TECHNICAL SUPPORT DOCUMENT For DRAFT/PROPOSED …NOx 0.44 0.44 0 2.28 9.13 Insig. ... • CAM has been added to CE001 Panel Filter in the permit as described in Table 5. Removal of

TECHNICAL SUPPORT DOCUMENT For

DRAFT/PROPOSED AIR EMISSION PERMIT NO. 12700055-002

This technical support document (TSD) is intended for all parties interested in the draft/proposed permit and to meet the requirements that have been set for th by the federal and state regulations (40 CFR § 70.7(a)(5) and Minn. R. 7007.0850, subp. 1). The purpose of this document is to provide the legal and factual justification for each applicable requirement or policy decision considered in the preliminary determination to issue the draft/proposed permit.

1. General Information

1.1 Applicant and Stationary Source Location

Table 1. Applicant and Source Address

Applicant/Address Stationary Source/Address (SIC Code: 3993, 3399)

Daktronics, Inc. 201 Daktronics Drive Brookings, SD 57006

Daktronics, Inc. Redwood Falls Facility

202 Industrial Dr and 1425 East Bridge St Redwood Falls, MN 56283

Redwood County Contact: Jeffrey Fritz Phone: 605-692-0200x56507

1.2 Facility Description

Daktronics fabricates parts for electronic message centers and displays. Metal sheets are cut to size, punched and bent into the required shapes. The metal'parts are then painted and cured in the bake oven. The painting process is the main contributing source of air emissions. The painting process releases off particulate matter (PM, PMi0, and PM25), volatile organic compounds (VOCs), and hazardous air pollutants (HAP). The spray booth uses panel filters to obtain an 85% control efficiency for the PM emissions. The painting process is the final fabrication process at the 202 building. Parts are then sent to be assembled at the second building located at 1425 East Bridge Street building in Redwood Falls. The only emission units at the 1425 building qualifytas insignificant activities and are included in Appendix B to the permit.

1.3 Description of the Activities Allowed by this Permit Action

This permit action is the reissuance of the Part 70 operating permit.

1.4 Changes Made Since Last Permit

1.4.1 Metal Sanding Machine

Sheets of aluminum metal are sanded for use in the fabrication of product. The sanding operation was originally done manually, however in 2010 the manual operation was replaced by Daktronics with an

automatic machine. This operation takes place after the first solvent/wipe down action and before the second solvent/wipe down action. The metal sanding machine has a wet dust coll ection system installed to comply with National Fire Protection Association 484 Combustible Metals recommended guidelines. The main pollutant of concern from this operation is particulate matter. Since the emissions from the sanding operation are filtered through an air cleaning system and are vented inside the building 100% of the time, this activity qualifies as a conditionally insignificant activity under Minn. R. 7008.4110. The sanding machine is added to the list of insignificant activities in Appendix B of the permit

1.4.2 EU001 Solvent/Rag Wipe Process Changes

EU001, the manual wipe down process has been expanded to include a secon d wipe down action. For EU00.1, wipe down involves using a solvent to clean the metal parts before sanding and before painting. Additionally, Daktronics is now only using 99% Isopropyl Alcohol (IPA) for wipe down actions. Switching to 99% IPA resulted in higher VOC emissions, but eliminated HAP emissions. EU001 emissions also vent through the same stack, SV001. Both changes were considered insignificant modifications under Minn. R. 7007.1250, subp. 1(B). Table 3 shows the emission increa se from this modification.

1.4.3 EU002 Spray Booth Changes

Some of the spray paint materials that are used in EU002 were changed to reduce VOCs and HAPs. 70DK8800 Prism Semi-Gloss Black was changed to 70DK8800L ("Low-HAP") and 5269 DTM Epoxy Sealer Hardener Part B was replaced with 5271 DTM Epoxy Sealer Hardener Part B. The change in material also eliminated the emission rates for toluene and xylenes. Neither material change affected the worst case scenario for VOC or particulate matter emissions.

1.4.4 Potting Material Application Process

Daktronics installed an application machine to apply a 2-part po tting material to printed circuit boards in 2011. Part A is a polyurethane resin and Part B is a urethane adhesive. These materials react when mixed and are applied in an extrusion-like process. The polyurethane resin contains VOCs (MDI and PMDI) and a H AP (MDI). Urethane adhesive does not contain any VOCs (according to the MSDS) or any HAPs. When mixed the MDI/PMDI reacts (worst case assumed to be 99.5%, used polyurethane.org to support this reaction number). This process used 99% isopropyl alcohol (IPA) as a clean-up material. The potting process qualified as an insignificant activity under Minn. R. 7007.1300, subp. 3(1) and therefore the addition of the potting process qualified as an insignificant modification under Minn. R. 7007.1250, subp. 1(A).

However after the reissuance application was sent to the MPCA, the Permittee changed the 2-part potting material to a 2-part silicone material. Part A of the silicone material is QSI TufGel 335A and Part B is QSI TufGel 335B. The new silicone material is a flexible gel-type material rather than a resin. Because of this there is no need for an IPA solvent to clean the machine. The material does not contain any VOC or HAPs. The MSDS for this material is provided in Attachment 4. There are no longer any emissions associated with this application process; therefore the potting process is not included in the permit at this time.

1.4.5 Building 1425 Air Makeup Units

Nine total natural gas air makeup units were installed as part of a 2014 warehouse expansion project to building 1425. Eight of the units have a capacity of 0.116 MMBtu/hr each, and the last remaining unit has a capacity of 0.606 MMBtu/hr. This addition of nine makeup units increased emission rates for PM, PM10, PM2I5, S02, NOX, VOC, CO, Pb, and C02e. Each of these units qualifies as an insignificant activity under Minn. R. 7007.1300, subp. 3(1) and therefore the addition of these units qualifies as an insignificant modification under Minn. R. 7007.1250, subp. 1(A). These units have been added to the insignificant activity list in Appendix B.

1.5 Facility Emissions

Table 2. Total Facility Potential to Emit Summary

PM tpy

PM10

tpy PM2,S tpy

so2 tpy

NOx

tpy

1.95

CO tpy

1.64

C02e tpy

VOC tpy

Single HAP tpy

All HAPS tpy

Total Facility Limited Potential Emissions Total Facility Actual Emissions (2013)

17.2 17.2 17.2 0.012

NOx

tpy

1.95

CO tpy

1.64 2330 201 28.7 33.7 Total Facility Limited Potential Emissions Total Facility Actual Emissions (2013)

0.57 0.57 0.57 0.0007 0.11 0.10 * 11.5 *

*Not reported in MN emission Inventory.

Table 3. Non-Title I Emissions Increase Summary from Additional Wipedown Step (EU001)

Type of Minor and Amendment

Insignificant Moderate (Minor or After Before Net Modification Amendment Moderate) or

Change Change Change* Thresholds Thresholds Insignificant Pollutant (Ib/hr) (Ib/hr) (Ib/hr) (Ib/hr <) (Ib/hr < or >) Modification PM10 25.93 25.93 0 0.855 3.42 Insig. so2 2.67E-03 2.67E-03 0 2.28 9.13 Insig. NOx 0.44 0.44 0 2.28 9.13 Insig. CO 0.38 0.38 0 5.70 22.80 Insig. Lead 2.22E-06 2.22E-06 0 0.025 0.11 Insig. VOC** 45.79 43.55 2.24 2.28 9.13 Insig.

* The term "Net Change" is not equivalent to "Net Emissions Increase" as defined at 40 CFR 52.21 (b)(3) ** The modification qualified as an insignificant modification under Minn. R. 7007.1250 based on the assumptions used in VOC calculations for Permit Number 12700055-001. During the processing of this permit action, the calculations were updated to reflect the potential emissions of the operation described in Section 3.1 and Attachment 1.

Table 4. Facility Classification

Classification Major Synthetic Minor/Area Minor/Area PSD X Part 70 Permit Program X Part 63 NESHAP X

1.6 Changes to Permit

The MPCA has a combined operating and construction permitting program under Minn. R. 7007, and under Minn. R. 7007.0800, that states the MPCA has authority to add additional requirements into a permit. Under that authority, the following changes have been made to the permit:

• The permit has been updated to the current MPCA templates and citation formats. • The emission unit descriptions have been changed to help integration into MPCA's new

database program (TEMPO), (i.e. EU003 Heater for Spray Booth was changed to EU003 Heater for Spray Booth - Process Heater.

• In the facility description, the maximum design materials for the combustion equipment EU003 and EU004 have been changed from "natural gas" to "heat". '

• The emissions data for methane, nitrous oxide, carbon dioxide, and carbon dioxide equivalent have been added to the Facility Description for EU003 and EU004.

• EU003 and EU004 have been removed from the GP002 NESHAP affected units, because they are not subject to 40 CFR Pt. 63, subp. MMMM. They are natural gas combustion units and are not subject to the surface coating NESHAP.

• EU005 has been removed from the Facility Description, because EU005 was added in error in a previous permit action.

• Toluene and Xylene were removed as pollutants from EU002. The Permittee no longer uses materials that contain these HAPs in this unit.

• Toluene and total HAPs were removed as pollutan ts from EU001. The Permittee no longer uses materials in this unit that contain toluene or HAPs.

• The emissions data in the Facility Description have been updated to reflect current calculations for the facility.

• Due to changes in Minnesota rule, the existing four natural gas space heaters (0.117 MMBtu/hr each) now qualify as insignificant activities under Minn. R. 7007.1300, subp. 3(1). This new classification of these four space heaters is due to a reduction in allowable total capacity under Minn. R. 7007.1300, subp. 3(A).

• The existing eleven natural gas makeup units in building 1425 were added to the list of insignificant activities in Appendix B of the permit. These eleven natural gas air makeup units range in capacity from 0.115 MMBtu/hr to 0.400 MMBtu/hr. All eleven units are classified as insignificant activities under Minn. R. 7007.1300, subp. 3(1). These units were left out of the insignificant activities table in error in Permit No. 12700055-001.

• EU002 (Spray Booth-Spray Booth/Coating Line), the citation of the Industrial Process Equipment Rule was changed from Minn. R. 7011.0710 to Minn. R. 7011.0715 because this unit started operation after July 9th, 1969. This unit was incorrectly labeled as Minn. R. 7011.0710 in Permit No. 12700055-001.

• CAM has been added to CE001 Panel Filter in the permit as described in Table 5.

Removal of Synthetic Minor VOC Limit

The synthetic minor VOC limit of 95 tpy has been removed from GP001 of the permit. The Permittee originally accepted the VOC limit to avoid an Air Emissions Risk Assessment (AERA). However since then, the emissions threshold that triggered an AERA has been increased from 100 tpy to 250 tpy. Removing this limit reduces the recordkeeping for the Permittee.

2 Regulatory and/or Statutory Basis

New Source Review The facility is an existing minor source under New Source Review regulations. The facility is not one of the listed source categories, therefore the facility is subject to the 250 tpy threshold, but the facility's unlimited/uncontrolled emissions are below this threshold.

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

New Source Performance Standards (NSPS) The Permittee has stated that no New Source Performance Standards apply to the operations at this facility.

National Emission Standards for Hazardous Air Pollutants (NESHAP) The facility is a major source under 40 CFR pt. 63. The facility is subject to 40 CFR Pt. 63, subp. MMMM -National Emission Standards for Hazardous Air Pollutants for Surface Coating of Miscellaneous Metal Parts and Products. The facility was not eligible to request limits on HAP emissions to avoid this standard because the compliance date for the standard had passed by the time the Permittee applied for its first air emissions permit.

Within 40 CFR Pt. 63, subp. MMMM there are three possible compliance options to choose from: Emission Rate without Add-on Controls, Compliant Material, and Emission Rate with Add-on Controls. Within the permit two of the options are listed, emission rate without add-on controls and compliant material option. The third option, emission rate with add-on controls, was not included because the facility does not have pollution control for organic HAPs. Currently the facility follows the emission rate without add-on controls compliance option. However, the second compliance option was left in the permit to give the Permittee flexibility in case they wanted to switch options. In order to switch compliance options they would follow the steps as allowed in the rule and permit.

Compliance Assurance Monitoring (CAM) The table below shows: the sources subject to CAM, the monitoring for the applicable pollutants, and whether the source is a large or other pollutant specific emission unit (PSEU).

Table 5. CAM Summary

Unit Control CAM Applicability

Pollutant Monitoring

EU002 (Spray Booth-Spray

Booth/Coating Line)

CE001 Panel Filter Other PM Periodic and daily

inspections

For other PSEUs (not large), records must be made at a minimum of once per 24 hours. See Attachment 3 to this document for the CAM Plan submitted by the applicant. .

Minnesota State Rules Portions of the facility are subject to the following Minnesota Standards of Performance:

• Minn. R. 7011.0610 Standards of Performance for Fossil-Fuel-Burning Direct Heating Equipment • Minn. R. 7011.0715 Standards of Performance for Post-1969 Industrial Process Equipment

Table 6. Regulatory Overview of Facility

Subject Item* Applicable Regulations Rationale

GP002 (EU001and

EU002)

40 CFR pt. 63, subp. MMMM

National Emission Standards for Hazardous Air Pollutants for Surface Coating of Miscellaneous Metal Parts and Products. The Permittee has the option to comply with either the Emission Rate without Add-on Controls or Compliant Material options. At the time of permit issuance, the Permittee is using the Emission Rate without Add-on Controls.

EU001 (Solvent/Rag Wipe Down -

Solvent Equipment)

Minn. R. 7011.0715

Standards of Performance for Post-1969 Industrial Process Equipment.

EU002 (Spray Booth -Spray

Booth/Coatin g Line)

Minn. R. 7011.0715

Standards of Performance for Post-1969 Industrial Process Equipment.

EU003 (Heater for Spray Booth - Process Heater)

Minn. R. 7011.0610

Standards of Performance for Fossil-Fuel-Burning Direct Heating Equipment. Determination of applicable limits from rule: • Facility is located outside the Minneapolis-Saint Paul Air

Quality Control Region. • Facility has less than 250 MMBtu/hr of direct heating

equipment.

Subject Item* Applicable Regulations Rationale

EU 004(Bake Oven -

Dryer/Oven, Unknown

Firing Method)

Minn. R. 7011.0610

Standards of Performance for Fossil-Fuel-Burning Direct Heating Equipment. Determination of applicable limits from rule: • Facility is located outside the Minneapolis-Saint Paul Air

Quality Control Region. • Facility has less than 250 MMBtu/hr of direct heating

equipment. * Location oft ie requirement in the permit (e.g., EU, SV, GP, etc.).

3 Technical Information

3.1 Calculations of Potential to Emit

The potential air emissions at the facility were calculated for the following emission units: • EU001 (Solvent Rag/Wipe down - Solvent Equipment). Solvent rags are contained in a closed

metal container until needed. Solvent is then added to the rags on a need ba sis. These wetted rags are used to manually wipe down the metal parts before sanding and before the painting process. These emissions are then vented outside via SV001. The potential emissions are based on actual usage rate of solvent, maximum VOC-content of solvents, adjusting to 8760 hr/yr and applying a multiplier of 2 (for a total multiplier of 4.68) to reflect potential emissions.

• EU002 (Spray Booth - Spray Booth/Coating Line) contains two manually operated spray guns. Under normal operation one gun is dedicated to paint primer while the other gun is for a pa int topcoat with only one spray gun operating at a given time. For the purposes of the PTE calculations it was assumed that both spray guns were operating simultaneously and applying the paint or primer with the worst case pollutant content for each pollutant. Paints used are solvent based paints. The booth has a panel filter (CE001) that controls the particulate matter, PM10, and PM2.5 emissions. These emissions are then vented to SV002. To determine the worst case pollutant contents, the primer material as applied, topcoat material, and solvent were all evaluated. Within the topcoat material there are some additives. These additives (hardeners, accelerators, reducers, etc.) are added as needed for proper paint application due to temperature, humidity, gloss, etc. Some small amounts (in grams) of color pigments are added to the topcoat material to create custom colors. The PTE calculations, for each HAP, were done based on which additive was higher for that given HAP and was assumed to make up the entire additive added to the paint. A value of 3.50 lb/gal maximum was used as worst case scenario for VOC. Even though historically the Permittee has generally operated this unit with a maximum VOC material content of 2.90 lb/gal, th'e Permittee's business allows custom paint jobs for their clients. Allowing this VOC content adds flexibility in their permit to meet their client's custom demands, but the Permittee in the past 5 years has not needed to make a paint with a VOC content that high, therefore the calculations represent a conservative worst-case scenario.

• EU003 (Heater for Spray Booth - Process Heater) is a direct heating combustion unit. The process air for the spray booth is heated with a 2.376 MMBtu/hr natural gas heater. The emissions from this unit are vented to SV002. Emissions calculations are based on AP-42 emission factors and maximum capacity of the equipment.

• EU004 (Bake Oven - Dryer/Oven, Unknown Firing Method) is a direct heating combustion unit. After painting the part is directly sent to this oven heated by a 2.160 MMBtu/hr natural gas heater. Emissions from this unit are sent through SV003. All paint related emissions are accounted for with EU002 rather than from this emission unit. Emissions calculations for the heater are based on AP-42 emission factors and maximum capacity for the equipment.

Attachment 1 to this TSD contains Form GI-07, which summarizes the PTE for the facility, and calculation spreadsheets and supporting information prepared by MPCA and the Permittee.

3.2 Monitoring In accordance with the Clean Air Act, it is the responsibility of the owner or operator of a facility to have sufficient knowledge of the facility to certify that the facility is in compliance with all applicable requirements.

For CAM, the Permittee submitted a CAM proposal as required by 40 CFR § 64.3. It can be found in Attachment 3 to this TSD. Further discussion of decisions about CAM can be found in Table 7.

In evaluating the monitoring included in the permit, the MPCA considered the following: • the likelihood of the facility violating the applicable requirements; • whether add-on controls are necessary to meet the emission limits; • the variability of emissions over time; • the type of monitoring, process, maintenance, or control equipment data already available for

the emission unit; • the technical and economic feasibility of possible periodic monitoring methods; and • the kind of monitoring found on similar units elsewhere.

Table 7 summarizes the monitoring requirements.

Table 7. Monitoring Subject Item*

Requirement (basis) Monitoring Discussion

GP002 (NESHAP Affected Units)

HAPs - organic: < 1.9 lb/gallon coating solids used during each 12-month compliance period (40 CFR pt. 63, subp. MMMM)

Material usage recordkeeping; Monthly calculations

Monitoring required by the NESHAP is adequate to ensure compliance with the applicable limit.

EU001 (Solvent/Rag Wipedown -Solvent Equipment

PM: < variable with airflow

Opacity: < 20% (Minn. R. 7011.0715)

None This unit is a solvent w ipedown activity using 99% Isopropyl Alcohol (IPA); therefore no particulate matter emissions are anticipated with this unit.

Subject Item*

Requirement (basis) Monitoring Discussion

EU002 (Spray Booth -Spray Booth/Coati ng Line)


Opacity: < 20% (Minn. R. 7011.0715)

See CE001 The operating and monitoring requirements of the control equipment (see CE001) ensure that this requirement is being met. The requirements of CE001 and EU002 results in maximum PM PTE of 3.89 Ib/hr. which is lower than the rule limit of 12.17 Ib/hr based on airflow.

