AIR EMISSION PERMIT NO Major Amendment IS ISSUED TO. Ardent Mills LLC

Transcription

1 AIR EMISSION PERMIT NO Major Amendment IS ISSUED TO Ardent Mills LLC ARDENT MILLS FLOUR MILL 2005 Vermillion Street South Hastings, Dakota County, Minnesota The emission units, control equipment and emission stacks at the stationary source authorized in this permit amendment are as described in the Permit Applications Table. This permit amendment supersedes Air Emission Permit No , 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 to 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 and as such as are enforceable by U.S. Environmental Protection Agency (EPA) Administrator or citizens under the Clean Air Act. Permit Type: State Permit; Limits to Avoid Part 70/Limits to Avoid NSR Operating Permit Issue Date: December 9, 2002 Major Amendment Issue Date: September 22, 2015 Expiration Date: Permit does not expire - Title I Conditions do not expire. Don Smith, P.E., Manager Air Quality Permits Section Industrial Division for John Line Stine Commissioner Minnesota Pollution Control Agency TDD (for hearing and speech impaired only): (651) Printed on recycled paper containing at least 10% fibers from paper recycled by consumers

2 Permit Applications Table Permit Type Application Date Permit Action Total Facility Operating Permit 2/15/96 revised 11/05/ Major Amendment 7/28/ Administrative Amendment 6/11/ Administrative Amendment 5/16/ Reopening (Major Amendment) 10/31/ TABLE OF CONTENTS Notice to the Permittee Permit Shield Facility Description Amendment Descriptions Table A: Limits and Other Requirements Table B: Submittals Table C: Compliance Schedule - Not used in this permit Appendices: Appendix I: Insignificant Activities and Applicable Requirements Appendix II: Equipment List

3 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 Outside Metro Area TTY The rules governing these programs are contained in Minn. R. chs Written questions may be sent to: Minnesota Pollution Control Agency, 520 Lafayette Road North, St. Paul, Minnesota 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 , 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 and , subp. 2, notwithstanding the conditions of this permit specifying compliance practices for applicable requirements, any person (including the Permittee) may also use other credible evidence to establish compliance or noncompliance with applicable requirements. FACILITY DESCRIPTION: Ardent Mills Four Mill operates a wheat flour and animal feed mill in Hastings, Minnesota. The facility consists of hardwheat mills, durum mills, durum processing, a rye mill, and associated elevator, storage, and packaging areas. Seventy-five percent of the wheat received is processed into flour and the remaining 25 percent into feed. The facility operates a boiler for heating and wheat tempering during the winter months.the facility has accepted limits on the amount of wheat to be processed, and on the amount of fumigant (methyl bromide), which may be used. These limits were federally enforceable, and resulted in the facility being a non-major source under the Part 70 permit program, New Source Review, and the National Emission Standards for Hazardous Air Pollutants program. AMENDMENT DESCRIPTIONS: PER002 (Major Amendment): This amendment removed all three Particulate Matter less than 10 microns (i 0) process throughput limits. The process throughput limits which limited i 0 to 95 tpy were replaced by an overall facilitywide 95 tons per year (tpy) 10 emission limit. Hence, there was no change in the M Potential to Emit or other pollutant emissions. PER003 (Administrative Amendment): This amendment added a new control equipment filter (CE036) and accounted for four new filters (CE ). The filters CE replaced CE013 and CE025 since both these filters were twin filters. CE013 and CE025 were both retired and the permit language, including monitoring and recordkeeping,

4 apply to the filters that are replacing the retired filters. CE036 has the requirements of flour storage and loading (EU007). PER004 (Current permit action; Major Amendment): Title I HAP limits for fugitive emission sources have been changed to 9.0 tpy for single HAPs and 20.0 tpy for total HAP. This permit action incorporates an Administrative Amendment to change the facility name from ConAgra Flour Mill - Hastings to Ardent Mills Flour Mill and the owner from ConAgra Foods to Ardent Mills LLC. In addition, recurring opacity testing for fugitive emissions was added to EU002 and EU005.

5 TABLE A: LIMITS AND OTHER REQUIREMENTS Facility Name: Ardent Mills Flour Mill Permit Number: A-1 09/21/15 Table A contains limits and other requirements with which your facility must comply. The limits are located in the first column of the table (What To do). The limits can be emission limits or operational limits. This column also contains the actions that you must take and the records you must keep to show that you are complying with the limits. The second column of Table A (Why to do it) lists the regulatory basis for these limits. Appendices included as conditions of your permit are listed in Table A under total facility requirements. Subject Item: Total Facility FACILITY-SPECIFIC REQUIREMENTS What to do This permit establishes limits on the facility to keep it a min or source under New Source Review and a nonmajor source under Part 70. The Permittee may not make any change at the source that would make the so urce a major source under New Source Review or Part 70 until a permit amendment has b een issued. This includes changes that might otherwise qualify as insignificant modifications and minor or moderate amendments. Permit Appendix: This permit contains a appendices as listed in the permit Table of Contents. The Permittee shall comply with all requirements contained in the appendices. OPERATIONAL REQUIREMENTS Circumvention: Do not install or use a device or means that conceals or dilutes emissions, which would otherwise violate a federal or sta te air pollution control rule, without reducing the total amount of pollutant emitted. Air Pollution Control Equipment: Operate all pollution control equipment whenever the corresponding process equipment and emission units are operated. Operation and Maintenance Plan: Retain at the stationary source an operation and maintenance plan for all air pollution control equipment. At a minimum, the O & M plan shall identify all air pollution control equipment and control practices and shall include a preventative maintenance program for the equipment and practices, a description of (the minimum but not necessarily the only) corrective actions to be taken to restore the equipment and practices to proper operation to meet applicable permit conditions, a description of the employee training program for proper operation and maintenance of the control equipment and practices, and the records kept to demonstrate plan implementation. Operation Changes: In any shutdown, breakdown, or deviation the Permittee shall immediately take all practical steps to modify operations to reduce the emission of any regulated air pollutant. The Commissioner may require feasible and practical modifications in the operation to reduce emissions of air pollutants. No emissions units that have an unreasonable shutdown or breakdown frequency of process or control equipment shall be permitted to operate. Fugitive Emissions: Do not cause or permit the handling, use, trans porting, or storage of any material in a manne r which may allow avoidable amounts of particulate matter to become airborne. Comply with all other requiremen ts listed in Minn. R Noise: The Permittee shall comply with the noise standards set forth in Minn. R to at all times during the operation of any emission units. This is a state only requirement and is not enforceable by the EPA Administrator or citizens under the Clean Air Act. Inspections: The Permittee shall comply with the inspection procedures and requirements as found in Minn. R , subp. 9(A). The Permittee shall comply with the General Conditions listed in Minn. R , subp. 16. PERFORMANCE TESTING Performance Testing: Conduct all performance tests in accordance with Minn. R. ch unless otherwise noted in Tables A, B, and/or C. hdr Why to do it Title I Condition: Avoid major source under 40 CFR (b)(1)(i) and Minn. R ; Avoid major source under 40 CFR 70.2 and Minn. R Minn. R , subp. 2 hdr Minn. R Minn. R , subp. 2; Minn. R , subp. 16(J) Minn. R , subps. 14 and 16(J) Minn. R , subp. 4 Minn. R Minn. R Minn. R , subp. 9(A) Minn. R , subp. 16 hdr Minn. R. ch. 7017

6 TABLE A: LIMITS AND OTHER REQUIREMENTS A-2 09/21/15 Facility Name: Ardent Mills Flour Mill Permit Number: Performance Test Notifications and Submittals: Performance Tests are due as outlined in Table A of the permit. See Table B for additional testing requirements. Minn. R ; Minn. R , subps. 1-4, Minn. R , subps. 1-2 Performance Test Notification (written): due 30 days before each Performance Tesi Performance Test Plan: due 30 days before each Performance Test Performance Test Pre-test Meeting: due 7 days before each Performance Test Performance Test Report: due 45 days after each Performance Test Performance Test Report - Microfiche Copy: due 105 days after each Performance Test The Notification, Test Plan, and Test Report may be submitted in an alternative format as allowed by Minn. R Limits set as a result of a performance test (conducted before or after permit issuance) apply until superseded as state d in the MPCA's Notice of Compliance letter granting preliminary approval. Preliminary approval is based on formal review of a subsequent performance test on the same unit as spe cified by Minn. R , subp. 3. The limit is final upon issu ance of a permit amendment incorporating the change. MONITORING REQUIREMENTS Monitoring Equipment Calibration - The Permittee shall either: Minn. R , subp. 3 hdr Minn. R , subp. 4(D) 1. Calibrate or replace required monitoring equipment every 12 months; or 2. Calibrate at the frequency stated in the manufacturer's specifications. For each monitor, the Permittee shall maintain a record of all calibrations, including the date conducted, and any corrective action that resulted. The Permittee shall include the calibration frequencies, procedures, and manufacturer's specifications (if applicable) in the Operations and Maintenance Plan. Any requirements applying to continuous emission monitors are listed separately in this permit. Operation of Monitoring Equipment: Unless otherwise noted in Tables A, B, and/or C, monitoring a process or control equipment connected to that process is not necessary during periods when the process is shutdown, or during checks of the monitoring systems, such as calibration checks and zero and span adjustments. I f monitoring records are required, they should reflect any such p eriods of process shutdown or checks of the monitoring system. RECORDKEEPING Recordkeeping: Retain all records at the stationary source, unless otherwise specified within this permit, from the date of monitoring, sample, measurement, or report. Records which must be retained at this location include all calibration and maintenance records, all original recordings for continuous monitoring instrumentation, and copies of all reports required by the permit. Records must conform to the requirements listed in Minn. R , subp. 5(A). Recordkeeping: Maintain records describing any insignificant modifications (as required by Minn. R , subp. 3) or changes contravening permit terms (as required by Minn. R , subp. 2), including records of the emissions resulting from those changes. If the Permittee determines that no permit amendment or notification is required prior to making a change, the Permittee must retain records of all calculations required under Minn. R For nonexpiring permits, these records shall be kept for a period of five years from the da te that the change was made. The records shall be kept at the stationary source for the current calendar year of operation and may be kept at the stationary source or office of the stationary source for all other years. The records may be maintained in either electronic or paper format. REPORTING/SUBMITTALS Shutdown Notifications: Notify the Commissioner at least 24 hours in advance of a planned shutdown of any control equipment or process equipment if the shutdown would cause any increase in the emissions of any regulated air pollutant. If the owner or operator does not have advance knowledge of the shutdown, notification shall be made to the Commissioner as soon as possible after the shutdown. However, notification is not required in the circumstances outlined in Items A, B and C of Minn. R , subp. 3. At the time of notification, the owner or operator shall inform the Commissioner of the cause of the shutdown and the estimated duration. The owner or operator shall notify the Commissioner when the shutdown is over. Minn. R , subp. 4(D) hdr Minn. R , subp. 5(C) Minn. R , subp. 5(B) Minn. R , subp. 4 hdr Minn. R , subp. 3 '

7 TABLE A: LIMITS AND OTHER REQUIREMENTS A-3 09/21/15 Facility Name: Ardent Mills Flour Mill Permit Number: Breakdown Notifications: Notify the Commissioner within 24 hours of a breakdown of more than one hour duration of any control equipment or process equipment if the breakdown causes any increase in the emissions of any reg ulated air pollutant. The 24-hour time period starts when the breakdown was discovered or reasonably should have been discovered by the owner or operator. However, notification is not required in the circumstances outlined in Items A, B and C of Minn. R , subp. 2. At the time of notification or as soon as possible thereafter, the owner or operator shall inform the Commissioner of the cause of the breakdown and the estimated duration. The owner or operator shall notify the Commissioner when the breakdown is over. Notification of Deviations Endangering Human Health or the Environment: As soon as possible after discovery, notify the Commissioner or the state duty officer, either orally or by facsimile, of any deviation from permit conditions which could endanger human health or the environment. Notification of Deviations Endangering Human Health or the Environment Report: Within 2 working days of discovery, notify the Commissioner in writing of any deviation from permit conditions which could endanger human health or the environment. Include the following information in this written description: 1. the cause of the deviation; 2. the exact dates of the period of the deviation, if the deviation has been corrected; 3. whether or not the deviation has been co rrected; 4. the anticipated time by which the deviation is expected to be corrected, if not yet corrected; and 5. steps taken or planned to reduce, eliminate, and prevent reoccurrence of the deviation. Application for Permit Amendment: If a permit amendment is needed, submit an application in accordance with the requirements of Minn. R through Minn. R Submittal dates vary, depending on the type of amendment needed. Minn. R , subp. 2 Minn. R , subp. 1 Minn. R , subp. 1 Minn. R Upon adoption of a new or amended federal applicable requirement, and if there are more than 3 years remaining in the permit term, the Permittee shall file an application for an amendment within nine months of promulgation of the applicable requirement, pursuant to Minn. R , subp. 3. Extension Requests: The Permittee may apply for an Administrative Amendment to extend a deadline in a permit by no more than 120 days, provided the proposed deadline extension meets the requirements of Minn. R , subp. 1(H). Performance testing deadlines from the General Provisions of 40 CFR pt. 60 and pt. 63 are examples of deadlines for which the MPCA does not have authority to grant extensions and therefore do not meet the requirements of Minn. R , subp. 1(H). Emission Inventory Report: due on or before April 1 of each calendar year following permit issuance, to be submitted on a form approved by the Commissioner. Minn. R , subp. 1(H) Minn. R Emission Fees: due 30 days after receipt of an MPCA bill. Minn. R The Permittee must submit a Risk Management Plan (RMP) under 40 CFR pt. 68. Each owner or operator of a stationary source, at which a regulated substance is present above a threshold quantity in a process, shall design and implement an accidental release prevention program. An initial RMP must be submitted no later than the latest of the following dates: 1) June 21, 1999; 2) Three years after the date on which a regulated substance is first listed under 40 CFR Section ; or 3) The date on which a regulated substance is first present above a threshold quantity in a process. A full update and resubmission of the RMP is required at least once every five years. The five-year anniversary date is reset whenever your facility fully updates and resubmits their RMP. Submit RMPs to the Risk Management Plan Reporting Center, P.O. Box 1515, Lanham-Seabrook, Maryland RMP information may be obtained at or by calling CFR pt. 68

8 TABLE A: LIMITS AND OTHER REQUIREMENTS Facility Name: Ardent Mills Flour Mill Permit Number: A-4 09/21/15 Subject Item: Associated Items: GP 001 Baghouses CE 001 Fabric Filter - Low Temperature CE 002 Fabric Filter - Low Temperature CE 003 Fabric Filter - Low Temperature CE 004 Fabric Filter - Low Temperature CE 005 Fabric Filter - Low Temperature CE 006 Fabric Filter - Low Temperature CE 007 Fabric Filter - Low Temperature CE 008 Fabric Filter - Low Temperature CE 009 Fabric Filter - Low Temperature CE 010 Fabric Filter - Low Temperature CE 011 Fabric Filter - Low Temperature CE 012 Fabric Filter - Low Temperature CE 014 Fabric Filter - Low Temperature CE 015 Fabric Filter - Low Temperature CE 016 Fabric Filter - Low Temperature CE 017 Fabric Filter - Low Temperature CE 018 Fabric Filter - Low Temperature CE 019 Fabric Filter - Low Temperature CE 020 Fabric Filter - Low Temperature CE 021 Fabric Filter - Low Temperature CE 022 Fabric Filter - Low Temperature CE 023 Fabric Filter - Low Temperature CE 024 Fabric Filter - Low Temperature CE 026 Fabric Filter Low Temperature CE 027 Fabric Filter Low Temperature CE 028 Fabric Filter Low Temperature CE 029 Fabric Filter Low Temperature CE 033 Fabric Filter - Low Temperature CE 034 Fabric Filter Low Temperature CE 035 Fabric Filter Low Temperature CE 036 Fabric Filter Low Temperature CE 037 Fabric Filter Low Temperature CE 038 Fabric Filter Low Temperature CE 039 Fabric Filter Low Temperature CE 040 Fabric Filter Low Temperature T<180 Degrees F T<180 Degrees F T<180 Degrees F T<180 Degrees F T<180 Degrees F T<180 Degrees F T<180 Degrees F T<180 Degrees F T<180 Degrees F T<180 Degrees F T<180 Degrees F T<180 Degrees F T<180 Degrees F T<180 Degrees F T<180 Degrees F T<180 Degrees F T<180 Degrees F T<180 Degrees F T<180 Degrees F T<180 Degrees F T<180 Degrees F ( T<180 Degrees F, T<180 Degrees F, T<180 Degre es F, T<180 Degre es F, T<180 Degrees F, T<180 Degrees F, T<180 Degre es F, T<180 Degre es F, T<180 Degrees F, T<180 Degrees F, T<180 Degrees F, T<180 Degrees F, T<180 Degrees F, T<180 Degrees F What to do If the Permittee replaces any existing fabric filters, adds new fabric filters, or modifies the fabric filters listed in GP 001, such equipment is subject to all of the requirements of GP 001. Prior to making such a change, the Permittee shall apply for and obtain the appropriate permit amendment, as applicable. The Permittee shall operate and maintain each fabric filter in accordance with the Operation and Maintenance (0 & M) Plan. The Permittee shall keep copies of the 0 & M Plan available onsite for use by staff and MPCA staff. Control efficiency requirements can be found at EU 002 through EU 007. Why to do it Title I Condition: Avoid major source under 40 CFR (b)(1)(i) and Minn. R ; Avoid major source under 40 CFR 70.2 and Minn. R Minn. R , subps. 4, 5, and 14

9 TABLE A: LIMITS AND OTHER REQUIREMENTS A-5 09/21/15 Facility Name: Ardent Mills Flour Mill Permit Number: Pressure Drop: greater than or equal to 0.5 inches of water colu mn and less than or equal to 8.0 inches of water column, unless a new range is set pursuant to Minn. R , subp. 3 based on the values recorded during the most recent MPCA-approved performance test where compliance was demonstrated. The new range shall be implemented upon receipt of the Notice of Compliance letter granting preliminary approval. The range is final upon issuance of a permit amendment incorporating the change. Visible Emissions: The Permittee shall check each fabric filter stack for any visible emissions once each day of operation during daylight hours. During inclement weather, the Permittee shall read and record the pressure drop across the fabric filter, once each day of operation. Recordkeeping of Visible Emissions and Pressure Drop. The Permittee shall record the time and date of each visible emission inspection and pressure drop reading, and whether or not any visible emissions were observed, and whether or not the observed pressure drop was within the range specified in this permit Periodic Inspections: At least once per calendar quarter, or more frequently as required by the manufacturing specifications, the Permittee shall inspect the control equipment components. The Permittee shall maintain a written record of these inspections. Corrective Actions: The Permittee shall take corrective action as soon as possible if any of the following occur: - visible emissions are observed; or - the recorded pressure drop is outside the required operating range; or - the fabric filter or any of its components are found during the inspections to need repair. Corrective actions shall eliminate visible emissions, and/or return the pressure drop to within the permitted range, and/or include completion of n ecessary repairs identified during the inspection, as applicable. Corrective actions include, but are not limited to, those outlined in the 0 & M Plan for the equipment. The Permittee shall keep a record of the type and date of any corrective action taken. Monitoring Equipment: The Permittee shall install and maintain the necessary monitoring equipment for measuring and recording pressure drop as required by this permit. The monitoring equipment must be installed, in use, and properly maintained when the monitored fabric filters are in operation. Title I Condition: Avoid major source under 40 CFR (b)(1)(i) and Minn. R ; Avoid major source under 40 CFR 70.2 and Minn. R Title I Condition: Avoid major source under 40 CFR (b)(1 )(i) and Minn. R ; Avoid major source under 40 CFR 70.2 and Minn. R Title I Condition: Avoid major source under 4 0 CFR (b)(1)(i) and Minn. R ; Avoid major source under 40 CFR 70.2 and Minn. R ; Minn. R , subps. 4, 5, and 14 Minn. R , subps. 4, 5, and 14 Minn. R , subps. 4, 5, and 14 Minn. R , subp. 4

10 TABLE A: LIMITS AND OTHER REQUIREMENTS Facility Name: Ardent Mills Flour Mill Permit Number: A-6 09/21/15 Subject Item: Associated Items: GP 002 Cyclones CE 031 Centrifugal Collector - Medium Efficiency CE 032 Centrifugal Collector - Medium Efficiency What to do The Permittee shall operate and maintain each cyclone in accordance with the Operation and Maintenance (O & M) Plan. The Permittee shall keep copies of the O & M Plan available onsite for use by staff and MPCA staff. Pressure Drop: The Permittee shall read and record the pressure drop across each of the two cyclones listed in GP002, once each day of operation. Pressure Drop: greater than or equal to 4.0 inches of water column and less than or equal to 10.0 inches of water column unless a new range is set pursuant to Minn. R , subp. 3 based on the values recorded during the most recent MPCA-approved performance test where compliance was demonstrated. The new range shall be implemented upon receipt of the Notice of Compliance letter granting preliminary approval. The range is final upon issuance of a permit amendment incorporating the change. Recordkeeping of Pressure Drop. The Permittee shall record the time and date of each pressure drop reading, and whether or not the observed pressure drop was within the range specified in this permit. Periodic Inspections: At least once per calendar quarter, or more frequently as required by the manufacturing specifications, the Permittee shall inspect the control equipment components. The Permittee shall maintain a written record of these inspections. Corrective Actions: The Permittee shall take corrective action as soon as possible if any of the following occur: - the recorded pressure drop is outside the required operating range; or - the cyclone or any of its components are found during the inspections to need repair. Corrective actions shall return the pressure drop to within the permitted range and/or include completion of necessary repairs identified during the inspection, as applicable. Corrective actions include, but are not limited to, those outlined in the O & M Plan for the equipment. T he Permittee shall keep a record of the type and date of any corrective action taken. Monitoring Equipment: The Permittee shall install and maintain the necessary monitoring equipment for measuring and recording pressure drop as required by this permit. The monitoring equipment must be installed, in use, and properly maintained when the monitored cyclone is in operation. Why to do it Minn. R , subps. 4-5; Minn. R , subp. 14 Title I Condition: Avoid major source under 40 CFR (b)(1 )(i) and Minn. R ; Avoid major source under 40 CFR 70.2 and Minn. R ; Minn. R , subp. 4, 5, and 14 Title I Condition: Avoid major source under 40 CFR (b)(1)(i) and Minn. R ; Avoid major source under 40 CFR 70.2 and Minn. R Title 1 Condition: Avoid major source under 40 CFR (b)(1)(i) and Minn. R ; Avoid major source under 40 CFR 70.2 and Minn. R ; Minn. R , subp. 4, 5, and 14 Minn. R , subps. 4-5; Minn. R , subp. 14 Minn. R , subps. 4-5; Minn. R , subp. 14 Minn. R , subp. 4

11 TABLE A: LIMITS AND OTHER REQUIREMENTS Facility Name: Ardent Mills Flour Mill Permit Number: A-7 09/21/15 Subject Item: Associated Items: GP and 2.5 Limits SV011 Milling Exhaust SV012 Milling Exhaust SV015 Milling Exhaust What to do < 10 micron: less than or equal to lbs/hour using 3-hour Average. This is a group limit. The sum of the hourly emissions from SV 011, SV 012, and SV 015 shall not exceed pounds per hour. If this limit cannot be met, the Permittee must apply for a Par t 70 permit. < 2.5 micron: less than or equal to lbs/hour using 3-hour Average. This is a group limit. The sum of the hourly emissions from SV 011, SV 012, and SV 015 shall not exceed pounds per hour. If this limit cannot be met, the Permittee must apply for a Par t 70 permit. Initial Performance Test: due 180 days after Permit Issuance to measure 10 emissions from SV 011, SV 012, and SV 015. The performance tests shall be conducted at worst case conditions as defined at Minn. R , subp. 8, using EPA Reference Method 5, or other method approved by MPCA in the performance test plan approval. It is assumed that 2.5 emissions do not exceed 10 emissions, therefore a single test for 10 will constitute a test for 2.5. Why to do it Title I Condition: Avoid major source under 40 CFR (b)(1)(i) and Minn. R ; Avoid major source under 40 CFR 70.2 and Minn. R Title I Condition: Avoid major source under 40 CFR (b)(1)(i) and Minn. R ; Avoid major source under 40 CFR 70.2 and Minn. R Minn. R , subp. 1

12 TABLE A: LIMITS AND OTHER REQUIREMENTS Facility Name: Ardent Mills Flour Mill Permit Number: A-8 09/21/15 Subject Item: Associated Items: EU 001 Boiler SV 023 Boiler Exhaust What to do OPERATING AND RECORDKEEPING REQUIREMENTS Minn. R Why to do it Fuel Use: Limited to natural gas and distillate oil only Minn. R , subp. 2 Sulfur Content of Fuel: less than or equal to 0.5 percent by weight, based on certification from fuel supplier. Recordkeeping: For each shipment of f uel oil, the Permittee shall obtain and maintain a copy of the fuel supplier's certific ation, which shall include the name of the oil supplier, and a statement from the o il supplier that the oil complies with the specifications under the definition of distillate oil in 40 CFR Section c. Monthly Recordkeeping: Record and maintain records of the amounts of each fuel combusted on a monthly basis. These recor ds may consist of purchase records or receipts. 40 CFR Section 60.42c(d); 40 CFR Section 60.42c(h)(1); Minn. R CFR Section 60.48c(f)(1); Minn. R CFR Section 60.13(i) and February 20, 1992, February 22, 1993, and June 25, 2002 EPA memoranda to meet the requirements of 40 CFR Section 60.48c(g) and (i); Minn. R

13 TABLE A: LIMITS AND OTHER REQUIREMENTS Facility Name: Ardent Mills Flour Mill Permit Number: A-9 09/21/15 Subject Item: Associated items: EU 002 Grain Receiving - Loading-Unloading Equipment CE 001 Fabric Filter - Low Temperature, i.e., T<180 Degrees F SV 001 Receiving Exhaust What to do EMISSION LIMITS AND OPERATING REQUIREMENTS Minn. R Opacity: less than or equal to 10 percent opacity from SV 001. Opacity: less than or equal to 5 percent opacity a discharge of fugitive emissions from a truck unloading station, railcar unloading station, or handling operation. Process Throughput: less than or equal to 523,000 tons/year using 12-month Rolling Sum of grain received. EU002 consists of the components listed in Appendix II to this permit. Any replacement, addition, or modification to the components listed in Appendix II is considered a modification of EU002 for purposes of determining if a permit amendment is required. CONTROL EQUIENT REQUIREMENTS (CE001 - See GP001 for additional requirements) The Permittee shall route all emissions from components of "EU 002" to control equipment meeting the requirements of GP001 and EU002. The Permittee shall operate and maintain the fabric filter (at the time of permit issuance, CE001) at all times that any process equipment controlled by the fabric filter is operating. The Permittee shall document periods of non-operation of the control equipment. Total Particulate Matter: greater than or equal to 79.2 percent control efficiency (capture efficiency x collection efficiency). Any new, replaced, or modified control equipment is also subject to this limit. Total Particulate Matter: greater than or equal to 80 percent collection efficiency. Any new, replaced, or modified control equipment is also subject to this limit. < 10 micron: greater than or equal to 74.4 percent control efficiency (capture efficiency x collection efficiency). Any new, replaced, or modified control equipment is also subject to this limit. < 2.5 micron: greater than or equal to 74.4 percent control efficiency (capture efficiency x collection efficiency). Any new, replaced, or modified control equipment is also subject to this limit. Why to do it Minn. R , subp. 3(D) Minn. R , subp. 3(A) Title I Condition: Avoid major source under 40 CFR (b)(1)(i) and Minn. R ; Avoid major source under 40 CFR 70.2 and Minn. R Minn. R , subp. 5 Minn. R Title I Condition: Avoid major source under 40 CFR (b)(1 )(i) and Minn. R ; Avoid major source under 40 CFR 70.2 and Minn. R Title I Condition: Avoid major source under 40 CFR (b)(1)(i) and Minn. R ; Avoid major source under 40 CFR 70.2 and Minn. R Title I Condition: Avoid major source under 40 CFR (b)(1)(i) and Minn. R Minn. R , subp. 3(E) MONITORING AND RECORDKEEPING REQUIREMENTS Minn. R Labeling Requirement: The Permittee shall permanently affix the emission unit number (EU002) and another unique number to each piece of equipment designated as part of "Grain Receiving," for tracking purposes. Labeling must be completed within 120 days of permit issuance and within 30 days of startup of any new piece of equipment. The number can be affixed by placard, stencil, or other means, provided it is maintained and readable from a safe distance. If equipment is added, it shall be given a new number; numbers from replaced or removed equipment shall not be reused. Equipment List: The Permittee shall maintain a list of each piece of equipment designated under the "Grain Receiving" category. The list shall include: - the type of equipment - the emission unit number (EU002) and another unique identifier - the date of installation and/or modification Title I Condition: Avoid major source under 40 CFR (b)(1 )(i) and Minn. R ; Avoid major source under 40 CFR 70.2 and Minn. R Title I Condition: Avoid major source under 40 CFR (b)(1)(i) and Minn. R ; Avoid major source under 40 CFR 70.2 and Minn. R Minn. R , subp. 2 Minn. R , subps. 4-5 If equipment is added or modified after permit issuance, the Equipment List shall also note that the following evaluations were made prior to the change: - the change does not trigger any applicable requirements that are not already listed in this permit - the change does not cause violation of any limits in this permit - the change did not require a permit amendment Daily Recordkeeping: Grain Receiving Each operating day, the Permittee shall record the quantity (weight) of grain received at the facility on the previous day. Title I Condition: Avoid major source under 40 CFR (b)(1)(i) and Minn. R ; Avoid major source under 40 CFR 70.2 and Minn. R

14 TABLE A: LIMITS AND OTHER REQUIREMENTS A-10 09/21/15 Facility Name: Ardent Mills Flour Mill Permit Number: Monthly Recordkeeping: Grain Receiving Minn. R , subps. 4-5 By the 15th day of each month, calculate and record the quantity (weight) of grain received during the previous month, and during the previous 12 months (12-month rolling sum). TESTING REQUIREMENTS Minn. R Performance Test: due before end of each calendar 60 months starting 05/01/2012 to measure opacity from fugitive emissions from truck unloading and rail unloading. The performance test shall be conducted at worst cast conditions as defined at Minn. R , subp. 8, using EP A Method 9 or other method approved by MPCA in the performance test plan ap proval. Testing conducted during the two months prior to the performance test due date satisfies the performance test due date, and will not reset the test due date for future testing as required by: 1) this permit, 2) by the most recently approved Performance Test Frequency Plan, or 3) if specified within a Notice of Compliance letter. Testing conducted more than two months prior to the performance test due date does not satisfy this test due date requirement and will be considered an additional test. Minn. R , subp. 1

15 TABLE A: LIMITS AND OTHER REQUIREMENTS Facility Name: Ardent Mills Flour Mill Permit Number: A-11 09/21/15 Subject Item: Associated Items: EU 003 Grain Cleaning - Cleaning Equipment CE 003 Fabric Filter - Low Temperature, i.e. T<180 Degrees F CE 004 Fabric Filter - Low Temperature, i.e. T<180 Degrees F CE 005 Fabric Filter - Low Temperature, i.e. T<180 Degrees F CE 006 Fabric Filter - Low Temperature, i.e. T<180 Degrees F CE 007 Fabric Filter - Low Temperature, i.e. T<180 Degrees F CE 008 Fabric Filter - Low Temperature, i.e. T<180 Degrees F CE 009 Fabric Filter - Low Temperature, i.e. T<180 Degrees F CE 010 Fabric Filter - Low Temperature, i.e. T<180 Degrees F CE 035 Fabric Filter - Low Temperature, i.e. T<180 Degrees F SV 003 Cleaning Exhaust SV 004 Cleaning Exhaust SV 005 Cleaning Exhaust SV 006 Cleaning Exhaust SV 007 Cleaning Exhaust SV 008 Cleaning Exhaust SV 009 Cleaning Exhaust SV 010 Cleaning Exhaust SV 013 Cleaning Exhaust What to do EMISSION LIMITS AND OPERATING REQUIREMENTS Minn. R Opacity: less than or equal to 10 percent opacity from each stack Opacity: less than or equal to 5 percent opacity from fugitive emissions. EU003 consists of the components listed in Appendix II to this permit. Any replacement, addition, or modification to the components listed in Appendix II is considered a modification of EU003 for purposes of determining if a permit amendment is required. CONTROL EQUIENT REQUIREMENTS (at the time of permit issuance: CE003 - CE010, CE035; See GP001 for addit ional requirements) The Permittee shall route all emissions from components of "EU 003" to control equipment meeting the requirements of GP001 and EU003. The Permittee shall operate and maintain each fabric filter at all times that any process equipment controlled by the fabric filter is operating. The Permittee shall document periods of non-operation of the control equipment. Total Particulate Matter: greater than or equal to 99 percent control efficiency (capture efficiency x collection efficiency). Any new, replaced, or modified control equipment is also subject to this limit. Total Particulate Matter: greater than or equal to 80 percent collection efficiency. Any new, replaced, or modified control equipment is also subject to this limit. < 10 micron: greater than or equal to 93 percent control efficiency (capture efficiency x collectio n efficiency). Any new, replaced, or modified control equipment is also subject to this limit. < 2.5 micron: greater than or equal to 93 percent control efficiency (capture efficiency x collecti on efficiency). Any new, replaced, or modified control equipment is also subject to this limit. Why to do it Minn. R , subp. 3(D) Minn. R , subp. 3(A) Minn. R , subp. 5 Minn. R Title I Condition: Avoid major source under 40 CFR (b)(1)(i) and Minn. R ; Avoid major source under 40 CFR 70.2 and Minn. R Title I Condition: Avoid major source under 40 CFR (b)(1)(i) and Minn. R ; Avoid major source under 40 CFR 70.2 and Minn. R Title I Condition: Avoid major source under 40 CFR (b)(1 )(i) and Minn. R Minn. R , subp. 3(E) MONITORING AND RECORDKEEPING REQUIREMENTS Minn. R Title I Condition: Avoid major source under 40 CFR (b)(1)(i) and Minn. R ; A void major source under 40 CFR 70.2 and Minn. R Title I Condition: Avoid major source under 40 CFR (b)(1)(i) and Minn. R ; Avoid major source under 40 CFR 70.2 and Minn. R

16 TABLE A: LIMITS AND OTHER REQUIREMENTS A-12 09/21/15 Facility Name: Ardent Mills Flour Mill Permit Number: Labeling Requirement: The Permittee shall permanently affix the emission unit number (EU003) and another unique number to each piece of equipment designated as part of "Grain Cleaning," for tracking purposes. Labeling must be completed within 120 days of permit issuance and within 30 days of startup of any new piece of equipment. The number can be affixed by placard, stencil, or other means, provided it is maintained and readable from a safe distance. If equipment is added, it shall be given a new number ; numbers from replaced or removed equipment shall not be reused. Equipment List: The Permittee shall maintain a list of each piece of equipment designated under the "Grain Cleaning" category. The list shall include: - the type of equipment - the emission unit number (EU003) and another unique identifier - the date of installation and/or modification Minn. R , subp. 2 Minn. R , subps. 4-5 If equipment is added or modified after permit issuance, the Equipment List shall also note that the following evaluations were made prior to the change: - the change does not trigger any applicable requirements that are not already listed in this permit - the change does not cause violation of any limits in this permit - the change did not require a permit amendment

