.
Process throughput:
A. The sulfur content of natural gas or LPG combusted by this source is not to
exceed 123 ppm by weight.
Reporting & Recordkeeping: See Facility-Wide Operational Limits
Authority for Requirement: Part 7b. of State of Iowa, ex rel., Iowa DNR vs. Vermeer
Manufacturing Company, 99AG23542
District Court, Marion County, Law No. LACV087889
Compliance Plan:
The owner/operator of this equipment shall comply with the following applicable
requirements.
This point is in compliance with all applicable requirements and shall continue to comply
with all such requirements. For those applicable requirements which will become
effective during the permit term, this source will comply with such requirements in a
timely manner.
Periodic Monitoring Requirements:
The owner/operator of this equipment shall comply with the following periodic
monitoring requirements.
Agency Approved Operation & Maintenance Plan Required? Yes ~ No IXI
Facility Maintained Operation & Maintenance Plan Required? Yes ~ No Kl
Authority for Requirement: 567 IAC 22.108(3)"b"
428
-------
Emission Point ID Number: 6.TORCH
Associated Equipment
Associated Emission Unit ID Numbers (if multiple units vent thru this EP): 6.TORCH
Applicable Requirements
(If more than one emission unit vents through this emission point subdivide the applicable requirements by emission
unit.)
Emission Unit vented through this Emission Point: 6.TORCH (Fugitive)
Emission Unit Description: Ten (10) Single Cutting Head
Oxyacetylene Torch Units
Raw Material/Fuel: Sheet Steel
Rated Capacity: 840 inches of metal cut/hr. per Head
Emission Limits (lb./hr. gr./dscf. lb./MMBtu. % opacity, etc.):
The emissions from this emission point shall not exceed the following specified levels.
Pollutant: Fugitive Dust
Emission Limit: No person shall allow, cause or permit any materials to be handled,
transported or stored; or a building, its appurtenances or a construction haul road to
be used, constructed, altered , repaired or demolished, without taking reasonable
precautions to prevent a nuisance. All persons shall take reasonable precautions to
prevent the discharge of visible emissions of fugitive dusts beyond the lot line of the
property on which the emissions originate.
Authority for Requirement: 567 IAC 23.3(2)"c"
Compliance Plan:
The owner/operator of this equipment shall comply with the following applicable
requirements.
This point is in compliance with all applicable requirements and shall continue to comply
with all such requirements. For those applicable requirements which will become
effective during the permit term, this source will comply with such requirements in a
timely manner.
Periodic Monitoring Requirements:
The owner/operator of this equipment shall comply with the following periodic
monitoring requirements.
Agency Approved Operation & Maintenance Plan Required? Yes ~ No IXI
Facility Maintained Operation & Maintenance Plan Required? Yes ~ No Kl
Authority for Requirement: 567 IAC 22.108(3)"b"
429
-------
Emission Point ID Number: 6.TT
Associated Equipment
Associated Emission Unit ID Numbers (if multiple units vent thru this EP): 6.TT
Applicable Requirements
(If more than one emission unit vents through this emission point subdivide the applicable requirements by emission
unit.)
Emission Unit vented through this Emission Point: 6.TT
Emission Unit Description: Stage 5 Burner
Raw Material/Fuel: Natural Gas
Rated Capacity: 1.5 MMBtu/hr.
Emission Limits (lb./hr. gr./dscf. lb./MMBtu. % opacity, etc.):
The emissions from this emission point shall not exceed the following specified levels.
Pollutant: Opacity
Emission Limit(s): 40 %
Authority for Requirement: 567 IAC 23.3(2)"d"
Pollutant: Particulate Matter (TSP)
Emission Limit(s): 15.3 lb./MMCF of LPG or Natural Gas
Authority for Requirement: Part 7a. of State of Iowa, ex rel., Iowa DNR vs. Vermeer
Manufacturing Company, 99AG23542
District Court, Marion County, Law No. LACV087889
Pollutant: Particulate Matter (TSP)
Emission Limits: 0.8 lb./MMBtu
Authority for Requirement: 567 IAC 23.3(2)"b"
Pollutant: Sulfur Dioxide (SO2)
Emission Limits: 500 ppmv
Authority for Requirement: 567 IAC 23.3(3)"e"
Pollutant: Nitrogen Oxides (NOx)
Emission Limit(s): See Facility-Wide Conditions
Authority for Requirement: Iowa DNR Construction Permit 98-A-003-S1
Pollutant: Volatile Organic Compounds (VOC)
Emission Limit: See Facility-Wide Conditions
Authority for Requirement: Iowa DNR Construction Permit 98-A-003-S1
430
-------
Operational Limits & Requirements:
The owner/operator of this equipment shall comply with the following operational limits
and requirements.
Supplemental Environmental Project:
Equipment parameters:
As part of a multi-stage washer system the emission unit associated with this
emission point will consist of a 1.5 MMBtu/hr. heater for the hot metal sealer washer
system in Stage 5. A power and free conveyer system will be utilized to supply parts
to and from the washer system. The entire washer system shall be approximately 150
feet long, 8 to 10 feet wide, and constructed of mild and stainless steel.
Authority for Requirement: Paragraph 3d. of State of Iowa, ex rel., Iowa DNR vs.
Vermeer Manufacturing Company, 99AG23542
District Court, Marion County, Law No. LACV087889
Operational term: This SEP will be maintained for the life of this permit.
Authority for Requirement: Paragraph 3i. of State of Iowa, ex rel., Iowa DNR vs.
Vermeer Manufacturing Company, 99AG23542
District Court, Marion County, Law No. LACV087889
Reporting & Record keeping:
Vermeer shall submit to the DNR an annual performance report covering the required
period of use and maintenance of this SEP documenting the actual use and
maintenance of this SEP. The reports shall be submitted on or before March 1, for the
preceding calendar year, commencing on March 1, 1999.
Authority for Requirement: Paragraph 3j. of State of Iowa, ex rel., Iowa DNR vs.
Vermeer Manufacturing Company, 99AG23542
District Court, Marion County, Law No. LACV087889
Process throughput:
A. The sulfur content of natural gas or LPG combusted by this source is not to
exceed 123 ppm by weight.
Reporting & Recordkeeping: See Facility-Wide Operational Limits
Authority for Requirement: Part 7b. of State of Iowa, ex rel., Iowa DNR vs. Vermeer
Manufacturing Company, 99AG23542
District Court, Marion County, Law No. LACV087889
Compliance Plan:
The owner/operator of this equipment shall comply with the following applicable
requirements.
This point is in compliance with all applicable requirements and shall continue to comply
with all such requirements. For those applicable requirements which will become
effective during the permit term, this source will comply with such requirements in a
timely manner.
Periodic Monitoring Requirements:
The owner/operator of this equipment shall comply with the following periodic
monitoring requirements.
431
-------
Agency Approved Operation & Maintenance Plan Required? Yes ~ No Kl
Facility Maintained Operation & Maintenance Plan Required? Yes ~ No Kl
Authority for Requirement: 567 IAC 22.108(3)"b"
432
-------
Emission Point ID Number: 6.UU
Associated Equipment
Associated Emission Unit ID Numbers (if multiple units vent thru this EP): 6.UU
Applicable Requirements
(If more than one emission unit vents through this emission point subdivide the applicable requirements by emission
unit.)
Emission Unit vented through this Emission Point: 6.UU
Emission Unit Description: Stage 5 Washer
Raw Material/Fuel: Hot Metal Sealer
Rated Capacity: 300 gal./hr.
Emission Limits (lb./hr. gr./dscf. lb./MMBtu. % opacity, etc.):
The emissions from this emission point shall not exceed the following specified levels.
Pollutant: Opacity
Emission Limit(s): 40 %
Authority for Requirement: 567 IAC 23.3(2)"d"
Pollutant:
Emission Limit(s):
Authority for Requirement:
Particulate Matter (TSP)
0.01 gr./dscf
567 IAC 23.4(13)
Operational Limits & Requirements:
The owner/operator of this equipment shall comply with the following operational limits
and requirements.
Supplemental Environmental Project:
Equipment parameters:
As part of a multi-stage washer system the emission unit associated with this
emission point will consist of a heated metal sealing solution utilizing a sequenced
manifold of spray nozzle tips to prepare the surface of the metal parts for
polyurethane coating. A power and free conveyer system will be utilized to supply
parts to and from the washer system. The entire washer system shall be
approximately 150 feet long, 8 to 10 feet wide, and constructed of mild and stainless
steel.
Authority for Requirement: Paragraph 3d. of State of Iowa, ex rel., Iowa DNR vs.
Vermeer Manufacturing Company, 99AG23542
District Court, Marion County, Law No. LACV087889
Operational term: This SEP will be maintained for the life of this permit.
Authority for Requirement: Paragraph 3i. of State of Iowa, ex rel., Iowa DNR vs.
Vermeer Manufacturing Company, 99AG23542
District Court, Marion County, Law No. LACV087889
433
-------
Operational Limits & Requirements (continued):
Reporting & Record keeping:
Vermeer shall submit to the DNR an annual performance report covering the required
period of use and maintenance of this SEP documenting the actual use and
maintenance of this SEP. The reports shall be submitted on or before March 1, for the
preceding calendar year, commencing on March 1, 1999.
Authority for Requirement: Paragraph 3j. of State of Iowa, ex rel., Iowa DNR vs.
Vermeer Manufacturing Company, 99AG23542
District Court, Marion County, Law No. LACV087889
Compliance Plan:
The owner/operator of this equipment shall comply with the following applicable
requirements.
This point is in compliance with all applicable requirements and shall continue to comply
with all such requirements. For those applicable requirements which will become
effective during the permit term, this source will comply with such requirements in a
timely manner.
Periodic Monitoring Requirements:
The owner/operator of this equipment shall comply with the following periodic
monitoring requirements.
Agency Approved Operation & Maintenance Plan Required? Yes ~ No Kl
Facility Maintained Operation & Maintenance Plan Required? Yes ~ No Kl
Authority for Requirement: 567 IAC 22.108(3)"b"
434
-------
Emission Point ID Number: 6.VV
Associated Equipment
Associated Emission Unit ID Numbers (if multiple units vent thru this EP): 6. VV
Applicable Requirements
(If more than one emission unit vents through this emission point subdivide the applicable requirements by emission
unit.)
Emission Units vented through this Emission Point: 6. VV
Emission Unit Description: Paint Kitchen
Raw Material/Fuel: Paints, Primers, and Solvents
Rated Capacity: 3 Barrels
Emission Limits (lb./hr. gr./dscf. lb./MMBtu. % opacity, etc.):
The emissions from this emission point shall not exceed the following specified levels.
Pollutant: Volatile Organic Compounds (VOC)
Emission Limit: See Facility-Wide Conditions
Authority for Requirement: Iowa DNR Construction Permit 98-A-155-S2
Compliance Plan:
The owner/operator of this equipment shall comply with the following applicable
requirements.
This point is in compliance with all applicable requirements and shall continue to comply
with all such requirements. For those applicable requirements which will become
effective during the permit term, this source will comply with such requirements in a
timely manner.
Additional Requirements:
This emission point shall conform to the following conditions.
The source is to be connected to the stack of the following detailed description.
Stack Height (feet): 41
Stack Diameter (inches): 15
Stack Exhaust Flow Rate (acfm): .... 3,500
Stack Temperature (°F): 70
Vertical, Unobstructed Discharge Required: Yes ^ No ~
Authority for Requirement: Iowa DNR Construction Permit 98-A-155-S2
435
-------
Periodic Monitoring Requirements:
The owner/operator of this equipment shall comply with the following periodic
monitoring requirements.
Agency Approved Operation & Maintenance Plan Required? Yes ~ No Kl
Facility Maintained Operation & Maintenance Plan Required? Yes ~ No Kl
Authority for Requirement: 567 IAC 22.108(3)"b"
436
-------
Emission Point ID Number: 6.W
Associated Equipment
Associated Emission Unit ID Numbers (if multiple units vent thru this EP): 6. W
Applicable Requirements
(If more than one emission unit vents through this emission point subdivide the applicable requirements by emission
unit.)
Emission Unit vented through this Emission Point: 6.W
Emission Unit Description: Paint Oven
Raw Material/Fuel: Natural Gas
Rated Capacity: 2.92 MMBtu/hr.
Emission Limits (lb./hr. gr./dscf. lb./MMBtu. % opacity, etc.):
The emissions from this emission point shall not exceed the following specified levels.
Pollutant: Opacity
Emission Limits: 40%
Indicator Opacity: (1)
(1) If visible emissions are observed other than startup, shutdown or malfunction, a stack
test may be required to demonstrate compliance with the particulate standard.
Authority for Requirement: Iowa DNR Construction Permit 97-A-298-S3
567 IAC 23.3(2)"d"
Pollutant: Particulate Matter (TSP)
Emission Limit(s): 15.3 lb./MMCF of LPG or Natural Gas
Authority for Requirement: Part 7a. of State of Iowa, ex rel., Iowa DNR vs. Vermeer
Manufacturing Company, 99AG23542
District Court, Marion County, Law No. LACV087889
Pollutant: Particulate Matter (TSP)
Emission Limits: 0.1 gr./dscf
Authority for Requirement: Iowa DNR Construction Permit 97-A-298-S3
567 IAC 23.3(2)"a"
Pollutant: Sulfur Dioxide (SO2)
Emission Limits: 500 ppmv
Authority for Requirement: 567 IAC 23.3(3)"e"
Pollutant: Nitrogen Oxides (NOx)
Emission Limit(s): See Facility-Wide Conditions
Authority for Requirement: Iowa DNR Construction Permit 97-A-298-S3
437
-------
Emission Limits (continued):
Pollutant: Volatile Organic Compounds (VOC)
Emission Limit: See Facility-Wide Conditions
Authority for Requirement: Iowa DNR Construction Permit 97-A-298-S3
Operational Limits & Requirements:
The owner/operator of this equipment shall comply with the following operational limits
and requirements.
Process throughput:
A. This oven shall be fired by natural gas or propane only.
Reporting & Recordkeeping: See Facility-Wide Operational Limits
Authority for Requirement: Iowa DNR Construction Permit 97-A-298-S3
Process throughput:
A. The sulfur content of natural gas or LPG combusted by this source is not to
exceed 123 ppm by weight.
Reporting & Recordkeeping: See Facility-Wide Operational Limits
Authority for Requirement: Part 7b. of State of Iowa, ex rel., Iowa DNR vs. Vermeer
Manufacturing Company, 99AG23542
District Court, Marion County, Law No. LACV087889
Compliance Plan:
The owner/operator of this equipment shall comply with the following applicable
requirements.
This point is in compliance with all applicable requirements and shall continue to comply
with all such requirements. For those applicable requirements which will become
effective during the permit term, this source will comply with such requirements in a
timely manner.
Additional Requirements:
This emission point shall conform to the following conditions.
The source is to be connected to the stack of the following detailed description.
Stack Height (feet): 28.6
Stack Diameter (inches): 11.0
Stack Exhaust Flow Rate (acfm): .... 27,729
Stack Temperature (°F): 450
Vertical, Unobstructed Discharge Required: Yes ^ No ~
Authority for Requirement: Iowa DNR Construction Permit 97-A-298-S3
438
-------
Periodic Monitoring Requirements:
The owner/operator of this equipment shall comply with the following periodic
monitoring requirements.
Opacity Monitoring:
The facility shall observe the opacity weekly during a period when the emission unit
associated with this emission point is at or near full capacity and record the reading
indicating if visible emissions were observed. The records shall be maintained for five
years. If weather conditions prevent the observer from conducting an opacity
observation, the observer shall note such conditions on the data observation sheet. At
least three attempts shall be made to retake opacity readings at approximately 2-hour
intervals throughout the day. If all observation attempts for a week have been
unsuccessful due to weather, an observation shall be made the next operating day where
weather permits.
Maintain a written record of the observation and any action resulting from the
observation.
Agency Approved Operation & Maintenance Plan Required? Yes ~ No IEI
Facility Maintained Operation & Maintenance Plan Required? Yes ~ No Kl
Authority for Requirement: 567 IAC 22.108(3)"b"
439
-------
Emission Point ID Number: 6.WW
Associated Equipment
Associated Emission Unit ID Numbers (if multiple units vent thru this EP): 6. WW
Applicable Requirements
(If more than one emission unit vents through this emission point subdivide the applicable requirements by emission
unit.)
Emission Unit vented through this Emission Point: 6.WW
Emission Unit Description: Paint Kitchen
Raw Material/Fuel: Paints, Primers, and Solvents
Rated Capacity: 3 Barrels
Emission Limits (lb./hr. gr./dscf. lb./MMBtu. % opacity, etc.):
The emissions from this emission point shall not exceed the following specified levels.
Pollutant: Volatile Organic Compounds (VOC)
Emission Limit: See Facility-Wide Conditions
Authority for Requirement: Iowa DNR Construction Permit 98-A-858-S1
Compliance Plan:
The owner/operator of this equipment shall comply with the following applicable
requirements.
This point is in compliance with all applicable requirements and shall continue to comply
with all such requirements. For those applicable requirements which will become
effective during the permit term, this source will comply with such requirements in a
timely manner.
Additional Requirements:
This emission point shall conform to the following conditions.
The source is to be connected to the stack of the following detailed description.
Stack Height (feet): 41
Stack Diameter (inches): 15
Stack Exhaust Flow Rate (acfm): .... 3,500
Stack Temperature (°F): 70
Vertical, Unobstructed Discharge Required: Yes ^ No ~
Authority for Requirement: Iowa DNR Construction Permit 98-A-858-S1
440
-------
Periodic Monitoring Requirements:
The owner/operator of this equipment shall comply with the following periodic
monitoring requirements.
Agency Approved Operation & Maintenance Plan Required? Yes ~ No Kl
Facility Maintained Operation & Maintenance Plan Required? Yes ~ No Kl
Authority for Requirement: 567 IAC 22.108(3)"b"
441
-------
Emission Point ID Number: 6.WELDING
Associated Equipment
Associated Emission Unit ID Numbers (if multiple units vent thru this EP): 6. WELDING
Applicable Requirements
(If more than one emission unit vents through this emission point subdivide the applicable requirements by emission
unit.)
Emission Unit vented through this Emission Point: 6.WELDING (Fugitive)
Emission Unit Description: 19 GMAW Units
Raw Material/Fuel: E70S Weld Wire
Rated Capacity: 19 lb. ofWire/hr. per Unit
Emission Limits (lb./hr. gr./dscf. lb./MMBtu. % opacity, etc.):
The emissions from this emission point shall not exceed the following specified levels.
Pollutant: Fugitive Dust
Emission Limit: No person shall allow, cause or permit any materials to be handled,
transported or stored; or a building, its appurtenances or a construction haul road to
be used, constructed, altered , repaired or demolished, without taking reasonable
precautions to prevent a nuisance. All persons shall take reasonable precautions to
prevent the discharge of visible emissions of fugitive dusts beyond the lot line of the
property on which the emissions originate.
Authority for Requirement: 567 IAC 23.3(2)"c"
Compliance Plan:
The owner/operator of this equipment shall comply with the following applicable
requirements.
This point is in compliance with all applicable requirements and shall continue to comply
with all such requirements. For those applicable requirements which will become
effective during the permit term, this source will comply with such requirements in a
timely manner.
Periodic Monitoring Requirements:
The owner/operator of this equipment shall comply with the following periodic
monitoring requirements.
Agency Approved Operation & Maintenance Plan Required? Yes ~ No Kl
Facility Maintained Operation & Maintenance Plan Required? Yes ~ No Kl
Authority for Requirement: 567 IAC 22.108(3)"b"
442
-------
Emission Point ID Number: 6.WELDPLS
Associated Equipment
Associated Emission Unit ID Numbers (if multiple units vent thru this EP): 6. WELDPLS
Applicable Requirements
(If more than one emission unit vents through this emission point subdivide the applicable requirements by emission
unit.)
Emission Unit vented through this Emission Point: 6.WELDPLS (Fugitive)
Emission Unit Description: 10 Pulse Current GMAW Units
Raw Material/Fuel: E70S Weld Wire
Rated Capacity: 19 lb. ofWire/hr. per Unit
Emission Limits (lb./hr. gr./dscf. lb./MMBtu. % opacity, etc.):
The emissions from this emission point shall not exceed the following specified levels.
Pollutant: Fugitive Dust
Emission Limit: No person shall allow, cause or permit any materials to be handled,
transported or stored; or a building, its appurtenances or a construction haul road to
be used, constructed, altered , repaired or demolished, without taking reasonable
precautions to prevent a nuisance. All persons shall take reasonable precautions to
prevent the discharge of visible emissions of fugitive dusts beyond the lot line of the
property on which the emissions originate.
Authority for Requirement: 567 IAC 23.3(2)"c"
Compliance Plan:
The owner/operator of this equipment shall comply with the following applicable
requirements.
This point is in compliance with all applicable requirements and shall continue to comply
with all such requirements. For those applicable requirements which will become
effective during the permit term, this source will comply with such requirements in a
timely manner.
Periodic Monitoring Requirements:
The owner/operator of this equipment shall comply with the following periodic
monitoring requirements.
Agency Approved Operation & Maintenance Plan Required? Yes ~ No Kl
Facility Maintained Operation & Maintenance Plan Required? Yes ~ No Kl
Authority for Requirement: 567 IAC 22.108(3)"b"
443
-------
Emission Point ID Number: 6.XX
Associated Equipment
Associated Emission Unit ID Numbers (if multiple units vent thru this EP): 6.XX
Applicable Requirements
(If more than one emission unit vents through this emission point subdivide the applicable requirements by emission
unit.)
Emission Unit vented through this Emission Point: 6.XX
Emission Unit Description: Production Engine Testing Unit
Raw Material/Fuel: #2 Diesel Fuel and Gasoline
Rated Capacity: 60.6 gal./hr.
Emission Limits (lb./hr. gr./dscf. lb./MMBtu. % opacity, etc.):
The emissions from this emission point shall not exceed the following specified levels.
Pollutant: Opacity
Emission Limits: 40%
Indicator Opacity: 25%(1)
(1) If visible emissions are observed that exceed the indicator opacity other than startup,
shutdown or malfunction, a stack test may be required to demonstrate compliance with
the particulate standard.
Authority for Requirement: Iowa DNR Construction Permit 98-A-864-S2
567 IAC 23.3(2)"d"
Pollutant: Particulate Matter (TSP)
Emission Limits: 0.1 gr./dscf
Authority for Requirement: Iowa DNR Construction Permit 98-A-864-S2
567 IAC 23.3(2)"a"
Pollutant: Sulfur Dioxide (SO2)
Emission Limits: 2.5 lb./MMBtu
Authority for Requirement: Iowa DNR Construction Permit 98-A-864-S2
567 IAC 23.3(3)"b"
Pollutant: Nitrogen Oxides (NOx)
Emission Limit(s): See Facility-Wide Conditions
Authority for Requirement: Iowa DNR Construction Permit 98-A-864-S2
Pollutant: Volatile Organic Compounds (VOC)
Emission Limit: See Facility-Wide Conditions
Authority for Requirement: Iowa DNR Construction Permit 98-A-864-S2
444
-------
Operational Limits & Requirements:
The owner/operator of this equipment shall comply with the following operational limits
and requirements.
Process Throughput:
A. The sulfur content of any diesel fuel used in this source shall not exceed 0.4% by
weight.
Reporting & Recordkeeping: See Facility-Wide Emission and Operational Limits
Authority for Requirement: Iowa DNR Construction Permit 98-A-864-S2
Compliance Plan:
The owner/operator of this equipment shall comply with the following applicable
requirements.
This point is in compliance with all applicable requirements and shall continue to comply
with all such requirements. For those applicable requirements which will become
effective during the permit term, this source will comply with such requirements in a
timely manner.
Additional Requirements:
This emission point shall conform to the following conditions.
The source is to be connected to the stack of the following detailed description.
Stack Height (feet): 38
Stack Diameter (inches): 12
Stack Exhaust Flow Rate (acfm): .... 7,387
Stack Temperature (°F): 845
Vertical, Unobstructed Discharge Required: Yes ~ No
Authority for Requirement: Iowa DNR Construction Permit 98-A-864-S2
Periodic Monitoring Requirements:
The owner/operator of this equipment shall comply with the following periodic
monitoring requirements.
Opacity Monitoring:
The facility shall observe the opacity weekly during a period when the emission unit
associated with this emission point is at or near full capacity and record the reading
indicating if visible emissions were observed. The records shall be maintained for five
years. If weather conditions prevent the observer from conducting an opacity
observation, the observer shall note such conditions on the data observation sheet. At
least three attempts shall be made to retake opacity readings at approximately 2-hour
intervals throughout the day. If all observation attempts for a week have been
unsuccessful due to weather, an observation shall be made the next operating day where
weather permits.
Maintain a written record of the observation and any action resulting from the
observation.
E
445
-------
Agency Approved Operation & Maintenance Plan Required? Yes ~ No Kl
Facility Maintained Operation & Maintenance Plan Required? Yes ~ No Kl
Authority for Requirement: 567 IAC 22.108(3)"b"
446
-------
Emission Point ID Number: 7.B1
Associated Equipment
Associated Emission Unit ID Numbers (if multiple units vent thru this EP): 7.B 1
Applicable Requirements
(If more than one emission unit vents through this emission point subdivide the applicable requirements by emission
unit.)
Emission Unit vented through this Emission Point: 7.B 1
Emission Unit Description: Non-Production Heating Unit
Raw Material/Fuel: Natural Gas
Rated Capacity: 0.16 MMBtu/hr.
Emission Limits (lb./hr. gr./dscf. lb./MMBtu. % opacity, etc.):
The emissions from this emission point shall not exceed the following specified levels.
Pollutant: Opacity
Emission Limit(s): 40 %
Authority for Requirement: 567 IAC 23.3(2)"d"
Pollutant: Particulate Matter (TSP)
Emission Limit(s): 15.3 lb./MMCF of LPG or Natural Gas
Authority for Requirement: Part 7a. of State of Iowa, ex rel., Iowa DNR vs. Vermeer
Manufacturing Company, 99AG23542
District Court, Marion County, Law No. LACV087889
Pollutant: Particulate Matter (TSP)
Emission Limits: 0.8 lb./MMBtu
Authority for Requirement: 567 IAC 23.3(2)"b"
Pollutant: Sulfur Dioxide (SO2)
Emission Limits: 500 ppmv
Authority for Requirement: 567 IAC 23.3(3)"e"
Pollutant: Nitrogen Oxides (NOx)
Emission Limit(s): See Facility-Wide Conditions
Authority for Requirement: Iowa DNR Construction Permit 98-A-003-S1
Pollutant: Volatile Organic Compounds (VOC)
Emission Limit: See Facility-Wide Conditions
Authority for Requirement: Iowa DNR Construction Permit 98-A-003-S1
447
-------
Operational Limits & Requirements:
The owner/operator of this equipment shall comply with the following operational limits
and requirements.
Process throughput:
A. The sulfur content of natural gas or LPG combusted by this source is not to
exceed 123 ppm by weight.
Reporting & Recordkeeping: See Facility-Wide Operational Limits
Authority for Requirement: Part 7b. of State of Iowa, ex rel., Iowa DNR vs. Vermeer
Manufacturing Company, 99AG23542
District Court, Marion County, Law No. LACV087889
Compliance Plan:
The owner/operator of this equipment shall comply with the following applicable
requirements.
This point is in compliance with all applicable requirements and shall continue to comply
with all such requirements. For those applicable requirements which will become
effective during the permit term, this source will comply with such requirements in a
timely manner.
Periodic Monitoring Requirements:
The owner/operator of this equipment shall comply with the following periodic
monitoring requirements.
Agency Approved Operation & Maintenance Plan Required? Yes ~ No IXI
Facility Maintained Operation & Maintenance Plan Required? Yes ~ No Kl
Authority for Requirement: 567 IAC 22.108(3)"b"
448
-------
Emission Point ID Number: 7.B2
Associated Equipment
Associated Emission Unit ID Numbers (if multiple units vent thru this EP): 7.B2
Applicable Requirements
(If more than one emission unit vents through this emission point subdivide the applicable requirements by emission
unit.)
Emission Unit vented through this Emission Point: 7.B2
Emission Unit Description: Non-Production Heating Unit
Raw Material/Fuel: Natural Gas
Rated Capacity: l.OMMBtu/hr.
Emission Limits (lb./hr. gr./dscf. lb./MMBtu. % opacity, etc.):
The emissions from this emission point shall not exceed the following specified levels.
Pollutant: Opacity
Emission Limit(s): 40 %
Authority for Requirement: 567 IAC 23.3(2)"d"
Pollutant: Particulate Matter (TSP)
Emission Limit(s): 15.3 lb./MMCF of LPG or Natural Gas
Authority for Requirement: Part 7a. of State of Iowa, ex rel., Iowa DNR vs. Vermeer
Manufacturing Company, 99AG23542
District Court, Marion County, Law No. LACV087889
Pollutant: Particulate Matter (TSP)
Emission Limits: 0.8 lb./MMBtu
Authority for Requirement: 567 IAC 23.3(2)"b"
Pollutant: Sulfur Dioxide (SO2)
Emission Limits: 500 ppmv
Authority for Requirement: 567 IAC 23.3(3)"e"
Pollutant: Nitrogen Oxides (NOx)
Emission Limit(s): See Facility-Wide Conditions
Authority for Requirement: Iowa DNR Construction Permit 98-A-003-S1
Pollutant: Volatile Organic Compounds (VOC)
Emission Limit: See Facility-Wide Conditions
Authority for Requirement: Iowa DNR Construction Permit 98-A-003-S1
449
-------
Operational Limits & Requirements:
The owner/operator of this equipment shall comply with the following operational limits
and requirements.
Process throughput:
A. The sulfur content of natural gas or LPG combusted by this source is not to
exceed 123 ppm by weight.
Reporting & Recordkeeping: See Facility-Wide Operational Limits
Authority for Requirement: Part 7b. of State of Iowa, ex rel., Iowa DNR vs. Vermeer
Manufacturing Company, 99AG23542
District Court, Marion County, Law No. LACV087889
Compliance Plan:
The owner/operator of this equipment shall comply with the following applicable
requirements.
This point is in compliance with all applicable requirements and shall continue to comply
with all such requirements. For those applicable requirements which will become
effective during the permit term, this source will comply with such requirements in a
timely manner.
Periodic Monitoring Requirements:
The owner/operator of this equipment shall comply with the following periodic
monitoring requirements.
Agency Approved Operation & Maintenance Plan Required? Yes ~ No IXI
Facility Maintained Operation & Maintenance Plan Required? Yes ~ No Kl
Authority for Requirement: 567 IAC 22.108(3)"b"
450
-------
Emission Point ID Number: 7.B3
Associated Equipment
Associated Emission Unit ID Numbers (if multiple units vent thru this EP): 7.B3
Applicable Requirements
(If more than one emission unit vents through this emission point subdivide the applicable requirements by emission
unit.)
Emission Unit vented through this Emission Point: 7.B3
Emission Unit Description: Non-Production Heating Unit
Raw Material/Fuel: Natural Gas
Rated Capacity: l.OMMBtu/hr.
Emission Limits (lb./hr. gr./dscf. lb./MMBtu. % opacity, etc.):
The emissions from this emission point shall not exceed the following specified levels.
Pollutant: Opacity
Emission Limit(s): 40 %
Authority for Requirement: 567 IAC 23.3(2)"d"
Pollutant: Particulate Matter (TSP)
Emission Limit(s): 15.3 lb./MMCF of LPG or Natural Gas
Authority for Requirement: Part 7a. of State of Iowa, ex rel., Iowa DNR vs. Vermeer
Manufacturing Company, 99AG23542
District Court, Marion County, Law No. LACV087889
Pollutant: Particulate Matter (TSP)
Emission Limits: 0.8 lb./MMBtu
Authority for Requirement: 567 IAC 23.3(2)"b"
Pollutant: Sulfur Dioxide (SO2)
Emission Limits: 500 ppmv
Authority for Requirement: 567 IAC 23.3(3)"e"
Pollutant: Nitrogen Oxides (NOx)
Emission Limit(s): See Facility-Wide Conditions
Authority for Requirement: Iowa DNR Construction Permit 98-A-003-S1
Pollutant: Volatile Organic Compounds (VOC)
Emission Limit: See Facility-Wide Conditions
Authority for Requirement: Iowa DNR Construction Permit 98-A-003-S1
451
-------
Operational Limits & Requirements:
The owner/operator of this equipment shall comply with the following operational limits
and requirements.
Process throughput:
A. The sulfur content of natural gas or LPG combusted by this source is not to
exceed 123 ppm by weight.
Reporting & Recordkeeping: See Facility-Wide Operational Limits
Authority for Requirement: Part 7b. of State of Iowa, ex rel., Iowa DNR vs. Vermeer
Manufacturing Company, 99AG23542
District Court, Marion County, Law No. LACV087889
Compliance Plan:
The owner/operator of this equipment shall comply with the following applicable
requirements.
This point is in compliance with all applicable requirements and shall continue to comply
with all such requirements. For those applicable requirements which will become
effective during the permit term, this source will comply with such requirements in a
timely manner.
Periodic Monitoring Requirements:
The owner/operator of this equipment shall comply with the following periodic
monitoring requirements.
Agency Approved Operation & Maintenance Plan Required? Yes ~ No IXI
Facility Maintained Operation & Maintenance Plan Required? Yes ~ No Kl
Authority for Requirement: 567 IAC 22.108(3)"b"
452
-------
Emission Point ID Number: 7.B4
Associated Equipment
Associated Emission Unit ID Numbers (if multiple units vent thru this EP): 7.B4
Applicable Requirements
(If more than one emission unit vents through this emission point subdivide the applicable requirements by emission
unit.)
Emission Unit vented through this Emission Point: 7.B4
Emission Unit Description: Non-Production Heating Unit
Raw Material/Fuel: Natural Gas
Rated Capacity: l.OMMBtu/hr.
Emission Limits (lb./hr. gr./dscf. lb./MMBtu. % opacity, etc.):
The emissions from this emission point shall not exceed the following specified levels.
Pollutant: Opacity
Emission Limit(s): 40 %
Authority for Requirement: 567 IAC 23.3(2)"d"
Pollutant: Particulate Matter (TSP)
Emission Limit(s): 15.3 lb./MMCF of LPG or Natural Gas
Authority for Requirement: Part 7a. of State of Iowa, ex rel., Iowa DNR vs. Vermeer
Manufacturing Company, 99AG23542
District Court, Marion County, Law No. LACV087889
Pollutant: Particulate Matter (TSP)
Emission Limits: 0.8 lb./MMBtu
Authority for Requirement: 567 IAC 23.3(2)"b"
Pollutant: Sulfur Dioxide (SO2)
Emission Limits: 500 ppmv
Authority for Requirement: 567 IAC 23.3(3)"e"
Pollutant: Nitrogen Oxides (NOx)
Emission Limit(s): See Facility-Wide Conditions
Authority for Requirement: Iowa DNR Construction Permit 98-A-003-S1
Pollutant: Volatile Organic Compounds (VOC)
Emission Limit: See Facility-Wide Conditions
Authority for Requirement: Iowa DNR Construction Permit 98-A-003-S1
453
-------
Operational Limits & Requirements:
The owner/operator of this equipment shall comply with the following operational limits
and requirements.
Process throughput:
A. The sulfur content of natural gas or LPG combusted by this source is not to
exceed 123 ppm by weight.
Reporting & Recordkeeping: See Facility-Wide Operational Limits
Authority for Requirement: Part 7b. of State of Iowa, ex rel., Iowa DNR vs. Vermeer
Manufacturing Company, 99AG23542
District Court, Marion County, Law No. LACV087889
Compliance Plan:
The owner/operator of this equipment shall comply with the following applicable
requirements.
This point is in compliance with all applicable requirements and shall continue to comply
with all such requirements. For those applicable requirements which will become
effective during the permit term, this source will comply with such requirements in a
timely manner.
Periodic Monitoring Requirements:
The owner/operator of this equipment shall comply with the following periodic
monitoring requirements.
Agency Approved Operation & Maintenance Plan Required? Yes ~ No IXI
Facility Maintained Operation & Maintenance Plan Required? Yes ~ No Kl
Authority for Requirement: 567 IAC 22.108(3)"b"
454
-------
Emission Point ID Number: 7.D
Associated Equipment
Associated Emission Unit ID Numbers (if multiple units vent thru this EP): 7.D
Applicable Requirements
(If more than one emission unit vents through this emission point subdivide the applicable requirements by emission
unit.)
Emission Unit vented through this Emission Point: 7.D
Emission Unit Description: Non-Production Heating Unit
Raw Material/Fuel: Natural Gas
Rated Capacity: 7.43 MMBtu/hr.
Emission Limits (lb./hr. gr./dscf. lb./MMBtu. % opacity, etc.):
The emissions from this emission point shall not exceed the following specified levels.
Pollutant: Opacity
Emission Limit(s): 40 %
Authority for Requirement: 567 IAC 23.3(2)"d"
Pollutant: Particulate Matter (TSP)
Emission Limit(s): 15.3 lb./MMCF of LPG or Natural Gas
Authority for Requirement: Part 7a. of State of Iowa, ex rel., Iowa DNR vs. Vermeer
Manufacturing Company, 99AG23542
District Court, Marion County, Law No. LACV087889
Pollutant: Particulate Matter (TSP)
Emission Limits: 0.8 lb./MMBtu
Authority for Requirement: 567 IAC 23.3(2)"b"
Pollutant: Sulfur Dioxide (SO2)
Emission Limits: 500 ppmv
Authority for Requirement: 567 IAC 23.3(3)"e"
Pollutant: Nitrogen Oxides (NOx)
Emission Limit(s): See Facility-Wide Conditions
Authority for Requirement: Iowa DNR Construction Permit 98-A-003-S1
Pollutant: Volatile Organic Compounds (VOC)
Emission Limit: See Facility-Wide Conditions
Authority for Requirement: Iowa DNR Construction Permit 98-A-003-S1
455
-------
Operational Limits & Requirements:
The owner/operator of this equipment shall comply with the following operational limits
and requirements.
Process throughput:
A. The sulfur content of natural gas or LPG combusted by this source is not to
exceed 123 ppm by weight.
Reporting & Recordkeeping: See Facility-Wide Operational Limits
Authority for Requirement: Part 7b. of State of Iowa, ex rel., Iowa DNR vs. Vermeer
Manufacturing Company, 99AG23542
District Court, Marion County, Law No. LACV087889
Compliance Plan:
The owner/operator of this equipment shall comply with the following applicable
requirements.
This point is in compliance with all applicable requirements and shall continue to comply
with all such requirements. For those applicable requirements which will become
effective during the permit term, this source will comply with such requirements in a
timely manner.
Periodic Monitoring Requirements:
The owner/operator of this equipment shall comply with the following periodic
monitoring requirements.
Agency Approved Operation & Maintenance Plan Required? Yes ~ No IXI
Facility Maintained Operation & Maintenance Plan Required? Yes ~ No Kl
Authority for Requirement: 567 IAC 22.108(3)"b"
456
-------
Emission Point ID Number: 7.FLAME1
Associated Equipment
Associated Emission Unit ID Numbers (if multiple units vent thru this EP): 7.FLAME1
Emissions Control Equipment ID Number: 7.FLAME1
Emissions Control Equipment Description: Water Table
Applicable Requirements
(If more than one emission unit vents through this emission point subdivide the applicable requirements by emission
unit.)
Emission Unit vented through this Emission Point: 7.FLAME1 (Fugitive)
Emission Unit Description: Single Cutting Head Oxyacetylene
Torch Unit
Raw Material/Fuel: Sheet Steel
Rated Capacity: 660 inches of metal cut/hr.
Emission Limits (lb./hr. gr./dscf. lb./MMBtu. % opacity, etc.):
The emissions from this emission point shall not exceed the following specified levels.
Pollutant: Fugitive Dust
Emission Limit: No person shall allow, cause or permit any materials to be handled,
transported or stored; or a building, its appurtenances or a construction haul road to
be used, constructed, altered , repaired or demolished, without taking reasonable
precautions to prevent a nuisance. All persons shall take reasonable precautions to
prevent the discharge of visible emissions of fugitive dusts beyond the lot line of the
property on which the emissions originate.
Authority for Requirement: 567 IAC 23.3(2)"c"
Compliance Plan:
The owner/operator of this equipment shall comply with the following applicable
requirements.
This point is in compliance with all applicable requirements and shall continue to comply
with all such requirements. For those applicable requirements which will become
effective during the permit term, this source will comply with such requirements in a
timely manner.
Periodic Monitoring Requirements:
The owner/operator of this equipment shall comply with the following periodic
monitoring requirements.
Agency Approved Operation & Maintenance Plan Required? Yes ~ No Kl
Facility Maintained Operation & Maintenance Plan Required? Yes ~ No Kl
Authority for Requirement: 567 IAC 22.108(3)"b"
457
-------
Emission Point ID Number: 7.FLAME2
Associated Equipment
Associated Emission Unit ID Numbers (if multiple units vent thru this EP): 7.FLAME2
Applicable Requirements
(If more than one emission unit vents through this emission point subdivide the applicable requirements by emission
unit.)
Emission Unit vented through this Emission Point: 7.FLAME2 (Fugitive)
Emission Unit Description: Two (2) Cutting Head Oxyacetylene
Torch Unit
Raw Material/Fuel: Sheet Steel
Rated Capacity: 660 inches of metal cut/hr. per Head
Emission Limits (lb./hr. gr./dscf. lb./MMBtu. % opacity, etc.):
The emissions from this emission point shall not exceed the following specified levels.
Pollutant: Fugitive Dust
Emission Limit: No person shall allow, cause or permit any materials to be handled,
transported or stored; or a building, its appurtenances or a construction haul road to
be used, constructed, altered , repaired or demolished, without taking reasonable
precautions to prevent a nuisance. All persons shall take reasonable precautions to
prevent the discharge of visible emissions of fugitive dusts beyond the lot line of the
property on which the emissions originate.
Authority for Requirement: 567 IAC 23.3(2)"c"
Compliance Plan:
The owner/operator of this equipment shall comply with the following applicable
requirements.
This point is in compliance with all applicable requirements and shall continue to comply
with all such requirements. For those applicable requirements which will become
effective during the permit term, this source will comply with such requirements in a
timely manner.
Periodic Monitoring Requirements:
The owner/operator of this equipment shall comply with the following periodic
monitoring requirements.
Agency Approved Operation & Maintenance Plan Required? Yes ~ No IXI
Facility Maintained Operation & Maintenance Plan Required? Yes ~ No Kl
Authority for Requirement: 567 IAC 22.108(3)"b"
458
-------
Emission Point ID Number: 7.FLAME3
Associated Equipment
Associated Emission Unit ID Numbers (if multiple units vent thru this EP): 7.FLAME3
Applicable Requirements
(If more than one emission unit vents through this emission point subdivide the applicable requirements by emission
unit.)
Emission Unit vented through this Emission Point: 7.FLAME3 (Fugitive)
Emission Unit Description: Single Cutting Head Oxyacetylene
Torch Unit
Raw Material/Fuel: Sheet Steel
Rated Capacity: 660 inches of metal cut/hr.
Emission Limits (lb./hr. gr./dscf. lb./MMBtu. % opacity, etc.):
The emissions from this emission point shall not exceed the following specified levels.
Pollutant: Fugitive Dust
Emission Limit: No person shall allow, cause or permit any materials to be handled,
transported or stored; or a building, its appurtenances or a construction haul road to
be used, constructed, altered , repaired or demolished, without taking reasonable
precautions to prevent a nuisance. All persons shall take reasonable precautions to
prevent the discharge of visible emissions of fugitive dusts beyond the lot line of the
property on which the emissions originate.
Authority for Requirement: 567 IAC 23.3(2)"c"
Compliance Plan:
The owner/operator of this equipment shall comply with the following applicable
requirements.
This point is in compliance with all applicable requirements and shall continue to comply
with all such requirements. For those applicable requirements which will become
effective during the permit term, this source will comply with such requirements in a
timely manner.
Periodic Monitoring Requirements:
The owner/operator of this equipment shall comply with the following periodic
monitoring requirements.
Agency Approved Operation & Maintenance Plan Required? Yes ~ No IXI
Facility Maintained Operation & Maintenance Plan Required? Yes ~ No Kl
Authority for Requirement: 567 IAC 22.108(3)"b"
459
-------
Emission Point ID Number: 7.FLAME4
Associated Equipment
Associated Emission Unit ID Numbers (if multiple units vent thru this EP): 7.FLAME4
Applicable Requirements
(If more than one emission unit vents through this emission point subdivide the applicable requirements by emission
unit.)
Emission Unit vented through this Emission Point: 7.FLAME4 (Fugitive)
Emission Unit Description: Single Cutting Head Oxyacetylene
Torch Unit
Raw Material/Fuel: Sheet Steel
Rated Capacity: 660 inches of metal cut/hr.
Emission Limits (lb./hr. gr./dscf. lb./MMBtu. % opacity, etc.):
The emissions from this emission point shall not exceed the following specified levels.
Pollutant: Fugitive Dust
Emission Limit: No person shall allow, cause or permit any materials to be handled,
transported or stored; or a building, its appurtenances or a construction haul road to
be used, constructed, altered , repaired or demolished, without taking reasonable
precautions to prevent a nuisance. All persons shall take reasonable precautions to
prevent the discharge of visible emissions of fugitive dusts beyond the lot line of the
property on which the emissions originate.
Authority for Requirement: 567 IAC 23.3(2)"c"
Compliance Plan:
The owner/operator of this equipment shall comply with the following applicable
requirements.
This point is in compliance with all applicable requirements and shall continue to comply
with all such requirements. For those applicable requirements which will become
effective during the permit term, this source will comply with such requirements in a
timely manner.
Periodic Monitoring Requirements:
The owner/operator of this equipment shall comply with the following periodic
monitoring requirements.
Agency Approved Operation & Maintenance Plan Required? Yes ~ No IXI
Facility Maintained Operation & Maintenance Plan Required? Yes ~ No Kl
Authority for Requirement: 567 IAC 22.108(3)"b"
460
-------
Emission Point ID Number: 7.FLAME5
Associated Equipment
Associated Emission Unit ID Numbers (if multiple units vent thru this EP): 7.FLAME5
Applicable Requirements
(If more than one emission unit vents through this emission point subdivide the applicable requirements by emission
unit.)
Emission Unit vented through this Emission Point: 7.FLAME5 (Fugitive)
Emission Unit Description: Single Cutting Head Oxyacetylene
Torch Unit
Raw Material/Fuel: Sheet Steel
Rated Capacity: 660 inches of metal cut/hr.
Emission Limits (lb./hr. gr./dscf. lb./MMBtu. % opacity, etc.):
The emissions from this emission point shall not exceed the following specified levels.
Pollutant: Fugitive Dust
Emission Limit: No person shall allow, cause or permit any materials to be handled,
transported or stored; or a building, its appurtenances or a construction haul road to
be used, constructed, altered , repaired or demolished, without taking reasonable
precautions to prevent a nuisance. All persons shall take reasonable precautions to
prevent the discharge of visible emissions of fugitive dusts beyond the lot line of the
property on which the emissions originate.
Authority for Requirement: 567 IAC 23.3(2)"c"
Compliance Plan:
The owner/operator of this equipment shall comply with the following applicable
requirements.
This point is in compliance with all applicable requirements and shall continue to comply
with all such requirements. For those applicable requirements which will become
effective during the permit term, this source will comply with such requirements in a
timely manner.
Periodic Monitoring Requirements:
The owner/operator of this equipment shall comply with the following periodic
monitoring requirements.
Agency Approved Operation & Maintenance Plan Required? Yes ~ No IXI
Facility Maintained Operation & Maintenance Plan Required? Yes ~ No Kl
Authority for Requirement: 567 IAC 22.108(3)"b"
461
-------
Emission Point ID Number: 7.FLAME6
Associated Equipment
Associated Emission Unit ID Numbers (if multiple units vent thru this EP): 7.FLAME6
Applicable Requirements
(If more than one emission unit vents through this emission point subdivide the applicable requirements by emission
unit.)
Emission Unit vented through this Emission Point: 7.FLAME6 (Fugitive)
Emission Unit Description: Single Cutting Head Oxyacetylene
Torch Unit
Raw Material/Fuel: Sheet Steel
Rated Capacity: 660 inches of metal cut/hr.
Emission Limits (lb./hr. gr./dscf. lb./MMBtu. % opacity, etc.):
The emissions from this emission point shall not exceed the following specified levels.
Pollutant: Fugitive Dust
Emission Limit: No person shall allow, cause or permit any materials to be handled,
transported or stored; or a building, its appurtenances or a construction haul road to
be used, constructed, altered , repaired or demolished, without taking reasonable
precautions to prevent a nuisance. All persons shall take reasonable precautions to
prevent the discharge of visible emissions of fugitive dusts beyond the lot line of the
property on which the emissions originate.
Authority for Requirement: 567 IAC 23.3(2)"c"
Compliance Plan:
The owner/operator of this equipment shall comply with the following applicable
requirements.
This point is in compliance with all applicable requirements and shall continue to comply
with all such requirements. For those applicable requirements which will become
effective during the permit term, this source will comply with such requirements in a
timely manner.
Periodic Monitoring Requirements:
The owner/operator of this equipment shall comply with the following periodic
monitoring requirements.
Agency Approved Operation & Maintenance Plan Required? Yes ~ No IXI
Facility Maintained Operation & Maintenance Plan Required? Yes ~ No Kl
Authority for Requirement: 567 IAC 22.108(3)"b"
462
-------
Emission Point ID Number: 7.G
Associated Equipment
Associated Emission Unit ID Numbers (if multiple units vent thru this EP): 7.G
Applicable Requirements
(If more than one emission unit vents through this emission point subdivide the applicable requirements by emission
unit.)
Emission Unit vented through this Emission Point: 7.G
Emission Unit Description: Production Engine Testing Unit
Raw Material/Fuel: #2 Diesel Fuel and Gasoline
Rated Capacity: 50.5 gal./hr.
Emission Limits (lb./hr. gr./dscf. lb./MMBtu. % opacity, etc.):
The emissions from this emission point shall not exceed the following specified levels.
Pollutant: Opacity
Emission Limits: 40%
Indicator Opacity: 25%(1)
(1) If visible emissions are observed that exceed the indicator opacity other than startup,
shutdown or malfunction, a stack test may be required to demonstrate compliance with
the particulate standard.
Authority for Requirement: Iowa DNR Construction Permit 97-A-1112-S2
567 IAC 23.3(2)"d"
Pollutant: Particulate Matter (TSP)
Emission Limits: 0.1 gr./dscf
Authority for Requirement: Iowa DNR Construction Permit 97-A-1112-S2
567 IAC 23.3(2)"a"
Pollutant: Sulfur Dioxide (SO2)
Emission Limits: 2.5 lb./MMBtu
Authority for Requirement: Iowa DNR Construction Permit 97-A-1112-S2
567 IAC 23.3(3)"b"
Pollutant: Nitrogen Oxides (NOx)
Emission Limit(s): See Facility-Wide Conditions
Authority for Requirement: Iowa DNR Construction Permit 97-A-1112-S2
Pollutant: Volatile Organic Compounds (VOC)
Emission Limit: See Facility-Wide Conditions
Authority for Requirement: Iowa DNR Construction Permit 97-A-1112-S2
463
-------
Operational Limits & Requirements:
The owner/operator of this equipment shall comply with the following operational limits
and requirements.
Process Throughput:
A. The sulfur content of any diesel fuel used in this source shall not exceed 0.4% by
weight.
Reporting & Recordkeeping: See Facility-Wide Emission and Operational Limits
Authority for Requirement: Iowa DNR Construction Permit 97-A-1112-S2
Compliance Plan:
The owner/operator of this equipment shall comply with the following applicable
requirements.
This point is in compliance with all applicable requirements and shall continue to comply
with all such requirements. For those applicable requirements which will become
effective during the permit term, this source will comply with such requirements in a
timely manner.
Additional Requirements:
This emission point shall conform to the following conditions.
The source is to be connected to the stack of the following detailed description.
Stack Height (feet): 35
Stack Diameter (inches): 12
Stack Exhaust Flow Rate (acfm): .... 5,750
Stack Temperature (°F): 759
Vertical, Unobstructed Discharge Required: Yes ^ No ~
Authority for Requirement: Iowa DNR Construction Permit 97-A-1112-S2
Periodic Monitoring Requirements:
The owner/operator of this equipment shall comply with the following periodic
monitoring requirements.
Opacity Monitoring:
The facility shall observe the opacity weekly during a period when the emission unit
associated with this emission point is at or near full capacity and record the reading
indicating if visible emissions were observed. The records shall be maintained for five
years. If weather conditions prevent the observer from conducting an opacity
observation, the observer shall note such conditions on the data observation sheet. At
least three attempts shall be made to retake opacity readings at approximately 2-hour
intervals throughout the day. If all observation attempts for a week have been
unsuccessful due to weather, an observation shall be made the next operating day where
weather permits.
Maintain a written record of the observation and any action resulting from the
observation.
464
-------
Agency Approved Operation & Maintenance Plan Required? Yes ~ No Kl
Facility Maintained Operation & Maintenance Plan Required? Yes ~ No Kl
Authority for Requirement: 567 IAC 22.108(3)"b"
465
-------
Emission Point ID Number: 7.H
Associated Equipment
Associated Emission Unit ID Numbers (if multiple units vent thru this EP): 7.H
Applicable Requirements
(If more than one emission unit vents through this emission point subdivide the applicable requirements by emission
unit.)
Emission Unit vented through this Emission Point: 7.H
Emission Unit Description: Production Engine Testing Unit
Raw Material/Fuel: #2 Diesel Fuel and Gasoline
Rated Capacity: 60.6 gal./hr.
Emission Limits (lb./hr. gr./dscf. lb./MMBtu. % opacity, etc.):
The emissions from this emission point shall not exceed the following specified levels.
Pollutant: Opacity
Emission Limits: 40%
Indicator Opacity: 25%(1)
(1) If visible emissions are observed that exceed the indicator opacity other than startup,
shutdown or malfunction, a stack test may be required to demonstrate compliance with
the particulate standard.
Authority for Requirement: Iowa DNR Construction Permit 98-A-862-S2
567 IAC 23.3(2)"d"
Pollutant: Particulate Matter (TSP)
Emission Limits: 0.1 gr./dscf
Authority for Requirement: Iowa DNR Construction Permit 98-A-862-S2
567 IAC 23.3(2)"a"
Pollutant: Sulfur Dioxide (SO2)
Emission Limits: 2.5 lb./MMBtu
Authority for Requirement: Iowa DNR Construction Permit 98-A-862-S2
567 IAC 23.3(3)"b"
Pollutant: Nitrogen Oxides (NOx)
Emission Limit(s): See Facility-Wide Conditions
Authority for Requirement: Iowa DNR Construction Permit 98-A-862-S2
Pollutant: Volatile Organic Compounds (VOC)
Emission Limit: See Facility-Wide Conditions
Authority for Requirement: Iowa DNR Construction Permit 98-A-862-S2
466
-------
Operational Limits & Requirements:
The owner/operator of this equipment shall comply with the following operational limits
and requirements.
Process Throughput:
A. The sulfur content of any diesel fuel used in this source shall not exceed 0.4% by
weight.
Reporting & Recordkeeping: See Facility-Wide Emission and Operational Limits
Authority for Requirement: Iowa DNR Construction Permit 98-A-862-S2
Compliance Plan:
The owner/operator of this equipment shall comply with the following applicable
requirements.
This point is in compliance with all applicable requirements and shall continue to comply
with all such requirements. For those applicable requirements which will become
effective during the permit term, this source will comply with such requirements in a
timely manner.
Additional Requirements:
This emission point shall conform to the following conditions.
The source is to be connected to the stack of the following detailed description.
Stack Height (feet): 37
Stack Diameter (inches): 12
Stack Exhaust Flow Rate (acfm): .... 7.387
Stack Temperature (°F): 845
Vertical, Unobstructed Discharge Required: Yes ~ No
Authority for Requirement: Iowa DNR Construction Permit 98-A-862-S2
Periodic Monitoring Requirements:
The owner/operator of this equipment shall comply with the following periodic
monitoring requirements.
Opacity Monitoring:
The facility shall observe the opacity weekly during a period when the emission unit
associated with this emission point is at or near full capacity and record the reading
indicating if visible emissions were observed. The records shall be maintained for five
years. If weather conditions prevent the observer from conducting an opacity
observation, the observer shall note such conditions on the data observation sheet. At
least three attempts shall be made to retake opacity readings at approximately 2-hour
intervals throughout the day. If all observation attempts for a week have been
unsuccessful due to weather, an observation shall be made the next operating day where
weather permits.
Maintain a written record of the observation and any action resulting from the
observation.
E
467
-------
Agency Approved Operation & Maintenance Plan Required? Yes ~ No Kl
Facility Maintained Operation & Maintenance Plan Required? Yes ~ No Kl
Authority for Requirement: 567 IAC 22.108(3)"b"
468
-------
Emission Point ID Number: 7.1
Associated Equipment
Associated Emission Unit ID Numbers (if multiple units vent thru this EP): 7.1
Applicable Requirements
(If more than one emission unit vents through this emission point subdivide the applicable requirements by emission
unit.)
Emission Unit vented through this Emission Point: 7.1
Emission Unit Description: Production Engine Testing Unit
Raw Material/Fuel: #2 Diesel Fuel and Gasoline
Rated Capacity: 60.6 gal./hr.
Emission Limits (lb./hr. gr./dscf. lb./MMBtu. % opacity, etc.):
The emissions from this emission point shall not exceed the following specified levels.
Pollutant: Opacity
Emission Limits: 40%
Indicator Opacity: 25%(1)
(1) If visible emissions are observed that exceed the indicator opacity other than startup,
shutdown or malfunction, a stack test may be required to demonstrate compliance with
the particulate standard.
Authority for Requirement: Iowa DNR Construction Permit 98-A-863-S2
567 IAC 23.3(2)"d"
Pollutant: Particulate Matter (TSP)
Emission Limits: 0.1 gr./dscf
Authority for Requirement: Iowa DNR Construction Permit 98-A-863-S2
567 IAC 23.3(2)"a"
Pollutant: Sulfur Dioxide (SO2)
Emission Limits: 2.5 lb./MMBtu
Authority for Requirement: Iowa DNR Construction Permit 98-A-863-S2
567 IAC 23.3(3)"b"
Pollutant: Nitrogen Oxides (NOx)
Emission Limit(s): See Facility-Wide Conditions
Authority for Requirement: Iowa DNR Construction Permit 98-A-863-S2
Pollutant: Volatile Organic Compounds (VOC)
Emission Limit: See Facility-Wide Conditions
Authority for Requirement: Iowa DNR Construction Permit 98-A-863-S2
469
-------
Operational Limits & Requirements:
The owner/operator of this equipment shall comply with the following operational limits
and requirements.
Process Throughput:
A. The sulfur content of any diesel fuel used in this source shall not exceed 0.4% by
weight.
Reporting & Recordkeeping: See Facility-Wide Emission and Operational Limits
Authority for Requirement: Iowa DNR Construction Permit 98-A-863-S2
Compliance Plan:
The owner/operator of this equipment shall comply with the following applicable
requirements.
This point is in compliance with all applicable requirements and shall continue to comply
with all such requirements. For those applicable requirements which will become
effective during the permit term, this source will comply with such requirements in a
timely manner.
Additional Requirements:
This emission point shall conform to the following conditions.
The source is to be connected to the stack of the following detailed description.
Stack Height (feet): 38
Stack Diameter (inches): 12
Stack Exhaust Flow Rate (acfm): .... 7,387
Stack Temperature (°F): 845
Vertical, Unobstructed Discharge Required: Yes ~ No
Authority for Requirement: Iowa DNR Construction Permit 98-A-863-S2
Periodic Monitoring Requirements:
The owner/operator of this equipment shall comply with the following periodic
monitoring requirements.
Opacity Monitoring:
The facility shall observe the opacity weekly during a period when the emission unit
associated with this emission point is at or near full capacity and record the reading
indicating if visible emissions were observed. The records shall be maintained for five
years. If weather conditions prevent the observer from conducting an opacity
observation, the observer shall note such conditions on the data observation sheet. At
least three attempts shall be made to retake opacity readings at approximately 2-hour
intervals throughout the day. If all observation attempts for a week have been
unsuccessful due to weather, an observation shall be made the next operating day where
weather permits.
Maintain a written record of the observation and any action resulting from the
observation.
E
470
-------
Agency Approved Operation & Maintenance Plan Required? Yes ~ No Kl
Facility Maintained Operation & Maintenance Plan Required? Yes ~ No Kl
Authority for Requirement: 567 IAC 22.108(3)"b"
471
-------
Emission Point ID Number: 7.K
Associated Equipment
Associated Emission Unit ID Numbers (if multiple units vent thru this EP): 7.K
Applicable Requirements
(If more than one emission unit vents through this emission point subdivide the applicable requirements by emission
unit.)
Emission Unit vented through this Emission Point: 7.K
Emission Unit Description: Non-Production Heating Unit
Raw Material/Fuel: Natural Gas
Rated Capacity: 0.1 MMBtu/hr.
Emission Limits (lb./hr. gr./dscf. lb./MMBtu. % opacity, etc.):
The emissions from this emission point shall not exceed the following specified levels.
Pollutant: Opacity
Emission Limit(s): 40 %
Authority for Requirement: 567 IAC 23.3(2)"d"
Pollutant: Particulate Matter (TSP)
Emission Limit(s): 15.3 lb./MMCF of LPG or Natural Gas
Authority for Requirement: Part 7a. of State of Iowa, ex rel., Iowa DNR vs. Vermeer
Manufacturing Company, 99AG23542
District Court, Marion County, Law No. LACV087889
Pollutant: Particulate Matter (TSP)
Emission Limits: 0.8 lb./MMBtu
Authority for Requirement: 567 IAC 23.3(2)"b"
Pollutant: Sulfur Dioxide (SO2)
Emission Limits: 500 ppmv
Authority for Requirement: 567 IAC 23.3(3)"e"
Pollutant: Nitrogen Oxides (NOx)
Emission Limit(s): See Facility-Wide Conditions
Authority for Requirement: Iowa DNR Construction Permit 98-A-003-S1
Pollutant: Volatile Organic Compounds (VOC)
Emission Limit: See Facility-Wide Conditions
Authority for Requirement: Iowa DNR Construction Permit 98-A-003-S1
472
-------
Operational Limits & Requirements:
The owner/operator of this equipment shall comply with the following operational limits
and requirements.
Process throughput:
A. The sulfur content of natural gas or LPG combusted by this source is not to
exceed 123 ppm by weight.
Reporting & Recordkeeping: See Facility-Wide Operational Limits
Authority for Requirement: Part 7b. of State of Iowa, ex rel., Iowa DNR vs. Vermeer
Manufacturing Company, 99AG23542
District Court, Marion County, Law No. LACV087889
Compliance Plan:
The owner/operator of this equipment shall comply with the following applicable
requirements.
This point is in compliance with all applicable requirements and shall continue to comply
with all such requirements. For those applicable requirements which will become
effective during the permit term, this source will comply with such requirements in a
timely manner.
Periodic Monitoring Requirements:
The owner/operator of this equipment shall comply with the following periodic
monitoring requirements.
Agency Approved Operation & Maintenance Plan Required? Yes ~ No IXI
Facility Maintained Operation & Maintenance Plan Required? Yes ~ No Kl
Authority for Requirement: 567 IAC 22.108(3)"b"
473
-------
Emission Point ID Number: 7.L
Associated Equipment
Associated Emission Unit ID Numbers (if multiple units vent thru this EP): 7.L
Applicable Requirements
(If more than one emission unit vents through this emission point subdivide the applicable requirements by emission
unit.)
Emission Unit vented through this Emission Point: 7.L
Emission Unit Description: Non-Production Heating Unit
Raw Material/Fuel: Natural Gas
Rated Capacity: 0.135 MMBtu/hr.
Emission Limits (lb./hr. gr./dscf. lb./MMBtu. % opacity, etc.):
The emissions from this emission point shall not exceed the following specified levels.
Pollutant: Opacity
Emission Limit(s): 40 %
Authority for Requirement: 567 IAC 23.3(2)"d"
Pollutant: Particulate Matter (TSP)
Emission Limit(s): 15.3 lb./MMCF of LPG or Natural Gas
Authority for Requirement: Part 7a. of State of Iowa, ex rel., Iowa DNR vs. Vermeer
Manufacturing Company, 99AG23542
District Court, Marion County, Law No. LACV087889
Pollutant: Particulate Matter (TSP)
Emission Limits: 0.8 lb./MMBtu
Authority for Requirement: 567 IAC 23.3(2)"b"
Pollutant: Sulfur Dioxide (SO2)
Emission Limits: 500 ppmv
Authority for Requirement: 567 IAC 23.3(3)"e"
Pollutant: Nitrogen Oxides (NOx)
Emission Limit(s): See Facility-Wide Conditions
Authority for Requirement: Iowa DNR Construction Permit 98-A-003-S1
Pollutant: Volatile Organic Compounds (VOC)
Emission Limit: See Facility-Wide Conditions
Authority for Requirement: Iowa DNR Construction Permit 98-A-003-S1
474
-------
Operational Limits & Requirements:
The owner/operator of this equipment shall comply with the following operational limits
and requirements.
Process throughput:
A. The sulfur content of natural gas or LPG combusted by this source is not to
exceed 123 ppm by weight.
Reporting & Recordkeeping: See Facility-Wide Operational Limits
Authority for Requirement: Part 7b. of State of Iowa, ex rel., Iowa DNR vs. Vermeer
Manufacturing Company, 99AG23542
District Court, Marion County, Law No. LACV087889
Compliance Plan:
The owner/operator of this equipment shall comply with the following applicable
requirements.
This point is in compliance with all applicable requirements and shall continue to comply
with all such requirements. For those applicable requirements which will become
effective during the permit term, this source will comply with such requirements in a
timely manner.
Periodic Monitoring Requirements:
The owner/operator of this equipment shall comply with the following periodic
monitoring requirements.
Agency Approved Operation & Maintenance Plan Required? Yes ~ No IXI
Facility Maintained Operation & Maintenance Plan Required? Yes ~ No Kl
Authority for Requirement: 567 IAC 22.108(3)"b"
475
-------
Emission Point ID Number: 7.LASER
Associated Equipment
Associated Emission Unit ID Numbers (if multiple units vent thru this EP): 7.LASER
Emissions Control Equipment ID Number: 7.LASER
Emissions Control Equipment Description: Baghouse
Applicable Requirements
(If more than one emission unit vents through this emission point subdivide the applicable requirements by emission
unit.)
Emission Unit vented through this Emission Point: 7.LASER
Emission Unit Description: Four (4) Single Head Laser Cutting
Machines
Raw Material/Fuel: Sheet Steel
Rated Capacity: 4,800 in. of metal cut/hr. per Head
Emission Limits (lb./hr. gr./dscf. lb./MMBtu. % opacity, etc.):
The emissions from this emission point shall not exceed the following specified levels.
Pollutant: Opacity
Emission Limits: 40%
Indicator Opacity: 25%(1)
(1) If visible emissions are observed that exceed the indicator opacity other than startup,
shutdown or malfunction, a stack test may be required to demonstrate compliance with
the particulate standard.
Authority for Requirement: Iowa DNR Construction Permit 98-A-456-S1
567 IAC23.3(2)"d"
Pollutant: Particulate Matter (TSP)
Emission Limits: 0.1 gr./dscf
Authority for Requirement: Iowa DNR Construction Permit 98-A-456-S1
567 I AC 23.3 (2) "a"
Pollutant: Volatile Organic Compounds (VOC)
Emission Limit: See Facility-Wide Conditions
Authority for Requirement: Iowa DNR Construction Permit 98-A-456-S1
Compliance Plan:
The owner/operator of this equipment shall comply with the following applicable
requirements.
This point is in compliance with all applicable requirements and shall continue to comply
with all such requirements. For those applicable requirements which will become
effective during the permit term, this source will comply with such requirements in a
timely manner.
476
-------
Additional Requirements:
This emission point shall conform to the following conditions.
The source is to be connected to the stack of the following detailed description.
Stack Height (feet): 25
Stack Diameter (inches): 18
Stack Exhaust Flow Rate (acfm): .... 4,800
Stack Temperature (°F): 68
Vertical, Unobstructed Discharge Required: Yes ~ No Kl
Authority for Requirement: Iowa DNR Construction Permit 98-A-456-S1
Periodic Monitoring Requirements:
The owner/operator of this equipment shall comply with the following periodic
monitoring requirements.
Opacity Monitoring:
The facility shall observe the opacity weekly during a period when the emission unit
associated with this emission point is at or near full capacity and record the reading
indicating if visible emissions were observed. The records shall be maintained for five
years. If weather conditions prevent the observer from conducting an opacity
observation, the observer shall note such conditions on the data observation sheet. At
least three attempts shall be made to retake opacity readings at approximately 2-hour
intervals throughout the day. If all observation attempts for a week have been
unsuccessful due to weather, an observation shall be made the next operating day where
weather permits.
Maintain a written record of the observation and any action resulting from the
observation.
Agency Approved Operation & Maintenance Plan Required? Yes ~ No IXI
Facility Maintained Operation & Maintenance Plan Required? Yes ~ No IE
Authority for Requirement: 567 IAC 22.108(3)"b"
477
-------
Emission Point ID Number: 7.M
Associated Equipment
Associated Emission Unit ID Numbers (if multiple units vent thru this EP): 7.M
Applicable Requirements
(If more than one emission unit vents through this emission point subdivide the applicable requirements by emission
unit.)
Emission Unit vented through this Emission Point: 7.M
Emission Unit Description: Non-Production Heating Unit
Raw Material/Fuel: Natural Gas
Rated Capacity: 0.08 MMBtu/hr.
Emission Limits (lb./hr. gr./dscf. lb./MMBtu. % opacity, etc.):
The emissions from this emission point shall not exceed the following specified levels.
