DRAFT. AIR EMISSION PERMIT NO Major Amendment. Central MN Renewables

Transcription

1 DRAFT AIR EMISSION PERMIT NO Major Amendment Central MN Renewables CENTRAL MN RENEWABLES 7936 Heron Little Falls, Morrison 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 and construct 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; Limits to Avoid Part 70/Limits to Avoid NSR/Limits to Avoid Part 63 State Operating Permit Issue Date: 04/28/995 Major Amendment Issue Date: < > 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 Linc Stine Commissioner Minnesota Pollution Control Agency TDD (for hearing and speech impaired only): (65) Printed on recycled paper containing at least 0% fibers from paper recycled by consumers

2 Permit Applications Table Permit Type Application Date Permit Action Total Facility Operating Permit April 28, Major Amendment March 9, Minor Amendment March 9, Major Amendment January 03, Major Amendment October 3, * Major Amendment January 2, 202 N/A** Major Amendment January 23, Major Amendment June 25, Administrative Amendment January 26, Major Amendment February, 205 Updated and certified July 20, **This application was updated through the /23/202 submittal. TABLE OF CONTENTS Notice to the Permittee Permit Shield Facility Description Description of Changes to the Facility Table A: Limits and Other Requirements Table B: Submittals Appendix I: Insignificant Activities and Applicable Requirements Appendix II: Modeling Parameters Appendix III: Stack Test Methods and Parameter Recording Requirements Appendix IV: Emission Unit Data for Flexible Permitting

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 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.

4 FACILITY DESCRIPTION: Central Minnesota Renewables (Facility) is a fuel grade ethanol production plant in Little Falls, Minnesota. The facility receives corn and processes it by milling, fermenting and distilling. Ethanol is then denatured by adding gasoline. Denatured ethanol is the final product. Coproducts of ethanol production are distillers dried grain with solubles (DDGS) which is used primarily as livestock feed, wetcake and corn oil. The primary emissions are VOCs, PM/PM 0 /PM 2.5, NO x, CO, and greenhouse gases. The plant is designed and permitted to produce 22 million gallons of 200 proof ethanol annually. The primary pieces of control equipment include fabric filters to control PM/PM 0 /PM 2.5 from the corn receiving and handling and DDGS handling and loadout; a scrubber, CE002, to control VOC and HAP emissions from fermentation; a scrubber, CE003, to control VOC and HAP emissions from distillation; a regenerative thermal oxidizer, CE006, to control VOC, HAP, PM/PM 0 /PM 2.5, and CO emissions from DDGS cooling, DDGS drying, and ethanol loading; and a backup flare, CE007, to control VOC and HAP emissions from ethanol loading. The facility has a denatured ethanol storage tank equipped with an internal floating roof as required by 40 CFR pt. 60, subp. Kb. Emissions from process valves and piping are controlled through an inspection and maintenance program that meets the requirements of 40 CFR pt. 60, subp. VVa. The permit contains conditions limiting the air emissions to less than the major source thresholds of 40 CFR 70.2 (Part 70 permit program) and 40 CFR 52.2 (Prevention of Significant Deterioration). DESCRIPTION OF CHANGES AUTHORIZED BY THIS PERMIT ACTION Administrative Amendment received January 6, 205. This permit action will incorporate a name change from Central MN Ethanol Cooperative to Central MN Renewables. Major Amendment received February, 205, updated July 205. This permit action will allow for the conversion of the facility from a fuel ethanol facility to facility which produces 3.82 million gallons per year (mgy) acetone, 2.25 mgy butanol and 0.34 mgy 40 proof ethanol (ABE). Core to the transition is the construction of a new distillation train for ABE production. The permit (SV005) states that the facility may operation EU05 EU08 (ethanol only distillation related units) until the facility has installed and commenced operation of EU047 EU049, and EU05 (ABE distillation related units). The distillation trains may at no time operate simultaneously. The front end (Corn Receiving & Storage, Dry Milling, Cooking, and Saccarification) of the existing plant will be used with little modification. Pre fermentation, seed, fermentation (existing tanks being fully utilized), separation, in situ separation of solvents, product distillation, product storage (acetone all new; n butanol uses existing ethanol tanks; ethanol uses existing denaturant tank), and evaporation & drying (DFS) will all be upgrades to the existing facility. The existing ethanol distillation and dehydration will be permanently disabled when the ABE Process is started up. The Facility will be installing new equipment for the handling and loadout of dried fermenter solids (DFS). This is the high protein cell mass that comes from the spent fermentation broth. Emission characteristics are similar to that of DDGS.