17 TABLE A: LIMITS AND OTHER REQUIREMENTS Facility Name: Ardent Mills Flour Mill Permit Number: A-13 09/21/15 Subject Item: Associated Items: EU 004 Milling - Milling Equipment CE 011 Fabric Filter - Low Temperature, i.e., T<180 Degrees F CE 012 Fabric Filter - Low Temperature, i.e. T<180 Degrees F CE 014 Fabric Filter - Low Temperature, i.e. T<180 Degrees F CE 015 Fabric Filter - Low Temperature, i.e. T<180 Degrees F CE 016 Fabric Filter - Low Temperature, i.e. T<180 Degrees F CE 017 Fabric Filter - Low Temperature, i.e. T<180 Degrees F CE 018 Fabric Filter - Low Temperature, i.e. T<180 Degrees F CE 019 Fabric Filter - Low Temperature, i.e. T<180 Degrees F CE 020 Fabric Filter - Low Temperature, i.e. T<180 Degrees F CE 021 Fabric Filter - Low Temperature, i.e. T<180 Degrees F CE 022 Fabric Filter - Low Temperature, i.e. T<180 Degrees F CE 023 Fabric Filter - Low Temperature, i.e. T<180 Degrees F CE 024 Fabric Filter - Low Temperature, i.e. T<180 Degrees F CE 037 Fabric Filter - Low Temperature, i.e. T<180 Degrees F CE 038 Fabric Filter - Low Temperature, i.e. T<180 Degrees F CE 039 Fabric Filter - Low Temperature, i.e. T<180 Degrees F CE 040 Fabric Filter - Low Temperature, i.e. T<180 Degrees F SV 011 Milling Exhaust SV 012 Milling Exhaust SV 015 Milling Exhaust What to do EMISSION LIMITS AND OPERATING REQUIREMENTS Minn. R Opacity: less than or equal to 10 percent opacity from each stack EU004 consists of the components listed in Appendix II to this permit. Any replacement, addition, or modification to the components listed in Appendix II is considered a modification of EU004 for purposes of determining if a permit amendment is required. CONTROL EQUIENT REQUIREMENTS (at the time of perm it issuance: CE011, CE012, CE014 - CE024, CE037 - CE040; See GP001 for additional requirements) The Permittee shall route all emissions from components of "EU 004" to control equipment meeting the requirements of GP001 and EU004. The Permittee shall operate and maintain each fabric filter at all times that any process equipment controlled by the fabric filter is operating. The Permittee shall document periods of non-operation of the control equipment. Total Particulate Matter: greater than or equal to 99 percent control efficiency (capture efficiency x collection efficiency). Any new, replaced, or modified control equipment is also subject to this limit. Total Particulate Matter: greater than or equal to 80 percent collection efficiency. Any new, replaced, or modified control equipment is also subject to this lim it. < 10 micron: greater than or equal to percent control efficiency (capture efficiency x collection efficiency). Any new, replaced, or modified control equipment is also subject to this limit. < 2.5 micron: greater than or equal to percent control efficiency (capture efficiency x co llection efficiency). Any new, replaced, or modified control equipment is also subject to this limit. Why to do it Minn. R , subp. 3(D) Minn. R , subp. 5 Minn. R Title I Condition: Avoid major source under 40 CFR (b)(1)(i) and Minn. R ; Avoid major source under 40 CFR 70.2 and Minn. R Title I Condition: Avoid major source under 40 CFR (b)(1 )(i) and Minn. R ; Avoid major source under 40 CFR 70.2 and Minn. R Title I Condition: Avoid major source under 40 CFR 52.21<b)<1)(i) and Minn. R Minn. R , subp. 3(E) MONITORING AND RECORDKEEPING REQUIREMENTS Minn. R Title I Condition: Avoid major source under 40 CFR (b)(1 )(i) and Minn. R ; Avoid major source under 40 CFR 70.2 and Minn. R Title I Condition: Avoid major source under 40 CFR (b)(1)(i) and Minn. R ; Avoid major source under 40 CFR 70.2 and Minn. R

18 TABLE A: LIMITS AND OTHER REQUIREMENTS A-14 09/21/15 Facility Name: Ardent Mills Flour Mill Permit Number: Labeling Requirement: The Permittee shall permanently affix the emission unit number (EU004) and another unique number to each piece of equipment designated as part of "Milling," for tracking purposes. Labeling must be completed within 120 days of permit issuance and within 30 days of startup of any new piece of equipment. The number can be affixed by placard, stencil, or other means, provided it is maintained and readable from a safe distance. If equipment is added, it shall be given a new number; numbers from replaced or ' removed equipment shall not be reused. Equipment List: The Permittee shall maintain a list of each piece of equipment designated under the "Milling" category. The list shall include: - the type of equipment - the emission unit number (EU004) and another unique identifier - the date of installation and/or modification If equipment is added or modified after permit issuance, the Equipment List shall also note that the following evaluations were made prior to the chang e: - the change does not trigger any applicable requirements that are not already listed in this permit - the change does not cause violation of any limits in this permit - the change did not require a permit amendment, Minn. R , subp. 2 Minn. R , subps. 4-5

19 TABLE A: LIMITS AND OTHER REQUIREMENTS Facility Name: Ardent Mills Flour Mill Permit Number: A-15 09/21/15 Subject Item: Associated Items: EU 005 Feed Loadout - Loading-Unloading Equipment CE 030 Fabric Filter - Low Temperature, i.e., T<180 Degrees F GP 004 Loadout SV016 Feed Loadout What to do EMISSION LIMITS AND OPERATING REQUIREMENTS Minn. R Opacity: less than or equal to 5 percent opacity from fugitive emissions from railcar loading. Opacity: less than or equal to 10 percent opacity from fugitive emissions from truck loading. Opacity: less than or equal to 10 percent opacity from the stack EU005 consists of the components listed in Appendix II to this permit. Any replacement, addition, or modification to the components listed in Appendix II is considered a modification of EU005 for purposes of determining if a permit amendment is required. Why to do it Minn. R , subp. 3(A) Minn. R , subp. 3(B) Minn. R , subp. 3(D) Minn. R , subp. 5 CONTROL EQUIENT REQUIREMENTS (See requirements under CE030) Minn. R The Permittee shall route all emissions from components of "EU 005" to control equipment meeting the requirements of CE030 and EU005. The Permittee shall operate and maintain the fabric filter at all times that any process equipment controlled by the fabric filter is operating. The Permittee shall document periods of non-operation of the control equipment. Minn. R (G) Minn. R (G) TESTING REQUIREMENTS Minn. R Performance Test: due before end of each calendar 60 months starting 05/01/2012 to measure opacity from fugitive emissions from truck loading and rail loading. The performance tst shall be conducted at worst cast conditions as defined at Minn. R , subp. 8, using EPA Method 9 or other method approved by MPCA in the performance test plan approval. Testing conducted during the two months prior to the performance test due date satisfies the performance test due date, and will not reset the test due date for future testing as required by: 1) this permit, 2) by the most recently approved Performance Test Frequency Plan, or 3) if specified within a Notice of Compliance letter. Testing conducted more than two months prior to the performance test due date does not satisfy this test due date requirement and will be considered an additional test. Minn. R , subp. 1 MONITORING AND RECORDKEEPING REQUIREMENTS Minn. R Labeling Requirement: The Permittee shall permanently affix the emission unit number (EU005) and another unique number to each piece of equipment designated as part of "Feed Loadout," for tracking purposes. Labeling must be completed within 120 days of permit issuance and within 30 days of startup of any new piece of equipment. The number can be affixed by placard, stencil, or other means, provided it is maintained and readable from a safe distance. If equipment is added, it shall be given a new number; numbers from replaced or removed equipment shall not be reused. Equipment List: The Permittee shall maintain a list of each piece of equipment designated under the "Feed Loadout" category. The list shall include: - the type of equipment - the emission unit number (EU005) and another unique identifier - the date of installation and/or modification If equipment is added or modified after permit issuance, the Equipment List shall also note that the following evaluations were made prior to the change: - the change does not trigger any applicable requirements that are not already listed in this permit - the change does not cause violation of any limits in this permit - the change did not require a permit amendment Minn.R , subp. 2 Minn. R , subps. 4-5

20 TABLE A: LIMITS AND OTHER REQUIREMENTS Facility Name: Ardent Mills Flour Mill Permit Number: A-16 09/21/15 Subject Item: Associated Items: EU 006 Grain Handling - Material Handling Equipment CE 002 Fabric Filter - Low Temperature, i.e., T<180 Degrees F SV 002 Grain Handling Exhaust What to do EMISSION LIMITS AND OPERATING REQUIREMENTS Minn. R Opacity: less than or equal to 10 percent opac ity from the stack Opacity: less than or equal to 5 percent opacity from fug itive emissions. EU006 consists of the compon ents listed in Appendix II to this permit. Any replacement, addition, or modification to the components listed in Appendix II is considered a modification of EU006 for purposes of determining if a permit amendment is required. CONTROL EQUIENT REQUIREMENTS (a time of permit issuance: CE002; See GP001 for additional requirements) The Permittee shall route all emissions from components of "EU 006" to control equipment meeting the requirements of GP001 and EU006. The Permittee shall operate and maintain the fabric filter at all times that any process equipment controlled by the fabric filter is operating. The Permittee shall document periods of non-operation of the contr ol equipment. Total Particulate Matter: greater than or equal to 99 percent control efficiency (capture efficiency x collection ef ficiency). Any new, replaced, or modified control equipment is also subject to this limit. Total Particulate Matter: greater than or equal to 80 percent collection efficiency. Any new, replaced, or modified control equipment is also subject to this limit. < 10 micron: greater than or equal to 93 percent control efficiency (capture efficiency x collec tion efficiency). Any new, replaced, or modified control equipment is also subject to this limit. < 2.5 micron: greater than or equal to 93 percent control efficiency (capture efficiency x collection efficiency). Any new, replaced, or modified control equipment is also subject to this limit. Why to do it Minn. R , subp. 3(D) Minn. R , subp. 3(A) Minn. R , subp. 5 Minn. R MONITORING AND RECORDKEEPING REQUIREMENTS Minn. R Labeling Requirement: The Permittee shall permanently affix the emission unit number (EU006) and another unique number to each piece of equip ment designated as part of "Grain Handling," for trac king purposes. Labeling must be completed within 120 days of permit issuance and within 30 days of startup of any new piece of equipment. The number can be affixed by placard, stencil, or other means, provided it is maintained and readable from a safe distance. If equipment is added, it shall be given a new number; numbers from replaced or removed equipment shall not be reused. Equipment List: The Permittee shall maintain a list of each piece of equipment designated under the "Grain Handling" category. The list shall include: - the type of equipment - the emission unit number (EU006) and another unique identifier - the date of installation and/or modification If equipment is added or modified after permit issuan ce, the Equipment List shall also note that the following evaluations were made prior to the change: - the change does not trigger any applicable requirements that are not already listed in this permit - the change does not cause violation of any limi ts in this permit - the change did not require a permit amendment Title I Condition: Avoid major source under 40 CFR (b)(1)(i) and Minn. R ; Avoid major source under 40 CFR 70.2 and Minn. R Title I Condition: Avoid major source under 40 CFR (b)(1)(i) and Minn. R ; Avoid majo r source under 40 CFR 70.2 and Minn. R Title I Condition: Avoid major source under 40 CFR (b)(1)(i) and Minn. R Minn. R , subp. 3(E). Title I Condition: Avoid major source under 40 CFR (b)(1)(i) and Minn. R ; Avoid major source under 40 CFR 70.2 and Minn. R Title I Condition: Avoid major source under 40 CFR (b)(1)(i) and Minn. R ; Avoid major source under 40 CFR 70.2 and Minn. R Minn. R , subp. 2 Minn. R , subps. 4-5

21 TABLE A: LIMITS AND OTHER REQUIREMENTS Facility Name: Ardent Mills Flour Mill Permit Number: A-17 09/21/15 Subject Item: Associated Items: EU 007 Flour Storage and Loading - Loading-Unloading Equipment CE 026 Fabric Filter - Low Temperature, i.e., T<180 Degrees F CE 027 Fabric Filter - Low Temperature, i.e., T<180 Degrees F CE 028 Fabric Filter - Low Temperature, i.e., T<180 Degrees F CE 029 Fabric Filter - Low Temperature, i.e., T<180 Degrees F CE 033 Fabric Filter - Low Temperature, i.e., T<180 Degrees F CE 034 Fabric Filter - Low Temperature, i.e., T<180 Degrees F CE 036 Fabric Filter - Low Temperature, i.e., T<180 Degrees F GP 004 Loadout SV 017 Storage/Loadout Exhaust SV 018 Storage/Loadout Exhaust SV019 Storage/Loadout Exhaust SV 020 Storage/Loadout Exhaust SV 021 Storage/Loadout Exhaust SV 022 Storage/Loadout Exhaust SV 024 Storage/Loadout Exhaust What to do EMISSION LIMITS AND OPERATING REQUIREMENTS Minn. R Opacity: less than or equal to 5 percent opacity from fugitive emissions from railcar loading. Opacity: less than or equal to 10 percent opacity from fugitive emissions from truck loading. Opacity: less than or equal to 10 percent opacity from each stack EU007 consists of the components listed in Appendix II to this permit. Any replacement, addition, or modification to the components listed in Appendix II is considered a modification of EU007 for purposes of determining if a permit amendment is required. CONTROL EQUIENT REQUIREMENTS (at time of permit issuance: CE026 - CE029, CE033, CE034, CE036; See GP001 for additional requirements) The Permittee shall route all emissions from components of "EU 007" to control equipment meeting the requirements of GP001 and EU007. The Permittee shall operate and maintain each fabric filter at all times that any process equipment controlled by the fabric filter is operating. The Permittee shall document periods of non-operation of the control equipment. Total Particulate Matter: greater than or equal to 99 percent control efficiency (capture efficiency x collection eff iciency). Any new, replaced, or modified control equipment is also subject to this limit. Total Particulate Matter: greater than or equal to 80 percent collection efficiency. Any new, replaced, or modified control equipment is also subject to this limit. < 10 micron: greater than or equal to 93 percent control efficiency (capture efficiency x collection efficiency). Any new, replaced, or modified control equipment is also subject to this limit. < 2.5 micron: greater than or equal to 93 percent control efficiency (capture efficiency x colle ction efficiency). Any new, replaced, or modified control equipment is also subject to this limit. Why to do it Minn. R , subp. 3(A) Minn. R , subp. 3(B) Minn. R , subp. 3(D) Minn. R , subp. 5 Minn. R Title I Condition: Avoid major source under 40 CFR (b)(1 )(i) and Minn. R ; A void major source under 40 CFR 70.2 and Minn. R Title I Condition: Avoid major source under 40 CFR (b)(1)(i) and Minn. R ; Avoid major source under 40 CFR 70.2 and Minn. R Title I Condition: Avoid major source under 40 CFR (b)(1 )(i) and Minn. R Minn. R , subp. 3(E) MONITORING AND RECORDKEEPING REQUIREMENTS Minn. R Title I Condition: Avoid major source under 40 CFR (b)(1)(i) and Minn. R ; A void major source under 40 CFR 70.2 and Minn. R Title I Condition: Avoid major source under 40 CFR (b)(1)(i) and Minn. R ; Avoid major source under 40 CFR 70.2 and Minn. R

22 TABLE A: LIMITS AND OTHER REQUIREMENTS A-18 09/21/15 Facility Name: Ardent Mills Flour Mill Permit Number: Labeling Requirement: The Permittee shall permanently affix the emission unit number (EU007) and another unique number to each piece of equipment designated as part of "Flour Storage and Loading," for tracking purposes. Labeling must be completed within 120 days of permit issuance and within 30 days of startup of any new piece of equipment. The number can be affixed by placard, stencil, or other means, provided it is maintained and readable from a safe distance. If equipment is added, it shall be given a new number; numbers from replaced or removed equipment shall not be reused. Equipment List: The Permittee shall maintain a list of each piece of equipment designated under the "Flour Storage and Loading" category. The list shall include: - the type of equipment - the emission unit number (EU007) and another unique identifier - the date of installation and/or modification Minn. R , subp. 2 Minn. R , subps. 4-5 If equipment is added or modified after permit issuance, the Equipment List shall also note that the following evaluations were made prior to the change: - the change does not trigger any applicable requirements that are not already listed in this permit - the change does not cause violation of any limits in this permit - the change did not require a permit amendment

23 TABLE A: LIMITS AND OTHER REQUIREMENTS Facility Name: Ardent Mills Flour Mill Permit Number: A-19 09/21/15 Subject Item: Associated Items: EU 008 Pellet Cooling - Cooler CE 031 Centrifugal Collector - Medium Efficiency CE 032 Centrifugal Collector - Medium Efficiency SV014 Pellet Cooling Exhaust What to do EMISSION LIMITS AND OPERATING REQUIREMENTS Minn. R Total Particulate Matter: less than or equal to 0.3 grains/dry standard cubic foot of exhaust gas unless required to further reduce emissions to comply with the less stringent limit of either Minn. R or Minn. R Opacity: less than or equal to 20 percent opacity from SV 014. Process Throughput: less than or equal to tons/year using 12-month Rolling Sum of pellets cooled. EU008 consists of the components listed in Appendix II to this permit. Any replacement, addition, or modification to the components listed in Appendix II is considered a modification of EU008 for purposes of determining if a permit amendment is required. CONTROL EQUIENT REQUIREMENTS (at time of permit issuance: CE031 & CE032; See GP002 for additional requirements) The Permittee shall route all emissions from components of "EU 008" to control equipment meeting the requirements of GP002 and EU008. The Permittee shall operate and maintain each cyclone at all times that any process equipment controlled by the device is operating. The Permittee shall document periods of non-operation of the control equipment. Total Particulate Matter: greater than or equal to 96 percent control efficiency (capture efficiency x collection efficiency, for 2 centrifugal collectors in series). Any new, replaced, or modified control equipment is also subject to this limit. < 10 micron: greater than or equal to 64 percent control efficiency (capture efficiency x co llection efficiency, for 2 centrifugal collectors in series). Any new, replaced, or modified control equipment is also subject to this limit. < 2.5 micron: greater than or equal to 64 percent control efficiency (capture efficiency x co llection efficiency, for 2 centrifugal collectors in series). Any new, replaced, or modified control equipment is also subject to this limit. Why to do it Minn. R , subp. 1(A) Minn. R , subp. 1(B) Title I Condition: Avoid major source under 40 CFR (b)(1)(i) and Minn. R ; Avoid major source under 40 CFR 70.2 and Minn. R Minn. R , subp. 5 Minn. R MONITORING AND RECORDKEEPING REQUIREMENTS Minn. R Labeling Requirement: The Permittee shall permanently affix the emission unit number (EU008) and another unique number to each piece of equipment designated as part of "Pellet Cooling," for tracking purposes. Labeling must be completed within 120 days of permit issuance. The number can be affixed by placard, stencil, or other means, provided it is maintained and readable from a safe distance. If equipment is added, it shall be given a new number; numbers from replaced or removed equipment shall not be reused. Equipment List: The Permittee shall maintain a list of each piece of equipment designated under the "Pellet Cooling" category. The list shall include: - the type of equipment - the emission unit number (EU008) and another unique identifier - the date of installation and/or modification Title I Condition: Avoid major source under 40 CFR (b)(1)(i) and Minn. R ; Avoid major source under 40 CFR 70.2 and Minn. R Title I Condition: Avoid major source under 40 CFR (b)(1 )(i) and Minn. R ; Avoid major source under 40 CFR 70.2 and Minn. R Title I Condition: Avoid major source under 40 CFR (b)(1)(i) and Minn. R Title I Condition: Avoid major source under 40 CFR (b)(1)(i) and Minn. R ; Avoid major source under 40 CFR 70.2 and Minn. R Title I Condition: Avoid major source under 40 CFR (b)(1)(i) and Minn. R ; Avoid major source under 40 CFR 70.2 and Minn. R Minn. R , subp. 2 Minn. R , subps. 4-5 If equipment is added or modified after permit issuance, the Equipment List shall also note that the following evaluations were made prior to the change: - the change does not trigger any applicable requirements that are not already listed in this permit - the change does not cause violation of any limits in this permit - the change did not require a permit amendment Daily Recordkeeping: Pellet Cooling Throughput Each operating day, the Permittee shall record the quantity (weight) of pellets cooled at the facility on the previous day. Title I Condition: Avoid major source under 40 CFR (b)(1)(i) and Minn. R ; A void major source under 40 CFR 70.2 and Minn. R

24 TABLE A: LIMITS AND OTHER REQUIREMENTS A-20 09/21/15 Facility Name: Ardent Mills Flour Mill Permit Number: Monthly Recordkeeping: Pellet Cooling Throughput Minn. R , subps. 4-5 By the 15th day of each month, calculate and record the quantity (weight) of pellets cooled during the previous month, and during the previous 12 month s (12-month rolling sum).

25 TABLE A: LIMITS AND OTHER REQUIREMENTS A-21 09/21/15 Facility Name: Ardent Mills Flour Mill Permit Number: Subject Item: Associated Items: EU 009 Emergency Generator SV 025 Emergency Generator What to do EMISSION LIMITS Minn. R Opacity: less than or equal to 20 percent opacity once operating temperatures have been attained. Sulfur Dioxide: less than 0.50 lbs/million Btu heat input. The potential to emit from the unit is 0.29 lbs/million Btu heat input due to equipment design and allowable fuels. Why to do it Minn. R , subp. 1 Minn. R , subp. 2 OPERATING CONDITIONS Minn. R No. 2 fuel oil/diesel fuel meeting the requirements of 40 CFR Section (c) only by design. Operating Hours: less than or equal to 500 hours/year using 12-month Rolling Sum to be calculated by the 15th day of each month. Minn. R , subp. 35a RECORDKEEPING REQUIREMENTS Minn. R Hours of Operation: The Permittee shall maintain documentation on site that the unit is an emergency generator by design that qualifies under the U.S. EPA memorandum entitled "Calculating Potential to Emit (PTE) for Emergency Generators" dated September 6,1995, limiting operation to 500 hours per year. Title I Condition: Avoid major source under 40 CFR (b)(1 )(i) and Minn. R ; Avoid major source under 40 CFR 70.2 and Minn. R Title I Condition: Avoid major source under 40 CFR (b)(1 )(i) and Minn. R ; Avoid major source under 40 CFR 70.2 and Minn. R ; Minn. R , subps. 4-5 The Permittee shall keep records of fuel type and usage on a monthly basis. Minn. R , subp. 5 NESHAP SUBPART 7777 REQUIREMENTS - Enforcement Not Delegated to MPCA Change oil and filter every 500 hours of operation or annually, whichever comes first. The Permittee has the option of utilizing an oil analysis program in order to extend the oil change requirement as described below. Inspect air cleaner every 1,000 hours of operation or annually, whichever comes first, and replace as necessary. Inspect all hoses and belts every 500 hours of operation or annually, whichever comes first, and replace as necessary. By January 1, 2015 the Permittee shall only use diesel fuel that meets the requirements in 40 CFR Section (b) for nonroad diesel fuel, except that any existing diesel fuel purchased or otherwise obtained prior to January 1, 2015 may be used until depleted. At all times the Permittee shall operate and maintain any affected source, including associated air pollution control equipment and monitoring equipment, in a manner consistent with safety and good air pollution control practices for minimizing emissions. The general duty to minimize emissions does not require the Permittee to make any further efforts to reduce emissions if levels required by this standard have been achieved. Determination of whether such operation and maintenance procedures are being used will be based on information available to the Administrator which may include, but is not limited to, monitoring results, review of operation and maintenance procedures, review of operation and maintenance records, and inspection of the source. The Permittee shall operate and maintain the stationary RICE and after-treatment control device (if any) according to the manufacturer's emission-related written instructions or develop a maintenance plan which shall provide to the extent practicable for the maintenance and operation of the engine in a manner consistent with good air pollution control practice for minimizing emissions. The Permittee shall minimize the engine's time spent at idle during startup and minimize the engine's startup time to a period needed for appropriate and safe loading of the engine, not to exceed 30 minutes, after which time the emission standards applicable to all times other than startup apply. Minn. R CFR Section (a); 40 CFR Section ; and Table 2d to subpart ZZZZ of Part 63; Minn. R CFR Section (a); 40 CFR Section ; and Table 2d to subpart ZZZZ of Part 63; Minn. R CFR Section (a); 40 CFR S ection ; and Table 2d to subpart ZZZZ of Part 63; Minn. R CFR Section (b); Minn. R CFR Section (a); Minn. R CFR Section (e); Minn. R CFR Section (h); Minn. R

26 TABLE A: LIMITS AND OTHER REQUIREMENTS A-22 09/21/15 Facility Name: Ardent Mills Flour Mill Permit Number: The Permittee has the option of utilizing an oil analysis program in order to extend the specified oil change requirement. The oil analysis shall be performed at the same frequency specified for changing the oil. The an alysis program shall at a minimum analyze the following 3 parameters: Total Base Number, viscosity, and percent water content. The condemning limits for these parameters are as follows: Total Base Number is less than 30 percent of the Total Base Number of the oil when new; viscosity of the oil has changed by more than 20 percent from the viscosity of the oil when new; or percent water conten t (by volume) is greater than 0.5. (continued below) (continued from above) 40 CFR Section (i); Minn. R CFR Section (i); Minn. R If none of the condemning limits are exceeded, the Permittee is not required to change the oil. If any of the limits are exceeded, the Permittee shall change the oil within 2 business days of receiving the results of the analysis; if the engine is not in operation when the results of the analysis are re ceived, the Permittee shall, change the oil within 2 business days or before commencing operation, whichever is later. The Permittee shall keep records of the parameters that are analyzed as part of the program, the results of the analysis, and the oil changes for the engine. The analysis program shall be part of the maintenance plan for the engine. The Permittee shall operate and maintain the stationary RICE according to the manufacturer's emission-related operation and maintenance instructions; or the Permittee shall develop and follow a maintenance plan which shall provide to the extent practicable for the maintenance and operation of the engine in a manner consistent with good air pollution control practice for minimizing emissions. The Permittee shall comply with the General Provisions in 40 CFR Section 63.1 through 63.15, as stated in 40 CFR pt. 63, subp. ZZZZ, Table 8, as applicable. REQUIREMENTS FOR EMERGENCY STATIONARY RICE Minn. R The Permittee shall install a non-resettable hour meter if one is not already installed by May 3, The Permittee shall operate the emergency stationary RICE according to the requirements in paragraphs 40 CFR Section (f)(1) through (4). Any operation other than emergency operation, maintenance and testing, emergency demand response, and operation in non-emergency situations for 50 hours per year, as described in 40 CFR Section (f)(1) through (4), is prohibited. If the engine is not operated according to the requirements in 40 CFR Section (f)(1) through (4), the engine will not be considered an emergency engine under this subpart and will need to meet all requirements for non-emergency engines. (1) There is no time limit on the use of emergency stationary RICE in emergency situations. ON MAY 1, 2015, THE D C. CIRCUIT VACATED THE PROVISIONS OF 40 CFR SECTION (f)(2) THAT ALLOW OPERATION OF AN EMERGENCY GENERATOR WITHOUT EMISSIONS CONTROLS FOR UP TO HOURS PER YEAR AS PART OF AN EMERGENCY DEMAND-RESPONSE PROGRAM. AS OF THE DATE OF ISSUANCE OF AIR EMISSION PERMIT NO , THE COURT HAD NOT ISSUED THE MANDATE IMPLEMENTING ITS DECISION. THESE PROVISIONS REMAIN IN EFFECT UNTIL THE COURT ISSUES THE MANDATE. AFTER THAT ACTION, THE PROVISIONS WILL NO LONGER BE EFFECTIVE. (2) The Permittee may operate the emergency stationary RICE for any combination of the purposes specified in 40 CFR Section (f)(2)(i) through (iii) for a maximum of hours per calendar year. Any operation for non-emergency situations as allowed by 40 CFR Section (f)(3) and (4) counts as part of the hours per calendar year allowed by this paragraph (f)(2). 40 CFR Section (a); 40 CFR pt. 63 subp. ZZZZ, Table 6 40 CFR Section and Table 8 to Sub part ZZZZ of Part 63; 40 CFR Section ; Minn. R CFR Section (f); Minn. R CFR Section (f); Minn. R CFR Section (f)(1) - (2); Minn. R (i) The Permittee may operate the emergency stationary RICE for the purpose of maintenance checks and readiness testing, provided that the tests are recommended by Federal, State or local government, the manufacturer, the vendor, the regional transmission organization or equivalent balancing authority and transmission operator, or the insurance company associated with the engine. The Permittee may petition the Administrator for app roval of additional hours to be used for maintenance checks and readiness testing, but a petition is not required if the Permittee maintains records indicating that Federal, State, or local standards require maintenance and testing of emergency RICE beyond hours per calendar year. 40 CFR Section (f)(2)(i); Minn. R

27 TABLE A: LIMITS AND OTHER REQUIREMENTS A-23 09/21/15 Facility Name: Ardent Mills Flour Mill Permit Number: (ii) Emergency stationary RICE may be operated for emergency demand response for periods in which the Reliability Coordinator under the North American Electric Reliability Corporation (NERC) Reliability Standard EOP-002-3, Capacity and Energy Emergencies (incorporated by reference, see 40 CFR Section 63.14), or other authorized entity as determined by the Reliability Coordinator, has declared an Energy Emergency Alert Level 2 as defined in the NERC Reliability Standard EOP (iii) Emergency stationary RICE may be operated for periods where there is a deviation of voltage or frequency of 5 percent or greater below standard voltage or frequency. (4) The Permittee may operate the emergency stationary RICE up to 50 hours per year in non-emergency situations, but those 50 hours are counted towards the hours per calendar year provided for maintenance and testing and emergency demand response provided in 40 CFR Section (f)(2). Except as provided in 40 CFR Section (f)(4)(i) and (ii), the 5 0 hours per year for non-emergency situations cannot be used for peak sh aving or non-emergency demand response, or to generate income for a facility to supply power to an electric grid or otherwise supply power as part of a financial arran gement with another entity. 40 CFR Section (f)(2)(ii) - (2)(iii); Minn. R CFR Section (f)(4); Minn. R (i) Prior to May 3, 2014, the 50 hours per year for non-emergency situations can be used for peak shaving or non-emergency demand response to generate income for a facility, or to otherwise supply power as part of a financial arrangement with another entity if the engine is operated as part of a peak shaving (load management program) with the local distribution system operator and the power is provided only to the facility itself or to support the local distribution system. 4(i) The 50 hours per year for nonemergency situations can be used to supply power as part of a financial arrangement with another entity if all of the following conditions are met: (A) The engine is dispatched by the local balancing authority or local transmission and distribution system operator. (B) The dispatch is intended to mitigate local transmission and/or distribution limitations so as to avert potential voltage collapse or line overloads that could lead to the interruption of power supply in a lo cal area or region. (C) The dispatch follows reliability, emergency operation or similar protocols that follow specific NERC, regional, state, public utility commission or local standards or guidelines. (D) The power is provided only to the facility itself or to support the local transmission and distribution system. (continued below) (continued from above) 40 CFR Section (f)(4)(i); Minn. R CFR Section (f)(4)(ii); Minn. R CFR Section (f)(4)(ii); Minn. R (ii) (E) The owner or operator identifies and records t he entity that dispatches the engine and the specific NERC, regional, state, public utility commission or local standards or guidelines that are being followed for dispatching the engine. The» local balancing authority or local transmission and distribution system operator may keep these records on behalf of the engine owner or operator. NESHAP RECORDKEEPING REQUIREMENTS Minn. R The Permittee shall demonstrate continuous compliance with teach emission limitation and operating limitation in Table 2d of 40 CFR pt. 63, subp. ZZZZ that apply according to methods specified in Table 6 of 40 CFR pt. 63, subp. ZZZZ. The Permittee shall keep the following records: 1. A copy of each notification and report submitted to comply with 40 CFR pt. 63, subp. ZZZZ, including all documentation supporting any Initial Notification or Notification of Compliance Status submitted according to the requirement in 40 CFR Section 63.10(b)(2)(xiv). 2. Records of the occurrence and duration of each malfunction of operation (i.e., process equipment) or the air pollution control and monitoring equipment. 3. Records of performance tests and performance evaluations as required in 40 CFR Section 63.10(b)(2)(viii). 4. Records of all required maintenance performed on the air pollution control and monitoring equipment. 5. Records of actions taken during periods of malfunction to minimize emissions in accordance with 40 CFR Section (b), including corrective actions to restore malfunctioning process and air pollution control and monitoring equipment to its normal or usual manner of operation. 40 CFR Section (a); Minn. R CFR Section (a); Minn. R

28 TABLE A: LIMITS AND OTHER REQUIREMENTS A-24 09/21/15 Facility Name: Ardent Mills Flour Mill Permit Number: The Permittee shall keep records of the maintenance conducted on the stationary RICE in order to demonstrate that the Permittee operated and maintained the stationary RICE and after-treatment control device (if any) ac cording to the maintenance plan. The Permittee shall keep records of the hours of operation of the engine that are recorded through the non-resettable hour meter. The Permittee shall document how many hours are spent for emergency operation, including what classified the operation as emergency and how many hours are spent for non-emergency operation. If the engine is used for the purposes specified in 40 CFR Section (f)(2)(ii) or (iii) or 40 CFR Section (f)(4)(ii), the Permittee shall keep records of the notification of the emergency situation, and the date, start time, and end time of engine operation for these purposes. The Permittee shall keep records in a form suitable and readily available for expeditious review according to 40 CFR Section 63.10(b)(1). 40 CFR Section (e); Minn. R CFR Section (f); Minn. R CFR Section ; 40 CFR Section 63.10( b)(1); Minn. R As specified in 40 CFR Section 63.10(b)(1), the Permittee shall keep each record for 5 years following the date of each occurrence, measurement, maintenance, corrective action, report or record. REPORTING AND NOTIFICATION REQUIREMENTS Minn. R The Permittee shall report each instance in which the stationary RICE did not meet each applicable operating limitation. These instances are deviations from the emission and operating limitations. These deviations shall be reported with the deviations report required by Table A (listed at the Total Facility level) and Table B of this permit. These deviations shall be reported according to the requirements in 40 CFR Section APPLICABLE GENERAL PROVISIONS Minn. R OPERATION AND MAINTENANCE REQUIREMENTS Minn. R Circumvention. The Permittee shall not build, erect, install, or use any article, machine, equipment, or process to conceal an emission that would otherwise constitute noncompliance with a relevant standard. Su ch concealment includes, bu< is not limited to: 1) The use of diluents to achieve compliance with a relevant standard based on the concentration of a pollutant in the effluent discharged to the atmosphere or 2) The use of gaseous diluents to achieve compliance with a relevant standard for visible emissions. Prior to construction or reconstruction of a major-emitting "affected source" under the promulgated MACT standards, the Permittee must apply for and obtain an air emission permit. The Permittee must submit notification according to 40 CFR Section 63.9(b) if the Permittee constructs or reconstructs a source such that the source becomes an affected source subject to a standard. After the effective date of any relevant standard promulgated under 40 CFR pt. 63, equipment added (or a process change) to an affected source that is within the scope of the definition of affected source under the relevant standard must be considered part of the affected source and subject to all provisions of the relevant standard established for that affected source. Proper Operation and Maintenance. At all times, including periods of startup, shutdown, and malfunction, the Permittee shall operate and maintain the emission unit subject to the MACT standard and any associated air pollution control equipment and monitoring equipment, in a manner consistent with safety and good air pollution control practices for minimizing emissions at least to the levels requirec by any relevant standard and as detailed in 40 CFR Section 63.6(e)(1)(i)-(iii). 40 CFR Section (b); Minn. R CFR Section 63.4(b); Minn. R CFR Section 63.5(b)(3); Minn. R CFR Section 63.5(b)(4); Minn. R CFR Section 63.5(b)(6); Minn. R CFR Section 63.6(e)(1)(i); Minn. R Malfunctions shall be corrected as soon as practicable after their occurrence. 40 CFR Section 63.6(e)(1)(ii); Minn. R Startup, shutdown, and malfunction plan (SSMP). The Permittee shall prepare and implement a written SSMP that describes, in detail, procedures for operating and maintaining the source during periods of startup, shutdown, and malfunction; and a program of corrective action for malfunctioning process, air pollution control, and monitoring equipment used to comply with the relevant standard. The plan requirements are further described in 40 CFR Section 63.6(e)(3)(i). When actions taken by Permittee during a startup or shutdown (and the startup or shutdown causes the source to exceed any applicable emission limitation), or malfunction (including actions taken to correct a malfunction) are consistent with the procedures specified in the affected source's SSMP, the Permittee must keep records which demonstrate that the procedures specified in the SSMP were followed and describes the actions taken for that event. 40 CFR Section 63.6(e)(3)(i); Minn. R CFR Section 63.6(e)(3)(iii); Minn. R

