Permit Applications Table · Permit Applications Table Permit Type Application ... A refinery may eventually be constructed at the ... conveying stack height was increased from 115

Permit Applications Table Permit Type Application Date Permit Action Total Facility Operating Permit December 13, 1999 001 Major Amendment September 18, 2001 002 Administrative Amendment March 22, 2004 003 Major Amendment May 13, 2005 004 Moderate Amendment October 18, 2006 005 Major Amendment September 29, 2009 006

TABLE OF CONTENTS Notice to the Permittee

Permit Shield

Facility Description Total Facility Operating Permit (Permit Action 001)

Major Amendment Description (Permit Action 002)

Administrative Amendment Description (Permit Action 003)

Major Amendment Description (Permit Action 004)

Moderate Amendment Description (Permit Action 005) Major Amendment Description (Permit Action 006) Table A: Limits and Other Requirements

Table B: Submittals

Appendix - Insignificant Activities Required to be Listed

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. Subject to the limitations of Minn. R. 7007.1800 and 7017.0100, subp. 2, notwithstanding the conditions of this permit specifying compliance practices for applicable requirements, any person (including the Permittee) may also use other credible evidence to establish compliance or noncompliance with applicable requirements.

FACILITY DESCRIPTION: TOTAL FACILITY OPERATING PERMIT (Permit Action 001):

The total facility operating permit authorized Cenex Harvest States Cooperatives (CHSC) to construct and operate a soybean processing plant in the city of Fairmont, Martin County, Minnesota. The proposed facility will receive raw soybeans and process them to extract soybean oil.

Soybeans will be received from via semi-trailers and railcar. The soybeans will be off-loaded into on-site grain elevators and cleaned to remove sticks, weed seeds, and dirt. After cleaning, the beans will be conveyed to temporary storage bins or directly to the bean preparation building. In the preparation building, the hull of the bean is separated from the meat and the meat is rolled flat into “flakes.” The hulls are formed into pellets, conveyed to storage, and eventually sold for use as animal feed. The flakes are conveyed to the extraction building.

Inside the extraction building, the flakes are washed in an extractor with commercial grade hexane, which strips the oil from the flakes. Two process streams leave the extractor: commercial hexane-laden flakes and miscella, which is a mixture of commercial hexane, oil, and water. The meal is “desolventized” by subjecting the commercial hexane-laden meal flakes to heat. The flakes are cooled, ground, and conveyed to storage bins. The ground and desolventized meal is sold as an animal feed. The commercial hexane that is driven off of the meal is piped to the solvent recovery system for re-use.

The miscella is separated into its components - oil, commercial hexane, and water - using distillation processes. The separated oil is termed crude oil. Initially, the facility will ship crude oil to another site for refining. A refinery may eventually be constructed at the Fairmont site to process the crude oil. The emission units associated with the refinery are included in this permit.

The refining process removes gums, colors, tastes, and odorous compounds from the crude oil to produce a product typically referred to as “salad oil.” The salad oil can be further processed to produce hydrogenated oil. Hydrogen would be produced on-site from natural gas or propane.

Final products - crude oil, refined and hydrogenated oil, meal, and hulls - will be shipped from the site primarily in bulk quantities via trucks and railcars. By-products will also be shipped via trucks and railcars.

Ancillary facilities at the plant will include a steam plant, a hydrogen plant, offices, a wastewater pretreatment system, maintenance facilities, and warehouses. The steam plant will consist of one steam generating boiler. The primary boiler fuel will be natural gas. Distillate fuel oil will be used as a backup fuel.

It is noted that there is not a GP 007, GP 011, GP 012, GP 013, SV 016, EU 023, or EU 024 in this permit.

MAJOR AMENDMENT (Permit Action 002):

This permit amendment allowed construction and operation of the following modifications. CHSC decided to not install a combustion turbine and duct as part of the original application. Instead, this permit authorized CHSC to install two additional 99 MMBtu/hr boilers. The 99 MMBtu/hr boilers, firing natural gas, as to the primary fuel will be the mainstream generating source at the facility. Distillate oil #2 is used as a backup fuel for the boilers. The #2 oil will be restricted to 5,000,000 gallons per 12-month rolling sum. Steam from the two boilers can be directed to a steam turbine, which will drive a 7 megawatt electric generator.

During the design process, the following changes were also made: SV007 (EU009) Hull Grinding/bin and conveying stack height was increased from 115.0 to 130.0 feet, stack diameter increased from 1.84 to 2.38 feet, and flow rate increased from 9,000 to 15,000 acfm.

SV009 (EU011) Meal Grinding, Sifters and Conveying, Meal Coat Bin and Conveying stack height was increased from 115.0 to 130.0 feet, stack diameter was decreased from 2.82 to 2.38 feet, and flow rate was decreased from 20,000 to 15,000 acfm. SV010 (EU012, EU013) Fabric Filter stack diameter was increased from 0.66 to 0.80 feet and flow rate is increased from 1,200 to 1,800 acfm.

Likewise, there were the following insignificant changes: SV004 (EU002) Grain Storage and conveying stack height was increased from 13.0 to 20.0 feet. SV005 (EU003, EU004, EU005) fabric filter stack height was increased from 115.0 to 130.0 feet. SV008 (EU010) Pellet Cooler/Cyclone stack height was increased from 115.0 to 130.0 feet.

In addition, the Permittee decided to not install the three emergency generators (EU025, EU026, and EU027 which were also GP009) that were included in the original permit.

ADMINISTRATIVE AMENDMENT (Permit Action 003):

This permit action authorized a 120-day extension to the performance testing deadline for SV013 within GP008, in accordance with Minn. R. 7007.1400, subp. 1(H).

MAJOR AMENDMENT (Permit Action 004):

This amendment changed the required pressure drop range for the fabric filters from 1-6 inches water column to 0.5-6 inches water column. The facility has stack emissions test data at the lower pressure drop range that demonstrates compliance with emission limits.

Also incorporated into this amendment was the stack testing frequency based on the initial stack emission test results, and the requirements for initial construction and startup notifications have been removed.

MODERATE AMENDMDMENT (Permit Action 005):

This amendment authorized the construction of a new hammermill in the meal grinding system and two new flakers in the flaking system. The additional equipment will debottleneck the facility. The facility’s existing capacity is 4,400 tons of beans per day. CHS expects that the facility will have a capacity of 4,670 tons of beans per day after the modification. The facility projects actual throughputs of approximately 4,560 tons of beans per day, 350 days per year.

The new and existing equipment will exhaust to existing control equipment and existing stacks that have Best Available Control Technology (BACT) emission limits placed on them. No changes to the BACT limits are needed, and no change to permit conditions. Additional requirements for testing have been added to make sure that the existing equipment is able to meet the existing emission limits, once installed.

This action also incorporated two previously submitted administrative amendment applications. One was for the addition of three new storage bins and associated conveyors, the other was for the addition of a third underground n-hexane storage tank. MAJOR AMENDMENT (Permit Action 006):

CHS applied for a Prevention of Significant Deterioration (PSD) Major Amendment on September 29, 2009, in accordance with Minn. R. 7007.1500. CHS is proposing to expand its oilseed processing capabilities. This expansion may occur in two phases. The first phase would involve replacing a conveyor motor and/or gear to increase the conveyor speed in the flaking area of the plant. This change would debottleneck the facility, but oil yield rates may decline. CHS is evaluating two options for the potential second phase of the debottlenecking project to restore the oil yield rates.

For Option 1, CHS would modify EU 008 by installing two new flakers in the flaking system and lengthen the existing extraction system.

For Option 2, CHS would install EU 035 (two mechanical presses, referred to as expellers or expanders) and SV 027 along with associated conveyors. The expellers would be controlled by a high-efficiency cyclone. The cyclone can be considered process equipment for air permitting since all the material collected by the cyclone is returned to the process. There are no VOC emissions from the expellers and choosing this option would require no physical modification to the existing extraction system. Higher energy costs are associated with this Option 2. This is primarily due to an increase in steam demand.

The permit amendment allows the permittee to choose only one of the two options listed above.

The facility’s existing capacity is 4,600 ton bean per day. CHS expects the facility will have a capacity of 5,280 ton bean per day after the modification. The facility projects actual throughputs of approximately 5,040 ton bean per day, 355 days per year.

The major pollutant of concern is Hexane which is a Volatile Organic Compound (VOC) and a Hazardous Air Pollutant (HAP). Hexane is the pollutant which is triggering PSD (projected actual emissions will be greater than 40 ton/yr). Particulate Matter less than 2.5 and 10 micrometers in aerodynamic diameter (PM2.5 and PM10) are also of interest because of how close the projected actual emissions are to PSD modification thresholds of 15 tons/yr for PM10 and 10 tons/yr for PM2.5.

This permit action also includes 3 permit reopenings along with a Notification of Replacement. These permit reopenings were generated from performance tests. The dates and some testing frequencies were updated (specifics can be seen in Table 6 of this TSD). The Notification of Replacement is informing the Agency that emissions from EU 014 will be rerouted from CE 009 (SV 011) to CE 007 (SV 009). This change is to improve operations. Both fabric filters are required to achieve 99 percent control. CE 007 is sized to accommodate the additional airflow. There will be no increase in air emissions from this change.

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

CHS Oilseed Processing - Fairmont

09100059 - 006

Facility Name:

Permit Number:

A-1

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 itSOURCE-SPECIFIC REQUIREMENTS hdr

The construction authorization of the 2011 debottlenecking project (EU 035, ormodification of EU 008) expires 18 months after permit issuance (of permit09100059-006). The Permittee must keep a record of the dates of installation andstart-up on site.

40 CFR Section 52.21(r)(2) and Minn. R. 7007.3000

Permit Appendix: This permit contains an appendix as listed in the permit Table ofContents. The Permittee shall comply with all requirements contained in theappendix.

Minn. R. 7007.0800, subp. 2

Rain caps are not allowed on any stacks facility-wide. Title I Condition: BACT Limit as per 40 CFR Section52.21(k) to demonstrate source impact analysis forattainment and increment standards.

