air emission permit no. 14900013-006 is issued to denco ii llc

SAM %2~4

AIR EMISSION PERMIT NO. 14900013- 006 Major Amendment

IS ISSUED TO

DENCO II L LC

DENCO II LLC 227 County Road 22

Morris, Stevens County, Minnesota 56267

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. 14900013-005 and authorizes the Permittee to operate and modify 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 as are enforceable by U.S. Environmental Protection Agency (EPA) Administrator or citizens under the Clean Air Act.

Permit Type: State; Limits to Avoid Pt 70/Limits to Avoid NSR;

Operating Permit Issue Date: June 29, 1998

Major Amendment Issue Date: September 15, 2015

Expiration Date: September 15, 2017 - Title I Conditions do not expire.

Do n4fmthj^ EVMa ribge r Air Quality Permits Section Industrial Division

for John Line Stine Commissioner Minnesota Pollution Control Agency

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

Permit Applications Table Permit Type Application Date Permit Action Total Facility Operating Permit 06/15/1996 001 Major Amendment 03/17/1999 002 Major Amendment 02/23/2000 003 Major Amendment 01/03/2003;10/03/2003 004 Administrative Amendment 08/31/2010 005 Major Amendment 05/14/2012 005 Administrative Amendment 03/31/2014 006 Major Amendment 06/16/2015 006

TABLE OF CONTENTS

Notice to the Permittee

Permit Shield

Facility Description

Amendment Descriptions

Table A: Limits and Other Requirements

Table B: Submittals

Table C: Compliance Schedule

Appendix I: Modeling Parameters

Appendix II: Stack Test Methods and Parameter Recordkeeping Requirements

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: The facility is a fuel-ethanol production plant located near Morris, Minnesota in Stevens County. The primary emissions are VOCs, PM/PMio/PM2.5, NOx, and CO. Volatile organic compounds (VOCs) are emitted by fermentation, distillation, DDGS drying, ethanol loading, and VOC liquid storage and piping. Particulate matter (PM/PM10/PM25) is emitted by corn receiving and handling, DDGS handling and drying, and vehicle traffic. Nitrogen oxides (NOx) and carbon monoxide (CO) are emitted by combustion sources. The plant is currently permitted to produce 30 million gallons of 200 proof ethanol annually.

The primary air pollution controls onsite are the Process Scrubber (CE020) and the Regenerative Thermal Oxidizer (RTO) (CE027). The scrubber controls emissions from the Fermentation and Distillation operation (SV018); the RTO controls emissions from the Dryer (EU066) and Yeast Propagation Tank (EU088). Baghouses control PM/PMI0/PM2.5 from the corn and DDGS handling and storage systems and the Truck/Rail Loadout area. There are internal floating roof tanks for ethanol. Emissions from process valves and piping are controlled through an inspection and maintenance program.

AMENDMENT DESCRIPTIONS:

AMENDMENT 002: Permit amendment 002 authorized the following changes to the ethanol plant design:

• Replacement of two boilers with one new boiler combusting natural gas and propane. • Replacement of five hammermills with one hammermill. • Replacement of all but two fermentation tanks with five new tanks replacement of two existing

DDGS dryers with one new dryer. • Addition of a flare to combust volatile organics from a bio-digester tank. • Removal of one DDGS loadout spout. • Replacement of two ethanol storage tanks and one gasoline storage tank with one tank to be

used to store denatured ethanol. • Replacement of pollution control devices.

The permitted plant capacity remains at 17 million gallons. The permit contains conditions limiting air emissions to less than 100 tons per year for each criteria pollutant. Therefore, the facility is considered a non-major source under 40 CFR § 70.2 (Part 70 permitting program) and 40 CFR § 52.21 (Prevention of Significant Deterioration).

AMENDMENT 003: Permit amendment 003 authorized the following: • The production limit for undenatured ethanol is increased from 17 million to 20 million gallons

per year. • The hammermill (EU 060) was not previously vented directly to the atmosphere. This

amendment allows the unit to be vented directly to the atmosphere and requires the installation of a fabric fil ter (CE 024) to control emissions. Emissions from the fabric filter are vented to a new stack vent (SV 021). A Particulate Matter (PM) and Particulate Matter less than 10 microns (PM10) emission limit of 0.60 Ib/hr for EU 060 is also added to the permit.

• The bio-digester gas from EU 067 is added as a fuel feed option for the DDGS Dryer (EU 066). • The cooling cyclone (EU 071) is added as an emission unit. This unit is an existing unit which

was previously not vented directly to the atmosphere. A new stack (SV 022) will be added for the unit and an emission limit for PM and PMi0 of 2.0 Ib/hr is also added.

• For SV 005, the PM and PM10 emission limit is increased from 1.22 to 1.50 Ib/hr. • For SV 016, the PM and PMi0 emission limit is increased from 0.50 to 0.60 Ib/hr.

• For SV 018, the VOC emission limit is increased from 4.80 to 5.70 Ib/hr. • For SV 019, the PM and PM10 emission limit is increased from 9.30 to 11.00 Ib/hr and the VOC

emission limit is increased from 7.28 to 8.60 Ib/hr. • Testing frequencies for SV 018 and SV 019 have been established based on the margin of

compliance recorded during performance testing. • The pressure drop range and minimum water flow rate for the scrubber were changed based on

performance test results. The minimum pressure drop was changed from 4.0 to 3.0 inches of water column and the minimum water flow rate for the scrubber was changed from 15 to 25 gallons/minute.

AMENDMENT 004: The changes authorized in permit action 004 include: Installation of the following new equipment:

• 250,000 gallon denatured ethanol tank, TK012 • 39,000 gallon denaturant tank, TK013 • 6 dry product storage bins, EU077 - 082 • Hammermill, EU084 • Baghouse dust collector for the dry product storage bins • Baghouse dust collector for the hammermill

Other Changes: • Increase in allowed ethanol production to 30 million gallons per year. • Reduction in amount of propane backup fuel usage. • Thermal oxidizer for control of VOC emissions from the DDGS dryer, CE027. • Ethanol loadout flare for control of VOC emissions, CE025. • Leak detection and repair requirements of 40 CFR pt. 60 Subpart VV, FS005. • Monitoring of beer and syrup feed rates to dryer. • Fuel usage monitoring. • VOC limit on fermentation scrubber, SV018. • VOC limit on cooling cyclone exhaust, SV022. • 95 tons per year source-wide limits on PM, PMi0, S02, NOx, CO, and VOC. • 9 ton per year source-wide limit on each individual HAP emitted. • 24 ton per year source-wide limit on sum of all HAPs. • Fugitive dust control requirements.

AMENDMENT 005: Changes authorized in permit action 005 include:

• Added two grain storage bins, 414,000 bushels each (EU086, EU087). • Increased RTO PM emission limits from 4.11 to 7.11 Ib/hr to account for condensable PM. • Insignificant modification - flat storage. • Insignificant modification - changed TK005 from storage of denaturant to E-85. • Removed Golden Lyk units from permit (GP012). • Added 500,000 gallon tank to store denatured ethanol (TK014). • Added hours-of-operation limit for grain receiving (7 am to 5 pm).

Other changes:

• Updated Total Facility Requirements (FC). • Removed references to Consent Decree which has been terminated.

• GP001 liquid storage tanks - a tank of less than 20,000 gallon capacity is not subject to Subpart Kb; tanks smaller than 20,000 gallons have been moved to GP002; Subpart Kb floating roof requirements added for larger tanks in GP001.

• GP002 added to permit for liquid storage tanks smaller than 20,000 gallons. • SV005, SV016, EU060, EU071, EU084 - deleted limit based on Minn. R. 7011.0735 which does

not apply. • Updated performance test frequency for SV018, EU071. • EU071, deleted test frequency plan which has been submitted. • EU072, existing fermenter added to SV018. • Updated requirements for fabric filters. • Tanks 008, 009, and 010 removed as reported to Emission Inventory System. • FS001, previously Unpaved Roads, now includes paved roads requirements. • One-time notifications which have been submitted have been removed (TK012, TK013).

AMENDMENT 006: This permit action is for a Major Amendment. Construction and operation of emission units 088, 089, 090, and 091 has been authorized in this permit action. The major amendment proposes to add a pre scrubber ethanol recovery device (CE029) in series on the upstream side of the existing scrubber (CE020) to condense and remove ethanol vapors before they enter CE020. The device will use water to condense and collect ethanol vapors resulting in a decrease of water discharged during the ethanol process.

DENCO II also proposes to replace the existing Stripper (EU051) with a new Beer Column (EU089), the existing yeast propagation tanks (EU016 and EU017) with a new yeast propagation tank (EU088), and the existing Rectifier (EU068) with a new Rectifier (EU090). An additional Fermentation tank to slow down the fermentation will also be added as EU 091. EU088 emissions will be now rerouted to the Regenerative Thermal Oxidizer (CE027), except for during periods of CE027 downtime in which EU088 will be controlled by CE020 and CE029. All other emission units will continue to be controlled by the existing scrubber (CE020) in addition to the new pre scrubber (CE029). The equipment replacements, yeast propagation control bypass, and additional fermenter will result in no increase of emissions.

Also included in this permit action is a rolled in Administrative Amendment (DQ# 4738) originally submitted 03/14/2014. This amendment was for a 120 day stack test extension that has since been passed and completed.

TABLE A: LIMITS AND OTHER REQUIREMENTS Facility Name: DENCO II LLC

Permit Number: 14900013 - 006

A-1 09/14/15

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

Subject Item: Total Facility

What to do Why to do it SOURCE-SPECIFIC REQUIREMENTS hdr

The Permittee is authorized to install and operate EUs 088, 089, 090, and 091 within 18 months after permit issuance of Permit No. 14900013-006. The units shall meet all the requirements of this permit.

Minn. R. 7007.0800, subp. 2

Permit Appendix: This permit contains an appendix as listed in the permit Table of Contents. The modeling parameters in Appendix I are included for reference only as described elsewhere in Table A.

Minn. R. 7007.0800, subp. 2

Production: less than or equal to 30 million gallons/year using 12-month Rolling Sum of undenatured ethanol to be calculated by the 15th day of each month for the previous 12-month period as described later in this permit.

Title I Condition: Avoid major source under 40 CFR 52.21 (b)(1)(i) and Minn. R. 7007.3000; To avoid major source under 40 CFR 70.2 & Minn. R. 7007.0200; To avoid major source under 40 CFR 63.2

Process Throughput: less than or equal to 322,000 tons/year using 12-month Rolling Sum of corn to be calculated by the 15th day of each month for the previous 12-month period as described later in this permit. This is based on a 56-pound bushel which is equivalent to 11.5 million bushels per year.

Title I Condition: Avoid major source under 40 CFR 52.21 (b)(1 )(i) and Minn. R. 7007.3000; To avoid major source under 40 CFR 70.2 & Minn. R. 7007.0200

Daily Ethanol Production Recordkeeping: On each day of operation, the Permittee shall calculate, record, and maintain records of the undenatured ethanol production for the previous calendar day.

Title I Condition: Avoid major source under 40 CFR 52.21 (b)(1 )(i) and Minn. R. 7007.3000; To avoid major source under 40 CFR 70.2 & Minn. R. 7007.0200; Minn. R. 7007.0800, subps. 4-5

Monthly Ethanol Production Recordkeeping: By the 15th of the month, the Permittee shall calculate and record the following:

1) The monthly gallons of undenatured ethanol produced during the previous month based on summing the daily undenatured ethanol production record for that month, and

2) The 12-month rolling sum undenatured ethanol production for the previous 12-month period by summing the monthly undenatured ethanol production data for the previous 12 months.

Minn. R. 7007.0800, subps. 4-5

Daily Grain Throughput Recordkeeping: On each day of operation, the Permittee shall calculate, record, and maintain records of the daily grain accepted by the facility for the previous calendar day. This shall be based on grain receipts.

Title I Condition: Avoid major source under 40 CFR 52.21 (b)(1 )(i) and Minn. R. 7007.3000; To avoid major source under 40 CFR 70.2 & Minn. R. 7007.0200; Minn. R. 7007.0800, subps. 4-5

Monthly Grain Throughput Recordkeeping: By the 15th of the month, the Permittee shall calculate and record the following:

1) The monthly tons of grain throughput during the previous month based on summing the daily grain throughput record for that month, and

2) The 12-month rolling sum grain throughput for the previous 12-month period by summing the monthly grain throughput data for the previous 12 months.

Minn. R. 7007.0800, subps. 4-5

Grain received by the facility shall only be used for production of ethanol and coproducts by the Permittee at the DENCO II LLC facility (ID No. 14900013).

Title I Condition: Avoid major source under 40 CFR 52.21 (b)(1)(i) and Minn. R. 7007.3000; To avoid major source under 40 CFR 70.2 & Minn. R. 7007.0200

The Permittee shall clean up commodities spilled on the driveway and other facility property as required to minimize fugitive emissions to a level consistent with RACT (reasonably available control technology).

Minn. R. 7011.1005, subp. 1 (A)-(B)

OPERATIONAL REQUIREMENTS hdr

The Permittee shall comply with National Primary and Secondary Ambient Air Quality Standards, 40 CFR pt. 50, and the Minnesota Ambient Air Quality Standards, Minn. R. 7009.0010 to 7009.0080. Compliance shall be demonstrated upon written request by the MPCA.

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

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

Minn. R. 7011.0020



A-2 09/14/15

Air Pollution Control Equipment: Operate all pollution control equipment whenever the corresponding process equipment and emission units are operated.

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

Operation and Maintenance Plan: Retain at the stationary source an operation and maintenance plan for all air pollution control equipment. At a minimum, the O & M plan shall identify all air pollution control equipment and control practices and shall include a preventative maintenance program for the equipment and practices, a description of (the minimum but not necessarily the only) corrective actions to be taken to restore the equipment and practices to proper operation to meet applicable permit conditions, a description of the employee training program for proper operation and maintenance of the control equipment and practices, and the records kept to demonstrate plan implementation.

Minn. R. 7007.0800, subps. 14 and 16(J)

Operation Changes: In any shutdown, breakdown, or deviation the Permittee shall immediately take all practical steps to modify operations to reduce the emission of any regulated air pollutant. The Commissioner may require feasible and practical modifications in the operation to reduce emissions of air pollutants. No emissions units that have an unreasonable shutdown or breakdown frequency of process or control equipment shall be permitted to operate.

Minn. R. 7019.1000, subp. 4

Fugitive Emissions: Do not cause or permit the handling, use, transporting, or storage of any material in a manner which may allow avoidable amounts of particulate matter to become airborne. Comply with all other requirements listed in Minn. R. 7011.0150.

Minn. R. 7011.0150

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 enforceable by the EPA Administrator or citizens under the Clean Air Act.

Minn. R. 7030.0010 - 7030.0080

Inspections: The Permittee shall comply with the inspection procedures and requirements as found in Minn. R. 7007.0800, subp. 9(A).

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

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

Minn. R. 7007.0800, subp. 16

PERFORMANCE TESTING hdr

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

Performance Test Notifications and Submittals:

Performance Tests are due as outlined in Table A of the permit. See Table B for additional testing requirements.

Minn. R. 7017.2018; Minn. R. 7017.2030, subps. 1-4, Minn. R. 7017.2035, subps. 1-2

Performance Test Notification (written): due 30 days before each Performance Tesl Performance Test Plan: due 30 days before each Performance Test Performance Test Pre-test Meeting: due 7 days before each Performance Test Performance Test Report: due 45 days after each Performance Test Performance Test Report - Microfiche Copy: due 105 days after each Performance Test

The Notification, Test Plan, and Test Report may be submitted in an alternative format as allowed by Minn. R. 7017.2018. Limits set as a result of a performance test (conducted before or after permit issuance) apply until superseded as stated in the MPCA's Notice of Compliance letter granting preliminary approval. Preliminary approval is based on formal review of a subsequent performance test on the same unit as specified by Minn. R. 7017.2025, subp. 3. The limit is final upon issuance of a permit amendment incorporating the change.

Minn. R. 7017.2025, subp. 3

MONITORING REQUIREMENTS hdr

Monitoring Equipment Calibration - The Permittee shall either: Minn. R. 7007.0800, subp. 4(D)

1. Calibrate or replace required monitoring equipment every 12 months; or 2. Calibrate at the frequency stated in the manufacturer's specifications.

For each monitor, the Permittee shall maintain a record of all calibrations, including the date conducted, and any corrective action that resulted. The Permittee shall include the calibration frequencies, procedures, and manufacturer's specifications (if applicable) in the Operations and Maintenance Plan. Any requirements applying to continuous emission monitors are listed separately in this permit.

TABLE A: LIMITS AND OTHER REQUIREMENTS A-3 09/14/15 Facility Name: DENCO II LLC

Permit Number: 14900013-006

Operation of Monitoring Equipment: Unless otherwise noted in Tables A, B, and/or C, monitoring a process or control equipment connected to that process is not necessary during periods when the process is shutdown, or during checks of the monitoring systems, such as calibration checks and zero and span adjustments. If monitoring records are required, they should reflect any such periods of process shutdown or checks of the monitoring system.

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

RECORDKEEPING hdr

Recordkeeping: Retain all records at the stationary source, unless otherwise specified within this permit, for a period of five (5) years from the date of monitoring, sample, measurement, or report. Records which must be retained at this location include all calibration and maintenance records, all original recordings for continuous monitoring instrumentation, and copies of all reports required by the permit. Records must conform to the requirements listed in Minn. R. 7007.0800, subp. 5(A).

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

Recordkeeping: Maintain records describing any insignificant modifications (as required 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 emissions resulting from those changes.

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

If the Permittee determines that no permit amendment or notification is required prior to making a change, the Permittee must retain records of all calculations required under Minn. R. 7007.1200. For expiring permits, these records shall be kept for a period of five years from the date the change was made or until permit reissuance, whichever is longer. The records shall be kept at the stationary source for the current calendar year of operation and may be kept at the stationary source or office of the stationary source for all other years. The records may be maintained in either electronic or paper format.

Minn. R. 7007.1200, subp. 4

REPORTING/SUBMITTALS hdr

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

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

Minn. R. 7019.1000, subp. 3

Breakdown Notifications: Notify the Commissioner within 24 hours of a breakdown of more than one hour duration of any control equipment or process equipment if the breakdown causes any increase in the emissions of any regulated air pollutant. The 24-hour time period starts when the breakdown was discovered or reasonably should have been discovered by the owner or operator. However, notification is not required in the circumstances outlined in Items A, B and C of Minn. R. 7019.1000, subp. 2.

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

Minn. R. 7019.1000, subp. 2

Notification of Deviations Endangering Human Health or the Environment: As soon as possible after discovery, notify the Commissioner or the state duty officer, either orally or by facsimile, of any deviation from permit conditions which could endanger human health or the environment.

Minn. R. 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 any deviation from permit conditions which could endanger human health or the environment. Include the following information in this written description: 1. the cause of the deviation; 2. the exact dates of the period of the deviation, if the deviation has been corrected; 3. whether or not the deviation has been corrected; 4. the anticipated time by which the deviation is expected to be corrected, if not yet corrected; and 5. steps taken or planned to reduce, eliminate, and prevent reoccurrence of the deviation.

Minn. R. 7019.1000, subp. 1



A-4 09/14/15

Application for Permit Amendment: If a permit amendment is needed, submit an application in accordance with the requirements of Minn. R. 7007.1150 through Minn. R. 7007.1500. Submittal dates vary, depending on the type of amendment needed.

Minn. R. 7007.1150-7007.1500

Extension Requests: The Permittee may apply for an Administrative Amendment to extend a deadline in a permit by no more than 120 days, provided the proposed deadline extension meets the requirements of Minn. R. 7007.1400, subp. 1(H). Performance testing deadlines from the General Provisions of 40 CFR pt. 60 and pt. 63 are examples of deadlines for which the MPCA does not have authority to grant extensions and therefore do not meet the requirements of Minn. R. 7007.1400, subp. 1(H).

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

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

Minn. R. 7019.3000 - 7019.3100

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

REQUIREMENTS RELATED TO AIR DISPERSION MODELING SUBMITTED WITH THE APPLICATION

These are state only requirements and are not enforceable by the EPA Administrator and citizens under the Clean Air Act.

hdr

Modeled Parameters for PM10: The parameters used in PM10 modeling for permit number 14900013-006 are listed in Appendix I of this permit. The parameters describe the operation of the facility at maximum permitted capacity when it is producing ethanol and other coproducts. The purpose of listing the parameters in the appendix is to provide a benchmark for future changes.


Modeled Parameters for PM2.5: The parameters used in PM2.5 modeling for permit number 14900013-006 are listed in Appendix I of this permit. The parameter describe the operation of the facility at maximum permitted capacity when it is producing ethanol and other coproducts. The purpose of listing the parameters in the appendix is to provide a benchmark for future changes.

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

Equivalent or Better Dispersion (EBD) Modeling Triggers (Modeling Not Required) for PM2.5: Changes that do not require a permit amendment or that require an administrative permit amendment do not trigger the EBD Modeling Submittal requirement. The Permittee shall keep updated records on site of all modeled PM2.5 parameters and emission rates listed in Appendix I. The Permittee shall submit any changes to modeled PM2.5 parameters and emission rates with the next required modeling submittal. (Tier 3)


EBD Modeling Triggers (Modeling Required) for PM2.5: Changes that require, or would require, a minor, moderate or major permit amendment due to an increase in PM2.5 emissions and affect any modeled PM2.5 parameter or emission rate listed in Appendix I, or an addition to the information documented in Appendix I, trigger the EBD Remodeling Submittal requirement. The Permittee shall include previously made changes to modeled PM2.5 parameters and emission rates listed in Appendix I that did not previously trigger the EBD Modeling Submittal requirement with this modeling submittal. (Tier 3)


Submit: due before end of each 60 months following Effective Date of Permit an EBD Modeling analysis for PM2.5: The Permittee shall submit an EBD Modeling Submittal that addresses any changes made during the previous five years that did not require a permit amendment but that affected any modeled PM2.5 parameter or emission rate documented in Appendix I or an addition to the information documented in Appendix I and that did not trigger the EBD Modeling Triggers (Modeling Required) requirement. If no changes were made, send a letter to the Commissioner stating that no EBD Modeling Analysis was required.


EBD Modeling Submittal for PM2.5: For changes meeting the criteria in the EBD Modeling Triggers (Modeling Required) requirement, the Permittee shall submit an EBD modeling submittal in accordance with the current version of the MPCA Air Dispersion Modeling Guidance and shall wait for written approval (for major amendments, in the form of an issued permit amendment; for moderate amendments, in the form of a construction authorization letter) before making such changes. For minor amendments, written approval of the EBD modeling may be given before permit issuance; however, this approval applies only to the EBD modeling and not to any other changes. (Tier 3)


EBD Modeling Submittal Content for PM2.5: The information submitted must include, for stack and vent sources, source emission rate, location, height, diameters, exit velocity, exit temperature, discharge direction, use of rain caps or rain hats, and, if applicable, locations and dimensions of nearby buildings. For non-stack/vent sources, this includes the source emission rate, location, size and shape, release height, and, if applicable, any emission rate scalars, and the initial lateral dimensions and initial vertical dimensions and adjacent building heights.


TABLE A: LIMITS AND OTHER REQUIREMENTS A-5 09/14/15 Facility Name: DENCO II LLC Permit Number: 14900013 - 006

Outdated EBD Baseline Modeling for PM2.5: Prior to conducting the EBD analysis, the Permittee shall use the current version of the MPCA Air Dispersion Modeling Guidance to determine if the Baseline Modeling (the most recent refined modeling demonstration) is outdated. If the Baseline Modeling is outdated, the Permittee shall update the Baseline Modeling to be consistent with the current version of the MPCA Air Dispersion Modeling Guidance. The updated modeling will become the new Baseline Modeling. This requirement does not require the Permittee to complete a new refined modeling demonstration using the revisions made for the EBD demonstration.


EBD Modeling Results for PM2.5: The dispersion characteristics due to the revisions of the information in Appendix I must be equivalent to or better than the dispersion characteristics modeled 6/25/2012. The Permittee shall demonstrate this equivalency in the proposal.


Computer Dispersion Modeling Triggers for PM2.5: The Permittee shall conduct a refined remodeling analysis in accordance with the Computer Dispersion Modeling requirements of this permit and the current version of the MPCA Air Dispersion Modeling Guidance if: (1) the results of the EBD modeling analysis do not demonstrate equivalent or better dispersion characteristics; (2) a conclusion cannot readily be made about the dispersion, or (3) the criteria in the EBD Modeling Triggers requirement are met and the Permittee has previously conducted three successive EBD analyses using the same Baseline Modeling.

Minn. Stat. Section 116.07, subds. 4a & 9; Minn. R. 7009.0020; Minn. R. 7007.0100, subp. 7(A), 7(L), & 7(M); Minn. R. 7007.0800, subp. 2



A-6 09/14/15

Subject Item: GP 001 Tanks subject to NSPS subp. Kb

Associated Items: TK011 Denatured Ethanol

TK012 Denatured Ethanol


What to do Why to do it The requirements of this group apply individually to each unit listed under this group.

Minn R. 7007.0800, subp. 2

Recordkeeping: Maintain records showing the dimensions of each tank and an analysis showing each tank's capacity.

40 CFR Section 60.116b(b); Minn. R. 7011.1520(C)

The storage vessel shall be equipped with a fixed roof in combination with an internal floating roof meeting the requirements of 40 CFR Section 60.112b(a)(1).

40 CFR Section 60.112b(a); Minn. R. 7011.1520(C)

The storage vessel shall be equipped with the following closure devices between the wall of the storage vessel and the edge of the internal floating roof consisting of two seals mounted one above the other so that each forms a continuous closure that completely covers the space between the wall of the storage vessel and the edge of the internal floating roof. The lower seal may be vapor mounted, but both must be continuous.

40 CFR Section 60.112b(a)(1 )(ii)(B); Minn. R. 7011.1520(C)

Inspection before initial fill: Visually inspect the internal floating roof, the primary seal, and the secondary seal, prior to filling the storage vessel with Volatile Organic Liquid (VOL). If there are holes, tears, or other openings in the primary seal, the secondary seal, or the seal fabric, or defects in the internal floating roof, or both, the owner or operator shall repair the items before filling the storage vessel.

40 CFR Section 60.113b(a)(1); Minn. R. 7011.1520(C)

Visually inspect the internal floating roof, the primary seal, and the secondary seal through manholes and roof hatches on the fixed roof at least once every 12 months after initial fill as required by this paragraph.

40 CFR Section 60.113b(a)(3)(ii); Minn. R. 7011.1520(C)

Visually inspect the internal floating roof, the primary seal, the secondary seal, gaskets, slotted membranes and sleeve seals (if any) each time the storage vessel is emptied and degassed, as required by this paragraph. In no event shall inspections conducted in accordance with this provision occur at intervals greater than 10 years.

40 CFR Section 60.113b(a)(3)(i): Minn. R. 7011.1520(C)

Notification: If an inspection is required (under 40 CFR Section 60.113b(a)(1) or 40 CFR Section 60.113b(a)(3)(i)), notify the Commissioner in writing at least 30 days prior to the filling or refilling of the storage vessel, to afford the Commissioner the opportunity to have an observer present. If the inspection is not planned and the owner or operator could not have known about the inspection 30 days in advance of the refilling the tank, the owner or operator shall notify the Commissioner at least 7 days prior to the refilling of the storage vessel. Notification shall be made by telephone immediately followed by written documentation demonstrating why the inspection was unplanned. Alternatively, this notification including the written documentation may be made in writing and sent by express mail so that it is received by the Commissioner at least 7 days prior to refilling.


Notification: Furnish the Commissioner with a report describing the internal floating roof and certifying that it meets the specifications of 40 CFR Section 60.112b(a)(1) and 40 CFR Section 60.113b(a)(1). The report shall be an attachment to the notification of actual date of initial startup required by 40 CFR Section 60.7(a)(3).


Keep a record of each inspection performed as required by 40 CFR Section 60.113b(a)(1), (a)(2), (a)(3), and (a)(4). Each record shall identify the storage vessel on which the inspection was performed and shall contain the date the vessel was inspected and the observed condition of each component of the control equipment (seals, internal floating roof, and fittings).


After each inspection required under 40 CFR Section 60.113b(a)(3) that finds holes or tears in the seal or seal fabric, or defects in the internal floating roof, or other control equipment defects listed in 40 CFR Section 60.113b(a)(3)(ii), a report shall be furnished to the Commissioner within 30 days of the inspection. The report shall indentify the storage vessel and the reason it did not meet the specifications of 40 CFR Section 60.112b(a)(1) or 40 CFR Section 60.113b(a)(3)(ii), and list each repair made.


TABLE A: LIMITS AND OTHER REQUIREMENTS A-7 09/14/15

Facility Name:

Permit Number:

Subject Item:

Associated Items:

DENCO II LLC

14900013-006

GP 002 Tanks subject to State Rule

TK 001 Ethanol 200 proof




TK 005 E-85




Minn R. 7007.0800, subp. 2

Equip each storage tank with a submerged fill pipe. Minn. R. 7011.1505, subp. 3


Minn. R. 7007.0800, subp. 5



A-8 09/14/15

Subject Item:

Associated Items:

GP 008 Boilers 001 and 002

EU 001 Boiler No. 1 - Boiler



Minn R. 7007.0800, subp. 2

Total Particulate Matter: less than or equal to 0.4 lbs/million Btu heat input. The potential to emit from each unit is 0.007 Ib/MMBtu due to equipment design and allowable fuels.

Minn. R. 7011.0515, subp. 1

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

This limit applies individually to each emission unit.

Minn. R. 7011.0515, subp. 2

Fuel used: Limited to natural gas and propane; for recordkeeping requirements, see GP011.

Minn. Stat. Section 116.07, subd. 4a; Minn. R. 7007.0800; Minn. R. 7011.0515, subp. 1



Subject Item: GP 010 Propane Users

Associated Items: EU 001 Boiler No. 1 - Boiler



EU 066 DDGS Dryer - Dryer/Oven, indirect fired

A-9 09/14/15


Minn R. 7007.0800, subp. 2

Fuel Usage: less than or equal to 2032787 gallons/year using 12-month Rolling Sum of total propane combustion (in all 4 units combined).

Title I Condition: CAAA of 1990; Minn. Stat. Section 116.07, subds. 4a & 9; Minn. R. 7007.0100, subps. 7(A) & (B); Minn. R. 7007.0800, subps. 1 and 2; Title I Condition: Avoid major source under 40 CFR 52.21 (b)(1)(i) and Minn. R. 7007.3000; To avoid major source under 40 CFR 70.2 & Minn. R. 7007.0200

Recordkeeping: By the 15th day of each month, calculate and record the quantity of propane, in gallons, used during the previous month and during the previous 12 months (12-month rolling sum).




A-10 09/14/15

Subject Item: GP011 NOx Group





EU 083 Regenerative Thermal Oxidizer CE027


Minn R. 7007.0800, subp. 2

EMISSION LIMIT hdr

Nitrogen Oxides: less than or equal to 28.7 tons/year calculated as a 52-week rolling sum. Compliance with the tons/year limit for GP011 is calculated using emission factors determined during most recent performance test for NOx for each unit.

Title I Condition: CAAA of 1990; Minn. Stat. Section 116.07, subds. 4a & 9; Minn. R. 7007.0100, subps. 7(A) & (B); Minn. R. 7007.0800, subps. 1 and 2; Title I Condition: Avoid major source under 40 CFR 52.21 (b)(1 )(i) and Minn. R. 7007.3000; To avoid major source under 40 CFR 70.2 & Minn. R. 7007.0200

RECORDKEEPING REQUIREMENTS hdr

Daily Recordkeeping. On each day of operation, the Permittee shall calculate, record, and maintain a record of the total quantity of each fuel used in each item in this Group. For natural gas, this shall be based on flowmeter readings. For propane, this shall be based on delivery records.

Title I Condition: CAAA of 1990; Minn. Stat. Section 116.07, subds. 4a & 9; Minn. R. 7007.0100, subps. 7(A) & (B); Minn. R. 7007.0800, subps. 1 and 2; Title I Condition: Avoid major source under 40 CFR 52.21 (b)(1)(i) and Minn. R. 7007.3000; To avoid major source under 40 CFR 70.2 & Minn. R. 7007.0200; Minn. R. 7007.0800. subp. 4 and 5

Weekly Recordkeeping - NOx emissions

By Thursday of each week, the Permittee shall calculate and record the following:

1) The NOx emissions for the previous calendar week using the daily fuel use records specified above.

2) The weekly rolling sum NOx emissions for the previous 52-week period by summing the monthly NOx emissions data.

Title I Condition: CAAA of 1990; Minn. Stat. Section 116.07, subds. 4a & 9; Minn. R. 7007.0100, subps. 7(A) & (B); Minn. R. 7007.0800, subps. 1 and 2; Title I Condition: Avoid major source under 40 CFR 52.21 (b)(1)(i) and Minn. R. 7007.3000; To avoid major source under 40 CFR 70.2 & Minn. R. 7007.0200; Minn. R. 7007.0800. subp. 4 and 5

Monthly Recordkeeping: By the 15th of the month, the Permittee shall identify, calculate and record the following:

1) The NOx emission factor in Ib/MMBtu for the previous calendar month for each unit in GP011 as determined by the most recent performance test data. Process NOx emissions may be excluded from the emission factor or calculation if accounted for within the test.

2) The 12-month rolling sum NOx emission rates (tons/year) for the previous 12-month period by summing the monthly NOx emission rate (tons/year) for the previous 12 months.

Minn. R. 7007.0800, subps. 4 and 5

Calculation Method - The Permittee shall calculate compliance with the NOx limit(tons/year) using the following equations:

Monthly GP011 NOx emissions (tons/year) = EFT * THI * 8760 hours/year * 0.0005 tons/lbs

where: EFT (Emission Factor Total) = sum of Ib/MMBtu as determined during most recent stack test for each unit = EF(EU001) + EF(EU002) + EF(EU059) + EF(EU066) + EF(EU083). The emission factors are to be determined for each combustion unit and each fuel typed allowed for the units in GP011.

THI (Total Heat Input) = sum of MMBtu/hr of each individual HI for each fuel allowed for the units in GP011 = HI(EU001) + HI(EU002) + HI(EU059) + HI(EU066) + HI(EU083) = THI MMBtu/hr

Minn. R. 7007.0800, subps. 4 and 5

PROTOCOL FOR RE-SETTING THE EMISSION FACTOR hdr



Protocol for Verifying the Emission Factor Used For Calculating GP011 NOx Ib/hr Emissions: The Permittee shall conduct performance testing under conditions that produce the maximum NOx emission rate, using US EPA Reference Method 19 or other approved method to measure the NOx emission factor as required elsewhere in this permit. The Permittee shall report the test result in Ib/MMBtu in the performance test report required by Minn. R. 7017.2035, subp. 1.

The emission factor used for calculating NOx emissions shall be re-set to the 3-hour average emission rate in Ib/MMBtu, measured during the most recent MPCA-approved NOx emission factor performance test.

(continued)


Protocol for Verifying the Emission Factor Used For Calculating NOx Emissions (continued):

The new emission factor used for calculating compliance with the NOx Ib/hr limit shall be effective upon receipt of the Notice of Compliance (NOC) letter that approves the test results and shall be incorporated into the permit during the next permit amendment.




Subject Item: GP013 Post-1969 Industrial Process Equipment

Associated Items: EU 007 Corn Bin 1 (storage bin) - Silo/Bin

EU 008 Corn Bin 2 (surge bin) - Silo/Bin

EU 009 Corn Bin 3 (storage bin) - Silo/Bin

EU 067 Bio-diges ter - Digester

EU 086 Grain Bin - Silo/Bin

. EU 087 Grain Bin - Silo/Bin

A-12 09/14/15


Minn R. 7007.0800, subp. 2

Total Particulate Matter: less than or equal to 0.30 grains/dry standard cubic foot of exhaust gas unless required to further reduce emissions to comply with the less stringent limit of either Minn. R. 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)



A-13 09/14/15

Subject Item: SV 005 Grain Handling Baghouse (CE 019)

Associated Items: EU 005 Corn Dump Pit - Other Emission Unit

EU 006 Grain Elevator - Elevator

EU010 Scalper-Cutting Equipment

EU 086 Grain Bin - Sil o/Bin


What to do Why to do i t EMISSION LIMITS hdr

Total Particulate Matter: less than or equal to 0.46 lbs/hour using 3-hour Average Title I Condition: Avoid major source under 40 CFR 52.21 (b)(1 )(i) and Minn. R. 7007.3000; To avoid major source under 40 CFR 70.2 & Minn. R. 7007.0200

PM < 10 micron: less than or equal to 0.46 lbs/hour using 3-hour Average Title I Condition: Avoid major source under 40 CFR 52.21 (b)(1 )(i) and Minn. R. 7007.3000; To avoid major source under 40 CFR 70.2 & Minn. R. 7007.0200; 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 and 2

PM < 2.5 micron: less than or equal to 0.46 lbs/hour using 3-hour Average Title 1 Condition: Avoid major source under 40 CFR 52.21 (b)(1)(i) and Minn. R. 7007.3000; To avoid major source under 40 CFR 70.2 & Minn. R. 7007.0200; 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 and 2

Opacity: less than or equal to 10 percent opacity Minn. R. 7011.1005, subp. 3(D)

POLLUTION CONTROL REQUIREMENTS (See CE 019 for monitoring and maintenance requirements).

hdr

The Permittee shall operate and maintain the control equipment such that it achieves an overall collection efficiency for Total Particulate Matter: greater than or equal to 99.0 percent collection efficiency


The Permittee shall operate and maintain the control equipment such that it achieves an overall collection efficiency for PM < 10 micron: greater than or equal to 99.0 percent collection efficiency

Title I Condition: Avoid major source under 40 CFR 52.21 (b)(1 )(i) and Minn. R. 7007.3000; To avoid major source under 40 CFR 70.2 & Minn. R. 7007.0200; 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 and 2

The Permittee shall operate and maintain the control equipment such that it achieves an overall collection efficiency for PM < 2.5 micron: greater than or equal to 99.0 percent collection efficiency

Title I Condition: Avoid major source under 40 CFR 52.21 (b)(1)(i) and Minn. R. 7007.3000; To avoid major source under 40 CFR 70.2 & Minn. R. 7007.0200; 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 and 2

Total Particulate Matter: greater than or equal to 80.0 percent capture efficiency from grain handling operations as long as they vent to SV005/CE019.

Title I Condition: Avoid major source under 40 CFR 52.21 (b)(1 )(i) and Minn. R. 7007.3000; To avoid major source under 40 CFR 70.2 & Minn. R. 7007.0200

PM <10 micron: greater than or equal to 80.0 percent capture efficiency from grain handling operations as long as they vent to SV005/CE019.


PM < 2.5 micron: greater than or equal to 80.0 percent capture efficiency from grain handling operations as long as they vent to SV005/CE019.


HOOD EVALUATION hdr



Initial Hood Certification and Evaluation: To claim a hood capture efficiency of 80% for PM, PM10 and PM2.5, the control device hood must conform to the design and operating requirements referenced in Minn. R. 7011.0072, subp. 2(B). The Permittee shall certify this as specified in Minn. R. 7011.0072, subps. 2 and 3, except that the Minn. R. 7011.0072, subp. 2(B) certification submittal deadline shall be superseded by the deadline established by this permit (No. 14900013-006). The hood certification must address how cross-drafts are accommodated in the design (i.e. higher face velocity, oversized hood, etc.). The Permittee shall maintain a copy of the evaluation and certification on site.

The Permittee shall certify that the hood conforms to the requirements of the reference listed in Minn. R. 7011.0061. The Permittee shall submit the results of the evaluation and certification on forms HE-01 and CR-02 no later than 180 days after issuance of permit No. 14900013-006.

Minn. R. 7007.0800, subps. 2, 4 & 5

Annual Hood Evaluation: The Permittee shall measure and record at least once every 12 months the fan rotation speed, fan power draw, face velocity, or other comparable air flow parameter(s) that was measured during the initial hood certification to verify the hood design and operation parameter(s) meet or exceed the parameter(s) measured during the initial hood evaluation conducted according to Minn. R. 7011.0072, subps. 2 & 3. The Permittee shall maintain a copy of the annual evaluation on site.

Minn. R. 7007.0800, subps. 2, 4 & 5


Performance Test: due 180 days after Effective Date of Permit to measure Total Particulate Matter emissions (Ib/hr).

The performance test shall be conducted at worst case conditions as defined at Minn. R. 7017.2005, subp. 8, using EPA Reference Method 5 and Method 202, or other method approved by MPCA in the performance test plan approval.

Testing conducted during the 60 days prior to the performance test due date satisfies the performance test due date, and will not reset the test due date for future testing as required: 1) by this permit; 2) by the most recently approved Performance Test Frequency Plan; or 3) within a Notice of Compliance letter. Testing conducted more than two months prior to the performance test due date satisfies this test due date requirement and will reset the performance test due date.

Title I Condition: Minn. Stat. Section 116.07, subds. 4a & 9; Minn. R. 7007.0100, subps. 7(A) & (B); Minn. R. 7007.0800, subps. 1 and 2; Title I Condition: Avoid major source under 40 CFR 52.21 (b)(1)(i) and Minn. R. 7007.3000; To avoid major source under 40 CFR 70.2 & Minn. R. 7007.0200; Minn. R. 7017.2020, subp. 1

Performance Test: due 180 days after Effective Date of Permit to measure PM10 emissions (Ib/hr).

The performance test shall be conducted at worst case conditions as defined at Minn. R. 7017.2005, subp. 8, using EPA Reference Method 5 and Method 202, or Method 201A and Method 202, or other method approved by MPCA in the performance test plan approval.


Title I Condition: Minn. Stat. Section 116.07, subds. 4a & 9; Minn. R. 7007.0100, subps. 7(A) & (B); Minn. R. 7007.0800, subps. 1 and 2; Title I Condition: Avoid major source under 40 CFR 52.21(b)(1)(i) and Minn. R. 7007.3000; To avoid major source under 40 CFR 70.2 & Minn. R. 7007.0200; Minn. R. 7017.2020, subp. 1

Performance Test: due 180 days after Effective Date of Permit to measure PM2.5 emissions (Ib/hr).




Performance Test Recordkeeping: During each performance test the Permittee shall record and maintain the process and control parameters as detailed in Appendix II. These records shall be included with the performance test results and submitted to the Commissioner with the performance test report.

Minn. R. 7007.0800, subps. 4-5; Minn. R. 7017.2020, subp. 1


Facility Name: DENCO II LLC


FOR POLLUTION CONTROL AND PERIODIC MONITORING REQUIREMENTS, SEECE 019.

hdr



A-16 09/14/15

Subject Item: SV016 DDGS Building Exhaust (CE 018)

Associated Items: EU 055 DDGS Storage Pile - Other Emission Unit

EU 056 DDGS Du mp Pit - Other Emission Unit

EU 057 DDGS Elevator - Elevator

EU 058 Truck Load Spout - Loading-Unloading Equipment

What to do Why to do it EMISSION LIMITS hdr

Total Particulate Matter: less than or equal to 0.11 lbs/hour using 3-hour Average Title I Condition: Avoid major source under 40 CFR 52.21 (b)(1 )(i) and Minn. R. 7007.3000; To avoid major source under 40 CFR 70.2 & Minn. R. 7007.0200

PM <10 micron: less than or equal to 0.11 lbs/hour using 3-hour Average Title I Condition: Avoid major source under 40 CFR 52.21 (b)(1)(i) and Minn. R. 7007.3000; To avoid major source under 40 CFR 70.2 & Minn. R. 7007.0200; 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 and 2

PM < 2.5 micron: less than or equal to 0.11 lbs/hour using 3-hour Average Title I Condition: Avoid major source under 40 CFR 52.21 (b)(1)(i) and Minn. R. 7007.3000; To avoid major source under 40 CFR 70.2 & Minn. R. 7007.0200; 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 and 2


POLLUTION CONTROL REQUIREMENTS (See CE 018 for monitoring and maintenance requirements).

hdr

Visible Emissions: The Permittee shall check the stack (SV016) for any visible emissions once each day of operation.

Minn. R. 7007.0800, subps. 4 and 5



The Permittee shall operate and maintain the control equipment such that it achieves an overall collection efficiency for PM <10 micron: greater than or equal to 99.0 percent collection efficiency

Title I Condition: Avoid major source under 40 CFR 52.21 (b)(1 )(i) and Minn. R. 7007.3000; To avoid major source under 40 CFR 70.2 & Minn. R. 7007.0200; 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 and 2




Title 1 Condition: Avoid major source under 40 CFR 52.21 (b)(1)(i) and Minn. R. 7007.3000; To avoid major source under 40 CFR 70.2 & Minn. R. 7007.0200

PM < 10 micron: greater than or equal to 80.0 percent capture efficiency from grain handling operations as long as they vent to SV016/CE018.