29 TABLE A: LIMITS AND OTHER REQUIREMENTS A-25 09/21/15 Facility Name: Ardent Mills Flour Mill Permit Number: If an action taken by the Permittee during a startup, shutdown, or malfunction (including an action taken to correct a malfunction) is not consistent with the procedures specified in the affected source's SSMP, and the source exceeds any applicable emission limitation in the relevant emission standard, then the Permittee must record the actions taken for that event and must report such actions as specified in 40 CFR Section 63.10(d)(5). The Permittee must maintain at the affected source a current SSMP and must make the plan available upon request for inspection and copying by the Administrator. In addition, if the SSMP is subsequently revised, the Permittee must maintain at the affected source each previous (i.e., superseded) version of the SSMP, and must make each such previous version available for inspection and copying for a period of 5 years after revision of the SSMP. To satisfy the requirements of this section to develop a SSMP, the Permittee may use a standard operating procedures (SOP) manual, or other plan, provided the alternative plans meet all the requirements and are made available for inspection oi submission. The Administrator may require that a Permittee make changes to the SSMP. Revisions to the SSMP will be required if the plan: 1) Does not address a startup, shutdown, or malfunction event that has occurred; 2) Fails to provide for the ope ration of the source (including associated air pollution control and monitoring equipment) during a startup, shutdown, or ma lfunction event in a manner consistent with the general duty to minimize emissions established by 40 CFR Section 63.6(e)(3)(iii)-63.6(e)(3)(ix) (e)(1)(i); 3) Does not provide adequate procedures for correcting malfunctioning process and/or air pollution control and monitoring equipment as quickly as prac ticable; or 4) Includes an event that does not meet the definition of startup, shutdown, or malfunction. The Permittee may periodically revise the SSMP as necessary to reflect changes in equipment or procedures at the affected source. Each such revision to a SSMP must be reported in the semiannual report required by 40 CFR Section 63.10(d)(5). If the SSMP fails to address or inadequately addresses an event that meets the characteristics of a malfunction but was not included in the SSMP, the Permittee shall revise the SSMP within 45 days after the event in accordance with 40 CFR Section 63.6(e)(3)(viii). Any revisions made to the SSMP shall not be deemed to constitute permit revisions under 40 CFR pt. 70 or pt. 71. Applicability. The non-opacity emission standards set forth in 40 CFR Section 63.6(f)(1 )-(3) shall apply at all times except during periods of startup, shutdown, and malfunction, and as otherwise specified in an 40 CFR pt. 63, Subpart ZZZZ. Methods for determining compliance will be, in part, based on the results of performance tests, conformance with operation and maintenance requirements, review of records, and inspection of the source as specified in 40 CFR Section 63.6(f)(2) The Permittee many use the results of performance testing conducted previously if it meets the requirements of 40 CFR Section 63.6(f)(iii). Finding of compliance. The Administrator will make a finding concerning an affected source's compliance with a non-opacity emission standard upon obtain ing all the compliance information required by the relevant standard. The Permittee may establish the use of an alternative non-opacity emi ssion standard by following the procedure specified in 40 CFR Section 63.6(g). The Administrator may grant an extension of compliance with an emission standard, as specified in 40 CFR Section 63.6(i). Until an extension of compliance has been granted by the Administrator, the Permittee shall comply with all applicable requirements of 40 CFR pt. 63, subp. A. 40 CFR Section 63.6(e)(3)(iv); Minn. R CFR Section 63.6(e)(3)(v); Minn. R (e)(3)(vi); Minn. R (e)(3)(vii) ; Minn. R PERFORMANCE TESTING REQUIREMENTS Minn. R Notification of performance test. 1) The Permittee must notify the Administrator of their intention to conduct a performance test at least 60 calendar days before the performance test is initially scheduled to begin. 2) In the event the Permittee is unable to conduct the performance test on the date specified due to unforeseeable circumstances, the Permittee must notify the Administrator as soon as practicable and without delay prior to the scheduled performance test date and specify the date when the performance test is rescheduled. 40 CFR Section 63.6(e)(3)(viii); Minn. R CFR Section 63.6(e)(3)(ix); Minn. R CFR Section 63.6(f)(1); Minn. R CFR Section 63.6(f)(2); Minn. R CFR Section 63.6(f)(3); Minn. R CFR Section 63.6(g); Minn. R CFR Section 63.6(i); Minn. R CFR Section 63.6(i)(1); Minn. R CFR Section 63.7(b); Minn. R

30 TABLE A: LIMITS AND OTHER REQUIREMENTS A-26 09/21/15 Facility Name: Ardent Mills Flour Mill Permit Number: Submission of site-specific test plan. Before conducting a required performance test, the Permittee shall develop and, if requested by the Administrator, shall submit a site-specific test plan for appro val in accordance with the requirements of 40 CFR Section 63.7(c)(2). Approval of site-specific test plan. The Admi nistrator will notify the Permittee of approval or intention to deny approval of the site-specific test plan (if review of the site-specific test plan is requested) within 30 calendar days after receipt of the original plan and within 30 calendar days after receipt of any supplementary information. Performance testing facilities. The Permittee, at the request of the Administrator, shall provide performance testing facilities as specified in 40 CFR Section 63.7(d). Conduct of performance tests. 1) Performance tests shall be conducted under based on representative of the affected source. Operations during periods of startup, shutdown, and malfunction shall not constitute representative conditions for the purpose of a performance test. 2) Performance tests shall be conducted and data shall be reduced in accordance with the test methods and procedures set forth in 40 CFR Section 63.7(e), in each relevant standard, and, if required, in applicable appendices of 40 CFR parts 51, 60, 61. The Commissioner has delegation to approve a minor or intermediate modification (if validated by Method 301) to a reference method or specified monitoring procedure as allowed for in 40 CFR Section 63.7(e)(2)(i) and (ii). Unless otherwise specified in a relevant sta ndard or test method, each performance test shall consist of three separate runs using the applicable test method. Each run shall be conducted for the time and under the conditions specified in the relevant standard. For the purpose of determining compliance w ith a relevant standard, the arithmetic mean of the results of the three runs shall apply, unless otherwise approved in accordance with provisions of 40 CFR Section 63.7(e)(3). Data analysis, recordkeeping, and reporting. Unless otherwise specified in a relevant standard or test method, or as otherwi se approved by the Administrator in writing, results of a performance test shall include the analysis of samples, determination of emissions, and raw data. A performance test is completed when field sample collection is terminated. The Permittee shall report the results of the performance test to the Administrator before the close of business on the 60th day following the completion of the performance test, unless specified otherwise in a relevant standard or as approved otherwise in writing. The results of the performance test shall be submitted as part of the notification of complian ce status required under 40 CFR Section 63.9(h) to the appropriate permitting authority. Waiver of performance tests. Until a waiver of a performance testing requirement has been granted by the Administrator under 40 CFR Section 63.7(h), the Permittee remains subject to the requirements of 40 CFR Section 63.7(h). MONITORING REQUIREMENTS Minn. R All CMS required under relevant standards shall be subject to the provisions of 40 CFR Section 63.8 upon promulgation of performance specifications for CMS as specified in the relevant standard or otherwise by the Administrator. The performance specifications in 40 CFR pt. 60, Appendix B apply. Conduct of monitoring. Monitoring shall be conducted as set forth in 40 CFR Section 63.8(a)(b)(1). Operation and maintenance of continuous monitoring systems. The Permittee shall maintain and operate each CMS in a manner consistent with good air pollution control practices. 1) The Permittee must keep the necessary parts for routine repairs of the affected CMS equipment readily available. 2) The Permittee must ensure the read out, or other indication of operation, from any CMS required for compliance with the emission standard is readily accessible on site for operational control or inspection. 3) All CMS shall be installed, operational, and the data verified prior to or in conjunction with conducting performance tests. Verification of operational status shall, at a minimum, include completion of the manufacturer's written specifications or recommendations for installation, operation, and calibration of the system. 6) The Permittee of a CMS that is not a CS, must check the zero (low-level) and high-level calibration drifts at least once daily in accordance with the written procedure specified in the performance evaluation plan. 40 CFR Section 63.7(c)(2); Minn. R CFR Section 63.7(c)(3); Minn. R CFR Section 63.7(d); Minn. R CFR Section 63.7(e)(1)-(2); Minn. R CFR Section 63.7(e)(3); Minn. R CFR Section 63.7(g); Minn. R CFR Section 63.7(h); Minn. R CFR 63.8(a)(2); Minn. R CFR Section 63.8(b)(1); Minn. R CFR Section 63.8(c)(1)-(3); Minn. R CFR Section 63.8(c)(6); Minn. R

31 TABLE A: LIMITS AND OTHER REQUIREMENTS A-27 09/21/15 Facility Name: Ardent Mills Flour Mill Permit Number: ) A CMS is out of control if: i) The zero (low-level), mid-level (if applicable), or high-level calibration drift (CD) exceeds two times the applicable CD specification in the applicable performance specification or in the relevant standard; or ii) The CMS fails a performance test audit (e.g., cylinder gas audit), relative accuracy audit, relative accuracy test audit, or linearity test au dit; or iii) The COMS CD exceeds two times the limit in the applicable performance specification in the relevant standard. When the CMS is out of control, the Permittee shall take the necessary corrective action and shall repeat all necessary tests which indicate that the system is out of control until the performance requirements are below the applicable limits. The beginning of the out-of-control period is the hour the Permittee conducts a performance check (e.g., calibration drift) that indicates an exceedance of the performance requirements established under this part. The end of the out-of-contro period is the hour following the completion of corrective action and successful demonstration that the system is within the allowable limits. During the period the CMS is out of control, recorded data shall not be used in data averages and calculations, or to meet any data availability requ irement. The Permittee shall submit all information concerning out-of-control periods, including start and end dates and hours and descriptions of corrective actions taken, in the excess emissions and continuous monitoring system performance report. The Permittee shall develop and implement a CMS quality control program. As part of the quality control program, the Permittee shall develop and submit to the Aministrator for approval upon request a site-specific performance evaluation test plan for the CMS performance evaluation required in 40 CFR Section 63.8(e)(3)(i). Each quality control program shall include, at a minimum, a written protocol that describes procedures for each of the following operations: i) Initial and any subsequent calibration of the CMS; ii) Determination and adjustment of the calibration drift of the CMS; iii) Preventive maintenance of the CMS, including spare parts inventory; iv) Data recording, calculations, and reporting; v) Accuracy audit procedures, including sampling and analysis methods; and vi) Program of corrective action for a malfunctioning CMS. The Permittee shall keep these written procedures on record for the life of the affected source, to be made available for inspection, upon request. The Permittee shall keep previous versions of the performance evaluation plan on record to be made available for inspection upon request, for a period of 5 years after each revision to the plan. Performance evaluation of continuous monitoring systems: 1) When required by a relevant standard, and at any other time the Administrator may require, the Permittee shall conduct a performance evaluation of the CMS according to the applicable specifications and procedures described in 40 CFR Section 63.8(e) or in the relevant standard. 2) Notification of performance evaluation. The Permittee shall notify the Administrator in writing of the date of the performance evaluation simultaneously with the notification of the performance test date or at least 6 0 days prior to the date the performance evaluation is scheduled to begin if no performance test is required. 3) Reporting performance evaluation results. The Permittee shall furnish the Administrator a copy of a written report of the results of the performance evaluation simultaneously with the results of the performance test or within 60 days of completion of the performance evaluation if no test is required, unless otherwise specified in a relevant standard. Use of an alternative monitoring method. Until permission to use an alternative monitoring procedure has been granted by the Administrator under 40 CFR Sections 63.8(f)(1)-(6), as appropriate, the Permittee remains subject to the requirements of 40 CFR Section 63.8 and the relevant standard. Reduction of monitoring data. The Permittee must reduce the monitoring data as specified in 40 CFR Section 63.8(g)(1)-(5). NOTIFICATION REQUIREMENTS Minn. R CFR Section 63.8(c)(7)(i); Minn. R CFR Section 63.8(c)(7)(H); Minn. R CFR Section 63.8(c)(8); Minn. R CFR Section 63.8(d); Minn. R CFR Section 63.8(d); Minn. R CFR Section 63.8(e)(1) & (2); Minn. R CFR Section 63.8(e)(3); Minn. R CFR Section 63.8(f); Minn. R CFR Section 63.8(g); Minn. R

32 TABLE A: LIMITS AND OTHER REQUIREMENTS A-28 09/21/15 Facility Name: Ardent Mills Flour Mill Permit Number: The Permittee of a new or reconstructed major affected source for which an application for approval of construction or reconstruction is required under 40 CFR Section 63.5(d) must provide the following information in writing to the Administrator: 1) A notification of intention to construct a new major-emitting affected source, reconstruct a major-emitting affected source, or reconstruct a major source such that the source becomes a major-emitting affected source; and 2) A notification of the actual date of startup of th e source, delivered or postmarked within 15 calendar days after that date. Notification of performance test. The Permittee shall notify the Administrator in writing of his or her intention to conduct a performance test at least 60 calendar days before the performance test is scheduled to begin. Additional notification requirements for sources with CMS. The Permittee shall submit to the Administrator written notification as follows: 1) A notification of the date the CMS performance evaluation under 40 CFR Sectior 63.8(e) is scheduled to begin, submitted simultaneously with the notification of the performance test date required under 40 CFR Section 63.7(b). If no performance test is required, or if the requirement to conduct a performance test has been waived, the Permittee shall notify the Administrator in writing of the date of the performance evaluation at least 60 calendar days before the evaluation is scheduled to begin; 2) A notification that the criterion necessary to continue use of an alternative to relative accuracy testing, as provided by 40 CFR Section 63.8(f)(6), has been exceeded. The notification shall be delivered or postmarked not later than 10 days after the occurrence of such exceedance. Notification of compliance status. Each time a notification of compliance status is required under 40 CFR pt. 63, subp. A, the Permittee shall submit to the Administrator a notification of compliance status containing the information required by 40 CFR Section 63.9(h), signed by the responsible official who shall certify its accuracy, attesting to whether the source has complied with the relevant standard. The notification must be sent by the 60th day following the completion of the relevant compliance demonstration activity specified in the relevant standard. If no performance test is required but opacity or visible emission observations are required, the notification of compliance status sh all be sent by the 30th day following the completion of opacity or visible emissio n observations. Notifications may be combined as long as the due date requirement for eac h notification is met. Notification. Any change in the informa tion already provided under 40 CFR Section 63.9 shall be provided to the Administrator in writing within 15 calendar days after the change. 40 CFR Section 63.9(b)(4); Minn. R CFR Section 63.9(e); Minn. R CFR Section 63.9(g)(1) & (3); Minn. R CFR Section 63.9(h); Minn. R CFR Section 63.9(j); Minn. R RECORDKEEPING AND REPORTING REQUIREMENTS Minn. R The Permittee shall submit each report to the Administrator. 40 CFR Section 63.10(a); Minn. R Recordkeeping. The Permittee shall maintain files of all information (including all reports and notifications) required by 40 CFR pt. 63 in a form suitable and readily available for expeditious inspection and review. The files shall be retained for at least 5 years following the date of each occurrence, measurement, maintenance, corrective action, report, or record. At a minimum, the most recent 2 years of data must be retained on site. The Permittee shall maintain, at a minimum, the following information in the files: 1) the occurrence and duration of each startup, shutdown, or malfunction of operation; 2) the occurrence and duration of each malfunction of the air pollution contro l equipment; 3) all maintenance performed on the pollution control equipment; 4) actions taken during periods of startup, shutdown, and malfunction when such actions are different from the procedures specified in the affected source's startup, shutdown, and malfunction plan (SSMP). In this case, the Permittee sh all report this action within 2 days of occurrence and follow by a written notification within 7 days of occurrence. 5) all information necessary to demonstrate conformance with the affected source's SSMP and actions taken in accordance with SSMP; 6) each period during which a continuous monitoring system (CMS) is malfunctioning or inoperative; (continued below) 40 CFR Section 63.10(b)(1); Minn. R , subp. 2(B) 40 CFR Section 63.10(b)(2); Minn. R , subp. 2(B)

33 TABLE A: LIMITS AND OTHER REQUIREMENTS A-29 09/21/15 Facility Name: Ardent Mills Flour Mill Permit Number: (continued from above) 7) all required measurements needed to demonstrate compliance with a relevant standard; 8) all results of performance test, CMS performance evaluations, and opacity and visible emission observations; 9) all measurements as may be necessary to determine the conditions of performance tests and performance evaluations; 10) all CMS calibration checks; 11) all adjustments and maintenance performed on CMS; 12) any information demonstrating whether a source is meeting the requirements for a waiver of record keeping or reporting requirements under this part; 13) all documents supporting initial notifications and notifications of compliance status. Additional recordkeeping requirements for sources with continuous monitoring systems. The Permittee shall maintain records as specified within 40 CFR Section 63.10(c); including CMS measurements (including monitoring data recorded during breakdowns and out-of-control periods) and corrective actions. Notwithstanding the requirements in 40 CFR Sections 63.10(d) and 63.10(e), the Permittee shall submit reports to the Administrator in accordance with the reporting requirements in the relevant standard. Progress reports. The Permittee who is required to submit progress reports as a condition of receiving an extension of compliance under 40 CFR Section 63.6(i) shall submit such reports to the Administrator by the dates specified in the written extension of compliance. Periodic startup, shutdown, and malfunction reports. If actions taken by a Permittee during a startup or shutdown (and the sta rtup or shutdown causes the source to exceed any applicable emission limitation in the relevant emission standards), or malfunction of an affected source (including actions taken to correct a malfunction) are consistent with the procedures specified in the source's startup, shutdown, and malfunction plan, the Permittee shall state such information in a startup, shutdown, and malfunction report. Actions taken to minimize emissions during such startups, shutdowns, and malfunctions shall be summarized in the report and may be done in checklist form. Such a report shall also include the number, duration, and a brief description for each type of malfunction which occurred during the reporting period and which caused or may have caused any applicable emission limitation to be exceeded. Reports shall only be required if a sta rtup or shutdown caused the source to exceed any applicable emission limitation, or if a malfunction occurred during the reporting period. The startup, shutdown, and malfunction report shall consist of a letter, containing the name, title, and signature of the Permittee who is certifying its accuracy, that shall be submitted to the Administrator semiannually. Startup, shutdown, and malfunction report: due 30 days following the end of each calendar half year. The Permittee may submit this simultaneously with the excess emissions and continuous monitoring system performance (or other) reports. The Permittee may request approval to reduce the frequency of reporting the procedures specified in 40 CFR Section 63.10(e)(3). Immediate startup, shutdown, and malfunction reports. Notwithstanding theallowance to reduce the frequency of reporting for periodic startup, shutdown, and malfunction reports, any time an action taken by a Permittee during a startup or shutdown that caused the source to exceed any applicable emission limitation in the relevant emission standards, or malfunction is not consistent with the procedures specified in the affected source's SSMP, the Permittee shall report the actions taken for that event within 2 working d ays after commencing actions inconsistent with the plan followed by a letter w ithin 7 working days after the end of the event. The immediate report required under this paragraph (d)(5)(ii) shall consist of a telephone call (or facsimile (FAX) transmission) to the Administrator within 2 working days after commencing actio ns inconsistent with the plan, and it shall be followed by a letter, delivered or postmarked within 7 working days. Additional reporting requirements for sources with continuous monitoring systems 1) When more than one CEMS is used to measure the emissions from one affected source, the Permittee shall report the results as required for each CEMS. Excess emissions and continuous monitoring system performance report and summary report. Excess emissions and parameter monitoring exceedances are defined in relevant standards. The Permittee shall submit an excess emissions and continuous monitoring system performance report and/or a summary report to the Administrator semiannually, except when more frequent reporting is specifically required by a relevant standard or a reduction in frequency is approved pursuant to 40 CFR Section 63.10(e)(3). 40 CFR Section 63.10(b)(2); Minn. R , subp. 2(B) 40 CFR Section 63.10(c); Minn. R CFR Section 63.10(d)(1); Minn. R CFR 63.10(d)(4); Minn. R CFR Section 63.10(d)(5)(i); Minn. R CFR Section 63.10(d)(5)(i); Minn. R CFR Section 63.10(d)(5)(i); Minn. R CFR Section 63.10(d)(5)(ii); Minn. R , subp. 2(B) 40 CFR Section 63.10(e)(1); Minn. R CFR Section 63.10(e)(3)(i)-(iv); Minn. R

34 TABLE A: LIMITS AND OTHER REQUIREMENTS A-30 09/21/15 Facility Name: Ardent Mills Flour Mill Permit Number: Content and submittal dates for excess emissions and monitoring system performance reports. All excess emissions and monitoring system performance reports and all summary reports, if required, shall be delivered or postmarked by the 30th day following the end of each calendar half or quarter, as appropriate. Written reports of excess emissions or exceedance s of process or control system parameters shall include all the information required in 40 CFR Section 63.10(c)(5)-(c)(13), in 40 CFR Section 63.8(c)(7) and 40 CFR Sectuib 63.8(c)(8), and in the relevant standard, and they shall contain the name, title, and signature of the responsible official who is certifying the accuracy of the report. When no excess emissions or exceedances of a parameter have occurred, or a CMS has not been inoperative, out of control, repaired, or adjusted, such information shall be stated in the report. Summary report. One summary report sha ll be submitted for the hazardous air pollutants monitored at each affected source (unless the relevant standard specifies that more than one summary report is required. The summary report shall be entitled "Summary Report: Gaseous and Opacity Excess Emission and Continuous Monitoring System Performance" and shall contain the information specified in 40 CFR Section 63.10(e)(3)(vi). If the total duration of excess emissions or process or control system parameter exceedances for the reporting period is 1 percent or greater of the total operating time for the reporting period, or the total CMS downtime for the reporting period is 5 percent or greater of the total operating time for the reporting period, both the summary report and the excess emissions and continuous monitoring system performance report shall be submitted. 40 CFR Section 63.10(e)(3)(v); Minn. R CFR Section 63.10(e)(3)(vi); Minn. R CFR Section 63.10(e)(3)(vii); Minn. R Waiver of recordkeeping or reporting requirements. No requirements required. 40 CFR Section 63.10(f); Minn. R

35 TABLE A: LIMITS AND OTHER REQUIREMENTS A-31 09/21/15 Facility Name: Ardent Mills Flour Mill Permit Number: Subject Item: Associated Items: CE 030 Fabric Filter - Low Temperature, i.e., T<180 Degrees F EU 005 Feed Loadout - Loading-Unloading Equipment What to do The operation of this piece of control equipment is not necessary in order for the process to meet applicable emissions limits. However, the Permittee wishes to take credit for its operation for the purposes of reporting actual emissions for emission inventory. Therefore, in order for, 10, and 2.5 to be considered controlled for the purposes of emissions inventory, the fabric filter must comply with the requirements of this permit during the time credit for control is taken. The, 10, and 2.5 generated during that time shall be considered controlled, and the control efficiency used is the limit given in this table. Total Particulate Matter: greater than or equal to 79 percent control efficiency (capture efficiency x collection efficiency) Total Particulate Matter: greater than or equal to 80 percent collection efficiency < 10 micron: greater than or equal to 74 percent control efficiency (capture efficiency x collectio n efficiency) < 2.5 micron: greater than or equal to 74 percent control efficiency (capture efficiency x collec tion efficiency) The Permittee shall operate and maintain the fabric filter in accordance with the Operation and Maintenance (O & M) Plan. The Permittee shall keep copies of the O & M Plan available onsite for use by staff and MPCA staff. Pressure Drop: greater than or equal to 0.5 inches of water column and less than or equal to 8 inches of water column unless a new range is set pursuant to Minn. R , subp. 3 based on the values recorded during the most recent MPCA-approved performance test where compliance was demonstrated. The new range shall be implemented upon receipt of the Notice of Compliance letter granting preliminary approval. The range is final upon issuance of a permit amendment incorporating the change. Visible Emissions: The Permittee shall check the fabric filter stack (SV 016) for any visible emissions once each day of operation during daylight hours. During inclement weather, the Permittee shall read and record the pressure drop across the fabric filter, once each day of operation. Recordkeeping of Visible Emissions and Pressure Drop. The Permittee shall record the time and date of each visible emission inspection and pressure drop reading, and whether or not any visible emiss ions were observed, and whether or not the observed pressure drop was within the range specified in this permit Periodic Inspections: At least once per calendar quarter, or more frequently as required by the manufacturing specifications, the Permittee shall inspect the control equipment components. The Permittee shall maintain a written record of these inspections. Corrective Actions: The Permittee shall take corrective action as soon as possible if any of the following occur: - visible emissions are observed; or - the recorded pressure drop is outside the required operating range; or - the fabric filter or any of its components are found during the inspections to need repair. Corrective actions shall eliminate visible emissions, and/or return the pressure drop to within the permitted range, and/or include completion of necessary repairs identified during the inspection, as applicable. Corrective actions include, but are not limited to, those outlined in the O & M Plan for the equipment. The Permittee shall keep a record of the type and date of any corrective action taken. Monitoring Equipment: The Permittee shall install and maintain the necessary monitoring equipment for measuring and recording pressure drop as required by this permit. The monitoring equipment must be installed, in use, and properly maintained when the monitored cyclones are in operation. Why to do it Minn. R (G) Minn. R (G) Minn. R , subp. 3(E) Minn. R (G) Minn. R (G) Minn. R (G) Minn. R (G) Minn. R (G) Minn. R (G) Minn. R (G) Minn. R (G) Minn. R , subp. 4

36 TABLE A: LIMITS AND OTHER REQUIREMENTS Facility Name: Ardent Mills Flour Mill Permit Number: A-32 09/21/15 Subject Item: FS 001 Fugitive HAP Sources (Fumigation, Preservation, etc.) What to do HAP-Single: less than or equal to 9.0 tons/year using 12-month Rolling Sum to be calculated by the 15th day of each month for the previous 12-month pe riod as described later in this permit. All fugitive HAP sources shall be included in this calculation. HAP contents for each material shall be determined as described under the Material Content requirement. Includes each individual HAP used in non-combu stion sources, including those used for water purification and product preservation. HAPs - Total: less than or equal to 20.0 tons/yea r using 12-month Rolling Sum to be calculated by the 15th day of each month for the previous 12-month period as described later in this permit. All fugitive HAP sources shall be included in this calculation. HAP contents for each material shall be determined as described under the Material Content requirement. Includes all HAP used in non-combustion sources, including those used for water purification and product preservation. Daily Recordkeeping. On each day of operation, the Permittee shall calculate, record, and maintain records of the total quantity of all HAP-containing materials used at the facility. This shall be based on written usage logs. Monthly Recordkeeping - HAP Usage. By the 15th day of each month, the Permittee shall calculate and record the following: 1) The quantity of each HAP-containing material used in the previous calendar month using the daily usage records. This record shall include the individual HAP content of each material as determined by the Material Content requirement of this permit. 2) The quantity of each individual HAP used in the previous month using the formulas specified in this permit. 3) The 12 month rolling sum of each individual HAP used for the previous 12 month period by summing the quantities calc ulated for that HAP for the previous 12 months. 4) The Total HAP usage for the previous month, by summing the quantities of each individual HAP used during the previous month. 5) the 12-month rolling sum of Total HAP for the previous 12 month s, by summing the Total HAP usage calculated for each of the previous 12 months. Monthly Calculation - Individual HAP Usage. The Permittee shall calculate the monthly quantity of each individual HAP using the following equations: Why to do it Title I Condition: Avoid major source under 40 CFR 63.2 and Minn. R ; Avoid major source under 40 CFR 70.2 and Minn. R Title I Condition: Avoid major source under 40 CFR 63.2 and Minn. R ; Avoid major sour ce under 40 CFR 70.2 and Minn. R Title I Condition: Avoid major source under 40 CFR 63.2 and Minn. R ; Avoid major so urce under 40 CFR 70.2 and Minn. R Minn. R , subps. 4-5 Minn. R , subps. 4-5 HAP A (tons/month) = (A1 x B1) + (A2 x B2) + (A3 x B3) + Where: HAP A = total quantity of HAP A used in tons/month; A# = amount of each HAP A-containing material used, in tons/month; B# = weight percent of HAP A in A#, as a fraction Material Content. HAP contents in materials shall be determined by the Material Safety Data Sheet (MSDS) provided by the supplier for each material used. If a material content range is given on the MSDS, the highest number in the range shall be used in all compliance calculations. Other alternative methods approved by the MPCA may be used to determine the HAP content. The MPCA reserves the right to require the Permittee to determine the HAP content of any material, according to EPA or ASTM reference methods. If an EPA or ASTM reference method is used for material content determination, the data obtained shall supersede the MSDS. Minn. R , subps. 4 and 5

37 TABLE B: SUBMITTALS Facility Name: Ardent Mills Flour Mill Permit Number: B-1 09/21/15 Also, where required by an applicable rule or permit condition, send to the Permit Document Coordinator notices of: - accumulated insignificant activities, - installation of control equipment, - replacement of an emissions unit, and - changes that contravene a permit term. Send submittals that are required to be submitted to the U.S. EPA regional office to: Chief Air Enforcement Air and Radiation Branch EPA Region V 77 West Jackson Boulevard Chicago, Illinois Each submittal must be postmarked or received by the date specified in the applicable Table. Those submittals required by parts to must be certified by a responsible official, defined in Minn. R , subp. 21. Other submittals shall be certified as appropriate if certification is required by an applicable rule or permit condition. Table B lists most of the submittals required by this permit. Please note that some submittal requirements may appear in Table A or, if applicable, within a compliance schedule located in Table C. Table B is divided into two sections in order to separately list one-time only and recurrent submittal requirements. Send submittals that are required by the Acid Rain Program to: U.S. Environmental Protection Agency Clean Air Markets Division 1200 Pennsylvania Avenue NW (6204N) Washington, D.C Send any application for a permit or permit amendment to: Fiscal Services Minnesota Pollution Control Agency 520 Lafayette Road North St. Paul, Minnesota 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

38 TABLE B: ONE TIME SUBMITTALS OR NOTIFICATIONS B-2 09/21/15 Facility Name: Ardent Mills Flour Mill Permit Number: Testing Frequency Plan What to send When to send Portion of Facility Affected due 60 days after Initial Performance Test for 10 emissions. The plan shall specify a testing frequency based on the test data and MPCA guidance. Future performance tests based on 12-month, 36-month, or 60-month intervals, or as applicable, shall be required upon written approval of the MPCA. GP003

39 TABLE B: RECURRENT SUBMITTALS B-3 09/21/15 Facility Name: Ardent Mills Flour Mill Permit Number: Report Semiannual Deviations Report Annual Report Compliance Certification What to send When to send Portion of Facility Affected due 30 days after end of each half-year starting 08/08/1994. The report shall be submitted to the U.S. EPA, and shall include the following: - the calendar dates covered in the reporting period - records of fuel oil supplier certifications - certified statement signed by the owner or operator stating that the records of fuel supplier certifications submitted represent all of the fuel oil combusted during the reporting period. due 30 days after end of each calendar half-year starting 12/09/2002. The first semiannual report submitted by the Permittee shall cover the calendar half-year in which the permit is issued. The first report of each calendar year covers January 1 - June 30. The second report of each calendar year covers July 1 - December 31. I f no deviations have occurred, the Permittee shall submit the report stating no deviations. due 90 days after end of each calendar year starting 12/09/2002. The Permittee shall submit an annual report by April 1 that describes the changes made at the facility during the previous calendar year. The report whall include a copy of all Equipment Lists, and shall document any equipment changes that took place during the previous calendar year, and any applicable New Source Performance Standards or NESHAPs that became effective during the previous calendar year. This report may be submitted with the annual emissions inventory, but it shall be a separate document marked as the "Annual Report." As part of the Annual Report, the Permittee shall verify and certify that the facility has maintained minor source status for New Source Review and Part 70, and has maintained area source status under the NESHAP program. due 31 days after end of each calendar year starting 12/09/2002 (for the previous calendar year). The Permittee shall submit this to the Commissioner on a form approved by the Commissioner. This report covers all deviations experienced during the calendar year. EU001 Total Facility Total Facility Total Facility

40 APPENDIX I: Insignificant Activities and Applicable Requirements Facility Name: Ardent Mills Flour Mill Permit Number: Minn. R , subpart 3(G) Rule Description of the Activity Emissions from a laboratory, as defined in the subpart. One OA laboratory Applicable Requirement Minn. R /0515; Minn. R ; Minn. R /0715

41 APPENDIX II: Equipment List Facility Name: Ardent Mills Flour Mill Permit Number: EU002 - Grain Receiving: SV002. CE002 Note: Any replacement, addition, or modification to the components listed below should be considered a modification ofeu002for purposes of determining if a permit amendment is required for the replacement, addition, or modification. CE001, SV001 - VENTS OUTSIDE *Truck Dump Pit * Rail Dump Pit EU003 - Grain Cleaning Note: Any replacement, addition, or modification to the components listed below should be considered a modification of EU003 for purposes of determining if a permit amendment is required for the replacement, addition, or modification. CE003, SV003 - vents inside * Bulk Feed Loadout cyclone 11/24/1985 *A/B Dirty wheat drag C332, C342 3/25/2001 *AM Camas 6/1/2006 *BM Camas 6/1/2006 *A-mill FD Airlock A200 1/19/1978 Pellet Drag FL101/11995 *AM Reddog A/L A-19 1/1978 Airlock A200 1/1978 Pellet cyclone 1995 Pellet to Storage A/L FM Pellet Scale 1995 B-mill FD A/L B200 1/19/1978 Reclaim Entoleter C270 6/1/1997 CE004, SV004-vents inside BM Aquatron bypass spout 11/27/2011 BM Carter Day separator C531 4/27/2000 BM MTMA Separator C Scr. A/L Bench SC RM MTMA Separator C RM Aspirator C Bins 19 and 20 2/23/1997 WW Rye Carter/Day 1975 Turbo Aspirator 2009 BM Inertial Separator C Rye Intertial Seperator C

42 *BM Light Fraction Dup Aspirator C *BM Scourer/aspirator C433 6/1/2006 *Screenings feeder screw SC * Bin 20 Chyclone SC *BM Dirty Wheat Scale 3/25/2001 *Loadout bin #5 11/24/1991 CE005, SV005 - vents inside *WW WTR Spout 2012 *AM WTR Aspirator Surge Bin 6/1/2006 *BM WTR Aspirator Surge Bin 6/1/2006 *AM Grinding Bin Conveyor C *BM Grinding Bin Conveyor C *Rye Feed Airlock C *WTR Aspiration Airlock A * *AM Carter/Day C *RM D. Wheat Elev. Leg C961 1/1/1977 *AM Scale Elev. Leg C941 8/13/1997 *AM Clean Wheat Elev. Leg C942 8/13/1997 *BM D. Wheat Elev. Leg C931 8/13/1997 *WW D. Wheat Elev. Leg C950 8/13/1997 Reclaim Leg C *WW product A/L 1995* *DR Airlock E *SPDR Airlock E *Rye Duo Aspirator 4/25/1988 *RM Clean Rye elev. Leg C *AM D. Wheat Elev. Leg C *AM 1st Temper Elev. Leg C Screenings A/L Hopper C *BM Clean Wheat Elev. Leg C *BM Scale Elev. Leg C * *WW Clean Wheat Elev. Leg C Damaged Wheat A/L Hopper C *WW Stonemill 2000 *Small Wht collection Drag C380 6/1/2006 *Small Wheat collection A/L C *AM WTR Recycle Aspirator MVSQ 2014* *BM WTR Recycle Aspirator MVSQ 2014 CE006, SV006 - vents inside *Dirty Wheat from Elevator Drag, E-W 1993 *AM Combinator booster fan C *AM Combinator (Stoner) C *Entolated wheat line, Reciever 1995 *A/B Final Temper Drags, N-S C841, C *Rye Stoner C *AM Light Fraction duo Asp C440 6/1/1994

