AIR EMISSION PERMIT NO. 15100026- 002 IS ISSUED TO CVEC ... · AIR EMISSION PERMIT NO. 15100026-...

AIR EMISSION PERMIT NO. 15100026- 002

IS ISSUED TO

CVEC - Benson Ethanol Plant 270 West County Road 20

Benson, Swift County, Minnesota 56215 The emission units, control equipment and emission stacks at the stationary source authorized in this permit are as described in the following permit applications: Permit Type Date Total Facility Operating Permit July 28, 1995 Major Amendment May 30, 1997 Minor Amendment March 9, 1998 Major Amendment August 21, 1998 This permit authorizes the Permittee to operate and modify the stationary source at the address listed above unless otherwise noted in Table A. The Permittee must comply with all the conditions of the permit. Any changes or modifications to the stationary source must be performed in compliance with Minn. R. 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. Permit Type: State ; Syn Min PSD/NSR Operating Permit Major Amendment

Issue Date: July 7, 1998 October 27, 1998

Expiration: Permit does not expire. All Title I Conditions do not expire.

Permit does not expire. All Title I Conditions do not expire.

Toni Volkmeier for Michael J. Sandusky Division Manager Air Quality Division for Peder A. Larson Commissioner Minnesota Pollution Control Agency TLV:yma

Permit No. 15100026-002

TABLE OF CONTENTS

Notice to the Permittee

Permit Shield

Facility Description

Table A: Limits and Other Requirements

Table B: Submittals

Appendix

Permit No. 15100026-002

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. Certain requirements which have been determined not to apply are listed in Table A of this permit. FACILITY DESCRIPTION: The facility is a fuel ethanol production plant located approximately one half mile northwest of Benson. An adjacent grain elevator, United Farmers Elevator, is considered part of the same stationary source. This permit allows the installation of an additional boiler. It also modifies (lowers) an existing limit on the amount of fuel that can be burned by the two generators on an annual basis. Following this modification, emissions of all regulated pollutants are limited by federally enforceable conditions such that the two facilities together (Chippewa Valley Ethanol Company and United Farmers Elevator) are considered a single non-major stationary source under both 40 CFR § 52.21 (Prevention of Significant Deterioration) and 40 CFR § 70.2 (Part 70 permitting program). United Farmers Elevator has been issued a separate state permit, Air Emission Permit No. 15100029-001.

TABLE A: LIMITS AND OTHER REQUIREMENTS 10/27/98

CVEC - Benson Ethanol Plant

15100026 - 002

Facility Name:

Permit Number:

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

Subject Item: Total Facility

What to do Why to do itProduction: less than or equal to 20000000 gallons/year using 12-month RollingSum of fuel ethanol (pure ethanol, prior to addition of any denaturant).

Title I Condition: To avoid major source classificationunder 40 CFR Section 52.21; to avoid major sourceclassification 40 CFR Section 70.2 and Minn. R.7007.0200

Recordkeeping: By the 15th day of every month, record the amount of ethanolproduced during the previous month, and calculate and record the amount ofethanol produced during the previous 12-month period (12-month rolling sum,calculated as described in the Appendix).

Title I Condition: To avoid major source classificationunder 40 CFR Section 52.21; to avoid major sourceclassification 40 CFR Section 70.2 and Minn. R.7007.0200

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

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

Operation and Maintenance Plan: Retain at the stationary source an operation andmaintenance plan for all air pollution control equipment.

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

Shutdowns: Notify the Commissioner at least 24 hours in advance of a plannedshutdown or as soon as possible after an unplanned shutdown, of any process orcontrol equipment if the shutdown would cause an increase in the emission of anyregulated air pollutant. At the time of notification, notify the Commissioner of thecause of the shutdown and the estimated duration. Notify the Commissioner againwhen the shutdown is over.

Minn. R. 7019.1000, subp. 3

Breakdowns: Notify the Commissioner no later than 24 hours after a breakdown ofmore than one hour duration of any process or control equipment if the breakdowncauses an increase in the emission of any regulated air pollutant. At the time ofnotification or as soon thereafter as possible, the permittee shall also notify theCommissioner of the cause of the breakdown and the estimated duration. Notifythe Commissioner again when the breakdown is over.

Minn. R. 7019.1000, subp. 2

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

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

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

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

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

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

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

Minn. R. 7011.0020

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

Minn. R. 7019.1000, subp. 1

Written Notification of Deviations Endangering Human Health or the Environment:within two (2) days after discovery, notify the Commissioner in writing of anydeviations from permit conditions which could endanger human health or theenvironment. Include the following information in this written notification: cause ofthe deviation; exact dates of the period of the deviation; if the deviation has notbeen corrected, the anticipated time it is expected to continue; and steps taken orplanned to reduce, eliminate, and prevent reoccurence of the deviation.