5 Facility Name: Central MN Renewables Permit Number: A- 07/22/5 Table A contains limits and other requirements with which your facility must comply. The limits are located in the first column of the table (What To do). The limits can be emission limits or operational limits. This column also contains the actions that you must take and the records you must keep to show that you are complying with the limits. The second column of Table A (Why to do it) lists the regulatory basis for these limits. Appendices included as conditions of your permit are listed in Table A under total facility requirements. Subject Item: Total Facility What to do SOURCE-SPECIFIC REQUIREMENTS Construction Authorization: The Permittee is authorized to install and operate EU047 - EU07 as defined by the emissions unit information in Appendix II of this permit within 24 months after permit issuance of Permit No The units shall meet all the requirements of this permit. Once EU047, EU048, EU049 and EU05 are operational, EU05, EU06, EU07 and EU08 will no longer be authorized to operate and shall be permanently disabled. After the transition from ethanol production to butanol production, TK002 will be used for 40-proof ethanol storage; and TK003, TK004 and TK005 for butanol storage. Production: less than or equal to million gallons/year using 2-month Rolling Sum of fuel ethanol (prior to addition of denaturant gasoline) when not operating as an ABE facility, to be calculated by the 5th day of each month for the previous 2-month period as described later in this permit. Production: less than or equal to 6.4 million gallons/year using 2-month Rolling Sum of product when operating as an ABE facility including ) fuel ethanol (prior to addition of denaturant gasoline), 2) butanol and 3) acetone to be calculated by the 5th day of each month for the previous 2-month period as described later in this permit. Process Throughput: less than or equal to tons/year using 2-month Rolling Sum of corn to be calculated by the 5th day of each month for the previous 2-month period as described later in this permit. This is based on a 56-pound bushel which is equivalent to 8.5 million bushels per year. Why to do it Minn. R , subp. 2 To avoid major source under 40 CFR 63.2 To avoid major source under 40 CFR 63.2 source under 40 CFR 70.2 & Minn. R Grain received by the facility shall only be used for production of ethanol, butanol, acetone and coproducts by the Permittee at the Central MN Renewables facility (ID No ). Fugitive Emissions: The Permittee shall clean up commodities spilled on the driveway and other facility property as required to minimize fugitive emissions to a level consistent with RACT (reasonably available control technology), and maintain air pollution control equipment in proper operating condition, and utilize the air pollution control systems as designed. Comply with Fugitive Emission Control Plan: The Permittee shall follow the actions and recordkeeping specified in the control plan. The plan may be amended by the Permittee with the Commissioner's approval. To change elements listed in FS006 (Unpaved s) will require a reassessment of BACT equivalency. If the Commissioner determines the Permittee is out of compliance with Minn. R or the fugitive control plan, then the Permittee may be required to amend the control plan and/or to install and operate particulate matter ambient monitors as requested by the Commissioner. Permit Appendices: This permit contains appendices as listed in the permit Table of Contents. The Permittee shall comply with all requirements contained in Appendices I, III and IV. Modeling parameters in Appendix II are included for reference only as described elsewhere in Table A. Flexible Permit Language: This permit establishes limits on the facility to keep it a minor source under New Source Review and Part 70. The Permittee cannot 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. Equipment Labeling: The Permittee shall permanently affix a unique number to each emissions unit for tracking purposes. The numbers shall correlate the unit to the appropriate EU and GP numbers used in this permit. The number can be affixed by placard, stencil, or other means. The number shall be maintained so that it is readable and visible at all times from a safe distance. If equipment is added, it shall be given a new unique number; numbers from replaced or removed equipment shall not be reused. source under 40 CFR 70.2 & Minn. R Minn. R , subp. (A)-(B) Minn. Stat. Section 6.07, subd. 4a; Minn. R ; Minn. R , subp. 2; Minn. R ; Minn. R Minn. Stat. Section 6.07, subds. 4a & 9; Minn. R , subp. 7(A), 7(L), & Minn. R , subps., 2 & 4; Minn. R ; Minn. R , subp. 2 source under 40 CFR 70.2 & Minn. R Minn. R , subp. 2

