AIR EMISSION PERMIT NO. 12900014-002 IS ISSUED TO Southern

TDD (for hearing and speech impaired only): (612)282-5332 Printed on recycled paper containing at least 10% fibers from paper recycled by consumers

AIR EMISSION PERMIT NO. 12900014-002 IS ISSUED TO

Southern Minnesota Beet Sugar Cooperative

Southern Minnesota Beet Sugar Cooperative

East Highway 212 Renville, Renville County, Minnesota 56284

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 January 17, 1995 Minor Amendment February 26, 1996 Minor Amendment October 31, 1996 Major Amendment July 1, 1998 This permit authorizes the Permittee to modify and operate the stationary source at the address listed above unless otherwise noted in Table A. The permit action is a non-major modification under 40 CFR § 52.21 due to permit limitations. The Permittee must comply with all the conditions of the permit and with all general conditions listed in Minn. R. pt. 7007.0800, subp. 16, all standard permit requirements listed in 40 CFR § 70.6(a), which are incorporated by reference. Any changes or modifications to the stationary source must be performed in compliance with Minn. R. pts. 7007.1150 to 7007.1500. 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: Federal; synthetic minor modification under 40 CFR § 52.21 Issue Date: August 11, 1999 Expiration: Upon the reissuance of the next total facility permit All Title I Conditions do not expire.

Michael J. Sandusky Division Manager Air Quality Division For Karen A. Studders Commissioner Minnesota Pollution Control Agency TRW:yma

Permit No. 12900014-002 Page 2

TABLE OF CONTENTS

Notice to the Permittee

Permit Shield

Facility Description

Table A: Limits and Other Requirements

Table B: Submittals


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)296-6300 Outside Metro Area 1-800-657-3864 TTY (651)282-5332 The rules governing these programs are contained in Minn. R. chs. 7000-7105. Written questions may be sent to: Minnesota Pollution Control Agency, 520 Lafayette Road North, St. Paul, Minnesota 55155-4194. 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. 7007.1800, compliance with the conditions of this permit shall be deemed compliance with the specific provision of the applicable requirement identified in the permit as the basis of each condition. Any requirements which have been determined not to apply are listed in Table A of this permit. The permit shield, however does not apply to: Minn. R. ch. 7030 (Noise Pollution Control).


FACILITY DESCRIPTION: Southern Minnesota Beet Sugar Cooperative (SMBSC) processes sugar from sugar beets for use in many consumer food products. The facility was built in 1974. SMBSC has about 480 members and grows beets in an eleven county area around the plant. The cooperative employs roughly 250 year-round employees and 350 seasonal employees. The facility’s operation is split into periods of time referred to as campaigns. Harvest can begin as early as August and usually ends in November. The beet slicing campaign will generally run from September to March, while the juice processing campaign will generally run through June, and the molasses campaign will run through August. The major sources of air emissions at SMBSC as it exists today, can be divided into two categories: combustion sources and product handling sources. Combustion sources include three boilers, two pulp dryers, and two lime kilns. The largest boiler is controlled by an electrostatic precipitator (ESP), each pulp dryer is controlled by four parallel cyclones, and the lime kilns are uncontrolled (although the combustion gas is usually bubbled through the carbonators). Product handling sources include sugar handling and conveying equipment along with other product/raw material handling equipment. The majority of the product handling sources are controlled by baghouses, but two units are controlled by scrubbers. The major source of fugitive emissions at the facility is truck traffic. SMBSC is proposing a five-year capital improvements project that will expand processing capacity, enhance operational efficiency, and improve performance. A permit amendment application was received on July 1, 1998, and amended on July 7, 1998 and August 7, 1998. The project involves the replacement or modification of nearly every major unit operation at the facility. A summary of the project is included in Attachment 1 to the Technical Support Document for this permit. The project includes a number of modifications to air emission sources at the facility. Boilers two and three will be replaced by a new boiler four. The two direct-fired pulp dryers will be replaced by two steam pulp dryers. The replacement of a number of non-air emission units will increase sugar production and will debottleneck the processing plant and a number of product handling sources. A new wastewater treatment plant will also be built. One goal of the capital improvements project is to reduce SMBSC’s role as an odor and Hydrogen Sulfide (H2S) source. H2S monitoring will be a requirement in this permit to measure the H2S concentrations around the new plant. In addition, H2S modeling will be required, using available data and best engineering judgement to assess the potential H2S emissions.

TABLE A: LIMITS AND OTHER REQUIREMENTS 08/11/99

Southern Minnesota Beet Sugar Coop

12900014 - 002

Facility Name:

Permit Number:

Table A contains limits and other requirements with which your facility must comply. The limits are located in the first column ofthe table (What To do). The limits can be emission limits or operational limits. This column also contains the actions that you musttake 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 facilityrequirements.

Subject Item: Total Facility

What to do Why to do itProhibition on operation of the beet processing facility expansion covered by thispermit until all permits are issued:(a) The issuance of this permit is related to an expansion of PermitteeÆs beetprocessing facility as described in the permit amendment application. Other MPCApermits related to this expansion include: NPDES/SDS Permit MN0040665,Aboveground Storage Tank Permit #9582, Solid Waste Permit SW-282, and thesolid waste land application permit(s). Permittee may construct facilities as the lawallows and as permits are issued but, until all the permits listed above have beenissued by the MPCA, Permittee is prohibited from operating any portion or all of thefacilities and equipment included in the expansion of PermitteeÆs facility, unlessspecifically authorized by the Commissioner as provided in (b) below.

Minn. R. 7007.0800, subp. 2

Prohibition on operation of the beet processing facility expansion covered by thispermit until all permits are issued (continued):(b) Upon the PermitteeÆs written application and showing of good cause, theCommissioner may authorize the Permittee to operate all or a portion of thefacilities and equipment governed by this permit prior to issuance of all the permitslisted above. Economic considerations alone do not constitute good cause. Neitherthe voidance of this prohibition by issuance of all the permits nor a Commissionerdecision to relieve the Permittee of the prohibition shall require amendment of thispermit.

Minn. R. 7007.0800, subp. 2

Equipment Removal and/or Dismantlement: due before Initial Startup of EU 028.EU 002, EU 003, EU 004, and EU 005 must be removed or dismantled before thedate of initial startup of EU 028. In addition, all construction activities related to thismodification, as described in Attachment 1 to the Technical Support Document forthis permit, must be completed by December 31, 2002.

Title I Condition: To avoid classification as a majormodification under 40 CFR 52.21

Air Pollution Control Equipment: Operate all pollution control equipment wheneverthe corresponding process equipment and emission units are operated, unlessotherwise noted in Table A.

Minn. R. 7007.0800, subp. 2;Minn. R. 7007.0800, subp. 16(J)

Operation and Maintenance Plan: Retain at the stationary source an operation andmaintenance (O&M) plan for all air pollution control equipment. The plan shallinclude: the manufacturer's recommended operating ranges for parameters to bemonitored such as pressure drop across the system, liquid flow rate, liquid supplypressure, etc.; corrective action procedures to be followed to return the controlequipment to within the specified range(s); corrective action procedures to befollowed in the event of a malfunction or breakdown; a description of inspectionprocedures to be followed; and records kept to demonstrate plan implementation.

Minn. R. 7007.0800, subp. 14 andMinn. R. 7007.0800, subp. 16(J)

Fugitive Emissions: Do not cause or permit the handling, use, transporting, orstorage of any material in a manner which may allow avoidable amounts ofparticulate matter to become airborne. Comply with all other requirements listed inMinn. R. 7011.0150 and the Fugitive Control Plan for the facility.

Minn. R. 7011.0150

Operating and/or production limits will be placed on emission units based onoperating conditions during performance testing. Limits set as a result of aperformance test (conducted before or after permit issuance) apply until newoperating/production limits are set following formal review of a performance test asspecified by Minn. R. 7017.2025

Minn. R. 7017.2025

Performance Testing: Conduct all performance tests in accordance with Minn. R.ch. 7017 unless otherwise noted in Tables A, B, and/or C.

Minn. R. ch. 7017

Monitoring Equipment: Install or make needed repairs to monitoring equipmentwithin 60 days of issuance of the permit if monitoring equipment is not installed andoperational on the date the permit is issued.

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

Monitoring Equipment Calibration: Annually calibrate all required monitoringequipment (any requirements applying to continuous emission monitors are listedseparately in this permit).

