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Technical Support Document, Permit Number: 01300099-101 of 13

Technical Support Document

For Draft Air Emission Permit No. 01300099‐101

This technical support document (TSD) is intended for all parties interested in the draft permit and to meet the requirements that have been set forth 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: 2869)

Northstar Ethanol LLC dba Poet Biorefining ‐ Lake Crystal 19200 499th Ave Lake Crystal, Minnesota 56055

Northstar Ethanol LLC dba Poet Biorefining ‐ Lake Crystal 19200 499th Ave Lake Crystal, Minnesota 56055

Contact: Jim Lambert Phone: 507‐726‐5201

1.2 Facility description

Northstar Ethanol, LLC dba POET Biorefining – Lake Crystal is a fuel‐grade ethanol production plant in Lake Crystal, Minnesota. The primary emissions are volatile organic compounds (VOCs), particulate matter (PM/PM10/PM2.5), nitrogen oxides (NOX), and carbon monoxide (CO). VOCs are emitted by fermentation, distillation, dried distiller’s grains with solubles (DDGS) drying, ethanol loading, and VOC liquid storage and piping. Particulate matter is emitted by the DDGS handling and drying, grain receiving and handling, and vehicle traffic. NOX and CO are emitted by combustion sources. The plant is designed to produce 59.75 million gallons of 200‐proof ethanol annually.

The primary pieces of control equipment are fabric filters, a wet scrubber and a regenerative thermal oxidizer (RTO). The wet scrubber and RTO are connected in series to control emissions from fermentation and distillation. DDGS cooling and DDGS drying are controlled by the RTO. Fabric filters control PM/PM10/ PM2.5 from the grain and DDGS handling and storage systems. There are five large, internal floating roof tanks for ethanol, denaturant, and denatured ethanol storage. Emissions from process valves and piping are controlled through an inspection and maintenance program.

1.3 Description of the activities allowed by this permit action

The MPCA has a combined operating and construction permitting program under Minn. R. ch. 7007, and under Minn. R. 7007.0800. Under that authority, this permit action authorizes construction.

Major permit amendment application received 9/9/2015:

This major permit amendment authorizes changes in operation at the facility. The Permittee will construct ductwork to allow an alternative operating scenario for emissions from COMG 6 (fermentation and distillation processes) to bypass the wet scrubber (TREA 7) for a maximum of 100 hours per year during maintenance activities. The emissions will still be vented to the RTO. The maximum beer feed rate will be increased from 641 gallons per minute (gpm) to 700 gpm to allow the facility to operate at capacity. Flexibility provisions have also been added to the permit which makes existing Title I Conditions applicable to future new or modified control equipment, potentially allowing the Permittee to replace control equipment without a major permit amendment.


1.4 Facility emissions:

Table 2. Title I emissions summary

Pollutant

Unlimited potential emissions from the modification (tpy)

Limited potential emissions from the modification (tpy)

NSR/112(g) threshold for new major source (tpy)

NSR/112(g) review required? (yes/no)

PM 104.91 21.62 250 No PM10 52.74 17.60 250 No PM2.5 10.53 1.75 250 No NOX 48.18 0.00 250 No SO2 0.70 0.00 250 No CO 44.5 0.70 250 No Ozone (VOC) 48.51 6.65 250 No Lead 0.00 0.00 250 No HAPs‐Single 50.1 2.36 10 No HAPs‐Total 92.6 6.57 25 No

Table 3. Facility classification

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

1.5 Changes to permit

Technical changes to the permit are described in detail in section 3 of this TSD. The MPCA has a combined operating and construction permitting program under Minnesota Rules Chapter 7007, and under Minn. R. 7007.0800, the MPCA has authority to include additional requirements in a permit. Under that authority, the following changes to the permit are also made through this permit action:

• Migrated permit conditions to Tempo (MPCA’s new database) from Delta (the previous database).

• The permit has been updated to reflect current MPCA templates and standard citation formatting.

• Completed requirements have been deleted.

COMG 2 (Tanks subject to NSPS subp. Kb) requirements were updated. The 190‐proof and 200‐proof ethanol process tanks, EQUI 73 and EQUI 74 (formerly TKs 001 and 002), were also removed from this group since process tanks are not subject to the NSPS subp. Kb. Please refer to Attachment 6 of this TSD for more information on this applicability determination.

Minnesota standards for post‐1969 industrial process equipment were added to the ethanol process tanks, EQUI 73 and EQUI 74 since these tanks are no longer subject to the NSPS subp. Kb.

Control equipment units which are also emission units (e.g. flares, RTOs) are now represented as controls only. EU 047 (Loadout Flare) was removed and the requirements were combined with TREA 14 (Flaring). EU 042 (Regenerative Thermal Oxidizer) was removed, and the requirements were combined with TREA 8 (RTO).

The name associated with SV007 was changed from "Fermentation Scrubber AOS Bypass" to "RTO Bypass Stack AOS". This change is intended to clarify the bypass scenarios in the permit.

Permit limits in the form of concentration limits, i.e. grains/dry standard cubic feet (gr/dscf) were changed to mass based limits, i.e. lb/hr.


GP 006 (Fabric Filters) and GP 009 (Hammermill Vents) were removed from the permit, with the requirements of each group being moved to the individual units within these groups. This was necessary to allow the flexible replacement provisions added to the permit.

STRU 21 and STRU 26 (Dryer A and Dryer B Emergency Bypasses) requirements were updated to clarify that bypass events shall be reported as deviations.

2. Regulatory and/or statutory basis

2.1 New source review (NSR)

The permit carries forward limits on the facility such that it remains a minor source under New Source Review regulations.

2.2 Part 70 permit program

The facility has a PTE for GHG of more than 100,000 tpy and became a major Title V source on July 1, 2011 due to the EPA’s GHG Tailoring Rule. The Supreme Court has since ruled that Title V permitting based solely on GHG emissions is impermissible under the Clean Air Act. The Permittee has not applied for a state operating permit and will continue to operate under its Title V operating permit.

2.3 New source performance standards (NSPS)

The facility is subject to the following NSPS:

Subpart Kb – Standards of Performance for Volatile Organic Liquid Storage Tanks: The following table provides the data used for determining applicability of the standard:

Table 4. 40 CFR § 60.110b(a) Applicability and Exemptions

Tank Capacity (m3)

Material stored

Max vapor pressure (kPa)1

Is capacity ≥ 75 m3 and constructed

after July 23, 1984?

Is 75 m3 < capacity < 151 m3 and VP < 15 kPa?

Is it a process tank as defined in 60.111b?

Subject to NSPS

subp. Kb?

EQUI 72 (804)

7570.8

Denatured ethanol

>5.2 kPa Yes No No Yes

EQUI 73 (802)

726.8

200‐proof ethanol

>5.2 kPa Yes No Yes, exempt No

EQUI 74 (801)

726.8

190‐proof ethanol

>5.2 kPa Yes No Yes, exempt No

EQUI 75 (805)

480.7 Denaturant

> 27.6 kPa Yes No No Yes

EQUI 77 (803)

7570.8 Denatured ethanol

>5.2 kPa Yes No No Yes

1. Max. vapor pressure is defined as local maximum monthly average temperature as reported by the National Weather Service for VOL's stored at the ambient temperature. The vapor pressure used in the Tanks program is a different value based on a different averaging period.

Subpart Dc – Standards of Performance for Steam Generating Units: Subpart Dc applies to each steam generating unit with a heat input capacity between 10 and 100 million British thermal units per hour (MMBtu/hr). EQUI 53 and EQUI 61 (COMG 1) are subject to this NSPS.

Subpart VV and Subpart VVa – Standards of Performance for Equipment Leaks: The facility is choosing to comply with subp. VVa for all equipment leaks. The provisions of this subpart apply to affected facilities in the synthetic organic chemicals manufacturing industry.

Subpart DD – Standards of Performance for Grain Handling Facilities: The facility’s grain storage capacity exceeds 2.5 million bushels (bu) due to a previous permit modification. STRU 9 (Grain Handling) has since been modified and is subject to the NSPS subp. DD.

The Permittee has stated that no other new source performance standards apply to the facility.


2.4 National emission standards for hazardous air pollutants (NESHAP)

The facility uses and tests control equipment which effectively limits hazardous air pollutants (HAP) emissions such that it is a non‐major source under 40 CFR pt. 63.

Thus, no major‐source NESHAPs apply.

The 3 generators at the source (COMG 5) are subject to the NESHAP subp. ZZZZ ‐ National Emissions Standards for Hazardous Air Pollutants for Stationary Reciprocating Internal Combustion Engines. All of the generators are existing, non‐emergency, non‐limited use compression ignited engines with site capacities greater than 500 brake‐horsepower.

US EPA has promulgated Part 63, Subpart VVVVVV for sources which operate chemical manufacturing process units and are minor sources of HAP. An applicability determination was made in 2010 that determines that subp. VVVVVV does not apply to this facility.

2.5 Compliance assurance monitoring (CAM)

A CAM plan was created for the RTO (TREA 8) and is attached to this TSD. No control equipment was added or replaced in this modification so CAM does not apply and the facility’s existing CAM plan was not updated.

2.6 Environmental review and air emissions risk analysis (AERA)

The facility does not trigger any of the requirements for the need to conduct environmental review, i.e. an Environmental Assessment Worksheet (EAW), and is not required to perform an AERA.

2.7 Minnesota state rules

No new Minnesota Rules become effective as a result of this permit action. Portions of the facility are subject to the following Minnesota Standards of Performance:

• Minn. R. 7011.0150 ‐ Minnesota Performance Standards for Bulk Agricultural Handling Facilities

• 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

• Minn. R. 7011.2300 ‐ Standards of Performance for Stationary Internal Combustion Engines

Table 5. Regulatory overview of units affected by the modification/permit amendment

Subject item* Applicable regulations Rationale

Total Facility

Title I limits to avoid major source classification for 40 CFR §52.21 and to avoid major source classification for 40 CFR §63.2

The production and throughput limits restrict allowable emissions to below major source thresholds.

Best Management Practice Odor Plan There have been no odor complaints at this facility. The odor plan ensures wet cake is managed well.

Minn. R. 7011.1005, subp. 1 Minnesota Standards of Performance for Dry Bulk Agricultural Facilities applies to facility property.

Minn. R. 7011.0150 Minnesota Standards of Performance for Preventing Particulate Emissions from Becoming Airborne. This subpart applies to the facility in general.

COMG 3: Dryers

Title I limits to avoid major source classification for 40 CFR §52.21

Vent all emissions to an RTO meeting the requirements of TREA 8 to keep emissions below major source thresholds.

Minn. R. 7011.0610 Minnesota Standards of Performance for New Direct‐Heating Equipment.

COMG 5: Generators Title I limits to avoid major source classification for 40 CFR §52.21

Limits on hours of operation for each generator to keep emissions below major source thresholds.


40 CFR pt. 63, subp. ZZZZ

NESHAP for Stationary Reciprocating Internal Combustion Engines. Determination of applicable limits from rule: Engines are existing, at an area source of HAP emissions Each engine is non‐limited use, non‐emergency Engines are compression‐ignited w/ a capacity ≥ 500 bhp Catalytic oxidizers (TREAs 18‐20) are used to comply with the standard

Minn. R. 7011.2300 Minnesota Standards of Performance for Stationary Internal Combustion Engines.

COMG 6: Fermentation and Distillation

Title I limits to avoid major source classification for 40 CFR §52.21 and to avoid major source classification for 40 CFR §63

Vent all emissions to a wet scrubber meeting the requirements of TREA 7, and vent all emissions to an RTO meeting the requirements of TREA 8 to keep emissions below major source thresholds.

Alternative Operating Scenario One: ≤ 500 hours/yr of bypassing the RTO. Alternative Operating Scenario Two: ≤ 100 hours/yr of bypassing the wet scrubber. The Permittee may bypass the control equipment only during periods of maintenance or breakdown of the control equipment and associated equipment.

Hammermill Vents: STRU 11 – 13, STRU 24


Vent all emissions to fabric filters meeting the requirements of each individual TREA to keep emissions below major source thresholds.

Minn. R. 7011.1005, subp. 3(D) and Minn. R. 7011.1010

Minnesota Standards of Performance for Dry Bulk Agricultural Facilities.

Emission limits for PM, PM10, and PM2.5 to prevent potential emissions from exceeding major source levels.

40 CFR pt. 60, subp. DD

Facility's storage capacity is greater than 2.5 million bushels and is a grain terminal elevator. STRU 9 lb/hr limits are more stringent than subp. DD limit of 0.01 grain/dscf.


Minnesota Standards of Performance for Dry Bulk Agricultural Facilities. Maintain pollution control equipment and maintain facility such that it is not a public nuisance.

STRU 10: Grain Cleaning


Vent all emissions to a fabric filter meeting the requirements of TREA 2 to keep emissions below major source thresholds.

Emission limits for PM, PM10, and PM2.5 to prevent potential emissions from exceeding major source levels.



STRU 14: Flour Receiver





STRU 15: RTO Bypass AOS


VOC on a total mass basis: ≤ 23.6 lb/hr to keep emissions below major source thresholds. Effectively restricts HAP emissions.


STRU 16: Centrifuges/CO2/Dryers


Emission limits for PM, PM10, PM2.5, NOX, CO and VOCs to prevent potential emissions from exceeding major source levels.

Vent all emissions to an RTO meeting the requirements of TREA 8 to keep emissions below major source thresholds.

Minn. R. 7011.0610 Minnesota Standards of Performance for Fossil Fuel Burning Direct Heating Equipment.

STRU 17: DDGS Silo





STRU 18: DDGS Silo Bypass Title I limits to avoid major source classification for 40 CFR §52.21


EQUI 73 and EQUI 74: 190‐proof and 200‐proof ethanol tanks

Minn. R. 7011.0715 Standards of Performance for Post‐1969 Industrial Process Equipment applies since the tanks are no longer subject to the NSPS subp. Kb.

EQUI 80: Uncaptured grain receiving emissions

40 CFR pt. 60, subp. DD Standards of Performance for Grain Elevators (meets the requirements of Minnesota Standards of Performance for Dry Bulk Agricultural Facilities).

Minn. R. 7011.1005

Minnesota Standards of Performance for Dry Bulk Agricultural Facilities. Clean up spilled commodities to prevent fugitive emissions and maintain facility such that it is not a public nuisance.

EQUI 81: Uncaptured DDGS loadout emissions


Minnesota Standards of Performance for Dry Bulk Agricultural Facilities. Clean up spilled commodities to prevent fugitive emissions, and maintain facility such that it is not a public nuisance.

Fabric Filters: TREAs 3 – 6, TREAs 11 – 13, TREA 15


Requirements to operate and maintain fabric filters to meet an overall control efficiency: ≥ 99% for Total PM, ≥ 93% for PM10 and PM2.5 to keep emissions below major source thresholds.

TREA 1: Fabric Filter for STRU 9


Overall control efficiency: ≥ 99.6% for PM, ≥ 98.9% for PM10 and PM2.5 to keep emissions below major source thresholds.

Minn. R. 7011.0072 Initial Hood Capture Certification and Evaluation is required when capture efficiencies of < 100% are used in calculations.

TREA 2: Fabric Filter for STRU 10 Title I limits to avoid major source classification for 40 CFR §52.21

Overall control efficiency: ≥ 99.6% for PM, ≥ 99.0% for PM10 and PM2.5 to keep emissions below major source thresholds.

TREA 7: Wet Scrubber


VOC control efficiency: ≥ 95.0% when emissions are not vented to the RTO. Normal operation is for the scrubber to be operated in series with the RTO.

TREA 8: RTO


VOC control efficiency: ≥ 95.0%, CO control efficiency: ≥ 90%, PM/PM10 /PM2.5 ≥ 90% to keep emissions below major source thresholds.

Minn. R. 7005.0100, subp. 35a Fuel type restricted to natural gas only, by design.

TREA 18, 19, 20: CO Catalysts 40 CFR pt. 63, subp. ZZZZ Pressure Drop: ≤ 2 in. of w.c. from the pressure drop measured during the last performance test, Temperature: ≥ 450°F and ≤ 1635°F


FUGI 3: Truck Traffic Minn. R. 7011.0150

Minnesota Standards of Performance for Dry Bulk Agricultural Facilities. Opacity: ≤ 5%, clean up spilled commodities to prevent fugitive emissions and maintain facility such that it is not a public nuisance.

*Location of the requirement in the permit (e.g., EQUI000000001, STRU0000000002,etc.).

3. Technical information

3.1 Control equipment replacement procedures

Permit flexibility conditions were added that make the existing conditions enforceable for replacement and modified control devices. This may allow the Permittee to make these changes without triggering a major amendment. The Permittee may replace or modify individual control equipment which can meet the requirements of the permit. Language was changed at the TREA and STRU levels so that replacement or modified units will be subject to the existing permit requirements. These flexibility provisions were added to the following units:

Fabric Filters: TREAs 3 ‐ 6, TREAs 11 – 13, TREA 15

TREA 1 (Grain handling baghouse)

TREA 2 (Grain cleaning baghouse)

TREA 7 (Wet scrubber)

TREA 8 (RTO)

TREA 14 (Flaring)

If the RTO and/or wet scrubber are replaced, performance testing will be required for VOCs, NOX, and CO at STRU 16 within 90 days of the replacement. New requirements were added at the total facility (TFAC) level to ensure that these changes could not make the Permittee a major NSR source and how to track equipment replacements using an equipment inventory (Appendix D of the permit).

Replacement provisions were not added at TREA 16 (Route to auxiliary boiler burners) because these units (EQUIs 53 and 61) function primarily as emission units. PTE calculations are based off of manufacturer’s guarantees for these units so changes cannot be pre‐authorized in the same way as the other units could.

3.2 Alternative operating scenarios

The permit includes an alternative operating scenario at STRU 15 (RTO Bypass AOS) under which the Permittee may bypass the RTO with parts of the emissions stream for up to 500 hours per 12 month period. This alternative operating scenario allows the facility to continue to operate if the RTO is unoperational.

Emissions from the DDGS cooling system are also allowed to bypass combustion in the RTO or dryer for up to 500 hours per 12 month period. The exhaust stream from the DDGS cooling system is routed to the burners (as combustion air) of the RTO and dryer. If this gas stream becomes too laden with particulate matter, the burners will malfunction. This alternative operating scenario allows continued operation if the gas stream becomes too particulate‐laden for up to 500 hours in a 12‐month period.

The Permittee may also bypass the ethanol loadout flare while loading tanker trucks with ethanol for a maximum of 5 million gallons of ethanol per 12 month period. This allows continued loading if the flare is down.

In this permit action, an alternative operating scenario was also added to STRU 16 (Centrifuges/CO2/Dryers) to allow for bypass of the wet scrubber (TREA 7). Emissions from COMG 6 will be permitted to bypass TREA 7 for a maximum of 100 hours per 12 month period. These emissions will still be treated by the RTO (TREA 8) during this time. The Permittee may not simultaneously bypass the RTO and scrubber. When bypassing the scrubber, emissions would still be vented from STRU 16 because the RTO is in series with the scrubber. An initial performance test will be required to verify the emission factors used to calculate VOC/HAP emissions during this alternative operating scenario.


All of the emissions resulting from these alternative operating scenarios are included in the emissions estimates and the Permittee must keep records that demonstrate compliance with the limits.

3.3 NESHAP subp. ZZZZ requirements

Specific requirements to comply with NESHAP subp. ZZZZ were added to the permit. Catalytic oxidizers (TREAs 21 ‐ 23) were installed on the generators (EQUIs 56 – 58) to comply with the standard, and applicable control equipment rules and subp. ZZZZ standards were added to these subject items. Performance testing requirements were added to EQUIs 56 – 58. General subp. ZZZZ compliance, monitoring, and recordkeeping requirements were added to the pre‐existing COMG 5 (Generators) requirements.

3.4 Beer feed rate increase

The maximum beer feed rate was increased from 641 gpm to 700 gpm to allow the Permittee to meet it’s existing annual ethanol production limits. This operational change will result in an increase in the VOC/HAP inlet concentration to the RTO (TREA 8). The 2015 RTO test result showed that the actual emissions were about 75% of the past permit limit for VOCs. To maintain this margin of safety, the Permittee proposed increasing the VOC limit by 10% from 6.71 lb/hr to 9.9 lb/hr. The 10% increase is proportional to the beer feed rate increase.

Short‐term production limits are included in the permit to define worst‐case test conditions and resulting operating parameters. If the Permittee tests at < 80% of the associated emission limit(s) and the throughput rate during testing is > 90% of the short‐term listed production limit in the permit, the Permittee can increase the short‐term production limit by 10% without a retest. The beer feed rate increase fits within these parameters for the RTO. The beer feed limit has been rewritten to clarify that it is not an absolute maximum and can be increased or decreased as an operating parameter during performance testing.

The new beer feed rate will change emissions from the permitted bypass scenarios. The 2015 scrubber test (STRU 15: RTO Bypass Stack AOS) showed that the actual emissions were about 88% of the current permit limit. Therefore, the Permittee proposed to base the increase in the RTO bypass emissions on a 10% increase from the actual emissions from the stack test plus a 25% safety margin.

The previous beer feed limit was at COMG 3 (Dryers) and was moved to STRU 16 (Centrifuges/CO2/Dryers) requirements. The beer feed needs to be less than the rate measured during performance testing through all processes venting to STRU 16, and not just at the dryers. Beer rate recordkeeping requirements were also moved to STRU 16.

3.5 Performance testing at maximum capacity

Performance tests shall be conducted at worst case conditions as defined at Minn. R. 7017.2005, subp. 8. For ethanol production facilities, this means that each process emitting to a tested stack must be operated at maximum capacity during testing. However, it is difficult at an ethanol facility to determine maximum capacity. Language was added to all performance testing requirements to ensure that short‐term production rates relied upon to determine compliance with lb/hr emission limits are not exceeded. An Appendix C was also added to the permit which lists the process parameters that must be tracked during each performance test.

Short term production limits were added at STRU 16. These limits define expected worst case conditions according to Minn. R.7017.2025 subp. 3(A). The facility will conduct initial performance tests for particulates at STRU 9 and STRU 10 to determine worst case conditions for grain receiving, DDGS loadout, and grain handling throughputs.

3.6 Uncaptured grain and DDGS emissions

Uncontrolled PM emissions from Grain Receiving (EQUI 1) and DDGS Handling (EQUI 2) were counted as fugitive emissions (FS 002) in the previous permit. Because loading and unloading emissions can and are captured, these do not qualify as fugitive emissions. EQUI 1 was renamed “Grain receiving pit captured emissions” and EQUI 2 “DDGS loadout captured emissions”. Next, 2 new EQUIs were added for “Grain receiving pit uncaptured emissions (EQUI 80)”, and “DDGS loadout uncaptured emissions (EQUI 81)”. These


two new EQUIs represent the former emissions from FS 002; no emission increases are authorized through this action. FS 002 requirements were moved to these new units, and FS 002 was removed from the permit. Lastly, the 80% minimum capture requirement was removed from the TREA 1 control efficiency equation which applied to all units controlled by TREA 1. Specific capture efficiency requirements were added to TREA 1 for EQUI 1 and EQUI 2.

The hood which is used to capture emissions from EQUI 1 and EQUI 2 has never been evaluated according to Minn. R. 7011.0072. Permit requirements to conduct initial hood certifications for the grain receiving and DDGS loudout areas conforming to the requirements in Minn. R. 7011.0072 were added to TREA 1.

3.7 Calculations of potential to emit and emissions increase analysis

Attachment 1 to this TSD contains the Title I net emissions increase calculations for this modification. This demonstrates that this modification is not a major modification for PSD.

The VOC and HAP emission calculations included in the permit application are primarily based on 2015 performance tests that measured VOCs as VOCs by mass. VOC emissions from the RTO and control equipment bypass scenarios were based on the new limits discussed above. The VOC and HAP emission calculations assume a destruction efficiency of 95 percent in the wet scrubber and 95 percent in the thermal oxidizer. Calculations are included in Attachment 1 to this TSD.

AP‐42 (Compilation of Air Pollutant Emission Factors) emission factors were used for emission estimates for the combustion of natural gas, particulate matter from grain handling, particulate matter from vehicle traffic, diesel fuel combustion, tanks, and fugitive emissions from piping and valves.

3.8 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.

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.

The kind of monitoring found on similar units elsewhere.

The table below summarizes the monitoring requirements associated with this amendment.

Table 5. Monitoring

Subject item* Requirement (rule basis) Monitoring Discussion

Total Facility

Ethanol production limit ≤ 59,750,000 gallons/yr of denatured ethanol

Daily record of production and monthly calculations of ethanol production.

Based on a flow meter of 200‐proof ethanol transferred to the storage tanks.

Process throughput limit ≤ 642,710 ton/yr of grain (Limits to avoid NSR and NESHAP major source)

Daily records and monthly calculations of grain throughput.

The Permittee records the quantity of all grain received based on delivery records. In addition, there is a record of each truck and rail car load of ethanol so shipping records are available to backup production.

COMG 3: Dryers PM: ≤ 0.30 gr/dscf Fuel usage, recordkeeping of monthly fuel records

All units use natural gas so the likelihood of violating either of the emission limits is


Opacity: < 20 % with exceptions (Minn. R. 7011.0610)

Vent emissions to RTO very small.

COMG 5: Generators

Opacity: ≤ 20% with exceptions

Fuel limited to No. 2 fuel with ≤ 15 ppm sulfur

SO2 limit is met by burning ultra‐low sulfur diesel fuel. Fuel supplier certifications must be received for each shipment. PTE of each generator is 0.001515 lb/MMBtu.

SO2 ≤ 0.50 lb/MMBtu heat input (Minn. R. 7011.2300)

Hours of operation: ≤ 140 hours/yr based on a 12‐month rolling sum (Limit to avoid NSR major source)

Daily records using a non‐resettable running time meter. Monthly calculation of 12‐month rolling sum limit

The Permittee is required to maintain monthly records of the 12‐month rolling sum of the hourly operation of each generator.

Carbon Monoxide: ≤ 23 ppm or reduce emissions by 70% or more (40 CFR pt. 63, subp. ZZZZ)

Vent all emissions through a CO Catalyst (TREA 18, 19, 20), performance testing

Each COMG 5 generator is an affected unit and is required to be tested for CO emissions every 36 months or 8760 hours of operation for each engine. 2013 tests showed that removal efficiency of CO exceeded 87% for each engine.

COMG 6: Fermentation and Distillation

AOS 1: Operating hours: ≤ 500 hours/yr on a 12‐month rolling sum of bypassing the RTO

Daily records and monthly calculation of the hours of and reasons for bypassing the RTO

The facility is permitted to bypass the thermal oxidizer up to 500 hours per 12‐month period. The Permittee shall record the time and duration of each bypass.

AOS 2: Operating hours: ≤ 100 hours/yr on a 12‐month rolling sum of bypassing the wet scrubber (Limits to avoid NSR and NESHAP major source)

Daily records and monthly calculation of the hours of and reasons for bypassing the wet scrubber

The facility is permitted to bypass the wet scrubber up to 100 hours per 12‐month period. The Permittee shall record the time and duration of each bypass. AOS 1 and 2 may not be operated simultaneously.

EQUI 50: DDGS Fluid Bed Cooler

Vent all emissions to the dryer burners (EQUI 47 and EQUI 48) and/or auxiliary boiler burners (EQUI 53 and EQUI 61).

Daily recordkeeping and monthly calculation of hours bypassed

The DDGS coolers are vented to both boilers and the DDGS Dryers as preheat air to reduce fuel use. The dryers are vented to the RTO. The majority of the air goes to the dryers. If the dryers go down, the DDGS fluid bed cooler also goes down. Only in the event of a startup, shutdown, or malfunction do emissions from the DDGS Fluid Bed Cooler vent to the bypass stack STRU 22.

Bypass hours: < 500 hours/yr using 12‐month rolling sum (Limits to avoid NSR major source)

EQUIs 73 and 74: 190‐proof and 200‐proof ethanol tanks

Opacity: ≤ 20% PM: ≤ 0.30 grains/dscf (Minn. R. 7011.0715)

None

These are process tanks which temporarily store ethanol. Minimal opacity and particulate emissions would be expected due to the product inside.

EQUI 80: Uncaptured Receiving Pit Emissions

Opacity: ≤ 5% (40 CFR pt. 60, subp. DD) Closing doors while

unloading grain, hood certifications

Minimal opacity is expected if capture hoods conform to Minn. R. 7011.0072.

EQUI 81: Uncaptured DDGS Loadout Emissions

Opacity: ≤ 10% (Minn. R. 7011.1005, subp. 3(A))

STRUs 11 – 13, STRU 24: Hammermill Vents

Opacity: ≤ 10% (Minn. R. 7011.1005, subp. 3(D))

Vent all emissions through a fabric filter

Visible emissions are used as an indicator of normal operation of the fabric filter and thus compliance with the efficiency and opacity limits. The Permittee must record the pressure drop.

STRU 9: Grain Handling PM: ≤ 0.99 lb/hr Vent all emissions through

a fabric filter (TREA 2), Visible emissions are used as an indicator of normal operation of the fabric filter. PM10: ≤ 0.99 lb/hr


PM2.5: ≤ 0.17 lb/hr (Limits to avoid NSR major source, meets 40 CFR Section 60.302(b)(1) and (c)(1))

Performance testing for PM and PM10 every 5 years

2015 performance tests on STRU 9 showed that Total PM emissions were 0.048 lb/hr.

Opacity < 0 % (40 CFR Pt. 60, subp. DD)

Grain received: ≤ 12,238 bu/hr DDGS Loaded: ≤ 50.0 tons/hr (Limits to avoid NSR major source)

Measure and record grain receiving totals on an hourly basis. Measure and record DDGS loading totals on an hourly basis

The process throughput rates are based on the maximum rates achieved during the last performance test and ensures that performance tests are conducted at worst case conditions.

STRU 10: Grain Cleaning

PM: ≤ 0.09 lb/hr

Vent all emissions through a fabric filter (TREA 2), performance testing for PM and PM10 every 5 years

Visible emissions are used as an indicator of normal operation of the fabric filter. 2015 performance tests on STRU 10 showed that Total PM emissions were 0.003 lb/hr.

PM10: ≤ 0.09 lb/hr

PM2.5: ≤ 0.015 lb/hr (Limits to avoid NSR major source)

Opacity < 10 % (Minn. R. 7011.1005, subp. 3(D))

Grain throughput ≤ 2,605 bu/hr (Limits to avoid NSR major source)

Measure and record grain throughput totals on an hourly basis

The process throughput rates are based on the maximum rates achieved during the last performance test and ensures that performance tests are conducted at worst case conditions.

STRU 14: Flour Receiver Opacity < 10 % (Minn. R. 7011.1005, subp. 3(D))

Vent all emissions through a fabric filter (TREA 2)

Visible emissions are used as an indicator of normal operation of the fabric filter and thus compliance with the opacity limits. See TREA 6.

STRU 15: RTO Bypass VOC < 29.0 lb/hr (limit to avoid NSR)

Performance test for total mass of VOC every 5 years, pressure drop and water flow rate at wet scrubber (TREA 7)

COMG 6 allows up to 500 hours per year of bypassing of the RTO (TREA 8). Testing is required to ensure that the lb/hr value used to calculate VOC emissions is appropriate. 2015 tests showed that VOC emissions were 20.71 lb/hr.

STRU 16: Centrifuges/CO2/Dryers

PM: < 8.0 lb/hr Initial performance test for total mass of VOC, test all other pollutants every 5 years. Vent all emissions through the RTO, except as allowed by COMG 6. Temperature monitoring at RTO (TREA 8)

2015 RTO stack test results showed that emission were 3.26 lb/hr for PM, 5.55 lb/hr for NOX, 6.55 lb/hr for CO, and 6.71 lb/hr for VOC.

PM10: < 8.0 lb/hr

PM2.5: < 8.0 lb/hr

NOX: < 11.0 lb/hr

CO: < 10.0 lb/hr

VOC: < 9.9 lb/hr

Beer Feed Rate ≤ 700 gpm (Limits to avoid NSR and NESHAP major source)

Measure and record beer feed rate on an hourly basis

The beer feed rate is based on the maximum production achieved during the last performance test and ensures that performance tests are conducted at worst case conditions.

STRU 17: DDGS Silo Opacity < 10 % (Minn. R. 7011.1005, subp. 3(D))

Vent all emissions through a fabric filter (TREA 12)

Visible emissions are used as an indicator of normal operation of the fabric filter and thus compliance with the opacity limits. See TREA 12.

TREA 1: Grain Handling Baghouse

PM control efficiency: > 99.6%

Fabric filter monitoring for visible emissions, O & M, corrective actions, performance testing at

Visible emissions and pressure drop readings are used as an indicator of normal operation of the fabric filter and thus compliance with the efficiencies.

PM10 control efficiency: > 98.9 %


PM2.5 control efficiency: > 98.9 %

STRU 9 Pressure Drop ≥ 0.5 in. of w.c. and < 6.0 in. of w.c (Limits to avoid NSR major

source)

PM, PM10, PM2.5 capture efficiency at EQUI 1 and EQUI 2: ≥ 80%

Closing doors while unloading grain, power draw monitoring

80% capture is expected if capture hoods conform to Minn. R. 7011.0072. The Permittee continuously monitors the fan power and air flow of these hoods.

TREA 2: Grain Cleaning Baghouse

PM control efficiency: > 99.6%

Fabric filter monitoring for visible emissions, O & M, corrective actions, performance testing at STRU 10 Pressure Drop ≥ 0.5 in. of w.c. and < 6.0 in. of w.c

Visible emissions and pressure drop readings are used as an indicator of normal operation of the fabric filter and thus compliance with the efficiencies.

PM10 control efficiency: > 98.9 %

PM2.5 control efficiency: > 98.9 %

Fabric Filters: TREAs 3 – 6, TREAs 11 – 13, TREA 15

PM control efficiency: > 99% PM10 control efficiency: > 93% PM2.5 control efficiency: > 93% (Limits to avoid NSR major source)

Monitoring for visible emissions, O & M, Pressure Drop ≥ 0.5 in. of w.c. and < 6.0 in. of w.c

Visible emissions are used as an indicator of normal operation of the fabric filter, along with maintaining the pressure drop limit. Initial performance tests on the stacks showed that particulate emissions are much lower than those relied upon for determining the PTE of the facility.

TREA 7: Wet Scrubber

PM10 control efficiency: > 93% PM2.5 control efficiency: > 93% (Limits to avoid NSR major source)

Pressure Drop ≥ 2.0 in. of w.c. and < 10 in. of w.c

The pressure drop and water flow monitoring assures that the wet scrubber is properly functioning. VOC emissions are tested at STRU 15 and 16.

Water Flow Rate ≥ 35.0 gpm when emissions are vented to RTO, ≥ 49.5 gpm when emissions are not vented to the RTO

TREA 8: RTO

VOC control efficiency: ≥ 95%

Temperature: > 1635°F Continuous temperature monitoring, recordkeeping, O & M, inspections, and CAM Plan

Minimum temperature assures destruction of VOC and CO; since most PM entering the TO is organic, temperature also assures adequate combustion of PM. STRU 16 requires testing of VOCs on a mass basis to meet the limit of 9.9 lb/hr. Per the calculations, 9.9 lb/hr is the equivalent of 95% control. Emissions venting to TREA 8 constitute a large PSEU.

CO control efficiency: ≥ 90%

PM control efficiency: ≥ 90%

PM10 control efficiency: ≥ 90%

PM2.5 control efficiency: ≥ 90%

(Limits to avoid NSR, NESHAP major source, CAM)

TREA 18, 19, 20: CO Catalysts

Pressure Drop: ≤ 2 in. of w.c. from the pressure drop measured during the last performance test

Performance testing

The pressure drop and temperature must be recorded during the initial performance test and each subsequent test. The Permittee shall conduct a performance evaluation of each CPMS in accordance with the site‐specific monitoring plan.

Temperature: ≥ 450°F and ≤ 1635°F at the catalyst inlet (40 CFR pt. 63, subp. ZZZZ)

Continuous temperature monitoring, O & M, inspections

3.9 Insignificant activities

Northstar Ethanol LLC has several operations which are classified as insignificant activities under the MPCA’s permitting rules. These are listed in Appendix A to the permit. No insignificant activities were added or changed in this modification.

3.10 Permit organization


In general, the permit meets the MPCA Tempo Guidance for ordering and grouping of requirements. One area where this permit deviates slightly from Tempo 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 the Requirements table in Tempo. 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.

Another area that deviates from the guidance is in the use of groups where the requirements in the group apply to the members of the group individually. This was done in order to shorten the permit and where no testing or tracking specific to a unit is in the permit (thereby reducing the likelihood that there where will be further unit‐specific requirements later). This is the case for the requirements at COMG 2 (Tanks) and COMG 5 (Generators).

3.11 Comments received

This section is to be completed following the public and EPA notice periods.

3 Permit fee assessment

Attachment 3 to this TSD contains the MPCA’s assessment of Application and Additional Points used to determine the permit application fee for this permit action as required by Minn. R. 7002.0019. This major permit amendment (25 pts.) includes limits to remain an NSR minor source (10 pts.) NESHAP subp. ZZZZ was an existing standard that applied to the facility and is not a chargeable activity.

4 Conclusion

Based on the information provided by Northstar Ethanol LLC the MPCA has reasonable assurance that the proposed operation of the emission facility, as described in the Air Emission Permit No. 01300099‐101 and this TSD, will not cause or contribute to a violation of applicable federal regulations and Minnesota Rules.