6 Facility Name: Central MN Renewables Permit Number: A-2 07/22/5 Equipment Inventory: The Permittee shall maintain a written list of all control equipment on site. The Permittee shall update the list to include any replaced, modified, or new equipment prior to making the change. Minn. R , subp. 2 The list shall correlate the units to the numbers used in this permit (EU, GP, CE) and shall include the data on GI-05C. The date of construction shall be the date the change was made for replaced, modified, or new equipment. OPERATIONAL REQUIREMENTS The Permittee shall comply with National Primary and Secondary Ambient Air Quality Standards, 40 CFR pt. 50, and the Minnesota Ambient Air Quality Standards, Minn. R to Compliance shall be demonstrated upon written request by the MPCA. 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. 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, 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 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. 6. PERFORMANCE TESTING Performance Testing: Conduct all performance tests in accordance with Minn. R. ch. 707 unless otherwise noted in Tables A, B, and/or C. Performance Test Notifications and Submittals: Performance Tests are due as outlined in Table A of the permit. See Table B for additional testing requirements. Performance Test Notification (written): due 30 days before each Performance Test Performance Test Plan: due 30 days before each Performance Test Performance Test Pre-test Meeting: due 7 days before each Performance Test Performance Test Report: due 45 days after each Performance Test Performance Test Report - Microfiche Copy: due 05 days after each Performance Test Minn. Stat. Section 6.07, subds. 4a & 9; Minn. R , subp. 7(A), 7(L), & 7(M); Minn. R , subps., 2 & 4; Minn. R Minn. R Minn. R , subp. 2; Minn. R , subp. 6(J) Minn. R , subps. 4 and 6(J) Minn. R , subp. 4 Minn. R Minn. R Minn. R , subp. 9(A) Minn. R , subp. 6 Minn. R. ch. 707 Minn. R ; Minn. R , subps. -4, Minn. R , subps. -2 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 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. Minn. R , subp. 3

7 Facility Name: Central MN Renewables Permit Number: A-3 07/22/5 MONITORING REQUIREMENTS Monitoring Equipment Calibration - The Permittee shall either: Minn. R , subp. 4(D). Calibrate or replace required monitoring equipment every 2 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. If monitoring records are required, they should reflect any such periods of process shutdown or checks of the monitoring system. MODELING REQUIREMENTS Minn. R , subp. 4(D) Minn. R , subp. 2 NOTE: Modeling is based upon operation in ABE mode. The Permittee shall install and maintain fencing around the facility. In areas where fencing is not permissible by setbacks, right-of-ways, safety concerns, or clearances, the Permittee shall install and maintain signs and conduct patrols to sufficiently restrict public access to the property outlined as fenced in the dispersion modeling. Modeled Parameters for : The parameters used in modeling for permit number are listed in Appendix II of this permit. The parameters describe the operation of the facility at maximum permitted capacity when it is producing acetone, butanol, ethanol and other coproducts. The purpose of listing the parameters in the appendix is to provide a benchmark for future changes. Equivalent or Better Dispersion (EBD) Modeling Triggers (Modeling Not Required) for : Changes that do not require a permit amendment or that require an administrative permit amendment do not trigger the EBD Modeling Submittal requirement. The Permittee shall keep updated records on site of all modeled parameters and emission rates listed in Appendix II. The Permittee shall submit any changes to modeled parameters and emission rates with the next required modeling submittal. (Tier 3) EBD Modeling Triggers (Modeling Required) for : Changes that require, or would require, a minor, moderate or major permit amendment due to an increase in emissions and affect any modeled parameter or emission rate listed in Appendix II, or an addition to the information documented in Appendix II, trigger the EBD Remodeling Submittal requirement. The Permittee shall include previously made changes to modeled parameters and emission rates listed in Appendix II that did not previously trigger the EBD Modeling Submittal requirement with this modeling submittal. (Tier 3) Submit: due before end of each 60 months following Permit Issuance an EBD Modeling analysis for : The Permittee shall submit an EBD Modeling Submittal that addresses any changes made during the previous five years that did not require a permit amendment but that affected any modeled parameter or emission rate documented in Appendix II or an addition to the information documented in Appendix II and that did not trigger the EBD Modeling Triggers (Modeling Required) requirement. If no changes were made, send a letter to the Commissioner stating that no EBD Modeling Analysis was required. EBD Modeling Submittal for : For changes meeting the criteria in the EBD Modeling Triggers (Modeling Required) requirement, the Permittee shall submit an EBD modeling submittal in accordance with the current version of the MPCA Air Dispersion Modeling Guidance and shall wait for written approval (for major amendments, in the form of an issued permit amendment; for moderate amendments, in the form of a construction authorization letter) before making such changes. For minor amendments, written approval of the EBD modeling may be given before permit issuance; however, this approval applies only to the EBD modeling and not to any other changes. (Tier 3) EBD Modeling Submittal Content for : The information submitted must include, for stack and vent sources, source emission rate, location, height, diameters, exit velocity, exit temperature, discharge direction, use of rain caps or rain hats, and, if applicable, locations and dimensions of nearby buildings. For non-stack/vent sources, this includes the source emission rate, location, size and shape, release height, and, if applicable, any emission rate scalars, and the initial lateral dimensions and initial vertical dimensions and adjacent building heights. Minn. Stat. Section 6.07, subds. 4a & 9; Minn. R , subp. 7(A), 7(L), & 7(M); Minn. R , subps., 2 & 4; Minn. R Minn. Stat. Section 6.07, subds. 4a & 9; Minn. R , subp. 7(A), 7(L), & 7(M); Minn. R , subps., 2 & 4; Minn. R Minn. Stat. Section 6.07, subds. 4a & 9; Minn. R , subp. 7(A), 7(L), & 7(M); Minn. R , subps., 2 & 4; Minn. R Minn. Stat. Section 6.07, subds. 4a & 9; Minn. R , subp. 7(A), 7(L), & 7(M); Minn. R , subps., 2 & 4; Minn. R Minn. Stat. Section 6.07, subds. 4a & 9; Minn. R , subp. 7(A), 7(L), & 7(M); Minn. R , subps., 2 & 4; Minn. R Minn. Stat. Section 6.07, subds. 4a & 9; Minn. R , subp. 7(A), 7(L), & 7(M); Minn. R , subps., 2 & 4; Minn. R Minn. Stat. Section 6.07, subds. 4a & 9; Minn. R , subp. 7(A), 7(L), & 7(M); Minn. R , subps., 2 & 4; Minn. R