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

Operation of Monitoring Equipment: Unless otherwise noted in Tables A, B, and/orC, monitoring a process or control equipment connected to that process is notnecessary during periods when the process is shutdown, or during checks of themonitoring systems, such as calibration checks and zero and span adjustments. Ifmonitoring records are required, they should reflect any such periods of processshutdown or checks of the monitoring system.

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

Circumvention: Do not install or use a device or means that conceals or dilutesemissions, which would otherwise violate a federal or state air pollution control rule,without reducing the total amount of pollutant emitted.

Minn. R. 7011.0020

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Facility Name:

Permit Number:

Shutdown Notifications: Notify the Commissioner at least 24 hours in advance of aplanned shutdown of any control equipment or process equipment if the shutdownwould cause any increase in the emissions of any regulated air pollutant. If theowner or operator does not have advance knowledge of the shutdown, notificationshall be made to the Commissioner as soon as possible after the shutdown.However, notification is not required in the circumstances outlined in Items A, Band C of Minn. R. 7019.1000, subp. 3.

At the time of notification, the owner or operator shall inform the Commissioner ofthe cause of the shutdown and the estimated duration. The owner or operator shallnotify the commissioner when the shutdown is over.

Minn. R. 7019.1000, subp. 3

Breakdown Notifications: Notify the Commissioner within 24 hours of a breakdownof more than one hour duration of any control equipment or process equipment ifthe breakdown causes any increase in the emissions of any regulated air pollutant.The 24-hour time period starts when the breakdown was discovered or reasonablyshould have been discovered by the owner or operator. However, notification is notrequired in the circumstances outlined in Items A, B and C of Minn. R. 7019.1000,subp. 2.

At the time of notification or as soon as possible thereafter, the owner or operatorshall inform the Commissioner of the cause of the breakdown and the estimatedduration. The owner or operator shall notify the Commissioner when thebreakdown is over.

Minn. R. 7019.1000, subp. 2

Notification of Deviations Endangering Human Health or the Environment: As soonas possible after discovery, notify the Commissioner or the state duty officer, eitherorally or by facsimile, of any deviation from permit conditions which could endangerhuman health or the environment.

Minn. R. 7019.1000, subp. 1

Notification of Deviations Endangering Human Health or the Environment Report:Within 2 working days of discovery, notify the Commissioner in writing of anydeviation from permit conditions which could endanger human health or theenvironment. 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 yetcorrected; and5. steps taken or planned to reduce, eliminate, and prevent reoccurrence of thedeviation.

Minn. R. 7019.1000, subp. 1

Application for Permit Amendment: If you need a permit amendment, submitapplication in accordance with the requirements of Minn. R. 7007.1150 throughMinn. R. 7007.1500. Submittal dates vary, depending on the type of amendmentneeded.

Minn. R. 7007.1150 through Minn. R. 7007.1500

Extension Requests: The Permittee may apply for an Administrative Amendmentto extend a deadline in a permit by no more than 120 days, provided the proposeddeadline extension meets the requirements of Minn. R. 7007.1400, subp. 1(H)

Minn. R. 7007.1400, subp. 1(H)

Record keeping: Maintain records describing any insignificant modifications (asrequired by Minn. R. 7007. 1250, subp. 3) or changes contravening permit terms(as required by Minn. R. 7007.1350 subp. 2), including records of the emissionsresulting from those changes.

Minn. R. 7007. 0800, subp. 5(B)

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 whichmust be retained at this location include all calibration and maintenance records, alloriginal strip-chart recordings for continuous monitoring instrumentation, and copiesof all reports required by the permit. Records must conform to the requirementslisted in Minn. R. 7007.0800, subp. 5(A).

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

Noise: The Permittee shall comply with the noise standards set forth in Minn. R.7030.0010 to 7030.0080 at all times during the operation of any emission units.This is a state only requirement and is not federally enforceable.

Minn. R. 7030.0010 - 7030.0080

The Permittee shall comply with the General Conditions listed in Minn. R.7007.0800, subp. 16

Minn. R. 7007.0800, subp. 16

Inspections: Upon presentation of credentials and other documents as may berequired by law, allow the Agency, or its representative, to enter the Permittee'spremises to have access to and copy any records required by this permit, to inspectat reasonable times (which include any time the source is operating) any facilities,equipment, practices or operations, and to sample or monitor any substances orparameters at any location.

Minn. R. 7007.0800, subp. 9(A)

Emission Fees: due 60 days after receipt of an MPCA bill. Minn. R. 7002.0005 through Minn. R. 7002.0095

HYDROGEN SULFIDE REQUIREMENTS hdr

Hydrogen Sulfide: emissions from the facility shall not cause or contribute to anambient concentration that is greater then 0.05 parts per million as a 1/2 houraverage not to be exceeded more than 2 times per year.

Minn. R. 7009.0080; Minn. R. 7007.0800, subp. 2

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Facility Name:

Permit Number:

Hydrogen Sulfide: emissions from the facility shall not cause or contribute to anambient concentration that is greater then 0.03 parts per million as a 1/2 houraverage not to be exceeded more than 2 times in any five consecutive days.

Minn. R. 7009.0080; Minn. R. 7007.0800, subp. 2

Hydrogen Sulfide Monitoring: A Monitoring Network for hydrogen sulfide must be inplace and operating before permit issuance. The monitoring network must beoperating at all times during the months of April through October. A HydrogenSulfide Monitoring Plan shall be approved by the South District Manager (or hisdesignee) before the Monitoring Network can be constructed. The Plan shallinclude a description of the monitors, their locations, and the quality assurancerequirements for the monitors and their data.

Minn. R. 7007.0800, subp. 4

Hydrogen Sulfide Monitoring Corrective Actions: The operation of the monitorsshall be checked, and the data downloaded, weekly. If the data show anexceedance of the hydrogen sulfide standard the Permittee shall:

1) notify the South District Major Facilities Unit Supervisor at (651) XXX-XXXX nolater than 24 hours after the exceedance is discovered;

2) immediately implement the monitoring requirements for stations WS015 throughWS027 of National Pollutant Discharge Elimination System (NPDES)/StateDisposal System (SDS) Permit MN0040665, at a monitoring frequency of twice perweek and a duration to be determined by the South District Major Facilities UnitSupervisor; OR explain in 1) why the monitoring will not be immediatelyimplemented;

Minn. R. 7007.0800, subp. 2

Hydrogen Sulfide Monitoring Corrective Actions (continued):

3) within 7 days after the exceedance is discovered submit a written report to theSouth District Major Facilities Unit Supervisor that: identifies the reason for theelevated levels, evaluates and addresses whether or not the hydrogen sulfideemissions are expected to increase, and recommends whether corrective actionsare necessary and a schedule for their implementation.

The South District Major Facilities Unit Supervisor will evaluate the informationcontained in the report and notify the Permittee if the corrective actions identifiedmust be implemented.

Minn. R. 7007.0800, subp. 2

Hydrogen Sulfide Modeling: Modeling Results for hydrogen sulfide must beapproved by the South District Manager (or his designee) by December 1, 1999. Inaddition, a Revised Modeling Protocol shall be submitted to the South DistrictManager (or his designee) for approval before August 1, 1999. The RevisedModeling Protocol shall specify the general modeling approach, and the specificsteps used to predict the ambient concentration of hydrogen sulfide under worstcase conditions. The Modeling Results shall also include the corrective actionsthat will be implemented should an exceedence of the standard be modeled,including: the steps that will be taken, and the timelines to implement these stepsand report on their progress.

Minn. R. 7007.0800, subp. 2

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12900014 - 002

Facility Name:

Permit Number:

Subject Item: GP 001 Insignificant Particulate Sources

Associated Items: EU 012 Sugar Conveying/Silo Penthouse Dust Control

EU 016 Lime Rock Classifier

EU 017 Bulk Soda Ash Conveying System

EU 018 Chemical Feed Station Dust Control Systems

EU 019 Ash Conveying System

EU 020 Weibull Bin Dust Control System

EU 021 Pellet Conveying System

EU 022 Sugar Screening & Bagging Dust Control System

EU 024 Bulk Sugar Control Vacuum System

EU 026 Lime Dispensing Dust Collector

What to do Why to do itTotal Particulate Matter: less than or equal to 0.3 grains/dry standard cubic foot ofexhaust gas unless required to further reduce emissions to meet the less stringentlimit of either Minn. R. 7011.0730 or Minn. R. 7011. 0735 (applies individually toeach emission unit listed under Associated Items).

