Intent to Issue Air Emission Permit to Malteurop North ... · Malteurop North America, Inc....

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

DRAFT/PROPOSED

AIR EMISSION PERMIT NO. 16900013‐005 Total Facility Operating Permit ‐ Reissuance

IS ISSUED TO

Malteurop North America, Inc.

MALTEUROP NORTH AMERICA, INC. ‐ WINONA

500 3rd Street West Winona, Winona County, Minnesota 55987

The emission units, control equipment and emission stacks at the stationary source authorized in this permit reissuance are as described in the Permit Applications Table. This permit reissuance supersedes Air Emission Permit No. 16900013‐004, 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: Federal; Part 70/Limits to Avoid NSR

Operating Permit Issue Date: <issue date>

Expiration Date: <expiration date or Non‐Expiring> – All Title I Conditions do not expire.

Don Smith, P.E., Manager Air Quality Permits Section Industrial Division for John Linc Stine Commissioner Minnesota Pollution Control Agency

Permit Applications Table

Permit Type Application Date Permit Action

Total Facility Operating Permit ‐ Reissuance 7/30/2012 005

TABLE OF CONTENTS Notice to the Permittee

Permit Shield

Facility Description Table A: Limits and Other Requirements

Table B: Submittals

Appendices Appendix A: Insignificant Activities and Applicable Requirements Appendix B: Fugitive Emissions Control Plan

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 AND PERMIT ACTION 005 DESCRIPTION: Malteurop North America Inc. is a barley malting plant in Winona, Winona County, Minnesota. The facility receives barley by truck and rail, where it is then weighed and sent to storage. Prior to the malting process, the barley is transferred from storage to a cleaner, width grader, separator, debearder, and an aspirator. Barley is then sent to one of the two malt houses. In the malt house the barley is soaked in water in a steeping tank and is then sent to a germination box to sprout. After the barley has sprouted it is dried in a malt kiln, where elemental sulfur is oxidized to produce sulfur dioxide (SO2) which acts as a fungicide, bactericide, and preservative. The SO2 released from this process is the primary potential source of emissions at the facility, along with particulate emissions from the grain handling processes. After drying is complete the malted barley is sent to storage by means of a bucket elevator. Lastly, malted barley is sent to a scale and shipped in bulk by rail and truck, although rail is the predominate method. Malted barley may also be shipped by barge by means of trucking it to a barge loading facility upstream of Malteurop. Malt byproduct (sprouts and screenings dust) is also shipped out by truck. Barley byproduct is loaded out in the barley receiving area and shipped out by rail or truck.

Both byproduct loadouts are equipped with extendible DCL loadout spouts to reduce byproduct freefall and fugitive dust emissions. Fabric filters are used to control particulate matter (PM), PM10, and PM2.5 emissions from barley and malt handling processes, while all other sources are uncontrolled. All fuel combustion sources are restricted to natural gas and propane. Small vacuum systems are used in the malt houses and elevators for building cleanup and are insignificant activities under Minn. R. 7007.1300, subp. 4(B). The four natural gas fired boilers used for heating on site are also insignificant activities under Minn. R. 7007.1300, subp. 4. The facility is a synthetic minor source under New Source Review (NSR) due to a 12‐month rolling sum sulfur material usage limit. In addition to this limit, there are also Title I Conditions to avoid being an affected NSR major source for total PM and PM10 emissions. Several processes are also subject to 40 CFR pt. 60, subp. DD – Standards of Performance for Grain Elevators. This permit action is the reissuance of the Title V operating permit and does not allow any specific modifications. However, the permit will require the Permittee to certify the hoods used to capture fugitive particulate emissions according to Minn. R. 7007.0072, updates required control equipment efficiencies, and updates the facility’s potential to emit (PTE), among other administrative changes described in the following sections. A complete description of all changes to this permit and supporting technical information may be seen in the Technical Support Document.

