AIR EMISSION PERMIT NO IS ISSUED TO. Van Hoven Company, Inc.

Transcription

1 AIR EMISSION PERMIT NO IS ISSUED TO Van Hoven Company, Inc. VAN HOVEN COMPANY, INC. 505 Hardman Avenue South South Saint Paul, Dakota County, Minnesota The emission units, control equipment and emission stacks at the stationary source authorized in this permit are as described in the following permit applications and documents: Permit Type Application Date Total Facility Operating Permit January 16, 1995 Minor Amendment December 18, 2000 Updates to Operating Permit Application April 8, 2002 Major Amendment September 3, 2002 This permit authorizes the Permittee to 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: Federal; Part 70 / Incorporates Existing NSR Conditions / Limits to Avoid NSR Issue Date: April 29, 2003 Expiration: April 29, 2008 All 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 I: Parameters Relied on in Dispersion Modeling Analysis Appendix II: Insignificant Activities Appendix III: Emission Unit Descriptions

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 provisions of the applicable requirements identified in the permit as the basis of each condition. Subject to the limitations Minn. R 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.

4 FACILITY DESCRIPTION: The Van Hoven Company recycles animal, vegetable, and food processing waste materials. The products manufactured from these recycled materials are primarily used by the animal feed manufacturing and chemical industries. The principle products processed at the Van Hoven Company manufacturing facility are: beef, poultry and pork by-products, animal and vegetable oils and a variety of other recycled waste materials from food processing, meat processing, and livestock industries. Van Hoven is an existing synthetic minor source with respect to New Source Review s (NSR) Prevention of Significant Deterioration (PSD) requirements because sulfur dioxide (SO2) emissions have been limited to less than 250 tons per year. Two boilers, a dryer, three pneumatic conveyance systems, two storage silos, a continuous milling system, two continuous cookers and a protein recovery facility made up of two small cookers and a small indirectly heated dryer are the only emission sources at the facility that are addressed in this operating permit. All other emission units qualify as insignificant activities under Minn. R , subps. 2, 3 and 4. The permit contains operating restrictions and associated monitoring and recordkeeping requirements limiting potential emissions from the two boilers and dryer (EUs 001, EU 002 and EU 006) to 240 tons per year of SO2 emissions. This permit authorizes the replacement of the continuous milling system s (EU 011) baghouse (CE 015) with a new centrifugal separator particulate capture unit (CE 016) as described in the application dated September 3, 2002.

5 TABLE A: LIMITS AND OTHER REQUIREMENTS 04/29/03 Facility Name: Permit Number: Van Hoven Co Inc 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 MODELING REQUIREMENTS What to do Parameters Used in Modeling: The stack heights, emission rates, and other parameters used in modeling done to demonstrate compliance with the National and Minnesota Ambient Air Quality Standards are listed in Appendix I of this permit. The Permittee must submit to the Commissioner for approval any revisions of these parameters and must wait for a written approval before making such changes. The information submitted must include, at a minimum: - the locations, heights and diameters of the stacks; - the locations and dimensions of nearby buildings; - the velocity and temperatures of the gases emitted; and - the emission rates of the pollutants being modeled. Why to do it 40 CFR 52.21(d), Minn. R and Minn. R continued from above The plume dispersion charateristics due to the revisions of the information must be equivalent to or better than the dispersion charateristics modeled in the previous submittal. The Permittee shall demonstrate this equivalency in the proposal. 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. OPERATIONAL REQUIREMENTS 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. 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 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 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). NOTIFICATION REQUIREMENTS Minn. R , subp. 14 and Minn. R , subp. 16(J) Minn. R Minn. R , subp. 2; Minn. R , subp. 16(J) Minn. R , subp. 4 Minn. R Minn. R Minn. R , subp. 9(A) A-1

6 TABLE A: LIMITS AND OTHER REQUIREMENTS 04/29/03 Facility Name: Van Hoven Co Inc Permit Number: 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. MONITORING EQUIPMENT REQUIREMENTS Monitoring Equipment Calibration: Annually calibrate all required monitoring equipment (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. PERFORMANCE TESTING REQUIREMENTS 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 , subp. 1 Minn. R , subp. 1 Minn. R , subp. 4(D) Minn. R , subp. 4(D) 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 RECORDKEEPING REQUIREMENTS 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. Minn. R , subp. 5(B) A-2

7 TABLE A: LIMITS AND OTHER REQUIREMENTS 04/29/03 Facility Name: Permit Number: Van Hoven Co Inc 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). REPORTING REQUIREMENTS Minn. R , subp. 5(C) Application for Permit Amendment: If a permit amendment is needed, submit an Minn. R through Minn. R 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 Minn. R , subp. 1(H) 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). 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 The Permittee shall comply with the General Conditions listed in Minn. R , subp. 16. Minn. R , subp. 16 A-3

8 TABLE A: LIMITS AND OTHER REQUIREMENTS 04/29/03 Facility Name: Van Hoven Co Inc Permit Number: Subject Item: GP 001 Combustion Equipment Subject to Facility-Wide SO2 Limit Associated Items: EU 001 Boiler No. 1 EU 002 Ring/Blood Dryer EU 006 Boiler No. 2 What to do EMISSION LIMITS Sulfur Dioxide: less than or equal to 240 tons/year using 12-month Rolling Sum as described below in Equation 1 to be calculated by the 15th day of each month for the previous 12-month period as described later in this permit. Equation 1: SO2 = [(EFr x S%r x VOLr)+(EFd x S%d x VOLd)+(EFrafvo x S%rafvo x VOLrafvo)] / 2000 Why to do it Title I Condition: Limit to avoid major source classification under 40 CFR Section 52.21; Minn. R Title I Condition: Limit to avoid major source classification under 40 CFR Section 52.21; Minn. R Where, SO2 = annual sulfur dioxide emissions (tons per year) Residual Fuel Oil -- EFr = most recent US EPA-approved emission factor for SO2 emissions from residual fuel oil combustion assuming all SO3 converts to SO2 (lb per gallon) S%r = 12-month weighted average residual fuel oil sulfur content as certified by the supplier (percent by weight) VOLr = volume of residual fuel oil fired by the emission units in GP 001 using 12-month rolling sum (gallons per year) Distillate Fuel Oil -- EFd = most recent US EPA-approved emission factor for SO2 emissions from distillate fuel oil combustion assuming all SO3 converts to SO2 (lb per gallon) S%d = 12-month weighted average distillate fuel oil sulfur content as certified by the supplier (percent by weight) VOLd = volume of distillate fuel oil fired by the emission units in GP 001 using 12-month rolling sum (gallons per year) Refined Animal Fats and Vegetable Oils (RAFVO) -- EFrafvo = most recent US EPA-approved emission factor for SO2 emissions based on distillate fuel oil combustion and assuming all SO3 converts to SO2 (lb per gallon) S%rafvo = average RAFVO sulfur content as certified by laboratory analysis (percent by weight) VOLrafvo = volume of RAFVO fired by the emission units in GP 001 using 12-month rolling sum (gallons per year) 2000 = conversion factor (lbs per ton) RECORDKEEPING REQUIREMENTS Daily Recordkeeping -- SO2 Emissions: continued from above continued from above Minn. R , subps. 4 and 5 The Permittee shall gather and record the following information: 1) Volume of residual fuel oil in gallons combusted in GP 001 for each day residual fuel oil is combusted in GP ) Volume of distillate fuel oil in gallons combusted in GP 001 for each day distillate fuel oil is combusted in GP ) Volume of refined animal fats and vegetable oils (RAFVO) in gallons combusted in GP 001 for each day RAFVO is combusted in GP 001. Monthly Recordkeeping -- SO2 Emissions: Minn. R , subps. 4 and 5 By the 15th day of the month, the Permittee shall record and calculate the following: 1) Volume of residual fuel oil in gallons combusted in GP 001 during the previous month, calculated by summing the data collected for each day residual fuel oil was combusted in GP ) Volume of distillate fuel oil in gallons combusted in GP 001 during the previous month, calculated by summing the data collected for each day distillate fuel oil was combusted in GP ) Volume of RAFVO in gallons combusted in GP 001 during the previous month, calculated by summing the data collected for each day RAFVO was combusted in GP 001. A-4

9 TABLE A: LIMITS AND OTHER REQUIREMENTS 04/29/03 Facility Name: Van Hoven Co Inc Permit Number: ) SO2 emissions from residual fuel oil, distillate fuel oil and RAFVO combustion from the previous 12 calendar months, calculated by using the data collected above from Items 1, 2 and 3 in Equation 1, and adding it the sum of the emissions data for the prior 11 months. continued from above A-5

10 TABLE A: LIMITS AND OTHER REQUIREMENTS 04/29/03 Facility Name: Van Hoven Co Inc Permit Number: Subject Item: Associated Items: GP 002 Continuous Milling System and Associated Control Equipment CE 015 Milling System Fabric Filter (LT) CE 016 Particulate Capture Unit EU 011 Continuous Milling System What to do CONSTRUCTION AUTHORIZATION This Permit authorizes the replacement of CE 015 with CE 016 within 30 days following Permit Issuance. After CE 016 is installed and operating, the requirements below will no longer apply to CE 015. EMISSION LIMITS -- Prior to the installation of CE 016 The Permittee shall operate and maintain CE 015 such that it achieves an overall control efficiency for Particulate Matter < 10 micron: greater than or equal to 90 percent control efficiency The Permittee shall operate and maintain CE 015 such that it achieves an overall control efficiency for Total Particulate Matter: greater than or equal to 90 percent control efficiency Vent emissions from EU 011 to CE 015 at all times EU 011 is in operation to meet applicable PM and PM10 limits. The Permittee shall operate and maintain the fabric filter at all times that any emission unit controlled by the fabric filter is in operation. MONITORING AND RECORDKEEPING REQUIREMENTS -- Prior to the installation of CE 016 Visible Emissions and Broken Bag Detector: The Permittee shall check CE 015's stack (SV 011) for any visible emissions and its broken bag detector once each day of operation during daylight hours. Recordkeeping of Visible Emissions and Broken Bag Detector for CE 015: The Permittee shall record the time and date of each visible emission inspection and broken bag detector reading, and whether or not any visible emissions were observed, and whether or not the broken bag detector indicated that a filter (or filters) required replacement. Corrective Actions: The Permittee shall take corrective action as soon as possible if any of the following occur: Why to do it Title I Condition: Limit to avoid major modification classification under 40 CFR Section Title I Condition: Limit to avoid major modification classification under 40 CFR Section Title I Condition: Limit to avoid major modification classification under 40 CFR Section Title I Condition: Limit to avoid major modification classification under 40 CFR Section Minn , subp. 4(B) Minn , subp. 5 Minn. R , subp. 4, 5 and 14 - visible emissions are observed; - the broken bag detector indicates that a filter (or filters) require(s) replacement; or, - CE 015 or any of its components are found during the inspections to need repair. Corrective actions shall 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 CE 015. The Permittee shall keep a record of the type and date of any corrective action taken for CE 015. Periodic Inspections: At least once per calendar quarter, or more frequently as required by the manufacturing specifications, the Permittee shall inspect CE 015's components. The Permittee shall maintain a written record of these inspections. EMISSION LIMITS -- After the installation of CE 016 The Permittee shall operate and maintain CE 016 such that it achieves an overall control efficiency for Total Particulate Matter: greater than or equal to 90 percent control efficiency The Permittee shall operate and maintain CE 016 such that it achieves an overall control efficiency for Particulate Matter < 10 micron: greater than or equal to 90 percent control efficiency Vent emissions from EU 011 to CE 016 at all times EU 011 is in operation to meet applicable PM and PM10 limits. The Permittee shall operate and maintain CE 016 at all times that any emission unit controlled by CE 016 is in operation. MONITORING AND RECORDKEEPING REQUIREMENTS -- After the installation of CE 016 Visible Emissions and Broken Bag Detector: The Permittee shall check CE 016's stack (SV 011) for any visible emissions and its broken bag detector once each day of operation during daylight hours. Minn. R , subp. 4, 5 and 14 Title I Condition: Limit to avoid major modification classification under 40 CFR Section Title I Condition: Limit to avoid major modification classification under 40 CFR Section Title I Condition: Limit to avoid major modification classification under 40 CFR Section Minn , subp. 4(B) A-6

