DRAFT/PROPOSED Air Individual Permit Major Amendment

Transcription

1 DRAFT/PROPOSED Air Individual Permit Major Amendment Permittee: Facility name: Heartland Corn Products Heartland Corn Products State Highway 19 E Winthrop, MN Operating permit issuance date: March 6, 2014 Expiration date: March 6, 2019 * All Title I Conditions do not expire Major Amendment: [Amendment Issue Date] Permit characteristics: Federal; Part 70/ Limits to avoid NSR; Limits to avoid NSR 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 the permit. 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 EPA Administrator or citizens under the Clean Air Act. Signature: for [Type e-signature] This document has been electronically signed. Don Smith, P.E., Manager Air Quality Permits Section Industrial Division for the Minnesota Pollution Control Agency

2 Table of Contents 1. Permit applications table Where to send submittals Facility description Summary of subject items Limits and other requirements Submittal/action requirements Appendices Appendix A. Insignificant Activities and General Applicable Requirements Appendix B: Modeling Inputs Appendix C: Fence Diagram Appendix D: HAP Performance Testing Required Compounds Appendix E: Diesel Idling Prevention Plan Appendix F: Equipment Inventory Page

3 Permit issued: [month day, year] Permit expires: [month day, year] Page 1 of Permit applications table Subsequent permit applications: Title description Application receipt date Action number Part 70 Reissuance 06/29/ Major Amendment 10/15/2012 updated 01/17/ Administrative Amendment 02/03/ Minor Amendment 08/29/ Major Amendment 05/12/2015 updated 11/24/

4 Permit issued: [month day, year] Permit expires: [month day, year] Page 2 of Where to send submittals 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 Minn. R 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. 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 6 th Floor Minnesota Pollution Control Agency 520 Lafayette Road North St. Paul, Minnesota Also, where required by an applicable rule or permit condition, send to the Permit Document Coordinator notices of: a. Accumulated insignificant activities b. Installation of control equipment c. Replacement of an emissions unit, and d. Changes that contravene a permit term 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

5 Permit issued: [month day, year] Permit expires: [month day, year] Page 3 of Facility description The Heartland Corn Products (Facility) is located at State Highway 19 E in Winthrop, MN, Sibley County, Minnesota. The Heartland Corn Products (Facility) is a natural fermentation fuel ethanol production plant located at State Highway 19 E in Winthrop, MN, Sibley County, Minnesota. At the facility, corn is ground and mixed with water and enzymes, cooked, and then fermented in tanks. The resulting liquid is separated from the solids, and distilled to produce pure fuel grade ethanol. The pure ethanol is denatured with gasoline, and stored in tanks prior to shipping by truck or rail. Solids from the fermentation process are dried to produce Dry Distillers Grain with Solubles, which is sold for use in livestock feed. Permit Action 010 description: This permit action was a reissuance of the pt. 70 operating permit, and also included a major amendment to increase the (un denatured 200 proof) ethanol production limit from million gallons per year to 120 million gallons per year. The major amendment included in the reissuance also revised the paved road fugitive dust requirements, added a fire pump diesel engine to the permit (installed circa 2006 as part of a project authorized by permit No , but not included in that permit), provided flexibility to add, replace, and modify certain emission units, removed the Methanator Flares (because they were not operated), revised the permit modeling appendix due to recent modeling, and corrected errors and omissions in the Delta permit database. Permit Action 011 description: This permit action is a major amendment to add a combined heat and power unit with combustion turbine (EQUI 164) and duct burner (EQUI 165) to provide on site steam and electricity. The existing boilers will remain as a backup. The facility also proposes to increase ethanol production to million gallons per year through process improvements. This production increase will not involve increases in grain throughput or DDGS output limits. All grain handling and DDGS loading/unloading operations at the East Plant will end once West Plant construction is completed. After construction, these operations will be at the West Plant only. The hours for these operations will be expanded from 10 (7AM 5PM) to 12 hours (6AM 6PM) per day. Fermenters #6 and #7 that were permitted but never built will be built and represented as EQUI 120 and EQUI 138. VRTO #1 will be replaced by a new VRTO #1 (EQUI 162), cooling towers will be relocated and a new Fermenter #6 (EQUI 161), DDGS Bin #3 (EQUI 163) and Corn Bin #7 (EQUI 166) will be added to the West Plant. This permit action also includes a minor amendment to add a 2 million gallon storage tank for denatured ethanol (EQUI 75), and an administrative amendment for a 120 day test extension.

6 Permit issued: [month day, year] Permit expires: [month day, year] Page 4 of Summary of subject items SI ID: Description ACTV5: All AI's COMG1: Baghouse Monitoring Requirements COMG3: Natural Gas Usage Recordkeeping COMG4: HAP Limits, Monitoring, and Recordkeeping COMG5: Scrubber Monitoring Requirements COMG6: Leaks From Equipment In VOC Service subp. VV COMG7: Storage Tanks Subject To NSPS Subp. Kb Relationship Type has members has members has members has members has members has members Related SI ID: Description STRU7, STRU10, STRU71, STRU72, STRU85, STRU86, TREA12, TREA14, TREA32, TREA33, TREA43, TREA44 EQUI4, EQUI6, EQUI22, EQUI51, EQUI52, EQUI56, EQUI57, EQUI164, EQUI165, TREA11, TREA15, TREA16, TREA29, TREA45 EQUI4, EQUI6, EQUI51, EQUI52, EQUI179, STRU9, STRU68, STRU69, STRU70, STRU79, STRU87 STRU68, STRU69, STRU79, TREA30, TREA31, TREA34 FUGI6, FUGI7, TREA41 EQUI104, EQUI105, EQUI106, SI ID: Description COMG8: Storage Tanks Not Subject To NSPS Subp. Kb COMG9: Leaks From Equipment In VOC Relationship Type has members has members Service subp. VVa EQUI103: Denaturant Tank #3; Unleaded Gas (Fixed Roof only; 18 mgal) EQUI104: 200 proof shift Tank #2; Ethanol (120 mgal) EQUI105: 200 proof shift Tank #1; Ethanol (120 mgal) EQUI106: Denaturant Tank #1; Unleaded Gas (39 mgal) EQUI107: 190 proof Tank #1; Ethanol & Water (Fixed Roof only; mgal) EQUI10: Beer Well sends to #1 East Plant Fermentation Equipment EQUI10: Beer Well #1 East Plant Fermentation Equipment EQUI11: Corn Dump Pit/Auger #2 Captured Emissions Material Handling Equipment EQUI128: 190 proof Tank #2; Ethanol & Water (100 mgal) is controlled by is controlled by Related SI ID: Description EQUI128, EQUI129, EQUI130, EQUI131, EQUI148, EQUI157, EQUI160 EQUI103, EQUI107, EQUI132 FUGI6, FUGI7, TREA41 STRU79: East Plant Fermentation Scrubber (CE 003) TREA30: Packed Gas Adsorption Column TREA32: Fabric Filter Low Temperature, i.e., T<180 Degrees F

7 Permit issued: [month day, year] Permit expires: [month day, year] Page 5 of 243 SI ID: Description EQUI129: 200 proof Tank #3; Ethanol (100 mgal) EQUI12: Corn Elevator #2 West Plant Elevator Relationship Type is controlled by EQUI130: 200 proof Tank #4; Ethanol (100 mgal) EQUI131: Denaturant Tank #2; Unleaded Gas (100 mgal) EQUI132: Corrosion Inhibitor (Fixed Roof only; 2.37 mgal) EQUI13: Corn Bin #5 is controlled West Plant Silo/Bin by EQUI148: Denatured or 200 proof Ethanol Tank #2 (2 mmgal) EQUI14: Corn Bin #6 West Plant Silo/Bin EQUI157: Denatured or 200 proof Ethanol Tank #3 (2 mmgal) EQUI15: Hammermill #3 West Plant Milling Equipment EQUI160: Denatured or 200 proof Ethanol Tank #1 (500 mgal) EQUI161: Fermenter #6 West Plant Fermentation Equipment EQUI162: New is controlled by is controlled by is controlled by Related SI ID: Description TREA32: Fabric Filter Low Temperature, i.e., T<180 Degrees F TREA32: Fabric Filter Low Temperature, i.e., T<180 Degrees F TREA32: Fabric Filter Low Temperature, i.e., T<180 Degrees F TREA33: Fabric Filter Low Temperature, i.e., T<180 Degrees F TREA34: Packed Gas Adsorption Column SI ID: Description VRTO #1 East Plant Other Combustion EQUI163: DDGS Bin #3 West Plant Silo/Bin EQUI164: Combustion Turbine EQUI165: Duct Burner EQUI166: Corn Bin #7 West Plant Silo/Bin EQUI167: Fermenter #6 East Plant Fermentation Equipment EQUI167: Fermenter #6 East Plant Fermentation Equipment EQUI168: Fermenter #7 East Plant Fermentation Equipment EQUI168: Fermenter #7 East Plant Fermentation Equipment EQUI169: West Plant Grain Receiving Uncaptured Emissions Material Handling Equipment EQUI16: Hammermill #4 West Plant Milling Equipment EQUI170: West Plant DDGS Loadout Uncaptured Emissions Material Handling Equipment Relationship Type is controlled by sends to is controlled by sends to is controlled by sends to is controlled by sends to Related SI ID: Description TREA32: Fabric Filter Low Temperature, i.e., T<180 Degrees F STRU79: East Plant Fermentation Scrubber (CE 003) TREA30: Packed Gas Adsorption Column STRU79: East Plant Fermentation Scrubber (CE 003) TREA30: Packed Gas Adsorption Column STRU12: West Plant Grain Receiving Uncaptured Emissions TREA33: Fabric Filter Low Temperature, i.e., T<180 Degrees F STRU13: West Plant DDGS Loadout Uncaptured Emissions EQUI171: West sends to STRU14: West

8 Permit issued: [month day, year] Permit expires: [month day, year] Page 6 of 243 SI ID: Description Plant DDGS Truck Loading Building Uncaptured Emissions Material Handling Equipment EQUI172: West Plant DDGS Loadout Captured Emissions Material Handling Equipment EQUI173: West Plant DDGS Truck Loading Building Captured Emissions Material Handling Equipment EQUI174: Corn Dump Pit/Auger #2 Uncaptured Emissions Material Handling Equipment EQUI175: Corn Dump Pit/Auger #3 Uncaptured Emissions Material Handling Equipment EQUI176: DDGS Dryer B East Plant Multiple Cyclone Other Emission Unit EQUI176: DDGS Dryer B East Plant Multiple Cyclone Other Emission Unit EQUI177: DDGS Dryer A East Plant Multiple Cyclone Other Emission Unit EQUI177: DDGS Dryer A East Plant Multiple Cyclone Other Emission Unit EQUI178: DDGS Dryer #3 West Plant Multiple Cyclone Other Emission Unit EQUI178: DDGS Dryer #3 West Plant Multiple Cyclone Other Emission Unit Relationship Type sends to sends to sends to sends to sends to is controlled by sends to is controlled by sends to is controlled by Related SI ID: Description Plant DDGS Truck Loading Building Uncaptured Emissions STRU15: West Plant DDGS Loadout Captured Emissions STRU16: West Plant DDGS Truck Loading Building Captured Emissions STRU17: Corn Dump Pit/Auger #2 Uncaptured Emissions STRU18: Corn Dump Pit/Auger #3 Uncaptured Emissions STRU9: VRTO #1 Stack East Plant (CE 036) TREA11: VRTO #1 (new) STRU9: VRTO #1 Stack East Plant (CE 036) TREA11: VRTO #1 (new) STRU70: VRTO #2 West Plant (CE 012) TREA29: VRTO No. 2 EQUI179: DDGS sends to STRU88: DDGS SI ID: Description Cooling Cyclone (CE011) East Plant EQUI179: DDGS Cooling Cyclone (CE011) East Plant EQUI17: Fermenter #1 West Plant Fermentation Equipment EQUI17: Fermenter #1 West Plant Fermentation Equipment EQUI181: Corn Dump Pit/Auger East Plant EQUI181: Corn Dump Pit/Auger East Plant EQUI182: Corn Bin #1 East Plant EQUI182: Corn Bin #1 East Plant EQUI183: Corn Bin #2 East Plant EQUI183: Corn Bin #2 East Plant EQUI184: Corn Bin #3 East Plant EQUI184: Corn Bin #3 East Plant EQUI185: Corn Bin #4 East Plant EQUI185: Corn Bin #4 East Plant Relationship Type is controlled by sends to is controlled by sends to is controlled by sends to is controlled by sends to is controlled by sends to is controlled by sends to is controlled by Related SI ID: Description Cooling Cyclone East Plant (CE011) TREA46: Single Cyclone STRU68: West Plant CO2 Scrubber (CE 008) TREA34: Packed Gas Adsorption Column STRU85: Grain Handling East Plant (CE001) TREA43: Fabric Filter Low Temperature, i.e., T<180 Degrees F STRU85: Grain Handling East Plant (CE001) TREA43: Fabric Filter Low Temperature, i.e., T<180 Degrees F STRU85: Grain Handling East Plant (CE001) TREA43: Fabric Filter Low Temperature, i.e., T<180 Degrees F STRU85: Grain Handling East Plant (CE001) TREA43: Fabric Filter Low Temperature, i.e., T<180 Degrees F STRU85: Grain Handling East Plant (CE001) TREA43: Fabric Filter Low

9 Permit issued: [month day, year] Permit expires: [month day, year] Page 7 of 243 SI ID: Description EQUI186: Hammermill #1 East Plant EQUI186: Hammermill #1 East Plant EQUI187: Hammermill #2 East Plant EQUI187: Hammermill #2 East Plant EQUI188: Corn Elevator #1 East Plant EQUI188: Corn Elevator #1 East Plant EQUI189: Scalper #1 East Plant EQUI189: Scalper #1 East Plant EQUI18: Fermenter #2 West Plant Fermentation Equipment EQUI18: Fermenter #2 West Plant Fermentation Equipment EQUI190: Corn Elevator #3 East Plant EQUI190: Corn Elevator #3 East Plant Relationship Type sends to is controlled by sends to is controlled by sends to is controlled by sends to is controlled by sends to is controlled by sends to is controlled by Related SI ID: Description Temperature, i.e., T<180 Degrees F STRU86: Hammermills 1 & 2 East Plant (CE002) TREA44: Fabric Filter Low Temperature, i.e., T<180 Degrees F STRU86: Hammermills 1 & 2 East Plant (CE002) TREA44: Fabric Filter Low Temperature, i.e., T<180 Degrees F STRU85: Grain Handling East Plant (CE001) TREA43: Fabric Filter Low Temperature, i.e., T<180 Degrees F STRU85: Grain Handling East Plant (CE001) TREA43: Fabric Filter Low Temperature, i.e., T<180 Degrees F STRU68: West Plant CO2 Scrubber (CE 008) TREA34: Packed Gas Adsorption Column STRU85: Grain Handling East Plant (CE001) TREA43: Fabric Filter Low Temperature, SI ID: Description EQUI191: Corn Bin #7 East Plant EQUI191: Corn Bin #7 East Plant EQUI192: Corn Bin #8 East Plant EQUI192: Corn Bin #8 East Plant EQUI193: Corn Dump Pit/Auger #4 East Plant EQUI193: Corn Dump Pit/Auger #4 East Plant EQUI194: Slurry Tank #1 East Plant Above Ground Storage Tank EQUI194: Slurry Tank #1 East Plant Above Ground Storage Tank EQUI195: Slurry Tank #2 West Plant Above Ground Storage Tank EQUI195: Slurry Tank #2 West Plant Above Ground Storage Tank EQUI19: Fermenter #3 West Plant Fermentation Equipment EQUI19: Fermenter #3 West Plant Fermentation Equipment Relationship Type sends to is controlled by sends to is controlled by sends to is controlled by sends to is controlled by sends to is controlled by sends to is controlled by Related SI ID: Description i.e., T<180 Degrees F STRU85: Grain Handling East Plant (CE001) TREA43: Fabric Filter Low Temperature, i.e., T<180 Degrees F STRU85: Grain Handling East Plant (CE001) TREA43: Fabric Filter Low Temperature, i.e., T<180 Degrees F STRU85: Grain Handling East Plant (CE001) TREA43: Fabric Filter Low Temperature, i.e., T<180 Degrees F STRU69: East Plant Distillation Scrubber (CE 005) TREA31: Packed Gas Adsorption Column STRU68: West Plant CO2 Scrubber (CE 008) TREA34: Packed Gas Adsorption Column STRU68: West Plant CO2 Scrubber (CE 008) TREA34: Packed Gas Adsorption Column

10 Permit issued: [month day, year] Permit expires: [month day, year] Page 8 of 243 SI ID: Description EQUI1: Fermenter #5 East Plant Fermentation Equipment EQUI1: Fermenter #5 East Plant Fermentation Equipment EQUI20: Fermenter #4 West Plant Fermentation Equipment EQUI20: Fermenter #4 West Plant Fermentation Equipment EQUI21: Beer Well #2 West Plant Fermentation Equipment EQUI21: Beer Well #2 West Plant Fermentation Equipment EQUI22: DDGS Dryer #3 West Plant Dryer/Oven, unknown firing method EQUI24: DDGS Bin #1 West Plant SIlo/Bin EQUI25: DDGS Bin #2 West Plant Silo/Bin EQUI26: Fire Pump Engine CI 575 hp (01/2006) Reciprocating IC Engine EQUI27: Liquefaction Tank #2 East Plant Liquefaction Equipment EQUI28: Corn Relationship Related SI ID: Type Description sends to STRU79: East Plant Fermentation Scrubber (CE 003) is controlled TREA30: by Packed Gas Adsorption sends to is controlled by sends to is controlled by is controlled by is controlled by is controlled by is controlled by Column STRU68: West Plant CO2 Scrubber (CE 008) TREA34: Packed Gas Adsorption Column STRU68: West Plant CO2 Scrubber (CE 008) TREA34: Packed Gas Adsorption Column TREA29: VRTO No. 2 TREA14: Fabric Filter Low Temperature, i.e., T<180 Degrees F TREA14: Fabric Filter Low Temperature, i.e., T<180 Degrees F TREA31: Packed Gas Adsorption Column is controlled TREA32: Fabric SI ID: Description Elevator #4 West Pant Elevator EQUI29: Corn Dump Pit/Auger #3 Captured Emissions Material Handling Equipment EQUI2: Fermenter #5 West Plant Fermentation Equipment EQUI2: Fermenter #5 West Plant Fermentation Equipment EQUI30: Evaporator Dehydrator EQUI31: Fermenter #1 East Plant Fermentation Equipment EQUI31: Fermenter #1 East Plant Fermentation Equipment EQUI32: Fermenter #2 East Plant Fermentation Equipment EQUI32: Fermenter #2 East Plant Fermentation Equipment EQUI33: Fermenter #3 East Plant Fermentation Equipment EQUI33: Fermenter #3 East Plant Fermentation Equipment EQUI34: Fermenter #4 East Plant Fermentation Relationship Related SI ID: Type Description by Filter Low Temperature, i.e., T<180 Degrees F is controlled by sends to is controlled by is controlled by sends to is controlled by sends to is controlled by sends to is controlled by sends to TREA32: Fabric Filter Low Temperature, i.e., T<180 Degrees F STRU68: West Plant CO2 Scrubber (CE 008) TREA34: Packed Gas Adsorption Column TREA31: Packed Gas Adsorption Column STRU79: East Plant Fermentation Scrubber (CE 003) TREA30: Packed Gas Adsorption Column STRU79: East Plant Fermentation Scrubber (CE 003) TREA30: Packed Gas Adsorption Column STRU79: East Plant Fermentation Scrubber (CE 003) TREA30: Packed Gas Adsorption Column STRU79: East Plant Fermentation

11 Permit issued: [month day, year] Permit expires: [month day, year] Page 9 of 243 SI ID: Description Equipment EQUI34: Fermenter #4 East Plant Fermentation Equipment EQUI35: Liquefaction Tank #1 East Plant Liquefaction Equipment EQUI35: Liquefaction Tank #1 East Plant Liquefaction Equipment EQUI36: Yeast Tank #2 East Plant Fermentation Equipment EQUI36: Yeast Tank #2 East Plant Fermentation Equipment EQUI38: Yeast Tank #1 East Plant Fermentation Equipment EQUI38: Yeast Tank #1 East Plant Fermentation Equipment EQUI39: 190 Proof Run Down East Plant Separation Equipment EQUI3: Side Stripper #1 East Plant Stripping Equipment EQUI40: Scalper #2 West Plant Other Emission Unit EQUI41: Beer Stripper #2 West Plant Stripping Equipment EQUI42: Rectifier #2 West Plant Relationship Type is controlled by sends to is controlled by sends to is controlled by sends to is controlled by is controlled by is controlled by is controlled by is controlled by Related SI ID: Description Scrubber (CE 003) TREA30: Packed Gas Adsorption Column STRU69: East Plant Distillation Scrubber (CE 005) TREA31: Packed Gas Adsorption Column STRU69: East Plant Distillation Scrubber (CE 005) TREA31: Packed Gas Adsorption Column STRU69: East Plant Distillation Scrubber (CE 005) TREA31: Packed Gas Adsorption Column TREA31: Packed Gas Adsorption Column TREA31: Packed Gas Adsorption Column TREA34: Packed Gas Adsorption Column TREA34: Packed Gas SI ID: Description Distillation Equipment EQUI43: Side Stripper #2 West Plant Stripping Equipment EQUI44: Molecular Sieve #2 West Plant Separation Equipment EQUI45: Evaporator #2 West Plant Dehydrator EQUI46: Liquefaction Tank #1 West Plant Liquefaction Equipment EQUI46: Liquefaction Tank #1 West Plant Liquefaction Equipment EQUI47: Liquefaction Tank #2 West Plant Liquefaction Equipment EQUI47: Liquefaction Tank #2 West Plant Liquefaction Equipment EQUI49: Yeast Tank #2 West Plant Fermentation Equipment EQUI4: Boiler #1 East Plant Boiler EQUI50: 190 Proof Run Down Tank West Plant Separation Equipment EQUI51: Utility Boiler #3 West Plant Boiler EQUI52: Utility Boiler #4 West Plant Boiler Relationship Type is controlled by is controlled by is controlled by sends to is controlled by sends to is controlled by is controlled by is controlled by Related SI ID: Description Adsorption Column TREA34: Packed Gas Adsorption Column TREA34: Packed Gas Adsorption Column TREA34: Packed Gas Adsorption Column STRU68: West Plant CO2 Scrubber (CE 008) TREA34: Packed Gas Adsorption Column STRU68: West Plant CO2 Scrubber (CE 008) TREA34: Packed Gas Adsorption Column TREA34: Packed Gas Adsorption Column TREA34: Packed Gas Adsorption Column

12 Permit issued: [month day, year] Permit expires: [month day, year] Page 10 of 243 SI ID: Description EQUI53: Ethanol Loadout #2 West Plant (Railcar) Loading Unloading Equipment EQUI54: Wetcake Loadout and Storage West Plant Loading Unloading Equipment EQUI55: DDGS Cooler West Plant (CE 013/CE 012/SV 018) Cooler EQUI55: DDGS Cooler West Plant (CE 013/CE 012/SV 018) Cooler EQUI56: DDGS Dryer B East Plant Dryer/Oven, unknown firing method EQUI56: DDGS Dryer B East Plant Dryer/Oven, unknown firing method EQUI56: DDGS Dryer B East Plant Dryer/Oven, unknown firing method EQUI57: DDGS Dryer A East Plant Dryer/Oven, unknown firing method EQUI57: DDGS Dryer A East Plant Dryer/Oven, unknown firing method EQUI57: DDGS Dryer A East Plant Dryer/Oven, unknown firing method EQUI5: Ethanol Loadout #1 East Relationship Related SI ID: Type Description is controlled TREA15: by Ethanol Loading Rack Flare #1 is controlled in parallel by is controlled in parallel by sends to is controlled by is controlled by sends to is controlled by is controlled by is controlled by TREA29: VRTO No. 2 TREA3: Fabric Filter Low Temperature, i.e., T<180 Degrees F STRU87: VRTO #1 Stack East Plant (CE010) TREA11: VRTO #1 (new) TREA45: VRTO #1 STRU87: VRTO #1 Stack East Plant (CE010) TREA11: VRTO #1 (new) TREA45: VRTO #1 TREA16: Ethanol SI ID: Description Plant (Trucks) Loading Unloading Equipment EQUI6: Boiler #2 East Plant Boiler EQUI75: Denatured or 200 proof Ethanol Tank #4 (2 mmgal) EQUI7: Beer Stripper #1 East Plant Stripping Equipment EQUI8: Rectifier East Plant Distillation Equipment EQUI9: Molecular Sieve #1 East Plant Separation Equipment FUGI10: East Plant Truck Traffic FUGI11: East Plant Cooling Tower (3 cells) FUGI12: West Plant Cooling Tower (4 cells) FUGI13: East Plant Grain & DDGS Uncaptured Emissions FUGI14: East Plant Cooling Towers FUGI15: West Plant Cooling Towers FUGI6: East Plant Equipment in VOC Service Equipment Leaks FUGI7: West Plant Equipment in VOC Service Equipment Leaks FUGI8: Ethanol Product Loading Fugitive Emissions Material Handling/Transfer/S torage Relationship Type is controlled by is controlled by is controlled by is controlled by is controlled by Related SI ID: Description Loading Rack Flare #2 TREA31: Packed Gas Adsorption Column TREA31: Packed Gas Adsorption Column TREA31: Packed Gas Adsorption Column TREA41: Leak Detection Program TREA41: Leak Detection Program

13 Permit issued: [month day, year] Permit expires: [month day, year] Page 11 of 243 SI ID: Description FUGI9: West Plant Truck Traffic STRU10: DDGS Handling Baghouse #2 (CE 037) STRU11: Combustion Turbine with Duct Burner STRU11: Combustion Turbine with Duct Burner STRU12: West Plant Grain Receiving Uncaptured Emissions STRU13: West Plant DDGS Loadout Uncaptured Emissions STRU14: West Plant DDGS Truck Loading Building Uncaptured Emissions STRU15: West Plant DDGS Loadout Captured Emissions STRU16: West Plant DDGS Truck Loading Building Captured Emissions STRU17: Corn Dump Pit/Auger #2 Uncaptured Emissions STRU18: Corn Dump Pit/Auger #3 Uncaptured Emissions STRU19: Dryer Building East Plant STRU20: Process Building East Plant STRU21: Process Building (South) East Plant STRU22: Maintenance Building East Plant STRU23: Grain Receiving East Plant Relationship Type receives from receives from receives from Related SI ID: Description EQUI163: DDGS Bin #3 West Plant Silo/Bin EQUI164: Combustion Turbine EQUI165: Duct Burner SI ID: Description STRU24: Process Building West Plant STRU25: Cooling Tower 1 East Plant STRU26: Cooling Tower 2 East Plant STRU27: Grain Receiving West Plant STRU28: Boiler Building STRU29: Office STRU30: Cooling Towers West Plant STRU31: Cooling Tower 3 East Plant STRU32: Denatured Ethanol Tank West STRU33: Fermenter 1 West STRU34: Fermenter 2 West STRU35: Beerwell West STRU36: Fermenter 3 West STRU37: Fermenter 4 West STRU38: Corn Silo 1 West STRU39: Corn Silo 2 West STRU40: DDGS Bin 1 West STRU41: DDGS Bin 2 West STRU42: Corrosion Inhibitor West STRU43: 200 Proof Tank 1 West STRU44: 190 Proof Tank West STRU45: Denatured Tank West STRU46: Fermenter 1 East STRU47: Beerwell East STRU48: Fermenter 2 East Relationship Type Related SI ID: Description

14 Permit issued: [month day, year] Permit expires: [month day, year] Page 12 of 243 SI ID: Description STRU49: Corn Silo 1 East STRU50: Corn Silo 2 East STRU51: Corn Silo 3 East STRU52: Corn Silo 4 East STRU53: Corn Silo 5 East STRU54: Corn Silo 6 East STRU55: T24 STRU56: 190 Proof Tank East STRU57: Denatured Tank East STRU58: 200 Proof Tank 1 East STRU59: 200 Proof Tank 2 East STRU5: Ethanol Loading Rack Flare #1 (CE 018) STRU60: Denatured Ethanol Tank East STRU61: Denatured Ethanol Tank 2 West STRU62: 200 Proof Tank 2 West STRU63: Fermenter 3 East STRU64: Fermenter 4 East STRU65: Fire Pumphouse STRU66: Fire Water Tank STRU67: STRU68: West Plant CO2 Scrubber (CE 008) STRU68: West Plant CO2 Scrubber (CE Relationship Type receives from receives from receives from Related SI ID: Description EQUI5: Ethanol Loadout #1 East Plant (Trucks) Loading Unloading Equipment EQUI161: Fermenter #6 West Plant Fermentation Equipment EQUI41: Beer Stripper #2 SI ID: Relationship Related SI ID: Description Type Description 008) West Plant Stripping Equipment STRU68: West Plant CO2 Scrubber (CE 008) STRU68: West Plant CO2 Scrubber (CE 008) STRU68: West Plant CO2 Scrubber (CE 008) STRU68: West Plant CO2 Scrubber (CE 008) STRU68: West Plant CO2 Scrubber (CE 008) STRU68: West Plant CO2 Scrubber (CE 008) STRU69: East Plant Distillation Scrubber (CE 005) STRU69: East Plant Distillation Scrubber (CE 005) STRU69: East Plant Distillation Scrubber (CE 005) STRU69: East Plant Distillation Scrubber receives from receives from receives from receives from receives from receives from receives from receives from receives from receives from EQUI42: Rectifier #2 West Plant Distillation Equipment EQUI43: Side Stripper #2 West Plant Stripping Equipment EQUI44: Molecular Sieve #2 West Plant Separation Equipment EQUI45: Evaporator #2 West Plant Dehydrator EQUI49: Yeast Tank #2 West Plant Fermentation Equipment EQUI50: 190 Proof Run Down Tank West Plant Separation Equipment EQUI27: Liquefaction Tank #2 East Plant Liquefaction Equipment EQUI30: Evaporator Dehydrator EQUI39: 190 Proof Run Down East Plant Separation Equipment EQUI3: Side Stripper #1 East

15 Permit issued: [month day, year] Permit expires: [month day, year] Page 13 of 243 SI ID: Relationship Related SI ID: Description Type Description (CE 005) Plant Stripping Equipment STRU69: East Plant Distillation Scrubber (CE 005) STRU69: East Plant Distillation Scrubber (CE 005) STRU69: East Plant Distillation Scrubber (CE 005) STRU6: Ethanol Loading Rack Flare #2 (CE 019) STRU70: VRTO #2 West Plant (CE 012) STRU70: VRTO #2 West Plant (CE 012) STRU71: Grain Handling West Plant (CE 006) receives from receives from receives from receives from receives from receives from receives from EQUI7: Beer Stripper #1 East Plant Stripping Equipment EQUI8: Rectifier East Plant Distillation Equipment EQUI9: Molecular Sieve #1 East Plant Separation Equipment EQUI53: Ethanol Loadout #2 West Plant (Railcar) Loading Unloading Equipment EQUI22: DDGS Dryer #3 West Plant Dryer/Oven, unknown firing method EQUI55: DDGS Cooler West Plant (CE 013/CE 012/SV 018) Cooler EQUI11: Corn Dump Pit/Auger #2 Captured Emissions Material Handling Equipment STRU71: Grain receives EQUI12: Corn Handling West Plant from (CE 006) Elevator #2 West Plant Elevator STRU71: Grain receives EQUI13: Corn SI ID: Relationship Related SI ID: Description Type Description Handling West Plant from Bin #5 West (CE 006) Plant Silo/Bin STRU71: Grain receives EQUI14: Corn Handling West Plant from (CE 006) Bin #6 West Plant Silo/Bin STRU71: Grain Handling West Plant (CE 006) STRU71: Grain Handling West Plant (CE 006) STRU71: Grain Handling West Plant (CE 006) STRU72: Hammermills 3 & 4 West Plant (CE 007) STRU72: Hammermills 3 & 4 West Plant (CE 007) STRU78: DDGS Cooler #2 (CE 013) bypass STRU79: East Plant Fermentation Scrubber (CE 003) STRU7: DDGS Handling Baghouse (CE 035) STRU7: DDGS Handling Baghouse (CE 035) STRU82: Utility Boiler Stack STRU82: Utility Boiler Stack receives from receives from receives from receives from receives from receives from receives from receives from receives from receives from EQUI166: Corn Bin #7 West Plant Silo/Bin EQUI28: Corn Elevator #4 West Pant Elevator EQUI29: Corn Dump Pit/Auger #3 Captured Emissions Material Handling Equipment EQUI15: Hammermill #3 West Plant Milling Equipment EQUI16: Hammermill #4 West Plant Milling Equipment EQUI55: DDGS Cooler West Plant (CE 013/CE 012/SV 018) Cooler EQUI24: DDGS Bin #1 West Plant SIlo/Bin EQUI25: DDGS Bin #2 West Plant Silo/Bin EQUI4: Boiler #1 East Plant Boiler EQUI51: Utility Boiler #3 West Plant Boiler STRU82: Utility receives EQUI52: Utility

16 Permit issued: [month day, year] Permit expires: [month day, year] Page 14 of 243 SI ID: Relationship Related SI ID: Description Type Description Boiler Stack from Boiler #4 West Plant Boiler STRU82: Utility Boiler Stack receives from STRU85: Grain Handling East Plant (CE001) STRU86: Hammermills 1 & 2 East Plant (CE002) STRU87: VRTO #1 Stack East Plant (CE010) STRU88: DDGS Cooling Cyclone East Plant (CE011) STRU8: Diesel Fire Pump Engine Stack STRU9: VRTO #1 Stack East Plant (CE 036) STRU9: VRTO #1 Stack East Plant (CE 036) TFAC1: Heartland Corn Products TREA11: VRTO #1 (new) TREA12: Fabric Filter Low Temperature, i.e., T<180 Degrees F receives from receives from receives from EQUI6: Boiler #2 East Plant Boiler EQUI26: Fire Pump Engine CI 575 hp (01/2006) Reciprocating IC Engine EQUI56: DDGS Dryer B East Plant Dryer/Oven, unknown firing method EQUI57: DDGS Dryer A East Plant Dryer/Oven, unknown firing method SI ID: Description TREA14: Fabric Filter Low Temperature, i.e., T<180 Degrees F TREA15: Ethanol Loading Rack Flare #1 TREA16: Ethanol Loading Rack Flare #2 TREA29: VRTO No. 2 TREA30: Packed Gas Adsorption Column TREA31: Packed Gas Adsorption Column TREA32: Fabric Filter Low Temperature, i.e., T<180 Degrees F TREA33: Fabric Filter Low Temperature, i.e., T<180 Degrees F TREA34: Packed Gas Adsorption Column TREA3: Fabric Filter Low Temperature, i.e., T<180 Degrees F TREA41: Leak Detection Program TREA43: Fabric Filter Low Temperature, i.e., T<180 Degrees F TREA44: Fabric Filter Low Temperature, i.e., T<180 Degrees F TREA45: VRTO #1 TREA46: Single Cyclone Relationship Type Related SI ID: Description

17 Permit Expires: [month day, year] Page 15 of Limits and other requirements TFAC Heartland Corn Products Production <= million gallons per year 12 month rolling sum of fuel ethanol (pure ethanol, prior to addition of denaturant gasoline). [Title I Condition: 40 CFR 52.21(j)(BACT) & Minn. R , Title I Condition: Avoid major source under 40 CFR 52.21(b)(1)(i) & Minn. R ] Grain received by the facility shall only be used for ethanol production by the Permittee at the Heartland Corn Products facility (ID No ). [Title I Condition: Avoid major modification under 40 CFR 52.21(b)(23)(i) & Minn. R , Title I Condition: Avoid major source under 40 CFR 52.21(b)(1)(i) & Minn. R ] Permit Appendices: This permit contains appendices as listed in the permit Table of Contents. The Permittee shall comply with all requirements contained in Appendices A (Insignificant Activities & Applicable Requirements), C (Fence Diagram), D (HAP Performance Testing Required Compounds), E (Diesel Idling Prevention Plan), and F (Equipment Inventory). Appendix B Modeling parameters are included for reference only and compliance with these parameters is achieved through meeting the requirements that reference Appendix B. [Minn. R , subp. 7(A), 7(L), & 7(M), Minn. R , subp. 4, Minn. R , subps. 1 2, Minn. R , Minn. R , Minn. Stat , subd. 4a, Minn. Stat , subd. 9, Title I Condition: 40 CFR 52.21(k)(1)(i) & Minn. R , Title I Condition: Avoid major source under 40 CFR 63.2] Fugitive Emissions Control: The facility shall take reasonable measure to prevent particulate matter from becoming airborne. On each day of operation, the Permittee shall visually inspect all paved surfaces to minimize or eliminate fugitive emissions. The facility shall maintain records of this inspection that include the date of the inspection, whether fugitive dust was observed, the corrective actions taken, when the corrective actions were taken, and whether the corrective actions eliminated the fugitive dust. Anytime fugitive emissions are observed on facility roadways, the Permittee shall immediately eliminate the fugitive emissions by sweeping those road segments and/or apply water or a chemical dust suppressant. The Permittee shall implement and enforce a facility wide speed limit of 15 miles per hour. The Permittee must post the

18 Permit Expires: [month day, year] Page 16 of 243 speed limit in a highly visible location near the facility entrance. [CAAA of 1990, Minn. R , subp. 7(A), 7(L), & 7(M), Minn. R , subp. 4, Minn. R , subps. 1 2, Minn. R , Minn. R , Minn. Stat , subd. 4a, Minn. Stat , subd. 9, Title I Condition: 40 CFR 52.21(k)(1)(i) & Minn. R ] Grain Storage Capacity: The facility permanent grain storage capacity is limited to less than 2.5 million bushels to avoid classification as a grain terminal elevator under 40 CFR pt. 60, subp. DD. [Minn. R , subp. 2] The Permittee shall retain on site and continue implementation of the Diesel Emission Idling Prevention Plan (Appendix E) submitted to MPCA on June 9, Any proposed changes to the plan shall be submitted to the MPCA for review and approval prior to implementation. [Minn. R , Minn. R , Title I Condition: 40 CFR 52.21] 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. This permit shall not alter or affect the liability of the Permittee for any violation of applicable requirements prior to or at the time of permit issuance. [Minn. R , (A)(2)] 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. [40 CFR pt. 50, Minn. R , subp. 7(A), 7(L), & 7(M), Minn. R , subp. 4, Minn. R , subps. 1 2, Minn. Stat , subd. 4a, Minn. Stat , subd. 9] 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. [Minn. R ] Air Pollution Control Equipment: Operate all pollution control equipment whenever the corresponding process equipment and emission units are operated. [Minn. R , subp. 16(J), Minn. R , subp. 2] Operation and Maintenance Plan: Retain at the stationary

19 Permit Expires: [month day, year] Page 17 of 243 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. [Minn. R , subp. 14, Minn. R , subp. 16(J)] Operation Changes: In any shutdown, breakdown, or deviation the Permittee shall immediately take all practical steps to modify operations to reduce the emission of any regulated air pollutant. The Commissioner may require feasible and practical modifications in the operation to reduce emissions of air pollutants. No emissions units that have an unreasonable shutdown or breakdown frequency of process or control equipment shall be permitted to operate. [Minn. R , subp. 4] 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 [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. [Minn. R ] Inspections: The Permittee shall comply with the inspection procedures and requirements as found in Minn. R , subp. 9(A). [Minn. R , subp. 9(A)] The Permittee shall comply with the General Conditions listed in Minn. R , subp. 16. [Minn. R , subp. 16] Changes/Modifications That May Trigger New Source Review and/or Part 63 Major Source Status Prohibited: This permit contains limits and requirements to keep the facility a minor source under New Source Review and the National Emission Standards for Hazardous Air Pollutants (NESHAP) program. The Permittee cannot make any change to the source that qualifies as a Title I modification (as defined at Minn. R , subp. 26), or that would make the source a major source under New Source Review or the NESHAP program until a permit amendment has been issued. This

20 Permit Expires: [month day, year] Page 18 of 243 includes changes that might otherwise qualify as insignificant modifications, or that could otherwise be permitted as minor or moderate amendments. [Minn. R , Title I Condition: Avoid major modification under 40 CFR 52.21(b)(23)(i) & Minn. R , Title I Condition: Avoid major source under 40 CFR 52.21(b)(1)(i) & Minn. R , Title I Condition: Avoid major source under 40 CFR 63.2] Changes/Modifications That May Affect Modeled Parameters or Processes Subject To Limits Based On 40 CFR Section and Minn. R : Except as allowed by this permit, the Permittee can not make any changes to process equipment subject to requirements based on 40 CFR Section 52.21(j) and/or (k) without obtaining the appropriate amendment required under Minn. R. ch This includes changes that might otherwise qualify as insignificant modifications, or that could otherwise be permitted as minor or moderate amendments. [Minn. R , subp. 2] Equipment Inventory: The Permittee shall maintain a written list of all emission units and control equipment that vent through STRU 5 11, 68 72, 78, 79, 82, 85 and 86. The Permittee shall update the list to include any new, modified, or replaced equipment prior to making any permitted changes described in subject items STRU 5 11, 68 72, 78, 79, 82, 85 or 86 of this permit. The Permittee shall use the tables in Appendix F to maintain the list. Appropriate data shall be entered for all data fields in Appendix F emission unit tables A and B. Removed equipment shall be shown in the table(s) with equipment data struck out. Modified equipment shall be shown in the table(s) with current equipment data, and past equipment data struck. [Minn. R , subp. 2] Equipment Labeling: The Permittee shall permanently affix a unique number to each emission unit for tracking purposes. The numbers shall correlate the unit to the appropriate EQUI, STRU, TREA, and COMG 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. [Minn. R , subp. 2] Daily Ethanol Production Recordkeeping: Once each day, the Permittee shall calculate and record the ethanol production for the previous calendar day. [Minn. R , subps. 4 5,

21 Permit Expires: [month day, year] Page 19 of 243 Title I Condition: 40 CFR 52.21(j)(BACT) & Minn. R , Title I Condition: Avoid major source under 40 CFR 52.21(b)(1)(i) & Minn. R ] Recordkeeping: By the 15th day of every month, record the following: 1. gallons of pure (undenatured) ethanol produced during the previous month based on the daily production records, and 2. gallons of pure ethanol produced during the previous 12 months (12 month rolling sum). [Minn. R , subps. 4 5] Performance Testing: Conduct all performance tests in accordance with Minn. R. ch unless otherwise noted in in this permit. [Minn. R. ch. 7017] Performance Test Notifications and Submittals: Performance Tests are due as outlined in this permit. 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 [Minn. R , Minn. R , subps. 1 4, Minn. R , subps. 1 2] 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] Monitoring Equipment Calibration The Permittee shall either: 1. Calibrate or replace required monitoring equipment every 12 months; or 2. Calibrate at the frequency stated in the manufacturer's specifications. For each monitor, the Permittee shall maintain a record of all calibrations, including the date conducted, and any corrective

22 Permit Expires: [month day, year] Page 20 of 243 action that resulted. The Permittee shall include the calibration frequencies, procedures, and manufacturer's specifications (if applicable) in the Operations and Maintenance Plan. Any requirements applying to continuous emission monitors are listed separately in this permit. [Minn. R , subp. 4(D)] Operation of Monitoring Equipment: Unless noted elsewhere in this permit, 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. [Minn. R , subp. 4(D)] 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). [Minn. R , subp. 5(C)] 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. [Minn. R , subp. 5(B)] If the Permittee determines that no permit amendment or notification is required prior to making a change, the Permittee must retain records of all calculations required under Minn. R [For expiring permits, these records shall be kept for a period of five years from the date the change was made or until permit reissuance, whichever is longer. ][For non expiring 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. [Minn. R , subp. 4] 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

23 Permit Expires: [month day, year] Page 21 of 243 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. 3] Breakdown Notifications: Notify the Commissioner within 24 hours of a breakdown of more than one hour duration of any control equipment or process equipment 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. [Minn. R , subp. 2] Notification of Deviations Endangering Human Health or the Environment: As soon as possible after discovery, notify the Commissioner or the state duty officer, either orally or by facsimile, of any deviation from permit conditions which could endanger human health or the environment. [Minn. R , 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. [Minn. R , subp. 1] 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.

24 Permit Expires: [month day, year] Page 22 of 243 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. [Minn. R , subp. 3, Minn. R ] 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). [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 ] 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 the Permittee 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 [40 CFR pt. 68] CO Dispersion Modeling: The parameters used in CO modeling (for permit No ) are listed in Appendix B of this permit. [Title I Condition: 40 CFR 52.21(k)(1)(i) & Minn. R ] NOx Dispersion Modeling (Tier 1): The parameters used in NOx modeling (for permit No ) are listed in Appendix B of this permit. The parameters describe the operation of the facility at maximum permitted capacity. The purpose of listing

25 Permit Expires: [month day, year] Page 23 of 243 the parameters in Appendix B is to provide a benchmark for future changes. [Minn. R , Title I Condition: 40 CFR 52.21(k)(1)(i) & Minn. R ] Modeled Parameters for PM2.5: The parameters used in PM2.5 modeling dated April 2015 for permit number are listed in Appendix B of this permit. The parameters describe the operation of the facility at maximum permitted capacity. The purpose of listing the parameters in the appendix is to provide a benchmark for future changes. [Minn. R , subp. 7(A), 7(L), & 7(M), Minn. R , subp. 4, Minn. R , subps. 1 2, Minn. R , Minn. Stat , subd. 4a, Minn. Stat , subd. 9] Equivalent or Better Dispersion (EBD) Modeling Triggers (Modeling Not Required) for PM2.5: Changes that do not require a permit amendment or require an administrative permit amendment do not trigger the EBD Modeling Submittal requirement. The Permittee shall keep updated records on site of all modeled PM2.5 parameters and emission rates listed in Appendix B. The Permittee shall submit any changes to modeled PM2.5 parameters and emission rates with the next required modeling submittal. [Minn. R , subp. 7(A), 7(L), & 7(M), Minn. R , subp. 4, Minn. R , subps. 1 2, Minn. R , Minn. Stat , subd. 4a, Minn. Stat , subd. 9] EBD Modeling Triggers (Modeling Required) for PM2.5: Changes that require, or would require, a minor, moderate, or major permit amendment due to an increase in PM2.5 emissions and affect any modeled PM2.5 parameter or emission rate listed in Appendix B, or an addition to the information documented in Appendix B, trigger the EBD Remodeling Submittal requirement. The Permittee shall include previously made changes to modeled PM2.5 parameters and emission rates listed in Appendix B that did not previously trigger the EBD Modeling Submittal requirement with this modeling submittal. [Minn. R , subp. 7(A), 7(L), & 7(M), Minn. R , subp. 4, Minn. R , subps. 1 2, Minn. R , Minn. Stat , subd. 4a, Minn. Stat , subd. 9] EBD Modeling at Reissuance for PM2.5: The Permittee shall submit an EBD Modeling Submittal with the permit reissuance application (due as stated elsewhere in this permit) that addresses any changes made during the permit term that did not require a permit amendment but that affected any modeled PM2.5 parameter or emission rate documented in Appendix B, or an addition to the information documented in Appendix B and that did not trigger the EBD Modeling Triggers (Modeling Required) requirement. [Minn. R , subp.

26 Permit Expires: [month day, year] Page 24 of 243 7(A), 7(L), & 7(M), Minn. R , subp. 4, Minn. R , subps. 1 2, Minn. R , Minn. Stat , subd. 4a, Minn. Stat , subd. 9] EBD Modeling Submittal for PM2.5: 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. [Minn. R , subp. 7(A), 7(L), & 7(M), Minn. R , subp. 4, Minn. R , subps. 1 2, Minn. R , Minn. Stat , subd. 4a, Minn. Stat , subd. 9] EBD Modeling Submittal Content for PM2.5: 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. R , subp. 7(A), 7(L), & 7(M), Minn. R , subp. 2, Minn. Stat , subd. 4a, Minn. Stat , subd. 9] Outdated EBD Baseline Modeling for PM2.5: 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. [Minn. R , subp. 7(A), 7(L), & 7(M), Minn. R , subp. 2, Minn. Stat , subd. 4a, Minn. Stat , subd. 9] EBD Modeling Results for PM2.5: The dispersion characteristics due to the revisions of the information in Appendix B must be equivalent to or better than the dispersion characteristics modeled April The Permittee shall demonstrate this

27 Permit Expires: [month day, year] Page 25 of 243 equivalency in the proposal. [Minn. R , subp. 7(A), 7(L), & 7(M), Minn. R , subp. 2, Minn. Stat , subd. 4a, Minn. Stat , subd. 9] Computer Dispersion Modeling Triggers for PM2.5: 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: (1) 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. [Minn. R , subp. 7(A), 7(L), & 7(M), Minn. R , subp. 2, Minn. Stat , subd. 4a, Minn. Stat , subd. 9] Computer Dispersion Modeling Protocol: due 180 days after receipt of written MPCA request for PM2.5 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. [Minn. R , subp. 7(A), 7(L), & 7(M), Minn. R , subp. 2, Minn. Stat , subd. 4a, Minn. Stat , subd. 9] Computer Dispersion Modeling Protocol: due 60 days after receipt of written MPCA request for revisions to the submitted protocol for PM2.5 modeling. [Minn. R , subp. 7(A), 7(L), & 7(M), Minn. R , subp. 2, Minn. Stat , subd. 4a, Minn. Stat , subd. 9] Computer Dispersion Modeling Results: due 180 days after receipt of written MPCA approval of Computer Dispersion Modeling Protocol for PM2.5. 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. [Minn. R , subp. 7(A), 7(L), & 7(M), Minn. R , subp. 2, Minn. Stat , subd. 4a, Minn. Stat , subd. 9] Modeled Parameters for PM10: The parameters used in PM10 modeling dated April 2015 for permit number are listed in Appendix B of this permit. The parameters describe the operation of the facility at maximum permitted capacity. The purpose of listing the parameters in the appendix is to provide a benchmark for future changes. [Minn. R.

