Peer Review Checklist
Facility Name:	Sanimax USA LLC	
Air Project Tracking Number (formerly DQ#):	4268 (4278, 5089, 5103)	
Permit Number:	03700070-007	
Permit Author:	Dick Cordes / Tyler Johnson	
Peer Reviewer:	Amrill Okonkwo	

Air Quality Permit Peer Review  				☐	Not applicable			

1)	TSD Review
The TSD describes the facility, permit type, applicable requirements, any changes authorized by the permit, and special or unique permit conditions. 
a.	Tempo Data: Verify that the appropriate data has been pulled in to the various data tags. See Cheat Sheet #23 and #32.
b.	Emissions Tables: Verify the (Title I, Non-Title I, Total Facility Limited PTE, etc.) emissions tables are populated correctly. Emission calculations spreadsheet should show derivation of the TSD emissions table(s) data.
c.	Modeling: If modeling was conducted, the modeling results table derived from Tables 3, 4, and 5 of the Air Quality Dispersion Modeling Report (AQDM-06) must be included.
d.	Citation Guide: Regulatory citations should conform to the Tempo citation guidance (cheat sheet #19).
e.	Text format: All instructional text must be removed from the TSD. All remaining text should be formatted to be standard color with no highlighting.
f.	Attachments: Must be in the approved file format per the April 18, 2012 Leads meeting, which includes no embedded icons. All attachments should be referenced within the TSD text.

Reviewer’s comments: 
1.	Under the facility description, for Boiler No. 3, please see my comment in the permit.  Per raw material receiving, third sentence, sp on materia1 to material. 
2.	I believe that you added the HAPs limits under COMG 2.
3.	Under other changes, delete “Delta”
4.	Permit History was changed to Description of Notifications and Applications Included in this Action (Date Received and Application/Notification Type and description); therefore I would delete permit action nos. 005 and 006. 
5.	Under regulatory overview it should read “Regulatory Overview of Facility” .
6.	Under 3.6 , change Appendix II, to Appendix B and Appendix III to Appendix C.   
Author’s response:
1.	The correct capacity is 98 mmBtu/hr. Typo corrected from materia1 to material.
2.	The limits for HAPs – Total and HAPs – Single have been removed from COMG 2 because they don’t apply until testing and use of the alternative fuels. The HAPs tracking is listed under each EQUI that is authorized to burn these alternative fuels because that is where the HAPs tracking will be triggered from.
3.	Done.
4.	Updated table to reflect the new Tempo TSD template and removed permit action nos. 005 and 006.
5.	Done
6.	Done
Resolution: Completed