EU003 (Heater for Spray Booth - Process Heater)


Opacity: < 20% except for one six-minute period per hour of no more than 60% opacity. (Minn. R. 7011.0610)

None This unit burns natural gas; therefore the likelihood of violating either of the emission limits is very small. The permittee can demonstrate that these units will continue to operate such that emissions are well below the emission limits by only burning natural gas. Since this is a permit condition, the semi-annual deviations report will document any deviations from this condition. Maximum uncontrolled particulate matter PTE for this emission unit is 0.018 Ib/hr. The limit at maximum airflow is 12.17 Ib/hr. (Minn. R. 7011.0730 and 7011.0735)

EU004 (Bake Oven -Dryer/Oven, Unknown Firing Method)


Opacity: < 20% except for one six-minute period per hour of no more than 60% opacity. (Minn. R. 7011.0610)

None This unit burns natural gas; therefore, the likelihood of violating either of the emission limits is very small. The Permittee can demonstrate that these units will continue to operate such that emissions are well below the emission limits by only burning natural gas. Since this is a permit condition, the semi-annual deviations report will document any deviations from this condition. Maximum uncontrolled particulate matter PTE for this emission unit is 0.016 Ib/hr. The limit at maximum airflow is 12.17 Ib/hr. (Minn. R. 7011.0730 and 7011.0735)

Subject Item*

Requirement i (basis) Monitoring Discussion

CE001 ' PM, PMw, and Daily and periodic inspections, O&M Compliance Assurance Monitoring (Panel Filter) PM2 5: Control

efficiency > 85% (Minn. R. 7007.0800, subp. 2 and 40 CFR pt. 64)

Plan; Corrective Actions, recordkeeping (CAM) requirements. Monitoring based on the Minnesota Performance Standard for Control Equipment and the approved Compliance Assurance Monitoring Plan is adequate to have a reasonable assurance of compliance. The panel filter is total enclosure.

^Location of the requirement in the permit (e.g., EU, SV, GP, etc.).

3.3 Insignificant Activities Daktronics Inc. has several operations which qualify as insignificant activities or conditionally insignificant under the MPCA's permitting rules. These are listed in Appendix B to the permit.

The permit is required to include periodic monitoring for all emissions units, including insignificant activities, per EPA guidance. The insignificant activities at this Facility are only subject to general applicable requirements. Using the criteria outlined earlier in this TSD, the following table documents the justification why no additional periodic monitoring is necessary for the current insignificant activities. See Attachment 1 of this TSD for PTE information for the insignificant activities.

Table 8. Insignificant Activities

Insignificant Activity General Applicable

Emission limit Discussion Brazing, soldering or welding equipment

PM, variable depending on airflow Opacity < 20% (Minn. R. 7011.0715)

The facility has two welding machines. For these units, based on EPA published emissions factors, it is highly unlikely that they could violate the applicable requirement. In addition, these units are typically operated and vented inside a building, so testing for PM or opacity is not feasible.

Individual units each with potential emissions less than: 1. 4,000 Ib/yr of CO; and 2. 2,000 Ib/yr each of NOx,

S02, PM, PM10, VOCs, and ozone; and

3. 1,000 tpy of C02e

PM < 0.4 Ib/MMBtu Opacity < 20% except for one six-minute period per hour of no more than 60% (Minn. R. 7011.0715 and Minn. R. 7011.0515)

The facility has four natural gas space heaters each at 117,000 Btu/hr heat input. The facility also has 20 natural gas air makeup units ranging in capacity from 115,000 to 606,000 Btu/hr. For natural gas using units, based on the fuel used and EPA published emissions factors, it is highly unlikely that it could violate the applicable requirement. In addition, these types of units are typically operated and vented inside a building, so testing for PM or opacity is not feasible.

Fugitive Emissions from unpaved roads and parking lots

Requirement to take reasonable measures to prevent PM from becoming airborne (Minn. R. 7011.0150)

The facility has an unpaved parking lot.

Insignificant Activity General Applicable

Emission limit Discussion Equipment venting PM/PM10

inside a building, provided that emissions from the equipment are: a), filtered through an air cleaning system; and b). vented inside of the building 100% of the time

PM, variable depending on airflow Opacity < 20% (Minn. R. 7011.0715)

The facility has a metal sanding machine inside a building that has a wet du st collection system installed. Airflow from this operation is sent through the dust collection system and is returned inside the building 100% of the time. For these units, it is highly unlikely that they could violate the applicable requirement. In addition, these units are vented inside a building, so testing for PM or opacity is not feasible.

3.4 Permit Organization

In general, the permit meets the MPCA Guidance for ordering and grouping of requirements. One area where this permit deviates slightly from guidance is in the use of appendices. While appendices are fully enforceable parts of the permit, in general, any requirement that the MPCA thinks should be electronically tracked (e.g., limits, submittals, etc.), should be in Table A or B of the permit. The main reason is that the appendices are word processing sections and are not part of the electronic tracking system. Violation of the appendices can be enforced, but the computer system will not automatically generate the necessary enforcement notices or documents. Staff must generate these.

3.5 Comments Received

This section will be completed after the Public comment and EPA review periods.

4 Permit Fee Assessment

This permit action is the reissuance of an individual Part 70 and has no rolled in applications; therefore, no application fees apply under Minn. R. 7002.0016, subp. 1.

5 Conclusion

Based on the information provided by Daktronics Inc., the MPCA has reasonable assurance that the proposed operation of the emission facility, as described in the Air Emission Permit No. 12700055-002 and this TSD, will not cause or contribute to a violation of applicable federal regulations and Minnesota Rules.

Staff Members on Permit Team: Michael Van Der Wal (permit writer/engineer) Janice Noggle (enforcement) Sarah Sevcik (peer reviewer)

Beckie Olson (permit writing assistant) Laurie O'Brien (administrative support)

AQ File No. 4443; DQ4970

Attachments: 1. Calculation Spreadsheets 2. Facility Description and CD-01 Forms 3. CAM Submittal 4. MSDS for QSI TufGel 335A/335B

\

Daktronics, Inc. Permit No. 12700055-002 Technical Support Document

Attachment 1 Calculation Spreadsheets

Daktronics Incorporated - Redwood Falls, MN Facility Calculations Permit 12700055-002 Potential Emissions - EU 001 Solvent/Rag Wipe

AQ. Facility ID No.: Facility Name: Emission unit: Stack/Vent: Control Equipment:

12700055 AQ File No.: 4443 Daktronics, Incorporated EU 001 (Solvent/Rag Wipedown) (202 Building) SV 001 None

Actual Operating Hr/Yr: 3,744 Based on 12 hours/day, 6 days/week, 52 weeks/year

Process Description: Solvent is used to manually wipe down parts prior to them entering the paint booth. Solvent is poured into a bucket which contains towels; the towels are then used to wipe the parts. Parts are wiped prior to sanding and following sanding (prior to entering the paint booth). Solvent use is 2 gallons per 12 hour shift per each wiping step, for a total of 4 gallons per 12 hour s hift. As a worst case ana lysis, the max usage rate is evaluated at two times the above actual use rate of 4 gal/12 hr shift, which is 8 gallons per 12 hour shi ft, to allow for similar additional wipe processes in the future.

Material Parameters: Actual Usage Rate (gal/12 Annual Usage Density voc voc

Material hr) Rate (gal/yr) (lb/gal) (%) (lb/gal) 99% Isopropyl Alcohol 4 1248 6.59 100% 6.59 Material does not contain HAPs.

Calculation summary: Pollution Maximum Limited Actual

Maximum Uncontrolled Maximum Actual Control Controlled Controlled Controlled Content Emission Rate Uncontrolled Uncontrolled Efficiency Emissions Emissions Emissions

Pollutant (lbs/gal) (lb/hr) Emissions (tpy) Emissions (tpy) (%) (tpy) (tpy) (tpy)

VOC 6.59 4.39 19.24 4.11 0% 19.24 19.24 4.11

For maximum uncotrolled emissions, the actual annual usage was adjusted to 8760 hr/yr and multiplied by 2 for a tota l of 4.68 multiplier.

Daktronics Incorporated - Redwood Falls, MN Facility Calculations Permit 12700055-002 Potential Emissions - EU 002 Paint Spray Booth

AQ Facility ID No.: 12700055 AQ File No.: 4443 Facility Name: Daktronics, Incorporated Emission unit: EU 002 (Spray Booth) (includes cleanup materials) (202 Building) Stack/Vent: SV 002 Control Equipment: CE 001 (Panel Filters) Application Method: 2 Manual spray guns Paint Application Rate: 12 02/mm each gun = 5.625 gal/hr each gun = 11.25 gal/hr total application rate

Minimum Transfer Efficiency: 75% Airmix Spray Gun, which are HVLP compliant Cleanup Materia! Usage Rate; 1 gal/hr Based on facility usage data

Maximum Operating Hours/Year: 8,760 Based on 24 hours /day, 365 days/year

Material Parameters: HAPs Material Ethylbenzene MIBK density VOC Content Solids Content (100-41-4) Glycol Ethers (108-10-1} Total HAP

Material Content % by wt % by wt % by wt % by wt % by wt % by wt Primer As Appl ied (see below) -- 18.9% 75.4% 0.09% 0.0% 4,8% 4.9% 70A61817 Genesis Semi-Gloss 33.0% 52.9% 0.0% 0.0% 0.0% 0.0% No HAPs 70DK8800L Prism Semi-Gloss Black Lcw-HAP - 28.3% 45.2% 0.0% 1.0% 0.0% 1.0% 68-1208 Prism Flat Intermix, Linen White .. 24.1% 75.9% 0.0% 0.0% 0.0% 0.0% No HAPs CS-20 Compliant Solvent -- 17.6% 0.0% 0.0% 0.0% 0.0% 0.0% No HAPs Cleanup Material: Barsol A-4165 - 30% 0.0% 0.0% 0.0% 0.0% 0.0% No HAPs Material Content Ib/gaf lb/gal Ib/gai lb/gal ib/gai lb/gal lb/gal Primer As Applied (see below) 12.21 2.30 9.21 0.011 0.00 0.583 0.594 70A61817 Genesis Semi-Gloss 8.79 2.90 4.65 0.00 0.00 0.00 0.00 No HAPs 70DK8800L Prism Semi-Gloss Black tow-HAP 8.91 2.52 4.03 0.00 0.089 0.00 0.089 68-1208 Prism Flat Intermix, Linen White 10.59 2.55 8.04 0.00 0.00 0.00 0 00 No HAPs CS-20 Compliant Solvent 6.64 1.17 0.00 0.00 0.00 0.00 0.00 NO HAPs Maximum (Worst-Case): 12.21 3.50 9.21 0.011 0.089 0.583 0.683 Cleanup Material: Barsol A-4165 6.64 1.99 0.00 0.00 0.00 0.00 0 00 No HAPs Notes: Federally exempt solvents (acetone, p-chlorobenzotnfiuoride) listed on material Environmental Data Sheets are not included. Federally exempt VOC t-butyl acetate was still included in the VOC content if listed on an EDS since it must be included in emissions reporting. As a worst case scenario of th e paint materials applied, a VO C content of 3.5 lb/gal is used. Glycol ethers are contained in some additive materials, they are accounted for with one topcoat material as a worst case analysis. One oth er HAP (ethybenzene) is con tained in one additive material, and is represented by the maximum HAP contents listed for the paint materials. Primer As Applied calculations are based on Ratios: for every 4.9 02 Part A, 1 02 Part B is added; for every 30 gal Part A, 144 oz TA070 is added.

Part A Part B TA070 Total Ratio (based on 1 gal Part A): 1 0 204 0.038 1.242 Ratio (1 gal as applied): 0.81 0.16 0.03 1.00

Paint Primer Material Parameters: HAPs HAPs

VOC Content Solids Content Ethylbenzene

(100-41-4) MIBK

(108-10-1) Material density VOC Content Solids Content

Ethylbenzene (100-41-4)

MIBK (108-10-1)

Material Content % by wt % by wt % by wt % by wt lb/gal lb/gal Ib/gal lb/gal lb/gal Part A 5274 DTM Epoxy Sealer 18.3% 79.9% 0.1% 2.0% 13.13 2.40 10.49 0.013 0.26

Part B 5271 DTM Epoxy Sealer Hardener 16.8% 50.4% 0.0% 17.0% 8.66 1.45 4.36 0.000 1.47

TA070 Tec/Prime Plus PS Speed Cure 60.0% 20.0% 0.0% 60.0% 7.16 4.30 1.43 0.000 4.30

Material Content - As Applied % by wt % by wt % by wt % by wt lb/gal ib/gal Ib/gal ib/gal Ib/gal

Part A 5274 DTM Epoxy Sealer 10.58 1.94 8.45 0.011 0.212

Part B 5271 DTM Epoxy Sealer Hardener 1.42 0.24 0.72 0.000 0.242

TA070 Tec/Prime Plus PS Speed Cure | 0.22 0.13 0.04 0.000 0.130

Primer As Applied: | 1B.9% | 75.3% | 0.1% [ 4.8% [ 12.21 | 2.30 | 9.21 | ' 0.011 1 0-5~Ii"

Calculation summary: Maximum Pollution

Maximum Uncontrolled Uncontrolled Control Controlled Maximum Limited Content Emission Rate Emissions Efficiency Emission Rate Controlled Controlled

Pollutant (ibs/gal) (Ib/hr) (tpv) {%) (Ib/hr) Emissions (tpy) Emissions (tpy) PM 9.21 25.90 113.46 85% 3.89 17.02 17.02 PM10 9.21 25.90 113.46 85% 3.89 17.02 17.02 PM„ 9.21 25.90 113.46 85% 3.89 17.02 17.02

VOC (paint spray) 3.50 39.38 172.48 0% 39.38 172.46 -VOC (cleanup) 1.99 1.99 8.72 0% 1.99 8.72 -VOC total ~ 41.37 181 19 0.00 41.37 181.19 181.19 HAPs (CAS): Ethylbenzene (100-41-4) 0.011 0.12 0.S2 0.00 0.12 0.52 0.52 Glycol Ethers 0.089 1.00 4 39 0.00 1.00 4.39 4.39 Methyl Isobutyl Ketone (108-10-1) 0.583 6.56 28.74 0.00 6.56 28.74 28.74 Total HAPs -- 7.68 33.65 0.00 7,68 33.65 33.65

2-Butoxy-ethyl Acetate

Mono-butyi Ether Acetate

Total Glycol Ethers Category

112-07-2 124-17-4 Total 6506 Urethane Metallic Clear 2.0% 2.0% 6573 Warm Weather Reducer 10.0% 6591 Prism Hardener 4.0% 4.0% Assume mixing ratio of 90% Paint 10% additive:

Ethylbenzene 6510 Prism Mixing Clear Additive 0.1% Assume mixing ratio of 90% Paint 10% additive:

Max times 1% additive in the paint mixture Add into o topcoat material to occount for

Max times 1% additive in the paint mixture Accounted for in the max HAP in paints already listed

Daktronics Incorporated - Redwood Falls, MN Facility Calculations Permit 12700055-002 Potential Emissions - Natu ral Gas Combustion - Spray Booth Heater

AQ Facility ID No.:

Facility Name:

Emission unit identification number:

Stack/Vent designation number:

Maximum Rated Capacity:

Control Equipment

Maximum Operating Hours/Year:

Fuel Parameters:

12700055 AQ File No.: 4443

Daktronics, Incorporated

EU 003 (Heater for Spray Booth) (202 Building)

SV 002

2.376 MMBtu/hr

None

8,760 Based on 24 hours/day, 365 days/year

Fuel Type % Sulfur % Ash Heat Value Units Fuel Consumption Rate

Natural Gas 0.2 Negligible 10 20 Btu/cf 20.41 MM scf/yr

Natural Gas: Heat and sulfur values from AP-42 Section 1.4 (July 1998), Tables 1.4-1 and -2.

Calculation summary - Primary Fuel: Natural Gas Maximum Limited

Emission Uncontrolled Maximum Pollution Controlled Controlled Controlled Factor1 Emission Rate Uncontrolled Control Emission Rate Emissions Emissions

Pollutant (Ib/MMcf) (Ib/hr) Emissions (tpy) Efficiency {%) (Ib/hr) (tpy) (tpy) PM 7.60 1.77E-02 7.75E-02 0% 1.77E-02 7.75E-02 7.75E-02 PMi0 7.60 1.77E-02 7.75E-02 0% 1.77E-02 7.75E-02 7.75E-02 PM25 7.60 1.77E-02 7.75E-02 0% 1.77E-02 7.75E-02 7.75E-02 SO; 0.60 1.40E-03 6.12E-03 0% 1.4QE-03 6.12E-03 6.12E-03 NO, 100 2.33E-01 1.02E+00 . 0% 2.33E-01 1.02E+00 1.02E+00 VOC 5.50 1.28E-02 5.61E-02 0% 1.28E-02 5.61E-02 5.61E-02 CO 84 1.96E-01 8.57E-01 0% 1.96E-01 8.57E-01 8.57E-01 Lead 0.0005 1.16E-06 5.10E-06 0% 1 16E-06 5.10E-06 5.10E-06 GHGs: (Ib/MMBtu) CO; 116.98 277.9 1217.4 0% 277.9 1217.4 1217.4 CH. 2.20E-03 5.24E-03 2.29E-02 0% 5.24E-03 2.29E-02 2.29E-02 N^O 2.20E-04 5.24E-04 2.29E-Q3 0% 5.24E-04 2.2 9E-03 2.29E-03 CO,e 117.10 278.2 1218.6 0% 278.2 1218.6 1218.6 HAPs (CAS): (Ib/MMCf) Arsenic (7440-38-2) 2.00E-04 4.66E-07 2.04E-06 C.00% 4.66E-07 2.04E-06 2.04E-06 Benzene (71-43-2) 2.10E-03 4.89E-06 2.14E-05 0.00% 4.89E-06 2.14E-05 2.14E-05 Beryllium (7440-41-7) 1.20E-05 2.80E-08 1.22E-07 C.00% 2.80E-08 1.22E-07 1.22E-07 Cadmium (7440-43-9) 1.10E-03 2.56E-06 1.12E-05 C.00% 2.56E-06 1.12E-05 1.12E-05 Chromium (7440-47-3) 1.40E-03 3.26E-06 1.43E-05 0.00% 3.26E-06 1.43E-05 1.43E-05 Cobalt (7440-48-4) 8.40E-05 1.96E-07 8.57E-07 0.00% 1.96E-07 8.57E-07 8.57E-07 1,4-Dichlorobenzene (106-46-7 1.20E-03 2.80E-06 1.22E-05 000% 2.80E-06 1.22E-05 1.22E-05 Formaldehyde (50-00-0) 7.50E-02 1.75E-04 7.65E-04 0.00% 1.75E-04 7.65E-04 7.65E-04 Hexane (110-54-3) 1.80E+00 4.19E-03 1.84E-02 0.00% 4.19E-03 1.84E-02 1.84E-02

