Preliminary Draft Air Individual Permit State Permit

Transcription

1 Preliminary Draft Air Individual Permit State Permit Permittee: Facility name: CHS Inc - Prairie Lakes Coop - Glenwood Grain Elevator CHS Inc - Prairie Lakes Coop - Glenwood Grain Elevator th Ave NE Glenwood, MN Pope County Expiration date: Non-expiring Permit State Permit: [Amendment Issue Date] Permit characteristics: State; Limits to avoid 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 are as described in the submittals listed in the Permit Applications Table. This permit supersedes Air Emission Permit No and authorizes the Permittee to operate 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 are enforceable by the U.S. Environmental Protection Agency (EPA) Administrator or citizens under the Clean Air Act. Signature: for 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 Page

3 Permit issued: [month day, year] Permit expires: [month day, year] Page 3 of Permit applications table Subsequent permit applications: Title description Application receipt date Action number State Permit 08/17/2017 (Final Certification Received 4/24/2018)

4 Permit issued: [month day, year] Permit expires: [month day, year] Page 4 of Where to send submittals Send submittals that are required to be submitted to the 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 Or a signed and scanned PDF copy to: submitstacktest.pca@state.mn.us (for submittals related to stack testing) AQRoutineReport.PCA@state.mn.us (for other compliance submittals) (See complete instructions in Routine Air Report Instructions Letter at

5 Permit issued: [month day, year] Permit expires: [month day, year] Page 5 of Facility description The CHS Inc - Prairie Lakes Coop - Glenwood Grain Elevator (Facility) is located at th Avenue NE in Glenwood, Pope County, Minnesota. CHS Inc - Prairie Lakes Coop - Glenwood Grain Elevator ("CHS" or "the facility") is a country grain elevator limited to 720,000 tons of grain received per year. Three types of grain are received: corn, soybeans, and wheat. There are three truck receiving pits where grain is received by hopper truck or straight truck. One of the receiving pits is vented to a baghouse for particulate matter control. There is one rail receiving pit that is rarely used. The facility has 22 silo/bins for storage. Seven of the bins have bins vents. Grain may also be stored at four temporary storage piles. Pile 1 has an 8.4 foot tall concrete wall, and is fed through one of the truck receiving pits that routes grain to three outdoor conveyors in series. The other three piles have 4 or 6 feet tall walls. Grain may be added to these pile using two portable outdoor conveyors that receive grain directly from trucks. All piles are covered by tarps during storage. The piles are filled and emptied once each year, and the maximum amount of grain that is put into temporary storage is 135,000 tons each year. When grain is reclaimed from the piles, a portion of the tarp is torn away and a grain gobbler is used to suck up the grain, convey it upwards on an incline, and drop it into a truck. The truck then drives to one of the receiving pits to dump the grain for drying or storage in one of the silo/bins. If wet grain is received or reclaimed from one of the temporary storage areas, the grain may be dried in one of the two column dryers prior to storage or loadout. There are three truck loadout spouts and one rail loadout station. Grain is primarily loaded out to rail, with a small portion loaded out to truck. The facility has two 10,000 gallon diesel tanks that are used for truck fueling that are categorized as insignificant activities. Particulate matter (PM), particulate matter less than ten microns (PM10), and particulate matter less than 2.5 microns (PM2.5) are the main pollutants of concern at this facility. Sources of particulate matter include emissions from grain receiving, storage (silo vents), drying, handling, and loadout, and fugitive emissions from unpaved roads, truck traffic, the addition of grain to temporary storage piles, and reclaim of grain from the storage piles. A small amount of combustion-related pollutants are also emitted from drying, including nitrogen oxides (NOx), carbon monoxide (CO), carbon dioxide equivalents (CO2e), and hazardous air pollutants (HAPs).