28 Permit Expires: [month day, year] Page 26 of , subp. 7(A), 7(L), & 7(M), Minn. R , subp. 4, Minn. R , subps. 1 2, Minn. R , Minn. Stat , subd. 4a, Minn. Stat , subd. 9, Title I Condition: 40 CFR 52.21(k)(1)(i) & Minn. R ] Equivalent or Better Dispersion (EBD) Modeling Triggers (Modeling Not Required) for PM10: Changes that do not require a permit amendment or require an administrative permit amendment do not trigger the EBD Modeling Submittal requirement. The Permittee shall keep updated records on site of all modeled PM10 parameters and emission rates listed in Appendix B. The Permittee shall submit any changes to modeled PM10 parameters and emission rates with the next required modeling submittal. [Minn. R , subp. 7(A), 7(L), & 7(M), Minn. R , subp. 4, Minn. R , subps. 1 2, Minn. R , Minn. Stat , subd. 4a, Minn. Stat , subd. 9, Title I Condition: 40 CFR 52.21(k)(1)(i) & Minn. R ] EBD Modeling Triggers (Modeling Required) for PM10: Changes that require, or would require, a minor, moderate, or major permit amendment due to an increase in PM10 emissions and affect any modeled PM10 parameter or emission rate listed in Appendix B, or an addition to the information documented in Appendix B, trigger the EBD Remodeling Submittal requirement. The Permittee shall include previously made changes to modeled PM10 parameters and emission rates listed in Appendix B that did not previously trigger the EBD Modeling Submittal requirement with this modeling submittal. [Minn. R , subp. 7(A), 7(L), & 7(M), Minn. R , subp. 4, Minn. R , subps. 1 2, Minn. R , Minn. Stat , subd. 4a, Minn. Stat , subd. 9, Title I Condition: 40 CFR 52.21(k)(1)(i) & Minn. R ] EBD Modeling at Reissuance for PM10: The Permittee shall submit an EBD Modeling Submittal with the permit reissuance application (due as stated elsewhere in this permit) that addresses any changes made during the permit term that did not require a permit amendment but that affected any modeled PM10 parameter or emission rate documented in Appendix B, or an addition to the information documented in Appendix B and that did not trigger the EBD Modeling Triggers (Modeling Required) requirement. [Minn. R , subp. 7(A), 7(L), & 7(M), Minn. R , subp. 4, Minn. R , subps. 1 2, Minn. R , Minn. Stat , subd. 4a, Minn. Stat , subd. 9, Title I Condition: 40 CFR 52.21(k)(1)(i) & Minn. R ] EBD Modeling Submittal for PM10: For changes meeting the criteria in the EBD Modeling Triggers (Modeling Required)

29 Permit Expires: [month day, year] Page 27 of 243 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. [Minn. R , subp. 7(A), 7(L), & 7(M), Minn. R , subp. 4, Minn. R , subps. 1 2, Minn. R , Minn. Stat , subd. 4a, Minn. Stat , subd. 9, Title I Condition: 40 CFR 52.21(k)(1)(i) & Minn. R ] EBD Modeling Submittal Content for PM10: 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. R , subp. 7(A), 7(L), & 7(M), Minn. R , subp. 2, Minn. Stat , subd. 4a, Minn. Stat , subd. 9, Title I Condition: 40 CFR 52.21(k)(1)(i) & Minn. R ] Outdated EBD Baseline Modeling for PM10: 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. [Minn. R , subp. 7(A), 7(L), & 7(M), Minn. R , subp. 2, Minn. Stat , subd. 4a, Minn. Stat , subd. 9, Title I Condition: 40 CFR 52.21(k)(1)(i) & Minn. R ] EBD Modeling Results for PM10: The dispersion characteristics due to the revisions of the information in Appendix B must be equivalent to or better than the dispersion characteristics modeled April The Permittee shall demonstrate this equivalency in the proposal. [Minn. R , subp. 7(A), 7(L), & 7(M), Minn. R , subp. 2, Minn. Stat ,

30 Permit Expires: [month day, year] Page 28 of 243 subd. 4a, Minn. Stat , subd. 9, Title I Condition: 40 CFR 52.21(k)(1)(i) & Minn. R ] Computer Dispersion Modeling Triggers for PM10: 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: (1) 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. [Minn. R , subp. 7(A), 7(L), & 7(M), Minn. R , subp. 2, Minn. Stat , subd. 4a, Minn. Stat , subd. 9, Title I Condition: 40 CFR 52.21(k)(1)(i) & Minn. R ] Computer Dispersion Modeling Protocol: due 180 days after receipt of written MPCA request for PM10 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. [Minn. R , subp. 7(A), 7(L), & 7(M), Minn. R , subp. 2, Minn. Stat , subd. 4a, Minn. Stat , subd. 9, Title I Condition: 40 CFR 52.21(k)(1)(i) & Minn. R ] Computer Dispersion Modeling Protocol: due 60 days after receipt of written MPCA request for revisions to the submitted protocol for PM10 modeling. [Minn. R , subp. 7(A), 7(L), & 7(M), Minn. R , subp. 2, Minn. Stat , subd. 4a, Minn. Stat , subd. 9, Title I Condition: 40 CFR 52.21(k)(1)(i) & Minn. R ] Computer Dispersion Modeling Results: due 180 days after receipt of written MPCA approval of Computer Dispersion Modeling Protocol for PM10. 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. [Minn. R , subp. 7(A), 7(L), & 7(M), Minn. R , subp. 2, Minn. Stat , subd. 4a, Minn. Stat , subd. 9, Title I Condition: 40 CFR 52.21(k)(1)(i) & Minn. R ] COMG 3 GP006 Natural Gas Usage

31 Permit Expires: [month day, year] Page 29 of 243 Recordkeeping Recordkeeping Daily Fuel Usage: Once each day, record the total cubic feet of natural gas combusted by all COMG 3 units during the previous calendar day. [Minn. R , Title I Condition: Avoid major source under 40 CFR 63.2] Recordkeeping Monthly Fuel Usage: By the 15th day of each month, calculate and record the total cubic feet of natural gas combusted by all COMG 3 units during the previous calendar month. [Minn. R , subp. 5] COMG 4 GP008 HAP Limits, Monitoring, and Recordkeeping Air pollution control equipment requirements for COMG 4 HAP emitting sources (that use HAP air pollution control equipment) are found under the following subject items in this permit: 1. STRU 79 and TREA 30 (East Plant Fermentation Equipment and Scrubber) 2. STRU 69 and TREA 31 (East Plant Distillation Equipment and Scrubber) 3. STRU 87 and TREA 45 (East Plant DDGS Dryers and Valveless Regenerative Thermal Oxidizer) 4. STRU 68 and TREA 34 (West Plant Fermentation/Distillation Equipment and CO2 Scrubber) 5. STRU 70 and TREA 29 (West Plant DDGS Dryer and Cooler, and Valveless Regenerative Thermal Oxidizer) 6. STRU 9 and TREA 11 (East Plant DDGS Dryers and new Valveless Regenerative Thermal Oxidizer) HAP emissions from all other COMG 4 subject items are uncontrolled. [Minn. R , subp. 2] HAPs Total <= tons per year 12 month rolling sum calculated by the 15th day of each month for the previous 12 month period. This limit applies to the total HAP emissions from all related subject items in COMG 4. [Minn. R , Title I Condition: Avoid major source under 40 CFR 63.2] HAPs Single <= 9.00 tons per year 12 month rolling sum calculated by the 15th day of each month for the previous 12 month period. This limit applies to the total emissions from all related subject items in COMG 4 of any single HAP, except hexane. [Minn. R , Title I Condition: Avoid major source under 40 CFR 63.2] Hexane <= 7.20 tons per year 12 month rolling sum calculated by the 15th day of each month for the previous 12 month period. This limit applies to the total hexane emissions from all related subject items in COMG 4. [Minn. R , Title I Condition: Avoid major source under 40 CFR 63.2] Monthly Recordkeeping HAP Emissions: By the 15th of the month, the Permittee shall calculate and record the following

32 Permit Expires: [month day, year] Page 30 of 243 as prescribed in Steps 1 7 below: Step 1) Monthly acetaldehyde, acrolein, formaldehyde, and methanol emissions from EQUI 179, STRU 9, 68 70, 79 and 87 during the previous calendar month using Equation 1. Equation 1: Hp = [(A1c x B1) + (A1u x B1/(1 CE)) + (A2c x B2) + (A2u x B2/(1 CE))...etc.]/2000 Where: Hp = Individual acetaldehyde, acrolein, formaldehyde, and methanol process emissions; tons/month A#c = Controlled HAP source (STRU or EQUI) operating hours (recorded under subject items STRU 9, 68 70, 79 & 87) during the previous month when all applicable control equipment operating parameters were at or above the required minimum; for EQUI 179 this value is the operating hours recorded under EQUI 179; hrs/month B# = HAP controlled emission rate; lb/hr A#u = Controlled HAP source operating hours during the previous month when any applicable control equipment operating parameter was below the required minimum (recorded under subject items STRU 9, 68 70, 79 & 87; hrs/month CE = decimal equivalent of control device percent control efficiency for the specific pollutant as defined below The Permittee shall use the following values for TREA in Equation 1: TREA 30 East Fermentation Scrubber and TREA 31 East Distillation Scrubber (both w/no additive): Acetaldehyde: 32.5% Acrolein: 32.5% Formaldehyde: 32.5% Methanol: 95% TREA 34 West Scrubber (w/acetaldehyde control additive) Acetaldehyde: 85% Acrolein: 32.5% Formaldehyde: 85% Methanol: 95% TREA 11 East VRTO and TREA 29 West VRTO Acetaldehyde: 95% Acrolein: 95% Formaldehyde: 95% Methanol: 95%

33 Permit Expires: [month day, year] Page 31 of 243 For EQUI 179 (which is uncontrolled for HAPs), A#c is monthly operating hours and B# is the (uncontrolled) lb/hr emission rate determined by stack testing. In no instance shall a value be established for A#u for EQUI 179 because the unit does not have HAP emission control equipment. The Permittee shall establish and re confirm emission factors for these pollutants based on site specific performance test data and use the factors to calculate actual emissions of these individual HAPs. Step 2) The natural gas combustion formaldehyde and hexane emissions (lb/month), for the previous calendar month using Equation 2. Equation 2: Hc = (NG * EF)/2000 Where: Hc = Individual formaldehyde and hexane combustion emissions, tons/month NG = COMG 3 monthly natural gas usage, mmcf/month EF = AP 42 Table emission factor (7.5E 02 lb/mmcf; 1.8E+00 lb/mmcf, formaldehyde and hexane, respectively) Step 3) The natural gas combustion total HAP (minus formaldehyde and hexane) emissions for the previous calendar month using Equation 3. Equation 3: Hct = (NG * 1.3E 02)/2000 Where: Hct = monthly total HAP (minus formaldehyde and hexane) natural gas combustion emissions, tons/month NG = COMG 3 monthly natural gas usage, mmcf/month 1.3E 02 = composite total HAP emission factor (minus formaldehyde and hexane based on AP 42 Tables and 1.4 4) Step 4) The total monthly formaldehyde emissions (lb/month) by summing the monthly formaldehyde emissions determined by Equations 1 and 2. Step 5) The monthly total HAP emissions for the previous month by summing the acetaldehyde, acrolein, and methanol monthly emissions determined in Step 1 above, the formaldehyde monthly emissions determined in Step 4 above,

34 Permit Expires: [month day, year] Page 32 of 243 the hexane monthly emissions determined in Step 2 above, and the total combustion HAP minus formaldehyde and hexane monthly emissions determined in Step 3 above. (continued below). [Minn. R , subps. 4 5, Minn. R , Title I Condition: Avoid major source under 40 CFR 63.2] (continued from above) Step 6) The 12 month rolling sum emissions of each single HAP species for the previous 12 month period by individually summing the monthly emissions data for acetaldehyde, acrolein, and methanol for the previous 12 months determined in Step 1, by summing the monthly formaldehyde emissions data determined in Step 4, and by summing the hexane emissions data determined in Step 2. Step 7) The 12 month rolling sum total HAP emissions by summing the monthly total HAPs emissions data determined in Step 5 above, for the previous 12 months. [Minn. R , subps. 4 5, Minn. R , Title I Condition: Avoid major source under 40 CFR 63.2] COMG 6 GP007 Leaks From Equipment In VOC Service subp. VV The requirements of NSPS subp. VV remain effective until construction commences on EQUI 161 (West Plant Fermenter #6) triggering the requirements of NSPS subp. VVa for FUGI 6 and 7. When construction commences on EQUI 161, the requirements of NSPS subp. VVa located at COMG 9 will become effective and the requirements of NSPS subp. VV at COMG 6 will expire. [Minn. R , subp. 2] The requirements of COMG 6 apply separately to FUGI 6 and 7. [Minn. R , subp. 2] The Permittee shall meet the requirements of 40 CFR pt. 60, subp. VV (until the affected facility becomes subject to 40 CFR pt. 60, subp. VVa) for the control of VOC emissions from leaks from equipment in VOC service. [Title I Condition: 40 CFR 52.21(j)(BACT) & Minn. R ] Pumps in light liquid service: (a)(1) Each pump in light liquid service shall be monitored monthly to detect leaks by the methods specified in 40 CFR Section (b), except as provided in 40 CFR Section (c) and paragraphs (d), (e), and (f). (2) Each pump in light liquid service shall be checked by visual inspection each calendar week for indications of liquids

35 Permit Expires: [month day, year] Page 33 of 243 dripping from the seal. [40 CFR (a), Minn. R ] (b)(1) If an instrument reading of 10,000 ppm or greater is measured, a leak is detected. (2) If there are indications of liquids dripping from the pump seal, a leak is detected. (c)(1) When a leak is detected, it shall be repaired as soon as practicable, but not later than 15 calendar days after it is detected, except as proved in 40 CFR Section (Delay of Repair). (2) A first attempt at repair shall be made no later than 5 calendar days after each leak is detected. [40 CFR (b)&(c), Minn. R ] (a) Each compressor shall be equipped with a seal system that includes a barrier fluid system and that prevents leakage of VOC to the atmosphere, except as provided in 40 CFR Section (c) and 40 CFR Section (h) and (i). [40 CFR (a), Minn. R ] (b) Each compressor seal system shall be: (1) Operated with the barrier fluid at a pressure that is greater than the compressor stuffing box pressure; or (2) Equipped with a barrier fluid system that is connected by a closed vent system to a control device that complies with the requirements of 40 CFR Section ; or (3) Equipped with a system that purges the barrier fluid into a process stream with zero VOC emissions to the atmosphere. [40 CFR (b), Minn. R ] (c) The barrier fluid system shall be in heavy liquid service or shall not be in VOC service. (d) Each barrier fluid system shall be equipped with a sensor that will detect failure of the seal system, barrier fluid system, or both. [40 CFR (c)&(d), Minn. R ] (e)(1) Each sensor shall be checked daily or shall be equipped with an audible alarm. (2) The owner or operator shall determine, based on design considerations and operating experience, a criterion that indicates failure of the seal system, the barrier fluid system, or both. [40 CFR (e), Minn. R ] (f) If the sensor indicates failure of the seal system, the barrier system, or both based on the criterion determined under paragraph (e)(2), a leak is detected. [40 CFR (f), Minn.

36 Permit Expires: [month day, year] Page 34 of 243 R ] (g)(1) When a leak is detected, it shall be repaired as soon as practicable, but not later than 15 calendar days after it is detected except as provided in 40 CFR Section (Delay of Repair). (2) A first attempt at repair shall be made no later than 5 calendar days after it is detected, except as provided in 40 CFR Section [40 CFR (g), Minn. R ] (a) Except during pressure releases, each pressure relief device in gas/vapor service shall be operated with no detectable emissions, as indicated by an instrument reading of less than 500 ppm above background as determined by the methods specified in 40 CFR Section (c). [40 CFR (a), Minn. R ] (b)(1) After each pressure release, the pressure relief device shall be returned to a condition of no detectable emissions, as indicated by an instrument reading of less than 500 ppm above background, as soon as practicable, but no later than 5 calendar days after the pressure release, except as provided in 40 CFR Section (Delay of Repair). [40 CFR (b), Minn. R ] (a) Each sampling connection system shall be equipped with a closed purged, closed loop, or closed vent system, except as provided in 40 CFR Section (c). [40 CFR (a), Minn. R ] (b) Each closed purge, closed loop, or closed vent system shall: (1) Return the purged process fluid directly to the process line; or (2) Collect and recycle the purged process fluid to a process; or (3) Be designed and operated to capture and transport all the purged process fluid to a control device that complies with the requirements of 40 CFR Section (c) In situ sampling systems are exempt from these requirements. [40 CFR (b)&(c), Minn. R ] (a)(1) Each open ended valve or line shall be equipped with a cap, blind flange, plug, or a second valve, except as provided in 40 CFR Section (c). (2) The cap, blind flange, plug, or second valve shall seal the open end at all times except during operations requiring process fluid flow through the open ended valve or line. [40 CFR (a), Minn. R ] (b) Each open ended valve or line equipped with a second valve shall be operated in a manner such that the valve on the process fluid end is closed before the second valve is closed.

37 Permit Expires: [month day, year] Page 35 of 243 (c) When a double block and bleed system is being used, the bleed valve or line may remain open during operations that require venting the line between the block valves but shall comply with paragraph (a) at all other times. [40 CFR (b)&(c), Minn. R ] (a) Each valve shall be monitored monthly to detect leaks by the methods specified in 40 CFR Section (b). [40 CFR (a), Minn. R ] (b) If an instrument reading of 10,000 ppm or greater is measured, a leak is detected. (c)(1) Any valve for which a leak is not detected for 2 successive months may be monitored the first month of every quarter, beginning with the next quarter, until a leak is detected. (2) If a leak is detected, the valve shall be monitored monthly until a leak is not detected for 2 successive months. [40 CFR (b)&(c), Minn. R ] (d)(1) When a leak is detected, it shall be repaired as soon as practicable, but no later than 15 calendar days after the leak is detected, except as provided in 40 CFR Section (2) A first attempt at repair shall be made no later than 5 calendar days after each leak is detected. [40 CFR (d), Minn. R ] (e) First attempts at repair include, but are not limited to, the following best practices where practicable: (1) Tightening of bonnet bolts; (2) Replacement of bonnet bolts; (3) Tightening of packing gland nuts; (4) Injection of lubricant into lubricated packing. [40 CFR (e), Minn. R ] (a) Pumps and valves in heavy liquid service, pressure relief devices in light liquid or heavy liquid service and flanges and other connectors shall be monitored within 5 days by the method specified in 40 CFR Section (b) if evidence of a potential leak is found by visual, audible, olfactory, or any other detection method. [40 CFR (a), Minn. R ] (b) If an instrument reading of 10,000 ppm or greater is measured, a leak is detected. (c)(1) When a leak is detected, it shall be repaired as soon as practible, but not later than 15 calendar days after it is detected, except as provided in 40 CFR Section (delay of repair).

38 Permit Expires: [month day, year] Page 36 of 243 (2) The first attempt at repair shall be made no later than 5 calendar days after each leak is detected. [40 CFR (b)&(c), Minn. R ] (d) First attempts at repair include, but are not limited to, the best practices described under 40 CFR Section (e). [40 CFR (d), Minn. R ] (a) Delay of repair of equipment for which leaks have been detected will be allowed if the repair is technically infeasible without a process unit shutdown. Repair of this equipment shall occur before the end of the next process unit shutdown. (b) Delay of repair of equipment will be allowed for equipment which is isolated from the process and which does not remain in VOC service. [40 CFR (a)&(b), Minn. R ] (c) Delay of repair for valves will be allowed if: (1) The owner or operator demonstrates that emissions of purged material resulting from the immediate repair are greater than the fugitive emissions likely to result from delay of repair, and (2) When repair procedures are effected, the purged material is collected and destroyed or recovered in a control device complying with 40 CFR Section [40 CFR (c), Minn. R ] (d) Delay of repair for pumps will be allowed if: (1) Repair required the use of a dual mechanical seal system that includes a barrier fluid system, and (2) Repair is completed as soon as practicable, but not later than 6 months after the leak was detected. [40 CFR (d), Minn. R ] (e) Delay of repair beyond a process unit shutdown will be allowed for a valve, if valve assembly replacement is necessary during the process unit shutdown, valve assembly supplies have been depleted, and valve assembly supplies had been sufficiently stocked before the supplies were depleted. Delay of repair beyond the next process unit shutdown will not be allowed unless the next process unit shutdown occurs sooner than 6 months after the first process unit shutdown. [40 CFR (e), Minn. R ] Compliance shall be determined by the methods specified in 40 CFR Section [40 CFR (b), Minn. R ] (b) When each leak is detected, the following requirements apply: (1) A weatherproof and readily visible identification, marked with the equipment identification number, shall be attached to

39 Permit Expires: [month day, year] Page 37 of 243 the leaking equipment. (2) The identification on a valve may be removed after it has been monitored for 2 successive months as specified in 40 CFR Section (c) and no leak has been detected during those 2 months. (3) The identification on equipment except on a valve, may be removed after it has been repaired. [40 CFR (b), Minn. R ] (c) When each leak is detected the following information shall be recorded in a log and shall be kept for 2 years in a readily accessible location: (1) The instrument and operator identification numbers and the equipment identification number. (2) The date the leak was detected and the dates of each attempt to repair the leak. (3) Repair methods applied in each attempt to repair the leak. (4) Above 10,000 is the maximum instrument reading measured by the methods specified in 40 CFR Section (a) after each repair attempt is equal to or greater than 10,000 ppm. (5) Repair delayed and the reason for the delay if a leak is not repaired within 15 calendar days after discover of the leak. (6) The signature of the owner or operator whose decision it was that the repair could not be effected without a process shutdown. (7) The expected date of successful repair of the leak if a leak is not repaired within 15 days. (8) Dates of process unit shutdown that occur while the equipment is unrepaired. (9) The date of successful repair of the leak. [40 CFR (c), Minn. R ] (a) Each owner or operator subject to the provisions of this subpart shall submit semiannual reports to the Administrator beginning six months after the initial startup date. [40 CFR (a), Minn. R ] (b) The initial semiannual report to the Administrator shall include the following information: (1) Process unit identification, (2) Number of valves subject to the requirements of 40 CFR Section , (3) Number of pumps subject to the requirements of 40 CFR Section , (4) Number of compressors subject to the requirements of 40 CFR Section [40 CFR (b), Minn. R ] (c) All semiannual reports to the Administrator shall include

40 Permit Expires: [month day, year] Page 38 of 243 the following information, summarized from the information in 40 CFR Section ; (1) Process unit identification. (2) For each month during the semiannual reporting period, (i) Number of valves for which leaks were detected as described in 40 CFR Section (7)(b) or 40 CFR Section , (ii) Number of valves for which leaks were not repaired as required in 40 CFR Section (d)(1), (iii) Number of pumps for which leaks were detected as described in 40 CFR Section (b) and (d)(6)(i), (iv) Number of pumps for which leaks were not repaired as required in 40 CFR Section (c)(1) and (d)(6)(ii), (v) Number of compressors for which leaks were detected as described in 40 CFR Section (f), (vi) Number of compressors for which leaks were not repaired as required in 40 CFR Section (g)(1), (vii) The facts that explain each delay of repair and, where appropriate, why a process unit shutdown was technically infeasible. (3) Dates of process unit shutdowns which occurred within the semiannual reporting period. (4) Revisions to items reported according to paragraph (b) if changes have occurred since the initial report or subsequent revisions to the initial report. [40 CFR (c), Minn. R ] (e) Report the results of all performance tests in accordance with 40 CFR Section The provisions of 40 CFR Section 60.8(d) do not apply to affected facilities subject to the provisions of this subpart except than an owner or operator must notify the Administrator of the schedule for the initial performance tests at least 30 days before the initial performance tests. [40 CFR (e), Minn. R ] COMG 7 GP001 Storage Tanks Subject To NSPS Subp. Kb 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. [40 CFR 60.7(a)(4), Minn. R , subp. 1] Recordkeeping: The Permittee shall 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. [40 CFR 60.7(b), Minn. R , subp. 1]

41 Permit Expires: [month day, year] Page 39 of Recordkeeping: The Permittee shall maintain a file of all measurements, maintenance, reports and records for at least five years. This requirement is more stringent than 40 CFR Section 60.7(f), which specifies two years. [40 CFR 60.7(f), Minn. R , subp. 5(C), Minn. R , subp. 1] No Permittee 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. [40 CFR 60.12, Minn. R ] The Permittee shall equip EQUI 106 with a permanent submerged fill pipe or comply with the requirements of Minn. R , subp. 3(C). [Minn. R , subp. 3(B)] The Permittee shall equip EQUI 104, 105, , 148, 157 and 160 with a floating roof, a vapor recovery system, or their equivalents. [Minn. R , subp. 3(C)(1)] Each COMG 7 storage vessel shall be equipped with a fixed roof in combination with an internal floating roof meeting the requirements of 40 CFR Section b(a)(1). [40 CFR b(a), Minn. R , C, Title I Condition: 40 CFR 52.21(j)(BACT) & Minn. R ] The internal floating roof shall rest or float on the liquid surface (but not necessarily in complete contact with it) inside a storage vessel that has a fixed roof. The internal floating roof shall be floating on the liquid surface at all times, except during initial fill and during those intervals when the storage vessel is completely emptied or subsequently emptied and refilled. When the roof is resting on the leg supports, the process of filling, emptying, or refilling shall be continuous and shall be accomplished as rapidly as possible. [40 CFR b(a)(1)(i), Minn. R , C] Each internal floating roof shall be equipped with a closure device between the wall of the storage vessel and the edge of the internal floating roof consisting of two seals mounted one above the other so that each forms a continuous closure that completely covers the space between the wall of the storage vessel and the edge of the internal floating roof. The lower seal may be vapor mounted, but both must be continuous. [40 CFR b(a)(1)(ii)(B), Minn. R , C] Each opening in a noncontact internal floating roof except for automatic bleeder vents (vacuum breaker vents) and the rim space vents is to provide a projection below the liquid surface. [40 CFR b(a)(1)(iii), Minn. R , C] Each opening in the internal floating roof except for leg sleeves, automatic bleeder vents, rim space vents, column wells, ladder wells, sample wells, and stub drains is to be equipped with a cover or lid which is to be maintained in a closed position at all times (i.e., no visible gap) except when the device is in actual use. The cover or lid shall be equipped with a gasket. Covers on each access hatch and automatic

42 Permit Expires: [month day, year] Page 40 of 243 gauge float well shall be bolted except when they are in use. [40 CFR b(a)(1)(iv), Minn. R , C] Automatic bleeder vents shall be equipped with a gasket and are to be closed at all times when the roof is floating except when the roof is being floated off or is being landed on the roof leg supports. [40 CFR b(a)(1)(v), Minn. R , C] Rim space vents shall be equipped with a gasket and are to be set to open only when the internal floating roof is not floating or at the manufacturer's recommended setting. [40 CFR b(a)(1)(vi), Minn. R , C] Each penetration of the internal floating roof for the purpose of sampling shall be a sample well. The sample well shall have a slit fabric cover that covers at least 90 percent of the opening. [40 CFR b(a)(1)(vii), Minn. R , C] Each penetration of the internal floating roof that allows for passage of a column supporting the fixed roof shall have a flexible fabric sleeve seal or a gasketed sliding cover. [40 CFR b(a)(1)(viii), Minn. R , C] Each penetration of the internal floating roof that allows for passage of a ladder shall have a gasketed sliding cover. [40 CFR b(a)(1)(ix), Minn. R , C] The Permittee shall visually inspect the internal floating roof, the primary seal, and the secondary seal, prior to filling the storage vessel with Volatile Organic Liquid (VOL). If there are holes, tears, or other openings in the primary seal, the secondary seal, or the seal fabric, or defects in the internal floating roof, or both, the Permittee shall repair the items before filling the storage vessel. [40 CFR b(a)(1), Minn. R , C] The Permittee shall visually inspect the internal floating roof and the primary seal or the secondary seal through manholes and roof hatches on the fixed roof at least once every 12 months after initial fill. If the internal floating roof is not resting on the surface of the VOL inside the storage vessel, or there is liquid accumulated on the roof, or the seal is detached, or there are holes or tears in the seal fabric, the Permittee shall repair the items or empty and remove the storage vessel from service within 45 days. If a failure that is detected during inspections cannot be repaired within 45 days and if the vessel cannot be emptied within 45 days, a 30 day extension may be requested from the Administrator in the inspection report required in 40 CFR Section b(a)(3). Such a request for an extension must document that alternate storage capacity is unavailable and specify a schedule of actions the company will take that will assure that the control equipment will be repaired or the vessel will be emptied as soon as possible. [40 CFR b(a)(3)(ii), Minn. R , C]

43 Permit Expires: [month day, year] Page 41 of Visually inspect the internal floating roof, the primary seal, the secondary seal (if one is in service), gaskets, slotted membranes and sleeve seals (if any) each time the storage vessel is emptied and degassed. If the internal floating roof has defects, the primary seal has holes, tears, or other openings in the seal or the seal fabric, or the secondary seal has holes, tears, or other openings in the seal or the seal fabric, or the gaskets no longer close off the liquid surfaces from the atmosphere, or the slotted membrane has more than 10 percent open area, the Permittee shall repair the items as necessary so that none of the conditions contained within this requirement exist before refilling the storage vessel with VOL. In no event shall inspections conducted in accordance with this provision occur at intervals greater than 10 years in the case of vessels conducting the annual visual inspection as specified in 40 CFR Sections b(a)(2) and (a)(3)(ii). [40 CFR b(a)(4), Minn. R , C] Notification: If an inspection is required (under 40 CFR Section b(a)(1) or 40 CFR Section b(a)(3)(i)), the Permittee shall notify the Commissioner in writing at least 30 days prior to the filling or refilling of the storage vessel, to afford the Commissioner the opportunity to have an observer present. If the inspection is not planned and the Permittee could not have known about the inspection 30 days in advance of the refilling the tank, the Permittee shall notify the Commissioner at least 7 days prior to the refilling of the storage vessel. Notification shall be made by telephone immediately followed by written documentation demonstrating why the inspection was unplanned. Alternatively, this notification including the written documentation may be made in writing and sent by express mail so that it is received by the Commissioner at least 7 days prior to refilling. [40 CFR b(a)(5), Minn. R , C] Notification: The Permittee shall furnish the Commissioner with a report describing the internal floating roof and certifying that it meets the specifications of 40 CFR Section b(a)(1) and 40 CFR Section b(a)(1). The report shall be an attachment to the notification of actual date of initial startup required by 40 CFR Section 60.7(a)(3). [40 CFR b(a)(1), Minn. R , C] The Permittee shall keep a record of each inspection performed as required by 40 CFR Section b(a)(1), (a)(2), (a)(3), and (a)(4). Each record shall identify the storage vessel on which the inspection was performed and shall contain the date the vessel was inspected and the observed condition of each component of the control equipment (seals, internal floating roof, and fittings). [40 CFR b(a)(2), Minn. R , C] After each inspection required under 40 CFR Section

44 Permit Expires: [month day, year] Page 42 of b(a)(3) that finds holes or tears in the seal or seal fabric, or defects in the internal floating roof, or other control equipment defects listed in 40 CFR Section b(a)(3)(ii), a report shall be furnished to the Commissioner within 30 days of the inspection. The report shall identify the storage vessel and the reason it did not meet the specifications of 40 CFR Section b(a)(1) or 40 CFR Section b(a)(3)(ii), and list each repair made. [40 CFR b(a)(4), Minn. R , C] The Permittee shall keep copies of all records for at least 2 years. The record showing the dimension of the storage vessel and an analysis showing the capacity of the storage vessel will be kept for the life of the source. [40 CFR b(a), Minn. R , C] Recordkeeping: The Permittee shall maintain records showing the volatile organic liquid (VOL) stored, the period of storage, and the maximum true vapor pressure of the VOL during the respective storage period, calculated as described in 40 CFR Section b(e). [40 CFR b(c), Minn. R , C] The Permittee shall keep readily accessible records showing the dimensions of each COMG 7 storage vessel and an analysis showing the capacity of each storage vessel for the life of the source. This requirement does not apply to EQUI 103 and EQUI 132. [40 CFR b(a), 40 CFR b(b), Minn. R , C] COMG 9 GP009 Leaks From Equipment In VOC Service subp. VVa The requirements of NSPS subp. VVa become effective upon commencing construction of EQUI 161 (West Plant Fermenter #6). Upon the effectiveness of NSPS subp. VVa, the requirements of NSPS subp. VV contained in COMG 6 will expire. [Minn. R , subp. 2] 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. This requirement does not apply if the change is specifically exempted under an applicable subpart (in 40 CFR part 60) or in 40 CFR Section 60.14(e). The notification shall include information describing the precise nature of the change, present and proposed emission control systems, productive capacity of the facility before and after the change, and the expected completion date of the change. The Commissioner may request additional relevant information subsequent to this notice. [40 CFR 60.7(a)(4), Minn. R , subp. 1] Recordkeeping: The Permittee shall maintain records of the occurrence and duration of any startup, shutdown, or

45 Permit Expires: [month day, year] Page 43 of 243 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. [40 CFR 60.7(b), Minn. R , subp. 1] Recordkeeping: The Permittee shall maintain a file of all measurements, maintenance, reports and records for at least five years. This requirement is more stringent than 40 CFR Section 60.7(f), which specifies two years. [40 CFR 60.7(f), Minn. R , subp. 5(C), Minn. R , subp. 1] 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. [40 CFR 60.12, Minn. R ] COMG 9 requirements apply separately to each affected facility, FUGI 6 and 7. [Minn. R , subp. 2] Equipment means each pump, compressor, pressure relief device, sampling connection system, open ended valve or line, valve, and flange or other connector in VOC service and any devices or systems required by 40 CFR pt. 60, subp. VVa. [40 CFR a] The Permittee shall demonstrate compliance with the requirements of 40 CFR Sections a through a or Section a(e) for all equipment upon issuance of permit no [40 CFR a(a)] Equipment that the Permittee designates as being in VOC service less than 300 hr/yr is excluded from the requirements of 40 CFR Section a a if it is identified as required in 40 CFR Section (e)(6) and: 1) The equipment is in VOC service only during startup and shutdown, excluding startup and shutdown between batches of the same campaign for a batch process. 2) The equipment is in VOC service only during process malfunctions or other emergencies. 3) The equipment is backup equipment that is in VOC service only when the primary equipment is out of service. [40 CFR a(e)] If a dedicated batch process unit operates less than 365 days during a year, the Permittee may monitor at a reduced frequency as specified in 40 CFR Section a(f). [40 CFR a(f)] If the storage vessel is shared with multiple process units, the process unit with the greatest annual amount of stored materials (predominant use) is the process unit the storage vessel is assigned to. If the storage vessel is shared equally among process units, and one of the process units has equipment subject to 40 CFR pt. 60, subp. VVa, the storage vessel is assigned to that process unit. If the storage vessel is

46 Permit Expires: [month day, year] Page 44 of 243 shared equally among process units, none of which have equipment subject to 40 CFR pt. 60, subp. VVa of this part, the storage vessel is assigned to any process unit subject to 40 CFR pt. 60, subp. VV. If the predominant use of the storage vessel varies from year to year, then the Permittee must estimate the predominant use initially and reassess every 3 years. The Permittee must keep records of the information and supporting calculations that show how predominant use is determined. All equipment on the storage vessel must be monitored when in VOC service. [40 CFR a(g)] Pumps in light liquid service: (1) Each pump in light liquid service shall be monitored monthly to detect leaks by the methods specified in 40 CFR Section a(b), except as provided in 40 CFR Section a(c) and (f) and 40 CFR Section a(d), (e) and (f). A pump that begins operation in light liquid service after the initial startup date for the process unit must be monitored for the first time within 30 days after the end of its startup period, except for a pump that replaces a leaking pump and except as provided in Section a(c) and 40 CFR Section a(d), (e) and (f). (2) Each pump in light liquid service shall be checked by visual inspection each calendar week for indications of liquids dripping from the pump seal, except as provided in 40 CFR Section a(f). [40 CFR a(a)] For the purpose of the requirements of this section of the permit, the instrument reading that defines a leak is as follows: (i) 5,000 parts per million (ppm) or greater for pumps handling polymerizing monomers; (ii) 2,000 ppm or greater for all other pumps. [40 CFR a(b)(1)] If there are indications of liquids dripping from the pump seal, the Permittee shall follow one of the procedures specified in this item. This requirement does not apply to a pump that was monitored after a previous weekly inspection and the instrument reading was less than the concentration listed above, whichever is applicable. (i) Monitor the pump within 5 days as specified in 40 CFR Section a(b). If a leak is detected, the leak shall be repaired using the procedures in 40 CFR Section a(c). (ii) Designate the visual indications of liquids dripping as a leak, and repair the leak using either the procedures in 40 CFR Section a(c) or by eliminating the visual indications of liquids dripping. [40 CFR a(b)(2)] (1) When a leak is detected, it shall be repaired as soon as practicable, but not later than 15 calendar days after it is detected, except as provided in 40 CFR Section a. (2) A first attempt at repair shall be made no later than 5 calendar days after each leak is detected. First attempts at

47 Permit Expires: [month day, year] Page 45 of 243 repair include, but are not limited to, the practices described in 40 CFR Section a(c)(2)(i) and (ii), where applicable. (i) Tightening the packing gland nuts; (ii) Ensuring that the seal flush is operating at design pressure and temperature. [40 CFR a(c)] Each pump equipped with a dual mechanical seal system that includes a barrier fluid system is exempt from the requirements of 40 CFR Section a(a), provided the requirements specified in 40 CFR Section a(d)(1) through (6) are met. [40 CFR a(d)] Any pump that is designated, as described as follows, for no detectable emissions, as indicated by an instrument reading of less than 500 ppm above background, is exempt from the requirements of 40 CFR Section a(a), (c), and (d) if the pump: (1) Has no externally actuated shaft penetrating the pump housing; (2) Is demonstrated to be operating with no detectable emissions as indicated by an instrument reading of less than 500 ppm above background as measured by the methods specified in 40 CFR Section a(c); and (3) Is tested for compliance with 40 CFR Section a(e)(2) initially upon designation, annually, and at other times requested by the Commissioner. [40 CFR a(e)] If any pump is equipped with a closed vent system capable of capturing and transporting any leakage from the seal or seals to a process or to a fuel gas system or to a control device that complies with the requirements of 40 CFR Section a, it is exempt from 40 CFR Section a(a) through (e). [40 CFR a(f)] Any pump that is designated, as described in 40 CFR Section a(f)(1), as an unsafe to monitor pump is exempt from the monitoring and inspection requirements of 40 CFR Section a(a) and (d)(4) through (6) if: (1) The Permittee demonstrates that the pump is unsafe tomonitor because monitoring personnel would be exposed to an immediate danger as a consequence of complying with 40 CFR Section a(a); and (2) The Permittee has a written plan that requires monitoring of the pump as frequently as practicable during safe tomonitor times, but not more frequently than the periodic monitoring schedule otherwise applicable, and repair of the equipment according to the procedures in 40 CFR Section a(c) if a leak is detected. [40 CFR a(g)] Any pump that is located within the boundary of an unmanned plant site is exempt from the weekly visual inspection requirement of 40 CFR Section a(a)(2) and (d)(4), and the daily requirements of 40 CFR Section a(d)(5), provided that each pump is visually inspected as often as

48 Permit Expires: [month day, year] Page 46 of 243 practicable and at least monthly. [40 CFR a(h)] Each compressor shall be equipped with a seal system that includes a barrier fluid system and that prevents leakage of VOC to the atmosphere, except as provided in 40 CFR Section a(c) and 40 CFR Section a(h), (i), and (j). [40 CFR a(a)] Each compressor seal system shall be: (1) Operated with the barrier fluid at a pressure that is greater than the compressor stuffing box pressure; or (2) Equipped with a barrier fluid system degassing reservoir that is routed to a process or fuel gas system or connected by a closed vent system to a control device that complies with the requirements of 40 CFR Section a; or (3) Equipped with a system that purges the barrier fluid into a process stream with zero VOC emissions to the atmosphere. [40 CFR a(b)] The barrier fluid system shall be in heavy liquid service or shall not be in VOC service. [40 CFR a(c)] Each barrier fluid system shall be equipped with a sensor that will detect failure of the seal system, barrier fluid system, or both. [40 CFR a(d)] (1) Each sensor shall be checked daily or shall be equipped with an audible alarm. (2) The Permittee shall determine, based on design considerations and operating experience, a criterion that indicates failure of the seal system, the barrier fluid system, or both. [40 CFR a(e)] If the sensor indicates failure of the seal system, the barrier system, or both based on the criterion determined under paragraph (e)(2) of 40 CFR Section a, a leak is detected. [40 CFR a(f)] (1) When a leak is detected, it shall be repaired as soon as practicable, but not later than 15 calendar days after it is detected except as provided in 40 CFR Section a. (2) A first attempt at repair shall be made no later than 5 calendar days after each leak is detected. [40 CFR a(g)] A compressor is exempt from the requirements of 40 CFR Section a(a) and (b), if it is equipped with a closed vent system to capture and transport leakage from the compressor drive shaft back to a process or fuel gas system or to a control device that complies with the requirements of 40 CFR Section a, except as provided in 40 CFR Section a(i). [40 CFR a(h)] Any compressor that is designated, as described in 40 CFR Section a(e)(1) and (2), for no detectable emissions, as indicated by an instrument reading of less than 500 ppm above background, is exempt from the requirements of 40 CFR Section a(a) through (h) if the compressor:

49 Permit Expires: [month day, year] Page 47 of 243 (1) Is demonstrated to be operating with no detectable emissions, as indicated by an instrument reading of less than 500 ppm above background, as measured by the methods specified in 40 CFR Section a(c); and (2) Is tested for compliance with the prior paragraph initially upon designation, annually, and at other times requested by the Commissioner. [40 CFR a(i)] Any existing reciprocating compressor in a process unit which becomes an affected facility under provisions of 40 CFR Sections or is exempt from 40 CFR Section a(a) through (e) and (h), provided the Permittee demonstrates that recasting the distance piece or replacing the compressor are the only options available to bring the compressor into compliance with the provisions of 40 CFR Section a(a) through (e) and (h). [40 CFR a(j)] Except during pressure releases, each pressure relief device in gas/vapor service shall be operated with no detectable emissions, as indicated by an instrument reading of less than 500 ppm above background as determined by the methods specified in 40 CFR Section a(c). [40 CFR a(a)] (1) After each pressure release, the pressure relief device shall be returned to a condition of no detectable emissions, as indicated by an instrument reading of less than 500 ppm above background, as soon as practicable, but no later than 5 calendar days after the pressure release, except as provided in 40 CFR Section a (Delay of Repair). (2) No later than 5 calendar days after the pressure release, the pressure relief device shall be monitored to confirm the conditions of no detectable emissions, as indicated by an instrument reading of less than 500 ppm above background, by the methods specified in 40 CFR Section a(c). [40 CFR a(b)] Any pressure relief device that is routed to a process or fuel gas system or equipped with a closed vent system capable of capturing and transporting leakage through the pressure relief device to a control device as described in Section a is exempted from the previous two items. [40 CFR a(c)] (1) Any pressure relief device that is equipped with a rupture disk upstream of the pressure relief device is exempt from the previous two items, provided the Permittee complies with the following paragraph. (2) After each pressure release, a new rupture disk shall be installed upstream of the pressure relief device as soon as practicable, but no later than 5 calendar days after each pressure release, except as provided in 40 CFR Section a. [40 CFR a(d)] Each sampling connection system shall be equipped with a closed purge, closed loop, or closed vent system, except as provided in 40 CFR Section a(c) and 40 CFR Section

50 Permit Expires: [month day, year] Page 48 of a(c). [40 CFR a(a)] Each closed purge, closed loop, or closed vent system as required in 40 CFR Section a(a) shall comply with the following requirements: (1) Gases displaced during filling of the sample container are not required to be collected or captured. (2) Containers that are part of a closed purge system must be covered or closed when not being filled or emptied. (3) Gases remaining in the tubing or piping between the closed purge system valve(s) and sample container valve(s) after the valves are closed and the sample container is disconnected are not required to be collected or captured. (4) Each closed purge, closed loop, or closed vent system shall be designed and operated to meet requirements in either 40 CFR Section a(b)(4)(i), (ii), (iii), or (iv). [40 CFR a(b)] In situ sampling systems and sampling systems without purges are exempt from the requirements of 40 CFR Section a(a) and (b). [40 CFR a(c)] (1) Each open ended valve or line equipped with a second valve shall be operated in a manner such that the valve on the process fluid end is closed before the second valve is closed. (2) The cap, blind flange, plug, or second valve shall seal the open end at all times except during operations requiring process fluid flow through the open ended valve or line. [40 CFR a(a)] Each open ended valve or line equipped with a second valve shall be operated in a manner such that the valve on the process fluid end is closed before the second valve is closed. [40 CFR a(b)] When a double block and bleed system is being used, the bleed valve or line may remain open during operations that require venting the line between the block valves but shall comply with 40 CFR Section a(a) at all other times. [40 CFR a(c)] Open ended valves or lines in an emergency shutdown system which are designed to open automatically in the event of a process upset are exempt from the requirements of 40 CFR Section a(a), (b), and (c). [40 CFR a(d)] Open ended valves or lines containing materials which would autocatalytically polymerize or would present an explosion, serious overpressure, or other safety hazard if capped or equipped with a double block and bleed system as specified in 40 CFR Section a(a) through (c) are exempt from the requirements of 40 CFR Section a(a) through (c). [40 CFR a(e)] (1) Each valve shall be monitored monthly to detect leaks by the methods specified in 40 CFR Section a(b) and shall comply with 40 CFR Section a(b) through (e), as

51 Permit Expires: [month day, year] Page 49 of 243 detailed in this permit, except as provided in 40 CFR Section a(f), (g), and (h), 40 CFR Section a(c) and (f), and 40 CFR Sections a and a. (2) A valve that begins operation in gas/vapor service or light liquid service after the initial startup date for the process unit shall be monitored according to 40 CFR Section a(a)(2)(i) or (ii) below, except for a valve that replaces a leaking valve and except as provided in 40 CFR Sections a(f), (g), and (h), a(c), and a and a. (i) Monitor the valve as in 40 CFR Section a(a)(1). The valve must be monitored for the first time within 30 days after the end of its startup period to ensure proper installation. (ii) If the existing valves in the process unit are monitored in accordance with 40 CFR Sections a or a, count the new valve as leaking when calculating the percentage of valves leaking as described in 40 CFR Section a(b)(5). If less than 2.0 percent of the valves are leaking for that process unit, the valve shall be monitored for the first time during the next scheduled monitoring event for existing valves in the process unit or within 90 days, whichever comes first. [40 CFR a(a)] If an instrument reading of 500 ppm or greater is measured, a leak is detected. [40 CFR a(b)] (1)(i) Any valve for which a leak is not detected for 2 successive months may be monitored the first month of every quarter, beginning with the next quarter, until a leak is detected. (ii) As an alternative to monitoring all of the valves in the first month of a quarter, an Permittee may elect to subdivide the process unit into two or three subgroups of valves and monitor each subgroup in a different month during the quarter, provided each subgroup is monitored every 3 months. The Permittee must keep records of the valves assigned to each subgroup. (2) If a leak is detected, the valve shall be monitored monthly until a leak is not detected for 2 successive months. [40 CFR a(c)] (1) When a leak is detected, it shall be repaired as soon as practicable, but no later than 15 calendar days after the leak is detected, except as provided in 40 CFR Section a. (2) A first attempt at repair shall be made no later than 5 calendar days after each leak is detected. [40 CFR a(d)] First attempts at repair include, but are not limited to, the following best practices where practicable: (1) Tightening of bonnet bolts; (2) Replacement of bonnet bolts; (3) Tightening of packing gland nuts; (4) Injection of lubricant into lubricated packing. [40 CFR

52 Permit Expires: [month day, year] Page 50 of a(e)] Any valve that is designated, as described in 40 CFR Section a(e)(2), for no detectable emissions, as indicated by an instrument reading of less than 500 ppm above background, is exempt from the requirements of 40 CFR Section a(a) if the valve: (1) Has no external actuating mechanism in contact with the process fluid, (2) Is operated with emissions less than 500 ppm above background as determined by the method specified in 40 CFR Section a(c), and (3) Is tested for compliance with the previous paragraph initially upon designation, annually, and at other times requested by the Commissioner. [40 CFR a(f)] Any valve that is designated, as described in 40 CFR Section a(f)(1), as an unsafe to monitor valve is exempt from the requirements of 40 CFR Section a(a) if: (1) The Permittee demonstrates that the valve is unsafe to monitor because monitoring personnel would be exposed to an immediate danger as a consequence of complying with 40 CFR Section a(a), and (2) The Permittee adheres to a written plan that requires monitoring of the valve as frequently as practicable during safe to monitor times. [40 CFR a(g)] Any valve that is designated, as described in 40 CFR Section a(f)(2), as a difficult to monitor valve is exempt from the requirements of 40 CFR Section a(a) if: (1) The Permittee demonstrates that the valve cannot be monitored without elevating the monitoring personnel more than 2 meters above a support surface. (2) The process unit within which the valve is located: (i) Becomes an affected facility through 40 CFR Section or and was constructed on or before January 5, 1981; or (ii) Has less than 3.0 percent of its valves designated as difficult to monitor by the Permittee. (3) The Permittee follows a written plan that requires monitoring of the valve at least once per calendar year. [40 CFR a(h)] If evidence of a potential leak is found by visual, audible, olfactory, or any other detection method at pumps, valves, and connectors in heavy liquid service and pressure relief devices in light liquid or heavy liquid service, the Permittee shall follow either one of the following procedures: (1) The Permittee shall monitor the equipment within 5 days by the method specified in 40 CFR Section a(b) and shall comply with the requirements of 40 CFR Section a(b)

53 Permit Expires: [month day, year] Page 51 of 243 through (d). (2) The Permittee shall eliminate the visual, audible, olfactory, or other indication of a potential leak within 5 calendar days of detection. [40 CFR a(a)] If an instrument reading of 10,000 ppm or greater is measured, a leak is detected. [40 CFR a(b)] (1) When a leak is detected, it shall be repaired as soon as practicable, but not later than 15 calendar days after it is detected, except as provided in 40 CFR Section a (delay of repair). (2) The first attempt at repair shall be made no later than 5 calendar days after each leak is detected. [40 CFR a(c)] First attempts at repair include, but are not limited to, the best practices described under 40 CFR Sections a(c)(2) and a(e). [40 CFR a(d)] Delay of repair of equipment for which leaks have been detected will be allowed if repair within 15 days is technically infeasible without a process unit shutdown. Repair of this equipment shall occur before the end of the next process unit shutdown. Monitoring to verify repair must occur within 15 days after startup of the process unit. [40 CFR a(a)] Delay of repair of equipment will be allowed for equipment which is isolated from the process and which does not remain in VOC service. [40 CFR a(b)] Delay of repair for valves and connectors will be allowed if: (1) The Permittee demonstrates that emissions of purged material resulting from immediate repair are greater than the fugitive emissions likely to result from delay of repair, and (2) When repair procedures are effected, the purged material is collected and destroyed or recovered in a control device complying with 40 CFR Section a. [40 CFR a(c)] Delay of repair for pumps will be allowed if: (1) Repair required the use of a dual mechanical seal system that includes a barrier fluid system, and (2) Repair is completed as soon as practicable, but not later than 6 months after the leak was detected. [40 CFR a(d)] Delay of repair beyond a process unit shutdown will be allowed for a valve, if valve assembly replacement is necessary during the process unit shutdown, valve assembly supplies have been depleted, and valve assembly supplies had been sufficiently stocked before the supplies were depleted. Delay of repair beyond the next process unit shutdown will not be allowed unless the next process unit shutdown occurs sooner than 6 months after the first process unit shutdown. [40 CFR a(e)] When delay of repair is allowed for a leaking pump, valve, or

54 Permit Expires: [month day, year] Page 52 of 243 connector that remains in service, the pump, valve, or connector may be considered to be repaired and no longer subject to delay of repair requirements if two consecutive monthly monitoring instrument readings are below the leak definition. [40 CFR a(f)] If the Permittee utilizes closed vent systems and control devices used to comply with provisions of 40 CFR pt. 60, subp. VVa, the Permittee shall comply with the provisions of 40 CFR Section a as detailed in this permit. [40 CFR a(a)] Vapor recovery systems (for example, condensers and absorbers) shall be designed and operated to recover the VOC emissions vented to them with an efficiency of 95 percent or greater, or to an exit concentration of 20 parts per million by volume (ppmv), whichever is less stringent. [40 CFR a(b)] Enclosed combustion devices shall be designed and operated to reduce the VOC emissions vented to them with an efficiency of 95 percent or greater, or to an exit concentration of 20 ppmv, on a dry basis, corrected to 3 percent oxygen, whichever is less stringent or to provide a minimum residence time of 0.75 seconds at a minimum temperature of 816 deg C. [40 CFR a(c)] Flares used to comply with 40 CFR pt. 60, subp. VVa shall comply with the requirements of 40 CFR Section [40 CFR a(d)] The Permittee shall monitor the control devices to ensure that they are operated and maintained in conformance with their designs. [40 CFR a(e)] Except as provided in 40 CFR Section a(i) through (k), each closed vent system shall be inspected according to the following procedures: (1) If the vapor collection system or closed vent system is constructed of hard piping, the Permittee shall comply with the following requirements: (i) Conduct an initial inspection according to the procedures in 40 CFR Section a(b); and (ii) Conduct annual visual inspections for visible, audible, or olfactory indications of leaks. (2) If the vapor collection system or closed vent system is constructed of ductwork, the Permittee shall: (i) Conduct an initial inspection according to the procedures in 40 CFR Section a(b); and (ii) Conduct annual inspections according to the procedures in 40 CFR Section a(b). [40 CFR a(f)] Leaks, as indicated by an instrument reading greater than 500 ppmv above background or by visual inspections, shall be repaired as soon as practicable except as provided in 40 CFR Section a(h).

55 Permit Expires: [month day, year] Page 53 of 243 (1) A first attempt at repair shall be made no later than 5 calendar days after the leak is detected. (2) Repair shall be completed no later than 15 calendar days after the leak is detected. [40 CFR a(g)] Delay of repair of a closed vent system for which leaks have been detected is allowed if the repair is technically infeasible without a process unit shut down or if the Permittee determines that emissions resulting from immediate repair would be greater than the fugitive emissions likely to result from delay of repair. Repair of such equipment shall be complete by the end of the next process unit shutdown. [40 CFR a(h)] If a vapor collection system or closed vent system is operated under a vacuum, it is exempt from the inspection requirements of 40 CFR Section a(f)(1)(i) and f(2). [40 CFR a(i)] Any parts of the closed vent system that are designated, as described in 40 CFR Section a(l)(1), as unsafe to inspect are exempt from the inspection requirements of 40 CFR Section a(f)(1)(i) and (f)(2) if they comply with the following requirements: (1) The Permittee determines that the equipment is unsafe to inspect because inspecting personnel would be exposed to an imminent or potential danger as a consequence of complying with 40 CFR Section a(f)(1)(i) or (f)(2); and (2) The Permittee has a written plan that requires inspection of the equipment as frequently as practicable during safe toinspect times. [40 CFR a(j)] Any parts of the closed vent system that are designated, as described in 40 CFR Section a(l)(2), as difficult to inspect are exempt from the inspection requirements of 40 CFR Section a(f)(1)(i) and (f)(2) if they comply with the requirements specified in 40 CFR Section a(k)(1) through (3): (1) The Permittee determines that the equipment cannot be inspected without elevating the inspecting personnel more than 2 meters above a support surface; and (2) The process unit within which the closed vent system is located becomes an affected facility through 40 CFR Sections or 60.15, or the Permittee designates less than 3.0 percent of the total number of closed vent system equipment as difficult to inspect; and (3) The Permittee has a written plan that requires inspection of the equipment at least once every 5 years. A closed vent system is exempt from inspection if it is operated under a vacuum. [40 CFR a(k)] The Permittee shall record the information specified below: (1) Identification of all parts of the closed vent system that are designated as unsafe to inspect, an explanation of why the

56 Permit Expires: [month day, year] Page 54 of 243 equipment is unsafe to inspect, and the plan for inspection. (2) Identification of all parts of the closed vent system that are designated as difficult to inspect, an explanation of why the equipment is difficult to inspect, and the plan for inspection. (3) For each inspection during which a leak is detected, a record of the information specified in 40 CFR Section a(c). (4) For each inspection during which no leaks are detected, a record of the inspection, the inspection date, and a statement that no leaks were detected. (5) For each visual inspection conducted in accordance with 40 CFR Section a(f)(1)(ii) during which no leaks are detected, a record of the inspection, the inspection date, and a statement that no leaks were detected. [40 CFR a(l)] Closed vent systems and control devices used to comply with provisions of 40 CFR pt. 60, subp. VVa shall be operated at all times when emissions may be vented to them. [40 CFR a(m)] The Permittee shall initially monitor all connectors in the process unit for leaks by the later of either 12 months after the compliance date or 12 months after initial startup. If all connectors in the process unit have been monitored for leaks prior to the compliance date, no initial monitoring is required provided either no process changes have been made since the monitoring or the Permittee can determine that the results of the monitoring, with or without adjustments, reliably demonstrate compliance despite process changes. If required to monitor because of a process change, the Permittee is required to monitor only those connectors involved in the process change. [40 CFR a(a)] Except as allowed in 40 CFR Section a(c), Section a, or as specified in 40 CFR Section a(e), the Permittee shall monitor all connectors in gas and vapor and light liquid service as specified in 40 CFR Section a(a) and (b)(3). (1) The connectors shall be monitored to detect leaks by the method specified in 40 CFR Section a(b) and, as applicable, 40 CFR Section a(c). (2) If an instrument reading greater than or equal to 500 ppm is measured, a leak is detected. (3)The Permittee shall perform monitoring, subsequent to the initial monitoring required in 40 CFR Section a(a), as specified in 40 CFR Section a(b)(3)(i) through (iii), and shall comply with the requirements of 40 CFR Section a(b)(3)(iv) and (v). The required period in which monitoring must be conducted shall be determined from 40 CFR Section a(b)(3)(i) through (iii) using the monitoring results from the preceding monitoring period. The percent leaking connectors shall be calculated as specified in

57 Permit Expires: [month day, year] Page 55 of CFR Section a(c). (i) If the percent leaking connectors in the process unit was greater than or equal to 0.5 percent, then monitor within 12 months (1 year). (ii) If the percent leaking connectors in the process unit was greater than or equal to 0.25 percent but less than 0.5 percent, then monitor within 4 years. The Permittee may comply with the requirements of this paragraph by monitoring at least 40 percent of the connectors within 2 years of the start of the monitoring period, provided all connectors have been monitored by the end of the 4 year monitoring period. (iii) If the percent leaking connectors in the process unit was less than 0.25 percent, then monitor as provided in 40 CFR Section a(b)(3)(iii)(A) and either 40 CFR Section a(b)(3)(iii)(B) or a(b)(3)(iii)(C), as appropriate. (A) The Permittee shall monitor at least 50 percent of the connectors within 4 years of the start of the monitoring period. (B) If the percent of leaking connectors calculated from the monitoring results in 40 CFR Section a(b)(3)(iii)(A) is greater than or equal to 0.35 percent of the monitored connectors, the Permittee shall monitor as soon as practical, but within the next 6 months, all connectors that have not yet been monitored during the monitoring period. At the conclusion of monitoring, a new monitoring period shall be started pursuant to 40 CFR Section a(b)(3), based on the percent of leaking connectors within the total monitored connectors. (C) If the percent of leaking connectors calculated from the monitoring results in 40 CFR Section a(b)(3)(iii)(A) is less than 0.35 percent of the monitored connectors, the Permittee shall monitor all connectors that have not yet been monitored within 8 years of the start of the monitoring period. (iv) If, during the monitoring conducted pursuant to 40 CFR Section a(b)(3)(i) through (iii), a connector is found to be leaking, it shall be re monitored once within 90 days after repair to confirm that it is not leaking. (v) The Permittee shall keep a record of the start date and end date of each monitoring period under this section for each process unit. [40 CFR a(b)] For use in determining the monitoring frequency, as specified in 40 CFR Section a(a) and (b)(3), the percent leaking connectors as used in 40 CFR Section a(a) and (b)(3) shall be calculated by using the following equation: %CL= CL/ Ct* 100 Where: %CL= Percent of leaking connectors as determined through periodic monitoring required in 40 CFR Section a(a)

58 Permit Expires: [month day, year] Page 56 of 243 and (b)(3)(i) through (iii). CL= Number of connectors measured at 500 ppm or greater, by the method specified in 40 CFR Section a(b). Ct= Total number of monitored connectors in the process unit or affected facility. [40 CFR a(c)] When a leak is detected pursuant to 40 CFR Section a(a) and (b), it shall be repaired as soon as practicable, but not later than 15 calendar days after it is detected, except as provided in 40 CFR Section a. A first attempt at repair as defined in 40 CFR pt. 60, subp. VVa shall be made no later than 5 calendar days after the leak is detected. [40 CFR a(d)] Any connector that is designated, as described in 40 CFR Section a(f)(1), as an unsafe to monitor connector is exempt from the requirements of 40 CFR Section a(a) and (b)(3)(i) through (iii) if: (1) The Permittee of the connector demonstrates that the connector is unsafe to monitor because monitoring personnel would be exposed to an immediate danger as a consequence of complying with 40 CFR Section a(a) and (b); and (2) The Permittee of the connector has a written plan that requires monitoring of the connector as frequently as practicable during safe to monitor times but not more frequently than the periodic monitoring schedule otherwise applicable, and repair of the equipment according to the procedures in 40 CFR Section a(d) if a leak is detected. [40 CFR a(e)] Inaccessible, ceramic, or ceramic lined connectors. (1) Any connector that is inaccessible or that is ceramic or ceramic lined (e.g., porcelain, glass, or glass lined), is exempt from the monitoring requirements of 40 CFR Section a(a) and (b), from the leak repair requirements of 40 CFR Section a(d), and from the recordkeeping and reporting requirements of 40 CFR Sections and An inaccessible connector is one that meets any of the provisions specified in 40 CFR Section a(f)(1)(i) through (vi), as applicable. (2) If any inaccessible, ceramic, or ceramic lined connector is observed by visual, audible, olfactory, or other means to be leaking, the visual, audible, olfactory or other indications of a leak to the atmosphere shall be eliminated as soon as practical. [40 CFR a(f)] Except for instrumentation systems and inaccessible, ceramic, or ceramic lined connectors meeting the provisions of 40 CFR Section a(f), identify the connectors subject to the requirements of 40 CFR pt. 60, subp. VVa. Connectors need not be individually identified if all connectors in a designated area or length of pipe subject to the provisions of 40 CFR pt. 60, subp. VVa are identified as a group, and the number of

59 Permit Expires: [month day, year] Page 57 of 243 connectors subject is indicated. [40 CFR a(g)] The Permittee may elect to comply with an allowable percentage of valves leaking of equal to or less than 2.0 percent. [40 CFR a(a)] The following requirements shall be met the Permittee wishes to comply with an allowable percentage of valves leaking: (1) The Permittee must notify the Commissioner that the Permittee has elected to comply with the allowable percentage of valves leaking before implementing this alternative standard, as specified in 40 CFR Section a(d). (2) A performance test as specified in 40 CFR Section a(c) shall be conducted initially upon designation, annually, and at other times requested by the Commissioner. (3) If a valve leak is detected, it shall be repaired in accordance with 40 CFR Section a(d) and (e). [40 CFR a(b)] The Permittee shall conduct performance tests in the following manner: (1) All valves in gas/vapor and light liquid service within the affected facility shall be monitored within 1 week by methods specified in 40 CFR Section a(b). (2) If an instrument reading of 500 ppm or greater is measured, a leak is detected. (3) The leak percentage shall be determined by dividing the number of valves for which leaks are detected by the number of valves in gas/vapor and light liquid service within the affected facility. [40 CFR a(c)] If the Permittee elects to comply with this alternative standard, the Permittee shall not have an affected facility with a leak percentage greater than 2.0 percent determined as described in 40 CFR Section a(h). [40 CFR a(d)] (1) The Permittee may elect to comply with one of the alternative work practices specified in 40 CFR Section a(b)(2) and (3). (2) The Permittee must notify the Commissioner before implementing one of the alternative work practices, as specified in 40 CFR Section a(d). [40 CFR a(a)] ) The Permittee shall comply initially with the requirements for valves in gas/vapor service and valves in light liquid service, as described in 40 CFR Section a. (2) After 2 consecutive quarterly leak detection periods with percent of valves leaking equal to or less than 2.0, the Permittee may begin to skip 1 of the quarterly leak detection periods for the valves in gas/vapor and light liquid service. (3) After 5 consecutive quarterly leak detection periods with the percent of leaking equal to or less than 2.0, the Permittee may begin to skip 3 of the quarterly leak detection periods for the valves in gas/vapor and light liquid service. (4) If the percent of valves leaking is greater than 2.0, the

