Technical Support Document Draft Air Emission Permit No. 04900001-101 … · 2017. 5. 1. · Technical Support Document, Permit Number: 04900001-101 Page 1 of 14 Technical Support

Technical Support Document, Permit Number: 04900001-101 Page 1 of 14

Technical Support Document For

Draft Air Emission Permit No. 04900001-101 This technical support document (TSD) is intended for all parties interested in the draft 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 permit.

1. General information

1.1 Applicant and stationary source location:

Table 1. Applicant and source address

Applicant/Address

Stationary source/Address (SIC Code: 2076 - Vegetable Oil Mills, Except Corn, Cottonseed, and Soybean)

Archer Daniels Midland Co 4666 Faries Pkwy Decatur, Illinois 62526-5630

Archer Daniels Midland Co - Red Wing 126 LaGrange St Red Wing MN 55066

Contact: Jeffrey Penman Phone: 651-267-3867

1.2 Facility description

Archer Daniels Midland Co. (ADM or Permittee) owns and operates an oilseed crushing and vegetable oil refining facility (facility) in Red Wing, Minnesota. The facility consists of emission units for oilseed receiving, storage, processing, solvent extraction/recovery, meal processing, oil refining, and steam production. The facility receives various raw oilseeds and processes them in part using hexane to extract vegetable oil. The crude vegetable oil is separated from the hexane and is further refined, stored, loaded, and shipped. The remaining solids are processed into meal by de-solventizing, drying, and cooling. The meal is stored prior to shipping to customers for animal feed. The facility emits particulate matter (PM), particulate matter less than 10 microns in size (PM10), PM less than 2.5 microns in size (PM2.5), volatile organic compounds (VOC), sulfur dioxide (SO2), carbon monoxide (CO), nitrogen oxides (NOx) and hazardous air pollutants (HAPs). PM/PM10/PM2.5 emissions are emitted from the handling and processing of the seeds, the meal system, and the refinery. PM/PM10/PM2.5, SO2, CO, NOx, and VOC emissions are emitted from the boilers. Hexane emissions (which are both VOC and HAP emissions) are released from the hexane extraction and recovery systems. The facility is a major source under federal New Source Review (NSR), the federal Operating Permit Program (40 CFR pt. 70), and federal National Emission Standards for Hazardous Air Pollutants (NESHAPs, 40 CFR pt. 63).

1.3 Description of the activities allowed by this permit action This permit action is a major permit amendment. The MPCA has a combined operating and construction permit program under Minn. R. ch. 7007, and under Minn. R. 7007.0800. Under that authority, this permit action authorizes construction. The Permittee will construct a new belt conveyor (EQUI 247), a new rail elevator leg (EQUI 248), two new belt conveyors (EQUIs 249 and 250), and will modify the enclosed drag conveyor (EQUI 246). These changes will increase the railcar loading and conveying capacity to 30,000 bushels per hour (bph). The Permittee’s overall annual throughput will not be affected by these changes and no other downstream units will be affected. Unrelated to these process changes, the Permittee will replace a dust collector (TREA 28) through this permit action.


A previously submitted permit re-opening (DQ 2384) and an administrative amendment (DQ 5033) are also incorporated into this permit action. DQ 2384 updated performance test frequency plans and DQ 5033 corrected errors in the facility description. Due to the time-sensitive nature of this project, this amendment will be issued in stages. The first stage (Stage 1) of the issuance will include the NSR portion of the permit (construction authorization and Title I requirements) while the second and final stage (Stage 2) will include the Part 70 portion of the permit (operating and periodic monitoring requirements). This effectively allows the Permittee to complete the construction-portion of this project during EPA review. The second stage (facility operation) will be issued following EPA review.

1.4 Description of notifications and applications included in this action Table 2. Notifications and applications included in this action

Date received Application/notification type and description 12/18/2008 DQ 2384 – Permit Re-opening 12/11/2014 DQ 5033 - Administrative permit amendment 2/9/2016 DQ 5482 – Major permit amendment

1.5 Facility emissions: Table 3. Title I emissions summary

Pollutant

Potential emissions increase from the modification (tpy)

NSR/112(g) Significant thresholds for major sources (tpy)

NSR/ 112(g) review required? (yes/no)

PM 10.79 25 No PM10 8.84 15 No PM2.5 6.80 10 No NOx 0.00 40 No SO2 0.00 40 No CO 0.00 100 No Ozone (VOC) 0.00 40 No Lead 0.00 0.6 No Individual HAP 0.00 10 No Total HAPs 0.00 25 No *Other emission changes during the contemporaneous period as defined by 40 CFR § 52.21, 40 CFR § 52.24 or 40 CFR pt. 51. **Carbon dioxide equivalents as defined in Minn. R. 7007.0100.

Table 4. Facility classification

Classification Major Synthetic minor/area Minor/area PSD X Part 70 Permit Program X Part 63 NESHAP X

1.6 Changes to permit

The MPCA has a combined operating and construction permit program under Minnesota Rules Chapter 7007, and under Minn. R. 7007.0800, the MPCA has authority to include additional requirements in a


permit. Under that authority, the sections below discuss the changes to the permit that were made through this permit action. 1.6.1 Seed transfer/conveying system upgrades

The Permittee will upgrade the existing seed transfer/conveying system to be able to unload up to 134 railcars in a 24-hour period and transfer to the process elevators and seed silos. To accomplish this, the Permittee will increase the conveying capacity of certain railcar receiving and storage units to 30,000 bph. These changes will not affect the facility’s overall annual throughput, affect any downstream production or increase utilization of downstream emission units.

∑ Total Facility:

o A maximum annual throughput of 578,160 tons of oilseed was used to calculate the annual PTE of STRU 4. This throughput limit did not exist in the previous permit (-003), and was added at the total facility level to make the assumptions used in calculations enforceable. Since the facility remains subject to requirements that stemmed from the 2003 Consent Decree, recordkeeping requirements for the amount of oilseed processed at the facility are already present in the permit;

o The oilseed throughput will be calculated using an oil meter that measures oil produced. This production will be correlated to the amount of grain crushed and the grain throughput will be calculated from this correlation (pounds of oil per bushel of grain or equivalent);

o Updated Compliance Ratio requirement to reflect exactly what was in the previous Consent Decree; and

o The existing permit record is incomplete and requires updating. Five requirements were added to the permit requiring submittals of supplemental information to the Title V reissuance application. Specific information required and due dates are specified in Section 6 of this permit.

∑ STRU 3: The particulate matter concentration limit was converted to mass based pound per hour limits for each pollutant (PM, PM10, and PM2.5). The Permittee will be required to conduct performance tests to assure compliance with these limits.

o The short-term throughput was increased to 171 tons per hour (10 percent increase) since the performance test showed emissions under 80 percent of the limit. Procedures for increasing throughput and performance test recordkeeping were also added as requirements.

o EU072 ‘Driveway Drag’ will be removed and replaced with EQUI 247 ‘Belt Conveyor to Process Silo’. EQUI 247 is a belt-type conveyor rated for 30,000 bph, effectively increasing the capacity. EQUI 247 will aspirate to TREA 14 (fully enclosed) and STRU 4.

∑ STRU 4: The following units were added to the facility which aspirate to STRU 4:

o EU 146 ‘Rail Elevator Leg’ will be removed and replaced with EQUI 248 ‘Rail Elevator Leg’, which is also rated for 30,000 bph. EQUI 248 will aspirate to TREA 14 (fully enclosed) and STRU 4;

o EQUI 246 (formerly EU 147) ‘Enclosed Drag Conveyor’ is currently rated at 12,000 bph but will be modified to increase capacity to 30,000 bph through installation of a new gearbox. EQUI 246 will still aspirate to TREA 14 and STRU 4; and

o EU008 and EU 073, Screw Conveyor to Tank 1000 #1 & #2 will be replaced with EQUIs 249 and 250, each rated at 30,000 bph. Both of these units will aspirate to TREA 14 and STRU 4.


∑ COMG 1 – Fabric Filter Control Equipment without Hoods (formerly 99% fabric filter control equipment): This group was renamed to clarify that emissions from equipment that vent to fabric filters in COMG 1 must be 100 percent capture with 99 percent control. Authorization to construct TREA 29 to replace TREA 28, including re-test, has been added to the permit. Flexibility language was added for replacement of fabric filters within this group. Updated citations and periodic monitoring language for fabric filter operation was also added.

