AIR EMISSION PERMIT NO IS ISSUED TO. ConAgra Flour Milling Company P.O. Box 3500 Omaha, NE For

Transcription

1 AIR EMISSION PERMIT NO IS ISSUED TO ConAgra Flour Milling Company P.O. Box 3500 Omaha, NE For CONAGRA FLOUR MILLING COMPANY HASTINGS 2005 South Vermilion Street Hastings, Dakota County, MN The emission units, control equipment and emission stacks at the stationary source authorized in this permit are as described in the following permit application(s): Permit Type Application Date Total Facility Operating Permit 02/15/1996 Revised copy rec. 11/05/01 Major Amendment 07/28/2003 This permit authorizes the Permittee to operate and modify 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 as defined in the state air pollution control rules unless the term is explicitly defined in the permit. Permit Type: State; Limits to Avoid Pt 70/Limits to Avoid NSR Issue Date: December 9, 2002 Amendment Issuance: January 26, 2004 Expiration: Permit does not expire 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 Table C: Not used in this permit Appendix A: Not used in this permit Appendix B: Insignificant Activities Required to be Listed

3 NOTICE TO THE PERMITTEE: Your stationary source may be subject to the requirements of the Minnesota Pollution Control Agency s (MPCA) solid waste, hazardous waste, and water quality programs. If you wish to obtain information on these programs, including information on obtaining any required permits, please contact the MPCA general information number at: Metro Area (651) Outside Metro Area TTY (651) The rules governing these programs are contained in Minn. R. chs Written questions may be sent to: Minnesota Pollution Control Agency, 520 Lafayette Road North, St. Paul, Minnesota Questions about this air emission permit or about air quality requirements can also be directed to the telephone numbers and address listed above. PERMIT SHIELD: Subject to the limitations in Minn. R , compliance with the conditions of this permit shall be deemed compliance with the specific provision of the applicable requirement identified in the permit as the basis of each condition. Subject to the limitations of Minn. R and , subp. 2, notwithstanding the conditions of this permit specifying compliance practices for applicable requirements, any person (including the Permittee) may also use other credible evidence to establish compliance or noncompliance with applicable requirements. FACILITY DESCRIPTION: ConAgra Flour Milling Company operates a wheat flour and animal feed mill in Hastings, Minnesota. The facility consists of hardwheat mills, durum mills, durum processing, a rye mill, and associated elevator, storage, and packaging areas. Seventy-five percent of the wheat received is processed into flour and the remaining 25 percent into feed. The facility operates a boiler for heating and wheat tempering during the winter months. Methyl bromide is used for fumigation. In Permit -001, the facility accepted limits on the amount of wheat to be processed, and on the amount of fumigant (methyl bromide) which may be used. These limits were federally enforceable, and resulted in the facility being a non-major source under the Part 70 permit program, New Source Review, and the National Emission Standards for Hazardous Air Pollutants program.

4 AMENDMENT DESCRIPTION: This amendment removes all three Particulate Matter less than 10 microns (PM 10 ) process throughput limits. The process throughput limits are replaced by an overall facility wide 95 tons per year (tpy) PM 10 emission limit. The previous permit (-001) had a facility wide Potential to Emit PM 10 emission of 95 tpy. Hence, there is no change in the PM 10 Potential to Emit or other pollutant emissions.

5 Permit Number: Table A contains limits and other requirements with which your facility must comply. The limits are located in the first column of the table (What To do). The limits can be emission limits or operational limits. This column also contains the actions that you must take and the records you must keep to show that you are complying with the limits. The second column of Table A (Why to do it) lists the regulatory basis for these limits. Appendices included as conditions of your permit are listed in Table A under total facility requirements. Subject Item: Total Facility What to do FACILITY-SPECIFIC REQUIREMENTS Why to do it This permit establishes limits on the facility (including authorized modifications) to keep it a minor source under New Source Review. The Permittee may not make any change at the source that would make the source a major source under New Source Review until a permit amendment has been issued. This includes changes that might otherwise qualify as insignificant modifications and minor or moderate amendments. The Permittee shall not begin construction of any single project or projects that are connected or phased which will cause a total increase in actual emissions of greater than 99 tons per year for any criteria pollutant without first getting a permit amendment to authorize the project. Connected and phased have meanings as defined in Minn. R subps. 9b and 60. The Permittee shall not begin construction of any other project which is listed in Minn. R. 4410,4300 or Minn. R without first getting a permit amendment to authorize the project. Such projects may require the completion of an Environmental Assessment Worksheet or an Environmental Impact Statement prior to the amendment being issued. This is a state only requirement and is not federally enforceable. Recordkeeping -- Hours of Generator Operation: The Permittee shall maintain documentation on site that the generator listed as an insignificant activity in Appendix B of this permit is an emergency generator by design that qualifies under the U.S. EPA memorandum entitled "Calculating Potential to Emit (PTE) for Emergency Generators" dated September 6, 1995, limiting operation to 500 hours per year. PERFORMANCE TESTING Title I Condition: To avoid major source classification under 40 CFR Section and Minn. R Minn. R and Minn. R Minn. R , subp. 4 and 5 Performance Testing: Conduct all performance tests in accordance with Minn. R. ch unless otherwise noted in Tables A, B, and/or C. Limits set as a result of a performance test (conducted before or after permit issuance) apply until superseded as specified by Minn. R following formal review of a subsequent performance test on the same unit. REQUIREMENTS APPLICABLE TO ALL FACILITIES 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. 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. 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. 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. Minn. R. ch Minn. R Minn. R , subp. 14 and Minn. R , subp. 16(J) Minn. R , subp. 4(D) Minn. R , subp. 4(D) Minn. R Minn. R , subp. 3 A-1