Page 4 of IS

Manganese (7439-96-5) 3.8CE-04 8.85E-07 3.88E-06 0.00% 8.85E-07 3.88E-06 3.88E-06 Mercury (7439-97-6) 2.6CE-04 6.06E-07 2.65E-06 0.00% 6.06E-07 2.65E-06 2.65E-06 Naphthalene (91-20-3) S.1CE-04 1.42E-06 6.22E-06 0.00% 1.42E-06 6.22E-06 6.22E-06 Nickel (7440-02-0) 2 10E-03 4.89E-06 2.14E-05 0.00% 4.89E-06 2.14E-05 2.14E-0S POM S.98E-04 1.63E-06 7.12E-06 0.00% 1.63E-06 7.12E-06 7 12E-06 Selenium (7782-49-2) 2.4CE-05 5.59E-08 2.45E-07 0.00% 5.59E-08 2.45E-07 2 45E-07 Toluene (108-88-3) 3.40E-03 7.92E-06 3.47E-05 0.00% 7.92E-06 3.47E-0S 3.47E-05 Total HAPs 4.40E-03 1.93E-02 4.40E-03 1.93E-02 1.93E-02 Notes:

Emission factors from AP-42 Section 1 4 "Natural Gas Combustion" (July 1998), Tables 1.4-1 and -2. PM2 s conservative ly assumed to equal PM,-. Dichlorobenzene (CAS 25321-22-6) is not a HAP; therefore, it is conservatively represented as the HAP isomer 1,4-Dichlorobenzene (CAS 106-46-7). GHG emission fact ors from 40 CFR Part 98, Subpart C. C02e EF calculated based on Global Warming Potential (GWP) as follows:

GHG Pollutant GWP

Mass EF (kg/MMBtu)

Mass EF (Ib/MMBtu)

C02e EF

(Ib/MMBtu) CO, 1 53.06 116.98 116.98 CH- 25 1.00E-03 2.20E-03 5.51E-02 N;C 298 1.00E-04 2.20E-04 6.57E-02 CQ,e ... 117.10

Conversion factor: 2.2046 lb/kg

Naphthalene is included in the PCM emissions and is not double-counted in the total HAPs. The panel filter control equipment on the Spray Booth is n ot relied on for the natural gas combustion, which also vents to SV 002

MN Standards of Performance for Indirect Heating Equipment, for <250 MMBtu/hr heat input per equip. & <250 MMBtu/hr for total facility: PM< 0.4 ib/MMBtu PM = 7.60 ib/MMcf HHV = 1020 btu/cf PM = 0.00745098 Ib/MMBtu OK

POM 2-Methylnaphthalene 91-57-4 2.40E-05 3-Methylchloranthrene 56-49-5 1.80E-06 7,12-Dimethylhenz(a)anthracen 57-97-6 1.60E-05 Acenaphthene 83-32-9 1.80E-06 Acenaphthyfene 203-96-8 1.80E-06 Anthracene 120-12-7 2.40E-06 Benz(a)anthracene 56-55-3 1.80E-06 Benzo(a)pyrene 50-32-8 1.20E-06 Benzo(b)fluoranther»e 205-99-2 1.80B-06 Benzo(g/h,i)pery!ene 191-24-2 1.20E-06 Benzo(k)fluoranthene 205-82-3 1.80E-06 Chrysene 218-01-9 1.80E-06 Dibenzo(a,h)anthracene 53-70-3 1.20E-06 Fluoranthene 206-44-0 3.00E-06

Flourene 86-73-7 2.80E-06 lndeno(l,2,3-cd)pyrene 193-39-5 1.80E-06

Naphthalene 91-20-3 6.10E-04 Phenanthrene 85-01-8 1.70E-05 Pyrene 129-00-0 5.00E-06 Total w/Naphthaiene 6.98E-04 Total w/out Naphthalene 8.82E-05

Page 5 of 15

Daktronics Incorporated - Redwood Falls, MN Facility Calculations Permit 12700055-002 Potential Emissions • Natural Gas Combustion - Bake Oven

AQ Facility ID No.:

Facility Name:

Emission unit identification number: Stack/Vent designation number:


Control Equipment

12700055 AQ File No.: 4443

Daktronics, incorporated EU 004 (Bake Oven) (202 Building)

MMBtu/hr

Maximum Operating Hours/Year: Based on 24 hours/day, 365 days/year

Fuel Parameters:

Fuei Type % Sulfur % Ash Heat Value Units Fuel Consumption Rate

Natural Gas 0.2 Negligible 1020 | Btu/cf 18.55 |MM scf/yr

Natural Gas: Heat and sulfur values from AP-42 Section 1.4 (July 1998), Tables 1.4-1 and -2.

Calculation summary - Primary Fuel: Natural Gas Maximum Maximum Limited

Emission Uncontrolled Uncontrolled Pollution Controlled Controlled Controlled Factor1 Emission Rate Emissions Control Emission Emissions Emissions

Pollutant (Ib/MMcf) (Ib/hr) (tpy) Efficiency {%) Rate (Ib/hr) (tpy) (tpy) PM 7.60 1.61E-02 7.05E-02 0% 1.61E-02 7.05E-02 7.05E-02 PM10 7.60 1 61E-02 7.05E-02 0% 1.61E-02 7.05E-02 7.05E-02 PM2.5 7.60 1 61E-C2 7.05E-02 0% 1.61E-02 7.05E-02 7.05E-02 S02 0.60 1.27E-03 5.57E-03 0% 1.27E-03 5.S7E-03 5.57E-03 NO, 100 . 2 3 2E-C1 9.28E-01 0% 2.12E-01 9.28E-01 9.28E-01 VOC 5.50 i 16E-C2 5.10E-02 0% 1.16E-02 5.10E-02 5.10E-02 CO 84 1 78E-01 7.79E-01 0% 1.78E-01 7.79E-01 7.79E-01 Lead 0.0005 1 06E 06 4.64E-06 0% 1.06E-06 4.64E-06 4.64E-06 GHGs: (Ib/MMBtu) co2 116.98 252.7 1106.7 0% 252.7 1106.7 1106.7 CH4 2.20E-03 4.76E-03 2.09E-02 0% 4.76E-03 2.09E-02 2.09E-02 N2O 2.20E-04 4.76E-04 2.09E-03 0% 4.76E-04 2.09E-03 2.09E-03 C02e 117.10 252.9 1107.8 0% 252.9 1107.8 1107.8 HAPs (CAS): (Ib/MMCf) Arsenic (7440-38-2) 2.00E-04 4 24E-07 1.86E-06 0.00% 4.24E-07 1.86E-06 1.86E-06 Benzene (71-43-2) 2.10E-D3 4 4SE-06 1.95E-05 0.00% 4.45E-06 1.95E-05 1.95E-05 Beryllium (7440-41-7) 1.20E-05 2 54E-08 1.11E-07 0.00% 2.54E-08 1.11E-07 1.11E-07 Cadmium (7440-43-9) 1.10E-03 2 33E-06 1.02E-05 0.00% 2.33E-06 1.02E-05 1.02E-05 Chromium (7440-47-3) 1.40E-03 2 96E-06 1.30E-05 0.00% 2.96E-06 1.30E-05 1.30E-05 Cobalt (7440-48-4) 8.40E-05 1.78E-C7 7.79E-07 0.00% 1.78E-07 7.79E-07 7.79E-07 Dichlorobenzene (25321-22-6) 1.20E-03 2.54E-06 1.11E-05 0.00% 2.54E-06 1.11E-05 1.11E-05 Formaldehyde (50-00-0) 7.50E-02 1.59E-04 6.96E-04 0.00% 1.59E-04 6.96E-04 6.96E-04

Hexane (110-54-3) 1.80E+00 3.81E-03 1.67E-02 0.00% 3.81E-03 1.67E-02 1.67E-02 Manganese (7439-96-5) 3.80E-04 8.05E-07 3.52E-06 0.00% 8.05E-07 3.52E-06 3.52E-06 Mercury (7439-97-6) 2.60E-04 5.51E-07 2.41E-06 0.00% 5.51E-07 2.41E-06 2.41E-06 Naphthalene (91-20-3) 6.10E-04 1.29E-06 5.66E-06 0.00% 1.29E-06 5.66E-06 5.66E-06 Nickel (7440-02-0) 2.10E-03 4.45E-06 1.95E-05 0.00% 4.45E-06 1.95E-05 1.95E-05 POM 6.98E-04 1.48E-06 6.48E-06 0.00% 1.48E-06 6.48E-06 6.48E-06 Selenium (7782-49-2) 2.40E-05 5.08E-08 2.23E-07 0.00% 5.08E-08 2.23E-07 2.23E-07 Toluene (108-88-3) 3.40E-03 7.20E-06 3.15E-05 0.00% 7.20E-06 3.15E-05 3.15E-05 Total HAPs 4.00E-03 1.75E-02 4.00E-03 1.75E-02 1.75E-02 Notes: Emission factors from AP-42 Section 1.4 "Natural Gas Combustion" (July 1998), Tables 1.4-1 and -2. PM 2S conservatively assumed to equal PM10. GHG emission factors from 40 CFR Part 98, Subpart C. C02e EF calculated based on Global Warming Potential (GWP) as follows:

GHG Pollutant GWP Mass EF

(kg/MMBtu) Mass EF

(Ib/MMBtu) CO;e EF

(Ib/MMBtu) C02 1 53.06 116.98 116.98 CHa 25 1.00E-03 2.20E-03 5 51E -C2 N;0 298 1.00E-04 2.20E-Q4 6 57E-C2 C02e — 117.10

Conversion factor: 2.2046 ib/kg

Naphthalene is included in the POM emissions and is not doubie-counted in the total HAPs

MN Standards of Performance for Indirect Heating Equipment, for <250 MMBtu/hr heat input per equip. & <250 MMBtu/hr for total facility: PM< 0.4 Ib/MMBtU PM = 7.60 Ib/MMcf HHV = 1020 btu/cf PM = 0.00745098 Ib/MMBtu

POM 2-Methylnaphthaiene 91-57-4 2.40E-05 3-Methylchloranthrene 56-49-5 1.80 E-06 7,12-Dimethylbenz(a)anthracene 57-97-6 1.60E-05 Acenaphthene 83-32-9 * 1.80E-06 Acenaphthylene 203-96-8 1.80E-06 Anthracene 120-12-7 2.40E-06 Benz(a)anthracene 56-55-3 1.80E-06 Benzo(a)pyrene 50-32-8 1.20E-06 Benzo(b)fluoranthene 205-99-2 1.80E-06 Benzo(g,h,i)perylene 191-24-2 1.20E-06 Benzo(k)fluoranthene 205-82-3 1.80E-06 Chrysene 218-01-9 1.80E-06 Dibenzo(a,h)anthracene 53-70-3 1.20E-06 Fluoranthene 206-44-0 3.00E-06 Flourene 86-73-7 2.80E-06 lndeno(l,2,3-cd)pyrene 193-39-5 1.80E-06 Naphthalene 91-20-3 6.10E-04

Phenanthrene 85-01-8 1.70E-05

Pyrene 129-00-0 5.00E-06 Total w/Naphthalene 6.98E-04 Total w/out Naphthalene 8.82E-05

Daktronics Incorporated - Redwood Falls, MN Facility Calculations Permit 12700055-002 Allowable Total Particulate Emissions under Minnesota State Process Equipment Rule (7011.0700 - 7011.0735)

Process Information:

EU

Process Weight Dry Weight Airflow Exit Gas Moisture Airflow

EU Ibs/hr Total

% Solids (total less

water) Ib/hr ton/hr acfm Temp (°F) % scfm dscfm 002 - Spray Booth 104 100% 104 0.05 20,000 70 0.0% 19,925 19,925 003 - Heater on Spray Booth

0 0% 0 0.00 20,000 70 0.0% 19,925 19,925

004 - Bake Oven 0 0% 0 0.00 2,000 130 0.0% 1,790 1,790 Input Data scfm = acfm * ((460+68)/(460+Exit Gas Temp)) dscfm = scfm * (1-% moisture) Notes: EU 002 spray booth process weight = max solids content of paint materials (9.21 lb/gal) * application rate 11.25 gal/hr = 104 Ib/hr. EU 003 and 004 nat gas combustion: Gaseous fuels and combustion air are not part of the process weight per MN R. 7011.0700 Subp. 4.

Allowable Emissions: Hourly emission rates may be limited by the Industrial Process Equipment Rule (IPER). However, if potential emissions are less than limits required by IPER, PTE will be used to demonstrate compliance with IPER. Allowable emissions for IPER are calculated by:

Process Weight: E = 3.59 x (P)°62, where E = emissions in Ib/hr, and P = process we ight in tons/hr -OR-

Airflow: c = 1.7627 x FRcorrected"0'3241 where c = concentration in gr/dscf, FRcorrected = gas volume in dscfm. The allowable total particulate rate is the less stringent of the two methods (process weight or airflow), not to exceed a maximum rule limit of 0.3 gr/dscf. However, if corrected airflow is 7000 dscfm or less, the limit is 0.1 gr/dscf. This method valid for process weights up to 30 tons/hr.

EU

by Process Weight by Airflow Total Particulate Allowable Comparison to PTE

EU calculated:

Ib/hr converted to:

gr/dscf calculated:

gr/dscf converted to:

Ib/hr Ib/hr gr/dscf Ib/hr Notes 002 - Spray Booth 0.57 0.003 0.071 12.17 12.17 0.0712 3.89 Maximum controlled

potential hourly rate is < allowable rate

Conversion factor: 7000 gr/lb

Daktronics Incorporated - Redwood Falls, MN Facility

Calculations Permit 12700055-002 Potential Emissions - N atural Gas Combustion - Space Heaters (202 Building)

AQ Facility ID No.: 12700055

Facility Name:

Emission unit identification number:

AQ File No.: 4443

Daktronics, Incorporated


Control Equipment


IA - Space Heaters (202 Building)

Number of Units

Individual Capacity

(MMBtu/hr) Total Capacity (MMBtu/hr)

4 0.117 0.468

None

None

0.117 MMBtu/hr Max individual unit capacity

Maximum Operating Hours/Year:

Fuel Parameters:


Fuel Type % Sulfur % Ash Heat Value Units Fuel Consumption Rate

Natural Gas 0.2 Negligible 1020 Btu/cf 1.00 MM scf/yr

Natural Gas: Heat and sulfur values from AP-42 Section 1.4 (July 1998), Table 1.4-1 and -2.

Calculation summary - Primary Fuel: Natural Gas Per Unit, Based on the Max Unit Capacity

MN R. Maximum 7007.1300 Subp Each unit

Emission Uncontrolled Uncontrolled 3(0 IA qualifies as IA Factor Emission Rate Emissions Threshold under subp.

Pollutant (Ib/MMcf) (Ib/hr) (Ibs/yr) (Ibs/yr) 3(1)?

PM 7.60 0.001 7.637 2000 Yes PMi0 7.60 0.001 7.637 2000 Yes

PM25 7.60 0.001 7.637 N/A N/A

S02 0.60 0.000 0.603 2000 Yes

NO, 100 0.011 100.482 2000 Yes

VOC 5.50 0.001 5.527 2000 Yes

CO 84 0.010 84.405 4000 Yes

Lead 0.0005 5.74E-08 0.001 N/A N/A

MN Standards of Performance for Indirect Heating Equipment,

for <250 MMBtu/hr heat input per equip.

& <250 MMBtu/hr for total facility:

PM < 0.4 Ib/MMBtu

PM EF = 7.60 Ib/MMcf

HHV = 1020 btu/cf

PM = 0.00745098 Ib/MMBtu OK

GHGs: (Ib/MMBtu) (tpy) (tpy) C02 116.98 13.69 59.95 N/A N/A

CH4 2.20E-0B 2.58E-04 1.13E-03 N/A N/A

N2O 2.20E-04 2.58E-05 1.13E-04 N/A N/A

C02e 117.10 13.70 60.007 1,000 Yes

Notes:

Emission factors from AP-42 Section 1.4 "Natural Gas Combustion" (July 1998), Tables 1.4-1 and -2. PM2 s conservatively assumed to equal PM10. GHG

emission factors from 40 CFR Part 98, Subpart C. C02e EF calcu lated based on Global Warming Potential (GWP) as fo llows:

GHG Pollutant GWP

Mass EF (kg/MMBtu)

Mass EF (Ib/MMBtu)

C02e EF (Ib/MMBtu)

C02 1 53.06 116.98- 116.98

CH« 25 1.00E-03 2.20E-03 5.51E-02

N20 298 1.00E-04 2.20E-04 6.57E-02

C02e ... — — 117.10


Daktronics Incorporated - Redwood Fails, MN Facility Calculations Permit 12700055-002 Potential Emissions - Natural Gas Combustio n - Makeup Air Unit (202 Building)

AQ Facility ID No.: 12700055 AQ File No.: 4443 Facility Name: Daktronics, Incorporated Emission unit identification number: IA - Makeup Air Unit (one unit) (202 Building) Stack/Vent designation number: None Control Equipment None Maximum Rated Capacity: 0.540 MMStu/hr

Maximum Operating Hours/Year: 8,760 Based on 24 hours/day. 365 days/year

Fuel Parameters: Fuel Type % Sulfur % Ash Heat Value Units Fuel Consumption Rate

Natural Gas 0.2 Negligible 1020 Btu/cf 4.64 MMscf/yr Natural Gas: Heat and sulfur values from AP-42 Section 1.4 (July 1998), Tables 1.4-1 and -2

Calculation summary - Primary Fuel: Natural Gas MN R.

Maximum 7007.1300 Each unit Emission Uncontrolled Uncontrolled Subp 3(1) IA qualifies as IA

Factor Emission Rate Emissions Threshold under subp. Pollutant (ib/MMcf) flb/hr) (Ibs/yr) (Ibs/yr) 3(1)?

PM 7.60 0.004 35.246 2000 Yes PMic 7.60 0.004 35.246 2000 Yes PM2i 7.60 0.004 35.246 N/A N/A

SO, 0.60 " 0.000 2.783 2000 Yes

WO, 100 0.053 463.765 2000 Yes

voc 5.50 0.003 25.507 2000 Yes

CO 84 0.044 389.562 4000 Yes

Lead 0.0005 2.65E-07 0.002 N/A N/A

GHGs: (Ib/MMBtu) (tpy) (tpy) CO, 116.98 63.17 276.67 N/A N/A

CHd 2.20E-03 1.19E-03 5.21E-03 N/A N/A

N20 2.20E-04 1.19E-04 5.21E-04 N/A N/A

C02e 117.10 63.23 276.96 1,000 Yes

MN Standards of Performance for Indirect Heating Equipment, for <250 MMBtu/hr heat input per equip. & <250 MMBtu/hr for total facility:

PM < 0.4 Ib/MMBtu

PM EF = 7.60 ib/MMcf HHV = 1020 btu/cf

PM = 0.00745098 Ib/MMBtu OK

Motes: Emission factors from AP-42 Section 1.4 "Natural Gas Combustion" (July 1998), Tables 1.4-1 and -2. PM2^ conservatively assumed to equal PM10. GHG emission factors from 40 CFR Part 98, Subpart C. C02e EF calculated based on Global Warming Potential (GWP) as follows:

GHG Pollutant GWP

Mass EF (kg/MMBtu)

Mass EF (Ib/MMBtu)

C02e EF (Ib/MMBtu)

CO, 1 53.06 116.98 116.98

CH4 25 1.00E-03 2.20E-03 5.51E-02

N2O 298 1.00E-04 2.20E-04 6.57E-02

C02e — - 117.10


Daktronics Incorporated - Redwood Falls, MN Facility Calculations Permit 12700055-002 Potential Emissions - Natural Gas Combustion - Makeup Air Units (1425 Building) 'NutAH'

AQ Facility ID No.: 12700055 AQ File No.: 4443 Facility Name: Daktronics, Incorporated Emission unit identification number: IA - Makeup Air Units (1425 Building)

Individual Number of Capacity Total Capacity

Units (MMBtu/hr) (MMBtu/hr)

5 0.224 1.120

1 0.115 0.115

1 0.350 0.350 4 0.400 1.600

8 0.116 0.928

1 0.606 0.606

20 4.719

Stack/Vent designation number: None

Control Equipment None

Maximum Rated Capacity: 0.606 MMBtu/hr Max individual unit capac ity

Maximum Operating Hours/Year: 8,760 Based on 24 hours/day, 365 days/year

Fuel Parameters: Fuel Type % Sulfur % Ash Heat Value Units Fuel Consumption Rate

Natural Gas 0.2 Negligible 1020 Btu/cf 5.21 MM scf/yr

Natural Gas: Heat and sulfur values from AP-42 Section 1.4 (July 1998), Table 1.4-1 and -2.