Pollutant: Opacity
Emission Limit(s): 40 %
Authority for Requirement: 567 IAC 23.3(2)"d"
Pollutant: Particulate Matter (TSP)
Emission Limit(s): 15.3 lb./MMCF of LPG or Natural Gas
Authority for Requirement: Part 7a. of State of Iowa, ex rel., Iowa DNR vs. Vermeer
Manufacturing Company, 99AG23542
District Court, Marion County, Law No. LACV087889
Pollutant: Particulate Matter (TSP)
Emission Limits: 0.8 lb./MMBtu
Authority for Requirement: 567 IAC 23.3(2)"b"
Pollutant: Sulfur Dioxide (SO2)
Emission Limits: 500 ppmv
Authority for Requirement: 567 IAC 23.3(3)"e"
Pollutant: Nitrogen Oxides (NOx)
Emission Limit(s): See Facility-Wide Conditions
Authority for Requirement: Iowa DNR Construction Permit 98-A-003-S1
Pollutant: Volatile Organic Compounds (VOC)
Emission Limit: See Facility-Wide Conditions
Authority for Requirement: Iowa DNR Construction Permit 98-A-003-S1
478
-------
Operational Limits & Requirements:
The owner/operator of this equipment shall comply with the following operational limits
and requirements.
Process throughput:
A. The sulfur content of natural gas or LPG combusted by this source is not to
exceed 123 ppm by weight.
Reporting & Recordkeeping: See Facility-Wide Operational Limits
Authority for Requirement: Part 7b. of State of Iowa, ex rel., Iowa DNR vs. Vermeer
Manufacturing Company, 99AG23542
District Court, Marion County, Law No. LACV087889
Compliance Plan:
The owner/operator of this equipment shall comply with the following applicable
requirements.
This point is in compliance with all applicable requirements and shall continue to comply
with all such requirements. For those applicable requirements which will become
effective during the permit term, this source will comply with such requirements in a
timely manner.
Periodic Monitoring Requirements:
The owner/operator of this equipment shall comply with the following periodic
monitoring requirements.
Agency Approved Operation & Maintenance Plan Required? Yes ~ No IXI
Facility Maintained Operation & Maintenance Plan Required? Yes ~ No Kl
Authority for Requirement: 567 IAC 22.108(3)"b"
479
-------
Emission Point ID Number: 7.N
Associated Equipment
Associated Emission Unit ID Numbers (if multiple units vent thru this EP): 7.N
Applicable Requirements
(If more than one emission unit vents through this emission point subdivide the applicable requirements by emission
unit.)
Emission Unit vented through this Emission Point: 7.N
Emission Unit Description: Non-Production Heating Unit
Raw Material/Fuel: Natural Gas
Rated Capacity: 0.08 MMBtu/hr.
Emission Limits (lb./hr. gr./dscf. lb./MMBtu. % opacity, etc.):
The emissions from this emission point shall not exceed the following specified levels.
Pollutant: Opacity
Emission Limit(s): 40 %
Authority for Requirement: 567 IAC 23.3(2)"d"
Pollutant: Particulate Matter (TSP)
Emission Limit(s): 15.3 lb./MMCF of LPG or Natural Gas
Authority for Requirement: Part 7a. of State of Iowa, ex rel., Iowa DNR vs. Vermeer
Manufacturing Company, 99AG23542
District Court, Marion County, Law No. LACV087889
Pollutant: Particulate Matter (TSP)
Emission Limits: 0.8 lb./MMBtu
Authority for Requirement: 567 IAC 23.3(2)"b"
Pollutant: Sulfur Dioxide (SO2)
Emission Limits: 500 ppmv
Authority for Requirement: 567 IAC 23.3(3)"e"
Pollutant: Nitrogen Oxides (NOx)
Emission Limit(s): See Facility-Wide Conditions
Authority for Requirement: Iowa DNR Construction Permit 98-A-003-S1
Pollutant: Volatile Organic Compounds (VOC)
Emission Limit: See Facility-Wide Conditions
Authority for Requirement: Iowa DNR Construction Permit 98-A-003-S1
480
-------
Operational Limits & Requirements:
The owner/operator of this equipment shall comply with the following operational limits
and requirements.
Process throughput:
A. The sulfur content of natural gas or LPG combusted by this source is not to
exceed 123 ppm by weight.
Reporting & Recordkeeping: See Facility-Wide Operational Limits
Authority for Requirement: Part 7b. of State of Iowa, ex rel., Iowa DNR vs. Vermeer
Manufacturing Company, 99AG23542
District Court, Marion County, Law No. LACV087889
Compliance Plan:
The owner/operator of this equipment shall comply with the following applicable
requirements.
This point is in compliance with all applicable requirements and shall continue to comply
with all such requirements. For those applicable requirements which will become
effective during the permit term, this source will comply with such requirements in a
timely manner.
Periodic Monitoring Requirements:
The owner/operator of this equipment shall comply with the following periodic
monitoring requirements.
Agency Approved Operation & Maintenance Plan Required? Yes ~ No IXI
Facility Maintained Operation & Maintenance Plan Required? Yes ~ No Kl
Authority for Requirement: 567 IAC 22.108(3)"b"
481
-------
Emission Point ID Number: 7.0
Associated Equipment
Associated Emission Unit ID Numbers (if multiple units vent thru this EP): 7.0
Applicable Requirements
(If more than one emission unit vents through this emission point subdivide the applicable requirements by emission
unit.)
Emission Unit vented through this Emission Point: 7.0
Emission Unit Description: Non-Production Heating Unit
Raw Material/Fuel: Natural Gas
Rated Capacity: 0.08 MMBtu/hr.
Emission Limits (lb./hr. gr./dscf. lb./MMBtu. % opacity, etc.):
The emissions from this emission point shall not exceed the following specified levels.
Pollutant: Opacity
Emission Limit(s): 40 %
Authority for Requirement: 567 IAC 23.3(2)"d"
Pollutant: Particulate Matter (TSP)
Emission Limit(s): 15.3 lb./MMCF of LPG or Natural Gas
Authority for Requirement: Part 7a. of State of Iowa, ex rel., Iowa DNR vs. Vermeer
Manufacturing Company, 99AG23542
District Court, Marion County, Law No. LACV087889
Pollutant: Particulate Matter (TSP)
Emission Limits: 0.8 lb./MMBtu
Authority for Requirement: 567 IAC 23.3(2)"b"
Pollutant: Sulfur Dioxide (SO2)
Emission Limits: 500 ppmv
Authority for Requirement: 567 IAC 23.3(3)"e"
Pollutant: Nitrogen Oxides (NOx)
Emission Limit(s): See Facility-Wide Conditions
Authority for Requirement: Iowa DNR Construction Permit 98-A-003-S1
Pollutant: Volatile Organic Compounds (VOC)
Emission Limit: See Facility-Wide Conditions
Authority for Requirement: Iowa DNR Construction Permit 98-A-003-S1
482
-------
Operational Limits & Requirements:
The owner/operator of this equipment shall comply with the following operational limits
and requirements.
Process throughput:
A. The sulfur content of natural gas or LPG combusted by this source is not to
exceed 123 ppm by weight.
Reporting & Recordkeeping: See Facility-Wide Operational Limits
Authority for Requirement: Part 7b. of State of Iowa, ex rel., Iowa DNR vs. Vermeer
Manufacturing Company, 99AG23542
District Court, Marion County, Law No. LACV087889
Compliance Plan:
The owner/operator of this equipment shall comply with the following applicable
requirements.
This point is in compliance with all applicable requirements and shall continue to comply
with all such requirements. For those applicable requirements which will become
effective during the permit term, this source will comply with such requirements in a
timely manner.
Periodic Monitoring Requirements:
The owner/operator of this equipment shall comply with the following periodic
monitoring requirements.
Agency Approved Operation & Maintenance Plan Required? Yes ~ No IXI
Facility Maintained Operation & Maintenance Plan Required? Yes ~ No Kl
Authority for Requirement: 567 IAC 22.108(3)"b"
483
-------
Emission Point ID Number: 7.P
Associated Equipment
Associated Emission Unit ID Numbers (if multiple units vent thru this EP): 7.P
Applicable Requirements
(If more than one emission unit vents through this emission point subdivide the applicable requirements by emission
unit.)
Emission Unit vented through this Emission Point: 7.P
Emission Unit Description: Non-Production Heating Unit
Raw Material/Fuel: Natural Gas
Rated Capacity: 0.1 MMBtu/hr.
Emission Limits (lb./hr. gr./dscf. lb./MMBtu. % opacity, etc.):
The emissions from this emission point shall not exceed the following specified levels.
Pollutant: Opacity
Emission Limit(s): 40 %
Authority for Requirement: 567 IAC 23.3(2)"d"
Pollutant: Particulate Matter (TSP)
Emission Limit(s): 15.3 lb./MMCF of LPG or Natural Gas
Authority for Requirement: Part 7a. of State of Iowa, ex rel., Iowa DNR vs. Vermeer
Manufacturing Company, 99AG23542
District Court, Marion County, Law No. LACV087889
Pollutant: Particulate Matter (TSP)
Emission Limits: 0.8 lb./MMBtu
Authority for Requirement: 567 IAC 23.3(2)"b"
Pollutant: Sulfur Dioxide (SO2)
Emission Limits: 500 ppmv
Authority for Requirement: 567 IAC 23.3(3)"e"
Pollutant: Nitrogen Oxides (NOx)
Emission Limit(s): See Facility-Wide Conditions
Authority for Requirement: Iowa DNR Construction Permit 98-A-003-S1
Pollutant: Volatile Organic Compounds (VOC)
Emission Limit: See Facility-Wide Conditions
Authority for Requirement: Iowa DNR Construction Permit 98-A-003-S1
484
-------
Operational Limits & Requirements:
The owner/operator of this equipment shall comply with the following operational limits
and requirements.
Process throughput:
A. The sulfur content of natural gas or LPG combusted by this source is not to
exceed 123 ppm by weight.
Reporting & Recordkeeping: See Facility-Wide Operational Limits
Authority for Requirement: Part 7b. of State of Iowa, ex rel., Iowa DNR vs. Vermeer
Manufacturing Company, 99AG23542
District Court, Marion County, Law No. LACV087889
Compliance Plan:
The owner/operator of this equipment shall comply with the following applicable
requirements.
This point is in compliance with all applicable requirements and shall continue to comply
with all such requirements. For those applicable requirements which will become
effective during the permit term, this source will comply with such requirements in a
timely manner.
Periodic Monitoring Requirements:
The owner/operator of this equipment shall comply with the following periodic
monitoring requirements.
Agency Approved Operation & Maintenance Plan Required? Yes ~ No IXI
Facility Maintained Operation & Maintenance Plan Required? Yes ~ No Kl
Authority for Requirement: 567 IAC 22.108(3)"b"
485
-------
Emission Point ID Number: 7.PLASMA1
Associated Equipment
Associated Emission Unit ID Numbers (if multiple units vent thru this EP): 7.PLASMA1
Applicable Requirements
(If more than one emission unit vents through this emission point subdivide the applicable requirements by emission
unit.)
Emission Unit vented through this Emission Point: 7.PLASMA1 (Fugitive)
Emission Unit Description: Single Head Plasma Cutting
Machine
Raw Material/Fuel: Sheet Steel
Rated Capacity: 4,500 inches of metal cut/hr.
Emission Limits (lb./hr. gr./dscf. lb./MMBtu. % opacity, etc.):
The emissions from this emission point shall not exceed the following specified levels.
Pollutant: Fugitive Dust
Emission Limit: No person shall allow, cause or permit any materials to be handled,
transported or stored; or a building, its appurtenances or a construction haul road to
be used, constructed, altered , repaired or demolished, without taking reasonable
precautions to prevent a nuisance. All persons shall take reasonable precautions to
prevent the discharge of visible emissions of fugitive dusts beyond the lot line of the
property on which the emissions originate.
Authority for Requirement: 567 IAC 23.3(2)"c"
Compliance Plan:
The owner/operator of this equipment shall comply with the following applicable
requirements.
This point is in compliance with all applicable requirements and shall continue to comply
with all such requirements. For those applicable requirements which will become
effective during the permit term, this source will comply with such requirements in a
timely manner.
Periodic Monitoring Requirements:
The owner/operator of this equipment shall comply with the following periodic
monitoring requirements.
Agency Approved Operation & Maintenance Plan Required? Yes ~ No IXI
Facility Maintained Operation & Maintenance Plan Required? Yes ~ No Kl
Authority for Requirement: 567 IAC 22.108(3)"b"
486
-------
Emission Point ID Number: 7.PLASMA2
Associated Equipment
Associated Emission Unit ID Numbers (if multiple units vent thru this EP): 7.PLASMA2
Applicable Requirements
(If more than one emission unit vents through this emission point subdivide the applicable requirements by emission
unit.)
Emission Unit vented through this Emission Point: 7.PLASMA2 (Fugitive)
Emission Unit Description: Single Head Plasma Cutting
Machine
Raw Material/Fuel: Sheet Steel
Rated Capacity: 4,500 inches of metal cut/hr.
Emission Limits (lb./hr. gr./dscf. lb./MMBtu. % opacity, etc.):
The emissions from this emission point shall not exceed the following specified levels.
Pollutant: Fugitive Dust
Emission Limit: No person shall allow, cause or permit any materials to be handled,
transported or stored; or a building, its appurtenances or a construction haul road to
be used, constructed, altered , repaired or demolished, without taking reasonable
precautions to prevent a nuisance. All persons shall take reasonable precautions to
prevent the discharge of visible emissions of fugitive dusts beyond the lot line of the
property on which the emissions originate.
Authority for Requirement: 567 IAC 23.3(2)"c"
Compliance Plan:
The owner/operator of this equipment shall comply with the following applicable
requirements.
This point is in compliance with all applicable requirements and shall continue to comply
with all such requirements. For those applicable requirements which will become
effective during the permit term, this source will comply with such requirements in a
timely manner.
Periodic Monitoring Requirements:
The owner/operator of this equipment shall comply with the following periodic
monitoring requirements.
Agency Approved Operation & Maintenance Plan Required? Yes ~ No IXI
Facility Maintained Operation & Maintenance Plan Required? Yes ~ No Kl
Authority for Requirement: 567 IAC 22.108(3)"b"
487
-------
Emission Point ID Number: 7.PLASMA3
Associated Equipment
Associated Emission Unit ID Numbers (if multiple units vent thru this EP): 7.PLASMA3
Applicable Requirements
(If more than one emission unit vents through this emission point subdivide the applicable requirements by emission
unit.)
Emission Unit vented through this Emission Point: 7.PLASMA3 (Fugitive)
Emission Unit Description: Single Head Plasma Cutting
Machine
Raw Material/Fuel: Sheet Steel
Rated Capacity: 4,500 inches of metal cut/hr.
Emission Limits (lb./hr. gr./dscf. lb./MMBtu. % opacity, etc.):
The emissions from this emission point shall not exceed the following specified levels.
Pollutant: Fugitive Dust
Emission Limit: No person shall allow, cause or permit any materials to be handled,
transported or stored; or a building, its appurtenances or a construction haul road to
be used, constructed, altered , repaired or demolished, without taking reasonable
precautions to prevent a nuisance. All persons shall take reasonable precautions to
prevent the discharge of visible emissions of fugitive dusts beyond the lot line of the
property on which the emissions originate.
Authority for Requirement: 567 IAC 23.3(2)"c"
Compliance Plan:
The owner/operator of this equipment shall comply with the following applicable
requirements.
This point is in compliance with all applicable requirements and shall continue to comply
with all such requirements. For those applicable requirements which will become
effective during the permit term, this source will comply with such requirements in a
timely manner.
Periodic Monitoring Requirements:
The owner/operator of this equipment shall comply with the following periodic
monitoring requirements.
Agency Approved Operation & Maintenance Plan Required? Yes ~ No IXI
Facility Maintained Operation & Maintenance Plan Required? Yes ~ No Kl
Authority for Requirement: 567 IAC 22.108(3)"b"
488
-------
Emission Point ID Number: 7.PLASMA4
Associated Equipment
Associated Emission Unit ID Numbers (if multiple units vent thru this EP): 7.PLASMA4
Emissions Control Equipment ID Number: 7.PLASMA4
Emissions Control Equipment Description: Baghouse
Applicable Requirements
(If more than one emission unit vents through this emission point subdivide the applicable requirements by emission
unit.)
Emission Unit vented through this Emission Point: 7.PLASMA4 (Fugitive)
Emission Unit Description: Single Head Whitney Plasma Cutting
Machine
Raw Material/Fuel: Sheet Steel
Rated Capacity: 12,000 inches of metal cut/hr.
Emission Limits (lb./hr. gr./dscf. lb./MMBtu. % opacity, etc.):
The emissions from this emission point shall not exceed the following specified levels.
Pollutant: Fugitive Dust
Emission Limit: No person shall allow, cause or permit any materials to be handled,
transported or stored; or a building, its appurtenances or a construction haul road to
be used, constructed, altered , repaired or demolished, without taking reasonable
precautions to prevent a nuisance. All persons shall take reasonable precautions to
prevent the discharge of visible emissions of fugitive dusts beyond the lot line of the
property on which the emissions originate.
Authority for Requirement: 567 IAC 23.3(2)"c"
Compliance Plan:
The owner/operator of this equipment shall comply with the following applicable
requirements.
This point is in compliance with all applicable requirements and shall continue to comply
with all such requirements. For those applicable requirements which will become
effective during the permit term, this source will comply with such requirements in a
timely manner.
Periodic Monitoring Requirements:
The owner/operator of this equipment shall comply with the following periodic
monitoring requirements.
Agency Approved Operation & Maintenance Plan Required? Yes ~ No Kl
Facility Maintained Operation & Maintenance Plan Required? Yes ~ No Kl
Authority for Requirement: 567 IAC 22.108(3)"b"
489
-------
Emission Point ID Number: 7.PLASMA5
Associated Equipment
Associated Emission Unit ID Numbers (if multiple units vent thru this EP): 7.PLASMA5
Emissions Control Equipment ID Number: 7.PLASMA5
Emissions Control Equipment Description: Water Table
Applicable Requirements
(If more than one emission unit vents through this emission point subdivide the applicable requirements by emission
unit.)
Emission Unit vented through this Emission Point: 7.PLASMA5 (Fugitive)
Emission Unit Description: Single Head Whitney Plasma Cutting
Machine
Raw Material/Fuel: Sheet Steel
Rated Capacity: 12,000 inches of metal cut/hr.
Emission Limits (lb./hr. gr./dscf. lb./MMBtu. % opacity, etc.):
The emissions from this emission point shall not exceed the following specified levels.
Pollutant: Fugitive Dust
Emission Limit: No person shall allow, cause or permit any materials to be handled,
transported or stored; or a building, its appurtenances or a construction haul road to
be used, constructed, altered , repaired or demolished, without taking reasonable
precautions to prevent a nuisance. All persons shall take reasonable precautions to
prevent the discharge of visible emissions of fugitive dusts beyond the lot line of the
property on which the emissions originate.
Authority for Requirement: 567 IAC 23.3(2)"c"
Compliance Plan:
The owner/operator of this equipment shall comply with the following applicable
requirements.
This point is in compliance with all applicable requirements and shall continue to comply
with all such requirements. For those applicable requirements which will become
effective during the permit term, this source will comply with such requirements in a
timely manner.
Periodic Monitoring Requirements:
The owner/operator of this equipment shall comply with the following periodic
monitoring requirements.
Agency Approved Operation & Maintenance Plan Required? Yes ~ No Kl
Facility Maintained Operation & Maintenance Plan Required? Yes ~ No Kl
Authority for Requirement: 567 IAC 22.108(3)"b"
490
-------
Emission Point ID Number: 7.PLASMA6
Associated Equipment
Associated Emission Unit ID Numbers (if multiple units vent thru this EP): 7.PLASMA6
Emissions Control Equipment ID Number: 7.PLASMA6
Emissions Control Equipment Description: Water Table
Applicable Requirements
(If more than one emission unit vents through this emission point subdivide the applicable requirements by emission
unit.)
Emission Unit vented through this Emission Point: 7.PLASMA6 (Fugitive)
Emission Unit Description: Single Head Whitney Plasma Cutting
Machine
Raw Material/Fuel: Sheet Steel
Rated Capacity: 12,000 inches of metal cut/hr.
Emission Limits (lb./hr. gr./dscf. lb./MMBtu. % opacity, etc.):
The emissions from this emission point shall not exceed the following specified levels.
Pollutant: Fugitive Dust
Emission Limit: No person shall allow, cause or permit any materials to be handled,
transported or stored; or a building, its appurtenances or a construction haul road to
be used, constructed, altered , repaired or demolished, without taking reasonable
precautions to prevent a nuisance. All persons shall take reasonable precautions to
prevent the discharge of visible emissions of fugitive dusts beyond the lot line of the
property on which the emissions originate.
Authority for Requirement: 567 IAC 23.3(2)"c"
Compliance Plan:
The owner/operator of this equipment shall comply with the following applicable
requirements.
This point is in compliance with all applicable requirements and shall continue to comply
with all such requirements. For those applicable requirements which will become
effective during the permit term, this source will comply with such requirements in a
timely manner.
Periodic Monitoring Requirements:
The owner/operator of this equipment shall comply with the following periodic
monitoring requirements.
Agency Approved Operation & Maintenance Plan Required? Yes ~ No Kl
Facility Maintained Operation & Maintenance Plan Required? Yes ~ No Kl
Authority for Requirement: 567 IAC 22.108(3)"b"
491
-------
Emission Point ID Number: 7.PRTWSH
Associated Equipment
Associated Emission Unit ID Numbers (if multiple units vent thru this EP): 7.PRTWSH
Applicable Requirements
(If more than one emission unit vents through this emission point subdivide the applicable requirements by emission
unit.)
Emission Unit vented through this Emission Point: 7.PRTWSH (Fugitive)
Emission Unit Description: Three (3) Safety Kleen Parts
Washers
Raw Material/Fuel: Stoddard Solvent
Rated Capacity: 55 Gallons Solvent per Washer
Emission Limits (lb./hr. gr./dscf. lb./MMBtu. % opacity, etc.):
The emissions from this emission point shall not exceed the following specified levels.
Pollutant: Volatile Organic Compounds (VOC)
Emission Limit: See Facility-Wide Conditions
Authority for Requirement: Iowa DNR Construction Permit 98-A-003-S1
Compliance Plan:
The owner/operator of this equipment shall comply with the following applicable
requirements.
This point is in compliance with all applicable requirements and shall continue to comply
with all such requirements. For those applicable requirements which will become
effective during the permit term, this source will comply with such requirements in a
timely manner.
Periodic Monitoring Requirements:
The owner/operator of this equipment shall comply with the following periodic
monitoring requirements.
Agency Approved Operation & Maintenance Plan Required? Yes ~ No Kl
Facility Maintained Operation & Maintenance Plan Required? Yes ~ No Kl
Authority for Requirement: 567 IAC 22.108(3)"b"
492
-------
Emission Point ID Number: 7.Q
Associated Equipment
Associated Emission Unit ID Numbers (if multiple units vent thru this EP): 7.Q
Applicable Requirements
(If more than one emission unit vents through this emission point subdivide the applicable requirements by emission
unit.)
Emission Unit vented through this Emission Point: 7.Q
Emission Unit Description: Non-Production Heating Unit
Raw Material/Fuel: Natural Gas
Rated Capacity: 0.1 MMBtu/hr.
Emission Limits (lb./hr. gr./dscf. lb./MMBtu. % opacity, etc.):
The emissions from this emission point shall not exceed the following specified levels.
Pollutant: Opacity
Emission Limit(s): 40 %
Authority for Requirement: 567 IAC 23.3(2)"d"
Pollutant: Particulate Matter (TSP)
Emission Limit(s): 15.3 lb./MMCF of LPG or Natural Gas
Authority for Requirement: Part 7a. of State of Iowa, ex rel., Iowa DNR vs. Vermeer
Manufacturing Company, 99AG23542
District Court, Marion County, Law No. LACV087889
Pollutant: Particulate Matter (TSP)
Emission Limits: 0.8 lb./MMBtu
Authority for Requirement: 567 IAC 23.3(2)"b"
Pollutant: Sulfur Dioxide (SO2)
Emission Limits: 500 ppmv
Authority for Requirement: 567 IAC 23.3(3)"e"
Pollutant: Nitrogen Oxides (NOx)
Emission Limit(s): See Facility-Wide Conditions
Authority for Requirement: Iowa DNR Construction Permit 98-A-003-S1
Pollutant: Volatile Organic Compounds (VOC)
Emission Limit: See Facility-Wide Conditions
Authority for Requirement: Iowa DNR Construction Permit 98-A-003-S1
493
-------
Operational Limits & Requirements:
The owner/operator of this equipment shall comply with the following operational limits
and requirements.
Process throughput:
A. The sulfur content of natural gas or LPG combusted by this source is not to
exceed 123 ppm by weight.
Reporting & Recordkeeping: See Facility-Wide Operational Limits
Authority for Requirement: Part 7b. of State of Iowa, ex rel., Iowa DNR vs. Vermeer
Manufacturing Company, 99AG23542
District Court, Marion County, Law No. LACV087889
Compliance Plan:
The owner/operator of this equipment shall comply with the following applicable
requirements.
This point is in compliance with all applicable requirements and shall continue to comply
with all such requirements. For those applicable requirements which will become
effective during the permit term, this source will comply with such requirements in a
timely manner.
Periodic Monitoring Requirements:
The owner/operator of this equipment shall comply with the following periodic
monitoring requirements.
Agency Approved Operation & Maintenance Plan Required? Yes ~ No IXI
Facility Maintained Operation & Maintenance Plan Required? Yes ~ No Kl
Authority for Requirement: 567 IAC 22.108(3)"b"
494
-------
Emission Point ID Number: 7.R
Associated Equipment
Associated Emission Unit ID Numbers (if multiple units vent thru this EP): 7.R
Applicable Requirements
(If more than one emission unit vents through this emission point subdivide the applicable requirements by emission
unit.)
Emission Unit vented through this Emission Point: 7.R
Emission Unit Description: One (1) Safety Kleen Partswasher
Raw Material/Fuel: Stoddard Solvent
Rated Capacity: 55 Gallons Solvent
Emission Limits (lb./hr. gr./dscf. lb./MMBtu. % opacity, etc.):
The emissions from this emission point shall not exceed the following specified levels.
Pollutant: Volatile Organic Compounds (VOC)
Emission Limit: See Facility-Wide Conditions
Authority for Requirement: Iowa DNR Construction Permit 98-A-869-S1
Operational Limits & Requirements:
The owner/operator of this equipment shall comply with the following operational limits
and requirements.
Reporting & Record keeping:
All records, as required in the following, shall be satisfactory for demonstrating
compliance with all applicable operating limits.
Records shall be kept on-site for five years and shall be available for inspection by
the Department. Records shall be maintained in a legible and orderly manner and
shall indicate the following:
A. The amount of any solvent used in this unit, in gallons. Calculate and record
monthly and twelve (12) month rolling totals
B. The VOC content of any solvent used in this partswasher, in pounds per gallon.
Authority for Requirement: Iowa DNR Construction Permit 98-A-869-S1
Compliance Plan:
The owner/operator of this equipment shall comply with the following applicable
requirements.
This point is in compliance with all applicable requirements and shall continue to comply
with all such requirements. For those applicable requirements which will become
effective during the permit term, this source will comply with such requirements in a
timely manner.
495
-------
Additional Requirements:
This emission point shall conform to the following conditions.
The source is to be connected to the stack of the following detailed description.
Stack Height (feet): 25
Stack Diameter (inches): 12
Stack Exhaust Flow Rate (acfm): .... 1,000
Stack Temperature (°F): 68
Vertical, Unobstructed Discharge Required: Yes ~ No Kl
Authority for Requirement: Iowa DNR Construction Permit 98-A-869-S1
Periodic Monitoring Requirements:
The owner/operator of this equipment shall comply with the following periodic
monitoring requirements.
Agency Approved Operation & Maintenance Plan Required? Yes ~ No IEI
Facility Maintained Operation & Maintenance Plan Required? Yes ~ No IE
Authority for Requirement: 567 IAC 22.108(3)"b"
496
-------
Emission Point ID Number: 7.S
Associated Equipment
Associated Emission Unit ID Numbers (if multiple units vent thru this EP): 7. S
Applicable Requirements
(If more than one emission unit vents through this emission point subdivide the applicable requirements by emission
unit.)
Emission Unit vented through this Emission Point: 7.S
Emission Unit Description: Non-Production Heating Unit
Raw Material/Fuel: Propane (LPG) or Natural Gas
Rated Capacity: 2.75 MMBtu/hr.
Emission Limits (lb./hr. gr./dscf. lb./MMBtu. % opacity, etc.):
The emissions from this emission point shall not exceed the following specified levels.
Pollutant: Opacity
Emission Limit(s): 40 %
Authority for Requirement: 567 IAC 23.3(2)"d"
Pollutant: Particulate Matter (TSP)
Emission Limit(s): 15.3 lb./MMCF of LPG or Natural Gas
Authority for Requirement: Part 7a. of State of Iowa, ex rel., Iowa DNR vs. Vermeer
Manufacturing Company, 99AG23542
District Court, Marion County, Law No. LACV087889
Pollutant: Particulate Matter (TSP)
Emission Limits: 0.8 lb./MMBtu
Authority for Requirement: 567 IAC 23.3(2)"b"
Pollutant: Sulfur Dioxide (SO2)
Emission Limits: 500 ppmv
Authority for Requirement: 567 IAC 23.3(3)"e"
Pollutant: Nitrogen Oxides (NOx)
Emission Limit(s): See Facility-Wide Conditions
Authority for Requirement: Iowa DNR Construction Permit 98-A-003-S1
Pollutant: Volatile Organic Compounds (VOC)
Emission Limit: See Facility-Wide Conditions
Authority for Requirement: Iowa DNR Construction Permit 98-A-003-S1
497
-------
Operational Limits & Requirements:
The owner/operator of this equipment shall comply with the following operational limits
and requirements.
Process throughput:
A. The sulfur content of natural gas or LPG combusted by this source is not to
exceed 123 ppm by weight.
Reporting & Recordkeeping: See Facility-Wide Operational Limits
Authority for Requirement: Part 7b. of State of Iowa, ex rel., Iowa DNR vs. Vermeer
Manufacturing Company, 99AG23542
District Court, Marion County, Law No. LACV087889
Compliance Plan:
The owner/operator of this equipment shall comply with the following applicable
requirements.
This point is in compliance with all applicable requirements and shall continue to comply
with all such requirements. For those applicable requirements which will become
effective during the permit term, this source will comply with such requirements in a
timely manner.
Periodic Monitoring Requirements:
The owner/operator of this equipment shall comply with the following periodic
monitoring requirements.
Agency Approved Operation & Maintenance Plan Required? Yes ~ No IXI
Facility Maintained Operation & Maintenance Plan Required? Yes ~ No Kl
Authority for Requirement: 567 IAC 22.108(3)"b"
498
-------
Emission Point ID Number: 7.T
Associated Equipment
Associated Emission Unit ID Numbers (if multiple units vent thru this EP): 7.T
Applicable Requirements
(If more than one emission unit vents through this emission point subdivide the applicable requirements by emission
unit.)
Emission Unit vented through this Emission Point: 7.T
Emission Unit Description: Non-Production Heating Unit
Raw Material/Fuel: Propane (LPG) or Natural Gas
Rated Capacity: 7.50 MMBtu/hr.
Emission Limits (lb./hr. gr./dscf. lb./MMBtu. % opacity, etc.):
The emissions from this emission point shall not exceed the following specified levels.
Pollutant: Opacity
Emission Limit(s): 40 %
Authority for Requirement: 567 IAC 23.3(2)"d"
Pollutant: Particulate Matter (TSP)
Emission Limit(s): 15.3 lb./MMCF of LPG or Natural Gas
Authority for Requirement: Part 7a. of State of Iowa, ex rel., Iowa DNR vs. Vermeer
Manufacturing Company, 99AG23542
District Court, Marion County, Law No. LACV087889
Pollutant: Particulate Matter (TSP)
Emission Limits: 0.8 lb./MMBtu
Authority for Requirement: 567 IAC 23.3(2)"b"
Pollutant: Sulfur Dioxide (SO2)
Emission Limits: 500 ppmv
Authority for Requirement: 567 IAC 23.3(3)"e"
Pollutant: Nitrogen Oxides (NOx)
Emission Limit(s): See Facility-Wide Conditions
Authority for Requirement: Iowa DNR Construction Permit 98-A-003-S1
Pollutant: Volatile Organic Compounds (VOC)
Emission Limit: See Facility-Wide Conditions
Authority for Requirement: Iowa DNR Construction Permit 98-A-003-S1
499
-------
Operational Limits & Requirements:
The owner/operator of this equipment shall comply with the following operational limits
and requirements.
Process throughput:
A. The sulfur content of natural gas or LPG combusted by this source is not to
exceed 123 ppm by weight.
Reporting & Recordkeeping: See Facility-Wide Operational Limits
Authority for Requirement: Part 7b. of State of Iowa, ex rel., Iowa DNR vs. Vermeer
Manufacturing Company, 99AG23542
District Court, Marion County, Law No. LACV087889
Compliance Plan:
The owner/operator of this equipment shall comply with the following applicable
requirements.
This point is in compliance with all applicable requirements and shall continue to comply
with all such requirements. For those applicable requirements which will become
effective during the permit term, this source will comply with such requirements in a
timely manner.
Periodic Monitoring Requirements:
The owner/operator of this equipment shall comply with the following periodic
monitoring requirements.
Agency Approved Operation & Maintenance Plan Required? Yes ~ No IXI
Facility Maintained Operation & Maintenance Plan Required? Yes ~ No Kl
Authority for Requirement: 567 IAC 22.108(3)"b"
500
-------
Emission Point ID Number: 7.TORCH
Associated Equipment
Associated Emission Unit ID Numbers (if multiple units vent thru this EP): 7.TORCH
Applicable Requirements
(If more than one emission unit vents through this emission point subdivide the applicable requirements by emission
unit.)
Emission Unit vented through this Emission Point: 7.TORCH (Fugitive)
Emission Unit Description: Ten (10) Single Cutting Head
Oxyacetylene Torch Units
Raw Material/Fuel: Sheet Steel
Rated Capacity: 840 inches of metal cut/hr. per Head
Emission Limits (lb./hr. gr./dscf. lb./MMBtu. % opacity, etc.):
The emissions from this emission point shall not exceed the following specified levels.
Pollutant: Fugitive Dust
Emission Limit: No person shall allow, cause or permit any materials to be handled,
transported or stored; or a building, its appurtenances or a construction haul road to
be used, constructed, altered , repaired or demolished, without taking reasonable
precautions to prevent a nuisance. All persons shall take reasonable precautions to
prevent the discharge of visible emissions of fugitive dusts beyond the lot line of the
property on which the emissions originate.
Authority for Requirement: 567 IAC 23.3(2)"c"
Compliance Plan:
The owner/operator of this equipment shall comply with the following applicable
requirements.
This point is in compliance with all applicable requirements and shall continue to comply
with all such requirements. For those applicable requirements which will become
effective during the permit term, this source will comply with such requirements in a
timely manner.
Periodic Monitoring Requirements:
The owner/operator of this equipment shall comply with the following periodic
monitoring requirements.
Agency Approved Operation & Maintenance Plan Required? Yes ~ No IXI
Facility Maintained Operation & Maintenance Plan Required? Yes ~ No Kl
Authority for Requirement: 567 IAC 22.108(3)"b"
501
-------
Emission Point ID Number: 7.U
Associated Equipment
Associated Emission Unit ID Numbers (if multiple units vent thru this EP): 7.U
Applicable Requirements
(If more than one emission unit vents through this emission point subdivide the applicable requirements by emission
unit.)
Emission Unit vented through this Emission Point: 7.U
Emission Unit Description: Non-Production Heating Unit
Raw Material/Fuel: Propane (LPG) or Natural Gas
Rated Capacity: 0.054 MMBtu/hr.
Emission Limits (lb./hr. gr./dscf. lb./MMBtu. % opacity, etc.):
The emissions from this emission point shall not exceed the following specified levels.
Pollutant: Opacity
Emission Limit(s): 40 %
Authority for Requirement: 567 IAC 23.3(2)"d"
Pollutant: Particulate Matter (TSP)
Emission Limit(s): 15.3 lb./MMCF of LPG or Natural Gas
Authority for Requirement: Part 7a. of State of Iowa, ex rel., Iowa DNR vs. Vermeer
Manufacturing Company, 99AG23542
District Court, Marion County, Law No. LACV087889
Pollutant: Particulate Matter (TSP)
Emission Limits: 0.8 lb./MMBtu
Authority for Requirement: 567 IAC 23.3(2)"b"
Pollutant: Sulfur Dioxide (SO2)
Emission Limits: 500 ppmv
Authority for Requirement: 567 IAC 23.3(3)"e"
Pollutant: Nitrogen Oxides (NOx)
Emission Limit(s): See Facility-Wide Conditions
Authority for Requirement: Iowa DNR Construction Permit 98-A-003-S1
Pollutant: Volatile Organic Compounds (VOC)
Emission Limit: See Facility-Wide Conditions
Authority for Requirement: Iowa DNR Construction Permit 98-A-003-S1
502
-------
Operational Limits & Requirements:
The owner/operator of this equipment shall comply with the following operational limits
and requirements.
Process throughput:
A. The sulfur content of natural gas or LPG combusted by this source is not to
exceed 123 ppm by weight.
Reporting & Recordkeeping: See Facility-Wide Operational Limits
Authority for Requirement: Part 7b. of State of Iowa, ex rel., Iowa DNR vs. Vermeer
Manufacturing Company, 99AG23542
District Court, Marion County, Law No. LACV087889
Compliance Plan:
The owner/operator of this equipment shall comply with the following applicable
requirements.
This point is in compliance with all applicable requirements and shall continue to comply
with all such requirements. For those applicable requirements which will become
effective during the permit term, this source will comply with such requirements in a
timely manner.
Periodic Monitoring Requirements:
The owner/operator of this equipment shall comply with the following periodic
monitoring requirements.
Agency Approved Operation & Maintenance Plan Required? Yes ~ No IXI
Facility Maintained Operation & Maintenance Plan Required? Yes ~ No Kl
Authority for Requirement: 567 IAC 22.108(3)"b"
503
-------
Emission Point ID Number: 7.V
Associated Equipment
Associated Emission Unit ID Numbers (if multiple units vent thru this EP): 7. V
Applicable Requirements
(If more than one emission unit vents through this emission point subdivide the applicable requirements by emission
unit.)
Emission Unit vented through this Emission Point: 7.V
Emission Unit Description: Non-Production Heating Unit
Raw Material/Fuel: Propane (LPG) or Natural Gas
Rated Capacity: 0.054 MMBtu/hr.
Emission Limits (lb./hr. gr./dscf. lb./MMBtu. % opacity, etc.):
The emissions from this emission point shall not exceed the following specified levels.
Pollutant: Opacity
Emission Limit(s): 40 %
Authority for Requirement: 567 IAC 23.3(2)"d"
Pollutant: Particulate Matter (TSP)
Emission Limit(s): 15.3 lb./MMCF of LPG or Natural Gas
Authority for Requirement: Part 7a. of State of Iowa, ex rel., Iowa DNR vs. Vermeer
Manufacturing Company, 99AG23542
District Court, Marion County, Law No. LACV087889
Pollutant: Particulate Matter (TSP)
Emission Limits: 0.8 lb./MMBtu
Authority for Requirement: 567 IAC 23.3(2)"b"
Pollutant: Sulfur Dioxide (SO2)
Emission Limits: 500 ppmv
Authority for Requirement: 567 IAC 23.3(3)"e"
Pollutant: Nitrogen Oxides (NOx)
Emission Limit(s): See Facility-Wide Conditions
Authority for Requirement: Iowa DNR Construction Permit 98-A-003-S1
Pollutant: Volatile Organic Compounds (VOC)
Emission Limit: See Facility-Wide Conditions
Authority for Requirement: Iowa DNR Construction Permit 98-A-003-S1
504
-------
Operational Limits & Requirements:
The owner/operator of this equipment shall comply with the following operational limits
and requirements.
Process throughput:
A. The sulfur content of natural gas or LPG combusted by this source is not to
exceed 123 ppm by weight.
Reporting & Recordkeeping: See Facility-Wide Operational Limits
Authority for Requirement: Part 7b. of State of Iowa, ex rel., Iowa DNR vs. Vermeer
Manufacturing Company, 99AG23542
District Court, Marion County, Law No. LACV087889
Compliance Plan:
The owner/operator of this equipment shall comply with the following applicable
requirements.
This point is in compliance with all applicable requirements and shall continue to comply
with all such requirements. For those applicable requirements which will become
effective during the permit term, this source will comply with such requirements in a
timely manner.
Periodic Monitoring Requirements:
The owner/operator of this equipment shall comply with the following periodic
monitoring requirements.
Agency Approved Operation & Maintenance Plan Required? Yes ~ No IXI
Facility Maintained Operation & Maintenance Plan Required? Yes ~ No Kl
Authority for Requirement: 567 IAC 22.108(3)"b"
505
-------
Emission Point ID Number: 7.WELDING
Associated Equipment
Associated Emission Unit ID Numbers (if multiple units vent thru this EP): 7. WELDING
Applicable Requirements
(If more than one emission unit vents through this emission point subdivide the applicable requirements by emission
unit.)
Emission Unit vented through this Emission Point: 7.WELDING (Fugitive)
Emission Unit Description: 61 GMAW Units
Raw Material/Fuel: E70S Weld Wire
Rated Capacity: 19 lb. ofWire/hr. per Unit
Emission Limits (lb./hr. gr./dscf. lb./MMBtu. % opacity, etc.):
The emissions from this emission point shall not exceed the following specified levels.
Pollutant: Fugitive Dust
Emission Limit: No person shall allow, cause or permit any materials to be handled,
transported or stored; or a building, its appurtenances or a construction haul road to
be used, constructed, altered , repaired or demolished, without taking reasonable
precautions to prevent a nuisance. All persons shall take reasonable precautions to
prevent the discharge of visible emissions of fugitive dusts beyond the lot line of the
property on which the emissions originate.
Authority for Requirement: 567 IAC 23.3(2)"c"
Compliance Plan:
The owner/operator of this equipment shall comply with the following applicable
requirements.
This point is in compliance with all applicable requirements and shall continue to comply
with all such requirements. For those applicable requirements which will become
effective during the permit term, this source will comply with such requirements in a
timely manner.
Periodic Monitoring Requirements:
The owner/operator of this equipment shall comply with the following periodic
monitoring requirements.
Agency Approved Operation & Maintenance Plan Required? Yes ~ No Kl
Facility Maintained Operation & Maintenance Plan Required? Yes ~ No Kl
Authority for Requirement: 567 IAC 22.108(3)"b"
506
-------
Emission Point ID Number: 7.WELDPLS
Associated Equipment
Associated Emission Unit ID Numbers (if multiple units vent thru this EP): 7. WELDPLS
Applicable Requirements
(If more than one emission unit vents through this emission point subdivide the applicable requirements by emission
unit.)
Emission Unit vented through this Emission Point: 7.WELDPLS (Fugitive)
Emission Unit Description: 47 Pulse Current GMAW Units
Raw Material/Fuel: E70S Weld Wire
Rated Capacity: 19 lb. ofWire/hr. per Unit
Emission Limits (lb./hr. gr./dscf. lb./MMBtu. % opacity, etc.):
The emissions from this emission point shall not exceed the following specified levels.
Pollutant: Fugitive Dust
Emission Limit: No person shall allow, cause or permit any materials to be handled,
transported or stored; or a building, its appurtenances or a construction haul road to
be used, constructed, altered , repaired or demolished, without taking reasonable
precautions to prevent a nuisance. All persons shall take reasonable precautions to
prevent the discharge of visible emissions of fugitive dusts beyond the lot line of the
property on which the emissions originate.
Authority for Requirement: 567 IAC 23.3(2)"c"
Compliance Plan:
The owner/operator of this equipment shall comply with the following applicable
requirements.
This point is in compliance with all applicable requirements and shall continue to comply
with all such requirements. For those applicable requirements which will become
effective during the permit term, this source will comply with such requirements in a
timely manner.
Periodic Monitoring Requirements:
The owner/operator of this equipment shall comply with the following periodic
monitoring requirements.
Agency Approved Operation & Maintenance Plan Required? Yes ~ No Kl
Facility Maintained Operation & Maintenance Plan Required? Yes ~ No Kl
Authority for Requirement: 567 IAC 22.108(3)"b"
507
-------
Emission Point ID Number: 8.A1
Associated Equipment
Associated Emission Unit ID Numbers (if multiple units vent thru this EP): 8. A1
Applicable Requirements
(If more than one emission unit vents through this emission point subdivide the applicable requirements by emission
unit.)
Emission Unit vented through this Emission Point: 8.A1
Emission Unit Description: Non-Production Heating Unit
Raw Material/Fuel: Propane (LPG) or Natural Gas
Rated Capacity: 0.4 MMBtu/hr.
Emission Limits (lb./hr. gr./dscf. lb./MMBtu. % opacity, etc.):
The emissions from this emission point shall not exceed the following specified levels.
Pollutant: Opacity
Emission Limit(s): 40 %
Authority for Requirement: 567 IAC 23.3(2)"d"
Pollutant: Particulate Matter (TSP)
Emission Limit(s): 15.3 lb./MMCF of LPG or Natural Gas
Authority for Requirement: Part 7a. of State of Iowa, ex rel., Iowa DNR vs. Vermeer
Manufacturing Company, 99AG23542
District Court, Marion County, Law No. LACV087889
Pollutant: Particulate Matter (TSP)
Emission Limits: 0.8 lb./MMBtu
Authority for Requirement: 567 IAC 23.3(2)"b"
Pollutant: Sulfur Dioxide (SO2)
Emission Limits: 500 ppmv
Authority for Requirement: 567 IAC 23.3(3)"e"
Pollutant: Nitrogen Oxides (NOx)
Emission Limit(s): See Facility-Wide Conditions
Authority for Requirement: Iowa DNR Construction Permit 98-A-003-S1
Pollutant: Volatile Organic Compounds (VOC)
Emission Limit: See Facility-Wide Conditions
Authority for Requirement: Iowa DNR Construction Permit 98-A-003-S1
508
-------
Operational Limits & Requirements:
The owner/operator of this equipment shall comply with the following operational limits
and requirements.
Process throughput:
A. The sulfur content of natural gas or LPG combusted by this source is not to
exceed 123 ppm by weight.
Reporting & Recordkeeping: See Facility-Wide Operational Limits
Authority for Requirement: Part 7b. of State of Iowa, ex rel., Iowa DNR vs. Vermeer
Manufacturing Company, 99AG23542
District Court, Marion County, Law No. LACV087889
Compliance Plan:
The owner/operator of this equipment shall comply with the following applicable
requirements.
This point is in compliance with all applicable requirements and shall continue to comply
with all such requirements. For those applicable requirements which will become
effective during the permit term, this source will comply with such requirements in a
timely manner.
Periodic Monitoring Requirements:
The owner/operator of this equipment shall comply with the following periodic
monitoring requirements.
Agency Approved Operation & Maintenance Plan Required? Yes ~ No IXI
Facility Maintained Operation & Maintenance Plan Required? Yes ~ No Kl
Authority for Requirement: 567 IAC 22.108(3)"b"
509
-------
Emission Point ID Number: 8.A2
Associated Equipment
Associated Emission Unit ID Numbers (if multiple units vent thru this EP): 8. A2
Applicable Requirements
(If more than one emission unit vents through this emission point subdivide the applicable requirements by emission
unit.)
Emission Unit vented through this Emission Point: 8.A2
Emission Unit Description: Non-Production Heating Unit
Raw Material/Fuel: Propane (LPG) or Natural Gas
Rated Capacity: 0.4 MMBtu/hr.
Emission Limits (lb./hr. gr./dscf. lb./MMBtu. % opacity, etc.):
The emissions from this emission point shall not exceed the following specified levels.
Pollutant: Opacity
Emission Limit(s): 40 %
Authority for Requirement: 567 IAC 23.3(2)"d"
Pollutant: Particulate Matter (TSP)
Emission Limit(s): 15.3 lb./MMCF of LPG or Natural Gas
Authority for Requirement: Part 7a. of State of Iowa, ex rel., Iowa DNR vs. Vermeer
Manufacturing Company, 99AG23542
District Court, Marion County, Law No. LACV087889
Pollutant: Particulate Matter (TSP)
Emission Limits: 0.8 lb./MMBtu
Authority for Requirement: 567 IAC 23.3(2)"b"
Pollutant: Sulfur Dioxide (SO2)
Emission Limits: 500 ppmv
Authority for Requirement: 567 IAC 23.3(3)"e"
Pollutant: Nitrogen Oxides (NOx)
Emission Limit(s): See Facility-Wide Conditions
Authority for Requirement: Iowa DNR Construction Permit 98-A-003-S1
Pollutant: Volatile Organic Compounds (VOC)
Emission Limit: See Facility-Wide Conditions
Authority for Requirement: Iowa DNR Construction Permit 98-A-003-S1
510
-------
Operational Limits & Requirements:
The owner/operator of this equipment shall comply with the following operational limits
and requirements.
Process throughput:
A. The sulfur content of natural gas or LPG combusted by this source is not to
exceed 123 ppm by weight.
Reporting & Recordkeeping: See Facility-Wide Operational Limits
Authority for Requirement: Part 7b. of State of Iowa, ex rel., Iowa DNR vs. Vermeer
Manufacturing Company, 99AG23542
District Court, Marion County, Law No. LACV087889
Compliance Plan:
The owner/operator of this equipment shall comply with the following applicable
requirements.
This point is in compliance with all applicable requirements and shall continue to comply
with all such requirements. For those applicable requirements which will become
effective during the permit term, this source will comply with such requirements in a
timely manner.
Periodic Monitoring Requirements:
The owner/operator of this equipment shall comply with the following periodic
monitoring requirements.
Agency Approved Operation & Maintenance Plan Required? Yes ~ No IXI
Facility Maintained Operation & Maintenance Plan Required? Yes ~ No Kl
Authority for Requirement: 567 IAC 22.108(3)"b"
511
-------
Emission Point ID Number: 8.A3
Associated Equipment
Associated Emission Unit ID Numbers (if multiple units vent thru this EP): 8. A3
Applicable Requirements
(If more than one emission unit vents through this emission point subdivide the applicable requirements by emission
unit.)
Emission Unit vented through this Emission Point: 8.A3
Emission Unit Description: Non-Production Heating Unit
Raw Material/Fuel: Propane (LPG) or Natural Gas
Rated Capacity: 0.4 MMBtu/hr.
Emission Limits (lb./hr. gr./dscf. lb./MMBtu. % opacity, etc.):
The emissions from this emission point shall not exceed the following specified levels.
Pollutant: Opacity
Emission Limit(s): 40 %
Authority for Requirement: 567 IAC 23.3(2)"d"
Pollutant: Particulate Matter (TSP)
Emission Limit(s): 15.3 lb./MMCF of LPG or Natural Gas
Authority for Requirement: Part 7a. of State of Iowa, ex rel., Iowa DNR vs. Vermeer
Manufacturing Company, 99AG23542
District Court, Marion County, Law No. LACV087889
Pollutant: Particulate Matter (TSP)
Emission Limits: 0.8 lb./MMBtu
Authority for Requirement: 567 IAC 23.3(2)"b"
Pollutant: Sulfur Dioxide (SO2)
Emission Limits: 500 ppmv
Authority for Requirement: 567 IAC 23.3(3)"e"
Pollutant: Nitrogen Oxides (NOx)
Emission Limit(s): See Facility-Wide Conditions
Authority for Requirement: Iowa DNR Construction Permit 98-A-003-S1
Pollutant: Volatile Organic Compounds (VOC)
Emission Limit: See Facility-Wide Conditions
Authority for Requirement: Iowa DNR Construction Permit 98-A-003-S1
512
-------
Operational Limits & Requirements:
The owner/operator of this equipment shall comply with the following operational limits
and requirements.
Process throughput:
A. The sulfur content of natural gas or LPG combusted by this source is not to
exceed 123 ppm by weight.
Reporting & Recordkeeping: See Facility-Wide Operational Limits
Authority for Requirement: Part 7b. of State of Iowa, ex rel., Iowa DNR vs. Vermeer
Manufacturing Company, 99AG23542
District Court, Marion County, Law No. LACV087889
Compliance Plan:
The owner/operator of this equipment shall comply with the following applicable
requirements.
This point is in compliance with all applicable requirements and shall continue to comply
with all such requirements. For those applicable requirements which will become
effective during the permit term, this source will comply with such requirements in a
timely manner.
Periodic Monitoring Requirements:
The owner/operator of this equipment shall comply with the following periodic
monitoring requirements.
Agency Approved Operation & Maintenance Plan Required? Yes ~ No IXI
Facility Maintained Operation & Maintenance Plan Required? Yes ~ No Kl
Authority for Requirement: 567 IAC 22.108(3)"b"
513
-------
Emission Point ID Number: 8.A4
Associated Equipment
Associated Emission Unit ID Numbers (if multiple units vent thru this EP): 8. A4
Applicable Requirements
(If more than one emission unit vents through this emission point subdivide the applicable requirements by emission
unit.)
Emission Unit vented through this Emission Point: 8.A4
Emission Unit Description: Non-Production Heating Unit
Raw Material/Fuel: Propane (LPG) or Natural Gas
Rated Capacity: 0.4 MMBtu/hr.
Emission Limits (lb./hr. gr./dscf. lb./MMBtu. % opacity, etc.):
The emissions from this emission point shall not exceed the following specified levels.
Pollutant: Opacity
Emission Limit(s): 40 %
Authority for Requirement: 567 IAC 23.3(2)"d"
Pollutant: Particulate Matter (TSP)
Emission Limit(s): 15.3 lb./MMCF of LPG or Natural Gas
Authority for Requirement: Part 7a. of State of Iowa, ex rel., Iowa DNR vs. Vermeer
Manufacturing Company, 99AG23542
District Court, Marion County, Law No. LACV087889
Pollutant: Particulate Matter (TSP)
Emission Limits: 0.8 lb./MMBtu
Authority for Requirement: 567 IAC 23.3(2)"b"
Pollutant: Sulfur Dioxide (SO2)
Emission Limits: 500 ppmv
Authority for Requirement: 567 IAC 23.3(3)"e"
Pollutant: Nitrogen Oxides (NOx)
Emission Limit(s): See Facility-Wide Conditions
Authority for Requirement: Iowa DNR Construction Permit 98-A-003-S1
Pollutant: Volatile Organic Compounds (VOC)
Emission Limit: See Facility-Wide Conditions
Authority for Requirement: Iowa DNR Construction Permit 98-A-003-S1
514
-------
Operational Limits & Requirements:
The owner/operator of this equipment shall comply with the following operational limits
and requirements.
Process throughput:
A. The sulfur content of natural gas or LPG combusted by this source is not to
exceed 123 ppm by weight.
Reporting & Recordkeeping: See Facility-Wide Operational Limits
Authority for Requirement: Part 7b. of State of Iowa, ex rel., Iowa DNR vs. Vermeer
Manufacturing Company, 99AG23542
District Court, Marion County, Law No. LACV087889
Compliance Plan:
The owner/operator of this equipment shall comply with the following applicable
requirements.
This point is in compliance with all applicable requirements and shall continue to comply
with all such requirements. For those applicable requirements which will become
effective during the permit term, this source will comply with such requirements in a
timely manner.
Periodic Monitoring Requirements:
The owner/operator of this equipment shall comply with the following periodic
monitoring requirements.
Agency Approved Operation & Maintenance Plan Required? Yes ~ No IXI
Facility Maintained Operation & Maintenance Plan Required? Yes ~ No Kl
Authority for Requirement: 567 IAC 22.108(3)"b"
515
-------
Emission Point ID Number: 8.A5
Associated Equipment
Associated Emission Unit ID Numbers (if multiple units vent thru this EP): 8. A5
Applicable Requirements
(If more than one emission unit vents through this emission point subdivide the applicable requirements by emission
unit.)
Emission Unit vented through this Emission Point: 8.A5
Emission Unit Description: Non-Production Heating Unit
Raw Material/Fuel: Propane (LPG) or Natural Gas
Rated Capacity: 0.4 MMBtu/hr.
Emission Limits (lb./hr. gr./dscf. lb./MMBtu. % opacity, etc.):
The emissions from this emission point shall not exceed the following specified levels.
Pollutant: Opacity
Emission Limit(s): 40 %
Authority for Requirement: 567 IAC 23.3(2)"d"
Pollutant: Particulate Matter (TSP)
Emission Limit(s): 15.3 lb./MMCF of LPG or Natural Gas
Authority for Requirement: Part 7a. of State of Iowa, ex rel., Iowa DNR vs. Vermeer
Manufacturing Company, 99AG23542
District Court, Marion County, Law No. LACV087889
Pollutant: Particulate Matter (TSP)
Emission Limits: 0.8 lb./MMBtu
Authority for Requirement: 567 IAC 23.3(2)"b"
Pollutant: Sulfur Dioxide (SO2)
Emission Limits: 500 ppmv
Authority for Requirement: 567 IAC 23.3(3)"e"
Pollutant: Nitrogen Oxides (NOx)
Emission Limit(s): See Facility-Wide Conditions
Authority for Requirement: Iowa DNR Construction Permit 98-A-003-S1
Pollutant: Volatile Organic Compounds (VOC)
Emission Limit: See Facility-Wide Conditions
Authority for Requirement: Iowa DNR Construction Permit 98-A-003-S1
516
-------
Operational Limits & Requirements:
The owner/operator of this equipment shall comply with the following operational limits
and requirements.
Process throughput:
A. The sulfur content of natural gas or LPG combusted by this source is not to
exceed 123 ppm by weight.
Reporting & Recordkeeping: See Facility-Wide Operational Limits
Authority for Requirement: Part 7b. of State of Iowa, ex rel., Iowa DNR vs. Vermeer
Manufacturing Company, 99AG23542
District Court, Marion County, Law No. LACV087889
Compliance Plan:
The owner/operator of this equipment shall comply with the following applicable
requirements.
This point is in compliance with all applicable requirements and shall continue to comply
with all such requirements. For those applicable requirements which will become
effective during the permit term, this source will comply with such requirements in a
timely manner.
Periodic Monitoring Requirements:
The owner/operator of this equipment shall comply with the following periodic
monitoring requirements.
Agency Approved Operation & Maintenance Plan Required? Yes ~ No IXI
Facility Maintained Operation & Maintenance Plan Required? Yes ~ No Kl
Authority for Requirement: 567 IAC 22.108(3)"b"
517
-------
Emission Point ID Number: 8.A6
Associated Equipment
Associated Emission Unit ID Numbers (if multiple units vent thru this EP): 8. A6
Applicable Requirements
(If more than one emission unit vents through this emission point subdivide the applicable requirements by emission
unit.)
Emission Unit vented through this Emission Point: 8.A6
Emission Unit Description: Non-Production Heating Unit
Raw Material/Fuel: Propane (LPG) or Natural Gas
Rated Capacity: 0.4 MMBtu/hr.
Emission Limits (lb./hr. gr./dscf. lb./MMBtu. % opacity, etc.):
The emissions from this emission point shall not exceed the following specified levels.
Pollutant: Opacity
Emission Limit(s): 40 %
Authority for Requirement: 567 IAC 23.3(2)"d"
Pollutant: Particulate Matter (TSP)
Emission Limit(s): 15.3 lb./MMCF of LPG or Natural Gas
Authority for Requirement: Part 7a. of State of Iowa, ex rel., Iowa DNR vs. Vermeer
Manufacturing Company, 99AG23542
District Court, Marion County, Law No. LACV087889
Pollutant: Particulate Matter (TSP)
Emission Limits: 0.8 lb./MMBtu
Authority for Requirement: 567 IAC 23.3(2)"b"
Pollutant: Sulfur Dioxide (SO2)
Emission Limits: 500 ppmv
Authority for Requirement: 567 IAC 23.3(3)"e"
Pollutant: Nitrogen Oxides (NOx)
Emission Limit(s): See Facility-Wide Conditions
Authority for Requirement: Iowa DNR Construction Permit 98-A-003-S1
Pollutant: Volatile Organic Compounds (VOC)
Emission Limit: See Facility-Wide Conditions
Authority for Requirement: Iowa DNR Construction Permit 98-A-003-S1
518
-------
Operational Limits & Requirements:
The owner/operator of this equipment shall comply with the following operational limits
and requirements.
Process throughput:
A. The sulfur content of natural gas or LPG combusted by this source is not to
exceed 123 ppm by weight.
Reporting & Recordkeeping: See Facility-Wide Operational Limits
Authority for Requirement: Part 7b. of State of Iowa, ex rel., Iowa DNR vs. Vermeer
Manufacturing Company, 99AG23542
District Court, Marion County, Law No. LACV087889
Compliance Plan:
The owner/operator of this equipment shall comply with the following applicable
requirements.
This point is in compliance with all applicable requirements and shall continue to comply
with all such requirements. For those applicable requirements which will become
effective during the permit term, this source will comply with such requirements in a
timely manner.
Periodic Monitoring Requirements:
The owner/operator of this equipment shall comply with the following periodic
monitoring requirements.
Agency Approved Operation & Maintenance Plan Required? Yes ~ No IXI
Facility Maintained Operation & Maintenance Plan Required? Yes ~ No Kl
Authority for Requirement: 567 IAC 22.108(3)"b"
519
-------
Emission Point ID Number: 8.A7
Associated Equipment
Associated Emission Unit ID Numbers (if multiple units vent thru this EP): 8. A7
Applicable Requirements
(If more than one emission unit vents through this emission point subdivide the applicable requirements by emission
unit.)
Emission Unit vented through this Emission Point: 8.A7
Emission Unit Description: Non-Production Heating Unit
Raw Material/Fuel: Propane (LPG) or Natural Gas
Rated Capacity: 0.4 MMBtu/hr.
Emission Limits (lb./hr. gr./dscf. lb./MMBtu. % opacity, etc.):
The emissions from this emission point shall not exceed the following specified levels.
Pollutant: Opacity
Emission Limit(s): 40 %
Authority for Requirement: 567 IAC 23.3(2)"d"
Pollutant: Particulate Matter (TSP)
Emission Limit(s): 15.3 lb./MMCF of LPG or Natural Gas
Authority for Requirement: Part 7a. of State of Iowa, ex rel., Iowa DNR vs. Vermeer
Manufacturing Company, 99AG23542
District Court, Marion County, Law No. LACV087889
Pollutant: Particulate Matter (TSP)
Emission Limits: 0.8 lb./MMBtu
Authority for Requirement: 567 IAC 23.3(2)"b"
Pollutant: Sulfur Dioxide (SO2)
Emission Limits: 500 ppmv
Authority for Requirement: 567 IAC 23.3(3)"e"
Pollutant: Nitrogen Oxides (NOx)
Emission Limit(s): See Facility-Wide Conditions
Authority for Requirement: Iowa DNR Construction Permit 98-A-003-S1
Pollutant: Volatile Organic Compounds (VOC)
Emission Limit: See Facility-Wide Conditions
Authority for Requirement: Iowa DNR Construction Permit 98-A-003-S1
520
-------
Operational Limits & Requirements:
The owner/operator of this equipment shall comply with the following operational limits
and requirements.
Process throughput:
A. The sulfur content of natural gas or LPG combusted by this source is not to
exceed 123 ppm by weight.
Reporting & Recordkeeping: See Facility-Wide Operational Limits
Authority for Requirement: Part 7b. of State of Iowa, ex rel., Iowa DNR vs. Vermeer
Manufacturing Company, 99AG23542
District Court, Marion County, Law No. LACV087889
Compliance Plan:
The owner/operator of this equipment shall comply with the following applicable
requirements.
This point is in compliance with all applicable requirements and shall continue to comply
with all such requirements. For those applicable requirements which will become
effective during the permit term, this source will comply with such requirements in a
timely manner.
Periodic Monitoring Requirements:
The owner/operator of this equipment shall comply with the following periodic
monitoring requirements.
Agency Approved Operation & Maintenance Plan Required? Yes ~ No IXI
Facility Maintained Operation & Maintenance Plan Required? Yes ~ No Kl
Authority for Requirement: 567 IAC 22.108(3)"b"
521
-------
Emission Point ID Number: 8.A8
Associated Equipment
Associated Emission Unit ID Numbers (if multiple units vent thru this EP): 8. A8
Applicable Requirements
(If more than one emission unit vents through this emission point subdivide the applicable requirements by emission
unit.)
Emission Unit vented through this Emission Point: 8.A8
Emission Unit Description: Non-Production Heating Unit
Raw Material/Fuel: Propane (LPG) or Natural Gas
Rated Capacity: 0.4 MMBtu/hr.
Emission Limits (lb./hr. gr./dscf. lb./MMBtu. % opacity, etc.):
The emissions from this emission point shall not exceed the following specified levels.
Pollutant: Opacity
Emission Limit(s): 40 %
Authority for Requirement: 567 IAC 23.3(2)"d"
Pollutant: Particulate Matter (TSP)
Emission Limit(s): 15.3 lb./MMCF of LPG or Natural Gas
Authority for Requirement: Part 7a. of State of Iowa, ex rel., Iowa DNR vs. Vermeer
Manufacturing Company, 99AG23542
District Court, Marion County, Law No. LACV087889
Pollutant: Particulate Matter (TSP)
Emission Limits: 0.8 lb./MMBtu
Authority for Requirement: 567 IAC 23.3(2)"b"
Pollutant: Sulfur Dioxide (SO2)
Emission Limits: 500 ppmv
Authority for Requirement: 567 IAC 23.3(3)"e"
Pollutant: Nitrogen Oxides (NOx)
Emission Limit(s): See Facility-Wide Conditions
Authority for Requirement: Iowa DNR Construction Permit 98-A-003-S1
Pollutant: Volatile Organic Compounds (VOC)
Emission Limit: See Facility-Wide Conditions
Authority for Requirement: Iowa DNR Construction Permit 98-A-003-S1
522
-------
Operational Limits & Requirements:
The owner/operator of this equipment shall comply with the following operational limits
and requirements.
Process throughput:
A. The sulfur content of natural gas or LPG combusted by this source is not to
exceed 123 ppm by weight.
Reporting & Recordkeeping: See Facility-Wide Operational Limits
Authority for Requirement: Part 7b. of State of Iowa, ex rel., Iowa DNR vs. Vermeer
Manufacturing Company, 99AG23542
District Court, Marion County, Law No. LACV087889
Compliance Plan:
The owner/operator of this equipment shall comply with the following applicable
requirements.
This point is in compliance with all applicable requirements and shall continue to comply
with all such requirements. For those applicable requirements which will become
effective during the permit term, this source will comply with such requirements in a
timely manner.
Periodic Monitoring Requirements:
The owner/operator of this equipment shall comply with the following periodic
monitoring requirements.
Agency Approved Operation & Maintenance Plan Required? Yes ~ No IXI
Facility Maintained Operation & Maintenance Plan Required? Yes ~ No Kl
Authority for Requirement: 567 IAC 22.108(3)"b"
523
-------
Emission Point ID Number: 8.A9
Associated Equipment
Associated Emission Unit ID Numbers (if multiple units vent thru this EP): 8. A9
Applicable Requirements
(If more than one emission unit vents through this emission point subdivide the applicable requirements by emission
unit.)
Emission Unit vented through this Emission Point: 8.A9
Emission Unit Description: Non-Production Heating Unit
Raw Material/Fuel: Propane (LPG) or Natural Gas
Rated Capacity: 0.4 MMBtu/hr.
Emission Limits (lb./hr. gr./dscf. lb./MMBtu. % opacity, etc.):
The emissions from this emission point shall not exceed the following specified levels.
Pollutant: Opacity
Emission Limit(s): 40 %
Authority for Requirement: 567 IAC 23.3(2)"d"
Pollutant: Particulate Matter (TSP)
Emission Limit(s): 15.3 lb./MMCF of LPG or Natural Gas
Authority for Requirement: Part 7a. of State of Iowa, ex rel., Iowa DNR vs. Vermeer
Manufacturing Company, 99AG23542
District Court, Marion County, Law No. LACV087889
Pollutant: Particulate Matter (TSP)
Emission Limits: 0.8 lb./MMBtu
Authority for Requirement: 567 IAC 23.3(2)"b"
Pollutant: Sulfur Dioxide (SO2)
Emission Limits: 500 ppmv
Authority for Requirement: 567 IAC 23.3(3)"e"
Pollutant: Nitrogen Oxides (NOx)
Emission Limit(s): See Facility-Wide Conditions
Authority for Requirement: Iowa DNR Construction Permit 98-A-003-S1
Pollutant: Volatile Organic Compounds (VOC)
Emission Limit: See Facility-Wide Conditions
Authority for Requirement: Iowa DNR Construction Permit 98-A-003-S1
524
-------
Operational Limits & Requirements:
The owner/operator of this equipment shall comply with the following operational limits
and requirements.
Process throughput:
A. The sulfur content of natural gas or LPG combusted by this source is not to
exceed 123 ppm by weight.
Reporting & Recordkeeping: See Facility-Wide Operational Limits
Authority for Requirement: Part 7b. of State of Iowa, ex rel., Iowa DNR vs. Vermeer
Manufacturing Company, 99AG23542
District Court, Marion County, Law No. LACV087889
Compliance Plan:
The owner/operator of this equipment shall comply with the following applicable
requirements.
This point is in compliance with all applicable requirements and shall continue to comply
with all such requirements. For those applicable requirements which will become
effective during the permit term, this source will comply with such requirements in a
timely manner.
Periodic Monitoring Requirements:
The owner/operator of this equipment shall comply with the following periodic
monitoring requirements.