11 TABLE A: LIMITS AND OTHER REQUIREMENTS 04/29/03 Facility Name: Van Hoven Co Inc Permit Number: Recordkeeping of Visible Emissions and Broken Bag Detector for CE 016: The Permittee shall record the time and date of each visible emission inspection and broken bag detector reading, and whether or not any visible emissions were observed, and whether or not the broken bag detector indicated that a part on CE 016 required repair or replacement. Corrective Actions: The Permittee shall take corrective action as soon as possible if any of the following occur: Minn , subp. 5 Minn. R , subp. 4, 5 and 14 - visible emissions are observed; - the broken bag detector indicates that a part on CE 016 requires replacement; or, - CE 016 or any of its components are found during the inspection to need repair. Corrective actions shall 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 CE 016. The Permittee shall keep a record of the type and date of any corrective action taken for CE 016. Periodic Inspections: At least once per calendar quarter, or more frequently as required by the manufacturing specifications, the Permittee shall inspect CE 016's components. The Permittee shall maintain a written record of these inspections. Minn. R , subp. 4, 5 and 14 A-7

12 TABLE A: LIMITS AND OTHER REQUIREMENTS 04/29/03 Facility Name: Van Hoven Co Inc Permit Number: Subject Item: Associated Items: GP 003 Continuous Cookers CE 012 Continuous Cooker Scrubber EU 012 Continuous Cooker No. 1 EU 013 Continuous Cooker No. 2 SV 012 Continuous Cookers What to do EMISSION LIMITS Total Particulate Matter: less than or equal to 6.57 lbs/hour using 3-hour Average. This limit applies at SV 012. Particulate Matter < 10 micron: less than or equal to 6.57 lbs/hour using 3-hour Average. This limit applies at SV 012. 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. OPERATIONAL REQUIREMENTS Vent emissions from EU 012 and EU 013 to CE 012 at all times EU 012 and EU 013 are in operation to meet applicable PM and PM10 limits. The Permittee shall operate and maintain CE 012 at all times that any emission unit controlled by CE 012 is in operation. MONITORING AND RECORDKEEPING REQUIREMENTS See CE 012 for additional Monitoring and Recordkeeping Requirements for CE 012. Why to do it Title I Condition: Limit to avoid major modification classification under 40 CFR Section Title I Condition: Limit to avoid major modification classification under 40 CFR Section Minn. R , subp. 1(A) Minn. R , subp. 1(B) Title I Condition: Limit to avoid major modification classification under 40 CFR Section A-8

13 TABLE A: LIMITS AND OTHER REQUIREMENTS 04/29/03 Facility Name: Van Hoven Co Inc Permit Number: Subject Item: Associated Items: GP 004 Blood System (BS) Fabric Filters CE 006 BS Bin C & E Fabric Filter (LT) CE 014 BS Bin 9 & 10 Fabric Filter (LT) What to do OPERATIONAL REQUIREMENTS The Permittee shall operate and maintain CE 006 and CE 014 such that they each achieve an overall control efficiency for Particulate Matter < 10 micron: greater than or equal to 99 percent control efficiency The Permittee shall operate and maintain CE 006 and CE 014 such that they each achieve an overall control efficiency for Total Particulate Matter: greater than or equal to 99 percent control efficiency MONITORING EQUIPMENT INSTALLATION REQUIREMENTS Broken Bag Detector: The Permittee shall install broken bag detectors on CE 006 and CE 014 within 120 days after Permit Issuance. MONITORING AND RECORDKEEPING REQUIREMENTS Visible Emissions and Broken Bag Detector: The Permittee shall check the stack (SV 005) for CE 006 and CE 014 for any visible emissions and their broken bag detectors once each day of operation during daylight hours. Recordkeeping of Visible Emissions and Broken Bag Detector for CE 006 and CE 014: The Permittee shall record the time and date of each visible emission inspection and broken bag detector reading, and whether or not any visible emissions were observed, and whether or not either of the broken bag detectors indicated that a filter (or filters) required replacement. Corrective Actions: The Permittee shall take corrective action as soon as possible if any of the following occur: Why to do it Title I Condition: Limit relied on in modeling to demonstrate compliance with 40 CFR Section 52.21(d), National Ambient Air Quality Standards To demonstrate compliance with Minn. R , subp. 1(A) Title I Condition: Monitoring to demonstrate compliance with limit relied on in modeling to demonstrate compliance with 40 CFR Section 52.21(d), National Ambient Air Quality Standards Minn , subp. 4(B) Minn , subp. 5 Minn. R , subp. 4, 5 and 14 - visible emissions are observed; - a broken bag detector indicates that a filter (or filters) require(s) replacement; or, - CE 006 or CE 014 or any of their components are found during the inspections to need repair. Corrective actions shall 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 CE 006 and CE 014. The Permittee shall keep a record of the type and date of any corrective action taken for CE 006 and CE 014. Periodic Inspections: At least once per calendar quarter, or more frequently as required by the manufacturing specifications, the Permittee shall inspect the components of CE 006 and CE 014. The Permittee shall maintain a written record of these inspections. Minn. R , subp. 4, 5 and 14 A-9

14 TABLE A: LIMITS AND OTHER REQUIREMENTS 04/29/03 Facility Name: Van Hoven Co Inc Permit Number: Subject Item: Associated Items: GP 005 Protein Silo Fabric Filters CE 010 Protein Silo #1 Fabric Filter (LT) CE 011 Protein Silo #2 Fabric Filter (LT) What to do OPERATIONAL REQUIREMENTS The Permittee shall operate and maintain CE 010 and CE 011 such that they each achieve an overall control efficiency for Particulate Matter < 10 micron: greater than or equal to 99 percent control efficiency The Permittee shall operate and maintain CE 010 and CE 011 such that they each achieve an overall control efficiency for Total Particulate Matter: greater than or equal to 99 percent control efficiency MONITORING EQUIPMENT INSTALLATION REQUIREMENTS Broken Bag Detector: The Permittee shall install broken bag detectors on CE 010 and CE 011 within 120 days after Permit Issuance. MONITORING AND RECORDKEEPING REQUIREMENTS Visible Emissions and Broken Bag Detector: The Permittee shall check each fabric filter's stack (SV 009 and SV 010) for any visible emissions and their broken bag detectors once each day of operation during daylight hours. Recordkeeping of Visible Emissions and Broken Bag Detector for CE 006 and CE 014: The Permittee shall record the time and date of each visible emission inspection and broken bag detector reading, and whether or not any visible emissions were observed, and whether or not either of the broken bag detectors indicated that a filter (or filters) required replacement. Corrective Actions: The Permittee shall take corrective action as soon as possible if any of the following occur: Why to do it Title I Condition: Limit relied on in modeling to demonstrate compliance with 40 CFR Section 52.21(d), National Ambient Air Quality Standards Minn. R , subp. 16(J) to ensure maintenance with Minn. R , Minnesota Ambient Air Quality Standards Title I Condition: Monitoring to demonstrate compliance with limit relied on in modeling to demonstrate compliance with 40 CFR Section 52.21(d), National Ambient Air Quality Standards Minn , subp. 4(B) Minn , subp. 5 Minn. R , subp. 4, 5 and 14 - visible emissions are observed; - a broken bag detector indicates that a filter (or filters) require(s) replacement; or, - CE 010 or CE 011 or any of their components are found during the inspections to need repair. Corrective actions shall 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 CE 010 and CE 011. The Permittee shall keep a record of the type and date of any corrective action taken for CE 010 and CE 011. Periodic Inspections: At least once per calendar quarter, or more frequently as required by the manufacturing specifications, the Permittee shall inspect the components of CE 010 and CE 011. The Permittee shall maintain a written record of these inspections. Minn. R , subp. 4, 5 and 14 A-10

15 TABLE A: LIMITS AND OTHER REQUIREMENTS 04/29/03 Facility Name: Permit Number: Van Hoven Co Inc Subject Item: EU 001 Boiler No. 1 Associated Items: GP 001 Combustion Equipment Subject to Facility-Wide SO2 Limit SV 001 Boiler No. 1 What to do EMISSION LIMITS Particulate Matter < 10 micron: less than or equal to 7.0 lbs/hour (maximum uncontrolled emissions from this unit are 5.0 lbs/hour). Total Particulate Matter: less than or equal to 0.4 lbs/million Btu heat input (maximum uncontrolled emissions from this unit are 0.11 lbs/million Btu heat input). Sulfur Dioxide: less than or equal to 2.0 lbs/million Btu heat input when burning residual fuel oil or refined animal fats & vegetable oils (maximum uncontrolled emissions from this unit are 1.59 lbs/million Btu heat input). Opacity: less than or equal to 20 percent except for one six-minute period per hour of not more than 60 percent opacity. MONITORING AND RECORDKEEPING REQUIREMENTS See GP 001 for additional Monitoring and Recordkeeping requirements for EU 001. Why to do it Title I Condition: Limit relied on in modeling to demonstrate compliance with 40 CFR Section 52.21(d), National Ambient Air Quality Standards Minn. R , subp. 1 Minn. R , subp. 1 Minn. R , subp. 2 A-11