60 Permit Expires: [month day, year] Page 58 of 243 Permittee shall comply with the requirements of 40 CFR Section a but can again elect to use this section. (5) The percent of valves leaking shall be determined as described in 40 CFR Section a(h). (6) The Permittee must keep a record of the percent of valves found leaking during each leak detection period. [40 CFR a(b)] The Permittee may apply to the Administrator for determination of equivalence for any means of emission limitation that achieves a reduction in emissions of VOC at least equivalent to the reduction in emissions of VOC achieved by the controls required in 40 CFR pt. 60, subp. VVa. [40 CFR a(a)] Determination of equivalence to the equipment, design, and operational requirements of 40 CFR pt. 60, subp. VVa will be evaluated by the guidelines in 40 CFR Section a(b)(1) through (3). [40 CFR a(b)] Determination of equivalence to the required work practices in 40 CFR pt. 60, subp. VVa will be evaluated by the guidelines in 40 CFR Section a(c)(1) through (6). [40 CFR a(c)] The Permittee shall determine compliance with the standards in 40 CFR Sections a through a, a, and a by: (1) Using Method 21 to determine the presence of leaking sources. The instrument shall be calibrated before use each day of its use by the procedures specified in Method 21 of 40 CFR pt. 60, appendix A 7. The following calibration gases shall be used: (i) Zero air (less than 10 ppm of hydrocarbon in air); and (ii) A mixture of methane or n hexane and air at a concentration no more than 2,000 ppm greater than the leak definition concentration of the equipment monitored. If the monitoring instrument's design allows for multiple calibration scales, then the lower scale shall be calibrated with a calibration gas that is no higher than 2,000 ppm above the concentration specified as a leak, and the highest scale shall be calibrated with a calibration gas that is approximately equal to 10,000 ppm. If only one scale on an instrument will be used during monitoring, the Permittee need not calibrate the scales that will not be used during that day's monitoring. (2) A calibration drift assessment shall be performed, at a minimum, at the end of each monitoring day. Check the instrument using the same calibration gas(as) that were used to calibrate the instrument before use. Follow the procedures specified in Method 21 of 40 CFR pt. 60, appendix A 7, Section 10.1, except do not adjust the meter readout to correspond to the calibration gas value. Record the instrument reading for each scale used as specified in 40 CFR Section a(e)(7). Calculate the average algebraic difference between the three

61 Permit Expires: [month day, year] Page 59 of 243 meter readings and the most recent calibration value. Divide this algebraic calibration difference by the initial calibration value and multiply by 1 to express the calibration drift as a percentage. If any calibration drift assessment shows a negative drift of more than 10 percent from the initial calibration value, then all equipment monitored since the last calibration with instrument readings below the appropriate leak definition and above the leak definition multiplied by (100 minus the percent of negative drift/divided by 100) must be re monitored. If any calibration drift assessment shows a positive drift of more than 10 percent from the initial calibration value, then, at the Permittee's discretion, all equipment since the last calibration with instrument readings above the appropriate leak definition and below the leak definition multiplied by (10 plus the percent of positive drift/divided by 100) may be re monitored. [40 CFR a(b)] The Permittee shall conduct performance tests required in 40 CFR Section 60.8 using as reference methods and procedures the test methods in 40 CFR pt. 60, appendix A or other methods and procedures as specified in 40 CFR pt. 60, subp. VVa, except as provided in 40 CFR Section 60.8(b). [40 CFR a(a)] The Permittee shall determine compliance with the nodetectable emissions standards in 40 CFR Section aâ, a(i), a, a(f), and a(e) as follows: (1) The requirements of 40 CFR Section a(b) shall apply. (2) Method 21 of 40 CFR pt. 60, appendix A 7 shall be used to determine the background level. All potential leak interfaces shall be traversed as close to the interface as possible. The arithmetic difference between the maximum concentration indicated by the instrument and the background level is compared with 500 ppm for determining compliance. [40 CFR a(c)] (d) The Permittee shall test each piece of equipment unless the Permittee demonstrates that a process unit is not in VOC service, i.e., that the VOC content would never be reasonably expected to exceed 10 percent by weight. For purposes of this demonstration, the following methods and procedures shall be used: (1) Procedures that conform to the general methods in ASTM E260 73, 91, or 96, E168 67, 77, or 92, E169 63, 77, or 93 (incorporated by reference see  60.17) shall be used to determine the percent VOC content in the process fluid that is contained in or contacts a piece of equipment. (2) Organic compounds that are considered by the Administrator to have negligible photochemical reactivity may be excluded from the total quantity of organic compounds in

62 Permit Expires: [month day, year] Page 60 of 243 determining the VOC content of the process fluid. (3) Engineering judgment may be used to estimate the VOC content, if a piece of equipment had not been shown previously to be in service. If the Administrator disagrees with the judgment, 40 CFR Section a(d)(1) and (2) of this section shall be used to resolve the disagreement. [40 CFR a(d)] (e) The Permittee shall demonstrate that a piece of equipment is in light liquid service by showing that all the following conditions apply: (1) The vapor pressure of one or more of the organic components is greater than 0.3 kpa at 20  C (1.2 in. H2O at 68  F). Standard reference texts or ASTM D , 96, or 97 (incorporated by reference see  60.17) shall be used to determine the vapor pressures. (2) The total concentration of the pure organic components having a vapor pressure greater than 0.3 kpa at 20  C (1.2 in. H2O at 68  F) is equal to or greater than 20 percent by weight. (3) The fluid is a liquid at operating conditions. [40 CFR a(e)] (f) Samples used in conjunction with paragraphs (d), (e), and (g) of this section shall be representative of the process fluid that is contained in or contacts the equipment or the gas being combusted in the flare. [40 CFR a(f)] (g) The owner or operator shall determine compliance with the standards of flares as follows: (1) Method 22 of appendix A 7 of this part shall be used to determine visible emissions. (2) A thermocouple or any other equivalent device shall be used to monitor the presence of a pilot flame in the flare. (3) The maximum permitted velocity for air assisted flares shall be computed using the equation in Appendix [X] of this permit. [40 CFR a(g)] When each leak is detected, the following requirements apply: (1) A weatherproof and readily visible identification, marked with the equipment identification number, shall be attached to the leaking equipment. (2) The identification on a valve may be removed after it has been monitored for 2 successive months as specified in 40 CFR Section a(c) and no leak has been detected during those 2 months. (3) The identification on a connector may be removed after it has been monitored as specified in 40 CFR Section a(b)(3)(iv) and no leak has been detected during that monitoring. (4) The identification on equipment, except on a valve or connector, may be removed after it has been repaired. [40 CFR a(b)]

63 Permit Expires: [month day, year] Page 61 of When each leak is detected the following information shall be recorded in a log and shall be kept for 2 years in a readily accessible location: (1) The instrument and operator identification numbers and the equipment identification number. (2) The date the leak was detected and the dates of each attempt to repair the leak. (3) Repair methods applied in each attempt to repair the leak. (4) Maximum instrument reading measured by Method 21 of appendix A 7 of 40 CFR pt. 60 at the time the leak is successfully repaired or determined to be nonrepairable, except when a pump is repaired by eliminating indications of liquids dripping. (5) Repair delayed and the reason for the delay if a leak is not repaired within 15 calendar days after discovery of the leak. (6) The signature of the Permittee whose decision it was that the repair could not be affected without a process shutdown. (7) The expected date of successful repair of the leak if a leak is not repaired within 15 days. (8) Dates of process unit shutdown that occur while the equipment is unrepaired. (9) The date of successful repair of the leak. [40 CFR a(c)] The information pertaining to the design requirements for closed vent systems and required control devices described in 40 CFR Section a shall be recorded and kept in a readily accessible location: (1) Detailed schematics, design specifications, and piping and instrumentation diagrams. (2) The dates and descriptions of any changes in the design specifications. (3) A description of the parameter(s) monitored per 40 CFR Section a(e), to ensure that control devices are operated and maintained in conformance with their design and an explanation of why that parameter(s) was selected. (4) Periods when the closed vent systems and required control devices are not operated as designed, including periods when a flare pilot light does not have a flame. (5) Dates of startups and shutdowns of the closed vent systems and required control devices. [40 CFR a(d)] Information pertaining to all equipment subject to the requirements in 40 CFR Section a to a shall be recorded in a log that is kept in a readily accessible location and contain the information specified in 40 CFR Section 486a(e)(1) through (10). [40 CFR a(e)] The following information pertaining to all valves subject to the requirements of 40 CFR Section a(g) and (h), all pumps subject to the requirements of 40 CFR Section a(g), and all connectors subject to the requirements of 40 CFR

64 Permit Expires: [month day, year] Page 62 of 243 Section a(e) shall be recorded in a log that is kept in a readily accessible location: (1) A list of identification numbers for valves, pumps, and connectors that are designated as unsafe to monitor, an explanation for each valve, pump, or connector stating why the valve, pump, or connector is unsafe to monitor, and the plan for monitoring each valve, pump, or connector. (2) A list of identification numbers for valves that are designated as difficult to monitor, an explanation for each valve stating why the valve is difficult to monitor, and the schedule for monitoring each valve. [40 CFR a(f)] The following information shall be recorded for valves complying with 40 CFR Section a: (1) A schedule of monitoring. (2) The percent of valves found leaking during each monitoring period. [40 CFR a(g)] The following information shall be recorded in a log that is kept in a readily accessible location: (1) Design criterion required in 40 CFR Sections a(d)(5) and a(e)(2) and explanation of the design criterion; and (2) Any changes to this criterion and the reasons for the changes. [40 CFR a(h)] The following information shall be recorded in a log that is kept in a readily accessible location for use in determining exemptions as provided in 40 CFR Section a(d): (1) An analysis demonstrating the design capacity of the affected facility, (2) A statement listing the feed or raw materials and products from the affected facilities and an analysis demonstrating whether these chemicals are heavy liquids or beverage alcohol, and (3) An analysis demonstrating that equipment is not in VOC service. [40 CFR a(i)] Information and data used to demonstrate that a piece of equipment is not in VOC service shall be recorded in a log that is kept in a readily accessible location. [40 CFR a(j)] The provisions of 40 CFR Section 60.7(b) and (d) do not apply to affected facilities subject to 40 CFR pt. 60, subp. VVa. [40 CFR a(k)] The initial semiannual report to the Commissioner shall include the following information: (1) Process unit identification, (2) Number of valves subject to the requirements of 40 CFR Section a, (3) Number of pumps subject to the requirements of 40 CFR Section a, (4) Number of compressors subject to the requirements of 40 CFR Section a,

65 Permit Expires: [month day, year] Page 63 of 243 (5) Number of connectors subject to the requirements of 40 CFR Section a. [40 CFR a(b)] All semiannual reports to the Commissioner shall include the following information, summarized from the information in 40 CFR Section a; (1) Process unit identification. (2) For each month during the semiannual reporting period, (i) Number of valves for which leaks were detected as described in 40 CFR Section (7a)(b) or 40 CFR a (ii) Number of valves for which leaks were not repaired as required in 40 CFR Section a(d)(1), (iii) Number of pumps for which leaks were detected as described in 40 CFR Section a(b), (d)(4)(ii)(a) or (B), or (d)(5)(iii), (iv) Number of pumps for which leaks were not repaired as required in 40 CFR Section a(c)(1) and (d)(6), (v) Number of compressors for which leaks were detected as described in 40 CFR Section a(f), (vi) Number of compressors for which leaks were not repaired as required in 40 CFR Section a(g)(1), (vii) Number of connectors for which leaks were detected as described in 40 CFR Section a(b), and (viii) Number of connectors for which leaks were not repaired as required in 40 CFR Section a(d). (3) Dates of process unit shutdowns which occurred within the semiannual reporting period. and (4) Revisions to items reported according to 40 CFR Section a(b) if changes have occurred since the initial report or subsequent revisions to the initial report. [40 CFR a(c)] Notification: If the Permittee elects to comply with the provisions of 40 CFR Sections a or a, the Permittee shall notify the Administrator of the alternative standard selected 90 days before implementing either of the provisions. [40 CFR a(d)] Report the results of all performance tests in accordance with 40 CFR Section The provisions of 40 CFR Section 60.8(d) do not apply to affected facilities subject to the provisions of 40 CFR pt. 60, subp. VVa except that the Permittee must notify the Commissioner of the schedule for the initial performance tests at least 30 days before the initial performance tests. [40 CFR a(e)] EQUI 4 EU018 Boiler #1 East Plant Boiler Total Particulate Matter <= pounds per million Btu heat input at 1020 Btu/scf of natural gas. [Title I Condition: 40 CFR 52.21(j)(BACT) & Minn. R ] PM < 10 micron <= pounds per million Btu heat input at 1020 Btu/scf of natural gas. [Title I Condition: 40 CFR 52.21(j)(BACT) & Minn. R , Title I Condition: 40 CFR 52.21(k)(1)(i) & Minn. R ] PM < 2.5 micron <= pounds per million Btu heat input

66 Permit Expires: [month day, year] Page 64 of 243 at 1020 Btu/scf of natural gas. [Title I Condition: Avoid major source under 40 CFR 52.21(b)(1)(i) & Minn. R ] Nitrogen Oxides <= pounds per million Btu heat input. [CAAA of 1990, Minn. R , subp. 7, Minn. R , subps. 1 2, Minn. Stat , subd. 4a, Minn. Stat , subd. 9, Title I Condition: 40 CFR 52.21(j)(BACT) & Minn. R , Title I Condition: 40 CFR pt. 52] Carbon Monoxide <= pounds per million Btu heat input. [Title I Condition: 40 CFR 52.21(j)(BACT) & Minn. R , Title I Condition: Avoid major source under 40 CFR 52.21(b)(1)(i) & Minn. R ] Volatile Organic Compounds <= pounds per million Btu heat input at 1020 Btu/scf of natural gas. [Title I Condition: 40 CFR 52.21(j)(BACT) & Minn. R ] The Permittee shall use good combustion practices (GCP) to control EQUI 4 PM, PM10, CO, and VOC emissions. GCP includes the proper design and maintenance of equipment, good housekeeping, and good operating practices. The Permittee shall follow manufacturer's recommendations, industry best practices, air flow and quality monitoring, periodic testing and analysis and fuel scrubbing and testing, among other work practices, to optimize operation of the equipment. [Title I Condition: 40 CFR 52.21(j)(BACT) & Minn. R ] Permitted Fuel: Natural gas only. [Minn. R , subp. 2, Minn. Stat , subd. 4a] Recordkeeping: By the 15th of the month, record and maintain records of the amounts of natural gas combusted on a monthly basis for the previous calendar month. These records may consist of fuel meter readings or fuel bills/purchase receipts. [40 CFR 60.48c(g), Minn. R ] EQUI 5 EU032 Ethanol Loadout #1 East Plant (Trucks) Loading Unloading Equipment Ethanol Loadout: Loadout from EQUI 5 East Plant Ethanol Loadout is restricted to denatured or undenatured ethanol loaded into tanker trucks by submerged fill with vapor collection vented to TREA 16. [Minn. R , subp. 2] The Permittee shall vent EQUI 5 emissions to TREA 16 when EQUI 5 is operating, and operate and maintain TREA 16 at all times that EQUI 5 is in operation. [CAAA of 1990, Minn. R , subp. 7, Minn. R , subp. 16(J), Minn. R , subps. 1 2, Minn. Stat , subd. 4a, Minn. Stat , subd. 9, Title I Condition: 40 CFR 52.21(j)(BACT) and Minn. R , Title I Condition: 40 CFR pt. 52]

67 Permit Expires: [month day, year] Page 65 of Refer to TREA 16 for additional EQUI 5 requirements. [Minn. R , subp. 2] EQUI 6 EU034 Boiler #2 East Plant Boiler Total Particulate Matter <= pounds per million Btu heat input at 1020 Btu/scf of natural gas. [Title I Condition: 40 CFR 52.21(j)(BACT) & Minn. R ] PM < 10 micron <= pounds per million Btu heat input at 1020 Btu/scf of natural gas. [Title I Condition: 40 CFR 52.21(j)(BACT) & Minn. R ] PM < 2.5 micron <= pounds per million Btu heat input at 1020 Btu/scf of natural gas. [Title I Condition: Avoid major source under 40 CFR 52.21(b)(1)(i) & Minn. R ] Nitrogen Oxides <= pounds per million Btu heat input. [CAAA of 1990, Minn. R , subp. 7, Minn. R , subps. 1 2, Minn. Stat , subd. 4a, Minn. Stat , subd. 9, Title I Condition: 40 CFR 52.21(j)(BACT) & Minn. R , Title I Condition: 40 CFR pt. 52] Carbon Monoxide <= pounds per million Btu heat input. [Title I Condition: 40 CFR 52.21(j)(BACT) & Minn. R ] Volatile Organic Compounds <= pounds per million Btu heat input at 1020 Btu/scf of natural gas. [Title I Condition: 40 CFR 52.21(j)(BACT) & Minn. R ] The Permittee shall use good combustion practices to control EQUI 6 PM, PM10, CO, NOx, and VOC emissions. [Title I Condition: 40 CFR 52.21(j)(BACT) & Minn. R ] Permitted Fuel: Natural gas only. [Minn. R , subp. 2, Minn. Stat , subd. 4a] Recordkeeping: By the 15th of the month, record and maintain records of the amounts of natural gas combusted on a monthly basis for the previous calendar month. These records may consist of fuel meter readings or fuel bills/purchase receipts. [40 CFR 60.48c(g), Minn. R ] EQUI 11 EU048 Corn Dump Pit/Auger #2 Captured Emissions Material Handling Equipment Straight Truck Grain Deliveries: To achieve 80% capture of grain dust from straight truck grain deliveries, the Permittee shall close all doors on the EQUI 11 corn dump pit building when corn is delivered to the facility by straight truck. [Minn. R , subp. 7(A), 7(L), & 7(M), Minn. R , subp. 4, Minn. R , subps. 1 2, Minn. R , Minn. Stat , subd. 4a, Minn. Stat ,

68 Permit Expires: [month day, year] Page 66 of 243 subd. 9, Title I Condition: 40 CFR 52.21(j)(BACT) & Minn. R ] Grain Receiving: Limited each day to the 12 hour period from 6AM to 6PM. [Minn. R , subp. 7(A), 7(L), & 7(M), Minn. R , subp. 4, Minn. R , subps. 1 2, Minn. R , Minn. Stat , subd. 4a, Minn. Stat , subd. 9] Recordkeeping Straight Truck Grain Deliveries: The Permittee shall keep a log of the date and time of each straight truck grain delivery, and whether or not all doors on the dump pit building were closed during grain delivery. The log shall be updated at the time of each delivery. [Minn. R , subp. 7(A), 7(L), & 7(M), Minn. R , subps. 1 2, Minn. R , subps. 4 5, Minn. R , Minn. Stat , subd. 4a, Minn. Stat , subd. 9, Title I Condition: 40 CFR 52.21(j)(BACT) & Minn. R ] Initial Hood Certification and Evaluation: The EQUI 11 control device hood must conform to the requirements listed in Minn. R , subp. 2(B), and the Permittee shall certify this as specified in Minn. R , subps. 2 and 3. The hood certification must address how cross drafts are accommodated in the design (i.e. higher face velocity, oversized hood, etc.). The Permittee shall maintain a copy of the evaluation and certification on site. [Minn. R , subp. 14, Minn. R , subps. 4 5] Annual Hood Evaluation: The Permittee shall measure and record at least once every 12 months the fan rotation speed, fan power draw, face velocity, or other comparable air flow parameter(s) that was measured during the initial hood certification to verify the hood design and operation parameter(s) meet or exceed the parameter(s) measured during the initial hood evaluation conducted according to Minn. R , subps. 2 & 3. The Permittee shall maintain a copy of the annual evaluation on site. [Minn. R , subp. 14, Minn. R , subps. 4 5] EQUI 22 EU071 DDGS Dryer #3 West Plant Dryer/Oven, unknown firing method The dryer shall be fitted with a low NOx burner specified to emit NOx at 0.04 lb/mmbtu or less. [Title I Condition: 40 CFR 52.21(j)(BACT) & Minn. R ] Fuel Burned: Natural gas only. [Minn. R , subp. 2, Minn. Stat , subd. 4a] EQUI 26 EU084 Fire Pump Engine CI 575 hp

69 Permit Expires: [month day, year] Page 67 of 243 (01/2006) Reciprocating IC Engine Volatile Organic Compounds <= 0.12 grams per horsepowerhour. [Title I Condition: 40 CFR 52.21(j)(BACT) & Minn. R ] Nitrogen Oxides <= 4.83 grams per horsepower hour. [Title I Condition: 40 CFR 52.21(j)(BACT) & Minn. R ] Carbon Monoxide <= 0.75 grams per horsepower hour. [Title I Condition: 40 CFR 52.21(j)(BACT) & Minn. R ] PM < 10 micron <= grams per horsepower hour. [Title I Condition: 40 CFR 52.21(j)(BACT) & Minn. R ] PM < 2.5 micron <= grams per horsepower hour. [Title I Condition: 40 CFR 52.21(j)(BACT) & Minn. R ] Total Particulate Matter <= grams per horsepower hour. [Title I Condition: 40 CFR 52.21(j)(BACT) & Minn. R ] The Permittee shall use good combustion practices for the control of EQUI 26 PM, PM10, PM2.5, NOx, CO, and VOC emissions. [Title I Condition: 40 CFR 52.21(j)(BACT) & Minn. R ] Sulfur Dioxide <= 0.50 pounds per million Btu heat input. The PTE of this unit is 0.29 lb/mmbtu. [Minn. R , subp. 2] Opacity <= 20 percent opacity once operating temperatures have been attained. [Minn. R , subp. 1] Best Management Practices for Reciprocating Internal Combustion Engines (RICE) The Permittee must use engine best management practices (BMPs) to minimize the release of pollutants as defined in this permit for all emergency engines, including existing, modified or new emergency engines. [Minn. R , subp. 7(A), 7(L), & 7(M), Minn. R , subps. 1 2, Minn. R , subps. 4 5, Minn. R , Minn. Stat , subd. 4a, Minn. Stat , subd. 9] Best Management Practices for Reciprocating Internal Combustion Engines (RICE) 1. The Permittee shall only use diesel fuel with a sulfur content of less than or equal to 15 ppm or natural gas in the emergency engine. 2. The Permittee may not install a rain cap on any emergency engine stack. 3. The Permittee may install and operate a hinged flapper which is opened by the exhaust flow from the emergency engine stack. There shall be no flow obstruction at the point of discharge that inhibits vertical dispersion. The Permittee shall inspect the hinged flapper (i.e. tip up rain cap) once per calendar month to make sure it is operating per the

70 Permit Expires: [month day, year] Page 68 of 243 manufacturer's specifications and is not impeding the vertical flow of exhaust from the emergency engine stack. The Permittee shall keep records of these monthly inspections. 4. The Permittee shall make the test runs for each engine as short as allowed by insurance and building code considerations. 5. The testing for an emergency engine shall not occur while another emergency engine is being tested. 6. No testing shall be conducted on a day the Air Quality Index (AQI) or the forecasted AQI exceeds 90 unless the test cannot be deferred. For testing conducted on a day with the AQI above 90, document the reason it was not possible to defer the test and any actions that were taken to limit emissions during the test with the testing records. [Minn. R , subp. 7(A), 7(L), & 7(M), Minn. R , subps. 1 2, Minn. R , subps. 4 5, Minn. R , Minn. Stat , subd. 4a, Minn. Stat , subd. 9] Air Quality Index (AQI) The AQI and the forecasted AQI can be found at: quality andpollutants/general air quality/air quality index/current airquality index.html. [Minn. R , subp. 2] Conduct routine maintenance as required by 40 CFR pt. 63, subp. ZZZZ. [Minn. R , subp. 2] EQUI 26 is a 575 hp existing compression ignition reciprocating internal combustion engine (RICE) for which construction commenced prior to June 12, 2006 and is located at an area source of hazardous air pollutants (HAPs). [40 CFR (a)(1)(iii), Minn. R ] The Permittee shall comply with the applicable requirements for EQUI 26 under 40 CFR pt. 63, subp. ZZZZ no later than May 3, [40 CFR (a), Minn. R ] Work Practice Standards: The Permittee must: a. Change oil and filter every 500 hours of operation or annually, whichever comes first; however sources have the option to utilize an oil analysis program as described in 40 CFR Section (i) or (j) in order to extend the specified oil change requirement. b. Inspect air cleaner every 1,000 hours of operation or annually, whichever comes first, and replace as necessary; and c. Inspect all hoses and belts every 500 hours of operation or annually, whichever comes first, and replace as necessary. [40 CFR (a), 40 CFR pt. 63, Subp. ZZZZ(Table 2d), Minn. R ] The Permittee shall be in compliance with the emission limitations and operating limitations in pt. 63, subp. ZZZZ that apply to EQUI 26 at all times. [40 CFR (a), Minn. R ]

71 Permit Expires: [month day, year] Page 69 of At all the Permittee must operate and maintain any affected source, including associated air pollution control equipment and monitoring equipment, in a manner consistent with safety and good air pollution control practices for minimizing emissions. The general duty to minimize emissions does not require the Permittee to make any further efforts to reduce emissions if levels required by this standard have been achieved. Determination of whether such operation and maintenance procedures are being used will be based on information available to the Administrator which may include, but is not limited to, monitoring results, review of operation and maintenance procedures, review of operation and maintenance records, and inspection of the source. [40 CFR (b), Minn. R ] The Permittee must operate and maintain EQUI 26 and aftertreatment control device (if any) according to the manufacturer's emission related written instructions, or develop a maintenance plan which must provide to the extent practicable for the maintenance and operation of EQUI 26 in a manner consistent with good air pollution control practice for minimizing emissions. [40 CFR (e)(3), Minn. R ] The Permittee shall install a non resettable hour meter on EQUI 26 if one is not already installed. [40 CFR (f), Minn. R ] The Permittee shall minimize EQUI 26 time spent at idle during startup and minimize EQUI 26 startup time to a period needed for appropriate and safe loading of EQUI 26, not to exceed 30 minutes, after which time the emission standards applicable to all times other than startup in Table 2d in pt. 63, subp. ZZZZ apply. [40 CFR (h), Minn. R ] The Permittee has the option of utilizing an oil analysis program in order to extend the specified oil change requirement in Table 2d to pt. 63, subp. ZZZZ. The oil analysis must be performed at the same frequency specified for changing the oil in Table 2d to subp. ZZZZ. The analysis program must at a minimum analyze the following three 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. If all of these condemning limits are not exceeded, the Permittee is not required to change the oil. If any of the limits are exceeded, the Permittee must change the oil within 2 days of receiving the results of the analysis; if EQUI 26 is not in operation when the results of the analysis are received, the Permittee must change the oil within 2 days or before

72 Permit Expires: [month day, year] Page 70 of 243 commencing operation, whichever is later. The Permittee must keep records of the parameters that are analyzed as part of the program, the results of the analysis, and the oil changes for EQUI 26. The analysis program must be part of the maintenance plan for EQUI 26. [40 CFR (i), Minn. R ] The Permittee must demonstrate continuous compliance with each emission limitation and operating limitation in Table 2d to pt. 63, subp. ZZZZ that applies to EQUI 26 according to methods specified in item 9 in Table 6 to subp. ZZZZ. [40 CFR (a), Minn. R ] The Permittee must also report each instance in which the Permittee did not meet the applicable requirements for EQUI 26 in Table 8 of pt. 63, subp. ZZZZ. [40 CFR (e), Minn. R ] The Permittee must operate EQUI 26 according to the requirements in 40 CFR Section (f) paragraphs (1) through (4). Any operation other than emergency operation, maintenance and testing, and operation in nonemergency situations for 50 hours per year, as described in Section (f)(1) through (4), is prohibited. If the Permittee does not operate EQUI 26 according to the requirements in Section (f)(1) through (4), EQUI 26 will not be considered an emergency engine under pt. 63, subp. ZZZZ and will need to meet all requirements for non emergency engines. [40 CFR (f), Minn. R ] There is no time limit on the use of EQUI 26 in emergency situations. [40 CFR (f)(1), Minn. R ] The Permittee may operate EQUI 26 for any combination of the purposes specified in 40 CFR Section (f)(2)(i) through (iii) for a maximum of 100 hours per calendar year. Any operation for non emergency situations as allowed by 40 CFR Section (f)(3) and (4) counts as part of the 100 hours per calendar year allowed by this 40 CFR Section (f)(2). [40 CFR (f)(2), Minn. R ] The Permittee may operate EQUI 26 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, or the insurance company associated with EQUI 26. The Permittee may petition the Administrator for approval of additional hours to be used for maintenance checks and readiness testing, but a petition is not required if the Permittee maintains records indicating that Federal, State, or local standards require maintenance and testing of emergency RICE beyond 100 hours per calendar year. [40 CFR (f)(2)(i), Minn. R ] ON MAY 1, 2015, THE DISTRICT OF COLUMBIA CIRCUIT COURT VACATED THE PROVISIONS OF 40 CFR SECTION (f)(2) THAT ALLOW OPERATION OF AN EMERGENCY GENERATOR

73 Permit Expires: [month day, year] Page 71 of 243 WITHOUT EMISSIONS CONTROLS FOR UP TO 100 HOURS PER YEAR AS PART OF AN EMERGENCY DEMAND RESPONSE PROGRAM. THIS PROVISION REMAINS VALID AND IN EFFECT UNTIL REVISED BY THE U.S. EPA OR UNTIL MAY 1, 2016 (THE DATE WHICH THE D.C. CIRCUIT COURT'S MANDATE TO VACATE THE PROVISION IS EFFECTIVE), WHICHEVER IS EARLIER. AFTERWARDS, THIS PROVISION IS NO LONGER EFFECTIVE. THE PERMITTEE SHALL NOT OPERATE ACCORDING TO THIS PROVISION IF VACATED OR SHALL OPERATE ACCORDING TO THE PROVISION AS AMENDED BY THE U.S. EPA. Emergency stationary RICE may be operated for emergency demand response for periods in which the Reliability Coordinator under the North American Electric Reliability Corporation 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 [40 CFR (f)(2)(ii), Minn. R ] ON MAY 1, 2015, THE DISTRICT OF COLUMBIA CIRCUIT COURT VACATED THE PROVISIONS OF 40 CFR SECTION (f)(2) THAT ALLOW OPERATION OF AN EMERGENCY GENERATOR WITHOUT EMISSIONS CONTROLS FOR UP TO 100 HOURS PER YEAR AS PART OF AN EMERGENCY DEMAND RESPONSE PROGRAM. THIS PROVISION REMAINS VALID AND IN EFFECT UNTIL REVISED BY THE U.S. EPA OR UNTIL MAY 1, 2016 (THE DATE WHICH THE D.C. CIRCUIT COURT'S MANDATE TO VACATE THE PROVISION IS EFFECTIVE), WHICHEVER IS EARLIER. AFTERWARDS, THIS PROVISION IS NO LONGER EFFECTIVE. THE PERMITTEE SHALL NOT OPERATE ACCORDING TO THIS PROVISION IF VACATED OR SHALL OPERATE ACCORDING TO THE PROVISION AS AMENDED BY THE U.S. EPA. Emergency stationary RICE may be operated for periods where there is a deviation of voltage or frequency of 5 percent or greater below standard voltage or frequency. [40 CFR (f)(2)(iii), Minn. R ] EQUI 26 may be operated for up to 50 hours per calendar year in non emergency situations. The 50 hours of operation in non emergency situations are counted as part of the 100 hours per calendar year for maintenance and testing and emergency demand response provided in 40 CFR Section (f)(2)(i). 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 an electric grid or otherwise supply power as part of a financial arrangement with another entity. [40 CFR (f)(4), Minn. R.

74 Permit Expires: [month day, year] Page 72 of ] The 50 hours per year for non emergency 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 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. (E) The Permittee identifies and records the entity that dispatches the engine and the specific standards or guidelines that are being followed. [40 CFR (f)(4), Minn. R ] The requirement to submit all of the notifications in 40 CFR Sections 63.7(b) and (c), 63.8(e), (f)(4) and (f)(6), 63.9(b) through (e), and (g) and (h) do not apply to EQUI 26 (existing emergency RICE). [40 CFR (a)(5), Minn. R ] If EQUI 26 is operating during an emergency and it is not possible to shut down EQUI 26 in order to perform the management practice requirements on the schedule required in Table 2d of pt. 63, subp. ZZZZ, or if performing the management practice on the required schedule would otherwise pose an unacceptable risk under federal, state, or local law, the management practice can be delayed until the emergency is over or the unacceptable risk under federal, state, or local law has abated. The management practice should be performed as soon as practicable after the emergency has ended or the unacceptable risk under federal, state, or local law has abated. The Permittee must report any failure to perform the management practice on the schedule required and the federal, state or local law under which the risk was deemed unacceptable. [40 CFR pt. 63, subp. ZZZZ(Table 2d)(footnote 2)] The Permittee shall keep the following records: (1) A copy of each notification and report that you submitted to comply with pt. 63, subp. ZZZZ, including all documentation supporting any Initial Notification or Notification of Compliance Status submitted, according to the requirement in 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

75 Permit Expires: [month day, year] Page 73 of 243 as required in 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 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 (a), Minn. R ] The Permittee must keep the records required in Table 6 of pt. 63, subp. ZZZZ to show continuous compliance with each applicable emission or operating limitation. [40 CFR (d), Minn. R ] The Permittee must keep records of the maintenance conducted on EQUI 26 in order to demonstrate that the Permittee operated and maintained EQUI 26 and aftertreatment control device (if any) according to the Permittee's maintenance plan. [40 CFR (e), Minn. R ] If EQUI 26 does not meet the standards applicable to nonemergency engines, the Permittee must keep records of the hours of operation of EQUI 26 that is recorded through the non resettable hour meter. The Permittee must 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 EQUI 26 is used for demand response operation, the Permittee must keep records of the notification of the emergency situation, and the time EQUI 26 was operated as part of demand response. [40 CFR (f), Minn. R ] (a) Records must be in a form suitable and readily available for expeditious review according to Section 63.10(b)(1). EQUI 29 EU093 Corn Dump Pit/Auger #3 Captured Emissions Material Handling (b) As specified in Section 63.10(b)(1), the Permittee must keep each record for 5 years following the date of each occurrence, measurement, maintenance, corrective action, report, or record. (c) The Permittee must keep each record readily accessible in hard copy or electronic form for at least 5 years after the date of each occurrence, measurement, maintenance, corrective action, report, or record, according to Section 63.10(b)(1). [40 CFR , Minn. R ]

76 Permit Expires: [month day, year] Page 74 of 243 Equipment Straight Truck Grain Deliveries: To achieve 80% capture of grain dust from straight truck grain deliveries, the Permittee shall close all doors on the EQUI 29 corn dump pit building when corn is delivered to the facility by straight truck. [Minn. R , subp. 7(A), 7(L), & 7(M), Minn. R , subp. 4, Minn. R , subps. 1 2, Minn. R , Minn. Stat , subd. 4a, Minn. Stat , subd. 9, Title I Condition: 40 CFR 52.21(j)(BACT) & Minn. R ] Grain Receiving: Limited each day to the 12 hour period from 6AM to 6PM. [Minn. R , subp. 7(A), 7(L), & 7(M), Minn. R , subp. 4, Minn. R , subps. 1 2, Minn. R , Minn. Stat , subd. 4a, Minn. Stat , subd. 9] Recordkeeping Straight Truck Grain Deliveries: The Permittee shall keep a log of the date and time of each straight truck grain delivery, and whether or not all doors on the dump pit building were closed during grain delivery. The log shall be updated at the time of each delivery. [Minn. R , subp. 7(A), 7(L), & 7(M), Minn. R , subps. 1 2, Minn. R , subps. 4 5, Minn. R , Minn. Stat , subd. 4a, Minn. Stat , subd. 9, Title I Condition: 40 CFR 52.21(j)(BACT) & Minn. R ] Initial Hood Certification and Evaluation: The EQUI 29 control device hood must conform to the requirements listed in Minn. R , subp. 2(B), and the Permittee shall certify this as specified in Minn. R , subps. 2 and 3. The hood certification must address how cross drafts are accommodated in the design (i.e. higher face velocity, oversized hood, etc.). The Permittee shall maintain a copy of the evaluation and certification on site. [Minn. R , subp. 14, Minn. R , subps. 4 5] Annual Hood Evaluation: The Permittee shall measure and record at least once every 12 months the fan rotation speed, fan power draw, face velocity, or other comparable air flow parameter(s) that was measured during the initial hood certification to verify the hood design and operation parameter(s) meet or exceed the parameter(s) measured during the initial hood evaluation conducted according to Minn. R , subps. 2 & 3. The Permittee shall maintain a copy of the annual evaluation on site. [Minn. R , subp. 14, Minn. R , subps. 4 5] EQUI 51 EU074 Utility Boiler #3 West Plant Boiler Total Particulate Matter <= pounds per million Btu heat input at 1020 Btu/scf of natural gas. [Title I Condition: 40

77 Permit Expires: [month day, year] Page 75 of 243 CFR 52.21(j)(BACT) & Minn. R ] PM < 10 micron <= pounds per million Btu heat input at 1020 Btu/scf of natural gas. [Title I Condition: 40 CFR 52.21(j)(BACT) & Minn. R ] PM < 2.5 micron <= pounds per million Btu heat input at 1020 Btu/scf of natural gas. [Title I Condition: Avoid major source under 40 CFR 52.21(b)(1)(i) & Minn. R ] Nitrogen Oxides <= 0.04 pounds per million Btu heat input. [Title I Condition: 40 CFR 52.21(j)(BACT) & Minn. R ] Carbon Monoxide <= 0.04 pounds per million Btu heat input. [Title I Condition: 40 CFR 52.21(j)(BACT) & Minn. R ] Volatile Organic Compounds <= pounds per million Btu heat input at 1020 Btu/scf of natural gas. [Title I Condition: 40 CFR 52.21(j)(BACT) & Minn. R ] The Permittee shall use good combustion practices to control EQUI 51 PM, PM10, CO, and VOC emissions. [Title I Condition: 40 CFR 52.21(j)(BACT) & Minn. R ] Fuel Burned: Natural gas only. [Minn. R , subp. 2, Minn. Stat , subd. 4a] Recordkeeping: By the 15th of the month, record and maintain records of the amounts of natural gas combusted on a monthly basis for the previous calendar month. These records may consist of fuel meter readings or fuel bills/purchase receipts. [40 CFR 60.48c(g), Minn. R ] Performance Test: due before end of each 12 months to measure EQUI 51 NOx emissions in lb/mmbtu. This test frequency starts on the date of the EQUI 51 NOx performance test that causes the average measured NOx emission rate from the three most recent tests to equal or exceed lb NOx/mmBtu heat input. Testing shall be conducted at intervals not to exceed 12 months between tests when the average of the three most current test results equals or exceeds lb/mmbtu. This 12 month test interval shall revert to 36 months starting on the date of any test that causes the average measured NOx emission rate from the three most recent tests to be less than lb NOx/mmBtu heat input. The Permittee shall generate and maintain records of the three most recent test results and the average of those results, to verify the applicable test interval. All NOx performance tests shall be conducted at worst case conditions as defined at Minn. R , subp. 8, using EPA Reference Method 7E, or other method approved by MPCA in the performance test plan approval. [Minn. R , subp. 1, Title I Condition: 40 CFR 52.21(j)(BACT) & Minn. R ]

78 Permit Expires: [month day, year] Page 76 of 243 EQUI 52 EU075 Utility Boiler #4 West Plant Boiler Total Particulate Matter <= pounds per million Btu heat input at 1020 Btu/scf of natural gas. [Title I Condition: 40 CFR 52.21(j)(BACT) & Minn. R ] PM < 10 micron <= pounds per million Btu heat input at 1020 Btu/scf of natural gas. [Title I Condition: 40 CFR 52.21(j)(BACT) & Minn. R ] PM < 2.5 micron <= pounds per million Btu heat input at 1020 Btu/scf of natural gas. [Title I Condition: Avoid major source under 40 CFR 52.21(b)(1)(i) & Minn. R ] Nitrogen Oxides <= 0.04 pounds per million Btu heat input. [Title I Condition: 40 CFR 52.21(j)(BACT) & Minn. R ] Carbon Monoxide <= 0.04 pounds per million Btu heat input. [Title I Condition: 40 CFR 52.21(j)(BACT) & Minn. R ] Volatile Organic Compounds <= pounds per million Btu heat input at 1020 Btu/scf of natural gas. [Title I Condition: 40 CFR 52.21(j)(BACT) & Minn. R ] The Permittee shall use good combustion practices to control EQUI 52 PM, PM10, CO, and VOC emissions. [Title I Condition: 40 CFR 52.21(j)(BACT) & Minn. R ] Fuel Burned: Natural gas only. [Minn. R , subp. 2, Minn. Stat , subd. 4a] Recordkeeping: By the 15th of the month, record and maintain records of the amounts of natural gas combusted on a monthly basis for the previous calendar month. These records may consist of fuel meter readings or fuel bills/purchase receipts. [40 CFR 60.48c(g), Minn. R ] Performance Test: due before end of each 12 months to measure EQUI 52 NOx emissions in lb/mmbtu. This test frequency starts on the date of the EQUI 52 NOx performance test that causes the average measured NOx emission rate from the three most recent tests to equal or exceed lb NOx/mmBtu heat input. Testing shall be conducted at intervals not to exceed 12 months between tests when the average of the three most current test results equals or exceeds lb/mmbtu. This 12 month test interval shall revert to 36 months starting on the date of any test that causes the average measured NOx emission rate from the three most recent tests to be less than lb NOx/mmBtu heat input. The Permittee shall generate and maintain records of the three most recent test results and the average of those results, to verify the applicable test interval. All NOx performance tests shall be conducted at worst case conditions as defined at Minn. R , subp. 8, using

79 Permit Expires: [month day, year] Page 77 of 243 EPA Reference Method 7E, or other method approved by MPCA in the performance test plan approval. [Minn. R , subp. 1, Title I Condition: 40 CFR 52.21(j)(BACT) & Minn. R ] EQUI 53 EU077 Ethanol Loadout #2 West Plant (Railcar) Loading Unloading Equipment Ethanol Loadout: Loadout from EQUI 53 West Plant Ethanol Loadout is restricted to loadout of denatured and undenatured ethanol to dedicated normal service railcars. [CAAA of 1990, Minn. R , subp. 7, Minn. R , subps. 1 2, Minn. Stat , subd. 4a, Minn. Stat , subd. 9, Title I Condition: 40 CFR 52.21, Title I Condition: 40 CFR pt. 52] Ethanol Loadout: Loadout from EQUI 53 West Plant Ethanol Loadout is restricted to denatured and undenatured ethanol loaded into dedicated normal service railcars by submerged fill with vapor collection vented to TREA 15. [Minn. R , subp. 2, Title I Condition: Avoid major source under 40 CFR 52.21(b)(1)(i) & Minn. R ] The Permittee shall vent EQUI 53 emissions to TREA 15 when EQUI 53 is operating, and operate and maintain TREA 15 at all times that EQUI 53 is in operation. [Minn. R , subp. 16(A), Title I Condition: 40 CFR 52.21(j)(BACT) & Minn. R , Title I Condition: Avoid major source under 40 CFR 52.21(b)(1)(i) & Minn. R ] Refer to TREA 15 for additional EQUI 53 requirements. [Minn. R , subp. 2] EQUI 54 EU081 Wetcake Loadout and Storage West Plant Loading Unloading Equipment Wet Cake Storage Limitation: When wet cake by product is produced, it shall be stored for no longer than 72 hours on site unless the outside temperature is less than 55 degrees (daily maximum). In all cases, the wet cake shall be removed from the facility property as soon as possible. [Minn. R , subp. 2] The Permittee shall record the daily wet cake storage, ambient temperature and duration of wet cake storage. [Minn. R , subp. 2, 5] EQUI 75 TK014/TK 2508 Denatured or

80 Permit Expires: [month day, year] Page 78 of proof Ethanol Tank #4 (2 mmgal) 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. [40 CFR 60.7(a)(4), Minn. R , subp. 1] All requests, reports, applications, submittals, and other communications to the Administrator pursuant to 40 CFR pt. 60 shall be submitted in duplicate to the Region V Office of the U.S. Environmental Protection Agency to the attention of the Region V Director. All information required to be submitted to EPA must also be submitted to the MPCA to which this authority has been delegated (provided, that each specific delegation may except sources from a certain Federal or State reporting requirement). [40 CFR 60.4(a) & (b)] Recordkeeping: The Permittee shall 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. [40 CFR 60.7(b), Minn. R , subp. 1] Recordkeeping: The Permittee shall maintain a file of all measurements, maintenance, reports and records for at least five years. This requirement is more stringent than 40 CFR Section 60.7(f), which specifies two years. [40 CFR 60.7(f), Minn. R , subp. 5(C), Minn. R , subp. 1] No Permittee 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. [40 CFR 60.12, Minn. R ] The Permittee shall equip EQUI 75 with a floating roof, a vapor recovery system, or their equivalents. [Minn. R , subp. 3(C)(1)] The Permittee shall equip the storage vessel with a fixed roof in combination with an internal floating roof meeting the requirements of 40 CFR Section b(a)(1). [40 CFR b(a), Minn. R , C] The internal floating roof shall rest or float on the liquid surface (but not necessarily in complete contact with it) inside a storage vessel that has a fixed roof. The internal floating roof shall be floating on the liquid surface at all times, except during initial fill and during those intervals when the storage vessel is completely emptied or subsequently emptied and refilled. When the roof is resting on the leg supports, the process of filling, emptying, or refilling shall be continuous and shall be accomplished as rapidly as possible. [40 CFR b(a)(1)(i), Minn. R , C]

81 Permit Expires: [month day, year] Page 79 of Each internal floating roof shall be equipped with a closure device between the wall of the storage vessel and the edge of the internal floating roof consisting of two seals mounted one above the other so that each forms a continuous closure that completely covers the space between the wall of the storage vessel and the edge of the internal floating roof. The lower seal may be vapor mounted, but both must be continuous. [40 CFR b(a)(1)(ii)(B), Minn. R , C] The internal floating roof shall rest or float on the liquid surface (but not necessarily in complete contact with it) inside a storage vessel that has a fixed roof. The internal floating roof shall be floating on the liquid surface at all times, except during initial fill and during those intervals when the storage vessel is completely emptied or subsequently emptied and refilled. When the roof is resting on the leg supports, the process of filling, emptying, or refilling shall be continuous and shall be accomplished as rapidly as possible. [40 CFR b(a)(1)(i), Minn. R , C] Each opening in a noncontact internal floating roof except for automatic bleeder vents (vacuum breaker vents) and the rim space vents is to provide a projection below the liquid surface. [40 CFR b(a)(1)(iii), Minn. R , C] Each opening in the internal floating roof except for leg sleeves, automatic bleeder vents, rim space vents, column wells, ladder wells, sample wells, and stub drains is to be equipped with a cover or lid which is to be maintained in a closed position at all times (i.e., no visible gap) except when the device is in actual use. The cover or lid shall be equipped with a gasket. Covers on each access hatch and automatic gauge float well shall be bolted except when they are in use. [40 CFR b(a)(1)(iv), Minn. R , C] Automatic bleeder vents shall be equipped with a gasket and are to be closed at all times when the roof is floating except when the roof is being floated off or is being landed on the roof leg supports. [40 CFR b(a)(1)(v), Minn. R , C] Rim space vents shall be equipped with a gasket and are to be set to open only when the internal floating roof is not floating or at the manufacturer's recommended setting. [40 CFR b(a)(1)(vi), Minn. R , C] Each penetration of the internal floating roof for the purpose of sampling shall be a sample well. The sample well shall have a slit fabric cover that covers at least 90 percent of the opening. [40 CFR b(a)(1)(vii), Minn. R , C] Each penetration of the internal floating roof that allows for passage of a column supporting the fixed roof shall have a flexible fabric sleeve seal or a gasketed sliding cover. [40 CFR b(a)(1)(viii), Minn. R , C] Each penetration of the internal floating roof that allows for

82 Permit Expires: [month day, year] Page 80 of 243 passage of a ladder shall have a gasketed sliding cover. [40 CFR b(a)(1)(ix), Minn. R , C] The Permittee shall visually inspect the internal floating roof, the primary seal, and the secondary seal, prior to filling the storage vessel with Volatile Organic Liquid (VOL). If there are holes, tears, or other openings in the primary seal, the secondary seal, or the seal fabric, or defects in the internal floating roof, or both, the Permittee shall repair the items before filling the storage vessel. [40 CFR b(a)(1), Minn. R , C] The Permittee shall visually inspect the internal floating roof and the primary seal or the secondary seal through manholes and roof hatches on the fixed roof at least once every 12 months after initial fill. If the internal floating roof is not resting on the surface of the VOL inside the storage vessel, or there is liquid accumulated on the roof, or the seal is detached, or there are holes or tears in the seal fabric, the Permittee shall repair the items or empty and remove the storage vessel from service within 45 days. If a failure that is detected during inspections cannot be repaired within 45 days and if the vessel cannot be emptied within 45 days, a 30 day extension may be requested from the Administrator in the inspection report required in 40 CFR Section b(a)(3). Such a request for an extension must document that alternative storage capacity is unavailable and specify a schedule of actions the company will take that will assure that the control equipment will be repaired or the vessel will be emptied as soon as possible. [40 CFR b(a)(3)(ii), Minn. R , C] Visually inspect the internal floating roof, the primary seal, the secondary seal (if one is in service), gaskets, slotted membranes and sleeve seals (if any) each time the storage vessel is emptied and degassed. If the internal floating roof has defects, the primary seal has holes, tears, or other openings in the seal or the seal fabric, or the secondary seal has holes, tears, or other openings in the seal or the seal fabric, or the gaskets no longer close off the liquid surfaces from the atmosphere, or the slotted membrane has more than 10 percent open area, the Permittee shall repair the items as necessary so that none of the conditions contained within this requirement exist before refilling the storage vessel with VOL. In no event shall inspections conducted in accordance with this provision occur at intervals greater than 10 years in the case of vessels conducting the annual visual inspection as specified in 40 CFR Sections b(a)(2) and (a)(3)(ii). [40 CFR b(a)(4), Minn. R , C] Notification: If an inspection is required (under 40 CFR Section b(a)(1) or 40 CFR Section b(a)(3)(i)), the Permittee shall notify the Commissioner in writing at least 30

83 Permit Expires: [month day, year] Page 81 of 243 days prior to the filling or refilling of the storage vessel, to afford the Commissioner the opportunity to have an observer present. If the inspection is not planned and the Permittee could not have known about the inspection 30 days in advance of the refilling the tank, the Permittee shall notify the Commissioner at least 7 days prior to the refilling of the storage vessel. Notification shall be made by telephone immediately followed by written documentation demonstrating why the inspection was unplanned. Alternatively, this notification including the written documentation may be made in writing and sent by express mail so that it is received by the Commissioner at least 7 days prior to refilling. [40 CFR b(a)(5), Minn. R , C] Notification: The Permittee shall furnish the Commissioner with a report describing the internal floating roof and certifying that it meets the specifications of 40 CFR Section b(a)(1) and 40 CFR Section b(a)(1). The report shall be an attachment to the notification of actual date of initial startup required by 40 CFR Section 60.7(a)(3). [40 CFR b(a)(1), Minn. R , C] The Permittee shall keep a record of each inspection performed as required by 40 CFR Section b(a)(1), (a)(2), (a)(3), and (a)(4). Each record shall identify the storage vessel on which the inspection was performed and shall contain the date the vessel was inspected and the observed condition of each component of the control equipment (seals, internal floating roof, and fittings). [40 CFR b(a)(2), Minn. R , C] After each inspection required under 40 CFR Section b(a)(3) that finds holes or tears in the seal or seal fabric, or defects in the internal floating roof, or other control equipment defects listed in 40 CFR Section b(a)(3)(ii), a report shall be furnished to the Commissioner within 30 days of the inspection. The report shall identify the storage vessel and the reason it did not meet the specifications of 40 CFR Section b(a)(1) or 40 CFR Section b(a)(3)(ii), and list each repair made. [40 CFR b(a)(4), Minn. R , C] The Permittee shall keep copies of all records for at least 2 years. The record showing the dimension of the storage vessel and an analysis showing the capacity of the storage vessel will be kept for the life of the source. [40 CFR b(a), Minn. R , C] Recordkeeping: The Permittee shall maintain records showing the volatile organic liquid (VOL) stored, the period of storage, and the maximum true vapor pressure of the VOL during the respective storage period, calculated as described in 40 CFR Section b(e). [40 CFR b(c), Minn. R , C] Recordkeeping: Maintain records showing the dimensions of

84 Permit Expires: [month day, year] Page 82 of 243 EQUI 75 and an analysis showing the capacity of EQUI 75. [40 CFR b(b), Minn. R , C] Available data on the storage temperature may be used to determine the maximum true vapor pressure. For other liquids, the vapor pressure: i) May be obtained from standard reference texts, or ii) Determined by ASTM D , 96, or 97 (incorporated by reference see 40 CFR Section 60.17); or iii) Measured by an appropriate method approved by the Administrator; or iv) Calculated by an appropriate method approved by the Administrator. [40 CFR b(e)(3), Minn. R , C] Except as provided under paragraphs (e) and (f) of 40 CFR Section 60.14, any physical or operational change to an existing facility which results in an increase in the emission rate to the atmosphere of any pollutant to which a standard applies shall be considered a modification within the meaning of section 111 of the Act. Upon modification, an existing facility shall become an affected facility for each pollutant to which a standard applies and for which there is an increase in the emission rate to the atmosphere. [40 CFR 60.14(a), Minn. R ] Emission rate shall be expressed as kg/hr of any pollutant discharged into the atmosphere for which a standard is applicable. The Administrator shall use paragraphs (1) and (2) of 40 CFR Section 60.14(b) to determine the emission rate. [40 CFR 60.14(b), Minn. R ] The addition of an affected facility to a stationary source as an expansion to that source or as a replacement for an existing facility shall not by itself bring within the applicability of 40 CFR pt. 60 any other facility within that source. [40 CFR 60.14(c), Minn. R ] The following shall not, by themselves, be considered modifications under 40 CFR pt. 60: 1) Maintenance, repair and replacement which the Administrator determines to be routine for a source category, subject to the provisions of paragraph (c) of 40 CFR Sections and ) An increase in production rate of an existing facility, if that increase can be accomplished without a capital expenditure on that facility. 3) An increase in the hours of operation. 4) Use of an alternative fuel or raw material if, prior to the date any standard under 40 CFR pt. 60 becomes applicable to that source type, as provided by 40 CFR Section 60.1, the existing facility was designed to accommodate that alternative use. A facility shall be considered to be designed to

85 Permit Expires: [month day, year] Page 83 of 243 accommodate an alternative fuel or raw material if that use could be accomplished under the facility's construction specifications as amended prior to the change. Conversion to coal required for energy considerations, as specified in Section 111(a)(8) of the Act, shall not be considered a modification. 5) The addition or use of any system or device whose primary function is the reduction of air pollutants, except when an emission control system is removed or is replaced by a system which the Administrator determines to be less environmentally beneficial. 6) The relocation or change in ownership of an existing facility. [40 CFR 60.14(e), Minn. R ] 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. [40 CFR 60.7(f), Minn. R , subp. 5(C), Minn. R , subp. 1] If the Permittee is required to submit periodic reports under 40 CFR pt. 60, and there is an established timeline for submission of periodic reports that is consistent with the reporting frequency(ies) specified for such facility, the Permittee may change the dates by which periodic reports under 40 CFR pt. 60 shall be submitted (without changing the frequency of reporting) to be consistent with the schedule by mutual agreement between the Permittee and the State. The allowance in the previous sentence applies in each State beginning 1 year after the affected facility is required to be in compliance with the applicable subpart in 40 CFR pt. 60. Procedures governing the implementation of this provision are specified in paragraph (f) of 40 CFR Section [40 CFR 60.19(d), Minn. R ] If a Permittee supervises one or more stationary sources affected by standards set under 40 CFR pt. 60 and that standards set under pts. 61, 63 or both of this chapter, the Permittee may arrange by mutual agreement between the Permittee and the Administrator (or the State with approved permit program) a common schedule on which periodic reports required by each applicable standard shall be submitted throughout the year. The allowance in the previous sentence applies in each State beginning 1 year after the affected facility is required to be in compliance with the applicable subpart in 40 CFR pt. 60, or 1 year after the stationary source is required to be in compliance with the applicable 40 CFR pt. 61 or 63 of this chapter standard, whichever is latest. Procedures governing the implementation of this provision are specified in paragraph (f) of 40 CFR Section [40 CFR 60.19(e), Minn. R ] Until an adjustment of a time period or postmark deadline has been approved by the Administrator under 40 CFR Section 60.19(f)(2) and (f)(3), the Permittee remains strictly subject to