Agency Approved Operation & Maintenance Plan Required? Yes ~ No IXI
Facility Maintained Operation & Maintenance Plan Required? Yes ~ No Kl
Authority for Requirement: 567 IAC 22.108(3)"b"
525
-------
Emission Point ID Number: 8.A10
Associated Equipment
Associated Emission Unit ID Numbers (if multiple units vent thru this EP): 8.A10
Applicable Requirements
(If more than one emission unit vents through this emission point subdivide the applicable requirements by emission
unit.)
Emission Unit vented through this Emission Point: 8.A10
Emission Unit Description: Non-Production Heating Unit
Raw Material/Fuel: Propane (LPG) or Natural Gas
Rated Capacity: 0.4 MMBtu/hr.
Emission Limits (lb./hr. gr./dscf. lb./MMBtu. % opacity, etc.):
The emissions from this emission point shall not exceed the following specified levels.
Pollutant: Opacity
Emission Limit(s): 40 %
Authority for Requirement: 567 IAC 23.3(2)"d"
Pollutant: Particulate Matter (TSP)
Emission Limit(s): 15.3 lb./MMCF of LPG or Natural Gas
Authority for Requirement: Part 7a. of State of Iowa, ex rel., Iowa DNR vs. Vermeer
Manufacturing Company, 99AG23542
District Court, Marion County, Law No. LACV087889
Pollutant: Particulate Matter (TSP)
Emission Limits: 0.8 lb./MMBtu
Authority for Requirement: 567 IAC 23.3(2)"b"
Pollutant: Sulfur Dioxide (SO2)
Emission Limits: 500 ppmv
Authority for Requirement: 567 IAC 23.3(3)"e"
Pollutant: Nitrogen Oxides (NOx)
Emission Limit(s): See Facility-Wide Conditions
Authority for Requirement: Iowa DNR Construction Permit 98-A-003-S1
Pollutant: Volatile Organic Compounds (VOC)
Emission Limit: See Facility-Wide Conditions
Authority for Requirement: Iowa DNR Construction Permit 98-A-003-S1
526
-------
Operational Limits & Requirements:
The owner/operator of this equipment shall comply with the following operational limits
and requirements.
Process throughput:
A. The sulfur content of natural gas or LPG combusted by this source is not to
exceed 123 ppm by weight.
Reporting & Recordkeeping: See Facility-Wide Operational Limits
Authority for Requirement: Part 7b. of State of Iowa, ex rel., Iowa DNR vs. Vermeer
Manufacturing Company, 99AG23542
District Court, Marion County, Law No. LACV087889
Compliance Plan:
The owner/operator of this equipment shall comply with the following applicable
requirements.
This point is in compliance with all applicable requirements and shall continue to comply
with all such requirements. For those applicable requirements which will become
effective during the permit term, this source will comply with such requirements in a
timely manner.
Periodic Monitoring Requirements:
The owner/operator of this equipment shall comply with the following periodic
monitoring requirements.
Agency Approved Operation & Maintenance Plan Required? Yes ~ No IXI
Facility Maintained Operation & Maintenance Plan Required? Yes ~ No Kl
Authority for Requirement: 567 IAC 22.108(3)"b"
527
-------
Emission Point ID Number: 8.All
Associated Equipment
Associated Emission Unit ID Numbers (if multiple units vent thru this EP): 8. A11
Applicable Requirements
(If more than one emission unit vents through this emission point subdivide the applicable requirements by emission
unit.)
Emission Unit vented through this Emission Point: 8.A11
Emission Unit Description: Non-Production Heating Unit
Raw Material/Fuel: Propane (LPG) or Natural Gas
Rated Capacity: 0.4 MMBtu/hr.
Emission Limits (lb./hr. gr./dscf. lb./MMBtu. % opacity, etc.):
The emissions from this emission point shall not exceed the following specified levels.
Pollutant: Opacity
Emission Limit(s): 40 %
Authority for Requirement: 567 IAC 23.3(2)"d"
Pollutant: Particulate Matter (TSP)
Emission Limit(s): 15.3 lb./MMCF of LPG or Natural Gas
Authority for Requirement: Part 7a. of State of Iowa, ex rel., Iowa DNR vs. Vermeer
Manufacturing Company, 99AG23542
District Court, Marion County, Law No. LACV087889
Pollutant: Particulate Matter (TSP)
Emission Limits: 0.8 lb./MMBtu
Authority for Requirement: 567 IAC 23.3(2)"b"
Pollutant: Sulfur Dioxide (SO2)
Emission Limits: 500 ppmv
Authority for Requirement: 567 IAC 23.3(3)"e"
Pollutant: Nitrogen Oxides (NOx)
Emission Limit(s): See Facility-Wide Conditions
Authority for Requirement: Iowa DNR Construction Permit 98-A-003-S1
Pollutant: Volatile Organic Compounds (VOC)
Emission Limit: See Facility-Wide Conditions
Authority for Requirement: Iowa DNR Construction Permit 98-A-003-S1
528
-------
Operational Limits & Requirements:
The owner/operator of this equipment shall comply with the following operational limits
and requirements.
Process throughput:
A. The sulfur content of natural gas or LPG combusted by this source is not to
exceed 123 ppm by weight.
Reporting & Recordkeeping: See Facility-Wide Operational Limits
Authority for Requirement: Part 7b. of State of Iowa, ex rel., Iowa DNR vs. Vermeer
Manufacturing Company, 99AG23542
District Court, Marion County, Law No. LACV087889
Compliance Plan:
The owner/operator of this equipment shall comply with the following applicable
requirements.
This point is in compliance with all applicable requirements and shall continue to comply
with all such requirements. For those applicable requirements which will become
effective during the permit term, this source will comply with such requirements in a
timely manner.
Periodic Monitoring Requirements:
The owner/operator of this equipment shall comply with the following periodic
monitoring requirements.
Agency Approved Operation & Maintenance Plan Required? Yes ~ No IXI
Facility Maintained Operation & Maintenance Plan Required? Yes ~ No Kl
Authority for Requirement: 567 IAC 22.108(3)"b"
529
-------
Emission Point ID Number: 8.A12
Associated Equipment
Associated Emission Unit ID Numbers (if multiple units vent thru this EP): 8. A12
Applicable Requirements
(If more than one emission unit vents through this emission point subdivide the applicable requirements by emission
unit.)
Emission Unit vented through this Emission Point: 8.A12
Emission Unit Description: Non-Production Heating Unit
Raw Material/Fuel: Propane (LPG) or Natural Gas
Rated Capacity: 0.4 MMBtu/hr.
Emission Limits (lb./hr. gr./dscf. lb./MMBtu. % opacity, etc.):
The emissions from this emission point shall not exceed the following specified levels.
Pollutant: Opacity
Emission Limit(s): 40 %
Authority for Requirement: 567 IAC 23.3(2)"d"
Pollutant: Particulate Matter (TSP)
Emission Limit(s): 15.3 lb./MMCF of LPG or Natural Gas
Authority for Requirement: Part 7a. of State of Iowa, ex rel., Iowa DNR vs. Vermeer
Manufacturing Company, 99AG23542
District Court, Marion County, Law No. LACV087889
Pollutant: Particulate Matter (TSP)
Emission Limits: 0.8 lb./MMBtu
Authority for Requirement: 567 IAC 23.3(2)"b"
Pollutant: Sulfur Dioxide (SO2)
Emission Limits: 500 ppmv
Authority for Requirement: 567 IAC 23.3(3)"e"
Pollutant: Nitrogen Oxides (NOx)
Emission Limit(s): See Facility-Wide Conditions
Authority for Requirement: Iowa DNR Construction Permit 98-A-003-S1
Pollutant: Volatile Organic Compounds (VOC)
Emission Limit: See Facility-Wide Conditions
Authority for Requirement: Iowa DNR Construction Permit 98-A-003-S1
530
-------
Operational Limits & Requirements:
The owner/operator of this equipment shall comply with the following operational limits
and requirements.
Process throughput:
A. The sulfur content of natural gas or LPG combusted by this source is not to
exceed 123 ppm by weight.
Reporting & Recordkeeping: See Facility-Wide Operational Limits
Authority for Requirement: Part 7b. of State of Iowa, ex rel., Iowa DNR vs. Vermeer
Manufacturing Company, 99AG23542
District Court, Marion County, Law No. LACV087889
Compliance Plan:
The owner/operator of this equipment shall comply with the following applicable
requirements.
This point is in compliance with all applicable requirements and shall continue to comply
with all such requirements. For those applicable requirements which will become
effective during the permit term, this source will comply with such requirements in a
timely manner.
Periodic Monitoring Requirements:
The owner/operator of this equipment shall comply with the following periodic
monitoring requirements.
Agency Approved Operation & Maintenance Plan Required? Yes ~ No IXI
Facility Maintained Operation & Maintenance Plan Required? Yes ~ No Kl
Authority for Requirement: 567 IAC 22.108(3)"b"
531
-------
Emission Point ID Number: 8.B
Associated Equipment
Associated Emission Unit ID Numbers (if multiple units vent thru this EP): 8.B
Applicable Requirements
(If more than one emission unit vents through this emission point subdivide the applicable requirements by emission
unit.)
Emission Unit vented through this Emission Point: 8.B
Emission Unit Description: Production Engine Testing Unit
Raw Material/Fuel: #2 Diesel Fuel and Gasoline
Rated Capacity: 60.6 gal./hr.
Emission Limits (lb./hr. gr./dscf. lb./MMBtu. % opacity, etc.):
The emissions from this emission point shall not exceed the following specified levels.
Pollutant: Opacity
Emission Limits: 40%
Indicator Opacity: 25%(1)
(1) If visible emissions are observed that exceed the indicator opacity other than startup,
shutdown or malfunction, a stack test may be required to demonstrate compliance with
the particulate standard.
Authority for Requirement: Iowa DNR Construction Permit 98-A-861-S2
567 IAC 23.3(2)"d"
Pollutant: Particulate Matter (TSP)
Emission Limits: 0.1 gr./dscf
Authority for Requirement: Iowa DNR Construction Permit 98-A-861-S2
567 IAC 23.3(2)"a"
Pollutant: Sulfur Dioxide (SO2)
Emission Limits: 2.5 lb./MMBtu
Authority for Requirement: Iowa DNR Construction Permit 98-A-861-S2
567 IAC 23.3(3)"b"
Pollutant: Nitrogen Oxides (NOx)
Emission Limit(s): See Facility-Wide Conditions
Authority for Requirement: Iowa DNR Construction Permit 98-A-861-S2
Pollutant: Volatile Organic Compounds (VOC)
Emission Limit: See Facility-Wide Conditions
Authority for Requirement: Iowa DNR Construction Permit 98-A-861-S2
532
-------
Operational Limits & Requirements:
The owner/operator of this equipment shall comply with the following operational limits
and requirements.
Process Throughput:
A. The sulfur content of any diesel fuel used in this source shall not exceed 0.4% by
weight.
Reporting & Recordkeeping: See Facility-Wide Emission and Operational Limits
Authority for Requirement: Iowa DNR Construction Permit 98-A-861-S2
Compliance Plan:
The owner/operator of this equipment shall comply with the following applicable
requirements.
This point is in compliance with all applicable requirements and shall continue to comply
with all such requirements. For those applicable requirements which will become
effective during the permit term, this source will comply with such requirements in a
timely manner.
Additional Requirements:
This emission point shall conform to the following conditions.
The source is to be connected to the stack of the following detailed description.
Stack Height (feet): 27
Stack Diameter (inches): 12
Stack Exhaust Flow Rate (acfm): .... 7,386.8
Stack Temperature (°F): 845
Vertical, Unobstructed Discharge Required: Yes ~ No
Authority for Requirement: Iowa DNR Construction Permit 98-A-861-S2
Periodic Monitoring Requirements:
The owner/operator of this equipment shall comply with the following periodic
monitoring requirements.
Opacity Monitoring:
The facility shall observe the opacity weekly during a period when the emission unit
associated with this emission point is at or near full capacity and record the reading
indicating if visible emissions were observed. The records shall be maintained for five
years. If weather conditions prevent the observer from conducting an opacity
observation, the observer shall note such conditions on the data observation sheet. At
least three attempts shall be made to retake opacity readings at approximately 2-hour
intervals throughout the day. If all observation attempts for a week have been
unsuccessful due to weather, an observation shall be made the next operating day where
weather permits.
Maintain a written record of the observation and any action resulting from the
observation.
E
533
-------
Agency Approved Operation & Maintenance Plan Required? Yes ~ No Kl
Facility Maintained Operation & Maintenance Plan Required? Yes ~ No Kl
Authority for Requirement: 567 IAC 22.108(3)"b"
534
-------
Emission Point ID Number: DSLTANK2
Associated Equipment
Associated Emission Unit ID Numbers (if multiple units vent thru this EP): TANK2
Applicable Requirements
(If more than one emission unit vents through this emission point subdivide the applicable requirements by emission
unit.)
Emission Unit vented through this Emission Point: TANK2
Emission Unit Description: Storage Tank (Fugitive)
Raw Material/Fuel: #2 Diesel Fuel
Rated Capacity: 1,000 gallons
Emission Limits (lb./hr. gr./dscf. lb./MMBtu. % opacity, etc.):
The emissions from this emission point shall not exceed the following specified levels.
Pollutant: Volatile Organic Compounds (VOC)
Emission Limit: See Facility-Wide Conditions
Authority for Requirement: Iowa DNR Construction Permit 98-A-003-S1
Compliance Plan:
The owner/operator of this equipment shall comply with the following applicable
requirements.
This point is in compliance with all applicable requirements and shall continue to comply
with all such requirements. For those applicable requirements which will become
effective during the permit term, this source will comply with such requirements in a
timely manner.
Periodic Monitoring Requirements:
The owner/operator of this equipment shall comply with the following periodic
monitoring requirements.
Agency Approved Operation & Maintenance Plan Required? Yes ~ No Kl
Facility Maintained Operation & Maintenance Plan Required? Yes ~ No Kl
Authority for Requirement: 567 IAC 22.108(3)"b"
535
-------
Emission Point ID Number: DSLTANK4
Associated Equipment
Associated Emission Unit ID Numbers (if multiple units vent thru this EP): TANK4
Applicable Requirements
(If more than one emission unit vents through this emission point subdivide the applicable requirements by emission
unit.)
Emission Unit vented through this Emission Point: TANK4
Emission Unit Description: Storage Tank (Fugitive)
Raw Material/Fuel: #2 Diesel Fuel
Rated Capacity: 1,000 gallons
Emission Limits (lb./hr. gr./dscf. lb./MMBtu. % opacity, etc.):
The emissions from this emission point shall not exceed the following specified levels.
Pollutant: Volatile Organic Compounds (VOC)
Emission Limit: See Facility-Wide Conditions
Authority for Requirement: Iowa DNR Construction Permit 98-A-003-S1
Compliance Plan:
The owner/operator of this equipment shall comply with the following applicable
requirements.
This point is in compliance with all applicable requirements and shall continue to comply
with all such requirements. For those applicable requirements which will become
effective during the permit term, this source will comply with such requirements in a
timely manner.
Periodic Monitoring Requirements:
The owner/operator of this equipment shall comply with the following periodic
monitoring requirements.
Agency Approved Operation & Maintenance Plan Required? Yes ~ No Kl
Facility Maintained Operation & Maintenance Plan Required? Yes ~ No Kl
Authority for Requirement: 567 IAC 22.108(3)"b"
536
-------
Emission Point ID Number: DSLTANK8
Associated Equipment
Associated Emission Unit ID Numbers (if multiple units vent thru this EP): TANK8
Applicable Requirements
(If more than one emission unit vents through this emission point subdivide the applicable requirements by emission
unit.)
Emission Unit vented through this Emission Point: TANK8
Emission Unit Description: Storage Tank (Fugitive)
Raw Material/Fuel: #2 Diesel Fuel
Rated Capacity: 1,000 gallons
Emission Limits (lb./hr. gr./dscf. lb./MMBtu. % opacity, etc.):
The emissions from this emission point shall not exceed the following specified levels.
Pollutant: Volatile Organic Compounds (VOC)
Emission Limit: See Facility-Wide Conditions
Authority for Requirement: Iowa DNR Construction Permit 98-A-003-S1
Compliance Plan:
The owner/operator of this equipment shall comply with the following applicable
requirements.
This point is in compliance with all applicable requirements and shall continue to comply
with all such requirements. For those applicable requirements which will become
effective during the permit term, this source will comply with such requirements in a
timely manner.
Periodic Monitoring Requirements:
The owner/operator of this equipment shall comply with the following periodic
monitoring requirements.
Agency Approved Operation & Maintenance Plan Required? Yes ~ No Kl
Facility Maintained Operation & Maintenance Plan Required? Yes ~ No Kl
Authority for Requirement: 567 IAC 22.108(3)"b"
537
-------
Emission Point ID Number: DSLTANK9
Associated Equipment
Associated Emission Unit ID Numbers (if multiple units vent thru this EP): TANK9
Applicable Requirements
(If more than one emission unit vents through this emission point subdivide the applicable requirements by emission
unit.)
Emission Unit vented through this Emission Point: TANK9 (Fugitive)
Emission Unit Description: Storage Tank
Raw Material/Fuel: #2 Diesel Fuel
Rated Capacity: 1,000 gallons
Emission Limits (lb./hr. gr./dscf. lb./MMBtu. % opacity, etc.):
The emissions from this emission point shall not exceed the following specified levels.
Pollutant: Volatile Organic Compounds (VOC)
Emission Limit: See Facility-Wide Conditions
Authority for Requirement: Iowa DNR Construction Permit 98-A-003-S1
Compliance Plan:
The owner/operator of this equipment shall comply with the following applicable
requirements.
This point is in compliance with all applicable requirements and shall continue to comply
with all such requirements. For those applicable requirements which will become
effective during the permit term, this source will comply with such requirements in a
timely manner.
Periodic Monitoring Requirements:
The owner/operator of this equipment shall comply with the following periodic
monitoring requirements.
Agency Approved Operation & Maintenance Plan Required? Yes ~ No Kl
Facility Maintained Operation & Maintenance Plan Required? Yes ~ No Kl
Authority for Requirement: 567 IAC 22.108(3)"b"
538
-------
Emission Point ID Number: GASTANK3
Associated Equipment
Associated Emission Unit ID Numbers (if multiple units vent thru this EP): TANK3
Applicable Requirements
(If more than one emission unit vents through this emission point subdivide the applicable requirements by emission
unit.)
Emission Unit vented through this Emission Point: TANK3 (Fugitive)
Emission Unit Description: Storage Tank
Raw Material/Fuel: Gasoline
Rated Capacity: 1,000 gallons
Emission Limits (lb./hr. gr./dscf. lb./MMBtu. % opacity, etc.):
The emissions from this emission point shall not exceed the following specified levels.
Pollutant: Volatile Organic Compounds (VOC)
Emission Limit: See Facility-Wide Conditions
Authority for Requirement: Iowa DNR Construction Permit 98-A-003-S1
Compliance Plan:
The owner/operator of this equipment shall comply with the following applicable
requirements.
This point is in compliance with all applicable requirements and shall continue to comply
with all such requirements. For those applicable requirements which will become
effective during the permit term, this source will comply with such requirements in a
timely manner.
Periodic Monitoring Requirements:
The owner/operator of this equipment shall comply with the following periodic
monitoring requirements.
Agency Approved Operation & Maintenance Plan Required? Yes ~ No Kl
Facility Maintained Operation & Maintenance Plan Required? Yes ~ No Kl
Authority for Requirement: 567 IAC 22.108(3)"b"
539
-------
Emission Point ID Number: GASTANK7
Associated Equipment
Associated Emission Unit ID Numbers (if multiple units vent thru this EP): TANK7
Applicable Requirements
(If more than one emission unit vents through this emission point subdivide the applicable requirements by emission
unit.)
Emission Unit vented through this Emission Point: TANK7
Emission Unit Description: Storage Tank (Fugitive)
Raw Material/Fuel: Gasoline
Rated Capacity: 1,000 gallons
Emission Limits (lb./hr. gr./dscf. lb./MMBtu. % opacity, etc.):
The emissions from this emission point shall not exceed the following specified levels.
Pollutant: Volatile Organic Compounds (VOC)
Emission Limit: See Facility-Wide Conditions
Authority for Requirement: Iowa DNR Construction Permit 98-A-003-S1
Compliance Plan:
The owner/operator of this equipment shall comply with the following applicable
requirements.
This point is in compliance with all applicable requirements and shall continue to comply
with all such requirements. For those applicable requirements which will become
effective during the permit term, this source will comply with such requirements in a
timely manner.
Periodic Monitoring Requirements:
The owner/operator of this equipment shall comply with the following periodic
monitoring requirements.
Agency Approved Operation & Maintenance Plan Required? Yes ~ No Kl
Facility Maintained Operation & Maintenance Plan Required? Yes ~ No Kl
Authority for Requirement: 567 IAC 22.108(3)"b"
540
-------
Emission Point ID Number: HB.A
Associated Equipment
Associated Emission Unit ID Numbers (if multiple units vent thru this EP): HB.A
Applicable Requirements
(If more than one emission unit vents through this emission point subdivide the applicable requirements by emission
unit.)
Emission Unit vented through this Emission Point: HB.A
Emission Unit Description: Production Engine Testing Unit
Raw Material/Fuel: #2 Diesel Fuel and Gasoline
Rated Capacity: 50.5 gal./hr.
Emission Limits (lb./hr. gr./dscf. lb./MMBtu. % opacity, etc.):
The emissions from this emission point shall not exceed the following specified levels.
Pollutant: Opacity
Emission Limits: 40%
Indicator Opacity: 25%(1)
(1) If visible emissions are observed that exceed the indicator opacity other than startup,
shutdown or malfunction, a stack test may be required to demonstrate compliance with
the particulate standard.
Authority for Requirement: Iowa DNR Construction Permit 97-A-l 113-S2
567 IAC 23.3(2)"d"
Pollutant: Particulate Matter (TSP)
Emission Limits: 0.1 gr./dscf
Authority for Requirement: Iowa DNR Construction Permit 97-A-l 113-S2
567 IAC 23.3(2)"a"
Pollutant: Sulfur Dioxide (SO2)
Emission Limits: 2.5 lb./MMBtu
Authority for Requirement: Iowa DNR Construction Permit 97-A-l 113-S2
567 IAC 23.3(3)"b"
Pollutant: Nitrogen Oxides (NOx)
Emission Limit(s): See Facility-Wide Conditions
Authority for Requirement: Iowa DNR Construction Permit 97-A-l 113-S2
Pollutant: Volatile Organic Compounds (VOC)
Emission Limit: See Facility-Wide Conditions
Authority for Requirement: Iowa DNR Construction Permit 97-A-l 113-S2
541
-------
Operational Limits & Requirements:
The owner/operator of this equipment shall comply with the following operational limits
and requirements.
Process Throughput:
A. The sulfur content of any diesel fuel used in this source shall not exceed 0.4% by
weight.
Reporting & Recordkeeping: See Facility-Wide Emission and Operational Limits
Authority for Requirement: Iowa DNR Construction Permit 97-A-l 113-S2
Compliance Plan:
The owner/operator of this equipment shall comply with the following applicable
requirements.
This point is in compliance with all applicable requirements and shall continue to comply
with all such requirements. For those applicable requirements which will become
effective during the permit term, this source will comply with such requirements in a
timely manner.
Additional Requirements:
This emission point shall conform to the following conditions.
The source is to be connected to the stack of the following detailed description.
Stack Height (feet): 38
Stack Diameter (inches): 12
Stack Exhaust Flow Rate (acfm): .... 5,750
Stack Temperature (°F): 759
Vertical, Unobstructed Discharge Required: Yes ^ No ~
Authority for Requirement: Iowa DNR Construction Permit 97-A-l 113-S2
Periodic Monitoring Requirements:
The owner/operator of this equipment shall comply with the following periodic
monitoring requirements.
Opacity Monitoring:
The facility shall observe the opacity weekly during a period when the emission unit
associated with this emission point is at or near full capacity and record the reading
indicating if visible emissions were observed. The records shall be maintained for five
years. If weather conditions prevent the observer from conducting an opacity
observation, the observer shall note such conditions on the data observation sheet. At
least three attempts shall be made to retake opacity readings at approximately 2-hour
intervals throughout the day. If all observation attempts for a week have been
unsuccessful due to weather, an observation shall be made the next operating day where
weather permits.
Maintain a written record of the observation and any action resulting from the
observation.
542
-------
Agency Approved Operation & Maintenance Plan Required? Yes ~ No Kl
Facility Maintained Operation & Maintenance Plan Required? Yes ~ No Kl
Authority for Requirement: 567 IAC 22.108(3)"b"
543
-------
Emission Point ID Number: P.A1
Associated Equipment
Associated Emission Unit ID Numbers (if multiple units vent thru this EP): P. A1
Applicable Requirements
(If more than one emission unit vents through this emission point subdivide the applicable requirements by emission
unit.)
Emission Unit vented through this Emission Point: P.A1
Emission Unit Description: Non Production Heating Unit
Raw Material/Fuel: Used Oil
Rated Capacity: 0.00328 gal./hr.
Emission Limits (lb./hr. gr./dscf. lb./MMBtu. % opacity, etc.):
The emissions from this emission point shall not exceed the following specified levels.
Pollutant: Opacity
Emission Limit(s): 40 %
Authority for Requirement: 567 IAC 23.3(2)"d"
Pollutant:
Emission Limits:
Authority for Requirement:
Particulate Matter (TSP)
0.1 gr./dscf
567 IAC 23.3(2)"a"
Pollutant: Sulfur Dioxide (SO2)
Emission Limits: 2.5 lb./MMBtu
Authority for Requirement: 567 IAC 23.3(3)"b"
Pollutant: Nitrogen Oxides (NOx)
Emission Limit(s): See Facility-Wide Conditions
Authority for Requirement: Iowa DNR Construction Permit 98-A-003-S1
Pollutant: Volatile Organic Compounds (VOC)
Emission Limit: See Facility-Wide Conditions
Authority for Requirement: Iowa DNR Construction Permit 98-A-003-S1
Compliance Plan:
The owner/operator of this equipment shall comply with the following applicable
requirements.
This point is in compliance with all applicable requirements and shall continue to comply
with all such requirements. For those applicable requirements which will become
effective during the permit term, this source will comply with such requirements in a
timely manner.
544
-------
Periodic Monitoring Requirements:
The owner/operator of this equipment shall comply with the following periodic
monitoring requirements.
Agency Approved Operation & Maintenance Plan Required? Yes ~ No Kl
Facility Maintained Operation & Maintenance Plan Required? Yes ~ No Kl
Authority for Requirement: 567 IAC 22.108(3)"b"
545
-------
Emission Point ID Number: P.A2
Associated Equipment
Associated Emission Unit ID Numbers (if multiple units vent thru this EP): P. A2
Applicable Requirements
(If more than one emission unit vents through this emission point subdivide the applicable requirements by emission
unit.)
Emission Unit vented through this Emission Point: P.A2
Emission Unit Description: Non Production Heating Unit
Raw Material/Fuel: Used Oil
Rated Capacity: 0.00328 gal./hr.
Emission Limits (lb./hr. gr./dscf. lb./MMBtu. % opacity, etc.):
The emissions from this emission point shall not exceed the following specified levels.
Pollutant: Opacity
Emission Limit(s): 40 %
Authority for Requirement: 567 IAC 23.3(2)"d"
Pollutant:
Emission Limits:
Authority for Requirement:
Particulate Matter (TSP)
0.1 gr./dscf
567 IAC 23.3(2)"a"
Pollutant: Sulfur Dioxide (SO2)
Emission Limits: 2.5 lb./MMBtu
Authority for Requirement: 567 IAC 23.3(3)"b"
Pollutant: Nitrogen Oxides (NOx)
Emission Limit(s): See Facility-Wide Conditions
Authority for Requirement: Iowa DNR Construction Permit 98-A-003-S1
Pollutant: Volatile Organic Compounds (VOC)
Emission Limit: See Facility-Wide Conditions
Authority for Requirement: Iowa DNR Construction Permit 98-A-003-S1
Compliance Plan:
The owner/operator of this equipment shall comply with the following applicable
requirements.
This point is in compliance with all applicable requirements and shall continue to comply
with all such requirements. For those applicable requirements which will become
effective during the permit term, this source will comply with such requirements in a
timely manner.
546
-------
Periodic Monitoring Requirements:
The owner/operator of this equipment shall comply with the following periodic
monitoring requirements.
Agency Approved Operation & Maintenance Plan Required? Yes ~ No Kl
Facility Maintained Operation & Maintenance Plan Required? Yes ~ No Kl
Authority for Requirement: 567 IAC 22.108(3)"b"
547
-------
Emission Point ID Number: P.C1
Associated Equipment
Associated Emission Unit ID Numbers (if multiple units vent thru this EP): P.CI
Applicable Requirements
(If more than one emission unit vents through this emission point subdivide the applicable requirements by emission
unit.)
Emission Unit vented through this Emission Point: P.CI
Emission Unit Description: Non-Production Heating Unit
Raw Material/Fuel: Propane (LPG) or Natural Gas
Rated Capacity: 0.4 MMBtu/hr.
Emission Limits (lb./hr. gr./dscf. lb./MMBtu. % opacity, etc.):
The emissions from this emission point shall not exceed the following specified levels.
Pollutant: Opacity
Emission Limit(s): 40 %
Authority for Requirement: 567 IAC 23.3(2)"d"
Pollutant: Particulate Matter (TSP)
Emission Limit(s): 15.3 lb./MMCF of LPG or Natural Gas
Authority for Requirement: Part 7a. of State of Iowa, ex rel., Iowa DNR vs. Vermeer
Manufacturing Company, 99AG23542
District Court, Marion County, Law No. LACV087889
Pollutant: Particulate Matter (TSP)
Emission Limits: 0.8 lb./MMBtu
Authority for Requirement: 567 IAC 23.3(2)"b"
Pollutant: Sulfur Dioxide (SO2)
Emission Limits: 500 ppmv
Authority for Requirement: 567 IAC 23.3(3)"e"
Pollutant: Nitrogen Oxides (NOx)
Emission Limit(s): See Facility-Wide Conditions
Authority for Requirement: Iowa DNR Construction Permit 98-A-003-S1
Pollutant: Volatile Organic Compounds (VOC)
Emission Limit: See Facility-Wide Conditions
Authority for Requirement: Iowa DNR Construction Permit 98-A-003-S1
548
-------
Operational Limits & Requirements:
The owner/operator of this equipment shall comply with the following operational limits
and requirements.
Process throughput:
A. The sulfur content of natural gas or LPG combusted by this source is not to
exceed 123 ppm by weight.
Reporting & Recordkeeping: See Facility-Wide Operational Limits
Authority for Requirement: Part 7b. of State of Iowa, ex rel., Iowa DNR vs. Vermeer
Manufacturing Company, 99AG23542
District Court, Marion County, Law No. LACV087889
Compliance Plan:
The owner/operator of this equipment shall comply with the following applicable
requirements.
This point is in compliance with all applicable requirements and shall continue to comply
with all such requirements. For those applicable requirements which will become
effective during the permit term, this source will comply with such requirements in a
timely manner.
Periodic Monitoring Requirements:
The owner/operator of this equipment shall comply with the following periodic
monitoring requirements.
Agency Approved Operation & Maintenance Plan Required? Yes ~ No IXI
Facility Maintained Operation & Maintenance Plan Required? Yes ~ No Kl
Authority for Requirement: 567 IAC 22.108(3)"b"
549
-------
Emission Point ID Number: P.C2
Associated Equipment
Associated Emission Unit ID Numbers (if multiple units vent thru this EP): P.C2
Applicable Requirements
(If more than one emission unit vents through this emission point subdivide the applicable requirements by emission
unit.)
Emission Unit vented through this Emission Point: P.C2
Emission Unit Description: Non-Production Heating Unit
Raw Material/Fuel: Propane (LPG) or Natural Gas
Rated Capacity: 0.4 MMBtu/hr.
Emission Limits (lb./hr. gr./dscf. lb./MMBtu. % opacity, etc.):
The emissions from this emission point shall not exceed the following specified levels.
Pollutant: Opacity
Emission Limit(s): 40 %
Authority for Requirement: 567 IAC 23.3(2)"d"
Pollutant: Particulate Matter (TSP)
Emission Limit(s): 15.3 lb./MMCF of LPG or Natural Gas
Authority for Requirement: Part 7a. of State of Iowa, ex rel., Iowa DNR vs. Vermeer
Manufacturing Company, 99AG23542
District Court, Marion County, Law No. LACV087889
Pollutant: Particulate Matter (TSP)
Emission Limits: 0.8 lb./MMBtu
Authority for Requirement: 567 IAC 23.3(2)"b"
Pollutant: Sulfur Dioxide (SO2)
Emission Limits: 500 ppmv
Authority for Requirement: 567 IAC 23.3(3)"e"
Pollutant: Nitrogen Oxides (NOx)
Emission Limit(s): See Facility-Wide Conditions
Authority for Requirement: Iowa DNR Construction Permit 98-A-003-S1
Pollutant: Volatile Organic Compounds (VOC)
Emission Limit: See Facility-Wide Conditions
Authority for Requirement: Iowa DNR Construction Permit 98-A-003-S1
550
-------
Operational Limits & Requirements:
The owner/operator of this equipment shall comply with the following operational limits
and requirements.
Process throughput:
A. The sulfur content of natural gas or LPG combusted by this source is not to
exceed 123 ppm by weight.
Reporting & Recordkeeping: See Facility-Wide Operational Limits
Authority for Requirement: Part 7b. of State of Iowa, ex rel., Iowa DNR vs. Vermeer
Manufacturing Company, 99AG23542
District Court, Marion County, Law No. LACV087889
Compliance Plan:
The owner/operator of this equipment shall comply with the following applicable
requirements.
This point is in compliance with all applicable requirements and shall continue to comply
with all such requirements. For those applicable requirements which will become
effective during the permit term, this source will comply with such requirements in a
timely manner.
Periodic Monitoring Requirements:
The owner/operator of this equipment shall comply with the following periodic
monitoring requirements.
Agency Approved Operation & Maintenance Plan Required? Yes ~ No IXI
Facility Maintained Operation & Maintenance Plan Required? Yes ~ No Kl
Authority for Requirement: 567 IAC 22.108(3)"b"
551
-------
Emission Point ID Number: P.D1
Associated Equipment
Associated Emission Unit ID Numbers (if multiple units vent thru this EP): P.D 1
Applicable Requirements
(If more than one emission unit vents through this emission point subdivide the applicable requirements by emission
unit.)
Emission Unit vented through this Emission Point: P.D1
Emission Unit Description: Non-Production Heating Unit
Raw Material/Fuel: Propane (LPG) or Natural Gas
Rated Capacity: 0.4 MMBtu/hr.
Emission Limits (lb./hr. gr./dscf. lb./MMBtu. % opacity, etc.):
The emissions from this emission point shall not exceed the following specified levels.
Pollutant: Opacity
Emission Limit(s): 40 %
Authority for Requirement: 567 IAC 23.3(2)"d"
Pollutant: Particulate Matter (TSP)
Emission Limit(s): 15.3 lb./MMCF of LPG or Natural Gas
Authority for Requirement: Part 7a. of State of Iowa, ex rel., Iowa DNR vs. Vermeer
Manufacturing Company, 99AG23542
District Court, Marion County, Law No. LACV087889
Pollutant: Particulate Matter (TSP)
Emission Limits: 0.8 lb./MMBtu
Authority for Requirement: 567 IAC 23.3(2)"b"
Pollutant: Sulfur Dioxide (SO2)
Emission Limits: 500 ppmv
Authority for Requirement: 567 IAC 23.3(3)"e"
Pollutant: Nitrogen Oxides (NOx)
Emission Limit(s): See Facility-Wide Conditions
Authority for Requirement: Iowa DNR Construction Permit 98-A-003-S1
Pollutant: Volatile Organic Compounds (VOC)
Emission Limit: See Facility-Wide Conditions
Authority for Requirement: Iowa DNR Construction Permit 98-A-003-S1
552
-------
Operational Limits & Requirements:
The owner/operator of this equipment shall comply with the following operational limits
and requirements.
Process throughput:
A. The sulfur content of natural gas or LPG combusted by this source is not to
exceed 123 ppm by weight.
Reporting & Recordkeeping: See Facility-Wide Operational Limits
Authority for Requirement: Part 7b. of State of Iowa, ex rel., Iowa DNR vs. Vermeer
Manufacturing Company, 99AG23542
District Court, Marion County, Law No. LACV087889
Compliance Plan:
The owner/operator of this equipment shall comply with the following applicable
requirements.
This point is in compliance with all applicable requirements and shall continue to comply
with all such requirements. For those applicable requirements which will become
effective during the permit term, this source will comply with such requirements in a
timely manner.
Periodic Monitoring Requirements:
The owner/operator of this equipment shall comply with the following periodic
monitoring requirements.
Agency Approved Operation & Maintenance Plan Required? Yes ~ No IXI
Facility Maintained Operation & Maintenance Plan Required? Yes ~ No Kl
Authority for Requirement: 567 IAC 22.108(3)"b"
553
-------
Emission Point ID Number: P.D2
Associated Equipment
Associated Emission Unit ID Numbers (if multiple units vent thru this EP): P.D2
Applicable Requirements
(If more than one emission unit vents through this emission point subdivide the applicable requirements by emission
unit.)
Emission Unit vented through this Emission Point: P.D2
Emission Unit Description: Non-Production Heating Unit
Raw Material/Fuel: Propane (LPG) or Natural Gas
Rated Capacity: 0.4 MMBtu/hr.
Emission Limits (lb./hr. gr./dscf. lb./MMBtu. % opacity, etc.):
The emissions from this emission point shall not exceed the following specified levels.
Pollutant: Opacity
Emission Limit(s): 40 %
Authority for Requirement: 567 IAC 23.3(2)"d"
Pollutant: Particulate Matter (TSP)
Emission Limit(s): 15.3 lb./MMCF of LPG or Natural Gas
Authority for Requirement: Part 7a. of State of Iowa, ex rel., Iowa DNR vs. Vermeer
Manufacturing Company, 99AG23542
District Court, Marion County, Law No. LACV087889
Pollutant: Particulate Matter (TSP)
Emission Limits: 0.8 lb./MMBtu
Authority for Requirement: 567 IAC 23.3(2)"b"
Pollutant: Sulfur Dioxide (SO2)
Emission Limits: 500 ppmv
Authority for Requirement: 567 IAC 23.3(3)"e"
Pollutant: Nitrogen Oxides (NOx)
Emission Limit(s): See Facility-Wide Conditions
Authority for Requirement: Iowa DNR Construction Permit 98-A-003-S1
Pollutant: Volatile Organic Compounds (VOC)
Emission Limit: See Facility-Wide Conditions
Authority for Requirement: Iowa DNR Construction Permit 98-A-003-S1
554
-------
Operational Limits & Requirements:
The owner/operator of this equipment shall comply with the following operational limits
and requirements.
Process throughput:
A. The sulfur content of natural gas or LPG combusted by this source is not to
exceed 123 ppm by weight.
Reporting & Recordkeeping: See Facility-Wide Operational Limits
Authority for Requirement: Part 7b. of State of Iowa, ex rel., Iowa DNR vs. Vermeer
Manufacturing Company, 99AG23542
District Court, Marion County, Law No. LACV087889
Compliance Plan:
The owner/operator of this equipment shall comply with the following applicable
requirements.
This point is in compliance with all applicable requirements and shall continue to comply
with all such requirements. For those applicable requirements which will become
effective during the permit term, this source will comply with such requirements in a
timely manner.
Periodic Monitoring Requirements:
The owner/operator of this equipment shall comply with the following periodic
monitoring requirements.
Agency Approved Operation & Maintenance Plan Required? Yes ~ No IXI
Facility Maintained Operation & Maintenance Plan Required? Yes ~ No Kl
Authority for Requirement: 567 IAC 22.108(3)"b"
555
-------
Emission Point ID Number: P.D3
Associated Equipment
Associated Emission Unit ID Numbers (if multiple units vent thru this EP): P.D3
Applicable Requirements
(If more than one emission unit vents through this emission point subdivide the applicable requirements by emission
unit.)
Emission Unit vented through this Emission Point: P.D3
Emission Unit Description: Non-Production Heating Unit
Raw Material/Fuel: Propane (LPG) or Natural Gas
Rated Capacity: 0.4 MMBtu/hr.
Emission Limits (lb./hr. gr./dscf. lb./MMBtu. % opacity, etc.):
The emissions from this emission point shall not exceed the following specified levels.
Pollutant: Opacity
Emission Limit(s): 40 %
Authority for Requirement: 567 IAC 23.3(2)"d"
Pollutant: Particulate Matter (TSP)
Emission Limit(s): 15.3 lb./MMCF of LPG or Natural Gas
Authority for Requirement: Part 7a. of State of Iowa, ex rel., Iowa DNR vs. Vermeer
Manufacturing Company, 99AG23542
District Court, Marion County, Law No. LACV087889
Pollutant: Particulate Matter (TSP)
Emission Limits: 0.8 lb./MMBtu
Authority for Requirement: 567 IAC 23.3(2)"b"
Pollutant: Sulfur Dioxide (SO2)
Emission Limits: 500 ppmv
Authority for Requirement: 567 IAC 23.3(3)"e"
Pollutant: Nitrogen Oxides (NOx)
Emission Limit(s): See Facility-Wide Conditions
Authority for Requirement: Iowa DNR Construction Permit 98-A-003-S1
Pollutant: Volatile Organic Compounds (VOC)
Emission Limit: See Facility-Wide Conditions
Authority for Requirement: Iowa DNR Construction Permit 98-A-003-S1
556
-------
Operational Limits & Requirements:
The owner/operator of this equipment shall comply with the following operational limits
and requirements.
Process throughput:
A. The sulfur content of natural gas or LPG combusted by this source is not to
exceed 123 ppm by weight.
Reporting & Recordkeeping: See Facility-Wide Operational Limits
Authority for Requirement: Part 7b. of State of Iowa, ex rel., Iowa DNR vs. Vermeer
Manufacturing Company, 99AG23542
District Court, Marion County, Law No. LACV087889
Compliance Plan:
The owner/operator of this equipment shall comply with the following applicable
requirements.
This point is in compliance with all applicable requirements and shall continue to comply
with all such requirements. For those applicable requirements which will become
effective during the permit term, this source will comply with such requirements in a
timely manner.
Periodic Monitoring Requirements:
The owner/operator of this equipment shall comply with the following periodic
monitoring requirements.
Agency Approved Operation & Maintenance Plan Required? Yes ~ No IXI
Facility Maintained Operation & Maintenance Plan Required? Yes ~ No Kl
Authority for Requirement: 567 IAC 22.108(3)"b"
557
-------
Emission Point ID Number: P.E
Associated Equipment
Associated Emission Unit ID Numbers (if multiple units vent thru this EP): P.E
Applicable Requirements
(If more than one emission unit vents through this emission point subdivide the applicable requirements by emission
unit.)
Emission Unit vented through this Emission Point: P.E
Emission Unit Description: Non-Production Heating Unit
Raw Material/Fuel: Propane (LPG) or Natural Gas
Rated Capacity: 0.4 MMBtu/hr.
Emission Limits (lb./hr. gr./dscf. lb./MMBtu. % opacity, etc.):
The emissions from this emission point shall not exceed the following specified levels.
Pollutant: Opacity
Emission Limit(s): 40 %
Authority for Requirement: 567 IAC 23.3(2)"d"
Pollutant: Particulate Matter (TSP)
Emission Limit(s): 15.3 lb./MMCF of LPG or Natural Gas
Authority for Requirement: Part 7a. of State of Iowa, ex rel., Iowa DNR vs. Vermeer
Manufacturing Company, 99AG23542
District Court, Marion County, Law No. LACV087889
Pollutant: Particulate Matter (TSP)
Emission Limits: 0.8 lb./MMBtu
Authority for Requirement: 567 IAC 23.3(2)"b"
Pollutant: Sulfur Dioxide (SO2)
Emission Limits: 500 ppmv
Authority for Requirement: 567 IAC 23.3(3)"e"
Pollutant: Nitrogen Oxides (NOx)
Emission Limit(s): See Facility-Wide Conditions
Authority for Requirement: Iowa DNR Construction Permit 98-A-003-S1
Pollutant: Volatile Organic Compounds (VOC)
Emission Limit: See Facility-Wide Conditions
Authority for Requirement: Iowa DNR Construction Permit 98-A-003-S1
558
-------
Operational Limits & Requirements:
The owner/operator of this equipment shall comply with the following operational limits
and requirements.
Process throughput:
A. The sulfur content of natural gas or LPG combusted by this source is not to
exceed 123 ppm by weight.
Reporting & Recordkeeping: See Facility-Wide Operational Limits
Authority for Requirement: Part 7b. of State of Iowa, ex rel., Iowa DNR vs. Vermeer
Manufacturing Company, 99AG23542
District Court, Marion County, Law No. LACV087889
Compliance Plan:
The owner/operator of this equipment shall comply with the following applicable
requirements.
This point is in compliance with all applicable requirements and shall continue to comply
with all such requirements. For those applicable requirements which will become
effective during the permit term, this source will comply with such requirements in a
timely manner.
Periodic Monitoring Requirements:
The owner/operator of this equipment shall comply with the following periodic
monitoring requirements.
Agency Approved Operation & Maintenance Plan Required? Yes ~ No IXI
Facility Maintained Operation & Maintenance Plan Required? Yes ~ No Kl
Authority for Requirement: 567 IAC 22.108(3)"b"
559
-------
Emission Point ID Number: P.O
Associated Equipment
Associated Emission Unit ID Numbers (if multiple units vent thru this EP): P.01, P.02
Applicable Requirements
(If more than one emission unit vents through this emission point subdivide the applicable requirements by emission
unit.)
Emission Unit vented through this Emission Point: P.01 (Fugitive)
Emission Unit Description: One (1) Safety Kleen Parts
Washer
Raw Material/Fuel: MAK Solvent
Rated Capacity: 10 Gallons Solvent
Emission Unit vented through this Emission Point: P.02 (Fugitive)
Emission Unit Description: One (1) Safety Kleen Parts
Washer
Raw Material/Fuel: MAK Solvent
Rated Capacity: 20 Gallons Solvent
Emission Limits (lb./hr. gr./dscf. lb./MMBtu. % opacity, etc.):
The emissions from this emission point shall not exceed the following specified levels.
Pollutant: Volatile Organic Compounds (VOC)
Emission Limit: See Facility-Wide Conditions
Authority for Requirement: Iowa DNR Construction Permit 99-A-685
Compliance Plan:
The owner/operator of this equipment shall comply with the following applicable
requirements.
This point is in compliance with all applicable requirements and shall continue to comply
with all such requirements. For those applicable requirements which will become
effective during the permit term, this source will comply with such requirements in a
timely manner.
Periodic Monitoring Requirements:
The owner/operator of this equipment shall comply with the following periodic
monitoring requirements.
Agency Approved Operation & Maintenance Plan Required? Yes ~ No Kl
Facility Maintained Operation & Maintenance Plan Required? Yes ~ No Kl
Authority for Requirement: 567 IAC 22.108(3)"b"
560
-------
Emission Point ID Number: P.PRTWSH
Associated Equipment
Associated Emission Unit ID Numbers (if multiple units vent thru this EP): P.PRTWSH
Applicable Requirements
(If more than one emission unit vents through this emission point subdivide the applicable requirements by emission
unit.)
Emission Unit vented through this Emission Point: P.PRTWSH (Fugitive)
Emission Unit Description: Four (4) Safety Kleen Parts
Washers
Raw Material/Fuel: Stoddard Solvent
Rated Capacity: 55 Gallons Solvent per Washer
Emission Limits (lb./hr. gr./dscf. lb./MMBtu. % opacity, etc.):
The emissions from this emission point shall not exceed the following specified levels.
Pollutant: Volatile Organic Compounds (VOC)
Emission Limit: See Facility-Wide Conditions
Authority for Requirement: Iowa DNR Construction Permit 98-A-003-S1
Compliance Plan:
The owner/operator of this equipment shall comply with the following applicable
requirements.
This point is in compliance with all applicable requirements and shall continue to comply
with all such requirements. For those applicable requirements which will become
effective during the permit term, this source will comply with such requirements in a
timely manner.
Periodic Monitoring Requirements:
The owner/operator of this equipment shall comply with the following periodic
monitoring requirements.
Agency Approved Operation & Maintenance Plan Required? Yes ~ No Kl
Facility Maintained Operation & Maintenance Plan Required? Yes ~ No Kl
Authority for Requirement: 567 IAC 22.108(3)"b"
561
-------
Emission Point ID Number: P.TORCH
Associated Equipment
Associated Emission Unit ID Numbers (if multiple units vent thru this EP): P.TORCH
Applicable Requirements
(If more than one emission unit vents through this emission point subdivide the applicable requirements by emission
unit.)
Emission Unit vented through this Emission Point: P.TORCH (Fugitive)
Emission Unit Description: Two (2) Single Cutting Head
Oxyacetylene Torch Units
Raw Material/Fuel: Sheet Steel
Rated Capacity: 840 inches of metal cut/hr. per Head
Emission Limits (lb./hr. gr./dscf. lb./MMBtu. % opacity, etc.):
The emissions from this emission point shall not exceed the following specified levels.
Pollutant: Fugitive Dust
Emission Limit: No person shall allow, cause or permit any materials to be handled,
transported or stored; or a building, its appurtenances or a construction haul road to
be used, constructed, altered , repaired or demolished, without taking reasonable
precautions to prevent a nuisance. All persons shall take reasonable precautions to
prevent the discharge of visible emissions of fugitive dusts beyond the lot line of the
property on which the emissions originate.
Authority for Requirement: 567 IAC 23.3(2)"c"
Compliance Plan:
The owner/operator of this equipment shall comply with the following applicable
requirements.
This point is in compliance with all applicable requirements and shall continue to comply
with all such requirements. For those applicable requirements which will become
effective during the permit term, this source will comply with such requirements in a
timely manner.
Periodic Monitoring Requirements:
The owner/operator of this equipment shall comply with the following periodic
monitoring requirements.
Agency Approved Operation & Maintenance Plan Required? Yes ~ No IXI
Facility Maintained Operation & Maintenance Plan Required? Yes ~ No Kl
Authority for Requirement: 567 IAC 22.108(3)"b"
562
-------
Emission Point ID Number: P.WELDING
Associated Equipment
Associated Emission Unit ID Numbers (if multiple units vent thru this EP): P. WELDING
Applicable Requirements
(If more than one emission unit vents through this emission point subdivide the applicable requirements by emission
unit.)
Emission Unit vented through this Emission Point: P.WELDING (Fugitive)
Emission Unit Description: 2 GMAW Units
Raw Material/Fuel: E70S Weld Wire
Rated Capacity: 19 lb. ofWire/hr. per Unit
Emission Limits (lb./hr. gr./dscf. lb./MMBtu. % opacity, etc.):
The emissions from this emission point shall not exceed the following specified levels.
Pollutant: Fugitive Dust
Emission Limit: No person shall allow, cause or permit any materials to be handled,
transported or stored; or a building, its appurtenances or a construction haul road to
be used, constructed, altered , repaired or demolished, without taking reasonable
precautions to prevent a nuisance. All persons shall take reasonable precautions to
prevent the discharge of visible emissions of fugitive dusts beyond the lot line of the
property on which the emissions originate.
Authority for Requirement: 567 IAC 23.3(2)"c"
Compliance Plan:
The owner/operator of this equipment shall comply with the following applicable
requirements.
This point is in compliance with all applicable requirements and shall continue to comply
with all such requirements. For those applicable requirements which will become
effective during the permit term, this source will comply with such requirements in a
timely manner.
Periodic Monitoring Requirements:
The owner/operator of this equipment shall comply with the following periodic
monitoring requirements.
Agency Approved Operation & Maintenance Plan Required? Yes ~ No Kl
Facility Maintained Operation & Maintenance Plan Required? Yes ~ No Kl
Authority for Requirement: 567 IAC 22.108(3)"b"
563
-------
Emission Point ID Number: Q.A
Associated Equipment
Associated Emission Unit ID Numbers (if multiple units vent thru this EP): Q.A
Applicable Requirements
(If more than one emission unit vents through this emission point subdivide the applicable requirements by emission
unit.)
Emission Unit vented through this Emission Point: Q.A
Emission Unit Description: Non Production Heating Unit
Raw Material/Fuel: Used Oil
Rated Capacity: 0.00328 gal./hr.
Emission Limits (lb./hr. gr./dscf. lb./MMBtu. % opacity, etc.):
The emissions from this emission point shall not exceed the following specified levels.
Pollutant: Opacity
Emission Limit(s): 40 %
Authority for Requirement: 567 IAC 23.3(2)"d"
Pollutant:
Emission Limits:
Authority for Requirement:
Particulate Matter (TSP)
0.1 gr./dscf
567 IAC 23.3(2)"a"
Pollutant: Sulfur Dioxide (SO2)
Emission Limits: 2.5 lb./MMBtu
Authority for Requirement: 567 IAC 23.3(3)"b"
Pollutant: Nitrogen Oxides (NOx)
Emission Limit(s): See Facility-Wide Conditions
Authority for Requirement: Iowa DNR Construction Permit 98-A-003-S1
Pollutant: Volatile Organic Compounds (VOC)
Emission Limit: See Facility-Wide Conditions
Authority for Requirement: Iowa DNR Construction Permit 98-A-003-S1
Compliance Plan:
The owner/operator of this equipment shall comply with the following applicable
requirements.
This point is in compliance with all applicable requirements and shall continue to comply
with all such requirements. For those applicable requirements which will become
effective during the permit term, this source will comply with such requirements in a
timely manner.
564
-------
Periodic Monitoring Requirements:
The owner/operator of this equipment shall comply with the following periodic
monitoring requirements.
Agency Approved Operation & Maintenance Plan Required? Yes ~ No Kl
Facility Maintained Operation & Maintenance Plan Required? Yes ~ No Kl
Authority for Requirement: 567 IAC 22.108(3)"b"
565
-------
Emission Point ID Number: W.A1
Associated Equipment
Associated Emission Unit ID Numbers (if multiple units vent thru this EP): W. A1
Applicable Requirements
(If more than one emission unit vents through this emission point subdivide the applicable requirements by emission
unit.)
Emission Unit vented through this Emission Point: W. A1
Emission Unit Description: Non Production Heating Unit
Raw Material/Fuel: Used Oil
Rated Capacity: 0.00328 gal./hr.
Emission Limits (lb./hr. gr./dscf. lb./MMBtu. % opacity, etc.):
The emissions from this emission point shall not exceed the following specified levels.
Pollutant: Opacity
Emission Limit(s): 40 %
Authority for Requirement: 567 IAC 23.3(2)"d"
Pollutant:
Emission Limits:
Authority for Requirement:
Particulate Matter (TSP)
0.1 gr./dscf
567 IAC 23.3(2)"a"
Pollutant: Sulfur Dioxide (SO2)
Emission Limits: 2.5 lb./MMBtu
Authority for Requirement: 567 IAC 23.3(3)"b"
Pollutant: Nitrogen Oxides (NOx)
Emission Limit(s): See Facility-Wide Conditions
Authority for Requirement: Iowa DNR Construction Permit 98-A-003-S1
Pollutant: Volatile Organic Compounds (VOC)
Emission Limit: See Facility-Wide Conditions
Authority for Requirement: Iowa DNR Construction Permit 98-A-003-S1
Compliance Plan:
The owner/operator of this equipment shall comply with the following applicable
requirements.
This point is in compliance with all applicable requirements and shall continue to comply
with all such requirements. For those applicable requirements which will become
effective during the permit term, this source will comply with such requirements in a
timely manner.
566
-------
Periodic Monitoring Requirements:
The owner/operator of this equipment shall comply with the following periodic
monitoring requirements.
Agency Approved Operation & Maintenance Plan Required? Yes ~ No Kl
Facility Maintained Operation & Maintenance Plan Required? Yes ~ No Kl
Authority for Requirement: 567 IAC 22.108(3)"b"
567
-------
Emission Point ID Number: W.B
Associated Equipment
Associated Emission Unit ID Numbers (if multiple units vent thru this EP): W.B
Applicable Requirements
(If more than one emission unit vents through this emission point subdivide the applicable requirements by emission
unit.)
Emission Unit vented through this Emission Point: W.B
Emission Unit Description: Hotsey Washer
Raw Material/Fuel: Natural Gas
Rated Capacity: 0.657 MMBtu/hr.
Emission Limits (lb./hr. gr./dscf. lb./MMBtu. % opacity, etc.):
The emissions from this emission point shall not exceed the following specified levels.
Pollutant: Opacity
Emission Limit(s): 40 %
Authority for Requirement: 567 IAC 23.3(2)"d"
Pollutant: Particulate Matter (TSP)
Emission Limit(s): 15.3 lb./MMCF of LPG or Natural Gas
Authority for Requirement: Part 7a. of State of Iowa, ex rel., Iowa DNR vs. Vermeer
Manufacturing Company, 99AG23542
District Court, Marion County, Law No. LACV087889
Pollutant: Particulate Matter (TSP)
Emission Limits: 0.8 lb./MMBtu
Authority for Requirement: 567 IAC 23.3(2)"b"
Pollutant: Sulfur Dioxide (SO2)
Emission Limits: 500 ppmv
Authority for Requirement: 567 IAC 23.3(3)"e"
Pollutant: Nitrogen Oxides (NOx)
Emission Limit(s): See Facility-Wide Conditions
Authority for Requirement: Iowa DNR Construction Permit 98-A-003-S1
Pollutant: Volatile Organic Compounds (VOC)
Emission Limit: See Facility-Wide Conditions
Authority for Requirement: Iowa DNR Construction Permit 98-A-003-S1
568
-------
Operational Limits & Requirements:
The owner/operator of this equipment shall comply with the following operational limits
and requirements.
Process throughput:
A. The sulfur content of natural gas or LPG combusted by this source is not to
exceed 123 ppm by weight.
Reporting & Recordkeeping: See Facility-Wide Operational Limits
Authority for Requirement: Part 7b. of State of Iowa, ex rel., Iowa DNR vs. Vermeer
Manufacturing Company, 99AG23542
District Court, Marion County, Law No. LACV087889
Compliance Plan:
The owner/operator of this equipment shall comply with the following applicable
requirements.
This point is in compliance with all applicable requirements and shall continue to comply
with all such requirements. For those applicable requirements which will become
effective during the permit term, this source will comply with such requirements in a
timely manner.
Periodic Monitoring Requirements:
The owner/operator of this equipment shall comply with the following periodic
monitoring requirements.
Agency Approved Operation & Maintenance Plan Required? Yes ~ No IXI
Facility Maintained Operation & Maintenance Plan Required? Yes ~ No Kl
Authority for Requirement: 567 IAC 22.108(3)"b"
569
-------
Emission Point ID Number: W.E
Associated Equipment
Associated Emission Unit ID Numbers (if multiple units vent thru this EP): W.E
Applicable Requirements
(If more than one emission unit vents through this emission point subdivide the applicable requirements by emission
unit.)
Emission Unit vented through this Emission Point: W.E
Emission Unit Description: Paint Hook Burn-Off Oven
Raw Material/Fuel: Natural Gas
Rated Capacity: 0.78 MMBtu/hr.
Emission Limits (lb./hr. gr./dscf. lb./MMBtu. % opacity, etc.):
The emissions from this emission point shall not exceed the following specified levels.
Pollutant: Opacity
Emission Limit(s): 40 %
Authority for Requirement: Iowa DNR Construction Permit 98-A-072-S1
567 IAC23.4(12)"b"
Pollutant: Particulate Matter (TSP)
Emission Limit(s): 15.3 lb./MMCF of LPG or Natural Gas
Authority for Requirement: Part 7a. of State of Iowa, ex rel., Iowa DNR vs. Vermeer
Manufacturing Company, 99AG23542
District Court, Marion County, Law No. LACV087889
Pollutant: Particulate Matter (TSP)
Emission Limit(s): 0.35 gr./dscf^
(1) Adjusted to 12% CO2
Authority for Requirement: Iowa DNR Construction Permit 98-A-072-S1
567 IAC 23.4(12)"a"
Pollutant: Sulfur Dioxide (SO2)
Emission Limits: 500 ppmv
Authority for Requirement: 567 IAC 23.3(3)"e"
Pollutant: Nitrogen Oxides (NOx)
Emission Limit(s): See Facility-Wide Conditions
Authority for Requirement: Iowa DNR Construction Permit 98-A-072-S1
570
-------
Emission Limits (continued):
Pollutant: Volatile Organic Compounds (VOC)
Emission Limit: See Facility-Wide Conditions
Authority for Requirement: Iowa DNR Construction Permit 98-A-072-S1
Compliance Testing Requirements
TSP Iowa Compliance Sampling Manual
The owner shall verily compliance with the emission limitations contained in
Construction Permit 98-A-072-S1 within sixty (60) days after achieving maximum
production rate and no later than one hundred eighty (180) days after the startup date of
the proposed equipment. The test shall be conducted with the equipment operating in a
manner representative of full rated capacity. Failure to test at this maximum may be
cause to limit the source to operating at the level at which the compliance tests were
conducted.
The owner shall furnish the DNR the following written notifications:
1. The date of intended startup at least ten (10) days before the equipment or control
equipment involved is placed into operation.
2. The actual date of startup postmarked within fifteen (15) days following the start
of operation.
Authority for Requirement: Iowa DNR Construction Permit 98-A-072-S1
Operational Limits & Requirements:
The owner/operator of this equipment shall comply with the following operational limits
and requirements.
Supplemental Environmental Project:
Equipment parameters:
The emission unit associated with this emission point will consist of a high
temperature, natural gas fired oven for the destruction of paint built up on the hooks
that transport parts to the paint lines at the facility. This will include a 36 foot by 16
foot insulated addition to the existing waste management building to house one Blu
Surf Model No. 6506 Wash Booth Unit and one Model No. 5505 Burnoff Oven
together with the necessary electrical system for the equipment, gas lines for the
oven, drain lines for the wash water discharge, multilevel footings, foundation, and
concrete flooring to support and allow for operation of the oven. The hook burnoff
oven system will consist of one batch burnoff oven, Model No. 5506 with a top
mount after burner.
571
-------
Operational Limits & Requirements (continued):
The oven will include a primary and secondary water suppression system to prevent
overheating during oven burning cycles. A modulating gas valve system will be
supplied for the primary burner to maintain consistent, efficient thermal operating
temperatures, operating at an approximate 540,000 Btu per hour level with a potential
for 780,000 Btu per hour maximum. Each time the oven is started, the water
suppression system will automatically turn on for approximately 30 seconds. A roller
track will be installed in the floor to transport carts from the oven to the wash booth
unit. The wash unit will be supplied with a power washer operating at 2 gallons per
minute at 1,000 pounds per square inch pressure for cleaning the ash from the hooks,
carts and racks after burning.
Authority for Requirement: Paragraph 3a. of State of Iowa, ex rel., Iowa DNR vs.
Vermeer Manufacturing Company, 99AG23542
District Court, Marion County, Law No. LACV087889
Operational term: This SEP will be maintained for the life of this permit.
Authority for Requirement: Paragraph 3i. of State of Iowa, ex rel., Iowa DNR vs.
Vermeer Manufacturing Company, 99AG23542
District Court, Marion County, Law No. LACV087889
Reporting & Record keeping:
Vermeer shall submit to the DNR an annual performance report covering the required
period of use and maintenance of this SEP documenting the actual use and
maintenance of this SEP. The reports shall be submitted on or before March 1, for the
preceding calendar year, commencing on March 1, 1999.
Authority for Requirement: Paragraph 3j. of State of Iowa, ex rel., Iowa DNR vs.
Vermeer Manufacturing Company, 99AG23542
District Court, Marion County, Law No. LACV087889
Process throughput:
A. The quantity of paint incinerated in this source shall not exceed 27.5 pounds
per hour.
B. This source shall be fired by natural gas or propane only.
Reporting & Recordkeeping: See Facility-Wide Emission Limits
Authority for Requirement: Iowa DNR Construction Permit 98-A-072-S1
Process throughput:
A. The sulfur content of natural gas or LPG combusted by this source is not to
exceed 123 ppm by weight.
Reporting & Recordkeeping: See Facility-Wide Operational Limits
Authority for Requirement: Part 7b. of State of Iowa, ex rel., Iowa DNR vs. Vermeer
Manufacturing Company, 99AG23542
District Court, Marion County, Law No. LACV087889
572
-------
Compliance Plan:
The owner/operator of this equipment shall comply with the following applicable
requirements.
This point is in compliance with all applicable requirements and shall continue to comply
with all such requirements. For those applicable requirements which will become
effective during the permit term, this source will comply with such requirements in a
timely manner.
Additional Requirements:
This emission point shall conform to the following conditions.
The source is to be connected to the stack of the following detailed description.
Stack Height (feet): 35.2
Stack Diameter (inches): 6
Stack Exhaust Flow Rate (acfm): .... 1,578
Stack Temperature (°F): 1,322
Vertical, Unobstructed Discharge Required: Yes ^ No ~
Authority for Requirement: Iowa DNR Construction Permit 98-A-072-S1
Periodic Monitoring Requirements:
The owner/operator of this equipment shall comply with the following periodic
monitoring requirements.
Agency Approved Operation & Maintenance Plan Required? Yes ~ No IXI
Facility Maintained Operation & Maintenance Plan Required? Yes ~ No Kl
Authority for Requirement: 567 IAC 22.108(3)"b"
573
-------
Emission Point ID Number: W.F1
Associated Equipment
Associated Emission Unit ID Numbers (if multiple units vent thru this EP): W.F
Applicable Requirements
(If more than one emission unit vents through this emission point subdivide the applicable requirements by emission
unit.)
Emission Unit vented through this Emission Point: W.F
Emission Unit Description: Waste Solvent Still
Raw Material/Fuel: Recovered Paints, etc.
Rated Capacity: 4.58 gallons/hr.
Emission Limits (lb./hr. gr./dscf. lb./MMBtu. % opacity, etc.):
The emissions from this emission point shall not exceed the following specified levels.
Pollutant: Opacity
Emission Limit(s): 40 %
Authority for Requirement: 567 IAC 23.3(2)"d"
Operational Limits & Requirements:
The owner/operator of this equipment shall comply with the following operational limits
and requirements.
Reporting & Record keeping: See Facility-Wide Conditions and include:
A. A monthly and a twelve (12) month rolling total of the amount of solvent
recovered, in gallons.
Authority for Requirement: Iowa DNR Construction Permit 99-A-340
Compliance Plan:
The owner/operator of this equipment shall comply with the following applicable
requirements.
This point is in compliance with all applicable requirements and shall continue to comply
with all such requirements. For those applicable requirements which will become
effective during the permit term, this source will comply with such requirements in a
timely manner.
574
-------
Additional Requirements:
This emission point shall conform to the following conditions.
The source is to be connected to the stack of the following detailed description.
Stack Height (feet): 10
Stack Diameter (inches): 2
Stack Exhaust Flow Rate (acfm): .... Natural draft
Stack Temperature (°F): Ambient
Vertical, Unobstructed Discharge Required: Yes ~ No Kl
Authority for Requirement: Iowa DNR Construction Permit 99-A-340
Periodic Monitoring Requirements:
The owner/operator of this equipment shall comply with the following periodic
monitoring requirements.
Agency Approved Operation & Maintenance Plan Required? Yes ~ No IEI
Facility Maintained Operation & Maintenance Plan Required? Yes ~ No IE
Authority for Requirement: 567 IAC 22.108(3)"b"
575
-------
Emission Point ID Number: W.F2
Associated Equipment
Associated Emission Unit ID Numbers (if multiple units vent thru this EP): W.F
Applicable Requirements
(If more than one emission unit vents through this emission point subdivide the applicable requirements by emission
unit.)
Emission Unit vented through this Emission Point: W.F
Emission Unit Description: Waste Solvent Still
Raw Material/Fuel: Recovered Paints, etc.
Rated Capacity: 4.58 gallons/hr.
Emission Limits (lb./hr. gr./dscf. lb./MMBtu. % opacity, etc.):
The emissions from this emission point shall not exceed the following specified levels.
Pollutant: Opacity
Emission Limit(s): 40 %
Authority for Requirement: 567 IAC 23.3(2)"d"
Operational Limits & Requirements:
The owner/operator of this equipment shall comply with the following operational limits
and requirements.
Reporting & Record keeping: See Facility-Wide Conditions and include:
A. A monthly and a twelve (12) month rolling total of the amount of solvent
recovered, in gallons.
Authority for Requirement: Iowa DNR Construction Permit 99-A-340
Compliance Plan:
The owner/operator of this equipment shall comply with the following applicable
requirements.
This point is in compliance with all applicable requirements and shall continue to comply
with all such requirements. For those applicable requirements which will become
effective during the permit term, this source will comply with such requirements in a
timely manner.
576
-------
Additional Requirements:
This emission point shall conform to the following conditions.
The source is to be connected to the stack of the following detailed description.
Stack Height (feet): 10
Stack Diameter (inches): 2
Stack Exhaust Flow Rate (acfm): .... Natural draft
Stack Temperature (°F): Ambient
Vertical, Unobstructed Discharge Required: Yes ~ No Kl
Authority for Requirement: Iowa DNR Construction Permit 99-A-341
Periodic Monitoring Requirements:
The owner/operator of this equipment shall comply with the following periodic
monitoring requirements.
Agency Approved Operation & Maintenance Plan Required? Yes ~ No IEI
Facility Maintained Operation & Maintenance Plan Required? Yes ~ No IE
Authority for Requirement: 567 IAC 22.108(3)"b"
577
-------
Emission Point ID Number: W.H
Associated Equipment
Associated Emission Unit ID Numbers (if multiple units vent thru this EP): W.H, W.F
Applicable Requirements
(If more than one emission unit vents through this emission point subdivide the applicable requirements by emission
unit.)
Emission Unit vented through this Emission Point: W.H
Emission Unit Description: Aerosol Can Crusher
Raw Material/Fuel: Aerosol Cans
Rated Capacity: 120 cans/hr.