MN Standards of Performance for Indirect Heating Equipment, for <250 MMBtu/hr heat input per equip.

& <250 MMBtu/hr for total facility: PM < 0.4 Ib/MMBtu

PM EF = 7.60 Ib/MMcf

HHV = 1020 btu/cf PM = 0.01 Ib/MMBtu OK

Calculation summary - Primary Fuel: Natural Gas

Pollutant

Emission Factor

(Ib/MMcf)

Uncontrolled Emission Rate

(Ib/hr)

Maximum Uncontrolled

Emissions (Ibs/yr)

MN R. 7007.1300

Subp 3(1) IA Threshold (Ibs/yr)

Each unit qualifies as IA under subp.

3(1)? PM 7.60 0.005 39.560 2000 Yes PMio 7.60 0.005 39.560 2000 Yes

PM2.5 7.60 0.005 39.560 N/A N/A so2 0.60 0.000 3.123 2000 Yes NO, 100 0.059 520.525 2000 Yes

VOC 5.50 0.003 28.629 2000 Yes

CO 84 0.050 437.241 4000 Yes

Lead 0.0005 2.97E-07 0.003 N/A N/A

GHGs: (Ib/MMBtu) (tpv) (tpy) C02 116.98 70.90 310.53 N/A N/A CH„ 2.20E-03 1.34E-03 5.85E-03 N/A N/A N20 2.20E-04 1.341-04 5.85E-04 N/A N/A C02e 117.10 70.97 310.855 1,000 Yes

Notes: . Emission factors from AP-42 Section 1.4 "Natural Gas Combustion" (July 1998), Tables 1.4-1 and -2. PM2 5 conservatively assumed to equal PMi0. GHG emission factors from 40 CFR Part 98, Subpart C. CQ2e EF calculated based on Global Warming Potential (GWP) as follows:

GHG Pollutant GWP

Mass EF (kg/MMBtu)

Mass EF (Ib/MMBtu)

C02e EF (Ib/MMBtu)

CO; 1 53.06 116.98 116.98

CH4 25 1.00E-03 2.20E-03 S.51E-02

N2O 298 1.00E-04 2.20E-04 6.57E-02

C02e ... ... ... 117.10


Summary - Change in PTE: 8 Units 1 Unit MN R.

7007.1250 Modification Emission Rate Total Emission Emission Rate Total Emission Subp IB Insig Emission Rate

(Ib/hr) Rate (Ib/hr) (Ib/hr) Rate (Ib/hr) Mod (Ib/hr) < Pollutant per unit 8 Units per unit 9 Units Threshold Threshold?

PM 8.64E-04 6.91 E-03 4.52E -03 1.14E 02 0.855 Yes PM10 8.641:-04 6.91E-03 4.52E 0 3 1.14E 02 N/A N/A

PM„ 8.641-04 6.911 03 4.S2E -03 1.14E-02 N/A N/A

S02 6.82E-05 5.46 E-04 3.57E-04 9.02E-04 2.28 Yes

NO, 1.14E-02 9.10E-02 5.94E-02 1.50E-01 2.28 Yes

VOC 6.25E-04 5.00E-03 3.27E-03 8.27E-03 2.28 Yes CO 9.55E-03 7.64E-02 4.99E-02 1.26E-01 5.70 Yes Lead 5.69E-08 4.55E-07 2.97E-07 7.52E-07 0.025 Yes C02e 13.58 108.67 70.97 179.64 N/A N/A

Daktronics Incorporated - Redwood Falls, MN Facility

Calculations Permit 12700055-002 Potential Emissions - Sanding Machine (Subp. 7008.4110 Insignificant Activity)

Supplemental Submittal Prepared by Wenck Associates, Inc. 2/25/2015

Calculations are provided to MPCA to demonstrate that the lA unit does not trigger CAM. Referring to MPCA form GH-09H (most recent version available on MPCA website is 4/21/14): In generalCAM applies to emission units meeting the following criteria: 1. The emission unit is subject to an emission limit or standard (including limits and standards in Minnesota Rules contained in the State Implementation Plan) for an air pollutant regulated by Part 70. 2. Compliance with the applicable limit or standard is achieved through the use of add-on control equipment. 3. The emission unit has pre-controlled potentia l emissions of the applicable regulated air pollutant that are equal to or greater than 100 percent of the Part 70 major source level for that pollutant (in tons per year).

Conclusions: PM/PM10/PM2.5 uncontrolled potential to emit is <100 tpy, which is 100% of the Part 70 Major Source Level for those pollutants. This demonstration shows that the unit does not meet all three of the above criteria, and CAM is not applicable to the unit.

AQ Facility ID No.:

Facility Name: Emission unit identification number:


Control Equipment

12700055 AQ File No.: 4443

Daktronics, Incorporated IA (7008.4110) - Sanding Machine

(Internally Vented) (Wet Dust Collector)

Maximum Operating Hours/Year.

Actual Operating Hours/Year


1,678 Actual 2014 Hours of Operation

Calculated Emission Factor

(Ibs/ft2)

Process Throughput Rate

(ft2/hr) Emission Rate

(Ibs/hr)

Maximum Uncontrolled

Emissions (tons/yr)

Actual Uncontrolled Emissions

(tons/yr)

Pollution Control Efficiency

(%)

Maximum Controlled Emissions (tons/yr)

Actual Controlled Emissions (tons/yr)

PM 8.23E-05 3600 0.296 1.30 0.25 No credit taken 1.30 0.25 PM10 8.23E-C5 3600 0.296 1.30 0.25 No credit taken 1.30 0.25 PM2. 8.23E-CS 3600 0.296 1.30 0.25 No credit taken 1.30 0.25

No credit is taken for the wet scr jbber control equipment for this CAM demonstration.

Process Throughput Rate. Machine Belt Speed: 12 ft/min Max Width of Sheet throjgh Machine: 60 inches = 5.0 feet Max Surface Area Processed through Machine: 60 ft2 / min = 360Cft2/hr

Development of Site Specific Emission Factor: This represents the typical material processed / thickness sanded in the machine. Based on Daktronics measurements of 4, 4"x4" pieces of metal sanded in machine. Total Surface Area, 4 pieces 64 in2 = 0.4444 ft2 Total Weight before sanding, 4 pieces: 178.9279 grams Total Weight after sand ng, 4 pieces: 178.9196 grams Weight Sanded, 4 pieces. 0.0083 grams Calculated Emission Factor (weight sanded / surface area): 0.018675 grams/ft2 = 4.12E-05 Ib/ft2 Conversion Factor: 0.0022046 lb/gram

Apply a safety factor to account for small variability in sanding thickness:

Safety Factor 2

Calculated Emission Factor (weight sanded / surface area) w/Safety Factor: 8.23E-05 Ib/ft2

Daktronics Incorporated - Redwood Falls, MN Facility Calculations Permit 1270005S-002 Insignificant Modification Summary -EU 001 (Solvent/Rage Wipedown) Process Changes 2014

AQ Facility ID No.: 12700055 AQ File No,: 4443

Facility Name: Daktronics, Incorporated

Emission unit identification number: EU 001 (Solvent/Rag Wipedown)

Stack/Vent designation number: SV 001

Control Equipment None __

Insignificant Modification Description for EU 001: 1. Changed the original wipe step (prior to entering paint booth) from 6282 Klean? Easy so lvent to 99% Isopropyl Alcohol (IPA). 2. Added another wipe step using IPA 99%, similar to the original wipe step. This step is done prior to sanding. After sanding, the original wipe step is then completed prior to the part entering the paint booth.

Original EU 001 PTE Calculations: Process Description:

Solvent is used to wipe down parts prior to them entering the paint booth, Solvent is poured into a bucket which contains towels; the towels are then used to wipe the parts. Solvent use is 2 gallons per 12 hour shift.

Material Parameters: Usage Rate Usage Rate Toluene

Material (gal/12 hr) (gal/hr) Density (lb/gal) VOC (%) VOC (lb/gal) Toluene (%) (lb/gal)

6383 Kleanz-Easy 2 0.167 6.44 100% 6.44 11.09% 0.71

Calculation summary:

Maximum Uncontrolled Maximum Pollution Controlled Maximum Limited Content Emission Rate Uncontrolled Control Emission Rate Controlled Controlled

Pollutant (lbs/gal) (Ib/hr) Emissions (tpy) Efficiency (%) (Ib/hr) Emissions (tpy) Emissions (tpy)

VOC 6.44 1.073 4.70 0% 1.07 4.70 95*

HAPs

Toluene (108-88-3) 0.71 0.12 0.52 0% 0.12 0.52 0.52

Total HAPs 0.12 0.52 0% 0.12 0.52 0.52

*Facifity permitted VOC limit is 95 tons/year for EU 001 and FU 002. This limit is now being removed in this permit process as outined in the TSD. Modification - EU 001 PTE Calculations: Process Description:

Solvent is used to wipe down parts prior to them entering the paint booth. Solvent is poured into a bucket which contains towels; the towels are then used to wipe the parts. Parts are wiped prior to sanding and following sanding (prior to entering the paint booth). Solvent use is 2 gallons per 12 hour shift per wiping step, for a t otal of 4 gallons per 12 hour shift.

Material Parameters:

Material Usage Rate (gal/12 hr)

Usage Rate (gal/hr) Density (lb/gal) VOC (%) VOC (lb/gal) HAP HAP (lb/gal)

99% Isopropyl Alcohol 4 0.333 6.59 100% 6.59 None None

Calculation summary:

Maximum Uncontrolled Maximum Pollution Controlled Maximum Limited Content Emission Rate Uncontrolled Control Emission Rate Controlled Controlled

Pollutant (lbs/gal) (Ib/hr) Emissions (tpy) Efficiency (%) (Ib/hr) Emissions (tpy) Emissions (tpy)

VOC 6.59 2.197 9.62 0% 2.20 9.62 95*

HAPs None 0.00 0.00 0.00 0% 0.00 0.00 0.00

^Facility permitted VOC limit is 95 tons/year for EU 001 and EU 002. This limit is now being removed in this permit process as outined in the TSD. Summary - Change in PTE for EU 001:

Pollutant Emission Rate

(Ib/hr)

MN R. 7007.1250 Subp IB Insig

Mod Threshold (Ib/hr)

Modification Emission Rate

(Ib/hr) < Threshold?

VOC 1.12 2.28 Yes Toluene (HAP) 0.12 N/A N/A

Page 15 of 15


Attachment 2 Facility Description and CD-01 Forms

8.July, 2015 14:00

FACILITY DESCRIPTION: CONTROL EQUIPMENT (CE)

ID No. Control Equip. Status

Added By

(Action)

Retired By

(Action;

Operator ID

fcr Item

Control Equip. Type

Control Equipment Description Manufacturer Model Pollutants Controlled

Capture Efficiency

(%) Destruction/ Collection Efficiency

(%)

Afterburner Combustion Parameters

1 CE 001 Active EIS 001 058 Mat or Panel Filter Paint Pockets PP-G20-020 PM2.5 100 85 PM10 100 85 PM 100 85

Page 1 of 1

MINNESOTA POLLUTION C'ONTROl ACiFNCY AIR QU ALITY 520 LAFAYETTE ROAD ST PAUL. MN 55 155-4194

Show: Active and Pending Records

Action: PER 002

AQD Facility ID: 12700055

Facility Name: Daktronics Inc

MINNESOTA POLLUTION CONTROL AGENCY AIR QUALITY 520 LAFAYETTE ROAD ST. PAUL. MN 55155-4194


Action: PER 002



8 July, 2015 14:02

FACILITY DESCRIPTION: EMISSION UNIT (EU)

ID No. Emission Unit

Status

Added By

(Action)

Retired By

(Action)

Insignificant

Activity

Operator ID

for Item

Stack/ Vent

ID No(s).

Controi Equip.

ID No(s).

Operator Description Manufacturer Model Number

SiC Max. Design

Capacity

Ma D

Ca

Materials

ximum 2Sign pacity

Units n Units d

Max Fuel Input

(mil Btu)

1 EU 001 Active EIS 001 SV 001 (M) Solvent/Rag Wipedown None (manual) None 3993 .083 Coating Gal Hr

2 EU 001 Active PER 002 SV001 (M) Solvent/Rag Wipedown -Solvent Equipment

None (manual) None 3993 0.667 Coating Gal Hr

3 EU 002 Active EIS 001 SV 002 (M) CE 001 Spray Booth Tecor Series 5000 3993 11.25 Coating Gal Hr

4 EU 002 Active PER 002 SV 002 (M) CE 001 Spray Booth - Spray Booth/Coating Line

Tecor Series 5000 3993 11.25 Coating Gal Hr

5 EU 003 Active EIS 001 SV 002 (M) Heater for Spray Booth Tecor ARTT218HH 3993 2.376 Natural Gas Mmbtu Hr 2.376

6 EU 003 Active PER 002 SV 002 (M) Heater for Spray Booth -Process Heater

Tecor ARTT218HH 3993 2.376 Heat Mmbtu Hr 2.376

7 EU 004 Active EIS 001 SV 003 (M) Bake Oven Tecor ARTT218HHL 3993 2.160 Natural Gas Mmbtu Hr 2.160

8 EU 004 Active PER 002 SV 003 (M) Bake Oven - Dryer/Oven, qirect firing method

Tecor ARTT218HHL 3993 2.160 Heat Mmbtu Hr 2.160

9 EU 005 Active EIS 001 3993

10 EU 005 Removed PER 002 3993

Page 1 of 1 (a)

8 July, 2015 14:02

FACILITY DESCRIPTION: EMISSION UNIT (EU)

ID No. Emission Unit

Status

Added By

(Action)

Commence

Const. Date

Initial Startup

Date

Removal Date

Firing Method Pet. Fuel/

Space Heat

Bottleneck Elevator Type

1 EU 001 Active EIS 001 01/30/2009 01/30/2009

2 EU 001 Active PER 002 01/30/2009 01/30/2009

3 EU 002 Active EIS 001 08/11/2007 09/11/2007

4 EU 002 Active PER 002 08/11/2007 09/11/2007

5 EU 003 Active EIS 001 08/11/2007 09/11/2007

6 EU 003 Active PER 002 08/11/2007 09/11/2007

7 EU 004 Active EIS 001 08/11/2007 09/11/2007

8 EU 004 Active PER 002 08/11/2007 09/11/2007

9 EU 005 Active EIS 001

10 EU 005 Removed PER 002

Page 1 of 1 (b)

MINNESOTA POLLUTION CONTROL AGENCY AIR QUALITY 520 LAFAYETTE ROAD ST. PAUL. MN 55155-4194

8 July, 2015 13:59

FACILITY DESCRIPTION: STACK/VENTS (SV)


Action: PER 002



ID No. Stack/ Vent

Status

Added By

(Action)

Retired By

(Action)

Operator ID

for Item

Operators Description Height of Opening

From Ground (feet)

Inside Dimensions Design Flow Rate

at TOD (ACFM)

Exit Gas Temperature

at Top (°F)

Flow Rate/ Temperature

Information Source

Discharge Direction ID No. Stack/ Vent

Status

Added By

(Action)

Retired By

(Action)

Operator ID

for Item

Operators Description Height of Opening

From Ground (feet)

Diameter or Length

(feet)

Width (feet)

Design Flow Rate

at TOD (ACFM)

Exit Gas Temperature

at Top (°F)

Flow Rate/ Temperature

Information Source

Discharge Direction

1 SV 001 Active EIS 001 Solvent Rag/Wipeacwn 9.83 2.08 2.08 2650 70 Estimate Horizontal

2 SV 002 Active EIS001 Spray Booth 26 3 20000 70 Estimate Up, No Cap

3 SV 003 Active EIS 001 Bake Oven 26 1.17 2000 130 Estimate Up, No Cap

Page 1 of 1

MINNESOTA POLLUTION CON TROL AC/.KNCY AIR Q UALITY 520 I.AI-AYL I TL ROAD ST. PAUL. MN 55155-4194

Page 1 of 21 8 Jul, 2015 14:08

COMPLIANCE PLAN CD-01 Facility Name:

Permit Number:

Subject Item:

Daktronics Inc

12700055-002

Total Facility

NC/ CA

Type Citation Requirement

1.0 CD hdr SOURCE-SPECIFIC REQUIREMENTS

2.0 CD Minn. R. 7007.0800, subp. 2 Permit Appendices: This permit contains appendices as listed in the permit Table of Contents. The Permittee shall comply with all requirements contained in the appendices.

3.0 CD hdr OPERATIONAL REQUIREMENTS

4.0 CD Minn. Stat. Section 116.07, subp. 4a; Minn, Stat. Section 116.07, subp. 9; Minn. R. 7007.0100, subp. 7(A); Minn. R. 7007.0100. subp. 7(L): Minn R. 7007.0100, subp 7(M); Minn R 7007 0800. subps. 1-2: Minn R 7007 0800, subp 4; Minn R 7009 0010-7009.0080

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

5.0 CD Minn. R. 7011 0020 Circumvention: Do not install or use a device or means that conceals or dilutes emissions, which would otherwise violate a federal or state air pollution control rule, without reducing the total amount of pollutant emitted.

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

Air Pollution Control Equipment: Operate all pollution control equipment whenever the correspQnding process equipment and emission units are operated.

7.0 CD Minn. R. 7007.0800, subp. 14; Minn. R. 7007.0800, subp. 16(J)

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

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

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

10.0 CD Minn R. 7030.0010 - 7030.0080 Noise: The Permittee shall comply with the noise standards set forth in Minn. R. 7030 0010 to 7030.0080 at al l times during the operation of any emission units. This is a state only requirement and is not enforceable by the EPA Administrator or citizens under the Clean Air Act

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

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

13.0 CD hdr PERFORMANCE TESTING

14.0 CD Minn. R. Ch. 7017 Performance Testing: Conduct all performance tests in accordance with Minn. R. ch. 7017 unless otherwise noted in Tables A, B, and/or C.

MINNESOTA POLLUTION CONTROL AGENCY AIR QUALITY 520 LAFAYETTH ROAD ST. PAUL, MN 55155-4194

Page 2 of 21 8 Jul, 2015 14:08


Permit Number:

Daktronics Inc

12700055-002

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

Performance Test Notifications and Submittals:

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

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

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

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

17.0 CD hdr MONITORING REQUIREMENTS

18.0 CD Minn. R. 7007.0800, subp. 4(D) Monitoring Equipment Calibration - The Permittee shall either:

1. Calibrate or replace required monitoring equipment every 12 months; or 2. Calibrate at the frequency stated in the manufacturer's specifications

For each monitor, the Permittee shall maintain a record of all calibrations, including the date conducted, and any corrective action that resulted. The Permittee shall include the calibration frequencies, procedures, and manufacturer's specifications (if applicable) in the Operations and Maintenance Plan. Any requirements applying to continuous emission monitors are listed separately in this permit.

