air emission permit no. 12900014-006 is issued to southern

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

AIR EMISSION PERMIT NO. 12900014- 006 Minor Amendment

IS ISSUED TO

Southern Minnesota Beet Sugar Cooperative

SOUTHERN MINNESOTA BEET SUGAR COOP

83550 County Road 21 Renville, Renville County, MN 56284

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. 12900014- 005 and authorizes the Permittee to operate and construct the stationary source at the address listed above unless otherwise noted in Table A. The Permittee must comply with all the conditions of the permit. Any changes or modifications to the stationary source must be performed in compliance with Minn. R. 7007.1150 to 7007.1500. Terms used in the permit are as defined in the state air pollution control rules unless the term is explicitly defined in the permit. Unless otherwise indicated, all the Minnesota rules cited as the origin of the permit terms are incorporated into the SIP under 40 CFR § 52.1220 and as such are enforceable by U.S. Environmental Protection Agency (EPA) Administrator or citizens under the Clean Air Act. Permit Type: Federal; Part 70/Major for NSR Operating Permit Issue Date: 04/01/1998 Minor Amendment Issue Date: September 29, 2009 Expiration Date: 04/01/2003<*> – Title I Conditions do not expire.

<*> The Permittee may continue to operate this facility after the expiration date of the permit, per the provision under Minn. R. 7007.0450, subp. 3. (Title V Reissuance Application was received 9/27/2002) Jeff J. Smith, Manager Air Quality Permits Section Industrial Division for Paul Eger Commissioner Minnesota Pollution Control Agency

Permit Applications Table

Permit Type Application Date Permit Action

Total Facility Operating Permit January 17, 1995 001 Major Amendment July 1, 1998 002 Major Amendment March 13, 2000 003 Major Amendment June 8, 2002 004 Major Amendment November 29, 2005 005 Minor Amendment June 15, 2009 006

TABLE OF CONTENTS

Notice to the Permittee Permit Shield Facility Description Amendment Description Table A: Limits and Other Requirements Table B: Submittals Table C: Compliance Schedule: Not included in this permit action. Appendices: Attached and Referenced in Table A

NOTICE TO THE PERMITTEE: Your stationary source may be subject to the requirements of the Minnesota Pollution Control Agency’s (MPCA) solid waste, hazardous waste, and water quality programs. If you wish to obtain information on these programs, including information on obtaining any required permits, please contact the MPCA general information number at: Metro Area 651-296-6300 Outside Metro Area 1-800-657-3864 TTY 651-282-5332 The rules governing these programs are contained in Minn. R. chs. 7000-7105. Written questions may be sent to: Minnesota Pollution Control Agency, 520 Lafayette Road North, St. Paul, Minnesota 55155-4194. Questions about this air emission permit or about air quality requirements can also be directed to the telephone numbers and address listed above. PERMIT SHIELD: Subject to the limitations in Minn. R. 7007.1800, compliance with the conditions of this permit shall be deemed compliance with the specific provision of the applicable requirement identified in the permit as the basis of each condition. Subject to the limitations of Minn. R. 7007.1800 and 7017.0100, subp. 2, notwithstanding the conditions of this permit specifying compliance practices for applicable requirements, any person (including the Permittee) may also use other credible evidence to establish compliance or noncompliance with applicable requirements.

FACILITY DESCRIPTION: Southern Minnesota Beet Sugar Cooperative (SMBSC) processes sugar from sugar beets for use in many consumer food products. The original facility was built in 1974. SMBSC has about 480 members and grows beets in an eleven county area around the plant. The cooperative employs roughly 250 year-round employees and 350 seasonal employees. The facility’s operation is split into time periods referred to as campaigns. Harvest can begin as early as August and usually ends in November. The beet slicing campaign will generally run from September to March, while the juice processing campaign will generally run through June, and the molasses campaign will run through August. The major sources of air emissions at SMBSC can be divided into two categories: combustion sources and product handling sources. Combustion sources include three boilers and two lime kilns. The largest boiler is controlled by an electrostatic precipitator and the lime kilns are uncontrolled (although the combustion gas is usually bubbled through the carbonators). Product handling sources include sugar handling and conveying equipment along with other product/raw material handling equipment. The majority of the product handling sources are controlled by baghouses. Two units are controlled by scrubbers. The major source of fugitive emissions at the facility is truck traffic. AMENDMENT DESCRIPTION Permit action 002: SMBSC proposed a five-year capital improvements project to expand processing capacity, enhance operational efficiency, and improve performance. A permit amendment application was received on July 1, 1998, and amended on July 7, 1998 and August 7, 1998. The project involved the replacement or modification of nearly every major unit operation at the facility. The project included a number of modifications to air emission sources at the facility. Boilers two and three were planned for replacement by a new boiler four. The two direct-fired pulp dryers were replaced by two steam pulp dryers. The replacement of a number of non-air emission units increased sugar production and debottlenecked the processing plant and a number of product handling sources. A new wastewater treatment plant was planned to be built. One goal of the capital improvements project was to reduce SMBSC’s role as an odor and Hydrogen Sulfide (H2S) source. H2S monitoring was a requirement in permit No. 12900014- 002 to measure the H2S concentrations around the new plant. Permit action 003: This modification was for the installation and operation of temporary boilers, in the event of an emergency situation in which one of the existing boilers are not operable. The temporary boilers use only natural gas, and permit No. 12900014- 003 limits operation to 790 million cubic feet of natural gas usage per year. This requirement resulted in nitrogen oxides emissions of less than 40 tons per year (TPY), which is the limit for significant levels. 40 CFR pt. 60, Subpart Dc contains no standards for boilers burning only natural gas, however startup notifications are required, as well as recordkeeping of fuel combusted.

Permit action 004: This permit action responded to two applications for changes to permit conditions:

• To remove the requirement for computer dispersion modeling of hydrogen sulfide emissions. The facility continues to operate hydrogen sulfide ambient air monitors.

• To extend the date by which a new boiler can be installed from December 31, 2002, to December 31, 2004. The installation of this new boiler was originally authorized by permit action 002.

Permit Action 005: This permit amendment revised the pressure drop monitoring range for Pellet Cooler Cyclone (EU 006/CE 010) and Sugar Drier/Cooler Scrubber (EU 007/CE 011); making changes to the existing monitoring requirements is done only through a major amendment.

Permit Action 006: This permit action is a minor permit amendment. This amendment authorizes SMBSC to modify its facility to enhance safety. Dust emissions associated with maintenance activity is SMBSC's primary concern in the beet pulp processing area of the plant. Therefore, SMBSC is proposing the following changes to minimize the occurrences of plugging and thereby reduce maintenance related dust emissions: • Install a hammermill, new emissions unit EU032, controlled by a centrifugal collection system

(CE029) as required by federally enforceable rules. The new hammermill will be placed into the process downstream of the existing pulp dryers and upstream of the pellet mills/coolers to help pulverize the dry beet pulp into a more uniform size.

• Modify the existing Pellet Cooler Dust Control System (EU 006) by: o Replacing the belt conveyance system with an enclosed auger system. o Replacing one of the four existing pellet mills with a new modern pellet mill. o Replacing the four existing pellet coolers with two new pellet coolers. Each of the new pellet

coolers will exhaust to its own cyclone (CE027 and CE028), and the exhaust will be routed to the existing cyclone (CE 010). By exhausting the new pellet coolers through new individual cyclones and through the existing common cyclone, actual particulate emissions will be further reduced before exiting the permitted stack.

o No changes will be made to the existing pulp system cyclone air blower, which controls the amount of air through the dust control system. Therefore, the modified Pellet Cooler Dust Control System (EU 006) will be limited by the capacity of the air blower at the existing cyclone (CE 010).

• Updates permit language to reflect changes in applicable rules and standard operating practices. • Removes obsolete requirements.

TABLE A: LIMITS AND OTHER REQUIREMENTS 09/29/09

Southern Minnesota Beet Sugar Coop

12900014 - 006

Facility Name:

Permit Number:

A-1

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

Subject Item: Total Facility

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

40 CFR pt. 50; Minn. Stat. Section 116.07, subds. 4a &9; Minn. R. 7007.0100, subp. 7(A), 7(L), & 7(M); Minn.R. 7007.0800, subps. 1, 2 & 4; Minn. R.7009.0010-7009.0080

Equipment Removal and/or Dismantlement: due 180 days after Initial Startup of EU028. EU 002 and EU 003 must be removed or dismantled after a reasonableshakedown period for EU 028 but not later than 180 days after initial starup ofEU028. In addition, all construction activities related to this modification, asdescribed in Attachment 1 to the Technical Support Document for permit action002, must be completed by December 31, 2004.

Note: EU004 and EU005, also required to be removed or dismantled by priorpermit action 002, have been removed.

Title I Condition: To avoid classification as a majormodification under 40 CFR 52.21

Air Pollution Control Equipment: Operate all pollution control equipment wheneverthe corresponding process equipment and emission units are operated, unlessotherwise noted in Table A.

Minn. R. 7007.0800, subp. 2;Minn. R. 7007.0800, subp. 16(J)

Operation and Maintenance Plan: Retain at the stationary source an operation andmaintenance (O&M) plan for all air pollution control equipment. The plan shallinclude: the manufacturer's recommended operating ranges for parameters to bemonitored such as pressure drop across the system, liquid flow rate, liquid supplypressure, etc.; corrective action procedures to be followed to return the controlequipment to within the specified range(s); corrective action procedures to befollowed in the event of a malfunction or breakdown; a description of inspectionprocedures to be followed; and records kept to demonstrate plan implementation.

Minn. R. 7007.0800, subp. 14 andMinn. R. 7007.0800, subp. 16(J)

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

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

Operating and/or production limits will be placed on emission units based onoperating conditions during performance testing. Limits set as a result of aperformance test (conducted before or after permit issuance) apply until newoperating/production limits are set following formal review of a performance test asspecified by Minn. R. 7017.2025

Minn. R. 7017.2025

Temporary boilers may be brought on site for the purpose of providing steam, heat,or electrical power in place of boilers that are temporarily out of operation for lessthan one year. The temporary units may not be operated at the same time as thepermanent units that they are meant to replace, except for up to 8 hours during thestart-up and shutdown transition periods.

Minn. R. 7007.0800, subp.2

Temporary boilers shall have a maximum design heat input capacity of 100 millionBtu per hour, to be eligible as a Subpart Dc Boiler. Boilers shall only combustnatural gas.

40 CFR Section 60.40c

Fuel Usage: less than or equal to 790 million cubic feet/year using 12-monthRolling Sum with this total applying to cumulative usage of all temporary boilers tobe used.

Title I Condition: to limit potential emissions increase toless than significant levels.

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

Minn. R. ch. 7017

Monitoring Equipment Calibration: Annually calibrate all required monitoringequipment (any requirements applying to continuous emission monitors are listedseparately in this permit).

Minn. R. 7007.0800, subp. 4(D)

Operation of Monitoring Equipment: Unless otherwise noted in Tables A, B, and/orC, monitoring a process or control equipment connected to that process is notnecessary during periods when the process is shutdown, or during checks of themonitoring systems, such as calibration checks and zero and span adjustments. Ifmonitoring records are required, they should reflect any such periods of processshutdown or checks of the monitoring system.

Minn. R. 7007.0800, subp. 4(D)

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

Minn. R. 7011.0020



12900014 - 006

Facility Name:

Permit Number:

A-2

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

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

Minn. R. 7019.1000, subp. 3

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

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

Minn. R. 7019.1000, subp. 2

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

Minn. R. 7019.1000, subp. 1

Notification of Deviations Endangering Human Health or the Environment Report:Within 2 working days of discovery, notify the Commissioner in writing of anydeviation from permit conditions which could endanger human health or theenvironment. Include the following information in this written description:1. the cause of the deviation;2. the exact dates of the period of the deviation, if the deviation has 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 yetcorrected; and5. steps taken or planned to reduce, eliminate, and prevent reoccurrence of thedeviation.