HOOD EVALUATION hdr





Minn. R. 7007.0800, subps. 2, 4 & 5


Minn. R. 7007.0800, subps. 2, 4 & 5













Title I Condition: Minn. Stat. Section 116.07, subds. 4a & 9; Minn. R. 7007.0100, subps. 7(A) & (B); Minn. R. 7007.0800, subps. 1 and 2; Title I Condition: Avoid major source under 40 CFR 52.21 (b)(1 )(i) and Minn. R. 7007.3000; To avoid major source under 40 CFR 70.2 & Minn. R. 7007.0200; Minn. R. 7017.2020, subp. 1






FOR POLLUTION CONTROL AND PERIODIC MONITORING REOUIRMENTS, SEE CE 018

hdr


Facility Name:

Permit Number:

Subject Item:

Associated Items:

DENCO II LLC

14900013 - 006

SV 018 Fermentation and Distillation

EU 018 Fermenter A-3 - Fermentation Equipment


EU 061 Fermenter - Fermentation Equipment



EU 064 Beer Well - Fermentation Equipment


EU 069 Side Stripper - Stripping Equipment

EU 070 Molecular S ieve - Distillation Equipment


EU 088 Yeast Propagation Tank - Fermentation Equipment

EU 089 Beer Column - Distillation Equipment

EU 090 Rectifier - Distillation Equipment


What to do Why to do it EMISSION LIMIT hdr

Volatile Organic Compounds: less than or equal to 5.0 lbs/hour using 3-hour Average measured on a total mass of VOC basis.


OPERATIONAL REQUIREMENTS hdr

Process Throughput: less than or equal to 320 gallons/minute using 8-hour Block Average Beer Feed Rate, unless a new limit is set pursuant to Minn. R. 7017.2025, subp. 3 based on the throughput recorded during the most recent MPCA-approved performance test where compliance was demonstrated. The new limit shall be implemented upon receipt of the Notice of Compliance letter granting preliminary approval. The limit is final upon issuance of a permit amendment incorporating the change. This operating parameter must remain in the permit to define the maximum capacity of the process on an hourly basis.


The Permittee shall vent emissions from EU's 018, 019, 061, 062, 063, 064, 065, 069, 070, 072, 089, 090, 091, or their replacements, that are venting through SV018 to a scrubber and prescrubber meeting the requirements of CE020 and CE029 whenever EU's 018, 019, 061, 062, 063, 064, 065, 069, 070, 072, 089, 090, 091, or their replacements, operate. The Permittee shall operate and maintain a scrubber and prescrubber meeting the requirements of CE020 and CE029 at all times that any emissions are vented to a scrubber and prescrubber meeting the requirements of CE020 and CE029. The Permittee shall document periods of non-operation of the control equipment.

Title I Condition: to avoid major source classification under 40 CFR Section 52.21 and Minn. R. 7007.3000; To avoid major source under 40 CFR 70.2 & Minn. R. 7007.0200; Minn. R. 7007.0800, subps. 2 and 14

The Permittee shall vent all emissions from EU's 018, 019, 061, 062, 063, 064, 065, 069, 070, 072, 089, 090, 091, or their replacements, that are venting through SV018 to a scrubber and prescrubber capable of achieving 96.5% destruction of VOC emissions.

Title I Condition: Minn. Stat. Section 116.07, subds. 4a & 9; Minn. R. 7007.0100, subps. 7(A) & (B); Minn. R. 7007.0800, subps. 1 and 2

The Permittee shall vent emissions from EU088 to CE020 and CE029 whenever EU088 operates and is not controlled by CE027. The Permittee shall document periods when EU088 is vented to CE020 and CE029.

See CE027 for additional bypass requirements.


POLLUTION CONTROL REQUIREMENTS (FOR ADDITIONAL REQUIREMENTS SEE CE020 AND CE029)

hdr

Volatile Organic Compounds: greater than or equal to 96.5 percent collection efficiency (See CE 020 and CE 029 for monitoring and maintenance requirements.)




A-20 09/14/15

Alternative to the above efficiency requirement, if the inlet VOC concentration is less than 200 ppm, Volatile Organic Compounds: less than or equal to 20 parts per million using 3-hour Average


PERFORMANCE TESTING REQUIREMENTS hdr

Performance Test: due 180 days after Effective Date of Permit to measure VOC emissions as mass (Ib/hr) from SV 018.

The performance test shall be conducted at the target process rates defined in Appendix II, using EPA Reference Method 25, 25A, 18, 320, or other method approved by MPCA in the performance test plan approval. Process throughput limits as gpm for the beer feed rate, 190 proof ethanol production rate and 200 proof ethanol production rates will be defined by the operating process rates sustained during the test pursuant to Minn. R. 7017.2025 subp. 3.C


Title I Condition: CAAA of 1990; Minn. Stat. Section 116.07, subds. 4a & 9; Minn. R. 7007.0100, subps. 7(A) & (B); Minn. R. 7007.0800, subps. 1 and 2; Minn. R. 7017.2020, subp. 1; Minn. R. 7017.2025 subp. 3.C

Performance Test: due 180 days after Effective Date of Permit to measure VOC control efficiency or ppm VOC from SV 018.

The performance test shall be conducted the target process rates defined in Appendix II, using EPA Reference Method 25, 25A, or other method approved by MPCA in the performance test plan approval. Process throughput limits as gpm for the beer feed rate, 190 proof ethanol production rate and 200 proof ethanol production rates will be defined by the operating process rates sustained during the test pursuant to Minn. R. 7017.2025 subp. 3.C


Title I Condition: Minn. Stat. Section 116.07, subds. 4a & 9; Minn. R. 7007.0100, subps. 7(A) & (B); Minn. R. 7007.0800, subps. 1 and 2; To avoid major source under 40 CFR 52.2; to avoid major source under 40 CFR 70.2 and Minn. R. 7007.0200; To avoid major source under 40 CFR 63.2; Minn. R. 7017.2020, subp. 1; Minn. R. 7017.2025 subp. 3.C

Performance Test: due 180 days after Effective Date of Permit to measure speciated HAP emission factors.

The testing report shall contain, at a minimum, test results for acetaldehyde, methanol, acrolein, and formaldehyde. The results of the performance test shall be used to verify the emission factors used in the potential emission calculations.

The performance test shall be conducted at the target process rates defined in Appendix II, using EPA Reference Methods 18, or other method approved by the MPCA in the performance test plan approval. Process throughput limits as gpm for the beer feed rate, 190 proof ethanol production rate and 200 proof ethanol production rates will be defined by the operating process rates sustained during the test pursuant to Minn. R. 7017.2025 subp. 3.C (continued below)

Minn. R. 7007.0800, subp. 2; Minn. R. 7017.2020, subp. 1; Minn. R. 7017.2025 subp. 3.C

(continued from above) Testing conducted during the 60 days prior to the performance test due date satisfies the test due date, and will not reset the test due date for future testing as required: 1) by this permit; 2) by the most recently approved Performance Test Frequency Plan; or 3) within a Notice of Compliance letter. Testing conducted more than two months prior to the performance test due date satisfies this test due date requirement and will reset the performance test due date.




Performance Test: due 180 days after Equipment Installation of Fermentation Tank EU 091 to measure VOC emissions as mass (Ib/hr) from SV 018.

The performance test shall be conducted at the target process rates defined in Appendix II, using EPA Reference Method 25, 25A, 18, 320, or other method approved by MPCA in the performance test plan approval. Process throughput limits as gpm for the beer feed rate, 190 proof ethanol production rate and 200 proof ethanol production rates will be defined by the operating process rates sustained during the test pursuant to Minn. R. 7017.2025 subp. 3.C. (continued below)


(continued from above) Testing conducted during the 60 days prior to the performance test due date satisfies the performance test due date, and will not reset the test due date for future testing as required: 1) by this permit; 2) by the most recently approved Performance Test Frequency Plan; or 3) within a Notice of Compliance letter. Testing conducted more than two months prior to the performance test due date satisfies this test due date requirement and will reset the performance test due date.


Performance Test: due 180 days after Equipment Installation of Fermentation Tank EU 091 to measure VOC control efficiency or ppm VOC from SV 018.

The performance test shall be conducted at the target process rates defined in Appendix II, using EPA Reference Method 25, 25A, or other method approved by MPCA in the performance test plan approval. Process throughput limits as gpm for the beer feed rate, 190 proof ethanol production rate and 200 proof ethanol production rates will be defined by the operating process rates sustained during the test pursuant to Minn. R. 7017.2025 subp. 3.C (continued below)




Performance Test: due 180 days after Equipment Installation of Fermentation Tank EU 091 to measure speciated HAP emission factors.

The testing report shall contain, at a minimum, test results for acetaldehyde, methanol, and acrolein. The results of the performance test shall be used to verify the emission factors used in the potential emission calculations.







A-22 09/14/15

Performance Test: due 90 days after achieving normal operation after any change to the source of the scrubber water to measure VOC emissions as mass (Ib/hr) from SV 018.

The performance test shall be conducted at worst case conditions as defined at Minn. R. 7017.2005, subp. 8, using EPA Reference Method 25, 25A, 18, 320 or other method approved by MPCA in the performance test plan approval.


Title I Condition: CAAA of 1990; Minn. Stat. Section 116.07, subds. 4a & 9; Minn. R. 7007.0100, subps. 7(A) & (B); Minn. R. 7007.0800, subps. 1 and 2; Minn. R. 7017.2020, subp. 1

Performance Test: due 90 days after achieving normal operation after any change to the source of the scrubber water to measure VOC control efficiency or VOC ppm from SV 018.

The performance test shall be conducted at worst case conditions as defined at Minn. R. 7017.2005, subp. 8, using EPA Reference Method 25, 25A, or other method approved by MPCA in the performance test plan approval.


Title I Condition: Minn. Stat. Section 116.07, subds. 4a & 9; Minn. R. 7007.0100, subps. 7(A) & (B); Minn. R. 7007.0800, subps. 1 and 2; To avoid major source under 40 CFR 52.2; to avoid major source under 40 CFR 70.2 and Minn. R. 7007.0200; To avoid major source under 40 CFR 63.2; Minn. R. 7017.2020, subp. 1

Performance Test: due 90 days after achieving normal operation after any change to the source of the scrubber water to measure HAP emission factors.


The performance test shall be conducted at worst case conditions as defined at Minn. R. 7017.2005, subp. 8, using EPA Reference Methods 18, or other method approved by the MPCA in the performance test plan approval. (continued below)

Minn. R. 7007.0800, subp. 2; Minn. R. 7017.2020, subp. 1



Performance Test: due before end of each calendar 60 months starting 04/08/2014 for total mass of VOC emissions, not to exceed 60 months between test dates. The performance test shall be conducted at worst case conditions as defined at Minn. R. 7017.2005, subp. 8, using EPA Reference Methods 18, 25A, 320, or other method approved by MPCA in the performance test plan approval. This test shall include, at a minimum, speciated results for the following HAPs of concern: acetaldehyde, hexane, methanol, and acrolein. The results of the performance test shall be used to confirm the emission factors used to calculated HAP emissions, (continued below)

Title I Condition: to avoid major source classification under 40 CFR Section 52.21 and Minn. R. 7007.3000; To avoid major source under 40 CFR 70.2 & Minn. R. 7007.0200; Minn. R. 7017.2020, subp. 1


Title I Condition: to avoid major source classification under 40 CFR Section 52.21 and Minn. R. 7007.3000; To avoid major source under 40 CFR 70.2 & Minn. R. 7007.0200; Minn. R. 7017.2020, subp. 1



Procedure to Increase Process Throughput Limits: 1. Performance Test Notification (written): due 90 days before performance test at an increased process throughput rate. 2. The values for the beer processing rate, 190 proof ethanol processing rate, and 200 proof processing rate sustained during the test will determine operating conditions after every stack test in accordance with Minn. R. 7017.2025 subp. 3.C. Refer to Appendix II for more stack testing requirements. 3. The Permittee may exceed the process throughput limits after notification of a performance test at a higher process throughputs is received by the MPCA. 4. The Permittee shall calculate actual emissions using the emission rate from the increased process throughput performance test beginning the date of the Performance Test Notification. 5. Performance Test Plan: due 30 days before performance test. The Test Plan will identify the new proposed maximum process throughput limits. (continued)

Minn. R. 7017.2018; Minn. R. 7017.2030, subps. 1-4, Minn. R. 7017.2025 subp. 3.C, Minn. R. 7107.2035, subps. 1-2

Procedure to Increase Process Throughput Limits (continued): 5. Performance Test Pre-Test Meeting: due 7 days before performance test. 6. Performance Test Report: due 45 days after performance test. 7. Performance Test Report - Microfiche Copy: due 105 days after each performance test.

The Notification, Test Plan and Test Report may be submitted in an alternative format as allowed by Minn. R. 7017.2018.


Procedure to Authorize Reverse Osmosis Reject Water as input for CE020: 1. Performance Test Notification (written): due 90 days before performance test at the defined reverse osmosis reject water flow rate to be authorized as input for CE020. 2. The values for reverse osmosis reject water flow rate during the test will determine operating conditions after every stack test in accordance with Minn. R. 7017.2025 subp. 3.C. 3. The Permittee may use reverse osmosis reject water as input for CE020 after notification of a performance test with reverse osmosis reject water is received by the MPCA. 4. The Permittee shall calculate actual emissions using the emission rate from the reverse osmosis reject water performance test beginning the date of change to reverse osmosis reject water. (continued)


Procedure to Authorize Reverse Osmosis Reject Water as input for CE020(continued): 5. Performance Test Plan: due 30 days before performance test. The Test Plan will identify defined reverse osmosis reject water flow rate limit as input for CE020. 6. Performance Test Pre-Test Meeting: due 7 days before performance test. 7. Performance Test Report: due 45 days after performance test. 8. Performance Test Report - Microfiche Copy: due 105 days after each performance test. The Notification, Test Plan, and Test Report may be submitted in an alternative format as allowed by Minn. R. 7017.2018.


Performance Test Recordkeeping: During each performance test the Permittee shall record and maintain the required items as detailed in Appendix II. These records shall be included with the performance test results and submitted to the Commissioner with the performance test report.


FOR POLLUTION CONTROL AND PERIODIC MONITORING REQUIREMENTS, SEE CE020 AND CE029

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A-24 09/14/15

Subject Item: SV 019 Dryer (CE021 and CE027) Associated Items: EU 066 DDGS Dryer - Dryer/Oven, indirect fired




Total Particulate Matter: less than or equal to 7.11 lbs/hour using 3-hour Average Title I Condition: CAAA of 1990; Minn. Stat. Section 116.07, subds. 4a & 9; Minn. R. 7007.0100, subps. 7(A) & (B); Minn. R. 7007.0800, subps. 1 and 2; Title I Condition: Avoid major source under 40 CFR 52.21 (b)(1 )(i) and Minn. R. 7007.3000; To avoid major source under 40 CFR 70.2 & Minn. R. 7007.0200

Total Particulate Matter: less than or equal to 0.070 grains/dry standard cubic foot or the allowable concentration at the exhaust flow rate, as described in Minn. R. 7011.0735.

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

PM <10 micron: less than or equal to 7.11 lbs/hour using 3-hour Average Title I Condition: CAAA of 1990; 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 and 2; Title I Condition: Avoid major source under 40 CFR 52.21 (b)(1)(i) and Minn. R. 7007.3000; To avoid major source under 40 CFR 70.2 & Minn. R. 7007.0200

PM < 2 .5 micron: less than or equal to 7.11 lbs/hour using 3-hour Average Title I Condition: CAAA of 1990; 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 and 2; Title I Condition: Avoid major source under 40 CFR 52.21 (b)(1 )(i) and Minn. R. 7007.3000; To avoid major source under 40 CFR 70.2 & Minn. R. 7007.0200

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

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



Carbon Monoxide: less than or equal to 9.0 lbs/hour using 3-hour Average Title I Condition: CAAA of 1990; Minn. Stat. Section 116.07, subds. 4a & 9; Minn. R. 7007.0100, subps. 7(A) & (B); Minn. R. 7007.0800, subps. 1 and 2; Title I Condition: Avoid major source under 40 CFR 52.21 (b)(1 )(i) and Minn. R. 7007.3000; To avoid major source under 40 CFR 70.2 & Minn. R. 7007.0200

POLLUTION CONTROL REQUIREMENTS, SEE CE021 AND CE027 FOR MONITORING AND MAINTENANCE REQUIREMENTS

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The Permittee shall operate and maintain the control equipment such that it achieves an overall collection efficiency for Volatile Organic Compounds: greater than or equal to 95.0 percent collection efficiency

Title I Condition: Minn. Stat. Section 116.07, subds. 4a & 9; Minn. R. 7007.0100, subps. 7(A) & (B); Minn. R. 7007.0800, subps. 1 and 2; Title I Condition: Avoid major source under 40 CFR 52.21 (b)(1)(i) and Minn. R. 7007.3000; To avoid major source under 40 CFR 70.2 & Minn. R. 7007.0200

The Permittee shall operate and maintain the control equipment such that it achieves an overall collection efficiency for Carbon Monoxide: greater than or equal to 90.0 percent collection efficiency

Title I Condition: Minn. Stat. Section 116.07, subds. 4a & 9; Minn. R. 7007.0100, subps. 7(A) & (B); Minn. R. 7007.0800, subps. 1 and 2; Title I Condition: Avoid major source under 40 CFR 52.21 (b)(1 )(i) and Minn. R. 7007.3000; To avoid major source under 40 CFR 70.2 & Minn. R. 7007.0200









Thermal Oxidizer Breakdown (CE027): In the event of a breakdown of the thermal oxidizer, the Permittee shall stop feed to the dryer as soon as the breakdown is discovered. Dryer operation may continue only as long as necessary to empty the dryer. The Permittee shall also submit the notification required by Minn. R. 7019.1000, subp. 2, if required.

Minn. R. 7007.0800, subp. 2

TESTING REQUIREMENTS hdr

Performance Test: due 180 days after Effective Date of Permit to measure Total Particulate Matter emissions (Ib/hr) from SV 019.




Performance Test: due 180 days after Effective Date of Permit to measure PM10 emissions (Ib/hr) from SV019.

The performance test shall be conducted at worst case conditions as defined at Minn. R. 7017.2005, subp. 8, using EPA Reference Method 5 and Method 202, or 201A and 202, or other method approved by MPCA in the performance test plan approval.



Performance Test: due 180 days after Effective Date of Permit to measure PM2.5 emissions (Ib/hr) from SV 019.






A-26 09/14/15

Performance Test: due 180 days after Effective Date of Permit to measure CO emissions (Ib/hr) from SV 019.

The performance test shall be conducted at worst case conditions as defined at Minn. R. 7017.2005, subp. 8, using EPA Reference Method 10, or other method approved by MPCA in the performance test plan approval.




The performance test shall be conducted at worst case conditions as defined at Minn. R. 7017.2005, subp. 8, using EPA Reference Method 25, 25A, 18, 320, or other method approved by MPCA in the performance test plan approval.





The performance test shall be conducted at worst case conditions as defined at Minn. R. 7017.2005, subp. 8, using EPA Reference Methods 18, or other method approved by the MPCA in the performance test plan approval.

Testing conducted during the 60 days prior to the performance test due date satisfies the test due date, and will not reset the test due date for future testing as required: 1) by this permit; 2) by the most recently approved Performance Test Frequency Plan; or 3) within a Notice of Compliance letter. Testing conducted more than two months prior to the performance test due date satisfies this test due date requirement and will reset the performance test due date.


Performance Test: due 180 days after Effective Date of Permit to measure the S02 emission factor for SV 019.

The performance test shall be conducted at worst case conditions as defined at Minn. R. 7017.2005, subp. 8, using EPA Reference Method 6C, or other method approved by MPCA in the performance test plan approval.


Title I Condition: Minn. Stat. Section 116.07, subds. 4a & 9; Minn. R. 7007.0100, subps. 7(A) & (B); Minn. R. 7007.0800, subps. 1 and 2; To avoid major source under 40 CFR 52.21; to avoid major source under 40 CFR 70.2 and Minn. R. 7007.0200; To avoid major source under 40 CFR 63.2; Minn. R. 7017.2020, subp. 1





A-27 09/14/15

Subject Item: SV 020 Biodigester Flare

Associated Items: EU 067 Bio-digester - Digester

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

Visible Emissions: The Permittee shall check the stack (SV020) for any visible emissions once each day of operation during daylight hours.

Minn. R. 7007.0800, subps. 4 and 5



A-28 09/14/15

Subject Item:

Associated Items:


GP 010 Propane Users

GP 011 NOx Group

SV017 New Boiler Stack

What to do Why to do it Fuel used: Limited to natural gas and propane. Minn. R. 7005.0100, subp. 35a

Recordkeeping: By the 15th day of each month, record the amount of fuel used during the previous month. These records may consist of fuel bill or meter readings.

40 CFR Section 60.48c(g); Minn. R. 7011.0570



A-29 09/14/15

Subject Item: EU 060 Hammermill - Milling Equipment Associated Items: CE 024 Fabric Filter - L ow Temperature, i.e., T<180 Degrees F

SV 021 Hammermill Bag house

What to do Why to do it

EMISSION LIMITS hdr

Total Particulate Matter: less than or equal to 0.60 lbs/hour using 3-hour Average Title I Condition: 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 and 2; Title I Condition: Avoid major source under 40 CFR 52.21 (b)(1 )(i) and Minn. R. 7007.3000; To avoid major source under 40 CFR 70.2 & Minn. R. 7007.0200

PM < 10 micron: less than or equal to 0.60 lbs/hour using 3-hour Average Title I Condition: 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 and 2; Title I Condition: Avoid major source under 40 CFR 52.21 (b)(1)(i) and Minn. R. 7007.3000; To avoid major source under 40 CFR 70.2 & Minn. R. 7007.0200

PM < 2 .5 micron: less than or equal to 0.60 lbs/hour using 3-hour Average Title I Condition: 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 and 2; Title I Condition: Avoid major source under 40 CFR 52.21 (b)(1)(i) and Minn. R. 7007.3000; To avoid major source under 40 CFR 70.2 & Minn. R. 7007.0200


POLLUTION CONTROL REQUIREMENTS (See CE 024 for additional requirements)

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A-30 09/14/15

Subject Item: EU 066 DDGS Dryer - Dryer/Oven, indirect fired Associated Items: CE 021 Multiple Cyclone w/o Fly Ash Reinjection - Most Multiclones

CE 027 Direct Fla me Afterburner

GP 010 Propane Users

GP 011 NOx Group

SV 019 Dryer (CE021 and CE027)

What to do Why to do it Fuel used: Limited to natural gas, propane and bio-digester gas from EU 067; for recordkeeping requirements, see GP011.

Minn. R. 7005.0100, subp. 35a

OPERATING REQUIREMENTS hdr

Thermal Oxidizer Breakdown: In the event of a breakdown of the thermal oxidizer, the Permittee shall stop feed to the dryer as soon as the breakdown is discovered. Dryer operation may continue only as long as necessary to empty the dryer. The Permittee shall also submit the notification required by Minn. R. 7019.1000, subp. 2, if required.

Minn. R. 7007.0800, subp. 2

Wet cake storage limitation: When wet cake by-product is produced, it will be stored for no more than 72 hours on-site unless the outside temperature is less than 55 degrees F (daily maximum). In all cases, the wet cake will be moved off-site as soon as possible.

Minn. R. 7007.0800, subp. 2

Temperature: less than or equal to 1350 degrees F using 1-Hour Average Title I Condition: Avoid major source under 40 CFR 52.21 (b)(1)(i) and Minn. R. 7007.3000; To avoid major source under 40 CFR 70.2 & Minn. R. 7007.0200

Recordkeeping: Observe and record the dryer inlet temperature once each day the dryer is operated


CENTRIFUGE AND SYRUP FEED RATE REQUIREMENTS hdr

Centrifuge Feedrate Process Throughput: less than or equal to 310 gallons/minute using 1-Hour Average

Minn. R. 7017.2025, subp. 3(A)

Recordkeeping: The permittee shall record dryer centrifuge feed rate as a 24-hour average once each day of operation

Minn. R. 7007.0800, subps. 4C and subp. 5

The Permittee shall maintain and operate a flow monitoring device that continuously indicates and records the centrifuge flowrate to the dryer. The monitoring device shall have a margin of error of no more than +/- 2 percent of the flowrate being measured. The recording device shall also calculate the 24-hour average flowrate.

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

Syrup Feedrate Process Throughput: less than or equal to 49 gallons/minute using 1-Hour Average

Minn. R. 7017.2025, subp. 3(A)

Recordkeeping: The permittee shall record the dryer syrup feed rate as a 24-hour average once each day of operation

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

The Permittee shall maintain and operate a flow monitoring device that continuously indicates and records the syrup flowrate to the dryer. The monitoring device shall have a margin of error of no more than +/- 2 percent of the flowrate being measured. The recording device shall also calculate the 24-hour average flowrate.

Minn. R. 7007.0800, subps. 4 and 5

MAINTENANCE REQUIREMENTS hdr

RTO (CE 027) burnouts and other maintenance activities: During RTO burnouts and any other maintenance for which the manufacturer recommends that dryer emissions bypass the RTO, the dryer (EU 066) shall be shutdown. Wet DDGS shall be stored and handled in a manner to minimize VOC emissions and odors during these maintenance activities.

Minn. R. 7007.0800, subp. 14 and 7007.0800, subp. 15J

The Permittee shall maintain a record of such maintenance activities in the O and M Plan for CE 027.



A-31 09/14/15

Subject Item: EU 071 Cooling Cyclone - Cooler Associated Items: SV 022 Cooling Cyclone Stack


Total Particulate Matter: less than or equal to 0.3 lbs/hour using 3-hour Average Title I Condition: Minn. Stat. Section 116.07, subds. 4a & 9; Minn. R. 7007.0100, subps. 7(A) & (B); Minn. R. 7007.0800, subps. 1 and 2; Title I Condition: Avoid major source under 40 CFR 52.21 (b)(1)(i) and Minn. R. 7007.3000; To avoid major source under 40 CFR 70.2 & Minn. R. 7007.0200


PM < 2.5 micron: less than or equal to 0.3 lbs/hour using 3-hour Average Title I Condition: 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 and 2; Title I Condition: Avoid major source under 40 CFR 52.21 (b)(1)(i) and Minn. R. 7007.3000; To avoid major source under 40 CFR 70.2 & Minn. R. 7007.0200


Volatile Organic Compounds: less than or equal to 3.0 lbs/hour using 3-hour Average measured on a total mass of VOC basis

Title I Condition: CAAA of 1990; Minn. Stat. Section 116.07, subds. 4a & 9; Minn. R. 7007.0100, subps. 7(A) & (B); Minn. R. 7007.0800, subps. 1 and 2; to avoid major source classification under 40 CFR Section 70.2 and Minn. R. 7007.0200

MONITORING REQUIREMENTS hdr

Operation and Maintenance of the Cooling Cyclone: The Permittee shall operate and maintain the control device according to the equipment manufacturer's specifications.

Title I Condition: Avoid major source under 40 CFR 52.21 (b)(1)(i) and Minn. R. 7007.3000; To avoid major source under 40 CFR 70.2 & Minn. R. 7007.0200; Minn. R. 7007.0800, subps. 2 and 14; Minn. R. 7007.0800, subps. 2 and 14

Pressure Drop: greater than or equal to 2.0 inches of water column and less than or equal to 8.0 inches of water column , unless a new range is set pursuant to Minn. R. 7017.2025, subp. 3 based on the values recorded during the most recent MPCA-approved performance test where compliance was demonstrated. The new range shall be implemented upon receipt of the Notice of Compliance letter granting preliminary approval. The range is final upon issuance of a permit amendment incorporating the change. The Permittee shall record the pressure drop at least once every 24 hours when in operation.


Recordkeeping of Pressure Drop. 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.


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

Minn. R. 7007.0800, subp. 4

Corrective Actions: The Permittee shall take corrective action as soon as possible if any of the following occur: - visible emissions are observed; - the recorded pressure drop is outside the required operating range; or - the control device or any of i ts components are found during the inspections to need repair. Corrective actions shall return the pressure drop to within the permitted range, eliminate visible emissions, and/or include completion of necessary repairs identified during the inspection, as applicable. Corrective actions include, but are not limited to, those outlined in the O & M Plan for the control device. The Permittee shall keep a record of the type and date of any corrective action taken for each control device.

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



Inspect quarterly, or as required by manufacturing specifications, all components that are not subject to wear or plugging, including structural components, housings, ducts, and hoods. Maintain a written record of the inspection and any action resulting from the inspection.

Minn. R. 7007.0800, subp. 2

Inspect quarterly, or as required by manufacturing specifications, all components that are subject to wear or plugging. Maintain a written record of the inspection and any action resulting from the inspection.

Minn. R. 7007.0800, subp. 2

Monitoring Equipment Calibration: Calibrate or replace the pressure drop measurement device every 12 months, or more or less frequently as required by the manufacturer's specifications. Maintain a written record of the calibration and any action resulting from the calibrations. If calibration frequency is based upon manufacturer's specifications, then manufacturer specifications supporting the calibration frequency must be included in the Operation and Maintenance plan.

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

TESTING REQUIREMENTS hdr

Performance Test: due 180 days after Effective Date of Permit to measure Total Particulate Matter emissions (Ib/hr) from EU 071.


Testing conducted during the 60 days prior to the performance test due date satisfies the performance test due date, and will not reset the test due date for future testing as required: 1) by this permit; 2) by the most recently approved Performance Test Frequency Plan; or 3) within a Notice of Compliance letter. Testing conducted more th an two months prior to the performance test due date satisfies this test due date requirement and will reset the performance test due date.

Title I Condition: Avoid major source under 40 CFR 52.21 (b)(1 )(i) and Minn. R. 7007.3000; To avoid major source under 40 CFR 70.2 & Minn. R. 7007.0200; Minn. R. 7017.2020, subp. 1

Performance Test: due 180 days after Effective Date of Permit to measure PM10 emissions (Ib/hr) from EU 071.




Performance Test: due 180 days after Effective Date of Permit Performance Test: due 180 days after Effective Date of Permit to measure PM2.5 emissions (Ib/hr) from Eu 071.






Performance Test: due 180 days after Effective Date of Permit to measure VOC emissions as mass (Ib/hr) from EU 071.



Title I Condition: Avoid major source under 40 CFR 52.21(b)(1)(i) and Minn. R. 7007.3000; To avoid major source under 40 CFR 70.2 & Minn. R. 7007.0200; Minn. R. 7017.2020, subp. 1





Title I Condition: Avoid major source under 40 CFR 52.21 (b)(1)(i) and Minn. R. 7007.3000; To avoid major source under 40 CFR 70.2 & Minn. R. 7007.0200; Minn. R. 7017.2020, subp. 1





A-34 09/14/15

Subject Item: EU 084 Hammermill 2 - Milling Equipment Associated Items: CE 028 Fabric Filter - Low Temperature, i.e., T<180 Degrees F

SV 025 Hammermill #2


Total Particulate Matter: less than or equal to 0.60 lbs/hour using 3-hour Average Title I Condition: 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 and 2; Title I Condition: Avoid major source under 40 CFR 52.21 (b)(1)(i) and Minn. R. 7007.3000; To avoid major source under 40 CFR 70.2 & Minn. R. 7007.0200


PM < 2.5 micron: less than or equal to 0.60 lbs/hour using 3-hour Average Title I Condition: 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 and 2; Title I Condition: Avoid major source under 40 CFR 52.21 (b)(1 )(i) and Minn. R. 7007.3000; To avoid major source under 40 CFR 70.2 & Minn. R. 7007.0200


POLLUTION CONTROL REQUIREMENTS (See CE 028 for additional requirements)

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A-35 09/14/15

Subject Item: EU 092 Ethanol Loadout - Loading-Unloading Equipment

Associated Items: CE 025 Flaring

SV 023 Ethanol loadout flare

What to do Why to do it Railcar Loadout: Railcars dedicated to ethanol are not required to be vented to the loadout flare (CE025). All other railcars must be vented to the loadout flare (CE025).

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



Subject Item: CE018 Centrifugal Collector - High Efficiency

Associated Items: EU 056 DDGS Dump Pit - Other Emission Unit



A-36 09/14/15

What to do Why to do it EMISSION AND OPERATIONAL LIMITS (SEE SV 016 FOR POLLUTION CONTROL REQUIREMENTS)

hdr

The Permittee shall vent emissions from EU's 056, 057, 058 to CE 018 whenever EU's 056, 057, and 058 operate, and operate and maintain CE 018 at all times that any emissions are vented to CE 018. The Permittee shall document periods of non-operation of the control equipment.

Title I Condition: Avoid major source under 40 CFR 52.21 (b)(1)(i) and Minn. R. 7007.3000; To avoid major source under 40 CFR 70.2 & Minn. R. 7007.0200; Minn. R. 7007.0800, subps. 2 and 14


Title I Condition: Avoid major source under 40 CFR 52.21 (b)(1 )(i) and Minn. R. 7007.3000; To avoid major source under 40 CFR 70.2 & Minn. R. 7007.0200; Minn. R. 7007.0800, subps. 2 and 14

MONITORING AND RECORDKEEPING hdr

Daily Inspections: The Permittee shall do the following, once every 24 hours: 1). Read and record the pressure drop across the centrifugal collector.


Recordkeeping of Pressure Drop: 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.


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



Minn. R. 7007.0800, subp. 4


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

Periodic Inspections: At least once per calendar quarter, or more frequently as required by the manufacturing specifications, the Permittee shall inspect the control equipment components. The Permittee shall maintain a written record of these inspections.

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

The Permittee shall operate and maintain the control device in accordance with the Operation and Maintenance (O & M) Plan. The Permittee shall keep copies of the O & M Plan available onsite for use by staff and MPCA staff.

Minn. R. 7007.0800, subp. 14



A-37 09/14/15

Subject Item: CE 019 Fabric Filter - Low Temperature, i.e., T<180 Degrees F


EU 006 Grain Elevato r - Elevator

EU 010 Scalper - Cutting Equipment


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The Permittee shall vent emissions from EU's 005, 006, and 010 to CE 019 whenever EU's 005, 006, and 010 operate, and operate and maintain CE 019 at all times that any emissions are vented to CE 019. The Permittee shall document periods of non-operation of the control equipment.


Pressure Drop: greater than or equal to 1.0 inches of water column and less than or equal to 6.0 inches of water column . An alternate pressure drop range may be approved by the Agency based on performance testing.



Visible Emissions: The Permittee shall check the fa bric filter stack (SV 005) for any visible emissions once each day of operation during daylight hours. During inclement weather, the Permittee shall read and record the pressure drop across the fabric filter, once each day of operation.


Recordkeeping of Visible Emissions and Pressure Drop. The Permittee shall record the time and date of each visible emission inspection and pressure drop reading, and whether or not any visible emissions were observed, and whether or not the observed pressure drop was within the range specified in this permit.


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

Minn. R. 7007.0800, subps. 4, 5, and 14 Corrective Actions: The Permittee shall take corrective action as soon as possible if any of the following occur: - visible emissions are observed; - the recorded pressure drop is outside the required operating range; or - the fabric filter or any of its components are found during the inspections to need repair. Corrective actions shall return the pressure drop to within the permitted range, eliminate visible emissions, and/or include completion of necessary repairs identified during the inspection, as applicable. Corrective actions include, but are not limited to, those outlined in the O & M Plan for the fabric filter. The Permittee shall keep a record of the type and date of any corrective action taken for each filter. Monitoring Equipment: The Permittee shall install and maintain the necessary monitoring equipment for measuring and recording pressure drop as required by this permit. The monitoring equipment must be installed, in use, and properly maintained when the monitored fabric filter is in operation.

Minn. R. 7007.0800, subp. 4


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


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

The Permittee shall operate and maintain the fabric filter in accordance with the Operation and Maintenance (O & M) Plan. The Permittee shall keep copies of the O & M Plan available onsite for use by staff and MPCA staff.

Minn. R. 7007.0800, subp. 14


Facility Name:

Permit Number:

Subject Item: Associated Items:

DENCO II LLC

14900013-006

CE 020 EU 018

EU 019

EU 061

EU 062

EU 063

EU 064

EU 065

EU 069

EU 070

EU 072

EU 088

EU 089

EU 090

EU 091

Packed-Gas Adsorption Column Fermenter A-3 - Fermentation Equipment

Fermenter A-4 - Fermentation Equipment

Fermenter - Fermentation Equipment



Beer Well - Fermentation Equipment

Beer Well - Fermentation Equipment

Side Stripper - Stripping Equipment

Molecular Sieve - Distillation Equipment


Yeast Propagation Tank - Fermentation Equipment

Beer Column - Distillation Equipment

Rectifier - Distillation Equipment


What to do Why to do it EMISSION AND OPERATIONAL LIMITS hdr

The Permittee shall vent emissions from EU's 018, 019, 061-065, 069, 070, 072, and 089-091 to CE020 whenever EU's 018, 019, 061-065, 069, 070, 072, and 089-091 operate, and operate and maintain CE020 at all times that any emissions are vented to CE020. The Permittee shall document periods of non-operation of the control equipment.





The Permittee shall operate CE029 and CE020 in series at all times that any emissions are vented to CE029 and CE020. CE020 shall operate downstream from CE029.


Pressure Drop: greater than or equal to 3.0 inches of water column and less than or equal to 10.0 inches of water column , unless a new range is set pursuant to Minn. R. 7017.2025, subp. 3 based on the values recorded during the most recent MPCA-approved performance test where compliance was demonstrated. The new range shall be implemented upon receipt of the Notice of Compliance letter granting preliminary approval. The new range is final upon issuance of a permit amendment incorporating the change. The Permittee shall record the pressure drop once every 24 hours when in operation.

Title I Condition: Avoid major source under 40 CFR 52.21 (b)(1)(i) and Minn. R. 7007.3000; To avoid major source under 40 CFR 70.2 & Minn. R. 7007.0200; Minn. R. 7007.0800, subps. 2 and 14; Minn. R. 7017.2025

Water flow rate: greater than or equal to 25 gallons/minute absolute minimum, unless a new minimum is set pursuant to Minn. R. 7017.2025, subp. 3 based on the values recorded during the most recent MPCA-approved performance test where compliance was demonstrated. The new limit shall be implemented upon receipt of the Notice of Compliance letter granting preliminary approval. The limit is final upon issuance of a permit amendment incorporating the change. If the flow rate is below the minimum, the VOC used during that time shall be considered uncontrolled until the flow rate is above the minimum. This shall be reported as a deviation.


Liquid Flow Rate: greater than or equal to 110 milliliter/min ute of either sodium bisulfite (SBS) or ammonium bisulfite (ABS), unless a new minimum is set pursuant to Minn. R. 7017.2025, subp. 3 based on the values recorded during the most recent MPCA-approved performance test where compliance was demonstrated. The new limit shall be implemented upon receipt of the Notice of Compliance letter granting preliminary approval. The limit is final upon issuance of a permit amendment incorporating the change. If the additive rate is below the minimum, the VOC used during that time shall be considered uncontrolled.




Water Supply Source: De-ironed well water. The Permittee may use reverse osmosis reject water after notifying MPCA of this change. The notification must include the percentage of water supply that will be provided by the reverse osmosis reject water and the date when the change in water supply will begin.

Minn. R. 7007.0800, subps. 2 and 14


Daily Inspections: The Permittee shall do the following, once every 24 hours: 1. Read and record the water flow rate; 2. Read and record the scrubber additive rate; 3. Read and record the gas pressure drop across the scrubber.


Recordkeeping of Water Flow Rate, Scrubber Additive Rate, and Pressure Drop: The Permittee shall record the time and date of each water flow rate, scrubber additive rate, and pressure drop reading, and whether or not the observed flow rate, additive rate, or pressure drop was within the range specified in this permit.


The Permittee shall operate and maintain the scrubber at all times that any emission unit controlled by the scrubber is in operation. The Permittee shall document periods of non-operation of the control equipment.


Corrective Actions: The Permittee shall take corrective action as soon as possible if any of the following occur: - the water flow rate is below the minimum specified; - the recorded pressure drop is outside the required operating range; or - the scrubber or any of its components are found during the inspections to need repair. Corrective actions shall return the water flow rate to the minimum value or more, return pressure drop to within the permitted range, and/or include completion of necessary repairs identified during the inspection, as applicable. Corrective actions include, but are not limited to, those outlined in the O & M Plan for the scrubber. The Permittee shall keep a record of the type and date of any corrective action taken for the scrubber.

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

Monitoring Equipment: The Permittee shall install and maintain the necessary monitoring equipment for measuring and recording pressure drop and water flow rate as required by this permit. The monitoring equipment must be installed, in use, and properly maintained when the scrubber is in operation.


For periods when the scrubber is operated within the parameters specified by this permit, the Permittee shall use either one of the following when completing calculations as required elsewhere in this permit:

a. The overall collection efficiency limit specified in this permit for CE020 and CE029 (96.5%); or b. The overall collection efficiency determined during the most recent MPCA approved performance test. If the tested efficiency is less than the efficiency limit in this permit, the Permittee must use the tested value in all calculations until the efficiency is demonstrated to be above the permit limit through a new test.


Periodic Inspections: At least once per calendar quarter, or more or less frequently as required by the manufacturer's specifications, the Permittee shall inspect the control equipment internal and external system components. The Permittee shall maintain a written record of the inspection and any corrective actions taken resulting from the inspection. If inspection frequency is based upon manufacturer's specifications, then manufacturer specifications supporting the frequency must be included in the Operation and Maintenance plan.

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

Monitoring Equipment Calibration: Calibrate or replace the pressure drop and water flow gauges every 12 months, or more or less frequently as required by the manufacturer's specifications. Maintain a written record of the calibration and any action resulting from the calibrations. If calibration frequency is based upon manufacturer's specifications, then manufacturer specifications supporting the calibration frequency must be included in the Operation and Maintenance plan.

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

The Permittee shall operate and maintain the scrubber in accordance with the Operation and Maintenance (O & M) Plan. The Permittee shall keep copies of the O & M Plan available onsite for use by staff and MPCA staff.

Minn. R. 7007.0800, subp. 14



A-40 09/14/15

Subject Item: CE 021 Multiple Cyclone w/o Fly Ash Reinjection - Most Multiclones Associated Items: EU 066 DDGS Dryer - Dryer/Oven, indirect fired


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The Permittee shall vent emissions from EU 066 to CE 021 whenever EU 066 operates, and operate and maintain CE 021 at all times that any emissions are vented to CE 021. The Permittee shall document periods of non-operation of the control equipment.





Daily Inspections: The Permittee shall do the following, once every 24 hours: 1). Read and record the pressure drop across the cyclone.





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


Minn. R. 7007.0800, subp. 4


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


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

The Permittee shall operate and maintain the control device in accordance with the Operation and Maintenance (O & M) Plan. The Permittee shall keep copies of the O & M Plan available onsite for use by staff and MPCA staff.

Minn. R. 7007.0800, subp. 14



A-41 09/14/15


Associated Items: EU 060 Hammermill - Milling Equipment

What to do Why to do it EMISSION AND OPERATIONAL LIMITS (See EU 060 for additional emission and operational limits)

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The Permittee shall operate and maintain the control equipment such that it achieves an overall control efficiency for Total Particulate Matter: greater than or equal to 99.0 percent control efficiency

Title I Condition: 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 and 2; Title I Condition: Avoid major source under 40 CFR 52.21 (b)(1)(i) and Minn. R. 7007.3000; To avoid major source under 40 CFR 70.2 & Minn. R. 7007.0200; Minn. R. 7007.0800, subps. 2 and 14

The Permittee shall operate and maintain the control equipment such that it achieves an overall control efficiency for PM <10 micron: greater than or equal to 99.0 percent control efficiency


The Permittee shall operate and maintain the control equipment such that it achieves an overall control efficiency for PM < 2.5 micron: greater than or equal to 99.0 percent control efficiency





Visible Emissions: The Permittee shall check the fabric filter stack (SV 021) for any visible emissions once each day of operation during daylight hours. During inclement weather, the Permittee shall read and record the pressure drop across the fabric filter, once each day of operation.





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

TABLE A: LIMITS AND OTHER REQUIREMENTS A-42 09/14/15 Facility Name: DENCO II LLC Permit Number: 14900013-006

Monitoring Equipment: The Permittee shall install and maintain the necessary monitoring equipment for measuring and recording pressure drop as required by this permit. The monitoring equipment must be installed, in use, and properly maintained when the monitored fabric filter is in operation.