The Permittee shall maintain a designated contact, on-site, for the neighbors totelephone with concerns of any dust arising from trucks, either entering or leavingthe facility premises. Upon such a complaint, the facility will investigate thecomplaint. Valid dust complaints are to be addressed by reasonable andappropriate mitigation measures. Such mitigation measures may include, but arenot limited to road watering. The Permittee shall record all complaints,investigation findings, and mitigation measures taken. A continued pattern of dustcomplaints may trigger a new PM10 modeling analysis. Such modeling will includean appropriate percentage of additional plant-related truck traffic driving west of thefacility on County Road No. 130.

Minn. R. 7007.0800, subp. 2

DETERMINING IF A PROJECT/MODIFICATION IS SUBJECT TO NSR hdr

These requirements apply if a reasonable possibility (RP) as defined in 40 CFRSection 52.21(r)(6)(vi) exists that a proposed project, analyzed using theactual-to-projected-actual (ATPA) test (either by itself or as part of the hybrid test atSection 52.21(a)(2)(iv)(f)) and found to not be part of a major modification, mayresult in a significant emissions increase (SEI). If the ATPA test is not used for theproject, or if there is no RP that the proposed project could result in a SEI, theserequirements do not apply to that project. The Permittee is only subject to thePreconstruction Documentation requirement for a project where a RP occurs onlywithin the meaning of Section 52.21(r)(6)(vi)(b).

Even though a particular modification is not subject to New Source Review (NSR),or where there isn't a RP that a proposed project could result in a SEI, a permitamendment, recordkeeping, or notification may still be required by Minn. R.7007.1150 - 7007.1500.

Title I Condition: 40 CFR Section 52.21(r)(6); Minn. R.7007.3000; Minn. R. 7007.0800, subp. 2

Preconstruction Documentation -- Before beginning actual construction on aproject, the Permittee shall document the following:

1. Project description2. Identification of any emission unit (EU) whose emissions of an NSR pollutantcould be affected3. Pre-change potential emissions of any affected existing EU, and the projectedpost-change potential emissions of any affected existing or new EU.4. A description of the applicability test used to determine that the project is not amajor modification for any regulated NSR pollutant, including the baseline actualemissions, the projected actual emissions, the amount of emissions excluded dueto increases not associated with the modification and that the EU could haveaccommodated during the baseline period, an explanation of why the amountswere excluded, and any creditable contemporaneous increases and decreases thatwere considered in the determination.

The Permittee shall maintain records of this documentation.

Title I Condition: 40 CFR Section 52.21(r)(6); Minn. R.7007.3000; Minn. R. 7007.1200, subp. 4; Minn. R.7007.0800, subps. 4 & 5



09100059 - 006

Facility Name:

Permit Number:

A-2

The Permittee shall monitor the actual emissions of any regulated NSR pollutantthat could increase as a result of the project and that were analyzed using theATPA test, and the potential emissions of any regulated NSR pollutant that couldincrease as a result of the project and that were analyzed using potential emissionsin the hybrid test. The Permittee shall calculate and maintain a record of the sum ofthe actual and potential (if the hybrid test was used in the analysis) emissions of theregulated pollutant, in tons per year on a calendar year basis, for a period of 5years following resumption of regular operations after the change, or for a period of10 years following resumption of regular operations after the change if the projectincreases the design capacity of or potential to emit of any unit associated with theproject.

Title I Condition: 40 CFR Section 52.21(r)(6); Minn. R.7007.3000; Minn. R. 7007.0800, subps. 4 & 5

The Permittee must submit a report to the Agency if the annual summed (actual,plus potential if used in hybrid test) emissions differ from the preconstructionprojection and exceed the baseline actual emissions by a significant amount aslisted at 40 CFR Section 52.21(b)(23). Such report shall be submitted to theAgency within 60 days after the end of the year in which the exceedances occur.The report shall contain:

a. The name and ID number of the facility, and the name and telephone number ofthe facility contact personb. The annual emissions (actual, plus potential if any part of the project wasanalyzed using the hybrid test) for each pollutant for which the preconstructionprojection and significant emissions increase are exceeded.c. Any other information, such as an explanation as to why the summed emissionsdiffer from the preconstruction projection.

Title I Condition: 40 CFR Section 52.21(r)(6); Minn. R.7007.3000; Minn. R. 7007.0800, subps. 4 & 5

OPERATIONAL REQUIREMENTS hdr

The Permittee shall comply with National Primary and Secondary Ambient AirQuality Standards, 40 CFR pt. 50, and the Minnesota Ambient Air QualityStandards, Minn. R. 7009.0010 to 7009.0080. Compliance shall be demonstratedupon written request by the MPCA.

40 CFR pt. 50; Minn. Stat. Section 116.07, subds. 4a &9; Minn. R. 7007.0100, subp. 7(A), 7(L), & 7(M); Minn.R. 7007.0800, subps. 1, 2 & 4; Minn. R.7009.0010-7009.0080

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

Air Pollution Control Equipment: Operate all pollution control equipment wheneverthe corresponding process equipment and emission units are operated.

Minn. R. 7007.0800, subps. 2 & 16(J)

Operation and Maintenance Plan: Retain at the stationary source an operation andmaintenance plan for all air pollution control equipment. At a minimum, the O & Mplan shall identify all air pollution control equipment and control practices and shallinclude a preventative maintenance program for the equipment and practices, adescription of (the minimum but not necessarily the only) corrective actions to betaken to restore the equipment and practices to proper operation to meet applicablepermit conditions, a description of the employee training program for properoperation and maintenance of the control equipment and practices, and the recordskept to demonstrate plan implementation.

Minn. R. 7007.0800, subps. 14 & 16(J)

Operation Changes: In any shutdown, breakdown, or deviation the Permittee shallimmediately take all practical steps to modify operations to reduce the emission ofany regulated air pollutant. The Commissioner may require feasible and practicalmodifications in the operation to reduce emissions of air pollutants. No emissionsunits that have an unreasonable shutdown or breakdown frequency of process orcontrol equipment shall be permitted to operate.

Minn. R. 7019.1000, subp. 4

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.

Minn. R. 7011.0150

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

Minn. R. 7030.0010 - 7030.0080

Inspections: The Permittee shall comply with the inspection procedures andrequirements as found in Minn. R. 7007.0800, subp. 9(A).

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

Fugitive Emissions Control Plan: The Permittee shall develop and comply with aFugitive Emissions Control Plan. The Plan may be amended by the Permittee withthe Commissioner's approval. If the Commissioner determines the Permittee is outof compliance with Minn. R. 7011.0150 or the Fugitive Emissions Control Plan, thenthe Permittee may be required by the Commissioner to amend the Control Planand/or install and operate particulate matter ambient monitors.

Minn. R. 7007.0800, subp. 2

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

Minn. R. 7007.0800, subp. 16

NOTIFICATION REQUIREMENTS hdr



09100059 - 006

Facility Name:

Permit Number:

A-3

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 yet corrected; and5. Steps taken or planned to reduce, eliminate, and prevent reoccurrence of the deviation.

Minn. R. 7019.1000, subp. 1

MONITORING REQUIREMENTS hdr

Monitoring Equipment Calibration: The Permittee shall calibrate all requiredmonitoring equipment at least once every 12 months (any requirements applying tocontinuous emission monitors are listed separately in this permit).

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

Operation of Monitoring Equipment: Unless otherwise noted in Tables A, and/or B,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.If monitoring records are required, they should reflect any such periods of processshutdown or checks of the monitoring system.

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

RECORDKEEPING REQUIREMENTS hdr

Recordkeeping: 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 recordings for continuous monitoring instrumentation, and copies of allreports required by the permit. Records must conform to the requirements listed inMinn. R. 7007.0800, subp. 5(A).

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

Recordkeeping: Maintain records describing any insignificant modifications (asrequired by Minn. R. 7007.1250, subp. 3) or changes contravening permit terms (asrequired by Minn. R. 7007.1350 subp. 2), including records of the emissionsresulting from those changes.

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

If the Permittee determines that no permit amendment or notification is requiredprior to making a change, the Permittee must retain records of all calculationsrequired under Minn. R. 7007.1200. For expiring permits, these records shall bekept for a period of five years from the date the change was made or until permitreissuance, whichever is longer. The records shall be kept at the stationary sourcefor the current calendar year of operation and may be kept at the stationary sourceor office of the stationary source for all other years. The records may be maintainedin either electronic or paper format.

Minn. R. 7007.1200, subp. 4



09100059 - 006

Facility Name:

Permit Number:

A-4

Equipment List: The Permittee shall maintain a written list of all emission units onsite that are not insignificant activities. The list shall include the type of equipment;identifying number; date of installation, modifcation, and/or reconstruction; andidentification of any applicable Standards of Performance for New StationarySources (40 CFR pt. 60) and/or National Emission Standards for Hazardous AirPollutants (40 CRF pt. 63).

Minn. R. 7007.0800, subp. 5

REPORTING REQUIREMENTS hdr

Application for Permit Amendment: If a permit amendment is needed, submit anapplication 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 - 7007.1500

For changes that do not require a permit amendment:- The Permittee shall submit a Part 1 MACT application within 30 days of startup ofany 112(j) affected source. The application shall meet the requirements of 40 CFRSection 63.53(a).- The Permittee shall submit a Part 2 MACT application within 90 days of startup ofany 112(j) affected source. The application shall meet the requirements of 40 CFRSection 63.53(b).112(j) affected source is defined in 40 CFR Section 63.51. As of permit issuance,112(j) affected sources include industrial, commercial, and institutional boilers andprocess heaters; brick and structural clay products manufacturing; clay ceramicsmanufacturing.

40 CFR Section 63.52(b)(1) and 63.52(e)(1)

Extension Requests: The Permittee may apply for an Administrative Amendment toextend 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).Performance testing deadlines from the General Provisions of 40 CFR pt. 60 andpt. 63 are examples of deadlines for which the MPCA does not have authority togrant extensions and therefore do not meet the requirements of Minn. R.7007.1400, subp. 1(H).

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

Application for Permit Reissuance: due 180 days before expiration of existingpermit.

Minn. R. 7007.0400, subp. 2

Emission Inventory Report: due on or before April 1 of each calendar year followingpermit issuance, to be submitted on a form approved by the Commissioner.

Minn. R. 7019.3000 - 7019.3100

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

PERFORMANCE TESTING REQUIREMENTS hdr

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

Minn. R. ch. 7017

General Performance Test Requirements:

Performance Tests are due as outlined in Tables A and B of the permit.See Table B for additional testing requirements.