Emission Unit vented through this Emission Point: W.F
Emission Unit Description: Waste Solvent Still
Raw Material/Fuel: Recovered Paints, etc.
Rated Capacity: 4.58 gallons/hr.
Emission Limits (lb./hr. gr./dscf. lb./MMBtu. % opacity, etc.):
The emissions from this emission point shall not exceed the following specified levels.
Pollutant: Volatile Organic Compounds (VOC)
Emission Limit: See Facility-Wide Conditions
Authority for Requirement: Iowa DNR Construction Permit 99-A-691
Compliance Plan:
The owner/operator of this equipment shall comply with the following applicable
requirements.
This point is in compliance with all applicable requirements and shall continue to comply
with all such requirements. For those applicable requirements which will become
effective during the permit term, this source will comply with such requirements in a
timely manner.
Additional Requirements:
This emission point shall conform to the following conditions.
The source is to be connected to the stack of the following detailed description.
Stack Height (feet): 35
Stack Diameter (inches): 12
Stack Exhaust Flow Rate (acfm): .... 3,500
Stack Temperature (°F): Ambient
Vertical, Unobstructed Discharge Required: Yes ^ No ~
Authority for Requirement: Iowa DNR Construction Permit 99-A-691
578
-------
Periodic Monitoring Requirements:
The owner/operator of this equipment shall comply with the following periodic
monitoring requirements.
Agency Approved Operation & Maintenance Plan Required? Yes ~ No Kl
Facility Maintained Operation & Maintenance Plan Required? Yes ~ No Kl
Authority for Requirement: 567 IAC 22.108(3)"b"
579
-------
Emission Point ID Number: W.M
Associated Equipment
Associated Emission Unit ID Numbers (if multiple units vent thru this EP): W.M
Applicable Requirements
(If more than one emission unit vents through this emission point subdivide the applicable requirements by emission
unit.)
Emission Unit vented through this Emission Point: W.M (Fugitive)
Emission Unit Description: One (1) Safety Kleen Parts Washer
Raw Material/Fuel: Stoddard Solvent
Rated Capacity: 55 Gallons Solvent
Emission Limits (lb./hr. gr./dscf. lb./MMBtu. % opacity, etc.):
The emissions from this emission point shall not exceed the following specified levels.
Pollutant: Volatile Organic Compounds (VOC)
Emission Limit: See Facility-Wide Conditions
Authority for Requirement: Iowa DNR Construction Permit 98-A-003-S1
Compliance Plan:
The owner/operator of this equipment shall comply with the following applicable
requirements.
This point is in compliance with all applicable requirements and shall continue to comply
with all such requirements. For those applicable requirements which will become
effective during the permit term, this source will comply with such requirements in a
timely manner.
Periodic Monitoring Requirements:
The owner/operator of this equipment shall comply with the following periodic
monitoring requirements.
Agency Approved Operation & Maintenance Plan Required? Yes ~ No Kl
Facility Maintained Operation & Maintenance Plan Required? Yes ~ No Kl
Authority for Requirement: 567 IAC 22.108(3)"b"
580
-------
Emission Point ID Number: F.SAND
Associated Equipment
Associated Emission Unit ID Numbers (if multiple units vent thru this EP): F. SAND
Applicable Requirements
(If more than one emission unit vents through this emission point subdivide the applicable requirements by emission
unit.)
Emission Unit vented through this Emission Point: F. SAND (Fugitive)
Emission Unit Description: Sand Blasting Unit
Raw Material/Fuel: Silica Sand
Rated Capacity: 600 lb. Sand/hr.
Emission Limits (lb./hr. gr./dscf. lb./MMBtu. % opacity, etc.):
The emissions from this emission point shall not exceed the following specified levels.
Pollutant: Fugitive Dust
Emission Limit: No person shall allow, cause or permit any materials to be handled,
transported or stored; or a building, its appurtenances or a construction haul road to
be used, constructed, altered , repaired or demolished, without taking reasonable
precautions to prevent a nuisance. All persons shall take reasonable precautions to
prevent the discharge of visible emissions of fugitive dusts beyond the lot line of the
property on which the emissions originate.
Authority for Requirement: 567 IAC 23.3(2)"c"
Compliance Plan:
The owner/operator of this equipment shall comply with the following applicable
requirements.
This point is in compliance with all applicable requirements and shall continue to comply
with all such requirements. For those applicable requirements which will become
effective during the permit term, this source will comply with such requirements in a
timely manner.
Periodic Monitoring Requirements:
The owner/operator of this equipment shall comply with the following periodic
monitoring requirements.
Agency Approved Operation & Maintenance Plan Required? Yes ~ No Kl
Facility Maintained Operation & Maintenance Plan Required? Yes ~ No Kl
Authority for Requirement: 567 IAC 22.108(3)"b"
581
-------
Emission Point ID Number: F.SODA
Associated Equipment
Associated Emission Unit ID Numbers (if multiple units vent thru this EP): F. SODA
Applicable Requirements
(If more than one emission unit vents through this emission point subdivide the applicable requirements by emission
unit.)
Emission Unit vented through this Emission Point: F. SODA (Fugitive)
Emission Unit Description: Soda Blasting Unit
Raw Material/Fuel: Abrasive Soda
Rated Capacity: 120 lb. Soda/hr.
Emission Limits (lb./hr. gr./dscf. lb./MMBtu. % opacity, etc.):
The emissions from this emission point shall not exceed the following specified levels.
Pollutant: Fugitive Dust
Emission Limit: No person shall allow, cause or permit any materials to be handled,
transported or stored; or a building, its appurtenances or a construction haul road to
be used, constructed, altered , repaired or demolished, without taking reasonable
precautions to prevent a nuisance. All persons shall take reasonable precautions to
prevent the discharge of visible emissions of fugitive dusts beyond the lot line of the
property on which the emissions originate.
Authority for Requirement: 567 IAC 23.3(2)"c"
Compliance Plan:
The owner/operator of this equipment shall comply with the following applicable
requirements.
This point is in compliance with all applicable requirements and shall continue to comply
with all such requirements. For those applicable requirements which will become
effective during the permit term, this source will comply with such requirements in a
timely manner.
Periodic Monitoring Requirements:
The owner/operator of this equipment shall comply with the following periodic
monitoring requirements.
Agency Approved Operation & Maintenance Plan Required? Yes ~ No Kl
Facility Maintained Operation & Maintenance Plan Required? Yes ~ No Kl
Authority for Requirement: 567 IAC 22.108(3)"b"
582
-------
Emission Point ID Number: PROPANE
Associated Equipment
Associated Emission Unit ID Numbers (if multiple units vent thru this EP): PROPANE
Applicable Requirements
(If more than one emission unit vents through this emission point subdivide the applicable requirements by emission
unit.)
Emission Unit vented through this Emission Point: PROPANE
Emission Unit Description: Three Storage Tanks (Fugitive)
Raw Material/Fuel: Propane
Rated Capacity: 6,000 gallons per Tank
Emission Limits (lb./hr. gr./dscf. lb./MMBtu. % opacity, etc.):
The emissions from this emission point shall not exceed the following specified levels.
Pollutant: Volatile Organic Compounds (VOC)
Emission Limit: See Facility-Wide Conditions
Authority for Requirement: Iowa DNR Construction Permit 98-A-003-S1
Compliance Plan:
The owner/operator of this equipment shall comply with the following applicable
requirements.
This point is in compliance with all applicable requirements and shall continue to comply
with all such requirements. For those applicable requirements which will become
effective during the permit term, this source will comply with such requirements in a
timely manner.
Periodic Monitoring Requirements:
The owner/operator of this equipment shall comply with the following periodic
monitoring requirements.
Agency Approved Operation & Maintenance Plan Required? Yes ~ No IEI
Facility Maintained Operation & Maintenance Plan Required? Yes ~ No Kl
Authority for Requirement: 567 IAC 22.108(3)"b"
583
-------
Emission Point ID Number: PROPYLENE
Associated Equipment
Associated Emission Unit ID Numbers (if multiple units vent thru this EP): PROPYLENE
Applicable Requirements
(If more than one emission unit vents through this emission point subdivide the applicable requirements by emission
unit.)
Emission Unit vented through this Emission Point: PROPYLENE
Emission Unit Description: Three Storage Tanks (Fugitive)
Raw Material/Fuel: Propylene
Rated Capacity: 1,000 gallons per Tank
Emission Limits (lb./hr. gr./dscf. lb./MMBtu. % opacity, etc.):
The emissions from this emission point shall not exceed the following specified levels.
Pollutant: Volatile Organic Compounds (VOC)
Emission Limit: See Facility-Wide Conditions
Authority for Requirement: Iowa DNR Construction Permit 98-A-003-S1
Compliance Plan:
The owner/operator of this equipment shall comply with the following applicable
requirements.
This point is in compliance with all applicable requirements and shall continue to comply
with all such requirements. For those applicable requirements which will become
effective during the permit term, this source will comply with such requirements in a
timely manner.
Periodic Monitoring Requirements:
The owner/operator of this equipment shall comply with the following periodic
monitoring requirements.
Agency Approved Operation & Maintenance Plan Required? Yes ~ No IEI
Facility Maintained Operation & Maintenance Plan Required? Yes ~ No Kl
Authority for Requirement: 567 IAC 22.108(3)"b"
584
-------
Emission Point ID Number: OILTANK
Associated Equipment
Associated Emission Unit ID Numbers (if multiple units vent thru this EP): OILTANK
Applicable Requirements
(If more than one emission unit vents through this emission point subdivide the applicable requirements by emission
unit.)
Emission Unit vented through this Emission Point: OILTANK (Fugitive)
Emission Unit Description: Storage Tank
Raw Material/Fuel: Used Oil
Rated Capacity: 5,000 gallons
Emission Limits (lb./hr. gr./dscf. lb./MMBtu. % opacity, etc.):
The emissions from this emission point shall not exceed the following specified levels.
Pollutant: Volatile Organic Compounds (VOC)
Emission Limit: See Facility-Wide Conditions
Authority for Requirement: Iowa DNR Construction Permit 98-A-003-S1
Compliance Plan:
The owner/operator of this equipment shall comply with the following applicable
requirements.
This point is in compliance with all applicable requirements and shall continue to comply
with all such requirements. For those applicable requirements which will become
effective during the permit term, this source will comply with such requirements in a
timely manner.
Periodic Monitoring Requirements:
The owner/operator of this equipment shall comply with the following periodic
monitoring requirements.
Agency Approved Operation & Maintenance Plan Required? Yes ~ No Kl
Facility Maintained Operation & Maintenance Plan Required? Yes ~ No Kl
Authority for Requirement: 567 IAC 22.108(3)"b"
585
-------
IV. General Conditions
This permit is issued under the authority of the Iowa Code subsection 45 5B. 133(8) and in
accordance with 567 Iowa Administrative Code chapter 22.
Gl. Duty to Comply
1. The permittee must comply with all conditions of the Title V permit. Any permit
noncompliance constitutes a violation of the Act and is grounds for enforcement action;
for a permit termination, revocation and reissuance, or modification; or for denial of a
permit renewal application. 567IAC 22.108(9) "a"
2. Any compliance schedule shall be supplemental to, and shall not sanction
noncompliance with, the applicable requirements on which it is based. 567 IAC 22.105
(2)"h"3.
3. Where an applicable requirement of the Act is more stringent than an applicable
requirement of regulations promulgated under Title IV of the Act, both provisions shall
be enforceable by the administrator and are incorporated into this permit. 567 IAC 22.108
(l)"b"
4. Unless specified as either "state enforceable only" or "local program enforceable only",
all terms and conditions in the permit, including provisions to limit a source's potential to
emit, are enforceable by the administrator and citizens under the Act. 567 IAC 22.108
(14)
5. It shall not be a defense for a permittee, in an enforcement action, that it would have
been necessary to halt or reduce the permitted activity in order to maintain compliance
with the conditions of the permit. 567 IAC 22.108 (9)"b"
G2. Permit Expiration
1. Except as provided in 567 IAC 22.104, the expiration of this permit terminates the
permittee's right to operate unless a timely and complete application has been submitted
for renewal. Any testing required for renewal shall be completed before the application is
submitted. 567 IAC 22.116(2)
2. To be considered timely, the owner, operator, or designated representative (where
applicable) of each source required to obtain a Title V permit shall present or mail the Air
Quality Bureau, Iowa Department of Natural Resources, Air Quality Bureau, 7900
Hickman Rd, Suite #1, Urbandale, Iowa 50322, four or more copies of a complete permit
application, at least 6 months but not more than 18 months prior to the date of permit
expiration. The definition of a complete application is as indicated in 567 IAC 22.105(2).
567 IAC 22.105
G3. Certification Requirement for Title V Related Documents
Any application, report, compliance certification or other document submitted pursuant to
this permit shall contain certification by a responsible official of truth, accuracy, and
completeness. All certifications shall state that, based on information and belief formed
after reasonable inquiry, the statements and information in the document are true,
accurate, and complete. 567 IAC 22.107 (4)
G4. Annual Compliance Certification
On March 31 of each year, the permittee shall submit compliance certifications for the
previous calendar year. The certifications shall include descriptions of means to monitor
the compliance status of all emissions sources including emissions limitations, standards,
and work practices in accordance with applicable requirements. The certification for a
source shall include the identification of each term or condition of the permit that is the
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basis of the certification; the compliance status; whether compliance was continuous or
intermittent; the method(s) used for determining the compliance status of the source,
currently and over the reporting period consistent with all applicable department rules.
For sources determined not to be in compliance at the time of compliance certification, a
compliance schedule shall be submitted which provides for periodic progress reports,
dates for achieving activities, milestones, and an explanation of why any dates were
missed and preventive or corrective measures. The compliance certification shall be
submitted to the administrator, director, and the appropriate DNR Field office. 567IAC
22.108 (15)"e"
G5. Semi-Annual Monitoring Report
On March 31 and September 30 of each year, the permittee shall submit a report of any
monitoring required under this permit for the 6 month periods of July 1 to December 31
and January 1 to June 30, respectively. All instances of deviations from permit
requirements must be clearly identified in these reports, and the report must be signed by
a responsible official, consistent with 567 IAC 22.107(4). The semi-annual monitoring
report shall be submitted to the director and the appropriate DNR Field office. 567 IAC
22.108 (5).
G6. Annual Fee
1. The permittee is required under subrule 567 IAC 22.106 to pay an annual fee based on
the total tons of actual emissions of each regulated air pollutant. Beginning July 1, 1996,
Title V operating permit fees will be paid on July 1 of each year. The fee shall be based
on emissions for the previous calendar year.
2. The fee amount shall be calculated based on the first 4,000 tons of each regulated air
pollutant emitted each year. The fee to be charged per ton of pollutant will be available
from the department by June 1 of each year. The Responsible Official will be advised of
any change in the annual fee per ton of pollutant.
3. The following forms shall be submitted annually by March 31 documenting actual
emissions for the previous calendar year.
a. Form 1.0 "Facility Identification";
b. Form 4.0 "Emissions unit-actual operations and emissions" for each emission unit;
c. Form 5.0 "Title V annual emissions summary/fee"; and
d. Part 3 "Application certification."
4. The fee shall be submitted annually by July 1. The fee shall be submitted with the
following forms:
a. Form 1.0 "Facility Identification";
b. Form 5.0 "Title V annual emissions summary/fee";
c. Part 3 "Application certification."
5. If there are any changes to the emission calculation form, the department shall make
revised forms available to the public by January 1. If revised forms are not available by
January 1, forms from the previous year may be used and the year of emissions
documented changed. The department shall calculate the total statewide Title V
emissions for the prior calendar year and make this information available to the public no
later than April 30 of each year.
6. Phase I acid rain affected units under section 404 of the Act shall not be required to
pay a fee for emissions which occur during the years 1993 through 1999 inclusive.
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7. The fee for a portable emissions unit or stationary source which operates both in Iowa
and out of state shall be calculated only for emissions from the source while operating in
Iowa.
8. Failure to pay the appropriate Title V fee represents cause for revocation of the Title V
permit as indicated in 567 IAC 22.115(l)"d".
G7. Inspection of Premises, Records, Equipment, Methods and Discharges
Upon presentation of proper credentials and any other documents as may be required by
law, the permittee shall allow the director or the director's authorized representative to:
1. Enter upon the permittee's premises where a Title V source is located or emissions-
related activity is conducted, or where records must be kept under the conditions of the
permit;
2. Have access to and copy, at reasonable times, any records that must be kept under the
conditions of the permit;
3. Inspect, at reasonable times, any facilities, equipment (including monitoring and air
pollution control equipment), practices, or operations regulated or required under the
permit; and
4. Sample or monitor, at reasonable times, substances or parameters for the purpose of
ensuring compliance with the permit or other applicable requirements. 567 IAC 22.108
(15)"b"
G8. Duty to Provide Information
The permittee shall furnish to the director, within a reasonable time, any information that
the director may request in writing to determine whether cause exists for modifying,
revoking and reissuing, or terminating the permit or to determine compliance with the
permit. Upon request, the permittee also shall furnish to the director copies of records
required to be kept by the permit, or for information claimed to be confidential, the
permittee shall furnish such records directly to the administrator of EPA along with a
claim of confidentiality. 567 IAC 22.108 (9)"e"
G9. General Maintenance and Repair Duties
The owner or operator of any air emission source or control equipment shall:
1. Maintain and operate the equipment or control equipment at all times in a manner
consistent with good practice for minimizing emissions.
2. Remedy any cause of excess emissions in an expeditious manner.
3. Minimize the amount and duration of any excess emission to the maximum extent
possible during periods of such emissions. These measures may include but not be
limited to the use of clean fuels, production cutbacks, or the use of alternate process units
or, in the case of utilities, purchase of electrical power until repairs are completed.
4. Schedule, at a minimum, routine maintenance of equipment or control equipment
during periods of process shutdowns to the maximum extent possible. 567 IAC 24.2(1)
G10. Recordkeeping Requirements for Compliance Monitoring
1. In addition to any source specific recordkeeping requirements contained in this permit,
the permittee shall maintain the following compliance monitoring records:
a. The date, place and time of sampling or measurements
b. The date the analyses were performed.
c. The company or entity that performed the analyses.
d. The analytical techniques or methods used.
e. The results of such analyses; and
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f. The operating conditions as existing at the time of sampling or measurement.
g. The records of quality assurance for continuous compliance monitoring systems
(including but not limited to quality control activities, audits and calibration drifts.)
2. The permittee shall retain records of all required compliance monitoring data and
support information for a period of at least 5 years from the date of compliance
monitoring sample, measurement report or application. Support information includes all
calibration and maintenance records and all original strip chart recordings for continuous
compliance monitoring, and copies of all reports required by the permit.
3. For any source which in its application identified reasonably anticipated alternative
operating scenarios, the permittee shall:
a. Comply with all terms and conditions of this permit specific to each alternative
scenario.
b. Maintain a log at the permitted facility of the scenario under which it is operating.
c. Consider the permit shield, if provided in this permit, to extend to all terms and
conditions under each operating scenario. 567IAC 22.108(4), 567IAC 22.108(12)
Gil. Prevention of Accidental Release: Risk Management Plan Notification and
Compliance Certification
If the permittee is required to develop and register a risk management plan pursuant to
section 112(r) of the Act, the permittee shall notify the department of this requirement.
The plan shall be filed with all appropriate authorities by the deadline specified by EPA.
A certification that this risk management plan is being properly implemented shall be
included in the annual compliance certification of this permit. 567 IAC 22.108(6)
G12. Hazardous Release
The permittee must report any situation involving the actual, imminent, or probable
release of a hazardous substance into the atmosphere which, because of the quantity,
strength and toxicity of the substance, creates an immediate or potential danger to the
public health, safety or to the environment. A verbal report shall be made to the
department at (515) 281-8694 and to the local police department or the office of the
sheriff of the affected county as soon as possible but not later than six hours after the
discovery or onset of the condition. This verbal report must be followed up with a written
report as indicated in 567 IAC 131.2(2). 567 IAC Chapter 131-State Only
G13. Excess Emissions and Excess Emissions Reporting Requirements
1. Excess Emissions. Excess emission during a period of startup, shutdown, or cleaning
of control equipment is not a violation of the emission standard if the startup, shutdown
or cleaning is accomplished expeditiously and in a manner consistent with good practice
for minimizing emissions. Cleaning of control equipment which does not require the
shutdown of the process equipment shall be limited to one six-minute period per one-
hour period. An incident of excess emission (other than an incident during startup,
shutdown or cleaning of control equipment) is a violation. If the owner or operator of a
source maintains that the incident of excess emission was due to a malfunction, the owner
or operator must show that the conditions which caused the incident of excess emission
were not preventable by reasonable maintenance and control measures. Determination of
any subsequent enforcement action will be made following review of this report. If
excess emissions are occurring, either the control equipment causing the excess emission
shall be repaired in an expeditious manner or the process generating the emissions shall
be shutdown within a reasonable period of time. An expeditious manner is the time
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necessary to determine the cause of the excess emissions and to correct it within a
reasonable period of time. A reasonable period of time is eight hours plus the period of
time required to shut down the process without damaging the process equipment or
control equipment. In the case of an electric utility, a reasonable period of time is eight
hours plus the period of time until comparable generating capacity is available to meet
consumer demand with the affected unit out of service, unless, the director shall, upon
investigation, reasonably determine that continued operation constitutes an unjustifiable
environmental hazard and issue an order that such operation is not in the public interest
and require a process shutdown to commence immediately.
2. Excess Emissions Reporting
a. Oral Reporting of Excess Emissions. An incident of excess emission (other than an
incident of excess emission during a period of startup, shutdown, or cleaning) shall be
reported to the appropriate field office of the department within eight hours of, or at
the start of the first working day following the onset of the incident. The reporting
exemption for an incident of excess emission during startup, shutdown or cleaning
does not relieve the owner or operator of a source with continuous monitoring
equipment of the obligation of submitting reports required in 567-subrule 25.1(6). An
oral report of excess emission is not required for a source with operational continuous
monitoring equipment (as specified in 567-subrule 25.1(1) ) if the incident of excess
emission continues for less than 30 minutes and does not exceed the applicable
visible emission standard by more than 10 percent opacity. The oral report may be
made in person or by telephone and shall include as a minimum the following:
i. The identity of the equipment or source operation from which the excess
emission originated and the associated stack or emission point.
ii. The estimated quantity of the excess emission.
iii. The time and expected duration of the excess emission.
iv. The cause of the excess emission.
v. The steps being taken to remedy the excess emission.
vi. The steps being taken to limit the excess emission in the interim period.
b. Written Reporting of Excess Emissions. A written report of an incident of excess
emission shall be submitted as a follow-up to all required oral reports to the
department within seven days of the onset of the upset condition, and shall include as
a minimum the following:
i. The identity of the equipment or source operation point from which the excess
emission originated and the associated stack or emission point.
ii. The estimated quantity of the excess emission.
iii. The time and duration of the excess emission.
iv. The cause of the excess emission.
v. The steps that were taken to remedy and to prevent the recurrence of the
incident of excess emission.
vi. The steps that were taken to limit the excess emission.
vii. If the owner claims that the excess emission was due to malfunction,
documentation to support this claim. 567IAC 24.1(l)-567 IAC 24.1(4)
3. Emergency Defense for Excess Emissions. For the purposes of this permit, an
"emergency" means any situation arising from sudden and reasonably unforeseeable
events beyond the control of the source, including acts of God, which requires immediate
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corrective action to restore normal operation, and that causes the source to exceed a
technology-based emission limitation under the permit due to unavoidable increases in
emissions attributable to the emergency. An emergency shall not include non-
compliance, to the extent caused by improperly designed equipment, lack of preventive
maintenance, careless or improper operation or operator error. An emergency constitutes
an affirmative defense to an action brought for non-compliance with technology based
limitations if it can be demonstrated through properly signed contemporaneous operating
logs or other relevant evidence that:
a. An emergency occurred and that the permittee can identify the cause(s) of the
emergency;
b. The facility at the time was being properly operated;
c. During the period of the emergency, the permittee took all reasonable steps to
minimize levels of emissions that exceeded the emissions standards or other
requirements of the permit; and
d. The permittee submitted notice of the emergency to the director by certified mail
within two working days of the time when the emissions limitations were exceeded
due to the emergency. This notice must contain a description of the emergency, any
steps taken to mitigate emissions, and corrective actions taken. 567IAC 22.108(16)
G14. Permit Deviation Reporting Requirements
A deviation is an instance when any condition of this permit is violated. Reporting
requirements for deviations that result in a hazardous release or excess emissions have
been indicated above. Any violation of an applicable requirement shall be reported to the
appropriate regional office by telephone or in person within seven (7) days of the
violation. This report shall include the probable cause of such violation, and any
corrective actions or preventive measures taken. Any other deviations shall be
documented in the semi-annual report. 567IAC 22.108(5)"b".
G15. Notification Requirements for Sources That Become Subject to NSPS and
HAP Regulations
During the term of this permit, the permittee must notify the department of any source
that becomes subject to a standard or other requirement under 567-subrule 23.1(2)
(standards of performance of new stationary sources) or section 111 of the Act; or 567-
subrule 23.1(3) (emissions standards for hazardous air pollutants) or section 112 of the
Act. This notification shall be submitted in writing to the department 30 days before the
source becomes subject to the afore-mentioned standard or other requirement. 40 CFR
part 63.9 as adopted in 567 IAC 23.1(4); 40 CFR part 60.7 as adopted in 567 IAC
23.1(2)
G16. Requirements for Making Changes to Emission Sources That Do Not Require
Title V Permit Modification
1. Off Permit Changes to a Source. Pursuant to section 502(b)(10) of the CAAA, the
permittee may make changes to this installation/facility without revising this permit if:
a. The changes are not major modifications under any provision of any program
required by section 110 of the Act, modifications under section 111 of the act,
modifications under section 112 of the act, or major modifications as defined in 567
IAC Chapter 22.
b. The changes do not exceed the emissions allowable under the permit (whether
expressed therein as a rate of emissions or in terms of total emissions);
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c. The changes are not modifications under any provisions of Title I of the Act and
the changes do not exceed the emissions allowable under the permit (whether
expressed therein as a rate of emissions or as total emissions);
d. The changes are not subject to any requirement under Title IV of the Act.
e. The changes comply with all applicable requirements.
f. For such a change, the permitted source provides to the department and the
administrator by certified mail, at least 30 days in advance of the proposed change, a
written notification, including the following, which must be attached to the permit by
the source, the department and the administrator:
i. A brief description of the change within the permitted facility,
ii. The date on which the change will occur,
iii. Any change in emission as a result of that change,
iv. The pollutants emitted subject to the emissions trade
v. If the emissions trading provisions of the state implementation plan are
invoked, then Title V permit requirements with which the source shall comply; a
description of how the emissions increases and decreases will comply with the
terms and conditions of the Title V permit.
vi. A description of the trading of emissions increases and decreases for the
purpose of complying with a federally enforceable emissions cap as specified in
and in compliance with the Title V permit; and
vii. Any permit term or condition no longer applicable as a result of the change.
567IAC 22.110.(1)
2. Such changes do not include changes that would violate applicable requirements or
contravene federally enforceable permit terms and conditions that are monitoring
(including test methods), record keeping, reporting, or compliance certification
requirements. 567 IAC 22.110.(2)
3. Notwithstanding any other part of this rule, the director may, upon review of a notice,
require a stationary source to apply for a Title V permit if the change does not meet the
requirements of subrule 22.110(1). 567 IAC 22.110.(3)
4. The permit shield provided in subrule 22.108(18) shall not apply to any change made
pursuant to this rule. Compliance with the permit requirements that the source will meet
using the emissions trade shall be determined according to requirements of the state
implementation plan authorizing the emissions trade. 567 IAC 22.110.(4)
5. Aggregate Insignificant Emissions. The permittee shall not construct, establish or
operate any new insignificant activities or modify any existing insignificant activities in
such a way that the emissions from these activities no longer meet the criteria of
aggregate insignificant emissions. If the aggregate insignificant emissions are expected to
be exceeded, the permittee shall submit the appropriate permit modification and receive
approval prior to making any change. 567 IAC 22.103.(2)
6. No permit revision shall be required, under any approved economic incentives,
marketable permits, emissions trading and other similar programs or processes, for
changes that are provided for in this permit. 567 IAC 22.108 (11)
G17. Duty to Modify a Title V Permit
1. Administrative Amendment.
a. An administrative permit amendment is a permit revision that is required to do any
of the following:
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i. Correct typographical errors
ii. Identify a change in the name, address, or telephone number of any person
identified in the permit, or provides a similar minor administrative change at the
source;
iii. Require more frequent monitoring or reporting by the permittee; or
iv. Allow for a change in ownership or operational control of a source where the
director determines that no other change in the permit is necessary, provided that
a written agreement containing a specific date for transfer of permit responsibility,
coverage and liability between the current and new permittee has been submitted
to the director.
b. The permittee may implement the changes addressed in the request for an
administrative amendment immediately upon submittal of the request. The request
shall be submitted to the director.
c. Administrative amendments to portions of permits containing provisions pursuant
to Title IV of the Act shall be governed by regulations promulgated by the
administrator under Title IV of the Act.
2. Minor Permit Modification.
a. Minor permit modification procedures may be used only for those permit
modifications that do any of the following:
i. Do not violate any applicable requirements
ii. Do not involve significant changes to existing monitoring, reporting or
recordkeeping requirements in the Title V permit.
iii. Do not require or change a case by case determination of an emission
limitation or other standard, or increment analysis.
iv. Do not seek to establish or change a permit term or condition for which there
is no corresponding underlying applicable requirement and that the source has
assumed in order to avoid an applicable requirement to which the source would
otherwise be subject. Such terms and conditions include any federally enforceable
emissions caps which the source would assume to avoid classification as a
modification under any provision under Title I of the Act; and an alternative
emissions limit approved pursuant to regulations promulgated under section
112(i)(5) of the Act.;
v. Are not modifications under any provision of Title I of the Act; and
vi. Are not required to be processed as significant modification.
b. An application for minor permit revision shall be on the minor Title V modification
application form and shall include at least the following:
i. A description of the change, the emissions resulting from the change, and any
new applicable requirements that will apply if the change occurs.
ii. The permittee's suggested draft permit
iii. Certification by a responsible official, pursuant to 567 IAC 22.107(4), that the
proposed modification meets the criteria for use of a minor permit modification
procedures and a request that such procedures be used; and
iv. Completed forms to enable the department to notify the administrator and the
affected states as required by 567 IAC 107(7).
c. The permittee may make the change proposed in its minor permit modification
application immediately after it files the application. After the permittee makes this
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change and until the director takes any of the actions specified in 567 I AC 22.112(4)
"a" to "c", the permittee must comply with both the applicable requirements
governing the change and the proposed permit terms and conditions. During this time,
the permittee need not comply with the existing permit terms and conditions it seeks
to modify. However, if the permittee fails to comply with its proposed permit terms
and conditions during this time period, existing permit term terms and conditions it
seeks to modify may subject the facility to enforcement action.
3. Significant Permit Modification. Significant Title V modification procedures shall be
used for applications requesting Title V permit modifications that do not qualify as minor
Title V modifications or as administrative amendments. These include but are not limited
to all significant changes in monitoring permit terms, every relaxation of reporting or
recordkeeping permit terms, and any change in the method of measuring compliance with
existing requirements. Significant Title V modifications shall meet all requirements of
567 IAC Chapter 22, including those for applications, public participation, review by
affected states, and review by the administrator, and those requirements that apply to
Title V issuance and renewal. 567 IAC 22.111-567 IAC 22.113
The permittee shall submit an application for a significant permit modification at least 6
months, but not more than 18 months prior to the date of the proposed modification. 567
IAC 22.105(l)a(2)
G18. Duty to Obtain Construction Permits
Unless exempted under 567 IAC 22.1(2), the permittee must not construct, install,
reconstruct, or alter any equipment, control equipment or anaerobic lagoon without first
obtaining a construction permit, conditional permit, or permit pursuant to 567 IAC 22.8,
or permits required pursuant to 567 IAC 22.4 and 567 IAC 22.5. Such permits shall be
obtained prior to the initiation of construction, installation or alteration of any portion of
the stationary source. 567 IAC 22.1(1)
G19. Asbestos
The permittee shall comply with 567 IAC 23.1(3)"a", and 567 IAC 23.2(3)"g" when
conducting any renovation or demolition activities at the facility. IAC 23.1(3) "a", and
567 IAC 23.2
G20. Open Burning
The permittee is prohibited from conducting open burning, except as may be allowed by
567 IAC 23.2. 567IAC 23.2 except 23.2(3) "h"; 567IAC 23.2(3) "h" - State Only
G21. Acid Rain (Title IV) Emissions Allowances
The permittee shall not exceed any allowances that it holds under Title IV of the Act or
the regulations promulgated there under. Annual emissions of sulfur dioxide in excess of
the number of allowances to emit sulfur dioxide held by the owners and operators of the
unit or the designated representative of the owners and operators is prohibited.
Exceedences of applicable emission rates are prohibited. "Held" in this context refers to
both those allowances assigned to the owners and operators by USEPA, and those
allowances supplementally acquired by the owners and operators. The use of any
allowance prior to the year for which it was allocated is prohibited. Contravention of any
other provision of the permit is prohibited. 567 IAC 22.108(7)
G22. Stratospheric Ozone and Climate Protection (Title VI) Requirements
1. The permittee shall comply with the standards for labeling of products using ozone-
depleting substances pursuant to 40 CFR Part 82, Subpart E:
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a. All containers in which a class I or class II substance is stored or transported, all
products containing a class I substance, and all products directly manufactured with a
class I substance must bear the required warning statement if it is being introduced
into interstate commerce pursuant to § 82.106.
b. The placement of the required warning statement must comply with the
requirements pursuant to § 82.108.
c. The form of the label bearing the required warning statement must comply with the
requirements pursuant to § 82.110.
d. No person may modify, remove, or interfere with the required warning statement
except as described in § 82.112.
2. The permittee shall comply with the standards for recycling and emissions reduction
pursuant to 40 CFR Part 82, Subpart F, except as provided for MVACs in Subpart B:
a. Persons opening appliances for maintenance, service, repair, or disposal must
comply with the required practices pursuant to § 82.156.
b. Equipment used during the maintenance, service, repair, or disposal of appliances
must comply with the standards for recycling and recovery equipment pursuant to §
82.158.
c. Persons performing maintenance, service, repair, or disposal of appliances must be
certified by an approved technician certification program pursuant to § 82.161.
d. Persons disposing of small appliances, MVACs, and MVAC-like appliances must
comply with reporting and recordkeeping requirements pursuant to § 82.166.
("MVAC-like appliance" as defined at § 82.152)
e. Persons owning commercial or industrial process refrigeration equipment must
comply with the leak repair requirements pursuant to § 82.156.
f. Owners/operators of appliances normally containing 50 or more pounds of
refrigerant must keep records of refrigerant purchased and added to such appliances
pursuant to § 82.166.
3. If the permittee manufactures, transforms, imports, or exports a class I or class II
substance, the permittee is subject to all the requirements as specified in 40 CFR part 82,
Subpart A, Production and Consumption Controls.
4. If the permittee performs a service on motor (fleet) vehicles when this service involves
ozone-depleting substance refrigerant (or regulated substitute substance) in the motor
vehicle air conditioner (MVAC), the permittee is subject to all the applicable
requirements as specified in 40 CFR part 82, Subpart B, Servicing of Motor Vehicle Air
Conditioners. The term "motor vehicle" as used in Subpart B does not include a vehicle
in which final assembly of the vehicle has not been completed. The term "MVAC" as
used in Subpart B does not include the air-tight sealed refrigeration system used as
refrigerated cargo, or system used on passenger buses using HCFC-22 refrigerant,
5. The permittee shall be allowed to switch from any ozone-depleting substance to any
alternative that is listed in the Significant New Alternatives Program (SNAP)
promulgated pursuant to 40 CFR part 82, Subpart G, Significant New Alternatives Policy
Program. 40 CFR part 82
G23. Permit Reopenings
1. This permit may be modified, revoked, reopened, and reissued, or terminated for
cause. The filing of a request by the permittee for a permit modification, revocation and
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reissuance, or termination, or of a notification of planned changes or anticipated
noncompliance does not stay any permit condition. 567IAC 22.108(9)"c"
2. Additional applicable requirements under the Act become applicable to a major part 70
source with a remaining permit term of 3 or more years. Revisions shall be made as
expeditiously as practicable, but not later than 18 months after the promulgation of such
standards and regulations.
a. Reopening and revision on this ground is not required if the permit has a remaining
term of less than three years;
b. Reopening and revision on this ground is not required if the effective date of the
requirement is later than the date on which the permit is due to expire, unless the
original permit or any of its terms and conditions have been extended pursuant to 40
CFR 70.4(b)(10)(i) or (ii) as amended to June 25, 1993.
c. Reopening and revision on this ground is not required if the additional applicable
requirements are implemented in a general permit that is applicable to the source and
the source receives approval for coverage under that general permit. 567 IAC
22.108(17) "a", 567 IAC 22.108(17) "b"
3. A permit shall be reopened and revised under any of the following circumstances:
a. The department receives notice that the administrator has granted a petition for
disapproval of a permit pursuant to 40 CFR 70.8(d) as amended to June 25, 1993,
provided that the reopening may be stayed pending judicial review of that
determination;
b. The department or the administrator determines that the Title V permit contains a
material mistake or that inaccurate statements were made in establishing the
emissions standards or other terms or conditions of the Title V permit;
c. Additional applicable requirements under the Act become applicable to a Title V
source, provided that the reopening on this ground is not required if the permit has a
remaining term of less than three years, the effective date of the requirement is later
than the date on which the permit is due to expire, or the additional applicable
requirements are implemented in a general permit that is applicable to the source and
the source receives approval for coverage under that general permit. Such a reopening
shall be complete not later than 18 months after promulgation of the applicable
requirement.
d. Additional requirements, including excess emissions requirements, become
applicable to a Title IV affected source under the acid rain program. Upon approval
by the administrator, excess emissions offset plans shall be deemed to be incorporated
into the permit.
e. The department or the administrator determines that the permit must be revised or
revoked to ensure compliance by the source with the applicable requirements. 567
IAC 22.114(1)
4. Proceedings to reopen and reissue a Title V permit shall follow the procedures
applicable to initial permit issuance and shall effect only those parts of the permit for
which cause to reopen exists. 567 IAC 22.114(2)
G24. Permit Shield
Compliance with the conditions of this permit shall be deemed compliance with the
applicable requirements included in this permit as of the date of permit issuance.
This permit shield shall not alter or affect the following:
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1. The provisions of section 303 of the Act (emergency orders), including the authority
of the administrator under that section;
2. The liability of an owner or operator of a source for any violation of applicable
requirements prior to or at the time of permit issuance;
3. The applicable requirements of the acid rain program, consistent with section 408(a)
of the Act;
4. The ability of the department or the administrator to obtain information from the
facility pursuant to section 114 of the Act. I AC 22.108 (18)
G25. Severability
The provisions of this permit are severable and if any provision or application of any
provision is found to be invalid by this department or a court of law, the application of
such provision to other circumstances, and the remainder of this permit, shall not be
affected by such finding. 567IAC 22.108 (8)
G26. Property Rights
The permit does not convey any property rights of any sort, or any exclusive privilege.
567IAC 22.108 (9)"d"
G27. Transferability
This permit is not transferable from one source to another. If title to the facility or any
part of it is transferred, an administrative amendment to the permit must be sought to
determine transferability of the permit. 567 IAC 22.111 (l)"d"
G28. Disclaimer
No review has been undertaken on the engineering aspects of the equipment or control
equipment other than the potential of that equipment for reducing air contaminant
emissions. 567IAC 22.3(3)"c"
G29. Notification and Reporting Requirements for Stack Tests or Monitor
Certification
The permittee shall notify the department's stack test contact in writing not less than 30
days before a required test or performance evaluation of a continuous emission monitor is
performed to determine compliance with an applicable requirement. For the department
to consider test results a valid demonstration of compliance with applicable rules or a
permit condition, such notice shall be given. Such notice shall include the time, the place,
the name of the person who will conduct the test and other information as required by the
department. Unless specifically waived by the department's stack test contact, a pretest
meeting shall be held not later than 15 days prior to conducting the compliance
demonstration. The department may accept a testing protocol in lieu of a pretest meeting.
A representative of the department shall be permitted to witness the tests. Results of the
tests shall be submitted in writing to the department's stack test contact in the form of a
comprehensive report within six weeks of the completion of the testing. Compliance tests
conducted pursuant to this permit shall be conducted with the source operating in a
normal manner at its maximum continuous output as rated by the equipment
manufacturer, or the rate specified by the owner as the maximum production rate at
which the source shall be operated.
597
-------
Stack test notifications, reports and correspondence shall be sent to:
Stack Test Review Coordinator
Iowa DNR, Air Quality Bureau
7900 Hickman Road, Suite #1
Urbandale, IA 50322
(515) 242-6001
Within Polk and Linn Counties, stack test notifications, reports and correspondence shall
also be directed to the supervisor of the respective county air pollution program.
567IAC 25.1(7) "a", 567IAC 25.1(9)
G30. Prevention of Air Pollution Emergency Episodes
The permittee shall comply with the provisions of 567 IAC Chapter 26 in the prevention
of excessive build-up of air contaminants during air pollution episodes, thereby
preventing the occurrence of an emergency due to the effects of these contaminants on
the health of persons. 567 IAC 26.1(1)
G31. Contacts List
The current address and phone number for reports and notifications to the EPA
administrator is:
Chief of Air Permits
EPA Region 7
Air Permits and Compliance Branch
901 N. 5th St.
Kansas City, KS 66101
(913)551-7020
The current address and phone number for reports and notifications to the department or
the Director is:
Chief, Air Quality Bureau
Iowa Department of Natural Resources
7900 Hickman Road, Suite #1
Urbandale, IA 50322
(515) 242-5100
598
-------
Reports or notifications to the DNR Field Offices or local programs shall be directed to
the supervisor at the appropriate field office or local program. Current addresses and
phone numbers are:
Field Office 1
909 West Main - Suite 1
Manchester, IA 52057
(319) 927-2640
Field Office 3
1900 N. Grand Ave.
Spencer, IA 51301
(712) 262-4177
Field Office 5
607 East 2nd St.
Des Moines, IA 50309
(515) 281-9069
Polk County Public Works Dept.
Air Quality Division
5895 NE 14th St.
Des Moines, IA 50313
(515) 286-3351
Field Office 2
P.O. Box 1443
2300-15th St., SW
Mason City, IA 50401
(515) 424-4073
Field Office 4
706 Sunnyside
Atlantic, IA 50022
(712) 243-1934
Field Office 6
1004 W. Madison
Washington, IA 52353
(319) 653-2135
Linn County Health Dept.
Air Pollution Control Division
501 13th St., NW
Cedar Rapids, IA 52405
(319) 398-3551
599
-------
V. Appendix
State of Iowa, ex rel., Iowa DNR vs. Vermeer Manufacturing Company, 99AG23542,
District Court, Marion County, Law No. LACV087889 (attached)
600
-------
Iowa Department of Natural Resources
Title V Operating Permit
Name of Permitted Facility: Vermeer Manufacturing Co.
Facility Location: 1210 Vermeer Road East
Pella, IA 50219
Air Quality Operating Permit Number: 99-TV-052-M001
Expiration Date: October 18,2004
EIQ Number: 92-5246
Facility File Number: 63-02-004
Responsible Official
Kurt Langel
Vice President of Human Resources
1210 Vermeer Road East
Pella, IA 50219
Phone#: (641)628-3141
Permit Contact Person for the Facility
Bob Dougherty
Environmental Engineering Manager
1210 Vermeer Road East
Pella, IA 50219
Phone#: (641)621-7821
This permit is issued in accordance with 567 Iowa Administrative Code Chapter 22, and is issued
subject to the terms and conditions contained in this permit.
For the Director of the Department of Natural Resources
Douglas A. Campbell, Supervisor of Air Operating Permits Section
Vermeer Manufacturing Co.
Date
99-TV-052-M001
-------
Table of Contents
I. Facility Description and Equipment List 5
II. Facility - Wide Conditions 17
III. Emission Point Specific Conditions
A. Cutting Equipment 22
B. Metal Welding and Fabricating Equipment 36
C. Parts Washers 39
D. Plant 4 Multi-Stage Washer System 43
E. Plant 5 Multi-Stage Washer System and Powder Paint Booth 50
F. Plant 6 Multi-Stage Washer System 65
G. Paint Booths 77
H. Paint Ovens 110
I. Paint Kitchens 113
J. Production Engine Testing Units 115
K. Heating Units 121
L. Storage Tanks 129
M. Miscellaneous Equipment 130
IV. General Conditions 145
G1. Duty to Comply
G2. Permit Expiration
G3. Certification Requirement for Title V Related Documents
G4. Annual Compliance Certification
G5. Semi-Annual Monitoring Report
G6. Annual Fee
G7. Inspection of Premises, Records, Equipment, Methods and Discharges
G8. Duty to Provide Information
G9. General Maintenance and Repair Duties
G10. Recordkeeping Requirements for Compliance Monitoring
G11. Prevention of Accidental Release: Risk Management Plan Notification and
Compliance Certification
G12. Hazardous Release
G13. Excess Emissions and Excess Emissions Reporting Requirements
G14. Permit Deviation Reporting Requirements
G15. Notification Requirements for Sources That Become Subject to NSPS and
NESHAP Regulations
G16. Requirements for Making Changes to Emission Sources That Do Not Require
Title V Permit Modification
G17. Duty to Modify a Title V Permit
G18. Duty to Obtain Construction Permits
G19. Asbestos
G20. Open Burning
G21. Acid Rain (Title IV) Emissions Allowances
Vermeer Manufacturing Co.
2
99-TV-052-M001
-------
G22. Stratospheric Ozone and Climate Protection (Title VI) Requirements
G23. Permit Reopenings
G24. Permit Shield
G25. Severability
G26. Property Rights
G27. Transferability
G28. Disclaimer
G29. Notification and Reporting Requirements for Stack Tests or Monitor Certification
G30. Prevention of Air Pollution Emergency Episodes
G31. Contacts List
V. Appendix A:
State of Iowa, ex rel.
Iowa DNR vs. Vermeer Manufacturing Company, 99AG23542
District Court, Marion County, Law No. LACV087889
VI. Appendix B: DNR Air Quality Policy 3-b-08, Opacity Limits
Vermeer Manufacturing Co.
3
99-TV-052-M001
-------
Abbreviations
acfm actual cubic feet per minute
bbl barrel
CFR Code of Federal Regulations
°F degrees Fahrenheit
EIQ emissions inventory questionnaire
gal/hr gallons per hour
gr/dscf grains per dry standard cubic foot
IAC Iowa Administrative Code
Iowa DNR Iowa Department of Natural Resources
LPG liquified petroleum gas (propane)
MMCF million cubic feet
MSDS Material Safety Data Sheet
NAAQS National Ambient Air Quality Standard
NG natural gas
NSPS New Source Performance Standard
ppm parts per million
ppmv parts per million by volume
lb/hr pounds per hour
lb/MMBtu pounds per million British thermal units
scfm standard cubic feet per minute
SEP Supplemental Environmental Project
TPY tons per year
VE visible emissions
Pollutants
PMio particulate matter less than ten (10) microns in size
PM particulate matter
SO2 sulfur dioxide
NOx nitrogen oxide
VOC volatile organic compound
CO carbon monoxide
HAP hazardous air pollutant
Vermeer Manufacturing Co.
4
99-TV-052-M001
-------
I. Facility Description and Equipment List
Facility Name: Vermeer Manufacturing Co.
Permit Number: 99-TV-052-M001
Facility Description: Manufacturer of Farm Machinery and Equipment and Construction
Equipment
Equipment List
A. Cutting Equipment
Emission
Associated
Point
Emission Unit
Associated Emission Unit Description
Number
Number
4.Laser*
4.Laser
Laser Cutting Unit
7.Laser
7.Laser
Laser Cutting Unit
2.Flamel**
2.Flamel
Flame Cutting Unit
2.Flame2
2.Flame2
Flame Cutting Unit
3.Flame4
3.Flame4
Flame Cutting Unit
3.Flame5
3.Flame5
Flame Cutting Unit
4.Flame2
4.Flame2
Flame Cutting Unit
4.Flame3
4.Flame3
Flame Cutting Unit
5.Flamel
5.Flamel
Flame Cutting Unit
7.Flame2
7.Flame2
Flame Cutting Unit
7.Flame3
7.Flame3
Flame Cutting Unit
7.Flame4
7.Flame4
Flame Cutting Unit
7.Flame5
7.Flame5
Flame Cutting Unit
7.Flame6
7.Flame6
Flame Cutting Unit
l.Flamel
l.Flamel
Flame Cutting Unit
1 .Flame2
1 .Flame2
Flame Cutting Unit
3.Flamel
3.Flamel
Flame Cutting Unit
3.Flame2
3.Flame2
Flame Cutting Unit
3.Flame3
3.Flame3
Flame Cutting Unit
4.Flamel
4.Flamel
Flame Cutting Unit
7.Flamel
7.Flamel
Flame Cutting Unit
* The first number is the number of the building where the point/unit is located. (For
example, Emission Point/Unit 4.Laser is located in Building 4.)
** The double border around certain equipment in this list indicates that the enclosed
equipment is grouped in a table in the Emission Point-Specific Conditions section of this
permit.
Vermeer Manufacturing Co.
5
99-TV-052-M001
-------
A. Cutting Equipment (continued)
Emission
Associated
Point
Emission Unit
Associated Emission Unit Description
Number
Number
l.Plasmal
l.Plasmal
Plasma Cutting Unit
2.Plasmal
2.Plasmal
Plasma Cutting Unit
2.Plasma2
2.Plasma2
Plasma Cutting Unit
3.Plasmal
3.Plasmal
Plasma Cutting Unit
3.Plasma2
3.Plasma2
Plasma Cutting Unit
3.Plasma3
3.Plasma3
Plasma Cutting Unit
4.Plasmal
4.Plasmal
Plasma Cutting Unit
4.Plasma2
4.Plasma2
Plasma Cutting Unit
4.Plasma3
4.Plasma3
Plasma Cutting Unit
5.Plasmal
5.Plasmal
Plasma Cutting Unit
5.Plasma2
5.Plasma2
Plasma Cutting Unit
6.Plasmal
6.Plasmal
Plasma Cutting Unit
7.Plasmal
7.Plasmal
Plasma Cutting Unit
7.Plasma2
7.Plasma2
Plasma Cutting Unit
7.Plasma3
7.Plasma3
Plasma Cutting Unit
2.Plasma3
2.Plasma3
Plasma Cutting Unit
2.Plasma4
2.Plasma4
Plasma Cutting Unit
2.Plasma5
2.Plasma5
Plasma Cutting Unit
3.Plasma4
3.Plasma4
Plasma Cutting Unit
3.Plasma5
3.Plasma5
Plasma Cutting Unit
4.Plasma4
4.Plasma4
Plasma Cutting Unit
4.Plasma5
4.Plasma5
Plasma Cutting Unit
5.Plasma3
5.Plasma3
Plasma Cutting Unit
5.Plasma4
5.Plasma4
Plasma Cutting Unit
7.Plasma4
7.Plasma4
Plasma Cutting Unit
3.Plasma6
3.Plasma6
Plasma Cutting Unit
7.Plasma5
7.Plasma5
Plasma Cutting Unit
7.Plasma6
7.Plasma6
Plasma Cutting Unit
1. TORCH
1.TORCH
Torch Cutting Units
2.TORCH
2. TORCH
Torch Cutting Units
3. TORCH
3.TORCH
Torch Cutting Units
4.TORCH
4. TORCH
Torch Cutting Units
5. TORCH
5.TORCH
Torch Cutting Units
6.TORCH
6. TORCH
Torch Cutting Units
7.TORCH
7. TORCH
Torch Cutting Units
P. TORCH
P.TORCH
Torch Cutting Units
Vermeer Manufacturing Co.
6
99-TV-052-M001
-------
B. Metal Welding and Fabricating Equipment
Emission
Associated
Point
Emission
Associated Emission Unit Description
Number
Unit Number
1. WELDING
1. WELDING
Conventional Welding Units
1WELDPLS
1. WELDPLS
Pulse Current Welding Units
2.WELDING
2.WELDING
Conventional Welding Units
2. WELDPLS
2. WELDPLS
Pulse Current Welding Units
3. WELDING
3. WELDING
Conventional Welding Units
3. WELDPLS
3. WELDPLS
Pulse Current Welding Units
4.WELDING
4.WELDING
Conventional Welding Units
4. WELDPLS
4. WELDPLS
Pulse Current Welding Units
5. WELDING
5. WELDING
Conventional Welding Units
5. WELDPLS
5. WELDPLS
Pulse Current Welding Units
6.WELDING
6.WELDING
Conventional Welding Units
6. WELDPLS
6. WELDPLS
Pulse Current Welding Units
7.WELDING
7.WELDING
Conventional Welding Units
7. WELDPLS
7. WELDPLS
Pulse Current Welding Units
P.WELDING
P.WELDING
Conventional Welding Units
P.WELDPLS
P.WELDPLS
Pulse Current Welding Units
1.METAL
1.METAL
Plant 1 Metal Drilling, Machining, and Grinding
2.METAL
2.METAL
Plant 2 Metal Drilling, Machining, and Grinding
3.METAL
3. METAL
Plant 3 Metal Drilling, Machining, and Grinding
4.METAL
4.METAL
Plant 4 Metal Drilling, Machining, and Grinding
5.METAL
5.METAL
Plant 5 Metal Drilling, Machining, and Grinding
6.METAL
6.METAL
Plant 6 Metal Drilling, Machining, and Grinding
C. Parts Washers
Emission
Associated
Point
Emission
Associated Emission Unit Description
Number
Unit Number
7.R
7.R
Parts Washers
P.O
P.O
Parts Washers
l.PRTWSH
l.PRTWSH
Parts Washers
2.PRTWSH
2.PRTWSH
Parts Washers
3.PRTWSH
3.PRTWSH
Parts Washers
4.PRTWSH
4.PRTWSH
Parts Washers
5.PRTWSH
5.PRTWSH
Parts Washers
6.PRTWSH
6.PRTWSH
Parts Washers
7.PRTWSH
7.PRTWSH
Parts Washers
P.PRTWSH
P.PRTWSH
Parts Washers
W.M
W.M
Parts Washers
Vermeer Manufacturing Co.
7
99-TV-052-M001
-------
D. Plant 4 Multi-Stage Washer System
Emission
Associated
Point
Emission Unit
Associated Emission Unit Description
Number
Number
4.DD
4.DD
Stage 1 Washer
4.EE
4.EE
Stage 3 Burner
4.FF
4.FF
Stage 1 Burner
4.GG
4.GG
Stage 5 Washer
E. Plant 5 Multi-Stage Washer System and Powder Paint Booth
Emission
Associated
Point
Emission Unit
Associated Emission Unit Description
Number
Number
5.KK3
5.KK3
Stage 1 Washer
5.KK4
5.KK4
Multi-stage Washer
5.KK5
5.KK5
Stage 1 Burner
5.KK6
5.KK6
Stage 3 Burner
5.KK7
5.KK7
Dry-off Oven
5.KK8
5.KK8
Cure Oven
F. Plant 6 Multi-Stage Washer System
Emission
Associated
Point
Emission Unit
Associated Emission Unit Description
Number
Number
6 QQ
6 QQ
Stage 1 Washer
6.RR
6.RR
Stage 1 Burner
6.SS
6.SS
Stage 3 Burner
6.TT
6.TT
Stage 5 Burner
6.UU
6.UU
Stage 5 Washer
Vermeer Manufacturing Co.
8
99-TV-052-M001
-------
G. Paint Booths
Emission
Associated
Point
Emission Unit
Associated Emission Unit Description
Number
Number
1.AG1
l.AG
Paint Booth
1.AG2
l.AG
Paint Booth
l.K
l.K
Paint Booth
5.G1
5.G
Paint Booth
5.G2
5.G
Paint Booth
5.J
5.J
Paint Booth
6.HH
6.HH
Paint Booth
6.M1
6.M
Paint Booth
6.M2
6.M
Paint Booth
2.All
2.AI
Paint Booth
2AI2
2.AI
Paint Booth
2.F1
2.F
Paint Booth
2.F2
2.F
Paint Booth
2.H
2.H
Paint Booth
3.F1
3.F
Paint Booth
3.F2
3.F
Paint Booth
3.HH
3.HH
Paint Booth
3.II
3.II
Paint Booth
4.F
4.F
Paint Booth
4.G1
4.G
Paint Booth
4.G2
4.G
Paint Booth
6.N
6.N
Paint Booth
6.S
6.S
Paint Booth
H. Paint Ovens
Emission
Associated
Point
Emission Unit
Associated Emission Unit Description
Number
Number
l.J
l.J
Paint Oven
2.1
2.1
Paint Oven
3.B
3.B
Paint Oven
3.JJ
3.JJ
Paint Oven
3.MM
3.MM
Paint Oven
4.E
4.E
Paint Oven
5.1
5.1
Paint Oven
6.F
6.F
Paint Oven
Vermeer Manufacturing Co.
9
99-TV-052-M001
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I. Paint Kitchens
Emission
Associated
Point
Emission Unit
Associated Emission Unit Description
Number
Number(s)
l.AP
l.AP
Paint Kitchen
l.AQ
1.AQ1
Paint Kitchen
1.AQ2
2.AF
2.AF1
Paint Kitchen
2.AF2
2.AG
2.AG
Paint Kitchen
3.GH
3.GH
Paint Kitchen
3.GI
3.GI
Paint Kitchen
3.KK
3.KK
Paint Kitchen
4.CD
4.CD
Paint Kitchen
4.CE
4.CE1
Paint Kitchen
4.CE2
5.BB
5.BB1
Paint Kitchen
5.BB2
5.DD
5.DD
Paint Kitchen
6.FF
6.FF
Paint Kitchen
6.GG
6.GG
Paint Kitchen
6.VV
6.VV
Paint Kitchen
6. WW
6.WW
Paint Kitchen
Vermeer Manufacturing Co.
10
99-TV-052-M001
-------
J. Production Engine Testing Units
Emission
Associated
Point
Emission Unit
Construction Permit #
Number
Number
l.AH
l.AH
Production Engine Testing Unit
2.AB
2.AB
Production Engine Testing Unit
2.G
2.G
Production Engine Testing Unit
2.J
2.J
Production Engine Testing Unit
4.J
4.J
Production Engine Testing Unit
5.N
5.N
Production Engine Testing Unit
5.T
5.T
Production Engine Testing Unit
5.W
5.W
Production Engine Testing Unit
l.AU
l.AU
Production Engine Testing Unit
3.A1
3.A1
Production Engine Testing Unit
3.A2
3.A2
Production Engine Testing Unit
3.D1
3.D1
Production Engine Testing Unit
3.D2
3.D2
Production Engine Testing Unit
3.D3
3.D3
Production Engine Testing Unit
3.S
3.S
Production Engine Testing Unit
3 Z
3 Z
Production Engine Testing Unit
4.1
4.1
Production Engine Testing Unit
4.JJ
4.JJ
Production Engine Testing Unit
4.S
4.S
Production Engine Testing Unit
6.D
6.D
Production Engine Testing Unit
6.K
6.K
Production Engine Testing Unit
6.LL
6.LL
Production Engine Testing Unit
6.MM
6.MM
Production Engine Testing Unit
7.G
7.G
Production Engine Testing Unit
7.H
7.H
Production Engine Testing Unit
7.1
7.1
Production Engine Testing Unit
8.B
8.B
Production Engine Testing Unit
HB.A
HB.A
Production Engine Testing Unit
HB.B
HB.B
Production Engine Testing Unit
Vermeer Manufacturing Co.
11
99-TV-052-M001
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K. Heating Units
Emission
Point
Number
Associated
Emission Unit
Number
Associated Emission
Unit Description
l.AA
l.AA
Non-Production Heating Unit
l.AC
LAC
Non-Production Heating Unit
l.AD
LAD
Non-Production Heating Unit
l.AF
l.AF
Non-Production Heating Unit
LAV
LAV
Non-Production Heating Unit
LAW
LAW
Non-Production Heating Unit
LAX
LAX
Non-Production Heating Unit
LAY
LAY
Non-Production Heating Unit
1.AZ
1.AZ
Non-Production Heating Unit
1.B A
1.B A
Non-Production Heating Unit
l.BC
l.BC
Non-Production Heating Unit
l.BD
l.BD
Non-Production Heating Unit
l.C
l.C
Non-Production Heating Unit
ID
ID
Water Heater
LEE
LEE
Phos Pro Water Heater
IFF
IFF
Non-Production Heating Unit
l.GG
l.GG
Non-Production Heating Unit
1.0
1.0
Non-Production Heating Unit
l.U
l.U
Water Heater
l.Y
l.Y
Non-Production Heating Unit
2.AD1
2.AD1
Make Up Air Unit
2.AD2
2.AD2
Make Up Air Unit
2.AE
2.AE
Make Up Air Unit
2.AH
2.AH
Phos Pro Water Heater
2.AJ
2.AJ
Paint Boot Air Intake
2.B
2.B
Non-Production Heating Unit
2.P
2.P
Non-Production Heating Unit
2 Q
2 Q
Water Heater
2.VI
2.VI
Non-Production Heating Unit
2.V2
2.V2
Non-Production Heating Unit
2.X
2.X
Non-Production Heating Unit
2.Y1
2.Y1
Non-Production Heating Unit
2.Y2
2.Y2
Non-Production Heating Unit
3.AA
3.AA
Parts Oven
3.AD
3. AD
Phos Pro Water Heater
3.AF
3.AF
Non-Production Heating Unit
3. AG
3. AG
Non-Production Heating Unit
3.BB
3.BB
Non-Production Heating Unit
3.C
3.C
Non-Production Heating Unit
3.GG
3.GG
Non-Production Heating Unit
Vermeer Manufacturing Co.
12
99-TV-052-M001
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K. Heating Units (continued)
Emission
Point
Number
Associated
Emission Unit
Number
Associated Emission
Unit Description
3.GK1
3.GK1
Non-Production Heating Unit
3.GK2
3.GK2
Non-Production Heating Unit
3.LL
3.LL
Make Up Air Unit
3.M
3.M
Water Heater
3.P
3.P
Non-Production Heating Unit
3.PP
3.PP
Make Up Air Unit
3.RR
3.RR
Make Up Air Unit
3.SS
3.SS
Make Up Air Unit
3.T
3.T
Non-Production Heating Unit
3.TT
3.TT
Make Up Air Unit
3.UU
3.UU
Make Up Air Unit
3.VV
3.VV
Make Up Air Unit
3.W
3.W
Non-Production Heating Unit
3. WW
3. WW
Make Up Air Unit
3.XI
3.XI
Non-Production Heating Unit
3.X2
3.X2
Non-Production Heating Unit
3.Y1
3.Y1
Non-Production Heating Unit
4.A1
4.A1
Non-Production Heating Unit
4.A2
4.A2
Non-Production Heating Unit
4.A3
4.A3
Non-Production Heating Unit
4AA
4.AA
Non-Production Heating Unit
4AC
4.AC
Non-Production Heating Unit
4.AD
4.AD
Non-Production Heating Unit
4.AE
4.AE
Non-Production Heating Unit
4.AF
4.AF
Non-Production Heating Unit
4.BB
4.BB
Non-Production Heating Unit
4.D
4.D
Water Heater
4.H2
4.H2
Non-Production Heating Unit
4.K1
4.K1
Non-Production Heating Unit
4.KK
4.KK
Wash Bay Heater
4.L
4.L
Non-Production Heating Unit
4.R
4.R
Non-Production Heating Unit
4.T
4.T
Non-Production Heating Unit
5A
5.A
Non-Production Heating Unit
5AA
5.AA
Non-Production Heating Unit
5AJ1
5.AJ1
Make Up Air Unit
5 AJ2
5.AJ2
Make Up Air Unit
5 AJ3
5.AJ3
Make Up Air Unit
5AJ4
5.AJ4
Make Up Air Unit
5 AJ5
5.AJ5
Make Up Air Unit
Vermeer Manufacturing Co.
13
99-TV-052-M001
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K. Heating Units (continued)
Emission
Point
Number
Associated
Emission Unit
Number
Associated Emission
Unit Description
5.AJ6
5.AJ6
Make Up Air Unit
5.AJ7
5.AJ7
Make Up Air Unit
5.AJ8
5.AJ8
Make Up Air Unit
5.B1
5.B1
Non-Production Heating Unit
5.B2
5.B2
Non-Production Heating Unit
5.E
5.E
Water Heater
5.EE
5.EE
Non-Production Heating Unit
5.FF
5.FF
Non-Production Heating Unit
5.GG
5.GG
Non-Production Heating Unit
5.H
5.H
Non-Production Heating Unit
5.HH
5.HH
Non-Production Heating Unit
5.II
5.II
Non-Production Heating Unit
5.JJ
5.JJ
Non-Production Heating Unit
5.K
5.K
Non-Production Heating Unit
5.M
5.M
Non-Production Heating Unit
5.0
5.0
Non-Production Heating Unit
5.P
5.P
Make Up Air Unit
5.R
5.R
Water Heater
6.AA1
6.AA1
Non-Production Heating Unit
6.AA2
6.AA2
Non-Production Heating Unit
6. A A3
6. A A3
Non-Production Heating Unit
6.AA4
6.AA4
Non-Production Heating Unit
6.AB
6.AB
Non-Production Heating Unit
6.AC
6.AC
Non-Production Heating Unit
6.AD
6.AD
Non-Production Heating Unit
6.AE
6.AE
Non-Production Heating Unit
6.AF
6.AF
Non-Production Heating Unit
6.AG
6.AG
Non-Production Heating Unit
6.C
6.C
Non-Production Heating Unit
6.JJ
6.JJ
Paint Boot Air Intake
6.KK
6.KK
Paint Boot Air Intake
6.L
6.L
Non-Production Heating Unit
6 Q
6 Q
Water Heater
6.R
6.R
Non-Production Heating Unit
6.T
6.T
Non-Production Heating Unit
7.B1
7.B1
Non-Production Heating Unit
7.B2
7.B2
Non-Production Heating Unit
7.B3
7.B3
Non-Production Heating Unit
7.B4
7.B4
Non-Production Heating Unit
7.D
7.D
Non-Production Heating Unit
Vermeer Manufacturing Co.
14
99-TV-052-M001
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K. Heating Units (continued)
Emission
Point
Number
Associated
Emission Unit
Number
Associated Emission
Unit Description
7.K
7.K
Non-Production Heating Unit
7.L
7.L
Non-Production Heating Unit
7.M
7.M
Non-Production Heating Unit
7.N
7.N
Non-Production Heating Unit
7.0
7.0
Non-Production Heating Unit
7.P
7.P
Non-Production Heating Unit
7 Q
7.Q
Non-Production Heating Unit
7.S
7.S
Non-Production Heating Unit
7.T
7.T
Non-Production Heating Unit
7.T1
7.T1
Non-Production Heating Unit
7.U
7.U
Non-Production Heating Unit
7.V
7.V
Non-Production Heating Unit
7.W
7.W
Non-Production Heating Unit
7.X
7.X
Non-Production Heating Unit
8.A1
8.A1
Non-Production Heating Unit
8.A2
8.A2
Non-Production Heating Unit
8. A3
8.A3
Non-Production Heating Unit
8.A4
8.A4
Non-Production Heating Unit
8.A5
8.A5
Non-Production Heating Unit
8.A6
8.A6
Non-Production Heating Unit
8.A7
8.A7
Non-Production Heating Unit
8.A8
8.A8
Non-Production Heating Unit
8.A9
8.A9
Non-Production Heating Unit
8.A10
8.A10
Non-Production Heating Unit
8. All
8.A11
Non-Production Heating Unit
8.A12
8.A12
Non-Production Heating Unit
HB.J
HB.J
Non-Production Heating Unit
HB.N
HB.N
Non-Production Heating Unit
P.C1
P.C1
Non-Production Heating Unit
P.C2
P.C2
Non-Production Heating Unit
P.D1
P.D1
Non-Production Heating Unit
P.D2
P.D2
Non-Production Heating Unit
P.D3
P.D3
Non-Production Heating Unit
P.E
P.E
Non-Production Heating Unit
PB.A
PB.A
Non-Production Heating Unit
W.B
W.B
Hotsey Washer
P.A1
P.A1
Non-Production Heating Unit
P.A2
P.A2
Non-Production Heating Unit
Q A
Q A
Non-Production Heating Unit
WW.A
WW.A
Non-Production Heating Unit
Vermeer Manufacturing Co.
15
99-TV-052-M001
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L. Storage Tanks
Emission
Associated
Point
Emission Unit
Associated Emission Unit Description
Number
Number
DSLTANK2
DSLTANK2
Storage Tank
DSLTANK4
DSLTANK4
Storage Tank
DSLTANK8
DSLTANK8
Storage Tank
DSLTANK9
DSLTANK9
Storage Tank
GASTANK3
GASTANK3
Storage Tank
GASTANK7
GASTANK7
Storage Tank
OILTANK
OILTANK
Storage Tank
PROPANE
PROPANE
Three (3) Storage Tanks
PROPYLENE
PROPYLENE
Three (3) Storage Tanks
M. Miscellaneous Equipment
Emission
Associated
Point
Emission Unit
Associated Emission Unit Description
Number
Number
l.T
l.T
Steel Shot Metal Blast Booth
WE
WE
Hook Burn-Off Oven
W.F1
W.F1
Waste Solvent Still
W.F2
W.F2
Waste Solvent Still
W.H
W.H
Aerosol Can Crusher
W.I
W.I
Hook Burn-Off Oven
F.SAND
F.SAND
Sand Blasting Unit (Fugitive)
F.SODA
F.SODA
Soda Blasting Unit (Fugitive)
Vermeer Manufacturing Co.