∑ COMG 2 (formerly GP 002) – 89 Percent Fabric Filter Control Equipment: This group was disbanded and the requirements for each TREA in the group were moved to the individual TREA’s requirements. Each of the units in this group were control devices with capture efficiencies less than 100 percent. Annual hood evaluation requirements were added to the individual TREA. TREA 11 was the only unit in COMG 2 affected by this permit modification, so the control efficiencies for TREAs 10, 12, and 25 were carried forward and will be evaluated at permit reissuance.

∑ COMG 3 – Cyclone Control Equipment: Added cyclone (TREA 30) that controls the column dryer (EQUI 369).

1.5.2 Control equipment replacements The Flour Elevator Baghouse (formerly CE 009) will be removed and replaced by a similar fabric filter (TREA 28) as part of this permit action. The Permittee used a vendor guarantee to determine the PTE from the new unit and the controlled PTE totals were implemented as permit limits for PM, PM10, and PM2.5 at STRU 5.

1.5.3 Boilers ∑ Fuel use was restricted to pipeline natural gas only for EQUI 76 ‘Boiler #1’ except during periods

of natural gas curtailment. The Permittee certified that the unit is in the “units designed to burn gas 1 fuels” subcategory in its initial NESHAP subp. DDDDD Notice of Compliance. EQUI 76 can use fuel oil #2 during periods of natural gas curtailment only. This alternative fuel use is allowed by subp. DDDDD without changing the fuel subcategory of the unit. The Permittee must submit a notification anytime fuel oil #2 is used and must keep records of the total hours per calendar year that the unit operated during periods of gas curtailment or gas supply emergencies. Based on past use dating back to 2010, the Permittee assumes 96 percent natural gas use and 4 percent fuel oil #2 use for the purpose of calculating PTE;

∑ Performance testing requirements for particulate emissions from EQUI 76 were removed due to the new fuel restriction. Particulate emissions from natural gas combustion are minimal and the fuel restriction requirement is adequate to ensure compliance with the Minnesota indirect heating equipment limit for particulate matter of 0.6 lb/MMBtu;

∑ NESHAP subp. DDDDD requirements were added to EQUIs 76 and 78. Both units are designed to burn gas 1 subcategory fuels only, so the units are not subject to the fuel analysis, emission limit, or monitoring requirements of the subcategory. The Permittee has already completed the initial energy assessment and tune-ups on these units;

∑ Boiler #1 (EQUI 76) is equipped with oxygen trim systems, making tune-ups required every 60 months rather than annually. Boiler #2 (EQUI 78) does not have this feature and therefore is required to have annual tune-ups; and

∑ Minn. R. 7007.0800, subp. 2 has been added to the citations. This rule states that the permit shall include emissions limitations, operational requirements, and other provisions needed to ensure compliance with all applicable requirements at the time of permit issuance.


1.5.4 Uncaptured emissions ∑ Uncontrolled PM emissions from railcar unloading emission units (EQUIs 47, 81, 82, 121, 247,

and 337) were counted as fugitive emissions in the previous permit. The Clean Air Act defines fugitive emissions as "emissions that could not reasonably pass through a stack, chimney, vent, or other functionally equivalent opening”. Loading and unloading emissions do not qualify as fugitive emissions because they can be reasonably captured and are captured through the use of hoods. New STRUs were added for ‘Railcar Receiving South - Uncaptured Emissions (EQUI 260)’, ‘Barge Loadout – Uncaptured Emissions (EQUI 261)’, ‘Truck Meal Loadout – Uncaptured Emissions (EQUI 262)’, ‘Truck Receiving Pit 2 – Uncaptured Emissions (EQUI 263)’. These new EQUIs represent the former emissions from FS 002, FS 003, FS 005, and FS 009, respectively. No emission increases are authorized through this action besides those from the new units added by this permit action. Further, this change ensures that uncontrolled emissions from loading and unloading are not being double counted at the emission unit and fugitive unit levels as they were before.

∑ Previously, the ‘Barge Loadout – Uncaptured Emissions’ (EQUI 261) contained rail loadout operations. Rail loadout was pulled out and established as a new emission unit (EQUI 371) because barge and rail loadout have different standards under Minn. R. 7011.1005;

∑ The Minn. R. 7011.1005, subp. 3(A) opacity limit for fugitive emissions were removed from STRUs 2, 3, 4, 5, and 17. These opacity limits were moved to the newly created emission units for uncaptured emissions (EQUIs 260 - 263); and

∑ The hoods which are used to capture emissions aspirating to TREA 10/STRU 2, TREA 11/STRU 3, TREA 12/STRU 18, and TREA 25/STRU 17 have never been evaluated according to Minn. R. 7011.0072, and there is no further data to support a capture efficiency greater than 80 percent. Permit requirements to conduct initial hood certifications conforming to the requirements in Minn. R. 7011.0072 were added to the TREAs noted above so that the Permittee could assume a minimum capture efficiency of 80 percent. Previous PTE calculations which used capture efficiencies of 90 percent were revised to 80 percent. The Permittee is required to submit documentation (see requirement at TFAC) that reliance upon a capture efficiency of 80 percent in lieu of 90 percent in past modifications did not cause a previous modification to exceed the PSD significance thresholds.

1.5.5 Performance testing at maximum capacity Performance tests shall be conducted at worst-case conditions as defined at Minn. R. 7017.2025, subp. 3. This means that each process emitting to a tested stack should be operated at maximum capacity during testing. However, it is not always possible to identify or achieve maximum throughputs during performance testing for some operations. Therefore, language was added to some performance testing requirements to impose short-term production rates based upon operating conditions during performance test runs. The facility will conduct performance tests for particulates at STRU 3 and STRU 5 to determine short-term production limit for the new rail-receiving units.

Instructions for when short-term throughputs may be increased and by how much they may be increased are specified for when a performance test shows emissions under 80 percent of the emission limit. Short-term process throughputs for STRU 3 and STRU 5 were increased 10 percent due to their most recent respective performance tests showing their emissions under 80 percent of the limit. These throughputs may continue to be increased by this increment until maximum capacity is reached.


1.5.6 Other permit changes ∑ Migrated permit conditions to Tempo (MPCA’s new database) from Delta (the previous

database);

∑ The permit has been updated to reflect current MPCA templates and standard citation formatting;

∑ Diesel engines for fire pumps and associated stack/vents were added to the permit. The emergency generator that was previously listed as an insignificant activity was also added to the permit;

∑ Additional cleaning equipment and a boiler were added as emission units to the permit;

∑ Performance testing schedules for STRU 3, STRU 5, STRU 8, STRU 9, STRU 13, STRU 14, and STRU 23 were updated based on the most recent approved test frequency plans dated January 27, 2012 and January 16, 2015;

∑ EUs 097, 098, and 099 were permanently shut down and removed from the facility and permit following the initial startup of EU 178 (EQUI 4);

∑ Removed opacity-testing requirements from STRU 8. Opacity tests have never exceeded zero percent and the Permittee is still required to perform daily opacity checks by the Total Facility requirements;

∑ Requirements based upon the 2003 Consent Decree were clarified to reflect Consent Decree; citations were updated to reflect the requirements were established by Consent Decree and that they are Title I Conditions; and

∑ Fugitive Sources (FS002, 010, 011, 012, and 013) were removed from the permit. These mobile sources (forklifts and bobcats) are not subject to permitting under PSD and Part 70.

1.5.7 Administrative Amendment The Permittee submitted an administrative amendment on 3/7/2016 to correct errors in the facility description. The units have always been ducted to the corrected groups. They do not represent change to the facility’s PTE. The following changes were made as part of this action:

∑ EQUI 74 ‘S-N Tramco Drag to Barge Loading’ and EQUI 30 ‘S-N 24” Screw Conveyor to River’ were incorrectly listed under STRU 13 ‘Meal Grinding’ as being aspirated by TREA 20. This mistake was corrected and both units were moved to STRU 17 ‘Rail/Barge Loadout/Barge Receiving’ and TREA 25.

∑ EQUI 26 ‘Meal Screw from 24” Rev. Screw to East’ was incorrectly listed under STRU 13 ‘Meal Grinding’ as being aspirated by TREA 20. This was corrected and the unit was moved to STRU 3 ‘Railcar Receiving’ and TREA 11

∑ EQUI 29 ‘24” Reversing Screw E-W or W-E’ was incorrectly listed under STRU 13 as being aspirated by TREA 20. This was corrected and the unit was moved to STRU 5 ‘Old Flour Mill’ and TREA 17.

2. Regulatory and/or statutory basis

2.1 New source review (NSR) The facility is an existing major source under the NSR permit program. In determining the PSD applicability of the changes to the source, the Permittee calculated the limited potential emissions of the project. As shown in Table 2, the combined changes are less than the NSR significant thresholds.