Minn. R. 7019.1000, subp. 1

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

Minn. R. 7007.1150 through Minn. R. 7007.1500

Extension Requests: The Permittee may apply for an Administrative Amendmentto extend a deadline in a permit by no more than 120 days, provided the proposeddeadline extension meets the requirements of Minn. R. 7007.1400, subp. 1(H)

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

Record keeping: Maintain records describing any insignificant modifications (asrequired by Minn. R. 7007. 1250, subp. 3) or changes contravening permit terms(as required by Minn. R. 7007.1350 subp. 2), including records of the emissionsresulting from those changes.

Minn. R. 7007. 0800, subp. 5(B)

If the Permittee determines that no permit amendment or notification is requiredprior to making a change, the Permittee must retain records of all calculationsrequired under Minn. R. 7007.1200. These records shall be kept for a period of fiveyears from the date the change was made or until permit reissuance, whichever islonger. The records shall be kept at the stationary source for the current calendaryear of operation and may be kept at the stationary source or office of thestationary source for all other years. The records may be maintained in eitherelectronic or paper format.

Minn. R. 7007.1200, subp. 4

Recordkeeping and Reporting for Temporary Boilers: Keep the following recordson site: documentation of hours of operation of the temporary units, a statement forall periods of temporary unit operation that the replaced permanent unit is not alsooperation, and fuel usage for all temporary boilers employed. Notification due 10days before anticipated date of initial startup, and 15 days after actual initial startup.Notify the Commissioner if temporary and permanent units are operatedsimultaneously, except as allowed by this permit. Make verbal notification of thiswithin 2 days, and written notification with the semi-annual deviations report.

Minn. R. 7007.0800, subp. 2

Record keeping: Retain all records at the stationary source for a period of five (5)years from the date of monitoring, sample, measurement, or report. Records whichmust be retained at this location include all calibration and maintenance records, alloriginal strip-chart recordings for continuous monitoring instrumentation, and copiesof all reports required by the permit. Records must conform to the requirementslisted in Minn. R. 7007.0800, subp. 5(A).

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



12900014 - 006

Facility Name:

Permit Number:

A-3

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

Minn. R. 7030.0010 - 7030.0080

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

Minn. R. 7007.0800, subp. 16

Inspections: Upon presentation of credentials and other documents as may berequired by law, allow the Agency, or its representative, to enter the Permittee'spremises to have access to and copy any records required by this permit, to inspectat reasonable times (which include any time the source is operating) any facilities,equipment, practices or operations, and to sample or monitor any substances orparameters at any location.

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

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

Minn. R. 7019.3000 through Minn. R. 7019.3010

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

For changes that do not require a permit amendment:- The Permittee shall submit a Part 1 MACT application within 30 days of startup ofany 112(j) affected source. The application shall meet the requirements of 40 CFRSection 63.53(a).- The Permittee shall submit a Part 2 MACT application within 90 days of startup ofany 112(j) affected source. The application shall meet the requirements of 40 CFRSection 63.53(b).112(j) affected source is defined in 40 CFR Section 63.51. As of permit issuance,112(j) affected sources include industrial, commercial, and institutional boilers andprocess heaters; brick and structural clay products manufacturing; clay ceramicsmanufacturing.

40 CFR Section 63.52(b)(1) and 63.52(e)(1)

HYDROGEN SULFIDE REQUIREMENTS hdr

Hydrogen Sulfide: emissions from the facility shall not cause or contribute to anambient concentration that is greater then 0.05 parts per million as a 1/2 houraverage not to be exceeded more than 2 times per year.

Minn. R. 7009.0080; Minn. R. 7007.0800, subp. 2

Hydrogen Sulfide: emissions from the facility shall not cause or contribute to anambient concentration that is greater then 0.03 parts per million as a 1/2 houraverage not to be exceeded more than 2 times in any five consecutive days.

Minn. R. 7009.0080; Minn. R. 7007.0800, subp. 2

Hydrogen Sulfide Monitoring: A Monitoring Network for hydrogen sulfide must be inplace and operating before permit issuance. The monitoring network must beoperating at all times during the months of April through October. A HydrogenSulfide Monitoring Plan shall be approved by the South District Manager (or hisdesignee) before the Monitoring Network can be constructed. The Plan shallinclude a description of the monitors, their locations, and the quality assurancerequirements for the monitors and their data.

Minn. R. 7007.0800, subp. 4

Hydrogen Sulfide Monitoring Corrective Actions: The operation of the monitorsshall be checked, and the data downloaded, weekly. If the data show anexceedance of the hydrogen sulfide standard the Permittee shall:

1) notify the Agency at (218) 846-0746 no later than 24 hours after the exceedanceis discovered;

2) immediately implement the monitoring requirements for stations WS015 throughWS027 of National Pollutant Discharge Elimination System (NPDES)/StateDisposal System (SDS) Permit MN0040665, at a monitoring frequency of twice perweek and a duration to be determined by the Commissioner; OR explain in 1) whythe monitoring will not be immediately implemented.

Minn. R. 7007.0800, subp. 2

Hydrogen Sulfide Monitoring Corrective Actions (continued):

3) within 7 days after the exceedance is discovered submit a written report to theAgency addressed to the Compliance Tracking Coordinator, Majors andRemediation Division, MWL Section, C and E Unit, 520 Lafayette Road, St. Paul,Minnesota 55155, that: identifies the reason for the elevated levels, evaluates andaddresses whether or not the hydrogen sulfide emissions are expected to increase,and recommends whether corrective actions are necessary and a schedule for theirimplementation.

Agency staff will evaluate the information contained in the report and notify thePermittee if the corrective actions identified must be implemented.

Minn. R. 7007.0800, subp. 2

DETERMINING IF A PROJECT/MODIFICATION IS SUBJECT TO NEW SOURCEREVIEW

hdr



12900014 - 006

Facility Name:

Permit Number:

A-4

These requirements apply where there is a reasonable possibility that a proposedproject, analyzed using the actual-to-projected-actual (ATPA) test and found to notbe part of a major modification, may result in a significant emissions increase. Ifthe ATPA test is not used for a particular project, or if there is not a reasonablepossibility that the proposed project could result in a significant emissions increase,then these requirements do not apply to that project.

Even though a particular modification is not subject to New Source Review, apermit amendment, recordkeeping, or notification may still be required under Minn.R. 7007.1150 - 7007.1500.

Title I Condition: 40 CFR Section 52.21(r)(6) and Minn.R. 7007.3000

Preconstruction Documentation -- Before beginning actual construction on aproject, the Permittee shall document the following information:

1. A description of the project2. Identification of the emission unit(s) whose emissions of an NSR pollutant couldbe affected3. A description of the applicability test used to determine that the project is not amajor modification for any regulated NSR pollutant, including the baseline actualemissions, the potential emissions, the projected actual emissions, the amount ofemissions excluded due to increases not associated with the modification and thatthe unit(s) could have accommodated during the baseline period, an explanation ofwhy the amounts were excluded, and any creditable contemporaneous increasesand decreases that were considered in the determination.

The Permittee shall maintain records of this documentation.

Title I Condition: 40 CFR Section 52.21(r)(6) and Minn.R. 7007.3000; Minn. R. 7007.0800, subp. 4 & 5

The Permittee shall monitor the actual emissions of any regulated NSR pollutantthat could increase as a result of the project and that were analyzed using theATPA test, and the potential emissions of any regulated NSR pollutant that couldincrease as a result of the project and that were analyzed using potentialemissions. The Permittee shall calculate and maintain a record of the sum of theactual and potential (if used in the analysis) emissions of the regulated pollutant, intons per year on a calendar year basis, for a period of 5 years following resumptionof regular operations after the change, or for a period of 10 years followingresumption of regular operations after the change if the project increases thedesign capacity of or potential to emit of any unit associated with the project.


The Permittee must submit a report to the Agency if the annual summed (actualplus potential, if applicable) emissions differ from the preconstruction projection andexceed the baseline actual emissions by a significant amount as listed at 40 CFRSection 52.21(b)(23). Such report shall be submitted to the Agency within 60 daysafter the end of the year in which the exceedances occur. The report shall contain:

a. The name and ID number of the facility, and the name and telephone number ofthe facility contact personb. The annual emissions (actual plus potential, if any part of the project wasanalyzed using potential emissions) for each pollutant for which the preconstructionprojection and significant emissions increase are exceeded.c. Any other information, such as an explanation as to why the summed emissionsdiffer from the preconstruction projection.




12900014 - 006

Facility Name:

Permit Number:

A-5

Subject Item: GP 001 Insignificant Particulate Sources

Associated Items: EU 012 Sugar Conveying/Silo Penthouse Dust Control

EU 016 Lime Rock Classifier

EU 017 Bulk Soda Ash Conveying System

EU 018 Chemical Feed Station Dust Control Systems

EU 019 Ash Conveying System

EU 020 Weibull Bin Dust Control System

EU 021 Pellet Conveying System

EU 022 Sugar Screening & Bagging Dust Control System

EU 024 Bulk Sugar Control Vacuum System

EU 026 Lime Dispensing Dust Collector

What to do Why to do itTotal Particulate Matter: less than or equal to 0.3 grains/dry standard cubic foot ofexhaust gas unless required to further reduce emissions to meet the less stringentlimit of either Minn. R. 7011.0730 or Minn. R. 7011. 0735 (applies individually toeach emission unit listed under Associated Items).

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

Opacity: less than or equal to 20 percent opacity (applies individually to eachemission unit listed under Associated Items).

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

Monitoring of Pollution Control Equipment: Operation and maintenance proceduresfor each piece of pollution control equipment associated with the emission unitslisted in GP 001 (i.e. CE 016, CE 017, CE 018, CE 019, CE 020, CE 021, CE 023,CE 024) shall be covered under the facility operation and maintenance plan.

Minn. R. 7007.0800, subp. 2



12900014 - 006

Facility Name:

Permit Number:

A-6

Subject Item: GP 002 Lime production and use

Associated Items: EU 013 Lime Kiln A

EU 014 Lime Kiln B

EU 015 Lime Slaker

What to do Why to do itEMISSION LIMITS hdr

Total Particulate Matter: less than or equal to 0.3 grains/dry standard cubic foot ofexhaust gas unless required to further reduce emissions to meet the less stringentlimit of either Minn. R. 7011.0730 or Minn. R. 7011.0735. This limit appliesindividually to EU 013 and EU 014.

Minn. R. 7011.0610, subp. 1(A)(1)

Opacity: less than or equal to 20 percent opacity except for one six-minute periodper hour of not more than 60 percent opacity. This limit applies individually to EU013 and EU 014.

Minn. R. 7011.0610, subp. 1(A)(2)

Sulfur Dioxide: less than or equal to 4.0 lbs/million Btu heat input for solid fossilfuels. This limit applies individually to EU 013 and EU 014.

Minn. R. 7011.0610, subp. 2(B)

OPERATIONAL LIMITS hdr

Material Usage: less than or equal to 115344 tons/year using 12-month RollingSum for limestone

Title I Condition: Limit to avoid classification as a majormodification under 40 CFR Section 52.21

Material Usage: less than or equal to 8572 tons/year using 12-month Rolling Sumfor coke

Title I Condition: Limit to avoid classification as a majormodification under 40 CFR Section 52.21

Sulfur Content of Fuel: less than or equal to 1 percent by weight for coke Title I Condition: Limit to avoid classification as a majormodification under 40 CFR Section 52.21

Fuels Allowed: industrial oven coke as the main fuel source. Natural gas, propaneand/or wood as fuels for initiating combustion of the coke.