6 Permit Number: 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. 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. 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. 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. 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 Application for Permit Amendment: If a permit amendment is needed, submit an application in accordance with the requirements of Minn. R through Minn. R Submittal dates vary, depending on the type of amendment needed. Extension Requests: The Permittee may apply for an Administrative Amendment to extend a deadline in a permit by no more than 120 days, provided the proposed deadline extension meets the requirements of Minn. R , subp. 1(H). 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. 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). 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. The Permittee shall comply with the General Conditions listed in Minn. R , subp. 16. Inspections: The Permittee shall comply with the inspection procedures and requirements as found in Minn. R , subp. 9(A). Emission Inventory Report: due 91 days after end of each calendar year following permit issuance (April 1). To be submitted on a form approved by the Commissioner. Minn. R , subp. 1 Minn. R , subp. 1 Minn. R , subp. 4 Minn. R , subp. 2; Minn. R , subp. 16(J) Minn. R Minn. R through Minn. R Minn. R , subp. 1(H) Minn. R , subp. 5(B) Minn. R , subp. 5(C) Minn. R Minn. R , subp. 16 Minn. R , subp. 9(A) Minn. R through Minn. R Emission Fees: due 60 days after receipt of an MPCA bill. Minn. R through Minn. R A-2

7 Permit Number: The Permittee is required to submit a Risk Management Plan (RMP) under the federal rule, 40 CFR pt. 68. Each owner or operator of a stationary source, at which a regulated substance is present above a threshold quantity in a process, shall design and implement an accidental release prevention program. A complete RMP must be submitted to the RMP Reporting Center, PO Box 3346, Merrifield, VA RMP submittal information may be obtained at or by calling These requirements must be complied with no later than the latest of the following dates: (1) June 21, 1999; (2) Three years after the date on which a regulated substance is first listed under 40 CFR Section ; or (3) The date on which a regulated substance is first present above a threshold quantity in a process. Particulate Matter < 10 micron: less than or equal to 95 tons/year using 365-day Rolling Sum Calculations: By the 15th day of each month, the Permittee shall record the process throughput for each of the four process weights, for each day, of the previous month and calculate each of the four 365-day rolling sum process weights for each day. The Permittee shall also calculate the 365-day rolling sum PM10 emissions for each day of the previous month. 40 CFR pt. 68 Title I Condition: To avoid major source classification under 40 CFR Section and Minn. R ; to avoid major source under 40 CFR Section 70.2 and Minn. R Title I Condition: To avoid major source classification under 40 CFR Section and Minn. R ; to avoid major source under 40 CFR Section 70.2 and Minn. R For each day, the 365-day rolling sum PM10 emissions are to be calculated using the following equation: E = (R * 6.95E-07) + (M * E-04) + (P * 4.5E-05) + (F * 8.32E-08) where: E = Facility - wide PM10 emissions as per 365-day (in tons/yr) R = Grain receiving process throughput weight (from EU 002), in tons M = Milling process throughput weight (from EU 004), in tons P = Pellet cooling process throughput weight (from EU 008), in tons F = Feed Loadout process throughput weight (from EU 005), in tons A-3