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


2.3 New source performance standards (NSPS)

The Permittee has stated that no New Source Performance Standards apply to this modification.

2.4 National emission standards for hazardous air pollutants (NESHAP) The Permittee is an existing source subject to 40 CFR pt. 63, subp. DDDDD – National Emission Standards for Hazardous Air Pollutants for Major Sources: Industrial, Commercial, and Institutional Boilers and Process Heaters. This subpart applies to EQUIs 76 (Boiler #1) and 78 (Boiler #2).

The Permittee is also a major source subject to 40 CFR pt. 63, subp. GGGG—National Emission Standards for Hazardous Air Pollutants: Solvent Extraction for Vegetable Oil Production.

2.5 Compliance assurance monitoring (CAM) CAM plans were previously not prepared for any units at the facility because no single emission unit had uncontrolled emissions exceeding 100 tpy. However, if the emissions from the collection of processes exceed 100 tpy and are subject to a single emissions limit, then the collection of processes is subject to CAM. The collection of processes which vent to TREA 11/STRU 3 and TREA 28/STRU 5 are thus subject to CAM as Other PSEUs because controlled emissions from these sources are less than 100 tpy. A requirement was added to TREA 11 and TREA 28 to submit a CAM plan by 180 days after permit issuance so that the plans may be added when the Title V permit is reissued. Further analysis of CAM applicability will be necessary at reissuance based upon updated calculations.

2.6 Minnesota state rules Portions of the facility are subject to the following Minnesota Standards of Performance:

∑ Minn. R. 7011.0515 Standards of Performance for New Indirect Heating Equipment ∑ Minn. R. 7011.0715 Standards of Performance for Post-1969 Industrial Process Equipment ∑ Minn. R. 7011.1005 Standards of Performance for Dry Bulk Agricultural Commodity Facilities

Table 5. Regulatory overview of units affected by the modification/permit amendment

Subject item* Applicable regulations Rationale TFAC 1 – Total Facility

Title I Condition to avoid PSD & CAAA of 1990; Minn. R. 7007.0800, subp. 2

Limits on solvent loss, calculation and recordkeeping requirements. These requirements are a reference to legacy BACT-equivalent requirements that were negotiated in a 2003 federal Consent Decree

Title I Condition: 40 CFR §52.21(r)(6)

A reasonable possibility exists that the project may result in a significant emissions increase for PM emissions. The Permittee shall monitor the actual emissions of these pollutants and shall calculate and maintain a record of the sum of the actual and potential emissions, in tons per year, on a calendar year basis for a period of 5 years after the change.

Minn. R. 7011.0150 Minnesota Standards of Performance for Preventing Particulate Emissions from Becoming Airborne. This subpart applies to the facility in general.


Subject item* Applicable regulations Rationale

Minn. R. 7007.0500, subp. 2 and Minn. R. 7007.0800, subp. 2

Title V Application Supplement Material Submittal/Action Requirements. The Permittee shall submit individual reports containing the following information (each item below represents an individual submittal): 1) A Subject Item Details Report containing the details noted in Attachment 6 to this TSD; 2) A report that shall contain a process flow diagram (PFD) that identifies the flow of material and air emissions with sufficient specificity to identify all applicable requirements and application of emission factors. All subject items must be identified using the Tempo convention (EQUI/STRU/TREA numbers) defined in the current permit; 3) A report that shall contain updates to the calculations that address the following: a) Identify all emission units and emission points; b) Include calculations for PM2.5 emissions; c) Provide basis of emission factors and control efficiencies; d) Based on updated PTE calculations, identify controls which are subject to CAM; and e) Ensure that the updated calculations demonstrate that major source thresholds for PSD were not exceeded in the analysis for Air Permit 04900001-101. 4) A report shall address the following: a) Reassess units that qualify as insignificant activities. Any equipment which relies upon controls does not qualify as an insignificant activity; b) Subpart 4 of the insignificant activity rule may only be relied upon for an initial Part 70 application. As such, these units currently designated as insignificant activities under this subpart will need to be included as emission units in the reissuance application. Please provide all necessary equipment data and PTE calculations for these units; and c) Storage bin vents are subject to opacity limits that require site-specific compliance conditions under the Bulk Ag Rule and do not qualify as insignificant activities. 5) A report that shall contain a highlighted NESHAP for the fire pumps and emergency generator. Items 1-5 above are each their own stand-alone requirement that must be submitted separately. The due date of each submittal is specified in the permit.

COMG 1 –Fabric Filter Control Equipment without Hoods)

Title I limits to avoid major modification for 40 CFR §52.21

Minimum control efficiency requirements to keep emissions below major source thresholds. Expected control efficiencies are determined from the controlled emission rates and the estimated uncontrolled emission rates. Performance testing is required where the expected control efficiencies are greater than those listed at Minn. R. 7011.0072. Flexibility provisions were added to this group to allow for equipment replacement without obtaining an amendment provided certain criteria are met.

COMG 3 – Cyclone Control Equipment


Minimum control efficiency requirements to keep emissions below major source thresholds. Performance testing is not required because the expected control efficiencies are less than those listed at Minn. R. 7011.0072.

EQUI 76 – Boiler #1

40 CFR pt. 63, subp. DDDDD National Emission Standard for Industrial Boilers. EQUI 76 is an existing 88 MMBtu/hr boiler designed to burn gas 1 subcategory fuels only. The boiler was constructed before June 4, 2010; therefore, it is an existing source.

Minn. R. 7011.0510 Standards of Performance for Existing Indirect Heating Equipment. The boiler is limited to pipeline natural gas only except during period of curtailment, in which case fuel oil #2 is permitted. Opacity and particulate matter limits, and fuel restrictions ensure compliance with applicable limits.

EQUI 78 – Boiler #2

40 CFR pt. 63, subp. DDDDD National Emission Standard for Industrial Boilers. EQUI 78 is an existing 65 MMBtu/hr boiler designed to burn gas 1 subcategory fuels only.

Minn. R. 7011.0510 Standards of Performance for Existing Indirect Heating Equipment. The boiler is limited to pipeline natural gas only except during period of curtailment, in which case fuel oil #2 is permitted. Opacity and particulate matter limits, and fuel restrictions ensure compliance with applicable limits.


Subject item* Applicable regulations Rationale EQUI 260 – Railcar Receiving South (Uncaptured Emissions)

Minn. R. 7011.1005, subp. 3(D) Minnesota Standards of Performance for Dry Bulk Agricultural Facilities. The facility has an annual commodity throughput of more than 180,000 tons. In addition, the facility was constructed after 1/1/84. Therefore, it is subject to control (See TREA 11). Under the rule, STRU 3 is subject to a 10 percent opacity limit from the control equipment, which applies individually to each EQUI aspirating to STRU 3.

EQUI 261 - Barge Loadout (Uncaptured Emissions)


EQUI 262 - Truck Meal Loadout (Uncaptured Emissions)


EQUI 263 - Truck Receiving Pit 2 (Uncaptured Emissions)


STRU 3 – Railcar Receiving


Emission limits for PM, PM10, and PM2.5 to prevent potential emissions from exceeding major source significant modification levels.

Minn. R. 7011.1005, subp. 3(D) Minnesota Standards of Performance for Dry Bulk Agricultural Facilities. Under the rule, STRU 3 is subject to a 10 percent opacity limit from the control equipment, which applies individually to each EQUI aspirating to STRU 3.

STRU 4 – Process Elevator 1a & 1b




STRU 5 – Old Flour Mill




STRU 17 - Rail/Barge Loadout/Barge Receiving


STRU 18 - Truck Loadout


TREAs 10, 11, 12, and 25

Title I limits to avoid major modification for 40 CFR §52.21 Minn. R. 7011.0072

Minimum control efficiency requirements to keep emissions below major modification thresholds. Performance testing requirements are listed at the respective STRU level. Requirements for hood certifications and annual hood evaluations ensure that control devices used to capture emissions will be properly set up and operated.

*Location of the requirement in the permit (e.g., EQUI 1, STRU 2, 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


established only under state law and are not established under or required 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 only under state law. State law-only 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

3.1 Calculations of emissions increase analysis Attachment 1 to this TSD contains the Title I net emissions increase calculations for this modification. This demonstrates that this modification is not a major modification for PSD. The PTE of the new units aspirating to STRUs 3 and 5 is based on the emission rate (0.01 gr/dscf for PM > 2 micron) guaranteed by the fabric filter vendor (Attachment 5 to this TSD) along with the air flow rate at which the unit’s performance test was conducted. The most recent performance tests on STRUs 3 and 5 showed that PM emissions were at 0.000065 gr/dscf and 0.00034 gr/dscf, respectively. The Permittee will continue to conduct performance tests on these units to verify compliance. The PTE of the new units aspirating to STRU 4 is based off the assumed control efficiencies listed in Minn. R. 7011.0072. Uncontrolled emission factors for PM, PM10, and PM2.5 were taken from AP-42 Section 9.9, Table 9.9.1-1 for head house and grain handling. Maximum hourly emissions are based off the physical throughput capacity of each unit. The Permittee used the emission factor from AP-42 Section 9.9, Table 9.9.1-1 for grain handling for all operations, which is more conservative than the emission factors for truck and railcar receiving. The calculations are adequate to show that the project does not exceed PSD thresholds; however, to more adequately assess CAM applicability and control efficiencies, this approach should be refined for the Part 70 permit reissuance.