TABLE A: LIMITS AND OTHER REQUIREMENTSMalteurop North America Inc - Winona

16900013 - 005

Facility Name:

Permit Number:

06/26/14A-1

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

Subject Item: Total Facility

What to do Why to do it

SOURCE-SPECIFIC REQUIREMENTS hdr

Permit Appendices: This permit contains appendices as listed in the permit Table ofContents. The Permittee shall comply with all requirements contained in theappendices.

Minn. R. 7007.0800, subp. 2

Comply with Fugitive Emission Control Plan: The Permittee shall follow the actionsand recordkeeping specified in the fugitive emission control plan, located atAppendix B to the permit. The plan may be amended by the Permittee with theCommissioner's approval. If the Commissioner determines the Permittee is out ofcompliance with Minn. R. 7011.0150 or the fugitive emission control plan, then thePermittee may be required to amend the fugitive emission control plan and/or toinstall and operate particulate matter ambient monitors as requested by theCommissioner.

Minn. Stat. Section 116.07, subds. 4a & 9; Minn. R.7007.0100; Minn. R. 7007.0800, subp. 2; Minn. R.7011.0150; Minn. R. 7009.0020

OPERATIONAL REQUIREMENTS hdr

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

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

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

Minn. R. 7011.0020

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

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

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

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

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

Minn. R. 7019.1000, subp. 4

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

Minn. R. 7011.0150

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

Minn. R. 7030.0010 - 7030.0080

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

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

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

Minn. R. 7007.0800, subp. 16

PERFORMANCE TESTING REQUIREMENTS hdr

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

Minn. R. ch. 7017


16900013 - 005

Facility Name:

Permit Number:

06/26/14A-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 TestPerformance Test Plan: due 30 days before each Performance TestPerformance Test Pre-test Meeting: due 7 days before each Performance TestPerformance Test Report: due 45 days after each Performance TestPerformance Test Report - Microfiche Copy: due 105 days after each PerformanceTest

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

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

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

Minn. R. 7017.2025, subp. 3

MONITORING REQUIREMENTS hdr

Monitoring Equipment Calibration: The Permittee shall either:

1. Calibrate or replace required monitoring equipment every 12 months; OR2. Calibrate at the frequency stated in the manufacturer's specifications.

For each monitor, the Permittee shall maintain a record of all calibrations, includingthe date conducted and any corrective action that resulted. The Permittee shallinclude the calibration frequencies, procedures, and manufacturer's specifications(if applicable) in the Operations and Maintenance Plan. Any requirements applyingto 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 and B,monitoring a process or control equipment connected to that process is notnecessary during periods when the process is shutdown, or during checks of themonitoring systems, such as calibration checks and zero and span adjustments. 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)

RECORDKEEPING REQUIREMENTS hdr

Recordkeeping: Retain all records at the stationary source, unless otherwisespecified within this permit, for a period of five (5) years from the date ofmonitoring, sample, measurement, or report. Records which must be retained atthis location include all calibration and maintenance records, all original recordingsfor continuous monitoring instrumentation, and copies of all reports required by thepermit. 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 (asrequired by Minn. R. 7007.1250, subp. 3) or changes contravening permit terms (asrequired by Minn. R. 7007.1350, subp. 2), including records of the emissionsresulting from those changes.

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

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

Minn. R. 7007.1200, subp. 4

REPORTING/SUBMITTAL REQUIREMENTS hdr

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

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

Minn. R. 7019.1000, subp. 3


16900013 - 005

Facility Name:

Permit Number:

06/26/14A-3

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

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

Minn. R. 7019.1000, subp. 2

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

Minn. R. 7019.1000, subp. 1

Notification of Deviations Endangering Human Health or the Environment Report:Within 2 working days of discovery, notify the Commissioner in writing of anydeviation from permit conditions which could endanger human health or theenvironment. Include the following information in this written description:1. The cause of the deviation;2. The exact dates of the period of the deviation, if the deviation has beencorrected;3. Whether or not the deviation has been corrected;4. The anticipated time by which the deviation is expected to be corrected, if not yetcorrected; and5. Steps taken or planned to reduce, eliminate, and prevent reoccurrence of thedeviation.