43 CE007, SV007 - vents inside *AM AquaTron 2011 Pelletmill Bin Suction Fan FM620/6 6/1/1995 WW Cyclone 1995 *AM Dirty Wheat Scale 3/25/2001 Mixing Screw WW final temper C852 12/23/1990 *Mixing screw BM final temper leg C *AM Final Temper leg C *DM Feed Bins 2, Pellet Mill surge bin 3/24/1996 Durum cyclone to bins 28, *Suction to bins 28, *AM Inertial Separator C CE008, SV008 - vents inside *WW MTMA Separator C WW Concentrator C WW Carter/Day C "WW airlock to Mill C WW Inertial Separator C *FD Airlock #1 FR *FD Airlock #2 FR CE009, SV009 - vents inside WW Destoner 2000 BM Combinator Booster Fan 2005 CE010, SV010 - vents inside Feed cyclone C Bridge drag C Feed Tower Cyclones, Screw and Bins 1998 Rye Annex Cyclones and Bins 2/22/1998 Bin 20 Screenings cyclone 1998 CE035, SV013 - vents inside Cyclone on Screenings bench SC830 4/1997 Flammermill Screenings A/L SC230 4/1997 EU004-Milling Note: Any replacement, addition, or modification to the components listed below should be considered a modification ofeu004for purposes of determining if a permit amendment is required for the replacement, addition, or modification. CE011, SV011- VENTS OUTSIDE 6th fl- cyclone receivers

44 *3rd fl- product scales- 2 3/17/2009 *3rd fl- airlock hoppers- 2 7/22/1996 *lst fl- airlock hoppers-10 7/22/1996 CE012, SV011 - VENTS OUTSIDE 6th fl- cyclone receivers rd fl- product scales- 2 3/17/2009 3rd fl- airlock hoppers- 2 7/22/1996 1st fl- airlock hoppers-9 7/22/1996 CE014, SV012 - vents inside *Durum Blending Filter 1978 Filter # Conveyor(s) - 8 6/1/1989 *Cyclone Reciever A/L Hopper(s) Fan Bulk Truck -1 1/24/1991 CE015, SV012 - vents inside Bulk L/O 11/24/1991 Filter # Rail Car Suction A/L Hopper Elevator/Packing/Feed 1978 CE016, SV012 - vents inside Flour Bin Suction Filter 1971 Filter #8 6/1/2006 Bin(s) Cyclone Reciever(s) A/L Hopper(s) Rail loadout bins 1978 Durum blending blower 1971 Blender bulk blower 1971 Blend plant forcsa's 1971 Rye annex blower 1971 Durum transfer blower cyclone 1971 Bulk truck receiving cyclone 1971 CE017, SV012 - vents inside System 1 Mill Pneumatics 1971 Filter # Pressure lift: semo to rebolt cyclones 1971 CE018, SV012 - vents inside Durum Combinator Filter 1971

45 * Filter # *Buhler MTCD Combinator 3/28/2005 CE019, SV012 - vents inside Filter # *Purifier(s) /5/1993 *1 BKA/L Hopper CE020, SV012 - VENTS OUTSIDE (I think this is a typo) *Pneu. Sys. #2 - Filter #3 4/1/1980 Scourers - 4 4/25/1988 Combinator Asp /57/2000 *TW Duo Asp. -1 6/1/1994 Seperator Asp *Cyclone Reciever(Feed) CarterDay - 5 4/25/1988 *TW Bin Elevator Leg-7 8/13/1997 Garvity Table Asp Cyclone Reciever(VertiJet) Cyclone Reciever(TW Asp.) LF Duo Asp *Bin(s) - 7(TW - 2, Scr. -1, Cr. Wht. -1, RD - 2, Rebolt -1) 1971 Conv. (Feed) -1 6/1/1995 Bin - Wheat Heater -11/14/2000 *DW Scale -1 3/25/2001 Scr. Bin A/L Hopper(s) Hammermill - 1 7/15/2005 CE021, SV015 - vents inside Bulk Truck Filter 11/24/1985 Bin(s) - 2 4/20/1997 CE022, SV012 - vents inside Pneu. Sys. #3 -Filter #11971 Cyclone Recievers BK Product lift to sifters BK Red on S-mix and T-mix 1971 CE023, SV015 - vents inside Pneu. Sys. #3-Filter #11971 Cyclone Recievers *1 BK Product lift to sifters BK Red on S-mix and T-mix 1971 CE024, SV015 - vents inside Durum Pneu. Systems 1971

46 *Pneu. Sys. #1 - Filter # *Cyclone Recievers *Product lift: Pat flour to rebolt 1971 ""Product lift: 2/3 BK Redust to sifter 1971 *Product lift: 1 BK Red to Chappati cyclone 1971 CE037, SV011 - VENTS OUTSIDE *6th fl- cyclone receivers- 5 3/1998 CE038, SV011 - VENTS OUTSIDE *5th fl- cyclone receivers- 2 3/1998 *5th fl D mill- red dog cyclone receiver 3/1998 *4th fl- purifiers- 7 3/1998 *4th fl- spouts- 2 3/1998 *4th fl- wheat germ sifter 3/1998 *5th fl D mill- cyclone receiver 3/1998 *4th fl- cyclone receiver- co/fn farina 3/1998 *3rd- product scale-1 3/1998 CE039, SV011 - VENTS OUTSIDE *6th fl- cyclone receivers- 15 3/1998 *5th fl- cyclone receivers- 2 3/1998 *3rd fl- airlock hopper-1 3/1998 CE040, SV011 - VENTS OUTSIDE *5th fl- cyclone receivers- 3 3/1998 *4th- purifiers- 7 3/1998 EU005 - Feed Loadout Note: Any replacement, addition, or modification to the components listed below should be considered a modification of EU005 for purposes of determining if a permit amendment is required for the replacement, addition, or modification. CE030, SV016 - vents inside *Midds Shed 11/24/1985 EU006 - Grain Handling Note: Any replacement, addition, or modification to the components listed below should be considered a modification ofeu006for purposes of determining if a permit amendment is required for the replacement, addition, or modification. CE002, SV002 - VENTS OUTSIDE *N. Mix drag 10/21/2013 *S. Mix Drag 10/21/2013 *Separator Leg 1/1/1977

47 Unload Leg 1/1/1977 *Mix Leg 1/1/1977 *Durum Leg 1/1/1977 Durum Screw 1971 Garner Bin 1982 Separator Bins 1971 Screenings Hopper 6/1/1996 Filter Drag 1971 Unload Drag 11/8/2010 Roof drag 11/25/2011 EU007 - Flour Storage and Loading Note: Any replacement; addition, or modification to the components listed below should be considered a modification of EU007for purposes of determining if a permit amendment is required for the replacement, addition, or modification. CE007, SV007 - vents inside AM AquaTron 2011 Pelletmill Bin Suction Fan FM620/6 6/1/1995 WW Cyclone 1995 AM Dirty Wheat Scale 3/25/2001 Mixing Screw WW final temper C852 12/23/1990 Mixing screw BM final temper leg C AM Final Temper leg C DM Feed Bins 2, Pellet Mill surge bin 3/24/1996 Durum cyclone to bins 28, Suction to bins 28, AM Inertial Separator C EU008 - Pellet Cooling Note: Any replacement, addition, or modification to the components listed below should be considered a modification ofeu008for purposes of determining if a permit amendment is required for the replacement, addition, or modification. CE008, SV008 - vents inside WW MTMA Separator C WW Concentrator C WW Carter/Day C WW airlock to Mill C WW Inertial Separator C *FD Airlock #1 FR FD Airlock #2 FR

48 TECHNICAL SUPPORT DOCUMENT For AIR EMISSION PERMIT NO This technical support document (TSD) is intended for all parties interested in the permit and to meet the requirements that have been set forth by the federal and state regulations (40 CFR 70.7(a)(5) and Minn. R , subp. 1). The purpose of this document is to provide the legal and factual justification for each applicable requirement or policy decision considered in the determination to issue the permit. 1. General Information 1.1 Applicant and Stationary Source Location: Table 1. Applicant and Source Address Ardent Mills LLC 11 Conagra Drive Omaha, NE Contact: Levi Burton Phone: Applicant/Address Stationary Source/Address (SIC Code: 2041) Ardent Mills Flour Mill 2005 Vermillion Street South Hastings, Dakota County, Minnesota Facility Description Ardent Mills Flour Mill operates a wheat flour and animal feed mill in Hastings, Minnesota. The facility consists of wheat mills, durum mills, durum processing, a rye mill, and associated elevator, storage, and packaging areas. Seventy-five percent of the wheat received is processed into flour and the remaining 25 percent into feed. The facility operates a boiler for heating and wheat tempering during the winter months. In Permit -001 the facility accepted limits on the amount of wheat to be processed and on the amount of fumigant (methyl bromide), which may be used. These limits were federally enforceable, and resulted in the facility being a nonmajor source under the Part 70 permit program, the New Source Review program, and the National Emission Standards for Hazardous Air Pollutants program. 1.3 Description of the Activities Allowed by this Permit Action This permit action is for a Major Amendment. It is a reopening under Minn. R , subp. 1(D). No construction is being authorized. This permit action incorporates an Administrative Amendment to change the facility name from ConAgra Flour Mill - Hastings to Ardent Mills Flour Mill and the owner from ConAgra Foods to Ardent Mills LLC. In addition, recurring opacity testing for fugitive emissions was added to EU 002 and EU 005. Other changes to the permit: Citations were corrected. Total Facility boilerplate language was updated. Completed requirements were deleted. EU descriptions were updated in preparation for migration to new MPCA permit database. 2.5 control efficiencies were added. Requirements to route all emissions to control equipment was added under EU EU 008. Monitoring requirements were added to GP 001 and CE day rolling sum limits were changed to 12-month rolling sum limits, to be consistent with similar facilities. Total Facility 10 limits were replaced with grain throughput limits at EU EU 008, to be consistent with similar facilities. Added a list of equipment to the permit appendix. Technical Support Document, Permit Action Number: Page 1 of 13

49 GP 003: "io and 25" Limits was created and Ib/hr limits and performance testing requirements were added. The emergency generator was removed from the Insignificant Activities list in the permit appendix and added to the body of the permit with its applicable requirements (EU009). Capture efficiency of Grain Receiving (EU 002) was corrected in the calculation spreadsheet from % to 80%. 1.4 Facility Emissions: There is no real change in potential emissions authorized by this permit action. However the calculated potential emissions have changed because of regulatory changes in the method of calculation (control efficiencies in Minn. R have been revised), and the addition of 25 and greenhouse gases as regulated pollutants. The calculated PTE based on permit conditions is as follows: tpy Table 2. Total Facility Potential to Emit Summary 10 tpy 25 tpy S0 2 tpy Total Facility Limited Potential Emissions Total Facility Actual * 0.1 * Emissions (2014) *Not reported in MN emission inventory. PSD NO x tpy Table 3. Facility Classification CO tpy C0 2e tpy Classification Major Synthetic Minor/Area Minor/Area Part 70 Permit Program Part 63 NESHAP X X X VOC tpy Single HAP tpy All HAPs tpy 2. Regulatory and/or Statutory Basis New Source Review The existing facility is subject to, 10, 25, and throughput limits such that emissions are less than the major source thresholds for NSR (40 CFR 52.21(b)(1)). Therefore, as defined by the federal rules, the facility is not considered an existing major source for NSR. That status does not change with this permit action. Part 70 Permit Program The existing facility is subject to 10, 25, and throughput limits such that emissions are less than the major source thresholds for Part (40 CFR 70.2).Therefore, as defined by the federal rules, the facility is not considered an existing major source under the Part 70 Permit Program. That status does not change with this permit action. New Source Performance Standards (NSPS) EU001 is a 13.4 MMBtu/hour boiler installed in 1994, and is subject to 40 CFR pt. 60, Subp. Dc, Standards of Performance for Small Industrial-Commercial-lnstitutional Steam Generating Units. EU009, a compression ignition engine, was manufactured before July 11, 2005, and therefore is not subject to 40 CFR pt. 60, Subp. Illl, Standards of Performance for Stationary Compression Ignition Internal Combustion Engines. National Emission Standards for Hazardous Air Pollutants (NESHAP) The facility has accepted limits on HAP emissions such that it is an area source under 40 CFR pt. 63. Thus, no major source NESHAPs apply. However, the area source NESHAP for stationary RICE, 40 CFR pt. 63, subp. ZZZZ, applies to the emergency generator, EU 009. Technical Support Document, Permit Action Number: Page 2 of 13

50 Minnesota State Rules The emergency generator (EU 009) is subject to Minn. R : Standards of Performance for Stationary Internal Combustion Engines. Portions of the facility are subject to Minn. R : Standards of Performance for Dry Bulk Agricultural Commodity Facilities. Portions of the facility are subject to Minn. R : Standards of Performance for Post-1969 Industrial Process Equipment. Table 4. Regulatory Overview of Units Affected by the Permit Amendment Subject Item Applicable Regulations Rationale GP 003 (io and 2.5 Limits) EU 001 (Boiler) EU 002 (Grain Receiving) EU 003 (Grain Cleaning) Limit to avoid PSD and Part 70 Prevention of Significant Deterioration (PSD) and Part 70. Pound per hour limits taken to keep the potential emissions of 10 and 25 from the Milling operations to less than the major source threshold as defined by 40 CFR Part 70 Permit Program. Pound per hour limits taken to keep the potential emissions of 10 and 25 from the Milling operations to less than the major source threshold as defined by 40 CFR CFR pt. 60, Subpart Dc Standards of Performance for Small Industrial-Commercial- Institutional Steam Generating Units. Boiler combusts natural gas and oil, and is subject fuel sulfur limitations; because it is smaller than 30 MMBtu/hour, it is not subject to the NSPS opacity limits (40 CFR 60.43c(c)) Limit to avoid PSD and Part 70 Minn. R , subp. 5 Conditions to avoid PSD and Part 70 PSD and Part 70. Process throughput must not exceed 523,000 tpy in order to remain a non-major source under 40 CFR and 40 CFR 70.2 Any replacement or change or modification of any component of EU 002 (listed in Appendix II) is considered a modification of EU 002 for purposes of determining if a permit amendment is needed. PSD and Part 70. The permittee sha ll route all emissions from "EU 002" to control equipment meeting the requirements of GP 001 and EU 002. Limit to avoid PSD and Part 70 PSD and Part 70. The control equipment associated with EU 002 must meet collection efficiency for and 93% collection efficiency of i0 and 25 in order to remain a non-major source under 40 CFR and 40 CFR 70.2 Minn. R , subp. 5 Conditions to avoid PSD and Part 70 Any replacement or change or modification of any component of EU 003 (listed in Appendix II) is considered a modification of EU 003 for purposes of determining if a permit amendment is needed. PSD and Part 70. The permittee sha ll route all components of "EU 003" to control equipment meeting the requirements of GP 001 and EU 003. Limit to avoid PSD and Part 70 The control equipment associated with EU 003 must meet 93% collection efficiency of 10 and 2. 5 in order to remain a nonmajor source under 40 CFR and 40 CFR Technical Support Document, Permit Action Number: Page 3 of 13

51 Subject Item Applicable Regulations Rationale EU 004 (Milling) Minn. R , subp. 5 Conditions to avoid PSD and Part 70 Any replacement or change or modification of any component of EU 004 (listed in Appendix II) is considered a modification of EU 004 for purposes of determining if a permit amendment is needed. The permittee shall route all components of "EU 004" to control equipment meeting the requirements of GP 001 and EU 004. Limit to avoid PSD and Part 70 PSD and Part 70. The control equipment associated with EU 004 must meet control efficiency for, 99.06% collection efficiency of 10 and 94.05% collection efficiency for 2. 5 in order to remain a non-major source under 40 CFR and 40 CFR EU 005 (Feed Loadout) Minn. R , subp. 5 Minn. R (G) Minn. R (G) Minn. R , subp. 5 Any replacement or change or modification of any component of EU 005 (listed in Appendix II) is considered a modification of EU 005 for purposes of determining if a permit amendment is needed. Use of control equipment is not required in order to meet applicable limits. However, so that the permittee is able to take credit for the controls for purposes of reporting annual emissions, the permit requires that all EU 005 components be routed to CE 030 (or equivalent replacement unit) and that the control be at least 93% efficient for 10 and The permittee is given credit for control efficiency for, and 93% control efficiency of 10 and 2i5for emission inventory purposes. The control is not required in order to meet applicable emission limits. Any replacement or change or modification of any component of EU 006 (listed in Appendix II) is considered a modification of EU 003 for purposes of determining if a permit amendment is needed. EU 006 (Grain Handling) Conditions to avoid PSD and Part 70 PSD and Part 70. The permittee shall route all components of "EU 006" to control equipment meeting the requirements of GP 001 and EU 006 Limit to avoid PSD and Part 70 PSD and Part 70. The control equipment associated with EU 006 must meet control efficiency for and 93% control efficiency of 10 and 25 in order to remain a non-major source under 40 CFR and 40 CFR Minn. R , subp. 5 Any replacement or change or modification of any component of EU 007 (listed in Appendix li) is considered a modification of EU 007 for purposes of determining if a permit amendment is needed. EU 007 Conditions to avoid PSD and PSD and Part 70. The permittee shall route all components of "EU (Flour Part " to control equipment meeting the requirements of GP 001 and Storage EU 007. and Loading) Limit to avoid PSD and Part 70 PSD and Part 70. The control equipment associated with EU 007 must meet control efficiency for and 93% control efficiency of io and 2. 5 in order to remain a non-major source under 40 CFR and 40 CFR EU 008 (Pellet Cooling) Limit to avoid PSD and Part 70 PSD and Part 70. Process throughput must not exceed 43,147.5 tpy (33% of feed is pelletized) in order to remain a non-major source under 40 CFR and 40 CFR 70.2 Technical Support Document, Permit Action Number: Page 4 of 13

52 Subject Item Applicable Regulations Rationale Minn. R , subp. 5 Conditions to avoid PSD and Part 70 Any replacement or change or modification of any component of EU 008 (listed in Appendix II) is considered a modification of EU 008 for purposes of determining if a permit amendment is needed. PSD and Part 70. The permittee shall route all components of "EU 008" to control equipment meeting the requirements of GP 001 and EU 008. Limit to avoid PSD and Part 70 PSD and Part 70. The control equipment associated with EU 008 must meet control efficiency for and 93% control efficiency of 10 and 2. 5 in order to remain a non-major source under 40 CFR and 40 CFR EU 009 (Emergency Generator) 40 CFR pt. 63, Subpart ZZZZ National Emission Standards for Hazardous Air Pollutants for Reciprocating Internal Combustion Engines. The unit is existing. The unit is compression ignition. The unit is for emergency use only. FS 001 (Fugitive HAP Sources) Minn. R Limit to avoid Part 70 and NESHAPs Standards of Performance for Stationary Internal Combustion Engines National Emission Standards for Hazardous Air Pollutants and Part 70. Limit set on HAPs emissions to avoid major source classification under 40 CFR Part 63 and 40 CFR Part Technical Information 3.1 m and?^ Control Efficiencies Previous permit actions were based on an assumed control efficiency for 10 for calculations of potential-to-emit (PTE). However, the assumed i 0 control efficiency in Minn. R has been changed to 93%, so calculations were revised to reflect that change. In order to remain a non-major source under NSR and Part 70, a higher control efficiency must be met for the milling operations (EU004); the permit includes the higher efficiency as well as an hourly emission rate that must be met. The Permittee is required to test the milling operations stacks to ensure that the hourly emission rate is met. The calculations are in Attachment 3 to this TSD. 3.2 Monitoring In accordance with the Clean Air Act, it is the responsibility of the owner or operator of a facility to have sufficient knowledge of the facility to certify that the facility is in compliance with all applicable requirements. In evaluating the monitoring included in the permit, the MPCA considered the following: the likelihood of the facility violating the applicable requirements; whether add-on controls are necessary to meet the emission limits; the variability of emissions over time; the type of monitoring, process, maintenance, or control equipment data already available for the emission unit; the technical and economic feasibility of possible periodic monitoring methods; and the kind of monitoring found on similar units elsewhere. The table below summarizes the monitoring requirements associated with this amendment. Technical Support Document, Permit Action Number: Page 5 of 13

53 Subject Item GP 003 ( 10 and 2.5 Limits) Table 5. Monitoring Requirement (rule basis) Monitoring Discussion 10 <23.00 Ibs/hr 2.S< Ib/hr (Limit to avoid PSD and Part 70) EU 001 (Boiler) Fuel Sulfur content < 0.5% by weight EU 002 (Grain Receiving) (40 CFR 60 Subpart Dc) Opacity: < 5 % from fugitive emissions (Minn. R , subp. 3(A)) Opacity: < 10% from the stack (Minn. R , subp. 3(D)) Process Throughput < 523,000 tpy (Limit to avoid PSD and Part 70) > 80% collection efficiency (Minn. R , subp.3(e)) > collection efficiency 10 > 93% collection efficiency (Limit to avoid PSD and Part 70) Initial Performance Test and Testing Frequency Plan for 10 Control equipment monitoring as described at GP001 (Daily visible emissions checks and recordkeeping, daily pressure drop readings and recordkeeping, O&M, periodic inspections, corrective) Recordkeeping of fuel oil supplier certifications Performance Testing every five years. Daily visible emission checks (GP001) Daily recordkeeping; Monthly calculations and recordkeeping Daily visible emissions checks and recordkeeping, daily pressure drop readings and recordkeeping, O&M, periodic inspections, corrective actions (GP001) Emissions from the three stacks exhausting 10 emissions from milling operations must not exceed Ibs/hr when the emissions of the three stacks are added together. The permittee is only required to specifically test 10 emissions. It is assumed that all 2. 5 is a lso i 0, so if io is less than Ib/hr, 2. 5 will also be less than Ib/hr. If the limits cannot be met, the permittee must apply for a permit amendment proposing permit terms to maintain non-major status, or must apply for a Part 70 permit. As required by standard. The May 1, 2012 Performance Test resulted in: < 1.3% Opacity for Truck Unloading (26% of limit) < 0.6% Opacity for Railcar Unloading (12% of limit) If any visible emissions are detected, corrective action is to betaken. The facility must not receive more than 523,000 tpy of grain in order to remain a non-major source under 40 CFR and 40 CFR Monthly calculations are adequate to ensure compliance. This is less restrictive than the collection efficiency required by the control equipment rule, and is easily met by a properly maintained fabric filter. The control equipment is Listed Control Equipment under Minn. R with the efficiency specified in the rule. The MPCA generally does not require testing unless a higher efficiency is needed to meet permit limits. The permit contains requirements for proper operation and maintenance of the control equipment. If the control equipment is properly operated and maintained there is a reasonable assurance that the control equipment will achieve the listed efficiency. Technical Support Document, Permit Action Number: Page 6 of 13

54 Subject Item Requirement (rule basis) Monitoring Discussion 2.5 > 93% collection efficiency (Limit to avoid PSD and Part 70) 2.5 emissions are conservatively estimated as 10 emissions. Based on the type of operation, there is not expected to be condensable. Because the control equipment is Listed Control Equipment under Minn. R with 10 control efficiency listed in the rule, no testing is required. The permit contains requirements for proper operation and maintenance of the control equipment. I f the control equipment is properly operated and maintained there is a reasonable assurance that the control equipment will achieve the listed efficiency. Opacity: <5% from fugitive emissions (Minn. R , subp. 3(A)) None Capture efficiency of the control device is % (total enclosure); there are not expected to be fugitive emissions Opacity: < 10% from each stack (Minn. R , subp. 3(D)) Daily visible emission checks (GP001) If any visible emissions are detected, corrective action is to be taken. > 80% collection efficiency (Minn. R , subp.3(e)) This is less restrictive than the collection efficiency required by the control equipment rule, and is easily met by a properly maintained fabric filter. EU 003 (Grain Cleaning) > collection efficiency 10 > 93% collection efficiency (Limit to avoid PSD and Part 70) 2.5 > 93% collection efficiency (Limit to avoid PSD and Part 70) Daily visible emissions checks and recordkeeping, daily pressure drop readings and recordkeeping, O&M, periodic inspections, corrective actions (GP001) The control equipment is Listed Control Equipment under Minn. R with the efficiency specified in the rule. The MPCA generally does not require testing unless a higher efficiency is needed to meet permit limits. The permit contains requirements for proper operation and maintenance of the control equipment. If the control equipment is properly operated and maintained there is a reasonable assurance that the control equipment will achieve the listed efficiency. 2.5 emissions are conservatively estimated as i0 emissions. Based on the type of operation, there is not expected to be condensable. Because the control equipment is Listed Control Equipment under Minn. R with io control efficiency listed in the rule, no testing is required. The permit contains requirements for proper operation and maintenance of the control equipment. I f the control equipment is properly operated and maintained there is a reasonable assurance that the control equipment will achieve the listed efficiency. EU 004 (Milling) Opacity: < 10% from each stack (Minn. R , subp. 3(D)) Daily visible emission checks (GP001) If any visible emissions are detected, corrective action is to be taken. Technical Support Document, Permit Action Number: Page 7 of 13

55 Subject Item Requirement (rule basis) Monitoring Discussion EU 005 (Feed Loadout) 10 > 99.06% collection efficiency 2.S > 94.06% collection efficiency (Limit to avoid PSD and Part 70) > collection efficiency (Limit to avoid PSD and Part 70) >80% collection efficiency (Minn. R , subp.3(e)) Opacity: < 5 % from fugitive emissions from railcar loading (Minn. R , subp. 3(A)) Opacity: < 10 % from fugitive emissions from truck loading (Minn. R , subp. 3(B)) Opacity: < 10% from the stack (Minn. R , subp. 3(D)) >80% collection efficiency (Minn. R , subp.3(e)) Daily visible emissions checks and recordkeeping or daily pressure drop readings and recordkeeping, O&M, periodic inspections, corrective actions. See also performance testing required under GP003. Daily visible emissions checks and recordkeeping or daily pressure drop readings and recordkeeping, O&M, periodic inspections, corrective actions (GP001) Performance Testing every five years. Daily visible emission checks(ce030) Daily visible emissions checks and recordkeeping or daily pressure drop Pounds per hour allowed was calculated using the required collection efficiency necessary to remain a nonmajor source under 40 CFR and 40 CFR If the performance testing at GP 003 demonstrates compliance with the permit limits, daily pressure drop reading will ensure continuous compliance with the permit limits. The control equipment is Listed Control Equipment under Minn. R with the efficiency specified in the rule. The MPCA generally does not require testing unless a higher efficiency is needed to meet permit limits. The permit contains requirements for proper operation and maintenance of the control equipment. If the control equipment is properly operated and maintained there is a reasonable assurance that the control equipment will achieve the listed efficiency. This is less restrictive than the collection efficiency required by the control equipment rule, and is easily met by a properly maintained fabric filter. The May 1, 2012 Performance Test resulted in: < 0.4% Opacity (8% of most restrictive limit) If any visible emissions are detected, corrective action is to be taken. This is less restrictive than the collection efficiency required by the control equipment rule, and is easily met by a properly maintained fabric filter. Technical Support Document, Permit Action Number: Page 8 of 13

56 Subject Item Requirement (rule basis) Monitoring Discussion readings and > collection recordkeeping, O&M, efficiency periodic inspections, io > 93% collection efficiency corrective actions (CE030) (Minn. R (G)) The control equipment is Listed Control Equipment under Minn. R with the efficiency specified in the rule. Control from CE 030 is not needed to meet any applicable requirement; therefore performance testing is not required. The permit contains requirements for proper operation and maintenance of the control equipment. If the control equipment is properly operated and maintained there is a reasonable assurance that the control equipment will achieve the listed efficiency. 2.5 > 93% collection efficiency (Minn. R (G)) 2. 5 emissions are conservatively estimated as 10 emissions. Based on the type of operation, there is not expected to be condensable. Because the control equipment is Listed Control Equipment under Minn. R with 10 control efficiency listed in the rule, no testing is required. The permit contains requirements for proper operation and maintenance of the control equipment. If the control equipment is properly operated and maintained there is a reasonable assurance that the control equipment will achieve the listed efficiency. Opacity: <5% from fugitive emissions (Minn. R , subp. 3(A)) None Capture efficiency of the control device is % (total enclosure); there are not expected to be fugitive emissions Opacity: < 10% from each stack Daily visible emission checks (GP001) If any visible emissions are detected, corrective action is to be taken. (Minn. R , subp. 3(D)) EU 006 (Grain Handling) >80% collection efficiency (Minn. R , subp.3(e)) > collection efficiency io > 93% collection efficiency (Limit to avoid PSD and Part 70) Daily visible emissions checks and recordkeeping or daily pressure drop readings and recordkeeping, O&M, periodic inspections, corrective actions (GP001) This is less restrictive than the collection efficiency required by the control equipment rule, and is easily met by a properly maintained fabric filter. The control equipment is Listed Control Equipment under Minn. R with the efficiency specified in the rule. The MPCA generally does not require testing unless a higher efficiency is needed to meet permit limits. The permit contains requirements for proper operation and maintenance of the control equipment. If the control equipment is properly operated and maintained there is a reasonable assurance that the control equipment will achieve the listed efficiency. Technical Support Document, Permit Action Number: Page 9 of 13

57 ' Subject Item Requirement (rule basis) Monitoring Discussion 2.S > 93% collection efficiency (Limit to avoid PSD and Part 70) 2I5 emissions are conservatively estimated as 10 emissions. Based on the type of operation, there is not expected to be condensable. Because the control equipment is Listed Control Equipment under Minn. R with 10 control efficiency listed in the rule, no testing is required. The permit contains requirements for proper operation and maintenance of the control equipment. If the control equipment is properly operated and maintained there is a reasonable assurance that the control equipment will achieve the listed efficiency. Opacity: < 5% from fugitive emissions (Minn. R , subp. 3(A)) None Capture efficiency of the control device is % (total enclosure); there are not expected to be fugitive emissions Opacity: < 10% from each stack Daily visible emission checks (GP001) If any visible emissions are detected, corrective action is to be taken. (Minn. R , subp. 3(D)) >80% collection efficiency (Minn. R , subp.3(e)) This is less restrictive than the collection efficiency required by the control equipment rule, and is easily met by a properly maintained fabric filter. EU 007 (Flour Storage and Loading) > collection efficiency 10 > 93% collection efficiency (Limit to avoid PSD and Part 70) 2.5 > 93% collection efficiency (Limit to avoid PSD and Part 70) Daily visible emissions checks and recordkeeping or daily pressure drop readings and recordkeeping, O&M, periodic inspections, corrective actions (GP001) The control equipment is Listed Control Equipment under Minn. R with the efficiency specified in the rule. The MPCA generally does not require testing unless a higher efficiency is needed to meet permit limits. The permit contains requirements for proper operation and maintenance of the control equipment. If the control equipment is properly operated and maintained there is a reasonable assurance that the control equipment will achieve the listed efficiency. 2.5 emissions are conservatively estimated as 10 emissions. Base d on the type of operation, there is not expected to be condensable. Because the control equipment is Listed Control Equipment under Minn. R with 10 control efficiency listed in the rule, no testing is required. The permit contains requirements for proper operation and maintenance of the control equipment. If the control equipment is properly operated and maintained there is a reasonable assurance that the control equipment will achieve the listed efficiency. EU 008 (Pellet Cooling) Process Throughput < 127,590 tpy (Limit to avoid PSD and Part 70) Daily recordkeeping; Monthly calculations and recordkeeping The facility must not handle more than 127,590 tpy of pellets cooled (33% of feed is pelletized) in order to remain a non-major source under 40 CFR and 40 CFR Monthly calculations are adequate to ensure compliance. Technical Support Document, Permit Action Number: Page 10 of 13

58 Subject Item Requirement (rule basis) Monitoring Discussion : Variable with process weight (Minn. R ) Opacity: < 20% opacity (Minn. R ) Proper operation of control equipment - Daily recordkeeping of pressure drop; O&M, periodic inspections; corrective actions (GP002) Controlled emissions based on equipment capacity, published emission factors, and control efficiency allowed under Minn. R are 0.72 Ib/hr, well below the applicable limit. The controlled emission rate (0.72 Ib/hr) is not expected to result in visible emissions of 20%; noncompliance is unlikely. > 80% collection efficiency 10 > 60% collection efficiency (Limit to avoid PSD and Part 70) 2.5 > 60% collection efficiency (Limit to avoid PSD and Part 70) Daily recordkeeping of pressure drop; O&M, periodic inspections; corrective actions The control equipment is Listed Control Equipment under Minn. R with the efficiency specified in the rule. The MPCA generally does not require testing unless a higher efficiency is needed to meet permit limits. The permit contains requirements for proper operation and maintenance of the control equipment. If the control equipment is properly operated and maintained there is a reasonable assurance that the control equipment will achieve the listed efficiency. 2.5 emissions are conservatively estimated as i0 emissions. Based on the type of operation, there is not expected to be condensable. Because the control equipment is Listed Control Equipment under Minn. R with 10 control efficiency listed in the rule, no testing is required. The permit contains requirements for proper operation and maintenance of the control equipment. If the control equipment is properly operated and maintained there is a reasonable assurance that the control equipment will achieve the listed efficiency. EU 009 (Emergency Generator) 40 CFR pt. 63, Subpart ZZZZ Recordkeeping of hours of operation The Permittee must install a non-resettable hour meter and record hours of operation: during emergency operations during non-emergency operations ON MAY 1, 2015, THE D.C. CIRCUIT VACATED THE PROVISIONS OF 40 CFR SECTION (f)(2) THAT ALLOW OPERATION OF AN EMERGENCY GENERATOR WITHOUT EMISSIONS CONTROLS FOR UP TO HOURS PER YEAR AS PART OF AN EMERGENCY DEMAND- RESPONSE PROGRAM. AS OF THE DATE OF ISSUANCE OF AIR EMISSION PERMIT NO , THE COURT HAD NOT ISSUED THE MANDATE IMPLEMENTING ITS DECISION. THESE PROVISIONS REMAIN IN EFFECT UNTIL THE COURT ISSUES THE MANDATE. AFTER THAT ACTION, THE PROVISIONS WILL NO LONGER BE EFFECTIVE. Opacity < 20% Opacity Records of type of fuel used Given the fuel allowed, the unit is highly unlikely to violate the limit. (Minn. R , subp. 1 Technical Support Document, Permit Action Number: Page 11 of 13

59 Subject Item FS 001 (Fugitive HAP Sources) Requirement (rule basis) Monitoring Discussion S0 2 < 0.50 Ibs/mmBtu (Minn.R , subp. 2 HAP-Single < 9.0 tpy HAPs-Total < 20.0 tpy (Limit to avoid Part 70 and NESHAPs) Records of type of fuel used. Monthly calculations and recordkeeping. Based on the capacity of the unit, allowable fuels, and published emission factors, the PTE from this unit is lb S0 2/MMBtu. Given the fuel allowed, the unit is highly unlikely to violate the limit. The greatest potential source of HAP is the methyl bromide used during fumigation, which happens very infrequently, so monthly recordkeeping is adequate. The only other source of HAP at the facility is fuel combustion, with potential total HAP emissions of 0.3 tpy. 3.3 Insignificant Activities The permit is required to include periodic monitoring for all emissions units, including insignificant activities, per EPA guidance. The insignificant activities at this Facility are only subject to general applicable requirements. Using the criteria outlined earlier in this TSD, the following table documents the justification why no additional periodic monitoring is necessary for the insignificant activities affected by this modification. Table 6. Insignificant Activities Insignificant Activity Emissions from a laboratory, as defined in Minn. R , subp. 3(G) General Applicable Emission limit, variable depending on airflow Opacity < 20% (Minn. R /0715) Discussion These are very small, intermittent, bench-top operations that typically do not even have any emissions. It is highly unlikely that they could violate the applicable requirement. 3.4 Permit Organization In general, the permit meets the current guidance for ordering and grouping of requirements. One area where this permit deviates slightly from current guidance is in the use of appendices. While appendices are fully enforceable parts of the permit, in general, any requirement that the MPCA thinks should be electronically tracked (e.g., limits, submittals, etc.), should be in Table A or B of the permit. The main reason is that the appendices are word processing sections and are not part of the electronic tracking system. Violation of the appendices can be enforced, but the computer system will not automatically generate the necessary enforcement notices or documents. Staff must generate these. This permit uses appendices for "Insignificant Activities" (Appendix I) and Applicable Requirements and an "Equipment List" (Appendix II). Another area that deviates from the guidance is in the use of groups where the requirements in the group apply to the members of the group individually. This was done in order to shorten the permit. This is the case for the requirements at GP 001 (Baghouses) and GP 002 (Cyclones). 3.5 Comments Received Public Notice Period: August 7, September 8, 2015 Comments were not received from the public or EPA during the public notice period. One change was made to the permit following public notice. On the cover page of the draft permit, the description "administrative amendment" was changed to "major amendment." The permit action is a major amendment. It stated "major amendment" elsewhere in the draft permit including on the cover page, it was processed as a majo r amendment including public notice, and the public notice itself described the permit action as a major amendment. Technical Support Document, Permit Action Number: Page 12 of 13