Minn. R. 7019.1000, subp. 1

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

Minn. R. 7007.1150 through Minn. R. 7007.1500

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

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

Minn. R. 7011.0150

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15100026 - 002

Facility Name:

Permit Number:

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

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

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

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

Record keeping: Retain all records at the stationary source for a period of five (5)years from the date of monitoring, sample, measurement, or report. Records whichmust be retained at this location include all calibration and maintenance records, alloriginal strip-chart recordings for continuous monitoring instrumentation, and copiesof all reports required by the permit. Records must conform to the requirementslisted in Minn. R. 7007.0800, subp. 5(A).

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

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

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

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15100026 - 002

Facility Name:

Permit Number:

Subject Item: GP 001 NOx Emissions from Fuel Combustion

Associated Items: EU 014 Dryer

EU 016 Boiler #1

EU 031 Boiler #2

What to do Why to do itA. EMISSION LIMITS hdr

Nitrogen Oxides: less than or equal to 83.7 tons/year using 12-month Rolling Sum Title I Condition: To avoid major source classificationunder 40 CFR Section 52.21; to avoid major sourceclassification under 40 CFR Section 70.2 and Minn. R.7007.0200

B. OPERATING REQUIREMENTS hdr

Fuel Burned: Natural gas and propane only. Minn. Stat. Section 116.07, subd. 4a;Minn. R. 7007.0800, subp. 2

C. RECORDKEEPING REQUIREMENTS hdr

Recordkeeping - Fuel Usage: Each day, record the following:a. the gallons of propane combusted during the previous day;b. the cubic feet of natural gas combusted during the previous day.

Title I Condition: To avoid major source classificationunder 40 CFR Section 52.21; to avoid major sourceclassification under 40 CFR Section 70.2 and Minn. R.7007.0200

Recordkeeping - Fuel Usage: By the 15th day of each month, calculate and recordthe following:a. the gallons of propane combusted during the previous month;b. the gallons of propane combusted during the previous 12 months;c. the cubic feet of natural gas combusted during the previous month;d. the cubic feet of natural gas combusted during the previous 12 months.

Title I Condition: To avoid major source classficationunder 40 CFR Secion 52.21; to avoid major sourceclassification under 40 CFR Section 70.2 and Minn. R.7007.0200

Recordkeeping: By the 15th day of each month, calculate and record the GP 001NOx emissions for the previous month and the previous 12 months (12-monthrolling sum).

To calculate the monthly NOx emissions, use Equation 1 in the Appendix.


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15100026 - 002

Facility Name:

Permit Number:

Subject Item: GP 002 Generators

Associated Items: EU 020 Generator #1

EU 021 Generator #2

SV 006 Generator #1

SV 007 Generator #1

SV 008 Generator #2

SV 009 Generator #2


Opacity: less than or equal to 20 percent opacity at each stack, once operatingtemperatures have been attained.

Minn. R. 7011.2300, subp. 1

Sulfur Dioxide: less than or equal to 0.5 lbs/million Btu heat input for eachgenerator

Minn. R. 7011.2300, subp. 2

B. OPERATING REQUIREMENTS hdr

Fuel Usage: less than or equal to 40000 gallons/year using 12-month Rolling Sumof diesel fuel oil combusted in the two generators.


Fuel Burned: Diesel fuel oil only. Minn. Stat. Section 116.07, subd. 4a;Minn. R. 7007.0800, subp. 2

C. RECORDKEEPING REQUIREMENTS hdr

Recordkeeping: Each day, record the gallons of diesel fuel oil combusted in the twogenerators during the previous day.


Recordkeeping: By the 15th day of each month, calculate and record the following:a. the gallons of diesel fuel oil combusted during the previous month;b. the gallons of diesel fuel oil combusted during the previous 12 months.


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15100026 - 002

Facility Name:

Permit Number:

Subject Item: GP 003 Tanks Subject to NSPS Subpart Kb

Associated Items: TK 001 Ethanol

TK 002 Gasoline

TK 003 Ethanol 95%; Gasoline 5%

TK 004 Ethanol

What to do Why to do itRecordkeeping: Maintain records showing the dimensions of each tank, andanalyses showing each tank's capacity.

40 CFR Section 60.116b(b); Minn. R. 7011.1520 (C)

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15100026 - 002

Facility Name:

Permit Number:

Subject Item: GP 005 Boiler Recordkeeping

Associated Items: EU 016 Boiler #1

EU 031 Boiler #2

What to do Why to do itRecordkeeping: Record and maintain records of the amounts of each fuelcombusted on a monthly basis. These records may consist of purchase records orreceipts.

40 CFR Section 60.13(i) and February 20, 1992, EPAmemorandum to meet the requirements of 40 CFRSection 60.48c(g) and (i); Minn. R. 7011.0570

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15100026 - 002

Facility Name:

Permit Number:

Subject Item: SV 002 Grain cleaning/milling

Associated Items: EU 002 Grain Cleaning

EU 003 Hammermill


Total Particulate Matter: less than or equal to 1.1 lbs/hour Title I Condition: To avoid major source classificationunder 40 CFR Section 52.21

Total Particulate Matter: less than or equal to 0.1 grains/dry standard cubic footunless a different limit is allowed pursuant to Minn. R. 7011.0735 Table 2.