6 Permit issued: [month day, year] Permit expires: [month day, year] Page 6 of Summary of subject items SI ID: Description TFAC 1: CHS Inc - Prairie Lakes Coop - Glenwood Grain Elev ACTV 2: All IA's COMG 2: Enclosed Material Handling Equipment Relationshi p Type has members COMG 3: Unvented Silos has members COMG 4: Vented Bins has members Related SI ID: Description EQUI 5, EQUI 6, EQUI 12, EQUI 13, EQUI 14, EQUI 15, EQUI 16, EQUI 17, EQUI 18, EQUI 19, EQUI 20, EQUI 21, EQUI 22, EQUI 23, EQUI 24, EQUI 25, EQUI 26, EQUI 27, EQUI 28, EQUI 29, EQUI 30, EQUI 31, EQUI 32, EQUI 33, EQUI 34, EQUI 35, EQUI 36, EQUI 37, EQUI 38 EQUI 9, EQUI 40, EQUI 43, EQUI 44, EQUI 45, EQUI 46, EQUI 47, EQUI 48, EQUI 49, EQUI 50, EQUI 55, EQUI 56, EQUI 58 EQUI 41, EQUI 42, EQUI 51, EQUI 52, EQUI 53, EQUI 54, EQUI 57 EQUI 5: Receiving Pit 1 EQUI 6: Wet Leg EQUI 7: GSI Dryer sends to STRU 2: GSI Dryer Stack EQUI 8: Zimmerman Dryer sends to STRU 3: Zimmerman Dryer EQUI 9: Bin 1 EQUI 10: Receiving Pit 2 sends to STRU 1: Baghouse Stack SI ID: Relationshi Description p Type EQUI 10: Receiving Pit 2 is controlled by EQUI 11: Receiving Pit 3 EQUI 12: Dry Leg EQUI 13: Leg 1 EQUI 14: Leg 2 EQUI 15: Bulkweigh Leg EQUI 16: Pit 2 Leg EQUI 17: Pit 3 Leg EQUI 18: Under Silo EQUI 19: GSI Dryer EQUI 20: Rail Pit EQUI 21: Under Road EQUI 22: East Rec EQUI 23: Under N&S EQUI 24: Bin 22 EQUI 25: Zimmerman Dryer EQUI 26: Pit 2 EQUI 27: Pit 3 EQUI 28: Top Jump EQUI 29: Old Blue EQUI 30: Grey EQUI 31: Bin 22 Drag EQUI 32: Bin 22 Belt EQUI 33: East Bin Transfer EQUI 34: East Bin Over Road EQUI 35: North Drag EQUI 36: Bin 15 Belt EQUI 37: North Pile EQUI 38: Mid Pile Related SI ID: Description TREA 1: Pit 2 Baghouse

7 Permit Expires: [month day, year] Page 7 of 26 SI ID: Description EQUI 39: South Pile EQUI 40: Bin 2 EQUI 41: Bin 3 (vented) EQUI 42: Bin 4 (vented) EQUI 43: Bin 5 EQUI 44: Bin 6 EQUI 45: Bin 7 EQUI 46: Bin 8 EQUI 47: Bin 9 EQUI 48: Bin 10 EQUI 49: Bin 11 EQUI 50: Bin 12 EQUI 51: Bin 13 (vented) EQUI 52: Bin 14 (vented) EQUI 53: Bin 15 (vented) EQUI 54: Bin 16 (vented) EQUI 55: Bin 20 EQUI 56: Bin 21 EQUI 57: Bin 22 (vented) EQUI 58: Bin 23 EQUI 59: Rail Loadout EQUI 60: Truck Loadout Relationshi p Type Related SI ID: Description SI ID: Description 1 EQUI 61: Truck Loadout 2 EQUI 62: Truck Loadout 3 EQUI 63: Grain Gobbler EQUI 64: Rail Pit EQUI 65: Portable 1 - Pile 2&3 EQUI 66: Portable Auger/ 2 - Pile 4 FUGI 1: Pile 1 (XT2) FUGI 2: Unpaved roads FUGI 3: Pile 2 (XT7) FUGI 4: Pile 3 (XT8) FUGI 5: Pile 4 (XT5) STRU 1: Baghouse Stack STRU 2: GSI Dryer Stack STRU 3: Zimmerman Dryer TREA 1: Pit 2 Baghouse Relationshi p Type Related SI ID: Description