8 Facility Name: Central MN Renewables Permit Number: A-4 07/22/5 Outdated EBD Baseline Modeling for : Prior to conducting the EBD analysis, the Permittee shall use the current version of the MPCA Air Dispersion Modeling Guidance to determine if the Baseline Modeling (the most recent refined modeling demonstration) is outdated. If the Baseline Modeling is outdated, the Permittee shall update the Baseline Modeling to be consistent with the current version of the MPCA Air Dispersion Modeling Guidance. The updated modeling will become the new Baseline Modeling. This requirement does not require the Permittee to complete a new refined modeling demonstration using the revisions made for the EBD demonstration. DATE...EBD Modeling Results for : The dispersion characteristics due to the revisions of the information in Appendix II must be equivalent to or better than the dispersion characteristics modeled <reference date of previous modeling submittal>. The Permittee shall demonstrate this equivalency in the proposal. Computer Dispersion Modeling Triggers for : The Permittee shall conduct a refined remodeling analysis in accordance with the Computer Dispersion Modeling requirements of this permit and the current version of the MPCA Air Dispersion Modeling Guidance if: () the results of the EBD modeling analysis do not demonstrate equivalent or better dispersion characteristics; (2) a conclusion cannot readily be made about the dispersion, or (3) the criteria in the EBD Modeling Triggers requirement are met and the Permittee has previously conducted three successive EBD analyses using the same Baseline Modeling. Computer Dispersion Modeling Protocol: due 80 days after receipt of written MPCA request for refined modeling. The Permittee shall submit a Computer Dispersion Modeling Protocol that is complete and approvable by MPCA by the deadline in this requirement. This protocol will describe the proposed modeling methodology and input data, in accordance with the current version of the MPCA Air Dispersion Modeling Guidance. The protocol must be based on projected operating conditions under the next permit term. Computer Dispersion Modeling Protocol: due 60 days after receipt of written MPCA request for revisions to the submitted protocol for modeling. Computer Dispersion Modeling Results: due 80 days after receipt of written MPCA approval of Computer Dispersion Modeling Protocol for. The Permittee shall submit a final Computer Dispersion Modeling Report that is complete and approvable by MPCA by the deadline in this requirement. The submittal shall adhere to the current version of the MPCA Air Dispersion Modeling Guidance and the approved Computer Dispersion Modeling Protocol. RECORDKEEPING Daily Grain Throughput Recordkeeping: On each day of operation, the Permittee shall calculate, record, and maintain records of the daily grain throughput at the facility for the previous calendar day. This shall be based on grain receipts. Daily Acetone Production Recordkeeping: On each day of operation, the Permittee shall calculate, record, and maintain records of the acetone production for the previous calendar day. This shall be based on flowmeters. Daily Butanol Production Recordkeeping: On each day of operation, the Permittee shall calculate, record, and maintain records of the butanol production for the previous calendar day. This shall be based on flowmeters. Daily Ethanol Production Recordkeeping: On each day of operation, the Permittee shall calculate, record, and maintain the ethanol production for the previous calendar day. This shall be based on flowmeters. Monthly Acetone, Butanol and Ethanol Production Recordkeeping: By the 5th of the month, the Permittee shall calculate and record the following: Minn. Stat. Section 6.07, subds. 4a & 9; Minn. R , subp. 7(A), 7(L), & 7(M); Minn. R , subps., 2 & 4; Minn. R *****Minn. Stat. Section 6.07, subds. 4a & 9; Minn. R , subp. 7(A), 7(L), & 7(M); Minn. R , subps., 2 & 4; Minn. R Minn. Stat. Section 6.07, subds. 4a & 9; Minn. R ; Minn. R , subp. 7(A), 7(L), & 7(M); Minn. R , subp. 2 Minn. Stat. Section 6.07, subds. 4a & 9; Minn. R ; Minn. R , subp. 7(A), 7(L), & 7(M); Minn. R , subp. 2 Minn. Stat. Section 6.07, subds. 4a & 9; Minn. R ; Minn. R , subp. 7(A), 7(L), & 7(M); Minn. R , subp. 2 Minn. Stat. Section 6.07, subds. 4a & 9; Minn. R ; Minn. R , subp. 7(A), 7(L), & 7(M); Minn. R , subp. 2 Minn. R , subps. 4-5 Minn. R , subps. 4-5 Minn. R , subps. 4-5 Minn. R , subps. 4-5 Minn. R , subps. 4-5 ) The monthly gallons of acetone, butanol and ethanol produced during the previous month based on summing the daily acetone, butanol and ethanol production records for that month, and 2) The 2-month rolling sum acetone, butanol and ethanol production for the previous 2-month period by summing the monthly acetone, butanol and ethanol production data for the previous 2 months.