Minn. R. 7007.0800, subp. 2

RECORDKEEPING hdr

Limestone and Coke Usage Recordkeeping: once each day record the amount oflimestone and coke used in the lime kilns for the previous day. At the end of eachcalendar month, calculate and record the usage of limestone and coke during theprevious month and the previous 12-month period.

Title I Condition: Recordkeeping to avoid classificationas a major modification under 40 CFR Section 52.21;Minn. R. 7007.0800, subp. 5

Coke Sulfur Content Recordkeeping: For each coke shipment, the Permittee shallobtain a fuel certification from the fuel supplier, stating the percent sulfur by weight,in the coke. Maintain certification records for a minimum of 5 years from the date ofreceipt.




12900014 - 006

Facility Name:

Permit Number:

A-7

Subject Item: GP 003 Hammermill and Pellet Cooler Primary Centrifugal Collectors

Associated Items: CE 027 Centrifugal Collector - Medium Efficiency

CE 028 Centrifugal Collector - Medium Efficiency


What to do Why to do itOPERATING REQUIREMENTS hdr

Pressure Drop: greater than or equal to 1.5 inches of water column and less than orequal to 10.0 inches of water column

Minn. R. 7007.0800, subp. 2, Minn. R. 7011.0075,subp. 1, Minn. R. 7011.0080

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

Minn. R. 7011.0075, subp. 2

Monitoring Equipment: The Permittee shall install and maintain pressure dropgauges for measuring and recording the presure drop as required by this permit.The monitoring equipment must be installed, in use, and properly maintained whenoperation of the monitored control equipment is required.

Minn. R. 7011.0075, subp. 3

Corrective Actions: The Permittee shall take corrective action as soon as possible ifany of the following occur:- the recorded pressure drop is outside the required operating range; or- any of the associated centrifugal collectors or any of its components are foundduring the inspections to need repair.Corrective actions shall return the pressure drop to within the permitted range,eliminate excesive visible emissions, and/or include completion of necessaryrepairs identified during the inspection, as applicable. Corrective actions include,but are not limited to, those outlined in the O & M Plan for the associatedcentrifugal collectors. The Permittee shall keep a record of the type and date of anycorrective action taken for each associated centrifugal collector.

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

MONITORING REQUIREMENTS hdr

Monitoring of Pollution Control Equipment: Once each operating day measure andrecord the pressure drop in inches of water column across each cyclone. ThePermittee shall record the time and date of each pressure drop reading andwhether or not the recorded pressure drop was within the range specified in thispermit.

Minn. R. 7011.0080, Minn. R. 7007.0800, subp. 4

Corrective Actions: If the monitored parameter is out of the manufacturer'srecommended range, perform the necessary corrective action(s) as stated in thefacility O&M plan. Record all corrective actions immediately after the action iscompleted.

Minn. R. 7007.0800, subp. 14; Minn. R. 7007.0800,subp. 5



12900014 - 006

Facility Name:

Permit Number:

A-8

Subject Item: EU 001 Boiler No. 1 (Main)

Associated Items: CE 001 Electrostatic Precipitator - High Efficiency

MR 004

MR 005

MR 006

MR 007

SV 001


Total Particulate Matter: less than or equal to 0.1 lbs/million Btu heat input 40 CFR Section 60.42(a)(1); Minn. R. 7011.0555

Opacity: less than or equal to 20 percent opacity except for one six-minute periodper hour of not more than 27 percent opacity.

40 CFR Section 60.42(a)(2); Minn. R. 7011.0555

Sulfur Dioxide: less than or equal to 0.8 lbs/million Btu heat input for liquid fossilfuels and 1.2 lbs/million Btu heat input for solid fossil fuels, based on a three-houraverage. When different fossil fuels are burned simultaneously, the sulfur dioxidestandard is determined by proration with the following formula:

PSso2 = [y(0.8) + z(1.2)]/(y+z)

where:PSso2 = prorated SO2 standardy = percentage of total heat input derived from liquid fossil fuelsz = percentage of total heat input derived from solid fossil fuels

40 CFR Section 60.43(a); 40 CFR Section 60.43(b);Minn. R. 7011.0555

Nitrogen Oxides: less than or equal to 0.3 lbs/million Btu heat input for liquid fossilfuels and 0.7 lbs/million Btu heat input for solid fossil fuels, based on a three-houraverage. When different fossil fuels are burned simultaneously, the nitrogen oxidesstandard is determined by proration with the following formula:

PSnox = [y(0.30) + z(0.7)]/(y+z)

where:PSnox = prorated NOx standardy is the percentage of total heat input derived from liquid fossil fuelsz is the percentage of total heat input derived from solid fossil fuels

40 CFR Section 60.44(a); 40 CFR Section 60.44(b);Minn. R. 7011.0555

Fuels Allowed: sub-bituminous coal and fuel oil. Minn. R. 7007.0800, subp. 2

OPERATIONAL REQUIREMENTS hdr

Fuel Heat Input: less than or equal to 254,000 MMBtu/month based on a 12-monthrolling average. This limit applies after the commencement of operation of EU 028.This limit does not apply during periods when EU 028 is shutdown due tomalfunction or for maintenance.

Title I Condition: Limit taken to avoid classification as amajor modification under 40 CFR 52.21

Operation of Pollution Control Equipment: Operate the electrostatic precipitator onEU 001 (CE 001) with no less than the number of fields on-line as during the mostrecent performance test that met the total particulate matter standard in 40 CFRSection 60.42.

Minn. R. 7007.0800, subp. 14


Fuel Heat Content: Determine the heat content of each delivery of each permittedfuel by either of the following methods:

1) according to ASTM sampling and analysis methods in part 5.2.1 and 5.2.2 ofMethod 19 in 40 CFR pt. 60 Appendix A, or2) obtain from the fuel supplier for each permitted fuel delivery, a certification of theheat content of the fuel.

Maintain heat content records for a minimum of five years from the date theinformation was obtained.

Title I Condition: Monitoring to avoid classification as amajor modification under 40 CFR 52.21; Minn. R.7007.0800, subp. 4

CEMS/COMS Operation: Operate certified SO2 and NOx CEMS, as well as acertified continuous opacity monitoring system (COMS), whenever the emissionunit is operating.

Minn. R. 7007.0800, subp. 2; Minn. R. 7017.1000,subp. 1; 40 CFR Section 60.45(a)



12900014 - 006

Facility Name:

Permit Number:

A-9

CEMS Daily Calibration Drift (CD) Test: The CD shall be quantified and recordedat zero (low level) and upscale (high-level) gas concentrations at least once daily.The CEMS shall be adjusted whenever the CD exceeds twice the specification of40 CFR pt. 60, Appendix B. 40 CFR pt. 60, Appendix F shall be used to determineout-of-control periods for CEMS.

40 CFR pt. 60, Appendix F, Section 4.1; 40 CFRSection 60.13(d)(1); Minn. R. 7007.0800, subp. 2

COMS Daily Calibration Drift (CD) Check: The CD shall be quantified and recordedat zero (low-level) and upscale (high-level) opacity at least once daily. The COMSmust be adjusted whenever the calibration drift (CD) exceeds twice thespecification of PS-1 of 40 CFR 60, Appendix B.

Minn. R. 7017.0800, subp. 2; 40 CFR Section 60.13(d)

COMS Calibration Error Audit: due before end of each calendar half-year starting04/01/1998 Conduct audit at least 3 months apart but no greater than 8 monthsapart. Follow the procedure listed in 40CFR60, Appendix B, PS-1, 7.1.4.

Minn. R. 7007.0800, subp. 2; 40 CFR Section 60,App. B., PS-1, part 7.1.4.

Cylinder Gas Audit: due before end of each calendar half-year starting 04/01/1998Conduct CGA at least 3 months apart and not greater than 8 months apart. Followthe procedures in 40 CFR pt. 60, Appendix F.

Minn. R. 7007.0800, subp. 2

CEMS Relative Accuracy Test Audit (RATA): due before end of each calendar yearstarting 04/01/1998 . If the relative accuracy is 15% or less the next CEMS RATAis not due for 24 months. Follow the procedures in 40 CFR pt. 60, Appendix B andAppendix F.

Minn. R. 7007.0800, subp. 2

RECORDKEEPING hdr

Fuel Heat Input: Once each day, record the amount of each type of fuel combustedin EU 001 during the previous day and use these figures to also calculate the totaldaily heat input. At the end of each calendar month, calculate and record the heatinput for the previous month, except do not include the heat input of any fuelscombusted in EU 001 when EU 028 was shutdown due to malfunction ormaintenance. Also at the end of each calendar month, calculate the total heatinput for the previous 12-month period based on a 12-month rolling average, for allfuels combusted in EU 001.

Title I Condition: Recordkeeping to avoid classificationas a major modification under 40 CFR 52.21; Minn. R.7007.0800, subp. 5

CEMS/COMS Continuous Operation: Monitoring systems must be operated anddata recorded during all periods of emission unit operation including periods ofemission unit startup, shutdown, and malfunction. This requirement to operate themonitor applies whether or not a numerical emission limit applies during theseperiods. Monitoring systems must not be bypassed except in emergencies wherefailure to bypass the system would endanger human health, safety, or plantequipment.

Minn. R. 7007.0800, subp. 2

COMS Monitoring Data: Owners or operators of all COMS shall reduce all data to6 minute averages. Opacity averages shall be calculated from all equally spacedconsecutive 10-second (or shorter) data points in the 6 minute averaging period.

Minn. R. 7007.0800, subp. 2

CEMS Recordkeeping: The owner or operator must retain records of all CEMSmonitoring data and support information for a period of five years from the date ofthe monitoring sample, measurement or report. Records shall be kept at thesource.

Minn. R. 7007.0800, subp. 5

COMS Recordkeeping: The owner or operator must retain records of all COMSmonitoring data and support information for a period of five years from the date ofthe monitoring sample, measurement or report. Records shall be kept at thesource.

Minn. R. 7007.0800, subp. 5

Pollution Control Equipment Operating Conditions: The Permittee shall recordonce each day of EU 001 operation, the minimum number of CE 001 fields on-lineduring that day.

Minn. R. 7007.0800, subp. 5



12900014 - 006

Facility Name:

Permit Number:

A-10

Subject Item: EU 002 Boiler No. 2

Associated Items: SV 002

What to do Why to do itTotal Particulate Matter: less than or equal to 0.6 lbs/million Btu heat input Minn. R. 7011.0510, subp. 1

Sulfur Dioxide: less than or equal to 2.0 lbs/million Btu heat input when burning fueloil.

Minn. R. 7011.0510, subp. 1

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

Minn. R. 7011.0510, subp. 2

Fuels Allowed: natural gas and fuel oil. Minn. R. 7007.0800, subp. 2



12900014 - 006

Facility Name:

Permit Number:

A-11



What to do Why to do itTotal Particulate Matter: less than or equal to 0.6 lbs/million Btu heat input Minn. R. 7011.0510, subp. 1

Sulfur Dioxide: less than or equal to 2.0 lbs/million Btu heat input when burning fueloil.