8 Permit Number: Subject Item: Associated Items: GP 001 Baghouses CE 001 Fabric Filter - Low Temperature, i.e., T<180 Degrees F CE 002 Fabric Filter - Low Temperature, i.e., T<180 Degrees F CE 003 Fabric Filter - Low Temperature, i.e., T<180 Degrees F CE 004 Fabric Filter - Low Temperature, i.e., T<180 Degrees F CE 005 Fabric Filter - Low Temperature, i.e., T<180 Degrees F CE 006 Fabric Filter - Low Temperature, i.e., T<180 Degrees F CE 007 Fabric Filter - Low Temperature, i.e., T<180 Degrees F CE 008 Fabric Filter - Low Temperature, i.e., T<180 Degrees F CE 009 Fabric Filter - Low Temperature, i.e., T<180 Degrees F CE 010 Fabric Filter - Low Temperature, i.e., T<180 Degrees F CE 011 Fabric Filter - Low Temperature, i.e., T<180 Degrees F CE 012 Fabric Filter - Low Temperature, i.e., T<180 Degrees F CE 013 Fabric Filter - Low Temperature, i.e., T<180 Degrees F CE 014 Fabric Filter - Low Temperature, i.e., T<180 Degrees F CE 015 Fabric Filter - Low Temperature, i.e., T<180 Degrees F CE 016 Fabric Filter - Low Temperature, i.e., T<180 Degrees F CE 017 Fabric Filter - Low Temperature, i.e., T<180 Degrees F CE 018 Fabric Filter - Low Temperature, i.e., T<180 Degrees F CE 019 Fabric Filter - Low Temperature, i.e., T<180 Degrees F CE 020 Fabric Filter - Low Temperature, i.e., T<180 Degrees F CE 021 Fabric Filter - Low Temperature, i.e., T<180 Degrees F CE 022 Fabric Filter - Low Temperature, i.e., T<180 Degrees F CE 023 Fabric Filter - Low Temperature, i.e., T<180 Degrees F CE 024 Fabric Filter - Low Temperature, i.e., T<180 Degrees F CE 025 Fabric Filter - Low Temperature, i.e., T<180 Degrees F CE 026 Fabric Filter - Low Temperature, i.e., T<180 Degrees F CE 027 Fabric Filter - Low Temperature, i.e., T<180 Degrees F CE 028 Fabric Filter - Low Temperature, i.e., T<180 Degrees F CE 029 Fabric Filter - Low Temperature, i.e., T<180 Degrees F CE 033 Fabric Filter - Low Temperature, i.e., T<180 Degrees F CE 034 Fabric Filter - Low Temperature, i.e., T<180 Degrees F CE 035 Fabric Filter - Low Temperature, i.e., T<180 Degrees F What to do The Permittee shall operate and maintain each fabric filter in accordance with the Operation and Maintenance (O & M) Plan. The Permittee shall keep copies of the O & M Plan available onsite for use by staff and MPCA staff. Visible Emissions: The Permittee shall check the exhaust stack of each fabric filter included in GP001 for any visible emissions once each day of operation during daylight hours. During inclement weather, the Permittee shall read and record the pressure drop across the fabric filter, once each day of operation. Pressure Drop: greater than or equal to 0.5 inches of water column and less than or equal to 8 inches of water column, unless a new range is set pursuant to Minn. R , subp. 3, based on the values recorded during the most recent MPCA approved performance test where compliance was demonstrated. Recordkeeping of Visible Emissions and Pressure Drop. The Permittee shall record the time and date of each visible emission inspection and pressure drop reading, and whether or not any visible emissions were observed, and whether or not the observed pressure drop was within the range specified in this permit. Why to do it Minn. R , subp. 2; MInn. R , subp. 4, 5, and 14 Minn. R , subp. 2; MInn. R , subp. 4, 5, and 14 Minn. R Minn. R , subp. 2; MInn. R , subp. 4, 5, and 14 A-4

9 Permit Number: 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. Corrective Actions: The Permittee shall take corrective action as soon as possible if any of the following occur: - visible emissions are observed; or - the recorded pressure drop is outside the required operating range; or - the fabric filter or any of its components are found during the inspections to need repair. Corrective actions shall eliminate visible emissions, and/or return the pressure drop to within the permitted range, and/or include completion of necessary repairs identified during the inspection, as applicable. Corrective actions include, but are not limited to, those outlined in the O & M Plan for the equipment. The Permittee shall keep a record of the type and date of any corrective action taken. Minn. R , subp. 2; MInn. R , subp. 4, 5, and 14 Minn. R , subp. 2; MInn. R , subp. 4, 5, and 14 A-5

10 Permit Number: Subject Item: Associated Items: GP 002 Cyclones CE 031 Centrifugal Collector - Medium Efficiency CE 032 Centrifugal Collector - Medium Efficiency What to do The Permittee shall operate and maintain each cyclone in accordance with the Operation and Maintenance (O & M) Plan. The Permittee shall keep copies of the O & M Plan available onsite for use by staff and MPCA staff. Pressure Drop: The Permittee shall read and record the pressure drop across the two cyclones listed in GP002, once each day of operation. Pressure Drop: greater than or equal to 4.0 inches of water column, unless a new minimum is set pursuant to Minn. R , subp. 3, based on the values recorded during the most recent MPCA approved performance test where compliance was demonstrated. Recordkeeping of Pressure Drop. The Permittee shall record the time and date of each pressure drop reading, and whether or not the observed pressure drop was within the range specified in this permit. 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. Corrective Actions: The Permittee shall take corrective action as soon as possible if any of the following occur: - the recorded pressure drop is outside the required operating range; or - the cyclone or any of its components are found during the inspections to need repair. Corrective actions shall return the pressure drop to within the permitted range and/or include completion of necessary repairs identified during the inspection, as applicable. Corrective actions include, but are not limited to, those outlined in the O & M Plan for the equipment. The Permittee shall keep a record of the type and date of any corrective action taken. Why to do it Minn. R , subp. 2; MInn. R , subp. 4, 5, and 14 Minn. R , subp. 2; MInn. R , subp. 4, 5, and 14 Minn. R Minn. R , subp. 2; MInn. R , subp. 4, 5, and 14 Minn. R , subp. 2; MInn. R , subp. 4, 5, and 14 Minn. R , subp. 2; MInn. R , subp. 4, 5, and 14 A-6