8 Permit Expires: [month day, year] Page 8 of Limits and other requirements TFAC CHS Inc - Prairie Lakes Coop - Glenwood Grain Elev The Permittee shall limit Process Throughput <= tons per year 12-month rolling sum of grain received to be calculated by the 15th day of each month for the previous 12-month period as described later in this permit. [Title I Condition: Avoid major source under 40 CFR 52.21(b)(1)(i) and Minn. R , To avoid major source under 40 CFR 70.2 & Minn. R ] The Permittee shall limit Process Throughput <= tons per year 12-month rolling sum of grain dried to be calculated by the 15th day of each month for the previous 12-month period as described later in this permit. [Title I Condition: Avoid major source under 40 CFR 52.21(b)(1)(i) and Minn. R , To avoid major source under 40 CFR 70.2 & Minn. R ] The Permittee shall limit Process Throughput <= tons per year 12-month rolling sum of grain stored in the temporary storage piles to be calculated by the 15th day of each month for the previous 12-month period as described later in this permit. [Minn. R , subp. 2(B)] Daily Recordkeeping: Monthly Recordkeeping: Once each day of operation the Permittee shall calculate, record, and maintain records of the following, in tons of grain: 1. the total grain received at receiving pits EQUI 5, 10, 11, or 64, not including grain reclaimed from Pile 1 (FUGI 1), 2. the amount of grain dried in Dryer EQUI 7 or 8, and 3. the grain added to any temporary storage pile FUGI 1, 3, 4, or 5. Daily records shall by based on ticket reports and maintained electronically. [Title I Condition: Avoid major source under 40 CFR 52.21(b)(1)(i) and Minn. R , To avoid major source under 40 CFR 70.2 & Minn. R ] By the 15th day of each month, for the previous calendar month, the Permittee shall calculate and record the following: 1. the tons of grain received at receiving pits EQUI 5, 10, 11, or 64, not including grain reclaimed from Pile 1 (FUGI 1), and 2. tons of grain dried in Dryer EQUI 7 or 8, and 3. the tons of grain added to any temporary storage pile FUGI 1, 3, 4, or 5, and 4. the 12-month rolling sum of grain received, the 12-month rolling sum of grain dried, and the 12-month rolling sum of grain added to any storage pile for the previous 12-month period by summing the

9 Permit Expires: [month day, year] Page 9 of 26 monthly records for the previous 12 months. [Minn. R , subps. 4-5] Permit Appendices: This permit contains appendices as listed in the permit Table of Contents. The Permittee shall comply with all requirements contained in Appendix A: Insignificant Activities and General Applicable Requirements. [Minn. R , subp. 2] 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)] 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 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

10 Permit Expires: [month day, year] Page 10 of 26 allow avoidable amounts of particulate matter to become airborne. Comply with all other requirements listed in Minn. R [Minn. R ] The Permittee shall clean up commodities spilled on the driveway and other facility property as required to minimize fugitive emissions to a level consistent with RACT (reasonably available control technology). [Minn. R , subp. 1(A)] 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] 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 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

11 Permit Expires: [month day, year] Page 11 of 26 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 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 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;

12 Permit Expires: [month day, year] Page 12 of 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. Upon adoption of a new or amended federal applicable requirement, and if there are 3 or more 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. Submit in a format specified by the Commissioner. [Minn. R ] Emission Fees: due 30 days after receipt of an MPCA bill. [Minn. R ] COMG 2 Enclosed Material Handling Equipment Opacity <= 5 percent opacity from handling operation fugitive emissions. This limit applies separately to each individual unit in the group. [Minn. R , subp. 3(A)] COMG 3 Unvented Silos Opacity <= 5 percent opacity from handling operation fugitive emissions. This limit applies separately to each individual unit in the group. [Minn. R , subp. 3(A)] COMG 4 Vented Bins Opacity <= 5 percent opacity from any bin vent while transferring

13 Permit Expires: [month day, year] Page 13 of 26 grain into or out of the bin. [Minn. R , subp. 3(A)] Visible Emissions: The Permittee shall check for visible emissions from any bin vent using Method 22 once each day of operation during daylight hours. The observation shall be conducted from a location where all bin vents are visible and shall be done while grain is being added to one or more bins. The observation period shall be no less than 10 minutes. Each observer determining the presence of visible emissions must meet the training requirements specified in 40 CFR Part 60, appendix A-7, Section 2.3 of Method 22. If no grain is added to any bin during the operating day, then the Permittee shall record that no grain was added. [Minn. R , subps. 1-2] Visible Emissions: Recordkeeping of Visible Emissions. The Permittee shall record the time and date of each visible emission inspection, whether or not any visible emissions were observed, and at which bin(s) the visible emissions were observed. The presence of visible emissions at any bin vent is considered a deviation and must be reported in the semiannual deviations report and annual deviations report required by this permit. [Minn. R , subps. 4-5] Visible Emissions: Corrective Actions: The Permittee shall take corrective action as soon as possible if visible emissions are observed. Corrective actions include, but are not limited to, reducing the rate of grain being added to the bin, adding mineral oil prior to adding grain to the bin, and postponing operations until no visible emissions are observed. The Permittee shall keep a record of the type and date of any corrective action taken, at which bin(s) the corrective actions were taken, and whether or not the corrective actions eliminated the visible emissions. [Minn. R , subps. 4-5] EQUI 5 Receiving Pit Opacity <= 5 percent opacity from truck unloading station fugitive (uncaptured) emissions. [Minn. R , subp. 3(A)] Visible Emissions: The Permittee shall check EQUI 5 for any visible emissions using Method 22 once each day of operation during daylight hours. The observation period shall be no less than 10 minutes and shall be conducted while grain unloading occurs. Each observer determining the presence of visible emissions must meet the training requirements specified in 40 CFR Part 60, appendix A-7, Section 2.3 of Method 22. If no grain is received at EQUI 5 during the operating day, then the Permittee shall record that no grain was received. [Minn. R , subps. 1-2] Visible Emissions: Recordkeeping: The Permittee shall record the time and date of each visible emission inspection, and whether or not any visible emissions were observed. The presence of visible emissions at the unloading station is considered a deviation and must be reported in the semiannual deviations report required by this permit. [Minn. R , subps. 4-5]