Performance Test Notification (written): due 30 days before each Performance TestPerformance Test Plan: due 30 days before each Performance TestPerformance Test Pre-test Meeting: due 7 days before each Performance TestPerformance Test Report: due 45 days after each Performance TestPerformance Test Report - Microfiche Copy: due 105 days after each PerformanceTest

The Notification, Test Plan, and Test Report may be submitted in alternative formatas allowed by Minn. R. 7017.2018.

Minn. R. 7017.2018;Minn. R. 7017.2030, subps. 1-4;Minn. R. 7017.2035, subp. 1-2

Testing Frequency Plan: due 60 days after completion of all permit specified InitialPerformance Tests. The plan will address all of the tested units. The plan shallspecify a testing frequency using the test data and MPCA guidance. Futureperformance tests based on year (12 month), 36 month, and 60 month intervals, oras applicable, shall be required on written approval of MPCA per Minn. R.7017.2020, subp. 1.

Minn. R. 7017.2020, subp. 1

Limits set as a result of a performance test (conducted before or after permitissuance) apply until superseded as stated in the MPCA's Notice of Complianceletter granting preliminary approval. Preliminary approval is based on formal reviewof a subsequent performance test on the same unit as specified by Minn. R.7017.2025, subp. 3. The limit is final upon issuance of a permit amendmentincorporating the change.

Minn. R. 7017.2025, subp. 3

NESHAP REQUIREMENTS hdr

The Permittee shall comply with the Maximum Achievable Control Technology(MACT) Standard for Solvent Extraction for Vegetable Oil Production.

40 CFR pt. 63



09100059 - 006

Facility Name:

Permit Number:

A-5

The Permittee shall not "construct" or "reconstruct" a major source of hazardous airpollutants as defined in 40 CFR section 63.2, without first obtaining apreconstruction permit.

40 CFR Sections 63.40 to 63.44;Minn. R. 7007.3010

Comply with Subp. DDDDD, National Emission Standards for Hazardous AirPollutants for Industrial, Commercial, and Institutional Boilers and Process Heaters,as applicable by September 13, 2007 for Boilers 1, 2, and 3.

Also comply with applicable requirements of 40 CFR Part 63, Subp. A.

40 CFR DDDDD



09100059 - 006

Facility Name:

Permit Number:

A-6

Subject Item: GP 001 Solvent Extraction (Hexane) Losses

Associated Items: EU 016 DC Deck/Cyclone No 1

EU 017 DC Deck/Cyclone No 2




EU 021 Mineral Oil System

What to do Why to do itThe units in GP 001 are subject to requirements set under the preconstructionprogram required by 40 CFR pt. 63, Subpart B. As such, the units are also subjectto any applicable requirements in 40 CFR pt. 63, Subpart A, General Conditions.

40 CFR Section 63.43; Minn R. 7011.7840

EMISSION LIMITS hdr

Compliance Ratio: less than or equal to 1.00.

The Compliance Ratio = (fhap * actual solvent loss)/(0.64* allowable solvent loss)

Where, fhap = the weighted average HAP content of solvent purchased during the previous 12 operating months (volume fraction); 0.64 = average volume fraction of HAP in solvent (dimensionless); Actual solvent loss = quantity of actual solvent loss during previous 12 operating months (gallons); Allowable solvent loss = quantity of soybeans processed during the previous 12 operating months (tons) multiplied by 0.2 (gallons/ton)


GENERAL REQUIREMENTS hdr

Calculations - Compliance Ratio: By the end of each calendar month following anoperating month, calculate the compliance ratio for the previous 12 operatingmonths. This requirement does not apply during the initial startup period (i.e., thefirst 6 calendar months following initial startup). The first compliance ratio will bedetermined following the first 12 operating months after initial startup (or the 19thoperating month after initial plant startup).

An operating month is any calendar month with at least one normal operatingperiod. It does not include the initial startup period or malfunction period. A normaloperating period is defined in the proposed 40 CFR 63.2872.


By the end of each calendar month following an operating month, calculate theactual extraction solvent loss during the previous operating month. The monthlyactual extraction solvent loss is to be determined as follows:Actual Solvent Loss = SOLVb - SOLVe + SOLVr +/- SOLVa

where,SOLVb = gallons of solvent in the inventory at the beginning of the normaloperating month.SOLVe = gallons of solvent in the inventory at the end of the normal operatingmonth.SOLVr = gallons of solvent received between the beginning and ending inventorydates of the normal operating month. This includes purchased hexane and hexanerecovered from imported oil that is added to the extraction plant inventory.SOLVa = gallons of solvent added or removed from the extraction solvent inventoryduring the normal operating month. For SSM Solvent loss events, the excludedsolvent loss must be documented for the event and an estimated associatedsolvent loss must be provided.


Calculations - 12-month Rolling Sum: Calculate the 12-month rolling sum actualsolvent loss by summing the 12 most recent actual monthly solvent losses.




09100059 - 006

Facility Name:

Permit Number:

A-7

Calculations - Monthly Weighted Average HAP Content: By the end of eachcalendar month following an operating month, calculate weighted average HAPcontent (volume fraction). The monthly weighted average HAP content is to bedetermined using the following equation:

Monthly Weighted nAverage HAP Content = Sum (Receivedi * Contenti) / Total Receivedof Extraction Solvent i =1(volume fraction)

Where: Receivedi = gallons of extraction solvent received in delivery i; Contenti = volume fraction of HAP in extraction solvent delivery i; n = number of extraction solvent deliveries since the end of the previous operating month. Total received = total gallons of extraction solvent received since the end of the previous operating month.


Calculations - 12-month Weighted Average of HAP Content of Solvent Received:

12-Month Weighted 12Average of HAP Content = Sum (Receivedi * Contenti) / Total Receivedin Solvent Received i =1(volume fraction)


Calculations - Oilseed Quantity Processed: By the end of each calendar monthfollowing an operating month, calculate the monthly quantity of each oilseedprocessed by using the following equation:

Monthly Quantity of Oilseed Processed = The sum of (SEEDb - SEEDe + SEEDr+/- SEEDa)

Where: SEEDb = tons of soybeans in the inventory at the beginning of the normal operating month; SEEDe = tons of soybeans in the inventory at the end of the normal operating month SEEDr = tons of soybeans received during the normal operating month; SEEDa = tons of soybeans added or removed from the oilseed inventory during the normal operating month.


Calculations - 12-month Rolling Sum: Calculate the 12-month rolling sum of theoilseed quantity processed by summing the monthly oilseed quantity processed forthe previous 12 operating months.


Plan for Demonstrating Compliance: Develop and implement a written Plan forDemonstrating Compliance. This Plan will include:1) A detailed description of the procedures that will be followed to minimize solvent loss, at all times, including normal, startup/shutdown/malfunction (SSM), and non-operating conditions; and,2) A detailed description of the method of measurement, measurement frequency, calculations, and quality assurance/quality control plan; recordkeeping; and reporting procedures that will be followed to determine source compliance.

40 CFR Section 63.2862(b); Minn R. 7011.7840

Startup, Shutdown, and Malfunction Plan: Develop and implement a writtenStartup, Shutdown, and Malfunction (SSM) plan. At a minimum, this plan is toinclude:1) A detailed procedure for operating and maintaining the facility to minimize emissions during any SSM event, periods of non-operation associated with a SSM event, and periods of initial startup operation; and,2) A specified program of corrective action for malfunctioning process and air pollution control equipment; and,3) Specified procedures for estimating solvent loss during each such SSM event.


RECORDKEEPING REQUIREMENTS hdr

By the end of each calendar month following an operating month, record thecompliance ratio for each 12 month operating period.

40 CFR Section 63.2862(d); Minn R. 7011.7840

Upon delivery, record the volume fraction of each HAP comprising more than 1percent by volume of the solvent in each delivery of solvent, including solventrecovered from off-site oil. For purchased solvent, a Certificate of Analysisprovided by the solvent may be used to determine the average HAP content ofsolvent received. For recovered solvent from vegetable oil purchased from off-sitelocations, reasonable and sound methods for determining the HAP content shall beused.

40 CFR Section 63.2862(c); Minn R. 7011.7840



09100059 - 006

Facility Name:

Permit Number:

A-8

Recording - Solvents: By the end of each calendar month following an operatingmonth, record the following information for the previous operating month. Theserecords shall include the sum of all hexane solvents. At a minimum, these recordsare to include:1) Beginning and end dates defining the operating month;2) Extraction solvent inventories (gallons) at the beginning and end of the operating month;3) Quantity of all extraction solvent (gallons) received, purchased, and off-site recovered, during the operating month;4) Documention of the reason for and quantity estimation of all extraction solvent inventory adjustments, additions or subtractions;5) Total solvent loss during the operating month; and,6) 12-month rolling sum of the extraction solvent lost by the process (gallons).


Recording - Average HAP Content: By the end of each calendar month followingan operating month, record the following information for the average HAP contentin the extraction solvent, for the previous operating month:1) Quantity of extraction solvent purchased and delivered during the operating month;2) Concentration of each HAP exceeding 1 percent by volume in each delivery of purchased solvent;3) Average HAP content of extraction solvent received during the operating month; and,4) Weighted average HAP content of extraction solvent received during the previous 12 operating months. (This is not required during the initial startup period.)


Recording - Processed Soybean Weight: Record the tons of soybeans processedfor the operating month. At a minimum, these records are to include:1) Beginning and end dates defining the operating month;2) Inventory of each oilseed (tons) at the beginning and end of the operating month;3) Quantity of each each oilseed received at the process (tons) during the operating month;4) Documention as to reason for adjustment and estimation of the quantity of the adjustment for all oilseed inventory adjustments (additions or subtractions);5) Quantity of each oilseed processed (tons) during the operating month; and,6) 12-month rolling sum of each oilseed processed (tons). (This is not required during the initial startup period.)


Record any process modifications resulting in changes to the solvent workingcapacity.

40 CFR Section 63.2853(a); Minn R. 7011.7840

REPORTING REQUIREMENTS hdr

Submit notifications before, during, and after construction according to theschedule listed in 40 CFR Section 63.9, but not sooner than the promulgation dateof 40 CFR pt. 63, Subpart GGGG. The notifications are subject to the exceptionsnoted in 40 CFR Section 63.2860(b)(1). The application for approval ofconstruction must include a brief description of the source including the types oflisted oilseed processed, nominal operating capacity, and type of desolventizerused. The notification of actual startup shall state whether the Permittee haselected to operate under an initial startup period subject to 40 CFR Section63.2850(c)(2) and provide an estimate and justification for the anticpated durationof the initial startup period.