Staff members on permit team: Eric Sulita (permit engineer)

Bonnie Nelson (peer reviewer)

Beckie Olsen (permit writing assistant)

Laurie O’Brien (administrative support)

Curt Stock (stack testing)

Cory Boeck (enforcement staff)

TEMPO360 Activities: Permit Change ‐ Major

Attachments: 1. PTE summary and emissions increase calculation spreadsheets 2. Requirements development report 3. Subject item inventory 4. Points calculator 5. CAM Plan 6. NSPS subp. Kb Applicability Determination

Attachment 1: PTE summary and emissions increase calculation spreadsheets

Northstar Ethanol, LLC d/b/a POET Biorefining - Lake CrystalLake Crystal, MinnesotaProject Parameters

CURRENT OPERATIONS:Annual Grain Receiving 21,100,000 bushels/yrBeer Feed Rate 641 gpmCurrent Gallons Anhydrous Ethanol Produced per Year: 59.75 MMgal/yr Permit LimitDenaturant Delivery 2.99 MMgal/yrDenatured Ethanol Production Rate 62.7 MMgal/yrGrain Receiving Capacity 30,000 bushel/hrGrain Receiving Capacity 840 ton/hrAnnual Grain Receiving 642,710 tons/year Permit LimitHourly DDGS Production 23 tons/hourAnnual DDGS Production 192,394 ton/year Permit Limit

FUTURE OPERATIONS:Production IncreasesTotal Production after Increase in Gallons Anhydrous Ethanol Produced per Year: 59,750,000 gallon/yrBeer Feed Rate 700 gpmDenatured Ethanol Production Rate 62,737,500 gallon/yrIncrease in Gallons Anhydrous Ethanol Produced per Year: 0 gallon/yrIncrease in Gallons Denatured Ethanol Produced per Year: 0 gallon/yrIncrease in Gallons Denaturant per Year: 0 gallon/yrDenaturant Throughput: 2,987,500 gallon/yrGallons Ethanol Produced per Bushel of Corn: 2.67 gallon/buAdditional Grain Required for Ethanol: 0 bu/yrGrain Density: 56 lb/bushelTotal Increase Grain Throughput: 0 ton/yr

Total Increase Grain Throughput: 0.0 ton/hrPercent Grain Throughput that becomes DDGS 27.8%Total Increase DDGS Produced: 0.0 ton/yrTotal Grain Throughput: 642,710 ton/yrGrain Required for Ethanol: 21,100,000 bu/yrDDGS Produced: 192,394.0 ton/yrTruck Count - Road CalcsDDGS Haul Out 7,696 Trucks/yrEthanol Haul Out 7,842 Trucks/yrDenaturant Delivery 373 Trucks/yrGrain Delivery 25,708 Trucks/yrCorn Oil 450 Trucks/yr Based on information provided

No changes to grain handling equipment

Emission Calculations.xlsx Page 1 of 52 3/22/2016

Northstar Ethanol, LLC d/b/a POET Biorefining - Lake CrystalLake Crystal, MinnesotaList of Emission Sources

Emission Unit Stack/Vent Control Equipment Description Capacity Pollutants Control EquipmentEU001 SV001 CE001 Corn Receiving Pit 840 ton/hr TSP/PM10/PM2.5 Fabric FilterEU002 SV001 CE001 DDGS Loadout 200 ton/hr TSP/PM10/PM2.5 Fabric FilterEU003 SV001 CE001 Corn Bin Loading 840 ton/hr TSP/PM10/PM2.5 Fabric FilterEU004 SV001 CE001 Corn Elevator 840 ton/hr TSP/PM10/PM2.5 Fabric FilterEU005 SV001 CE001 Corn Conveyor 840 ton/hr TSP/PM10/PM2.5 Fabric FilterEU006 SV001 CE001 Corn Bin #1 840 ton/hr TSP/PM10/PM2.5 Fabric FilterEU007 SV001 CE001 Corn Bin #2 840 ton/hr TSP/PM10/PM2.5 Fabric FilterEU008 SV001 CE001 Corn Bin #3 840 ton/hr TSP/PM10/PM2.5 Fabric FilterEU009 SV002 CE002 Corn Scalper 140 ton/hr TSP/PM10/PM2.5 Fabric FilterEU010 SV002 CE002 Surge Bin 140 ton/hr TSP/PM10/PM2.5 Fabric FilterEU011 SV002 CE002 Elevator 140 ton/hr TSP/PM10/PM2.5 Fabric FilterEU012 SV002 CE002 Corn Conveyor Belt 140 ton/hr TSP/PM10/PM2.5 Fabric FilterEU013 SV003 CE003 Hammermill 1 24 ton/hr TSP/PM10/PM2.5 Fabric FilterEU014 SV004 CE004 Hammermill 2 24 ton/hr TSP/PM10/PM2.5 Fabric FilterEU015 SV005 CE005 Hammermill 3 24 ton/hr TSP/PM10/PM2.5 Fabric FilterEU053 SV017 CE015 Hammermill 4 24 ton/hr TSP/PM10/PM2.5 Fabric FilterEU016 SV006 CE006 Pneumatic Flour Convey96 ton/hr TSP/PM10/PM2.5 Fabric Filter

SV007 CE007

Bypass Stack:Fermentation (5 Fermenters @ 570,000 gallons each), 2 Beer 42000 gals. per hour (beer) TSP/PM10/PM2.5

EU017 SV007,008 CE007, 008 Fermenter #1 570,000 g VOC, HAP Wet Scrubber, Cyclone, RTOEU018 SV007,008 CE007, 008 Fermenter #2 570,000 g VOC, HAP Wet Scrubber, Cyclone, RTOEU019 SV007,008 CE007, 008 Fermenter #3 570,000 g VOC, HAP Wet Scrubber, Cyclone, RTOEU020 SV007,008 CE007, 008 Fermenter #4 570,000 g VOC, HAP Wet Scrubber, Cyclone, RTOEU055 SV007,008 CE007, 008 Fermenter #5 570,000 g VOC, HAP Wet Scrubber, Cyclone, RTOEU021 SV007,008 CE007, 008 Beer Well 685,000 gallo VOC, HAP Wet Scrubber, Cyclone, RTOEU022 SV007,008 CE007, 008 Beer Well 685,000 gallo VOC, HAP Wet Scrubber, RTOEU023 SV007,008 CE007, 008 Liquefaction Tank #1 VOC, HAP Wet Scrubber, RTOEU024 SV007,008 CE007, 008 Liquefaction Tank #2 VOC, HAP Wet Scrubber, RTOEU025 SV007,008 CE007, 008 Liquefaction Tank #3 VOC, HAP Wet Scrubber, RTOEU026 SV007,008 CE007, 008 One (1) slurry tank VOC, HAP Wet Scrubber, RTOEU027 SV007,008 CE007, 008 Yeast Propagation Tank VOC, HAP Wet Scrubber, RTOEU028 SV007,008 CE007, 008 Thin Stillage Tank VOC, HAP Wet Scrubber, RTOEU029 SV007,008 CE007, 008 Syrup Tank VOC, HAP Wet Scrubber, RTOEU030 SV007,008 CE007, 008 Beer Stripper VOC, HAP Wet Scrubber, RTOEU031 SV007,008 CE007, 008 Rectifier Column VOC, HAP Wet Scrubber, RTOEU032 SV007,008 CE007, 008 Side Stripper VOC, HAP Wet Scrubber, RTOEU033 SV007,008 CE007, 008 One (1) Set of Evaporat VOC, HAP Wet Scrubber, RTOEU034 SV007,008 CE007, 008 One (1) Set of Three (3) VOC, HAP Wet Scrubber, RTOEU035-039 0 CE008 One (1) Set of Five (5) C VOC, HAP Wet Scrubber, RTOEU040 SV008 CE009, CE008 DDGS Dryer #1 60 ton/hr feed TSP, PM10, PM2.5, NOx, SOx, VOC, HAP Multiclone and RTOEU041 SV008 CE010, CE008 DDGS Dryer #2 60 ton/hr feed TSP, PM10, PM2.5, NOx, SOx, VOC, HAP Multiclone and RTOEU042 SV008 RTO 30 MMBtu/hr TSP, PM10, PM2.5, NOx, SOx, VOC, HAPEU043 SV008, 014 CE011, CE008 DDG Fluid Bed Cooler 23 Tons per hour TSP, PM10, PM2.5, NOx, SOx, VOC, HAP Fabric FilterEU046 SV011 Auxiliary Boiler #1 100 MMBtu/Hr TSP, PM10, PM2.5, NOx, SOx, VOC, HAP Low NOx BurnerEU054 SV018 Auxiliary Boiler #2 100 MMBtu/Hr TSP, PM10, PM2.5, NOx, SOx, VOC, HAP Low NOx BurnerEU044 SV009 CE012 DDGS Storage Silo #1 23 ton/hr TSP/PM10 Fabric FilterEU045 SV010 CE013 DDGS Silo Bypass 23 ton/hr TSP/PM10 Fabric FilterEU048 SV012 CE014 Truck and Rail Loading 3000 gpm TSP, PM10, PM2.5, NOx, SOx, VOC, HAP Flare EU049 SV016 Diesel Generator #1 2000 KW TSP, PM10, PM2.5, NOx, SOx, VOC, HAP NoneEU050 SV016 Diesel Generator #2 2000 KW TSP, PM10, PM2.5, NOx, SOx, VOC, HAP NoneEU051 SV016 Diesel Generator #3 2000 KW TSP, PM10, PM2.5, NOx, SOx, VOC, HAP NoneEU052 Diesel Generator #4 (Not InstalledEU056 SV001 CE001 Corn Bin 840 ton/hr TSP/PM10/PM2.5 Fabric FilterEU057 SV001 CE001 Corn Bin 840 ton/hr TSP/PM10/PM2.5 Fabric FilterEU058 SV001 CE001 Corn Bin 840 ton/hr TSP/PM10/PM2.5 Fabric FilterEU059 SV001 CE001 Corn Bin 840 ton/hr TSP/PM10/PM2.5 Fabric FilterEU060 SV001 CE001 Belt Conveyor 840 ton/hr TSP/PM10/PM2.5 Fabric FilterEU061 SV001 CE001 Belt Conveyor 840 ton/hr TSP/PM10/PM2.5 Fabric FilterEU062 SV001 CE001 Belt Conveyor 140 ton/hr TSP/PM10/PM2.5 Fabric FilterTK001 190 Proof Ethanol Stora192,500 gallons VOC Internal Floating RoofTK002 200 Proof Ethanol Stora192,500 gallons VOC Internal Floating RoofTK003 Denaturant Storage Tan65,000 gallons VOC, HAP Internal Floating RoofTK004 Denatured Ethanol Stora2,000,000 gallons VOC, HAP Internal Floating RoofTK005 Denatured Ethanol Stora2,000,000 gallons VOC, HAP Internal Floating Roof

Fugitive Source DescriptionFS001 Truck Traffic - Unpaved NA TSP/PM10/PM2.5 NoneFS002 Grain Receiving/DDGS 840 ton/hr TSP/PM10/PM2.5 NoneFS003 Equipment leaks NA VOC, HAP Leak Detection and Repair ProgramFS004 Cooling Towers 18,500 gpm TSP/PM10/PM2.5 High Efficiency Mist Eliminators

42000 gals. per hour (beer)

42000 gals. per hour (beer)


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3of

523/

22/2

016

Fac

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0.37

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0.36

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1.5E

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1.5E

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4of

523/

22/2

016

Fac

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AQ

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ID N

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099

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Calc

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.xlsx

5of

523/

22/2

016

Fac

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Calc

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6of

523/

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l74

40-0

2-0

-

-

-

-

-

-

-

-

-

-

-

-

Pro

pion

alde

hyd

e12

3-38

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-

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-

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-

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-

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S

elen

ium

7782

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2-

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T

olue

ne10

8-88

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X

ylen

es13

30-2

0-7

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Emiss

ion

Calc

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ions

.xlsx

7of

523/

22/2

016

No

rth

star

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ano

l, L

LC

d/b

/a P

OE

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e C

ryst

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inn

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taP

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lium

7440

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7440

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mal

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0-54

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AM

anga

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7439

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7-6

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7440

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38-6

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m77

82-4

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108-

88-3

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enes

1330

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7T

ota

l HA

P

ST

RU

13S

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RU

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-

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6.

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3.13

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4.

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5.

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41.

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-

-

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-

-

-

-

-

-

0.

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4.

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Ham

mer

mill

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Pne

umat

ic F

lour

Con

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r/R

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RT

O B

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s S

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S

Emiss

ion

Calc

ulat

ions

.xlsx

8of

523/

22/2

016

No

rth

star

Eth

ano

l, L

LC

d/b

/a P

OE

Lak

e C

ryst

al, M

inn

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taP

ote

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Em

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7440

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lium

7440

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7440

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n D

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75-1

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Chr

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Cob

alt

7440

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e98

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8E

thyl

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ene

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For

mal

dehy

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0H

exan

e11

0-54

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AM

anga

nese

7439

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5M

ercu

ry74

39-9

7-6

Met

hano

l67

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1N

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ne

91-2

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Nic

kel

7440

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0P

ropi

onal

dehy

de

123-

38-6

Sel

eniu

m77

82-4

9-2

Tol

uene

108-

88-3

Xyl

enes

1330

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7T

ota

l HA

P

ST

RU

16S

V8

AO

SS

TR

U19

ST

RU

25S

TR

U22

lb/h

rU

nc

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Lim

tp

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c tp

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py

lb/h

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tp

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Un

c tp

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im t

py

lb/h

rU

nc

tpy

Lim

tp

y5.

89E

-01

4.42

E+

012.

34E

+00

0.62

52

0.

6252

0.03

13

0.

000E

+00

0.00

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000.

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0.00

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000.

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0.00

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003.

931E

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1.72

2E+

009.

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1.43

E-0

11.

07E

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5.69

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10.

0000

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00

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0.00

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0.00

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000E

+00

9.82

8E-0

24.

305E

-01

2.45

7E-0

22.

86E

-05

1.25

E-0

41.

25E

-04

-

-

-

1.90

5E-0

58.

343E

-05

8.34

3E-0

51.

905E

-05

8.34

3E-0

58.

343E

-05

0.00

0E+

000.

000E

+00

0.00

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007.

20E

-05

1.31

E-0

33.

15E

-04

-

-

-

2.00

0E-0

48.

760E

-04

8.76

0E-0

42.

000E

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8.76

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48.

760E

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000.

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0.00

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000.

00E

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0.00

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00E

+00

-

-

-

1.14

3E-0

65.

006E

-06

5.00

6E-0

61.

143E

-06

5.00

6E-0

65.

006E

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0.00

0E+

000.

000E

+00

0.00

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001.

57E

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6.88

E-0

46.

88E

-04

-

-

-

1.04

8E-0

44.

589E

-04

4.58

9E-0

41.

048E

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4.58

9E-0

44.

589E

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0.00

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0.00

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000.

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-

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0.00

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000.

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0.00

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002.

00E

-04

8.76

E-0

48.

76E

-04

-

-

-

1.33

3E-0

45.

840E

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5.84

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41.

333E

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5.84

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45.

840E

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0.00

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001.

20E

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5.26

E-0

55.

26E

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-

-

-

8.00

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63.

504E

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3.50

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58.

000E

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53.

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0.00

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05E

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011.

21E

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0.00

01

0.

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00

7.

143E

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3.12

9E-0

23.

129E

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7.14

3E-0

33.

129E

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3.12

9E-0

25.

078E

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2.22

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001.

270E

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6.17

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21.

13E

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2.70

E-0

1-

-

-

1.

714E

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7.50

9E-0

17.

509E

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1.71

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17.

509E

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7.50

9E-0

10.

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0.00

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7.14

E-0

53.

13E

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3.13

E-0

4-

-

-

4.

762E

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2.08

6E-0

42.

086E

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4.76

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52.

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2.08

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40.

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0.00

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5.43

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52.

38E

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2.38

E-0

4-

-

-

3.

619E

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1.58

5E-0

41.

585E

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3.61

9E-0

51.

585E

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1.58

5E-0

40.

000E

+00

0.00

0E+

000.

000E

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3.71

E-0

51.

63E

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1.63

E-0

4-

-

-

2.

476E

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1.08

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41.

085E

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2.47

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51.

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40.

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0.00

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4.20

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1.67

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11.

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9.00

9E-0

22.

09E

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3.82

E-0

49.

16E

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-

-

-

5.81

0E-0

52.

545E

-04

2.54

5E-0

45.

810E

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2.54

5E-0

42.

545E

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0.00

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1.31

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31.

31E

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-

-

2.00

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48.

760E

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8.76

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42.

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8.76

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000.

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+00

0.00

0E+

003.

57E

-06

1.56

E-0

51.

56E

-05

-

-

-

2.38

1E-0

61.

043E

-05

1.04

3E-0

52.

381E

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1.04

3E-0

51.

043E

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0.00

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000.

000E

+00

0.00

0E+

001.

17E

-04

2.13

E-0

35.

11E

-04

-

-

-

3.23

8E-0

41.

418E

-03

1.41

8E-0

33.

238E

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1.41

8E-0

31.

418E

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000.

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0.00

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0.00

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14

81.9

7

4.

57

0.63

0.

63

0.

03

0.18

0.

79

0.79

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0.

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1.36

5.

96

0.34

RT

OS

crub

ber

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ass

AO

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r #1

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DG

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id B

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s

Emiss

ion

Calc

ulat

ions

.xlsx

9of

523/

22/2

016

No

rth

star

Eth

ano

l, L

LC

d/b

/a P

OE

Lak

e C

ryst

al, M

inn

eso

taP

ote

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al H

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Em

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on

Su

mm

ary

HA

P N

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CA

S #

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e75

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crol

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7440

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2B

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ne71

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2B

eryl

lium

7440

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7C

adm

ium

7440

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7C

arbo

n D

isul

fide

75-1

5-0

Chr

omiu

m74

40-4

7-3

Cob

alt

7440

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4C

umen

e98

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8E

thyl

benz

ene

100-

41-4

For

mal

dehy

de50

-00-

0H

exan

e11

0-54

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adN

AM

anga

nese

7439

-96-

5M

ercu

ry74

39-9

7-6

Met

hano

l67

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1N

apht

hale

ne

91-2

0-3

Nic

kel

7440

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0P

ropi

onal

dehy

de

123-

38-6

Sel

eniu

m77

82-4

9-2

Tol

uene

108-

88-3

Xyl

enes

1330

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7T

ota

l HA

P

ST

RU

17S

TR

U18

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RU

20E

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lb/h

rU

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Lim

tp

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tp

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c tp

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-

-

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-

-

-

-

-

-

1.

47E

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6.45

E-0

31.

03E

-04

-

-

-

-

-

-

-

-

-

4.

62E

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2.02

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33.

23E

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-

-

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-

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-

-

-

0.

00E

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0.00

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00E

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-

-

-

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-

-

8.92

E-0

33.

98E

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3.91

E-0

24.

54E

-02

1.99

E-0

13.

18E

-03

-

-

-

-

-

-

-

-

-

0.

00E

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0.00

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-

-

-

-

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-

-

-

-

0.

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0.00

E+

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+00

-

-

-

-

-

-

7.14

E-0

53.

19E

-03

3.13

E-0

40.

00E

+00

0.00

E+

000.

00E

+00

-

-

-

-

-

-

-

-

-

0.

00E

+00

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Lake Crystal, MinnesotaParticulate Matter (PM / PM10 / PM2.5) Point Source Emission Calculations

Ec lb/hr = G gr/dscf x 1 lb / 7000 gr x Q dscfm x 60 minutes / hour

Q = Annual Throughput

Qcorn = 642,710 tons/year 160,678 tons/year/hammermillQddgs = 192,394 tons/year

SV 001Corn Receiving PitGiven:Capacity = 840 ton/hr corn receiving, conveying, storage bins, elevatorCapacity = 200 ton/hr DDGS Loadout

Uncontrolled Emission Factors PM lb/ton PM10 lb/ton PM2.5 lb/ton0.18 0.059 0.01

0.061 0.034 0.00580.025 0.0063 0.00110.086 0.029 0.0049

Uncontrolled Emissionslb/hr ton/year

TSP 240.64 93.75

PM10 89.21 34.70

PM2.5 15.18 5.90

All point source emissions from these emission units will be controlled by a fabric filter.Control

EfficiencyMaximum controlled TSP/PM10 emission rate = 0.005 gr/dscfExhaust Flow Rate = 23,000 dscfmControlled TSP Hourly Potential to Emit 0.99 lb/hr 99.6%Controlled TSP Annual Potential to Emit 4.32 ton/yearControlled PM10 Hourly Potential to Emit 0.99 lb/hr 98.9%Controlled PM10 Annual Potential to Emit 4.32 ton/year

Maximum controlled PM2.5 emission rate = 17.00%Controlled PM2.5 Hourly Potential to Emit 0.17 lb/hr 98.9%Controlled PM2.5 Annual Potential to Emit 0.73 ton/year

DDGS Loadout Straight Truck AP42 Table 9.9.1-1, March 2003

of PM10 emission rate per AP-42 Table 9.9.1-1 Reference 40

Corn Bins AP42 Table 9.9.1-1, March 2003

The potential to emit from these sources will not changes as a result of this project. The actual emissions will increase by theratio of past to future grain throughput.

The following calculations are for the emissions of total suspended particulate (TSP), particulate matter less than 10 micron (PM10) and particulate matter less than 2.5 micron (PM2.5) from point sources at the proposed ethanol facility. For the purposes of these calculations, TSP and PM10 were assumed to be equal. Per AP-42, PM2.5 was assumed to be 17% of PM10.

The controlled potential TSP/PM10 emissions were calculated by multiplying the design grain loading from the fabric filter by the design flow rate for the source and converting to a pound per hour emission rate. The equation for the calculations is:

Where:E = Emission rate of TSP/PM10 in lb/hrG = Outlet Grain Loading in grain per dry standard cubic foot of airQ = Flow Rate in dry standard cubic feet per minute

The uncontrolled potential emission were calculated by multiplying the AP-42 emission factor by the annual throughput in tons/year. The equation for the uncontrolled emission rate is:

Eu lb/hr = Ef * QWhere:Eu = Uncontrolled Emission rate in ton/yrEf = AP-42 Emission Factor

SourceReceiving Pit Straight Truck AP42 Table 9.9.1-1, March 2003Corn Conveyor AP42 Table 9.9.1-1, March 2003

Emission Calculations.xlsx 13 of 52 3/22/2016



SV 002Corn ScalperGiven:Capacity = 140 ton/hr

Uncontrolled Emission Factors PM lb/ton PM10 lb/ton PM2.5 lb/tonCapture Efficiency

0.061 0.034 0.0058 100%0.075 0.019 0.0032 100%0.025 0.0063 0.0011 100%


TSP 22.54 51.74PM10 8.30 19.06PM2.5 1.41 3.25




SV 003Hammermill 1Given:Capacity = 24 ton/hr


TSP 41.14 180.21PM10 5.88 25.74PM2.5 1.00 4.38




Scalper AP42 Table 9.9.1-1, March 2003

Surge Bin AP42 Table 9.9.1-1, March 2003


Note: Uncontrolled emissions were calculated using the controlled emission rate divided by the control efficiency from Minnesota Rule 7011.0070.


Corn Conveyor AP42 Table 9.9.1-1, March 2003




STRU 12Hammermill 2Given:Capacity = 24 ton/hr


TSP 41.14 180.21PM10 5.88 25.74PM2.5 1.00 4.38






TSP 41.14 180.21PM10 5.88 25.74PM2.5 1.00 4.38











STRU 14Pneumatic Flour Conveyor/ReceiverGiven:Capacity = 96 ton/hr


TSP 18.43 80.72PM10 2.63 11.53PM2.5 0.45 1.96




STRU 17DDGS Storage Silo #1Given:Capacity = 23 ton/hr

PM lb/ton PM10 lb/ton PM2.5 lb/tonDDGS Storage Silo 0.086 0.029 0.0049


TSP 1.98 8.27PM10 0.67 2.79PM2.5 0.11 0.47





Uncontrolled Emission FactorsAP42 Table 9.9.1-1, March 2003






STRU 18DDGS Silo BypassGiven:Capacity = 23 ton/hr

PM lb/ton PM10 lb/ton PM2.5 lb/tonDDGS Storage Silo 0.086 0.029 0.0049


TSP 1.98 8.27PM10 0.67 2.79PM2.5 0.11 0.47






TSP 41.14 180.21PM10 5.88 25.74PM2.5 1.00 4.38




AP42 Table 9.9.1-1, March 2003

of PM10 emission rate per AP-42 Table 9.9.1-1



Uncontrolled Emission Factors


Northstar Ethanol, LLC d/b/a POET Biorefining - Lake CrystalLake Crystal, MinnesotaSV007 Emission Calculations for RTO Bypass

Existing Production

Scrubber VOC Control Efficiency = 95.00%Scrubber HAP Control Efficiency = 50.00%Yearly operation limit= 500 hours

lb/hr ton/yrVOC 472.00 118.0Acetaldehyde 9.16 2.290Acrolein 0.001 0.000Methanol 0.001 0.000Formaldehyde 0.001 0.000Total Uncontrolled HAP 9.2 2.291

lb/hr ton/yrVOC 23.6 5.90 Permit LimitAcetaldehyde 4.58 1.15Acrolein 0.0003 0.00Methanol 0.0004 0.00Formaldehyde 0.0004 0.00Total Controlled HAP 4.6 1.1453

Proposed Emissions with Beer Feed Rate Increase

Scrubber VOC Control Efficiency = 95.00%Scrubber HAP Control Efficiency = 50.00%Yearly operation limit= 500 hours

lb/hr ton/yrVOC 580.00 145.00Acetaldehyde 12.50 3.13Acrolein 0.00 0.000Methanol 0.00 0.000Formaldehyde 0.00 0.000Total Uncontrolled HAP 12.51 3.13

lb/hr ton/yrVOC 29.00 7.25 Note 1Acetaldehyde 6.25 1.56 Note 2Acrolein 0.0004 0.00 Note 2Methanol 0.0004 0.00 Note 2Formaldehyde 0.0005 0.00 Note 2Total Controlled HAP 6.25 1.56 Note 2

Note 1

Note 2

Change in EmissionsPollutant lb/hr ton/yearVOC 5.40 1.35Acetaldehy 1.67 0.42Acrolein 0.00 0.00Methanol 0.00 0.00Formaldehy 0.00 0.00HAPs 1.67 0.42

Uncontrolled by both

Controlled by Scrubber, no RTO

The proposed controlled lb/hr emission rate was based on Stack Test Data from 2015 increased by the ratio of the proposed increase in beer feed rate ((700-641)/641) plus a 25% safety factor.

The proposed controlled lb/hr HAP emission rate was increased by the ratio of the proposed increase in beer feed rate ((700-641)/641) plus a 25% safety factor.

The RTO must occasionally be temporarily shut down for unscheduled maintenance or other operational reasons. In this event, the DDGS dryers will be shut down, however, the fermentation tanks and distillation systems will continue to be operated in normal mode. This operating scenario will be limited to less than 500 hours per calendar year. The emissions from these sources will be vented to a bypass stack. The emissions will be controlled by the wet scrubber.The VOC and HAP emission factors as well as the control efficiencies from the scrubber are based on performance tests at similar facilities.

Uncontrolled

Controlled by scrubber, no RTO

RTO Bypass permit limits increased based on increase in beer feed rate.


Northstar Ethanol, LLC d/b/a POET Biorefining - Lake CrystalLake Crystal, MinnesotaSV008 Potential Emissions from the Fermenters, Distillation System, DDGS Coolers and DDGS Dryers - Change

Given:Emission Factors for Fuel CombustionAP-42 emission factors from Section 1.4 were converted to lb/MMBtu assuming a heating value of 1050 Btu/ft3 for natural gas.Pollutant lb/MMBTU SourceNOx 0.040 Stack TestsCO 0.082 AP-42 Section 1.4TSP 0.007 AP-42 Section 1.4VOC 0.005 AP-42 Section 1.4SO2 0.0006 AP-42 Section 1.4

Therefore, the dryer combustion emissions are:

#1 and #2 Dryer= 60 MMBtu/hr eachPollutant lb/hr ton/yearNOx 4.80 21.0CO 9.88 43.3TSP 0.89 3.9VOC 0.65 2.8SO2 0.07 0.3

Given:Emission Factors for Fuel Combustion

AP-42 emission factors from Section 1.4 were converted to lb/MMBtu assuming a heating value of 1050 Btu/ft3 for natural gas.Pollutant lb/MMBTU SourceNOx 0.040 Mfg. GuaranteeCO 0.082 AP-42 Section 1.4TSP 0.007 AP-42 Section 1.4VOC 0.005 AP-42 Section 1.4SO2 0.0006 AP-42 Section 1.4

Therefore, RTO combustion emissions are:RTO Burners = 30 MMBtu/hr each

Total TotalPollutant lb/hr ton/yearNOx 1.20 5.3CO 2.47 10.8TSP 0.22 1.0VOC 0.16 0.7SO2 0.02 0.08

The annual potential to emit from the RTO will not change as a result of this project since the annual production limit will not be changed. The lb/hour emission limit will increase due to the increase in beer feed rate.

SV008 includes the emissions from its fermentation system, distillation system, DDGS Coolers and the DDGS dryers. The fermenters and distillation systems are sources of VOC and HAPs and are designated as SV007 when in bypass mode. The distillation system includes the beer wells, distillation columns, rectifiers, molecular sieves, and centrifuges. The dryers have natural gas fired burners and are sources of TSP, PM10, NOx, SOx, CO, VOC and HAPs. The emission units are vented to a regenerative thermal oxidizer (RTO). The RTO will control VOC HAPs, CO, and TSP emissions.

The RTO has been designed to achieve a minimum of 95.0% reduction in VOC and HAP emissions. Additionally, the RTO will achieve 90% reduction in TSP and CO emissions. The RTO control efficiencies are based on engineering estimates for TSP and performance tests for VOC, HAPs, and CO.

The DDGS dryers #1 and #2 have a 60 MMBtu/hr natural gas fired burners. The dryers do not have the capacity to combust any other fuel. The dryers are connected in series, therefore, all of the DDGS from each production line is processed by the two dryers in series.

The RTO is equipped with 5 natural gas fired burners rated at 6 MMBTU/hr each. The RTO is not equipped with burners to combust any other fuel.




Process Emissions from the Dryers

Calculate the Process related TSP/PM10 Emissions from the RTO

Given:Dryer Feed Rate = 60.0 ton/hr

50,000 dscfm0.1 gr/dscf

42.9 lb/hr187.7 tons/year

Controlled Emission Rate = 5.0 lb/hr21.9 ton/yr

33.28 lb/hr

Total Processing Systems VOC and HAP Emissions from RTO

Assumptions for DDGS dryers:- All VOCs in the water of the Wet Distillers Grains (WDGs) fed to the dryers are all released within the dryer.- Average 0.0055 lbs of VOCs per lb of water to dryer (0.2%).- Maximum total flow (solids + water) is 120,000 lbs/hr.- 65% of the inlet weight to the dryer is water.- Maximum HAPs vented to RTO (based on stack tests and estimates) 15 lbs/hour - Maximum CO vented to RTO equals 150.0 lbs/hour (based on stack tests and estimates)

Water to dryers = 78000.0 lbs/hrVOCs to dryers = 176.8 lbs/hr 774.4 TPY

VOCs evaporated from Centrifuges = 0.1 lbs/hr 0.4 TPY

Assumptions for fermentation/distillation:- Maximum VOCs vented to RTO = 20 lb/hr

5 lb/hr

Assuming 95% control for VOCs and HAPs:

Estimated VOC emissions: 8.84 Lbs/hr 38.72 TPYEstimated HAP emissions: 1.00 Lbs/hr 4.38 TPY

HAP emissions are based on stack test results from similar facilities.The uncontrolled potential emission were calculated by dividing the controlled potential emission rate by the assumed control efficiency of the RTO.

Therefore, the RTO HAP emissions are:

Uncontrolled Emission Rate

Uncontrolled Emission Rate

Control Efficiency

Controlled Emission Rate

Controlled Emission Rate

lb/hr ton/year % lb/hr ton/yearAcetaldehyde 10.7 44.2 95% 0.54 2.2Acrolein 2.6 10.7 95% 0.13 0.5Methanol 0.8 3.2 95% 0.04 0.2Formaldehyde 5.5 22.7 95% 0.27 1.1Total HAP 19.6 80.8 95% 1.0 4.0

Calculate the Total Controlled Emissions from the RTO StackThe emission rates for VOC and TSP from the RTO stack assume the products of combustion are not further reduced by the RTO.

Pollutant lb/hr Uncontrolled ton/yearLimitedton/year

NOx 11.0 48.18 48.1800 Permit LimitCO 10.0 43.80 43.8000 Permit LimitTSP/PM10/PM2.5 8.0 187.71 35.0400 Permit LimitVOC 9.0 778.34 39.4200 Permit LimitSO2 0.16 0.70 0.6956Acetaldehyde 0.54 44.22 2.3448Acrolein 0.13 10.74 0.5694Methanol 0.04 3.16 0.1674Formaldehyde 0.27 22.68 1.2025Total HAPs 0.98 80.8 4.2841

Proposed Emissions with Beer Feed Rate Increase

RTO Exhaust Flow Rate =Uncontrolled emission rate =

Allowable Emission Rate per Mn Rule 7011.0730, Table 1

Existing Production

- Maximum HAPs vented to RTO (based on stack tests and estimates)=

The DDGS from the centrifuges that is fed into the dryers contains water, some ethanol, methanol, and acetaldehyde. The majority of the water and VOCs are evaporated from the DDGS in the dryers. The drying process for the DDGS also produces some CO and TSP.

The exhaust is vented to the RTO where the VOCs, HAPs, CO, and TSP are thermally oxidized. The RTO has been designed to achieve a minimum of 95.0% reduction in VOC and HAP emissions. Additionally, the RTO will achieve 90% reduction in TSP and CO emissions. The emission factors for the dryers are based on an engineering estimate for TSP and stack test results for similar facilities for VOC.




Updated Total Controlled Emissions from the RTO StackThe emission rates for VOC and TSP from the RTO stack assume the products of combustion are not further reduced by the RTO.

Pollutant lb/hr Uncontrolled ton/yearLimitedton/year

NOx 11.0 48.18 48.1800 Permit LimitCO 10.0 43.80 43.8000 Permit Limit

TSP/PM10/PM2.5 8.0 187.71 35.0400 Permit LimitVOC 9.9 778.34 43.3620SO2 0.16 0.70 0.6956Acetaldehyde 0.59 44.22 2.3448Acrolein 0.14 10.74 0.5694Methanol 0.04 3.16 0.1674Formaldehyde 0.30 22.68 1.2025Total HAPs 1.08 80.8 4.2841

Pollutant lb/hr ton/yearNOx 0.00 0.000CO 0.00 0.000TSP/PM10/PM2.5 0.00 0.000VOC 0.90 3.942SO2 0.00 0.000Acetaldehyde 0.05 0.000Acrolein 0.01 0.000Methanol 0.00 0.000Formaldehyde 0.03 0.000Total HAPs 0.10 0.000

Change in Emissions

RTO permit limits increased based on increase in beer feed rates


Northstar Ethanol, LLC d/b/a POET Biorefining - Lake CrystalLake Crystal, MinnesotaSV008 HAP Emissions from Natural Gas Combustion

Emission

Factor 1

HAP Pollutant (lb/MMSCF) (lb/hr) (ton/yr) (lb/hr) (ton/yr) (lb/hr) (ton/yr) (lb/hr) (ton/yr)Benzene 0.00210 2.40E-04 1.05E-03 1.20E-05 5.26E-05 0.0001 0.0005 0.0000 0.0000Formaldehyde 0.07500 8.57E-03 3.75E-02 4.29E-04 1.88E-03 0.0043 0.0188 0.0002 0.0009Hexane 1.80000 2.06E-01 9.01E-01 1.03E-02 4.51E-02 0.1029 0.4505 0.0051 0.0225Naphthalene 0.00061 6.97E-05 3.05E-04 3.49E-06 1.53E-05 0.0000 0.0002 0.0000 0.0000Toluene 0.00340 3.89E-04 1.70E-03 1.94E-05 8.51E-05 0.0002 0.0009 0.0000 0.0000Arsenic 0.00020 2.29E-05 1.00E-04 2.29E-05 1.00E-04 0.0000 0.0001 0.0000 0.0001Berylium 0.00001 1.37E-06 6.01E-06 1.37E-06 6.01E-06 0.0000 0.0000 0.0000 0.0000Cadmium 0.00110 1.26E-04 5.51E-04 1.26E-04 5.51E-04 0.0001 0.0003 0.0001 0.0003Chromium 0.00140 1.60E-04 7.01E-04 1.60E-04 7.01E-04 0.0001 0.0004 0.0001 0.0004Cobalt 0.00008 9.60E-06 4.20E-05 9.60E-06 4.20E-05 0.0000 0.0000 0.0000 0.0000Lead 0.00050 5.71E-05 2.50E-04 5.71E-05 2.50E-04 0.0000 0.0001 0.0000 0.0001Manganese 0.00038 4.34E-05 1.90E-04 4.34E-05 1.90E-04 0.0000 0.0001 0.0000 0.0001Mercury 0.00026 2.97E-05 1.30E-04 2.97E-05 1.30E-04 0.0000 0.0001 0.0000 0.0001Nickel 0.00210 2.40E-04 1.05E-03 2.40E-04 1.05E-03 0.0001 0.0005 0.0001 0.0005Selenium 0.00003 2.86E-06 1.25E-05 2.86E-06 1.25E-05 0.0000 0.0000 0.0000 0.0000

0.216 0.945 0.011 0.050 0.108 0.472 0.006 0.0251 - Emission factor is from AP-42, 5th Edition, Section 1.4, 7/98

Emission

Factor 1

HAP Pollutant (lb/MMSCF) (lb/hr) (ton/yr)Benzene 0.00210 6.00E-05 2.63E-04Formaldehyde 0.07500 2.14E-03 9.39E-03Hexane 1.80000 5.14E-02 2.25E-01Naphthalene 0.00061 1.74E-05 7.63E-05Toluene 0.00340 9.71E-05 4.25E-04Arsenic 0.00020 5.71E-06 2.50E-05Berylium 0.00001 3.43E-07 1.50E-06Cadmium 0.00110 3.14E-05 1.38E-04Chromium 0.00140 4.00E-05 1.75E-04Cobalt 0.00008 2.40E-06 1.05E-05Lead 0.00050 1.43E-05 6.26E-05Manganese 0.00038 1.09E-05 4.76E-05Mercury 0.00026 7.43E-06 3.25E-05Nickel 0.00210 6.00E-05 2.63E-04Selenium 0.00003 7.14E-07 3.13E-06

0.054 0.2361 - Emission factor is from AP-42, 5th Edition, Section 1.4, 7/98

Total HAPs

HAP Pollutant (lb/hr) (ton/yr) (lb/hr) (ton/yr)Benzene 71-43-2 7.20E-05 3.15E-04 3.00E-04 1.31E-03Formaldehyde 50-00-0 2.57E-03 1.13E-02 1.07E-02 4.69E-02Hexane 110-54-3 6.17E-02 2.70E-01 2.57E-01 1.13E+00Naphthalene 91-20-3 2.09E-05 9.16E-05 8.71E-05 3.82E-04Toluene 108-88-3 1.17E-04 5.11E-04 4.86E-04 2.13E-03Arsenic 7440-38-2 2.86E-05 1.25E-04 2.86E-05 1.25E-04Berylium 7440-41-7 1.71E-06 7.51E-06 1.71E-06 7.51E-06Cadmium 7440-43-7 1.57E-04 6.88E-04 1.57E-04 6.88E-04Chromium 7440-47-3 2.00E-04 8.76E-04 2.00E-04 8.76E-04Cobalt 7440-48-4 1.20E-05 5.26E-05 1.20E-05 5.26E-05Lead NA 7.14E-05 3.13E-04 7.14E-05 3.13E-04Manganese 7439-96-5 5.43E-05 2.38E-04 5.43E-05 2.38E-04Mercury 7439-97-6 3.71E-05 1.63E-04 3.71E-05 1.63E-04Nickel 7440-02-0 3.00E-04 1.31E-03 3.00E-04 1.31E-03Selenium 7782-49-2 3.57E-06 1.56E-05 3.57E-06 1.56E-05

0.065 0.286 0.270 1.1811 - Emission factor is from AP-42, 5th Edition, Section 1.4, 7/98

The facility operates an RTO to control emissions from the fermentation and distillation systems, and the DDG driers. The RTO is equipped with natural gas fired burners totaling 30 MMBTU/hr.

Potential to Emit Emissions

CAS #

Limited Potential to Emit Emissions

Uncontrolled Potential to Emit Emissions

The facility operates two DDGS driers. Each drier will be 60 MMBtu/hr and be fired on natural gas. There is no back-up fuel. The drier exhaust is directed to the RTO at all times when the driers are operated. The RTO has an estimated volatile HAP control efficiency of 95%.

For One Drier


(Uncontrolled)


(Controlled)


(Uncontrolled)Potential to Emit

Emissions (Controlled)


POET Biorefining- Lake CrystalLake Crystal, Minnesota

Scrubber Bypass Annual Operating Time100 hr/yr

Control Efficiencies RTO StackVOCs 95%HAPs 95%

Control Efficiencies ScrubberVOCs 95%HAPs 50%

lb/hr ton/yrVOC 580.00 29.00Acetaldehyde 75-07-0 12.50 0.63Acrolein 107-02-8 0.00 0.00Methanol 67-56-1 0.00 0.00Formaldehyde 50-00-0 0.00 0.00

12.51 0.63


0.63 0.03

SV008 Alternate Operating Scenario Emissions from the Fermenters, Distillation System, and DDGS Dryers during Fermentation ScrubBypass

The fermentation scrubber must occasionally be temporarily shut down for unscheduled maintenance or other operational reasthis event, the the fermentation tanks and distillation systems will continue to be operated in normal mode and the scrubber wilbypassed directly to the RTO. This alternate operating scenario will be limited to less than 100 hours per calendar year.

In this operating scenario, emissions from the fermentation and distillation systems will bypass the scrubber directly to the RTOthe VOCs, HAPs, CO, and TSP are thermally oxidized. The RTO has been designed to achieve a minimum of 95.0% reductioand HAP emissions.

Uncontrolled From Fermenters/Distillation System

Total Uncontrolled HAP

Controlled From Fermenters/Distillation System (controlled by RTO)

Total HAP


18.45 0.92


0.92 0.05


1.55 0.08

10 lb/hr

140%24.000 lb/hr 0.700

Total HAP

CO Emission Limit during Normal Operations

Projected Increase

Based on stack test resultsoperations to scrubber bypoperations, at POET BioreAlexandria (2/19/2015) andBiorefining - Portland (4/2/2

Proposed CO Emission Limit during Bypass

Total RTO Emission Rate During Scrubber Bypass

Uncontrolled from Dryers

Total Uncontrolled HAP

Controlled from Dryers (controlled by RTO)

Total HAP

Northstar Ethanol, LLC d/b/a POET Biorefining - Lake CrystalLake Crystal, MinnesotaSV011 and SV018 Boiler Calculations

TSP 0.0072 lb/MMbtu AP-42 Section 1.4PM10 0.0072 lb/MMbtu AP-42 Section 1.4PM2.5 0.0072 lb/MMbtu Assumed = PM10NOx 0.0363 lb/MMbtu Manufacturer GuaranteeSOx 0.0006 lb/MMbtu AP-42 Section 1.4VOC 0.0052 lb/MMbtu AP-42 Section 1.4CO 0.0800 lb/MMbtu AP-42 Section 1.4

Given:#1 & #2 Boiler Size= 100 MMBtu/hrLimited Fuel Use = 876000 MMBtu/yr per boiler

TSP PM10 PM2.5 NOx SOx VOC COlb/hr lb/hr lb/hr lb/hr lb/hr lb/hr lb/hr

Boiler #1 0.72 0.72 0.72 3.6 0.1 0.5 8.0Boiler #2 0.72 0.72 0.72 3.6 0.1 0.5 8.0Total 1.45 1.45 1.45 7.26 0.1 1.0 16.0

Potential Emissions

TSP PM10 PM2.5 NOx SOx VOC COton/year ton/year ton/year ton/year ton/year ton/year ton/year


Limited Emissions

TSP PM10 PM2.5 NOx SOx VOC COton/year ton/year ton/year ton/year ton/year ton/year ton/year


The facility has two 100 MMBtu/hr natural gas fired steam boilers. No backup fuel is capable of firing. Both boilers are subject to the provisions of the United Stated Environmental Protection Agency's (USEPA's) New Source Performance Standard (NSPS), Subpart Dc, Standard for Institutional, Commercial, and Industrial Steam Generating Units.

The boilers are equipped with low NOx burners.

The potential emissions for the boilers are calculated by multiplying an emission factor by the rated capacity of the boilers. AP-42 emission factors from Section 1.4 were converted to lb/MMBtu assuming a heating value of 1050 Btu/ft3 for natural gas. The emission factors are:

Limited emissions are calculated by by multiplying an emission factor by the above emission factor in lb/MMBtu.