Minn. R. 7007.0800, subp. 4


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


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


Minn. R. 7007.0800, subp. 14



A-43 09/14/15

Subject Item: CE 025 Flaring

Associated Items: EU 076 Ethanol loado ut flare - Other Combustion

EU 092 Ethanol Loadout - Loading-Unloading Equipment


The Permittee shall vent emissions from EU 076, and EU 092 to CE 025 whenever EU 076, and EU 092 operates, and operate and maintain CE 025 at all times that any emissions are vented to CE 025. The Permittee shall document periods of non-operation of the control equipment.


The Permittee shall operate and maintain the control equipment such that it achieves an overall collection efficiency for Volatile Organic Compounds: greater than or equal to 95.0 percent control efficiency


Opacity: not greater than 0 percent opacity using a 6-minute average except for periods not to exceed 5 minutes in any 2 consecutive hours

Title I Condition: CAAA of 1990; Minn. Stat. Section 116.07, subds. 4a & 9; Minn. R. 7007.0100, subps. 7(A) & (B); Minn. R. 7007.0800, subps. 1 and 2

Operate the flare only with a net heating value of the gas combusted of 300 Btu/scf or greater with a steam-assisted or air assisted fiarre; or with the net heating value of the gas being combusted of 200 Btu/scf with a nonassisted flare

Minn. R. 7007.0800, subp. 14


Title I Condition: CAAA of 1990; 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 and 2; Title I Condition: Avoid major source under 40 CFR 52.21 (b)(1)(i) and Minn. R. 7007.3000; To avoid major source under 40 CFR 70.2 & Minn. R. 7007.0200

MONITORING AND RECORDKEEPING REQUIREMENTS hdr

Visible Emissions: The Permittee shall check the flare stack (SV 023) for any visible emissions once each day of operation during daylight hours while the flare is operating.

Minn. R. 7007.0800, subp. 14; Minn. R. 7007.0800, subp. 16(J); Minn. R. 7007.0800, subps. 4 and 5

Monitoring Equipment: The Permittee shall install and maintain thermocouples to monitor the presence of a pilot flame. The monitoring equipment must be installed, in use, and properly maintained whenever operation of the monitored control equipment is required.

Title I Condition: CAAA of 1990; Minn. Stat. Section 116.07, subds. 4a & 9; Minn. R. 7007.0100, subps. 7(A) & (B); Minn. R. 7007.0800, subps. 1 and 2; Consent Decree para. 7 and 21

The presence of a f lame shall be monitored using a thermocouple or any other equivalent device to detect the presence of a flame.


Operation Requirement: At all times, including periods of startup, shutdown and malfunction, owners shall maintain and operate any affected facility in a manner consistent with good air pollution control practice for minimizing emissions. Determination of whether acceptable operating and maintenance procedures are being used will be based on information available to the Administrator which may include, but is not limited to, monitoring results, opacity observations, review of operating and maintenance procedures, and inspection of the source.


Records Requirement: Keep a record of any startup, shutdown, or malfunction of the flare.


Recordkeeping: Maintain a file of al l measurements, calibration checks, adjustments and maintenance, and all other information required by this part in permanent form, suitable for inspection for at least two years following the date of such measurements, maintenance, and records.


The Permittee shall operate and maintain the flare any time that any process equipment controlled by the flare is in operation.

Minn. R. 7007.0800, subp. 16J

The Permittee shall operate and maintain the flare in accordance with the Operation and Maintenance (O & M) Plan. The Permittee shall keep copies of the O & M Plan available onsite for use by staff and MPCA staff.

Minn. R. 7007.0800, subp. 14

Quarterly Inspections: At least once per calendar quarter, the Permittee shall inspect the control equipment internal and external system components, including but not limited to the refractory and electrical systems. The Permittee shall maintain a written record of the inspection and any corrective actions taken resulting from the inspection.

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



A-44 09/14/15

Corrective Actions: If a pilot flame is not present or if the flare or any of its components are found during the inspections to need repair, the Permittee shall take corrective action as soon as possible. Corrective actions shall result in return to operation of the pilot flame and/or include completion of necessary repairs identified during the inspection, as applicable. Corrective actions include, but are not limited to, those outlined in the O & M Plan for the flare. The Permittee shall keep a record of the type and date of any corrective action taken.

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



Subject Item: CE 027 Direct Flame Afterburner

Associated Items: EU 066 DDGS Dryer - Dryer/Oven, indirect fired


EU 088 Yeast Pro pagation Tank - Fermentation Equipment

A-45 09/14/15

What to do Why to do it EMISSION AND OPERATIONAL LIMITS (SEE SV 019 FOR ADDITIONAL POLLUTION CONTROL REQUIREMENTS)

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The Permittee shall vent emissions from EU 066, EU 083, and EU 088 to CE 027 whenever EU 066, EU 083, and EU 088 operates, and operate and maintain CE 027 at all times that any emissions are vented to CE 027. The Permittee shall document periods of non-operation of the control equipment.


Alternative Operating Scenario: During normal operation, and whenever the regenerative thermal oxidizer (RTO) is operational, emissions from the DDGS dryer (EU 066), the RTO (EU 083), and the Yeast Propagation Tank (EU 088), must vent to the RTO (CE 027/SV 019).

During periods of RTO downtime, the Permittee may vent emissions from the Yeast Propagation Tank (EU 088) to the pre-scrubber (CE 029/SV 018), and scrubber (CE 020/SV018).

Title I Condition: Minn. Stat. Section 116.07, subds. 4a & 9; Minn. R. 7007.0100, subps. 7(A) & (B); Minn. R. 7007.0800, subps. 1 and 2; Title I Condition: Avoid major source under 40 CFR 52.21 (b)(1)(i) and Minn. R. 7007.3000; To avoid major source under 40 CFR 70.2 & Minn. R. 7007.0200

AOS Daily Recordkeeping: The Permittee shall record daily the hours of and reasons for bypassing the RTO (CE 027/SV 019) with some or all of the emissions from EU's 066, 083, and 088. Records shall be kept in a log at the facility.

Title I Condition: Minn. Stat. Section 116.07, subds. 4a & 9; Minn. R. 7007.0100, subps. 7(A) & (B); Minn. R. 7007.0800, subps. 1 and 2; Title I Condition: Avoid major source under 40 CFR 52.21 (b)(1)(i) and Minn. R. 7007.3000; To avoid major source under 40 CFR 70.2 & Minn. R. 7007.0200; Minn. R. 7007.0800, subps. 4, 5 and 11

AOS Monthly Recordkeeping: Using the daily records, by the 15th day of each month, the Permittee shall calculate and record the following:

1) The total hours bypassing the RTO for the previous calender month.

2) The 12-month rolling sum of hours bypassed for the previous 12-month period by summing the monthly hours bypassed data for the previous 12 months.

Minn. R. 7007.0800, subps. 4, 5 and 11

The Permittee shall operate and maintain the control equipment such that it achieves an overall control efficiency for Volatile Organic Compounds: greater than or equal to 95.0 percent control efficiency


Alternative to the above efficiency requirement, Volatile Organic Compounds: less than or equal to 10 parts per million using 3-hour Average


The Permittee shall operate and maintain the control equipment such that it achieves an overall control efficiency for Carbon Monoxide: greater than or equal to 90.0 percent control efficiency


Alternative to the above efficiency requirement, Carbon Monoxide: less than or equal to 100 parts per million using 3-hour Average


Temperature: greater than or equal to 1600 degrees F using 3-hour Average at the Combustion Chamber unless a new minimum is set pursuant to Minn. R. 7017.2025, subp. 3, based on the average temperature recorded during the most recent MPCA approved performance test where compliance for VOC and CO emissions was demonstrated. If the three-hour rolling average temperature drops below the minimum temperature limit, the VOC and CO shall be considered uncontrolled until the average minimum temperature limit is once again achieved. This shall be reported as a deviation.



The Permittee shall maintain a continuous hard copy readout or computer disk file of the temperature readings and calculated three-hour rolling average temperatures for the combustion chamber.

Title I Condition: Minn. Stat. Section 116.07, subds. 4a & 9; Minn. R. 7007.0100, subps. 7(A) & (B); Minn. R. 7007.0800, subps. 1 and 2; Title I Condition: Avoid major source under 40 CFR 52.21 (b)(1 )(i) and Minn. R. 7007.3000; To avoid major source under 40 CFR 70.2 & Minn. R. 7007.0200; Minn. R. 7007.0800, subps. 4 and 5



Daily Monitoring: The Permittee shall physically verify the operation of the temperature recording device at least once each operating day to verify that it is working and recording properly. The Permittee shall maintain a written record of the daily verifications.

Minn. R. 7007.0800, subps. 4 and 5

Monitoring Equipment: The Permittee shall install and maintain thermocouples to conduct temperature monitoring required by this permit. The monitoring equipment must be installed, in use, and properly maintained whenever operation of the monitored control equipment is required.

Minn. R. 7007.0800, subp. 4

The Permittee shall maintain and operate a thermocouple monitoring device that continuously indicates and records the combustion chamber temperature of the thermal oxidizer. The monitoring device shall have a margin of error less than the greater of +/- 0.75 percent of the temperature being measured or +/- 4.5 degrees Fahrenheit. The recording device shall also calculate the three-hour rolling average combustion chamber temperature.

Minn. R. 7007.0800, subps. 4 and 5

Quarterly Inspections: At least once per calendar quarter, the Permittee shall inspect the control equipment external system components. The Permittee shall maintain a written record of the inspection and any corrective actions taken resulting from the inspection.

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

Annual Inspections: At least once per calendar year, and more frequently if required by manufacturer's specifications, the Permittee shall inspect the control equipment internal components, including but not limited to, the refractory, heat exchanger, and electrical systems. Each inspection must be separated by at least 8 months. The Permittee shall maintain a written record of the inspection and any corrective actions taken resulting from the inspection.

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

Annual Calibration: The Permittee shall calibrate the temperature monitor at least annually and shall maintain a written record of the calibration and any action resulting from the calibration.

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

Corrective Actions: If the temperature is below the minimum specified by this permit or if the thermal oxidizer or any of its components are found during the inspections to need repair, the Permittee shall take corrective action as soon as possible. Corrective actions shall return the temperature to at least the permitted minimum and/or include completion of necessary repairs identified during the inspection, as applicable. Corrective actions include, but are not limited to, those outlined in the O & M Plan for the thermal oxidizer. The Permittee shall keep a record of the type and date of any corrective action taken.

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

The Permittee shall operate and maintain the thermal oxidizer in accordance with the Operation and Maintenance (O & M) Plan. The Permittee shall keep copies of the O & M Plan available onsite for use by staff and MPCA staff.

Minn. R. 7007.0800, subp. 14



A-47 09/14/15

Subject Item: CE 028 Fabric Filter - Low Temperature, i.e., T<180 Degrees F Associated Items: EU 084 Hammermill 2 - Milling Equipment

What to do Why to do it EMISSION AND OPERATIONAL LIMITS (See EU 084 for additonal emission and operational requirements)

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The Permittee shall operate and maintain the control equipment such that it achieves an overall control efficiency for PM < 10 micron: greater than or equal to 99.0 percent control efficiency












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

Monitoring Equipment: The Permittee shall install and maintain the necessary monitoring equipment for measuring and recording pressure drop as required by this permit. The monitoring equipment must be installed, in use, and properly maintained when the monitored fabric filter is in operation.

Minn. R. 7007.0800, subp. 4

Monitoring Equipment Calibration: Calibrate or replace the pressure drop every 12 months, or more or less frequently as required by the manufacturer's specifications. Maintain a written record of the calibration and any action resulting from the calibrations. If calibration frequency is based upon manufacturer's specifications, then manufacturer specifications supporting the calibration frequency must be included in the Operation and Maintenance plan.

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


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


Minn. R. 7007.0800, subp. 14


Facility Name:

Permit Number:

Subject Item: Associated Items:

DENCO II LLC

14900013-006

CE 029 Packed-Gas Adsorption Column EU 018 Fermenter A-3 - Fermentation Equipment



EU 062 Fermente r - Fermentation Equipment





EU 070 Molecular Sieve - Distillation Equipment





EU 091 Ferment er - Fermentation Equipment







The Permittee shall operate CE029 and CE020 in series at all times that any emissions are vented to CE029 and CE020. CE029 shall operate upstream from CE020.




Water flow rate: greater than or equal to 90 gallons/minute absolute minimum recirculating water flow rate, unless a new minimum is set pursuant to Minn. R. 7017.2025, subp. 3 based on the values recorded during the most recent MPCA-approved performance test where compliance was demonstrated. The new limit shall be implemented upon receipt of the Notice of Compliance letter granting preliminary approval. The limit is final upon issuance of a permit amendment incorporating the change. If the flow rate is below the minimum, the VOC used during that time shall be considered uncontrolled until the flow rate is above the minimum. This shall be reported as a deviation.


Water flow rate: greater than or equal to 2.5 gallons/minute absolute minimum output from CE029 to the beer well or other process equipment which must be equal to the water flow input from CE020, unless a new minimum is set pursuant to Minn. R. 7017.2025, subp. 3 based on the values recorded during the most recent MPCA-approved performance test where compliance was demonstrated. The new limit shall be implemented upon receipt of the Notice of Compliance letter granting preliminary approval. The limit is final upon issuance of a permit amendment incorporating the change. If the flow rate is below the minimum, the VOC used during that time shall be considered uncontrolled until the flow rate is above the minimum. This shall be reported as a deviation.

Title I Condition: to avoid major source classification under 40 CFR Section 52.21 and Minn. R. 7007.3000; To avoid major source under 40 CFR 70.2 & Minn. R. 7007.0200; Minn. R. 7007.0800, subps. 2 and 14; Minn. R. 7017.2025




Daily Inspections: The Permittee shall do the following, once every 24 hours: 1. Read and record the water recirculating rate 2. Read and record the water flow rate output from CE029 to the beer well or other process equipment. 3. Read and record the gas pressure drop across the scrubber.


Recordkeeping of Water Flow Rates and Pressure Drop: The Permittee shall record the time and date of water flow rate, recirculating flow rate, and pressure drop reading, and whether or not the observed flow rate, recirculating rate, or pressure drop was within the range specified in this permit.




Corrective Actions: The Permittee shall take corrective action as soon as possible if any of the following occur: - the water flow rate or reciruclating flow rate is below the minimum specified; - the recorded pressure drop is outside the required operating range; or - the scrubber or any of its components are found during the inspections to need repair. Corrective actions shall return the water flow rates to the minimum value or more, return pressure drop to within the permitted range, and/or include completion of necessary repairs identified during the inspection, as applicable. Corrective actions include, but are not limited to, those outlined in the O & M Plan for the scrubber. The Permittee shall keep a record of the type and date of any corrective action taken for the scrubber.

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

Monitoring Equipment: The Permittee shall install and maintain the necessary monitoring equipment for measuring and recording pressure drop, water flow rate, and recirculating flow rate as required by this permit. The monitoring equipment must be installed, in use, and properly maintained when the scrubber is in operation.






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


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

The Permittee shall operate and maintain the scrubber in accordance with the Operation and Maintenance (O & M) Plan. The Permittee shall keep copies of the O & M Plan available onsite for use by staff and MPCA staff.

Minn. R. 7007.0800, subp. 14



A-50 09/14/15

Subject Item: TK013 Denaturant

What to do Why to do it (d) For each storage vessel with a design capacity greater than or equal to 75 m3 (20,000 gallons) but less than 151 m3 (40,000 gallons) storing a liquid with a maximum true vapor pressure that is normally less than 27.6 kPa (4.0 psi), the Permittee shall notify the Commissioner within 30 days when the maximum true vapor pressure of the liquid exceeds 27.6 kPa.

40 CFR Section 60.116b; Minn. R. 7011.1520(C)



A-51 09/14/15

Subject Item: FS 001 Roads (truck traffic)

What to do Why to do it Fugitive emissions: Do not cause or permit the transporting of any material in a manner which may allow avoidable amounts of particulate matter to become airborne. Do not caus e or permit a road or a driveway to be constructed, used, repaired, or demolished without applying all such reasonable measures as may be required to prevent particulate matter from becoming airborne.

Minn. R. 7011.0150

Paved roads: The Permittee shall inspect paved roads weekly. The roads shall be cleaned if there is visible accumulation of silt and/or fugitive emissions are observed from traffic.

The Permittee shall maintain a record of the weekly inspections and corrective actions.

Minn. R. 7011.0150

Grain receiving: Limited to the hours of 7 am to 5 pm Monday through Friday year round plus 7 am to 5 pm on Saturdays during the month of October.

Title I Condition: 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 and 2; Title I Condition: Avoid major source under 40 CFR 52.21 (b)(1)(i) and Minn. R. 7007.3000; To avoid major source under 40 CFR 70.2 & Minn. R. 7007.0200



A-52 09/14/15

Subject Item: FS 002 Grain Fugitives

What to do Why to do it Opacity: less than or equal to 5 percent opacity for fugitive emissions from truck unloading of grain or grain handling activities.

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

Clean up commodities spilled on the driveway and other facility property as required to minimize fugitive emissions to a level consistent with FtACT (Reasonably Available Control Technology).

Minn. R. 7011.1005, subp. 1(A)



A-53 09/14/15

Subject Item: FS 003 DDGS Fugitives

What to do Why to do it Opacity: less than or equal to 5 percent opacity for fugitive emissions from DDGS handling activities.

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

Opacity: less than or equal to 10 percent opacity for fugitive emissions from DDGS truck loading.

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

Clean up commodities spilled on the driveway and other facility property as required to minimize fugitive emissions to a level consistent with RACT (Reasonably Available Control Technology).

Minn. R. 7011.1005, subp. 1(A)



A-54 09/14/15

Subject Item: FS 005 Equipment Leaks (valves, flanges and seals)

What to do Why to do it The Permittee shall meet the requirements of 40 CFR pt. 60, subp. VV (until the affected facility becomes subject to 40 CFR pt. 60, subp. VVa) for the control of VOC emissions from leaks from equipment in VOC service.

40 CFR Section 60.482-1 (a)

STANDARDS: PUMPS hdr

Pumps in light liquid service

(a)(1) Each pump in light liquid service shall be monitored monthly to detect leaks by the methods specified in 40 CFR Section 60.485(b) except as provided in 40 CFR Section 60.482-1 (c) and paragraphs (d), (e), and (f)

40 CFR Section 60.482-2(a); Minn. R. 7011.2900

(2) Each pump in light liquid service shall be checked by visual inspection each calendar week for indications of liquids dripping from the pump seal (b)(1) If an instrument reading of 10,000 ppm or greater is measured, a leak is detected

40 CFR Section 60.482-2(b) and (c)

(2) If there are indications of liquids dripping from a pump seal, a leak is detected

(c)(1)When a leak is detected, it shall be repaired as soon as practicable, but not later than 15 days after it is detected, except as provided in 40 CFR Section 60.482-9, delay of repair

(2) A first attempt at repair shall be made no later than 5 calendar days after each leak is detected STANDARDS: COMPRESSORS hdr

Each compressor shall be equipped with a seal system that includes a barrier fluid system and that prevents leakage of VOC to the atmosphere, except as provided in 40 CFR Section 60.482-1 (c) and 40 CFR Section 60.482-3(h) and (i)

40 CFR Section 60.482-3(a)

(b) Each compressor seal system shall be: 40 CFR Section 60.482-3(b)

(1) operated with the barrier fluid at a pressure that is greater than the compressor stuffing box pressure; or

(2) equipped with a barrier fluid system that is connected by a closed vent system to a control device that complies with the requirements of 40 CFR Section 60.482-10; or

(3) equipped with a system that purges the barrier fluid into a process stream with zero VOC emissions (c) The barrier fluid system shall be in heavy liquid service or shall not be in VOC service

40 CFR Section 60.482-3(c) and (d)

(d) Each barrier fluid system shall be equipped with a sensor that will detect failure of the seal system, barrier fluid system or both (e)(1) Each sensor shall be checked daily or equipped with an audible alarm 40 CFR Section 60.482-3(e)

(2) The owner or operator shall determine, based on design considerations and operating experience, a criterion that indicates failure of the seal system, the barrier fluid system or both (f) If the sensor indicates a failure of the seal system, barrier fluid system, or both, a leak is detected

40 CFR Section 60.482-3(f)

(g)(1 )When a leak is detected, it shall be repaired as soon as practicable, but not later than 15 days after it is detected, except as provided in 40 CFR Section 60.482-9, delay of repair

40 CFR Section 60.482-3(g)

(2) A first attempt at repair shall be made no later than 15 calendar days after each leak is detected, except as provided in 40 CFR Section 60.482-9 STANDARDS: PRESSURE RELIEF DEVICES IN GAS/VAPOR SERVICE hdr

(a) Except during pressure releases, each pressure relief device in gas/vapor service shall be operated with no detectable emissions, as indicated by an instrument reading of less than 500 ppm above background, as determined by the methods specified in 40 CFR Section 60.485(c)




(b)(1) After each pressure release, the PRV shall be returned to a condition of no detectable emissions, as indicated by an instrument reading of less than 500 ppm above background, as soon as practicable, but no later than 5 calendar days after the pressure release, except as provided in 40 CFR Section 60.482-9, Delay of Repair

40 CFR Section 60.482-4(b)

STANDARDS: SAMPLING CONNECTION SYSTEMS hdr

(a) Each sampling connection system shall be equipped with a closed-purge, closed-loop, or closed-vent system, except as provided in 40 CFR Section 60,482-1 (c)


(b) Each closed-purge, closed-loop, or closed-vent system as required by 40 CFR Section 60.482-5(a) shall comply with the applicable requirement following:

(1) return the purged process fluid directly to the process line; or

(2) collect and recycle the purged process fluid to a process; or

(3) be designed and operated to capture and transport all the purged fluid to a control device that complies with the requirements of 40 CFR Section 60.482-10

(c) In-situ sampling systems are exempt from these requirements


STANDARDS: OPEN-ENDED VALVES OR LINES hdr

(a)(1) Each open-ended valve or line shall be equipped with a cap, blind flange, plug, or second valve except as provided in 40 CFR Section 60.482-1 (c)

(2) The cap, blind flange, plug, or second valve shall seal the open end at all times except during operations requiring process fluid flow through the open-ended valve or line


(b) Each open-ended valve or line equipped with a second valve shall be operated in a manner such that the valve on the process fluid is closed before the second valve is opened

(c) When a double block-and-bleed system is being used, the bleed valve or line may remain open during operations that require venting the line between the block valves but shall comply with 40 CFR Section 60.482-6(a) at all other times


STANDARDS: VALVES hdr

(a) Each valve shall be monitored monthly to detect leaks by the methods specified in 40 CFR Section 60.485(b)


(b) If an instrument reading of 10,000 ppm or greater is measured, a leak is detected

(c)(1) Any valve for which a leak is not detected for 2 successive months may be monitored the first month of every quarter, beginning with the next quarter, until a leak is detected

(c)(2) If a leak is detected in a valve which is being monitored quarterly, the valve shall be monitored monthly until a leak is not d etected for 2 successive months


(d)(1) When a leak is detected, it shall be repaired as soon as practicable, but not later than 15 calendar days after it is detected, except as provided in 40 CFR Section 60.482-9

(2) A first attempt at repair shall be made no later than 5 calendar days after each leak is detected

40 CFR Section 60.482-7(d)

(e) First attempts at repair include, but are not limited to, the following practices where practicable:

(1) tightening of bonnet bolts, (2) replacement of bonnet bolts, (3) tightening of packing gland nuts, and (4) injection of lubricant into lubricated packings

40 CFR Section 60.482-7(e)

STANDARDS: PUMPS AND VALVES IN HEAVY LIQUID SERVICE, PRESSURE RELIEF DEVICES IN LIGHT LIQUID OR HEAVY LIQUID SERVICE, AND FLANGES AND OTHER CONNECTIONS

hdr

(a) Pumps and valves in heavy liquid service, pressure relief valves in light liquid or heavy liquid service, and flanges and other connectors shall be monitored within 5 days by the method specified in 40 CFR Section 60.485(b) if evidence of a potential leak is found by visual, audible, olfactory, or any other detection method





(c)(1) When a leak is detected, it shall be repaired as soon as practicable, but not later than 15 calendar days after it is detected, except as provided in 40 CFR Section 60.482-9, Delay of Repair



(d) First attempts at repair include, but are not limited to, the practices described under 40 CFR Section 60.482-7(e)


DELAY OF REPAIR hdr

(a) Delay of repair of equipment for wh ich leaks have been detected will be allowed if the repair is technically infeasible without a process unit shutdown; repair of this equipment is to occur before the end of the next process unit shutdown

(b) Delay of repair of equipment will be allowed for equipment which is isolated from the process and which does not remain in VOC service

40 CFR Section 60.482-9(a) and (b)

(c) Delay of repair for valves will be allowed if:

(1) the owner or operator demonstrates that emissions of purged material resulting from the immediate repair are greater than the fugitive emissions likely to result from delay of repair, and

(2) when repair procedures are effected, the purged material is collected and destroyed or recovered in a control device complying with 40 CFR Section 60.482-10

40 CFR Section 60.482-9(c)

(d) Delay of repair for pumps will be allowed if:

(1) Repair required the use of a dual mechanical seal system that includes a barrier fluid system, and

(2) repair is completed as soon as practicable, but not later than 6 months after the leak was detected


(e) Delay of repair beyond a process unit shutdown will be allowed for a valve if valve assembly replacement is necessary during the process unit shoudown, valve asssembly supplies have been depleted, and valve assembly supplies had been sufficiently stocked before the supplies were depleted. Delay of repair beyond the next process unit shutdown will not be allowed unless the next process unit shutdown occurs sooner than 6 months after the first process unit shutdown.

40 CFR Section 60.482-9(e)

TESTING PROCEDURES hdr

Compliance shall be demonstrated by the methods specified in 40 CFR Section 60.485.

40 CFR Section 60.486(b)

RECORDKEEPING hdr

(b) When each leak is detected, the following requirements apply:

(1) a weatherproof and readily visible identification, marked with the equipment identification number, shall be attached to the leaking equipment

(2) the identification on a valve may be removed after it has been monitored for 2 successive months as specified in 40 CFR Section 60.482-7(c) and no leak has been detected during those two months

(3) the identification on equipment, except on a valve, may be removed after it has been repaired


(c) When a leak is detected, the following information shall be recorded in a log and shall be kept for 2 years in a readily accessible location:

(1) the instrument and operator ID numbers and the equipment ID number, (2) the date the leak was detected and the dates of each attempt to repair the leak, (3) repair methods applied in each attempt to repair the leak, (4) "Above 10,000" if the instrument reading measured by the methods specified in 40 CFR Section 60.485(a) after each repair attempt is equal to or greater than 10,000 ppm

40 CFR Section 60.486(c)(1)-(4)



(5) "Repair delayed" and the reason for the delay if a leak is not repaired within 15 calendar days after discovery of the leak, (6) the signature of the owner or operator whose decision it was that repair could not be effected without a process shutdown, (7) the expected date of successful repair of the leak if a leak is not repaired within 15 days, (8) dates of process unit shutdowns that occur while the leaking equipment is unrepaired, and (9) the date of successful repair of the leak

40 CFR Section 60.486(c)(5)-(9)

REPORTING REQUIREMENTS hdr

The first semiannual report submitted for htis purpose shall include the following information:

(1) process unit identification (2) number of va lves subject to the requirements of 40 CFR Section 60.482-7 (3) number of pumps subject to the requirements of 40 CFR Section 60.482-2 (4) number of compressors subject to the requirements of 40 CFR Section 60.482-3


(c) All semiannual reports shall include the following information summarized from the information in 40 CFR 60.486:

(1) process unit identification (2) for each month during the semiannual reporting period, (i) number of valves for which leaks were detected as described in 40 CFR Section 60.482-7(b) or 40 CFR Section 60.483-2 (ii) number of valves for which leaks were not repaired as required in 40 CFR Section 60.482-7 (d)(1) . (iii) number of pumps for which leaks were detected as described in 40 CFR Section 60.482-2(b) and (d)(6)(i) (iv) number of pumps for which leaks were not repaired as required in 40 CFR Section 60.482-2(c)(1) and (d)(6)(ii)

40 CFR Section 60.487(c)(1) and (2)(i)-(2)(iv)

(v) number of compressors for which leaks were detected as described in 40 CFR Section 60.482-3(f) (vi) number of compressors for which leaks were not repaired as required in 40 CFR Section 60.482-3(g)(1) (vii) the facts that explain each delay of repair and, where appropriate, why a process unit shutdown was technically infeasible

40 CFR Section 60.487(c)(2)(v)-(vii)

(3) dates of process unit shutdowns which occurred within the semiannual reporting period (4) revisions to items reported according to paragraph (b) if changes have occurred since the initial report or subsequent revisions to the initial report

40 CFR Section 60.487(c)(3) and (4)

(e) Report the results of all performance tests in accordance with 40 CFR Section 60.8. The provisions of 40 CFR Section 60.8 do not apply to affected facilities subject to the provisions of this subpart except that an owner or operator must notify the Administrator of the schedule for the intial performance tests at least 30 days before the initial performance tests.

40 CFR Section 60.487(e)

TABLE B: SUBMITTALS Facility Name: DENCO II LLC


B-1 09/14/15

Also, where required by an applicable rule or permit condition, send to the Permit Document Coordinator notices of: - accumulated insignificant activities, - installation of control equipment, - replacement of an emissions unit, and - changes that contravene a permit term.

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

Chief Air Enforcement Air and Radiation Branch EPA Region V 77 West Jackson Boulevard Chicago, Illinois 60604

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

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

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

Send any application for a permit or permit amendment to:

Fiscal Services Minnesota Pollution Control Agency 520 Lafayette Road North St. Paul, Minnesota 55155-4194

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

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 NOTIFICATIONS B-2 09/14/15 Facility Name: DENCO II LLC


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

Permit Total Facility

Computer Dispersion Modeling Protocol due 60 days after receipt of written MPCA request for revisions to the submitted protocol for PM2.5 modeling.

Total Facility

Computer Dispersion Modeling Protocol due 90 days after Submittal of updated GI-05B forms for PM2.5 refined modeling. The Permittee shall submit a Computer Dispersion Modeling Protocol that is complete and approvable by MPCA by the deadline in this requirement. This protocol will describe the proposed modeling methodology and input data, in accordance with the current version of the MPCA Air Dispersion Modeling Guidance. The protocol must be based on projected operating conditions under the next permit term.

Total Facility

Computer Dispersion Modeling Results due 270 days after receipt of written MPCA approval of Computer Dispersion Modeling Protocol for PM2.5. The Permittee shall submit a final Computer Dispersion Modeling Report that is complete and approvable by MPCA by the deadline in this requirement. The submittal shall adhere to the current version of the MPCA Air Dispersion Modeling Guidance and the approved Computer Dispersion Modeling Protocol.

Total Facility

Submittal due 180 days after Effective Date of Permit, forms GI-02, GI-03, GI-04, GI-05A, GI-05B, GI-05C, GI-05D, GI-05F, and GI-07 providing complete, accurate, and up-to-date information where this information is blank, missing, outdated, incorrect, or listed as 'TBD' in the facility description. Include Form SCP-01 to certify the information provided in the forms.

Total Facility

Testing Frequency Plan due 60 days after Performance Test for PM10 emissions. The plan shall specify a testing frequency based on the test data and MPCA guidance. Future performance tests based on 12-month, 36-month, or 60-month intervals, or as applicable, shall be required upon written approval of the MPCA.

SV005, SV016

Testing Frequency Plan due 60 days after Performance Test for PM2.5 emissions. The plan shall specify a testing frequency based on the test data and MPCA guidance. Future performance tests based on 12-month, 36-month, or 60-month intervals, or as applicable, shall be required upon written approval of the MPCA.

SV005, SV016

Testing Frequency Plan due 60 days after Performance Test for Total Particulate Matter emissions. The plan shall specify a testing frequency based on the test data and MPCA guidance. Future performance tests based on 12-month, 36-month, or 60-month intervals, or as applicable, shall be required upon written approval of the MPCA.

SV005, SV016

TABLE B: RECURRENT SUBMITTALS B-3 09/14/15 Facility Name: DENCO II LLC


What to send When to send Portion of Facility Affected LDAR Report due 30 days after half-year following permit

issuance The reports are due by July 30 and January 30 for the respective 6-month periods.

FS005

Semiannual Deviations Report due 30 days after end of each calendar half-year starting 09/12/2012 . The first semiannual report submitted by the Permittee shall cover the calendar half-year in which the permit is issued. The first report of each calendar year covers January 1 - June 30. The second report of each calendar year covers July 1 - December 31. If no deviations have occurred, the Permittee shall submit the report stating no deviations.

Total Facility

Compliance Certification due 31 days after end of each calendar year starting 09/12/2012 (for the previous calendar year). The Permittee shall submit this to the Commissioner on a form approved by the Commissioner. This report covers all deviations experienced during the calendar year.

Total Facility

TABLE C: COMPLIANCE SCHEDULE Facility Name: DENCO II LLC


C-1 09/14/15

Table C contains the compliance schedule as required by Minn. R. 7007.0500, subp. 2 (K). You must complete the actions required in Table C by the dates listed in the table. All submittals must be postmarked or received by the date specified in the table, and certified by a responsible official, defined in Minn. R. 7007.0100, subp. 21.


Citation Corrective Action When to complete the action DUPLICATE (1) Minn. R. 7007.0800, subp. 2

Submittal due 180 days after Effective Date of Permit, forms GI-02, GI-03, GI-04, GI-05A, GI-05B, GI-05C, GI-05D, GI-05F, and GI-07 providing complete, accurate, and up-to-date information where this information is blank, missing, outdated, incorrect, or listed as 'TBD' in the facility description. Include Form SCP-01 to certify the information provided in the forms.

Facility Name: DENCO II LLC Permit Number: 14900013-006

APPENDIX I Modeling Parameters

Table 1: Modeled Parameters, Point Sources

Stack Vent id

Polluta nt

Base_ Elev (m)

Height (m)

Diam (m)

Exit_Vel (m/s)

Exit_Temp (K)

Release -Type

Emission_Rate (g/sec)

Emission _Rate (Ib/hr)

Easting (m) Northing

(m) Description

DENSV001 PM10 342.67 10.3632 0.5944 10.6432 457.04 VERT 0.022679618 0.18 272869.73 5050883.98 Boiler #1


DENSV005 PM10 341.72 30.48 0.51 27.84 -1 VERT 0.057959025 0.46 272873.93 5050992.37 Grain Handling

DENSV016 PM10 342.19 10.36 0.3 38.83 -1 VERT 0.013859767 0.11 272850.86 5050968.88 DDGS Handling


DENSV018 PM10 342.54 12.8 0.3048 10.45 279 VERT 0 0 272853.76 5050929.7 Process

Scrubber

DENSV019 PM10 342.29 21.336 1.5179 11.4584 435.93 VERT 0.895844931 7.11 272830.65 5050965.04 RTO

DENSV020 PM10 342.33 11.2776 0.3048 0.51744 1033.15 VERT 1.26E-04 0.001 272899.95 5050918.2 Bio-digester

DENSV021 PM10 341.59 24.384 0.8626 21.336 -1 VERT 0.075598728 0.6 272886.66 5050996.05 Hammermill

DENSV022 PM10 342.19 18.288 0.445 20.2119 294.26 VERT 0.037799364 0.3 272847.96 5050971.38 Cyclone Cooler

DENF006A PM10 341.47 8.8392 7.62 6.9966 294.26 VERT 0.028979513 0.23 272956.25 5050971.6 Cooling Tower

#1

DENF006B PM10 341.78 8.8392 7.62 6.9966 294.26 VERT 0.028979513 0.23 272970.26 5050902.92 Cooling Tower

#2

DENSV023 PM10 342.33 10.9728 1.0668 0.10546 1033.15 VERT 0.002015966 0.016 272899.95 5050918.2 Loadout Flare

DENSV026 PM10 341.47 19.5072 1.1156 0.001 -1 VERT 0.103318262 0.82 272876.73 5051008.09 Grain Bin 1

DENSV027 PM10 341.36 19.5072 1.1156 0.001 -1 VERT 0.103318262 0.82 272900.02 5051008.09 Grain Bin 2

DENSV029 PM10 341.61 29.465 1.1156 0.001 -1 VERT 0.103318262 0.82 272853.5 5051015 Proposed Grain

Bin 3

DENSV030 PM10 341.23 29.465 1.1156 0.001 -1 VERT 0.103318262 0.82 272923.15 5051006.23 Proposed Grain

Bin 4

DENSV001 PM2.5 342.67 10.3632 0.5944 10.6432 457.04 VERT 0.022679618 0.18 272869.73 5050883.98 Boiler #1


DENSV005 PM2.5 341.72 30.48 0.51 27.84 -1 VERT 0.057959025 0.46 272873.93 5050992.37 Grain Handling

DENSV016 PM2.5 342.19 10.36 0.3 38.83 -1 VERT 0.013859767 0.11 272850.86 5050968.88 DDGS Handling



DENSV018 PM2.5 342.54 12.8 0.3048 10.45 279 VERT 0 0 272853.76 5050929.7 Process

Scrubber

DENSV019 PM2.5 342.29 21.336 1.5179 11.4584 435.93 VERT 0.895844931 7.11 272830.65 5050965.04 RTO

DENSV020 PM2.5 342.33 11.2776 0.3048 0.51744 1033.15 VERT 1.26E-04 1.00E-03 272899.95 5050918.2 Bio-digester

DENSV021 PM2.5 341.59 24.384 0.8626 21.336 -1 VERT 0.075598728 0.6 272886.66 5050996.05 Hammermill

DENSV022 PM2.5 342.19 18.288 0.445 20.2119 294.26 VERT 0.037799364 0.3 272847.96 5050971.38 Cyclone Cooler

DENF006A PM2.5 341.47 8.8392 7.62 6.9966 294.26 VERT 0.028979513 0.23 272956.25 5050971.6 Cooling Tower

#1

DENF006B PM2.5 341.78 8.8392 7.62 6.9966 294.26 VERT 0.028979513 0.23 272970.26 5050902.92 Cooling Tower

#2

DENSV023 PM2.5 342.33 10.9728 1.0668 0.10546 1033.15 VERT 0.002015966 0.016 272899.95 5050918.2 Loadout Flare

DENSV026 PM2.5 341.47 19.5072 1.1156 0.001 -1 VERT 0.017639703 0.14 272876.73 5051008.09 Grain Bin 1

DENSV027 PM2.5 341.36 19.5072 1.1156 0.001 -1 VERT 0.017639703 0.14 272900.02 5051008.09 Grain Bin 2

DENSV029 PM2.5 341.61 29.465 1.1156 0.001 -1 VERT 0.017639703 0.14 272853.5 5051015 Proposed Grain

Bin 3

DENSV030 PM2.5 341.23 29.465 1.1156 0.001 -1 VERT 0.017639703 0.14 272923.15 5051006.23 Proposed Grain

Bin 4

Table 2: Modeled Parameters, Area Sources Stack Vent

ID Pollutant

Base_Elev (m)

Height (m)

Length X (m)

Length_Y (m)

Rotation Angle (deg)

Emission Rate (g/sec)

Emission Rate (Ib/hr)

XI (m) Y1 (m) Desc

DENF7A PM10 344.13 3.048 117.348 32.004 166 0.03250745

3 0.258 272695.94

5050908. 7

Flat Storage #1

DENF7B PM10 344.25 3.048 117.348 32.004 166 0.03250745

3 0.258 272701.02 5050868 Flat Storage #2

DENF7A PM2.5 344.13 3.048 117.348 32.004 166 0.00112189

9 0.00890411 272695.94

5050908. 7

Flat Storage #1

DENF7B PM2.5 344.25 3.048 117.348 32.004 166 0.00112189

9 0.00890411 272701.02 5050868 Flat Storage #2

'roads, cooling towers, material landling, storage piles, unloading...


Table 3: Modeled Parameters, Volume Source

Stack Vent ID

Polluta nt

Base_Elev (m) Height (m)

Later Dimension SigmaY (m)

Vertical Dimension SigmaZ (m)

Emission Rate (g/sec)

Emission_Rate (Ib/hr)

Easting XI (m)

Northing Y1 (m) Desc

DENF2&3 PM10 341.93 6.096 12.8 5.67 1.03E-01 8.21E-01 272866.74 5050983.42

Grain Recieving and DDGS

Uncaptured Emissions

DENF2&B PM2.5 341.93 6.096 12.8 5.67 1.74E-02 1.38E-01 272866.74 5050983.42

Grain Recieving and DDGS

Uncaptured Emissions


APPENDIX II: Stack Test Methods and Parameter Recording Requirements

The values for process parameters will determine operating conditions after every stack test in accordance with Minn. R. 7017.2012 subp. 3.C. The values for APCE parameters will determine operating conditions after every stack test in accordance with Minn. R. 7017.2012 subp. 3.B

Emission Source Pollutant Test Method(s)1 Process Parameters APCE Parameters GP 011 (NOx Group) EU 001, 002, 059, 066, 083

NOx emission factor (EF)

19 MMBtu/hr heat input NA

SV 005 (Grain Handling Baghouse) EU 005, 006, 010, 086, 087

PM PM10 PM2.5

5 & 202 5 & 202 or 201A & 202 5 & 202 or 201A & 202

Short Term Grain Receiving Throughput: 130.0 ton/hr

CE 019 (Fabric Filter) • Pressure drop (in. w.c.)

SV 016 (DDGS Building Exhaust) EU 055, 056, 057, 058

PM PM10 PM2.5

5 & 202 5 & 202 or 201A & 202 5 & 202 or 201A & 202

DDGS short term peak throughput: 84 tons/hr

CE 018 (Centrifugal Collector) • Pressure drop (in w.c.)

SV 018 (Fermentation and Distillation and Molecular Sieve) EU 018, 019, 061-065, 069, 070, 072, 088-091 (note: during the stack test, the new yeast propagation tank must be connected to the scrubber.)

VOC as mass VOC % control HAPs species

25 or 25A and 18 or 320 25, 25A 18 or 320

Yeast propagation tank: when the tested batch started and when it is expected to end.

Target Beer Feed Rate: 320 gpm from beer well to beer column as measured at the beer feed pump located at the discharge of the beer wells

Target Distillation ethanol production: 60 gpm of 190 proof ethanol as measured at the pump that sends 190 proof ethanol to storage.

Target Undenatured ethanol: 48 gpm of 200 proof ethanol as measured at the outlet of the molecular sieve.

CE 020 (Scrubber) • Pressure drop (in. w.c.) • Water Flow rate (gpm):

permit limit > 25 gpm • Additive flow rate

(mL/min): permit limit > 110 mL/min

• Water Supply Source: De-ironed well water. Reverse osmosis water may be used upon MPCA notification

CE 029 (Pre Scrubber) • Pressure drop (in. w.c.) • Recirculating water flow

rate (gpm): permit limit > 90 gpm

• Water flow rate discharge to beerwells (gpm): permit limit >2.5 gpm


SV 019 (Dryer) EU 066, 083, 088

PM PM10 PM2.5 CO VOC as mass HAPs species S02 EF

5 & 202 5 & 202 or 201A & 202 5 & 202 or 201A & 202 10 25 or 25A and 18 or 320 18 or 320 6C

Total DDGS feed to dryer (solids only): 17,500 Ib/hr

CE 021 (Multiple Cyclone) • Pressure drop (in w.c.) CE 027 (RTO) • Temp (degrees F)

EU 071 (Cooling Cyclone)

PM PM10 PM2.5 VOC as mass HAPs species

5 & 202 5 & 202 or 201A & 202 5 & 202 or 201A & 202 25 or 25A and 18 or 320 18 or 320

Total DDGS feed to dryer (solids only): 17,500 Ib/hr

EU 071 (Cooling Cyclone) • Pressure Drop (in. w.c.)

^he MPCA may approve other methods when appropriate

When conducting HAP performance testing, the Permittee must test for the following compounds from the following sources:

a. acetaldehyde

b. acetic acid

c. acrolein

d. ethanol

e. ethyl acetate

f. formaldehyde

g- isoamyl alcohol

h. methanol

Additional chemicals may be required by the MPCA Performance Test Coordinator.

TECHNICAL SUPPORT DOCUMENT For

AIR EMISSION PERMIT NO. 14900013-006

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 preliminary 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: 2869)

DENCO II LLC 227 County Road 22 Morris, Stevens County, Minnesota 56267

DENCO II LLC 227 County Road 22 Morris, Stevens County, Minnesota 56267

Contact: Mick Miller Phone: 320-585-7901

1.2 Facility Description The facility is a fuel-ethanol production plant located near Morris, Minnesota in Stevens County. The primary emissions are VOCs, PM/PM10/PM2.5, NOx, and CO. Volatile organic compounds (VOCs) are emitted by fermentation, distillation, DDGS drying, ethanol loading, and VOC liquid storage and piping. Particulate matter (PM/PMi0/PM2.5) is emitted by corn receiving and handling, DDGS handling and drying, and vehicle traffic. Nitrogen oxides (NOx) and carbon monoxide (CO) are emitted by combustion sources. The plant is currently permitted to produce 30 million gallons of 200 proof ethanol annually.

