Air Emission Permit No. 03700020-004 Is Issued to Ardent ... · Ardent Mills Four Mill operates a...

AIR EMISSION PERMIT NO. 03700020-004 Major Amendment

IS ISSUED TO

Ardent Mills LLC

ARDENT MILLS FLOUR MILL 2005 Vermillion Street South

Hastings, Dakota County, Minnesota 55033

The emission units, control equipment and emission stacks at the stationary source authorized in this permit amendment are as described in the Permit Applications Table.

This permit amendment supersedes Air Emission Permit No. 03700020-003, and authorizes the Permittee to operate the stationary source at the address listed above unless otherwise noted in Table A. The Permittee must comply with all the conditions of the permit. Any changes or modifications to the stationary source must be performed in compliance with Minn. R. 7007.1150 to 7007.1500. Terms used in the permit are as defined in the state air pollution control rules unless the term is explicitly defined in the permit.

Unless otherwise indicated, all the Minnesota rules cited as the origin of the permit terms are incorporated into the SIP under 40 CFR § 52.1220 and as such as are enforceable by U.S. Environmental Protection Agency (EPA) Administrator or citizens under the Clean Air Act.

Permit Type: State Permit; Limits to Avoid Part 70/Limits to Avoid NSR

Operating Permit Issue Date: December 9, 2002

Major Amendment Issue Date: September 22, 2015

Expiration Date: Permit does not expire - Title I Conditions do not expire.

Don Smith, P.E., Manager Air Quality Permits Section Industrial Division

for John Line Stine Commissioner Minnesota Pollution Control Agency

TDD (for hearing and speech impaired only): (651) 282-5332 Printed on recycled paper containing at least 10% fibers from paper recycled by consumers

Permit Applications Table

Permit Type Application Date Permit Action Total Facility Operating Permit 2/15/96 revised 11/05/01 001 Major Amendment 7/28/03 002 Administrative Amendment 6/11/07 003 Administrative Amendment 5/16/14 004 Reopening (Major Amendment) 10/31/14 004

TABLE OF CONTENTS

Notice to the Permittee

Permit Shield

Facility Description

Amendment Descriptions

Table A: Limits and Other Requirements

Table B: Submittals

Table C: Compliance Schedule - Not used in this permit

Appendices:

Appendix I: Insignificant Activities and Applicable Requirements

Appendix II: Equipment List

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:

Ardent Mills Four Mill operates a wheat flour and animal feed mill in Hastings, Minnesota. The facility consists of hardwheat mills, durum mills, durum processing, a rye mill, and associated elevator, storage, and packaging areas. Seventy-five percent of the wheat received is processed into flour and the remaining 25 percent into feed. The facility operates a boiler for heating and wheat tempering during the winter months.The facility has accepted limits on the amount of wheat to be processed, and on the amount of fumigant (methyl bromide), which may be used. These limits were federally enforceable, and resulted in the facility being a non-major source under the Part 70 permit program, New Source Review, and the National Emission Standards for Hazardous Air Pollutants program.

AMENDMENT DESCRIPTIONS:

PER002 (Major Amendment):

This amendment removed all three Particulate Matter less than 10 microns (PMi0) process throughput limits. The process throughput limits which limited PMi0 to 95 tpy were replaced by an overall facility-wide 95 tons per year (tpy) PM10 emission limit. Hence, there was no change in the PMM Potential to Emit or other pollutant emissions.

PER003 (Administrative Amendment):

This amendment added a new control equipment filter (CE036) and accounted for four new filters (CE037-040). The filters CE037-040 replaced CE013 and CE025 since both these filters were twin filters. CE013 and CE025 were both retired and the permit language, including monitoring and recordkeeping,

apply to the filters that are replacing the retired filters. CE036 has the requirements of flour storage and loading (EU007).

PER004 (Current permit action; Major Amendment):

Title I HAP limits for fugitive emission sources have been changed to 9.0 tpy for single HAPs and 20.0 tpy for total HAP. This permit action incorporates an Administrative Amendment to change the facility name from ConAgra Flour Mill - Hastings to Ardent Mills Flour Mill and the owner from ConAgra Foods to Ardent Mills LLC. In addition, recurring opacity testing for fugitive emissions was added to EU002 and EU005.

TABLE A: LIMITS AND OTHER REQUIREMENTS Facility Name: Ardent Mills Flour Mill

Permit Number: 03700020 - 004

A-1 09/21/15

Table A contains limits and other requirements with which your facility must comply. The limits are located in the first column of the table (What To do). The limits can be emission limits or operational limits. This column also contains the actions that you must take and the records you must keep to show that you are complying with the limits. The second column of Table A (Why to do it) lists the regulatory basis for these limits. Appendices included as conditions of your permit are listed in Table A under total facility requirements.

Subject Item: Total Facility

What to do Why to do it

FACILITY-SPECIFIC REQUIREMENTS hdr

This permit establishes limits on the facility to keep it a min or source under New Source Review and a nonmajor source under Part 70. The Permittee may not make any change at the source that would make the source a major source under New Source Review or Part 70 until a permit amendment has b een issued. This includes changes that might otherwise qualify as insignificant modifications and minor or moderate amendments.

Title I Condition: Avoid major source under 40 CFR 52.21 (b)(1)(i) and Minn. R. 7007.3000; Avoid major source under 40 CFR 70.2 and Minn. R. 7007.020 0

Permit Appendix: This permit contains a appendices as listed in the permit Table of Contents. The Permittee shall comply with all requirements contained in the appendices.

Minn. R. 7007.0800, subp. 2

OPERATIONAL REQUIREMENTS hdr

Circumvention: Do not install or use a device or means that conceals or dilutes emissions, which would otherwise violate a federal or sta te 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 whenever the corresponding process equipment and emission units are operated.

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

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 train ing program for proper operation and maintenance of the control equipment and practices, and the records kept to demonstrate plan implementation.

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

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

Fugitive Emissions: Do not cause or permit the handling, use, trans porting, or storage of any material in a manner which may allow avoidable amounts of particulate matter to become airborne. Comply with all other requiremen ts listed in Minn. 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 or citizens under the Clean Air Act.

Minn. R. 7030.0010 - 7030.0080

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)

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

Minn. R. 7007.0800, subp. 16

PERFORMANCE TESTING hdr

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

Minn. R. ch. 7017

TABLE A: LIMITS AND OTHER REQUIREMENTS A-2 09/21/15 Facility Name: Ardent Mills Flour Mill


Performance Test Notifications and Submittals:

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

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

The Notification, Test Plan, and Test Report may be submitted in 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

Limits set as a result of a performance test (conducted before or after permit issuance) apply until superseded as state d 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 spe cified by Minn. R. 7017.2025, subp. 3. The limit is final upon issu ance of a permit amendment incorporating the change.

Minn. R. 7017.2025, subp. 3

MONITORING REQUIREMENTS hdr

Monitoring Equipment Calibration - The Permittee shall either:

1. Calibrate or replace required monitoring equipment every 12 months; or 2. Calibrate at the frequency stated in the manufacturer's specifications.

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)

Operation of Monitoring Equipment: Unless otherwise noted in Tables A, B, and/or C, monitoring a process or control equipment connected to that process is not necessary during periods when the process is shutdown, or during checks of the monitoring systems, such as calibration checks and zero and span adjustments. I f monitoring records are required, they should reflect any such p eriods of process shutdown or checks of the monitoring system.

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

RECORDKEEPING hdr

Recordkeeping: Retain all records at the stationary source, unless otherwise specified within this permit, 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)

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)

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. For nonexpiring permits, these records shall be kept for a period of five years from the da te that the change was made. 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

REPORTING/SUBMITTALS hdr

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

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

Minn. R. 7019.1000, subp. 3



Breakdown Notifications: Notify the Commissioner within 24 hours of a breakdown of more than one hour duration of any control equipment or process equipment i f the breakdown causes any increase in the emissions of any reg ulated air pollutant. The 24-hour time period starts when the breakdown was discovered or reasonably should have been discovered by the owner or operator. However, notification is not required in the circumstances outlined in Items A, B and C of Minn. R. 7019.1000, subp. 2.

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

Minn. R. 7019.1000, subp. 2

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

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

Minn. R. 7019.1000, subp. 1

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. 7007.1150-7007.1500

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)

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

Emission Fees: due 30 days after receipt of an MPCA bill. Minn. R. 7002.0005 - 7002.0095

The Permittee must submit a Risk Management Plan (RMP) under 40 CFR pt. 68. Each owner or operator of a stationary source, at which a regulated substance is present above a threshold quantity in a process, shall design and implement an accidental release prevention program. An initial RMP must be submitted no later than the latest of the following dates: 1) June 21, 1999; 2) Three years after the date on which a regulated substance is first listed under 40 CFR Section 68.130; or 3) The date on which a regulated substance is first present above a threshold quantity in a process. A full update and resubmission of the RMP is required at least once every five years. The five-year anniversary date is reset whenever your facility fully updates and resubmits their RMP. Submit RMPs to the Risk Management Plan Reporting Center, P.O. Box 1515, Lanham-Seabrook, Maryland 20703-1515. RMP information may be obtained at http://www.epa.gov/swercepp or by calling 1-800-424-9346.

40 CFR pt. 68



A-4 09/21/15

Subject Item:

Associated Items:

GP 001

CE 001

CE 002

CE 003

CE 004

CE 005

CE 006

CE 007

CE 008

CE 009

CE 010

CE 011

CE 012

CE 014

CE 015

CE 016

CE 017

CE 018

CE 019

CE 020

CE 021

CE 022

CE 023

CE 024

CE 026

CE 027

CE 028

CE 029

CE 033

CE 034

CE 035

CE 036

CE 037

CE 038

CE 039

CE 040

Baghouses

Fabric Filter -

Fabric Filter -

Fabric Filter -

Fabric Filter -

Fabric Filter -

Fabric Filter -

Fabric Filter -

Fabric Filter -

Fabric Filter -

Fabric Filter -

Fabric Filter -

Fabric Filter -

Fabric Filter -

Fabric Filter -

Fabric Filter -

Fabric Filter -

Fabric Filter -

Fabric Filter -

Fabric Filter -

Fabric Filter -

Fabric Filter -

Fabric Filter -

Fabric Filter -

Fabric Filter •

Fabric Filter •

Fabric Filter •

Fabric Filter •

Fabric Filter -

Fabric Filter •

Fabric Filter •

Fabric Filter •

Fabric Filter •

Fabric Filter •

Fabric Filter •

Fabric Filter •

Low Temperature

Low Temperature

Low Temperature

Low Temperature

Low Temperature

Low Temperature

Low Temperature

Low Temperature

Low Temperature

Low Temperature

Low Temperature

Low Temperature

Low Temperature

Low Temperature

Low Temperature

Low Temperature

Low Temperature

Low Temperature

Low Temperature

Low Temperature

Low Temperature

Low Temperature

Low Temperature

Low Temperature

Low Temperature

Low Temperature

Low Temperature

Low Temperature

Low Temperature

Low Temperature

Low Temperature

Low Temperature

Low Temperature

Low Temperature

Low Temperature

T<180 Degrees F

T<180 Degrees F

T<180 Degrees F

T<180 Degrees F

T<180 Degrees F

T<180 Degrees F

T<180 Degrees F

T<180 Degrees F

T<180 Degrees F

T<180 Degrees F

T<180 Degrees F

T<180 Degrees F

T<180 Degrees F

T<180 Degrees F

T<180 Degrees F

T<180 Degrees F

T<180 Degrees F

T<180 Degrees F

T<180 Degrees F

T<180 Degrees F

T<180 Degrees F

( T<180 Degrees F

, T<180 Degrees F

, T<180 Degre es F

, T<180 Degre es F

, T<180 Degrees F

, T<180 Degrees F

, T<180 Degre es F

, T<180 Degre es F

, T<180 Degrees F

, T<180 Degrees F

, T<180 Degrees F

, T<180 Degrees F

, T<180 Degrees F

, T<180 Degrees F

What to do Why to do it If the Permittee replaces any existing fabric filters, adds new fabric filters, or modifies the fabric filters listed in GP 001, such equipment is subject to all of the requirements of GP 001. Prior to making such a change, the Permittee shall apply for and obtain the appropriate permit amendment, as applicable.

Title I Condition: Avoid major source under 40 CFR 52.21 (b)(1)(i) and Minn. R. 7007.3000; Avoid major source under 40 CFR 70.2 and Minn. R. 7007.0200

The Permittee shall operate and maintain each fabric filter in accordance with the Operation and Maintenance (0 & M) Plan. The Permittee shall keep copies of the 0 & M Plan available onsite for use by staff and MPCA staff. Control efficiency requirements can be found at EU 002 through EU 007.

Minn. R. 7007.0800, subps. 4, 5, and 14



Pressure Drop: greater than or equal to 0.5 inches of water column and less than or equal to 8.0 inches of water column , unless a new range is set pursuant to Minn. R. 7017.2025, subp. 3 based on the values recorded during the most recent MPCA-approved performance test where compliance was demonstrated. The new range shall be implemented upon receipt of the Notice of Compliance letter granting preliminary approval. The range is final upon issuance of a permit amendment incorporating the change.


Visible Emissions: The Permittee shall check each fabric filter stack for any visible emissions once each day of operation during daylight hours. During inclement weather, the Permittee shall read and record the pressure drop across the fabric filter, once each day of operation.

Title I Condition: Avoid major source under 40 CFR 52.21 (b)(1 )(i) and Minn. R. 7007.3000; Avoid major source under 40 CFR 70.2 and Minn. R. 7007.0200

Recordkeeping of Visible Emissions and Pressure Drop. The Permittee shall record the time and date of each visible emission inspection and pressure drop reading, and whether or not any visible emissions were observed, and whether or not the observed pressure drop was within the range specified in this permit

Title I Condition: Avoid major source under 4 0 CFR 52.21 (b)(1)(i) and Minn. R. 7007.3000; Avoid major source under 40 CFR 70.2 and Minn. R. 7007.0 200; Minn. R. 7007.0800, subps. 4, 5, and 14

Periodic Inspections: At least once per calendar quarter, or more frequently as required by the manufacturing specifications, the Permittee shall inspect the control equipment components. The Permittee shall maintain a written record of these inspections.

Minn. R. 7007.0800, subps. 4, 5, and 14

Corrective Actions: The Permittee shall take corrective action as soon as possible if any of the following occur: - visible emissions are observed; or - the recorded pressure drop is outside the required operating range; or - the fabric filter or any of its components are found during the inspections to need repair. Corrective actions shall eliminate visible emissions, and/or return the pressure drop to within the permitted range, and/or include completion of necessary repairs identified during the inspection, as applicable. Corrective actions include, but are not limited to, those outlined in the 0 & M Plan for the equipment. The Permittee shall keep a record of the type and date of any corrective action taken.

Minn. R. 7007.0800, subps. 4, 5, and 14

Monitoring Equipment: The Permittee shall install and maintain the necessary monitoring equipment for measuring and recording pressure drop as required by this permit. The monitoring equipment must be installed, in use, and properly maintained when the monitored fabric filters are in operation.

Minn. R. 7007.0800, subp. 4



Subject Item: GP 002 Cyclones

Associated Items: CE 031 Centrifugal Collector - Medium Efficiency

CE 032 Centrifugal Collector - Medium Efficiency

A-6 09/21/15

What to do Why to do it The Permittee shall operate and maintain each cyclone in accordance with the Operation and Maintenance (O & M) Plan. The Permittee shall keep copies of the O & M Plan available onsite for use by staff and MPCA staff.

Minn. R. 7007.0800, subps. 4-5; Minn. R. 7007.0800, subp. 14

Pressure Drop: The Permittee shall read and record the pressure drop across each of the two cyclones listed in GP002, once each day of operation.

Title I Condition: Avoid major source under 40 CFR 52.21 (b)(1 )(i) and Minn. R. 7007.3000; Avoid major source under 40 CFR 70.2 and Minn. R. 7007 .0200; Minn. R. 7007.0800, subp. 4, 5, and 14

Pressure Drop: greater than or equal to 4.0 inches of water column and less than or equal to 10.0 inches of water column unless a new range is set pursuant to Minn. R. 7017.2025, subp. 3 based on the values recorded during the most recent MPCA-approved performance test where compliance was demonstrated. The new range shall be implemented upon receipt of the Notice of Compliance letter granting preliminary approval. The range is final upon issuance of a permit amendment incorporating the change.


Recordkeeping of Pressure Drop. The Permittee shall record the time and date of each pressure drop reading, and whether or not the observed pressure drop was within the range specified in this permit.

Title 1 Condition: Avoid major source under 40 CFR 52.21 (b)(1)(i) and Minn. R. 7007.3000; Avoid major source under 40 CFR 70.2 and Minn. R. 7007.0200; Minn. R. 7007.0800, subp. 4, 5, and 14



Corrective Actions: The Permittee shall take corrective action as soon as possible if any of the following occur: - the recorded pressure drop is outside the required operating range; or - the cyclone or any of its components are found during the inspections to need repair. Corrective actions shall return the pressure drop to within the permitted range and/or include completion of necessary repairs identified during the inspection, as applicable. Corrective actions include, but are not limited to, those outlined in the O & M Plan for the equipment. T he Permittee shall keep a record of the type and date of any corrective action taken.


Corrective Actions: The Permittee shall take corrective action as soon as possible if any of the following occur: - the recorded pressure drop is outside the required operating range; or - the cyclone or any of its components are found during the inspections to need repair. Corrective actions shall return the pressure drop to within the permitted range and/or include completion of necessary repairs identified during the inspection, as applicable. Corrective actions include, but are not limited to, those outlined in the O & M Plan for the equipment. T he Permittee shall keep a record of the type and date of any corrective action taken.

Monitoring Equipment: The Permittee shall install and maintain the necessary monitoring equipment for measuring and recording pressure drop as required by this permit. The monitoring equipment must be installed, in use, and properly maintained when the monitored cyclone is in operation.

Minn. R. 7007.0800, subp. 4



A-7 09/21/15

Subject Item:

Associated Items:

GP 003 PM10 and PM2.5 Limits

SV011 Milling Exhaust



What to do Why to do it PM < 10 micron: less than or equal to 23.00 lbs/hour using 3-hour Average . This is a group limit. The sum of the hourly emissions from SV 011, SV 012, and SV 015 shall not exceed 23.00 pounds per hour.

If this limit cannot be met, the Permittee must apply for a Par t 70 permit.


PM < 2.5 micron: less than or equal to 23.00 lbs/hour using 3-hour Average . This is a group limit. The sum of the hourly emissions from SV 011, SV 012, and SV 015 shall not exceed 23.00 pounds per hour.

If this limit cannot be met, the Permittee must apply for a Par t 70 permit.


Initial Performance Test: due 180 days after Permit Issuance to measure PM10 emissions from SV 011, SV 012, and SV 015. The performance tests shall be conducted at worst case conditions as defined at Minn. R. 7017.2005, subp. 8, using EPA Reference Method 5, or other method approved by MPCA in the performance test plan approval. It is assumed that PM2.5 emissions do not exceed PM10 emissions, therefore a single test for PM10 will constitute a test for PM2.5.

Minn. R. 7017.2020, subp. 1



A-8 09/21/15

Subject Item: EU 001 Boiler

Associated Items: SV 023 Boiler Exhaust

What to do Why to do it OPERATING AND RECORDKEEPING REQUIREMENTS Minn. R. 7007.0800

Fuel Use: Limited to natural gas and distillate oil only Minn. R. 7007.0800, subp. 2

Sulfur Content of Fuel: less than or equal to 0.5 percent by weight, based on certification from fuel supplier.

40 CFR Section 60.42c(d); 40 CFR Section 60.42c(h)(1); Minn. R. 7011.0570

Recordkeeping: For each shipment of f uel oil, the Permittee shall obtain and maintain a copy of the fuel supplier's certific ation, which shall include the name of the oil supplier, and a statement from the o il supplier that the oil complies with the specifications under the definition of distillate oil in 40 CFR Section 60.41 c.

40 CFR Section 60.48c(f)(1); Minn. R. 7011.0570

Monthly Recordkeeping: Record and maintain records of the amounts of each fuel combusted on a monthly basis. These recor ds may consist of purchase records or receipts.

40 CFR Section 60.13(i) and February 20, 1992, February 22, 1993, and June 25, 2002 EPA memoranda to meet the requirements of 40 CFR Section 60.48c(g) and (i); Minn. R. 7011.0570



A-9 09/21/15

Subject Item: EU 002 Grain Receiving - Loading-Unloading Equipment

Associated items: CE 001 Fabric Filter - Low Temperature, i.e., T<180 Degrees F

SV 001 Receiving Exhaust

What to do Why to do it EMISSION LIMITS AND OPERATING REQUIREMENTS Minn. R. 7007.0800

Opacity: less than or equal to 10 percent opacity from SV 001. Minn. R. 7011.1005, subp. 3(D)

Opacity: less than or equal to 5 percent opacity a discharge of fugitive emissions from a truck unloading station, railcar unloading station, or handling operation.

Minn. R. 7011.1005, subp. 3(A)

Process Throughput: less than or equal to 523,000 tons/year using 12-month Rolling Sum of grain received.


EU002 consists of the components listed in Appendix II to this permit. Any replacement, addition, or modification to the components listed in Appendix II is considered a modification of EU002 for purposes of determining if a permit amendment is required.

Minn. R. 7007.0800, subp. 5

CONTROL EQUIPMENT REQUIREMENTS (CE001 - See GP001 for additional requirements)

Minn. R. 7007.0800

The Permittee shall route all emissions from components of "EU 002" to control equipment meeting the requirements of GP001 and EU002.


The Permittee shall operate and maintain the fabric filter (at the time of permit issuance, CE001) at all times that any process equipment controlled by the fabric filter is operating. The Permittee shall document periods of non-operation of the control equipment.


Total Particulate Matter: greater than or equal to 79.2 percent control efficiency (capture efficiency x collection efficiency). Any new, replaced, or modified control equipment is also subject to this limit.

Title I Condition: Avoid major source under 40 CFR 52.21 (b)(1)(i) and Minn. R. 7007.3000

Total Particulate Matter: greater than or equal to 80 percent collection efficiency . Any new, replaced, or modified control equipment is also subject to this limit.

Minn. R. 7011.1005, subp. 3(E)

PM < 10 micron: greater than or equal to 74.4 percent control efficiency (capture efficiency x collection efficiency). Any new, replaced, or modified control equipment is also subject to this limit.


PM < 2.5 micron: greater than or equal to 74.4 percent control efficiency (capture efficiency x collection efficiency). Any new, replaced, or modified control equipment is also subject to this limit.


MONITORING AND RECORDKEEPING REQUIREMENTS Minn. R. 7007.0800

Labeling Requirement: The Permittee shall permanently affix the emission unit number (EU002) and another unique number to each piece of equipment designated as part of "Grain Receiving," for tracking purposes. Labeling must be completed within 120 days of permit issuance and within 30 days of startup of any new piece of equipment. The number can be affixed by placard, stencil, or other means, provided it is maintained and readable from a safe distance. If equipment is added, it shall be given a new number; numbers from replaced or removed equipment shall not be reused.

Minn. R. 7007.0800, subp. 2

Equipment List: The Permittee shall maintain a list of each piece of equipment designated under the "Grain Receiving" category. The list shall include: - the type of equipment - the emission unit number (EU002) and another unique identifier - the date of installation and/or modification

If equipment is added or modified after permit issuance, the Equipment List shall also note that the following evaluations were made prior to the change: - the change does not trigger any applicable requirements that are not already listed in this permit - the change does not cause violation of any limits in this permit - the change did not require a permit amendment

Minn. R. 7007.0800, subps. 4- 5

Daily Recordkeeping: Grain Receiving

Each operating day, the Permittee shall record the quantity (weight) of grain received at the facility on the previous day.




Monthly Recordkeeping: Grain Receiving

By the 15th day of each month, calculate and record the quantity (weight) of grain received during the previous month, and during the previous 12 months (12-month rolling sum).

Minn. R. 7007.0800, subps. 4-5

TESTING REQUIREMENTS Minn. R. 7007.0800

Performance Test: due before end of each calendar 60 months starting 05/01/2012 to measure opacity from fugitive emissions from truck unloading and rail unloading. The performance test shall be conducted at worst cast conditions as defined at Minn. R. 7017.2005, subp. 8, using EP A Method 9 or other method approved by MPCA in the performance test plan ap proval. Testing conducted during the two months prior to the performance test due date satisfies the performance test due date, and will not reset the test due date for future testing as required by: 1) this permit, 2) by the most recently approved Performance Test Frequency Plan, or 3) if specified within a Notice of Compliance letter. Testing conducted more than two months prior to the performance test due date does not satisfy this test due date requirement and will be considered an additional test.

Minn. R. 7017.2020, subp. 1



A-11 09/21/15

Subject Item:

Associated Items:

EU 003 Grain Cleaning - Cleaning Equipment

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









SV 003 Cleaning Exhaust










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

Opacity: less than or equal to 5 percent opacity from fugitive emissions. Minn. R. 7011.1005, subp. 3(A)


Minn. R. 7007.0800, subp. 5

CONTROL EQUIPMENT REQUIREMENTS (at the time of permit issuance: CE003 - CE010, CE035; See GP001 for addit ional requirements)

Minn. R. 7007.0800



The Permittee shall operate and maintain each fabric filter at all times that any process equipment controlled by the fabric filter is operating. The Permittee shall document periods of non-operation of the control equipment.


Total Particulate Matter: greater than or equal to 99 percent control efficiency (capture efficiency x collection efficiency). Any new, replaced, or modified control equipment is also subject to this limit.

Title I Condition: Avoid major source under 40 CFR 52.21 (b)(1 )(i) and Minn. R. 7007.3000


Minn. R. 7011.1005, subp. 3(E)

PM < 10 micron: greater than or equal to 93 percent control efficiency (capture efficiency x collection efficiency). Any new, replaced, or modified control equipment is also subject to this limit.

Title I Condition: Avoid major source under 40 CFR 52.21 (b)(1)(i) and Minn. R. 7007.3000; A void major source under 40 CFR 70.2 and Minn. R. 7007.0200

PM < 2.5 micron: greater than or equal to 93 percent control efficiency (capture efficiency x collecti on efficiency). Any new, replaced, or modified control equipment is also subject to this limit.





Labeling Requirement: The Permittee shall permanently affix the emission unit number (EU003) and another unique number to each piece of equipment designated as part of "Grain Cleaning," for tracking purposes. Labeling must be completed within 120 days of permit issuance and within 30 days of startup of any new piece of equipment. The number can be affixed by placard, stencil, or other means, provided it is maintained and readable from a safe distance. If equipment is added, it shall be given a new number ; numbers from replaced or removed equipment shall not be reused.

Minn. R. 7007.0800, subp. 2

Equipment List: The Permittee shall maintain a list of each piece of equipment designated under the "Grain Cleaning" category. The list shall include: - the type of equipment - the emission unit number (EU003) and another unique identifier - the date of installation and/or modification

If equipment is added or modified after permit issuance, the Equipment List shall also note that the following evaluations were made prior to the change: - the change does not trigger any applicable requirements that are not already

listed in this permit - the change does not cause violation of any limits in this permit - the change did not require a permit amendment

Minn. R. 7007.0800, subps. 4-5



A-13 09/21/15

Subject Item:

Associated Items:

EU 004 Milling - Milling Equipment

CE 011 Fabric Filter - Low Temperature, i.e., T<180 Degrees F

















SV 011 Milling Exhaust




EMISSION LIMITS AND OPERATING REQUIREMENTS Minn. R. 7007.0800


EU004 consists of the components listed in Appendix II to this permit. Any replacement, addition, or modification to the components listed in Appendix II is considered a modification of EU004 for purposes of determining i f a permit amendment is required.

Minn. R. 7007.0800, subp. 5

CONTROL EQUIPMENT REQUIREMENTS (at the time of permit issuance: CE011, CE012, CE014 - CE024, CE037 - CE040; See GP001 for additional requirements)

Minn. R. 7007.0800






Title I Condition: Avoid major source under 40 CFR 52.21<b)<1)(i) and Minn. R. 7007.3000

Total Particulate Matter: greater than or equal to 80 percent collection efficiency . Any new, replaced, or modified control equipment is also subject to this lim it.

Minn. R. 7011.1005, subp. 3(E)



PM < 2.5 micron: greater than or equal to 94.05 percent control efficiency (capture efficiency x co llection efficiency). Any new, replaced, or modified control equipment is also subject to this limit.

Title I Condition: Avoid major source under 40 CFR 52.21 (b)(1)(i) and Minn. R. 7007.3000; Avoid major source under 40 CFR 70.2 and Minn. R . 7007.0200




Labeling Requirement: The Permittee shall permanently affix the emission unit number (EU004) and another unique number to each piece of equipment designated as part of "Milling," for tracking purposes. Labeling must be completed within 120 days of permit issuance and within 30 days of startup of any new piece of equipment. The number can be affixed by placard, stencil, or other means, provided it is maintained and readable from a safe distance. If equipment is added, it shall be given a new number; numbers from replaced or ' removed equipment shall not be reused.

Minn. R. 7007.0800, subp. 2

Equipment List: The Permittee shall maintain a list of each piece of equipment designated under the "Milling" category. The list shall include: - the type of equipment - the emission unit number (EU004) and another unique identifier - the date of installation and/or modification

If equipment is added or modified after permit issuance, the Equipment List shall also note that the following evaluations were made prior to the chang e: - the change does not trigger any applicable requirements that are not already listed in this permit - the change does not cause violation of any limits in this permit - the change did not require a permit amendment ,

Minn. R. 7007.0800, subps. 4-5



A-15 09/21/15

Subject Item:

Associated Items:

EU 005 Feed Loadout - Loading-Unloading Equipment


GP 004 Loadout

SV016 Feed Loadout


Opacity: less than or equal to 5 percent opacity from fugitive emissions from railcar loading.

Minn. R. 7011.1005, subp. 3(A)

Opacity: less than or equal to 10 percent opacity from fugitive emissions from truck loading.

Minn. R. 7011.1005, subp. 3(B)

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


Minn. R. 7007.0800, subp. 5

CONTROL EQUIPMENT REQUIREMENTS (See requirements under CE030) Minn. R. 7007.0800

The Permittee shall route all emissions from components of "EU 005" to control equipment meeting the requirements of CE030 and EU005.

Minn. R. 7019.3020(G)

The Permittee shall operate and maintain the fabric filter at all times that any process equipment controlled by the fabric filter is operating. The Permittee shall document periods of non-operation of the control equipment.

Minn. R. 7019.3020(G)

TESTING REQUIREMENTS Minn. R. 7007.0800

Performance Test: due before end of each calendar 60 months starting 05/01/2012 to measure opacity from fugitive emissions from truck loading and rail loading. The performance tst shall be conducted at worst cast conditions as defined at Minn. R. 7017.2005, subp. 8, using EPA Method 9 or other method approved by MPCA in the performance test plan approval. Testing conducted during the two months prior to the performance test due date satisfies the performance test due date, and will not reset the test due date for future testing as required by: 1) this permit, 2) by the most recently approved Performance Test Frequency Plan, or 3) if specified within a Notice of Compliance letter. Testing conducted more than two months prior to the performance test due date does not satisfy this test due date requirement and will be considered an additional test.

Minn. R. 7017.2020, subp. 1


Labeling Requirement: The Permittee shall permanently affix the emission unit number (EU005) and another unique number to each piece of equipment designated as part of "Feed Loadout," for tracking purposes. Labeling must be completed within 120 days of permit issuance and within 30 days of startup of any new piece of equipment. The number can be affixed by placard, stencil, or other means, provided it is maintained and readable from a safe distance. If equipment is added, it shall be given a new number; numbers from replaced or removed equipment shall not be reused.