16
99-TV-052-M001
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II. Facility-Wide Conditions
Facility Name: Vermeer Manufacturing Co.
Permit Number: 99-TV-052-M001
Permit conditions are established in accord with 567 Iowa Administrative Code rule 22.108
Permit Duration
The term of this permit is: .... 5 years
Commencing on: October 19, 1999
Ending on: October 18, 2004
Amendments, modifications and reopenings of the permit shall be obtained in accordance with
567 Iowa Administrative Code rules 22.110 - 22.114. Permits may be suspended, terminated, or
revoked as specified in 567 Iowa Administrative Code Rules 22.115.
Emission Limits
The atmospheric emissions from the facility and the specified units shall not exceed the
following:
Pollutant: Nitrogen Oxides (NOx) Facility-wide limit
Emission Rate (tons/yr.): 249
Authority for Requirement: Iowa DNR Construction Permit 97-A-298-S3, (see Emission Point-
Specific Conditions for other construction permit citations)
Pollutant: Volatile Organic Compound (VOC) Facility-wide limit
Emission Rate (tons/yr.): 249
Authority for Requirement: Iowa DNR Construction Permit 96-A-1216-S4, (see Emission
Point-Specific Conditions for other construction permit citations)
Pollutant: Hazardous Air Pollutants (HAP)
Emission Rate (tons/yr.): Emissions shall remain below 10 tons per year of any HAP, and
below 25 tons per year of any combination of HAPs.
Authority for Requirement: This limit was requested by the applicant.
567 IAC 22.108(14)
The facility requested this limit, with the intent that the facility will remain an area source with
regard to 40 CFR Part 63, National Emission Standards for Hazardous Air Pollutants.
Vermeer Manufacturing Co.
17
99-TV-052-M001
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Reporting & Recordkeeping
Painting Operations
All records, as required in the following, shall be satisfactory for demonstrating compliance
with all applicable emission limits.
Records shall be kept on-site for five years and shall be available for inspection by the
Department. Records shall be maintained in a legible and orderly manner and shall indicate
the following:
A. The amount of each paint and solvent used in all painting operations, other than
architectural, in gallons. Calculate and record monthly and 12-month rolling totals for
each paint and solvent.
B. The VOC content of any paint and solvent used in all painting operations, other than
architectural, in pounds per gallon.
C. The amount of paint and solvent waste sent off-site for disposal from all painting
operations, other than architectural, in gallons. Calculate and record monthly and 12-
month rolling totals for each waste stream.
D. The VOC content of any paint and solvent waste from production operations, other than
architectural, sent off site for disposal, in pounds per gallon.
E. The amount of solvent recycled for re-use in all painting operations, other than
architectural, in gallons.
F. The VOC content of any solvent recycled for reuse in all painting operations, other than
architectural, in pounds per gallon.
G. Calculate and record monthly and 12-month rolling totals of VOC emissions from all
painting operations, other than architectural, at this source, in tons.
H. Calculate and record monthly and 12-month rolling totals of VOC emissions from all
emission units at this source, in tons.
Authority for Requirement: Iowa DNR Construction Permit 97-A-972-S3, (see Emission Point-
Specific Conditions for other construction permit citations)
Hazardous Air Pollutants (HAP)
All records, as required in the following, shall be satisfactory for demonstrating compliance
with all applicable emission limits.
Records shall be kept on-site for five years and shall be available for inspection by the
Department. Records shall be maintained in a legible and orderly manner and shall indicate
the following:
A. The content of each HAP contained in any paint and solvent used in all painting
operations, other than architectural, in pounds per gallon.
B. The content of each HAP contained in any paint and solvent waste from production
operations, other than architectural, sent off site for disposal, in pounds per gallon.
C. The content of each HAP contained in any solvent recycled for reuse in all painting
operations, other than architectural, in pounds per gallon.
D. Calculate and record monthly and 12-month rolling totals of individual and total HAP
emissions from all painting operations, other than architectural, at this source, in tons.
E. Calculate and record monthly and 12-month rolling totals of individual and total HAP
emissions from all emission units at this source, in tons.
Authority for Requirement: 567 IAC 22.108(3)
Vermeer Manufacturing Co.
18
99-TV-052-M001
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Liquid Fuels
A. The amount of diesel fuel used in all production test units, in gallons. Calculate and
record monthly and 12-month rolling totals.
B. The amount of gasoline used in all production test units, in gallons. Calculate and record
monthly and 12-month rolling totals.
C. The sulfur content of any diesel fuel used in all production test units, in weight percent.
D. The amount of VOC emitted by the production test units, in tons. Calculate and record
monthly and 12-month rolling totals. Emissions must be based on total gallons used and
AP-42 factors for engines less than 600 hp.
E. The amount of NOx emitted by the production test units, in tons. Calculate and record
monthly and 12-month rolling totals. Emissions must be based on total gallons used and
AP-42 factors for engines less than 600 hp.
F. Calculate and record monthly and 12-month rolling totals of NOx emissions from all
production test units at this source, in tons.
G. Calculate and record monthly and 12-month rolling totals of VOC emissions from all
production test units at this source, in tons.
H. Calculate and record monthly and 12-month rolling totals of NOx emissions from all
emission units at this source, in tons.
I. Calculate and record monthly and 12-month rolling totals of VOC emissions from all
emission units at this source, in tons.
Authority for Requirement: Iowa DNR Construction Permit 97-A-299-S3, (see Emission Point-
Specific Conditions for other construction permit citations)
567 IAC 22.108(3)
Gaseous Fuels
A. The amount of natural gas used in all units, in cubic feet. Calculate and record monthly
and 12-month rolling totals.
B. The amount of propane used in all units, in gallons. Calculate and record monthly and
12-month rolling totals.
C. The amount VOC emitted by all natural gas and propane fired units, in tons. Calculate
and record monthly and 12-month rolling totals.
D. The amount NOx emitted by all natural gas and propane fired units, in tons. Calculate
and record monthly and 12-month rolling totals.
Authority for Requirement: Iowa DNR Construction Permit 98-A-094-S1, (see Emission Point-
Specific Conditions for other construction permit citations)
Facility-Wide Operational Limits
Unless specified otherwise in the Emission Point-Specific Conditions, the following limitations
and supporting regulations apply to all emission points at this facility:
Process Throughput:
The sulfur content of any number one or number two diesel fuel combusted at this facility
shall not exceed 0.5% by weight.
Authority for Requirement: 567 IAC 23.3(3)"b"
Vermeer Manufacturing Co.
19
99-TV-052-M001
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Process Throughput:
The sulfur content of natural gas or LPG combusted in indirectly fired emission units at this
facility shall not exceed 123 ppm by weight.
Reporting & Record keeping:
All records, as required in the following, shall demonstrate compliance with all applicable
limits on LPG. Records shall be made available for inspection upon request by
representatives of the Iowa DNR. The records, as a minimum, shall consist of the following:
A. The amount of LPG purchased by this facility, in gallons. Calculate and record monthly
and twelve (12) month rolling totals.
B. The owner/operator shall obtain two reports per year from the LPG supplier, one in July
and one in December, to verify the sulfur content of the LPG.
Authority for Requirement: Part 7a. of State of Iowa, ex rel., Iowa DNR vs. Vermeer
Manufacturing Company, 99AG23542
District Court, Marion County, Law No. LACV087889
Opacity (visible emissions): 40% opacity
Authority for Requirement: 567 IAC 23.3(2)"d"
Sulfur Dioxide (SO?): 500 ppmv
Authority for Requirement: 567 IAC 23.3(3)"e"
Particulate Matter: No person shall cause or allow the emission of particulate matter from any
source in excess of the emission standards specified in this chapter, except as provided in 567
IAC Chapter 24. For sources constructed, modified or reconstructed after July 21, 1999, the
emission of particulate matter from any process shall not exceed an emission standard of 0.1
grain per dry standard cubic foot of exhaust gas, except as provided in 567 IAC 21.2(455B),
23.1(455B), 23.4(455B) and 567 IAC Chapter 24.
For sources constructed, modified or reconstructed prior to July 21, 1999, the emission of
particulate matter from any process shall not exceed the amount determined from Table I, or
amount specified in a permit if based on an emission standard of 0.1 grain per standard cubic
foot of exhaust gas or established from standards provided in 23.1(455B) and 23.4(455B).
Authority for Requirement: 567 IAC 23.3(2)"a"
Fugitive Dust: Attainment and Unclassified Areas - No person shall allow, cause or permit any
materials to be handled, transported or stored; or a building, its appurtenances or a construction
haul road to be used, constructed, altered, repaired or demolished, with the exception of farming
operations or dust generated by ordinary travel on unpaved public roads, without taking
reasonable precautions to prevent particulate matter in quantities sufficient to create a nuisance,
as defined in Iowa Code section 657.1, from becoming airborne. All persons, with the above
exceptions, shall take reasonable precautions to prevent the discharge of visible emissions of
fugitive dusts beyond the lot line of the property on which the emissions originate. The highway
authority shall be responsible for taking corrective action in those cases where said authority has
received complaints of or has actual knowledge of dust conditions that require abatement
pursuant to this subrule. Reasonable precautions may include, but not limited to, the following
procedures.
Vermeer Manufacturing Co.
20
99-TV-052-M001
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1. Use, where practical, of water or chemicals for control of dusts in the demolition of
existing buildings or structures, construction operations, the grading of roads or the
clearing of land.
2. Application of suitable materials, such as but not limited to asphalt, oil, water or
chemicals on unpaved roads, material stockpiles, race tracks and other surfaces which can
give rise to airborne dusts.
3. Installation and use of containment or control equipment, to enclose or otherwise limit
the emissions resulting from the handling and transfer of dusty materials, such as but not
limited to grain, fertilizers or limestone.
4. Covering at all times when in motion, open-bodied vehicles transporting materials likely
to give rise to airborne dusts.
5. Prompt removal of earth or other material from paved streets or to which earth or other
material has been transported by trucking or earth-moving equipment, erosion by water
or other means.
Authority for Requirement: 567 IAC 23.3(2)"c"
Compliance Plan
The owner/operator shall comply with the applicable requirements listed below. The compliance
status is based on information provided by the applicant.
Unless otherwise noted in Section III of this permit, Vermeer Manufacturing Co. is in
compliance with all applicable requirements and shall continue to comply with all such
requirements. For those applicable requirements which become effective during the permit term,
Vermeer Manufacturing Co. shall comply with such requirements in a timely manner.
Authority for Requirement: 567 IAC 22.108(15)
Vermeer Manufacturing Co.
21
99-TV-052-M001
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III. Emission Point-Specific Conditions
Facility Name: Vermeer Manufacturing Co.
Permit Number: 99-TV-052-M001
Emission Point ID Number: 4.Laser
Associated Equipment
Associated Emission Unit ID Numbers: 4.Laser
Emissions Control Equipment ID Numbers: 4.Laser
Emissions Control Equipment Description: Baghouse
Applicable Requirements
Emission Units vented through this Emission Point: 4.Laser
Emission Units Description: Single Head Laser Cutter
Raw Material/Fuel: Sheet Steel
Rated Capacity: 8,268 inches steel/cutting head/hour
Emission Limits (lb/hr, gr/dscf, lb/MMBtu, % opacity, etc.)
The emissions from this emission point shall not exceed the following specified levels.
Pollutant: Fugitive Dust
Emission Limit: No person shall allow, cause or permit any materials to be handled, transported
or stored; or a building, its appurtenances or a construction haul road to be used, constructed,
altered, repaired or demolished, without taking reasonable precautions to prevent a nuisance.
All persons shall take reasonable precautions to prevent the discharge of visible emissions of
fugitive dusts beyond the lot line of the property on which the emissions originate.
Authority for Requirement: 567 IAC 23.3(2)"c"
Pollutant: Hazardous Air Pollutants (HAP)
Emission Limit: See Facility-Wide Conditions
Periodic Monitoring Requirements
The owner/operator of this equipment shall comply with the following periodic monitoring
requirements.
Agency Approved Operation & Maintenance Plan Required? Yes ~ No |EI
Facility Maintained Operation & Maintenance Plan Required? Yes ~ No |EI
Authority for Requirement: 567 IAC 22.108(3)"b"
Vermeer Manufacturing Co. 22 99-TV-052-M001
-------
Emission Point ID Number: 7.LASER
Associated Equipment
Associated Emission Unit ID Number: 7.LASER
Emissions Control Equipment ID Number: 7.LASER
Emissions Control Equipment Description: Baghouse
Applicable Requirements
Emission Unit vented through this Emission Point: 7.LASER
Emission Unit Description: Four (4) Single Head Laser Cutters
Raw Material/Fuel: Sheet Steel
Rated Capacity: 4,800 inches steel/cutting head/hr
Emission Limits (lb/hr, gr/dscf, lb/MMBtu, % opacity, etc.)
The emissions from this emission point shall not exceed the following specified levels.
Pollutant: Opacity
Emission Limit: 40 %
Indicator Opacity: 25%(1)
(1) If visible emissions are observed that exceed the indicator opacity other than startup,
shutdown or malfunction, a stack test may be required to demonstrate compliance with the
particulate standard.
Authority for Requirement: 567 IAC 23.3(2)"d"
Iowa DNR Construction Permit 98-A-456-S1
Pollutant: Particulate Matter
Emission Limit: 0.1 gr/scf
Authority for Requirement: 567 IAC 23.3(2)"a"
Iowa DNR Construction Permit 98-A-456-S1
Pollutant: Volatile Organic Compounds (VOC)
Emission Limit: See Facility-Wide Conditions
Authority for Requirement: Iowa DNR Construction Permit 98-A-456-S1
Pollutant: Hazardous Air Pollutants (HAP)
Emission Limit: See Facility-Wide Conditions
Vermeer Manufacturing Co. 23 99-TV-052-M001
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Operational Limits & Requirements
The owner/operator of this equipment shall comply with the operational limits and requirements
listed below.
Operating Limits:
This source is comprised of four lasercutting tables.
Authority for Requirement: Iowa DNR Construction Permit 98-A-456-S1
Emission Point Characteristics
This emission point shall conform to the following conditions.
Stack Height (feet): 25
Stack Diameter (inches): 18
Stack Exhaust Flow Rate (scfm): 4,800
Stack Temperature (°F): Ambient
Vertical, Unobstructed Discharge Required: Yes ~ No El
Authority for Requirement: Iowa DNR Construction Permit 98-A-456-S1
Periodic Monitoring Requirements
The owner/operator of this equipment shall comply with the following periodic monitoring
requirements.
Agency Approved Operation & Maintenance Plan Required? Yes ~ No |EI
Facility Maintained Operation & Maintenance Plan Required? Yes ~ No |EI
Authority for Requirement: 567 IAC 22.108(3)"b"
Vermeer Manufacturing Co.
24
99-TV-052-M001
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Emission Point ID Number: See Table FLAME-NC
Applicable Requirements
(Hie following requirements apply to the emission units identified in Table FLAME-NC)
Emission Units vented through this Emission Point: See Table FLAME-NC
Emission Units Description: Oxyacetylene Flame Cutting Units
Raw Material/Fuel: Sheet Steel
Rated Capacity: 660 inches steel/cutting head/hour
Table FLAME-NC
(Flame cutting units with no control device)
Emission Point
Number
Associated
Emission Unit
Number
Control
Equipment ID
Number
Number of
Cutting Heads
Building
Number
2.Flamel
2.Flamel
None
1
2
2.Flame2
2.Flame2
None
1
2
3.Flame4
3.Flame4
None
1
3
3.Flame5
3.Flame5
None
1
3
4.Flame2
4.Flame2
None
1
4
4.Flame3
4.Flame3
None
1
4
5.Flamel
5.Flamel
None
1
5
7.Flame2
7.Flame2
None
7
7.Flame3
7.Flame3
None
1
7
7.Flame4
7.Flame4
None
1
7
7.Flame5
7.Flame5
None
1
7
7.Flame6
7.Flame6
None
1
7
Emission Limits (lb/hr, gr/dscf, lb/MMBtu, % opacity, etc.)
The emissions from each emission point identified in Table FLAME-NC shall not exceed the
following specified levels.
Pollutant: Fugitive Dust
Emission Limit: No person shall allow, cause or permit any materials to be handled, transported
or stored; or a building, its appurtenances or a construction haul road to be used, constructed,
altered, repaired or demolished, without taking reasonable precautions to prevent a nuisance.
All persons shall take reasonable precautions to prevent the discharge of visible emissions of
fugitive dusts beyond the lot line of the property on which the emissions originate.
Authority for Requirement: 567 IAC 23.3(2)"c"
Pollutant: Hazardous Air Pollutants (HAP)
Emission Limit: See Facility-Wide Conditions
Venneer Manufacturing Co.
25
99-TV-052-M001
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Periodic Monitoring Requirements
The owner/operator of each piece of equipment identified in Table FLAME-NC shall comply
with the following periodic monitoring requirements.
Agency Approved Operation & Maintenance Plan Required? Yes ~ No |EI
Facility Maintained Operation & Maintenance Plan Required? Yes ~ No |EI
Authority for Requirement: 567 IAC 22.108(3)"b"
Vermeer Manufacturing Co.
26
99-TV-052-M001
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Emission Point ID Number: See Table FLAME-WT
Applicable Requirements
(Hie following requirements apply to the emission units identified in Table FLAME-WT)
Emission Units vented through this Emission Point: See Table FLAME-WT
Emission Units Description: Oxyacetylene Flame Cutting Units
Raw Material/Fuel: Sheet Steel
Rated Capacity: 660 inches steel/cutting head/hour
Table FLAME-WT
(Flame cutting units controlled by a water table)
Emission
Point
Number
Associated
Emission Unit
Number
Control
Equipment
ID Number
Control
Equipment
Description
Number of
Cutting
Heads
Building
Number
l.Flamel
l.Flamel
l.Flamel
Water Table
1
1
1 .Flame2
1 .Flame2
1 .Flame2
Water Table
1
1
3.Flamel
3.Flame 1
3.Flame 1
Water Table
1
3
3.Flame2
3.Flame2
3.Flame2
Water Table
8
3
3.Flame3
3.Flame3
3.Flame3
Water Table
8
3
4.Flamel
4.Flamel
4.Flamel
Water Table
2
4
7.Flamel
7.Flamel
7.Flamel
Water Table
1
7
Emission Limits (lb/hr, gr/dscf, lb/MMBtu, % opacity, etc.)
The emissions from each emission point identified in Table FLAME-WT shall not exceed the
following specified levels.
Pollutant: Fugitive Dust
Emission Limit: No person shall allow, cause or permit any materials to be handled, transported
or stored; or a building, its appurtenances or a construction haul road to be used, constructed,
altered, repaired or demolished, without taking reasonable precautions to prevent a nuisance.
All persons shall take reasonable precautions to prevent the discharge of visible emissions of
fugitive dusts beyond the lot line of the property on which the emissions originate.
Authority for Requirement: 567 IAC 23.3(2)"c"
Pollutant: Hazardous Air Pollutants (HAP)
Emission Limit: See Facility-Wide Conditions
Venneer Manufacturing Co.
27
99-TV-052-M001
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Periodic Monitoring Requirements
The owner/operator of each piece of equipment identified in Table FLAME-WT shall comply
with the following periodic monitoring requirements.
Agency Approved Operation & Maintenance Plan Required? Yes ~ No |EI
Facility Maintained Operation & Maintenance Plan Required? Yes ~ No |EI
Authority for Requirement: 567 IAC 22.108(3)"b"
Vermeer Manufacturing Co.
28
99-TV-052-M001
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Emission Point ID Number: See Table PLASMA-NC
Applicable Requirements
(The following requirements apply to the emission units identified in Table PLASMA-NC)
Emission Units vented through this Emission Point: See Table PLASMA-NC
Emission Units Description: Plasma Cutting Units
Raw Material/Fuel: Sheet Steel
Rated Capacity: 4,500 inches steel/cutting head/hour
Table PLASMA-NC
(Plasma cutting units with no control device)
Emission Point
Number
Associated
Emission Unit
Number
Control
Equipment ID
Number
Number of
Cutting Heads
Building
Number
1.Plasma 1
l.Plasmal
None
1
1
2.Plasmal
2.Plasmal
None
1
2
2.Plasma2
2.Plasma2
None
1
2
3.Plasma 1
3.Plasmal
None
1
3
3.Plasma2
3.Plasma2
None
1
3
3.Plasma3
3.Plasma3
None
1
3
4.Plasmal
4.Plasmal
None
1
4
4.Plasma2
4.Plasma2
None
1
4
4.Plasma3
4.Plasma3
None
1
4
5.Plasma 1
5.Plasmal
None
1
5
5.Plasma2
5.Plasma2
None
1
5
6.Plasmal
6.Plasmal
None
1
6
7.Plasmal
7.Plasmal
None
1
7
7.Plasma2
7.Plasma2
None
1
7
7.Plasma3
7.Plasma3
None
1
7
Emission Limits (lb/hr, gr/dscf, lb/MMBtu, % opacity, etc.)
The emissions from each emission point identified in Table PLASMA-NC shall not exceed the
following specified levels.
Pollutant: Fugitive Dust
Emission Limit: No person shall allow, cause or permit any materials to be handled, transported
or stored; or a building, its appurtenances or a construction haul road to be used, constructed,
altered, repaired or demolished, without taking reasonable precautions to prevent a nuisance.
All persons shall take reasonable precautions to prevent the discharge of visible emissions of
fugitive dusts beyond the lot line of the property on which the emissions originate.
Authority for Requirement: 567 IAC 23.3(2)"c"
Venneer Manufacturing Co.
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99-TV-052-M001
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Pollutant: Hazardous Air Pollutants (HAP)
Emission Limit: See Facility-Wide Conditions
Periodic Monitoring Requirements
The owner/operator of each piece of equipment identified in Table PLASMA-NC shall comply
with the following periodic monitoring requirements.
Agency Approved Operation & Maintenance Plan Required? Yes ~ No |EI
Facility Maintained Operation & Maintenance Plan Required? Yes ~ No |EI
Authority for Requirement: 567 IAC 22.108(3)"b"
Vermeer Manufacturing Co.
30
99-TV-052-M001
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Emission Point ID Number: See Table PLASMA-BH
Applicable Requirements
(The following requirements apply to the emission units identified in Table PLASMA-BH)
Emission Units vented through this Emission Point: See Table PLASMA-BH
Emission Units Description: Whitney Plasma Cutting Units
Raw Material/Fuel: Sheet Steel
Rated Capacity: 12,000 inches steel/cutting head/hour
Table PLASMA-BH
(Plasma cutting units controlled by a baghouse)
Emission
Point
Number
Associated
Emission Unit
Number
Control
Equipment
ID Number
Control
Equipment
Description
Number of
Cutting
Heads
Building
Number
2.Plasma3
2.Plasma3
2.Plasma3
Baghouse
1
2
2.Plasma4
2.Plasma4
2.Plasma4
Baghouse
1
2
2.Plasma5
2.Plasma5
2.Plasma5
Baghouse
1
2
3.Plasma4
3.Plasma4
3.Plasma4
Baghouse
1
3
3.Plasma5
3.Plasma5
3.Plasma5
Baghouse
1
3
4.Plasma4
4.Plasma4
4.Plasma4
Baghouse
1
4
4.Plasma5
4.Plasma5
4.Plasma5
Baghouse
1
4
5.Plasma3
5.Plasma3
5.Plasma3
Baghouse
1
5
5.Plasma4
5.Plasma4
5.Plasma4
Baghouse
1
5
7.Plasma4
7.Plasma4
7.Plasma4
Baghouse
1
7
Emission Limits (lb/hr, gr/dscf, lb/MMBtu, % opacity, etc.)
The emissions from each emission point identified in Table PLASMA-BH shall not exceed the
following specified levels.
Pollutant: Fugitive Dust
Emission Limit: No person shall allow, cause or permit any materials to be handled, transported
or stored; or a building, its appurtenances or a construction haul road to be used, constructed,
altered, repaired or demolished, without taking reasonable precautions to prevent a nuisance.
All persons shall take reasonable precautions to prevent the discharge of visible emissions of
fugitive dusts beyond the lot line of the property on which the emissions originate.
Authority for Requirement: 567 IAC 23.3(2)"c"
Pollutant: Hazardous Air Pollutants (HAP)
Emission Limit: See Facility-Wide Conditions
Venneer Manufacturing Co.
31
99-TV-052-M001
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Periodic Monitoring Requirements
The owner/operator of each piece of equipment identified in Table PLASMA-BH shall comply
with the following periodic monitoring requirements.
Agency Approved Operation & Maintenance Plan Required? Yes ~ No |EI
Facility Maintained Operation & Maintenance Plan Required? Yes ~ No |EI
Authority for Requirement: 567 IAC 22.108(3)"b"
Vermeer Manufacturing Co.
32
99-TV-052-M001
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Emission Point ID Number: See Table PLASMA-WT
Applicable Requirements
(The following requirements apply to the emission units identified in Table PLASMA-WT)
Emission Units vented through this Emission Point: See Table PLASMA-WT
Emission Units Description: Whitney Plasma Cutting Units
Raw Material/Fuel: Sheet Steel
Rated Capacity: 12,000 inches steel/cutting head/hour
Table PLASMA-WT
(Plasma cutting units controlled by a water table)
Emission
Point
Number
Associated
Emission Unit
Number
Control
Equipment
ID Number
Control
Equipment
Description
Number of
Cutting
Heads
Building
Number
3.Plasma6
3.Plasma6
3.Plasma6
Water Table
1
3
7.Plasma5
7.Plasma5
7.Plasma5
Water Table
1
7
7.Plasma6
7.Plasma6
7.Plasma6
Water Table
1
7
Emission Limits (lb/hr, gr/dscf, lb/MMBtu, % opacity, etc.)
The emissions from each emission point identified in Table PLASMA-WT shall not exceed the
following specified levels.
Pollutant: Fugitive Dust
Emission Limit: No person shall allow, cause or permit any materials to be handled, transported
or stored; or a building, its appurtenances or a construction haul road to be used, constructed,
altered, repaired or demolished, without taking reasonable precautions to prevent a nuisance.
All persons shall take reasonable precautions to prevent the discharge of visible emissions of
fugitive dusts beyond the lot line of the property on which the emissions originate.
Authority for Requirement: 567 IAC 23.3(2)"c"
Pollutant: Hazardous Air Pollutants (HAP)
Emission Limit: See Facility-Wide Conditions
Periodic Monitoring Requirements
The owner operator of each piece of equipment identified in Table PLASMA-WT shall comply
with the following periodic monitoring requirements.
Agency Approved Operation & Maintenance Plan Required? Yes ~ No |EI
Facility Maintained Operation & Maintenance Plan Required? Yes ~ No |EI
Authority for Requirement: 567 IAC 22.108(3)"b"
Venneer Manufacturing Co.
33
99-TV-052-M001
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Emission Point ID Number: See Table TORCH
Applicable Requirements
(Hie following requirements apply to the emission units identified in Table TORCH)
Emission Units vented through this Emission Point: See Table TORCH
Emission Units Description: Single Cutting Head Oxyacetylene Torch Cutting Units
Raw Material/Fuel: Sheet Steel
Rated Capacity: 840 inches of steel cut/hr
Table TORCH
(Torch cutting units)
Emission Point
Number
Associated Emission
Unit Number
Number of Cutters
Building Number
1. TORCH
1.TORCH
9
1
2.TORCH
2. TORCH
9
2
3. TORCH
3.TORCH
17
3
4.TORCH
4. TORCH
13
4
5. TORCH
5.TORCH
7
5
6.TORCH
6. TORCH
10
6
7.TORCH
7. TORCH
10
7
P. TORCH
P.TORCH
2
Parts
Emission Limits (lb/hr, gr/dscf, lb/MMBtu, % opacity, etc.)
The emissions from each emission point identified in Table TORCH shall not exceed the
following specified levels.
Pollutant: Fugitive Dust
Emission Limit: No person shall allow, cause or permit any materials to be handled, transported
or stored; or a building, its appurtenances or a construction haul road to be used, constructed,
altered, repaired or demolished, without taking reasonable precautions to prevent a nuisance.
All persons shall take reasonable precautions to prevent the discharge of visible emissions of
fugitive dusts beyond the lot line of the property on which the emissions originate.
Authority for Requirement: 567 IAC 23.3(2)"c"
Pollutant: Hazardous Air Pollutants (HAP)
Emission Limit: See Facility-Wide Conditions
Venneer Manufacturing Co.
34
99-TV-052-M001
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Periodic Monitoring Requirements
The owner/operator of each piece of equipment identified in Table TORCH shall comply with the
following periodic monitoring requirements.
Agency Approved Operation & Maintenance Plan Required? Yes ~ No |EI
Facility Maintained Operation & Maintenance Plan Required? Yes ~ No |EI
Authority for Requirement: 567 IAC 22.108(3)"b"
Vermeer Manufacturing Co.
35
99-TV-052-M001
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Emission Point ID Number: See Table WELD
Applicable Requirements
(The following requirements apply to the emission units identified in Table WELD)
Emission Units vented through this Emission Point: See Table WELD
Emission Units Description: GMAW Welding Units
Raw Material/Fuel: E70S weld wire
Rated Capacity: 19 lb of wire/hr per unit
Table WELD
(GMAW welding units)
Emission Point
Number
Associated
Emission Unit
Number
Type of Welder
Number of
Welders
Building
Number
1. WELDING
1. WELDING
Conventional
49
1
1WELDPLS
1. WELDPLS
Pulse Current
38
1
2.WELDING
2.WELDING
Conventional
45
2
2. WELDPLS
2. WELDPLS
Pulse Current
24
2
3. WELDING
3. WELDING
Conventional
60
3
3. WELDPLS
3. WELDPLS
Pulse Current
33
3
4.WELDING
4.WELDING
Conventional
61
4
4. WELDPLS
4. WELDPLS
Pulse Current
47
4
5. WELDING
5. WELDING
Conventional
42
5
5. WELDPLS
5. WELDPLS
Pulse Current
49
5
6.WELDING
6.WELDING
Conventional
43
6
6. WELDPLS
6. WELDPLS
Pulse Current
32
6
7.WELDING
7.WELDING
Conventional
35
7
7. WELDPLS
7. WELDPLS
Pulse Current
54
7
P.WELDING
P.WELDING
Conventional
3
Parts
P.WELDPLS
P.WELDPLS
Pulse Current
1
Parts
Emission Limits (lb/hr, gr/dscf, lb/MMBtu, % opacity, etc.)
The emissions from each emission point identified in Table WELD shall not exceed the following
specified levels.
Pollutant: Fugitive Dust
Emission Limit: No person shall allow, cause or permit any materials to be handled, transported
or stored; or a building, its appurtenances or a construction haul road to be used, constructed,
altered, repaired or demolished, without taking reasonable precautions to prevent a nuisance.
All persons shall take reasonable precautions to prevent the discharge of visible emissions of
fugitive dusts beyond the lot line of the property on which the emissions originate.
Authority for Requirement: 567 IAC 23.3(2)"c"
Vermeer Manufacturing Co.
36
99-TV-052-M001
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Pollutant: Hazardous Air Pollutants (HAP)
Emission Limit: See Facility-Wide Conditions
Periodic Monitoring Requirements
The owner/operator of each piece of equipment identified in Table WELD shall comply with the
following periodic monitoring requirements.
Agency Approved Operation & Maintenance Plan Required? Yes ~ No |EI
Facility Maintained Operation & Maintenance Plan Required? Yes ~ No |EI
Authority for Requirement: 567 IAC 22.108(3)"b"
Vermeer Manufacturing Co.
37
99-TV-052-M001
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Emission Point ID Number: See Table METAL
Applicable Requirements
(Hie following requirements apply to the emission units identified in Table METAL)
Table METAL
(Metal fabricating units)
Emission
Point
Number
Associated
Emission Unit
Number
Associated Emission Unit Description
Raw
Material
Rated
Capacity
1. METAL
1. METAL
Metal Drilling, Machining, and Grinding
Sheet Steel
Variable
2. METAL
2.METAL
Metal Drilling, Machining, and Grinding
Sheet Steel
Variable
3.METAL
3.METAL
Metal Drilling, Machining, and Grinding
Sheet Steel
Variable
4.METAL
4.METAL
Metal Drilling, Machining, and Grinding
Sheet Steel
Variable
5.METAL
5.METAL
Metal Drilling, Machining, and Grinding
Sheet Steel
Variable
6.METAL
6.METAL
Metal Drilling, Machining, and Grinding
Sheet Steel
Variable
Emission Limits (lb/hr, gr/dscf, lb/MMBtu, % opacity, etc.)
The emissions from each emission point identified in Table METAL shall not exceed the
following specified levels.
Pollutant: Fugitive Dust
Emission Limit: No person shall allow, cause or permit any materials to be handled, transported
or stored; or a building, its appurtenances or a construction haul road to be used, constructed,
altered, repaired or demolished, without taking reasonable precautions to prevent a nuisance.
All persons shall take reasonable precautions to prevent the discharge of visible emissions of
fugitive dusts beyond the lot line of the property on which the emissions originate.
Authority for Requirement: 567 IAC 23.3(2)"c"
Pollutant: Hazardous Air Pollutants (HAP)
Emission Limit: See Facility-Wide Conditions
Periodic Monitoring Requirements
The owner operator of each piece of equipment identified in Table METAL shall comply with the
following periodic monitoring requirements.
Agency Approved Operation & Maintenance Plan Required? Yes ~ No |EI
Facility Maintained Operation & Maintenance Plan Required? Yes ~ No |EI
Authority for Requirement: 567 IAC 22.108(3)"b"
Vermeer Manufacturing Co.
38
99-TV-052-M001
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Emission Point ID Number: 7.R
Associated Equipment
Associated Emission Unit ID Number: .
7.R
Applicable Requirements
Emission Unit vented through this Emission Point: 7.R
Emission Unit Description: One (1) Safety Kleen Partswasher
Raw Material/Fuel: Stoddard Solvent
Rated Capacity: 55 Gallons Solvent
Emission Limits (lb/hr, gr/dscf, lb/MMBtu, % opacity, etc.)
The emissions from this emission point shall not exceed the following specified levels.
Pollutant: Volatile Organic Compounds (VOC)
Emission Limit: See Facility-Wide Conditions
Authority for Requirement: Iowa DNR Construction Permit 98-A-869-S1
Operational Limits & Requirements
The owner/operator of this equipment shall comply with the following operational limits and
requirements.
Reporting & Record keeping: See Facility-Wide Conditions and include:
A. The amount of any solvent used in this unit, in gallons. Calculate and record monthly
and twelve (12) month rolling totals
B. The VOC content of any solvent used in this partswasher, in pounds per gallon.
Authority for Requirement: Iowa DNR Construction Permit 98-A-869-S1
Emission Point Characteristics
This emission point shall conform to the following conditions.
Stack Height (feet, from the ground): 25
Stack Diameter (inches): 12
Stack Exhaust Flow Rate (scfm): 1,000
Stack Temperature (°F): Ambient
Vertical, Unobstructed Discharge Required: Yes ~ No
Authority for Requirement: Iowa DNR Construction Permit 98-A-869-S1
E
Vermeer Manufacturing Co.
39
99-TV-052-M001
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Periodic Monitoring Requirements
The owner/operator of this equipment shall comply with the following periodic monitoring
requirements.
Agency Approved Operation & Maintenance Plan Required? Yes ~ No |EI
Facility Maintained Operation & Maintenance Plan Required? Yes ~ No |EI
Authority for Requirement: 567 IAC 22.108(3)"b"
Vermeer Manufacturing Co.
40
99-TV-052-M001
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Emission Point ID Number: P.O
Associated Equipment
Associated Emission Unit ID Number: ..
P. 01, P.02
Applicable Requirements
Emission Unit vented through this Emission Point: P.01
Emission Unit Description: One (1) Safety Kleen Parts Washer
Raw Material/Fuel: MAK Solvent
Rated Capacity: 10 Gallons Solvent
Emission Unit vented through this Emission Point: P.02
Emission Unit Description: One (1) Safety Kleen Parts Washer
Raw Material/Fuel: MAK Solvent
Rated Capacity: 20 Gallons Solvent
Emission Limits (lb/hr, gr/dscf, lb/MMBtu, % opacity, etc.)
The emissions from this emission point shall not exceed the following specified levels.
Pollutant: Volatile Organic Compounds (VOC)
Emission Limit: See Facility-Wide Conditions
Authority for Requirement: Iowa DNR Construction Permit 99-A-685
Emission Point Characteristics
This emission point shall conform to the following conditions.
Stack Height (feet, from the ground): 25.3
Stack Diameter (inches): 12
Stack Exhaust Flow Rate (scfm): 1,100
Stack Temperature (°F): Ambient
Vertical, Unobstructed Discharge Required: Yes ^ No ~
Authority for Requirement: Iowa DNR Construction Permit 99-A-685
Periodic Monitoring Requirements
The owner/operator of this equipment shall comply with the following periodic monitoring
requirements.
Agency Approved Operation & Maintenance Plan Required? Yes ~ No |EI
Facility Maintained Operation & Maintenance Plan Required? Yes ~ No |EI
Authority for Requirement: 567 IAC 22.108(3)"b"
Vermeer Manufacturing Co.
41
99-TV-052-M001
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Emission Point ID Number: See Table PARTSWASH
Associated Equipment
Associated Emission Unit ID Number: See Table PARTSWASH
Applicable Requirements
(Hie following requirements apply to the emission units identified in Table PARTSWASH)
Emission Unit vented through this Emission Point: See Table PARTSWASH
Emission Unit Description: Safety Kleen Parts Washers
Raw Material/Fuel: Stoddard Solvent
Rated Capacity: 55 gallons solvent per washer
Table PARTSWASH
Emission Point
Number
Associated Emission
Unit Number
Number of Parts
Washers
Building Number
l.PRTWSH
l.PRTWSH
5
1
2.PRTWSH
2.PRTWSH
4
2
3.PRTWSH
3.PRTWSH
3
3
4.PRTWSH
4.PRTWSH
7
4
5.PRTWSH
5.PRTWSH
2
5
6.PRTWSH
6.PRTWSH
2
6
7.PRTWSH
7.PRTWSH
3
7
P.PRTWSH
P.PRTWSH
4
Parts
W.M
W.M
1
Waste
Emission Limits (lb/hr, gr/dscf, lb/MMBtu, % opacity, etc.)
The emissions from each emission point identified in Table PARTSWASH shall not exceed the
following specified levels.
Pollutant: Volatile Organic Compounds (VOC)
Emission Limit: See Facility-Wide Conditions
Periodic Monitoring Requirements
The owner operator of each piece of equipment identified in Table PARTSWASH shall comply
with the following periodic monitoring requirements.
Agency Approved Operation & Maintenance Plan Required? Yes ~ No |EI
Facility Maintained Operation & Maintenance Plan Required? Yes ~ No |EI
Authority for Requirement: 567 IAC 22.108(3)"b"
Vermeer Manufacturing Co. 42 99-TV-052-M001
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Emission Point ID Number: 4.DD
Associated Equipment
Associated Emission Unit ID Number: ....
4.DD
Applicable Requirements
Emission Unit vented through this Emission Point: 4.DD
Emission Unit Description: Stage 1 Washer
Raw Material/Fuel: Reagent
Rated Capacity: 300 gal/hr
Emission Limits (lb/hr, gr/dscf, lb/MMBtu, % opacity, etc.)
The emissions from this emission point shall not exceed the following specified levels.
Pollutant: Opacity
Emission Limit: 40 %
Indicator Opacity: 25 %(1)
(1)Per DNR Air Quality Policy 3-b-08, Opacity Limits, an exceedence of the indicator opacity of
25% will require the owner/operator to promptly investigate the emission unit and make
corrections to operations or equipment associated with the exceedence. The permit holder shall
also file an "indicator opacity exceedence report" with the DNR field office and keep records as
required in the policy. If exceedences continue after the corrections, the DNR may require
additional proof to demonstrate compliance (e.g., stack testing).
Authority for Requirement: 567 IAC 23.3(2)"d"
Iowa DNR Construction Permit 99-A-1014
Pollutant: PMi0
Emission Limit: 3.29 lb/hr
Authority for Requirement: Iowa DNR Construction Permit 99-A-1014
Pollutant: Particulate Matter
Emission Limit: 0.1 gr/dscf
Authority for Requirement: 567 IAC 23.3(2)"a"
Iowa DNR Construction Permit 99-A-1014
Vermeer Manufacturing Co.
43
99-TV-052-M001
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Emission Point Characteristics
This emission point shall conform to the following conditions.
Stack Height (feet, from the ground): 35
Stack Opening (inches, diameter): 36
Exhaust Flow Rate (scfm): 5,000
Exhaust Temperature (°F): 100
Vertical, Unobstructed Discharge Required: Yes ~ No El
Authority for Requirement: Iowa DNR Construction Permit 99-A-1014
Periodic Monitoring Requirements
The owner/operator of this equipment shall comply with the following periodic monitoring
requirements.
Agency Approved Operation & Maintenance Plan Required? Yes ~ No |EI
Facility Maintained Operation & Maintenance Plan Required? Yes ~ No |EI
Authority for Requirement: 567 IAC 22.108(3)"b"
Vermeer Manufacturing Co.
44
99-TV-052-M001
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Emission Point ID Number: 4.EE
Associated Equipment
Associated Emission Unit ID Number: ....
4.EE
Applicable Requirements
Emission Unit vented through this Emission Point: 4.EE
Emission Unit Description: Stage 3 Burner
Raw Material/Fuel: Natural Gas
Rated Capacity: 2.5 MMBtu/hr
Emission Limits (lb/hr, gr/dscf, lb/MMBtu, % opacity, etc.)
The emissions from this emission point shall not exceed the following specified levels.
Pollutant: Opacity
Emission Limit: 40 %
Authority for Requirement: 567 IAC 23.3(2)"d"
Pollutant: Particulate Matter
Emission Limit: 15.3 lb/MMCF of Propane or Natural Gas
Authority for Requirement: Part 7a. of State of Iowa, ex rel., Iowa DNR vs. Vermeer
Manufacturing Company, 99AG23542
District Court, Marion County, Law No. LACV087889
Pollutant: Particulate Matter
Emission Limit: 0.8 lb/MMBtu
Authority for Requirement: 567 IAC 23.3(2)"b"
Pollutant: Sulfur Dioxide (SO2)
Emission Limit: 500 ppmv
Authority for Requirement: 567 IAC 23.3(3)"e"
Pollutant: Nitrogen Oxides (NOx)
Emission Limit: See Facility-Wide Conditions
Pollutant: Volatile Organic Compounds (VOC)
Emission Limit: See Facility-Wide Conditions
Pollutant: Hazardous Air Pollutants (HAP)
Emission Limit: See Facility-Wide Conditions
Vermeer Manufacturing Co.
45
99-TV-052-M001
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Operational Limits & Requirements
The owner/operator of this equipment shall comply with the following operational limits and
requirements.
Process throughput:
The sulfur content of natural gas or LPG combusted by this source is not to exceed 123 ppm
by weight.
Reporting & Recordkeeping: See Facility-Wide Operational Limits
Authority for Requirement: Part 7b. of State of Iowa, ex rel., Iowa DNR vs. Vermeer
Manufacturing Company, 99AG23542
District Court, Marion County, Law No. LACV087889
Periodic Monitoring Requirements
The owner/operator of this equipment shall comply with the following periodic monitoring
requirements.
Agency Approved Operation & Maintenance Plan Required? Yes ~ No |EI
Facility Maintained Operation & Maintenance Plan Required? Yes ~ No |EI
Authority for Requirement: 567 IAC 22.108(3)"b"
Vermeer Manufacturing Co.
46
99-TV-052-M001
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Emission Point ID Number: 4.FF
Associated Equipment
Associated Emission Unit ID Number: ...
4.FF
Applicable Requirements
Emission Unit vented through this Emission Point: 4.FF
Emission Unit Description: Stage 1 Burner
Raw Material/Fuel: Natural Gas
Rated Capacity: 3.8MMBtu/hr
Emission Limits (lb/hr, gr/dscf, lb/MMBtu, % opacity, etc.)
The emissions from this emission point shall not exceed the following specified levels.
Pollutant: Opacity
Emission Limit: 40 %
Authority for Requirement: 567 IAC 23.3(2)"d"
Pollutant: Particulate Matter
Emission Limit: 15.3 lb/MMCF of Propane or Natural Gas
Authority for Requirement: Part 7a. of State of Iowa, ex rel., Iowa DNR vs. Vermeer
Manufacturing Company, 99AG23542
District Court, Marion County, Law No. LACV087889
Pollutant: Particulate Matter
Emission Limit: 0.8 lb/MMBtu
Authority for Requirement: 567 IAC 23.3(2)"b"
Pollutant: Sulfur Dioxide (SO2)
Emission Limit: 500 ppmv
Authority for Requirement: 567 IAC 23.3(3)"e"
Pollutant: Nitrogen Oxides (NOx)
Emission Limit: See Facility-Wide Conditions
Pollutant: Volatile Organic Compounds (VOC)
Emission Limit: See Facility-Wide Conditions
Pollutant: Hazardous Air Pollutants (HAP)
Emission Limit: See Facility-Wide Conditions
Vermeer Manufacturing Co.
47
99-TV-052-M001
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Operational Limits & Requirements
The owner/operator of this equipment shall comply with the following operational limits and
requirements.
Process throughput:
The sulfur content of natural gas or LPG combusted by this source is not to exceed 123 ppm
by weight.
Reporting & Recordkeeping: See Facility-Wide Operational Limits
Authority for Requirement: Part 7b. of State of Iowa, ex rel., Iowa DNR vs. Vermeer
Manufacturing Company, 99AG23542
District Court, Marion County, Law No. LACV087889
Periodic Monitoring Requirements
The owner/operator of this equipment shall comply with the following periodic monitoring
requirements.
Agency Approved Operation & Maintenance Plan Required? Yes ~ No |EI
Facility Maintained Operation & Maintenance Plan Required? Yes ~ No |EI
Authority for Requirement: 567 IAC 22.108(3)"b"
Vermeer Manufacturing Co.
48
99-TV-052-M001
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Emission Point ID Number: 4.GG
Associated Equipment
Associated Emission Unit ID Number: 4.GG
Applicable Requirements
Emission Unit vented through this Emission Point: 4.GG
Emission Unit Description: Stage 5 Washer
Raw Material/Fuel: Reagent
Rated Capacity: 300 gal/hr
Emission Limits (lb/hr, gr/dscf, lb/MMBtu, % opacity, etc.)
The emissions from this emission point shall not exceed the following specified levels.
Pollutant: Opacity
Emission Limit: 40 %
Authority for Requirement: 567 IAC 23.3(2)"d"
Pollutant: Particulate Matter
Emission Limit: 0.1 gr/dscf
Authority for Requirement: 567 IAC 23.3(2)"a"
Periodic Monitoring Requirements
The owner/operator of this equipment shall comply with the following periodic monitoring
requirements.
Agency Approved Operation & Maintenance Plan Required? Yes ~ No |EI
Facility Maintained Operation & Maintenance Plan Required? Yes ~ No |EI
Authority for Requirement: 567 IAC 22.108(3)"b"
Vermeer Manufacturing Co.
49
99-TV-052-M001
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Emission Point ID Number: 5.KK3
Associated Equipment
Associated Emission Unit ID Number:
5.KK3
Applicable Requirements
Emission Unit vented through this Emission Point: 5.KK3
Emission Unit Description: Stage 1 Washer
Raw Material/Fuel: Reagent
Rated Capacity: 300 gal/hr
Emission Limits (lb/hr, gr/dscf, lb/MMBtu, % opacity, etc.)
The emissions from this emission point shall not exceed the following specified levels.
Pollutant: Opacity
Emission Limit: 40 %
Indicator Opacity: 25 %(1)
(1)Per DNR Air Quality Policy 3-b-08, Opacity Limits, an exceedence of the indicator opacity of
25% will require the owner/operator to promptly investigate the emission unit and make
corrections to operations or equipment associated with the exceedence. The permit holder shall
also file an "indicator opacity exceedence report" with the DNR field office and keep records as
required in the policy. If exceedences continue after the corrections, the DNR may require
additional proof to demonstrate compliance (e.g., stack testing).
Authority for Requirement: 567 IAC 23.3(2)"d"
Iowa DNR Construction Permit 00-A-730
Pollutant: PMi0
Emission Limit: 1.0 lb/hr
Authority for Requirement: Iowa DNR Construction Permit 00-A-730
Pollutant: Particulate Matter
Emission Limit: 0.1 gr/dscf
Authority for Requirement: 567 IAC 23.3(2)"a"
Iowa DNR Construction Permit 00-A-730
Vermeer Manufacturing Co.
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Operational Limits & Requirements
The owner/operator of this equipment shall comply with the following operational limits and
requirements.
Supplemental Environmental Project (SEP):
Equipment parameters:
This SEP shall consist of a power and free conveyor system, controlled atmosphere room
with air handling unit, spray booth powder reclaim unit, and batch oven with cool down
tunnel and include a newly constructed room of approximately 36 feet by 32 feet in
dimension for the purpose of providing a clean room type atmosphere for powder painting,
installed with a power and free conveyor system which will transport small and/or medium
parts from an iron phosphate multi-stage or manual wash bay cleaning system to the powder
paint booth, located in the clean room using a separate air handling unit to maintain
humidity, temperature and a clean environment. Vermeer will install at least one primer
finish booth.
Authority for Requirement: Paragraph 3f. of State of Iowa, ex rel., Iowa DNR vs. Vermeer
Manufacturing Company, 99AG23542
District Court, Marion County, Law No. LACV087889
Operational term:
This SEP will be maintained for one year following commencement of the operation of the
SEP, unless the DNR and Vermeer agree in writing some other period is appropriate in the
circumstances.
Authority for Requirement: Paragraph 3i. of State of Iowa, ex rel., Iowa DNR vs. Vermeer
Manufacturing Company, 99AG23542
District Court, Marion County, Law No. LACV087889
Reporting & Record keeping:
Vermeer shall submit to the DNR an annual performance report covering the required period
of use and maintenance of this SEP documenting the actual use and maintenance of this SEP.
The reports shall be submitted on or before March 1, for the preceding calendar year,
commencing on March 1, 2001.
Authority for Requirement: Paragraph 3j. of State of Iowa, ex rel., Iowa DNR vs. Vermeer
Manufacturing Company, 99AG23542
District Court, Marion County, Law No. LACV087889
Emission Point Characteristics
This emission point shall conform to the following conditions.
Stack Height (feet, from the ground): 35
Stack Opening (inches, diameter): 16
Exhaust Flow Rate (scfm): 5,000
Exhaust Temperature (°F): 100
Vertical, Unobstructed Discharge Required: Yes ~ No El
Authority for Requirement: Iowa DNR Construction Permit 00-A-730
Vermeer Manufacturing Co.
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Periodic Monitoring Requirements
The owner/operator of this equipment shall comply with the following periodic monitoring
requirements.
Agency Approved Operation & Maintenance Plan Required? Yes ~ No |EI
Facility Maintained Operation & Maintenance Plan Required? Yes ~ No |EI
Authority for Requirement: 567 IAC 22.108(3)"b"
Vermeer Manufacturing Co.
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Emission Point ID Number: 5.KK4
Associated Equipment
Associated Emission Unit ID Number:
5.KK4
Applicable Requirements
Emission Unit vented through this Emission Point: 5.KK4
Emission Unit Description: Multi-Stage Washer
Raw Material/Fuel: Reagent
Rated Capacity: 300 gal/hr
Emission Limits (lb/hr, gr/dscf, lb/MMBtu, % opacity, etc.)
The emissions from this emission point shall not exceed the following specified levels.
Pollutant: Opacity
Emission Limit: 40 %
Authority for Requirement: 567 IAC 23.3(2)"d"
Pollutant: Particulate Matter
Emission Limit: 0.1 gr/dscf
Authority for Requirement: 567 IAC 23.3(2)"a"
Operational Limits & Requirements
The owner/operator of this equipment shall comply with the following operational limits and
requirements.
Supplemental Environmental Project (SEP):
Equipment parameters:
This SEP shall consist of a power and free conveyor system, controlled atmosphere room
with air handling unit, spray booth powder reclaim unit, and batch oven with cool down
tunnel and include a newly constructed room of approximately 36 feet by 32 feet in
dimension for the purpose of providing a clean room type atmosphere for powder painting,
installed with a power and free conveyor system which will transport small and/or medium
parts from an iron phosphate multi-stage or manual wash bay cleaning system to the powder
paint booth, located in the clean room using a separate air handling unit to maintain
humidity, temperature and a clean environment. Vermeer will install at least one primer
finish booth.
Authority for Requirement: Paragraph 3f. of State of Iowa, ex rel., Iowa DNR vs. Vermeer
Manufacturing Company, 99AG23542
District Court, Marion County, Law No. LACV087889
Vermeer Manufacturing Co.
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99-TV-052-M001
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Operational term:
This SEP will be maintained for one year following commencement of the operation of the
SEP, unless the DNR and Vermeer agree in writing some other period is appropriate in the
circumstances.
Authority for Requirement: Paragraph 3i. of State of Iowa, ex rel., Iowa DNR vs. Vermeer
Manufacturing Company, 99AG23542
District Court, Marion County, Law No. LACV087889
Reporting & Record keeping:
Vermeer shall submit to the DNR an annual performance report covering the required period
of use and maintenance of this SEP documenting the actual use and maintenance of this SEP.
The reports shall be submitted on or before March 1, for the preceding calendar year,
commencing on March 1, 2001.
Authority for Requirement: Paragraph 3j. of State of Iowa, ex rel., Iowa DNR vs. Vermeer
Manufacturing Company, 99AG23542
District Court, Marion County, Law No. LACV087889
Periodic Monitoring Requirements
The owner/operator of this equipment shall comply with the following periodic monitoring
requirements.
Agency Approved Operation & Maintenance Plan Required? Yes ~ No |EI
Facility Maintained Operation & Maintenance Plan Required? Yes ~ No |EI
Authority for Requirement: 567 IAC 22.108(3)"b"
Vermeer Manufacturing Co.
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Emission Point ID Number: 5.KK5
Associated Equipment
Associated Emission Unit ID Number:
5.KK5
Applicable Requirements
Emission Unit vented through this Emission Point: 5.KK5
Emission Unit Description: Stage 1 Burner
Raw Material/Fuel: Natural Gas
Rated Capacity: 800,000 Btu/hr
Emission Limits (lb/hr, gr/dscf, lb/MMBtu, % opacity, etc.)
The emissions from this emission point shall not exceed the following specified levels.
Pollutant: Opacity
Emission Limit: 40 %
Authority for Requirement: 567 IAC 23.3(2)"d"
Pollutant: Particulate Matter
Emission Limit: 15.3 lb/MMCF of Propane or Natural Gas
Authority for Requirement: Part 7a. of State of Iowa, ex rel., Iowa DNR vs. Vermeer
Manufacturing Company, 99AG23542
District Court, Marion County, Law No. LACV087889
Pollutant: Particulate Matter
Emission Limit: 0.8 lb/MMBtu
Authority for Requirement: 567 IAC 23.3(2)"b"
Pollutant: Sulfur Dioxide (SO2)
Emission Limit: 500 ppmv
Authority for Requirement: 567 IAC 23.3(3)"e"
Pollutant: Nitrogen Oxides (NOx)
Emission Limit: See Facility-Wide Conditions
Pollutant: Volatile Organic Compounds (VOC)
Emission Limit: See Facility-Wide Conditions
Pollutant: Hazardous Air Pollutants (HAP)
Emission Limit: See Facility-Wide Conditions
Vermeer Manufacturing Co.
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Operational Limits & Requirements
The owner/operator of this equipment shall comply with the following operational limits and
requirements.
Supplemental Environmental Project (SEP):
This burner is associated with the SEP described in Paragraph 3f. of State of Iowa, ex rel.,
IowaDNRvs. Vermeer Manufacturing Company, 99AG23542
District Court, Marion County, Law No. LACV087889
Process throughput:
The sulfur content of natural gas or LPG combusted by this source is not to exceed 123 ppm
by weight.
Reporting & Recordkeeping: See Facility-Wide Operational Limits
Authority for Requirement: Part 7b. of State of Iowa, ex rel., Iowa DNR vs. Vermeer
Manufacturing Company, 99AG23542
District Court, Marion County, Law No. LACV087889
Periodic Monitoring Requirements
The owner/operator of this equipment shall comply with the following periodic monitoring
requirements.
Agency Approved Operation & Maintenance Plan Required? Yes ~ No |EI
Facility Maintained Operation & Maintenance Plan Required? Yes ~ No |EI
Authority for Requirement: 567 IAC 22.108(3)"b"
Vermeer Manufacturing Co.
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Emission Point ID Number: 5.KK6
Associated Equipment
Associated Emission Unit ID Number:
5.KK6
Applicable Requirements
Emission Unit vented through this Emission Point: 5.KK6
Emission Unit Description: Stage 3 Burner
Raw Material/Fuel: Natural Gas
Rated Capacity: 400,000 Btu/hr
Emission Limits (lb/hr, gr/dscf, lb/MMBtu, % opacity, etc.)
The emissions from this emission point shall not exceed the following specified levels.
Pollutant: Opacity
Emission Limit: 40 %
Authority for Requirement: 567 IAC 23.3(2)"d"
Pollutant: Particulate Matter
Emission Limit: 15.3 lb/MMCF of Propane or Natural Gas
Authority for Requirement: Part 7a. of State of Iowa, ex rel., Iowa DNR vs. Vermeer
Manufacturing Company, 99AG23542
District Court, Marion County, Law No. LACV087889
Pollutant: Particulate Matter
Emission Limit: 0.8 lb/MMBtu
Authority for Requirement: 567 IAC 23.3(2)"b"
Pollutant: Sulfur Dioxide (SO2)
Emission Limit: 500 ppmv
Authority for Requirement: 567 IAC 23.3(3)"e"
Pollutant: Nitrogen Oxides (NOx)
Emission Limit: See Facility-Wide Conditions
Pollutant: Volatile Organic Compounds (VOC)
Emission Limit: See Facility-Wide Conditions
Pollutant: Hazardous Air Pollutants (HAP)
Emission Limit: See Facility-Wide Conditions
Vermeer Manufacturing Co.
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99-TV-052-M001
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Operational Limits & Requirements
The owner/operator of this equipment shall comply with the following operational limits and
requirements.
Supplemental Environmental Project (SEP):
This burner is associated with the SEP described in Paragraph 3f. of State of Iowa, ex rel.,
IowaDNRvs. Vermeer Manufacturing Company, 99AG23542
District Court, Marion County, Law No. LACV087889
Process throughput:
The sulfur content of natural gas or LPG combusted by this source is not to exceed 123 ppm
by weight.
Reporting & Recordkeeping: See Facility-Wide Operational Limits
Authority for Requirement: Part 7b. of State of Iowa, ex rel., Iowa DNR vs. Vermeer
Manufacturing Company, 99AG23542
District Court, Marion County, Law No. LACV087889
Periodic Monitoring Requirements
The owner/operator of this equipment shall comply with the following periodic monitoring
requirements.
Agency Approved Operation & Maintenance Plan Required? Yes ~ No |EI
Facility Maintained Operation & Maintenance Plan Required? Yes ~ No |EI
Authority for Requirement: 567 IAC 22.108(3)"b"
Vermeer Manufacturing Co.
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Emission Point ID Number: 5.KK7
Associated Equipment
Associated Emission Unit ID Number:
5.KK7
Applicable Requirements
Emission Unit vented through this Emission Point: 5.KK7
Emission Unit Description: Dry-off Oven
Raw Material/Fuel: Natural Gas
Rated Capacity: 2.0 MMBtu/hr
Emission Limits (lb/hr, gr/dscf, lb/MMBtu, % opacity, etc.)
The emissions from this emission point shall not exceed the following specified levels.
Pollutant: Opacity
Emission Limit: 40 %
Indicator Opacity: 25 %(1)
(1)Per DNR Air Quality Policy 3-b-08, Opacity Limits, an exceedence of the indicator opacity of
25% will require the owner/operator to promptly investigate the emission unit and make
corrections to operations or equipment associated with the exceedence. The permit holder shall
also file an "indicator opacity exceedence report" with the DNR field office and keep records as
required in the policy. If exceedences continue after the corrections, the DNR may require
additional proof to demonstrate compliance (e.g., stack testing).
Authority for Requirement: 567 IAC 23.3(2)"d"
Iowa DNR Construction Permit 00-A-731
Pollutant: Particulate Matter
Emission Limit: 0.1 gr/dscf
Authority for Requirement: 567 IAC 23.3(2)"a"
Iowa DNR Construction Permit 00-A-731
Pollutant: Sulfur Dioxide (SO2)
Emission Limit: 500 ppmv
Authority for Requirement: 567 IAC 23.3(3)"e"
Pollutant: Sulfur Dioxide (SO2)
Emission Limit: 2.5 lb/MMBtu
Authority for Requirement: Iowa DNR Construction Permit 00-A-731
Pollutant: Nitrogen Oxides (NOx)
Emission Limit: See Facility-Wide Conditions
Authority for Requirement: Iowa DNR Construction Permit 00-A-731
Vermeer Manufacturing Co.
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Pollutant: Volatile Organic Compounds (VOC)
Emission Limit: See Facility-Wide Conditions
Authority for Requirement: Iowa DNR Construction Permit 00-A-731
Pollutant: Hazardous Air Pollutants (HAP)
Emission Limit: See Facility-Wide Conditions
Operational Limits & Requirements
The owner/operator of this equipment shall comply with the following operational limits and
requirements.
Supplemental Environmental Project (SEP):
Equipment parameters:
This SEP shall consist of a power and free conveyor system, controlled atmosphere room
with air handling unit, spray booth powder reclaim unit, and batch oven with cool down
tunnel and include a newly constructed room of approximately 36 feet by 32 feet in
dimension for the purpose of providing a clean room type atmosphere for powder painting,
installed with a power and free conveyor system which will transport small and/or medium
parts from an iron phosphate multi-stage or manual wash bay cleaning system to the powder
paint booth, located in the clean room using a separate air handling unit to maintain
humidity, temperature and a clean environment. Vermeer will install at least one primer
finish booth.
Authority for Requirement: Paragraph 3f. of State of Iowa, ex rel., Iowa DNR vs. Vermeer
Manufacturing Company, 99AG23542
District Court, Marion County, Law No. LACV087889
Operational term:
This SEP will be maintained for one year following commencement of the operation of the
SEP, unless the DNR and Vermeer agree in writing some other period is appropriate in the
circumstances.
Authority for Requirement: Paragraph 3i. of State of Iowa, ex rel., Iowa DNR vs. Vermeer
Manufacturing Company, 99AG23542
District Court, Marion County, Law No. LACV087889
Reporting & Record keeping:
Vermeer shall submit to the DNR an annual performance report covering the required period
of use and maintenance of this SEP documenting the actual use and maintenance of this SEP.
The reports shall be submitted on or before March 1, for the preceding calendar year,
commencing on March 1, 2001.
Authority for Requirement: Paragraph 3j. of State of Iowa, ex rel., Iowa DNR vs. Vermeer
Manufacturing Company, 99AG23542
District Court, Marion County, Law No. LACV087889
Process throughput:
This oven shall be fired by natural gas or propane only.
Authority for Requirement: Iowa DNR Construction Permit 00-A-731
Vermeer Manufacturing Co.
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Emission Point Characteristics
This emission point shall conform to the following conditions.
Stack Height (feet, from the ground): 34
Stack Opening (inches, diameter): 12
Exhaust Flow Rate (scfm): 1,500
Exhaust Temperature (°F): 400
Vertical, Unobstructed Discharge Required: Yes ^ No ~
Authority for Requirement: Iowa DNR Construction Permit 00-A-731
Periodic Monitoring Requirements
The owner/operator of this equipment shall comply with the following periodic monitoring
requirements.
Agency Approved Operation & Maintenance Plan Required? Yes ~ No |EI
Facility Maintained Operation & Maintenance Plan Required? Yes ~ No |EI
Authority for Requirement: 567 IAC 22.108(3)"b"
Vermeer Manufacturing Co.
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Emission Point ID Number: 5.KK8
Associated Equipment
Associated Emission Unit ID Number:
5.KK8
Applicable Requirements
Emission Unit vented through this Emission Point: 5.KK8
Emission Unit Description: Cure Oven
Raw Material/Fuel: Natural Gas
Rated Capacity: 2.0 MMBtu/hr
Emission Limits (lb/hr, gr/dscf, lb/MMBtu, % opacity, etc.)
The emissions from this emission point shall not exceed the following specified levels.
Pollutant: Opacity
Emission Limit: 40 %
Indicator Opacity: 25 %(1)
(1)Per DNR Air Quality Policy 3-b-08, Opacity Limits, an exceedence of the indicator opacity of
25% will require the owner/operator to promptly investigate the emission unit and make
corrections to operations or equipment associated with the exceedence. The permit holder shall
also file an "indicator opacity exceedence report" with the DNR field office and keep records as
required in the policy. If exceedences continue after the corrections, the DNR may require
additional proof to demonstrate compliance (e.g., stack testing).
Authority for Requirement: 567 IAC 23.3(2)"d"
Iowa DNR Construction Permit 00-A-732
Pollutant: Particulate Matter
Emission Limit: 0.1 gr/dscf
Authority for Requirement: 567 IAC 23.3(2)"a"
Iowa DNR Construction Permit 00-A-732
Pollutant: Sulfur Dioxide (SO2)
Emission Limit: 500 ppmv
Authority for Requirement: 567 IAC 23.3(3)"e"
Pollutant: Sulfur Dioxide (SO2)
Emission Limit: 2.5 lb/MMBtu
Authority for Requirement: Iowa DNR Construction Permit 00-A-731
Pollutant: Nitrogen Oxides (NOx)
Emission Limit: See Facility-Wide Conditions
Authority for Requirement: Iowa DNR Construction Permit 00-A-732
Vermeer Manufacturing Co.
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Pollutant: Volatile Organic Compounds (VOC)
Emission Limit: See Facility-Wide Conditions
Authority for Requirement: Iowa DNR Construction Permit 00-A-732
Pollutant: Hazardous Air Pollutants (HAP)
Emission Limit: See Facility-Wide Conditions
Operational Limits & Requirements
The owner/operator of this equipment shall comply with the operational limits and requirements
listed below.
Supplemental Environmental Project (SEP):
Equipment parameters:
This SEP shall consist of a power and free conveyor system, controlled atmosphere room
with air handling unit, spray booth powder reclaim unit, and batch oven with cool down
tunnel and include a newly constructed room of approximately 36 feet by 32 feet in
dimension for the purpose of providing a clean room type atmosphere for powder painting,
installed with a power and free conveyor system which will transport small and/or medium
parts from an iron phosphate multi-stage or manual wash bay cleaning system to the powder
paint booth, located in the clean room using a separate air handling unit to maintain
humidity, temperature and a clean environment. Vermeer will install at least one primer
finish booth.
Authority for Requirement: Paragraph 3f. of State of Iowa, ex rel., Iowa DNR vs. Vermeer
Manufacturing Company, 99AG23542
District Court, Marion County, Law No. LACV087889
Operational term:
This SEP will be maintained for one year following commencement of the operation of the
SEP, unless the DNR and Vermeer agree in writing some other period is appropriate in the
circumstances.
Authority for Requirement: Paragraph 3i. of State of Iowa, ex rel., Iowa DNR vs. Vermeer
Manufacturing Company, 99AG23542
District Court, Marion County, Law No. LACV087889
Reporting & Record keeping:
Vermeer shall submit to the DNR an annual performance report covering the required period
of use and maintenance of this SEP documenting the actual use and maintenance of this SEP.
The reports shall be submitted on or before March 1, for the preceding calendar year,
commencing on March 1, 2001.
Authority for Requirement: Paragraph 3j. of State of Iowa, ex rel., Iowa DNR vs. Vermeer
Manufacturing Company, 99AG23542
District Court, Marion County, Law No. LACV087889
Process throughput:
This oven shall be fired by natural gas or propane only.
Authority for Requirement: Iowa DNR Construction Permit 00-A-732
Vermeer Manufacturing Co.
63
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Emission Point Characteristics
This emission point shall conform to the following conditions.
Stack Height (feet, from the ground): 34
Stack Opening (inches, diameter): 12
Exhaust Flow Rate (scfm): 1,500
Exhaust Temperature (°F): 400
Vertical, Unobstructed Discharge Required: Yes ^ No ~
Authority for Requirement: Iowa DNR Construction Permit 00-A-732
Periodic Monitoring Requirements
The owner/operator of this equipment shall comply with the following periodic monitoring
requirements.
Agency Approved Operation & Maintenance Plan Required? Yes ~ No |EI
Facility Maintained Operation & Maintenance Plan Required? Yes ~ No |EI
Authority for Requirement: 567 IAC 22.108(3)"b"
Vermeer Manufacturing Co.
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Emission Point ID Number: 6.QQ
Associated Equipment
Associated Emission Unit ID Number: 6.QQ
Applicable Requirements
Emission Unit vented through this Emission Point: 6.QQ
Emission Unit Description: Stage 1 Washer
Raw Material/Fuel: Hot Alkaline Cleaner
Rated Capacity: 300 gal/hr
Emission Limits (lb/hr, gr/dscf, lb/MMBtu, % opacity, etc.)
The emissions from this emission point shall not exceed the following specified levels.
Pollutant: Opacity
Emission Limit: 40 %
Indicator Opacity: (1)
(1) If visible emissions are observed other than startup, shutdown or malfunction, a stack test may
be required to demonstrate compliance with the particulate standard.
Authority for Requirement: 567 IAC 23.3(2)"d"
Iowa DNR Construction Permit 98-A-868-S1
Pollutant: Particulate Matter
Emission Limit: 0.1 gr/dscf
Authority for Requirement: 567 IAC 23.3(2)"a"
Iowa DNR Construction Permit 98-A-868-S1
Operational Limits & Requirements
The owner/operator of this equipment shall comply with the following operational limits and
requirements.