2)	Permit Review
a.	Tempo Data: Verify that the appropriate data has been pulled in to the various data tags. See Cheat Sheet #22. Make sure that the permit author did not edit any of the sections of the permit that should pull in data from Tempo (e.g., no reformatting or wordsmithing of data pulled from Tempo).
b.	Verify that the Tempo requirements have been cleaned up per the Tempo cleanup checklist.
c.	Check applicable requirements.
d.	Check the adequacy of permit conditions for each of the above applicable requirements. 
e.	112g applicability: for construction permits, check applicability of 112g. Note: Currently (as of 2014) the applicability of Clean Air Act Section 112g (case-by-case MACT) is very uncommon because EPA has promulgated most if not all MACT standards for source categories.
f.	Check modeling requirements (based on MPCA policy, NAAQS, MAAQS, increment, etc.). Verify if modeling has been completed, and/or the permit contains the appropriate modeling submittal requirements. Permit requirements for already completed modeling should include the modeling Tier and appropriate requirements (see Requirements Library). Modeling parameters should be in the Appendix.
g.	Check emission limits and compliance demonstration methods. Almost all limits must have associated compliance demonstration requirements. The only common exception is control efficiency; verifying control efficiency is not routinely required.
h.	Verify compliance demonstration methods are consistent with the associated limit averaging period. For example, if a limit is 10 ppmvd on a 30-day rolling average, does the permit require emissions data collection for each 30-day period for determining the 30-day rolling average in ppmvd?
i.	Check Performance testing requirements. For repeat testing, the testing frequency needs to be incorporated in the permit, or a test frequency plan submittal should be required. EPA test methods must be specified.
j.	Audit the Requirements Development screen permit conditions. Check some of the permit conditions to verify that limits have been entered on the Limit Screen, Submittals on the S/A screen, etc. Pay particular attention to S/A requirements.
k.	Verify that all appropriate Requirements Library profiles were used (e.g., total facility requirements, NESHAPs, etc.) and edited as needed.
l.	Appendices: make sure all are directly included in the LetterBuilder permit and listed in the table of contents.
Reviewer’s comments: 
1.	General Description in the perset: Paragraph 2: remove the extra space in the beginning of the sentence. Remove all the extra spaces in paragraph 4 and paragraph 3, per New Source Review regulations delete “A”. Also, since this includes a modification, add the description of the modification.  Also list boiler no. 1 (EQUI 19) will be retired. 
2.	I would move “permit appendices, sequence no. 1260 ” before sequence # 4 in the perset.
3.	Under sequence #4, my suggestion is to change PM10/PM2.5 to PM10 and PM2.5 and remove the brackets.
4.	Permit cover page, remove the SIP references, Title V Reissuance since this is a state permit, and amend/reissue.  
5.	Clean up the permit applications table; delete action nos. 005 and 006.
6.	See comment no. 1 for Facility description in the permit.  The capacity of the new boiler no. 3 was listed as 73,529 cuft per hour in the preset but in the TSD and calculations the capacity was 98MMBtu/hr.  Which capacity is correct? 
7.	I did not see the requirement for the permittee to submit an application for permit reissuance in the preset but it did show up under submit/action requirements per 6.1.1 in the permit. 
8.	I do not believe that the permittee must submit a risk management plan, sequence # 1770 in the preset or 5.1.42 in the permit.
9.	For sequence #1710 in the preset and 5.1.38 in the permit, you may want to edit in respect to the term of the permit.
10.	 I did not see the requirements for COMG 2 in the preset but the requirements were in the permit.  What are the compliance methods for HAPs limits?
11.	COMG 7, the limits did not reflect that they are applicable to EQUI 3, EQUI 16 and EQUI 17.  You may want to add a requirement for TREA 28 to control PM, PM10 and PM2.5 emissions from EQUI 3, EQUI 16 and EQUI 17. 
12.	5.7.6, move or add a period before  “This limit…..” 
13.	5.8.1. You will need to add a notification requirement to reflect this requirement. You may want to add a S/A to notify the MPCA when the boiler becomes subject to Subpart JJJ.
14.	See comment no. 12 for 5.8.8 and 5.8.9
15.	5.8.14, add “0” after “5” for percent by weight and delete the extra spaces before sulfur dioxide.
16.	5.8.26, “fill in the MACT standard compliance date”
17.	5.8.40 and 5.8.41, select biennially or 5 years,  25 or 61 months or 36/72 months
18.	5.8.57, I believe that this requirement should be a S/A, if we are requesting the permittee to develop emission factors. 
19.	5.8.61,  You will need to add by the 15th day of each month.
20.	6.2.1. Is this a one-time test? Maybe I missed the requirement in the permit. How will you address, if the test results for the emission factors are higher that the emission factors used in their PTE calculations? I believe there are profiles for setting emission factors using performance tests.
21.	I did not see a trigger date of a notification for startup date for the boilers glycerin combustion.
22.	You may want to move 5.8.33 up before 5.8.22
23.	5.11.1, remove the reference to “emission unit”
24.	5.11.3, see comment no. 13
25.	5.11.11 and 5.11.12, add a period before “This limit… 
26.	5.11.14 and 5.11.16 are duplicate requirements
27.	5.11.47, use 40 CFR pt. 63, subp. JJJJJJ
28.	5.11.63, see comment 19 
29.	TREA 26, TREA 27 and TREA 28 were loaded as CAM units for per the requirement profiles. These treatments are not CAM units.
30.	TREA 31, TREA 32, TREA 33, TREA 34 and TREA 35, in the permit the control efficiencies were 99% but in the TSD the control efficiencies were 90% .
31.	Appendix B and C, use the Tempo terminology. 
32.	Appendix C, for PM2.5 limits add “0” after “5” 
Author’s response:
1.	The “A” is not in the General Description in the PERSET, but it loaded with the “A” in the Permit. Therefore, removed the § symbol so now it is just 40 CFR 52.21. Added a description of this permit action to the general description in Tempo and mentioned that Boiler #1 (EQUI 19) will be retired within 180 days after the initial startup of the new boiler.
2.	Done
3.	The brackets surrounding PM10/PM2.5 were removed and PM10/PM2.5 was changed to PM10 and/or PM2.5.
4.	Removed SIP references, Title V reissuance information, and both amend/reissue. Operate/construct/modify was also changed to operate and modify.
5.	Done
6.	The capacity of Boiler #3 should be 98 mmBtu/hr. This has been changed in Tempo.
7.	This was removed from the PERSET and will not appear in section 6 of the permit once it is reloaded.
8.	Done
9.	Updated language by removing “the Permittee shall file an application for an amendment within nine months of promulgation of the applicable requirement.”
10.	The HAPs-Total and HAPs-Single limits were removed from COMG 2 since they are not required until the Permittee tests and uses alternative fuels in one or more of their boilers. 
11.	These limits for Total PM, PM10, and PM2.5 are at the stack and everything listed in this group goes to this stack (STRU 24). TREA 29 was added as EQUI 3 is controlled by TREA 29.
12.	Done
13.	Talking with Dan Dietrich, we do not need a notification of when the boilers are subject to JJJJJJ since we are not delegated to NESHAP JJJJJJ. I have removed the text requirement stating that the notification of compliance status shall be submitted to the MPCA.
14.	Done
15.	Done
16.	Added the MACT standard compliance date for JJJJJJ of March 21, 2014.
17.	Done
18.	Performance testing requirements were added for each pollutant for glycerin and RAFVO once they start using that alternative fuel type. These performance testing requirements go along with this requirement at 5.8.57.
19.	Done
20.	This is a one-time test. I have changed the profile and language from emission factor testing to testing to measure the emissions rate and demonstrate compliance with the modeled emissions rate.
21.	The “Fuel Testing Submittals” requirement found near the end of the set of requirements for each boiler now states that a test notification and test plan shall be submitted at least 30 days prior to initial combustion of glycerin or RAFVO. The Test plan will include the anticipated startup date for glycerin or RAFVO combustion. This will provide the notification of startup for glycerin and RAFVO combustion and will provide a date for the performance tests for glycerin and RAFVO.
22.	Done
23.	Done
24.	See response no. 13.
25.	Done
26.	Removed requirement 5.11.16 from the PERSET. This will be gone from the permit once it is reloaded.
27.	Done
28.	Done
29.	The requirement profile used for TREA 26, TREA 27, TREA 28, and TREA 30 was for CAM > other pseu > venture scrubber. These pieces of treatment are not subject to CAM, as shown in the Air Control Equipment tab in the SI details for each piece of treatment. However, I chose this profile because it had the most overlap between the profile language and the needed language. The requirements that didn’t apply from this CAM profile were removed and all of the CAM citations were removed. Let me know if a different profile needs to be used. I feel that the use of this profile is fine since there is no designation of CAM anywhere else in the permit and all of the CAM citations have been removed, but I can change this if needed. 
30.	These have been corrected in the TSD.
31.	The only non-Tempo terminology I see are the FUG1 and FUG2 in the two lower tables of Appendices B and C. These are not listed as SIs in Tempo and are referred to as FUG1 and FUG2 in the modeling. Therefore, they will remain referenced as FUG1 and FUG2 since that’s how they are referenced in the modeling. 
32.	Done
Resolution: Completed