19.0 CD Minn. R. 7007.0800, subp. 4(D) Operation of Monitoring Equipment: Unless otherwise noted in Tables A, B, and/or C, monitoring a process or control equipment connected to that process is not necessary during periods when the process is shutdown, or during checks of the monitoring systems, such as calibration checks and zero and span adjustments. If monitoring records are required, they should reflect any such periods of process shutdown or checks of the monitoring system.

20.0 CD hdr RECORDKEEPING

21.0 CD Minn. R. 7007.0800, subp. 5(C) Recordkeeping: Retain all records at the stationary source, unless otherwise specified within this permit, for a period of five (5) years from the date of monitoring, sample, measurement, or report. Records which must be retained at this location include all calibration and maintenance records, all original recordings for continuous monitoring instrumentation, and copies of all reports required by the permit. Records must conform to the requirements listed in Minn. R. 7007.0800, subp. 5(A).

22.0 CD Minn. R. 7007.0800, subp. 5(B) Recordkeeping: Maintain records describing any insignificant modifications (as required by Minn. R. 7007.1250, subp. 3) or changes contravening permit terms (as required by Minn. R. 7007.1350, subp. 2), including records of the emissions resulting from those changes.

23.0 CD Minn. R. 7007.1200, subp. 4 If the Permittee determines that no permit amendment or notification is required prior to making a change, the Permittee must retain records of all calculations required under Minn. R. 7007.1200. For expiring permits, these records shall be kept for a period of five years from the date the change was made or until permit reissuance, whichever is longer The records shall be kept at the stationary source for the current calendar year of operation and may be kept at the stationary source or office of the stationary source for al l other years The records may be maintained in either electronic or paper format

24.0 CD hdr . REPORTING/SUBMITTALS

MINNESOTA POLLUTION CONTROL AGENCY AIR QUALITY 520 LAIAYLTTL ROAD ST. PAUL. MN 55155-4194

Page 3 of 21 8 Jul, 2015 14:08


Permit Number:

Daktronics Inc

12700055 - 002

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

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

26,0 CD Minn. R. 7019.1000, subp. 2 Breakdown Notifications: Notify the Commissioner within 24 hours of a breakdown of more than one hour duration of any control equipment or process equipment if the breakdown causes any increase in the emissions of any regulated air pollutant. The 24-hour time period starts when the breakdown was discovered or reasonably should have been discovered by the owner or operator. However, notification is not required in the circumstances outlined in Items A, B and C of Minn. R. 7019.1000, subp. 2. ,

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

27.0 CD Minn. R. 7019.1000, subp. 1 Notification of Deviations Endangering Human Health or the Environment: As soon as possible after discovery, notify the Commissioner or the state duty officer, either orally or by facsimile, of any deviation from permit conditions which could endanger human health or the environment.

28.0 CD Minn. R. 7019.1000, subp. 1 Notification of Deviations Endangering Human Health or the Environment Report: Within 2 working days of discovery, notify the Commissioner in writing of any deviation from permit conditions which could endanger human health or the environment. Include the following information in this written description: 1. the cause of the deviation; 2 the exact dates of the period of the deviation, if the deviation has been corrected; 3. whether or not the deviation has been corrected; 4 the anticipated time by which the deviation is expected to be corrected, if not yet corrected; and 5. steps taken or planned to reduce, eliminate, and prevent reoccurrence of the deviation.

29.0 S/A Minn. R. 7007.0800, subp. 6(A)(2) Semiannual Deviations Report: due 30 days after end of each calendar half-year following Permit Issuance. The first semiannual report submitted by the Permittee shall cover the calendar half-year in which the permit is issued. The first report of each calendar year covers January 1 - June 30. The second report of each calendar year covers July 1 - D ecember 31. If no deviations have occurred, the Permittee shall submit the report stating no deviations.

30.0 CD Minn. R. 7007.1150 - 7007.1500; Minn. R. 7007.0400, subp. 3

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

Upon adoption of a new or amended federal applicable requirement, and if there are more than 3 years remaining in the permit term, the Permittee shall file an application for an amendment within nine months of promulgation of the applicable requirement, pursuant to Minn. R. 7007.0400, subp. 3.

31.0 CD Minn. R. 7007.0400, subp. 2 Application for Permit Reissuance: due 180 days before expiration of existing permit.

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

33.0 S/A Minn. R. 7007.0800, subp 6(C) Compliance Certification: due 31 days after end of each calendar year following Permit Issuance (for the previous calendar year). The Permittee shall submit this on a form approved by the Commissioner, both to the Commissioner and to the US EPA regional office in Chicago, This report covers all deviations experienced during the calendar year

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

Page 4 of 21 8 Jul, 2015 14:08

COMPLIANCE PLAN CD-01 Facility Name: Daktronics Inc

Permit Number: 12700055-002

35.0 CD Minn. R. 7002.0005 - 7002.0095 Emission Fees: due 30 days after receipt of an MPCA bill.

MINNESOTA POLLUTION CONTROL AGLNC'V AIR QUALITY 520 LAIAYLTTL ROAD ST. PAUL, MN 55 155-4194

MINNESOTA POLLUTION CONI R(ll A<il-N('Y AIR QU ALITY 520 I.Al-'AYI-TTI-: ROAD SI'. PA Li I.. iVIN 55I55-4HM


Permit Number: 12700055 -002

Subject Item: GP 002 NESHAP Affected Units

Associated Items: EU 001 Solvent/Rag Wipedown - Solvent Equipment

EU 002 Spray Booth - Spray Booth/Coating Line

Page 5 of 21 8 Jul, 2015 14:08

COMPLIANCE PLAN CD-01

NCI CA


1.0 CD 40 CFR 63.3891; Minn. R. 7007.1150; Minn. R. 7011.8090

Based on the current and expected operations of the affected source, this permit includes both the compliant material option (40 CFR Section 63.3891(a)) as well as the emission rate without add-on controls option (40 CFR Section 63.3891(b)). If the Permittee later chooses to switch to or add the other compliance option allowed in the standard, the Permittee shall comply with all applicable portions of 40 CFR pt. 63, subp. MMMM for that option. In addition, the Permittee shall apply for a p ermit amendment, as appropriate (e.g., to add applicable NESHAP language, installation of an oxidizer, etc )

2 0

3.0

CD

CD

Minn. R. 7007.0800, subp. 4-5

hdr

Unless otherwise noted, all equations for 40 CFR pt. 63, subp. MMMM referenced in the requirements of this group can be found in Appendix C of this permit.

APPLICABILITY

4.0 CD 40 CFR 63 3881: 40 CFR 63.3883(a); 40 CFR 63.3883(d): Minn. R. 7011.8090

1 he facility is a new source that applies general use coatings to miscellaneous metal products. The compliance date for 40 CFR Part 63, subpart MMMM for this facility was September 01, 2007.

The Permittee must meet the notification requirements in 40 CFR Section 63.3910 according to the dates specified in that section and in 40 CFR pt. 63, subp. A.

5.0 CD 40 CFR 63.3882(b); Minn. R. 7011.8090

The affected source is the collection of all of the items listed below that are used for surface coating of miscellaneous metal parts and products within each subcategory. 1) All coating operations as defined in 40 CFR Section 63.3981; 2) All storage containers and mixing vessels in which coatings, thinners and/or other additives, and cleaning materials are stored or mixed; 3) All manual and automated equipment and containers used for conveying coatings, thinners and/or other additives, and cleaning materials; and 4) All storage containers and all manual and automated equipment and containers used for conveying waste materials generated by a coating operation.

6.0 CD hdr EMISSION AND OPERATIONAL REQUIREMENTS

7.0 CD 40 CFR 63.6(e)(1)(i); 40 CFR 63.6(e)(1)(ii); Minn. R. 7011.7000

At all times, including periods of startup, shutdown and malfunction, the Permittee shall operate and maintain the emission unit subject to the MACT standard and its associated air pollution control and monitoring equipment in a manner consistent with safety and good air pollution control practices for minimizing emissions at least to the levels required by all relevant standards. Malfunctions shall be corrected as soon as practicable after their occurrence.

8.0 CD 40 CFR 63.3892(a); Minn. R. 7011.8090

For any coating operation(s) on which the Permittee uses the compliant material option or the emission rate without add-on controls option, the Permittee is not required to meet any operating limits.

9 0 CD 40 CFR 63.3893(a); Minn R 7011 8090

For any coating operation(s) on which the Permittee uses the compliant material option or the emission rate without add-on controls option, the Permittee is not required to meet any work practice standards.

10.0 CD hdr COMPLIANCE REQUIREMENTS

11.0 CD 40 CFR 63.3891; Minn. R. 7011.8090

The Permittee must include all coatings (as defined in 40 CFR Section 63.3981), thinners and/or other additives, and cleaning materials used in the affected source when determining whether the HAP emission rate is equal to or less than the HAP emission limit. To make this determination, the Permittee must use at least one of the three compliance options listed in paragraphs (a) through (c) of 40 CFR Section 63.3891.

As stated earlier, this permit only includes the requirements associated with the compliant material option specified in 40 CFR Section 63.3891(a) and the emission rate without add-on controls option specified in 40 CFR Section 63.3891(b).

MINNESOTA POLLUTION CONTROL AGENCY Page 6 of 21 8 Jul 2015 14:08 AIR QUALI TY 520 i \i AYi . 11 RO AD ST. PAUL, MN 55155-4194 „ f ̂ 1^ HI COMPLIANCE; PLAN CLI-Ui

Facility Name: Daktronics inc

Permit Number: 12700055 - 002

12.0 CD 40 CFR 63.3891; Minn. R. 7011.8090

The Permittee may apply any of the compliance options to an individual coating operation, or to multiple coating operations as a group, or to the entire affected source. The Permittee may use different compliance options for different coating operations or at different times on the same coating operation. The Permittee may employ different compliance options when different coatings are applied to the same part, or when the same coating is applied to different parts. However, the Permittee may not use different compliance options at the same time on the same coating operation. If the Permittee switches between compliance options for any coating operation or group of coating operations, the Permittee must document this switch as required by 40 CFR Section 63.3930(c), and the Permittee must report it in the next semiannual compliance report. At the time of issuance the Permittee meets 40 CFR pt. 63 Subp. MMMM using the Emission Rate Without Add-On controls compliance option.

13.0 CD 40 CFR 63.3900(a)(1); 40 CFR 63.3900(b); Minn. R. 7011.8090

The Permittee must be in compliance with the emission limitations as specified below: 1) Any coating operation(s) for which the Permittee uses the compliant material option or the emission rate without add-on controls option, as specified in 40 CFR Section 63.3891(a) and (b), must be in compliance with the HAP emission limit at all times. 2) The Permittee must always operate and maintain the affected source according to the provisions in 40 CFR Section 63.6(e)(1 )(i).

14.0 CD hdr EMISSION RATE WITHOUT ADD-ON CONTROLS OPTION

15.0 LIMIT 40 CFR 63.3890(a)(1); Minn. R. 7011.8090

HAPs - Organic: less than or equal to 1.9 lbs/gallon coating solids used during each 12-month compliance period (HAP Emission Limit).

16.0 CD 40 CFR 63.3891(b); Minn. R. 7011.8090

The Permittee shall demonstrate that, based on the coatings, thinners and/or other additives, and cleaning materials used in the coating operation(s), the organic HAP emission rate for the coating operation(s) is less than or equal to the HAP emission limit, calculated as a rolling 12-month emission rate and determined on a monthly basis. The Permittee must meet all the requirements of 40 CFR Sections 63.3950, 63.3951, and 63.3952 to demonstrate compliance with the emission limit using the emission rate without add-on controls option.

17 0 CD 40 CFR 63.3950; Minn. R. 7011.8090

The Permittee must determine the mass of organic HAP emissions and volume of coating solids used each month and then calculate an organic HAP emission rate at the end of the initial compliance period. The initial compliance demonstration includes the calculations according to 40 CFR Section 63.3951 and supporting documentation showing that during the initial compliance period the organic HAP emission rate was equal to or less than the HAP emission limit.

18.0 CD 40 CFR 63.3951; Minn. R. 7011.8090

The Permittee may use the emission rate without add-on controls option for any individual coating operation, for any group of coating operations in the affected source, or for all the coating operations in the affected source. The Permittee must use either the compliant material option or the emission rate with add-on controls option for any coating operation in the affected source for which the Permittee does not use this option. To demonstrate initial compliance using the emission rate without add-on controls option, the coating operation or group of coating operations must meet the applicable HAP emission limit.

The Permittee must conduct a separate initial compliance demonstration for each general use coating operation. The Permittee must meet all the requirements of 40 CFR Section 63.3951.

19.0 CD 40 CFR 63.3951; Minn. R. 7011.8090

When calculating the organic HAP emission rate, do not include any coatings, thinners and/or other additives, or cleaning materials used on coating operations for which the Permittee uses the compliant material option or the emission rate with add-on controls option.

20.0 CD 40 CFR 63.3951; Minn. R. 7011.8090

The Permittee does not need to redetermine the mass of organic HAP in coatings, thinners and/or other additives, or cleaning materials that have been reclaimed on-site (or reclaimed off-site if the Permittee has documentation showing that they received back the exact same materials that were sent off-site) and reused in the coating operation for which the Permittee uses the emission rate without add-on controls option. If the Permittee uses coatings, thinners and/or other additives, or cleaning materials that have been reclaimed on-site, the amount of each used in a month may be reduced by the amount of each that is reclaimed. That is, the amount used may be calculated as the amount consumed to account for materials that are reclaimed. ...

MINNESOTA POLLUTION CONTROL AGENCY AIR QUALITY 520 I.AI AYLTTi; ROAD ST. PAUL. M N 55 155-4194

Page 7 of 21 8 Jul, 2015 14:08


Permit Number:

Daktronics Inc

12700055- 002

21.0 CD 40 CFR 63.3951(a); Minn. R. 7011.8090

Mass Fraction of HAP: The Permittee shall determine the mass fraction of organic HAP for each coating, thinner and/or other additive, and cleaning material used during each month by using one of the following options: 1) The Permittee may use Method 311 (appendix A to 40 CFR pt. 63) for determining the mass fraction of organic HAP. Use the procedures specified in 40 CFR Section 63.3941 (a)(1 >(i) and (ii ) when performing a Method 311 test; 2) For coatings, the Permittee may use Method 24 (appendix A to 40 CFR part 60) to determine the mass fraction of nonaqueous volatile matter and use that value as a substitute for mass fraction of organic HAP. For reactive adhesives in which some of the HAP react to form solids and are not emitted to the atmosphere, the Permittee may use the alternative method contained in appendix A to 40 CFR pt. 63, subp. PPPP, rather than Method 24.

22.0 CD 40 CFR 63.3951(a); Minn. R. 7011.8090

2) continued The Permittee may use the volatile fraction that is emitted, as measured by the alternative method in appendix A to 40 CFR pt. 63, subpart PPPP, as a substitute for the mass fraction of organic HAP; 3) The Permittee may use an alternative test method for determining the mass fraction of organic HAP as specified in 40 CFR Section 63.3941(a)(3); 4) The Permittee may rely on information other than the three options given above, such as manufacturer's formulation data, if it represents each organic HAP that is present at 0.1 percent by mass or more for OSHA-defined carcinogens as specified in 29 CFR Section 1910.1200(d)(4) and at 1.0 percent by mass or more for other compounds. For reactive adhesives in which some of the HAP react to form solids and are not emitted to the atmosphere, the Permittee may rely on manufacturer's data that expressly states the organic HAP or volatile matter mass fraction emitted.

23 0 CD 40 CFR 63.3951(a); Minn. R. 7011.8090

4) continued If there is a disagreement between such information and results of a test conducted.according to the three other options, then the test method results will take precedence unless, after consultation, the Permittee can demonstrate to the satisfaction of the Agency that the formulation data are correct; or 5) Solvent blends may be listed as single components for some materials in data provided by manufacturers or suppliers. Solvent blends may contain organic HAP which must be counted toward the total organic HAP mass fraction of the materials. When test data and manufacturer's data for solvent blends are not available, the Permittee may use the default values for the mass fraction of organic HAP in these solvent blends listed in Table 3 or 4 of 40 CFR pt. 63, subp. MMMM.

24.0 CD 40 CFR 63.3951(a); Minn. R. 7011.8090

5) continued If these tables are used, the Permittee must use the values in Table 3 for all solvent blends that match Table 3 entries according to the instructions for Table 3, and the Permittee may use Table 4 only if the solvent blends in the materials used do not match any of the solvent blends in Table 3 and the Permittee knows only whether the blend is aliphatic or aromatic. However, if the results of a Method 311 (appendix A to 40 CFR pt. 63) test indicate higher values than those listed on Table 3 or 4, the Method 311 results will take precedence unless, after consultation, the Permittee demonstrate to the satisfaction of the Agency the formulation data are correct.

25.0 CD 40 CFR 63.3951(b); Minn. R. 7011.8090

Volume Fraction of Solids: The Permittee shall determine the volume fraction of coating solids (liter (gal) of coating solids per liter (gal) of coating) for each coating used during each month by one of the methods given below. If test results obtained according to item 1 below do not agree with the information obtained under items 3 or 4 below, the test results will take precedence unless, after consultation, the Permittee can demonstrate to the satisfaction of the Agency that the formulation data are correct. 1) The Permittee may use ASTM methods as specified in 40 CFR Section 63.3941(b)(1); 2) The Permittee may use an alternative test method for determining the solids content of each coating as specified in 40 CFR Section 63.3941(b)(2); 3) The Permittee may obtain the volume fraction of coating solids for each coating from the supplier or manufacturer; or 4) The Permittee may determine the volume fraction of coating solids using the equation in 40 CFR Section 63.3941(b)(4).

MINNESOTA POLLUTION CONTROL AGLNCY AIR QUALITY 520 LAFAYETTL ROAD ST. PAUL, MN 55 155-4 194

Page 8 of 21 8 Jul, 2015 14:08


Permit Number:

Daktronics Inc

12700055- 002

26.0 CD 40 CFR 63.3951(c); Minn. R. 7011.8090

Density: The Permittee shall determine the density of each liquid coating, thinner and/or other additive, and cleaning material used during each month from test results using ASTM Method D1475-98, "Standard Test Method for Density of Liquid Coatings, Inks, and Related Products" (incorporated by reference, see 40 CFR Section 63.1.4), information from the supplier or manufacturer of the material, or reference sources providing density or specific gravity data for pure materials. If the Permittee is including powder coatings in the compliance determination, determine the density of powder coatings, using ASTM Method D5965-02, "Standard Test Methods for Specific Gravity of Coating Powders" (incorporated by reference, see 40 CFR Section 63.14), or information from the supplier.

27.0 CD 40 CFR 63.3951(c); Minn. R. 7011.8090

continued If there is disagreement between ASTM Method D1475-98 or ASTM Method D5965-02 test results and other such information sources, the test results will take precedence unless, after consultation the Permittee demonstrates to the satisfaction of the Agency that the formulation data are correct. If the Permittee purchases materials or monitor consumption by weight instead of volume, the Permittee does not need to determine material density. Instead, the Permittee may use the material weight in place of the combined terms for density and volume in Equations 1A, 1B, 1C, and 2.

