CH10 APPLICABILITY OF MINOR OR MODERATE AMENDMENT PROCESS AIR

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CH10 APPLICABILITY OF MINOR OR MODERATE AMENDMENT PROCESS AIR
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CH-10 Applicability of Minor or Moderate Amendment Process -- Air Quality Permit Program - Form

CH-10

Applicability of Minor or Moderate Amendment Process

Air Quality Permit Program

Doc Type: Permit Application

Instructions on Page 3

1a) AQ Facility ID number:			1b) AQ File number:
2) Facility name:

After completing Form CH-03 to determine that the proposed change does not require a major amendment, use this form to determine if the change requires a minor or moderate amendment. Please confirm the following:

3) I answered “No” to all questions on Form CH-03.

No. This indicates that a major amendment is required and this form is not applicable.

Yes. The proposed change does not require a major amendment.

Part A. Regulatory change affecting a previously-listed insignificant activity

4) Is the change you wish to make to your permit solely to add emissions units, tanks, or fugitive sources that were listed as insignificant activities under Minn. R. 7007.1300, subp 3 or 4 in a prior permit application where those activities no longer qualify as insignificant due to a regulatory change (Not due to a modification to the activity)?

No. Continue on to Part B of this form.

Yes. The proposed change can be made to your permit through a minor amendment, and the application for the Minor Amendment must be submitted with 120 days of the regulation’s effective date. Proceed to Question 6 in Part D of this form and check the box for Minor Amendment.

Part B. Change to permit conditions

5) Is the proposed change only a change to permit conditions, without modification of the activity and without an associated increase in emissions?

No. Continue on to Part C of this form.

Yes. The proposed change can be made to your permit using a minor amendment. Proceed to Question 6 in Part D of this form and check the box for Minor Amendment.

Part C. Determination of increases for non-Title I changes

See instructions for calculating emissions. Make copies if more than four emission units are affected by the proposed change. Attach your calculations.

Emission Source:
Pollutant	After Change (lb/hr)	Before Change (lb/hr)	Net Change (lb/hr)	Annual (ton/year)
PM₁₀
NOx
SO₂
CO
VOC
Lead

Emission Source:
Pollutant	After Change (lb/hr)	Before Change (lb/hr)	Net Change (lb/hr)	Annual (ton/year)
PM₁₀
NOx
SO₂
CO
VOC
Lead

Emission Source:
Pollutant	After Change (lb/hr)	Before Change (lb/hr)	Net Change (lb/hr)	Annual (ton/year)
PM₁₀
NOx
SO₂
CO
VOC
Lead

Emission Source:
Pollutant	After change (lb/hr)	Before change (lb/hr)	Net change (lb/hr)	Annual (ton/year)
PM₁₀
NOx
SO₂
CO
VOC
Lead

Part D. Determination of applicability of minor or moderate amendment process

(See instructions for calculating increases. Attach any additional calculations.)

Total project emission changes by pollutant

PM₁₀		SO₂
Source	Net increase (lb/hr)	Source	Net increase (lb/hr)





NO_X		CO
Source	Net increase (lb/hr)	Source	Net increase (lb/hr)





VOC		Lead
Source	Net increase (lb/hr)	Source	Net increase (lb/hr)

Table 1: Insignificant modification, minor amendment, and moderate amendment thresholds

Pollutant	Insignificant modification	Minor amendment	Moderate amendment
NO_X	< 2.28 lb/hr	≥ 2.28 lb/hr, ≤ 9.13 lb/hr	> 9.13 lb/hr
SO₂	< 2.28 lb/hr	≥ 2.28 lb/hr, ≤ 9.13 lb/hr	> 9.13 lb/hr
VOC	< 2.28 lb/hr	≥ 2.28 lb/hr, ≤ 9.13 lb/hr	> 9.13 lb/hr
PM₁₀	< 0.855 lb/hr	≥ 0.855 lb/hr, ≤3.42 lb/hr	> 3.42 lb/hr
CO	< 5.70 lb/hr	≥ 5.70 lb/hr, ≤ 22.80 lb/hr	> 22.80 lb/hr
Lead	< 0.025 lb/hr	≥ 0.025 lb/hr, ≤ 0.11 lb/hr	> 0.11 lb/hr

To determine if the change qualifies for the Moderate or Minor Amendment process or as an insignificant modification, compare the net change in hourly emissions for the criteria pollutants to the thresholds in the instructions. Please note that the terms ‘Net Change’ and ‘Net Increase’ used in Part C and D, respectively, are not equivalent to ‘Net Emissions Increase’ as defined at 40 CFR Section 52.21(b)(3).