Notification of Deviation Report: A deviation notification report must be submitted,for each operating month, in which the compliance ratio exceeds 1.00. The reportis to be submitted by the end of the month following the calendar month in whichthe deviation occurred. This report is to include the compliance ratio comprisingthe deviation.


Periodic SSM Report: By the end of the calendar month, submit a periodic SSMreport for the previous month during which the facility has been operated under aninitial startup period or a malfunction period. This SSM report is to include anestimate of the solvent loss during the initial startup or malfunction period withsupporting documentation.


Immediate Startup, Shutdown, and Malfunction Reports: Within 2 working daysafter commencing actions inconsistent with the SSM plan, submit an ImmediateStartup, Shutdown, and Malfunction Report consisting of a telephone call orfacsimile transmission followed by a letter within 7 working days of the event. ThisSSM report is to include an estimate of the solvent loss during the SSM event withsupporting documentation.

40 CFR Section 63.2861(d); Minn R. 7011.7840



09100059 - 006

Facility Name:

Permit Number:

A-9

Subject Item: GP 002 Grain Elevator Equipment (0.005 gr/dscf)

Associated Items: CE 002 Fabric Filter - Low Temperature, i.e., T<180 Degrees F

CE 003 Fabric Filter - Low Temperature, i.e., T<180 Degrees F


EU 002 Grain Storage & Conveying

SV 002 Grain Storage & Conveying (CE 002 Fabric Filter)



What to do Why to do itEMISSION LIMITS

(All limits apply individually to each stack vent. See subject items SV 002, SV 003,and SV 004 for performance testing requirements)

hdr

Total Particulate Matter: less than or equal to 0.005 grains/dry standard cubic footusing 1-Hour Average for any process emissions from each stack vent in GP 002.

Title I Condition: BACT Limit as per 40 CFR Section52.21(j); also meets the requirements of 40 CFR60.302(b)(1) and Minn. R. 7011.1005, subp. 2

PM < 10 micron: less than or equal to 0.005 grains/dry standard cubic foot using3-hour Average for any process emissions from each stack vent in GP 002.

Title I Condition: BACT Limit as per 40 CFR Section52.21(j)

Opacity: less than or equal to 0 percent from any stack vent process emissions. 40 CFR Section 60.302(b)(2);Minn. R. 7011.1005, subp. 2

Opacity: less than or equal to 5 percent for fugitive emissions from any grainunloading station

40 CFR Section 60.302(c)(1);Minn. R. 7011.1005, subp. 2

Opacity: less than or equal to 0 percent for any fugitive emissions from grainhandling operations


OPERATING REQUIREMENTS hdr

Clean up commodities spilled on facility property, as required, to minimizeemissions to a level required with RACT

Minn. R. 7011.1005, subp. 1

Maintain air pollution control equipment in proper operating condition and utilize theair pollution control systems as designed. See GP 004 for Fabric Filterrequirements.

Minn. R. 7011.1005, subp. 1



09100059 - 006

Facility Name:

Permit Number:

A-10

Subject Item: GP 003 Grain Elevator Equipment (0.003 gr/dscf)



EU 001 Grain Truck & Rail Receiving

EU 003 Cleaning Aspirators & Cyclone

EU 004 Pod Transfer

EU 005 Hullfat Recovery System & Cyclone

SV 001 Grain Truck & Rail Receiving (CE 001 Fabric Filter)

SV 005 Cl. Asp., Pod Trans., Hullfat Rec. (CE 005 Fabric Filter)


(All limits apply individually to each emission unit. See subject items SV 001 andSV 005 for performance testing requirements)

hdr

Total Particulate Matter: less than or equal to 0.003 grains/dry standard cubic footusing 1-Hour Average for any process emissions from SV 001 and SV 005.

Title I Condition: BACT Limit as per 40 CFR Section52.21(j); also meets the requirements of 40 CFR60.302(b)(1) and Minn. R. 7011.1005, subp. 2

PM < 10 micron: less than or equal to 0.003 grains/dry standard cubic foot using3-hour Average for any process emissions from SV 001 and SV 005.


Opacity: less than or equal to 0 percent for any process emissions from SV 001and SV 005.

40 CFR Section 60.302(b)(2);Minn. R. 7011.1005, subp. 2

Opacity: less than or equal to 5 percent for fugitive emissions from any grainunloading station


Opacity: less than or equal to 0 percent for any fugitive emissions from grainhandling operations




Minn. R. 7011.1005, subp. 1


Minn. R. 7011.1005, subp. 1

Maintain total enclosure around the rail car for the entire grain receiving building bycomplete closure of all doors on both ends of the grain receiving building.


Maintain total enclosure around the grain truck for the entire grain receiving bycomplete closure of all doors on the grain receiving building.




09100059 - 006

Facility Name:

Permit Number:

A-11

Subject Item: GP 004 Fabric Filter Equipment











What to do Why to do itOPERATING REQUIREMENTS

(All requirements apply to each control equipment unit.)

hdr

The Permittee shall operate and maintain the control equipment any time that theprocess equipment that it controls is in operation.

Title I Condition: BACT Limit as per 40 CFR Section52.21(j);Minn. R. 7007.3000

Visible Emissions/Pressure Drop Monitoring: Once each day of operation of anyGP 004 fabric filter, the Permittee shall check the outlet of each operating fabricfilter during daylight hours for any visible emissions (VEs). If inclement weatherprohibits a VE check, the Permittee shall observe and record the pressure dropacross each operating fabric filter.

Title I Condition: BACT Limit as per 40 CFR Section52.21(j);Minn. R. 7007.0800, subp. 4

Install and operate a pressure differential monitoring gauge for determining thepressure drop across the baghouse. The pressure drop shall not exceed 6.0inches of water column nor be less than 0.5 inch of water column.

Title I Condition: BACT Limit as per 40 CFR Section52.21(j);Minn. R. 7007.0800, subp.4

The Permittee shall take corrective actions, as soon as possible, as based on theoperation and maintenance plan to eliminate any visible emissions and/or anypressure drops outside the permitted range specified under this subject item, fromany fabric filters.

Title I Condition: BACT Limit as per 40 CFR Section52.21(j);Minn. R. 7007.0800, subp. 2

Operate and maintain each control equipment such that it achieves a removalefficiency of each fabric filter for total PM: greater than or equal to 99.0 percentcontrol efficiency.


Operate and maintain each control equipment such that it achieves a removalefficiency of each fabric filter for PM10: greater than or equal to 99.0 percentcontrol efficiency.


Inspect each of the fabric filters quarterly, or as required by manufacturingspecifications, all components that are not subject to wear or plugging, includingstructural components, housing, ducts, and hoods. Maintain a written record of theinspection and any action resulting from the inspection.

Minn. R. 7007.0800, subps. 2, 5, & 14

Inspect each of the fabric filters quarterly, or as required by manufacturingspecifications, all components that are subject to wear or plugging. Maintain awritten record of the inspection and any action resulting from the inspection.

Minn. R. 7007.0800, subps. 2, 5, & 14

RECORDING REQUIREMENTS hdr

Recordkeeping of daily monitoring: The Permittee shall keep a daily record, thatcontains, at a minimum, the following information for each fabric filter unit:

1) Printed name of observer;2) Signature of observer;3) Date and time of observation;4) Are there any visible emissions observed from the fabric filters? ("yes" or "no")5) Stack/Vent ID number for each "yes";6) Description of investigation and corrective actions completed for each "yes";7) Weather conditions (temperature, cloud cover, wind, precipitation). or1) Pressure drop.

Minn. R. 7007.0800, subp. 5



09100059 - 006

Facility Name:

Permit Number:

A-12

Recordkeeping of corrective actions: The Permittee shall record the correctiveactions taken, as soon as possible, as based on the operation and maintenanceplan to eliminate any visible emissions and/or any pressure drops outside thepermitted range specified under this subject item, from any fabric filters.

The Permittee shall keep a record, on-site, of the corrective actions taken.

Minn. R. 7007.0800, subp. 5

Monitor and record pressure drop, for each fabric filter, once every seven days ofoperation.

Minn. R. 7007.0800, subps. 4 & 5



09100059 - 006

Facility Name:

Permit Number:

A-13

Subject Item: GP 005 VOC Losses






EU 021 Mineral Oil System

What to do Why to do itOPERATING REQUIREMENTS

(All requirements apply to each emission unit.)

hdr

Volatile Organic Compounds: less than or equal to 1361 tons/year using 12-monthRolling Sum for VOC solvent loss (after first eighteen months of operation).


During the first eighteen months of operation, the total sum VOC solvent loss shallbe less than the following values as of any given month:

Month Sum VOC Loss (tons) Month Sum VOC Loss (tons)

1 600 13 1,777 2 1,000 14 1,694 3 1,086 15 1,611 4 1,172 16 1,527 5 1,258 17 1,444 6 1,344 18 1,361 7 1,430 8 1,516 9 1,602 10 1,688 11 1,774 12 1,860


ALTERNATE OPERATING SCENARIO (2011 DEBOTTLENECKING PROJECT) hdr

Volatile Organic Compounds: less than or equal to 1032.42 tons/year using12-month Rolling Sum for VOC solvent loss. This limit is applicable the day of initialstartup of the 2011 debottlenecking project (modification to the extraction system,EU 035 or modification to EU 008).

Title I Condition: 40 CFR Section 52.21(j)(BACT Limit);Minn R. 7007.3000

The provisions of this paragraph (r)(6) apply with respect to any regulated NSRpollutant emitted from projects at existing emissions units at a major stationarysource in circumstances where there is a reasonable possibility (occurs when theowner or operator calculates the project to result in actual emissions increase of atleast 50 percent of the amount that is a significant emissions increase), that aproject that is not a part of a major modification may result in a significantemissions increase of such pollutant, and the owner or operator elects to use themethod specified in paragraphs (b)(41)(ii)( a ) through ( c ) of this section forcalculating projected actual emissions.