Hazardous Air Pollutant Calculations

Emission Calculations PER Boiler

HAPCompound

EmissionFactor

Emission Rate #1 & #2 Boiler

(each)Total for Boilers

Potential to Emit each #1 and #2 Boiler

Total for Boilers

lb/MMSCF lb/hr lb/hr ton/year ton/yr

Benzene 0.0021 2.00E-04 4.00E-04 8.76E-04 1.75E-03Formaldehyde 0.075 7.14E-03 1.43E-02 3.13E-02 6.26E-02Hexane 1.8 1.71E-01 3.43E-01 7.51E-01 1.50E+00Naphthalene 0.00061 5.81E-05 1.16E-04 2.54E-04 5.09E-04Toluene 0.0034 3.24E-04 6.48E-04 1.42E-03 2.84E-03Arsenic 0.0002 1.90E-05 3.81E-05 8.34E-05 1.67E-04Beryllium 0.000012 1.14E-06 2.29E-06 5.01E-06 1.00E-05Cadmium 0.0011 1.05E-04 2.10E-04 4.59E-04 9.18E-04Chromium 0.0014 1.33E-04 2.67E-04 5.84E-04 1.17E-03Cobalt 0.000084 8.00E-06 1.60E-05 3.50E-05 7.01E-05Lead 0.0005 4.76E-05 9.52E-05 2.09E-04 4.17E-04Manganese 0.00038 3.62E-05 7.24E-05 1.59E-04 3.17E-04Mercury 0.00026 2.48E-05 4.95E-05 1.08E-04 2.17E-04Nickel 0.0021 2.00E-04 4.00E-04 8.76E-04 1.75E-03Selenium 0.000025 2.38E-06 4.76E-06 1.04E-05 2.09E-05

1.80E-01 3.59E-01 7.87E-01


Northstar Ethanol, LLC d/b/a POET Biorefining - Lake CrystalLake Crystal, MinnesotaSV014 Fluid Bed Cooler RTO Bypass Stack - Change

Before Modification

Yearly operation limit= 500 hours

STRU 22DDG Fluid Bed Cooler BypassGiven:Capacity = 23 ton/hrAll point source emissions from these emission units will be controlled by a fabric filteMaximum controlled TSP/PM10 emission rate = 0.005 gr/dscfExhaust Flow Rate = 23,400 dscfmControlled Hourly Potential to Emi 1.00 lb/hrUncontrolled Hourly Potential to Emi 100.29 lb/hrControlled Annual Potential to Emit 0.25 ton/yearUncontrolled Annual Potential to Emit 1.23 ton/yearMaximum controlled PM2.5 emission rate = 17.00%Controlled Hourly Potential to Emi 0.17 lb/hrControlled Annual Potential to Emit 0.04 ton/year

Therefore:VOC Emission Rate (as carbon) = 145.0 ppmvMolecular Weight of carbon = 12VOC Emission Rate (as carbon) = 6.3 lb/hrRatio of Carbon to VOC as Ethanol = 1.92VOC Emission Rate (as ethanol) = 12.2 lb/hr Permit limit

3.0 ton/yrMethanol 0.059 lb/hr 0.01 ton/yrAcetaldehyde 0.204 lb/hr 0.05 ton/yrFormaldehyde 0.0056 lb/hr 0.00 ton/yrAcrolein 0.011 lb/hr 0.00 ton/yrTotal HAPs 0.28 lb/hr 0.07 ton/yr

After Modification

Yearly operation limit= 500 hoursSTRU 22DDG Fluid Bed Cooler BypassGiven:Capacity = 23 ton/hr


TSP 108.86 476.79PM10 15.55 68.11PM2.5 2.64 11.58


EfficiencyMaximum controlled TSP/PM10 emission rate = 0.005 gr/dscfExhaust Flow Rate = 25,400 dscfmControlled TSP Hourly Potential to Emi 1.09 lb/hr 99.0%Controlled TSP Annual Potential to Emit 4.77 ton/yearControlled PM10 Hourly Potential to Emi 1.09 lb/hr 93.0%Controlled PM10 Annual Potential to Emit 4.77 ton/year

Maximum controlled PM2.5 emission rate = 17.00%Controlled PM2.5 Hourly Potential to Emi 0.19 lb/hr 93.0%Controlled PM2.5 Annual Potential to Emit 0.81 ton/year

Therefore:VOC Emission Rate (as carbon) = 145.0 ppmvMolecular Weight of carbon = 12VOC Emission Rate (as carbon) = 6.9 lb/hrRatio of Carbon to VOC as Ethanol = 1.92VOC Emission Rate (as ethanol) = 13.21 lb/hrAnnual Potential to Emit 57.88 ton/yrLimited Annual Potential to Emit 3.30 ton/yr

HAP PTE Limited HAPMethanol See Note 1 0.36 lb/hr 1.58 ton/yr 0.09 ton/yrAcetaldehyde See Note 1 0.39 lb/hr 1.72 ton/yr 0.10 ton/yrFormaldehyde See Note 2 0.51 lb/hr 2.22 ton/yr 0.13 ton/yrAcrolein See Note 2 0.10 lb/hr 0.43 ton/yr 0.02 ton/yrTotal HAPs 1.36 lb/hr 5.96 ton/yr 0.34 ton/yr

Note 1

Note 2

Change in EmissionsPollutant lb/hr ton/yearTSP/PM10 0.09 0.84VOC 1.04 0.26Methanol 0.30 0.08Acetaldehyde 0.19 0.05Formaldehyde 0.50 0.13Acrolein 0.09 0.02HAPs 1.08 0.27


The DDGS cooler is also a source of VOC emissions because the DDGS retains a small quantity of ethanol after drying. This ethanol is emitted from the cooler stack. The cooler is not controlled during bypass mode. The concentration of VOC in the DDGS cooler exhaust ranges from 20 to 50 PPMV. 145 PPMV was used to calculate the VOC emissions.

Lake Crystal May 18, 2010 Stack Test Result increased by 50% safety factor and beer feed increase ratio of 700 gpm/641 gpmThis test result was used because it was higher than the 2005 test result.

Lake Crystal July 12-14, 2005 Stack Test Result increased by 50% safety factor and beer feed increase ratio of 700 gpm/641 gpm.This test result was used because it was higher than the 2010 test result.

The DDGS coolers are vented to both boilers and the DDGS Dryers as preheat air to reduce fuel use. The dryers are vented to the RTO. The majority of the air goes to the dryers. If the dryers go down, the DDGS fluid bed cooler also goes down.Only in the event of a startup, shutdown, or malfunction do emissions from the DDGS Fluid Bed Cooler vent to the bypass Stack SV014.

of PM10 emission rate per AP-42 Table

The DDGS cooler is also a source of VOC emissions because the DDGS retains a small quantity of ethanol after drying. This ethanol is emitted from the cooler stack. The cooler is not controlled during bypass mode. The concentration of VOC in the DDGS cooler exhaust ranges from 20 to 50 PPMV. 145 PPMV was used to calculate the emissions. The HAP emissions are based upon stack test data conducted on the James Valley facility on July 23, 2003.

The RTO must occasionally be temporarily shut down for unscheduled maintenance or other operational reasons. In this event, the DDGS Fluid Bed Cooler emissions will be vented to the bypass Stack SV014.



Northstar Ethanol, LLC d/b/a POET Biorefining - Lake CrystalLake Crystal, MinnesotaMiscellaneous Source VOC Emission CalculationsStorage Tanks, Unit SV012 Ethanol Load-out, Process Equipment Leaks FS00

Equipment Leaks from sources in VOC service

These factors assume the working fluid is 100% VOC by wt

Equipment Type Service Emission Factor (lbs/hour/source

Pump Seals light liquid 0.04378Valves light liquid 0.008866Valves gas 0.013134

Compressors gas 0.5016Relief Valves gas 0.2288

Sampling Connections all 0.033Open Ended Lines all 0.00374

Connectors all 0.004026

Emission Factors (EPA-453/R-95-017, Table 2-1)

For sources where the working fluid is < 90% VOC by weight. The emission factors are multiplied by the VOC wt. % to calculathe appropriate emission rate

Sources in Beer service (I.e. 15% VOC by wt. Sources in 90% or greater VOC service (assume 100% VOC by wt.

Equipment TypeNumber of

sources VOC Emissions lbs/hr TPY Equipment Type Number of sourcesVOC Emissions

lbs/hr TPYPump Seals 7 0.05 0.20 Pump Seals 7 0.31 1.34Valves lt. Liq. 180 0.24 1.05 Valves lt. Liq. 281 2.49 10.91Valves gas 0 0.00 0.00 Valves gas 0 0.00 0.00

Compressors 0 0.00 0.00 Compressors 0 0.00 0.00Relief Valves 0 0.00 0.00 Relief Valves 13 2.97 13.03

Sampling Connections 0 0.00 0.00Sampling

Connections 0 0.00 0.00Open Ended Lines 0 0.00 0.00 Open Ended Lines 0 0.00 0.00

Connectors 637 0.38 1.68 Connectors 1140 4.59 20.10

Total 0.67 2.93 Total 10.36 45.38

Since all of these sources are subject to the NSPS subpart VVa; credit for emission reduction attributable to control equipment and a LeaDetection and Repair (LDAR) Program is warranted (see EPA-453/R-95-017, chapter 5)

Summary of Equipment Modifications and Control Efficiency Control Effectiveness for a LDAR Program

Equipment Type

Number of SourcesModified Modification Control % Equipment Type

Pump Seals 0Dual mechanical seal with barrier fluid

at higher pressure 100 Pump SealsValves lt. Liq. 0 Valves lt. Liq.Valves gas 0 Valves gas

Compressors 0 ConnectorsRelief Valves 3 Rupture disk assembly 100 Relief Valves

Sampling Connections 0Open Ended Lines 0 Blind, cap, plug or second valve 100

Connectors 0

Controlled Fugitive Equipment Leak Emissions

Equipment Type

VOCEmissions

lbs/hr TPYPump Seals 0.09 0.39Valves lt. Liq. 0.33 1.44Valves gas 0.00 0.00

Compressors 0.00 0.00Relief Valves 0.18 0.80

Sampling Connections 0.00 0.00Open Ended Lines 0.00 0.00

Connectors 0.35 1.53

lbs/hr TPYTotal VOCs 0.95 4.15

Ethanol Loading RacksEmission Factors: AP-42, Section 5.2, September 1995

Denatured ethanol is loaded into either trucks or railcars. The railcars is a dedicated fleet for denatured ethanol service. Also, ttrucks can be used to carry gasoline prior to filling with ethanol. Both railcars and trucks will be filled by submerged loading procesTruck loadout operations are controlled by a flare, which has a control efficiency of 98% for VOC and HAP

According to AP-42, Chapter 5.2 - Transportation and Marketing of Petroleum Liquids (01/95), the VOC emission factors for thtruck and rail loading racks can be estimated from the following equation

L = 12.46 x (SPM)/T

where:L = loading loss (lbs/kgalS = a saturation factor (see AP-42, Table 5.2-1 P = true vapor pressure of the liquid loaded (psia)M = molecular weight of vapors T = temperature of the bulk liquid loaded (degree R)

*S P (psia)

M(lbs/mole

lbs) T (degree R) L (lbs/kgal)Denatured Ethanol (normal) 0.6 0.5364 50.521 507.56 0.40

The emission factor for loading denatured ethanol to rail which previously contained denatured ethanol

= L (Denatured ethanol, normal) = Denatured Ethano 0.40 (lbs/kgal)The emission factor for loading E-85 to trucks which stored gasoline previously

= L (gasoline, normal) - L (gasoline, clean cargo) + L (E-85, clean cargo) = E-85 5.95Therefore, the emission factor for loading denatured ethanol to trucks which stored gasoline previously

= L (gasoline, normal) - L (gasoline, clean cargo) + L (denatured ethanol, clean cargo) = Denatured Ethano 5.08

True vapor pressure and the molecular weight are calculated within Tanks 4.0.9 software for Des Moines, Iowa meteorological data.

Denatured ethanol is assumed to be 95% ethanol and 5% RVP13 gasoline

1Control effectiveness is based upon a 500 ppm leak detection fromChapter 4, Preferredand alternative methods for estimating fugitive emissions from equipment leaks,November 1996.

92

Control effectiveness (%) for HON monitoring 500 ppmv leak definition1

75889293


1. Uncontrolled Potential to Emit for VOC:

(1) Assume truck loadout = Denatured Loadout = 100%Total Loadout = 62.74 Mmgal/yr

Denatured Ethanol Loading Rate limit for truck 62.74 MMgal/yr PTE of VOC before Control (tons/yr) = 62.7375 MMgal/yr x 5.08 lbs/kgal, x 1 ton/2000 lbs = 159.3 tons/yr

(2) Assume all ethanol loaded out via rail and 5,000 kgal uncontrolled to truck PTE of VOC from dedicated railcar loading (tons/yr) =52.54 MMgal/yr x 0.40 lbs/kgal x 1 ton/2000 lbs = 10.5 tons/yr

PTE of VOC from uncontrolled truck loading (tons/yr) =5 MMgal/yr x 5.08 lbs/kgal x 1 ton/2000 lbs = 12.7 tons/yrTotal: 23.18 tons/yr

2. Limited Potential to Emit:

Annual Production Limit 62,738 kgal/yr (total)Annual Uncontrolled Truck Loading Limit 5,000 kgal/yr (truck loading limit

Annual Controlled Truck Loading Limit 57,738 kgal/yr (truck loading limitFlare Control Efficiency 98%

(1) Assume truck loadout = Denatured Loadout = 100%

PTE of VOC from denatured ethanol truck loading (tons/yr) =5.08 lbs/kgal x 57737.5 kgal/yr x (1-98%) x 1 ton/2000 lbs 2.93 tons/yr PTE of VOC from uncontrolled denatured ethanol truck loading (tons/yr) 5.08 lbs/kgal x 5000 kgal/yr x 1 ton/2000 lbs = 12.70

Total: 15.63

23.18 tons/yr

17.85 lb/hr3. Potential to Emit HAPs:

HAP emissions are mainly from the unloading process for trucks, which may have been used to ship gasoline previous

HAP Fraction*2.50E-032.00E-051.00E-045.00E-055.00E-025.00E-035.00E-04

0.06* This is the HAP fraction for gasoline vapors.

Methodology

PTE of HAP before Control (tons/yr) = PTE of VOC before Control (tons/yr) x HAP Fraction

Limited PTE of HAP after Control (tons/yr) = Limited PTE of VOC by Trucks (tons/yr) x HAP Fraction

Flare Emissions

PM* PM10* SO2* NOx** VOC*** CO**

Emission Factor NA NA NA 0.068 0.14 0.370 (lb/MMBtu) (lb/MMBtu) (lb/MMBtu)

Limited Potential to Emit in tons/yr NA NA NA 0.00193 0.00397 0.01049Limited Potential to Emit in lbs/hr NA NA NA 0.00386 0.00794 0.02098*PM, PM10, and SO2 emission factors are negligible due to the smokeless design and minimal H2S levels.

**Emission factors for NOx and CO are based on the information provided by the flare manufacturer (John Zink Company).

Methodology

Limited PTE of NOx and CO (tons/yr) = Annual Production Limit (kgal/yr) x Emission Factor (lbs/kgal) x 1 ton/2000 lbs

Pollutant

Heat Input Capacity Annual Production LimitMMBtu/hr kgal/yr

0.0567 62,738

Xylenes 0.08 7.82E-03 1.78E-03Total 9.27 0.91 0.21

Hexane 7.97 7.82E-01 1.78E-01Toluene 0.80 7.82E-02 1.78E-02

Cumene 0.02 1.56E-03 3.57E-04Ethylbenzene 0.01 7.82E-04 1.78E-04

Benzene 0.40 3.91E-02 8.92E-03Carbon Disulfide 0.00 3.13E-04 7.14E-05

Worst case scenario is when loading 52.5 MMgal/yr denatured ethanol to uncontrolled rail and 5 Mmgal/yr denatured ethanol to uncontrolled truck =

Worst case hourly emission scenario is loading 3000 gal/hr of E-85 into trucks uncontrolled =

HAP PTE of HAP before Control (tons/yr)Limited PTE of HAP after Control

(tons/yr) Limited PTE of HAP after Control (lbs/hr)


No

rth

star

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ano

l, L

LC

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cific

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n Ju

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cific

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2.5

0.41

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0.00

0147

lb/H

P-h

rC

ater

pilla

r S

peci

ficat

ion

June

201

2N

O2

58.7

00lb

/hr

0.02

1055

lb/H

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ater

pilla

r S

peci

ficat

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June

201

2N

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66.9

12lb

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0.02

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AP

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Sec

tion

Sec

tion

3.4

Tab

le 3

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SO

x1.

128

lb/h

r0.

0004

05lb

/HP

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AP

-42

Sec

tion

Sec

tion

3.4

Tab

le 3

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VO

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640

lb/h

r0.

0005

88lb

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Cat

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n Ju

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CO

1.18

0lb

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0.00

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lb/H

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ater

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r S

peci

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June

201

2G

reen

hous

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ases

CO

21.

16lb

/HP

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AP

-42

Sec

tion

Sec

tion

3.4

Tab

le 3

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CH

46.

35E

-05

lb/H

P-h

rA

P-4

2 S

ectio

n S

ectio

n 3.

4 T

able

3.4

-2, F

ootn

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fN

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32E

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lb/M

MB

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able

s C

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C-2

, 40

CF

R 9

8

Giv

en:

Gen

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ize

2788

HP

Per

mit

An

nu

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ou

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uel U

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ate

136.

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l/hr

The

faci

lity

is e

quip

ped

with

thre

e 20

00 k

w e

lect

ric g

ener

ator

s. T

he p

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the

gene

rato

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to

pro

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ctric

ity in

the

even

t of a

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ition

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In th

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and

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and

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is n

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pact

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e op

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ion

of th

e ge

nera

tors

in e

mer

genc

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The

gen

erat

ors

may

be

used

for

peak

sha

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ope

ratio

n.

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pot

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for

the

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re c

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mul

tiply

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mis

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fact

or b

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s. T

he e

mis

sion

fact

ors

are:

The

sul

fur

cont

ent o

f the

fuel

use

d fo

r th

e ge

nera

tor

will

be

less

than

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t% (

500

ppm

- lo

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ulfu

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Emiss

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Calc

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.xlsx

32of

523/

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TS

PP

M10

PM

2.5

NO

2N

Ox

SO

xV

OC

CO

CO

2C

H4

N2O

CO

2elb

/hr

lb/h

rlb

/hr

lb/h

rlb

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lb/h

rlb

/hr

lb/h

rlb

/hr

lb/h

rlb

/hr

lb/h

rG

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#1

0.41

0.41

0.41

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1.80

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ITE

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mis

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ns

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0.03

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Emiss

ion

Calc

ulat

ions

.xlsx

33of

523/

22/2

016

Northstar Ethanol, LLC d/b/a POET Biorefining - Lake CrystalLake Crystal, MinnesotaSV013 Diesel Generator Calculations

Permit Annual Hourly Usage 140 hours/year each unit

2000 kw GeneratorsEmission

Factor 1

HAP Pollutant (lb/hp-hr) (lb/hr) (ton/yr)Acetaldehyde 1.76E-07 4.91E-04 2.15E-03Acrolein 5.52E-08 1.54E-04 6.74E-04Benzene 5.43E-06 1.51E-02 6.63E-02Formaldehyde 5.52E-07 1.54E-03 6.74E-03Naphthalene 9.10E-07 2.54E-03 1.11E-02Toluene 1.97E-06 5.49E-03 2.41E-02Xylenes 1.35E-06 3.76E-03 1.65E-02

0.029 0.128

LIMITED Emissions - per unitPotential to

HAP Pollutant (lb/hr) (ton/yr)Acetaldehyde 4.91E-04 3.43E-05Acrolein 1.54E-04 1.08E-05Benzene 1.51E-02 1.06E-03Formaldehyde 1.54E-03 1.08E-04Naphthalene 2.54E-03 1.78E-04Toluene 5.49E-03 3.84E-04Xylenes 3.76E-03 2.63E-04

0.029 0.002

The facility is equipped with three 2000 kw electric generators. The primary purposeof the generators are to provide electricity in the event of an emergency condition atthe plant.The generators may be used for peak shaving operation.


1. Emission factors are from AP-42 Section 3.4 Large Stationary Diesel and All Stationary Dual-fuel Engines.


Northstar Ethanol, LLC d/b/a POET Biorefining - Lake CrystalLake Crystal, Minnesota

Storage Tanks TK001 - TK005

Before ModificationStorage Tanks (see TANKS 4.0 reports)

Tank Number lb/year lb/hr Ton/year Description74 535 0.06 0.27 190 Proof Ethanol Storage Tank73 514 0.06 0.26 200 Proof Ethanol Storage Tank

75 1763 0.20 0.88 Denaturant Storage Tank77 638 0.07 0.32 Denatured Ethanol Storage Tank #172 638 0.07 0.32 Denatured Ethanol Storage Tank #2

After Modification

Tank Number lb/year lb/hr Ton/year Description74 570 0.0651 0.2850 190 Proof Ethanol Storage Tank73 550 0.0628 0.2750 200 Proof Ethanol Storage Tank

75 3207 0.3661 1.6035 Denaturant Storage Tank77 714 0.0815 0.3570 Denatured Ethanol Storage Tank #172 714 0.0815 0.3570 Denatured Ethanol Storage Tank #2

HAP Name Vapor FractionEmissions

lb/hr Emissions (TPY)Benzene 1.31E-02 4.80E-03 2.10E-02

Ethylbenzene 2.00E-04 7.32E-05 3.21E-04Hexane 6.53E-02 2.39E-02 1.05E-01Toluene 2.10E-03 7.69E-04 3.37E-03Xylenes 9.00E-04 3.29E-04 1.44E-03

Total 8.16E-02 2.99E-02 1.31E-01


lb/hrControlled

Emissions (TPY)Benzene 3.60E-03 5.87E-04 2.57E-03Ethylbenzene 1.00E-04 1.63E-05 7.14E-05Hexane 1.80E-02 2.93E-03 1.29E-02Toluene 6.00E-04 9.78E-05 4.28E-04Xylenes 3.00E-04 4.89E-05 2.14E-04Acetaldehyde 2.00E-04 3.26E-05 1.43E-04Methanol 2.11E-05 3.43E-06 1.50E-05Formaldehyde 2.81E-05 4.58E-06 2.00E-05Acrolein 1.40E-05 2.29E-06 1.00E-05Total 2.29E-02 3.73E-03 1.63E-02

HAP NameEmissions

lb/hr

ControlledEmissions

(TPY)Benzene 5.38E-03 2.36E-02Ethylbenzene 8.95E-05 3.92E-04Hexane 2.68E-02 1.18E-01Toluene 8.67E-04 3.80E-03Xylenes 3.78E-04 1.66E-03Acetaldehyde 3.26E-05 1.43E-04Methanol 3.43E-06 1.50E-05Formaldehyde 4.58E-06 2.00E-05Acrolein 2.29E-06 1.00E-05Total 3.36E-02 1.47E-01

HAP Emission Calculations (Denaturant)

HAP Emission Calculations (Denatured Ethanol)

HAP Emission Calculations (Total)


Change in Emissions

Tank Number lb/year lb/hr Ton/year Description74 35 0.00 0.02 190 Proof Ethanol Storage Tank73 36 0.00 0.02 200 Proof Ethanol Storage Tank75 1444 0.16 0.72 Denaturant Storage Tank77 76 0.01 0.04 Denatured Ethanol Storage Tank #172 76 0.01 0.04 Denatured Ethanol Storage Tank #2

Total 1667 0.19 0.83


lb/hr Emissions (TPY)Benzene 1.31E-02 2.16E-03 9.46E-03

Ethylbenzene 2.00E-04 3.30E-05 1.44E-04Hexane 6.53E-02 1.08E-02 4.71E-02Toluene 2.10E-03 3.46E-04 1.52E-03Xylenes 9.00E-04 1.48E-04 6.50E-04

Total 8.16E-02 1.35E-02 5.89E-02

HAP Name Vapor Fraction

ControlledEmissions

(TPY)Benzene 3.60E-03 2.74E-04Ethylbenzene 1.00E-04 7.60E-06Hexane 1.80E-02 1.37E-03Toluene 6.00E-04 4.56E-05Xylenes 3.00E-04 2.28E-05Acetaldehyde 2.00E-04 1.52E-05Methanol 2.11E-05 1.60E-06Formaldehyde 2.81E-05 2.13E-06Acrolein 1.40E-05 1.07E-06Total 2.29E-02 1.74E-03

HAP Emission Calculations (Denaturant)

HAP Emission Calculations (Denatured Ethanol)


Northstar Ethanol, LLC d/b/a POET Biorefining - Lake CrystalLake Crystal, MinnesotaFS001 Unpaved Road Traffic Emission Calculations

Equation from AP-42 Section 13.2.2 Unpaved RoadsE = k(s/12)^a(W/3)^b

Eext = E[(365 P)/365]

Formula VariablesDescription Variable ValueValue used for lb/ton PM2.5 k 0.15Value used for lb/ton PM10 k 1.5Value used for lb/ton PM k 4.9Value used for lb/ton PM2.5 a 0.9Value used for lb/ton PM10 a 0.9Value used for lb/ton PM a 0.7Value used for lb/ton PM2.5 b 0.45Value used for lb/ton PM10 b 0.45Value used for lb/ton PM b 0.45

Surface material silt content (g/m2) sL 5.00Surface material moisture content M 5.00Mean vehicle weight (tons)1

W 27.50Number of Days in a year with at least 0.254 mm of precipitation P 105.00

Vehicle Type

Average Weight of

Truck (tons)1Quantity Transported

per Truck

MaximumNumber of

Trucks(Trucks/yr)

Limited Number of Trucks

(Trucks/yr)

MilesTraveled per

Truck Limited VMT/yrDDGS Haul Out 27.5 25 ton 7,696 7,696 1.30 10,004Ethanol Haul Out 27.5 8,000 gal 7,842 7,842 1.20 9,411Denaturant Delivery 27.5 8,000 gal 373 373 1.20 448Grain Delivery 27.5 25 tons 25,708 25,708 1.30 33,421Corn Oil 27.5 8,000 gal 450 450 0.85 383Syrup 27.5 8,000 gal 100 100 0.85 85Total 27.50 53,752

Fugitive dust control plan requires application of dust suppressant.Control Efficiency of dust suppresant = 50%Lb/hr calculations are based on 16 hours per day, 5 days per week. 50 weeks per year.

Unpaved Haul Road Emissions E(lb/VMT) Eext

UncontrolledLb/hour

Uncontrolled(TPY)

PrecipitationReduced

(TPY)Emissions PM2.5 0.18 0.13 2.48 4.97 3.54Emissions PM10 1.85 1.32 24.84 49.69 35.39Emissions PM 7.20 5.13 96.69 193.38 137.75

Unpaved Haul Road Emissions

ControlledLb/hour

DustSuppressantControlled

(TPY)

DustSuppressant

Reduced(TPY)

Emissions PM2.5 1.24 2.48 1.77Emissions PM10 12.42 24.84 17.70Emissions PM 48.34 96.69 68.87

All trucks are assumed to have an empty weight of 15 tons and a full weight of 40 tons. Actual ethanol and denaturant trucks havea capacity of 8,000 gallons and DDGS trucks have a capacity of 25 tons.

Assume for the limited potential to emit calculations that 100% of the ethanol and DDGS are trucked off-site. Also assume that 100% of the denaturant and grain is received by truck. Actual operations will result in some of the ethanol and DGGS being shipped off-site by rail.


Northstar Ethanol, LLC d/b/a POET Biorefining - Lake CrystalLake Crystal, MinnesotaEQUI 80 Uncaptured Grain Handling Source Emission Calculations

Before ModificationGiven:Maximum Hourly Truck Dump Rate = 840 ton/hourLimited Daily Truck Dump Rate 20,160 tons/dayMaximum Annual Truck Dump Rate = 642,710 ton/yearHopper Truck TSP Emission Factor = 0.035 lb/tonHopper Truck PM10 Emission Factor = 0.0078 lb/tonStraight Truck TSP Emission Factor = 0.18 lb/tonStraight Truck PM10 Emission Factor = 0.059 lb/tonHopper Truck TSP Emission Factor = 0.035 lb/tonHopper Truck PM10 Emission Factor = 0.0078 lb/tonPercent Straight Trucks= 65%Percent Hopper Trucks= 35%Average Truck TSP Emission Factor = 0.129 lb/tonAverage Truck PM10 Emission Factor = 0.041 lb/tonShed Capture Efficiency = 80%

Hourly Emission Rate Daily Emission Rate

Annual Emission Rate

lb/hr lb/day ton/yearTSP 30.2 725.8 8.3PM10 9.9 237.9 2.6PM2.5 1.7 40.4 0.4

After Modification

Maximum Annual Truck Dump Rate = 642,710 ton/year

Hourly Emission Rate Daily Emission Rate

Annual Emission Rate

lb/hr lb/day ton/yearTSP 30.24 725.76 8.31PM10 9.91 237.89 2.64PM2.5 1.69 40.44 0.45

Change in Uncaptured Grain Receiving EmissionsHourly Emission

Rate Annual Emission Rate

lb/hr ton/yearTSP 0.0 0.0PM10 0.0 0.0PM2.5 0.0 0.00

The grain unloading operations are located inside a dump shed and will be aspirated to a fabric filter. The shed enclosure will provide control of the TSP and PM10 emissions. The loading shed and aspiration system will capture 80% of the particulate matter emitted during rail loading operations. Therefore, grain unloading will be a source of fugitive particulate emissions.

PM2.5 = 17% of PM10 emission rate per AP-42

No physical modification will be completed at the grain receiving pit. The change will be due to an increase in annual grain receipts

PM2.5 = 17% of PM10 emission rate per AP-42


Northstar Ethanol, LLC d/b/a POET Biorefining - Lake CrystalLake Crystal, MinnesotaEQUI 81 Uncaptured DDG Source Emission Calculations

Eu lb/hr = Ef lb/ton x W tons

Ec lb/hr = (Ef lb/ton x W tons) x [(100-Ce) / 100]

Before ModificationGiven:Maximum Hourly Loading Rate = 200 ton/hourMaximum Annual Loading Rate = 192,394 ton/yearStraight Truck TSP Emission Factor = 0.086 lb/ton AP-42 Table 9.9.1-1 Grain ShippingStraight Truck PM10 Emission Factor = 0.029 lb/ton AP-42 Table 9.9.1-1 Grain ShippingRail Car TSP Emission Factor = 0.027 lb/ton AP-42 Table 9.9.1-1 Grain ShippingRail Car PM10 Emission Factor = 0.0022 lb/ton AP-42 Table 9.9.1-1 Grain ShippingCapture Efficiency of Rail shed and Aspiration system 80%Capture Efficiency of truck shed 80%

HourlyEmission

RateAnnual

Emission Rate

lb/hr ton/yearControlled TSP 3.44 1.65Controlled PM10 1.16 0.56

Controlled PM2.5 0.20 0.09

Ef = Emission factor in lb/ton loadedW = Tons loaded per unit timeCe = Capture efficiency of shed and aspiration system

PM2.5 = 17% of PM10 emission rate per AP-42 Table 9.9.1-1 Reference 40

Ec = Emission rate in lb/hr

The loading of DDG solids into trucks and railcars will be conducted inside a shed. The loading operations will be aspirated to a fabric filter. The loading shed and aspiration system will capture 80% of the particulate matter emitted during loading operations. Therefore, DDG loading will be a source of uncaptured particulate emissions.

The emissions from the loading operations into trucks are higher than railcar loading. Therefore, the potential emission calculations will be based on truck loading for all DDG.

The uncontrolled potential emission will be calculated by multiplying the appropriate USEPA AP-42 emission factor by the maximum loading rate for the process and assuming that all TSP/PM10 is emitted.

The controlled potential emissions will be calculated by multiplying the appropriate USEPA AP-42 emission factor by the maximum loading rate for the process, assuming that 80% of the TSP/PM10 is captured by the aspiration system with the remainder being emitted.

The equation for calculating the uncontrolled potential fugitive emissions is:

The equation for calculating the uncaptured emissions is:

Where:



After Modification

Maximum Annual Loading Rate = 192,394 ton/year

HourlyEmission

RateAnnual

Emission Rate

lb/hr ton/yearControlled TSP 3.44 1.65Controlled PM10 1.16 0.56Controlled PM2.5 0.20 0.09

DDGS bypassing silo and sent to floor storage

Before ModificationAssumeDDGS Production Rate = 23 ton/hrmaximum annual production of DDGS sent to floor 25%- straight truck loading emission factor for piling operation

HourlyEmission

RateAnnual

Emission Rate

lb/hr ton/yearUncontrolled TSP 1.98 2.07Uncontrolled PM10 0.67 0.70Uncontrolled PM2.5 0.11 0.12

After ModificationAssumeDDGS Production Rate = 25 ton/hr- 25% maximum annual production of DDGS sent to floor- straight truck loading emission factor for piling operation

HourlyEmission

RateAnnual

Emission Rate

lb/hr ton/yearUncontrolled TSP 2.15 2.07Uncontrolled PM10 0.73 0.70Uncontrolled PM2.5 0.12 0.12

Total DDGS Loading Emissions -Before Modification

HourlyEmission

RateAnnual

Emission Rate




No physical modification will be completed at the DDGS Loading System. The change will be due to an increase in annual DDGS production and loadout.




Total DDGS Loading Emissions -After Modification

HourlyEmission

RateAnnual

Emission Rate


Change in DDGS Loading Emissions

HourlyEmission

RateAnnual

Emission Rate




Northstar Ethanol, LLC d/b/a POET Biorefining - Lake CrystalLake Crystal, MinnesotaMiscellaneous Source VOC/HAP Emission CalculationsProcess Equipment Leaks FS003

Equipment Leaks from Equipment in VOC Service in the Tank Farm

These factors assume the working fluid is 100% VOC by wt.

Equipment Type ServiceEmission Factor (lbs/hour/source) Emission Factors (EPA-453/R-95-017, Table 2-1)

Pump Seals light liquid 0.04378Valves light liquid 0.008866Valves gas 0.013134

Compressors gas 0.5016Relief Valves gas 0.2288

Sampling Connections all 0.033Open Ended Lines all 0.00374

Connectors all 0.004026

Sources in Tank Farm Equipment Denaturant service Sources in Tank Farm Equipment Ethanol service

Equipment TypeNumber of

sourcesVOC Emissions

lbs/hr TPY Equipment TypeNumber of

sourcesVOC Emissions

lbs/hr TPYPump Seals 2 0.09 0.38 Pump Seals 5 0.22 0.96Valves lt. Liq. 11 0.10 0.43 Valves lt. Liq. 70 0.62 2.72Valves gas 0 0.00 0.00 Valves gas 0 0.00 0.00

Compressors 0 0.00 0.00 Compressors 0 0.00 0.00Relief Valves 2 0.46 2.00 Relief Valves 21 4.80 21.05

Sampling Connections 0 0.00 0.00Sampling

Connections 0 0.00 0.00

Open Ended Lines 0 0.00 0.00 Open Ended Lines 0 0.00 0.00Connectors 115 0.46 2.03 Connectors 544 2.19 9.59

Total 1.11 4.84 Total 7.83 34.31

Since all of these sources are subject to the NSPS subpart VVa; credit for emission reduction attributable to control equipment and a Leak Detection and Repair (LDAR) Program is warranted (see EPA-453/R-95-017, chapter 5).

Equipment Type

Number of SourcesModified Modification Control % Equipment Type

Pump Seals 0 0 100 Pump SealsValves lt. Liq. 0 Valves lt. Liq.Valves gas 0 Valves gas

Compressors 0 Connectors1

Relief Valves 0Rupture disk

assembly 100 Relief Valves

Sampling Connections 0

Open Ended Lines 0Blind, cap, plug or

second valve 100Connectors 0

9293

92Conrol effectiveness is based upon a 500 ppm leak detection

from Chapter 4, Preferred and alternative methods forestimating fugitive emissions from equipment leaks, November1996.

88

HAP speciation profile from the TANKS 4.09 reports for denatured ethanol and denaturant was used to estimate the HAP emissions from the equipment leaks associated with the respective service.

Summary of Equipment Modifications and Control Efficiency Control Effectiveness for a LDAR Program

Control effectiveness (%) for HON monitoring

500 ppmv leak definition1

75


Equipment Type

VOCEmissions

lbs/hr TPY Equipment Type

VOCEmissions

lbs/hr TPYPump Seals 0.02 0.10 Pump Seals 0.05 0.24Valves lt. Liq. 0.01 0.05 Valves lt. Liq. 0.07 0.33Valves gas 0.00 0.00 Valves gas 0.00 0.00

Compressors 0.00 0.00 Compressors 0.00 0.00Relief Valves 0.04 0.16 Relief Valves 0.38 1.68

Sampling Connections 0.00 0.00 Sampling Connectio 0.00 0.00Open Ended Lines 0.00 0.00 Open Ended Lines 0.00 0.00

Connectors 0.03 0.14 Connectors 0.15 0.67lbs/hr TPY lbs/hr TPY

Total VOCs 0.10 0.45 Total VOCs 0.67 2.92

HAP Name Vapor FractionControlled

Emissions (TPY)

UncontrolledEmissions

(TPY) HAP NameVapor

FractionControlled

Emissions (TPY)

Uncontrolled Emissions

(TPY)Benzene 1.31E-02 5.89E-03 6.34E-02 Benzene 3.60E-03 1.05E-02 1.24E-01Ethylbenzene 2.00E-04 8.99E-05 9.69E-04 Ethylbenzene 1.00E-04 2.92E-04 3.43E-03Hexane 6.53E-02 2.93E-02 3.16E-01 Hexane 1.80E-02 5.26E-02 6.18E-01Toluene 2.10E-03 9.44E-04 1.02E-02 Toluene 6.00E-04 1.75E-03 2.06E-02Xylenes 9.00E-04 4.04E-04 4.36E-03 Xylenes 3.00E-04 8.76E-04 1.03E-02

Acetaldehyde 2.00E-04 5.84E-04 6.86E-03Methanol 2.11E-05 6.15E-05 7.22E-04Formaldehyde 2.81E-05 8.20E-05 9.63E-04Acrolein 1.40E-05 4.10E-05 4.82E-04

HAP Name

ControlledEmissions

Lb/hrControlled

Emissions (TPY)

UncontrolledEmissions

(TPY)Benzene 1.87E-06 1.64E-02 1.87E-01Ethylbenzene 4.36E-08 3.82E-04 4.40E-03Hexane 9.35E-06 8.19E-02 9.34E-01Toluene 3.08E-07 2.70E-03 3.08E-02Xylenes 1.46E-07 1.28E-03 1.47E-02Acetaldehyde 6.67E-08 5.84E-04 6.86E-03Methanol 7.02E-09 6.15E-05 7.22E-04Formaldehyde 9.36E-09 8.20E-05 9.63E-04Acrolein 4.68E-09 4.10E-05 4.82E-04

1.18E-05 1.03E-01 1.18E+00

HAP Emission Calculations (Denaturant Service) HAP Emission Calculations (Ethanol Service)

Total HAP Emission Calculations in HAP Service

Controlled Fugitive Emissions from Tank Farm Equipment in Denaturant Service

Controlled Fugitive Emissions from Tank Farm Equipment in Denatured Ethanol Service


Northstar Ethanol, LLC d/b/a POET Biorefining - Lake CrystalLake Crystal, Minnesota

FS004 Cooling Tower Emission Calculations

PM to PM10 ratio: 70% California SCAQMD CEIDARS TablePM to PM2.5 ratio 42% California SCAQMD CEIDARS Table

Water circulation flow = 18,500 gallons per minuteWater circulation flow = 70,030 liters per minuteDrift loss = 0.005%Drift loss = 3.5 liters per minuteTotal Dissolved Solids in cooling tower = 2500 mg/lTotal Dissolved Solids in cooling tower = 2.5 g/lPM-10 = Drift loss (l/min) x TDS (g/l) 8.8 grams/minuteg/min x 60 = 525.2 grams/hr1 pound = 453.6 gramsFugitive PM emissions= 1.16 lbs/hrFugitive PM emissions= 5.07 TPYFugitive PM10 emissions= 0.81 lbs/hrFugitive PM10 emissions= 3.55 TPYFugitive PM2.5 emissions= 0.49 lbs/hrFugitive PM2.5 emissions= 2.13 TPY

Particulate emissions are estimated by analyzing the mass of condensed water that is released times the total mass of dissolved solids present in the water. The estimate is based on the assumption that all of the dissolved solids that are present in the water becomes airborne particulate matter upon evaporation of the release condensed water droplets. The released water droplets are referred to as the "drift loss" of the tower. The drift loss of the tower is usually referenced as a percent of the total water circulation rate of the tower.


Northstar Ethanol, LLC d/b/a POET Biorefining - Lake CrystalLake Crystal, MinnesotaVOC from the Centrifuges

Given:Surface evaporation from tank due to mixing.