14 Permit Expires: [month day, year] Page 14 of Visible Emissions: Corrective Actions: The Permittee shall take corrective action as soon as possible if visible emissions are observed. Corrective actions include, but are not limited to, reducing the truck unloading rate, shrouding the pit during unloading operations, and ceasing operations until no visible emissions are observed. The Permittee shall keep a record of the type and date of any corrective action taken and whether or not the corrective actions eliminated the visible emissions. [Minn. R , subps. 4-5] EQUI 7 GSI Dryer The perforations of a column dryer screen must not exceed 3/32 inches in diameter. [Minn. R , subp. 5(A)] EQUI 8 Zimmerman Dryer The perforations of a column dryer screen must not exceed 3/32 inches in diameter. [Minn. R , subp. 5(A)] EQUI 10 Receiving Pit The Permittee shall vent emissions from EQUI 10 to control equipment meeting the requirements of TREA 1 whenever EQUI 10 operates. [Minn. R , subp. 2((A))] Opacity <= 5 percent opacity from truck unloading station fugitive (uncaptured) emissions. [Minn. R , subp. 3(A)] Visible Emissions: The Permittee shall check EQUI 10 for any visible emissions using Method 22 once each day of operation during daylight hours. The observation period shall be no less than 10 minutes and shall be conducted while grain unloading occurs. Each observer determining the presence of visible emissions must meet the training requirements specified in 40 CFR Part 60, appendix A-7, Section 2.3 of Method 22. If no grain is received at EQUI 10 during the operating day, then the Permittee shall record that no grain was received. [Minn. R , subps. 1-2] Visible Emissions: Recordkeeping of Visible Emissions. The Permittee shall record the time and date of each visible emission inspection, and whether or not any visible emissions were observed. The presence of visible emissions at the unloading station is considered a deviation and must be reported in the semiannual deviations report and annual deviations report required by this permit. [Minn. R , subps. 4-5] Visible Emissions: Corrective Actions: The Permittee shall take corrective action as soon as possible if visible emissions are observed. Corrective actions include, but are not limited to, reducing the truck unloading rate, shrouding the pit during unloading operations, and ceasing operations until no visible emissions are observed. The Permittee shall keep a record of the type and date of any corrective action taken and whether or not the