Minn. R. 7019.1000, subp. 1

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

Minn. R. 7007.1150 - 7007.1500

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

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

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

Minn. R. 7019.3000 - 7019.3100

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


16900013 - 005

Facility Name:

Permit Number:

06/26/14A-4

Subject Item: GP 001 Sulfur Pans

Associated Items: EU 041 Oxidation Unit - MH-2 Sulfur Pans (SV 005)

EU 043 Oxidation Unit - MH-3 Sulfur Pans (SV 006)


EMISSION LIMITS hdr

Material Usage: less than or equal to 120 tons/year using 12-month Rolling Sum .This is a total combined sulfur usage limit for all units listed in GP 001.

Title I Condition: To avoid classification as a majorsource under 40 CFR Section 52.21 and Minn. R.7007.3000

RECORDKEEPING REQUIREMENTS hdr

Sulfur Usage Recordkeeping: Each operating day, the Permittee shall record thetotal quantity of sulfur consumed by the units listed in GP 001.

By the 15th day of each month, the Permittee shall calculate and record thefollowing:

1. The total tons of sulfur burned in the GP 001 units during the previous calendarmonth;2. The total tons of sulfur burned in GP 001 units during the previous 12-monthperiod (12-month rolling sum).



16900013 - 005

Facility Name:

Permit Number:

06/26/14A-5

Subject Item: GP 003 Indirect Heating Equipment post-1977

Associated Items: EU 062 Process Heater - MH-2 Kiln Heater 1

EU 063 Process Heater - MH-2 Kiln Heater 2






EU 069 Process Heater - MH-3 Kiln Heater #4


EMISSION LIMITS hdr

Total Particulate Matter: less than or equal to 0.4 lbs/million Btu heat input . Thislimit applies individually to each unit listed in GP 003. PTE based on worst casefuel allowed is 0.007 lbs/million Btu heat input for each unit.

Minn. R. 7011.0515, subp. 1

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

Minn. R. 7011.0515, subp. 2

Fuels allowed: natural gas and propane only, by design Minn. R. 7007.0800, subp. 2


16900013 - 005

Facility Name:

Permit Number:

06/26/14A-6

Subject Item: GP 005 Fabric Filter Requirements

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

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




Units controlled by CE 002 (SV 002): EU 001, EU 002, EU 003, EU 005, EU 007,EU 009, EU 049, EU 057

Units controlled by CE 003 (SV 003): EU 004, EU 012, EU 013, EU 014, EU 020,EU 048, EU 050, EU 071, EU 072

Units controlled by CE 004 (SV 007): EU 016, EU 017, EU 053, EU 054, EU 073


hdr

EMISSION LIMITS hdr

The Permittee shall operate and maintain each fabric filter at all times that anyemission unit controlled by the fabric filter is in operation. The Permittee shalldocument periods of non-operation of the control equipment when thecorresponding process is operating.

TItle I Condition: To avoid classification as a majorsource under 40 CFR Section 52.21 and Minn. R.7007.3000

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

Minn. R. 7007.0800, subp. 14

The Permittee shall operate and maintain each fabric filter in GP 005 so that eachfabric filter achieves a collection efficiency for Total Particulate Matter: greater thanor equal to 99.0 percent collection efficiency

Title I Condition: To avoid classification as a majorsource and modification under 40 CFR Section 52.21and Minn. R. 7007.3000

The Permittee shall operate and maintain each fabric filter in GP 005 so that eachfabric filter achieves a collection efficiency for PM < 10 micron: greater than orequal to 99.0 percent collection efficiency


The Permittee shall operate and maintain each fabric filter in GP 005 so that eachfabric filter achieves a collection efficiency for PM < 2.5 micron: greater than orequal to 93.0 percent collection efficiency

Minn. R. 7007.0800, subp. 2

Pressure Drop: greater than or equal to 1.0 inches of water column and less thanor equal to 8.0 inches of water column for each fabric filter, unless a new range isset pursuant to Minn. R. 7017.2025, subp. 3 based on the values recorded duringthe most recent MPCA-approved performance test where compliance wasdemonstrated. The new range shall be implemented upon receipt of the Notice ofCompliance letter granting preliminary approval. The range is final upon issuanceof a permit amendment incorporating the change. The Permittee shall record thepressure drop at least once every 24 hours when in operation.