16 TABLE A: LIMITS AND OTHER REQUIREMENTS 04/29/03 Facility Name: Permit Number: Van Hoven Co Inc Subject Item: EU 002 Ring/Blood Dryer Associated Items: CE 001 Blood Process Scrubber GP 001 Combustion Equipment Subject to Facility-Wide SO2 Limit SV 002 Ring/Blood Dryer What to do EMISSION LIMITS Particulate Matter < 10 micron: less than or equal to 2.0 lbs/hour. 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 Sulfur Dioxide: less than or equal to 2.0 lbs/million Btu heat input when burning distillate fuel oil (maximum uncontrolled emissions from this unit are 0.51 lbs/million Btu heat input). 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 Vent emissions from EU 002 to CE 001 at all times EU 002 is in operation to meet applicable PM and PM10 limits. The Permittee shall operate and maintain CE 001 at all times that any emission unit controlled by CE 001 is in operation. MONITORING AND RECORDKEEPING REQUIREMENTS See GP 001 for additional Monitoring and Recordkeeping requirements for EU 002. See CE 001 for additional Monitoring and Recordkeeping requirements for CE 001. Why to do it Title I Condition: Limit relied on in modeling to demonstrate compliance with 40 CFR Section 52.21(d), National Ambient Air Quality Standards Minn. R , subp. 1(A)(1) Minn. R , subp. 2(A)(2) Minn. R , subp. 1(A)(2) Title I Condition: Limit relied on in modeling to demonstrate compliance with 40 CFR Section 52.21(d), National Ambient Air Quality Standards; Minn , subp. 16(J) A-12

17 TABLE A: LIMITS AND OTHER REQUIREMENTS 04/29/03 Facility Name: Permit Number: Van Hoven Co Inc Subject Item: EU 003 Protein Recovery Facility (PRF) Associated Items: CE 003 PRF Scrubber SV 003 Protein Recovery Facility What to do EMISSION LIMITS Total Particulate Matter: less than or equal to 2.0 lbs/hour. Since the National Ambient Air Quality Standard for Particulate Matter as Total Suspended Particulates no longer exists, this is a state-only requirement and is not enforceable by the Administrator or citizens under the Clean Air Act. Particulate Matter < 10 micron: less than or equal to 2.0 lbs/hour. 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. OPERATIONAL REQUIREMENTS Vent emissions from EU 003 to CE 003 at all times EU 003 is in operation to meet applicable PM and PM10 limits. The Permittee shall operate and maintain CE 003 at all times that any emission unit controlled by CE 003 is in operation. MONITORING AND RECORDKEEPING REQUIREMENTS See CE 003 for Monitoring and Recordkeeping Requirements of CE 003. Why to do it Limit relied on in modeling to demonstrate compliance with 40 CFR Section 52.21(d), National Ambient Air Quality Standards and carried forward as maintenance with Minn. R , Minnesota Ambient Air Quality Standards Title I Condition: Limit relied on in modeling to demonstrate compliance with 40 CFR Section 52.21(d), National Ambient Air Quality Standards Minn. R , subp. 1(A) Minn. R , subp. 1(B) Title I Condition: Limit relied on in modeling to demonstrate compliance with 40 CFR Section 52.21(d), National Ambient Air Quality Standards; Minn , subp. 16(J) A-13

18 TABLE A: LIMITS AND OTHER REQUIREMENTS 04/29/03 Facility Name: Permit Number: Van Hoven Co Inc Subject Item: EU 005 Blood Pneumatic Conveying System Associated Items: CE 006 BS Bin C & E Fabric Filter (LT) CE 014 BS Bin 9 & 10 Fabric Filter (LT) SV 005 Blood Pneumatic Conveying System What to do EMISSION LIMITS Particulate Matter < 10 micron: less than or equal to 0.05 lbs/hour. 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. OPERATIONAL REQUIREMENTS Vent emissions from EU 005 to CE 006 or CE 014 at all times EU 005 is in operation to meet applicable PM and PM10 limits. The Permittee shall operate and maintain the fabric filter at all times that any emission unit controlled by the fabric filter is in operation. MONITORING AND RECORDKEEPING REQUIREMENTS See GP 004 for additional Monitoring and Recordkeeping requirements for CE 006 and CE 014. Why to do it Title I Condition: Limit relied on in modeling to demonstrate compliance with 40 CFR Section 52.21(d), National Ambient Air Quality Standards Minn. R , subp. 1(A) Minn. R , subp. 1(B) Title I Condition: Limit relied on in modeling to demonstrate compliance with 40 CFR Section 52.21(d), National Ambient Air Quality Standards; Minn , subp. 16(J) A-14

19 TABLE A: LIMITS AND OTHER REQUIREMENTS 04/29/03 Facility Name: Permit Number: Van Hoven Co Inc Subject Item: EU 006 Boiler No. 2 Associated Items: GP 001 Combustion Equipment Subject to Facility-Wide SO2 Limit SV 006 Boiler No. 2 What to do EMISSION LIMITS Particulate Matter < 10 micron: less than or equal to 2.0 lbs/hour (maximum uncontrolled emissions from this unit are 0.13 lbs/hour). Total Particulate Matter: less than or equal to 2.0 lbs/hour (maximum uncontrolled emissions from this unit are 0.25 lbs/hour). This is a state only requirement and is not enforceable by the Administrator or the citizens under the Clean Air Act. Sulfur Content of Fuel: less than or equal to 0.5 percent by weight as certified by fuel supplier. The SO2 emission limit applies at all times, including periods of startup, shutdown and malfunctions. Total Particulate Matter: less than or equal to 0.4 lbs/million Btu heat input (maximum uncontrolled emissions from this unit are lbs/million Btu heat input). Sulfur Dioxide: less than or equal to 2.0 lbs/million Btu heat input when burning distillate fuel oil. Opacity: less than or equal to 20 percent except for one six-minute period per hour of not more than 60 percent opacity. MONITORING, RECORDKEEPING and REPORTING REQUIREMENTS Sulfur Content of Fuel: Obtain certification from fuel supplier to demonstrate compliance with SO2 limit. Certification from fuel supplier shall include name of the fuel supplier and a statement from the fuel supplier that the fuel oil complies with the specifications under the definition of distillate fuel oil following each fuel delivery. Recordkeeping: The Permittee shall record amount of each fuel combusted in EU 006 each month. Records shall be in the form of fuel bills or meter readings. Recordkeeping: The Permittee shall maintain all records for a minimum of two years. Reporting: The Permittee shall submit excess emissions reports quarterly if there are excess emissions by the 30th day of the third month following completion of the initial performance test, or semiannually if no excess emissions by the 30th day of the sixth month following completion of the initial performance test. Each subsequent quarterly or semiannual report shall be postmarked by the 30th day following the end of the reporting period. Reporting: The Permittee shall submit quarterly reports on fuel oil sulfur limits. Reports shall be postmarked by the 30th day following the end of each quarter. Quarterly reports shall include records of fuel supplier certification, and certified statement that the records represent all fuel combusted. The fuel supplier certification must include the name of the fuel supplier and a statement from the fuel supplier that the fuel oil complies with the specifications under the definition of distillate fuel oil. Notification: The Permittee shall provide notification of any physical or operational change to an existing facility which may increase the emission rate of any air pollutant to which a standard applies, due no later than 60 days or as soon as practical before the change is commenced. See GP 001 for additional Monitoring and Recordkeeping requirements for EU 006. Why to do it Title I Condition: Limit relied on in modeling to demonstrate compliance with 40 CFR Section 52.21(d), National Ambient Air Quality Standards Limit relied on in modeling to demonstrate compliance with 40 CFR Section 52.21(d), National Ambient Air Quality Standards and carried forward as maintenance with Minn. R , Minnesota Ambient Air Quality Standards 40 CFR Section 60.42c(d) which meets the SO2 limit in lb/mmbtu in 40 CFR Section 60.42c(d) and Minn. R , subp CFR Section 60.42c(i) Minn. R , subp. 1 Minn. R , subp. 1 Minn. R , subp CFR Section 60.44c(h) 40 CFR Section 60.48c(g) 40 CFR Section 60.48c(i) 40 CFR Sections 60.48c(c) 40 CFR Sections 60.48c(d), 60.48c(e)(11) and 60.48c(f) 40 CFR Section 60.7(a)(4) A-15

20 TABLE A: LIMITS AND OTHER REQUIREMENTS 04/29/03 Facility Name: Permit Number: Van Hoven Co Inc Subject Item: EU 009 Protein Silo No. 1 Associated Items: CE 010 Protein Silo #1 Fabric Filter (LT) SV 009 Protein Silo No. 1 What to do EMISSION LIMITS Total Particulate Matter: less than or equal to 0.10 lbs/hour. Since the National Ambient Air Quality Standard for Particulate Matter as Total Suspended Particulates no longer exists, this is a state only requirement and is not enforceable by the Administrator or citizens under the Clean Air Act. Particulate Matter < 10 micron: less than or equal to 0.10 lbs/hour. 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. OPERATIONAL REQUIREMENTS Vent emissions from EU 009 to CE 010 at all times EU 009 is in operation to meet applicable PM and PM10 limits. The Permittee shall operate and maintain the fabric filter at all times that any emission unit controlled by the fabric filter is in operation. MONITORING AND RECORDKEEPING REQUIREMENTS See GP 005 for additional Monitoring and Recordkeeping Requirements of CE 010. dr Why to do it Limit relied on in modeling to demonstrate compliance with 40 CFR Section 52.21(d), National Ambient Air Quality Standards and carried forward as maintenance with Minn. R , Minnesota Ambient Air Quality Standards Title I Condition: Limit relied on in modeling to demonstrate compliance with 40 CFR Section 52.21(d), National Ambient Air Quality Standards Minn. R , subp. 1(A) Minn. R , subp. 1(B) Limit relied on in modeling to demonstrate compliance with 40 CFR Section 52.21(d), National Ambient Air Quality Standards; Minn , subp. 16(J) A-16