3.2 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 considered the following:

∑ The likelihood of the facility 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. ∑ The kind of monitoring found on similar units elsewhere.

The table below summarizes the monitoring requirements associated with this amendment. Table 6. Monitoring

Subject item* Requirement (rule basis)

What is the monitoring Why is this monitoring adequate?

TFAC 1 – Total Facility

Process Throughput


COMG 1 – Fabric Filter Control Equipment without Hoods

PM, PM10, PM2.5 control efficiency: ≥ 99 percent (Avoid major modification under 40 CFR §52.21)

Pressure drop and visible emissions monitoring

Visible emissions and pressure drop monitoring and recordkeeping are required daily. Performance testing is required at the STRU level to verify proper operation. Equipment monitoring and proper operation will provide reasonable assurance that the limit will be met.

COMG 3 – Cyclone Control Equipment

PM, PM10, PM2.5 control efficiency: ≥ 80 percent (Minn. R. 7011.1005)

Visible emissions monitoring

Visible emissions monitoring and recordkeeping are required daily. Performance testing is required at the STRU level to verify proper operation. Equipment monitoring and proper operation will provide reasonable assurance that the limit will be met.

STRU 3 - Railcar Receiving

Opacity: ≤ 10 percent from control equipment (Minn. R. 7011.1005)


The emission limit for each PM species is determined by performance testing every 60 months based on the permitted short-term throughput. Compliance with the limit is therefore ensured every 60 months. The latest performance test put the emission rate under 80 percent of the limit, making non-compliance unlikely at this time. Visible emissions monitoring and corrective action prescribed by the O&M Plan ensures compliance with the opacity limit.

PM, PM10, PM2.5: ≤ 0.317 lb/hr (Avoid major modification under 40 CFR §52.21)

Performance testing

STRU 4 – Process Elevator 1a & 1b



Operation requirements for TREA 14 (COMG 1) ensure 99 percent control with 100 percent collection along with pressure drop monitoring and recordkeeping. Proper operation of the fabric filter will provide reasonable assurance that the limit will not be exceeded. Visible emissions monitoring and corrective action prescribed by the O&M Plan ensures compliance with the opacity limit. PM: ≤ 0.512 lb/hr

PM10: ≤ 0.286 lb/hr PM2.5: ≤ 0.049 lb/hr (Avoid major modification under 40 CFR §52.21)

Performance testing

STRU 5 – Old Flour Mill



The emission limit for each PM species is determined by performance testing every 60 months based on the permitted short-term throughput. Compliance with the limit is therefore ensured every 60 months. The latest performance test put the emission rate under 80 percent of the limit, making non-compliance unlikely at this time. Visible emissions monitoring and corrective action prescribed by the O&M Plan ensures compliance with the opacity limit.

PM, PM10, PM2.5: ≤ 1.140 lb/hr (Avoid major modification under 40 CFR §52.21)

Performance testing

EQUIs 260 and 263 – Truck and Railcar Unloading (Uncaptured Emissions)

Opacity: ≤ 5 percent for fugitive emissions (Minn. R. 7011.1005, subp. 3(A))

None Receiving and load out areas are aspirated to fabric filters. The hood is evaluated against a design that should be capable of achieving upwards of 95 percent capture even though 80 percent capture is credited for the purposes of calculating PTE. The operations are enclosed and some operations also have the doors closed to ensure opacity limits are not exceeded. Best management practices of these operations will ensure that the opacity limit is not exceeded.

EQUIs 261 – Barge Unloading (Uncaptured Emissions)

Opacity: ≤ 20 percent for fugitive emissions (Minn. R.

None Receiving and load out areas are aspirated to fabric filters. The hood is evaluated against a design that should be capable of achieving upwards of 95 percent capture even though 80 percent capture is credited for the purposes of calculating PTE. The operations are enclosed and some operations also have the


7011.1005, subp. 3(C))

doors closed to ensure opacity limits are not exceeded. Best management practices of these operations will ensure that the opacity limit is not exceeded.

EQUIs 262 – Truck Meal Loadout

Opacity: ≤ 10 percent for fugitive emissions (Minn. R. 7011.1005, subp. 3(B))


EQUI 371–Railcar Loadout (Uncaptured Emissions)

Opacity: ≤ 5 percent for fugitive emissions (Minn. R. 7011.1005, subp. 3(A))


TREAs 10, 12, and 25

PM, PM10, PM2.5 control efficiency: ≥ 99 percent PM, PM10, PM2.5 capture efficiency: ≥ 80 percent (Avoid major modification under 40 CFR §52.21, Minn. R. 7007.0800, subps. 2 & 14, Minn. R. 7011.1005, subp. 1(B))

Pressure drop and visible emissions monitoring O&M requirements

Visible emissions checks are required daily. Performance testing is required at the STRU level to verify proper operation. Each control device hood must be evaluated as specified in Minn. R. 7011.0072, subp. 2(A) and must conform to the design and operating requirements listing in Minn. R. 7011.0072 and this permit.

TREA 11 PM control efficiency: ≥ 99.38 percent PM10 control efficiency: ≥ 98.89 percent PM2.5 control efficiency: ≥ 93.49 percent PM, PM10, PM2.5 capture efficiency: ≥ 80 percent (Avoid major modification under 40 CFR §52.21, Minn. R. 7007.0800, subps. 2 & 14, Minn. R. 7011.1005, subp. 1(B))

Pressure drop and visible emissions monitoring O&M requirements

Visible emissions checks are required daily. Performance testing is required at the STRU level to verify proper operation. Each control device hood must be evaluated as specified in Minn. R. 7011.0072, subp. 2(A) and must conform to the design and operating requirements listed in Minn. R. 7011.0072 and this permit.

* Location of the requirement in the permit (e.g., EQUI 1, STRU 2, etc.).

3.3 Insignificant activities ADM – Red Wing has several operations which are classified as insignificant activities under the MPCA’s permitting rules. These are listed in Appendix A to the permit. No new insignificant activities are associated with this permit action.


3.4 Permit organization In general, the permit meets the MPCA Tempo Guidance for ordering and grouping of requirements. One area where this permit deviates slightly from Tempo guidance is in the use of appendices. While appendices are fully enforceable parts of the permit, in general, any requirement that the MPCA thinks should be electronically tracked (e.g., limits, submittals, etc.), should be in the Requirements table in Tempo. The main reason is that the appendices are word processing sections and are not part of the electronic tracking system. Violation of the appendices can be enforced, but the computer system will not automatically generate the necessary enforcement notices or documents. Staff must generate these.

3.5 Comments received The MPCA plans to issue this draft permit under the provisions of Minn. R. 7007.0750, subp. 7. This rule allows the MPCA to issue permits in two stages. The requirements issued in the first stage - the Stage 1 conditions - are the portions of the draft permit that relate to the construction activities authorized by the draft permit. Examples of Stage 1 conditions include emissions limits, restrictions on hours of operation and the recordkeeping associated with that restriction, and requirements to demonstrate initial compliance. In this draft permit, many Stage 1 conditions are identified as Title I Conditions to avoid classification as a major modification and can be found in Section 5 and 6 of this permit. Stage 1 conditions are denoted in the permit requirements that apply by “[Stage 1]”.

The notice dates will be filled in after each notice is completed.

Public Notice Period: [start date] – [end date] EPA Review Period: [start date] – [end date]

4. Permit fee assessment Attachment 4 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 included limits to remain below a federal threshold (10 pts). Existing standards such as the NESHAP subp. DDDDD are not a chargeable activity. No other additional points apply.