60 4. Permit Fee Assessment The permit action includes a Reopening, which is not a chargeable activity, and one permit application received after the effective date of the rule (July 1, 2009). No additional points were assessed. 5. Conclusion Based on the information provided by Ardent Mills Flour Mill, the MPCA has reasonable assurance that the proposed operation of the emission facility, as described in the Air Emission Permit No and this TSD, will not cause or contribute to a violation of applicable federal regulations and Minnesota Rules. Staff Members on Permit Team: Jessica Forsberg/Toni Volkmeier (permit engineers) Brent Rohne (enforcement) Kelsey Suddard (peer reviewer) Beckie Olson (permit writing assistant) Laurie O'Brien (administrative support) AQ File No. 543A; DQ4781 Attachments: 1. Facility Description and CD-01 Forms 2. Calculations Technical Support Document, Permit Action Number: Page 13 of 13

61 Attachment 1 - Facility Description

62 MINNESOTA POLLUTION CONTROL AGENCY AIR QUALITY 520 LAFAYETTE ROAD ST. PAUL, MN May, :49 FACILITY DESCRIPTION: EMISSION UNIT (EU) Show: Active and Pending Records Action: PER 004 AQD Facility ID: Facility Name: Ardent Mills Flour Mill ID No. Emission Unit Status Added By (Action) Retired By (Action) Insignificant Activity Operator ID for Item Stack/ Vent ID No(s). Control Equip. ID No(s). Operator Description Manufacturer Model Number SIC Max. Design Capacity Materials Ma ximum D 3sign Ca pacity Units n Units d Max Fuel Input (mil Btu) 1 EU 001 Active PER 001 i SV 023 (M) Boiler C!eaver Brooks CB Heat Mmbtu Hr EU 001 Active PER 004 SV 023 (M) Boiler Cleaver Brooks CB Heat Mmbtu Hr EU 002 Active PER 001 n SV 001 (M) CE 001 Grain Receiving various various Ton Hr 4 EU 002 Active PER 004 CJ SV 001 (M) CE 001 Grain Receiving - Loading-Unloading Equipment various various Ton Hr 5 EU 003 Active PER 001 SV 003 (P) SV 004 (P) SV 005 (P) SV 006 (P) SV 007 (P) SV 008 (P) SV 009(P) SV010 (P) SV 013 (P) 6 EU 003 Active PER 004 SV 003 (P) SV 004 (P) SV 005 (P) SV 006 (P) SV 007 (P) SV 008(P) SV 009 (P) SV010(P) SV 013 (P) 7 EU 004 Active PER 003 I i SV011 (P) SV 012(P) SV 015 (P) CE 003 CE 004 CE 005 CE 006 CE 007 CE 008 CE 009 CE 010 CE 035 CE 003 CE 004 CE 005 CE 006 CE 007 CE 008 CE 009 CE 010 CE 035 CE 011 CE 012 CE 014 CE 015 CE 016 CE 017 CE 018 CE 019 CE 020 CE 021 CE 022 CE 023 CE 024 CE 037 CE 038 CE 039 CE 040 Grain Cleaning various various Ton Hr Grain Cleaning - Cleaning Equipment various various Ton Hr Milling various various Ton Hr Page 1 of 2 (a)

63 22 May, :49 FACILITY DESCRIPTION: EMISSION UNIT (EU) ID No. Emission Added Comm Initial Removal Firing Method Pet. Bottleneck Elevator Unit By ence Startup Date Fuel/ Type Status (Action) Const. Date Space Date Heat 1 EU 001 Active PER /08/ /08/ EU 001 Active PER /08/ /08/ EU 002 Active PER /01/ /01/ EU 002 Active PER /01/ /01/ EU 003 Active PER /01/ /01/ EU 003 Active PER /01/ /01/ " EU 004 Active PER /01/ /01/1950 Page 1 of 2 (b)

64 MINNESOTA POLLUTION CONTROL AGENCY AIR QUALITY 520 LAFAYETTE ROAD ST PAUL. MN May :49 FACILITY DESCRIPTION: EMISSION UNIT (EU) Show: Action: PER 004 AQD Facility ID: Facility Name: Active and Pending Records Ardent Mills Flour Mill ID No. Emission Unit Status Added By (Action) Retired By (Action) Insignificant Activity Operator ID for Item Stack/ Vent ID No(s). Control Equip. ID No(s). Operator Description Manufacturer Model Number SIC Max. Design Capacity Materials Ma ximum D 5$ign Ca pacity Units n Units d Max Fuel Input (mil Btu) 8 EU 004 Active PER 004 SV011 (P) SV 012 (P) SV 015 (P) CE 011 CE 012 CE 014 CE 015 CE 016 CE 017 CE 018 CE 019 CE 020 CE 021 CE 022 CE 023 CE 024 CE 037 CE 038 CE 039 CE 040 Milling - Milling Equipment various various Ton Hr 9 EU 005 Active PER 001 SV 016 (M) CE 030 Feed Loadout various various Ton Hr 10 EU 005 Active PER 004 L_J SV 016 (M) CE 030 Feed Loadout - Loading-Unloading Equipment various various Ton Hr 11 EU 006 Active PER 001 j ^ SV 002 (M) CE 002 Grain Handling various various Ton Hr 12 EU 006 Active PER 004 Lj 13 EU 007 Active PER 003! ; SV 017 (P) SV 018 (P) SV 019 (P) SV 020 (P) SV 021 (P) SV 022(P) SV 024 (P) 14 EU 007 Active PER 004 j j SV 017(P) SV 018(P) SV 019(P) SV 020 (P) SV 021 (P) SV 022 (P) SV 024 (P) SV 002 (M) CE 002 Grain Handling - Material Handling Equipment CE 026 CE 027 CE 028 CE 029 CE 033 CE 034 CE 036 CE 026 CE 027 CE 028 CE 029 CE 033 CE 034 CE EU 008 Active PER 001 i SV 014 (M) CE 031 CE EU 008 Active PER 004 SV 014 (M) CE 031 CE 032 various various Ton Hr Flour Storage and Loading various various Ton Hr Flour Storage and Loading - Loading-Unloading Equipment various various Ton Hr Pellet Cooling various various Ton Hr Pellet Cooling - Cooler various various Ton Hr 17 EU 009 Active PER 004 SV 025 (M) Emergency Generator Cummins Energy BHp Page 2 of 2 (a)

65 22 May, :49 FACILITY DESCRIPTION: EMISSION UNIT (EU) ID No. Emission Unit Status Added By (Action) Commence Const. Date initial Startup Date Removal Date Firing Method Pet. Fuel/ Space Heat Bottleneck Elevator Type 8 EU 004 Active PER /01/ /01/ EU 005 Active PER /01/ /01/ EU 005 Active PER /01/ /01/ EU 006 Active PER /01/ /01/ EU 006 Active PER /01/ /01/ EU 007 Active PER /01/ /01/ EU 007 Active PER /01/ /01/ EU 008 Active PER /01/ /01/ EU 008 Active PER /01/ /01/ EU 009 Active PER 004 Page 2 of 2 (b)

66 MINNESOTA POLLUTION CONTROL AGENCY AIR QUALITY 520 LAFAYETTE ROAD ST. PAUL. MN June, :12 FACILITY DESCRIPTION: CONTROL EQUIENT (CE) Show: Pending Records Only Action: PER 004 AQD Facility ID: Facility Name: Ardent Mills Flour Mill ID No. Control Equip. Status Added By (Action) Retired By (Action) Operator ID for Item Control Equip. Type Control Equipment Description Manufacturer Model Pollutants Controlled Capture Efficiency (%) Destruction/ Collection Efficiency (%) Afterburner Combustion Parameters 1 CE 001 Active PER Fabric Filter- Low Temperature, i.e., T<180 Degrees F Buhler ASF-64/ CE 002 Active PER Fabric Filter- Low Temperature, i.e., T<180 Degrees F Buhler-Maig PRF-120/ CE 003 Active PER Fabric Filter - Low Temperature, i.e., T<180 Degrees F Micro-Pulsair 80G CE 004 Active PER Fabric Filter - Low Temperature, i.e., T<180 Degrees F Micro-Pulsair 1F1-48C CE 005 Active PER Fabric Filter - Low Temperature, i.e., T<180 Degrees F Micro-Pulsair 1F1-48C CE 006 Active PER Fabric Filter - Low Temperature, i.e., T<180 Degrees F Micro-Pulsair 1F1-48C CE 007 Active PER Fabric Filter- Low Temperature, i.e., T<180 Degrees F Micro-Pulsair 1F1-48C CE 008 Active PER Fabric Filter - Low Temperature, i.e., T<180 Degrees F Micro-Pulsair 1F1-48C CE 009 Active PER Fabric Filter- Low Temperature, i.e., T<180 Degrees F Micro-Pulsair 1F1-48C % 80 % 80 % % % % % % % % % % % % % % % % Page 1 of 5

67 MINNESOTA POLLUTION CONTROL AGENCY AIR QUALITY 520 LAFAYETTE ROAD ST. PAUL, MN June, :12 FACILITY DESCRIPTION: CONTROL EQUIENT (CE) Show: Pending Records Only Action: PER 004 AQD Facility ID: Facility Name: Ardent Mills Flour Mill ID No. Control Equip. Status Added By (Action) Retired By (Action) Operator ID for Item Control Equip. Type Control Equipment Description Manufacturer Model Pollutants Controlled Capture Efficiency (%) Destruction/ Collection Efficiency (%) Afterburner Combustion Parameters 10 CE 010 Active PER Fabric Filter - Low Temperature, i.e., T<180 Degrees F Micro-Pulsair 1F1-48C ^ 11 CE 011 Active PER Fabric Filter - Low Temperature, i.e., T<180 Degrees F Kice M CE 012 Active PER Fabric Filter- Low Temperature, i.e., T<180 Degrees F Kice M CE 014 Active PER Fabric Filter- Low Temperature, i.e., T<180 Degrees F Micro-Puisair 1F CE 015 Active PER Fabric Filter- Low Temperature, i.e., T<180 Degrees F Micro-Pulsair 1F CE 016 Active PER Fabric Filter - Low Temperature, i.e., T<180 Degrees F Micro-Pulsair 1C CE 017 Active PER Fabric Filter - Low Temperature, i.e., T<180 Degrees F Micro-Pulsair 1F CE 018 Active PER Fabric Filter- Low Temperature, i.e., T<180 Degrees F Micro-Pulsair 1F CE 019 Active PER Fabric Filter - Low Temperature, i.e., T<180 Degrees F Micro-Pulsair 1F % % % % % % % % % % % % % % % % % % Page 2 of 5

68 MINNESOTA POLLUTION CONTROL AGENCY AIR QUALITY 520 LAFAYETTE ROAD ST.PAUL, MN June, :12 FACILITY DESCRIPTION: CONTROL EQUIENT (CE) Show: Pending Records Only Action: PER 004 AQD Facility ID: Facility Name: Ardent Mills Flour Mill ID No. Control Equip. Status Added By (Action) Retired By (Action) Operator ID for Item Control Equip. Type Control Equipment Description Manufacturer Model Pollutants Controlled Capture Efficiency (%) Destruction/ Collection Efficiency (%) Afterburner Combustion Parameters 19 CE 020 Active PER Fabric Filter- Low Temperature, i.e., T<180 Degrees F Micro-Pulsair 2G CE 021 Active PER Fabric Filter- Low Temperature, i.e., T<180 Degrees F Donaldson/Day 36-PJD CE 022 Active PER Fabric Filter- Low Temperature, i.e., T<180 Degrees F Micro-Pulsair 1F CE 023 Active PER Fabric Filter- Low Temperature, i.e., T<180 Degrees F Micro-Pulsair 1F CE 024 Active PER Fabric Filter- Low Temperature, i.e., T<180 Degrees F Micro-Pulsair 1F CE 026 Active PER Fabric Filter- Low Temperature, i.e., T<180 Degrees F Kice unknown CE 027 Active PER Fabric Filter - Low Temperature, i.e.. T<180 Degrees F Kice unknown CE 028 Active PER Fabric Filter- Low Temperature, i.e., T<180 Degrees F Micro-Pulsair 80F CE 029 Active PER Fabric Filter- Low Temperature, i.e., T<180 Degrees F Micro-Pulsair 36S % % % % % % % % % % % % % % % % % % Page 3 of 5

69 MINNESOTA POLLUTION CONTROL AGENCY AIR QUALITY 520 LAFAYETTE ROAD ST PAUL, MN June, :12 FACILITY DESCRIPTION: CONTROL EQUIENT (CE) Show: Pending Records Only Action: PER 004 AQD Facility ID: Facility Name: Ardent Mills Flour Mill ID No. Control Equip. Status Added By (Action) Retired By (Action) Operator ID for Item Control Equip. Type Control Equipment Description Manufacturer Mode! Pollutants Controlled Capture Efficiency (%) Destruction/ Collection Efficiency (%) Afterburner Combustion Parameters 28 CE 030 Active PER Fabric Filter - Low Temperature, i.e., T<180 Degrees F Micro-Pulsair 36S CE 031 Active PER Centrifugal Collector - Medium Efficiency Buhler PDA CE 032 Active PER Centrifugal Collector - Medium Efficiency Buhler PDAZ CE 033 Active PER Fabric Filter - Low Temperature, i.e., T<180 Degrees F Northern Blower CE 034 Active PER Fabric Filter - Low Temperature, i.e.. T<180 Degrees F Kice VS CE 035 Active PER Fabric Filter- Low Temperature, i.e., T<180 Degrees F unknown unknown CE 036 Active PER Fabric Filter - Low Temperature, i.e., T<180 Degrees F Buhler unknown CE 037 Active PER 004 WW 018 Fabric Filter - Low Temperature, i.e., T<180 Degrees F Kice M CE 038 Active PER 004 B Pur 018 Fabric Filter- Low Temperature, i.e., T<180 Degrees F Kice M % 60 80% 60 % % % % 10)% % % % % % % % % % % % % 60 50% % 60 50% Page 4 of 5

70 MINNESOTA POLLUTION CONTROL AGENCY AIR QUALITY 520 LAFAYETTE ROAD ST. PAUL, MN June, :12 FACILITY DESCRIPTION: CONTROL EQUIENT (CE) Show: Pending Records Only Action: PER 004 AQD Facility ID: Facility Name: Ardent Mills Flour Mill ID No. Control Equip. Status Added By (Action) Retired By (Action) Operator ID for Item Control Equip. Type Control Equipment Description Manufacturer Model Pollutants Controlled Capture Efficiency (%) Destruction/ Collection Efficiency (%) Afterburner Combustion Parameters 37 CE 039 Active PER 004 Rye 018 Fabric Filter - Low Temperature, i.e., T<180 Degrees F Kice M % % CE 040 Active PER 004 A Pur 018 Fabric Filter - Low Temperature, i.e., T<180 Degrees F Kice M % % Page 5 of 5

71 MINNESOTA POLLUTION CONTROL AGENCY AIR QUALITY 520 LAFAYETTE ROAD ST. PAUL. MN May, :48 FACILITY DESCRIPTION: STACK/VENTS (SV) Show: Active and Pending Records Action: PER 004 AQD Facility ID: Facility Name: Ardent Mills Flour Mill ID No. Stack/ Vent Status Added By (Action) Retired By (Action) Operator ID for Item Operators Description Height of Opening From Ground (feet) Inside Dimensions Diameter or Length (feet) Width (feet) Design Flow Rate at Top (ACFM) Exit Gas Temperature at Top ( F) Flow Rate/ Temperature Information Source Discharge Direction 1 SV 001 Active PER 001 SV1 Receiving Exhaust Estimate Up, No Cap 2 SV 002 Active PER 001 SV2 Grain Handling Exhaust Estimate Down 3 SV 003 Active PER 001 SV3 Cleaning Exhaust Estimate Horizontal 4 SV 004 Active PER 001 SV4 Cleaning Exhaust Estimate Horizontal 5 SV 005 Active PER 001 SV5 Cleaning Exhaust Estimate Horizontal 6 SV 006 Active PER 001 SV6 Cleaning Exhaust Estimate Horizontal 7 SV 007 Active PER 001 SV7 Cleaning Exhaust Estimate Horizontal 8 SV 008 Active PER 001 SV8 Cleaning Exhaust Estimate Horizontal 9 SV 009 Active PER 001 SV9 Cleaning Exhaust Estimate Horizontal 10 SV010 Active PER 001 SV10 Cleaning Exhaust Estimate Horizontal 11 SV 011 Active PER 001 SV11 Milling Exhaust Estimate Horizontal 12 SV 012 Active PER 001 SV12 Milling Exhaust Estimate Horizontal 13 SV 013 Active PER 001 SV35 Cleaning Exhaust Estimate Horizontal 14 SV 014 Active PER 001 SV31 Pellet Cooling Exhaust Estimate Up, No Cap 15 SV 015 Active PER 001 SV15 Milling Exhaust Esti mate Horizontal 16 SV 016 Active PER 001 SV30 Feed Loadout Estimate Horizontal 17 SV 017 Active PER 001 SV26 Storage/Loadout Exhaust Estimate Horizontal 18 SV 018 Active PER 001 SV27 Storage/Loadout Exhaust Estimate Horizontal 19 SV 019 Active PER 001 SV28 Storage/Loadout Exhaust Estimate Horizontal 20 SV 020 Active PER 001 SV29 Storage/Loadout Exhaust Estimate Horizontal 21 SV 021 Active PER 001 SV33 Storage/Loadout Exhaust Estimate Horizontal 22 SV 022 Active PER 001 SV36 Storage/Loadout Exhaust Estimate Horizontal 23 SV 023 Active PER 001 SV34 Boiler Exhaust Estimate Up, No Cap 24 SV 024 Active PER 003 SV24 Storage/Loadout Exhaust Estimate Horizontal 25 SV 025 Active PER 004 Emergency Generator Page 1 of 1

72 MINNESOTA POLLUTION CONTROL AGENCY AIR QUALITY 520 LAFAYETTE ROAD ST PAUL. MN May, :50 FACILITY DESCRIPTION: FUGITIVE SOURCES (FS) Show: Active and Pending Records Action: PER 004 AQD Facility ID: Facility Name: Ardent Mills Flour Mill ID No. Fugitive Source Status Added By (Action) Retired By (Action) Insignificant Activity Operator ID for Item Pollutant(s) Emitted Control Equip. ID No(s). Fugitive Source Description Year Installed Year Removed 1 FS 001 Active PER 001 VOC Sing hap HAPs Bromometha Fugitive HAP Sources (Fumigation, Preservation, etc.) Page 1 of 1

73 MINNESOTA POLLUTION CONTROL AGENCY AIR QUALITY 520 LAFAYETTE ROAD ST PAUL, MN June, :38 FACILITY DESCRIPTION: GROUPS (GP) Show: Active and Pending Records Action: PER 004 AQD Facility ID: Facility Name: Ardent Mills Flour Mill ID No. Group Status Added By (Action) Retired By (Action) Include in El Operator ID for Item Group Description Group Items 1 GP 001 Active PER 003 r Baghouses CE 001, CE 002, CE 003, CE 004, CE 005, CE 006, CE 007, CE 008, CE 009, CE 010, CE 011. CE 012, CE 014, CE 015, CE 016, CE 017, CE 018, CE 019, CE 020, CE 021, CE 022, CE 023, CE 024, CE 026, CE 027, CE 028, CE 029, CE 030, CE 033, CE 034, CE 035, CE 036, CE 037, CE 038, CE 039, CE GP 001 Active PER 004 r Baghouses CE 001, CE 002, CE 003, CE 004, CE 005, CE 006, CE 007, CE 008, CE 009, CE 010, CE 011. CE 012, CE 014, CE 015, CE 016, CE 017, CE 018, CE 019, CE 020, CE 021, CE 022. CE 023, CE 024, CE 026, CE 027, CE 028, CE 029, CE 033, CE 034, CE 035, CE 036, CE 037, CE 038, CE 039, CE GP 002 Active PER 001 t i Cyclones CE 031, CE GP 003 Active PER 001 r 5 GP 003 Active PER 004 p 10 and 2.5 Limits SV011, SV012, SV GP 004 Active PER 004 } ) Loadout EU 005, EU 007 Page 1 of 1

74 Facility Name: Permit Number: MINNESOTA POLLUTION CONTROL AGENCY AIR QUALITY 520 LAFAYETTE ROAD ST. PAUL, MN Ardent Mills Flour Mill Page 1 of Jut, :28 COMPLIANCE PLAN CD-01 Subject Item: Total Facility NC/ CA Type Citation Requirement 1.0 CD hdr FACILITY-SPECIFIC REQUIREMENTS 2.0 CD Title I Condition: Avoid major source under 40 CFR (b)(1)(i) and Minn. R ; Avoid major source under 40 CFR 70.2 and Minn. R This permit establishes limits on the facility to keep it a m inor source under New Source Review and a nonmajor source under Part 70. The Permittee may not make any change at the source that would make the source a major source under New Source Review or Part 70 until a permit amendment has been issued. This includes changes that might otherwise qualify as insignificant modifications and minor or moderate amendments. 3.0 CD Minn. R , subp. 2 Permit Appendix: This permit contains a appendices as listed in the permit Table of Contents. The Permittee shall comply with all requirements contained in the appendices. 4.0 CD hdr OPERATIONAL REQUIREMENTS 5.0 CD Minn. R Circumvention: Do not install or use a device or means that conceals or dilutes emissions, which would otherwise violate a federal or state air pollution control rule, without reducing the total amount of pollutant emitted. 6.0 CD Minn. R , subp. 2; Minn. R , subp. 16(J) 7.0 CD Minn. R , subps. 14 and 16( J) Air Pollution Control Equipment: Operate all pollution control equipment whenever the corresponding process equipment and emission units are operated. Operation and Maintenance Plan: Retain at the stationary source an operation and maintenance plan for all air pollution control equipment. At a minimum, the O & M plan shall identify all air pollution control equipment and control practices and shall include a preventative maintenance program for the equipment and practices, a description of (the minimum but not necessarily the only) corrective actions to be taken to restore the equipment and practices to proper operation to meet applicable permit conditions, a description of the employee training program for proper operation and maintenance of the control equipment and practices, and the records kept to demonstrate plan implementation. 8.0 CD Minn. R , subp. 4 Operation Changes: In any shutdown, breakdown, or deviation the Permittee shall immediately take all practical steps to modify operations to reduce the emission of any regulated air pollutant. The Commissioner may require feasible and practical modifications in the operation to reduce emissions of air pollutants. No emissions units that have an unreasonable shutdown or breakdown frequency of process or control equipment shall be permitted to operate. 9.0 CD Minn. R Fugitive Emissions: Do not cause or permit the handling, use, transporting, or storage of any material in a manner which may allow avoidable amounts of particulate matter to become airborne. Comply with all other requirements listed in Minn. R CD Minn. R Noise: The Permittee shall comply with the noise standards set forth in Minn. R to at all times during the operation of any emission units. This is a state only requirement and is not enforceable by the EPA Administrator or citizens under the Clean Air Act CD Minn. R , subp. 9(A) Inspections: The Permittee shall comply with the inspection procedures and requirements as found in Minn. R , subp. 9(A) CD Minn. R , subp. 16 The Permittee shall comply with the General Conditions listed in Minn. R , subp CD hdr PERFORMANCE TESTING 14.0 CD Minn. R. ch Performance Testing: Conduct all performance tests in accordance with Minn. R. ch unless otherwise noted in Tables A, B, and/or C.

75 Facility Name: MINNESOTA POLLUTION CONTROL AGENCY AIR QUALITY 520 LAFAYETTE ROA D ST. PAUL, MN Ardent Mills Flour Mill Permit Number: CD Minn. R ; Minn. R , subps. 1-4, Minn. R , subps. 1-2 Page 2 of Jul, :28 Performance Test Notifications and Submittals: COMPLIANCE PLAN CD-01 Performance Tests are due as outlined in Table A of the permit. See Table B for additional testing requirements. Performance Test Notification (written): due 30 days before each Performance Test Performance Test Plan: due 30 days before each Performance Test Performance Test Pre-test Meeting: due 7 days before each Performance Test Performance Test Report: due 45 days after each Performance Test Performance Test Report - Microfiche Copy: due 105 days after each Performance Test The Notification, Test Plan, and Test Report may be submitted in an alternative format as allowed by Minn. R CD Minn. R , subp. 3 Limits set as a result of a performance test (conducted before or after permit issuance) apply until superseded as stated in the MPCA's Notice of Compliance letter granting preliminary approval. Preliminary approval is based on formal review of a subsequent performance test on the same unit as specified by Minn. R , subp. 3. The limit is final upon issuance of a permit amendment incorporating the change CD hdr MONITORING REQUIREMENTS 18.0 CD Minn. R , subp. 4(D) Monitoring Equipment Calibration - The Permittee shall either: 1. Calibrate or replace required monitoring equipment every 12 months; or 2. Calibrate at the frequency stated in the manufa cturer's specifications. For each monitor, the Permittee shall maintain a record of all calibrations, including the date conducted, and any corrective action that resulted. The Permittee shall include the calibration frequencies, procedures, and manufacturer's specifications (if applicable) in the Operations and Maintenance Plan. Any requirements applying to continuous emission monitors are listed separately in this permit CD Minn. R , subp. 4(D) Operation of Monitoring Equipment: Unless otherwise noted in Tables A, B, and/or C, monitoring a process or control equipment connected to that process is not necessary during periods when the process is shutdown, or during checks of the monitoring systems, such as calibration checks and zero and span adjustments. If monitoring records are required, they should reflect any such periods of process shutdown or checks of the monitoring system CD hdr RECORDKEEPING 21.0 CD Minn. R , subp. 5(C) Recordkeeping: Retain all records at the stationary source, unless otherwise specified within this permit, from the date of monitoring, sample, measurement, or report. Records which must be retained at this location include all calibration and maintenance records, all original recordings for continuous monitoring instrumentation, and copies of all reports required by the permit. Records must conform to the requirements listed in Minn. R , subp. 5(A) CD Minn. R , subp. 5(B) Recordkeeping: Maintain records describing any insignificant modifications (as required by Minn. R , subp. 3) or changes contravening permit terms (as required by Minn. R , subp. 2), including records of the emissions resulting from those changes CD Minn. R , subp. 4 If the Permittee determines that no permit amendment or notification is required prior to making a change, the Permittee must retain records of all calculations required under Minn. R For nonexpiring permits, these records shall be kept for a period of five years from the date that the change was made. The records shall be kept at the stationary source for the current calendar year of operation and may be kept at the stationary source or office of the stationary source for all other years. The records may be maintained in either electronic or paper format CD hdr REPORTING/SUBMiTTALS

76 Facility Name: MINNESOTA POLLUTION CONTROL AGENCY Page 3 of Jul, :28 AIR QUALITY 520 LAFAYETTE ROAD COMPLIANCE PLAN CD-01 Ardent Mills Flour Mill Permit Number: CD Minn. R , subp. 3 Shutdown Notifications: Notify the Commissioner at least 24 hours in advance of a planned shutdown of any control equipment or process equipment if the shutdown would cause any increase in the emissions of any regulated air pollutant. If the owner or operator does not have advance knowledge of the shutdown, notification shall be made to the Commissioner as soon as possible after the shutdown. However, notification is not required in the circumstances outlined in Items A, B and C of Minn. R , subp. 3. At the time of notification, the owner or operator shall inform the Commissioner of the cause of the shutdown and the estimated duration. The owner or operator shall notify the Commissioner when the shutdown is over CD Minn. R , subp. 2 Breakdown Notifications: Notify the Commissioner within 24 hours of a breakdown of more than one hour duration of any control equipment or process equipment if the breakdown causes any increase in the emissions of any regulated air pollutant. The 24-hour time period starts when the breakdown was discovered or reasonably should have been discovered by the owner or operator. However, notification is not required in the circumstances outlined in Items A, B and C of Minn. R , subp. 2. At the time of notification or as soon as possible thereafter, the owner or operator shall inform the Commissioner of the cause of the breakdown and the estimated duration. The owner or operator shall notify the Commissioner when the breakdown is over CD Minn. R , subp. 1 Notification of Deviations Endangering Human Health or the Environment: As soon as possible after discovery, notify the Commissioner or the state duty officer, either orally or by facsimile, of any deviation from permit conditions which could endanger human health or the environment CD Minn. R , subp. 1 Notification of Deviations Endangering Human Health or the Environment Report: Within 2 working days of discovery, notify the Commissioner in writing of any deviation from permit conditions which could endanger human health or the environment. Include the following information in this written description: 1. the cause of the deviation; 2. the exact dates of the period of the deviation, if the deviation has been corrected: 3. whether or not the deviation has been corrected; 4. the anticipated time by which the deviation is expected to be corrected, if not yet corrected; and 5. steps taken or planned to reduce, eliminate, and prevent reoccurrence of the deviation S/A Minn. R , subp. 6(A)(2) Semiannual Deviations Report: due 30 days after end of each calendar half-year starting 12/09/2002. The first semiannual report submitted by the Permittee shall cover the calendar half-year in which the permit is issued. The first report of each calendar year covers January 1 - June 30. The second report of each calendar year covers July 1 - December 31. If no deviations have occurred, the Permittee shall submit the report stating no deviations CD Minn. R Application for Permit Amendment: If a permit amendment is needed, submit an application in accordance with the requirements of Minn. R through Minn. R Submittal dates vary, depending on the type of amendment needed. Upon adoption of a new or amended federal applicable requirement, and if there are more than 3 years remaining in the permit term, the Permittee shall file an application for an amendment within nine months of promulgation of the applicable requirement, pursuant to Minn. R , subp CD Minn. R , subp. 1(H) Extension Requests: The Permittee may apply for an Administrative Amendment to extend a deadline in a permit by no more than 120 days, provided the proposed deadline extension meets the requirements of Minn. R , subp. 1 (H). Performance testing deadlines from the General Provisions of 40 CFR pt. 60 and pt. 63 are examples of deadlines for which the MPCA does not have authority to grant extensions and therefore do not meet the requirements of Minn. R , subp. 1(H) S/A Minn. R , subp. 6(C) Compliance Certification: due 31 days after end of each calendar year starting 12/09/2002 (for the previous calendar year). The Permittee shall submit this to the Commissioner on a form approved by the Commissioner. This report covers all deviations experienced during the calendar year CD Minn. R Emission Inventory Report: due on or before April 1 of each calendar year following permit issuance, to be submitted on a form approved by the Commissioner CD Minn. R Emission Fees: due 30 days after receipt of an MPCA bill.

77 Facility Name: Permit Number: MINNESOTA POLLUTION CONTROL AGENCY AIR QUALITY 520 LAFAYETTE ROAD ST. PAUL, MN Ardent Mills Flour Mill Page 4 of Jul, :28 COMPLIANCE PLAN CD CD 40 CFR pt. 68 The Permittee must submit a Risk Management Plan (RMP) under 40 CFR pt. 68. Each owner or operator of a stationary source, at which a regulated substance is present above a threshold quantity in a process, shall design and implement an accidental release prevention program. An initial RMP must be submitted no later than the latest of the following dates: 1) June 21,1999; 2) Three years after the date on which a regulated substance is first listed under 40 CFR Section ; or 3) The date on which a regulated substance is first present above a threshold quantity in a process. A full update and resubmission of the RMP is required at least once every five years. The five-year anniversary date is reset whenever your facility fully updates and resubmits their RMP. Submit RMPs to the Risk Management Plan Reporting Center, P.O. Box 1515, Lanham-Seabrook, Maryland RMP information may be obtained at or by calling S/A Minn. R , subp. 2 Annual Report: due 90 days after end of each calendar year starting 12/09/2002. The Permittee shall submit an annual report by April 1 that describes the changes made at the facility during the previous calendar year. The report whall include a copy of all Equipment Lists, and shall document any equipment changes that took place during the previous calendar year, and any applicable New Source Performance Standards or NESHAPs that became effective during the previous calendar year. This report may be submitted with the annual emissions inventory, but it shall be a separate document marked as the "Annual Report." As part of the Annual Report, the Permittee shall verify and certify that the facility has maintained minor source status for New Source Review and Part 70, and has maintained area source status under the NESHAP program.

78 MINNESOTA POLLUTION CONTROL AGENCY AIR QUALITY 520 LAFAYETTE ROAD ST. PAUL, MN Page 5 of Jul, :28 COMPLIANCE PLAN CD-01 Facility Name: Permit Number: Subject Item: Associated Items: Ardent Mills Flour Mill GP 001 Baghouses CE 001 Fabric Filter - Low Temperature i.e. T<180 Degrees F CE 002 Fabric Filter - Low Temperature i.e. T<180 Degrees F CE 003 Fabric Filter - Low Temperature i.e. T<180 Degrees F CE 004 Fabric Filter - Low Temperature i.e. T<180 Degrees F CE 005 Fabric Filter - Low Temperature i.e. T<180 Degrees F CE 006 Fabric Filter - Low Temperature i.e. T<180 Degrees F CE 007 Fabric Filter - Low Temperature i.e. T<180 Degrees F CE 008 Fabric Filter - Low Temperature i.e. T<180 Degrees F CE 009 Fabric Filter - Low Temperature i.e. T<180 Degrees F CE 010 Fabric Filter - Low Temperature i.e. T<180 Degrees F CE 011 Fabric Filter - Low Temperature i.e. T<180 Degrees F CE 012 Fabric Filter - Low Temperature i.e. T<180 Degrees F CE 014 Fabric Filter - Low Temperature i.e. T<180 Degrees F CE 015 Fabric Filter - Low Temperature i.e. T<180 Degrees F CE 016 Fabric Filter - Low Temperature i.e. T<180 Degrees F CE 017 Fabric Filter - Low Temperature i.e. T<180 Degrees F CE 018 Fabric Filter - Low Temperature i.e. T<180 Degrees F CE 019 Fabric Filter - Low Temperature i.e. T<180 Degrees F CE 020 Fabric Filter - Low Temperature i.e. T<180 Degrees F CE 021 Fabric Filter - Low Temperature i.e. T<180 Degrees F CE 022 Fabric Filter - Low Temperature i.e. T<180 Degrees F CE 023 Fabric Filter - Low Temperature i.e. T<180 Degrees F CE 024 Fabric Filter - Low Temperature i.e. T<180 Degrees F CE 026 Fabric Filter - Low Temperature i.e. T<180 Degrees F CE 027 Fabric Filter - Low Temperature i.e. T<180 Degrees F CE 028 Fabric Filter - Low Temperature i.e. T<180 Degrees F CE 029 Fabric Filter - Low Temperature i.e. T<180 Degrees F CE 033 Fabric Filter - Low Temperature i.e. T<180 Degrees F CE 034 Fabric Filter - Low Temperature i.e. T<180 Degrees F CE 035 Fabric Filter - Low Temperature i.e. T<180 Degrees F CE 036 Fabric Filter - Low Temperature i.e. T<180 Degrees F CE 037 Fabric Filter - Low Temperature i.e. T<180 Degrees F CE 038 Fabric Filter - Low Temperature i.e. T<180 Degrees F CE 039 Fabric Filter - Low Temperature i.e. T<180 Degrees F CE 040 Fabric Filter - Low Temperature i.e. T<180 Degrees F NC/ CA Type Citation Requirement 1.0 CD Title I Condition: Avoid major source under 40 CFR (b)(1)(i) and Minn. R ; Avoid major source under 40 CFR 70.2 and Minn. R If the Permittee replaces any existing fabric filters, adds new fabric filters, or modifies the fabric filters listed in GP 001, such equipment is subject to all of the requirements of GP 001. Prior to making such a change, the Permittee shall apply for and obtain the appropriate permit amendment, as applicable.