11 Permit Number: Subject Item: EU 001 Boiler Associated Items: SV 023 Boiler Exhaust What to do OPERATING AND RECORDKEEPING REQUIREMENTS Why to do it Fuel Use: Limited to natural gas and distillate oil only Minn. Stat , subd. 4a; Minn. R , subp. 2 Sulfur Content of Fuel: less than or equal to 0.5 percent by weight, based on certification from fuel supplier. Recordkeeping: For each shipment of fuel oil, the Permittee shall obtain and maintain a copy of the fuel supplier's certification, which shall include the name of the oil supplier, and a statement from the oil supplier that the oil complies with the specifications under the definition of distillate oil in 40 CFR Section 60.41c. Monthly Recordkeeping: Record and maintain records of the amounts of each fuel combusted on a monthly basis. These records may consist of purchase records or receipts. 40 CFR Section 60.42c(d); 40 CFR Section 60.42c(h)(1); Minn. R CFR Section 60.48c(f)(1); Minn. R CFR Section 60.13(i) and February 20, 1992, February 22, 1993, and June 25, 2002 EPA memoranda to meet the requirements of 40 CFR Section 60.48c(g) and (i); Minn. R A-7

12 Permit Number: Subject Item: EU 002 Grain Receiving Associated Items: CE 001 Fabric Filter - Low Temperature, i.e., T<180 Degrees F SV 001 Receiving Exhaust What to do EMISSION LIMITS AND OPERATING REQUIREMENTS Why to do it Opacity: less than or equal to 10 percent opacity from the stack Opacity: less than or equal to 5 percent opacity from fugitive emissions. Pre-Authorized Changes: The Permittee may modify, replace, or add emission units under the designation "EU002," provided grain receipts are tracked and calculated as specified in this permit, and all other permit conditions are met. Minn. R , subp. 3(D) Minn. R , subp. 3(A) Title I Condition: To avoid classification of equipment changes as modifications under 40 CFR Section If a proposed change triggers an applicable requirement that is not contained in this permit, the change must go through the appropriate procedures in Minn. R. ch Changes resulting in actual grain throughputs beyond what are allowed in this permit are not allowed under this provision. CONTROL EQUIPMENT REQUIREMENTS (CE001 - See GP001 for additional requirements) The Permittee shall operate and maintain the fabric filter at all times that any process equipment controlled by the fabric filter is operating. Total Particulate Matter: greater than or equal to 99 percent control efficiency Total Particulate Matter: greater than or equal to 80 percent control efficiency Particulate Matter < 10 micron: greater than or equal to 99 percent control efficiency MONITORING AND RECORDKEEPING REQUIREMENTS Labeling Requirement: The Permittee shall permanently affix the emission unit number (EU002) and another unique number to each piece of equipment designated as part of "Grain Receiving," for tracking purposes. Labeling must be completed within 120 days of permit issuance. The number can be affixed by placard, stencil, or other means, provided it is maintained and readable from a safe distance. If equipment is added, it shall be given a new number; numbers from replaced or removed equipment shall not be reused. Equipment List: The Permittee shall maintain a list of each piece of equipment designated under the "Grain Receiving" category. The list shall include: - the type of equipment - the emission unit number (EU002) and another unique identifier - the date of installation and/or modification. If equipment is added or modified after permit issuance, the Equipment List shall also note that the following two evaluations were made prior to the change: - the change does not trigger any applicable requirements that are not already listed in this permit - the change does cause violation of any limits listed in this permit. Daily Recordkeeping: Grain Receiving By the 15th day of each month, the Permittee shall record the grain receiving throughput quantity (weight), for each day, of the previous month. The Permittee shall also calculate the 365-day rolling sum of the grain receiving throughput for each day (in tons). The 365-day rolling sum is "R" for the purpose of the compliance equation under Subject Item: Total Facility. TESTING REQUIREMENTS Performance Test: due 365 days after Permit Issuance (Amendment -002) to measure opacity from fugitive emissions. Performance Test Notifications and Submittals: Performance Test Notification (written): due 30 days before each Performance Test Performance Test Plan: due 30 days before each Performance Test Performance Test Pre-Test Meeting: due 7 days before each Performance Test Performance Test Report: due 45 days after each Performance Test Performance Test Report - Microfiche Copy: due 105 days after each Performance Test. The Notification, Test Plan, and Test Report may be submitted in alternative format as allowed by Minn. R Minn. R , subp. 2(A) Minn. R , subp. 1(A) Minn. R , subp. 3(E) Minn. R , subp. 1(A) Title I Condition: Monitoring of equipment changes allowed while still avoiding major source classification under 40 CFR Section and Minn. R Minn. R , subp. 4 and subp. 5 Title I Condition: Monitoring of limit to avoid major source classification under 40 CFR Section and Minn. R ; monitoring of limit to avoid major source classification under 40 CFR Section 70.2 and Minn. R Minn. R , subp. 1 Minn. R , subps. 1-4; Minn. R ; and Minn. R , subps. 1-2 A-8