Minn. R. 7011.0715, subp. 1(A)

Opacity: less than or equal to 20 percent opacity (applies individually to eachemission unit listed under Associated Items).

Minn. R. 7011.0715, subp. 1(B)

Monitoring of Pollution Control Equipment: Operation and maintenance proceduresfor each piece of pollution control equipment associated with the emission unitslisted in GP 001 (i.e. CE 016, CE 017, CE 018, CE 019, CE 020, CE 021, CE 023,CE 024) shall be covered under the facility operation and maintenance plan.

Minn. R. 7007.0800, subp. 2

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12900014 - 002

Facility Name:

Permit Number:

Subject Item: GP 002 Lime production and use

Associated Items: EU 013 Lime Kiln A

EU 014 Lime Kiln B

EU 015 Lime Slaker

What to do Why to do itEMISSION LIMITS hdr

Total Particulate Matter: less than or equal to 0.3 grains/dry standard cubic foot ofexhaust gas unless required to further reduce emissions to meet the less stringentlimit of either Minn. R. 7011.0730 or Minn. R. 7011.0735. This limit appliesindividually to EU 013 and EU 014.

Minn. R. 7011.0610, subp. 1(A)(1)

Opacity: less than or equal to 20 percent opacity except for one six-minute periodper hour of not more than 60 percent opacity. This limit applies individually to EU013 and EU 014.

Minn. R. 7011.0610, subp. 1(A)(2)

Sulfur Dioxide: less than or equal to 4.0 lbs/million Btu heat input for solid fossilfuels. This limit applies individually to EU 013 and EU 014.

Minn. R. 7011.0610, subp. 2(B)

OPERATIONAL LIMITS hdr

Material Usage: less than or equal to 115344 tons/year using 12-month RollingSum for limestone

Title I Condition: Limit to avoid classification as a majormodification under 40 CFR Section 52.21

Material Usage: less than or equal to 8572 tons/year using 12-month Rolling Sumfor coke

Title I Condition: Limit to avoid classification as a majormodification under 40 CFR Section 52.21

Sulfur Content of Fuel: less than or equal to 1 percent by weight for coke Title I Condition: Limit to avoid classification as a majormodification under 40 CFR Section 52.21

Fuels Allowed: industrial oven coke as the main fuel source. Natural gas, propaneand/or wood as fuels for initiating combustion of the coke.

Minn. R. 7007.0800, subp. 2

RECORDKEEPING hdr

Limestone and Coke Usage Recordkeeping: once each day record the amount oflimestone and coke used in the lime kilns for the previous day. At the end of eachcalendar month, calculate and record the usage of limestone and coke during theprevious month and the previous 12-month period.

Title I Condition: Recordkeeping to avoid classificationas a major modification under 40 CFR Section 52.21;Minn. R. 7007.0800, subp. 5

Coke Sulfur Content Recordkeeping: For each coke shipment, the Permittee shallobtain a fuel certification from the fuel supplier, stating the percent sulfur by weight,in the coke. Maintain certification records for a minimum of 5 years from the date ofreceipt.


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12900014 - 002

Facility Name:

Permit Number:

Subject Item: EU 001 Boiler No. 1 (Main)

Associated Items: CE 001 Electrostatic Precipitator - High Efficiency

MR 004

MR 005

MR 006

MR 007

SV 001


Total Particulate Matter: less than or equal to 0.1 lbs/million Btu heat input 40 CFR Section 60.42(a)(1); Minn. R. 7011.0555

Opacity: less than or equal to 20 percent opacity except for one six-minute periodper hour of not more than 27 percent opacity.

40 CFR Section 60.42(a)(2); Minn. R. 7011.0555

Sulfur Dioxide: less than or equal to 0.8 lbs/million Btu heat input for liquid fossilfuels and 1.2 lbs/million Btu heat input for solid fossil fuels, based on a three-houraverage. When different fossil fuels are burned simultaneously, the sulfur dioxidestandard is determined by proration with the following formula:

PSso2 = [y(0.8) + z(1.2)]/(y+z)

where:PSso2 = prorated SO2 standardy = percentage of total heat input derived from liquid fossil fuelsz = percentage of total heat input derived from solid fossil fuels

40 CFR Section 60.43(a); 40 CFR Section 60.43(b);Minn. R. 7011.0555

Nitrogen Oxides: less than or equal to 0.3 lbs/million Btu heat input for liquid fossilfuels and 0.7 lbs/million Btu heat input for solid fossil fuels, based on a three-houraverage. When different fossil fuels are burned simultaneously, the nitrogen oxidesstandard is determined by proration with the following formula:

PSnox = [y(0.30) + z(0.7)]/(y+z)

where:PSnox = prorated NOx standardy is the percentage of total heat input derived from liquid fossil fuelsz is the percentage of total heat input derived from solid fossil fuels

40 CFR Section 60.44(a); 40 CFR Section 60.44(b);Minn. R. 7011.0555

Fuels Allowed: sub-bituminous coal and fuel oil. Minn. R. 7007.0800, subp. 2

OPERATIONAL REQUIREMENTS hdr

Fuel Heat Input: less than or equal to 254,000 MMBtu/month based on a 12-monthrolling average. This limit applies after the commencement of operation of EU 028.This limit does not apply during periods when EU 028 is shutdown due tomalfunction or for maintenance.

Title I Condition: Limit taken to avoid classification as amajor modification under 40 CFR 52.21

Operation of Pollution Control Equipment: Operate the electrostatic precipitator onEU 001 (CE 001) with no less than the number of fields on-line as during the mostrecent performance test that met the total particulate matter standard in 40 CFRSection 60.42.

Minn. R. 7007.0800, subp. 14

MONITORING REQUIREMENTS hdr

Fuel Heat Content: Determine the heat content of each delivery of each permittedfuel by either of the following methods:

1) according to ASTM sampling and analysis methods in part 5.2.1 and 5.2.2 ofMethod 19 in 40 CFR pt. 60 Appendix A, or2) obtain from the fuel supplier for each permitted fuel delivery, a certification of theheat content of the fuel.

Maintain heat content records for a minimum of five years from the date theinformation was obtained.

Title I Condition: Monitoring to avoid classification as amajor modification under 40 CFR 52.21; Minn. R.7007.0800, subp. 4

CEMS/COMS Operation: Operate certified SO2 and NOx CEMS, as well as acertified continuous opacity monitoring system (COMS), whenever the emissionunit is operating.

Minn. R. 7007.0800, subp. 2; Minn. R. 7017.1000,subp. 1; 40 CFR Section 60.45(a)

CEMS Daily Calibration Drift (CD) Test: The CD shall be quantified and recordedat zero (low level) and upscale (high-level) gas concentrations at least once daily.The CEMS shall be adjusted whenever the CD exceeds twice the specification of40 CFR pt. 60, Appendix B. 40 CFR pt. 60, Appendix F shall be used to determineout-of-control periods for CEMS.

40 CFR pt. 60, Appendix F, Section 4.1; 40 CFRSection 60.13(d)(1); Minn. R. 7007.0800, subp. 2

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Facility Name:

Permit Number:

COMS Daily Calibration Drift (CD) Check: The CD shall be quantified and recordedat zero (low-level) and upscale (high-level) opacity at least once daily. The COMSmust be adjusted whenever the calibration drift (CD) exceeds twice thespecification of PS-1 of 40 CFR 60, Appendix B.

Minn. R. 7017.0800, subp. 2; 40 CFR Section 60.13(d)

COMS Calibration Error Audit: due before end of each calendar half-year starting04/01/1998 Conduct audit at least 3 months apart but no greater than 8 monthsapart. Follow the procedure listed in 40CFR60, Appendix B, PS-1, 7.1.4.

Minn. R. 7007.0800, subp. 2; 40 CFR Section 60,App. B., PS-1, part 7.1.4.

Cylinder Gas Audit: due before end of each calendar half-year starting 04/01/1998Conduct CGA at least 3 months apart and not greater than 8 months apart. Followthe procedures in 40 CFR pt. 60, Appendix F.

Minn. R. 7007.0800, subp. 2

CEMS Relative Accuracy Test Audit (RATA): due before end of each calendar yearfollowing Permit Issuance . If the relative accuracy is 15% or less the next CEMSRATA is not due for 24 months. Follow the procedures in 40 CFR pt. 60, AppendixB and Appendix F.