9 Facility Name: Central MN Renewables Permit Number: A-5 07/22/5 Monthly Grain Throughput Recordkeeping: By the 5th of the month, the Permittee shall calculate and record the following: Minn. R , subps. 4-5 ) The monthly tons of grain throughput during the previous month based on summing the daily grain throughput record for that month, and 2) The 2-month rolling sum grain throughput for the previous 2-month period by summing the monthly grain throughput data for the previous 2 months. Recordkeeping: Retain all records at the stationary source, unless otherwise specified within this permit, for a period of five (5) years from the date of monitoring, sample, measurement, or report. Records which must be retained at this location include all calibration and maintenance records, all original recordings for continuous monitoring instrumentation, and copies of all reports required by the permit. Records must conform to the requirements listed in Minn. R , 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 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. 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. 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. Minn. R , subp. 5(C) Minn. R , subp. 5(B) Minn. R , subp. 4 Minn. R , subp. 3 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:. 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. Minn. R , subp. Minn. R , subp.

10 Facility Name: Central MN Renewables Permit Number: A-6 07/22/5 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 ; Minn. R , subp. 3 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 Minn. R , subp. (H) extend a deadline in a permit by no more than 20 days, provided the proposed deadline extension meets the requirements of Minn. R , subp. (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. (H). Emission Inventory Report: due on or before April of each calendar year following Minn. R permit issuance, to be submitted on a form approved by the Commissioner. 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: ) June 2, 999; 2) Three years after the date on which a regulated substance is first listed under 40 CFR Section 68.30; 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 55, Lanham-Seabrook, Maryland RMP information may be obtained at or by calling CFR pt. 68

11 Facility Name: Permit Number: Central MN Renewables Subject Item: GP 00 Fuel Combustion A-7 07/22/5 Associated Items: EU 02 DDGS Dryer: Dryer/Oven, direct fired EU 028 Boiler EU 029 Boiler 2 EU 040 Regenerative Thermal Oxidizer What to do EMISSION LIMITS AND OPERATIONAL REQUIREMENTS Nitrogen Oxides: less than or equal to 5.92 lbs/hour using 2-month Rolling Sum. Compliance with the lb/hr limit for GP00 is calculated using emission factors determined during most recent performance test for NOx for each unit. Fuel type: Natural gas only by design. RECORDKEEPING REQUIREMENTS Monthly Recordkeeping: By the 5th of the month, the Permittee shall identify, calculate and record the following: Why to do it Title I Condition: CAAA of 990; Minn. Stat. Section 6.07, subds. 4a & 9; Minn. R , subps. 7(A) & (B); Minn. R , subps. and 2. Minn. R , subp. 35a Minn. R , subps. 4 and 5 ) The NOx emission factor in lb/mmbtu for the previous calendar month for each unit in GP00 as determined by the most recent performance test data. Process NOx emissions may be excluded from the emission factor or calculation if accounted for within the test. 2) The 2-month rolling sum NOx emission rate (lb/hr) for the previous 2-month period by summing the monthly NOx emission rate (lb/hr) for the previous 2 months. Calculation Method - The Permittee shall calculate compliance with the NOx limit (lb/hr) using the following equations: Minn. R , subps. 4 and 5 Monthly GP00 NOx limit (lb/hr) = EFT * 48 MMBtu/hr where: EFT (Emission Factor Total) = sum of lb/mmbtu as determined during most recent stack test for each unit = EF(EU02) + EF(EU028) + EF(EU029) + EF(EU040) Total Heat Input = sum of MMBtu/hr of each individual HI = 60(EU02) +40(EU027) + 40(EU028) + 8(EU040) = 48 MMBtu/hr PROTOCOL FOR RE-SETTING THE EMISSION FACTOR Protocol for Verifying the Emission Factor Used For Calculating GP00 NOx lb/hr Emissions: The Permittee shall conduct performance testing under conditions that produce the maximum NOx emission rate, using US EPA. reference method 9 or other approved method to measure the NOx emission factor as required elsewhere in this permit. The Permittee shall report the test result in lb/mmbtu in the performance test report required by Minn. R , subp.. Title I Condition: CAAA of 990; Minn. Stat. Section 6.07, subds. 4a & 9; Minn. R , subps. 7(A) & (B); Minn. R , subps. and 2. The emission factor used for calculating NOx emissions shall be re-set to the 3-hour average emission rate in lb/mmbtu, measured during the most recent MPCA-approved NOx emission factor performance test. (continued) Protocol for Verifying the Emission Factor Used For Calculating NOx Emissions (continued): The new emission factor used for calculating compliance with the NOx lb/hr limit shall be effective upon receipt of the Notice of Compliance (NOC) letter that approves the test results and shall be incorporated into the permit during the next permit amendment. PERFORMANCE TESTING Title I Condition: CAAA of 990; Minn. Stat. Section 6.07, subds. 4a & 9; Minn. R , subps. 7(A) & (B); Minn. R , subps. and 2.