Even if there is no increase in emissions, you need a Minor Amendment if you wish to revise a permit condition for a change that is not a modification, and you have determined that the revision does not require a Major Amendment (using Form CH-03) and that it does not qualify for an Administrative Amendment (using Form CH-08). For example, you may be replacing an existing boiler with a smaller boiler; the existing boiler pre-dated the NSPS; the new boiler is subject to 40 CFR pt. 60, subp. Dc. While the replacement is not a modification (because there is an overall decrease in emissions calculated per Minn. R. 7007.1200, subp. 3), your permit must be amended to include the new applicable NSPS requirements.

If no amendment is needed, notification to the Minnesota Pollution Control Agency (MPCA) is still required for some activities. See Form CH-12.

6) The proposed change qualifies as a (choose one):

Minor Amendment – If the change is related to adding previously-listed insignificant activities to the permit, attach all necessary application forms to incorporate the equipment into the permit. For all other changes, attach all calculations and suggested permit language (as well as any necessary forms as listed on Form CH-14).

Moderate Amendment – Attach all calculations and suggested permit language (as well as any necessary forms as listed on Form CH-14).

Insignificant Modification – Keep documentation of your determination for your records.

No Increase and No Amendment Needed – Determine if written notification to the MPCA is required.

7) If you determined the proposed change qualifies as a minor amendment, moderate amendment, or an insignificant modification, is the proposed change part of a larger project which, taken as a whole, would not qualify for treatment as a minor amendment, moderate amendment, or an insignificant modification?

No, the proposed change is not part of a larger project. You are done with this form.

Yes. This means the proposed change potentially does not qualify for the minor amendment, moderate amendment, or insignificant modification process. Stop here and re-evaluate the proposed change as part of the larger project to determine what type of permit modification is required.

Instructions for Form CH-10

1a) AQ Facility ID number -- Fill in your Air Quality (AQ) Facility Identification (ID) Number. This is the first eight digits of the permit number for all permits issued under the operating permit program.

1b) AQ File number -- Fill in your AQ File Number. This number can be found in the “cc” line of correspondence from the Minnesota Pollution Control Agency (MCPA).

2) Facility name -- Enter your facility name.

3) Answer the question. If “Yes”, continue on with Part A; if “No”, you are done with this form.

Part A

4) Regulatory change affecting an insignificant activity – Answer the question. If “No’”, continue on with Part B; if “Yes”, proceed to question 6 (in Part D) of this form.

Part B

5) Change to permit conditions – Answer the question. If “No,” continue on with Part C; if “Yes,” proceed to question 6 (in Part D) of this form.

Part C

If you determined that the proposed change results in an emissions increase but does not require a Major Amendment, and does not qualify under the provisions for contravening permit terms or administrative amendments, then you must use the following procedure to determine the type of amendment procedure available to you under Minnesota Rules.

Use the following procedure to determine the total emissions increase from the proposed change, under State Rules. Perform the analysis for nitrogen oxides (NO_X), sulfur dioxide (SO₂), volatile organic compounds (VOC), particulate matter smaller than 10 microns (PM₁₀), carbon monoxide (CO), and lead. Do not take air pollution control equipment into account except as allowed under Minn. R. 7007.1200, subp. 3 (below).

Please provide your maximum total project emission increases, emission decreases, and net change in pounds per hour (lbs/hour), and your annual increase in tons per year (tpy) for all pollutants listed in these instructions. Supporting calculations must be attached showing that the numbers reflect the maximum possible increases. Minn. R. 7007.1200 provides the following instructions on how to calculate emissions changes for a modification that is not a Title 1 modification:

Subpart 3. Calculation method for modifications that are not title I modifications. Emissions changes for a modification must be calculated by comparing the hourly emission rate of the stationary source, at maximum physical capacity, before and after the proposed physical or operational change. The emission rate shall be expressed as pounds per hour of any regulated air pollutant. Items A to C shall be used to determine emission changes for modifications that are not title I modifications.