Minn. R. 7007.0800, subp. 2

RECORDKEEPING hdr

Fuel Heat Input: Once each day, record the amount of each type of fuel combustedin EU 001 during the previous day and use these figures to also calculate the totaldaily heat input. At the end of each calendar month, calculate and record the heatinput for the previous month, except do not include the heat input of any fuelscombusted in EU 001 when EU 028 was shutdown due to malfunction ormaintenance. Also at the end of each calendar month, calculate the total heatinput for the previous 12-month period based on a 12-month rolling average, for allfuels combusted in EU 001.

Title I Condition: Recordkeeping to avoid classificationas a major modification under 40 CFR 52.21; Minn. R.7007.0800, subp. 5

CEMS/COMS Continuous Operation: Monitoring systems must be operated anddata recorded during all periods of emission unit operation including periods ofemission unit startup, shutdown, and malfunction. This requirement to operate themonitor applies whether or not a numerical emission limit applies during theseperiods. Monitoring systems must not be bypassed except in emergencies wherefailure to bypass the system would endanger human health, safety, or plantequipment.

Minn. R. 7007.0800, subp. 2

COMS Monitoring Data: Owners or operators of all COMS shall reduce all data to6 minute averages. Opacity averages shall be calculated from all equally spacedconsecutive 10-second (or shorter) data points in the 6 minute averaging period.

Minn. R. 7007.0800, subp. 2

CEMS Recordkeeping: The owner or operator must retain records of all CEMSmonitoring data and support information for a period of five years from the date ofthe monitoring sample, measurement or report. Records shall be kept at thesource.

Minn. R. 7007.0800, subp. 5

COMS Recordkeeping: The owner or operator must retain records of all COMSmonitoring data and support information for a period of five years from the date ofthe monitoring sample, measurement or report. Records shall be kept at thesource.

Minn. R. 7007.0800, subp. 5

Pollution Control Equipment Operating Conditions: The Permittee shall recordonce each day of EU 001 operation, the minimum number of CE 001 fields on-lineduring that day.

Minn. R. 7007.0800, subp. 5

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12900014 - 002

Facility Name:

Permit Number:

Subject Item: EU 002 Boiler No. 2

Associated Items: SV 002

What to do Why to do itTotal Particulate Matter: less than or equal to 0.6 lbs/million Btu heat input Minn. R. 7011.0510, subp. 1

Sulfur Dioxide: less than or equal to 2.0 lbs/million Btu heat input when burning fueloil.

Minn. R. 7011.0510, subp. 1

Opacity: less than or equal to 20 percent opacity except for one six-minute periodper hour of not more than 60 percent opacity

Minn. R. 7011.0510, subp. 2

Fuels Allowed: natural gas and fuel oil. Minn. R. 7007.0800, subp. 2

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Facility Name:

Permit Number:



What to do Why to do itTotal Particulate Matter: less than or equal to 0.6 lbs/million Btu heat input Minn. R. 7011.0510, subp. 1

Sulfur Dioxide: less than or equal to 2.0 lbs/million Btu heat input when burning fueloil.

Minn. R. 7011.0510, subp. 1


Minn. R. 7011.0510, subp. 2


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12900014 - 002

Facility Name:

Permit Number:

Subject Item: EU 004 "A" Pulp Dryer

Associated Items: CE 002 Centrifugal Collector - High Efficiency

CE 003 Centrifugal Collector - High Efficiency



SV 003

SV 004

SV 005

SV 006


Total Particulate Matter: less than or equal to 0.3 grains/dry standard cubic foot ofexhaust gas unless required to further reduce emissions to meet the less stringentlimit of either Minn. R. 7011.0730 or Minn. R. 7011.0735. See next requirement forthe alternate Total Particulate Matter limit based on Minn. R. 7011.0715, subp. 3(A)the Permittee may elect to meet instead of this limit.

Minn. R. 7011.0610, subp. 1(A)(1)

Total Particulate Matter: greater than or equal to 85 percent collection efficiency forthe pollution control equipment, providing the entire emission facility does notcause a violation of the PM10 ambient air quality standards, and the emissionfacility is located not less than one-fourth mile from any residence or publicroadway. The Permittee is allowed to meet this alternate Total Particulate Matterlimit instead of the Total Particulate Matter limit in Minn. R. 7011.0715, subp. 1(A).

Minn. R. 7011.0610, subp. 1(A)(1); Minn. R.7011.0715, subp. 3

Sulfur Dioxide: less than or equal to 2.0 lbs/million Btu heat input for fuel oil. Minn. R. 7011.0610, subp. 2(B)


Minn. R. 7011.0610, subp. 1(A)(2)



Monitoring of Pollution Control Equipment: Once each operating day record thepressure drop in inches of water column across each cyclone.

Minn. R. 7007.0800, subp. 4

Corrective Actions: If the monitored parameter is out of the manufacturer'srecommended range, perform the necessary corrective action(s) as stated in thefacility O&M plan. Record all corrective actions immediately after the action iscompleted.

Minn. R. 7007.0800, subp. 14; Minn. R. 7007.0800,subp. 5

A-10



12900014 - 002

Facility Name:

Permit Number:

Subject Item: EU 005 "B" Pulp Dryer





SV 007

SV 008

SV 009

SV 010


Total Particulate Matter: less than or equal to 0.3 grains/dry standard cubic foot ofexhaust gas unless required to further reduce emissions to meet the less stringentlimit of either Minn. R. 7011.0730 or Minn. R. 7011.0735. See next requirement forthe alternate Total Particulate Matter limit based on Minn. R. 7011.0715, subp. 3(A)the Permittee may elect to meet instead of this limit.

Minn. R. 7011.0610, subp. 1(A)(1)

Total Particulate Matter: greater than or equal to 85 percent collection efficiency forthe pollution control equipment, providing the entire emission facility does notcause a violation of the PM10 ambient air quality standards, and the emissionfacility is located not less than one-fourth mile from any residence or publicroadway. The Permittee is allowed to meet this alternate Total Particulate Matterlimit instead of the Total Particulate Matter limit in Minn. R. 7011.0715, subp. 1(A).

Minn. R. 7011.0610, subp. 1(A)(1); Minn. R.7011.0715, subp. 3

Sulfur Dioxide: less than or equal to 2.0 lbs/million Btu heat input for fuel oil. Minn. R. 7011.0610, subp. 2(B)

Opacity: less than or equal to 20 percent opacity except for one six-minute periodper hour of not more than 60 percent opacity

Minn. R. 7011.0610, subp. 1(A)(2)



Monitoring of Pollution Control Equipment: Once each operating day record thepressure drop in inches of water column across each cyclone.

Minn. R. 7007.0800, subp. 4



A-11



12900014 - 002

Facility Name:

Permit Number:

Subject Item: EU 006 Pellet Cooler Dust Control System


SV 011


Total Particulate Matter: less than or equal to 0.3 grains/dry standard cubic foot ofexhaust gas unless required to further reduce emissions to meet the less stringentlimit of either Minn. R. 7011.0730 or Minn. R. 7011.0735.

Minn. R. 7011.0715, subp. 1(A)

Opacity: less than or equal to 20 percent opacity Minn. R. 7011.0715, subp. 1(B)

Pressure Drop: greater than or equal to 1.5 inches of water column and less than orequal to 2.5 inches of water column

Minn. R. 7007.0800, subp. 2


Monitoring of Pollution Control Equipment: Once each operating day record thepressure drop in inches of water column across the cyclone.

Minn. R. 7007.0800, subp. 4



A-12



12900014 - 002

Facility Name:

Permit Number:

Subject Item: EU 007 Sugar Drier/Cooler

Associated Items: CE 011 Venturi Scrubber

SV 012

What to do Why to do itEMISSON LIMITS +hdr

Total Particulate Matter: less than or equal to 0.3 grains/dry standard cubic foot ofexhaust gas unless required to further reduce emissions to meet the less stringentlimit of either Minn. R. 7011.0730 or Minn. R. 7011.0735.

Minn. R. 7011.0715, subp. 1(A)


Pressure Drop: greater than or equal to 4.5 inches of water column and less than orequal to 7.5 inches of water column

Minn. R. 7007.0800, subp. 2

Liquid Flow Rate: greater than or equal to 500 gallons/minute Minn. R. 7007.0800, subp. 2


Monitoring of Pollution Control Equipment: Once each operating day record thepressure drop in inches of water column across the scrubber and the inlet flow ratein gallons per minute.

