AIR EMISSION PERMIT NO IS ISSUED TO. Granite Falls Community Ethanol Plant LLC

Size: px
Start display at page:

Download "AIR EMISSION PERMIT NO IS ISSUED TO. Granite Falls Community Ethanol Plant LLC"

Transcription

1 AIR EMISSION PERMIT NO IS ISSUED TO Granite Falls Community Ethanol Plant LLC Granite Falls Community Ethanol Plant LLC 150 th Street Southeast & Highway 23 North Granite Falls, Chippewa County, MN The emission units, control equipment and emission stacks at the stationary source authorized in this permit are as described in the following permit application(s): Permit Type Application Date Total Facility Operating Permit November 2002 This permit authorizes the permittee to construct and operate the stationary source at the address listed above unless otherwise noted in Table A. The permittee must comply with all the conditions of the permit. Any changes or modifications to the stationary source must be performed in compliance with Minn. R to Terms used in the permit are as defined in the state air pollution control rules unless the term is explicitly defined in the permit. Permit Type: State; Limits to Avoid Pt 70/Limits to Avoid NSR Issue Date: April 29, 2004 Expiration: Permit does not expire Title I Conditions do not expire. Ann M. Foss Major Facilities Section Manager Majors and Remediation Division For Sheryl A. Corrigan Commissioner Minnesota Pollution Control Agency TDD (for hearing and speech impaired only): (651) Printed on recycled paper containing at least 10% fibers from paper recycled by consumers

2 TABLE OF CONTENTS Notice to the Permittee Permit Shield Facility Description Table A: Limits and Other Requirements Table B: Submittals Appendix: Dispersion Modeling Parameters List of Facility Equipment Best Management Practices Plan

3 NOTICE TO THE PERMITTEE: Your stationary source may be subject to the requirements of the Minnesota Pollution Control Agency s (MPCA) solid waste, hazardous waste, and water quality programs. If you wish to obtain information on these programs, including information on obtaining any required permits, please contact the MPCA general information number at: Metro Area (651) Outside Metro Area TTY (651) The rules governing these programs are contained in Minn. R. chs Written questions may be sent to: Minnesota Pollution Control Agency, 520 Lafayette Road North, St. Paul, Minnesota Questions about this air emission permit or about air quality requirements can also be directed to the telephone numbers and address listed above. PERMIT SHIELD: Subject to the limitations in Minn. R , 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 and , 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.

4 FACILITY DESCRIPTION: The facility to be built that is authorized by this permit is a fuel-grade ethanol production plant. Emission sources at the plant include fermentation, distillation, DDGS handling, DDGS drying, combustion, storage tanks, product loadout, and grain handling fugitives. The grain handling elevator is owned by Farmer s Cooperative Elevator Company and is considered for air permitting purposes to be a part of the stationary source. The plant will be capable of producing 45,000,000 gallons of ethanol per year, (47,250,000 gallons of denatured ethanol.)

5 Table A contains limits and other requirements with which your facility must comply. The limits are located in the first column of the table (What To do). The limits can be emission limits or operational limits. This column also contains the actions that you must take and the records you must keep to show that you are complying with the limits. The second column of Table A (Why to do it) lists the regulatory basis for these limits. Appendices included as conditions of your permit are listed in Table A under total facility requirements. Subject Item: Total Facility What to do This permit allows for the addition or replacement of the following equipment: distillation equipment, fermentation equipment, grain handling equipment, hammermills, and DDGS handling equipment without an amendment to the permit. See the requirements tables under EU001 - EU003, GP004, and EU008, for specific requirements. This approval is intended for modifications that are not intended to increase the annual physical production capacity of the facility. If the annual physical production capacity of the facility is to be increased, an Environmental Assessment Worksheet or Environmental Impact Statement may need to be completed, and the permit may need to be amended. OPERATIONAL REQUIREMENTS Production: less than or equal to gallons/year of ethanol (without denaturant), based on a 12 month rolling sum. Process Throughput: less than or equal to tons/year of corn, based on a 12-month rolling sum. Process Throughput: less than or equal to tons/year of soybeans, based on a 12-month rolling sum. The Permittee shall not produce wet cake except under conditions of shutdown or breakdown of the dryer or associated air pollution control equipment. For each event leading to the production of wet cake, 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 (a reasonable period of time). Why to do it Minn. R , subp. 2 Title I Condition: To limit potential emissions to less Title I Condition: To limit potential emissions to less Title I Condition: To limit potential emissions to less Minn. R , Subp.4 and Minn. R , subp. 2. Please note that requirements for reporting of shutdowns and breakdowns must be followed as well. Those requirements are outlined below. When wet-cake by-product is produced, it will be stored for no more than 72 hours unless the outside temperature is less than 55 F. The facility will sell wet cake as soon as possible, or transport the wet cake offsite for land application or agricultural bagging. Follow the Best Management Practices Plan attached to this permit. Minn. R , subp. 2 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. Air Pollution Control Equipment: Operate all pollution control equipment whenever the corresponding process equipment and emission units are operated, unless otherwise noted in Table A. 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 shall include a preventative maintenance program for that equipment, a description of (the minimum but not necessarily the only) corrective actions to be taken to restore the equipment 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 the records kept to demonstrate plan implementation. 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. 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 Minn. R Minn. R , subp. 2; Minn. R , subp. 16(J) Minn. R , subp. 14 and Minn. R , subp. 16(J) Minn. R , subp. 4 Minn. R A-1