Ex = B* {Mx * Kx * A * Px * 3600 * H} / {R * T)Where:Ex = Emissions of VOC species x (lb/hr)Mx = Molecular weight of VOC species X (lb/lbmole)Kx = Gas Phase mass transfer coefficient or VOC species x (ft/sec)A = Surface area of tank (ft2)Px = Vapor pressure of VOC x (psia)3600 = 3600 seconds per hourH = Batch time (hours)R = Universal gas constant (10.73 psia ft3/lb mole R)T = Temperature of the liquid (R)B = number of batches per year

H = 1.00 hoursB = 1 batchR = 10.73T = 180.0 oFT = 639.7 oRA = 28.27 ft2 Note: Used 6 ft Diameter for Tank

atch Size = 8,330 gallons

Species Mx Px EmissionsEmissionslb/lbmol psia Kx lbs/batch lbs/gallon

Ethanol 46.1 0.055 0.000531 0.020 2.38E-06Water 18.0 7.481 0.000727 1.451 1.74E-04

Total Emissions = 1.471 1.77E-04

Gallons Processed = 35,786 gallon/hr

313,485,360 gallons liquid per year through centrifuge

Centrifuge Unitsanufacturing (lbs/gallon)VOCEthanol 2.38E-06Water 1.74E-04HAPSVOC Emission Rate 2.38E-06 lbs VOC/gallonHourly VOC Emission Rate 8.52E-02 lb/hrAnnual VOC Emission Rate 0.37 ton/year

2.05 lbs/day


No

rth

star

Eth

ano

l, L

LC

d/b

/a P

OE

T B

iore

fin

ing

- L

ake

Cry

stal

Lak

e C

ryst

al, M

inn

eso

taG

reen

ho

use

Gas

Inve

nto

ry -

Em

issi

on

s In

crea

se

Dat

a E

ntr

y S

hee

t

Cal

enda

r Y

eaN

atur

al G

as(d

ecat

herm

s)N

atur

al G

as(s

cf)

Gal

lons

of 2

00-P

roof

E

tOH

Pro

duce

d

Rat

io o

f Nat

ural

G

as U

sage

to

Gal

lons

200

-P

roof

EtO

H

Pro

duce

d20

0575

0,39

275

0,39

2,00

025

,184

,813

29.8

020

061,

588,

640

1,58

8,64

0,00

052

,719

,654

30.1

320

071,

598,

519

1,59

8,51

9,00

053

,637

,316

29.8

020

081,

573,

396

1,57

3,39

6,00

053

,721

,630

29.2

920

091,

560,

196

1,56

0,19

6,00

052

,293

,931

29.8

420

101,

519,

827

1,51

9,82

7,00

053

,309

,023

28.5

1M

axim

um R

atio

=30

.13

Bas

elin

e A

vera

ge N

G U

sage

=1,

593,

579,

500

(Fro

m y

ears

200

6 &

200

7)

Thr

ough

put A

fter

Mod

ifica

tion:

Pro

pose

d Li

mit

for

Gal

lons

of 2

00-P

roof

EtO

H P

rodu

ced

59,7

50,0

00

Pro

ject

ed A

ctua

l NG

Usa

ge =

1,80

0,49

0,57

2(B

ased

on

prop

osed

200

-pro

of E

tOH

pro

duct

ion

limit.

)

Not

es:

Ass

ume

1 th

erm

= 1

00 c

f of N

G.

Pro

ject

ed A

ctua

l NG

Usa

ge =

Pro

pose

d Li

mit

for

Gal

lons

of 2

00-P

roof

EtO

H P

rodu

ced

x M

axim

um R

atio

of A

ctua

l Nat

ural

Gas

Usa

ge/A

ctua

l 200

-Pro

of E

tOH

Pro

duce

d

Gas

100

year

GW

PU

SE

PA

4/4

/201

4

CH

425

N2O

298

Inpu

t for

PT

E C

alcu

latio

ns

Rat

ing

mm

Btu

/hr

An

nu

al N

atu

ral G

as

Eq

uiv

alen

ts(s

cf)

CO

2 P

TE

lb/h

rC

O2

PT

Etp

yL

imit

ed C

O2

tpy

CH

4 P

TE

lb/h

rC

H4

PT

Etp

yL

imit

ed C

H4

tpy

6051

1,28

4,04

770

1529

887

2092

10.

132

0.56

40.

3960

511,

284,

047

7015

2988

720

921

0.13

20.

564

0.39

3025

5,64

2,02

335

0714

943

1046

00.

066

0.28

20.

2010

085

2,14

0,07

811

691

4981

134

868

0.22

10.

939

0.66

100

852,

140,

078

1169

149

811

3486

80.

221

0.93

90.

66

0.05

6748

3,16

37

2820

0.00

00.

001

0.00

2,98

2,97

3,43

617

4368

1220

583.

292.

30

N2O

PT

Elb

/hr

N2O

PT

Etp

yL

imit

ed N

2Otp

yC

O2e

PT

Elb

/hr

CO

2e P

TE

tpy

Lim

ited

CO

2etp

y0.

013

0.05

60.

0470

2229

918

2094

20.

013

0.05

60.

0470

2229

918

2094

20.

007

0.02

80.

0235

1114

959

1047

10.

022

0.09

40.

0711

703

4986

334

904

0.02

20.

094

0.07

1170

349

863

3490

40.

000

0.00

00.

007

2820

0.23

1745

4912

2184

Boi

ler

#2T

ruck

and

Rai

l Loa

ding

Rac

k F

lare

Fac

ility

Tot

al

Tru

ck a

nd R

ail L

oadi

ng R

ack

Fla

reF

acili

ty T

otal

DD

GS

Dry

er #

1D

DG

S D

ryer

#2

RT

OB

oile

r #1

Boi

ler

#2

Em

issi

on

Un

itD

DG

S D

ryer

#1

DD

GS

Dry

er #

2R

TO

Boi

ler

#1

No

rth

star

Eth

ano

l, L

LC

d/b

/a P

OE

T B

iore

fin

ing

- L

ake

Cry

stal

Lak

e C

ryst

al, M

inn

eso

taG

reen

ho

use

Gas

Inve

nto

ry -

Em

issi

on

s In

crea

se

Em

issi

on

Fac

tors

(T

able

s C

-1 &

C-2

, 40

CF

R 9

8)

Def

ault

Hig

h H

eatin

g V

alue

Def

ault

CO

2 E

mis

sion

F

acto

rD

efau

lt C

H4

Em

issi

on F

acto

rD

efau

lt N

2OE

mis

sion

Fac

tor

Fue

l Typ

eM

MB

tu/s

cfkg

CO

2/M

MB

tukg

CH

4/M

MB

tukg

N2O

/MM

Btu

Nat

ural

Gas

(P

ipel

ine

)0.

0010

2853

.02

0.00

10.

0001

MM

Btu

/gal

lon

kg C

O2/

MM

Btu

kg C

H4/

MM

Btu

kg N

2O/M

MB

tu

Dis

tilla

te F

uel O

il N

o. 2

0.13

873

.96

0.00

30.

0006

Liqu

efie

d pe

trol

eum

gas

es (

LPG

)0.

092

62.9

80.

003

0.00

06N

atur

al G

asol

ine

0.11

066

.83

0.00

30.

0006

MM

Btu

/sho

rt to

nkg

CO

2/M

MB

tukg

CH

4/M

MB

tukg

N2O

/MM

Btu

Woo

d an

d W

ood

Res

idua

ls15

.38

93.8

00.

032

0.00

42A

gric

ultu

ral B

ypro

duct

s (c

ob /

stov

er)

8.25

118.

170.

032

0.00

42

MM

Btu

/gal

lon

kg C

O2/

MM

Btu

kg C

H4/

MM

Btu

kg N

2O/M

MB

tu

Bio

mas

s F

uels

- L

iqui

d (v

eg o

il )0.

120

81.5

50.

0011

0.00

011

MM

Btu

/scf

kg C

O2/

MM

Btu

kg C

H4/

MM

Btu

kg N

2O/M

MB

tu

Bio

gas

0.00

0841

52.0

70.

0032

0.00

063

Eq

uat

ion

s U

sed

to

Cal

cula

te E

mis

sio

ns

(Tie

r 1

Cal

cula

tio

n M

eth

od

olo

gy)

Eq

uat

ion

s C

-1 &

C-8

CO

2 o

r C

H4

or

N2O

= 1

x 1

0-3

* F

uel

* H

HV

* E

FW

here

:C

O2

=

CH

4 =

N2O

=

Fue

l =H

HV

=E

F =

1 x

10-3

=C

onve

rsio

n fa

ctor

from

kilo

gram

s to

met

ric to

ns

Ann

ual C

O2

mas

s em

issi

ons

[=] m

etric

tons

Ann

ual C

H4

mas

s em

issi

ons

[=] m

etric

tons

Ann

ual N

2O m

ass

emis

sion

s [=

] met

ric to

nsM

ass

or v

olum

e of

fuel

[=] s

hort

tons

for

solid

fuel

s, v

olum

e (s

cf)

Def

ault

high

hea

t val

ue [=

] MM

Btu

/mas

s or

vol

ume

Fue

l-spe

cific

def

ault

pollu

tant

-spe

cific

em

issi

on fa

ctor

Gre

enh

ou

se G

as In

ven

tory

- P

TE

Fer

men

tati

on

Pro

cess

- E

mis

sio

n F

acto

r D

evel

op

men

t -

Bio

gen

ic E

mis

sio

ns

Giv

en:

1ga

llon

of 2

00-P

roof

EtO

H46

.068

44[g

/mol

] mol

e w

eigh

t of E

tOH

0.78

9[g

/cm

3] d

ensi

ty o

f liq

uid

EtO

H44

.009

5[g

/mol

] mol

e w

eigh

t of C

O2

and:

The

refo

re:

1ga

l 200

-Pro

of E

tOH

0.78

9g

EtO

H3,

785.

41

cm

31

cm3

1ga

l

=2,

986.

69

g

EtO

H1

mol

EtO

H46

.068

44g

EtO

H

=65

m

ol E

tOH

2m

ol C

O2

2m

ol E

tOH

=65

m

ol C

O2

44.0

095

g C

O2

1lb

1m

ol C

O2

453.

59

g

=6.

29

lb

s b

iog

enic

CO

2 / g

allo

n o

f E

tOH

pro

du

ced

59,7

50,0

00ga

llons

/yea

r

375,

841,

754

lbs/

year

187,

921

TP

Y42

904

lb/h

r

C6H

12O

6 +

yea

st =

2 C

H3C

H2O

H +

2 C

O2

suga

r +

yea

st =

eth

anol

+ c

arbo

n di

oxid

e

Max

eth

anol

pro

duct

ion

at fa

cilit

y=

CO

2 fr

om fe

rmen

tatio

n pr

oces

s=

Attachment 2: Requirements development report

Requirements Development Subject Item Description

COMG 01 GP011 Fuel type: Limited to natural gas only, by design. [Minn. R. 7005.0100, subp. 35a]

COMG 01 GP011

Recordkeeping: By the last day of each calendar month, the Permittee shall record the amount of natural gas combusted in the boilers during the previous calendar month. These records shall consist of purchase records, receipts, or fuel meter readings. [40 CFR 60.48c(g), Minn. R. 7011.0570]

COMG 02 GP005

The Permittee shall submit a notification of any physical or operational change which increases emission rate: due 60 days (or as soon as practical) before the change is commenced. [40 CFR 60.7(a)(4), Minn. R. 7019.0100, subp. 1]

COMG 02 GP005

Recordkeeping: The Permittee shall maintain records of the occurrence and duration of any startup, shutdown, or malfunction in the operation of the facility including; any malfunction of the air pollution control equipment; or any periods during which a continuous monitoring system or monitoring device is inoperative. [40 CFR 60.7(b), Minn. R. 7019.0100, subp. 1]

COMG 02 GP005

Recordkeeping: The Permittee shall maintain a file of all measurements, maintenance, reports and records for at least five years. This requirement is more stringent than 40 CFR Section 60.7(f), which specifies two years. [40 CFR 60.7(f), Minn. R. 7007.0800, subp. 5(C), Minn. R. 7019.0100, subp. 1]

COMG 02 GP005

No owner or operator shall build, erect, install, or use any article, machine, equipment or process, the use of which conceals an emission which would otherwise constitute a violation of an applicable standard. [40 CFR 60.12, Minn. R. 7011.0050]

COMG 02 GP005

The Permittee shall equip the storage vessel with a fixed roof in combination with an internal floating roof meeting the requirements of 40 CFR Section 60.112b(a)(1). [40 CFR 60.112b(a), Minn. R. 7011.1520, C]

COMG 02 GP005

The internal floating roof shall rest or float on the liquid surface (but not necessarily in complete contact with it) inside a storage vessel that has a fixed roof. The internal floating roof shall be floating on the liquid surface at all times, except during initial fill and during those intervals when the storage vessel is completely emptied or subsequently emptied and refilled. When the roof is resting on the leg supports, the process of filling, emptying, or refilling shall be continuous and shall be accomplished as rapidly as possible. [40 CFR 60.112b(a)(1)(i), Minn. R. 7011.1520, C]

COMG 02 GP005

Each opening in a noncontact internal floating roof except for automatic bleeder vents (vacuum breaker vents) and the rim space vents is to provide a projection below the liquid surface. [40 CFR 60.112b(a)(1)(iii), Minn. R. 7011.1520, C]

COMG 02 GP005

Each opening in the internal floating roof except for leg sleeves, automatic bleeder vents, rim space vents, column wells, ladder wells, sample wells, and stub drains is to be equipped with a cover or lid which is to be maintained in a closed position at all times (i.e., no visible gap) except when the device is in actual use. The cover or lid shall be equipped with a gasket. Covers on each access hatch and automatic gauge float well shall be bolted except when they are in use. [40 CFR 60.112b(a)(1)(iv), Minn. R. 7011.1520, C]

COMG 02 GP005

Automatic bleeder vents shall be equipped with a gasket and are to be closed at all times when the roof is floating except when the roof is being floated off or is being landed on the roof leg supports. [40 CFR 60.112b(a)(1)(v), Minn. R. 7011.1520, C]

COMG 02 GP005

Rim space vents shall be equipped with a gasket and are to be set to open only when the internal floating roof is not floating or at the manufacturer's recommended setting. [40 CFR 60.112b(a)(1)(vi), Minn. R. 7011.1520, C]

COMG 02 GP005

Each penetration of the internal floating roof for the purpose of sampling shall be a sample well. The sample well shall have a slit fabric cover that covers at least 90 percent of the opening. [40 CFR 60.112b(a)(1)(vii), Minn. R. 7011.1520, C]

COMG 02 GP005 Each penetration of the internal floating roof that allows for passage of a column supporting the fixed roof shall have a flexible fabric sleeve seal or a gasketed sliding cover. [40 CFR

60.112b(a)(1)(viii), Minn. R. 7011.1520, C]

COMG 02 GP005 Each penetration of the internal floating roof that allows for passage of a ladder shall have a gasketed sliding cover. [40 CFR 60.112b(a)(1)(ix), Minn. R. 7011.1520, C]

COMG 02 GP005

The Permittee shall visually inspect the internal floating roof, the primary seal, and the secondary seal, prior to filling the storage vessel with Volatile Organic Liquid (VOL). If there are holes, tears, or other openings in the primary seal, the secondary seal, or the seal fabric, or defects in the internal floating roof, or both, the Permittee shall repair the items before filling the storage vessel. [40 CFR 60.113b(a)(1) , Minn. R. 7011.1520, C]

COMG 02 GP005

Notification: If an inspection is required (under 40 CFR Section 60.113b(a)(1) or 40 CFR Section 60.113b(a)(3)(i)), the Permittee shall notify the Commissioner in writing at least 30 days prior to the filling or refilling of the storage vessel, to afford the Commissioner the opportunity to have an observer present. If the inspection is not planned and the Permittee could not have known about the inspection 30 days in advance of the refilling the tank, the Permittee shall notify the Commissioner at least 7 days prior to the refilling of the storage vessel. Notification shall be made by telephone immediately followed by written documentation demonstrating why the inspection was unplanned. Alternatively, this notification including the written documentation may be made in writing and sent by express mail so that it is received by the Commissioner at least 7 days prior to refilling. [40 CFR 60.113b(a)(5), Minn. R. 7011.1520, C]

COMG 02 GP005

The Permittee shall keep a record of each inspection performed as required by 40 CFR Section 60.113b(a)(1), (a)(2), (a)(3), and (a)(4). Each record shall identify the storage vessel on which the inspection was performed and shall contain the date the vessel was inspected and the observed condition of each component of the control equipment (seals, internal floating roof, and fittings). [40 CFR 60.115b(a)(2), Minn. R. 7011.1520, C]

COMG 02 GP005

The Permittee shall keep copies of all records for at least 2 years. The record showing the dimension of the storage vessel and an analysis showing the capacity of the storage vessel will be kept for the life of the source. [40 CFR 60.116b(a), Minn. R. 7011.1520, C]

COMG 02 GP005

Recordkeeping: The Permittee shall maintain records showing the volatile organic liquid (VOL) stored, the period of storage, and the maximum true vapor pressure of the VOL during the respective storage period, calculated as described in 40 CFR Section 116b(e). [40 CFR 60.116b(c), Minn. R. 7011.1520, C]

COMG 02 GP005

Each internal floating roof shall be equipped with a closure devices between the wall of the storage vessel and the edge of the internal floating roof consisting of two seals mounted one above the other so that each forms a continuous closure that completely covers the space between the wall of the storage vessel and the edge of the internal floating roof. The lower seal may be vapor mounted, but both must be continuous. [40 CFR 60.112b(a)(1)(ii)(B) , Minn. R. 7011.1520, C]

COMG 02 GP005

The Permittee shall visually inspect the internal floating roof and the primary seal, or the secondary seal through manholes and roof hatches on the fixed roof at least once every 12 months after initial fill. If the internal floating roof is not resting on the surface of the VOL inside the storage vessel, or there is liquid accumulated on the roof, or the seal is detached, or there are holes or tears in the seal fabric, the Permittee shall repair the items or empty and remove the storage vessel from service within 45 days. If a failure that is detected during inspections cannot be repaired within 45 days and if the vessel cannot be emptied within 45 days, a 30-day extension may be requested from the Administrator in the inspection report required in 40 CFR 60.115b(a)(3). Such a request for an extension must document that alternate storage capacity is unavailable and specify a schedule of actions the company will take that will assure that the control equipment will be repaired or the vessel will be emptied as soon as possible. [40 CFR 60.113b(a)(3)(ii), Minn. R. 7011.1520, C]

COMG 02 GP005

After each inspection required under 40 CFR Section 60.113b(a)(3) that finds holes or tears in the seal or seal fabric, or defects in the internal floating roof, or other control equipment defects listed in 40 CFR Section 60.113b(a)(3)(ii), a report shall be furnished to the Commissioner within 30 days of the inspection. The report shall identify the storage vessel and the reason it did not meet the specifications of 40 CFR Section 60.112b(a)(1) or 40 CFR Section 60.113b(a)(3)(ii), and list each repair made. [40 CFR 60.115b(a)(4), Minn. R. 7011.1520, C]

COMG 02 GP005

Internal Inspections: The Permittee shall conduct internal inspections at intervals no greater than 10 years. The Permittee shall visually inspect the internal floating roof, the primary seal, the secondary seal, gaskets, slotted membranes and sleeve seals (if any) each time the storage vessel is emptied and degassed. If the internal floating roof has defects, the primary or secondary seal has holes, tears, or other openings in the seal or the seal fabric, or the gaskets no longer close off the liquid surfaces from the atmosphere, or the slotted membrane has more than 10 percent open area, the Permittee shall repair the items so that none of these conditions exist before refilling the storage vessel. [40 CFR 60.113b(a)(3)(ii) and (4), Minn. R. 7011.1520, C]

COMG 03 GP008

Total Particulate Matter <= 0.30 grains per 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. Because it has been shown that the facility does not cause a violation of ambient air quality standards, and is located outside the Mpls/St. Paul air quality control region and the city of Duluth, and is located at least 1/4 mile from any residence or public roadway, and the industrial process equipment is controlled by control equipment which has a collection efficiency of 85% by weight, this direct heating equipment is considered to be in compliance with this requirement. [Minn. R. 7011.0610, subp. 1(A)(1), Minn. R. 7011.0715, subp. 3]

COMG 03 GP008 Opacity <= 20 percent opacity except for one six-minute period per hour of not more than 60 percent opacity. [Minn. R. 7011.0610, subp. 1(A)(2)]

COMG 03 GP008 Fuel type: Limited to natural gas only, by design. [Minn. R. 7005.0100, subp. 35a]

COMG 03 GP008

The Permittee shall operate and maintain each dryer 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. [Minn. R. 7007.0800, subp. 14]

COMG 03 GP008

Vent all emissions to a regenerative thermal oxidizer meeting the permit requirements for TREA 8 whenever EQUI 47 and/or EQUI 48 are operated. See TREA 8 for operation and maintenance requirements for the regenerative thermal oxidizer. See STRU 16 for emission limits and testing requirements. [Title I Condition: 40 CFR 63.2, Title I Condition: Avoid major source under 40 CFR 52.21(b)(1)(i) and Minn. R. 7007.3000]

COMG 05 GP010 Opacity <= 20 percent opacity once operating temperatures have been attained. This limit applies to each generator individually. [Minn. R. 7011.2300, subp. 1]

COMG 05 GP010

Sulfur Dioxide <= 0.50 pounds per million Btu heat input. The potential to emit from each unit is 0.051 lb/MMBtu due to equipment design and allowable fuels. This limit applies to each engine individually. [Minn. R. 7011.2300, subp. 2]

COMG 05 GP010

Operating Hours <= 140 hours per year 12-month rolling sum for each generator. The sum is to be calculated by the 15th day of each month. [Title I Condition: Avoid major source under 40 CFR 52.21(b)(1)(i) and Minn. R. 7007.3000]

COMG 05 GP010 Fuel type: No. 2 fuel oil only. [Minn. R. 7005.0100, subp. 35a]

COMG 05 GP010

Daily Recordkeeping for Hours of Operation Limit: The Permittee shall record each day of operation, the number of hours of operation of each generator using a non-resettable running time meter. [Title I Condition: Avoid major source under 40 CFR 52.21(b)(1)(i) and Minn. R. 7007.3000]

COMG 05 GP010

Diesel Fuel Certification: The Permittee shall obtain a certification for each diesel fuel delivery from the fuel supplier specifying the actual sulfur content in percent by weight, or guaranteeing that the sulfur content does not exceed 0.0015 percent or 15 parts per million by weight. [40 CFR 80.510(b), Minn. R. 7007.0800, subps. 4-5]

COMG 05 GP010 The Permittee shall keep records of fuel type and usage on a monthly basis. [Minn. R. 7007.0800,

subp. 5]

COMG 05 GP010

Performance Testing Recordkeeping: During each performance test the Permittee shall record and maintain the process and control parameters as detailed in Appendix C. These records shall be included with the performance test results and submitted to the Commissioner with the performance test report. [Minn. R. 7007.0800, subps. 4 & 5, Minn. R. 7017.2020, subp. 1]

COMG 05 GP010

NESHAP SUBP. ZZZZ REQUIREMENTS Note: This standard is not delegated to the MPCA. Carbon Monoxide <= 23.0 parts per million volumetric dry at 15 percent oxygen; OR reduce Carbon Monoxide emissions by 70 percent or more from the control inlet to the control outlet. [40 CFR 63.6603(a), 40 CFR pt. 63, subp. ZZZZ (Table 2d), Minn. R. 7011.8150]

COMG 05 GP010

Compliance with the numerical emission limitations established in 40 CFR pt. 63, subp. ZZZZ is based on the results of testing the average of three 1-hour runs using the testing requirements and procedures in 40 CFR Section 63.6620 and 40 CFR pt. 63, subp. ZZZZ, Table 4. [40 CFR 63.6603, 40 CFR pt. 63, subp. ZZZZ (Table 4), Minn. R. 7011.8150]

COMG 05 GP010

Permitted Fuel Type: Diesel fuel must meet the requirements of 40 CFR Section 80.510(b). Diesel fuel must have a maximum annual average sulfur content of 0.0015 percent or 15 parts per million by weight, and either a minimum cetane index of 40 or a maximum aromatic content of 35 volume percent. This sulfur content limit is more stringent than 40 CFR Section 72.7(a)(2) and (3), which sets the maximum annual sulfur content at 0.05 percent or 500 parts per million by weight. [40 CFR 63.6604(a), 40 CFR 80.510(b), Minn. R. 7011.8150]

COMG 05 GP010 The Permittee shall be in compliance with the emission limitations and operating limitations in this subpart that apply at all times. [40 CFR 63.6605(a), Minn. R. 7011.8150]

COMG 05 GP010

At all times, the Permittee shall operate and maintain any affected source, including associated air pollution control equipment and monitoring equipment, in a manner consistent with safety and good air pollution control practices for minimizing emissions. The general duty to minimize emissions does not require the Permittee to make any further efforts to reduce emissions if levels required by this standard have been achieved. Determination of whether such operation and maintenance procedures are being used will be based on information available to the Administrator which may include, but is not limited to, monitoring results, review of operation and maintenance procedures, review of operation and maintenance records, and inspection of the source. [40 CFR 63.6605(b), Minn. R. 7011.8150]

COMG 05 GP010

The Permittee shall minimize the engines' time spent at idle during startup and minimize the engines' startup time to a period needed for appropriate and safe loading of the engines, not to exceed 30 minutes. After which time the emissions standards applicable to all times other than startup in Table 2d of 40 CFR pt. 63, subp. ZZZZ apply. [40 CFR 63.6625(h), Minn. R. 7011.8150]

COMG 05 GP010

The Permittee shall determine compliance with the percent reduction requirement according to the procedures in 40 CFR Section 63.6620(e)(1). The Permittee shall normalize the carbon monoxide concentrations at the inlet and outlet of the control device to a dry basis and to 15 percent oxygen, or an equivalent percent carbon dioxide. If pollutant concentrations are to be corrected to 15 percent oxygen and carbon dioxide concentration is measured in lieu of oxygen concentration measurement, a carbon dioxide correction factor is needed. The Permittee shall calculate the carbon dioxide correction factor as described in paragraphs (e)(2)(i) through (iii) of 40 CFR Section 63.6620. [40 CFR 63.6620(e), Minn. R. 7011.8150]

COMG 05 GP010

MONITORING AND RECORDKEEPING REQUIREMENTS (ZZZZ) The Permittee shall operate and maintain a continuous parameter monitoring system (CPMS) according to the following requirements: 1. The Permittee shall prepare a site-specific monitoring plan that addresses the monitoring system design, data collection, and the quality assurance and quality control elements outlined in paragraphs (b)(1)(i) through (v) of 40 CFR Section 63.6625(b) and in 40 CFR Section 63.8(d). 2. The Permittee shall install, operate, and maintain each CPMS in continuous operation according to the procedures in the site-specific monitoring plan. 3. The CPMS shall collect data at least once every 15 minutes. 4. For a CPMS for measuring temperature range, the temperature sensor shall have a minimum tolerance of 5.0 degrees Fahrenheit or 1 percent of the measurement range, whichever is larger. 5. The Permittee shall conduct the CPMS equipment

performance evaluation, system accuracy audits, or other audit procedures specified in the site-specific monitoring plan at least annually. 6. The Permittee shall conduct a performance evaluation of each CPMS in accordance with the site-specific monitoring plan. [40 CFR 63.6625(b), 40 CFR pt. 63, subp. ZZZZ (Table 5), Minn. R. 7011.8150]

COMG 05 GP010

The Permittee shall monitor and collect data according to the requirements of 40 CFR Section 63.6635. Except for monitor malfunctions, associated repairs, and required quality assurance or control activities, the Permittee shall monitor continuously at all times that the stationary RICE is operating. The Permittee may not use data recorded during monitoring malfunctions, associated repairs, and required quality assurance or control activities in data averages and calculations used to report emission or operating levels. The Permittee shall use all the valid data collected during all other periods. [40 CFR 63.6635, Minn. R. 7011.8150]

COMG 05 GP010

Upon promulgation of a performance specification for the CPMS, the Permittee shall comply with the quality control provisions in 40 CFR Section 63.8(d) and shall conduct the required performance evaluation in 40 CFR Section 63.8(e), unless an alternative monitoring method has been approved under the provisions of 40 CFR Section 63.8(f). [40 CFR 63.8(a)(2)]

COMG 05 GP010

The Permittee shall maintain the following records: 1. A copy of each notification and report submitted to comply with 40 CFR pt. 63, subp. ZZZZ, including all documentation supporting any Initial Notification or Notification of Compliance Status submitted, according to the requirement in 40 CFR Section 63.10(b)(2)(xiv). 2. Records of the occurrence and duration of each malfunction of operation or the air pollution control and monitoring equipment. 3. Records of performance tests and performance evaluations as required in 40 CFR Section 63.10(b)(2)(viii). 4. Records of all required maintenance performed on the air pollution control and monitoring equipment. 5. Records of actions taken during periods of malfunction to minimize emissions in accordance with 40 CFR Section 63.6605(b), including corrective actions to restore malfunctioning process and air pollution control and monitoring equipment to its normal or usual manner of operation. [40 CFR 63.6655(a), Minn. R. 7011.8150]

COMG 05 GP010

The Permittee shall maintain the following records: 1. Records described in 40 CFR Section 63.10(b)(2)(vi) - (xi). 2. Previous (i.e. superseded) versions of the performance evaluation plan as required in 40 CFR Section 63.8(d)(3). 3. Requests for alternatives to the relative accuracy test for CEMS or CPMS as required in 40 CFR Section 63.8(f)(6)(i), if applicable. [40 CFR 63.6655(b), Minn. R. 7011.8150]

COMG 05 GP010

The Permittee shall maintain, at a minimum, the following information: 1. Each period during which a CMS is malfunctioning or inoperative, including out-of-control periods; 2. All required measurements needed to demonstrate compliance with a relevant standard; 3. All results of performance tests, CMS performance evaluations, and opacity and visible emission observations; 4. All measurements as may be necessary to determine the conditions of performance tests and performance evaluations; 5. All CMS calibration checks; 6. All adjustments and maintenance performed on CMS; 7. Any information demonstrating whether a source is meeting the requirements for a waiver of recordkeeping or reporting requirements under 40 CFR pt. 63, subp. A if the Permittee has been granted a waiver under paragraph (f) of this Section; 8. All emission levels relative to the criterion for obtaining permission to use an alternative to the relative accuracy test, if the source has been granted such permission under 40 CFR Section 63.8(f)(6); and 9. All documentation supporting initial notifications and notifications of compliance status under 40 CFR Section 63.9. [40 CFR 63.10(b)(2), Minn. R. 7019.0100, subp. 2(B)]

COMG 05 GP010

The Permittee shall maintain all records in a form suitable and readily available for expeditious review according to 40 CFR Section 63.10(b)(1). The Permittee shall keep each record for 5 years following the date of each occurrence, measurement, maintenance, corrective action, report, or record. The Permittee shall keep each record readily accessible in hard copy or electronic form for at least 5 years after the date of each occurrence, measurement, maintenance, corrective action, report, or record, according to 40 CFR Section 63.10(b)(1). [40 CFR 63.10(b)(1), Minn. R. 7019.0100, subp. 2(B)]

COMG 05 GP010

REPORTING AND NOTIFICATION REQUIREMENTS (ZZZZ) The Permittee shall submit all of the notifications in 40 CFR Section 63.7(b) and (c), 63.8(e), (f)(4) and (f)(6), 63.9(b)-(e), (g), and (h) that apply by the dates specified. [40 CFR 63.6645(a), Minn. R. 7011.8150]

COMG 05 GP010 The Permittee shall submit each report in Table 7 of 40 CFR pt. 63, subp. ZZZZ, as applicable. [40 CFR 63.6650(a), 40 CFR pt. 63, subp. ZZZZ (Table 7), Minn. R. 7011.8150]

COMG 05 GP010 The Semiannual Compliance report shall contain the information in paragraphs (c)(1) through (c)(6) of 40 CFR Section 63.6650. [40 CFR 63.6650(c), Minn. R. 7011.8150]

COMG 05 GP010

For each deviation from an emission or operating limitation that occurs, the Compliance report shall contain the information in paragraphs (c)(1), (c)(4), (e)(1), and (e)(12) of 40 CFR Section 63.6650. [40 CFR 63.6650(e), Minn. R. 7011.8150]

COMG 05 GP010 The Permittee shall report all deviations as defined in 40 CFR pt. 63, subp. ZZZZ in the semiannual monitoring report required by 40 CFR 70.6(a)(3)(iii)(A). [40 CFR 63.6650(f), Minn. R. 7011.8050]

COMG 05 GP010

The Permittee shall report each instance in which the stationary RICE did not meet each applicable emission limitation or operating limitation. These instances are deviations from the emission and operating limitations. These deviations shall be reported according to the requirements in 40 CFR Section 63.6650. [40 CFR 63.6640(b), Minn. R. 7011.8150]

COMG 05 GP010

The Permittee shall submit a Compliance Report semiannually according to the requirements in 40 CFR Section 63.6650(b) with the following contents: 1. If there are no deviations from any applicable emission limitations or operating limitations, a statement that there were no deviations from the emission limitations or operating limitations during the reporting period. If there were no periods during which the CMS, including CEMS and CPMS, was out-of-control, as specified in 40 CFR Section 63.8(c)(7), a statement that there were not periods during which the CMS was out-of-control during the reporting period; OR 2. If there was a deviation from any emission limitation or operating limitation during the reporting period, the information in 40 CFR Section 63.6650(d). If there were periods during which the CMS, including CEMS and CPMS, was out-of-control, as specified in 40 CFR Section 63.8(c)(7), the information in 40 CFR Section 63.6650(e); OR 3. If there was a malfunction during the reporting period, the information in 40 CFR Section 63.6650(c)(4). [40 CFR 63.6650(a), 40 CFR pt. 63, subp. ZZZZ(Table 7), Minn. R. 7011.8150]

COMG 05 GP010

The Permittee shall report each instance when the applicable requirements in Table 8 of 40 CFR pt. 63, subp. ZZZZ were not met. [40 CFR 63.6640(e), 40 CFR pt. 63, subp. ZZZZ (Table 8), Minn. R. 7011.8150]

COMG 06 GP003

The Permittee shall vent all emissions from each COMG 6 emission unit to a wet scrubber meeting the permit requirements for TREA 7 whenever COMG 6 emission units operate, AND vent all emissions from the wet scrubber to a regenerative thermal oxidizer meeting the permit requirements for TREA 8 whenever COMG 6 emission units operate, except as provided below under "Alternative Operating Scenario One" and "Alternative Operating Scenario Two". See wet scrubber (TREA 7) and regenerative thermal oxidizer (TREA 8) for operation and maintenance requirements for the scrubber and regenerative thermal oxidizer. [Title I Condition: Avoid major source under 40 CFR 52.21(b)(1)(i) and Minn. R. 7007.3000, Title I Condition: Avoid major source under 40 CFR 63.2]

COMG 06 GP003

The Permittee may only operate under one Alternative Operating Scenario at any given time. At all times, the Permittee shall: 1) Vent emissions from each COMG 6 emission unit to a wet scrubber meeting the permit requirements for TREA 7 whenever COMG 6 emission units operate, OR 2) Vent emissions from each COMG 6 emission unit to a regenerative thermal oxidizer meeting the permit requirements for TREA 8 whenever COMG 6 emission units operate. [Title I Condition:

Avoid major source under 40 CFR 52.21(b)(1)(i) and Minn. R. 7007.3000, Title I Condition: Avoid major source under 40 CFR 63.2]

COMG 06 GP003

ALTERNATIVE OPERATING SCENARIO ONE: Operating Hours <= 500 hours per year 12-month rolling sum of bypassing the regenerative thermal oxidizer and sending emissions to STRU 15 from some or all of COMG 6. The Permittee may bypass the regenerative thermal oxidizer only during periods of maintenance or breakdown of the regenerative thermal oxidizer or associated equipment. [Title I Condition: Avoid major source under 40 CFR 52.21(b)(1)(i) and Minn. R. 7007.3000, Title I Condition: Avoid major source under 40 CFR 63.2]

COMG 06 GP003

While using Alternative Operating Scenario One, the Permittee shall vent all emissions from each COMG 6 emission unit to a wet scrubber meeting the permit requirements for TREA 7 whenever COMG 6 emission units operate, and operate and maintain a wet scrubber meeting the requirements of TREA 7 at all times that any emissions are vented to a wet scrubber meeting the requirements of TREA 7. The Permittee shall document periods of non-operation of the control equipment. See TREA 7 for operation and maintenance requirements for the scrubber. [Minn. R. 7007.0800, subps. 2 & 14, Title I Condition: Avoid major source under 40 CFR 52.21(b)(1)(i) and Minn. R. 7007.3000, Title I Condition: Avoid major source under 40 CFR 63.2]

COMG 06 GP003

Daily Recordkeeping for Alternative Operating Scenario One: The Permittee shall daily record the hours of and reasons for bypassing the regenerative thermal oxidizer with some or all of the emissions from COMG 6 emission units. [Minn. R. 7007.0800, subps. 4-5, Title I Condition: Avoid major source under 40 CFR 52.21(b)(1)(i) and Minn. R. 7007.3000, Title I Condition: Avoid major source under 40 CFR 63.2]

COMG 06 GP003

Monthly Recordkeeping: By the 15th day of each month, the Permittee shall calculate and record the following: 1) The total hours bypassing the regenerative thermal oxidizer for the previous calendar month. 2) The 12-month rolling sum of hours bypassed for the previous 12-month period by summing the monthly hours bypassed data for the previous 12 months. [Minn. R. 7007.0800, subps. 4-5, Title I Condition: Avoid major source under 40 CFR 52.21(b)(1)(i) & Minn. R. 7007.3000, Title I Condition: Avoid major source under 40 CFR 63.2]

COMG 06 GP003

ALTERNATIVE OPERATING SCENARIO TWO: Operating Hours <= 100 hours per year 12-month rolling sum of bypassing the wet scrubber and sending emissions from some or all of COMG 6 directly to a regenerative thermal oxidizer meeting the permit requirements for TREA 8. The Permittee may bypass the wet scrubber and send COMG 6 emissions directly to the RTO only during periods of maintenance or breakdown of the wet scrubber or associated equipment. [Title I Condition: Avoid major source under 40 CFR 52.21(b)(1)(i) and Minn. R. 7007.3000, Title I Condition: Avoid major source under 40 CFR 63.2]

COMG 06 GP003

While using Alternative Operating Scenario Two, the Permittee shall vent all emissions from each COMG 6 emission unit to a regenerative thermal oxidizer meeting the permit requirements for TREA 8 whenever COMG 6 emission units operate, and operate and maintain a regenerative thermal oxidizer meeting the permit requirements for TREA 8 at all times that any emissions are vented to a regenerative thermal oxidizer meeting the permit requirements for TREA 8. The Permittee shall document periods of non-operation of the control equipment. See TREA 8 for operation and maintenance requirements for the scrubber. [Minn. R. 7007.0800, subps. 4-5, Title I Condition: Avoid major source under 40 CFR 52.21(b)(1)(i) and Minn. R. 7007.3000, Title I Condition: Avoid major source under 40 CFR 63.2]

COMG 06 GP003

Daily Recordkeeping for Alternative Operating Scenario Two: The Permittee shall daily record the hours of and reasons for bypassing the wet scrubber with some or all of the emissions from COMG 6 emission units. [Minn. R. 7007.0800, subps. 4-5, Title I Condition: Avoid major source under 40 CFR 52.21(b)(1)(i) and Minn. R. 7007.3000, Title I Condition: Avoid major source under 40 CFR 63.2]

COMG 06 GP003

Monthly Recordkeeping: By the 15th day of each month, the Permittee shall calculate and record the following: 1) The total hours bypassing the wet scrubber for the previous calendar month. 2) The 12-month rolling sum of hours bypassed for the previous 12-month period by summing the monthly hours bypassed data for the previous 12 months. [40 CFR 63.2, Minn. R. 7007.0800, subps. 4-5, Title I Condition: Avoid major source under 40 CFR 52.21(b)(1)(i) and Minn. R. 7007.3000]

EQUI 01 EU001

Receiving area: Permittee shall keep at least one door to the grain receiving area closed while receiving grain. [Title I Condition: Avoid major source under 40 CFR 52.21(b)(1)(i) and Minn. R. 7007.3000]

EQUI 01 EU001

The Permittee shall vent emissions from EQUI 1 to a fabric filter meeting the permit requirements for TREA 1 whenever EQUI 1 is operated, and operate and maintain a fabric filter meeting the requirements of TREA 1 at all times that any emissions are vented to a fabric filter meeting the requirements of TREA 1. The Permittee shall document periods of non-operation of the control equipment. See TREA 1 for requirements for fabric filter operation and maintenance. [Minn. R. 7007.0800, subps. 2 & 14, Title I Condition: Avoid major source under 40 CFR 52.21(b)(1)(i) and Minn. R. 7007.3000]

EQUI 02 EU002

Loadout area: Permittee shall keep at least one door to the DDGS loadout area closed while loading DDGS. [Title I Condition: Avoid major source under 40 CFR 52.21(b)(1)(i) and Minn. R. 7007.3000]