Minn. R. 7007.0800, subp. 4

Corrective Actions: If any of the monitored parameters are out of the manufacturer'srecommended range, perform the necessary corrective action(s) as stated in thefacility O&M plan. Record all corrective actions immediately after the action iscompleted.


A-13



12900014 - 002

Facility Name:

Permit Number:

Subject Item: EU 008 Sugar Bin Climate Control System

Associated Items: CE 012 Fabric Filter - Low Temperature, i.e., T<180 Degrees F

SV 013

What to do Why to do itTotal Particulate Matter: less than or equal to 0.3 grains/dry standard cubic foot ofexhaust gas unless required to further reduce emissions to meet the less stringentlimit of either Minn. R. 7011.0730 or Minn. R. 7011.0735.

Minn. R. 7011.0715, subp. 1(A)


Visible Emissions Monitoring: The Permittee shall perform a visible emissionscheck on SV 013 once each day while in operation (during daylight hours). Avisible emissions check shall consist of viewing the exhaust gas exiting the stackand determining whether visible emissions are present or not.

Minn. R. 7007.0800, subp. 4

Visible Emissions Corrective Actions: If visible emissions (VEs) are observed,determine the cause and take corrective actions as soon as possible to eliminatethe VEs.

Minn. R. 7007.0800, subp. 2

Visible Emissions Recordkeeping: Record the time and date of each VEinspection, and whether or not any VEs were observed. If VEs were observed, alsorecord a brief description of the type of corrective actions taken, and the date theactions were taken.

Minn. R. 7007.0800, subp. 5

A-14



12900014 - 002

Facility Name:

Permit Number:



SV 014


Minn. R. 7011.0715, subp. 1(A)



Minn. R. 7007.0800, subp. 4


Minn. R. 7007.0800, subp. 2


Minn. R. 7007.0800, subp. 5

A-15



12900014 - 002

Facility Name:

Permit Number:



SV 015


Minn. R. 7011.0715, subp. 1(A)



Minn. R. 7007.0800, subp. 4


Minn. R. 7007.0800, subp. 2


Minn. R. 7007.0800, subp. 5

A-16



12900014 - 002

Facility Name:

Permit Number:



SV 016


Minn. R. 7011.0715, subp. 1(A)



Minn. R. 7007.0800, subp. 4


Minn. R. 7007.0800, subp. 2


Minn. R. 7007.0800, subp. 5

A-17



12900014 - 002

Facility Name:

Permit Number:




Nitrogen Oxides: less than or equal to 0.0913 lbs/million Btu heat input using30-day Rolling Average

Title I Condition: Limit to avoid classification as a majormodification under 40 CFR 52.21; meets requirementsof 40 CFR Section 60.44b; Minn. R. 7011.0565

Sulfur Dioxide: less than or equal to 0.50 lbs/million Btu heat input using 24-hourBlock Average (calenday day average) when combusting fuel oil.

Title I Condition: Limit to avoid classification as a majormodification under 40 CFR 52.21; meets requirementsof 40 CFR Section 60.42b(a); Minn. R. 7011.0565

Total Particulate Matter: less than or equal to 0.1 lbs/million Btu heat input 40 CFR Section 60.42(a)(1); Minn. R. 7011.0555

Opacity: less than or equal to 20 percent opacity (six-minute average), except forone six-minute period per hour of not more than 27 percent opacity, whencombusting fuel oil.

40 CFR Section 60.43b(f); Minn. R. 7011.0565

Emission Standard Applicability: the nitrogen oxides and sulfur dioxide standardsapply at all times, whereas the opacity standard does not apply during periods ofstartup, shutdown, or malfunction.

40 CFR Section 60.45b(a); 40 CFR Section 60.46b(a);Minn. R. 7011.0565

OPERATIONAL LIMITS hdr

Fuels Allowed: only very low sulfur oil (as defined in 40 CFR Section 60.41b),natural gas, and wastewater treatment plant gases may be combusted in EU 028.

Title I Condition: Fuel restriction to avoid classificationas a major modification under 40 CFR 52.21

Fuel Usage: less than or equal to 1119000 gallons/year using 12-month RollingSum of very low sulfur fuel oil (equivalent to a very low sulfur oil annual capacityfactor of approximately 5.0%).For the first 11 months after the initial startup of EU 028 the Permittee shall use nomore than the following: limit (gallons) = 996927 + 10172(n)where, n = the number of months of operation of EU 028

Title I Condition: Limit taken to avoid classification as amajor modification under 40 CFR 52.21

PERFORMANCE TESTING hdr

Initial Performance Test: due 180 days after Initial Startup but not to exceed 60days after achieving the maximum production rate at which Boiler No. 4 will beoperated to measure SO2 emissions in accordance with the procedures in 40 CFR60.45b(d). The initial performance test shall be conducted over 24 consecutivesteam generating unit operating hours at full load. The SO2 emission rate shall bebased on a daily average determined by the fuel sampling and analysis proceduresunder Method 19.

40 CFR Sections 60.8(a); 40 CFR 60.45b(d); Minn. R.7011.0565; Minn. R. 7017.2020, subp. 1

Initial Performance Test: due 180 days after Initial Startup but not to exceed 60days after achieving the maximum production rate at which Boiler No. 4 will beoperated to measure NOx emissions in accordance with the procedures in 40 CFR60.46b(e) and 60.48b. NOx emissions are monitored for 30 successive steamgenerating unit operating days and the 30-day average emission rate isdetermined. The 30-day average emission rate is calculated as the average of allhourly emissions data recorded by the monitoring system during the 30-day testperiod.

40 CFR Sections 60.8(a); 40 CFR 60.46b(e); Minn. R.7011.0565; Minn. R. 7017.2020, subp. 1

Initial Performance Test: due 180 days after Initial Startup but not to exceed 60days after achieving the maximum production rate at which Boiler No. 4 will beoperated to measure PM emissions in accordance with the procedures in 40 CFR60.46. Test to be conducted while combusting fuel oil.

40 CFR Sections 60.8(a); 40 CFR 60.46; Minn. R.7011.0555; Minn. R. 7017.2020, subp. 1

Initial Performance Test: due 180 days after Initial Startup but not to exceed 60days after achieving the maximum production rate at which Boiler No. 4 will beoperated to measure Opacity emissions. Test to be conducted while combustingfuel oil.

40 CFR Sections 60.8(a); 40 CFR 60.46b(d); Minn. R.7011.0565; Minn. R. 7017.2020, subp. 1

Performance Test Pre-test Meeting: due 7 days before Initial Performance Test forSO2, NOx, PM and Opacity. (7 days before each Initial Performance Test)

Minn. R. 7017.2030, subp. 4

MONITORING hdr

Fuel Oil Analysis: Sample the fuel oil daily at the boiler inlet in an as-fired conditionand analyze for sulfur content (percent by weight) and heat content (gross calorificvalue) as described in Part 5.2.2 of Method 19 in Appendix A of 40 CFR pt. 60.

Title I Condition: Monitoring to avoid classification as amajor modification under 40 CFR 52.21; meetsrequriements of 40 CFR Section 60.47b(b)(1); Minn. R.7011.0565

Install: due 180 days after Initial Startup continuous monitoring systems to measureopacity and nitrogen oxides emissions.

40 CFR Sections 60.48b(a) and (b), Minn. R.7017.1000, subp. 1

CEM Certification Test Pretest Meeting: due 7 days before CEM Certification Test Minn. R. 7017.2030, subp. 4; Minn. R. 7007.0800,subp. 2

COMS Certification Test Pretest Meeting: due 7 days before COMS CertificationTest

Minn. R. 7007.0800, subp. 2

CEM Certification Test: due 180 days after Initial Startup 40 CFR Section 60.13(b); Minn. R. 7007.0800, subp.2; 40 CFR Section 60.8(a)

A-18



12900014 - 002

Facility Name:

Permit Number:

COMS Certification Test: due 180 days after Initial Startup 40 CFR Section 60.13(b); Minn. R. 7007.0800, subp.2; 40 CFR Section 60.8(a)

CEMS Daily Calibration Drift (CD) Test: The CD shall be quantified and recorded atzero (low-level) and upscale (high-level) gas concentrations at least once daily.The CEMS shall be adjusted whenever the CD exceeds twice the specification of40 CFR pt. 60, Appendix B. 40 CFR pt. 60, Appendix F, shall be used to determineout-of-control periods.