6 Noise: The Permittee shall comply with the noise standards set forth in Minn. R to 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. Inspections: The Permittee shall comply with the inspection procedures and requirements as found in Minn. R , subp. 9(A). The Permittee shall comply with the General Conditions listed in Minn. R , subp. 16. PERFORMANCE TESTING Performance Testing: Conduct all performance tests in accordance with Minn. R. ch unless otherwise noted in Tables A, B, and/or C. Performance Test Notifications and Submittals: Performance Tests are due as outlined in Tables A and B of the permit. See Table B for additional testing requirements. Minn. R Minn. R , subp. 9(A) Minn. R , subp. 16 Minn. R. ch Minn. R , subp. 1-4, and Minn. R , subp. 1-2 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 alternative format as allowed by Minn. R Limits set as a result of a performance test (conducted before or after permit issuance) apply until superseded as specified by Minn. R following formal review of a subsequent performance test on the same unit. Once performance testing has been completed for speciated VOCs, (resulting in emission numbers for hazardous air pollutants (HAPs) as well as other chemicals that are present) from the thermal oxidizer stack, the fermentation stack, and the cooling cyclone, use the emission results to calculate facility potential HAP emissions. Facility potential HAP emissions shall be calculated by using the test results for each pollutant, in lb/hour, multiplied by 8760/2000 to convert to tons per year. If any of the results for each individual HAP equal or exceed 10 tons per year, or the total of all HAPs equal or exceed 25 tons per year, submit an application for a major amendment to this permit. The application will specify that permit limits be set at 9 tons per year for any individual HAP, and 25 tons per year for HAPs total. The application will also specify a compliance demonstration method for tracking HAP emissions on a 12-month rolling sum basis. MONITORING REQUIREMENTS Monitoring Equipment Calibration: Annually calibrate all required monitoring equipment or as frequently as recommended by manufacturer's specifications. (any requirements applying to continuous emission monitors are listed separately in this permit). Operation of Monitoring Equipment: Unless otherwise noted in Tables A, B, and/or C, 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. RECORDKEEPING Record keeping: Retain all records at the stationary source 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 , subp. 5(A). Recordkeeping: Maintain records describing any insignificant modifications (as required by Minn. R , subp. 3) or changes contravening permit terms (as required by Minn. R subp. 2), including records of the emissions resulting from those changes. By the 15th day of each month, calculate and record ethanol production and throughput of each grain for the previous month, and the previous 12-month period. REPORTING/SUBMITTALS Minn. R Title I Condition: limit set to restrict potential hazardous air pollutants to less than major source levels as defined by 40 CFR Part 63 Minn. R , subp. 4(D) Minn. R , subp. 4(D) Minn. R , subp. 5(C) Minn. R , subp. 5(B) A-2