21 TABLE A: LIMITS AND OTHER REQUIREMENTS 04/29/03 Facility Name: Permit Number: Van Hoven Co Inc Subject Item: EU 010 Protein Silo No. 2 Associated Items: CE 011 Protein Silo #2 Fabric Filter (LT) SV 010 Protein Silo No. 2 What to do EMISSION LIMITS Total Particulate Matter: less than or equal to 0.10 lbs/hour. Since the National Ambient Air Quality Standard for Particulate Matter as Total Suspended Particulates no longer exists, this is a state only requirement and is not enforceable by the Administrator or citizens under the Clean Air Act. Particulate Matter < 10 micron: less than or equal to 0.10 lbs/hour. 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. OPERATIONAL REQUIREMENTS Vent emissions from EU 010 to CE 011 at all times EU 010 is in operation to meet applicable PM and PM10 limits. The Permittee shall operate and maintain the fabric filter at all times that any emission unit controlled by the fabric filter is in operation. MONITORING AND RECORDKEEPING REQUIREMENTS See GP 005 for additional Monitoring and Recordkeeping Requirements of CE 011. Why to do it Limit relied on in modeling to demonstrate compliance with 40 CFR Section 52.21(d), National Ambient Air Quality Standards and carried forward as maintenance with Minn. R , Minnesota Ambient Air Quality Standards Title I Condition: Limit relied on in modeling to demonstrate compliance with 40 CFR Section 52.21(d), National Ambient Air Quality Standards Minn. R , subp. 1(A) Minn. R , subp. 1(B) Limit relied on in modeling to demonstrate compliance with 40 CFR Section 52.21(d), National Ambient Air Quality Standards; Minn , subp. 16(J) A-17

22 TABLE A: LIMITS AND OTHER REQUIREMENTS 04/29/03 Facility Name: Permit Number: Van Hoven Co Inc Subject Item: EU 011 Continuous Milling System Associated Items: CE 015 Milling System Fabric Filter (LT) CE 016 Particulate Capture Unit GP 002 Continuous Milling System and Associated Control Equipment SV 011 Continuous Milling System What to do EMISSION LIMITS Total Particulate Matter: less than or equal to 3.38 lbs/hour using 3-hour Average. This limit applies at SV 011. Particulate Matter < 10 micron: less than or equal to 3.38 lbs/hour using 3-hour Average. This limit applies at SV 011. 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. OTHER REQUIREMENTS See GP 002 for Operational, Recordkeeping and Monitoring Requirements for the continuous milling system (EU 011) and its associated control equipment (CE 015 and CE 016). Why to do it Title I Condition: Limit to avoid major modification classification under 40 CFR Section Title I Condition: Limit to avoid major modification classification under 40 CFR Section Minn. R , subp. 1(A) Minn. R , subp. 1(B) A-18

23 TABLE A: LIMITS AND OTHER REQUIREMENTS 04/29/03 Facility Name: Permit Number: Van Hoven Co Inc Subject Item: EU 014 Feather Pneumatic Conveying System Associated Items: CE 009 Feather System Fab. Filter (LT) SV 014 Feather Pneumatic Conveying System What to do EMISSION LIMITS 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. OPERATIONAL REQUIREMENTS Vent emissions from EU 014 to CE 009 at all times EU 014 is in operation to meet applicable PM limit. The Permittee shall operate and maintain the fabric filter at all times that any emission unit controlled by the fabric filter is in operation. MONITORING AND RECORDKEEPING REQUIREMENTS See CE 009 for Monitoring and Recordkeeping Requirements for CE 009. Why to do it Minn. R , subp. 1(A) Minn. R , subp. 1(B) Minn , subp. 16(J) A-19

24 TABLE A: LIMITS AND OTHER REQUIREMENTS 04/29/03 Facility Name: Permit Number: Van Hoven Co Inc Subject Item: CE 001 Blood Process Scrubber Associated Items: EU 002 Ring/Blood Dryer What to do OPERATIONAL REQUIREMENTS The Permittee shall operate and maintain the control equipment such that it achieves an overall control efficiency for Particulate Matter < 10 micron: greater than or equal to 90 percent control efficiency The Permittee shall operate and maintain the control equipment such that it achieves an overall control efficiency for Total Particulate Matter: greater than or equal to 90 percent control efficiency MONITORING AND RECORDKEEPING REQUIREMENTS The Permittee shall read and record the pressure drop and liquid flow rate across CE 001, once each day of operation. Pressure Drop: greater than or equal to 4 inches of water column and less than or equal to 6 inches of water column across CE 001. Liquid Flow Rate: greater than or equal to 48 gallons/minute through CE 001. Recordkeeping of Pressure Drop and Liquid Flow Rate. The Permittee shall record the time and date of each pressure drop and liquid flow rate reading, whether or not any visible emissions were observed, and whether or not the observed pressure drop liquid flow rate were within the ranges specified in this permit. 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 and/or liquid flow rate are outside the required operating ranges; or - CE 001 or any of its components are found during the inspections to need repair. Why to do it Title I Condition: Limit relied on in modeling to demonstrate compliance with 40 CFR Section 52.21(d), National Ambient Air Quality Standards To demonstrate compliance with Minn , subp. 1(A)(1) Title I Condition: Monitoring to demonstrate compliance with limit relied on in modeling to demonstrate compliance with 40 CFR Section 52.21(d), National Ambient Air Quality Standards and Minn. R Minn , subp. 4(B) Minn , subp. 4(B) Minn , subp. 5 Minn. R , subp. 4, 5 and 14 Corrective actions shall return the pressure drop and/or liquid flow rate to within the permitted ranges 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 CE 001. The Permittee shall keep a record of the type and date of any corrective action taken for CE 001. 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 , subp. 4, 5 and 14 A-20

25 TABLE A: LIMITS AND OTHER REQUIREMENTS 04/29/03 Facility Name: Permit Number: Van Hoven Co Inc Subject Item: CE 003 PRF Scrubber Associated Items: EU 003 Protein Recovery Facility (PRF) What to do OPERATIONAL REQUIREMENTS The Permittee shall operate and maintain the control equipment such that it achieves an overall control efficiency for Particulate Matter < 10 micron: greater than or equal to 90 percent control efficiency The Permittee shall operate and maintain the control equipment such that it achieves an overall control efficiency for Total Particulate Matter: greater than or equal to 90 percent control efficiency MONITORING AND RECORDKEEPING REQUIREMENTS The Permittee shall read and record the pressure drop and liquid flow rate across CE 003, once each day of operation. Pressure Drop: greater than or equal to 4 inches of water column and less than or equal to 6 inches of water column across CE 003. Liquid Flow Rate: greater than or equal to 16 gallons/minute through CE 003. Recordkeeping of Pressure Drop and Liquid Flow Rate. The Permittee shall record the time and date of each pressure drop and liquid flow rate reading, whether or not any visible emissions were observed, and whether or not the observed pressure drop liquid flow rate were within the ranges specified in this permit. 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 and/or liquid flow rate are outside the required operating ranges; or - CE 003 or any of its components are found during the inspections to need repair. Why to do it Title I Condition: Limit relied on in modeling to demonstrate compliance with 40 CFR Section 52.21(d), National Ambient Air Quality Standards Minn. R , subp. 16(J) to ensure maintenance with Minn. R , Minnesota Ambient Air Quality Standards Title I Condition: Monitoring to demonstrate compliance with limit relied on in modeling to demonstrate compliance with 40 CFR Section 52.21(d), National Ambient Air Quality Standards and Minn. R Minn , subp. 4(B) Minn , subp. 4(B) Minn , subp. 5 Minn. R , subp. 4, 5 and 14 Corrective actions shall return the pressure drop and/or liquid flow rate to within the permitted ranges 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 CE 003. The Permittee shall keep a record of the type and date of any corrective action taken for CE 003. 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 , subp. 4, 5 and 14 A-21

26 TABLE A: LIMITS AND OTHER REQUIREMENTS 04/29/03 Facility Name: Permit Number: Van Hoven Co Inc Subject Item: CE 009 Feather System Fab. Filter (LT) Associated Items: EU 008 Storage Silo EU 014 Feather Pneumatic Conveying System What to do OPERATIONAL REQUIREMENTS The Permittee shall operate and maintain the control equipment such that it achieves an overall control efficiency for Particulate Matter < 10 micron: greater than or equal to 90 percent control efficiency The Permittee shall operate and maintain the control equipment such that it achieves an overall control efficiency for Total Particulate Matter: greater than or equal to 90 percent control efficiency MONITORING EQUIPMENT INSTALLATION REQUIREMENTS Broken Bag Detector: The Permittee shall install a broken bag detector on CE 009 within 120 days after Permit Issuance. MONITORING AND RECORDKEEPING REQUIREMENTS Visible Emissions and Broken Bag Detector: The Permittee shall check CE 009's stack (SV 014) for any visible emissions and its broken bag detector once each day of operation during daylight hours. Recordkeeping of Visible Emissions and Broken Bag Detector for CE 009: The Permittee shall record the time and date of each visible emission inspection and broken bag detector reading, and whether or not any visible emissions were observed, and whether or not the broken bag detector indicated that a filter (or filters) required replacement. Corrective Actions: The Permittee shall take corrective action as soon as possible if any of the following occur: Why to do it Minn. R , subp. 16(J) Minn. R , subp. 16(J) Title I Condition: Monitoring to demonstrate compliance with limit relied on in modeling to demonstrate compliance with 40 CFR Section 52.21(d), National Ambient Air Quality Standards Minn , subp. 4(B) Minn , subp. 5 Minn. R , subp. 4, 5 and 14 - visible emissions are observed; - the broken bag detector indicates that a filter (or filters) require(s) replacement; or, - CE 009 or any of its components are found during the inspections to need repair. Corrective actions shall 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 CE 009. The Permittee shall keep a record of the type and date of any corrective action taken for CE 009. Periodic Inspections: At least once per calendar quarter, or more frequently as required by the manufacturing specifications, the Permittee shall inspect CE 009's components. The Permittee shall maintain a written record of these inspections. Minn. R , subp. 4, 5 and 14 A-22

27 TABLE A: LIMITS AND OTHER REQUIREMENTS 04/29/03 Facility Name: Permit Number: Van Hoven Co Inc Subject Item: CE 012 Continuous Cooker Scrubber Associated Items: EU 012 Continuous Cooker No. 1 EU 013 Continuous Cooker No. 2 GP 003 Continuous Cookers What to do OPERATIONAL REQUIREMENTS The Permittee shall operate and maintain the control equipment such that it achieves an overall control efficiency for Particulate Matter < 10 micron: greater than or equal to 90 percent control efficiency The Permittee shall operate and maintain the control equipment such that it achieves an overall control efficiency for Total Particulate Matter: greater than or equal to 90 percent control efficiency MONITORING AND RECORDKEEPING REQUIREMENTS The Permittee shall read and record the pressure drop and liquid flow rate across CE 012, once each day of operation. Pressure Drop: greater than or equal to 4 inches of water column and less than or equal to 6 inches of water column across CE 012. Liquid Flow Rate: greater than or equal to 65 gallons/minute through CE 012. Recordkeeping of Pressure Drop and Liquid Flow Rate. The Permittee shall record the time and date of each pressure drop and liquid flow rate reading, whether or not any visible emissions were observed, and whether or not the observed pressure drop liquid flow rate were within the ranges specified in this permit. 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 and/or liquid flow rate are outside the required operating ranges; or - CE 012 or any of its components are found during the inspections to need repair. Why to do it Title I Condition: Limit to avoid major modification classification under 40 CFR Section Title I Condition: Limit to avoid major modification classification under 40 CFR Section Title I Condition: Monitoring to demonstrate compliance with limit to avoid major modification classification under 40 CFR Section 52.21and Minn Minn , subp. 4(B) Minn , subp. 4(B) Minn , subp. 5 Minn. R , subp. 4, 5 and 14 Corrective actions shall return the pressure drop and/or liquid flow rate to within the permitted ranges 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 CE 012. The Permittee shall keep a record of the type and date of any corrective action taken for CE 012. 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 , subp. 4, 5 and 14 A-23