28.0 CD 40 CFR 63.3951(d); Minn. R. 7011.8090

Volume: The Permittee shall determine the volume (liters) of each coating, thinner and/or other additive, and cleaning material used during each month by measurement or usage records. If the Permittee purchases materials or monitors consumption by weight instead of volume, the Permittee does not need to determine the volume of each material used. Instead, the Permittee may use the material weight in place of the combined terms for density and volume in Equations 1A, 1B, and 1C.

29.0 CD 40 CFR 63.3951(e); Minn. R. 7011.8090

The mass of organic HAP emissions is the combined mass of organic HAP contained in all coatings, thinners and/or other additives, and cleaning materials used during each month minus the organic HAP in certain waste materials. The Permittee shall calculate the following using the referenced equations in the Appendix of this permit: 1) Calculate the mass of organic HAP emissions using Equation 1. 2) Calculate the kg organic HAP in the coatings used during the month using Equation 1 A. , ,, 3) Calculate the kg of organic HAP in the thinners and/or other additives used during the month using Equation 1B. 4) Calculate the kg organic HAP in the cleaning materials used during the month using Equation 1C. 5) If the Permittee chooses to account for the mass of organic HAP contained in waste materials sent or designated for shipment to a hazardous waste TSDF in Equation 1, then the Permittee must determine the mass according to 40 CFR Section 63 3951 (e)(4)(i) through (iv)

30,0 CD 40 CFR 63.3951(f); Minn. R 7011.8090

The Permittee shall determine the total volume of coating solids used, liters, which is the combined volufrie of coating solids for all the coatings used during each month, using Equation 2.

31.0 CD 40 CFR 63.3951(g); Minn. R. 7011.8090

The Permittee shall calculate the organic HAP emission rate for the compliance period, kg (lb) organic HAP emitted per liter (gal) coating solids used, using Equation 3.

32.0 CD 40 CFR 63.3952(a); Minn. R. 7011.8090

To demonstrate continuous compliance, the organic HAP emission rate for each compliance period, determined according to 40 CFR Section 63.3951(a) through (g), must be less than or equal to the HAP emission limit. A compliance period consists of 12 months. Each month after the end of the initial compliance period described in 40 CFR Section 63.3950 is the end of a compliance period consisting of that month and the preceding 11 months. The Permittee must perform the calculations in 40 CFR Section 63.3951 (a) through (g) on a monthly basis using data from the previous 12 months of operation.

33.0 CD 40 CFR 63.3952(b); Minn. R. 7011.8090

If the organic HAP emission rate for any 12-month compliance period exceeded the HAP emission limit, this is a deviation from the emission limitation for that compliance period and must be reported as specified in 40 CFR Sections 63.3910(c)(6) and 63.3920(a)(6).

MINNESOTA P< >1.1.1' I'lON CON IKOI •\(i|-.N( N AIR QUA LITY 520 I Af AVf r f f; ROAD ST. PAUL. MN 5M55-4194

Page 9 of 21 8 Jul, 2015 14:08


Permit Number:

Daktronics Inc

12700055- 002

34.0 CD 40 CFR 63, subp. MMMM, Table 3; 40 CFR 63.3951(a); Minn. R. 7011.8090

The Permittee may use the mass fraction values in Table 3 for solvent blends for which the Permittee does not have test data or manufacturer's formulation data and which match either the solvent blend name or the chemical abstract series (CAS) number. If a solvent blend matches both the name and CAS number for an entry, that entry's organic HAP mass fraction must be used for that solvent blend. Otherwise, use the organic HAP mass fraction for the entry matching either the solvent blend name or CAS number, or use the organic HAP mass fraction from Table-4 if neither the name nor CAS number match.

35.0 CD 40 CFR 63, subp. MMMM, Table 4; 40 CFR 63.3951(a); Minn. R. 7011.8090

The Permittee may use the mass fraction values in Table 4 for solvent blends for which the Permittee does not have test data or manufacturer's formulation data.

36.0 CD hdr RECORDKEEPING for the EMISSION RATE WITHOUT ADD-ON CONTROLS OPTION

37.0 CD 40 CFR 63.3930(a), (b), (c)(1) and (c)(3); 40 CFR 63.3930(d), (e), (f), (g), (h) and (j); 40 CFR 63.3952(d); Minn. R 7011.8090

The Permittee must collect and keep records of the data and information specified below. Failure to collect and keep these records is a deviation from the applicable standard. 1) A copy of each notification and report that the Permittee submitted to comply with 40 CFR pt 63. subp MMMM, and the documentation supporting each notification and report;

38 0 CD 40 CFR 63.3930(a), (b), (c)(1) and (c)(3). 40 CFR 63.3930(d), (e), (f). (g), (h) and (j); 40 CFR 63.3952(d); Minn. R. 7011.8090

continued 2) A current copy of information provided by materials suppliers or manufacturers, such as manufacturer's formulation data, or test data used to determine the mass fraction of organic HAP and density for each coating, thinner and/or other additive, and cleaning material, and the volume fraction of coating solids for each coating. If the Permittee conducted testing to determine mass fraction of organic HAP, density, or volume fraction of coating solids, the Permittee must keep a copy of the complete test report. If the Permittee uses information provided to the Permittee by the manufacturer or supplier of the material that was based on testing, the Permittee must keep the summary sheet of results provided to the Permittee by the manufacturer or supplier. The Permittee are not required to obtain the test report or other supporting documentation from the manufacturer or supplier;

39.0 CD 40 CFR 63.3930(a), (b), (c)(1) and (c)(3); 40 CFR 63.3930(d), (e), (f), (g), (h) and (J); 40 CFR 63.3952(d); Minn. R. 7011.8090

continued 3) For each compliance period, the records specified below: - A record of the coating operations on which the Permittee used each compliance option and the time periods (beginning and ending dates and times) for each option the Permittee used; - and - A record of the calculation of the total mass of organic HAP emissions for the coatings, thinners and/or other additives, and cleaning materials used each month using Equations 1, 1A, 1B, 1C, and 2, if applicable, the calculation used to determine mass of organic HAP in waste materials according to 40 CFR Section 63.3951(e)(4); the calculation of the total volume of coating solids used each month using Equation 2; and the calculation of each 12-month organic HAP emission rate using Equation 3; 4) A record of the name and volume of each coating, thinner and/or other additive, and cleaning material used during each compliance period;

continued 3) For each compliance period, the records specified below: - A record of the coating operations on which the Permittee used each compliance option and the time periods (beginning and ending dates and times) for each option the Permittee used; - and - A record of the calculation of the total mass of organic HAP emissions for the coatings, thinners and/or other additives, and cleaning materials used each month using Equations 1, 1A, 1B, 1C, and 2, if applicable, the calculation used to determine mass of organic HAP in waste materials according to 40 CFR Section 63.3951(e)(4); the calculation of the total volume of coating solids used each month using Equation 2; and the calculation of each 12-month organic HAP emission rate using Equation 3; 4) A record of the name and volume of each coating, thinner and/or other additive, and cleaning material used during each compliance period;

40.0 CD 40 CFR 63.3930(a), (b), (c)(1) and (c)(3); 40 CFR 63.3930(d), (e), (f), (g), (h) and (j); 40 CFR 63 3952(d): Minn R 7011 8090

continued 5) A record of the mass fraction of organic HAP for each coating, thinner and/or other additive, and cleaning material used during each compliance period unless the material is tracked by weight; 6) A record of the volume fraction of coating solids for each coating used during each compliance period(compliant material option: may maintain purchase records for each material used) 7) The density for each coating, thinner and/or other additive, and cleaning material used during each compliance period; 8) If the Permittee uses an allowance in Equation 1 for organic HAP contained in waste materials according to 40 CFR Section 63.3951(e)(4), the Permittee must keep the following records: - The name and address of each TSDF to which the Permittee sent waste materials for which the Permittee uses an allowance in Equation 1 in the Appendix of this permit; a statement of which subparts under 40 CFR parts 262, 264, 265, and 266 apply to the facility; and the date of each shipment;

MINNESOTA POLLUTION CONTROL AGENCY Page 10 of 21 8 Jul 2015 14:08 AIR QUALITY 520 LAFAYETTE ROAD ST. PAUL. MN 55I55-.II9 4 „ f ̂ I~\ COMPLIANCE PLAN CU-Ul



41.0 CD 40 CFR 63.3930(a), (b), (c)(1) and (c)(3); 40 CFR 63.3930(d), (e), (f), (g), (h)and(j); 40 CFR 63.3952(d): Minn. R. 7011.8090

continued - Identification of the coating operations producing waste materials included in each shipment and the month or months in which the Permittee used the allowance for these materials in Equation 1; - The methodology used in accordance with 40 CFR Section 63.3951(e)(4) to determine the total amount of waste materials sent to or the amount collected, stored, and designated for transport to a TSDF each month; and the methodology to determine the mass of organic HAP contained in these waste materials. This must include the sources for all data used in the determination, methods used to generate the data, frequency of testing or monitoring, and supporting calculations and documentation, including the waste manifest for each shipment. 9) The Permittee must keep records of the date, time, and duration of each deviation.

42.0 CD 40 CFR 63.3931; 40 CFR 63.3952(d); Minn. R. 7011.8090

The Permittee's records must be in a form suitable and readily available for expeditious review, according to 40 CFR Section 63.10(b)(1). Where appropriate, the records may be maintained as electronic spreadsheets or as a database.

As specified in 40 CFR Section 63.10(b)(1), the Permittee must keep each record for 5 years following the date of each occurrence, measurement, maintenance, corrective action, report, or record.

The Permittee must keep each record on-site for at least 2 years after the date of each occurrence, measurement, maintenance, corrective action, report, or record according to 40 CFR Section 63.10(b)(1). The Permittee may keep the records off-site for the remaining 3 years.

43.0 CD hdr 2. COMPLIANT MATERIAL OPTION

44.0 LIMIT 40 CFR 63.3890(b)(1); Minn. R. 7011.8090

HAPs - Organic: less than or equal to 1 9 lbs /gallon coating solids used during each 12-month compliance period (HAP Emission Limit).

45.0 CD 40 CFR 63.3942(a); Minn. R. 7011.8090

For each compliance period to demonstrate continuous compliance, the Permittee must use no coating for which the organic HAP content (determined using Equation 2 listed later in this permit) exceeds the applicable emission limit in 40 CFR Section 63.3890, and use no thinner and/or other additive, or cleaning material that contains organic HAP, determined according to 40 CFR Section 63.3941(a). A compliance period consists of 12 months. Each month, after the end of the initial compliance period described in 40 CFR Section 63.3940, is the end of a compliance period consisting of that month and the preceding 11 months.

46.0 CD 40 CFR 63.3891(a); Minn. R. 7011.8090

The Permittee shall demonstrate that the organic HAP content of each coating used in the coating operation(s) is less than or equal to 0.23 kg (1.9 lb) kg organic HAP per liter (gal) coating solids used during each 12-month compliance period, and that each thinner and/or other additive, and cleaning material used contains no organic HAP. The Permittee must meet all the requirements of 40 CFR Sections 63.3940, 63.3941, and 63.3942 to demonstrate compliance with the HAP emission limit using the compliant material option.

47,0 CD 40 CFR 63.3941(a); 40 CFR 63.3942(a); Minn. R. 7011.8090

The Permittee must determine the mass fraction of organic HAP for each coating, thinner and/or other additive, and cleaning material used during the compliance period by using one of the following options: 1) Method 311 (appendix A to 40 CFR pt. 63). The Permittee may use Method 311 for determining the mass fraction of organic HAP. To use Method 311, count each organic HAP that is measured to be present at 0.1 percent by mass fraction or more for Occupational Safety and Health Administration (OSHA)-defined carcinogens as specified in 40 CFR Section 1910.1200(d)(4) and at 1.0 percent by mass or more for other compounds. Calculate the total mass fraction of organic HAP in the test material by adding up the individual organic HAP mass fractions and truncating the result to three places after the decimal point;

MINNESOTA POLLU TION CONTROL AGLNCY AIR QUALITY 520 LAIAYLTTI ROAD ST. PAUL. MN 55155-4194

Page 11 of 21 8 Jul, 2015 14:08


Permit Number:

Daktronics Inc

12700055-002

48.0 CD 40 CFR 63.3941(a); 40 CFR 63.3942(a); Minn. R. 7011.8090

Continued 2) Method 24 (appendix A to 40 CFR pt. 60). For coatings, the Permittee may use Method 24 to determine the mass fraction of nonaqueous volatile matter and use that value as a substitute for mass fraction of organic HAP. For reactive adhesives in which some of the HAP react to form solids and are not emitted to the atmosphere, the Permittee may use the alternative method described in appendix A to 40 CFR pt. 63, subp. PPPP, rather than Method 24. The Permittee may use the volatile fraction that is emitted, as measured by the alternative method in appendix A to 40 CFR pt. 63, subp. PPPP, as a substitute for the mass fraction of organic HAP: 3) Alternative Method. The Permittee may use an alternative test method for determining the mass fraction of organic HAP once the Administrator has approved it. The Permittee must follow the procedure in 40 CFR Section 63.7(f) to submit an alternative test method for approval;


Continued 4) Information from the supplier or manufacturer of the material. The Permittee may rely on information other than that generated by the previous three paragraphs, such as manufacturer's formulation data, if it represents each organic HAP that is present in 0.1 percent by mass or more for OSHA-defined carcinogens as specified in 40 CFR Section 1910.1200(d)(4) and at 1.0 percent by mass or more for the other compounds. For reactive adhesives in which some of the HAP react to form solids and are not emitted to the atmosphere, the Permittee may rely on manufacturer's data that expressly states the organic HAP or volatile matter mass fraction emitted. If there is a disagreement between such information and the results of a test conducted in according to 40 CFR Section 63.3941 (a)(1) through (3), then the test method results will take precedence unless, after consultation the Permittee demonstrates to the satisfaction of the MPCA that the formulation data are correct; or


Continued 5) Solvent blends. Solvent blends may be listed as single components for some materials in data provided by manufacturers or suppliers. Solvent blends may contain organic HAP which must be counted toward the total organic HAP mass fraction of the materials When test data and manufacturer's data for solvent blends are not available, The Permittee may use the default values for the mass fraction of organic HAP in these solvent blends listed in Table 3 or 4 of 40 CFR pt. 63, subp MMMM.


Continued If the tables are used, the values in Table 3 for all solvent blends that match the entries according to the instructions for Table 3 may be used, and Table 4 may be used only if the solvent blends in materials that are used are known and they do not match any of the solvent blends in Table 3 and it is known only whether the blend is aliphatic or aromatic. However, if the results of a Method 311 (appendix A to 40 CFR pt. 63) test indicate higher values than those listed in Tables 3 or 4, the Method 311 results will take precedence unless, after consultation, it is determined to the satisfaction of the MPCA that the formulation data are correct.

52 0 CD 40 CFR 63.3941(b); 40 CFR 63.3942(a); Minn. R. 7011.8090

The Permittee must determine the volume fraction of coating solids (liters (gal) of coating solids per liter (gal) of coating) for each coating used during the compliance as specified below If test results obtained according to item 1 below do not agree with the information obtained under items 3 or 4 below, the test results will take precedence unless, after consultation, the Permittee can demonstrate to the satisfaction of the Agency that the formulation data are correct.

53.0 CD 40 CFR 63.3941(b); 40 CFR 63.3942(a); Minn. R. 7011.8090

Continued 1) The Permittee may use ASTM methods as specified in 40 CFR Section 63.3941(b)(1); 2) The Permittee may use an alternative test method for determining the solids content of each coating as specified in 40 CFR Section 63.3941(b)(2); 3) The Permittee may obtain the volume fraction of coating solids for each coating from the supplier or manufacturer; or

Page 12 of 21 8 Jul, 2015 14:08

COMPLIANCE PLAN CD-01 Facility Name: Daktronics Inc


54.0 CD 40 CFR 63.3941(b); 40 CFR 63.3942(a); Minn. R. 7011.8090

Continued (4) Calculation of volume fraction of coating solids. The Permittee may determine the volume fraction of.coating solids by using the following equation (Equation 1): Vs = 1-(ms/Davg) Where: Vs = Volume fraction of coating solids, liters (gal) coating solids per liter (gal) coating. ms = Total volatile matter content of the coating, including HAP, VOCs, water, and exempt compounds, determined according to Method 24 in appendix A of 40 CFR part 60, grams volatile matter per liter coating. Davg = Average density of volatile matter in the coating, grams volatile matter per liter volatile matter, determined from test results using ASTM Method D1475-98, "Standard Test Method for Density of Liquid Coatings, Inks, and Related Products" (incorporated by reference, see 40 CFR Section 63.14), information from the supplier or manufacturer of the material, or reference sources providing density or specific gravity data for pure materials.

55.0 CD 40 CFR 63.3941(c); 40 CFR 63.3942(a); Minn, R. 7011.8090

Determine the density of each coating. The Permittee shall determine the density of each coating used during the compliance period from test results using ASTM Method D1475-98, "Standard Test Method for Density of Liquid Coatings, Inks, and Related Products" (incorporated by reference, see 40 CFR 63.14), information from the supplier or manufacturer of the material, or specific gravity data for pure chemicals. If there is disagreement between ASTM Method D1475-98 test results and the supplier's or manufacturer's information, the test results will take precedence unless, after consultation it is demonstrated to the satisfaction of the MPCA that the formulation data are correct.

56.0 CD 40 CFR 63.3941(d); 40 CFR 63.3942(a); Minn. R. 7011.8090

Determine the organic HAP content of each coating. The Permittee shall calculate the organic HAP content, kg (lb) of organic HAP emitted per liter (gal) coating solids used, of each coating used during the compliance period using the following equation (Equation 2): He = (Dc*Wc)/Vs Where: He = Organic HAP content of the coating, kg organic HAP emitted per liter (gal) coating solids used. ' Dc = Density of coating, kg coating per liter (gal) coating, determined according to 40 CFR Section 63,3941 (c). Wc = Mass fraction of organic HAP in the coating, kg organic HAP per kg coating, determined according to 40 CFR Section 63.3941(a). Vs= Volume fraction of coating solids, liter (gal) coating solids per liter (gal) coating, determined according to 40 CFR 63.3941(b).

57.0 CD 40 CFR 63.3942(b); Minn. R. 7011.8090

Deviation: The use of any coating, thinner and/or other additive, or c leaning material that does not meet the criteria specified in 40 CFR Section 63.3942(a) is a deviation from the emission limitations that must be reported as specified in 40 CFR Sections 63.3910(c)(6) and 63 3920(a)(5).

58.0 CD hdr RECORDKEEPING for the COMPLIANT MATERIAL OPTION

59.0 CD 40 CFR 63.3930(a), (b), (c)(1) and (2); 40 CFR 63.3930(d), (e), (f), and 0); 40 CFR 63.3942(d); Minn. R. 7011.8090

The Permittee shall collect and keep records of the data and information specified below. Failure to collect and keep these records is a deviation from the standard. 1) A copy of each notification and report that was submitted to comply with 40 CFR pt. 63, subp. MMMM, and the documentation supporting each notification and report; 2) A current copy of information provided by materials suppliers or manufacturers, such as manufacturer's formulation data, or test data used to determine the mass fraction of organic HAP and density for each coating, thinner and/or other additive, and cleaning material, and the volume fraction of coating solids for each coating. If a test was conducted to determine mass fraction of organic HAP, density, or volume fraction of coating solids, keep a copy of the complete test report. If the information provided by the manufacturer or supplier that was based on testing was used, keep the summary sheet of results provided by the supplier.