MONITORING AND RECORDKEEPING REQUIREMENTS hdr

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


Recordkeeping of Visible Emissions and Pressure Drop. The Permittee shall recordthe 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 theobserved pressure drop was within the range specified in this permit.

Title I Condition: To avoid classification as a majorsource under 40 CFR Section 52.21 and Minn. R.7007.3000; Minn. R. 7007.0800, subp. 5

Monitoring Equipment: The Permittee shall install and maintain the necessarymonitoring equipment for measuring and recording pressure drop as required bythis permit. The monitoring equipment must be installed, in use, and properlymaintained when the monitored fabric filter is in operation, as required by Minn. R.7011.0075, subp. 3.

Minn. R. 7007.0800, subp. 4

Periodic Inspections: At least once per calendar quarter, or more frequently asrequired by the manufacturing specifications, the Permittee shall inspect the controlequipment components. The Permittee shall maintain a written record of theseinspections.

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


16900013 - 005

Facility Name:

Permit Number:

06/26/14A-7

Corrective Actions: The Permittee shall take corrective action as soon as possible ifany of the following occur:- Visible emissions are observed;- 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 needrepair.Corrective actions shall return the pressure drop to within the permitted range,eliminate visible emissions, and/or include completion of necessary repairsidentified during the inspection, as applicable. Corrective actions include, but arenot limited to, those outlined in the O & M Plan for the fabric filter. The Permitteeshall keep a record of the type and date of any corrective action taken for each filter

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

The Permittee shall maintain each piece of control equipment according to themanufacturer's specification, shall conduct inspections, and maintaindocumentation of those actions as required by Minn. R. 7011.0075, subp. 2(A) to2(I).

Minn. R. 7007.0800, subp. 2

Initial Hood Certification and Evaluation: The control device hood must conform tothe requirements listed in Minn. R. 7011.0072, subp. 2(B), and the Permittee shallcertify this as specified in Minn. R. 7011.0072, subps. 2 and 3. The Permittee shallmaintain a copy of the evaluation and certification on site.

Minn. R. 7007.0800, subp. 2


16900013 - 005

Facility Name:

Permit Number:

06/26/14A-8

Subject Item: GP 007 Grain Handling Operations Subject to Minn. R. 7011.1005





EU 001 Material Handling - West Barley Gallery

EU 002 West Barley Jump Leg Elevator

EU 003 West Barley Bsmnt Conveyor

EU 004 East Barley Bsmnt Conveyor

EU 005 Material Handling - Receiving Leg

EU 007 Cleaning Equipment - Barley Shaker Cleaner

EU 009 West Transfer Leg Elevator

EU 012 Material Handling - Unload Scale

EU 013 Cleaning Equipment - Debearders

EU 014 Cleaning Equipment - Aspirator

EU 016 Malt Gallery Belt Conveyor

EU 017 Cleaning Equipment - Kiln Malt Cleaners

EU 018 Malt Basement Belt Conveyor

EU 019 Malt Byproduct (Sprouts and Screenings) Dust Tank

EU 020 Material Handling - Sprout Transfer

EU 048 East Barley Gallery Conveyor

EU 049 East Transfer Leg Elevator

EU 050 Material Handling - Transfer Scale

EU 053 Elevator - Kiln Malt Leg

EU 054 Elevator - Malt Transfer Leg

EU 055 Elevator - Shipping Leg

EU 056 Cleaning Equipment - Shipping Cleaners

EU 058 Elevator - MH-1 Leg

EU 071 Screens - Barley width graders

EU 072 Screens - Barley length graders

EU 073 Silo/bin - Barley Storage

EU 074 Silo/bin - Malt Storage

SV 002 Barley Elevator West Baghouse (CE002)

SV 003 Barley Elevator East Baghouse (CE003)

SV 007 Malt Storage East Baghouse (CE004)

SV 008 Malt Storage West Baghouse (CE005)


To avoid being classified as a grain terminal elevator as defined by 40 CFR Section60.301(c), EU 074 Malt Storage shall not store any grain (non-malted barley).