7 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 , 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. 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 , subp. 2. Minn. R , subp. 3 Minn. R , 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. 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. 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. Application for Permit Amendment: If a permit amendment is needed, submit an application in accordance with the requirements of Minn. R through Minn. R Submittal dates vary, depending on the type of amendment needed. 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 , subp. 1(H). Minn. R , subp. 1 Minn. R , subp. 1 Minn. R through Minn. R Minn. R , subp. 1(H) Any requirements set due to 40 CFR Part 60 (Federal New Source Performance Standards), 40 CFR Part 70 (Operating Permits), or that are set as Title I Conditions do not meet the requirements of Minn. R , subp. 1(H). Emission Inventory Report: due 91 days after end of each calendar year following Minn. R through Minn. R permit issuance (April 1). To be submitted on a form approved by the Commissioner. Emission Fees: due 60 days after receipt of an MPCA bill. Minn. R through Minn. R List of Facility Equipment: Each year submit a report that lists all of the equipment on site. If no changes have been made under the preauthorized construction allowances in this permit, the report shall state such, and no new list of equipment is required. The report is due 91 days after end of each calendar year following permit issuance (April 1). FUEL USE RESTRICTIONS Fuel Use: limited to natural gas and propane Fuel Usage: less than or equal to gallons/year for the total facility of propane based on a 12 month rolling sum. This limit applies to the dryers as well as the thermal oxidizer. By the 15th day of each month, all propane burned at any unit during the previous month, and the previous 12 month's total facility propane usage is to be calculated. STACK PARAMETERS Minn. R , subp. 2 A-3

8 Parameters Used in Modeling: The parameters used in the modeling performed for an Environmental Assessment Worksheet under Minn. R. ch and for determining emission and/or operational limits for this facility are listed in the Appendix of this permit. If the Permittee intends to change any of these parameters, the Permittee must submit the revised parameters to the Commissioner and receive written approval before making any changes. The revised parameter information submittal must include, but is not limited to: the locations, heights and diameters of the stacks; locations and dimensions of nearby buildings; velocity and temperatures of the gases emitted; and the emission rates. The plume dispersion characteristics due to the parameter revisions must equal or exceed the dispersion characteristics modeled for this permit, and the Permittee shall demonstrate this in the proposal. continued from above: Minn. R. ch and Minn. R , subp. 2 Minn. R. ch and Minn. R , subp. 2 If the information does not demonstrate equivalent or better dispersion characteristics, or if a conclusion cannot readily be made about the dispersion, the Permittee must remodel. For changes that do not involve an increase in an emission rate and that do not require a permit amendment, the proposal must be submitted as soon as practicable, but no less than 60 days before making the change to any parameter. continued from above: Minn. R. ch and Minn. R , subp. 2 For changes involving increases in emission rates and that require a minor permit amendment, the proposal must be submitted as soon as practicable, but no less than 60 days before making the change to any parameter. For changes involving increases in emission rates and that require a permit amendment other than a minor amendment, the proposal must be submitted prior to or with the permit amendment application. This is a state only requirement and is not enforceable by the EPA Administrator and citizens under the Clean Air Act. A-4

9 Subject Item: Associated Items: GP 001 Baghouse Monitoring and Maintenance CE 002 Fabric Filter - Low Temperature, i.e., T<180 Degrees F CE 003 Fabric Filter - Low Temperature, i.e., T<180 Degrees F CE 008 Fabric Filter - Low Temperature, i.e., T<180 Degrees F What to do Pressure Drop: Less than 1 inches of water column and greater than 6 inches of water column. Operation and Maintenance of Fabric Filter: The Permittee shall operate and maintain each fabric filter according to the control equipment manufacturer's specifications. Visible Emissions: The Permittee shall check the fabric filter stacks for any visible emissions once each day of operation during daylight hours, or the pressure drop across the fabric filter once each day of operation if inclement weather prohibits a visible emissions check. 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. Corrective Action: If visible emissions are observed, and/or if the pressure drop is outside the permitted range specified in this subject item, the Permittee shall follow the Operation and Maintenance Plan for the fabric filter and take corrective actions as soon as possible to eliminate the visible emissions and/or return the pressure drop to within the permitted range. The Permittee shall keep a record of the type and date of all corrective actions taken. Inspect quarterly, or as required by manufacturing specifications, all components that are not subject to wear or plugging, including structural components, housing, ducts, and hoods. Maintain a written record of the inspection and any action resulting from the inspection. 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. 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. Why to do it Title I Condition: To limit potential emissions to less Title I Condition: To limit potential emissions to less Title I Condition: To limit potential emissions to less Title I Condition: To limit potential emissions to less Title I Condition: To limit potential emissions to less Minn. R , subp. 2 and subp. 14 Minn. R , subp. 2 and subp. 14 Minn. R , subp. 2 and subp. 14 A-5