5. Conclusion

Based on the information provided by Archer Daniels Midland Co - Red Wing the MPCA has reasonable assurance that the proposed operation of the emission facility, as described in the Air Emission Permit No. 04900001-101 and this TSD, will not cause or contribute to a violation of applicable federal regulations and Minnesota Rules. Staff members on permit team: Eric Sulita (permit engineer) Jacobe Timler (permit engineer)

Bonnie Nelson (peer reviewer) Beckie Olson (permit writing assistant) Laurie O’Brien (administrative support) Andy Place (compliance) Dan Dietrich (enforcement)

TEMPO360 Activities: IND20160001, IND20140001, IND2008001

Attachments: 1. Emissions increase calculation spreadsheets

2. Requirements development report


3. Subject item inventory/details

4. Points calculator

5. Fabric filter manufacturer information

6. AQ Subject Item Details Update Report

ATTACHMENT 1 EMISSIONS INCREASE CALCULATION SPREADSHEETS

(Available Electronically in Tempo Central File)

ADM - Red Wing (Facility No. 04900001)Table 1. CH-04a: New Source Review - Potential to Emit Calculations 1Major modification to seed transfer system, and to replace CE-009

PM PM10 PM2.5 PM PM10 PM2.5 PM PM10 PM2.5 PM PM10 PM2.5 PM PM10 PM2.5STRU 3/SV003 COMG 2/GP002 TREA 11/CE003 3,700 0.010 5 0.061 0.034 0.0058 840 578,160 99.38% 98.89% 93.49% 51.24 28.56 4.87 0.32 0.32 0.32 88.2 49.1 8.4 1.39 1.39 1.39

500 0.01 1 0.061 0.034 0.0058 840 578,160 99% 99% 99% 51.24 28.56 4.87 0.51 0.29 0.05 17.6 9.8 1.7 0.18 0.10 0.02500 0.01 1 0.061 0.034 0.0058 840 578,160 99% 99% 99% 51.24 28.56 4.87 0.51 0.29 0.05 17.6 9.8 1.7 0.18 0.10 0.02500 0.01 1 0.061 0.034 0.0058 840 578,160 99% 99% 99% 51.24 28.56 4.87 0.51 0.29 0.05 17.6 9.8 1.7 0.18 0.10 0.02500 0.01 1 0.061 0.034 0.0058 840 578,160 99% 99% 99% 51.24 28.56 4.87 0.51 0.29 0.05 17.6 9.8 1.7 0.18 0.10 0.02500 0.01 1 0.061 0.034 0.0058 840 578,160 99% 99% 99% 51.24 28.56 4.87 0.51 0.29 0.05 17.6 9.8 1.7 0.18 0.10 0.02

STRU 5/SV005 10 COMG 1/GP001 TREA 28/CE029 11 13,300 0.01 11 0.061 0.034 0.0058 340 578,160 94.50% 90.14% 42.19% 20.74 11.56 1.97 1.14 1.14 1.14 194.0 108.1 18.4 4.99 4.99 4.99

10.79 8.84 6.8025 15 10

Yes Yes Yes

EQUI # (EU #)

1 The NSR emission calculations put forth in this major permit amendment application do not account for baseline emission. The potential to emit calculations consist of two separate and unrelated projects as described in form CH-01. As ADM wishes to expedite the permit amendment process, the potential to emit from both projects are conservatively combined for comparison to the PSD Significant Level. ADM reserves the right to modify this analysis in the future to demonstrate the projects are two individual projects.

EQUIs 34, 48, 65, 89, 90, 91, 353, 354, 355, 356, 357 (EU135, EU151, EU011, EU078, EU079, EU080, EU081, EU082, EU083, EU084, EU085)

Uncontrolled Emission Factors 4

(lb/ton)Annual PTE (Controlled) 9

(tpy)Max Annual

Throughput 6

(tpy)

EQUI 247 (EU179), Belt Coveyor to Process Silo

Max Hourly Throughput 5

(tph)

EQUI 246 (EU147), Enclosed Drag Conveyor

EQUIs 47, 81, 82, 121, 337 (EU152, EU070, EU071, EU003, EU127)

Annual PTE (Uncontrolled) 8

(tpy)Hourly PTE (Controlled)

(lb/hr)Number of EU # under SV #

COMG 1/GP001 TREA 14/CE006EQUI 248 (EU180), Rail Elevator Leg

Minimum PM2.5 Pollution

Control Eff.

Hourly PTE (Uncontrolled lb/hr)

STRU #/SV # COMG #/GP # TREA #/CE #

Maximum Air Flow Rate(dscf/min)

Minimum PM Pollution Control

Eff.

Minimum PM10 Pollution Control

Eff.

Grain Loading Limit 2,3

(gr/dscf)

11 CE 009 is being replaced by TREA 28 as part of this major permit amendment application.

2 The grain loading limit for SV-003 is obtained from Air Emission Permit No. 04900001-003 Table A, page A-14 (subject item SV-003).3 The proposed grain loading limit for STRUs 3, 4, and 5 are based on CAMCORP manufacturer guarantee for the HVP Baghouse Dust Collector. The average outlet emissions will not exceed 0.01 grains per dry standard cubic foot (gr/dscf), including PM10 and PM2.5 and large by weight dry particulate matter, during the life of the media.

10 Emissions from all existing, unmodified emission units are not included in the NSR potential to emit calculations. The emission units that meet this criteria are: EU-001, EU-074, EU-075, EU-076, EU-077, EU-086, EU-149, EU-150, EU-155, EU-156, EU-157, and EU-158.

EQUI 249 (EU181), TK 1000 Belt Conveyor #1EQUI 250 (EU182), TK 1000 Belt Conveyor #2

Potential to EmitPSD Significance Level (tpy):

Under Significance Level?

8 The annual uncontrolled PTE for SV-003 and SV-005 are the sum of the annual uncontrolled PTE for the emission units associated with each SV (i.e. individual emission unit annual uncontrolled PTE multiplied by the number of emission units under each SV). For the purposes of CAM applicability, the annual uncontrolled PTE of the individual EU is compared against the CAM threshold of 100 tpy; thus, the individual emission units under SV-003 and SV-005 are not subject to CAM.

6 The plant-wide throughput is limited to 66 tons per hour on an annual average basis.7 The control efficiency for TREA 14 (STRU 4) is assumed from the efficiencies listed in Minn. R. 7011.0070.

9 Per the guidance in the EPA New Source Review Workshop Manual Section II.B.3 (October 1990), fugitive emissions are only included in potential to emit calculations for NSR if they occur at any one of the 28 named PSD source categories listed in 40 CFR 52.21(b)(1)(i)(a). As the ADM Red Wing facility does not fall into any of the 28 named PSD source categories, fugitive emissions are not included in the NSR potential to emit calculations.

4 Uncontrolled Emission factors obtained from AP-42 Section 9.9, Table 9.9.1-1 for Headhouse and grain handling (SCC 3-02-005-30), March 2003.5 STRUs 3 and 4 capacity based on a maximum design capacity of 840 tons per hour. STRU 5 capacity based on a maximum design capacity of 340 tons per hour.

STRU 4/SV004

ADM - Red Wing (Facility No. 04900001)Table 2. CH-04a: Uncaptured (Prev. Fugitive) Emission Calculations Inputs

PM PM10 PM2.5

0.061 0.034 0.005880% 80% 80%

100% 100% 100%

100% 100% 100%

Table 3. CH-04a: Uncaptured (Prev. Fugitive) Potential to Emit Emission Calculations

PM PM10 PM2.5 PM PM10 PM2.501 EQUI 260 COMG 2/GP-002 TREA 11/CE-003 80% 578,160 3.5 1.97 0.3 10.2 5.7 1.001 EQUI 260 COMG 2/GP-002 TREA 11/CE-003 80% 578,160 3.5 1.97 0.3 10.2 5.7 1.001 EQUI 260 COMG 2/GP-002 TREA 11/CE-003 80% 578,160 3.5 1.97 0.3 10.2 5.7 1.0

Parameter

Uncontrolled Emission Factors, lb/ton 1

Pollution Control Device - Capture Efficiency, % 2,3

Pollution Control Device - Capture Efficiency, % 2,3

Pollution Control Device - Capture Efficiency, % 2

SV005 (CE009) - Old Flour Mill SV 005 Performance Test Results

SV004 (CE003) - Process Elevator

SV003 (CE003) - Railcar Receiving SV 003 Performance Test Results

1 Uncontrolled Emission factors obtained from AP-42 Section 9.9, Table 9.9.1-1 for Headhouse and grain handling (SCC 3-02-005-30), March 2003.2 Capture efficiencies are listed in form GI-05A.3 Due to the 100% capture efficiency for SV-004 and SV-005, no uncaptured emission calculations are necessary in Table 3.