13 Permit Number: Subject Item: EU 003 Grain Cleaning Associated Items: CE 003 Fabric Filter - Low Temperature, i.e., T<180 Degrees F CE 004 Fabric Filter - Low Temperature, i.e., T<180 Degrees F CE 005 Fabric Filter - Low Temperature, i.e., T<180 Degrees F CE 006 Fabric Filter - Low Temperature, i.e., T<180 Degrees F CE 007 Fabric Filter - Low Temperature, i.e., T<180 Degrees F CE 008 Fabric Filter - Low Temperature, i.e., T<180 Degrees F CE 009 Fabric Filter - Low Temperature, i.e., T<180 Degrees F CE 010 Fabric Filter - Low Temperature, i.e., T<180 Degrees F CE 035 Fabric Filter - Low Temperature, i.e., T<180 Degrees F SV 003 Cleaning Exhaust SV 004 Cleaning Exhaust SV 005 Cleaning Exhaust SV 006 Cleaning Exhaust SV 007 Cleaning Exhaust SV 008 Cleaning Exhaust SV 009 Cleaning Exhaust SV 010 Cleaning Exhaust SV 013 Cleaning Exhaust What to do EMISSION LIMITS AND OPERATING REQUIREMENTS Why to do it Opacity: less than or equal to 10 percent opacity from each stack Opacity: less than or equal to 5 percent opacity from fugitive emissions. Pre-Authorized Changes: The Permittee may modify, replace, or add emission units under the designation "EU003," provided grain receipts are tracked and calculated as specified in this permit, and all other permit conditions are met. Minn. R , subp. 3(D) Minn. R , subp. 3(A) Title I Condition: To avoid classification of equipment changes as modifications under 40 CFR Section If a proposed change triggers an applicable requirement that is not contained in this permit, the change must go through the appropriate procedures in Minn. R. ch Changes resulting in actual grain throughputs beyond what are allowed in this permit are not allowed under this provision. CONTROL EQUIPMENT REQUIREMENTS (CE003 - CE010, CE035; See GP001 for additional requirements) The Permittee shall operate and maintain each fabric filter at all times that any process equipment controlled by the fabric filter is operating. Total Particulate Matter: greater than or equal to 99 percent control efficiency Total Particulate Matter: greater than or equal to 80 percent control efficiency Particulate Matter < 10 micron: greater than or equal to 99 percent control efficiency MONITORING AND RECORDKEEPING REQUIREMENTS Labeling Requirement: The Permittee shall permanently affix the emission unit number (EU003) and another unique number to each piece of equipment designated as part of "Grain Cleaning," for tracking purposes. Labeling must be completed within 120 days of permit issuance. The number can be affixed by placard, stencil, or other means, provided it is maintained and readable from a safe distance. If equipment is added, it shall be given a new number; numbers from replaced or removed equipment shall not be reused. Minn. R , subp. 2(A) Minn. R , subp. 1(A) Minn. R , subp. 3(E) Minn. R , subp. 1(A) Title I Condition: Monitoring of equipment changes allowed while still avoiding major source classification under 40 CFR Section and Minn. R A-9

14 Permit Number: Equipment List: The Permittee shall maintain a list of each piece of equipment designated under the "Grain Cleaning" category. The list shall include: - the type of equipment - the emission unit number (EU003) and another unique identifier - the date of installation and/or modification. Minn. R , subp. 4 and subp. 5 If equipment is added or modified after permit issuance, the Equipment List shall also note that the following two evaluations were made prior to the change: - the change does not trigger any applicable requirements that are not already listed in this permit - the change does cause violation of any limits listed in this permit. A-10