79 Facility Name: Permit Number: MINNESOTA POLLUTION CONTROL AGENCY AIR QUALITY 520 LAFAYETTE ROAD ST. PAUL, MN Ardent Mills Flour Mill Page 6 of Jul, :28 COMPLIANCE PLAN CD CD Minn. R , subps. 4, 5, and LIMIT Title I Condition: Avoid major source under 40 CFR (b)(1)(i) and Minn. R ; Avoid major source under 40 CFR 70.2 and Minn. R CD Title I Condition: Avoid major source under 40 CFR (b)(1)(i) and Minn. R ; Avoid major source under 40 CFR 70.2 and Minn. R CD Title I Condition: Avoid major source under 40 CFR (b)(1)(i) and Minn. R ; Avoid major source under 40 CFR 70.2 and Minn. R ; Minn. R , subps. 4, 5, and CD Minn. R , subps. 4, 5, and CD Minn. R , subps. 4, 5, and 14 The Permittee shall operate and maintain each fabric filter in accordance with the Operation and Maintenance (O & M) Plan. The Permittee shall keep copies of the O & M Plan available onsite for use by staff and MPCA staff. Control efficiency requirements can be found at EU 002 through EU 007. Pressure Drop: greater than or equal to 0.5 inches of water column and less than or equal to 8.0 inches of water column, unless a new range is set pursuant to Minn. R , subp. 3 based on the values recorded during the most recent MPCA : approved performance test where compliance was demonstrated. The new range shall be implemented upon receipt of the Notice of Compliance letter granting preliminary approval. The range is final upon issuance of a permit amendment incorporating the change. Visible Emissions: The Permittee shall check each fabric filter stack for any visible emissions once each day of operation during daylight hours. During inclement weather, the Permittee shall read and record the pressure drop across the fabric filter, once each day of operation. Recordkeeping of Visible Emissions and Pressure Drop. The Permittee shall record the time and date of each visible emission inspection and pressure drop reading, and whether or not any visible emissions were observed, and whether or not the observed pressure drop was within the range specified in this permit Periodic Inspections: At least once per calendar quarter, or more frequently as required by the manufacturing specifications, the Permittee shall inspect the control equipment components. The Permittee shall maintain a written record of these inspections. Corrective Actions: The Permittee shall take corrective action as soon as possible if any of the following occur: - visible emissions are observed; or - the recorded pressure drop is outside the required operating range; or - the fabric filter or any of its components are found during the inspections to need repair. Corrective actions shall eliminate visible emissions, and/or return the pressure drop to within the permitted range, and/or include completion of necessary repairs identified during the inspection, as applicable. Corrective actions include, but are not limited to, those outlined in the O & M Plan for the equipment. The Permittee shall keep a record of the type and date of any corrective action taken. 8.0 CD Minn. R , subp. 4 Monitoring Equipment: The Permittee shall install and maintain the necessary monitoring equipment for measuring and recording pressure drop as required by this permit. The monitoring equipment must be installed, in use, and properly maintained when the monitored fabric filters are in operation.

80 Facility Name: Permit Number: MINNESOTA POLLUTION CONTROL AGENCY AIR QUALITY 520 LAFAYETTE ROAD ST. PAUL, MN Ardent Mills Flour Mill Page 7 of Jul, :28 COMPLIANCE PLAN CD-01 Subject Item: Associated Items: GP 002 Cyclones CE 031 Centrifugal Collector - Medium Efficiency CE 032 Centrifugal Collector - Medium Efficiency NC/ CA Type Citation Requirement 1.0 CD Minn. R , subps. 4-5; Minn. R , subp CD Title I Condition: Avoid major source under 40 CFR (b)(1)(i) and Minn. R ; Avoid major source under 40 CFR 70.2 and Minn. R ; Minn. R , subp. 4, 5, and LIMIT Title I Condition: Avoid major source under 40 CFR (b)(1)(i) and Minn. R ; Avoid major source under 40 CFR 70.2 and Minn. R CD Title I Condition: Avoid major source under 40 CFR (b)(1)(i) and Minn. R ; Avoid major source under 40 CFR 70.2 and Minn. R ; Minn. R , subp. 4, 5, and CD Minn. R , subps. 4-5; Minn. R , subp CD Minn. R , subps. 4-5; Minn. R , subp. 14 The Permittee shall operate and maintain each cyclone in accordance with the Operation and Maintenance (O & M) Plan. The Permittee shall keep copies of the O & M Plan available onsite for use by staff and MPCA staff. Pressure Drop: The Permittee shall read and record the pressure drop across each of the two cyclones listed in GP002, once each day of operation. Pressure Drop: greater than or equal to 4.0 inches of water column and less than or equal to 10.0 inches of water column unless a new range is set pursuant to Minn. R , subp. 3 based on the values recorded during the most recent MPCA-approved performance test where compliance was demonstrated. The new range shall be implemented upon receipt of the Notice of Compliance letter granting preliminary approval. The range is final upon issuance of a permit amendment incorporating the change. Recordkeeping of Pressure Drop. The Permittee shall record the time and date of each pressure drop reading, and whether or not the observed pressure drop was within the range specified in this permit. Periodic Inspections: At least once per calendar quarter, or more frequently as required by the manufacturing specifications, the Permittee shall inspect the control equipment components. The Permittee shall maintain a written record of these inspections. Corrective Actions: The Permittee shall take corrective action as soon as possible if any of the following occur: - the recorded pressure drop is outside the required operating range; or - the cyclone or any of its components are found during the inspections to need repair. Corrective actions shall return the pressure drop to within the permitted range and/or include completion of necessary repairs identified during the inspection, as applicable. Corrective actions include, but are not limited to, those outlined in the O & M Plan for the equipment. The Permittee shall keep a record of the type and date of any corrective action taken. 7.0 CD Minn. R , subp. 4 Monitoring Equipment: The Permittee shall install and maintain the necessary monitoring equipment for measuring and recording pressure drop as required by this permit. The monitoring equipment must be installed, in use, and properly maintained when the monitored cyclone is in operation.

81 Facility Name: Permit Number: MINNESOTA POLLUTION CONTROL AGENCY AIR QUALITY 520 LAFAYETTE ROAD ST. PAUL, MN Ardent Mills Flour Mill Page 8 of Jul, :28 COMPLIANCE PLAN CD-01 Subject Item: Associated Items: GP and 2.5 Limits SV011 Milling Exhaust SV 012 Milling Exhaust SV 015 Milling Exhaust NC/ CA Type Citation Requirement 1.0 LIMIT Title I Condition: Avoid major source under 40 CFR (b)(1)(i) and Minn. R ; Avoid major source under 40 CFR 70.2 and Minn. R LIMIT Title I Condition: Avoid major source under 40 CFR (b)(1)(i) and Minn. R ; Avoid major source under 40 CFR 70.2 and Minn. R < 10 micron: less than or equal to lbs/hour using 3-hour Average. This is a group limit. The sum of the hourly emissions from SV 011, SV 012, and SV 015 shall not exceed pounds per hour. If this limit cannot be met, the Permittee must apply for a Part 70 permit. < 2.5 micron: less than or equal to lbs/hour using 3-hour Average. This is a group limit. The sum of the hourly emissions from SV 011, SV 012, and SV 015 shall not exceed pounds per hour. If this limit cannot be met, the Permittee must apply for a Part 70 permit. 3.0 S/A Minn. R , subp. 1 Initial Performance Test: due 180 days after Permit Issuance to measure 10 emissions from SV011, SV 012, and SV 015. The performance tests shall be conducted at worst case conditions as defined at Minn. R , subp. 8, using EPA Reference Method 5, or other method approved by MPCA in the performance test plan approval. It is assumed that 2.5 emissions do not exceed 10 emissions, therefore a single test for 10 will constitute a test for S/A Minn. R , subp. 1 Testing Frequency Plan: due 60 days after Initial Performance Test for 10 emissions. The plan shall specify a testing frequency based on the test data and MPCA guidance. Future performance tests based on 12-month, 36-month, or 60-month intervals, or as applicable, shall be required upon written approval of the MPCA.

82 Facility Name: Permit Number: MINNESOTA POLLUTION CON TROL AGENCY AIR QUALITY 520 LAFAYETTE ROAD ST. PAUL, MN Ardent Mills Flour Mill Page 9 of Jul, :28 COMPLIANCE PLAN CD-01 Subject Item: Associated Items: EU 001 Boiler SV 023 Boiler Exhaust NC/ CA Type Citation Requirement 1.0 CD Minn. R OPERATING AND RECORDKEEPING REQUIREMENTS 2.0 CD Minn. R , subp. 2 Fuel Use: Limited to natural gas and distillate oil only 3.0 LIMIT 40 CFR Section 60.42c(d); 40 CFR Section 60.42c(h)(1); Minn. R CD 40 CFR Section 60.48c(f)(1); Minn. R CD 40 CFR Section 60.13(i) and February 20, 1992, February 22, 1993, and June 25, 2002 EPA memoranda to meet the requirements of 40 CFR Section 60.48c(g) and (i); Minn. R S/A 40 CFR Section 60.48c(e)(1); 40 CFR Section 60.48c(e)(11); 40 CFR Section 60.48c(f)(1); Minn. R Sulfur Content of Fuel: less than or equal to 0.5 percent by weight, based on certification from fuel supplier. Recordkeeping: For each shipment of fuel oil, the Permittee shall obtain and maintain a copy of the fuel supplier's certification, which shall include the name of the oil supplier, and a statement from the oil supplier that the oil complies with the specifications under the definition of distillate oil in 40 CFR Section 60.41c. Monthly Recordkeeping: Record and maintain records of the amounts of each fuel combusted on a monthly basis. These records may consist of purchase records or receipts. Report: due 30 days after end of each half-year starting 08/08/1994. The repo rt shall be submitted to the U.S. EPA, and shall include the following: - the calendar dates covered in the reporting period - records of fuel oil supplier certifications - certified statement signed by the owner or operator stating that the records of fuel supplier certifications submitted represent all of the fuel oil combusted during the reporting period.

83 MINNESOTA POLLUTION CONTROL AGENCY AIR QUALITY 520 LAFAYETTE ROAD ST. PAUL. MN Page 10 of Jul, :28 COMPLIANCE PLAN CD-01 Facility Name: Ardent Mills Flour Mill Permit Number: Subject Item: Associated Items: EU 002 Grain Receiving - Loading-Unloading Equipment CE 001 Fabric Filter - Low Temperature, i.e., T<180 Degrees F SV 001 Receiving Exhaust NC/ CA Type Citation Requirement 1.0 CD Minn. R EMISSION LIMITS AND OPERATING REQUIREMENTS 2.0 LIMIT Minn. R , subp. 3(D) Opacity: less than or equal to 10 percent opacity from SV LIMIT Minn. R , subp. 3(A) Opacity: less than or equal to 5 percent opacity a discharge of fugitive emissions from a truck unloading station, railcar unloading station, or handling operation. 4.0 LIMIT Title I Condition: Avoid major source under 40 CFR (b)(1)(i) and Minn. R ; Avoid major source under 40 CFR 70.2 and Minn. R Process Throughput: less than or equal to 523,000 tons/year using 12-month Rolling Sum of grain received. 5.0 CD Minn. R , subp. 5 EU002 consists of the components listed in Appendix II to this permit. Any replacement, addition, or modification to the components listed in Appendix II is considered a modification of EU002 for purposes of determining if a permit amendment is required. 6.0 CD Minn. R CONTROL EQUIENT REQUIREMENTS (CE001 - See GP001 for additional requirements) 7.0 CD Title I Condition: Avoid major source under 40 CFR (b)(1)(i) and Minn. R ; Avoid major source under 40 CFR 70.2 and Minn. R CD Title I Condition: Avoid major source under 40 CFR (b)(1)(i) and Minn. R ; Avoid major source under 40 CFR 70.2 and Minn. R LIMIT Title I Condition: Avoid major source under 40 CFR (b)(1)(i) and Minn. R The Permittee shall route all emissions from components of "EU 002" to control equipment meeting the requirements of GP001 and EU002. The Permittee shall operate and maintain the fabric filter (at the time of permit issuance, CE001) at all times that any process equipment controlled by the fabric filter is operating. The Perm ittee shall document periods of non-operation of the control equipment. Total Particulate Matter: greater than or equal to 79.2 percent control efficiency (capture efficiency x collection efficiency). Any new, replaced, or modified control equipment is also subject to this limit LIMIT Minn. R , subp. 3(E) Total Particulate Matter: greater than or equal to 80 percent collection efficiency. Any new, replaced, or modified control equipment is also subject to this limit LIMIT Title I Condition: Avoid major source under 40 CFR (b)(1)(i) and Minn. R ; Avoid major source under 40 CFR 70.2 and Minn. R LIMIT Title I Condition: Avoid major source under 40 CFR (b)(1)(i) and Minn. R ; Avoid major source under 40 CFR 70.2 and Minn. R < 10 micron: greater than or equal to 74.4 percent control efficiency (capture efficiency x collection efficiency). Any new, replaced, or modified control equipment is also subject to this limit. < 2.5 micron: greater than or equal to 74.4 percent control efficiency (capture efficiency x collection efficiency). Any new, replaced, or modified control equipment is also subject to this limit CD Minn. R MONITORING AND RECORDKEEPING REQUIREMENTS 14.0 CD Minn. R , subp. 2 Labeling Requirement: The Permittee shall permanently affix the emission unit number (EU002) and another unique number to each piece of equipment designated as part of "Grain Receiving," for tracking purposes. Labeling must be completed within 120 days of permit issuance and within 30 days of startup of any new piece of equipment. The numbe r can be affixed by placard, stencil, or other means, provided it is maintained and readable from a safe distance. If equipment is added, it shall be given a new number; numbers from replaced or removed equipment shall not be reused.

84 Facility Name: MINNESOTA POLLUTION CONTROL AGENCY AIR QUALITY 520 LAFAYETTE ROAD ST. PAU L, MN Ardent Mills Flour Mill Permit Number: Page 11 of Jul, :28 COMPLIANCE PLAN CD CD Minn. R , subps. 4-5 Equipment List: The Permittee shall maintain a list of each piece of equipment designated under the "Grain Receiving" category. The list shall include: - the type of equipment - the emission unit number (EU002) and another unique identifier - the date of installation and/or modification 16.0 CD Title I Condition: Avoid major source under 40 CFR (b)(1)(i) and Minn. R ; Avoid major source under 40 CFR 70.2 and Minn. R If equipment is added or modified after permit issuance, the Equipment List shall also note that the following evaluations were made prior to the change: - the change does not trigger any applicable requirements that are not already listed in this permit - the change does not cause violation of any limits in this permit - the change did not require a permit amendment Daily Recordkeeping: Grain Receiving Each operating day, the Permittee shall record the quantity (weight) of grain received at the facility on the previous day CD Minn. R , subps. 4-5 Monthly Recordkeeping: Grain Receiving 18.0 CD Minn. R TESTING REQUIREMENTS By the 15th day of each month, calculate and record the quantity (weight) of grain received during the previous month, and during the previous 12 months (12-month rolling sum) S/A Minn. R , subp. 1 Performance Test: due before end of each calendar 60 months starting 05/01/2012 to measure opacity from fugitive emissions from truck unloading and rail unloading. The performance test shall be conducted at worst cast conditions as defined at Minn. R , subp. 8, using EPA Method 9 or other method approved by MPCA in the performance test plan approval. Testing conducted during the two months prior to the performance test due date satisfies the performance test due date, and will not reset the test due date for future testing as required by: 1) this permit, 2) by the most recently approved Performance Test Frequency Plan, or 3) if specified within a Notice of Compliance letter. Testing conducted more than two months prior to the performance test due date does not satisfy this test due date requirement and will be considered an additional test.

85 MINNESOTA POLLUTION CONTROL AGENCY AIR QUALITY 520 LAFAYETTE ROAD ST. PAUL, MN Page 12 of Jul, :28 COMPLIANCE PLAN CD-01 Facility Name: Ardent Mills Flour Mill Permit Number: Subject Item: Associated Items: EU 003 Grain Cleaning - Cleaning Equipment CE 003 Fabric Fi lter - Low Temperature, i.e., T<180 Degrees F CE 004 Fabric Fi lter - Low Temperature, i.e., T<180 Degrees F CE 005 Fabric Fi lter - Low Temperature, i.e., T<180 Degrees F CE 006 Fabric Fi lter - Low Temperature, i.e., T<180 Degrees F CE 007 Fabric Filt er - Low Temperature, i.e., T<180 Degrees F CE 008 Fabric Filt er - Low Temperature, i.e., T<180 Degrees F CE 009 Fabric Filt er - Low Temperature, i.e., T<180 Degrees F CE 010 Fabric Fil ter - Low Temperature, i.e., T<180 Degrees F CE 035 Fabric Filter - Low Temperature, i.e., T<180 Degrees F SV 003 Cleaning Exhaust SV 004 Cleaning Exhaust SV 005 Cleaning Exhaust SV 006 Cleaning Exhaust SV 007 Cleaning E xhaust SV 008 Cleaning E xhaust SV 009 Cleaning E xhaust SV 010 Cleaning Exhaust SV 013 Cleaning Exhaust NC/ CA Type Citation Requirement 1.0 CD Minn. R EMISSION LIMITS AND OPERATING REQUIREMENTS 2.0 LIMIT Minn. R , subp. 3(D) Opacity: less than or equal to 10 percent opacity from each stack 3.0 LIMIT Minn. R , subp. 3(A) Opacity: less than or equal to 5 percent opacity from fugitive emissions. 4.0 CD Minn. R , subp. 5 EU003 consists of the components listed in Appendix II to this permit. Any replacement, addition, or modification to the components listed in Appendix II is considered a modification of EU003 for purposes of determining if a permit amendment is required. 5.0 CD Minn. R CONTROL EQUIENT REQUIREMENTS (at the time of permit issuance: CE003 - CE010, CE035; See GP001 for additional requirements) 6.0 CD Title I Condition: Avoid major source under 40 CFR (b)(1)(i) and Minn. R ; Avoid major source under 40 CFR 70.2 and Minn. R CD Title I Condition: Avoid major source under 40 CFR (b)(1)(i) and Minn. R ; Avoid major source under 40 CFR 70.2 and Minn. R LIMIT Title I Condition: Avoid major source under 40 CFR (b)(1)(i) and Minn. R The Permittee shall route all emissions from components of "EU 003" to control equipment meeting the requirements of GP001 and EU003. The Permittee shall operate and maintain each fabric filter at all times that any process equipment controlled by the fabric filter is operating. The Permittee shall document periods of non-operation of the control equipment. Total Particulate Matter: greater than or equal to 99 percent control efficiency (capture efficiency x collection efficiency). Any new, replaced, or modified control equipment is also subject to this limit. 9.0 LIMIT Minn. R , subp. 3(E) Total Particulate Matter: greater than or equal to 80 percent collection efficiency. Any new, replaced, or modified control equipment is also subject to this limit.

86 Facility Name: MINNESOTA POL.LUTION CONTROL AGENCY AIR QUALITY 520 LAFAYETTE ROAD ST. PAUL, MN Ardent Mills Flour Mill Permit Number: Page 13 of Jul, :28 COMPLIANCE PLAN CD LIMIT Title I Condition: Avoid major source under 40 CFR (b)(1)(i) and Minn. R ; Avoid major source under 40 CFR 70.2 and Minn. R LIMIT Title I Condition: Avoid major source under 40 CFR (b)(1)(i) and Minn. R ; Avoid major source under 40 CFR 70.2 and Minn. R < 10 micron: greater than or equal to 93 percent control efficiency (capture efficiency x collection efficiency). Any new, replaced, or modified control equipment is also subject to this limit. < 2.5 micron: greater than or equal to 93 percent control efficiency (capture efficiency x collection efficiency). Any new, replaced, or modified control equipment is also subject to this limit CD Minn. R MONITORING AND RECORDKEEPING REQUIREMENTS 13.0 CD Minn. R , subp. 2 Labeling Requirement: The Permittee shall permanently affix the emission unit number (EU003) and another unique number to each piece of equipment designated as part of "Grain Cleaning," for tracking purposes. Labeling must be completed within 120 days of permit issuance and within 30 days of startup of any new piece of equipment. The number can be affixed by placard, stencil, or other means, provided it is maintained and readable from a safe distance. If equipment is added, it shall be given a new number; numbers from replaced or removed equipment shall not be reused CD Minn. R , subps. 4-5 Equipment List: The Permittee shall maintain a list of each piece of equipment designated under the "Grain Cleaning" category. The list shall include: - the type of equipment - the emission unit number (EU003) and another unique identifier - the date of installation and/or modification If equipment is added or modified after permit issuance, the Equipment List shall also note that the following evaluations were made prior to the change: - the change does not trigger any applicable requirements that are not already listed in this permit - the change does not cause violation of any limits in this permit - the change did not require a permit amendment

87 MINNESOTA POLLUTION CONTROL AGENCY AIR QUALITY 520 LAFAYETTE ROAD ST. P AUL, M N Page 14 of Jul, :28 COMPLIANCE PLAN CD-01 Facility Name: Ardent Mills Flour Mill Permit Number: Subject Item: Associated Items: EU 004 Milling - Milling Equipment CE011 Fabric Filter - Low Temperature, i.e. T<180 Degrees F CE 012 Fabric Filter - Low Temperature, i.e. T<180 Degrees F CE 014 Fabric Filter - Low Temperature, i.e. T<180 Degrees F CE 015 Fabric Filter - Low Temperature, i.e. T<180 Degrees F CE 016 Fabric Filter - Low Temperature, i.e. T<180 Degrees F CE 017 Fabric Filter - Low Temperature, i.e. T<180 Degrees F CE 018 Fabric Filter - Low Temperature, i.e. T<180 Degrees F CE 019 Fabric Filter - Low Temperature, i.e. T<180 Degrees F CE 020 Fabric Filter - Low Temperature, i.e., T<180 Degrees F CE 021 Fabric Filter - Low Temperature, i.e., T<180 Degrees F CE 022 Fabric Filter - Low Temperature, i.e., T<180 Degrees F CE 023 Fabric Filter - Low Temperature, i.e., T <180 Degrees F CE 024 Fabric Filter - Low Temperature, i.e., T <180 Degrees F CE 037 Fabric Filter - Low Temperature, i.e., T<180 Degrees F CE 038 Fabric Filter - Low Temperature, i.e., T<180 Degrees F CE 039 Fabric Filter - Low Temperature, i.e., T<180 Degrees F CE 040 Fabric Filter - Low Temperature, i.e., T<180 Degrees F SV011 Milling Exhaust SV012 Milling Exhaust SV 015 Milling Exhaust NCI CA Type Citation Requirement 1.0 CD Minn. R EMISSION LIMITS AND OPERATING REQUIREMENTS 2.0 LIMIT Minn. R , subp. 3(D) Opacity: less than or equal to 10 percent opacity from each stack 3.0 CD Minn. R , subp. 5 EU004 consists of the components listed in Appendix II to this permit. Any replacement, addition, or modification to the components listed in Appendix II is considered a modification of EU004 for purposes of determining if a permit amendment is required. 4.0 CD Minn. R CONTROL EQUIENT REQUIREMENTS (at the time of permit issuance: CE011, CE012, CE014 - CE024, CE037 - CE040; See GP001 for additional requirements) 5.0 CD Title I Condition: Avoid major source under 40 CFR (b)(1)(i) and Minn. R ; Avoid major source under 40 CFR 70.2 and Minn. R CD Title I Condition: Avoid major source under 40 CFR (b)(1)(i) and Minn. R ; Avoid major source under 40 CFR 70.2 and Minn. R LIMIT Title I Condition: Avoid major source under 40 CFR (b)(1)(i) and Minn. R The Permittee shall route all emissions from components of "EU 004" to control equipment meeting the requirements of GP001 and EU004. The Permittee shall operate and maintain each fabric filter at all times that any process equipment controlled by the fabric filter is operating. The Permittee shall document periods of non-operation of the control equipment. Total Particulate Matter: greater than or equal to 99 percent control efficiency (capture efficiency x collection efficiency). Any new, replaced, or modified control equipment is also subject to this limit. 8.0 LIMIT Minn. R , subp. 3(E) Total Particulate Matter: greater than or equal to 80 percent collection efficiency. Any new, replaced, or modified control equipment is also subject to this limit.

88 Facility Name: Permit Number: MINNESOTA POLLUTION CONTROL AGENCY AIR QUALITY 520 LAFAYETTE ROAD ST. PAUL, MN Ardent Mills Flour Mill Page 15 of Jul, :28 COMPLIANCE PLAN CD LIMIT Title I Condition: Avoid major source under 40 CFR (b)(1)(i) and Minn. R ; Avoid major source under 40 CFR 70.2 and Minn. R LIMIT Title I Condition: Avoid major source under 40 CFR (b)(1)(i) and Minn. R ; Avoid major source under 40 CFR 70.2 and Minn. R < 10 micron: greater than or equal to percent control efficiency (capture efficiency x collection efficiency). Any new, replaced, or modified control equipment is also subject to this limit. < 2.5 micron: greater than or equal to percent control efficiency (capture efficiency x collection efficiency). Any new, replaced, or modified control equipment is also subject to this limit CD Minn. R MONITORING AND RECORDKEEPING REQUIREMENTS 12.0 CD Minn. R , subp. 2 Labeling Requirement: The Permittee shall permanently affix the emission unit number (EU004) and another unique number to each piece of equipment designated as part of "Milling," for tracking purposes. Labeling must be completed within 120 days of permit issuance and within 30 days of startup of any new piece of equipment. The num ber can be affixed by placard, stencil, or other means, provided it is maintained and readable from a safe distance. If equipment is added, it shall be given a new number; numbers from replaced or removed equipment shall not be reused CD Minn. R , subps. 4-5 Equipment List: The Permittee shall maintain a list of each piece of equipment designated under the "Milling" category. The list shall include: - the type of equipment - the emission unit number (EU004) and another unique identifier - the date of installation and/or modification If equipment is added or modified after permit issuance, the Equipment List shall also note that the following evaluations were made prior to the change: - the change does not trigger any applicable requirements that are not already listed in this permit - the change does not cause violation of any limits in this permit - the change did not require a permit amendment

89 MINNESOTA POLLUTION CONTROL AGENCY AIR QUALITY 520 LAFAYETTE ROAD ST. PAUL, MN Page 16 of Jul, :28 COMPLIANCE PLAN CD-01 Facility Name: Ardent Mills Flour Mill Permit Number: Subject Item: Associated Items: EU 005 Feed Loadout - Loading-Unloading Equipment CE 030 Fabric Filter - Low Temperature, i.e., T<180 Degrees F GP 004 Loadout SV016 Feed Loadout NCI CA Type Citation Requirement 1.0 CD Minn. R EMISSION LIMITS AND OPERATING REQUIREMENTS 2.0 LIMIT Minn. R , subp. 3(A) Opacity: less than or equal to 5 percent opacity from fugitive emissions from railcar loading. 3.0 LIMIT Minn. R , subp. 3(B) Opacity: less than or equal to 10 percent opacity from fugitive emissions from truck loading. 4.0 LIMIT Minn. R , subp. 3(D) Opacity: less than or equal to 10 percent opacity from the stack 5.0 CD Minn. R , subp. 5 EU005 consists of the components listed in Appendix II to this permit. Any replacement, addition, or modification to the components listed in Appendix II is considered a modification of EU005 for purposes of determining if a permit amendment is required. 6.0 CD Minn. R CONTROL EQUIENT REQUIREMENTS (See requirements under CE030) 7.0 CD Minn. R (G) The Permittee shall route all emissions from components of "EU 005" to control equipment meeting the requirements of CE030 and EU CD Minn. R (G) The Permittee shall operate and maintain the fabric filter at all times that any process equipment controlled by the fabric filter is operating. The Permittee shall document periods of non-operation of the control equipment. 9.0 CD Minn. R TESTING REQUIREMENTS 10.0 S/A Minn. R , subp. 1 Performance Test: due before end of each calendar 60 months starting 05/01/2012 to measure opacity from fugitive emissions from truck loading and rail loading. The performance tst shall be conducted at worst cast conditions as defined at Minn. R , subp. 8, using EPA Method 9 or other method approved by MPCA in the performance test plan approval. Testing conducted during the two months prior to the performance test due date satisfies the performance test due date, and will not reset the test due date for future testing as required by: 1) this per mit, 2) by the most recently approved Performance Test Frequency Plan, or 3) if specified within a Notice of Compliance letter. Testing conducted more than two months prior to the performance test due date does not satisfy this test due date requirement and will be considered an additional test CD Minn. R MONITORING AND RECORDKEEPING REQUIREMENTS 12.0 CD Minn.R , subp. 2 Labeling Requirement: The Permittee shall permanently affix the emission unit number (EU005) and another unique number to each piece of equipment designated as part of "Feed Loadout," for tracking purposes. Labeling must be completed within 120 days of permit issuance and within 30 days of startup of any new piece of equipment. The number can be affixed by placard, stencil, or other means, provided it is maintained and readable from a safe distance. If equipment is added, it shall be given a new number; numbers from replaced or removed equipment shall not be reused CD Minn. R , subps. 4-5 Equipment List: The Permittee shall maintain a list of each piece of equipment designated under the "Feed Loadout" category. The list shall include: - the type of equipment - the emission unit number (EU005) and another unique identifier - the date of installation and/or modification If equipment is added or modified after permit issuance, the Equipment List shall also note that the following evaluations were made prior to the change: - the change does not trigger any applicable requirements that are not already listed in this permit - the change does not cause violation of any limits in this permit - the change did not require a permit amendment

90 Facility Name: MINNESOTA POLLUTION CONTROL AGENCY AIR QUALITY 520 LAFAYETTE ROAD ST. PAUL, MN Ardent Mills Flour Mill Permit Number: Page 17 of Jul, :28 COMPLIANCE PLAN CD-01 Subject Item: Associated Items: EU 006 Grain Handling - Material Handling Equipment CE 002 Fabric Filter - Low Temperature, i.e., T<180 Degrees F SV 002 Grain Handling Exhaust NG/ CA Type Citation Requirement 1.0 CD Minn. R EMISSION LIMITS AND OPERATING REQUIREMENTS 2.0 LIMIT Minn. R , subp. 3(D) Opacity: less than or equal to 10 percent opacity from the stack 3.0 LIMIT Minn. R , subp. 3(A) Opacity: less than or equal to 5 percent opacity from fugitive emissions. 4.0 CD Minn. R , subp. 5 EU006 consists of the components listed in Appendix II to this permit. Any replacement, addition, or modification to the components listed in Appendix II is considered a modification of EU006 for purposes of determining if a permit amendment is required. 5.0 CD Minn. R CONTROL EQUIENT REQUIREMENTS (a time of permit issuance: CE002; See GP001 for additional requirements) 6.0 CD Title I Condition: Avoid major source under 40 CFR (b)(1)(i) and Minn. R ; Avoid major source under 40 CFR 70.2 and Minn. R CD Title I Condition: Avoid major source under 40 CFR (b)(1)(i) and Minn. R ; Avoid major source under 40 CFR 70.2 and Minn. R LIMIT Title I Condition: Avoid major source under 40 CFR (b)(1)(i) and Minn. R The Permittee shall route all emissions from components of "EU 006" to control equipment meeting the requirements of GP001 and EU006. The Permittee shall operate and maintain the fabric filter at all times that any process equipment controlled by the fabric filter is operating. The Permit tee shall document periods of non-operation of the control equipment. Total Particulate Matter: greater than or equal to 99 percent control efficiency (capture efficiency x collection efficiency). Any new, replaced, or modified control equipment is also subject to this limit. 9.0 LIMIT Minn. R , subp. 3(E) Total Particulate Matter: greater than or equal to 80 percent collection efficiency. Any new, replaced, or modified control equipment is also subject to this limit LIMIT Title I Condition: Avoid major source under 40 CFR (b)(1)(i) and Minn. R ; Avoid major source under 40 CFR 70.2 and Minn. R LIMIT Title I Condition: Avoid major source under 40 CFR (b)(1)(i) and Minn. R ; Avoid major source under 40 CFR 70.2 and Minn. R < 10 micron: greater than or equal to 93 percent control efficiency (capture efficiency x collection efficiency). Any new, replaced, or modified control equipment is also subject to this limit. < 2.5 micron: greater than or equal to 93 percent control efficiency (capture efficiency x collection efficiency). Any new, replaced, or modified control equipment is also subject to this limit CD Minn. R MONITORING AND RECORDKEEPING REQUIREMENTS 13.0 CD Minn. R , subp. 2 Labeling Requirement: The Permitt ee shall permanently affix the emission unit number (EU006) and another unique number to each piece of equipment designated as part of "Grain Handling," for tracking purposes. Labeling must be completed within 120 days of permit issuance and within 30 days of startup of any new piece of equipment. The number can be affixed by placard, stencil, or other means, provided it is maintained and readable from a safe distance. If equipment is added, it shall be given a new number; numbers from replaced or removed equipment shall not be reused.

91 Facility Name: Permit Number: MINNESOTA POLLUTION CONTROL AGENCY AIR QUALITY 520 LAFAYETTE ROAD ST. PAUL, MN Ardent Mills Flour Mill Page 18 of Jul, :28 COMPLIANCE PLAN CD CD Minn. R , subps. 4-5 Equipment List: The Permittee shall maintain a list of each piece of equipment designated under the "Grain Handling" category. The lis t shall include: - the type of equipment - the emission unit number (EU006) and another unique identifier - the date of installation and/or modification If equipment is added or modified after permit issuance, the Equipment List shall also note that the following evaluations were made prior to the change: - the change does not trigger any applicable requirements that are not already listed in this permit - the change does not cause violation of any limits in this permit - the change did not require a permit amendment

92 Facility Name: Permit Number: MINNESOTA POLLUTION CONTROL AGENCY AIR QUALITY 520 LAFAYETTE ROAD ST. PAUL, MN Ardent Mills Flour Mill Page 19 of Jul, :28 COMPLIANCE PLAN CD-01 Subject Item: Associated Items: EU 007 Flour Storage and Loading - Loading-Unloading Equipment CE 026 Fabric Filter - Low Temperature, i.e., T<180 Degrees F CE 027 Fabric Filter - Low Temperature, i.e., T<180 Degrees F CE 028 Fabric Filter - Low Temperature, i.e., T<180 Degrees F CE 029 Fabric Filter - Low Temperature, i.e., T<180 Degrees F CE 033 Fabric Filter - Low Temperature, i.e., T<180 Degrees F CE 034 Fabric Filter - Low Temperature, i.e., T<180 Degrees F CE 036 Fabric Filter - Low Temperature, i.e., T<180 Degrees F GP 004 Loadout SV017 Storage/Loadout Exhaust SV018 Storage/Loadout Exhaust SV019 Storage/Loadout Exhaust SV 020 Storage/Loadout Exhaust SV 021 Storage/Loadout Exhaust SV 022 Storage/Loadout Exhaust SV 024 Storage/Loadout Exhaust NC/ CA Type Citation Requirement 1.0 CD Minn. R EMISSION LIMITS AND OPERATING REQUIREMENTS 2.0 LIMIT Minn. R , subp. 3(A) Opacity: less than or equal to 5 percent opacity from fugitive emissions from railcar loading. 3.0 LIMIT Minn. R , subp. 3(B) Opacity: less than or equal to 10 percent opacity from fugitive emissions from truck loading. 4.0 LIMIT Minn. R , subp. 3(D) Opacity: less than or equal to 10 percent opacity from each stack 5.0 CD Minn. R , subp. 5 EU007 consists of the components listed in Appendix II to this permit. Any replacement, addition, or modification to the components listed in Appendix II is considered a modification of EU007 for purposes of determining if a permit amendment is required. 6.0 CD Minn. R CONTROL EQUIENT REQUIREMENTS (at time of permit issuance: CE026 - CE029, CE033, CE034, CE036; See GP001 for additional requirements) 7.0 CD Title I Condition: Avoid major source under 40 CFR (b)(1)(i) and Minn. R ; Avoid major source under 40 CFR 70.2 and Minn. R CD Title I Condition: Avoid major source under 40 CFR (b)(1)(i) and Minn. R ; Avoid major source under 40 CFR 70.2 and Minn. R LIMIT Title I Condition: Avoid major source under 40 CFR (b)(1)(i) and Minn. R The Permittee shall route all emissions from components of "EU 007" to control equipment meeting the requirements of GP001 and EU007. The Permittee shall operate and maintain each fabric filter at all times that any process equipment controlled by the fabric filter is operating. The Permittee shall document periods of non-operation of the control equipment. Total Particulate Matter: greater than or equal to 99 percent control efficiency (capture efficiency x collection efficiency). Any new, replaced, or modified control equipment is also subject to this limit LIMIT Minn. R , subp. 3(E) Total Particulate Matter: greater than or equal to 80 percent collection efficiency. Any new, replaced, or modified control equipment is also subject to this limit.