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

Particulate Matter < 10 micron: less than or equal to 0.7 lbs/hour Title I Condition: To avoid major source classificationunder 40 CFR Section 52.21; to avoid major sourceclassification under 40 CFR Section 70.2 and Minn. R.7007.0200

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

B. POLLUTION CONTROL REQUIREMENTS hdr

Total Particulate Matter: greater than or equal to 95 percent control efficiency (CE001)

Title I Condition: To avoid major source classificationunder 40 CFR Section 52.21

Particulate Matter < 10 micron: greater than or equal to 93 percent controlefficiency (CE 001)


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15100026 - 002

Facility Name:

Permit Number:

Subject Item: SV 003 Fermentation scrubber

Associated Items: EU 004 Liquification Tank

EU 005 Saccharification Tank

EU 006 Whole Stillage Surge Tank

EU 007 Thin Stillage Surge Tank

EU 008 Process Condensate Storage Tank

EU 009 Fermentation Tank


EU 011 Slurry Mix Tank



EU 017 Degasser Vent Condenser

EU 018 Evaporator Separator

EU 019 Yeast Tank


EU 028 Yeast Propagation Tank


Volatile Organic Compounds: less than or equal to 5.6 lbs/hour at outlet of controldevice.


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


Volatile Organic Compounds: greater than or equal to 98 percent control efficiency(CE 003)


C. TESTING REQUIREMENTS hdr

Performance Test: due 180 days after Initial Startup of new fermenter (EU027) tomeasure volatile organic compound emissions.

Title I Condition: To avoid major source classificationunder 40 CFR Section 52.21; to avoid major sourceclassification under 40 CFR Section 70.2 and Minn. R.7007.0200; Minn. R. 7017.2020, subp. 1

Performance Test Pre-test Meeting: due 7 days before Performance Test (seeTable B for additional test requirements).

Minn. R. 7017.2030, subp. 4

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15100026 - 002

Facility Name:

Permit Number:

Subject Item: SV 004 DDGS dryer




Total Particulate Matter: less than or equal to 0.085 grains/dry standard cubic foot ,unless a different limit is allowed pursuant to Minn. R. 7011.0735 Table 2.

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


Volatile Organic Compounds: less than or equal to 5.68 lbs/hour Title I Condition: To avoid major source classificationunder 40 CFR Section 52.21; to avoid major sourceclassification under 40 CFR Section 70.2 and Minn. R.7007.0200




Title I Condition: To avoid major source classificationunder 40 CFR Section 52.21; Minn. R. 7007.0800,subp. 2 to meet requirements of Minn. R. 7011.1005,subp. 3(D)

Particulate Matter < 10 micron: greater than or equal to 80 percent controlefficiency (CE 004)


C. TESTING REQUIREMENTS hdr

Performance Test: due 180 days after Initial Startup of new fermenter (EU027) tomeasure emissions of particulate matter.

Title I Condition: Emissions testing to avoid majorsource classification under 40 CFR Section 52.21;Minn. R. 7017.2020, subp. 1

Performance Test: due 180 days after Initial Startup of new fermenter (EU027) tomeasure emissions of particulate matter < 10 microns.

Title I Condition: Emissions testing to avoid majorsource classification under 40 CFR Section 52.21; toavoid major source classification under 40 CFRSection 70.2 and Minn. R. 7007.0200;Minn. R.7017.2020, subp. 1

Performance Test: due 180 days after Initial Startup of new fermenter (EU027) tomeasure emissions of volatile organic compounds.

Title I Condition: Emissions testing to avoid majorsource classification under 40 CFR Section 52.21;emissions testing to avoid major source classificationunder 40 CFR Section 70.2 and Minn. R. 7007.0200;Minn. R. 7017.2020, subp. 1

Performance Test: due 180 days after Initial Startup of new fermenter (EU027) tomeaure opacity.

Minn. R. 7017.2020, subp. 1

Performance Test Pre-test Meeting: due 7 days before Performance Test (seeTable B for additional testing requirements).

Minn. R. 7017.2030, subp. 4

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15100026 - 002

Facility Name:

Permit Number:

Subject Item: SV 011 Cooling cyclone

Associated Items: EU 026 Cooling/separating cyclone



Total Particulate Matter: less than or equal to 0.088 grains/dry standard cubic foot ,unless a different limit is allowed based on the actual air flow rate, pursuant toMinn. R. 7011.0735 Table 2.

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



B. TESTING REQUIREMENTS hdr

Performance Test: due 180 days after Initial Startup of new fermenter (EU027) tomeasure particulate matter emissions.

Title I Condition: To avoid major source classificationunder 40 CFR Section 52.21; Minn. R. 7017.2020,subp. 1

Performance Test: due 180 days after Initial Startup of new fermenter (EU027) tomeasure emissions of particulate matter <10 microns.