10 Subject Item: GP 002 Tanks 1-5 Associated Items: TK Proof Ethanol TK Proof Ethanol TK 003 Denaturant (gasoline) TK 004 Denatured Ethanol TK 005 Denatured Ethanol What to do POLLUTION CONTROL REQUIREMENTS Why to do it The storage vessel shall be equipped with a fixed roof in combination with an internal floating roof meeting the requirements of 40 CFR Section b(a)(1). Internal Floating Roof Seal Requirement: Each interal roof shall be equipped with one of the closure devices between the wall of the storage vessel and the edge of the internal floating roof as described in Section b(a)(1)(ii). MONITORING REQUIREMENTS Inspection - Prior to initial fill of tanks: Visually inspect the internal floating roof, the primary seal, and the secondary seal (if one is in service), 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 owner or operator shall repair the items before filling the storage vessel. Inspection - Annual: Visually inspect the internal floating roof, the primary seal, and the secondary seal (if one is in service) through manholes and roof hatches on the fixed roof at least once every twelve (12) months after initial fill as required by Section b(a)(2). Inspection - Tank Empty and Degassed: Visually inspect the internal floating roof, the primary seal, and the secondary seal (if one is in service), gaskets, slotted membranes and sleeve seals (if any) each time the tank is emptied and degassed as required by Section b(a)(4). In no event shall inspections be conducted in accordance with this provision occur at intervals greater than 10 years. RECORDKEEPING REQUIREMENTS Keep a record of each inspection performed as required by 40 CFR Section b(a). 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.) Recordkeeping: Maintain records showing the dimensions of each tank and an analysis showing tank capacity. Recordkeeping: Maintain records of the 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 b(e). REPORTING REQUIREMENTS Notification: Notify the Commissioner in writing at least 30 days prior to the filling or refilling of each tank for which an inspection is required by paragraphs (a)(1) and (a)(4) of this section to afford the Commissioner the opportunity to have an observer present. If the inspection required by paragraph (a)(4) of this section is not planned and the Permittee could not have known about the inspection 30 days in advance of refilling the tank, the owner or operator shall notify the Administrator at least 7 days prior to the refilling of the tank. Notification shall be made by telephone 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 the refilling. After each inspection required by 40 CFR Section b(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 b(a)(3)(ii), a report shall be furnished to the Administrator within thirty (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 b(a)(1) or 40 CFR Section b(a)(3)(ii) and list each repair made. Notification - Control Equipment Installation and Certification: After installing the internal floating roofs, furnish the Administrator with a report describing the control equipment (fixed roof/internal floating roof combination) and certifying that the control equipment meets the specifications of Sections b(a)(1) and b(a)(1). This report shall be attached to the initial startup notification required by Section 60.7(a)(3) and located in Table B of this permit. 40 CFR Section b(a); Minn. R (C) 40 CFR Section b(a)(1)(ii); Minn. R (C) 40 CFR Section b(a)(1); Minn. R (C) 40 CFR Section b(a)(2) and (4); Minn. R (C) 40 CFR Section b(a)(2) and (4); Minn. R (C) 40 CFR Section b(a)(2); Minn. R (C) 40 CFR Section b(c); Minn. R (C) 40 CFR Section b(c); Minn. R (C) 40 CFR Section b(a)(5); Minn. R (C) 40 CFR Section b(a)(4); Minn. R (C) 40 CFR Section b(a)(1); Minn. R (C) A-6

11 Reporting - Annual Inspection Results: If any of the conditions described in Section b(a)(2) are detected during the annual visual inspection required by Section b(a)(2) are detected during the annual visual inspection required by Section b(a)(2), a report shall be furnished to the Administrator within 30 days of the inspection. Each report shall identify the tank, the nature of the defects, and the date the tank was emptied or the nature of and date the repair was made. 40 CFR Section b(a)(3); Minn. R (C) A-7