MINNESOTA POLLUTION CONTROL AGENCY AIR QUALI TY 520 LA1AYETTL ROAD ST. PAUL, MN 55 ] 55-4194

MINNI.SO'I A ['()[.I I TION CON I KOI \<il Nl'Y AIR Ql AI.ITY 520 l.-M AYl l I f. ROAD S T. PAUL. MN 55 I l<-J4

Facility Name:

Permit Number:

Daktronics Inc

12700055-002

Page 13 of 21 8 Jul, 2015 14:08

COMPLIANCE PLAN CD-0.1

60.0 CD 40 CFR 63.3930(a), (b), (c)(1) and (2); 40 CFR 63.3930(d), (e), (f), and (j); 40 CFR 63.3942(d); Minn. R. 7011.8090

Continued , The Permittee is not required to obtain the test report or other documentation from the manufacturer or supplier; 3) A record of the coating operations on which the Permittee used each compliance option and the time periods (beginning and ending dates) for each option that was used; 4) A record of the calculation of the organic HAP content for each coating, using Equation 2 in this permit; 5) A record of the name and volume of each coating, thinner and/or other additive, and cleaning material used during each compliance period. Purchase records for each material used may be kept instead of recording the volume used during each compliance period;

61.0 CD 40 CFR 63.3930(a), (b), (c)(1) and (2); 40 CFR 63.3930(d), (e), (f), and (j); 40 CFR 63.3942(d): Minn. R. 7011.8090

Continued 6) A record of the mass fraction of organic HAP for each coating, thinner and/or other additive, and cleaning material used during each compliance period unless the material is tracked by weight. 7) A record of the volume fraction of coating solids for each coating used during each compliance period. 8) Records of the date, time and duration of each deviation.

62.0 CD 40 CFR 63.3931; 40 CFR 63.3942(d); Minn. R. 7011.8090

The Permittee's records must be in a form suitable and readily viewable for expeditious review according to 40 CFR Section 63.10(b)(1). Where appropriate, the records may be maintained as electronic spreadsheets or as a database. As specified in 40 CFR Section 63.10(b)(1), each record must be kept for 5 years following the date of each occurrence, measurement, maintenance, corrective action, report, or record. The record must be kept on-site for at least 2 years after the date of each occurrence, measurement, maintenance, corrective action, report, or record according to 40 CFR Section 63.10(b)(1). The remaining records may be kept off-site for the remaining 3 years.

63.0 CD hdr GENERAL PROVISIONS

64.0 CD 40 CFR 63.4(a); Minn. R. 7011.7000

Prohibited Activities: (1) No owner or operator subject to the provisions of this part must operate any affected source in violation of the requirements of this part. Affected sources subject to and in compliance with either an extension of compliance or an exemption from compliance are not in violation of the requirements of this part. An extension of compliance can be granted by the Administrator under this part; by a State with an approved permit program; or by the President under section 112(i)(4) of the Act.

(2) No owner or operator subject to the provisions of this part shall fail to keep records, notify, report, or revise reports as required under this part.

65.0 CD 40 CFR 63.4(b); Minn. R. 7011.7000

Circumvention. The Permittee shall not build, erect, install, or use any article, machine, equipment, or process to conceal an emission that would otherwise constitute noncompliance with a relevant standard. Such concealment includes, but is not limited to:

1) The use of diluents to achieve compliance with a relevant standard based on the concentration of a pollutant in the effluent discharged to the atmosphere or

2) The use of gaseous diluents to achieve compliance with a relevant standard for visible emissions.

66.0 CD 40 CFR 63.4(c); Minn R. 7011.7000

Fragmentation. Fragmentation after November 15, 1990 which divides ownership of an operation, within the same facility among various owners where there is no real change in control, will not affect applicability. The owner and operator must not use fragmentation or phasing of reconstruction activities (i.e., intentionally dividing reconstruction into multiple parts for purposes of avoiding new source requirements) to avoid becoming subject to new source requirements.

67.0 CD 40 CFR 63.5(b)(3); Minn. R. 7011.7000

Prior to construction or reconstruction of an "affected source" under the promulgated MACT standards, the Permittee must apply for and obtain an air emission permit.

68.0 CD 40 CFR 63.5(b)(4); Minn. R. 7011.7000

The Permittee must submit notification according to 40 CFR Section 63.9(b) if the Permittee constructs or reconstructs a source such that the source becomes an affected source subject to a standard.

MINNESOTA POLLUTION CONTROL AGENCY Page14of21 8 Jul 2015 14:08 AIR QUALITY ' 520 LAIAYETTE ROAD ST. PAUL. MN 55)55-4194 _ _ rt1 COMPLIANCE PLAN tlJ-Ul

Facility Name: Daktronics tnc


69.0 CD 40 CFR 63.5(b)(6); Minn. R. 7011.7000

After the effective date of any relevant standard promulgated under 40 CFR pt. 63, equipment added (or a process change) to an affected source that is within the scope of the definition of affected source under the relevant standard must be considered part of the affected source and subject to all provisions of the relevant standard established for that affected source.

70.0 CD 40 CFR 63.6(e)(1)(i); Minn. R. 7011.7000

Proper Operation and Maintenance: At all times, including periods of startup, shutdown and malfunction, the Permittee shall operate and maintain the emission unit subject to the MACT standard and its associated air pollution control and monitoring equipment in a manner consistent with safety and good air pollution control practices for minimizing emissions at least to the levels required by all relevant standards.

71.0 CD 40 CFR 63.6(e)(l)(ii); Minn. R. 7011.7000

Malfunctions shall be corrected as soon as practicable after their occurrence.

72.0 CD 40 CFR 63.6(f)(2); Minn. R. 7011.7000

Methods for determining compliance will be, in part, based on the results of performance tests, conformance with operation and maintenance requirements, review of records, and inspection of the source as specified in 40 CFR Section 63.6(f)(2).

The Permittee may use the results of performance testing conducted previously if it meets the requirements of 40 CFR Section 63.6(f)(iii)

73.0 CD 40 CFR 63.6(f)(3); Minn. R. 7011.7000

Finding of Compliance. The Commissioner or the Administrator will make a finding concerning an affected source's compliance with a non-opacity emission standard upon obtaining all the compliance information required by the relevant standard.

74.0 CD 40 CFR 63.6(g); Minn. R. 7011.7000

The Permittee may establish the use of an alternative non-opacity emission standard by following the procedure specified in 40 CFR 63 6(g)

75.0 CD 40 CFR 63.9(b)(4); Minn. R. 7019.0100

The Permittee of a new or reconstructed mapr affected source for which an application for approval of construction or reconstruction is required under 40 CFR 63.5(d) must provide the following information in writing to the Commissioner and the Administrator:

1) A notification of intention to construct a new major-emitting affected source, reconstruct a major-emitting affected source, or reconstruct a major source such that the source becomes a major-emitting affected source; and

2) A notification of the actual date of startup of the source, delivered or postmarked within 15 calendar days after that date.

76.0 CD 40 CFR 63.9(h); Minn. R. 7019.0100

Notification of compliance status.

Each time a notification of compliance status is required under 40 CFR pt. 63, subp. A, the Permittee shall submit to the Commissioner a notification of compliance status containing the information required by 40 CFR 63.9(h), signed by the responsible official who shall certify its accuracy, attesting to whether the source has complied with the relevant standard.

The notification must be sent by the 60th day following the completion of the relevant compliance demonstration activity specified in the relevant standard. If no performance test is required but opacity or visible emission observations are required, the notification of compliance status shall be sent by the 30th day following the completion of opacity or visible emission observations. Notifications may be combined as long as the due date requirement for each notification is met.

40 CFR 63.3910 specifies the dates for submitting the notification of compliance status.

77.0 CD 40 CFR 63.9(j); Minn. R. 7019.0100

Notification. Any change in the information already provided under 40 CFR 63.9 shall be provided to the Commissioner and the Administrator in writing within 15 calendar days after the change.

78.0 CD 40 CFR 63.10(b)(1); Minn. R. 7019.0100, subp. 2(B)

Recordkeeping: The Permittee shall maintain files of all information required by 40 CFR pt. 63 in a form suitable and readily available for expeditious inspection and review.

The files should be retained for at least 5 years following the date of each occurrence, measurement, maintenance, corrective action, report, or record. Only the most recent two years of information must be kept on site.

MINNESOTA POLLUTION CONTROL AGENCY AIR QUALITY 520 I V \YI I !l ROAD ST. PAUL. MN 55155-4194

Facility Name:

Permit Number:

Daktronics Inc

12700055- 002

Page 15 of 21 8 Jul, 2015 14:08


79.0 CD 40 CFR 63.10(b)(2); Minn, R, 7019.0100, subp. 2(B)

The Permittee shall maintain, at a minimum, the following information in the files: 12) any information demonstrating whether a s ource is meeting the requirements for a waiver of record keeping or reporting requirements under this part; 14) all documents supporting initial notifications and notifications of compliance status

80 0 CD 40 CFR 63.10(d)(1): Minn. R. 7019.0100

Notwithstanding the requirements in 40 CFR 63.10(d) and 63.10(e), the Permittee shall submit reports to the Commissioner and the Administrator in accordance with the reporting requirements in the relevant standard.

Additional requirements are specified in 40 CFR 63,3920.

81.0 CD hdr REPORTING

82.0 S/A 40 CFR 63.3920(a)(1 )(i), (ii), and(iv); Minn. R. 7011.8090

Semiannual Compliance Report: due 31 days after end of each calendar half-year starting 04/28/2010. The report shall contain the information specified in Table A of this permit under GP 002. The first semiannual compliance report must cover the first semiannual reporting period which after permit issuance. Each subsequent semiannual compliance report must cover the subsequent semiannual reporting period from January 1 through June 30 or the semiannual reporting period from July 1 through December 31. This report may be submitted with the Semiannual Deviations Report also listed in this permit.

83.0 CD 40 CFR 63.3920(a)(3), (4) and (6); 40 CFR 63.3952(c); Minn. R. 7011.8090

Content of Semiannual Compliance Report: At a minimum, the report shall include: 1) Company name and address; 2) Statement by a responsible official with that official's name, title, and signature, certifying the truth, accuracy, and completeness of the content of the report; 3) Date of report and beginning and ending dates of the reporting period. The reporting period is the 6-month period ending on June 30 or December 31. Note that the information reported for each of the 6 months in the reporting period will be based on the last 12 months of data prior to the date of each monthly calculation; 4) Identification of the compliance option or options specified in 40 CFR Section 63.3891 that the Permittee used on each coating operation during the reporting period. If the Permittee switched between compliance options during the reporting period, the Permittee must report the beginning and ending dates for each option the Permittee used.

84.0 CD 40 CFR 63.3920(a)(3), (4) and (6); 40 CFR 63.3952(c); Minn. R, 7011.8090

continued 5) If th e Permittee used the emission rate without add-on controls or the emission rate with add-on controls compliance option (40 CFR Section 63.3891(b) or (c)), the calculation results for each rolling 12-month organic HAP emission rate during the 6-month reporting period; 6) If there were no deviations from the applicable HAP emission limit, the semiannual compliance report must include a statement that there were no deviations from the emission limitations during the reporting period; and

85.0 CD 40 CFR 63.3920(a)(3), (4) and (6); 40 CFR 63.3952(c); Minn. R. 7011.8090

continued 7) If there was a deviation from the applicable HAP emission limit, the semiannual compliance report must contain the following information: - The beginning and ending dates of each compliance period during which the 12-month organic HAP emission rate exceeded the applicable HAP emission limit; - The calculations used to determine the 12-month organic HAP emission rate for the compliance period in which the deviation occurred. The Permittee must submit the calculations for Equations 1, 1 A. 1B, 1C, 2, and 3, and if applicable, the calculation used to determine mass of organic HAP in waste materials according to 40 CFR Section 63.3951(e)(4). The Permittee does not need to submit background data supporting these calculations (e.g., information provided by materials suppliers or manufacturers, or test reports); and - A s tatement of the cause of each deviation.

MINNESOTA POLLUTION CONTROL ACiKNCY AIR QUALITY 520 I.AFAYLTTL ROAD ST. PAUL, MN 55155-4194


Permit Number: 12700055-002

Subject Item: EU 001 Solvent/Rag Wipedown - Solvent Equipment Associated Items: GP 002 NESHAP Affected Units

SV 001 Solvent Rag /Wipedown

Page 16 of 21 8 Jul, 2015 14:08


NC/ CA


1.0 LIMIT Minn. R. 7011.0715, subp. 1(A) Total Particulate Matter: less than or equal to 0.30 grains/dry standard cubic foot of exhaust gas unless required to further reduce emissions to comply with the less stringent limit of either Minn R 7011 0730 or Minn. R. 7011 0735.

Opacity: less than or equal to 20 percent opacity 2.0 LIMIT Minn. R. 7011.0715, subp. 1(B)

Total Particulate Matter: less than or equal to 0.30 grains/dry standard cubic foot of exhaust gas unless required to further reduce emissions to comply with the less stringent limit of either Minn R 7011 0730 or Minn. R. 7011 0735.

Opacity: less than or equal to 20 percent opacity

3.0 CD Minn. R. 7005.0100, subp. 35a Maximum Contents of Materials: The Permittee assumed certain worst-case contents of materials when determining the short term potential to emit of units in this group. These assumptions are listed in the Appendix D of th is permit. Changing to a material that has a higher content of any of the given pollutants is considered a change in method of operation that must be evaluated under Minn. R. 7007.1200, subp. 3 to determine if a permit amendment or notification is required under Minn. R. 7007.1150.

MINNESOTA l'< >1.1.1 "HON CONTROI -\(il.N( V AIR Ql ALIIA 520 I.ALAYFITL ROAD ST. PAUL. MN 55 I 55-4 I'M


Permit Number: 12700055- 002

Subject Item: EU 002 Spray Booth - Spray Booth/Coating Line

Associated Items: CE 001 Mat or Panel Filter

GP 002 NESHAP Affected Units .

SV 002 Spray Booth

Page 17 of 21 8 Jul, 2015 14:08


NC/ CA


1.0 LIMIT Minn. R. 7011.0715 subp. 1(A) Total Particulate Matter: less than or equal to 0.30 grains/dry standard cubic foot of exhaust gas unless required to further reduce emissions to comply with the less stringent limit of either Minn. R.7011.0730 or Minn. R. 7011.0735.

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

3.0 CD Minn. R. 7007.0800, subp. 2 and Minn. R. 7007.0800, subp. 14

The Permittee shall vent emissions to control equipment meeting the requirements of CE001. (See specific requirements at CE 001).

4.0 CD Minn. R. 7005.0100, subp. 35a Maximum Contents of Materials: The Permittee assumed certain worst-case contents of materials when determining the short term potential to emit of units in this group. These assumptions are listed in the Appendix D of this permit. Changing to a material that has a higher content of any of the given pollutants is considered a change in method of operation that must be evaluated under Minn. R. 7007 1200, subp. 3 to determine if a permit amendment or notification is required under Minn. R. 7007.1 150

MINNESOTA POLLUTION CONTROL AGliNCY Page18of21 8 Jul 2015 14:08 AIR QUALITY 520 LAI AYI-: 1 IT-: ROAD ST I'AUl.. .VIN _S5I.S5-4|y4 „ „ H1 COMPLIANCE PLAN L.1J-U1



Subject Item: EU 003 Heater for Spray Booth - Process Heater

Associated Items: SV 002 Spray Booth

NC/ CA


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

2,0 LIMIT Minn. R. 7011.0610, subp. 1(A)(2) Opacity: less than or equal to 20 percent opacity except for one six-minute period per hour of not more than 60 percent opacity.

3.0 CD Minn. R. 7005.0100, subp. 35a Fuel type: Natural gas only by design.

CD-01 MINNESOTA POLLUTION CONTROL AGF.NCY Page19of21 8 Jul, 201 5 14:08 AIR QUALI TY ' 520 I V AY I :: I ROAD

ST. P AUL MN 5 5155-4194 COMPLIANCE PLAN



Subject Item: EU 004 Bake Oven - Dryer/Oven, direct firing method

Associated Items: SV 003 Bake Oven

NC/ CA


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

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

3.0 CD Minn. R. 7005.0100, subp. 35a Fuel type: Natural gas only by design.

MINNESOTA POLLUTION CONTROL AGLNCY AIK QUALITY 520 LAI AYETTL ROAD ST. PAUL, MN 55155-4194



Subject Item: CE 001 Mat or Panel Filter

Associated Items: EU 002 Spray Booth - Spray Booth/Coating Line

NC/ CA


1.0 CD Minn. R. 7007.0800, subp. 2 The Permittee shall vent emissions from EU002 to panel filters meeting the requirements of CE 001.

2.0 CD Minn. R. 7007.0800, subp. 2 If the Permittee replaces the panel filter or modifies the panel filter listed in CE 001, such equipment is subject to all of the requirements of CE 001. Prior to making such a change the Permittee shall apply for and obtain the appropriate permit amendment, as applicable.

3.0 CD hdr EMISSION AND OPERATIONAL LIMITS

4.0 CD Minn. R. 7007.0800, subp. 2; Minn. R. 7007.0800, subp.14

The Permittee shall operate and maintain the panel filter (CE 001) at all times that any emission unit controlled by the panel filter (EU 002) is in operation. The Permittee shall document periods of non-operation of the control equipment.

5.0 LIMIT Minn. R. 7007.0800, subp. 2: Minn. R. 7007.0800, subp.14

The Permittee shall operate and maintain the control equipment such that it achieves an overall control efficiency for Total Particulate Matter: greater than or equal to 85 percent control efficiency

6.0 LIMIT Minn. R. 7007.0800, subp. 2; Minn. R. 7007.0800, subp.14

The Permittee shall operate and maintain the control equipment such that it achieves an overall control efficiency for PM < 10 micron: greater than or equal to 85 percent control efficiency

7.0 LIMIT Minn. R. 7007.0800, subp. 2; Minn. R. 7007.0800, subp.14

The Permittee shall operate and maintain the control equipment such that it achieves an overall control efficiency for PM < 2.5 micron: greater than or equal to 85 percent control efficiency

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

9.0 CD hdr MONITORING AND RECORDKEEPING

10.0 CD 40 CFR 64.3; Minn. R. 7017.0200 Daily Inspections: At least once per 24-hour period, the Permittee shall visually inspect the condition of the panel filter with respect to alignment, saturation, tears, holes and any other matter that may affect the filter's performance. The Permittee shall record the time and date of each inspection and any actions resulting from the inspection.

11.0 CD 40 CFR 64,3; Minn. R. 7017.0200 Periodic Inspections: The Permittee shall inspect the control equipment components as required by the manufacturing specifications The Permittee shall maintain a written record of these inspections

12.0 CD 40 CFR 64.7(d); Minn R 7017 0200

Corrective Actions The Permittee shall take corrective action as soon as possible if the panel filter or any of its components are found during the inspections to need repair. Corrective actions shall include completion of necessary repairs identified during the inspection, as applicable. Corrective actions include, but are not limited to, those outlined in the O & M Plan for the panel filter. The Permittee shall keep a record of the type and date of any corrective action taken for the panel filter.