Minn.R. 7007.0800, subp. 2

Equipment List: The Permittee shall maintain a list of each piece of equipment designated under the "Feed Loadout" category. The list shall include: - the type of equipment - the emission unit number (EU005) and another unique identifier - the date of installation and/or modification

Minn. R. 7007.0800, subps. 4-5




A-16 09/21/15

Subject Item: EU 006 Grain Handling - Material Handling Equipment

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

SV 002 Grain Handling Exhaust


Opacity: less than or equal to 10 percent opac ity from the stack Minn. R. 7011.1005, subp. 3(D)

Opacity: less than or equal to 5 percent opacity from fug itive emissions. Minn. R. 7011.1005, subp. 3(A)


Minn. R. 7007.0800, subp. 5

CONTROL EQUIPMENT REQUIREMENTS (a time of permit issuance: CE002; See GP001 for additional requirements)

Minn. R. 7007.0800



The Permittee shall operate and maintain the fabric filter at all times that any process equipment controlled by the fabric filter is operating. The Permittee shall document periods of non-operation of the control equipment.

Title I Condition: Avoid major source under 40 CFR 52.21 (b)(1)(i) and Minn. R. 7007.3000; Avoid majo r source under 40 CFR 70.2 and Minn. R. 7007.0200

Total Particulate Matter: greater than or equal to 99 percent control efficiency (capture efficiency x collection ef ficiency). Any new, replaced, or modified control equipment is also subject to this limit.



Minn. R. 7011.1005, subp. 3(E) .

PM < 10 micron: greater than or equal to 93 percent control efficiency (capture efficiency x collec tion efficiency). Any new, replaced, or modified control equipment is also subject to this limit.


PM < 2.5 micron: greater than or equal to 93 percent control efficiency (capture efficiency x collection efficiency). Any new, replaced, or modified control equipment is also subject to this limit.



Labeling Requirement: The Permittee shall permanently affix the emission unit number (EU006) and another unique number to each piece of equip ment designated as part of "Grain Handling," for trac king purposes. Labeling must be completed within 120 days of permit issuance and within 30 days of startup of any new piece of equipment. The number can be affixed by placard, stencil, or other means, provided it is maintained and readable from a safe distance. If equipment is added, it shall be given a new number; numbers from replaced or removed equipment shall not be reused.

Minn. R. 7007.0800, subp. 2

Equipment List: The Permittee shall maintain a list of each piece of equipment designated under the "Grain Handling" category. The list shall include: - the type of equipment - the emission unit number (EU006) and another unique identifier - the date of installation and/or modification

Minn. R. 7007.0800, subps. 4-5

If equipment is added or modified after permit issuan ce, the Equipment List shall also note that the following evaluations were made prior to the change: - the change does not trigger any applicable requirements that are not already

listed in this permit - the change does not cause violation of any limi ts in this permit - the change did not require a permit amendment



A-17 09/21/15

Subject Item:

Associated Items:

EU 007 Flour Storage and Loading - Loading-Unloading Equipment








GP 004 Loadout

SV 017 Storage/Loadout Exhaust


SV019 Storage/Loadout Exhaust






Opacity: less than or equal to 5 percent opacity from fugitive emissions from railcar loading.

Minn. R. 7011.1005, subp. 3(A)

Opacity: less than or equal to 10 percent opacity from fugitive emissions from truck loading.

Minn. R. 7011.1005, subp. 3(B)


EU007 consists of the components listed in Appendix I I to this permit. Any replacement, addition, or modification to the components listed in Appendix II is considered a modification of EU007 for purposes of determining if a permit amendment is required.

Minn. R. 7007.0800, subp. 5

CONTROL EQUIPMENT REQUIREMENTS (at time of permit issuance: CE026 -CE029, CE033, CE034, CE036; See GP001 for additional requirements)

Minn. R. 7007.0800


Title I Condition: Avoid major source under 40 CFR 52.21 (b)(1 )(i) and Minn. R. 7007.3000; A void major source under 40 CFR 70.2 and Minn. R. 7007.0200



Total Particulate Matter: greater than or equal to 99 percent control efficiency (capture efficiency x collection eff iciency). Any new, replaced, or modified contro l equipment is also subject to this limit.

Title I Condition: Avoid major source under 40 CFR 52.21 (b)(1 )(i) and Minn. R. 7007.3000


Minn. R. 7011.1005, subp. 3(E)



PM < 2.5 micron: greater than or equal to 93 percent control efficiency (capture efficiency x colle ction efficiency). Any new, replaced, or modified control equipment is also subject to this limit.





Labeling Requirement: The Permittee shall permanently affix the emission unit number (EU007) and another unique number to each piece of equipment designated as part of "Flour Storage and Loading," for tracking purposes. Labeling must be completed within 120 days of permit issuance and within 30 days of startup of any new piece of equipment. The number can be affixed by placard, stencil, or other means, provided it is maintained and readable from a safe distance. If equipment is added, it shall be given a new number; numbers from replaced or removed equipment shall not be reused.

Minn. R. 7007.0200, subp. 2

Equipment List: The Permittee shall maintain a list of each piece of equipment designated under the "Flour Storage and Loading" category. The list shall include: - the type of equipment - the emission unit number (EU007) and another unique identifier - the date of installation and/or modification


Minn. R. 7007.0800, subps. 4-5



A-19 09/21/15

Subject Item:

Associated Items:

EU 008 Pellet Cooling - Cooler



SV014 Pellet Cooling Exhaust


EMISSION LIMITS AND OPERATING REQUIREMENTS Minn. R. 7007.0800

Total Particulate Matter: less than or equal to 0.3 grains/dry standard cubic foot of exhaust gas unless required to further reduce emissions to comply with the less stringent limit of either Minn. R. 7011.0730 or Minn. R. 7011. 0735.

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

Opacity: less than or equal to 20 percent opacity from SV 014. Minn. R. 7011.0715, subp. 1(B)

Process Throughput: less than or equal to 172590 tons/year using 12-month Rolling Sum of pellets cooled.



Minn. R. 7007.0800, subp. 5

CONTROL EQUIPMENT REQUIREMENTS (at time of permit issuance: CE031 & CE032; See GP002 for additional requirements)

Minn. R. 7007.0800


Title I Condition: Avoid major source under 40 CFR 52.21 (b)(1)(i) and Minn. R. 7007.3000; Avoid major source under 40 CFR 70.2 and Minn. R. 7007. 0200

The Permittee shall operate and maintain each cyclone at all times that any process equipment controlled by the device is operating. The Permittee shall document periods of non-operation of the control equipment.

Title I Condition: Avoid major source under 40 CFR 52.21 (b)(1 )(i) and Minn. R. 7007.3000; Avoid major source under 40 CFR 70.2 and Minn. R. 7007 .0200

Total Particulate Matter: greater than or equal to 96 percent control efficiency (capture efficiency x collection efficiency, for 2 centrifugal collectors in series). Any new, replaced, or modified control equipment is also subject to this limit.


PM < 10 micron: greater than or equal to 64 percent control efficiency (capture efficiency x co llection efficiency, for 2 centrifugal collectors in series). Any new, replaced, or modified control equipment is also subject to this limit.

Title I Condition: Avoid major source under 40 CFR 52.21 (b)(1)(i) and Minn. R. 7007.3000; Avoid major source under 40 CFR 70.2 and Minn. R. 7 007.0200

PM < 2.5 micron: greater than or equal to 64 percent control efficiency (capture efficiency x co llection efficiency, for 2 centrifugal collectors in series). Any new, replaced, or modified control equipment is also subject to this limit.



Labeling Requirement: The Permittee shall permanently affix the emission unit number (EU008) and another unique number to each piece of equipment designated as part of "Pellet Cooling," for tracking purposes. Labeling must be completed within 120 days of permit issuance. The number can be affixed by placard, stencil, or other means, provided it is maintained and readable from a safe distance. If equipment is added, it shall be given a new number; numbers from replaced or removed equipment shall not be reused.

Minn. R. 7007.0800, subp. 2

Equipment List: The Permittee shall maintain a list of each piece of equipment designated under the "Pellet Cooling" category. The list shall include: - the type of equipment - the emission unit number (EU008) and another unique identifier - the date of installation and/or modification


Minn. R. 7007.0800, subps. 4-5

Daily Recordkeeping: Pellet Cooling Throughput

Each operating day, the Permittee shall record the quantity (weight) of pellets cooled at the facility on the previous day.


TABLE A: LIMITS AND OTHER REQUIREMENTS A-20 09/21/15

Facility Name: Ardent Mills Flour Mill


Monthly Recordkeeping: Pellet Cooling Throughput Minn. R. 7007.0800, subps. 4-5

By the 15th day of each month, calculate and record the quantity (weight) of pellets cooled during the previous month, and during the previous 12 month s (12-month rolling sum).



Subject Item: EU 009 Emergency Generator

Associated Items: SV 025 Emergency Generator

What to do Why to do it EMISSION LIMITS Minn. R. 7007.0800

Opacity: less than or equal to 20 percent opacity once operating temperatures have been attained.

Minn. R. 7011.2300, subp. 1

Sulfur Dioxide: less than 0.50 lbs/million Btu heat input. The potential to emit from the unit is 0.29 lbs/million Btu heat input due to equipment design and allowable fuels.

Minn. R. 7011.2300, subp. 2

OPERATING CONDITIONS Minn. R. 7007.0800

No. 2 fuel oil/diesel fuel meeting the requirements of 40 CFR Section 80.510(c) only by design.

Minn. R. 7005.0100, subp. 35a

Operating Hours: less than or equal to 500 hours/year using 12-month Rolling Sum to be calculated by the 15th day of each month.


RECORDKEEPING REQUIREMENTS Minn. R. 7007.0800

Hours of Operation: The Permittee shall maintain documentation on site that the unit is an emergency generator by design that qualifies under the U.S. EPA memorandum entitled "Calculating Potential to Emit (PTE) for Emergency Generators" dated September 6,1995, limiting operation to 500 hours per year.

Title I Condition: Avoid major source under 40 CFR 52.21 (b)(1 )(i) and Minn. R. 7007.3000; Avoid major source under 40 CFR 70.2 and Minn. R. 700 7.0200; Minn. R. 7007.0800, subps. 4-5

The Permittee shall keep records of fuel type and usage on a monthly basis. Minn. R. 7007.0800, subp. 5

NESHAP SUBPART 7777 REQUIREMENTS - Enforcement Not Delegated to MPCA

Minn. R. 7007.0800

Change oil and filter every 500 hours of operation or annually, whichever comes first. The Permittee has the option of utilizing an oil analysis program in order to extend the oil change requirement as described below.

40 CFR Section 63.6603(a); 40 CFR Section 63.6640; and Table 2d to subpart ZZZZ of Part 63; Minn. R. 7011.8150

Inspect air cleaner every 1,000 hours of operation or annually, whichever comes first, and replace as necessary.

40 CFR Section 63.6603(a); 40 CFR Section 63.6640; and Table 2d to subpart ZZZZ of Part 63; Minn. R. 7011.8150

Inspect all hoses and belts every 500 hours of operation or annually, whichever comes first, and replace as necessary.

40 CFR Section 63.6603(a); 40 CFR S ection 63.6640; and Table 2d to subpart ZZZZ of Part 63; Minn. R. 7011.8150

By January 1, 2015 the Permittee shall only use diesel fuel that meets the requirements in 40 CFR Section 80.510(b) for nonroad diesel fuel, except that any existing diesel fuel purchased or otherwise obtained prior to January 1 , 2015 may be used until depleted.

40 CFR Section 63.6604(b); Minn. R. 7011.8150

At all times the Permittee shall operate and maintain any affected source, including associated air pollution control equipment and monitoring equipment, in a manner consistent with safety and good air pollution control practices for minimizing emissions. The general duty to minimize emissions does not require the Permittee to make any further efforts to reduce emissions if levels required by this standard have been achieved. Determination of whether such operation and maintenance procedures are being used will be based on information available to the Administrator which may include, but is not limited to, monitoring results, review of operation and maintenance procedures, review of operation and maintenance records, and inspection of the source.

40 CFR Section 63.6605(a); Minn. R. 7011.8150

The Permittee shall operate and maintain the stationary RICE and after-treatment control device (if any) according to the manufacturer's emission-related written instructions or develop a maintenance plan which shall provide to the extent practicable for the maintenance and operation of the engine in a manner consistent with good air pollution control practice for minimizing emissions.

40 CFR Section 63.6625(e); Minn. R. 7011.8150

The Permittee shall minimize the engine's time spent at idle during startup and minimize the engine's startup time to a period needed for appropriate and safe loading of the engine, not to exceed 30 minutes, after which time the emission standards applicable to all times other than startup apply.

40 CFR Section 63.6625(h); Minn. R. 7011.8150



The Permittee has the option of utilizing an oil analysis program in order to extend the specified oil change requirement. The oil analysis shall be performed at the same frequency specified for changing the oil. The an alysis program shall at a minimum analyze the following 3 parameters: Total Base Number, viscosity, and percent water content. The condemning limits for these parameters are as follows: Total Base Number is less than 30 percent of the Total Base Number of the oil when new; viscosity of the oil has changed by more than 20 percent from the viscosity of the oil when new; or percent water conten t (by volume) is greater than 0.5.

(continued below)

40 CFR Section 63.6625(i); Minn. R. 7011.8150

(continued from above)

If none of the condemning limits are exceeded, the Permittee is not required to change the oil. If any of the limits are exceeded, the Permittee shall change the oil within 2 business days of receiving the results of the analysis; if the engine is not in operation when the results of the analysis are received, the Permittee shall , change the oil within 2 business days or before commencing operation, whichever is later. The Permittee shall keep records of the parameters that are analyzed as part of the program, the results of the analysis, and the oil changes for the engine. The analysis program shall be part of the maintenance plan for the engine.


The Permittee shall operate and maintain the stationary RICE according to the manufacturer's emission-related operation and maintenance instructions; or the Permittee shall develop and follow a maintenance plan which shall provide to the extent practicable for the maintenance and operation of the engine in a manner consistent with good air pollution control practice for minimizing emissions.

40 CFR Section 63.6640(a); 40 CFR pt. 63 subp. ZZZZ, Table 6

The Permittee shall comply with the General Provisions in 40 CFR Section 63.1 through 63.15, as stated in 40 CFR pt. 63, subp. ZZZZ, Table 8, as applicable.

40 CFR Section 63.6665 and Table 8 to Sub part ZZZZ of Part 63; 40 CFR Section 63.1 - 63.15; Minn. R. 7011.8150

REQUIREMENTS FOR EMERGENCY STATIONARY RICE Minn. R. 7007.0800

The Permittee shall install a non-resettable hour meter if one is not already installed by May 3, 2013.

40 CFR Section 63.6625(f); Minn. R. 7011.8150

The Permittee shall operate the emergency stationary RICE according to the requirements in paragraphs 40 CFR Section 63.6640 (f)(1) through (4). Any operation other than emergency operation, maintenance and testing, emergency demand response, and operation in non-emergency situations for 50 hours per year, as described in 40 CFR Section 63.6640(f)(1) through (4), is prohibited. If the engine is not operated according to the requirements in 40 CFR Section 63.6640(f)(1) through (4), the engine will not be considered an emergency engine under this subpart and will need to meet all requirements for non-emergency engines. •


(1) There is no time limit on the use of emergency stationary RICE in emergency situations.

ON MAY 1, 2015, THE D C. CIRCUIT VACATED THE PROVISIONS OF 40 CFR SECTION 63.6640(f)(2) THAT ALLOW OPERATION OF AN EMERGENCY GENERATOR WITHOUT EMISSIONS CONTROLS FOR UP TO 100 HOURS PER YEAR AS PART OF AN EMERGENCY DEMAND-RESPONSE PROGRAM. AS OF THE DATE OF ISSUANCE OF AIR EMISSION PERMIT NO. 03700020-004, THE COURT HAD NOT ISSUED THE MANDATE IMPLEMENTING ITS DECISION. THESE PROVISIONS REMAIN IN EFFECT UNTIL THE COURT ISSUES THE MANDATE. AFTER THAT ACTION, THE PROVISIONS WILL NO LONGER BE EFFECTIVE.

(2) The Permittee may operate the emergency stationary RICE for any combination of the purposes specified in 40 CFR Section 63.6640(f)(2)(i) through (iii) for a maximum of 100 hours per calendar year. Any operation for non-emergency situations as allowed by 40 CFR Section 63.6640(f)(3) and (4) counts as part of the 100 hours per calendar year allowed by this paragraph (f)(2).

40 CFR Section 63.6640(f)(1) - (2); Minn. R. 7011.8150

2(i) The Permittee may operate the emergency stationary RICE for the purpose of maintenance checks and readiness testing, provided that the tests are recommended by Federal, State or local government, the manufacturer, the vendor, the regional transmission organization or equivalent balancing authority and transmission operator, or the insurance company associated with the engine. The Permittee may petition the Administrator for app roval of additional hours to be used for maintenance checks and readiness testing, but a petition is not required if the Permittee maintains records indicating that Federal, State, or local standards require maintenance and testing of emergency RICE beyond 100 hours per calendar year.

40 CFR Section 63.6640(f)(2)(i); Minn. R. 7011.8150



2(ii) Emergency stationary RICE may be operated for emergency demand response for periods in which the Reliability Coordinator under the North American Electric Reliability Corporation (NERC) Reliability Standard EOP-002-3, Capacity and Energy Emergencies (incorporated by reference, see 40 CFR Section 63.14), or other authorized entity as determined by the Reliability Coordinator, has declared an Energy Emergency Alert Level 2 as defined in the NERC Reliability Standard EOP-002-3. 2(iii) Emergency stationary RICE may be operated for periods where there is a deviation of voltage or frequency of 5 percent or greater below standard voltage or frequency.

40 CFR Section 63.6640(f)(2)(ii) - (2)(iii); Minn. R. 7011.8150

(4) The Permittee may operate the emergency stationary RICE up to 50 hours per year in non-emergency situations, but those 50 hours are counted towards the 100 hours per calendar year provided for maintenance and testing and emergency demand response provided in 40 CFR Section 63.6640(f)(2). Except as provided in 40 CFR Section 63.6640(f)(4)(i) and (ii), the 5 0 hours per year for non-emergency situations cannot be used for peak sh aving or non-emergency demand response, or to generate income for a facility to supply power to an electric grid or otherwise supply power as part of a financial arran gement with another entity.

40 CFR Section 63.6640(f)(4); Minn. R. 7011.8150

4(i) Prior to May 3, 2014, the 50 hours per year for non-emergency situations can be used for peak shaving or non-emergency demand response to generate income for a facility, or to otherwise supply power as part of a financial arrangement with another entity if the engine is operated as part of a peak shaving (load management program) with the local distribution system operator and the power is provided only to the facility itsel f or to support the local distribution system.

40 CFR Section 63.6640(f)(4)(i); Minn. R. 7011.8150

4(i) The 50 hours per year for nonemergency situations can be used to supply power as part of a financial arrangement with another entity if all of the following conditions are met: (A) The engine is dispatched by the local balancing authority or local transmission and distribution system operator. (B) The dispatch is intended to mitigate local transmission and/or distribution limitations so as to avert potential voltage collapse or line overloads that could lead to the interruption of power supply in a lo cal area or region. (C) The dispatch follows reliability, emergency operation or similar protocols that follow specific NERC, regional, state, public utility commission or local standards or guidelines. (D) The power is provided only to the facility itself or to support the local transmission and distribution system.

(continued below)

40 CFR Section 63.6640(f)(4)(ii); Minn. R. 7011.8150


4(ii) (E) The owner or operator identifies and records t he entity that dispatches the engine and the specific NERC, regional, state, public utility commission or local standards or guidelines that are being followed for dispatching the engine. The » local balancing authority or local transmission and distribution system operator may keep these records on behalf of the engine owner or operator.

40 CFR Section 63.6640(f)(4)(ii); Minn. R. 7011.8150

NESHAP RECORDKEEPING REQUIREMENTS Minn. R. 7007.0800

The Permittee shall demonstrate continuous compliance with teach emission limitation and operating limitation in Table 2d of 40 CFR pt. 63, subp. ZZZZ that apply according to methods specified in Table 6 of 40 CFR pt. 63, subp. ZZZZ.


The Permittee shall keep the following records: 1. A copy of each notification and report submitted to comply with 40 CFR pt. 63, subp. ZZZZ, including all documentation supporting any Initial Notification or Notification of Compliance Status submitted according to the requirement in 40 CFR Section 63.10(b)(2)(xiv). 2. Records of the occurrence and duration of each malfunction of operation (i.e., process equipment) or the air pollution control and monitoring equipment. 3. Records of performance tests and performance evaluations as required in 40 CFR Section 63.10(b)(2)(viii). 4. Records of all required maintenance performed on the air pollution control and monitoring equipment. 5. Records of actions taken during periods of malfunction to minimize emissions in accordance with 40 CFR Section 63.6605(b), including corrective actions to restore malfunctioning process and air pollution control and monitoring equipment to its normal or usual manner of operation.




The Permittee shall keep records of the maintenance conducted on the stationary RICE in order to demonstrate that the Permittee operated and maintained the stationary RICE and after-treatment control device (if any) ac cording to the maintenance plan.


The Permittee shall keep records of the hours of operation of the engine that are recorded through the non-resettable hour meter. The Permittee shall document how many hours are spent for emergency operation, including what classified the operation as emergency and how many hours are spent for non-emergency operation. If the engine is used for the purposes specified in 40 CFR Section 63.6640(f)(2)(ii) or (iii) or 40 CFR Section 63.6640(f)(4)(ii), the Permittee shall keep records of the notification of the emergency situation, and the date, start time, and end time of engine operation for these purposes.


The Permittee shall keep records in a form suitable and readily available for expeditious review according to 40 CFR Section 63.10(b)(1).

As specified in 40 CFR Section 63.10(b)(1), the Permittee shall keep each record for 5 years following the date of each occurrence, measurement, maintenance, corrective action, report or record.

40 CFR Section 63.6660; 40 CFR Section 63.10(b)(1); Minn. R. 7011.8150

REPORTING AND NOTIFICATION REQUIREMENTS Minn. R. 7007.0800

The Permittee shall report each instance in which the stationary RICE did not meet each applicable operating limitation. These instances are deviations from the emission and operating limitations. These deviations shall be reported with the deviations report required by Table A (listed at the Total Facility level) and Table B of this permit. These deviations shall be reported according to the requirements in 40 CFR Section 63.6650.


APPLICABLE GENERAL PROVISIONS Minn. R. 7007.0800

OPERATION AND MAINTENANCE REQUIREMENTS Minn. R. 7007.0800

Circumvention. The Permittee shall not build, erect, install, or use any article, machine, equipment, or process to conceal an emission that would otherwise constitute noncompliance with a relevant standard. Such concealment includes, bu< is not limited to: 1) The use of diluents to achieve compliance with a relevant standard based on the concentration of a pollutant in the effluent discharged to the atmosphere or 2) The use of gaseous diluents to achieve compliance with a relevant standard for visible emissions.


Prior to construction or reconstruction of a major-emitting "affected source" under the promulgated MACT standards, the Permittee must apply for and obtain an air emission permit.

40 CFR Section 63.5(b)(3); Minn. R. 7011.7000

The Permittee must submit notification according to 40 CFR Section 63.9(b) if the Permittee constructs or reconstructs a source such that the source becomes an affected source subject to a standard.


After the effective date of any relevant standard promulgated under 40 CFR pt. 63, equipment added (or a process change) to an affected source that is within the scope of the definition of affected source under the relevant standard must be considered part of the affected source and subject to all provisions of the relevant standard established for that affected source.


Proper Operation and Maintenance. At all times, including periods of startup, shutdown, and malfunction, the Permittee shall operate and maintain the emission unit subject to the MACT standard and any associated air pollution control equipment and monitoring equipment, in a manner consistent with safety and good air pollution control practices for minimizing emissions at least to the levels requirec by any relevant standard and as detailed in 40 CFR Section 63.6(e)(1)(i)-(iii).

40 CFR Section 63.6(e)(1)(i); Minn. R. 7011.7000

Malfunctions shall be corrected as soon as practicable after their occurrence. 40 CFR Section 63.6(e)(1)(ii); Minn. R. 7011.7000

Startup, shutdown, and malfunction plan (SSMP). The Permittee shall prepare and implement a written SSMP that describes, in detail, procedures for operating and maintaining the source during periods of startup, shutdown, and malfunction; and a program of corrective action for malfunctioning process, air pollution control, and monitoring equipment used to comply with the relevant standard. The plan requirements are further described in 40 CFR Section 63.6(e)(3)(i).

40 CFR Section 63.6(e)(3)(i); Minn. R. 7011.7000

When actions taken by Permittee during a startup or shutdown (and the startup or shutdown causes the source to exceed any applicable emission limitation), or malfunction (including actions taken to correct a malfunction) are consistent with the procedures specified in the affected source's SSMP, the Permittee must keep records which demonstrate that the procedures specified in the SSMP were followed and describes the actions taken for that event.

40 CFR Section 63.6(e)(3)(iii); Minn. R. 7011.7000



If an action taken by the Permittee during a startup, shutdown, or malfunction (including an action taken to correct a malfunction) is not consistent with the procedures specified in the affected source's SSMP, and the source exceeds any applicable emission limitation in the relevant emission standard, then the Permittee must record the actions taken for that event and must report such actions as specified in 40 CFR Section 63.10(d)(5).

40 CFR Section 63.6(e)(3)(iv); Minn. R. 7011.7000

The Permittee must maintain at the affected source a current SSMP and must make the plan available upon request for inspection and copying by the Administrator. In addition, if the SSMP is subsequently revised, the Permittee must maintain at the affected source each previous (i.e., superseded) version of the SSMP, and must make each such previous version available for inspection and copying for a period of 5 years after revision of the SSMP.

40 CFR Section 63.6(e)(3)(v); Minn. R. 7011.7000

To satisfy the requirements of this section to develop a SSMP, the Permittee may use a standard operating procedures (SOP) manual, or other plan, provided the alternative plans meet all the requirements and are made available for inspection oi submission.

63.6(e)(3)(vi); Minn. R. 7011.7000

The Administrator may require that a Permittee make changes to the SSMP. Revisions to the SSMP will be required if the plan: 1) Does not address a startup, shutdown, or malfunction event that has occurred; 2) Fails to provide for the ope ration of the source (including associated air pollution control and monitoring equipment) during a startup, shutdown, or ma lfunction event in a manner consistent with the general duty to minimize emissions established by 40 CFR Section 63.6(e)(3)(iii)-63.6(e)(3)(ix) (e)(1)(i); 3) Does not provide adequate procedures for correcting malfunctioning process and/or air pollution control and monitoring equipment as quickly as prac ticable; or 4) Includes an event that does not meet the definition of startup, shutdown, or malfunction.

63.6(e)(3)(vii) ; Minn. R. 7011.7000

The Permittee may periodically revise the SSMP as necessary to reflect changes in equipment or procedures at the affected source. Each such revision to a SSMP must be reported in the semiannual report required by 40 CFR Section 63.10(d)(5). If the SSMP fails to address or inadequately addresses an event that meets the characteristics of a malfunction but was not included in the SSMP, the Permittee shall revise the SSMP within 45 days after the event in accordance with 40 CFR Section 63.6(e)(3)(viii).

40 CFR Section 63.6(e)(3)(viii); Minn. R. 7011.7000

Any revisions made to the SSMP shall not be deemed to constitute permit revisions under 40 CFR pt. 70 or pt. 71.

40 CFR Section 63.6(e)(3)(ix); Minn. R. 7011.7000

Applicability. The non-opacity emission standards set forth in 40 CFR Section 63.6(f)(1 )-(3) shall apply at all times except during periods of startup, shutdown, and malfunction, and as otherwise specified in an 40 CFR pt. 63, Subpart ZZZZ.


Methods for determining compliance will be, in part, based on the results of performance tests, conformance with operation and maintenance requirements, review of records, and inspection of the source as specified in 40 CFR Section 63.6(f)(2) The Permittee many use the results of performance testing conducted previously if it meets the requirements of 40 CFR Section 63.6(f)(iii).

40 CFR Section 63.6(f)(2); Minn. R. 7011 .7000

Finding of compliance. The Administrator will make a finding concerning an affected source's compliance with a non-opacity emission standard upon obtain ing all the compliance information required by the relevant standard.


The Permittee may establish the use of an alternative non-opacity emi ssion standard by following the procedure specified in 40 CFR Section 63.6(g).

40 CFR Section 63.6(g); Minn. R. 7011.7000

The Administrator may grant an extension of compliance with an emission standard, as specified in 40 CFR Section 63.6(i).


Until an extension of compliance has been granted by the Administrator, the Permittee shall comply with all applicable requirements of 40 CFR pt. 63, subp. A.

40 CFR Section 63.6(i)(1); Minn. R. 7011.7000

PERFORMANCE TESTING REQUIREMENTS Minn. R. 7007.0800

Notification of performance test. 1) The Permittee must notify the Administrator of their intention to conduct a performance test at least 60 calendar days before the performance test is initially scheduled to begin. 2) In the event the Permittee is unable to conduct the performance test on the date specified due to unforeseeable circumstances, the Permittee must notify the Administrator as soon as practicable and without delay prior to the scheduled performance test date and specify the date when the performance test is rescheduled.




Submission of site-specific test plan. Before conducting a required performance test, the Permittee shall develop and, if requested by the Administrator, shall submit a site-specific test plan for appro val in accordance with the requirements of 40 CFR Section 63.7(c)(2).

40 CFR Section 63.7(c)(2); Minn. R. 7017.2015

Approval of site-specific test plan. The Administrator will notify the Permittee of approval or intention to deny approval of the site-specific test plan (if review of the site-specific test plan is requested) within 30 calendar days after receipt of the original plan and within 30 calendar days after receipt of any supplementary information.


Performance testing facilities. The Permittee, at the request of the Administrator, shall provide performance testing facilities as specified in 40 CFR Section 63.7(d).

40 CFR Section 63.7(d); Minn. R. 7017.2015

Conduct of performance tests. 1) Performance tests shall be conducted under based on representative of the affected source. Operations during periods of startup, shutdown, and malfunction shall not constitute representative conditions for the purpose of a performance test. 2) Performance tests shall be conducted and data shall be reduced in accordance with the test methods and procedures set forth in 40 CFR Section 63.7(e), in each relevant standard, and, if required, in applicable appendices of 40 CFR parts 51, 60, 61. The Commissioner has delegation to approve a minor or intermediate modification (if validated by Method 301) to a reference method or specified monitoring procedure as allowed for in 40 CFR Section 63.7(e)(2)(i) and (ii).

40 CFR Section 63.7(e)(1)-(2); Minn. R. 7017.2015

Unless otherwise specified in a relevant sta ndard or test method, each performance test shall consist of three separate runs using the applicable test method. Each run shall be conducted for the time and under the conditions specified in the relevant standard. For the purpose of determining compliance w ith a relevant standard, the arithmetic mean of the results of the three runs shall apply, unless otherwise approved in accordance with provisions of 40 CFR Section 63.7(e)(3).

40 CFR Section 63.7(e)(3); Minn. R. 7017.2015

Data analysis, recordkeeping, and reporting. Unless otherwise specified in a relevant standard or test method, or as otherwi se approved by the Administrator in writing, results of a performance test shall include the analysis of samples, determination of emissions, and raw data. A performance test is completed when field sample collection is terminated. The Permittee shall report the results of the performance test to the Administrator before the close of business on the 60th day following the completion of the performance test, unless specified otherwise in a relevant standard or as approved otherwise in writing. The results of the performance test shall be submitted as part of the notification of complian ce status required under 40 CFR Section 63.9(h) to the appropriate permitting authority.


Waiver of performance tests. Until a waiver of a performance testing requirement has been granted by the Administrator under 40 CFR Section 63.7(h), the Permittee remains subject to the requirements of 40 CFR Section 63.7(h).