15 Permit Expires: [month day, year] Page 15 of 26 corrective actions eliminated the visible emissions. [Minn. R , subps. 4-5] EQUI 11 Receiving Pit Opacity <= 5 percent opacity from truck unloading station fugitive (uncaptured) emissions. [Minn. R , subp. 3(A)] Visible Emissions: The Permittee shall check EQUI 11 for any visible emissions using Method 22 once each day of operation during daylight hours. The observation period shall be no less than 10 minutes and shall be conducted while grain unloading occurs. Each observer determining the presence of visible emissions must meet the training requirements specified in 40 CFR Part 60, appendix A-7, Section 2.3 of Method 22. If no grain is received at EQUI 11 during the operating day, then the Permittee shall record that no grain was received. [Minn. R , subps. 1-2] Visible Emissions: Recordkeeping of Visible Emissions. The Permittee shall record the time and date of each visible emission inspection, and whether or not any visible emissions were observed. The presence of visible emissions at the unloading station is considered a deviation and must be reported in the semiannual deviations report and annual deviations report required by this permit. [Minn. R , subps. 4-5] Visible Emissions: Corrective Actions: The Permittee shall take corrective action as soon as possible if visible emissions are observed. Corrective actions include, but are not limited to, reducing the truck unloading rate, shrouding the pit during unloading operations, and postponing operations until no visible emissions are observed. The Permittee shall keep a record of the type and date of any corrective action taken and whether or not the corrective actions eliminated the visible emissions. [Minn. R , subps. 4-5] EQUI 39 South Pile Opacity <= 5 percent opacity from handling operation emissions. [Minn. R , subp. 3(A)] Visible Emissions: The Permittee shall check EQUI 39 for any visible emissions at the grain drop point using Method 22 during daylight hours on each day that the conveyor is operated. The observation period shall be no less than 10 minutes and shall be conducted while grain is being added to the pile. Each observer determining the presence of visible emissions must meet the training requirements specified in 40 CFR Part 60, appendix A-7, Section 2.3 of Method 22. [Minn. R , subps. 1-2] Visible Emissions: Recordkeeping of Visible Emissions. The Permittee shall record the time and date of each visible emission inspection, and whether or not any visible emissions were observed. The presence of visible emissions from the conveyor or the conveyor drop point is considered a deviation and must be

16 Permit Expires: [month day, year] Page 16 of 26 reported in the semiannual deviations report and annual deviations report required by this permit. [Minn. R , subps. 4-5] Visible Emissions: Corrective Actions: The Permittee shall take corrective action as soon as possible if visible emissions are observed. Corrective actions include, but are not limited to, reducing the conveyor speed and postponing operations until no visible emissions are observed. The Permittee shall keep a record of the type and date of any corrective action taken and whether or not the corrective actions eliminated the visible emissions. [Minn. R , subps. 4-5] EQUI 59 Rail Loadout Opacity <= 5 percent opacity from railcar loading station fugitive (uncaptured) emissions. [Minn. R , subp. 3(A)] Visible Emissions: The Permittee shall check EQUI 59 for any visible emissions using Method 22 once each day of operation during daylight hours. The observation period shall be no less than 10 minutes and shall be conducted while grain is being loaded out to rail. Each observer determining the presence of visible emissions must meet the training requirements specified in 40 CFR Part 60, appendix A-7, Section 2.3 of Method 22. If no grain is added is loaded out to rail during the operating day, then the Permittee shall record that no grain was loaded out to rail. [Minn. R , subps. 1-2] Visible Emissions: Recordkeeping of Visible Emissions. The Permittee shall record the time and date of each visible emission inspection, and whether or not any visible emissions were observed. [Minn. R , subps. 4-5] Visible Emissions: Corrective Actions: The Permittee shall take corrective action as soon as possible if visible emissions are observed. Corrective actions shall eliminate visible emissions. Corrective actions include, but are not limited to, reducing the rate of grain being loaded out. The Permittee shall keep a record of the type and date of any corrective action taken. [Minn. R , subps. 4-5] EQUI 60 Truck Loadout Opacity <= 10 percent opacity from truck loading station fugitive emissions. [Minn. R , subp. 3(B)] Visible Emissions: The Permittee shall check EQUI 60 for any visible emissions using Method 22 once each day of operation during daylight hours. The observation period shall be no less than 10 minutes and shall be conducted while grain loading occurs. Each observer determining the presence of visible emissions must meet the training requirements specified in 40 CFR Part 60, appendix A-7, Section 2.3 of Method 22. If no grain is loaded at EQUI 60 during the operating day, then the Permittee shall record that no grain was loaded out. [Minn. R , subps. 1-2]