Performance Test: due 180 days after Initial Startup of new fermenter (EU027) tomeasure opacity

Minn. R. 7017.2020, subp. 1

Performance Test Pre-test Meeting: due 7 days before Performance Test (seeTable B for additional testing requirements).

Minn. R. 7017.2030, subp. 4

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15100026 - 002

Facility Name:

Permit Number:

Subject Item: SV 012 DDGS loadout

Associated Items: EU 022 DDGS Loadout Pit

EU 023 DDGS Elevator (to loadout)

EU 024 DDGS Loadout



Total Particulate Matter: less than or equal to 0.1 grains/dry standard cubic foot ,unless a different limit is allowed pursuant to Minn. R. 7011.0735 Table 2.

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




Title I Condition: To avoid major source classificationunder 40 CFR Section 52.21

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15100026 - 002

Facility Name:

Permit Number:

Subject Item: EU 026 Cooling/separating cyclone

Associated Items: SV 011 Cooling cyclone

What to do Why to do itPressure Drop: greater than or equal to 3 inches of water column and less than orequal to 8 inches of water column

Title I Condition: Equipment operating parameter toavoid major source classification under 40 CFRSection 52.21; to avoid major source classificationunder 40 CFR Section 70.2 and Minn. R. 7007.0200

Record pressure drop once each day of operation. Title I Condition: Monitoring of operating parameter toavoid major source classification under 40 CFRSection 52.21; to avoid major source classificationunder 40 CFR Section 70.2 and Minn. R. 7007.0200

Corrective Action: If the pressure drop is not within the range of values specifiedherein, the Permittee shall take corrective action as soon as possible to return thepressure drop to within the required operating values. The Permittee shall keep arecord of the type and date of all corrective actions taken.

Title I Condition: Corrective Action to avoid majorsource classification under 40 CFR Section 52.21; toavoid major source classification under 40 CFRSection 70.2 and Minn. R. 7007.0200

Inspect quarterly, or as required by manufacturing specifications, all componentsthat are not subject to wear or plugging, including structural components, housing,ducts, and hoods. Maintain a written record of the inspection and any actionresulting from the inspection.

Minn. R. 7007.0800, subp. 2 and subp. 14

Inspect quarterly, or as required by manufacturing specifications, all componentsthat are subject to wear or plugging. Maintain a written record of the inspection andany action resulting from the inspection.


Calibrate the pressure gauge annually, or as often as required by manufacturingspecifications, and maintain a written record of the calibration and any actionresulting from the calibration.


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15100026 - 002

Facility Name:

Permit Number:

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

Associated Items: EU 002 Grain Cleaning

EU 003 Hammermill

What to do Why to do itOperation and Maintenance of Fabric Filter: The Permittee shall operate andmaintain the fabric filter according to the control equipment manufacturer'sspecifications.


Visible Emissions: The Permittee shall check the outlet of the baghouse (SV 002)for any visible emissions, once each day of operation during daylight hours.Record the time and date of each inspection, and whether or not any visibleemissions were observed.

Title I Condition: To avoid major source classificationunder 40 CFR Section 52.21; to avoid major sourceclassification under 40 CFR Section 70.2 and Minn. R.7007.0200; Minn. R. 7007.0800. subp. 14

Corrective Actions: If visible emissions are observed, the Permittee shall follow theOperation and Maintenance Plan for the fabric filter and take corrective actions assoon as possible to eliminate the visible emissions. The Permittee shall keep arecord of the type and date of all corrective actions taken.

Title I Condition: Corrective Action to avoid majorsource classification under 40 CFR Section 52.21; toavoid major source classification under 40 CFRSection 70.2 and Minn. R. 7007.0200; Minn. R.7007.0800. subp. 14





A-13



15100026 - 002

Facility Name:

Permit Number:

Subject Item: CE 002 Centrifugal Collector - High Efficiency

Associated Items: EU 022 DDGS Loadout Pit

EU 023 DDGS Elevator (to loadout)

EU 024 DDGS Loadout

What to do Why to do itPressure Drop: greater than or equal to 0.5 inches of water column and less than orequal to 2.0 inches of water column











A-14



15100026 - 002

Facility Name:

Permit Number:

Subject Item: CE 003 Packed-Gas Adsorption Column

Associated Items: EU 004 Liquification Tank

EU 005 Saccharification Tank

EU 006 Whole Stillage Surge Tank

EU 007 Thin Stillage Surge Tank

EU 008 Process Condensate Storage Tank



EU 011 Slurry Mix Tank



EU 017 Degasser Vent Condenser

EU 018 Evaporator Separator

EU 019 Yeast Tank


EU 028 Yeast Propagation Tank

What to do Why to do itPressure Drop: greater than or equal to 0.5 inches of water column and less than orequal to 9 inches of water column


Water flow rate: greater than or equal to 12.5 gallons/minute Title I Condition: Equipment operating parameter toavoid major source classification under 40 CFRSection 52.21; to avoid major source classificationunder 40 CFR Section 70.2 and Minn. R. 7007.0200