The primary air pollution controls onsite are the Process Scrubber (CE020) and the Regenerative Thermal Oxidizer (RTO) (CE027). The scrubber controls emissions from the Fermentation and Distillation operation (SV018); the RTO controls emissions from the Dryer (EU066) and Yeast Propagation Tank (EU088). Baghouses control PM/PM10/PM25 from the corn and DDGS handling and storage systems and the Truck/Rail Loadout area. There are internal floating roof tanks for ethanol. Emissions from process valves and piping are controlled through an inspection and maintenance program.

1.3 Description of the Activities Allowed by this Permit Action This permit action is for a Major Amendment. Construction and operation of emission units 088, 089, 090, and 091 has been authorized in this permit action. The major amendment proposes to add a pre scrubber ethanol recovery device (CE029) in series on the upstream side of the existing scrubber (CE020) to condense and remove ethanol vapors before they enter CE020. The device will use water to condense and collect ethanol vapors resulting in a decrease of water discharged during the ethanol process.

DENCO II also proposes to replace the existing Stripper (EU051) with a new Beer Column (EU089), the existing yeast propagation tanks (EU016 and EU017) with a new yeast propagation tank (EU088), and

Technical Support Document, Permit Action Number: 14900013 - 006 Page 1 of 12

the existing Rectifier (EU068) with a new Rectifier (EU090). An additional Fermentation tank to slow down the fermentation will also be added as EU 091. EU088 emissions will be now rerouted to the Regenerative Thermal Oxidizer (CE027), except for during periods of CE027 downtime in which EU088 will be controlled by CE020 and CE029. All other emission units will continue to be controlled by the existing scrubber (CE020) in addition to the new pre scrubber (CE029). The equipment replacements, yeast propagation control bypass, and additional fermenter will result in no increase of emissions.

Also included in this permit action is a rol led in Administrative Amendment (DQ# 4738) originally submitted 03/14/2014. This amendment was for a 120 day stack test extension that has since been passed and completed.

1.4 Changes to Permit: • Updates to reflect current MPCA templates and standard citation formatting; • Changed name of SV018 from "Fermentation Scrubber (CE020)" to "Fermentation and

Distillation"; • Changed name of replaced unit EU 051 from "Stripper" to EU089 "Beer Column" ; • Added new pre scrubber CE029 to permit; • Updated BACT-equivalent limit citations to "Title I Condition: CAAA of 1990; Minn. Stat. Section

116.07, subds. 4a & 9; Minn. R. 7007.0100, subps. 7(A) & (B); Minn. R. 7007.0800, subps. 1 and 2";

• Updated CE 020 requirement language; • Updated source-specific requirements language on the FC level to better distinguish daily and

monthly recordkeeping; • Added Grain throughput recordkeeping, and a requirement that states "Grain received by the

facility shall only be used for production of ethanol and coproducts" to the FC source-specific requirements;

• Updated all Title I citations; • Updated modeling citations; • Added Annual Inspection to RTO (CE027); • Added PM2.5 limit to RTO (SV019); • Removed unnecessary hood certification requirements from throughout the permit • Added a 322,000 tpy grain process throughput limit and recordkeeping to FC level of permit; • Added PM2.5 limits throughout permit where Total PM and PM10 limits were currently located. • Added limit for a minimum capture of 80.0% for grain handling operations; • Updated Fabric Filter CE language for Hammermilling operation control devices (CE 024, 028).

Included control efficiencies set at 99.0% based on calculations; • Moved CE requirements from Hammermilling activites (EU 060, EU84) to the CE level (CE 024,

CE028); • Updated Flaring (CE 025) control equipment language. Included control efficiency limit of 95.0%

for VOC emissions; • Added Tier I modeling requirements for PM10, and Tier III requirements for PM2.5 at the FC

level; • Added PM limit to GP 008; • Removed Corn Bin (EU 007-009) associations with CE 019 and SV 005 since they are

uncontrolled;


• Added hood capture requirements to grain handling operations (SV 005), and DDGS (SV016). • Added language for SV 005 and SV 016 for hood certification that requires the facility to account

for cross drafts; • Added Beer Feed Rate throughput limit for SV 018; • Added PM2.5 requirements to SV 019; • Updated performance testing language for SV 018 and SV 019; • Collection and Capture Efficiencies added to SV 018 and SV 019; • Fully removed Golden Lyk operations from permit. SV024, CE026, EU077-082; • Added GP 013 for Post-1969 Industrial Process Equipment; • Changed FS 004 into an emission unit EU 092 because the ethanol loadout was not a fugitive

source. EU 092 is now a part of GP 013; • Submittal with schedule added to FC for updated Gl-05b, and GI-07 forms; • Added limit for sodium bilsulfite and ammonium bisulfite to scrubber CE 020. Tthe pre scrubber

(CE 029) reuses water from the main scrubber, and as such no additives are added to CE 029; • Added a new fermentation tank EU 091 that vents through CE 020, CE 029, and SV 018; • New yeast propagation tank EU 088 is now controlled by CE 027; • Removed Tank EU 017; • Added Performance Testing requirements to SV 018 for tests to be conducted after any change

to the source of scrubber water; • Updated/Added modeling parameters from the most recent approved protocol, and a

performance testing plan to the Appendix of the permit.

See list in Attachment 4 for an overview of other changes made during this permit action, and planned changes for permit reissuance.

1.5 Facility Emissions: Table 2. Total Facility Potential to Emit Summary

PM tpy

PM10

tpy PM2.5 tpy

S02

tpy NO„ tpy

CO Tpy

C02e tpy

VOC tpy

Single HAP tpy

All HAPs tpy

Total Facility Limited Potential Emissions

78.12 49.00 43.43 0.45 29.71 87.87 173,871 54.50 9.4 11.9

Total Facility Actual Emissions (2013)

34.13 30.47 29.03 0.23 31.39 27.62 * 35.45 *

* Not reported in MN emission inventory.

Table 3. Facility Classification Classification Major Synthetic Minor/Area Minor/Area

PSD PM, PM10, PM2 5, CO, VOC

NOx, S02

Part 70 Permit Program PM10, PM2.5, NOX, CO, VOC

S02

Part 63 NESHAP X 2. Regulatory and/or Statutory Basis


New Source Review DENCO II currently operates under a permit which limits all NSR pollutants (other than GHG) to less than 100 tons per year, and the PTE remains less than 100 tons per year under the permit so that all NSR regulated air pollutants emitted from the facility are less than the major source thresholds for NSR (40 CFR § 52.21(b)(1)).

Definition of major stationary source 40 CFR § 52.21(b)(l)(i) defines a major stationary source for NSR as a stationary source that has the potential to emit (PTE) of 250 tpy or more of a regulated NSR pollutant or 100 tpy or more of a regulated NSR pollutant for those facilities that are listed in 40 CFR § 52.21(b)(l)(iii). Chemical Process plants are a listed facility as follows:

• 52.21 (b)(1)(iii)(t) Chemical process plants—The term chemical processing plant shall not include ethanol production facilities that produce ethanol by natural fermentation included in NAICS codes 325193 or 312140;

In May of 2007, US EPA promulgated a change to the federal PSD regulation changing the major source threshold for a fuel- ethanol plant from 100 to 250 tons per year.

Part 70 Permit Program The facility is and remains a nonmajor source under the Part 70 permit program.

New Source Performance Standards (NSPS) Due to the proposed changes not incurring a capital expenditure, 40 CFR pt. 60, subp. VV will not be updated by 40 CFR pt. 60, subp. VVa as a part of this permit action.

National Emission Standards for Hazardous Air Pollutants (NESHAP) The facility has accepted limits on HAP emissions such that it is an area source under 40 CFR pt. 63. Thus, no major source NESHAPs apply. In addition, the Permittee has stated that no area source NESHAPs apply to the proposed changes.

Compliance Assurance Monitoring (CAM) DENCO II is not a major source under the federal Part 70 operating permit regulation; therefore, CAM does not apply.

Environmental Review & Air Emissions Risk Analysis (AER A) The facility has accepted limits on production such that it is not subject to environmental review, i.e. an Environmental Assessment Worksheet (EAW), and is not required to perform an AERA.

Minnesota State Rules The proposed changes are subject to the following Minnesota Standards of Performance:

• Minn. R. 7011.0715 Standards of Performance for Post-1969 Industrial Process Equipment Table 4. Regulatory Overview of Units Affected by the Modification/Permit Amendment

Subject Item* Applicable Regulations Rationale

Technical Support Document, Permit Action Number: 14900013 -006 Page 4 of 12

Subject Item* Applicable Regulations Rationale

CE029 Title 1 Condition: Avoid major source under 40 CFR 52.21(b)(l)(i) and Minn. R. 7007.3000; To avoid major source under 40 CFR 70.2 & Minn. R. 7007.0200

New pre-scrubber added in series previous to the existing scrubber (CE020).

Removed: EU016, EU017 EU051, EU068 Added: EU088, EU089, EU090

See SV018, CE020, and CE029 for applicable regulations

Existing yeast propagation tanks, EU016 and EU017, replaced by new yeast propagation tank, EU 088.

Existing stripper, EU 051, replaced by a new beer column, EU 089.

Existing rectifier, EU 090, replaced by new rectifier, EU 068.

No increase in emission from replacements and existing rules/language have been carried over identically for the new units.

FC Minn. Stat. Section 116.07, subds. 4a & 9; Minn. R. 7009.0020; Minn. R. 7007.0100, subp. 7(A), 7(L), & 7(M); Minn. R. 7007.0800, subp. 2

Title 1 Condition: Avoid major source under 40 CFR 52.21(b)(l)(i) and Minn. R. 7007.3000; To avoid major source under 40 CFR 70.2 & Minn. R. 7007.0200

Added process throughput limit of 322,000 tons/year of corn. This is based on calculations submitted.

Grain received by the facility shall only be used for production of ethanol and coproducts

Added requirement for reissuance. Permit is set to expire in two years.

Added submittal requirement for updated GI-02, GI-03, GI-04, Gl-05A, GI-05B, GI-05C, GI-05D, GI-05F, and GI-07 forms to address discrepancies before reissuance and remodeling.

Added tier 3 modeling requirements for PM2.5 and tier 1 requirements for PM10.

EU091 (Fermenter)


New fermenter unit. Subject to requirements found in SV018, CE029, and CE029.

GP013 (Post 1969 IPER)

Minn. R. 7011.0715 New group for units that were removed from groups they didn't belong in, and for emission units that had no requirements.

SV 018 (Fermentati on and Distillation)


Process Throughput: Less than or equal to 320 gallons/minute. Beer feed rate limit that is set 10% greater than the maximum of what was previously tested.

^Location o :the requirement in the permit (e.g., EU, SV, GP, etc.).

The language 'This is a state -only requirement and is not enforceable by the U.S. Environmental Protection Agency (EPA) Administrator and citizens under the Clean Air Act' refers to permit


requirements that are established only under state law and are not established under or required by the federal Clean Air Act. The language is to clarify the distinction between permit conditions that are required by federal law and those that are required only under state law. State law-only requirements are not enforceable by the EPA or by citizens under the federal Clean Air Act, but are fully enforceable by the MPCA and citizens under provisions of state law.

3. Technical Information

3.1 Calculations of Potential to Emit Attachment 1 to this TSD contains an emissions summary, and calculations for the various processes at the facility. Discrepancies such as, calculating SV016 over permitted limits due to the wrong throughput number being used, and incorrect emission unit listings can be found throughout the calculations. Since there will be no emissions increase from the proposed changes, and the project is on a very strict deadline, it was decided that these issues would be addressed by requiring the Permittee to submit a new facility description and facility emissions summary 6 months after the issuance of this permit. That updated information will be used to fully address the discrepancies issues during the next reissuance.

3.2 Dispersion Modeling MPCA policy required DENCO II to complete air dispersion modeling to show modeled compliance with the PM10 and PM2.5 national ambient air quality standards (NAAQS). Several operating restrictions were assumed when the modeling was conducted. These have been incorporated as permit limits in the permit. In addition, per MPCA practice, a table of the modeled parameters has been added to the permit as an appendix. Other than the specific operating restrictions mentioned above, the parameters listed in Appendix I of the permit describe the operation of the facility at maximum allowed emissions. The MPCA does not require any specific compliance demonstration with these parameters because they are worse-case conditions. The purpose of listing the parameters in the permit appendix is to provide a benchmark for determining if additional modeling is required at some future time.

The total ambient air impact of Denco II plus other sources and background (24-hour average and Annual) can be seen below. Based on MPCA practice for requiring remodeling for future changes (see below), remodeling for PM2.5 will follow Tier 3 requirements. PM10 is subject to Tier 1 requirements (generally no automatic remodeling).

Table 5. Modeling Results

Averaging Period NAAQS (ug/m3)

Modeled NAAQS Impact

Concentrations (ug/m3)

% of NAAQS

PM10 24-hour 150 105.82 71.00%

PM10 Annual 50 27.05 54.00%

PM2.5 24-Hour 35 3.95 91%

PM2.5 Annual 15 12.59 84.00%

Table 6.


% of NAAQS/MAAQS: > 90% 90% - 75% < 75%

Allowable Growth Level: Low Medium High PSD - Limits Tier 4 Tier 2** Tier 1 PSD - No Limits Tier 3 Tier 2** Tier 1

Not PSD - Limits Tier3** Tier 2** Tier 1 Not PSD - No Limits Tier 1 Tier 1 Tier 1

*Refer to Requirement Guidance in Delta for permit language for each tier, o Tier 1. Parameter documentation only (no re-modeling); o Tier 2. Parameter documentation and submittal/approval for major/moderate

amendment levels; o Tier 3. Parameter documentation and submittal/approval major/moderate/minor

amendment levels w/an evaluation at reissuance that addresses changes that didn't need an amendment; and

o Tier 4. Parameter documentation and submittal/approval for all changes. **The default tier is listed in the table and footnotes; however, individual permit teams may decide on a case-by-case basis to require a di fferent level of modeling than stated in the table for these noted scenarios. Some things to consider in deciding on when to re-evaluate and/or when to submit and/or require MPCA approval for changes:

• How likely the facility is to make modifications that would increase the PTE of the pollutant(s) that was/were modeled;

• Does the facility make routine changes to units/sources that have low emissions but poor dispersion (e.g., heat recovery, fugitives);

• Does the permit already prohibit the facility from increasing emissions of the modeled pollutant(s) without first going through a permit amendment? For example, if they have a state synthetic minor permit, they cannot make any change that makes them cross the Part 70 threshold without getting the permit amendment first;

• Was the modeled required by a ru le or was the decision to complete it based on policy or some case-by-case decision;

• How well do the operating assumptions used in the modeling resembling how the facility actually operates; and

• Does the facility have a wide range of growth levels for one pollutant.

The most recent modeling parameters that were used reflect the outdated information of the facility description, and facility emissions summary. There are also discrepancies with the exit temperatures and exit velocities as it appears some non-standard practices were used in a few instances (negative exit temperatures and 0.001 exit velocities on vertical release stacks). The parameters have been included as Appendix I to the permit.

3.3 Monitoring In accordance with the Clean Air Act, it is the responsibility of the owner or operator of a facility to have sufficient knowledge of the facility to certify that the facility is in compliance with all applicable requirements. In evaluating the monitoring included in the permit, the MPCA considered the following:

• the likelihood of the facility violating the applicable requirements;


• whether add-on controls are necessary to meet the emission limits; • the variability of emissions over time; • the type of monitoring, process, maintenance, or control equipment data already available for

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

The table below summarizes the monitoring requirements associated with this amendment.

Table 7. Monitoring

Subject Item* Requirement (rule basis) Monitoring Discussion

FC (Total Facility)

Process Throughput: < 322,000 tpy using 12-month rolling sum of corn

(Title 1 Condition: Avoid major source under 40 CFR 52.21(b)(l)(i) and Minn. R. 7007.3000; To avoid major source under 40 CFR 70.2 & Minn. R. 7007.0200)

Daily and monthly grain throughput recordkeeping

This is the current design capacity of the facility and is used as the basis of the calculations. Grain received by the facility shall only be used for production of ethanol and coproducts. The facility may not operate as a storage facility for grain (i.e. receive, store, sell). Monthly calculation and recordkeeping of ethanol production is required by the 15th day of each month for the previous month and provides a direct determination of compliance with the 12-month rolling sum limit.

FC (Total Facility)

Equivalent or Better Dispersion (EBD) analysis or revised dispersion modeling required for significant PM2.5 increases.

(Modeling Limit -Minn. Stat. 116.07, subds. 4a & 9)

Modeling parameters are contained within Appendix II of the permit.

This requirement is to ensure compliance with NAAQS every time the facility makes a change that affects emissions rates as described in the permit. The permit contains triggers for Equivalent or Better Dispersion (EBD) analyses or remodeling based upon

the type PM2.5 increase at the facility. The facility will conduct an EBD analysis every 5 years to assess any increases in PM2.5 emissions that did not trigger an EBD analysis at the time of the change. See dispersion modeling section 3.2 above for further

discussion.


Requirement Subject Item* (rule basis) Monitoring Discussion CE 020 Liquid flow rate: Monitoring Added a limit for additive flow rate to the main (Scrubber) > 110 mL/min of equipment scrubber. This was missing from previous permit

either sodium installation, actions. The pre-scrubber uses water from the main bisulfite or maintenance, and scrubber so the pre-scrubber does not have an ammonium calibration. Daily additive limit. bisulfite inspection and

recordkeeping. The Permittee shall use de-ironed well water for the Water Supply Water source change scrubbers. The Permittee may also use reverse Source: De-ironed notification osmosis reject water after notifying the MPCA of the well water changes.

(Title 1 Condition: EU 091 (Fermenter) is controlled by CE 020. Avoid major source under 40 CFR 52.21(b)(l)(i) and Minn. R. 7007.3000; To avoid major source under 40 CFR 70.2 & Minn. R. 7007.0200)

CE029 (Pre- 5.0<AP<15.0 Daily pressure and This scrubber is being added in series to the original Scrubber) inches of water flow rate monitoring scrubber. This will result in increased pollution

column and recordkeeping, control as no emissions increase will occur as a result corrective actions, of the permit action. This along with extensive

Water flow rate: monitoring performance testing should ensure that all applicable > 90 gallons/min equipment, periodic requirements are complied with. of recirculating inspections, water monitoring EU 091 (Fermenter) is controlled by CE 029.

calibration, O&M Water flow rate: > 2.5 gallons/min output to beer well



Subject Item* Requirement (rule basis) Monitoring Discussion

EU 091 (Fermenter)

Process Throughput: < 320 gpm using 8hour block average Beer Feed Rate

VOC < 5.0 lbs/hour using 3hour avg on a total mass basis


Performance testing before and after installation of EU 091.

Requirements for the fermentation and distillation process at the facility can be found at SV018, CE020, and CE029. The addition of EU 091, which will not result in an increase of emissions, should not impact compliance with the applicable requirements. Performance testing before and after the installation of the fermenter will ensure that all applicable limits are met.

GP 013 (Post 1969 IPER)

Total PM £ 0.30 grains/dscf

Opacity < 20 percent opacity

(Minn. R. 7011.0715)

N/A Emission units in this group (EU007-009, EU067, EU086, EU087) meet this rule by design.

SV 018 (Fermentation and Distillation)

Process Throughput: < 320 gpm using 8hour block average Beer Feed Rate

(Title 1 Conditions)

Performance Testing Performance testing before and after installation of the new fermenter as well as testing for any increase to the beer feed throughput (measured at the discharge pump of the beer wells) should ensure compliance with the applicable limits.

EU 091 (Fermenter) was added as an associated item to SV 018.

*Location of the requirement in the permit (e.g., EU, SV, GP, etc.).

3.4 Permit Organization In general, the permit meets the MPCA Delta Guidance for ordering and grouping of requirements. One area where this permit deviates slightly from Delta guidance is in the use of appendices. While appendices are fully enforceable parts of the permit, in general, any requirement that the MPCA thinks should be electronically tracked (e.g., limits, submittals, etc.), should be in Table A or B of the permit. The main reason is that the appendices are word processing sections and are not part of the electronic tracking system. Violation of the appendices can be enforced, but the computer system will not automatically generate the necessary enforcement notices or documents. Staff must generate these.


This permit uses an appendix for modeling parameters and stack test methods and parameter recordkeeping requirements.

Organizational issues, such as where you can expect to find certain requirements (SV vs. CE), were found throughout the permit as a result of compounding mistakes from previous permit actions. Some of these issues can be seen outlined in Bonnie's list of notes and comments that can be found as Attachment 4 to this TSD, and will be addressed at the later reissuance date due to the strict deadline of this current permit action. Some of these issues were addressed with this permit action in order for the permit to at least make some sense. Those changes can be founded listed above in section 1 of this TSD.

3.5 Comments Received Public Notice Period: 08/16/2015-09/14/2015 EPA 30-day Review Period: 08/16/2015 - 09/14/2015

No comments were received, and as a result no changes were made to the permit.

4. Permit Fee Assessment Attachment 3 to this TSD contains the MPCA's assessment of Application and Additional Points used to determine the permit application fee for this permit action as required by Minn. R. 7002.0019. The permit action includes two permit applications, both received after the effective date of the rule (July 1, 2009). The Administrative Amendment and Major Amendment have both been paid for, and additional points were assed for the permit action because of limits to avoid PSD and PT. 70. Please see attachment 3 for further points details.

5. Conclusion Based on the information provided by DENCO II, LLC, the MPCA has reasonable assurance that the proposed operation of the emission facility, as described in the Air Emission Permit No. 14900013-006 and this TSD, will not cause or contribute to a violation of applicable federal regulations and Minnesota Rules.

Staff Members on Permit Team:

AQ File No. 2322; DQ 5271, 4728

Robert Little (permit engineer) Bonnie Nelson (permit engineer) Carolina Schutt (permit supervisor) Janice Noggle (enforcement) Tarik Hanafy (peer reviewer) Beckie Olson (permit writing assistant) Laurie O'Brien (administrative support)

Attachments: 1. Calculation Spreadsheets 2. Facility Description and CD-01 Forms 3. Points Calculator 4. Permit Notes to be Addressed Now or Later


DENCO II, LLC 14900013-006

Attachment 1 Emission Calculation Spreadsheets

DENCO II, LLC Limited Potential Emissions @30 million gallons ethanol production

Stack/ Control Emission Criteria Pollutants (Limited Emissions) Vent Equipment Unit Emission Sources Associated with PM PM10 PM2.5 S02 NOx VOC CO ID ID ID Ethanol Operations (tPV) (tpy) (tpy) (tpy) (tpy) (tpy) (tpy)

SV001 ... EU001 Boiler 0.78 0.78 0.78 0.07 GP001 0.57 8.58 SV002 ... EU002 Boiler 0.78 0.78 0.78 0.07 GP001 0.57 8.58 SV005 CE019 EU005 Corn Dump Pit/Auqer SV005 SV005 SV005 ... ... SV005 CE019 EU006 Corn Elevator SV005 SV005 SV005 SV005 CE019 EU010 Scalper SV005 SV005 SV005 ... — SV005 — SV005 Limited Emissions from Grain/DDGS Handlinq 2.01 2.01 2.01 ... SV026 — EU007 Corn Bin 1 L_ 2.46 0.25 0.18 — ... ... ... SV005 — EU008 Com Bin 2 (Surqe Bin) SV005 SV005 SV005 ... SV005 ... EU009 Corn Bin 3 2,46 0.25 0.18 ... — ... ... SV027 ... EU086 Corn Bin 4 2.46 0.25 0.18 — ... ... SV028 EU087 Corn Bin 5 2.46 0.25 0.18 ... ... SV016 CE018 EU055 DDGS Storaqe Pile SV016 SV016 SV016 ... ... ... SV016 CE018 EU056 DDGS Dump Pit/Auqer SV016 SV016 SV016 ... ... ... SV016 CE018 EU057 DDGS Elevator SV016 SV016 SV016 ... ... — SV016 CE018 EU058 Truck Load Spout 2 SV016 SV016 SV016 ... ... SV016 _. SV016 Limited Emissions from DDGS Handlinq 0.48 0.48 0.48 ... SV017 EU059 Boiler #3 1.90 1.90 1.90 0.17 GP001 1.38 21.02 SV018 CE020 1 "i ̂ •vEy016-;:"« Fermenter#! '.-v-' ... ... — SV018 SV018 CE020.C •: :EU017 F&rmentor #2V<.;<.! ... — ... SV018 SV018 CE020 •" > EU061 Fermenter #3 ... SV018 SV018 CE020 -. i - v EU062 Fermenter #4 — ... SV018 ... SV018 CE020 -: ; • EU063 Fermenter #5 ... ... SV018 SV018 CE020 :: EU064 Beer Well #1 ... ... ... SV018 ... SV018 CE020v i EU065 Beer Well #2 ... ... ... SV018 ... SV018 CE020. ";-E-UG61 Stripper = ... ... SV018 ... SV018 CE020.C; t;..-EU068 Rectify©? ^-vv^vr ... — SV018 ... SV018 CE020 :> i-;<\ EU069 Side Stripper SV018 ... SV018 CE020 a EU070 Molecular Sieve — ... SV018 SV018 ... SV018 Limited Emissions from Process Scrubber ... ... — — 21.90 ... SV019 CE021 EU066 DDGS Dryer 31.14 31.14 31.14 0.11 GP001 10.95 48.18 SV019 CE027 EU083 RTO SV019 SV019 SV019 0.02 GP001 SV019 SV019 SV020 CE023 EU067 Bio-diqester 0.00 0.00 0.00 0.01 0.09 0.01 0.49 SV021 CE024 EU060 Hammermill 2.19 2.19 2.19 — ... ... ... SV022 CE025 EU 071 Cyclone Cooler 1.31 1.31 1.31 __ 5.26 SV023 CE025 EU076 Loadout Flare 0.07 0.07 0.07 0.01 0.92 6.58 1.00 SV025 CE029 EU084 Hammermill #2 EU060 EU060 EU060 ._ ...

— — GP001 NOx Group Emissions _. 28.70 ... ... — — TK001 Ethanol Tank — 0.03 ...

... TK002 Ethanol Tank ... ... 0.03 ... — TK003 Ethanol Tank — ... 0.03 ...

TK004 Ethanol Tank — — ... 0.03 ... ... ... TK005 Gasoline ... ... — — 0.03 ... ~ TK006 Ethanol Tank — ... 0.00 —

... TK007 Ethanol Tank ... ... 0.00 ... ... TK011 Denatured Ethanol Storaqe Tank #1 ... ... ... ... 0.06 —

TK014 Denatured Ethanoi Storaqe Tank #2 ... _. 0.08 ... ... ... FS001 Truck Traffic 2.39 0.48 0,12 ... ... ... ... FS002 Uncaptured Grain handlinq emissions 7.21 2.02 0.32 ... ... ... ...

... FS003 DDGS handlinq emissions 13.39 2 71 0.46 ... ... ... — — FS004 Ethanol Loadinq Rack ... — — — ... EU072 — ... FS005 Equipment Leaks — _ 6.99 ...

— ... FS006 Coolinq Towers 1.42 0.99 0.99 ... ... ... ... ... FS007 Flat Storaqe 3.23 1.13 0.17 _ ... ...

TOTAL 78.12 49.00 43.43 0.45 29.71 64.£o SOURCE-WIDE EMISSION CAP 95.00 95.00 95.00 95.00 95.00 95.00 95.00

CE029 - Prefen nes'ihlion Scrubber ackiod in process nne before? esvufjs\oi\>> emer C&02Q (F'^rmaniatlon Scrubber;

DENCO II, LLC RTO Combustion Calculations (Postmodification)

RTO (EU080) Firing Capacity: 8,000,000 BTU/hr 5.16%

Primary Fuel Type: Heat Value: Fuel Burning Capacity:

Natural Gas 1,050 7,619

BTU/cf cf/hr

Pollutant Emission

Factor (Ib/cf)

Emission Rate (Ib/hr)

Max. Uncontrolled Emissions (tons/yr)

Pollution Control

Efficiency (%)

Max. Controlled Emissions (tons/yr)

PM 0.0000076 0.06 0.25 0.00 0.25 PM10 0.0000076 0.06 0.25 0.00 0.25 SOx 0.0000006 0.00 0.02 0.00 0.02 NOx 0.0000381 0.29 1.27 0.00 1.27 VOC 0.0000055 0.04 0.18 0.00 0.18 CO 0.0000840 0.64 2.80 0.00 2.80

All emission factors, except Nox, from Fifth Edition AP-42, Section 1.4, "Natural Gas

Example Calculations: 0.0000076 lb PM/cf • 7 ,619 cf/hr = 0.06 Ib/hr 0.06 Ib/hr • 8760 hr/yr -ton/2000 lb = 0.25 tpy

Back-up Fuel Type: Propane Heat Value: 91,500 BTU/gal Fuel Burning Capacity: 87 gal/hr

Max. Pollution Max. Emission Emission Uncontrolled Control Controlled

Pollutant Factor Rate Emissions Efficiency Emissions (lb/gal) (Ib/hr) (tons/yr) (%) (tons/yr)

PM 0.0006 0.05 0.23 0.00 0.23 PM10 0.0006 0.05 0.23 0.00 0.23 SOx 0.0001 0.01 0.04 0.00 0.04 NOx 0.0073 0.64 2.80 0.00 2.80 VOC 0.0005 0.04 0.19 0.00 0.19 CO 0.0032 0.28 1.23 0.00 1.23

All emission factors, except for NOx, from Fifth Edition AP-42, Section 1.5, "Liquefied

Example Calculations: 0.0006000 lb PM/gal • 8 7 gal/hr = 0.05 Ib/hr 0.05 Ib/hr • 8760 hr/yr -ton/2000 lb = 0.23 tpy

Maximum Controlled Emission Summary Max.

Pollutant Controlled Emissions (tons/yr)

PM 0.25 PM10 0.25 SOx 0.02 NOx 1.48 VOC 0.18 CO 2.80

Page 11 of 23

DENCO II, LLC DDGS Dryer

Particulate Emissions

Assumptions •Since no particulate size distribution data is available for the dryer exhaust, assume PM10/PM2.5 emissions equal PM emissions. •Particulate emissions from both process and combustion are included in the permit limit. •Regenerative Thermal Oxidizer particulate control efficiency: 60%

Process Data Total DDGS feed to dryer (solids only): 17,500 Ib/hr Solids Concentration: 35% by weight Water Concentration: 65% by weight

E =3.59 * (P + 2,000)A0.62 (Equation from MN Rules 7011.0730, Table 1)

where P = dry process weight rate in Ib/hr (subtract any water or moisture content) E = particulate emission rate in Ib/hr

E, particulate emission rate = 3.59 * (17,500 Ib/hr + 2,000)A0.62 = 13.78 Ib/hr Potential PM emissions = 13.78 Ib/hr * 1 ton/2,000 lb * 8,760 hr/yr = I 60.34 ton/yr Controlled PM/PM10/PM2.5 emission rate = 13.78 Ib/hr • (1 - 0.60) = 5.51 Ib/hr

= 24.14 ton/yr

Original Proposed PM/PM10 Limit: 5.00 Ib/hr 21.90 tons/year

January 2004 Stack test re 2.80 Ib/hr = 12.25 tpy Revised* proposed PM/PM10/PM2.5 Limit= l

l

-t 11 31.14 tpy

* Emission Limit has been revised on August 10, 2004 to demonstrate that the change in emissions less than 15tpy with the October 2003 Major Modification Application.

VOC Emissions

Assumptions • Regenerative Thermal Oxidizer VOC control efficiency: 95%

RTO inlet loading based on stack testing: 50.00 Ib/hr

Potential VOC emissions = 50.00 Ib/hr ethanol (VOC) • 8,760 hr/yr • 1 ton/2000 lb = | 219.00 ton /yr Controlled VOC emission rate = 50.00 Ib/hr • ( 1 - 0.95) = 2.50 Ib/hr

= 10.95 ton/yr

CO Emissions

Assumptions • Regenerative Thermal Oxidizer CO control efficiency: 90%

RTO inlet loading based on stack testing: 50.00 Ib/hr

Potential CO emissions = 50.00 Ib/hr CO • 8,760 hr/yr • 1 ton/2000 lb = I 219.00 ton/yr I Controlled CO emission rate = 50.00 Ib/hr • ( 1 - 0.90) = 5.00 Ib/hr

= 21.90 ton/yr

Proposed Permitted CO Limit: 11.00 Ib/hr 48.18 tons/year

DENCO II, LLC Grain Receiving, Cleaning, and Hammermilling Emission Calculations (Postmodification)

Assumptions • Only grain for ethanol operations is processed through cleaning and hammermilling equipment. • All grain is c orn which has the highest Dustiness Ratio for the AP-42 emission factors.

Additional Information The Corn Bins (EU007-009) had previously been permitted as being controlled by the Grain Receiving Baghouse (SV005, CE019). This is not the case for the existing or proposed grain bins. The calculations below reflect the change in control efficiency for these sources.

Process Data Grain Required for 30.00 MMgal EtOH: Ethanol Grain Density: Total Grain Receiving Throughput: Short Term Grain Receiving Throughput (facility maximum based on MPCA records for unloading conveyer) Dryer Solids rate (solids only - no moisture included): DDGS Handling (solids only): DDGS Handling (facility maximum): Emission Calculation Method Uncontrolled Potential Emissions = Throughput (ton/hr) • E mission Factor (lb/ton)

11.5 MM bushels/yr = 11,500,000 bu/yr 56 lb/bushel

322,000 ton/yr = 36.8 ton/hr 130.0 ton/hr

17,500 Ib/hr-2000 lb/ton = 17,500

8.75 84

Ib/hr ton/hr ton/hr

3,760 hr/yr • 1 ton/2000 lb

PM Emissions from Grain Receiving, Cleaning, and Hammermilling AP-421 Uncontrolled Controlled

Emission Emission PM Control PM Unit Emission Throughput Factor Emissions Capture Equipment Emissions ID Source (ton/hr) (lb/ton) (Ib/hr) (tpy) Efficiency Efficiency (tpy) (Ib/hr)

EU005 Corn Dump Pit/Auger (Grain Receiving by Hopper Truck) 36.8 0.035 1.29 5.64 80% 99% 0.05 0.01 EU006 Grain Elevator (Headhouse and Internal Handling) 36.8 0.061 2.24 9.82 100% 99% 0.10 0.02 EU010 Scalper(Flaker) 36.8 0.770 28.30 123.97 100% 99% 1.24 0.28 EU087 Grain Leg(Headhouse and Internal Handling) 36.8 0.061 2.24 9.82 100% 99% 0.10 0.02 EU088 Grain Leg (Headhouse and Internal Handling) 36.8 0.061 2.24 9.82 100% 99% 0.10 0.02 EU089 Reclaim Leg (Headhouse and Internal Handling) 36.8 0.061 2.24 9.82 100% 99% 0.10 0.02 EU090 Reclaim Leg (Headhouse and Internal Handlinq) 36.8 0.061 2.24 9.82 100% 99% 0.10 0.02 SV005 Grain Handling Totals 31.83 139.43 1.58 0.36 EU056 DDGS Dump Pit/Auger 84.00 0.035 2.94 12.88 80% 99% 0.10 0.02 EU057 DDGS Elevator 84.00 0.061 5.12 22.44 100% 99% 0.22 0.05 EU058 Truck Load Spout 84.00 0.086 7.22 31.64 80% 99% 0.25 0.06 SV016 DDGS Handling Totals 0.182 15.29 66.96 0.58 0.13 EU060, 080 Hammermilling2 36.8 1.2 44.11 193.20 100% 99% 1.93 0.44 EU007, 9 & EU085-86 Corn Bins (Worst Case for modeling) 130.0 0.061 7.93 34.73 100% 0% 34.73 7.93

EU007, 9 & EU085-86 Corn Bins (Average)3 36.8 0.061 2.24 9.82 100% 0% 9.82 2.24

FS002 Uncaptured Emissions From Grain Handling 130.0 0.035 4.55 19.93 20% uncaptured 3.99 0.91 FS003 Uncaptured Emissions From DDGS Handling 84.00 0.182 15.29 66.96 20% uncaptured 13.39 3.06 1. Emission factors taken from AP-42 Section 9.9.1,6/98. 2. The hammermilling emission factor is for controlled systems. The uncontrolled factor is back-calculated based on the baghouse control efficiency. 3. For individual permitting the grain bin (total) emissions will be divided equally between the 2 existing and 2 proposed grain bins.

DENCO II, LLC Grain Receiving, Cleaning, and Hammermilling Emission Calculations (continued)

PM10 Emissions from Grain Receiving, Cleaning, and Hammermilling

Emission Unit Emission Throughput

AP-42' Emission

Factor

Uncontrolled PM10

Emissions Capture Control

Equipment

Controlled PM10

Emissions ID Source (ton/hr) (lb/ton) (Ib/hr) (tpy) Efficiency Efficiency^ (tpy) (Ib/hr)

EU005 EU006 EU010 EU087 EU088 EU089 EU090

Corn Dump Pit/Auger (Grain Receiving by Hopper Truck) Grain Elevator (Headhouse and Internal Handling) Scalper(Flaker) Grain Elevator (Headhouse and Internal Handling) Grain Elevator (Headhouse and Internal Handling) Reclaim Leg (Headhouse and Internal Handling) Reclaim Leq (Headhouse and Internal Handlinq)

36.8 36.8 36.8 36.8 36.8 36.8 36.8

0.0078 0.034 0.075 0.034 0.034 0.034 0.034

0.29 1.25 2.76 1.25 1.25 1.25 1.25

1.26 5.47

12.08 5.47 5.47 5.47 5.47

80% 100% 100% 100% 100% 100% 100%

99% 99% 99% 99% 99% 99% 99%

0.01 0.05 0.12 0.05 0.05 0.05 0.05

0.00 0.01 0.03 0.01 0.01 0.01 0.01

SV005 Grain Handling Totals 4.29 18.80 0.35 0.08 EU056 EUD57 EU058

DDGS Dump Pit/Auger DDGS Elevator Truck Load Spout

84.00 84.00 84.00

0.0078 0.034 0.029

0.66 2.86 2.44

2.87 12.51 10.67

80% 100% 80%

99% 99% 99%

0.02 0.13 0.09

0.01 0.03 0.02

SV016 DDGS Handling Totals 0.071 5.9S 26.05 0.23 0.05 EU060, 080 Hammermilling2 36.8 1.2 44.11 193.20 100% 99% 1.93 0.44 EU007, 9 & EU086-87

Corn Bins (Worst Case for modeling) 130.0 0.0063 0.82 3.59 100% 0% 3.59 0.82

EU007, 9 & EU086-87 Corn Bins (Average)3 36.8 0.0063 0.23 1.01 100% 0% 1.01 0.23

FS002 FS003

Uncaptured Emissions From Grain Handling Uncaptured Emissions From DDGS Handlinq

130.0 84.0

0.0078 0.037

1.01 3.09

4.44 13.54

20% 20%

uncaptured uncaptured

0.89 2.71

0.20 0.62

1. Emission factors taken from AP-42 Section 9.9.1, 6/98. 2. The hammermilling emission factor is for controlled systems. The uncontrolled factor is back-calculated based on the baghouse control efficiency. 3. For individual permitting the grain bin (total) emissions will be divided equally between the 2 existing and 2 proposed grain bins.

DENCO II, LLC Grain Receiving, Cleaning, and Hammermilling Emission Calculations (continued)

PM2.S Emissions from Grain Receiving, Cleaning, and Hammermilling

Emission Unit Emission Throughput

AP-42' Emission

Factor

Uncontrolled PM2.5

Emissions Capture Control

Equipment

Controlled PM2.5

Emissions ID Source (ton/hr) (lb/ton) (Ib/hr) (tpy) Efficiency Efficiency (tpy) (Ib/hr)

EU005 EU006 EU010 EU087 EU088 EU089 EU090

Corn Dump Pit/Auger (Grain Receiving by Hopper Truck) Grain Elevator (Headhouse and Internal Handling) Scalper(Flaker) Grain Leg (Headhouse and Internal Handling) Grain Leg (Headhouse and Internal Handling) Reclaim Leg (Headhouse and Internal Handling) Reclaim Leq (Headhouse and Internal Handlinq)

36.8 36.8 36.8 36.8 36.8 36.8 36.8

0.0013 0.0058 0.075 0.0059 0.0059 0.0059 0.0059

0.05 0.21 2.76 0.22 0.22 0.22 0.22

0.21 0.93

12.08 0.95 0.95 0.95 0.95

80% 100% 100% 100% 100% 100% 100%

99% 99% 99% 99% 99% 99% 99%

0.00 0.01 0.12 0.01 0.01 0.01 0.01

0.00 0.00 0.03 0.00 0.00 0.00 0.00

SV005 Grain Handling Totals 3.02 13.22 0.15 0.03 EU056 EU057 EU058

DDGS Dump Pit/Auger DDGS Elevator Truck Load Spout

84.00 84.00 84.00

0.0013 0.0058 0.0049

0.11 0.49 0.41

0.48 2.13 1.80

80% 100% 80%

99% 99% 99%

0.00 0.02 0.01

0.00 0.00 0.00

SV016 DDGS Handling Totals 1.01 4.42 0.04 0.01

EU060, 080 Hammermilling2 36.8 1.2 44.11 193.20 100% 99% 1.93 0.44 EU007, 9 & EU086-87

Corn Bins (Worst Case for modeling) 130.0 0.0011 0.14 0.63 100% 0% 0.63 0.14

EU007. 9 & EU086-87 Com Bins (Average)3 36.8 0.0011 0.04 0.18 100% 0% 0.18 0.04

FS002 FS003

Uncaptured Emissions From Grain Handling Uncaptured Emissions From DDGS Handling

130.0 84.0

0.0013 0.006

0.17 0.52

0.74 2.28

20% 20%

uncaptured uncaptured

0.15 0.46

0.03 0.10

1. Emission factors taken from AP-42 Section 9.9.1, 6/98. 2. The hammermilling emission factor is for controlled systems. The uncontrolled factor is back-calculated based on the baghouse control efficiency. 3. For individual permitting the grain bin (total) emissions will be divided equally between the 2 existing and 2 proposed grain bins.

SV005 PM/PM10 Emission Limit: 0.46 lb PM/hr = 2.01 ton PM/yr SV016 PM/PM10 Emission Limit: 0.11 lb PM/hr = 0.48 ton PM/yr

DENCO II, LLC Temporary Flat Storage

Assumptions: - All emissions are fugitive. - Material moisture content will be closer to 15.5%, however, we have conservatively assumed 4.8%. - Thoughput will be 188 ton/hr for grain dropping. - Only one operation will take place at a time (loading or reclaim).