Title I Condition: BACT Limit as per 40 CFR Section52.21(r)(6); Minn. R. 7007.3000

Before beginning actual construction of the project, the owner or operator shalldocument and maintain a record of the following information:

( a ) A description of the project;

( b ) Identification of the emissions unit(s) whose emissions of a regulated NSRpollutant could be affected by the project; and

( c ) A description of the applicability test used to determine that the project is not amajor modification for any regulated NSR pollutant, including the baseline actualemissions, the projected actual emissions, the amount of emissions excludedunder paragraph (b)(41)(ii)( c ) of this section and an explanation for why suchamount was excluded, and any netting calculations, if applicable.

Title I Condition: 40 CFR Section 52.21(r)(6); Minn R.7007.3000

RECORDKEEPING hdr

By the end of each calendar month following an operating month, calculate thequantity of actual VOC solvent loss for the previous 12 months by using themonthly and 12 month solvent loss methods in GP 001.

Title I Condition: BACT Limit as per 40 CFR Section52.21(j);Minn. R. 7007.0800, subps. 4 & 5



09100059 - 006

Facility Name:

Permit Number:

A-14

Subject Item: GP 006 Hull Grinding/bin & Conveying; Pellet Storage/Hull Storage & Conveying



EU 009 Hull Grinding & Conveying

EU 012 Pellet Storage & Conveying

EU 013 Hull Storage & Conveying

SV 007 Hull Grinding & Conveying (CE 006 Fabric Filter)

SV 010 Pellet & Hull Storage & Conveying (CE 008 Fabric Filter)


(All limits apply individually to each emission unit. See subject items SV 007 andSV 010 for performance testing requirements)

hdr



PM < 10 micron: less than or equal to 0.005 grains/dry standard cubic foot using3-hour Average for any process emissions from each stack vent in GP 006.

Title Condition: BACT Limit as per 40 CFR Section52.21(j)

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


Fabric filters for each individual stack shall be operated at all times when theemission unit is in operation. See GP 004 for Fabric Filter requirements.




09100059 - 006

Facility Name:

Permit Number:

A-15

Subject Item: GP 008 Grain Heaters, Hot Dehuller, Flakers; Pellet Cooler; DC Decks

Associated Items: EU 006 Grain Heaters & Conveying

EU 007 Hot Dehulling

EU 008 Flakers & Conveying

EU 010 Pellet Cooler/Cyclone






EU 035 Expellers and Conveying

SV 006 Gr. Heaters, Hot Dehull., Flakers

SV 008 Pellet Cooler/Cyclone

SV 013 DC Deck/Cyclones 1 - 4

SV 027 Expeller system (included two expellers, conveying to and from expellers, and a bin)


(All limits apply individually to each emission unit. See subject items SV 006, SV008, SV 013, and SV 027 for performance testing requirements)

hdr


Title I Condition: BACT Limit as per 40 CFR Section52.21(j);also meets the requirements of Minn. R. 7011.0715,subp. 1(A)

PM < 10 micron: less than or equal to 0.013 grains/dry standard cubic foot using3-hour Average for any process emissions from each stack in GP 008.




Cyclones for each individual stack shall be operated at all times whenever theemission unit vented to that stack is in operation.


Install and maintain a monitoring device in each cyclone that will continouslymonitor for plugging of the cyclone. The monitoring devices will be connected toaudible and visible alarms to indicate plugging or failure of the probe.

Title I Condition: BACT Limit as per 40 CFR Section52.21;Minn. R. 7007.0800, subp. 14

The monitoring devices and alarm system shall be operated whenever thecorresponding cyclone is operating.

Minn. R. 7007.0800, subps. 4 & 5

Inspect each cyclone quarterly, or as required by manufacturing specifications, allcomponents that are not subject to wear or plugging, including structuralcomponents, housing, ducts, and hoods. Maintain a written record of theinspection and any action resulting from the inspection.

Minn. R. 7007.0800, subps. 2, 5, & 14

Inspect each cyclone quarterly, or as required by manufacturing specifications, allcomponents that are subject to wear or plugging. Maintain a written record of theinspection and any action resulting from the inspection.

Minn. R. 7007.0800, subps. 2, 5, & 14



09100059 - 006

Facility Name:

Permit Number:

A-16

Subject Item: GP 010 Storage Tanks

Associated Items: TK 001 Commercial Hexane

TK 002 Commercial Hexane

TK 003 Distillate Oil

TK 004 Distillate Oil

TK 006 Commercial Hexane

What to do Why to do itKeep readily accessible records showing the dimension of each individual storagevessel and an analysis showing the capacity of each individual storage vessel.

40 CFR Section 60.116b(b)



09100059 - 006

Facility Name:

Permit Number:

A-17

Subject Item: GP 015 Boilers #2 & #3

Associated Items: CE 012 Flue Gas Recirculation

CE 013 Flue Gas Recirculation

EU 032 Boiler #2 (with low-NOx burner)

EU 033 Boiler #3 (with low-NOx burner)

SV 024 Boiler #2

SV 025 Boiler #3

What to do Why to do itEMISSION LIMITS hdr

Nitrogen Oxides: less than or equal to 0.050 lbs/million Btu heat input whencombusting natural gas, using 3-hour average.


Nitrogen Oxides: less than or equal to 0.1250 lbs/million Btu heat input whencombusting distillate fuel oil, using 3-hour Average.


PM < 10 micron: less than or equal to 0.00724 lbs/million Btu heat input whencombusting natural gas.


PM < 10 micron: less than or equal to 0.020 lbs/million Btu heat input whencombusting distillate oil.


Opacity: less than or equal to 20 percent except for one 6-minute period per hour ofnot more than 27 percent opacity.

40 CFR Section 60.43c(c)


Fuel Usage: Limited to pipeline natural gas and low sulfur distillate oil. (Maximumsulfur content 0.05% by weight for distillate oil.)

Title I Condition: Limit to avoid classification as a majormodification under 40 CFR Section 52.21;Minn. R. 7007.3000

Fuel Usage: less than or equal to 5000000 gallons/year using 12-month RollingSum of #2 fuel oil to be consumed by both Boilers #2 (EU 032) and #3 (EU 033),based on a calculated 12-month rolling sum.

Title I Condition: BACT Limit as per 40 CFR Section52.21(j) (for NOx);Title I Condition: Limit to avoid classification as a majormodification under 40 CFR Section 52.21 (for SO2)

Except during start-up and shutdown, operate CE 012 at all times that EU 032 isoperating and operate CE 013 at all times that EU 033 is operating.


MONITORING REQUIREMENTS hdr

The Permittee shall obtain the supplier certifications for each delivery of distillate oilwhich specify the sulfur content in percent by weight.

Minn. R. 7007.0800, subp. 4

Record the quantity #2 fuel oil consumed for Boilers #2 and #3 (in gallons) on amonthly basis. Keep records on site.

Title I Condition: BACT Limit as per 40 CFR Section52.21(j) (for NOx);Title I Condition: Limit to avoid classification as a majormodification under 40 CFR Section 52.21 (forSO2)

SUBMITTAL AND REPORTS hdr

Fuel supplier certifications shall include:i) The name of the oil supplier; and,ii) A statement from the oil supplier that the oil sulfur content is less than or equal to 0.05 percent by weight for distillate oil.

Title I Condition: BACT Limit as per 40 CFR Section52.21;also meets the requirements of 40 CFR Section60.48c(f)

Record and maintain records of the amounts of each fuel combusted during eachmonth.

40 CFR Section 60.48c(g);Feb. 20, 1992 EPA Memo

PERFORMANCE TESTS hdr

Performance Test: due before end of each calendar 60 months starting 10/05/2006for each individual unit (EU 032 and EU 033) and allowable fuel, but not to exceed60 days after achieving the maximum production rate at which the affected facilitywill be operated to measure opacity.

For additional applicable performance test requirements see 'General PerformanceTest Requirements' in Table A, subject Item "Total Facility."

40 CFR Section 60.45c(a);MInn. R. 7017.2020, subp. 1

Performance Test: due before end of each calendar 36 months starting 10/05/2006for each individual unit (EU 032 and EU 033) and allowable fuel to measure NOx.





09100059 - 006

Facility Name:

Permit Number:

A-18

Subject Item: SV 001 Grain Truck & Rail Receiving (CE 001 Fabric Filter)

Associated Items: EU 001 Grain Truck & Rail Receiving

GP 003 Grain Elevator Equipment (0.003 gr/dscf)

What to do Why to do itPerformance Test: due before end of each calendar 60 months starting 03/04/2009to measure PM (PM to include organic condensibles).

See GP 003 for limits.


Title I Condition: BACT Limit as per 40 CFR Section52.21(j);40 CFR Section 60.303(b);40 CFR Section 60.8(a);Minn. R. 7011.1005, subp. 2

Performance Test: due before end of each calendar 36 months starting 03/04/2009to measure PM10.




Performance Test: due before end of each calendar 60 months starting 03/04/2009to measure Opacity.


For additional applicable performance test requirements see 'General PerformanceTest Requirements' in Table A, subject item "Total Facility."

40 CFR Section 60.303(b);40 CFR Section 60.8(a);Minn. R. 7011.1005, subp. 2



09100059 - 006

Facility Name:

Permit Number:

A-19

Subject Item: SV 002 Grain Storage & Conveying (CE 002 Fabric Filter)

Associated Items: EU 002 Grain Storage & Conveying


What to do Why to do itPerformance Test: due before end of each calendar 60 months starting 03/04/2009to measure PM (PM to include organic condensibles), and PM10.










09100059 - 006

Facility Name:

Permit Number:

A-20














09100059 - 006

Facility Name:

Permit Number:

A-21














09100059 - 006

Facility Name:

Permit Number:

A-22

Subject Item: SV 005 Cl. Asp., Pod Trans., Hullfat Rec. (CE 005 Fabric Filter)

Associated Items: EU 003 Cleaning Aspirators & Cyclone

EU 004 Pod Transfer

EU 005 Hullfat Recovery System & Cyclone





Title I Condition: BACT Limit as per 40 CFR 52.21(j);40 CFR Section 60.303(b);40 CFR Section 60.8(a);Minn. R. 7011.1005, subp. 2







09100059 - 006

Facility Name:

Permit Number:

A-23

Subject Item: SV 006 Gr. Heaters, Hot Dehull., Flakers

Associated Items: EU 006 Grain Heaters & Conveying

EU 007 Hot Dehulling

EU 008 Flakers & Conveying

GP 008 Grain Heaters, Hot Dehuller, Flakers; Pellet Cooler; DC Decks

What to do Why to do itPerformance Test: due before end of each calendar 60 months starting 02/28/2008to measure PM (PM to include organic condensibles) and PM10.