EQUI 02 EU002

The Permittee shall vent emissions from EQUI 2 to a fabric filter meeting the permit requirements for TREA 1 whenever EQUI 2 is operated, and operate and maintain a fabric filter meeting the requirements of TREA 1 at all times that any emissions are vented to a fabric filter meeting the requirements of TREA 1. The Permittee shall document periods of non-operation of the control equipment. See TREA 1 for requirements for fabric filter operation and maintenance. [Minn. R. 7007.0800, subps. 2 & 14, Title I Condition: Avoid major source under 40 CFR 52.21(b)(1)(i) and Minn. R. 7007.3000]

EQUI 50 EU043

The Permittee shall vent all emissions from EQUI 50 to a fabric filter meeting the permit requirements for TREA 11 whenever EQUI 50 is operated, and operate and maintain a fabric filter meeting the requirements of TREA 11 at all times that any emissions are vented to a fabric filter meeting the requirements of TREA 11. The Permittee shall document periods of non-operation of the control equipment. [Minn. R. 7007.0800, subps. 2 & 14, Title I Condition: Avoid major source under 40 CFR 52.21(b)(1)(i) and Minn. R. 7007.3000]

EQUI 50 EU043

Notwithstanding the Alternative Operating Scenario below, vent all emissions to the dryer burners (EQUI 47 and EQUI 48) and/or auxiliary boiler burners (EQUI 53 and EQUI 61). See dryer burners (EQUI 47 and EQUI 48) and auxiliary boiler burners (EQUI 53 and EQUI 61) for operation and maintenance requirements for the dryer and auxiliary boiler. [Title I Condition: Avoid major source under 40 CFR 52.21(b)(1)(i) and Minn. R. 7007.3000, Title I Condition: Avoid major source under 40 CFR 63.2]

EQUI 50 EU043

Operating Hours <= 500 hours per year 12-month rolling sum of bypassing the dryer burner (EQUI 47 and EQUI 48) and/or the auxiliary boiler burners (EQUI 53 and EQUI 61) with emissions from the fluid bed cooler. [Title I Condition: Avoid major source under 40 CFR 52.21(b)(1)(i) and Minn. R. 7007.3000, Title I Condition: Avoid major source under 40 CFR 63.2]

EQUI 50 EU043

Daily Recordkeeping: The Permittee shall daily record the hours of and reasons for bypassing the dryer burners (EQUI 47 and EQUI 48) and the auxiliary boiler burners (EQUI 53 and EQUI 61) with some or all of the emissions from the fluid bed cooler (EQUI 50). [Title I Condition: Avoid major source under 40 CFR 52.21(b)(1)(i) and Minn. R. 7007.3000, Title I Condition: Avoid major source under 40 CFR 63.2]

EQUI 50 EU043

Monthly Recordkeeping: By the 15th day of each month, the Permittee shall calculate and record the following: 1) The total hours bypassing the RTO for the previous calendar month. 2) The 12-month rolling sum of hours bypassed for the previous 12-month period by summing the monthly hours bypassed data for the previous 12 months. [Minn. R. 7007.0800, subps. 4-5]

EQUI 55 EU048

When loading ethanol to trucks, the Permittee shall vent all emissions to a flare meeting the requirements of TREA 14 except as described herein. The Permittee may load up to 5,000,000 gallons of ethanol in any 12-month period into non-dedicated, noncontrolled trucks during periods of breakdown or maintenance of the ethanol loadout rack. See TREA 14 for requirements for the flare. [Title I Condition: Avoid major source under 40 CFR 52.21(b)(1)(i) and Minn. R. 7007.3000, Title I Condition: Avoid major source under 40 CFR 63.2]

EQUI 55 EU048

All rail cars must be dedicated fleet (carry only ethanol). No loadout controls are required for dedicated fleet rail cars. To be considered dedicated, the rail cars must be placarded as ethanol transportation cars. [Title I Condition: Avoid major source under 40 CFR 52.21(b)(1)(i) and Minn. R. 7007.3000, Title I Condition: Avoid major source under 40 CFR 63.2]

EQUI 55 EU048

Daily Recordkeeping: The Permittee shall maintain a daily record of the number of number of gallons of denatured ethanol loaded into non-dedicated, uncontrolled trucks. [Title I Condition: Avoid major source under 40 CFR 52.21(b)(1)(i) and Minn. R. 7007.3000, Title I Condition: Avoid major source under 40 CFR 63.2]

EQUI 55 EU048

Monthly Recordkeeping: By the 15th day of each month, the Permittee shall calculate and record the number of gallons loaded into non-dedicated, noncontrolled trucks for the previous month, and the previous 12-month period. [Minn. R. 7007.0800, subps. 4-5, Title I Condition: Avoid major source under 40 CFR 52.21(b)(1)(i), Title I Condition: Avoid major source under 40 CFR 63.2]

EQUI 56 EU049

EQUI 56 is an existing affected source under 40 CFR pt. 63, subp. ZZZZ - National Emission Standards for Hazardous Air Pollutants: Stationary Reciprocating Internal Combustion Engines. EQUI 56 is a non-emergency, non-limited use compression ignited engine with a site rating greater than 500 brake-horsepower (bhp). The Permittee shall comply with the applicable emission limitations and operating limitations in this subpart after the compliance date of May 13, 2013. See COMG 5 for further requirements for EQUI 56. [40 CFR 63.6585(c), Minn. R. 7011.8150]

EQUI 56 EU049

The Permittee shall demonstrate continuous compliance with the requirements of 40 CFR pt. 63, subp. ZZZZ by: 1. Conducting performance tests for Carbon Monoxide every 8,760 hours of engine operation or 3 years, whichever comes first. 2. Conducting performance tests for Carbon Monoxide, to demonstrate that the required 70 percent reduction is achieved or that emissions remain at or below the 23 parts per million, dry volumetric concentration limit. 3. Maintaining monthly records of engine operating hours and a sum of engine operating hours for the calendar year. 4. Collecting the catalyst inlet temperature data according to 40 CFR Section 63.6625(b). 5. Reducing the data to 4-hour rolling averages. 6. Maintaining the 4-hour rolling averages within the operating limitations for the catalyst inlet temperature. 7. Measuring the pressure drop across the catalyst once per month and demonstrating that the pressure drop across the catalyst is within the operating limitation established during the performance test for Carbon Monoxide. [40 CFR 63.6604(a), 40 CFR pt. 63, subp. ZZZZ (Table 6), Minn. R. 7011.8150]

EQUI 56 EU049

The Permittee shall conduct a performance test : Due before 09/05/2016 or after 8,760 hours of individual engine operation following the initial performance test, whichever comes first. EQUI 56 shall be tested to determine the carbon monoxide reduction or carbon monoxide concentration according to the requirements of 40 CFR pt. 63, subp. ZZZZ, Tables 3 and 4, and 40 CFR Section 63.6620. The performance tests shall be conducted at worst case conditions as defined at Minn. R. 7017.2005, subp. 8, and as identified in Appendix C of this permit using EPA Reference Method 10, or another method approved by MPCA in the performance test plan approval. [40 CFR 63.6615, 40 CFR pt. 63, subp. ZZZZ (Table 3), Minn. R. 7011.8150]

EQUI 56 EU049

The engine percent load during a performance test shall be determined by documenting the calculations, assumptions, and measurement devices used to measure or estimate the percent load in a specific application. A written report of the average percent load determination shall be included in the notification of compliance status. The following information shall be included in the written report: the engine model number, the engine manufacturer, the year of purchase, the manufacturer's site-rated brake horsepower, the ambient temperature, pressure, and humidity during the performance test, and all assumptions that were made to estimate or calculate percent load during the performance test shall be clearly explained. If measurement devices such as flow

meters, kilowatt meters, beta analyzers, strain gauges, etc. are used, the model number of the measurement device and an estimate of its accuracy in percentage of true value shall be provided. [40 CFR 63.6620(i), Minn. R. 7011.8150]

EQUI 57 EU050


EQUI 57 EU050


EQUI 57 EU050


EQUI 57 EU050

The engine percent load during a performance test shall be determined by documenting the calculations, assumptions, and measurement devices used to measure or estimate the percent load in a specific application. A written report of the average percent load determination shall be included in the notification of compliance status. The following information shall be included in the written report: the engine model number, the engine manufacturer, the year of purchase, the manufacturer's site-rated brake horsepower, the ambient temperature, pressure, and humidity during the performance test, and all assumptions that were made to estimate or calculate percent load during the performance test shall be clearly explained. If measurement devices such as flow meters, kilowatt meters, beta analyzers, strain gauges, etc. are used, the model number of the measurement device and an estimate of its accuracy in percentage of true value shall be provided. [40 CFR 63.6620(i), Minn. R. 7011.8150]

EQUI 58 EU051


EQUI 58 EU051


EQUI 58 EU051


EQUI 58 EU051

The engine percent load during a performance test shall be determined by documenting the calculations, assumptions, and measurement devices used to measure or estimate the percent load in a specific application. A written report of the average percent load determination shall be included in the notification of compliance status. The following information shall be included in the written report: the engine model number, the engine manufacturer, the year of purchase, the manufacturer's site-rated brake horsepower, the ambient temperature, pressure, and humidity during the performance test, and all assumptions that were made to estimate or calculate percent load during the performance test shall be clearly explained. If measurement devices such as flow meters, kilowatt meters, beta analyzers, strain gauges, etc. are used, the model number of the measurement device and an estimate of its accuracy in percentage of true value shall be provided. [40 CFR 63.6620(i), Minn. R. 7011.8150]

EQUI 73 802 (TK 002) Opacity <= 20 percent opacity. [Minn. R. 7011.0715, subp. 1(B)]

EQUI 73 802 (TK 002)

Total Particulate Matter <= 0.30 grains per 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. [Minn. R. 7011.0715, subp. 1(A)]

EQUI 74 801 (TK 001) Opacity <= 20 percent opacity. [Minn. R. 7011.0715, subp. 1(B)]

EQUI 74 801 (TK 001)

Total Particulate Matter <= 0.30 grains per 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. [Minn. R. 7011.0715, subp. 1(A)]

EQUI 80 EU065

Clean up commodities spilled on the driveway and other facility property as required to minimize fugitive emissions to a level consistent with reasonably available control technology. [Minn. R. 7011.1005, subp. 1(A)]

EQUI 80 EU065 Opacity <= 5 percent opacity for uncaptured emissions from any truck or railcar unloading station. [40 CFR 60.302(c)(1), Minn. R. 7011.1005, subp. 2]

EQUI 80 EU065

NSPS General Provisions The Permittee shall submit a notification of any physical or operational change which increases emission rate: due 60 days (or as soon as practical) before the change is commenced and shall include information describing the precise nature of the change, present and proposed emission control systems, productive capacity of the facility before and after the change, and the expected completion date of the change. [40 CFR 60.7(a)(4), Minn. R. 7019.0100, subp. 1]

EQUI 80 EU065

Recordkeeping: Maintain a file of all measurements, maintenance, reports and records for at least five years. This is more stringent than 40 CFR Section 60.7(f) which specifies a minimum of two years. [40 CFR 60.7(f), Minn. R. 7007.0800, subp. 5(C), Minn. R. 7019.0100, subp. 1]

EQUI 80 EU065

No owner or operator shall build, erect, install, or use any article, machine, equipment or process, the use of which conceals an emission which would otherwise constitute a violation of an applicable standard. Such concealment includes, but is not limited to, the use of gaseous diluents to achieve compliance with an opacity standard or with a standard which is based on the concentration of a pollutant in the gases discharged to the atmosphere. [40 CFR 60.12, Minn. R. 7011.0050]

EQUI 80 EU065

At all times, including periods of startup, shutdown, and malfunction, the Permittee shall, to the extent practicable, maintain and operate any affected facility including associated air pollution control equipment in a manner consistent with good air pollution control practice for minimizing emissions. Determination of whether acceptable operating and maintenance procedures are being used will be based on information available to the Administrator which may include, but is not limited to, monitoring results, opacity observations, review of operating and maintenance procedures, and inspection of the source. [40 CFR 60.11(d), Minn. R. 7017.2015]

EQUI 80 EU065

The Permittee shall maintain a file of all measurements, including performance testing measurements and all other information required by 40 CFR pt. 60 recorded in a permanent form suitable for inspection. The file shall be retained for at least two years following the date of such measurements, maintenance, reports, and records. [40 CFR 60.7(f), Minn. R. 7019.0100]

EQUI 80 EU065

Compliance with opacity standards in this part shall be determined by conducting observations in accordance with Method 9 in appendix A of this part. For purposes of determining initial compliance, the minimum total time of observations shall be 3 hours (30 6-minute averages) for the performance test or other set of observations (meaning those fugitive-type emission sources subject only to an opacity standard). [40 CFR 60.11, Minn. R. 7011.2015]

EQUI 80 EU065

Any physical or operational change to an existing facility which results in an increase in the emission rate to the atmosphere of any pollutant to which a standard applies shall be considered a modification within the meaning of section 111 of the Act. Upon modification, an existing facility shall become an affected facility for each pollutant to which a standard applies and for which there is an increase in the emission rate to the atmosphere. The addition of an affected facility to a stationary source as an expansion to that source or as a replacement for an existing facility shall not by itself bring within the applicability of this part any other facility within that source. [40 CFR 60.14(a-c), Minn. R. 7011.0050]

EQUI 81 EU066

Clean up commodities spilled on the driveway and other facility property as required to minimize fugitive emissions to a level consistent with reasonably available control technology. [Minn. R. 7011.1005, subp. 1(A)]

EQUI 81 EU066 Opacity <= 10 percent opacity from DDGS loading station. [Minn. R. 7011.1005, subp. 3(B)]

FUGI 03 FS001

Fugitive Emissions: Do not cause or permit the transporting of any material in a manner which may allow avoidable amounts of particulate matter to become airborne. Do not cause or permit a road or a driveway to be constructed, used, repaired, or demolished without applying all such reasonable measures as may be required to prevent particulate matter from becoming airborne. [Minn. R. 7011.0150]

FUGI 03 FS001 Abide by Fugitive Dust Control Plan in Appendix B of this permit. [Minn. R. 7011.0150]

FUGI 04 FS003

Notification of any physical or operational change which increases emission rate: due 60 days (or as soon as practical) before the change is commenced. [40 CFR 60.7(a)(4), Minn. R. 7019.0100, subp. 1]

FUGI 04 FS003

Recordkeeping: Maintain records of the occurrence and duration of any startup, shutdown, or malfunction in the operation of the facility including; any malfunction of the air pollution control equipment; or any periods during which a continuous monitoring system or monitoring device is inoperative. [40 CFR 60.7(b), Minn. R. 7019.0100, subp. 1]

FUGI 04 FS003

Recordkeeping: Maintain a file of all measurements, maintenance, reports and records for at least five years. 40 CFR Section 60.7(f) specifies two years. [40 CFR 60.7(f), Minn. R. 7007.0800, subp. 5(C), Minn. R. 7019.0100, subp. 1]

FUGI 04 FS003

No owner or operator shall build, erect, install, or use any article, machine, equipment or process, the use of which conceals an emission which would otherwise constitute a violation of an applicable standard. [40 CFR 60.12, Minn. R. 7011.0050]

FUGI 04 FS003

Each owner or operator subject to the provisions of this subpart shall demonstrate compliance with the requirements of 40 CFR Sections 60.482-1a through 60.482-10a or Section 60.480a(e) for all equipment within 180 days of initial startup. [40 CFR 60.482-1a(a)]

FUGI 04 FS003

(g) If the storage vessel is shared with multiple process units, the process unit with the greatest annual amount of stored materials (predominant use) is the process unit the storage vessel is assigned to. If the storage vessel is shared equally among process units, and one of the process units has equipment subject to this subpart, the storage vessel is assigned to that process unit. If the storage vessel is shared equally among process units, none of which have equipment subject to this subpart of this part, the storage vessel is assigned to any process unit subject to subpart VVa of this part. If the predominant use of the storage vessel varies from year to year, then the owner or operator must estimate the predominant use initially and reassess every 3 years. The owner or operator must keep records of the information and supporting calculations that show how predominant use is determined. All equipment on the storage vessel must be monitored when in VOC service. [40 CFR 60.482-1a(g)]

FUGI 04 FS003

Pumps in light liquid service: (a)(1) Each pump in light liquid service shall be monitored monthly to detect leaks by the methods specified in Section 60.485a(b), except as provided in Section 60.482-1a(c) and (f) and paragraphs (d), (e), and (f) of this section. A pump that begins operation in light liquid service after the initial startup date for the process unit must be monitored for the first time within 30 days after the end of its startup period, except for a pump that replaces a leaking pump and except as provided in Section 60.482-1a(c) and paragraphs (d), (e), and (f) of this section. (2) Each pump in light liquid service shall be checked by visual inspection each calendar week for indications of liquids dripping from the pump seal, except as provided in Section 60.482-1a(f). [40 CFR 60.482-2a]

FUGI 04 FS003

The instrument reading that defines a leak is specified in paragraphs (b)(1)(i) and (ii) of this section. (i) 5,000 parts per million (ppm) or greater for pumps handling polymerizing monomers; (ii) 2,000 ppm or greater for all other pumps. [40 CFR 60.482-2a(b)(1)]

FUGI 04 FS003

If there are indications of liquids dripping from the pump seal, the owner or operator shall follow the procedure specified in either paragraph (b)(2)(i) or (ii) of this section. This requirement does not apply to a pump that was monitored after a previous weekly inspection and the instrument reading was less than the concentration specified in paragraph (b)(1)(i) or (ii) of this section, whichever is applicable. (i) Monitor the pump within 5 days as specified in Section 60.485a(b). A leak is detected if the instrument reading measured during monitoring indicates a leak as specified in paragraph (b)(1)(i) or (ii) of this section, whichever is applicable. The leak shall be repaired using the procedures in paragraph (c) of this section. (ii) Designate the visual indications of liquids dripping as a leak, and repair the leak using either the procedures in paragraph (c) of this section or by eliminating the visual indications of liquids dripping. [40 CFR 60.482-2a(b)(2)]

FUGI 04 FS003

(c)(1) When a leak is detected, it shall be repaired as soon as practicable, but not later than 15 calendar days after it is detected, except as provided in Section 60.482-9a. (2) A first attempt at repair shall be made no later than 5 calendar days after each leak is detected. First attempts at repair include, but are not limited to, the practices described in paragraphs (c)(2)(i) and (ii) of this section, where practicable. [40 CFR 60.482-2a(c)&(d)]

FUGI 04 FS003

(d) Each pump equipped with a dual mechanical seal system that includes a barrier fluid system is exempt from the requirements of paragraph (a) of this section, provided the requirements specified in paragraphs (d)(1) through (6) of this section are met. [40 CFR 60.482-2a(d)]

FUGI 04 FS003

(e) Any pump that is designated, as described in Section 60.486a(e)(1) and (2), for no detectable emissions, as indicated by an instrument reading of less than 500 ppm above background, is exempt from the requirements of paragraphs (a), (c), and (d) of this section if the pump: (1) Has no externally actuated shaft penetrating the pump housing; (2) Is demonstrated to be operating with no detectable emissions as indicated by an instrument reading of less than 500 ppm above background as measured by the methods specified in Section 60.485a(c); and (3) Is tested for compliance with paragraph (e)(2) of this section initially upon designation, annually, and at other times requested by the Administrator. [40 CFR 60.482-2a(e)]

FUGI 04 FS003

(f) If any pump is equipped with a closed vent system capable of capturing and transporting any leakage from the seal or seals to a process or to a fuel gas system or to a control device that complies with the requirements of Section 60.482-10a, it is exempt from paragraphs (a) through (e) of this section. [40 CFR 60.482-2a(f)]

FUGI 04 FS003

(g) Any pump that is designated, as described in Section 60.486a(f)(1), as an unsafe-to-monitor pump is exempt from the monitoring and inspection requirements of paragraphs (a) and (d)(4) through (6) of this section if: (1) The owner or operator of the pump demonstrates that the pump is unsafe-to-monitor because monitoring personnel would be exposed to an immediate danger as a consequence of complying with paragraph (a) of this section; and (2) The owner or operator of the pump has a written plan that requires monitoring of the pump as frequently as practicable during safe-to-monitor times, but not more frequently than the periodic monitoring schedule otherwise applicable, and repair of the equipment according to the procedures in paragraph (c) of this section if a leak is detected. [40 CFR 60.482-2a(g)]

FUGI 04 FS003

(h) Any pump that is located within the boundary of an unmanned plant site is exempt from the weekly visual inspection requirement of paragraphs (a)(2) and (d)(4) of this section, and the daily requirements of paragraph (d)(5) of this section, provided that each pump is visually inspected as often as practicable and at least monthly. [40 CFR 60.482-2a(h)]

FUGI 04 FS003

(a) Except during pressure releases, each pressure relief device in gas/vapor service shall be operated with no detectable emissions, as indicated by an instrument reading of less than 500 ppm above background as determined by the methods specified in 40 CFR Section 60.485a(c). [40 CFR 60.482a(a)]

FUGI 04 FS003

(b)(1) After each pressure release, the pressure relief device shall be returned to a condition of no detectable emissions, as indicated by an instrument reading of less than 500 ppm above background, as soon as practicable, but no later than 5 calendar days after the pressure release, except as provided in 40 CFR Section 60.482-9a (Delay of Repair). (b)(2) No later than 5 calendar days after the pressure release, the pressure relief device shall be monitored to confirm the conditions of no detectable emissions, as indicated by an instrument reading of less than 500 ppm above background, by the methods specified in 40 CFR Section 60.485a(c). [40 CFR 60.482a(b)]

FUGI 04 FS003

(c) Any pressure relief device that is routed to a process or fuel gas system or equipped with a closed vent system capable of capturing and transporting leakage through the pressure relief device to a control device as described in Section 60.482-10a is exempted from the requirements of paragraphs (a) and (b) of this section. (d)(1) Any pressure relief device that is equipped with a rupture disk upstream of the pressure relief device is exempt from the requirements of paragraphs (a) and (b) of this section, provided the owner or operator complies with the requirements in paragraph (d)(2) of this section. (2) After each pressure release, a new rupture disk shall be installed upstream of the pressure relief device as soon as practicable, but no later than 5 calendar days after each pressure release, except as provided in Section 60.482-9a. [40 CFR 60.482a(c)&(d)]

FUGI 04 FS003

(a) Each sampling connection system shall be equipped with a closed-purge, closed-loop, or closed-vent system, except as provided in Section 60.482-1a(c) and paragraph (c) of this section. [40 CFR 60.482-5a(a)]

FUGI 04 FS003

(b) Each closed-purge, closed-loop, or closed-vent system as required in paragraph (a) of this section shall comply with the requirements specified in paragraphs (b)(1) through (4). (1) Gases displaced during filling of the sample container are not required to be collected or captured. (2) Containers that are part of a closed-purge system must be covered or closed when not being filled or emptied. (3) Gases remaining in the tubing or piping between the closed-purge system valve(s) and sample container valve(s) after the valves are closed and the sample container is disconnected are not required to be collected or captured. (4) Each closed-purge, closed-loop, or closed-vent system shall be designed and operated to meet requirements in either paragraph (b)(4)(i), (ii), (iii), or (iv). [40 CFR 60.482-5a(b)]

FUGI 04 FS003 (c) In-situ sampling systems and sampling systems without purges are exempt from the requirements of paragraphs (a) and (b) of this section. [40 CFR 60.482-5a(c)]

FUGI 04 FS003

(a)(1) Each open-ended valve or line shall be equipped with a cap, blind flange, plug, or a second valve, except as provided Section 60.482-1a(c) and paragraphs (d) and (e) of this section. (2) The cap, blind flange, plug, or second valve shall seal the open end at all times except during operations requiring process fluid flow through the open-ended valve or line. [40 CFR 60.482-6a(a)]

FUGI 04 FS003

(b) Each open-ended valve or line equipped with a second valve shall be operated in a manner such that the valve on the process fluid end is closed before the second valve is closed. (c) When a double block-and-bleed system is being used, the bleed valve or line may remain open during operations that require venting the line between the block valves but shall comply with paragraph (a) of this section at all other times. [40 CFR 60.482-6a]

FUGI 04 FS003

(d) Open-ended valves or lines in an emergency shutdown system which are designed to open automatically in the event of a process upset are exempt from the requirements of paragraphs (a), (b), and (c) of this section. (e) Open-ended valves or lines containing materials which would autocatalytically polymerize or would present an explosion, serious overpressure, or other safety hazard if capped or equipped with a double block and bleed system as specified in paragraphs (a) through (c) of this section are exempt from the requirements of paragraphs (a) through (c) of this section. [40 CFR 60.482-6a]

FUGI 04 FS003

(a)(1) Each valve shall be monitored monthly to detect leaks by the methods specified in Section 60.485a(b) and shall comply with paragraphs (b) through (e) of this section, except as provided in paragraphs (f), (g), and (h) of this section, Section 60.482-1a(c) and (f), and Sections 60.483-1a and 60.483-2a. [40 CFR 60.482-7a(a)]

FUGI 04 FS003

(b) If an instrument reading of 500 ppm or greater is measured, a leak is detected. (c)(1)(i) Any valve for which a leak is not detected for 2 successive months may be monitored the first month of every quarter, beginning with the next quarter, until a leak is detected. (ii) As an alternative to monitoring all of the valves in the first month of a quarter, an owner or operator may elect to subdivide the process unit into two or three subgroups of valves and monitor each subgroup in a different month during the quarter, provided each subgroup is monitored every 3 months. The owner or operator must keep records of the valves assigned to each subgroup. (2) If a leak is detected, the valve shall be monitored monthly until a leak is not detected for 2 successive months. [40 CFR 60.482-7a(b)&(c)]

FUGI 04 FS003

(d)(1) When a leak is detected, it shall be repaired as soon as practicable, but no later than 15 calendar days after the leak is detected, except as provided in Section 60.482-9a. (2) A first attempt at repair shall be made no later than 5 calendar days after each leak is detected. [40 CFR 60.482-7a(d)]

FUGI 04 FS003

(e) First attempts at repair include, but are not limited to, the following best practices where practicable: (1) Tightening of bonnet bolts; (2) Replacement of bonnet bolts; (3) Tightening of packing gland nuts; (4) Injection of lubricant into lubricated packing. [40 CFR 60.482-7a(e)]

FUGI 04 FS003

(f) Any valve that is designated, as described in Section 60.486a(e)(2), for no detectable emissions, as indicated by an instrument reading of less than 500 ppm above background, is exempt from the requirements of paragraph (a) of this section if the valve: (1) Has no external actuating mechanism in contact with the process fluid, (2) Is operated with emissions less than 500 ppm above background as determined by the method specified in Section 60.485a(c), and (3) Is tested for compliance with paragraph (f)(2) of this section initially upon designation, annually, and at other times requested by the Administrator. [40 CFR 60.482-7a(f)]

FUGI 04 FS003

(g) Any valve that is designated, as described in Section 60.486a(f)(1), as an unsafe-to-monitor valve is exempt from the requirements of paragraph (a) of this section if: (1) The owner or operator of the valve demonstrates that the valve is unsafe to monitor because monitoring personnel would be exposed to an immediate danger as a consequence of complying with paragraph (a) of this section, and (2) The owner or operator of the valve adheres to a written plan that requires monitoring of the valve as frequently as practicable during safe-to-monitor times. [40 CFR 60.482-7a(g)]

FUGI 04 FS003

(h) Any valve that is designated, as described in Section 60.486a(f)(2), as described in Section 60.486a(f)(2), as a difficult-to-monitor valve is exempt from the requirements of paragraph (a) f: (1) The Permittee demonstrates that the valve cannot be monitored without elevating the monitoring personnel more than 2 meters above a support surface. (2) The process unit within which the valve is located: (i) Becomes an affected facility through Section 60.14 or 60.15 and was constructed on or before January 5, 1981; or (ii) Has less than 3.0 percent of its valves designated as difficult-to-monitor by the owner or operator. (3) The owner or operator of the valve follows a written plan that requires monitoring of the valve at least once per calendar year [40 CFR 60.482-7a(h)]

FUGI 04 FS003

(a) If evidence of a potential leak is found by visual, audible, olfactory, or any other detection method at pumps, valves, and connectors in heavy liquid service and pressure relief devices in light liquid or heavy liquid service, the owner or operator shall follow either one of the following procedures: (1) The owner or operator shall monitor the equipment within 5 days by the method specified in Section 60.485a(b) and shall comply with the requirements of paragraphs (b) through (d) of this section. (2) The owner or operator shall eliminate the visual, audible, olfactory, or other indication of a potential leak within 5 calendar days of detection. [40 CFR 60.482-8a(a)]

FUGI 04 FS003

(b) If an instrument reading of 10,000 ppm or greater is measured, a leak is detected. (c)(1) When a leak is detected, it shall be repaired as soon as practicable, but not later than 15 calendar days after it is detected, except as provided in 40 CFR Section 60.482-9a (delay of repair). (2) The first attempt at repair shall be made no later than 5 calendar days after each leak is detected. [40 CFR 60.482-8a(b)&(c)]

FUGI 04 FS003 (d) First attempts at repair include, but are not limited to, the best practices described under Sections 60.482-2a(c)(2) and 60.482-7a(e). [40 CFR 60.482-8a(d)]

FUGI 04 FS003

(a) Delay of repair of equipment for which leaks have been detected will be allowed if repair within 15 days is technically infeasible without a process unit shutdown. Repair of this equipment shall occur before the end of the next process unit shutdown. Monitoring to verify repair must occur within 15 days after startup of the process unit. (b) Delay of repair of equipment will be allowed for equipment which is isolated from the process and which does not remain in VOC service. [40 CFR 60.482-9a(a) and (b)]

FUGI 04 FS003

(c) Delay of repair for valves and connectors will be allowed if: (1) The owner or operator demonstrates that emissions of purged material resulting from immediate repair are greater than the fugitive emissions likely to result from delay of repair, and (2) When repair procedures are effected, the purged material is collected and destroyed or recovered in a control device complying with Section 60.482-10a. [40 CFR 60.482-9a(c)]

FUGI 04 FS003

(d) Delay of repair for pumps will be allowed if: (1) Repair required the use of a dual mechanical seal system that includes a barrier fluid system, and (2) Repair is completed as soon as practicable, but not later than 6 months after the leak was detected. [40 CFR 60.482-9a(d)]

FUGI 04 FS003

(e) Delay of repair beyond a process unit shutdown will be allowed for a valve, if valve assembly replacement is necessary during the process unit shutdown, valve assembly supplies have been depleted, and valve assembly supplies had been sufficiently stocked before the supplies were depleted. Delay of repair beyond the next process unit shutdown will not be allowed unless the next process unit shutdown occurs sooner than 6 months after the first process unit shutdown. (f) When delay of repair is allowed for a leaking pump, valve, or connector that remains in service, the pump, valve, or connector may be considered to be repaired and no longer subject to delay of repair requirements if two consecutive monthly monitoring instrument readings are below the leak definition. [40 CFR 60.482-9a(e) and (f)]

FUGI 04 FS003

(a) Owners or operators of closed vent systems and control devices used to comply with provisions of this subpart shall comply with the provisions of this section. (b) Vapor recovery systems (for example, condensers and absorbers) shall be designed and operated to recover the VOC emissions vented to them with an efficiency of 95 percent or greater, or to an exit concentration of 20 parts per million by volume (ppmv), whichever is less stringent. [40 CFR 60.482-10a(a)&(b)]

FUGI 04 FS003

(c) Enclosed combustion devices shall be designed and operated to reduce the VOC emissions vented to them with an efficiency of 95 percent or greater, or to an exit concentration of 20 ppmv, on a dry basis, corrected to 3 percent oxygen, whichever is less stringent or to provide a minimum residence time of 0.75 seconds at a minimum temperature of 816 deg C. (d) Flares used to comply with this subpart shall comply with the requirements of Section 60.18. (e) Owners or operators of control devices used to comply with the provisions of this subpart shall monitor these control devices to ensure that they are operated and maintained in conformance with their designs. [40 CFR 60.482-10a(c),(d),&(e)]

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(f) Except as provided in paragraphs (i) through (k), each closed vent system shall be inspected according to the procedures and schedule specified in paragraphs (f)(1) and (2). (1) If the vapor collection system or closed vent system is constructed of hard-piping, the owner or operator shall comply with the requirements specified in paragraphs (f)(1)(i) and (ii): (i) Conduct an initial inspection according to the procedures in Section 60.485a(b); and (ii) Conduct annual visual inspections for visible, audible, or olfactory indications of leaks. (2) If the vapor collection system or closed vent system is constructed of ductwork, the owner or operator shall: (i) Conduct an initial inspection according to the procedures in Section 60.485a(b); and (ii) Conduct annual inspections according to the procedures in Section 60.485a(b). [40 CFR 60.482-10a(f)]

FUGI 04 FS003

(g) Leaks, as indicated by an instrument reading greater than 500 ppmv above background or by visual inspections, shall be repaired as soon as practicable except as provided in paragraph (h) of this section. (1) A first attempt at repair shall be made no later than 5 calendar days after the leak is detected. (2) Repair shall be completed no later than 15 calendar days after the leak is detected. [40 CFR 60.482-10a(g)]

FUGI 04 FS003

(h) Delay of repair of a closed vent system for which leaks have been detected is allowed if the repair is technically infeasible without a process unit shutdown or if the owner or operator determines that emissions resulting from immediate repair would be greater than the fugitive emissions likely to result from delay of repair. Repair of such equipment shall be complete by the end of the next process unit shutdown. (i) If a vapor collection system or closed vent system is operated under a vacuum, it is exempt from the inspection requirements of paragraphs (f)(1)(i) and (f)(2) of this section. [40 CFR 60.482-10a(h)&(i)]

FUGI 04 FS003

(j) Any parts of the closed vent system that are designated, as described in paragraph (l)(1) of this section, as unsafe to inspect are exempt from the inspection requirements of paragraphs (f)(1)(i) and (f)(2) of this section if they comply with the requirements specified in paragraphs (j)(1) and (2) of this section: (1) The owner or operator determines that the equipment is unsafe to inspect because inspecting personnel would be exposed to an imminent or potential danger as a consequence of complying with paragraphs (f)(1)(i) or (f)(2) of this section; and (2) The owner or operator has a written plan that requires inspection of the equipment as frequently as practicable during safe-to-inspect times. [40 CFR 60.482-10a(j)]

FUGI 04 FS003

(k) Any parts of the closed vent system that are designated, as described in paragraph (l)(2) of this section, as difficult to inspect are exempt from the inspection requirements of paragraphs (f)(1)(i) and (f)(2) of this section if they comply with the requirements specified in paragraphs (k)(1) through (3) of this section: (1) The owner or operator determines that the equipment cannot be inspected without elevating the inspecting personnel more than 2 meters above a support surface; and (2) The process unit within which the closed vent system is located becomes an affected facility through Sections 60.14 or 60.15, or the owner or operator designates less than 3.0 percent of the total number of closed vent system equipment as difficult to inspect; and (3) The owner or operator has a written plan that requires inspection of the equipment at least once every 5 years. A closed vent system is exempt from inspection if it is operated under a vacuum. [40 CFR 60.482-10a(k)]

FUGI 04 FS003

(l) The Permittee shall record the information specified below: (1) Identification of all parts of the closed vent system that are designated as unsafe to inspect, an explanation of why the equipment is unsafe to inspect, and the plan for inspection. (2) Identification of all parts of the closed vent system that are designated as difficult to inspect, an explanation of why the equipment is difficult to inspect, and the plan for inspection. (3) For each inspection during which a leak is detected, a record of the information specified in Section 60.486a(c). (4) For each inspection during which no leaks are detected, a record of the inspection, the inspection date, and a statement that no leaks were detected. (5) For each visual inspection conducted in accordance with paragraph (f)(1)(ii) of this section during which no leaks are detected, a record of the inspection, the inspection date, and a statement that no leaks were detected. [40 CFR 60.482-10a(l)]

FUGI 04 FS003 (m) Closed vent systems and control devices used to comply with provisions of this subpart shall be operated at all times when emissions may be vented to them. [40 CFR 60.482-10a(m)]

FUGI 04 FS003

(a) The permittee shall initially monitor all connectors in the process unit for leaks by the later of either 12 months after the compliance date or 12 months after initial startup. If all connectors in the process unit have been monitored for leaks prior to the compliance date, no initial monitoring is required provided either no process changes have been made since the monitoring or the owner or operator can determine that the results of the monitoring, with or without adjustments, reliably demonstrate compliance despite process changes. If required to monitor because of a process change, the owner or operator is required to monitor only those connectors involved in the process change. [40 CFR 60.482-11a(a)]

FUGI 04 FS003

(b) Except as allowed in Section 60.482-1a(c), Section 60.482-10a, or as specified in paragraph (e) of this section, the owner or operator shall monitor all connectors in gas and vapor and light liquid service as specified in paragraphs (a) and (b)(3) of this section. (1) The connectors shall be monitored to detect leaks by the method specified in Section 60.485a(b) and, as applicable, Section 60.485a(c). (2) If an instrument reading greater than or equal to 500 ppm is measured, a leak is detected. [40 CFR 60.482-11a(b)(1) and (2)]

FUGI 04 FS003

(3) The owner or operator shall perform monitoring, subsequent to the initial monitoring required in paragraph (a) of this section, as specified in paragraphs (b)(3)(i) through (iii) of this section, and shall comply with the requirements of paragraphs (b)(3)(iv) and (v) of this section. The required period in which monitoring must be conducted shall be determined from paragraphs (b)(3)(i) through (iii) of this section using the monitoring results from the preceding monitoring period. The percent leaking connectors shall be calculated as specified in paragraph (c) of this section. [40 CFR 60.482-11a(b)(3)]

FUGI 04 FS003

(c) For use in determining the monitoring frequency, as specified in paragraphs (a) and (b)(3) of this section, the percent leaking connectors as used in paragraphs (a) and (b)(3) of this section shall be calculated by using the following equation: %CL= CL/ Ct* 100 Where: %CL= Percent of leaking connectors as determined through periodic monitoring required in paragraphs (a) and (b)(3)(i) through (iii) of this section. CL= Number of connectors measured at 500 ppm or greater, by the method specified in Section 60.485a(b). Ct= Total number of monitored connectors in the process unit or affected facility. [40 CFR 60.482-11a(c) and (d)]

FUGI 04 FS003

(d) When a leak is detected pursuant to paragraphs (a) and (b) of this section, it shall be repaired as soon as practicable, but not later than 15 calendar days after it is detected, except as provided in Section 60.482-9a. A first attempt at repair as defined in this subpart shall be made no later than 5 calendar days after the leak is detected. [40 CFR 60.482-11a(d)]

FUGI 04 FS003

(e) Any connector that is designated, as described in Section 60.486a(f)(1), as an unsafe-to-monitor connector is exempt from the requirements of paragraphs (a) and (b) of this section if: (1) The owner or operator of the connector demonstrates that the connector is unsafe-to-monitor because monitoring personnel would be exposed to an immediate danger as a consequence of complying with paragraphs (a) and (b) of this section; and (2) The owner or operator of the connector has a written plan that requires monitoring of the connector as frequently as practicable during safe-to-monitor times but not more frequently than the periodic monitoring schedule otherwise applicable, and repair of the equipment according to the procedures in paragraph (d) of this section if a leak is detected. [40 CFR 60.482-11a(e)]

FUGI 04 FS003

(f) Inaccessible, ceramic, or ceramic-lined connectors . (1) Any connector that is inaccessible or that is ceramic or ceramic-lined (e.g., porcelain, glass, or glass-lined), is exempt from the monitoring requirements of paragraphs (a) and (b) of this section, from the leak repair requirements of paragraph (d) of this section, and from the recordkeeping and reporting requirements of Sections 63.1038 and 63.1039. An inaccessible connector is one that meets any of the provisions specified in paragraphs (f)(1)(i) through (vi) of this section, as applicable. [40 CFR 60.482-11a(f)]

FUGI 04 FS003

(g) Except for instrumentation systems and inaccessible, ceramic, or ceramic-lined connectors meeting the provisions of paragraph (f) of this section, identify the connectors subject to the requirements of this subpart. Connectors need not be individually identified if all connectors in a designated area or length of pipe subject to the provisions of this subpart are identified as a group, and the number of connectors subject is indicated. [40 CFR 60.482-11a]

FUGI 04 FS003 Compliance shall be determined by the methods specified in 40 CFR Section 60.485a. [40 CFR 60.485a(b)]

FUGI 04 FS003

(b) When each leak is detected, the following requirements apply: (1) A weatherproof and readily visible identification, marked with the equipment identification number, shall be attached to the leaking equipment. (2) The identification on a valve may be removed after it has been monitored for 2 successive months as specified in 40 CFR Section 60.482-7a(c) and no leak has been detected during those 2 months. (3) The identification on a connector may be removed after it has been monitored as specified in Section 60.482-11a(b)(3)(iv) and no leak has been detected during that monitoring. (4) The identification on equipment, except on a valve or connector, may be removed after it has been repaired. [40 CFR 60.486a(b)]

FUGI 04 FS003

(c) When each leak is detected the following information shall be recorded in a log and shall be kept for 2 years in a readily accessible location: (1) The instrument and operator identification numbers and the equipment identification number. (2) The date the leak was detected and the dates of each attempt to repair the leak. (3) Repair methods applied in each attempt to repair the leak. (4) Maximum instrument reading measured by Method 21 of appendix A-7 of this part at the time the leak is successfully repaired or determined to be nonrepairable, except when a pump is repaired by eliminating indications of liquids dripping. [40 CFR 60.486a(c)(1)-(4)]