86 Permit Expires: [month day, year] Page 84 of 243 the requirements of 40 CFR pt. 60. [40 CFR 60.19(f), Minn. R ] EQUI 103 T805/TK012 Denaturant Tank #3; Unleaded Gas (Fixed Roof only; 18 mgal) The Permittee shall equip EQUI 103 with a permanent submerged fill pipe or comply with the requirements of Minn. R , subp. 3(C). [Minn. R , subp. 3(B)] EQUI 107 T801/TK proof Tank #1; Ethanol & Water (Fixed Roof only; mgal) Total Particulate Matter <= 0.30 grains per 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 [Minn. R , subp. 1(A)] Opacity <= 20 percent opacity. [Minn. R , subp. 1(B)] EQUI 132 T 2506/TK008 Corrosion Inhibitor (Fixed Roof only; 2.37 mgal) Total Particulate Matter <= 0.30 grains per 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 [Minn. R , subp. 1(A)] Opacity <= 20 percent opacity. [Minn. R , subp. 1(B)] EQUI 176 EU110 DDGS Dryer B East Plant Multiple Cyclone Other Emission Unit The Permittee shall vent emissions from EQUI 176 to TREA 11 and STRU 9 whenever EQUI 176 operates. [Title I Condition: 40 CFR 52.21(j)(BACT) & Minn. R ] EQUI 177 EU111 DDGS Dryer A East Plant Multiple Cyclone Other Emission

87 Permit Expires: [month day, year] Page 85 of 243 Unit The Permittee shall vent emissions from EQUI 177 to TREA 11 and STRU 9 whenever EQUI 177 operates. [Title I Condition: 40 CFR 52.21(j)(BACT) & Minn. R ] EQUI 178 EU112 DDGS Dryer #3 West Plant Multiple Cyclone Other Emission Unit The Permittee shall vent emissions from EQUI 178 to TREA 29 and STRU 70 whenever EQUI 178 operates. [Title I Condition: 40 CFR 52.21(j)(BACT) & Minn. R ] EQUI 179 EU031 DDGS Cooling Cyclone (CE011) East Plant Total Particulate Matter <= 1.06 pounds per hour. [Title I Condition: 40 CFR 52.21(j)(BACT) & Minn. R ] PM < 10 micron <= 1.06 pounds per hour. [Title I Condition: 40 CFR 52.21(j)(BACT) & Minn. R ] Volatile Organic Compounds <= pounds per ton DDGS produced but not to exceed 3.56 lb VOC/hr (as total mass of VOC). [Title I Condition: 40 CFR 52.21(j)(BACT) & Minn. R ] Total Particulate Matter <= 0.30 grains per 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 [Minn. R , subp. 1(A)] Opacity <= 20 percent opacity. [Minn. R , subp. 1(B)] EQUI 179 Operating Hours Monitoring and Recordkeeping: The Permittee shall monitor EQUI 179 operating hours. By the 15th day of each month, the Permittee shall calculate and record the monthly EQUI 179 operating hours for the previous calendar month, by summing the daily operating hours records from the previous calendar month. [Minn. R , subps. 4 5, Minn. R , Title I Condition: Avoid major source under 40 CFR 63.2] Performance Test: due before end of each 36 months starting 10/17/2012 to measure STRU 88 Particulate Matter emissions in lb/hr, not to exceed 36 months between test dates. The performance test shall be conducted at worst case conditions as defined at Minn. R , subp. 8, using EPA Reference Methods 5 and 202, or other method approved by MPCA in the performance test plan approval. [Minn. R , subp. 1, Title I Condition: 40 CFR 52.21(j)(BACT) & Minn. R ]

88 Permit Expires: [month day, year] Page 86 of Performance Test: due before end of each 36 months starting 10/17/2012 to measure STRU 88 PM10 emissions in lb/hr, not to exceed 36 months between test dates. The performance test shall be conducted at worst case conditions as defined at Minn. R , subp. 8, using EPA Reference Methods 5 and 202, Methods 201A and 202, or other method approved by MPCA in the performance test plan approval. [Minn. R , subp. 1, Title I Condition: 40 CFR 52.21(j)(BACT) & Minn. R ] Performance Test: due before end of each 36 months starting 10/17/2007 to measure STRU 88 VOC emissions on a mass basis in lb/hr, not to exceed 36 months between test dates. The performance test shall be conducted at worst case conditions as defined at Minn. R , subp. 8, using EPA Reference Method 18, 25A, 320, or other method approved by MPCA in the performance test plan approval. [Minn. R , subp. 1, Title I Condition: 40 CFR 52.21(j)(BACT) & Minn. R ] Performance Test: due before end of each 36 months starting 10/17/2007 to measure STRU 88 HAP emissions from EU 031, not to exceed 36 months between test dates. Testing must include all chemicals listed in Appendix D of this permit. The performance test shall be conducted at worst case conditions as defined at Minn. R , subp. 8, using EPA Reference Method 18, 320, or other method approved by MPCA in the performance test plan approval. [Minn. R , Minn. R , subp. 1, Title I Condition: Avoid major source under 40 CFR 63.2] Protocol for Re Setting the Emission Factor Used For Calculating Acetaldehyde, Acrolein, Formaldehyde, and Methanol Emissions: The Permittee shall conduct performance testing under worst case conditions (as defined at Minn. R ) that produce the maximum acetaldehyde, acrolein, formaldehyde, and methanol emissions. US E.P.A. Reference Method 18, 320, or other method approved by MPCA in the performance test plan approval shall be used to measure the emission factor for each of these HAPs as required under subject item EQUI 179 in this permit. The Permittee shall report the test result in lb/hr in the performance test report required by Minn. R , subp. 1. The emission factors used for calculating acetaldehyde, acrolein, formaldehyde, and methanol emissions shall be reset to the 3 hour average emission rate in lb/hr, measured during the most recent MPCA approved acetaldehyde, acrolein, formaldehyde, and methanol emission factor performance test. The new emission factor used for calculating acetaldehyde, acrolein, formaldehyde, and methanol emissions determined

89 Permit Expires: [month day, year] Page 87 of 243 using this Protocol 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. [Minn. R , Title I Condition: Avoid major source under 40 CFR 63.2] The Permittee must apply for and obtain a major permit amendment if the Permittee wishes to deviate from the Protocol for Re setting the Emission Factor Used for Calculating Acetaldehyde, Acrolein, Formaldehyde, and Methanol Emissions established by this permit. [Minn. R , subp. 1] Notwithstanding the Protocol detailed above, the MPCA reserves the right to set operational limits and requirements as allowed under Minn. R If the MPCA sets limits, the new limits shall be implemented upon receipt of the NOC letter that notifies the Permittee of preliminary approval. The limits set according to Minn. R are final upon issuance of a permit amendment incorporating the change. [Minn. R ] EQUI 181 EU001 Corn Dump Pit/Auger East Plant Straight Truck Grain Deliveries: The Permittee shall close all doors on the EQUI 181 corn dump pit building when corn is delivered to the facility by straight truck. [Title I Condition: 40 CFR 52.21(j)(BACT) & Minn. R ] Grain Receiving: Limited each day to the 12 hour period from 6AM to 6PM. [Minn. R , subp. 7(A), 7(L), & 7(M), Minn. R , subp. 4, Minn. R , subps. 1 2, Minn. R , Minn. Stat , subd. 4a, Minn. Stat , subd. 9] Recordkeeping Straight Truck Grain Deliveries: The Permittee shall keep a log of the date and time of each straight truck grain delivery, and whether or not all doors on the dump pit building were closed during grain delivery. The log shall be updated at the time of each delivery. [Minn. R , subps. 4 5, Title I Condition: 40 CFR 52.21(j)(BACT) & Minn. R ] Grain Receiving Recordkeeping: The Permittee shall keep a record of the date and time of each STRU 85 grain delivery. [Minn. R , subps. 4 5] Initial Hood Certification and Evaluation: The Permittee shall conduct the initial hood certification no later than 60 days after issuance of permit No The EQUI 181 control device hood must conform to the requirements listed in Minn. R , subp. 2(B), and the Permittee shall certify this as specified in Minn. R , subps. 2 and 3. The Permittee shall maintain a copy of the evaluation and

90 Permit Expires: [month day, year] Page 88 of 243 certification on site. [Minn. R , subp. 14, Minn. R , subps. 4 5] Annual Hood Evaluation: The Permittee shall measure and record at least once every 12 months the fan rotation speed, fan power draw, or face velocity of each hood, or other comparable air flow indication method. The Permittee shall maintain a copy of the annual evaluation on site. [Minn. R , subp. 14, Minn. R , subps. 4 5] EQUI 193 EU094 Corn Dump Pit/Auger #4 East Plant Straight Truck Grain Deliveries: The Permittee shall close all doors on the EQUI 193 corn dump pit building when corn is delivered to the facility by straight truck. [Title I Condition: 40 CFR 52.21(j)(BACT) & Minn. R ] Grain Receiving: Limited each day to the 12 hour period from 6AM to 6PM. [Minn. R , subp. 7(A), 7(L), & 7(M), Minn. R , subp. 4, Minn. R , subps. 1 2, Minn. R , Minn. Stat , subd. 4a, Minn. Stat , subd. 9] Recordkeeping Straight Truck Grain Deliveries: The Permittee shall keep a log of the date and time of each straight truck grain delivery, and whether or not all doors on the dump pit building were closed during grain delivery. The log shall be updated at the time of each delivery. [Minn. R , subps. 4 5, Title I Condition: 40 CFR 52.21(j)(BACT) & Minn. R ] Grain Receiving Recordkeeping: The Permittee shall keep a record of the date and time of each STRU 85 grain delivery. [Minn. R , subps. 4 5] Initial Hood Certification and Evaluation: The Permittee shall conduct the initial hood certification no later than 60 days after issuance of permit No The EQUI 181 control device hood must conform to the requirements listed in Minn. R , subp. 2(B), and the Permittee shall certify this as specified in Minn. R , subps. 2 and 3. The Permittee shall maintain a copy of the evaluation and certification on site. [Minn. R , subp. 14, Minn. R , subps. 4 5] Annual Hood Evaluation: The Permittee shall measure and record at least once every 12 months the fan rotation speed, fan power draw, or face velocity of each hood, or other comparable air flow indication method. The Permittee shall maintain a copy of the annual evaluation on site. [Minn. R , subp. 14, Minn. R , subps. 4 5] FUGI 9 FS009 West Plant Truck Traffic

91 Permit Expires: [month day, year] Page 89 of The facility shall take reasonable measure to prevent particulate matter from becoming airborne. [Minn. R , subp. 2, Minn. R ] On each day of operation, the Permittee shall visually inspect all paved surfaces to minimize or eliminate fugitive emissions. The facility shall maintain records of this inspection that include the date of the inspection, whether fugitive dust was observed, what corrective actions were taken, when the corrective actions were taken, and whether the corrective actions eliminated the fugitive dust. [Minn. R , subp. 7(A), 7(L), & 7(M), Minn. R , subp. 4, Minn. R , subps. 1 2, Minn. R , Minn. R , Minn. Stat , subd. 4a, Minn. Stat , subd. 9] Anytime fugitive emissions are observed on facility roadways, the Permittee shall immediately eliminate fugitive emissions by sweeping those road segments and/or apply water or a chemical dust suppressant. [Minn. R , subp. 7(A), 7 (L), & 7(M), Minn. R , subp. 4, Minn. R , subps. 1 2, Minn. R , Minn. R , Minn. Stat , subd. 4a, Minn. Stat , subd. 9] The Permittee shall implement and enforce a facility wide speed limit of 15 miles per hour. The Permittee must post the speed limit in a highly visible location near the facility entrance. [Minn. R , subp. 7(A), 7(L), & 7(M), Minn. R , subp. 4, Minn. R , subps. 1 2, Minn. R , Minn. R , Minn. Stat , subd. 4a, Minn. Stat , subd. 9] The Permittee shall follow the procedures below to limit the amount of fugitive dust from vehicle traffic at the facility and add these conditions to the fugitive dust control plan: FUGI 10 FS001 East Plant Truck Traffic 1) Pave the maintenance building parking area. 2) Any unpaved areas are prohibited from parking and traffic during facility operation. Contractor or maintenance vehicles are allowed on unpaved areas only during facility shutdowns or breakdowns. Road cleaning/sweeping shall be conducted immediately following shutdown/breakdown days if visible emissions are present. 3) No parking is allowed along the fire safety road. Cones and barriers shall be placed to prohibit access to this road except in case of an emergency. [Minn. R , subp. 7(A), 7(L), & 7(M), Minn. R , subp. 4, Minn. R , subps. 1 2, Minn. R , Minn. Stat , subd. 4a, Minn. Stat , subd. 9]

92 Permit Expires: [month day, year] Page 90 of The facility shall take reasonable measure to prevent particulate matter from becoming airborne. [Minn. R , subp. 2, Minn. R ] On each day of operation, the Permittee shall visually inspect all paved surfaces to minimize or eliminate fugitive emissions. The facility shall maintain records of this inspection that include the date of the inspection, whether fugitive dust was observed, what corrective actions were taken, when the corrective actions were taken, and whether the corrective actions eliminated the fugitive dust. [Minn. R , subp. 7(A), 7(L), & 7(M), Minn. R , subp. 4, Minn. R , subps. 1 2, Minn. R , Minn. R , Minn. Stat , subd. 4a, Minn. Stat , subd. 9] Anytime fugitive emissions are observed on facility roadways, the Permittee shall immediately eliminate fugitive emissions by sweeping those road segments and/or apply water or a chemical dust suppressant. [Minn. R , subp. 7(A), 7(L), & 7(M), Minn. R , subp. 4, Minn. R , subps. 1 2, Minn. R , Minn. R , Minn. Stat , subd. 4a, Minn. Stat , subd. 9] The Permittee shall implement and enforce a facility wide speed limit of 15 miles per hour. The Permittee must post the speed limit in a highly visible location near the facility entrance. [Minn. R , subp. 7(A), 7(L), & 7(M), Minn. R , subp. 4, Minn. R , subps. 1 2, Minn. R , Minn. R , Minn. Stat , subd. 4a, Minn. Stat , subd. 9] The Permittee shall follow the procedures below to limit the amount of fugitive dust from vehicle traffic at the facility and add these conditions to the fugitive dust control plan: FUGI 11 FS011 East Plant Cooling Tower (3 1) Pave the maintenance building parking area. 2) Any unpaved areas are prohibited from parking and traffic during facility operation. Contractor or maintenance vehicles are allowed on unpaved areas only during facility shutdowns or breakdowns. Road cleaning/sweeping shall be conducted immediately following shutdown/breakdown days if visible emissions are present. 3) No parking is allowed along the fire safety road. Cones and barriers shall be placed to prohibit access to this road except in case of an emergency. [Minn. R , subp. 7(A), 7(L), & 7(M), Minn. R , subp. 4, Minn. R , subps. 1 2, Minn. R , Minn. Stat , subd. 4a, Minn. Stat , subd. 9]

93 Permit Expires: [month day, year] Page 91 of 243 cells) Total Particulate Matter <= 0.30 grains per 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 [Minn. R , subp. 1(A)] Opacity <= 20 percent opacity. [Minn. R , subp. 1(B)] The Permittee shall not operate FUGI 14 and FUGI 11 simultaneously. FUGI 11 shall replace FUGI 14 at the facility upon initial startup of FUGI 11. [Minn. R , subp. 2] FUGI 12 FS012 West Plant Cooling Tower (4 cells) Total Particulate Matter <= 0.30 grains per 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 [Minn. R , subp. 1(A)] Opacity <= 20 percent opacity. [Minn. R , subp. 1(B)] The Permittee shall not operate FUGI 15 and FUGI 12 simultaneously. FUGI 12 shall replace FUGI 15 at the facility upon initial startup of FUGI 12. [Minn. R , subp. 2] FUGI 13 FS002 East Plant Grain & DDGS Uncaptured Emissions Opacity <= 5 percent opacity for fugitive emissions from grain unloading and grain or DDGS handling activities. [Minn. R , subp. 3(A)] 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). [Minn. R , subp. 1(A)] 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 This requirement applies to DDGS handling and loadout. [Minn. R ] FUGI 14 FS005 East Plant Cooling Towers Total Particulate Matter <= 0.30 grains per dry standard cubic foot of exhaust gas unless required to further reduce

94 Permit Expires: [month day, year] Page 92 of 243 emissions to comply with the less stringent limit of either Minn. R or Minn. R [Minn. R , subp. 1(A)] Opacity <= 20 percent opacity. [Minn. R , subp. 1(B)] The Permittee shall not operate FUGI 14 and FUGI 11 simultaneously. FUGI 11 shall replace FUGI 14 at the facility upon initial startup of FUGI 11. [Minn. R , subp. 2] FUGI 15 FS006 West Plant Cooling Towers Total Particulate Matter <= 0.30 grains per 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 [Minn. R , subp. 1(A)] Opacity <= 20 percent opacity. [Minn. R , subp. 1(B)] The Permittee shall not operate FUGI 15 and FUGI 12 simultaneously. FUGI 12 shall replace FUGI 15 at the facility upon initial startup of FUGI 12. [Minn. R , subp. 2] STRU 7 SV024 DDGS Handling Baghouse (CE 035) DDGS Loadout: Limited each day to the 12 hour period from 6AM to 6PM. [Minn. R , subp. 7(A), 7(L), & 7(M), Minn. R , subp. 4, Minn. R , subps. 1 2, Minn. R , Minn. Stat , subd. 4a, Minn. Stat , subd. 9] Total Particulate Matter <= grains per dry standard cubic foot. [Title I Condition: 40 CFR 52.21(j)(BACT) & Minn. R ] Total Particulate Matter <= pounds per hour 3 hour average. [Title I Condition: Avoid major source under 40 CFR 52.21(b)(1)(i) & Minn. R ] PM < 10 micron <= grains per dry standard cubic foot. [Minn. R , subp. 7(A), 7(L), & 7(M), Minn. R , subp. 4, Minn. R , subps. 1 2, Minn. R , Minn. Stat , subd. 4a, Minn. Stat , subd. 9, Title I Condition: 40 CFR 52.21(j) & (k)(bact) & Minn. R ] PM < 10 micron <= pounds per hour 3 hour average. [Title I Condition: 40 CFR 52.21(k)(1)(i) & Minn. R , Title I Condition: Avoid major source under 40 CFR 52.21(b)(1)(i) & Minn. R ] PM < 2.5 micron <= grains per dry standard cubic foot. [Minn. R , subp. 7(A), 7(L), & 7(M), Minn. R , subp. 4, Minn. R , subps. 1 2, Minn. R.

95 Permit Expires: [month day, year] Page 93 of , Minn. Stat , subd. 4a, Minn. Stat , subd. 9, Title I Condition: Avoid major source under 40 CFR 52.21(b)(1)(i) & Minn. R ] PM < 2.5 micron <= pounds per hour 3 hour average. [Minn. R , subp. 7(A), 7(L), & 7(M), Minn. R , subp. 4, Minn. R , subps. 1 2, Minn. R , Minn. Stat , subd. 4a, Minn. Stat , subd. 9, Title I Condition: Avoid major source under 40 CFR 52.21(b)(1)(i) & Minn. R ] Opacity <= 10 percent opacity. This limit applies individually to each emission unit that vents through STRU 7. [Minn. R , subp. 3(D)] The Permittee shall operate and maintain the control equipment such that it achieves a collection efficiency for Total Particulate Matter >= 80 percent collection efficiency. [Minn. R , subp. 3(E)] The Permittee shall prevent the escape of particulate emissions by installing flexible deflectors on each side of the West Plant DDGS rail loadout doors. [Minn. R , subp. 7(A), 7(L), & 7(M), Minn. R , subp. 4, Minn. R , subps. 1 2, Minn. R , Minn. Stat , subd. 4a, Minn. Stat , subd. 9] Process Throughput <= 220 tons per hour 8 hour block average for EQUI 24 and EQUI 25, unless a new limit is set pursuant to Minn. R , subp. 3 based on the throughput recorded during the most recent MPCA approved performance test where compliance was demonstrated. The new limit shall be implemented upon receipt of the NOC letter (or equivalent MPCA correspondence) granting preliminary approval. The limit is final upon issuance of a permit amendment incorporating the change. This operating parameter must remain in the permit to define the maximum capacity of the process on an hourly basis. [Minn. R , subp. 3] Process Throughput <= 101 trucks per day for DDGS trucks at STRU 7. [Minn. R , subp. 7(A), 7(L), & 7(M), Minn. R , subp. 4, Minn. R , subps. 1 2, Minn. R , Minn. Stat , subd. 4a, Minn. Stat , subd. 9, Title I Condition: 40 CFR 52.21(k)(1)(i) & Minn. R ] Recordkeeping of DDGS Trucks: The Permittee shall record the number of DDGS trucks each day at STRU 7. [Minn. R , subp. 7(A), 7(L), & 7(M), Minn. R , subp. 4, Minn. R , subps. 1 2, Minn. R , Minn. Stat , subd. 4a, Minn. Stat , subd. 9, Title I Condition: 40 CFR 52.21(k)(1)(i) & Minn. R ] Vent all emissions from West Plant DDGS Bins #1 and #2 (EQUI 24 and EQUI 25) to fabric filter TREA 14. The Permittee shall document periods of non operation of TREA 14 when DDGS is

96 Permit Expires: [month day, year] Page 94 of 243 handled to or from EQUI 24 and/or EQUI 25. [Title I Condition: 40 CFR 52.21(j)(BACT) & Minn. R ] Daily Recordkeeping: The Permittee shall record each day the hours of loadout for the West Plant DDGS Bins #1 and #2 (EQUI 24 and EQUI 25) and that the hours of loadout are within the 12 hour period specified in this permit. [Minn. R , subps. 4 5] POLLUTION CONTROL REQUIREMENTS Refer to TREA 14 for additional pollution control requirements. [Minn. R , subp. 2] Initial Hood Certification and Evaluation: The control device hood must conform to the requirements listed in Minn. R , subp. 1, and the Permittee shall certify this as specified in Minn. R , subps. 2 and 3. The hood certification must address how cross drafts are accommodated in the design (i.e. higher face velocity, oversized hood, etc.). The Permittee shall maintain a copy of the evaluation and certification on site. [Minn. R , subp. 14, Minn. R , subps. 4 5] Annual Hood Evaluation: The Permittee shall measure and record at least once every 12 months the fan rotation speed, fan power draw, or face velocity of each hood, or other comparable air flow indication method. The Permittee shall maintain a copy of the annual evaluation on site. [Minn. R , subp. 14, Minn. R , subps. 4 5] STRU 9 SV026 VRTO #1 Stack East Plant (CE 036) Total Particulate Matter <= 0.30 grains per 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 individually to EQUI 56 and EQUI 57. [Minn. R , subp. 1(A)(1)] Total Particulate Matter <= 0.30 grains per 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 individually to EQUI 176 and EQUI 177. [Minn. R , subp. 1(A)] Total Particulate Matter <= grains per dry standard cubic foot. [Title I Condition: 40 CFR 52.21(j)(BACT) & Minn. R ] Total Particulate Matter <= pounds per hour 3 hour average. [Title I Condition: 40 CFR 52.21(j)(BACT) & Minn. R ] PM < 10 micron <= grains per dry standard cubic foot. [Title I Condition: 40 CFR 52.21(j)(BACT) & Minn. R ]

97 Permit Expires: [month day, year] Page 95 of PM < 10 micron <= pounds per hour 3 hour average. [Title I Condition: 40 CFR 52.21(j) & (k)(bact) & Minn. R , Title I Condition: Avoid major source under 40 CFR 52.21(b)(1)(i) & Minn. R ] PM < 2.5 micron <= pounds per hour 3 hour average. [Minn. R , subp. 7(A), 7(L), & 7(M), Minn. R , subp. 4, Minn. R , subps. 1 2, Minn. R , Minn. Stat , subd. 4a, Minn. Stat , subd. 9, Title I Condition: Avoid major source under 40 CFR 52.21(b)(1)(i) & Minn. R ] Volatile Organic Compounds <= 4.00 pounds per hour as total mass of VOC. [Title I Condition: 40 CFR 52.21(j)(BACT) & Minn. R ] Nitrogen Oxides <= 9.00 pounds per hour. This limit applies to total NOx (thermal and process NOx). [Title I Condition: 40 CFR 52.21(j)(BACT) & Minn. R ] Nitrogen Oxides <= parts per million by volume, wet gas basis. This limit applies to total NOx (thermal and process NOx). [Title I Condition: 40 CFR 52.21(j)(BACT) & Minn. R ] Nitrogen Oxides <= pounds per million Btu heat input. This limit applies to thermal (combustion) NOx only. [CAAA of 1990, Title I Condition: 40 CFR 52.21(j)(BACT) & Minn. R ] Carbon Monoxide <= pounds per hour 3 hour average. [Title I Condition: 40 CFR 52.21(j)(BACT) & Minn. R ] Sulfur Dioxide <= 3.82 pounds per hour 3 hour average. [Title I Condition: Avoid major modification under 40 CFR 52.21(b)(23)(i) & Minn. R ] Opacity <= 20 percent opacity except for one six minute period per hour of not more than 60 percent opacity. This limit applies individually to EQUI 56 and EQUI 57. [Minn. R , subp. 1(A)(2)] Opacity <= 20 percent opacity. This limit applies individually to EQUI 176 and EQUI 177. [Minn. R , subp. 1(B)] Permitted Fuel: Natural gas only. [Title I Condition: 40 CFR 52.21(j)(BACT) & Minn. R ] POLLUTION CONTROL REQUIREMENTS Refer to TREA 11 for additional pollution control requirements. [Minn. R , subp. 2] Vent all emissions from East Plant Dryer A and Dryer B to TREA 11. The Permittee shall document periods of non operation of TREA 11 during operation of East Plant Dryer A and/or Dryer B. [Title I Condition: 40 CFR 52.21(j)(BACT) & Minn. R , Title I Condition: Avoid major source under 40 CFR 52.21(b)(1)(i) & Minn. R ] STRU 9 Operating Hours Monitoring and Recordkeeping: The Permittee shall monitor STRU 9 operating hours for use in

98 Permit Expires: [month day, year] Page 96 of 243 COMG 4 HAP calculations. An 'STRU 9 operating hour' is any hour during which any process equipment is operating that vents through STRU 9. The Permittee shall monitor and keep separate records for STRU 9 operating hours when TREA 11 combustion chamber temperature is less than the required minimum (listed under TREA 11) during the operating hour. If the Permittee only conducts daily TREA 11 temperature monitoring (and not hourly monitoring as described under TREA 11) and the monitored combustion chamber temperature is below the required minimum, all operating hours during that calendar day are recorded as TREA 11 operating below the required minimum temperature. [Minn. R , subps. 4 5, Minn. R , Title I Condition: Avoid major source under 40 CFR 63.2] Monthly Monitoring and Recordkeeping: By the 15th day of each month, the Permittee shall calculate and record the following for the previous calendar month: 1. Monthly STRU 9 operating hours when TREA 11 was operating at or above the required minimum temperature; and, 2. Monthly STRU 9 operating hours when TREA 11 was operating at less than the required minimum temperature. [Minn. R , subps. 4 5] Performance Test Notifications and Submittals; 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 or CD: due 105 days after each Performance Test. The Notification, Test Plan, and Test Report may be submitted in alternative format as allowed by Minn. R [Minn. R , Minn. R , subps. 1 4, Minn. R , subps. 1 2] Protocol for Re Setting the Emission Factor Used For Calculating Acetaldehyde, Acrolein, Formaldehyde, and Methanol Emissions:

99 Permit Expires: [month day, year] Page 97 of 243 The Permittee shall conduct performance testing under worst case conditions (as defined at Minn. R ) that produce the maximum acetaldehyde, acrolein, formaldehyde, and methanol emissions. US E.P.A. Reference Method 18, 320, or other method approved by MPCA in the performance test plan approval shall be used to measure the emission factor for each of these HAPs as required under subject item STRU 9 in this permit. The Permittee shall report the test result in lb/hr in the performance test report required by Minn. R , subp. 1. The emission factors used for calculating acetaldehyde, acrolein, formaldehyde, and methanol emissions shall be reset to the 3 hour average emission rate in lb/hr, measured during the most recent MPCA approved acetaldehyde, acrolein, formaldehyde, and methanol emission factor performance test. The new emission factor used for calculating acetaldehyde, acrolein, formaldehyde, and methanol emissions determined using this Protocol shall be effective upon receipt of the Notice of Verification (NOV) letter or equivalent MPCA correspondence, that approves the test results and shall be incorporated into the permit during the next permit amendment. [Minn. R , Title I Condition: Avoid major source under 40 CFR 63.2] The Permittee must apply for and obtain a major permit amendment if the Permittee wishes to deviate from the Protocol for Re setting the Emission Factor Used for Calculating Acetaldehyde, Acrolein, Formaldehyde, and Methanol Emissions established by this permit. [Minn. R , subp. 1] Notwithstanding the Protocol detailed above, the MPCA reserves the right to set operational limits and requirements as allowed under Minn. R If the MPCA sets limits, the new limits shall be implemented upon receipt of the NOV letter (or equivalent MPCA correspondence), that notifies the Permittee of preliminary approval. The limits set according to Minn. R are final upon issuance of a permit amendment incorporating the change. [Minn. R ] Thermal Oxidizer Burnouts and Other Maintenance Activities: During thermal oxidizer malfunctions and any other maintenance for which the manufacturer recommends dryer emissions bypass the thermal oxidizer, the dryer shall be shutdown. Wet DDGS shall be stored and handled to minimize VOC emissions and odors during these maintenance activities. The Permittee shall maintain a record of such maintenance activities in the O & M plan for TREA 11. [Minn. R ,

100 Permit Expires: [month day, year] Page 98 of 243 subp. 14, Minn. R , subp. 16(J)] Thermal Oxidizer Breakdown: In the event of a breakdown of the thermal oxidizer, the Permittee shall stop feed into the dryer as soon as the breakdown is discovered. Dryer operation may continue as long as necessary to empty the dryer. The Permittee shall also submit the notification required by Minn. R , subp. 2, if required. [Minn. R , subp. 2] Wet cake storage limitation: When wet cake by product is produced, it will be stored for no longer than 72 hours on site unless the outside temperature is less than 55 degrees (daily maximum). In all cases, the wet cake will be moved off site as soon as possible. [Minn. R , subp. 2] The Permittee shall record the daily wet cake storage, ambient temperature and duration of wet cake storage. [Minn. R , subp. 2, 5] STRU 10 SV027 DDGS Handling Baghouse #2 (CE 037) PM < 10 micron <= pounds per hour 3 hour average. [Title I Condition: 40 CFR 52.21(k)(1)(i) & Minn. R , Title I Condition: Avoid major source under 40 CFR 52.21(b)(1)(i) & Minn. R ] PM < 2.5 micron <= pounds per hour 3 hour average. [Minn. R , subp. 7(A), 7(L), & 7(M), Minn. R , subp. 4, Minn. R , subps. 1 2, Minn. R , Minn. Stat , subd. 4a, Minn. Stat , subd. 9, Title I Condition: Avoid major source under 40 CFR 52.21(b)(1)(i) & Minn. R ] Opacity <= 10 percent opacity. [Minn. R , subp. 3(D)] The Permittee shall operate and maintain the control equipment such that it achieves a collection efficiency for Total Particulate Matter >= 80 percent collection efficiency. [Minn. R , subp. 3(E)] Process Throughput <= 125 tons per hour 8 hour block average for EQUI 163, unless a new limit is set pursuant to Minn. R , subp. 3 based on the throughput recorded during the most recent MPCA approved performance test where compliance was demonstrated. The new limit shall be implemented upon receipt of the NOV letter (or equivalent MPCA correspondence) granting preliminary approval. The limit is final upon issuance of a permit amendment incorporating the change. This operating parameter must remain in the permit to define the maximum capacity of the process on an hourly basis. [Minn. R , subp. 3] Process Throughput <= 57 trucks per day for DDGS trucks at STRU 10. [Minn. R , subp. 7(A), 7(L), & 7(M), Minn.

101 Permit Expires: [month day, year] Page 99 of 243 R , subp. 4, Minn. R , subps. 1 2, Minn. R , Minn. Stat , subd. 4a, Minn. Stat , subd. 9, Title I Condition: 40 CFR 52.21(k)(1)(i) & Minn. R ] Recordkeeping of DDGS Trucks: The Permittee shall record the number of DDGS trucks each day at STRU 10. [Minn. R , subp. 7(A), 7(L), & 7(M), Minn. R , subp. 4, Minn. R , subps. 1 2, Minn. R , Minn. Stat , subd. 4a, Minn. Stat , subd. 9, Title I Condition: 40 CFR 52.21(k)(1)(i) & 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. The Permittee shall comply with all other requirements listed in Minn. R [Minn. R ] The Permittee shall use best management practices for DDGS handling operations. These shall include: 1) Keep DDGS building doors closed to the greatest extent possible; or, 2) Install plastic strip barriers at entrances and exits to the DDGS building. [Minn. R , subp. 2] Vent all emissions from West Plant DDGS Bin #3 (EQUI 163) to fabric filter TREA 12 whenever TREA 12 operates, and operate and maintain TREA 12 at all times that any emissions are vented to TREA 12. The Permittee shall document periods of non operation of TREA 12 when DDGS is handled to or from EQUI 163. [Minn. R , subp. 2] POLLUTION CONTROL REQUIREMENTS Refer to TREA 12 for additional pollution control requirements. [Minn. R , subp. 2] Initial Hood Certification and Evaluation: The control device hood must conform to the requirements listed in Minn. R , subp. 1, and the Permittee shall certify this as specified in Minn. R , subps. 2 and 3. The hood certification must address how cross drafts are accommodated in the design (i.e. higher face velocity, oversized hood, etc.). The Permittee shall maintain a copy of the evaluation and certification on site. [Minn. R , subp. 14, Minn. R , subps. 4 5] Annual Hood Evaluation: The Permittee shall measure and record at least once every 12 months the fan rotation speed, fan power draw, or face velocity of each hood, or other comparable air flow indication method. The Permittee shall maintain a copy of the annual evaluation on site. [Minn. R , subp. 14, Minn. R , subps. 4 5]

102 Permit Expires: [month day, year] Page 100 of 243 STRU 11 SV028 Combustion Turbine with Duct Burner PM < 10 micron <= pounds per hour 3 hour average. [Title I Condition: 40 CFR 52.21(k)(1)(i) & Minn. R , Title I Condition: Avoid major source under 40 CFR 52.21(b)(1)(i) & Minn. R ] PM < 2.5 micron <= pounds per hour 3 hour average. [Minn. R , subp. 7(A), 7(L), & 7(M), Minn. R , subp. 4, Minn. R , subps. 1 2, Minn. R , Minn. Stat , subd. 4a, Minn. Stat , subd. 9, Title I Condition: Avoid major source under 40 CFR 52.21(b)(1)(i) & Minn. R ] Nitrogen Oxides <= 42 parts per million at 15 percent O2 or 290 ng/j of useful output (2.3 lb/mwh) while combusting natural gas. This limit applies to EQUI 164 and EQUI 165. [40 CFR (a), 40 CFR pt. 60, subp. KKKK (Table 1)] Sulfur Dioxide <= pounds per million Btu heat input at 15 percent oxygen. [40 CFR (a)(2)] Sulfur Dioxide <= 0.50 pounds per million Btu 3 hour average. [Minn. R , subp. 2] Opacity <= 20 percent opacity once operating temperatures have been attained. [Minn. R , subp. 1] Permitted Fuel: Natural gas only. [Minn. R , subp. 2] The Permittee must operate and maintain EQUI 164, EQUI 165, air pollution control equipment, and monitoring equipment in a manner consistent with good air pollution control practices for minimizing emissions at all times including during startup, shutdown, and malfunction. [40 CFR (a)] Fuel Sulfur Content: The Permittee shall maintain a current valid purchase contract, tariff sheet or transportation contract for the fuel (natural gas), specifying that the maximum total sulfur content for natural gas is 20 grains of sulfur or less per 100 standard cubic feet. [40 CFR (a)] NOx Performance Test Report: In addition to the other notifications and submittals required by Minn. R. ch. 7017, the Permittee shall submit a written report of the results of each NOx performance test before the close of business on the 60th day following completion of the performance test. [40 CFR (b)] The Permittee shall perform annual performance tests in accordance with 40 CFR Section to demonstrate continuous compliance. If the NOx emission result from the performance test is less than or equal to 75 percent of the NOx emission limit for the turbine, the Permittee may reduce the frequency of subsequent performance tests to once every 2 years (no more than 26 calendar months following the previous performance test). If the results of any subsequent performance test exceed 75 percent of the NOx emission limit

103 Permit Expires: [month day, year] Page 101 of 243 for the turbine, the Permittee must resume annual performance tests. [40 CFR (a)] The Permittee shall conduct an initial performance test, as required in 40 CFR Section Subsequent NOx performance tests shall be conducted on an annual basis (no more than 14 calendar months following the previous performance test) unless the frequency is reduced to every 24 months in accordance with 40 CFR Section (a). [40 CFR (a), Minn. R , subp. 1] For each test run: i) Measure the NOx concentration (in parts per million (ppm)), using EPA Method 7E or Method 20 in 40 CFR pt. 60, Appendix A. For units complying with the output based standard, concurrently measure the stack gas flow rate, using EPA Methods 1 and 2 in 40 CFR pt. 60, Appendix A, and measure and record the electrical and thermal output from the unit. Then use the following equation to calculate the NOx emission rate: E = (1.194 x 10^ 7 * (NOx)c * Qstd) / P where E = NOx emission rate, in lb/mwh x 10^ 7 = conversion constant, in lb/dscf ppm (NOx)c = average NOx concentration for the run, in ppm Qstd = stack gas volumetric flow rate, in dscf/hr P = for combined heat and power operation, the sum of all electrical and mechanical output from the combustion and steam turbines plus all useful recovered thermal output not used for additional electric or mechanical generation, in MW, calculated according to 40 CFR Section (f)(2); or ii) Measure the NOx and diluent gas concentrations, using either EPA Methods 7E and 3A, or Method 20 in 40 CFR pt. 60, Appendix A. Concurrently measure the heat input to the unit, using a fuel flowmeter (or flowmeters), and measure the electrical and thermal output of the unit. Use EPA Method 19 in 40 CFR pt. 60, Appendix A to calculate the NOx emission rate in lb/mmbtu. Then, use Equations 1 and, if necessary, 2 and 3 in 40 CFR Section (f) to calculate the NOx emission rate in lb/mwh. [40 CFR (a)(1)] Sampling traverse points for NOx and (if applicable) diluent gas are to be selected following EPA Method 20 or Method 1 (nonparticulate procedures), and sampled for equal time intervals. The sampling must be performed with a traversing single hole probe, or, if feasible, with a stationary multi hole probe that samples each of the points sequentially. Alternatively, a multihole probe designed and documented to sample equal volumes from each hole may be used to sample

104 Permit Expires: [month day, year] Page 102 of 243 simultaneously at the required points. [40 CFR (a)(2)] The performance test must be done at any load condition within plus or minus 25 percent of 100 percent of peak load. The Permittee may perform testing at the highest achievable load point, if at least 75 percent of peak load cannot be achieved in practice. The Permittee must conduct three separate test runs for each performance test. The minimum time per run is 20 minutes. For a combined cycle and CHP turbine system with supplemental heat (duct burner), the Permittee must measure the total NOx emissions after the duct burner rather than directly after the turbine. The duct burner must be in operation during the performance test. Compliance with the applicable emission limit in 40 CFR Section must be demonstrated at each tested load level. Compliance is achieved if the three run arithmetic average NOx emission rate at each tested level meets the applicable emission limit in 40 CFR Section The ambient temperature must be greater than 0 Â F during the performance test. [40 CFR (b)(2)(4) & (6)] A notification of any physical or operational change to an existing facility which may increase the emission rate of any air pollutant to which a standard applies, unless that change is specifically exempted under an applicable subpart or in 40 CFR Section 60.14(e). This notice shall be postmarked 60 days or as soon as practicable before the change is commenced and shall include information describing the precise nature of the change, present and proposed emission control systems, productive capacity of the facility before and after the change, and the expected completion date of the change. The Administrator may request additional relevant information subsequent to this notice. [40 CFR 60.7(a)(4), Minn. R , subp. 1] 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. [40 CFR 60.7(b), Minn. R , subp. 1] 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. [40 CFR 60.7(f), Minn. R , subp. 5(C), Minn. R , subp. 1] If notification substantially similar to that in 40 CFR Section 60.7(a) is required by any other State or local agency, sending the Administrator a copy of that notification will satisfy the requirements of 40 CFR Section 60.7(a) [40 CFR 60.7(f), Minn. R , subp. 1] Individual subparts of 40 CFR pt. 60 may include specific provisions which clarify or make inapplicable the provisions set

105 Permit Expires: [month day, year] Page 103 of 243 forth in this section. [40 CFR 60.7(f), Minn. R , subp. 1] At all times, including periods of startup, shutdown and malfunction, the Permittee shall, to the extent possible, maintain and operate any affected facility including associated air pollution control equipment in a manner consistent with good air pollution control practice for minimizing emissions. Determination of whether acceptable operating 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, opacity observations, review of operating and maintenance procedures and inspection of the source. [40 CFR 60.11(d), Minn. R ] For the purpose of submitting compliance certifications or establishing whether or not a person has violated or is in violation of any standard in this part, nothing in this part shall preclude the use, including the exclusive use, of any credible evidence or information, relevant to whether a source would have been in compliance with applicable requirements if the appropriate performance or compliance test or procedure had been performed. [40 CFR 60.11(g), Minn. R ] 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. [40 CFR 60.12, Minn. R ] If the Permittee proposes to replace components, and the fixed capital cost of the new components exceeds 50 percent of the fixed capital cost that would be required to construct a comparable entirely new facility, the Permittee shall notify the Administrator of the proposed replacements. The notice must be postmarked 60 days (or as soon as practicable) before construction of the replacements is commenced and must include the following information: 1) Name and address of the owner or operator. 2) The location of the existing facility. 3) A brief description of the existing facility and the components which are to be replaced. 4) A description of the existing air pollution control equipment and the proposed air pollution control equipment. 5) An estimate of the fixed capital cost of the replacements and of constructing a comparable entirely new facility. 6) The estimated life of the existing facility after the replacements. 7) A discussion of any economic or technical limitations the facility may have in complying with the applicable standards of performance after the proposed replacements. [40 CFR

106 Permit Expires: [month day, year] Page 104 of (d), Minn. R ] STRU 12 SV029 West Plant Grain Receiving Uncaptured Emissions Opacity <= 5 percent opacity for uncaptured emissions from EQUI 169. [Minn. R , subp. 3(A)] Clean up commodities spilled on the driveway and other facility property as required to minimize emissions to a level consistent with RACT (Reasonably Available Control Technology). [Minn. R , subp. 1(A)] STRU 13 SV030 West Plant DDGS Loadout Uncaptured Emissions Opacity <= 5 percent opacity for uncaptured emissions from rail loading operations. [Minn. R , subp. 3(A)] Opacity <= 10 percent opacity for uncaptured emissions from truck loading operations. [Minn. R , subp. 3(B)] Clean up commodities spilled on the driveway and other facility property as required to minimize emissions to a level consistent with RACT (Reasonably Available Control Technology). [Minn. R , subp. 1(A)] STRU 14 SV031 West Plant DDGS Truck Loading Building Uncaptured Emissions PM < 10 micron <= pounds per hour 3 hour average. [Title I Condition: 40 CFR 52.21(k)(1)(i) & Minn. R , Title I Condition: Avoid major source under 40 CFR 52.21(b)(1)(i) & Minn. R ] PM < 2.5 micron <= pounds per hour 3 hour average. [Minn. R , subp. 7(A), 7(L), & 7(M), Minn. R , subp. 4, Minn. R , subps. 1 2, Minn. R , Minn. Stat , subd. 4a, Minn. Stat , subd. 9, Title I Condition: Avoid major source under 40 CFR 52.21(b)(1)(i) & Minn. R ] Opacity <= 10 percent opacity for uncaptured emissions from truck loading operations. [Minn. R , subp. 3(B)] Clean up commodities spilled on the driveway and other facility property as required to minimize emissions to a level consistent with RACT (Reasonably Available Control Technology). [Minn. R , subp. 1(A)] STRU 15 SV032 West Plant DDGS

107 Permit Expires: [month day, year] Page 105 of 243 Loadout Captured Emissions The Permittee shall install, operate and maintain control equipment such that it achieves a capture efficiency for Total Particulate Matter >= 80 percent capture efficiency. [Minn. R , subp. 14, Minn. R , subp. 2, Title I Condition: Avoid major source under 40 CFR 52.21(b)(1)(i) and Minn. R ] The Permittee shall install, operate and maintain control equipment such that it achieves a capture efficiency for PM < 10 micron >= 80 percent capture efficiency. [Minn. R , subp. 14, Minn. R , subp. 2, Title I Condition: Avoid major source under 40 CFR 52.21(b)(1)(i) and Minn. R ] The Permittee shall install, operate and maintain control equipment such that it achieves a capture efficiency for PM < 2.5 micron >= 80 percent capture efficiency. [Minn. R , subp. 14, Minn. R , subp. 2, Title I Condition: Avoid major source under 40 CFR 52.21(b)(1)(i) and Minn. R ] The Permittee shall install, operate and maintain control equipment such that it achieves a collection efficiency for Total Particulate Matter >= 80 percent collection efficiency. [Minn. R , subp. 3(E)] Uncaptured 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 [Minn. R ] Initial Hood Certification and Evaluation: To claim a hood capture efficiency of 80% for PM, PM10 and PM2.5, the control device hood must conform to the design and operating requirements referenced in Minn. R , subp. 2(B). The Permittee shall certify this as specified in Minn. R , subps. 2 and 3, except that the Minn. R , subp. 2(B) certification submittal deadline shall be superseded by the deadline established by this permit (No ). The hood certification must address how cross drafts are accommodated in the design (i.e. higher face velocity, oversized hood, etc.). The Permittee shall maintain a copy of the evaluation and certification on site. [Minn. R , subp. 14, Minn. R , subps. 4 5] Annual Hood Evaluation: The Permittee shall measure and record at least once every 12 months the fan rotation speed, fan power draw, face velocity, or other comparable air flow parameter(s) that was measured during the initial hood certification to verify the hood design and operation parameter(s) meet or exceed the parameter(s) measured

108 Permit Expires: [month day, year] Page 106 of 243 during the initial hood evaluation conducted according to Minn. R , subps. 2 & 3. The Permittee shall maintain a copy of the annual evaluation on site. [Minn. R , subp. 14, Minn. R , subps. 4 5] STRU 16 SV033 West Plant DDGS Truck Loading Building Captured Emissions The Permittee shall install, operate and maintain control equipment such that it achieves a capture efficiency for Total Particulate Matter >= 80 percent capture efficiency. [Minn. R , subp. 14, Minn. R , subp. 2, Title I Condition: Avoid major source under 40 CFR 52.21(b)(1)(i) and Minn. R ] The Permittee shall install, operate and maintain control equipment such that it achieves a capture efficiency for PM < 10 micron >= 80 percent capture efficiency. [Minn. R , subp. 14, Minn. R , subp. 2, Title I Condition: Avoid major source under 40 CFR 52.21(b)(1)(i) and Minn. R ] The Permittee shall install, operate and maintain control equipment such that it achieves a capture efficiency for PM < 2.5 micron >= 80 percent capture efficiency. [Minn. R , subp. 14, Minn. R , subp. 2, Title I Condition: Avoid major source under 40 CFR 52.21(b)(1)(i) and Minn. R ] The Permittee shall install, operate and maintain control equipment such that it achieves a collection efficiency for Total Particulate Matter >= 80 percent collection efficiency. [Minn. R , subp. 3(E)] Uncaptured 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 [Minn. R ] All DDGS loadout operations shall be conducted within the West Plant DDGS truck loading building. [Minn. R , subp. 7(A), 7(L), & 7(M), Minn. R , subp. 4, Minn. R , subps. 1 2, Minn. R , Minn. Stat , subd. 4a, Minn. Stat , subd. 9, Title I Condition: Avoid major source under 40 CFR 52.21(b)(1)(i) and Minn. R ] The Permittee shall use best management practices for DDGS loadout operations. [Minn. R , subp. 2] Initial Hood Certification and Evaluation: To claim a hood capture efficiency of 80% for PM, PM10 and PM2.5, the control device hood must conform to the design and operating

109 Permit Expires: [month day, year] Page 107 of 243 requirements referenced in Minn. R , subp. 2(B). The Permittee shall certify this as specified in Minn. R , subps. 2 and 3, except that the Minn. R , subp. 2(B) certification submittal deadline shall be superseded by the deadline established by this permit (No ). The hood certification must address how cross drafts are accommodated in the design (i.e. higher face velocity, oversized hood, etc.). The Permittee shall maintain a copy of the evaluation and certification on site. [Minn. R , subp. 14, Minn. R , subps. 4 5] Annual Hood Evaluation: The Permittee shall measure and record at least once every 12 months the fan rotation speed, fan power draw, face velocity, or other comparable air flow parameter(s) that was measured during the initial hood certification to verify the hood design and operation parameter(s) meet or exceed the parameter(s) measured during the initial hood evaluation conducted according to Minn. R , subps. 2 & 3. The Permittee shall maintain a copy of the annual evaluation on site. [Minn. R , subp. 14, Minn. R , subps. 4 5] STRU 17 SV034 Corn Dump Pit/Auger #2 Uncaptured Emissions Opacity <= 10 percent opacity for uncaptured emissions from EQUI 174. [Minn. R , subp. 3(D)] Clean up commodities spilled on the driveway and other facility property as required to minimize emissions to a level consistent with RACT (Reasonably Available Control Technology). [Minn. R , subp. 1(A)] STRU 18 SV035 Corn Dump Pit/Auger #3 Uncaptured Emissions Opacity <= 10 percent opacity for uncaptured emissions from EQUI 175. [Minn. R , subp. 3(D)] Clean up commodities spilled on the driveway and other facility property as required to minimize emissions to a level consistent with RACT (Reasonably Available Control Technology). [Minn. R , subp. 1(A)] STRU 68 SV016 West Plant CO2 Scrubber (CE 008) Volatile Organic Compounds <= 6.59 pounds per hour 3 hour average as total mass of VOC. [Title I Condition: 40 CFR 52.21(j)(BACT) & Minn. R , Title I Condition: Avoid

110 Permit Expires: [month day, year] Page 108 of 243 major source under 40 CFR 52.21(b)(1)(i) & Minn. R ] Total Particulate Matter <= 0.30 grains per 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 individually to each emission unit that vents through STRU 68. [Minn. R , subp. 1(A)] Opacity <= 20 percent opacity. This limit applies individually to each emission unit that vents through STRU 68. [Minn. R , subp. 1(B)] Emission Unit Flexibility: The Permittee may replace, add or modify existing West Plant fermentation and distillation equipment. Fermentation equipment is fermentation tanks and beer wells. Distillation equipment is distillation columns, evaporators, slurry tanks, liquefaction tanks, yeast tanks, run down tanks, and molecular sieves. For the West Plant fermentation and distillation equipment, if the Permittee replaces any existing equipment, adds new equipment, or modifies existing equipment, such equipment is subject to all of the requirements of STRU 68 as well as the requirements in the Total Facility subject item of this permit. Additionally: 1) All existing, new, replaced, and modified fermentation tanks and beerwells at the facility shall be vented to the CO2 scrubber (TREA 34) at all times that fermentation and/or distillation equipment is operating; and, 2) VOC emissions shall remain below the limits specified in this subject item (STRU 68). 3) After the addition, replacement, or modification of equipment, stack emissions testing for VOCs and HAPs shall be completed within 90 days after completing the addition, replacement, or modification to ensure that the new equipment does not cause an exceedance of applicable emission limits. 4) Replacement, modification, and/or addition of a unit/process venting to STRU 68 does not relieve the Permittee from STRU 68 BACT requirements. BACT requirements can only be removed if the process is permanently retired. 5) Prior to making such a change, the Permittee shall apply for and obtain the appropriate permit amendment, as applicable. The Permittee shall complete calculations described in Minn.