EU 073 Barley Storage shall only store grain (barley) as defined by 40 CFR Section60.301(a). No grain by-products or malted barley may be stored at any time in EU073.

Minn. R. 7007.0800, subp. 2

EMISSION LIMITS hdr

Opacity: less than or equal to 10 percent opacity (process emissions from SV 002,SV 003, SV 007, and SV 008).

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


16900013 - 005

Facility Name:

Permit Number:

06/26/14A-9

CONTROL REQUIREMENTS (see GP 005 for specific operation and maintenancerequirements)

hdr

All emission units listed in GP 007 must be controlled by control equipment listed inGP 005.


Units controlled by CE 002 (SV 002): EU 001, EU 002, EU 003, EU 005, EU 007,EU 009, EU 049

Units controlled by CE 003 (SV 003): EU 004, EU 012, EU 013, EU 014, EU 020,EU 048, EU 050, EU 071, EU 072



Title I Condition: To avoidclassification as a major sourceunder 40 CFR Section 52.21 andMinn. R. 7007.3000; Minn. R.7007.0800, subps. 2 and 14

Total Particulate Matter: greater than or equal to 80.0 percent collection efficiency .Compliance with this requirement is met by complying with the more stringent Title IConditions for the percent collection and control efficiencies of the controlequipment, which are listed below and in the GP 005 requirements.

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

The Permittee shall operate and maintain the control equipment associated withGP 007 operations such that it achieves a total control efficiency for TotalParticulate Matter: greater than or equal to 99.0 percent control efficiency


The Permittee shall operate and maintain the control equipment associated withGP 007 operations such that it achieves a total control efficiency for PM < 10micron: greater than or equal to 99.0 percent control efficiency


The Permittee shall operate and maintain the control equipment associated withGP 007 operations such that it achieves a total control efficiency for PM < 2.5micron: greater than or equal to 93.0

Minn. R. 7007.0800, subp. 2


16900013 - 005

Facility Name:

Permit Number:

06/26/14A-10

Subject Item: GP 009 Malt Houses

Associated Items: EU 040 Kiln - MH-2 Kiln Grain Beds


EU 042 Kiln - MH-3 Kiln Grain Beds


SV 005 Malt House 2 (EU 040 & 041)

SV 006 Malt House 3 (EU 042 & 043)


EMISSION LIMITS hdr

Total Particulate Matter: less than or equal to 0.30 grains/dry standard cubic foot ofexhaust gas unless required to further reduce emissions to meet the less stringentlimit of either Minn. R. 7011.0730 or Minn. R. 7011.0735. This limit appliesseparately to each stack/vent in GP 009.

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

Opacity: less than or equal to 20 percent opacity for each stack/vent in GP 009. Minn. R. 7011.0715, subp. 1(B)


16900013 - 005

Facility Name:

Permit Number:

06/26/14A-11

Subject Item: GP 010 Receiving/Loadout operations subject to Minn. R. 7011.1005



EU 008 DCL Barley Byproduct Loadout Spout

EU 057 Rail Unloading

EU 060 Malt Loadout Rail/Truck

EU 061 Loading/Unloading - Sprouts/Screenings Dust Tank DCL Truck Loadout Spout

SV 002 Barley Elevator West Baghouse (CE002)

SV 008 Malt Storage West Baghouse (CE005)


EMISSION LIMITS hdr

Opacity: less than or equal to 10 percent opacity (process emissions from SV 002and SV 008).

SV 002 is also subject to a more restrictive limit under the NSPS subp. DDrequirements (see GP 008). The unit controlled by CE 002 is exhausted to SV 002.Therefore, the stack opacity limit of the NSPS subp. DD (GP 008) supersedes theGP 010 stack opacity limit for SV 002.