Corrective Actions The Permittee shall take corrective action as soon as possible if the panel filter or any of its components are found during the inspections to need repair. Corrective actions shall include completion of necessary repairs identified during the inspection, as applicable. Corrective actions include, but are not limited to, those outlined in the O & M Plan for the panel filter. The Permittee shall keep a record of the type and date of any corrective action taken for the panel filter.

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

Documentation of Need for Improved Monitoring: If the Permittee fails to achieve compliance with an emission limitation or standard for which the monitoring did not provide an indication of an excursion or exceedance while providing valid data, or the results of compliance or performance testing document a need to modify the existing pressure drop range, the Permittee shall promptly notify the MPCA and, if necessary, submit a permit amendment application to address the necessary monitoring change.

14.0 CD 40 CFR 64.9(a)(2); Minn. R. 7017.0200

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

Page 20 of 21 8 Jul, 2015 14:08


YIINNI.SOIA I'ttl.l I HON < (IXHRCII Mil N< > MR yi.M ITV 520 I Al ,-\V r I ri ROAD ST PAUL. MN

Facility Name:

Permit Number:

Daktronics Inc

12700055- 002

Page 21 of 21 8 Jul, 2015 14:08


15.0 CD 40 CFR 64.9(b); Minn. R. 7017.0200

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


Attachment 3 CAM Submittal

Compliance Assurance Monitoring (CAM) Submittal Daktronics, Incorporated Prepared by Wenck Associates for Daktronics, Incorporated June 9,2015 Page 1 of 1

A.

Background

Emission Unit

Description: Spray Booth (SV 001)

Identification: EU 002

APCDID: CE 001-Panel Filters

Facility: Redwood Falls, Minnesota, 202 Building

B. Applicable Regulation, Emissions Limit, and Monitoring Requirements

Regulation: Minn. R. 7011.0715 Subp 1(A)

Emissions Limits:

Particulate Matter (PM): 12.17 Ib/hr (based on Process Equipment Rule)

Monitoring Requirements: Daily inspections of filters

C. Control Technology:

Panel (wall) filters

Monitoring Approach:

Indicator No. 1 Indicator Measurement Approach

Daily visually inspect the condition of the panel filters with respect to alignment, saturation, tears, holes and any other matter that may affect the filter's performance.

Indicator Range Any conditions visually observed related to alignment, saturation, tear, holes or any other matter that may affect the filter's performance that require corrective action.

Performance Criteria The filters must be in use and properly maintained when the spray booth is in operation.

Data Collection Procedures Inspections must be recorded once every 24-hour period. Inspections will occur while the filters are in operation. The operator records the date and time of the visual inspection and whether or not any conditions were observed that require corrective action. Any corrective actions taken will be recorded.

Averaging Period Instantaneous. Visual inspections are completed once per 24-hour period. Inspections will occur while the filters are in operation.

III. Basis and Implementation

Visual inspection was selected as a performance indicator because it is indicative of good operation and maintenance of the filters. When a filter is operating optimally, there will be no visible misalignment, tears, saturation, holes or any other condition that may reduce the filter performance.

Implementation of a control equipment inspection and maintenance program provides assurance that the control equipment is in good repair and operating properly. At least quarterly inspections of the control equipment ensure that the operation of the moving parts, nonmoving parts, and filters are all in proper operating condition.

IV. Rationale for Selection of Indicator Ranges

The indicator range is the visual inspection of the condition of the filters with respect to alignment, saturation, tears, holes and other condition that may reduce filter performance. Generally, under normal operating conditions, filters that are operating properly will exhibit no visible misalignment, tears, saturation, holes or any other condition that may reduce the filter performance.

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Attachment 4 MSDS for QSI TufGel 335A/335B

j

MATERIAL SAFETY DATA SHEET

1. Product and Company Identification

Material name Revision date Version # CAS H Product use

ManufacturerfSupplier

Emergency

TUFGEL 33SA 09-20-2011 00 Mixture • ' ' Industrial Silicone Gel

Quantum Silicones B021 ReycanRoad Richmond, VA 23237 oKllmcdennotligiauantumslllcQngs.com 804-271-9010 Contact Person: Phillip McDermott

Chemtrec 800-424-9300

2. Hazards Identification

Physical state Viscous Liquid

OSHA regulatory status

Potential health effects

Routas of exposure

Eyes

This product is not considered hazardous under 29 CFR 1910.1200 (Hazard'Cammunication).

Skin

Inhalation

Ingestion

Target organs

Chronic effects

Signs and symptoms

Potential environmental

Contact .

Contact with eyas may cause mild irritation.

Repeated or prolonged exposure may cause mild irritation.

Nona

Low In normal use. ,

Eyes. Skin.

None.

Mild irritation

The product Is not classified as environmentally hazardous. However, this does not exclude the possibility lhat large or frequent spills can have a harmful or damaging effect on the environment.

3. Composition / Information on Ingredients

Mixture does not contain Ingredients that are considered hazardous under 29 CFR 1910,1200 (Hazard Communication).

4. First Aid Measures

First aid procedures Eye Contact

Skin Contact

Inhalation TUFGEL 335A

Immediately flush with water for up to 10 minutes.

No first aid needed. '

No first aid needed. 1 Revision - 0

9/20/2011

Ingestion

Notes to physician

General advicc

5. Fire Fighting Measure

Flammable properties

Extinguishing media Suitable extinguishing media

No first aid needed.

Treat symptomatlcally.

In case of mild irritation flush affected area with water.

None.

Extinguish with foam, carbon dioxide, dry powder or waler fog.

Unsul.tabts extinguishing media

None.

Protection of firefighters Specific hazards arising None, from the chemical

Protoctlvo equipment and Use standard flreflghtlng procedures and consider the hazards of other involved materials, precautions for flrofiglrfors

Fireflghting equipment/Instructions

Specific methods

Hazardous decomposition

Selection of respiratory protection for fire fighting: follow the general fire precautions Indicated in the workplace. Self-contained breathing apparatus and full protective clothing must be worn In casB of fire.

Use standard flrefighting procedures and consider the hazards of other Involved materials. Containers close to firs should ba removed or cooled with water. .

High heat conditions only. NitrogBn oxides, metal oxides, formaldehyde, silicon dioxide, carbon oxides and traces of Incompletely burned carbon compounds.

6. Accidental Release Measures

Personal Precautions Extinguish all Ignition sources. Avoid sparks, flames, heat and smoking. Ventilate the araa. Avoid Inhalation of vapors/spray and contact with skin and ayes. Wear suitable protective clothing. See Section 8 of the MSDS for Personal Protective Equipment.

Environmental procaulions Avoid Discharge Into drains, watercourses or onto the ground unless auUiorized by penmil.

Methods for containment Dike the spilled materiel, where this Is possible.

Methods for cloaning up

Other Information

7. Handling and Storage

Handling

Storage

For waets disposal sea section 13 of the MSDS. Remove sources of ignition. Absorb spillage with non-combusllble, absorbent material.

Clean up in accordance wilh'all applicable federal, statB and local regulations.

Observe good industrial hygiene praclices. Avoid skin and eye contact. Wear protective glavas and appropriate clothing to prevent skin contact. Wear approved safety goggles. •

Do not store near heat sources, sources of Ignition, oxidizers or incompatible materials. Store In closed original container in a dry place,

8. Exposure Controls/Persona) Protection

These precautions are for room temperature handling, Use at elevated temperatures or aerosol/spray applications may require additional precautions. :1 j.

Occupational exposure There are no components with workplace exposure limits. TUFGEL335A 2 Revision - 0

9/20/2011

Exposure guidelines Follow standard monitoring procedures.

Engineering controls Ensure adequate ventilation.

Personal protective equipment Eye/Face protection Do not get In eyes. Eye wash fountain Is recommended.

Sltln protection Wear appropriate chemical resistant clothing, Suitable gloves can be recommended by the glove supplier. Safety shower recommended.

Respiratory protection None required.

General hygiene Handle In accordance with good industrial hygiene and safety practice. Considerations

9. Physical & Chemical Properties

Appearance Not available Color Clear Yellow Odor Odorless Odor threshold Not available Physical state Liquid Form Viscous liquid pH Not available Melting point Not available Freezing point Not available Boiling point > 260 C (> 500 F) Flash point > 212 F (> 100 C) Evaporation rate Not available

FlommabtlHy limits In Not available air, upper, % by volume

Flammablllty limits In Not available air, lower, % by voluma

Vapor pressure Not available Vapor density Not available Specific gravity 0.97 Solubility (water) Negligible Partition coefficient No data available (N-oetanol/water) Auto-lgniUon Not available temperature Decomposition Not available Temperature

10. Chemical Stability & Reactivity Information

Chemical stability Stable under normal temperature conditions.

Conditions to avoid Nona,

Incompatible Strong oxidizers may cause a reaction. . materials

Hazardous decomposition Carbon monoxide, carbon dioxide, silicone dioxide and formaldehyde.

Possibility of hazardous

TUFGEL 33SA

Will not occur.

3 Revision-0 9/20/2011

reactions

11. Toxicological Information

Carcinogenicity This product Is not considered to be a ca rcinogen by tARC, ACGIH, NTP or OSHA.

12. Ecological Information

Environmental effects Not classified as an environmental hazard. .

Persistence and No data available, degradablllly

Bloaccumulation/ No data available Accumulation

Partition coefficient No data available. (n-octanol/water)

Mobility in environmental Reacts with water, madia

13. Disposal Considerations

Disposal Instructions Material as received is non-hazardous.

Waste from residues/ Dispose In accordance with applicable federal, state and local regulations. Unused products

14. Transport Information

DOT ' Not subject to DOT regulations.

IATA Not regulated as dangerous goods.

IMDG Not subject to IMDG code.

TDG Not regulated as dangerous goods.

15. Regulatory Information

US federal regulations This product is not a "Hazardous Chemicar as defined by the OSI IA Hazard Communication Standard, 29 CFR 1910.1200. •

CERCLA/SARA Hazardous Substances - Not applicable.

TSGA Section 12(b) Export Notification (40 CFR 707, Subpt. O) . Not regulated '

CERCLA (Superfund) reportable quantity (lbs) (40 CFR 302.40 None

Superfund Amendments and Reauthorization Act of 1986 (SARA) Hazard categories Immediate Hazard - No •

Delayed Hazard - No Fire Hazard - No

• Pressure Hazard - No ' • Reactivity Hazard - No

TUFGEL335A 4 Revision - 0 9/20/2011

Section 302 oxtromaly No Hazardous substance (40 CFR 355, Appendix A)

Scctlon 311/312(40 CFR No 370)

Drug Enforcement Administration (DEA) (21 CFR 1308.11-150

Canadian regulations

WHMIS status

Not controlled.

The MSDS contains all the information required by Ihe CPR.

Not controlled

Mexico regulations

16. Other Information

Further Information

HMIS® ratings

NFPA ratings

Disclaimer

This safety data sheet was prepared In accordance with the official Mexican Standard (NOM-01B-STPS-2000).

HMIS© Is a registered trade and service mark of Ihe NPCA.

Health: 0 Flammablllty: 1 Physical hazard: 0

Health: 0 Flammabillty: 1 Instability: 0

These data are offered in good faith as typical values and not as product specifications. NO warranty, either expressed or Implied Is hereby made. The recommended Industrial hygiene and safe handling procedures are believed to be generally applicable. However , each user should review Ihese recommendations in the specific context of the Intended use and determlns whether they are appropriate.

fssue data 9-19-11

TUFGEL 335A 5 Revision - 0 9/20/2011

MATERIAL SAFETY DATA SHEET

1. Product and Company identification

Malarial name

Revision date Version # CAS# Product use

Manufacturer/Supplier

Emergency

TUFGEL 335B

09-20-2011 00 Mixture industrial Silicone Gel

Quantum Silicones 8021 Reycan Road Richmond, VA 23237 [email protected] 804-271-9010 " " Contact Person: Phillip McDermott

Chemtrec 800-424-9300

2. Hazards Identification

Physical state

OSHA regulatory status

Potential health effects

Routes of exposure

Eyes

Shin

Inhalation

Ingestion

Target organs

Chronic effects

Signs and symptoms

Potential environmental

Viscous Liquid

This product is not con sidered hazardous un der 29 CFR 1910.1200 (Hazard Communication).

Conlact

Contact with eyes may cause mild irritation. . .

. Repeated or p rolonged exposure may cause mild irritation. .

None. . . .

Low in normal use. • . . . ..

Eyes. Skin. . • . : • ...

None, ' ' •

Mild Irritation . .

The product Is not classified as environmentally hazardous. However, this does not exclude the ' possibility that large or frequBnt spills can have a harmful or damaging effect on the environment.

3. Composition / Information oh Ingredients "

-, Mixture does not contain ingredients that are considered hazardous un der 29 CFR 1910.1200 (Hazard Communication).

4. First Aid Measures

First aid procedures Eye Contact

Skin Contact

TUFGEL 33SB

Immediately flush with water for up to 10 minutes.


1 Revision - O 9/20/2011

Inhalation

Ingestion

Notes to physician

General advice

5. Fire Fighting Measure

Flammable propartiss



Treat symptomatlcally.

In case of mild irritation flush affecled area with water.

None.

Extinguishing media Suitable extinguishing Extinguish with foam, carbon dioxide, dry powder or water fog. media

Unsuitable extinguishing media

None.

Protection of firefighters Specific hazards arising None, from the chemical

Protective equipment and precautions far firefighters

Flrefighting equipment/Instructions

Specific methods

Hazardous decomposition

Uso standard flrefighting procedures and consider the hazards of olher involved materials.

Selection of respiratory protection for fire fighting: follow the general fire precautions indicated In the workplace, Self-contained brealhlng apparatus and full protective clothing must be worn in case of fire.

Use standard flrefighting procedures and consider the hazards of other Involved materials. Containers close to fire should be removed or cooled with water.

High heat conditions only. Nitrogen oxides, metal oxides, formaldehyde, silicon dioxide, carbon oxides and traces of Incompletely burned carbon compounds.

6. Accidental Release Measures

Personal Precautions Extinguish all Ignition sources. Avoid sparks, flames, heal and smoking. Ventilate the area Avoid Inhalation of vapors/spray and contact with skin and eyes. Wear suitable protective clothing. See Section 8 of ttia MSDS for Personal Protective Equipment.

Environmental precaullone Avoid Discharge Into drains, water courses or onto the ground unless authorized by permit

Methods for containment Dike the spilled material, where this Is possible. . •

Methods for claanlng up

Other information

7, Handling and Storage

Handling

Storage

For waste disposal see section 13 of Ihe MSDS. Remove sources of Ignition. Absorb spillage with non-combuslible, absorbent material.

Clean up in accordance with all applicable federal, stale and local regulations.

Observe good Industrial hygiene pracllces. Avoid skin and eye contact. Wear proteeb've gloves and appropriate clothing to prevent skin contact. Wear approved safety goggles.

Do not store near heat-sources, sources of ignition, oxidizers or incompatible materials. Store In closed original container in a dry place.

8. Exposure Controls/Personal Protection '

These precautions are for room temperature handling. Use at elevated temperatures or aerosol/spray applications may require additional precautions,

TUFGEL 335B Revision - 0 9/20/2011

Occupational oxposuse There are no components wllfi workplace exposure limits.

Exposure guidelines Follow standard monitoring procedures.

Engineering controls Ensure adequate ventilation.

Personal protective equipment Eye/Face protection Do not get in eyes. Eye wash fountain is recommended.

Skin protection Wear appropriate chemical resistant clothing. Suitable gloves can be recommended by the glove supplier. Safety shower recommended.

Respiratory protection None required.

General hygiene Handle in accordance with good Industrial hygiene and safety practice. Considerations

9. Physical & Chemical Properties

Appearance Not available Color Black Odor Odorless Odor threshold Not available Physical state Liquid Form Viscous liquid pH Not available Melting point Not available Freezing point Not available Boiling point > 260 C (> 500 F) Flash point > 212 F (> 100 C) Evaporation rate Not available

Flammabilfty limits In Not available air, upper, % by volume

Flammabilfty limits in Not available air, lower, % by volume

Vapor pressure Not available Vapor density Not available Specific gravity 0,97 Solubility (water) Negligible Partition coefficient No data available (N-octanol/water) Auto-ignition Not available temperature Decomposition Not available Temperature

10. Chemical Stability & Reactivity Information

Chemical stability Stable under normal temperature conditions.

Conditions to avoid Mane.

Incompatible Strang oxidizers may cause a reaction. • materials .

Hazardous decomposition Carbon monoxide, carbon dioxide, siOcone dioxids and formaldehyde.

TUFGEL 335B 3 Revision-0 0/20/2011

Possibility of hazardous Will not occur, reactions

11. Toxicological Information

Carcinogenicity This product Is not considered fa ba a carcinogen by (ARC, ACGIH, NTP or OSHA.

12. Ecological Information

Environmental effects Not classified as an environmental hazard.

Persistence and No data available, degradablllty

Bioaccumulatlon/ No data available Accumulation

Partition coefficient No data available. (n-octanol/water)

Mobility In environmental Reacts with water, media

13. Disposal Considerations

Disposal Instructions Material as received is non-hazardous.

Waste from residues/ Dispose In accordance with applicable federal, state and local regulations. Unused products

14. Transport Information

DOT • Not subject to DOT regulations.

lATA Not regulated as dangerous goods.

IMDG Not subject to IMDG code.

TDG Nol regulated as dangerous goods.

15. Regulatory Information

US fedoral regulations This product is nol a "Hazardous Chemical" as defined by the OSHA Hazard Communication Standard. 29 CFR 1910.1200.

CERCLA/SARA Hazardous Substances - Not applicable.

TSCA Section 12(b) Export Notification (40 CFR 707, Subpt. D) Not regulated

CERCLA (Superfund) reportable quantity (lbs) (40 CFR 302.40 None

Superfund Amendments and Reauthorization Act of 1986 (SARA) Hazard categories Immediate Hazard - No

Delayed Hazard - No Fire Hazard - No Pressure Hazard - No Reactivity Hazard - No

TUFGEL 335B 4 Revision - 0 9/2012011

Section 302 extremely No Hazaidoua substance (40 CFR 353, Appendix A)

Soction 311/312 (40 CFR No 370)

Drug Enforcement Not controlled. Administration (DEA) {21 CFR 1308.11-150

Canadian regulations

WHMIS status

The M5DS contains all the information required by the CPR.

Not controlled

Mexico regulations

16. Other Information

Further Information

HMIS® ratings

NFPA ratings

Disclaimer

This safety data sheet was prepared In accordance with the official Mexican Standard (NOM-018-STPS-2000),

HMIS® Is a registered trade and service mark of tho NPCA.

Health: 0 Flammabillty: 1 Physical hazard: 0

Health: 0 Rammablllty: 1 Instability: 0 '

These data are offered in good faith as typical values and not as product specifications. NO warranty, either expressed or implied Is hereby made. The recommended industrial hygiene and safe handling procedures are Believed to be generally applicable. However, each user should review these recommendations In the specific context of the intended use and determine whether they are appropriate.

Issue dale 9-19-11

TUFGF-L335B Revision - O 9/20/2011

TECHNICAL SUPPORT DOCUMENT For DRAFT/PROPOSED …NOx 0.44 0.44 0 2.28 9.13 Insig. ... • CAM has been added to CE001 Panel Filter in the permit as described in Table 5. Removal of

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