111 Permit Expires: [month day, year] Page 109 of 243 R A permit amendment is still required regardless of the emissions increase if the change will be subject to a new applicable requirement or requires revisions to limits or monitoring and recordkeeping requirements in this permit. [Minn. R , Title I Condition: Avoid major source under 40 CFR 52.21(b)(1)(i) & Minn. R , Title I Condition: Avoid major source under 40 CFR 63.2] Vent all emissions from all West Plant fermentation and distillation equipment to scrubber TREA 34. The Permittee shall document periods of non operation of TREA 34 during operation of any West Plant Fermentation and/or Distillation Equipment. [Minn. R , Title I Condition: 40 CFR 52.21(j)(BACT) & Minn. R , Title I Condition: Avoid major source under 40 CFR 52.21(b)(1)(i) & Minn. R , Title I Condition: Avoid major source under 40 CFR 63.2] POLLUTION CONTROL REQUIREMENTS Refer to TREA 34 for additional pollution control requirements. [Minn. R , subp. 2] STRU 68 Operating Hours Monitoring and Recordkeeping: The Permittee shall monitor STRU 68 operating hours for use in COMG 4 HAP calculations. An 'STRU 68 operating hour' is any hour during which any process equipment is operating that vents through STRU 68. The Permittee shall monitor and keep separate records for STRU 68 operating hours when TREA 34 water flow rate or pressure drop is less than the required minimum (listed under TREA 34) during the operating hour. If the Permittee only conducts daily TREA 34 water flow rate and pressure drop monitoring (and not hourly monitoring as described under TREA 34) and the monitored daily water flow rate or pressure drop is below the required minimum, all operating hours during that calendar day are recorded as TREA 34 operating below the required minimum pressure drop or water flow rate. [Minn. R , subps. 4 5, Minn. R , Title I Condition: Avoid major source under 40 CFR 63.2] Monthly Monitoring and Recordkeeping: By the 15th day of each month, the Permittee shall calculate and record the following for the previous calendar month: 1. Monthly STRU 68 operating hours when TREA 34 was operating at or above the required water flow rate and pressure drop; and,

112 Permit Expires: [month day, year] Page 110 of Monthly STRU 68 operating hours when TREA 34 was operating at less than the required minimum water flow rate and/or pressure drop. [Minn. R , subps. 4 5] Protocol for Re Setting the Emission Factor Used For Calculating Acetaldehyde, Acrolein, Formaldehyde, and Methanol Emissions: The Permittee shall conduct performance testing under worst case conditions (as defined at Minn. R ) that produce the maximum acetaldehyde, acrolein, formaldehyde, and methanol emissions. US E.P.A. Reference Method 18, 320, or other method approved by MPCA in the performance test plan approval shall be used to measure the emission factor for each of these HAPs as required under subject item STRU 68 in this permit. The Permittee shall report the test result in lb/hr in the performance test report required by Minn. R , subp. 1. The emission factors used for calculating acetaldehyde, acrolein, formaldehyde, and methanol emissions shall be reset to the 3 hour average emission rate in lb/hr, measured during the most recent MPCA approved acetaldehyde, acrolein, formaldehyde, and methanol emission factor performance test. The new emission factor used for calculating acetaldehyde, acrolein, formaldehyde, and methanol emissions determined using this Protocol shall be effective upon receipt of the Notice of Verification (NOV) letter or equivalent MPCA correspondence, that approves the test results and shall be incorporated into the permit during the next permit amendment. [Minn. R , Title I Condition: Avoid major source under 40 CFR 63.2] The Permittee must apply for and obtain a major permit amendment if the Permittee wishes to deviate from the Protocol for Re setting the Emission Factor Used for Calculating Acetaldehyde, Acrolein, Formaldehyde, and Methanol Emissions established by this permit. [Minn. R , subp. 1] Notwithstanding the Protocol detailed above, the MPCA reserves the right to set operational limits and requirements as allowed under Minn. R If the MPCA sets limits, the new limits shall be implemented upon receipt of the NOV letter (or equivalent MPCA correspondence), that notifies the Permittee of preliminary approval. The limits set according to Minn. R are final upon issuance of a permit amendment incorporating the change. [Minn. R ] Process Throughput <= 1237 gallons per minute 8 hour block average of beer produced unless a new limit is set pursuant to

113 Permit Expires: [month day, year] Page 111 of 243 Minn. R , subp. 3 based on the throughput recorded during the most recent MPCA approved performance test where compliance was demonstrated. The new limit shall be implemented upon receipt of the NOV letter (or equivalent MPCA correspondence) granting preliminary approval. The limit is final upon issuance of a permit amendment incorporating the change. This operating parameter must remain in the permit to define the maximum capacity of the process on an hourly basis. [Minn. R , subp. 3] Procedure to Increase Process Throughput Limit: STRU 69 SV007 East Plant The Permittee may increase the STRU 68 process throughput limit by conducting a performance test at an operating rate that exceeds the permitted STRU 68 process throughput limit and meeting requirements 1 through 7 below. 1. Performance Test Notification (written): due 90 days before performance test at an increased process throughput rate. 2. The Permittee may exceed the existing process throughput limit upon MPCA receipt of the notification of a performance test at a higher process throughput (required by item 1 above). 3. The Permittee shall calculate actual emissions (i.e. for HAPs as required under COMG 4, or for emission inventory or any other purpose) using the emission rate from the increased process throughput performance test retroactive to the date of the Performance Test Notification. 4. Performance Test Plan: due 30 days before performance test. The Test Plan shall identify the new proposed maximum process throughput limit. 5. Performance Test Pre Test Meeting: due 7 days before performance test. 6. Performance Test Report: due 45 days after performance test. 7. 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 [Minn. R , subp. 2, Minn. R , Minn. R , subps. 1 4, Minn. R , subps. 1 2]

114 Permit Expires: [month day, year] Page 112 of 243 Distillation Scrubber (CE 005) Volatile Organic Compounds <= 0.99 pounds per hour 3 hour average as total mass of VOC. [Title I Condition: 40 CFR 52.21(j)(BACT) & Minn. R , Title I Condition: Avoid major source under 40 CFR 52.21(b)(1)(i) & Minn. R ] Total Particulate Matter <= 0.30 grains per 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 individually to each emission unit that vents through STRU 69. [Minn. R , subp. 1(A)] Opacity <= 20 percent opacity. This limit applies individually to each emission unit that vents through STRU 69. [Minn. R , subp. 1(B)] Emission Unit Flexibility: The Permittee may replace, add or modify existing East Plant distillation equipment. Distillation equipment is distillation columns, evaporators, slurry tanks, liquefaction tanks, yeast tanks, run down tanks, and molecular sieves. For the East Plant distillation equipment, if the Permittee replaces any existing equipment, adds new equipment, or modifies existing equipment, such equipment is subject to all of the requirements of STRU 69 as well as the requirements in the Total Facility subject item of this permit. Additionally: 1) All existing, new, replaced, and modified distillation equipment at the facility shall be vented to the distillation scrubber (TREA 31) at all times that distillation equipment is operating; and, 2) VOC emissions shall remain below the limits specified in this subject item (STRU 69). 3) After the addition, replacement, or modification of equipment, stack emissions testing for VOCs and HAPs shall be completed within 90 days after completing the addition, replacement, or modification to ensure that the new equipment does not cause an exceedance of applicable emission limits. 4) Replacement, modification, and/or addition of a unit/process venting to STRU 69 does not relieve the Permittee from STRU 69 BACT requirements. BACT requirements can only

115 Permit Expires: [month day, year] Page 113 of 243 be removed if the process is permanently retired. 5) Prior to making such a change, the Permittee shall apply for and obtain the appropriate permit amendment, as applicable. The Permittee shall complete calculations described in Minn. R A permit amendment is still required regardless of the emissions increase if the change will be subject to a new applicable requirement or requires revisions to limits or monitoring and recordkeeping requirements in this permit. [Minn. R , Title I Condition: Avoid major source under 40 CFR 52.21(b)(1)(i) & Minn. R , Title I Condition: Avoid major source under 40 CFR 63.2] Vent all emissions from all East Plant distillation equipment to scrubber TREA 31. The Permittee shall document periods of non operation of TREA 31 during operation of any East Plant Distillation Equipment. [Minn. R , Title I Condition: 40 CFR 52.21(j)(BACT) & Minn. R , Title I Condition: Avoid major source under 40 CFR 52.21(b)(1)(i) & Minn. R , Title I Condition: Avoid major source under 40 CFR 63.2] POLLUTION CONTROL REQUIREMENTS Refer to TREA 31 for additional pollution control requirements. [Minn. R , subp. 2] Volatile Organic Compounds >= 98 percent control efficiency or emissions no higher than 10 ppm outlet VOC concentration. [Title I Condition: 40 CFR 52.21(j)(BACT) & Minn. R , Title I Condition: Avoid major source under 40 CFR 52.21(b)(1)(i) & Minn. R ] STRU 69 Operating Hours Monitoring and Recordkeeping: The Permittee shall monitor STRU 69 operating hours for use in COMG 4 HAP calculations. An 'STRU 69 operating hour' is any hour during which any process equipment is operating that vents through STRU 69. The Permittee shall monitor and keep separate records for STRU 69 operating hours when TREA 31 water flow rate or pressure drop is less than the required minimum (listed under TREA 31) during the operating hour. If the Permittee only conducts daily TREA 31 water flow rate and pressure drop monitoring (and not hourly monitoring as described under TREA 31) and the monitored daily water flow rate or pressure drop is below the required minimum, all operating hours during that calendar day are recorded as TREA 31 operating below the required minimum pressure drop or water flow rate. [Minn. R , subps. 4 5, Minn. R , Title I Condition: Avoid major source under 40 CFR 63.2]

116 Permit Expires: [month day, year] Page 114 of Monthly Monitoring and Recordkeeping: By the 15th day of each month, the Permittee shall calculate and record the following for the previous calendar month: 1. Monthly STRU 69 operating hours when TREA 31 was operating at or above the required water flow rate and pressure drop; and, 2. Monthly STRU 69 operating hours when TREA 31 was operating at less than the required minimum water flow rate and/or pressure drop. [Minn. R , subps. 4 5] Protocol for Re Setting the Emission Factor Used For Calculating Acetaldehyde, Acrolein, Formaldehyde, and Methanol Emissions: The Permittee shall conduct performance testing under worst case conditions (as defined at Minn. R ) that produce the maximum acetaldehyde, acrolein, formaldehyde, and methanol emissions. US E.P.A. Reference Method 18, 320, or other method approved by MPCA in the performance test plan approval shall be used to measure the emission factor for each of these HAPs as required under subject item STRU 69 in this permit. The Permittee shall report the test result in lb/hr in the performance test report required by Minn. R , subp. 1. The emission factors used for calculating acetaldehyde, acrolein, formaldehyde, and methanol emissions shall be reset to the 3 hour average emission rate in lb/hr, measured during the most recent MPCA approved acetaldehyde, acrolein, formaldehyde, and methanol emission factor performance test. The new emission factor used for calculating acetaldehyde, acrolein, formaldehyde, and methanol emissions determined using this Protocol shall be effective upon receipt of the Notice of Verification (NOV) letter or equivalent MPCA correspondence, that approves the test results and shall be incorporated into the permit during the next permit amendment. [Minn. R , Title I Condition: Avoid major source under 40 CFR 63.2] The Permittee must apply for and obtain a major permit amendment if the Permittee wishes to deviate from the Protocol for Re setting the Emission Factor Used for Calculating Acetaldehyde, Acrolein, Formaldehyde, and Methanol Emissions established by this permit. [Minn. R , subp. 1] Notwithstanding the Protocol detailed above, the MPCA

117 Permit Expires: [month day, year] Page 115 of 243 reserves the right to set operational limits and requirements as allowed under Minn. R If the MPCA sets limits, the new limits shall be implemented upon receipt of the NOV letter (or equivalent MPCA correspondence), that notifies the Permittee of preliminary approval. The limits set according to Minn. R are final upon issuance of a permit amendment incorporating the change. [Minn. R ] Process Throughput <= 73 gallons per minute 8 hour block average of 200 proof ethanol produced unless a new limit is set pursuant to Minn. R , subp. 3 based on the throughput recorded during the most recent MPCA approved performance test where compliance was demonstrated. The new limit shall be implemented upon receipt of the NOV letter (or equivalent MPCA correspondence) granting preliminary approval. The limit is final upon issuance of a permit amendment incorporating the change. This operating parameter must remain in the permit to define the maximum capacity of the process on an hourly basis. [Minn. R , subp. 3] Procedure to Increase Process Throughput Limit: The Permittee may increase the STRU 69 process throughput limit by conducting a performance test at an operating rate that exceeds the permitted STRU 69 process throughput limit and meeting requirements 1 through 7 below. 1. Performance Test Notification (written): due 90 days before performance test at an increased process throughput rate. 2. The Permittee may exceed the existing process throughput limit upon MPCA receipt of the notification of a performance test at a higher process throughput (required by item 1 above). 3. The Permittee shall calculate actual emissions (i.e. for HAPs as required under COMG 4, or for emission inventory or any other purpose) using the emission rate from the increased process throughput performance test retroactive to the date of the Performance Test Notification. 4. Performance Test Plan: due 30 days before performance test. The Test Plan shall identify the new proposed maximum process throughput limit. 5. Performance Test Pre Test Meeting: due 7 days before performance test. 6. Performance Test Report: due 45 days after performance test.

118 Permit Expires: [month day, year] Page 116 of 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 [Minn. R , subp. 2, Minn. R , Minn. R , subps. 1 4, Minn. R , subps. 1 2] STRU 70 SV018 VRTO #2 West Plant (CE 012) Total Particulate Matter <= 0.30 grains per 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 individually to EQUI 22 and EQUI 23. [Minn. R , subp. 1(A)(1)] Total Particulate Matter <= 0.30 grains per 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 individually to EQUI 55 and EQUI 178. [Minn. R , subp. 1(A)] Total Particulate Matter <= grains per dry standard cubic foot. [Title I Condition: 40 CFR 52.21(j)(BACT) & Minn. R ] Total Particulate Matter <= pounds per hour 3 hour average. [Title I Condition: 40 CFR 52.21(j)(BACT) & Minn. R ] PM < 10 micron <= grains per dry standard cubic foot. [Title I Condition: 40 CFR 52.21(j)(BACT) & Minn. R ] PM < 10 micron <= pounds per hour 3 hour average. [Title I Condition: 40 CFR 52.21(j) & (k)(bact) & Minn. R , Title I Condition: Avoid major source under 40 CFR 52.21(b)(1)(i) & Minn. R ] PM < 2.5 micron <= grains per dry standard cubic foot. [Title I Condition: Avoid major source under 40 CFR 52.21(b)(1)(i) & Minn. R ] PM < 2.5 micron <= pounds per hour 3 hour average. [Minn. R , subp. 7(A), 7(L), & 7(M), Minn. R , subp. 4, Minn. R , subps. 1 2, Minn. R , Minn. Stat , subd. 4a, Minn. Stat , subd. 9, Title I Condition: Avoid major source under 40 CFR 52.21(b)(1)(i) & Minn. R ] Volatile Organic Compounds <= pounds per hour 3 hour average as total mass of VOC. [Title I Condition: 40 CFR 52.21(j)(BACT) & Minn. R ] Nitrogen Oxides <= pounds per hour 3 hour average. This limit applies to total NOx (thermal and process NOx). [Title I Condition: 40 CFR 52.21(j)(BACT) & Minn. R ]

119 Permit Expires: [month day, year] Page 117 of Nitrogen Oxides <= parts per million by volume, wet gas basis. This limit applies to total NOx (thermal and process NOx). [Title I Condition: 40 CFR 52.21(j)(BACT) & Minn. R ] Carbon Monoxide <= 19.4 pounds per hour 3 hour average. [Title I Condition: 40 CFR 52.21(j)(BACT) & Minn. R ] Sulfur Dioxide <= 5.05 pounds per hour 3 hour average. [Title I Condition: Avoid major modification under 40 CFR 52.21(b)(23)(i) & Minn. R ] The dryer shall be fitted with a low NOx burner specified to emit fuel combustion NOx at 0.04 lb/mmbtu or less. [Title I Condition: 40 CFR 52.21(j)(BACT) & Minn. R ] Opacity <= 20 percent opacity except for one six minute period per hour of not more than 60 percent opacity. This limit applies individually to EQUI 22 and EQUI 23. [Minn. R , subp. 1(A)(2)] Opacity <= 20 percent opacity. This limit applies individually to EQUI 55 and EQUI 178. [Minn. R , subp. 1(B)] Permitted Fuel: Natural gas only. [Title I Condition: 40 CFR 52.21(j)(BACT) & Minn. R ] POLLUTION CONTROL REQUIREMENTS Refer to TREA 29 for additional pollution control requirements. [Minn. R , subp. 2] Vent all emissions from West Plant Dryer #3 to TREA 29. The Permittee shall document periods of non operation of TREA 29 during operation of West Plant Dryer #3. [Title I Condition: 40 CFR 52.21(j)(BACT) & Minn. R , Title I Condition: Avoid major source under 40 CFR 52.21(b)(1)(i) & Minn. R ] STRU 70 Operating Hours Monitoring and Recordkeeping: The Permittee shall monitor STRU 70 operating hours for use in COMG 4 HAP calculations. An 'STRU 70 operating hour' is any hour during which any process equipment is operating that vents through STRU 70. The Permittee shall monitor and keep separate records for STRU 70 operating hours when TREA 29 combustion chamber temperature is less than the required minimum (listed under TREA 29) during the operating hour. If the Permittee only conducts daily TREA 29 temperature monitoring (and not hourly monitoring as described under TREA 29) and the monitored combustion chamber temperature is below the required minimum, all operating hours during that calendar day are recorded as TREA 29 operating below the required minimum temperature. [Minn. R , subps. 4 5, Minn. R , Title I Condition: Avoid major source under 40 CFR 63.2]

120 Permit Expires: [month day, year] Page 118 of Monthly Monitoring and Recordkeeping: By the 15th day of each month, the Permittee shall calculate and record the following for the previous calendar month: 1. Monthly STRU 70 operating hours when TREA 29 was operating at or above the required minimum temperature; and, 2. Monthly STRU 70 operating hours when TREA 29 was operating at less than the required minimum temperature. [Minn. R , subps. 4 5] Protocol for Re Setting the Emission Factor Used For Calculating Acetaldehyde, Acrolein, Formaldehyde, and Methanol Emissions: The Permittee shall conduct performance testing under worst case conditions (as defined at Minn. R ) that produce the maximum acetaldehyde, acrolein, formaldehyde, and methanol emissions. US E.P.A. Reference Method 18, 320, or other method approved by MPCA in the performance test plan approval shall be used to measure the emission factor for each of these HAPs as required under subject item STRU 70 in this permit. The Permittee shall report the test result in lb/hr in the performance test report required by Minn. R , subp. 1. The emission factors used for calculating acetaldehyde, acrolein, formaldehyde, and methanol emissions shall be reset to the 3 hour average emission rate in lb/hr, measured during the most recent MPCA approved acetaldehyde, acrolein, formaldehyde, and methanol emission factor performance test. The new emission factor used for calculating acetaldehyde, acrolein, formaldehyde, and methanol emissions determined using this Protocol shall be effective upon receipt of the Notice of Verification (NOV) letter or equivalent MPCA correspondence, that approves the test results and shall be incorporated into the permit during the next permit amendment. [Minn. R , Title I Condition: Avoid major source under 40 CFR 63.2] The Permittee must apply for and obtain a major permit amendment if the Permittee wishes to deviate from the Protocol for Re setting the Emission Factor Used for Calculating Acetaldehyde, Acrolein, Formaldehyde, and Methanol Emissions established by this permit. [Minn. R , subp. 1] Notwithstanding the Protocol detailed above, the MPCA

121 Permit Expires: [month day, year] Page 119 of 243 reserves the right to set operational limits and requirements as allowed under Minn. R If the MPCA sets limits, the new limits shall be implemented upon receipt of the NOV letter (or equivalent MPCA correspondence), that notifies the Permittee of preliminary approval. The limits set according to Minn. R are final upon issuance of a permit amendment incorporating the change. [Minn. R ] Thermal Oxidizer Burnouts and Other Maintenance Activities: During thermal oxidizer malfunctions and any other maintenance for which the manufacturer recommends dryer emissions bypass the thermal oxidizer, the dryer shall be shutdown. Wet DDGS shall be stored and handled to minimize VOC emissions and odors during these maintenance activities. The Permittee shall maintain a record of such maintenance activities in the O & M plan for TREA 11. [Minn. R , subp. 14, Minn. R , subp. 16(J)] Thermal Oxidizer Breakdown: In the event of a breakdown of the thermal oxidizer, the Permittee shall stop feed into the dryer as soon as the breakdown is discovered. Dryer operation may continue as long as necessary to empty the dryer. The Permittee shall also submit the notification required by Minn. R , subp. 2, if required. [Minn. R , subp. 2] STRU 71 SV014 Grain Handling West Plant (CE 006) Total Particulate Matter <= grains per dry standard cubic foot. [Title I Condition: 40 CFR 52.21(j)(BACT) & Minn. R ] Total Particulate Matter <= pounds per hour 3 hour average. [Title I Condition: 40 CFR 52.21(j)(BACT) & Minn. R , Title I Condition: Avoid major source under 40 CFR 52.21(b)(1)(i) & Minn. R ] PM < 10 micron <= grains per dry standard cubic foot. [Title I Condition: 40 CFR 52.21(j) & (k)(bact) & Minn. R ] PM < 10 micron <= pounds per hour 3 hour average. [Title I Condition: 40 CFR 52.21(j) & (k)(bact) & Minn. R , Title I Condition: Avoid major source under 40 CFR 52.21(b)(1)(i) & Minn. R ] PM < 2.5 micron <= grains per dry standard cubic foot. [Title I Condition: Avoid major source under 40 CFR 52.21(b)(1)(i) & Minn. R ] PM < 2.5 micron <= pounds per hour 3 hour average. [Minn. R , subp. 7(A), 7(L), & 7(M), Minn. R , subp. 4, Minn. R , subps. 1 2, Minn. R , Minn. Stat , subd. 4a, Minn.

122 Permit Expires: [month day, year] Page 120 of 243 Stat , subd. 9, Title I Condition: Avoid major source under 40 CFR 52.21(b)(1)(i) & Minn. R ] Opacity <= 10 percent opacity. [Minn. R , subp. 3(D)] Emission Unit Flexibility: The Permittee may replace, add, or modify West Plant grain handling and storage equipment. This does not include replacement or modification of the receiving pit. If the Permittee replaces, adds new, or modifies existing grain handling and storage equipment, such equipment is subject to all of the requirements of STRU 71 as well as those listed in the Total Facility subject item of this permit. Grain handling and storage equipment is grain elevators, grain bins, and scalpers. Additionally: 1) All existing, new, replaced, and modified grain handling and storage equipment at the facility shall be vented to a grain handling and storage baghouse meeting the requirements of TREA 32 at all times that any of the equipment is operating; and, 2) Emissions of PM, PM10, and PM2.5 shall remain below the limits specified in this subject item (STRU 71). 3) Replacement, modification, and/or addition of a unit/process venting to STRU 71 does not relieve the Permittee from STRU 71 BACT requirements. BACT requirements can only be removed if the process is permanently retired. 4) Prior to making such a change, the Permittee shall apply for and obtain the appropriate permit amendment, as applicable. The Permittee shall complete calculations described in Minn. R A permit amendment is still required regardless of the emissions increase if the change will be subject to a new applicable requirement or requires revisions to limits or monitoring and recordkeeping requirements in this permit. [Title I Condition: Avoid major source under 40 CFR 52.21(b)(1)(i) & Minn. R ] Vent all emissions from all West Plant grain handling and storage equipment to fabric filter TREA 32. The Permittee shall document periods of non operation of TREA 32 during any West Plant grain handling and storage equipment activity. [Title I Condition: 40 CFR 52.21(j)(BACT) & Minn. R , Title I Condition: Avoid major source under 40 CFR 52.21(b)(1)(i) & Minn. R ] POLLUTION CONTROL REQUIREMENTS Refer to TREA 32 for additional pollution control requirements.

123 Permit Expires: [month day, year] Page 121 of 243 [Minn. R , subp. 2] Process Throughput <= 700 tons per hour 8 hour block average of corn received unless a new limit is set pursuant to Minn. R , subp. 3 based on the throughput recorded during the most recent MPCA approved performance test where compliance was demonstrated. The new limit shall be implemented upon receipt of the Notice of Compliance letter granting preliminary approval. The limit is final upon issuance of a permit amendment incorporating the change. This operating parameter must remain in the permit to define the maximum capacity of the process on an hourly basis. [Minn. R , subp. 3] Procedure to Increase Process Throughput Limit: The Permittee may increase the STRU 71 process throughput limit by conducting a performance test at an operating rate that exceeds the permitted STRU 71 process throughput limit and meeting requirements 1 through 7 below. 1. Performance Test Notification (written): due 90 days before performance test at an increased process throughput rate. 2. The Permittee may exceed the existing process throughput limit upon MPCA receipt of the notification of a performance test at a higher process throughput (required by item 1 above). 3. The Permittee shall calculate actual emissions (i.e. for emission inventory or any other purpose) using the emission rate from the increased process throughput performance test retroactive to the date of the Performance Test Notification. 4. Performance Test Plan: due 30 days before performance test. The Test Plan shall identify the new proposed maximum process throughput limit. 5. Performance Test Pre Test Meeting: due 7 days before performance test. 6. Performance Test Report: due 45 days after performance test. 7. 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 [Minn. R , subp. 2, Minn. R , Minn. R , subps. 1 4, Minn. R , subps. 1 2] Process Throughput <= 323 trucks per day for grain receiving

124 Permit Expires: [month day, year] Page 122 of 243 trucks. Of these 323 grain receiving trucks, no more than 5 trucks shall be straight trucks per day. [Minn. R , subp. 7(A), 7(L), & 7(M), Minn. R , subp. 4, Minn. R , subps. 1 2, Minn. R , Minn. Stat , subd. 4a, Minn. Stat , subd. 9, Title I Condition: 40 CFR 52.21(k)(1)(i) & Minn. R ] Recordkeeping of Grain Receiving Trucks: The Permittee shall record the number of grain receiving trucks each day. No more than 5 grain receiving trucks per day shall be straight trucks. [Minn. R , subp. 7(A), 7(L), & 7(M), Minn. R , subp. 4, Minn. R , subps. 1 2, Minn. R , Minn. Stat , subd. 4a, Minn. Stat , subd. 9, Title I Condition: 40 CFR 52.21(k)(1)(i) & Minn. R ] STRU 72 SV015 Hammermills 3 & 4 West Plant (CE 007) Total Particulate Matter <= grains per dry standard cubic foot. [Title I Condition: 40 CFR 52.21(j)(BACT) & Minn. R , Title I Condition: Avoid major source under 40 CFR 52.21(b)(1)(i) & Minn. R ] Total Particulate Matter <= pounds per hour 3 hour average based on air flow of 27,500 acfm. [Title I Condition: Avoid major source under 40 CFR 52.21(b)(1)(i) & Minn. R ] PM < 10 micron <= grains per dry standard cubic foot. [Title I Condition: 40 CFR 52.21(j) & (k)(bact) & Minn. R , Title I Condition: Avoid major source under 40 CFR 52.21(b)(1)(i) & Minn. R ] PM < 10 micron <= pounds per hour 3 hour average. [Title I Condition: 40 CFR 52.21(k)(1)(i) & Minn. R , Title I Condition: Avoid major source under 40 CFR 52.21(b)(1)(i) & Minn. R ] PM < 2.5 micron <= grains per dry standard cubic foot. [Title I Condition: Avoid major source under 40 CFR 52.21(b)(1)(i) & Minn. R ] PM < 2.5 micron <= pounds per hour 3 hour average. [Minn. R , subp. 7(A), 7(L), & 7(M), Minn. R , subp. 4, Minn. R , subps. 1 2, Minn. R , Minn. Stat , subd. 4a, Minn. Stat , subd. 9, Title I Condition: Avoid major source under 40 CFR 52.21(b)(1)(i) & Minn. R ] Opacity <= 10 percent opacity. [Minn. R , subp. 3(D)] The Permittee shall operate and maintain the control equipment such that it achieves a collection efficiency for Total Particulate Matter >= 80 percent collection efficiency. [Minn. R , subp. 3(E)]

125 Permit Expires: [month day, year] Page 123 of Emission Unit Flexibility: The Permittee may replace, add, or modify West Plant hammermilling equipment. If the Permittee replaces any existing hammermills, adds new hammermills, or modifies existing hammermills, such equipment is subject to all of the requirements of STRU 72 as well as those listed in the Total Facility subject item of this permit. Additionally: 1) all existing, new, replaced, and modified hammermills at the facility shall be vented to a hammermill baghouse meeting the requirements of TREA 33 at all times that the hammermills are operating; and, 2) emissions of PM, PM10, and PM2.5 shall remain below the limits specified in this subject item (STRU 72). 3) Replacement, modification, and/or addition of a unit/process venting to STRU 72 does not relieve the Permittee from STRU 72 BACT requirements. BACT requirements can only be removed if the process is permanently retired. 4) Prior to making such a change, the Permittee shall apply for and obtain the appropriate permit amendment, as applicable. The Permittee shall complete calculations described in Minn. R A permit amendment is still required regardless of the emissions increase if the change will be subject to a new applicable requirement or requires revisions to limits or monitoring and recordkeeping requirements in this permit. [Title I Condition: Avoid major source under 40 CFR 52.21(b)(1)(i) & Minn. R ] Vent all emissions from all West Plant hammermilling units to fabric filter TREA 33. The Permittee shall document periods of non operation of TREA 33 during operation of any West Plant hammermill. [Title I Condition: 40 CFR 52.21(j)(BACT) & Minn. R , Title I Condition: Avoid major source under 40 CFR 52.21(b)(1)(i) & Minn. R ] POLLUTION CONTROL REQUIREMENTS Refer to TREA 33 for additional pollution control requirements. [Minn. R , subp. 2] Process Throughput <= 95.2 tons per hour 8 hour block average (3,400 bushels/hour at 56 pounds per bushel) of corn received unless a new limit is set pursuant to Minn. R , subp. 3 based on the throughput recorded during the most recent MPCA approved performance test where compliance was demonstrated. The new limit shall be implemented upon receipt of the Notice of Compliance letter granting preliminary approval. The limit is final upon issuance of a permit amendment incorporating the change. This

126 Permit Expires: [month day, year] Page 124 of 243 operating parameter must remain in the permit to define the maximum capacity of the process on an hourly basis. [Minn. R , subp. 3] Procedure to Increase Process Throughput Limit: The Permittee may increase the STRU 72 process throughput limit by conducting a performance test at an operating rate that exceeds the permitted STRU 72 process throughput limit and meeting requirements 1 through 7 below. 1. Performance Test Notification (written): due 90 days before performance test at an increased process throughput rate. 2. The Permittee may exceed the existing process throughput limit upon MPCA receipt of the notification of a performance test at a higher process throughput (required by item 1 above). 3. The Permittee shall calculate actual emissions (i.e. for emission inventory or any other purpose) using the emission rate from the increased process throughput performance test retroactive to the date of the Performance Test Notification. 4. Performance Test Plan: due 30 days before performance test. The Test Plan shall identify the new proposed maximum process throughput limit. 5. Performance Test Pre Test Meeting: due 7 days before performance test. 6. Performance Test Report: due 45 days after performance test. 7. 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 [Minn. R , subp. 2, Minn. R , Minn. R , subps. 1 4, Minn. R , subps. 1 2] STRU 78 SV019 DDGS Cooler #2 (CE 013) bypass The Permittee shall not vent EQUI 55 emissions through STRU 78. [Title I Condition: 40 CFR 52.21(k)(1)(i) & Minn. R ] STRU 79 SV003 East Plant Fermentation Scrubber (CE

127 Permit Expires: [month day, year] Page 125 of ) Total Particulate Matter <= 0.30 grains per 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 individually to each emission unit that vents through STRU 79. [Minn. R , subp. 1(A)] Volatile Organic Compounds <= 2.73 pounds per hour 3 hour average as total mass of VOC. [Title I Condition: 40 CFR 52.21(j)(BACT) & Minn. R , Title I Condition: Avoid major source under 40 CFR 52.21(b)(1)(i) & Minn. R ] Opacity <= 20 percent opacity. This limit applies individually to each emission unit that vents through STRU 79. [Minn. R , subp. 1(B)] Emission Unit Flexibility: The Permittee may replace, add, or modify existing East Plant fermentation equipment. Fermentation equipment is fermentation tanks and/or beerwells. For the East Plant fermentation equipment, if the Permittee replaces any existing equipment, adds new equipment, or modifies existing equipment, such fermentation equipment is subject to all of the requirements of STRU 79 as well as the requirements in the Total Facility subject item of this permit. Additionally: 1) All existing, new, replaced, and modified fermentation equipment at the facility shall be vented to the fermentation scrubber (TREA 30) at all times that fermentation equipment is operating; and, 2) VOC emissions shall remain below the limits specified in this subject item (STRU 79). 3) After the addition, replacement, or modification of equipment, stack emissions testing for VOCs and HAPs shall be completed within 90 days after completing the addition, replacement, or modification to ensure that the new equipment does not cause an exceedance of applicable emission limits. 4) Replacement, modification, and/or addition of a unit/process venting to STRU 79 does not relieve the Permittee from STRU 79 BACT requirements. BACT requirements can only be removed if the process is permanently retired. 5) Prior to making such a change, the Permittee shall apply for and obtain the appropriate permit amendment, as applicable.

128 Permit Expires: [month day, year] Page 126 of 243 The Permittee shall complete calculations described in Minn. R A permit amendment is still required regardless of the emissions increase if the change will be subject to a new applicable requirement or requires revisions to limits or monitoring and recordkeeping requirements in this permit. [Minn. R , Title I Condition: Avoid major source under 40 CFR 52.21(b)(1)(i) & Minn. R , Title I Condition: Avoid major source under 40 CFR 63.2] Vent all emissions from all East Plant fermentation equipment to scrubber TREA 30. The Permittee shall document periods of non operation of TREA 30 during operation of any East Plant fermentation equipment. [Minn. R , Title I Condition: 40 CFR 52.21(j)(BACT) & Minn. R , Title I Condition: Avoid major source under 40 CFR 52.21(b)(1)(i) & Minn. R , Title I Condition: Avoid major source under 40 CFR 63.2] POLLUTION CONTROL REQUIREMENTS Refer to TREA 30 for additional pollution control requirements. [Minn. R , subp. 2] STRU 79 Operating Hours Monitoring and Recordkeeping: The Permittee shall monitor STRU 79 operating hours for use in COMG 4 HAP calculations. An 'STRU 79 operating hour' is any hour during which any process equipment is operating that vents through STRU 79. The Permittee shall monitor and keep separate records for STRU 79 operating hours when TREA 30 water flow rate or pressure drop is less than the required minimum (listed under TREA 30) during the operating hour. If the Permittee only conducts daily TREA 30 water flow rate and pressure drop monitoring (and not hourly monitoring as described under TREA 30) and the monitored daily water flow rate or pressure drop is below the required minimum, all operating hours during that calendar day are recorded as TREA 30 operating below the required minimum pressure drop or water flow rate. [Minn. R , subps. 4 5, Minn. R , Title I Condition: Avoid major source under 40 CFR 63.2] Monthly Monitoring and Recordkeeping: By the 15th day of each month, the Permittee shall calculate and record the following for the previous calendar month: 1. Monthly STRU 79 operating hours when TREA 30 was operating at or above the required water flow rate and pressure drop; and,

129 Permit Expires: [month day, year] Page 127 of Monthly STRU 79 operating hours when TREA 30 was operating at less than the required minimum water flow rate and/or pressure drop. [Minn. R , subps. 4 5] Protocol for Re Setting the Emission Factor Used For Calculating Acetaldehyde, Acrolein, Formaldehyde, and Methanol Emissions: The Permittee shall conduct performance testing under worst case conditions (as defined at Minn. R ) that produce the maximum acetaldehyde, acrolein, formaldehyde, and methanol emissions. US E.P.A. Reference Method 18, 320, or other method approved by MPCA in the performance test plan approval shall be used to measure the emission factor for each of these HAPs as required under subject item STRU 79 in this permit. The Permittee shall report the test result in lb/hr in the performance test report required by Minn. R , subp. 1. The emission factors used for calculating acetaldehyde, acrolein, formaldehyde, and methanol emissions shall be reset to the 3 hour average emission rate in lb/hr, measured during the most recent MPCA approved acetaldehyde, acrolein, formaldehyde, and methanol emission factor performance test. The new emission factor used for calculating acetaldehyde, acrolein, formaldehyde, and methanol emissions determined using this Protocol shall be effective upon receipt of the Notice of Verification (NOV) letter or equivalent MPCA correspondence, that approves the test results and shall be incorporated into the permit during the next permit amendment. [Minn. R , Title I Condition: Avoid major source under 40 CFR 63.2] The Permittee must apply for and obtain a major permit amendment if the Permittee wishes to deviate from the Protocol for Re setting the Emission Factor Used for Calculating Acetaldehyde, Acrolein, Formaldehyde, and Methanol Emissions established by this permit. [Minn. R , subp. 1] Notwithstanding the Protocol detailed above, the MPCA reserves the right to set operational limits and requirements as allowed under Minn. R If the MPCA sets limits, the new limits shall be implemented upon receipt of the NOV letter (or equivalent MPCA correspondence), that notifies the Permittee of preliminary approval. The limits set according to Minn. R are final upon issuance of a permit amendment incorporating the change. [Minn. R ] Process Throughput <= 440 gallons per minute 8 hour block average of beer produced unless a new limit is set pursuant to

130 Permit Expires: [month day, year] Page 128 of 243 Minn. R , subp. 3 based on the throughput recorded during the most recent MPCA approved performance test where compliance was demonstrated. The new limit shall be implemented upon receipt of the NOV letter (or equivalent MPCA correspondence) granting preliminary approval. The limit is final upon issuance of a permit amendment incorporating the change. This operating parameter must remain in the permit to define the maximum capacity of the process on an hourly basis. [Minn. R , subp. 3] Procedure to Increase Process Throughput Limit: STRU 82 SV020 Utility Boiler Stack The Permittee may increase the STRU 79 process throughput limit by conducting a performance test at an operating rate that exceeds the permitted STRU 79 process throughput limit and meeting requirements 1 through 7 below. 1. Performance Test Notification (written): due 90 days before performance test at an increased process throughput rate. 2. The Permittee may exceed the existing process throughput limit upon MPCA receipt of the notification of a performance test at a higher process throughput (required by item 1 above). 3. The Permittee shall calculate actual emissions (i.e. for HAPs as required under COMG 4, or for emission inventory or any other purpose) using the emission rate from the increased process throughput performance test retroactive to the date of the Performance Test Notification. 4. Performance Test Plan: due 30 days before performance test. The Test Plan shall identify the new proposed maximum process throughput limit. 5. Performance Test Pre Test Meeting: due 7 days before performance test. 6. Performance Test Report: due 45 days after performance test. 7. 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 [Minn. R , subp. 2, Minn. R , Minn. R , subps. 1 4, Minn. R , subps. 1 2]

131 Permit Expires: [month day, year] Page 129 of PM < 10 micron <= pounds per hour 3 hour average. [Title I Condition: 40 CFR 52.21(k)(1)(i) & Minn. R , Title I Condition: Avoid major source under 40 CFR 52.21(b)(1)(i) & Minn. R ] PM < 2.5 micron <= pounds per hour 3 hour average. [Minn. R , subp. 7(A), 7(L), & 7(M), Minn. R , subp. 4, Minn. R , subps. 1 2, Minn. R , Minn. Stat , subd. 4a, Minn. Stat , subd. 9, Title I Condition: Avoid major source under 40 CFR 52.21(b)(1)(i) & Minn. R ] See additional requirements at EQUI 4, 6, 51 and 52. [Minn. R , subp. 2] STRU 85 SV001 Grain Handling East Plant (CE001) Total Particulate Matter <= 0.43 pounds per hour. [Title I Condition: 40 CFR 52.21(j)(BACT) & Minn. R , Title I Condition: Avoid major source under 40 CFR 52.21(b)(1)(i) & Minn. R ] PM < 10 micron <= 0.43 pounds per hour. [Title I Condition: 40 CFR 52.21(j)(BACT) & Minn. R , Title I Condition: Avoid major source under 40 CFR 52.21(b)(1)(i) & Minn. R ] PM < 2.5 micron <= 0.43 pounds per hour. [Title I Condition: Avoid major source under 40 CFR 52.21(b)(1)(i) & Minn. R ] Opacity <= 10 percent opacity. [Minn. R , subp. 3(D)] Vent all emissions from all East Plant receiving and storage equipment to fabric filter TREA 43. The Permittee shall document periods of non operation of TREA 43 during any East Plant grain handling and storage equipment activity. [Title I Condition: 40 CFR 52.21(j)(BACT) & Minn. R , Title I Condition: Avoid major source under 40 CFR 52.21(b)(1)(i) & Minn. R ] Performance Test: due 24 months after Permit Issuance Date to measure STRU 85 PM emissions in gr/dscf and lb/hr. The performance test shall be conducted at worst case conditions as defined at Minn. R , subp. 8 (i.e. at least 90% of 420 tons/hr grain throughput), using EPA Reference Methods 5 and 202, or other method approved by MPCA in the performance test plan approval. [Minn. R , subp. 1, Title I Condition: 40 CFR 52.21(j)(BACT) & Minn. R , Title I Condition: Avoid major source under 40 CFR 52.21(b)(1)(i) & Minn. R ] Performance Test: due 24 months after Permit Issuance Date to measure STRU 85 PM10 emissions in gr/dscf and lb/hr. The performance test shall be conducted at worst case

132 Permit Expires: [month day, year] Page 130 of 243 conditions as defined at Minn. R , subp. 8 (i.e. at least 90% of 420 tons/hr grain throughput), using EPA Reference Methods 5 and 202, Methods 201A and 202, or other method approved by MPCA in the performance test plan approval. [Minn. R , subp. 1, Title I Condition: 40 CFR 52.21(j)(BACT) & Minn. R , Title I Condition: Avoid major source under 40 CFR 52.21(b)(1)(i) & Minn. R ] Performance Test: due 24 months after Permit Issuance Date to measure STRU 85 PM2.5 emissions in gr/dscf and lb/hr. The performance test shall be conducted at worst case conditions as defined at Minn. R , subp. 8 (i.e. at least 90% of 420 tons/hr grain throughput), using EPA Reference Methods 5 and 202, Methods 201A and 202, or other method approved by MPCA in the performance test plan approval. [Minn. R , subp. 1, Title I Condition: Avoid major source under 40 CFR 52.21(b)(1)(i) & Minn. R ] The Permittee shall submit a test frequency plan due 60 calendar days after Performance Test Date for Total Particulate Matter, PM10 and PM2.5 emissions based on the test data and MPCA guidance if EQUI 181 and EQUI 193 are not permanently shut down within 24 months of issuance of permit no [Minn. R , subp. 1] Process Throughput <= 420 tons per hour 8 hour block average (15,000 bushels/hour at 56 pounds per bushel) of corn received unless a new limit is set pursuant to Minn. R , subp. 3 based on the throughput recorded during the most recent MPCA approved performance test where compliance was demonstrated. The new limit shall be implemented upon receipt of the Notice of Compliance letter granting preliminary approval. The limit is final upon issuance of a permit amendment incorporating the change. This operating parameter must remain in the permit to define the maximum capacity of the process on an hourly basis. [Minn. R , subp. 3] Procedure to Increase Process Throughput Limit: The Permittee may increase the STRU 85 process throughput limit by conducting a performance test at an operating rate that exceeds the permitted STRU 85 process throughput limit and meeting requirements 1 through 7 below. 1. Performance Test Notification (written): due 90 days before performance test at an increased process throughput rate. 2. The Permittee may exceed the existing process throughput limit upon MPCA receipt of the notification of a performance test at a higher process throughput (required by item 1 above). 3. The Permittee shall calculate actual emissions (i.e. for emission inventory or any other purpose) using the emission rate from the increased process throughput performance test

133 Permit Expires: [month day, year] Page 131 of 243 retroactive to the date of the Performance Test Notification. 4. Performance Test Plan: due 30 days before performance test. The Test Plan shall identify the new proposed maximum process throughput limit. 5. Performance Test Pre Test Meeting: due 7 days before performance test. 6. Performance Test Report: due 45 days after performance test. 7. 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 [Minn. R , subp. 2, Minn. R , Minn. R , subps. 1 4, Minn. R , subps. 1 2] STRU 86 SV002 Hammermills 1 & 2 East Plant (CE002) Total Particulate Matter <= 0.27 pounds per hour. [Title I Condition: 40 CFR 52.21(j)(BACT) & Minn. R , Title I Condition: Avoid major source under 40 CFR 52.21(b)(1)(i) & Minn. R ] PM < 10 micron <= 0.27 pounds per hour. [Title I Condition: 40 CFR 52.21(j)(BACT) & Minn. R , Title I Condition: Avoid major source under 40 CFR 52.21(b)(1)(i) & Minn. R ] PM < 2.5 micron <= 0.27 pounds per hour. [Title I Condition: Avoid major source under 40 CFR 52.21(b)(1)(i) & Minn. R ] Opacity <= 10 percent opacity. [Minn. R , subp. 3(D)] Emission Unit Flexibility: The Permittee may replace, add, modify, or move East Plant hammermilling equipment. If the Permittee replaces any existing hammermills, adds new hammermills, or modifies existing hammermills, such equipment is subject to all of the requirements of STRU 86 as well as those listed in the Total Facility subject item of this permit. Additionally: 1) all existing, new, replaced, and modified hammermills at the facility shall be vented to a hammermill baghouse meeting the requirements of COMG 1 at all times that the hammermills are operating; and, 2) emissions of PM, PM10, and PM2.5 shall remain below the limits specified in this subject item (STRU 86). 3) Replacement, modification, and/or addition of a unit/process venting to STRU 86 does not relieve the Permittee from STRU 86 BACT requirements. BACT requirements can only be removed if the process is permanently retired.

134 Permit Expires: [month day, year] Page 132 of 243 4) Prior to making such a change, the Permittee shall apply for and obtain the appropriate permit amendment, as applicable. The Permittee shall complete calculations described in Minn. R A permit amendment is still required regardless of the emissions increase if the change will be subject to a new applicable requirement or requires revisions to limits or monitoring and recordkeeping requirements in this permit. [Title I Condition: Avoid major source under 40 CFR 52.21(b)(1)(i) & Minn. R ] Vent all emissions from all East Plant hammermilling units to fabric filter TREA 44. The Permittee shall document periods of non operation of TREA 44 during operation of any East Plant Hammermill. [Title I Condition: 40 CFR 52.21(j)(BACT) & Minn. R , Title I Condition: Avoid major source under 40 CFR 52.21(b)(1)(i) & Minn. R ] Performance Test: due 24 months after Permit Issuance Date to measure STRU 86 PM emissions in gr/dscf and lb/hr. The performance test shall be conducted at worst case conditions as defined at Minn. R , subp. 8 (i.e. at least 90% of 47.6 tons/hr grain throughput), using EPA Reference Methods 5 and 202, or other method approved by MPCA in the performance test plan approval. [Minn. R , subp. 1, Title I Condition: 40 CFR 52.21(j)(BACT) & Minn. R , Title I Condition: Avoid major source under 40 CFR 52.21(b)(1)(i) & Minn. R ] Performance Test: due 24 months after Permit Issuance Date to measure STRU 86 PM10 emissions in gr/dscf and lb/hr. The performance test shall be conducted at worst case conditions as defined at Minn. R , subp. 8 (i.e. at least 90% of 47.6 tons/hr grain throughput), using EPA Reference Methods 5 and 202, Methods 201A and 202, or other method approved by MPCA in the performance test plan approval. [Minn. R , subp. 1, Title I Condition: 40 CFR 52.21(j)(BACT) & Minn. R , Title I Condition: Avoid major source under 40 CFR 52.21(b)(1)(i) & Minn. R ] Performance Test: due 24 months after Permit Issuance Date to measure STRU 86 PM2.5 emissions in gr/dscf and lb/hr. The performance test shall be conducted at worst case conditions as defined at Minn. R , subp. 8 (i.e. at least 90% of 47.6 tons/hr grain throughput), using EPA Reference Methods 5 and 202, Methods 201A and 202, or other method approved by MPCA in the performance test plan approval. [Minn. R , subp. 1, Title I Condition: Avoid major source under 40 CFR 52.21(b)(1)(i) & Minn. R ] Process Throughput <= 47.6 tons per hour 8 hour block average (1,700 bushels/hour at 56 pounds per bushel) of corn

135 Permit Expires: [month day, year] Page 133 of 243 received unless a new limit is set pursuant to Minn. R , subp. 3 based on the throughput recorded during the most recent MPCA approved performance test where compliance was demonstrated. The new limit shall be implemented upon receipt of the Notice of Compliance letter granting preliminary approval. The limit is final upon issuance of a permit amendment incorporating the change. This operating parameter must remain in the permit to define the maximum capacity of the process on an hourly basis. [Minn. R , subp. 3] Procedure to Increase Process Throughput Limit: The Permittee may increase the STRU 86 process throughput limit by conducting a performance test at an operating rate that exceeds the permitted STRU 86 process throughput limit and meeting requirements 1 through 7 below. 1. Performance Test Notification (written): due 90 days before performance test at an increased process throughput rate. 2. The Permittee may exceed the existing process throughput limit upon MPCA receipt of the notification of a performance test at a higher process throughput (required by item 1 above). 3. The Permittee shall calculate actual emissions (i.e. for emission inventory or any other purpose) using the emission rate from the increased process throughput performance test retroactive to the date of the Performance Test Notification. 4. Performance Test Plan: due 30 days before performance test. The Test Plan shall identify the new proposed maximum process throughput limit. 5. Performance Test Pre Test Meeting: due 7 days before performance test. 6. Performance Test Report: due 45 days after performance test. 7. 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 [Minn. R , subp. 2, Minn. R , Minn. R , subps. 1 4, Minn. R , subps. 1 2] STRU 87 SV011 VRTO #1 Stack East Plant (CE010) Total Particulate Matter <= 0.30 grains per 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 individually to each emission unit that vents through STRU 87. [Minn. R , subp. 1(A)(1)] Total Particulate Matter <= grains per dry standard cubic foot. [Title I Condition: 40 CFR 52.21(j)(BACT) & Minn. R.

136 Permit Expires: [month day, year] Page 134 of ] Total Particulate Matter <= 5.75 pounds per hour. [Title I Condition: 40 CFR 52.21(j)(BACT) & Minn. R ] PM < 10 micron <= grains per dry standard cubic foot. [Title I Condition: 40 CFR 52.21(j)(BACT) & Minn. R ] PM < 10 micron <= 5.75 pounds per hour. [Title I Condition: 40 CFR 52.21(j)(BACT) & Minn. R ] Volatile Organic Compounds <= 8.87 pounds per hour as total mass of VOC. [Title I Condition: 40 CFR 52.21(j)(BACT) & Minn. R ] Nitrogen Oxides <= pounds per hour. This limit applies to total NOx (thermal and process NOx). [Title I Condition: 40 CFR 52.21(j)(BACT) & Minn. R ] Nitrogen Oxides <= parts per million by volume, wet gas basis. This limit applies to total NOx (thermal and process NOx). [Title I Condition: 40 CFR 52.21(j)(BACT) & Minn. R ] Carbon Monoxide <= 11.3 pounds per hour. [Title I Condition: 40 CFR 52.21(j)(BACT) & Minn. R ] Sulfur Dioxide <= 2.93 pounds per hour. [Title I Condition: Avoid major modification under 40 CFR 52.21(b)(23)(i) & Minn. R ] Opacity <= 20 percent opacity except for one six minute period per hour of not more than 60 percent opacity. This limit applies individually to each emission unit that vents through STRU 87. [Minn. R , subp. 1(A)(2)] Permitted Fuel: Natural gas only. [Title I Condition: 40 CFR 52.21(j)(BACT) & Minn. R ] POLLUTION CONTROL REQUIREMENTS Refer to TREA 45 for additional pollution control requirements. [Minn. R , subp. 2] Vent all emissions from East Plant Dryer A and Dryer B to TREA 45. The Permittee shall document periods of non operation of TREA 45 during operation of East Plant Dryer A and/or Dryer B. [Title I Condition: 40 CFR 52.21(j)(BACT) & Minn. R , Title I Condition: Avoid major source under 40 CFR 52.21(b)(1)(i) & Minn. R ] STRU 87 Operating Hours Monitoring and Recordkeeping: The Permittee shall monitor STRU 87 operating hours for use in COMG 4 HAP calculations. An 'STRU 87 operating hour' is any hour during which any process equipment is operating that vents through STRU 87. The Permittee shall monitor and keep separate records for STRU 87 operating hours when TREA 45 combustion chamber temperature is less than the required minimum (listed under TREA 45) during the operating hour.

137 Permit Expires: [month day, year] Page 135 of 243 If the Permittee only conducts daily TREA 45 temperature monitoring (and not hourly monitoring as described under TREA 45) and the monitored combustion chamber temperature is below the required minimum, all operating hours during that calendar day are recorded as TREA 45 operating below the required minimum temperature. [Minn. R , subps. 4 5, Minn. R , Title I Condition: Avoid major source under 40 CFR 63.2] Monthly Monitoring and Recordkeeping: By the 15th day of each month, the Permittee shall calculate and record the following for the previous calendar month: 1. Monthly STRU 87 operating hours when TREA 45 was operating at or above the required minimum temperature; and, 2. Monthly STRU 87 operating hours when TREA 45 was operating at less than the required minimum temperature. [Minn. R , subps. 4 5] Performance Test: due before end of each 60 months starting 02/08/2011 to measure STRU 87 PM10 emissions in gr/dscf and lb/hr, not to exceed 60 months between test dates. The performance test shall be conducted at worst case conditions as defined at Minn. R , subp. 8, using EPA Reference Methods 5 and 202, Methods 201A and 202, or other method approved by MPCA in the performance test plan approval. [Minn. R , subp. 1, Title I Condition: 40 CFR 52.21(j)(BACT) & Minn. R ] Performance Test: due before end of each 60 months starting 02/08/2011 to measure STRU 87 Total Particulate Matter emissions in gr/dscf and lb/hr, not to exceed 60 months between test dates. The performance test shall be conducted at worst case conditions as defined at Minn. R , subp. 8, using EPA Reference Methods 5 and 202, or other method approved by MPCA in the performance test plan approval. [Minn. R , subp. 1, Title I Condition: 40 CFR 52.21(j)(BACT) & Minn. R ] Performance Test: due before end of each 60 months starting 02/08/2011 to measure STRU 87 total NOx emissions on both a lbs/hour basis and a parts per million by volume on a wet basis, not to exceed 60 months between test dates. The performance test shall be conducted at worst case conditions as defined at Minn. R , subp. 8, using EPA Reference Method 7E or other method approved by MPCA in the performance test plan approval. [Minn. R , subp. 1, Title I Condition: 40 CFR 52.21(j)(BACT) & Minn. R ]

138 Permit Expires: [month day, year] Page 136 of Performance Test: due before end of each 60 months starting 09/05/2012 to measure STRU 87 SO2 emissions in lb/hr, not to exceed 60 months between test dates. The performance test shall be conducted at worst case conditions as defined at Minn. R , subp. 8, using EPA Reference Method 6C or other method approved by MPCA in the performance test plan approval. [Minn. R , subp. 1, Title I Condition: Avoid major modification under 40 CFR 52.21(b)(23)(i) & Minn. R ] Performance Test: due before end of each 60 months starting 09/05/2012 to measure STRU 87 VOC emissions on a mass basis in lb/hr, not to exceed 60 months between test dates. The performance test shall be conducted at worst case conditions as defined at Minn. R , subp. 8, using EPA Reference Method 18, 25A, 320, or other method approved by MPCA in the performance test plan approval. [Minn. R , subp. 1, Title I Condition: 40 CFR 52.21(j)(BACT) & Minn. R ] Performance Test: due before end of each 36 months starting 10/17/2007 to measure STRU 87 CO emissions in lb/hr, not to exceed 36 months between test dates. The performance test shall be conducted at worst case conditions as defined at Minn. R , subp. 8, using EPA Reference Method 10 or other method approved by MPCA in the performance test plan approval. [Minn. R , subp. 1, Title I Condition: 40 CFR 52.21(j)(BACT) & Minn. R ] Performance Test: due before end of each 60 months starting 09/05/2012 to measure STRU 87 HAP emissions, not to exceed 60 months between test dates. Testing must include all chemicals listed in Appendix D of this permit. The performance test shall be conducted at worst case conditions as defined at Minn. R , subp. 8, using EPA Reference Method 18, 320, or other method approved by MPCA in the performance test plan approval. [Minn. R , Minn. R , subp. 1, Title I Condition: Avoid major source under 40 CFR 63.2] Protocol for Re Setting the Emission Factor Used For Calculating Acetaldehyde, Acrolein, Formaldehyde, and Methanol Emissions: The Permittee shall conduct performance testing under worst case conditions (as defined at Minn. R ) that produce the maximum acetaldehyde, acrolein, formaldehyde, and methanol emissions. US E.P.A. Reference Method 18, 320, or other method approved by MPCA in the performance test plan approval shall be used to measure the emission factor for each of these HAPs as required under subject item STRU 87 in this permit. The Permittee shall report the test result in lb/hr

139 Permit Expires: [month day, year] Page 137 of 243 in the performance test report required by Minn. R , subp. 1. The emission factors used for calculating acetaldehyde, acrolein, formaldehyde, and methanol emissions shall be reset to the 3 hour average emission rate in lb/hr, measured during the most recent MPCA approved acetaldehyde, acrolein, formaldehyde, and methanol emission factor performance test. The new emission factor used for calculating acetaldehyde, acrolein, formaldehyde, and methanol emissions determined using this Protocol shall be effective upon receipt of the Notice of Verification (NOV) letter or equivalent MPCA correspondence, that approves the test results and shall be incorporated into the permit during the next permit amendment. [Minn. R , Title I Condition: Avoid major source under 40 CFR 63.2] The Permittee must apply for and obtain a major permit amendment if the Permittee wishes to deviate from the Protocol for Re setting the Emission Factor Used for Calculating Acetaldehyde, Acrolein, Formaldehyde, and Methanol Emissions established by this permit. [Minn. R , subp. 1] Notwithstanding the Protocol detailed above, the MPCA reserves the right to set operational limits and requirements as allowed under Minn. R If the MPCA sets limits, the new limits shall be implemented upon receipt of the NOV letter (or equivalent MPCA correspondence), that notifies the Permittee of preliminary approval. The limits set according to Minn. R are final upon issuance of a permit amendment incorporating the change. [Minn. R ] Thermal Oxidizer Burnouts and Other Maintenance Activities: During thermal oxidizer malfunctions and any other maintenance for which the manufacturer recommends dryer emissions bypass the thermal oxidizer, the dryer shall be shutdown. Wet DDGS shall be stored and handled to minimize VOC emissions and odors during these maintenance activities. The Permittee shall maintain a record of such maintenance activities in the O & M plan for TREA 45. [Minn. R , subp. 14, Minn. R , subp. 16(J)] Thermal Oxidizer Breakdown: In the event of a breakdown of the thermal oxidizer, the Permittee shall stop feed into the dryer as soon as the breakdown is discovered. Dryer operation may continue as long as necessary to empty the dryer. The Permittee shall also submit the notification required by Minn. R , subp. 2, if required. [Minn. R , subp. 2]

140 Permit Expires: [month day, year] Page 138 of Wet cake storage limitation: When wet cake by product is produced, it will be stored for no longer than 72 hours on site unless the outside temperature is less than 55 degrees (daily maximum). In all cases, the wet cake will be moved off site as soon as possible. [Minn. R , subp. 2] The Permittee shall not operate STRU 87 and STRU 9 simultaneously. STRU 9 shall replace STRU 87 at the facility upon initial startup of STRU 9. [Minn. R , subp. 2] TREA 3 CE013 Fabric Filter Low Temperature, i.e., T<180 Degrees F The Permittee shall vent emissions from EQUI 55 to TREA 3, and then to TREA 29 whenever EQUI 22 (DDGS Dryer #3) is operating. When EQUI 22 is operating, EQUI 55 shall not vent through STRU 78, except in an emergency. Venting EQUI 55 emissions through STRU 78 when EQUI 22 is operating is a reportable deviation that must be included in the Semi annual Deviations Report required under the Total Facility subject item in this permit. [Title I Condition: 40 CFR 52.21(j)(BACT) & Minn. R ] The Permittee shall operate and maintain fabric filter TREA 3 such that it achieves an overall control efficiency for Total Particulate Matter >= 99 percent control efficiency. [Title I Condition: 40 CFR 52.21(j)(BACT) & Minn. R ] The Permittee shall operate and maintain fabric filter TREA 3 such that it achieves an overall control efficiency for PM < 10 micron >= 99 percent control efficiency. [Minn. R , subp. 7(A), 7(L), & 7(M), Minn. R , subp. 4, Minn. R , subps. 1 2, Minn. R , Minn. Stat , subd. 4a, Minn. Stat , subd. 9, Title I Condition: 40 CFR 52.21(j)(BACT) & Minn. R ] The Permittee shall operate and maintain fabric filter TREA 3 such that it achieves an overall control efficiency for PM < 2.5 micron >= 99 percent control efficiency. [Minn. R , subp. 7(A), 7(L), & 7(M), Minn. R , subp. 4, Minn. R , subps. 1 2, Minn. R , Minn. Stat , subd. 4a, Minn. Stat , subd. 9, Title I Condition: Avoid major source under 40 CFR 52.21(b)(1)(i) and Minn. R ] Operation and Maintenance of Fabric Filter: The Permittee shall operate and maintain fabric filter TREA 3 according to the control equipment manufacturer's specifications. [Minn. R , subp. 14] The Permittee shall operate and maintain the fabric filter TREA 3 in accordance with the Operation and Maintenance (O & M) Plan. The Permittee shall keep copies of the O & M Plan