MONITORING REQUIREMENTS Minn. R. 7007.0800

All CMS required under relevant standards shall be subject to the provisions of 40 CFR Section 63.8 upon promulgation of performance specifications for CMS as specified in the relevant standard or otherwise by the Administrator. The performance specifications in 40 CFR pt. 60, Appendix B apply.

40 CFR 63.8(a)(2); Minn. R. 7017.2015

Conduct of monitoring. Monitoring shall be conducted as set forth in 40 CFR Section 63.8(a)(b)(1).


Operation and maintenance of continuous monitoring systems. The Permittee shall maintain and operate each CMS in a manner consistent with good air pollution control practices. 1) The Permittee must keep the necessary parts for routine repairs of the affected CMS equipment readily available. 2) The Permittee must ensure the read out, or other indication of operation, from any CMS required for compliance with the emission standard is readily accessible on site for operational control or inspection. 3) All CMS shall be installed, operational, and the data verified prior to or in conjunction with conducting performance tests. Verification of operational status shall, at a minimum, include completion of the manufacturer's written specifications or recommendations for installation, operation, and calibration of the system.

40 CFR Section 63.8(c)(1)-(3); Minn. R. 7017.2015

6) The Permittee of a CMS that is not a CPMS, must check the zero (low-level) and high-level calibration drifts at least once daily in accordance with the written procedure specified in the performance evaluation plan.




7) A CMS is out of control if: i) The zero (low-level), mid-level (if applicable), or high-level calibration drift (CD) exceeds two times the applicable CD specification in the applicable performance specification or in the relevant standard; or ii) The CMS fails a performance test audit (e.g., cylinder gas audit), relative accuracy audit, relative accuracy test audit, or linearity test au dit; or iii) The COMS CD exceeds two times the limit in the applicable performance specification in the relevant standard.

40 CFR Section 63.8(c)(7)(i); Minn. R. 7017.2015

When the CMS is out of control, the Permittee shall take the necessary corrective action and shall repeat all necessary tests which indicate that the system is out of control until the performance requirements are below the applicable limits. The beginning of the out-of-control period is the hour the Permittee conducts a performance check (e.g., calibration drift) that indicates an exceedance of the performance requirements established under this part. The end of the out-of-contro period is the hour following the completion of corrective action and successful demonstration that the system is within the allowable limits. During the period the CMS is out of control, recorded data shall not be used in data averages and calculations, or to meet any data availability requ irement.

40 CFR Section 63.8(c)(7)(H); Minn. R. 7017.2015

The Permittee shall submit all information concerning out-of-control periods, including start and end dates and hours and descriptions of corrective actions taken, in the excess emissions and continuous monitoring system performance report.


The Permittee shall develop and implement a CMS quality control program. As part of the quality control program, the Permittee shall develop and submit to the Aministrator for approval upon request a site-specific performance evaluation test plan for the CMS performance evaluation required in 40 CFR Section 63.8(e)(3)(i). Each quality control program shall include, at a minimum, a written protocol that describes procedures for each of the following operations: i) Initial and any subsequent calibration of the CMS; ii) Determination and adjustment of the calibration drift of the CMS; iii) Preventive maintenance of the CMS, including spare parts inventory; iv) Data recording, calculations, and reporting; v) Accuracy audit procedures, including sampling and analysis methods; and vi) Program of corrective action for a malfunctioning CMS.


The Permittee shall keep these written procedures on record for the life of the affected source, to be made available for inspection, upon request. The Permittee shall keep previous versions of the performance evaluation plan on record to be made available for inspection upon request, for a period of 5 years after each revision to the plan.


Performance evaluation of continuous monitoring systems: 1) When required by a relevant standard, and at any other time the Administrator may require, the Permittee shall conduct a performance evaluation of the CMS according to the applicable specifications and procedures described in 40 CFR Section 63.8(e) or in the relevant standard. 2) Notification of performance evaluation. The Permittee shall notify the Administrator in writing of the date of the performance evaluation simultaneously with the notification of the performance test date or at least 6 0 days prior to the date the performance evaluation is scheduled to begin if no performance test is required.

40 CFR Section 63.8(e)(1) & (2); Minn. R . 7017.2015

3) Reporting performance evaluation results. The Permittee shall furnish the Administrator a copy of a written report of the results of the performance evaluation simultaneously with the results of the performance test or within 60 days of completion of the performance evaluation if no test is required, unless otherwise specified in a relevant standard.


Use of an alternative monitoring method. Until permission to use an alternative monitoring procedure has been granted by the Administrator under 40 CFR Sections 63.8(f)(1)-(6), as appropriate, the Permittee remains subject to the requirements of 40 CFR Section 63.8 and the relevant standard.


Reduction of monitoring data. The Permittee must reduce the monitoring data as specified in 40 CFR Section 63.8(g)(1)-(5).


NOTIFICATION REQUIREMENTS • Minn. R. 7007.0800



The Permittee of a new or reconstructed major affected source for which an application for approval of construction or reconstruction is required under 40 CFR Section 63.5(d) must provide the following information in writing to the Administrator: 1) A notification of intention to construct a new major-emitting affected source, reconstruct a major-emitting affected source, or reconstruct a major source such that the source becomes a major-emitting affected source; and 2) A notification of the actual date of startup of th e source, delivered or postmarked within 15 calendar days after that date.


Notification of performance test. The Permittee shall notify the Administrator in writing of his or her intention to conduct a performance test at least 60 calendar days before the performance test is scheduled to begin.


Additional notification requirements for sources with CMS. The Permittee shall submit to the Administrator written notification as follows: 1) A notification of the date the CMS performance evaluation under 40 CFR Sectior 63.8(e) is scheduled to begin, submitted simultaneously with the notification of the performance test date required under 40 CFR Section 63.7(b). If no performance test is required, or if the requirement to conduct a performance test has been waived, the Permittee shall notify the Administrator in writing of the date of the performance evaluation at least 60 calendar days before the evaluation is scheduled to begin; 2) A notification that the criterion necessary to continue use of an alternative to relative accuracy testing, as provided by 40 CFR Section 63.8(f)(6), has been exceeded. The notification shall be delivered or postmarked not later than 10 days after the occurrence of such exceedance.

40 CFR Section 63.9(g)(1) & (3); Minn. R. 7019.0100

Notification of compliance status. Each time a notification of compliance status is required under 40 CFR pt. 63, subp. A, the Permittee shall submit to the Administrator a notification of compliance status containing the information required by 40 CFR Section 63.9(h), signed by the responsible official who shall certify its accuracy, attesting to whether the source has complied with the relevant standard. The notification must be sent by the 60th day following the completion of the relevant compliance demonstration activity specified in the relevant standard. If no performance test is required but opacity or visible emission observations are required, the notification of compliance status sh all be sent by the 30th day following the completion of opacity or visible emissio n observations. Notifications may be combined as long as the due date requirement for eac h notification is met.


Notification. Any change in the informa tion already provided under 40 CFR Section 63.9 shall be provided to the Administrator in writing within 15 calendar days after the change.

40 CFR Section 63.9(j); Minn. R. 7019.0100

RECORDKEEPING AND REPORTING REQUIREMENTS Minn. R. 7007.0800

The Permittee shall submit each report to the Administrator. 40 CFR Section 63.10(a); Minn. R. 7019.0100

Recordkeeping. The Permittee shall maintain files of all information (including all reports and notifications) required by 40 CFR pt. 63 in a form suitable and readily available for expeditious inspection and review. The files shall be retained for at least 5 years following the date of each occurrence, measurement, maintenance, corrective action, report, or record. At a minimum, the most recent 2 years of data must be retained on site.

40 CFR Section 63.10(b)(1); Minn. R. 7019.0100, subp. 2(B)

The Permittee shall maintain, at a minimum, the following information in the files: 1) the occurrence and duration of each startup, shutdown, or malfunction of operation; 2) the occurrence and duration of each malfunction of the air pollution contro l equipment; 3) all maintenance performed on the pollution control equipment; 4) actions taken during periods of startup, shutdown, and malfunction when such actions are different from the procedures specified in the affected source's startup, shutdown, and malfunction plan (SSMP). In this case, the Permittee shall report this action within 2 days of occurrence and follow by a written notification within 7 days of occurrence. 5) all information necessary to demonstrate conformance with the affected source's SSMP and actions taken in accordance with SSMP; 6) each period during which a continuous monitoring system (CMS) is malfunctioning or inoperative;

(continued below)





7) all required measurements needed to demonstrate compliance with a relevant standard; 8) all results of performance test, CMS performance evaluations, and opacity and visible emission observations; 9) all measurements as may be necessary to determine the conditions of performance tests and performance evaluations; 10) all CMS calibration checks; 11) all adjustments and maintenance performed on CMS; 12) any information demonstrating whether a source is meeting the requirements for a waiver of record keeping or reporting requirements under this part; 13) all documents supporting initial notifications and notifications of compliance status.


Additional recordkeeping requirements for sources with continuous monitoring systems. The Permittee shall maintain records as specified within 40 CFR Section 63.10(c); including CMS measurements (including monitoring data recorded during breakdowns and out-of-control periods) and corrective actions.

40 CFR Section 63.10(c); Minn. R. 7019.0100

Notwithstanding the requirements in 40 CFR Sections 63.10(d) and 63.10(e), the Permittee shall submit reports to the Administrator in accordance with the reporting requirements in the relevant standard.

40 CFR Section 63.10(d)(1); Minn. R. 7019.0100

Progress reports. The Permittee who is required to submit progress reports as a condition of receiving an extension of compliance under 40 CFR Section 63.6(i) shall submit such reports to the Administrator by the dates specified in the written extension of compliance.

40 CFR 63.10(d)(4); Minn. R. 7019.0100

Periodic startup, shutdown, and malfunction reports. If actions taken by a Permittee during a startup or shutdown (and the sta rtup or shutdown causes the source to exceed any applicable emission limitation in the relevant emission standards), or malfunction of an affected source (including actions taken to correct a malfunction) are consistent with the procedures specified in the source's startup, shutdown, and malfunction plan, the Permittee shall state such information in a startup, shutdown, and malfunction report.

40 CFR Section 63.10(d)(5)(i); Minn. R. 7019.0100

Actions taken to minimize emissions during such startups, shutdowns, and malfunctions shall be summarized in the report and may be done in checklist form. Such a report shall also include the number, duration, and a brief description for each type of malfunction which occurred during the reporting period and which caused or may have caused any applicable emission limitation to be exceeded. Reports shall only be required if a sta rtup or shutdown caused the source to exceed any applicable emission limitation, or if a malfunction occurred during the reporting period. The startup, shutdown, and malfunction report shall consist of a letter, containing the name, title, and signature of the Permittee who is certifying its accuracy, that shall be submitted to the Administrator semiannually.


Startup, shutdown, and malfunction report: due 30 days following the end of each calendar half year. The Permittee may submit this simultaneously with the excess emissions and continuous monitoring system performance (or other) reports. The Permittee may request approval to reduce the frequency of reporting the procedures specified in 40 CFR Section 63.10(e)(3).


Immediate startup, shutdown, and malfunction reports. Notwithstanding theallowance to reduce the frequency of reporting for periodic startup, shutdown, and malfunction reports, any time an action taken by a Permittee during a startup or shutdown that caused the source to exceed any applicable emission limitation in the relevant emission standards, or malfunction is not consistent with the procedures specified in the affected source's SSMP, the Permittee shall report the actions taken for that event within 2 working d ays after commencing actions inconsistent with the plan followed by a letter w ithin 7 working days after the end of the event. The immediate report required under this paragraph (d)(5)(ii) shall consist of a telephone call (or facsimile (FAX) transmission) to the Administrator within 2 working days after commencing actio ns inconsistent with the plan, and it shall be followed by a letter, delivered or postmarked within 7 working days.

40 CFR Section 63.10(d)(5)(ii); Minn. R. 7019.0100, subp. 2(B)

Additional reporting requirements for sources with continuous monitoring systems 1) When more than one CEMS is used to measure the emissions from one affected source, the Permittee shall report the results as required for each CEMS.


Excess emissions and continuous monitoring system performance report and summary report. Excess emissions and parameter monitoring exceedances are defined in relevant standards. The Permittee shall submit an excess emissions and continuous monitoring system performance report and/or a summary report to the Administrator semiannually, except when more frequent reporting is specifically required by a relevant standard or a reduction in frequency is approved pursuant to 40 CFR Section 63.10(e)(3).

40 CFR Section 63.10(e)(3)(i)-(iv); Minn. R. 7019.0100



Content and submittal dates for excess emissions and monitoring system performance reports. All excess emissions and monitoring system performance reports and all summary reports, if required, shall be delivered or postmarked by the 30th day following the end of each calendar half or quarter, as appropriate. Written reports of excess emissions or exceedance s of process or control system parameters shall include all the information required in 40 CFR Section 63.10(c)(5)-(c)(13), in 40 CFR Section 63.8(c)(7) and 40 CFR Sectuib 63.8(c)(8), and in the relevant standard, and they shall contain the name, title, and signature of the responsible official who is certifying the accuracy of the report. When no excess emissions or exceedances of a parameter have occurred, or a CMS has not been inoperative, out of control, repaired, or adjusted, such information shall be stated in the report.

40 CFR Section 63.10(e)(3)(v); Minn. R. 7019.0100

Summary report. One summary report sha ll be submitted for the hazardous air pollutants monitored at each affected source (unless the relevant standard specifies that more than one summary report is required. The summary report shall be entitled "Summary Report: Gaseous and Opacity Excess Emission and Continuous Monitoring System Performance" and shall contain the information specified in 40 CFR Section 63.10(e)(3)(vi).

40 CFR Section 63.10(e)(3)(vi); Minn. R. 7019.0100

If the total duration of excess emissions or process or control system parameter exceedances for the reporting period is 1 percent or greater of the total operating time for the reporting period, or the total CMS downtime for the reporting period is 5 percent or greater of the total operating time for the reporting period, both the summary report and the excess emissions and continuous monitoring system performance report shall be submitted.

40 CFR Section 63.10(e)(3)(vii); Minn. R. 7019.0100

Waiver of recordkeeping or reporting requirements. No requirements required. 40 CFR Section 63.10(f); Minn. R. 7019.0100



Subject Item: CE 030 Fabric Filter - Low Temperature, i.e., T<180 Degrees F

Associated Items: EU 005 Feed Loadout - Loading-Unloading Equipment


The operation of this piece of control equipment is not necessary in order for the process to meet applicable emissions limits. However, the Permittee wishes to take credit for its operation for the purposes of reporting actual emissions for emission inventory. Therefore, in order for PM, PM10, and PM2.5 to be considered controlled for the purposes of emissions inventory, the fabric filter must comply with the requirements of this permit during the time credit for control is taken. The PM, PM10, and PM2.5 generated during that time shall be considered controlled, and the control efficiency used is the limit given in this table.

Minn. R. 7019.3020(G)

Total Particulate Matter: greater than or equal to 79 percent control efficiency (capture efficiency x collection efficiency)

Minn. R. 7019.3020(G)

Total Particulate Matter: greater than or equal to 80 percent collection efficiency Minn. R. 7011.1005, subp. 3(E)

PM < 10 micron: greater than or equal to 74 percent control efficiency (capture efficiency x collection efficiency)

Minn. R. 7019.3020(G)

PM < 2.5 micron: greater than or equal to 74 percent control efficiency (capture efficiency x collec tion efficiency)

Minn. R.7019.3020(G)

The Permittee shall operate and maintain the fabric filter in accordance with the Operation and Maintenance (O & M) Plan. The Permittee shall keep copies of the O & M Plan available onsite for use by staff and MPCA staff.

Minn. R. 7019.3020(G)

Pressure Drop: greater than or equal to 0.5 inches of water column and less than or equal to 8 inches of water column unless a new range is set pursuant to Minn. R. 7017.2025, subp. 3 based on the values recorded during the most recent MPCA-approved performance test where compliance was demonstrated. The new range shall be implemented upon receipt of the Notice of Compliance letter granting preliminary approval. The range is final upon issuance of a permit amendment incorporating the change.

Minn. R. 7019.3020(G)

Visible Emissions: The Permittee shall check the fabric filter stack (SV 016) for any visible emissions once each day of operation during daylight hours. During inclement weather, the Permittee shall read and record the pressure drop across the fabric filter, once each day of operation.

Minn. R. 7019.3020(G)

Recordkeeping of Visible Emissions and Pressure Drop. The Permittee shall record the time and date of each visible emission inspection and pressure drop reading, and whether or not any visible emiss ions were observed, and whether or not the observed pressure drop was within the range specified in this permit

Minn. R. 7019.3020(G)


Minn. R. 7019.3020(G)

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

Minn. R. 7019.3020(G)

Monitoring Equipment: The Permittee shall install and maintain the necessary monitoring equipment for measuring and recording pressure drop as required by this permit. The monitoring equipment must be installed, in use, and properly maintained when the monitored cyclones are in operation.

Minn. R. 7007.0800, subp. 4



A-32 09/21/15

Subject Item: FS 001 Fugitive HAP Sources (Fumigation, Preservation, etc.)

What to do Why to do it HAP-Single: less than or equal to 9.0 tons/year using 12-month Rolling Sum to be calculated by the 15th day of each month for the previous 12-month pe riod as described later in this permit. All fugitive HAP sources shall be included in this calculation. HAP contents for each material shall be determined as described under the Material Content requirement. Includes each individual HAP used in non-combustion sources, including those used for water purification and product preservation.

Title I Condition: Avoid major source under 40 CFR 63.2 and Minn. R. 7011.7000; Avoid major source under 40 CFR 70.2 and Minn. R. 7007.0200

HAPs - Total: less than or equal to 20.0 tons/yea r using 12-month Rolling Sum to be calculated by the 15th day of each month for the previous 12-month period as described later in this permit. All fugitive HAP sources shall be included in this calculation. HAP contents for each material shall be determined as described under the Material Content requirement. Includes all HAP used in non-combustion sources, including those used for water purification and product preservation.

Title I Condition: Avoid major source under 40 CFR 63.2 and Minn. R. 7011.7000; Avoid major source under 40 CFR 70.2 and Minn. R. 7007.0200

Daily Recordkeeping. On each day of operation, the Permittee shall calculate, record, and maintain records of the total quantity of all HAP-containing materials used at the facility. This shall be based on written usage logs.

Title I Condition: Avoid major source under 40 CFR 63.2 and Minn. R. 7011.7000; Avoid major so urce under 40 CFR 70.2 and Minn. R. 7007.0200

Monthly Recordkeeping - HAP Usage. By the 15th day of each month, the Permittee shall calculate and record the following: 1) The quantity of each HAP-containing material used in the previous calendar month using the daily usage records. This record shall include the individual HAP content of each material as determined by the Material Content requirement of this permit. 2) The quantity of each individual HAP used in the previous month using the formulas specified in this permit. 3) The 12 month rolling sum of each individual HAP used for the previous 12 month period by summing the quantities calc ulated for that HAP for the previous 12 months. 4) The Total HAP usage for the previous month, by summing the quantities of each individual HAP used during the previous month. 5) the 12-month rolling sum of Total HAP for the previous 12 month s, by summing the Total HAP usage calculated for each of the previous 12 months.

Minn. R. 7007.0800, subps. 4-5

Monthly Calculation - Individual HAP Usage. The Permittee shall calculate the monthly quantity of each individual HAP using the following equations:

HAP A (tons/month) = (A1 x B1) + (A2 x B2) + (A3 x B3) +

Where: HAP A = total quantity of HAP A used in tons/month; A# = amount of each HAP A-containing material used, in tons/month; B# = weight percent of HAP A in A#, as a fraction

Minn. R. 7007.0800, subps. 4-5

Material Content. HAP contents in materials shall be determined by the Material Safety Data Sheet (MSDS) provided by the supplier for each material used. If a material content range is given on the MSDS, the highest number in the range shall be used in all compliance calculations. Other alternative methods approved by the MPCA may be used to determine the HAP content. The MPCA reserves the right to require the Permittee to determine the HAP content of any material, according to EPA or ASTM reference methods. If an EPA or ASTM reference method is used for material content determination, the data obtained shall supersede the MSDS.

Minn. R. 7007.0800, subps. 4 and 5

TABLE B: SUBMITTALS Facility Name: Ardent Mills Flour Mill


B-1 09/21/15

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:

Chief Air Enforcement 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 parts 7007.0100 to 7007.1850 must be certified by a responsible official, defined in Minn. R. 7007.0100, subp. 21. Other submittals shall be certified as appropriate if certification is required by an applicable rule or permit condition.

Table B lists most of the submittals required by this permit. Please note that some submittal requirements may appear in Table A or, if applicable, within a compliance schedule located in Table C. Table B is divided into two sections in order to separately list one-time only and recurrent submittal requirements.

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:

Fiscal Services 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: ONE TIME SUBMITTALS OR NOTIFICATIONS B-2 09/21/15 Facility Name: Ardent Mills Flour Mill


What to send When to send Portion of Facility Affected Testing Frequency Plan due 60 days after Initial Performance Test for

PM10 emissions. The plan shall specify a testing frequency based on the test data and MPCA guidance. Future performance tests based on 12-month, 36-month, or 60-month intervals, or as applicable, shall be required upon written approval of the MPCA.

GP003

TABLE B: RECURRENT SUBMITTALS B-3 09/21/15 Facility Name: Ardent Mills Flour Mill


What to send When to send Portion of Facility Affected Report due 30 days after end of each half-year

starting 08/08/1994. The report shall be submitted to the U.S. EPA, and shall include the following: - the calendar dates covered in the reporting period - records of fuel oil supplier certifications - certified statement signed by the owner or operator stating that the records of fuel supplier certifications submitted represent all of the fuel oil combusted during the reporting period.

EU001

Semiannual Deviations Report due 30 days after end of each calendar half-year starting 12/09/2002. 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. I f no deviations have occurred, the Permittee shall submit the report stating no deviations.

Total Facility

Annual Report due 90 days after end of each calendar year starting 12/09/2002. The Permittee shall submit an annual report by April 1 that describes the changes made at the facility during the previous calendar year. The report whall include a copy of all Equipment Lists, and shall document any equipment changes that took place during the previous calendar year, and any applicable New Source Performance Standards or NESHAPs that became effective during the previous calendar year. This report may be submitted with the annual emissions inventory, but it shall be a separate document marked as the "Annual Report." As part of the Annual Report, the Permittee shall verify and certify that the facility has maintained minor source status for New Source Review and Part 70, and has maintained area source status under the NESHAP program.

Total Facility

Compliance Certification due 31 days after end of each calendar year starting 12/09/2002 (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.

Total Facility

APPENDIX I: Insignificant Activities and Applicable Requirements Facility Name: Ardent Mills Flour Mill Permit Number: 03700020-004

Minn. R. 7007.1300, subpart

Rule Description of the Activity Applicable Requirement

3(G) Emissions from a laboratory, as defined in the subpart. • One OA laboratory

Minn. R. 7011.0510/0515; Minn. R. 7011.0610; Minn. R. 7011.0710/0715

APPENDIX II: Equipment List Facility Name: Ardent Mills Flour Mill Permit Number: 03700020-004

EU002 - Grain Receiving: SV002. CE002

Note: Any replacement, addition, or modification to the components listed below should be considered a modification ofEU002for purposes of determining if a permit amendment is required for the replacement, addition, or modification.

CE001, SV001 - VENTS OUTSIDE *Truck Dump Pit * Rail Dump Pit

EU003 - Grain Cleaning

Note: Any replacement, addition, or modification to the components listed below should be considered a modification of EU003 for purposes of determining if a permit amendment is required for the replacement, addition, or modification.

CE003, SV003 - vents inside * Bulk Feed Loadout cyclone 11/24/1985 *A/B Dirty wheat drag C332, C342 3/25/2001 *AM Camas 6/1/2006 *BM Camas 6/1/2006 *A-mill FD Airlock A200 1/19/1978 •Pellet Drag FL101/11995 *AM Reddog A/L A-19 1/1978 •Airlock A200 1/1978 •Pellet cyclone 1995 •Pellet to Storage A/L FM105 1995 •Pellet Scale 1995 • B-mill FD A/L B200 1/19/1978 •Reclaim Entoleter C270 6/1/1997

CE004, SV004-vents inside •BM Aquatron bypass spout 11/27/2011 •BM Carter Day separator C531 4/27/2000 •BM MTMA Separator C730 1990 •Scr. A/L Bench SC830 1995 •RM MTMA Separator C860 1990 •RM Aspirator C860 1990 •Bins 19 and 20 2/23/1997 •WW Rye Carter/Day 1975 •Turbo Aspirator 2009 •BM Inertial Separator C731 2000 •Rye Intertial Seperator C861 2000

*BM Light Fraction Dup Aspirator C430 2006 *BM Scourer/aspirator C433 6/1/2006 *Screenings feeder screw SC309 2006 * Bin 20 Chyclone SC380 1988 *BM Dirty Wheat Scale 3/25/2001 *Loadout bin #5 11/24/1991

CE005, SV005 - vents inside *WW WTR Spout 2012 *AM WTR Aspirator Surge Bin 6/1/2006 *BM WTR Aspirator Surge Bin 6/1/2006 *AM Grinding Bin Conveyor C337 1980 *BM Grinding Bin Conveyor C847 1980 *Rye Feed Airlock C6 1980 *WTR Aspiration Airlock A120 1980* *AM Carter/Day C5411990 *RM D. Wheat Elev. Leg C961 1/1/1977 *AM Scale Elev. Leg C941 8/13/1997 *AM Clean Wheat Elev. Leg C942 8/13/1997 *BM D. Wheat Elev. Leg C931 8/13/1997 *WW D. Wheat Elev. Leg C950 8/13/1997 •Reclaim Leg C970 2005 *WW product A/L 1995* *DR Airlock E4 1980 *SPDR Airlock E42 1980 *Rye Duo Aspirator 4/25/1988 *RM Clean Rye elev. Leg C962 1995 *AM D. Wheat Elev. Leg C940 1975 *AM 1st Temper Elev. Leg C943 1975 •Screenings A/L Hopper C281 1995 *BM Clean Wheat Elev. Leg C932 1995 *BM Scale Elev. Leg C930 1995* *WW Clean Wheat Elev. Leg C951 1995 •Damaged Wheat A/L Hopper C275 2005 *WW Stonemill 2000 *Small Wht collection Drag C380 6/1/2006 *Small Wheat collection A/L C284 2005 *AM WTR Recycle Aspirator MVSQ 2014* *BM WTR Recycle Aspirator MVSQ 2014

CE006, SV006 - vents inside *Dirty Wheat from Elevator Drag, E-W 1993 *AM Combinator booster fan C843 2005 *AM Combinator (Stoner) C640 2005 *Entolated wheat line, Reciever 1995 *A/B Final Temper Drags, N-S C841, C831 1995 *Rye Stoner C660 2000 *AM Light Fraction duo Asp C440 6/1/1994

CE007, SV007 - vents inside *AM AquaTron 2011 •Pelletmill Bin Suction Fan FM620/6 6/1/1995 •WW Cyclone 1995 *AM Dirty Wheat Scale 3/25/2001 •Mixing Screw WW final temper C852 12/23/1990 *Mixing screw BM final temper leg C632 2006 *AM Final Temper leg C642 1975 *DM Feed Bins 2,5 1988 •Pellet Mill surge bin 3/24/1996 •Durum cyclone to bins 28,29 1995 *Suction to bins 28, 29 1995 *AM Inertial Separator C740 2000

CE008, SV008 - vents inside *WW MTMA Separator C750 1985 •WW Concentrator C353 1985 •WW Carter/Day C550 2000 "WW airlock to Mill C251 1980 •WW Inertial Separator C751 1980 *FD Airlock #1 FR302 1980 *FD Airlock #2 FR304 1980

CE009, SV009 - vents inside •WW Destoner 2000 •BM Combinator Booster Fan 2005

CE010, SV010 - vents inside •Feed cyclone C810 1980 •Bridge drag C811 2000 •Feed Tower Cyclones, Screw and Bins 1998 •Rye Annex Cyclones and Bins 2/22/1998 •Bin 20 Screenings cyclone 1998

CE035, SV013 - vents inside •Cyclone on Screenings bench SC830 4/1997 •Flammermill Screenings A/L SC230 4/1997

EU004-Milling


CE011, SV011- VENTS OUTSIDE •6th fl- cyclone receivers- 52 1980

*3rd fl- product scales- 2 3/17/2009 *3rd fl- airlock hoppers- 2 7/22/1996 *lst fl- airlock hoppers-10 7/22/1996

CE012, SV011 - VENTS OUTSIDE •6th fl- cyclone receivers- 52 1980 •3rd fl- product scales- 2 3/17/2009 •3rd fl- airlock hoppers- 2 7/22/1996 •1st fl- airlock hoppers-9 7/22/1996

CE014, SV012 - vents inside *Durum Blending Filter 1978 •Filter #10 1978 •Conveyor(s) - 8 6/1/1989 *Cyclone Reciever -11978 •A/L Hopper(s) - 3 1978 •Fan -11978 •Bulk Truck -1 11/24/1991

CE015, SV012 - vents inside •Bulk L/O 11/24/1991 •Filter #9 1978 •Rail Car Suction - 4 1978 •A/L Hopper -11978 •Elevator/Packing/Feed 1978

CE016, SV012 - vents inside •Flour Bin Suction Filter 1971 •Filter #8 6/1/2006 • Bin(s) - 20 1971 •Cyclone Reciever(s) - 2 1971 •A/L Hopper(s) - 3 1971 •Rail loadout bins 1978 •Durum blending blower 1971 •Blender bulk blower 1971 •Blend plant forCSA's 1971 •Rye annex blower 1971 •Durum transfer blower cyclone 1971 •Bulk truck receiving cyclone 1971

CE017, SV012 - vents inside •System 1 Mill Pneumatics 1971 •Filter #2 1971 •Pressure lift: semo to rebolt 1971 •33 cyclones 1971

CE018, SV012 - vents inside •Durum Combinator Filter 1971

* Filter #18 1971 *Buhler MTCD Combinator 3/28/2005

CE019, SV012 - vents inside •Filter #6 1971 *Purifier(s) -17 11/5/1993 *1 BKA/L Hopper -11971

CE020, SV012 - VENTS OUTSIDE (I think this is a typo) *Pneu. Sys. #2 - Filter #3 4/1/1980 •Scourers - 4 4/25/1988 •Combinator Asp. - 1 4/57/2000 *TW Duo Asp. -1 6/1/1994 •Seperator Asp. -11971 *Cyclone Reciever(Feed) -11971 •CarterDay - 5 4/25/1988 *TW Bin -11971 •Elevator Leg-7 8/13/1997 •Garvity Table Asp. -11971 •Cyclone Reciever(VertiJet) - 2 1971 •Cyclone Reciever(TW Asp.) -11971 •LF Duo Asp.-11971 *Bin(s) - 7(TW - 2, Scr. -1, Cr. Wht. -1, RD - 2, Rebolt -1) 1971 •Conv. (Feed) -1 6/1/1995 •Bin - Wheat Heater -11/14/2000 *DW Scale -1 3/25/2001 •Scr. Bin -11971 •A/L Hopper(s) - 3 1971 •Hammermill - 1 7/15/2005

CE021, SV015 - vents inside •Bulk Truck Filter 11/24/1985 •Bin(s) - 2 4 /20/1997

CE022, SV012 - vents inside •Pneu. Sys. #3 -Filter #11971 •Cyclone Recievers - 29 1971 •1 BK Product lift to sifters 1971 •1 BK Red on S-mix and T-mix 1971

CE023, SV015 - vents inside •Pneu. Sys. #3-Filter #11971 •Cyclone Recievers - 29 1971 *1 BK Product lift to sifters 1971 •1 BK Red on S-mix and T-mix 1971

CE024, SV015 - vents inside •Durum Pneu. Systems 1971

*Pneu. Sys. #1 - Filter #4 1971 *Cyclone Recievers -15 1971 *Product lift: Pat flour to rebolt 1971 ""Product lift: 2/3 BK Redust to sifter 1971 *Product lift: 1 BK Red to Chappati cyclone 1971

CE037, SV011 - VENTS OUTSIDE *6th fl- cyclone receivers- 5 3/1998

CE038, SV011 - VENTS OUTSIDE *5th fl- cyclone receivers- 2 3/1998 *5th fl D mill- red dog cyclone receiver 3/1998 *4th fl- purifiers- 7 3/1998 *4th fl- spouts- 2 3/1998 *4th fl- wheat germ sifter 3/1998 *5th fl D mill- cyclone receiver 3/1998 *4th fl- cyclone receiver- co/fn farina 3/1998 *3rd- product scale-1 3/1998

CE039, SV011 - VENTS OUTSIDE *6th fl- cyclone receivers- 15 3/1998 *5th fl- cyclone receivers- 2 3/1998 *3rd fl- airlock hopper-1 3/1998

CE040, SV011 - VENTS OUTSIDE *5th fl- cyclone receivers- 3 3/1998 *4th- purifiers- 7 3/1998

EU005 - Feed Loadout

Note: Any replacement, addition, or modification to the components listed below should be considered a modification of EU005 for purposes of determining if a permit amendment is required for the replacement, addition, or modification.