Read and record the pressure drop once each day of operation. Title I Condition: Monitoring of equipment operatingparameters to avoid major source classification under40 CFR Section 52.21; to avoid major sourceclassification under 40 CFR Section 70.2 and Minn. R.7007.0200

Record the water flow rate once each day of operation. Title I Condition: Monitoring of equipment operatingparameters to avoid major source classification under40 CFR Section 52.21; to avoid major sourceclassification under 40 CFR Section 70.2 and Minn. R.7007.0200

Corrective Action: If the pressure drop and/or water flow rate are not equal to orgreater than the minimum values specified in the Operation and Maintenance Plan,the Permittee shall take corrective action as soon as possible to achieve therequired operating values. The Permittee shall keep a record of the type and dateof all corrective actions taken.

Title I Condition: Corrective Action to avoid majorsource classification under 40 CFR Section 52.21; toavoid major source classification under 40 CFRSection 70.2 and Minn. R. 7007.0200; Minn. R.7007.0800, subp. 14







Calibrate the water flowmeter annually, or as often as as required by manufacturingspecifications, and maintain a written record of the calibration and any actionresulting from the calibration.


A-15



15100026 - 002

Facility Name:

Permit Number:

Subject Item: CE 004 Multiple Cyclone w/o Fly Ash Reinjection - Most Multiclones


What to do Why to do itPressure Drop: greater than or equal to 4 inches of water column and less than orequal to 8 inches of water column











A-16



15100026 - 002

Facility Name:

Permit Number:

Subject Item: TK 003 Ethanol 95%; Gasoline 5%

Associated Items: GP 003 Tanks Subject to NSPS Subpart Kb

What to do Why to do itRecordkeeping: maintain records of the volatile organic liquid (VOL) stored, theperiod of storage, and the maximum true vapor pressure of the VOL during therespective storage period, calculated as described in 40 CFR Section 60.116b (e).

40 CFR Section 60.116b (c); Minn. R. 7011.1520 (C)

Notification: notify the Administrator within thirty (30) days when the maximum truevapor pressure exceeds 5.2 kPa.

40 CFR Section 60.116b (d); Minn. R. 7011.1520 (C)

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15100026 - 002

Facility Name:

Permit Number:

Subject Item: FS 001 Truck Traffic

What to do Why to do itFugitive Emissions: Do not cause or permit the transporting of any material in amanner which may allow avoidable amounts of particulate matter to becomeairborne. Do not cause or permit a road or a driveway to be constructed, used,repaired, or demolished without applying all such reasonable measures as may berequired to prevent particulate matter from becoming airborne.

Minn. R. 7011.0150

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15100026 - 002

Facility Name:

Permit Number:

Subject Item: FS 003 Uncaptured DDGS emissions

What to do Why to do itClean up commodities spilled on the driveway and other facility property asrequired to minimize fugitive emissions to a level consistent with RACT(Reasonably Available Control Technology).

MInn. R. 7011.1005, subp. 1(A)

Opacity: less than or equal to 5 percent opacity for fugitive emissions from railcarloading of DDGS or DDGS handling activities

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

Opacity: less than or equal to 10 percent opacity for fugitive emissions from DDGStruck loading

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

A-19

TABLE B: SUBMITTALSFacility Name: CVEC - Benson Ethanol Plant

Permit Number: 15100026 - 002

10/27/98

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

Each submittal must be postmarked or received by the date specified in the applicable Table. Those submittals required by parts7007.0100 to 7007.1850 must be certified by a responsible official, defined in Minn. R. 7007.0100, subp. 21. Other submittals shallbe certified as appropriate if certification is required by an applicable rule or permit condition.

Send any application for a permit or permit amendment to:

Permit Technical AdvisorPermit SectionAir Quality DivisionMinnesota Pollution Control Agency520 Lafayette Road NorthSt. Paul, Minnesota 55155-4194

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

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

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

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

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

B-1

TABLE B: ONE TIME SUBMITTALS OR NOTIFICATIONSFacility Name: CVEC - Benson Ethanol Plant


10/27/98

What to send When to send Portion of Facility AffectedNotification of the Actual Date of Initial Startup due 15 days after Initial Startup EU031

Notification of the Actual Date of Initial Startup due 15 days after Initial Startup EU027

Notification of the Anticipated Date of InitialStartup

due 30 days before Anticipated Date of InitialStartup

EU031

Notification of the Date Construction Began due 30 days after Start Of Construction EU031

Performance Test Notification (written) due 30 days before Performance Test SV003, SV004, SV011

Performance Test Plan due 30 days before Performance Test SV003, SV004, SV011

Performance Test Report - Microfiche Copy due 105 days after Performance Test SV003, SV004, SV011

Performance Test Report due 45 days after Performance Test SV003, SV004, SV011

Testing Frequency Plan due 60 days after Performance Test forparticulate matter, particulate matter <10micron, and opacity. The plan shall specify atesting frequency based on the test data andMPCA guidance. Future performance testsbased on year (12-month), 36-month, and60-month intervals, or as applicable, shall berequired on written approval of MPCA.