Minn. R. 7007.0800, subp. 4




Minn. R. 7007.0800, subp. 4



09100059 - 006

Facility Name:

Permit Number:

A-24

Subject Item: SV 007 Hull Grinding & Conveying (CE 006 Fabric Filter)

Associated Items: EU 009 Hull Grinding & Conveying

GP 006 Hull Grinding/bin & Conveying; Pellet Storage/Hull Storage & Conveying

What to do Why to do itPerformance Test: due before end of each calendar 60 months starting 10/05/2006to measure PM10.



Minn. R. 7007.0800, subp. 4



09100059 - 006

Facility Name:

Permit Number:

A-25

Subject Item: SV 008 Pellet Cooler/Cyclone

Associated Items: EU 010 Pellet Cooler/Cyclone








09100059 - 006

Facility Name:

Permit Number:

A-26

Subject Item: SV 010 Pellet & Hull Storage & Conveying (CE 008 Fabric Filter)

Associated Items: EU 012 Pellet Storage & Conveying

EU 013 Hull Storage & Conveying

GP 006 Hull Grinding/bin & Conveying; Pellet Storage/Hull Storage & Conveying




Minn. R. 7007.0800, subp. 4



09100059 - 006

Facility Name:

Permit Number:

A-27

Subject Item: SV 013 DC Deck/Cyclones 1 - 4










Minn. R. 7007.0800, subp. 4



09100059 - 006

Facility Name:

Permit Number:

A-28

Subject Item: SV 027 Expeller system (included two expellers, conveying to and from expellers, and a bin)

Associated Items: EU 035 Expellers and Conveying


What to do Why to do itInitial Performance Test: due 180 days after Initial Startup of EU 035, to measurePM (PM to include organic condensibles) and PM10.



Minn. R. 7007.0800, subp. 4



09100059 - 006

Facility Name:

Permit Number:

A-29

Subject Item: EU 011 Meal Grind, Sifter & Conveying


SV 009 Meal Grind, Sifter, Coat Bin & Conveying (CE 007 Fabric Filter)


(All limits apply individually to each emission unit.)

hdr

Total Particulate Matter: less than or equal to 0.003 grains/dry standard cubic footusing 1-Hour Average for any process emissions from SV 009.


PM < 10 micron: less than or equal to 0.003 grains/dry standard cubic foot using3-hour Average for any process emissions from SV 009.






PERFORMANCE TESTING hdr

Performance Test: due before end of each calendar 60 months starting 12/04/2007to measure PM (PM to include organic condensibles), and PM10.


Minn. R. 7017.2020, subp. 1



Minn. R. 7017.2020, subp. 1



09100059 - 006

Facility Name:

Permit Number:

A-30

Subject Item: EU 014 Meal Storage & Conveying


SV 009 Meal Grind, Sifter, Coat Bin & Conveying (CE 007 Fabric Filter)


Total Particulate Matter: less than or equal to 0.005 grains/dry standard cubic footusing 1-hour average.

Title I Condition: BACT Limit as per 40 CFR Section52.21(j);also meets the requirements of Minn. R. 7011.1005,subp. 3(D)

PM < 10 micron: less than or equal to 0.005 grains/dry standard cubic foot using3-hour average.


Opacity: less than or equal to 10 percent Minn. R. 7011.1005, subp. 3(D)

OPERATING REQUIRMENTS hdr

Fabric filters for each individual stack shall be operated at all times when theemission unit is in operation.



Minn. R. 7011.1005, subp. 1


Minn. R. 7011.1005, subp. 1



09100059 - 006

Facility Name:

Permit Number:

A-31

Subject Item: EU 015 Meal Loadout & Conveying


SV 012 Meal Loadout & Conveying (CE 010 Fabric Filter)


Total Particulate Matter: less than or equal to 0.003 grains/dry standard cubic footusing 1-hour average.

Title I Condition: BACT Limit as per 40 CFR Section52.21(j);also meets the requirements of Minn. R. 7011.1005,subp. 3(D)

PM < 10 micron: less than or equal to 0.003 grains/dry standard cubic foot using3-hour average.


Opacity: less than or equal to 10 percent Minn. R. 7011.1005, subp. 3(D)





Minn. R. 7011.1005, subp. 1

Maintain air pollution control equipment in proper operating condition and utilize theair pollution control systems as designed.

Minn. R. 7011.1005, subp. 1



09100059 - 006

Facility Name:

Permit Number:

A-32

Subject Item: EU 034 Grain Bins (3) and conveyors


SV 026 Storage Bins and Grain handling


Total Particulate Matter: less than or equal to 0.01 grains/dry standard cubic foot 40 CFR Section 60.302(b)(1)

Opacity: less than or equal to 0 percent 40 CFR Section 60.302(b)(2)

PERFORMANCE TESTING hdr

Performance Test: due before end of each calendar 60 months starting 01/16/2007to measure PM (PM to include organic condensibles).


Minn. R. 7017.2020, subp. 1



Minn. R. 7017.2020, subp. 1



Minn. R. 7011.1005, subp. 1

TABLE B: SUBMITTALSFacility Name: CHS Oilseed Processing - Fairmont

Permit Number: 09100059 - 006

08/08/11B-1

Also, where required by an applicable rule or permit condition, send to the Permit Document Coordinator notices of:- accumulated insignificant activities,- installation of control equipment,- replacement of an emissions unit, and- changes that contravene a permit term.

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

Mr. George Czerniak Air and Radiation Branch EPA Region V 77 West Jackson Boulevard Chicago, Illinois 60604

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 submittals that are required by the Acid Rain Program to:

U.S. Environmental Protection Agency Clean Air Markets Division 1200 Pennsylvania Avenue NW (6204N) Washington, D.C. 20460

Send any application for a permit or permit amendment to:

AQ Permit Document Coordinator Industrial Division Minnesota Pollution Control Agency 520 Lafayette Road North St. Paul, Minnesota 55155-4194

Unless another person is identified in the applicable Table, send all other submittals to:

AQ Compliance Tracking Coordinator Industrial Division Minnesota Pollution Control Agency 520 Lafayette Road North St. Paul, Minnesota 55155-4194

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.

TABLE B: ONE TIME SUBMITTALS OR NOTIFICATIONSFacility Name: CHS Oilseed Processing - Fairmont


08/08/11B-2

What to send When to send Portion of Facility AffectedNotification of the Actual Date of Initial Startup due 15 days after Initial Startup of EU 035. EU035

Notification of the Actual Date of Initial Startup due 15 days after Initial Startup of the 2011debottlenecking project.

EU008

Notification of the Date Construction Began due 30 days after Start Of Construction of EU035 for the 2011 debottlenecking project.

EU035

Notification of the Date Construction Began due 30 days after Start Of Construction ofmodification to EU 008 for the 2011debottlenecking project.

EU008

Notification of the Date Construction Began due 540 days after Permit Issuance. Thenotification shall be one of the following threeoptions.

- The permittee has elected not to constructthe 2011 debottlenecking project.- The permittee has elected to modify EU 008(Option 1, Flakers) for the 2011debottlenecking project.- The permittee has elected to construct EU035 (Option 2, Expellers) for the 2011debottlenecking project.

GP005

Notification due 120 days after 11/24/2004 (effective dateof 40 CFR Subp. DDDDD) for Boilers 1, 2, &3.

Total Facility

Submittal due 610 days after Initial Startup Certificationof Compliance Status. This notification shallinclude:1) name and address of owner;2) physical address of facility;3) type of oilseed type processed;4) each HAP, present in purchased solvent, inconcentrations greater than 1 percent byvolume, during the initial compliancedetermination;5) statement designating either being a majoror area source;6) compliance certification of Plan forDemonstrating Compliance and SSM ascomplete and available, procedures in Planfor Demonstrating Compliance are beingfollowed, and compliance ratio is less than orequal to 1.00.

GP001

Testing Frequency Plan due 60 days after Initial Performance Test forPM and PM10 emissions. The plan shallspecify a testing frequency based on the testdata and MPCA guidance. Futureperformance tests based on 12-month,36-month, or 60-month intervals, or asapplicable, shall be required upon writtenapproval of the MPCA.

SV027

TABLE B: RECURRENT SUBMITTALSFacility Name: CHS Oilseed Processing - Fairmont


08/08/11B-3

What to send When to send Portion of Facility AffectedQuarterly Report due 30 days after end of each calendar

quarter following Quarterly Report. Keeprecords and submit quarterly reports. Eachquarterly report shall be postmarked by the30th day following the end of the reportingperiod. The quarterly report shall include both1) the calendar dates covered in the reportingperiod, 2) a copy of all certifications of fueldeliveries for fuel oil burned during thequarter, and 3) a statement certifying that therecords of fuel supplier certificationssubmitted represent all of the fuel combustedduring the quarter.

GP015

Semiannual Deviations Report due 30 days after end of each calendarhalf-year starting 06/17/2002 . The firstsemiannual report submitted by the Permitteeshall cover the calendar half-year in which thepermit is issued. The first report of eachcalendar year covers January 1 - June 30.The second report of each calendar yearcovers July 1 - December 31. If no deviationshave occured, the Permittee shall submit thereport stating no deviations.

Total Facility

Compliance Certification due 31 days after end of each calendar yearstarting 06/17/2002 (for the previous calendaryear). The Permittee shall submit this on aform approved by the Commissioner, both tothe Commissioner and to the US EPAregional office in Chicago. This report coversall deviations experienced during the calendaryear.

Total Facility

Compliance Certification due 365 days after end of each calendar yearfollowing Notification of compliance status

GP001

APPENDIX MATERIAL Facility Name: CHS Oilseed Processing - Fairmont Permit Number: 09100059-006 Insignificant Activities Required to be Listed 1. Minn. R. 7007.1300, subp. 3(G)

Emission from a Laboratory (experimental testing and analysis conducted on a laboratory scale).