CE030, SV016 - vents inside *Midds Shed 11/24/1985

EU006 - Grain Handling


CE002, SV002 - VENTS OUTSIDE *N. Mix drag 10/21/2013 *S. Mix Drag 10/21/2013 *Separator Leg 1/1/1977

•Unload Leg 1/1/1977 *Mix Leg 1/1/1977 *Durum Leg 1/1/1977 •Durum Screw 1971 •Garner Bin 1982 •Separator Bins 1971 •Screenings Hopper 6/1/1996 •Filter Drag 1971 •Unload Drag 11/8/2010 •Roof drag 11/25/2011

EU007 - Flour Storage and Loading

Note: Any replacement; addition, or modification to the components listed below should be considered a modification of EU007for purposes of determining if a permit amendment is required for the replacement, addition, or modification.

CE007, SV007 - vents inside •AM AquaTron 2011 •Pelletmill Bin Suction Fan FM620/6 6/1/1995 •WW Cyclone 1995 •AM Dirty Wheat Scale 3/25/2001 •Mixing Screw WW final temper C852 12/23/1990 •Mixing screw BM final temper leg C632 2006 •AM Final Temper leg C642 1975 •DM Feed Bins 2,5 1988 •Pellet Mill surge bin 3/24/1996 •Durum cyclone to bins 28,29 1995 •Suction to bins 28, 29 1995 •AM Inertial Separator C740 2000

EU008 - Pellet Cooling


CE008, SV008 - vents inside •WW MTMA Separator C750 1985 •WW Concentrator C353 1985 •WW Carter/Day C550 2000 •WW airlock to Mill C251 1980 •WW Inertial Separator C751 1980 *FD Airlock #1 FR302 1980 •FD Airlock #2 FR304 1980

TECHNICAL SUPPORT DOCUMENT For

AIR EMISSION PERMIT NO. 03700020-004

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 determination to issue the permit.

1. General Information

1.1 Applicant and Stationary Source Location:

Table 1. Applicant and Source Address

Applicant/Address Stationary Source/Address (SIC Code: 2041)

Ardent Mills LLC 11 Conagra Drive Omaha, NE 68102

Ardent Mills Flour Mill 2005 Vermillion Street South Hastings, Dakota County, Minnesota 55033

Contact: Levi Burton Phone: 651-437-0138

1.2 Facility Description

Ardent Mills Flour Mill operates a wheat flour and animal feed mill in Hastings, Minnesota. The facility consists of wheat mills, durum mills, durum processing, a rye mill, and associated elevator, storage, and packaging areas. Seventy-five percent of the wheat received is processed into flour and the remaining 25 percent into feed. The facility operates a boiler for heating and wheat tempering during the winter months.

In Permit -001 the facility accepted limits on the amount of wheat to be processed and on the amount of fumigant (methyl bromide), which may be used. These limits were federally enforceable, and resulted in the facility being a non-major source under the Part 70 permit program, the New Source Review program, and the National Emission Standards for Hazardous Air Pollutants program.

1.3 Description of the Activities Allowed by this Permit Action

This permit action is for a Major Amendment. It is a reopening under Minn. R. 7007.1600, subp. 1(D). No construction is being authorized. This permit action incorporates an Administrative Amendment to change the facility name from ConAgra Flour Mill - Hastings to Ardent Mills Flour Mill and the owner from ConAgra Foods to Ardent Mills LLC. In addition, recurring opacity testing for fugitive emissions was added to EU 002 and EU 005.

Other changes to the permit:

• Citations were corrected. • Total Facility boilerplate language was updated. • Completed requirements were deleted. • EU descriptions were updated in preparation for migration to new MPCA permit database. • PM2.5 control efficiencies were added. • Requirements to route all emissions to control equipment was added under EU 002 - EU 008. • Monitoring requirements were added to GP 001 and CE 030. • 365-day rolling sum limits were changed to 12-month rolling sum limits, to be consistent with similar facilities. • Total Facility PM10 limits were replaced with grain throughput limits at EU 002 - EU 008, to be consistent with

similar facilities. • Added a list of equipment to the permit appendix.

Technical Support Document, Permit Action Number: 03700020-004 Page 1 of 13

• GP 003: "PMio and PM25" Limits was created and Ib/hr limits and performance testing requirements were added.

• The emergency generator was removed from the Insignificant Activities list in the permit appendix and added to the body of the permit with its applicable requirements (EU009).

• Capture efficiency of Grain Receiving (EU 002) was corrected in the calculation spreadsheet from 100% to 80%.

1.4 Facility Emissions:

There is no real change in potential emissions authorized by this permit action. However the calculated potential emissions have changed because of regulatory changes in the method of calculation (control efficiencies in Minn. R. 7011.0070 have been revised), and the addition of PM25 and greenhouse gases as regulated pollutants. The calculated PTE based on permit conditions is as follows:

Table 2. Total Facility Potential to Emit Summary

PM tpy

PM10

tpy PM25

tpy S02

tpy NOx

tpy CO tpy

C02e tpy

VOC tpy

Single HAP tpy

All HAPs tpy

Total Facility Limited Potential Emissions

197.4 93.5 89.7 30.2 14.4 7.3 9785 22.1 9.0 20.3

Total Facility Actual Emissions (2014)

152 76.2 28.7 0.0 1.2 1.0 * 0.1 *

*Not reported in MN emission inventory.

Table 3. Facility Classification

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

2. Regulatory and/or Statutory Basis

New Source Review

The existing facility is subject to PM, PM10, PM25, and throughput limits such that emissions are less than the major source thresholds for NSR (40 CFR § 52.21(b)(1)). Therefore, as defined by the federal rules, the facility is not considered an existing major source for NSR. That status does not change with this permit action.

Part 70 Permit Program

The existing facility is subject to PM10, PM25, and throughput limits such that emissions are less than the major source thresholds for Part (40 CFR § 70.2).Therefore, as defined by the federal rules, the facility is not considered an existing major source under the Part 70 Permit Program. That status does not change with this permit action.

New Source Performance Standards (NSPS)

EU001 is a 13.4 MMBtu/hour boiler installed in 1994, and is subject to 40 CFR pt. 60, Subp. Dc, Standards of Performance for Small Industrial-Commercial-lnstitutional Steam Generating Units.

EU009, a compress ion ignition engine, was manufactured before July 11, 2005, and therefore is not subject to 40 CFR pt. 60, Subp. Illl, Standards of Performance for Stationary Compression Ignition Internal Combustion Engines.

National Emission Standards for Hazardous Air Pollutants (NESHAP)

The facility has accepted limits on HAP emissions such that it is an area source under 40 CFR pt. 63. Thus, no major source NESHAPs apply. However, the area source NESHAP for stationary RICE, 40 CFR pt. 63, subp. ZZZZ, applies to the emergency generator, EU 009.


Minnesota State Rules

• The emergency generator (EU 009) is subject to Minn. R. 7011.2300: Standards of Performance for Stationary Internal Combustion Engines.

• Portions of the facility are subject to Minn. R. 7011.1005: Standards of Performance for Dry Bulk Agricultural Commodity Facilities.

• Portions of the facility are subject to Minn. R. 7011.0715: Standards of Performance for Post-1969 Industrial Process Equipment.

Table 4. Regulatory Overview of Units Affected by the Permit Amendment

Subject Item Applicable Regulations Rationale

GP 003 (PMio and PM2.5 Limits)

Limit to avoid PSD and Part 70 Prevention of Significant Deterioration (PSD) and Part 70. Pound per hour limits taken to keep the potential emissions of PM10 and PM25

from the Milling operations to less than the major source threshold as defined by 40 CFR § 52.21.

Part 70 Permit Program. Pound per hour limits taken to keep the potential emissions of PM10 and PM25 from the Milling operations to less than the major source threshold as defined by 40 CFR § 70.2

EU 001 (Boiler)

40 CFR pt. 60, Subpart Dc Standards of Performance for Small Industrial-Commercial-Institutional Steam Generating Units. Boiler combusts natural gas and oil, and is subject fuel sulfur limitations; because it is smaller than 30 MMBtu/hour, it is not subject to the NSPS opacity limits (40 CFR § 60.43c(c))

Limit to avoid PSD and Part 70 PSD and Part 70. Process throughput must not exceed 523,000 tpy in order to remain a non-major source under 40 CFR § 52.21 and 40 CFR 70.2

EU 002

Minn. R. 7007.0800, subp. 5 Any replacement or change or modification of any component of EU 002 (listed in Appendix II) is considered a modification of EU 002 for purposes of determining if a permit amendment is needed.

(Grain Receiving)

Conditions to avoid PSD and Part 70

PSD and Part 70. The permittee sha ll route all emissions from "EU 002" to control equipment meeting the requirements of GP 001 and EU 002.

Limit to avoid PSD and Part 70 PSD and Part 70. The control equipment associated with EU 002 must meet 99% collection efficiency for PM and 93% collection efficiency of PMi0 and PM25 in order to remain a non-major source under 40 CFR § 52.21 and 40 CFR 70.2


EU 003 (Grain Cleaning)


PSD and Part 70. The permittee sha ll route all components of "EU 003" to control equipment meeting the requirements of GP 001 and EU 003.

Limit to avoid PSD and Part 70 The control equipment associated with EU 003 must meet 93% collection efficiency of PM10 and PM2.5 in order to remain a non-major source under 40 CFR § 52.21 and 40 CFR 70.2.




EU 004 (Milling)


The permittee shall route all components of "EU 004" to control equipment meeting the requirements of GP 001 and EU 004. EU 004

(Milling) Limit to avoid PSD and Part 70 PSD and Part 70. The control equipment associated with EU 004

must meet 99% control efficiency for PM, 99.06% collection efficiency of PM10 and 94.05% collection efficiency for PM2.5 in order to remain a non-major source under 40 CFR § 52.21 and 40 CFR 70.2.


EU 005 (Feed Loadout)

Minn. R. 7019.3020(G) Use of control equipment is not required in order to meet applicable limits. However, so that the permittee is able to take credit for the controls for purposes of reporting annual emissions, the permit requires that all EU 005 components be routed to CE 030 (or equivalent replacement unit) and that the control be at least 93% efficient for PM10 and PM2.5.

Minn. R. 7019.3020(G) The permittee is given credit for 99% control efficiency for PM, and 93% control efficiency of PM10 and PM2i5for emission inventory purposes. The control is not required in order to meet applicable emission limits.


EU 006 (Grain Handling)


PSD and Part 70. The permittee shall route all components of "EU 006" to control equipment meeting the requirements of GP 001 and EU 006


Limit to avoid PSD and Part 70 PSD and Part 70. The control equipment associated with EU 006 must meet 99% control efficiency for PM and 93% control efficiency of PM10 and PM25 in order to remain a non-major source under 40 CFR §52.21 and 40 CFR 70.2.

Minn. R. 7007.0800, subp. 5 Any replacement or change or modification of any component of EU 007 (listed in Appendix li) is considered a modification of EU 007 for purposes of determining if a permit amendment is needed.

EU 007 (Flour Storage and Loading)


PSD and Part 70. The permittee shall route all components of "EU 007" to control equipment meeting the requirements of GP 001 and EU 007.

EU 007 (Flour Storage and Loading) Limit to avoid PSD and Part 70 PSD and Part 70. The control equipment associated with EU 007

must meet 99% control efficiency for PM and 93% control efficiency of PMio and PM2.5 in order to remain a non-major source under 40 CFR §52.21 and 40 CFR 70.2.

EU 008 (Pellet Cooling)

Limit to avoid PSD and Part 70 PSD and Part 70. Process throughput must not exceed 43,147.5 tpy (33% of feed is pelletized) in order to remain a non-major source under 40 CFR §52.21 and 40 CFR 70.2





PSD and Part 70. The permittee shall route all components of "EU 008" to control equipment meeting the requirements of GP 001 and EU 008.

Limit to avoid PSD and Part 70 PSD and Part 70. The control equipment associated with EU 008 must meet 99% control efficiency for PM and 93% control efficiency of PM10 and PM2.5 in order to remain a non-major source under 40 CFR §52.21 and 40 CFR 70.2.

EU 009 (Emergency Generator)

40 CFR pt. 63, Subpart ZZZZ National Emission Standards for Hazardous Air Pollutants for Reciprocating Internal Combustion Engines.

• The unit is existing. • The unit is compression ignition. • The unit is for emergency use only.

Minn. R. 7011.2300 Standards of Performance for Stationary Internal Combustion Engines

FS 001 (Fugitive HAP Sources)

Limit to avoid Part 70 and NESHAPs

National Emission Standards for Hazardous Air Pollutants and Part 70. Limit set on HAPs emissions to avoid major source classification under 40 CFR Part 63 and 40 CFR Part 70.

3. Technical Information

3.1 PMm and PM?^ Control Efficiencies

Previous permit actions were based on an assumed 99% control efficiency for PM10 for calculations of potential-to-emit (PTE). However, the assumed PMi0 control efficiency in Minn. R. 7011.0070 has been changed to 93%, so calculations were revised to reflect that change. In order to remain a non-major source under NSR and Part 70, a higher control efficiency must be met for the milling operations (EU004); the permit includes the higher efficiency as well as an hourly emission rate that must be met. The Permittee is required to test the milling operations stacks to ensure that the hourly emission rate is met.

The calculations are in Attachment 3 to this TSD.

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; and • the kind of monitoring found on similar units elsewhere.

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


Table 5. Monitoring

Subject Item Requirement (rule

basis) Monitoring Discussion

GP 003 (PM10

and PM2.5 Limits)

PM10 <23.00 Ibs/hr

PM2.S< 23.00 Ib/hr

(Limit to avoid PSD and Part 70)

Initial Performance Test and Testing Frequency Plan for PM10

Control equipment monitoring as described at GP001 (Daily visible emissions checks and recordkeeping, daily pressure drop readings and recordkeeping, O&M, periodic inspections, corrective)

Emissions from the three stacks exhausting PM10

emissions from milling operations must not exceed 23.00 Ibs/hr when the emissions of the three stacks are added together.

The permittee is only required to specifically test PM10

emissions. It is assumed that all PM2.5 is a lso PMi0, so if PMio is less than 23.00 Ib/hr, PM2.5 will also be less than 23.00 Ib/hr.

If the limits cannot be met, the permittee must apply for a permit amendment proposing permit terms to maintain non-major status, or must apply for a Part 70 permit.

EU 001 (Boiler) Fuel Sulfur content < 0.5% by weight

(40 CFR 60 Subpart Dc)

Recordkeeping of fuel oil supplier certifications

As required by standard.

EU 002 (Grain Receiving)

Opacity: < 5 % from fugitive emissions

(Minn. R. 7011.1005, subp. 3(A))

Performance Testing every five years.

The May 1, 2012 Performance Test resulted in:

< 1.3% Opacity for Truck Unloading (26% of limit)

< 0.6% Opacity for Railcar Unloading (12% of limit)


Opacity: < 10% from the stack

(Minn. R. 7011.1005, subp. 3(D))

Daily visible emission checks (GP001)

If any visible emissions are detected, corrective action is to betaken.


Process Throughput < 523,000 tpy


Daily recordkeeping; Monthly calculations and recordkeeping

The facility must not receive more than 523,000 tpy of grain in order to remain a non-major source under 40 CFR § 52.21 and 40 CFR 70.2. Monthly calculations are adequate to ensure compliance.


PM > 80% collection efficiency

(Minn. R. 7011.1005, subp.3(E))

Daily visible emissions checks and recordkeeping, daily pressure drop readings and recordkeeping, O&M, periodic inspections, corrective actions (GP001)

This is less restrictive than the collection efficiency required by the control equipment rule, and is easily met by a properly maintained fabric filter.


PM >99% collection efficiency

PM10 > 93% collection efficiency


Daily visible emissions checks and recordkeeping, daily pressure drop readings and recordkeeping, O&M, periodic inspections, corrective actions (GP001)

The control equipment is Listed Control Equipment under Minn. R. 7011.0070 with the efficiency specified in the rule. The MPCA generally does not require testing unless a higher efficiency is needed to meet permit limits. The permit contains requirements for proper operation and maintenance of the control equipment. If the control equipment is properly operated and maintained there is a reasonable assurance that the control equipment will achieve the listed efficiency.




PM2.5 > 93% collection efficiency


PM2.5 emissions are conservatively estimated as PM10

emissions. Based on the type of operation, there is not expected to be condensable PM. Because the control equipment is Listed Control Equipment under Minn. R. 7011.0070 with PM10 control efficiency listed in the rule, no testing is required. The permit contains requirements for proper operation and maintenance of the control equipment. I f the control equipment is properly operated and maintained there is a reasonable assurance that the control equipment will achieve the listed efficiency.

Opacity: <5% from fugitive emissions

(Minn. R. 7011.1005, subp. 3(A))

None Capture efficiency of the control device is 100% (total enclosure); there are not expected to be fugitive emissions

Opacity: < 10% from each stack

(Minn. R. 7011.1005, subp. 3(D))


If any visible emissions are detected, corrective action is to be taken.


(Minn. R. 7011.1005, subp.3(E))


EU 003 (Grain Cleaning)




Daily visible emissions checks and recordkeeping, daily pressure drop readings and recordkeeping, O&M,




periodic inspections, corrective actions (GP001)

PM2.5 emissions are conservatively estimated as PMi0

emissions. Based on the type of operation, there is not expected to be condensable PM. Because the control equipment is Listed Control Equipment under Minn. R. 7011.0070 with PMio control efficiency listed in the rule, no testing is required. The permit contains requirements for proper operation and maintenance of the control equipment. I f the control equipment is properly operated and maintained there is a reasonable assurance that the control equipment will achieve the listed efficiency.

EU 004 (Milling)


(Minn. R. 7011.1005, subp. 3(D))






PM10 > 99.06% collection efficiency

PM2.S > 94.06% collection efficiency


Daily visible emissions checks and recordkeeping or daily pressure drop readings and recordkeeping, O&M, periodic inspections, corrective actions.

See also performance testing required under GP003.

Pounds per hour allowed was calculated using the required collection efficiency necessary to remain a non-major source under 40 CFR § 52.21 and 40 CFR 70.2.

If the performance testing at GP 003 demonstrates compliance with the permit limits, daily pressure drop reading will ensure continuous compliance with the permit limits.



Daily visible emissions checks and recordkeeping or daily pressure drop readings and recordkeeping, O&M, periodic inspections, corrective actions (GP001)



(Minn. R. 7011.1005, subp.3(E))




Opacity: < 5 % from fugitive emissions from railcar loading

(Minn. R. 7011.1005, subp. 3(A))

Opacity: < 10 % from fugitive emissions from truck loading

(Minn. R. 7011.1005, subp. 3(B))

Performance Testing every five years.

The May 1, 2012 Performance Test resulted in: < 0.4% Opacity (8% of most restrictive limit)


Opacity: < 10% from the stack

(Minn. R. 7011.1005, subp. 3(D))

Daily visible emission checks(CE030)




(Minn. R. 7011.1005, subp.3(E))

Daily visible emissions checks and recordkeeping or daily pressure drop






PMio > 93% collection efficiency

(Minn. R. 7019.3020(G))

readings and recordkeeping, O&M, periodic inspections, corrective actions (CE030)

The control equipment is Listed Control Equipment under Minn. R. 7011.0070 with the efficiency specified in the rule. Control from CE 030 is not needed to meet any applicable requirement; therefore performance testing is not required. The permit contains requirements for proper operation and maintenance of the control equipment. If the control equipment is properly operated and maintained there is a reasonable assurance that the control equipment will achieve the listed efficiency.


(Minn. R. 7019.3020(G))

readings and recordkeeping, O&M, periodic inspections, corrective actions (CE030)


emissions. Based on the type of operation, there is not expected to be condensable PM. Because the control equipment is Listed Control Equipment under Minn. R. 7011.0070 with PM10 control efficiency listed in the rule, no testing is required. The permit contains requirements for proper operation and maintenance of the control equipment. If the control equipment is properly operated and maintained there is a reasonable assurance that the control equipment will achieve the listed efficiency.


Opacity: <5% from fugitive emissions

(Minn. R. 7011.1005, subp. 3(A))




(Minn. R. 7011.1005, subp. 3(D))





(Minn. R. 7011.1005, subp.3(E))





PMio > 93% collection efficiency







'

PM2.S > 93% collection efficiency


PM2I5 emissions are conservatively estimated as PM10


Opacity: < 5% from fugitive emissions

(Minn. R. 7011.1005, subp. 3(A))





(Minn. R. 7011.1005, subp. 3(D))

PM>80% collection efficiency

(Minn. R. 7011.1005, subp.3(E))


EU 007 (Flour Storage and Loading)










emissions. Base d on the type of operation, there is not expected to be condensable PM. Because the control equipment is Listed Control Equipment under Minn. R. 7011.0070 with PM10 control efficiency listed in the rule, no testing is required. The permit contains requirements for proper operation and maintenance of the control equipment. If the control equipment is properly operated and maintained there is a reasonable assurance that the control equipment will achieve the listed efficiency.

EU 008 (Pellet Cooling)

Process Throughput < 127,590 tpy


Daily recordkeeping; Monthly calculations and recordkeeping

The facility must not handle more than 127,590 tpy of pellets cooled (33% of feed is pelletized) in order to remain a non-major source under 40 CFR § 52.21 and 40 CFR 70.2. Monthly calculations are adequate to ensure compliance.




PM: Variable with process weight

(Minn. R. 7011. 0715)

Proper operation of control equipment -Daily recordkeeping of pressure drop; O&M, periodic inspections; corrective actions (GP002)

Controlled emissions based on equipment capacity, published emission factors, and control efficiency allowed under Minn. R. 7011.0070 are 0.72 Ib/hr, well below the applicable limit.

Opacity: < 20% opacity

(Minn. R. 7011.0715)

Proper operation of control equipment -Daily recordkeeping of pressure drop; O&M, periodic inspections; corrective actions (GP002)

The controlled emission rate (0.72 Ib/hr) is not expected to result in visible emissions of 20%; noncompliance is unlikely.




Daily recordkeeping of pressure drop; O&M, periodic inspections; corrective actions




Daily recordkeeping of pressure drop; O&M, periodic inspections; corrective actions

PM2.5 emissions are conservatively estimated as PMi0



40 CFR pt. 63, Subpart ZZZZ

Recordkeeping of hours of operation

The Permittee must install a non-resettable hour meter and record hours of operation:

• during emergency operations • during non-emergency operations

ON MAY 1, 2015, THE D.C. CIRCUIT VACATED THE PROVISIONS OF 40 CFR SECTION 63.6640(f)(2) THAT ALLOW OPERATION OF AN EMERGENCY GENERATOR WITHOUT EMISSIONS CONTROLS FOR UP TO 100 HOURS PER YEAR AS PART OF AN EMERGENCY DEMAND-RESPONSE PROGRAM. AS OF THE DATE OF ISSUANCE OF AIR EMISSION PERMIT NO. 03700020-004, THE COURT HAD NOT ISSUED THE MANDATE IMPLEMENTING ITS DECISION. THESE PROVISIONS REMAIN IN EFFECT UNTIL THE COURT ISSUES THE MANDATE. AFTER THAT ACTION, THE PROVISIONS WILL NO LONGER BE EFFECTIVE.


Opacity < 20% Opacity

(Minn. R. 7011.2300, subp. 1

Records of type of fuel used

Given the fuel allowed, the unit is highly unlikely to violate the limit.




S02 < 0.50 Ibs/mmBtu

(Minn.R. 7011.2300, subp. 2

Records of type of fuel used.

Based on the capacity of the unit, allowable fuels, and published emission factors, the PTE from this unit is 0.003 lb S02/MMBtu. Given the fuel allowed, the unit is highly unlikely to violate the limit.

FS 001 (Fugitive HAP Sources)

HAP-Single < 9.0 tpy

HAPs-Total < 20.0 tpy

(Limit to avoid Part 70 and NESHAPs)

Monthly calculations and recordkeeping.

The greatest potential source of HAP is the methyl bromide used during fumigation, which happens very infrequently, so monthly recordkeeping is adequate. The only other source of HAP at the facility is fuel combustion, with potential total HAP emissions of 0.3 tpy.

3.3 Insignificant Activities

The permit is required to include periodic monitoring for all emissions units, including insignificant activities, per EPA guidance. The insignificant activities at this Facility are only subject to general applicable requirements. Using the criteria outlined earlier in this TSD, the following table documents the justification why no additional periodic monitoring is necessary for the insignificant activities affected by this modification.

Table 6. Insignificant Activities

Insignificant Activity General Applicable

Emission limit Discussion

Emissions from a laboratory, as defined in Minn. R. 7007.1300, subp. 3(G)

PM, variable depending on airflow

Opacity < 20%

(Minn. R. 7011.0710/0715)

These are very small, intermittent, bench-top operations that typically do not even have any emissions. It is highly unlikely that they could violate the applicable requirement.

3.4 Permit Organization

In general, the permit meets the current guidance for ordering and grouping of requirements. One area where this permit deviates slightly from current 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 Table A or B of the permit. 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. This permit uses appendices for "Insignificant Activities" (Appendix I) and Applicable Requirements and an "Equipment List" (Appendix II).

Another area that deviates from the guidance is in the use of groups where the requirements in the group apply to the members of the group individually. This was done in order to shorten the permit. This is the case for the requirements at GP 001 (Baghouses) and GP 002 (Cyclones).

3.5 Comments Received

Public Notice Period: August 7, 2015 - September 8, 2015

Comments were not received from the public or EPA during the public notice period. One change was made to the permit following public notice. On the cover page of the draft permit, the description "administrative amendment" was changed to "major amendment." The permit action is a major amendment. It stated "major amendment" elsewhere in the draft permit including on the cover page, it was processed as a majo r amendment including public notice, and the public notice itself described the permit action as a major amendment.


4. Permit Fee Assessment

The permit action includes a Reopening, which is not a chargeable activity, and one permit application received after the effective date of the rule (July 1, 2009). No additional points were assessed.

5. Conclusion

Based on the information provided by Ardent Mills Flour Mill, the MPCA has reasonable assurance that the proposed operation of the emission facility, as described in the Air Emission Permit No. 03700020-004 and this TSD, will not cause or contribute to a violation of applicable federal regulations and Minnesota Rules.

Staff Members on Permit Team: Jessica Forsberg/Toni Volkmeier (permit engineers) Brent Rohne (enforcement) Kelsey Suddard (peer reviewer) Beckie Olson (permit writing assistant) Laurie O'Brien (administrative support)

AQ File No. 543A; DQ4781

Attachments: 1. Facility Description and CD-01 Forms 2. Calculations


Attachment 1 - Facility Description

MINNESOTA POLLUTION CONTROL AGENCY AIR QUALITY 520 LAFAYETTE ROAD ST. PAUL, MN 55155-4194

Show: Active and Pending Records Action: PER 004 AQD Facility ID: 03700020 Facility Name: Ardent Mills Flour Mill

22 May, 2015 15:49

FACILITY DESCRIPTION: EMISSION UNIT (EU)

ID No. Emission Unit

Status

Added By

(Action)

Retired By

(Action)

Insignificant

Activity

Operator ID

for Item

Stack/ Vent

ID No(s).

Control Equip.

ID No(s).

Operator Description Manufacturer Model Number

SIC Max. Design

Capacity

Ma D

Ca

Materials

ximum 3sign pacity

Units n Units d

Max Fuel Input

(mil Btu)

1 EU 001 Active PER 001 | i SV 023 (M) Boiler C!eaver Brooks CB200-400 2041 13.39 Heat Mmbtu Hr 13.39

2 EU 001 Active PER 004 • SV 023 (M) Boiler Cleaver Brooks CB200-400 2041 13.39 Heat Mmbtu Hr 13.39

3 EU 002 Active PER 001 n SV 001 (M) CE 001 Grain Receiving various various 2041 300 Ton Hr

4 EU 002 Active PER 004 CJ SV 001 (M) CE 001 Grain Receiving -Loading-Unloading Equipment

various various 2041 300 Ton Hr

5 EU 003 Active PER 001 SV 003 (P) SV 004 (P) SV 005 (P) SV 006 (P) SV 007 (P) SV 008 (P) SV 009(P) SV010 (P) SV 013 (P)

CE 003 CE 004 CE 005 CE 006 CE 007 CE 008 CE 009 CE 010 CE 035

Grain Cleaning various various 2041 15 Ton Hr

6 EU 003 Active PER 004 SV 003 (P) SV 004 (P) SV 005 (P) SV 006 (P) SV 007 (P) SV 008(P) SV 009 (P) SV010(P) SV 013 (P)

CE 003 CE 004 CE 005 CE 006 CE 007 CE 008 CE 009 CE 010 CE 035

Grain Cleaning - Cleaning Equipment


7 EU 004 Active PER 003 I i SV011 (P) SV 012(P) SV 015 (P)

CE 011 CE 012 CE 014 CE 015 CE 016 CE 017 CE 018 CE 019 CE 020 CE 021 CE 022 CE 023 CE 024 CE 037 CE 038 CE 039 CE 040

Milling various various 2041 15 Ton Hr

Page 1 of 2 (a)

22 May, 2015 15:49


ID No. Emission Added Comm Initial Removal Firing Method Pet. Bottleneck Elevator Unit By ence Startup Date

Firing Method Fuel/ Type

Status (Action) Const. Date Space Date Heat

1 EU 001 Active PER 001 08/08/1994 08/08/1994

2 EU 001 Active PER 004 08/08/1994 08/08/1994

3 EU 002 Active PER 001 01/01/1950 01/01/1950

4 EU 002 Active PER 004 01/01/1950 01/01/1950

5 EU 003 Active PER 001 01/01/1950 01/01/1950

6 EU 003 Active PER 004 01/01/1950 01/01/1950

7 " EU 004 Active PER 003 01/01/1950 01/01/1950

Page 1 of 2 (b)

MINNESOTA POLLUTION CONTROL AGENCY AIR QUALITY 520 LAFAYETTE ROAD ST PAUL. MN 55155-419 4


22 May. 2015 15:49



Status

Added By

(Action)

Retired By

(Action)

Insignificant

Activity

Operator ID

for Item

Stack/ Vent

ID No(s).

Control Equip.

ID No(s).