£ = £(0.0032

E = emission factor (lb/ton) k = particle size multiplier U = mean wind speed (mph) M = material moisture content (%)

k =

U = M =

1 for TSP 0.35 for PM10

0.053 for PM2.5 15.0 mph (max wind speed for equation) 4.8 % (AP-42 Table 13.2.4-1)

Throughput 188 ton/hr

Average Uncontrolled Emissions Emissions Throughput Emission Factor (lb/ton) (Ib/hr)

Activity (tons) PM PM10 PM2.5 PM PM10 PM2.5

Loading 188 0.00392 0.00137 0.00021 0.737 0.258 0.039 Reclaim 188 0.00392 0.00137 0.00021 0.737 0.258 0.039

Ib/hr

Ind HAP (acetaldehyde)

uncontrol/ed controlfed tpy tpy

SV001 EU001 Boiler #1 SV002 EU002 BoiJer #2 SV017 EU059 Boiler #3 . SV018 CE020, CE029 SV018 Fermentation Scrubber Stack 1.30 37.96 5.69 SV019 CE021, CE027 SV019 VRTO #1 Stack 0.35 30.84 1.54 SV022 NA EU071 Cooling Cyclone 0.50 2.17 2.17 SV023 CE025 EU076 Loadout Flare 0.00 0.03 0.00

Ind HAP (acetaldehyde) Ib/hr tpy tpy

Ind HAP (hexane)

uncontrofled controlled Ib/hr tpy tpy

0.04 0.19 0.19

0.04 0.19 0.19 0.11 0.46 0.46

0.01 0.06 0.06

0.67 6.57 0.33

Ind HAP (hexane) Ib/hr tpy tpy

Ib/hr

0.00 0.00

0.00

1.32 0.70 0.61 0.78

HAPs

uncontrolled controlled tpy

0.01

0.01

0.02 38.90 59.81 2.65 7.70

HAPs tpy

tpy

0.01 0.01 0.02 5.78 3.05 2.65 0.39

SV No. SV001 SVOOl

CENo. Ell No. EUOOl EUOOl

Description Boiler #1 Boiler #1

Pollutant Combustion HAPs

Hexane (comb)

Hexane 1.8 Ib/MMCF AP-42 Section 1.4 2-Methylnaphthalene 2.50E-05 Ib/MMCF AP-42 Section 1.4 3-Methylnaphthalene 1.80E-06 Ib/MMCF AP-42 Section 1.4 7,12-Dimethylbenz(a)anthracene 1.60E-05 Ib/MMCF AP-42 Section 1.4 Acenaphthene 1.80E-06 Ib/MMCF AP-42 Section 1.4 Acenaphthylene 1.80E-06 Ib/MMCF AP-42 Section 1.4 Anthracene 2.40E-06 Ib/MMCF AP-42 Section 1.4 Benz(a)anthracene 1.80E-06 Ib/MMCF AP-42 Section 1.4 Benzene 2.10E-03 Ib/MMCF AP-42 Section 1.4 Benzo(a)pyrene 1.20E-06 Ib/MMCF AP-42 Section 1.4 Benzo(b)fluoranthene 1.80E-06 Ib/MMCF AP-42 Section 1.4 Benzo(g,h,i)perylene 1.20E-06 Ib/MMCF AP-42 Section 1.4 Benzo(k)fluoranthene 1.80E-06 Ib/MMCF AP-42 Section 1.4 Chrysene 1.80E-06 Ib/MMCF AP-42 Section 1.4 Dibenzo(a,h)anthracene 1.20E-06 Ib/MMCF AP-42 Section 1.4 Dichlorobenzene 1.20E-03 Ib/MMCF AP-42 Section 1.4 Fluoranthene 3.00E-06 Ib/MMCF AP-42 Section 1.4 Fluorene 2.80E-06 Ib/MMCF AP-42 Section 1.4 Formaldehyde 2.80E-06 Ib/MMCF AP-42 Section 1.4 lndeno(l,2,3-cd)pyrene 7.50E-02 Ib/MMCF AP-42 Section 1.4 Naphthalene 6.10E-04 Ib/MMCF AP-42 Section 1.4 Phenanathrene 1.70E-05 Ib/MMCF AP-42 Section 1.4 Pyrene 5.00E-06 Ib/MMCF AP-42 Section 1.4 Toluene 3.40E-03 Ib/MMCF AP-42 Section 1.4

Throughput 24.5 24.5

Units MMBtu/hr MMBtu/hr

Emission Factor Units

1.80E+00 Ib/MMCF

Emission Factor Citation

AP-42 Section 1.4 AP-42 Section 1.4

Potential to Emit Uncontrolled Controlled

Ib/hr TPY TPY 0.002 0.01 0.01 0.04 0.19 0.19

SV No. SV002 SV002

CENo. EU No. EU002 EU002



Hexane (comb)


Throughput Units Emission Factor Units Emission Factor Citation Ib/hr TPY TPV 24.5 MMBtu/hr - - AP-42 Section 1.4 0.002 0.01 0.01 24.5 MMBtu/hr 1.80E+00 Ib/MMCF AP-42 Section 1.4 0.04 0.19 0.19

Combustion HAP emission factors for Natural Gas Combustion Hexane 1.8 Ib/MMCF AP-42 Section 1.4 2-Methylnaphthalene 2.50E-05 Ib/MMCF AP-42 Section 1.4 3-Methylnaphthalene 1.80E-06 Ib/MMCF AP-42 Section 1.4 7,12-Dimethylbenz(a)anthracene 1.60E-05 Ib/MMCF AP-42 Section 1.4 Acenaphthene 1.80E-06 Ib/MMCF AP-42 Section 1.4 Acenaphthylene 1.80E-06 Ib/MMCF AP-42 Section 1.4 Anthracene 2.40E-06 Ib/MMCF AP-42 Section 1.4 Benz(a)anthracene 1.80E-06 Ib/MMCF AP-42 Section 1.4 Benzene 2.10E-03 Ib/MMCF AP-42 Section 1.4 Benzo(a)pyrene 1.20E-06 Ib/MMCF AP-42 Section 1.4 Benzo(b)fluoranthene 1.80E-06 Ib/MMCF AP-42 Section 1.4 Benzo(g,h,i)perylene 1.20E-06 Ib/MMCF AP-42 Section 1.4 Benzo(k)fluoranthene 1.80E-06 Ib/MMCF AP-42 Section 1.4 Chrysene 1.80E-06 Ib/MMCF AP-42 Section 1.4 Dibenzo(a,h)anthracene 1.20E-06 Ib/MMCF AP-42 Section 1.4 Dichlorobenzene 1.20E-03 Ib/MMCF AP-42 Section 1.4 Fluoranthene 3.00E-06 Ib/MMCF AP-42 Section 1.4 Fluorene 2.80E-06 Ib/MMCF AP-42 Section 1.4 Formaldehyde 2.80E-06 Ib/MMCF AP-42 Section 1.4 lndeno(l,2,3-cd)pyrene 7.50E-02 Ib/MMCF AP-42 Section 1.4 Naphthalene 6.10E-04 Ib/MMCF AP-42 Section 1.4 Phenanathrene 1.70E-05 Ib/MMCF AP-42 Section 1.4 Pyrene 5.00E-06 Ib/MMCF AP-42 Section 1.4 Toluene 3.40E-03 Ib/MMCF AP-42 Section 1.4

SV No. CENo. SV017 SV017

EU No. EU059 EU059



Hexane (comb)

Throughput Units 60.0 MMBtu/hr 60.0 MMBtu/hr

Combustion HAP emission factors for Natural Gas Combustion Hexane 1.8 Ib/MMCF AP-42 Section 1.4

lylnaphthalene 2.50E-05 Ib/MMCF AP-42 Section 1.4 lylnaphthalene 1.80E-06 Ib/MMCF AP-42 Section 1.4 ylbenz(a)anthrac 1.60E-05 Ib/MMCF AP-42 Section 1.4 ;naphthene 1.80E-06 Ib/MMCF AP-42 Section 1.4 naphthylene 1.80E-06 Ib/MMCF AP-42 Section 1.4 nthracene 2.40E-06 Ib/MMCF AP-42 Section 1.4 ^anthracene 1.80E-06 Ib/MMCF AP-42 Section 1.4 Benzene 2.10E-03 . Ib /MMCF AP-42 Section 1.4 zo(a)pyrene 1.20E-06 Ib/MMCF AP-42 Section 1.4 b)fluoranthene 1.80E-06 Ib/MMCF AP-42 Section 1.4 (g,h,i)perylene 1.20E-06 Ib/MMCF AP-42 Section 1.4 k)fluoranthene 1.80E-06 Ib/MMCF AP-42 Section 1.4 ^hrysene 1.80E-06 Ib/MMCF AP-42 Section 1.4 i(a,h)anthracene 1.20E-06 Ib/MMCF AP-42 Section 1.4 lorobenzene 1.20E-03 Ib/MMCF AP-42 Section 1.4 loranthene 3.00E-06 Ib/MMCF AP-42 Section 1.4 Fluorene 2.80E-06 Ib/MMCF AP-42 Section 1.4 'maldehyde 2.80E-06 Ib/MMCF AP-42 Section 1.4 l,2,3-cd)pyrene 7.50E-02 Ib/MMCF AP-42 Section 1.4 iphthalene 6.10E-04 Ib/MMCF AP-42 Section 1.4 manathrene 1.70E-05 Ib/MMCF AP-42 Section 1.4 Pyrene 5.00E-06 Ib/MMCF AP-42 Section 1.4

Toluene 3.40E-03 Ib/MMCF AP-42 Section 1.4

Emission Potential to Emit Uncontrolled Controlled

Factor Units Emission Factor Citation Ib/hr TPY TPY

- - AP-42 Section 1.4 0.005 0.02 0.02 1.80E-06 Ib/MMCF AP-42 Section 1.4 0.11 0.46 0.46

SV No. CE No. EU No. Description SV018 - - Fermentation Scrubber Stack SV018 - - Fermentation Scrubber Stack SV018 - - Fermentation Scrubber Stack

Pollutant Acetaldehyde Formaldehyde

Methanol

Throughput 8,760 8,760 8,760

Units hrs/yr hrs/yr hrs/yr

Control Potential to Emit Emission Equipment Uncontrolled Controlled Factor Units Efficiency * Emission Factor Citation Ib/hr TPY TPY

1.3 fb/hr 85.0% Engineering Estimate 1.30 37.96 5.69 0.01 Ib/hr 32.5% Engineering Estimate 0.01 0.06 0.04 0.01 Ib/hr 95.0% Engineering Estimate 0.01 0.88 0.04

K Scrubb er efficiency based on guidance from Nebraska Department of Environmental Quality in a memo dated 9/29/08 titled, "Miscellaneous Organic NESHAP (MON) and Ethanol Production."

SV No. CE No. Description Pollutant Throughput Units

SV019 CE021, CE027 VRTO #1 Stack Acetaldehyde 8,760 hrs/yr

SV019 CE021, CE027 VRTO #1 Stack Acrolein 8,760 hrs/yr

SV019 CE021, CE027 VRTO #1 Stack Formaldehyde 8,760 hrs/yr

SV019 CE021, CE027 VRTO #1 Stack Methanol 8,760 hrs/yr

SV019 CE021, CE027 VRTO #1 Stack Combustion HAPs 8 MMBtu/hr

SV019 CE021, CE027 VRTO #1 Stack Hexane (comb) 8 MMBtu/hr

Hexane 1.8 Ib/MMCF AP-42 Section 1.4 2-Methylnaphthalene 2.50E-05 Ib/MMCF AP-42 Section 1.4 3-Methylnaphthalene 1.80E-06 Ib/MMCF AP-42 Section 1.4 7,12-Dimethylbenz(a)anthracene 1.60E-05 Ib/MMCF AP-42 Section 1.4 Acenaphthene 1.80E-06 Ib/MMCF AP-42 Section 1.4 Acenaphthylene 1.80E-06 Ib/MMCF AP-42 Section 1.4 Anthracene 2.40E-06 Ib/MMCF AP-42 Section 1.4 Benz(a)anthracene 1.80E-06 Ib/MMCF AP-42 Section 1.4 Benzene 2.10E-03 Ib/MMCF AP-42 Section 1.4 Benzo(a)pyrene 1.20E-06 Ib/MMCF AP-42 Section 1.4 Benzo(b)fluoranthene 1.80E-06 Ib/MMCF AP-42 Section 1.4 Benzo(g,h,i)perylene 1.20E-06 Ib/MMCF AP-42 Section 1.4 Benzo(k)fluoranthene 1.80E-06 Ib/MMCF AP-42 Section 1.4 Chrysene 1.80E-06 Ib/MMCF AP-42 Section 1.4 Dibenzo(a,h)anthracene 1.20E-06 Ib/MMCF AP-42 Section 1.4 Dichlorobenzene 1.20E-03 Ib/MMCF AP-42 Section 1.4 Fluoranthene 3.00E-06 Ib/MMCF AP-42 Section 1.4 Fluorene 2.80E-06 Ib/MMCF AP-42 Section 1.4 Formaldehyde 2.80E-06 Ib/MMCF AP-42 Section 1.4 lndeno(l,2,3-cd)pyrene 7.50E-02 Ib/MMCF AP-42 Section 1.4 Naphthalene 6.10E-04 lb/MMCF AP-42 Section 1.4 Phenanathrene 1.70E-05 Ib/MMCF AP-42 Section 1.4 Pyrene 5.00E-06 Ib/MMCF AP-42 Section 1.4

Toluene 3.40E-03 Ib/MMCF AP-42 Section 1.4

Control Potential to Emit Emission Equipment Uncontrolled Controlled Factor Units Efficiency Emission Factor Citation Ib/hr TPY TPY 0.352 Ib/hr 95% 110% of April 2011 Stack Test 0.35 30.84 1.54

0.022 Ib/hr 95% 110% of April 2011 Stack Test 0.02 1.93 0.10 0.22 Ib/hr 95% 110% of April 2011 Stack Test 0.22 19.27 0.96

0.088 Ib/hr 95% 110% of April 2011 Stack Test 0.09 7.71 0.39 - - 0% AP-42 Section 1.4 0.001 0.003 0.003

1.80E+00 Ib/MMCF 1 1 o

1 N

p I

0s- AP-42 Section 1.4 0.014 0.06 0.06

BgiglS IMfl

SV No. CE No. EU No. SV022 NA EU071 SV022 NA EU071 SV022 NA EU071 SV022 NA EU071

Description Cooling Cyclone Cooling Cyclone Cooling Cyclone Cooling Cyclone

Pollutant Acetaldehyde

Acrolein Formaldehyde

Methanol

Throughput 8,760 8,760 8,760 8,760

Emission Potential to Emit

Uncontrolled Controlled Units Factor Units Emission Factor Citation Ib/hr TPY TPY hrs/yr 0.50 Ib/hr 110% of Dec. 2010 Stack Test Data 0.50 2.17 2.17 hrs/yr 0.01 Ib/hr 110% of Dec. 2010 Stack Test Data 0.01 0.05 0.05 hrs/yr 0.0B Ib/hr 110% of Dec. 2010 Stack Test Data 0.03 0.14 0.14 hrs/yr 0.07 Ib/hr 110% of Dec. 2010 Stack Test Data 0.07 0.29 0.29

Potential to Emit Emission Emission Factor Uncontrolled Controlled

SV No. CENo. EU No. Description Pollutant Throughput Units Factor Units Citation Ib/hr TPY TPY SV023 CE025 EU076 Loadout Flare VOC(asVOC) 30.0 1000 gal/hr 0.44 lb/1000 gal AP-42 Section 1.4 13.14 131.35 5.57 SV023 CE025 EU076 Loadout Flare VOC (as VOC) 5.5 MMCF natural gas/yr 5.50 Ib/MMCF AP-42 Section 1.4 30.35 0.30 0.02 SV023 CE025 EU076 Loadout Flare VOC (Total) 43.49 131.66 6.58 5V023 CE02S EU076 Loadout Flare Combustion HAPs 0.0147 MMBtu/hr AP-42 Section 1.4 2.69E-0S 2.36E-03 1.18E-04 SV023 CE025 EU07S Loadout Flare Process HAPs NA 0.8% wt % VOC Nebraska DEQ 0.11 1.10 0.05 SV023 CE025 EU075 Loadout Flare Acetaldehyde NA 0.0% wt % VOC Nebraska DEQ 0.00 0.03 0.00 SV023 CE025 EU07S Loadout Flare Hexane (proc) NA 5.0% wt % VOC Nebraska DEQ 0.66 6.57 0.33 SV023 CE025 EU076 Loadout Flare Hexane (comb) 5.5 MMCF natural gas/yr 1.80 Ib/MMCF AP-42 Section 1.4 0.01 0.00 0.00

BllSB —1 W8ZW IK32 1 Assumptions:

Vapors Denatured

Ethanol G

0.03 0.44 Loading losses, lb VOC/IOOO gal

1 1 Saturation Factor 0.48 3.86 True Vapor Pressure, psia

46.07 92 Molecular Weight, Ib/lb-mole 505.39 505.39 Temperature, R

L = 12.45 • S • P • M -r T

where: L = Loading Loss, lb VOC/IOOO gal of liquid loaded S = Saturation Factor (AP-42 Table 5.2-1) P = True Vapor Pressure of Liquid Loaded, psia - EPA TANKs program M = Molecular Weight of Vapors, (b/ib-moie - EPA TANKs program T = Temperature of Sulk Liquid Loaded, R - EPA TANK s program

Flare Control: 95%

Loading Rate (gpm): 500

Limited loading Rate (MMgpy): 30.0

Firing Rate: 0.0147 MMBtu/hr

HAPs Emission Factors for Natural Gas Combustfon Hexane 1.8 Ib/MMCF AP-42 Section 1.4 2-Methylnaphthalene 2.50E-05 Ib/MMCF AP-42 Section 1.4 3-Methylnaphthaiene 1.80E-06 Ib/MMCF AP-42 Section 1.4 7,12-Dimethylbenz(a)anthra 1.60E-05 Ib/MMCF AP-42 Section 1.4 Acenaphthene 1.80E-06 Ib/MMCF AP-42 Section 1.4 Acenaphthylene 1.80E-06 Ib/MMCF AP-42 Section 1.4 Anthracene 2.40E-06 Ib/MMCF AP-42 Section 1.4 Benz(a)anthracene 1.80E-06 fb/MMCF AP-42 Section 1.4 Benzene 2.10E-03 Ib/MMCF AP-42 Section 1.4 Benzo(a)pyrene 1.20E-06 Ib/MMCF AP-42 Section 1.4 Benzo(b)fluoranthene 1.80E-06 Ib/MMCF AP-42 Section 1.4 3 enzo(g, h, i) perylene 1.20E-06 Ib/MMCF AP-42 Section 1.4 Benzo(k)fIuoranthene 1.80E-06 Ib/MMCF AP-42 Section 1.4 Chrysene 1.80E-06 Ib/MMCF AP-42 Section 1.4 Dibenzo(a,h)anthracene 1.20E-06 Ib/MMCF AP-42 Section 1.4 Dichlorobenzerte 1.20E-03 Ib/MMCF AP-42 Section 1.4 Fluoranthene 3.00E-06 Ib/MMCF AP-42 Section 1.4 Fluorene 2.80E-06 Ib/MMCF AP-42 Section 1.4 Formaldehyde 2.80E-06 Ib/MMCF AP-42 Section 1.4 lndeno(l,2,3-cd)pyrene 7.50E-02 Ib/MMCF AP-42 Section 1.4

Naphthalene 6.10E-04 Ib/MMCF AP-42 Section 1.4

Phenanathrene 1.70E-05 Ib/MMCF AP-42 Section 1.4

Pyrene 5.00E-06 Ib/MMCF AP-42 Section 1.4 Toluene 3.40E-03 Ib/MMCF AP-42 Section 1.4

Type

Natural Gas Natural Gas Natural Gas Natural Gas Natural Gas Natural Gas Natural Gas

Fe rmentation

EU001-Boiler #1 EU002-Boiler #2 EU059-Boiler #3

EU066-Dryer EU083-RTO

EU067 - Bio-Digester EU076 - Loadout Fiare SV018 - Fermentation

Natural Gas: 1,020 Btu/cf Diesel: 129,500 Btu/gal

Capacity (Hourly)

Throughput (Annual)

24.50 24.50 60.00 38.00 8.00 0.01 0.02 0.003

214620 214620 525600 332880 70080 129 179 30.00

214620 214620 525600 332880 70080 129 179

30.000

MMBtu MMBtu MMBtu MMBtu MMBtu MMBtu MMBtu MMGPY

Assumptions for Global Warming Potential C02 1 CH4 25 N2O 298 Note; All Global Warming Potential data were obtained from 40 CFR 98 Table A-1 Note: Unless otherwise noted, all emission factors were obtained from 40 CFR 98 Tables C-l and C-2

Emission Factor Emission Factor Emission Factor Emissions Emissions Emissions Emissions (Ib/MMBtu) (Ib/MMBtu) (Ib/MMBtu) (tons/yr) (tons/yr) (tons/yr) (tons/yr)

116.98 0.0022 0.00024 12,553 0.24 0.03 12,566 116.98 0.0022 0.00024 12,553 0.24 0.03 12,566 116.98 0.0022 0.00024 30,742 0.58 0.06 30,775 116.98 0.0022 0.00024 19,470 0.37 0.04 19,491 116.98 0.0022 0.00024 4,099 0.08 0.01 4,103 116.98 0.0022 0.00024 8 0.00 0.00 8 116.98 0.0022 0.00024 10 0.00 0.00 10

6 0.0000 0 94,351 0.00 0.00 94,351

Total 173785.26 1.49 0.16 S 173871.18

Facility Name: Denco II Facility Site Location: Morris, Minnesota Permit No.: 14900013-005 Facility Contact: Brandon Soine, Plant Manager Phone #: 320-585-7904 Email Address: [email protected] Responsible Official: Mick Miller Responsible Official's Title: General Manager

POTENTIAL UNITS Undenatured ethanoi throughput: 30 MMGal/yr Hours of Operation: 8760 Hours Denaturant Rate: 2.5% Denaturant throughput: 0.75 MMGal/yr Denatured Ethanoi throughput 30.75 MMGal/yr Propane Usage 2,032,787 Gal/yr Corrosion Inhibitor 11800.0 gallons/yr Yield: 2.6 Gal/bu Corn Density: 56 Ib/bu Corn Processed: 11.5 MMBu/yr Corn Oil Produced: 715000 Gal/yr Annual Grain Receiving: 323077 TPY DDGS Yield: 17 Ib/bu DDGS Processed: 98,077 TPY (dry mass)

14.55 tons/hr Loadout 30.00 MMGal/yr Wet Cake Processed: 306,490 TPY (wet)

35.0 tons/hr Flat Storage Throughput 1,648,000.0 tons/vr

SV001 EUOOl Boiler #1 SV002 EUOOZ Boiler #2

SV017 EU059 Boiler #3

SV018 CE020, CE029 SV018 Fermentation Scrubber Stack SV019 CE021, CE027 SV019 VRTO #1 Stack

SV022 NA EU071 Cooling Cyclone

SV023 CE025 EU07S Loadout Flare

ind HAP (acetaldehyde)

uncontrolled controlled Ib/hr tpy tpy

1.30 37.96 5.69 0.35 30.84 1.54 0.50 2.17 2.17 0.00 0.03 0.00

Ind HAP [acetaldehyde) Ib/hr tpy tpy

Ib/hr

0.04 0.04

0.11

0.01

0.67

Ib/hr

Ind HAP (hexane)

uncontrolled controlled tpy

0.19 0.19 0.46

0.06

tpy

0.19

0.19 0.46

0.06

0.33 6.57

Ind HAP [hexane)

tpy tpy

Ib/hr

0.00

0.00

0.00

1.32 0.70 0.61 0.78

Ib/hr

HAPs

uncontrolled

tpy

0.01

0.01

0.02

38.90

59.81

2.65

7.70

HAPS tpy

controlled tpy

0.01 0.01

0.02

5.78

3.05

2.65

0.39

SV No. CE No. EU No. Description Pollutant

SV002 EU002 Boiler #2 Combustion HAPs

SV002 EU002 Boiler #2 Hexane (comb)

Combustion HAP emission factors for Natural Gas Combustion

Hexane 1.8 Ib/MMCF AP-42 Sect on 1.4

2-Methyinaphthalene 2.50E-05 Ib/MMCF AP-42 Sect on 1.4

3-Methylnaphthalene 1.80E-06 Ib/MMCF AP-42 Sect on 1.4

7,12-Dimethylbenz(a)anthracene 1.60E-05 Ib/MMCF AP-42 Sect on 1.4

Acenaphthene 1.80E-06 Ib/MMCF AP-42 Sect on 1.4

Acenaphthylene 1.80E-06 Ib/MMCF AP-42 Sect on 1.4

Anthracene 2.40E-06 Ib/MMCF AP-42 Sect on 1.4

Benz(a)anthracene 1.80E-06 Ib/MMCF AP-42 Sect on 1.4

Benzene 2.10E-03 Ib/MMCF AP-42 Sect on 1.4

Benzo(a)pyrene 1.20E-06 Ib/MMCF AP-42 Sect on 1.4

Benzo(b)fluoranthene 1.80E-06 Ib/MMCF AP-42 Sect on 1.4

Benzo(g,h,i)perylene 1.20E-06 Ib/MMCF AP-42 Sect on 1.4 Benzo(k)fluoranthene 1.80E-06 Ib/MMCF AP-42 Sect on 1.4

Chrysene 1.80E-06 Ib/MMCF AP-42 Sect on 1.4 Dibenzo{a,h)anthracene 1.20E-06 Ib/MMCF AP-42 Sect on 1.4 Dichlorobenzene 1.20E-03 Ib/MMCF AP-42 Sect on 1.4 Fluoranthene 3.00E-06 Ib/MMCF AP-42 Sect on 1.4 Fluorene 2.80E-06 Ib/MMCF AP-42 Sect on 1.4 Formaldehyde 2.80E-06 Ib/MMCF AP-42 Sect on 1.4 lndeno(l,2,3-ai)pyrene 7.50E-02 Ib/MMCF AP-42 Sect on 1.4

Naphthalene 6.10E-04 Ib/MMCF AP-42 Sect on 1.4

Phenanathrene 1.70E-05 Ib/MMCF AP-42 Sect on 1.4

Pyrene 5.00E-06 Ib/MMCF AP-42 Sect on 1.4 Toluene 3.40E-03 Ib/MMCF AP-42 Sect on 1.4




Emission Factor Units Emission Factor Citation Ib/hr TPY TPY - AP-42 Section 1.4 0.002 0.01 0.01

1.80E+00 Ib/MMCF AP-42 Section 1.4 0.04 0.19 0.19

SV No. CE No. EU No. Description Pollutant SV001 EU001 Boiler #1 Combustion HAPs SV001 EU001 Boiler #1 Hexane (comb)


2-Methylnaphthalene 2.50E-05 Ib/MMCF AP-42 Section 1.4 3-Methylnaphthalene 1.80E-06 Ib/MMCF AP-42 Section 1.4 7,12-Dimethylbenz(a)anthracene 1.60E-05 Ib/MMCF AP-42 Section 1.4 Acenaphthene 1.80E-06 Ib/MMCF AP-42 Section 1.4 Acenaphthylene 1.80E-06 Ib/MMCF AP-42 Section 1.4 Anthracene 2.40E-06 Ib/MMCF AP-42 Section 1.4 Benz(a)anthracene 1.80E-06 Ib/MMCF AP-42 Section 1.4 Benzene 2.10E-03 Ib/MMCF AP-42 Section 1.4 Benzo(a)pyrene 1.20E-06 Ib/MMCF AP-42 Section 1.4 Benzo(b)fluoranthene 1.80E-06 Ib/MMCF AP-42 Section 1.4 Benzo(g,h,i)perylene 1.20E-06 Ib/MMCF AP-42 Section 1.4 Benzo(k)fluoranthene 1.80E-06 Ib/MMCF AP-42 Section 1.4 Chrysene 1.80E-06 Ib/MMCF AP-42 Section 1.4 Dibenzo(a,h)anthracene 1.20E-06 Ib/MMCF AP-42 Section 1.4 Dichlorobenzene 1.20E-03 Ib/MMCF AP-42 Section 1.4 Fluoranthene 3.00E-06 Ib/MMCF AP-42 Section 1.4 Fluorene 2.80E-06 Ib/MMCF AP-42 Section 1.4 Formaldehyde 2.80E-06 Ib/MMCF AP-42 Section 1.4 lndeno(l,2,3-cd)pyrene 7.50E-02 Ib/MMCF AP-42 Section 1.4 Naphthalene 6.10E-04 Ib/MMCF AP-42 Section 1.4 Phenanathrene 1.70E-05 Ib/MMCF AP-42 Section 1.4 Pyrene 5.00E-06 Ib/MMCF AP-42 Section 1.4 Toluene 3.40E-03 Ib/MMCF AP-42 Section 1.4



Emission Factor Units

1.80E+00 Ib/MMCF

Emission Factor Citation

AP-42 Section 1.4 AP-42 Section 1.4


Ib/hr TPY TPY 0.002 0.01 0.01 0.04 0.19 0.19

SV No. SV017 SV017

CE No. EU No.

EU059

EU059



Hexane (comb)

Throughput

60.0 60.0


Combustion HAP Hexane

nylnaphthalene nylnaphthalene iylbenz(a)anthrac snaphthene naphthylene nthracene (a)anthracene Benzene izo(a)pyrene b)fluoranthene (g,h,i)perylene k)fluoranthene Chrysene >(a,h)anthracene tlorobenzene loranthene Fluorene -maldehyde l,2,3-cd)pyrene sphthalene ;nanathrene Pyrene

Toluene

emission factors for Natural Gas Combustion

2.50E-05 1.80E-06 1.60E-05 1.80E-06 1.80E-06 2.40E-06 1.80E-06 2.10E-03 1.20E-06 1.80E-06 1.20E-06 1.80E-06 1.80E-06 1.20E-06 1.20E-03 3.00E-06 2.80E-06 2.80E-06 7.50E-02 6.10E-04 1.70E-05 5.00E-06 3.40E-03

Ib/MMCF Ib/MMCF Ib/MMCF Ib/MMCF Ib/MMCF Ib/MMCF Ib/MMCF Ib/MMCF Ib/MMCF Ib/MMCF Ib/MMCF Ib/MMCF Ib/MMCF Ib/MMCF Ib/MMCF Ib/MMCF Ib/MMCF Ib/MMCF Ib/MMCF Ib/MMCF Ib/MMCF Ib/MMCF Ib/MMCF Ib/MMCF

AP-42 Section 1.4 AP-42 Section 1.4 AP-42 Section 1.4 AP-42 Section 1.4 AP-42 Section 1.4 AP-42 Section 1.4 AP-42 Section 1.4 AP-42 Section 1.4 AP-42 Section 1.4 AP-42 Section 1.4 AP-42 Section 1.4 AP-42 Section 1.4 AP-42 Section 1.4 AP-42 Section 1.4 AP-42 Section 1.4 AP-42 Section 1.4 AP-42 Section 1.4 AP-42 Section 1.4 AP-42 Section 1.4 AP-42 Section 1.4 AP-42 Section 1.4 AP-42 Section 1.4 AP-42 Section 1.4 AP-42 Section 1.4

Emission Potential to Emit Uncontrolled Controlled

Factor Units Emission Factor Citation Ib/hr TPY TPY

- - AP-42 Section 1.4 0.005 0.02 0.02

1.80E-06 Ib/MMCF AP-42 Section 1.4 0.11 0.46 0.46

Emission CE No. EU No. Description Pollutant Throughput Units Factor Units

Acetaldehyde 8,760 hrs/yr 1.3 Ib/hr Formaldehyde 8,760 hrs/yr 0.01 Ib/hr

Methanol 8,760 ^Is/yr Ib/hr PH

Scrubber efficiency based on guidance from Nebraska Department of Environmental Quality in a memo dated 9/29/08 titled, "Miscellaneous Organic NESHAP (MON) and Ethanol Production.

SV No. SV018 SV018 SV018

Description Fermentation Scrubber Stack Fermentation Scrubber Stack Fermentation Scrubber Stack

Control Equipment Efficiency *

85.0% 32.5% 95.0%

Emission Factor Citation Engineering Estimate Engineering Estimate Engineering Estimate


Ib/hr TPY TPY 1.30 37.96 5.69 0.01 0.06 0.04 0.01 0.88 0.04

SPgjggg

SV No. CE No. Description Pollutant Throughput Units

SV019 CE021, CE027 VRTO #1 Stack Acetaldehyde 8,760 hrs/yr

SV019 CE021, CE027 VRTO #1 Stack Acrolein 8,760 hrs/yr

SV019 CE021, CE027 VRTO #1 Stack Formaldehyde 8,760 hrs/yr SV019 CE021, CE027 VRTO #1 Stack Methanol 8,760 hrs/yr

SV019 CE021, CE027 VRTO #1 Stack Combustion HAPs 8 MMBtu/hr

SV019 CE021, CE027 VRTO #1 Stack Hexane (comb) 8 MMBtu/hr


2-Methylnaphthalene 2.50E-05 Ib/MMCF AP-42 Section 1.4 3-Methylnaphthalene 1.80E-06 Ib/MMCF AP-42 Section 1.4 7/12-Dimethylbenz(a)anthracene 1.60E-05 Ib/MMCF AP-42 Section 1.4 Acenaphthene 1.80E-06 Ib/MMCF AP-42 Section 1.4 Acenaphthylene 1.80E-06 Ib/MMCF AP-42 Section 1.4 Anthracene 2.40E-06 Ib/MMCF AP-42 Section 1.4 Benz(a)anthracene 1.80E-06 Ib/MMCF AP-42 Section 1.4 Benzene 2.10E-03 Ib/MMCF AP-42 Section 1.4 Benzo(a)pyrene 1.20E-06 Ib/MMCF AP-42 Section 1.4 Benzo(b)fluoranthene 1.80E-06 Ib/MMCF AP-42 Section 1.4 8enzo(g,h,i)pery!ene 1.20E-06 Ib/MMCF AP-42 Section 1.4 Benzo(k)fluoranthene 1.80E-06 Ib/MMCF AP-42 Section 1.4 Chrysene 1.80E-06 Ib/MMCF AP-42 Section 1.4 Dibenzo(a,h)anthracene 1.20E-06 Ib/MMCF AP-42 Section 1.4 Dichlorobenzene 1.20E-03 Ib/MMCF AP-42 Section 1.4 Fiuoranthene 3.00E-06 Ib/MMCF AP-42 Section 1.4 Fiuorene 2.80E-06 Ib/MMCF AP-42 Section 1.4 Formaldehyde 2.80E-06 Ib/MMCF AP-42 Section 1.4 lndeno(l,2,3-cd)pyrene 7.50E-02 Ib/MMCF AP-42 Section 1.4 Naphthalene 6.10E-04 Ib/MMCF AP-42 Section 1.4 Phenanathrene 1.70E-05 Ib/MMCF AP-42 Section 1.4 Pyrene 5.00E-06 Ib/MMCF AP-42 Section 1.4 Toluene 3.40E-03 Ib/MMCF AP-42 Section 1.4 •••• msssmMMMB

Control Potential to Emit Emission Equipment Uncontrolled Controlli Factor Units Efficiency Emission Factor Citation Ib/hr TPY TPY 0.352 Ib/hr 95% 110% of April 2011 Stack Test 0.35 30.84 1.54 0.022 Ib/hr 95% 110% of April 2011 Stack Test 0.02 1.93 0.10 0.22 Ib/hr 95% 110% of April 2011 Stack Test 0.22 19.27 0.96

0.088 Ib/hr 95% 110% of April 2011 Stack Test 0.09 7.71 0.39 - - 0% AP-42 Section 1.4 0.001 0.003 0.003

1.80E+00 Ib/MMCF 0% AP-42 Section 1.4 0.014 0.06 0.06

Potential to Emit Emission Uncontrolfed Controll

SV No. CE No. EU No. Description Pollutant Throughput Units Factor Units Emission Factor Citation Ib/hr TPY TPY SV022 NA EU071 Cooling Cyclone Acetaidehyde 8,760 hrs/yr 0.50 Ib/hr 110% of Dec. 2010 Stack Test Data 0.50 2.17 2.17 SV022 NA EU071 Cooling Cyclone Acrolein 8,760 hrs/yr 0.01 ib/hr 110% of Dec. 2010 Stack Test Data 0.01 0.05 0.05 SV022 NA EU071 Cooling Cyclone Formaldehyde 8,760 hrs/yr 0.03 Ib/hr 110% of Dec. 2010 Stack Test Data 0.03 0.14 0.14 SV022 NA EU071 Cooling Cyclone Methanol 8,760 hrs/yr 0.07 Ib/hr 110% of Dec. 2010 Stack Test Data 0.07 0.29 0.29

Potential to Emft Emission Emission Factor Uncontrolled Controlled

SV No. CE No. EU No. Description Pollutant Throughput Units Factor Units Citation Ib/hr TPY TPY

SV023 CE025 EU076 Loadout Flare VOC (as VOC) 30.0 1000 gal/hr 0.44 lb/1000 gal AP-42 Section 1.4 13.14 131.35 6.57

SV023 CE025 EU076 Loadout Flare VOC (as VOC) 5.5 MMCF natural gas/yr 5.50 Ib/MMCF AP-42 Section 1.4 30.35 0.30 0.02

SV023 CE025 EU076 Loadout Flare VOC (Total) 43.49 131.66 6.58

SV023 CE025 EU076 Loadout Flare Combustion HAPs 0.0147 MMBtu/hr AP-42 Section 1.4 2.69E-05 2.36E-03 1.18E-04

SV023 CE025 EU076 Loadout Flare Process HAPs NA 0.8% wt % VOC Nebraska DEQ 0.11 1.10 0.05 SV023 CE025 EU076 Loadout Flare Acetaldehyde NA 0.0% wt % VOC Nebraska DEQ 0.00 0.03 0.00

SV023 CE02S EU076 Loadout Flare Hexane (proc) NA S.0% wt % VOC Nebraska DEQ 0.66 6.57 0.33 SV023 CE025 EU076 Loadout Flare Hexane (comb) 5.5 MMCF natural gas/yr 1.80 Ib/MMCF AP-42 Section 1.4 0.01 0.00 0.00

Assumptions:

Vapors Denatured

Ethanol

0.03 1

0.48 46.07

505.39

L= 12.46- S - P • M •

Gasoline 0.44

1 3.86 92

505.39

loading losses, lb VOC/IOOO gal Saturation Factor True Vapor Pressure, psia Molecular Weight, Ib/lb-mole Temperature, R

L = Loading Loss, lb VOC/IOOO gal of liquid loaded S = Saturation Factor (AP-42 Table 5.2-1) P =True Vapor Pressure of Liquid Loaded, psia - EPA TANKs program M = Molecular Weight of Vapors, Ib/lb-mole - EPA TANKs program T = Temperature of Bulk Liquid Loaded, R - EPA TANKs program

Flare Control: 95%

Loading Rate (gpm): 500

Limited Loading Rate (MMgpy): 30.0

Firing Rate: 0.0147 MMBtu/hr

HAPs Emission Factors for Hexane 2-Methylnaphtha lene 3-Methylnaphthalene 7,12-Dimethylbenz(a)anth Acenaphthene Acenaphthylene Anthracene Benz(a)anthracene Benzene Benzo(a)pyrene Benzo(b)fluoranthene Benzo(g,h,i)perylene Benzo(k)fluoranthene Chrysene Dibenzo(a,h)anthracene Dichloro benzene Fiuoranthene Fluorene Formaldehyde lndeno(l,2,3-cd)pyrene

Naphthalene

Phenanathrene

Pyrene

Toluene

Natural Gas Combustion 1.8

2.50E-05 1.80E-06

ra. 1.60E-05 1.80E-06 1.80E-06 2.40E-06 1.80E-06 2.10E-03 1.20E-06 1.80E-06 1.20E-06 1.80E-06 1.80E-06 1.20E-06 1.20E-03 3.00E-06 2.80E-06 2.80E-06 7.50E-02

6.10E-04

1.70E-05 5.00E-06 3.40E-03

Ib/MMCF Ib/MMCF ib/MMCF Ib/MMCF Ib/MMCF ib/MMCF Ib/MMCF Ib/MMCF Ib/MMCF Ib/MMCF Ib/MMCF Ib/MMCF Ib/MMCF Ib/MMCF Ib/MMCF Ib/MMCF Ib/MMCF Ib/MMCF Ib/MMCF Ib/MMCF Ib/MMCF

Ib/MMCF Ib/MMCF Ib/MMCF

AP-42 Section 1.4 AP-42 Section 1.4 AP-42 Section 1.4 AP-42 Section 1.4 AP-42 Section 1.4 AP-42 Section 1.4 AP-42 Section 1.4 AP-42 Section 1.4 AP-42 Section 1.4 AP-42 Section 1.4 AP-42 Section 1.4 AP-42 Section 1.4 AP-42 Section 1.4

AP-42 Section 1.4

AP-42 Section 1.4 AP-42 Section 1.4 AP-42 Section 1.4 AP-42 Section 1.4 AP-42 Section 1.4 AP-42 Section 1.4 AP-42 Section 1.4 AP-42 Section 1.4 AP-42 Section 1.4 AP-42 Section 1.4

Type Capacity

Throughput (Annual) (Hourly) Emission Factor Emission Factor Emission Factor Emissions Emissions Emissions Emissions

(Ib/MMBtu) (Ib/MMBtu) (Ib/MMBtu) (tons/yr} (tons/yr) (tons/yr) (tons/yr) Natural Gas EU001 - Boiler#l 24.50 214520 214620 MMBtu 116.98 0.0022 0.00024 12,553 0.24 0.03 12,566 Natural Gas EU002 - Boiler#2 24.50 214620 214620 MMBtu 116.98 0.0022 0.00024 12,553 0.24 0.03 12,566 Natural Gas EU059 - Boiler#3 60.00 525600 S25600 MMBtu 116.98 0.0022 0.00024 30,742 0.58 0.06 30,775 Natural Gas EU066 - Dryer 38.00 332880 332880 MMBtu 116.98 0.0022 0.00024 19,470 0.37 0.04 19,491 Natural Gas EU083 - RTO 8.00 70080 70080 MMBtu 116.98 0.0022 0.00024 4,099 0.08 0.01 4,103 Natural Gas EU067 - Bio-Digester 0.01 129 129 MMBtu 116.98 0.0022 0.00024 8 0.00 0.00 8 Natural Gas EU07S - Loadout Flare 0.02 179 179 MMBtu 116.98 0.0022 0.00024 10 0.00 0.00 10

Fermentation SV018 - Fermentation 0.003 "TOO 30.000 MMGPY 6 0.0000 0 94,351 ~ 0.00 94,351

Total 173785.26 1.49 ** 0.16 173871.18

Natural Gas: 1,020 Btu/cf Diesel: 129,500 Btu/gal

Assumptions for Global Warming Potential co2 1

CH4 25

N2O 298

Note: All Global Warming Potential dato were obtained from 40 CFR 98 Table A-l Note: Unless otherwise noted, all emission factors were obtained from 40 CFR 98 Tables C-1 and C-2

SCC Code HAP wt% of liquid Source

Loadout - NONDEDICATED (Gasoline Vapors)

71432 Benzene 0.25% Nebraska DEQ


98828 Cumene 0.01% Nebraska DEQ Loadout - NONDEDICATED (Gasoline Vapors)

100414 Ethyl benzene 0.01% Nebraska DEQ Loadout - NONDEDICATED (Gasoline Vapors) 110543 Hexane 5.00% Nebraska DEQ Loadout - NONDEDICATED (Gasoline Vapors)

108883 Toluene 0.50% Nebraska DEQ


1330207 Xylene 0.05% Nebraska DEQ

Loadout - DEDICATED (Denatured Ethanol)

71432 8enzene 0.25% Nebraska DEQ


98828 Cumene 0.01% Nebraska DEQ


100414 Ethyl benzene 0.01% Nebraska DEQ Loadout - DEDICATED (Denatured Ethanol)

110543 Hexane 5.00% Nebraska DEQ Loadout - DEDICATED (Denatured Ethanol) 108883 Toluene 0.50% Nebraska DEQ Loadout - DEDICATED (Denatured Ethanol)

1330207 Xylene 0.05% Nebraska DEQ


75070 Acetaldehyde 0.02% Nebraska DEQ


67561 Methanol 0.02% Nebraska DEQ

DENCO II, LLC 14900013-006

Attachment 2 Facility Description and CD-01

MINNESOTA POLLUTION CONTROL AGENCY AIR QUALITY 520 LAFAYETTE ROAD ST. PAUL, MN 55155-4 194

Show: Pending Records Only Action: PER 006 AQD Facility ID: 14900013 Facility Name: DENCO II LLC

lOAugust, 2015 11:27

FACILITY DESCRIPTION: EMISSION UNIT (EU)

ID No. Emission Unit

Status

Added By

(Action)

Retired By

(Action)

Insignificant

Activity

Operator ID

for item

Stack/ Vent

ID No(s).

Control Equip.

ID No(s).