SV011

Testing Frequency Plan due 60 days after Performance Test forvolatile organic compounds, particulatematter, and particulate matter <10 micron.The plan shall specify a testing frequencybased on the test data and MPCA guidance.Future performance tests based on year(12-month), 36-month, and 60-monthintervals, or as applicable, shall be requiredon written approval of MPCA.

SV004

Testing Frequency Plan due 60 days after Performance Test forvolatile organic compunds. The plan shallspecify a testing frequency based on the testdata and MPCA guidance. Futureperformance tests based on year (12-month),36-month, and 60-month intervals, or asapplicable, shall be required on writtenapproval of MPCA.

SV003

B-2

TABLE B: RECURRENT SUBMITTALSFacility Name: CVEC - Benson Ethanol Plant


10/27/98

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

half-year following Permit Issuance The firstsemiannual report submitted by the Permitteeshall cover the calendar half-year in which thepermit is issued. The first report of eachcalendar year covers January 1 - June 30.The second report of each calendar yearcovers July 1 - December 31.

Total Facility

Compliance Certification due 30 days after end of each calendar yearfollowing Permit Issuance (for the previouscalendar year). To be submitted on a formapproved by the Commissioner. The reportcovers all deviations experienced during thecalendar year.

Total Facility

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

Total Facility

B-3

APPENDIX MATERIAL Facility Name: CVEC - Benson Ethanol Plant Permit Number: 15100026-002 Section I. Calculation of 12-Month Rolling Sum A 12-month rolling sum is used track the quantity of ethanol produced per 12 month period, the quantities of natural gas and propane combusted in the dryer and boiler, and the quantity of diesel fuel oil combusted in the generators. A 12 month rolling sum is calculated monthly, using data from the preceeding 12 months. Each month, a new 12 month “window” of data is used.

• In October 1998, the 12 month rolling sum would be calculated using the data from October 1997 through September 1998.

• In November 1998, the 12 month rolling sum would again be calculated, this time using the data from November 1997 through October 1998.

• In December 1998, the 12 month rolling sum would be calculated using the data from December 1997 through November 1998.

• And so on.

Section II. Calculation of NOX emissions for GP001 (Boiler and Dryer Fuel Usage) Limit NOX emissions from combustion of natural gas and propane in the boiler and dryer are not to exceed 83.7 tons per 12-month rolling period. The NOX emissions for the preceeding 12 months are to be calculated monthly using using the following equation:

N = (EFP × P) + (EFNG × NG) + (EFNG-LOW × NGLOW) Equation 1 Where:

N = NOX emissions, must be less than or equal to 83.7 tons

EFP = the most current emission factor for NOX emissions from combustion of propane in a boiler, in units of tons of NOX per million gallons of propane. [At time of permit issuance, EFP = 9.5 tons of NOX per million gallons of propane. See Note 1 below.]

P = quantity of propane combusted during the previous 12 months, in millions of gallons. See Note 2 below.

EFNG = the most current emission factor for NOX emissions from combustion of natural gas in a boiler without NOX control technology, in units of tons of NOX per million cubic feet of

Permit No. 15100026-002 Appendix, Page 2 of 2

natural gas. [At time of permit issuance, EFNG = 0.05 tons of NOX per million cubic feet of natural gas. See Note 3 below.]

NG = total quantity of natural gas combusted in Boiler #1 (EU016) and in the dryer (EU014) during the previous 12 months, in millions of cubic feet. See Note 4 below.

EFNG-LOW = the most cuurent emission factor for NOX emissions from combustion of natural gas in a boiler using a low-NOX burner and flue gas recirculation (FGR) technology, in units of tons of NOX per million cubic feet of natural gas. [At time of permit issuance, EFNG-LOW = 0.016 tons of NOX per million cubic feet of natural gas. See Note 5 below.]

NGLOW = quantity of natural gas combusted in Boiler #2 (EU031) during the previous 12 months, in millions of cubic feet. See Note 4 below.

NOTES: 1. At the time of permit issuance, the current NOX emission factor for combustion of propane

in a boiler is 19 pounds per thousand gallons, for industrial boilers 10 to 100 million Btu/hour (AP-42 Fifth Edition, January 1995, Table 1.5-2). The number used in Equation 1 is obtained as follows:

19 pounds

1000 gallons1000000 gallonsmillion gallons

1 ton2000 pounds

9.5 tonsmillion gallons

× × =

2. For example, if 2,000,000 gallons of propane are combusted, P = 2. 3. At the time of permit issuance, the current NOX emission factor for combustion of natural

gas in a boiler without NOX control technology is 100 pounds per million cubic feet, for boilers less than 100 million Btu/hour (AP-42 Fifth Edition, February 1998, Table 1.4-1). The number used in Equation 1 is obtained as follows:

100 pounds

million cubic feet1 ton

2000 pounds0.05 tons

million cubic feet× =

4. For example, if 95,000,000 cubic feet of natural gas are combusted, NG = 95. 5. At the time of permit issuance, the current NOX emission factor for combustion of natural

gas in a boiler with NOX and FGR control technology is 32 pounds per million cubic feet, for boilers less than 100 million Btu/hour (AP-42 Fifth Edition, February 1998, Table 1.4-1). The number used in Equation 1 is obtained as follows:

32 pounds

million cubic feet1 ton

2000 pounds0.016 tons

million cubic feet× =

Permit Action Number: 15100026-002 Date Printed: 1/6/2004

TECHNICAL SUPPORT DOCUMENT For

AIR EMISSION PERMIT NO. 15100026-002 This technical support document is intended for all parties interested in the permit. The purpose of this document is to set forth the legal and factual basis for the permit conditions, including references to the applicable statutory or regulatory provisions. 1. General Information 1.1. Applicant and Stationary Source Location:

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

Facility Address (SIC Code: 2869)

Chippewa Valley Agrafuels Cooperative P.O. Box 130 Benson, Minnesota 56216

Chippewa Valley Ethanol Company, Inc. (CVEC) - Benson Ethanol Plant 270 West County Road 20

John Huffman, Plant Manager Bill Lee, General Manager (320)843-4813 (320)843-4800 (fax)

Benson, Swift County, Minnesota

United Farmers Elevator P.O. Box 47 Murdock, Minnesota 56271

United Farmers Elevator 260 20th Street NW Benson, Swift County, Minnesota

Frank McDowell, General Manager (320)875-2811 (320)875-2813 (fax)

1.2. Description of the facility

The facility is a fuel ethanol production plant located approximately 1/2 mile northwest of Benson. An adjacent grain elevator, United Farmers Elevator (UFE), is considered a support facility and a part of this stationary source. The two facilities together constitute a non-major source under both 40 CFR § 52.21 (PSD) and 40 CFR § 70.2 (Part 70). UFE operates under a separate state permit, Air Emission Permit No. 15100029-001.

Corn is received at UFE through an uncontrolled dumping pit. It is transferred to the elevator for storage. Some of the corn is dried. As needed, the corn is sent to CVEC through a closed, pnuematic conveying system.

The CVEC operation begins when corn is conveyed to a scalper, where “non-corn” (cobs, dirt, other debris) is removed. From the scalper, corn flows to the hammermill,


where it is ground. Scalping and milling generate particulate emissions (PM and PM10), which are controlled by a baghouse (CE001, SV002).

Milled corn then enters the fermentation and distillation process, where enzymes are introduced, and the mixture is cooked, fermented, distilled, cooled, separated, etc.. There is a variety of equipment included in these processes. Volatile organic compound emissions are produced, which are controlled by a scrubber (CE003, SV003). Fugitive VOC emissions resulting from leaks in fittings, pumps, valves, etc. are exhausted out the ventilation system of the fermentation/distillation building (SV001).

Heat is provided to the fermentation and distillation operations via steam from two natural gas/propane boilers (SV005 and SV013).

Solid corn materials left over from the fermentation/distillation are dried to form distillers dried grains with solubles (DDGS) which is sold and used as livestock feed. The dryer combusts natural gas and/or propane for heat. The drying process generates PM and PM10 emissions, which are controlled by a multiclone, and VOC emissions, which are emitted uncontrolled (CE004, SV004).

DDGS is transported to a storage building by a conveyor. It enters a cooling or “separating” cyclone, which separates air from DDGS (SV011).

The DDGS then drops into the storage building, onto a pile, from ceiling height.

When DDGS is sold and shipped out, a tractor is used to dump the DDGS into the loadout pit. It is then conveyed to the loadout spout by an elevator leg. There is one loadout spout, used for both truck and rail loadout. PM and PM10 are generated by these activities. A cyclone collects and controls emissions from the loadout pit, elevator let, and loadout spout (CE002, SV012). Fugitive PM and PM10 emissions from dropping the DDGS into the building from the conveyor are exhausted through the building ventilation (SV010).

Two emergency generators provide power as needed (SV006, SV007, SV008, SV009).

There are two alcohol purification systems (EU 029 and EU 030) at the facility, which distill the ethanol further, for industrial (non-fuel) uses.

There are seven storage tanks located at the facility. One tank stores 200 proof ethanol, prior to addition of the denaturant (gasoline). One tank stores off-spec ethanol which comes out of the process. One thank stores denaturant, prior to being added to the 200 proof ethanol. Two tanks store denatured ethanol prior to sale/shipment. Two tanks store the purified ethanol.


1.3 Description of any changes allowed with this permit issuance

1. This permit allows the installation of a second natural gas/propane fired boiler (EU031, SV013). A NOX emission limit covering the two boilers and the dryer keeps the NOX emission below 100 tpy.

2. To allow the total emissions from the facility to remain below 100 tpy for each pollutant, the limit on the amount of diesel fuel that can be combusted in the generators (EU020 and EU021) is being decreased to 40,000 gallons per year.