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

Opacity: less than or equal to 5 percent opacity for uncaptured emissions(emissions not captured and routed to control equipment), as required by Minn. R.7011.1005, subp. 3(A). This limit applies individually to each emission unit in GP010, except when a truck is being loaded by EU 060 (see below).

Minn. R. 7007.0800, subp. 2

Opacity: less than or equal to 10 percent opacity for uncaptured emissions(emissions not captured and routed to control equipment), as required by Minn. R.7011.1005, subp. 3(B). This limit applies to EU 60 and only when a truck is beingloaded.

Minn. R. 7007.0800, subp. 2

CONTROL REQUIREMENTS (see GP 005 for specific operation and maintenancerequirements)

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Units controlled by CE 002 (SV 002): EU 008, EU 057

Units controlled by CE 005 (SV 008): EU 060, EU 061

Title I Condition: To avoidclassification as a major sourceunder 40 CFR Section 52.21 andMinn. R. 7007.3000; Minn. R.7007.0800, subps. 2 and 14

Total Particulate Matter: greater than or equal to 80.0 percent collection efficiency .Compliance with this requirement is met by complying with the more stringent Title ICondition for the percent collection efficiency of the control equipment, which islisted in the GP 005 requirements.

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

The Permittee shall operate and maintain the control equipment associated withvented processes such that it achieves a capture efficiency for Total ParticulateMatter: greater than or equal to 80.0 percent capture efficiency

Title I Condition: To avoid classification as a majorsource under 40 CFR Section 52.21 and Minn. R.7007.3000; Minn. R. 7007.0800, subp. 2 and 14

The Permittee shall operate and maintain the control equipment associated withvented processes such that it achieves a capture efficiency for PM < 10 micron:greater than or equal to 80.0 percent capture efficiency

Title I Condition: To avoid classification as a majorsource under 40 CFR Section 52.21 and Minn. R.7007.3000; Minn. R. 7007.0800, subp. 2 and 14

The Permittee shall operate and maintain the control equipment associated withvented processes such that it achieves a capture efficiency for PM < 2.5 micron:greater than or equal to 80.0 percent capture efficiency

Minn. R. 7007.0800, subp. 2

Initial Hood Certification and Evaluation: Each control device hood must conform tothe requirements listed in Minn. R. 7011.0072, subp. 2(B), and the Permittee shallcertify this as specified in Minn. R. 7011.0072, subps. 2 and 3. The Permittee shallmaintain a copy of the evaluation and certification on site.

Minn. R. 7007.0800, subp. 2

TABLE B: SUBMITTALSFacility Name: Malteurop North America Inc - Winona

Permit Number: 16900013 - 005

06/26/14B-1

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

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

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 parts7007.0100 to 7007.1850 must be certified by a responsible official, defined in Minn. R. 7007.0100, subp. 21. Other submittals shallbe certified as appropriate if certification is required by an applicable rule or permit condition.

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

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

Send any application for a permit or permit amendment to:

Fiscal Services Minnesota Pollution Control Agency 520 Lafayette Road North St. Paul, Minnesota 55155-4194

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

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 NOTIFICATIONSFacility Name: Malteurop North America Inc - Winona


06/26/14B-2

What to send When to send Portion of Facility Affected

Application for Permit Reissuance due 180 days before expiration of ExistingPermit.

Total Facility

Submittal due 180 days after Permit Issuance(169000013-005) for Initial Hood Certificationand Evaluation

GP005

Submittal due 180 days after Permit Issuance(169000013-005) for Initial Hood Certificationand Evaluation

GP010

TABLE B: RECURRENT SUBMITTALSFacility Name: Malteurop North America Inc - Winona


06/26/14B-3

What to send When to send Portion of Facility Affected

Report due 30 days before end of each calendarhalf-year following Permit Issuance. TheCompliance Schedule Progress Report shallcontain the information specified in Minn. R.7007.0800, subp. 6(B) and shall be submittedon a form approved by the Commissioner inaccordance with the Compliance Schedulecontained in Table C. Progress Reports willnot be needed upon completion of allactivities contained in the ComplianceSchedule.