141 Permit Expires: [month day, year] Page 139 of 243 available onsite for use by staff and MPCA staff. [Minn. R , subp. 14] The Permittee shall operate and maintain a bag break detection system on TREA 3 whenever TREA 3 is operating. [40 CFR 64.1, 40 CFR 64.3(b)(4), Minn. R , subp. 4, Minn. R , Title I Condition: 40 CFR 52.21(j)(BACT) & Minn. R , Title I Condition: Avoid major source under 40 CFR 52.21(b)(1)(i) and Minn. R ] 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. [40 CFR 64.1, 40 CFR 64.3(b)(4), Minn. R , subp. 14, Minn. R , subp. 2, Minn. R ] Corrective Actions: The Permittee shall take corrective action as soon as possible if any of the following conditions occur for TREA 3: the TREA 3 broken bag detector detects a broken bag on TREA 3; the fabric filter or any of its components are found during the inspections to need repair. Corrective actions shall eliminate a broken bag(s), and/or include completion of necessary repairs identified during the inspection, as applicable for TREA 3. Corrective actions include, but are not limited to, those outlined in the O & M Plan for the fabric filter. The Permittee shall keep a record of the type and date of any corrective action taken for each filter. [40 CFR 64.7(d)(1), Minn. R , subp. 14, Minn. R , subps. 4 5, Minn. R ] Documentation of Need for Improved Monitoring: If the Permittee fails to achieve compliance with an emission limitation or standard for which the monitoring did not provide an indication of an excursion or exceedance while providing valid data, or the results of compliance or performance testing document a need to modify the existing pressure drop range, the Permittee shall promptly notify the MPCA and, if necessary, submit a permit amendment application to address the necessary monitoring change. [40 CFR 64.7(e), Minn. R ] As required by 40 CFR Section 64.9(a)(2), for the Semi Annual Deviations Report required by this permit and/or the Notification of Deviations Endangering Human Health and the Environment required by this permit, as applicable, the Permittee shall include the following related to the monitoring identified as required by 40 CFR Section 64.9:

142 Permit Expires: [month day, year] Page 140 of 243 1) Summary information on the number, duration, and cause of excursions or exceedances, as applicable, and the corrective action taken; and, 2) Summary information on the number, duration, and cause for monitor downtime incidents. [40 CFR 64.9(a)(2), Minn. R ] The Permittee shall maintain records of monitoring data, monitor performance data, corrective actions taken, and other supporting information required to be maintained. The Permittee may maintain records on alternative media, such as microfilm, computer files, magnetic tape disks, or microfiche, provided that the use of such alternative media allows for expeditious inspection and review, and does not conflict with other applicable recordkeeping requirements. [40 CFR 64.9(b), Minn. R ] Continued operation. Except for monitoring malfunctions, associated repairs, and required quality assurance or control activities, the Permittee shall conduct all monitoring in continuous operation (or shall collect data at all required intervals) at all times that the pollutant specific emissions unit is operating. Data recorded during monitoring malfunctions, associated repairs, and required quality assurance or control activities shall not be used for purposes of this part, including data averages and calculations, or fulfilling a minimum data availability requirement, if applicable. A monitoring malfunction is any sudden, infrequent, not reasonably preventable failure of the monitoring to provide valid data. Monitoring failures that are caused in part by poor maintenance or careless operation are not malfunctions. [40 CFR 64.7(c), Minn. R ] Response to excursions. Upon detecting an excursion, the Permittee shall restore operation of the pollutant specific emissions unit (including the control device and associated capture system) to its normal or usual manner of operation as expeditiously as practicable in accordance with good air pollution control practices for minimizing emissions. The response shall include minimizing the period of any startup, shutdown or malfunction and taking any necessary corrective actions to restore normal operation and prevent the likely recurrence of the cause of an excursion. Such actions may include initial inspection and evaluation, recording that operations returned to normal without operator action (such as through response by a computerized distribution control system), or any necessary follow up actions to return operation to within the indicator range, designated condition, or below the applicable emission limitation or standard, as applicable. [40 CFR 64.7(d), Minn. R , subp. 14, Minn. R ]

143 Permit Expires: [month day, year] Page 141 of Quality Improvement Plan (QIP) requirements. If there is an accumulation of 9 or more excursions during a calendar year, the Permittee must develop and implement a QIP in accordance with 40 CFR 64.8(b). The QIP must be available for inspection. [40 CFR 64.8, Minn. R ] If a QIP is required, the Permittee shall develop and implement the QIP as expeditiously as practicable and shall notify the MPCA if the period for completing the improvements contained in the QIP exceeds 180 days from the date on which the need to implement the QIP was determined. [40 CFR 64.8(c), Minn. R ] Following implementation of a QIP, the Administrator or the MCPA may require that the Permittee make reasonable changes to the QIP if the QIP is found to have: (1) Failed to address the cause of the control device performance problems; or (2) Failed to provide adequate procedures for correcting control device performance problems as expeditiously as practicable in accordance with good air pollution control practices for minimizing emissions. [40 CFR 64.8(d), Minn. R ] Implementation of a QIP shall not excuse the Permittee from compliance with any existing emission limitation or standard, or any existing monitoring, testing, reporting or recordkeeping requirement that may apply. [40 CFR 64.8(e), Minn. R ] TREA 11 CE036 VRTO #1 (new) The Permittee shall operate and maintain TREA 11 such that it achieves a control efficiency for Carbon Monoxide >= 90 percent control efficiency or less than or equal to 100 ppm. [CAAA of 1990, Title I Condition: 40 CFR 52.21(j)(BACT) & Minn. R ] The Permittee shall operate and maintain TREA 11 such that it achieves a control efficiency for Total Particulate Matter >= 90 percent control efficiency. [Title I Condition: 40 CFR 52.21(j)(BACT) & Minn. R ] The Permittee shall operate and maintain TREA 11 such that it achieves a control efficiency for PM < 10 micron >= 90 percent control efficiency. [Title I Condition: 40 CFR 52.21(j)(BACT) & Minn. R ] The Permittee shall operate and maintain TREA 11 such that it achieves an overall control efficiency for PM < 2.5 micron >= 90 percent control efficiency. [Title I Condition: Avoid major source under 40 CFR 52.21(b)(1)(i) and Minn. R ] The Permittee shall operate and maintain TREA 11 such that it achieves a control efficiency for Volatile Organic Compounds >= 98 percent control efficiency or no higher than 10 ppm outlet VOC concentration as total mass of VOC. [Title I

144 Permit Expires: [month day, year] Page 142 of 243 Condition: 40 CFR 52.21(j)(BACT) & Minn. R , Title I Condition: Avoid major source under 40 CFR 52.21(b)(1)(i) & Minn. R ] The Permittee shall operate and maintain TREA 11 such that it achieves a control efficiency for Acetaldehyde >= 95 percent control efficiency. [Minn. R , Title I Condition: Avoid major source under 40 CFR 63.2] The Permittee shall operate and maintain TREA 11 such that it achieves a control efficiency for Acrolein >= 95 percent control efficiency. [Minn. R , Title I Condition: Avoid major source under 40 CFR 63.2] The Permittee shall operate and maintain TREA 11 such that it achieves a control efficiency for Formaldehyde >= 95 percent control efficiency. [Minn. R , Title I Condition: Avoid major source under 40 CFR 63.2] The Permittee shall operate and maintain TREA 11 such that it achieves a control efficiency for Methanol >= 95 percent control efficiency. [Minn. R , Title I Condition: Avoid major source under 40 CFR 63.2] Temperature >= 1600 degrees Fahrenheit as a 3 hour rolling average at the combustion chamber outlet, unless a new limit 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 limit shall be implemented upon receipt of the Notice of Compliance letter granting preliminary approval. The limit is final upon issuance of a permit amendment incorporating the change. If the 3 hour rolling average temperature is below the minimum temperature limit, the VOC used during that time shall be considered uncontrolled until the average temperature is above the minimum temperature limit. This shall be reported as a deviation. [Minn. R , Title I Condition: 40 CFR 52.21(j)(BACT) & Minn. R , Title I Condition: Avoid major source under 40 CFR 52.21(b)(1)(i) & Minn. R , Title I Condition: Avoid major source under 40 CFR 63.2] The Permittee shall operate and maintain the thermal oxidizer any time that any process equipment controlled by the thermal oxidizer is in operation. The Permittee shall document periods of non operation of the control equipment. [Minn. R , Title I Condition: 40 CFR 52.21(j)(BACT) & Minn. R , Title I Condition: Avoid major source under 40 CFR 52.21(b)(1)(i) & Minn. R , Title I Condition: Avoid major source under 40 CFR 63.2] The Permittee shall operate and maintain the thermal oxidizer in accordance with the Operation and Maintenance (O & M) Plan. The Permittee shall keep copies of the O & M Plan available onsite for use by staff and MPCA staff. [Minn. R , subp. 14]

145 Permit Expires: [month day, year] Page 143 of Monitoring Equipment: The Permittee shall install and maintain a thermocouple to conduct TREA 11 temperature monitoring required by this permit. The monitoring equipment must be installed, in use, and properly maintained whenever operation of the monitored control equipment is required. [40 CFR 64.7(b), Minn. R , subp. 4, Minn. R ] The Permittee shall maintain and operate a thermocouple monitoring device that continuously indicates and records the TREA 11 combustion chamber temperature. The monitoring device shall have a margin of error less than the greater of +/ 0.75 percent of the temperature being measured or +/ 2.5 degrees Celsius (+/ 4.5 degrees Fahrenheit). The recording device shall also calculate the three hour rolling average TREA 11 combustion chamber temperature. Recorded values below the minimum temperature specified in this permit for TREA 11 are deviations as defined by Minn. R , subp. 8a. The Permittee may elect to monitor and record TREA 11 combustion chamber temperature on an hourly basis for determining operating hours when TREA 11 is operating below the required minimum temperature (for use in STRU 9 operating hours recordkeeping for when TREA 11 is operating below the required minimum temperature). [40 CFR 64.3(b)(4)(ii), Minn. R , subps. 4 5, Minn. R ] Daily Monitoring: The Permittee shall physically verify the operation of the TREA 11 temperature recording device at least once each operating day to verify that it is working and recording properly. The Permittee shall maintain a written record of the daily verifications. [40 CFR 64.3(b), Minn. R , subps. 4 5, Minn. R , Minn. R , Title I Condition: 40 CFR 52.21(j)(BACT) & Minn. R , Title I Condition: Avoid major source under 40 CFR 52.21(b)(1)(i) & Minn. R , Title I Condition: Avoid major source under 40 CFR 63.2] The Permittee shall maintain a continuous hard copy readout or computer disk file of the temperature readings and calculated three hour rolling average temperatures for the TREA 11 combustion chamber. [40 CFR 64.3, 40 CFR 64.9, Minn. R , subps. 4 5, Minn. R , Minn. R , Title I Condition: 40 CFR 52.21(j)(BACT) & Minn. R , Title I Condition: Avoid major source under 40 CFR 52.21(b)(1)(i) & Minn. R , Title I Condition: Avoid major source under 40 CFR 63.2] Quarterly Inspections: At least once per calendar quarter, or as required by the manufacturer, the Permittee shall inspect the control equipment internal and external system components,

146 Permit Expires: [month day, year] Page 144 of 243 including but not limited to the refractory, heat exchanger, and electrical systems. The Permittee shall maintain a written record of the inspection and any corrective actions taken resulting from the inspection. [40 CFR 64.3, Minn. R , subp. 14, Minn. R , subps. 4 5, Minn. R ] Annual Calibration: The Permittee shall calibrate the TREA 11 temperature monitor at least annually and shall maintain a written record of the calibration and any action resulting from the calibration. [40 CFR 64.3, Minn. R , subp. 14, Minn. R , subps. 4 5, Minn. R ] Corrective Actions: If the TREA 11 temperature is below the minimum specified by this permit or if TREA 11 or any of its components are found during the inspections to need repair, the Permittee shall take corrective action as soon as possible. Corrective actions shall return the temperature to at least the permitted minimum 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 thermal oxidizer. The Permittee shall keep a record of the type and date of any corrective action taken. [40 CFR 64.7(d)(1), Minn. R , subp. 14, Minn. R , subps. 4 5, Minn. R ] Documentation of Need for Improved Monitoring: If the Permittee fails to achieve compliance with an emission limitation or standard for which the monitoring did not provide an indication of an excursion or exceedance while providing valid data, or the results of compliance or performance testing document a need to modify the existing pressure drop range, the Permittee shall promptly notify the MPCA and, if necessary, submit a permit amendment application to address the necessary monitoring change. [40 CFR 64.7(e), Minn. R ] As required by 40 CFR Section 64.9(a)(2), for the Semi Annual Deviations Report and/or the Notification of Deviations Endangering Human Health and the Environment requirement in the Total Facility subject item of this permit, as applicable, the Permittee shall include the following related to the monitoring identified as required by 40 CFR pt. 64: 1) Summary information on the number, duration, and cause of excursions or exceedances, as applicable, and the corrective action taken; and, 2) Summary information on the number, duration, and cause for monitor downtime incidents. [40 CFR 64.9(a)(2), Minn. R ] The Permittee shall maintain records of monitoring data,

147 Permit Expires: [month day, year] Page 145 of 243 monitor performance data, corrective actions taken, and other supporting information required to be maintained. The Permittee may maintain records on alternative media, such as microfilm, computer files, magnetic tape disks, or microfiche, provided that the use of such alternative media allows for expeditious inspection and review, and does not conflict with other applicable recordkeeping requirements. [40 CFR 64.9(b), Minn. R ] Continued operation. Except for monitoring malfunctions, associated repairs, and required quality assurance or control activities, the Permittee shall conduct all monitoring in continuous operation (or shall collect data at all required intervals) at all times that the pollutant specific emissions unit is operating. Data recorded during monitoring malfunctions, associated repairs, and required quality assurance or control activities shall not be used for purposes of this part, including data averages and calculations, or fulfilling a minimum data availability requirement, if applicable. A monitoring malfunction is any sudden, infrequent, not reasonably preventable failure of the monitoring to provide valid data. Monitoring failures that are caused in part by poor maintenance or careless operation are not malfunctions. [40 CFR 64.7(c), Minn. R ] Response to excursions. Upon detecting an excursion, the Permittee shall restore operation of the pollutant specific emissions unit (including the control device and associated capture system) to its normal or usual manner of operation as expeditiously as practicable in accordance with good air pollution control practices for minimizing emissions. The response shall include minimizing the period of any startup, shutdown or malfunction and taking any necessary corrective actions to restore normal operation and prevent the likely recurrence of the cause of an excursion. Such actions may include initial inspection and evaluation, recording that operations returned to normal without operator action (such as through response by a computerized distribution control system), or any necessary follow up actions to return operation to within the indicator range, designated condition, or below the applicable emission limitation or standard, as applicable. [40 CFR 64.7(d), Minn. R , subp. 14, Minn. R ] Quality Improvement Plan (QIP) requirements. If there is an accumulation of 9 or more excursions during a calendar year, the Permittee must develop and implement a QIP in accordance with 40 CFR 64.8(b). The QIP must be available for inspection. [40 CFR 64.8, Minn. R ] If a QIP is required, the Permittee shall develop and implement the QIP as expeditiously as practicable and shall notify the MPCA if the period for completing the improvements

148 Permit Expires: [month day, year] Page 146 of 243 contained in the QIP exceeds 180 days from the date on which the need to implement the QIP was determined. [40 CFR 64.8(c), Minn. R ] Following implementation of a QIP, the Administrator or the MCPA may require that the Permittee make reasonable changes to the QIP if the QIP is found to have: (1) Failed to address the cause of the control device performance problems; or (2) Failed to provide adequate procedures for correcting control device performance problems as expeditiously as practicable in accordance with good air pollution control practices for minimizing emissions. [40 CFR 64.8(d), Minn. R ] Implementation of a QIP shall not excuse the Permittee from compliance with any existing emission limitation or standard, or any existing monitoring, testing, reporting or recordkeeping requirement that may apply. [40 CFR 64.8(e), Minn. R ] TREA 12 CE037 Fabric Filter Low Temperature, i.e., T<180 Degrees F Pressure Drop >= 0.5 and <= 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 MPCAapproved 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. The Permittee shall record the pressure drop at least once every 24 hours when in operation. [Title I Condition: Avoid major source under 40 CFR 52.21(b)(1)(i) and Minn. R ] The Permittee shall operate and maintain fabric filter TREA 12 such that it achieves an overall control efficiency for Total Particulate Matter >= 99.0 percent control efficiency. [Title I Condition: Avoid major source under 40 CFR 52.21(b)(1)(i) and Minn. R ] The Permittee shall operate and maintain fabric filter TREA 12 such that it achieves an overall control efficiency for PM < 10 micron >= 99.0 percent control efficiency. [Title I Condition: Avoid major source under 40 CFR 52.21(b)(1)(i) and Minn. R ] The Permittee shall operate and maintain fabric filter TREA 12 such that it achieves an overall control efficiency for PM < 2.5 micron >= 99.0 percent control efficiency. [Title I Condition: Avoid major source under 40 CFR 52.21(b)(1)(i) and Minn. R.

149 Permit Expires: [month day, year] Page 147 of ] The control equipment is considered listed control equipment under Minn. R to The Permittee shall vent emissions from EQUI 163 to TREA 12 whenever EQUI 163 operates, and operate and maintain TREA 12 at all times that any emissions are vented to TREA 12. The Permittee shall document periods of non operation of the control equipment. [Minn. R , subp. 14, Minn. R , subp. 2, Title I Condition: Avoid major source under 40 CFR 52.21(b)(1)(i) and Minn. R ] Operation and Maintenance of Fabric Filter: The Permittee shall operate and maintain fabric filter TREA 12 according to the control equipment manufacturer's specifications. [Minn. R , subp. 14] The Permittee shall operate and maintain fabric filter TREA 12 in accordance with the Operation and Maintenance (O & M) Plan. The Permittee shall keep copies of the O & M Plan available onsite for use by staff and MPCA staff. [Minn. R , subp. 14] Daily Inspections: The Permittee shall do the following, once every 24 hours when in operation: 1) Inspect the fabric filter stack STRU 10 for any visible emissions during daylight hours, except during inclement weather. 2) During inclement weather, read and record the pressure drop across the fabric filter. [Minn. R , subps. 4 5, Minn. R , Title I Condition: Avoid major source under 40 CFR 52.21(b)(1)(i) & Minn. R ] Recordkeeping of Visible Emissions and Pressure Drop: At least once during every 24 hour period that any associated emissions are vented to the fabric filter, 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. Recorded values outside the range specified in this permit are considered Deviations as defined by Minn. R , subp. 8a. [Minn. R , subps. 4 5, Minn. R , Title I Condition: Avoid major source under 40 CFR 52.21(b)(1)(i) and Minn. R ] Pressure Drop: 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 filter is in operation. This includes, but is not limited to, maintaining necessary parts for routine repairs. [Minn. R , subp. 3] Corrective Actions: The Permittee shall take corrective action as soon as possible if any of the following conditions occur:

150 Permit Expires: [month day, year] Page 148 of 243 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 return the pressure drop to within the permitted range, eliminate visible emissions, 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 fabric filter. The Permittee shall keep a record of the type and date of any corrective action taken for each filter. [Minn. R , subp. 14, Minn. R , subps. 4 5] TREA 14 CE035 Fabric Filter Low Temperature, i.e., T<180 Degrees F Pressure Drop >= 0.5 and <= 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 MPCAapproved 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. The Permittee shall record the pressure drop at least once every 24 hours when in operation. [Title I Condition: 40 CFR 52.21(j)(BACT) & Minn. R ] The Permittee shall operate and maintain fabric filter TREA 14 such that it achieves an overall control efficiency for Total Particulate Matter >= 99.0 percent control efficiency. [Title I Condition: 40 CFR 52.21(j)(BACT) & Minn. R ] The Permittee shall operate and maintain fabric filter TREA 14 such that it achieves an overall control efficiency for PM < 10 micron >= 99.0 percent control efficiency. [Title I Condition: 40 CFR 52.21(j)(BACT) & Minn. R ] The Permittee shall operate and maintain fabric filter TREA 14 such that it achieves an overall control efficiency for PM < 2.5 micron >= 99.0 percent control efficiency. [Title I Condition: Avoid major source under 40 CFR 52.21(b)(1)(i) and Minn. R ] The control equipment is considered listed control equipment under Minn. R to The Permittee shall vent emissions from EQUI 24 and 25, to TREA 14 whenever the listed EQUIs operate, and operate and maintain TREA 14 at all

151 Permit Expires: [month day, year] Page 149 of 243 times that any emissions are vented to TREA 14. The Permittee shall document periods of non operation of the control equipment. [Minn. R , subp. 14, Minn. R , subp. 2, Title I Condition: Avoid major source under 40 CFR 52.21(b)(1)(i) and Minn. R ] Operation and Maintenance of Fabric Filter: The Permittee shall operate and maintain fabric filter TREA 14 according to the control equipment manufacturer's specifications. [Minn. R , subp. 14] The Permittee shall operate and maintain fabric filter TREA 14 in accordance with the Operation and Maintenance (O & M) Plan. The Permittee shall keep copies of the O & M Plan available onsite for use by staff and MPCA staff. [Minn. R , subp. 14] Daily Inspections: The Permittee shall do the following, once every 24 hours when in operation: 1) Inspect the fabric filter stack STRU 7 for any visible emissions during daylight hours, except during inclement weather. 2) During inclement weather, read and record the pressure drop across the fabric filter. [Minn. R , subps. 4 5, Title I Condition: 40 CFR 52.21(j)(BACT) & Minn. R ] Recordkeeping of Visible Emissions and Pressure Drop: At least once during every 24 hour period that any associated emissions are vented to the fabric filter, 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. Recorded values outside the range specified in this permit are considered Deviations as defined by Minn. R , subp. 8a. [Minn. R , subps. 4 5, Title I Condition: 40 CFR 52.21(j)(BACT) & Minn. R ] Pressure Drop: 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 filter is in operation. This includes, but is not limited to, maintaining necessary parts for routine repairs. [Minn. R , subp. 3] Corrective Actions: The Permittee shall take corrective action as soon as possible if any of the following conditions 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.

152 Permit Expires: [month day, year] Page 150 of 243 Corrective actions shall return the pressure drop to within the permitted range, eliminate visible emissions, 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 fabric filter. The Permittee shall keep a record of the type and date of any corrective action taken for each filter. [Minn. R , subp. 14, Minn. R , subps. 4 5] TREA 15 CE019 Ethanol Loading Rack Flare # TREA 15 is Flare #2 and controls EQUI 53 (Ethanol Loadout #2 West Plant (Railcar)). [Minn. R , subp. 2] The Permittee shall operate and maintain TREA 15 such that it achieves a control efficiency for Volatile Organic Compounds >= 98 percent control efficiency or less than or equal to 20 ppm VOC if the inlet is less than 200 ppm VOC as total mass of VOC. [Title I Condition: 40 CFR 52.21(j)(BACT) & Minn. R , Title I Condition: Avoid major source under 40 CFR 52.21(b)(1)(i) & Minn. R ] Opacity: not greater than 0 percent opacity using a 6 minute average except for periods not to exceed 5 minutes in any 2 consecutive hours. [Title I Condition: 40 CFR 52.21(j)(BACT) & Minn. R ] Fuel Burned: Natural gas only for TREA 15. [Minn. R , subp. 2, Minn. Stat , subd. 4a] If the flare (TREA 15) is steam assisted or air assisted, the flare shall be fueled with gas with a minimum heat content of 300 Btu/scf. If the flare is nonassisted, the flare shall be fueled with gas with a minimum heat content of 200 Btu/scf. [Minn. R , subp. 14, Title I Condition: Avoid major source under 40 CFR 52.21(b)(1)(i) & Minn. R ] The Permittee shall operate and maintain TREA 15 at all times that EQUI 53 is in operation. [Minn. R , subp. 16(J), Title I Condition: Avoid major source under 40 CFR 52.21(b)(1)(i) & Minn. R ] Vent all emissions from West Plant Loading Rack EQUI 53 to flare TREA 15. The Permittee shall document periods of nonoperation of TREA 15 during operation of the West Plant Loading Rack. [Title I Condition: 40 CFR 52.21(j)(BACT) & Minn. R , Title I Condition: Avoid major source under 40 CFR 52.21(b)(1)(i) & Minn. R ] The flare shall be operated with a flame present at all times. Flame presence shall be monitored using a thermocouple or any other equivalent device. [Minn. R , subp. 14, Minn. R , subp. 4, Title I Condition: Avoid major source under 40 CFR 52.21(b)(1)(i) & Minn. R ] The Permittee shall operate and maintain the flare (TREA 15) in accordance with the Operation and Maintenance (O & M)

153 Permit Expires: [month day, year] Page 151 of 243 Plan. The Permittee shall keep copies of the O & M plan available on site for use by staff and MPCA staff. [Minn. R , subp. 14] The Permittee shall calibrate or replace the thermocouple or other measurement device annually. The Permittee shall maintain a written record of this inspection and calibration. [Minn. R , subp. 14, Minn. R , subps. 4 5] Monitoring Equipment: The Permittee shall install and maintain thermocouples to monitor the presence of a pilot flame. The monitoring equipment must be installed, in use, and properly maintained whenever operation of the monitored control equipment is required. [Minn. R , subp. 4] Quarterly Inspections: At least once per calendar quarter, the Permittee shall inspect the flare internal and external system components, including but not limited to the refractory and electrical systems. The Permittee shall maintain a written record of the inspection and any corrective actions taken resulting from the inspection. [Minn. R , subp. 14, Minn. R , subps. 4 5] Corrective Actions: If a pilot flame is not present or if the flare or any of its components are found during the inspections to need repair, the Permittee shall take corrective action as soon as possible. Corrective action shall result in return to operation of the pilot flame 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 flare. The Permittee shall keep a record of the type and date of any corrective action taken. [Minn. R , subp. 14, Minn. R , subps. 4 5] Recordkeeping: The Permittee shall maintain written records of the presence of the flame and any malfunction of the flare. [Minn. R , subp. 14, Minn. R , subp. 5, Title I Condition: Avoid major source under 40 CFR 52.21(b)(1)(i) & Minn. R ] TREA 16 CE018 Ethanol Loading Rack Flare # TREA 16 is Flare #1 and controls EQUI 5 (Ethanol Loadout #1 East Plant (Trucks)). [Minn. R , subp. 2] The Permittee shall operate and maintain TREA 16 such that it achieves a control efficiency for Volatile Organic Compounds >= 98 percent control efficiency or less than or equal to 20 ppm VOC if the inlet is less than 200 ppm VOC as total mass of VOC. [Title I Condition: 40 CFR 52.21(j)(BACT) & Minn. R ] Opacity: not greater than 0 percent opacity using a 6 minute average except for periods not to exceed 5 minutes in any 2

154 Permit Expires: [month day, year] Page 152 of 243 consecutive hours. [Title I Condition: 40 CFR 52.21(j)(BACT) & Minn. R ] Visible Emissions: The Permittee shall check the loadout flare for any visible emissions once each day of operation during daylight hours while the flare is operating. The Permittee shall determine the presence of visible emission using Reference Method 22 when requested by the Commissioner. [40 CFR 64.3, Minn. R , subp. 14, Minn. R , subp. 2, Minn. R , subp. 4, Minn. R , Minn. R , subp. 1] Fuel Burned: Natural gas only for TREA 16. [Minn. R , subp. 2, Minn. Stat , subd. 4a] The flare shall be operated with a flame present at all times. [40 CFR 64.3, Minn. R , subp. 14, Minn. R , subp. 4, Minn. R , Title I Condition: Avoid major source under 40 CFR 52.21(b)(1)(i) & Minn. R ] If the flare (TREA 16) is steam assisted or air assisted, the flare shall be fueled with gas with a minimum heat content of 300 Btu/scf. If the flare is nonassisted, the flare shall be fueled with gas with a minimum heat content of 200 Btu/scf. [40 CFR 64.3, Minn. R , subp. 14, Minn. R , subp. 16(J), Minn. R , Title I Condition: Avoid major source under 40 CFR 52.21(b)(1)(i) & Minn. R ] The Permittee shall operate and maintain TREA 16 at all times, including startup and shutdown, that EQUI 5 is in operation. The Permittee shall maintain and operate the flare in a manner consistent with good air pollution control practice for minimizing emissions. [Minn. R , subp. 14, Minn. R , subp. 16(J)] Vent all emissions from East Plant Loading Rack EQUI 5 to flare TREA 16. The Permittee shall document periods of nonoperation of TREA 16 during operation of the East Plant Loading Rack. [Title I Condition: 40 CFR 52.21(j)(BACT) & Minn. R , Title I Condition: Avoid major source under 40 CFR 52.21(b)(1)(i) & Minn. R ] The Permittee shall operate and maintain the flare (TREA 16) in accordance with the Operation and Maintenance (O & M) Plan. The Permittee shall keep copies of the O & M plan available on site for use by staff and MPCA staff. [Minn. R , subp. 14] Monitoring Equipment: The Permittee shall install and maintain thermocouples to monitor the presence of a TREA 16 pilot flame. The monitoring equipment must be installed, in use, and properly maintained whenever TREA 16 operation is required. In place of monitoring for the presence of a TREA 16 pilot flame, the Permittee shall continuously maintain the EQUI 5

155 Permit Expires: [month day, year] Page 153 of 243 loading rack system design in a manner where the EQUI 5 ethanol loadout pumps will not operate if the TREA 16 pilot flame is not present. [40 CFR 64.3(b)(4)(ii), 40 CFR 64.7(b), Minn. R , subp. 4, Minn. R ] The Permittee shall calibrate or replace the thermocouple or other measurement device annually. The Permittee shall maintain a written record of this inspection and calibration. [40 CFR 64.3, Minn. R , subps. 4 5, Minn. R ] Quarterly Inspections: At least once per calendar quarter, the Permittee shall inspect the flare internal and external system components, including but not limited to the refractory and electrical systems. The Permittee shall maintain a written record of the inspection and any corrective actions taken resulting from the inspection. [40 CFR 64.3, Minn. R , subp. 14, Minn. R , subps. 4 5, Minn. R ] Corrective Actions: If a pilot flame is not present or if the flare or any of its components are found during the inspections to need repair, the Permittee shall take corrective action as soon as possible. Corrective action shall result in return to operation of the pilot flame 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 flare. The Permittee shall keep a record of the type and date of any corrective action taken. [40 CFR 64.7(d)(1), Minn. R , subp. 14, Minn. R , subps. 4 5, Minn. R ] Documentation of Need for Improved Monitoring: If the Permittee fails to achieve compliance with an emission limitation or standard for which the monitoring did not provide an indication of an excursion or exceedance while providing valid data, or the results of compliance or performance testing document a need to modify the existing pressure drop range, the Permittee shall promptly notify the MPCA and, if necessary, submit a permit amendment application to address the necessary monitoring change. [40 CFR 64.7(e), Minn. R ] As required by 40 CFR Section 64.9(a)(2), for the Semi Annual Deviations Report and/or the Notification of Deviations Endangering Human Health and the Environment requirement in the Total Facility subject item of this permit, as applicable, the Permittee shall include the following related to the monitoring identified as required by 40 CFR pt. 64: 1) Summary information on the number, duration, and cause of excursions or exceedances, as applicable, and the corrective action taken; and,

156 Permit Expires: [month day, year] Page 154 of 243 2) Summary information on the number, duration, and cause for monitor downtime incidents. [40 CFR 64.9(a)(2), Minn. R ] The Permittee shall maintain records of monitoring data, monitor performance data, corrective actions taken, and other supporting information required to be maintained. The Permittee may maintain records on alternative media, such as microfilm, computer files, magnetic tape disks, or microfiche, provided that the use of such alternative media allows for expeditious inspection and review, and does not conflict with other applicable recordkeeping requirements. [40 CFR 64.9(b), Minn. R ] Continued operation. Except for monitoring malfunctions, associated repairs, and required quality assurance or control activities, the Permittee shall conduct all monitoring in continuous operation (or shall collect data at all required intervals) at all times that the pollutant specific emissions unit is operating. Data recorded during monitoring malfunctions, associated repairs, and required quality assurance or control activities shall not be used for purposes of this part, including data averages and calculations, or fulfilling a minimum data availability requirement, if applicable. A monitoring malfunction is any sudden, infrequent, not reasonably preventable failure of the monitoring to provide valid data. Monitoring failures that are caused in part by poor maintenance or careless operation are not malfunctions. [40 CFR 64.7(c), Minn. R ] Response to excursions. Upon detecting an excursion, the Permittee shall restore operation of the pollutant specific emissions unit (including the control device and associated capture system) to its normal or usual manner of operation as expeditiously as practicable in accordance with good air pollution control practices for minimizing emissions. The response shall include minimizing the period of any startup, shutdown or malfunction and taking any necessary corrective actions to restore normal operation and prevent the likely recurrence of the cause of an excursion. Such actions may include initial inspection and evaluation, recording that operations returned to normal without operator action (such as through response by a computerized distribution control system), or any necessary follow up actions to return operation to within the indicator range, designated condition, or below the applicable emission limitation or standard, as applicable. [40 CFR 64.7(d), Minn. R , subp. 14, Minn. R ] Quality Improvement Plan (QIP) requirements. If there is an accumulation of 9 or more excursions during a calendar year, the Permittee must develop and implement a QIP in accordance with 40 CFR 64.8(b). The QIP must be available for

157 Permit Expires: [month day, year] Page 155 of 243 inspection. [40 CFR 64.8, Minn. R ] If a QIP is required, the Permittee shall develop and implement the QIP as expeditiously as practicable and shall notify the MPCA if the period for completing the improvements contained in the QIP exceeds 180 days from the date on which the need to implement the QIP was determined. [40 CFR 64.8(c), Minn. R ] Following implementation of a QIP, the Administrator or the MCPA may require that the Permittee make reasonable changes to the QIP if the QIP is found to have: (1) Failed to address the cause of the control device performance problems; or (2) Failed to provide adequate procedures for correcting control device performance problems as expeditiously as practicable in accordance with good air pollution control practices for minimizing emissions. [40 CFR 64.8(d), Minn. R ] Implementation of a QIP shall not excuse the Permittee from compliance with any existing emission limitation or standard, or any existing monitoring, testing, reporting or recordkeeping requirement that may apply. [40 CFR 64.8(e), Minn. R ] Recordkeeping: The Permittee shall maintain written records of the presence of the flame and any malfunction of the flare. [Minn. R , subp. 14, Minn. R , subp. 5, Title I Condition: Avoid major source under 40 CFR 52.21(b)(1)(i) & Minn. R ] TREA 29 CE012 VRTO No The Permittee shall operate and maintain TREA 29 such that it achieves a control efficiency for Carbon Monoxide >= 90 percent control efficiency or less than or equal to 100 ppm. [Title I Condition: 40 CFR 52.21(j)(BACT) & Minn. R ] The Permittee shall operate and maintain TREA 29 such that it achieves a control efficiency for Total Particulate Matter >= 90 percent control efficiency. [Title I Condition: 40 CFR 52.21(j)(BACT) & Minn. R ] The Permittee shall operate and maintain TREA 29 such that it achieves a control efficiency for PM < 10 micron >= 90 percent control efficiency. [Title I Condition: 40 CFR 52.21(j)(BACT) & Minn. R ] The Permittee shall operate and maintain TREA 29 such that it achieves a control efficiency for PM < 2.5 micron >= 90 percent control efficiency. [Title I Condition: Avoid major source under 40 CFR 52.21(b)(1)(i) and Minn. R ] The Permittee shall operate and maintain TREA 29 such that it achieves a control efficiency for Volatile Organic Compounds >= 95 percent control efficiency or no higher than 10 ppm outlet VOC concentration as total mass of VOC. [Title I

158 Permit Expires: [month day, year] Page 156 of 243 Condition: 40 CFR 52.21(j)(BACT) & Minn. R ] The Permittee shall operate and maintain TREA 29 such that it achieves a control efficiency for Acetaldehyde >= 95 percent control efficiency. [Minn. R , Title I Condition: Avoid major source under 40 CFR 63.2] The Permittee shall operate and maintain TREA 29 such that it achieves a control efficiency for Acrolein >= 95 percent control efficiency. [Minn. R , Title I Condition: Avoid major source under 40 CFR 63.2] The Permittee shall operate and maintain TREA 29 such that it achieves a control efficiency for Formaldehyde >= 95 percent control efficiency. [Minn. R , Title I Condition: Avoid major source under 40 CFR 63.2] The Permittee shall operate and maintain TREA 29 such that it achieves a control efficiency for Methanol >= 95 percent control efficiency. [Minn. R , Title I Condition: Avoid major source under 40 CFR 63.2] Temperature >= 1605 degrees Fahrenheit as a 3 hour rolling average at the combustion chamber outlet, unless a new limit 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 limit shall be implemented upon receipt of the Notice of Compliance letter granting preliminary approval. The limit is final upon issuance of a permit amendment incorporating the change. If the 3 hour rolling average temperature is below the minimum temperature limit, the VOC used during that time shall be considered uncontrolled until the average temperature is above the minimum temperature limit. This shall be reported as a deviation. [Minn. R , Title I Condition: 40 CFR 52.21(j)(BACT) & Minn. R , Title I Condition: Avoid major source under 40 CFR 63.2] The Permittee shall operate and maintain TREA 29 any time that any process equipment controlled by TREA 29 is in operation. The Permittee shall document periods of nonoperation of the control equipment. [Minn. R , Title I Condition: 40 CFR 52.21(j)(BACT) & Minn. R , Title I Condition: Avoid major source under 40 CFR 63.2] The Permittee shall operate and maintain TREA 29 in accordance with the Operation and Maintenance (O & M) Plan. The Permittee shall keep copies of the O & M Plan available onsite for use by staff and MPCA staff. [Minn. R , subp. 14] Monitoring Equipment: The Permittee shall install and maintain a thermocouple to conduct TREA 29 temperature monitoring required by this permit. The monitoring equipment must be installed, in use, and properly maintained whenever operation of the monitored control equipment is required. [40 CFR 64.7(b), Minn. R , subp. 4, Minn. R ]

159 Permit Expires: [month day, year] Page 157 of The Permittee shall maintain and operate a thermocouple monitoring device that continuously indicates and records the TREA 29 combustion chamber temperature. The monitoring device shall have a margin of error less than the greater of +/ 0.75 percent of the temperature being measured or +/ 2.5 degrees Celsius (+/ 4.5 degrees Fahrenheit). The recording device shall also calculate the three hour rolling average TREA 29 combustion chamber temperature. Recorded values below the minimum temperature specified in this permit for TREA 29 are deviations as defined by Minn. R , subp. 8a. The Permittee may elect to monitor and record TREA 29 combustion chamber temperature on an hourly basis for determining operating hours when TREA 29 is operating below the required minimum temperature (for use in STRU 70 operating hours recordkeeping for when TREA 29 is operating below the required minimum temperature). [40 CFR 64.3(b)(4)(ii), Minn. R , subps. 4 5, Minn. R ] Daily Monitoring: The Permittee shall physically verify the operation of the TREA 29 temperature recording device at least once each operating day to verify that it is working and recording properly. The Permittee shall maintain a written record of the daily verifications. [40 CFR 64.3(b), Minn. R , subps. 4 5, Minn. R , Minn. R , Title I Condition: 40 CFR 52.21(j)(BACT) & Minn. R , Title I Condition: Avoid major source under 40 CFR 63.2] The Permittee shall maintain a continuous hard copy readout or computer disk file of the temperature readings and calculated three hour rolling average temperatures for the TREA 29 combustion chamber. [40 CFR 64.3, 40 CFR 64.9, Minn. R , subps. 4 5, Minn. R , Minn. R , Title I Condition: 40 CFR 52.21(j)(BACT) & Minn. R , Title I Condition: Avoid major source under 40 CFR 63.2] Quarterly Inspections: At least once per calendar quarter, or as required by the manufacturer, the Permittee shall inspect the control equipment internal and external system components, including but not limited to the refractory, heat exchanger, and electrical systems. The Permittee shall maintain a written record of the inspection and any corrective actions taken resulting from the inspection. [40 CFR 64.3, Minn. R , subp. 14, Minn. R , subps. 4 5, Minn. R ] Annual Calibration: The Permittee shall calibrate the TREA 29 temperature monitor at least annually and shall maintain a

160 Permit Expires: [month day, year] Page 158 of 243 written record of the calibration and any action resulting from the calibration. [40 CFR 64.3, Minn. R , subp. 14, Minn. R , subps. 4 5, Minn. R ] Corrective Actions: If the TREA 29 temperature is below the minimum specified by this permit or if TREA 29 or any of its components are found during the inspections to need repair, the Permittee shall take corrective action as soon as possible. Corrective actions shall return the temperature to at least the permitted minimum 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 thermal oxidizer. The Permittee shall keep a record of the type and date of any corrective action taken. [40 CFR 64.7(d)(1), Minn. R , subp. 14, Minn. R , subps. 4 5, Minn. R ] Documentation of Need for Improved Monitoring: If the Permittee fails to achieve compliance with an emission limitation or standard for which the monitoring did not provide an indication of an excursion or exceedance while providing valid data, or the results of compliance or performance testing document a need to modify the existing pressure drop range, the Permittee shall promptly notify the MPCA and, if necessary, submit a permit amendment application to address the necessary monitoring change. [40 CFR 64.7(e), Minn. R ] As required by 40 CFR Section 64.9(a)(2), for the Semi Annual Deviations Report and/or the Notification of Deviations Endangering Human Health and the Environment requirement in the Total Facility subject item of this permit, as applicable, the Permittee shall include the following related to the monitoring identified as required by 40 CFR pt. 64: 1) Summary information on the number, duration, and cause of excursions or exceedances, as applicable, and the corrective action taken; and, 2) Summary information on the number, duration, and cause for monitor downtime incidents. [40 CFR 64.9(a)(2), Minn. R ] The Permittee shall maintain records of monitoring data, monitor performance data, corrective actions taken, and other supporting information required to be maintained. The Permittee may maintain records on alternative media, such as microfilm, computer files, magnetic tape disks, or microfiche, provided that the use of such alternative media allows for expeditious inspection and review, and does not conflict with other applicable recordkeeping requirements. [40 CFR 64.9(b), Minn. R ]

161 Permit Expires: [month day, year] Page 159 of Continued operation. Except for monitoring malfunctions, associated repairs, and required quality assurance or control activities, the Permittee shall conduct all monitoring in continuous operation (or shall collect data at all required intervals) at all times that the pollutant specific emissions unit is operating. Data recorded during monitoring malfunctions, associated repairs, and required quality assurance or control activities shall not be used for purposes of this part, including data averages and calculations, or fulfilling a minimum data availability requirement, if applicable. A monitoring malfunction is any sudden, infrequent, not reasonably preventable failure of the monitoring to provide valid data. Monitoring failures that are caused in part by poor maintenance or careless operation are not malfunctions. [40 CFR 64.7(c), Minn. R ] Response to excursions. Upon detecting an excursion, the Permittee shall restore operation of the pollutant specific emissions unit (including the control device and associated capture system) to its normal or usual manner of operation as expeditiously as practicable in accordance with good air pollution control practices for minimizing emissions. The response shall include minimizing the period of any startup, shutdown or malfunction and taking any necessary corrective actions to restore normal operation and prevent the likely recurrence of the cause of an excursion. Such actions may include initial inspection and evaluation, recording that operations returned to normal without operator action (such as through response by a computerized distribution control system), or any necessary follow up actions to return operation to within the indicator range, designated condition, or below the applicable emission limitation or standard, as applicable. [40 CFR 64.7(d), Minn. R , subp. 14, Minn. R ] Quality Improvement Plan (QIP) requirements. If there is an accumulation of 9 or more excursions during a calendar year, the Permittee must develop and implement a QIP in accordance with 40 CFR 64.8(b). The QIP must be available for inspection. [40 CFR 64.8, Minn. R ] If a QIP is required, the Permittee shall develop and implement the QIP as expeditiously as practicable and shall notify the MPCA if the period for completing the improvements contained in the QIP exceeds 180 days from the date on which the need to implement the QIP was determined. [40 CFR 64.8(c), Minn. R ] Following implementation of a QIP, the Administrator or the MCPA may require that the Permittee make reasonable changes to the QIP if the QIP is found to have: (1) Failed to address the cause of the control device performance problems; or

162 Permit Expires: [month day, year] Page 160 of 243 (2) Failed to provide adequate procedures for correcting control device performance problems as expeditiously as practicable in accordance with good air pollution control practices for minimizing emissions. [40 CFR 64.8(d), Minn. R ] Implementation of a QIP shall not excuse the Permittee from compliance with any existing emission limitation or standard, or any existing monitoring, testing, reporting or recordkeeping requirement that may apply. [40 CFR 64.8(e), Minn. R ] TREA 30 CE003 Packed Gas Adsorption Column The Permittee shall operate and maintain TREA 30 such that it achieves a control efficiency for Volatile Organic Compounds >= 98 percent control efficiency or less than or equal to 20 ppm VOC if the inlet is less than 200 ppm VOC as total mass of VOC. [CAAA of 1990, Title I Condition: 40 CFR 52.21(j)(BACT) & Minn. R , Title I Condition: Avoid major source under 40 CFR 52.21(b)(1)(i) & Minn. R ] The Permittee shall operate and maintain TREA 30 such that it achieves a control efficiency for Acetaldehyde >= 32.5 percent control efficiency. [Minn. R , Title I Condition: Avoid major source under 40 CFR 63.2] The Permittee shall operate and maintain TREA 30 such that it achieves a control efficiency for Acrolein >= 32.5 percent control efficiency. [Minn. R , Title I Condition: Avoid major source under 40 CFR 63.2] The Permittee shall operate and maintain TREA 30 such that it achieves a control efficiency for Formaldehyde >= 32.5 percent control efficiency. [Minn. R , Title I Condition: Avoid major source under 40 CFR 63.2] The Permittee shall operate and maintain TREA 30 such that it achieves a control efficiency for Methanol >= 95 percent control efficiency. [Minn. R , Title I Condition: Avoid major source under 40 CFR 63.2] Pressure Drop >= 3.0 inches of water column unless a new minimum is set pursuant to Minn. R , subp. 3 based on the values recorded during the most recent MPCAapproved performance test where compliance was demonstrated. The new minimum shall be implemented upon receipt of the Notice of Compliance letter granting preliminary approval. The new minimum is final upon issuance of a permit amendment incorporating the change. The Permittee shall record the pressure drop at least once every 24 hours when in operation. [Minn. R , Title I Condition: 40 CFR 52.21(j)(BACT) & Minn. R , Title I Condition: Avoid major source under 40 CFR 63.2]

163 Permit Expires: [month day, year] Page 161 of Water flow rate >= 31.5 gallons per minute unless a new minimum is set pursuant to Minn. R , subp. 3 based on the values recorded during the most recent MPCAapproved performance test where compliance was demonstrated. The new minimum shall be implemented upon receipt of the Notice of Compliance letter granting preliminary approval. The minimum is final upon issuance of a permit amendment incorporating the change. The Permittee shall record the flowrate at least once every 24 hours when in operation. [Minn. R , Title I Condition: 40 CFR 52.21(j)(BACT) & Minn. R , Title I Condition: Avoid major source under 40 CFR 63.2] Additional flow rate monitoring: If the Permittee adjusts the water flow rate to the scrubber, the Permittee shall record the new flow rate within 1 hour. After adjustment and recording of the new flow rate, the Permittee may resume recording the water flow rate once every 24 hours of operation. [Minn. R , subp. 2] The Permittee shall vent emissions from EQUI 1, 10, 31 34, 167 and 168 to TREA 30 whenever EQUI 1, 10, 31 34, 167 and 168 operate, and operate and maintain TREA 30 at all times that any emissions are vented to TREA 30. The Permittee shall document periods of non operation of the control equipment. [Minn. R , Title I Condition: 40 CFR 52.21(j)(BACT) & Minn. R , Title I Condition: Avoid major source under 40 CFR 52.21(b)(1)(i) & Minn. R , Title I Condition: Avoid major source under 40 CFR 63.2] Operation and Maintenance of Wet Scrubber: The Permittee shall operate and maintain the wet scrubber TREA 30 according to the control equipment manufacturer's specifications. [Minn. R , subp. 14] The Permittee shall operate and maintain the scrubber TREA 30 in accordance with the Operation and Maintenance (O & M) Plan. The Permittee shall keep copies of the O & M Plan available onsite for use by staff and MPCA staff. [Minn. R , subp. 14] Record the pressure drop (inches of water column) and water flow rate (gallons per minute) of the scrubber TREA 30 once each day of operation. The Permittee may elect to record pressure drop and water flow rate on an hourly basis for determining operating hours when the scrubber is operating below the required minimum pressure drop or water flow rate, for use in STRU 79 operating hours recordkeeping for when the scrubber is operating below the required minimum pressure drop or water flow rate. [40 CFR 64.3, Minn. R , subps. 4 5, Minn. R , Minn. R , Title I Condition: 40 CFR 52.21(j)(BACT) & Minn. R , Title I Condition: Avoid major source

164 Permit Expires: [month day, year] Page 162 of 243 under 40 CFR 52.21(b)(1)(i) & Minn. R , Title I Condition: Avoid major source under 40 CFR 63.2] Monitoring Equipment: The Permittee shall install and maintain the necessary monitoring equipment for measuring and recording pressure drop and water flow rate as required by this permit. The monitoring equipment must be installed, in use, and properly maintained when the monitored scrubber is in operation. [40 CFR 64.7(b), Minn. R , subp. 4, Minn. R ] Pressure Drop and Water Flow Rate Gauges Calibration: The Permittee shall calibrate the pressure and water flow rate gauges for the scrubber TREA 30 at least once every 12 months and shall maintain a written record of any action resulting from the calibration. [40 CFR 64.3, Minn. R ] 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. [40 CFR 64.3, Minn. R , subp. 14, Minn. R , subp. 2, Minn. R ] Corrective Actions: The Permittee shall take corrective action as soon as possible if any of the following occur: the recorded pressure drop or water flow rate is outside the required operating range; or the scrubber 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 scrubber. The Permittee shall keep a record of the type and date of any corrective action taken for each scrubber. [40 CFR 64.7(d), Minn. R , subp. 14, Minn. R , subps. 4 5, Minn. R ] Documentation of Need for Improved Monitoring: If the Permittee fails to achieve compliance with an emission limitation or standard for which the monitoring did not provide an indication of an excursion or exceedance while providing valid data, or the results of compliance or performance testing document a need to modify the existing pressure drop range, the Permittee shall promptly notify the MPCA and, if necessary, submit a permit amendment application to address the necessary monitoring change. [40 CFR 64.7(e), Minn. R ] As required by 40 CFR Section 64.9(a)(2), for the Semi Annual

165 Permit Expires: [month day, year] Page 163 of 243 Deviations Report and/or the Notification of Deviations Endangering Human Health and the Environment requirement in the Total Facility subject item of this permit, as applicable, the Permittee shall include the following related to the monitoring identified as required by 40 CFR pt. 64: 1) Summary information on the number, duration, and cause of excursions or exceedances, as applicable, and the corrective action taken; and, 2) Summary information on the number, duration, and cause for monitor downtime incidents. [40 CFR 64.9(a)(2), Minn. R ] The Permittee shall maintain records of monitoring data, monitor performance data, corrective actions taken, and other supporting information required to be maintained. The Permittee may maintain records on alternative media, such as microfilm, computer files, magnetic tape disks, or microfiche, provided that the use of such alternative media allows for expeditious inspection and review, and does not conflict with other applicable recordkeeping requirements. [40 CFR 64.9(b), Minn. R ] Continued operation. Except for monitoring malfunctions, associated repairs, and required quality assurance or control activities, the Permittee shall conduct all monitoring in continuous operation (or shall collect data at all required intervals) at all times that the pollutant specific emissions unit is operating. Data recorded during monitoring malfunctions, associated repairs, and required quality assurance or control activities shall not be used for purposes of this part, including data averages and calculations, or fulfilling a minimum data availability requirement, if applicable. A monitoring malfunction is any sudden, infrequent, not reasonably preventable failure of the monitoring to provide valid data. Monitoring failures that are caused in part by poor maintenance or careless operation are not malfunctions. [40 CFR 64.7(c), Minn. R ] Response to excursions. Upon detecting an excursion, the Permittee shall restore operation of the pollutant specific emissions unit (including the control device and associated capture system) to its normal or usual manner of operation as expeditiously as practicable in accordance with good air pollution control practices for minimizing emissions. The response shall include minimizing the period of any startup, shutdown or malfunction and taking any necessary corrective actions to restore normal operation and prevent the likely recurrence of the cause of an excursion. Such actions may include initial inspection and evaluation, recording that operations returned to normal without operator action (such

166 Permit Expires: [month day, year] Page 164 of 243 as through response by a computerized distribution control system), or any necessary follow up actions to return operation to within the indicator range, designated condition, or below the applicable emission limitation or standard, as applicable. [40 CFR 64.7(d), Minn. R , subp. 14, Minn. R ] Quality Improvement Plan (QIP) requirements. If there is an accumulation of 9 or more excursions during a calendar year, the Permittee must develop and implement a QIP in accordance with 40 CFR 64.8(b). The QIP must be available for inspection. [40 CFR 64.8, Minn. R ] If a QIP is required, the Permittee shall develop and implement the QIP as expeditiously as practicable and shall notify the MPCA if the period for completing the improvements contained in the QIP exceeds 180 days from the date on which the need to implement the QIP was determined. [40 CFR 64.8(c), Minn. R ] Following implementation of a QIP, the Administrator or the MCPA may require that the Permittee make reasonable changes to the QIP if the QIP is found to have: (1) Failed to address the cause of the control device performance problems; or (2) Failed to provide adequate procedures for correcting control device performance problems as expeditiously as practicable in accordance with good air pollution control practices for minimizing emissions. [40 CFR 64.8(d), Minn. R ] Implementation of a QIP shall not excuse the Permittee from compliance with any existing emission limitation or standard, or any existing monitoring, testing, reporting or recordkeeping requirement that may apply. [40 CFR 64.8(e), Minn. R ] TREA 31 CE005 Packed Gas Adsorption Column The Permittee shall operate and maintain TREA 31 such that it achieves a control efficiency for Volatile Organic Compounds >= 98 percent control efficiency or less than or equal to 20 ppm VOC if the inlet is less than 200 ppm VOC as total mass of VOC. [Title I Condition: 40 CFR 52.21(j)(BACT) & Minn. R ] The Permittee shall operate and maintain TREA 31 such that it achieves a control efficiency for Acetaldehyde >= 32.5 percent control efficiency. [Minn. R , Title I Condition: Avoid major source under 40 CFR 63.2] The Permittee shall operate and maintain TREA 31 such that it achieves a control efficiency for Acrolein >= 32.5 percent control efficiency. [Minn. R , Title I Condition: Avoid

167 Permit Expires: [month day, year] Page 165 of 243 major source under 40 CFR 63.2] The Permittee shall operate and maintain TREA 31 such that it achieves a control efficiency for Formaldehyde >= 32.5 percent control efficiency. [Minn. R , Title I Condition: Avoid major source under 40 CFR 63.2] The Permittee shall operate and maintain TREA 31 such that it achieves a control efficiency for Methanol >= 95 percent control efficiency. [Minn. R , Title I Condition: Avoid major source under 40 CFR 63.2] Pressure Drop >= 3.0 inches of water column unless a new minimum is set pursuant to Minn. R , subp. 3 based on the values recorded during the most recent MPCAapproved performance test where compliance was demonstrated. The new minimum shall be implemented upon receipt of the Notice of Compliance letter granting preliminary approval. The new minimum is final upon issuance of a permit amendment incorporating the change. The Permittee shall record the pressure drop at least once every 24 hours when in operation. [Minn. R , Title I Condition: 40 CFR 52.21(j)(BACT) & Minn. R , Title I Condition: Avoid major source under 40 CFR 63.2] Water flow rate >= 9.9 gallons per minute, unless a new minimum is set pursuant to Minn. R , subp. 3 based on the values recorded during the most recent MPCAapproved performance test where compliance was demonstrated. The new minimum shall be implemented upon receipt of the Notice of Compliance letter granting preliminary approval. The new minimum is final upon issuance of a permit amendment incorporating the change. The Permittee shall record the flowrate at least once every 24 hours when in operation. [Minn. R , Title I Condition: 40 CFR 52.21(j)(BACT) & Minn. R , Title I Condition: Avoid major source under 40 CFR 63.2] Additional flow rate monitoring: If the Permittee adjusts the water flow rate to the scrubber, the Permittee shall record the new flow rate within 1 hour. After adjustment and recording of the new flow rate, the Permittee may resume recording the water flow rate once every 24 hours of operation. [Minn. R , subp. 2] The Permittee shall vent emissions from EQUI 3, 7 9, 27, 30, 35, 36, 38, 39 and 194 to TREA 31 whenever EQUI 3, 7 9, 27, 30, 35, 36, 38, 39 and 194 operate, and operate and maintain TREA 31 at all times that any emissions are vented to TREA 31. The Permittee shall document periods of non operation of the control equipment. [Minn. R , Title I Condition: 40 CFR 52.21(j)(BACT) & Minn. R , Title I Condition: Avoid major source under 40 CFR 52.21(b)(1)(i) & Minn. R , Title I Condition: Avoid major source under 40 CFR 63.2]

168 Permit Expires: [month day, year] Page 166 of Operation and Maintenance of Wet Scrubber: The Permittee shall operate and maintain the wet scrubber TREA 31 according to the control equipment manufacturer's specifications. [Minn. R , subp. 14] The Permittee shall operate and maintain the scrubber TREA 31 in accordance with the Operation and Maintenance (O & M) Plan. The Permittee shall keep copies of the O & M Plan available onsite for use by staff and MPCA staff. [Minn. R , subp. 14] Record the pressure drop (inches of water column) and water flow rate (gallons per minute) of the scrubber TREA 31 once each day of operation. The Permittee may elect to record pressure drop and water flow rate on an hourly basis for determining operating hours when the scrubber is operating below the required minimum pressure drop or water flow rate, for use in STRU 69 operating hours recordkeeping for when the scrubber is operating below the required minimum pressure drop or water flow rate. [40 CFR 64.3, Minn. R , subps. 4 5, Minn. R , Minn. R , Title I Condition: 40 CFR 52.21(j)(BACT) & Minn. R , Title I Condition: Avoid major source under 40 CFR 52.21(b)(1)(i) & Minn. R , Title I Condition: Avoid major source under 40 CFR 63.2] Monitoring Equipment: The Permittee shall install and maintain the necessary monitoring equipment for measuring and recording pressure drop and water flow rate as required by this permit. The monitoring equipment must be installed, in use, and properly maintained when the monitored scrubber is in operation. [40 CFR 64.7(b), Minn. R , subp. 4, Minn. R ] Pressure Drop and Water Flow Rate Gauges Calibration: The Permittee shall calibrate the pressure and water flow rate gauges for the scrubber TREA 31 at least once every 12 months and shall maintain a written record of any action resulting from the calibration. [40 CFR 64.3, Minn. R ] 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. [40 CFR 64.3, Minn. R , subp. 14, Minn. R , subp. 2, Minn. R ] Corrective Actions: The Permittee shall take corrective action as soon as possible if any of the following occur: the recorded pressure drop or water flow rate is outside the required operating range; or the scrubber or any of its components are found during the

169 Permit Expires: [month day, year] Page 167 of 243 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 scrubber. The Permittee shall keep a record of the type and date of any corrective action taken for each scrubber. [40 CFR 64.7(d), Minn. R , subp. 14, Minn. R , subps. 4 5, Minn. R ] Documentation of Need for Improved Monitoring: If the Permittee fails to achieve compliance with an emission limitation or standard for which the monitoring did not provide an indication of an excursion or exceedance while providing valid data, or the results of compliance or performance testing document a need to modify the existing pressure drop range, the Permittee shall promptly notify the MPCA and, if necessary, submit a permit amendment application to address the necessary monitoring change. [40 CFR 64.7(e), Minn. R ] As required by 40 CFR Section 64.9(a)(2), for the Semi Annual Deviations Report and/or the Notification of Deviations Endangering Human Health and the Environment requirement in the Total Facility subject item of this permit, as applicable, the Permittee shall include the following related to the monitoring identified as required by 40 CFR pt. 64: 1) Summary information on the number, duration, and cause of excursions or exceedances, as applicable, and the corrective action taken; and, 2) Summary information on the number, duration, and cause for monitor downtime incidents. [40 CFR 64.9(a)(2), Minn. R ] The Permittee shall maintain records of monitoring data, monitor performance data, corrective actions taken, and other supporting information required to be maintained. The Permittee may maintain records on alternative media, such as microfilm, computer files, magnetic tape disks, or microfiche, provided that the use of such alternative media allows for expeditious inspection and review, and does not conflict with other applicable recordkeeping requirements. [40 CFR 64.9(b), Minn. R ] Continued operation. Except for monitoring malfunctions, associated repairs, and required quality assurance or control activities, the Permittee shall conduct all monitoring in continuous operation (or shall collect data at all required intervals) at all times that the pollutant specific emissions unit

170 Permit Expires: [month day, year] Page 168 of 243 is operating. Data recorded during monitoring malfunctions, associated repairs, and required quality assurance or control activities shall not be used for purposes of this part, including data averages and calculations, or fulfilling a minimum data availability requirement, if applicable. A monitoring malfunction is any sudden, infrequent, not reasonably preventable failure of the monitoring to provide valid data. Monitoring failures that are caused in part by poor maintenance or careless operation are not malfunctions. [40 CFR 64.7(c), Minn. R ] Response to excursions. Upon detecting an excursion, the Permittee shall restore operation of the pollutant specific emissions unit (including the control device and associated capture system) to its normal or usual manner of operation as expeditiously as practicable in accordance with good air pollution control practices for minimizing emissions. The response shall include minimizing the period of any startup, shutdown or malfunction and taking any necessary corrective actions to restore normal operation and prevent the likely recurrence of the cause of an excursion. Such actions may include initial inspection and evaluation, recording that operations returned to normal without operator action (such as through response by a computerized distribution control system), or any necessary follow up actions to return operation to within the indicator range, designated condition, or below the applicable emission limitation or standard, as applicable. [40 CFR 64.7(d), Minn. R , subp. 14, Minn. R ] Quality Improvement Plan (QIP) requirements. If there is an accumulation of 9 or more excursions during a calendar year, the Permittee must develop and implement a QIP in accordance with 40 CFR 64.8(b). The QIP must be available for inspection. [40 CFR 64.8, Minn. R ] If a QIP is required, the Permittee shall develop and implement the QIP as expeditiously as practicable and shall notify the MPCA if the period for completing the improvements contained in the QIP exceeds 180 days from the date on which the need to implement the QIP was determined. [40 CFR 64.8(c), Minn. R ] Following implementation of a QIP, the Administrator or the MCPA may require that the Permittee make reasonable changes to the QIP if the QIP is found to have: (1) Failed to address the cause of the control device performance problems; or (2) Failed to provide adequate procedures for correcting control device performance problems as expeditiously as practicable in accordance with good air pollution control practices for minimizing emissions. [40 CFR 64.8(d), Minn. R ]

171 Permit Expires: [month day, year] Page 169 of Implementation of a QIP shall not excuse the Permittee from compliance with any existing emission limitation or standard, or any existing monitoring, testing, reporting or recordkeeping requirement that may apply. [40 CFR 64.8(e), Minn. R ] TREA 32 CE006 Fabric Filter Low Temperature, i.e., T<180 Degrees F Pressure Drop >= 0.5 and <= 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 MPCAapproved 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. The Permittee shall record the pressure drop at least once every 24 hours when in operation. [40 CFR 64.3(b)(2), Minn. R , Title I Condition: 40 CFR 52.21(j)(BACT) & Minn. R ] The Permittee shall operate and maintain fabric filter TREA 32 such that it achieves a capture efficiency for Total Particulate Matter >= 80 percent capture efficiency. [Minn. R , subp. 14, Minn. R , subp. 2, Title I Condition: Avoid major source under 40 CFR 52.21(b)(1)(i) & Minn. R ] The Permittee shall operate and maintain fabric filter TREA 32 such that it achieves an overall control efficiency for Total Particulate Matter >= 99.0 percent control efficiency. [Title I Condition: 40 CFR 52.21(j)(BACT) & Minn. R ] The Permittee shall operate and maintain fabric filter TREA 32 such that it achieves a capture efficiency for PM < 10 micron >= 80 percent capture efficiency. [Minn. R , subp. 7(A), 7(L), & 7(M), Minn. R , subp. 14, Minn. R , subp. 4, Minn. R , subps. 1 2, Minn. R , Minn. Stat , subd. 4a, Minn. Stat , subd. 9, Title I Condition: 40 CFR 52.21(k)(1)(i) & Minn. R , Title I Condition: Avoid major source under 40 CFR 52.21(b)(1)(i) & Minn. R ] The Permittee shall operate and maintain fabric filter TREA 32 such that it achieves an overall control efficiency for PM < 10 micron >= 99.0 percent control efficiency. [Title I Condition: 40 CFR 52.21(j)(BACT) & Minn. R ] The Permittee shall operate and maintain fabric filter TREA 32 such that it achieves a capture efficiency for PM < 2.5 micron >= 80 percent capture efficiency. [Minn. R , subp. 7(A), 7(L), & 7(M), Minn. R , subp. 14, Minn. R.