28 TABLE B: SUBMITTALS Facility Name: Van Hoven Co Inc Permit Number: /29/03 Table B lists most of the submittals required by this permit. Please note that some submittal requirements may appear in Table A or, if applicable, within a compliance schedule located in Table C. Table B is divided into two sections in order to separately list one-time only and recurrent submittal requirements. Each submittal must be postmarked or received by the date specified in the applicable Table. Those submittals required by parts to must be certified by a responsible official, defined in Minn. R , subp. 21. Other submittals shall be certified as appropriate if certification is required by an applicable rule or permit condition. Send any application for a permit or permit amendment to: Permit Technical Advisor Permit Section Air Quality Division Minnesota Pollution Control Agency 520 Lafayette Road North St. Paul, Minnesota Also, where required by an applicable rule or permit condition, send to the Permit Technical Advisor notices of: - accumulated insignificant activities, - installation of control equipment, - replacement of an emissions unit, and - changes that contravene a permit term. Unless another person is identified in the applicable Table, send all other submittals to: Supervisor Compliance Determination Unit Air Quality Division Minnesota Pollution Control Agency 520 Lafayette Road North St. Paul, Minnesota Send submittals that are required to be submitted to the U.S. EPA regional office to: Mr. George Czerniak Air and Radiation Branch EPA Region V 77 West Jackson Boulevard Chicago, Illinois Send submittals that are required by the Acid Rain Program to: U.S. Environmental Protection Agency Clean Air Markets Division 1200 Pennsylvania Avenue NW (6204N) Washington, D.C B-1

29 TABLE B: ONE TIME SUBMITTALS OR NOTIFICATIONS Facility Name: Van Hoven Co Inc Permit Number: /29/03 What to send When to send Portion of Facility Affected Application for Permit Reissuance due 180 days before expiration of Existing Total Facility Permit. Computer Dispersion Modeling Information due 1,096 days after Permit Issuance. Submit Total Facility modeling data as specified in MPCA guidance for Modeling Information Requests (for pollutant). This modeling information is for data collection purposes, no modeling analysis is required at this time. This is a state only requirement and is not enforceable by the EPA Administrator or citizens under the Clean Air Act. Notification due 7 days before Start Of Construction on GP004 the installation of broken bag detectors on CE 006 and CE 014. Notification due 7 days before Start Of Construction on GP005 the installation of broken bag detectors on CE 010 and CE 011. Notification due 7 days before Start Of Construction on GP002 the installation of CE 016. Notification due 7 days before Start Of Construction on the installation of the broken bag detector on CE 009. CE009 B-2

30 TABLE B: RECURRENT SUBMITTALS Facility Name: Van Hoven Co Inc Permit Number: /29/03 What to send When to send Portion of Facility Affected Semiannual Deviations Report due 30 days after end of each calendar Total Facility half-year following Permit Issuance. 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 occured, the Permittee shall submit the report stating no deviations. Compliance Certification due 31 days after end of each calendar year following Permit Issuance (for the previous calendar year). To be submitted on a form approved by the Commissioner, both to the Commissioner and to the US EPA regional office in Chicago. This report covers all deviations experienced during the calendar year. Total Facility B-3

31 TABLE C: COMPLIANCE SCHEDULE Facility Name: Van Hoven Co Inc Permit Number: /29/03 Table C contains the compliance schedule as required by Minn. R , subp. 2 (K). You must complete the actions required in Table C by the dates listed in the table. All submittals must be postmarked or received by the date specified in the table, and certified by a responsible official, defined in Minn. R , subp. 21. Subject Item: CE 001 Blood Process Scrubber Associated Items: EU 002 Ring/Blood Dryer Citation Title I Condition: Monitoring to demonstrate compliance with limit relied on in modeling to demonstrate compliance with 40 CFR Section 52.21(d), National Ambient Air Quality Standards and Minn. R Title I Condition: Monitoring to demonstrate compliance with limit relied on in modeling to demonstrate compliance with 40 CFR Section 52.21(d), National Ambient Air Quality Standards and Minn. R Corrective Action Pressure Drop Monitoring Equipment Installation Notification When to complete the action due 120 days after Permit Issuance due 7 days after Equipment Installation. C-1

32 TABLE C: COMPLIANCE SCHEDULE Facility Name: Van Hoven Co Inc Permit Number: /29/03 Subject Item: CE 003 PRF Scrubber Associated Items: EU 003 Protein Recovery Facility (PRF) Citation Title I Condition: Monitoring to demonstrate compliance with limit relied on in modeling to demonstrate compliance with 40 CFR Section 52.21(d), National Ambient Air Quality Standards and Minn. R Title I Condition: Monitoring to demonstrate compliance with limit relied on in modeling to demonstrate compliance with 40 CFR Section 52.21(d), National Ambient Air Quality Standards and Minn. R Corrective Action Pressure Drop Monitoring Equipment Installation Notification When to complete the action due 120 days after Permit Issuance due 7 days after Equipment Installation. C-2

33 TABLE C: COMPLIANCE SCHEDULE Facility Name: Van Hoven Co Inc Permit Number: /29/03 Subject Item: CE 012 Continuous Cooker Scrubber Associated Items: EU 012 Continuous Cooker No. 1 EU 013 Continuous Cooker No. 2 GP 003 Continuous Cookers Citation Title I Condition: Monitoring to demonstrate compliance with limit to avoid major modification classification under 40 CFR Section and Minn Title I Condition: Monitoring to demonstrate compliance with limit to avoid major modification classification under 40 CFR Section and Minn Corrective Action Pressure Drop Monitoring Equipment Installation Notification When to complete the action due 120 days after Permit Issuance due 7 days after Equipment Installation. C-3

34 APPENDIX III FACILITY DESCRIPTION FORMS 1/15/03 Facility Name: Van Hoven Co Inc Permit Number: Under Minn. R , subp. 1(A), the Permittee may add insignificant activities to the stationary source throughout the term of the permit without getting permit amendments. Certain exclusions apply and are listed in Minn. R , subp. 2. In addition, this permit specifically prohibits the Permittee from making any modifications that would make the source major under NSR. The following sources at the Permittee s facility qualify as insignificant activities under Minn. R , subps. 2, 3 and 4 and are not required to be listed in the permit. Subject Item: Minn. R , subp. Insignificant Activities Rule Description of the Activity and Comments General Applicable Requirement 2(D)(3) Miscellaneous fabricating equipment such as drills, grinders, saws, etc. Minn. R (PM and opacity) 3(D)(2) Miscellaneous fabricating equipment such as drills, grinders, saws, etc. Minn. R (PM and opacity) 3(G), 4(B) and 4(C) Laboratory equipment Minn. R (PM and opacity) 3(H)(1) Miscellaneous Minn. R (PM and opacity) 3(H)(4) Brazing, soldering, and welding (equipment used for maintenance purposes only) Minn. R (PM and opacity) 3(H)(5) Blueprint and photographic process Minn. R (PM and opacity) 3(I) Individual emissions units at a stationary source, each of which have a potential to emit the following pollutants in amounts less than: Minn. R SO 2, and opacity) (PM, 1. 4,000 lbs/year of carbon monoxide; and 2. 2,000 lbs/year each of nitrogen oxide, sulfur dioxide, particulate matter, particulate matter less than ten microns, volatile organic compounds (including hazardous air pollutant-containing VOC), and ozone. or Van Hoven Company has several of these individual emissions units, the largest of which have had their emissions calculated by Van Hoven s consultant and MPCA staff. These are: Minn. R (PM and opacity) inside and outisde storage tanks; and kerosene portable hot water pressure washer. Subp. 3(J) Fugitive emissions from roads and parking lots Minn. R (PM and opacity) 4(A), (B) and (C) Individual emissions units at a stationary source, each of which have a potential to emit the following pollutants in amounts less than: A. potential emissions of 5.7 lbs/hr or actual emissions of two tons per year of carbon monoxide; B. potential emissions of 2.28 lbs/hr or actual emissions of one ton per year of nitrogen oxide, sulfur dioxide, particulate matter, particulate matter less than ten microns, or volatile organic compounds C. individual emissions units that have actual emissions of less than or equal to 1 ton per year of the criteria pollutants, and for hazardous air pollutants, emissions units with potential emissions of less than certain thresholds listed in Minn. R , subps. 4(C)(1) and (2). Van Hoven Company has several of these individual emissions units, the largest of which have had their emissions calculated by MPCA staff. These are: natural gas space and line heaters; and, vegetable oil recovery. Minn. R (PM, SO 2, and opacity)

35 APPENDIX III FACILITY DESCRIPTION FORMS 1/15/03 Facility Name: Van Hoven Co Inc Permit Number: The DELTA forms that follow constitute Appendix III.