Operator Description Manufacturer Model Number

SIC Max. Design

Capacity

Ma D

Ca

Materials

ximum ssign pacity

Units n Units d

Max Fuel Input

(mil Btu)

1 EU 001 Active PER 006 • SV 001 (M) Boiler No. 1 - Boiler Stone Johnson 2869 24.5 Heat Mm btu Hr 24.5

2 EU 002 Active PER 006 • SV 002 (M) Boiler No. 2 - Boiler Stone Johnson 2869 24.5 Heat Mm btu Hr 24.5

3 EU 005 Active PER 006 • SV 005 (M) CE 019 Corn Dump Pit - Other Emission Unit

Butler Manufacturing 2869 130 Corn Ton Hr

4 EU 006 Active PER 006 • SV 005 (M) CE 019 Grain Elevator - Elevator 2869 3000 Bushel Hr

5 EU 007 Active PER 006 rn Corn Bin 1 (storage bin) -Silo/Bin

Hutchinson Div of Lear 2869 18000 Bushel

6 EU 008 Active PER 006 : f LJ Corn Bin 2 (surge bin) -

Silo/Bin TBD 2869 12000 Bushel

7 EU 009 Active PER 006 ;—! : : i i

Com Bin 3 (storage bin) -Silo/Bin

TBD 2869 20000 Bushel

8 EU 010 Active PER 006 • SV 005 (M) CE 019 Scalper - Cutting Equipment Henke Manufacturing 2869 2000 Bushel Hr

9 EU 016 Removed PER 006 L J SV 018 (M) CE 020 Yeast Propagation Tank Morris Ag-Energy Custom 2869 14500 Gal

10 EU 017 Removed PER 006 n SV 018 (M) CE 020 Yeast Propagation Tank Morris Ag-Energy Custom 2869 14500 Gal

11 EU 018 Active PER 006 n i i

SV 018 (M) CE 020 CE 029


Morris Ag-Energy Custom 2869 14500 Gal

12 EU 019 Active PER 006 • SV 018 (M) CE 020 CE 029


Morris Ag-Energy Custom 2869 14500 Gal

13 EU 051 Removed PER 006 • SV 018 (M) CE 020 Stripper 2869 17 Ethanol Mgal Yr

14 EU 055 Active PER 006 • SV 016 (M) DDGS Storage Pile - Other Emission Unit

2869 4.2 Ton Hr

15 EU 056 Active PER 006 • SV 016 (M) CE 018 DDGS Dump Pit - Other Emission Unit

2869 5.5 Ton Hr

16 EU 057 Active PER 006 • SV 016 (M) CE 018 DDGS Elevator - Elevator 2869 5.5 Ton Hr

17 EU 058 Active PER 006 n L_J SV 016 (M) CE 018 Truck Load Spout -

Loading-Unloading Equipment 2869 5.5 Ton Hr

18 EU 059 Active PER 006 • SV 017 (M) Boiler No. 3 - Boiler Superior 2869 60 Heat Mm btu Hr 60

19 EU 060 Active PER 006 i ! SV 021 (M) CE 024 Hammermill - Milling

Equipment Westphal 2869 20 Ton Hr



Diversified Energy Co. custom 2869 250000 Gal

21 EU 062 Active PER 006 1 ! SV 018 (M) CE 020 CE 029



Page 1 of 3 (a)

10 August, 2015 11:27



Status

Added By

(Action)

Commence

Const. Date

Initial Startup

Date

Removal Date

Firing Method Pet. Fuel/

Space Heat

Bottleneck Elevator Type

1 EU 001 Active PER 006 01/01/1985

2 EU 002 Active PER 006 01/01/1985

3 EU 005 Active PER 006 06/01/1990

4 EU 006 Active PER 006 06/01/1990

5 EU 007 Active PER 006



8 EU 010 Active PER 006 06/01/1990

9 EU 016 Removed PER 006 01/01/1990 06/01/1990

10 EU 017 Removed PER 006 01/01/1990 06/01/1990

11 EU 018 Active PER 006 01/01/1990 06/01/1990

12 EU 019 Active PER 006 01/01/1990 06/01/1990

13 EU 051 Removed PER 006 01/01/1990 06/01/1990





18 EU 059 Active PER 006 04/01/1999

19 EU 060 Active PER 006 04/01/1999 09/01/1999

20 EU 061 Active PER 006 04/01/1999 09/01/1999

21 EU 062 Active PER 006 04/01/1999 09/01/1999

Page 1 of 3 (b)



Show: Pending Records Only Action: PER 006 AQD Facility ID: 149000 13 Facility Name: DENCO II LLC

MINNESOTA POLLUTION CONTROL AGENCY AIR QUALITY 520 LAFAYETTE ROAD ST. PAUL, MN 55155- 4194


Status

Added By

(Action)

Retired By

(Action)

Insignificant

Activity

Operator ID

for Item

Stack/ Vent

ID No(s).

Control Equip.

ID No(s).


SIC Max. Design

Capacity

Ma D

Ca

Materials

ximum ssign pacity

Units n Units d

Max Fuel Input

(mil Btu)




23 EU 064 Active PER 006 • ! SV 018 (M) CE 020

CE 029 Beer Well - Fermentation Equipment


24 EU 065 Active PER 006 ; , u SV 018 (M) CE 020

CE 029 Beer Well - Fermentation Equipment



DDGS Dryer - Dryer/Oven, indirect fired

Heil 85 2869 50400 DDGS Lb Hr 38

26 EU 067 Active PER 006 • SV 020 (M) CE 023 Bio-digester - Digester TBD TBD 2869 12600 Ft3 Day 0.0147

27 EU 068 Removed PER 006 • SV 018 (M) Rectifier 2869


Side Stripper - Stripping Equipment

2869


Molecular Sieve - Distillation Equipment

2869 48 Ethanol Gal Min

30 EU 071 Active PER 006 !—1 LJ SV 022 Cooling Cyclone - Cooler 2869 17500 DDGS Lb Hr

31 EU 072 Active PER 006 j—| SV 018 CE 020 CE 029


2869

32 EU 076 Active PER 006 u SV 023 (M) CE 025 Ethanol loadout flare - Other Combustion

TBD TBD 2869 14,700 Heat Btu Hr 0.0147

33 EU 077 Removed PER 006 • DDGS Storage Bin TBD TBD 2869 2150 Ft3 Day

34 EU 078 Removed PER 006 I i ; I SV 024 Corn Gluten Storage Bin TBD TBD 2869 1500 Ft3 Day

35 EU 079 Removed PER 006 • SV 024 Premix Storage Bin TBD TBD 2869 625 Ft3 Day

36 EU 080 Removed PER 006 LJ SV 024 Phosphorous Storage Bin TBD TBD 2869 625 Ft3 Day

37 EU 081 Removed PER 006 • SV 024 Magnesium Oxide Storage Bin TBD TBD 2869 1000 Ft3 Day

38 EU 082 Removed PER 006 • SV 024 Calcium Carbonate Storage Bin

TBD TBD 2869 1000 Ft3 Day

39 EU 084 Active PER 006 pi SV 025 CE 028 Hammermill 2 - Milling Equipment

TBD TBD 2869 40 Ton Hr

40 EU 085 Active PER 006 u Slurry Tank - Process Tank 2869

41 EU 086 Active PER 006 • SV 005(P) CE 019 Grain Bin - Silo/Bin Brock 2869 295000 Grain Bushel

42 EU 087 Active PER 006 • SV 005(P) CE 019 Grain Bin - Silo/Bin Brock 2869 295000 Grain Bushel

43 EU 088 Active PER 006 f.—j SV 018(B)

SV 019 (M) CE 020 CE 027 CE 029

Yeast Propagation Tank -Fermentation Equipment

PAR Piping & Fabricate Custom 2869 22000 Yeast Gal Day

Page 2 of 3 (a)

10 August, 2015 11:27



Status

Added By

(Action)

Commence

Const. Date

Initial Startup

Date

Removal Date


Space Heat


22 EU 063 Active PER 006 04/01/1999 09/01/1999

23 EU 064 Active PER 006 04/01/1999 09/01/1999

24 EU 065 Active PER 006 04/01/1999 09/01/1999

25 EU 066 Active PER 006 04/01/1999 09/01/1999

26 EU 067 Active PER 006 04/01/1999 09/01/1999

27 EU 068 Removed PER 006





32 EU 076 Active PER 006 07/01/2004 09/01/2004 0

33 EU 077 Removed PER 006 07/01/2004 09/01/2004

34 EU 078 Removed PER 006 07/01/2004 09/01/2004

35 EU 079 Removed PER 006 07/01/2004 09/01/2004

36 EU 080 Removed PER 006 07/01/2004 09/01/2004

37 EU 081 Removed PER 006 07/01/2004 09/01/2004

38 EU 082 Removed PER 006 07/01/2004 09/01/2004

39 EU 084 Active PER 006 07/01/2004 09/01/2004


41 EU 086 Active PER 006 08/01/2012 09/01/2012

42 EU 087 Active PER 006 08/01/2012 09/01/2012


Page 2 of 3 (b)

10 August, 2015 11:27


Show: Pending Records Only

Action: PER 006

AQD Facility ID: 14900013



Status

Added By

(Action)

Retired By

(Action)

Insignificant

Activity

Operator ID

for Item

Stack/ Vent

ID No(s).

Control Equip.

ID No(s).


SIC Max. Design

Capacity

Maximum Design

Capacity

Max Fuel Input

(mil Btu) Materials Units n Units d

Max Fuel Input

(mil Btu)

44 EU 089 Active PER 006 n SV 018 (M) CE 020 CE 029

Beer Column - Distillation Equipment

PAR Piping & Fabricate Custom 2869 320 Beer Gal Min


Rectifier - Distillation Equipment

PAR Piping &Fabricatic Custom 2869 60 Ethanol Gal Min

46 EU 091 Active PER 006 • SV 018 CE 020 CE 029


2869 320 Beer Gal Min

47 EU 092 Active PER 006 • SV 023 CE 025 Ethanol Loadout -Loading-Unloading Equipment

2869

MINNESOTA POLLUTION CONTROL AGENCY AIR QUALITY 520 LAFAYETTE ROAD ST. PAUL. MN 55155^4194

Page 3 of 3 (a)




Status

Added By

(Action)

Commence

Const. Date

Initial Startup Date

Removal Date


Space Heat




46 EU 091 Active PER 006 Whole Facility


Page 3 of 3 (b)

10 August, 2015 10:48

FACILITY DESCRIPTION: CONTROL EQUIPMENT (CE)

Show: Active and Pending Records Action: PER 006 AQD Facility ID: 149000 13 Facility Name: DENCO II LLC

ID No. Control Equip. Status

Added By

(Action)

Retired By

(Action)

Operator ID

for Item

Control Equip. Type

Control Equipment Description Manufacturer Model Pollutants Controlled

Capture Efficiency

(%) Destruction/ Collection Efficiency

<%)

Afterburner Combustion Parameters

1 CE 001 Removed PER 002 018 Fabric Filter - Low Temperature, i.e., T<180 Degrees F AAF Amerpulse 1048-660 PM 80 99

2 CE 002 Removed PER 002 007 Centrifugal Collector - High Efficiency Westphal NR-1.1-8885 PM 100 80



5 CE 005 Removed PER 002 007 Centrifugal Collector - High Efficiency Westphal TBD PM 100 80

6 CE 006 Removed PER 002 007 Centrifugal Collector - High Efficiency Westphal TBD PM 100 80

7 CE 007 Removed PER 002 018 Fabric Filter - Low Temperature, i.e., T<180 Degrees F Westphal NA PM 100 99



10 CE 010 Removed PER 002 018 Fabric Filter - Low Temperature, i.e.. T<180 Degrees F Westphal NA PM 100 99


12 CE 012 Removed PER 002 013 Gas Scrubber (General, Not Classified) Morris Ag-Energy NA



15 CE 015 Removed PER 002 007 Centrifugal Collector - High Efficiency Thompson Dehydrating Custom PM 100 80

16 CE 016 Removed PER 002 007 Centrifugal Collector - High Efficiency Thompson Dehydrating Custom PM 100 80

17 CE 017 Retired PER 002 047 Vapor Recovery System-Condensers, Hoods, & Other Enclosures

Diversified Energy design

18 CE 018 Active PER 001 007 Centrifugal Collector - High Efficiency TBD TBD PM 100 80

19 CE 019 Active PER 005 018 Fabric Filter - Low Temperature, i.e., T<180 Degrees F TBD TBD PM10 PM

80 80

99 99

20 CE 020 Active PER 005 013 Gas Scrubber (General, Not Classified) Diversified Energy Co., LLC

Custom VOC 100 70

21 CE 020 Active PER 006 050 Packed-Gas Adsorption Column Diversified Energy Co., LLC

Custom VOC 100 70

22 CE 021 Active PER 005 076 Multiple Cyclone w/o Fly Ash Reinjection - Most Multiclones

Thompson Dehydrating custom PM10 PM

100 100

80 80

23 CE 023 Active PER 005 023 Flaring TBD TBD VOC 100 98


100 100

99 99

25 CE 025 Active PER 004 023 Flaring TBD TBD VOC 100 95

MINNESOTA POLLUTION CONTROL AGENCY AIR QUALITY 520 LAFAYETTE ROAD ST. P AUL. MN 55155-4194

Page 1 of 2

10 August, 2015 10:48

FACILITY DESCRIPTION: CONTROL EQUIPMENT (CE)

Show: Active and Pending Records Action: PER 006 AQD Facility ID: 14900013


ID No. Control Equip. Status

Added By

(Action)

Retired By

(Action)

Operator ID

for Item

Control Equip. Type

Control Equipment Description Manufacturer Model Pollutants Controlled

Capture Efficiency

(%) Destruction/ Collection Efficiency

(%)

Afterburner Combustion Parameters

26 CE 026 Active PER 004 018 Fabric Filter - Low Temperature, i.e., T<180 Degrees F Dyn equip 030467 PM10 PM

100 100

99 99

27 CE 026 Removed PER 006 018 Fabric Filter - Low Temperature, i.e., T<180 Degrees F Dynequip 030467 PM10 PM

100 100

99 99

28 CE 027 Active PER 005 021 Direct Flame Afterburner TBD TBD CO PM10 PM VOC

100 100 100 100

90 60 60 95


100 100

99 99

30 CE 029 Active PER 006 050 Packed-Gas Adsorption Column PAR Piping & Fabrication

Custom VOC 100 80

MINNESOTA POLLUTION CONTROL AGENCY AIR QUALITY 520 LAFAYETTE ROAD ST. PAUL, MN 55155-4194

Page 2 of 2

10 August, 2015 10:47

FACILITY DESCRIPTION: STACK/VENTS (SV)

Show: Active and Pending Records

Action: PER 006



ID No. Stack/ Vent

Status

Added By

(Action)

Retired By

(Action)

Operator ID

for Item

Operators Description Height of Opening

From Ground (feet)

Inside Dimensions Design Flow Rate

at Top (ACFM)

Exit Gas Temperature

at Top (°F)

Flow Rate/ Temperature

Information Source

Discharge Direction ID No. Stack/ Vent

Status

Added By

(Action)

Retired By

(Action)

Operator ID

for Item


From Ground (feet)

Diameter or Length

(feet)

Width (feet)

Design Flow Rate

at Top (ACFM)


at Top (°F)


Information Source

Discharge Direction

1 SV 001 Active PER 001 Boiler #1 34.0 2.00 5095 350 Manufacturer Up, With Cap

2 SV 002 Active PER 001 Boiler #2 34.0 2.00 5095 350 Manufacturer Up, With Cap

3 SV 003 Removed PER 002 Boiler #3 34.0 2.00 3390 350 Manufacturer Up, With Cap

4 SV 004 Removed PER 002 Boiler #4 34.0 2.00 3390 350 Manufacturer Up, With Cap

5 SV 005 Active PER 004 Grain Handling Baghouse (CE 019) 6.0 1.67 2.17 12000 60 Test Up, No Cap

6 SV 006 Removed PER 002 Hammermill Baghouse #1 28.0 1.25 1.25 2650 60 Estimate Up, No Cap




10 SV010 Removed PER 002 Hammermill Baghouse #5 28.0 1.25 1.25 2650 60 Estimate Up, No Cap

11 SV011 Removed PER 002 Fermentation A Scrubber 52.0 0.50 380 85 Test Up, No Cap

12 SV 012 Removed PER 002 Fermentation B Scrubber 52.0 0.50 380 80 Test Up, No Cap

13 SV 013 Removed PER 002 Fermentation C Scrubber 52.0 0.50 380 85 Test Up, No Cap

14 SV 014 Removed PER 002 Dryer A Cyclone 70.0 2.00 12500 180 Test Up, No Cap

15 SV 015 Removed PER 002 Dryer B Cyclone 70.0 2.00 12500 180 Test Up, No Cap

16 SV 016 Active PER 004 DDGS Building Exhaust (CE 018) 34.0 1.00 6000 80 Test Up, No Cap

17 SV 017 Active PER 002 New Boiler Stack 34 2.67 30000 410 Manufacturer Up, With Cap

18 SV 018 Active PER 004 Fermentation Scrubber (CE 020) 30 1 2700 90 Estimate Up, No Cap

19 SV 018 Active PER 006 Fermentation and Distillation 30 1 2700 90 Estimate Up, No Cap

20 SV 019 Active PER 005 Dryer (CE021 and CE027) 80 2.83 26400 210 Estimate Up, No Cap

21 SV 020 Active PER 002 Biodigester Flare 20 .33 500 1400 Estimate Up, No Cap

22 SV 021 Active PER 003 Hammermill Baghouse 60 2.83 26400 210 Estimate Up, No Cap

23 SV 022 Active PER 003 Cooling Cyclone Stack 15 1.33 8500 90 Test Up, No Cap

24 SV 023 Active PER 004 Ethanol loadout flare 36 3.5 200 1400 Estimate Up, No Cap

25 SV 024 Active PER 004 Golden Lyk storage bins 1-6 0 2 4000 70 Estimate Horizontal

26 SV 024 Removed PER 006 Golden Lyk storage bins 1-6 0 2 4000 70 Estimate Horizontal

27 SV 025 Active PER 004 Hammermill #2 60 2.83 26400 210 Estimate Up, No Cap


Page 1 of 2

MINNESOTA POLLUTION CONTROL AGENCY AIR QUALITY 520 LAFAYETTE ROAD ST. PAU L. MN 55155-4194

Show: Active and Pending Records Action: PER 006

AQD Facility ID: 14900013 Facility Name: DENCO II LLC

10 August, 2015 10:47

FACILITY DESCRIPTION: STACK/VENTS (SV)

ID No. Stack/ Vent

Status

Added By

(Action)

Retired By

(Action)

Operator ID

for Item


From Ground (feet)

Inside Dimensions Design Flow Rate

at Top (ACFM)


at Top <°F)


Information Source

Discharge Direction ID No. Stack/ Vent

Status

Added By

(Action)

Retired By

(Action)

Operator ID

for Item


From Ground (feet)

Diameter or Length

(feet)

Width (feet)

Design Flow Rate

at Top (ACFM)


at Top <°F)


Information Source

Discharge Direction

28 SV 026 Active PER 005 Corn Bin 1



Page 2 of 2



Action: PER 006



3 August, 2015 14:15

FACILITY DESCRIPTION: STORAGE TANKS (TK)

ID No. Tank Status

Added By

(Action)

Retired By

(Action)

Insignificant

Activity

Operator ID

for Item

Control Equip.

ID No(s).

Product Stored Interior Height

(ft.)

Interior Diameter

(ft.)

Capacity (1000 gal)

Construction Type

1 TK 001 Active PER 005 i I Ethanol 200 proof 40. 8.8 19 Fixed Roof

2 TK 002 Active PER 005 • Ethanol 200 proof 40. 8.8 19 Fixed Roof

3 TK 003 Active PER 005 • Ethanol 200 proof 40. 8.8 19 Fixed Roof

4 TK 004 Active PER 005 i I Ethanol 200 proof 40. 8.8 19 Fixed Roof

5 TK 005 Active PER 005 LJ E-85 24. 11 11.5 Internal Floating Roof

6 TK 006 Active PER 005 I Ethanol 190 proof 21 11 15 Fixed Roof

7 TK 007 Active PER 005 • Ethanol 190 proof 21. 11. 15 Fixed Roof

8 TK 008 Removed PER 005 • removed 43. 14. 50 Internal Floating Roof

9 TK 009 Removed PER 005 n removed 70. 16. 100 Internal Floating Roof

10 TK 010 Removed PER 005 • removed 70. 16. 100 Internal Floating Roof

11 TK 011 Active PER 002 n Denatured Ethanol 36 35 250 Internal Floating Roof

12 TK 012 Active PER 004 I I Denatured Ethanol 250 Internal Floating Roof

13 TK 013 Active PER 004 r i Denaturant 39 Fixed Roof

14 TK 014 Active PER 005 • Denatured Ethanol 42 45 500 Internal Floating Roof

Page 1 of 1 (a)

3 August, 2015 14:15

FACILITY DESCRIPTION: STORAGE TANKS (TK)

ID No. Tank Status

Added By

(Action)

Support Type (floating roof only)

Column Count

Column Diameter

(ft.)

Deck Type (floating roof only)

Seal Type (floating roof only)

Year Installed

Year Removed

1 TK 001 Active PER 005




5 TK 005 Active PER 005 Column Supported Roof, Construction Type N 1 Welded Resilient seal (nonmetallic), liquid mounted, pi



8 TK 008 Removed PER 005 Column Supported Roof, Construction Type N 1.0 Welded Resilient seal (nonmetallic), liquid mounted, pi 1999

9 TK 009 Removed PER 005 Column Supported Roof, Construction Type N 1.0 Welded Resilient seal (nonmetallic), liquid mounted, pi 1999

10 TK 010 Removed PER 005 Column Supported Roof, Construction Type N 1.0 Welded Resilient sea! (nonmetallic), liquid mounted, p 1999

11 TK 011 Active PER 002 Column Supported Roof, Construction Type N 1.0 Welded Resilient seal (nonmetallic), liquid mounted, p:

12 TK 012 Active PER 004 Column Supported Roof, Construction Type N 1 Bolted, Cont. Sheet Const. 5 Ft Wide 2004


14 TK 014 Active PER 005 2012

Page 1 of 1 (b)

MINNESOTA POLLUTION CONTROL AGENCY AIR QUALITY 520 LAFAYETTE ROAD ST. PAU L, MN 55155- 4194


Action: PER 006



3 August, 2015 14:14

FACILITY DESCRIPTION: GROUPS (GP)

ID No. Group Status

Added By

(Action)

Retired By

(Action)

Include in El

Operator ID

for Item

Group Description Group Items

1 GP 001 Active PER 005 r Tanks subject to NSPS subp. Kb TK 011, TK 012, TK 014

2 GP 002 Active PER 005 r Tanks subject to State Rule TK 001, TK 002, TK 003, TK 004, TK 005, TK 006, TK 007

3 GP 003 Retired PER 002 r Baghouse Monitoring Requirements

4 GP 004 Retired PER 002 r Scrubber Monitoring Requirements

5 GP 005 Retired PER 002 r Cyclone Monitoring Requirements CE 015, CE 016, CE 018

6 GP 006 Retired PER 002 r Hammermills 1, 2, and 3 SV 007, SV 008

7 GP 007 Retired PER 002 r Hammermills 4 and 5 SV010

8 GP 008 Active PER 001 r Boilers 001 and 002 EU 001, EU 002

9 GP 009 Retired PER 002 p Boilers 003 and 004 EU 004

10 GP 010 Active PER 002 r Propane Users EU 001, EU 002, EU 059, EU 066

11 GP 011 Active PER 004 r NOx Group EU 001, EU 002, EU 059, EU 066, EU 083

12 GP 012 Retired PER 005 r Golden Lyk storage bins EU 077, EU 078, EU 079, EU 080, EU 081, EU 082, SV 024

13 GP 013 Active PER 006 P Post-1969 Industrial Process Equipment EU 007, EU 008, EU 009, EU 067

Page 1 of 1

MINNESOTA POLLUTION CONTROL AGENCY page «| 0f 67 <14 Sep, 2015 10:29 AIR QUALITY 520 LAFAYETTE ROAD

ST. »UL, COMPLIANCE PLAN CD-01 Facility Name: DENCO II LLC



NC/ CA

Type Citation Requirement

1.0 CD hdr SOURCE-SPECIFIC REQUIREMENTS

2.0 S/A Minn. R. 7007.0400, subp. 2 Application for Permit Reissuance: due 180 days before expiration of Existing Permit

3.0 CD Minn. R. 7007.0800, subp. 2 The Permittee is authorized to install and operate EUs 088, 089, 090, and 091 within 18 months after permit issuance of Permit No. 14900013-006. The units shall meet all the requirements of this permit.

4.0 CD Minn. R. 7007.0800, subp. 2 Permit Appendix: This permit contains an appendix as listed in the permit Table of Contents. The modeling parameters in Appendix I are included for reference only as described elsewhere in Table A.

5.0 LIMIT Title I Condition: Avoid major source under 40 CFR 52.21 (b)(1)(i) and Minn. R. 7007.3000; To avoid major source under 40 CFR 70.2 & Minn. R. 7007.0200; To avoid major source under 40 CFR 63.2

Production: less than or equal to 30 million gallons/year using 12-month Rolling Sum of undenatured ethanol to be calculated by the 15th day of each month for the previous 12-month period as described later in this permit.

6.0 LIMIT Title I Condition: Avoid major source under 40 CFR 52.21 (b)(1 )(i) and Minn. R. 7007.3000; To avoid major source under 40 CFR 70.2 & Minn. R. 7007.0200

Process Throughput: less than or equal to 322,000 tons/year using 12-month Rolling Sum of corn to be calculated by the 15th day of each month for the previous 12-month period as described later in this permit. This is based on a 56-pound bushel which is equivalent to 11.5 million bushels per year.

7.0 CD Title I Condition: Avoid major source under 40 CFR 52.21 (b)(1)(i) and Minn. R. 7007.3000; To avoid major source under 40 CFR 70.2 & Minn. R. 7007.0200; Minn. R. 7007.0800, subps. 4-5

Daily Ethanol Production Recordkeeping: On each day of operation, the Permittee shall calculate, record, and maintain records of the undenatured ethanol production for the previous calendar day.

8.0 CD Minn. R. 7007.0800, subps. 4-5 Monthly Ethanol Production Recordkeeping: By the 15th of the month, the Permittee shall calculate and record the following:

1) The monthly gallons of undenatured ethanol produced during the previous month based on summing the daily undenatured ethanol production record for that month, and

2) The 12-month rolling sum undenatured ethanol production for the previous 12-month period by summing the monthly undenatured ethanol production data for the previous 12 months.

9.0 CD Title I Condition: Avoid major source under 40 CFR 52.21 (b)(1)(i) and Minn. R. 7007.3000; To avoid major source under 40 CFR 70.2 & Minn. R. 7007.0200; Minn. R. 7007.0800, subps. 4-5

Daily Grain Throughput Recordkeeping: On each day of operation, the Permittee shall calculate, record, and maintain records of the daily grain accepted by the facility for the previous calendar day. This shall be based on grain receipts.

10.0 CD Minn. R. 7007.0800, subps. 4-5 Monthly Grain Throughput Recordkeeping: By the 15th of the month, the Permittee shall calculate and record the following:

1) The monthly tons of grain throughput during the previous month based on summing the daily grain throughput record for that month, and

2) The 12-month rolling sum grain throughput for the previous 12-month period by summing the monthly grain throughput data for the previous 12 months.

11.0 CD Title I Condition: Avoid major source under 40 CFR 52.21 (b)(1 )(i) and Minn. R. 7007.3000; To avoid major source under 40 CFR 70.2 & Minn. R. 7007.0200

Grain received by the facility shall only be used for production of ethanol and coproducts by the Permittee at the DENCO II LLC facility (ID No. 14900013).




Page 2 of 67 14 Sep, 2015 10:29

COMPLIANCE PLAN CD-01

12.0 CD Minn. R. 7011.1005, subp. 1 (A)-(B)

The Permittee shall clean up commodities spilled on the driveway and other facility property as required to minimize fugitive emissions to a level consistent with RACT (reasonably available control technology).

13.0 NC S/A Minn. R. 7007.0800, subp. 2 Submittal: due 180 days after Effective Date of Permit, forms GI-02, GI-03, GI-04, GI-05A, GI-05B, GI-05C, GI-05D, GI-05F, and GI-07 providing complete, accurate, and up-to-date information where this information is blank, missing, outdated, incorrect, or listed as 'TBD' in the facility description. Include Form SCP-01 to certify the information provided in the forms.

13.1 CA S/A DUPLICATE (1) Minn. R. 7007.0800, subp. 2

Submittal: due 180 days after Effective Date of Permit, forms GI-02, GI-03, GI-04, GI-05A, GI-05B, GI-05C, GI-05D, GI-05F, and GI-07 providing complete, accurate, and up-to-date information where this information is blank, missing, outdated, incorrect, or listed as 'TBD' in the facility description. Include Form SCP-01 to certify the information provided in the forms.

14.0 CD hdr OPERATIONAL REQUIREMENTS

15.0 CD 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

The Permittee shall comply with National Primary and Secondary Ambient Air Quality Standards, 40 CFR pt. 50, and the Minnesota Ambient Air Quality Standards, Minn. R. 7009.0010 to 7009.0080. Compliance shall be demonstrated upon written request by the MPCA.

16.0 CD Minn. R. 7011.0020 Circumvention: Do not install or use a device or means that conceals or dilutes emissions, which would otherwise violate a federal or state air pollution control rule, without reducing the total amount of pollutant emitted.

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

Air Pollution Control Equipment: Operate all pollution control equipment whenever the corresponding process equipment and emission units are operated.

18.0 CD Minn. R. 7007.0800, subps. 14 and 16(J)

Operation and Maintenance Plan: Retain at the stationary source an operation and maintenance plan for all air pollution control equipment. At a minimum, the O & M plan shall identify all air pollution control equipment and control practices and shall include a preventative maintenance program for the equipment and practices, a description of (the minimum but not necessarily the only) corrective actions to be taken to restore the equipment and practices to proper operation to meet applicable permit conditions, a description of the employee training program for proper operation and maintenance of the control equipment and practices, and the records kept to demonstrate plan implementation.

19.0 CD Minn. R. 7019.1000, subp. 4 Operation Changes: In any shutdown, breakdown, or deviation the Permittee shall immediately take all practical steps to modify operations to reduce the emission of any regulated air pollutant. The Commissioner may require feasible and practical modifications in the operation to reduce emissions of air pollutants. No emissions units that have an unreasonable shutdown or breakdown frequency of process or control equipment shall be permitted to operate.

20.0 CD Minn. R. 7011.0150 Fugitive Emissions: Do not cause or permit the handling, use, transporting, or storage of any material in a manner which may allow avoidable amounts of particulate matter to become airborne. Comply with all other requirements listed in Minn. R. 7011.0150.

21.0 CD Minn. R. 7030.0010 - 7030.0080 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 enforceable by the EPA Administrator or citizens under the Clean Air Act.

22.0 CD Minn. R. 7007.0800, subp. 9(A) Inspections: The Permittee shall comply with the inspection procedures and requirements as found in Minn. R. 7007.0800, subp. 9(A).

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

24.0 CD hdr PERFORMANCE TESTING

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

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26.0 CD Minn. R. 7017.2018; Minn. R. 7017.2030, subps. 1-4, Minn. R. 7017.2035, subps. 1-2

Performance Test Notifications and Submittals:

Performance Tests are due as outlined in Table A of the permit. See Table B for additional testing requirements.

Performance Test Notification (written): due 30 days before each Performance Tesl Performance Test Plan: due 30 days before each Performance Test Performance Test Pre-test Meeting: due 7 days before each Performance Test Performance Test Report: due 45 days after each Performance Test Performance Test Report - Microfiche Copy: due 105 days after each Performance Test

The Notification, Test Plan, and Test Report may be submitted in an alternative format as allowed by Minn. R. 7017.2018.

27.0 CD Minn. R. 7017.2025, subp. 3 Limits set as a result of a performance test (conducted before or after permit issuance) apply until superseded as stated in the MPCA's Notice of Compliance letter granting preliminary approval. Preliminary approval is based on formal review of a subsequent performance test on the same unit as specified by Minn. R. 7017.2025, subp. 3. The limit is final upon issuance of a permit amendment incorporating the change.

28.0 CD hdr MONITORING REQUIREMENTS

29.0 CD Minn. R. 7007.0800, subp. 4(D) Monitoring Equipment Calibration - The Permittee shall either:

1. Calibrate or replace required monitoring equipment every 12 months; or 2. Calibrate at the frequency stated in the manufactu rer's specifications.

For each monitor, the Permittee shall maintain a record of all calibrations, including the date conducted, and any corrective action that resulted. The Permittee shall include the calibration frequencies, procedures, and manufacturer's specifications (if applicable) in the Operations and Maintenance Plan. Any requirements applying to continuous emission monitors are listed separately in this permit.

30.0 CD Minn. R. 7007.0800, subp. 4(D) Operation of Monitoring Equipment: Unless otherwise noted in Tables A, B, and/or C, monitoring a process or control equipment connected to that process is not necessary during periods when the process is shutdown, or during checks of the monitoring systems, such as calibration checks and zero and span adjustments. If monitoring records are required, they should reflect any such periods of process shutdown or checks of the monitoring system.

31.0 CD hdr RECORDKEEPING

32.0 CD Minn. R. 7007.0800, subp. 5(C) Recordkeeping: Retain all records at the stationary source, unless otherwise specified within this permit, for a period of five (5) years from the date of monitoring, sample, measurement, or report. Records which must be retained at this location include all calibration and maintenance records, all original recordings for continuous monitoring instrumentation, and copies of all reports required by the permit. Records must conform to the requirements listed in Minn. R. 7007.0800, subp. 5(A).

33.0 CD Minn. R. 7007.0800, subp. 5(B) Recordkeeping: Maintain records describing any insignificant modifications (as required 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 emissions resulting from those changes.

34.0 CD Minn. R. 7007.1200, subp. 4 If the Permittee determines that no permit amendment or notification is required prior to making a change, the Permittee must retain records of all calculations required under Minn. R. 7007.1200. For expiring permits, these records shall be kept for a period of five years from the date the change was made or until permit reissuance, whichever is longer. The records shall be kept at the stationary source for the current calendar year of operation and may be kept at the stationary source or office of the stationary source for all other years. The records may be maintained in either electronic or paper format.

35.0 CD hdr REPORTING/SUBMITTALS

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36.0 CD Minn. R. 7019.1000, subp. 3 Shutdown Notifications: Notify the Commissioner at least 24 hours in advance of a planned shutdown of any control equipment or process equipment if the shutdown would cause any increase in the emissions of any regulated air pollutant. If the owner or operator does not have advance knowledge of the shutdown, notification shall be made to the Commissioner as soon as possible after the shutdown. However, notification is not required in the circumstances outlined in Items A, B and C of Minn. R. 7019.1000, subp. 3.

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

37.0 CD Minn. R. 7019.1000, subp. 2 Breakdown Notifications: Notify the Commissioner within 24 hours of a breakdown of more than one hour duration of any control equipment or process equipment if the breakdown causes any increase in the emissions of any regulated air pollutant. The 24-hour time period starts when the breakdown was discovered or reasonably should have been discovered by the owner or operator. However, notification is not required in the circumstances outlined in Items A, B and C of Minn. R. 7019.1000, subp. 2.

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

38.0 CD Minn. R. 7019.1000, subp. 1 Notification of Deviations Endangering Human Health or the Environment: As soon as possible after discovery, notify the Commissioner or the state duty officer, either orally or by facsimile, of any deviation from permit conditions which could endanger human health or the environment.

39.0 CD 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 any deviation from permit conditions which could endanger human health or the environment. Include the following information in this written description: 1. the cause of the deviation; 2. the exact dates of the period of the deviation, if the deviation has been corrected; 3. whether or not the deviation has been corrected; 4. the anticipated time by which the deviation is expected to be corrected, if not yet corrected; and 5. steps taken or planned to reduce, eliminate, and prevent reoccurrence of the deviation.

40.0 S/A Minn. R. 7007.0800, subp. 6(A)(2) Semiannual Deviations Report: due 30 days after end of each calendar half-year starting 09/12/2012 . The first semiannual report submitted by the Permittee shall cover the calendar half-year in which the permit is issued. The first report of each calendar year covers January 1 - June 30. The second report of each calendar year covers July 1 - December 31. If no deviations have occurred, the Permittee shall submit the report stating no deviations.

41.0 CD Minn. R. 7007.1150 - 7007.1500 Application for Permit Amendment: If a permit amendment is needed, submit an application in accordance with the requirements of Minn. R. 7007.1150 through Minn. R. 7007.1500. Submittal dates vary, depending on the type of amendment needed.

42.0 CD Minn. R. 7007.1400, subp. 1(H) Extension Requests: The Permittee may apply for an Administrative Amendment to extend a deadline in a permit by no more than 120 days, provided the proposed deadline extension meets the requirements of Minn. R. 7007.1400, subp. 1(H). Performance testing deadlines from the General Provisions of 40 CFR pt. 60 and pt. 63 are examples of deadlines for which the MPCA does not have authority to grant extensions and therefore do not meet the requirements of Minn. R. 7007.1400, subp. 1(H).

43.0 S/A Minn. R. 7007.0800, subp. 6(C) Compliance Certification: due 31 days after end of each calendar year starting 09/12/2012 (for the pre vious calendar year). The Permittee shall submit this to the Commissioner on a form approved by the Commissioner. This report covers all deviations experienced during the calendar year.

44.0 CD Minn. R. 7019.3000 - 7019.3100 Emission Inventory Report: due on or before April 1 of each calendar year following permit issuance, to be submitted on a form approved by the Commissioner.

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

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46.0 CD hdr REQUIREMENTS RELATED TO AIR DISPERSION MODELING SUBMITTED WITH THE APPLICATION

These are state only requirements and are not enforceable by the EPA Administrator and citizens under the Clean Air Act.


Modeled Parameters for PM10: The parameters used in PM10 modeling for permit number 14900013-006 are listed in Appendix I of this permit. The parameters describe the operation of the facility at maximum permitted capacity when it is producing ethanol and other coproducts. The purpose of listing the parameters in the appendix is to provide a benchmark for future changes.


Modeled Parameters for PM2.5: The parameters used in PM2.5 modeling for permit number 14900013-006 are listed in Appendix I of this permit. The parameter describe the operation of the facility at maximum permitted capacity when it is producing ethanol and other coproducts. The purpose of listing the parameters in the appendix is to provide a benchmark for future changes.


Equivalent or Better Dispersion (EBD) Modeling Triggers (Modeling Not Required) for PM2.5: Changes that do not require a permit amendment or that require an administrative permit amendment do not trigger the EBD Modeling Submittal requirement. The Permittee shall keep updated records on site of all modeled PM2.5 parameters and emission rates listed in Appendix I. The Permittee shall submit any changes to modeled PM2.5 parameters and emission rates with the next required modeling submittal. (Tier 3)


EBD Modeling Triggers (Modeling Required) for PM2.5: Changes that require, or would require, a minor, moderate or major permit amendment due to an increase in PM2.5 emissions and affect any modeled PM2.5 parameter or emission rate listed in Appendix I, or an addition to the information documented in Appendix I, trigger the EBD Remodeling Submittal requirement. The Permittee shall include previously made changes to modeled PM2.5 parameters and emission rates listed in Appendix I that did not previously trigger the EBD Modeling Submittal requirement with this modeling submittal. (Tier 3)

51.0 S/A 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

Submit: due before end of each 60 months following Effective Date of Permit an EBD Modeling analysis for PM2.5: The Permittee shall submit an EBD Modeling Submittal that addresses any changes made during the previous five years that did not require a permit amendment but that affected any modeled PM2.5 parameter or emission rate documented in Appendix I or an addition to the information documented in Appendix I and that did not trigger the EBD Modeling Triggers (Modeling Required) requirement. If no changes were made, send a letter to the Commissioner stating that no EBD Modeling Analysis was required.


EBD Modeling Submittal for PM2.5: For changes meeting the criteria in the EBD Modeling Triggers (Modeling Required) requirement, the Permittee shall submit an EBD modeling submittal in accordance with the current version of the MPCA Air Dispersion Modeling Guidance and shall wait for written approval (for major amendments, in the form of an issued permit amendment; for moderate amendments, in the form of a construction authorization letter) before making such changes. For minor amendments, written approval of the EBD modeling may be given before permit issuance; however, this approval applies only to the EBD modeling and not to any other changes. (Tier 3)


EBD Modeling Submittal Content for PM2.5: The information submitted must include, for stack and vent sources, source emission rate, location, height, diameters, exit velocity, exit temperature, discharge direction, use of rain caps or rain hats, and, if applicable, locations and dimensions of nearby buildings. For non-stack/vent sources, this includes the source emission rate, location, size and shape, release height, and, if applicable, any emission rate scalars, and the initial lateral dimensions and initial vertical dimensions and adjacent building heights.


Outdated EBD Baseline Modeling for PM2.5: Prior to conducting the EBD analysis, the Permittee shall use the current version of the MPCA Air Dispersion Modeling Guidance to determine if the Baseline Modeling (the most recent refined modeling demonstration) is outdated. If the Baseline Modeling is outdated, the Permittee shall update the Baseline Modeling to be consistent with the current version of the MPCA Air Dispersion Modeling Guidance. The updated modeling will become the new Baseline Modeling. This requirement does not require the Permittee to complete a new refined modeling demonstration using the revisions made for the EBD demonstration.

MINNESOTA POLLUTION CONTROL AGENCY AIR QUALITY 520 LAFAYETTE ROAD ST. PA UL, MN 55155-4194



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55.0 CD 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

EBD Modeling Results for PM2.5: The dispersion characteristics due to the revisions of the information in Appendix I must be equivalent to or better than the dispersion characteristics modeled 6/25/2012. The Permittee shall demonstrate this equivalency in the proposal.

56.0 CD Minn. Stat. Section 116.07, subds. 4a & 9; Minn. R. 7009.0020; Minn. R. 7007.0100, subp. 7(A), 7(L), & 7(M); Minn. R. 7007.0800, subp. 2

Computer Dispersion Modeling Triggers for PM2.5: The Permittee shall conduct a refined remodeling analysis in accordance with the Computer Dispersion Modeling requirements of this permit and the current version of the MPCA Air Dispersion Modeling Guidance if: (1) the results of the EBD modeling analysis do not demonstrate equivalent or better dispersion characteristics; (2) a conclusion cannot readily be made about the dispersion, or (3) the criteria in the EBD Modeling Triggers requirement are met and the Permittee has previously conducted three successive EBD analyses using the same Baseline Modeling.

57.0 S/A Minn. Stat. Section 116.07, subds. 4a & 9; Minn. R. 7009.0020; Minn. R. 7007.0100, subp. 7(A), 7(L), & 7(M); Minn. R. 7007.0800, subp. 2

Computer Dispersion Modeling Protocol: due 90 days after Submittal of updated GI-05B forms for PM2.5 refined modeling. The Permittee shall submit a Computer Dispersion Modeling Protocol that is complete and approvable by MPCA by the deadline in this requirement. This protocol will describe the proposed modeling methodology and input data, in accordance with the current version of the MPCA Air Dispersion Modeling Guidance. The protocol must be based on projected operating conditions under the next permit term.


Computer Dispersion Modeling Protocol: due 60 days after receipt of written MPCA request for revisions to the submitted protocol for PM2.5 modeling.


Computer Dispersion Modeling Results: due 270 days after receipt of written MPCA approval of Computer Dispersion Modeling Protocol for PM2.5. The Permittee shall submit a final Computer Dispersion Modeling Report that is complete and approvable by MPCA by the deadline in this requirement. The submittal shall adhere to the current version of the MPCA Air Dispersion Modeling Guidance and the approved Computer Dispersion Modeling Protocol.




Subject Item: GP 001 Tanks subject to NSPS subp. Kb Associated Items: TK011 Denatured Ethanol



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1.0 CD Minn R. 7007.0800, subp. 2 The requirements of this group apply individually to each unit listed under this group.

2.0 CD 40 CFR Section 60.116b(b); Minn. R. 7011.1520(C)


3.0 CD 40 CFR Section 60.112b(a); Minn. R. 7011.1520(C)

The storage vessel shall be equipped with a fixed roof in combination with an internal floating roof meeting the requirements of 40 CFR Section 60.112b(a)(1).

4.0 CD 40 CFR Section 60.112b(a)(1 )(ii)(B); Minn. R. 7011.1520(C)

The storage vessel shall be equipped with the following closure devices between the wall of the storage vessel and the edge of the internal floating roof consisting of two seals mounted one above the other so that each forms a continuous closure that completely covers the space between the wall of the storage vessel and the edge of the internal floating roof. The lower seal may be vapor mounted, but both must be continuous.

5.0 CD 40 CFR Section 60.113b(a)(1); Minn. R. 7011.1520(C)

Inspection before initial fill: Visually inspect the internal floating roof, the primary seal, and the secondary seal, prior to filling the storage vessel with Volatile Organic Liquid (VOL). If there are holes, tears, or other openings in the primary seal, the secondary seal, or the seal fabric, or defects in the internal floating roof, or both, the owner or operator shall repair the items before filling the storage vessel.

6.0 CD 40 CFR Section 60.113b(a)(3)(ii); Minn. R. 7011.1520(C)

Visually inspect the internal floating roof, the primary seal, and the secondary seal through manholes and roof hatches on the fixed roof at least once every 12 months after initial fill as required by this paragraph.

7.0 CD 40 CFR Section 60.113b(a)(3)(i); Minn. R. 7011.1520(C)

Visually inspect the internal floating roof, the primary seal, the secondary seal, gaskets, slotted membranes and sleeve seals (if any) each time the storage vessel is emptied and degassed, as required by this paragraph. In no event shall inspections conducted in accordance with this provision occur at intervals greater than 10 years.


Notification: If an inspection is required (under 40 CFR Section 60.113b(a)(1) or 40 CFR Section 60.113b(a)(3)(i», notify the Commissioner in writing at least 30 days prior to the filling or refilling of the storage vessel, to afford the Commissioner the opportunity to have an observer present. If the inspection is not planned and the owner or operator could not have known about the inspection 30 days in advance of the refilling the tank, the owner or operator shall notify the Commissioner at least 7 days prior to the refilling of the storage vessel. Notification shall be made by telephone immediately followed by written documentation demonstrating why the inspection was unplanned. Alternatively, this notification including the written documentation may be made in writing and sent by express mail so that it is received by the Commissioner at least 7 days prior to refilling.