12 Facility Name: Central MN Renewables Permit Number: A-8 07/22/5 Performance Test: due before end of each calendar 60 months starting 06/7/204 to measure EU028 NOx emission factor in lb/mmbtu. The performance test shall be conducted at worst case conditions as defined at Minn. R , subp. 8, using EPA Reference Method 9, or other method approved by MPCA in the performance test plan approval. Testing conducted during the 60 days 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 this permit; 2) by the most recently approved Performance Test Frequency Plan; or 3) within a Notice of Compliance letter. Testing conducted more than two months prior to the performance test due date satisfies this test due date requirement and will reset the performance test due date. Performance Test: due before end of each calendar 60 months starting 06/7/204 to measure EU029 NOx emission factor in lb/mmbtu. The performance test shall be conducted at worst case conditions as defined at Minn. R , subp. 8, using EPA Reference Method 9, or other method approved by MPCA in the performance test plan approval. Testing conducted during the 60 days 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 this permit; 2) by the most recently approved Performance Test Frequency Plan; or 3) within a Notice of Compliance letter. Testing conducted more than two months prior to the performance test due date satisfies this test due date requirement and will reset the performance test due date. Performance Test: due before end of each calendar 60 months starting 06/7/204 to measure EU02 and EU040 NOx emission factors in lb/mmbtu, either combined or individually. The performance test shall be conducted at worst case conditions as defined at Minn. R , subp. 8, using EPA Reference Method 9, or other method approved by MPCA in the performance test plan approval. Title I Condition: CAAA of 990; Minn. Stat. Section 6.07, subds. 4a & 9; Minn. R , subps. 7(A) & (B); Minn. R , subps. and 2; Minn. R , subp. Title I Condition: CAAA of 990; Minn. Stat. Section 6.07, subds. 4a & 9; Minn. R , subps. 7(A) & (B); Minn. R , subps. and 2; Minn. R , subp. Title I Condition: CAAA of 990; Minn. Stat. Section 6.07, subds. 4a & 9; Minn. R , subps. 7(A) & (B); Minn. R , subps. and 2; Minn. R , subp. Testing conducted during the 60 days 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 this permit; 2) by the most recently approved Performance Test Frequency Plan; or 3) within a Notice of Compliance letter. Testing conducted more than two months prior to the performance test due date satisfies this test due date requirement and will reset the performance test due date.

13 Facility Name: Permit Number: Central MN Renewables Subject Item: GP 004 Boiler NSPS Requirements Associated Items: EU 028 Boiler EU 029 Boiler 2 EU 055 Boiler 3 A-9 07/22/5 What to do Fuel type: Natural gas only by design for each boiler. Recordkeeping: By the last day of each calendar month, the Permittee shall record the amount of natural gas combusted in the boilers during the previous calendar month. These records shall consist of purchase records, receipts, or fuel meter readings. The Permittee shall submit a notification of any physical or operational change which increases emission rate: due 60 days (or as soon as practical) before the change is commenced. The Permittee shall submit the notification both to the Commissioner and to the US EPA regional office in Chicago. Notification of the Date Construction of Replacements Begun: due 60 days prior to start of construction (or as soon as practicable). Submit the information specified in 40 CFR Section 60.5(d)() through (7). The Permittee shall submit the notification both to the Commissioner and to the US EPA regiional office in Chicago. Recordkeeping: Maintain records of the occurrence and duration of any startup, shutdown, or malfunction in the operation of the facility including; any malfunction of the air pollution control equipment; or any periods during which a continuous monitoring system or monitoring device is inoperative. Recordkeeping: Maintain a file of all measurements, maintenance, reports and records for at least five years. 40 CFR Section 60.7(f) specifies two years. No owner or operator shall build, erect, install, or use any article, machine, equipment or process, the use of which conceals an emission which would otherwise constitute a violation of an applicable standard. Why to do it Minn. R , subp 35a 40 CFR Section 60.48c(g); Minn. R CFR Section 60.7(a)(4); Minn. R , subp. 40 CFR Section 60.5(d); Minn. R CFR Section 60.7(b), Minn. R , subp. Minn. R , subp. 5(C); Minn. R , subp. 40 CFR Section 60.2; Minn. R