36 TECHNICAL SUPPORT DOCUMENT for AIR EMISSION PERMIT NO This technical support document is for all the interested parties of the draft permit. The purpose of this document is to set forth the legal and factual basis for the draft permit conditions, including references to the applicable statutory or regulatory provisions. 1. General Information 1.1. Applicant and Stationary Source Location: Owner and Operator Address and Telephone Number Van Hoven Company Post Office Box 56 South Saint Paul, Minnesota (651) Facility Address (SIC Code: 2844) Van Hoven Company 505 Hardman Road South Saint Paul, Minnesota Description of the facility The Van Hoven Company recycles animal, vegetable, and food processing waste materials. The products manufactured from these recycled materials are primarily used by the animal feed manufacturing and chemical industries. The principle products processed at the Van Hoven Company manufacturing facility are: beef, poultry and pork by-products, animal and vegetable oils and a variety of other recycled waste materials from food processing, meat processing, and livestock industries. Other products processed are shown below in Figure 1. Figure 1 -- Van Hoven Company Manufacturing Products Van Hoven s animal waste recycling plant is composed of four distinctly separate operations: Permit Action Number: Date: 12/12/2003

37 animal matter recycling (rendering); blood processing; protein recovery facility (high protein meal production); and, vegetable oils and animal fats processing. These operations are described in the following paragraphs. In addition to two boilers, the emission units that are part of the above operations are the only emission sources at the facility that are addressed in this operating permit. All other emission units qualify as insignificant activities under Minn. R , subps. 2, 3 or a. Boilers Boiler No. 1 (EU 001), the main boiler, is a Nebraska boiler with rated heat input 51 million Btu per hour. It is capable of burning natural gas as the primary fuel, and No. 6 residual fuel oil or refined animal fats and vegetable oils (RAFVO) as backup. It was installed in Boiler No. 2 (EU 006) is a Johnston 509A boiler with maximum rated heat input million Btu per hour while fired with natural gas and million Btu per hour while fired with No. 2 distillate fuel oil. It was installed in b. Animal Waste Recycling (Rendering) Raw Material Receiving Raw materials are deposited in the receiving and handling area. Two grinding and pumping lines feed the continuous cooker operations. Equipment associated with the materia1 receiving and transfer includes conveyors, a grinder, an electromagnet and a surge bin. Cooking and Pressing In the steam heated continuous cooking vessels (EUs 012 and 013), water is evaporated and the temperature of the material is raised to approximately degrees F. Water vapor is routed to an air condenser. The cookers are unloaded into a perc-pan where the free fat is allowed to drain out through perforations. Cooked material is then transferred across a mechanical device to an area that separates fatty liquids from protein solids. Liquid fat is pumped across a screen where residual solids are removed. Liquid fat from the cooker and the presses are pumped through a new centrifuge where the last bits of solids are removed. The fat is pumped to storage tanks for loading into railroad cars or tanker trucks for delivery. Continuous Milling System The solids are transferred to a surge bin and from there to a continuous hammer milling system (EU 011) where the particle size is further reduced. Ground protein solids are conveyed across a screen and conditioner to meet specific customer requirements before being conveyed to storage silos. 1.2.c. Blood Processing Permit Action Number: Date: 12/12/2003

38 Blood is unloaded from tank trucks into storage tanks. The blood is coagulated with steam and centrifuged before it is conveyed into the blood/ring dryer (EU 002). The blood/ring dryer burns natural gas with No. 2 distillate fuel oil as a back-up, has a maximum rated heat input of 5.00 million Btu per hour while firing either fuel, and was installed in The dried blood meal is transferred using one of two conveyance systems to the finished product storage vessels (EUs 005 and 015) for shipment. 1.2.d. Protein Recovery Facility Raw materials for the protein recovery facility (EU 003) are delivered in vehicles designed for the purpose. The vehicles unload the raw materials into a receiving vessel or area designed for the materials. The high protein raw feed is conveyed through a magnetic separator and size reduction system into steam jacketed cookers where it remains until it reaches proper temperature. The material is conveyed to a dryer where final moisture reduction takes place before the material is milled, screened and transferred using a conveyance system (EU 014) to finished product storage vessels (EUs 009 and 010) for shipment. Water evaporated in the cooking process and drying vessels is condensed in a condenser. Condensate is sewered and noncondensible gases pass through a multi-stage system designed to oxidize the odors before release to the atmosphere. The receiving and process space are ventilated with a single stage system also designed to oxidize any odors before release to the atmosphere. Steam from one of the boilers is the heat source for the cooking and drying cycles. 1.2.e. Vegetable Oil Recovery Raw materials handling equipment consists of two 3,250-gallon mixing tanks in which the waste grease from area restaurants are heated to elevated temperatures for a period of 24 to 48 hours until the materials are properly homogenized. The impurities in the product are allowed to settle and are drawn from the bottom of the tank for further processing. The purified liquid is drawn from the top of the tank into storage tanks. During the raw material heating period, any gases vented from the tank are released into the room air and drawn through the room air scrubber. The vapor pressure of the raw material at elevated temperature remains low (0.001 mmhg at 480 degrees F and 0.05 mmhg at 585 degrees F), therefore MPCA staff anticipate very small amounts of volatile organic compound (VOC) emissions from this process and believe it qualifies as an insignificant activity under Minn. R , subp Description of any changes allowed with this permit issuance This permit authorizes the replacement of the continuous milling system s (EU 011) baghouse (CE 015) with a new centrifugal separator particulate capture unit (CE 016) as described in the application dated September 3, 2002 and in Section 3.2.h. of this TSD. 1.4 Permitting History Permit Action Number: Date: 12/12/2003

39 Table 1 -- Permitting History Permit Number and Issuance Date Action Authorized Total Facility Permit ( OT-2) August 3, 1990 Amendment No. 1 February 3, 1993 Amendment No. 2 September 20, 1993 Amendment No. 3 September 20, 1997 Amendment No. 4 December 18, 2000 Authorized operation of original batch recycling, blood process operations and associated air pollution control equipment. Authorized installation of raw material handling equipment. Authorized modifications to air pollution control equipment (scrubbers and packed towers) to optimize performance and clarify monitoring parameters for compliance determination. Difficult to know for sure what else was authorized, as the MPCA file only had the odd numbered pages of this permit. Authorized installation of protein recovery process (PRF), associated air pollution control equipment, and a boiler. Imposed limits on PM and PM10 to demonstrate modeled compliance with NAAQS. Authorized installation of a boiler, two continuous cookers, continuous milling system, storage silo and associated air pollution control equipment. Only the cookers, milling system and their control equipment were actually installed. Authorized ability to burn refined animal fats and vegetable oils (RAFVO) in boiler No. 1. Application was for a minor permit amendment. Amendment never actually issued Facility Emissions Emission Unit ID No. Table 2 -- Total Facility Potential to Emit Summary: Note: See Sections 3.2 and 3.3 of this TSD for more discussion of potential emissions. Emission Unit Description PM (tpy) PM10 (tpy) SOx (tpy) NOx (tpy) VOC (tpy) CO (tpy) Pb (tpy) Single HAP (tpy) All HAPs (tpy) EU 001 Boiler No x EU 002 Ring/Blood Dryer x 10-4 neg. neg. EU 003 Protein Recovery Facility EU 005 Blood Pneumatic Conveying System EU 006 Boiler No x 10-4 neg. neg. EU 009 Protein Silo No EU 010 Protein Silo No EU 011 Continuous Milling System GP 003 Continuous Cookers (EUs 012 and 013) Permit Action Number: Date: 12/12/

40 EU 014 Feather Pneumatic Conveying System Total Facility Limited Potential Emissions * x Total Facility Actual Emissions ** neg. neg. * These are the limited potential emissions from column 3 in GI-07 from DELTA. They differ from those in the permit application sent by the company in that they have been verified and corrected as needed by MPCA staff. ** These are the actual emissions that appeared in the facility s most current Emissions Inventory Report. Where, PM = Particulate Matter PM 10 = PM smaller than 10 microns SO 2 = Sulfur Dioxide NO x = Nitrogen Oxides CO = Carbon Monoxide VOCs = Volatile Organic Compounds HAPs = Hazardous Air Pollutants neg. = negligible Program (list pollutant) Table 3 -- Facility and Permit Classification Major/Affected Source Synthetic Minor * Minor * PSD SO2 and PM/PM10 VOC, NOx and CO NAAR NA NA NA Part 70 Permit Program Part 63 National Emissions Standards for Hazardous Air Pollutants SO2 and PM/PM10 NA NOx, VOC, SO2 and CO NA NA NA * Refers to potential emissions that are less than those specified as major by 40 CFR pt 52.21, 40 CFR pt. 51 Appendix S, 40 CFR pt. 63 and 40 CFR pt Regulatory and/or Statutory Basis 2.1 New Source Review Van Hoven is a synthetic minor source for New Source Review s Prevention of Significant Deterioration (PSD) requirements because limited potential SO2 emissions are less than 250 tons per year. Controlled PM/PM10 potential emissions are both less than 50 tons per year. 2.2 Federal New Source Performance Standards Boiler No. 2 (EU 006) is subject to New Source Performance Standards (NSPS) 40 CFR pt. 60, subp. Dc (Small Steam Generating Units) because it was installed after the NSPS s promulgation date and it burns distillate oil as a back-up fuel. The NSPS limits SO2, but not opacity as EU 006 s heat input is less than 30 million Btu/hr. Permit Action Number: Date: 12/12/2003

41 Table 4 -- Regulatory Overview of Facility Level * Applicable Regulations Comments: GP 001 (EUs 001, 002, and 006) Each unit except EU 011 through EU 014 EU 006 (Boiler No. 2) EUs 001 and 006 (Boilers Nos. 1 and 2) EUs 002 and 003 (Blood dryer and PRF) All EUs except EUs 001, 002, and CFR Prevention of Significant Deterioration (PSD). Limits taken on SO2 emissions to avoid major source classification under PSD. 40 CFR 52.21(d) and Minn. R Ambient Air Quality Standards. Limits for PM and/or PM10 set at the emission unit level. Limits derived from computer dispersion modeling. 40 CFR Part 60, subp Dc Federal Standards of Performance for Small Steam Generating Units Minn. R to Minn. R to Minn. R to State Standards of Performance for New Indirect Heating Equipment State Standards of Performance for Direct Heating Equipment State Standards of Performance for New and Existing Industrial Process Equipment * Level: EU = emission unit, GP = group, SV = stack/vent, CE = control equipment 3. Technical Information 3.1 PM10 Non-Attainment Area Minnesota's PM10 Non-Attainment area located in Saint Paul (see Attachment 1) was redesignated "Attainment" by the U.S. Environmental Protection Agency (EPA) effective on September 24, Van Hoven has many grinding, milling and drying processes, as well as several combustion units that emit PM and PM10. The company is located just outside the border of the PM10 Non-Attainment area. Van Hoven emissions were first modeled by MPCA staff in 1993 to evaluate whether the facility was contributing to PM10 non-attainment. Significant contributions to modeled non-attainment would require that the State Implementation Plan (SIP) for PM10 include an Administrative Order specifying control measures sufficient to attain and maintain the PM10 National Ambient Air Quality Standard (NAAQS) with a margin of safety. The dispersion modeling showed that the facility was not a significant contributor in the non-attainment area, although the company's emissions contributed to a modeled exceedance of the standard near their property boundary (outside the non-attainment area). For this reason, Van Hoven received a permit amendment in September 1993 imposing limits for PM and/or PM10 on several emission units to demonstrate modeled compliance with the NAAQS (see Attachment 2). Those limits were carried forward into this permit. The combustion units operate well below their modeled limits, and compliance with the modeled limits placed on process equipment can be demonstrated by the continued use of add-on control equipment. Van Hoven was included in dispersion modeling done by MPCA staff in 1998 to address a monitored violation in the PM10 non-attainment area (see Attachment 3). Considering the conditions imposed in their 1993 permit amendment, Van Hoven was not a contributing source to that violation. Permit Action Number: Date: 12/12/2003