FUGI 04 FS003

(5) Repair delayed and the reason for the delay if a leak is not repaired within 15 calendar days after discovery of the leak. (6) The signature of the owner or operator whose decision it was that the repair could not be affected without a process shutdown. (7) The expected date of successful repair of the leak if a leak is not repaired within 15 days. (8) Dates of process unit shutdowns that occur while the equipment is unrepaired. (9) The date of successful repair of the leak. [40 CFR 60.486a(c)(5)-(9)]

FUGI 04 FS003

(d) The information pertaining to the design requirements for closed vent systems and required control devices described in Section 60.482-10a shall be recorded and kept in a readily accessible location: (1) Detailed schematics, design specifications, and piping and instrumentation diagrams. (2) The dates and descriptions of any changes in the design specifications. (3) A description of the parameter(s) monitored per Section 60.482-10a(e), to ensure that control devices are operated and maintained in conformance with their design and an explanation of why that parameter(s) was selected. (4) Periods when the closed vent systems and required control devices are not operated as designed, including periods when a flare pilot light does not have a flame. (5) Dates of startups and shutdowns of the closed vent systems and required control devices. [40 CFR 60.486a(d)]

FUGI 04 FS003

(e) Information pertaining to all equipment subject to the requirements in Section 60.482-1a to 60.482-11a shall be recorded in a log that is kept in a readily accessible location and contain the information specified in 40 CFR Section 60.486a(e)(1) through (10). [40 CFR 60.486a(e)]

FUGI 04 FS003

(f) The following information pertaining to all valves subject to the requirements of Section 60.482-7a(g) and (h), all pumps subject to the requirements of Section 60.482-2a(g), and all connectors subject to the requirements of Section 60.482-11a(e) shall be recorded in a log that is kept in a readily accessible location: (1) A list of identification numbers for valves, pumps, and connectors that are designated as unsafe-to-monitor, an explanation for each valve, pump, or connector stating why the valve, pump, or connector is unsafe-to-monitor, and the plan for monitoring each valve, pump, or connector. (2) A list of identification numbers for valves that are designated as difficult-to-monitor, an explanation for each valve stating why the valve is difficult-to-monitor, and the schedule for monitoring each valve. [40 CFR 60.486a(f)]

FUGI 04 FS003

(g) The following information shall be recorded for valves complying with Section 60.483-2a: (1) A schedule of monitoring. (2) The percent of valves found leaking during each monitoring period. [40 CFR 60.486a(g)]

FUGI 04 FS003

(h) The following information shall be recorded in a log that is kept in a readily accessible location: (1) Design criterion required in Sections 60.482-2a(d)(5) and 60.482-3a(e)(2) and explanation of the design criterion; and (2) Any changes to this criterion and the reasons for the changes. [40 CFR 60.486a(h)]

FUGI 04 FS003

(i) The following information shall be recorded in a log that is kept in a readily accessible location for use in determining exemptions as provided in Section 60.480a(d): (1) An analysis demonstrating the design capacity of the affected facility, (2) A statement listing the feed or raw materials and products from the affected facilities and an analysis demonstrating whether these chemicals are heavy liquids or beverage alcohol, and (3) An analysis demonstrating that equipment is not in VOC service. [40 CFR 60.486a(i)]

FUGI 04 FS003

(j) Information and data used to demonstrate that a piece of equipment is not in VOC service shall be recorded in a log that is kept in a readily accessible location. (k) The provisions of Section 60.7(b) and (d) do not apply to affected facilities subject to this subpart. [40 CFR 60.486a(j) and (k)]

FUGI 04 FS003 The Permittee shall submit a report : Due by the end of each calendar half-year following Initial Startup that includes the information specified in 40 CFR 60.487. [40 CFR 60.487a(a)]

FUGI 04 FS003

(a) Each owner or operator subject to the provisions of this subpart shall submit semiannual reports to the Administrator beginning six months after the initial startup date. [40 CFR 60.487a(a)]

FUGI 04 FS003

(b) The initial semiannual report to the Administrator shall include the following information: (1) Process unit identification, (2) Number of valves subject to the requirements of 40 CFR Section 60.482-7a, (3) Number of pumps subject to the requirements of 40 CFR Section 60.482-2a, (4) Number of compressors subject to the requirements of 40 CFR Section 60.482-3a (5) Number of connectors subject to the requirements of 40 CFR Section 60.482-11a. [40 CFR 60.487a(b)]

FUGI 04 FS003

(c) All semiannual reports to the Administrator shall include the following information, summarized from the information in 40 CFR Section 60.486a; (1) Process unit identification. (2) For each month during the semiannual reporting period: (i) Number of valves for which leaks were detected as described in 40 CFR Section 60.482(7a)(b) or 40 CFR 60.483-2a (ii) Number of valves for which leaks were not repaired as required in 40 CFR Section 60.482-7a(d)(1), (iii) Number of pumps for which leaks were detected as described in Section 60.482-2a(b), (d)(4)(ii)(A) or (B), or (d)(5)(iii), (iv) Number of pumps for which leaks were not repaired as required in Section 60.482-2a(c)(1) and (d)(6), (v) Number of compressors for which leaks were detected as described in Section 60.482-3a(f), (vi) Number of compressors for which leaks were not repaired as required in Section 60.482-3a(g)(1), (vii) Number of connectors for which leaks were detected as described in Section 60.482-11a(b), and (viii) Number of connectors for which leaks were not repaired as required in Section 60.482-11a(d). [40 CFR 60.487a(c)(1) and (2)]

FUGI 04 FS003

(3) Dates of process unit shutdowns which occurred within the semiannual reporting period. (4) Revisions to items reported according to paragraph (b) if changes have occurred since the initial report or subsequent revisions to the initial report. [40 CFR 60.487a(c)(3) and (4)]

FUGI 04 FS003

(e) Report the results of all performance tests in accordance with 40 CFR Section 60.8. The provisions of 40 CFR Section 60.8(d) do not apply to affected facilities subject to the provisions of this subpart except than an owner or operator must notify the Administrator of the schedule for the initial performance tests at least 30 days before the initial performance tests. [40 CFR 60.487a(e)]

FUGI 04 FS003

(f) The requirements of paragraphs (a) through (c) of this section remain in force until and unless EPA, in delegating enforcement authority to a state under section 111(c) of the CAA, approves reporting requirements or an alternative means of compliance surveillance adopted by such state. In that event, affected sources within the state will be relieved of the obligation to comply with the requirements of paragraphs (a) through (c) of this section, provided that they comply with the requirements established by the state. [40 CFR 60.487a(f)]

STRU 09 SV001

Total Particulate Matter <= 0.99 pounds per hour. Meets limit of 0.01 grains/dry standard cubic foot required by 40 CFR Section 60.302(b)(1). [40 CFR 60.302(b)(1), Minn. R. 7011.1005, subp. 2, Title I Condition: Avoid major source under 40 CFR 52.21(b)(1)(i) and Minn. R. 7007.3000]

STRU 09 SV001 PM < 10 micron <= 0.99 pounds per hour. [Title I Condition: Avoid major source under 40 CFR 52.21(b)(1)(i) and Minn. R. 7007.3000]

STRU 09 SV001 PM < 2.5 micron <= 0.17 pounds per hour. [Title I Condition: Avoid major source under 40 CFR 52.21(b)(1)(i) and Minn. R. 7007.3000]

STRU 09 SV001

Procedure to Increase Process Throughput Limit: The Permittee may increase the STRU 9 process throughput limit by conducting a performance test at an operating rate that exceeds the permitted STRU 9 process throughput limit and meeting requirements 1 through 6 below. 1. Performance Test Notification (written): due 90 days before performance test at an increased process throughput rate. 2. The Permittee may exceed the existing process throughput limit upon MPCA receipt of the notification of performance test at a higher process throughput (required by item 1 above). 3. Performance Test Plan: due 30 days before performance test. The Test Plan shall identify the new proposed maximum process throughput limit. 4. Performance Test Pre-Test Meeting: due 7 days before performance test. 5. Performance Test Report: due 45 days after performance test. 6. Performance Test Report : Microfiche Copy: due 105 days after each performance test. The Notification, Test Plan and Test Report may be submitted in an alternative format as allowed by Minn. R. 7017.2018. [Minn. R. 7007.0800, subp. 2, Minn. R. 7017.2018, Minn. R. 7017.2030, subps. 1-4, Minn. R. ch. 7017.2035, subps. 1 & 2]

STRU 09 SV001 Opacity <= 0 percent opacity. [40 CFR 60.302(c)(2), Minn. R. 7011.1005, subp. 2, Minn. R. 7011.1005, subp. 3(D)]

STRU 09 SV001

Notwithstanding any provisions in Minn. R. 7011.1000 to 7011.1015, no Permittee of a dry bulk agricultural commodity facility may operate or maintain a facility that creates a public nuisance. If the commissioner determines that operation or maintenance of a commodity facility creates a public nuisance, the commissioner may require the Permittee to take measures necessary to

eliminate the nuisance. [Minn. R. 7011.1010]

STRU 09 SV001

The Permittee shall vent emissions from all emission units to a fabric filter meeting the permit requirements for TREA 1 whenever emission units venting to STRU 9 operate, and operate and maintain a fabric filter meeting the requirements of TREA 1 at all times that any emissions are vented to a fabric filter meeting the requirements of TREA 1. The Permittee shall document periods of non-operation of the control equipment. [Minn. R. 7007.0800, subps. 2 & 14, Title I Condition: Avoid major source under 40 CFR 52.21(b)(1)(i) and Minn. R. 7007.3000]

STRU 09 SV001 Maintain TREA 1 in proper operating condition and utilize the air pollution control systems as designed. [Minn. R. 7011.1005, subp. 1(B)]

STRU 09 SV001


STRU 09 SV001


STRU 09 SV001


STRU 09 SV001


STRU 09 SV001


STRU 09 SV001


STRU 09 SV001


STRU 09 SV001

Any physical or operational change to an existing facility which results in an increase in the emission rate to the atmosphere of any pollutant to which a standard applies shall be considered a modification within the meaning of section 111 of the Act. Upon modification, an existing facility shall become an affected facility for each pollutant to which a standard applies and for which there is an increase in the emission rate to the atmosphere. The addition of an affected facility to a stationary source as an expansion to that source or as a replacement for an existing facility shall

not by itself bring within the applicability of this part any other facility within that source. [40 CFR 60.14(a-c), Minn. R. 7011.0050]

STRU 09 SV001

The Permittee shall conduct an initial performance test : Due 365 calendar days after Permit Issuance Date and after every 60 months thereafter to measure total PM emissions. The performance test shall be conducted at worst case conditions as defined at Minn. R. 7017.2005, subp. 8, and as identified in Appendix C of this permit, using EPA Reference Method 5 and Method 202, or another method approved by MPCA in the performance test plan approval. Process throughput limits (bushels/hr) for grain received and DDGS loaded (tons/hr) will be defined by the operating process rates sustained during the test pursuant to Minn. R. 7017.2025, subp. 3(C). [Minn. R. 7017.2025, subp. 3, Title I Condition: Avoid major source under 40 CFR 52.21(b)(1)(i) and Minn. R. 7007.3000]

STRU 09 SV001

The Permittee shall conduct an initial performance test : Due 365 calendar days after Permit Issuance Date and after every 60 months thereafter to measure PM10 emissions. The performance test shall be conducted at worst case conditions as defined at Minn. R. 7017.2005, subp. 8, and as identified in Appendix C of this permit, using EPA Reference Method 5 and Method 202, or another method approved by MPCA in the performance test plan approval. Process throughput limits (bushels/hr) for grain received and DDGS loaded (tons/hr) will be defined by the operating process rates sustained during the test pursuant to Minn. R. 7017.2025, subp. 3(C). [Minn. R. 7017.2025, subp. 3, Title I Condition: Avoid major source under 40 CFR 52.21(b)(1)(i) and Minn. R. 7007.3000]

STRU 09 SV001

The Permittee shall conduct an initial performance test : Due 365 calendar days after Permit Issuance Date The Permittee shall conduct an initial performance test : Due 365 calendar days after Permit Issuance Date and after every 60 months thereafter to measure PM2.5 emissions. The performance test shall be conducted at worst case conditions as defined at Minn. R. 7017.2005, subp. 8, and as identified in Appendix C of this permit, using EPA Reference Method 5 and Method 202, or another method approved by MPCA in the performance test plan approval. Process throughput limits (bushels/hr) for grain received and DDGS loaded (tons/hr) will be defined by the operating process rates sustained during the test pursuant to Minn. R. 7017.2025, subp. 3(C). [Minn. R. 7017.2025, subp. 3, Title I Condition: Avoid major source under 40 CFR 52.21(b)(1)(i) and Minn. R. 7007.3000]

STRU 10 SV002

Total Particulate Matter <= 0.09 pounds per hour. Meets limit of 0.01 grains/dry standard cubic foot required by 40 CFR Section 60.302(b)(1). [Title I Condition: Avoid major source under 40 CFR 52.21(b)(1)(i) and Minn. R. 7007.3000]


STRU 10 SV002 PM < 2.5 micron <= 0.015 pounds per hour. [Minn. R. 7005.0100, subp. 35a, Minn. R. 7007.0800, subp. 2]

STRU 10 SV002 Opacity <= 10 percent opacity discharged from control equipment. [Minn. R. 7011.1005, subp. 3(D)]

STRU 10 SV002

Procedure to Increase Process Throughput Limit: The Permittee may increase the STRU 10 process throughput limit by conducting a performance test at an operating rate that exceeds the permitted STRU 10 process throughput limit and meeting requirements 1 through 6 below. 1. Performance Test Notification (written): due 90 days before performance test at an increased process throughput rate. 2. The Permittee may exceed the existing process throughput limit upon MPCA receipt of the notification of performance test at a higher process throughput (required by item 1 above). 3. Performance Test Plan: due 30 days before performance test. The Test Plan shall identify the new proposed maximum process throughput limit. 4. Performance Test Pre-Test Meeting: due 7 days before performance test. 5. Performance Test Report: due 45 days after performance test. 6. Performance Test Report : Microfiche Copy: due 105 days after each

performance test. The Notification, Test Plan and Test Report may be submitted in an alternative format as allowed by Minn. R. 7017.2018. [Minn. R. 7007.0800, subp. 2, Minn. R. 7017.2018, Minn. R. 7017.2030, subps. 1-4, Minn. R. ch. 7017.2035, subps. 1 & 2]

STRU 10 SV002

Notwithstanding any provisions in Minn. R. 7011.1000 to 7011.1015, no Permittee of a dry bulk agricultural commodity facility may operate or maintain a facility that creates a public nuisance. If the commissioner determines that operation or maintenance of a commodity facility creates a public nuisance, the commissioner may require the Permittee to take measures necessary to eliminate the nuisance. [Minn. R. 7011.1010]

STRU 10 SV002 Maintain air pollution control equipment in proper operating condition and utilize the air pollution control systems as designed. [Minn. R. 7011.1005, subp. 1(B)]

STRU 10 SV002

The Permittee shall vent emissions from all emission units to a fabric filter meeting the permit requirements for TREA 2 whenever emission units venting to STRU 10 operate, and operate and maintain a fabric filter meeting the requirements of TREA 2 at all times that any emissions are vented to a fabric filter meeting the requirements of TREA 2. The Permittee shall document periods of non-operation of the control equipment. [Minn. R. 7007.0800, subps. 2 & 14, Title I Condition: Avoid major source under 40 CFR 52.21(b)(1)(i) and Minn. R. 7007.3000]

STRU 10 SV002


STRU 10 SV002


STRU 10 SV002


STRU 10 SV002


STRU 10 SV002


STRU 10 SV002


STRU 10 SV002


STRU 10 SV002

Any physical or operational change to an existing facility which results in an increase in the emission rate to the atmosphere of any pollutant to which a standard applies shall be considered a modification within the meaning of section 111 of the Act. Upon modification, an existing facility shall become an affected facility for each pollutant to which a standard applies and for which there is an increase in the emission rate to the atmosphere. The addition of an affected facility to a stationary source as an expansion to that source or as a replacement for an existing facility shall not by itself bring within the applicability of this part any other facility within that source. [40 CFR 60.14(a-c), Minn. R. 7011.0050]

STRU 10 SV002

The Permittee shall conduct an initial performance test : Due 365 calendar days after Permit Issuance Date and after every 60 months thereafter to measure total PM emissions. The performance test shall be conducted at worst case conditions as defined at Minn. R. 7017.2005, subp. 8, and as identified in Appendix C of this permit, using EPA Reference Method 5 and Method 202, or another method approved by MPCA in the performance test plan approval. Process throughput limits (bushels/hr) will be defined by the operating process rates sustained during the test pursuant to Minn. R. 7017.2025, subp. 3(C). [Minn. R. 7017.2025, subp. 3, Title I Condition: Avoid major source under 40 CFR 52.21(b)(1)(i) and Minn. R. 7007.3000]

STRU 10 SV002

The Permittee shall conduct an initial performance test : Due 365 calendar days after Permit Issuance Date and after every 60 months thereafter to measure PM10 emissions. The performance test shall be conducted at worst case conditions as defined at Minn. R. 7017.2005, subp. 8, and as identified in Appendix C of this permit, using EPA Reference Method 5 and Method 202, or another method approved by MPCA in the performance test plan approval. Process throughput limits (bushels/hr) will be defined by the operating process rates sustained during the test pursuant to Minn. R. 7017.2025, subp. 3(C). [Minn. R. 7017.2025, subp. 3, Title I Condition: Avoid major source under 40 CFR 52.21(b)(1)(i) and Minn. R. 7007.3000]

STRU 10 SV002

The Permittee shall conduct an initial performance test : Due 365 calendar days after Permit Issuance Date The Permittee shall conduct an initial performance test : Due 365 calendar days after Permit Issuance Date and after every 60 months thereafter to measure PM2.5 emissions. The performance test shall be conducted at worst case conditions as defined at Minn. R. 7017.2005, subp. 8, and as identified in Appendix C of this permit, using EPA Reference Method 5 and Method 202, or another method approved by MPCA in the performance test plan approval. Process throughput limits (bushels/hr) will be defined by the operating process rates sustained during the test pursuant to Minn. R. 7017.2025, subp. 3(C). [Minn. R. 7017.2025, subp. 3, Title I Condition: Avoid major source under 40 CFR 52.21(b)(1)(i) and Minn. R. 7007.3000]


STRU 11 SV003


STRU 11 SV003

The Permittee shall vent emissions to a fabric filter meeting the permit requirements for TREA 3 whenever emission units venting to STRU 11 operate, and operate and maintain a fabric filter meeting the requirements of TREA 3 at all times that any emissions are vented to a fabric filter meeting the requirements of TREA 3. The Permittee shall document periods of non-operation of the control equipment. [Minn. R. 7007.0800, subps. 2 & 14, Title I Condition: Avoid major source under 40 CFR 52.21(b)(1)(i) and Minn. R. 7007.3000]

STRU 12 SV004 Opacity <= 10 percent opacity discharged from control equipment. [Minn. R. 7011.1005, subp.

3(D)]

STRU 12 SV004


STRU 12 SV004



STRU 13 SV005


STRU 13 SV005



STRU 14 SV006


STRU 14 SV006

The Permittee shall vent all emissions to a fabric filter meeting the permit requirements for TREA 6 whenever emission units venting to STRU 14 operate, and operate and maintain a fabric filter meeting the requirements of TREA 6 at all times that any emissions are vented to a fabric filter meeting the requirements of TREA 6. The Permittee shall document periods of non-operation of the control equipment. [Minn. R. 7007.0800, subps. 2 & 14, Title I Condition: Avoid major source under 40 CFR 52.21(b)(1)(i) and Minn. R. 7007.3000]

STRU 15 SV007

Volatile Organic Compounds <= 29.0 pounds per hour 3-hour average as measured on a total mass of VOC basis. [Title I Condition: Avoid major source under 40 CFR 52.21(b)(1)(i) and Minn. R. 7007.3000, Title I Condition: Avoid major source under 40 CFR 63.2]

STRU 15 SV007


STRU 15 SV007

Volatile Organic Compounds : The Permittee shall conduct a performance test : Due before 04/30/2020 and after end of every 60 months thereafter to measure total mass of VOC emissions. The performance test shall be conducted at worst case conditions as defined at Minn. R. 7017.2005, subp. 8, and as identified in Appendix C of this permit, using EPA Reference Method 25A and Method 18 or 320, or another method approved by MPCA in the performance test plan approval. Testing conducted during the 60 days prior to the performance test due date satisfies the performance test due date, and will not reset the test due date for future testing as required: 1) by this permit; 2) by the most recently approved Performance Test Frequency Plan; or 3) within a Notice of Compliance letter. Testing conducted more than two months prior to the performance test due date satisfies this test due date requirement and will reset the performance test due date. [Minn. R. 7017.2020, subp. 1, Title I Condition: Avoid major source under 40 CFR 52.21(b)(1)(i) and Minn. R. 7007.3000]

STRU 16 SV008 Total Particulate Matter <= 8.0 pounds per hour. [Title I Condition: Avoid major source under 40 CFR 52.21(b)(1)(i) and Minn. R. 7007.3000]



STRU 16 SV008 Nitrogen Oxides <= 11.0 pounds per hour. [Title I Condition: Avoid major source under 40 CFR 52.21(b)(1)(i) and Minn. R. 7007.3000]

STRU 16 SV008 Carbon Monoxide <= 10.0 pounds per hour. [Title I Condition: Avoid major source under 40 CFR 52.21(b)(1)(i) and Minn. R. 7007.3000]

STRU 16 SV008

Volatile Organic Compounds <= 9.9 pounds per hour on the basis of total mass of VOC. [Title I Condition: Avoid major source under 40 CFR 52.21(b)(1)(i) and Minn. R. 7007.3000, Title I Condition: Avoid major source under 40 CFR 63.2]

STRU 16 SV008

Total Particulate Matter <= 0.3 grains per 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. [Minn. R. 7011.0610, subp. 1(A)(1)]

STRU 16 SV008 Opacity <= 20 percent opacity except for one six-minute period per hour of not more than 60 percent opacity. [Minn. R. 7011.0610, subp. 1(A)(2)]

STRU 16 SV008

The Permittee shall vent all emissions to a regenerative thermal oxidizer meeting the permit requirements for TREA 8 whenever emission units venting to STRU 16 operate, and operate and maintain a regenerative thermal oxidizer meeting the requirements of TREA 8 at all times that any emissions are vented to a regenerative thermal oxidizer meeting the requirements of TREA 8. The Permittee shall document periods of non-operation of the control equipment. Alternative Operating Scenarios are allowed according to COMG 6 requirements. [Title I Condition: Avoid major source under 40 CFR 52.21(b)(1)(i) and Minn. R. 7007.3000, Title I Condition: Avoid major source under 40 CFR 63.2]

STRU 16 SV008

Control Equipment Replacement. If the thermal oxidizer and/or wet scrubber emitting to STRU 16 are replaced according to the provisions of this permit, stack emissions testing for Volatile Organic Compounds (on the basis of total mass of VOC), Nitrogen Oxides, and Carbon Monoxide shall be completed within 90 days after completing the replacement to ensure that the new equipment does not cause an exceedance of applicable emission limits and so that new operating parameters may be set pursuant to Minn. R. 7017.2025, subp. 3. [Minn. R. 7007.0800, subps. 2 & 14, Title I Condition: Avoid major source under 40 CFR 52.21(b)(1)(i) and Minn. R. 7007.3000]

STRU 16 SV008

Process Throughput <= 700.0 gallons per minute (beer feed rate) unless a new limit is set pursuant to Minn. R. 7017.2025, subp. 3 based on the throughput recorded during the most recent MPCA-approved performance test for STRU 16 where compliance was demonstrated. If the results of the most recent and approved performance tests for STRU 16 are less than or equal to 80.0% of the limit for each and every STRU 16 emission limit (Total PM, PM10, PM2.5, NOX, CO, VOC), the process throughput limit may be increased by an amount equal to 10.0% of the existing throughput limit. If the Permittee does not test within 90% of the target process rate, a new limit

shall be implemented upon receipt of the Notice of Compliance letter granting preliminary approval. The limit is final upon issuance of a permit amendment incorporating the change. [Minn. R. 7017.2025, subp. 3, Title I Condition: Avoid major source under 40 CFR 52.21(b)(1)(i) and Minn. R. 7007.3000]

STRU 16 SV008

Procedure to Increase Process Throughput Limit: The Permittee may increase the STRU 16 process throughput limit by conducting a performance test at an operating rate that exceeds the permitted STRU 16 process throughput limit and meeting requirements 1 through 6 below. 1. Performance Test Notification (written): due 90 days before performance test at an increased process throughput rate. 2. The Permittee may exceed the existing process throughput limit upon MPCA receipt of the notification of performance test at a higher process throughput (required by item 1 above). 3. Performance Test Plan: due 30 days before performance test. The Test Plan shall identify the new proposed maximum process throughput limit. 4. Performance Test Pre-Test Meeting: due 7 days before performance test. 5. Performance Test Report: due 45 days after performance test. 6. Performance Test Report : Microfiche Copy: due 105 days after each performance test. The Notification, Test Plan and Test Report may be submitted in an alternative format as allowed by Minn. R. 7017.2018. [Minn. R. 7007.0800, subp. 2, Minn. R. 7017.2018, Minn. R. 7017.2030, subps. 1-4, Minn. R. ch. 7017.2035, subps. 1 & 2]

STRU 16 SV008

Measure and record the beer feed rate on an hourly basis. [Minn. R. 7007.0800, subps. 4-5, Title I Condition: 40 CFR 63.2, Title I Condition: Avoid major source under 40 CFR 52.21(b)(1)(i) and Minn. R. 7007.3000]

STRU 16 SV008


STRU 16 SV008

Nitrogen Oxides : The Permittee shall conduct a performance test : Due before 04/30/2020 and after end of every 60 months thereafter to measure emissions. The performance test shall be conducted at worst case conditions as defined at Minn. R. 7017.2005, subp. 8, and as identified in Appendix C of this permit, using EPA Reference Method 19, or another method approved by MPCA in the performance test plan approval. Testing conducted during the 60 days prior to the performance test due date satisfies the performance test due date, and will not reset the test due date for future testing as required: 1) by this permit; 2) by the most recently approved Performance Test Frequency Plan; or 3) within a Notice of Compliance letter. Testing conducted more than two months prior to the performance test due date satisfies this test due date requirement and will reset the performance test due date. [Minn. R. 7017.2020, subp. 1, Title I Condition: Avoid major source under 40 CFR 52.21(b)(1)(i) and Minn. R. 7007.3000]

STRU 16 SV008

PM < 10 micron : The Permittee shall conduct a performance test : Due before 04/30/2020 and after end of every 60 months thereafter to measure emissions. The performance test shall be conducted at worst case conditions as defined at Minn. R. 7017.2005, subp. 8, and as identified in Appendix C of this permit, using EPA Reference Method 5 and Method 202, or another method approved by MPCA in the performance test plan approval. Testing conducted during the 60 days prior to the performance test due date satisfies the performance test due date, and will not reset the test due date for future testing as required: 1) by this permit; 2) by the most recently approved Performance Test Frequency Plan; or 3) within a Notice of Compliance letter. Testing conducted more than two months prior to the performance test due date satisfies this test due date requirement and will reset the performance test due date. [Minn. R. 7017.2020, subp. 1, Title I Condition: Avoid major source under 40 CFR 52.21(b)(1)(i) and Minn. R. 7007.3000]

STRU 16 SV008

Total Particulate Matter : The Permittee shall conduct a performance test : Due before 04/30/2020 and after end of every 60 months thereafter to measure emissions. The performance test shall be conducted at worst case conditions as defined at Minn. R. 7017.2005, subp. 8, and as identified in Appendix C of this permit, using EPA Reference Method 5 and Method 202, or another method approved by MPCA in the performance test plan approval. Testing conducted during the 60 days prior to the performance test due date satisfies the performance test due date, and will not reset the test due date for future testing as required: 1) by this permit; 2) by the most recently approved Performance Test Frequency Plan; or 3) within a Notice of Compliance letter. Testing conducted more than two months prior to the performance test due date satisfies this test due date requirement and will reset the performance test due date. [Minn. R. 7017.2020, subp. 1, Title I Condition: Avoid major source under 40 CFR 52.21(b)(1)(i) and Minn. R. 7007.3000]

STRU 16 SV008

PM < 2.5 micron : The Permittee shall conduct a performance test : Due before 04/30/2020 and after end of every 60 months thereafter to measure emissions. The performance test shall be conducted at worst case conditions as defined at Minn. R. 7017.2005, subp. 8, and as identified in Appendix C of this permit, using EPA Reference Method 201A and 202, or another method approved by MPCA in the performance test plan approval. Testing conducted during the 60 days prior to the performance test due date satisfies the performance test due date, and will not reset the test due date for future testing as required: 1) by this permit; 2) by the most recently approved Performance Test Frequency Plan; or 3) within a Notice of Compliance letter. Testing conducted more than two months prior to the performance test due date satisfies this test due date requirement and will reset the performance test due date. [Minn. R. 7017.2020, subp. 1, Title I Condition: Avoid major source under 40 CFR 52.21(b)(1)(i) and Minn. R. 7007.3000]

STRU 16 SV008

Carbon Monoxide : The Permittee shall conduct a performance test : Due before 04/30/2020 and after end of every 60 months thereafter to measure emissions. The performance test shall be conducted at worst case conditions as defined at Minn. R. 7017.2005, subp. 8, and as identified in Appendix C of this permit, using EPA Reference Method 10, or another method approved by MPCA in the performance test plan approval. Testing conducted during the 60 days prior to the performance test due date satisfies the performance test due date, and will not reset the test due date for future testing as required: 1) by this permit; 2) by the most recently approved Performance Test Frequency Plan; or 3) within a Notice of Compliance letter. Testing conducted more than two months prior to the performance test due date satisfies this test due date requirement and will reset the performance test due date. [Minn. R. 7017.2020, subp. 1, Title I Condition: Avoid major source under 40 CFR 52.21(b)(1)(i) and Minn. R. 7007.3000]

STRU 16 SV008

Volatile Organic Compounds : The Permittee shall conduct a performance test : Due before 04/30/2020 to measure emissions. Testing must include all chemicals listed in Appendix C of this permit. The performance test shall be conducted at worst case conditions as defined at Minn. R. 7017.2005, subp. 8, using EPA Reference Method 25A in addition to Method 18 or Method 320, or another method approved by MPCA in the performance test plan approval. Process throughput limits (gpm) for the beer feed rate, 190-proof ethanol production rate, and 200-proof ethanol production rates will be defined by the operating process rates sustained during the test pursuant to Minn. R. 7017.2025, subp. 3(C). [Minn. R. 7017.2020, subp. 1, Title I Condition: 40 CFR 63.2, Title I Condition: Avoid major source under 40 CFR 52.21(b)(1)(i) and Minn. R. 7007.3000]

STRU 16 SV008

Alternative Operating Scenario (Scrubber Bypass): Volatile Organic Compounds <= 37.89 pounds per hour 3-hour average as measured on a total mass of VOC basis while bypassing the wet scrubber. [Minn. R. 7005.0100, subp. 35a, Title I Condition: Avoid major source under 40 CFR 52.21(b)(1)(i) and Minn. R. 7007.3000, Title I Condition: Avoid major source under 40 CFR 63.2]

STRU 16 SV008

Alternative Operating Scenario (Scrubber Bypass): The Permittee shall conduct an initial performance test : Due 365 calendar days after Permit Issuance Date to verify the VOC emission factor on a total mass basis while bypassing the scrubber. Testing must include all chemicals listed in Appendix C of this permit. The performance test shall be conducted at worst case conditions as defined at Minn. R. 7017.2005, subp. 8, using EPA Reference Method 25A in addition to Method 18 or Method 320, or another method approved by MPCA in the performance test plan approval. Process throughput limits (gpm) for the beer feed rate, 190-proof ethanol production rate, and 200-proof ethanol production rates will be defined by the operating process rates sustained during the test pursuant to Minn. R. 7017.2025, subp. 3(C). [Minn. R. 7017.2020, subp. 1, Title I Condition: Avoid major source under 40 CFR 52.21(b)(1)(i) and MInn. R. 7007.3000, Title I Condition: Avoid major source under 40 CFR 63.2]


STRU 17 SV009


STRU 17 SV009


STRU 18 SV010 Total Particulate Matter <= 0.14 pounds per hour. [Title I Condition: Avoid major source under 40 CFR 52.21(b)(1)(i) and Minn. R. 7007.3000]




STRU 18 SV010


STRU 18 SV010

The Permittee shall vent all emissions to a fabric filter meeting the permit requirements for TREA 13 whenever emission units venting to STRU 18 operate, and operate and maintain a fabric filter meeting the requirements of TREA 13 at all times that any emissions are vented to a fabric filter meeting the requirements of TREA 13. The Permittee shall document periods of non-operation of the control equipment. [Minn. R. 7007.0800, subps. 2 & 14, Title I Condition: Avoid major source under 40 CFR 52.21(b)(1)(i) and Minn. R. 7007.3000]

STRU 20 SV012

The Permittee shall vent emissions from EQUI 55 to a flare meeting the permit requirements for TREA 14 whenever emission units venting to STRU 20 operate, and operate and maintain a flare meeting the requirements of TREA 14 at all times that any emissions are vented to a flare meeting the requirements of TREA 14. The Permittee shall document periods of non-operation of the control equipment. [Title I Condition: 40 CFR 63.2, Title I Condition: Avoid major source under 40 CFR 52.21(b)(1)(i) and Minn. R. 7007.3000]

STRU 21 SV013

Emergency Bypass Use: The Permittee may bypass an RTO meeting the permit requirements of TREA 8 when the DDGS dryers are in operation only when plant or worker safety would be in jeopardy without the use of the bypass. Each period of bypass use, while the DDGS dryers are operated, shall be recorded in the daily operating record. The record shall include the date, start time of use, duration of use, and the facility operating conditions during its use. For periods of bypass use while the DDGS dryers are operated, the Permittee shall conduct a root-cause failure analysis of the event and submit a report of the analysis to the Commissioner within 15 days. The emissions emitted during a bypass event shall be considered uncontrolled and shall be reported as a deviation. [Title I Condition: Avoid major source under 40 CFR 52.21(b)(1)(i) and Minn. R. 7007.3000, Title I Condition: Avoid major source under 40 CFR 63.2]

STRU 22 SV014

Volatile Organic Compounds <= 13.2 pounds per hour during bypass of the dryer burners (EQUI 47 and EQUI 48) and Auxiliary Boiler burners (EQUI 53 and EQUI 61) as measured by total mass of VOC basis. [Title I Condition: Avoid major source under 40 CFR 52.21(b)(1)(i) and Minn. R. 7007.3000, Title I Condition: Avoid major source under 40 CFR 63.2]

STRU 22 SV014

Total Particulate Matter <= 1.1 pounds per hour during bypass of the dryer burners (EQUI 47 and EQUI 48) and Auxiliary Boiler burners (EQUI 53 and EQUI 61). [Title I Condition: Avoid major source under 40 CFR 52.21(b)(1)(i) and Minn. R. 7007.3000]

STRU 22 SV014

PM < 10 micron <= 1.1 pounds per hour during bypass of the dryer burners (EQUI 47 and EQUI 48) and Auxiliary Boiler burners (EQUI 53 and EQUI 61). [Title I Condition: Avoid major source under 40 CFR 52.21(b)(1)(i) and Minn. R. 7007.3000]

STRU 22 SV014

Volatile Organic Compounds : The Permittee shall conduct a performance test : Due before 04/30/2020 and after end of every 60 months thereafter to measure total mass of VOC emissions. Testing must include all chemicals listed in Appendix C of this permit. The performance test shall be conducted at worst case conditions as defined at Minn. R. 7017.2005, subp. 8, and as identified in Appendix C of this permit, using EPA Reference Method 25A and Method 18 or 320, or another method approved by MPCA in the performance test plan approval. The process throughput limit (tons/hr) for the DDGS cooling rate will be defined by the operating process rates sustained during the test pursuant to Minn. R. 7017.2025, subp. 3(C). Testing conducted during the 60 days prior to the performance test due date satisfies the performance test due date, and will not reset the test due date for future testing as required: 1) by this permit; 2) by the most recently approved Performance Test Frequency Plan; or 3) within a Notice of Compliance letter. Testing conducted more than two months prior to the performance test due date satisfies this test due date requirement and will reset the performance test due date. [Minn. R. 7017.2020, subp. 1, Title I Condition: 40 CFR 63.2, Title I Condition: Avoid major source under 40 CFR 52.21(b)(1)(i) and Minn. R. 7007.3000]

STRU 22 SV014



STRU 24 SV017


STRU 24 SV017


STRU 26 SV019

Emergency Bypass Use: The Permittee may bypass an RTO meeting the permit requirements of TREA 8 when the DDGS dryers are in operation only when plant or worker safety would be in jeopardy without the use of the bypass. Each period of bypass use, while the DDGS dryers are operated, shall be recorded in the daily operating record. The record shall include the date, start time of use, duration of use, and the facility operating conditions during its use. For period of bypass use while the DDGS dryers are operated, the Permittee shall conduct a root-cause failure analysis of the event and submit a report of the analysis to the Commissioner within 15 days. The emissions emitted during a bypass event shall be considered uncontrolled and shall be reported as a deviation. [Title I Condition: Avoid major source under 40 CFR 52.21(b)(1)(i) and Minn. R. 7007.3000, Title I Condition: Avoid major source under 40 CFR 63.2]

STRU 27 SV015

Emergency Bypass Use: The Permittee may bypass the regenerative thermal oxidizer (TREA 8) only when the RTO is not in operation. Each period of bypass use shall be recorded in the daily operating record. The record shall include the date, start time of use, duration of use, and the facility operating conditions during its use. [Title I Condition: Avoid major source under 40 CFR 52.21(b)(1)(i) and Minn. R. 7007.3000, Title I Condition: Avoid major source under 40 CFR 63.2]

TFAC 01 01300099

Flexible Permit Language: This permit establishes limits on the facility to keep it a minor source under New Source Review. The Permittee cannot make any change at the source that would make the source a major source under New Source Review until a permit amendment has been issued. This includes changes that might otherwise qualify as insignificant modifications and minor or moderate amendments. [Title I Condition: Avoid major source under 40 CFR 52.21(b)(1)(i) & Minn. R. 7007.3000]

TFAC 01 01300099

The Permittee shall submit an annual report : Due by 31 days after the end of each calendar year following permit issuance. The Permittee shall submit an annual report by January 31st that describes the changes made at the facility during the previous calendar year using the latest MPCA application forms. The report shall include the emission unit, stack/vent, group, and control equipment data for any new or replaced units or control devices. The report shall document the 12-month rolling sum calculations for the previous calendar year for all pollutants limited within this permit on a 12-month rolling sum basis. The report shall be submitted with the annual Compliance Certification listed in Section 6 of this permit. As part of the Annual Report, the Permittee shall verify and certify that the facility has maintained minor source status for New Source Review. [Minn. R. 7007.0800, subp. 2]

TFAC 01 01300099

Control Equipment Labeling: The Permittee shall permanently affix a unique number to each piece of control equipment for tracking purposes. The numbers shall correlate the unit to the appropriate TREA and COMG numbers used in this permit. The number can be affixed by placard, stencil, or other means. The number shall be maintained so that it is readable and visible at all times from a safe distance. If new control equipment is added, it shall be given a new unique number; numbers from replaced or removed equipment shall not be reused. [Minn. R. 7007.0800, subp. 2]

TFAC 01 01300099

Control Equipment Inventory: The Permittee shall maintain a written list of all control equipment on site. The Permittee shall update the list to include any replaced, modified, or new equipment prior to making the change. The list shall correlate the units to the numbers used in this permit and shall include the data on GI-05A form. [Minn. R. 7007.0800, subps. 5 & 14]

TFAC 01 01300099

Production <= 59.750 million gallons 12-month rolling sum of ethanol (without denaturant). [Title I Condition: Avoid major source under 40 CFR 52.21(b)(1)(i) and Minn. R. 7007.3000, Title I Condition: Avoid major source under 40 CFR 63.2]

TFAC 01 01300099

Process Throughput <= 642,710 tons per year 12-month rolling sum of grain, based on 56 lb/bushel. This is equivalent to 21.1 MM bushels/yr. [Title I Condition: Avoid major source under 40 CFR 52.21(b)(1)(i) and Minn. R. 7007.3000, Title I Condition: Avoid major source under 40 CFR 63.2]

TFAC 01 01300099

Best Management Practices Odor Plan. The Permittee shall maintain and comply with a plan based on Best Management Practices for the minimization of odorous emissions from the facility. The plan shall address minimization of odors from: - emissions units and control equipment; - fugitive emissions from process piping, valves, flanges, etc.; and - emissions from the production of wet cake. The Permittee shall update the plan as necessary and submit the updated plan to the commissioner for approval. [Minn. R. 7007.0800, subp. 2]

TFAC 01 01300099

Clean up commodities spilled on the driveway and other facility property as required to minimize fugitive emissions; maintain air pollution control equipment in proper operating condition and utilize the air pollution control systems as designed. [Minn. R. 7011.1005, subp. 1]

TFAC 01 01300099

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 A - D. [Minn. R. 7007.0800, subp. 2]