2. All other insignificant activities are not required to be listed according to Minn. R. 7007.1300, subp. 2.

Technical Support Document, Permit Action Number: 09100059-006 Page 1 of 11 Date: 8/17/2011

TECHNICAL SUPPORT DOCUMENT For

AIR EMISSION PERMIT NO. 09100059-006 This technical support document (TSD) is intended for all parties interested in the permit and to meet the requirements that have been set forth by the federal and state regulations (40 CFR § 70.7(a)(5) and Minn. R. 7007.0850, subp. 1). The purpose of this document is to provide the legal and factual justification for each applicable requirement or policy decision considered in the preliminary determination to issue the draft/proposed permit.

1. General Information 1.1 Applicant and Stationary Source Location:

Table 1. Applicant and Source Address

Stationary Source/Address/Applicant (SIC Code: 2075)

CHS Oilseed Processing - Fairmont 1833 130th St Fairmont Martin County Contact: Eric Colvin Phone: 507-238-8906

1.2 Facility Description

The total facility operating permit authorized Cenex Harvest States Cooperatives (CHS) to construct and operate a soybean processing plant in the city of Fairmont, Martin County, Minnesota. The facility receives raw soybeans and processes them to extract soybean oil.

Soybeans are received from semi-trailers and railcar. The soybeans are off-loaded into on-site grain elevators and cleaned to remove sticks, weed seeds, and dirt. After cleaning, the beans are conveyed to temporary storage bins or directly to the bean preparation building. In the preparation building, the hull of the bean is separated from the meat and the meat is rolled flat into “flakes.” The hulls are formed into pellets, conveyed to storage, and eventually sold for use as animal feed. The flakes are conveyed to the extraction building.

Inside the extraction building, the flakes are washed in an extractor with commercial grade hexane, which strips the oil from the flakes. Two process streams leave the extractor: commercial hexane-laden flakes and miscella, which is a mixture of commercial hexane, oil, and water. The meal is “desolventized” by subjecting the commercial hexane-laden meal flakes to heat. The flakes are cooled, ground, and conveyed to storage bins. The ground and desolventized meal is sold as an animal feed. The commercial hexane that is driven off of the meal is piped to the solvent recovery system for re-use.

The miscella is separated into its components – oil, commercial hexane, and water – using distillation processes. The separated oil is termed crude oil. Initially, the facility will ship crude oil to another site for refining. A refinery may eventually be constructed at the Fairmont site to process the crude oil. The emission units associated with the refinery are included in this permit.


The refining process removes gums, colors, tastes, and odorous compounds from the crude oil to produce a product typically referred to as “salad oil.” The salad oil can be further processed to produce hydrogenated oil. Hydrogen would be produced on-site from natural gas or propane.

Final products – crude oil, refined and hydrogenated oil, meal, and hulls – are shipped from the site primarily in bulk quantities via trucks and railcars. By-products are also shipped via trucks and railcars.

Ancillary facilities at the plant include a steam plant, a hydrogen plant, offices, a wastewater pretreatment system, maintenance facilities, and warehouses. The steam plant will consist of two steam generating boilers. The primary boiler fuel is natural gas. Distillate fuel oil is used as a backup fuel. 1.3 Description of the Activities Allowed by this Permit Action CHS applied for a Prevention of Significant Deterioration (PSD) Major Amendment on September 29, 2009 in accordance with Minn. R. 7007.1500. CHS is proposing to expand its oilseed processing capabilities. This expansion may occur in two phases. The first phase would involve replacing a conveyor motor and/or gear to increase the conveyor speed in the flaking area of the plant. This change would debottleneck the facility, but oil yield rates may decline. CHS is evaluating two options for the potential second phase of the debottlenecking project to restore the oil yield rates.

For Option 1, CHS would modify EU 008 by installing two new flakers in the flaking system and lengthen the existing extraction system.

For Option 2, CHS would install EU 035 (two mechanical presses, referred to as expellers or expanders) and SV 027 along with associated conveyors. The expellers would be controlled by a high-efficiency cyclone. The cyclone can be considered process equipment for air permitting since all the material collected by the cyclone is returned to the process. There are no VOC emissions from the expellers and choosing this option would require no physical modification to the existing extraction system. Higher energy costs are associated with this Option 2. This is primarily due to an increase in steam demand.

The permit amendment allows the permittee to choose only one of the two options listed above.

The facility’s existing capacity is 4,600 ton bean per day. CHS expects the facility will have a capacity of 5,280 ton bean per day after the modification. The facility projects actual throughputs of approximately 5,040 ton bean per day, 355 days per year.

The major pollutant of concern is Hexane which is a Volatile Organic Compound (VOC) and a Hazardous Air Pollutant (HAP). Hexane is the pollutant which is triggering PSD (projected actual emissions will be greater than 40 ton/yr). Particulate Matter less than 2.5 and 10 micrometers in aerodynamic diameter (PM2.5 and PM10) are also of interest because of how close the projected actual emissions are to PSD modification thresholds of 15 tons/yr for PM10 and 10 tons/yr for PM2.5.

This permit action also includes 3 permit reopenings along with a Notification of Replacement. These permit reopenings were generated from performance tests. The dates and some testing frequencies were updated (specifics can be seen in Table 6 of this TSD). The Notification of Replacement is informing the Agency that emissions from EU 014 will be rerouted from CE 009


(SV 011) to CE 007 (SV 009). This change is to improve operations. Both fabric filters are required to achieve 99% control. CE 007 is sized to accommodate the additional airflow. There will be no increase in air emissions from this change.

1.4. Facility Emissions: Table 2. Title I Emissions Increase Summary for Expellers

Pollutant

Emissions Increase for

Flakers Option**

(tpy)

Emissions Increase for

Expellers Option**

(tpy)

PSD/112(g) Significant Thresholds for major sources

(tpy)

NSR/ 112(g) Review

Required? (Yes/No)

PM 12.9 21.4 25 No PM10 7.5 11.2 15 No PM2.5 6.2 8.8 10 No NOx 9.7 13.2 40 No SO2 4.1 5.7 40 No CO 6.5 8.9 100 No

Ozone (VOC) 526.2 526.3 40 Yes Lead 0.0002 0.0003 0.6 No

Individual HAP

526.2 526.3

**This does not include any limits – it’s the unlimited emissions increase.

Table 3. Facility Classification

Classification Major/Affected Source

Synthetic Minor Minor

PSD X Part 70 Permit Program X

Part 63 NESHAP X

2. Regulatory and/or Statutory Basis

New Source Review

The facility is an existing major source under New Source Review regulations and the proposed modification is subject to PSD. An Endangered Species Act (ESA) determination was required. The EPA has determined that this modification will have no affects on any threatened or endangered species present in Fairmont County and no further consultation is required for this project. More information is available in Attachment 5 of this TSD. A Best Available Control


Technology (BACT) analysis was also required for this permit amendment and can be seen in Attachment 4 of this TSD.

Part 70 Permit Program

The facility is a major source under the Part 70 permit program.

New Source Performance Standards (NSPS)

There are no New Source Performance Standards newly applicable to the operations at this facility because of this permit amendment.

National Emission Standards for Hazardous Air Pollutants (NESHAP)

There are no newly applicable major source or area source NESHAPs that apply to the facility because of this amendment. The facility is subject to CFR pt. 40 subp. DDDDD & GGGG (National Emission Standard for Hazardous Air Pollutants: for industrial, commercial, and institutional boilers and process heater & Solvent extraction for vegetable oil production).

Compliance Assurance Monitoring (CAM)

CAM does not apply to the modification allowed in this permit amendment, because compliance with applicable limits is not achieved through the use of add-on control equipment.

Environmental Review

The Permittee completed an Environmental Assessment Worksheet (EAW) for its original permit. Permit number 09100059-001 had a limit of 1361 ton/yr of VOC loss. This permit action is decreasing that limit to 1032.42 ton/yr. Per Minn. R. 4410.4600 subp. 2(E) an EAW is not needed. This topic was discussed with other MPCA staff members Bill Lynott and Kevin Kain who agree with this assessment.

Air Emissions Risk Analysis (AERA)

An AERA is not needed for this permit amendment. An AERA was performed for the facility’s first permit (permit #09100059-001). Permit #09100059-001 had a limit of 1361 tons/yr of VOC loss. This permit action (#09100059-006) the Permittee is proposing to lower that VOC limit to 1032.42 ton/yr. This decision was confirmed in a meeting on 8/2/10 with Jake Swaggert, Steve Pak, Heather Magee-Hill, and Shelly Burman all of the MPCA.


Prevention of Significant Deterioration (PSD) for carbon dioxide equivalent (CO2e) On 1/2/11, PSD requirements apply to sources’ greenhouse gas (GHG) emissions if the sources are subject to PSD due to their non-GHG emissions. The applicability requirements of PSD apply to projects that increase net GHG emissions by at least 75,000 tpy CO2e – but only if the project also significantly increases emissions of at least one non-GHG pollutant. CHS will not be increasing CO2e emissions more than 75,000 tpy as can be seen in Attachment 1.

Minnesota State Rules

Portions of the modification at the facility are subject to the following Minnesota Standards of Performance:

• Minn. R. 7011.0715 Standards of Performance for Post-1969 Industrial Process Equipment

Table 5. Regulatory Overview of Units Affected by the Modification/Permit Amendment

Level* Applicable Regulations Comments: FC 40 CFR Section 52.21(r)(2)

and Minn. R. 7007.3000 Authorization to construct will expire after 18 months per CFR Section 52.21.

GP 005 Title I Condition: BACT Limit as per 40 CFR Section 52.21(j)

CHS triggered PSD with permit #09100059-001 therefore has BACT limits. The old VOC limit is 1361 ton/year and the new limit is 1032.42 tons/year. The new limit will apply if the permittee chooses to proceed with the debottlenecking project.

GP 005 Title I Condition: BACT Limit as per 40 CFR Section 52.21(r)(6)

Recordkeeping requirements for any regulated NSR pollutant that actual emissions exceed 50% of the PSD definition of a significant emissions increase. As seen in the calculations PM, PM10, and PM2.5 are all over the 50% threshold.

SV 027 Minn. R. 7007.0800, subp. 4 Monitoring of new stack vent to assure calculations are accurate and emission limits are met.

Table 6. Summary of Permit Amendment Changes

Level* Applicable Regulations Comments:


Level* Applicable Regulations Comments: GP 005 Title I Condition: 40 CFR

Section 52.21 & Minn. R. 7007.3000

Added notification requirement to inform the Agency if and when construction is started for the debottlenecking project. This requirement also requires notification of initial startup and what units are being modified or constructed, if construction does take place. This requirement can also be complied with by notifying the Agency that the project will not be constructed.