42 3.2 Periodic Monitoring / Compliance Demonstration 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 violating the applicable requirement; whether add-on controls are necessary to meet the emission limit; 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; and the kind of monitoring found on similar units. The following section summarizes the periodic monitoring requirements for those emission units for which the monitoring required by the applicable requirement is nonexistent or inadequate. For the combustion sources, using AP-42 emission factors, the Permittee can demonstrate that uncontrolled emissions are below the emission limits, and the likelihood of violating any of the limits is very small. For the manufacturing processes, using a combination of conservative AP-42 emission factors and performance test data from the same processes at similar facilities; the Permittee can demonstrate that calculated predictions of controlled emissions are below the emission limits. Default control efficiencies from Minn. R were also used in the calculations instead of more accurate, up-to-date guarantees provided by the control equipment manufacturers. The permit requires that emissions be sent to the control equipment as a precautionary measure, so the likelihood of violating any of the emission limits is very small. 3.2.a. EU 001 (Boiler No. 1) Natural gas combustion uncontrolled emission factors were taken from AP-42, 5th Edition, U.S. EPA, January 1995 (Updated July 1998), "Natural Gas Combustion, Tables and 1.4-2, Pages and 1.4-6; residual and distillate fuel oil uncontrolled emission factors were taken from AP-42, 5th Edition, U.S. EPA, September 1998, "Fuel Oil Combustion", Tables 1.3-1, 1.3-3, and , Pages , , and ; refined animal fats and vegetable oils (RAFVO) uncontrolled emission factors were based on a combination of the residual and distillate fuel oil factors. The factors were also used for controlled emissions. Uncontrolled emissions of particulate matter (PM) while combusting the fuel that would generate the highest emissions were well below the limit in the Indirect Heating Equipment Rule (IDHER). Therefore, MPCA staff believe stack testing of EU 001 for particulate matter (PM) is not necessary to demonstrate compliance with that limit. Emissions (pounds per hour) PM Emissions for EU 001 (Boiler No. 1) Emission Limit (based on IDHER) Uncontrolled Controlled Comparison of Controlled/Uncontrolled Emissions with PM Limit Permit Action Number: Date: 12/12/2003

43 Uncontrolled emissions of particulate matter less than 10 microns (PM10) while combusting the fuel that would generate the highest emissions were below the limit set based on modeling to demonstrate compliance with the NAAQS. Therefore, MPCA staff believe stack testing of EU 001 for PM10 is not necessary to demonstrate compliance with the Title I Condition. Emissions (pounds per hour) PM10 Emissions for EU 001 (Boiler No. 1) Emission Limit (based on NAAQS modeling) Uncontrolled Controlled Comparison of Controlled/Uncontrolled Emissions with PM10 Limit Uncontrolled emissions of sulfur dioxide (SO2) while combusting the fuel that would generate the highest emissions were below the limit in the Indirect Heating Equipment Rule (IDHER). Therefore, MPCA staff believe stack testing of EU 001 for SO2 is not necessary to demonstrate compliance with that limit. Also, if the SO2 limit (in pounds per hour) in the IDHER were applied on an annual basis (in tons per year), EU 001 will remain below that amount because it is part of GP 001 in DELTA which is combustion equipment subject to a cap on SO2 emissions of 240 tons per year. Daily records will be kept for the amounts of all fuels combusted in GP 001 and monthly emissions calculations using Equation 1 in the permit is how the Permittee will demonstrate compliance with the emissions cap on SO2. SO2 Emissions for EU 001 (Boiler No. 1) SO2 Emissions for EU 001 (Boiler No. 1) Emissions (pounds per hour) Emission Limit (based on IDHER) Uncontrolled Controlled Emissions (tons per year) Emission Limit (based on IDHER) Uncontrolled Controlled (Limited) Comparison of Controlled/Uncontrolled Emissions with SO2 Limit Comparison of Controlled/Uncontrolled Emissions with SO2 Limit 3.2.b. EU 002 (Blood/Ring Dryer) Natural gas combustion uncontrolled emission factors were taken from AP-42, 5th Edition, U.S. EPA, January 1995 (Updated July 1998), "Natural Gas Combustion, Tables and 1.4-2, Pages and 1.4-6; and distillate fuel oil uncontrolled emission factors were taken from AP-42, 5th Edition, U.S. EPA, September 1998, "Fuel Oil Combustion", Tables 1.3-1, 1.3-3, and , Pages , , and The factors were also used to for controlled emissions. In addition to emissions from the combustion of natural gas and distillate fuel oil, MPCA staff also calculated PM emissions from the drying of the blood meal, assuming all filterable PM was PM10, and added the two together to get total PM/PM10 emissions from EU 002. Permit Action Number: Date: 12/12/2003

44 A thorough search of the MPCA s Performance Test Files on microfiche revealed that all past tests on blood dryers appeared to have been done only for odor. Since then the Minnesota Odor Rules (Minn. R ) have been repealed by the legislature, but MPCA staff were able to locate one test for a blood dryer showing 0.27 lb PM/PM10 per ton of blood dried. (See Attachment 4, Interpoll Laboratories Report, Farmland Foods, Iowa Falls, Iowa, January 1987). However, after reading the report, it was not clear what type of control equipment was attached to the dryer at that facility. AP-42 does not have many factors for emissions from rendering plants, likely since they are not known as substantial PM/PM10 or VOC sources. The only data available in AP-42 are for emissions from blood dryers, which is an auxiliary process in meat rendering (AP-42, 5th Edition, U.S. EPA, January 1995, "Controlled Blood Drying, Table , Page ). MPCA staff calculated PM/PM10 emissions from EU 002 using an emission factor for controlled blood dryers of 0.76 lb PM/PM10 per ton of blood dried. The dryer was controlled with a venturi scrubber and a packed tower and MPCA staff assumed that control equipment to be 90% efficient. Although three times more conservative than the test data from the Farmland Foods facility, MPCA believe it s use is reasonable when a rough estimate of emissions done by MPCA staff (see below) is within fifteen percent of the AP-42 factor: Into the dryer: 2,000 lb/hr blood at 60% moisture content (information from Van Hoven) Moisture: 1,200 lb/hr of water Blood: 800 lb/hr product (2000 x 0.60 = 1200 lb/hr) ( = 800 lb/hr) Out of the dryer and into a cyclone: 800 lb/hr blood at 10% moisture (information from Van Hoven) Moisture: 80 lb/hr of water Blood: 800 lb/hr product [( ) x 0.10 α ] = 88 lb/hr ( α Assume cyclone is 90% efficient) Out of cyclone and into high efficiency scrubber: (88 x 0.10 β ) = 8.8 lb/hr ( β Assume scrubber is 90% efficient) Out of high efficiency scrubber and into room air scrubber: (8.8 x 0.10 β ) = 0.88 lb PM/PM10 per ton of blood dried ( β Assume scrubber is 90% efficient) When air pollution control equipment is used in a facility s manufacturing process, it s effects can generally be considered when calculating the facility s potential emissions. This is typically true when the equipment is used to recover specific byproducts. After viewing the blood drying process during a facility visit and speaking with Van Hoven staff, MPCA believe that the Permit Action Number: Date: 12/12/2003

45 cyclone mentioned in the above calculations is used to capture material of value. Therefore, it can be considered an inherent part of the production process, rather than air pollution control equipment. Uncontrolled emissions of PM while operating at maximum capacity and combusting the fuel that would generate the highest emissions were below the limit set in the DHER. Therefore, MPCA staff believe stack testing of EU 002 for PM is not necessary to demonstrate compliance with that limit. The permit contains a requirement to operate, monitor and maintain the corresponding control equipment to ensure compliance with the limit as a precautionary measure. Predicted controlled emissions of PM10 while combusting the fuel that would generate the highest emissions were well below the limit set based on modeling to demonstrate compliance with the NAAQS. Therefore, MPCA staff believe stack testing of EU 002 for PM10 is not necessary to demonstrate compliance with that limit. The permit contains a requirement to operate, monitor and maintain the corresponding control equipment to ensure compliance with the Title I Condition. Emissions (pounds per hour) Emissions (pounds per hour) PM Emissions for EU 002 (Blood/Ring Dryer) 7.67 Uncontrolled Emission Limit (based on DHER) 0.83 Controlled Comparison of Controlled/Uncontrolled Emissions with PM Limit PM10 Emissions for EU 002 (Blood/Ring Dryer) 7.64 Emission Limit (based on NAAQS modeling) 0.80 Uncontrolled Controlled Comparison of Controlled/Uncontrolled Emissions with PM10 Limit Uncontrolled emissions of sulfur dioxide (SO2) while combusting the fuel that would generate the highest emissions were below the limit in the Direct Heating Equipment Rule (DHER). Therefore, MPCA staff believe stack testing of EU 002 for SO2 is not necessary to demonstrate compliance with that limit. EU 002 is part of GP 001 in DELTA which is combustion equipment subject to a cap on SO2 emissions of 240 tons per year. Daily records will be kept for the amounts of all fuels combusted in GP 001 and monthly emissions calculations using Equation 1 in the SO2 Emissions for EU 002 (Blood/Ring Dryer) permit is how the Permittee will demonstrate compliance with the emissions cap on SO c. EU 003 (Protein Recovery Facility) Emissions (pounds per hour) Emission Limit (based on DHER) Uncontrolled Controlled Comparison of Controlled/Uncontrolled Emissions with SO2 Limit Permit Action Number: Date: 12/12/2003