14 Facility Name: Permit Number: Central MN Renewables Subject Item: GP 006 Emission Units Subject to IPER A-0 07/22/5 Associated Items: EU 004 Corn bin : Material Handling Equipment EU 005 Corn bin 2: Material Handling Equipment EU 03 Slurry Tank: Fermentation Equipment EU 027 DDGS Storage Bin : Material Handling Equipment EU 036 Liquefaction tank A EU 037 Liquefaction tank B EU 038 Sacc. Tank EU 042 Corn Bin 3: Material Handling Equipment EU 043 Hammermill 2: Milling Equipment EU 044 DDGS/DFR Storage Bin 2: Material Handling Equipment EU 056 Pre-fermentation Tank EU 059 DFS/DDGS Storage Bin: Material Handling Equipment EU 066 Uncontrolled ABE Loadout: Loading-Unloading Equipment EU 067 Pre-fermentation Tank 2 EU 068 Pre-fermentation Tank 3 EU 069 Pre-fermentation Tank 4 EU 070 Pre-fermentation Tank 5 EU 07 DFS conveyor/transfer FS 006 Cooling Tower Cell FS 0 Cooling Tower Cell 2 TK 00 Off-Spec Butanol and Acetone TK 004 Butanol Day Tank TK 005 Butanol Day Tank What to do Total Particulate Matter: less than or equal to 0.30 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 This limit applies to each unit individually. Opacity: less than or equal to 20 percent opacity. This limit applies to each unit individually. Why to do it Minn. R , subp. (A); Minn. R , subp. 3 Minn. R , subp. (B)

15 Facility Name: Permit Number: Central MN Renewables Subject Item: GP 007 Cooling Towers Associated Items: FS 006 Cooling Tower Cell FS 0 Cooling Tower Cell 2 A- 07/22/5 What to do PM < 0 micron: less than or equal to 0.20 lbs/hour based on a one-month block average to be calculated by the 5th day of each month for the previous one-month period as described later in this permit. All emission units or stacks added to GP 007 as allowed in this permit shall be included in this calculation. Monthly Recordkeeping of Water Circulating Flow Rate: On the first day of each month, the Permittee shall calculate, record, and maintain records of the water circulating flow rate for the previous calendar month. This shall be based on flowmeters. Alternatively, the Permittee may maintain documentation on site from the manufacturer, or equivalent engineering documentation that verifies the maximum design flow for the cooling towers in GP 007. For the existing Cooling Cells (FS006 and FS0), the Permittee shall use a water circulating flow rate of 666 gpm/cell in the calculation, unless the Permittee chooses to install a flowmeter and use that data. Drift Loss Factor: The default drift loss factor is 0.005%. A reduced drift loss factor, as low as 0.00% may be used if guaranteed by the manufacturer. Documentation of the manufacturer s guarantee must be maintained on site. Daily Recordkeeping for Conductivity: Each day of operation, the Permittee shall calculate, record, and maintain records of the conductivity. This shall be based on conductivity meters. Monthly Recordkeeping for Conductivity: By the 5th day of each month, the Permittee shall calculate, record, and maintain the average conductivity for the previous calendar month by summing the daily conductivity readings and dividing by the number of days in the month. Monthly Total Dissolved Solids (TDS) Calculation from Conductivity Measurements: Conductivity (in micro-mhos) x 0.7 = TDS (ppm) Monthly Calculation: Circulating Flow Rate/cell (gallons/month/cell) x (number of cells) x ( month/# days) x ( day/24 hours) x (Drift Loss %) x (8.336 lb/gallon) x TDS (ppm) /,000,000 = lb/hr Why to do it Minn. Stat. Section 6.07, subds. 4a & 9; Minn. R , subp. 7(A), 7(L), & 7(M); Minn. R , subps., 2 & 4; Minn. R Minn. Stat. Section 6.07, subds. 4a & 9; Minn. R , subp. 7(A), 7(L), & 7(M); Minn. R , subps., 2 & 4; Minn. R Minn. Stat. Section 6.07, subds. 4a & 9; Minn. R , subp. 7(A), 7(L), & 7(M); Minn. R , subps., 2 & 4; Minn. R Minn. Stat. Section 6.07, subds. 4a & 9; Minn. R , subp. 7(A), 7(L), & 7(M); Minn. R , subps., 2 & 4; Minn. R Minn. Stat. Section 6.07, subds. 4a & 9; Minn. R , subp. 7(A), 7(L), & 7(M); Minn. R , subps., 2 & 4; Minn. R Minn. Stat. Section 6.07, subds. 4a & 9; Minn. R , subp. 7(A), 7(L), & 7(M); Minn. R , subps., 2 & 4; Minn. R Minn. Stat. Section 6.07, subds. 4a & 9; Minn. R , subp. 7(A), 7(L), & 7(M); Minn. R , subps., 2 & 4; Minn. R Emission Unit Flexibility: The Permittee may replace, add or move cooling tower cells. If the Permittee replaces cooling cells, adds cooling cells or modifies existing cooling cells, such equipment is subject to all of the requirements within GP 007, as well as those listed in the Total Facility subject item of this permit, including any modeling provisions. Additionally: emissions of PM less than 0 microns must remain below 0.2 lb/hr, to be calculated as defined within GP 007. If a proposed change triggers an applicable requirement that is not contained in this permit, the change must go through the appropriate procedure in Minn. R. ch Minn. Stat. Section 6.07, subds. 4a & 9; Minn. R , subp. 7(A), 7(L), & 7(M); Minn. R , subps., 2 & 4; Minn. R