Minn. R. 7011.0510, subp. 1

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

Minn. R. 7011.0510, subp. 2

Fuels Allowed: natural gas and fuel oil. Minn. R. 7007.0800, subp. 2



12900014 - 006

Facility Name:

Permit Number:

A-12

Subject Item: EU 006 Pellet Cooler Dust Control System




SV 011 Pellet Cooler Dust Control System


The Permittee shall operate and maintain the control equipment such that itachieves an overall collection efficiency for Total Particulate Matter: greater than 80percent collection efficiency

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

Opacity: less than or equal to 10 percent opacity (subp. 3(D)) - <discharged fromSV011>

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

The Permittee shall operate and maintain the control equipment such that itachieves an overall control efficiency for PM < 10 micron: greater than 60 percentcontrol efficiency

Minn. R. 7011.0070, subp. 1

OPERATING REQUIREMENTS hdr

The control equipment CE027 and CE028 are the primary control equipment andconsidered listed control equipment under Minn. R. 7011.0060 to 7011.0080. ThePermittee shall operate and maintain the associated centrifugal collectors (CE010,CE027 and CE028) at all times that the pellet cooler dust control system isoperating. The Permittee shall document periods of non-operation of the controlequipment.

Minn. R. 7011.0065, subp. 2(A), Minn. R. 7007.0800,subp. 2 and 14



12900014 - 006

Facility Name:

Permit Number:

A-13

Subject Item: EU 007 Sugar Drier/Cooler

Associated Items: CE 011 Venturi Scrubber

SV 012

What to do Why to do itEMISSON LIMITS +hdr

Total Particulate Matter: less than or equal to 0.3 grains/dry standard cubic foot ofexhaust gas unless required to further reduce emissions to meet the less stringentlimit of either Minn. R. 7011.0730 or Minn. R. 7011.0735.

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

Opacity: less than or equal to 20 percent opacity Minn. R. 7011.0715, subp. 1(B)


Minn. R. 7007.0800, subp. 2

Liquid Flow Rate: greater than or equal to 500 gallons/minute Minn. R. 7007.0800, subp. 2


Monitoring of Pollution Control Equipment: Once each operating day record thepressure drop in inches of water column across the scrubber and the inlet flow ratein gallons per minute.

Minn. R. 7007.0800, subp. 4

Corrective Actions: If any of the monitored parameters are out of the manufacturer'srecommended range, perform the necessary corrective action(s) as stated in thefacility O&M plan. Record all corrective actions immediately after the action iscompleted.




12900014 - 006

Facility Name:

Permit Number:

A-14

Subject Item: EU 008 Sugar Bin Climate Control System

Associated Items: CE 012 Fabric Filter - Low Temperature, i.e., T<180 Degrees F

SV 013

What to do Why to do itTotal Particulate Matter: less than or equal to 0.3 grains/dry standard cubic foot ofexhaust gas unless required to further reduce emissions to meet the less stringentlimit of either Minn. R. 7011.0730 or Minn. R. 7011.0735.

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


Visible Emissions Monitoring: The Permittee shall perform a visible emissionscheck on SV 013 once each day while in operation (during daylight hours). Avisible emissions check shall consist of viewing the exhaust gas exiting the stackand determining whether visible emissions are present or not.

Minn. R. 7007.0800, subp. 4

Visible Emissions Corrective Actions: If visible emissions (VEs) are observed,determine the cause and take corrective actions as soon as possible to eliminatethe VEs.

Minn. R. 7007.0800, subp. 2

Visible Emissions Recordkeeping: Record the time and date of each VEinspection, and whether or not any VEs were observed. If VEs were observed, alsorecord a brief description of the type of corrective actions taken, and the date theactions were taken.

Minn. R. 7007.0800, subp. 5



12900014 - 006

Facility Name:

Permit Number:

A-15



SV 014


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



Minn. R. 7007.0800, subp. 4


Minn. R. 7007.0800, subp. 2


Minn. R. 7007.0800, subp. 5



12900014 - 006

Facility Name:

Permit Number:

A-16



SV 015


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



Minn. R. 7007.0800, subp. 4


Minn. R. 7007.0800, subp. 2


Minn. R. 7007.0800, subp. 5



12900014 - 006

Facility Name:

Permit Number:

A-17



SV 016


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



Minn. R. 7007.0800, subp. 4


Minn. R. 7007.0800, subp. 2


Minn. R. 7007.0800, subp. 5



12900014 - 006

Facility Name:

Permit Number:

A-18




Nitrogen Oxides: less than or equal to 0.0913 lbs/million Btu heat input using30-day Rolling Average

Title I Condition: Limit to avoid classification as a majormodification under 40 CFR 52.21; meets requirementsof 40 CFR Section 60.44b; Minn. R. 7011.0565

Sulfur Dioxide: less than or equal to 0.50 lbs/million Btu heat input using 24-hourBlock Average (calenday day average) when combusting fuel oil.

Title I Condition: Limit to avoid classification as a majormodification under 40 CFR 52.21; meets requirementsof 40 CFR Section 60.42b(a); Minn. R. 7011.0565

Total Particulate Matter: less than or equal to 0.1 lbs/million Btu heat input 40 CFR Section 60.42(a)(1); Minn. R. 7011.0555

Opacity: less than or equal to 20 percent opacity (six-minute average), except forone six-minute period per hour of not more than 27 percent opacity, whencombusting fuel oil.

40 CFR Section 60.43b(f); Minn. R. 7011.0565

Emission Standard Applicability: the nitrogen oxides and sulfur dioxide standardsapply at all times, whereas the opacity standard does not apply during periods ofstartup, shutdown, or malfunction.

40 CFR Section 60.45b(a); 40 CFR Section 60.46b(a);Minn. R. 7011.0565

OPERATIONAL LIMITS hdr

Fuels Allowed: only very low sulfur oil (as defined in 40 CFR Section 60.41b),natural gas, and wastewater treatment plant gases may be combusted in EU 028.

Title I Condition: Fuel restriction to avoid classificationas a major modification under 40 CFR 52.21

Fuel Usage: less than or equal to 1119000 gallons/year using 12-month RollingSum of very low sulfur fuel oil (equivalent to a very low sulfur oil annual capacityfactor of approximately 5.0%).For the first 11 months after the initial startup of EU 028 the Permittee shall use nomore than the following: limit (gallons) = 996927 + 10172(n)where, n = the number of months of operation of EU 028

Title I Condition: Limit taken to avoid classification as amajor modification under 40 CFR 52.21

PERFORMANCE TESTING hdr

Initial Performance Test: due 180 days after Initial Startup but not to exceed 60days after achieving the maximum production rate at which Boiler No. 4 will beoperated to measure SO2 emissions in accordance with the procedures in 40 CFR60.45b(d). The initial performance test shall be conducted over 24 consecutivesteam generating unit operating hours at full load. The SO2 emission rate shall bebased on a daily average determined by the fuel sampling and analysis proceduresunder Method 19.

40 CFR Sections 60.8(a); 40 CFR 60.45b(d); Minn. R.7011.0565; Minn. R. 7017.2020, subp. 1

Initial Performance Test: due 180 days after Initial Startup but not to exceed 60days after achieving the maximum production rate at which Boiler No. 4 will beoperated to measure NOx emissions in accordance with the procedures in 40 CFR60.46b(e) and 60.48b. NOx emissions are monitored for 30 successive steamgenerating unit operating days and the 30-day average emission rate isdetermined. The 30-day average emission rate is calculated as the average of allhourly emissions data recorded by the monitoring system during the 30-day testperiod.

40 CFR Sections 60.8(a); 40 CFR 60.46b(e); Minn. R.7011.0565; Minn. R. 7017.2020, subp. 1

Initial Performance Test: due 180 days after Initial Startup but not to exceed 60days after achieving the maximum production rate at which Boiler No. 4 will beoperated to measure PM emissions in accordance with the procedures in 40 CFR60.46. Test to be conducted while combusting fuel oil.

40 CFR Sections 60.8(a); 40 CFR 60.46; Minn. R.7011.0555; Minn. R. 7017.2020, subp. 1

Initial Performance Test: due 180 days after Initial Startup but not to exceed 60days after achieving the maximum production rate at which Boiler No. 4 will beoperated to measure Opacity emissions. Test to be conducted while combustingfuel oil.

40 CFR Sections 60.8(a); 40 CFR 60.46b(d); Minn. R.7011.0565; Minn. R. 7017.2020, subp. 1

Performance Test Pre-test Meeting: due 7 days before Initial Performance Test forSO2, NOx, PM and Opacity. (7 days before each Initial Performance Test)

Minn. R. 7017.2030, subp. 4

MONITORING hdr

Fuel Oil Analysis: Sample the fuel oil daily at the boiler inlet in an as-fired conditionand analyze for sulfur content (percent by weight) and heat content (gross calorificvalue) as described in Part 5.2.2 of Method 19 in Appendix A of 40 CFR pt. 60.

Title I Condition: Monitoring to avoid classification as amajor modification under 40 CFR 52.21; meetsrequriements of 40 CFR Section 60.47b(b)(1); Minn. R.7011.0565

Install: due 180 days after Initial Startup continuous monitoring systems to measureopacity and nitrogen oxides emissions.

40 CFR Sections 60.48b(a) and (b), Minn. R.7017.1000, subp. 1

CEM Certification Test Pretest Meeting: due 7 days before CEM Certification Test Minn. R. 7017.2030, subp. 4; Minn. R. 7007.0800,subp. 2



12900014 - 006

Facility Name:

Permit Number:

A-19

COMS Certification Test Pretest Meeting: due 7 days before COMS CertificationTest

Minn. R. 7007.0800, subp. 2

CEM Certification Test: due 180 days after Initial Startup 40 CFR Section 60.13(b); Minn. R. 7007.0800, subp.2; 40 CFR Section 60.8(a)

COMS Certification Test: due 180 days after Initial Startup 40 CFR Section 60.13(b); Minn. R. 7007.0800, subp.2; 40 CFR Section 60.8(a)

CEMS Daily Calibration Drift (CD) Test: The CD shall be quantified and recorded atzero (low-level) and upscale (high-level) gas concentrations at least once daily.The CEMS shall be adjusted whenever the CD exceeds twice the specification of40 CFR pt. 60, Appendix B. 40 CFR pt. 60, Appendix F, shall be used to determineout-of-control periods.

40 CFR pt. 60, Appendix F, section 4; Minn. R.7007.0800, subp. 2; 40 CFR Section 60.13(d)

COMS Daily Calibration Drift (CD) Check: The CD shall be quantified and recordedat zero (low-level) and upscale (high-level) opacity at least once daily. The COMSmust be adjusted whenever the calibration drift (CD) exceeds twice thespecification of PS-1 of 40 CFR 60, Appendix B.

Minn. R. 7017.0800, subp. 2; 40 CFR Section 60.13(d)

COMS Calibration Error Audit: due before end of each calendar half-year starting03/14/2003 Conduct calibration error audits at least 3 months apart but no greaterthan 8 months apart.

Minn. R. 7007.0800, subp. 2

Cylinder Gas Audit: due before end of each calendar quarter starting 03/14/2003 ACGA is not due during any quarter in which a RATA was performed.

40 CFR pt. 60, Appendix F, 5.1.2.; Minn. R.7007.0800, subp. 2

CEMS Relative Accuracy Test Audit (RATA): due before end of each calendar yearstarting 03/14/2003

40 CFR pt. 60, Appendix F, 5.1.1.; Minn. R.7007.0800, subp. 2

RECORDKEEPING hdr

Fuel Usage Recordkeeping: Once each day, record the amount of each type of fuelused in EU 028 during the previous day. At the end of each calendar month,calculate and record fuel usage for each type of fuel for the previous month and theprevious 12-month period. At the end of each calendar month, calculate andrecord the annual capacity factor for each fuel type based on a 12-month rollingaverage.