17 Permit Expires: [month day, year] Page 17 of Visible Emissions: Recordkeeping of Visible Emissions. The Permittee shall record the time and date of each visible emission inspection, and whether or not any visible emissions were observed. The presence of visible emissions at the unloading station is considered a deviation and must be reported in the semiannual deviations report and annual deviations report required by this permit. [Minn. R , subps. 4-5] Visible Emissions: Corrective Actions: The Permittee shall take corrective action as soon as possible if visible emissions are observed. Corrective actions include, but are not limited to, reducing the truck loading rate, adding mineral to the grain prior to loadout, utilizing a dead box or sock at the loadout spout, and postponing operations until no visible emissions are observed. The Permittee shall keep a record of the type and date of any corrective action taken and whether or not the corrective actions eliminated the visible emissions. [Minn. R , subps. 4-5] EQUI 61 Truck Loadout Opacity <= 10 percent opacity from truck loading station fugitive emissions. [Minn. R , subp. 3(B)] Visible Emissions: The Permittee shall check EQUI 61 for any visible emissions using Method 22 once each day of operation during daylight hours. The observation period shall be no less than 10 minutes and shall be conducted while grain loading occurs. Each observer determining the presence of visible emissions must meet the training requirements specified in 40 CFR Part 60, appendix A-7, Section 2.3 of Method 22. If no grain is loaded at EQUI 61 during the operating day, then the Permittee shall record that no grain was loaded out. [Minn. R , subps. 1-2] Visible Emissions: Recordkeeping of Visible Emissions. The Permittee shall record the time and date of each visible emission inspection, and whether or not any visible emissions were observed. The presence of visible emissions at the unloading station is considered a deviation and must be reported in the semiannual deviations report and annual deviations report required by this permit. [Minn. R , subps. 4-5] Visible Emissions: Corrective Actions: The Permittee shall take corrective action as soon as possible if visible emissions are observed. Corrective actions include, but are not limited to, reducing the truck loading rate, adding mineral to the grain prior to loadout, utilizing a dead box or sock at the loadout spout, and postponing operations until no visible emissions are observed. The Permittee shall keep a record of the type and date of any corrective action taken and whether or not the corrective actions eliminated the visible emissions. [Minn. R , subps. 4-5] EQUI 62 Truck Loadout Opacity <= 10 percent opacity from truck loading station fugitive emissions. [Minn. R , subp. 3(B)]

18 Permit Expires: [month day, year] Page 18 of Visible Emissions: The Permittee shall check EQUI 62 for any visible emissions using Method 22 once each day of operation during daylight hours. The observation period shall be no less than 10 minutes and shall be conducted while grain loading occurs. Each observer determining the presence of visible emissions must meet the training requirements specified in 40 CFR Part 60, appendix A-7, Section 2.3 of Method 22. If no grain is loaded at EQUI 62 during the operating day, then the Permittee shall record that no grain was loaded out. [Minn. R , subps. 1-2] Visible Emissions: Recordkeeping of Visible Emissions. The Permittee shall record the time and date of each visible emission inspection, and whether or not any visible emissions were observed. The presence of visible emissions at the unloading station is considered a deviation and must be reported in the semiannual deviations report and annual deviations report required by this permit. [Minn. R , subps. 4-5] Visible Emissions: Corrective Actions: The Permittee shall take corrective action as soon as possible if visible emissions are observed. Corrective actions include, but are not limited to, reducing the truck loading rate, adding mineral to the grain prior to loadout, utilizing a dead box or sock at the loadout spout, and postponing operations until no visible emissions are observed. The Permittee shall keep a record of the type and date of any corrective action taken and whether or not the corrective actions eliminated the visible emissions. [Minn. R , subps. 4-5] EQUI 63 Grain Gobbler Opacity <= 5 percent opacity from handling operation fugitive emissions (this includes grain reclaim from the pile and conveyance up to the gobbler spout). [Minn. R , subp. 3(A)] Opacity <= 10 percent opacity from truck loading fugitive emissions (this included emissions from the spout and the drop into the truck). [Minn. R , subp. 3(B)] Visible Emissions: The Permittee shall check EQUI 63 for any visible emissions using Method 22 once each day of operation during daylight hours. The observation period shall be no less than 10 minutes and shall be conducted while grain is being reclaimed from a temporary storage pile. Each observer determining the presence of visible emissions must meet the training requirements specified in 40 CFR Part 60, appendix A-7, Section 2.3 of Method 22. If no grain is being reclaimed from a pile during the operating day, then the Permittee shall record that no grain was reclaimed from the pile. [Minn. R , subps. 1-2] Visible Emissions: Recordkeeping of Visible Emissions. The Permittee shall record the time and date of each visible emission inspection, and whether or not any visible emissions were observed. The presence of visible emissions at the unloading station is considered a deviation and must be reported in the semiannual deviations report and annual deviations report required by this