Supplemental Environmental Project (SEP):
Equipment parameters:
As part of a multi-stage washer system the emission unit associated with this emission point
will consist of a heated alkaline cleaner solution utilizing a sequenced manifold of spray
nozzle tips to clean the metal parts in preparation for polyurethane coating. An extended
drain zone will be provided to prevent chemical drag out to the second stage, a clean water
rinse. A power and free conveyer system will be utilized to supply parts to and from the
washer system. The entire washer system shall be approximately 150 feet long, 8 to 10 feet
wide, and constructed of mild and stainless steel.
Authority for Requirement: Paragraph 3d. of State of Iowa, ex rel., Iowa DNR vs. Vermeer
Manufacturing Company, 99AG23542
District Court, Marion County, Law No. LACV087889
Vermeer Manufacturing Co.
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Operational term: This SEP will be maintained for the life of this permit.
Authority for Requirement: Paragraph 3i. of State of Iowa, ex rel., Iowa DNR vs. Vermeer
Manufacturing Company, 99AG23542
District Court, Marion County, Law No. LACV087889
Reporting & Record keeping:
Vermeer shall submit to the DNR an annual performance report covering the required period
of use and maintenance of this SEP documenting the actual use and maintenance of this SEP.
The reports shall be submitted on or before March 1, for the preceding calendar year,
commencing on March 1, 1999.
Authority for Requirement: Paragraph 3j. of State of Iowa, ex rel., Iowa DNR vs. Vermeer
Manufacturing Company, 99AG23542
District Court, Marion County, Law No. LACV087889
Emission Point Characteristics
This emission point shall conform to the following conditions.
Stack Height (feet, from the ground): 36
Stack Diameter (inches): 12.0
Stack Exhaust Flow Rate (scfm): 6,000
Stack Temperature (°F): Ambient
Vertical, Unobstructed Discharge Required: Yes ^ No ~
Authority for Requirement: Iowa DNR Construction Permit 98-A-868-S1
Periodic Monitoring Requirements
The owner/operator of this equipment shall comply with the following periodic monitoring
requirements.
Agency Approved Operation & Maintenance Plan Required? Yes ~ No |EI
Facility Maintained Operation & Maintenance Plan Required? Yes ~ No |EI
Authority for Requirement: 567 IAC 22.108(3)"b"
Vermeer Manufacturing Co.
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Emission Point ID Number: 6.RR
Associated Equipment
Associated Emission Unit ID Number: ....
6.RR
Applicable Requirements
Emission Unit vented through this Emission Point: 6.RR
Emission Unit Description: Stage 1 Burner
Raw Material/Fuel: Natural Gas
Rated Capacity: 3.8MMBtu/hr
Emission Limits (lb/hr, gr/dscf, lb/MMBtu, % opacity, etc.)
The emissions from this emission point shall not exceed the following specified levels.
Pollutant: Opacity
Emission Limit: 40 %
Authority for Requirement: 567 IAC 23.3(2)"d"
Pollutant: Particulate Matter
Emission Limit: 15.3 lb/MMCF of Propane or Natural Gas
Authority for Requirement: Part 7a. of State of Iowa, ex rel., Iowa DNR vs. Vermeer
Manufacturing Company, 99AG23542
District Court, Marion County, Law No. LACV087889
Pollutant: Particulate Matter
Emission Limit: 0.8 lb/MMBtu
Authority for Requirement: 567 IAC 23.3(2)"b"
Pollutant: Sulfur Dioxide (SO2)
Emission Limit: 500 ppmv
Authority for Requirement: 567 IAC 23.3(3)"e"
Pollutant: Nitrogen Oxides (NOx)
Emission Limit: See Facility-Wide Conditions
Pollutant: Volatile Organic Compounds (VOC)
Emission Limit: See Facility-Wide Conditions
Pollutant: Hazardous Air Pollutants (HAP)
Emission Limit: See Facility-Wide Conditions
Vermeer Manufacturing Co.
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Operational Limits & Requirements
The owner/operator of this equipment shall comply with the following operational limits and
requirements.
Supplemental Environmental Project (SEP):
Equipment parameters:
As part of a multi-stage washer system the emission unit associated with this emission point
will consist of a 3.8 MMBtu/hr heater for the hot alkaline washer system in Stage 1. An
extended drain zone will be provided to prevent chemical drag out to the second stage, a
clean water rinse. A power and free conveyer system will be utilized to supply parts to and
from the washer system. The entire washer system shall be approximately 150 feet long, 8 to
10 feet wide, and constructed of mild and stainless steel.
Authority for Requirement: Paragraph 3d. of State of Iowa, ex rel., Iowa DNR vs. Vermeer
Manufacturing Company, 99AG23542
District Court, Marion County, Law No. LACV087889
Operational term: This SEP will be maintained for the life of this permit.
Authority for Requirement: Paragraph 3i. of State of Iowa, ex rel., Iowa DNR vs. Vermeer
Manufacturing Company, 99AG23542
District Court, Marion County, Law No. LACV087889
Reporting & Record keeping:
Vermeer shall submit to the DNR an annual performance report covering the required period
of use and maintenance of this SEP documenting the actual use and maintenance of this SEP.
The reports shall be submitted on or before March 1, for the preceding calendar year,
commencing on March 1, 1999.
Authority for Requirement: Paragraph 3j. of State of Iowa, ex rel., Iowa DNR vs. Vermeer
Manufacturing Company, 99AG23542
District Court, Marion County, Law No. LACV087889
Process throughput:
The sulfur content of natural gas or LPG combusted by this source is not to exceed 123 ppm
by weight.
Reporting & Recordkeeping: See Facility-Wide Operational Limits
Authority for Requirement: Part 7b. of State of Iowa, ex rel., Iowa DNR vs. Vermeer
Manufacturing Company, 99AG23542
District Court, Marion County, Law No. LACV087889
Vermeer Manufacturing Co.
68
99-TV-052-M001
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Periodic Monitoring Requirements
The owner/operator of this equipment shall comply with the following periodic monitoring
requirements.
Agency Approved Operation & Maintenance Plan Required? Yes ~ No |EI
Facility Maintained Operation & Maintenance Plan Required? Yes ~ No |EI
Authority for Requirement: 567 IAC 22.108(3)"b"
Vermeer Manufacturing Co.
69
99-TV-052-M001
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Emission Point ID Number: 6.SS
Associated Equipment
Associated Emission Unit ID Number: ...
6.SS
Applicable Requirements
Emission Unit vented through this Emission Point: 6.SS
Emission Unit Description: Stage 3 Burner
Raw Material/Fuel: Natural Gas
Rated Capacity: 2.5 MMBtu/hr
Emission Limits (lb/hr, gr/dscf, lb/MMBtu, % opacity, etc.)
The emissions from this emission point shall not exceed the following specified levels.
Pollutant: Opacity
Emission Limit: 40 %
Authority for Requirement: 567 IAC 23.3(2)"d"
Pollutant: Particulate Matter
Emission Limit: 15.3 lb/MMCF of Propane or Natural Gas
Authority for Requirement: Part 7a. of State of Iowa, ex rel., Iowa DNR vs. Vermeer
Manufacturing Company, 99AG23542
District Court, Marion County, Law No. LACV087889
Pollutant: Particulate Matter
Emission Limit: 0.8 lb/MMBtu
Authority for Requirement: 567 IAC 23.3(2)"b"
Pollutant: Sulfur Dioxide (SO2)
Emission Limit: 500 ppmv
Authority for Requirement: 567 IAC 23.3(3)"e"
Pollutant: Nitrogen Oxides (NOx)
Emission Limit: See Facility-Wide Conditions
Pollutant: Volatile Organic Compounds (VOC)
Emission Limit: See Facility-Wide Conditions
Pollutant: Hazardous Air Pollutants (HAP)
Emission Limit: See Facility-Wide Conditions
Vermeer Manufacturing Co.
70
99-TV-052-M001
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Operational Limits & Requirements
The owner/operator of this equipment shall comply with the following operational limits and
requirements.
Supplemental Environmental Project (SEP):
Equipment parameters:
As part of a multi-stage washer system the emission unit associated with this emission point
will consist of a 2.5 MMBtu/hr heater for the hot iron phosphate washer system in Stage 3.
An extended drain zone will be provided to prevent chemical drag out to the fourth stage, a
clean water rinse. A power and free conveyer system will be utilized to supply parts to and
from the washer system. The entire washer system shall be approximately 150 feet long, 8 to
10 feet wide, and constructed of mild and stainless steel.
Authority for Requirement: Paragraph 3d. of State of Iowa, ex rel., Iowa DNR vs. Vermeer
Manufacturing Company, 99AG23542
District Court, Marion County, Law No. LACV087889
Operational term: This SEP will be maintained for the life of this permit.
Authority for Requirement: Paragraph 3i. of State of Iowa, ex rel., Iowa DNR vs. Vermeer
Manufacturing Company, 99AG23542
District Court, Marion County, Law No. LACV087889
Reporting & Record keeping:
Vermeer shall submit to the DNR an annual performance report covering the required period
of use and maintenance of this SEP documenting the actual use and maintenance of this SEP.
The reports shall be submitted on or before March 1, for the preceding calendar year,
commencing on March 1, 1999.
Authority for Requirement: Paragraph 3j. of State of Iowa, ex rel., Iowa DNR vs. Vermeer
Manufacturing Company, 99AG23542
District Court, Marion County, Law No. LACV087889
Process throughput:
The sulfur content of natural gas or LPG combusted by this source is not to exceed 123 ppm
by weight.
Reporting & Recordkeeping: See Facility-Wide Operational Limits
Authority for Requirement: Part 7b. of State of Iowa, ex rel., Iowa DNR vs. Vermeer
Manufacturing Company, 99AG23542
District Court, Marion County, Law No. LACV087889
Vermeer Manufacturing Co.
71
99-TV-052-M001
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Periodic Monitoring Requirements
The owner/operator of this equipment shall comply with the following periodic monitoring
requirements.
Agency Approved Operation & Maintenance Plan Required? Yes ~ No |EI
Facility Maintained Operation & Maintenance Plan Required? Yes ~ No |EI
Authority for Requirement: 567 IAC 22.108(3)"b"
Vermeer Manufacturing Co.
72
99-TV-052-M001
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Emission Point ID Number: 6.TT
Associated Equipment
Associated Emission Unit ID Number: ....
6.TT
Applicable Requirements
Emission Unit vented through this Emission Point: 6.TT
Emission Unit Description: Stage 5 Burner
Raw Material/Fuel: Natural Gas
Rated Capacity: 1.5 MMBtu/hr
Emission Limits (lb/hr, gr/dscf, lb/MMBtu, % opacity, etc.)
The emissions from this emission point shall not exceed the following specified levels.
Pollutant: Opacity
Emission Limit: 40 %
Authority for Requirement: 567 IAC 23.3(2)"d"
Pollutant: Particulate Matter
Emission Limit: 15.3 lb/MMCF of Propane or Natural Gas
Authority for Requirement: Part 7a. of State of Iowa, ex rel., Iowa DNR vs. Vermeer
Manufacturing Company, 99AG23542
District Court, Marion County, Law No. LACV087889
Pollutant: Particulate Matter
Emission Limit: 0.8 lb/MMBtu
Authority for Requirement: 567 IAC 23.3(2)"b"
Pollutant: Sulfur Dioxide (SO2)
Emission Limit: 500 ppmv
Authority for Requirement: 567 IAC 23.3(3)"e"
Pollutant: Nitrogen Oxides (NOx)
Emission Limit: See Facility-Wide Conditions
Pollutant: Volatile Organic Compounds (VOC)
Emission Limit: See Facility-Wide Conditions
Pollutant: Hazardous Air Pollutants (HAP)
Emission Limit: See Facility-Wide Conditions
Vermeer Manufacturing Co.
73
99-TV-052-M001
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Operational Limits & Requirements
The owner/operator of this equipment shall comply with the following operational limits and
requirements.
Supplemental Environmental Project (SEP):
Equipment parameters:
As part of a multi-stage washer system the emission unit associated with this emission point
will consist of a 1.5 MMBtu/hr heater for the hot metal sealer washer system in Stage 5. A
power and free conveyer system will be utilized to supply parts to and from the washer
system. The entire washer system shall be approximately 150 feet long, 8 to 10 feet wide,
and constructed of mild and stainless steel.
Authority for Requirement: Paragraph 3d. of State of Iowa, ex rel., Iowa DNR vs. Vermeer
Manufacturing Company, 99AG23542
District Court, Marion County, Law No. LACV087889
Operational term: This SEP will be maintained for the life of this permit.
Authority for Requirement: Paragraph 3i. of State of Iowa, ex rel., Iowa DNR vs. Vermeer
Manufacturing Company, 99AG23542
District Court, Marion County, Law No. LACV087889
Reporting & Record keeping:
Vermeer shall submit to the DNR an annual performance report covering the required period
of use and maintenance of this SEP documenting the actual use and maintenance of this SEP.
The reports shall be submitted on or before March 1, for the preceding calendar year,
commencing on March 1, 1999.
Authority for Requirement: Paragraph 3j. of State of Iowa, ex rel., Iowa DNR vs. Vermeer
Manufacturing Company, 99AG23542
District Court, Marion County, Law No. LACV087889
Process throughput:
The sulfur content of natural gas or LPG combusted by this source is not to exceed 123 ppm
by weight.
Reporting & Recordkeeping: See Facility-Wide Operational Limits
Authority for Requirement: Part 7b. of State of Iowa, ex rel., Iowa DNR vs. Vermeer
Manufacturing Company, 99AG23542
District Court, Marion County, Law No. LACV087889
Periodic Monitoring Requirements
The owner/operator of this equipment shall comply with the following periodic monitoring
requirements.
Agency Approved Operation & Maintenance Plan Required? Yes ~ No |EI
Facility Maintained Operation & Maintenance Plan Required? Yes ~ No |EI
Authority for Requirement: 567 IAC 22.108(3)"b"
Vermeer Manufacturing Co.
74
99-TV-052-M001
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Emission Point ID Number: 6.UU
Associated Equipment
Associated Emission Unit ID Number: ....
6.UU
Applicable Requirements
Emission Unit vented through this Emission Point: 6.UU
Emission Unit Description: Stage 5 Washer
Raw Material/Fuel: Hot Metal Sealer
Rated Capacity: 300 gal/hr
Emission Limits (lb/hr, gr/dscf, lb/MMBtu, % opacity, etc.)
The emissions from this emission point shall not exceed the following specified levels.
Pollutant: Opacity
Emission Limit: 40 %
Authority for Requirement: 567 IAC 23.3(2)"d"
Pollutant: Particulate Matter
Emission Limit: 0.01 gr/scf
Authority for Requirement: 567 IAC 23.4(13)
Operational Limits & Requirements
The owner/operator of this equipment shall comply with the following operational limits and
requirements.
Supplemental Environmental Project (SEP):
Equipment parameters:
As part of a multi-stage washer system the emission unit associated with this emission point
will consist of a heated metal sealing solution utilizing a sequenced manifold of spray nozzle
tips to prepare the surface of the metal parts for polyurethane coating. A power and free
conveyer system will be utilized to supply parts to and from the washer system. The entire
washer system shall be approximately 150 feet long, 8 to 10 feet wide, and constructed of
mild and stainless steel.
Authority for Requirement: Paragraph 3d. of State of Iowa, ex rel., Iowa DNR vs. Vermeer
Manufacturing Company, 99AG23542
District Court, Marion County, Law No. LACV087889
Operational term: This SEP will be maintained for the life of this permit.
Authority for Requirement: Paragraph 3i. of State of Iowa, ex rel., Iowa DNR vs. Vermeer
Manufacturing Company, 99AG23542
District Court, Marion County, Law No. LACV087889
Vermeer Manufacturing Co.
75
99-TV-052-M001
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Reporting & Record keeping:
Vermeer shall submit to the DNR an annual performance report covering the required period
of use and maintenance of this SEP documenting the actual use and maintenance of this SEP.
The reports shall be submitted on or before March 1, for the preceding calendar year,
commencing on March 1, 1999.
Authority for Requirement: Paragraph 3j. of State of Iowa, ex rel., Iowa DNR vs. Vermeer
Manufacturing Company, 99AG23542
District Court, Marion County, Law No. LACV087889
Periodic Monitoring Requirements
The owner/operator of this equipment shall comply with the following periodic monitoring
requirements.
Agency Approved Operation & Maintenance Plan Required? Yes ~ No |EI
Facility Maintained Operation & Maintenance Plan Required? Yes ~ No |EI
Authority for Requirement: 567 IAC 22.108(3)"b"
Vermeer Manufacturing Co.
76
99-TV-052-M001
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Emission Point ID Number: 1.AG1
Associated Equipment
Associated Emission Unit ID Numbers: l.AG
Emissions Control Equipment ID Number: l.AG
Emissions Control Equipment Description: Paper Filter
Applicable Requirements
Emission Unit vented through this Emission Point: 1 .AG
Emission Unit Description: Finish Paint Booth
Raw Material/Fuel: Paints, Primers, and Solvents
Rated Capacity: 15 gal/hr
Emission Limits (lb/hr, gr/dscf, lb/MMBtu, % opacity, etc.)
The emissions from this emission point shall not exceed the following specified levels.
Pollutant: Opacity
Emission Limit: 40 %
Indicator Opacity: (1)
(1) If visible emissions are observed other than startup, shutdown or malfunction, a stack test may
be required to demonstrate compliance with the particulate standard.
Authority for Requirement: 567 IAC 23.3(2)"d"
Iowa DNR Construction Permit 97-A-972-S3
Pollutant: PMi0
Emission Limit: 1.0 lb/hr
Authority for Requirement: Iowa DNR Construction Permit 97-A-972-S3
Pollutant: Particulate Matter
Emission Limit: 0.01 gr/dscf
Authority for Requirement: 567 IAC 23.4(13)
Iowa DNR Construction Permit 97-A-972-S3
Pollutant: Volatile Organic Compounds (VOC)
Emission Limit: See Facility-Wide Conditions
Authority for Requirement: Iowa DNR Construction Permit 97-A-972-S3
Pollutant: Hazardous Air Pollutants (HAP)
Emission Limit: See Facility-Wide Conditions
Vermeer Manufacturing Co. 77 99-TV-052-M001
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Operational Limits & Requirements
The owner/operator of this equipment shall comply with the following operational limits and
requirements.
Supplemental Environmental Project (SEP):
Equipment parameters:
The emission unit associated with this emission point will maintain a Graco, multi-color,
precision mix system with two gun flush boxes, solvent meters, and solvent valves. The
system will be supplied with a microprocessor which will control solvent, paint, and catalyst
flow to a mixing tube adjacent to the emission unit and record the cumulative amount of the
exact volume or weight of paint, solvent, or catalyst utilized in the emission unit. The system
will be interlocked with the two Graco gun flush boxes, and the guns will be interlocked with
the fans of the paint spray booth.
Authority for Requirement: Paragraph 3b. of State of Iowa, ex rel., Iowa DNR vs. Vermeer
Manufacturing Company, 99AG23542
District Court, Marion County, Law No. LACV087889
Operational term: This SEP will be maintained for the life of this permit.
Authority for Requirement: Paragraph 3i. of State of Iowa, ex rel., Iowa DNR vs. Vermeer
Manufacturing Company, 99AG23542
District Court, Marion County, Law No. LACV087889
Reporting & Record keeping:
Vermeer shall submit to the DNR an annual performance report covering the required period
of use and maintenance of this SEP documenting the actual use and maintenance of this SEP.
The report shall evaluate the performance of the SEP and document the extent of VOC
emissions reductions. Vermeer shall conduct cumulative mass balance calculations to
determine the actual effect measured against the 1997 baseline of 122.94 tons of VOC
emitted per year. The reports shall be submitted on or before March 1, for the preceding
calendar year, commencing on March 1, 1999. For additional reporting and recordkeeping
see the Facility-Wide Conditions.
Authority for Requirement: Paragraph 3j. of State of Iowa, ex rel., Iowa DNR vs. Vermeer
Manufacturing Company, 99AG23542
District Court, Marion County, Law No. LACV087889
Iowa DNR Construction Permit 97-A-972-S3
Emission Point Characteristics
This emission point shall conform to the following conditions.
Stack Height (feet, from the ground): 43.5
Stack Diameter (inches): 36
Stack Exhaust Flow Rate (scfm): 24,000
Stack Temperature (°F): Ambient
Vertical, Unobstructed Discharge Required: Yes ^ No ~
Authority for Requirement: Iowa DNR Construction Permit 97-A-972-S3
Vermeer Manufacturing Co.
78
99-TV-052-M001
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Periodic Monitoring Requirements
The owner/operator of this equipment shall comply with the following periodic monitoring
requirements.
Stack Testing:
Pollutant: Particulate Matter
Stack Test to be Completed by (date): October 18, 2001
Test Method: Iowa Compliance Sampling Manual
Authority for Requirement: 567 IAC 22.108(3)
The higher of the results for emissions from the compliance stack testing of emission points
1.AG1 and 1.AG2 will be used to calculate actual emissions for this source until such time as
more recent data becomes available. If the source test does not demonstrate compliance this
permit will be reopened to add a compliance plan and operation and maintenance requirements.
The owner of this equipment or the owner's authorized agent shall provide written notice to the
Director, not less than 30 days before a required stack test or performance evaluation of a
continuous emission monitor. Results of the test shall be submitted in writing to the Director in
the form of a comprehensive report within 6 weeks of the completion of the testing. 567 IAC
25.1(7)
Agency Approved Operation & Maintenance Plan Required? Yes ~ No |EI
Facility Maintained Operation & Maintenance Plan Required? Yes |EI No ~
Facility operation and maintenance plans must be sufficient to yield reliable data from the
relevant time period that are representative of the source's compliance with the applicable
requirements.
Facility operation and maintenance plans are to be developed by the facility within six (6)
months of the issuance date of this permit and the data pertaining to the plan maintained on site
for at least 5 years. The plan and associated recordkeeping provides documentation of this
facility's implementation of its obligation to operate according to good air pollution control
practice.
Good air pollution control practice is achieved by adoption of quality control standards in the
operation and maintenance procedures for air pollution control that are comparable to industry
quality control standards for the production processes associated with this emission point.
Authority for Requirement: 567 IAC 22.108(3)"b"
Vermeer Manufacturing Co.
79
99-TV-052-M001
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Emission Point ID Number: 1.AG2
Associated Equipment
Associated Emission Unit ID Numbers: l.AG
Emissions Control Equipment ID Number: l.AG
Emissions Control Equipment Description: Paper Filter
Applicable Requirements
Emission Unit vented through this Emission Point: 1 .AG
Emission Unit Description: Finish Paint Booth
Raw Material/Fuel: Paints, Primers, and Solvents
Rated Capacity: 15 gal/hr
Emission Limits (lb/hr, gr/dscf, lb/MMBtu, % opacity, etc.)
The emissions from this emission point shall not exceed the following specified levels.
Pollutant: Opacity
Emission Limit: 40 %
Indicator Opacity: (1)
(1) If visible emissions are observed other than startup, shutdown or malfunction, a stack test may
be required to demonstrate compliance with the particulate standard.
Authority for Requirement: 567 IAC 23.3(2)"d"
Iowa DNR Construction Permit 97-A-973-S3
Pollutant: PMi0
Emission Limit: 1.0 lb/hr
Authority for Requirement: Iowa DNR Construction Permit 97-A-973 -S3
Pollutant: Particulate Matter
Emission Limit: 0.01 gr/dscf
Authority for Requirement: 567 IAC 23.4(13)
Iowa DNR Construction Permit 97-A-973-S3
Pollutant: Volatile Organic Compounds (VOC)
Emission Limit: See Facility-Wide Conditions
Authority for Requirement: Iowa DNR Construction Permit 97-A-973 -S3
Pollutant: Hazardous Air Pollutants (HAP)
Emission Limit: See Facility-Wide Conditions
Vermeer Manufacturing Co. 80 99-TV-052-M001
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Operational Limits & Requirements
The owner/operator of this equipment shall comply with the following operational limits and
requirements.
Supplemental Environmental Project (SEP):
Equipment parameters:
The emission unit associated with this emission point will maintain a Graco, multi-color,
precision mix system with two gun flush boxes, solvent meters, and solvent valves. The
system will be supplied with a microprocessor which will control solvent, paint, and catalyst
flow to a mixing tube adjacent to the emission unit and record the cumulative amount of the
exact volume or weight of paint, solvent, or catalyst utilized in the emission unit. The system
will be interlocked with the two Graco gun flush boxes, and the guns will be interlocked with
the fans of the paint spray booth.
Authority for Requirement: Paragraph 3b. of State of Iowa, ex rel., Iowa DNR vs. Vermeer
Manufacturing Company, 99AG23542
District Court, Marion County, Law No. LACV087889
Operational term: This SEP will be maintained for the life of this permit.
Authority for Requirement: Paragraph 3i. of State of Iowa, ex rel., Iowa DNR vs. Vermeer
Manufacturing Company, 99AG23542
District Court, Marion County, Law No. LACV087889
Reporting & Record keeping:
Vermeer shall submit to the DNR an annual performance report covering the required period
of use and maintenance of this SEP documenting the actual use and maintenance of this SEP.
The report shall evaluate the performance of the SEP and document the extent of VOC
emissions reductions. Vermeer shall conduct cumulative mass balance calculations to
determine the actual effect measured against the 1997 baseline of 122.94 tons of VOC
emitted per year. The reports shall be submitted on or before March 1, for the preceding
calendar year, commencing on March 1, 1999. For additional reporting and recordkeeping
see the Facility-Wide Conditions.
Authority for Requirement: Paragraph 3j. of State of Iowa, ex rel., Iowa DNR vs. Vermeer
Manufacturing Company, 99AG23542
District Court, Marion County, Law No. LACV087889
Iowa DNR Construction Permit 97-A-973-S3
Emission Point Characteristics
This emission point shall conform to the following conditions.
Stack Height (feet, from the ground): 43.5
Stack Diameter (inches): 36
Stack Exhaust Flow Rate (scfm): 24,000
Stack Temperature (°F): Ambient
Vertical, Unobstructed Discharge Required: Yes ^ No ~
Authority for Requirement: Iowa DNR Construction Permit 97-A-973 -S3
Vermeer Manufacturing Co.
81
99-TV-052-M001
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Periodic Monitoring Requirements
The owner/operator of this equipment shall comply with the following periodic monitoring
requirements.
Stack Testing:
Pollutant: Particulate Matter
Stack Test to be Completed by (date): October 18, 2001
Test Method: Iowa Compliance Sampling Manual
Authority for Requirement: 567 IAC 22.108(3)
The higher of the results for emissions from the compliance stack testing of emission points
1.AG1 and 1.AG2 will be used to calculate actual emissions for this source until such time as
more recent data becomes available. If the source test does not demonstrate compliance this
permit will be reopened to add a compliance plan and operation and maintenance requirements.
The owner of this equipment or the owner's authorized agent shall provide written notice to the
Director, not less than 30 days before a required stack test or performance evaluation of a
continuous emission monitor. Results of the test shall be submitted in writing to the Director in
the form of a comprehensive report within 6 weeks of the completion of the testing. 567 IAC
25.1(7)
Agency Approved Operation & Maintenance Plan Required? Yes ~ No |EI
Facility Maintained Operation & Maintenance Plan Required? Yes |EI No ~
Facility operation and maintenance plans must be sufficient to yield reliable data from the
relevant time period that are representative of the source's compliance with the applicable
requirements.
Facility operation and maintenance plans are to be developed by the facility within six (6)
months of the issuance date of this permit and the data pertaining to the plan maintained on site
for at least 5 years. The plan and associated recordkeeping provides documentation of this
facility's implementation of its obligation to operate according to good air pollution control
practice.
Good air pollution control practice is achieved by adoption of quality control standards in the
operation and maintenance procedures for air pollution control that are comparable to industry
quality control standards for the production processes associated with this emission point.
Authority for Requirement: 567 IAC 22.108(3)"b"
Vermeer Manufacturing Co.
82
99-TV-052-M001
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Emission Point ID Number: l.K
Associated Equipment
Associated Emission Unit ID Numbers: 1 K
Emissions Control Equipment ID Number: l.K
Emissions Control Equipment Description: Paper Filter
Applicable Requirements
Emission Unit vented through this Emission Point: 1 .K
Emission Unit Description: Parts Paint Booth
Raw Material/Fuel: Paints, Primers, and Solvents
Rated Capacity: 15 gal/hr
Emission Limits (lb/hr, gr/dscf, lb/MMBtu, % opacity, etc.)
The emissions from this emission point shall not exceed the following specified levels.
Pollutant: Opacity
Emission Limit: 40 %
Indicator Opacity: (1)
(1) If visible emissions are observed other than startup, shutdown or malfunction, a stack test may
be required to demonstrate compliance with the particulate standard.
Authority for Requirement: 567 IAC 23.3(2)"d"
Iowa DNR Construction Permit 97-A-974-S3
Pollutant: Particulate Matter
Emission Limit: 0.01 gr/dscf
Authority for Requirement: 567 IAC 23.4(13)
Iowa DNR Construction Permit 97-A-974-S3
Pollutant: Volatile Organic Compounds (VOC)
Emission Limit: See Facility-Wide Conditions
Authority for Requirement: Iowa DNR Construction Permit 97-A-974-S3
Pollutant: Hazardous Air Pollutants (HAP)
Emission Limit: See Facility-Wide Conditions
Vermeer Manufacturing Co. 83 99-TV-052-M001
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Operational Limits & Requirements
The owner/operator of this equipment shall comply with the following operational limits and
requirements.
Supplemental Environmental Project (SEP):
Equipment parameters:
The emission unit associated with this emission point will maintain a Graco, multi-color,
precision mix system with two gun flush boxes, solvent meters, and solvent valves. The
system will be supplied with a microprocessor which will control solvent, paint, and catalyst
flow to a mixing tube adjacent to the emission unit and record the cumulative amount of the
exact volume or weight of paint, solvent, or catalyst utilized in the emission unit. The system
will be interlocked with the two Graco gun flush boxes, and the guns will be interlocked with
the fans of the paint spray booth.
Authority for Requirement: Paragraph 3b. of State of Iowa, ex rel., Iowa DNR vs. Vermeer
Manufacturing Company, 99AG23542
District Court, Marion County, Law No. LACV087889
Operational term: This SEP will be maintained for the life of this permit.
Authority for Requirement: Paragraph 3i. of State of Iowa, ex rel., Iowa DNR vs. Vermeer
Manufacturing Company, 99AG23542
District Court, Marion County, Law No. LACV087889
Reporting & Record keeping:
Vermeer shall submit to the DNR an annual performance report covering the required period
of use and maintenance of this SEP documenting the actual use and maintenance of this SEP.
The report shall evaluate the performance of the SEP and document the extent of VOC
emissions reductions. Vermeer shall conduct cumulative mass balance calculations to
determine the actual effect measured against the 1997 baseline of 122.94 tons of VOC
emitted per year. The reports shall be submitted on or before March 1, for the preceding
calendar year, commencing on March 1, 1999. For additional reporting and recordkeeping
see the Facility-Wide Conditions.
Authority for Requirement: Paragraph 3j. of State of Iowa, ex rel., Iowa DNR vs. Vermeer
Manufacturing Company, 99AG23542
District Court, Marion County, Law No. LACV087889
Iowa DNR Construction Permit 97-A-974-S3
Emission Point Characteristics
This emission point shall conform to the following conditions.
Stack Height (feet, from the ground): 42.1
Stack Diameter (inches): 34
Stack Exhaust Flow Rate (scfm): 21,195
Stack Temperature (°F): Ambient
Vertical, Unobstructed Discharge Required: Yes ^ No ~
Authority for Requirement: Iowa DNR Construction Permit 97-A-974-S3
Vermeer Manufacturing Co.
84
99-TV-052-M001
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Periodic Monitoring Requirements
The owner/operator of this equipment shall comply with the following periodic monitoring
requirements.
Stack Testing:
Pollutant: Particulate Matter
Stack Test to be Completed by (date): October 18, 2001
Test Method: Iowa Compliance Sampling Manual
Authority for Requirement: 567 IAC 22.108(3)
This stack test will represent the compliance testing for emission points l.K, 2.H, and 5.J. In the
event that a stack test of one of the other listed emission points is more suitable it may be tested
to fulfill the requirements. Suitability will be determined by the Stack Test Observation
Coordinator of the Air Quality Bureau Compliance Assistance Section. The results of the
compliance stack testing will be used to calculate actual emissions for the listed sources until
such time as more recent data becomes available. If the source test does not demonstrate
compliance this permit will be reopened to add a compliance plan and operation and
maintenance requirements.
The owner of this equipment or the owner's authorized agent shall provide written notice to the
Director, not less than 30 days before a required stack test or performance evaluation of a
continuous emission monitor. Results of the test shall be submitted in writing to the Director in
the form of a comprehensive report within 6 weeks of the completion of the testing. 567 IAC
25.1(7)
Agency Approved Operation & Maintenance Plan Required? Yes ~ No |EI
Facility Maintained Operation & Maintenance Plan Required? Yes |EI No ~
Facility operation and maintenance plans must be sufficient to yield reliable data from the
relevant time period that are representative of the source's compliance with the applicable
requirements.
Facility operation and maintenance plans are to be developed by the facility within six (6)
months of the issuance date of this permit and the data pertaining to the plan maintained on site
for at least 5 years. The plan and associated recordkeeping provides documentation of this
facility's implementation of its obligation to operate according to good air pollution control
practice.
Good air pollution control practice is achieved by adoption of quality control standards in the
operation and maintenance procedures for air pollution control that are comparable to industry
quality control standards for the production processes associated with this emission point.
Authority for Requirement: 567 IAC 22.108(3)"b"
Vermeer Manufacturing Co.
85
99-TV-052-M001
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Emission Point ID Number: 5.G1
Associated Equipment
Associated Emission Unit ID Numbers: 5.G
Emissions Control Equipment ID Number: 5.G
Emissions Control Equipment Description: Paper Filter
Applicable Requirements
Emission Unit vented through this Emission Point: 5.G
Emission Unit Description: Finish Paint Booth
Raw Material/Fuel: Paints, Primers, and Solvents
Rated Capacity: 15 gal/hr
Emission Limits (lb/hr, gr/dscf, lb/MMBtu, % opacity, etc.)
The emissions from this emission point shall not exceed the following specified levels.
Pollutant: Opacity
Emission Limit: 40 %
Indicator Opacity: (1)
(1) If visible emissions are observed other than startup, shutdown or malfunction, a stack test may
be required to demonstrate compliance with the particulate standard.
Authority for Requirement: 567 IAC 23.3(2)"d"
Iowa DNR Construction Permit 97-A-1030-S2
Pollutant: PMi0
Emission Limit: 1.22 lb/hr
Authority for Requirement: Iowa DNR Construction Permit 97-A-1030-S2
Pollutant: Particulate Matter
Emission Limit: 0.01 gr/dscf
Authority for Requirement: 567 IAC 23.4(13)
Iowa DNR Construction Permit 97-A-1030-S2
Pollutant: Volatile Organic Compounds (VOC)
Emission Limit: See Facility-Wide Conditions
Authority for Requirement: Iowa DNR Construction Permit 97-A-1030-S2
Pollutant: Hazardous Air Pollutants (HAP)
Emission Limit: See Facility-Wide Conditions
Vermeer Manufacturing Co. 86 99-TV-052-M001
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Operational Limits & Requirements
The owner/operator of this equipment shall comply with the following operational limits and
requirements.
Supplemental Environmental Project (SEP):
Equipment parameters:
The emission unit associated with this emission point will maintain a Graco, multi-color,
precision mix system with two gun flush boxes, solvent meters, and solvent valves. The
system will be supplied with a microprocessor which will control solvent, paint, and catalyst
flow to a mixing tube adjacent to the emission unit and record the cumulative amount of the
exact volume or weight of paint, solvent, or catalyst utilized in the emission unit. The system
will be interlocked with the two Graco gun flush boxes, and the guns will be interlocked with
the fans of the paint spray booth.
Authority for Requirement: Paragraph 3c. of State of Iowa, ex rel., Iowa DNR vs. Vermeer
Manufacturing Company, 99AG23542
District Court, Marion County, Law No. LACV087889
Operational term: This SEP will be maintained for the life of this permit.
Authority for Requirement: Paragraph 3i. of State of Iowa, ex rel., Iowa DNR vs. Vermeer
Manufacturing Company, 99AG23542
District Court, Marion County, Law No. LACV087889
Reporting & Record keeping:
Vermeer shall submit to the DNR an annual performance report covering the required period
of use and maintenance of this SEP documenting the actual use and maintenance of this SEP.
The report shall evaluate the performance of the SEP and document the extent of VOC
emissions reductions. Vermeer shall conduct cumulative mass balance calculations to
determine the actual effect measured against the 1997 baseline of 122.94 tons of VOC
emitted per year. The reports shall be submitted on or before March 1, for the preceding
calendar year, commencing on March 1, 1999. For additional reporting and recordkeeping
see the Facility-Wide Conditions
Authority for Requirement: Paragraph 3j. of State of Iowa, ex rel., Iowa DNR vs. Vermeer
Manufacturing Company, 99AG23542
District Court, Marion County, Law No. LACV087889
Iowa DNR Construction Permit 97-A-1030-S2
Emission Point Characteristics
This emission point shall conform to the following conditions.
Stack Height (feet, from the ground): 40.5
Stack Diameter (inches): 42.0
Stack Exhaust Flow Rate (scfm): 29,000
Stack Temperature (°F): Ambient
Vertical, Unobstructed Discharge Required: Yes ^ No ~
Authority for Requirement: Iowa DNR Construction Permit 97-A-1030-S2
Vermeer Manufacturing Co.
87
99-TV-052-M001
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Periodic Monitoring Requirements
The owner/operator of this equipment shall comply with the following periodic monitoring
requirements.
Stack Testing:
Pollutant: Particulate Matter
Stack Test to be Completed by (date): October 18, 2001
Test Method: Iowa Compliance Sampling Manual
Authority for Requirement: 567 IAC 22.108(3)
The stack tests required for emission points 5.G1 and 5.G2 will represent the compliance testing
for emission points 5.G1, 5G2, 6.Ml, and 6.M2. In the event that a stack test of one of the other
listed emission points is more suitable it may be tested to fulfill the requirements. Suitability
will be determined by the Stack Test Observation Coordinator of the Air Quality Bureau
Compliance Assistance Section. The higher of the results for emissions from the compliance
stack testing of emission points 5.G1 and 5.G2 will be used to calculate actual emissions for the
listed sources until such time as more recent data becomes available. If the source tests do not
demonstrate compliance this permit will be reopened to add a compliance plan and operation and
maintenance requirements.
The owner of this equipment or the owner's authorized agent shall provide written notice to the
Director, not less than 30 days before a required stack test or performance evaluation of a
continuous emission monitor. Results of the test shall be submitted in
writing to the Director in the form of a comprehensive report within 6 weeks of the completion of
the testing. 567 IAC 25.1(7)
Agency Approved Operation & Maintenance Plan Required? Yes ~ No |EI
Facility Maintained Operation & Maintenance Plan Required? Yes |EI No ~
Facility operation and maintenance plans must be sufficient to yield reliable data from the
relevant time period that are representative of the source's compliance with the applicable
requirements.
Facility operation and maintenance plans are to be developed by the facility within six (6)
months of the issuance date of this permit and the data pertaining to the plan maintained on site
for at least 5 years. The plan and associated recordkeeping provides documentation of this
facility's implementation of its obligation to operate according to good air pollution control
practice.
Good air pollution control practice is achieved by adoption of quality control standards in the
operation and maintenance procedures for air pollution control that are comparable to industry
quality control standards for the production processes associated with this emission point.
Authority for Requirement: 567 IAC 22.108(3)"b"
Vermeer Manufacturing Co. 88 99-TV-052-M001
-------
Emission Point ID Number: 5.G2
Associated Equipment
Associated Emission Unit ID Numbers: 5.G
Emissions Control Equipment ID Number: 5.G
Emissions Control Equipment Description: Paper Filter
Applicable Requirements
Emission Unit vented through this Emission Point: 5.G
Emission Unit Description: Finish Paint Booth
Raw Material/Fuel: Paints, Primers, and Solvents
Rated Capacity: 15 gal/hr
Emission Limits (lb/hr, gr/dscf, lb/MMBtu, % opacity, etc.)
The emissions from this emission point shall not exceed the following specified levels.
Pollutant: Opacity
Emission Limit: 40 %
Indicator Opacity: (1)
(1) If visible emissions are observed other than startup, shutdown or malfunction, a stack test may
be required to demonstrate compliance with the particulate standard.
Authority for Requirement: 567 IAC 23.3(2)"d"
Iowa DNR Construction Permit 97-A-1031-S2
Pollutant: PMi0
Emission Limit: 1.22 lb/hr
Authority for Requirement: Iowa DNR Construction Permit 97-A-1031-S2
Pollutant: Particulate Matter
Emission Limit: 0.01 gr/dscf
Authority for Requirement: 567 IAC 23.4(13)
Iowa DNR Construction Permit 97-A-1031-S2
Pollutant: Volatile Organic Compounds (VOC)
Emission Limit: See Facility-Wide Conditions
Authority for Requirement: Iowa DNR Construction Permit 97-A-1031-S2
Pollutant: Hazardous Air Pollutants (HAP)
Emission Limit: See Facility-Wide Conditions
Vermeer Manufacturing Co. 89 99-TV-052-M001
-------
Operational Limits & Requirements
The owner/operator of this equipment shall comply with the following operational limits and
requirements.
Supplemental Environmental Project (SEP):
Equipment parameters:
The emission unit associated with this emission point will maintain a Graco, multi-color,
precision mix system with two gun flush boxes, solvent meters, and solvent valves. The
system will be supplied with a microprocessor which will control solvent, paint, and catalyst
flow to a mixing tube adjacent to the emission unit and record the cumulative amount of the
exact volume or weight of paint, solvent, or catalyst utilized in the emission unit. The system
will be interlocked with the two Graco gun flush boxes, and the guns will be interlocked with
the fans of the paint spray booth.
Authority for Requirement: Paragraph 3b. of State of Iowa, ex rel., Iowa DNR vs. Vermeer
Manufacturing Company, 99AG23542
District Court, Marion County, Law No. LACV087889
Operational term: This SEP will be maintained for the life of this permit.
Authority for Requirement: Paragraph 3i. of State of Iowa, ex rel., Iowa DNR vs. Vermeer
Manufacturing Company, 99AG23542
District Court, Marion County, Law No. LACV087889
Reporting & Record keeping:
Vermeer shall submit to the DNR an annual performance report covering the required period
of use and maintenance of this SEP documenting the actual use and maintenance of this SEP.
The report shall evaluate the performance of the SEP and document the extent of VOC
emissions reductions. Vermeer shall conduct cumulative mass balance calculations to
determine the actual effect measured against the 1997 baseline of 122.94 tons of VOC
emitted per year. The reports shall be submitted on or before March 1, for the preceding
calendar year, commencing on March 1, 1999. For additional reporting and recordkeeping
see the Facility-Wide Conditions
Authority for Requirement: Paragraph 3j. of State of Iowa, ex rel., Iowa DNR vs. Vermeer
Manufacturing Company, 99AG23542
District Court, Marion County, Law No. LACV087889
Iowa DNR Construction Permit 97-A-1031-S2
Emission Point Characteristics
This emission point shall conform to the following conditions.
Stack Height (feet, from the ground): 40.5
Stack Diameter (inches): 42.0
Stack Exhaust Flow Rate (scfm): 29,000
Stack Temperature (°F): Ambient
Vertical, Unobstructed Discharge Required: Yes ^ No ~
Authority for Requirement: Iowa DNR Construction Permit 97-A-1031-S2
Vermeer Manufacturing Co.
90
99-TV-052-M001
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Periodic Monitoring Requirements
The owner/operator of this equipment shall comply with the following periodic monitoring
requirements.
Stack Testing:
Pollutant: Particulate Matter
Stack Test to be Completed by (date): October 18, 2001
Test Method: Iowa Compliance Sampling Manual
Authority for Requirement: 567 IAC 22.108(3)
The stack tests required for emission points 5.G1 and 5.G2 will represent the compliance testing
for emission points 5.G1, 5.G2, 6.M1, and 6.M2. In the event that a stack test of one of the other
listed emission points is more suitable it may be tested to fulfill the requirements. Suitability
will be determined by the Stack Test Observation Coordinator of the Air Quality Bureau
Compliance Assistance Section. The higher of the results for emissions from the compliance
stack testing of emission points 5.G1 and 5.G2 will be used to calculate actual emissions for the
listed sources until such time as more recent data becomes available. If the source tests do not
demonstrate compliance this permit will be reopened to add a compliance plan and operation and
maintenance requirements.
The owner of this equipment or the owner's authorized agent shall provide written notice to the
Director, not less than 30 days before a required stack test or performance evaluation of a
continuous emission monitor. Results of the test shall be submitted in writing to the Director in
the form of a comprehensive report within 6 weeks of the completion of the testing. 567 IAC
25.1(7)
Agency Approved Operation & Maintenance Plan Required? Yes ~ No |EI
Facility Maintained Operation & Maintenance Plan Required? Yes |EI No ~
Facility operation and maintenance plans must be sufficient to yield reliable data from the
relevant time period that are representative of the source's compliance with the applicable
requirements.
Facility operation and maintenance plans are to be developed by the facility within six (6)
months of the issuance date of this permit and the data pertaining to the plan maintained on site
for at least 5 years. The plan and associated recordkeeping provides documentation of this
facility's implementation of its obligation to operate according to good air pollution control
practice.
Good air pollution control practice is achieved by adoption of quality control standards in the
operation and maintenance procedures for air pollution control that are comparable to industry
quality control standards for the production processes associated with this emission point.
Authority for Requirement: 567 IAC 22.108(3)"b"
Vermeer Manufacturing Co.
91
99-TV-052-M001
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Emission Point ID Number: 5. J
Associated Equipment
Associated Emission Unit ID Numbers: 5.J
Emissions Control Equipment ID Number: 5.J
Emissions Control Equipment Description: Paper Filter
Applicable Requirements
Emission Unit vented through this Emission Point: 5.J
Emission Unit Description: Parts Paint Booth
Raw Material/Fuel: Paints, Primers, and Solvents
Rated Capacity: 15 gal/hr
Emission Limits (lb/hr, gr/dscf, lb/MMBtu, % opacity, etc.)
The emissions from this emission point shall not exceed the following specified levels.
Pollutant: Opacity
Emission Limit: 40 %
Indicator Opacity: (1)
(1) If visible emissions are observed other than startup, shutdown or malfunction, a stack test may
be required to demonstrate compliance with the particulate standard.
Authority for Requirement: 567 IAC 23.3(2)"d"
Iowa DNR Construction Permit 97-A-1033-S2
Pollutant: Particulate Matter
Emission Limit: 0.01 gr/dscf
Authority for Requirement: 567 IAC 23.4(13)
Iowa DNR Construction Permit 97-A-1033-S2
Pollutant: Volatile Organic Compounds (VOC)
Emission Limit: See Facility-Wide Conditions
Authority for Requirement: Iowa DNR Construction Permit 97-A-1033-S2
Pollutant: Hazardous Air Pollutants (HAP)
Emission Limit: See Facility-Wide Conditions
Vermeer Manufacturing Co.
92
99-TV-052-M001
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Operational Limits & Requirements
The owner/operator of this equipment shall comply with the following operational limits and
requirements.
Supplemental Environmental Project (SEP):
Equipment parameters:
The emission unit associated with this emission point will maintain a Graco, multi-color,
precision mix system with two gun flush boxes, solvent meters, and solvent valves. The
system will be supplied with a microprocessor which will control solvent, paint, and catalyst
flow to a mixing tube adjacent to the emission unit and record the cumulative amount of the
exact volume or weight of paint, solvent, or catalyst utilized in the emission unit. The system
will be interlocked with the two Graco gun flush boxes, and the guns will be interlocked with
the fans of the paint spray booth.
Authority for Requirement: Paragraph 3c. of State of Iowa, ex rel., Iowa DNR vs. Vermeer
Manufacturing Company, 99AG23542
District Court, Marion County, Law No. LACV087889
Operational term: This SEP will be maintained for the life of this permit.
Authority for Requirement: Paragraph 3i. of State of Iowa, ex rel., Iowa DNR vs. Vermeer
Manufacturing Company, 99AG23542
District Court, Marion County, Law No. LACV087889
Reporting & Record keeping:
Vermeer shall submit to the DNR an annual performance report covering the required period
of use and maintenance of this SEP documenting the actual use and maintenance of this SEP.
The report shall evaluate the performance of the SEP and document the extent of VOC
emissions reductions. Vermeer shall conduct cumulative mass balance calculations to
determine the actual effect measured against the 1997 baseline of 122.94 tons of VOC
emitted per year. The reports shall be submitted on or before March 1, for the preceding
calendar year, commencing on March 1, 1999. For additional reporting and recordkeeping
see the Facility-Wide Conditions
Authority for Requirement: Paragraph 3j. of State of Iowa, ex rel., Iowa DNR vs. Vermeer
Manufacturing Company, 99AG23542
District Court, Marion County, Law No. LACV087889
Iowa DNR Construction Permit 97-A-1033-S2
Emission Point Characteristics
This emission point shall conform to the following conditions.
Stack Height (feet, from the ground): 43.8
Stack Diameter (inches): 42.0
Stack Exhaust Flow Rate (scfm): 20,000
Stack Temperature (°F): Ambient
Vertical, Unobstructed Discharge Required: Yes ^ No ~
Authority for Requirement: Iowa DNR Construction Permit 97-A-1033-S2
Vermeer Manufacturing Co.
93
99-TV-052-M001
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Periodic Monitoring Requirements
The owner/operator of this equipment shall comply with the following periodic monitoring
requirements.
Stack Testing: The stack test required for emission point l.K will represent the compliance
testing for this emission point.
Agency Approved Operation & Maintenance Plan Required? Yes ~ No |EI
Facility Maintained Operation & Maintenance Plan Required? Yes |EI No ~
Facility operation and maintenance plans must be sufficient to yield reliable data from the
relevant time period that are representative of the source's compliance with the applicable
requirements.
Facility operation and maintenance plans are to be developed by the facility within six (6)
months of the issuance date of this permit and the data pertaining to the plan maintained on site
for at least 5 years. The plan and associated recordkeeping provides documentation of this
facility's implementation of its obligation to operate according to good air pollution control
practice.
Good air pollution control practice is achieved by adoption of quality control standards in the
operation and maintenance procedures for air pollution control that are comparable to industry
quality control standards for the production processes associated with this emission point.
Authority for Requirement: 567 IAC 22.108(3)"b"
Vermeer Manufacturing Co.
94
99-TV-052-M001
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Emission Point ID Number: 6.HH
Associated Equipment
Associated Emission Unit ID Numbers: 6.HH
Emissions Control Equipment ID Number: 6.HH
Emissions Control Equipment Description: Paper Filter
Applicable Requirements
Emission Unit vented through this Emission Point: 6.HH
Emission Unit Description: Primer Paint Booth
Raw Material/Fuel: Paints, Primers, and Solvents
Rated Capacity: 15 gal/hr
Emission Limits (lb/hr, gr/dscf, lb/MMBtu, % opacity, etc.)
The emissions from this emission point shall not exceed the following specified levels.
Pollutant: Opacity
Emission Limit: 40 %
Indicator Opacity: (1)
(1) If visible emissions are observed other than startup, shutdown or malfunction, a stack test may
be required to demonstrate compliance with the particulate standard.
Authority for Requirement: 567 IAC 23.3(2)"d"
Iowa DNR Construction Permit 97-A-975-S3
Pollutant: PMi0
Emission Limit: 0.9 lb/hr
Authority for Requirement: Iowa DNR Construction Permit 97-A-975-S3
Pollutant: Particulate Matter
Emission Limit: 0.01 gr/dscf
Authority for Requirement: 567 IAC 23.4(13)
Iowa DNR Construction Permit 97-A-975-S3
Pollutant: Volatile Organic Compounds (VOC)
Emission Limit: See Facility-Wide Conditions
Authority for Requirement: Iowa DNR Construction Permit 97-A-975-S3
Pollutant: Hazardous Air Pollutants (HAP)
Emission Limit: See Facility-Wide Conditions
Vermeer Manufacturing Co. 95 99-TV-052-M001
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Operational Limits & Requirements
The owner/operator of this equipment shall comply with the following operational limits and
requirements.
Supplemental Environmental Project (SEP):
Equipment parameters:
The emission unit associated with this emission point will consist of the booth, an exhaust
fan, and a duct extending from a sixteen (16) foot long by four (4) foot wide by six (6) foot
deep exhaust pit to ten (10) feet above the peak of the roof. The emission unit will maintain
a Binks microprocessor controlled, multi-color, precision mix system with two gun flush
boxes, solvent meters, and solvent valves. The system will be panel mounted approximately
five (5) feet from the nearest opening and will control solvent, paint, and catalyst flow to a
mixing tube adjacent to the emission unit and record the cumulative amount of the exact
volume or weight of primer, paint, solvent, or catalyst utilized in the emission unit. The
system will be interlocked with the two Graco gun flush boxes, and the guns will be
interlocked with the fan mix system and electronic generators of the paint spray booth.
Authority for Requirement: Paragraph 3e. of State of Iowa, ex rel., Iowa DNR vs. Vermeer
Manufacturing Company, 99AG23542
District Court, Marion County, Law No. LACV087889
Operational term: This SEP will be maintained for the life of this permit.
Authority for Requirement: Paragraph 3i. of State of Iowa, ex rel., Iowa DNR vs. Vermeer
Manufacturing Company, 99AG23542
District Court, Marion County, Law No. LACV087889
Reporting & Record keeping:
Vermeer shall submit to the DNR an annual performance report covering the required period
of use and maintenance of this SEP documenting the actual use and maintenance of this SEP.
The report shall evaluate the performance of the SEP and document the extent of VOC
emissions reductions. Vermeer shall conduct cumulative mass balance calculations to
determine the actual effect measured against the 1997 baseline of 122.94 tons of VOC
emitted per year. The reports shall be submitted on or before March 1, for the preceding
calendar year, commencing on March 1, 1999. For additional reporting and recordkeeping
see the Facility-Wide Conditions
Authority for Requirement: Paragraph 3j. of State of Iowa, ex rel., Iowa DNR vs. Vermeer
Manufacturing Company, 99AG23542
District Court, Marion County, Law No. LACV087889
Iowa DNR Construction Permit 97-A-975-S3
Vermeer Manufacturing Co.
96
99-TV-052-M001
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Emission Point Characteristics
This emission point shall conform to the following conditions.
Stack Height (feet, from the ground): 44.5
Stack Diameter (inches): 42.0
Stack Exhaust Flow Rate (scfm): 20,000
Stack Temperature (°F): Ambient
Vertical, Unobstructed Discharge Required: Yes ^ No ~
Authority for Requirement: Iowa DNR Construction Permit 97-A-975-S3
Periodic Monitoring Requirements
The owner/operator of this equipment shall comply with the following periodic monitoring
requirements.
Stack Testing:
Pollutant: Particulate Matter
Stack Test to be Completed by (date): Done*
Test Method: Iowa Compliance Sampling Manual
Authority for Requirement: 567 IAC 22.108(3)
This stack test will represent the compliance testing for emission points 6.HH and 6.S. In the
event that a stack test of the other listed emission point is more suitable it may be tested to fulfill
the requirements. Suitability will be determined by the Stack Test Observation Coordinator of
the Air Quality Bureau Compliance Assistance Section. The results of the compliance stack
testing will be used to calculate actual emissions for the listed sources until such time as more
recent data becomes available. If the source test does not demonstrate compliance this permit
will be reopened to add a compliance plan and operation and maintenance requirements.
* The test report, received September 25, 2000, for the testing conducted August 21-22, 2000,
has been reviewed. This testing is acceptable for showing this source is in compliance with
its particulate limit, 0.01 gr/dscf, and its PMi0 limit, 0.9 lb/hr. Acceptance of these results
does not relieve Vermeer Manufacturing of any responsibility to operate and maintain this
source in compliance.
Vermeer Manufacturing Co.
97
99-TV-052-M001
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Agency Approved Operation & Maintenance Plan Required? Yes ~ No
Facility Maintained Operation & Maintenance Plan Required? Yes |EI No ~
Facility operation and maintenance plans must be sufficient to yield reliable data from the
relevant time period that are representative of the source's compliance with the applicable
requirements.
Facility operation and maintenance plans are to be developed by the facility within six (6)
months of the issuance date of this permit and the data pertaining to the plan maintained on site
for at least 5 years. The plan and associated recordkeeping provides documentation of this
facility's implementation of its obligation to operate according to good air pollution control
practice.
Good air pollution control practice is achieved by adoption of quality control standards in the
operation and maintenance procedures for air pollution control that are comparable to industry
quality control standards for the production processes associated with this emission point.
Authority for Requirement: 567 IAC 22.108(3)"b"
Vermeer Manufacturing Co.
98
99-TV-052-M001
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Point ID Number: 6.M1
Associated Equipment
Associated Emission Unit ID Numbers: 6.M
Emissions Control Equipment ID Number: 6.M
Emissions Control Equipment Description: Paper Filter
Applicable Requirements
Emission Unit vented through this Emission Point: 6.M
Emission Unit Description: Finish Paint Booth
Raw Material/Fuel: Paints, Primers, and Solvents
Rated Capacity: 15 gal/hr
Emission Limits (lb/hr, gr/dscf, lb/MMBtu, % opacity, etc.)
The emissions from this emission point shall not exceed the following specified levels.
Pollutant: Opacity
Emission Limit: 40 %
Indicator Opacity: (1)
(1) If visible emissions are observed other than startup, shutdown or malfunction, a stack test may
be required to demonstrate compliance with the particulate standard.
Authority for Requirement: 567 IAC 23.3(2)"d"
Iowa DNR Construction Permit 97-A-295-S3
Pollutant: PMi0
Emission Limit: 1.22 lb/hr
Authority for Requirement: Iowa DNR Construction Permit 97-A-295-S3
Pollutant: Particulate Matter
Emission Limit: 0.01 gr/dscf
Authority for Requirement: 567 IAC 23.4(13)
Iowa DNR Construction Permit 97-A-295-S3
Pollutant: Volatile Organic Compounds (VOC)
Emission Limit: See Facility-Wide Conditions
Authority for Requirement: Iowa DNR Construction Permit 97-A-295-S3
Pollutant: Hazardous Air Pollutants (HAP)
Emission Limit: See Facility-Wide Conditions
Vermeer Manufacturing Co. 99 99-TV-052-M001
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Operational Limits & Requirements
The owner/operator of this equipment shall comply with the following operational limits and
requirements.
Supplemental Environmental Project (SEP):
Equipment parameters:
The emission unit associated with this emission point will consist of the booth, an exhaust
fan, and a duct extending from a sixteen (16) foot long by four (4) foot wide by six (6) foot
deep exhaust pit to ten (10) feet above the peak of the roof. The emission unit will maintain
a Binks microprocessor controlled, multi-color, precision mix system with two gun flush
boxes, solvent meters, and solvent valves. The system will be panel mounted approximately
five (5) feet from the nearest opening and will control solvent, paint, and catalyst flow to a
mixing tube adjacent to the emission unit and record the cumulative amount of the exact
volume or weight of primer, paint, solvent, or catalyst utilized in the emission unit. The
system will be interlocked with the two Graco gun flush boxes, and the guns will be
interlocked with the fan mix system and electronic generators of the paint spray booth.
Authority for Requirement: Paragraph 3e. of State of Iowa, ex rel., Iowa DNR vs. Vermeer
Manufacturing Company, 99AG23542
District Court, Marion County, Law No. LACV087889
Operational term: This SEP will be maintained for the life of this permit.
Authority for Requirement: Paragraph 3i. of State of Iowa, ex rel., Iowa DNR vs. Vermeer
Manufacturing Company, 99AG23542
District Court, Marion County, Law No. LACV087889
Reporting & Record keeping:
Vermeer shall submit to the DNR an annual performance report covering the required period
of use and maintenance of this SEP documenting the actual use and maintenance of this SEP.
The report shall evaluate the performance of the SEP and document the extent of VOC
emissions reductions. Vermeer shall conduct cumulative mass balance calculations to
determine the actual effect measured against the 1997 baseline of 122.94 tons of VOC
emitted per year. The reports shall be submitted on or before March 1, for the preceding
calendar year, commencing on March 1, 1999. For additional reporting and recordkeeping
see the Facility-Wide Conditions
Authority for Requirement: Paragraph 3j. of State of Iowa, ex rel., Iowa DNR vs. Vermeer
Manufacturing Company, 99AG23542
District Court, Marion County, Law No. LACV087889
Iowa DNR Construction Permit 97-A-295-S3
Vermeer Manufacturing Co.
100
99-TV-052-M001
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Emission Point Characteristics
This emission point shall conform to the following conditions.
Stack Height (feet, from the ground): 43.5
Stack Diameter (inches): 42.0
Stack Exhaust Flow Rate (scfm): 28,620
Stack Temperature (°F): Ambient
Vertical, Unobstructed Discharge Required: Yes ^ No ~
Authority for Requirement: Iowa DNR Construction Permit 97-A-295-S3
Periodic Monitoring Requirements
The owner/operator of this equipment shall comply with the following periodic monitoring
requirements.
Stack Testing: The stack tests required for emission points 5.G1 and 5.G2 will represent the
compliance testing for this emission point.
Agency Approved Operation & Maintenance Plan Required? Yes ~ No |EI
Facility Maintained Operation & Maintenance Plan Required? Yes |EI No ~
Facility operation and maintenance plans must be sufficient to yield reliable data from the
relevant time period that are representative of the source's compliance with the applicable
requirements.
Facility operation and maintenance plans are to be developed by the facility within six (6)
months of the issuance date of this permit and the data pertaining to the plan maintained on site
for at least 5 years. The plan and associated recordkeeping provides documentation of this
facility's implementation of its obligation to operate according to good air pollution control
practice.
Good air pollution control practice is achieved by adoption of quality control standards in the
operation and maintenance procedures for air pollution control that are comparable to industry
quality control standards for the production processes associated with this emission point.
Authority for Requirement: 567 IAC 22.108(3)"b"
Vermeer Manufacturing Co.
101
99-TV-052-M001
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Emission Point ID Number: 6.M2
Associated Equipment
Associated Emission Unit ID Numbers: 6.M
Emissions Control Equipment ID Number: 6.M
Emissions Control Equipment Description: Paper Filter
Applicable Requirements
Emission Unit vented through this Emission Point: 6.M
Emission Unit Description: Primer Paint Booth
Raw Material/Fuel: Paints, Primers, and Solvents
Rated Capacity: 15 gal/hr
Emission Limits (lb/hr, gr/dscf, lb/MMBtu, % opacity, etc.)
The emissions from this emission point shall not exceed the following specified levels.
Pollutant: Opacity
Emission Limit: 40 %
Indicator Opacity: (1)
(1) If visible emissions are observed other than startup, shutdown or malfunction, a stack test may
be required to demonstrate compliance with the particulate standard.
Authority for Requirement: 567 IAC 23.3(2)"d"
Iowa DNR Construction Permit 97-A-296-S3
Pollutant: PMi0
Emission Limit: 1.22 lb/hr
Authority for Requirement: Iowa DNR Construction Permit 97-A-296-S3
Pollutant: Particulate Matter
Emission Limit: 0.01 gr/dscf
Authority for Requirement: 567 IAC 23.4(13)
Iowa DNR Construction Permit 97-A-296-S3
Pollutant: Volatile Organic Compounds (VOC)
Emission Limit: See Facility-Wide Conditions
Authority for Requirement: Iowa DNR Construction Permit 97-A-296-S3
Pollutant: Hazardous Air Pollutants (HAP)
Emission Limit: See Facility-Wide Conditions
Vermeer Manufacturing Co. 102 99-TV-052-M001
-------
Operational Limits & Requirements
The owner/operator of this equipment shall comply with the following operational limits and
requirements.
Supplemental Environmental Project (SEP):
Equipment parameters:
The emission unit associated with this emission point will consist of the booth, an exhaust
fan, and a duct extending from a sixteen (16) foot long by four (4) foot wide by six (6) foot
deep exhaust pit to ten (10) feet above the peak of the roof. The emission unit will maintain
a Binks microprocessor controlled, multi-color, precision mix system with two gun flush
boxes, solvent meters, and solvent valves. The system will be panel mounted approximately
five (5) feet from the nearest opening and will control solvent, paint, and catalyst flow to a
mixing tube adjacent to the emission unit and record the cumulative amount of the exact
volume or weight of primer, paint, solvent, or catalyst utilized in the emission unit. The
system will be interlocked with the two Graco gun flush boxes, and the guns will be
interlocked with the fan mix system and electronic generators of the paint spray booth.
Authority for Requirement: Paragraph 3e. of State of Iowa, ex rel., Iowa DNR vs. Vermeer
Manufacturing Company, 99AG23542
District Court, Marion County, Law No. LACV087889
Operational term: This SEP will be maintained for the life of this permit.
Authority for Requirement: Paragraph 3i. of State of Iowa, ex rel., Iowa DNR vs. Vermeer
Manufacturing Company, 99AG23542
District Court, Marion County, Law No. LACV087889
Reporting & Record keeping:
Vermeer shall submit to the DNR an annual performance report covering the required period
of use and maintenance of this SEP documenting the actual use and maintenance of this SEP.
The report shall evaluate the performance of the SEP and document the extent of VOC
emissions reductions. Vermeer shall conduct cumulative mass balance calculations to
determine the actual effect measured against the 1997 baseline of 122.94 tons of VOC
emitted per year. The reports shall be submitted on or before March 1, for the preceding
calendar year, commencing on March 1, 1999. For additional reporting and recordkeeping
see the Facility-Wide Conditions
Authority for Requirement: Paragraph 3j. of State of Iowa, ex rel., Iowa DNR vs. Vermeer
Manufacturing Company, 99AG23542
District Court, Marion County, Law No. LACV087889
Iowa DNR Construction Permit 97-A-296-S3
Vermeer Manufacturing Co.
103
99-TV-052-M001
-------
Emission Point Characteristics
This emission point shall conform to the following conditions.
Stack Height (feet, from the ground): 43.5
Stack Diameter (inches): 42.0
Stack Exhaust Flow Rate (scfm): 28,620
Stack Temperature (°F): Ambient
Vertical, Unobstructed Discharge Required: Yes ^ No ~
Authority for Requirement: Iowa DNR Construction Permit 97-A-296-S3
Periodic Monitoring Requirements
The owner/operator of this equipment shall comply with the following periodic monitoring
requirements.
Stack Testing: The stack tests required for emission points 5.G1 and 5.G2 will represent the
compliance testing for this emission point.
Agency Approved Operation & Maintenance Plan Required? Yes ~ No |EI
Facility Maintained Operation & Maintenance Plan Required? Yes |EI No ~
Facility operation and maintenance plans must be sufficient to yield reliable data from the
relevant time period that are representative of the source's compliance with the applicable
requirements.
Facility operation and maintenance plans are to be developed by the facility within six (6)
months of the issuance date of this permit and the data pertaining to the plan maintained on site
for at least 5 years. The plan and associated recordkeeping provides documentation of this
facility's implementation of its obligation to operate according to good air pollution control
practice.
Good air pollution control practice is achieved by adoption of quality control standards in the
operation and maintenance procedures for air pollution control that are comparable to industry
quality control standards for the production processes associated with this emission point.
Authority for Requirement: 567 IAC 22.108(3)"b"
Vermeer Manufacturing Co.
104
99-TV-052-M001
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Emission Point ID Number: See Table PAINT
Applicable Requirements
(The following requirements apply to the emission units identified in Table PAINT)
Emission Unit vented through this Emission Point: See Table PAINT
Emission Unit Description: Paint Booth
Raw Material/Fuel: Paints, Primers, and Solvents
Rated Capacity: See Table PAINT
Table PAINT
Emission
Point
Number
Associated
Emission Unit
Number
Control
Equipment
Number
Control Equipment
Description
Rated Capacity
(gal/hr)
2.All
2.AI
2AI
Paper Filter
15
2.AI2
2.AI
2.AI
Paper Filter
15
2.F1
2.F
2.F
Paper Filter
15
2.F2
2.F
2.F
Paper Filter
15
2.H
2.H
2.H
Paper Filter
15
3.F1
3.F
3.F
Paper Filter
15
3.F2
3.F
3.F
Paper Filter
15
3.HH
3.HH
3.HH
Paper Filter
5.625
3.II
3.II
3.II
Paper Filter
5.625
4.F
4.F
4.F
Paper Filter
15
4.G1
4.G
4.G
Paper Filter
15
4.G2
4.G
4.G
Paper Filter
15
6.N
6.N
6.N
Paper Filter
15
6.S
6.S
6.S
Paper Filter
15
Venneer Manufacturing Co.
105
99-TV-052-M001
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Emission Limits (lb/hr, gr/dscf, lb/MMBtu, % opacity, etc.)
The emissions from each emission point identified in Table PAINT2 shall not exceed the
following specified levels.
Table PAINT2
Emission
Point
Number
Associated
Emission Unit
Number
Opacity
Limit
Indicator
Opacity
PMio
Limit
(lb/hr)
PM Limit
(gr/dscf)
Construction
Permit #
2.All
2.All
40%
VE(1)
0.01
98-A-859-S2
2.AI2
2.AI2
40%
VE(1)
0.01
98-A-860-S2
2.F1
2.F1
40%
VE(1)
0.9
0.01
98-A-075-S2
2.F2
2.F2
40%
VE(1)
0.9
0.01
98-A-076-S2
2.H
2.H
40%
VE(1)
0.01
98-A-077-S2
3.F1
3.F1
40%
VE(1)
0.9
0.01
98-A-004-S2
3.F2
3.F2
40%
VE(1)
0.9
0.01
98-A-005-S2
3.HH
3.HH
40%
VE(1)
0.01
99-A-688-S1
3.II
3.II
40%
VE(1)
0.01
99-A-689-S1
4.F
4.F
40%
VE(1)
0.01
98-A-032-S2
4.G1
4.G1
40%
VE(1)
0.9
0.01
98-A-033-S2
4.G2
4.G2
40%
VE(1)
0.9
0.01
98-A-034-S2
6.N
6.N
40%
VE(1)
0.01
97-A-297-S2
6.S
6.S
40%
VE(1)
0.01
96-A-1216-S4
Pollutant: Opacity
Emission Limit: 40%
Indicator Opacity: (1)
(1) If visible emissions are observed other than startup, shutdown or malfunction, a stack test may
be required to demonstrate compliance with the particulate standard.