15 Permit Number: Subject Item: EU 004 Milling Associated Items: CE 011 Fabric Filter - Low Temperature, i.e., T<180 Degrees F CE 012 Fabric Filter - Low Temperature, i.e., T<180 Degrees F CE 013 Fabric Filter - Low Temperature, i.e., T<180 Degrees F CE 014 Fabric Filter - Low Temperature, i.e., T<180 Degrees F CE 015 Fabric Filter - Low Temperature, i.e., T<180 Degrees F CE 016 Fabric Filter - Low Temperature, i.e., T<180 Degrees F CE 017 Fabric Filter - Low Temperature, i.e., T<180 Degrees F CE 018 Fabric Filter - Low Temperature, i.e., T<180 Degrees F CE 019 Fabric Filter - Low Temperature, i.e., T<180 Degrees F CE 020 Fabric Filter - Low Temperature, i.e., T<180 Degrees F CE 021 Fabric Filter - Low Temperature, i.e., T<180 Degrees F CE 022 Fabric Filter - Low Temperature, i.e., T<180 Degrees F CE 023 Fabric Filter - Low Temperature, i.e., T<180 Degrees F CE 024 Fabric Filter - Low Temperature, i.e., T<180 Degrees F CE 025 Fabric Filter - Low Temperature, i.e., T<180 Degrees F SV 011 Milling Exhaust SV 012 Milling Exhaust SV 015 Milling Exhaust What to do EMISSION LIMITS AND OPERATING REQUIREMENTS Why to do it Opacity: less than or equal to 10 percent opacity from each stack Pre-Authorized Changes: The Permittee may modify, replace, or add emission units under the designation "EU004," provided grain receipts are tracked and calculated as specified in this permit, and all other permit conditions are met. Minn. R , subp. 3(D) Title I Condition: To avoid classification of equipment changes as modifications under 40 CFR Section If a proposed change triggers an applicable requirement that is not contained in this permit, the change must go through the appropriate procedures in Minn. R. ch Changes resulting in actual grain throughputs beyond what are allowed in this permit are not allowed under this provision. CONTROL EQUIPMENT REQUIREMENTS (CE011 - CE025; See GP001 for additional requirements) The Permittee shall operate and maintain each fabric filter at all times that any process equipment controlled by the fabric filter is operating. Total Particulate Matter: greater than or equal to 99 percent control efficiency Total Particulate Matter: greater than or equal to 80 percent control efficiency Particulate Matter < 10 micron: greater than or equal to 99 percent control efficiency MONITORING AND RECORDKEEPING REQUIREMENTS Labeling Requirement: The Permittee shall permanently affix the emission unit number (EU004) and another unique number to each piece of equipment designated as part of "Milling," for tracking purposes. Labeling must be completed within 120 days of permit issuance. The number can be affixed by placard, stencil, or other means, provided it is maintained and readable from a safe distance. If equipment is added, it shall be given a new number; numbers from replaced or removed equipment shall not be reused. Minn. R , subp. 2(A) Minn. R , subp. 1(A) Minn. R , subp. 3(E) Minn. R , subp. 1(A) Title I Condition: Monitoring of equipment changes allowed while still avoiding major source classification under 40 CFR Section and Minn. R A-11

16 Permit Number: Equipment List: The Permittee shall maintain a list of each piece of equipment designated under the "Milling" category. The list shall include: - the type of equipment - the emission unit number (EU004) and another unique identifier - the date of installation and/or modification. If equipment is added or modified after permit issuance, the Equipment List shall also note that the following two evaluations were made prior to the change: - the change does not trigger any applicable requirements that are not already listed in this permit - the change does cause violation of any limits listed in this permit. Daily Recordkeeping: Milling By the 15th day of each month, the Permittee shall record the milling throughput quantity (weight), for each day, of the previous month. The Permittee shall also calculate the 365-day rolling sum of the milling throughput for each day (in tons). The 365-day rolling sum is "M" for the purpose of the compliance equation under Subject Item: Total Facility. Minn. R , subp. 4 and subp. 5 Title I Condition: Monitoring of limit to avoid major source classification under 40 CFR Section and Minn. R ; monitoring of limit to avoid major source classification under 40 CFR Section 70.2 and Minn. R A-12

17 Permit Number: Subject Item: EU 005 Feed Loadout Associated Items: CE 030 Fabric Filter - Low Temperature, i.e., T<180 Degrees F SV 016 Feed Loadout What to do EMISSION LIMITS AND OPERATING REQUIREMENTS Why to do it Opacity: less than or equal to 5 percent opacity from fugitive emissions from railcar loading. Opacity: less than or equal to 10 percent opacity from fugitive emissions from truck loading. Opacity: less than or equal to 10 percent opacity from the stack Pre-Authorized Changes: The Permittee may modify, replace, or add emission units under the designation "EU005," provided grain receipts are tracked and calculated as specified in this permit, and all other permit conditions are met. Minn. R , subp. 3(A) Minn. R , subp. 3(B) Minn. R , subp. 3(D) Title I Condition: To avoid classification of equipment changes as modifications under 40 CFR Section If a proposed change triggers an applicable requirement that is not contained in this permit, the change must go through the appropriate procedures in Minn. R. ch Changes resulting in actual grain throughputs beyond what are allowed in this permit are not allowed under this provision. CONTROL EQUIPMENT REQUIREMENTS (See requirements under CE030) MONITORING AND RECORDKEEPING REQUIREMENTS Labeling Requirement: The Permittee shall permanently affix the emission unit number (EU005) and another unique number to each piece of equipment designated as part of "Feed Loadout," for tracking purposes. Labeling must be completed within 120 days of permit issuance. The number can be affixed by placard, stencil, or other means, provided it is maintained and readable from a safe distance. If equipment is added, it shall be given a new number; numbers from replaced or removed equipment shall not be reused. Equipment List: The Permittee shall maintain a list of each piece of equipment designated under the "Feed Loadout" category. The list shall include: - the type of equipment - the emission unit number (EU005) and another unique identifier - the date of installation and/or modification. If equipment is added or modified after permit issuance, the Equipment List shall also note that the following two evaluations were made prior to the change: - the change does not trigger any applicable requirements that are not already listed in this permit - the change does cause violation of any limits listed in this permit. Daily Recordkeeping: Feed Loadout By the 15th day of each month, the Permittee shall record the feed loadout throughput quantity (weight), for each day, of the previous month. The Permittee shall also calculate the 365-day rolling sum of the feed loadout throughput for each day (in tons). The 365-day rolling sum is "F" for the purpose of the compliance equation under Subject Item: Total Facility. TESTING REQUIREMENTS Performance Test: due 365 days after Permit Issuance (Amendment -002) to measure opacity from fugitive emissions. Performance Test Notifications and Submittals: Performance Test Notification (written): due 30 days before each Performance Test Performance Test Plan: due 30 days before each Performance Test Performance Test Pre-Test Meeting: due 7 days before each Performance Test Performance Test Report: due 45 days after each Performance Test Performance Test Report - Microfiche Copy: due 105 days after each Performance Test. The Notification, Test Plan, and Test Report may be submitted in alternative format as allowed by Minn. R Title I Condition: Monitoring of equipment changes allowed while still avoiding major source classification under 40 CFR Section and Minn. R Minn. R , subp. 4 and subp. 5 Title I Condition: Monitoring of limit to avoid major source classification under 40 CFR Section and Minn. R ; monitoring of limit to avoid major source classification under 40 CFR Section 70.2 and Minn. R Minn. R , subp. 1 Minn. R , subps. 1-4; Minn. R ; and Minn. R , subps. 1-2 A-13