172 Permit Expires: [month day, year] Page 170 of , subp. 4, Minn. R , subps. 1 2, Minn. R , Minn. Stat , subd. 4a, Minn. Stat , subd. 9, Title I Condition: Avoid major source under 40 CFR 52.21(b)(1)(i) & Minn. R ] The Permittee shall operate and maintain fabric filter TREA 32 such that it achieves an overall control efficiency for PM < 2.5 micron >= 99.0 percent control efficiency. [Title I Condition: Avoid major source under 40 CFR 52.21(b)(1)(i) and Minn. R ] The Permittee shall operate and maintain fabric filter TREA 32 such that it achieves a collection efficiency for Total Particulate Matter >= 80 percent collection efficiency. [Minn. R , subp. 3(E)] The control equipment is considered listed control equipment under Minn. R to The Permittee shall vent emissions from EQUI 11 14, 28, 29 and 166 to TREA 32 whenever the listed EQUIs operate, and operate and maintain TREA 32 at all times that any emissions are vented to TREA 32. The Permittee shall document periods of non operation of the control equipment. [Minn. R , subp. 14, Minn. R , subp. 2, Title I Condition: Avoid major source under 40 CFR 52.21(b)(1)(i) and Minn. R ] The Permittee shall vent emissions from EQUI 11 14, 28, 29 and 166 to TREA 32 whenever EQUI 11 14, 28, 29 and 166 operate, and operate and maintain TREA 32 at all times that any emissions are vented to TREA 32. The Permittee shall document periods of non operation of the control equipment. [Title I Condition: 40 CFR 52.21(j) & (k)(bact) and Minn. R , Title I Condition: Avoid major source under 40 CFR 52.21(b)(1)(i) and Minn. R ] Operation and Maintenance of Fabric Filter: The Permittee shall operate and maintain fabric filter TREA 32 according to the control equipment manufacturer's specifications. [Minn. R , subp. 14] The Permittee shall operate and maintain fabric filter TREA 32 in accordance with the Operation and Maintenance (O & M) Plan. The Permittee shall keep copies of the O & M Plan available onsite for use by staff and MPCA staff. [Minn. R , subp. 14] Daily Inspections: The Permittee shall do the following, once every 24 hours when in operation: 1) Inspect the fabric filter stack STRU 71 for any visible emissions during daylight hours, except during inclement weather. 2) During inclement weather, read and record the pressure drop across the fabric filter. [40 CFR 64.1, 40 CFR 64.3(b)(4), Minn. R , subps. 4 5, Minn. R , Title I Condition: 40 CFR 52.21(j)(BACT) & Minn. R , Title I Condition: Avoid major source under 40 CFR 52.21(b)(1)(i) & Minn. R ]

173 Permit Expires: [month day, year] Page 171 of Recordkeeping of Visible Emissions and Pressure Drop: At least once during every 24 hour period that any associated emissions are vented to the fabric filter, 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. Recorded values outside the range specified in this permit are considered Deviations as defined by Minn. R , subp. 8a. [40 CFR 64.1, 40 CFR 64.3(b)(4), Minn. R , subps. 4 5, Minn. R , Title I Condition: 40 CFR 52.21(j)(BACT) & Minn. R , Title I Condition: Avoid major source under 40 CFR 52.21(b)(1)(i) and Minn. R ] Pressure Drop: 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 filter is in operation. This includes, but is not limited to, maintaining necessary parts for routine repairs. [40 CFR 64.7(b), Minn. R , subp. 4, Minn. R , subp. 1(B), Minn. R ] The Permittee shall calibrate or replace the pressure gauge at least once every 12 months and shall maintain a written record of any action resulting from the calibration. [40 CFR 64.1, 40 CFR 64.3(b)(4), Minn. R ] 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. [40 CFR 64.1, 40 CFR 64.3(b)(4), Minn. R , subp. 14, Minn. R , subp. 2, Minn. R ] Corrective Actions: The Permittee shall take corrective action as soon as possible if any of the following conditions 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 return the pressure drop to within the permitted range, eliminate visible emissions, 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 fabric filter. The Permittee shall keep a record of the type and date of

174 Permit Expires: [month day, year] Page 172 of 243 any corrective action taken for each filter. [40 CFR 64.7(d)(1), Minn. R , subp. 14, Minn. R , subps. 4 5, Minn. R ] Documentation of Need for Improved Monitoring: If the Permittee fails to achieve compliance with an emission limitation or standard for which the monitoring did not provide an indication of an excursion or exceedance while providing valid data, or the results of compliance or performance testing document a need to modify the existing pressure drop range, the Permittee shall promptly notify the MPCA and, if necessary, submit a permit amendment application to address the necessary monitoring change. [40 CFR 64.7(e), Minn. R ] As required by 40 CFR Section 64.9(a)(2), for the Semi Annual Deviations Report required by this permit and/or the Notification of Deviations Endangering Human Health and the Environment required by this permit, as applicable, the Permittee shall include the following related to the monitoring identified as required by 40 CFR pt. 64: 1) Summary information on the number, duration, and cause of excursions or exceedances, as applicable, and the corrective action taken; and, 2) Summary information on the number, duration, and cause for monitor downtime incidents. [40 CFR 64.9(a)(2), Minn. R ] The Permittee shall maintain records of monitoring data, monitor performance data, corrective actions taken, and other supporting information required to be maintained. The Permittee may maintain records on alternative media, such as microfilm, computer files, magnetic tape disks, or microfiche, provided that the use of such alternative media allows for expeditious inspection and review, and does not conflict with other applicable recordkeeping requirements. [40 CFR 64.9(b), Minn. R ] Continued operation. Except for monitoring malfunctions, associated repairs, and required quality assurance or control activities, the Permittee shall conduct all monitoring in continuous operation (or shall collect data at all required intervals) at all times that the pollutant specific emissions unit is operating. Data recorded during monitoring malfunctions, associated repairs, and required quality assurance or control activities shall not be used for purposes of this part, including data averages and calculations, or fulfilling a minimum data availability requirement, if applicable. A monitoring malfunction is any sudden, infrequent, not reasonably preventable failure of the monitoring to provide valid data. Monitoring failures that are caused in part by poor

175 Permit Expires: [month day, year] Page 173 of 243 maintenance or careless operation are not malfunctions. [40 CFR 64.7(c), Minn. R ] Response to excursions. Upon detecting an excursion, the Permittee shall restore operation of the pollutant specific emissions unit (including the control device and associated capture system) to its normal or usual manner of operation as expeditiously as practicable in accordance with good air pollution control practices for minimizing emissions. The response shall include minimizing the period of any startup, shutdown or malfunction and taking any necessary corrective actions to restore normal operation and prevent the likely recurrence of the cause of an excursion. Such actions may include initial inspection and evaluation, recording that operations returned to normal without operator action (such as through response by a computerized distribution control system), or any necessary follow up actions to return operation to within the indicator range, designated condition, or below the applicable emission limitation or standard, as applicable. [40 CFR 64.7(d), Minn. R , subp. 14, Minn. R ] Quality Improvement Plan (QIP) requirements. If there is an accumulation of 9 or more excursions during a calendar year, the Permittee must develop and implement a QIP in accordance with 40 CFR 64.8(b). The QIP must be available for inspection. [40 CFR 64.8, Minn. R ] If a QIP is required, the Permittee shall develop and implement the QIP as expeditiously as practicable and shall notify the MPCA if the period for completing the improvements contained in the QIP exceeds 180 days from the date on which the need to implement the QIP was determined. [40 CFR 64.8(c), Minn. R ] Following implementation of a QIP, the Administrator or the MCPA may require that the Permittee make reasonable changes to the QIP if the QIP is found to have: (1) Failed to address the cause of the control device performance problems; or (2) Failed to provide adequate procedures for correcting control device performance problems as expeditiously as practicable in accordance with good air pollution control practices for minimizing emissions. [40 CFR 64.8(d), Minn. R ] Implementation of a QIP shall not excuse the Permittee from compliance with any existing emission limitation or standard, or any existing monitoring, testing, reporting or recordkeeping requirement that may apply. [40 CFR 64.8(e), Minn. R ] TREA 33 CE007 Fabric Filter Low

176 Permit Expires: [month day, year] Page 174 of 243 Temperature, i.e., T<180 Degrees F Pressure Drop >= 0.5 and <= 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 MPCAapproved 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. The Permittee shall record the pressure drop at least once every 24 hours when in operation. [Title I Condition: 40 CFR 52.21(j)(BACT) & Minn. R ] The Permittee shall operate and maintain fabric filter TREA 33 such that it achieves an overall control efficiency for Total Particulate Matter >= 99 percent control efficiency. [Title I Condition: 40 CFR 52.21(j)(BACT) & Minn. R ] The Permittee shall operate and maintain fabric filter TREA 33 such that it achieves an overall control efficiency for PM < 10 micron >= 99 percent control efficiency. [Title I Condition: 40 CFR 52.21(j)(BACT) & Minn. R ] The Permittee shall operate and maintain fabric filter TREA 33 such that it achieves an overall control efficiency for PM < 2.5 micron >= 99 percent control efficiency. [Title I Condition: Avoid major source under 40 CFR 52.21(b)(1)(i) and Minn. R ] The control equipment is considered listed control equipment under Minn. R to The Permittee shall vent emissions from EQUI 15 and 16 to TREA 33 whenever the listed EQUIs operate, and operate and maintain TREA 33 at all times that any emissions are vented to TREA 33. The Permittee shall document periods of non operation of the control equipment. [Minn. R , subp. 14, Minn. R , subp. 2, Title I Condition: Avoid major source under 40 CFR 52.21(b)(1)(i) and Minn. R ] The Permittee shall vent emissions from EQUI 15 and 16 to TREA 33 whenever EQUI 15 and 16 operate and operate and maintain TREA 33 at all times that any emissions are vented to TREA 33. The Permittee shall document periods of nonoperation of the control equipment. [Title I Condition: 40 CFR 52.21(j) & (k)(bact) and Minn. R , Title I Condition: Avoid major source under 40 CFR 52.21(b)(1)(i) and Minn. R ] Operation and Maintenance of Fabric Filter: The Permittee shall operate and maintain fabric filter TREA 33 according to the control equipment manufacturer's specifications. [Minn. R , subp. 14] The Permittee shall operate and maintain fabric filter TREA 33

177 Permit Expires: [month day, year] Page 175 of 243 in accordance with the Operation and Maintenance (O & M) Plan. The Permittee shall keep copies of the O & M Plan available onsite for use by staff and MPCA staff. [Minn. R , subp. 14] Daily Inspections: The Permittee shall do the following, once every 24 hours when in operation: 1) Inspect the fabric filter stack STRU 72 for any visible emissions during daylight hours, except during inclement weather. 2) During inclement weather, read and record the pressure drop across the fabric filter. [40 CFR 64.1, 40 CFR 64.3(b)(4), Minn. R , subps. 4 5, Minn. R , Title I Condition: 40 CFR 52.21(j)(BACT) & Minn. R , Title I Condition: Avoid major source under 40 CFR 52.21(b)(1)(i) & Minn. R ] Recordkeeping of Visible Emissions and Pressure Drop: At least once during every 24 hour period that any associated emissions are vented to the fabric filter, 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. Recorded values outside the range specified in this permit are considered Deviations as defined by Minn. R , subp. 8a. [40 CFR 64.1, 40 CFR 64.3(b)(4), Minn. R , subps. 4 5, Minn. R , Title I Condition: 40 CFR 52.21(j)(BACT) & Minn. R , Title I Condition: Avoid major source under 40 CFR 52.21(b)(1)(i) and Minn. R ] Pressure Drop: 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 filter is in operation. This includes, but is not limited to, maintaining necessary parts for routine repairs. [40 CFR 64.7(b), Minn. R , subp. 4, Minn. R , subp. 1(B), Minn. R ] The Permittee shall calibrate or replace the pressure gauge at least once every 12 months and shall maintain a written record of any action resulting from the calibration. [40 CFR 64.1, 40 CFR 64.3(b)(4), Minn. R ] 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. [40 CFR 64.1, 40 CFR 64.3(b)(4), Minn. R , subp. 14, Minn. R , subp. 2, Minn. R ] Corrective Actions: The Permittee shall take corrective action

178 Permit Expires: [month day, year] Page 176 of 243 as soon as possible if any of the following conditions 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 return the pressure drop to within the permitted range, eliminate visible emissions, 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 fabric filter. The Permittee shall keep a record of the type and date of any corrective action taken for each filter. [40 CFR 64.7(d)(1), Minn. R , subp. 14, Minn. R , subps. 4 5, Minn. R ] Documentation of Need for Improved Monitoring: If the Permittee fails to achieve compliance with an emission limitation or standard for which the monitoring did not provide an indication of an excursion or exceedance while providing valid data, or the results of compliance or performance testing document a need to modify the existing pressure drop range, the Permittee shall promptly notify the MPCA and, if necessary, submit a permit amendment application to address the necessary monitoring change. [40 CFR 64.7(e), Minn. R ] As required by 40 CFR Section 64.9(a)(2), for the Semi Annual Deviations Report required by this permit and/or the Notification of Deviations Endangering Human Health and the Environment required by this permit, as applicable, the Permittee shall include the following related to the monitoring identified as required by 40 CFR pt. 64: 1) Summary information on the number, duration, and cause of excursions or exceedances, as applicable, and the corrective action taken; and, 2) Summary information on the number, duration, and cause for monitor downtime incidents. [40 CFR 64.9(a)(2), Minn. R ] The Permittee shall maintain records of monitoring data, monitor performance data, corrective actions taken, and other supporting information required to be maintained. The Permittee may maintain records on alternative media, such as microfilm, computer files, magnetic tape disks, or microfiche, provided that the use of such alternative media allows for expeditious inspection and review, and does not conflict with other applicable recordkeeping requirements. [40 CFR 64.9(b),

179 Permit Expires: [month day, year] Page 177 of 243 Minn. R ] Continued operation. Except for monitoring malfunctions, associated repairs, and required quality assurance or control activities, the Permittee shall conduct all monitoring in continuous operation (or shall collect data at all required intervals) at all times that the pollutant specific emissions unit is operating. Data recorded during monitoring malfunctions, associated repairs, and required quality assurance or control activities shall not be used for purposes of this part, including data averages and calculations, or fulfilling a minimum data availability requirement, if applicable. A monitoring malfunction is any sudden, infrequent, not reasonably preventable failure of the monitoring to provide valid data. Monitoring failures that are caused in part by poor maintenance or careless operation are not malfunctions. [40 CFR 64.7(c), Minn. R ] Response to excursions. Upon detecting an excursion, the Permittee shall restore operation of the pollutant specific emissions unit (including the control device and associated capture system) to its normal or usual manner of operation as expeditiously as practicable in accordance with good air pollution control practices for minimizing emissions. The response shall include minimizing the period of any startup, shutdown or malfunction and taking any necessary corrective actions to restore normal operation and prevent the likely recurrence of the cause of an excursion. Such actions may include initial inspection and evaluation, recording that operations returned to normal without operator action (such as through response by a computerized distribution control system), or any necessary follow up actions to return operation to within the indicator range, designated condition, or below the applicable emission limitation or standard, as applicable. [40 CFR 64.7(d), Minn. R , subp. 14, Minn. R ] Quality Improvement Plan (QIP) requirements. If there is an accumulation of 9 or more excursions during a calendar year, the Permittee must develop and implement a QIP in accordance with 40 CFR 64.8(b). The QIP must be available for inspection. [40 CFR 64.8, Minn. R ] If a QIP is required, the Permittee shall develop and implement the QIP as expeditiously as practicable and shall notify the MPCA if the period for completing the improvements contained in the QIP exceeds 180 days from the date on which the need to implement the QIP was determined. [40 CFR 64.8(c), Minn. R ] Following implementation of a QIP, the Administrator or the MCPA may require that the Permittee make reasonable changes to the QIP if the QIP is found to have: (1) Failed to address the cause of the control device

180 Permit Expires: [month day, year] Page 178 of 243 performance problems; or (2) Failed to provide adequate procedures for correcting control device performance problems as expeditiously as practicable in accordance with good air pollution control practices for minimizing emissions. [40 CFR 64.8(d), Minn. R ] Implementation of a QIP shall not excuse the Permittee from compliance with any existing emission limitation or standard, or any existing monitoring, testing, reporting or recordkeeping requirement that may apply. [40 CFR 64.8(e), Minn. R ] TREA 34 CE008 Packed Gas Adsorption Column The Permittee shall operate and maintain TREA 34 such that it achieves a control efficiency for Volatile Organic Compounds >= 98 percent control efficiency or less than or equal to 20 ppm VOC if the inlet is less than 200 ppm VOC as total mass of VOC. [Title I Condition: 40 CFR 52.21(j)(BACT) & Minn. R , Title I Condition: Avoid major source under 40 CFR 52.21(b)(1)(i) & Minn. R ] The Permittee shall operate and maintain TREA 34 such that it achieves a control efficiency for Acetaldehyde >= 85 percent control efficiency. [Minn. R , Title I Condition: Avoid major source under 40 CFR 63.2] The Permittee shall operate and maintain TREA 34 such that it achieves a control efficiency for Acrolein >= 32.5 percent control efficiency. [Minn. R , Title I Condition: Avoid major source under 40 CFR 63.2] The Permittee shall operate and maintain TREA 34 such that it achieves a control efficiency for Formaldehyde >= 85 percent control efficiency. [Minn. R , Title I Condition: Avoid major source under 40 CFR 63.2] The Permittee shall operate and maintain TREA 34 such that it achieves a control efficiency for Methanol >= 95 percent control efficiency. [Minn. R , Title I Condition: Avoid major source under 40 CFR 63.2] Pressure Drop >= 19.5 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. The Permittee shall record the pressure drop at least once every 24 hours when in operation. [Minn. R , Title I Condition: 40 CFR 52.21(j)(BACT) & Minn. R , Title I Condition: Avoid major source under 40 CFR 63.2]

181 Permit Expires: [month day, year] Page 179 of Water flow rate >= 60.3 gallons per minute, unless a new range is set by permit reopening or permit amendment, based on the values recorded during the most recent MPCA approved performance test where compliance was demonstrated. The Permittee shall record the water flow rate once every 24 hours when in operation. [Minn. R , Title I Condition: 40 CFR 52.21(j)(BACT) & Minn. R , Title I Condition: Avoid major source under 40 CFR 63.2] The Permittee shall vent emissions from EQUI 2, 17 21, 41 47, 49, 50, 161 and 195 to TREA 34 whenever EQUI 2, 17 21, 41 47, 49, 50, 161 and 195 operate, and operate and maintain TREA 34 at all times that any emissions are vented to TREA 34. The Permittee shall document periods of non operation of the control equipment. [Minn. R , Title I Condition: 40 CFR 52.21(j)(BACT) & Minn. R , Title I Condition: Avoid major source under 40 CFR 52.21(b)(1)(i) & Minn. R , Title I Condition: Avoid major source under 40 CFR 63.2] Operation and Maintenance of Wet Scrubber: The Permittee shall operate and maintain the wet scrubber TREA 34 according to the control equipment manufacturer's specifications. [Minn. R , subp. 14] The Permittee shall operate and maintain the scrubber TREA 34 in accordance with the Operation and Maintenance (O & M) Plan. The Permittee shall keep copies of the O & M Plan available onsite for use by staff and MPCA staff. [Minn. R , subp. 14] Record the pressure drop (inches of water column) and water flow rate (gallons per minute) of the scrubber TREA 34 once each day of operation. The Permittee may elect to record pressure drop and water flow rate on an hourly basis for determining operating hours when the scrubber is operating below the required minimum pressure drop or water flow rate, for use in STRU 68 operating hours recordkeeping for when the scrubber is operating below the required minimum pressure drop or water flow rate. [40 CFR 64.3, Minn. R , subps. 4 5, Minn. R , Minn. R , Title I Condition: 40 CFR 52.21(j)(BACT) & Minn. R , Title I Condition: Avoid major source under 40 CFR 52.21(b)(1)(i) & Minn. R , Title I Condition: Avoid major source under 40 CFR 63.2] Monitoring Equipment: The Permittee shall install and maintain the necessary monitoring equipment for measuring and recording pressure drop and water flow rate as required by this permit. The monitoring equipment must be installed, in use, and properly maintained when the monitored scrubber is in operation. [40 CFR 64.7(b), Minn. R , subp. 4, Minn. R ]

182 Permit Expires: [month day, year] Page 180 of Pressure Drop and Water Flow Rate Gauges Calibration: The Permittee shall calibrate the pressure and water flow rate gauges for the scrubber TREA 34 at least once every 12 months and shall maintain a written record of any action resulting from the calibration. [40 CFR 64.3, Minn. R ] 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. [40 CFR 64.3, Minn. R , subp. 14, Minn. R , subp. 2, Minn. R ] Corrective Actions: The Permittee shall take corrective action as soon as possible if any of the following occur: the recorded pressure drop or water flow rate is outside the required operating range; or the scrubber 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 scrubber. The Permittee shall keep a record of the type and date of any corrective action taken for each scrubber. [40 CFR 64.7(d), Minn. R , subp. 14, Minn. R , subps. 4 5, Minn. R ] Documentation of Need for Improved Monitoring: If the Permittee fails to achieve compliance with an emission limitation or standard for which the monitoring did not provide an indication of an excursion or exceedance while providing valid data, or the results of compliance or performance testing document a need to modify the existing pressure drop range, the Permittee shall promptly notify the MPCA and, if necessary, submit a permit amendment application to address the necessary monitoring change. [40 CFR 64.7(e), Minn. R ] As required by 40 CFR Section 64.9(a)(2), for the Semi Annual Deviations Report and/or the Notification of Deviations Endangering Human Health and the Environment requirement in the Total Facility subject item of this permit, as applicable, the Permittee shall include the following related to the monitoring identified as required by 40 CFR pt. 64: 1) Summary information on the number, duration, and cause of excursions or exceedances, as applicable, and the corrective action taken; and,

183 Permit Expires: [month day, year] Page 181 of 243 2) Summary information on the number, duration, and cause for monitor downtime incidents. [40 CFR 64.9(a)(2), Minn. R ] The Permittee shall maintain records of monitoring data, monitor performance data, corrective actions taken, and other supporting information required to be maintained. The Permittee may maintain records on alternative media, such as microfilm, computer files, magnetic tape disks, or microfiche, provided that the use of such alternative media allows for expeditious inspection and review, and does not conflict with other applicable recordkeeping requirements. [40 CFR 64.9(b), Minn. R ] Continued operation. Except for monitoring malfunctions, associated repairs, and required quality assurance or control activities, the Permittee shall conduct all monitoring in continuous operation (or shall collect data at all required intervals) at all times that the pollutant specific emissions unit is operating. Data recorded during monitoring malfunctions, associated repairs, and required quality assurance or control activities shall not be used for purposes of this part, including data averages and calculations, or fulfilling a minimum data availability requirement, if applicable. A monitoring malfunction is any sudden, infrequent, not reasonably preventable failure of the monitoring to provide valid data. Monitoring failures that are caused in part by poor maintenance or careless operation are not malfunctions. [40 CFR 64.7(c), Minn. R ] Response to excursions. Upon detecting an excursion, the Permittee shall restore operation of the pollutant specific emissions unit (including the control device and associated capture system) to its normal or usual manner of operation as expeditiously as practicable in accordance with good air pollution control practices for minimizing emissions. The response shall include minimizing the period of any startup, shutdown or malfunction and taking any necessary corrective actions to restore normal operation and prevent the likely recurrence of the cause of an excursion. Such actions may include initial inspection and evaluation, recording that operations returned to normal without operator action (such as through response by a computerized distribution control system), or any necessary follow up actions to return operation to within the indicator range, designated condition, or below the applicable emission limitation or standard, as applicable. [40 CFR 64.7(d), Minn. R , subp. 14, Minn. R ] Quality Improvement Plan (QIP) requirements. If there is an accumulation of 9 or more excursions during a calendar year, the Permittee must develop and implement a QIP in

184 Permit Expires: [month day, year] Page 182 of 243 accordance with 40 CFR 64.8(b). The QIP must be available for inspection. [40 CFR 64.8, Minn. R ] If a QIP is required, the Permittee shall develop and implement the QIP as expeditiously as practicable and shall notify the MPCA if the period for completing the improvements contained in the QIP exceeds 180 days from the date on which the need to implement the QIP was determined. [40 CFR 64.8(c), Minn. R ] Following implementation of a QIP, the Administrator or the MCPA may require that the Permittee make reasonable changes to the QIP if the QIP is found to have: (1) Failed to address the cause of the control device performance problems; or (2) Failed to provide adequate procedures for correcting control device performance problems as expeditiously as practicable in accordance with good air pollution control practices for minimizing emissions. [40 CFR 64.8(d), Minn. R ] Implementation of a QIP shall not excuse the Permittee from compliance with any existing emission limitation or standard, or any existing monitoring, testing, reporting or recordkeeping requirement that may apply. [40 CFR 64.8(e), Minn. R ] TREA 43 CE001 Fabric Filter Low Temperature, i.e., T<180 Degrees F Pressure Drop >= 0.5 and <= 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 MPCAapproved 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. The Permittee shall record the pressure drop at least once every 24 hours when in operation. [Title I Condition: 40 CFR 52.21(j)(BACT) & Minn. R ] The Permittee shall operate and maintain fabric filter TREA 43 such that it achieves an overall control efficiency for Total Particulate Matter >= 99.0 percent control efficiency. [Title I Condition: 40 CFR 52.21(j)(BACT) & Minn. R ] The Permittee shall operate and maintain fabric filter TREA 43 such that it achieves an overall control efficiency for PM < 10 micron >= 99.0 percent control efficiency. [Title I Condition: 40 CFR 52.21(j)(BACT) & Minn. R ] The Permittee shall operate and maintain fabric filter TREA 43

185 Permit Expires: [month day, year] Page 183 of 243 such that it achieves an overall control efficiency for PM < 2.5 micron >= 99.0 percent control efficiency. [Title I Condition: Avoid major source under 40 CFR 52.21(b)(1)(i) & Minn. R ] The Permittee shall vent emissions from EQUI and to TREA 43 whenever EQUI and operate and operate and maintain TREA 43 at all times that any emissions are vented to TREA 43. The Permittee shall document periods of non operation of the control equipment. [Title I Condition: 40 CFR 52.21(j) & (k)(bact) and Minn. R , Title I Condition: Avoid major source under 40 CFR 52.21(b)(1)(i) and Minn. R ] Operation and Maintenance of Fabric Filter: The Permittee shall operate and maintain fabric filter TREA 43 according to the control equipment manufacturer's specifications. [Minn. R , subp. 14] The Permittee shall operate and maintain fabric filter TREA 43 in accordance with the Operation and Maintenance (O & M) Plan. The Permittee shall keep copies of the O & M Plan available onsite for use by staff and MPCA staff. [Minn. R , subp. 14] Daily Inspections: The Permittee shall do the following, once every 24 hours when in operation: 1) Inspect the fabric filter stack STRU 85 for any visible emissions during daylight hours, except during inclement weather. 2) During inclement weather, read and record the pressure drop across the fabric filter. [40 CFR 64.1, 40 CFR 64.3(b)(4), Minn. R , subps. 4 5, Minn. R , Title I Condition: 40 CFR 52.21(j)(BACT) & Minn. R , Title I Condition: Avoid major source under 40 CFR 52.21(b)(1)(i) & Minn. R ] Recordkeeping of Visible Emissions and Pressure Drop: At least once during every 24 hour period that any associated emissions are vented to the fabric filter, 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. Recorded values outside the range specified in this permit are considered Deviations as defined by Minn. R , subp. 8a. [40 CFR 64.1, 40 CFR 64.3(b)(4), Minn. R , subps. 4 5, Minn. R , Title I Condition: 40 CFR 52.21(j)(BACT) & Minn. R , Title I Condition: Avoid major source under 40 CFR 52.21(b)(1)(i) and Minn. R ] Pressure Drop: 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,

186 Permit Expires: [month day, year] Page 184 of 243 and properly maintained when the monitored fabric filter is in operation. This includes, but is not limited to, maintaining necessary parts for routine repairs. [40 CFR 64.7(b), Minn. R , subp. 4, Minn. R , subp. 1(B), Minn. R ] The Permittee shall calibrate or replace the pressure gauge at least once every 12 months and shall maintain a written record of any action resulting from the calibration. [40 CFR 64.1, 40 CFR 64.3(b)(4), Minn. R ] 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. [40 CFR 64.1, 40 CFR 64.3(b)(4), Minn. R , subp. 14, Minn. R , subp. 2, Minn. R ] Corrective Actions: The Permittee shall take corrective action as soon as possible if any of the following conditions 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 return the pressure drop to within the permitted range, eliminate visible emissions, 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 fabric filter. The Permittee shall keep a record of the type and date of any corrective action taken for each filter. [40 CFR 64.7(d)(1), Minn. R , subp. 14, Minn. R , subps. 4 5, Minn. R ] Documentation of Need for Improved Monitoring: If the Permittee fails to achieve compliance with an emission limitation or standard for which the monitoring did not provide an indication of an excursion or exceedance while providing valid data, or the results of compliance or performance testing document a need to modify the existing pressure drop range, the Permittee shall promptly notify the MPCA and, if necessary, submit a permit amendment application to address the necessary monitoring change. [40 CFR 64.7(e), Minn. R ] As required by 40 CFR Section 64.9(a)(2), for the Semi Annual Deviations Report required by this permit and/or the Notification of Deviations Endangering Human Health and the Environment required by this permit, as applicable, the Permittee shall include the following related to the monitoring

187 Permit Expires: [month day, year] Page 185 of 243 identified as required by 40 CFR pt. 64: 1) Summary information on the number, duration, and cause of excursions or exceedances, as applicable, and the corrective action taken; and, 2) Summary information on the number, duration, and cause for monitor downtime incidents. [40 CFR 64.9(a)(2), Minn. R ] The Permittee shall maintain records of monitoring data, monitor performance data, corrective actions taken, and other supporting information required to be maintained. The Permittee may maintain records on alternative media, such as microfilm, computer files, magnetic tape disks, or microfiche, provided that the use of such alternative media allows for expeditious inspection and review, and does not conflict with other applicable recordkeeping requirements. [40 CFR 64.9(b), Minn. R ] Continued operation. Except for monitoring malfunctions, associated repairs, and required quality assurance or control activities, the Permittee shall conduct all monitoring in continuous operation (or shall collect data at all required intervals) at all times that the pollutant specific emissions unit is operating. Data recorded during monitoring malfunctions, associated repairs, and required quality assurance or control activities shall not be used for purposes of this part, including data averages and calculations, or fulfilling a minimum data availability requirement, if applicable. A monitoring malfunction is any sudden, infrequent, not reasonably preventable failure of the monitoring to provide valid data. Monitoring failures that are caused in part by poor maintenance or careless operation are not malfunctions. [40 CFR 64.7(c), Minn. R ] Response to excursions. Upon detecting an excursion, the Permittee shall restore operation of the pollutant specific emissions unit (including the control device and associated capture system) to its normal or usual manner of operation as expeditiously as practicable in accordance with good air pollution control practices for minimizing emissions. The response shall include minimizing the period of any startup, shutdown or malfunction and taking any necessary corrective actions to restore normal operation and prevent the likely recurrence of the cause of an excursion. Such actions may include initial inspection and evaluation, recording that operations returned to normal without operator action (such as through response by a computerized distribution control system), or any necessary follow up actions to return operation to within the indicator range, designated condition, or below the applicable emission limitation or standard, as

188 Permit Expires: [month day, year] Page 186 of 243 applicable. [40 CFR 64.7(d), Minn. R , subp. 14, Minn. R ] Quality Improvement Plan (QIP) requirements. If there is an accumulation of 9 or more excursions during a calendar year, the Permittee must develop and implement a QIP in accordance with 40 CFR 64.8(b). The QIP must be available for inspection. [40 CFR 64.8, Minn. R ] If a QIP is required, the Permittee shall develop and implement the QIP as expeditiously as practicable and shall notify the MPCA if the period for completing the improvements contained in the QIP exceeds 180 days from the date on which the need to implement the QIP was determined. [40 CFR 64.8(c), Minn. R ] Following implementation of a QIP, the Administrator or the MCPA may require that the Permittee make reasonable changes to the QIP if the QIP is found to have: (1) Failed to address the cause of the control device performance problems; or (2) Failed to provide adequate procedures for correcting control device performance problems as expeditiously as practicable in accordance with good air pollution control practices for minimizing emissions. [40 CFR 64.8(d), Minn. R ] Implementation of a QIP shall not excuse the Permittee from compliance with any existing emission limitation or standard, or any existing monitoring, testing, reporting or recordkeeping requirement that may apply. [40 CFR 64.8(e), Minn. R ] TREA 44 CE002 Fabric Filter Low Temperature, i.e., T<180 Degrees F Pressure Drop >= 0.5 and <= 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 MPCAapproved 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. The Permittee shall record the pressure drop at least once every 24 hours when in operation. [Title I Condition: 40 CFR 52.21(j)(BACT) & Minn. R ] The Permittee shall operate and maintain fabric filter TREA 44 such that it achieves an overall control efficiency for Total Particulate Matter >= 99 percent control efficiency. [Title I Condition: 40 CFR 52.21(j)(BACT) & Minn. R ]

189 Permit Expires: [month day, year] Page 187 of The Permittee shall operate and maintain fabric filter TREA 44 such that it achieves an overall control efficiency for PM < 10 micron >= 99 percent control efficiency. [Title I Condition: 40 CFR 52.21(j)(BACT) & Minn. R ] The Permittee shall operate and maintain fabric filter TREA 44 such that it achieves an overall control efficiency for PM < 2.5 micron >= 99 percent control efficiency. [Title I Condition: Avoid major source under 40 CFR 52.21(b)(1)(i) & Minn. R ] The Permittee shall vent emissions from EQUI 186 and 187 to TREA 44 whenever EQUI 186 and 187 operate and operate and maintain TREA 44 at all times that any emissions are vented to TREA 44. The Permittee shall document periods of nonoperation of the control equipment. [Title I Condition: 40 CFR 52.21(j) & (k)(bact) and Minn. R , Title I Condition: Avoid major source under 40 CFR 52.21(b)(1)(i) and Minn. R ] Operation and Maintenance of Fabric Filter: The Permittee shall operate and maintain fabric filter TREA 44 according to the control equipment manufacturer's specifications. [Minn. R , subp. 14] The Permittee shall operate and maintain fabric filter TREA 44 in accordance with the Operation and Maintenance (O & M) Plan. The Permittee shall keep copies of the O & M Plan available onsite for use by staff and MPCA staff. [Minn. R , subp. 14] Daily Inspections: The Permittee shall do the following, once every 24 hours when in operation: 1) Inspect the fabric filter stack STRU 86 for any visible emissions during daylight hours, except during inclement weather. 2) During inclement weather, read and record the pressure drop across the fabric filter. [40 CFR 64.1, 40 CFR 64.3(b)(4), Minn. R , subps. 4 5, Minn. R , Title I Condition: 40 CFR 52.21(j)(BACT) & Minn. R , Title I Condition: Avoid major source under 40 CFR 52.21(b)(1)(i) & Minn. R ] Recordkeeping of Visible Emissions and Pressure Drop: At least once during every 24 hour period that any associated emissions are vented to the fabric filter, 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. Recorded values outside the range specified in this permit are considered Deviations as defined by Minn. R , subp. 8a. [40 CFR 64.1, 40 CFR 64.3(b)(4), Minn. R , subps. 4 5, Minn. R , Title I Condition: 40 CFR 52.21(j)(BACT) & Minn. R , Title I Condition: Avoid major source under 40 CFR 52.21(b)(1)(i) and Minn. R.

190 Permit Expires: [month day, year] Page 188 of ] Pressure Drop: 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 filter is in operation. This includes, but is not limited to, maintaining necessary parts for routine repairs. [40 CFR 64.7(b), Minn. R , subp. 4, Minn. R , subp. 1(B), Minn. R ] The Permittee shall calibrate or replace the pressure gauge at least once every 12 months and shall maintain a written record of any action resulting from the calibration. [40 CFR 64.1, 40 CFR 64.3(b)(4), Minn. R ] 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. [40 CFR 64.1, 40 CFR 64.3(b)(4), Minn. R , subp. 14, Minn. R , subp. 2, Minn. R ] Corrective Actions: The Permittee shall take corrective action as soon as possible if any of the following conditions 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 return the pressure drop to within the permitted range, eliminate visible emissions, 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 fabric filter. The Permittee shall keep a record of the type and date of any corrective action taken for each filter. [40 CFR 64.7(d)(1), Minn. R , subp. 14, Minn. R , subps. 4 5, Minn. R ] Documentation of Need for Improved Monitoring: If the Permittee fails to achieve compliance with an emission limitation or standard for which the monitoring did not provide an indication of an excursion or exceedance while providing valid data, or the results of compliance or performance testing document a need to modify the existing pressure drop range, the Permittee shall promptly notify the MPCA and, if necessary, submit a permit amendment application to address the necessary monitoring change. [40 CFR 64.7(e), Minn. R ]

191 Permit Expires: [month day, year] Page 189 of As required by 40 CFR Section 64.9(a)(2), for the Semi Annual Deviations Report required by this permit and/or the Notification of Deviations Endangering Human Health and the Environment required by this permit, as applicable, the Permittee shall include the following related to the monitoring identified as required by 40 CFR pt. 64: 1) Summary information on the number, duration, and cause of excursions or exceedances, as applicable, and the corrective action taken; and, 2) Summary information on the number, duration, and cause for monitor downtime incidents. [40 CFR 64.9(a)(2), Minn. R ] The Permittee shall maintain records of monitoring data, monitor performance data, corrective actions taken, and other supporting information required to be maintained. The Permittee may maintain records on alternative media, such as microfilm, computer files, magnetic tape disks, or microfiche, provided that the use of such alternative media allows for expeditious inspection and review, and does not conflict with other applicable recordkeeping requirements. [40 CFR 64.9(b), Minn. R ] Continued operation. Except for monitoring malfunctions, associated repairs, and required quality assurance or control activities, the Permittee shall conduct all monitoring in continuous operation (or shall collect data at all required intervals) at all times that the pollutant specific emissions unit is operating. Data recorded during monitoring malfunctions, associated repairs, and required quality assurance or control activities shall not be used for purposes of this part, including data averages and calculations, or fulfilling a minimum data availability requirement, if applicable. A monitoring malfunction is any sudden, infrequent, not reasonably preventable failure of the monitoring to provide valid data. Monitoring failures that are caused in part by poor maintenance or careless operation are not malfunctions. [40 CFR 64.7(c), Minn. R ] Response to excursions. Upon detecting an excursion, the Permittee shall restore operation of the pollutant specific emissions unit (including the control device and associated capture system) to its normal or usual manner of operation as expeditiously as practicable in accordance with good air pollution control practices for minimizing emissions. The response shall include minimizing the period of any startup, shutdown or malfunction and taking any necessary corrective actions to restore normal operation and prevent the likely recurrence of the cause of an excursion. Such actions may include initial inspection and evaluation, recording that

192 Permit Expires: [month day, year] Page 190 of 243 operations returned to normal without operator action (such as through response by a computerized distribution control system), or any necessary follow up actions to return operation to within the indicator range, designated condition, or below the applicable emission limitation or standard, as applicable. [40 CFR 64.7(d), Minn. R , subp. 14, Minn. R ] Quality Improvement Plan (QIP) requirements. If there is an accumulation of 9 or more excursions during a calendar year, the Permittee must develop and implement a QIP in accordance with 40 CFR 64.8(b). The QIP must be available for inspection. [40 CFR 64.8, Minn. R ] If a QIP is required, the Permittee shall develop and implement the QIP as expeditiously as practicable and shall notify the MPCA if the period for completing the improvements contained in the QIP exceeds 180 days from the date on which the need to implement the QIP was determined. [40 CFR 64.8(c), Minn. R ] Following implementation of a QIP, the Administrator or the MCPA may require that the Permittee make reasonable changes to the QIP if the QIP is found to have: (1) Failed to address the cause of the control device performance problems; or (2) Failed to provide adequate procedures for correcting control device performance problems as expeditiously as practicable in accordance with good air pollution control practices for minimizing emissions. [40 CFR 64.8(d), Minn. R ] Implementation of a QIP shall not excuse the Permittee from compliance with any existing emission limitation or standard, or any existing monitoring, testing, reporting or recordkeeping requirement that may apply. [40 CFR 64.8(e), Minn. R ] TREA 45 CE010 VRTO # The Permittee shall operate and maintain TREA 45 such that it achieves a control efficiency for Carbon Monoxide >= 90 percent control efficiency or less than or equal to 100 ppm. [CAAA of 1990, Title I Condition: 40 CFR 52.21(j)(BACT) & Minn. R ] The Permittee shall operate and maintain TREA 45 such that it achieves a control efficiency for Total Particulate Matter >= 90 percent control efficiency. [Title I Condition: 40 CFR 52.21(j)(BACT) & Minn. R ] The Permittee shall operate and maintain TREA 45 such that it achieves a control efficiency for PM < 10 micron >= 90 percent control efficiency. [Title I Condition: 40 CFR 52.21(j)(BACT) & Minn. R ] The Permittee shall operate and maintain TREA 45 such that it

193 Permit Expires: [month day, year] Page 191 of 243 achieves a control efficiency for Volatile Organic Compounds >= 95 percent control efficiency or no higher than 10 ppm outlet VOC concentration as total mass of VOC. [Title I Condition: 40 CFR 52.21(j)(BACT) & Minn. R ] The Permittee shall operate and maintain TREA 45 such that it achieves a control efficiency for Acetaldehyde >= 95 percent control efficiency. [Minn. R , Title I Condition: Avoid major source under 40 CFR 63.2] The Permittee shall operate and maintain TREA 45 such that it achieves a control efficiency for Acrolein >= 95 percent control efficiency. [Minn. R , Title I Condition: Avoid major source under 40 CFR 63.2] The Permittee shall operate and maintain TREA 45 such that it achieves a control efficiency for Formaldehyde >= 95 percent control efficiency. [Minn. R , Title I Condition: Avoid major source under 40 CFR 63.2] The Permittee shall operate and maintain TREA 45 such that it achieves a control efficiency for Methanol >= 95 percent control efficiency. [Minn. R , Title I Condition: Avoid major source under 40 CFR 63.2] Temperature >= 1600 degrees Fahrenheit as a 3 hour rolling average at the combustion chamber outlet, unless a new limit 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 limit shall be implemented upon receipt of the Notice of Compliance letter granting preliminary approval. The limit is final upon issuance of a permit amendment incorporating the change. If the 3 hour rolling average temperature is below the minimum temperature limit, the VOC used during that time shall be considered uncontrolled until the average temperature is above the minimum temperature limit. This shall be reported as a deviation. [Minn. R , Title I Condition: 40 CFR 52.21(j)(BACT) & Minn. R , Title I Condition: Avoid major source under 40 CFR 63.2] The Permittee shall operate and maintain the thermal oxidizer any time that any process equipment controlled by the thermal oxidizer is in operation. The Permittee shall document periods of non operation of the control equipment. [Minn. R , Title I Condition: 40 CFR 52.21(j)(BACT) & Minn. R , Title I Condition: Avoid major source under 40 CFR 63.2] The Permittee shall operate and maintain the thermal oxidizer in accordance with the Operation and Maintenance (O & M) Plan. The Permittee shall keep copies of the O & M Plan available onsite for use by staff and MPCA staff. [Minn. R , subp. 14] Monitoring Equipment: The Permittee shall install and maintain a thermocouple to conduct TREA 45 temperature

194 Permit Expires: [month day, year] Page 192 of 243 monitoring required by this permit. The monitoring equipment must be installed, in use, and properly maintained whenever operation of the monitored control equipment is required. [40 CFR 64.7(b), Minn. R , subp. 4, Minn. R ] The Permittee shall maintain and operate a thermocouple monitoring device that continuously indicates and records the TREA 45 combustion chamber temperature. The monitoring device shall have a margin of error less than the greater of +/ 0.75 percent of the temperature being measured or +/ 2.5 degrees Celsius (+/ 4.5 degrees Fahrenheit). The recording device shall also calculate the three hour rolling average TREA 45 combustion chamber temperature. Recorded values below the minimum temperature specified in this permit for TREA 45 are deviations as defined by Minn. R , subp. 8a. The Permittee may elect to monitor and record TREA 45 combustion chamber temperature on an hourly basis for determining operating hours when TREA 45 is operating below the required minimum temperature (for use in STRU 87 operating hours recordkeeping for when TREA 45 is operating below the required minimum temperature). [40 CFR 64.3(b)(4)(ii), Minn. R , subps. 4 5, Minn. R ] Daily Monitoring: The Permittee shall physically verify the operation of the TREA 45 temperature recording device at least once each operating day to verify that it is working and recording properly. The Permittee shall maintain a written record of the daily verifications. [40 CFR 64.3(b), Minn. R , subps. 4 5, Minn. R , Minn. R , Title I Condition: 40 CFR 52.21(j)(BACT) & Minn. R , Title I Condition: Avoid major source under 40 CFR 63.2] The Permittee shall maintain a continuous hard copy readout or computer disk file of the temperature readings and calculated three hour rolling average temperatures for the TREA 45 combustion chamber. [40 CFR 64.3, 40 CFR 64.9, Minn. R , subps. 4 5, Minn. R , Minn. R , Title I Condition: 40 CFR 52.21(j)(BACT) & Minn. R , Title I Condition: Avoid major source under 40 CFR 63.2] Quarterly Inspections: At least once per calendar quarter, or as required by the manufacturer, the Permittee shall inspect the control equipment internal and external system components, including but not limited to the refractory, heat exchanger, and electrical systems. The Permittee shall maintain a written record of the inspection and any corrective actions taken resulting from the inspection. [40 CFR 64.3, Minn. R.