40 CFR pt. 60, Appendix F, section 4; Minn. R.7007.0800, subp. 2; 40 CFR Section 60.13(d)

COMS Daily Calibration Drift (CD) Check: The CD shall be quantified and recordedat zero (low-level) and upscale (high-level) opacity at least once daily. The COMSmust be adjusted whenever the calibration drift (CD) exceeds twice thespecification of PS-1 of 40 CFR 60, Appendix B.

Minn. R. 7017.0800, subp. 2; 40 CFR Section 60.13(d)

COMS Calibration Error Audit: due before end of each calendar half-year followingPermit Issuance Conduct calibration error audits at least 3 months apart but nogreater than 8 months apart.

Minn. R. 7007.0800, subp. 2

Cylinder Gas Audit: due before end of each calendar quarter following PermitIssuance A CGA is not due during any quarter in which a RATA was performed.

40 CFR pt. 60, Appendix F, 5.1.2.; Minn. R.7007.0800, subp. 2

CEMS Relative Accuracy Test Audit (RATA): due before end of each calendar yearfollowing Permit Issuance

40 CFR pt. 60, Appendix F, 5.1.1.; Minn. R.7007.0800, subp. 2

RECORDKEEPING hdr

Fuel Usage Recordkeeping: Once each day, record the amount of each type of fuelused in EU 028 during the previous day. At the end of each calendar month,calculate and record fuel usage for each type of fuel for the previous month and theprevious 12-month period. At the end of each calendar month, calculate andrecord the annual capacity factor for each fuel type based on a 12-month rollingaverage.

Title I Condition: Recordkeeping to avoid classificationas a major modification under 40 CFR Section 52.21;meets requirements of 40 CFR Section 60.49b(d);Minn. R. 7007.0800, subp. 5

Sulfur Dioxide Emissions Calculation: once each day that fuel oil is combusted,calculate and record the daily average sulfur dioxide emission rate in pounds permillion Btu heat input, based on the results of the Method 19 fuel oil analyses.

Title I Condition: Recordkeeping to avoid classificationas a major modification under 40 CFR Section 52.21;meets requirements of 40 CFR Section 60.45b(d)(2);Minn. R. 7011.0565

Recordkeeping - Periods of Malfunction and Maintenance: Record the time anddate and each start and finish time for all shutdowns of EU 028 due to malfunctionor maintenance.


COMS Monitoring Data: Owners or operators of all COMS shall reduce all data to6 minute averages. Opacity averages shall be calculated from all equally spacedconsecutive 10-second (or shorter) data points in the 6 minute averaging period.

Minn. R. 7007.0800, subp. 2; 40 CFR Section60.13(e)(1)

CEMS/COMS Records: Keep records of all CEMS/COMS data onsite available forinspection for a period of five years following the record.

40 CFR Sections 60.49b(f)&(g); Minn. R. 7007.0800,subp. 5; 40 CFR Section 60.7(f); Minn. R. 7019.2000,subp. 2

CEMS/COMS Continuous Operation: Monitoring systems must be operated anddata recorded during all periods of emission unit operation including periods ofemission unit startup, shutdown, and malfunction. This requirement to operate themonitor applies whether or not a numerical emission limit applies during theseperiods. Monitoring systems must not be bypassed except in emergencies wherefailure to bypass the system would endanger human health, safety, or plantequipment.

Minn. R. 7007.0800, subp. 2

REPORTING hdr

A-19



12900014 - 002

Facility Name:

Permit Number:

Subject Item: EU 029 WWTP Flare


What to do Why to do itOpacity: less than or equal to 20 percent opacity Minn. R. 7011.0110

A-20

TABLE B: SUBMITTALSFacility Name: Southern Minnesota Beet Sugar Coop

Permit Number: 12900014 - 002

08/11/99

Table B lists most of the submittals required by this permit. Please note that some submittal requirements may appear in Table Aor, if applicable, within a compliance schedule located in Table C. Table B is divided into two sections in order to separately listone-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 parts7007.0100 to 7007.1850 must be certified by a responsible official, defined in Minn. R. 7007.0100, subp. 21. Other submittals shallbe 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 AdvisorPermit SectionAir Quality DivisionMinnesota Pollution Control Agency520 Lafayette Road NorthSt. Paul, Minnesota 55155-4194

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:

SupervisorCompliance Determination UnitAir Quality DivisionMinnesota Pollution Control Agency520 Lafayette Road NorthSt. Paul, Minnesota 55155-4194

Send submittals that are required to be submitted to the U.S. EPA regional office to:

Mr. George CzerniakAir and Radiation BranchEPA Region V77 West Jackson BoulevardChicago, Illinois 60604

Send submittals that are required by the Acid Rain Program to:

U.S. Environmental Protection AgencyClean Air Markets Division1200 Pennsylvania Avenue NW (6204N)Washington, D.C. 20460

B-1

TABLE B: ONE TIME SUBMITTALS OR NOTIFICATIONSFacility Name: Southern Minnesota Beet Sugar Coop


08/11/99

What to send When to send Portion of Facility AffectedApplication for Permit Reissuance due 180 days before expiration of Existing

PermitTotal Facility

CEM Certification Test Notification due 30 days before CEM Certification Test EU028

CEM Certification Test Plan due 30 days before CEM Certification Test EU028

CEM Certification Test Report - MicroficheCopy

due 105 days after CEM Certification Test EU028

CEM Certification Test Report due 45 days after CEM Certification Test . EU028

Computer Dispersion Modeling Protocol due 1,096 days after 04/01/1998 Total Facility

Computer Dispersion Modeling Results due 1,462 days after 04/01/1998 Total Facility

COMS Certification Test Notification due 30 days before COMS Certification Test EU028

COMS Certification Test Plan due 30 days before COMS Certification Test EU028

COMS Certification Test Report - MicroficheCopy

due 105 days after COMS Certification Test EU028

COMS Certification Test Report due 45 days after COMS Certification Test EU028

Notification of the Actual Date of Initial Startup due 15 days after Initial Startup. Thisnotification shall include the items listed at 40CFR Section 60.49b(a).

EU028

Notification of the Anticipated Date of InitialStartup

due 30 days before Anticipated Date of InitialStartup

EU028

Notification of the Date Construction Began due 30 days after Start Of Construction EU028

Notification of the date of EquipmentRemoval/Dismantlement

due 30 days after Equipment Removal and/orDismantlement for EU 002, EU 003, EU 004,and EU 005. A seperate notification shall besubmitted for each emission unit. Submit thenotifications to theCompliance TrackingCoordinator

Total Facility

Performance Test Notification (written) due 30 days before Initial Performance Testfor SO2, NOx, PM and Opacity. (30 daysbefore each Initial Performance Test)

EU028

Performance Test Plan due 30 days before Initial Performance Testfor SO2, NOx, PM and Opacity. (30 daysbefore each Initial Performance Test)

EU028

Performance Test Report - Microfiche Copy due 105 days after Initial Performance Test forSO2, NOx, PM and Opacity. (105 days aftereach Initial Performance Test)

EU028

Performance Test Report due 45 days after Initial Performance Test forSO2, NOx, PM and Opacity. (45 days aftereach Initial Performance Test)

EU028

Relative Accuracy Test Audit (RATA)Notification

due 30 days before CEMS Relative AccuracyTest Audit (RATA)

EU001, EU028

B-2

TABLE B: RECURRENT SUBMITTALSFacility Name: Southern Minnesota Beet Sugar Coop


08/11/99

What to send When to send Portion of Facility AffectedExcess Emissions/Downtime Reports (EER's) due 30 days after end of each calendar

quarter following Permit Issuance (SubmitDeviations Reporting Form DRF-1 asamended). The EER shall indicate all periodsof monitor bypass and all periods ofexceedances of the opacity, sulfur dioxide ornitrogen oxides limits including exceedancesallowed by an applicable standard, i.e. duringstartup, shutdown, and malfunctions.

EU001

Excess Emissions/Downtime Reports (EER's) due 30 days after end of each calendarquarter following Permit Issuance (SubmitDeviations Reporting Form DRF-1 asamended). The EER shall indicate anyperiods of monitor bypass and all periods ofexceedances of the opacity or nitrogen oxideslimits including exceedances allowed by anapplicable standard, i.e. during startup,shutdown, and malfunctions.

EU028

Relative Accuracy Test Audit (RATA) ResultsSummary

due 30 days after end of each calendarquarter following CEMS Relative AccuracyTest Audit (RATA) in which the CEMS RATAwas conducted.