93 Facility Name: MINNESOTA POLLUTION CONTROL AGENCY AIR QUALITY 520 LAFAYETTE ROAD ST. P AUL, MN Ardent Mills Flour Mill Permit Number: Page 20 of Jul, :28 COMPLIANCE PLAN CD LIMIT Title I Condition: Avoid major source under 40 CFR (b)(1)(i) and Minn. R ; Avoid major source under 40 CFR 70.2 and Minn. R LIMIT Title I Condition: Avoid major source under 40 CFR (b)(1)(i) and Minn. R ; Avoid major source under 40 CFR 70.2 and Minn. R < 10 micron: greater than or equal to 93 percent control efficiency (capture efficiency x collection efficiency). Any ne w, replaced, or modified control equipment is also subject to this limit. < 2.5 micron: greater than or equal to 93 percent control efficiency (capture efficiency x collection efficiency). Any new, replaced, or modified control equipment is also subject to this limit CD Minn. R MONITORING AND RECORDKEEPING REQUIREMENTS 14.0 CD Minn. R , subp. 2 Labeling Requirement: The Permittee shall permanently affix the emission unit number (EU007) and another unique number to each piece of equipment designated as part of "Flour Storage and Loading," for tracking purposes. Labeling must be completed within 120 days of permit issuance and within 30 days of startup of any new piece of equipment. The nu mber can be affixed by placard, stencil, or other means, provided it is maintained and readable from a safe distance. If equipment is added, it shall be given a new number; numbers from replaced or removed equipment shall not be reused CD Minn. R , subps. 4-5 Equipment List: The Permittee shall maintain a list of each piece of equipment designated under the "Flour Storage and Loading" category. The list shall include: - the type of equipment - the emission unit number (EU007) and another unique identifier - the date of installation and/or modification If equipment is added or modified after permit issuance, the Equipment List shall also note that the following evaluations were made prior to the change: - the change does not trigger any applicable requirements that are not already listed in this permit - the change does not cause violation of any limits in this permit - the change did not require a permit amendment

94 Facility Name: MINNESOTA POLLUTION CONTROL AGENCY Page 21 of Jul, :28 AIR QUALITY 520 LAFAYETTE ROAD "" " COMPLIANCE PLAN CD-01 Ardent Mills Flour Mill Permit Number: Subject Item: Associated Items: EU 008 Pellet Cooling - Cooler CE 031 Centrifug al Collector - Medium Efficiency CE 032 Centrifugal Collector - Medium Efficiency SV 014 Pellet C ooling Exhaust NCI CA Type Citation Requirement 1.0 CD Minn. R EMISSION LIMITS AND OPERATING REQUIREMENTS 2.0 LIMIT Minn. R , subp. 1(A) Total Particulate Matter: less than or equal to 0.3 grains/dry standard cubic foot of exhaust gas unless required to further reduce emissions to comply with the less stringent limit of either Minn. R or Minn. R LIMIT Minn. R , subp. 1(B) Opacity: less than or equal to 20 percent opacity from SV LIMIT Title I Condition: Avoid major source under 40 CFR (b)(1)(i) and Minn. R ; Avoid major source under 40 CFR 70.2 and Minn. R Process Throughput: less than or equal to tons/year using 12-month Rolling Sum of pellets cooled. 5.0 CD Minn. R , subp. 5 EU008 consists of the components listed in Appendix II to this permit. Any replacement, addition, or modification to the components listed in Appendix II is considered a modification of EU008 for purposes of determining if a permit amendment is required. 6.0 CD Minn. R CONTROL EQUIENT REQUIREMENTS (at time of permit issuance: CE031 & CE032; See GP002 for additional requirements) 7.0 CD Title I Condition: Avoid major source under 40 CFR (b)(1)(i) and Minn. R ; Avoid major source under 40 CFR 70.2 and Minn. R CD Title I Condition: Avoid major source under 40 CFR (b)(1)(i) and Minn. R ; Avoid major source under 40 CFR 70.2 and Minn. R LIMIT Title I Condition: Avoid major source under 40 CFR (b)(1)(i) and Minn. R LIMIT Title I Condition: Avoid major source under 40 CFR (b)(1)(f) and Minn. R ; Avoid major source under 40 CFR 70.2 and Minn. R LIMIT Title I Condition: Avoid major source under 40 CFR (b)(1)(i) and Minn. R ; Avoid major source under 40 CFR 70.2 and Minn. R The Permittee shall route all emissions from components of "EU 008" to control equipment meeting the requirements of GP002 and EU008. The Permittee shall operate and maintain each cyclone at all times that any process equipment controlled by the device is operating. The Permittee shall document periods of non-operation of the control equipment. Total Particulate Matter: greater than or equal to 96 percent control efficiency (capture efficiency x collection efficiency, for 2 centrifugal collectors in series). Any new, replaced, or modified control equipment is also subject to this limit. < 10 micron: greater than or equal to 64 percent control efficiency (capture efficiency x collection efficiency, for 2 centrifugal collectors in series). Any new, replaced, or modified control equipment is also subject to this limit. < 2.5 micron: greater than or equal to 64 percent control efficiency (capture efficiency x collection efficiency, for 2 centrifugal collectors in series). Any new, replaced, or modified control equipment is also subject to this limit CD Minn. R MONITORING AND RECORDKEEPING REQUIREMENTS 13.0 CD Minn. R , subp. 2 Labeling Requirement: The Permit tee shall permanently affix the emission unit number (EU008) and another unique number to each piece of equipment designated as part of "Pellet Cooling," for tracking purposes. Labeling must be completed within 120 days of permit issuance. The num ber can be affixed by placard, stencil, or other means, provided it is maintained and readable from a safe distance. If equipment is added, it shall be given a new number; numbers from replaced or removed equipment shall not be reused.

95 MINNESOTA POLLUTION CONTROL AGENCY AIR QUALITY 520 LAFAYETTE ROAD ST. P AUL, MN Page 22 of Jul, :28 COMPLIANCE PLAN CD-01 Facility Name: Ardent Mills Flour Mill Permit Number: CD Minn. R , subps. 4-5 Equipment List: The Permittee shall maintain a list of each piece of equipment designated under the "Pellet Cooling" category. The list shall include: - the type of equipment - the emission unit number (EU008) and another unique identifier - the date of installation and/or modification 15.0 CD Title I Condition: Avoid major source under 40 CFR (b)(1)(i) and Minn. R ; Avoid major source under 40 CFR 70.2 and Minn. R If equipment is added or modified after permit issuance, the Equipment List shall also note that the following evaluations were made prior to the change: - the change does not trigger any applicable requirements that are not already listed in this permit - the change does not cause violation of any limits in this permit - the change did not require a permit amendment Daily Recordkeeping: Pellet Cooling Throughput Each operating day, the Permittee shall record the quantity (weight) of pellets cooled at the facility on the previous day CD Minn. R , subps. 4-5 Monthly Recordkeeping: Pellet Cooling Throughput By the 15th day of each month, calculate and record the quantity (weight) of pellets cooled during the previous month, and during the previous 12 months (12-month rolling sum).

96 MINNESOTA POLLUTION CONTROL AGENCY AIR QUALITY 520 LAFAYETTE ROA D ST. PAUL, MN Page 23 of Jul, :28 COMPLIANCE PLAN CD-01 Facility Name; Ardent Mills Flour Mill Permit Number: Subject Item: Associated Items: EU 009 Emergency Generator SV025 Emergency Generator NC/ CA Type Citation Requirement 1.0 CD Minn. R EMISSION LIMITS 2.0 LIMIT Minn. R , subp. 1 Opacity: less than or equal to 20 percent opacity once operating temperatures have been attained. 3.0 LIMIT Minn. R , subp. 2 Sulfur Dioxide: less than 0.50 lbs/million Btu heat input. The potential to emit from the unit is 0.29 lbs/million Btu heat input due to equipment design and allowable fuels. 4.0 CD Minn. R OPERATING CONDITIONS 5.0 CD Minn. R , subp. 35a No. 2 fuel oil/diesel fuel meeting the requirements of 40 CFR Section (c) only by design. 6.0 LIMIT Title I Condition: Avoid major source under 40 CFR (b)(1)(i) and Minn. R ; Avoid major source under 40 CFR 70.2 and Minn. R CD Minn. R RECORDKEEPING REQUIREMENTS 8.0 CD Title I Condition: Avoid major source under 40 CFR (b)(1)(i) and Minn. R ; Avoid major source under 40 CFR 70.2 and Minn. R ; Minn. R , subps. 4-5 Operating Hours: less than or equal to 500 hours/year using 12-month Rolling Sum to be calculated by the 15th day of each month. Hours of Operation: The Permittee shall maintain documentation on site that the unit is an emergency generator by design that qualifies under the U.S. EPA memorandum entitled "Calculating Potential to Emit (PTE) for Emergency Generators" dated September 6,1995, limiting operation to 500 hours per year. 9.0 CD Minn. R , subp. 5 The Permittee shall keep records of fuel type and usage on a monthly basis CD Minn. R NESHAP SUBPART ZZZZ REQUIREMENTS - Enforcement Not Delegated to MPCA 11.0 CD 40 CFR Section (a); 40 CFR Section ; and Table 2d to subpart ZZZZ of Part 63; Minn. R CD 40 CFR Section (a); 40 CFR Section ; and Table 2d to subpart ZZZZ of Part 63; Minn. R CD 40 CFR Section (a); 40 CFR Section ; and Table 2d to subpart ZZZZ of Part 63; Minn. R CD 40 CFR Section (b); Minn. R CD 40 CFR Section (a); Minn. R Change oil and filter every 500 hours of operation or annually, whichever comes first. The Permittee has the option of utilizing an oil analysis program in order to extend the oil change requirement as described below. Inspect air cleaner every 1,000 hours of operation or annually, whichever comes first, and replace as necessary. Inspect all hoses and belts every 500 hours of operation or annually, whichever comes first, and replace as necessary. By January 1, 2015 the Permittee shall only use diesel fuel that meets the requirements in 40 CFR Section (b) for nonroad diesel fuel, except that any existing diesel fuel purchased or otherwise obtained prior to January 1, 2015 may be used until depleted. At all times the Permittee shall operate and maintain any affected source, including associated air pollution control equipment and monitoring equipment, in a manner consistent with safety and good air pollution control practices for minimizing emissions. The general duty to minimize emissions does not require the Permittee to make any further efforts to reduce emissions if levels required by this standard have been achieved. Determination of whether such operation and maintenance procedures are being used will be based on information available to the Administrator which may include, but is not limited to, monitoring results, review of operation and maintenance procedures, review of op eration and maintenance records, and inspection of the source.

97 Facility Name: Permit Number: MINNESOTA POLLUTION CONTROL AGENCY AIR QUALITY 520 LAFAYETTE ROAD ST. PAU L, MN Ardent Mills Flour Mill Page 24 of Jul, :28 COMPLIANCE PLAN CD CD 40 CFR Section (e); Minn. R CD 40 CFR Section (h); Minn. R CD 40 CFR Section (i); Minn. R CD 40 CFR Section (i); Minn. R CD 40 CFR Section (a); 40 CFR pt. 63 subp. ZZZZ, Table CD 40 CFR Section and Table 8 to Subpart ZZZZ of Part 63; 40 CFR Section ; Minn. R The Permittee shall operate and maintain the stationary RICE and after-treatment control device (if any) according to the manufacturer's emission-related written instructions or develop a maintenance plan which shall provide to the extent practicable for the maintenance and operation of the engine in a manner consistent with good air pollution control practice for minimizing emissions. The Permittee shall minimize the engine's time spent at idle during startup and minimize the engine's startup time to a period needed for appropriate and safe loading of the engine, not to exceed 30 minutes, after which time the emission standards applicable to all times other than startup apply. The Permittee has the option of utilizing an oil analysis program in order to extend the specified oil change requirement. The oil analysis shall be performed at the same frequency specified for changing the oil. The analysis program shall at a minimum analyze the following 3 parameters: Total Base Number, viscosity, and percent water content. The condemning limits for these parameters are as follows: Total Base Number is less than 30 percent of the Total Base Number of the oil when new; viscosity of the oil has changed by more than 20 percent from the viscosity of the oil when new; or percent water content (by volume) is greater than 0.5. (continued below) (continued from above) If none of the condemning limits are exceeded, the Permittee is not required to change the oil. If any of the limits are exceeded, the Permittee shall change the oil within 2 business days of receiving the results of the analysis; if the engine is not in operation when the results of the analysis are received, the Permittee shall change the oil within 2 business days or before commencing operation, whichever is later. The Permittee shall keep records of the parameters that are analyzed as part of the program, the results of the analysis, and the oil changes for the engine. The analysis program shall be part of the maintenance plan for the engine. The Permittee shall operate and maintain the stationary RICE according to the manufacturer's emission-related operation and maintenance instructions; or the Permittee shall develop and follow a maintenance plan which shall provide to the extent practicable for the maintenance and operation of the engine in a manner consistent with good air pollution control practice for minimizing emissions. The Permittee shall comply with the General Provisions in 40 CFR Section 63.1 through 63.15, as stated in 40 CFR pt. 63, subp. ZZZZ, Table 8, as applicable CD Minn. R REQUIREMENTS FOR EMERGENCY STATIONARY RICE 23.0 CD 40 CFR Section (f); Minn. R CD 40 CFR Section (f); Minn. R The Permittee shall install a non-resettable hour meter if one is not already installed by May 3, The Permittee shall operate the emergency stationary RICE according to the requirements in paragraphs 40 CFR Section (f)(1) through (4). Any operation other than emergency operation, maintenance and testing, emergency demand response, and operation in non-emergency situations for 50 hours per year, as described in 40 CFR Section (f)(1) through (4), is prohibited. If the engine is not operated according to the requirements in 40 CFR Section (f)(1) through (4), the engine will not be considered an emergency engine under this subpart and will need to meet all requirements for non-emergency engines.

98 Facility Name: MINNESOTA POLLUTION CONTROL AGENCY AIR QUALITY 520 LAFAYETTE ROA D ST. PAUL, MN Ardent Mills Flour Mill Permit Number: CD 40 CFR Section (f)(1) - (2); Minn. R Page 25 of Jul, :28 COMPLIANCE PLAN CD-01 (1) There is no time limit on the use of emergency stationary RICE in emergency situations. ON MAY 1, 2015, THE D.C. CIRCUIT VACATED THE PROVISIONS OF 40 CFR SECTION (f)(2) THAT ALLOW OPERATION OF AN EMERGENCY GENERATOR WITHOUT EMISSIONS CONTROLS FOR UP TO HOURS PER YEAR AS PART OF AN EMERGENCY DEMAND-RESPONSE PROGRAM. AS OF THE DATE OF ISSUANCE OF AIR EMISSION PERMIT NO , THE COURT HAD NOT ISSUED THE MANDATE IMPLEMENTING ITS DECISION. THESE PROVISIONS REMAIN IN EFFECT UNTIL THE COURT ISSUES THE MANDATE. AFTER THAT ACTION, THE PROVISIONS WILL NO LONGER BE EFFECTIVE. (2) The Permittee may operate the emergency stationary RICE for any combination of the purposes specified in 40 CFR Section (f)(2)(i) through (iii) for a maximum of hours per calendar year. Any operation for non-emergency situations as allowed by 40 CFR Section (f)(3) and (4) counts as part of the hours per calendar year allowed by this paragraph (f)(2) CD 40 CFR Section (f)(2)(i); Minn. R CD 40 CFR Section (f)(2)(ii) - (2)(iii); Minn. R CD 40 CFR Section (f)(4); Minn. R CD 40 CFR Section (f)(4)(i); Minn. R CD 40 CFR Section (f)(4)(ii); Minn. R (i) The Permittee may operate the emergency stationary RICE for the purpose of maintenance checks and readiness testing, provided that the tests are recommended by Federal, State or local government, the manufacturer, the vendor, the regional transmission organization or equivalent balancing authority and transmission operator, or the insurance company associated with the engine. The Permittee may petition the Administrator for approval of additional hours to be used for maintenance checks and readiness testing, but a petition is not required if the Permittee maintains records indicating that Federal, State, or local standards require maintenance and testing of emergency RICE beyond hours per calendar year. 2(ii) Emergency stationary RICE may be operated for emergency demand response for periods in which the Reliability Coordinator under the North American Electric Reliability Corporation (NERC) Reliability Standard EOP-002-3, Capacity and Energy Emergencies (incorporated by reference, see 40 CFR Section 63.14), or other authorized entity as determined by the Reliability Coordinator, has declared an Energy Emergency Alert Level 2 as defined in the NERC Reliability Standard EOP (iii) Emergency stationary RICE may be operated for periods where there is a deviation of voltage or frequency of 5 percent or greater below standard voltage or frequency. (4) The Permittee may operate the emergency stationary RICE up to 50 hours per year in non-emergency situations, but those 50 hours are counted towards the hours per calendar year provided for maintenance and testing and emergency demand response provided in 40 CFR Section (f)(2). Except as provided in 40 CFR Section (f)(4)(i) and (ii), the 50 hours per year for non-emergency situations cannot be used for peak shaving or non-emergency demand response, or to generate income for a facility to supply power to an electric grid or otherwise supply power as part of a financial arrangement with another entity. 4(i) Prior to May 3, 2014, the 50 hours per year for non-emergency situations can be used for peak shaving or non-emergency demand response to generate income for a facility, or to otherwise supply power as part of a financial arrangement with another entity if the engine is operated as part of a peak shaving (load management program) with the local distribution system operator and the power is provided only to the facility itself or to support the local distribution system. 4(i) The 50 hours per year for nonemergency situations can be used to supply power as part of a financial arrangement with another entity if all of the following conditions are met: (A) The engine is dispatched by the local balancing authority or local transmission and distribution system operator. (B) The dispatch is intended to mitigate local transmission and/or distribution limitations so as to avert potential voltage collapse or line overloads that could lead to the interruption of power supply in a local area or region. (C) The dispatch follows reliability, emergency operation or similar protocols that follow specific NERC, regional, state, public utility commission or local standards or guidelines. (D) The power is provided only to the facility itself or to support the local transmission and distribution system. (continued below)

99 Facility Name: MINNESOTA POLLUTION CONTROL AGENCY AIR QUALITY 520 LAFAYETTE ROAD ST. PAUL, MN Ardent Mills Flour Mill Permit Number: CD 40 CFR Section (f)(4)(ii); Minn. R (continued from above) Page 26 of Jul, :28 COMPLIANCE PLAN CD-01 4(ii) (E) The owner or operator identifies and records the entity that dispatches the engine and the specific NERC, regional, state, public utility commission or local standards or guidelines that are being followed for dispatching the engine. The local balancing authority or local transmission and distribution system operator may keep these records on behalf of the engine owner or operator CD Minn. R NESHAP RECORDKEEPING REQUIREMENTS 33.0 CD 40 CFR Section (a); Minn. R CD 40 CFR Section (a); Minn. R CD 40 CFR Section (e); Minn. R CD 40 CFR Section (f); Minn. R CD 40 CFR Section ; 40 CFR Section 63.10(b)(1); Minn. R The Permittee shall demonstrate continuous compliance with teach emission limitation and operating limitation in Table 2d of 40 CFR pt. 63, subp. ZZZZ that apply according to methods specified in Table 6 of 40 CFR pt. 63, subp. ZZZZ. The Permittee shall keep the following records: 1. A copy of each notification and report submitted to comply with 40 CFR pt. 63, subp. ZZZZ, including all documentation supporting any Initial Notification or Notification of Compliance Status submitted according to the requirement in 40 CFR Section 63.10(b)(2)(xiv). 2. Records of the occurrence and duration of each malfunction of operation (i.e., process equipment) or the air pollution control and monitoring equipment. 3. Records of performance tests and performance evaluations as required in 40 CFR Section 63.10(b)(2)(viii). 4. Records of all required maintenance performed on the air pollution control and monitoring equipment. 5. Records of actions taken during periods of malfunction to minimize emissions in accordance with 40 CFR Section (b), including corrective actions to restore malfunctioning process and air pollution control and monitoring equipment to its normal or usual manner of operation. The Permittee shall keep records of the maintenance conducted on the stationary RICE in order to demonstrate that the Permittee operated and maintained the stationary RICE and after-treatment control device (if any) according to the maintenance plan. The Permittee shall keep records of the hours of operation of the engine that are recorded through the non-resettable hour meter. The Permittee shall document how many hours are spent for emergency operation, including what classified the operation as emergency and how many hours are spent for non-emergency operation. If the engine is used for the purposes specified in 40 CFR Section (f)(2)(ii) or (iii) or 40 CFR Section (f)(4)(ii), the Permittee shall keep records of the notification of the emergency situation, and the date, start time, and end time of engine operation for these purposes. The Permittee shall keep records in a form suitable and readily available for expeditious review according to 40 CFR Section 63.10(b)(1). As specified in 40 CFR Section 63.10(b)(1), the Permittee shall keep each record for 5 years following the date of each occurrence, measurement, maintenance, corrective action, report or record CD Minn. R REPORTING AND NOTIFICATION REQUIREMENTS 39.0 CD 40 CFR Section (b); Minn. R CD Minn. R APPLICABLE GENERAL PROVISIONS The Permittee shall report each instance in which the stationary RICE did not meet each applicable operating limitation. These instances are deviations from the emission and operating limitations. These deviations shall be reported with the deviations report required by Table A (listed at the Total Facility level) and Table B of this permit. These deviations shall be reported according to the requirements in 40 CFR Section CD Minn. R OPERATION AND MAINTENANCE REQUIREMENTS 42.0 CD 40 CFR Section 63.4(b); Minn. R CD 40 CFR Section 63.5(b)(3); Minn. R Circumvention. The Permittee shall not build, erect, install, or use any article, machine, equipment, or process to conceal an emission that would otherwise constitute noncompliance with a relevant standard. Such concealment includes, but is not limited to: 1) The use of diluents to achieve compliance with a relevant standard based on the concentration of a pollutant in the effluent discharged to the atmosphere or 2) The use of gaseous diluents to achieve compliance with a relevant standard for visible emissions., Prior to construction or reconstruction of a major-emitting "affected source" under the promulgated MACT standards, the Permittee must apply for and obtain an air emission permit.

100 Facility Name: Permit Number: MINNESOTA POLLUTION CONTROL AGENCY AIR QUALITY 520 LAFAYETTE ROAD ST. PAUL. MN Ardent Mills Flour Mill Page 27 of Jul, :28 COMPLIANCE PLAN CD CD 40 CFR Section 63.5(b)(4); Minn. R CD 40 CFR Section 63.5(b)(6); Minn. R CD 40 CFR Section 63.6(e)(1)(i); Minn. R CD 40 CFR Section 63.6(e)(1)(H); Minn. R CD 40 CFR Section 63.6(e)(3)(i); Minn. R CD 40 CFR Section 63.6(e)(3)(iii); Minn. R CD 40 CFR Section 63.6(e)(3)(iv); Minn. R CD 40 CFR Section 63.6(e)(3)(v); Minn. R The Permittee must submit notification according to 40 CFR Section 63.9(b) if the Permittee constructs or reconstructs a source such that the source becomes an affected source subject to a standard. After the effective date of any relevant standard promulgated under 40 CFR pt. 63, equipment added (or a process change) to an affected source that is within the scope of the definition of affected source under the relevant standard must be considered part of the affected source and subject to all provisions of the relevant standard established for that affected source. Proper Operation and Maintenance. At all times, including periods of startup, shutdown, and malfunction, the Permittee shall operate and maintain the emission unit subject to the MACT standard and any associated air pollution control equipment and monitoring equipment, in a manner consistent with safety and good air pollution control practices for minimizing emissions at least to the levels required by any relevant standard and as detailed in 40 CFR Section 63.6(e)(1)(i)-(iii). Malfunctions shall be corrected as soon as practicable after their occurrence. Startup, shutdown, and malfunction plan (SSMP). The Permittee shall prepare and implement a written SSMP that describes, in detail, procedures for operating and maintaining the source during periods of startup, shutdown, and malfunction; and a program of corrective action for malfunctioning process, air pollution control, and monitoring equipment used to comply with the relevant standard. The plan requirements are further described in 40 CFR Section 63.6(e)(3)(i). When actions taken by Permittee during a startup or shutdown (and the startup or shutdown causes the source to exceed any applicable emission limitation), or malfunction (including actions taken to correct a malfunction) are consistent with the procedures specified in the affected source's SSMP, the Permittee must keep records which demonstrate that the procedures specified in the SSMP were followed and describes the actions taken for that event. If an action taken by the Permittee during a startup, shutdown, or malfunction (including an action taken to correct a malfunction) is not consistent with the procedures specified in the affected source's SSMP, and the source exceeds any applicable emission limitation in the relevant emission standard, then the Permittee must record the actions taken for that event and must report such actions as specified in 40 CFR Section 63.10(d)(5). The Permittee must maintain at the affected source a current SSMP and must make the plan available upon request for inspection and copying by the Administrator. In addition, if the SSMP is subsequently revised, the Permittee must maintain at the affected source each previous (i.e., superseded) version of the SSMP, and must make each such previous version available for inspection and copying for a period of 5 years after revision of the SSMP CD 63.6(e)(3)(vi); Minn. R To satisfy the requirements of this section to develop a SSMP, the Permittee may use a standard operating procedures (SOP) manual, or other plan, provided the alternative plans meet all the requirements and are made available for inspection or submission CD 63.6(e)(3)(vii); Minn. R CD 40 CFR Section 63.6(e)(3)(viii); Minn. R CD 40 CFR Section 63.6(e)(3)(ix); Minn. R The Administrator may require that a Permittee make changes to the SSMP. Revisions to the SSMP will be required if the plan: 1) Does not address a startup, shutdown, or malfunction event that has occurred; 2) Fails to provide for the operation of the source (including associated air pollution control and monitoring equipment) during a startup, shutdown, or malfunction event in a manner consistent with the general duty to minimize emissions established by 40 CFR Section 63.6(e)(3)(iii)-63.6(e)(3)(ix) (e)(1)(i); 3) Does not provide adequate procedures for correcting malfunctioning process and/or air pollution control and monitoring equipment as quickly as practicable; or 4) Includes an event that does not meet the definition of startup, shutdown, or malfunction. The Permittee may periodically revise the SSMP as necessary to reflect changes in equipment or procedures at the affected source. Each such revision to a SSMP must be reported in the semiannual report required by 40 CFR Section 63.10(d)(5). If the SSMP fails to address or inadequately addresses an event that meets the characteristics of a malfunction but was not included in the SSMP, the Permittee shall revise the SSMP within 45 days after the event in accordance with 40 CFR Section 63.6(e)(3)(viii). Any revisions made to the SSMP shall not be deemed to constitute permit revisions under 40 CFR pt. 70 or pt. 71.

101 Facility Name: MINNESOTA POLLUTION CONTROL AGENCY AIR QUALITY 520 LAFAYETTE ROAD ST. PAUL, MN Ardent Mills Flour Mill Permit Number: Page 28 of Jul, :28 COMPLIANCE PLAN CD CD 40 CFR Section 63.6(f)(1); Minn. R CD 40 CFR Section 63.6(f)(2); Minn. R CD 40 CFR Section 63.6(f)(3); Minn. R CD 40 CFR Section 63.6(g); Minn. R CD 40 CFR Section 63.6(i); Minn. R CD 40 CFR Section 63.6(i)(1); Minn. R Applicability. The non-opacity emission standards set forth in 40 CFR Section 63.6(f)(1 )-(3) shall apply at all times except during periods of startup, shutdown, and malfunction, and as otherwise specified in an 40 CFR pt. 63, Subpart ZZZZ. Methods for determining compliance will be, in part, based on the results of performance tests, conformance with operation and maintenance requirements, review of records, and inspection of the source as specified in 40 CFR Section 63.6(f)(2) The Permittee many use the results of performance testing conducted previously if it meets the requirements of 40 CFR Section 63.6(f)(iii). Finding of compliance. The Adminis trator will make a finding concerning an affected source's compliance with a non-opacity emission standard upon obtaining all the compliance information required by the relevant standard. The Permittee may establish the use of an alternative non-opacity emission standard by following the procedure specified in 40 CFR Section 63.6(g). The Administrator may grant an extension of compliance with an emission standard, as specified in 40 CFR Section 63.6(i). Until an extension of compliance has been granted by the Administrator, the Permittee shall comply with all applicable requirements of 40 CFR pt. 63, subp. A CD Minn. R PERFORMANCE TESTING REQUIREMENTS 63.0 CD 40 CFR Section 63.7(b); Minn. R CD 40 CFR Section 63.7(c)(2); Minn. R CD 40 CFR Section 63.7(c)(3); Minn. R CD 40 CFR Section 63.7(d); Minn. R CD 40 CFR Section 63.7(e)(1)-(2); Minn. R CD 40 CFR Section 63.7(e)(3); Minn. R Notification of performance test. 1) The Permittee must notify the Administrator of their intention to conduct a performance test at least 60 calendar days before the performance test is initially scheduled to begin. 2) In the event the Permittee is unable to conduct the performance test on the date specified due to unforeseeable circumstances, the Permittee must notify the Administrator as soon as practicable and without delay prior to the scheduled performance test date and specify the date when the performance test is rescheduled. Submission of site-specific test plan. Before conducting a required performance test, the Permittee shall develop and, if requested by the Administrator, shall submit a site-specific test plan for approval in accordance with the requirements of 40 CFR Section 63.7(c)(2). Approval of site-specific test plan. The Administrator will notify the Permittee of approval or intention to deny approval of the site-specific test plan (if review of the site-specific test plan is requested) within 30 calendar days after receipt of the original plan and within 30 calendar days after receipt of any supplementary information. Performance testing facilities. The Permittee, at the request of the Administrator, shall provide performance testing facilities as specified in 40 CFR Section 63.7(d). Conduct of performance tests. 1) Performance tests shall be conducted under based on representative of the affected source. Operations during periods of startup, shutdown, and malfunction shall not constitute representative conditions for the purpose of a performance test. 2) Performance tests shall be conducted and data shall be reduced in accordance with the test methods and procedures set forth in 40 CFR Section 63.7(e), in each relevant standard, and, if required, in applicable appendices of 40 CFR parts 51, 60, 61. The Commissioner has delegation to approve a minor or intermediate modification (if validated by Method 301) to a reference method or specified monitoring procedure as allowed for in 40 CFR Section 63.7(e)(2)(i) and (ii). Unless otherwise specified in a relevant standard or test method, each performance test shall consist of three separate runs using the applicable test method. Each run shall be conducted for the time and under the conditions specified in the relevant standard. For the purpose of determining compliance with a relevant standard, the arithmetic mean of the results of the three runs shall apply, unless otherwise approved in accordance with provisions of 40 CFR Section 63.7(e)(3).

102 Facility Name: MINNESOTA POLLUTION CONTROL AGENCY AIR QUALITY 520 LAFAYETTE ROAD ST. PAUL, MN Ardent Mills Flour Mill Permit Number: Page 29 of Jul, :28 COMPLIANCE PLAN CD CD 40 CFR Section 63.7(g); Minn. R CD 40 CFR Section 63.7(h); Minn. R CD Minn. R MONITORING REQUIREMENTS 72.0 CD 40 CFR 63.8(a)(2); Minn. R CD 40 CFR Section 63.8(b)(1); Minn. R CD 40 CFR Section 63.8(c)(1)-(3); Minn. R CD 40 CFR Section 63.8(c)(6); Minn. R CD 40 CFR Section 63.8(c)(7)(i); Minn. R CD 40 CFR Section 63.8(c)(7)(ii); Minn. R CD 40 CFR Section 63.8(c)(8); Minn. R Data analysis, recordkeeping, and reporting. Unless otherwise specified in a relevant standard or test method, or as otherwise approved by the Administrator in writing, results of a performance test shall include the analysis of samples, determination of emissions, and raw data. A performance test is completed when field sample collection is terminated. The Permittee shall report the results of the performance test to the Administrator before the close of business on the 60th day following the completion of the performance test, unless specified otherwise in a relevant standard or as approved otherwise in writing. The results of the performance test shall be submitted as part of the notification of compliance status required under 40 CFR Section 63.9(h) to the appropriate permitting authority. Waiver of performance tests. Until a waiver of a performance testing requirement has been granted by the Administrator under 40 CFR Section 63.7(h), the Permittee remains subject to the requirements of 40 CFR Section 63.7(h). All CMS required under relevant standards shall be subject to the provisions of 40 CFR Section 63.8 upon promulgation of performance specifications for CMS as specified in the relevant standard or otherwise by the Administrator. The performance specifications in 40 CFR pt. 60, Appendix B apply. Conduct of monitoring. Monitoring shall be conducted as set forth in 40 CFR Section 63.8(a)(b)(1). Operation and maintenance of continuous monitoring systems. The Permittee shall maintain and operate each CMS in a manner consistent with good air pollution control practices. 1) The Permittee must keep the necessary parts for routine repairs of the affected CMS equipment readily available. 2) The Permittee must ensure the read out, or other indication of operation, from any CMS required for compliance with the emission standard is readily accessible on site for operational control or inspection. 3) All CMS shall be installed, operational, and the data verified prior to or in conjunction with conducting performance tests. Verification of operational status shall, at a minimum, include completion of the manufacturer's written specifications or recommendations for installation, operation, and calibration of the system. 6) The Permittee of a CMS that is not a CS, must check the zero (low-level) and high-level calibration drifts at least once daily in accordance with the written procedure specified in the performance evaluation plan. 7) A CMS is out of control if: i) The zero (low-level), mid-level (if applicable), or high-level calibration drift (CD) exceeds two times the applicable CD specification in the applicable performance specification or in the relevant standard; or ii) The CMS fails a performance test audit (e.g., cylinder gas audit), relative accuracy audit, relative accuracy test audit, or linearity test audit; or iii) The COMS CD exceeds two times the limit in the applicable performance specification in the relevant standard. When the CMS is out of control, the Permittee shall take the necessary corrective action and shall repeat all necessary tests which indicate that the system is out of control until the performance requirements are below the applicable limits. The beginning of the out-of-control period is the hour the Permittee conducts a performance check (e.g., calibration drift) that indicates an exceedance of the performance requirements established under this part. The end of the out-of-control period is the hour following the completion of corrective action and successful demonstration that the system is within the allowable limits. During the period the CMS is out of control, recorded data shall not be used in data averages and calculations, or to meet any data availability requirement. The Permittee shall submit all information concerning out-of-control periods, including start and end dates and hours and descriptions of corrective actions taken, in the excess emissions and continuous monitoring system performance report.