Operator Description Manufacturer Model Number

SIC Max. Design

Capacity

Ma D

Ca

Materials

ximum 5$ign pacity

Units n Units d

Max Fuel Input

(mil Btu)

8 EU 004 Active PER 004 SV011 (P) SV 012 (P) SV 015 (P)

CE 011 CE 012 CE 014 CE 015 CE 016 CE 017 CE 018 CE 019 CE 020 CE 021 CE 022 CE 023 CE 024 CE 037 CE 038 CE 039 CE 040

Milling - Milling Equipment various various 2041 15 Ton Hr

9 EU 005 Active PER 001 • SV 016 (M) CE 030 Feed Loadout various various 2041 25 Ton Hr

10 EU 005 Active PER 004 L_J SV 016 (M) CE 030 Feed Loadout -Loading-Unloading Equipment


11 EU 006 Active PER 001 j ^ SV 002 (M) CE 002 Grain Handling various various 2041 300 Ton Hr

12 EU 006 Active PER 004 Lj SV 002 (M) CE 002 Grain Handling - Material Handling Equipment


13 EU 007 Active PER 003 ! ; SV 017 (P)

SV 018 (P) SV 019 (P) SV 020 (P) SV 021 (P) SV 022(P) SV 024 (P)

CE 026 CE 027 CE 028 CE 029 CE 033 CE 034 CE 036

Flour Storage and Loading various various 2041 22 Ton Hr

14 EU 007 Active PER 004 j j SV 017(P) SV 018(P) SV 019(P) SV 020 (P) SV 021 (P) SV 022 (P) SV 024 (P)

CE 026 CE 027 CE 028 CE 029 CE 033 CE 034 CE 036

Flour Storage and Loading -Loading-Unloading Equipment


15 EU 008 Active PER 001 | i SV 014 (M) CE 031 CE 032

Pellet Cooling various various 2041 25 Ton Hr

16 EU 008 Active PER 004 • SV 014 (M) CE 031 CE 032

Pellet Cooling - Cooler various various 2041 25 Ton Hr

17 EU 009 Active PER 004 • SV 025 (M) Emergency Generator Cummins 2041 355 Energy BHp 1903475

Page 2 of 2 (a)

22 May, 2015 15:49



Status

Added By

(Action)

Commence

Const. Date

initial Startup Date

Removal Date

Firing Method Pet. Fuel/

Space Heat

Bottleneck Elevator Type

8 EU 004 Active PER 004 01/01/1950 01/01/1950

9 EU 005 Active PER 001 01/01/1950 01/01/1950

10 EU 005 Active PER 004 01/01/1950 01/01/1950

11 EU 006 Active PER 001 01/01/1950 01/01/1950

12 EU 006 Active PER 004 01/01/1950 01/01/1950

13 EU 007 Active PER 003 01/01/1950 01/01/1950

14 EU 007 Active PER 004 01/01/1950 01/01/1950

15 EU 008 Active PER 001 01/01/1950 01/01/1950

16 EU 008 Active PER 004 01/01/1950 01/01/1950

17 EU 009 Active PER 004

Page 2 of 2 (b)

2 June, 2015 16:12

FACILITY DESCRIPTION: CONTROL EQUIPMENT (CE)

Show: Pending Records Only Action: PER 004 AQD Facility ID: 03700020 Facility Name: Ardent Mills Flour Mill

MINNESOTA POLLUTION CONTROL AGENCY AIR QUALITY 520 LAFAYETTE ROAD ST. PAUL. MN 55155-4194

ID No. Control Equip. Status

Added By

(Action)

Retired By

(Action)

Operator ID

for Item

Control

Equip. Type

Control Equipment Description Manufacturer Model Pollutants Controlled

Capture Efficiency

(%) Destruction/ Collection Efficiency

(%)

Afterburner Combustion Parameters

1 CE 001 Active PER 004 001 018 Fabric Filter- Low Temperature, i.e., T<180 Degrees F Buhler ASF-64/10 PM2.5 PM10 PM10 PM PM

80 100%

80 100%

80

93 99%

93 99%

99

2 CE 002 Active PER 004 002 018 Fabric Filter- Low Temperature, i.e., T<180 Degrees F Buhler-Maig PRF-120/10 PM2.5 PM10 PM10 PM PM

100 100%

100 100%

100

93 99%

93 99%

99

3 CE 003 Active PER 004 003 018 Fabric Filter - Low Temperature, i.e., T<180 Degrees F Micro-Pulsair 80G3 PM2.5 PM10 PM10 PM PM

100 100%

100 100%

100

93 99%

93 99%

99

4 CE 004 Active PER 004 004 018 Fabric Filter - Low Temperature, i.e., T<180 Degrees F Micro-Pulsair 1F1-48C PM2.5 PM10 PM10 PM PM

100 100%

100 100%

100

93 99%

93 99%

99


100 100%

100 100%

100

93 99%

93 99%

99


100 100%

100 100%

100

93 99%

93 99%

99

7 CE 007 Active PER 004 007 018 Fabric Filter- Low Temperature, i.e., T<180 Degrees F Micro-Pulsair 1F1-48C PM2.5 PM10 PM10 PM PM

100 100%

100 100%

100

93 99%

93 99%

99


100 100%

100 100%

100

93 99%

93 99%

99

9 CE 009 Active PER 004 009 018 Fabric Filter- Low Temperature, i.e., T<180 Degrees F Micro-Pulsair 1F1-48C PM2.5 PM10 PM10 PM PM

100 100%

100 100%

100

93 99%

93 99%

99

Page 1 of 5

MINNESOTA POLLUTION CONTROL AGENCY AIR QUALITY 520 LAFAYETTE ROAD ST. PAUL, MN 55155-41 94

2 June, 2015 16:12


Show: Pending Records Only Action: PER 004

AQD Facility ID: 03700020 Facility Name: Ardent Mills Flour Mill


Added By

(Action)

Retired By

(Action)

Operator ID

for Item

Control

Equip. Type


Capture Efficiency


(%)


10 CE 010 Active PER 004 010 018 Fabric Filter - Low Temperature, i.e., T<180 Degrees F Micro-Pulsair 1F1-48C PM2.5 PM10 PM10 PM ^ PM

100 100%

100 100%

100

93 99%

93 99%

99

11 CE 011 Active PER 004 011 018 Fabric Filter - Low Temperature, i.e., T<180 Degrees F Kice M240-10 PM2.5 PM10 PM10 PM PM

100 100%

100 100%

100

94.05 99%

99.06 99%

99

12 CE 012 Active PER 004 012 018 Fabric Filter- Low Temperature, i.e., T<180 Degrees F Kice M216-10 PM2.5 PM10 PM10 PM PM

100 100%

100 100%

100

94.05 99%

99.06 99%

99

13 CE 014 Active PER 004 014 018 Fabric Filter- Low Temperature, i.e., T<180 Degrees F Micro-Puisair 1F1-24 PM2.5 PM10 PM10 PM PM

100 100%

100 100%

100

94.05 99%

99.06 99%

99

14 CE 015 Active PER 004 015 018 Fabric Filter- Low Temperature, i.e., T<180 Degrees F Micro-Pulsair 1F1-24 PM2.5 PM10 PM10 PM PM

100 100%

100 100%

100

94.05 99%

99.06 99%

99

15 CE 016 Active PER 004 016 018 Fabric Filter - Low Temperature, i.e., T<180 Degrees F Micro-Pulsair 1C1 PM2.5 PM10 PM10 PM PM

100 100%

100 100%

100

94.05 99%

99.06 99%

99

16 CE 017 Active PER 004 017 018 Fabric Filter - Low Temperature, i.e., T<180 Degrees F Micro-Pulsair 1F3 PM2.5 PM10 PM10 PM PM

100 100%

100 100%

100

94.05 99%

99.06 99%

99


100 100%

100 100%

100

94.05 99%

99.06 99%

99

18 CE 019 Active PER 004 019 018 Fabric Filter - Low Temperature, i.e., T<180 Degrees F Micro-Pulsair 1F3 PM2.5 PM10 PM10 PM PM

100 100%

100 100%

100

94.05 99%

99.06 99%

99

Page 2 of 5

MINNESOTA POLLUTION CONTROL AGENCY AIR QUALITY 520 LAFAYETTE ROAD ST.PAUL, MN 55155-419 4

2 June, 2015 16:12





Added By

(Action)

Retired By

(Action)

Operator ID

for Item

Control

Equip. Type


Capture Efficiency


(%)


19 CE 020 Active PER 004 020 018 Fabric Filter- Low Temperature, i.e., T<180 Degrees F Micro-Pulsair 2G2 PM2.5 PM10 PM10 PM PM

100 100%

100 100%

100

94.05 99%

99.06 99%

99

20 CE 021 Active PER 004 021 018 Fabric Filter- Low Temperature, i.e., T<180 Degrees F Donaldson/Day 36-PJD-6 PM2.5 PM10 PM10 PM PM

100 100%

100 100%

100

94.05 99%

99.06 99%

99


100 100%

100 100%

100

94.05 99%

99.06 99%

99

22 CE 023 Active PER 004 023 018 Fabric Filter- Low Temperature, i.e., T<180 Degrees F Micro-Pulsair 1F1 PM2.5 PM10 PM10 PM PM

100 100%

100 100%

100

93 99%

99.06 99%

99


100 100%

100 100%

100

94.05 99%

99.06 99%

99

24 CE 026 Active PER 004 026 018 Fabric Filter- Low Temperature, i.e., T<180 Degrees F Kice unknown PM2.5 PM10 PM10 PM PM

100 100%

100 100%

100

93 99%

93 99%

99

25 CE 027 Active PER 004 027 018 Fabric Filter - Low Temperature, i.e.. T<180 Degrees F Kice unknown PM2.5 PM10 PM10 PM PM

100 100%

100 100%

100

93 99%

93 99%

99


100 100%

100 100%

100

93 99%

93 99%

99

27 CE 029 Active PER 004 029 018 Fabric Filter- Low Temperature, i.e., T<180 Degrees F Micro-Pulsair 36S830 PM2.5 PM10 PM10 PM PM

100 100%

100 100%

100

93 99%

93 99%

99

Page 3 of 5

2 June, 2015 16:12





Added By

(Action)

Retired By

(Action)

Operator ID

for Item

Control

Equip. Type

Control Equipment Description Manufacturer Mode! Pollutants Controlled

Capture Efficiency


(%)


28 CE 030 Active PER 004 030 018 Fabric Filter - Low Temperature, i.e., T<180 Degrees F Micro-Pulsair 36S830 PM2.5 PM10 PM10 PM PM

60 80%

60 80%

60

93 99%

93 99%

99

29 CE 031 Active PER 004 031 008 Centrifugal Collector - Medium Efficiency Buhler PDA2 PM2.5 PM10 PM10 PM PM

100 100%

100 100%

100

60 50%

60 50%

80

30 CE 032 Active PER 004 032 008 Centrifugal Collector - Medium Efficiency Buhler PDAZ PM2.5 PM10 PM10 PM PM

100 100%

100 100%

100

60 50%

60 50%

80

31 CE 033 Active PER 004 033 018 Fabric Filter - Low Temperature, i.e., T<180 Degrees F Northern Blower 5020 PM2.5 PM10 PM10 PM PM

100 10)%

100 100%

100

93 99%

93 99%

99

32 CE 034 Active PER 004 034 018 Fabric Filter - Low Temperature, i.e.. T<180 Degrees F Kice VS16-8 PM2.5 PM10 PM10 PM PM

100 100%

100 100%

100

93 99%

93 99%

99

33 CE 035 Active PER 004 035 018 Fabric Filter- Low Temperature, i.e., T<180 Degrees F unknown unknown PM2.5 PM10 PM10 PM PM

100 100%

100 100%

100

93 99%

93 99%

99

34 CE 036 Active PER 004 036 018 Fabric Filter - Low Temperature, i.e., T<180 Degrees F Buhler unknown PM2.5 PM10 PM10 PM PM

100 100%

100 100%

100

93 99%

93 99%

99

35 CE 037 Active PER 004 WW 018 Fabric Filter - Low Temperature, i.e., T<180 Degrees F Kice M216-10 PM2.5 PM10 PM10 PM PM

100 100%

100 100%

100

94.05 99%

99.06 99%

99

36 CE 038 Active PER 004 B Pur 018 Fabric Filter- Low Temperature, i.e., T<180 Degrees F Kice M216-10 PM2.5 PM10 PM10 PM PM

100 100%

100 100%

100

94.05 99%

99.06 99%

99

MINNESOTA POLLUTION CONTROL AGENCY AIR QUALITY 520 LAFAYETTE ROAD ST PAUL , MN 55155-419 4

Page 4 of 5

2 June, 2015 16:12


Show: Pending Records Only Action: PER 004 AQD Facility ID: 03700020 Facility Name: Ardent Mills Flour Mill


Added By

(Action)

Retired By

(Action)

Operator ID

for Item

Control

Equip. Type


Capture Efficiency


(%)


37 CE 039 Active PER 004 Rye 018 Fabric Filter - Low Temperature, i.e., T<180 Degrees F Kice M240-10 PM2.5 100 94.05 Rye PM10 100% 99% PM10 100 99.06 PM 100% 99% PM 100 99

38 CE 040 Active PER 004 A Pur 018 Fabric Filter - Low Temperature, i.e., T<180 Degrees F Kice M240-10 PM2.5 PM10 PM10 PM PM

100 100%

100 100%

100

94.05 99%

99.06 99%

99


Page 5 of 5

MINNESOTA POLLUTION CONTROL AGENCY AIR QUALITY 520 LAFAYETTE ROAD ST. PAUL. MN 55155-41 94

Show: Active and Pending Records Action: PER 004

AQD Facility ID: 03700020 Facility Name: Ardent Mills Flour Mil l

22 May, 2015 15:48

FACILITY DESCRIPTION: STACK/VENTS (SV)

ID No. Stack/ Vent

Status

Added By

(Action)

Retired By

(Action)

Operator ID

for Item

Operators Description Height of Opening

From Ground (feet)

Inside Dimensions Design Flow Rate

at Top (ACFM)

Exit Gas Temperature

at Top (°F)

Flow Rate/ Temperature

Information Source

Discharge Direction ID No. Stack/ Vent

Status

Added By

(Action)

Retired By

(Action)

Operator ID

for Item

Operators Description Height of Opening

From Ground (feet)

Diameter or Length

(feet)

Width (feet)

Design Flow Rate

at Top (ACFM)

Exit Gas Temperature

at Top (°F)

Flow Rate/ Temperature

Information Source

Discharge Direction

1 SV 001 Active PER 001 SV1 Receiving Exhaust 10.0 1.5 15000 80 Estimate Up, No Cap

2 SV 002 Active PER 001 SV2 Grain Handling Exhaust 10.0 0.94 25200 80 Estimate Down

3 SV 003 Active PER 001 SV3 Cleaning Exhaust 60.0 3.0 3.0 36000 80 Estimate Horizontal







10 SV010 Active PER 001 SV10 Cleaning Exhaust 130.0 1.76 1.76 9000 80 Estimate Horizontal

11 SV 011 Active PER 001 SV11 Milling Exhaust 140.0 1.25 65000 80 Estimate Horizontal

12 SV 012 Active PER 001 SV12 Milling Exhaust 140.0 1.25 85100 80 Estimate Horizontal


14 SV 014 Active PER 001 SV31 Pellet Cooling Exhaust 80.0 1.5 12500 120 Estimate Up, No Cap

15 SV 015 Active PER 001 SV15 Milling Exhaust 180.0 38.9 27500 80 Esti mate Horizontal

16 SV 016 Active PER 001 SV30 Feed Loadout 20.0 0.75 5000 80 Estimate Horizontal

17 SV 017 Active PER 001 SV26 Storage/Loadout Exhaust 180.0 1.25 6000 80 Estimate Horizontal




21 SV 021 Active PER 001 SV33 Storage/Loadout Exhaust 20.1 2.5 2.5 12585 68 Estimate Horizontal

22 SV 022 Active PER 001 SV36 Storage/Loadout Exhaust 130.0 1.76 1.76 1200 68 Estimate Horizontal

23 SV 023 Active PER 001 SV34 Boiler Exhaust 20 3.0 Estimate Up, No Cap


25 SV 025 Active PER 004 Emergency Generator

Page 1 of 1

MINNESOTA POLLUTION CONTROL AGENCY AIR QUALITY 520 LAFAYETTE ROAD ST PAUL . MN 55155-419 4


22 May, 2015 15:50

FACILITY DESCRIPTION: FUGITIVE SOURCES (FS)

ID No. Fugitive Source Status

Added By

(Action)

Retired By

(Action)

Insignificant

Activity

Operator ID

for Item

Pollutant(s) Emitted

Control Equip.

ID No(s).

Fugitive Source Description Year Installed

Year Removed

1 FS 001 Active PER 001 • VOC Sing hap HAPs Bromometha

Fugitive HAP Sources (Fumigation, Preservation, etc.)

Page 1 of 1

2 June, 2015 14:38

FACILITY DESCRIPTION: GROUPS (GP)

ID No. Group Status

Added By

(Action)

Retired By

(Action)

Include in El

Operator ID

for Item

Group Description Group Items

1 GP 001 Active PER 003 r

Baghouses CE 001, CE 002, CE 003, CE 004, CE 005, CE 006, CE 007, CE 008, CE 009, CE 010, CE 011. CE 012, CE 014, CE 015, CE 016, CE 017, CE 018, CE 019, CE 020, CE 021, CE 022, CE 023, CE 024, CE 026, CE 027, CE 028, CE 029, CE 030, CE 033, CE 034, CE 035, CE 036, CE 037, CE 038, CE 039, CE 040

2 GP 001 Active PER 004 r Baghouses CE 001, CE 002, CE 003, CE 004, CE 005, CE 006, CE 007, CE 008, CE 009, CE 010, CE 011. CE 012, CE 014, CE 015, CE 016, CE 017, CE 018, CE 019, CE 020, CE 021, CE 022. CE 023, CE 024, CE 026, CE 027, CE 028, CE 029, CE 033, CE 034, CE 035, CE 036, CE 037, CE 038, CE 039, CE 040

3 GP 002 Active PER 001 t— i Cyclones CE 031, CE 032

4 GP 003 Active PER 001 r 5 GP 003 Active PER 004 p PM10 and PM2.5 Limits SV011, SV012, SV 015

6 GP 004 Active PER 004 }— ) Loadout EU 005, EU 007

MINNESOTA POLLUTION CONTROL AGENCY AIR QUALITY 520 LAFAYETTE ROAD ST PAUL, MN 55155-419 4


Page 1 of 1


Page 1 of 35 14 Jut, 2015 16:28

COMPLIANCE PLAN CD-01 Facility Name:

Permit Number:

Subject Item:

Ardent Mills Flour Mill

03700020 - 004

Total Facility

NC/ CA

Type Citation Requirement

1.0 CD hdr FACILITY-SPECIFIC REQUIREMENTS

2.0 CD Title I Condition: Avoid major source under 40 CFR 52.21 (b)(1)(i) and Minn. R. 7007.3000; Avoid major source under 40 CFR 70.2 and Minn. R. 7007.0200

This permit establishes limits on the facility to keep it a m inor source under New Source Review and a nonmajor source under Part 70. The Permittee may not make any change at the source that would make the source a major source under New Source Review or Part 70 until a permit amendment has been issued. This includes changes that might otherwise qualify as insignificant modifications and minor or moderate amendments.

3.0 CD Minn. R. 7007.0800, subp. 2 Permit Appendix: This permit contains a appendices as listed in the permit Table of Contents. The Permittee shall comply with all requirements contained in the appendices.

4.0 CD hdr OPERATIONAL REQUIREMENTS

5.0 CD Minn. R. 7011.0020 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.

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

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

7.0 CD Minn. R. 7007.0800, subps. 14 and 16( J)

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.

8.0 CD Minn. R. 7019.1000, subp. 4 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.

9.0 CD Minn. R. 7011.0150 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.

10.0 CD Minn. R. 7030.0010 - 7030.0080 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.

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

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

13.0 CD hdr PERFORMANCE TESTING

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

of 35 14 Jul, 2015 16:28

COMPLIANCE PLAN CD-01 Facility Name: Ardent Mills Flour Mill

Permit Number: 03700020-004

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

Performance Test Notifications and Submittals:

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

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

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

16.0 CD Minn. R. 7017.2025, subp. 3 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.

17.0 CD hdr MONITORING REQUIREMENTS

18.0 CD Minn. R. 7007.0800, subp. 4(D) Monitoring Equipment Calibration - The Permittee shall either:

1. Calibrate or replace required monitoring equipment every 12 months; or 2. Calibrate at the frequency stated in the manufa cturer's specifications.

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.

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

20.0 CD hdr RECORDKEEPING

21.0 CD Minn. R. 7007.0800, subp. 5(C) Recordkeeping: Retain all records at the stationary source, unless otherwise specified within this permit, 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).

22.0 CD Minn. R. 7007.0800, subp. 5(B) 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.

23.0 CD Minn. R. 7007.1200, subp. 4 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. For nonexpiring permits, these records shall be kept for a period of five years from the date that the change was made. 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.

24.0 CD hdr REPORTING/SUBMiTTALS

MINNESOTA POLLUTION CONTROL AGENCY AIR QUALITY 520 LAFAYETTE ROA D ST. PAUL, MN 55155-4194

MINNESOTA POLLUTION CONTROL AGENCY Page 3 of 35 14 Jul, 2015 16:28 AIR QUALITY 520 LAFAYETTE ROAD



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

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

26.0 CD Minn. R. 7019.1000, subp. 2 Breakdown Notifications: Notify the Commissioner within 24 hours of a breakdown of more than one hour duration of any control equipment or process equipment if the breakdown causes any increase in the emissions of any regulated air pollutant. The 24-hour time period starts when the breakdown was discovered or reasonably should have been discovered by the owner or operator. However, notification is not required in the circumstances outlined in Items A, B and C of Minn. R. 7019.1000, subp. 2.

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

27.0 CD Minn. R. 7019.1000, subp. 1 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.

28.0 CD 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 any deviation from permit conditions which could endanger human health or the environment. Include the following information in this written description: 1. the cause of the deviation; 2. the exact dates of the period of the deviation, if the deviation has been corrected: 3. whether or not the deviation has been corrected; 4. the anticipated time by which the deviation is expected to be corrected, if not yet corrected; and 5. steps taken or planned to reduce, eliminate, and prevent reoccurrence of the deviation.

29.0 S/A Minn. R. 7007.0800, subp. 6(A)(2) Semiannual Deviations Report: due 30 days after end of each calendar half-year starting 12/09/2002. 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.

30.0 CD Minn. R. 7007.1150 - 7007.1500 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.

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

32.0 S/A Minn. R. 7007.0800, subp. 6(C) Compliance Certification: due 31 days after end of each calendar year starting 12/09/2002 (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.

33.0 CD Minn. R. 7019.3000 - 7019.3100 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.

34.0 CD Minn. R. 7002.0005 - 7002.0095 Emission Fees: due 30 days after receipt of an MPCA bill.


Facility Name:

Permit Number:


03700020 - 004

Page 4 of 35 14 Jul, 2015 16:28

COMPLIANCE PLAN CD-01

35.0 CD 40 CFR pt. 68 The Permittee must submit a Risk Management Plan (RMP) under 40 CFR pt. 68. Each owner or operator of a stationary source, at which a regulated substance is present above a threshold quantity in a process, shall design and implement an accidental release prevention program. An initial RMP must be submitted no later than the latest of the following dates: 1) June 21,1999; 2) Three years after the date on which a regulated substance is first listed under 40 CFR Section 68.130; or 3) The date on which a regulated substance is first present above a threshold quantity in a process. A full update and resubmission of the RMP is required at least once every five years. The five-year anniversary date is reset whenever your facility fully updates and resubmits their RMP. Submit RMPs to the Risk Management Plan Reporting Center, P.O. Box 1515, Lanham-Seabrook, Maryland 20703-1515. RMP information may be obtained at http://www.epa.gov/swercepp or by calling 1-800-424-9346.

36.0 S/A Minn. R. 7007.0800, subp. 2 Annual Report: due 90 days after end of each calendar year starting 12/09/2002. The Permittee shall submit an annual report by April 1 that describes the changes made at the facility during the previous calendar year. The report whall include a copy of all Equipment Lists, and shall document any equipment changes that took place during the previous calendar year, and any applicable New Source Performance Standards or NESHAPs that became effective during the previous calendar year. This report may be submitted with the annual emissions inventory, but it shall be a separate document marked as the "Annual Report." As part of the Annual Report, the Permittee shall verify and certify that the facility has maintained minor source status for New Source Review and Part 70, and has maintained area source status under the NESHAP program.


Page 5 of 35 14 Jul, 2015 16:28


Permit Number:

Subject Item:

Associated Items:


03700020 - 004

GP 001 Baghouses

CE 001 Fabric Filter - Low Temperature i.e. T<180 Degrees F



































NC/ CA



If the Permittee replaces any existing fabric filters, adds new fabric filters, or modifies the fabric filters listed in GP 001, such equipment is subject to all of the requirements of GP 001. Prior to making such a change, the Permittee shall apply for and obtain the appropriate permit amendment, as applicable.


Facility Name:

Permit Number:


03700020 - 004

Page 6 of 35 14 Jul, 2015 16:28


2.0 CD Minn. R. 7007.0800, subps. 4, 5, and 14

The Permittee shall operate and maintain each fabric filter in accordance with the Operation and Maintenance (O & M) Plan. The Permittee shall keep copies of the O & M Plan available onsite for use by staff and MPCA staff. Control efficiency requirements can be found at EU 002 through EU 007.

3.0 LIMIT Title I Condition: Avoid major source under 40 CFR 52.21 (b)(1)(i) and Minn. R. 7007.3000; Avoid major source under 40 CFR 70.2 and Minn. R. 7007.0200

Pressure Drop: greater than or equal to 0.5 inches of water column and less than or equal to 8.0 inches of water column , unless a new range is set pursuant to Minn. R. 7017.2025, subp. 3 based on the values recorded during the most recent MPCA:approved performance test where compliance was demonstrated. The new range shall be implemented upon receipt of the Notice of Compliance letter granting preliminary approval. The range is final upon issuance of a permit amendment incorporating the change.


Visible Emissions: The Permittee shall check each fabric filter stack for any visible emissions once each day of operation during daylight hours. During inclement weather, the Permittee shall read and record the pressure drop across the fabric filter, once each day of operation.

5.0 CD Title I Condition: Avoid major source under 40 CFR 52.21 (b)(1)(i) and Minn. R. 7007.3000; Avoid major source under 40 CFR 70.2 and Minn. R. 7007.0200; Minn. R. 7007.0800, subps. 4, 5, and 14

Recordkeeping of Visible Emissions and Pressure Drop. The Permittee shall record the time and date of each visible emission inspection and pressure drop reading, and whether or not any visible emissions were observed, and whether or not the observed pressure drop was within the range specified in this permit






8.0 CD Minn. R. 7007.0800, subp. 4 Monitoring Equipment: The Permittee shall install and maintain the necessary monitoring equipment for measuring and recording pressure drop as required by this permit. The monitoring equipment must be installed, in use, and properly maintained when the monitored fabric filters are in operation.


Facility Name:

Permit Number:


03700020 - 004

Subject Item: GP 002 Cyclones

Associated Items: CE 031 Centrifugal Collector - Medium Efficiency


Page 7 of 35 14 Jul, 2015 16:28


NC/ CA


1.0 CD Minn. R. 7007.0800, subps. 4-5; Minn. R. 7007.0800, subp. 14

The Permittee shall operate and maintain each cyclone in accordance with the Operation and Maintenance (O & M) Plan. The Permittee shall keep copies of the O & M Plan available onsite for use by staff and MPCA staff.

2.0 CD Title I Condition: Avoid major source under 40 CFR 52.21 (b)(1)(i) and Minn. R. 7007.3000; Avoid major source under 40 CFR 70.2 and Minn. R. 7007.0200; Minn. R. 7007.0800, subp. 4, 5, and 14

Pressure Drop: The Permittee shall read and record the pressure drop across each of the two cyclones listed in GP002, once each day of operation.


Pressure Drop: greater than or equal to 4.0 inches of water column and less than or equal to 10.0 inches of water column unless a new range is set pursuant to Minn. R. 7017.2025, subp. 3 based on the values recorded during the most recent MPCA-approved performance test where compliance was demonstrated. The new range shall be implemented upon receipt of the Notice of Compliance letter granting preliminary approval. The range is final upon issuance of a permit amendment incorporating the change.

4.0 CD Title I Condition: Avoid major source under 40 CFR 52.21 (b)(1)(i) and Minn. R. 7007.3000; Avoid major source under 40 CFR 70.2 and Minn. R. 7007.0200; Minn. R. 7007.0800, subp. 4, 5, and 14

Recordkeeping of Pressure Drop. The Permittee shall record the time and date of each pressure drop reading, and whether or not the observed pressure drop was within the range specified in this permit.




Corrective Actions: The Permittee shall take corrective action as soon as possible if any of the following occur: - the recorded pressure drop is outside the required operating range; or - the cyclone or any of its components are found during the inspections to need repair. Corrective actions shall return the pressure drop to within the permitted range and/or include completion of necessary repairs identified during the inspection, as applicable. Corrective actions include, but are not limited to, those outlined in the O & M Plan for the equipment. The Permittee shall keep a record of the type and date of any corrective action taken.

7.0 CD Minn. R. 7007.0800, subp. 4 Monitoring Equipment: The Permittee shall install and maintain the necessary monitoring equipment for measuring and recording pressure drop as required by this permit. The monitoring equipment must be installed, in use, and properly maintained when the monitored cyclone is in operation.


Facility Name:

Permit Number:

Subject Item:

Associated Items:


03700020 - 004

GP 003 PM10 and PM2.5 Limits SV011 Milling Exhaust



Page 8 of 35 14 Jul, 2015 16:28


NC/ CA


1.0 LIMIT Title I Condition: Avoid major source under 40 CFR 52.21 (b)(1 )(i) and Minn. R. 7007.3000; Avoid major source under 40 CFR 70.2 and Minn. R. 7007.0200

PM < 10 micron: less than or equal to 23.00 lbs/hour using 3-hour Average . This is a group limit. The sum of the hourly emissions from SV 011, SV 012, and SV 015 shall not exceed 23.00 pounds per hour.

If this limit cannot be met, the Permittee must apply for a Part 70 permit.


PM < 2.5 micron: less than or equal to 23.00 lbs/hour using 3-hour Average . This is a group limit. The sum of the hourly emissions from SV 011, SV 012, and SV 015 shall not exceed 23.00 pounds per hour.

If this limit cannot be met, the Permittee must apply for a Part 70 permit.

3.0 S/A Minn. R. 7017.2020, subp. 1 Initial Performance Test: due 180 days after Permit Issuance to measure PM10 emissions from SV011, SV 012, and SV 015. The performance tests shall be conducted at worst case conditions as defined at Minn. R. 7017.2005, subp. 8, using EPA Reference Method 5, or other method approved by MPCA in the performance test plan approval. It is assumed that PM2.5 emissions do not exceed PM10 emissions, therefore a single test for PM10 will constitute a test for PM2.5.

4.0 S/A Minn. R. 7017.2020, subp. 1 Testing Frequency Plan: due 60 days after Initial Performance Test for PM10 emissions. The plan shall specify a testing frequency based on the test data and MPCA guidance. Future performance tests based on 12-month, 36-month, or 60-month intervals, or as applicable, shall be required upon written approval of the MPCA.

MINNESOTA POLLUTION CON TROL AGENCY AIR QUALITY 520 LAFAYETTE ROAD ST. PAUL, MN 55155-4194

Facility Name:

Permit Number:

Subject Item:

Associated Items:


03700020 - 004

EU 001 Boiler

SV 023 Boiler Exhaust

Page 9 of 35 14 Jul, 2015 16:28


NC/ CA


1.0 CD Minn. R. 7007.0800 OPERATING AND RECORDKEEPING REQUIREMENTS

2.0 CD Minn. R. 7007.0800, subp. 2 Fuel Use: Limited to natural gas and distillate oil only

3.0 LIMIT 40 CFR Section 60.42c(d); 40 CFR Section 60.42c(h)(1); Minn. R. 7011.0570

Sulfur Content of Fuel: less than or equal to 0.5 percent by weight, based on certification from fuel supplier.