18 Permit Number: Subject Item: EU 006 Grain Handling Associated Items: CE 002 Fabric Filter - Low Temperature, i.e., T<180 Degrees F SV 002 Grain Handling Exhaust What to do EMISSION LIMITS AND OPERATING REQUIREMENTS Why to do it Opacity: less than or equal to 10 percent opacity from the stack Opacity: less than or equal to 5 percent opacity from fugitive emissions. Pre-Authorized Changes: The Permittee may modify, replace, or add emission units under the designation "EU006," provided grain receipts are tracked and calculated as specified in this permit, and all other permit conditions are met. Minn. R , subp. 3(D) Minn. R , subp. 3(A) Title I Condition: To avoid classification of equipment changes as modifications under 40 CFR Section If a proposed change triggers an applicable requirement that is not contained in this permit, the change must go through the appropriate procedures in Minn. R. ch Changes resulting in actual grain throughputs beyond what are allowed in this permit are not allowed under this provision. CONTROL EQUIPMENT REQUIREMENTS (CE002; See GP001 for additional requirements) The Permittee shall operate and maintain the fabric filter at all times that any process equipment controlled by the fabric filter is operating. Total Particulate Matter: greater than or equal to 99 percent control efficiency Total Particulate Matter: greater than or equal to 80 percent collection efficiency Particulate Matter < 10 micron: greater than or equal to 99 percent control efficiency MONITORING AND RECORDKEEPING REQUIREMENTS Labeling Requirement: The Permittee shall permanently affix the emission unit number (EU006) and another unique number to each piece of equipment designated as part of "Grain Handling," for tracking purposes. Labeling must be completed within 120 days of permit issuance. The number can be affixed by placard, stencil, or other means, provided it is maintained and readable from a safe distance. If equipment is added, it shall be given a new number; numbers from replaced or removed equipment shall not be reused. Equipment List: The Permittee shall maintain a list of each piece of equipment designated under the "Grain Handling" category. The list shall include: - the type of equipment - the emission unit number (EU006) and another unique identifier - the date of installation and/or modification. Minn. R , subp. 2(A) Minn. R , subp. 1(A) Minn. R , subp. 3(E) Minn. R , subp. 1(A) Title I Condition: Monitoring of equipment changes allowed while still avoiding major source classification under 40 CFR Section and Minn. R Minn. R , subp. 4 and subp. 5 If equipment is added or modified after permit issuance, the Equipment List shall also note that the following two evaluations were made prior to the change: - the change does not trigger any applicable requirements that are not already listed in this permit - the change does cause violation of any limits listed in this permit. A-14