16 Facility Name: Permit Number: Central MN Renewables Subject Item: SV 00 Material Handling Equipment: Grain Handling A-2 07/22/5 Associated Items: EU 00 Captured Corn dump pit/auger: Material Handling Equipment EU 002 Corn Bucket Elevator: Material Handling Equipment EU 003 Scalper: Material Handling Equipment EU 006 Hammermill : Milling Equipment EU 043 Hammermill 2: Milling Equipment EU 06 Hopper: Material Handling Equipment What to do Opacity: less than or equal to 0 percent opacity from emissions units venting to SV00. This standard applies ndividually to each unit that vents to SV00. When CE00, which vents to SV027, is constructed, EU00 must vent to a fabric filter meeting the requirements of CE00. The Permittee must vent emissions from SV00 to control equipment meeting the requirements of CE00. Total Particulate Matter: less than or equal to 0.30 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 This standard applies to any emission unit which vents to SV00 and is not defined as a truck unloading station or handling operation. EU006 and EU043 are subject to this standard. Opacity: less than or equal to 20 percent opacity. This standard applies to any emission unit which vents to SV00 and is not defined as a truck unloading station or handling operation. This standard applies to EU006 and EU043. If the Permittee replaces any existing grain handling equipment or hammermill equipment that vents to SV00; adds any grain handling equipment or hammermill equipment that vents to SV00; or modifies existing grain handling equipment or hammermill equipment that vents to SV00, such equipment is subject to all of the requirements of SV00 as well as those listed at the FC level of this permit. Additionally: ) all of the existing, new, replaced, and modified equipment shall be vented to a fabric filter meeting the requirements of CE00 at all times that any of the equipment is being operated; 2) the total permanent grain storage capacity of the facility shall not exceed 2.5 million bushels; and 3) emissions of PM,, and PM2.5 shall remain below the limits specified in this section. Prior to making such a change, the Permittee shall apply for and obtain the appropriate permit amendment, as applicable. The Permittee is required to complete calculations described in Minn. R A permit amendment will still be needed regardless of the emissions increase if the change will be subject to a new applicable requirement or requires revisions to the limits or monitoring and recordkeeping in this permit. The Permittee shall vent emissions from all emission units to a fabric filter meeting the permit requirements for CE00 whenever emission units venting to SV00 operate, and operate and maintain a fabric filter meeting the requirements of CE00 at all times that any emissions are vented to a fabric filter meeting the requirements of CE00. The Permittee shall document periods of non-operation of the control equipment. EU00 must vent to SV027/CE00 once CE00 is constructed and operational. Open Door Restriction: The Permittee must keep one door of the grain receiving building closed during any period of grain unloading. Why to do it Minn. R , subp. 3(D) Minn. R Minn. R , subp. (A) Minn. R , subp. (B) Minn. R , subps. 2 and 4 Minn. R , subps. 2 and 4 Minn. Stat. Section 6.07, subds. 4a & 9; Minn. R , subp. 7(A), 7(L), & 7(M); Minn. R , subps., 2 & 4; Minn. R ; Minn. R , subps. 2 and 4 Minn. Stat. Section 6.07, subds. 4a & 9; Minn. R , subp. 7(A), 7(L), & 7(M); Minn. R , subps., 2 & 4; Minn. R