46 Calculations were provided for each process in the Protein Recovery Facility (PRF), which include: cooking, drying, milling and conveying. Calculations from the cookers and dryer do not include any pollutants from combustion because steam from one of the boilers is the heat source for the cooking and drying cycles. No emission factors specifically for protein recovery process cookers exist in AP-42, or other sources that MPCA staff were able to find. AP-42 does, however, have emission factors for a somewhat similar process: snack chip frying. Emissions from the cookers were calculated using factors taken from AP-42, 5th Edition, U.S. EPA, January 1995, "Snack Chip Deep Fat Frying, Tables and , Pages and MPCA staff used those emission factors as a worse-case estimate of emissions of VOCs and PM/PM10 from the cookers. No emission factors specifically for feather protein meal dryers exist in AP-42, or other sources that MPCA staff were able to find. MPCA staff were able to locate performance test data for a feather protein meal dryer showing 0.87 lb PM per ton of feathers processed. (See Attachment 4, Braun Intertec Report, Central Bi-Products, Redwood Falls, Minnesota, June 1995). MPCA staff used the highest value of the three one-hour runs as a worse-case estimate of PM/PM10 emissions from the dryer. The snack chip frying factor was used for VOC emissions. Emissions from the protein recovery facility s (PRF) milling/grinding processes were calculated using the highest of the milling factors taken from a similar process; grain elevators and processes (AP-42, 5th Edition, U.S. EPA, May 1998, "Grain Milling Controlled with Cyclone, Table , Page ). The milling/grinding processes at Van Hoven are controlled with a combination venturi scrubber and packed tower. It is likely that the air pollution control equipment in use at the facility is more efficient than the cyclone used in AP-42. MPCA staff therefore believe that it is conservative to use emission factors from a process controlled with a cyclone as a worse-case estimate of emissions from the PRF s milling/grinding operations. Emissions from the conveying system were calculated using factors taken from a similar process; concrete batching (AP-42, 5th Edition, U.S. EPA, September 2001, "Pneumatic Unloading of Cement to Elevated Storage Silo, Table , Page ). The particle size of the protein meal recovered is substantially larger than that of finely powdered cement. MPCA staff therefore believe that it is conservative to use emission factors from concrete batching as a worse-case estimate of emissions from the PRF s conveying system. Predicted controlled emissions of PM were below the limit set based on modeling to demonstrate PM Emissions for EU 003 compliance with the NAAQS. Therefore, (Protein Recovery Facility) MPCA staff believe stack testing of EU for PM is not necessary to demonstrate Emission Limit (based 8.00 compliance with that limit. The permit contains on NAAQS modeling) 6.00 a requirement to operate, monitor and maintain 4.00 the corresponding control equipment to ensure continued maintenance with Minnesota s Ambient Uncontrolled Controlled Air Quality Standard for PM. Predicted controlled emissions of PM10 were below the limit set based on modeling to PM10 Emissions for EU 003 Permit Action Number: Date: 12/12/2003 Emissions (pounds per hour) ons (pounds per hour) Comparison of Controlled/Uncontrolled Emissions with PM Limit (Protein Recovery Facility) 9.72 Emission Limit (based on NAAQS modeling)

47 demonstrate compliance with the NAAQS. Therefore, MPCA staff believe stack testing of EU 003 for PM10 is not necessary to demonstrate compliance with that limit. The permit contains a requirement to operate, monitor and maintain the corresponding control equipment to ensure compliance with the Title I Condition. 3.2.d. EU 005 (Blood Pneumatic Conveying Systems) Emissions from the dried blood conveying systems were also calculated using the concrete batching factors (AP-42, 5th Edition, U.S. EPA, September 2001, "Pneumatic Unloading of Cement to Elevated Storage Silo, Table , Page ). The particle size of the dried blood protein meal recovered is substantially larger than that of finely powdered cement. The conveying systems are controlled with fabric filter baghouses. The default control efficiency of 99 percent, as allowed by Minn. R , subp. 1, was used in the calculations for the conveying systems, although efficiencies of baghouses can be as high as 99.9 percent. MPCA staff therefore believe that it is conservative to use emission factors from concrete batching and the default control efficiency as a worse-case estimate of emissions from the blood pneumatic conveying systems. Predicted controlled emissions of PM were well below the limit in the Industrial Process Equipment Rule (IPER) and controlled emissions of and PM10 well below the limit set based on modeling to demonstrate compliance with the NAAQS. Therefore, MPCA staff believe stack testing of EU 005 for PM or PM10 is not necessary to demonstrate compliance with those limits. The permit contains a requirement to operate, monitor and maintain the corresponding control equipment to ensure compliance with the limits. PM Emissions for EUs 005 & 015 (Blood Conveying Systems) PM10 Emissions for EUs 005 & 015 (Blood Conveying Systems) Emissions (pounds per hour) Emission Limit (based on IPER) 0.01 Uncontrolled Controlled Emissions (pounds per hour) Uncontrolled Emission Limit (based on NAAQS modeling) Controlled Comparison of Controlled/Uncontrolled Emissions with PM Limit Comparison of Controlled/Uncontrolled Emissions with PM10 Limit 3.2.e. EU 014 (Feather Pneumatic Conveying Systems) Permit Action Number: Date: 12/12/2003

48 Emissions from the feather conveying system were calculated in a similar way the dried blood conveying systems were (i.e. concrete batching factors and a control efficiency of percent, instead of 99.00, because they will still be considerably under the limit). Again, MPCA staff believe that it is conservative to use emission factors from concrete batching and a 90 percent control efficiency as a worse-case estimate of emissions from the feather conveying system. Controlled emissions of PM were well below the limit in the Industrial Process Equipment Rule (IPER) Therefore, MPCA staff believe stack testing of EU 014 for PM is not necessary to demonstrate compliance with that limit. The permit contains a requirement to operate, monitor and maintain the corresponding control equipment to ensure compliance with the limit as a precautionary measure. Emissions (pounds per hour) PM Emissions for EU 014 (Feather Conveying System) 0.90 Uncontrolled Emission Limit (based on IPER) 0.09 Controlled Comparison of Controlled/Uncontrolled Emissions with PM Limit 3.2.f. EU 006 (Boiler No. 2) Natural gas combustion uncontrolled emission factors were taken from AP-42, 5th Edition, U.S. EPA, January 1995 (Updated July 1998), "Natural Gas Combustion, Tables and 1.4-2, Pages and 1.4-6; and distillate fuel oil uncontrolled emission factors were taken from AP-42, 5th Edition, U.S. EPA, September 1998, "Fuel Oil Combustion", Tables 1.3-1, 1.3-3, and , Pages , , and The factors were also used to for controlled emissions. Uncontrolled emissions of PM while combusting the fuel that would generate the highest emissions were well below the limit set based on modeling to demonstrate compliance with the NAAQS. Therefore, MPCA staff believe stack testing of EU 006 for PM was not necessary to ensure continued maintenance with Minnesota s Ambient Air Quality Standard for PM. Emissions (pounds per hour) PM Emissions for EU 006 (Boiler No. 2) Emission Limit (based on NAAQS modeling) 0.25 Uncontrolled 0.25 Controlled Comparison of Controlled/Uncontrolled Emissions with PM Limit Uncontrolled emissions of PM10 while combusting the fuel that would PM10 Emissions for EU 006 (Boiler No. 2) Permit Action Number: 3.00 Date: 12/12/2003 s (pounds per hour)

49 generate the highest emissions were well below the limit set based on modeling to demonstrate compliance with the NAAQS. Therefore, MPCA staff believe stack testing of EU 006 for PM10 is not necessary to demonstrate compliance with the Title I Condition. Federal New Source Performance Standards (NSPS) 40 CFR pt. 60, subp. Dc (Small Steam Generating Units) limits emissions of sulfur dioxide (SO2) from EU 006 to less than or equal to 0.5 pounds per million Btu while combusting distillate fuel oil. However, the NSPS alternatively gives the Permittee the option to obtain a certification from the fuel supplier that the fuel oil s sulfur content is less than or equal to 0.5 percent by weight to demonstrate compliance with the lb/mmbtu limit. Therefore, MPCA staff believe stack testing of EU 001 for SO2 is not necessary to demonstrate compliance with the NSPS limit. EU 006 is part of GP 001 in DELTA which is combustion equipment subject to a cap on SO2 emissions of 240 tons per year. Daily records will be kept for the amounts of all fuels combusted in GP 001 and monthly emissions calculations using Equation 1 in the permit is how the Permittee will demonstrate compliance with the facility wide emissions cap on SO g. EUs 009 and 010 (Protein Storage Silos) Emissions from the protein storage silos were calculated in the same way the dried blood and feather conveying systems were (i.e. concrete batching factors and the default control efficiency of 99.0 percent). Again, MPCA staff believe that it is conservative to use emission factors from concrete batching and the default control efficiency as a worse-case estimate of emissions from the feather conveying system. Predicted controlled emissions of PM were below the limit set based on modeling to demonstrate compliance with the NAAQS. Therefore, MPCA staff believe stack testing of EUs 009 and 010 for PM is not necessary to demonstrate compliance with that limit. The permit contains a requirement to operate, monitor and maintain the corresponding control equipment to ensure continued maintenance with Minnesota s Ambient Air Quality Standard for PM. Emissions (pounds per hour) PM Emissions for EUs 009 & 010 (Protein Storage Silos) Uncontrolled Emission Limit (based on NAAQS modeling) 0.07 Controlled Comparison of Controlled/Uncontrolled Emissions with PM Limit Predicted controlled emissions of PM were below the limit set based on modeling Permit Action Number: Date: 12/12/2003 pounds per hour) PM10 Emissions for EUs 009 & 010 (Protein Storage Silos) Emission Limit (based on NAAQS modeling)

50 to demonstrate compliance with the NAAQS. Therefore, MPCA staff believe stack testing of EU 014 for PM is not necessary to demonstrate compliance with that limit. The permit contains a requirement to operate, monitor and maintain the corresponding control equipment to ensure compliance with the Title I Condition. 3.2.h. EU 011 (Continuous Milling System) Emissions from the continuous milling system were calculated using the highest of the milling factors taken from a similar process; grain elevators and processes (AP-42, 5th Edition, U.S. EPA, May 1998, "Grain Milling Controlled with Baghouse, Table , Page ). A default control efficiency of 99 percent, as allowed by Minn. R , subp. 1, was used in the derivation of the emission factor for the continuous milling system. MPCA staff therefore believe that it is conservative to use an emission factor from a process controlled with a baghouse as a worse-case estimate of emissions from the continuous milling system. The continuous milling system was previously controlled with a fabric filter baghouse. However, as mentioned in Section 1.3 of this TSD, Van Hoven submitted an application dated September 3, 2002 asking that authorization of the replacement of the baghouse with a new centrifugal separator particulate capture unit (PCU) be included in this operating permit. The PCU (see Figure 2) was originally Figure 2 Particulate Capture Unit designed to handle fine, hot, oily product from coolers and dryers in the rendering industry. This is because cyclones and baghouses may not work satisfactorily to remove hot, fine, oily product with 10% to 17% fat content. In a drying operation, the PCU is able to handle very hot air in excess of 300 F without danger of baghouse fires or the oil residue that may make a baghouse inoperable on high fat product. The manufacturer also has applied the PCU to other separator applications. Since it can have up to a % removal efficiency of the particulate from the air, and is able to handle high fat products, it was chosen to replace the baghouse that previously controlled emissions from the continuous milling system. As the influent air stream enters the separation unit, it is directed through a centrifugal separator and then through a classifier plate to a blender section where water is added to capture any remaining particulate matter. MPCA staff assumed an removal efficiency of 90% in their calculations. As mentioned in Table 1 of this TSD, Amendment No. 3 to Van Hoven s existing total facility permit authorized the installation of a boiler, one continuous milling system, two continuous Permit Action Number: Date: 12/12/2003