Title I Condition: Recordkeeping to avoid classificationas a major modification under 40 CFR Section 52.21;meets requirements of 40 CFR Section 60.49b(d);Minn. R. 7007.0800, subp. 5

Sulfur Dioxide Emissions Calculation: once each day that fuel oil is combusted,calculate and record the daily average sulfur dioxide emission rate in pounds permillion Btu heat input, based on the results of the Method 19 fuel oil analyses.

Title I Condition: Recordkeeping to avoid classificationas a major modification under 40 CFR Section 52.21;meets requirements of 40 CFR Section 60.45b(d)(2);Minn. R. 7011.0565

Recordkeeping - Periods of Malfunction and Maintenance: Record the time anddate and each start and finish time for all shutdowns of EU 028 due to malfunctionor maintenance.


COMS Monitoring Data: Owners or operators of all COMS shall reduce all data to6 minute averages. Opacity averages shall be calculated from all equally spacedconsecutive 10-second (or shorter) data points in the 6 minute averaging period.

Minn. R. 7007.0800, subp. 2; 40 CFR Section60.13(e)(1)

CEMS/COMS Records: Keep records of all CEMS/COMS data onsite available forinspection for a period of five years following the record.

40 CFR Sections 60.49b(f)&(g); Minn. R. 7007.0800,subp. 5; 40 CFR Section 60.7(f); Minn. R. 7019.2000,subp. 2

CEMS/COMS Continuous Operation: Monitoring systems must be operated anddata recorded during all periods of emission unit operation including periods ofemission unit startup, shutdown, and malfunction. This requirement to operate themonitor applies whether or not a numerical emission limit applies during theseperiods. Monitoring systems must not be bypassed except in emergencies wherefailure to bypass the system would endanger human health, safety, or plantequipment.

Minn. R. 7007.0800, subp. 2

REPORTING hdr



12900014 - 006

Facility Name:

Permit Number:

A-20

Subject Item: EU 029 WWTP Flare


What to do Why to do itOpacity: less than or equal to 20 percent opacity Minn. R. 7011.0110



12900014 - 006

Facility Name:

Permit Number:

A-21

Subject Item: EU 032 Hammermill


SV 035 Hammermill


The Permittee shall operate and maintain the control equipment such that itachieves an overall collection efficiency for Total Particulate Matter: greater than 80percent collection efficiency

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

Opacity: less than or equal to 10 percent opacity (subp. 3(D)) - <discharged fromSV035>

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

The Permittee shall operate and maintain the control equipment such that itachieves an overall control efficiency for PM < 10 micron: greater than 60 percentcontrol efficiency

Minn. R. 7011.0070, subp. 1

OPERATING REQUIREMENTS hdr

The control equipment is considered listed control equipment under Minn. R.7011.0060 to 7011.0080. The Permittee shall operate and maintain the associatedcentrifugal collector (CE029) at all times that the hammermill is operating. ThePermittee shall document periods of non-operation of the control equipment.

Minn. R. 7011.0065, subp. 2(A), Minn. R. 7007.0800,subp. 2



12900014 - 006

Facility Name:

Permit Number:

A-22

Subject Item: CE 010 Centrifugal Collector - Medium Efficiency

Associated Items: EU 006 Pellet Cooler Dust Control System

What to do Why to do itOPERATING REQUIREMENTS hdr


Minn. R. 7007.0800, subp. 2

The Permittee shall operate and maintain each piece of control equipmentaccording to the manufacturer's specification.The permitee shall conduct inspections according to the manufacturer'sspecifications and maintain documentation of those actions.

Minn. R. 7007.0800, subp. 14

Monitoring Equipment: The Permittee shall install and maintain pressure dropgauges for measuring and recording the presure drop as required by this permit.The monitoring equipment must be installed, in use, and properly maintained whenoperation of the monitored control equipment is required.

Minn. R. 7007.0800, subp. 4

Corrective Actions: The Permittee shall take corrective action as soon as possible ifany of the following occur:- the recorded pressure drop is outside the required operating range; or- any of the associated centrifugal collectors or any of its components are foundduring the inspections to need repair.Corrective actions shall return the pressure drop to within the permitted range,eliminate excesive visible emissions, and/or include completion of necessaryrepairs identified during the inspection, as applicable. Corrective actions include,but are not limited to, those outlined in the O & M Plan for the associatedcentrifugal collectors. The Permittee shall keep a record of the type and date of anycorrective action taken for each associated centrifugal collector.

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

RECORDKEEPING AND MONITORING REQUIREMENTS hdr

Monitoring of Pollution Control Equipment: Once each operating day measure andrecord the pressure drop in inches of water column across the cyclone. ThePermittee shall record the time and date of each pressure drop reading andwhether or not the recorded pressure drop was within the range specified in thispermit.

Minn. R. 7007.0800, subps. 4 and 5

Corrective Actions: If the monitored parameter is out of the manufacturer'srecommended range, perform the necessary corrective action(s) as stated in thefacility O&M plan. Record all corrective actions immediately after the action iscompleted.


TABLE B: SUBMITTALSFacility Name: Southern Minnesota Beet Sugar Coop

Permit Number: 12900014 - 006

09/29/09B-1

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

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

Mr. George Czerniak Air and Radiation Branch EPA Region V 77 West Jackson Boulevard Chicago, Illinois 60604

Each submittal must be postmarked or received by the date specified in the applicable Table. Those submittals required by parts7007.0100 to 7007.1850 must be certified by a responsible official, defined in Minn. R. 7007.0100, subp. 21. Other submittals shallbe certified as appropriate if certification is required by an applicable rule or permit condition.

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

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

Send any application for a permit or permit amendment to:

AQ Permit Technical Advisor Industrial Division Minnesota Pollution Control Agency 520 Lafayette Road North St. Paul, Minnesota 55155-4194

Also, where required by an applicable rule or permit condition, send to the Permit Technical Advisor notices of:- accumulated insignificant activities,- installation of control equipment,- replacement of an emissions unit, and- 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 55155-4194

TABLE B: ONE TIME SUBMITTALS OR NOTIFICATIONSFacility Name: Southern Minnesota Beet Sugar Coop


09/29/09B-2

What to send When to send Portion of Facility AffectedApplication for Permit Reissuance due 180 days before expiration of Existing

PermitTotal Facility

CEM Certification Test Notification due 30 days before CEM Certification Test EU028

CEM Certification Test Plan due 30 days before CEM Certification Test EU028

CEM Certification Test Report - MicroficheCopy

due 105 days after CEM Certification Test EU028

CEM Certification Test Report due 45 days after CEM Certification Test . EU028

COMS Certification Test Notification due 30 days before COMS Certification Test EU028

COMS Certification Test Plan due 30 days before COMS Certification Test EU028

COMS Certification Test Report - MicroficheCopy

due 105 days after COMS Certification Test EU028

COMS Certification Test Report due 45 days after COMS Certification Test EU028

Notification of the Actual Date of Initial Startup due 15 days after Initial Startup. Thisnotification shall include the items listed at 40CFR Section 60.49b(a).

EU028

Notification of the Date Construction Began due 30 days after Start Of Construction EU028

Notification of the date of EquipmentRemoval/Dismantlement

due 30 days after Equipment Removal and/orDismantlement for EU 002, EU 003, EU 004,and EU 005. A seperate notification shall besubmitted for each emission unit. Submit thenotifications to theCompliance TrackingCoordinator

Total Facility

Performance Test Notification (written) due 30 days before Initial Performance Testfor SO2, NOx, PM and Opacity. (30 daysbefore each Initial Performance Test)

EU028

Performance Test Plan due 30 days before Initial Performance Testfor SO2, NOx, PM and Opacity. (30 daysbefore each Initial Performance Test)

EU028

Performance Test Report - Microfiche Copy due 105 days after Initial Performance Testfor SO2, NOx, PM and Opacity. (105 daysafter each Initial Performance Test)

EU028

Performance Test Report due 45 days after Initial Performance Test forSO2, NOx, PM and Opacity. (45 days aftereach Initial Performance Test)

EU028

Relative Accuracy Test Audit (RATA)Notification

due 30 days before CEMS Relative AccuracyTest Audit (RATA)

EU001, EU028

TABLE B: RECURRENT SUBMITTALSFacility Name: Southern Minnesota Beet Sugar Coop


09/29/09B-3

What to send When to send Portion of Facility AffectedExcess Emissions/Downtime Reports (EER's) due 30 days after end of each calendar

quarter starting 03/14/2003 (SubmitDeviations Reporting Form DRF-1 asamended). The EER shall indicate anyperiods of monitor bypass and all periods ofexceedances of the opacity or nitrogen oxideslimits including exceedances allowed by anapplicable standard, i.e. during startup,shutdown, and malfunctions.

EU028

Excess Emissions/Downtime Reports (EER's) due 30 days after end of each calendarquarter starting 04/01/1998 (SubmitDeviations Reporting Form DRF-1 asamended). The EER shall indicate all periodsof monitor bypass and all periods ofexceedances of the opacity, sulfur dioxide ornitrogen oxides limits including exceedancesallowed by an applicable standard, i.e. duringstartup, shutdown, and malfunctions.

EU001

Relative Accuracy Test Audit (RATA) ResultsSummary

due 30 days after end of each calendarquarter following CEMS Relative AccuracyTest Audit (RATA) in which the CEMS RATAwas conducted.

EU001, EU028

COMS Calibration Error Audit ResultsSummary

due 30 days after end of each calendarhalf-year following COMS Calibration ErrorAudit Results Summary COMS CalibrationError Audit Results Summary: due 30 daysafter end of each calendar half-year followingCOMS Calibration Error Audit.

EU001, EU028

Cylinder Gas Audit (CGA) Results Summary due 30 days after end of each calendarhalf-year following Cylinder Gas Audit

EU001, EU028

Semiannual Deviations Report due 30 days after end of each calendarhalf-year starting 04/01/1998 . The first reportof each calendar year covers January 1 - June30. The second report of each calendar yearcovers July 1 - December 31.

Total Facility

Compliance Certification due 30 days after end of each calendar yearstarting 04/01/1998 (for the previous calendaryear). The report covers all deviationsexperienced during the calendar year. To besubmitted on a form approved by theCommissioner to the Commissioner and tothe U.S. EPA regional office in Chicago. Thisreport covers all deviations experiencedduring the calendar year. The EPA copy shallbe sent to: Mr. George Czerniak, Chief, AirEnforcement and Compliance AssuranceBranch, Air and Radiation Division, EPARegion V, 77 West Jackson Boulevard,Chicago, Illinois 60604>

Total Facility

APPENDIX MATERIAL Facility Name: Southern Minnesota Beet Sugar Coop Permit Number: 12900014-006 NONE --------------------------------------------------------------------------------------------------- APPENDIX MATERIAL Facility Name: Southern Minnesota Beet Sugar Coop Permit Number: 12900014-005 NONE ---------------------------------------------------------------------------------------------------------------------

APPENDIX MATERIAL Facility Name: Southern Minnesota Beet Sugar Coop Permit Number: 12900014-004

Quality Assurance/Quality Control Plan Continuous Emission and Opacity Monitoring Southern Minnesota Beet Sugar Cooperative Renville, Minnesota Draft Permit No. 12900014-008 February 1998

ii

Southern Minnesota Beet Sugar Cooperative Continuous Emission and Opacity Monitoring

Quality Assurance/Quality Control Plan Draft Permit No. 12900014-008

Table of Contents

I. Introduction ...........................................................................................................................1 A. Facility ................................................................................................................................1 B. Continuous Monitoring System ..........................................................................................1 C. Emission Limits ...................................................................................................................2

II. CEMS and COMS Calculations and Reporting ...............................................................3 A. Data Calculations ................................................................................................................3 B. Excess Emissions and Downtime Reports ..........................................................................4 C. Record Keeping ...................................................................................................................5

III. Operating Procedures ........................................................................................................6 A. Response to Exceedance .....................................................................................................6 B. Response to Downtime ........................................................................................................7 C. Daily Calibration .................................................................................................................8 D. Periodic Audits ....................................................................................................................9 E. Maintenance ........................................................................................................................................... 10

Appendix

3

I. Introduction

A. Facility

The Southern Minnesota Beet Sugar Cooperative (SMBSC) facility in Renville, Minnesota,

processes sugar from sugar beets. The largest combustion source at the facility is Boiler No. 1.