EU001, EU028

COMS Calibration Error Audit ResultsSummary

due 30 days after end of each calendarhalf-year following COMS Calibration ErrorAudit Results Summary COMS CalibrationError Audit Results Summary: due 30 daysafter end of each calendar half-year followingCOMS Calibration Error Audit.

EU001

COMS Calibration Error Audit ResultsSummary

due 30 days after end of each calendarhalf-year following COMS Calibration ErrorAudit Results Summary COMS CalibrationError Audit Results Summary: due 30 daysafter end of each calendar half-year followingCOMS Calibration Error Audit.

EU028

Cylinder Gas Audit (CGA) Results Summary due 30 days after end of each calendarhalf-year following Cylinder Gas Audit

EU001

Cylinder Gas Audit (CGA) Results Summary due 30 days after end of each calendarhalf-year following Cylinder Gas Audit

EU028

Semiannual Deviations Report due 30 days after end of each calendarhalf-year following Permit Issuance . The firstreport of each calendar year covers January 1- June 30. The second report of eachcalendar year covers July 1 - December 31.

Total Facility

Compliance Certification due 30 days after end of each calendar yearstarting 04/01/1998 (for the previous calendaryear). The report covers all deviationsexperienced during the calendar year. To besubmitted on a form approved by theCommissioner to the Commissioner and tothe U.S. EPA regional office in Chicago. Thisreport covers all deviations experiencedduring the calendar year. The EPA copy shallbe sent to: Mr. George Czerniak, Chief, AirEnforcement and Compliance AssuranceBranch, Air and Radiation Division, EPARegion V, 77 West Jackson Boulevard,Chicago, Illinois 60604>

Total Facility

Emissions Inventory Report due 91 days after end of each calendar yearfollowing Permit Issuance (April 1). To besubmitted on a form approved by theCommissioner.

Total Facility

B-3

Page 1

TECHNICAL SUPPORT DOCUMENT For

AIR EMISSION PERMIT NO. 12900014-002 This Technical Support Document (TSD) is for all the interested parties of the permit. The purpose of this document is to set forth the legal and factual basis for the permit conditions, including references to the applicable statutory or regulatory provisions. 1. General Information 1.1. Applicant and Stationary Source Location:

Owner/Operator Address and Phone Number (list both if different)

Facility Address (SIC Code: 2063)

East Highway 212 Renville, Minnesota 56284

same Renville County

(320)329-4149 1.2. Description Of The Facility

Southern Minnesota Beet Sugar Cooperative (SMBSC) processes sugar from sugar beets for use in many consumer food products. The facility was built in 1974. SMBSC has about 480 members and grows beets in an eleven county area around the plant. The cooperative employs roughly 250 year-round employees and 350 seasonal employees. The general sugar making process can be divided into four steps: extraction, purification, evaporation, and crystallization. In the extraction process beets are received, cleaned, sliced and then the sugar-containing liquid, called raw juice, is extracted by diffusion. The leftover material, called pulp, is dried and pressed to be sold as animal feed. During purification, milk of lime and carbon dioxide gas are added to the raw juice in a series of carbonation tanks and non-sucrose impurities are removed by precipitation. The lime and carbon dioxide are produced in lime kilns and the lime is converted to milk of lime in a lime slaker. The evaporation process concentrates the juice in a series of evaporators. The concentrated liquid, now called thick juice, is crystallized, dried, cooled, screened, and stored or packaged for shipment. During the crystallization process, a liquid is centrifuged from the sugar crystals called molasses. Sugar can be extracted from this liquid by repeated boilings and ion exchange. The remaining molasses can be used in the production of livestock feed. The facility’s operation is split into periods of time referred to as campaigns. Harvest can begin as early as August and usually ends in November. The beet slicing campaign will generally run from September to March, while the juice processing campaign will generally run through June, and the molasses campaign will run through August.

Page 2

The major sources of air emissions at SMBSC, as it exists today, can be divided into two categories: combustion sources and product handling sources. Combustion sources include three boilers, two pulp dryers, and two lime kilns. The largest boiler is controlled by an electrostatic precipitator (ESP), each of the two pulp dryers are controlled by four parallel cyclones, and the two lime kilns are uncontrolled (although the combustion gas is usually bubbled through the carbonators). Product handling sources include sugar handling and conveying equipment along with other product/raw material handling equipment. The majority of the product handling sources are controlled by baghouses, but some units are controlled by wet scrubbers. The major source of fugitive emissions at the facility is truck traffic.

1.3 Description of the Activities Allowed By This Permit Action SMBSC is proposing a five-year capital improvements project that will expand processing capacity, enhance operational efficiency, and improve performance. A permit amendment application was received on July 1, 1998, and amended on July 7, 1998 and August 7, 1998. The project involves the replacement or modification of nearly every major unit operation at the facility. A summary of the project is included in Attachment 1. The project includes a number of modifications to air emission sources at the facility. Boiler Nos. 2 and 3, will be replaced by a new Boiler No. 4. The two direct-fired pulp dryers will be replaced by two steam pulp dryers. The replacement of a number of non-air emission units will increase sugar production and will debottleneck the processing plant and a number of product handling sources. A new wastewater treatment plant will also be built. The scope of the project required that an Environmental Assessment Worksheet (EAW) be completed. The public notice period for the EAW ran from September 7, 1998 to October 7, 1998. The EAW received comments on a number of issues including: water quality impacts from the new point source discharge, the validity of applying nonpoint pollutant trading in this case, the impact on water quality of an increased number of remote beet stockpiling sites, the impact on water quality of the increased sugar beet acreage associated with the expansion, and concerns about the cumulative impact of odors and hydrogen sulfide from SMBSC and other nearby facilities. No written comments were received on the air permit during its public notice period which ran from October 6, 1998 to November 4, 1998. Since their comment periods overlapped, comments received on the EAW that pertained to the air permit became comments on the air permit. Applicable comments received were related to odor and hydrogen sulfide concerns related to the wastewater treatment facility and were addressed in the EAW documentation (attached).

Page 3

A new NPDES/SDS (water) permit was required due to the new point source discharge associated with the new wastewater treatment plant. The water permit proved to be controversial and ultimately went to the MPCA board for their consideration on March 23, 1999 and again on April 7, 1999. For more information on the issues pertaining to the EAW, water permit, or solid waste permits please refer to those documents and their supporting information.

1.4. Facility Emissions:

Table 1. Emissions Associated With the Modification

Pollutant

Potential to Emit from the modification

(TPY)

Emission Increases

Authorized with this Permit Action

(TPY)

Emission Decreases

Authorized with this Permit Action

(TPY)

*Other Contemporaneous

Emission Increases/ Decreases

(TPY)

Net Emission Change

(TPY)

NSR Threshold

Level

(TPY)

NSR Review

Required

(Yes/No) PM -627.8 35.3 -663.1 12.1 -615.7 25 No

PM10 -634.1 29.0 -663.1 10.6 -623.5 15 No SO2 39.0 46.7 -7.7 0 39.0 40 No NOx 39.0 163.1 -124.1 0 39.0 40 No VOC -10.0 8.3 -18.3 0 -10.0 40 No CO -63.5 135.6 -199.1 0 -63.5 100 No

Lead 0 0 0 0 0.001 0.6 No *Emission changes during the contemporaneous period as defined by 40 CFR § 52.21, 40 CFR § 52.24 or 40 CFR pt. 51

Page 4

Table 2. Source Classification

Classification Major/Affected Source

*Synthetic Minor *Minor

PSD (PM10, SO2, NOx, CO) X NAAR NA NA NA Part 70 Permit Program (PM10, SO2, NOx, CO)

X

* Refers to potential emissions that are less than those specified as major by 40 CFR § 52.21, 40 CFR pt. 51 Appendix S, and 40 CFR pt. 70. 2. Regulatory and/or Statutory Basis Regulatory Overview of Units Affected by the Modification

Table 4. Regulatory Overview

*EU or GP

Applicable Regulations

**Comments

EU 028 40 CFR pt.60, subp. Db 40 CFR § 52.21

Operational limits taken to keep the potential emissions increase from Boiler No. 4 to less than significant as defined by 40 CFR § 52.21.

GP 002 40 CFR § 52.21 Operational limits taken to keep the potential emissions increase from the lime kilns to less than significant as defined by 40 CFR § 52.21.

Total Facility

Minn. R. 7009.0080; Minn. R. 7007.0800, subp. 4

Ambient air monitoring and modeling is required for hydrogen sulfide.