Captured Emissions EQUI #/EU #Emission GroupNEW Uncaptured

EQUI# COMG #/GP # TREA #/CE #

EQUI 247/EU-179 Belt Conveyor to Process Silo

Uncaptured (Prev. Fugitive) Potential to Emit 2

(tpy)Max Annual

Throughput 2

(tpy)

1 The plant-wide throughput is limited to 66 tons per hour on an annual average basis.

Uncaptured (Prev. Fugitive) Potential to Emit 2

(lb/hr)Capture Efficiency

EQUI 26/EU-127 Meal Screw from 24" Rev. Screw to EastEQUI 47/EU-152 N-S Rail Belt Conveyor

ATTACHMENT 2 REQUIREMENTS DEVELOPMENT REPORT

(Available Electronically in Tempo Central File)

Subject Item ID Requirement Citation

TFAC 1(04900001)

Compliance Ratio: Volatile Organic Compounds


TFAC 1(04900001)

Monthly Recordkeeping and Calculation of Production: By the end of each calendar month, following an operating month, for each seed type calculate and record the throughput for the previous month and the 12‐month Rolling Sum.

An operating month is any calendar month with at least one normal operating period. It does not include malfunction period. A normal operating period is defined in 40 CFR Section 63.2872.

CAAA of 1990, Minn. R. 7007.0100, subp. 7, Minn. R. 7007.0800, subps. 4‐5, Minn. R. 7007.0800, subps. 1 & 2, Minn. Stat. 116.07, subds. 4a & 9, Title I Condition: 40 CFR pt. 52

TFAC 1(04900001)

Monthly Recordkeeping of Hexane: By the end of each calendar month, following an operating month, calculate and record the hexane usage for the previous month and the 12‐month Rolling Sum.

CAAA of 1990, Minn. R. 7007.0100, subp. 7, Minn. R. 7007.0800, subps. 4‐5, Minn. R. 7007.0800, subps. 1 & 2, Minn. Stat. 116.07, subds. 4a & 9, Title I Condition: 40 CFR pt. 52

TFAC 1(04900001)

Annual Compliance Certification: due by July 1 of each calendar year for the 12‐month period beginning May 1 and ending April 30. The compliance cer fica on shall include: 1) The name and address of the Permi ee;2) The physical address of the vegetable oil produc on process;3) Each listed oilseed type processed during the 12 calendar month period covered by the report;4) Each HAP identified under 40 CFR 63.2854(a) as being present in concentrations greater than 1 percent by volume in each delivery of solvent received during the 12 calendar month period covered by the report;5) A statement designa ng the source as a major source of HAP; and6) A compliance certification to indicate whether the source was in compliance for each compliance determina on made during the 12 calendar month period covered by the report, including: a) A certification that the Permittee is following the procedures described in the plan for demonstra ng compliance; and b) A certification that the compliance ratio is less than or equal to 0.90.

CAAA of 1990, Minn. R. 7007.0100, subp. 7, Minn. R. 7007.0800, subps. 1 & 2, Minn. Stat. 116.07, subds. 4a & 9, Title I Condition: 40 CFR pt. 52

TFAC 1(04900001)

These requirements apply if a reasonable possibility (RP) as defined in 40 CFR Section 52.21(r)(6)(vi) exists that a proposed project, analyzed using the actual‐to‐projected‐actual (ATPA) test (either by itself or as part of the hybrid test at Section 52.21(a)(2)(iv)(f)) and found to not be part of a major modification, may result in a significant emissions increase (SEI). If the ATPA test is not used for the project, or if there is no RP that the proposed project could result in a SEI, these requirements do not apply to that project. The Permittee is only subject to the Preconstruction Documentation requirement for a project where a RP occurs only within the meaning of Sec on 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 permit amendment, recordkeeping, or notification may still be required by Minn. R. 7007.1150 ‐ 7007.1500.

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


TFAC 1(04900001)

Preconstruction Documentation ‐‐ Before beginning actual construction on a project, the Permittee shall document the following:

1. Project descrip on2. Iden fica on of any emission unit whose emissions of an NSR pollutant could be affected3. Pre‐change potential emissions of any affected existing emission unit, and the projected post‐change poten al emissions of any affected exis ng or new emission unit.4. A description of the applicability test used to determine that the project is not a major modification for any regulated NSR pollutant, including the baseline actual emissions, the projected actual emissions, the amount of emissions excluded due to increases not associated with the modification and that the emission unit could have accommodated during the baseline period, an explanation of why the amounts were excluded, and any creditable contemporaneous increases and decreases that were considered in the determina on.

The Permittee shall maintain records of this documentation.

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

TFAC 1(04900001)

The Permittee shall monitor the actual emissions of any regulated NSR pollutant that could increase as a result of the project and that were analyzed using the ATPA test, and the potential emissions of any regulated NSR pollutant that could increase as a result of the project and that were analyzed using potential emissions in the hybrid test. The Permittee shall calculate and maintain a record of the sum of the actual and potential (if the hybrid test was used in the analysis) emissions of the regulated pollutant, in tons per year on a calendar year basis, for a period of 5 years following resumption of regular operations after the change, or for a period of 10 years following resumption of regular operations after the change if the project increases the design capacity of or potential to emit of any unit associated with the project.

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

TFAC 1(04900001)

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 preconstruction projection and exceed the baseline actual emissions by a significant amount as listed at 40 CFR Section 52.21(b)(23). Such report shall be submitted to the Agency 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 of the Facility contact personb. The annual emissions (actual, plus potential if any part of the project was analyzed using the hybrid test) for each pollutant for which the preconstruction projection and significant emissions increase are exceeded.c. Any other information, such as an explanation as to why the summed emissions differ from the preconstruction projection.

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

TFAC 1(04900001)

Permit Appendices: This permit contains appendices as listed in the permit Table of Contents. The Permi ee shall comply with all requirements contained in the following:Appendix A: Insignificant Ac vi es and General Applicable Requirements;Appendix B: Inten onally le blank (reserved for future use);Appendix C: Solvent Loss Record; andAppendix D: Performance Test Recordkeeping Items and Test Methods. Minn. R. 7007.0800, subp. 2

TFAC 1(04900001)

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.

This permit shall not alter or affect the liability of the Permittee for any violation of applicable requirements prior to or at the time of permit issuance. Minn. R. 7007.1800, (A)(2)


TFAC 1(04900001)

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

Minn. R. 7007.0100, subp. 7(A), 7(L), & 7(M), Minn. R. 7007.0800, subp. 4, Minn. R. 7007.0800, subps. 1‐2, Minn. R. 7009.0010‐7009.0080, Minn. Stat. 116.07, subd. 4a, Minn. Stat. 116.07, subd. 9

TFAC 1(04900001)

Circumvention: Do not install or use a device or means that conceals or dilutes emissions, which would otherwise violate a federal or state air pollution control rule, without reducing the total amount of pollutant emitted. Minn. R. 7011.0020

TFAC 1(04900001)

Operation and Maintenance Plan: Retain at the stationary source an operation and maintenance plan for all air pollution control equipment. At a minimum, the O & M plan shall identify all air pollution control equipment and control practices and shall include a preventative maintenance program for the equipment and practices, a description of (the minimum but not necessarily the only) corrective actions to be taken to restore the equipment and practices to proper operation to meet applicable permit conditions, a description of the employee training program for proper operation and maintenance of the control equipment and practices, and the records kept to demonstrate plan implementation.

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

TFAC 1(04900001)

Operation Changes: In any shutdown, breakdown, or deviation the Permittee shall immediately take all practical steps to modify operations to reduce the emission of any regulated air pollutant. The Commissioner may require feasible and practical modifications in the operation to reduce emissions of air pollutants. No emissions units that have an unreasonable shutdown or breakdown frequency of process or control equipment shall be permitted to operate. Minn. R. 7019.1000, subp. 4

TFAC 1(04900001)

Fugitive Emissions: Do not cause or permit the handling, use, transporting, or storage of any material in a manner which may allow avoidable amounts of particulate matter to become airborne. Comply with all other requirements listed in Minn. R. 7011.0150. Minn. R. 7011.0150

TFAC 1(04900001)

Comply with Fugitive Emission Control Plan: The Permittee shall follow the actions and recordkeeping specified in the control plan. The plan may be amended by the Permittee with the Commissioner's approval. If the Commissioner determines the Permittee is out of compliance with Minn. R. 7011.0150 or the fugitive control plan, then the Permittee may be required to amend the control plan and/or to install and operate particulate matter ambient monitors as requested by the Commissioner.