4.0 CD 40 CFR Section 60.48c(f)(1); Minn. R. 7011.0570

Recordkeeping: For each shipment of fuel oil, the Permittee shall obtain and maintain a copy of the fuel supplier's certification, which shall include the name of the oil supplier, and a statement from the oil supplier that the oil complies with the specifications under the definition of distillate oil in 40 CFR Section 60.41c.

5.0 CD 40 CFR Section 60.13(i) and February 20, 1992, February 22, 1993, and June 25, 2002 EPA memoranda to meet the requirements of 40 CFR Section 60.48c(g) and (i); Minn. R. 7011.0570

Monthly Recordkeeping: Record and maintain records of the amounts of each fuel combusted on a monthly basis. These records may consist of purchase records or receipts.

6.0 S/A 40 CFR Section 60.48c(e)(1); 40 CFR Section 60.48c(e)(11); 40 CFR Section 60.48c(f)(1); Minn. R. 7011.0570

Report: due 30 days after end of each half-year starting 08/08/1994. The repo rt shall be submitted to the U.S. EPA, and shall include the following: - the calendar dates covered in the reporting period - records of fuel oil supplier certifications - certified statement signed by the owner or operator stating that the records of fuel supplier certifications submitted represent all of the fuel oil combusted during the reporting period.




Page 10 of 35 14 Jul, 2015 16:28


Subject Item: EU 002 Grain Receiving - Loading-Unloading Equipment


SV 001 Receiving Exhaust

NC/ CA


1.0 CD Minn. R. 7007.0800 EMISSION LIMITS AND OPERATING REQUIREMENTS

2.0 LIMIT Minn. R. 7011.1005, subp. 3(D) Opacity: less than or equal to 10 percent opacity from SV 001.

3.0 LIMIT Minn. R. 7011.1005, subp. 3(A) Opacity: less than or equal to 5 percent opacity a discharge of fugitive emissions from a truck unloading station, railcar unloading station, or handling operation.


Process Throughput: less than or equal to 523,000 tons/year using 12-month Rolling Sum of grain received.

5.0 CD Minn. R. 7007.0800, subp. 5 EU002 consists of the components listed in Appendix II to this permit. Any replacement, addition, or modification to the components listed in Appendix II is considered a modification of EU002 for purposes of determining if a permit amendment is required.

6.0 CD Minn. R. 7007.0800 CONTROL EQUIPMENT REQUIREMENTS (CE001 - See GP001 for additional requirements)




The Permittee shall operate and maintain the fabric filter (at the time of permit issuance, CE001) at all times that any process equipment controlled by the fabric filter is operating. The Perm ittee shall document periods of non-operation of the control equipment.

9.0 LIMIT Title I Condition: Avoid major source under 40 CFR 52.21 (b)(1)(i) and Minn. R. 7007.3000

Total Particulate Matter: greater than or equal to 79.2 percent control efficiency (capture efficiency x collection efficiency). Any new, replaced, or modified control equipment is also subject to this limit.

10.0 LIMIT Minn. R. 7011.1005, subp. 3(E) Total Particulate Matter: greater than or equal to 80 percent collection efficiency . Any new, replaced, or modified control equipment is also subject to this limit.




PM < 2.5 micron: greater than or equal to 74.4 percent control efficiency (capture efficiency x collection efficiency). Any new, replaced, or modified control equipment is also subject to this limit.

13.0 CD Minn. R. 7007.0800 MONITORING AND RECORDKEEPING REQUIREMENTS

14.0 CD Minn. R. 7007.0800, subp. 2 Labeling Requirement: The Permittee shall permanently affix the emission unit number (EU002) and another unique number to each piece of equipment designated as part of "Grain Receiving," for tracking purposes. Labeling must be completed within 120 days of permit issuance and within 30 days of startup of any new piece of equipment. The numbe r can be affixed by placard, stencil, or other means, provided it is maintained and readable from a safe distance. If equipment is added, it shall be given a new number; numbers from replaced or removed equipment shall not be reused.

MINNESOTA POLLUTION CONTROL AGENCY AIR QUALITY 520 LAFAYETTE ROAD ST. PAU L, MN 55155-4194



Page 11 of 35 14 Jul, 2015 16:28


15.0 CD Minn. R. 7007.0800, subps. 4- 5 Equipment List: The Permittee shall maintain a list of each piece of equipment designated under the "Grain Receiving" category. The list shall include: - the type of equipment - the emission unit number (EU002) and another unique identifier - the date of installation and/or modification




Daily Recordkeeping: Grain Receiving

Each operating day, the Permittee shall record the quantity (weight) of grain received at the facility on the previous day.

17.0 CD Minn. R. 7007.0800, subps. 4-5 Monthly Recordkeeping: Grain Receiving

By the 15th day of each month, calculate and record the quantity (weight) of grain received during the previous month, and during the previous 12 months (12-month rolling sum).

18.0 CD Minn. R. 7007.0800 TESTING REQUIREMENTS

19.0 S/A Minn. R. 7017.2020, subp. 1 Performance Test: due before end of each calendar 60 months starting 05/01/2012 to measure opacity from fugitive emissions from truck unloading and rail unloading. The performance test shall be conducted at worst cast conditions as defined at Minn. R. 7017.2005, subp. 8, using EPA Method 9 or other method approved by MPCA in the performance test plan approval. Testing conducted during the two months prior to the performance test due date satisfies the performance test due date, and will not reset the test due date for future testing as required by: 1) this permit, 2) by the most recently approved Performance Test Frequency Plan, or 3) if specified within a Notice of Compliance letter. Testing conducted more than two months prior to the performance test due date does not satisfy this test due date requirement and will be considered an additional test.


Page 12 of 35

COMPLIANCE PLAN

14 Jul, 2015 16:28

CD-01 Facility Name: Ardent Mills Flour Mill


Subject Item: EU 003 Grain Cleaning - Cleaning Equipment

Associated Items: CE 003 Fabric Fi lter - Low Temperature, i.e., T<180 Degrees F

CE 004 Fabric Fi lter - Low Temperature, i.e., T<180 Degrees F



CE 007 Fabric Filt er - Low Temperature, i.e., T<180 Degrees F



CE 010 Fabric Fil ter - Low Temperature, i.e., T<180 Degrees F






SV 007 Cleaning E xhaust





NC/ CA



2.0 LIMIT Minn. R. 7011.1005, subp. 3(D) Opacity: less than or equal to 10 percent opacity from each stack

3.0 LIMIT Minn. R. 7011.1005, subp. 3(A) Opacity: less than or equal to 5 percent opacity from fugitive emissions.


5.0 CD Minn. R. 7007.0800 CONTROL EQUIPMENT REQUIREMENTS (at the time of permit issuance: CE003 - CE010, CE035; See GP001 for additional requirements)



7.0 CD Title I Condition: Avoid major source under 40 CFR 52.21 (b)(1 )(i) and Minn. R. 7007.3000; Avoid major source under 40 CFR 70.2 and Minn. R. 7007.0200





MINNESOTA POL.LUTION CONTROL AGENCY AIR QUALITY 520 LAFAYETTE ROAD ST. PAUL, MN 55155-419 4



Page 13 of 35 14 Jul, 2015 16:28







13.0 CD Minn. R. 7007.0800, subp. 2 Labeling Requirement: The Permittee shall permanently affix the emission unit number (EU003) and another unique number to each piece of equipment designated as part of "Grain Cleaning," for tracking purposes. Labeling must be completed within 120 days of permit issuance and within 30 days of startup of any new piece of equipment. The number can be affixed by placard, stencil, or other means, provided it is maintained and readable from a safe distance. If equipment is added, it shall be given a new number; numbers from replaced or removed equipment shall not be reused.

14.0 CD Minn. R. 7007.0800, subps. 4-5 Equipment List: The Permittee shall maintain a list of each piece of equipment designated under the "Grain Cleaning" category. The list shall include: - the type of equipment - the emission unit number (EU003) and another unique identifier - the date of installation and/or modification



MINNESOTA POLLUTION CONTROL AGENCY AIR QUALITY 520 LAFAYETTE ROAD ST. P AUL, M N 55155-4194



Subject Item: EU 004 Milling - Milling Equipment Associated Items: CE011 Fabric Filter - Low Temperature, i.e.

CE 012 Fabric Filter - Low Temperature, i.e.



















Page 14 of 35 14 Jul, 2015 16:28


T<180 Degrees F

T<180 Degrees F

T<180 Degrees F

T<180 Degrees F

T<180 Degrees F

T<180 Degrees F

T<180 Degrees F

T<180 Degrees F

, T<180 Degrees F

, T<180 Degrees F

, T<180 Degrees F

, T <180 Degrees F

, T <180 Degrees F

, T<180 Degrees F

, T<180 Degrees F

, T<180 Degrees F

, T<180 Degrees F

NCI CA





4.0 CD Minn. R. 7007.0800 CONTROL EQUIPMENT REQUIREMENTS (at the time of permit issuance: CE011, CE012, CE014 - CE024, CE037 - CE040; See GP001 for additional requirements)









Facility Name:

Permit Number:


03700020 - 004

Page 15 of 35 14 Jul, 2015 16:28





PM < 2.5 micron: greater than or equal to 94.05 percent control efficiency (capture efficiency x collection efficiency). Any new , replaced, or modified control equipment is also subject to this limit.


12.0 CD Minn. R. 7007.0800, subp. 2 Labeling Requirement: The Permittee shall permanently affix the emission unit number (EU004) and another unique number to each piece of equipment designated as part of "Milling," for tracking purposes. Labeling must be completed within 120 days of permit issuance and within 30 days of startup of any new piece of equipment. The num ber can be affixed by placard, stencil, or other means, provided it is maintained and readable from a safe distance. If equipment is added, it shall be given a new number; numbers from replaced or removed equipment shall not be reused.

13.0 CD Minn. R. 7007.0800, subps. 4-5 Equipment List: The Permittee shall maintain a list of each piece of equipment designated under the "Milling" category. The list shall include: - the type of equipment - the emission unit number (EU004) and another unique identifier - the date of installation and/or modification



Page 16 of 35 14 Jul, 2015 16:28



Subject Item: EU 005 Feed Loadout - Loading-Unloading Equipment


GP 004 Loadout

SV016 Feed Loadout

NCI CA



2.0 LIMIT Minn. R. 7011.1005, subp. 3(A) Opacity: less than or equal to 5 percent opacity from fugitive emissions from railcar loading.

3.0 LIMIT Minn. R. 7011.1005, subp. 3(B) Opacity: less than or equal to 10 percent opacity from fugitive emissions from truck loading.

4.0 LIMIT Minn. R. 7011.1005, subp. 3(D) Opacity: less than or equal to 10 percent opacity from the stack


6.0 CD Minn. R. 7007.0800 CONTROL EQUIPMENT REQUIREMENTS (See requirements under CE030)

7.0 CD Minn. R. 7019.3020(G) The Permittee shall route all emissions from components of "EU 005" to control equipment meeting the requirements of CE030 and EU005.

8.0 CD Minn. R. 7019.3020(G) The Permittee shall operate and maintain the fabric filter at all times that any process equipment controlled by the fabric filter is operating. The Permittee shall document periods of non-operation of the control equipment.

9.0 CD Minn. R. 7007.0800 TESTING REQUIREMENTS

10.0 S/A Minn. R. 7017.2020, subp. 1 Performance Test: due before end of each calendar 60 months starting 05/01/2012 to measure opacity from fugitive emissions from truck loading and rail loading. The performance tst shall be conducted at worst cast conditions as defined at Minn. R. 7017.2005, subp. 8, using EPA Method 9 or other method approved by MPCA in the performance test plan approval. Testing conducted during the two months prior to the performance test due date satisfies the performance test due date, and will not reset the test due date for future testing as required by: 1) this per mit, 2) by the most recently approved Performance Test Frequency Plan, or 3) if specified within a Notice of Compliance letter. Testing conducted more than two months prior to the performance test due date does not satisfy this test due date requirement and will be considered an additional test.


12.0 CD Minn.R. 7007.0800, subp. 2 Labeling Requirement: The Permittee shall permanently affix the emission unit number (EU005) and another unique number to each piece of equipment designated as part of "Feed Loadout," for tracking purposes. Labeling must be completed within 120 days of permit issuance and within 30 days of startup of any new piece of equipment. The number can be affixed by placard, stencil, or other means, provided it is maintained and readable from a safe distance. If equipment is added, it shall be given a new number; numbers from replaced or removed equipment shall not be reused.

13.0 CD Minn. R. 7007.0800, subps. 4-5 Equipment List: The Permittee shall maintain a list of each piece of equipment designated under the "Feed Loadout" category. The list shall include: - the type of equipment - the emission unit number (EU005) and another unique identifier - the date of installation and/or modification





Page 17 of 35 14 Jul, 2015 16:28


Subject Item: EU 006 Grain Handling - Material Handling Equipment


SV 002 Grain Handling Exhaust

NG/ CA



2.0 LIMIT Minn. R. 7011.1005, subp. 3(D) Opacity: less than or equal to 10 percent opacity from the stack

3.0 LIMIT Minn. R. 7011.1005, subp. 3(A) Opacity: less than or equal to 5 percent opacity from fugitive emissions.


5.0 CD Minn. R. 7007.0800 CONTROL EQUIPMENT REQUIREMENTS (a time of permit issuance: CE002; See GP001 for additional requirements)




The Permittee shall operate and maintain the fabric filter at all times that any process equipment controlled by the fabric filter is operating. The Permit tee shall document periods of non-operation of the control equipment.

8.0 LIMIT Title I Condition: Avoid major source under 40 CFR 52.21 (b)(1 )(i) and Minn. R. 7007.3000








13.0 CD Minn. R. 7007.0800, subp. 2 Labeling Requirement: The Permitt ee shall permanently affix the emission unit number (EU006) and another unique number to each piece of equipment designated as part of "Grain Handling," for tracking purposes. Labeling must be completed within 120 days of permit issuance and within 30 days of startup of any new piece of equipment. The number can be affixed by placard, stencil, or other means, provided it is maintained and readable from a safe distance. If equipment is added, it shall be given a new number; numbers from replaced or removed equipment shall not be reused.


Facility Name:

Permit Number:


03700020 - 004

Page 18 of 35 14 Jul, 2015 16:28


14.0 CD Minn. R. 7007.0800, subps. 4-5 Equipment List: The Permittee shall maintain a list of each piece of equipment designated under the "Grain Handling" category. The lis t shall include: - the type of equipment - the emission unit number (EU006) and another unique identifier - the date of installation and/or modification




Facility Name:

Permit Number:

Subject Item:

Associated Items:

Page 19 of 35

COMPLIANCE PLAN

14 Jul, 2015 16:28

CD-01 Ardent Mills Flour Mill

03700020 - 004

EU 007 Flour Storage and Loading - Loading-Unloading Equipment








GP 004 Loadout








NC/ CA



2.0 LIMIT Minn. R. 7011.1005, subp. 3(A) Opacity: less than or equal to 5 percent opacity from fugitive emissions from railcar loading.

3.0 LIMIT Minn. R. 7011.1005, subp. 3(B) Opacity: less than or equal to 10 percent opacity from fugitive emissions from truck loading.



6.0 CD Minn. R. 7007.0800 CONTROL EQUIPMENT REQUIREMENTS (at time of permit issuance: CE026 -CE029, CE033, CE034, CE036; See GP001 for additional requirements)





9.0 LIMIT Title I Condition: Avoid major source under 40 CFR 52.21 (b)(1 )(i) and Minn. R. 7007.3000



of 35 14 Jul, 2015 16:28




PM < 10 micron: greater than or equal to 93 percent control efficiency (capture efficiency x collection efficiency). Any ne w, replaced, or modified control equipment is also subject to this limit.


PM < 2.5 micron: greater than or equal to 93 percent control efficiency (capture efficiency x col lection efficiency). Any new, replaced, or modified control equipment is also subject to this limit.


14.0 CD Minn. R. 7007.0200, subp. 2 Labeling Requirement: The Permittee shall permanently affix the emission unit number (EU007) and another unique number to each piece of equipment designated as part of "Flour Storage and Loading," for tracking purposes. Labeling must be completed within 120 days of permit issuance and within 30 days of startup of any new piece of equipment. The nu mber can be affixed by placard, stencil, or other means, provided it is maintained and readable from a safe distance. If equipment is added, it shall be given a new number; numbers from replaced or removed equipment shall not be reused.

15.0 CD Minn. R. 7007.0800, subps. 4-5 Equipment List: The Permittee shall maintain a list of each piece of equipment designated under the "Flour Storage and Loading" category. The list shall include: - the type of equipment - the emission unit number (EU007) and another unique identifier - the date of installation and/or modification


MINNESOTA POLLUTION CONTROL AGENCY AIR QUALITY 520 LAFAYETTE ROAD ST. P AUL, MN 55155-4194

MINNESOTA POLLUTION CONTROL AGENCY Page 21 of 35 14 Jul, 2015 16:28 AIR QUALITY 520 LAFAYETTE ROAD

™""™" COMPLIANCE PLAN CD-01 Facility Name: Ardent Mills Flour Mill


Subject Item: EU 008 Pellet Cooling - Cooler

Associated Items: CE 031 Centrifug al Collector - Medium Efficiency


SV 014 Pellet C ooling Exhaust

NCI CA



2.0 LIMIT Minn. R. 7011.0715, subp. 1(A) Total Particulate Matter: less than or equal to 0.3 grains/dry standard cubic foot of exhaust gas unless required to further reduce emissions to comply with the less stringent limit of either Minn. R. 7011.0730 or Minn. R. 7011. 0735.

3.0 LIMIT Minn. R. 7011.0715, subp. 1(B) Opacity: less than or equal to 20 percent opacity from SV 014.


Process Throughput: less than or equal to 172590 tons/year using 12-month Rolling Sum of pellets cooled.


6.0 CD Minn. R. 7007.0800 CONTROL EQUIPMENT REQUIREMENTS (at time of permit issuance: CE031 & CE032; See GP002 for additional requirements)




The Permittee shall operate and maintain each cyclone at all times that any process equipment controlled by the device is operating. The Permittee shall document periods of non-operation of the control equipment.


Total Particulate Matter: greater than or equal to 96 percent control efficiency (capture efficiency x collection efficiency, for 2 centrifugal collectors in series). Any new, replaced, or modified control equipment is also subject to this limit.

10.0 LIMIT Title I Condition: Avoid major source under 40 CFR 52.21 (b)(1)(f) and Minn. R. 7007.3000; Avoid major source under 40 CFR 70.2 and Minn. R. 7007.0200

PM < 10 micron: greater than or equal to 64 percent control efficiency (capture efficiency x collection efficiency, for 2 centrifugal collectors in series). Any new, replaced, or modified control equipment is also subject to this limit.


PM < 2.5 micron: greater than or equal to 64 percent control efficiency (capture efficiency x collection efficiency, for 2 centrifugal collectors in series). Any new, replaced, or modified control equipment is also subject to this limit.


13.0 CD Minn. R. 7007.0800, subp. 2 Labeling Requirement: The Permit tee shall permanently a ffix the emission unit number (EU008) and another unique number to each piece of equipment designated as part of "Pellet Cooling," for tracking purposes. Labeling must be completed within 120 days of permit issuance. The num ber can be affixed by placard, stencil, or other means, provided it is maintained and readable from a safe distance. If equipment is added, it shall be given a new number; numbers from replaced or removed equipment shall not be reused.

of 35 14 Jul, 2015 16:28



14.0 CD Minn. R. 7007.0800, subps. 4-5 Equipment List: The Permittee shall maintain a list of each piece of equipment designated under the "Pellet Cooling" category. The list shall include: - the type of equipment - the emission unit number (EU008) and another unique identifier - the date of installation and/or modification




Daily Recordkeeping: Pellet Cooling Throughput

Each operating day, the Permittee shall record the quantity (weight) of pellets cooled at the facility on the previous day.

16.0 CD Minn. R. 7007.0800, subps. 4-5 Monthly Recordkeeping: Pellet Cooling Throughput

By the 15th day of each month, calculate and record the quantity (weight) of pellets cooled during the previous month, and during the previous 12 months (12-month rolling sum).

MINNESOTA POLLUTION CONTROL AGENCY AIR QUALITY 520 LAFAYETTE ROAD ST. P AUL, MN 55155-4194

of 35 14 Jul, 2015 16:28

COMPLIANCE PLAN CD-01 Facility Name; Ardent Mills Flour Mill


Subject Item: EU 009 Emergency Generator Associated Items: SV025 Emergency Generator

NC/ CA


1.0 CD Minn. R. 7007.0800 EMISSION LIMITS

2.0 LIMIT Minn. R. 7011.2300, subp. 1 Opacity: less than or equal to 20 percent opacity once operating temperatures have been attained.

3.0 LIMIT Minn. R. 7011.2300, subp. 2 Sulfur Dioxide: less than 0.50 lbs/million Btu heat input. The potential to emit from the unit is 0.29 lbs/million Btu heat input due to equipment design and allowable fuels.

4.0 CD Minn. R. 7007.0800 OPERATING CONDITIONS

5.0 CD Minn. R. 7005.0100, subp. 35a No. 2 fuel oil/diesel fuel meeting the requirements of 40 CFR Section 80.510(c) only by design.


Operating Hours: less than or equal to 500 hours/year using 12-month Rolling Sum to be calculated by the 15th day of each month.

7.0 CD Minn. R. 7007.0800 RECORDKEEPING REQUIREMENTS

8.0 CD Title I Condition: Avoid major source under 40 CFR 52.21 (b)(1)(i) and Minn. R. 7007.3000; Avoid major source under 40 CFR 70.2 and Minn. R. 7007.0200; Minn. R. 7007.0800, subps. 4-5

Hours of Operation: The Permittee shall maintain documentation on site that the unit is an emergency generator by design that qualifies under the U.S. EPA memorandum entitled "Calculating Potential to Emit (PTE) for Emergency Generators" dated September 6,1995, limiting operation to 500 hours per year.

9.0 CD Minn. R. 7007.0800, subp. 5 The Permittee shall keep records of fuel type and usage on a monthly basis.

10.0 CD Minn. R. 7007.0800 NESHAP SUBPART ZZZZ REQUIREMENTS - Enforcement Not Delegated to MPCA

11.0 CD 40 CFR Section 63.6603(a); 40 CFR Sect ion 63.6640; and Table 2d to subpart ZZZZ of Part 63; Minn. R. 7011.8150

Change oil and filter every 500 hours of operation or annually, whichever comes first. The Permittee has the option of utilizing an oil analysis program in order to extend the oil change requirement as described below.

12.0 CD 40 CFR Section 63.6603(a); 40 CFR Section 63.6640; and Table 2d to subpart ZZZZ of Part 63; Minn. R. 7011.8150

Inspect air cleaner every 1,000 hours of operation or annually, whichever comes first, and replace as necessary.

13.0 CD 40 CFR Section 63.6603(a); 40 CFR Section 63.6640; and Table 2d to subpart ZZZZ of Part 63; Minn. R. 7011.8150

Inspect all hoses and belts every 500 hours of operation or annually, whichever comes first, and replace as necessary.

14.0 CD 40 CFR Section 63.6604(b); Minn. R. 7011.8150

By January 1, 2015 the Permittee shall only use diesel fuel that meets the requirements in 40 CFR Section 80.510(b) for nonroad diesel fuel, except that any existing diesel fuel purchased or otherwise obtained prior to January 1, 2015 may be used until depleted.

15.0 CD 40 CFR Section 63.6605(a); Minn. R. 7011.8150

At all times the Permittee shall operate and maintain any affected source, including associated air pollution control equipment and monitoring equipment, in a manner consistent with safety and good air pollution control practices for minimizing emissions. The general duty to minimize emissions does not require the Permittee to make any further efforts to reduce emissions if levels required by this standard have been achieved. Determination of whether such operation and maintenance procedures are being used will be based on information available to the Administrator which may include, but is not limited to, monitoring results, review of operation and maintenance procedures, review of operation and maintenance records, and inspection of the source.


MINNESOTA POLLUTION CONTROL AGENCY AIR QUALITY 520 LAFAYETTE ROAD ST. PAU L, MN 55155-4194

Page 24 of 35 14 Jul, 2015 16:28


Permit Number:


03700020 - 004

16.0 CD 40 CFR Section 63.6625(e); Minn. R. 7011.8150

The Permittee shall operate and maintain the stationary RICE and after-treatment control device (if any) according to the manufacturer's emission-related written instructions or develop a maintenance plan which shall provide to the extent practicable for the maintenance and operation of the engine in a manner consistent with good air pollution control practice for minimizing emissions.

17.0 CD 40 CFR Section 63.6625(h); Minn. R. 7011.8150

The Permittee shall minimize the engine's time spent at idle during startup and minimize the engine's startup time to a period needed for appropriate and safe loading of the engine, not to exceed 30 minutes, after which time the emission standards applicable to all times other than startup apply.

18.0 CD 40 CFR Section 63.6625(i); Minn. R. 7011.8150

The Permittee has the option of utilizing an oil analysis program in order to extend the specified oil change requirement. The oil analysis shall be performed at the same frequency specified for changing the oil. The analysis program shall at a minimum analyze the following 3 parameters: Total Base Number, viscosity, and percent water content. The condemning limits for these parameters are as follows: Total Base Number is less than 30 percent of the Total Base Number of the oil when new; viscosity of the oil has changed by more than 20 percent from the viscosity of the oil when new; or percent water content (by volume) is greater than 0.5.

(continued below)



If none of the condemning limits are exceeded, the Permittee is not required to change the oil. If any of the limits are exceeded, the Permittee shall change the oil within 2 business days of receiving the results of the analysis; if the engine is not in operation when the results of the analysis are received, the Permittee shall change the oil within 2 business days or before commencing operation, whichever is later. The Permittee shall keep records of the parameters that are analyzed as part of the program, the results of the analysis, and the oil changes for the engine. The analysis program shall be part of the maintenance plan for the engine.

20.0 CD 40 CFR Section 63.6640(a); 40 CFR pt. 63 subp. ZZZZ, Table 6

The Permittee shall operate and maintain the stationary RICE according to the manufacturer's emission-related operation and maintenance instructions; or the Permittee shall develop and follow a maintenance plan which shall provide to the extent practicable for the maintenance and operation of the engine in a manner consistent with good air pollution control practice for minimizing emissions.

21.0 CD 40 CFR Section 63.6665 and Table 8 to Subpart ZZZZ of Part 63; 40 CFR Section 63.1 - 63.15; Minn. R. 7011.8150

The Permittee shall comply with the General Provisions in 40 CFR Section 63.1 through 63.15, as stated in 40 CFR pt. 63, subp. ZZZZ, Table 8, as applicable.

22.0 CD Minn. R. 7007.0800 REQUIREMENTS FOR EMERGENCY STATIONARY RICE

23.0 CD 40 CFR Section 63.6625(f); Minn. R. 7011.8150

The Permittee shall install a non-resettable hour meter if one is not already installed by May 3, 2013.


The Permittee shall operate the emergency stationary RICE according to the requirements in paragraphs 40 CFR Section 63.6640 (f)(1) through (4). Any operation other than emergency operation, maintenance and testing, emergency demand response, and operation in non-emergency situations for 50 hours per year, as described in 40 CFR Section 63.6640(f)(1) through (4), is prohibited. If the engine is not operated according to the requirements in 40 CFR Section 63.6640(f)(1) through (4), the engine will not be considered an emergency engine under this subpart and will need to meet all requirements for non-emergency engines.




Page 25 of 35 14 Jul, 2015 16:28


25.0 CD 40 CFR Section 63.6640(f)(1) -(2); Minn. R. 7011.8150

(1) There is no time limit on the use of emergency stationary RICE in emergency situations.

ON MAY 1, 2015, THE D.C. CIRCUIT VACATED THE PROVISIONS OF 40 CFR SECTION 63.6640(f)(2) THAT ALLOW OPERATION OF AN EMERGENCY GENERATOR WITHOUT EMISSIONS CONTROLS FOR UP TO 100 HOURS PER YEAR AS PART OF AN EMERGENCY DEMAND-RESPONSE PROGRAM. AS OF THE DATE OF ISSUANCE OF AIR EMISSION PERMIT NO. 03700020-004, THE COURT HAD NOT ISSUED THE MANDATE IMPLEMENTING ITS DECISION. THESE PROVISIONS REMAIN IN EFFECT UNTIL THE COURT ISSUES THE MANDATE. AFTER THAT ACTION, THE PROVISIONS WILL NO LONGER BE EFFECTIVE.

(2) The Permittee may operate the emergency stationary RICE for any combination of the purposes specified in 40 CFR Section 63.6640(f)(2)(i) through (iii) for a maximum of 100 hours per calendar year. Any operation for non-emergency situations as allowed by 40 CFR Section 63.6640(f)(3) and (4) counts as part of the 100 hours per calendar year allowed by this paragraph (f)(2).

26.0 CD 40 CFR Section 63.6640(f)(2)(i); Minn. R. 7011.8150

2(i) The Permittee may operate the emergency stationary RICE for the purpose of maintenance checks and readiness testing, provided that the tests are recommended by Federal, State or local government, the manufacturer, the vendor, the regional transmission organization or equivalent balancing authority and transmission operator, or the insurance company associated with the engine. The Permittee may petition the Administrator for approval of additional hours to be used for maintenance checks and readiness testing, but a petition is not required if the Permittee maintains records indicating that Federal, State, or local standards require maintenance and testing of emergency RICE beyond 100 hours per calendar year.

27.0 CD 40 CFR Section 63.6640(f)(2)(ii) -(2)(iii); Minn. R. 7011.8150

2(ii) Emergency stationary RICE may be operated for emergency demand response for periods in which the Reliability Coordinator under the North American Electric Reliability Corporation (NERC) Reliability Standard EOP-002-3, Capacity and Energy Emergencies (incorporated by reference, see 40 CFR Section 63.14), or other authorized entity as determined by the Reliability Coordinator, has declared an Energy Emergency Alert Level 2 as defined in the NERC Reliability Standard EOP-002-3. 2(iii) Emergency stationary RICE may be operated for periods where there is a deviation of voltage or frequency of 5 percent or greater below standard voltage or frequency.

28.0 CD 40 CFR Section 63.6640(f)(4); Minn. R. 7011.8150

(4) The Permittee may operate the emergency stationary RICE up to 50 hours per year in non-emergency situations, but those 50 hours are counted towards the 100 hours per calendar year provided for maintenance and testing and emergency demand response provided in 40 CFR Section 63.6640(f)(2). Except as provided in 40 CFR Section 63.6640(f)(4)(i) and (ii), the 50 hours per year for non-emergency situations cannot be used for peak shaving or non-emergency demand response, or to generate income for a facility to supply power to an electric grid or otherwise supply power as part of a financial arrangement with another entity.

29.0 CD 40 CFR Section 63.6640(f)(4)(i); Minn. R. 7011.8150

4(i) Prior to May 3, 2014, the 50 hours per year for non-emergency situations can be used for peak shaving or non-emergency demand response to generate income for a facility, or to otherwise supply power as part of a financial arrangement with another entity if the engine is operated as part of a peak shaving (load management program) with the local distribution system operator and the power is provided only to the facility itself or to support the local distribution system.

30.0 CD 40 CFR Section 63.6640(f)(4)(ii); Minn. R. 7011.8150

4(i) The 50 hours per year for nonemergency situations can be used to supply power as part of a financial arrangement with another entity if all of the following conditions are met: (A) The engine is dispatched by the local balancing authority or local transmission and distribution system operator. (B) The dispatch is intended to mitigate local transmission and/or distribution limitations so as to avert potential voltage collapse or line overloads that could lead to the interruption of power supply in a local area or region. (C) The dispatch follows reliability, emergency operation or similar protocols that follow specific NERC, regional, state, public utility commission or local standards or guidelines. (D) The power is provided only to the facility itself or to support the local transmission and distribution system.