Total Facility

Semiannual Deviations Report due 30 days after end of each calendarhalf-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. If no deviationshave occurred, the Permittee shall submit thereport stating no deviations.

Total Facility

Compliance Certification due 31 days after end of each calendar yearfollowing Permit Issuance for the previouscalendar year. The Permittee shall submit thison a form approved by the Commissioner,both to the Commissioner and to the US EPAregional office in Chicago. This report coversall deviations experienced during the calendaryear.

Total Facility

APPENDIX MATERIAL

Facility Name: Malteurop North America, Inc. ‐ Winona Permit Number: 16900013‐005

APPENDIX A: INSIGNIFICANT ACTIVITIES AND APPLICABLE REQUIREMENTS

The table below lists the insignificant activities that are currently at the facility and their associated general applicable requirements.

Minn. R. 7007.1300, subpart

Rule Description of the Activity Applicable Requirement

3(E)

Storage tanks:

2. non‐hazardous air pollutant VOC storage tanks with a combined total tankage capacity of not more than 10,000 gallons of non‐hazardous air pollutant VOCs and with a vapor pressure of not more than 1.0 psia at 60 degrees Fahrenheit. ‐ 550 gallon diesel fuel storage tank

Minn. R. 7011.0710/0715

3(G) Emissions from a laboratory, as defined in the subpart. ‐ Product analysis laboratory

Minn. R. 7011.0510/0515;

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

3(H) Miscellaneous:

3. brazing, soldering or welding equipment; ‐ Maintenance welding

Minn. R. 7011.0510/0515;

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

7. cleaning operations: alkaline/phosphate cleaners and associated cleaners and associated burners. ‐ General plant cleaning with pressurized water and mild chlorine solution

Minn. R. 7011.0510/0515;

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

3(I)

Individual emissions units at a stationary source, each of which have a potential to emit the following pollutants in amounts less than: 1. 4,000 lbs./year of carbon monoxide; 2. 2,000 lbs./year each of nitrogen oxide, sulfur dioxide, particulate matter, particulate matter less than ten microns, volatile organic compounds (including hazardous air pollutant‐containing VOC), and ozone; and 3. 1,000 tpy of CO2e The barley and malt elevator vacuums have a PTE less than 1 tpy of all pollutants. Exhaust points from the malthouses and germination processes also qualify under this subpart. No particulate emissions are expected and CO2 is the primary emission.

Minn. R. 7011.0710/0715

The main office heating boiler has a PTE less than 1 tpy of all criteria pollutants, and less than 1,000 tpy of CO2e.

Minn. R. 7011.0510/0515

Minn. R. 7007.1300, subp. 4

Each of the four small heating boilers has a PTE below the thresholds of Minn. R. 7007.1300, subp. 4.

Minn. R. 7011.0510/0515

Minn. R. 7008.4100, subp. 2

The maintenance parts cleaning tank uses less than 200 gallons of solvent per year and meets the requirements of Minn. R. 7008.4100, subp. 2.

Minn. R. 7011.0510/0515

APPENDIX MATERIAL

Facility Name: Malteurop North America Inc. ‐ Winona Permit Number: 16900013‐005

APPENDIX B: FUGITIVE EMISSIONS CONTROL PLAN

1. Inspections of facility grounds will be performed weekly by the elevator foreman and necessary cleaning assigned.

2. Spillage from truck loading operations or control equipment malfunction will be cleaned up no later than four hours after they occur unless safety or weather conditions prevent starting within this time frame. In these cases cleanup will start as soon as possible after conditions allow it.

3. Employees will be instructed that vacuuming is the preferred method of cleaning and that use of compressed air is to be considered a last resort method of cleaning. When compressed air is used care shall be taken to prevent fugitive dust emissions.