TFAC 01 01300099

PERMIT SHIELD: Subject to the limitations in Minn. R. 7007.1800, compliance with the conditions of this permit shall be deemed compliance with the specific provision of the applicable requirement identified in the permit as the basis of each condition. Subject to the limitations of Minn. R. 7007.1800 and 7017.0100, subp. 2, notwithstanding the conditions of this permit specifying compliance practices for applicable requirements, any person (including the Permittee) may also use other credible evidence to establish compliance or noncompliance with applicable requirements. This permit shall not alter or affect the liability of the Permittee for any violation of applicable requirements prior to or at the time of permit issuance. [Minn. R. 7007.1800, (A)(2)]

TFAC 01 01300099

Comply with Fugitive Emission Control Plan: The Permittee shall follow the actions and recordkeeping specified in the control plan. The plan may be amended by the Permittee with the Commissioner's approval. If the Commissioner determines the Permittee is out of compliance with Minn. R. 7011.0150 or the fugitive control plan, then the Permittee may be required to amend the control plan and/or to install and operate particulate matter ambient monitors as requested by the Commissioner. [Minn. R. 7007.0100, Minn. R. 7007.0800, subp. 2, Minn. R. 7009.0020, Minn. R. 7011.0150, Minn. Stat. 116.07, subd. 4a]

TFAC 01 01300099

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. [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. Stat. 116.07, subd. 4a, Minn. Stat. 116.07, subd. 9]

TFAC 01 01300099

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. [Minn. R. 7011.0020]

TFAC 01 01300099

Air Pollution Control Equipment: Operate all pollution control equipment whenever the corresponding process equipment and emission units are operated. [Minn. R. 7007.0800, subp. 16(J), Minn. R. 7007.0800, subp. 2]

TFAC 01 01300099

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. [Minn. R. 7007.0800, subp. 14, Minn. R. 7007.0800, subp. 16(J)]

TFAC 01 01300099

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. [Minn. R. 7019.1000,

subp. 4]

TFAC 01 01300099

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. [Minn. R. 7011.0150]

TFAC 01 01300099

Noise: The Permittee shall comply with the noise standards set forth in Minn. R. 7030.0010 to 7030.0080 at all 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. [Minn. R. 7030.0010-7030.0080]

TFAC 01 01300099 Inspections: The Permittee shall comply with the inspection procedures and requirements as found in Minn. R. 7007.0800, subp. 9(A). [Minn. R. 7007.0800, subp. 9(A)]

TFAC 01 01300099 The Permittee shall comply with the General Conditions listed in Minn. R. 7007.0800, subp. 16. [Minn. R. 7007.0800, subp. 16]

TFAC 01 01300099 Performance Testing: Conduct all performance tests in accordance with Minn. R. ch. 7017 unless otherwise noted in in this permit. [Minn. R. ch. 7017]

TFAC 01 01300099

Performance Test Notifications and Submittals: Performance Tests are due as outlined in this permit. 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 an alternative format as allowed by Minn. R. 7017.2018. [Minn. R. 7017.2018, Minn. R. 7017.2030, subps. 1-4, Minn. R. 7017.2035, subps. 1-2]

TFAC 01 01300099

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. [Minn. R. 7017.2025, subp. 3]

TFAC 01 01300099

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. [Minn. R. 7007.0800, subp. 4(D)]

TFAC 01 01300099

Operation of Monitoring Equipment: Unless noted elsewhere in this permit, 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. [Minn. R. 7007.0800, subp. 4(D)]

TFAC 01 01300099

Ethanol Production Daily Recordkeeping: On each day of operation, the Permittee shall record and maintain the total quantity of all ethanol produced at the facility. This shall be based on a flow meter of 200-proof ethanol transferred to the storage tanks. [Minn. R. 7007.0800, subps. 4-5, Title I Condition: Avoid major source under 40 CFR 52.21(b)(1)(i) and Minn. R. 7007.3000]

TFAC 01 01300099

Grain Receiving Daily Recordkeeping: On each day of operation, the Permittee shall calculate, record, and maintain the total quantity of all grain received at the facility. This shall be based on delivery records. [Minn. R. 7007.0800, subps. 4-5, Title I Condition: Avoid major source under 40 CFR 52.21(b)(1)(i) and Minn. R. 7007.3000]

TFAC 01 01300099

Ethanol Monthly Recordkeeping: By the 15th of the month, the Permittee shall calculate and record the following: 1) The total ethanol production for the previous calendar month using the daily production records. 2) The 12-month rolling sum ethanol production in gallons for the previous 12-month period by summing the monthly ethanol production data for the previous 12 months. [Minn. R. 7007.0800, subps. 4-5]

TFAC 01 01300099

Grain throughput monthly recordkeeping: By the 15th of the month, the Permittee shall calculate and record the following: 1) The total grain throughput, in tons, for the previous calendar month using the daily production records. 2) The 12-month rolling sum grain throughput, in tons per year for the previous 12-month period by summing the monthly grain throughput data for the previous 12 months. [Minn. R. 7007.0800, subps. 4-5]

TFAC 01 01300099

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). [Minn. R. 7007.0800, subp. 5(C)]

TFAC 01 01300099

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. [Minn. R. 7007.0800, subp. 5(B)]

TFAC 01 01300099

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 all other years. The records may be maintained in either electronic or paper format. [Minn. R. 7007.1200, subp. 4]

TFAC 01 01300099

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. [Minn. R. 7019.1000, subp. 3]

TFAC 01 01300099

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. [Minn. R. 7019.1000, subp. 2]

TFAC 01 01300099

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. [Minn. R. 7019.1000, subp. 1]

TFAC 01 01300099

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. [Minn. R. 7019.1000, subp. 1]

TFAC 01 01300099

The Permittee shall submit a semiannual deviations report : Due semiannually, by the 30th of January and July. 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 - December 31. If no deviations have occurred, the Permittee shall submit the report stating no deviations. [Minn. R. 7007.0800, subp. 6(A)(2)]

TFAC 01 01300099

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. [Minn. R. 7007.0400, subp. 3, Minn. R. 7007.1150 - 7007.1500]

TFAC 01 01300099 The Permittee shall submit an application for permit reissuance : Due 180 calendar days before Permit Expiration Date. [Minn. R. 7007.0400, subp. 2]

TFAC 01 01300099

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). Performance testing deadlines from the General Provisions of 40 CFR pt. 60 and pt. 63 are examples of deadlines for which the MPCA does not have authority to grant extensions and therefore do not meet the requirements of Minn. R. 7007.1400, subp. 1(H). [Minn. R. 7007.1400, subp. 1(H)]

TFAC 01 01300099

The Permittee shall submit a compliance certification : Due annually, by the 31st of January (for the previous calendar year). The Permittee shall submit this to the Commissioner on a form approved by the Commissioner. This report covers all deviations experienced during the calendar year. [Minn. R. 7007.0800, subp. 6(C)]

TFAC 01 01300099

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

TFAC 01 01300099 Emission Fees: due 30 days after receipt of an MPCA bill. [Minn. R. 7002.0005-7002.0095]

TREA 01 CE001

Control Equipment Replacement. The Permittee may replace TREA 1 with listed control equipment which has equal or better control efficiency. If the Permittee replaces any existing equipment, such equipment is subject to all of the requirements of TREA 1 as well as the requirements in the Total Facility subject item of this permit. The "equal or better removal efficiency" shall be defined by the control equipment efficiencies listed in this permit for TREA 1. Prior to making such a change, the Permittee shall apply for and obtain the appropriate permit amendment, as applicable. The Permittee shall complete calculations described in Minn. R. 7007.1200. Written notifications shall be submitted to the Agency at least 7 days before making the changes. A permit amendment is still required regardless of the emissions increase if the change will be subject to a new applicable requirement or requires revisions to limits or monitoring and recordkeeping requirements in this permit. Any replaced fabric filter should be identified with a unique TREA number in the equipment inventory in Appendix D of this permit. [Minn. R. 7007.0800, subps. 5 & 14, Title I Condition: Avoid major source under 40 CFR 52.21(b)(1)(i) & Minn. R. 7007.3000]

TREA 01 CE001

The Permittee shall operate and maintain the control equipment such that it achieves an overall control efficiency for captured Total Particulate Matter >= 99.6 percent control efficiency. [Minn. R. 7007.0800, subp. 14, Minn. R. 7007.0800, subp. 2, Minn. R. 7011.0070, subp. 1(A), Title I Condition: Avoid major source under 40 CFR 52.21(b)(1)(i) and Minn. R. 7007.3000]

TREA 01 CE001

The Permittee shall operate and maintain the control equipment such that it achieves an overall control efficiency for captured PM < 10 micron >= 98.9 percent control efficiency. [Minn. R. 7007.0800, subp. 14, Minn. R. 7007.0800, subp. 2, Minn. R. 7011.0070, subp. 1(A), Title I Condition: Avoid major source under 40 CFR 52.21(b)(1)(i) and Minn. R. 7007.3000]

TREA 01 CE001

The Permittee shall operate and maintain the control equipment such that it achieves an overall control efficiency for captured PM < 2.5 micron >= 98.9 percent control efficiency. [Minn. R. 7007.0800, subp. 14, Minn. R. 7007.0800, subp. 2, Minn. R. 7011.0070, subp. 1(A), Title I Condition: Avoid major source under 40 CFR 52.21(b)(1)(i) and Minn. R. 7007.3000]

TREA 01 CE001

The Permittee shall operate and maintain the control equipment such that it achieves a capture efficiency for Total Particulate Matter >= 80.0 percent capture efficiency from grain unloading (EQUI 1) and DDGS loading (EQUI 2) operations venting to STRU 9/TREA 1. Emissions from grain unloading are identified as "Grain receiving pit captured emissions (EQUI 1)" and "Grain receiving pit uncaptured emissions (EQUI 80) ". Emissions from DDGS loadout are identified as "DDGS loadout captured emissions (EQUI 2 )" and "DDGS loadout uncaptured emissions (EQUI 81)". After EQUI 1 and EQUI 2 vent to STRU 9, any remaining units will have 100% capture. [Minn. R. 7007.0800, subp. 14, Minn. R. 7007.0800, subps. 1-2, Title I Condition: Avoid major source under 40 CFR 52.21(b)(1)(i) and Minn. R. 7007.3000]

TREA 01 CE001

The Permittee shall operate and maintain the control equipment such that it achieves a capture efficiency for PM < 10 micron >= 80.0 percent capture efficiency from grain unloading (EQUI 1) and DDGS loading (EQUI 2) operations venting to STRU 9/TREA 1. Emissions from grain unloading are identified as "Grain receiving pit captured emissions (EQUI 1)" and "Grain receiving pit uncaptured emissions (EQUI 80) ". Emissions from DDGS loadout are identified as "DDGS loadout captured emissions (EQUI 2 )" and "DDGS loadout uncaptured emissions (EQUI 81)". After EQUI 1 and EQUI 2 vent to STRU 9, any remaining units will have 100% capture. [Minn. R. 7007.0800, subp. 14, Minn. R. 7007.0800, subps. 1-2, Title I Condition: Avoid major source under 40 CFR 52.21(b)(1)(i) and Minn. R. 7007.3000]

TREA 01 CE001

The Permittee shall operate and maintain the control equipment such that it achieves a capture efficiency for PM < 2.5 micron >= 80.0 percent capture efficiency from grain unloading (EQUI 1) and DDGS loading (EQUI 2) operations venting to STRU 9/TREA 1. Emissions from grain unloading are identified as "Grain receiving pit captured emissions (EQUI 1)" and "Grain receiving pit uncaptured emissions (EQUI 80) ". Emissions from DDGS loadout are identified as "DDGS loadout captured emissions (EQUI 2 )" and "DDGS loadout uncaptured emissions (EQUI 81)". After EQUI 1 and EQUI 2 vent to STRU 9, any remaining units will have 100% capture. [Minn. R. 7007.0800, subp. 14, Minn. R. 7007.0800, subps. 1-2, Title I Condition: Avoid major source under 40 CFR 52.21(b)(1)(i) and Minn. R. 7007.3000]

TREA 01 CE001

Pressure Drop >= 0.5 and <= 6 inches of water column, unless a new range is set pursuant to Minn. R. 7017.2025, subp. 3 based on the values recorded during the most recent MPCA-approved performance test where compliance was demonstrated. The new range shall be implemented upon receipt of the Notice of Compliance letter granting preliminary approval. The range is final upon issuance of a permit amendment incorporating the change. [Minn. R. 7007.0800, subp. 14, Minn. R. 7007.0800, subp. 2, Minn. R. 7011.0080, Title I Condition: Avoid major source under 40 CFR 52.21(b)(1)(i) and Minn. R. 7007.3000]

TREA 01 CE001

The Permittee shall operate and maintain the fabric filter at all times that any emission unit controlled by the fabric filter is in operation. The Permittee shall document periods of non-operation of the control equipment. [Minn. R. 7007.0800, subp. 14, Minn. R. 7007.0800, subp. 2, Title I Condition: Avoid major source under 40 CFR 52.21(b)(1)(i) and Minn. R. 7007.3000]

TREA 01 CE001

Visible Emissions: The Permittee shall check the fabric filter stack (STRU 9) for any visible emissions once each day of operation during daylight hours. During inclement weather, the Permittee shall read and record the pressure drop across the fabric filter, once each day of operation. [Minn. R. 7007.0800, subp. 14, Minn. R. 7007.0800, subp. 2, Minn. R. 7011.0080, Title I Condition: Avoid major source under 40 CFR 52.21(b)(1)(i) and Minn. R. 7007.3000]

TREA 01 CE001

Recordkeeping of Visible Emissions and Pressure Drop: The Permittee shall record the time and date of each visible emission inspection and pressure drop reading, and whether or not any visible emissions were observed, and whether or not the observed pressure drop was within the range specified in this permit. [Minn. R. 7007.0800, subp. 14, Minn. R. 7007.0800, subp. 2, Minn. R. 7011.0080, Title I Condition: Avoid major source under 40 CFR 52.21(b)(1)(i) and Minn. R. 7007.3000]

TREA 01 CE001

Corrective Actions: The Permittee shall take corrective action as soon as possible if any of the following occur: - visible emissions are observed; - the recorded pressure drop is outside the required operating range; - the fabric filter or any of its components are found during the inspections to need repair. Corrective actions shall return the pressure drop to within the permitted range, eliminate visible emissions, and/or 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 fabric filter. The Permittee shall keep a record of the type and date of any corrective action taken for each filter. [40 CFR 64.7(d)(1), Minn. R. 7007.0800, subp. 14, Minn. R. 7007.0800, subps. 4-5, Minn. R. 7017.0200]

TREA 01 CE001

Monitoring Equipment: The Permittee shall install and maintain the necessary monitoring equipment for measuring and recording pressure drop as required by this permit. The monitoring equipment must be installed, in use, and properly maintained when the monitored fabric filter is in operation. [Minn. R. 7007.0800, subp. 4, Minn. R. 7011.0075, subp. 3]

TREA 01 CE001

The Permittee shall maintain each piece of control equipment according to the manufacturer's specification, shall conduct inspections, and maintain documentation of those actions as required by Minn. R. 7011.0075, subp. 2(A) to 2(I). [Minn. R. 7011.0075, subp. 2]

TREA 01 CE001

The Permittee shall operate and maintain the fabric 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. [Minn. R. 7007.0800, subp. 14]

TREA 01 CE001

Periodic Inspections: At least once per calendar quarter, or more frequently as required by the manufacturing specifications, the Permittee shall inspect the control equipment components. The Permittee shall maintain a written record of these inspections. [Minn. R. 7007.0800, subps. 2 & 14]

TREA 01 CE001

Hood Certification and Evaluation for Grain Receiving Building: The control device hood must be evaluated by a testing company as specified in Minn. R. 7011.0072, subp. 2(A) and must conform to the design and operating requirements listed in Minn. R. 7011.0072, subps. 2(B) and 3. The hood certification must address how cross-drafts are accommodated in the design (e.g., higher face velocity, oversized hood, etc.) and the Permittee shall certify this as specified in Minn. R. 7011.0072, subps. 2 and 3. The Permittee shall maintain the most current record of the hood evaluation and certification on site. [Minn. R. 7011.0072, subps. 2 - 4]

TREA 01 CE001

Annual Hood Evaluation for Grain Receiving Building: The Permittee shall measure and record at least once every 12 months the fan rotation speed, fan power draw, or face velocity of each hood, or other comparable air flow parameter that was measured during the initial hood certification to verify the hood design and operation parameters meet or exceed the parameters measured during the initial hood evaluation conducted according to Minn. R. 7011.0072, subps. 2 & 3 as required by Minn. R. 7011.0072, subp. 4. The Permittee shall maintain a copy of the annual evaluations on site for 5 years. [Minn. R. 7011.0072, subp. 4]

TREA 01 CE001

Hood Certification and Evaluation for DDGS Loadout: The control device hood must be evaluated by a testing company as specified in Minn. R. 7011.0072, subp. 2(A) and must conform to the design and operating requirements listed in Minn. R. 7011.0072, subps. 2(B) and 3. The hood certification must address how cross-drafts are accommodated in the design (e.g., higher face velocity, oversized hood, etc.) and the Permittee shall certify this as specified in Minn. R.

7011.0072, subps. 2 and 3. The Permittee shall maintain the most current record of the hood evaluation and certification on site. [Minn. R. 7011.0072, subps. 2 - 4]

TREA 01 CE001

Annual Hood Evaluation for DDGS Loadout: The Permittee shall measure and record at least once every 12 months the fan rotation speed, fan power draw, or face velocity of each hood, or other comparable air flow parameter that was measured during the initial hood certification to verify the hood design and operation parameters meet or exceed the parameters measured during the initial hood evaluation conducted according to Minn. R. 7011.0072, subps. 2 & 3 as required by Minn. R. 7011.0072, subp. 4. The Permittee shall maintain a copy of the annual evaluations on site for 5 years. [Minn. R. 7011.0072, subp. 4]

TREA 01 CE001

The Permittee shall submit a report : Due by 45 days after permit issuance that certifies that the grain receiving and DDGS loadout hoods conform to the requirements of the reference listed in Minn. R. 7011.0061. The Permittee shall submit the results of the evaluation and certification on forms HE-01 and CR-02. [Minn. R. 7011.0072, subps. 2-4]

TREA 02 CE002

Control Equipment Replacement. The Permittee may replace TREA 2 with listed control equipment which has equal or better control efficiency. If the Permittee replaces any existing equipment, such equipment is subject to all of the requirements of TREA 2 as well as the requirements in the Total Facility subject item of this permit. The "equal or better control efficiency" shall be defined by the control equipment efficiencies listed in this permit for TREA 2. Prior to making such a change, the Permittee shall apply for and obtain the appropriate permit amendment, as applicable. The Permittee shall complete calculations described in Minn. R. 7007.1200. Written notifications shall be submitted to the Agency at least 7 days before making the changes. A permit amendment is still required regardless of the emissions increase if the change will be subject to a new applicable requirement or requires revisions to limits or monitoring and recordkeeping requirements in this permit. Any replaced fabric filter should be identified with a unique TREA number in the equipment inventory in Appendix D of this permit. [Minn. R. 7007.0800, subps. 5 & 14, Title I Condition: Avoid major source under 40 CFR 52.21(b)(1)(i) and Minn. R. 7007.3000]

TREA 02 CE002

The Permittee shall operate and maintain the control equipment such that it achieves an overall control efficiency for Total Particulate Matter >= 99.6 percent control efficiency. [Minn. R. 7007.0800, subp. 14, Minn. R. 7007.0800, subp. 2, Minn. R. 7011.0070, subp. 1(A), Title I Condition: Avoid major source under 40 CFR 52.21(b)(1)(i) and Minn. R. 7007.3000]

TREA 02 CE002

The Permittee shall operate and maintain the control equipment such that it achieves an overall control efficiency for PM < 10 micron >= 99.0 percent control efficiency. [Minn. R. 7007.0800, subp. 14, Minn. R. 7007.0800, subp. 2, Minn. R. 7011.0070, subp. 1(A), Title I Condition: Avoid major source under 40 CFR 52.21(b)(1)(i) and Minn. R. 7007.3000]

TREA 02 CE002

The Permittee shall operate and maintain the control equipment such that it achieves an overall control efficiency for PM < 2.5 micron >= 99.0 percent control efficiency. [Minn. R. 7007.0800, subp. 14, Minn. R. 7007.0800, subp. 2, Minn. R. 7011.0070, subp. 1(A), Title I Condition: Avoid major source under 40 CFR 52.21(b)(1)(i) and Minn. R. 7007.3000]

TREA 02 CE002

Pressure Drop >= 0.5 and <= 6 inches of water column, unless a new range is set pursuant to Minn. R. 7017.2025, subp. 3 based on the values recorded during the most recent MPCA-approved performance test where compliance was demonstrated. The new range shall be implemented upon receipt of the Notice of Compliance letter granting preliminary approval. The range is final upon issuance of a permit amendment incorporating the change. [Minn. R. 7007.0800, subp. 14, Minn. R. 7007.0800, subp. 2, Minn. R. 7011.0080, Title I Condition: Avoid major source under 40 CFR 52.21(b)(1)(i) and Minn. R. 7007.3000]

TREA 02 CE002

The Permittee shall operate and maintain the fabric filter TREA 2 at all times that any emission unit controlled by the fabric filter is in operation. The Permittee shall document periods of non-operation of the control equipment. [Minn. R. 7007.0800, subp. 14, Minn. R. 7007.0800, subp. 2, Minn. R. 7011.0080, Title I Condition: Avoid major source under 40 CFR 52.21(b)(1)(i) and Minn. R.

7007.3000]

TREA 02 CE002

Visible Emissions: The Permittee shall check the fabric filter stack STRU 10 for any visible emissions once each day of operation during daylight hours. During inclement weather, the Permittee shall read and record the pressure drop across the fabric filter, once each day of operation. [40 CFR 64.3, Minn. R. 7007.0800, subp. 14, Minn. R. 7007.0800, subp. 2, Minn. R. 7011.0080, Minn. R. 7017.0200, Title I Condition: Avoid major source under 40 CFR 52.21(b)(1)(i) and Minn. R. 7007.3000]

TREA 02 CE002

Recordkeeping of Visible Emissions and Pressure Drop: The Permittee shall record the time and date of each visible emission inspection and pressure drop reading, and whether or not any visible emissions were observed, and whether or not the observed pressure drop was within the range specified in this permit. [Minn. R. 7007.0800, subp. 14, Minn. R. 7007.0800, subp. 2, Minn. R. 7011.0080, Title I Condition: Avoid major source under 40 CFR 52.21(b)(1)(i) and Minn. R. 7007.3000]

TREA 02 CE002

Corrective Actions: The Permittee shall take corrective action as soon as possible if any of the following occur: - visible emissions are observed; - the recorded pressure drop is outside the required operating range; - the fabric filter or any of its components are found during the inspections to need repair. Corrective actions shall return the pressure drop to within the permitted range, eliminate visible emissions, and/or 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 fabric filter. The Permittee shall keep a record of the type and date of any corrective action taken for each filter. [Minn. R. 7007.0800, subp. 14, Minn. R. 7007.0800, subps. 4-5]

TREA 02 CE002

Monitoring Equipment: The Permittee shall install and maintain the necessary monitoring equipment for measuring and recording pressure drop as required by this permit. The monitoring equipment must be installed, in use, and properly maintained when the monitored fabric filter is in operation. [Minn. R. 7007.0800, subp. 4, Minn. R. 7011.0075, subp. 3]

TREA 02 CE002


TREA 02 CE002


TREA 02 CE002

Periodic Inspections: At least once per calendar quarter, or more frequently as required by the manufacturing specifications, the Permittee shall inspect the control equipment components. The Permittee shall maintain a written record of these inspections. [Minn. R. 7007.0800, subps. 2 & 14]

TREA 03 CE003

Control Equipment Replacement. If the Permittee replaces or modifies TREA 3, such equipment is subject to all of the requirements of TREA 3 and the requirements in the Total Facility subject item of this permit. Prior to making such a change, the Permittee shall apply for and obtain the appropriate permit amendment, as applicable. The Permittee shall complete calculations described in Minn. R. 7007.1200. Written notifications shall be submitted to the Agency at least 7 days before making the changes. A permit amendment is still required regardless of the emissions increase if the change will be subject to a new applicable requirement or requires revisions to limits or monitoring and recordkeeping requirements in this permit. Any replaced fabric filter should be identified with a unique TREA number in the equipment inventory in Appendix D of this permit. [Minn. R. 7007.0800, subps. 5 & 14, Title I Condition: Avoid major source under 40 CFR 52.21(b)(1)(i) and Minn. R. 7007.3000]

TREA 03 CE003

The Permittee shall operate and maintain control equipment such that it achieves a control efficiency for Total Particulate Matter >= 99 percent control efficiency. [Minn. R. 7011.0070, subp. 1(A), Title I Condition: Avoid major source under 40 CFR 52.21(b)(1)(i) and Minn. R. 7007.3000]

TREA 03 CE003

The Permittee shall operate and maintain control equipment such that it achieves a control efficiency for PM < 10 micron >= 93 percent control efficiency. [Minn. R. 7011.0070, subp. 1(A), Title I Condition: Avoid major source under 40 CFR 52.21(b)(1)(i) and Minn. R. 7007.3000]

TREA 03 CE003

The Permittee shall operate and maintain control equipment such that it achieves a control efficiency for PM < 2.5 micron >= 93 percent control efficiency. [Title I Condition: Avoid major source under 40 CFR 52.21(b)(1)(i) and Minn. R. 7007.3000]

TREA 03 CE003

Pressure Drop >= 0.5 and <= 6.0 inches of water, unless a new range is set pursuant to Minn. R. 7017.2025, subp. 3 based on the values recorded during the most recent MPCA-approved performance test where compliance was demonstrated. The new range shall be implemented upon receipt of the Notice of Compliance letter granting preliminary approval. The range is final upon issuance of a permit amendment incorporating the change. The Permittee shall record the pressure drop at least once every 24 hours when in operation. [Minn. R. 7011.0080, Minn. R. 7017.2025, Title I Condition: Avoid major source under 40 CFR 52.21(b)(1)(i) and Minn. R. 7007.3000]

TREA 03 CE003

The Permittee shall operate and maintain the fabric filter (TREA 3) at all times that any emission unit controlled by the fabric filter is in operation. The Permittee shall document periods of non-operation of the control equipment. [Minn. R. 7007.0800, subp. 14, Minn. R. 7007.0800, subp. 2, Title I Condition: Avoid major source under 40 CFR 52.21(b)(1)(i) and Minn. R. 7007.3000]

TREA 03 CE003

Visible Emissions: The Permittee shall check the fabric filter stack (STRU 11) for any visible emissions once each day of operation during daylight hours. During inclement weather, the Permittee shall read and record the pressure drop across the fabric filter, once each day of operation. [Minn. R. 7011.0080, Title I Condition: Avoid major source under 40 CFR 52.21(b)(1)(i) and Minn. R. 7007.3000]

TREA 03 CE003

Recordkeeping of Visible Emissions and Pressure Drop. The Permittee shall record the time and date of each visible emission inspection and pressure drop reading, and whether or not any visible emissions were observed, and whether or not the observed pressure drop was within the range specified in this permit. [Minn. R. 7011.0080, Title I Condition: Avoid major source under 40 CFR 52.21(b)(1)(i) and Minn. R. 7007.3000]

TREA 03 CE003

Corrective Actions: The Permittee shall take corrective action as soon as possible if any of the following occur: - visible emissions are observed; - the recorded pressure drop is outside the required operating range; or - the fabric filter or any of its components are found during the inspections to need repair. Corrective actions shall return the pressure drop to within the permitted range, eliminate visible emissions, and/or 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 fabric filter. The Permittee shall keep a record of the type and date of any corrective action taken for each filter. [Minn. R. 7007.0800, subp. 14, Minn. R. 7007.0800, subp. 4, Minn. R. 7007.0800, subp. 5]

TREA 03 CE003

Monitoring Equipment: The Permittee shall install and maintain the necessary monitoring equipment for measuring and recording pressure drop as required by this permit. The monitoring equipment must be installed, in use, and properly maintained when the monitored fabric filter is in operation. [Minn. R. 7011.0075, subp. 3]

TREA 03 CE003


TREA 03 CE003


TREA 03 CE003

Periodic Inspections: At least once per calendar quarter, or more frequently as required by the manufacturing specifications, the Permittee shall inspect the control equipment components. The Permittee shall maintain a written record of these inspections. [Minn. R. 7007.0800, subp. 14, Minn. R. 7007.0800, subp. 4, Minn. R. 7007.0800, subp. 5]

TREA 04 CE004


TREA 04 CE004


TREA 04 CE004


TREA 04 CE004


TREA 04 CE004


TREA 04 CE004


TREA 04 CE004


TREA 04 CE004


TREA 04 CE004


TREA 04 CE004


TREA 04 CE004


TREA 04 CE004


TREA 04 CE004


TREA 05 CE005


TREA 05 CE005


TREA 05 CE005


TREA 05 CE005


TREA 05 CE005


TREA 05 CE005


TREA 05 CE005


TREA 05 CE005


TREA 05 CE005


TREA 05 CE005


TREA 05 CE005


TREA 05 CE005


TREA 05 CE005


TREA 06 CE006


TREA 06 CE006


TREA 06 CE006


TREA 06 CE006


TREA 06 CE006


TREA 06 CE006


TREA 06 CE006


TREA 06 CE006


TREA 06 CE006


TREA 06 CE006


TREA 06 CE006


TREA 06 CE006


TREA 06 CE006


TREA 07 CE007

When emissions are not vented to the regenerative thermal oxidizer (RTO), the Permittee shall operate and maintain control equipment such that it achieves an overall control efficiency for Volatile Organic Compounds >= 95.0 percent control efficiency. [Minn. R. 7007.0800, subp. 14, Minn. R. 7007.0800, subp. 2, Title I Condition: Avoid major source under 40 CFR 52.21(b)(1)(i) and Minn. R. 7007.3000, Title I Condition: Avoid major source under 40 CFR 63.2]

TREA 07 CE007

Control Equipment Replacement. If the Permittee replaces or modifies TREA 7, such equipment is subject to all of the requirements of TREA 7 and the requirements in the Total Facility subject item of this permit. Prior to making such a change, the Permittee shall apply for and obtain the appropriate permit amendment, as applicable. The Permittee shall complete calculations described in Minn. R. 7007.1200. Written notifications shall be submitted to the Agency at least 7 days before making the changes. A permit amendment is still required regardless of the emissions increase if the change will be subject to a new applicable requirement or requires revisions to limits or monitoring and recordkeeping requirements in this permit. Any replaced wet scrubber should be identified with a unique TREA number in the equipment inventory in Appendix D of this permit. [Minn. R. 7007.0800, subps. 5 & 14, Title I Condition: Avoid major source under 40 CFR 52.21(b)(1)(i) & Minn. R. 7007.3000]

TREA 07 CE007

Pressure Drop >= 2.0 and <= 10.0 inches of water column or as measured during the most recent stack emissions test that demonstrated compliance. [Title I Condition: Avoid major source under 40 CFR 52.21(b)(1)(i) and Minn. R. 7007.3000, Title I Condition: Avoid major source under 40 CFR 63.2]

TREA 07 CE007

Water flow rate >= 35.0 gallons per minute through the scrubber when emissions are vented to the Regenerative Thermal Oxidizer (RTO), or as measured during the most recent stack emissions test that demonstrated compliance. This flow rate is required only when the emissions are vented to the RTO, which is normal operation. Scrubber water flow rate: >= 49.5 gpm when emissions ARE NOT vented to the RTO, or as measured during the most recent stack emissions test that demonstrated compliance. This flow rate is required only when the emissions are not vented to the RTO. [Title I Condition: Avoid major source under 40 CFR 52.21(b)(1)(i) and Minn. R. 7007.3000, Title I Condition: Avoid major source under 40 CFR 63.2]

TREA 07 CE007

If the pressure drop or the water flow rate is not equal to or greater than the applicable minimum value specified herein, the Permittee shall take corrective action as soon as possible to achieve the required operating values. The Permittee shall keep a record of the type and date of all corrective actions taken. [Title I Condition: Avoid major source under 40 CFR 52.21(b)(1)(i) and Minn. R. 7007.3000, Title I Condition: Avoid major source under 40 CFR 63.2]

TREA 07 CE007

Calibrate the gauges annually, or as often as required by manufacturing specifications and maintain a written record of the calibration and any action resulting from the calibration. [Minn. R. 7007.0800, subp. 2, Minn. R. 7007.0800, subp. 14]

TREA 07 CE007

Inspect monthly, or as required by manufacturing specifications, all components that are subject to wear or plugging. Maintain a written record of the inspection and any action resulting from the inspection. [Minn. R. 7007.0800, subp. 14, Minn. R. 7007.0800, subp. 2]

TREA 08 CE008

Control Equipment Replacement. If the Permittee replaces or modifies TREA 8, such equipment is subject to all of the requirements of TREA 8 and the requirements in the Total Facility subject item of this permit. Prior to making such a change, the Permittee shall apply for and obtain the appropriate permit amendment, as applicable. The Permittee shall complete calculations described in Minn. R. 7007.1200. Written notifications shall be submitted to the Agency at least 7 days before making the changes. A permit amendment is still required regardless of the emissions increase if the change will be subject to a new applicable requirement or requires revisions to limits or monitoring and recordkeeping requirements in this permit. Any replaced fabric filter should be identified with a unique TREA number in the equipment inventory in Appendix D of this permit. [Minn. R. 7007.0800, subps. 5 & 14, Title I Condition: Avoid major source under 40 CFR 52.21(b)(1)(i) & Minn. R. 7007.3000]

TREA 08 CE008 Fuel type: Limited to natural gas only, by design. [Minn. R. 7005.0100, subp. 35a]

TREA 08 CE008

The Permittee shall operate and maintain the control equipment such that it achieves an overall control efficiency for Volatile Organic Compounds >= 95.0 percent control efficiency. [Minn. R. 7007.0800, subp. 14, Minn. R. 7007.0800, subp. 2, Title I Condition: Avoid major source under 40 CFR 52.21(b)(1)(i) and Minn. R. 7007.3000, Title I Condition: Avoid major source under 40 CFR 63.2]

TREA 08 CE008

The Permittee shall operate and maintain the control equipment such that it achieves an overall control efficiency for Carbon Monoxide >= 90.0 percent control efficiency. [Minn. R. 7007.0800, subp. 14, Minn. R. 7007.0800, subp. 2, Title I Condition: Avoid major source under 40 CFR 52.21(b)(1)(i) and Minn. R. 7007.3000]

TREA 08 CE008

The Permittee shall operate and maintain the control equipment such that it achieves an overall control efficiency for Total Particulate Matter >= 90.0 percent control efficiency. [Minn. R. 7007.0800, subp. 14, Minn. R. 7007.0800, subp. 2, Title I Condition: Avoid major source under 40 CFR 52.21(b)(1)(i) and Minn. R. 7007.3000]

TREA 08 CE008

The Permittee shall operate and maintain the control equipment such that it achieves an overall control efficiency for PM < 10 micron >= 90.0 percent control efficiency. [Minn. R. 7007.0800, subp. 14, Minn. R. 7007.0800, subp. 2, Title I Condition: Avoid major source under 40 CFR 52.21(b)(1)(i) and Minn. R. 7007.3000]

TREA 08 CE008

The Permittee shall operate and maintain the control equipment such that it achieves an overall control efficiency for PM < 2.5 micron >= 90.0 percent control efficiency. [Minn. R. 7007.0800, subp. 14, Minn. R. 7007.0800, subp. 2, Title I Condition: Avoid major source under 40 CFR 52.21(b)(1)(i) and Minn. R. 7007.3000]

TREA 08 CE008

The Permittee shall operate and maintain the regenerative thermal oxidizer at all times that any COMG 3 emission unit controlled by the thermal oxidizer is in operation. The Permittee shall document periods of non-operation of the control equipment. [Minn. R. 7007.0800, subp. 14, Minn. R. 7007.0800, subp. 2, Title I Condition: Avoid major source under 40 CFR 52.21(b)(1)(i) and Minn. R. 7007.3000]

TREA 08 CE008

The Permittee shall operate and maintain the regenerative thermal oxidizer 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. [Minn. R. 7007.0800, subp. 14]

TREA 08 CE008

Temperature >= 1635 degrees Fahrenheit 3-hour rolling average at the combustion chamber outlet, unless a new limit is required to be set pursuant to Minn. R. 7017.2025, subp. 3. If a new minimum is required to be set it will be based on the values recorded during the most recent MPCA-approved performance test where compliance was demonstrated. The new limit shall be implemented upon receipt of the Notice of Compliance letter granting preliminary approval. The limit is final upon issuance of a permit amendment incorporating the change. If the 3-hour rolling average temperature is below the minimum temperature limit, the VOC and CO emitted during that time shall be considered uncontrolled until the average temperature is above the minimum temperature limit. This shall be reported as a deviation. [Minn. R. 7007.0800, subps. 2 & 14, Title I Condition: Avoid major source under 40 CFR 52.21(b)(1)(i) and Minn. R. 7007.3000]

TREA 08 CE008

Temperature Monitoring: The Permittee shall maintain and operate a thermocouple monitoring device that continuously indicates and records the combustion chamber temperature of the thermal oxidizer. The monitoring device shall have a margin of error less than the greater of +/- 0.75 percent of the temperature being measured or +/- 2.5 degrees Celsius. The recording device shall also calculate the three-hour rolling average combustion chamber temperature. Recorded values outside the range specified in this permit are considered Deviations as defined by Minn. R. 7007.0100, subp. 8a. [40 CFR 64.3(b)(4)(ii), Minn. R. 7007.0800, subp. 14, Minn. R. 7007.0800, subp. 2, Minn. R. 7017.0200, Title I Condition: Avoid major source under 40 CFR 52.21(b)(1)(i) and Minn. R. 7007.3000]

TREA 08 CE008

Daily Monitoring: The Permittee shall physically verify the operation of the temperature recording device at least once each operating day to verify that it is working and recording properly. The Permittee shall maintain a written record of the daily verifications. [40 CFR 64.3(b), Minn. R. 7007.0800, subps. 2 & 14, Minn. R. 7017.0200, Title I Condition: Avoid major source under 40 CFR 52.21(b)(1)(i) and Minn. R. 7007.3000]

TREA 08 CE008

Monitoring Equipment: The Permittee shall install and maintain thermocouples to conduct temperature monitoring required by this permit. The monitoring equipment must be installed, in use, and properly maintained whenever operation of the monitored control equipment is required. [40 CFR 64.7(b), Minn. R. 7017.0200]

TREA 08 CE008

The Permittee shall maintain a continuous hard copy readout or computer disk file of the temperature readings and calculated three hour rolling average temperatures for the combustion chamber. [40 CFR 64.9(b), Minn. R. 7007.0800, subps 2 & 14, Minn. R. 7017.0200, Title I Condition: Avoid major source under 40 CFR 52.21(b)(1)(i) and Minn. R. 7007.3000]

TREA 08 CE008

Annual Calibration: The Permittee shall calibrate the temperature monitor at least once every 12 months and shall maintain a written record of the calibration and any action resulting from the calibration. [40 CFR 64.3, Minn. R. 7017.0200]

TREA 08 CE008

Quarterly Inspections: At least once per calendar quarter, the Permittee shall inspect the control equipment internal and external system components, including but not limited to the refractory, heat exchanger, and electrical systems. The Permittee shall maintain a written record of the inspection and any corrective actions taken resulting from the inspection. [40 CFR 64.3, Minn. R. 7017.0200]

TREA 08 CE008

Annual Inspection: At least once per calendar year, the Permittee shall conduct an internal inspection of the control device that includes all operating systems of the control device. The Permittee shall maintain a written record of the inspection and any action resulting from the inspection. [40 CFR 64.3, Minn. R. 7017.0200]

TREA 08 CE008

For periods when the thermal oxidizer is operated above the minimum combustion chamber temperature, the Permittee shall use either one of the following when completing calculations as required elsewhere in this permit: a. The overall control efficiency limit specified in this permit for this equipment (95.0%); OR b. The overall control efficiency determined during the most recent MPCA approved performance test (see STRU 16). If the tested efficiency is less than the efficiency limit in this permit, the Permittee must use the tested value in all calculations until the efficiency is demonstrated to be above the permit limit through a new test. [Minn. R. 7007.0800, subps. 4-5, Title I Condition: Avoid major source under 40 CFR 52.21(b)(1)(i) and Minn. R. 7007.3000]

TREA 08 CE008

Corrective Actions: If the temperature is below the minimum specified by this permit or if the thermal oxidizer or any of its components are found during the inspections to need repair, the Permittee shall take corrective action as soon as possible. Corrective actions shall return the temperature to at least the permitted minimum and/or 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 thermal oxidizer. The Permittee shall keep a record of the type and date of any corrective action taken. [40 CFR 64.7(d)(1), Minn. R. 7017.0200]

TREA 08 CE008

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 minimum combustion chamber temperature(s), the Permittee shall promptly notify the MPCA and, if necessary, submit a permit amendment application to address the necessary monitoring changes. [40 CFR 64.7(e), Minn. R. 7017.0200]

TREA 08 CE008

As required by 40 CFR Section 64.9(a)(2), for the Semi-Annual Deviations Report listed in section 6 of this permit and/or the Notification of Deviations Endangering Human Health and the Environment listed earlier in section 5 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. [40 CFR 64.9(a)(2), Minn. R. 7017.0200]