12 Subject Item: Associated Items: GP 004 Cooking and Distillation EU 004 Cooking EU 005 Distillation What to do The following requirements apply to all distillation and cooking equipment existing or installed on site. Distillation equipment includes beer columns, side strippers, rectifier columns, condensers and molecular sieves. Cooking equipment consists of mixers, slurry tanks, yeast tanks, cook tubes, liquification tanks and flash vessels. The facility may remove, install, or move equipment of the type listed above without a permit amendment if: 1. the 200 proof alcohol production at the facility does not exceed 45,000,000 gallons per year, 2. all of the listed equipment is vented to the thermal oxidizer, and Why to do it Minn. R , subp. 2 continued from above 3. after any addition or replacement of equipment, stack emissions testing for VOCs is repeated within 90 days of the completion of the modification to ensure that the new equipment does not cause emission limits set on SV001 to be exceeded. The notification and submittal requirements for stack emissions testing under the Total Facility table must be followed for each test. See table under CE001 for requirements for thermal oxidizer operation and maintenance. POLLUTION CONTROL REQUIREMENTS Vent all emissions to a thermal oxidizer. See CE001 for operation and maintentance requirements for the thermal oxidizer. See SV001 for testing requirements and emission limits. A-8

13 Subject Item: SV 001 Distillation, DDGS dryer, TO Associated Items: EU 004 Cooking EU 005 Distillation EU 006 Dryers EU 010 Anaerobic Water Treatment EMISSION LIMITS What to do Why to do it Total Particulate Matter: less than or equal to lbs/hour Particulate Matter < 10 micron: less than or equal to lbs/hour Carbon Monoxide: less than or equal to lbs/hour Nitrogen Oxides: less than or equal to 0.10 lbs/million Btu heat input based on a 30 day rolling average. Volatile Organic Compounds: less than or equal to 6.25 lbs/hour PERFORMANCE TESTING REQUIREMENTS Initial Performance Test: due 180 days after Initial Startup for PM/PM10, volatile organic compounds, opacity and carbon monoxide. The opacity limit is set under Subject Item: EU006, Dryers Performance Test: due 90 days after Initial Startup of new or replacement equipment for volatile organic compounds. Initial Performance Test: due 60 days after achieving maximum capacity for nitrogen oxides but not later than 180 days after initial startup. NOTIFICATION REQUIREMENTS See Table B for additional Notification Requirements. Notification of the installation or replacement of any cooking or distillation equipment. The notification is due within 30 days of beginning construction of the new or replaced equipment. 40 CFR Section 60.44b Title I Condition: to limit potential emission to less than major source levels as defined by 40 CFR Section 40 CFR Section 60.8 Tilte I Condition: to limit potential emissions to less A-9

14 Subject Item: EU 001 Grain Handling Associated Items: CE 002 Fabric Filter - Low Temperature, i.e., T<180 Degrees F SV 002 Grain receiving and storage What to do The following requirements apply to all grain receiving and storage equipment. Grain receiving and storage equipment includes; truck receiving hoppers, grain elevators, and grain bins. The facility may remove, install, or move equipment of the type listed above without a permit amendment if: Why to do it Minn. R , subp the throughput of the grain handled by the facility does not exceed 484,000 tons of grain per year, 2. all of the equipment is vented to a baghouse, at any time the equipment is operating, 3. the total grain storage capacity at the facility does not exceed 2.5 million bushels, continued from above 4. all grain received by truck is from hopper trucks only, and 5. The equipment meets the emission limits set below. EMISSION LIMITS Opacity: less than or equal to 5 percent from truck unloading and handling. Opacity: less than or equal to 10 percent from truck loading. Opacity: less than or equal to 10 percent from the baghouse (CE002) outlet. POLLUTION CONTROL REQUIREMENTS Vent emissions through a baghouse when grain is being unloaded or handled. See GP001 for requirements for baghouse operation and maintenance. Collection Efficiency: Equal to or greater than 99% for particulate matter. Minn. R , subp. 3(A) Minn. R , subp. 3(B) Minn. R , subp. 3(D) Title I Condition: Requirement to limit potential emissions to less than major source levels as defined by 40 CFR Section. Also meets the requirements of Minn. R , subp. 3(E) A-10

15 Subject Item: EU 002 Hammermills Associated Items: CE 003 Fabric Filter - Low Temperature, i.e., T<180 Degrees F SV 003 Hammermill What to do The following requirements apply to all hammermills existing or installed on site. The facility may remove, install, or move hammermills without a permit amendment if: Why to do it Minn. R , subp the throughput of the grain processed by the hammermill(s) does not exceed 484,000 tons of grain per year, 2. all hammermills are vented to a baghouse, at any time the equipment is operating, and 3. the equipment meets the emission limits set below. EMISSION LIMITS Opacity: less than or equal to 10 percent POLLUTION CONTROL REQUIREMENTS Vent all emissions through a baghouse when grain is being ground. See GP001 for requirements for baghouse operation and maintenance. Collection Efficiency: Equal to or greater than 99% for particulate matter. Minn. R , subp. 3(D) Title I Condition: Requirement to limit potential emissions to less than major source levels as defined by 40 CFR Section. Also meets the requirements of Minn. R , subp. 3(E) A-11