19 Permit Expires: [month day, year] Page 19 of 26 permit. [Minn. R , subps. 4-5] Visible Emissions: Corrective Actions: The Permittee shall take corrective action as soon as possible if visible emissions are observed. Corrective actions include, but are not limited to, reducing the rate of grain being removed from the pile, reducing the drop height of the grain into the truck, adding mineral oil prior to reclaim, adding a sleeve or sock to the gobbler spout, and postponing operations until no visible emissions are observed. The Permittee shall keep a record of the type and date of any corrective action taken and whether or not the corrective actions eliminated the visible emissions. [Minn. R , subps. 4-5] EQUI 64 Rail Pit Opacity <= 5 percent opacity from railcar loading station fugitive (uncaptured) emissions. [Minn. R , subp. 3(A)] Visible Emissions: The Permittee shall check EQUI 64 for any visible emissions using Method 22 once each day of operation during daylight hours. The observation period shall be no less than 10 minutes and shall be conducted while grain is received. Each observer determining the presence of visible emissions must meet the training requirements specified in 40 CFR Part 60, appendix A-7, Section 2.3 of Method 22. If no grain is received at the rail pit during the operating day, then the Permittee shall record that no grain was received at the rail pit. [Minn. R , subps. 1-2] Visible Emissions: Recordkeeping of Visible Emissions. The Permittee shall record the time and date of each visible emission inspection, and whether or not any visible emissions were observed. The presence of visible emissions at the unloading station is considered a deviation and must be reported in the semiannual deviations report and annual deviations report required by this permit. [Minn. R , subps. 4-5] Visible Emissions: Corrective Actions: The Permittee shall take corrective action as soon as possible if visible emissions are observed. Corrective actions include, but are not limited to, reducing the rate of grain being loaded out, reducing the drop height of the grain, and postponing operations until no visible emissions are observed (such as if high wind are contributing to the visible emissions). The Permittee shall keep a record of the type and date of any corrective action taken and whether or not the corrective actions eliminated the visible emissions. [Minn. R , subps. 4-5] EQUI 65 Portable 1 - Pile 2& Opacity <= 5 percent opacity from truck unloading and handling operation emissions. This limit applies to emissions from unloading of the grain from trucks to the conveyor, from the grain being conveyed, and from the drop of the grain onto the pile. [Minn. R.

20 Permit Expires: [month day, year] Page 20 of , subp. 3(A)] Visible Emissions: The Permittee shall check EQUI 65 for any visible emissions using Method 22 once each day of operation during daylight hours. The observation period shall be no less than 10 minutes and shall be conducted while grain is being added to a temporary storage pile. Each observer determining the presence of visible emissions must meet the training requirements specified in 40 CFR Part 60, appendix A-7, Section 2.3 of Method 22. If no grain is being reclaimed from a pile during the operating day, then the Permittee shall record that the conveyor was not used. [Minn. R , subps. 1-2] Visible Emissions: Recordkeeping of Visible Emissions. The Permittee shall record the time and date of each visible emission inspection, and whether or not any visible emissions were observed. The presence of visible emissions is considered a deviation and must be reported in the semiannual deviations report and annual deviations report required by this permit. [Minn. R , subps. 4-5] Visible Emissions: Corrective Actions: The Permittee shall take corrective action as soon as possible if visible emissions are observed. Corrective actions include, but are not limited to, reducing the rate of grain being unloaded and conveyed, reducing the drop height of the grain into the pile, adding a sleeve or sock to the conveyor spout, and postponing operations until no visible emissions are observed. The Permittee shall keep a record of the type and date of any corrective action taken and whether or not the corrective actions eliminated the visible emissions. [Minn. R , subps. 4-5] EQUI 66 Portable Auger/ 2 - Pile Opacity <= 5 percent opacity from truck unloading and handling operation emissions. This limit applies to emissions from unloading of the grain from trucks to the conveyor, from the grain being conveyed, and from the drop of the grain onto the pile. [Minn. R , subp. 3(A)] Visible Emissions: The Permittee shall check EQUI 66 for any visible emissions using Method 22 once each day of operation during daylight hours. The observation period shall be no less than 10 minutes and shall be conducted while grain is being added to a temporary storage pile. Each observer determining the presence of visible emissions must meet the training requirements specified in 40 CFR Part 60, appendix A-7, Section 2.3 of Method 22. If no grain is being reclaimed from a pile during the operating day, then the Permittee shall record that the conveyor was not used. [Minn. R , subps. 1-2] Visible Emissions: Recordkeeping of Visible Emissions. The Permittee shall record the time and date of each visible emission inspection, and whether or not any visible emissions were