(continued below)




Page 26 of 35 14 Jul, 2015 16:28


31.0 CD 40 CFR Section 63.6640(f)(4)(ii); Minn. R. 7011.8150


4(ii) (E) The owner or operator identifies and records the entity that dispatches the engine and the specific NERC, regional, state, public utility commission or local standards or guidelines that are being followed for dispatching the engine. The local balancing authority or local transmission and distribution system operator may keep these records on behalf of the engine owner or operator.

32.0 CD Minn. R. 7007.0800 NESHAP RECORDKEEPING REQUIREMENTS


The Permittee shall demonstrate continuous compliance with teach emission limitation and operating limitation in Table 2d of 40 CFR pt. 63, subp. ZZZZ that apply according to methods specified in Table 6 of 40 CFR pt. 63, subp. ZZZZ.


The Permittee shall keep the following records: 1. A copy of each notification and report submitted to comply with 40 CFR pt. 63, subp. ZZZZ, including all documentation supporting any Initial Notification or Notification of Compliance Status submitted according to the requirement in 40 CFR Section 63.10(b)(2)(xiv). 2. Records of the occurrence and duration of each malfunction of operation (i.e., process equipment) or the air pollution control and monitoring equipment. 3. Records of performance tests and performance evaluations as required in 40 CFR Section 63.10(b)(2)(viii). 4. Records of all required maintenance performed on the air pollution control and monitoring equipment. 5. Records of actions taken during periods of malfunction to minimize emissions in accordance with 40 CFR Section 63.6605(b), including corrective actions to restore malfunctioning process and air pollution control and monitoring equipment to its normal or usual manner of operation.


The Permittee shall keep records of the maintenance conducted on the stationary RICE in order to demonstrate that the Permittee operated and maintained the stationary RICE and after-treatment control device (if any) according to the maintenance plan.


The Permittee shall keep records of the hours of operation of the engine that are recorded through the non-resettable hour meter. The Permittee shall document how many hours are spent for emergency operation, including what classified the operation as emergency and how many hours are spent for non-emergency operation. If the engine is used for the purposes specified in 40 CFR Section 63.6640(f)(2)(ii) or (iii) or 40 CFR Section 63.6640(f)(4)(ii), the Permittee shall keep records of the notification of the emergency situation, and the date, start time, and end time of engine operation for these purposes.

37.0 CD 40 CFR Section 63.6660; 40 CFR Section 63.10(b)(1); Minn. R. 7011.8150

The Permittee shall keep records in a form suitable and readily available for expeditious review according to 40 CFR Section 63.10(b)(1).

As specified in 40 CFR Section 63.10(b)(1), the Permittee shall keep each record for 5 years following the date of each occurrence, measurement, maintenance, corrective action, report or record.

38.0 CD Minn. R. 7007.0800 REPORTING AND NOTIFICATION REQUIREMENTS


The Permittee shall report each instance in which the stationary RICE did not meet each applicable operating limitation. These instances are deviations from the emission and operating limitations. These deviations shall be reported with the deviations report required by Table A (listed at the Total Facility level) and Table B of this permit. These deviations shall be reported according to the requirements in 40 CFR Section 63.6650.

40.0 CD Minn. R. 7007.0800 APPLICABLE GENERAL PROVISIONS

41.0 CD Minn. R. 7007.0800 OPERATION AND MAINTENANCE REQUIREMENTS


Circumvention. The Permittee shall not build, erect, install, or use any article, machine, equipment, or process to conceal an emission that would otherwise constitute noncompliance with a relevant standard. Such concealment includes, but is not limited to: 1) The use of diluents to achieve compliance with a relevant standard based on the concentration of a pollutant in the effluent discharged to the atmosphere or 2) The use of gaseous diluents to achieve compliance with a relevant standard for visible emissions. ,

43.0 CD 40 CFR Section 63.5(b)(3); Minn. R. 7011.7000

Prior to construction or reconstruction of a major-emitting "affected source" under the promulgated MACT standards, the Permittee must apply for and obtain an air emission permit.


Page 27 of 35 14 Jul, 2015 16:28


Permit Number:


03700020 - 004


The Permittee must submit notification according to 40 CFR Section 63.9(b) if the Permittee constructs or reconstructs a source such that the source becomes an affected source subject to a standard.


After the effective date of any relevant standard promulgated under 40 CFR pt. 63, equipment added (or a process change) to an affected source that is within the scope of the definition of affected source under the relevant standard must be considered part of the affected source and subject to all provisions of the relevant standard established for that affected source.

46.0 CD 40 CFR Section 63.6(e)(1)(i); Minn. R. 7011.7000

Proper Operation and Maintenance. At all times, including periods of startup, shutdown, and malfunction, the Permittee shall operate and maintain the emission unit subject to the MACT standard and any associated air pollution control equipment and monitoring equipment, in a manner consistent with safety and good air pollution control practices for minimizing emissions at least to the levels required by any relevant standard and as detailed in 40 CFR Section 63.6(e)(1)(i)-(iii).

47.0 CD 40 CFR Section 63.6(e)(1)(H); Minn. R. 7011.7000

Malfunctions shall be corrected as soon as practicable after their occurrence.

48.0 CD 40 CFR Section 63.6(e)(3)(i); Minn. R. 7011.7000

Startup, shutdown, and malfunction plan (SSMP). The Permittee shall prepare and implement a written SSMP that describes, in detail, procedures for operating and maintaining the source during periods of startup, shutdown, and malfunction; and a program of corrective action for malfunctioning process, air pollution control, and monitoring equipment used to comply with the relevant standard. The plan requirements are further described in 40 CFR Section 63.6(e)(3)(i).

49.0 CD 40 CFR Section 63.6(e)(3)(iii); Minn. R. 7011.7000

When actions taken by Permittee during a startup or shutdown (and the startup or shutdown causes the source to exceed any applicable emission limitation), or malfunction (including actions taken to correct a malfunction) are consistent with the procedures specified in the affected source's SSMP, the Permittee must keep records which demonstrate that the procedures specified in the SSMP were followed and describes the actions taken for that event.

50.0 CD 40 CFR Section 63.6(e)(3)(iv); Minn. R. 7011.7000

If an action taken by the Permittee during a startup, shutdown, or malfunction (including an action taken to correct a malfunction) is not consistent with the procedures specified in the affected source's SSMP, and the source exceeds any applicable emission limitation in the relevant emission standard, then the Permittee must record the actions taken for that event and must report such actions as specified in 40 CFR Section 63.10(d)(5).

51.0 CD 40 CFR Section 63.6(e)(3)(v); Minn. R. 7011.7000

The Permittee must maintain at the affected source a current SSMP and must make the plan available upon request for inspection and copying by the Administrator. In addition, if the SSMP is subsequently revised, the Permittee must maintain at the affected source each previous (i.e., superseded) version of the SSMP, and must make each such previous version available for inspection and copying for a period of 5 years after revision of the SSMP.

52.0 CD 63.6(e)(3)(vi); Minn. R. 7011.7000 To satisfy the requirements of this section to develop a SSMP, the Permittee may use a standard operating procedures (SOP) manual, or other plan, provided the alternative plans meet all the requirements and are made available for inspection or submission.

53.0 CD 63.6(e)(3)(vii); Minn. R. 7011.7000

The Administrator may require that a Permittee make changes to the SSMP. Revisions to the SSMP will be required if the plan: 1) Does not address a startup, shutdown, or malfunction event that has occurred; 2) Fails to provide for the operation of the source (including associated air pollution control and monitoring equipment) during a startup, shutdown, or malfunction event in a manner consistent with the general duty to minimize emissions established by 40 CFR Section 63.6(e)(3)(iii)-63.6(e)(3)(ix) (e)(1)(i); 3) Does not provide adequate procedures for correcting malfunctioning process and/or air pollution control and monitoring equipment as quickly as practicable; or 4) Includes an event that does not meet the definition of startup, shutdown, or malfunction.

54.0 CD 40 CFR Section 63.6(e)(3)(viii); Minn. R. 7011.7000

The Permittee may periodically revise the SSMP as necessary to reflect changes in equipment or procedures at the affected source. Each such revision to a SSMP must be reported in the semiannual report required by 40 CFR Section 63.10(d)(5). If the SSMP fails to address or inadequately addresses an event that meets the characteristics of a malfunction but was not included in the SSMP, the Permittee shall revise the SSMP within 45 days after the event in accordance with 40 CFR Section 63.6(e)(3)(viii).

55.0 CD 40 CFR Section 63.6(e)(3)(ix); | Minn. R. 7011.7000

Any revisions made to the SSMP shall not be deemed to constitute permit revisions under 40 CFR pt. 70 or pt. 71.




Page 28 of 35 14 Jul, 2015 16:28



Applicability. The non-opacity emission standards set forth in 40 CFR Section 63.6(f)(1 )-(3) shall apply at all times except during periods of startup, shutdown, and malfunction, and as otherwise specified in an 40 CFR pt. 63, Subpart ZZZZ.


Methods for determining compliance will be, in part, based on the results of performance tests, conformance with operation and maintenance requirements, review of records, and inspection of the source as specified in 40 CFR Section 63.6(f)(2) The Permittee many use the results of performance testing conducted previously if it meets the requirements of 40 CFR Section 63.6(f)(iii).


Finding of compliance. The Adminis trator will make a finding concerning an affected source's compliance with a non-opacity emission standard upon obtaining all the compliance information required by the relevant standard.

59.0 CD 40 CFR Section 63.6(g); Minn. R. 7011.7000

The Permittee may establish the use of an alternative non-opacity emission standard by following the procedure specified in 40 CFR Section 63.6(g).


The Administrator may grant an extension of compliance with an emission standard, as specified in 40 CFR Section 63.6(i).

61.0 CD 40 CFR Section 63.6(i)(1); Minn. R. 7011.7000

Until an extension of compliance has been granted by the Administrator, the Permittee shall comply with all applicable requirements of 40 CFR pt. 63, subp. A.

62.0 CD Minn. R. 7007.0800 PERFORMANCE TESTING REQUIREMENTS


Notification of performance test. 1) The Permittee must notify the Administrator of their intention to conduct a performance test at least 60 calendar days before the performance test is initially scheduled to begin. 2) In the event the Permittee is unable to conduct the performance test on the date specified due to unforeseeable circumstances, the Permittee must notify the Administrator as soon as practicable and without delay prior to the scheduled performance test date and specify the date when the performance test is rescheduled.

64.0 CD 40 CFR Section 63.7(c)(2); Minn. R. 7017.2015

Submission of site-specific test plan. Before conducting a required performance test, the Permittee shall develop and, if requested by the Administrator, shall submit a site-specific test plan for approval in accordance with the requirements of 40 CFR Section 63.7(c)(2).


Approval of site-specific test plan. The Administrator will notify the Permittee of approval or intention to deny approval of the site-specific test plan (if review of the site-specific test plan is requested) within 30 calendar days after receipt of the original plan and within 30 calendar days after receipt of any supplementary information.

66.0 CD 40 CFR Section 63.7(d); Minn. R. 7017.2015

Performance testing facilities. The Permittee, at the request of the Administrator, shall provide performance testing facilities as specified in 40 CFR Section 63.7(d).

67.0 CD 40 CFR Section 63.7(e)(1)-(2); Minn. R. 7017.2015

Conduct of performance tests. 1) Performance tests shall be conducted under based on representative of the affected source. Operations during periods of startup, shutdown, and malfunction shall not constitute representative conditions for the purpose of a performance test. 2) Performance tests shall be conducted and data shall be reduced in accordance with the test methods and procedures set forth in 40 CFR Section 63.7(e), in each relevant standard, and, if required, in applicable appendices of 40 CFR parts 51, 60, 61. The Commissioner has delegation to approve a minor or intermediate modification (if validated by Method 301) to a reference method or specified monitoring procedure as allowed for in 40 CFR Section 63.7(e)(2)(i) and (ii).

68.0 CD 40 CFR Section 63.7(e)(3); Minn. R. 7017.2015

Unless otherwise specified in a relevant standard or test method, each performance test shall consist of three separate runs using the applicable test method. Each run shall be conducted for the time and under the conditions specified in the relevant standard. For the purpose of determining compliance with a relevant standard, the arithmetic mean of the results of the three runs shall apply, unless otherwise approved in accordance with provisions of 40 CFR Section 63.7(e)(3).




Page 29 of 35 14 Jul, 2015 16:28



Data analysis, recordkeeping, and reporting. Unless otherwise specified in a relevant standard or test method, or as otherwise approved by the Administrator in writing, results of a performance test shall include the analysis of samples, determination of emissions, and raw data. A performance test is completed when field sample collection is terminated. The Permittee shall report the results of the performance test to the Administrator before the close of business on the 60th day following the completion of the performance test, unless specified otherwise in a relevant standard or as approved otherwise in writing. The results of the performance test shall be submitted as part of the notification of compliance status required under 40 CFR Section 63.9(h) to the appropriate permitting authority.


Waiver of performance tests. Until a waiver of a performance testing requirement has been granted by the Administrator under 40 CFR Section 63.7(h), the Permittee remains subject to the requirements of 40 CFR Section 63.7(h).

71.0 CD Minn. R. 7007.0800 MONITORING REQUIREMENTS

72.0 CD 40 CFR 63.8(a)(2); Minn. R. 7017.2015

All CMS required under relevant standards shall be subject to the provisions of 40 CFR Section 63.8 upon promulgation of performance specifications for CMS as specified in the relevant standard or otherwise by the Administrator. The performance specifications in 40 CFR pt. 60, Appendix B apply.

73.0 CD 40 CFR Section 63.8(b)(1); Minn. R. 7017.2015 .

Conduct of monitoring. Monitoring shall be conducted as set forth in 40 CFR Section 63.8(a)(b)(1).

74.0 CD 40 CFR Section 63.8(c)(1)-(3); Minn. R. 7017.2015

Operation and maintenance of continuous monitoring systems. The Permittee shall maintain and operate each CMS in a manner consistent with good air pollution control practices. 1) The Permittee must keep the necessary parts for routine repairs of the affected CMS equipment readily available. 2) The Permittee must ensure the read out, or other indication of operation, from any CMS required for compliance with the emission standard is readily accessible on site for operational control or inspection. 3) All CMS shall be installed, operational, and the data verified prior to or in conjunction with conducting performance tests. Verification of operational status shall, at a minimum, include completion of the manufacturer's written specifications or recommendations for installation, operation, and calibration of the system.


6) The Permittee of a CMS that is not a CPMS, must check the zero (low-level) and high-level calibration drifts at least once daily in accordance with the written procedure specified in the performance evaluation plan.

76.0 CD 40 CFR Section 63.8(c)(7)(i); Minn. R. 7017.2015

7) A CMS is out of control if: i) The zero (low-level), mid-level (if applicable), or high-level calibration drift (CD) exceeds two times the applicable CD specification in the applicable performance specification or in the relevant standard; or ii) The CMS fails a performance test audit (e.g., cylinder gas audit), relative accuracy audit, relative accuracy test audit, or linearity test audit; or iii) The COMS CD exceeds two times the limit in the applicable performance specification in the relevant standard.

77.0 CD 40 CFR Section 63.8(c)(7)(ii); Minn. R. 7017.2015

When the CMS is out of control, the Permittee shall take the necessary corrective action and shall repeat all necessary tests which indicate that the system is out of control until the performance requirements are below the applicable limits. The beginning of the out-of-control period is the hour the Permittee conducts a performance check (e.g., calibration drift) that indicates an exceedance of the performance requirements established under this part. The end of the out-of-control period is the hour following the completion of corrective action and successful demonstration that the system is within the allowable limits. During the period the CMS is out of control, recorded data shall not be used in data averages and calculations, or to meet any data availability requirement.


The Permittee shall submit all information concerning out-of-control periods, including start and end dates and hours and descriptions of corrective actions taken, in the excess emissions and continuous monitoring system performance report.

MINNESOTA POLLUTION CONTROL AGENCY AIR QUALITY 520 LAFAYETTE ROAD ST. PAUL, M N 55155-4194

Page 30 of 35 14 Jul, 2015 16:28


Permit Number:


03700020 - 004


The Permittee shall develop and implement a CMS quality control program. As part of the quality control program, the Permittee shall develop and submit to the Aministrator for approval upon request a site-specific performance evaluation test plan for the CMS performance evaluation required in 40 CFR Section 63.8(e)(3)(i). Each quality control program shall include, at a minimum, a written protocol that describes procedures for each of the following operations: i) Initial and any subsequent calibration of the CMS; ii) Determination and adjustment of the calibration drift of the CMS; iii) Preventive maintenance of the CMS, including spare parts inventory; iv) Data recording, calculations, and reporting; v) Accuracy audit procedures, including sampling and analysis methods; and vi) Program of corrective action for a malfunctioning CMS.


The Permittee shall keep these written procedures on record for the life of the affected source, to be made available for inspection, upon request. The Permittee shall keep previous versions of the performance evaluation plan on record to be made available for inspection upon request, for a period of 5 years after each revision to the plan.

81.0 CD 40 CFR Section 63.8(e)(1) & (2); Minn. R. 7017.2015

Performance evaluation of continuous monitoring systems: 1) When required by a relevant standard, and at any other time the Administrator may require, the Permittee shall conduct a performance evaluation of the CMS according to the applicable specifications and procedures described in 40 CFR Section 63.8(e) or in the relevant standard. 2) Notification of performance evaluation. The Permittee shall notify the Administrator in writing of the date of the performance evaluation simultaneously with the notification of the performance test date or at least 60 days prior to the date the performance evaluation is scheduled to begin if no performance test is required.


3) Reporting performance evaluation results. The Permittee shall furnish the Administrator a copy of a written report of the results of the performance evaluation simultaneously with the results of the performance test or within 60 days of completion of the performance evaluation if no test is required, unless otherwise specified in a relevant standard.


Use of an alternative monitoring method. Until permission to use an alternative monitoring procedure has been granted by the Administrator under 40 CFR Sections 63.8(f)(1)-(6), as appropriate, the Permittee remains subject to the requirements of 40 CFR Section 63.8 and the relevant standard.


Reduction of monitoring data. The Permittee must reduce the monitoring data as specified in 40 CFR Section 63.8(g)(1)-(5).

85.0 CD Minn. R. 7007.0800 NOTIFICATION REQUIREMENTS


The Permittee of a new or reconstructed major affected source for which an application for approval of construction or reconstruction is required under 40 CFR Section 63.5(d) must provide the following information in writing to the Administrator: 1) A notification of intention to construct a new major-emitting affected source, reconstruct a major-emitting affected source, or reconstruct a major source such that the source becomes a major-emitting affected source; and 2) A notification of the actual date of startup of the source, delivered or postmarked within 15 calendar days after that date.


Notification of performance test. The Permittee shall notify the Administrator in writing of his or her intention to conduct a performance test at least 60 calendar days before the performance test is scheduled to begin.

88.0 CD 40 CFR Section 63.9(g)(1) & (3); Minn. R. 7019.0100

Additional notification requirements for sources with CMS. The Permittee shall submit to the Administrator written notification as follows: 1) A notification of the date the CMS performance evaluation under 40 CFR Section 63.8(e) is scheduled to begin, submitted simultaneously with the notification of the performance test date required under 40 CFR Section 63.7(b). If no performance test is required, or if the requirement to conduct a performance test has been waived, the Permittee shall notify the Administrator in writing of the date of the performance evaluation at least 60 calendar days before the evaluation is scheduled to begin; 2) A notification that the criterion necessary to continue use of an alternative to relative accuracy testing, as provided by 40 CFR Section 63.8(f)(6), has been exceeded. The notification shall be delivered or postmarked not later than 10 days after the occurrence of such exceedance.

MINNESOTA POLLUTION CONTROL AGENCY Page31of35 14 Jul, 2015 16:28 AIR QUALITY 520 LAFAYETTE ROAD

ST PAUL, MN -SS155-4IM COMPLIANCE PLAN CD-01




Notification of compliance status. Each time a notification of compliance status is required under 40 CFR pt. 63, subp. A, the Permittee shall submit to the Administrator a notification of compliance status containing the information required by 40 CFR Section 63.9(h), signed by the responsible official who shall certify its accuracy, attesting to whether the source has complied with the relevant standard. The notification must be sent by the 60th day following the completion of the relevant compliance demonstration activity specified in the relevant standard. If no performance test is required but opacity or visible emission observations are required, the notification of compliance status shall be sent by the 30th day following the completion of opacity or visible emission observations. Notifications may be combined as long as the due date requirement for each notification is met.

90.0 CD 40 CFR Section 63.9(j); Minn. R. 7019.0100

Notification. Any change in the information already provided under 40 CFR Section 63.9 shall be provided to the Administrator in writing within 15 calendar days after the change.

91.0 CD Minn. R. 7007.0800 RECORDKEEPING AND REPORTING REQUIREMENTS


The Permittee shall submit each report to the Administrator.

93.0 CD 40 CFR Section 63.10(b)(1); Minn. R. 7019.0100, subp. 2(B)

Recordkeeping. The Permittee shall maintain files of all information (including all reports and notifications) required by 40 CFR pt. 63 in a form suitable and readily available for expeditious inspection and review. The files shall be retained for at least 5 years following the date of each occurrence, measurement, maintenance, corrective action, report, or record. At a m inimum, the most recent 2 years of data must be retained on site.


The Permittee shall maintain, at a minimum, the following information in the files: 1) the occurrence and duration of each startup, shutdown, or malfunction of operation; 2) the occurrence and duration of each malfunction of the air pollution control equipment; 3) all maintenance performed on the pollution control equipment; 4) actions taken during periods of startup, shutdown, and malfunction when such actions are different from the procedures specified in the affected source's startup, shutdown, and malfunction plan (SSMP). In this case, the Permittee shall report this action within 2 days of occurrence and follow by a written notification within 7 days of occurrence. 5) all information necessary to demonstrate conformance with the affected source's SSMP and actions taken in accordance with SSMP; 6) each period during which a continuous monitoring system (CMS) is malfunctioning or inoperative;

(continued below)



7) all required measurements needed to demonstrate compliance with a relevant standard; 8) all results of performance test, CMS performance evaluations, and opacity and visible emission observations; 9) all measurements as may be necessary to determine the conditions of performance tests and performance evaluations; 10) all CMS calibration checks; 11) all adjustments and maintenance performed on CMS; 12) any information demonstrating whether a source is meeting the requirements for a waiver of record keeping or reporting requirements under this part; 13) all documents supporting initial notifications and notifications of compliance status.

96.0 CD 40 CFR Section 63.10(c); Minn. R. 7019.0100

Additional recordkeeping requirements for sources with continuous monitoring systems. The Permittee shall maintain records as specified within 40 CFR Sect ion 63.10(c); including CMS measurements (including monitoring data recorded during breakdowns and out-of-control periods) and corrective actions.

97.0 CD 40 CFR Section 63.10(d)(1); Minn. R. 7019.0100

Notwithstanding the requirements in 40 CFR Sections 63.10(d) and 63.10(e), the Permittee shall submit reports to the Administrator in accordance with the reporting requirements in the relevant standard.

98.0 CD 40 CFR 63.10(d)(4); Minn. R. 7019.0100

Progress reports. The Permittee who is required to submit progress reports as a condition of receiving an extension of compliance under 40 CFR Section 63.6(i) shall submit such reports to the Administrator by the dates specified in the written extension of compliance.

MINNESOTA POLLUTION CONTROL AGENCY Page 32 Qf 35 14 Jul, 2015 16:28 AIR QUALITY 520 LAFAYETTE ROAD

COMPLIANCE PLAN C D-01 Facility Name: Ardent Mills Flour Mill


99.0 CD 40 CFR Section 63.10(d)(5)(i); Minn. R. 7019.0100

Periodic startup, shutdown, and malfunction reports. If actions taken by a Permittee during a startup or shutdown (and the startup or shutdown causes the source to exceed any applicable emission limitation in the relevant emission standards), or malfunction of an affected source (including actions taken to correct a malfunction) are consistent with the procedures specified in the source's startup, shutdown, and malfunction plan, the Permittee shall state such information in a startup, shutdown, and malfunction report.


Actions taken to minimize emissions during such startups, shutdowns, and malfunctions shall be summarized in the report and may be done in checklist form. Such a report shall also include the number, duration, and a brief description for each type of malfunction which occurred during the reporting period and which caused or may have caused any applicable emission limitation to be exceeded. Reports shall only be required if a startup or shutdown caused the source to exceed any applicable emission limitation, or if a malfunction occurred during the reporting period. The startup, shutdown, and malfunction report shall consist of a letter, containing the name, title, and signature of the Permittee who is certifying its accuracy, that shall be submitted to the Administrator semiannually.


Startup, shutdown, and malfunction report: due 30 days following the end of each calendar half year. The Permittee may submit this simultaneously with the excess emissions and continuous monitoring system performance (or other) reports. The Permittee may request approval to reduce the frequency of reporting the procedures specified in 40 CFR Section 63.10(e)(3).

102.0 CD 40 CFR Section 63.10(d)(5)(H); Minn. R. 7019.0100, subp. 2(B)

Immediate startup, shutdown, and malfunction reports. Notwithstanding theallowance to reduce the frequency of reporting for periodic startup, shutdown, and malfunction reports, any time an action taken by a Permittee during a startup or shutdown that caused the source to exceed any applicable emission limitation in the relevant emission standards, or malfunction is not consistent with the procedures specified in the affected source's SSMP, the Permittee shall report the actions taken for that event within 2 working days after commencing actions inconsistent with the plan followed by a letter within 7 working days after the end of the event. The immediate report required under this paragraph (d)(5)(ii) shall consist of a telephone call (or facsimile (FAX) transmission) to the Administrator within 2 working days after commencing actions inconsistent with the plan, and it shall be followed by a letter, delivered or postmarked within 7 working days.


Additional reporting requirements for sources with continuous monitoring systems 1) When more than one CEMS is used to measure the emissions from one affected source, the Permittee shall report the results as required for each CEMS.

104.0 CD 40 CFR Section 63.10(e)(3)(i)-(iv); Minn. R. 7019.0100

Excess emissions and continuous monitoring system performance report and summary report. Excess emissions and parameter monitoring exceedances are defined in relevant standards. The Permittee shall submit an excess emissions and continuous monitoring system performance report and/or a summary report to the Administrator semiannually, except when more frequent reporting is specifically required by a relevant standard or a reduction in frequency is approved pursuant to 40 CFR Section 63.10(e)(3).

105.0 CD 40 CFR Section 63.10(e)(3)(v); Minn. R. 7019.0100

Content and submittal dates for excess emissions and monitoring system performance reports. All excess emissions and monitoring system performance reports and all summary reports, if required, shall be delivered or postmarked by the 30th day following the end of each calendar half or quarter, as appropriate. Written reports of excess emissions or exceedances of process or control system parameters shall include all the information required in 40 CFR Section 63.10(c)(5)-(c)(13), in 40 CFR Section 63.8(c)(7) and 40 CFR Sectuib 63.8(c)(8), and in the relevant standard, and they shall contain the name, title, and signature of the responsible official who is certifying the accuracy of the report. When no excess emissions or exceedances of a parameter have occurred, or a CMS has not been inoperative, out of control, repaired, or adjusted, such information shall be stated in the report.

106.0 CD 40 CFR Section 63.10(e)(3)(vi); Minn. R. 7019.0100

Summary report. One summary report shall be submitted for the hazardous air pollutants monitored at each affected source (unless the relevant standard specifies that more than one summary report is required. The summary report shall be entitled "Summary Report: Gaseous and Opacity Excess Emission and Continuous Monitoring System Performance" and shall contain the information specified in 40 CFR Section 63.10(e)(3)(vi).

MINNESOTA POLLUTION CONTROL AGENCY AIR QUALITY 520 LAFAYETTE ROAD ST PAUL, MN 55155-4194

Facility Name:

Permit Number:


03700020 - 004

Page 33 of 35 14 Jul, 2015 16:28


107.0 CD 40 CFR Section 63.10(e)(3)(vii); Minn. R. 7019.0100

If the total duration of excess emissions or process or control system parameter exceedances for the reporting period is 1 percent or greater of the total operating time for the reporting period, or the total CMS downtime for the reporting period is 5 percent or greater of the total operating time for the reporting period, both the summary report and the excess emissions and continuous monitoring system performance report shall be submitted.


Waiver of recordkeeping or reporting requirements. No requirements required.

MINNESOTA POLLUTION CONTROL AGENCY AIR QUALITY 520 LAFAYETTE ROAD ST. P AUL. MN 55155-4194

Page 34 of 35 14 Jul, 2015 16:28



Subject Item: CE 030 Fabric Filter - Low Temperature, i.e., T<180 Degrees F

Associated Items: EU 005 Feed Loadout - Loading-Unloading Equipment

N CI CA


1.0 CD Minn. R. 7019.3020(G) The operation of this piece of control equipment is not necessary in order for the process to meet applicable emissions limits. However, the Permittee wishes to take credit for its operation for the purposes of reporting actual emissions for emission inventory. Therefore, in order for PM, PM10, and PM2.5 to be considered controlled for the purposes of emissions inventory, the fabric filter must comply with the requirements of this permit during the time credit for control is taken. The PM, PM10, and PM2.5 generated during that time shall be considered controlled, and the control efficiency used is the limit given in this table.

2.0 LIMIT Minn. R. 7019.3020(G) Total Particulate Matter: greater than or equal to 79 percent control efficiency (capture efficiency x collection efficiency)

3.0 LIMIT Minn. R. 7011.1005, subp. 3(E) Total Particulate Matter: greater than or equal to 80 percent collection efficiency

4.0 LIMIT Minn. R. 7019.3020(G) PM < 10 micron: greater than or equal to 74 percent control efficiency (capture efficiency x collection efficiency)

5.0 LIMIT Minn. R.7019.3020(G) PM < 2.5 micron: greater than or equal to 74 percent control efficiency (capture efficiency x collection efficiency)

6.0 CD Minn. R. 7019.3020(G) The Permittee shall operate and maintain the fabric filter in accordance with the Operation and Maintenance (O & M) Plan. The Permittee shall keep copies of the O & M Plan available onsite for use by staff and MPCA staff.

7.0 LIMIT Minn. R. 7019.3020(G) Pressure Drop: greater than or equal to 0.5 inches of water column and less than or equal to 8 inches of water column unless a new range is set pursuant to Minn. R. 7017.2025, subp. 3 based on the values recorded during the most recent MPCA-approved performance test where compliance was demonstrated. The new range shall be implemented upon receipt of the Notice of Compliance letter granting preliminary approval. The range is final upon issuance of a permit amendment incorporating the change.

8.0 CD Minn. R. 7019.3020(G) Visible Emissions: The Permittee shall check the fabric filter stack (SV 016) for any visible emissions once each day of operation during daylight hours. During inclement weather, the Permittee shall read and record the pressure drop across the fabric filter, once each day of operation.

9.0 CD Minn. R. 7019.3020(G) Recordkeeping of Visible Emissions and Pressure Drop. The Permittee shall record the time and date of each visible emission inspection and pressure drop reading, and whether or not any visible emissions were observed, and whether or not the observed pressure drop was within the range specified in this permit

10.0 CD Minn. R. 7019.3020(G) Periodic Inspections: At least once per calendar quarter, or more frequently as required by the manufacturing specifications, the Permittee shall inspect the control equipment components. The Permittee shall maintain a written record of these inspections.

11.0 CD Minn. R. 7019.3020(G) Corrective Actions: The Permittee shall take corrective action as soon as possible if any of the following occur: - visible emissions are observed; or - the recorded pressure drop is outside the required operating range; or - the fabric filter or any of its components are found during the inspections to need repair. Corrective actions shall eliminate visible emissions, and/or return the pressure drop to within the permitted range, and/or include completion of necessary repairs identified during the inspection, as applicable. Corrective actions include, but are not limited to, those outlined in the O & M Plan for the equipment. The Permittee shall keep a record of the type and date of any corrective action taken.