Minn. R. 7007.0100, Minn. R. 7007.0800, subp. 2, Minn. R. 7009.0020, Minn. R. 7011.0150, Minn. Stat. 116.07, subd. 4a

TFAC 1(04900001)

Permittee shall clean up commodities spilled on the driveway and other facility property as required to minimize fugitive emissions to a level consistent with RACT and maintain air pollution control equipment in proper operating condition and utilize the air pollution control systems as designed. Comply with all other requirements listed in Minn. R. 7011.1005. Minn. R. 7011.1005

TFAC 1(04900001) Permittee may not operate or maintain a facility that creates a public nuisance. Minn. R. 7011.1010TFAC 1(04900001) Permittee must comply with the control requirements listed in Minn. R. 7011.1015. Minn. R. 7011.1015TFAC 1(04900001)

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

TFAC 1(04900001)

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

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

TFAC 1(04900001)

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 or citizens under the Clean Air Act. Minn. R. 7030.0010‐7030.0080

TFAC 1(04900001) The Permittee shall comply with the General Conditions listed in Minn. R. 7007.0800, subp. 16. Minn. R. 7007.0800, subp. 16

TFAC 1(04900001)

Visible Emission Monitoring: The permittee shall submit to the MPCA a 30‐day notification if the Permittee has to perform a Method 9 test based on periodic visible emission monitoring unless more immediate testing is required by this permit. The Method 9 test shall be conducted a minimum of 1 hour. Minn. R. 7007.0800, subp. 6


TFAC 1(04900001)

Monitoring Equipment Calibra on ‐ The Permi ee shall either:

1. Calibrate or replace required monitoring equipment every 12 months; or2. Calibrate at the frequency stated in the manufacturer's specifica ons.

For each monitor, the Permittee shall maintain a record of all calibrations, including the date conducted, and any corrective action that resulted. The Permittee shall include the calibration frequencies, procedures, and manufacturer's specifications (if applicable) in the Operations and Maintenance Plan. Any requirements applying to continuous emission monitors are listed separately in this permit. Minn. R. 7007.0800, subp. 4(D)

TFAC 1(04900001)

Operation of Monitoring Equipment: Unless noted elsewhere in this permit, monitoring a process or control equipment connected to that process is not necessary during periods when the process is shutdown, or during checks of the monitoring systems, such as calibration checks and zero and span adjustments. If monitoring records are required, they should reflect any such periods of process shutdown or checks of the monitoring system. Minn. R. 7007.0800, subp. 4(D)

TFAC 1(04900001)

Visible emissions training: The Permittee shall ensure at all times that at least one plant employee be certified in USEPA Method 9 visible emission evaluation procedures. This person will train other plant employees to perform the daily visible emissions check. Minn. R. 7007.0800, subp. 4(D)

TFAC 1(04900001)

The Permittee shall conduct visible emission checks once each operating day. If inclement weather is present, the Permittee shall record the pressure drop. Visible emissions checks are required at STRUs 2, 3, 4, 5, 8, 9, 12, 13, 14, 15, 16, 17, and 18. Minn. R. 7007.0800, subp. 4(D)

TFAC 1(04900001)

If visible emissions are observed, the Permittee shall conduct corrective actions to restore 0% opacity. Minn. R. 7007.0800, subp. 4(D)

TFAC 1(04900001)

If after exhausting all corrective actions visible emissions remain, the Permittee shall conduct a Method 9 test according to Minnesota rules. Minn. R. 7007.0800, subp. 4(D)

TFAC 1(04900001)

Performance Testing: Conduct all performance tests in accordance with Minn. R. ch. 7017 unless otherwise noted in this permit. Minn. R. ch. 7017

TFAC 1(04900001)

Performance Test No fica ons and Submi als:Performance Tests are due as outlined in this permit. Performance Test No fica on (wri en): due 30 days before each Performance TestPerformance Test Plan: due 30 days before each Performance TestPerformance Test Pre‐test Mee ng: due 7 days before each Performance TestPerformance Test Report: due 45 days a er each Performance TestPerformance Test Report ‐ Microfiche Copy: due 105 days a er each Performance Test

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

Minn. R. 7017.2018, Minn. R. 7017.2030, subps. 1‐4, Minn. R. 7017.2035, subps. 1‐2

TFAC 1(04900001)

Limits set as a result of a performance test (conducted before or after permit issuance) apply until superseded as stated in the MPCA's Notice of Compliance letter granting preliminary approval. Preliminary approval is based on formal review of 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 amendment incorporating the change. Minn. R. 7017.2025, subp. 3

TFAC 1(04900001)

If the Permittee performs a Method 9 test and the results indicate opacity readings at or above the permitted limit, the Permittee shall contact a certified third party to conduct a second Method 9 test. The results of the second Method 9 test shall be submitted to the MPCA. Minn. R. 7007.0800, subp. 4(D)

TFAC 1(04900001) All visible emissions shall be reported on the semiannual deviations report. Minn. R. 7007.0800, subp. 4(D)

TFAC 1(04900001)

Recordkeeping: Retain all records at the stationary source, unless otherwise specified within this permit, for a period of five (5) years from the date of monitoring, sample, measurement, or report. Records which must be retained at this location include all calibration and maintenance records, all original recordings for continuous monitoring instrumentation, and copies of all reports required by the permit. Records must conform to the requirements listed in Minn. R. 7007.0800, subp. 5(A). Minn. R. 7007.0800, subp. 5(C)

TFAC 1(04900001)

Recordkeeping: Maintain records describing any insignificant modifications (as required by Minn. R. 7007.1250, subp. 3) or changes contravening permit terms (as required by Minn. R. 7007.1350, subp. 2), including records of the emissions resulting from those changes. Minn. R. 7007.0800, subp. 5(B)


TFAC 1(04900001)

If the Permittee determines that no permit amendment or notification is required prior to making a change, the Permittee must retain records of all calculations required under Minn. R. 7007.1200. These records shall be kept for a period of five years from the date the change was made or until permit reissuance, whichever is longer. The records shall be kept at the stationary source for the current calendar year of operation and may be kept at the stationary source or office of the stationary source for all other years. The records may be maintained in either electronic or paper format. Minn. R. 7007.1200, subp. 4

TFAC 1(04900001)

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

At the time of notification, the Permittee shall inform the Commissioner of the cause of the shutdown and the estimated duration. The Permittee shall notify the Commissioner when the shutdown is over. Minn. R. 7019.1000, subp. 3

TFAC 1(04900001)

Breakdown Notifications: Notify the Commissioner within 24 hours of a breakdown of more than one hour duration of any control equipment or process equipment if the breakdown causes any increase in the emissions of any regulated air pollutant. The 24‐hour time period starts when the breakdown was discovered or reasonably should have been discovered by the Permittee. However, notification is not required 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 Permittee shall inform the Commissioner of the cause of the breakdown and the estimated duration. The Permittee shall notify the Commissioner when the breakdown is over. Minn. R. 7019.1000, subp. 2

TFAC 1(04900001)

Notification of Deviations Endangering Human Health or the Environment: As soon as possible after discovery, notify the Commissioner or the state duty officer, either orally or by facsimile, of any deviation from permit conditions which could endanger human health or the environment. Minn. R. 7019.1000, subp. 1

TFAC 1(04900001)

Notification of Deviations Endangering Human Health or the Environment Report: Within 2 working days of discovery, notify the Commissioner in writing of any deviation from permit conditions which could endanger human health or the environment. Include the following information in this written descrip on: 1. the cause of the devia on; 2. the exact dates of the period of the devia on, if the devia on has been corrected;3. whether or not the devia on has been corrected; 4. the an cipated me by which the devia on is expected to be corrected, if not yet corrected; and 5. steps taken or planned to reduce, eliminate, and prevent reoccurrence of the deviation. Minn. R. 7019.1000, subp. 1

TFAC 1(04900001)

Application for Permit Amendment: If a permit amendment is needed, submit an application in accordance with the requirements of Minn. R. 7007.1150 through Minn. R. 7007.1500. Submittal dates vary, depending on the type of amendment needed.

Upon adoption of a new or amended federal applicable requirement, and if there are more than 3 years remaining in the permit term, the Permittee shall file an application for an amendment within nine months of promulgation of the applicable requirement, pursuant to Minn. R. 7007.0400, subp. 3.