21 Permit Expires: [month day, year] Page 21 of 26 observed. The presence of visible emissions is considered a deviation and must be reported in the semiannual deviations report and annual deviations report required by this permit. [Minn. R , subps. 4-5] Visible Emissions: Corrective Actions: The Permittee shall take corrective action as soon as possible if visible emissions are observed. Corrective actions include, but are not limited to, reducing the rate of grain being unloaded and conveyed, reducing the drop height of the grain into the pile, adding a sleeve or sock to the conveyor spout, and postponing operations until no visible emissions are observed. The Permittee shall keep a record of the type and date of any corrective action taken and whether or not the corrective actions eliminated the visible emissions. [Minn. R , subps. 4-5] FUGI 1 Pile 1 (XT2) Opacity <= 5 percent opacity from handling operation fugitive emissions. See EQUI 37, 38, 39, and 63 for compliance demonstration while adding grain to the pile or reclaiming grain from the pile. [Minn. R , subp. 3(A)] The capacity of Pile 1 (FUGI 1) is 30,000 tons of grain. The Permittee shall fill the pile only once each calendar year. [Minn. R , subp. 2(B)] The Permittee shall fully cover the pile while grain is being stored. [Minn. R , subp. 2(B)] FUGI 2 Unpaved roads The Permittee shall clean up commodities spilled on the driveway and other facility property as required to minimize fugitive emissions to a level consistent with RACT (reasonably available control technology). [Minn. R , subp. 1(A)] The Permittee shall clean all roads at least once each calendar month. Anytime fugitive emissions are observed on facility roadways, the Permittee shall immediately eliminate fugitive emissions by cleaning those road segments and/or apply water or a chemical dust suppressant. [Minn. R , subp. 1(A) and (B)] Recordkeeping of visible emissions: On each day of operation, the Permittee shall visually inspect all surfaces to minimize or eliminate fugitive emissions. The facility shall maintain records of this inspection that include the date of inspection, whether or not fugitive dust was observed leaving the property, what corrective actions were taken (if any), when the corrective actions were taken, and whether the corrective actions eliminated the fugitive dust. [Minn. R , subps. 4-5] The Permittee shall implement and enforce a facility-wide speed limit of 10 miles per hour. The Permittee must post the speed limit in a highly visible location near the facility entrance. [Minn. R , subp. 2(B)]

22 Permit Expires: [month day, year] Page 22 of 26 FUGI 3 Pile 2 (XT7) Opacity <= 5 percent opacity from handling operation fugitive emissions. See EQUI 63 and 65 for compliance demonstration while adding grain to the pile or reclaiming grain from the pile. [Minn. R , subp. 3(A)] The Permittee shall fully cover the pile while grain is being stored. [Minn. R , subp. 2(B)] FUGI 4 Pile 3 (XT8) Opacity <= 5 percent opacity from handling operation fugitive emissions. See EQUI 63 and 65 for compliance demonstration while adding grain to the pile or reclaiming grain from the pile. [Minn. R , subp. 3(A)] The Permittee shall fully cover the pile while grain is being stored. [Minn. R , subp. 2(B)] FUGI 5 Pile 4 (XT5) Opacity <= 5 percent opacity from handling operation fugitive emissions. See EQUI 65 and 66 for compliance demonstration while adding grain to the pile or reclaiming grain from the pile. [Minn. R , subp. 3(A)] The Permittee shall fully cover the pile while grain is being stored. [Minn. R , subp. 2(B)] TREA 1 Pit 2 Baghouse The Permittee shall vent emissions from EQUI 10 to TREA 1 whenever EQUI 10 operates, and operate and maintain TREA 1 at all times that any emissions are vented to TREA 1. The Permittee shall document periods of non-operation of the control equipment TREA 1 whenever EQUI 10 is operating. [Minn. R , subp. 2(B)] Particulate Matter >= 80 percent collection efficiency for the control equipment. [Minn. R , subp. 3(E)] Opacity <= 10 percent opacity discharged from control equipment. [Minn. R , subp. 3(D)] The Permittee shall operate and maintain control equipment such that it achieves a capture efficiency for Particulate Matter >= 80 percent capture efficiency. [Minn. R , subp. 2(A)] The Permittee shall operate and maintain control equipment such that it achieves a capture efficiency for PM < 10 micron >= 80 percent capture efficiency. [Minn. R , subp. 2(A)] The Permittee shall operate and maintain control equipment such that it achieves a capture efficiency for PM < 2.5 micron >= 80 percent capture efficiency. [Minn. R , subp. 2(A)] The Permittee shall operate and maintain control equipment such that it achieves a control efficiency for Particulate Matter >= 99