12.0 CD Minn. R. 7007.0800, subp. 4 Monitoring Equipment: The Permittee shall install and maintain the necessary monitoring equipment for measuring and recording pressure drop as required by this permit. The monitoring equipment must be installed, in use, and properly maintained when the monitored cyclones are in operation.

MINNESOTA POLLUTION CONTROL AGENCY page 35 of 35 14 ju!i 2015 16:28 AIR QUALITY 520 LAFAYETTE ROAD

s, 'AUL'"N!i,,s-"" COMPLIANCE PLAN CD-01 Facility Name: Ardent Mills Flour Mill


Subject Item: FS 001 Fugitive HAP Sources (Fumigation, Preservation, etc.)

NC/ CA


1.0 LIMIT Title I Condition: Avoid major source under 40 CFR 63.2 and Minn. R. 7011.7000; Avoid major source under 40 CFR 70.2 and Minn. R. 7007.0200

HAP-Single: less than or equal to 9.0 tons/year using 12-month Rolling Sum to be calculated by the 15th day of each month for the previous 12-month period as described later in this permit. All fugitive HAP sources shall be included in this calculation. HAP con tents for each material shall be determined as described under the Material Content requirement. Includes each individual HAP used in non-combustion sources, including those used for water purification and product preservation.

2.0 LIMIT Title I Condition: Avoid major source under 40 CFR 63.2 and Minn. R. 7011.7000; Avoid major source under 40 CFR 70.2 and Minn. R. 7007.0200

HAPs - Total: less than or equal to 20.0 tons/year using 12-month Rolling Sum to be calculated by the 15th day of each month for the previous 12-month period as described later in this permit. All fugitive HAP sources shall be included in this calculation. HAP contents for each material shall be determined as described under the Material Content requirement. Includes all HAP used in non-combustion sources, including those used for water purification and product preservation.

3.0 CD Title I Condition: Avoid major source under 40 CFR 63.2 and Minn. R. 7011.7000; Avoid major source under 40 CFR 70.2 and Minn. R. 7007.0200

Daily Recordkeeping. On each day of operation, the Permittee shall calculate, record, and maintain records of the total quantity of all HAP-containing materials used at the facility. This shall be based on written usage logs.

4.0 CD Minn. R. 7007.0800, subps. 4-5 Monthly Recordkeeping - HAP Usage. By the 15th day of each month, the Permittee shall calculate and record the following: 1) The quantity of each HAP-containing material used in the previous calendar month using the daily usage records. This record shall include the individual HAP content of each material as determined by the Material Content requirement of this permit. 2) The quantity of each individual HAP used in the previous month using the formulas specified in this permit. 3) The 12 month rolling sum of each individual HAP used for the previous 12 month period by summing the quantities calculated for that HAP for the previous 12 months. 4) The Total HAP usage for the previous month, by summing the quantities of each individual HAP used during the previous month. 5) the 12-month rolling sum of Total HAP for the previous 12 months, by summing the Total HAP usage calculated for each of the previous 12 months.

5.0 CD Minn. R. 7007.0800, subps. 4-5 Monthly Calculation - Individual HAP Usage. The Permittee shall calculate the monthly quantity of each individual HAP using the following equations:

HAP A (tons/month) = (A1 x B1) + (A2 x B2) + (A3 x B3) +

Where: HAP A = total quantity of HAP A used in tons/month; A# = amount of each HAP A-containing material used, in tons/month; B# = weight percent of HAP A in A#, as a fraction

6.0 CD Minn. R. 7007.0800, subps. 4 and 5

Material Content. HAP contents in materials shall be determined by the Material Safety Data Sheet (MSDS) provided by the supplier for each material used. If a material content range is given on the MSDS, the highest number in the range shall be used in all compliance calculations. Other alternative methods approved by the MPCA may be used to determine the HAP content. The MPCA reserves the right to require the Permittee to determine the HAP content of any material, according to EPA or ASTM reference methods. If an EPA or ASTM reference method is used for material content determination, the data obtained shall supersede the MSDS.

Attachment 2 - Calculations

MINNESOTA POLLUTION CONTROL AGENCY 2 June, 2015 16:41 AIR QUALITY '

fT^A™N 5E5i5°5A4°94 FACILITY DESCRIPTION: Potential-to-emit (by pollutant)

Show: Active and Pending Records AQD Facility ID: 03700020 Facility Name: Ardent Mills Flour Mill

Pollutant Item Added By

(Action)

Retired By

(Action)

Hourly Potential

(lbs per hr)

Unrestricted Potential

(tons per yr)

Limited Potential

(tons per yr)

Actual Emissions

(tons per yr)

Acetaldehyde

EU 009 PER 004 3.980E-03 1.740E-02 1.740E-02

Totals 0.000E+00 O.OOOE+OO O.OOOE+OO

Acrolein

EU 009 PER 004 3.990E-03 1.750E-02 1.750E-02

Totals 1.750E-02 1.750E-02 O.OOOE+OO

Benzene

EU 001 PER 004 2.680E-05 1.170E-04 1.170E-04

EU 009 PER 004 9.940E-04 4.350E-03 4.350E-03

Totals 4.467E-03 4.467E-03 0.000E+00

Arsenic compounds

EU 001 PER 004 5.620E-05 2.460E-04 2.46QE-04

Totals 2.460E-04 2.460E-04 0.000E+00

Biphenyl

EU 009 PER 004 2.020E-06 8.860E-06 8.860E-06


Bromomethane

FS 001 PER 001 9.750E+00

FS 001 PER 004 9.000E+00

Totals 0.000E+00 9.000E+00 O.OOOE+OO

1,3-Butadiene

EU 009 PER 004 4.200E-04 1 840E-03 1.840E-03


Beryllium

EU 001 PER 004 3.350E-05 1.470E-04 1.470E-04


Carbon tetrachloride

EU 009 PER 004 3.110E-05 1.360E-04 1.360E-04


Carbon Dioxide Equivalent

EU 001 PER 004 9.576E+03

EU 009 PER 004 2.098E+02

Totals 0.000E+00 9785 O.OOOE+OO

Chlorobenzene

| EU 009 PER 004 2.280E-05 9.970E-05 9.970E-05


Page 1 of 6

MINNESOTA POLLUTION CONTROL AGENCY 2 June, 2015 16:41 AIR QUALITY ' ^20 I AFAY FTTF ROAD ST PAUL MN 55i55-4194 FACILITY DESCRIPTION: Potential-to-emit (by pollutant)



(Action)

Retired By

(Action)

Hourly Potential

(lbs per hr)


(tons per yr)

Limited Potential

(tons per yr)

Actual Emissions

(tons per yr)

Chloroform

EU 009 PER 004 2.410E-05 1.060E-04 1.060E-04

Totals 1.060E-04 1.060E-04 0.000E+00

Cadmium compounds

EU 001 PER 004 1.430E-04 6.280E-04 6.280E-04


Methane

EU 001 PER 004 8.800E-02 3.870E-01 3.870E-01

EU 009 PER 004 9.020E-04 3.950E-03 3.950E-03


Carbon Monoxide

EU 001 PER 001 1.070E+00 4.690E+00 4.690E+00

EU 009 PER 004 5.940E-01 2.600E+00 2.600E+00


Carbon Dioxide

EU 001 PER 004 2.179E+03 9.543E+03 9.543E+03

EU 009 PER 004 4.786E+01 2.096E+02 2.096E+02

Totals 9.752E+03 9.753E+03 0.000E+00

Cobalt compounds

EU 001 PER 004 1.070E-06 4.690E-06 4.690E-06

Totals 0.000E+00 0.000E+00 0.000E+00

Chromium compounds

EU 001 PER 004 8.970E-04 3.930E-03 3.930E-03


1,4-Dichlorobenzene

EU 001 PER 004 1.530E-05 6.700E-05 6.700E-05


1,3-Dichloropropene

EU 009 PER 004 2.240E-05 9.830E-05 9.830E-05

Totals O.OOOE+OO 0.000E+00 O.OOOE+OO

Ethylbenzene

EU 009 PER 004 5.530E-05 2.420E-04 2.420E-04


Formaldehyde

EU 001 PER 004 5.830E-03 2.S60E-02 2.560E-02

EU 009 PER 004 2.830E-02 1.240E-01 1.240E-01


Page 2 of 6


ST°FACILITY DESCRIPTION: Potential-to-emit (by pollutant)



(Action)

Retired By

(Action)

Hourly Potential

(lbs per hr)


(tons per yr)

Limited Potential

(tons per yr)

Actual Emissions

(tons per yr)

Hexane

EU 001 PER 004 2.300E-02 1.010E-01 1.010E-01

EU 009 PER 004 2.280E-04 9.980E-04 9.980E-04


Methanol

EU 009 PER 004 1.270E-03 5.560E-03 5.560E-03


Naphthalene

EU 001 PER 004 7.780E-06 3.410E-05 3.410E-05


HAPs - Total

EU 001 PER 004 2.410E-02 1.050E-01 1.050E-01

EU 009 PER 004 4.070E-02 1.780E-01 1.780E-01

FS 001 PER 001 9.750E+00

FS 001 PER 004 2.000E+01

Totals 2.830E-01 2.028E+01 O.OOOE+OO

Mercury

EU 001 PER 004 4.020E-05 1.760E-04 1.760E-04


Phenol

EU 009 PER 004 2.160E-05 9.450E-05 9.450E-05


Styrene

EU 009 PER 004 2.810E-05 1.230E-04 1.230E-04


1,1,2,2-Tetrachloroethane

EU 009 PER 004 3.400E-05 1.490E-04 1.490E-04


Toluene

EU 001 PER 004 4.340E-05 1.900E-04 1.900E-04

EU 009 PER 004 4.930E-04 2.160E-03 2.160E-03


1,1,2-Trichloroethane

EU 009 PER 004 2.700E-05 1 180E-04 1.180E-04

Totals O.OOOE+OO O.OOOE+OO O.OOOE+OO

Page 3 of 6


:"i^wj|AYMNT551554194 FACILITY DESCRIPTION: Potential-to-emit (by pollutant)



(Action)

Retired By

(Action)

Hourly Potential

(lbs per hr)


(tons per yr)

Limited Potential

(tons per yr)

Actual Emissions

(tons per yr)

Vinyl chloride

EU 009 PER 004 1.270E-05 5.540E-05 5.540E-05


Xylenes (mixed isomers)

EU 009 PER 004 1.370E-04 6.010E-04 6.010E-04


2,2,4-trimethyipentane

EU 009 PER 004 4.330E-04 1.900E-03 1.900E-03

Totals 1.900E-03 1 900E-03 O.OOOE+OO

Manganese compounds

EU 001 PER 004 1.870E-04 8.210E-04 8.210E-04


Ethylene dibromide (dibromoeth

EU 009 PER 004 3.760E-05 1.650E-04 1.650E-04


Nitrous Oxide

EU 001 PER 004 1.700E-02 7.700E-02 7.700E-02

EU 009 PER 004 9.020E-05 3.950E-04 3.950E-04


Methylene chloride (dichlorome

EU 009 PER 004 7.530E-05 3.300E-04 3.300E-04


Total Polycyciic aromatic hydr

EU 009 PER 004 6.670E-05 2.920E-04 2 920E-04

Totals 2.920E-04 2.920E-04 0.000E+00

Nickel compounds

.EU 001 PER 004 2.410E-04 1.060E-03 1.060E-03


Nitrogen Oxides

EU 001 PER 001 1.910E+00 8.380E+00 8.380E+00

EU 009 PER 004 1.380E+00 6.060E+00 6.060E+00

Totals 1.444E+01 1.444E+01 0.000E+00

PM < 2.5 micron

EU 001 PER 004 1.500E-01 6.500E-01 6.500E-01

| ' EU 002 PER 004 7.700E-01 1.3186+01 6.700E-01

| EU 003 PER 004 2.140E-03 9.380E-03 4.000E-02

| | EU 004 PER 004 | 2.300E+01 1.824E+03 8.603E+01 |

Page 4 of 6

MINNESOTA POLLUTION CONTROL AGENCY 2 June 2015 16:41 AIR QUALITY ' '

ST. PAUL, MN 55155-4 194 FACILITY DESCRIPTION: Potential-to-emit (by pollutant)



(Action)

Retired By

(Action)

Hourly Potential

(lbs per hr)


(tons per yr)

Limited Potential

(tons per yr)

Actual Emissions

(tons per yr)

PM < 2.5 micron

EU 005 PER 004 1.500E-03 1.490E-02

EU 006 PER 004 1.200E-01 7.590E+00 2.100E-01

EU 007 PER 004 1.000E-02 3.000E-02

EU 008 PER 004 5.500E-01 6.700E+00 1.900E+00

EU 009 PER 004 5.120E-06 2.240E-05 2.240E-05

GP 004 PER 004 2.200E-01

Totals 1.852E+03 8.972E+01 0.000E+00

Lead

EU 001 PER 001 4.000E-04 1.800E-03 1.800E-03

EU 001 PER 004 1.190E-04 5.220E-04 5.220E-04


PM < 10 micron

EU 001 PER 001 2.200E-01 9.600E-01 9.300E-01

EU 001 PER 004 2.200E-01 9.600E-01 9.600E-01

EU 002 PER 001 1.800E-01 7.753E+01 1.500E-01

EU 002 PER 004 4.530E+00 7.753E+01 3.370E+00

EU 003 PER 001 1.800E-03 7.900E-01 3.000E-02

EU 003 PER 004 3.600E-03 7.900E-01 6.000E-02

EU 004 PER 001 2.450E+01 1.073E+04 9.153E+01

EU 004 PER 004 2.300E+01 1.073E+04 8.603E+01

EU 005 PER 001 4.200E-03 9.000E-02 9.000E-02

EU 005 PER 004 8.800E-03 9.000E-02 O.OOOE+OO

EU 006 PER 001 1.000E-01 4.468E+01 1.800E-01

EU 006 PER 004 1.800E-01 4.468E+01 3.200E-01

EU 007 PER 003 2.470E-02 4.750E+00 1.290E-01

EU 007 PER 004 2.000E-02 2.790E+00 O.OOOE+OO

EU 008 PER 001 4.500E+00 3.942E+01 1.940E+00

EU 008 PER 004 7.200E-01 3.942E+01 2.490E+00

EU 009 PER 004 5.120E-06 2.240E-05 2.240E-05

GP 004 PER 004 2.200E-01


Polycyclic organic matter

EU 001 PER 004 3.160E-04 1.380E-03 1.380E-03


Total Particulate Matter

EU 001 PER 001 3.200E-01 1.380E+00 1.380E+00

Page 5 of 6


fT°PAAutYMNT55i5°5A4°94 FACILITY DESCRIPTION: Potential-to-emit (by pollutant)



(Action)

Retired By

(Action)

Hourly Potential

(lbs per hr)


(tons per yr)

Limited Potential

(tons per yr)

Actual Emissions

(tons per yr)

Total Particulate Matter

EU 002 PER 001 5.400E-01 2.365E+02 4.700E-01

EU 002 PER 004 1.123E+01 2.365E+02 9.790E+00

EU 003 PER 001 3.600E-03 1.580E+00 6.000E-02

EU 004 PER 001 4.900E+01 2.146E+04 1,831 E+02

EU 005 PER 001 1.700E-02 3.600E-01 3.600E-01

EU 005 PER 004 3.300E-02 3.600E-01 O.OOOE+OO

EU 006 PER 001 1.800E-01 8.015E+01 3.200E-01

EU 007 PER 001 1.000E-02 4.720E+00 1.000E-01

EU 007 PER 004 2.000E-02 8.290E+00 0.000E+00

EU 008 PER 001 9.000E+00 7.884E+01 3.880E+00

EU 008 PER 004 7.200E-01 7.884E+01 2.490E+00

EU 009 PER 004 5.120E-06 2.240E-05 2.240E-05

GP 004 PER 004 3.500E-01


Selenium compounds

EU 001 PER 004 3.060E-06 1.340E-05 1.340E-05


HAP-Single

FS 001 PER 001 9.750E+00

FS 001 PER 004 9.000E+00

Totals 0.000E+00 9.000E+00 0.000E+00

Sulfur Dioxide

EU 001 PER 001 6.890E+00 3.Q16E+01 3.016E+01

EU 009 PER 004 1.580E-03 6.910E-03 6.910E-03


Volatile Organic Compounds

EU 001 PER 001 7.000E-02 3.100E-01 3.100E-01

EU 009 PER 004 4.100E-01 1.800E+00 1.800E+00

FS 001 PER 001 9.750E+00

| FS 001 PER 004 2.000E+01


Page 6 of 6

EU001 (Boiler)

Fuels: Natural Gas No. 2 Fuel Oil

13.39 MMBtu/hr (total) 1050 MMBtu/mmcf

0.50 % sulfur 140000 Btu/gal 0.14 MMBtu/gallon

Fuel Consumption:

Emission Factors PM

Gas 7.6 Oil 0.0033

Natural Gas Fuel Oil

PM10

7.6 0.0023

0.0127524 mmcf/hour ((MMBtu/hr)/(MMBtu/mmcf)) 95.642857 gallons/hour ((M MBtu/hr)/(MMBtu/gallon))

S02

0.6 0.072

NOx

100 0.02

CO 84

0.005

VOC 5.5

0.0002

0.095643 kgal/hr

Lead 0.0005

0.0000042

PM2.5 7.6 Ib/mmcf

0.00155 lb/gallon

Potential Emissions

Nat Gas Fuel Oil

PM 0.10 0.32

PM10

0.10 0.22

so2 0.01 6.89

NOx

1.28 1.91

CO 1.07 0.48

VOC 0.07 0.02

Lead 0.00001 0.00040

PM2.5 0.09692 0.14825

lb/hour lb/hour

Worst: 0.32 1.38

0.22 0.96

6.89 30.16

1.91 8.38

1.07 4.69

0.07 0.31

0.00040 0.0018

0.15 0.65

lb/hour tpy

Emission factor source: AP-42 , sections 1.3 (Fuel Oil Combustion) and 1.4 (Natural Gas Combustion)

Generator - EU009

output capacity = voltage (asssumed) = power output = Btu/hour equivalent = Btu/hour input =

250 amps 480 Volts

120000 watts (volts x amps) 409821.5 Btu/hour

512276.875 Btu/hour (assuming 80% engine efficiency) 0.5122769 MMBtu/hr

Emission Factors Hourly emissions Emissions @ 8760

PM 0.00001 5.12E-06 2.24E-05

PM10

0.00001 5.12E-06 2.24E-05

PM2.5

0.00001 5.12E-06 2.24E-05

S02

0.00308175 1.58E-03 6.91 E-03

NOx

2.7 1.38E+00 6.06E+00

CO 1.16

5.94E-01 2.60E+00

VOC 0.8

4.10E-01 Ib/mmbtu lb/hour

1.80E+00 tpy

Emission Factor source:The engine is identified as a CI engine that burns natural gas, so emission factors for Dual-fuel engines were used (CI engines burning primarily natural gas with a small amount of diesel fuel); other o ption was to use emission factors for gas-fired SI engines. Since the engine is so small, the emissions do not make a regulatory difference in the facility PTE, so the emission factors chosen are probably irrelevant. S content of diesel assumed to be 0.05% S content of natural gas assumed to be 2000 gr /mmcf (AP-42 Section 1.4) 0.285714 Ib/mmcf density of natural gas = 0.044 - 0.056 lb/ft3 (http://www.engineeringtoolbox.com/gas-densi1

44000 Ib/mmcf S content = 0.000649%

PM emission factor in AP-42 listed as "ND" so 0.00001 was used to represent the neglible emissions.,

ty-d_158.html)

Combustion HAP

Boiler - EU001 0.0127524 mmcf/hr nat gas 0.0956429 kgal/hr distillate oil

Gas Dist Oil Gas Dist oil Worst Worst (Ib/mmcf) (Ib/kgal) Ib/hr Ib/hr Ib/hr tpy

1,4-dichlorobenzene 0.0012 1.53E-05 0 1.53E-05 6.70E-05 Benzene 0.0021 2.68E-05 0 2.68E-05 1.17E-04 Formaldehyde 0.075 0.061 9.56E-04 5.83E-03 5.83E-03 2.56E-02 Hexane 1.8 2.30E-02 0 2.30E-02 1.01E-01 Naphthalene 0.00061 7.78E-06 0 7.78E-06 3.41 E-05 Toluene 0.0034 4.34E-05 0 4.34E-05 1.90E-04 POM 0.0000882 0.0033 1.12E-06 3.16E-04 3.16E-04 1.38E-03 Arsensic 0.0002 0.000588 2.55E-06 5.62E-05 5.62E-05 2.46E-04 Beryllium 0.000012 0.00035 1.53E-07 3.35E-05 3.35E-05 1.47E-04 Cadmium 0.0011 0.0015 1.40E-05 1.43E-04 1.43E-04 6.28E-04 Cobalt 0.000084 1.07E-06 0 1.07E-06 4.69E-06 Chromium 0.0014 0.00938 1.79E-05 8.97E-04 8.97E-04 3.93E-03 Manganese 0.00038 0.00196 4.85E-06 1.87E-04 1.87 E-04 8.21 E-04 Mercury 0.00026 0.00042 3.32E-06 4.02E-05 4.02E-05 1.76E-04 Nickel 0.0021 0.00252 2.68E-05 2.41 E-04 2.41 E-04 1.06E-03 Selenium 0.00024 3.06E-06 0 3.06E-06 1.34E-05 Lead 0.0005 0.001246 6.38E-06 1.19E-04 1.19E-04 5.22E-04 Total 2.41 E-02 7.87E-03 2.41 E-02 1.05E-01

Emission factor source: AP-42, sections 1.3 (Fuel Oil. Combustion) and 1.4 (Natural Gas Combustion)

Generator - EU009 Emission factor source: AP-42, section 3.2 (Natural Gas-fired Reciprocating Engines (only NG-fired engine HAP fact

Used factor for 2-stroke lean burn engines, as those were worst-case.

0.51 Ib/mmBtu NG factor 2-stroke lean Ib/MMBtu Ib/hr tpy

benzene 0,00194 9.94E-04 4.35E-03 ethylbenzene 0.000108 5.53E-05 2.42E-04 chlorobenzene 4.444E-05 2.28E-05 9.97E-05 chloroform 0.0000471 2.41 E-05 1.06 E-04 styrene 0.0000548 2.81 E-05 1.23E-04 ethylene dibromide 0.0000734 3.76 E-05 1.65E-04 phenol 0.0000421 2.16E-05 9.45E-05 biphenyl 3.95E-06 2.02E-06 8.86E-06 carbon tetrachloride 0.0000607 3.11 E-05 1.36 E-04 hexane 0.000445 2.28E-04 9.98E-04 methylene chloride 0.000147 7.53E-05 3.30E-04 methanol 0.00248 1.27E-03 5.56E-03 Toluene 0.000963 4.93E-04 2.16E-03 xylene 0.000268 1.37E-04 6.01 E-04 1,3-butadiene 0.00082 4.20E-04 1.84E-03 formaldehyde 0.0552 2.83E-02 1.24E-01 acetaldehyde 0.00776 3.98E-03 1.74E-02

Page 1

EU001 - natural gas Natural Gas Emission

Emission Emissions Usage Rate PTE C02e PTE Pollutant Factor Factor Units Emissions Factor Source (MMBtu/hr) (lbs/hr) (tons/year) Multiplier (tons/year)

co2 116.732 lbs/MMBtu 40 CFR Part 98 Subpart C Table C-l 13.4 1563.041 6846.122 1 6,846.122

CH4 2.20E-03 lbs/MMBtu 40 CFR Part 98 Subpart C Table C-2 13.4 0.029 0.129 25 3.226

N2O 2.20E-04 lbs/MMBtu 40 CFR Part 98 Subpart C Table C-2 13.4 0.003 0.013 298 3.845 Total 6,853.192

EU001 - distillate oil - worst case for all pollutants Natural Gas Emission


co2 162.712 lbs/MMBtu 40 CFR Part 98 Subpart C Table C-l 13.4 2178.714 9542.766 1 9,542.766 CH4 6.60E-03 lbs/MMBtu 40 CFR Part 98 Subpart C Table C-2 13.4 0.088 0.387 25 9.677 N2O 1.32E-03 lbs/MMBtu 40 CFR Part 98 Subpart C Table C-2 13.4 0.018 0.077 298 23.070

Total 9,575.513

EU009 - natural gas Natural Gas Emission


CO, 116.732 lbs/MMBtu 40 CFR Part 98 Subpart C Table C-l 0.4 47.860 209.627 1 209.627

CH4 2.20E-03 lbs/MMBtu 40 CFR Part 98 Subpart C Table C-2 0.4 9.02E-04 3.95E-03 25 0.099

N2O 2.20E-04 lbs/MMBtu 40 CFR Part 98 Subpart C Table C-2 0.4 9.02E-05 3.95E-04 298 0.118 Total 209.844

Grain

EU002/SV001 - Grain Receiving

Capacity = 300 ton/hour Limit = 523000 ton/year Control = 80% capture efficiency

99% PM collection efficiency 93% PM10 and PM2.5 collection efficiency

PM PM10 PM2.5 Emission Factor 0.18 0.06 lb/ton 0.01 lb/ton Maximum Hourly 54.00 17.70 Ib/hr 3.01 Ib/hr Controlled Hourly 11.23 4.53 Ib/hr 0.77 Ib/hr Maximum Annual 236.52 77.53 tpy 13.18 tpy Controlled Annual 9.79 3.95 tpy 0.67 tpy

EU003/SV003 - SV010, SV013 -- Grain Cleaning



PM PM10 PM2.5 Emission Factor 0.02 0.01 lb/ton 0.00 lb/ton Maximum Hourly 0.36 0.18 Ib/hr 0.03 Ib/hr Controlled Hourly 3.60E-03 1.26E-02 Ib/hr 2.14E-03 Ib/hr Maximum Annual 1.58 0.79 tpy 9.38E-03 tpy Controlled Annual 0.06 0.22 tpy 0.04 tpy

3.60E-03 Ib/hr - assumed to not exceed PM 0.06 tpy - assumed to not exceed PM

EU006/SV002 - Grain Handling

Capacity = 300 ton/hour Limit = 1046000 ton/year (grain is handled twice) Control = 100% capture efficiency

99% PM co llection efficiency 93% PM10 and PM2.5 collection efficiency


0.18 Ib/hr - assumed to not exceed PM 0.32 tpy - assumed to not exceed PM

Page 1

Grain

EU004/SV011, SV012, SV015 - Milling


99% PM collection efficiency 99.06% PM10 collection efficiency 94.05% PM2.5 collection efficiency


23.03 Ib/hr 86.03 tpy

(assumed not to exceed PM10)

EU008/SV014 - Pellet Cooling

Capacity = 25 ton/hour Limit = 172590 ton/year 33% of feed is pelletized Control = 100% capture efficiency

80% PM collection efficiency- 1st in series of 2 collectors 60% for PM10 and PM2.5

80% collection efficiency - 2nd in series of 2 collectors 60% for PM10 and PM2.5

96% overall control efficiency (2nd collector controls 20% of the 20% emitted from the 1 st) 64% for PM10 and PM2.5



EU005/SV016 - Feed Loadout

Capacity = 25 ton/hour Limit = 523000 ton/year 100% of milled grain is made into feed Control = 60% capture efficiency (not required to certify hood, so assuming uncertified values from Minn. R. 7(

99% PM collection efficiency 93% PM and PM2.5 collection efficiency

PM PM10 PM2.5 Emission Factor 0.0033 0.0008 lb/ton 1.36E-04 lb/ton Maximum Hourly 0.08 0.02 Ib/hr 0.00 Ib/hr Controlled Hourly 0.033 0.0088 Ib/hr 1.50E-03 Ib/hr Maximum Annual 0.36 0.09 tpy 1.49E-02 tpy Limited Annual 0.35 0.09 tpy 1.57E-02 tpy

Page 2

Grain

Page 3

Grain

EU007/SV017 - SV022 - Flour Loadout

Capacity = 22 t on/hour Limit = 523000 ton/year 100% of milled grain is shipped as flour Control = 100% capture efficiency


PM PM10 PM2.5 Emission Factor 0.086 0.029 lb/ton 0.005 lb/ton (worst case factors for grain loadir Maximum Hourly 1.89 0.64 Ib/hr 0.11 Ib/hr Controlled Hourly 0.02 0.04 Ib/hr 0.01 Ib/hr Maximum Annual 8.29 2.79 tpy 0.03 tpy Controlled Annual 0.22 0.53 tpy 0.09 tpy


GP004 - Loadout - worst case for PM is that all is shipped out as feed worst case for PM10 and PM2.5 is that all is shipped out as flour

PM 0.35

PM10 0.22

PM2.5 0.09

Total Emissions PM PM10 S02 NOX CO VOC PM2.5

EU001 - boiler 1.38 0.96 30.16 8.38 4.69 0.31 0.65 EU009 - generator 0.00 0.00 0.01 6.06 2.60 1.80 0.00 EU002 - receiving 9.79 3.95 0.67 EU003 - cleaning 0.06 0.06 0.04 EU004 - milling 183.05 86.03 86.03 EU005 - feed loading EU006 - handling 0.32 0.32 0.21 EU007 - flour loading EU008 - pellet cool 2.49 2.49 1.90 GP004 - loadout 0.35 0.22 0.09 TOTAL 197.09 93.81 30.17 14.44 7.29 2.10 89.50

Total Throughput 523000 Percentage Flour 100% Percentage Feed 0% % of feed pelletized 33%

Page 4

Grain

Page 5

Grain

)11.0070)

Page 6

Worksheet in ole main

INDUSTRIAL PROCESS EQUIPMENT SPREADSHEET

This spreadsheet calculates allowable particulate emission rates based on Minnesota Rules parts 7011.0730 (Table 1) and 7011.0735 (Table 2).

Flow rate in standard cubic feet per minute (scfm) is calculated using the ideal gas law and the assumptions of 68 deg. F for standard temperature and 14.78 psia for standard pressure.

Table 1 Emission Point: SV014 - Pellet Cooling

Process Weight Rate (lbs/hour)

50000

Emission Rate (lbs/hour)

26.413

Emission Rate (grams/sec)

3.328

Emission Rate (tons/year)

115.689 Table 2

EMISSION POINT: SV014 - Pellet Cooling

Source Gas Volume (acfm) 12500.000

Percent Moisture 0.000

Outlet Temperature (deg. F) 125.000

Outlet Gauge Pressure (psig) 0.000

Source Gas Volume (dscf/min)

11281.364

Emission Rate (gr/dscf)

0.086

Emission Rate (lbs/hour)

8.284

Emission Rate (grams/sec)

1.044

Emission Rate (tons/year)

36.282

Emission Limit (based on Minn. R. 7011.0715, subp. 1(A)): 26.413 lbs/hour

0.273 gr/dscf

Page 1

SOURCEJD SOURCEJMAME PERMIT_TYPE 03700020 Ardent Mills Flour Mill R 03700020 ConAgra Flour Mill - Hastings R

NAICS_CODE INVENTORY_YEAR EM!SSION_UNIT_CODE 311211 2014 TON 311211 2013 TON

AMMONIA CO LEAD NOX PM10FIL 0.03754 0.985 0.000005865 1.173 76.046268 0.03538 0.929 0.000005528 1.106 86.67714

VI25FIL PMCON PMFIl S02 VOC 28.5244121 0.15455 152.176966 0.00704 0.06452 32.5050116 0.04441 173.330571 0.00663 0.0608

2014 PM10 PM2.5

76.200822 28.6789661

Air Emission Permit No. 03700020-004 Is Issued to Ardent ... · Ardent Mills Four Mill operates a...

Documents

Transcript of Air Emission Permit No. 03700020-004 Is Issued to Ardent ... · Ardent Mills Four Mill operates a...