103 Facility Name: Permit Number: MINNESOTA POLLUTION CONTROL AGENCY AIR QUALITY 520 LAFAYETTE ROAD ST. PAUL, M N Ardent Mills Flour Mill Page 30 of Jul, :28 COMPLIANCE PLAN CD CD 40 CFR Section 63.8(d); Minn. R CD 40 CFR Section 63.8(d); Minn. R CD 40 CFR Section 63.8(e)(1) & (2); Minn. R CD 40 CFR Section 63.8(e)(3); Minn. R CD 40 CFR Section 63.8(f); Minn. R CD 40 CFR Section 63.8(g); Minn. R CD Minn. R NOTIFICATION REQUIREMENTS 86.0 CD 40 CFR Section 63.9(b)(4); Minn. R CD 40 CFR Section 63.9(e); Minn. R CD 40 CFR Section 63.9(g)(1) & (3); Minn. R The Permittee shall develop and implement a CMS quality control program. As part of the quality control program, the Permittee shall develop and submit to the Aministrator for approval upon request a site-specific performance evaluation test plan for the CMS performance evaluation required in 40 CFR Section 63.8(e)(3)(i). Each quality control program shall include, at a minimum, a written protocol that describes procedures for each of the following operations: i) Initial and any subsequent calibration of the CMS; ii) Determination and adjustment of the calibration drift of the CMS; iii) Preventive maintenance of the CMS, including spare parts inventory; iv) Data recording, calculations, and reporting; v) Accuracy audit procedures, including sampling and analysis methods; and vi) Program of corrective action for a malfunctioning CMS. The Permittee shall keep these written procedures on record for the life of the affected source, to be made available for inspection, upon request. The Permittee shall keep previous versions of the performance evaluation plan on record to be made available for inspection upon request, for a period of 5 years after each revision to the plan. Performance evaluation of continuous monitoring systems: 1) When required by a relevant standard, and at any other time the Administrator may require, the Permittee shall conduct a performance evaluation of the CMS according to the applicable specifications and procedures described in 40 CFR Section 63.8(e) or in the relevant standard. 2) Notification of performance evaluation. The Permittee shall notify the Administrator in writing of the date of the performance evaluation simultaneously with the notification of the performance test date or at least 60 days prior to the date the performance evaluation is scheduled to begin if no performance test is required. 3) Reporting performance evaluation results. The Permittee shall furnish the Administrator a copy of a written report of the results of the performance evaluation simultaneously with the results of the performance test or within 60 days of completion of the performance evaluation if no test is required, unless otherwise specified in a relevant standard. Use of an alternative monitoring method. Until permission to use an alternative monitoring procedure has been granted by the Administrator under 40 CFR Sections 63.8(f)(1)-(6), as appropriate, the Permittee remains subject to the requirements of 40 CFR Section 63.8 and the relevant standard. Reduction of monitoring data. The Permittee must reduce the monitoring data as specified in 40 CFR Section 63.8(g)(1)-(5). The Permittee of a new or reconstructed major affected source for which an application for approval of construction or reconstruction is required under 40 CFR Section 63.5(d) must provide the following information in writing to the Administrator: 1) A notification of intention to construct a new major-emitting affected source, reconstruct a major-emitting affected source, or reconstruct a major source such that the source becomes a major-emitting affected source; and 2) A notification of the actual date of startup of the source, delivered or postmarked within 15 calendar days after that date. Notification of performance test. The Permittee shall notify the Administrator in writing of his or her intention to conduct a performance test at least 60 calendar days before the performance test is scheduled to begin. Additional notification requirements for sources with CMS. The Permittee shall submit to the Administrator written notification as follows: 1) A notification of the date the CMS performance evaluation under 40 CFR Section 63.8(e) is scheduled to begin, submitted simultaneously with the notification of the performance test date required under 40 CFR Section 63.7(b). If no performance test is required, or if the requirement to conduct a performance test has been waived, the Permittee shall notify the Administrator in writing of the date of the performance evaluation at least 60 calendar days before the evaluation is scheduled to begin; 2) A notification that the criterion necessary to continue use of an alternative to relative accuracy testing, as provided by 40 CFR Section 63.8(f)(6), has been exceeded. The notification shall be delivered or postmarked not later than 10 days after the occurrence of such exceedance.

104 Facility Name: MINNESOTA POLLUTION CONTROL AGENCY Page31of35 14 Jul, :28 AIR QUALITY 520 LAFAYETTE ROAD ST PAUL, MN -SS155-4IM COMPLIANCE PLAN CD-01 Ardent Mills Flour Mill Permit Number: CD 40 CFR Section 63.9(h); Minn. R CD 40 CFR Section 63.9(j); Minn. R Notification of compliance status. Each time a notification of compliance status is required under 40 CFR pt. 63, subp. A, the Permittee shall submit to the Administrator a n otification of compliance status containing the information required by 40 CFR Section 63.9(h), signed by the responsible official who shall certify its accuracy, attesting to whether the source has complied with the relevant standard. The notification must be sent by the 60th day following the completion of the relevant compliance demonstration activity specified in the relevant standard. If no performance test is required but opacity or visible emission observations are required, the notification of compliance status shall be sent by the 30th day following the completion of opacity or visible emission observations. Notifications may be combined as long as the due date requirement for each notification is met. Notification. Any change in the information already provided under 40 CFR Section 63.9 shall be provided to the Administrator in writing within 15 calendar days after the change CD Minn. R RECORDKEEPING AND REPORTING REQUIREMENTS 92.0 CD 40 CFR Section 63.10(a); Minn. R CD 40 CFR Section 63.10(b)(1); Minn. R , subp. 2(B) 94.0 CD 40 CFR Section 63.10(b)(2); Minn. R , subp. 2(B) 95.0 CD 40 CFR Section 63.10(b)(2); Minn. R , subp. 2(B) 96.0 CD 40 CFR Section 63.10(c); Minn. R CD 40 CFR Section 63.10(d)(1); Minn. R CD 40 CFR 63.10(d)(4); Minn. R The Permittee shall submit each report to the Administrator. Recordkeeping. The Permittee shall maintain files of all information (including all reports and notifications) required by 40 CFR pt. 63 in a form suitable and readily available for expeditious inspection and review. The files shall be retained for at least 5 years following the date of each occurrence, measurement, maintenance, corrective action, report, or record. At a m inimum, the most recent 2 years of data must be retained on site. The Permittee shall maintain, at a minimum, the following information in the files: 1) the occurrence and duration of each startup, shutdown, or malfunction of operation; 2) the occurrence and duration of each malfunction of the air pollution control equipment; 3) all maintenance performed on the pollution control equipment; 4) actions taken during periods of startup, shutdown, and malfunction when such actions are different from the procedures specified in the affected source's startup, shutdown, and malfunction plan (SSMP). In this case, the Permittee shall report this action within 2 days of occurrence and follow by a written notification within 7 days of occurrence. 5) all information necessary to demonstrate conformance with the affected source's SSMP and actions taken in accordance with SSMP; 6) each period during which a continuous monitoring system (CMS) is malfunctioning or inoperative; (continued below) (continued from above) 7) all required measurements needed to demonstrate compliance with a relevant standard; 8) all results of performance test, CMS performance evaluations, and opacity and visible emission observations; 9) all measurements as may be necessary to determine the conditions of performance tests and performance evaluations; 10) all CMS calibration checks; 11) all adjustments and maintenance performed on CMS; 12) any information demonstrating whether a source is meeting the requirements for a waiver of record keeping or reporting requirements under this part; 13) all documents supporting initial notifications and notifications of compliance status. Additional recordkeeping requirements for sources with continuous monitoring systems. The Permittee shall maintain records as specified within 40 CFR Sect ion 63.10(c); including CMS measurements (including monitoring data recorded during breakdowns and out-of-control periods) and corrective actions. Notwithstanding the requirements in 40 CFR Sections 63.10(d) and 63.10(e), the Permittee shall submit reports to the Administrator in accordance with the reporting requirements in the relevant standard. Progress reports. The Permittee who is required to submit progress reports as a condition of receiving an extension of compliance under 40 CFR Section 63.6(i) shall submit such reports to the Administrator by the dates specified in the written extension of compliance.

105 Facility Name: MINNESOTA POLLUTION CONTROL AGENCY Page 32 Qf Jul, :28 AIR QUALITY 520 LAFAYETTE ROAD COMPLIANCE PLAN C D-01 Ardent Mills Flour Mill Permit Number: CD 40 CFR Section 63.10(d)(5)(i); Minn. R CD 40 CFR Section 63.10(d)(5)(i); Minn. R CD 40 CFR Section 63.10(d)(5)(i); Minn. R CD 40 CFR Section 63.10(d)(5)(H); Minn. R , subp. 2(B) CD 40 CFR Section 63.10(e)(1); Minn. R CD 40 CFR Section 63.10(e)(3)(i)-(iv); Minn. R CD 40 CFR Section 63.10(e)(3)(v); Minn. R CD 40 CFR Section 63.10(e)(3)(vi); Minn. R Periodic startup, shutdown, and malfunction reports. If actions taken by a Permittee during a startup or shutdown (and the startup or shutdown causes the source to exceed any applicable emission limitation in the relevant emission standards), or malfunction of an affected source (including actions taken to correct a malfunction) are consistent with the procedures specified in the source's startup, shutdown, and malfunction plan, the Permittee shall state such information in a startup, shutdown, and malfunction report. Actions taken to minimize emissions during such startups, shutdowns, and malfunctions shall be summarized in the report and may be done in checklist form. Such a report shall also include the number, duration, and a brief description for each type of malfunction which occurred during the reporting period and which caused or may have caused any applicable emission limitation to be exceeded. Reports shall only be required if a startup or shutdown caused the source to exceed any applicable emission limitation, or if a malfunction occurred during the reporting period. The startup, shutdown, and malfunction report shall consist of a letter, containing the name, title, and signature of the Permittee who is certifying its accuracy, that shall be submitted to the Administrator semiannually. Startup, shutdown, and malfunction report: due 30 days following the end of each calendar half year. The Permittee may submit this simultaneously with the excess emissions and continuous monitoring system performance (or other) reports. The Permittee may request approval to reduce the frequency of reporting the procedures specified in 40 CFR Section 63.10(e)(3). Immediate startup, shutdown, and malfunction reports. Notwithstanding theallowance to reduce the frequency of reporting for periodic startup, shutdown, and malfunction reports, any time an action taken by a Permittee during a startup or shutdown that caused the source to exceed any applicable emission limitation in the relevant emission standards, or malfunction is not consistent with the procedures specified in the affected source's SSMP, the Permittee shall report the actions taken for that event within 2 working days after commencing actions inconsistent with the plan followed by a letter within 7 working days after the end of the event. The immediate report required under this paragraph (d)(5)(ii) shall consist of a telephone call (or facsimile (FAX) transmission) to the Administrator within 2 working days after commencing actions inconsistent with the plan, and it shall be followed by a letter, delivered or postmarked within 7 working days. Additional reporting requirements for sources with continuous monitoring systems 1) When more than one CEMS is used to measure the emissions from one affected source, the Permittee shall report the results as required for each CEMS. Excess emissions and continuous monitoring system performance report and summary report. Excess emissions and parameter monitoring exceedances are defined in relevant standards. The Permittee shall submit an excess emissions and continuous monitoring system performance report and/or a summary report to the Administrator semiannually, except when more frequent reporting is specifically required by a relevant standard or a reduction in frequency is approved pursuant to 40 CFR Section 63.10(e)(3). Content and submittal dates for excess emissions and monitoring system performance reports. All excess emissions and monitoring system performance reports and all summary reports, if required, shall be delivered or postmarked by the 30th day following the end of each calendar half or quarter, as appropriate. Written reports of excess emissions or exceedances of process or control system parameters shall include all the information required in 40 CFR Section 63.10(c)(5)-(c)(13), in 40 CFR Section 63.8(c)(7) and 40 CFR Sectuib 63.8(c)(8), and in the relevant standard, and they shall contain the name, title, and signature of the responsible official who is certifying the accuracy of the report. When no excess emissions or exceedances of a parameter have occurred, or a CMS has not been inoperative, out of control, repaired, or adjusted, such information shall be stated in the report. Summary report. One summary report shall be submitted for the hazardous air pollutants monitored at each affected source (unless the relevant standard specifies that more than one summary report is required. The summary report shall be entitled "Summary Report: Gaseous and Opacity Excess Emission and Continuous Monitoring System Performance" and shall contain the information specified in 40 CFR Section 63.10(e)(3)(vi).

106 Facility Name: Permit Number: MINNESOTA POLLUTION CONTROL AGENCY AIR QUALITY 520 LAFAYETTE ROAD ST PAUL, MN Ardent Mills Flour Mill CD 40 CFR Section 63.10(e)(3)(vii); Minn. R CD 40 CFR Section 63.10(f); Minn. R Page 33 of Jul, :28 COMPLIANCE PLAN CD-01 If the total duration of excess emissions or process or control system parameter exceedances for the reporting period is 1 percent or greater of the total operating time for the reporting period, or the total CMS downtime for the reporting period is 5 percent or greater of the total operating time for the reporting period, both the summary report and the excess emissions and continuous monitoring system performance report shall be submitted. Waiver of recordkeeping or reporting requirements. No requirements required.

107 MINNESOTA POLLUTION CONTROL AGENCY AIR QUALITY 520 LAFAYETTE ROAD ST. P AUL. MN Page 34 of Jul, :28 COMPLIANCE PLAN CD-01 Facility Name: Ardent Mills Flour Mill Permit Number: Subject Item: Associated Items: CE 030 Fabric Filter - Low Temperature, i.e., T<180 Degrees F EU 005 Feed Loadout - Loading-Unloading Equipment N CI CA Type Citation Requirement 1.0 CD Minn. R (G) The operation of this piece of control equipment is not necessary in order for the process to meet applicable emissions limits. However, the Permittee wishes to take credit for its operation for the purposes of reporting actual emissions for emission inventory. Therefore, in order for, 10, and 2.5 to be considered controlled for the purposes of emissions inventory, the fabric filter must comply with the requirements of this permit during the time credit for control is taken. The, 10, and 2.5 generated during that time shall be considered controlled, and the control efficiency used is the limit given in this table. 2.0 LIMIT Minn. R (G) Total Particulate Matter: greater than or equal to 79 percent control efficiency (capture efficiency x collection efficiency) 3.0 LIMIT Minn. R , subp. 3(E) Total Particulate Matter: greater than or equal to 80 percent collection efficiency 4.0 LIMIT Minn. R (G) < 10 micron: greater than or equal to 74 percent control efficiency (capture efficiency x collection efficiency) 5.0 LIMIT Minn. R (G) < 2.5 micron: greater than or equal to 74 percent control efficiency (capture efficiency x collection efficiency) 6.0 CD Minn. R (G) The Permittee shall operate and maintain the fabric filter in accordance with the Operation and Maintenance (O & M) Plan. The Permittee shall keep copies of the O & M Plan available onsite for use by staff and MPCA staff. 7.0 LIMIT Minn. R (G) Pressure Drop: greater than or equal to 0.5 inches of water column and less than or equal to 8 inches of water column unless a new range is set pursuant to Minn. R , subp. 3 based on the values recorded during the most recent MPCA-approved performance test where compliance was demonstrated. The new range shall be implemented upon receipt of the Notice of Compliance letter granting preliminary approval. The range is final upon issuance of a permit amendment incorporating the change. 8.0 CD Minn. R (G) Visible Emissions: The Permittee shall check the fabric filter stack (SV 016) for any visible emissions once each day of operation during daylight hours. During inclement weather, the Permittee shall read and record the pressure drop across the fabric filter, once each day of operation. 9.0 CD Minn. R (G) Recordkeeping of Visible Emissions and Pressure Drop. The Permittee shall record the time and date of each visible emission inspection and pressure drop reading, and whether or not any visible emissions were observed, and whether or not the observed pressure drop was within the range specified in this permit 10.0 CD Minn. R (G) Periodic Inspections: At least once per calendar quarter, or more frequently as required by the manufacturing specifications, the Permittee shall inspect the control equipment components. The Permittee shall maintain a written record of these inspections CD Minn. R (G) Corrective Actions: The Permittee shall take corrective action as soon as possible if any of the following occur: - visible emissions are observed; or - the recorded pressure drop is outside the required operating range; or - the fabric filter or any of its components are found during the inspections to need repair. Corrective actions shall eliminate visible emissions, and/or return the pressure drop to within the permitted range, and/or include completion of necessary repairs identified during the inspection, as applicable. Corrective actions include, but are not limited to, those outlined in the O & M Plan for the equipment. The Permittee shall keep a record of the type and date of any corrective action taken CD Minn. R , subp. 4 Monitoring Equipment: The Permittee shall install and maintain the necessary monitoring equipment for measuring and recording pressure drop as required by this permit. The monitoring equipment must be installed, in use, and properly maintained when the monitored cyclones are in operation.

108 Facility Name: MINNESOTA POLLUTION CONTROL AGENCY page 35 of ju!i :28 AIR QUALITY 520 LAFAYETTE ROAD s, ' AUL '" N!i,,s -"" COMPLIANCE PLAN CD-01 Ardent Mills Flour Mill Permit Number: Subject Item: FS 001 Fugitive HAP Sources (Fumigation, Preservation, etc.) NC/ CA Type Citation Requirement 1.0 LIMIT Title I Condition: Avoid major source under 40 CFR 63.2 and Minn. R ; Avoid major source under 40 CFR 70.2 and Minn. R LIMIT Title I Condition: Avoid major source under 40 CFR 63.2 and Minn. R ; Avoid major source under 40 CFR 70.2 and Minn. R CD Title I Condition: Avoid major source under 40 CFR 63.2 and Minn. R ; Avoid major source under 40 CFR 70.2 and Minn. R HAP-Single: less than or equal to 9.0 tons/year using 12-month Rolling Sum to be calculated by the 15th day of each month for the previous 12-month period as described later in this permit. All fugitive HAP sources shall be included in this calculation. HAP con tents for each material shall be determined as described under the Material Content requirement. Includes each individual HAP used in non-combustion sources, including those used for water purification and product preservation. HAPs - Total: less than or equal to 20.0 tons/year using 12-month Rolling Sum to be calculated by the 15th day of each month for the previous 12-month period as described later in this permit. All fugitive HAP sources shall be included in this calculation. HAP contents for each material shall be determined as described under the Material Content requirement. Includes all HAP used in non-combustion sources, including those used for water purification and product preservation. Daily Recordkeeping. On each day of operation, the Permittee shall calculate, record, and maintain records of the total quantity of all HAP-containing materials used at the facility. This shall be based on written usage logs. 4.0 CD Minn. R , subps. 4-5 Monthly Recordkeeping - HAP Usage. By the 15th day of each month, the Permittee shall calculate and record the following: 1) The quantity of each HAP-containing material used in the previous calendar month using the daily usage records. This record shall include the individual HAP content of each material as determined by the Material Content requirement of this permit. 2) The quantity of each individual HAP used in the previous month using the formulas specified in this permit. 3) The 12 month rolling sum of each individual HAP used for the previous 12 month period by summing the quantities calculated for that HAP for the previous 12 months. 4) The Total HAP usage for the previous month, by summing the quantities of each individual HAP used during the previous month. 5) the 12-month rolling sum of Total HAP for the previous 12 months, by summing the Total HAP usage calculated for each of the previous 12 months. 5.0 CD Minn. R , subps. 4-5 Monthly Calculation - Individual HAP Usage. The Permittee shall calculate the monthly quantity of each individual HAP using the following equations: HAP A (tons/month) = (A1 x B1) + (A2 x B2) + (A3 x B3) + Where: HAP A = total quantity of HAP A used in tons/month; A# = amount of each HAP A-containing material used, in tons/month; B# = weight percent of HAP A in A#, as a fraction 6.0 CD Minn. R , subps. 4 and 5 Material Content. HAP contents in materials shall be determined by the Material Safety Data Sheet (MSDS) provided by the supplier for each material used. If a material content range is given on the MSDS, the highest number in the range shall be used in all compliance calculations. Other alternative methods approved by the MPCA may be used to determine the HAP content. The MPCA reserves the right to require the Permittee to determine the HAP content of any material, according to EPA or A STM reference methods. If an EPA or ASTM reference method is used for material content determination, the data obtained shall supersede the MSDS.

109 Attachment 2 - Calculations

110 MINNESOTA POLLUTION CONTROL AGENCY 2 June, :41 AIR QUALITY ' ft^a N 5E 5i5 5 A 4 94 FACILITY DESCRIPTION: Potential-to-emit (by pollutant) Show: Active and Pending Records AQD Facility ID: Facility Name: Ardent Mills Flour Mill Pollutant Item Added By (Action) Retired By (Action) Hourly Potential (lbs per hr) Unrestricted Potential (tons per yr) Limited Potential (tons per yr) Actual Emissions (tons per yr) Acetaldehyde EU 009 PER E E E-02 Totals 0.000E+00 O.OOOE+OO O.OOOE+OO Acrolein EU 009 PER E E E-02 Totals 1.750E E-02 O.OOOE+OO Benzene EU 001 PER E E E-04 EU 009 PER E E E-03 Totals 4.467E E E+00 Arsenic compounds EU 001 PER E E QE-04 Totals 2.460E E E+00 Biphenyl EU 009 PER E E E-06 Totals 8.860E E-06 O.OOOE+OO Bromomethane FS 001 PER E+00 FS 001 PER E+00 Totals 0.000E E+00 O.OOOE+OO 1,3-Butadiene EU 009 PER E E E-03 Totals 1.840E E-03 O.OOOE+OO Beryllium EU 001 PER E E E-04 Totals 1.470E E-04 O.OOOE+OO Carbon tetrachloride EU 009 PER E E E-04 Totals 1.360E E-04 O.OOOE+OO Carbon Dioxide Equivalent EU 001 PER E+03 EU 009 PER E+02 Totals 0.000E O.OOOE+OO Chlorobenzene EU 009 PER E E E-05 Totals 0.000E+00 O.OOOE+OO O.OOOE+OO Page 1 of 6

111 MINNESOTA POLLUTION CONTROL AGENCY 2 June, :41 AIR QUALITY ' ^20 I AFAY FTTF ROAD ST PAUL MN 55i FACILITY DESCRIPTION: Potential-to-emit (by pollutant) Show: Active and Pending Records AQD Facility ID: Facility Name: Ardent Mills Flour Mill Pollutant Item Added By (Action) Retired By (Action) Hourly Potential (lbs per hr) Unrestricted Potential (tons per yr) Limited Potential (tons per yr) Actual Emissions (tons per yr) Chloroform EU 009 PER E E E-04 Totals 1.060E E E+00 Cadmium compounds EU 001 PER E E E-04 Totals 0.000E+00 O.OOOE+OO O.OOOE+OO Methane EU 001 PER E E E-01 EU 009 PER E E E-03 Totals 3.910E E-01 O.OOOE+OO Carbon Monoxide EU 001 PER E E E+00 EU 009 PER E E E+00 Totals 7.290E E+00 O.OOOE+OO Carbon Dioxide EU 001 PER E E E+03 EU 009 PER E E E+02 Totals 9.752E E E+00 Cobalt compounds EU 001 PER E E E-06 Totals 0.000E E E+00 Chromium compounds EU 001 PER E E E-03 Totals 0.000E E+00 O.OOOE+OO 1,4-Dichlorobenzene EU 001 PER E E E-05 Totals 6.700E E-05 O.OOOE+OO 1,3-Dichloropropene EU 009 PER E E E-05 Totals O.OOOE+OO 0.000E+00 O.OOOE+OO Ethylbenzene EU 009 PER E E E-04 Totals 2.420E E-04 O.OOOE+OO Formaldehyde EU 001 PER E-03 2.S60E E-02 EU 009 PER E E E-01 Totals 1.496E E-01 O.OOOE+OO Page 2 of 6

112 MINNESOTA POLLUTION CONTROL AGENCY 2 June, :41 AIR QUALITY ' ST FACILITY DESCRIPTION: Potential-to-emit (by pollutant) Show: Active and Pending Records AQD Facility ID: Facility Name: Ardent Mills Flour Mill Pollutant Item Added By (Action) Retired By (Action) Hourly Potential (lbs per hr) Unrestricted Potential (tons per yr) Limited Potential (tons per yr) Actual Emissions (tons per yr) Hexane EU 001 PER E E E-01 EU 009 PER E E E-04 Totals 1.010E E-01 O.OOOE+OO Methanol EU 009 PER E E E-03 Totals 5.560E E-03 O.OOOE+OO Naphthalene EU 001 PER E E E-05 Totals O.OOOE+OO 0.000E+00 O.OOOE+OO HAPs - Total EU 001 PER E E E-01 EU 009 PER E E E-01 FS 001 PER E+00 FS 001 PER E+01 Totals 2.830E E+01 O.OOOE+OO Mercury EU 001 PER E E E-04 Totals 1.760E E-04 O.OOOE+OO Phenol EU 009 PER E E E-05 Totals 0.000E+00 O.OOOE+OO O.OOOE+OO Styrene EU 009 PER E E E-04 Totals 0.000E+00 O.OOOE+OO O.OOOE+OO 1,1,2,2-Tetrachloroethane EU 009 PER E E E-04 Totals 1.490E E-04 O.OOOE+OO Toluene EU 001 PER E E E-04 EU 009 PER E E E-03 Totals 1.900E E-04 O.OOOE+OO 1,1,2-Trichloroethane EU 009 PER E E E-04 Totals O.OOOE+OO O.OOOE+OO O.OOOE+OO Page 3 of 6

113 MINNESOTA POLLUTION CONTROL AGENCY 2 June, :41 AIR QUALITY ' :"i^wj AY MN T FACILITY DESCRIPTION: Potential-to-emit (by pollutant) Show: Active and Pending Records AQD Facility ID: Facility Name: Ardent Mills Flour Mill Pollutant Item Added By (Action) Retired By (Action) Hourly Potential (lbs per hr) Unrestricted Potential (tons per yr) Limited Potential (tons per yr) Actual Emissions (tons per yr) Vinyl chloride EU 009 PER E E E-05 Totals 0.000E+00 O.OOOE+OO O.OOOE+OO Xylenes (mixed isomers) EU 009 PER E E E-04 Totals O.OOOE+OO O.OOOE+OO O.OOOE+OO 2,2,4-trimethyipentane EU 009 PER E E E-03 Totals 1.900E E-03 O.OOOE+OO Manganese compounds EU 001 PER E E E-04 Totals 8.210E E-04 O.OOOE+OO Ethylene dibromide (dibromoeth EU 009 PER E E E-04 Totals 1.650E E-04 O.OOOE+OO Nitrous Oxide EU 001 PER E E E-02 EU 009 PER E E E-04 Totals 7.700E E-02 O.OOOE+OO Methylene chloride (dichlorome EU 009 PER E E E-04 Totals O.OOOE+OO 0.000E+00 O.OOOE+OO Total Polycyciic aromatic hydr EU 009 PER E E E-04 Totals 2.920E E E+00 Nickel compounds.eu 001 PER E E E-03 Totals O.OOOE+OO O.OOOE+OO O.OOOE+OO Nitrogen Oxides EU 001 PER E E E+00 EU 009 PER E E E+00 Totals 1.444E E E+00 < 2.5 micron EU 001 PER E E E-01 ' EU 002 PER E E-01 EU 003 PER E E E-02 EU 004 PER E E E+01 Page 4 of 6

114 MINNESOTA POLLUTION CONTROL AGENCY 2 June :41 AIR QUALITY ' ' ST. PAUL, MN FACILITY DESCRIPTION: Potential-to-emit (by pollutant) Show: Active and Pending Records AQD Facility ID: Facility Name: Ardent Mills Flour Mill Pollutant Item Added By (Action) Retired By (Action) Hourly Potential (lbs per hr) Unrestricted Potential (tons per yr) Limited Potential (tons per yr) Actual Emissions (tons per yr) < 2.5 micron EU 005 PER E E-02 EU 006 PER E E+00 2.E-01 EU 007 PER E E-02 EU 008 PER E E E+00 EU 009 PER E E E-05 GP 004 PER E-01 Totals 1.852E E E+00 Lead EU 001 PER E E E-03 EU 001 PER E E E-04 Totals 0.000E E+00 O.OOOE+OO < 10 micron EU 001 PER E E E-01 EU 001 PER E E E-01 EU 002 PER E E E-01 EU 002 PER E E E+00 EU 003 PER E E E-02 EU 003 PER E E E-02 EU 004 PER E E E+01 EU 004 PER E E E+01 EU 005 PER E E E-02 EU 005 PER E E-02 O.OOOE+OO EU 006 PER E E E-01 EU 006 PER E E E-01 EU 007 PER E E E-01 EU 007 PER E E+00 O.OOOE+OO EU 008 PER E E E+00 EU 008 PER E E E+00 EU 009 PER E E E-05 GP 004 PER E-01 Totals 1.090E E+01 O.OOOE+OO Polycyclic organic matter EU 001 PER E E E-03 Totals O.OOOE+OO 0.000E+00 O.OOOE+OO Total Particulate Matter EU 001 PER E E E+00 Page 5 of 6

115 MINNESOTA POLLUTION CONTROL AGENCY 2 June, :41 AIR QUALITY ' ft PA A ut Y MN T 55i5 5 A 4 94 FACILITY DESCRIPTION: Potential-to-emit (by pollutant) Show: Active and Pending Records AQD Facility ID: Facility Name: Ardent Mills Flour Mill Pollutant Item Added By (Action) Retired By (Action) Hourly Potential (lbs per hr) Unrestricted Potential (tons per yr) Limited Potential (tons per yr) Actual Emissions (tons per yr) Total Particulate Matter EU 002 PER E E E-01 EU 002 PER E E E+00 EU 003 PER E E E-02 EU 004 PER E E+04 1,831 E+02 EU 005 PER E E E-01 EU 005 PER E E-01 O.OOOE+OO EU 006 PER E E E-01 EU 007 PER E E E-01 EU 007 PER E E E+00 EU 008 PER E E E+00 EU 008 PER E E E+00 EU 009 PER E E E-05 GP 004 PER E-01 Totals 2.187E E+02 O.OOOE+OO Selenium compounds EU 001 PER E E E-05 Totals 1.340E E-05 O.OOOE+OO HAP-Single FS 001 PER E+00 FS 001 PER E+00 Totals 0.000E E E+00 Sulfur Dioxide EU 001 PER E+00 3.Q16E E+01 EU 009 PER E E E-03 Totals 3.017E E+01 O.OOOE+OO Volatile Organic Compounds EU 001 PER E-02 3.E-01 3.E-01 EU 009 PER E E E+00 FS 001 PER E+00 FS 001 PER E+01 Totals 2.110E E+01 O.OOOE+OO Page 6 of 6

116 EU001 (Boiler) Fuels: Natural Gas No. 2 Fuel Oil MMBtu/hr (total) 1050 MMBtu/mmcf 0.50 % sulfur Btu/gal 0.14 MMBtu/gallon Fuel Consumption: Emission Factors Gas 7.6 Oil Natural Gas Fuel Oil S mmcf/hour ((MMBtu/hr)/(MMBtu/mmcf)) gallons/hour ((M MBtu/hr)/(MMBtu/gallon)) NO x 0.02 CO VOC Lead Ib/mmcf lb/gallon kgal/hr Potential Emissions Nat Gas Fuel Oil so NO x CO VOC Lead lb/hour lb/hour Worst: lb/hour tpy Emission factor source: AP-42, sections 1.3 (Fuel Oil Combustion) and 1.4 (Natural Gas Combustion) Generator - EU009 output capacity = voltage (asssumed) = power output = Btu/hour equivalent = Btu/hour input = 250 amps 480 Volts watts (volts x amps) Btu/hour Btu/hour (assuming 80% engine efficiency) MMBtu/hr Emission Factors Hourly emissions E E E E E E-05 S E E-03 NO x E E+00 CO E E+00 VOC E E+00 tpy Ib/mmbtu lb/hour Emission Factor source:the engine is identified as a CI engine that burns natural gas, so emission factors for Dual-fuel engines were used (CI engin es burning primarily natural gas with a small amount of diesel fuel); other o ption was to use emission factors for gas-fired SI engines. Since the engine is so small, the emissions do not make a regulatory difference in the facility PTE, so the emission factors chosen are probably irrelevant. S content of diesel assumed to be 0.05% S content of natural gas assumed to be 2000 gr /mmcf (AP-42 Section 1.4) Ib/ mmcf density of natural gas = lb/ft 3 ( Ib/mmcf S content = % emission factor in AP-42 listed as "ND" so was used to represent the neglible emissions.,

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118 Combustion HAP Boiler - EU mmcf/hr nat gas kgal/hr distillate oil Gas Dist Oil Gas Dist oil Worst Worst (Ib/mmcf) (Ib/kgal) Ib/hr Ib/hr Ib/hr tpy 1,4-dichlorobenzene E E E-05 Benzene E E E-04 Formaldehyde E E E E-02 Hexane E E E-01 Naphthalene E E E-05 Toluene E E E-04 POM E E E E-03 Arsensic E E E E-04 Beryllium E E E E-04 Cadmium E E E E-04 Cobalt E E E-06 Chromium E E E E-03 Manganese E E E E-04 Mercury E E E E-04 Nickel E E E E-03 Selenium E E E-05 Lead E E E E-04 Total 2.41 E E E E-01 Emission factor source: AP-42, sections 1.3 (Fuel Oil. Combustion) and 1.4 (Natural Gas Combustion) Generator - EU009 Emission factor source: AP-42, section 3.2 (Natural Gas-fired Reciprocating Engines (only NG-fired engine HAP fact Used factor for 2-stroke lean burn engines, as those were worst-case Ib/mmBtu NG factor 2-stroke lean Ib/MMBtu Ib/hr tpy benzene 0, E E-03 ethylbenzene E E-04 chlorobenzene 4.444E E E-05 chloroform E E-04 styrene E E-04 ethylene dibromide E E-04 phenol E E-05 biphenyl 3.95E E E-06 carbon tetrachloride E E-04 hexane E E-04 methylene chloride E E-04 methanol E E-03 Toluene E E-03 xylene E E-04 1,3-butadiene E E-03 formaldehyde E E-01 acetaldehyde E E-02 Page 1

119 EU001 - natural gas Natural Gas Emission Emission Emissions Usage Rate PTE C0 2e PTE Pollutant Factor Factor Units Emissions Factor Source (MMBtu/hr) (lbs/hr) (tons/year) Multiplier (tons/year) co lbs/mmbtu 40 CFR Part 98 Subpart C Table C-l , CH E-03 lbs/mmbtu 40 CFR Part 98 Subpart C Table C N 2 O 2.20E-04 lbs/mmbtu 40 CFR Part 98 Subpart C Table C Total 6, EU001 - distillate oil - worst case for all pollutants Natural Gas Emission Emission Emissions Usage Rate PTE C0 2e PTE Pollutant Factor Factor Units Emissions Factor Source (MMBtu/hr) (lbs/hr) (tons/year) Multiplier (tons/year) co lbs/mmbtu 40 CFR Part 98 Subpart C Table C-l , CH E-03 lbs/mmbtu 40 CFR Part 98 Subpart C Table C N 2 O 1.32E-03 lbs/mmbtu 40 CFR Part 98 Subpart C Table C Total 9, EU009 - natural gas Natural Gas Emission Emission Emissions Usage Rate PTE C0 2e PTE Pollutant Factor Factor Units Emissions Factor Source (MMBtu/hr) (lbs/hr) (tons/year) Multiplier (tons/year) CO, lbs/mmbtu 40 CFR Part 98 Subpart C Table C-l CH E-03 lbs/mmbtu 40 CFR Part 98 Subpart C Table C E E N 2 O 2.20E-04 lbs/mmbtu 40 CFR Part 98 Subpart C Table C E E Total