Minn. R. 7007.0400, subp. 3, Minn. R. 7007.1150 ‐ 7007.1500

TFAC 1(04900001)

The Permittee shall submit an application for permit reissuance : Due 180 calendar days before Permit Expiration Date. Minn. R. 7007.0400, subp. 2


TFAC 1(04900001)

Extension Requests: The Permittee may apply for an Administrative Amendment to extend a deadline in a permit by no more than 120 days, provided the proposed deadline extension meets the requirements of Minn. R. 7007.1400, subp. 1(H). Performance testing deadlines from the General Provisions of 40 CFR pt. 60 and pt. 63 are examples of deadlines for which the MPCA does not have authority to grant extensions and therefore do not meet the requirements of Minn. R. 7007.1400, subp. 1(H). Minn. R. 7007.1400, subp. 1(H)

TFAC 1(04900001)

The Permittee shall submit a semiannual deviations report : Due semiannually, by the 30th of January and July The first semiannual report submitted by the Permittee shall cover the calendar half‐year in which the permit is issued. The first report of each calendar year covers January 1 ‐ June 30. The second report of each calendar year covers July 1 ‐ December 31. If no deviations have occurred, the Permittee shall submit the report stating no deviations.

Minn. R. 7007.0800, subp. 6(A)(2)

TFAC 1(04900001)

The Permittee shall submit a compliance certification : Due annually, by the 31st of January (for the previous calendar year). The Permittee shall submit this to the Commissioner on a form approved by the Commissioner. This report covers all deviations experienced during the calendar year. Minn. R. 7007.0800, subp. 6(C)

TFAC 1(04900001)

Emission Inventory Report: due on or before April 1 of each calendar year following permit issuance, to be submitted on a form approved by the Commissioner. Minn. R. 7019.3000‐7019.3100

TFAC 1(04900001) Emission Fees: due 30 days after receipt of an MPCA bill. Minn. R. 7002.0005‐7002.0095

TFAC 1(04900001)

The Permittee shall not construct or reconstruct a major source of hazardous air pollutants as defined in 40 CFR Section 63.2, without first obtaining a preconstruction permit.

40 CFR 63.40‐44, Minn. R. 7007.3010

TFAC 1(04900001)

NESHAP subp. GGGG RequirementsCompliance Ra o: less than or equal to 1.00 for the previous 12 opera ng months. Compliance Ra o= [f * (Actual Solvent Loss)]/ 0.64*Allowable Solvent Loss] Where: f = the weighted average volume fraction of HAP in solvent received during the previous 12 opera ng months, dimensionless. 0.64 = The average volume fraction of HAP in solvent in the baseline performance data, dimensionless. Actual Solvent Loss = Quan ty of actual solvent loss during previous 12 opera ng months (gallons) Allowable Solvent Loss = [the summation of the Quantities of each of the oilseeds processed during the previous 12 operating months (tons) multiplied by their corresponding oilseed solvent loss factors].

40 CFR 63.2840(c), Minn. R. 7011.7840

TFAC 1(04900001)

Compliance Ratio Calculation: By the end of each calendar month following an operating month, calculate the compliance ratio for the previous 12 operating months. The compliance ratio must be less than or equal to 0.90.

An operating month is any calendar month with at least one normal operating period. It does not include malfunction period. A normal operating period is defined in 40 CFR Section 63.2872.

40 CFR 63.2840, CAAA of 1990, Minn. R. 7007.0100, subp. 7, Minn. R. 7007.0800, subps. 1&2, Minn. R. 7007.0800, subps. 4&5, Minn. R. 7011.7840, Minn. Stat. 116.07, subds. 4a&9, Title I Condition: 40 CFR pt. 52


TFAC 1(04900001)

Calculation‐Actual Solvent loss: By the end of each calendar month following an operating month, calculate the actual extraction solvent loss during the previous operating month using the following:

Monthly Actual Solvent (gal) = summa on from i = 1 to n (SOLVb ‐ SOLVe + SOLVr +/‐ SOLVa)

Where: SOLVb = Gallons of solvent in the inventory at the beginning of normal operating period `ì'' as determined in paragraph (a)(3) of this sec on. SOLVe = Gallons of solvent in the inventory at the end of normal operating period `ì'' as determined in 40 CFR Sec on 63.2853(a)(3). SOLVr = Gallons of solvent received between the beginning and ending inventory dates of normal opera ng period `ì'' as determined in 40 CFR 63.2853(a)(4). SOLVa = Gallons of solvent added or removed from the extraction solvent inventory during normal opera ng period `ì'' as determined in 40 CFR 63.2853(a)(5) n = Number of normal operating periods in a calendar month.

40 CFR 63.2853, Minn. R. 7011.7840

TFAC 1(04900001)

Calculation ‐ 12‐month Rolling Sum of actual solvent loss: The Permittee shall calculate the 12‐month rolling sum actual solvent loss by summing the previous 12 operating month solvent losses.

40 CFR 63.2853, Minn. R. 7011.7840

TFAC 1(04900001)

Calculation ‐ Monthly Weight Average HAP Content: By the end of each calendar month following an operating month, calculate weighted average HAP content (volume fraction). The monthly weighted average HAP content is to be determined using the following equa on: Monthly Weighted Average HAP Content of Extraction Solvent (volume fraction) = Summation from i = 1 to n (Receivedi * content)/Total Received Where: Receivedi = Gallons of extrac on solvent received in delivery `ì.'' Conten = The volume frac on of HAP in extrac on solvent delivery `ì.'' Total Received = Total gallons of extraction solvent received since the end of the previous opera ng month. n = Number of extraction solvent deliveries since the end of the previous operating month.

40 CFR 63.2854, Minn. R. 7011.7840

TFAC 1(04900001)

Calculation: 12‐month Weighted Average of HAP Content of Solvent Received using the following: 12‐Month Weighted Ave. of HAP Content in Solvent Received (Vol. Frac.) = Summation from i = 1 to 12 (Receivedi * Content)/Total Received Where Receivedi = Gallons of extraction solvent received in operating month `ì'' as determined in 40 CFR Section 63.2853(a)(4). Content = Average volume fraction of HAP in extraction solvent received in operating month `ì'' as determined in 40 CFR Section 63.2854 (b)(1) Total Received = Total gallons of extraction solvent received during the previous 12 operating months. 40 CFR 63.2854


TFAC 1(04900001)

Calculation ‐ Oilseed Quantity Processed: By the end of each calendar month following an operating month, calculate the monthly quantity of each oilseed processed by using the following equation: Monthly Quantity of Oilseed Processed = Summation from i = 1 to n (SEEDb‐ SEEDe+SEEDr +/‐ SEEDa) Where: SEEDb= Tons of oilseed in the inventory at the beginning of normal operating period `ì'' as determined in 40 CFR Section 63.2855(a)(3) SEEDe = Tons of oilseed in the inventory at the end of normal operating period `ì'' as determined in accordance with 40 CFR Section 63.2855(a)(3) SEEDr = Tons of oilseed received during normal operating period `ì'' as determined in 40 CFR Section 63.2855(a)(4) of this section. SEEDa = Tons of oilseed added or removed from the oilseed inventory during normal operating period `ì'' as determined in 40 CFR Section 63.2855(a)(5) n = Number of normal operating periods in the calendar month during which this type oilseed was processed.

40 CFR 63.2855, Minn. R. 7011.7840

TFAC 1(04900001)

Calculation ‐ 12‐Month Rolling Sum: Calculate the 12‐month rolling sum of the oilseed quantity processed by summing the monthly oilseed quantity processed for the previous 12 operating months.

40 CFR 63.2855, Minn. R. 7011.7840

TFAC 1(04900001)

Calculation ‐ Capacity Weighted Average for the VOC SLR Limit: Compliance Ratio = Actual Solvent Loss/ Summation [(Crushi)*(SLFi)] Actual Solvent Loss = Gallons of actual solvent loss during previous 12 operating months excluding any allowable losses during malfunction periods as defined in paragraph 74 of the Consent Decree. Crushi = Tons of each oil seed type "i" processed during the previous 12 operating months. SLFi = The corresponding solvent loss factor (gal/ton) for oil seed "i" as listed in Table 1 of 40 CFR Section 63.2840.

CAAA of 1990, Minn. R. 7007.0100, subp. 7, Minn. R. 7007.0800, subps. 1 & 2, Minn. Stat. 116.07, subds. 4a & 9, Title I Condition: 40 CFR pt. 52

TFAC 1(04900001)

Plan for Demonstrating Compliance: The Permittee shall develop and implement a written plan for demonstrating compliance which shall include the following:1) A detailed description of the method of measurement, measurement frequency, calculations and quality assurance/quality control plan; and2) Recordkeeping and reporting procedures that will be followed to determine source compliance.

40 CFR 63.2851(a), Minn. R. 7011.7840

TFAC 1(04900001)

Plan for Startup, Shutdown, and Malfunction (SSM): The Permittee shall develop and implement a wri en SSM plan. At a minimum, this plan is to include: 1. a detailed procedure

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Technical Support Document Draft Air Emission Permit No. 04900001-101 … · 2017. 5. 1. · Technical Support Document, Permit Number: 04900001-101 Page 1 of 14 Technical Support