* Insert the number that identifies the level the limit was set on. ** Comments column is for citations that need further explanation only. Most rows should not have any further explanation needed. 3. Technical Information Summary of Federal Regulation Applicability

Prevention of Significant Deterioration (PSD), 40 CFR § 52.21 - The source is an existing major source under PSD. PSD review is not applicable to the modification because the net emission increase for the modification is not significant, based on the federally enforceable Title I Conditions proposed by SMBSC and included in the permit. Standards of Performance for New Stationary Sources (NSPS), 40 CFR pt. 60 - The new boiler (Boiler No. 4) is subject to Subparts D and Db, Standards of Performance for Fossil-Fuel Fired Steam Generators for Which Construction is Commenced After August 17, 1971 and Standards of Performance for Industrial-Commercial-Institutional Steam Generating Units, respectively.

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National Emission Standards for Hazardous Air Pollutants (NESHAP), 40 CFR pt. 61 and 63 - There are no Part 61 NESHAP applicable to this facility. The existing facility is a major Hazardous Air Pollutant (HAP) source under Part 63. There are currently no promulgated Part 63 NESHAP applicable to the facility as a whole. The existing boiler and the new boiler will likely be subject to the Part 63 NESHAP for Industrial Combustion due to be proposed in November of 1999. The modification is not subject to 40 CFR pt. 63, subp. B (i.e. Section 112(g)(2)(B) of Title III of the Clean Air Act), because it does not meet the definition of “construct a major source” or “reconstruct a major source” at 40 CFR § 63.41. For more information see Attachment 3. Compliance Assurance Monitoring (CAM), 40 CFR pt. 64 - The date when a CAM plan is due for any applicable pollutant specific emission unit depends on both the size of the unit and whether a significant permit revision to a Part 70 permit is being made. At the latest, CAM plans are due upon renewal of a source’s Part 70 permit. For large pollutant specific emission units (post-controlled emissions are greater than the major source threshold) CAM plans are required as a part of an application for a significant permit revision, but only for those emission units "for which the proposed permit revision is applicable.” This amendment would qualify as a significant permit revision. The only emission units that could potentially qualify as large emission units under CAM are Boiler No. 1 and the new boiler. In both of these cases CAM would not be applicable because these units have (or will have) continuous emissions monitors for measuring emissions of the pollutants of concern, and are therefore are exempt per 40 CFR § 64.2(b)(1)(vi). Air Emission Characterization Many of the process modifications proposed for this project do not affect air emission sources. Air emission sources affected by this project are: the existing pulp dryers, the new boiler, the lime kilns and lime slaker, the wastewater treatment plant, and many product handling sources. The calculations that show how the actual and potential air emissions were determined, in detail, are included in Attachment 2. In general, emission decreases were calculated for the existing pulp dryers and boilers two and three. Emission increases were calculated for the new boiler and the wastewater treatment plant (WWTP). Debottlenecked emission increases were calculated for the lime kilns and lime slaker, and the product handling sources. Debottlenecked emission increases from the existing boiler (Boiler No. 1) were not included in the emission calculations, and as a result, permit limits requiring no increased utilization of this boiler are included. Emission decreases were calculated for the pulp dryers and Boiler Nos. 2 and 3, based on the average actual emissions for the past two years. Calculations of the emission increases from the new boiler were based on maximum potential emissions, taking into account the emissions and operational limits proposed by SMBSC. SMBSC has proposed operational limits with regard to Boiler No. 4’s flue gas recirculation system so that it can achieve the proposed Nitrogen Oxides (NOX) emission rate of 0.0913 lb NOX/MMBtu.

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This low emission rate is necessary to keep the NOX net emission increase for the modification below the significant emission rate threshold under PSD, and will also meet the NOX standards at NSPS, Subpart Db. SMBSC has also proposed a fuel oil usage limit and fuel quality limit (very low sulfur oil as defined in 40 CFR § 60.41b) for Boiler No. 4 to meet the Sulfur Dioxide (SO2) requirements of NSPS, Subpart Db and to keep the net SO2 emissions increase from the modification below the significant emission rate threshold under PSD. Debottlenecked emission increases were calculated based on a capacity increase of 51 percent (an increase in beet processing from 3.0 million tons to 4.6 million tons of raw beets per year). Pellet cooler, sugar dryer/cooler, and sugar bin climate control system emissions were calculated based on the capacity increase. The emission increases for the lime kilns and lime slaker are based on only a 30 percent capacity increase, which is reflected in the product usage (limestone and coke) limits proposed by SMBSC and included in the permit. Compliance Demonstration Different compliance demonstration methods are employed depending on the emission unit. Boiler four utilizes (per NSPS subp. Db) continuous emission monitors for opacity (as a surrogate for particulate matter) and NOX and fuel sampling and analysis for SO2. The lime kilns use daily recordkeeping for the coke and limestone throughput limits. In response to its utilization limit, boiler one has daily requirements to track its fuel heat input. Notification of the removal and installation of the air emission units that are part of the modification is also required. Some shuffling of existing permit requirements was done to achieve better overall organization and improve readability. The shutdown/breakdown requirements, notification of deviations endangering human health or the environment, and opacity excursion language were all updated to reflect the current rules. Hydrogen Sulfide One goal of the capital improvements project is to reduce SMBSC’s role as an odor and Hydrogen Sulfide (H2S) source. The MPCA is aware of levels of H2S measured by local citizens and agency staff (see Attachment 4) in the ambient air around SMBSC that could potentially exceed the state H2S standard. The measuring methods that were used to make these measurements are not approved methods. On December 22, 1997, two measurement methods for H2S were approved by the MPCA (see Attachment 5). Before this time, there was no method available to measure H2S that was approved by either the MPCA or EPA. Because of the evidence which indicates a potential problem, H2S monitoring will be a requirement in this permit. SMBSC has maintained that the construction of their new WWTP will address their odor and H2S problems by reducing the acreage and time wastewater is stored (i.e. essentially treating the wastewater as it is generated). The MPCA feels that the levels of odor and H2S emissions from the new WWTP are dependent on the final design of the plant and how it is operated. This uncertainty is a reason H2S monitoring will be required.

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In addition to monitoring, H2S modeling will be required that will use available data and best engineering judgement to assess the potential H2S emissions. Initially Golden Oval and ValAdCo were also going to participate in the hydrogen sulfide modeling and monitoring to assess the cumulative impact of the three facilities. Golden Oval and ValAdCo later pulled out of the process. As a result, the date for submittal of the modeling results was pushed back from what was in the permit. SMBSC went ahead on their own with installation of the monitoring network. The equalization basin was one area of the new WWTP that the MPCA was concerned may be a large H2S (and odor) source. In response to this concern, SMBSC proposed to install an aboveground tank with a cover and gas collection, in place of the uncovered pond that was originally proposed. The results of the H2S monitoring will show if there are any additional sources that need to be considered for control.

4. Conclusion

Based on the information provided by SMBSC, the MPCA has reasonable assurance that the proposed operation of the emission facility, as described in the Air Emission Permit No. 12900014-002, and this TSD, will not cause or contribute to a violation of applicable federal regulations and Minnesota Rules.

Staff Members on Permit Team: Attachments: 1) MOD-01, Vision 2002 summary Trent R. Wickman, 2) emission calculations Cary Hernandez, 3) 112(g) applicability determination Marshall Cole, 4) July 11, 1998, H2S monitoring log Dave Vaaler, 5) H2S monitoring method approval letter Glenn Giefer, 6) EAW findings of fact and conclusions Steve Sommer, Greg Pratt, Rick Strassman

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Attachment 3 - 112(g) applicability determination 112(g) requires a case-by-case MACT determination for sources affected by this regulation. To determine if 112(g) is applicable to the modification, the regulation and relevant guidance documents were examined. 112(g) became effective in Minnesota on June 29, 1998. 40 CFR § 63.40 states that 112(g) is applicable to anyone who constructs or reconstructs a major HAP source. 40 CFR § 63.41, contains the definitions of these terms. Under both the construction and reconstruction scenarios, the process or production unit under consideration must have the potential to emit HAP over the major source threshold (10 tons per year of any single HAP or 25 tons per year of any combination of HAP) to be potentially subject to this rule. The only unit that could qualify in this modification would be the new boiler. HAP emission calculations for the new boiler based on AP-42 emission factors show that the new boiler is not a major source (see the emission calculations in Attachment 2), so 112(g) is not applicable.

Documents

AIR EMISSION PERMIT NO. 12900014-002 IS ISSUED TO Southern