GP 005 Title I Condition: BACT Limit as per 40 CFR Section 52.21(r)(6)

Added recordkeeping requirements for any regulated NSR pollutant that actual emissions exceed 50% of the PSD definition of a significant emissions increase.

GP 003 SV 001 SV 005

Title I Condition: BACT Limit as per 40 CFR 52.21(j); 40 CFR Section 60.303(b); 40 CFR Section 60.8(a); Minn. R. 7011.1005, subp. 2

Updated the starting date for performance testing from 3/18/04 to 3/4/09. Requirements were moved from GP level to SV because of different testing frequencies.

GP 002 SV 002 SV 003 SV 004

Title I Condition: BACT Limit as per 40 CFR Section 52.21(j); 40 CFR Section 60.303(b); 40 CFR Section 60.8(a); Minn. R. 7011.1005, subp. 2

Updated the starting date for performance testing. Also moved this requirement out of GP 002 to SV level. This move was done because SV 004 in GP 002 is not on the same testing frequency.

GP 002 SV 002 SV 003 SV 004

40 CFR Section 60.303(b); 40 CFR Section 60.8(a); Minn. R. 7011.1005, subp. 2

Updated the starting date for performance testing. Also moved this requirement out of GP 002 to SV level. This move was done because SV 004 in GP 002 is not on the same testing schedule.

GP 008 SV 006

Minn. R. 7007.0800, subp. 4

Removed performance testing requirements out of GP 008 for SV 006 and placed at SV level. Testing within group was not on the same date.

SV 008 Title I Condition: BACT Limit as per 40 CFR Section 52.21(j); 40 CFR Section 60.303(b); 40 CFR Section 60.8(a); Minn. R. 7011.1005, subp. 2

Added performance testing for SV 008 from a reopening. Last test was 3/4/09 for PM10, testing every 60 months. Testing within group was not on the same schedule.

GP 006 SV 007 SV 010

Minn. R. 7007.0800, subp. 4 Moved performance test for PM10 requirement out of GP006 to SV level since testing within group was not on the same schedule.

SV 013 Minn. R. 7007.0800, subp. 4 Added a testing frequency of every 60 months for PM10 starting 10/5/06 from a reopening. Testing within group was not on the same schedule.

GP 015 SV 024 SV 025

40 CFR Section 60.45c(a); MInn. R. 7017.2020, subp. 1 & Title I Condition: BACT Limit as per 40 CFR Section 52.21(j)

Updated the performance testing dates from a reopening from 3/18/04 to 10/5/06.


Level* Applicable Regulations Comments: EU 011 SV 009

Minn. R. 7017.2020, subp. 1

Updated performance testing reference dates for stack testing requirements.

EU 034 SV 026

Minn. R. 7017.2020, subp. 1

Updated performance testing reference dates for stack testing requirements.

EU 022 EU 028 EU 029 EU 030 EU 031 SV 015 SV 020 SV 021 SV 022 SV 023 CE 014 CE 011 TNK 005 GP 014

40 CFR Section 52.21 Units were never constructed. Items removed due to expiration of 18 month time frame to construct. Permit clean up.

GP 004 EU 014 CE 009 CE 007 SV 011 SV 009

Minn. R. 7007.1500(C) CHS submitted a notification in accordance with Minn. R. 7007.1500 notifying the agency that emissions from EU 014 were going to be moved from CE 009 (SV 011) to CE 007 (SV 009). No decrease in control equipment will result and there will be no increase in air emissions. Both CE 009 and SV 011 have been retired. CE 009 was removed from GP 004.

EU 035 NA Added unit as possible option for debottlenecking project of 2011. Either these two expellers will be installed or two new flakers (which would be a part of EU 008). PTE was updated in facility description for the addition of EU 035 (not for modifying EU 008).

SV 027 NA Added stack for EU 035. GP 008 NA EU 035 and SV 027 were added to GP 008. *Where the requirement appears in the permit (e.g., EU, SV, GP, etc.). The language 'This is a state-only requirement and is not enforceable by the U.S. Environmental Protection Agency (EPA) Administrator and citizens under the Clean Air Act' refers to permit requirements that are mandated by state law rather than by the federal Clean Air Act. The language is to clarify the distinction between permit conditions that are required by federal law and those that are required by state law. State law requirements are not enforceable by the EPA or by citizens under the federal Clean Air Act, but are fully enforceable by the MPCA and citizens under provisions of state law.

3. Technical Information


Notification of Option This permit amendment allows the permittee to choose between two debottlenecking options. The permittee must submit a notification to the MPCA within 18 months of permit issuance indicating one of the following 3 choices: - The permittee has elected not to construct the 2011 debottlenecking project. - The permittee has elected to modify EU 008 (Option 1, Flakers) for the 2011 debottlenecking project. - The permittee has elected to construct EU 035 (Option 2, Expellers) for the 2011 debottlenecking project. PSD Class I Area Based on EPA’s visibility screening-level models, the proposed modification, and the facility as a whole, will have no modeled impact on nearby Class I areas. EPA’s VISCREEN model was used to perform the enclosed Level 1 analyses for the Rainbow Lake Wilderness Area. Please see Attachment 6 – Enclosure A for the VISCREEN model output. The nearest Class I areas are: -Rainbow Lake Wilderness Area, WI, located approximately 392 km from CHS Fairmont and -Boundary Waters Canoe Area Wilderness, MN, located approximately 501 km from CHS Fairmont. Allowable facility particulate and NOx emissions were entered into VISCREEN. All emission rates are based on BACT limits and maximum stack exhaust flowrates, with the exception of the proposed SV 027 expeller emissions which are based on PTE. Detailed allowable emission calculations for each stack are included in Attachment 1. All of EPA’s VISCREEN Level 1 default settings were selected such as background ozone concentration, meteorological stability class, and wind speed. All visual effects predicted by VISCREEN for CHS Fairmont round to 0.000. Emission Calculations The calculations for this amendment use test results to quantify the emissions increase. As can be seen in Attachment 1 to this TSD, the emission factors are referenced.

3.1 Emissions Increase Analysis Attachment 1 to this TSD contains detailed spreadsheets and supporting information prepared by the MPCA and the Permittee. The attachment contains the projected actual emission calculations for this modification. This demonstrates that this modification is a major modification for PSD for VOCs. Also included in Attachment 1 are the GHG calculations which show, for either construction option, that the modification is below the 75,000 ton/yr of significant emission rate set by the EPA for CO2e.


3.2 Periodic Monitoring In accordance with the Clean Air Act, it is the responsibility of the owner or operator of a facility to have sufficient knowledge of the facility to certify that the facility is in compliance with all applicable requirements.

In evaluating the monitoring included in the permit, the MPCA considers the following:

• The likelihood of violating the applicable requirements; • Whether add-on controls are necessary to meet the emission limits; • The variability of emissions over time; • The type of monitoring, process, maintenance, or control equipment data already

available for the emission unit; • The technical and economic feasibility of possible periodic monitoring methods; and • The kind of monitoring found on similar units elsewhere.

The table below summarizes the periodic monitoring requirements for those emission units for which the monitoring required by the applicable requirement is nonexistent or inadequate.

Table 7. Periodic Monitoring

Level* Requirement (rule basis)

Additional Monitoring

Discussion

GP 001 Compliance Ratio: < 1.0 (40 CFR Section 63 subp. GGGG)

Monthly calculations/recordkeeping of compliance ratio, emissions, purchase records, and processed soybean weight. & record keeping upon delivery of solvent containing more that 1% HAP

Calculations and record keeping requirements are sufficient periodic monitoring techniques. CHS is also required to: Plan for Demonstrating Compliance: Implement a written Plan for Demonstrating Compliance. This Plan will include: 1) A detailed description of the procedures that will be followed to minimize solvent loss, at all times, including normal, startup/shutdown/malfunction (SSM), and non-operating conditions; and, 2) A detailed description of the method of measurement, measurement frequency, calculations, and quality assurance/quality control plan; recordkeeping; and reporting procedures that will be followed to determine source compliance.

GP 005 VOC Solvent loss: < 1361 tpy (before debottlenecking project) VOC Solvent loss: < 1032.41 tpy (after debottlenecking project (40 CFR Section 52.21(j))

*Where the requirement appears in the permit (e.g., EU, SV, GP, etc.).


3.3 Insignificant Activities CHS does have operations which are classified as insignificant activities. There are State Rules listed in the Appendix to the permit which pertain to the insignificant activities. There are no new insignificant activities from this permit amendment.

Permit Organization In general, the permit meets the MPCA Delta Guidance for ordering and grouping of requirements. One area where this permit deviates slightly from Delta guidance is in the use of an alternate operating scenario. This was used because the permittee is not 100% sure the project will be constructed or how. The permittee wanted to keep operating under its current permit until startup of the modification. This can be seen in GP 005 of the permit.

3.5 Comments Received Public Notice Period: May 25, 2011 – June 23, 2011 EPA 45-day Review Period: May 27, 2011 - July 11, 2011

Comments were not received from the public during the public notice period.

Comments were not received from EPA during their review period. No changes were made to the permit during either review period.

4. Permit Fee Assessment

Attachment 3 to this TSD contains the MPCA’s assessment of Application and Additional Points used to determine the permit application fee for this permit action as required by Minn. R. 7002.0019. The permit action includes one permit application, received after the effective date of the rule (July 1, 2009). The permit includes a BACT analysis which was triggered by the modification authorized by the amendment.

5. Conclusion

Based on the information provided by CHS, the MPCA has reasonable assurance that the proposed operation of the emission facility, as described in the Air Emission Permit No. 09100059-006 and this TSD, will not cause or contribute to a violation of applicable federal regulations and Minnesota Rules.

Staff Members on Permit Team: Jake Swaggert (permit writer/engineer) Jennifer Lovett (enforcement) Marc Severin (stack testing) Toni Volkmeier (peer reviewer)


AQ File No. 758E; DQ 2859, 2308, 2267, 2639 Attachments: 1. Emissions Increase Calculation Spreadsheets

2. Facility Description and CD-01 Forms 3. Points Calculator 4. BACT Determination 5. Endangered Species Determination

Documents

Permit Applications Table · Permit Applications Table Permit Type Application ... A refinery may eventually be constructed at the ... conveying stack height was increased from 115