16 Subject Item: EU 003 Fermentation Associated Items: CE 004 Packed-Gas Adsorption Column SV 004 Fermentation What to do The following requirements apply to all fermentation equipment existing or installed on site. Fermentation equipment includes fermentation tanks and beerwells. The facility may remove, install, or move equipment of the type listed above without a permit amendment if: Why to do it Minn. R , subp the 200 proof alcohol production at the facility does not exceed 45,000,000 gallons per year, 2. all of the fermentation equipment is vented to the fermentation scrubber, and 3. after any addition or replacement of equipment, stack emissions testing for VOCs is repeated within 90 days of the completion of the modification to ensure that the new equipment does not cause emission limits set at SV004 to be exceeded. All notification and submittal requirements for stack emissions testing specified under the Total Facility requirements table must be followed for each test. See table under CE004 for requirements for scrubber operation and maintenance. EMISSION/CAPACITY LIMITS Volatile Organic Compounds: less than or equal to 7.25 lbs/hour Total Fermentation Tank Volume: Limited to 2,190,000 gallons. POLLUTION CONTROL REQUIREMENTS Vent all emissions to a scrubber. See CE004 for operation and maintentance requirements for the scrubber. PERFORMANCE TESTING REQUIREMENTS Performance Test: due 180 days after Initial Startup for VOC emissions. Performance Test: due 90 days after Initial Startup of new or replacement equipment for volatile organic compounds. Notification of the installation or replacement of any fermentation equipment. The notification is due within 30 days of beginning construction on the new or replaced equipment. continued from above Minn. R (limits annual capacity to 45 mmgallons) Tilte I Condition: to limit potential emissions to less A-12

17 Subject Item: EU 006 Dryers Associated Items: CE 001 Thermal Oxidizer CE 006 Centrifugal Collector - High Efficiency CE 007 Centrifugal Collector - High Efficiency SV 001 Distillation, DDGS dryer, TO EMISSION LIMITS What to do Why to do it Total Particulate Matter: less than or equal to 0.3 grains/dry standard cubic foot of exhaust gas unless required to further reduce emissions to comply with the less stringent limit of either Minn. R or Minn. R Opacity: less than or equal to 20 percent except for one six-minute period per hour of not more than 60 percent opacity. OPERATIONAL REQUIREMENTS Process Throughput: Limited to a maximum of 600 lb/hour (wet basis) from the centrifuge, or the maximum product throughput during the most recent stack emissions testing that demonstrated compliance. Dryer temperature: Limited to a maximum of 215 degrees F, or to the temperature measured during the most recent stack emissions testing that demonstrated compliance. Beer feed rate limited to a maximum of 300 gpm, or to the maximum feed rate measured during the last stack emissions testing that demonstrated compliance. Syrup feed rate: limited to a maximum of 50 gpm, or the highest feed rate measured during the most recent stack emissions testing that limits compliance. POLLUTION CONTROL REQUIREMENTS Vent all emissions to a thermal oxidizer. See CE001 for operation and maintentance requirements for the thermal oxidizer. See SV001 for emission limits and testing requirements. FUEL USE RESTRICTIONS Fuel Use: limited to natural gas and propane. See the total facility requirements for limits on total facility propane use. PROCESS MONITORING Measure and record the process throughput, beer feed rate, and syrup feed rate on an hourly basis. 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 equipment is required. 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 dryer chamber. Daily Monitoring: The Permittee shall physically check the temperature recording device at least once each operating day to verify that it is working and recording properly. Annual Calibration: The Permittee shall calibrate the temperature monitor at least annually and shall maintain a written record of the calibration and any action resulting from the calibration. Minn. R , subp. 1(A)(1) Minn. R , subp. 1(A)(2) Minn. R , subp. 4 Minn. R , subp. 4 and 5 Minn. R , subp. 4, 5, and 14 A-13