The boiler is permitted to burn sub-bituminous coal, residual fuel oil and distillate fuel oil.

Emissions are controlled by a high-efficiency electrostatic precipitator. Boiler No. 1 is subject to

40 CFR Part 60 Subpart D—Standards of Performance for Fossil-Fuel-Fired Steam Generators

for Which Construction is Commenced after August 17, 1971. As required by the New Source

Performance Standard (NSPS), a continuous emission monitoring system (CEMS) and

continuous opacity monitoring system (COMS) are installed on the effluent gas stream. The

CEMS and COMS measure and record pollutant emissions and opacity for comparison with

emission limits contained in Draft Air Emission Permit No. 12900014-008.

B. Continuous Monitoring System

The continuous emission monitoring CEMS measures sulfur dioxide (SO2), nitric oxide (NO),

and oxygen (O2) levels in the boiler exhaust gas. SO2 and NO concentrations are measured

using a Model SM8160 process gas analyzer. The instrument utilizes an ultraviolet analytical

technique. A continuous relationship between NO and NO2 levels in the exhaust gas is assumed,

so that the NOx concentration can be calculated from the measured NO concentration. Oxygen

content is determined by a Model LS420 In-Situ Zirconia Oxygen Analyzer which utilizes a

zirconium oxide detector. The COMS measures percent opacity using a United Sciences, Inc.

(USI) Model 500C compliance opacity monitor.

The span value for both the SO2 are NOx analyzers is 750 ppm. The span value for the oxygen

analyzer is 25 percent. The opacity monitor span value is 80 percent.

The CEMS and COMS is operated by a Monitor Labs Model LS710 universal control unit. The

control unit monitors the CEMS and COMS system operation and calibration checks for all

4

analyzers. The CEMS and COMS information output is controlled by a Monitor Labs Model

DR9075 data acquisition and handling system.

C. Emission Limits

Pollutant Limit for Coal Limit for No. 6 Fuel Oil Opacity1 20 percent Sulfur Dioxide (SO2) 1.2 lb/MMBtu 0.8 lb/MMBtu Nitric Oxides (NOx) 0.7 lb/MMBtu 0.3 lb/MMBtu

1A maximum of 27 percent opacity is allowed for 6 minutes in any 60-minute period.

5

II. CEMS and COMS Calculations and Reporting

A. Data Calculations

Opacity data is reduced to 6-minute averages. Opacity averages are calculated from all equally

spaced consecutive 10-second (or shorter) data points in the 6-minute averaging period. The six-

minute averages are stored by the data acquisition system.

NOx and SO2 data is reduced to 1-hour averaging periods. Each one-hour average is calculated

from four 15-minute averages. Three hour averages are calculated from three contiguous one-

hour averages. Measured pollutant concentrations for SO2 and NOx are converted to the units of

the standard (lb/MMBtu) by the following equation:

E = [CwFw20.9] / [ 20.9(1-Bwa) - % O2w]

where:

E is the pollutant emission rate in lbs/MMBtu.

Cw is the pollutant concentration in PPM (SO2 or NOx).

Fw is the wet F factor. A value of 10,640 is used for sub-bituminous coal and a value of 10,320

is used for residual oil.

Bwa is the moisture fraction of ambient air.

%O2w is the percent oxygen on a wet basis.

Data recorded during periods of system breakdowns, repairs, calibration checks, and zero and

span adjustments is not used in the computed data averages.

B. Excess Emissions and Downtime Reports

Opacity excess emissions are defined as any 6-minute period during which the average opacity

of emissions exceeds 20 percent opacity, except that one 6-minute average per hour of up to

27 percent opacity need not be reported.

6

Excess emissions for sulfur dioxide and nitrogen oxides are defined as any 3-hour period during

which the average emissions (arithmetic average of three contiguous 1-hour periods) exceed the

applicable standards (SO2—1.2 and 0.8 lb/MMBtu; NOx—0.7 and 0.3 lb/MMBtu for coal and

residual oil respectively).

The following will be documented and reported for all CEM exceedances. This information will

be stored by the data acquisition system (DAS):

• Start time and date

• Level of exceedance

• Reason

• Corrective action

• Stop time and date

Downtime is any time when a CEMS or COMS is inoperative and not collecting data.

Downtime is classified as system breakdowns, maintenance and adjustments except for zero and

span checks.

CEMS and COMS downtime is tabulated by the DAS and it generates a report for submittal to

MPCA.

The following parameters are required to be documented and reported for all CEMS and COMS

downtime:

• Start time and date

• Reason

• Corrective action

• Stop time and date

7

Excess emissions and downtime reports (EERs) will be submitted within 30 days after the end of

each calendar quarter following permit issuance. The EER will indicate all periods of monitor

bypass and all periods of exceedance of the opacity, sulfur dioxide or nitrogen oxides limits,

including exceedances allowed by an applicable standard (i.e., during startup, shutdown, and

malfunctions).

C. Record Keeping

Copies of all reports required to be submitted to MPCA will be kept at the facility for a

minimum of five years. Also, copies of original CEMS and COMS data in electronic format and

records of calibration and maintenance performed on the CEMS and COMS will be kept at the

facility for five years.

8

III. Operating Procedures

A. Response to Exceedance

The following is a step-by-step procedure to be followed by the operators in response to any

exceedance of permitted emission levels for SO2 and NOx:

Step 1: Notify Shift Superintendent

Step 2: Notify Instrumentation

Step 3: Instrumentation will make any necessary repairs or the operators, along with the

Shift Superintendent, will make any necessary operational adjustments to bring

emissions into compliance (1.2 lb/MMBtu or less SO2; 0.7 lb/MMBtu or less NOx

when buring coal)

Step 4: If necessary, consult Babcock & Wilcox

Step 5: If necessary, contact Campbell-Sevey for maintenance issue

Step 6: Document the following information utilizing the DAS:

– Date and time exceedance started

– Level of exceedance

– Cause of exceedance

– Corrective action taken

– Date and time exceedance stopped

If an exceedance of the opacity standard occurs (greater than 20%), the operators will respond as

shown in the Opacity Exceedence Action Plan included as Attachment 1.

9

B. Response to Downtime

In the instance where a continuous monitor is down (opacity, SO2, NOx, oxygen), immediate

action will be required by the Control Room Operators. The following is a step-by-step

procedure to be followed by the operators:

Step 1: Notify Shift Superintendent

Step 2: Notify Instrumentation

Step 3: Instrumentation will make any necessary repairs.

Step 4: In unable to repair, contact Campbell-Sevey.

Step 5: Document the following information utilizing the DAS:

– Date and time downtime started

– Cause of downtime

– Corrective action taken

– Date and time downtime stopped

NOTE: Immediate Response is required

Minnesota Pollution Control Agency Notification

SMBSC is required to notify the Commissioner immediately of:

• A breakdown of more than one hour duration of the control equipment on the Emission Unit,

and

• A breakdown of the Emission Unit if the breakdown results in an increase in emissions.

• Commissioner will be notified when breakdown is over.

SMBSC is required to notify the Commissioner at least 24 hours in advance of:

• A shutdown of the control equipment.

10

• A shutdown of the Emission Unit if the shutdown would cause an increase in emissions.

• Commissioner will be notified when shutdown is over.

NOTE: In any shutdown or breakdown, the owner or operator shall immediately take all

practical steps to modify operations to reduce the emission of air contaminants.

C. Daily Calibration

All Continuous monitors are required to perform, at a minimum, a daily calibration. The

following are the calibration settings for the Opacity, SO2, NOx, and Oxygen Monitors at

SMBSC:

• Opacity Monitor calibrates once every 8 hours.

• Zero setting is 0 percent and upscale is 33 percent.

• Required to be within ±2 percent of the low and high settings.

• SO2 Monitor calibrates once every 24 hours.

• Zero setting is 0 ppm and upscale is 430 ppm.

• Required to be within ±37.5 ppm of the low and high settings by.

• NOx Monitor calibrates once every 24 hours.

• Zero setting is 0 ppm and upscale is 430 ppm.

• Required to be within ±37.5 ppm of the low and high settings.

• Oxygen Monitor calibrates once every 24 hours.

• Zero setting is 2.009 percent and upscale is 20.95 percent.

• Required to be within ±0.5 percent of the low and high setting.

The daily zero and span drift of the calibration will be determined and documented once daily by

the DAS. The Utilities Area Manager will review the calibration recorded by the DAS to

11

determine its accuracy. If the zero and span readings are not within the above-listed required

ranges, Instrumentation must be notified immediately. Instrumentation must, at a minimum,

perform an adjustment. If necessary, instrumentation will contact Campbell-Sevey for service.

NOTE: The zero setting on the Oxygen CEM Monitor is the concentration of gas on the gas

bottle. If a bottle is replaced, check the gas concentration and adjust the zero setting

accordingly.

D. Periodic Audits

Campbell-Sevey will perform two (2) EPA Cylinder Gas Audits (CGA) per year on the NOx,

SO2 and Oxygen CEMS. The draft permit requires that the CGA’s be performed once each

calender half-year, not less than three months or more than eight months apart. The CGA’s will

be performed in accordance with 40 CFR Part 60 Appendix F section 5.1.2.

NOTE: CGA results are due to MPCA within 30 days of the end of each calender half-year

following permit issuance.

COMS calibration error audits will be performed before the end of each half-year following

permit issuance following the procedure described in 40 CFR Part 60, Appendix B, Performance

Specification 1, section 7.1.4. Calibration error audits summaries are required to be submitted

within 30 days after the end of each calender half-year following permit issuance.

A CEMS Relative Accuracy Test Audit (RATA) will be performed before the end of each

calendar year following permit issuance. The MPCA will be notified at least 30 days prior to the

performance of each RATA. If the relative accuracy is 15 percent or less, the next CEMS RATA

is not due for 24 months. CEMS RATA results will be submitted within 30 days after the end of

each calendar quarter in which the CEMS RATA was conducted.

12

E. Maintenance

Currently, three (3) instrumentation personnel are on site to perform normal on-site maintenance

of all continuous monitors. The normal on-site maintenance consists of:

• Calibration Checks

• Zero and Span Adjustments

• Cleaning or Replacing

– Filters

– Lamps

– Fuses

– Gas Bottles (use only certified gas if available)

Instrumentation personnel are responsible for maintaining an on-site supply of parts for

immediate maintenance of breakdowns.

SMBSC has a Preventive Maintenance Agreement with Campbell-Sevey for three (3) yearly site

visits. These visits are scheduled for August, December, and March.

13

Manufacturers’ Suggested Spare Parts List

It shall be the responsibility of the Electrical & Control Systems Manager to maintain an

inventory of the manufacturer’s suggested spare parts list as per Tables 1 through 3.