3)	Emission Calculations Review
a.	Check the calculations to verify that they are using an appropriate methodology, and that there is data for controlled lb/hr, unrestricted tpy (unlimited and uncontrolled), and limited tpy.
b.	Are the emission factors acceptable and the sources documented?
c.	Calculations should include the TSD emissions tables’ data derivation.
d.	If modeling was done, do the calculations support the modeled emission rates?
Reviewer’s comments: 
1.	Boiler No 1. (EQUI 19), Limited PTE for SO2 is 113.28 tons/yr while the total facility emissions are 61 tons/yr.
2.	See my comment no. 6 under permit in regards to the capacity of boiler no. 3.
3.	Add single (9.0 tons/yr) and total (20.0 tons/yr) HAPs emissions per COMG 2
4.	I sort of checked the AP-42 factors for the pneumatic conveying system (EQUI 18), per AP-42, the PM-0.73 lb/ton and PM10-0.47 lb/ton but in the emission cals, the permittee used 0.72 lb/ton for PM and 0.46 lb/ton for PM10. 
5.	Per COMG 7, emissions were double counted for PM, PM10, and PM2.5
Author’s response:
1.	The total facility emissions are post modification. This is once Boiler no. 3 is operating and when Boiler No. 1 is retired.
2.	Boiler no. 3 capacity is 98 mmBtu/hr.
3.	The PTE is much lower than these two and the limits for single and total HAPs aren’t in effect until they are subject to JJJJJJ.
4.	These will be changed in the emissions calculations and the corresponding documents will be updated due to this change.
5.	Potential lbs/hr and Unrestricted Potential tpy remain at the EQUI level, while Potential Limited tpy will be at the COMG 7 level. This has been corrected. Potential Limited set to 0 at the EQUI level since it cannot be blank.
Resolution: Completed