18 Subject Item: EU 007 Cooling Cyclone Associated Items: SV 006 DDGS cooling cyclone EMISSION LIMITS What to do Why to do it Total Particulate Matter: less than or equal to 1.0 lbs/hour Particulate Matter < 10 micron: less than or equal to 1.0 lbs/hour Volatile Organic Compounds: less than or equal to 3.0 lbs/hour Opacity: less than or equal to 10 percent CONTROL REQUIREMENTS Collection Efficiency: greater than or equal to 80% for PM and PM10. OPERATIONAL REQUIREMENTS Pressure Drop: greater than or equal to 2 inches of water column and less than or equal to 8 inches of water column, or the range shown during the most recent stack emissions testing that demonstrated compliance. Record pressure drop once each day of operation. Corrective Actions: The Permittee shall take corrective action as soon as possible if any of the following occur: - the recorded pressure drop is outside the required operating range; or - the cyclone 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 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 cyclone. The Permittee shall keep a record of the type and date of any corrective action taken. 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. Calibrate the pressure gauge annually, or as often as required by manufacturing specifications and maintain a written record of the calibration and any action resulting from the calibration. PERFORMANCE TESTING Performance Test: due 180 days after Initial Startup to measure PM, PM10 and VOC emissions. Minn. R , subp. 3(D) Minn. R , subp. 3(E) Minn. R , subp. 4, 5, and 14 Minn. R , subp. 4, 5 and 14 Minn. R , subp. 4, 5 and 14 Minn. R , subp. 1; 40 CFR Section 60.8(a); 40 CFR Section 63.7 A-14

19 Subject Item: EU 008 DDGS Loadout Associated Items: CE 008 Fabric Filter - Low Temperature, i.e., T<180 Degrees F SV 007 DDGS loadout What to do The following requirements apply to all DDGS loadout and storage equipment. DDGS loadout and storage equipment includes dump pit/auger(s) and loadout spout(s). The facility may remove, install, or move equipment of the type listed above without a permit amendment if: Why to do it Minn. R , subp the throughput of the grain handled by the facility does not exceed 484,000 tons of grain per year, 2. all of the equipment is vented a baghouse, at any time the equipment is operating, and 3. emission limits set below are met. EMISSION LIMITS Opacity: less than or equal to 10 percent from truck loading. Opacity: less than or equal to 10 percent from the baghouse (CE008) outlet. POLLUTION CONTROL REQUIREMENTS Vent emissions through a baghouse when DDGS is being loaded or handled. See GP001 for requirements for baghouse operation and maintenance. Collection Efficiency: Equal to or greater than 99% for particulate matter. Minn. R , subp. 3(B) Minn. R , subp. 3(D) Title I Condition: Requirement to limit potential emissions to less than major source levels as defined by 40 CFR Section. Also meets the requirements of Minn. R , subp. 3(E) A-15

20 Subject Item: EU 009 Ethanol Loadout Rack Associated Items: CE 005 Flaring SV 005 Methanator flare/ eth. loadout What to do POLLUTION CONTROL REQUIREMENTS Why to do it Vent all emissions when loading ethanol to trucks to the existing flare. See CE005 for requirements for the flare. 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 transportion cars. A-16

21 Subject Item: EU 010 Anaerobic Water Treatment Associated Items: CE 001 Thermal Oxidizer CE 005 Flaring SV 001 Distillation, DDGS dryer, TO SV 005 Methanator flare/ eth. loadout What to do Vent all emissions to the flare or the thermal oxidizer. See CE005 and CE001 for requirements for the control equipment. Why to do it A-17