Table 1. SM8160 SO2/NO Description Part Number Quantity Cartridge, Desiccant 16000053 1 Fuse, Thermal 53000093-2 2 Lamp Assembly, Ultraviolet 81000161-1 1 Printed Circuit Assembly, Serial Data Acquisition 81750012SP-1 1 Printed Circuit Assembly, Utility/Power Supply 8170015-2 1 Beam Splitter Assembly 81000160-2 1 Controller Assembly, Temperature 81000623-3 1 Dynode Chain Assembly 81000883-2 1 Printed Circuit Assembly, Transceiver 81750045-2 1 Scanner Assembly 81000164-4 2 Filter Assembly, Ceramic, 15 to 20 cm Cavity 81000935-1 1 Filter Assembly, Ceramic, 1.25 to 100 cm Cavity 28000262 1 Filter Assembly, Ceramic, 36 cm Cavity 80340018-1 1 Filter Assembly, Ceramic, 75 cm Cavity 81001130 1 Gasket, Ceramic Filter (except 36 and 75 cm 81000205 1 Cavity Gasket, Ceramic Filter, 75 cm Cavity 81001137 1 Gasket, Ceramic Filter, 36 cm Cavity 81001176 1 Gasket, Probe Mount 81750564 1 Ring, Grafoil (except 36 cm Cavity) 81000790-2 4 Seal, Grafoil (36 cm Cavity only) 81000790-3 1 Cloth, Polishing, Lint-Free (for transceiver lens) 25000393 1

14

Table 2. USI 500C Opacity Monitor Description Part Number Quantity Dessicator, Optical Head Assembly 997788 1 Lamp, Aperture Assembly1 601-0900-??2 1 Fuses 527354 1 Cal Wheel Belt Drive 528558 1 Power Cord 980112 1 Dessicator, Retroflector Assembly 997789 1 Catch 528554 1 Filter 820202 1 Blowers Motor 980111 1 Hose 980534 1 Hose Clamps 990744 1 Purge Switch Subassembly 1001-0700-01 1 1 Replacement requires complete recalibration of the system 2 Consult site specification sheets (Appendix J) for correct dash number aperture size for

specific monitor serial number.

15

Table 3. LS420 In-Situ Zirconia Oxygen Analyzer Description Part Number Quantity Cell Assembly 94200022 1 Filter Assembly 1 see permit file for the hard copy of the “Opacity Exceedance Action Flow Chart” which could not be stored electronically.

Technical Support Document, Permit Action Number: 12900014-006 Page 1 of 12 Date: 11/16/2009

TECHNICAL SUPPORT DOCUMENT For

AIR EMISSION PERMIT NO. 12900014-006 This technical support document (TSD) is intended for all parties interested in the permit and to meet the requirements that have been set forth by the federal and state regulations (40 CFR § 70.7(a)(5) and Minn. R. 7007.0850, subp. 1). The purpose of this document is to provide the legal and factual justification for each applicable requirement or policy decision considered in the determination to issue the permit.

1. General Information 1.1 Applicant and Stationary Source Location:

Table 1. Applicant and Source Address

Applicant/Address Stationary Source/Address (SIC Code: 2063)

Southern Minnesota Beet Sugar Cooperative P.O. Box 500 Renville Minnesota 56284

Southern Minnesota Beet Sugar Cooperative 83550 County Road 21 Renville Renville County Facility Contact: Mr. Clifford Mohs Environmental Compliance Director (320) 329-4105

1.2 Facility Description

Southern Minnesota Beet Sugar Cooperative (SMBSC) processes sugar from sugar beets for use in many consumer food products. The original facility was built in 1974. SMBSC has about 480 members and grows beets in an eleven county area around the plant. The cooperative employs roughly 250 year-round employees and 350 seasonal employees. The facility’s operation is split into time periods referred to as campaigns. Harvest can begin as early as August and usually ends in November. The beet slicing campaign will generally run from September to March, while the juice processing campaign will generally run through June, and the molasses campaign will run through August.


The major sources of air emissions at SMBSC can be divided into two categories: combustion sources and product handling sources. Combustion sources include three boilers and two lime kilns. The largest boiler is controlled by an electrostatic precipitator and the lime kilns are uncontrolled (although the combustion gas is usually bubbled through the carbonators). Product handling sources include sugar handling and conveying equipment along with other product/raw material handling equipment. The majority of the product handling sources are controlled by baghouses. Two units are controlled by scrubbers. The major source of fugitive emissions at the facility is truck traffic. 1.3 Description of the Activities Allowed by this Permit Action

This permit action is a minor permit amendment. This amendment authorizes SMBSC to modify its facility to enhance safety. Dust emissions associated with maintenance activity is SMBSC's primary concern in the beet pulp processing area of the plant. Therefore, SMBSC is proposing the following changes to minimize the occurrences of plugging and thereby reduce maintenance related dust emissions: - Install a hammermill, new emissions unit EU032, controlled by a centrifugal collection system

(CE029) as required by federally enforceable rules. The new hammermill will be placed into the process downstream of the existing pulp dryers and upstream of the pellet mills/coolers to help pulverize the dry beet pulp into a more uniform size.

- Modify the existing Pellet Cooler Dust Control System (EU 006) by: o Replacing the belt conveyance system with an enclosed auger system. o Replacing one of the four existing pellet mills with a new modern pellet mill. o Replacing the four existing pellet coolers with two new pellet coolers. Each of the new pellet

coolers will exhaust to its own cyclone (CE027 and CE028), and the exhaust will be routed to the existing cyclone (CE 010). By exhausting the new pellet coolers through new individual cyclones and through the existing common cyclone, actual particulate emissions will be further reduced before exiting the permitted stack.

o No changes will be made to the existing pulp system cyclone air blower, which controls the amount of air through the dust control system. Therefore, the modified Pellet Cooler Dust Control System (EU 006) will be limited by the capacity of the air blower at the existing cyclone (CE 010).

• Updates permit language to reflect changes in applicable rules and standard operating practices.. • Removes obsolete requirements.


1.4. Facility Emissions:

Table 2. Title I Emissions Increase Summary

Pollutant

Emissions Increase from

the Modification

(tpy)

Limited Emissions

Increase from the

Modification (tpy)

PSD/112(g) Significant Thresholds for major sources

(tpy)

NSR/ 112(g) Review Require

d? (Yes/No)

PM 10.5 10.5 25 NO PM10 6 6 15 NO

PM2.5 4.6 4.6 10 NO

NOx N/A 40 SO2 N/A N/A 40 CO N/A N/A 100 Ozone (VOC) N/A N/A 40 Lead N/A N/A 0.6 Individual and total HAPs, add as needed

N/A N/A 10/25 NO

.

Table 3. Non-Title I Emissions Increase Summary

.

Pollutant

After Change (lb/hr)

Before Change (lb/hr)

Net Change (lb/hr)

Insignificant

Modification

Thresholds (lb/hr <)

Minor and Moderate

Amendment

Thresholds (lb/hr < or

>)

Type of Amendment (Minor or Moderate)

PM10 6.82 5.54 1.28 0.855 3.42 Minor

NOx N/A N/A N/A 2.28 9.13

SO2 N/A N/A N/A 2.28 9.13

CO N/A N/A N/A 5.70 22.80

VOC N/A N/A N/A 2.28 9.13

Lead N/A N/A N/A 0.025 0.11


Table 4. Total Facility Potential to Emit Summary (*)

PM tpy

PM10 tpy

PM2.5 (**) tpy

SO2 tpy

NOx tpy

CO tpy

VOC tpy

SingleHAP tpy

All HAPs

tpy Total Facility Limited Potential Emissions (***)

3152 2783 2783 5559 1957 548 46 8.2 26.7

Total Facility Actual Emissions (2007)

294 453.4 Not reported

1148.9 929.3 63.3 6.35 HAPs not reported in emission inventory

(*) Potential Emissions for SO2, NOx , CO, VOC and HAPs are the same as the numbers documented in the Technical Support Document for permit action No. 12900014-004 (**) PM2.5 for existing facility is assumed to be equal to PM10 (***) These are the limited potential emissions based on operation of Boilers 1, 2, and 3 operation. Boiler 4 is reportedly not going to be installed to replace Boilers 1 and 2, these potential emissions will need to be verified upon reissuance of the permit.

Table 5. Facility Classification

Classification Major/Affected Source

Synthetic Minor Minor

PSD X Part 70 Permit Program X Part 63 NESHAP X

2. Regulatory and/or Statutory Basis

2.1 New Source Review

The facility is an existing major source under New Source Review regulations. No changes subject to NSR are authorized by this permit.

2.2 Part 70 Permit Program

The facility is a major source under the Part 70 permit program.


2.3 New Source Performance Standards (NSPS)

There are no NSPS applicable to the new hammermill and the modified pellet cooler control system authorized in this permit amendment.

2.4National Emission Standards for Hazardous Air Pollutants (NESHAP)

There are no HAPS emission increases from new hammermill and the modified pellet cooler control system authorized in this permit amendment. The Permittee has stated that no NESHAPs apply to the this equipment.

2.5 Compliance Assurance Monitoring (CAM)

CAM applies to the modification allowed in this permit amendment. The new hammermill is not a large pollutant specific emission unit (PSEU), but is subject to CAM requirements. The existing pellet cooler system unit to be modified is not a large PSEU but is currently subject to CAM. A CAM plan is not required for submittal with this permit application because this is for a minor permit amendment. A CAM plan needs to be submitted as part of the application for reissuance of the operating permit and this is being communicated in the cover letter for this permit.

2.6 Environmental Review & AERA

The proposed modification is not subject to environmental review, i.e. an Environmental Assessment Worksheet (EAW,) and an Air Emissions Risk Analysis (AERA is not required).

2.7 Minnesota State Rules

Standards of Performance for Dry Bulk Agricultural Facilities The new hammermill and the pellet cooler control system are subject to Minn. R. 7011.1000 to Minn. R. 7011.1015 Standards of Performance for Dry Bulk Agricultural Facilities. Previous permit actions show the pellet cooler control system (EU006) as subject to Minn. R. 7011.0715 Standards of Performance for Post-1969 Industrial Process Equipment. However, the hammermill and pellet cooler are part of the facility that processes the sugar beets and meets the definition of Dry Bulk Agricultural Commodity Facility at Minn. R. 7011.1000 subp. 5 because beet pulp or pellets are a commodity as defined in Minn. R. 7011.1000 subp. 4. The hammermill and pellet cooler are both subject to the control requirements in Minn. R. 7011.1015 because it has annual commodity throughput of more than 180,000 tons. The control requirements are listed in Minn. R. 7011.1005.


Since the hammermill and pellet cooler are subject to the Standards of Performance for Dry Bulk Agricultural Facilities, then Minn. R. 7011.0715 Standards of Performance for Post-1969 Industrial Process Equipment is no longer applicable.

Minn. R. 7011. 7011.0060 – 7011.0080 Listed Control Equipment and Control Equipment Efficiencies

The pellet cooler primary cyclones and the hammermill cyclone are subject to Minn. R. 7011. 7011.0060 – 7011.0080 in order to maintain emission increases of PM10 below significant thresholds under PSD without having to apply a Title I condition and therefore being subject to major amendment requirements. This is because the Standards of Performance for Dry Bulk Agricultural Facilities only define a specific pollution control efficiency for PM and the current permit does not specify either an emission limit nor a pollution control efficiency for PM10 that could be extended to the pellet cooler or any future equipment to be installed.

In the case of PM2.5, calculations show that uncontrolled levels of PM2.5 for the proposed modification are below significant thresholds under NSR, so no federally enforceable control efficiencies are needed for PM2.5.

The permitee disagrees with the conclusion that the pollution control rule applies to this modification in order to keep it as a minor amendment, but has agreed to comply with the pollution control rule for the purpose of expediting the permit processing. The permitee wishes to revisit this issue when the permit is reissued.