Authority for Requirement: 567 IAC 23.3(2)"d"
Iowa DNR Construction Permits specified in Table PAINT2
Pollutant: PMi0
Emission Limit: As specified in Table PAINT2
Authority for Requirement: Iowa DNR Construction Permits specified in Table PAINT2
Pollutant: PM
Emission Limit: 0.01 gr/dscf
Authority for Requirement: 567 IAC 23.4(13)
Iowa DNR Construction Permits specified in Table PAINT2
Pollutant: Volatile Organic Compounds (VOC)
Emission Limit: See Facility-Wide Conditions
Authority for Requirement: Iowa DNR Construction Permits specified in Table PAINT2
Pollutant: Hazardous Air Pollutants (HAP)
Emission Limit: See Facility-Wide Conditions
Vermeer Manufacturing Co. 106 99-TV-052-M001
-------
Emission Point Characteristics
These emission points shall conform to the conditions specified in Table PAINT3.
Table PAINT3
Stack Characteristics
Emission
Point
Number
Emission
Unit
Number
Construction
Permit #
Height
(feet)
Diameter
(inches)
Exhaust
Flowrate
(scfm)
Exhaust
Temp.
(F)
Vertical
Unobstructed
Discharge
Required?
2. All
2.AI
98-A-859-S2
36.2
42.0
16,875
Ambient
Yes
2.AI2
2.AI
98-A-860-S2
36.2
42.0
16,875
Ambient
Yes
2.F1
2.F
98-A-075-S2
46.2
42.0
21,000
Ambient
Yes
2.F2
2.F
98-A-076-S2
46.2
42.0
21,000
Ambient
Yes
2.H
2.H
98-A-077-S2
42.5
42.0
21,195
Ambient
Yes
3.F1
3.F
98-A-004-S2
39
42.0
21,000
Ambient
Yes
3.F2
3.F
98-A-005-S2
39
42.0
21,000
Ambient
Yes
3.HH
3.HH
99-A-688-S1
37.5
48.0
24,000
Ambient
Yes
3.II
3.II
99-A-689-S1
37.5
48.0
24,000
Ambient
Yes
4.F
4.F
98-A-032-S2
39.5
42.0
28,000
Ambient
Yes
4.G1
4.G
98-A-033-S2
39.5
42.0
21,000
Ambient
Yes
4.G2
4.G
98-A-034-S2
39.5
42.0
21,000
Ambient
Yes
6.N
6.N
97-A-297-S2
40.2
42.0
16,000
Ambient
Yes
6.S
6.S
96-A-1216-S4
44.5
42.0
20,000
Ambient
Yes
Authority for Requirement: Iowa DNR Construction Permits specified in Table PAINT3
Vermeer Manufacturing Co.
107
99-TV-052-M001
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Periodic Monitoring Requirements
The owner operator of each piece of equipment identified in Table PAINT4 shall comply with the
following periodic monitoring requirements.
Stack Testing:
Table PAINT4
Emission
Point
Number
Test
Required
Test Method
Test To Be
Completed By
Test
Note
Authority for
Requirement
2. All
PM
Iowa Compliance
Sampling Manual*
October 18, 2001
1
567 IAC 22.108(3)
2.AI2
PM
Iowa Compliance
Sampling Manual*
October 18, 2001
1
567 IAC 22.108(3)
2.F1
2
2.F2
2
2.H
3
3.F1
2
3.F2
2
3.HH
PM
Iowa Compliance
Sampling Manual*
Done
4
IDNR Construction Permit
99-A-688-S1
3.II
PM
Iowa Compliance
Sampling Manual*
Done
4
IDNR Construction Permit
99-A-689-S1
4.F
PM
Iowa Compliance
Sampling Manual*
Done
5
567 IAC 22.108(3)
4.G1
PM
Iowa Compliance
Sampling Manual*
October 18, 2001
2
567 IAC 22.108(3)
4.G2
PM
Iowa Compliance
Sampling Manual*
October 18, 2001
2
567 IAC 22.108(3)
6.N
PM
Iowa Compliance
Sampling Manual*
October 18, 2001
567 IAC 22.108(3)
6.S
6,7
*or approved alternative test method
Test Notes:
1. The higher of the results for emissions from the compliance stack testing of emission points
2. All and 2. AI2 will be used to calculate actual emissions for this source until such time as
more recent data becomes available. If the source test does not demonstrate compliance this
permit will be reopened to add a compliance plan and operation and maintenance
requirements.
2. The stack tests required for emission points 4.G1 and 4.G2 will represent the compliance
testing for emission points 2.F1, 2.F2, 3.F1, 3.F2, 4.G1, and 4.G2. In the event that a stack
test of one of the other listed emission points is more suitable it may be tested to fulfill the
requirements. Suitability will be determined by the Stack Test Observation Coordinator of
the Air Quality Bureau Compliance Assistance Section. The higher of the results for
emissions from the compliance stack testing of emission points 4.G1 and 4.G2 will be used
to calculate actual emissions for the listed sources until such time as more recent data
Vermeer Manufacturing Co.
108
99-TV-052-M001
-------
becomes available. If the source test does not demonstrate compliance this permit will be
reopened to add a compliance plan and operation and maintenance requirements.
3. The stack test required for emission point 1 .K will represent the compliance testing for this
emission point.
4. The test report, received August 9, 2000, for the testing conducted June 15, 2000, has been
reviewed. This testing is acceptable for showing that EP 3.HH and EP 3.II are in compliance
with their particulate limit, 0.01 gr/dscf. Acceptance of these results does not relieve
Vermeer Manufacturing of any responsibility to operate and maintain these sources in
compliance.
5. The test report, received September 25, 2000, for the testing conducted August 21-22, 2000,
has been reviewed. This testing is acceptable for showing that EP 4.F is in compliance with
its particulate limit, 0.01 gr/dscf. Acceptance of these results does not relieve Vermeer
Manufacturing of any responsibility to operate and maintain this source in compliance.
6. The stack test required for emission point 6.HH will represent the compliance testing for this
emission point.
7. The test report, received September 25, 2000, for the testing conducted August 21-22, 2000,
has been reviewed. This testing is acceptable for showing that EP 6.HH is in compliance
with its particulate limit, 0.01 gr/dscf, and its PMi0 limit, 0.9 lb/hr. Acceptance of these
results does not relieve Vermeer Manufacturing of any responsibility to operate and maintain
this source in compliance.
The owner of this equipment or the owner's authorized agent shall provide written notice to the
Director, not less than 30 days before a required stack test or performance evaluation of a
continuous emission monitor. Results of the test shall be submitted in writing to the Director in
the form of a comprehensive report within 6 weeks of the completion of the testing. 567IAC
25.1(7)
Agency Approved Operation & Maintenance Plan Required? Yes ~ No |EI
Facility Maintained Operation & Maintenance Plan Required? Yes |EI No ~
Facility operation and maintenance plans must be sufficient to yield reliable data from the
relevant time period that are representative of the source's compliance with the applicable
requirements.
Facility operation and maintenance plans are to be developed by the facility within six(6) months
of the issuance date of this permit and the data pertaining to the plan maintained on site for at
least 5 years. The plan and associated recordkeeping provides documentation of this facility's
implementation of its obligation to operate according to good air pollution control practice.
Good air pollution control practice is achieved by adoption of quality control standards in the
operation and maintenance procedures for air pollution control that are comparable to industry
quality control standards for the production processes associated with this emission point.
Authority for Requirement: 567 IAC 22.108(3)"b"
Vermeer Manufacturing Co.
109
99-TV-052-M001
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Emission Point ID Number: See Table OVEN
Applicable Requirements
(The following requirements apply to the emission units identified in Table OVEN)
Table OVEN
Emission
Point
Number
Associated
Emission Unit
Number
Emission Unit
Description
Fuel
Rated Capacity
(MMBtu/hr)
l.J
l.J
Paint Oven
LPG or NG
2.0
2.1
2.1
Paint Oven
LPG or NG
0.108
3.B
3.B
Paint Oven
NG
2.0
3.JJ
3.JJ
Paint Oven
NG
2.6
3.MM
3.MM
Paint Oven
NG
2.6
4.E
4.E
Paint Oven
NG
1.08
5.1
5.1
Paint Oven
NG
1.5
6.F
6.F
Paint Oven
NG
0.9
Emission Limits (lb/hr, gr/dscf, lb/MMBtu, % opacity, etc.)
The emissions from each emission point identified in Table OVEN2 shall not exceed the
following specified levels.
Table OVEN2
Emission
Point
Number
Associated
Emission Unit
Number
Opacity
Limit
Indicator
Opacity
PM Limit
(gr/dscf)
SO2 Limit
Construction
Permit #
l.J
l.J
40%
VE(1)
0.1
500 ppmv
98-A-094-S1
2.1
2.1
40%
VE(1)
0.1
500 ppmv
98-A-078-S1
3.B
3.B
40%
VE(1)
0.1
500 ppmv
98-A-003-S1
3.JJ
3.JJ
40%
VE(2)
0.1
500 ppmv
99-A-686-S1
3.MM
3.MM
40%
ve(2)
0.1
500 ppmv
00-A-562
4.E
4.E
40%
VE(1)
0.1
500 ppmv
98-A-031-S1
5.1
5.1
40%
VE(1)
0.1
500 ppmv
97-A-1032-S1
6.F
6.F
40%
VE(1)
0.1
500 ppmv
96-A-1217-S3
Venneer Manufacturing Co.
110
99-TV-052-M001
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Pollutant: Opacity
Emission Limit: 40 %
Indicator Opacity (1)
(1) If visible emissions are observed other than startup, shutdown or malfunction, a stack test may
be required to demonstrate compliance with the particulate standard.
Indicator Opacity (2)
(2)Per DNR Air Quality Policy 3-b-08, Opacity Limits, an exceedence of the indicator opacity of
no visible emissions will require the owner/operator to promptly investigate the emission unit
and make corrections to operations or equipment associated with the exceedence. The permit
holder shall also file an "indicator opacity exceedence report" with the DNR field office and
keep records as required in the policy. If exceedences continue after the corrections, the DNR
may require additional proof to demonstrate compliance (e.g., stack testing).
Authority for Requirement: 567 IAC 23.3(2)"d"
Iowa DNR Construction Permits specified in Table OVEN2
Pollutant: Particulate Matter
Emission Limit: 0.1 gr/dscf
Authority for Requirement: 567 IAC 23.3(2)"a"
Iowa DNR Construction Permits specified in Table OVEN2
Pollutant: Sulfur Dioxide (SO2)
Emission Limit: 500 ppmv
Authority for Requirement: 567 IAC 23.3(3)"e"
Pollutant: Nitrogen Oxides (NOx)
Emission Limit: See Facility-Wide Conditions
Authority for Requirement: Iowa DNR Construction Permits specified in Table OVEN2
Pollutant: Volatile Organic Compounds (VOC)
Emission Limit: See Facility-Wide Conditions
Authority for Requirement: Iowa DNR Construction Permits specified in Table OVEN2
Pollutant: Hazardous Air Pollutants (HAP)
Emission Limit: See Facility-Wide Conditions
Operational Limits & Requirements
The owner/operator of each piece of equipment identified in Table OVEN shall comply with the
following operational limits and requirements.
Process throughput:
Each oven shall be fired by natural gas or propane only.
Authority for Requirement: Iowa DNR Construction Permits specified in Table OVEN2
Vermeer Manufacturing Co.
Ill
99-TV-052-M001
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Emission Point Characteristics
These emission points shall conform to the conditions listed in Table OVEN3.
Table OVEN3
Stack Characteristics
Emission
Point
Number
Emission
Unit
Number
Construction
Permit #
Height
(feet)
Diameter
(inches)
Exhaust
Flowrate
(scfm)
Exhaust
Temp.
(F)
Vertical
Unobstructed
Discharge
Required?
l.J
l.J
98-A-094-S1
35
12
1,076
106
Yes
2.1
2.1
98-A-078-S1
34
12
1,100
150
Yes
3.B
3.B
98-A-003-S1
35.5
12
860
90
Yes
3.JJ
3.JJ
99-A-686-S1
35.5
10
2,500
180
Yes
3.MM
3.MM
00-A-562
35.5
10
2,500
180
Yes
4.E
4.E
98-A-031-S1
31
12
1,210
125
Yes
5.1
5.1
97-A-1032-S1
31.5
14
410
102
Yes
6.F
6.F
96-A-1217-S3
28.6
11
1,500
325
Yes
Authority for Requirement: Iowa DNR Construction Permits specified in Table OVEN3.
Periodic Monitoring Requirements
The owner operator of each piece of equipment identified in Table OVEN shall comply with the
following periodic monitoring requirements.
Agency Approved Operation & Maintenance Plan Required? Yes ~ No |EI
Facility Maintained Operation & Maintenance Plan Required? Yes ~ No |EI
Authority for Requirement: 567 IAC 22.108(3)"b"
Vermeer Manufacturing Co.
112
99-TV-052-M001
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Emission Point ID Number: See Table KITCHEN
Applicable Requirements
(The following requirements apply to the emission units identified in Table KITCHEN)
Table KITCHEN
Emission
Point
Associated
Emission Unit
Emission Unit
Description
Raw Material/Fuel
Rated
Capacity
Number
Number(s)
(bbl)
l.AP
LAP
Paint Kitchen
Paints, Primers, and Solvents
3
l.AQ
LAQ1
Paint Kitchen
Paints, Primers, and Solvents
3
LAQ2
Paint Kitchen
Paints, Primers, and Solvents
3
2.AF
2.AF1
Paint Kitchen
Paints, Primers, and Solvents
3
2.AF2
Paint Kitchen
Paints, Primers, and Solvents
3
2.AG
2 AG
Paint Kitchen
Paints, Primers, and Solvents
3
3.GH
3.GH
Paint Kitchen
Paints, Primers, and Solvents
3
3.GI
3.GI
Paint Kitchen
Paints, Primers, and Solvents
3
3.KK
3.KK
Paint Kitchen
Paints, Primers, and Solvents
6
4.CD
4.CD
Paint Kitchen
Paints, Primers, and Solvents
3
4.CE
4.CE1
Paint Kitchen
Paints, Primers, and Solvents
3
4.CE2
Paint Kitchen
Paints, Primers, and Solvents
3
5.BB
5.BB1
Paint Kitchen
Paints, Primers, and Solvents
3
5.BB2
Paint Kitchen
Paints, Primers, and Solvents
3
5.DD
5.DD
Paint Kitchen
Paints, Primers, and Solvents
3
6.FF
6.FF
Paint Kitchen
Paints, Primers, and Solvents
3
6.GG
6.GG
Paint Kitchen
Paints, Primers, and Solvents
3
6.VV
6.VV
Paint Kitchen
Paints, Primers, and Solvents
3
6.WW
6. WW
Paint Kitchen
Paints, Primers, and Solvents
3
Emission Limits (lb/hr, gr/dscf, lb/MMBtu, % opacity, etc.)
The emissions from each emission point identified in Table KITCHEN shall not exceed the
following specified levels.
Pollutant: Volatile Organic Compounds (VOC)
Emission Limit: See Facility-Wide Conditions
Authority for Requirement: Iowa DNR Construction Permits specified in Table KITCHEN2
Pollutant: Hazardous Air Pollutants (HAP)
Emission Limit: See Facility-Wide Conditions
Venneer Manufacturing Co.
113
99-TV-052-M001
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Emission Point Characteristics
These emission points shall conform to the conditions specified in Table KITCHEN2.
Table KITCHEN2
Stack Characteristics
Emission
Point
Number
Emission
Unit
Number
Construction
Permit #
Height
(feet)
Diameter
(inches)
Exhaust
Flowrate
(scfm)
Exhaust
Temp.
(F)
Vertical
Unobstructed
Discharge
Required?
l.AP
l.AP
98-A-089-S1
41
15
3,500
Ambient
Yes
l.AQ
1.AQ1
98-A-090-S1
41
20
7,000
Ambient
Yes
1.AQ2
2.AF
2.AF1
98-A-073-S1
43
20
7,000
Ambient
Yes
2.AF2
2. AG
2. AG
98-A-074-S1
41
20
3,500
Ambient
Yes
3.GH
3.GH
98-A-007-S1
41
15
3,500
Ambient
Yes
3.GI
3.GI
98-A-008-S1
41
15
3,500
Ambient
Yes
3.KK
3.KK
99-A-684
42
24
7,000
Ambient
Yes
4.CD
4.CD
98-A-029-S1
43
15
3,500
Ambient
Yes
4.CE
4.CE1
98-A-030-S1
43
20
7,000
Ambient
Yes
4.CE2
5.BB
5.BB1
97-A-1028-S1
43.5
20
7,000
Ambient
Yes
5.BB2
5.DD
5.DD
98-A-091-S1
43.5
15
3,500
Ambient
Yes
6.FF
6.FF
98-A-156-S1
41
15
3,500
70
Yes
6.GG
6.GG
98-A-157-S1
41
15
3,500
70
Yes
6.VV
6.VV
98-A-155-S2
41
15
3,500
Ambient
Yes
6. WW
6. WW
98-A-858-S1
41
15
3,500
Ambient
Yes
Authority for Requirement: Iowa DNR Construction Permits specified in Table KITCHEN2
Periodic Monitoring Requirements
The owner operator of each piece of equipment identified in Table KITCHEN shall comply with
the following periodic monitoring requirements.
Agency Approved Operation & Maintenance Plan Required? Yes ~ No |EI
Facility Maintained Operation & Maintenance Plan Required? Yes ~ No |EI
Authority for Requirement: 567 IAC 22.108(3)"b"
Vermeer Manufacturing Co.
114
99-TV-052-M001
-------
Emission Point ID Number: See Table ENG
Applicable Requirements
(Hie following requirements apply to the emission units identified in Table ENG)
Table ENG
Emission
Point
Number
Associated
Emission Unit
Number
Emission Unit Description
Raw
Material/Fuel
Rated
Capacity
(gal/hr)
1 AH
l.AH
Production Engine Testing Unit
Diesel/Gasoline
49.1
2.AB
2.AB
Production Engine Testing Unit
Diesel/Gasoline
51.7
2.G
2.G
Production Engine Testing Unit
Diesel/Gasoline
49.1
2.J
2.J
Production Engine Testing Unit
Diesel/Gasoline
49.1
4.J
4.J
Production Engine Testing Unit
Diesel/Gasoline
37.3
5.N
5.N
Production Engine Testing Unit
Diesel/Gasoline
51.7
5.T
5.T
Production Engine Testing Unit
Diesel/Gasoline
51.7
5.W
5.W
Production Engine Testing Unit
Diesel/Gasoline
51.7
Emission Limits (lb/hr, gr/dscf, lb/MMBtu, % opacity, etc.)
The emissions from each emission point identified in Table ENG shall not exceed the following
specified levels.
Pollutant: Opacity
Emission Limit: 40 %
Authority for Requirement: 567 IAC 23.3(2)"d"
Pollutant: Particulate Matter
Emission Limit: 0.1 gr/dscf
Authority for Requirement: 567 IAC 23.3(2)"a"
Pollutant: Sulfur Dioxide (SO2)
Emission Limit: 2.5 lb/MMBtu
Authority for Requirement: 567 IAC 23.3(3)"b"
Pollutant: Nitrogen Oxides (NOx)
Emission Limit: See Facility-Wide Conditions
Pollutant: Volatile Organic Compounds (VOC)
Emission Limit: See Facility-Wide Conditions
Pollutant: Hazardous Air Pollutants (HAP)
Emission Limit: See Facility-Wide Conditions
Vermeer Manufacturing Co. 115 99-TV-052-M001
-------
Operational Limits & Requirements
The owner/operator of each piece of equipment identified in Table ENG shall comply with the
following operational limits and requirements.
Process Throughput:
The sulfur content of any number one or number two diesel fuel combusted at this facility
shall not exceed 0.5% by weight.
Authority for Requirement: 567 IAC 23.3(3)
Fuel Limitations:
1. The 12-month rolling total usage of diesel fuel in all production engine testing units shall not
exceed 350,000 gallons.
2. The 12-month rolling total usage of gasoline in all production engine testing units shall not
exceed 31,000 gallons.
Authority for Requirement: These limits were requested by the applicant.
567 IAC 22.108(14)
Periodic Monitoring Requirements
The owner/operator of each piece of equipment identified in Table ENG shall comply with the
following periodic monitoring requirements.
Agency Approved Operation & Maintenance Plan Required? Yes ~ No |EI
Facility Maintained Operation & Maintenance Plan Required? Yes ~ No |EI
Authority for Requirement: 567 IAC 22.108(3)"b"
Vermeer Manufacturing Co.
116
99-TV-052-M001
-------
Emission Point ID Number: See Table ENG-CP
Applicable Requirements
(The following requirements apply to the emission units identified in Table ENG-CP)
Table ENG-CP
Emission
Point
Number
Associated
Emission Unit
Number
Emission Unit Description
Raw
Material/Fuel
Rated
Capacity
(gal/hr)
l.AU
l.AU
Production Engine Testing Unit
Diesel/Gasoline
50.5
3.A1
3.A1
Production Engine Testing Unit
Diesel/Gasoline
54.5
3.A2
3.A2
Production Engine Testing Unit
Diesel/Gasoline
54.5
3.D1
3.D1
Production Engine Testing Unit
Diesel/Gasoline
54.5
3.D2
3.D2
Production Engine Testing Unit
Diesel/Gasoline
54.5
3.D3
3.D3
Production Engine Testing Unit
Diesel/Gasoline
54.5
3.S
3.S
Production Engine Testing Unit
Diesel/Gasoline
54.5
3.Z
3 Z
Production Engine Testing Unit
Diesel/Gasoline
54.5
4.1
4.1
Production Engine Testing Unit
Diesel/Gasoline
60.6
4.JJ
4.JJ
Production Engine Testing Unit
Diesel/Gasoline
100.9
4.S
4.S
Production Engine Testing Unit
Diesel/Gasoline
60.6
6.D
6.D
Production Engine Testing Unit
Diesel/Gasoline
52.5
6.K
6.K
Production Engine Testing Unit
Diesel/Gasoline
60.6
6.LL
6.LL
Production Engine Testing Unit
Diesel/Gasoline
60.6
6.MM
6.MM
Production Engine Testing Unit
Diesel/Gasoline
60.6
7.G
7.G
Production Engine Testing Unit
Diesel/Gasoline
50.5
7.H
7.H
Production Engine Testing Unit
Diesel/Gasoline
60.6
7.1
7.1
Production Engine Testing Unit
Diesel/Gasoline
60.6
8.B
8.B
Production Engine Testing Unit
Diesel/Gasoline
60.6
HB.A
HB.A
Production Engine Testing Unit
Diesel/Gasoline
50.5
HB.B
HB.B
Production Engine Testing Unit
Diesel/Gasoline
60.6
Vermeer Manufacturing Co.
117
99-TV-052-M001
-------
Emission Limits (lb/hr, gr/dscf, lb/MMBtu, % opacity, etc.)
The emissions from each emission point identified in Table ENG-CP2 shall not exceed the
following specified levels.
Table ENG-CP2
Emission
Point
Number
Associated
Emission
Unit Number
Opacity
Limit
Indicator
Opacity
PM Limit
(gr/dscf)
SO2 Limit
(lb/MMBtu)
Construction
Permit #
l.AU
l.AU
40%
25 %(1)
0.1
2.5
97-A-l 107-S3
3.A1
3.A1
40%
25 %(1)
0.1
2.5
97-A-l 100-S2
3.A2
3.A2
40%
25 %(1)
0.1
2.5
97-A-l 101-S2
3.D1
3.D1
40%
25 %(1)
0.1
2.5
97-A-l 102-S2
3.D2
3.D2
40%
25 %(1)
0.1
2.5
97-A-l 103-S2
3.D3
3.D3
40%
25 %(1)
0.1
2.5
97-A-l 104-S2
3.S
3.S
40%
25 %(1)
0.1
2.5
97-A-l 105-S2
3.Z
3.Z
40%
25 %(1)
0.1
2.5
97-A-l 106-S2
4.1
4.1
40%
25 %(1)
0.1
2.5
97-A-l 108-S2
4.JJ
4.JJ
40%
25 %(2)
0.1
2.5
00-A-561
4.S
4.S
40%
25 %(1)
0.1
2.5
97-A-l 109-S2
6.D
6.D
40%
25 %(1)
0.1
2.5
97-A-299-S3
6.K
6.K
40%
25 %(1)
0.1
2.5
97-A-300-S4
6.LL
6.LL
40%
25 %(1)
0.1
2.5
98-A-865-S2
6.MM
6.MM
40%
25 %(1)
0.1
2.5
98-A-866-S2
7.G
7.G
40%
25 %(1)
0.1
2.5
97-A-l 112-S2
7.H
7.H
40%
25 %(1)
0.1
2.5
98-A-862-S2
7.1
7.1
40%
25 %(1)
0.1
2.5
98-A-863-S2
8.B
8.B
40%
25 %(1)
0.1
2.5
98-A-861-S2
HB.A
HB.A
40%
25 %(1)
0.1
2.5
97-A-l 113-S2
HB.B
HB.B
40%
25 %(2)
0.1
2.5
00-A-668
Pollutant: Opacity
Emission Limit: 40 %
Indicator Opacity: 25 %
(1) If visible emissions are observed that exceed the indicator opacity other than startup,
shutdown or malfunction, a stack test may be required to demonstrate compliance with the
particulate standard.
(2)Per DNR Air Quality Policy 3-b-08, Opacity Limits, an exceedence of the indicator opacity of
25% will require the owner/operator to promptly investigate the emission unit and make
corrections to operations or equipment associated with the exceedence. The permit holder
shall also file an "indicator opacity exceedence report" with the DNR field office and keep
records as required in the policy. If exceedences continue after the corrections, the DNR may
require additional proof to demonstrate compliance (e.g., stack testing).
Authority for Requirement: 567 IAC 23.3(2)"d"
Iowa DNR Construction Permits specified in Table ENG-CP2
Vermeer Manufacturing Co.
118
99-TV-052-M001
-------
Pollutant: Particulate Matter
Emission Limit: 0.1 gr/dscf
Authority for Requirement: 567 IAC 23.3(2)"a"
Iowa DNR Construction Permits specified in Table ENG-CP2
Pollutant: Sulfur Dioxide (SO2)
Emission Limit: 2.5 lb/MMBtu
Authority for Requirement: 567 IAC 23.3(3)"b"
Iowa DNR Construction Permits specified in Table ENG-CP2
Pollutant: Nitrogen Oxides (NOx)
Emission Limit: See Facility-Wide Conditions
Authority for Requirement: Iowa DNR Construction Permits specified in Table ENG-CP2
Pollutant: Volatile Organic Compounds (VOC)
Emission Limit: See Facility-Wide Conditions
Authority for Requirement: Iowa DNR Construction Permits specified in Table ENG-CP2
Pollutant: Hazardous Air Pollutants (HAP)
Emission Limit: See Facility-Wide Conditions
Operational Limits & Requirements
The owner/operator of each piece of equipment identified in Table ENG-CP shall comply with
the following operational limits and requirements.
Process Throughput:
The sulfur content of any diesel fuel used in this source shall not exceed 0.4% by weight.
Authority for Requirement: Iowa DNR Construction Permits as specified in Table ENG-CP2
Fuel Limitations:
1. The 12-month rolling total usage of diesel fuel in all production engine testing units shall not
exceed 350,000 gallons.
2. The 12-month rolling total usage of gasoline in all production engine testing units shall not
exceed 31,000 gallons.
Authority for Requirement: These limits were requested by the applicant.
567 IAC 22.108(14)
Vermeer Manufacturing Co.
119
99-TV-052-M001
-------
Emission Point Characteristics
These emission points shall conform to the conditions specified in Table ENG-CP3.
Table ENG-CP3
Stack Characteristics
Emission
Point
Number
Emission
Unit
Number
Construction
Permit #
Height
(feet)
Diameter
(inches)
Exhaust
Flowrate
(scfm)
Exhaust
Temp.
(F)
Vertical
Unobstructed
Discharge
Required?
l.AU
l.AU
97-A-l107-S3
36
12
2700
759
Yes
3.A1
3.A1
97-A-l100-S2
27
12
2700
759
Yes
3.A2
3.A2
97-A-l 101-S2
30
12
2700
759
Yes
3.D1
3.D1
97-A-l102-S2
37.4
12
2700
759
Yes
3.D2
3.D2
97-A-l103-S2
38.1
12
2700
759
Yes
3.D3
3.D3
97-A-l104-S2
35
12
2700
759
Yes
3.S
3.S
97-A-l105-S2
37
12
2700
759
Yes
3.Z
3.Z
97-A-l106-S2
30.8
12
2700
759
Yes
4.1
4.1
97-A-l108-S2
30
12
3000
845
Yes
4.JJ
4.JJ
00-A-561
35
12
3000
759
Yes
4.S
4.S
97-A-l109-S2
36
12
3000
845
Yes
6.D
6.D
97-A-299-S3
30.5
12
2600
759
Yes
6.K
6.K
97-A-300-S4
30.5
12
3000
845
Yes
6.LL
6.LL
98-A-865-S2
38
12
3000
845
Yes
6.MM
6.MM
98-A-866-S2
38
12
3000
845
Yes
7.G
7.G
97-A-l112-S2
35
12
2500
759
Yes
7.H
7.H
98-A-862-S2
37
12
3000
845
Yes
7.1
7.1
98-A-863-S2
38
12
3000
845
Yes
8.B
8.B
98-A-861-S2
27
12
3000
845
Yes
HB.A
HB.A
97-A-l 113-S2
38
12
2500
759
Yes
HB.B
HB.B
00-A-668
43
12
3000
845
Yes
Authority for Requirement: Iowa DNR Construction Permits specified in Table ENG-CP3
Periodic Monitoring Requirements
The owner operator of each piece of equipment identified in Table ENG-CP shall comply with
the following periodic monitoring requirements.
Agency Approved Operation & Maintenance Plan Required? Yes ~ No |EI
Facility Maintained Operation & Maintenance Plan Required? Yes ~ No |EI
Authority for Requirement: 567 IAC 22.108(3)"b"
Vermeer Manufacturing Co.
120
99-TV-052-M001
-------
Emission Point ID Numbers: See Table HEAT
Applicable Requirements
(The following requirements apply to each emission unit identified in Table HEAT)
Table HEAT
(Natural Gas or Propane Fired Units)
Emission
Associated
Associated Emission
Unit Description
Rated
Point
Number
Emission
Unit Number
Fuel
Capacity
(MMBtu/hr)
l.AA
l.AA
Non-Production Heating Unit
LPG or NG
0.35
l.AC
LAC
Non-Production Heating Unit
LPG or NG
0.35
l.AD
LAD
Non-Production Heating Unit
LPG or NG
0.18
l.AF
l.AF
Non-Production Heating Unit
LPG or NG
1.95
l.AV
LAV
Non-Production Heating Unit
LPG or NG
0.065
LAW
LAW
Non-Production Heating Unit
LPG or NG
0.065
LAX
LAX
Non-Production Heating Unit
LPG or NG
0.065
LAY
LAY
Non-Production Heating Unit
LPG or NG
0.065
1.AZ
1.AZ
Non-Production Heating Unit
LPG or NG
0.065
1.B A
1.B A
Non-Production Heating Unit
LPG or NG
0.065
l.BC
l.BC
Non-Production Heating Unit
LPG or NG
0.25
l.BD
l.BD
Non-Production Heating Unit
LPG or NG
0.25
l.C
l.C
Non-Production Heating Unit
LPG or NG
2.5
ID
ID
Water Heater
LPG or NG
0.28
LEE
LEE
Phos Pro Water Heater
LPG or NG
0.28
IFF
IFF
Non-Production Heating Unit
LPG or NG
0.25
l.GG
l.GG
Non-Production Heating Unit
LPG or NG
0.25
1.0
1.0
Non-Production Heating Unit
LPG or NG
2.0
l.U
l.U
Water Heater
LPG or NG
0.528
l.Y
l.Y
Non-Production Heating Unit
LPG or NG
8.0
2.AD1
2.AD1
Make Up Air Unit
LPG or NG
3.23
2.AD2
2.AD2
Make Up Air Unit
LPG or NG
3.23
2.AE
2.AE
Make Up Air Unit
LPG or NG
2.17
2.AH
2.AH
Phos Pro Water Heater
LPG or NG
0.55
2.AJ
2.AJ
Paint Booth Air Intake
LPG or NG
3.28
2.B
2.B
Non-Production Heating Unit
LPG or NG
0.35
2.P
2.P
Non-Production Heating Unit
LPG or NG
6.33
2 Q
2 Q
Water Heater
LPG or NG
0.528
2.VI
2.VI
Non-Production Heating Unit
LPG or NG
0.18
2.V2
2.V2
Non-Production Heating Unit
LPG or NG
0.18
2.X
2.X
Non-Production Heating Unit
LPG or NG
0.10
2.Y1
2.Y1
Non-Production Heating Unit
LPG or NG
0.15
2.Y2
2.Y2
Non-Production Heating Unit
LPG or NG
0.15
3.AA
3.AA
Parts Oven
NG
0.35
Vermeer Manufacturing Co.
121
99-TV-052-M001
-------
Table HEAT (continued)
(Natural Gas or Propane Fired Units)
Emission
Associated
Associated Emission
Unit Description
Rated
Point
Number
Emission
Unit Number
Fuel
Capacity
(MMBtu/hr)
3.AD
3.AD
Phos Pro Water Heater
NG
0.55
3.AF
3.AF
Non-Production Heating Unit
NG
0.065
3. AG
3 AG
Non-Production Heating Unit
NG
0.065
3.BB
3.BB
Non-Production Heating Unit
NG
1.3
3.C
3.C
Non-Production Heating Unit
NG
2.0
3.GG
3.GG
Non-Production Heating Unit
NG
0.05
3.GK1
3.GK1
Non-Production Heating Unit
NG
0.05
3.GK2
3.GK2
Non-Production Heating Unit
NG
0.05
3.LL
3.LL
Make Up Air Unit
NG
2.33
3.M
3.M
Water Heater
NG
0.528
3.P
3.P
Non-Production Heating Unit
NG
6.25
3.PP
3.PP
Make Up Air Unit
NG
2.33
3.RR
3.RR
Make Up Air Unit
NG
3.04
3.SS
3.SS
Make Up Air Unit
NG
3.04
3.T
3.T
Non-Production Heating Unit
NG
0.18
3.TT
3.TT
Make Up Air Unit
NG
3.65
3.UU
3.UU
Make Up Air Unit
NG
3.65
3.VV
3.VV
Make Up Air Unit
NG
3.65
3.W
3.W
Non-Production Heating Unit
NG
1.5
3. WW
3. WW
Make Up Air Unit
NG
2.33
3.XI
3.XI
Non-Production Heating Unit
NG
0.13
3.X2
3.X2
Non-Production Heating Unit
NG
0.13
3.Y1
3.Y1
Non-Production Heating Unit
NG
4.86
4.A1
4A1
Non-Production Heating Unit
NG
2.0
4.A2
4A2
Non-Production Heating Unit
NG
2.0
4.A3
4A3
Non-Production Heating Unit
NG
2.0
4.AA
4AA
Non-Production Heating Unit
NG
2.0
4.AC
4AC
Non-Production Heating Unit
NG
0.07
4.AD
4.AD
Non-Production Heating Unit
NG
0.07
4.AE
4.AE
Non-Production Heating Unit
NG
0.21
4.AF
4.AF
Non-Production Heating Unit
NG
0.21
4.BB
4.BB
Non-Production Heating Unit
NG
2.0
4.D
4.D
Water Heater
NG
0.528
4.H2
4.H2
Non-Production Heating Unit
NG
5.35
4.K1
4.K1
Non-Production Heating Unit
NG
5.35
4.KK
4.KK
Wash Bay Heater
NG
0.28
4.L
4.L
Non-Production Heating Unit
NG
0.24
4.R
4.R
Non-Production Heating Unit
NG
3.24
4.T
4.T
Non-Production Heating Unit
NG
0.09
5.A
5A
Non-Production Heating Unit
NG
3.58
Vermeer Manufacturing Co.
122
99-TV-052-M001
-------
Table HEAT (continued)
(Natural Gas or Propane Fired Units)
Emission
Associated
Associated Emission
Unit Description
Rated
Point
Number
Emission
Unit Number
Fuel
Capacity
(MMBtu/hr)
5.AA
5.AA
Non-Production Heating Unit
NG
0.25
5.AJ1
5.AJ1
Make Up Air Unit
NG
5.859
5.AJ2
5.AJ2
Make Up Air Unit
NG
5.859
5.AJ3
5.AJ3
Make Up Air Unit
NG
5.859
5.AJ4
5.AJ4
Make Up Air Unit
NG
5.859
5.AJ5
5.AJ5
Make Up Air Unit
NG
5.859
5.AJ6
5.AJ6
Make Up Air Unit
NG
5.859
5.AJ7
5.AJ7
Make Up Air Unit
NG
5.859
5.AJ8
5.AJ8
Make Up Air Unit
NG
5.859
5.B1
5.B1
Non-Production Heating Unit
NG
2.0
5.B2
5.B2
Non-Production Heating Unit
NG
2.0
5.E
5.E
Water Heater
NG
0.528
5.EE
5.EE
Non-Production Heating Unit
NG
0.065
5.FF
5.FF
Non-Production Heating Unit
NG
0.065
5.GG
5.GG
Non-Production Heating Unit
NG
0.065
5.H
5.H
Non-Production Heating Unit
NG
6.33
5.HH
5.HH
Non-Production Heating Unit
NG
0.065
5.II
5.II
Non-Production Heating Unit
NG
0.065
5.JJ
5.JJ
Non-Production Heating Unit
NG
0.065
5.K
5.K
Non-Production Heating Unit
NG
2.35
5.M
5.M
Non-Production Heating Unit
NG
0.76
5.0
5.0
Non-Production Heating Unit
NG
2.50
5.P
5.P
Make Up Air Unit
NG
1.65
5.R
5.R
Water Heater
NG
0.528
6.AA1
6.AA1
Non-Production Heating Unit
NG
0.08
6.AA2
6.AA2
Non-Production Heating Unit
NG
0.08
6. A A3
6. A A3
Non-Production Heating Unit
NG
0.08
6.AA4
6.AA4
Non-Production Heating Unit
NG
0.08
6.AB
6.AB
Non-Production Heating Unit
NG
2.75
6.AC
6.AC
Non-Production Heating Unit
NG
2.75
6.AD
6.AD
Non-Production Heating Unit
NG
2.75
6.AE
6.AE
Non-Production Heating Unit
NG
2.75
6.AF
6.AF
Non-Production Heating Unit
NG
2.75
6.AG
6.AG
Non-Production Heating Unit
NG
2.75
6.C
6.C
Non-Production Heating Unit
NG
7.43
6.JJ
6.JJ
Paint Booth Air Intake
NG
2.16
6.KK
6.KK
Paint Booth Air Intake
NG
2.16
6.L
6.L
Non-Production Heating Unit
NG
0.11
6 Q
6 Q
Water Heater
NG
0.528
6.R
6.R
Non-Production Heating Unit
NG
4.68
Vermeer Manufacturing Co.
123
99-TV-052-M001
-------
Table HEAT (continued)
(Natural Gas or Propane Fired Units)
Emission
Associated
Associated Emission
Unit Description
Rated
Point
Number
Emission
Unit Number
Fuel
Capacity
(MMBtu/hr)
6.T
6.T
Non-Production Heating Unit
NG
0.12
7.B1
7.B1
Non-Production Heating Unit
NG
0.16
7.B2
7.B2
Non-Production Heating Unit
NG
1.0
7.B3
7.B3
Non-Production Heating Unit
NG
1.0
7.B4
7.B4
Non-Production Heating Unit
NG
1.0
7.D
7.D
Non-Production Heating Unit
NG
7.43
7.K
7.K
Non-Production Heating Unit
NG
0.1
7.L
7.L
Non-Production Heating Unit
NG
0.135
7.M
7.M
Non-Production Heating Unit
NG
0.08
7.N
7.N
Non-Production Heating Unit
NG
0.08
7.0
7.0
Non-Production Heating Unit
NG
0.08
7.P
7.P
Non-Production Heating Unit
NG
0.1
7.Q
7 Q
Non-Production Heating Unit
NG
0.1
7.S
7.S
Non-Production Heating Unit
NG
2.75
7.T
7.T
Non-Production Heating Unit
NG
7.50
7.T1
7.T1
Non-Production Heating Unit
NG
7.50
7.U
7.U
Non-Production Heating Unit
NG
0.054
7.V
7.V
Non-Production Heating Unit
NG
0.054
7.W
7.W
Non-Production Heating Unit
NG
0.065
7.X
7.X
Non-Production Heating Unit
NG
0.065
8.A1
8.A1
Non-Production Heating Unit
NG
0.4
8.A2
8.A2
Non-Production Heating Unit
NG
0.4
8.A3
8. A3
Non-Production Heating Unit
NG
0.4
8.A4
8.A4
Non-Production Heating Unit
NG
0.4
8.A5
8.A5
Non-Production Heating Unit
NG
0.4
8.A6
8.A6
Non-Production Heating Unit
NG
0.4
8.A7
8.A7
Non-Production Heating Unit
NG
0.4
8.A8
8.A8
Non-Production Heating Unit
NG
0.4
8.A9
8.A9
Non-Production Heating Unit
NG
0.4
8.A10
8.A10
Non-Production Heating Unit
NG
0.4
8.A11
8. All
Non-Production Heating Unit
NG
0.4
8.A12
8.A12
Non-Production Heating Unit
NG
0.4
HB.J
HB.J
Non-Production Heating Unit
NG
0.075
HB.N
HB.N
Non-Production Heating Unit
NG
0.075
P.C1
P.C1
Non-Production Heating Unit
NG
0.4
P.C2
P.C2
Non-Production Heating Unit
NG
0.4
P.D1
P.D1
Non-Production Heating Unit
NG
0.4
P.D2
P.D2
Non-Production Heating Unit
NG
0.4
P.D3
P.D3
Non-Production Heating Unit
NG
0.4
P.E
P.E
Non-Production Heating Unit
NG
0.4
Vermeer Manufacturing Co.
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Table HEAT (continued)
(Natural Gas or Propane Fired Units)
Emission
Point
Number
Associated
Emission
Unit Number
Associated Emission
Unit Description
Fuel
Rated
Capacity
(MMBtu/hr)
PB.A
PB.A
Non-Production Heating Unit
NG
0.4
W.B
W.B
Hotsey Washer
NG
0.657
Emission Limits (lb/hr, gr/dscf, lb/MMBtu, % opacity, etc.)
The emissions from each emission point identified in Table HEAT shall not exceed the following
specified levels.
Pollutant: Opacity
Emission Limit: 40 %
Authority for Requirement: 567 IAC 23.3(2)"d"
Pollutant: Particulate Matter
Emission Limit: 15.3 lb/MMCF of Propane or Natural Gas
Authority for Requirement: Part 7a. of State of Iowa, ex rel., Iowa DNR vs. Vermeer
Manufacturing Company, 99AG23542
District Court, Marion County, Law No. LACV087889
Pollutant: Particulate Matter
Emission Limit: 0.8 lb/MMBtu
Authority for Requirement: 567 IAC 23.3(2)"b"
Pollutant: Sulfur Dioxide (SO2)
Emission Limit: 500 ppmv
Authority for Requirement: 567 IAC 23.3(3)"e"
Pollutant: Nitrogen Oxides (NOx)
Emission Limit: See Facility-Wide Conditions
Pollutant: Volatile Organic Compounds (VOC)
Emission Limit: See Facility-Wide Conditions
Pollutant: Hazardous Air Pollutants (HAP)
Emission Limit: See Facility-Wide Conditions
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Operational Limits & Requirements
The owner/operator of each piece of equipment identified in Table HEAT shall comply with the
following operational limits and requirements.
Process throughput:
The sulfur content of natural gas or LPG combusted by this source is not to exceed 123 ppm
by weight.
Reporting & Recordkeeping: See Facility-Wide Operational Limits
Authority for Requirement: Part 7b. of State of Iowa, ex rel., Iowa DNR vs. Vermeer
Manufacturing Company, 99AG23542
District Court, Marion County, Law No. LACV087889
Periodic Monitoring Requirements
The owner/operator of each piece of equipment identified in Table HEAT shall comply with the
following periodic monitoring requirements.
Agency Approved Operation & Maintenance Plan Required? Yes ~ No |EI
Facility Maintained Operation & Maintenance Plan Required? Yes ~ No |EI
Authority for Requirement: 567 IAC 22.108(3)"b"
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Emission Point ID Number: See Table HEAT2
Applicable Requirements
(Hie following requirements apply to each emission unit identified in Table HEAT2)
Table HEAT2
(Waste Oil Fired Units)
Emission
Point
Number
Associated
Emission
Unit Number
Associated Emission
Unit Description
Fuel
Rated
Capacity
(gal/hr)
P.A1
P.A1
Non-Production Heating Unit
Waste Oil
3.28
P.A2
P.A2
Non-Production Heating Unit
Waste Oil
3.28
Q A
Q A
Non-Production Heating Unit
Waste Oil
3.28
WW.A
WW.A
Non-Production Heating Unit
Waste Oil
3.28
Emission Limits (lb/hr, gr/dscf, lb/MMBtu, % opacity, etc.)
The emissions from each emission point described in Table HEAT2 shall not exceed the
following specified levels.
Pollutant: Opacity
Emission Limit: 40 %
Authority for Requirement: 567 IAC 23.3(2)"d"
Pollutant: Particulate Matter
Emission Limit: 0.8 lb/MMBtu
Authority for Requirement: 567 IAC 23.3(2)"b"
Pollutant: Sulfur Dioxide (SO2)
Emission Limit: 2.5 lb/MMBtu
Authority for Requirement: 567 IAC 23.3(3)"b"
Pollutant: Nitrogen Oxides (NOx)
Emission Limit: See Facility-Wide Conditions
Pollutant: Volatile Organic Compounds (VOC)
Emission Limit: See Facility-Wide Conditions
Pollutant: Hazardous Air Pollutants (HAP)
Emission Limit: See Facility-Wide Conditions
Vermeer Manufacturing Co. 127 99-TV-052-M001
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Periodic Monitoring Requirements
The owner/operator of each piece of equipment identified in Table HEAT2 shall comply with the
following periodic monitoring requirements.
Agency Approved Operation & Maintenance Plan Required? Yes ~ No |EI
Facility Maintained Operation & Maintenance Plan Required? Yes ~ No |EI
Authority for Requirement: 567 IAC 22.108(3)"b"
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Emission Point ID Number: See Table TANK
Applicable Requirements
(The following requirements apply to the emission units identified in Table TANK)
Table TANK
Emission
Point
Number
Associated
Emission
Unit Number
Associated Emission
Unit Description
Material Stored
Capacity
(gallons per
tank)
DSLTANK2
DSLTANK2
Storage Tank
Diesel Fuel
1,000
DSLTANK4
DSLTANK4
Storage Tank
Diesel Fuel
1,000
DSLTANK8
DSLTANK8
Storage Tank
Diesel Fuel
1,000
DSLTANK9
DSLTANK9
Storage Tank
Diesel Fuel
1,000
GASTANK3
GASTANK3
Storage Tank
Gasoline
1,000
GASTANK7
GASTANK7
Storage Tank
Gasoline
1,000
OILTANK
OILTANK
Storage Tank
Used Oil
5,000
PROPANE
PROPANE
Three (3) Storage Tanks
Propane
6,000
PROPYLENE
PROPYLENE
Three (3) Storage Tanks
Propylene
1,000
Emission Limits (lb/hr, gr/dscf, lb/MMBtu, % opacity, etc.)
The emissions from each emission point described in Table TANK shall not exceed the following
specified levels.
Pollutant: Volatile Organic Compounds (VOC)
Emission Limit: See Facility-Wide Conditions
Pollutant: Hazardous Air Pollutants (HAP)
Emission Limit: See Facility-Wide Conditions
Periodic Monitoring Requirements
The owner operator of each piece of equipment identified in Table TANK shall comply with the
following periodic monitoring requirements.
Agency Approved Operation & Maintenance Plan Required? Yes ~ No |EI
Facility Maintained Operation & Maintenance Plan Required? Yes ~ No |EI
Authority for Requirement: 567 IAC 22.108(3)"b"
Vermeer Manufacturing Co. 129 99-TV-052-M001
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Emission Point ID Number: l.T
Associated Equipment
Associated Emission Unit ID Number: l.T
Emissions Control Equipment ID Number: l.T
Emissions Control Equipment Description: Baghouse
Applicable Requirements
Emission Unit vented through this Emission Point: l.T
Emission Unit Description: Wheelabrator Shot Blast Booth
Raw Material/Fuel: Abrasive Shot
Rated Capacity: 40 lb/hr
Emission Limits (lb/hr, gr/dscf, lb/MMBtu, % opacity, etc.)
The emissions from this emission point shall not exceed the following specified levels.
Pollutant: Opacity
Emission Limit: 40 %
Authority for Requirement: 567 IAC 23.3(2)"d"
Pollutant: Particulate Matter
Emission Limit: 0.05 gr/dscf
Authority for Requirement: 567 IAC 23.4(6)
Iowa DNR Construction Permit 79-A-108
Periodic Monitoring Requirements
The owner/operator of this equipment shall comply with the following periodic monitoring
requirements.
Agency Approved Operation & Maintenance Plan Required? Yes ~ No |EI
Facility Maintained Operation & Maintenance Plan Required? Yes ~ No |EI
Authority for Requirement: 567 IAC 22.108(3)"b"
Vermeer Manufacturing Co. 130 99-TV-052-M001
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Emission Point ID Number: W.E
Associated Equipment
Associated Emission Unit ID Number: ...
W.E
Applicable Requirements
Emission Unit vented through this Emission Point: W.E
Emission Unit Description: Paint Hook Burn-Off Oven
Raw Material/Fuel: Natural Gas
Rated Capacity: 0.78 MMBtu/hr
Emission Limits (lb/hr, gr/dscf, lb/MMBtu, % opacity, etc.)
The emissions from this emission point shall not exceed the following specified levels.
Pollutant: Opacity
Emission Limit: 40
Authority for Requirement: 567 IAC 23.4(12)"b"
Iowa DNR Construction Permit 98-A-072-S1
(1)No person shall allow, cause or permit the operation of an incinerator in a manner such that it
produces visible air contaminants in excess of 40 percent opacity; except that visible air
contaminants in excess of 60 percent opacity may be emitted for a period or period aggregating
not more than 3 minutes in any 60-minute period during operation breakdown or during the
cleaning of air pollution control equipment.
Pollutant: Particulate Matter
Emission Limit: 0.35 gr/dscf^
(1) Adjusted to 12% CO2
Authority for Requirement: 567 IAC 23.4(12)"a"
Iowa DNR Construction Permit 98-A-072-S1
Pollutant: Sulfur Dioxide (SO2)
Emission Limit: 500 ppmv
Authority for Requirement: 567 IAC 23.3(3)"e"
Pollutant: Nitrogen Oxides (NOx)
Emission Limit: See Facility-Wide Conditions
Authority for Requirement: Iowa DNR Construction Permit 98-A-072-S1
Pollutant: Volatile Organic Compounds (VOC)
Emission Limit: See Facility-Wide Conditions
Authority for Requirement: Iowa DNR Construction Permit 98-A-072-S1
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Pollutant:
Emission Limit:
Hazardous Air Pollutants (HAP)
See Facility-Wide Conditions
Compliance Testing Requirements
PM
Iowa Compliance Sampling Manual*
The owner shall verify compliance with the emission limitations contained in Construction
Permit 98-A-072-S1 within sixty (60) days after achieving maximum production rate and no
later than one hundred eighty (180) days after the startup date of the proposed equipment. The
test shall be conducted with the equipment operating in a manner representative of full rated
capacity. Failure to test at this maximum may be cause to limit the source to operating at the
level at which the compliance tests were conducted.
The owner shall furnish the DNR the following written notifications:
1. The date of intended startup at least ten (10) days before the equipment or control
equipment involved is placed into operation.
2. The actual date of startup postmarked within fifteen (15) days following the start of
operation.
Authority for Requirement: Iowa DNR Construction Permit 98-A-072-S1
*The required stack testing was performed on November 15, 1999.
Operational Limits & Requirements
The owner/operator of this equipment shall comply with the following operational limits and
requirements.
Supplemental Environmental Project (SEP):
Equipment parameters:
The emission unit associated with this emission point will consist of a high temperature,
natural gas fired oven for the destruction of paint built up on the hooks that transport parts to
the paint lines at the facility. This will include a 36 foot by 16 foot insulated addition to the
existing waste management building to house one Blu Surf Model No. 6506 Wash Booth
Unit and one Model No. 5505 Burnoff Oven together with the necessary electrical system for
the equipment, gas lines for the oven, drain lines for the wash water discharge, multilevel
footings, foundation, and concrete flooring to support and allow for operation of the oven.
The hook burnoff oven system will consist of one batch burnoff oven, Model No. 5506 with
a top mount after burner.
Vermeer Manufacturing Co. 132 99-TV-052-M001
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The oven will include a primary and secondary water suppression system to prevent
overheating during oven burning cycles. A modulating gas valve system will be supplied for
the primary burner to maintain consistent, efficient thermal operating temperatures, operating
at an approximate 540,000 Btu per hour level with a potential for 780,000 Btu per hour
maximum. Each time the oven is started, the water suppression system will automatically
turn on for approximately 30 seconds. A roller track will be installed in the floor to transport
carts from the oven to the wash booth unit. The wash unit will be supplied with a power
washer operating at 2 gallons per minute at 1,000 pounds per square inch pressure for
cleaning the ash from the hooks, carts and racks after burning.
Authority for Requirement: Paragraph 3a. of State of Iowa, ex rel., Iowa DNR vs. Vermeer
Manufacturing Company, 99AG23542
District Court, Marion County, Law No. LACV087889
Operational term: This SEP will be maintained for the life of this permit.
Authority for Requirement: Paragraph 3i. of State of Iowa, ex rel., Iowa DNR vs. Vermeer
Manufacturing Company, 99AG23542
District Court, Marion County, Law No. LACV087889
Reporting & Record keeping:
Vermeer shall submit to the DNR an annual performance report covering the required period
of use and maintenance of this SEP documenting the actual use and maintenance of this SEP.
The reports shall be submitted on or before March 1, for the preceding calendar year,
commencing on March 1, 1999.
Authority for Requirement: Paragraph 3j. of State of Iowa, ex rel., Iowa DNR vs. Vermeer
Manufacturing Company, 99AG23542
District Court, Marion County, Law No. LACV087889
Process throughput:
A. The quantity of paint incinerated in this source shall not exceed 27.5 pounds per hour.
B. This source shall be fired by natural gas or propane only.
Reporting & Recordkeeping: See Facility-Wide Conditions and include:
The amount of paint incinerated in this unit, in pounds per hour.
Authority for Requirement: Iowa DNR Construction Permit 98-A-072-S1
Emission Point Characteristics
This emission point shall conform to the following conditions.
Stack Height (feet, from the ground): 35.2
Stack Diameter (inches): 6
Stack Exhaust Flow Rate (acfm): 1,578
Stack Temperature (°F): 1,322
Vertical, Unobstructed Discharge Required: Yes ^ No ~
Authority for Requirement: Iowa DNR Construction Permit 98-A-072-S1
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Periodic Monitoring Requirements
The owner/operator of this equipment shall comply with the following periodic monitoring
requirements.
Agency Approved Operation & Maintenance Plan Required? Yes ~ No |EI
Facility Maintained Operation & Maintenance Plan Required? Yes ~ No |EI
Authority for Requirement: 567 IAC 22.108(3)"b"
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Emission Point ID Number: W.F1
Associated Equipment
Associated Emission Unit ID Number:
W.F
Applicable Requirements
Emission Unit vented through this Emission Point: W.F
Emission Unit Description: Waste Solvent Still
Raw Material/Fuel: Recovered Paints, etc.
Rated Capacity: 4.58 gallons/hr
Emission Limits (lb/hr, gr/dscf, lb/MMBtu, % opacity, etc.)
The emissions from this emission point shall not exceed the following specified levels.
Pollutant: Volatile Organic Compounds (VOC)
Emission Limit: See Facility-Wide Conditions
Pollutant: Hazardous Air Pollutants (HAP)
Emission Limit: See Facility-Wide Conditions
Operational Limits & Requirements
The owner/operator of this equipment shall comply with the following operational limits and
requirements.
Reporting & Record keeping: See Facility-Wide Conditions and include:
A monthly and a twelve (12) month rolling total of the amount of solvent recovered, in
gallons.
Authority for Requirement: Iowa DNR Construction Permit 99-A-340
Emission Point Characteristics
This emission point shall conform to the following conditions.
Stack Height (feet, from the ground): 10
Stack Diameter (inches): 2
Stack Exhaust Flow Rate: Natural draft
Stack Temperature (°F): Ambient
Vertical, Unobstructed Discharge Required: Yes ~ No El
Authority for Requirement: Iowa DNR Construction Permit 99-A-340
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Periodic Monitoring Requirements
The owner/operator of this equipment shall comply with the following periodic monitoring
requirements.
Agency Approved Operation & Maintenance Plan Required? Yes ~ No |EI
Facility Maintained Operation & Maintenance Plan Required? Yes ~ No |EI
Authority for Requirement: 567 IAC 22.108(3)"b"
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Emission Point ID Number: W.F2
Associated Equipment
Associated Emission Unit ID Number:
W.F
Applicable Requirements
Emission Unit vented through this Emission Point: W.F
Emission Unit Description: Waste Solvent Still
Raw Material/Fuel: Recovered Paints, etc.
Rated Capacity: 4.58 gallons/hr
Emission Limits (lb/hr, gr/dscf, lb/MMBtu, % opacity, etc.)
The emissions from this emission point shall not exceed the following specified levels.
Pollutant: Volatile Organic Compounds (VOC)
Emission Limit: See Facility-Wide Conditions
Pollutant: Hazardous Air Pollutants (HAP)
Emission Limit: See Facility-Wide Conditions
Operational Limits & Requirements
The owner/operator of this equipment shall comply with the following operational limits and
requirements.
Reporting & Record keeping: See Facility-Wide Conditions and include:
A monthly and a twelve (12) month rolling total of the amount of solvent recovered, in
gallons.
Authority for Requirement: Iowa DNR Construction Permit 99-A-341
Emission Point Characteristics
This emission point shall conform to the following conditions.
Stack Height (feet, from the ground): 10
Stack Diameter (inches): 2
Stack Exhaust Flow Rate: Natural draft
Stack Temperature (°F): Ambient
Vertical, Unobstructed Discharge Required: Yes ~ No El
Authority for Requirement: Iowa DNR Construction Permit 99-A-341
Vermeer Manufacturing Co.
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Periodic Monitoring Requirements
The owner/operator of this equipment shall comply with the following periodic monitoring
requirements.
Agency Approved Operation & Maintenance Plan Required? Yes ~ No |EI
Facility Maintained Operation & Maintenance Plan Required? Yes ~ No |EI
Authority for Requirement: 567 IAC 22.108(3)"b"
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Emission Point ID Number: W.H
Associated Equipment
Associated Emission Unit ID Number: ...
W.H
Applicable Requirements
Emission Unit vented through this Emission Point: W.H
Emission Unit Description: Aerosol Can Crusher
Raw Material/Fuel: Aerosol Cans
Rated Capacity: 120 cans/hr
Emission Limits (lb/hr, gr/dscf, lb/MMBtu, % opacity, etc.)
The emissions from this emission point shall not exceed the following specified levels.
Pollutant: Volatile Organic Compounds (VOC)
Emission Limit: See Facility-Wide Conditions
Authority for Requirement: Iowa DNR Construction Permit 99-A-691
Pollutant: Hazardous Air Pollutants (HAP)
Emission Limit: See Facility-Wide Conditions
Emission Point Characteristics
This emission point shall conform to the following conditions.
Stack Height (feet, from the ground): 35
Stack Diameter (inches): 12
Stack Exhaust Flow Rate (scfm): 3,500
Stack Temperature (°F): Ambient
Vertical, Unobstructed Discharge Required: Yes ^ No ~
Authority for Requirement: Iowa DNR Construction Permit 99-A-691
Periodic Monitoring Requirements
The owner/operator of this equipment shall comply with the following periodic monitoring
requirements.
Agency Approved Operation & Maintenance Plan Required? Yes ~ No |EI
Facility Maintained Operation & Maintenance Plan Required? Yes ~ No |EI
Authority for Requirement: 567 IAC 22.108(3)"b"
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Emission Point ID Number: W.I
Associated Equipment
Associated Emission Unit ID Number: ..
W.I
Applicable Requirements
Emission Unit vented through this Emission Point: W.I
Emission Unit Description: Paint Hook Burn-Off Oven
Raw Material/Fuel: Natural Gas
Rated Capacity: 2.0 MMBtu/hr
Emission Limits (lb/hr, gr/dscf, lb/MMBtu, % opacity, etc.)
The emissions from this emission point shall not exceed the following specified levels.
Pollutant: Opacity
Emission Limit: 40
Authority for Requirement: 567 IAC 23.4(12)"b"
Iowa DNR Construction Permit 00-A-627
(1)No person shall allow, cause or permit the operation of an incinerator in a manner such that it
produces visible air contaminants in excess of 40 percent opacity; except that visible air
contaminants in excess of 60 percent opacity may be emitted for a period or period aggregating
not more than 3 minutes in any 60-minute period during operation breakdown or during the
cleaning of air pollution control equipment.
Pollutant: Particulate Matter
Emission Limit: 0.35 gr/dscf^
(1) Adjusted to 12% CO2
Authority for Requirement: 567 IAC 23.4(12)"a"
Iowa DNR Construction Permit 00-A-627
Pollutant: Sulfur Dioxide (SO2)
Emission Limit: 500 ppmv
Authority for Requirement: 567 IAC 23.3(3)"e"
Pollutant: Nitrogen Oxides (NOx)
Emission Limit: See Facility-Wide Conditions
Authority for Requirement: Iowa DNR Construction 00-A-627
Pollutant: Volatile Organic Compounds (VOC)
Emission Limit: See Facility-Wide Conditions
Authority for Requirement: Iowa DNR Construction Permit 00-A-627
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Pollutant:
Emission Limit:
Hazardous Air Pollutants (HAP)
See Facility-Wide Conditions
Compliance Testing Requirements
PM Iowa Compliance Sampling Manual*
The owner shall verify compliance with the emission limitations contained in Construction
Permit 00-A-627 within sixty (60) days after achieving maximum production rate and no later
than one hundred eighty (180) days after the startup date of the proposed equipment. The test
shall be conducted with the equipment operating in a manner representative of full rated
capacity. Failure to test at this maximum may be cause to limit the source to operating at the
level at which the compliance tests were conducted.
The owner shall furnish the DNR the following written notifications:
1. The date of intended startup at least ten (10) days before the equipment or control
equipment involved is placed into operation.
2. The actual date of startup postmarked within fifteen (15) days following the start of
operation.
Authority for Requirement: Iowa DNR Construction Permit 00-A-627
*The required stack testing was performed on October 17, 2000.
Operational Limits & Requirements
The owner/operator of this equipment shall comply with the following operational limits and
requirements.
Process throughput:
A. This burn-off oven shall be fired by natural gas or propane only.
B. The afterburner shall be operated whenever this unit is combusting waste.
C. The quantity of paint incinerated in this unit shall not exceed 70 pounds per hour.
Reporting & Recordkeeping: See Facility-Wide Conditions and include:
The amount of paint incinerated in this unit, in pounds per hour.
Authority for Requirement: Iowa DNR Construction Permit 00-A-627
Emission Point Characteristics
This emission point shall conform to the following conditions.
Stack Height (feet, from the ground): 35
Stack Opening (inches, diameter): 18
Exhaust Flow Rate (scfm): 952
Exhaust Temperature (°F): 1,322
Vertical, Unobstructed Discharge Required: Yes ~ No
Authority for Requirement: Iowa DNR Construction Permit 00-A-627
z
Vermeer Manufacturing Co.
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Periodic Monitoring Requirements
The owner/operator of this equipment shall comply with the following periodic monitoring
requirements.
Agency Approved Operation & Maintenance Plan Required? Yes ~ No |EI
Facility Maintained Operation & Maintenance Plan Required? Yes ~ No |EI
Authority for Requirement: 567 IAC 22.108(3)"b"
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Emission Point ID Number: F.SAND
Associated Equipment
Associated Emission Unit ID Number:
F.SAND
Applicable Requirements
Emission Unit vented through this Emission Point: F. SAND
Emission Unit Description: Sand Blasting Unit
Raw Material/Fuel: Silica Sand
Rated Capacity: 600 lb Sand/hr
Emission Limits (lb/hr, gr/dscf, lb/MMBtu, % opacity, etc.)
The emissions from this emission point shall not exceed the following specified levels.
Pollutant: Fugitive Dust
Emission Limit: No person shall allow, cause or permit any materials to be handled, transported
or stored; or a building, its appurtenances or a construction haul road to be used, constructed,
altered, repaired or demolished, without taking reasonable precautions to prevent a nuisance.
All persons shall take reasonable precautions to prevent the discharge of visible emissions of
fugitive dusts beyond the lot line of the property on which the emissions originate.
Authority for Requirement: 567 IAC 23.3(2)"c"
Periodic Monitoring Requirements
The owner/operator of this equipment shall comply with the following periodic monitoring
requirements.
Agency Approved Operation & Maintenance Plan Required? Yes ~ No |EI
Facility Maintained Operation & Maintenance Plan Required? Yes ~ No |EI
Authority for Requirement: 567 IAC 22.108(3)"b"
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Emission Point ID Number: F.SODA
Associated Equipment
Associated Emission Unit ID Number:
F.SODA
Applicable Requirements
Emission Unit vented through this Emission Point: F. SODA
Emission Unit Description: Soda Blasting Unit
Raw Material/Fuel: Abrasive Soda
Rated Capacity: 120 lb Soda/hr
Emission Limits (lb/hr, gr/dscf, lb/MMBtu, % opacity, etc.)
The emissions from this emission point shall not exceed the following specified levels.
Pollutant: Fugitive Dust
Emission Limit: No person shall allow, cause or permit any materials to be handled, transported
or stored; or a building, its appurtenances or a construction haul road to be used, constructed,
altered, repaired or demolished, without taking reasonable precautions to prevent a nuisance.
All persons shall take reasonable precautions to prevent the discharge of visible emissions of
fugitive dusts beyond the lot line of the property on which the emissions originate.
Authority for Requirement: 567 IAC 23.3(2)"c"
Periodic Monitoring Requirements
The owner/operator of this equipment shall comply with the following periodic monitoring
requirements.
Agency Approved Operation & Maintenance Plan Required? Yes ~ No |EI
Facility Maintained Operation & Maintenance Plan Required? Yes ~ No |EI
Authority for Requirement: 567 IAC 22.108(3)"b"
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IV. General Conditions
This permit is issued under the authority of the Iowa Code subsection 455B. 133(8) and in
accordance with 567 Iowa Administrative Code chapter 22.
Gl. Duty to Comply
1. The permittee must comply with all conditions of the Title V permit. Any permit
noncompliance constitutes a violation of the Act and is grounds for enforcement action; for a
permit termination, revocation and reissuance, or modification; or for denial of a permit renewal
application. 567IAC 22.108(9)"a"
2. Any compliance schedule shall be supplemental to, and shall not sanction noncompliance
with, the applicable requirements on which it is based. 567IAC 22.105 (2)"h"3
3. Where an applicable requirement of the Act is more stringent than an applicable requirement
of regulations promulgated under Title IV of the Act, both provisions shall be enforceable by the
administrator and are incorporated into this permit. 567IAC 22.108 (l)"b"
4. Unless specified as either "state enforceable only" or "local program enforceable only", all
terms and conditions in the permit, including provisions to limit a source's potential to emit, are
enforceable by the administrator and citizens under the Act. 567 IAC 22.108 (14)
5. It shall not be a defense for a permittee, in an enforcement action, that it would have been
necessary to halt or reduce the permitted activity in order to maintain compliance with the
conditions of the permit. 567 IAC 22.108 (9)"b"
G2. Permit Expiration
1. Except as provided in 567 IAC 22.104, the expiration of this permit terminates the permittee's
right to operate unless a timely and complete application has been submitted for renewal. Any
testing required for renewal shall be completed before the application is submitted. 567 IAC
22.116(2)
2. To be considered timely, the owner, operator, or designated representative (where applicable)
of each source required to obtain a Title V permit shall present or mail the Air Quality Bureau,
Iowa Department of Natural Resources, Air Quality Bureau, 7900 Hickman Rd, Suite #1,
Urbandale, Iowa 50322, four or more copies of a complete permit application, at least 6 months
but not more than 18 months prior to the date of permit expiration. The definition of a complete
application is as indicated in 567 IAC 22.105(2). 567 IAC 22.105
G3. Certification Requirement for Title V Related Documents
Any application, report, compliance certification or other document submitted pursuant to this
permit shall contain certification by a responsible official of truth, accuracy, and completeness.
