March 28, 2017

Justin Daubendiek
Sanimax USA LLC
505 Hardman Avenue South
South Saint Paul, MN  55075

RE:	Notice of Compliance for September 30, 2016, Performance Test on Ring/Blood Dryer/Oven (EQUI4)
Pursuant to Air Emission Permit Number 03700070-007 and Test Plan Approval issued September 22, 2016

Dear Mr. Daubendiek:

The Minnesota Pollution Control Agency (MPCA) staff has reviewed the final test report for the test conducted on the emission unit referenced above at the Sanimax USA LLC (Regulated Party) located in South Saint Paul, Minnesota. The test report was submitted electronically on November 1, 2016. This notice serves as the Commissioner's written verification of compliance status of the Regulated Party pursuant to Minn. R. 7017.2020 to 7017.2025. 

The MPCA staff has determined that the test results demonstrate the following under test conditions: 

Summary of Performance Test Results
Emission Unit Tested	Limitation
Basis	Pollutant and
Emission Limit	Test
Result	Compliance Status	
EQUI4	Minn. R. 7011.0610, 
subp. 1(A)(1)	Total Particulate Matter(A) (TPM):  
≤ 0.087 gr/dscf	TPM:
0.0053 gr/dscf	Compliant	
	Minn. R. 7007.0100, 
subp. 7(A), 7(L), & 7(M), 
Minn. R. 7007.0800, subp. 4, Minn. R. 7007.0800, subps. 1-2, Minn. R. 7009.0010-0080, 
Minn. Stat. 116.07, subd. 4a, Minn. Stat. 116.07, subd. 9, 
Title I Condition: Avoid major modification under 
40 CFR 52.21(b)(2) and 
Minn. R. 7007.3000, 
Title I Condition: 
Avoid major source under 
40 CFR 52.21(b)(1)(i) and 
Minn. R. 7007.3000	PM < 10 micron(B) (PM10): ≤ 1.3 lb/hr	PM10: 
0.54 lb/hr	Compliant	

Emission Unit Tested	Limitation
Basis	Pollutant and Emission Limit	Test
Result	Compliance Status	
EQUI4	Minn. R. 7007.0100, 
subp. 7(A), 7(L), & 7(M), 
Minn. R. 7007.0800, subp. 4, Minn. R. 7007.0800, subps. 1-2, Minn. R. 7009.0010-0080, 
Minn. Stat. 116.07, subd. 4a, Minn. Stat. 116.07, subd. 9, 
Title I Condition: Avoid major modification under 
40 CFR 52.21(b)(2) and 
Minn. R. 7007.3000, 
Title I Condition: 
Avoid major source under 
40 CFR 52.21(b)(1)(i) and 
Minn. R. 7007.3000	PM < 2.5 micron(C) (PM2.5): 
≤ 0.78 lb/hr	PM2.5:
0.54 lb/hr	Compliant	
Table References:
(A)	Total Particulate Matter includes filterable plus organic condensable particulate matter as determined by EPA Methods5 and 202
(B)	PM10 includes particles with an aerodynamic diameter less than or equal to a nominal ten micrometers as determined by EPA Methods 5 and 202
(C)	PM10 includes particles with an aerodynamic diameter less than or equal to a nominal ten micrometers as determined by EPA Methods 5 and 202

The test was conducted while combusting natural gas at a rate of 193 pounds per hour while generating steam at a rate of 9,000 pounds per hour and with a raw material feed rate of 13,210 pounds per hour. The venture pressure drop was 4.2 inches of water column and the water flow rate was 65.8 gallons per minute during the test. These parameters are within the ranges defined in the approved test plan.

In addition, please be advised of the following:

1.	The operating conditions met the worst-case operating condition as defined in the approved test plan. Therefore, no new operating limit is applicable pursuant to Minn. R. 7017.2025, subp. 3. However, please be aware that should operating practices change such that the current definition 
of worst-case becomes outdated, the MPCA may require a performance test at the new worst-case condition.

2.	The Emission Inventory rule, Minn. R. 7019.3000 to 7019.3100, requires the calculation of emissions based on an established hierarchy. In the absence of Continuous Emission Monitor data meeting the requirements of Minn. R. 7019.3040, a performance test must be used. When a performance test for particulate matter, carbon monoxide, nitrogen oxides, sulfur oxides, volatile organic compounds or lead is conducted and meets the requirements of Minn. R. 7017.2001 to 7017.2060, the results must be used to calculate emissions, unless specified otherwise by Minn. R. 7019.3000 to 7019.3100. It is the Regulated Party’s responsibility to ensure the results of performance tests are accounted for in their annual emission inventory submittal. Note that the final decision to approve the emission factor for any given inventory year will be made by the Emission Inventory Coordinator.
If you have questions or comments regarding the content of this letter, please contact me at 651-757-2716.

Sincerely,
Marc Severin
This document has been electronically signed.
Marc Severin
Environmental Specialist 3
Land & Air Compliance Section
Industrial Division

MAS:ss

cc:	Activity ID REP20160002 @ 4387