22 Subject Item: CE 001 Thermal Oxidizer Associated Items: EU 004 Cooking EU 005 Distillation EU 006 Dryers EU 010 Anaerobic Water Treatment What to do 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. 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 +/ 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. 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. Temperature: greater than or equal to 1500 degrees F as a three-hour rolling average at the Combustion Chamber unless a new minimum is set pursuant to Minn. R , subp. 3, based on the average temperature recorded during the most recent MPCA approved performance test where compliance for VOC emissions was demonstrated. If the three-hour rolling average temperature drops below the minimum temperature limit, the VOC used during that time shall be considered uncontrolled until the average minimum temperature limit is once again achieved. This shall be reported as a deviation. The Permittee shall operate and maintain the thermal oxidizer any time that any process equipment controlled by the thermal oxidizer is in operation. Daily Monitoring: The Permittee shall physically check the temperature recording device at least once each operating day to verify that it is working and recording properly. Quarterly Inspections: At least once per calendar quarter, the Permittee shall inspect the control equipment external system components, including but not limited to the heat exchanger, and electrical systems. The Permittee shall maintain a written record of the inspection and any corrective actions taken resulting from the inspection. The Permittee shall inspect the control equipment internal components during all planned shutdowns and not less than annually, including, but not limited to, the refractory. Annual Calibration: The Permittee shall calibrate the temperature monitor at least annually and shall maintain a written record of the calibration and any action resulting from the calibration. 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. The Permittee shall operate and maintain the 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. FUEL USE RESTRICTIONS Fuel Use: limited to natural gas and propane. See the total facility requirements section for the limit on total facility propane use. By the 15th day of each month, record the previous month's propane usage. Calculate the previous 12 months propane usage. Record the results. Why to do it Minn. R , subp. 4 Minn. R , subp. 4 and 5 Title I Condition: Monitoring for Limit taken to avoid classification as a major source and modification under 40 CFR Section 52.21; to avoid classification as a major source under 40 CFR Section 70.2; Minn. R , subp. 4 and 5 Minn. R , subp. 4 and 5 Minn. R , subp. 4, 5, and 14 Minn. R , subp. 4, 5, and 14 Minn. R , subp. 4, 5, and 14 Minn. R , subp. 14, also meets the requirements of 40 CFR Section 60.48b(g)(2) A-18

23 RECORDKEEPING AND REPORTING Recordkeeping: Record and maintain records of the amounts of each fuel combusted on a monthly basis. These records may consist of purchase records or receipts. Maintain records of the fuel combusted each day and calculate annual capacity factors for each fuel. Maintain the following records for each operating day, and submit the information to the Agency quarterly: 1. Calendar date. 2. Average hourly nitrogen oxides emission rates expressed as NO2. 3. The 30-day average nitrogen oxides emission rate in lb/mmbtu calculated at the end of each operating day. 4. Identification of the operating days when the calculated 30-day average nitrogen oxides emission rates are in excess of the standards in this permit. 5. Identification of the operating days for which pollutant data have not been obtained, including reasons for not obtaining sufficient data and a description of corrective actions taken. 6. Identification of the times when emission data have been excluded from the calculation of average emission rates and reasons for excluding the data. The owner or operator of each affected facility subject to the nitrogen oxides standard of 40 CFR Section 60.44b who seeks to demonstrate compliance with those standards through the monitoring of steam generating unit operating conditions under the provisions of 40 CFR Section 60.48b(g)(2) shall submit to the Administrator for approval a plan that identifies the operating conditions to be monitored under 40 CFR Section 60.48b(g)(2) and the records to be maintained under 40 CFR Section 60.49b(j). This plan shall be submitted to the Administrator for approval within 360 days of the initial startup of the affected facility. The plan shall: 1. Identify the specific operating conditions to be monitored and the relationship between these operating conditions and nitrogen oxides emission rates (i.e., ng/j or lbs/million Btu heat input). Steam generating unit operating conditions include, but are not limited to, the degree of staged combustion (i.e., the ratio of primary air to secondary and/or tertiary air) and the level of excess air (i.e., flue gas oxygen level); 40 CFR Section 60.13(i) and February 20, 1992, EPA memorandum to meet the requirements of 40 CFR Section 60.48c(g) and (i) 40 CFR Section 60.49b(d) 40 CFR Section 60.49b(g) and (h) continued from above 40 CFR Section 60.49b(c) continued from above 2. Include the data and information that the owner or operator used to identify the relationship between nitrogen oxides emission rates and these operating conditions; 3. Identify how these operating conditions, including steam generating unit load, will be monitored under 40 CFR Section 60.48b(g) on an hourly basis by the owner or operator during the period of operation of the affected facility; the quality assurance procedures or practices that will be employed to ensure that the data generated by monitoring these operating conditions will be representative and accurate; and the type and format of the records of these operating conditions, including steam generating unit load, that will be maintained by the owner or operator under 40 CFR Section 60.49b(j). If the plan is approved, the owner or operator shall maintain records of predicted nitrogen oxide emission rates and the monitored operating conditions, including steam generating unit load, identified in the plan. continued from above A-19