All certifications shall state that, based on information and belief formed after reasonable
inquiry, the statements and information in the document are true, accurate, and complete. 567
IAC 22.107 (4)
G4. Annual Compliance Certification
By March 31 of each year, the permittee shall submit compliance certifications for the previous
calendar year. The certifications shall include descriptions of means to monitor the compliance
status of all emissions sources including emissions limitations, standards, and work practices in
accordance with applicable requirements. The certification for a source shall include the
identification of each term or condition of the permit that is the basis of the certification; the
compliance status; whether compliance was continuous or intermittent; the method(s) used for
determining the compliance status of the source, currently and over the reporting period
consistent with all applicable department rules. For sources determined not to be in compliance
at the time of compliance certification, a compliance schedule shall be submitted which provides
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for periodic progress reports, dates for achieving activities, milestones, and an explanation of
why any dates were missed and preventive or corrective measures. The compliance certification
shall be submitted to the administrator, director, and the appropriate DNR Field office. 567IAC
22.108 (15) "e"
G5. Semi-Annual Monitoring Report
By March 31 and September 30 of each year, the permittee shall submit a report of any
monitoring required under this permit for the 6 month periods of July 1 to December 31 and
January 1 to June 30, respectively. All instances of deviations from permit requirements must be
clearly identified in these reports, and the report must be signed by a responsible official,
consistent with 567 IAC 22.107(4). The semi-annual monitoring report shall be submitted to the
director and the appropriate DNR Field office. 567 IAC 22.108 (5)
G6. Annual Fee
1. The permittee is required under subrule 567 IAC 22.106 to pay an annual fee based on the
total tons of actual emissions of each regulated air pollutant. Beginning July 1, 1996, Title V
operating permit fees will be paid on July 1 of each year. The fee shall be based on emissions for
the previous calendar year.
2. The fee amount shall be calculated based on the first 4,000 tons of each regulated air pollutant
emitted each year. The fee to be charged per ton of pollutant will be available from the
department by June 1 of each year. The Responsible Official will be advised of any change in the
annual fee per ton of pollutant.
3. The following forms shall be submitted annually by March 31 documenting actual emissions
for the previous calendar year.
a. Form 1.0 "Facility Identification";
b. Form 4.0 "Emissions unit-actual operations and emissions" for each emission unit;
c. Form 5.0 "Title V annual emissions summary/fee"; and
d. Part 3 "Application certification."
4. The fee shall be submitted annually by July 1. The fee shall be submitted with the following
forms:
a. Form 1.0 "Facility Identification";
b. Form 5.0 "Title V annual emissions summary/fee";
c. Part 3 "Application certification."
5. If there are any changes to the emission calculation form, the department shall make revised
forms available to the public by January 1. If revised forms are not available by January 1, forms
from the previous year may be used and the year of emissions documented changed. The
department shall calculate the total statewide Title V emissions for the prior calendar year and
make this information available to the public no later than April 30 of each year.
6. Phase I acid rain affected units under section 404 of the Act shall not be required to pay a fee
for emissions which occur during the years 1993 through 1999 inclusive.
7. The fee for a portable emissions unit or stationary source which operates both in Iowa and out
of state shall be calculated only for emissions from the source while operating in Iowa.
8. Failure to pay the appropriate Title V fee represents cause for revocation of the Title V permit
as indicated in 567 IAC 22.115(l)"d".
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G7. Inspection of Premises, Records, Equipment, Methods and Discharges
Upon presentation of proper credentials and any other documents as may be required by law, the
permittee shall allow the director or the director's authorized representative to:
1. Enter upon the permittee's premises where a Title V source is located or emissions-related
activity is conducted, or where records must be kept under the conditions of the permit;
2. Have access to and copy, at reasonable times, any records that must be kept under the
conditions of the permit;
3. Inspect, at reasonable times, any facilities, equipment (including monitoring and air pollution
control equipment), practices, or operations regulated or required under the permit; and
4. Sample or monitor, at reasonable times, substances or parameters for the purpose of ensuring
compliance with the permit or other applicable requirements. 567IAC 22.108 (15)"b"
G8. Duty to Provide Information
The permittee shall furnish to the director, within a reasonable time, any information that the
director may request in writing to determine whether cause exists for modifying, revoking and
reissuing, or terminating the permit or to determine compliance with the permit. Upon request,
the permittee also shall furnish to the director copies of records required to be kept by the permit,
or for information claimed to be confidential, the permittee shall furnish such records directly to
the administrator of EPA along with a claim of confidentiality. 567 IAC 22.108 (9)"e"
G9. General Maintenance and Repair Duties
The owner or operator of any air emission source or control equipment shall:
1. Maintain and operate the equipment or control equipment at all times in a manner consistent
with good practice for minimizing emissions.
2. Remedy any cause of excess emissions in an expeditious manner.
3. Minimize the amount and duration of any excess emission to the maximum extent possible
during periods of such emissions. These measures may include but not be limited to the use of
clean fuels, production cutbacks, or the use of alternate process units or, in the case of utilities,
purchase of electrical power until repairs are completed.
4. Schedule, at a minimum, routine maintenance of equipment or control equipment during
periods of process shutdowns to the maximum extent possible. 567 IAC 24.2(1)
G10. Recordkeeping Requirements for Compliance Monitoring
1. In addition to any source specific recordkeeping requirements contained in this permit, the
permittee shall maintain the following compliance monitoring records, where applicable:
a. The date, place and time of sampling or measurements
b. The date the analyses were performed.
c. The company or entity that performed the analyses.
d. The analytical techniques or methods used.
e. The results of such analyses; and
f. The operating conditions as existing at the time of sampling or measurement.
g. The records of quality assurance for continuous compliance monitoring systems
(including but not limited to quality control activities, audits and calibration drifts.)
2. The permittee shall retain records of all required compliance monitoring data and support
information for a period of at least 5 years from the date of compliance monitoring sample,
measurement report or application. Support information includes all calibration and maintenance
records and all original strip chart recordings for continuous compliance monitoring, and copies
of all reports required by the permit.
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3. For any source which in its application identified reasonably anticipated alternative operating
scenarios, the permittee shall:
a. Comply with all terms and conditions of this permit specific to each alternative
scenario.
b. Maintain a log at the permitted facility of the scenario under which it is operating.
c. Consider the permit shield, if provided in this permit, to extend to all terms and
conditions under each operating scenario. 567IAC 22.108(4), 567IAC 22.108(12)
Gil. Prevention of Accidental Release: Risk Management Plan Notification and
Compliance Certification
If the permittee is required to develop and register a risk management plan pursuant to section
112(r) of the Act, the permittee shall notify the department of this requirement. The plan shall be
filed with all appropriate authorities by the deadline specified by EPA. A certification that this
risk management plan is being properly implemented shall be included in the annual compliance
certification of this permit. 567 IAC 22.108(6)
G12. Hazardous Release
The permittee must report any situation involving the actual, imminent, or probable release of a
hazardous substance into the atmosphere which, because of the quantity, strength and toxicity of
the substance, creates an immediate or potential danger to the public health, safety or to the
environment. A verbal report shall be made to the department at (515) 281-8694 and to the local
police department or the office of the sheriff of the affected county as soon as possible but not
later than six hours after the discovery or onset of the condition. This verbal report must be
followed up with a written report as indicated in 567 IAC 131.2(2). 567 IAC Chapter 131-State
Only
G13. Excess Emissions and Excess Emissions Reporting Requirements
1. Excess Emissions. Excess emission during a period of startup, shutdown, or cleaning of
control equipment is not a violation of the emission standard if the startup, shutdown or cleaning
is accomplished expeditiously and in a manner consistent with good practice for minimizing
emissions. Cleaning of control equipment which does not require the shutdown of the process
equipment shall be limited to one six-minute period per one-hour period. An incident of excess
emission (other than an incident during startup, shutdown or cleaning of control equipment) is a
violation. If the owner or operator of a source maintains that the incident of excess emission was
due to a malfunction, the owner or operator must show that the conditions which caused the
incident of excess emission were not preventable by reasonable maintenance and control
measures. Determination of any subsequent enforcement action will be made following review
of this report. If excess emissions are occurring, either the control equipment causing the excess
emission shall be repaired in an expeditious manner or the process generating the emissions shall
be shutdown within a reasonable period of time. An expeditious manner is the time necessary to
determine the cause of the excess emissions and to correct it within a reasonable period of time.
A reasonable period of time is eight hours plus the period of time required to shut down the
process without damaging the process equipment or control equipment. In the case of an electric
utility, a reasonable period of time is eight hours plus the period of time until comparable
generating capacity is available to meet consumer demand with the affected unit out of service,
unless, the director shall, upon investigation, reasonably determine that continued operation
constitutes an unjustifiable environmental hazard and issue an order that such operation is not in
the public interest and require a process shutdown to commence immediately.
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2. Excess Emissions Reporting
a. Oral Reporting of Excess Emissions. An incident of excess emission (other than an
incident of excess emission during a period of startup, shutdown, or cleaning) shall be
reported to the appropriate field office of the department within eight hours of, or at the
start of the first working day following the onset of the incident. The reporting exemption
for an incident of excess emission during startup, shutdown or cleaning does not relieve
the owner or operator of a source with continuous monitoring equipment of the obligation
of submitting reports required in 567-subrule 25.1(6). An oral report of excess emission
is not required for a source with operational continuous monitoring equipment (as
specified in 567-subrule 25.1(1) ) if the incident of excess emission continues for less
than 30 minutes and does not exceed the applicable visible emission standard by more
than 10 percent opacity. The oral report may be made in person or by telephone and shall
include as a minimum the following:
i. The identity of the equipment or source operation from which the excess
emission originated and the associated stack or emission point.
ii. The estimated quantity of the excess emission.
iii. The time and expected duration of the excess emission.
iv. The cause of the excess emission.
v. The steps being taken to remedy the excess emission.
vi. The steps being taken to limit the excess emission in the interim period.
b. Written Reporting of Excess Emissions. A written report of an incident of excess
emission shall be submitted as a follow-up to all required oral reports to the department
within seven days of the onset of the upset condition, and shall include as a minimum the
following:
i. The identity of the equipment or source operation point from which the excess
emission originated and the associated stack or emission point.
ii. The estimated quantity of the excess emission.
iii. The time and duration of the excess emission.
iv. The cause of the excess emission.
v. The steps that were taken to remedy and to prevent the recurrence of the
incident of excess emission.
vi. The steps that were taken to limit the excess emission.
vii. If the owner claims that the excess emission was due to malfunction,
documentation to support this claim. 567IAC 24.1(l)-567 IAC 24.1(4)
3. Emergency Defense for Excess Emissions. For the purposes of this permit, an "emergency"
means any situation arising from sudden and reasonably unforeseeable events beyond the control
of the source, including acts of God, which requires immediate corrective action to restore
normal operation, and that causes the source to exceed a technology-based emission limitation
under the permit due to unavoidable increases in emissions attributable to the emergency. An
emergency shall not include non-compliance, to the extent caused by improperly designed
equipment, lack of preventive maintenance, careless or improper operation or operator error. An
emergency constitutes an affirmative defense to an action brought for non-compliance with
technology based limitations if it can be demonstrated through properly signed contemporaneous
operating logs or other relevant evidence that:
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a. An emergency occurred and that the permittee can identify the cause(s) of the
emergency;
b. The facility at the time was being properly operated;
c. During the period of the emergency, the permittee took all reasonable steps to
minimize levels of emissions that exceeded the emissions standards or other requirements
of the permit; and
d. The permittee submitted notice of the emergency to the director by certified mail
within two working days of the time when the emissions limitations were exceeded due
to the emergency. This notice must contain a description of the emergency, any steps
taken to mitigate emissions, and corrective actions taken. 567IAC 22.108(16)
G14. Permit Deviation Reporting Requirements
A deviation is any failure to meet a term, condition or applicable requirement in the permit.
Reporting requirements for deviations that result in a hazardous release or excess emissions have
been indicated above (see G12 and G13). Unless more frequent deviation reporting is specified
in the permit, any other deviation shall be documented in the semi-annual monitoring report and
the annual compliance certification (see G4 and G5). 567IAC 22.108(5)"b"
G15. Notification Requirements for Sources That Become Subject to NSPS and NESHAP
Regulations
During the term of this permit, the permittee must notify the department of any source that
becomes subject to a standard or other requirement under 567-subrule 23.1(2) (standards of
performance of new stationary sources) or section 111 of the Act; or 567-subrule 23.1(3)
(emissions standards for hazardous air pollutants), 567-subrule 23.1(4) (emission standards for
hazardous air pollutants for source categories) or section 112 of the Act. This notification shall
be submitted in writing to the department pursuant to the notification requirements in 40 CFR
Section 60.7, 40 CFR Section 61.07, and/or 40 CFR Section 63.9. 567IAC 23.1(2), 567IAC
23.1(3), 567 IAC 23.1(4)
G16. Requirements for Making Changes to Emission Sources That Do Not Require Title V
Permit Modification
1. Off Permit Changes to a Source. Pursuant to section 502(b)(10) of the CAAA, the permittee
may make changes to this installation/facility without revising this permit if:
a. The changes are not major modifications under any provision of any program required
by section 110 of the Act, modifications under section 111 of the act, modifications under
section 112 of the act, or major modifications as defined in 567 IAC Chapter 22.
b. The changes do not exceed the emissions allowable under the permit (whether
expressed therein as a rate of emissions or in terms of total emissions);
c. The changes are not modifications under any provisions of Title I of the Act and the
changes do not exceed the emissions allowable under the permit (whether expressed
therein as a rate of emissions or as total emissions);
d. The changes are not subject to any requirement under Title IV of the Act.
e. The changes comply with all applicable requirements.
f. For such a change, the permitted source provides to the department and the
administrator by certified mail, at least 30 days in advance of the proposed change, a
written notification, including the following, which must be attached to the permit by the
source, the department and the administrator:
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i. A brief description of the change within the permitted facility,
ii. The date on which the change will occur,
iii. Any change in emission as a result of that change,
iv. The pollutants emitted subject to the emissions trade
v. If the emissions trading provisions of the state implementation plan are
invoked, then Title V permit requirements with which the source shall comply; a
description of how the emissions increases and decreases will comply with the
terms and conditions of the Title V permit.
vi. A description of the trading of emissions increases and decreases for the
purpose of complying with a federally enforceable emissions cap as specified in
and in compliance with the Title V permit; and
vii. Any permit term or condition no longer applicable as a result of the change.
567IAC 22.110(1)
2. Such changes do not include changes that would violate applicable requirements or
contravene federally enforceable permit terms and conditions that are monitoring (including test
methods), record keeping, reporting, or compliance certification requirements. 567 IAC
22.110(2)
3. Notwithstanding any other part of this rule, the director may, upon review of a notice, require
a stationary source to apply for a Title V permit if the change does not meet the requirements of
subrule 22.110(1). 567 IAC 22.110(3)
4. The permit shield provided in subrule 22.108(18) shall not apply to any change made
pursuant to this rule. Compliance with the permit requirements that the source will meet using
the emissions trade shall be determined according to requirements of the state implementation
plan authorizing the emissions trade. 567 IAC 22.110(4)
5. Aggregate Insignificant Emissions. The permittee shall not construct, establish or operate any
new insignificant activities or modify any existing insignificant activities in such a way that the
emissions from these activities no longer meet the criteria of aggregate insignificant emissions. If
the aggregate insignificant emissions are expected to be exceeded, the permittee shall submit the
appropriate permit modification and receive approval prior to making any change. 567 IAC
22.103(2)
6. No permit revision shall be required, under any approved economic incentives, marketable
permits, emissions trading and other similar programs or processes, for changes that are provided
for in this permit. 567 IAC 22.108(11)
G17. Duty to Modify a Title V Permit
1. Administrative Amendment.
a. An administrative permit amendment is a permit revision that is required to do any of
the following:
i. Correct typographical errors
ii. Identify a change in the name, address, or telephone number of any person
identified in the permit, or provides a similar minor administrative change at the
source;
iii. Require more frequent monitoring or reporting by the permittee; or
iv. Allow for a change in ownership or operational control of a source where the
director determines that no other change in the permit is necessary, provided that
a written agreement containing a specific date for transfer of permit responsibility,
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coverage and liability between the current and new permittee has been submitted
to the director.
b. The permittee may implement the changes addressed in the request for an
administrative amendment immediately upon submittal of the request. The request shall
be submitted to the director.
c. Administrative amendments to portions of permits containing provisions pursuant to
Title IV of the Act shall be governed by regulations promulgated by the administrator
under Title IV of the Act.
2. Minor Permit Modification.
a. Minor permit modification procedures may be used only for those permit modifications
that do any of the following:
i. Do not violate any applicable requirements
ii. Do not involve significant changes to existing monitoring, reporting or
recordkeeping requirements in the Title V permit.
iii. Do not require or change a case by case determination of an emission
limitation or other standard, or increment analysis.
iv. Do not seek to establish or change a permit term or condition for which there
is no corresponding underlying applicable requirement and that the source has
assumed in order to avoid an applicable requirement to which the source would
otherwise be subject. Such terms and conditions include any federally enforceable
emissions caps which the source would assume to avoid classification as a
modification under any provision under Title I of the Act; and an alternative
emissions limit approved pursuant to regulations promulgated under section
112(i)(5) of the Act.;
v. Are not modifications under any provision of Title I of the Act; and
vi. Are not required to be processed as significant modification.
b. An application for minor permit revision shall be on the minor Title V modification
application form and shall include at least the following:
i. A description of the change, the emissions resulting from the change, and any
new applicable requirements that will apply if the change occurs.
ii. The permittee's suggested draft permit
iii. Certification by a responsible official, pursuant to 567 IAC 22.107(4), that the
proposed modification meets the criteria for use of a minor permit modification
procedures and a request that such procedures be used; and
iv. Completed forms to enable the department to notify the administrator and the
affected states as required by 567 IAC 22.107(7).
c. The permittee may make the change proposed in its minor permit modification
application immediately after it files the application. After the permittee makes this
change and until the director takes any of the actions specified in 567 IAC 22.112(4) "a"
to "c", the permittee must comply with both the applicable requirements governing the
change and the proposed permit terms and conditions. During this time, the permittee
need not comply with the existing permit terms and conditions it seeks to modify.
However, if the permittee fails to comply with its proposed permit terms and conditions
during this time period, existing permit term terms and conditions it seeks to modify may
subject the facility to enforcement action.
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3. Significant Permit Modification. Significant Title V modification procedures shall be used for
applications requesting Title V permit modifications that do not qualify as minor Title V
modifications or as administrative amendments. These include but are not limited to all
significant changes in monitoring permit terms, every relaxation of reporting or recordkeeping
permit terms, and any change in the method of measuring compliance with existing
requirements. Significant Title V modifications shall meet all requirements of 567 IAC Chapter
22, including those for applications, public participation, review by affected states, and review
by the administrator, and those requirements that apply to Title V issuance and renewal. 567IAC
22.111-567 IAC 22.113 The permittee shall submit an application for a significant permit
modification at least 6 months prior to the date of the proposed modification. 567 IAC
22.105(l)a(4)
G18. Duty to Obtain Construction Permits
Unless exempted under 567 IAC 22.1(2), the permittee must not construct, install, reconstruct, or
alter any equipment, control equipment or anaerobic lagoon without first obtaining a
construction permit, conditional permit, or permit pursuant to 567 IAC 22.8, or permits required
pursuant to 567 IAC 22.4 and 567 IAC 22.5. Such permits shall be obtained prior to the initiation
of construction, installation or alteration of any portion of the stationary source. 567 IAC 22.1(1)
G19. Asbestos
The permittee shall comply with 567 IAC 23.1(3)"a", and 567 IAC 23.2(3)"g" when conducting
any renovation or demolition activities at the facility. 567IAC 23.1(3)"a", and567IAC 23.2
G20. Open Burning
The permittee is prohibited from conducting open burning, except as may be allowed by 567
IAC 23.2. 567IAC 23.2 excevt 23.2(3)"h"; 567IAC 23.2(3)"h" - State Only
G21. Acid Rain (Title IV) Emissions Allowances
The permittee shall not exceed any allowances that it holds under Title IV of the Act or the
regulations promulgated there under. Annual emissions of sulfur dioxide in excess of the number
of allowances to emit sulfur dioxide held by the owners and operators of the unit or the
designated representative of the owners and operators is prohibited. Exceedences of applicable
emission rates are prohibited. "Held" in this context refers to both those allowances assigned to
the owners and operators by USEPA, and those allowances supplementally acquired by the
owners and operators. The use of any allowance prior to the year for which it was allocated is
prohibited. Contravention of any other provision of the permit is prohibited. 567 IAC 22.108(7)
G22. Stratospheric Ozone and Climate Protection (Title VI) Requirements
1. The permittee shall comply with the standards for labeling of products using ozone-depleting
substances pursuant to 40 CFR Part 82, Subpart E:
a. All containers in which a class I or class II substance is stored or transported, all
products containing a class I substance, and all products directly manufactured with a
class I substance must bear the required warning statement if it is being introduced into
interstate commerce pursuant to § 82.106.
b. The placement of the required warning statement must comply with the requirements
pursuant to § 82.108.
c. The form of the label bearing the required warning statement must comply with the
requirements pursuant to § 82.110.
d. No person may modify, remove, or interfere with the required warning statement
except as described in § 82.112.
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2. The permittee shall comply with the standards for recycling and emissions reduction pursuant
to 40 CFR Part 82, Subpart F, except as provided for MVACs in Subpart B:
a. Persons opening appliances for maintenance, service, repair, or disposal must comply
with the required practices pursuant to § 82.156.
b. Equipment used during the maintenance, service, repair, or disposal of appliances must
comply with the standards for recycling and recovery equipment pursuant to § 82.158.
c. Persons performing maintenance, service, repair, or disposal of appliances must be
certified by an approved technician certification program pursuant to § 82.161.
d. Persons disposing of small appliances, MVACs, and MVAC-like appliances must
comply with reporting and recordkeeping requirements pursuant to § 82.166. ("MVAC-
like appliance" as defined at § 82.152)
e. Persons owning commercial or industrial process refrigeration equipment must comply
with the leak repair requirements pursuant to § 82.156.
f. Owners/operators of appliances normally containing 50 or more pounds of refrigerant
must keep records of refrigerant purchased and added to such appliances pursuant to §
82.166.
3. If the permittee manufactures, transforms, imports, or exports a class I or class II substance,
the permittee is subject to all the requirements as specified in 40 CFR part 82, Subpart A,
Production and Consumption Controls.
4. If the permittee performs a service on motor (fleet) vehicles when this service involves ozone-
depleting substance refrigerant (or regulated substitute substance) in the motor vehicle air
conditioner (MVAC), the permittee is subject to all the applicable requirements as specified in
40 CFR part 82, Subpart B, Servicing of Motor Vehicle Air Conditioners. The term "motor
vehicle" as used in Subpart B does not include a vehicle in which final assembly of the vehicle
has not been completed. The term "MVAC" as used in Subpart B does not include the air-tight
sealed refrigeration system used as refrigerated cargo, or system used on passenger buses using
HCFC-22 refrigerant,
5. The permittee shall be allowed to switch from any ozone-depleting substance to any
alternative that is listed in the Significant New Alternatives Program (SNAP) promulgated
pursuant to 40 CFR part 82, Subpart G, Significant New Alternatives Policy Program. 40 CFR
part 82
G23. Permit Reopenings
1. This permit may be modified, revoked, reopened, and reissued, or terminated for cause. The
filing of a request by the permittee for a permit modification, revocation and reissuance, or
termination, or of a notification of planned changes or anticipated noncompliance does not stay
any permit condition. 567IAC 22.108(9)"c"
2. Additional applicable requirements under the Act become applicable to a major part 70 source
with a remaining permit term of 3 or more years. Revisions shall be made as expeditiously as
practicable, but not later than 18 months after the promulgation of such standards and
regulations.
a. Reopening and revision on this ground is not required if the permit has a remaining
term of less than three years;
b. Reopening and revision on this ground is not required if the effective date of the
requirement is later than the date on which the permit is due to expire, unless the original
permit or any of its terms and conditions have been extended pursuant to 40 CFR
70.4(b)(10)(i) or (ii) as amended to June 25, 1993.
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c. Reopening and revision on this ground is not required if the additional applicable
requirements are implemented in a general permit that is applicable to the source and the
source receives approval for coverage under that general permit. 567IAC 22.108(17) "a",
567IAC 22.108(17)"b"
3. A permit shall be reopened and revised under any of the following circumstances:
a. The department receives notice that the administrator has granted a petition for
disapproval of a permit pursuant to 40 CFR 70.8(d) as amended to June 25, 1993,
provided that the reopening may be stayed pending judicial review of that determination;
b. The department or the administrator determines that the Title V permit contains a
material mistake or that inaccurate statements were made in establishing the emissions
standards or other terms or conditions of the Title V permit;
c. Additional applicable requirements under the Act become applicable to a Title V
source, provided that the reopening on this ground is not required if the permit has a
remaining term of less than three years, the effective date of the requirement is later than
the date on which the permit is due to expire, or the additional applicable requirements
are implemented in a general permit that is applicable to the source and the source
receives approval for coverage under that general permit. Such a reopening shall be
complete not later than 18 months after promulgation of the applicable requirement.
d. Additional requirements, including excess emissions requirements, become applicable
to a Title IV affected source under the acid rain program. Upon approval by the
administrator, excess emissions offset plans shall be deemed to be incorporated into the
permit.
e. The department or the administrator determines that the permit must be revised or
revoked to ensure compliance by the source with the applicable requirements. 567 IAC
22.114(1)
4. Proceedings to reopen and reissue a Title V permit shall follow the procedures applicable to
initial permit issuance and shall effect only those parts of the permit for which cause to reopen
exists. 567 IAC 22.114(2)
G24. Permit Shield
Compliance with the conditions of this permit shall be deemed compliance with the applicable
requirements included in this permit as of the date of permit issuance.
This permit shield shall not alter or affect the following:
1. The provisions of section 303 of the Act (emergency orders), including the authority of the
administrator under that section;
2. The liability of an owner or operator of a source for any violation of applicable requirements
prior to or at the time of permit issuance;
3. The applicable requirements of the acid rain program, consistent with section 408(a) of the
Act;
4. The ability of the department or the administrator to obtain information from the facility
pursuant to section 114 of the Act. 567 IAC 22.108 (18)
G25. Severability
The provisions of this permit are severable and if any provision or application of any provision is
found to be invalid by this department or a court of law, the application of such provision to
other circumstances, and the remainder of this permit, shall not be affected by such finding. 567
IAC 22.108 (8)
Vermeer Manufacturing Co.
155
99-TV-052-M001
-------
G26. Property Rights
The permit does not convey any property rights of any sort, or any exclusive privilege. 567IAC
22.108 (9)"d"
G27. Transferability
This permit is not transferable from one source to another. If title to the facility or any part of it
is transferred, an administrative amendment to the permit must be sought to determine
transferability of the permit. 567 IAC 22.111 (l)"d"
G28. Disclaimer
No review has been undertaken on the engineering aspects of the equipment or control
equipment other than the potential of that equipment for reducing air contaminant emissions.
567IAC 22.3(3)"c"
G29. Notification and Reporting Requirements for Stack Tests or Monitor Certification
The permittee shall notify the department's stack test contact in writing not less than 30 days
before a required test or performance evaluation of a continuous emission monitor is performed
to determine compliance with an applicable requirement. For the department to consider test
results a valid demonstration of compliance with applicable rules or a permit condition, such
notice shall be given. Such notice shall include the time, the place, the name of the person who
will conduct the test and other information as required by the department. Unless specifically
waived by the department's stack test contact, a pretest meeting shall be held not later than 15
days prior to conducting the compliance demonstration. The department may accept a testing
protocol in lieu of a pretest meeting. A representative of the department shall be permitted to
witness the tests. Results of the tests shall be submitted in writing to the department's stack test
contact in the form of a comprehensive report within six weeks of the completion of the testing.
Compliance tests conducted pursuant to this permit shall be conducted with the source operating
in a normal manner at its maximum continuous output as rated by the equipment manufacturer,
or the rate specified by the owner as the maximum production rate at which the source shall be
operated. In cases where compliance is to be demonstrated at less than the maximum continuous
output as rated by the equipment manufacturer, and it is the owner's intent to limit the capacity to
that rating, the owner may submit evidence to the department that the source has been physically
altered so that capacity cannot be exceeded, or the department may require additional testing,
continuous monitoring, reports of operating levels, or any other information deemed necessary
by the department to determine whether such source is in compliance.
Stack test notifications, reports and correspondence shall be sent to:
Stack Test Review Coordinator
Iowa DNR, Air Quality Bureau
7900 Hickman Road, Suite #1
Urbandale, IA 50322
(515) 242-6001
Within Polk and Linn Counties, stack test notifications, reports and correspondence shall also be
directed to the supervisor of the respective county air pollution program.
567 IAC 25.1(7) "a", 567IAC 25.1(9)
Vermeer Manufacturing Co.
156
99-TV-052-M001
-------
G30. Prevention of Air Pollution Emergency Episodes
The permittee shall comply with the provisions of 567 IAC Chapter 26 in the prevention of
excessive build-up of air contaminants during air pollution episodes, thereby preventing the
occurrence of an emergency due to the effects of these contaminants on the health of persons.
567 IAC 26.1(1)
G31. Contacts List
The current address and phone number for reports and notifications to the EPA administrator is:
Chief of Air Permits
EPA Region 7
Air Permits and Compliance Branch
901 N. 5th Street
Kansas City, KS 66101
(913)551-7020
The current address and phone number for reports and notifications to the department or the
Director is:
Chief, Air Quality Bureau
Iowa Department of Natural Resources
7900 Hickman Road, Suite #1
Urbandale, IA 50322
(515) 242-5100
Reports or notifications to the DNR Field Offices or local programs shall be directed to the
supervisor at the appropriate field office or local program. Current addresses and phone numbers
are:
Field Office 1
909 West Main - Suite 4
Manchester, IA 52057
(319) 927-2640
Field Office 2
P.O. Box 1443
2300-15th St., SW
Mason City, IA 50401
(641)424-4073
Field Office 3
1900 N. Grand Ave
Spencer, IA 51301
(712) 262-4177
1401 Sunnyside Lane
Atlantic, IA 50022
(712) 243-1934
Field Office 4
Field Office 5
Field Office 6
1004 W. Madison
Washington, IA 52353
(319) 653-2135
401 SW 7 Street, Suite I
Des Moines, IA 50309
(515) 725-0268
rth
Polk County Public Health Dept.
Air Quality Division
Linn County Public Health Dept.
Air Pollution Control Division
501 13th St., NW
Cedar Rapids, IA 52405
(319) 892-6000
5895 NE 14th St.
Des Moines, IA 50313
(515) 286-3351
Vermeer Manufacturing Co.
157
99-TV-052-M001
-------
V. Appendix A
State of Iowa, ex rel., Iowa DNR vs. Vermeer Manufacturing Company, 99AG23542, District
Court, Marion County, Law No. LACV087889 (attached)
Vermeer Manufacturing Co.
158
99-TV-052-M001
-------
VI. Appendix B: DNR Air Quality Policy 3-b-08, Opacity Limits
Vermeer Manufacturing Co.
159
99-TV-052-M001
-------
Iowa department of natural Resources
Iowa EASY Air
ELECTRONIC PERMIT APPLICATION SYSTEM
What? Introducing Iowa EASY Air (Environmental Application System), a convenient, efficient way to submit air quality
permit applications. Recognizing the need to reduce industry's time and costs involved in applying for air quality
permits, the Department of Natural Resources (DNR) entered into a contract with enfoTech & Consulting, Inc. to develop
a modern electronic permit application system. The new system will allow applicants to quickly submit both air quality
construction permit and Title V operating permit applications. The new online system will be customized for air quality
programs, adaptable to changing business needs and scalable for use by other DNR programs.
Industry Recommendations: In the spring of 2016, 66 stakeholders from business, industry and consulting firms met to
detail their needs for a new electronic application system. Their vision reduces redundant data entry, increases data
accuracy, saves time and cuts costs during application preparation and submittal, and speeds delivery of final permits.
Improved Service: Iowa's investment in a customized electronic application system will fulfil! that vison by reducing
maintenance and support costs. Streamlining the DNR's ability to review and issue these complex air permits will
provide better customer service to meet the evolving needs of industry.
The DNR's existing electronic application system is more than 17 years oid and is seldom used (94 percent of
applications are received on paper). It was written with now outdated software, is difficult to use and does not meet
minimum federal electronic reporting standards.
How Can I Be Involved? Stakeholders will be asked to preview the system in spring 2019 and help test the system in
summer 2019. DNR will provide progress updates during the entire development process.
When Will the System be Ready to Use? The DNR expects the system to be ready for use no later than Dec. 1, 2019.
Engaged
Stakeholders
Notice of Intent
to Award to
enfoTech
Project Funding
Secured
Continue to
Implement
Project Plan
Gathered
Business
Requirments
Requested &
Evaluated
Proposal
Secure Project
Funding
Finalized Vendor
Services
Agreement
System Testing
& Data QA
Implement
Project Plan
Iowa EASY Air
Online (Dec. 1)
How is the System Funded?
On May 2, 2018, the Iowa
General Assembly passed a
bill (Senate File 2414)
appropriating $954,000 to
DNR to finance the
electronic application
project. $728,000 will be
used to pay for the contract
with enfoTech Consulting,
Inc. The remaining $226,000
wili be used to fund the
project manager, Office of
the Chief Information Officer
(OCIO) support, and
hardware.
More Information: Find out more about the electronic permit application system on the DNR's eAirServices webpage.
Stay current on new developments by signing up for eAirServices Updates, the Air Quality technical emails that go direct
to your inbox.
December 2018
-------
Alex Murphy, PSM2,
Public Information Officer
Bureau Chief, 515-725-8219
Communications
Section
Records
Section
Records
Section
Shannon Hafner
Info Spec 2, Fisheries
515-725-8241
JulieTack
Info Spec 3, Parks
515-725-8276
Karen Grimes
Info Spec 2
Air Quality, Field Services
515-725-8279
Mick Klemesrud
Info Spec 2, Wildlife
515-725-8280
Tracy Fahrion
Info Spec 2, Web Services
515-725-8277
Jessie Brown
Info Spec 2
Land Quality, Water Quality
Social media
515-725-8278
Kati Bainter
Info Spec 3, Art Director
515-725-8296
Brian Button
Info Spec 3, Magazine Editor
515-725-8286
Vacant,
Info Spec 2
Renae Girdler
AA2 Team Leader
515-725-8480
Peggy El scott
Clerk Specialist
515-725-8218
Allison Stiles
Clerk-Advanced
515-725-8297
Chris Robinson,
Clerk Advanced
515-725-0359
Megan Wisecup, Supervisor
515-238-4968
Vacant
Program Planner 3, Hunter Ed
Rachel Alliss
PP3, Hunter Ed
515-729-6037
Zach Benttine
PP2, Archery
515-205-8709
Chris Van Gorp
Executive Officer 2, Shooting Sports
and Ranges
515-725-8251
Barb Gigar
Training Specialist 2, Angler Education
515-494-3891
Holly Schulte
Training Specialist 1, Angler Education
563-927-3276
Todd Robertson
Program Planner 1, Outreach
Coord inator
515-725-8466
Anne Riordan
Training Specialist 1, Outreach
Coordinator
641-295-6028
Christina Roelofs
Naturalist
712-579-1801
-------
Making Your Comments Count
The public plays an important role when the Iowa Department of Natural Resources (DNR) prepares air quality permits
or updates state rules. DNR strives to ensure all projects meet federal and state standards. While DNR staff have the
technical expertise, the public may identify other issues—protecting everyone's air quality.
KEYS TO AN EFFECTIVE COMMENT
©Point Out Unintended Consequences
Well-intended rules or permitting
actions sometimes result in unintended
consequences. Thoughtful public feedback
may reveal these effects.
Provide Technical Information
Comments and assumptions supported by
technical information are more helpful than
general statements or form letters.
©Suggest Alternative Solutions
Explain your concerns as clearly as possible
and, if appropriate, suggest alternative
requirements or different language.
©Ask Questions
DNR staff welcome your questions.
Understanding technical requirements can
help you develop a meaningful comment
or address your concerns. If you have
questions, find DNR's experts on the public
participation page or call 515-725-8200.
COMMON COMMENT MISTAKES
®The Comment Process is Not a Vote
One well-supported comment is often
more effective than a hundred generic
emails or form letters. DNR will respond
to similar comments as a group.
Comments Not Specific to Proposal
Read and understand the proposal you are
commenting on. Make sure the comment
is relevant to the issue or action the DNR
is proposing.
Comments Beyond DNR's Authority
You may have a great suggestion to
improve Iowa's air, but it may not be
within the authority granted to DNR by
the legislature or Governor. The DNR is
unable to address issues regarding odor,
noise, light pollution and other factors not
regulated under federal or state air quality
standards.
QU
READY TO MAKE YOUR VOICE HEARD?
Stay informed by signing up for DNR's Air Quality Technical listserv. Check the public participation page regularly to
learn about opportunities to become involved and make public comments.
Comment periods and public hearings provide opportunities for you to comment. DNR will not present information
or answer questions during the formal part of a public hearing—that's for your input. However, there may be time for
questions before or after the hearing. Your voice improves DNR decisions through public notice and comment.
Iowa has made tremendous progress toward improving statewide air quality in the last 25 years.
Together we can ensure Iowa's air quality for the future.
Leading Iowans in Caring for Our Natural ResourcesIwww.iowacleanair.gov
March 2018
-------
Operating Permits & Emission Inventory Section
Air Quality Bureau, Wallace State Office Building , 502 E 9th Street, Des Moines, IA 50319-0034
Catharine Fitzsimmons, Bureau Chief
Kay I a Lyon, Director
Alex Moon, Deputy Director
Ed Tormey, Division Administrator
Marnie Stein, Supervisor,
Operating Permits & Emission Inventory Section
Years of Service = 23
Jim McGraw, Supervisor
Program Development & Support Section
Years of Service = 24
Program Development
Jeremy Arndt
Environmental Specialist Sr
Operating Permit Review,
Permit & Application
Tracking, Iowa EASY Air
Years of Service = 22
Taylor Dailey
Environmental Specialist
Operating Permit Review
Years of Service = 1
Jeremy James
Environmental Specialist
Operating Permit Review
Years of Service = 1
Derek Wedemeier
Environmental Specialist
Operating Permit Review
Years of Service = 0.5
Chris Kjellmark
Environmental Specialist Sr
Operating Permit Review
Acid Rain
Years of Service = 26
Zane Peters
Environmental Specialist
Operating Permit Review
Years of Service = 1
Emilie Peterson
Environmental Specialist
Operating Permit Review
Years of Service = 1
Emission Inventory
Nick Page
Environmental Specialist Sr
Emissions Inventory
Years of Service = 18
Seth Anderson
Environmental Specialist
Emissions Inventory
Years of Service = 11
Krysti Mostert
Environmental Specialist
Emissions Inventory
Years of Service = 13
Program Development
Support
Jessica Reese Mclntyre
Environmental Specialist
Records Support & Data
Entry
Years of Service = 5
Kevin Connolly
Environmental Specialist Sr
SLEIS/Iowa EASY Air Help Desk
Years of Service = 25
Virun Rongkavilt
Environmental Specialist
Records Support & Data
Entry
Years of Service = 29
Jason Dowie
IT Support Worker 4
SLEIS/Iowa EASY Air Help Desk
Years of Service = 13
Wendy Walker
Environmental Specialist Sr
Budget, Expense and
Revenue Tracking
Years of Service = 20
Years of Service for the Operating Permit & Emission Inventory Section = 117.5
Years of Service for the Program Development Section = 116
Total Years of Service = 233.5
-------
TRAINING PLAN
TITLE V OPERATING PERMIT SECTION
Employee: Derek Wedemeier
Start Date: February 8, 2021
Description:
The first three months of training will be spent reading instructional materials and discussing on-the-job
permitting activities. In addition to the training schedule on the reverse side of this page, there will also be
several opportunities for on-going training. Many of these are offered by the Environmental Protection Agency
(EPA), Central States Air Resource Agencies (CenSARA), Air Pollution Training Institute (APTI), and the
Iowa Department of Administrative Services (DAS) Performance and Development Solutions (PDS).
On-going Training (as they become available):
• New Employee Orientation
• Computer Training - New Horizons
• PDS Courses
• EASY Air webinars
• SLEIS webinars
• Compliance Assurance Monitoring (CAM) Workshop
• New Source Review (NSR) Workshop
• Control of Particulate Emissions
• Control of Gaseous Emissions
• NOx Control Technology
Staff Meetings:
Section meetings are held once a month on Thursdays at 8:30 am. Often the discussions become very technical
and acronyms are used quite frequently. Feel free to ask questions during the meeting, or discuss with your lead
worker afterwards. Individual meetings are also held once a month. These meetings are held with each permit
writer, their lead worker and the Title V Supervisor.
Bureau meetings are usually held once a month, typically on the fourth Thursday. The schedule is announced
via e-mail.
APTI, EPA, and CenSARA classes:
https://epaapti.csod.com/client/epaapti/default.aspx
PDS Course Listings:
Iowa DNR Intranet - Training & Education (google.com)
DNR Learning Center/LMS to register for DNR and PDS classes:
https://lsglm700.learnsoft.com/LSGLM/Login/dnrlogin.aspx
Iowa Administrative Code (IAC)
https://www.legis.iowa. gov/law/administrativeRules/chapters?agencv=567&pubDate=03-25-2020
Page 1 of 2
p: \Title_v\TrainingPlans\Training Plan, dot
-------
TRAINING PLAN
February 15-19
~
~
~
~
Discuss with lead worker the Title V permit application forms & instructions
Discuss with lead worker the Title V permit review checklist & manual
Register with EPAAPTI and complete SI-422 Air Pollution Control Orientation course
Begin review of rules 22.100-22.199
February 22-26
~
~
~
~
~
~
~
Work with lead worker on Title V permit application review
Continue review of Title V rules
Discuss the scope of the DNR's air quality rules & program with Marnie Stein
Attend Title V EASY Air webinar
Attend Construction Permit EASY Air webinar
Register for APTI 460: Introduction to Permitting
March 1-5
~
~
~
~
Review instructions on conducting a completeness review of a Title V permit application
Review two example Title V permit projects and discuss with lead worker
Complete APTI 460 and take test
Register for SI-431 - Air Pollution Control Systems for Selected Industries
March 8-12
~
~
~
Continue working with lead worker
Register for RE 100 - Basic Concepts in Environmental Sciences.: Module 6: Air Pollutants and
Control Techniques
Continue reading SI-431 material
March 15-19
~
~
~
~
Continue working with your lead worker
With lead worker's assistance get safety shoes, hard hat, & safety glasses (if COVID allows)
Complete APTI SI-431 and take test
Complete RE 100 and take test
March 22-26
~
~
~
~
~
Continue working with lead worker
Accompany Title V staff on a facility outreach visit (if COVID allows)
Register for SI-437: Module 7 - Fabric Filters
Register for SI-437: Module 4 - Electrostatic Precipitators
Register for SI-437: Module 6 - Wet Scrubbers
Mar 29-Apr 2
~
~
~
Continue working with lead worker
Complete SI-437 and take test
Complete and take test
April 5-9
~
~
Continue working with lead worker
Complete and take test
May - June
~
~
~
~
Discuss the Emission Inventory units role within the AQB with Marnie Stein
Discuss the Construction Permit Section's role within the AQB with Sarah Piziali
Discuss the Program Development & Support Sections" roles with AQB with Jim McGraw
Discuss the Compliance Section's role (compliance, asbestos, stack testing, monitoring) within the
AQB with Brian Hutchins
Page 2 of 2
p: \Title_v\TrainingPlans\Training Plan, dot
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Small Source Operating Permits
Facility #
Facility Name
Site City
11-02-002
Ag Partners L.L.C.
Alta
75-05-001
Agriliance, LLC
Merrill
08-01-014
Archway Cookies Inc.
Boone
30-04-002
Arco Dehydrating Company Inc.
Lake Park
70-01-056
Bandag Inc. - Plant 4
Muscatine
82-02-033
Bee Line Company
Bettendorf
97-01-125
Big Soo Terminal
Sioux City
90-01-033
BP - Ottumwa Terminal
Ottumwa
78-01-035
Cargill AgHorizons
Council Bluffs
91-01-021
Cemen Tech Inc.
Indianola
47-01-006
Century Nutrition, Inc.
Ida Grove
46-02-001
Chantland - MHS Company
Dakota City
44-03-003
Chem Gro of Houghton Inc
Winfield
70-01-059
CHS Muscatine
Muscatine
26-01-002
City of Bloomfield
Bloomfield
72-01-002
City of Sibley
Sibley
14-03-001
Coon Rapids Municipal Utilities
Coon Rapids
36-05-001
Crestland Cooperatives
Riverton
02-02-001
Crestland Cooperatives
Prescott
39-06-001
Crestland Cooperatives
Menlo
97-02-007
Crop Production Services
Moville
97-06-001
Crop Production Services
Anthon
85-01-074
Daily Tribune
Ames
23-01-008
Dairy Pak
Clinton
52-01-018
Dept. of Veterans Affairs Medical Center
Iowa City
27-01-004
Farmers Coop Grain & Seed C
Lamoni
41-04-002
Five Star Cooperative - Klemme
Klemme
34-01-022
Floyd County Ag Center
Charles City
99-01-007
Gold-Eagle Cooperative - Eagle Grove
Eagle Grove
19-01-014
GROWMARK, Inc.
New Hampton
38-01-001
Grundy Center Municipal Light and Power
Grundy Center
28-01-013
Henderson Products, Inc.
Manchester
51-01-007 Jefferson Company Hospital
Fairfield
78-01-049 Jennie Edmundson Memorial Hospital
Council Bluffs
07-01-108 Jerald Manufacturing Company
Waterloo
70-03-002 J-M Manufacturing Company, Inc.
Wilton
23-08-002
Kinder Morgan COCHIN LLC
Calamus
95-02-002
Lake Mills Municipal Light
Lake Mills
17-01-031
Land O'lakes Inc.
Mason City
16-05-002
Land O'lakes Inc.
Clarence
71-01-008
Land O'Lakes Purina Feed LLC - Sheldon
Sheldon
06-10-001
Linn Cooperative Oil Company
Newhall
74-01-014
Max Yield Co-op
Emmetsburg
64-01-005
Mepco
Marshalltown
23-01-059
Mercy Medical Center - Clinton North Campus
Clinton
97-01-059
Missouri Valley Steel Company
Sioux City
1 of 2
June 18, 2021
-------
Small Source Operating Permits
75-02-003
Nelson Hatchery Inc.
Akron
28-01-010
Oribs Division, Menasha Corporation
Manchester
90-01-032
Ottumwa Reg. Health
Ottumwa
28-04-002
Paladin Attachments
Delhi
08-01-009
Percival Scientific Company
Boone
82-17-001
Rockingham-Lunex Company
Pleasant Valley
22-04-003
SilverEdge Cooperative
Strawberry Point
84-03-014
Sioux Center Farmers Coop Society
Sioux Center
87-02-009
Terra International Inc.
Lenox
24-03-002
Terra International Inc.
Schleswig
06-01-017
Terra International Inc.
Vinton
18-04-003
Terra International Inc.
Quimby
13-04-003
Terra International Inc.
Pomeroy
43-01-005
Terra International Inc.
Missouri Valley
67-02-003
Terra International Inc.
Mapleton
70-01-066
Terra International Inc.
Muscatine
07-02-019
Universal International Inc.
Cedar Falls
07-01-064
UTC Railcar Repair Services LLC/Waterloo Shop
Waterloo
07-02-003
Viking Pump, Inc - Iron Foundry
Cedar Falls
69-02-004
Villisca Elevator Inc.
Villisca
29-01-075
Vista Bakery
Burlington
92-01-020
Washington Evening Journal
Washington
32-06-001
Watonwam Farm Service Company
Dolliver
99-01-008
Zoetis, Inc.
Eagle Grove
2 of 2
June 18, 2021
-------
ATTACHMENT D: Fee Attachment
Attachment C
from the March 27, 2018 guidance
[ see the attached copy ]
1084
-------
ATTACHMENT C
Annual Financial Data Form for 40 CFR Part 70
Permitting Authority: Iowa Department of Natural Resources
Annual Period: 07/01/2019 to 06/30/2020 (FY 2020)
Annual Program Revenue
A
Total Program Revenue (Fees Paid by Part 70 Sources)
$12,388,558
Annual Presumptive Minimum Cost Calculation
B
Total Emissions of "Regulated Pollutants (for presumptive fee
calculation)"
102,814 tons
C
Presumptive Minimum Fee Rate During Period ($/ton)
$53.81
D
Total Greenhouse Gas (GHG) Cost Adjustments (as applicable)
0
E=(B*C)+D
Presumptive Minimum Cost for the Program
$5,532,421
A< E or
A > E
Compare Total Program Revenue to Presumptive Minimum Cost
Enter: "Less Than" or "Greater Than" or "Equal To"
A > E
Annual Program Costs
F
Direct Labor Costs1
$3,586,487
G
Other Direct Costs2
$3,084,765
H = F+G
Total Direct Costs
$6,671,252
I
Known Indirect Costs3
$444,007
J = K*L
Calculated Indirect Costs4
n/a
K
Indirect Rate
12.38%
L
Total Cost Base for the Part 70 Program
M = I or J
Total Indirect Costs
$444,007
N = H + M
Total Program Costs
$7,115,259
Z;
i
<
ii
o
Annual Operating Results
(Report deficits in parentheses)
$5,273,299
Program Balance of Accounts (Report deficits in parentheses)
P
Beginning of Year Balance5
$8,605,416
Q = 0
Annual Operating Results
$5,273,299
R
Fee Revenue Transferred In (describe in comments)
$0
S
Non-Exchange Revenue Transferred In (describe in comments) -
Informational Only
$0
T
Fee Revenues Transferred Out (describe in comments)
$0
U = O+Q+R-T
End of Year Balance
$5,273,299
1 This is the sum of all direct labor costs, including regular payroll, overtime payroll, leave, fringe, and
any other administrative surcharges.
2 This is the sum of all other direct costs, including travel, materials, equipment, contractor, and
any other costs directly allocable to the part 70 program.
3 Indirect Costs may either be known or calculated. If known, enter on this row; if calculated,
skip to the next three rows.
4 If Indirect Costs are calculated, enter the result here, and enter the rate and base below.
Accounting or budgeting personnel may be able to provide additional information on or
assistance with calculating Indirect Costs.
5 This is the prior year's "End of Year Balance."
1
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Background
The information in Attachment C is for the air contaminant source fund, established in Iowa Code
455B.133B. There are two accounts in the fund: air emission fee account and operating permit
application fee account. No other revenues or expenses are included in the calculations.
Information provided is from state fiscal year (FY) 2020, which began on July 1, 2019 and ended on June
30, 2020. FY 2020 is the most recently completed fiscal year. The accounting for the fiscal year ending
on June 30, 2021, will not be completed until later in 2021.
Several Iowa DNR attachments are included with the Attachment C submittal. The file, FY 2020 Title V
Expense & Revenue Summary, provides an annual summary of the air contaminant fund. The file has a
section that lists the total air quality program's expenses and revenues and is included for reference
purposes.
Personnel expenses are tracked by specific codes per accounting cost center by funding stream. The file,
FY 2020 Personnel Time Code Data, provides the annual personnel summary. Also included are the
SFY20 stakeholder memo and budgetary agenda item presented to the Environmental Protection
Commission.
Total Program Revenue (A): The amount listed reflects fees paid to the air contaminant source fund
during FY 2020 along with accrued interest. The amount may include fees that were not assessed during
FY 2020, such as corrected prior year emission inventory fees. Air Quality Bureau staff review air
contaminant source fund deposits monthly to ensure revenue is deposited into the correct account and
that non-Title V revenue is not inadvertently deposited into the air contaminant fund.
Total Greenhouse Gas Cost Adjustment (D): Fees are not assessed on greenhouse gas emissions.
Direct Labor Costs (F): The amount listed reflects the personnel costs paid by the air contaminant source
fund.
Other Direct Costs (G): Expenses include DNR legal services, subawards with Linn and Polk Counties,
contractual agreements with the University of Iowa State Hygienic Laboratory, the Iowa Waste
Reduction Center, IT contractors for SLEIS and Iowa EASY Air, vehicles, records scanning,
communications, utilities, training, and other miscellaneous office expenses, and other travel expenses.
Known Indirect Costs (I): The Iowa DNR utilizes an indirect rate that is approved by the Department of
the Interior, the largest federal grantor. The approved indirect rate for FY 2020 was 12.38% (K) and was
multiplied by the direct labor costs (F).
Beginning Year Balance (P): This is the SFY2019 end of year balance.
Fee Revenue Transferred In/Out (R/T): Air contaminant funding is the sole funding source for the Title V
operating permit program. Non-Title V funding is not transferred into the air contaminant fund. Revenue
is not transferred out of the air contaminant to accounts or programs.
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ATTACHMENT E: Entrance Meeting Attendees
EPA
David Peter
Amy Algoe-Eakin
Dana Skelley
Ward Burns
Robert Cheever
Patricia Scott
Kathy Finazzo
IDNR
Sarah Piziali
Jim McGraw
Chris Roling
Gary Smith
Karen Kuhn
Michael Hermsen
Peter Zayudis
Chris Kjellmark
Jeremy Arndt
Brad Ashton
Wendy Walker
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ATTACHMENT F: Exit Meeting Attendees
EPA
David Peter
Amy Algoe-Eakin
Ward Burns
Robert Cheever
Patricia Scott
IDNR
Sarah Piziali
Chris Roling
Gary Smith
Karen Kuhn
Michael Hermsen
Peter Zayudis
Marnie Stein
Chris Kjellmark
Jeremy Arndt
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ATTACHMENT G: IDNR's Response Letter Regarding the Draft Report
[ see the attached copy ]
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March 4, 2022
Iowa Department of Natural Resources
Governor Kim Reynolds
Lt. Governor Adam Gregg
Director Kayla Lyon
Amy Algoe-Eakin, Branch Chief Sent by email
Air Permitting and Standards
Air and Radiation Division
U.S. Environmental Protection Agency Region 7
11201 Renner Blvd
Lenexa, KS 66219
Re: DNR Comments on EPA's Draft Program Review Report
Dear Ms. Algoe-Eakin:
Thank you for providing us the opportunity to comment on the draft program review report (report) sent via
email by David Peter on January 25, 2022. The report summarizes the findings and conclusions of the
Environmental Protection Agency's (EPA) review of the Iowa Department of Natural Resources' (DNR's) air
construction and Title V operating permit programs and DNR's administration of Title V fees. The program
review was conducted virtually during July and November of 2021.
Please find that our specific comments follow the organizational structure of the report and are ordered by
report section and page number followed by the corresponding report paragraph number (where applicable)
and item letter (where applicable) for reference. Two general comments are included after the specific
comments.
Specific Comments:
1. Section B (page 4), numbered paragraph 4, item b:
EPA Comment: IDNR has a relatively small amount of "backlogged" Title V permits. EPA recognizes that IDNR
made efforts beginning in 2014 to reduce the Title V permit backlog. The EPA also recognizes that staff turnover
in the last year or so has resulted in a slight increase in the backlog over that period.
DNR Comment: DNR continues to make progress on reducing the Title V permit backlog. The section has been
fully staffed since February 2021, and currently 14 Title V applications are backlogged. DNR plans to issue
permits for at least 8 of those facilities in 2022, reducing the backlog by over 50%.
2. Section B (page 5), numbered paragraph 1:
EPA Comment: The majority of the permits that EPA reviewed that included 12-month rolling limits didn't
specify the consequences of exceeding the limit in the first months the limit applies (for example, the limit is
exceeded in the 9th month after the limit is applicable). Although EPA believes that it would not be a compelling
argument, an argument could be made that a violation couldn't possibly occur until the 12th month of operating
under the limit, since one could argue that a full 12-month period is needed to compare to the 12-month rolling
limit. The EPA recommends that IDNR consider including a statement in the permit that an exceedance at any
point in the first 11 months that the limit applies would constitute a violation of the limit at the time that the
limit is exceeded.
Phone: 515-725-8200
502 E 9™ ST, DES MOINES IA 50319
www. Iowa DN R.gov
Fax: 515-725-9501
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DNR Response: DNR will start to include language to address this concern in construction permits going
forward. We will work with EPA to ensure the language developed is consistent with EPA's concerns in the area.
3. Section B (page 5), numbered paragraph 2:
EPA Comment: IDNR indicated in Question (ll)(B)(3)(4) and (VI)(A)(1) that environmental justice issues are
currently not generally considered in its permitting issuance process. We recognize that Iowa does not have any
EJ legislation, policy, or general guidance related to permitting. We further recognize that IDNR interprets the
Clean Air Act (Act) and their State Implementation Plan (SIP) to not address EJ in permitting actions. However,
other states with similar SIPs have received comments alleging that a minor construction permit violated Title VI
of the Civil Rights Act of 1964. Therefore, we encourage the IDNR to consider EJ issues and engage with
communities as appropriate. Further, EPA R7 is aware of IDNR's interest in potentially utilizing EJ considerations
in the future. To that extent, EPA encourages IDNR to consider potential EJ concerns in future permitting
activities.
DNR Response: DNR works diligently to ensure our work is transparent to the public. This transparency is
accomplished in a variety of ways that not only inform the public of the applications we currently are reviewing,
but also assists them in engaging with the DNR and providing meaningful comments that could impact the
decisions made during the review of an application.
DNR has several ways a member of the public can stay informed about proposed construction or Title V permit
applications in their area. Iowa EASY Air provides a public inquiry portal that allows anyone to search for and
view active applications, permits seeking public comment, and previously issued construction and Title V
operating permits. DNR's construction permit search website provides an alternative to Iowa EASY Air and
allows the public to search by varied criteria such as city or county to access issued permits and applications
that are currently under review. The public may also view Title V operating permits on public notice and
completed Title V permits on the Title V permit web page. On these sites the DNR encourages the public to
review the applications and emissions information and submit comments or questions to the DNR by providing
the direct contact information for the staff member assigned review.
DNR recently released a new GIS-based method the public can use to search for active applications. The
Environmental Services Dashboard allows the public to use a map tool to target areas of interest and display
active construction and Title V permit applications in those areas along with a link to Iowa EASY Air to further
view the application information. The dashboard also provides summary information for the public on the
number of active applications by submission type and review status in the selected areas of interest.
In addition to providing opportunities to view and comment on permits, the DNR maintains a public
participation website that lists all opportunities for the public to participate in and make recommendations to
the DNR on a variety of rulemaking and planning activities, including meetings and workgroups.
The DNR also understands that it can be difficult for the public to feel like they can meaningfully participate in
the permitting and rulemaking process and to know what types of comments and suggestions are
effective. DNR has made changes to address these challenges by including non-discrimination language in our
public notices, launched a website devoted to environmental justice, and created a guidance document for the
public on the keys to making an effective public comment.
Recently, the DNR launched an environmental justice website that outlines the DNR's language and disability
plans and reflects DNR's commitment to serving lowans of all backgrounds and cultures, including individuals
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with limited English proficiency and providing individuals with disabilities the opportunity for full participation in
its programs, services, and activities. To further that effort the following language has recently been added to
our air quality public notices:
"Individuals with disabilities or limited English proficiency are encouraged to participate in all DNR
activities, including submitting public comments. If a reasonable accommodation or language services
are needed to participate, contact the Air Quality Bureau staff member listed or Relay Iowa TTY Service
at 800-735-7942 in advance to advise them of your specific needs. DNR's language access and disability
nondiscrimination plans are available at https://www.iowadnr.gov/About-DNR/Environmental-Justice"
DNR feels that the public plays an important role in our work, including when the DNR prepares air quality
permits or updates state rules. We are confident that these efforts to engage with the public, assist us in making
better decisions and ensure clean air for all lowans. We welcome any feedback or suggestions on how we could
further improve in these areas.
4. Section B (page 5), numbered paragraph 3:
EPA Comment: As part of this permit review, the EPA determined that IDNR appeared to appropriately identify
all of the applicable requirements, including the applicable NSPS and NESHAP subparts, in the permitting actions
that we reviewed. As part of our routine review of Title V permits proposed for issuance by IDNR, EPA also has
determined that the IDNR, in general, identifies all of the appropriate applicable requirements. However, we do
note that the level of detail of the applicable requirements in Title V permits has not necessarily been consistent
from permit to permit, sometimes even for the same subpart. The EPA recognizes that there are several
approaches to incorporating applicable requirements from an applicable subpart. On one end of the spectrum,
the permit could simply indicate the facility or affected source is subject to a certain subpart and refer the
permittee to the Code of Federal Regulations. On the other end, the permit could include the entire subpart
verbatim, with no identification of the specific paragraphs that apply to the affected source. The EPA recognizes
that there are issues with both of these extreme approaches, as neither approach adequately informs the
permittee or the public of the specific applicable requirements that the permittee is required to comply with.
Typically, the most useful approach would be one that is a balance of these two extremes. The EPA recommends
that IDNR work toward achieving consistency in how applicable requirements are included in the draft permit,
especially for permits with affected sources subject to the same subpart. This approach would ensure that the
permittee and the public are made aware of the applicable requirements in a clear and consistent manner.
DNR Response: DNR appreciates EPA's findings that the NSPS and NESHAP applicability determinations made by
DNR in Title V permits are correct. DNR agrees that consistency in the level of detail of the NSPS and NESHAP
requirements could be improved, especially when citing the same subpart for multiple emission sources in the
same Title V permit. As discussed previously with EPA, DNR continuously strives to capture the correct balance
and level of detail between citing the entire subpart, correctly capturing the requirements of individual
construction permits, and providing enough detail, but not a burdensome amount of detail, for the public and
field office inspectors. DNR looks forward to working with EPA to improve consistency and encourages EPA to
provide more specific guidance and examples from other states to better explain how EPA would like NSPS and
NESHAP subparts cited in Title V permits.
5. Section B (page 6), numbered paragraph 4:
EPA Comment: IDNR has included the phrase "of the source category" when indicating that the facility is subject
to certain NSPS and NESHAP subparts in Title V permits. IDNR staff have indicated that the reason this phrase is
used for certain subparts is because the IDNR has not adopted that federal rule and that they have no authority
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to determine whether the rule applies or doesn't. Regardless of the rationale for the use of its phrase, the
phrase leads to ambiguity on whether the rule actually applies or not. As stated at 567 IAC 22.108(l)(f), the Title
V permit should clearly identify all applicable requirements. Should IDNR have any question whether a federal
rule that IDNR has not adopted is applicable, IDNR should coordinate with EPA Region 7 for a determination
such that the Title V permit will clearly identify whether the rule is applicable to the facility.
DNR Response: DNR used the "of the source category" for a brief time several years ago after several EPA
regulations were remanded, vacated, or not adopted into state rules. However, DNR discontinued using the
language in January 2013 based on a comment from EPA Region 7. DNR's practice since that time is for the Title
V permit writer to make a clear determination in the permit of which NSPS and NESHAP subparts the facility is
subject to. If the "of the source category" language was included in a Title V permit since January 2013, it was an
oversight on DNR's part and not DNR's intent to avoid making a clear determination. As staff continue to renew
older Title V permits, DNR will be watchful to remove any old instances of the "of the source category" language.
6. Section B (page 6), numbered paragraph 5:
EPA Comment: During routine reviews of IDNR's proposed draft Title V permits and follow-up discussions with
IDNR staff, it is EPA's understanding that the statement of basis or Title V permit writer notes typically only
address changes that occurred since the previous Title V was issued (such as physical changes at the facility or
changes in the applicable requirements). While this approach likely has benefits, such as highlighting the
changes to the previous permit so that the focus of the review can be on those changes, it also doesn't provide a
complete summary of the rationale for all applicable requirement determinations for the facility. As Title V
permits are generally renewed every five years, there is the likelihood that interested parties including the
public and permitting staff from IDNR, EPA and the affected facility may not have been involved in the drafting
and issuance of the previous Title V permit. Therefore, EPA recommends that the statement of basis or permit
writer notes reference the previous statement of basis in some manner. A couple of options that EPA identified,
but there are certainly others, include making the previous statement of basis part of the permitting record for
the renewal permit or clearly indicate where the public or other entities can easily obtain the previous
statement of basis.
DNR Response: DNR's current practice is to develop a statement of basis that combines the fact sheet and
permit writer notes into one document. As discussed in several prior conversations with EPA, DNR agrees that it
would be beneficial to carry forward more details from the previous statements of basis. The Title V supervisor
and senior environmental specialists continue to work with the other permit writing staff to make these
documents more robust. DNR is also considering providing the previous notes and statements in a combined
historical document during the public notice period. DNR encourages EPA to provide additional guidance and
examples from other states to better explain how EPA would like DNR to improve the statements of basis.
7. Section B (page 7), numbered paragraph 6:
EPA Comment: The EPA recommends that IDNR investigate opportunities to assess application fees for
significant modification applications such that this potentially important component of the Title V permit
program is fully implemented.
DNR Response: The DNR currently has authority in Iowa Code (455B.133B) to assess application fees for
processing modifications to Title V operating permits. However, implementing rules in 567 Iowa Administrative
Code (IAC) Chapter 30 only authorize the DNR to collect application fees for initial and renewal Title V permit
applications. The DNR will continue to work with affected stakeholders to obtain support for making changes to
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the Iowa Administrative Code to add modifications to the list of Title V permit application types that are eligible
for funding with Title V permit application fees.
8. Section C (page 8), 1st paragraph:
EPA Comment: EPA stated that fee revenue is currently tracked using SLEIS.
DNR Response: The State & Local Emissions Inventory System (SLEIS) is used for tracking source emissions
only. Emissions data from SLEIS for Title V sources is imported into a Microsoft Access database called "TV
Emissions and Fees Tracking." As annual emissions fees payments are received from Title V sources they are
cross-checked with the emissions data previously imported from SLEIS as part of the process of entering the
payment information into the database. In addition to this Access database, DNR Budget & Finance record the
deposits and are the official financial record for Title V emissions fees payments. The Budget & Finance tracking
information is compared monthly to the bureau's tracking information and any discrepancies are resolved.
9. Section C (page 8), 4th paragraph (Workday):
EPA Comment: EPA does recommend that IDNR ensure that the "Workday" Title V work tags are sufficiently
descriptive to demonstrate that the activities and expenses being claimed for Title V activities actually qualify as
valid Title V activities.
DNR Response: The Title V work tags are sufficiently descriptive that when combined with staff time use data,
they provide DNR with adequate information to demonstrate that the activities and expenses qualify as valid
Title V activities.
10. Section C (page 8), 5th paragraph: Emissions trends:
EPA Comment: In addition, the amount of regulated air emissions in Iowa that are covered under the emissions
fee program are trending down. Therefore, Iowa informed the EPA that it is considering potential actions that it
may need to take in response to this reduction to ensure that the Title V permit program is adequately funded.
DNR Response: The downward trend of feeable air emissions in the state is not unique to Iowa and reflects the
50 plus years of successes that the partnership between federal and state governments has had in implementing
the Clean Air Act. Like many states, DNR continues to explore long term, stable funding mechanisms that will
allow for a continued strong air program presence in the state. The DNR looks forward to having EPA's support
and partnership in this process.
11. Section D (page 9), numbered paragraph 1:
EPA Comment: The IDNR air permitting program is divided into two groups - Construction Permit Section and
Operating Permits and Emissions Inventory Section.
Based on information provided by IDNR as part of the NSR Questionnaire, the Construction Permit Section has a
total of 14 staff positions. This includes a Section Chief, four Senior Engineers, and nine permit writers. The
average length of NSR permitting experience is over 17 years.
Based on information provided by IDNR as part of the Title V Questionnaire, the Operating Permit and Emissions
Inventory Section has a total of eight staff positions related to Title V permit development. This includes a
Section Chief, two Senior Environmental Specialists, and five permit writers. The average length of operating
permitting experience is over nine years.
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DNR Response: The construction permit section consists of one supervisor (instead of chief), five senior
engineers (instead of four), and nine engineers (instead of permit writers). All engineers in the section, including
the senior engineers, are responsible for writing construction permits.
The operating permit and emission inventory section includes one supervisor (instead of chief), two senior
environmental specialists, and five environmental specialists. All staff in the section except the supervisor, write
operating permits.
12. Section D (page 9), numbered paragraph 2: items a and b:
EPA Comment: For AGP Eagle Grove project 17-314, it appears that the emission factors for certain units
associated with the project are developed from stack testing. We recommend that, in future permitting actions,
IDNR provide more detail in either the permit writer notes or the permit itself on the specific procedure from
converting stack test results to an emission factor that will be used in compliance demonstrations.
DNR response: DNR agrees with this comment and will ensure in the future that the procedure to convert a stack
test result to an emission factor is spelled out in either the permit or engineering evaluation. Additionally, DNR
has asked AGP to amend the permits issued in project 17-314 to document the procedure.
EPA Comment: For Flint Hills Menlo project 20-282, section 6 of permit indicates that a CEMS was not required
by the permit. However, it appears that to demonstrate compliance with certain NOx limits, a CEMS is utilized.
DNR response: DNR has reviewed the permit and concurs that a CEMS is required to demonstrate
compliance. DNR has asked POET, the new owner of this facility, to amend the permit to correct the error.
General Comments:
1. Where the EASY Air system is mentioned in the report, please refer to the system as "Iowa EASY Air" to
avoid possible copyright infringements.
2. Attachment A should be renamed "List of Construction Permit Files Reviewed" to clarify that the list
does not include Title V operating permits
We appreciate the time and effort that EPA has put forward in conducting this program review. The
recommendations provided by EPA from this program review will help us to further fine tune our permitting
programs. Please feel free to contact me, or any of the individuals who are copied on this letter, if you have
questions or need additional information.
Sincerely,
Catharine Fitzsimmons, Chief
Air Quality Bureau
C: Jim McGraw: 515-689-1439, iim.mcgrawffidnr. iowa.gov
Sarah Piziali: 515-725-9549, sarah.pizialiffidnr. iowa.gov
Marnie Stein: 515-725-9525, marnie.stein@dnr.iowa.gov
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