19 Permit Number: Subject Item: EU 007 Flour Storage and Loading Associated Items: CE 026 Fabric Filter - Low Temperature, i.e., T<180 Degrees F CE 027 Fabric Filter - Low Temperature, i.e., T<180 Degrees F CE 028 Fabric Filter - Low Temperature, i.e., T<180 Degrees F CE 029 Fabric Filter - Low Temperature, i.e., T<180 Degrees F CE 033 Fabric Filter - Low Temperature, i.e., T<180 Degrees F CE 034 Fabric Filter - Low Temperature, i.e., T<180 Degrees F SV 017 Storage/Loadout Exhaust SV 018 Storage/Loadout Exhaust SV 019 Storage/Loadout Exhaust SV 020 Storage/Loadout Exhaust SV 021 Storage/Loadout Exhaust SV 022 Storage/Loadout Exhaust What to do EMISSION LIMITS AND OPERATING REQUIREMENTS Why to do it Opacity: less than or equal to 5 percent opacity from fugitive emissions from railcar loading. Opacity: less than or equal to 10 percent opacity from fugitive emissions from truck loading. Opacity: less than or equal to 10 percent opacity from each stack Pre-Authorized Changes: The Permittee may modify, replace, or add emission units under the designation "EU007," provided grain receipts are tracked and calculated as specified in this permit, and all other permit conditions are met. Minn. R , subp. 3(A) Minn. R , subp. 3(B) Minn. R , subp. 3(D) Title I Condition: To avoid classification of equipment changes as modifications under 40 CFR Section If a proposed change triggers an applicable requirement that is not contained in this permit, the change must go through the appropriate procedures in Minn. R. ch Changes resulting in actual grain throughputs beyond what are allowed in this permit are not allowed under this provision. CONTROL EQUIPMENT REQUIREMENTS (CE026 - CE029, CE033, CE034; See GP001 for additional requirements) The Permittee shall operate and maintain each fabric filter at all times that any process equipment controlled by the fabric filter is operating. Total Particulate Matter: greater than or equal to 99 percent control efficiency Total Particulate Matter: greater than or equal to 80 percent control efficiency Particulate Matter < 10 micron: greater than or equal to 99 percent control efficiency MONITORING AND RECORDKEEPING REQUIREMENTS Labeling Requirement: The Permittee shall permanently affix the emission unit number (EU007) and another unique number to each piece of equipment designated as part of "Flour Storage and Loading," for tracking purposes. Labeling must be completed within 120 days of permit issuance. The number can be affixed by placard, stencil, or other means, provided it is maintained and readable from a safe distance. If equipment is added, it shall be given a new number; numbers from replaced or removed equipment shall not be reused. Equipment List: The Permittee shall maintain a list of each piece of equipment designated under the "Flour Storage and Loading" category. The list shall include: - the type of equipment - the emission unit number (EU007) and another unique identifier - the date of installation and/or modification. Minn. R , subp. 2(A) Minn. R , subp. 1(A) Minn. R , subp. 3(E) Minn. R , subp. 1(A) Title I Condition: Monitoring of equipment changes allowed while still avoiding major source classification under 40 CFR Section and Minn. R Minn. R , subp. 4 and subp. 5 If equipment is added or modified after permit issuance, the Equipment List shall also note that the following two evaluations were made prior to the change: - the change does not trigger any applicable requirements that are not already listed in this permit - the change does cause violation of any limits listed in this permit. A-15

20 Permit Number: Subject Item: EU 008 Pellet Cooling Associated Items: CE 031 Centrifugal Collector - Medium Efficiency CE 032 Centrifugal Collector - Medium Efficiency SV 014 Pellet Cooling Exhaust What to do EMISSION LIMITS AND OPERATING REQUIREMENTS Why to do it Total Particulate Matter: less than or equal to 0.3 grains/dry standard cubic foot of exhaust gas unless required to further reduce emissions to comply with the less stringent limit of either Minn. R or Minn. R Opacity: less than or equal to 20 percent opacity Pre-Authorized Changes: The Permittee may modify, replace, or add emission units under the designation "EU008," provided grain receipts are tracked and calculated as specified in this permit, and all other permit conditions are met. Minn. R , subp. 1(A) Minn. R , subp. 1(B) Title I Condition: To avoid classification of equipment changes as modifications under 40 CFR Section If a proposed change triggers an applicable requirement that is not contained in this permit, the change must go through the appropriate procedures in Minn. R. ch Changes resulting in actual grain throughputs beyond what are allowed in this permit are not allowed under this provision. CONTROL EQUIPMENT REQUIREMENTS (CE031 & CE032; See GP002 for additional requirements) The Permittee shall operate and maintain each cyclone at all times that any process equipment controlled by the device is operating. Total Particulate Matter: greater than or equal to 50 percent control efficiency Particulate Matter < 10 micron: greater than or equal to 50 percent control efficiency MONITORING AND RECORDKEEPING REQUIREMENTS Labeling Requirement: The Permittee shall permanently affix the emission unit number (EU008) and another unique number to each piece of equipment designated as part of "Pellet Cooling," for tracking purposes. Labeling must be completed within 120 days of permit issuance. The number can be affixed by placard, stencil, or other means, provided it is maintained and readable from a safe distance. If equipment is added, it shall be given a new number; numbers from replaced or removed equipment shall not be reused. Equipment List: The Permittee shall maintain a list of each piece of equipment designated under the "Pellet Cooling" category. The list shall include: - the type of equipment - the emission unit number (EU008) and another unique identifier - the date of installation and/or modification. If equipment is added or modified after permit issuance, the Equipment List shall also note that the following two evaluations were made prior to the change: - the change does not trigger any applicable requirements that are not already listed in this permit - the change does cause violation of any limits listed in this permit. Daily Recordkeeping: Feed Pelletization By the 15th day of each month, the Permittee shall record the feed pelletization throughput quantity (weight), for each day, of the previous month. The Permittee shall also calculate the 365-day rolling sum of the feed pellization throughput for each day (in tons). The 365-day rolling sum is "P" for the purpose of the compliance equation under Subject Item: Total Facility. Minn. R , subp. 2(A) Minn. R , subp. 1(A) Minn. R , subp. 1(A) Title I Condition: Monitoring of equipment changes allowed while still avoiding major source classification under 40 CFR Section and Minn. R Minn. R , subp. 4 and subp. 5 Title I Condition: Monitoring of limit to avoid major source classification under 40 CFR Section and Minn. R ; monitoring of limit to avoid major source classification under 40 CFR Section 70.2 and Minn. R A-16