Notification: Furnish the Commissioner with a report describing the internal floating roof and certifying that it meets the specifications of 40 CFR Section 60.112b(a)(1) and 40 CFR Section 60.113b(a)(1). The report shall be an attachment to the notification of actual date of initial startup required by 40 CFR Section 60.7(a)(3).


Keep a record of each inspection performed as required by 40 CFR Section 60.113b(a)(1), (a)(2), (a)(3), and (a)(4). Each record shall identify the storage vessel on which the inspection was performed and shall contain the date the vessel was inspected and the observed condition of each component of the control equipment (seals, internal floating roof, and fittings).


After each inspection required under 40 CFR Section 60.113b(a)(3) that finds holes or tears in the seal or seal fabric, or defects in the internal floating roof, or other control equipment defects listed in 40 CFR Section 60.113b(a)(3)(ii), a report shall be furnished to the Commissioner within 30 days of the inspection. The report shall indentify the storage vessel and the reason it did not meet the specifications of 40 CFR Section 60.112b(a)(1) or 40 CFR Section 60.113b(a)(3)(ii), and list each repair made.


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COMPLIANCE PLAN CD-01 Facility Name:

Permit Number:

Subject Item:

Associated Items:

DENCO II LLC

14900013-006

GP 002 Tanks subject to State Rule

TK 001 Ethanol 2 00 proof




TK 005 E-85



NCI CA



2.0 CD Minn. R. 7011.1505, subp. 3 Equip each storage tank with a submerged fill pipe.

3.0 CD Minn. R. 7007.0800, subp. 5 Recordkeeping: Maintain records showing the dimensions of each tank and an analysis showing each tank's capacity.


Facility Name:

Permit Number:

Subject Item:

Associated Items:

DENCO II LLC

14900013-006

GP 008 Boilers 001 and 002



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2.0 LIMIT Minn. R. 7011.0515, subp. 1 Total Particulate Matter: less than or equal to 0.4 lbs/million Btu heat input. The potential to emit from each unit is 0.007 Ib/MMBtu due to equipment design and allowable fuels.

3.0 LIMIT Minn. R. 7011.0515, subp. 2 Opacity: less than or equal to 20 percent opacity except for one six-minute period per hour of not more than 60 percent opacity.

This limit applies individually to each emission unit.

4.0 CD Minn. Stat. Section 116.07, subd. 4a; Minn. R. 7007.0800; Minn. R. 7011.0515, subp. 1

Fuel used: Limited to natural gas and propane; for recordkeeping requirements, see GP011.

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2.0 LIMIT Title I Condition: CAAA of 1990; Minn. Stat. Section 116.07, subds. 4a & 9 ; Minn. R. 7007.0100, subps. 7(A) & (B); Minn. R. 7007.0800, subps. 1 and 2; Title I Condition: Avoid major source under 40 CFR 52.21(b)(1 )(i) and Minn. R. 7007.3000; To avoid major source under 40 CFR 70.2 & Minn. R. 7007.0200

Fuel Usage: less than or equal to 2032787 gallons/year using 12-month Rolling Sum of total propane combustion (in all 4 units combined).

3.0 CD Title I Condition: CAAA of 1990; Minn. Stat. Section 116.07, subds. 4a & 9; Minn. R. 7007.0100, subps. 7(A) & (B); Minn. R. 7007.0800, subps. 1 and 2; Title I Condition: Avoid major source under 40 CFR 52.21 (b)(1 )(i) and Minn. R. 7007.3000; To avoid major source under 40 CFR 70.2 & Minn. R. 7007.0200

Recordkeeping: By the 15th day of each month, calculate and record the quantity of propane, in gallons, used during the previous month and during the previous 12 months (12-month rolling sum).

MINNESOTA POLLUTION CONTROL AGENCY AIR QUALITY 520 LAFAYETTE ROAD ST. PAU L, MN 55155-4194



Subject Item: GP010 Propane Users





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2.0 CD hdr EMISSION LIMIT

3.0 LIMIT Title I Condition: CAAA of 1990; Minn. Stat. Section 116.07, subds. 4a & 9; Minn. R. 7007.0100, subps. 7(A) & (B); Minn. R. 7007.0800, subps. 1 and 2; Title I Condition: Avoid major source under 40 CFR 52.21 (b)(1 )(i) and Minn. R. 7007.3000; To avoid major source under 40 CFR 70.2 & Minn. R. 7007.0200

Nitrogen Oxides: less than or equal to 28.7 tons/year calculated as a 52-week rolling sum. Compliance with the tons/year limit for GP011 is calculated using emission factors determined during most recent performance test for NOx for each unit.

4.0 CD hdr RECORDKEEPING REQUIREMENTS

5.0 CD Title I Condition: CAAA of 1990; Minn. Stat. Section 116.07, subds. 4a & 9; Minn. R. 7007.0100, subps. 7(A) & (B); Minn. R. 7007.0800, subps. 1 and 2; Title I Condition: Avoid major source under 40 CFR 52.21(b)(1)(i) and Minn. R. 7007.3000; To avoid major source under 40 CFR 70.2 & Minn. R. 7007.0200; Minn. R. 7007.0800. subp. 4 and 5

Daily Recordkeeping. On each day of operation, the Permittee shall calculate, record, and maintain a record of the total quantity of each fuel used in each item in this Group. For natural gas, this shall be based on flowmeter readings. For propane, this shall be based on delivery records.

6.0 CD Title I Condition: CAAA of 1990; Minn. Stat. Section 116.07, subds. 4a & 9; Minn. R. 7007.0100, subps. 7(A) & (B); Minn. R. 7007.0800, subps. 1 and 2; Title I Condition: Avoid major source under 40 CFR 52.21(b)(1 )(i) and Minn. R. 7007.3000; To avoid major source under 40 CFR 70.2 & Minn. R. 7007.0200; Minn. R. 7007.0800. subp. 4 and 5

Weekly Recordkeeping -- NOx emissions

By Thursday of each week, the Permittee shall calculate and record the following:

1) The NOx emissions for the previous calendar week using the daily fuel use records specified above.

2) The weekly rolling sum NOx emissions for the previous 52-week period by summing the monthly NOx emissions data.

7.0 CD Minn. R. 7007.0800, subps. 4 and 5

Monthly Recordkeeping: By the 15th of the month, the Permittee shall identify, calculate and record the following:

1) The NOx emission factor in Ib/MMBtu for the previous calendar month for each unit in GP011 as determined by the most recent performance test data. Process NOx emissions may be excluded from the emission factor or calculation if accounted for within the test.

2) The 12-month rolling sum NOx emission rates (tons/year) for the previous 12-month period by summing the monthly NOx emission rate (tons/year) for the previous 12 months.




Subject Item: GP 011 NOx Group Associated Items: EU 001 Boiler No. 1 - Boiler




EU 083 Regenerativ e Thermal Oxidizer CE027

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COMPLIANCE PLAN CD-01 Facility Name: DENCO II LLC



Calculation Method - The Permittee shall calculate compliance with the NOx limit(tons/year) using the following equations:

Monthly GP011 NOx emissions (tons/year) = EFT * THI * 8760 hours/year * 0.0005 tons/lbs

where: EFT (Emission Factor Total) = sum of Ib/MMBtu as determined during most recent stack test for each unit = EF(EU001) + EF(EU002) + EF(EU059) + EF(EU066) + EF(EU083). The emission factors are to be determined for each combustion unit and each fuel typed allowed for the units in GP011.

THI (Total Heat Input) = sum of MMBtu/hr of each individual HI for each fuel allowed for the units in GP011 = HI(EU001) + HI(EU002) + HI(EU059) + HI(EU066) + HI(EU083) = THI MMBtu/hr

9.0 CD hdr PROTOCOL FOR RE-SETTING THE EMISSION FACTOR

10.0 CD Title I Condition: CAAA of 1990; Minn. Stat. Section 116.07, subds. 4a & 9; Minn. R. 7007.0100, subps. 7(A) & (B); Minn. R. 7007.0800, subps. 1 and 2; Title I Condition: Avoid major source under 40 CFR 52.21 (b)(1)(i) and Minn. R. 7007.3000; To avoid major source under 40 CFR 70.2 & Minn. R. 7007.0200

Protocol for Verifying the Emission Factor Used For Calculating GP011 NOx Ib/hr Emissions: The Permittee shall conduct performance testing under conditions that produce the maximum NOx emission rate, using US EPA Reference Method 19 or other approved method to measure the NOx emission factor as required elsewhere in this permit. The Permittee shall report the test result in Ib/MMBtu in the performance test report required by Minn. R. 7017.2035, subp. 1.

The emission factor used for calculating NOx emissions shall be re-set to the 3-hour average emission rate in Ib/MMBtu, measured during the most recent MPCA-approved NOx emission factor performance test.

(continued)

11.0 CD Title I Condition: CAAA of 1990; Minn. Stat. Section 116.07, subds. 4a & 9; Minn. R. 7007.0100, subps. 7(A) & (B); Minn. R. 7007.0800, subps. 1 and 2; Title I Condition: Avoid major source under 40 CFR 52.21 (b)(1)(i) and Minn. R. 7007.3000; To avoid major source under 40 CFR 70.2 & Minn. R. 7007.0200

Protocol for Verifying the Emission Factor Used For Calculating NOx Emissions (continued):

The new emission factor used for calculating compliance with the NOx Ib/hr limit shall be effective upon receipt of the Notice of Compliance (NOC) letter that approves the test results and shall be incorporated into the permit during the next permit amendment.

MINNESOTA POLLUTION CONTROL AGENCY AIR QUALITY 520 LAFAYETTE ROA D ST. PAUL, MN 55155-4194




Subject Item: GP 013 Post-1969 Industrial Process Equipment

Associated Items: EU 007 Corn Bin 1 (storage bin) - Silo/Bin

EU 008 Corn Bin 2 (surge bin) - Silo/Bin

EU 009 Corn Bin 3 (storage bin) - Silo/Bin

EU 067 Bio-digester - Digester



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NC/ CA



2.0 LIMIT Minn. R. 7011.0715, subp. 1(A) Total Particulate Matter: less than or equal to 0.30 grains/dry standard cubic foot of exhaust gas unless required to further reduce emissions to comply with the less stringent limit of either Minn. R. 7011.0730 or Minn. R. 7011.0735.

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


Page 14 of 67 14 Sep, 2015 10:29

COMPLIANCE PLAN CD-01 Facility Name: DENCO1 I LLC


Subject Item: SV 005 Grain Handling Baghouse (CE 019) Associated Items: EU 005 Corn Dump Pit - Other Emission Unit





NC/ CA


1.0 CD hdr EMISSION LIMITS

2.0 LIMIT Title I Condition: Avoid major source under 40 CFR 52.21 (b)(1)(i) and Minn. R. 7007.3000; To avoid major source under 40 CFR 70.2 & Minn. R. 7007.0200

Total Particulate Matter: less than or equal to 0.46 lbs/hour using 3-hour Average

3.0 LIMIT Title I Condition: Avoid major source under 40 CFR 52.21 (b)(1)(i) and Minn. R. 7007.3000; To avoid major source under 40 CFR 70.2 & Minn. R. 7007.0200; 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 and 2

PM < 10 micron: less than or equal to 0.46 lbs/hour using 3-hour Average


PM < 2.5 micron: less than or equal to 0.46 lbs/hour using 3-hour Average

5.0 LIMIT Minn. R. 7011.1005, subp. 3(D) Opacity: less than or equal to 10 percent opacity

6.0 CD hdr POLLUTION CONTROL REQUIREMENTS (See CE 019 for monitoring and maintenance requirements).

7.0 LIMIT Title I Condition: Avoid major source under 40 CFR 52.21 (b)(1 )(i) and Minn. R. 7007.3000; To avoid major source under 40 CFR 70.2 & Minn. R. 7007.0200




MINNESOTA POLLUTION CONTROL AGENCY Page 15 of 67 14 Sep, 2015 10:29 AIR QUALITY 520 LAFAYETTE ROAD

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9.0 LIMIT Title I Condition: Avoid major source under 40 CFR 52.21 (b)(1 )(i) and Minn. R. 7007.3000; To avoid major source under 40 CFR 70.2 & Minn. R. 7007.0200; 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 and 2








13.0 CD hdr HOOD EVALUATION

14.0 CD Minn. R. 7007.0800, subps. 2, 4 & 5



15.0 CD Minn. R. 7007.0800, subps. 2, 4 & 5






Page 16 of 67 14 Sep, 2015 10:29


17.0 S/A Title I Condition: Minn. Stat. Section 116.07, subds. 4a & 9; Minn. R. 7007.0100, subps. 7(A) & (B); Minn. R. 7007.0800, subps. 1 and 2; Title I Condition: Avoid major source under 40 CFR 52.21 (b)(1)(i) and Minn. R. 7007.3000; To avoid major source under 40 CFR 70.2 & Minn. R. 7007.0200; Minn. R. 7017.2020, subp. 1












20.0 S/A Minn. R. 7017.2020, subp. 1 Testing Frequency Plan: due 60 days after Performance Test for Total Particulate Matter emissions. The plan shall specify a testing frequency based on the test data and MPCA guidance. Future performance tests based on 12-month, 36-month, or 60-month intervals, or as applicable, shall be required upon written approval of the MPCA.

21.0 S/A Minn. R. 7017.2020, subp. 1 Testing Frequency Plan: due 60 days after Performance Test for PM10 emissions. The plan shall specify a testing frequency based on the test data and MPCA guidance. Future performance tests based on 12-month, 36-month, or 60-month intervals, or as applicable, shall be required upon written approval of the MPCA.

22.0 S/A Minn. R. 7017.2020, subp. 1 Testing Frequency Plan: due 60 days after Performance Test for PM2.5 emissions. The plan shall specify a testing frequency based on the test data and MPCA guidance. Future performance tests based on 12-month, 36-month, or 60-month intervals, or as applicable, shall be required upon written approval of the MPCA.

23.0 CD Minn. R. 7007.0800, subps. 4-5; Minn. R. 7017.2020, subp. 1


24.0 CD hdr FOR POLLUTION CONTROL AND PERIODIC MONITORING REQUIREMENTS, SEE CE 019.




Subject Item: SV 016 DDGS Building Exhaust (CE 018)

Associated Items: EU 055 DDGS Storag e Pile - Other Emission Unit

EU 056 DDGS Dump Pit - Other Emission Unit

EU 057 DDGS Eleva tor - Elevator


Page 17 of 67 14 Sep, 2015 10:29


NC/ CA










6.0 CD hdr POLLUTION CONTROL REQUIREMENTS (See CE 018 for monitoring and maintenance requirements).


Visible Emissions: The Permittee shall check the stack (SV016) for any visible emissions once each day of operation.





MINNESOTA POLLUTION CONTROL AGENCY page 18 0f 67 14 Sep, 2015 10:29 AIR QUALITY 520 LAFAYETTE ROAD

ST. PAUL, MN 5SI55-3IS4 COMPLIANCE PLAN CD-01











14.0 CD hdr HOOD EVALUATION

15.0 CD Minn. R. 7007.0800, subps. 2, 4 & 5



16.0 CD Minn. R. 7007.0800, subps. 2, 4 & 5





Permit Number: 14900013- 006

Page 19 of 67 14 Sep, 2015 10:29






19.0 S/A Title I Condition: Minn. Stat. Section 116.07, subds. 4a & 9; Minn. R. 7007.0100, subps. 7(A) & (B); Minn. R. 7007.0800, subps. 1 and 2; Title I Condition: Avoid major source under 40 CFR 52.21 (b)(1 )(i) and Minn. R. 7007.3000; To avoid major source under 40 CFR 70.2 & Minn. R. 7007.0200; Minn. R. 7017.2020, subp. 1








21.0 S/A Minn. R. 7017.2020, subp. 1 Testing Frequency Plan: due 60 days after Performance Test for Total Particulate Matter emissions. The plan shall specify a testing frequency based on the test data and MPCA guidance. Future performance tests based on 12-month, 36-month, or 60-month intervals, or as applicable, shall be required upon written approval of the MPCA.

22.0 S/A Minn. R. 7017.2020, subp. 1 Testing Frequency Plan: due 60 days after Performance Test for PM10 emissions. The plan shall specify a testing frequency based on the test data and MPCA guidance. Future performance tests based on 12-month, 36-month, or 60-month intervals, or as applicable, shall be required upon written approval of the MPCA.

23.0 S/A Minn. R. 7017.2020, subp. 1 Testing Frequency Plan: due 60 days after Performance Test for PM2.5 emissions. The plan shall specify a testing frequency based on the test data and MPCA guidance. Future performance tests based on 12-month, 36-month, or 60-month intervals, or as applicable, shall be required upon written approval of the MPCA.



25.0 CD hdr FOR POLLUTION CONTROL AND PERIODIC MONITORING REQUIRMENTS, SEE CE 018




Subject Item: SV 018 Fermentation and Distillation

Associated Items: EU 018 FermenterA-3 - Fermentation Equipment














Page 20 of 67 14 Sep, 2015 10:29


NC/ CA


1.0 CD hdr EMISSION LIMIT

2.0 LIMIT Title I Condition: CAAA of 1990; Minn. Stat. Section 116.07, subds. 4a & 9; Minn. R. 7007.0100, subps. 7(A) & (B); Minn. R. 7007.0800, subps. 1 and 2; Title I Condition: Avoid major source under 40 CFR 52.21 (b)(1)(i) and Minn. R. 7007.3000; To avoid major source under 40 CFR 70.2 & Minn. R. 7007.0200


3.0 CD hdr OPERATIONAL REQUIREMENTS


Process Throughput: less than or equal to 320 gallons/minute using 8-hour Block Average Beer Feed Rate, unless a new limit is set pursuant to Minn. R. 7017.2025, subp. 3 based on the throughput recorded during the most recent MPCA-approved performance test where compliance was demonstrated. The new limit shall be implemented upon receipt of the Notice of Compliance letter granting preliminary approval. The limit is final upon issuance of a permit amendment incorporating the change. This operating parameter must remain in the permit to define the maximum capacity of the process on an hourly basis.

5.0 CD Title I Condition: to avoid major source classification under 40 CFR Section 52.21 and Minn. R. 7007.3000; To avoid major source under 40 CFR 70.2 & Minn. R. 7007.0200; Minn. R. 7007.0800, subps. 2 and 14

The Permittee shall vent emissions from EU's 018, 019, 061, 062, 063, 064, 065, 069, 070, 072, 089, 090, 091, or their replacements, that are venting through SV018 to a scrubber and prescrubber meeting the requirements of CE020 and CE029 whenever EU's 018, 019, 061, 062, 063, 064, 065, 069, 070, 072, 089, 090, 091, or their replacements, operate. The Permittee shall operate and maintain a scrubber and prescrubber meeting the requirements of CE020 and CE029 at all times that any emissions are vented to a scrubber and prescrubber meeting the requirements of CE020 and CE029. The Permittee shall document periods of non-operation of the control equipment.

6.0 CD Title I Condition: Minn. Stat. Section 116.07, subds. 4a & 9; Minn. R. 7007.0100, subps. 7(A) & (B); Minn. R. 7007.0800, subps. 1 and 2

The Permittee shall vent all emissions from EU's 018, 019, 061, 062, 063, 064, 065, 069, 070, 072, 089, 090, 091, or their replacements, that are venting through SV018 to a scrubber and prescrubber capable of achieving 96.5% destruction of VOC emissions.

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8.0 CD hdr POLLUTION CONTROL REQUIREMENTS (FOR ADDITIONAL REQUIREMENTS SEE CE020 AND CE029)


Volatile Organic Compounds: greater than or equal to 96.5 percent collection efficiency (See CE 020 and CE 029 for monitoring and maintenance requirements.)


Alternative to the above efficiency requirement, if the inlet VOC concentration is less than 200 ppm, Volatile Organic Compounds: less than or equal to 20 parts per million using 3-hour Average

11.0 CD hdr PERFORMANCE TESTING REQUIREMENTS

12.0 S/A Title I Condition: CAAA of 1990; Minn. Stat. Section 116.07, subds. 4a & 9; Minn. R. 7007.0100, subps. 7(A) & (B); Minn. R. 7007.0800, subps. 1 and 2; Minn. R. 7017.2020, subp. 1; Minn. R. 7017.2025 subp. 3.C


The performance test shall be conducted at the target process rates defined in Appendix II, using EPA Reference Method 25, 25A, 18, 320, or other method approved by MPCA in the performance test plan approval. Process throughput limits as gpm for the beer feed rate, 190 proof ethanol production rate and 200 proof ethanol production rates will be defined by the operating process rates sustained during the test pursuant to Minn. R. 7017.2025 subp. 3.C


13.0 S/A Title I Condition: Minn. Stat. Section 116.07, subds. 4a & 9; Minn. R. 7007.0100, subps. 7(A) & (B); Minn. R. 7007.0800, subps. 1 and 2; To avoid major source under 40 CFR 52.2; to avoid major source under 40 CFR 70.2 and Minn. R. 7007.0200; To avoid major source under 40 CFR 63.2; Minn. R. 7017.2020, subp. 1; Minn. R. 7017.2025 subp. 3.C

Performance Test: due 180 days after Effective Date of Permit to measure VOC control efficiency or ppm VOC from SV 018.

The performance test shall be conducted the target process rates defined in Appendix II, using EPA Reference Method 25, 25A, or other method approved by MPCA in the performance test plan approval. Process throughput limits as gpm for the beer feed rate, 190 proof ethanol production rate and 200 proof ethanol production rates will be defined by the operating process rates sustained during the test pursuant to Minn. R. 7017.2025 subp. 3.C



MINNESOTA POLLUTION CONTROL AGENCY Page 22 of 67 14 Sep, 2015 10:29 AIR QUALITY 520 LAFAYETTE ROAD ST. PAUL, MN 551 55-4194 „ fl "I COMPLIANCE PLAN CJLMJ1



14.0 S/A Minn. R. 7007.0800, subp. 2; Minn. R. 7017.2020, subp. 1; Minn. R. 7017.2025 subp. 3.C


The testing report shall contain, at a minimum, test results for acetaldehyde, methanol, acrolein, and formaldehyde. The results of the performance test shall be used to verify the emission factors used in the potential emission calculations.


15.0 CD Minn. R. 7007.0800, subp. 2; Minn. R. 7017.2020, subp. 1; Minn. R. 7017.2025 subp. 3.C


16.0 S/A Title I Condition: CAAA of 1990; Minn. Stat. Section 116.07, subds. 4a & 9; Minn. R. 7007.0100, subps. 7(A) & (B); Minn. R. 7007.0800, subps. 1 and 2; Minn. R. 7017.2020, subp. 1; Minn. R. 7017.2025 subp. 3.C

Performance Test: due 180 days after Equipment Installation of Fermentation Tank EU 091 to measure VOC emissions as mass (Ib/hr) from SV 018.

The performance test shall be conducted at the target process rates defined in Appendix II, using EPA Reference Method 25, 25A, 18, 320, or other method approved by MPCA in the performance test plan approval. Process throughput limits as gpm for the beer feed rate, 190 proof ethanol production rate and 200 proof ethanol production rates will be defined by the operating process rates sustained during the test pursuant to Minn. R. 7017.2025 subp. 3.C. (continued below)

17.0 CD Title I Condition: CAAA of 1990; Minn. Stat. Section 116.07, subds. 4a & 9; Minn. R. 7007.0100, subps. 7(A) & (B); Minn. R. 7007.0800, subps. 1 and 2; Minn. R. 7017.2020, subp. 1; Minn. R. 7017.2025 subp. 3.C


18.0 S/A Title I Condition: Minn. Stat. Section 116.07, subds. 4a & 9; Minn. R. 7007.0100, subps. 7(A) & (B); Minn. R. 7007.0800, subps. 1 and 2; To avoid major source under 40 CFR 52.2; to avoid major source under 40 CFR 70.2 and Minn. R. 7007.0200; To avoid major source under 40 CFR 63.2; Minn. R. 7017.2020, subp. 1; Minn. R. 7017.2025 subp. 3.C

Performance Test: due 180 days after Equipment Installation of Fermentation Tank EU 091 to measure VOC control efficiency or ppm VOC from SV 018.

The performance test shall be conducted at the target process rates defined in Appendix II, using EPA Reference Method 25, 25A, or other method approved by MPCA in the performance test plan approval. Process throughput limits as gpm for the beer feed rate, 190 proof ethanol production rate and 200 proof ethanol production rates will be defined by the operating process rates sustained during the test pursuant to Minn. R. 7017.2025 subp. 3.C (continued below)

19.0 CD Title I Condition: Minn. Stat. Section 116.07, subds. 4a & 9; Minn. R. 7007.0100, subps. 7(A) & (B); Minn. R. 7007.0800, subps. 1 and 2; To avoid major source under 40 CFR 52.2; to avoid major source under 40 CFR 70.2 and Minn. R. 7007.0200; To avoid major source under 40 CFR 63.2; Minn. R. 7017.2020, subp. 1; Minn. R. 7017.2025 subp. 3.C


MINNESOTA POLLUTION CONTROL AGENCY Page 23 of 67 14 Sep, 2015 10:29 AIR QUALITY ' 520 LAFAYETTE ROAD

ST. PAUL, MN 55155-4194 COMPLIANCE PLAN CD"01



20.0 S/A Minn. R. 7007.0800, subp. 2; Minn. R. 7017.2020, subp. 1; Minn. R. 7017.2025 subp. 3.C

Performance Test: due 180 days after Equipment Installation of Fermentation Tank EU 091 to measure speciated HAP emission factors.



21.0 CD Minn. R. 7007.0800, subp. 2; Minn. R. 7017.2020, subp. 1; Minn. R. 7017.2025 subp. 3.C


22.0 S/A Title I Condition: CAAA of 1990; Minn. Stat. Section 116.07, subds. 4a & 9; Minn. R. 7007.0100, subps. 7(A) & (B); Minn. R. 7007.0800, subps. 1 and 2; Minn. R. 7017.2020, subp. 1

Performance Test: due 90 days after achieving normal operation after any change to the source of the scrubber water to measure VOC emissions as mass (Ib/hr) from SV 018.

The performance test shall be conducted at worst case conditions as defined at Minn. R. 7017.2005, subp. 8, using EPA Reference Method 25, 25A, 18, 320 or other method approved by MPCA in the performance test plan approval.


23.0 S/A Title 1 Condition: Minn. Stat. Section 116.07, subds. 4a & 9; Minn. R. 7007.0100, subps. 7(A) & (B); Minn. R. 7007.0800, subps. 1 and 2; To avoid major source under 40 CFR 52.2; to avoid major source under 40 CFR 70.2 and Minn. R. 7007.0200; To avoid major source under 40 CFR 63.2; Minn. R. 7017.2020, subp. 1

Performance Test: due 90 days after achieving normal operation after any change to the source of the scrubber water to measure VOC control efficiency or VOC ppm from SV 018.

The performance test shall be conducted at worst case conditions as defined at Minn. R. 7017.2005, subp. 8, using EPA Reference Method 25, 25A, or other method approved by MPCA in the performance test plan approval.


24.0 S/A Minn. R. 7007.0800, subp. 2; Minn. R. 7017.2020, subp. 1

Performance Test: due 90 days after achieving normal operation after any change to the source of the scrubber water to measure HAP emission factors.


The performance test shall be conducted at worst case conditions as defined at Minn. R. 7017.2005, subp. 8, using EPA Reference Methods 18, or other method approved by the MPCA in the performance test plan approval. (continued below)

MINNESOTA POLLUTION CONTROL AGENCY Page 24 of 67 14 Sep, 2015 10:29 AIR QUALITY ' 520 LAFAYETTE ROAD

ST.™L«NSS„5-<™ COMPLIANCE PLAN CD-01 Facility Name: DENCO II LLC


25.0 CD Minn. R. 7007.0800, subp. 2; Minn. R. 7017.2020, subp. 1


26.0 S/A Title I Condition: to avoid major source classification under 40 CFR Section 52.21 and Minn. R. 7007.3000; To avoid major source under 40 CFR 70.2 & Minn. R. 7007.0200; Minn. R. 7017.2020, subp. 1

Performance Test: due before end of each calendar 60 months starting 04/08/2014 for total mass of VOC emissions, not to exceed 60 months between test dates. The performance test shall be conducted at worst case conditions as defined at Minn. R. 7017.2005, subp. 8, using EPA Reference Methods 18, 25A, 320, or other method approved by MPCA in the performance test plan approval. This test shall include, at a minimum, speciated results for the following HAPs of concern: acetaldehyde, hexane, methanol, and acrolein. The results of the performance test shall be used to confirm the emission factors used to calculated HAP emissions, (continued below)

27.0 CD Title I Condition: to avoid major source classification under 40 CFR Section 52.21 and Minn. R. 7007.3000; To avoid major source under 40 CFR 70.2 & Minn. R. 7007.0200; Minn. R. 7017.2020, subp. 1


28.0 CD Minn. R. 7017.2018; Minn. R. 7017.2030, subps. 1-4, Minn. R. 7017.2025 subp. 3.C, Minn. R. 7107.2035, subps. 1-2

Procedure to Increase Process Throughput Limits: 1. Performance Test Notification (written): due 90 days before performance test at an increased process throughput rate. 2. The values for the beer processing rate, 190 proof ethanol processing rate, and 200 proof processing rate sustained during the test will determine operating conditions after every stack test in accordance with Minn. R. 7017.2025 subp. 3.C. Refer to Appendix II for more stack testing requirements. 3. The Permittee may exceed the process throughput limits after notification of a performance test at a higher process throughputs is received by the MPCA. 4. The Permittee shall calculate actual emissions using the emission rate from the increased process throughput performance test beginning the date of the Performance Test Notification. 5. Performance Test Plan: due 30 days before performance test. The Test Plan will identify the new proposed maximum process throughput limits. (continued)


Procedure to Increase Process Throughput Limits (continued): 5. Performance Test Pre-Test Meeting: due 7 days before performance test. 6. Performance Test Report: due 45 days after performance test. 7. Performance Test Report - Microfiche Copy: due 105 days after each performance test.

The Notification, Test Plan and Test Report may be submitted in an alternative format as allowed by Minn. R. 7017.2018.


Procedure to Authorize Reverse Osmosis Reject Water as input for CE020: 1. Performance Test Notification (written): due 90 days before performance test at the defined reverse osmosis reject water flow rate to be authorized as input for CE020. 2. The values for reverse osmosis reject water flow rate during the test will determine operating conditions after every stack test in accordance with Minn. R. 7017.2025 subp. 3.C. 3. The Permittee may use reverse osmosis reject water as input for CE020 after notification of a performance test with reverse osmosis reject water is received by the MPCA. 4. The Permittee shall calculate actual emissions using the emission rate from the reverse osmosis reject water performance test beginning the date of change to reverse osmosis reject water. (continued)




Page 25 of 67 14 Sep, 2015 10:29



Procedure to Authorize Reverse Osmosis Reject Water as input for CE020(continued): 5. Performance Test Plan: due 30 days before performance test. The Test Plan will identify defined reverse osmosis reject water flow rate limit as input for CE020. 6. Performance Test Pre-Test Meeting: due 7 days before performance test. 7. Performance Test Report: due 45 days after performance test. 8. Performance Test Report - Microfiche Copy: due 105 days after each performance test. The Notification, Test Plan, and Test Report may be submitted in an alternative format as allowed by Minn. R. 7017.2018.


Performance Test Recordkeeping: During each performance test the Permittee shall record and maintain the required items as detailed in Appendix II. These records shall be included with the performance test results and submitted to the Commissioner with the performance test report.

33.0 CD hdr FOR POLLUTION CONTROL AND PERIODIC MONITORING REQUIREMENTS, SEE CE020 AND CE029




Subject Item: SV019 Dryer (CE021 and CE027)




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NCI CA





3.0 LIMIT Minn. R. 7011.0610, subp. 1.A(1) Total Particulate Matter: less than or equal to 0.070 grains/dry standard cubic foot or the allowable concentration at the exhaust flow rate, as described in Minn. R. 7011.0735.

4.0 LIMIT Title I Condition: CAAA of 1990; 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 and 2; Title I Condition: Avoid major source under 40 CFR 52.21 (b)(1 )(i) and Minn. R. 7007.3000; To avoid major source under 40 CFR 70.2 & Minn. R. 7007.0200

PM <10 micron: less than or equal to 7.11 lbs/hour using 3-hour Average

5.0 LIMIT Title I Condition: CAAA of 1990; 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 and 2; Title I Condition: Avoid major source under 40 CFR 52.21 (b)(1 )(i) and Minn. R. 7007.3000; To avoid major source under 40 CFR 70.2 & Minn. R. 7007.0200


6.0 LIMIT Minn. R. 7011.0610, subp. 1.A(2) Opacity: less than or equal to 20 percent opacity except for one six-minute period per hour of not more than 60 percent opacity.



8.0 LIMIT Title I Condition: CAAA of 1990; Minn. Stat. Section 116.07, subds. 4a & 9; Minn. R. 7007.0100, subps. 7(A) & (B); Minn. R. 7007.0800, subps. 1 and 2; Title I Condition: Avoid major source under 40 CFR 52.21 (b)(1)(i) and Minn. R. 7007.3000; To avoid major source under 40 CFR 70.2 & Minn. R. 7007.0200

Carbon Monoxide: less than or equal to 9.0 lbs/hour using 3-hour Average

MINNESOTA POLLUTION CONTROL AGENCY Page27of67 14Sep,2015 10:29 AIR QUALITY '

I APAVPTTF RflAn

ST. P AUL, MN 5 5155-4194 COMPLIANCE PLAN CD-01 Facility Name: DENCO II LLC


9.0 CD hdr POLLUTION CONTROL REQUIREMENTS, SEE CE021 AND CE027 FOR MONITORING AND MAINTENANCE REQUIREMENTS

10.0 LIMIT Title I Condition: Minn. Stat. Section 116.07, subds. 4a & 9; Minn. R. 7007.0100, subps. 7(A) & (B); Minn. R. 7007.0800, subps. 1 and 2; Title I Condition: Avoid major source under 40 CFR 52.21 (b)(1)(i) and Minn. R. 7007.3000; To avoid major source under 40 CFR 70.2 & Minn. R. 7007.0200



The Permittee shall operate and maintain the control equipment such that it achieves an overall collection efficiency for Carbon Monoxide: greater than or equal to 90.0 percent collection efficiency

12.0 LIMIT Title I Condition: Minn. Stat. Section 116.07, subds. 4a & 9; Minn. R. 7007.0100, subps. 7(A) & (B); Minn. R. 7007.0800, subps. 1 and 2; Title I Condition: Avoid major source under 40 CFR 52.21 (b)(1 )(i) and Minn. R. 7007.3000; To avoid major source under 40 CFR 70.2 & Minn. R. 7007.0200






15.0 CD Minn. R. 7007.0800, subp. 2 Thermal Oxidizer Breakdown (CE027): In the event o f a breakdown of the thermal oxidizer, the Permittee shall stop feed to the dryer as soon as the breakdown is discovered. Dryer operation may continue only as long as necessary to empty the dryer. The Permittee shall also submit the notification required by Minn. R. 7019.1000, subp. 2, if required.

16.0 CD hdr TESTING REQUIREMENTS


" COMPLIANCE PLAN CD-01 Facility Name: DENCO II LLC



Performance Test: due 180 days after Effective Date of Permit to measure Total Particulate Matter emissions (Ib/hr) from SV 019.




Performance Test: due 180 days after Effective Date of Permit to measure PM10 emissions (Ib/hr) from SV019.




Performance Test: due 180 days after Effective Date of Permit to measure PM2.5 emissions (Ib/hr) from SV 019.




Performance Test: due 180 days after Effective Date of Permit to measure CO emissions (Ib/hr) from SV 019.

The performance test shall be conducted at worst case conditions as defined at Minn. R. 7017.2005, subp. 8, using EPA Reference Method 10, or other method approved by MPCA in the performance test plan approval.


MINNESOTA POLLUTION CONTROL AGENCY AIR QUALITY 520 LAFAYETTE ROAD ST. P AUL, MN 55155-4194



Page 29 of 67 14 Sep, 2015 10:29






22.0 S/A Minn. R. 7007.0800, subp. 2; Minn. R. 7017.2020, subp. 1





23.0 S/A Title I Condition: Minn. Stat. Section 116.07, subds. 4a & 9; Minn. R. 7007.0100, subps. 7(A) & (B); Minn. R. 7007.0800, subps. 1 and 2; To avoid major source under 40 CFR 52.21; to avoid major source under 40 CFR 70.2 and Minn. R. 7007.0200; To avoid major source under 40 CFR 63.2; Minn. R. 7017.2020, subp. 1

Performance Test: due 180 days after Effective Date of Permit to measure the S02 emission factor for SV 019.

The performance test shall be conducted at worst case conditions as defined at Minn. R. 7017.2005, subp. 8, using EPA Reference Method 6C, or other method approved by MPCA in the performance test plan approval.





Facility Name:

Permit Number:

Subject Item:

Associated Items:

DENCO II LLC

14900013-006

SV 020 Biodigester Flare

EU 067 Bio-digester - Digester

Page 30 of 67 14 Sep, 2015 10:29


NCI CA


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


Visible Emissions: The Permittee shall check the stack (SV020) for any visible emissions once each day of operation during daylight hours.


Facility Name:

Permit Number:

Subject Item:

Associated Items:

DENCO II LLC

14900013-006


GP010 Propane Users

GP 011 NOx Grou p

SV 017 New Boiler Stack

Page 31 of 67 14 Sep, 2015 10:29


NC/ CA


1.0 CD Minn. R. 7005.0100, subp. 35a Fuel used: Limited to natural gas and propane.

2.0 CD 40 CFR Section 60.48c(g); Minn. R. 7011.0570

Recordkeeping: By the 15th day of each month, record the amount of fuel used during the previous month. These records may consist of fuel bill or meter readings.

of 67 14 Sep, 2015 10:29



Subject Item: EU 060 Hammermill - Milling Equipment

Associated Items: CE 024 Fabric Filter - L ow Temperature, i.e., T<180 Degrees F

SV 021 Hammermill Baghouse

NC/ CA



2.0 LIMIT Title I Condition: 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 and 2; Title I Condition: Avoid major source under 40 CFR 52.21 (b)(1)(i) and Minn. R. 7007.3000; To avoid major source under 40 CFR 70.2 & Minn. R. 7007.0200


3.0 LIMIT Title 1 Condition: 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 and 2; Title I Condition: Avoid major source under 40 CFR 52.21 (b)(1)(i) and Minn. R. 7007.3000; To avoid major source under 40 CFR 70.2 & Minn. R. 7007.0200


4.0 LIMIT Title I Condition: 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 and 2; Title I Condition: Avoid major source under 40 CFR 52.21 (b)(1 )(i) and Minn. R. 7007.3000; To avoid major source under 40 CFR 70.2 & Minn. R. 7007.0200



6.0 CD hdr POLLUTION CONTROL REQUIREMENTS (See CE 024 for additional requirements)

MINNESOTA POLLUTION CONTR OL AGENCY AIR QUALITY 520 LAFAYETTE ROAD ST. PAUL, MN 55155-4194




Page 33 of 67 14 Sep, 2015 10:29


Subject Item: EU 066 DDGS Dryer - Dryer/Oven, indirect fired

Associated Items: CE 021 Multiple Cyclone w/o Fly Ash Reinjection - Most Multiclones

CE 027 Direct Fl ame Afterburner

GP010 Propane Users

GP011 NOx Group

SV 019 Dryer (CE021 and CE027)

NC/ CA


1.0 CD Minn. R. 7005.0100, subp. 35a Fuel used: Limited to natural gas, propane and bio-digester gas from EU 067; for recordkeeping requirements, see GP011.

2.0 CD hdr OPERATING REQUIREMENTS

3.0 CD Minn. R. 7007.0800, subp. 2 Thermal Oxidizer Breakdown: In the event of a breakdown of the thermal oxidizer, the Permittee shall stop feed to the dryer as soon as the breakdown is discovered. Dryer operation may continue only as long as necessary to empty the dryer. The Permittee shall also submit the notification required by Minn. R. 7019.1000, subp. 2, if required.

4.0 CD Minn. R. 7007.0800, subp. 2 Wet cake storage limitation: When wet cake by-product is produced, it will be stored for no more than 72 hours on-site unless the outside temperature is less than 55 degrees F (daily maximum). In all cases, the wet cake will be moved off-site as soon as possible.


Temperature: less than or equal to 1350 degrees F using 1-Hour Average

6.0 CD Title I Condition: Avoid major source under 40 CFR 52.21 (b)(1)(i) and Minn. R. 7007.3000; To avoid major source under 40 CFR 70.2 & Minn. R. 7007.0200

Recordkeeping: Observe and record the dryer inlet temperature once each day the dryer is operated

7.0 CD hdr CENTRIFUGE AND SYRUP FEED RATE REQUIREMENTS

8.0 LIMIT Minn. R. 7017.2025, subp. 3(A) Centrifuge Feedrate Process Throughput: less than or equal to 310 gallons/minute using 1-Hour Average

9.0 CD Minn. R. 7007.0800, subps. 4C and subp. 5

Recordkeeping: The permittee shall record dryer centrifuge feed rate as a 24-hour average once each day of operation

10.0 CD Minn. R. 7007.0800, subps. 4C and 5

The Permittee shall maintain and operate a flow monitoring device that continuously indicates and records the centrifuge flowrate to the dryer. The monitoring device shall have a margin of error of no more than +/- 2 percent of the flowrate being measured. The recording device shall also calculate the 24-hour average flowrate.

11.0 LIMIT Minn. R. 7017.2025, subp. 3(A) Syrup Feedrate Process Throughput: less than or equal to 49 gallons/minute using 1-Hour Average

12.0 CD Minn. R. 7007.0800, subps. 4C and 5

Recordkeeping: The permittee shall record the dryer syrup feed rate as a 24-hour average once each day of operation


The Permittee shall maintain and operate a flow monitoring device that continuously indicates and records the syrup flowrate to the dryer. The monitoring device shall have a margin of error of no more than +/- 2 percent of the flowrate being measured. The recording device shall also calculate the 24-hour average flowrate.

14.0 CD hdr MAINTENANCE REQUIREMENTS

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15.0 CD Minn. R. 7007.0800, subp. 14 and 7007.0800, subp. 15J

RTO (CE 027) burnouts and other maintenance activities: During R TO burnouts and any other maintenance for which the manufacturer recommends that dryer emissions bypass the RTO, the dryer (EU 066) shall be shutdown. Wet DD GS shall be stored and handled in a manner to minimize VOC emissions and odors during these maintenance activities.

The Permittee shall maintain a record of such maintenance activities in the O and M Plan for CE 027.

MINNESOTA POLLUTION CONTROL AGENCY AIR QU ALITY 520 LAFAYETTE ROAD ST. PAUL, MN 55155-4194


Facility Name:

Permit Number:

Subject Item:

Associated Items:'

DENCO II LLC

14900013-006

EU 071 Cooling Cyclone - Cooler

SV 022 Cooling Cyclone Stack

Page 35 of 67 14 Sep, 2015 10:29


NC/ CA



2.0 LIMIT Title I Condition: Minn. Stat. • Section 116.07, subds. 4a & 9; Minn. R. 7007.0100, subps. 7(A) & (B); Minn. R. 7007.0800, subps. 1 and 2; Title I Condition: Avoid major source under 40 CFR 52.21 (b)(1)(i) and Minn. R. 7007.3000; To avoid major source under 40 CFR 70.2 & Minn. R. 7007.0200







6.0 LIMIT Title I Condition: CAAA of 1990; Minn. Stat. Section 116.07, subds. 4a & 9; Minn. R. 7007.0100, subps. 7(A) & (B); Minn. R. 7007.0800, subps. 1 and 2; to avoid major source classification under 40 CFR Section 70.2 and Minn. R. 7007.0200

Volatile Organic Compounds: less than or equal to 3.0 lbs/hour using 3-hour Average measured on a total mass of VOC basis

7.0 CD hdr MONITORING REQUIREMENTS

8.0 CD Title I Condition: Avoid major source under 40 CFR 52.21 (b)(1)(i) and Minn. R. 7007.3000; To avoid major source under 40 CFR 70.2 & Minn. R. 7007.0200; Minn. R. 7007.0800, subps. 2 and 14; Minn. R. 7007.0800, subps. 2 and 14

Operation and Maintenance of the Cooling Cyclone: The Permittee shall operate and maintain the control device according to the equipment manufacturer's specifications.