A. When calculating emissions before and after the physical and operational change, physical and operational limitations and emission decreases will be considered only if they:

(1) Are or will be automatically required by an applicable requirement including parts 7011.0060 to 7011.0080;

(2) Are or will be automatically required by an existing permit;

(3) Are integral to the process;

(4) Are proposed as a permit term and condition in the application for a minor, moderate, or major modification under part 7007.1450 or 7007.1500; or

(5) Are calculated in records kept at the stationary source where reductions rendered the modification insignificant under part 7007.1250.

B. In cases where use of emission factors or related calculation methods clearly demonstrates whether or not the change will increase the emission level, the emission factors as defined in part 7005.0100, subpart 10a shall be used.

C. Material balances, continuous monitor data, or manual emissions tests may be used in cases where use of emission factors or related calculation methods under item B does not clearly demonstrate, to the MPCA's satisfaction, whether or not the change will increase the emission level, or where a permittee demonstrates to the MPCA's satisfaction that there are reasonable grounds to dispute the result obtained under item B. These methods may be used only to establish pre-modification emission rates from which post-modification emission rates may be calculated. Tests shall be conducted under such conditions as the MPCA shall specify. At least three valid test runs must be conducted. All operating parameters which may affect emissions must be held constant to the maximum feasible degree for all test runs.

Part D

For each pollutant, enter each new, modified, changed, or debottlenecked unit that emits that pollutant, and the net hourly increase (net change) in emissions, as calculated in Part B, if applicable. Sum the entries for each pollutant to determine the total increase in hourly emissions due to the proposed change or modification. If all sums fall below the levels in the “Insignificant” column of Table 1, and the proposed change is not one of the exclusions listed in Minn. R. 7007.1250, subp. 2 (insignificant modification exclusions), then the proposed project is an insignificant modification. The insignificant modification exclusions in Minn. R. 7007.1250, subp. 2 are:

Subpart 2 Insignificant modification exclusions. A modification may not be made under this part if the modification:

Is a title I modification;
Would result in the violation of a permit emissions limit or any other permit term;
Is required to be authorized by a permit amendment under title IV of the act or Code of Federal Regulations, title 40, part 72, as amended;
Is part of a single project, as described in subpart 5, which taken as a whole, would not be authorized under this part; or
Is described under part 7007.1500, subpart 1 (Major permit amendment required).

If any single pollutant emissions increase is equal to or above the levels in the “Insignificant” column of Table 1 but all are below the levels in the “Moderate” column of Table 1 and the proposed change meets the requirements listed in Minn. R. 7007.1450, subp. 1 (minor or moderate amendment exclusions), then the proposed project qualifies for a minor amendment.

If any single pollutant emissions increase is equal to or above the levels listed in the “Moderate” column of Table 1 and the proposed change meets the requirements listed in Minn. R. 7007.1450 subp. 1 for minor and moderate amendments, then the proposed project qualifies for a moderate amendment. The requirements in Minn. R. 7007.1450 subp. 1. are:

Subpart 1. Minor and moderate amendment exclusions. The MPCA may amend a permit using the minor and moderate permit amendment processes described in this part if the amendments are described in subparts 2 and 3, and if the amendments are not described in part 7007.1500, subpart 1 (Major permit amendment required):

6) Check the appropriate box based on your analysis in Part C (or as directed in Part A, question 4)

Moderate permit amendment requirements:

Provide the MPCA with proposed language to amend all relevant sections of your current air emission permit for the proposed project. Attach the suggested language to this application form.

You must receive written approval from the MPCA before you can begin construction on this type of modification, and you may not begin operation of the new equipment until an air emission permit is obtained.

Minor permit amendment requirements:

Provide the MPCA with proposed language to amend all relevant sections of your current air emission permit for the proposed project. Attach the suggested language to this application form.

For regulatory changes affecting insignificant activities, you will need to complete and submit all applicable permit application forms that are needed to incorporate those activities into your permit: specifically, GI-04, GI-05A, GI-05B, GI-05C, and GI-05D, as applicable; revised GI-02 and GI-03, if applicable; GI-07 and supporting calculations in an editable spreadsheet; GI-09 series; CD-01 and CD-05, if applicable.

You may begin construction at your own risk seven working days after the MPCA receives this application. If at any time the MPCA determines that a state or local regulation applies and requires that you modify your construction plans, you will be required to do so regardless of the stage of project completeness.

7) If you determined your project is a minor amendment, moderate amendment, or an insignificant modification, check the appropriate box based on your current project and any other projects happening concurrently or planned for the future.

www.pca.state.mn.us • 651-296-6300 • 800-657-3864 • Use your preferred relay service • Available in alternative formats

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