3. This permit also reinstates the pressure drops for the cyclones and scrubber and the water flow rate for the scrubber as enforceable parts of this permit. (They are no longer required to be listed in the O&M plan.)

1.4. Source Emissions:

Table 1. Emission Changes

Pollutant

Change in Potential to Emit (lb/hr)

Change in Potential to Emit (TPY)

Emission Increases

Authorized with this Permit Action

Emission Decreases Authorized

with this Permit Action

Other contemporaneous emission increases/ decreases

(TPY)

Net Emission

Change

(TPY)

NSR/ 112(g) Threshold Level (TPY)

NSR/ MACT Review Required (Yes or No)

PM 0.43 1.09 1.9 0.81 n/a 1.09 100 NO PM10 0.43 1.16 1.9 0.74 n/a 1.16 100 NO SO2 0.03 -0.6 0.15 0.75 n/a -0.6 100 NO NOX 12.45 6.35 17.5 11.15 n/a 6.35 100 NO VOC 0.33 0.82 1.43 0.61 n/a 0.82 100 NO CO 4.8 18.57 21.02 2.45 n/a 18.57 100 NO

Changes in PTE are the result of the following factors:

• Addition of 2nd boiler (tpy reduced because of operational limits) • Decrease in allowed fuel combustion in the generators • Use of revised emission factors

Table 2. Total Source Potential to Emit Summary:

Note: See facility description for details

PM tpy

PM10 tpy

SO2 tpy

NOX tpy

CO tpy

VOC tpy

Meth. tpy

Benz. tpy

Total HAPs

tpy Total Facility Limited Potential Emissions - CVEC

62.32 88.33 1.25 95.86 65.69 89.73 4.6 0.167 4.766

Total Facility Limited Potential Emissions - UFE

29.92 8.77 0.0 0.31 0.26 0.02 0.0 0.0 0.0

Total Facility Limited Potential Emissions - Stationary Source

92.24 97.10 1.25 96.17 65.95 89.75 4.6 0.167 4.766


Table 3. Source and Permit Classification

Classification Major/Affected

Source Synthetic Minor Minor

PSD N/A PM, PM10, VOC, NOX CO, SO2 NAAR N/A N/A N/A Part 70 Permit Program N/A PM10, VOC, NOX CO, SO2, HAPs 2. Regulatory and/or Statutory Basis Regulatory Overview of Facility

EU, GP, SV, etc.

Applicable Regulations Comments:

GP001 Title I Condition, set in previous permit; 40 CFR § 52.21(r)(4) applies to changes.

Designed to maintain NOX emissions below 100 tpy. Fuel usage is recorded, and used to calculate NOX emissions according to the methods described in the Appendix to the permit.

GP002 Title I Condition, set in previous permit; 40 CFR § 52.21(r)(4) applies to relaxation of the limit.

Designed to maintain NOX emissions below 100 tpy.

SV004 Minn. R. 7011.1005, subp. 3(D)

Standards of Performance for Dry Bulk Agricultural Commodity Facilities. Opacity standard applies in place of the opacity standard for direct heating equipment, because DDGS is a DBAC, and the DBAC handling operation limits apply (carried over from from 15100026-001).

EU027 Minn. Stat. § 116.07, subd. 4a

Requirement to notify MPCA upon startup of new fermenter, so that testing requirements are triggered (carried over from from 15100026-001).

3. Additional Information

• Deviation from accepted Delta organization - Emission limits are set at the SV level, because in many cases, there are several emission units exhausting to a single control device, and ultimately out a single stack. All emissions are tested at the SV level.

• Operational limits for baghouse - rather than the traditional pressure drop range monitoring requirements, the permittee is required to monitor visible emissions from the baghouse each day that the associated emission units are in operation. Visible emissions are a better indication of a malfunction in a baghouse; a tear can occur and the pressure drop may not change significantly, but chances are good that visible emissions will result.


• The facility will be using a 12-month rolling sum to calculate NOX emissions, fuel usage in the emergency generators, and ethanol production. Because this is still a startup facility, the production rate is not constant or predictable. In addition, since ethanol production is dependent upon corn, the production rate depends on the quantity and quality of corn available at a given time, which is not predictable. This is consistent with the recordkeeping requirements of other ethanol plant permits issued in Minnesota.

• Any testing will be done in accordance with EPA test methods. 4. Conclusion Based on the information provided by Chippewa Valley Ethanol Company, the MPCA has reasonable assurance that the proposed operation of the emission facility, as described in the Air Emission Permit No. 15100026-002 and this technical support document, will not cause or contribute to a violation of applicable federal regulations and Minnesota Rules. Staff Members on Permit Team: Toni Volkmeier Marshall Cole Dave Vaaler Attachments: GI-07 (emission summary) and calculation details Facility Description Forms CD-01 Forms

AIR EMISSION PERMIT NO. 15100026- 002 IS ISSUED TO CVEC ... · AIR EMISSION PERMIT NO. 15100026-...

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