195 Permit Expires: [month day, year] Page 193 of , subp. 14, Minn. R , subps. 4 5, Minn. R ] Annual Calibration: The Permittee shall calibrate the TREA 45 temperature monitor at least annually and shall maintain a written record of the calibration and any action resulting from the calibration. [40 CFR 64.3, Minn. R , subp. 14, Minn. R , subps. 4 5, Minn. R ] Corrective Actions: If the TREA 45 temperature is below the minimum specified by this permit or if TREA 45 or any of its components are found during the inspections to need repair, the Permittee shall take corrective action as soon as possible. Corrective actions shall return the temperature to at least the permitted minimum 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 thermal oxidizer. The Permittee shall keep a record of the type and date of any corrective action taken. [40 CFR 64.7(d)(1), Minn. R , subp. 14, Minn. R , subps. 4 5, Minn. R ] Documentation of Need for Improved Monitoring: If the Permittee fails to achieve compliance with an emission limitation or standard for which the monitoring did not provide an indication of an excursion or exceedance while providing valid data, or the results of compliance or performance testing document a need to modify the existing pressure drop range, the Permittee shall promptly notify the MPCA and, if necessary, submit a permit amendment application to address the necessary monitoring change. [40 CFR 64.7(e), Minn. R ] As required by 40 CFR Section 64.9(a)(2), for the Semi Annual Deviations Report and/or the Notification of Deviations Endangering Human Health and the Environment requirement in the Total Facility subject item of this permit, as applicable, the Permittee shall include the following related to the monitoring identified as required by 40 CFR pt. 64: 1) Summary information on the number, duration, and cause of excursions or exceedances, as applicable, and the corrective action taken; and, 2) Summary information on the number, duration, and cause for monitor downtime incidents. [40 CFR 64.9(a)(2), Minn. R ] The Permittee shall maintain records of monitoring data, monitor performance data, corrective actions taken, and other supporting information required to be maintained. The Permittee may maintain records on alternative media, such as microfilm, computer files, magnetic tape disks, or microfiche,

196 Permit Expires: [month day, year] Page 194 of 243 provided that the use of such alternative media allows for expeditious inspection and review, and does not conflict with other applicable recordkeeping requirements. [40 CFR 64.9(b), Minn. R ] Continued operation. Except for monitoring malfunctions, associated repairs, and required quality assurance or control activities, the Permittee shall conduct all monitoring in continuous operation (or shall collect data at all required intervals) at all times that the pollutant specific emissions unit is operating. Data recorded during monitoring malfunctions, associated repairs, and required quality assurance or control activities shall not be used for purposes of this part, including data averages and calculations, or fulfilling a minimum data availability requirement, if applicable. A monitoring malfunction is any sudden, infrequent, not reasonably preventable failure of the monitoring to provide valid data. Monitoring failures that are caused in part by poor maintenance or careless operation are not malfunctions. [40 CFR 64.7(c), Minn. R ] Response to excursions. Upon detecting an excursion, the Permittee shall restore operation of the pollutant specific emissions unit (including the control device and associated capture system) to its normal or usual manner of operation as expeditiously as practicable in accordance with good air pollution control practices for minimizing emissions. The response shall include minimizing the period of any startup, shutdown or malfunction and taking any necessary corrective actions to restore normal operation and prevent the likely recurrence of the cause of an excursion. Such actions may include initial inspection and evaluation, recording that operations returned to normal without operator action (such as through response by a computerized distribution control system), or any necessary follow up actions to return operation to within the indicator range, designated condition, or below the applicable emission limitation or standard, as applicable. [40 CFR 64.7(d), Minn. R , subp. 14, Minn. R ] Quality Improvement Plan (QIP) requirements. If there is an accumulation of 9 or more excursions during a calendar year, the Permittee must develop and implement a QIP in accordance with 40 CFR 64.8(b). The QIP must be available for inspection. [40 CFR 64.8, Minn. R ] If a QIP is required, the Permittee shall develop and implement the QIP as expeditiously as practicable and shall notify the MPCA if the period for completing the improvements contained in the QIP exceeds 180 days from the date on which the need to implement the QIP was determined. [40 CFR 64.8(c), Minn. R ] Following implementation of a QIP, the Administrator or the

197 Permit Expires: [month day, year] Page 195 of 243 MCPA may require that the Permittee make reasonable changes to the QIP if the QIP is found to have: (1) Failed to address the cause of the control device performance problems; or (2) Failed to provide adequate procedures for correcting control device performance problems as expeditiously as practicable in accordance with good air pollution control practices for minimizing emissions. [40 CFR 64.8(d), Minn. R ] Implementation of a QIP shall not excuse the Permittee from compliance with any existing emission limitation or standard, or any existing monitoring, testing, reporting or recordkeeping requirement that may apply. [40 CFR 64.8(e), Minn. R ] The Permittee shall not operate TREA 45 and TREA 11 simultaneously. TREA 11 shall replace TREA 45 at the facility upon initial startup of TREA 11. [Minn. R , subp. 2] TREA 46 CE011 Single Cyclone Pressure Drop >= 2.0 and <= 8.0 inches of water column. [Title I Condition: 40 CFR 52.21(j)(BACT) & Minn. R ] The Permittee shall operate and maintain TREA 46 such that it achieves an overall control efficiency for Total Particulate Matter >= 60 percent control efficiency. [Title I Condition: 40 CFR 52.21(j)(BACT) & Minn. R ] The Permittee shall operate and maintain TREA 46 such that it achieves an overall control efficiency for PM < 10 micron >= 60 percent control efficiency. [Title I Condition: 40 CFR 52.21(j)(BACT) & Minn. R ] 6. Submittal/action requirements This section lists most of the submittals required by this permit. Please note that some submittal requirements may appear in the Limits and Other Requirements section, or, if applicable, within a Compliance Schedule section. TFAC Heartland Corn Products The Permittee shall submit an annual report : Due 31 calendar days after 12/31/2014 annually starting 03/06/2014. The Permittee shall submit an annual report by January 31st that describes the changes made at the facility during the previous calendar year. The report shall be submitted using current MPCA air permit application forms. The report shall include the EQUI, STRU, COMG, and TREA data for any new, modified, or

198 Permit Expires: [month day, year] Page 196 of 243 replaced emission units. The report shall include the 12 month rolling sum emission calculations for each month in the previous calendar year for all pollutants limited by this permit on a 12 month rolling sum basis (single and total HAP). The report shall be submitted with the annual Compliance Certification listed in Table B. 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 pt. 63. [Minn. R , subp. 2] The Permittee shall submit a submittal : Due by 60 days after permit issuance to update CAM Plans for TREA 3, 11, 16, 29 34, 43 and 44. Updates to CAM Plans shall reflect all applicable requirements, including BACT limits, modeling limits, federal and state standards of performance, and shall reflect all subject criteria pollutants (i.e. PM2.5). [40 CFR 64.4, Minn. R , subp. 2] The Permittee shall submit an application for permit reissuance : Due 180 calendar days before Permit Expiration Date. [Minn. R , subp. 2] The Permittee shall submit a semiannual deviations report : Due semiannually, by the 30th of January and July 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. [Minn. R , subp. 6(A)(2)] The Permittee shall submit a compliance schedule progress report : Due semiannually, by the 30th of January and July The Compliance Schedule Progress Report shall contain the information specified in Minn. R , subp. 6(B) and shall be submitted on a form approved by the Commissioner in accordance with the Compliance Schedule contained in this permit. Progress Reports will not be needed upon completion of all activities contained in the Compliance Schedule. [Minn. R , subp. 6(B)] The Permittee shall submit a compliance certification : Due annually, by the 31st of January (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. [Minn. R , subp. 6(C)] The Permittee shall submit a computer dispersion modeling protocol : Due by 60 days after permit issuance for PM10 and PM2.5 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

199 Permit Expires: [month day, year] Page 197 of 243 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. [Minn. R , subp. 7(A), 7(L), & 7(M), Minn. R , subp. 4, Minn. R , subps. 1 2, Minn. R , Minn. Stat , subd. 4a, Minn. Stat , subd. 9] The Permittee shall submit a computer dispersion modeling protocol : Due 30 calendar days after Date of receipt of written MPCA request for revisions to the submitted protocol for PM10 and PM2.5 modeling. [Minn. R , subp. 7(A), 7(L), & 7(M), Minn. R , subp. 2, Minn. Stat , subd. 4a, Minn. Stat , subd. 9] The Permittee shall submit computer dispersion modeling results : Due 60 calendar days after Date of receipt of written MPCA approval of Computer Dispersion Modeling Protocol for PM10 and PM2.5 refined modeling. 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. [Minn. R , subp. 7(A), 7(L), & 7(M), Minn. R , subp. 2, Minn. Stat , subd. 4a, Minn. Stat , subd. 9] COMG 7 GP001 Storage Tanks Subject To NSPS Subp. Kb The Permittee shall submit notification of the date construction of replacement began : Due 60 calendar days before Date of Construction or Replacement (or as soon as practicable). Submit the information specified in 40 CFR Section 60.15(d)(1) through (7). [40 CFR 60.15(d), Minn. R ] COMG 9 GP009 Leaks From Equipment In VOC Service subp. VVa The Permittee shall submit a notification of date construction began : Due 30 calendar days after Date of Construction Start (or reconstruction) of EQUI 161. Submit the name and number of the Subject Item and the date construction began. [40 CFR 60.7(a)(1), Minn. R , subp. 1] The Permittee shall submit a report : Due semiannually, by the 31st of January and July that includes the information specified in 40 CFR Section and that is summarized at COMG 9 in this permit. [40 CFR a(a)] EQUI 4 EU018 Boiler #1 East

200 Permit Expires: [month day, year] Page 198 of 243 Plant Boiler The Permittee shall conduct performance test : Due 06/05/2019 every 60 months to measure CO emissions in lb/mmbtu. Testing is due by the end of each 60 month period following 06/05/2019. The performance test shall be conducted at worst case conditions as defined at Minn. R , subp. 8 using EPA Reference Method 10 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: 1) 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. [Minn. R , subp. 1, Title I Condition: 40 CFR 52.21(j)(BACT) & Minn. R ] The Permittee shall conduct performance test : Due 06/05/2019 every 60 months to measure NOx emissions in lb/mmbtu. Testing is due by the end of each 60 month period following 06/05/2019. The performance test shall be conducted at worst case conditions as defined at Minn. R , subp. 8 using EPA Reference Method 7E 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: 1) 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. [Minn. R , subp. 1, Title I Condition: 40 CFR 52.21(j)(BACT) & Minn. R ] EQUI 6 EU034 Boiler #2 East Plant Boiler The Permittee shall conduct performance test : Due 06/05/2019 every 60 months to measure CO emissions in lb/mmbtu. Testing is due by the end of each 60 month period following 06/05/2019. The performance test shall be conducted at worst case conditions as defined at Minn. R , subp. 8 using EPA Reference Method 10 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: 1) by

201 Permit Expires: [month day, year] Page 199 of 243 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. [Minn. R , subp. 1, Title I Condition: 40 CFR 52.21(j)(BACT) & Minn. R ] EQUI 11 EU048 Corn Dump Pit/Auger #2 Captured Emissions Material Handling Equipment The Permittee shall submit : Due by 60 days after permit issuance a hood certification for the EQUI 11 control device hood for review and approval by MPCA that conforms to the requirements of the reference listed in Minn. R The Permittee shall submit the results of the evaluation and certification on forms HE 01 and CR 02 no later than 60 days after issuance of permit no [Minn. R , subp. 14, Minn. R , subps. 4 5] EQUI 29 EU093 Corn Dump Pit/Auger #3 Captured Emissions Material Handling Equipment The Permittee shall submit : Due by 60 days after permit issuance a hood certification for EQUI 29 control device hood for review and approval by MPCA that conforms to the requirements of the reference listed in Minn. R The Permittee shall submit the results of the evaluation and certification on forms HE 01 and CR 02 no later than 60 days after issuance of permit no [Minn. R , subp. 14, Minn. R , subps. 4 5] EQUI 51 EU074 Utility Boiler #3 West Plant Boiler The Permittee shall conduct performance test : Due 10/29/2016 every 36 months to measure NOx emissions in lb/mmbtu, not to exceed 36 months between test dates. Testing is due by the end of each 36 month period following the initial performance test date.

202 Permit Expires: [month day, year] Page 200 of 243 This 36 month test interval shall change to a 12 month interval commencing on the date of any test that causes the average measured NOx emission rate from the three most recent tests to equal or exceed lb NOx/mmBtu heat input. The performance test shall be conducted at worst case conditions as defined at Minn. R , subp. 8, using EPA Reference Method 7E, 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: 1) 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. [Minn. R , subp. 1, Title I Condition: 40 CFR 52.21(j)(BACT) & Minn. R ] EQUI 52 EU075 Utility Boiler #4 West Plant Boiler The Permittee shall conduct performance test : Due 10/29/2016 every 36 months to measure NOx emissions in lb/mmbtu, not to exceed 36 months between test dates. Testing is due by the end of each 36 month period following the initial performance test date. This 36 month test interval shall change to a 12 month interval commencing on the date of any test that causes the average measured NOx emission rate from the three most recent tests to equal or exceed lb NOx/mmBtu heat input. The performance test shall be conducted at worst case conditions as defined at Minn. R , subp. 8, using EPA Reference Method 7E, 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: 1) 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. [Minn. R , subp. 1, Title I Condition: 40 CFR

203 Permit Expires: [month day, year] Page 201 of (j)(BACT) & Minn. R ] EQUI 75 TK014/TK 2508 Denatured or 200 proof Ethanol Tank #4 (2 mmgal) The Permittee shall submit notification of the date construction of replacement began : Due 60 calendar days before Date of Construction or Replacement (or as soon as practicable). Submit the information specified in 40 CFR Section 60.15(d)(1) through (7). [40 CFR 60.15(d), Minn. R ] EQUI 179 EU031 DDGS Cooling Cyclone (CE011) East Plant The Permittee shall submit a notification of equipment removal/dismantlement : Due 30 calendar days after Date of Shutdown of EQUI 179 and STRU 88. The notification shall be postmarked within 30 days of actual shutdown of EQUI 179 and STRU 88. The requirements in the permit applicable to EQUI 179 remain effective until shutdown of EQUI 179 and STRU 88 occurs. [Minn. R , subp. 2] FUGI 13 FS002 East Plant Grain & DDGS Uncaptured Emissions The Permittee shall submit a notification of equipment removal/dismantlement : Due 30 calendar days after Date of Shutdown of FUGI 13. The notification shall be postmarked within 30 days of actual shutdown of FUGI 13. The requirements in the permit applicable to FUGI 13 remain effective until shutdown of FUGI 13 occurs. [Minn. R , subp. 2] FUGI 14 FS005 East Plant Cooling Towers The Permittee shall submit a notification of equipment removal/dismantlement : Due 30 calendar days after Date of Shutdown of FUGI 14. The notification shall be postmarked within 30 days and include the date of actual shutdown of FUGI 14 and date of initial startup of FUGI 11. The requirements in the permit applicable to FUGI 14 remain effective until shutdown of FUGI 14 occurs. [Minn. R , subp. 2] FUGI 15 FS006 West Plant Cooling Towers The Permittee shall submit a notification of equipment removal/dismantlement : Due 30 calendar days after Date of Shutdown of FUGI 15. The notification shall be postmarked

204 Permit Expires: [month day, year] Page 202 of 243 within 30 days and include the date of actual shutdown of FUGI 15 and date of initial startup of FUGI 12. The requirements in the permit applicable to FUGI 15 remain effective until shutdown of FUGI 15 occurs. [Minn. R , subp. 2] STRU 7 SV024 DDGS Handling Baghouse (CE 035) The Permittee shall submit : Due by 60 days after permit issuance a hood certification for the STRU 7 control device hood for review and approval by MPCA that conforms to the requirements of the reference listed in Minn. R The Permittee shall submit the results of the evaluation and certification on forms HE 01 and CR 02 no later than 60 days after issuance of permit no [Minn. R , subp. 14, Minn. R , subps. 4 5] The Permittee shall conduct initial performance test : Due by 180 days after permit issuance to measure Total Particulate Matter emissions in gr/dscf and lb/hr. The performance test shall be conducted at worst case conditions as defined at Minn. R , subp. 8 (i.e. at least 90% of 220 ton/hr DDGS throughput), using EPA Methods 5 and 202, or other method approved by MPCA in the performance test plan approval. [Minn. R , subp. 1, Title I Condition: 40 CFR 52.21(j)(BACT) & Minn. R , Title I Condition: Avoid major source under 40 CFR 52.21(b)(1)(i) & Minn. R ] The Permittee shall conduct initial performance test : Due by 180 days after permit issuance to measure PM10 emissions in gr/dscf and lb/hr. The performance test shall be conducted at worst case conditions as defined at Minn. R , subp. 8 (i.e. at least 90% of 220 ton/hr DDGS throughput), using EPA Methods 5 and 202, Methods 201A and 202, or other method approved by MPCA in the performance test plan approval. [Minn. R , subp. 1, Title I Condition: 40 CFR 52.21(j) & (k)(bact) & Minn. R , Title I Condition: Avoid major source under 40 CFR 52.21(b)(1)(i) & Minn. R ] The Permittee shall conduct initial performance test : Due by 180 days after permit issuance to measure PM2.5 emissions in gr/dscf and lb/hr. The performance test shall be conducted at worst case conditions as defined at Minn. R , subp. 8 (i.e. at least 90% of 220 ton/hr DDGS throughput), using EPA Methods 5 and 202, Methods 201A and 202, or other method approved by MPCA in the performance test plan approval. [Minn. R , subp. 1, Title I Condition: Avoid major source under 40 CFR 52.21(b)(1)(i) & Minn. R ] The Permittee shall submit a test frequency plan : Due 60 calendar days after Initial Performance Test Date for Total Particulate Matter emissions. The plan shall specify a testing frequency based on the test data and MPCA guidance. Future

205 Permit Expires: [month day, year] Page 203 of 243 performance tests based on 12 month, 36 month, or 60 month intervals, or as applicable, shall be required upon written approval of the MPCA. [Minn. R , subp. 1] The Permittee shall submit a test frequency plan : Due 60 calendar days after Initial Performance Test Date for PM10 emissions. The plan shall specify a testing frequency based on the test data and MPCA guidance. Future performance tests based on 12 month, 36 month, or 60 month intervals, or as applicable, shall be required upon written approval of the MPCA. [Minn. R , subp. 1] The Permittee shall submit a test frequency plan : Due 60 calendar days after Initial Performance Test Date for PM2.5 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. [Minn. R , subp. 1] STRU 9 SV026 VRTO #1 Stack East Plant (CE 036) The Permittee shall conduct initial performance test : Due 180 calendar days after Initial Startup Date of EQUI 162 to measure Total Particulate Matter emissions in gr/dscf and lb/hr. The performance test shall be conducted at worst case conditions as defined at Minn. R , subp. 8, using EPA Reference Methods 5 and 202, or other method approved by MPCA in the performance test plan approval. [Minn. R , subp. 1, Title I Condition: 40 CFR 52.21(j)(BACT) & Minn. R ] The Permittee shall conduct initial performance test : Due 180 calendar days after Initial Startup Date of EQUI 162 to measure PM10 emissions in gr/dscf and lb/hr. The performance test shall be conducted at worst case conditions as defined at Minn. R , subp. 8, using EPA Reference Methods 5 and 202, Methods 201A and 202, or other method approved by MPCA in the performance test plan approval. [Minn. R , subp. 1, Title I Condition: 40 CFR 52.21(j) & (k)(bact) & Minn. R , Title I Condition: Avoid major source under 40 CFR 52.21(b)(1)(i) & Minn. R ] The Permittee shall conduct initial performance test : Due 180 calendar days after Initial Startup Date of EQUI 162 to measure PM2.5 emissions in gr/dscf and lb/hr. The performance test shall be conducted at worst case conditions as defined at Minn. R , subp. 8, using EPA Reference Methods 5 and 202, Methods 201A and 202, or other method approved by MPCA in the performance test plan approval. [Minn. R , subp. 1, Title I Condition: Avoid major source under 40 CFR 52.21(b)(1)(i) & Minn. R ] The Permittee shall conduct initial performance test : Due 180

206 Permit Expires: [month day, year] Page 204 of 243 calendar days after Initial Startup Date of EQUI 162 to measure total NOx emissions on both a lbs/hour basis and a parts per million by volume on a wet basis. The performance test shall be conducted at worst case conditions as defined at Minn. R , subp. 8, using EPA Reference Method 7E or other method approved by MPCA in the performance test plan approval. [Minn. R , subp. 1, Title I Condition: 40 CFR 52.21(j)(BACT) & Minn. R ] The Permittee shall conduct initial performance test : Due 180 calendar days after Initial Startup Date of EQUI 162 to measure SO2 emissions in lb/hr. The performance test shall be conducted at worst case conditions as defined at Minn. R , subp. 8, using EPA Reference Method 6C or other method approved by MPCA in the performance test plan approval. [Minn. R , subp. 1, Title I Condition: Avoid major modification under 40 CFR 52.21(b)(23)(i) & Minn. R ] The Permittee shall conduct initial performance test : Due 180 calendar days after Initial Startup Date of EQUI 162 to measure VOC emissions on a mass basis in lb/hr. The performance test shall be conducted at worst case conditions as defined at Minn. R , subp. 8, using EPA Reference Method 18, 25A, 320, or other method approved by MPCA in the performance test plan approval. [Minn. R , subp. 1, Title I Condition: 40 CFR 52.21(j)(BACT) & Minn. R ] The Permittee shall conduct initial performance test : Due 180 calendar days after Initial Startup Date of EQUI 162 to measure CO emissions in lb/hr. The performance test shall be conducted at worst case conditions as defined at Minn. R , subp. 8, using EPA Reference Method 10 or other method approved by MPCA in the performance test plan approval. [Minn. R , subp. 1, Title I Condition: 40 CFR 52.21(j)(BACT) & Minn. R ] The Permittee shall conduct initial performance test : Due 180 calendar days after Initial Startup Date of EQUI 162 to measure HAP emissions. Testing must include all chemicals listed in Appendix D of this permit. The performance test shall be conducted at worst case conditions as defined at Minn. R , subp. 8, using EPA Reference Method 18, 320, or other method approved by MPCA in the performance test plan approval. [Minn. R , Minn. R , subp. 1, Title I Condition: Avoid major source under 40 CFR 63.2] The Permittee shall submit a test frequency plan : Due 60 calendar days after Initial Performance Test Date for PM2.5 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. [Minn. R , subp. 1] The Permittee shall submit a test frequency plan : Due 60

207 Permit Expires: [month day, year] Page 205 of 243 calendar days after Initial Performance Test Date for PM10 emissions. The plan shall specify a testing frequency based on the test data and MPCA guidance. Future performance tests based on 12 month, 36 month, or 60 month intervals, or as applicable, shall be required upon written approval of the MPCA. [Minn. R , subp. 1] The Permittee shall submit a test frequency plan : Due 60 calendar days after Initial Performance Test Date for Total Particulate Matter 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. [Minn. R , subp. 1] The Permittee shall submit a test frequency plan : Due 60 calendar days after Initial Performance Test Date for NOx 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. [Minn. R , subp. 1] The Permittee shall submit a test frequency plan : Due 60 calendar days after Initial Performance Test Date for SO2 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. [Minn. R , subp. 1] The Permittee shall submit a test frequency plan : Due 60 calendar days after Initial Performance Test Date for VOC 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. [Minn. R , subp. 1] The Permittee shall submit a test frequency plan : Due 60 calendar days after Initial Performance Test Date for CO 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. [Minn. R , subp. 1] The Permittee shall submit a test frequency plan : Due 60 calendar days after Initial Performance Test Date for HAP 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. [Minn. R , subp. 1]

208 Permit Expires: [month day, year] Page 206 of 243 STRU 10 SV027 DDGS Handling Baghouse #2 (CE 037) The Permittee shall submit : Due by 60 days after permit issuance a hood certification for the STRU 10 control device hood for review and approval by MPCA that conforms to the requirements of the reference listed in Minn. R The Permittee shall submit the results of the evaluation and certification on forms HE 01 and CR 02 no later than 60 days after issuance of permit no [Minn. R , subp. 14, Minn. R , subps. 4 5] The Permittee shall conduct initial performance test : Due 180 calendar days after Initial Startup Date to measure PM10 emissions in gr/dscf and lb/hr. The performance test shall be conducted at worst case conditions as defined at Minn. R , subp. 8 (i.e. at least 90% of 125 tons/hr DDGS throughput), using EPA Methods 5 and 202, Methods 201A and 202, or other method approved by MPCA in the performance test plan approval. [Minn. R , subp. 1, Title I Condition: 40 CFR 52.21(k)(1)(i) & Minn. R , Title I Condition: Avoid major source under 40 CFR 52.21(b)(1)(i) & Minn. R ] The Permittee shall conduct initial performance test : Due 180 calendar days after Initial Startup Date to measure PM2.5 emissions in gr/dscf and lb/hr. The performance test shall be conducted at worst case conditions as defined at Minn. R , subp. 8 (i.e. at least 90% of 125 tons/hr DDGS throughput), using EPA Methods 5 and 202, Methods 201A and 202, or other method approved by MPCA in the performance test plan approval. [Minn. R , subp. 1, Title I Condition: Avoid major source under 40 CFR 52.21(b)(1)(i) & Minn. R ] The Permittee shall submit a test frequency plan : Due 60 calendar days after Initial Performance Test Date for PM10 emissions. The plan shall specify a testing frequency based on the test data and MPCA guidance. Future performance tests based on 12 month, 36 month, or 60 month intervals, or as applicable, shall be required upon written approval of the MPCA. [Minn. R , subp. 1] The Permittee shall submit a test frequency plan : Due 60 calendar days after Initial Performance Test Date for PM2.5 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. [Minn. R , subp. 1] STRU 11 SV028 Combustion Turbine with

209 Permit Expires: [month day, year] Page 207 of 243 Duct Burner The Permittee shall conduct initial performance test : Due 180 calendar days after Initial Startup Date of EQUI 164 and EQUI 165 (includes duct burner and HRSG) for NOx in accordance with 40 CFR Sections 60.8 and The performance test shall be conducted while EQUI 164 and EQUI 165 (includes duct burner and HRSG) are operating at worst case conditions as defined at Minn. R , subp. 8, using EPA Reference Method 7E, or other method approved by MPCA in the performance test plan approval. [40 CFR , 40 CFR 60.8(a), Minn. R , subp. 1] The Permittee shall conduct initial performance test : Due 180 calendar days after Initial Startup Date of EQUI 164 and EUQI 165 to measure PM10 emissions. The performance test shall be conducted at worst case conditions as defined at Minn. R , subp. 8, using EPA Reference Methods 5 and 202, Methods 201A and 202, or other method approved by MPCA in the performance test plan approval. [Minn. R , subp. 1, Title I Condition: 40 CFR 52.21(k)(1) & Minn. R , Title I Condition: Avoid major source under 40 CFR 52.21(b)(1)(i) & Minn. R ] The Permittee shall conduct initial performance test : Due 180 calendar days after Initial Startup Date of EQUI 164 and EQUI 165 to measure PM2.5 emissions. The performance test shall be conducted at worst case conditions as defined at Minn. R , subp. 8, using EPA Reference Methods 5 and 202, Methods 201A and 202, or other method approved by MPCA in the performance test plan approval. [Minn. R , subp. 1, Title I Condition: Avoid major source under 40 CFR 52.21(b)(1) & Minn. R ] The Permittee shall submit a test frequency plan : Due 60 calendar days after Initial Performance Test Date for PM10 emissions. The plan shall specify a testing frequency based on the performance test results for PM10 and MPCA guidance. Future performance tests at 12 month, 36 month, or 60 month intervals, or as applicable, shall be required upon written approval of the test frequency plan. [Minn. R , subp. 1] The Permittee shall submit a test frequency plan : Due 60 calendar days after Initial Performance Test Date for PM2.5 emissions. The plan shall specify a testing frequency based on the performance test results for PM2.5 and MPCA guidance. Future performance tests at 12 month, 36 month, or 60 month intervals, or as applicable, shall be required upon written approval of the test frequency plan. [Minn. R , subp. 1] The Permittee shall submit a notification of the date construction began : Due 30 calendar days after Date of Construction Start. Submit the name and number of each unit

210 Permit Expires: [month day, year] Page 208 of 243 and the date construction of each unit began. The Permittee shall submit the notification both to the Commissioner and to the US EPA regional office in Chicago. [40 CFR 60.7(a)(1), Minn. R , subp. 1] The Permittee shall submit a notification of the actual date of initial startup : Due 15 calendar days after Initial Startup Date. The Permittee shall submit the notification both to the Commissioner and to the US EPA regional office in Chicago. [40 CFR 60.7(a)(3), Minn. R , subp. 1] STRU 15 SV032 West Plant DDGS Loadout Captured Emissions The Permittee shall submit : Due by 60 days after permit issuance a hood certification for the STRU 15 control device hood for review and approval by MPCA that conforms to the requirements of the reference listed in Minn. R The Permittee shall submit the results of the evaluation and certification on forms HE 01 and CR 02 no later than 60 days after issuance of permit no [Minn. R , subp. 14, Minn. R , subps. 4 5] STRU 16 SV033 West Plant DDGS Truck Loading Building Captured Emissions The Permittee shall submit : Due 60 calendar days after Initial Startup Date of STRU 16 a hood certification for the STRU 16 control device hood for review and approval by MPCA that conforms to the requirements of the reference listed in Minn. R The Permittee shall submit the results of the evaluation and certification on forms HE 01 and CR 02 no later than 60 days after initial startup date of STRU 16. [Minn. R , subp. 14, Minn. R , subps. 4 5] STRU 68 SV016 West Plant CO2 Scrubber (CE 008) The Permittee shall conduct performance test : Due 08/16/2018 every 36 months to measure VOC emissions on a mass basis in lb/hr, not to exceed 36 months between test dates. Testing is due by the end of each 36 month period following 08/16/2018. The performance test shall be conducted at worst case conditions as defined at Minn. R , subp. 8 (i.e. at least 90% of 1237 gallons/minute beer produced), using EPA Reference Method 18, 25A, 320, or other method approved by MPCA in the performance test plan approval.

211 Permit Expires: [month day, year] Page 209 of 243 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: 1) 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. [Minn. R , subp. 1, Title I Condition: 40 CFR 52.21(j)(BACT) & Minn. R ] The Permittee shall conduct performance test : Due 90 calendar days after Equipment Installation Date to measure VOC emissions on a mass basis in lb/hr. 'Equipment Installation' is the installation of new equipment, modification of existing equipment, and/or replacement of existing equipment with higher capacity same function equipment. 'Equipment Installation' does not include replacement of existing equipment where the replacement equipment meets the Replacement Unit criteria specified at 40 CFR Section 52.21(b)(33) paragraphs (ii), (iii), and (iv) and the replacement emission unit completely takes the place of the existing emission unit. The performance test shall be conducted at worst case conditions as defined at Minn. R , subp. 8 (i.e. at least 90% of 1237 gallons/minute beer produced), using EPA Reference Method 18, 25A, 320, 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: 1) 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. [Minn. R , subp. 1, Title I Condition: Avoid major source under 40 CFR 52.21(b)(1)(i) & Minn. R ] The Permittee shall conduct performance test : Due 08/16/2018 every 36 months to measure HAP emissions, not to exceed 36 months between test dates. Testing must include all chemicals listed in Appendix D to this permit. Testing is due by the end of each 36 month period following 08/16/2018. The performance test shall be conducted at worst case conditions as defined at Minn. R , subp. 8 (i.e. at least 90% of 1237 gallons/minute beer produced), using EPA Reference Method

212 Permit Expires: [month day, year] Page 210 of , 320, 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: 1) 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. [Minn. R , Minn. R , subp. 1, Title I Condition: Avoid major source under 40 CFR 63.2] The Permittee shall conduct performance test : Due 90 calendar days after Equipment Installation Date to measure HAP emissions. Testing must include all chemicals listed in Appendix D to this permit. STRU 69 SV007 East Plant Distillation Scrubber (CE 005) 'Equipment Installation' is the installation of new equipment, modification of existing equipment, and/or replacement of existing equipment with higher capacity same function equipment. 'Equipment Installation' does not include replacement of existing equipment where the replacement equipment meets the Replacement Unit criteria specified at 40 CFR Section 52.21(b)(33) paragraphs (ii), (iii), and (iv) and the replacement emission unit completely takes the place of the existing emission unit. The performance test shall be conducted at worst case conditions as defined at Minn. R , subp. 8 (i.e. at least 90% of 1237 gallons/minute beer produced), using EPA Reference Method 18, 320, 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: 1) 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. [Minn. R , Minn. R , subp. 1, Title I Condition: Avoid major source under 40 CFR 63.2]

213 Permit Expires: [month day, year] Page 211 of The Permittee shall conduct performance test : Due 06/05/2017 every 36 months to measure VOC emissions on a mass basis in lb/hr, not to exceed 36 months between test dates. Testing is due by the end of each 36 month period following 06/05/2017. The performance test shall be conducted at worst case conditions as defined at Minn. R , subp. 8 (i.e. at least 90% of 73 gallons/minute 200 proof ethanol produced), using EPA Reference Method 18, 25A, 320, 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: 1) 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. [Minn. R , subp. 1, Title I Condition: 40 CFR 52.21(j)(BACT) & Minn. R ] The Permittee shall conduct performance test : Due 90 calendar days after Equipment Installation Date to measure VOC emissions on a mass basis in lb/hr. 'Equipment Installation' is the installation of new equipment, modification of existing equipment, and/or replacement of existing equipment with higher capacity same function equipment. 'Equipment Installation' does not include replacement of existing equipment where the replacement equipment meets the Replacement Unit criteria specified at 40 CFR Section 52.21(b)(33) paragraphs (ii), (iii), and (iv) and the replacement emission unit completely takes the place of the existing emission unit. The performance test shall be conducted at worst case conditions as defined at Minn. R , subp. 8 (i.e. at least 90% of 73 gallons/minute 200 proof ethanol produced), using EPA Reference Method 18, 25A, 320, 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: 1) 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. [Minn. R , subp. 1, Title I Condition: Avoid major

214 Permit Expires: [month day, year] Page 212 of 243 source under 40 CFR 52.21(b)(1)(i) & Minn. R ] The Permittee shall conduct performance test : Due 06/05/2017 every 36 months to measure HAP emissions, not to exceed 36 months between test dates. Testing must include all chemicals listed in Appendix D of this permit. Testing is due by the end of each 36 month period following 06/05/2017. The performance test shall be conducted at worst case conditions as defined at Minn. R , subp. 8 (i.e. at least 90% of 73 gallons/minute 200 proof ethanol produced), using EPA Reference Method 18, 320, 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: 1) 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. [Minn. R , Minn. R , subp. 1, Title I Condition: Avoid major source under 40 CFR 63.2] The Permittee shall conduct performance test : Due 90 calendar days after Equipment Installation Date to measure HAP emissions. Testing must include all chemicals listed in Appendix D to this permit. 'Equipment Installation' is the installation of new equipment, modification of existing equipment, and/or replacement of existing equipment with higher capacity same function equipment. 'Equipment Installation' does not include replacement of existing equipment where the replacement equipment meets the Replacement Unit criteria specified at 40 CFR Section 52.21(b)(33) paragraphs (ii), (iii), and (iv) and the replacement emission unit completely takes the place of the existing emission unit. The performance test shall be conducted at worst case conditions as defined at Minn. R , subp. 8 (i.e. at least 90% of 73 gallons/minute 200 proof ethanol produced), using EPA Reference Method 18, 320, 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: 1) 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

215 Permit Expires: [month day, year] Page 213 of 243 performance test due date satisfies this test due date requirement and will reset the performance test due date. [Minn. R , Minn. R , subp. 1, Title I Condition: Avoid major source under 40 CFR 63.2] STRU 70 SV018 VRTO #2 West Plant (CE 012) The Permittee shall conduct performance test : Due 06/05/2017 every 36 months to measure total NOx emissions on both a lbs/hour basis and a parts per million by volume on a wet basis, not to exceed 36 months between test dates. Testing is due by the end of each 36 month period following 06/05/2017. The performance test shall be conducted at worst case conditions as defined at Minn. R , subp. 8, using EPA Reference Method 7E 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: 1) 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. [Minn. R , subp. 1, Title I Condition: 40 CFR 52.21(j)(BACT) & Minn. R ] The Permittee shall conduct performance test : Due 09/12/2017 every 60 months to measure Total Particulate Matter emissions in gr/dscf and lb/hr, not to exceed 60 months between test dates. Testing is due by the end of each 60 month period following 09/12/2017. The performance test shall be conducted at worst case conditions as defined at Minn. R , subp. 8, using EPA Reference Methods 5 and 202, 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: 1) 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. [Minn. R , subp. 1, Title I Condition: 40 CFR 52.21(j)(BACT) & Minn. R ] The Permittee shall conduct performance test : Due 09/12/2017 every 60 months to measure PM10 emissions in lb/hr, not to exceed 60 months between test dates. Testing is due by the end

216 Permit Expires: [month day, year] Page 214 of 243 of each 60 month period following 09/12/2017. The performance test shall be conducted at worst case conditions as defined at Minn. R , subp. 8, using EPA Reference Methods 5 and 202, Methods 201A and 202, 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: 1) 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. [Minn. R , subp. 1, Title I Condition: 40 CFR 52.21(j) & (k)(bact) & Minn. R , Title I Condition: Avoid major source under 40 CFR 52.21(b)(1)(i) & Minn. R ] The Permittee shall conduct initial performance test : Due by 180 days after permit issuance to measure PM2.5 emissions in lb/hr. The performance test shall be conducted at worst case conditions as defined at Minn. R , subp. 8, using EPA Reference Methods 5 and 202, Methods 201A and 202, or other method approved by MPCA in the performance test plan approval. [Minn. R , subp. 1, Title I Condition: Avoid major source under 40 CFR 52.21(b)(1)(i) & Minn. R ] The Permittee shall conduct performance test : Due 09/12/2017 every 60 months to measure SO2 emissions in lb/hr, not to exceed 60 months between test dates. Testing is due by the end of each 60 month period following 09/12/2017. The performance test shall be conducted at worst case conditions as defined at Minn. R , subp. 8, using EPA Reference Method 6C 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: 1) 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. [Minn. R , subp. 1, Title I Condition: Avoid major modification under 40 CFR 52.21(b)(23)(i) & Minn. R ] The Permittee shall conduct performance test : Due 09/12/2017 every 60 months to measure VOC emissions on a mass basis in lb/hr, not to exceed 60 months between test dates. Testing is due by the end of each 60 month period following 09/12/2017.

217 Permit Expires: [month day, year] Page 215 of 243 The performance test shall be conducted at worst case conditions as defined at Minn. R , subp. 8, using EPA Reference Method 18, 25A, 320, 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: 1) 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. [Minn. R , subp. 1, Title I Condition: 40 CFR 52.21(j)(BACT) & Minn. R ] The Permittee shall conduct performance test : Due 09/12/2017 every 60 months to measure CO emissions in lb/hr, not to exceed 60 months between test dates. Testing is due by the end of each 60 month period following 09/12/2017. The performance test shall be conducted at worst case conditions as defined at Minn. R , subp. 8, using EPA Reference Method 10 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: 1) 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. [Minn. R , subp. 1, Title I Condition: 40 CFR 52.21(j)(BACT) & Minn. R ] The Permittee shall conduct performance test : Due 09/12/2017 every 60 months to measure HAP emissions, not to exceed 60 months between test dates. Testing must include all chemicals listed in Appendix D of this permit. Testing is due by the end of each 60 month period following 09/12/2017. The performance test shall be conducted at worst case conditions as defined at Minn. R , subp. 8, using EPA Reference Method 18, 320, 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: 1) by this permit; 2) by the most recently approved Performance Test Frequency Plan; or 3) within a Notice of Compliance letter.

218 Permit Expires: [month day, year] Page 216 of 243 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. [Minn. R , Minn. R , subp. 1, Title I Condition: Avoid major source under 40 CFR 63.2] The Permittee shall submit a test frequency plan : Due 60 calendar days after Initial Performance Test Date for PM2.5 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. [Minn. R , subp. 1] STRU 71 SV014 Grain Handling West Plant (CE 006) The Permittee shall conduct performance test : Due by 180 days after permit issuance to measure Total Particulate Matter emissions with the doors closed in gr/dscf and lb/hr. The performance test shall be conducted at worst case conditions as defined at Minn. R , subp. 8 (i.e. at least 90% of 700 tons/hr grain throughput and at least one straight truck per hour for each one hour test), using EPA Methods 5 and 202, or other method approved by MPCA in the performance test plan approval. [Minn. R , subp. 1, Title I Condition: 40 CFR 52.21(j)(BACT) & Minn. R , Title I Condition: Avoid major source under 40 CFR 52.21(b)(1)(i) & Minn. R ] The Permittee shall conduct performance test : Due 90 calendar days after Equipment Installation Date to measure Total Particulate Matter emissions in gr/dscf and lb/hr. 'Equipment Installation' is the installation of new equipment, modification of existing equipment, and/or replacement of existing equipment with higher capacity same function equipment. 'Equipment Installation' does not include replacement of existing equipment where the replacement equipment meets the Replacement Unit criteria specified at 40 CFR Section 52.21(b)(33) paragraphs (ii), (iii), and (iv) and the replacement emission unit completely takes the place of the existing emission unit. The performance test shall be conducted at worst case conditions as defined at Minn. R , subp. 8 (i.e. at least 90% of 700 tons/hr grain throughput with the doors closed and at least one straight truck per hour for each one hour test), using EPA Reference Methods 5 and 202, or other method approved by MPCA in the performance test plan approval. Testing conducted during the 60 days prior to the performance

219 Permit Expires: [month day, year] Page 217 of 243 test due date satisfies the performance test due date, and will not reset the test due date for future testing as required: 1) 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. [Minn. R , subp. 1, Title I Condition: 40 CFR 52.21(j)(BACT) & Minn. R , Title I Condition: Avoid major source under 40 CFR 52.21(b)(1)(i) & Minn. R ] The Permittee shall conduct performance test : Due by 180 days after permit issuance to measure PM10 emissions with the doors closed in gr/dscf and lb/hr. The performance test shall be conducted at worst case conditions as defined at Minn. R , subp. 8 (i.e. at least 90% of 700 tons/hr grain throughput and at least one straight truck per hour for each one hour test), using EPA Methods 5 and 202, Methods 201A and 202, or other method approved by MPCA in the performance test plan approval. [Minn. R , subp. 7(A), 7(L), & 7(M), Minn. R , subp. 4, Minn. R , subps. 1 2, Minn. R , Minn. R , subp. 1, Minn. Stat , subd. 4a, Minn. Stat , subd. 9, Title I Condition: 40 CFR 52.21(j) & (k)(bact) & Minn. R , Title I Condition: Avoid major source under 40 CFR 52.21(b)(1)(i) & Minn. R ] The Permittee shall conduct performance test : Due 90 calendar days after Equipment Installation Date to measure PM10 emissions in gr/dscf and lb/hr. 'Equipment Installation' is the installation of new equipment, modification of existing equipment, and/or replacement of existing equipment with higher capacity same function equipment. 'Equipment Installation' does not include replacement of existing equipment where the replacement equipment meets the Replacement Unit criteria specified at 40 CFR Section 52.21(b)(33) paragraphs (ii), (iii), and (iv) and the replacement emission unit completely takes the place of the existing emission unit. The performance test shall be conducted at worst case conditions as defined at Minn. R , subp. 8 (i.e. at least 90% of 700 tons/hr grain throughput with the doors closed and at least one straight truck per hour for each one hour test), using EPA Reference Methods 5 and 202, Methods 201A and 202, 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

220 Permit Expires: [month day, year] Page 218 of 243 not reset the test due date for future testing as required: 1) 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. [Minn. R , subp. 1, Title I Condition: 40 CFR 52.21(j) & (k)(bact) & Minn. R , Title I Condition: Avoid major source under 40 CFR 52.21(b)(1)(i) & Minn. R ] The Permittee shall conduct performance test : Due by 180 days after permit issuance to measure PM2.5 emissions with the doors closed in gr/dscf and lb/hr. The performance test shall be conducted at worst case conditions as defined at Minn. R , subp. 8 (i.e. at least 90% of 700 tons/hr grain throughput and at least one straight truck per hour for each one hour test), using EPA Methods 5 and 202, Methods 201A and 202, or other method approved by MPCA in the performance test plan approval. [Minn. R , subp. 7(A), 7(L), & 7(M), Minn. R , subp. 4, Minn. R , subps. 1 2, Minn. R , Minn. R , subp. 1, Minn. Stat , subd. 4a, Minn. Stat , subd. 9, Title I Condition: Avoid major source under 40 CFR 52.21(b)(1)(i) & Minn. R ] The Permittee shall conduct performance test : Due 90 calendar days after Equipment Installation Date to measure PM2.5 emissions in gr/dscf and lb/hr. 'Equipment Installation' is the installation of new equipment, modification of existing equipment, and/or replacement of existing equipment with higher capacity same function equipment. 'Equipment Installation' does not include replacement of existing equipment where the replacement equipment meets the Replacement Unit criteria specified at 40 CFR Section 52.21(b)(33) paragraphs (ii), (iii), and (iv) and the replacement emission unit completely takes the place of the existing emission unit. The performance test shall be conducted at worst case conditions as defined at Minn. R , subp. 8 (i.e. at least 90% of 700 tons/hr grain throughput with the doors closed and at least one straight truck per hour for each one hour test), using EPA Reference Methods 5 and 202, Methods 201A and 202, 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: 1) by this permit; 2) by the most recently approved Performance Test

221 Permit Expires: [month day, year] Page 219 of 243 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. [Minn. R , subp. 1, Title I Condition: Avoid major source under 40 CFR 52.21(b)(1)(i) & Minn. R ] The Permittee shall submit a test frequency plan : Due 60 calendar days after Performance Test Date for PM emissions after Equipment Installation. The plan shall specify a testing frequency based on the initial performance test data and MPCA guidance. Future performance tests at 12 month, 36 month, or 60 month intervals, or as applicable, shall be required upon written approval of the MPCA. [Minn. R , subp. 1] The Permittee shall submit a test frequency plan : Due 60 calendar days after Performance Test Date for PM10 emissions after Equipment Installation. The plan shall specify a testing frequency based on the initial performance test data and MPCA guidance. Future performance tests at 12 month, 36 month, or 60 month intervals, or as applicable, shall be required upon written approval of the MPCA. [Minn. R , subp. 1] The Permittee shall submit a test frequency plan : Due 60 calendar days after Performance Test Date for PM2.5 emissions after Equipment Installation. The plan shall specify a testing frequency based on the initial performance test data and MPCA guidance. Future performance tests at 12 month, 36 month, or 60 month intervals, or as applicable, shall be required upon written approval of the MPCA. [Minn. R , subp. 1] STRU 72 SV015 Hammermills 3 & 4 West Plant (CE 007) The Permittee shall conduct performance test : Due 90 calendar days after Equipment Installation Date to measure PM emissions in gr/dscf and lb/hr. 'Equipment Installation' is the installation of new equipment, modification of existing equipment, and/or replacement of existing equipment with higher capacity same function equipment. 'Equipment Installation' does not include replacement of existing equipment where the replacement equipment meets the Replacement Unit criteria specified at 40 CFR Section 52.21(b)(33) paragraphs (ii), (iii), and (iv) and the replacement emission unit completely takes the place of the existing emission unit. The performance test shall be conducted at worst case conditions as defined at Minn. R , subp. 8 (i.e. at least 90% of 95.2 tons/hr grain throughput), using EPA Reference Methods 5 and 202, or other method approved by

222 Permit Expires: [month day, year] Page 220 of 243 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: 1) 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. [Minn. R , subp. 1, Title I Condition: 40 CFR 52.21(j)(BACT) & Minn. R , Title I Condition: Avoid major source under 40 CFR 52.21(b)(1)(i) & Minn. R ] The Permittee shall conduct performance test : Due 90 calendar days after Equipment Installation Date to measure PM10 emissions in gr/dscf and lb/hr. 'Equipment Installation' is the installation of new equipment, modification of existing equipment, and/or replacement of existing equipment with higher capacity same function equipment. 'Equipment Installation' does not include replacement of existing equipment where the replacement equipment meets the Replacement Unit criteria specified at 40 CFR Section 52.21(b)(33) paragraphs (ii), (iii), and (iv) and the replacement emission unit completely takes the place of the existing emission unit. The performance test shall be conducted at worst case conditions as defined at Minn. R , subp. 8 (i.e. at least 90% of 95.2 tons/hr grain throughput), using EPA Reference Methods 5 and 202, Methods 201A and 202, 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: 1) 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. [Minn. R , subp. 1, Title I Condition: 40 CFR 52.21(j) & (k)(bact) & Minn. R , Title I Condition: Avoid major source under 40 CFR 52.21(b)(1)(i) & Minn. R ] The Permittee shall conduct performance test : Due 90 calendar days after Equipment Installation Date to measure PM2.5 emissions in gr/dscf and lb/hr.

223 Permit Expires: [month day, year] Page 221 of 243 'Equipment Installation' is the installation of new equipment, modification of existing equipment, and/or replacement of existing equipment with higher capacity same function equipment. 'Equipment Installation' does not include replacement of existing equipment where the replacement equipment meets the Replacement Unit criteria specified at 40 CFR Section 52.21(b)(33) paragraphs (ii), (iii), and (iv) and the replacement emission unit completely takes the place of the existing emission unit. The performance test shall be conducted at worst case conditions as defined at Minn. R , subp. 8 (i.e. at least 90% of 95.2 tons/hr grain throughput), using EPA Reference Methods 5 and 202, Methods 201A and 202, 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: 1) 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. [Minn. R , subp. 1, Title I Condition: Avoid major source under 40 CFR 52.21(b)(1)(i) & Minn. R ] The Permittee shall submit a test frequency plan : Due 60 calendar days after Performance Test Date for PM emissions after Equipment Installation. The plan shall specify a testing frequency based on the initial performance test data and MPCA guidance. Future performance tests at 12 month, 36 month, or 60 month intervals, or as applicable, shall be required upon written approval of the MPCA. [Minn. R , subp. 1] The Permittee shall submit a test frequency plan : Due 60 calendar days after Performance Test Date for PM10 emissions after Equipment Installation. The plan shall specify a testing frequency based on the initial performance test data and MPCA guidance. Future performance tests at 12 month, 36 month, or 60 month intervals, or as applicable, shall be required upon written approval of the MPCA. [Minn. R , subp. 1] The Permittee shall submit a test frequency plan : Due 60 calendar days after Performance Test Date for PM2.5 emissions after Equipment Installation. The plan shall specify a testing frequency based on the initial performance test data and MPCA guidance. Future performance tests at 12 month, 36 month, or 60 month intervals, or as applicable, shall be required upon written approval of the MPCA. [Minn. R , subp. 1]

224 Permit Expires: [month day, year] Page 222 of 243 STRU 79 SV003 East Plant Fermentation Scrubber (CE 003) The Permittee shall conduct performance test : Due 09/12/2017 every 60 months to measure VOC emissions on a mass basis in lb/hr, not to exceed 60 months between test dates. Testing is due by the end of each 60 month period following 09/12/2017. The performance test shall be conducted at worst case conditions as defined at Minn. R , subp. 8 (i.e. at least 90% of 440 gallons/minute beer produced), using EPA Reference Method 18, 25A, 320, 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: 1) 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. [Minn. R , subp. 1, Title I Condition: 40 CFR 52.21(j)(BACT) & Minn. R ] The Permittee shall conduct performance test : Due 90 calendar days after Equipment Installation Date to measure VOC emissions on a mass basis in lb/hr. 'Equipment Installation' is the installation of new equipment, modification of existing equipment, and/or replacement of existing equipment with higher capacity same function equipment. 'Equipment Installation' does not include replacement of existing equipment where the replacement equipment meets the Replacement Unit criteria specified at 40 CFR Section 52.21(b)(33) paragraphs (ii), (iii), and (iv) and the replacement emission unit completely takes the place of the existing emission unit. The performance test shall be conducted at worst case conditions as defined at Minn. R , subp. 8 (i.e. at least 90% of 440 gallons/minute beer produced), using EPA Reference Method 18, 25A, 320, 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: 1) by this permit; 2) by the most recently approved Performance Test Frequency Plan; or 3) within a Notice of Compliance letter.

225 Permit Expires: [month day, year] Page 223 of 243 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. [Minn. R , subp. 1, Title I Condition: Avoid major source under 40 CFR 52.21(b)(1)(i) & Minn. R ] The Permittee shall conduct performance test : Due 09/12/2017 every 60 months to measure HAP emissions, not to exceed 60 months between test dates. Testing must include all chemicals listed in Appendix D of this permit. Testing is due by the end of each 60 month period following 09/12/2017. The performance test shall be conducted at worst case conditions as defined at Minn. R , subp. 8 (i.e. at least 90% of 440 gallons/minute beer produced), using EPA Reference Method 18, 320, 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: 1) 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. [Minn. R , Minn. R , subp. 1, Title I Condition: Avoid major source under 40 CFR 63.2] The Permittee shall conduct performance test : Due 90 calendar days after Equipment Installation Date to measure HAP emissions. Testing must include all chemicals listed in Appendix D to this permit. 'Equipment Installation' is the installation of new equipment, modification of existing equipment, and/or replacement of existing equipment with higher capacity same function equipment. 'Equipment Installation' does not include replacement of existing equipment where the replacement equipment meets the Replacement Unit criteria specified at 40 CFR Section 52.21(b)(33) paragraphs (ii), (iii), and (iv) and the replacement emission unit completely takes the place of the existing emission unit. The performance test shall be conducted at worst case conditions as defined at Minn. R , subp. 8 (i.e. at least 90% of 440 gallons/minute beer produced), using EPA Reference Method 18, 320, 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

226 Permit Expires: [month day, year] Page 224 of 243 not reset the test due date for future testing as required: 1) 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. [Minn. R , Minn. R , subp. 1, Title I Condition: Avoid major source under 40 CFR 63.2] STRU 85 SV001 Grain Handling East Plant (CE001) The Permittee shall submit a notification of equipment removal/dismantlement : Due 30 calendar days after Date of Shutdown of STRU 85 and all EQUIs venting to STRU 85. The notification shall be postmarked within 30 days of actual shutdown of STRU 85. The requirements in the permit applicable to STRU 85 remain effective until shutdown of STRU 85 occurs. [Minn. R , subp. 2] STRU 86 SV002 Hammermills 1 & 2 East Plant (CE002) The Permittee shall submit a notification of equipment removal/dismantlement : Due 30 calendar days after Date of Shutdown of STRU 86 and all EQUIs venting to STRU 86. The notification shall be postmarked within 30 days of actual shutdown of STRU 86. The requirements in the permit applicable to STRU 86 remain effective until shutdown of STRU 86 occurs. [Minn. R , subp. 2] STRU 87 SV011 VRTO #1 Stack East Plant (CE010) The Permittee shall submit a notification of equipment removal/dismantlement : Due 30 calendar days after Date of Shutdown of STRU 87. The notification shall be postmarked within 30 days and include the date of actual shutdown of STRU 87 and date of initial startup of STRU 9. The requirements in the permit applicable to STRU 87 remain effective until shutdown of STRU 87 occurs. [Minn. R , subp. 2] TREA 43 CE001 Fabric Filter Low Temperature, i.e., T<180 Degrees F The Permittee shall submit a notification of equipment removal/dismantlement : Due 30 calendar days after Date of

227 Permit Expires: [month day, year] Page 225 of 243 Shutdown of TREA 43. The notification shall be postmarked within 30 days of actual shutdown of TREA 43. The requirements in the permit applicable to TREA 43 remain effective until shutdown of TREA 43 occurs. [Minn. R , subp. 2] TREA 44 CE002 Fabric Filter Low Temperature, i.e., T<180 Degrees F The Permittee shall submit a notification of equipment removal/dismantlement : Due 30 calendar days after Date of Shutdown of TREA 44. The notification shall be postmarked within 30 days of actual shutdown of TREA 44. The requirements in the permit applicable to TREA 44 remain effective until shutdown of TREA 44 occurs. [Minn. R , subp. 2] TREA 45 CE010 VRTO # The Permittee shall submit a notification of equipment removal/dismantlement : Due 30 calendar days after Date of Shutdown of TREA 45. The notification shall be postmarked within 30 days and include the date of actual shutdown of TREA 45 and date of initial startup of TREA 11. The requirements in the permit applicable to TREA 45 remain effective until shutdown of TREA 45 occurs. [Minn. R , subp. 2] TREA 46 CE011 Single Cyclone The Permittee shall submit a notification of equipment removal/dismantlement : Due 30 calendar days after Date of Shutdown of TREA 46. The notification shall be postmarked within 30 days of actual shutdown of TREA 46. The requirements in the permit applicable to TREA 46 remain effective until shutdown of TREA 46 occurs. [Minn. R , subp. 2]

228 Permit Expires: [month day, year] Page 226 of Appendices Appendix A. Insignificant Activities and General Applicable Requirements The table below lists the insignificant activities that are currently at the Facility and their associated general applicable requirements. Minn. R. Rule description of the activity General applicable requirement Minn. R , subp. 3(A) Fuel Use: space heaters fueled by kerosene, natural gas, or propane, less than 420,000 Btu/hr There is one space heater with a 60,000 BTU/hr heat input capacity. PM <= 0.6 or 0.4 lb/mmbtu, depending on year constructed Opacity <= 20% with exceptions (Minn. R /0515) Minn. R , subp. 3(E)(1) Minn. R , subp. 3(G) Gasoline storage tanks with a combined total tankage capacity of not more than 10,000 gallons Small gasoline storage tanks (1 10 gallon fuel cans) for lawn mowers and other small equipment, etc. Emissions from a laboratory, as defined in Minn. R , subp. 3(G) The facility has a product testing laboratory. Minn. R , subp. 3(H)(3) Brazing, soldering or welding equipment Welding equipment for plant maintenance. Minn. R , subp. 3(H)(4) Blueprint copiers and photographic processes Normal scale office equipment is in the facility office. Minn. R , subp. 3(J) Minn. R , subp. 3(K) Fugitive dust emissions from unpaved roads and parking lots Fugitive emissions from roads and parking lots. Main facility haul roads will be paved. Unpaved pull offs may exist but are not used on a regular basis. Infrequent use of spray paint equipment for routine housekeeping or plant upkeep activities not associated with primary production processes at the stationary source Check to see if Minn. R , subp. 2(B)/1505, subp. 3(B) apply, if not PM, variable depending on airflow Opacity <= 20% (Minn. R /0715) PM, variable depending on airflow Opacity <= 20% (Minn. R /0715) PM, variable depending on airflow Opacity <= 20% (Minn. R /0715) Opacity <= 20% (Minn. R or ) Requirement to take reasonable measures to prevent PM from becoming airborne (Minn. R ) PM, variable depending on airflow Opacity <= 20% (Minn. R /0715)

229 Permit Expires: [month day, year] Page 227 of 243 Appendix B: Modeling Inputs BASE STACK STACK STACK STACK SOURCE EMISSION RATE X Y ELEV. HEIGHT TEMP. EXIT VEL. DIAMETER ID (GRAMS/SEC) (METERS) (METERS) (METERS) (METERS) (DEG.K) (M/SEC) (METERS) PM 10 & PM 2.5 (2015) HCPF7&8A (PM 2.5 ) E HCPF7&8B (PM 2.5 ) E HCPF7&8C (PM 2.5 ) E HCPF7&8D (PM 2.5 ) E HCPF7&8E (PM 2.5 ) E HCPF7&8F (PM 2.5 ) E HCPF7&8A (PM 10 ) E HCPF7&8B (PM 10 ) E HCPF7&8C (PM 10 ) E HCPF7&8D (PM 10 ) E HCPF7&8E (PM 10 ) E HCPF7&8F (PM 10 ) E HCPFS013A E HCPFS013B E HCPFS011A E HCPFS011B E HCPFS011C E HCPFS012A E HCPFS012B E HCPFS012C E HCPFS012D E HCPSV E HCPSV E HCPSV E HCPSV E HCPSV E HCPSV E HCPSV E HCPSV E HCPSV E

230 Permit Expires: [month day, year] Page 228 of 243 BASE STACK STACK STACK STACK SOURCE EMISSION RATE X Y ELEV. HEIGHT TEMP. EXIT VEL. DIAMETER ID (GRAMS/SEC) (METERS) (METERS) (METERS) (METERS) (DEG.K) (M/SEC) (METERS) CO (2005) SV E SV E SV E SV E SV E SV E SV E BASE STACK STACK STACK STACK SOURCE EMISSION RATE X Y ELEV. HEIGHT TEMP. EXIT VEL. DIAMETER ID (GRAMS/SEC) (METERS) (METERS) (METERS) (METERS) (DEG.K) (M/SEC) (METERS) NO X (2007) NEWSV E SV E NEWSV E SV E SV E SV E SV E

231 Permit Expires: [month day, year] Page 229 of 243 Appendix C: Fence Diagram