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Mr. Bryan Adams <br />September 16, 2007 <br />Page 3 <br />Permit Application <br />• Revise ERL's existing spreadsheet to calculate the potential emissions of criteria pollutants and <br />hazardous air pollutants (HAPs) for the proposed project. <br />• Determine which type of permit amendment (insignificant, minor, moderate or major) is applicable <br />to the proposed modification. To a great extent this depends on the calculated emission rates and <br />the applicability of various state and federal regulations. <br />• Complete the required MPCA permit amendment application forms. <br />• Submit the draft permit amendment application to ERMU, ERL and WMI for review and <br />comment. <br />• Prepare a final permit amendment application by making one round of revisions to the draft <br />application based on comments received following ERMU, ERL and WMI review. <br />AERA <br />• Meet with the MPCA risk assessment staff to negotiate a mutually acceptable approach to address <br />the AERA program. <br />It is assumed that the proposed project will not exceed either the PSD or EAW thresholds. For the <br />AERA/RASS, it is possible that the meeting with the MPCA may result in more refined air dispersion <br />modeling being needed. Once the AERA scope of work is defined, a refined cost estimate can be provided <br />for that task. <br />Schedule <br />We anticipate that it will take no more than six weeks to prepare the draft permit amendment application. <br />The schedule for the AERA/BASS work will depend on the outcome of the meeting with the MPCA risk <br />assessment staff. For that reason, we recommend scheduling that meeting as soon as possible. <br />Once the draft submittal(s) has (have) been prepared, we estimate an additional two weeks to prepare the <br />final submittal(s), allowing adequate review time for ERMU, ERL and WMI personnel. <br />Cost <br />As shown in Table 1, we anticipate that the cost of preparing the permit amendment application will be <br />approximately $5,000. The cost of the AERA work, as scoped above, is $1,200, which includes the cost of <br />one Barr representative preparing for and attending the meeting with the MPCA at which the scope of <br />work required by the MPCA for this project will be better defined. <br />Table 1: Cost Estimate <br />Task Cost $ <br />1. Permit Application Prepare emission calculation spreadsheet and permit <br />a lication forms 5,000 <br />2. AERA Prepare emission calculation spreadsheet and attend meeting <br />with MPCA risk mana ers 1,200 <br />Total: 6,200 <br />