At the time of reissuance, the permit could include approval of Title I conditions with specific control efficiencies for the cyclones and any other pollution control device at the facility based on available technical information. In this manner, since the permit will be public noticed, it would result in federally enforceable permit conditions without having to be subject to the pollution control rule.

Table 6. Regulatory Overview of Units Affected by the Modification/Permit Amendment


Level* Applicable Regulations Comments: EU006 EU032

Minn. R. 7011.1005, subp. 3 Standards of Performance for Dry Bulk Agricultural Facilities. Determination of applicable limits from rule (see more details above under 2.7):

• has annual commodity throughput of more than 180,000 tons

• beet pulp or pellets are a commodity EU006 EU032 CE027 CE028 CE029

Minn. R. 7011. 7011.0060 – 7011.0080

Listed Control Equipment and Control Equipment Efficiencies. Determination of applicable limits from rule (see more details above under 2.7): • Limits for PM10 are needed to avoid a major

modification requirement. • CE027, CE028 and CE029 meet the minimum

requirements for medium efficiency cyclones when compared with the Centrifugal device parameters that are defined in “Drawing 1 and Table 1” in Minn. R. 7011.0070.

• Permittee has agreed to comply with Minn. R. 7011. 7011.0060 – 7011.0080

*Where the requirement appears in the permit (e.g., EU, SV, GP, etc.).

3. Technical Information A detailed description of approach to emission calculations for the emission increases due to the modifications is documented in the permit application. A summary is as follows: Pellet cooler dust control system - The existing pellet cooler dust control system is made up of several components (pellet mills,

pellet coolers, conveyance devices and related appurtenances) but it constitutes an individual emission unit: it is designed to provide for a single production activity; all emissions exhaust through a single stack, the inputs and outputs enter and exit on a single conveyor.

- The new components of the pellet cooler system result in a design capacity for the system of 33 ton/hour of dry beet pulp, which is larger than the existing system (31 tons/hr dry beet pulp). Therefore, the modified pellet cooler does not constitute a replacement unit.

- The facility-wide capacity of the pellet cooler is limited (bottlenecked) by the pulp dryers upstream of the new hammermill and modified pellet cooler, so its potential to emit will not increase. The bottlenecked capacity of the modified pellet cooler is 23 tons/hr of dry beet pulp, which is based on the capacity of the pulp dryers.

- The modified pellet cooler system will be functionally equivalent to the original and as such continues to be a single unit.


- The modifications to the pellet cooler result in a physical change that is not routine maintenance and repair and does not qualify for any other exclusion.

- The only emissions from the modification are particulate matter as no emissions are generated from energy supply to the systems.

- The pellet cooler system has a pollution control system consisting of primary cyclones (CE027 and CE028) and the existing cyclone (CE010) acting as a secondary cyclone.

- Emission factors (PM, PM10 filterable, and PM condensable) used for the pellet cooler system are from EPA’s WebFIRE emission database for pellet cooler with a high efficiency centrifugal collector for the feed manufacturing industry because lack of data for the sugar beet processing industry.

- The emission calculations are based on emission factors for a high efficiency cyclone which is justifiable because of the combined effect of the cyclones in series. The estimated combined efficiency will comply with federally enforceable control efficiency of 80% for PM. Use of pollution control rule for calculations of emissions of PM10 and estimated emission factors for PM2.5. The allowable emissions of PM2.5 are based on estimated uncontrolled emissions, since there is no federally enforceable limit for PM2.5 imposed by this permit.

- Emission factors for PM2.5 filterable were estimated from size distributions in EPA’s AP-42, Appendix B and expected control efficiencies for a cyclone collector.

- The hourly emission rates are based on operation at design rated capacity. - The emissions calculations for the modified pellet cooler were conducted using the actual-to-

projected-actual applicability test. - SMBSC used annual throughput projections from 2009 to 2014. - The pellet cooler is fully contained within a building and the amount of associated fugitive

emissions are not appreciable. - The permit requires the operation of the control equipment at all times when the pellet cooler

is in operation. Therefore, no excess emissions are expected as result of startups or shutdowns.

- No adjustment was made for throughput which the facility currently can accommodate. - The baseline actual emissions used were based on the 24-month period between 1/1/2007 and

12/31/2008 for all regulated PSD pollutants. Likewise, no adjustments were made for fugitives, or excess emissions due to shutdown and startups.

Hammermill - The new hammermill is a new functional unit and as such is considered a new emission unit,

so the baseline actual emissions are zero. - The only emissions from the modification are particulate matter as no emissions are

generated from energy supply to the systems. - The new hammermill has a design capacity of 29 ton/hour of dry beet pulp. - The facility-wide capacity of the hammermill is limited (bottlenecked) by the pulp dryers

upstream of the new hammermill and modified pellet cooler. The bottlenecked capacity of the hammermill is 23 tons/hr of dry beet pulp, which is based on the capacity of the pulp dryers.


- The hammermill has a cyclone (CE029). The emission calculations are based federally enforceable control efficiency of 80% for PM and operation at design rated capacity. Used pollution control rule for calculations of emissions of PM10 and estimated emission factors for PM2.5. The allowable emissions of PM2.5 are based on estimated uncontrolled emissions, since there is no federally enforceable limit for PM2.5 imposed by this permit.

- Emission factors (PM, PM10 filterable) used for the hammermill are from EPA’s WebFIRE emission database for a hammermill with a single centrifugal collector for the feed manufacturing industry because lack of data for the sugar beet processing industry.

- Emission factors for PM2.5 filterable were estimated from size distributions in EPA’s AP-42, Appendix B and expected control efficiencies for a cyclone collector.

- Emission factors for condensibles from the hammermill were estimated by scaling of emission factors for condensable particulate matter for the pellet cooler by the air flow ratio of the hammermill to the combined flow from the hammermill and pellet cooler.

- The emissions calculations for the hammermill were conducted using the actual-to-potential applicability test.

- The permit requires the operation of the control equipment at all times when the hammermill is in operation.

Emission Increase for the Modification - The “hybrid test was used to determine if a significant emission increase of a NSR pollutant has occurred. Calculations show that this modification does not show a significant emission increase in any PSD pollutant. - No recordkeeping and reporting is required for this modification as a result of the use of the

baseline actual-to-projected actual emission increase methodology because the increase is less than 50% of the significance levels for all pollutants.

- No major amendment requirement is trigger under Minn. R. 7007.1500, subp. 1 and the projected hourly emissions increase at maximum physical capacity is less than the minor modification threshold at Minn. R. 7007.1250, subp. 1.(b)(2)

Explanations of deviations from accepted Delta practice.

EU028 was never constructed and there are no plans for construction. In the cover letter, will request the applicant to submit a revised application for re-issuance with formal request to:

• Request that Boiler No. 2 (EU002) be listed in our records as RETIRED. • Request that the language regarding the removal or dismantling of Boiler No. 3 (EU003)

be removed. • Request that Boiler No. 4 (EU028) be removed from the permit. • Request that the permit conditions restricting fuel heat input be revised as appropriate to

reflect the fact that Boiler No. 4 will not be installed. • Provide updated electronic calculations for the entire facility which reflect the current

situation regarding Boilers No. 1, 2, 3 and 4.

A condition to obtain other media permits will be removed as it has been satisfied.


Other Pending Permit Actions

There is a Reopening permit action pending (dq# 2529) which will not be incorporated into this minor permit amendment because it requires to be processed via a major permit amendment.

An earlier version of the application for this modification was submitted and returned because it was incomplete (dq 2665).

3.1 Calculations of Emissions Increase Analysis

Attachment 1 to this TSD contains Form GI-07, which summarizes the PTE of the units permitted by this amendment. Attachment 2 contains detailed spreadsheets and supporting information prepared by the Permittee and supplemented by MPCA. This demonstrates that this modification is not a major modification for PSD.

3.2 Periodic Monitoring and CAM

In accordance with the Clean Air Act, it is the responsibility of the owner or operator of a facility to have sufficient knowledge of the facility to certify that the facility is in compliance with all applicable requirements.

For CAM, the Permittee will submitt a CAM proposal as required by 40 CFR § 64.3 as a supplement to the application for re-issuance.

In evaluating the monitoring included in the permit, the MPCA considers the following:

• The likelihood of violating the applicable requirements; • Whether add-on controls are necessary to meet the emission limits; • The variability of emissions over time; • The type of monitoring, process, maintenance, or control equipment data already

available for the emission unit; • The technical and economic feasibility of possible periodic monitoring methods; and • The kind of monitoring found on similar units elsewhere.

The table below summarizes the periodic monitoring requirements for the emission units covered by this amendment and for which the monitoring required by the applicable requirement is nonexistent or inadequate.


Table 7. Periodic Monitoring

Level* Requirement (rule basis)

Additional Monitoring

Discussion

Examples EU006 EU032 GP 003 CE010

Control efficiency => 80% Opacity < 10% 1.5=> Pressure Drop Limit =< 7

Recordkeeping: - Periods of non-operation of the control equipment - Daily records of measured pressure drop in inches of water column across each cyclone. The Permittee shall record the time and date of each pressure drop reading and whether or not the recorded pressure drop was within the range specified in this permit. - Record Inspections - Record all corrective actions immediately after the action is completed. Control Equipment O & M Inspections

The permit requires operation and maintenance of the associated centrifugal collectors CE010, CE027 and CE028 at all times that the pellet cooler dust control system is operating. The permit requires operation and maintenance of the associated centrifugal collectors CE029 at all times that the hammermill is operating. The permit requires installation, maintainance and operation of pressure drop gauges when operation of the monitored control equipment is required. The permit requires documentation of periods of non-operation of the control equipment. The permit requires that records be generated by exception when the pollution control equipment is not operational and when corrective actions are taken.

Monitoring for CE027, CE028 and CE029 are subject to the Minnesota Performance Standard for Control Equipment.

Monitoring for CE010 is based on the Minnesota Performance Standard for Control Equipment Monitoring which is adequate to have a reasonable assurance of compliance.


*Where the requirement appears in the permit (e.g., EU, SV, GP, etc.).

3.3 Insignificant Activities

There are no insignificant activities associated with this minor modification.

SMBSC has several operations which are classified as insignificant activities. These are listed in in GP001.

3.4 Permit Organization

In general, the permit meets the MPCA Delta Guidance for ordering and grouping of requirements. The permit carries over an Appendix from permit action No. 12900014-004.

3.5 Comments Received

This permit amendment is not required to be public notice pursuant to Minn. R. 7007.0850, subp. 2(D).

This permit action is for an amendment to a part 70 permit and therefore, pursuant to Minn. R. 7007.1450 subp. 7, the permit is subject to 45-day EPA review. EPA 45-day Review Period: 8/13/09 – 9/28/09

No comment were received from EPA.

4. Conclusion

Based on the information provided by SMBSC, the MPCA has reasonable assurance that the proposed operation of the emission facility, as described in the Air Emission Permit No. 12900014-006 and this TSD, will not cause or contribute to a violation of applicable federal regulations and Minnesota Rules.

Staff Members on Permit Team: Carolina Schutt (permit writer/engineer) Rachel Peters (enforcement) Mark Severin (stack testing) Toni Volkmeier (peer reviewer) Beckie Olson (administrative support) Laurie O’Brien (administrative support) Chris Buntjer (expedited permit coordinator)

AQ File No. 2478; DQ 2703, 2665(returned application) Attachments: 1. Form GI-07 (paper copy only) 2. Calculation Spreadsheets (copy in delta) 3. Facility Description and CD-01 Forms

air emission permit no. 12900014-006 is issued to southern

Documents