4)	Verify necessary documents are in Tempo
a.	The Technical Support Document and any other MPCA-generated documents that support the permit (e.g., spreadsheets, lengthy TSD attachments) must be in Tempo and labeled such that they are easy to find. For example, the emissions calculation spreadsheet could be named ‘TSD Att 1 Emission Calcs’.
b.	If the Permittee submitted an electronic version of their calculations, they can be used with any necessary revisions/corrections by the permit author to create the emission calculations spreadsheet in Tempo.
c.	Any permit application documents submitted by the permittee should be in the Tempo Central File and locked.
Reviewer’s comments: 
1.	Update the TSD attachments to reflect the correct documentation, such as TSD Att 1 PTE  Calcs; TSD Att 2 … 
Author’s response:
1.	Done
Resolution: Completed

5)	Verify Permit Type and Sub-Program Data – The Permit Type and AISI Sub-program data must be complete and correct. Use Air Cheat Sheets #17 (Permit Type) and #15 (Regulatory Program).
Reviewer’s comments: Need to add the permit type (use cheat sheet #17)
Author’s response: Added permit type of ‘Permit Limits to Avoid NSR’ to PERSET.
Resolution: Completed

6)	SI Details and Tempo SI Cleanup
a.	The PTE entered for each SI must be consistent with the permit, TSD, and emission calculations spreadsheet. Data for every relevant column must be entered for each subject item that is in the scope of the project (if reissuance, the scope is every subject item).
b.	Verify that the subject item inventory and any SI details affected by the permit action have been revised and/or updated for the given permit action (and discussed in the TSD). 
c.	Verify that all SI’s removed in a given action were removed directly by the PDC in the master file.
d.	Verify that any needed cleanup of the SI information has been performed (per Tempo cleanup checklist).
Reviewer’s comments: There are a lot of documents in the central file, which were migrated from Delta. If you created any of these documents in Tempo, you can delete it; otherwise ask Beckie to do so.  
Author’s response: Done
Resolution: Completed

7)	Points Calculator - Verify that the Points Calculator spreadsheet has been saved in the Central File in Tempo and that the fees assessed are correct and clearly documented in the “Comments” column within the worksheet and described in the TSD.
Reviewer’s comments: None
Author’s response: None
Resolution: N/A