TREA 08 CE008

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. [40 CFR 64.9(b), Minn. R. 7017.0200]

TREA 11 CE011


TREA 11 CE011


TREA 11 CE011


TREA 11 CE011


TREA 11 CE011


TREA 11 CE011


TREA 11 CE011

Recordkeeping of Pressure Drop. The Permittee shall record the time and date of each pressure drop reading, and whether or not the observed pressure drop was within the range specified in this permit. [Minn. R. 7011.0080, Title I Condition: Avoid major source under 40 CFR 52.21(b)(1)(i) and Minn. R. 7007.3000]

TREA 11 CE011


TREA 11 CE011


TREA 11 CE011


TREA 11 CE011


TREA 11 CE011


TREA 12 CE012


TREA 12 CE012


TREA 12 CE012


TREA 12 CE012


TREA 12 CE012


TREA 12 CE012


TREA 12 CE012


TREA 12 CE012


TREA 12 CE012


TREA 12 CE012


TREA 12 CE012


TREA 12 CE012


TREA 12 CE012


TREA 13 CE013


TREA 13 CE013


TREA 13 CE013


TREA 13 CE013


TREA 13 CE013


TREA 13 CE013


TREA 13 CE013


TREA 13 CE013


TREA 13 CE013


TREA 13 CE013


TREA 13 CE013


TREA 13 CE013


TREA 13 CE013


TREA 14 CE014

Control Equipment Replacement. If the Permittee replaces or modifies TREA 14, such equipment is subject to all of the requirements of TREA 14 and the requirements in the Total Facility subject item of this permit. Prior to making such a change, the Permittee shall apply for and obtain the appropriate permit amendment, as applicable. The Permittee shall complete calculations described in Minn. R. 7007.1200. Written notifications shall be submitted to the Agency at least 7 days before making the changes. A permit amendment is still required regardless of the emissions increase if the change will be subject to a new applicable requirement or requires revisions to limits or monitoring and recordkeeping requirements in this permit. Any replaced fabric filter should be identified with a unique TREA number in the equipment inventory in Appendix D of this permit. [Minn. R. 7007.0800, subps. 5 & 14, Title I Condition: Avoid major source under 40 CFR 52.21(b)(1)(i) & Minn. R. 7007.3000]

TREA 14 CE014

Flare Operating Hours <= 1000 hours 12-month rolling sum. [Title I Condition: Avoid major source under 40 CFR 52.21(b)(1)(i) and Minn. R. 7007.3000, Title I Condition: Avoid major source under 40 CFR 63.2]

TREA 14 CE014

The Permittee shall operate and maintain the control equipment such that it achieves an overall control efficiency for Volatile Organic Compounds >= 98.0 percent control efficiency. [Minn. R. 7007.0800, subp. 14, Minn. R. 7007.0800, subp. 2, Title I Condition: Avoid major source under 40 CFR 52.21(b)(1)(i) and Minn. R. 7007.3000, Title I Condition: Avoid major source under 40 CFR 63.2]

TREA 14 CE014

Daily Recordkeeping: The Permittee shall read and record the number of hours that the vapor line valve is open and sending loadout vapors to the flare. [Title I Condition: Avoid major source under 40 CFR 52.21(b)(1)(i) and Minn. R. 7007.3000, Title I Condition: Avoid major source under 40 CFR 63.2]

TREA 14 CE014

Flares must be designed and operated with no visible emissions except for a period not to exceed a total of 5 minutes during any 2 consecutive hours. [Minn. R. 7007.0800, subp. 16(J), Minn. R. 7007.0800, subp. 14]

TREA 14 CE014

Monthly Recordkeeping: By the 15th day of each month, the Permittee shall calculate and record the number of hours of flare operation for the previous month, and the previous 12-month period. [Minn. R. 7007.0800, subps. 4-5]

TREA 14 CE014

The flare shall be operated at all times when emissions may be vented to them. [Minn. R. 7007.0800, subp. 14, Minn. R. 7007.0800, subp. 2, Title I Condition: Avoid major source under 40 CFR 52.21(b)(1)(i) and Minn. R. 7007.3000, Title I Condition: Avoid major source under 40 CFR 63.2]

TREA 14 CE014 The flare shall be operated with a flame present at all times. [Minn. R. 7007.0800, subp. 16(J), Minn. R. 7007.0800, subp. 14]

TREA 14 CE014

The presence of a flare pilot flame shall be monitored using a thermocouple or any other equivalent device to detect the presence of a flame. [Minn. R. 7007.0800, subp. 16(J), Minn. R. 7007.0800, subp. 2, Minn. R. 7007.0800, subp. 14]

TREA 14 CE014

Compliance Requirement: Reference Method 22 shall be used to determine the compliance of flares with visible emissions provisions. [Minn. R. 7007.0800, subp. 14, Minn. R. 7007.0800, subp. 16(J), Title I Condition: 40 CFR 63.2, Title I Condition: Avoid major source under 40 CFR 52.21(b)(1)(i) and Minn. R. 7007.3000]

TREA 14 CE014

Operation Requirement: At all times, including periods of startup, shutdown, and malfunction, owners shall maintain and operate any affected facility in a manner consistent with good air pollution control practice for minimizing emissions. Determination of whether acceptable operating and maintenance procedures are being used will be based on information available to the Administrator which may include, but is not limited to, monitoring results, opacity observations, review of operating and maintenance procedures, and inspection of the source. [Minn. R. 7007.0800, subp. 14, Minn. R. 7007.0800, subp. 16(J), Title I Condition: Avoid major source under 40 CFR 52.21(b)(1)(i) and Minn. R. 7007.3000, Title I Condition: Avoid major source under 40 CFR 63.2]

TREA 14 CE014

Operation Requirement: Flares shall be monitored to ensure that they are operated and maintained in conformance with their design. [Minn. R. 7007.0800, subp. 14, Minn. R. 7007.0800, subp. 16(J), Title I Condition: Avoid major source under 40 CFR 52.21(b)(1)(i) and Minn. R. 7007.3000, Title I Condition: Avoid major source under 40 CFR 63.2]

TREA 14 CE014

Recordkeeping: Keep a record of any startup, shutdown, or malfunction in the affected facility or malfunction of the air pollution control equipment. [Minn. R. 7007.0800, subp. 14, Minn. R. 7007.0800, subp. 16(J), Title I Condition: Avoid major source under 40 CFR 52.21(b)(1)(i) and Minn. R. 7007.3000, Title I Condition: Avoid major source under 40 CFR 63.2]

TREA 14 CE014

Recordkeeping: Maintain a file of all measurements, CMS performance evaluations, calibration checks, adjustments and maintenance, and all other information required by this part in permanent form, suitable for inspection for at least two years following the date of such measurements, maintenance, and records. [Minn. R. 7007.0800, subp. 14, Minn. R. 7007.0800, subp. 16(J), Title I Condition: Avoid major source under 40 CFR 52.21(b)(1)(i) and Minn. R. 7007.3000, Title I Condition: Avoid major source under 40 CFR 63.2]

TREA 15 CE015


TREA 15 CE015


TREA 15 CE015


TREA 15 CE015


TREA 15 CE015


TREA 15 CE015


TREA 15 CE015


TREA 15 CE015


TREA 15 CE015


TREA 15 CE015


TREA 15 CE015


TREA 15 CE015


TREA 15 CE015


TREA 16 CE016

The Permittee shall operate and maintain control equipment such that it achieves an overall control efficiency for Volatile Organic Compounds >= 95.0 percent control efficiency. [Minn. R. 7007.0800, subp. 14, Minn. R. 7007.0800, subp. 2, Title I Condition: Avoid major source under 40 CFR 52.21(b)(1)(i) and Minn. R. 7007.3000, Title I Condition: Avoid major source under 40 CFR 63.2]

TREA 21 CE017

The Permittee shall maintain the catalyst so that the pressure drop across the catalyst does not change by more than 2 inches of water column from the pressure drop across the catalyst that was measured during the initial performance test. [40 CFR 63.6603(a), 40 CFR pt. 63, subp. ZZZZ (Table 2b), Minn. R. 7011.8150]

TREA 21 CE017

The Permittee shall maintain the temperature of the stationary RICE exhaust so that the catalyst inlet Temperature >= 450 and <= 1350 degrees Fahrenheit. [40 CFR 63.6603(a), 40 CFR pt. 63, subp. ZZZZ (Table 2b), Minn. R. 7011.8150]

TREA 21 CE017

The Permittee shall vent emissions from EQUI 56 to an oxidation catalyst meeting the permit requirements of TREA 21 whenever EQUI 56 operates, and operate and maintain the oxidation catalyst at all times that any emissions are vented to the oxidation catalyst. The Permittee shall document periods of non-operation of the control equipment. [Minn. R. 7005.0100, subp. 35a, Minn. R. 7007.0800, subp. 2]

TREA 21 CE017

The Permittee shall operate and maintain the catalytic oxidizer 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. [Minn. R. 7007.0800, subp. 14]

TREA 21 CE017

The Permittee shall maintain and operate a thermocouple monitoring device that continuously indicates and records both the inlet and outlet temperatures of the catalytic oxidizer. The monitoring device shall have a margin of error less than the greater of +/- 0.75 percent of the temperature being measured or +/- 4.5 degrees Fahrenheit. The recording device shall also calculate the three-hour rolling average inlet temperature. [Minn. R. 7007.0800, subps. 4-5]

TREA 21 CE017

Daily Monitoring: The Permittee shall physically verify the operation of the temperature recording device at least once each operating day to verify that it is working and recording properly. The Permittee shall maintain a written record of the daily verifications. [Minn. R. 7007.0800, subps. 4-5]

TREA 21 CE017

Monitoring Equipment: The Permittee shall install and maintain thermocouples to conduct temperature monitoring required by this permit. The monitoring equipment must be installed, in use, and properly maintained whenever operation of the monitored control equipment is required. [Minn. R. 7007.0800, subp. 4, Minn. R. 7007.0800, subps. 4-5]

TREA 21 CE017

The Permittee shall maintain a continuous hard copy readout or computer disk file of the temperature readings and calculated three hour rolling average temperatures for the combustion chamber. [Minn. R. 7007.0800, subps. 4-5]

TREA 21 CE017 Annual Calibration: The Permittee shall calibrate the temperature monitor at least once every 12 months and shall maintain a written record of the calibration and any action resulting from the

calibration. [Minn. R. 7007.0800, subp. 14, Minn. R. 7007.0800, subp. 4, Minn. R. 7007.0800, subp. 5]

TREA 21 CE017

Monthly Monitoring: At least once each month during normal operation, the Permittee shall record the temperature rise across the catalyst (outlet temp. - inlet temp.) while the process is running. If it is determined that the catalyst reactivity has been impaired, by comparison of the observed temperature rise to the past temperature rise records, the Permittee shall follow the corrective actions in the Operation and Maintenance Plan. The Permittee shall maintain written records of the monitoring and any corrective actions taken. [Minn. R. 7007.0800, subp. 14, Minn. R. 7007.0800, subp. 4, Minn. R. 7007.0800, subp. 5]

TREA 21 CE017

Quarterly Inspections: At least once per calendar quarter, the Permittee shall inspect the control equipment internal and external system components, including but not limited to the refractory, heat exchanger, and electrical systems. The Permittee shall maintain a written record of the inspection and any corrective actions taken resulting from the inspection. [Minn. R. 7007.0800, subp. 14, Minn. R. 7007.0800, subp. 4, Minn. R. 7007.0800, subp. 5]

TREA 21 CE017

Annual Inspection: At least once per calendar year, the Permittee shall conduct an internal inspection of the control device that includes all operating systems of the control device. The Permittee shall maintain a written record of the inspection and any action resulting from the inspection. [Minn. R. 7007.0800, subp. 14, Minn. R. 7007.0800, subp. 4, Minn. R. 7007.0800, subp. 5]

TREA 21 CE017

Corrective Actions: If the temperature is below the minimum specified by this permit or if the catalytic oxidizer or any of its components are found during the inspections to need repair, the Permittee shall take corrective action as soon as possible. Corrective actions shall return the temperature to at least the permitted minimum and/or 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 catalytic oxidizer. The Permittee shall keep a record of the type and date of any corrective action taken. [Minn. R. 7007.0800, subp. 14, Minn. R. 7007.0800, subp. 4, Minn. R. 7007.0800, subp. 5]

TREA 22 CE018


TREA 22 CE018


TREA 22 CE018


TREA 22 CE018


TREA 22 CE018


TREA 22 CE018


TREA 22 CE018


TREA 22 CE018


TREA 22 CE018

Annual Calibration: The Permittee shall calibrate the temperature monitor at least once every 12 months and shall maintain a written record of the calibration and any action resulting from the calibration. [Minn. R. 7007.0800, subp. 14, Minn. R. 7007.0800, subp. 4, Minn. R. 7007.0800, subp. 5]

TREA 22 CE018


TREA 22 CE018


TREA 22 CE018


TREA 22 CE018


TREA 23 CE019


TREA 23 CE019


TREA 23 CE019


TREA 23 CE019


TREA 23 CE019


TREA 23 CE019


TREA 23 CE019


TREA 23 CE019


TREA 23 CE019

Annual Calibration: The Permittee shall calibrate the temperature monitor at least once every 12 months and shall maintain a written record of the calibration and any action resulting from the calibration. [Minn. R. 7007.0800, subp. 14, Minn. R. 7007.0800, subp. 4, Minn. R. 7007.0800, subp. 5]

TREA 23 CE019


TREA 23 CE019


TREA 23 CE019


TREA 23 CE019


Attachment 3: Subject item inventory

Category Type TEMPO ID DeltaDesignation

Description Groups

Activity Insignificant Air Emissions Activity ACTV 04 All IA's NoneEquipment Material Handling Equipment EQUI 01 EU001 Grain receiving pit captured emissions NoneEquipment Loading Unloading Equipment EQUI 02 EU002 DDGS loadout captured emissions NoneEquipment Loading Unloading Equipment EQUI 03 EU003 Grain Bin Loading NoneEquipment Elevator EQUI 04 EU004 Grain Elevator NoneEquipment Conveyor EQUI 05 EU005 Grain Conveyor NoneEquipment Silo/Bin EQUI 06 EU006 Grain Bin #1 NoneEquipment Silo/Bin EQUI 07 EU007 Grain Bin #2 NoneEquipment Silo/Bin EQUI 08 EU008 Grain Bin #3 NoneEquipment Other Emission Unit EQUI 09 EU009 Scalper NoneEquipment Silo/Bin EQUI 10 EU010 Surge Bin NoneEquipment Elevator EQUI 11 EU011 Grain Elevator NoneEquipment Conveyor EQUI 12 EU012 Grain Conveyor NoneEquipment Milling Equipment EQUI 13 EU013 Hammermill 1 NoneEquipment Milling Equipment EQUI 14 EU014 Hammermill 2 NoneEquipment Milling Equipment EQUI 15 EU015 Hammermill 3 NoneEquipment Material Handling Equipment EQUI 16 EU016 Flour Receiver NoneEquipment Fermentation Equipment EQUI 17 EU017 Fermentation Tank #1 COMG 06Equipment Fermentation Equipment EQUI 18 EU018 Fermentation Tank #2 COMG 06Equipment Fermentation Equipment EQUI 19 EU019 Fermentation Tank #3 COMG 06Equipment Fermentation Equipment EQUI 20 EU020 Fermentation Tank #4 COMG 06Equipment Fermentation Equipment EQUI 21 EU021 Beerwell #1 COMG 06Equipment Fermentation Equipment EQUI 22 EU022 Beerwell #2 COMG 06Equipment Liquefaction Equipment EQUI 23 EU023 Liquefaction Tank #1 COMG 06Equipment Liquefaction Equipment EQUI 24 EU024 Liquefaction Tank #2 COMG 06Equipment Liquefaction Equipment EQUI 25 EU025 Liquefaction Tank #3 COMG 06Equipment Mixing Equipment EQUI 26 EU026 Slurry Mix Tank COMG 06Equipment Fermentation Equipment EQUI 27 EU027 Yeast Tank COMG 06Equipment Stripping Equipment EQUI 37 EU030 Beer Stripper COMG 06Equipment Distillation Equipment EQUI 38 EU031 Rectifier COMG 06Equipment Stripping Equipment EQUI 39 EU032 Side Stripper COMG 06Equipment Dehydrator EQUI 40 EU033 Evaporator COMG 06Equipment Separation Equipment EQUI 41 EU034 Molecular Sieve COMG 06Equipment Separation Equipment EQUI 42 EU035 Centrifuge #1 NoneEquipment Separation Equipment EQUI 43 EU036 Centrifuge #2 NoneEquipment Separation Equipment EQUI 44 EU037 Centrifuge #3 NoneEquipment Separation Equipment EQUI 45 EU038 Centrifuge #4 NoneEquipment Separation Equipment EQUI 46 EU039 Centrifuge #5 NoneEquipment Dryer/Oven, unknown firing method EQUI 47 EU040 DDGS Dryer #1 COMG 03Equipment Dryer/Oven, unknown firing method EQUI 48 EU041 DDGS Dryer #2 COMG 03Equipment Cooler EQUI 50 EU043 DDGS Fluid Bed Cooler NoneEquipment Silo/Bin EQUI 51 EU044 DDG Silo NoneEquipment Silo/Bin EQUI 52 EU045 DDG Silo Bypass Receiver, Captured Emissions NoneEquipment Boiler EQUI 53 EU046 Auxiliary Boiler COMG 01Equipment Loading Unloading Equipment EQUI 55 EU048 Ethanol Loadout Rack NoneEquipment Reciprocating IC Engine EQUI 56 EU049 Diesel Generator COMG 05Equipment Reciprocating IC Engine EQUI 57 EU050 Diesel Generator COMG 05Equipment Reciprocating IC Engine EQUI 58 EU051 Diesel Generator COMG 05Equipment Milling Equipment EQUI 60 EU053 Hammermill 4 NoneEquipment Boiler EQUI 61 EU054 Auxiliary Boiler 2 COMG 01Equipment Fermentation Equipment EQUI 62 EU055 Fermentation Tank #5 COMG 06Equipment Silo/Bin EQUI 63 EU056 Grain Bin NoneEquipment Silo/Bin EQUI 64 EU057 Grain Bin NoneEquipment Silo/Bin EQUI 65 EU058 Grain Bin NoneEquipment Silo/Bin EQUI 66 EU059 Grain Bin NoneEquipment Conveyor EQUI 67 EU060 Belt Conveyor NoneEquipment Conveyor EQUI 68 EU061 Belt Conveyor NoneEquipment Conveyor EQUI 69 EU062 Belt Conveyor NoneEquipment Separation Equipment EQUI 70 EU063 Process Centrifugal Collector previously CE009 NoneEquipment Separation Equipment EQUI 71 EU064 Process Centrifugal Collector previously CE010 NoneEquipment Aboveground Storage Tank EQUI 72 804 (TK 005) Denatured Ethanol Tank COMG 02Equipment Aboveground Storage Tank EQUI 73 802 (TK 002) 200 Proof Tank NoneEquipment Aboveground Storage Tank EQUI 74 801 (TK 001) 190 Proof Tank None

Equipment Aboveground Storage Tank EQUI 75 805 (TK 003) Denaturant Tank COMG 02Equipment Aboveground Storage Tank EQUI 77 803 (TK 004) Denatured Ethanol Tank COMG 02Equipment Loading Unloading Equipment EQUI 80 EU065 Uncaptured receiving pit emissions NoneEquipment Loading Unloading Equipment EQUI 81 EU066 Uncaptured DDGS loadout emissions NoneEquipment Fermentation Equipment EQUI 82 EU028 Thin Stillage Tank COMG 06Equipment Fermentation Equipment EQUI 83 EU029 Syrup Tank COMG 06Fugitive Cooling Tower FUGI 01 FS004 Cooling Towers NoneFugitive Vehicle Emissions FUGI 03 FS001 Truck Traffic NoneFugitive Equipment Leaks FUGI 04 FS003 Equipment Leaks NoneFugitive Material Handling/Transfer/Storage FUGI 05 FS005 Rail Loadout NoneStructure Building STRU 02 BG001 Grains Building NoneStructure Building STRU 03 BG002 Mechanical Build NoneStructure Building STRU 04 BG003 Process Building A NoneStructure Building STRU 05 BG004 Process Building B NoneStructure Building STRU 06 BG005 Distillation and Evaporation Building 1 NoneStructure Building STRU 07 BG006 Distillation and Evaporation Building 2 NoneStructure Building STRU 08 BG007 Process Office Building NoneStructure Stack/Vent STRU 09 SV001 Grain Handling NoneStructure Stack/Vent STRU 10 SV002 Grain Cleaning NoneStructure Stack/Vent STRU 11 SV003 Hammermill #1 NoneStructure Stack/Vent STRU 12 SV004 Hammermill #2 NoneStructure Stack/Vent STRU 13 SV005 Hammermill #3 NoneStructure Stack/Vent STRU 14 SV006 Flour Receiver NoneStructure Stack/Vent STRU 15 SV007 RTO Bypass AOS NoneStructure Stack/Vent STRU 16 SV008 Centrifuges/CO2/Dryers NoneStructure Stack/Vent STRU 17 SV009 DDGS Silo NoneStructure Stack/Vent STRU 18 SV010 DDGS Silo Bypass NoneStructure Stack/Vent STRU 19 SV011 Boiler NoneStructure Stack/Vent STRU 20 SV012 Flare NoneStructure Stack/Vent STRU 21 SV013 Dryer A Emergency Bypass NoneStructure Stack/Vent STRU 22 SV014 Fluid Bed Cooling AOS Bypass NoneStructure Stack/Vent STRU 23 SV016 Diesel Generators NoneStructure Stack/Vent STRU 24 SV017 Hammermill #4 NoneStructure Stack/Vent STRU 25 SV018 Boiler 2 NoneStructure Stack/Vent STRU 26 SV019 Dryer B Emergency Bypass NoneStructure Stack/Vent STRU 27 SV015 Centrifuge Emergency Bypass NoneTotal Facility Air Quality Total Facility TFAC 01 01300099 Northstar Ethanol LLC/POET Biorefining Lk Crystal NoneTreatment 018 Fabric Filter Low Temp, T TREA 01 CE001 Fabric Filter Low Temperature, i.e., T NoneTreatment 018 Fabric Filter Low Temp, T TREA 02 CE002 Fabric Filter Low Temperature, i.e., T NoneTreatment 018 Fabric Filter Low Temp, T TREA 03 CE003 Fabric Filter Low Temperature, i.e., T NoneTreatment 018 Fabric Filter Low Temp, T TREA 04 CE004 Fabric Filter Low Temperature, i.e., T NoneTreatment 018 Fabric Filter Low Temp, T TREA 05 CE005 Fabric Filter Low Temperature, i.e., T NoneTreatment 018 Fabric Filter Low Temp, T TREA 06 CE006 Fabric Filter Low Temperature, i.e., T NoneTreatment 001 Wet Scrubber High Efficiency TREA 07 CE007 Wet Scrubber High Efficiency NoneTreatment 099 Other TREA 08 CE008 Regenerative Thermal Oxidizer NoneTreatment 018 Fabric Filter Low Temp, T TREA 11 CE011 Fabric Filter Low Temperature, i.e., T NoneTreatment 018 Fabric Filter Low Temp, T TREA 12 CE012 Fabric Filter Low Temperature, i.e., T NoneTreatment 018 Fabric Filter Low Temp, T TREA 13 CE013 Fabric Filter Low Temperature, i.e., T NoneTreatment 023 Flaring TREA 14 CE014 Flaring NoneTreatment 018 Fabric Filter Low Temp, T TREA 15 CE015 Fabric Filter Low Temperature, i.e., T NoneTreatment 099 Other TREA 16 CE016 Route to Auxiliary Boiler Burner NoneTreatment 312 Oxidation Catalyst TREA 21 CE017 Oxidation Catalyst NoneTreatment 312 Oxidation Catalyst TREA 22 CE018 Oxidation Catalyst NoneTreatment 312 Oxidation Catalyst TREA 23 CE019 Oxidation Catalyst NoneCOMG ACPT COMG 01 GP011 Auxiliary Boilers EQUI 53, EQUI 61COMG ACPT COMG 02 GP005 Tanks EQUI 72, EQUI 75, EQUI 77COMG ACPT COMG 03 GP008 Dryers EQUI 47, EQUI 48

COMG ACPT COMG 05 GP010 GeneratorsEQUI 56, EQUI 57, EQUI 58, STRU23

COMG ACPT COMG 06 GP003 Fermentation and Distillation

EQUI 17, EQUI 18, EQUI 19, EQUI20, EQUI 21, EQUI 22, EQUI 23,EQUI 24, EQUI 25, EQUI 26, EQUI27, EQUI 28, EQUI 29, EQUI 37,EQUI 38, EQUI 39, EQUI 40, EQUI41, EQUI 62

Attachment 4: Points calculator

Points Calculator

1) AI ID No.: 85851 Total Points 352) Facility Name: Northstar Ethanol LLC dba Poet Biorefining - Lake Crystal3) Small business? y/n? n 4) Air Project Tracking Numbers (including 5363 5) Date of each Application Received: 9/9/20156) Final Permit No. 01300099-1017) Permit Staff Eric Sulita

Total TotalApplication Type Air Project Tracking No. Tempo Activity ID Qty. Points Points Additionl Cost DetailsAdministrative Amendment 1 0 -$ Minor Amendment 4 0 -$ Applicability Request 10 0 -$ Moderate Amendment 15 0 -$ Major Amendment 5363 1 25 25 7,125.00$ Individual State Permit (not reissuance) 50 0 -$ Individual Part 70 Permit (not reissuance) 75 0 -$

Additional PointsModeling Review 15 0 -$

BACT Review 15 0 -$ LAER Review 15 0 -$ CAIR/Part 75 CEM analysis 10 0 -$ NSPS Review 10 0 -$ NESHAP Review 10 0 -$ Case-by-case MACT Review 20 0 -$ Netting 10 0 -$ Limits to remain below threshold 5363 1 10 10 2,850.00$ NSR major sourcePlantwide Applicability Limit (PAL) 20 0 -$ AERA review 15 0 -$ Variance request under 7000.7000 35 0 -$ Confidentiality request under 7000.1300 2 0 -$ EAW reviewPart 4410.4300, subparts 18, item A; and 29 15 0 -$ Part 4410.4300, subparts 8, items A & B; 10, items A to C; 16, items A & D; 17, items A to C & E to G; and 18, items B & C

35 0 -$

Part 4410.4300, subparts 4; 5 items A & B; 13; 15; 16, items B & C; and 17 item D

70 0 -$

Add'l Points 10

NOTES:

(DQ 5323)

Attachment 5: CAM Plan

Compliance Assurance Monitoring Plan for

POET Biorefining – Lake Crystal

Lake Crystal, Minnesota

March 22, 2016

Part One – Regenerative Thermal Oxidizer

I. Background

A. Emissions Units

Description: Fermentation, Distillation, Centrifuges, DDGS Dryers, DDGS cooler

B. Applicable Regulation, Emission Limit, and Monitoring Requirements

Volatile Organic Compounds: less than or equal to 9.0 lbs/hour on the basis of total mass of VOC

C. Control Technology

CE 008 Regenerative Thermal Oxidizer

II. Monitoring Approach

A. Indicator

Combustion chamber temperature when chamber temperature is below indicator range.

B. Measurement Approach

The combustion chamber temperature is measured continuously using a thermocouple in thecombustion chamber.

C. Indicator Range

RTO combustion temperature will be maintained at greater than or equal to 1650 degrees F as athree hour rolling average at the Combustion Chamber unless a new minimum is set pursuant toMinn. R. 7017.2025, subp. 3, based on the average temperature recorded during the most recentMPCA approved performance test where compliance for VOC emissions was demonstrated.

D. QIP Threshold

The Quality Improvement Plan (QIP) threshold is 36 excursions of the 3 hour temperature in onecalendar quarter. An excursions for temperature is a 3 hour average below 650 degrees F.

E. Performance Criteria

Data representativeness:

The monitoring system consists of a thermocouple in the combustion chamber with a digitalreadout and electronic data storage.

The equipment has been installed and calibrated according to the manufacturer’s specifications.

Verification of operational status:

The monitoring equipment will be maintained in good working condition according to themanufacturer’s O&M procedures.

QA/QC practices and criteria:

The thermocouple will be changed and calibrated according to the manufacturer’s specifications.

Monitoring frequency and data collection procedure:

The temperature of the combustion chamber is continuously displayed and recorded.

III. Justification

A. BackgroundThe fermentation system, centrifuges, distillation system, DDGS dryers, and DDGS cooler arecontrolled by the regenerative thermal oxidizer, CE 008.

B. Rationale for Selection of Performance Indicator

The combustion chamber temperature is the parameter that is most indicative of control deviceperformance. If the combustion zone temperature decreases, complete optimum combustionmay not occur resulting in an increase in VOC emissions. By maintaining the operatingtemperature above the minimum level, applicable control efficiencies can be achieved.

C. Rationale for Selection of Indicator Level

RTO combustion temperature will be maintained at greater than or equal to 1650 degrees F as athree hour rolling average at the Combustion Chamber in accordance with permit requirements.Compliance with emission limits has been demonstrated through performance testing.

Attachment 6: NSPS subp. Kb Applicability Determination

U.S. Environmental Protection Agency Applicability Determination Index

Control Number: 0800041

Category: NSPS

EPA Office: CAMPD

Date: 11/20/2007

Title: Process Tanks Defined

Recipient: Cunningham, Lee

Author: Alushin, Michael

Comments:

Part 60, A General Provisions

Kb Storage Vessels for VOCs (post 7/23/84)

References: 60.110b(a)

60.111b

Abstract:

Q1: Do the process and alcohol day tanks at Archer Daniels Midland's (ADM) dry mill ethanol production facility at its existing corn wet mill in Columbus, Nebraska, meet the process tank definition which exempts them from the control requirements of 40 CFR part 60, subpart Kb?

A1: Yes. EPA finds that these tanks are used within the process, are process tanks, and are not considered storage vessels subject to NSPS subpart Kb

Q2: Is the alcohol QC tank also a process tank and not a storage vessel under NSPS subpart Kb?

A2: No. EPA finds that this tank does not engage in the type of unit operations or other functions described for process tanks, and is outside of the process. The sampling performed at the tank does not qualify this tank as a process tank. It is subject to NSPS subpart Kb as a storage vessel.

Q3: Is the alcohol reclaim tank a process tank and not a storage vessel under NSPS subpart Kb?

A3: No. EPA finds that this tank serves as a feed vessel for reintroduction of material back into the process. It is not within the process, and is a storage vessel subject to NSPS subpart Kb.

Letter:

Mr. Lee R. Cunningham Corporate Environmental Counsel Archer Daniels Midland Company 4666 Faries Parkway P.O. Box 1470 Decatur, Illinois 62526

Dear Mr. Cunningham:

We have reviewed your inquiry of March 5, 2007, regarding the applicability of 40 CFR Part 60, Subpart Kb, Standards of Performance for Volatile Organic Liquid (VOL) Storage Vessels (NSPS Subpart Kb), to certain ethanol tanks at Archer Daniels Midland (ADM) Company's ethanol plants. In addition to your March 5, 2007, request, we have considered electronic mail correspondence from your company dated April 19, 2007, and May 25, 2007, a May 23, 2007, conference call, and conversations with your staff and counsel as recently as September. Our determination of applicability is provided for the Columbus, Nebraska ethanol plant. Requests for applicability determinations for other plants must be submitted in writing to the appropriate delegated state agency.

According to your March 5, 2007, request, ADM received a PSD permit from the Nebraska Department of Environmental Quality on October 20, 2006, to construct a dry mill ethanol production facility at its existing corn wet mill in Columbus, Nebraska. The ethanol plant will include fermentation and distillation processes followed by a finishing process. The finishing will include dehydration, nitrogen stripping, blending with denaturant and corrosion inhibitor, and filtering, followed by quality assurance/quality control (QA/QC) of the material (sampling, testing and segregation). Any product that does not meet the quality specifications is recycled back into the process.

Your request for an applicability determination pertains to five "proof ethanol" tanks. Those tanks are listed below:

- one 100,000 gallon Process Tank (EU-DM 54) - two 500,000 gallon Alcohol Day Tanks (EU-DM 41 & 42) - one 500,000 gallon Alcohol QC Tank (EU- DM 43) - one 500,000 gallon Alcohol Reclaim Tank (EU-DM 40).

Following a distillation process, raw ethanol is pumped into the Process Tank, and then sent through dehydration and nitrogen stripping to increase proof and remove impurities. The ethanol is then pumped to the Alcohol Day Tanks. From the Alcohol Day Tanks, the ethanol is converted to fuel-use ethanol by adding denaturant and corrosion inhibitor. The denatured ethanol fuel is pumped to the Alcohol QC Tank where it is sampled and tested to ensure that the ADM quality specifications are met. Any material that does not meet the specifications is sent to the Alcohol Reclaim Tank where it is gradually blended back into the Alcohol Day Tanks to be reprocessed. Material that meets the product specifications is pumped from the Alcohol QC Tank to three storage tanks used for shipping purposes.

ADM agrees with the Nebraska Department of Environmental Quality that the three storage tanks that hold the denatured fuel ethanol that meets the ADM quality specifications are subject to NSPS Subpart Kb. However, ADM believes the other five tanks referenced above qualify as process tanks under NSPS Subpart Kb, and as such would be exempt from the requirements of Subpart Kb for storage vessels. The United States Environmental Protection Agency (EPA or the Agency) agrees with ADM that the Process Tank and the two Alcohol Day Tanks are process tanks. However, EPA has determined that the Alcohol QC Tank and the Alcohol Reclaim Tank are storage vessels subject to NSPS Subpart Kb for reasons discussed below.

Regulatory Language

NSPS Subpart Kb applies to . . . each storage vessel with a capacity greater than or equal to 75 cubic meters that is used to store volatile organic liquids (VOL) for which construction, reconstruction, or modification is commenced after July 23, 1984. 40 CFR Section 60.110b(a). Certain exceptions apply. See 40 CFR Section 60.110b. A storage vessel generally includes each tank, reservoir, or container used for the storage of volatile organic liquids, but excludes certain enumerated structures.

40 CFR Section 60.111b.

On October 15, 2003, Subpart Kb was amended to exclude process tanks from the definition of storage vessel. 68 FR 59328. Subpart Kb defines process tank to mean:

a tank that is used within a process (including a solvent recovery or raw material recovery process) to collect material discharged from a feedstock storage vessel or equipment within the process before the material is transferred to other equipment within the process, to a product or by-product storage vessel,

or to a vessel used to store recovered solvent or raw material. In many process tanks, unit operations such as reactions and blending are conducted. Other process tanks, such as surge control vessels and bottoms receivers, however, may not involve unit operations. (Emphasis added.)

40 CFR Section 60.111b

To qualify as a process tank the tank in question must be "within the process." The Subpart Kb regulations do not define process. However, EPA has provided examples in the definition, the preamble and the response to comments document of what types of activities occur within process tanks, which again must be within a process. The definition identifies reactions and blending as unit operations that might be conducted in process tanks. The preamble to the final rule also lists fermentation and distillation. 68 FR 59330. The June 2003 response to comments document1 expands on this latter list and includes the following: fermentation, distillation, mixing and blending, condensing, filtering, and extraction.

The definition of process tank indicates that certain tanks that do not include unit operations may also qualify as process tanks. The definition identifies surge control vessels and bottoms receivers as such tanks, and the preamble to the final rule includes vessels used for surge control of wastewater and/or sludge. 68 FR 59330. The response to comments document includes pipeline surge control vessels. Any of these vessels would need to be located "within a process" to be covered by the process tank exclusion.

The types of processes covered in the process tank definition include solvent or raw material recovery processes. However, the preamble to the final rule clarifies,

[t]he EPA considers vessels that receive and accumulate solvent or raw material from recovery processes to be storage vessels, not process tanks. Such vessels serve the same function as virgin solvent and raw material storage vessels . . .

68 FR 59330

Applicability of NSPS to the Ethanol Proof Tanks at the Columbus, Nebraska Source

Process Tank (EU-DM 54)

The Process Tank receives material directly from the distillation process. From there the material is sent to dehydration and then nitrogen stripping. Consistent with the definition of "process tank" at 40 CFR Section 60.111b, the Process Tank (EU-DM 54) is therefore ". . . tank that is used within a process to collect material discharged from" equipment within the process before the material is transferred to other equipment within the process. . . It is a process tank as defined in the regulations; therefore, it is not a storage vessel and is not subject to NSPS Subpart Kb.

Alcohol Day Tanks (EU-DM 41 & 42)

The Alcohol Day Tanks also fit the definition of process tanks. These tanks are located after the nitrogen strippers and prior to denaturing. They are used, consistent with the process tank definition, "to collect material discharged from" equipment within the process before the material is transferred to other equipment within the process. . . 40 CFR Section 60.111b. As such, these tanks are process tanks, and are not storage vessels, so they are not subject to Subpart Kb.

Alcohol QC Tank (EU-DM 43)

The Alcohol QC Tank at the Nebraska facility contains ethanol which has been through the fermentation, distillation, dehydration, nitrogen stripping and blending processes, and holds the product from these processes. If the sample taken from the Alcohol QC Tank shows that the product meets the ADM specifications, the product is pumped into three storage vessels used for shipping purposes. If the sample does not meet specifications, the material is pumped back into the process, via the Alcohol Reclaim Tank.

Operations at the Alcohol QC Tank do not involve the type of unit operations or other functions (e.g., surge control or bottoms receiving) that are described in the rule, the preamble, or in the response to comments document. The operation performed at the tank is sampling. Obtaining a sample from a vessel at the end of the chemical and physical processing does not constitute processing as described

by the rulemaking. A tank which holds a product or by-product, whether on or off spec for ADM, is not involved in the same type of process functions as described in the rulemaking, and is no longer within the process.

Although ADM has stated that the Alcohol QC Tank is engaged in blending and mixing, there is no blending or mixing equipment in the Alcohol QC Tank. The denaturant and the corrosion inhibitor are not added directly to the Alcohol QC Tank, but are added in the pipeline to material exiting the Alcohol Day Tanks. The primary blending occurs in the piping. We do not consider the incidental mixing that occurs as material enters the Alcohol QC Tank as a mixing or blending process. Further, if the material in the Alcohol QC Tank is found to be off spec, the material is generally sent to the Alcohol Reclaim Tank, from which point it is sent back into the process. Although it is possible that a problem may be corrected simply by changing the amount of denaturant or corrosion inhibitor flowing into the piping, mixing in the piping with material from the Alcohol Day Tanks, and then entering the Alcohol QC Tank, the material is not actively mixed in the Alcohol QC Tank since the tank does not include any mixing or blending equipment. The Alcohol QC Tank simply holds the product of the process, ready for sampling.

Therefore, the Alcohol QC Tank is not a process tank; rather, it is a storage vessel as defined in the regulations. Since the Alcohol QC Tank has a capacity of greater than (or equal to) 75 cubic meters, is used to store a VOL, and construction will commence after July 23, 1984, the tank is subject to NSPS Subpart Kb.

Alcohol Reclaim Tank (EU-DM 40)

Product at the Nebraska facility that does not meet the ADM product specifications is pumped to the Alcohol Reclaim Tank. From there it is gradually sent back into the Alcohol Day Tanks for re-processing by blending with other material coming from the dehydration and nitrogen stripping processes. The piping is configured to allow the Alcohol Reclaim Tank to receive material from the Alcohol Day Tanks in the event that additional storage capacity is temporarily needed such as may occur in the event of equipment malfunction. No processing occurs in the Alcohol Reclaim Tank. It would normally function as storage for material being sent from the Alcohol QC Tank to the Alcohol Day Tanks for processing.

The Alcohol Reclaim Tank therefore serves as a feed vessel for reintroduction of material back into the process. The Alcohol Reclaim Tank itself is not within the process. It is a storage vessel, not a process tank.

This interpretation is consistent with EPA's decision to treat vessels that receive and accumulate solvent or raw material from recovery processes as storage vessels, not process tanks, as indicated in the preamble to the final rule. 68 FR 59330. These recovery processes contain process tanks, and produce material which may be used as a feedstock in the process. The storage of that material, which may be sent back into the process, is outside of the recovery process itself, and the tanks that contain that material are not considered process tanks.

Therefore, the Alcohol Reclaim Tank at the Nebraska facility is a storage vessel as defined in the regulations. Since the Alcohol Reclaim Tank has a capacity of greater than (or equal to) 75 cubic meters, is used to store a VOL, and construction will commence after July 23, 1984, the tank is subject to NSPS Subpart Kb.

This determination for the five proof ethanol tanks at the Nebraska ADM facility has been coordinated with the Office of Air Quality Planning and Standards, the Office of General Counsel, and EPA Region 7. Questions on this determination may be directed to Sally Harmon of my staff at 202-564-7012.

Very truly yours,

Michael S. Alushin, Director Compliance Assessment and Media Programs Division Office of Compliance

cc: Peter Wyckoff, Pillsbury Winthrop Shaw Pittman Dean Frommelt, Archer Daniels Midland

for draft air emission permit no. 01300099 101 tsd_0.pdf · the primary pieces of control equipment...

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