4. Employees will be instructed that loadout operations will be done in a manner to reduce free fall height of product.

5. All bag filters will be operated as designed to control fugitive emissions during receiving, loadout and handling.

6. All bag filters will be operated as designed to control fugitive emission sources including but not limited to:

a) Truck and rail car loadout

b) Truck and rail receiving

c) Spillage from control and process equipment

d) Open doors and windows in headhouse and gallery areas

7 Roof areas will be inspected by the responsible foreman on a weekly basis and cleaning will be assigned as necessary.

8. Weekly inspection reports will indicate the following items at a minimum:

a) Date inspection was completed

b) Areas inspected

c) What condition was found

d) Whether an employee was assigned to clean area

e) Whether such cleaning was completed

f) Whether any maintenance or repair of control equipment (dust collectors) was necessary

9. Weekly inspection reports shall be retained for 5 years.

BARLEY ELEVATOR DATE: _______________________

DUST COLLECTOR: WEST (CE 003) EAST (CE 002) OK COMMENTS OK COMMENTS FANS RUNNING

REVERSE AIR BLOWER ON ROTARY VALVE TURNING PNEUMATIC TAKEAWAY ON EXTERIOR PIPING (LEAKS?) DISCHARGE (VISIBLE EMISSIONS?)

PRESSURE READINGS ROOF AREAS: __________________________ INSPECTION COMMENTS_________________________________________________________________ ____________________________________________________________________________________ ____________________________________________________________________________________ BARLEY SCALE AREA: ___________________ ASSIGNMENTS_____________________________________________________________________ ____________________________________________________________________________________ ____________________________________________________________________________________ BARLEY UNLOAD AREA: _________________ COMPLETION______________________________________________________________________ ____________________________________________________________________________________ ____________________________________________________________________________________ GROUNDS: A) FROM MALT LOADOUT WEST TO FENCELINE

B) PARKING & STORAGE AREA C) ROADWAY NORTH OF MH #2 & 3 D) ROADWAY EAST OF KILN

ADDITIONAL COMMENTS: __________________________________________________________________________________________ __________________________________________________________________________________________ ____________________________________________________________________________________________________________________________________________________________________________________ FOREMAN: ________________________________________________ PLANT MANAGER: _________________________________________

MALT ELEVATOR DATE: ___________________

DUST COLLECTOR: EAST (CE 004) WEST (CE 005)

OK COMMENTS OK COMMENTS

FANS RUNNING

REVERSE AIR BLOWER ON ROTARY VALVE TURNING PNEUMATIC TAKEAWAY ON EXTERIOR PIPING (LEAKS?) DISCHARGE (VISIBLE EMISSIONS?) PRESSURE READINGS ROOF AREAS: __________________________ INSPECTION COMMENTS_________________________________________________________________ ____________________________________________________________________________________ ____________________________________________________________________________________ BARLEY SCALE AREA: ___________________ ASSIGNMENTS_____________________________________________________________________ ____________________________________________________________________________________ ____________________________________________________________________________________ BARLEY UNLOAD AREA: _________________ COMPLETION______________________________________________________________________ ____________________________________________________________________________________ ____________________________________________________________________________________ GROUNDS: A) FROM MALT LOADOUT WEST TO FENCELINE

B) PARKING & STORAGE AREA C) ROADWAY NORTH OF MH #2 & 3 D) ROADWAY EAST OF KILN

ADDITIONAL COMMENTS: __________________________________________________________________________________________ __________________________________________________________________________________________ ____________________________________________________________________________________________________________________________________________________________________________________ FOREMAN: ________________________________________________ PLANT MANAGER: _________________________________________

MALTHOUSE DATE: ___________________ ROOF AREAS: INSPECTION

COMMENTS______________________________________________________________________________

__________________________________________________________________________________________

__________________________________________________________________________________________

A) MH #2&3________________________________________________________________________

ASSIGNMENTS_____________________________________________________________________

____________________________________________________________________________________

____________________________________________________________________________________

B) MH #2&3________________

COMPLETION_____________________________________________________________

____________________________________________________________________________________

____________________________________________________________________________________

ADDITIONAL COMMENTS:

__________________________________________________________________________________________

__________________________________________________________________________________________

__________________________________________________________________________________________

__________________________________________________________________________________________

FOREMAN: ________________________________________________ PLANT MANAGER: ________________________________________

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