9.0 LIMIT Title I Condition: Avoid major source under 40 CFR 52.21 (b)(1)(i) and Minn. R. 7007.3000; To avoid major source under 40 CFR 70.2 & Minn. R. 7007.0200; Minn. R. 7007.0800, subps. 2 and 14; Minn. R. 7007.0800, subps. 2 and 14



ST,„UUMH COMPLIANCE PLAN CD-01 Facility Name: DENCO II LLC


10.0 CD Title I Condition: Avoid major source under 40 CFR 52.21(b)(1)(i) and Minn. R. 7007.3000; To avoid major source under 40 CFR 70.2 & Minn. R. 7007.0200; Minn. R. 7007.0800, subps. 2 and 14; Minn. R. 7007.0800, subps. 4 and 5

Recordkeeping of Pressure Drop. 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.

11.0 CD Minn. R. 7007.0800, subp. 4 Monitoring Equipment: The Permittee shall install and maintain the necessary monitoring equipment for measuring and recording pressure drop as required by this permit. The monitoring equipment must be installed, in use, and properly maintained when the monitored control device is in operation.

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


13.0 CD Minn. R. 7007.0800, subp. 2 Inspect quarterly, or as required by manufacturing specifications, all components that are not subject to wear or plugging, including structural components, housings, ducts, and hoods. Maintain a written record of the inspection and any action resulting from the inspection.

14.0 CD Minn. R. 7007.0800, subp. 2 Inspect quarterly, or as required by manufacturing specifications, all components that are subject to wear or plugging. Maintain a written record of the inspection and any action resulting from the inspection.



16.0 CD hdr TESTING REQUIREMENTS

17.0 S/A Title I Condition: Avoid major source under 40 CFR 52.21 (b)(1)(i) and Minn. R. 7007.3000; To avoid major source under 40 CFR 70.2 & Minn. R. 7007.0200; Minn. R. 7017.2020, subp. 1

Performance Test: due 180 days after Effective Date of Permit to measure Total Particulate Matter emissions (Ib/hr) from EU 071.




Performance Test: due 180 days after Effective Date of Permit to measure PM10 emissions (Ib/hr) from EU 071.


Testing conducted during the 60 days prior to the performance test due date satisfies the performance test due date, and will not reset the test due date for future testing as required: 1) by th is permit; 2) by the most recently approved Performance Test Frequency Plan; or 3) within a Notice of Compliance letter. Testing conducted more than two months prior to the performance test due date satisfies this test due date requirement and will reset the performance test due date.




Page 37 of 67 14 Sep, 2015 10:29



Performance Test: due 180 days after Effective Date of Permit Performance Test: due 180 days after Effective Date of Permit to measure PM2.5 emissions (Ib/hr) from Eu 071.



20.0 S/A Title I Condition; Avoid major source under 40 CFR 52.21 (b)(1)(i) and Minn. R. 7007.3000; To avoid major source under 40 CFR 70.2 & Minn. R. 7007.0200; Minn. R. 7017.2020, subp. 1

Performance Test: due 180 days after Effective Date of Permit to measure VOC emissions as mass (Ib/hr) from EU 071.











Page 38 of 67 14 Sep, 2015 10:29



Subject Item: EU 084 Hammermill 2 - Milling Equipment

Associated Items: CE 028 Fabric Filter - Low Temperature, i.e., T<180 Degrees F

SV 025 Hammermill #2

NC/ CA





3.0 LIMIT Title I Condition: 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 and 2; Title I Condition: Avoid major source under 40 CFR 52.21 (b)(1 )(i) and Minn. R. 7007.3000; To avoid major source under 40 CFR 70.2 & Minn. R. 7007.0200





6.0 CD hdr POLLUTION CONTROL REQUIREMENTS (See CE 028 for additional requirements)


Page 39 of 67 14 Sep, 2015 10:29



Subject Item: EU 092 Ethanol Loadout - Loading-Unloading Equipment

Associated Items: CE 025 Flaring

SV 023 Ethanol loadout flare

NC/ CA


1.0 CD Minn. R. 7007.0800, subp. 16(J) Railcar Loadout: Railcars dedicated to ethanol are not required to be vented to the loadout flare (CE025). All other railcars must be vented to the loadout flare (CE025).




Subject Item: CE018 Centrifugal Collector - High Efficiency

Associated Items: EU 056 DDGS Dump Pit - Other Emission Unit



NC/ CA


1.0 CD hdr EMISSION AND OPERATIONAL LIMITS (SEE SV 016 FOR POLLUTION CONTROL REQUIREMENTS)

2.0 CD Title I Condition: Avoid major source under 40 CFR 52.21 (b)(1 )(i) and Minn. R. 7007.3000; To avoid major source under 40 CFR 70.2 & Minn. R. 7007.0200; Minn. R. 7007.0800, subps. 2 and 14

The Permittee shall vent emissions from EU's 056, 057, 058 to CE 018 whenever EU's 056, 057, and 058 operate, and operate and maintain CE 018 at all times that any emissions are vented to CE 018. The Permittee shall document periods of non-operation of the control equipment.

3.0 LIMIT Title I Condition: Avoid major source under 40 CFR 52.21 (b)(1)(i) and Minn. R. 7007.3000; To avoid major source under 40 CFR 70.2 & Minn. R. 7007.0200; Minn. R. 7007.0800, subps. 2 and 14


4.0 CD hdr MONITORING AND RECORDKEEPING

5.0 CD Title I Condition: Avoid major source under 40 CFR 52.21 (b)(1)(i) and Minn. R. 7007.3000; To avoid major source under 40 CFR 70.2 & Minn. R. 7007.0200; Minn. R. 7007.0800, subps.2 and 14

Daily Inspections: The Permittee shall do the following, once every 24 hours: 1). Read and record the pressure drop across the centrifugal collector.

6.0 CD Title I Condition: Avoid major source under 40 CFR 52.21 (b)(1)(i) and Minn. R. 7007.3000; To avoid major source under 40 CFR 70.2 & Minn. R. 7007.0200; Minn. R. 7007.0800, subps. 2 and 14










Page 41 of 67 14 Sep, 2015 10:29




11.0 CD Minn. R. 7007.0800, subp. 14 The Permittee shall operate and maintain the control device in accordance with the Operation and Maintenance (O & M) Plan. The Permittee shall keep copies of the O & M Plan available onsite for use by staff and MPCA staff.


Page 42 of 67 14 Sep, 2015 10:29







NCI CA




The Permittee shall vent emissions from EU's 005, 006, and 010 to CE 019 whenever EU's 005, 006, and 010 operate, and operate and maintain CE 019 at all times that any emissions are vented to CE 019. The Permittee shall document periods of non-operation of the control equipment.

3.0 LIMIT Title I Condition: Avoid major source under 40 CFR 52.21 (b)(1 )(i) and Minn. R. 7007.3000; To avoid major source under 40 CFR 70.2 & Minn. R. 7007.0200; Minn. R. 7007.0800, subps. 2 and 14









8.0 CD Minn. R. 7007.0800, subp. 4 Monitoring Equipment: The Permittee shall install and maintain the necessary monitoring equipment for measuring and recording pressure drop as required by this permit. The monitoring equipment must be installed, in use, and properly maintained when the monitored fabric filter is in operation.



MINNESOTA POLLUTION CONTROL AGENCY AIR QUALITY 520 LAFAYETTE ROAD ST. PAUL. MN 55155-4194



Page 43 of 67 14 Sep, 2015 10:29


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


11.0 CD Minn. R. 7007.0800, subp. 14 The Permittee shall operate and maintain the fabric filter in accordance with the Operation and Maintenance (O & M) Plan. The Permittee shall keep copies of the O & M Plan available onsite for use by staff and MPCA staff.




Subject Item: CE 020 Packed-Gas Adsorption Column

Associated Items: EU018 FermenterA-3 - Fermentation Equipment




EU 0'63 Fermen ter - Fermentation Equipment










Page 44 of 67 14 Sep, 2015 10:29


NC/ CA


1.0 CD hdr EMISSION AND OPERATIONAL LIMITS



3.0 CD Title I Condition: to avoid major source classification under 40 CFR Section 52.21 and Minn. R. 7007.3000; To avoid major source under 40 CFR 70.2 & Minn. R. 7007.0200; Minn. R. 7007.0800, subps.2 and 14




The Permittee shall operate CE029 and CE020 in series at all times that any emissions are vented to CE029 and CE020. CE020 shall operate downstream from CE029.

5.0 LIMIT Title I Condition: Avoid major source under 40 CFR 52.21 (b)(1)(i) and Minn. R. 7007.3000; To avoid major source under 40 CFR 70.2 & Minn. R. 7007.0200; Minn. R. 7007.0800, subps. 2 and 14; Minn. R. 7017.2025


6.0 LIMIT Title I Condition: Avoid major source under 40 CFR 52.21 (b)(1 )(i) and Minn. R. 7007.3000; To avoid major source under 40 CFR 70.2 & Minn. R. 7007.0200; Minn. R. 7007.0800, subps. 2 and 14; Minn. R. 7017.2025

Water flow rate: greater than or equal to 25 gallons/minute absolute minimum, unless a new minimum is set pursuant to Minn. R. 7017.2025, subp. 3 based on the values recorded during the most recent MPCA-approved performance test where compliance was demonstrated. The new limit shall be implemented upon receipt of the Notice of Compliance letter granting preliminary approval. The limit is final upon issuance of a permit amendment incorporating the change. If the flow rate is below the minimum, the VOC used during that time shall be considered uncontrolled until the flow rate is above the minimum. This shall be reported as a deviation.

MINNESOTA POLLUTION CONTROL AGENCY Page 45 of 67 14Sep,2015 10:29 AIR QUALITY ' 520 LAFAYETTE ROAD

Sr.PAUL.MN S5I55-4I94 COMPLIANCE PLAN CD-01




Liquid Flow Rate: greater than or equal to 110 milliliter/minute of either sodium bisulfite (SBS) or ammonium bisulfite (ABS), unless a new minimum is set pursuant to Minn. R. 7017.2025, subp. 3 based on the values recorded during the most recent MPCA-approved performance test where compliance was demonstrated. The new limit shall be implemented upon receipt of the Notice of Compliance letter granting preliminary approval. The limit is final upon issuance of a permit amendment incorporating the change. If the additive rate is below the minimum, the VOC used during that time shall be considered uncontrolled.


Water Supply Source: De-ironed well water. The Permittee may use reverse osmosis reject water after notifying MPCA of this change. The notification must include the percentage of water supply that will be provided by the reverse osmosis reject water and the date when the change in water supply will begin.



Daily Inspections: The Permittee shall do the following, once every 24 hours: 1. Read and record the water flow rate; 2. Read and record the scrubber additive rate; 3. Read and record the gas pressure drop across the scrubber.


Recordkeeping of Water Flow Rate, Scrubber Additive Rate, and Pressure Drop: The Permittee shall record the time and date of each water flow rate, scrubber additive rate, and pressure drop reading, and whether or not the observed flow rate, additive rate, or pressure drop was within the range specified in this permit.







Monitoring Equipment: The Permittee shall install and maintain the necessary monitoring equipment for measuring and recording pressure drop and water flow rate as required by this permit. The monitoring equipment must be installed, in use, and properly maintained when the scrubber is in operation.







Page 46 of 67 14 Sep, 2015 10:29






18.0 CD Minn. R. 7007.0800, subp. 14 The Permittee shall operate and maintain the scrubber in accordance with the Operation and Maintenance (O & M) Plan. The Permittee shall keep copies of the O & M Plan available onsite for use by staff and MPCA staff.




Page 47 of 67 14 Sep, 2015 10:29


Subject Item: CE 021 Multiple Cyclone w/o Fly Ash Reinjection - Most Multiclones


NCI CA









Daily Inspections: The Permittee shall do the following, once every 24 hours: 1). Read and record the pressure drop across the cyclone.








10.0 CD Minn. R. 7007.0800, subp. 4, 5, and 14


MINNESOTA POLLUTION CONTROL AGENCY AIR QUALITY 520 LAFAYETTE ROAD ST.PAUL, MN 55155-4194



Page 48 of 67 14 Sep, 2015 10:29


11.0 CD Minn. R. 7007.0800, subp. 14 The Permittee shall operate and maintain the control device in accordance with the Operation and Maintenance (O & M) Plan. The Permittee shall keep copies of the O & M Plan available onsite for use by staff and MPCA staff.


Page 49 of 67 14 Sep, 2015 10:29




Associated Items: EU 060 Hammermill - Milling Equipment

NC/ CA


1.0 CD hdr EMISSION AND OPERATIONAL LIMITS (See EU 060 for additional emission and operational limits)



3.0 LIMIT Title I Condition: 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 and 2; Title I Condition: Avoid major source under 40 CFR 52.21 (b)(1 )(i) and Minn. R. 7007.3000; To avoid major source under 40 CFR 70.2 & Minn. R. 7007.0200; Minn. R. 7007.0800, subps.2 and 14


4.0 LIMIT Title I Condition: 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 and 2; Title I Condition: Avoid major source under 40 CFR 52.21 (b)(1)(i) and Minn. R. 7007.3000; To avoid major source under 40 CFR 70.2 & Minn. R. 7007.0200; Minn. R. 7007.0800, subps. 2 and 14

The Permittee shall operate and maintain the control equipment such that it achieves an overall control efficiency for PM <10 micron: greater than or equal to 99.0 percent control efficiency

5.0 LIMIT Title I Condition: 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 and 2; Title I Condition: Avoid major source under 40 CFR 52.21 (b)(1 )(i) and Minn. R. 7007.3000; To avoid major source under 40 CFR 70.2 & Minn. R. 7007.0200; Minn. R. 7007.0800, subps. 2 and 14










Page 50 of 67 14 Sep, 2015 10:29













MINNESOTA POLLUTION CON TROL AGENCY AIR QUALITY 520 LAFAYETTE ROAD ST. PAUL, MN 55155-4 194

Facility Name: DENCO If LLC


Page 51 of 67 14 Sep, 2015 10:29


Subject Item: CE 025 Flaring

Associated Items: EU 076 Ethanol loadout flare - Other Combustion

EU 092 Ethanol Loadout - Loading-Unloading Equipment

NC/ CA




The Permittee shall vent emissions from EU 076, and EU 092 to CE 025 whenever EU 076, and EU 092 operates, and operate and maintain CE 025 at all times that any emissions are vented to CE 025. The Permittee shall document periods of non-operation of the control equipment.


The Permittee shall operate and maintain the control equipment such that it achieves an overall collection efficiency for Volatile Organic Compounds: greater than or equal to 95.0 percent control efficiency

4.0 CD Title I Condition: CAAA of 1990; Minn. Stat. Section 116.07, subds. 4a & 9; Minn. R. 7007.0100, subps. 7(A) & (B); Minn. R. 7007.0800, subps. 1 and 2

Opacity: not greater than 0 percent opacity using a 6-minute average except for periods not to exceed 5 minutes in any 2 consecutive hours

5.0 CD Minn. R. 7007.0800, subp. 14 Operate the flare only with a net heating value of the gas combusted of 300 Btu/scf or greater with a steam-assisted or air assisted flarre; or with the net heating value of the gas being combusted of 200 Btu/scf with a nonassisted flare

6.0 LIMIT Title I Condition: CAAA of 1990; 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 and 2; Title I Condition: Avoid major source under 40 CFR 52.21 (b)(1 )(i) and Minn. R. 7007.3000; To avoid major source under 40 CFR 70.2 & Minn. R. 7007.0200


7.0 CD hdr MONITORING AND RECORDKEEPING REQUIREMENTS

8.0 CD Minn. R. 7007.0800, subp. 14; Minn. R. 7007.0800, subp. 16(J); Minn. R. 7007.0800, subps. 4 and 5

Visible Emissions: The Permittee shall check the flare stack (SV 023) for any visible emissions once each day of operation during daylight hours while the flare is operating.

9.0 CD Title I Condition: CAAA of 1990; Minn. Stat. Section 116.07, subds. 4a & 9; Minn. R. 7007.0100, subps. 7(A) & (B); Minn. R. 7007.0800, subps. 1 and 2; Consent Decree para. 7 and 21

Monitoring Equipment: The Permittee shall install and maintain thermocouples to monitor the presence of a pilot flame. The monitoring equipment must be installed, in use, and properly maintained whenever operation of the monitored control equipment is required.


The presence of a flame shall be monitored using a thermocouple or any other equivalent device to detect the presence of a flame.


Operation Requirement: At all times, including periods of startup, shutdown and malfunction, owners shall maintain and operate any affected facility in a manner consistent with good air pollution control practice for minimizing emissions. Determination of whether acceptable operating and maintenance procedures are being used will be based on information available to the Administrator which may include, but is not limited to, monitoring results, opacity observations, review of operating and maintenance procedures, and inspection of the source.


Records Requirement: Keep a record of any startup, shutdown, or malfunction of the flare.




Page 52 of 67 14 Sep, 2015 10:29



Recordkeeping: Maintain a file of all measurements, calibration checks, adjustments and maintenance, and all other information required by this part in permanent form, suitable for inspection for at least two years following the date of such measurements, maintenance, and records.

14.0 CD Minn. R. 7007.0800, subp. 16J The Permittee shall operate and maintain the flare any time that any process equipment controlled by the flare is in operation.

15.0 CD Minn. R. 7007.0800, subp. 14 The Permittee shall operate and maintain the flare in accordance with the Operation and Maintenance (O & M) Plan. The Permittee shall keep copies of the O & M Plan available onsite for use by staff and MPCA staff.


Quarterly Inspections: At least once per calendar quarter, the Permittee shall inspect the control equipment internal and external system components, including but not limited to the refractory and electrical systems. The Permittee shall maintain a written record of the inspection and any corrective actions taken resulting from the inspection.


Corrective Actions: If a pilot flame is not present or if the flare or any of its components are found during the inspections to need repair, the Permittee shall take corrective action as soon as possible. Corrective actions shall result in return to operation of the pilot flame and/or include completion of necessary repairs identified during the inspection, as applicable. Corrective actions include, but are not limited to, those outlined in the O & M Plan for the flare. The Permittee shall keep a record of the type and date of any corrective action taken.




Subject Item: CE 027 Direct Flame Afterburner




Page 53 of 67 14 Sep, 2015 10:29


NCI CA


1.0 CD hdr EMISSION AND OPERATIONAL LIMITS (SEE SV 019 FOR ADDITIONAL POLLUTION CONTROL REQUIREMENTS)


The Permittee shall vent emissions from EU 066, EU 083, and EU 088 to CE 027 whenever EU 066, EU 083, and EU 088 operates, and operate and maintain CE 027 at all times that any emissions are vented to CE 027. The Permittee shall document periods of non-operation of the control equipment.

3.0 CD Title I Condition: Minn. Stat. Section 116.07, subds. 4a & 9; Minn. R. 7007.0100, subps. 7(A) & (B); Minn. R. 7007.0800, subps. 1 and 2; Title I Condition: Avoid major source under 40 CFR 52.21 (b)(1)(i) and Minn. R. 7007.3000; To avoid major source under 40 CFR 70.2 & Minn. R. 7007.0200

Alternative Operating Scenario: During normal operation, and whenever the regenerative thermal oxidizer (RTO) is operational, emissions from the DDGS dryer (EU 066), the RTO (EU 083), and the Yeast Propagation Tank (EU 088), must vent to the RTO (CE 027/SV 019).

During periods of RTO downtime, the Permittee may vent emissions from the Yeast Propagation Tank (EU 088) to the pre-scrubber (CE 029/SV 018), and scrubber (CE 020/SV 018).

4.0 CD Title I Condition: Minn. Stat. Section 116.07, subds. 4a & 9; Minn. R. 7007.0100, subps. 7(A) & (B); Minn. R. 7007.0800, subps. 1 and 2; Title I Condition: Avoid major source under 40 CFR 52.21 (b)(1)(i) and Minn. R. 7007.3000; To avoid major source under 40 CFR 70.2 & Minn. R. 7007.0200; Minn. R. 7007.0800, subps. 4, 5 and 11

AOS Daily Recordkeeping: The Permittee shall record daily the hours of and reasons for bypassing the RTO (CE 027/SV 019) with some or all of the emissions from EU's 066, 083, and 088. Records shall be kept in a log at the facility.


AOS Monthly Recordkeeping: Using the daily records, by the 15th day of each month, the Permittee shall calculate and record the following:

1) The total hours bypassing the RTO for the previous calender month.

2) The 12-month rolling sum of hours bypassed for the previous 12-month period by summing the monthly hours bypassed data for the previous 12 months.

6.0 LIMIT Title I Condition: CAAA of 1990; Minn. Stat. Section 116.07, subds. 4a & 9; Minn. R. 7007.0100, subps. 7(A) & (B); Minn. R. 7007.0800, subps. 1 and 2

The Permittee shall operate and maintain the control equipment such that it achieves an overall control efficiency for Volatile Organic Compounds: greater than or equal to 95.0 percent control efficiency


Alternative to the above efficiency requirement, Volatile Organic Compounds: less than or equal to 10 parts per million using 3-hour Average

8.0 LIMIT Title 1 Condition: CAAA of 1990; Minn. Stat. Section 116.07, subds. 4a & 9; Minn. R. 7007.0100, subps. 7(A) & (B); Minn. R. 7007.0800, subps. 1 and 2

The Permittee shall operate and maintain the control equipment such that it achieves an overall control efficiency for Carbon Monoxide: greater than or equal to 90.0 percent control efficiency




Page 54 of 67 14 Sep, 2015 10:2 9



Alternative to the above efficiency requirement, Carbon Monoxide: less than or equal to 100 parts per million using 3-hour Average


Temperature: greater than or equal to 1600 degrees F using 3-hour Average at the Combustion Chamber unless a new minimum is set pursuant to Minn. R. 7017.2025, subp. 3, based on the average temperature recorded during the most recent MPCA approved performance test where compliance for VOC and CO emissions was demonstrated. If the three-hour rolling average temperature drops below the minimum temperature limit, the VOC and CO shall be considered uncontrolled until the average minimum temperature limit is once again achieved. This shall be reported as a deviation.


12.0 CD Title I Condition: Minn. Stat. Section 116.07, subds. 4a & 9; Minn. R. 7007.0100, subps. 7(A) & (B); Minn. R. 7007.0800, subps. 1 and 2; Title I Condition: Avoid major source under 40 CFR 52.21 (b)(1 )(i) and Minn. R. 7007.3000; To avoid major source under 40 CFR 70.2 & Minn. R. 7007.0200; Minn. R. 7007.0800, subps. 4 and 5

The Permittee shall maintain a continuous hard copy readout or computer disk file of the temperature readings and calculated three-hour rolling average temperatures for the combustion chamber.


Daily Monitoring: The Permittee shall physically verify the operation of the temperature recording device at least once each operating day to verify that it is working and recording properly. The Permittee shall maintain a written record of the daily verifications.

14.0 CD Minn. R. 7007.0800, subp. 4 Monitoring Equipment: The Permittee shall install and maintain thermocouples to conduct temperature monitoring required by this permit. The monitoring equipment must be installed, in use, and properly maintained whenever operation of the monitored control equipment is required.


The Permittee shall maintain and operate a thermocouple monitoring device that continuously indicates and records the combustion chamber temperature of the thermal oxidizer. The monitoring device shall have a margin of error less than the greater of +/- 0.75 percent of the temperature being measured or +/- 4.5 degrees Fahrenheit. The recording device shall also calculate the three-hour rolling average combustion chamber temperature.


Quarterly Inspections: At least once per calendar quarter, the Permittee shall inspect the control equipment external system components. The Permittee shall maintain a written record of the inspection and any corrective actions taken resulting from the inspection.


Annual Inspections: At least once per calendar year, and more frequently if required by manufacturer's specifications, the Permittee shall inspect the control equipment internal components, including but not limited to, the refractory, heat exchanger, and electrical systems. Each inspection must be separated by at least 8 months. The Permittee shall maintain a written record of the inspection and any corrective actions taken resulting from the inspection.

18.0 CD Minn. R. 7007.0800, subp. 4, 5, and 14

Annual Calibration: The Permittee shall calibrate the temperature monitor at least annually and shall maintain a written record of the calibration and any action resulting from the calibration.

19.0 CD Minn. R. 7007.0800, subp. 4, 5, and 14

Corrective Actions: If the temperature is below the minimum specified by this permit or if the thermal oxidizer or any of its components are found during the inspections to need repair, the Permittee shall take corrective action as soon as possible. Corrective actions shall return the temperature to at least the permitted minimum and/or include completion of necessary repairs identified during the inspection, as applicable. Corrective actions include, but are not limited to, those outlined in the O & M Plan for the thermal oxidizer. The Permittee shall keep a record of the type and date of any corrective action taken.

20.0 CD Minn. R. 7007.0800, subp. 14 The Permittee shall operate and maintain the thermal oxidizer in accordance with the Operation and Maintenance (O & M) Plan. The Permittee shall keep copies of the O & M Plan available onsite for use by staff and MPCA staff.




Page 55 of 67 14 Sep, 2015 10:29



Associated Items: EU 084 Hammermill 2 - Milling Equipment

NC/ CA


1.0 CD hdr EMISSION AND OPERATIONAL LIMITS (See EU 084 for additonal emission and operational requirements)



3.0 LIMIT Title I Condition: Avoid major source under 40 CFR 52.21(b)(1)(f) and Minn. R. 7007.3000; To avoid major source under 40 CFR 70.2 & Minn. R. 7007.0200; Minn. R. 7007.0800, subps.2 and 14



The Permittee shall operate and maintain the control equipment such that it achieves an overall control efficiency for PM < 10 micron: greater than or equal to 99.0 percent control efficiency

5.0 LIMIT Title I Condition: Avoid major source under 40 CFR 52.21 (b)(1)(i) and Minn. R. 7007.3000; To avoid major source under 40 CFR 70.2 & Minn. R. 7007.0200; Minn. R. 7007.0800, subps.2 and 14


6.0 LIMIT Title 1 Condition: Avoid major source under 40 CFR 52.21 (b)(1)(i) and Minn. R. 7007.3000; To avoid major source under 40 CFR 70.2 & Minn. R. 7007.0200; Minn. R. 7007.0800, subps. 2 and 14










Page 56 of 67 14 Sep, 2015 10:29







Monitoring Equipment Calibration: Calibrate or replace the pressure drop every 12 months, or more or less frequently as required by the manufacturer's specifications. Maintain a written record of the calibration and any action resulting from the calibrations. If calibration frequency is based upon manufacturer's specifications, then manufacturer specifications supporting the calibration frequency must be included in the Operation and Maintenance plan.







Subject Item: CE 029 Packed-Gas Adsorption Column Associated Items: EU018 FermenterA-3 - Fermentation Equipment


EU 061 Fermen ter - Fermentation Equipment


EU 063 Ferment er - Fermentation Equipment





EU 072 Fermen ter - Fermentation Equipment




EU 091 Ferme nter - Fermentation Equipment

Page 57 of 67

COMPLIANCE PLAN

14 Sep, 2015 10:29

CD-01

NC/ CA









The Permittee shall operate CE029 and CE020 in series at all times that any emissions are vented to CE029 and CE020. CE029 shall operate upstream from CE020.




Water flow rate: greater than or equal to 90 gallons/minute absolute minimum recirculating water flow rate, unless a new minimum is set pursuant to Minn. R. 7017.2025, subp. 3 based on the values recorded during the most recent MPCA-approved performance test where compliance was demonstrated. The new limit shall be implemented upon receipt of the Notice of Compliance letter granting preliminary approval. The limit is final upon issuance of a permit amendment incorporating the change. If the flow rate is below the minimum, the VOC used during that time shall be considered uncontrolled until the flow rate is above the minimum. This shall be reported as a deviation.

MINNESOTA POLLUTION CONTROL AGENCY Page 58 of 67 14 Sep, 2015 10:29 AIR QUALITY 520 LAFAYETTE ROAD ST. PAU L, MN 55155-4194 |"\ ft1 COMPLIANCE PLAN L.U-UI



7.0 LIMIT Title I Condition: to avoid major source classification under 40 CFR Section 52.21 and Minn. R. 7007.3000; To avoid major source under 40 CFR 70.2 & Minn. R. 7007.0200; Minn. R. 7007.0800, subps. 2 and 14; Minn. R. 7017.2025

Water flow rate: greater than or equal to 2.5 gallons/minute absolute minimum output from CE029 to the beer well or other process equipment which must be equal to the water flow input from CE020, unless a new minimum is set pursuant to Minn. R. 7017.2025, subp. 3 based on the values recorded during the most recent MPCA-approved performance test where compliance was demonstrated. The new limit shall be implemented upon receipt of the Notice of Compliance letter granting preliminary approval. The limit is final upon issuance of a permit amendment incorporating the change. If the flow rate is below the minimum, the VOC used during that time shall be considered uncontrolled until the flow rate is above the minimum. This shall be reported as a deviation.


9.0 CD Title I Condition: to avoid major source classification under 40 CFR Section 52.21 and Minn. R. 7007.3000; To avoid major source under 40 CFR, 70.2 & Minn. R. 7007.0200; Minn. R. 7007.0800, subps. 2 and 14

Daily Inspections: The Permittee shall do the following, once every 24 hours: 1. Read and record the water recirculating rate 2. Read and record the water flow rate output from CE029 to the beer well or other process equipment. 3. Read and record the gas pressure drop across the scrubber.


Recordkeeping of Water Flow Rates and Pressure Drop: The Permittee shall record the time and date of water flow rate, recirculating flow rate, and pressure drop reading, and whether or not the observed flow rate, recirculating rate, or pressure drop was within the range specified in this permit.




Corrective Actions: The Permittee shall take corrective action as soon as possible if any of the following occur: - the water flow rate or reciruclating flow rate is below the minimum specified; - the recorded pressure drop is outside the required operating range; or - the scrubber or any of its components are found during the inspections to need repair. Corrective actions shall return the water flow rates to the minimum value or more, return pressure drop to within the permitted range, and/or include completion of necessary repairs identified during the inspection, as applicable. Corrective actions include, but are not limited to, those outlined in the O & M Plan for the scrubber. The Permittee shall keep a record of the type and date of any corrective action taken for the scrubber.


Monitoring Equipment: The Permittee shall install and maintain the necessary monitoring equipment for measuring and recording pressure drop, water flow rate, and recirculating flow rate as required by this permit. The monitoring equipment must be installed, in use, and properly maintained when the scrubber is in operation.




MINNESOTA POLLUTION CONTROL AGENCY AIR QUALITY 520 LAFAYETTE ROAD ST. P AUL, MN 55(55-4194



Page 59 of 67 14 Sep, 2015 10:29






17.0 CD Minn. R. 7007.0800, subp. 14 The Permittee shall operate and maintain the scrubber in accordance with the Operation and Maintenance (O & M) Plan. The Permittee shall keep copies of the O & M Plan available onsite for use by staff and MPCA staff.


Facility Name:

Permit Number:

DENCO II LLC

14900013-006

Subject Item: TK013 Denaturant

Page 60 of 67 14 Sep, 2015 10:29


NC/ CA


1.0 CD 40 CFR Section 60.116b; Minn. R. 7011.1520(C)

(d) For each storage vessel with a design capacity greater than or equal to 75 m3 (20,000 gallons) but less than 151 m3 (40,000 gallons) storing a liquid with a maximum true vapor pressure that is normally less than 27.6 kPa (4.0 ps'i), the Permittee shall notify the Commissioner within 30 days when the maximum true vapor pressure of the liquid exceeds 27.6 kPa.


Facility Name:

Permit Number:

DENCO II LLC

14900013-006

Subject Item: FS 001 Roads (truck traffic)

Page 61 of 67 14 Sep, 2015 10:29


NCI CA


1.0 CD Minn. R. 7011.0150 Fugitive emissions: Do not cause or permit the transporting of any material in a manner which may allow avoidable amounts of particulate matter to become airborne. Do not caus e or permit a road or a driveway to be constructed, used, repaired, or demolished without applying all such reasonable measures as may be required to prevent particulate matter from becoming airborne.

2.0 CD Minn. R. 7011.0150 Paved roads: The Permittee shall inspect paved roads weekly. The roads shall be cleaned if there is visible accumulation of silt and/or fugitive emissions are observed from traffic.

The Permittee shall maintain a record of the weekly inspections and corrective actions.

3.0 CD Title I Condition: 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 and 2; Title I Condition: Avoid major source under 40 CFR 52.21 (b)(1)(i) and Minn. R. 7007.3000; To avoid major source under 40 CFR 70.2 & Minn. R. 7007.0200

Grain receiving: Limited to the hours of 7 am to 5 pm Monday through Friday year round plus 7 am to 5 pm on Saturdays during the month of October.


Facility Name:

Permit Number:

DENCO II LLC

14900013-006

Subject Item: FS 002 Grain Fugitives

Page 62 of 67 14 Sep, 2015 10:29


NC/ CA


1.0 LIMIT Minn. R. 7011.1005, subp. 3(A) Opacity: less than or equal to 5 percent opacity for fugitive emissions from truck unloading of grain or grain handling activities.

2.0 CD Minn. R. 7011.1005, subp. 1(A) Clean up commodities spilled on the driveway and other facility property as required to minimize fugitive emissions to a level consistent with RACT (Reasonably Available Control Technology).


Facility Name:

Permit Number:

DENCO II LLC

14900013-006

Subject Item: FS 003 DDGS Fugitives

Page 63 of 67 14 Sep, 2015 10:29


N CI CA


1.0 LIMIT Minn. R. 7011.1005, subp. 3(A) Opacity: less than or equal to 5 percent opacity for fugitive emissions from DDGS handling activities.

2.0 LIMIT Minn. R. 7011.1005, subp. 3(B) Opacity: less than or equal to 10 percent opacity for fugitive emissions from DDGS truck loading.

3.0 CD Minn. R. 7011.1005, subp. 1(A) Clean up commodities spilled on the driveway and other facility property as required to minimize fugitive emissions to a level consistent with RACT (Reasonably Available Control Technology).

MINNESOTA POLLUTION CONTROL AGENCY page 64 of 67 14 SePi 2015 10:29 AIR QUALITY 520 LAFAYETTE ROAD



Subject Item: FS 005 Equipment Leaks (valves, flanges and seals)

NCI CA


1.0 CD 40 CFR Section 60.482-1 (a) The Permittee shall meet the requirements of 40 CFR pt. 60, subp. VV (until the affected facility becomes subject to 40 CFR pt. 60, subp. VVa) for the control of VOC emissions from leaks from equipment in VOC service.

2.0 CD hdr STANDARDS: PUMPS

3.0 CD 40 CFR Section 60.482-2(a); Minn. R. 7011.2900

Pumps in light liquid service

(a)(1) Each pump in light liquid service shall be monitored monthly to detect leaks by the methods specified in 40 CFR Section 60.485(b) except as provided in 40 CFR Section 60.482-1 (c) and paragraphs (d), (e), and (f)

(2) Each pump in light liquid service shall be checked by visual inspection each calendar week for indications of liquids dripping from the pump seal

4.0 CD 40 CFR Section 60.482-2(b) and (c)

(b)(1) If an instrument reading of 10,000 ppm or greater is measured, a leak is detected

(2) If there are indications of liquids dripping from a pump seal, a leak is detected

(c)(1)When a leak is detected, it shall be repaired as soon as practicable, but not later than 15 days after it is detected, except as provided in 40 CFR Section 60.482-9, delay of repair


5.0 CD hdr STANDARDS: COMPRESSORS

6.0 CD 40 CFR Section 60.482-3(a) Each compressor shall be equipped with a seal system that includes a barrier fluid system and that prevents leakage of VOC to the atmosphere, except as provided in 40 CFR Section 60.482-1 (c) and 40 CFR Section 60.482-3(h) and (i)

7.0 CD 40 CFR Section 60.482-3(b) (b) Each compressor seal system shall be:

(1) operated with the barrier fluid at a pressure that is greater than the compressor stuffing box pressure; or

(2) equipped with a barrier fluid system that is connected by a closed vent system to a control device that complies with the requirements of 40 CFR Section 60.482-10; or

(3) equipped with a system that purges the barrier fluid into a process stream with zero VOC emissions

8.0 CD 40 CFR Section 60.482-3(c) and (d)

(c) The barrier fluid system shall be in heavy liquid service or shall not be in VOC service

(d) Each barrier fluid system shall be equipped with a sensor that will detect failure of the seal system, barrier fluid system or both

9.0 CD 40 CFR Section 60.482-3(e) (e)(1) Each sensor shall be checked daily or equipped with an audible alarm

(2) The owner or operator shall determine, based on design considerations and operating experience, a criterion that indicates failure of the seal system, the . barrier fluid system or both

10.0 CD 40 CFR Section 60.482-3(f) (f) If the sensor indicates a failure of the seal system, barrier fluid system, or both, a leak is detected

11.0 CD 40 CFR Section 60.482-3(g) (g)(1)When a leak is detected, it shall be repaired as soon as practicable, but not later than 15 days after it is detected, except as provided in 40 CFR Section 60.482-9, delay of repair

(2) A first attempt at repair shall be made no later than 15 calendar days after each leak is detected, except as provided in 40 CFR Section 60.482-9

12.0 CD hdr STANDARDS: PRESSURE RELIEF DEVICES IN GAS/VAPOR SERVICE


s,COMPLIANCE PLAN CD-01 Facility Name: DENCO II LLC


13.0 CD 40 CFR Section 60.482-4(a) (a) Except during pressure releases, each pressure relief device in gas/vapor service shall be operated with no detectable emissions, as indicated by an instrument reading of less than 500 ppm above background, as determined by the methods specified in 40 CFR Section 60.485(c)

14.0 CD 40 CFR Section 60.482-4(b) (b)(1) After each pressure release, the PRV shall be returned to a condition of no detectable emissions, as indicated by an instrument reading of less than 500 ppm above background, as soon as practicable, but no later than 5 calendar days after the pressure release, except as provided in 40 CFR Section 60.482-9, Delay of Repair

15.0 CD hdr STANDARDS: SAMPLING CONNECTION SYSTEMS

16.0 CD 40 CFR Section 60.482-5(a) (a) Each sampling connection system shall be equipped with a closed-purge, closed-loop, or closed-vent system, except as provided in 40 CFR Section 60.482-1 (c) .


(b) Each closed-purge, closed-loop, or closed-vent system as required by 40 CFR Section 60.482-5(a) shall comply with the applicable requirement following:

(1) return the purged process fluid directly to the process line; or

(2) collect and recycle the purged process fluid to a process; or

(3) be designed and operated to capture and transport all the purged fluid to a control device that complies with the requirements of 40 CFR Section 60.482-10

(c) In-situ sampling systems are exempt from these requirements

18.0 CD hdr STANDARDS: OPEN-ENDED VALVES OR LINES

19.0 CD 40 CFR Section 60.482-6(a) (a)(1) Each open-ended valve or line shall be equipped with a cap, blind flange, plug, or second valve except as provided in 40 CFR Section 60.482-1 (c)

(2) The cap, blind flange, plug, or second valve shall seal the open end at all times except during operations requiring process fluid flow through the open-ended valve or line


(b) Each open-ended valve or line equipped with a second valve shall be operated in a manner such that the valve on the process fluid is closed before the second valve is opened

(c) When a double block-and-bleed system is being used, the bleed valve or line may remain open during operations that require venting the line between the block valves but shall comply with 40 CFR Section 60.482-6(a) at all other times

21.0 CD hdr STANDARDS:VALVES

22.0 CD 40 CFR Section 60.482-7(a) (a) Each valve shall be monitored monthly to detect leaks by the methods specified in 40 CFR Section 60.485(b)

23.0 CD 40 CFR Section 60.482-7(b) and (o)


(c)(1) Any valve for which a leak is not detected for 2 successive months may be monitored the first month of every quarter, beginning with the next quarter, until a leak is detected

(c)(2) If a leak is detected in a valve which is being monitored quarterly, the valve shall be monitored monthly until a leak is not detected for 2 successive months

24.0 CD 40 CFR Section 60.482-7(d) (d)(1) When a leak is detected, it shall be repaired as soon as practicable, but not later than 15 calendar days after it is detected, except as provided in 40 CFR Section 60.482-9


25.0 CD 40 CFR Section 60.482-7(e) (e) First attempts at repair include, but are not limited to, the following practices where practicable:

(1) tightening of bonnet bolts, (2) replacement of bonnet bolts, (3) tightening of packing gland nuts, and (4) injection of lubricant into lubricated packings

of 67 14 Sep, 2015 10:29



26.0 CD hdr STANDARDS: PUMPS AND VALVES IN HEAVY LIQUID SERVICE, PRESSURE RELIEF DEVICES IN LIGHT LIQUID OR HEAVY LIQUID SERVICE, AND FLANGES AND OTHER CONNECTIONS

27.0 CD 40 CFR Section 60.482-8(a) (a) Pumps and valves in heavy liquid service, pressure relief valves in light liquid or heavy liquid service, and flanges and other connectors shall be monitored within 5 days by the method specified in 40 CFR Section 60.485(b) if evidence of a potential leak is found by visual, audible, olfactory, or any other detection method



(c)(1) When a leak is detected, it shall be repaired as soon as practicable, but not later than 15 calendar days after it is detected, except as provided in 40 CFR Section 60.482-9, Delay of Repair


29.0 CD 40 CFR Section 60.482-8(d) (d) First attempts at repair include, but are not limited to, the practices described under 40 CFR Section 60.482-7(e)

30.0 CD hdr DELAY OF REPAIR

31.0 CD 40 CFR Section 60.482-9(a) and (b)

(a) Delay of repair of equipment for which leaks have been detected will be allowed if the repair is technically infeasible without a process unit shutdown; repair of this equipment is to occur before the end of the next process unit shutdown

(b) Delay of repair of equipment will be allowed for equipment which is isolated from the process and which does not remain in VOC service

32.0 CD 40 CFR Section 60.482-9(c) (c) Delay of repair for valves will be allowed if:

(1) the owner or operator demonstrates that emissions of purged material resulting from the immediate repair are greater than the fugitive emissions likely to result from delay of repair, and

(2) when repair procedures are effected, the purged material is collected and destroyed or recovered in a control device complying with 40 CFR Section 60.482-10

33.0 CD 40 CFR Section 60.482-9(d) (d) Delay of repair for pumps will be allowed if:

(1) Repair required the use of a dual mechanical seal system that includes a barrier fluid system, and

(2) repair is completed as soon as practicable, but not later than 6 months after the leak was detected

34.0 CD 40 CFR Section 60.482-9(e) (e) Delay of repair beyond a process unit shutdown will be allowed for a valve if valve assembly replacement is necessary during the process unit shoudown, valve asssembly supplies have been depleted, and valve assembly supplies had been sufficiently stocked before the supplies were depleted. Delay of re pair beyond the next process unit shutdown will not be allowed unless the next process unit shutdown occurs sooner than 6 months after the first process unit shutdown.

35.0 CD hdr TESTING PROCEDURES

36.0 CD 40 CFR Section 60.486(b) Compliance shall be demonstrated by the methods specified in 40 CFR Section 60.485.

37.0 CD hdr RECORDKEEPING

38.0 CD 40 CFR Section 60.496(b) (b) When each leak is detected, the following requirements apply:

(1) a weatherproof and readily visible identification, marked with the equipment identification number, shall be attached to the leaking equipment

(2) the identification on a valve may be removed after it has been monitored for 2 successive months as specified in 40 CFR Section 60.482-7(c) and no leak has been detected during those two months

(3) the identification on equipment, except on a valve, may be removed after it has been repaired



Facility Name: DENCO il LLC


Page 67 of 67 14 Sep, 2015 10:29


39.0 CD 40 CFR Section 60.486(c)(1)-(4) (c) When a leak is detected, the following information shall be recorded in a log and shall be kept for 2 years in a readily accessible location:

(1) the instrument and operator ID numbers and the equipment ID number, (2) the date the leak was detected and the dates of each attempt to repair the leak, (3) repair methods applied in each attempt to repair the leak, (4) "Above 10,000" if the instrument reading measured by the methods specified in 40 CFR Section 60.485(a) after each repair attempt is equal to or greater than 10,000 ppm

40.0 CD 40 CFR Section 60.486(c)(5)-(9) (5) "Repair delayed" and the reason for the delay if a leak is not repaired within 15 calendar days after discovery of the leak, (6) the signature of the owner or operator whose decision it was that repair could not be effected without a process shutdown, (7) the expected date of successful repair of the leak if a leak is not repaired within 15 days, (8) dates of process unit shutdowns that occur while the leaking equipment is unrepaired, and (9) the date of successful repair of the leak

41.0 CD hdr REPORTING REQUIREMENTS

42.0 S/A 40 CFR Section 60.487(a) LDAR Report: due 30 days after half-year following permit issuance The reports are due by July 30 and January 30 for the respective 6-month periods.

43.0 CD 40 CFR Section 60.487(b) The first semiannual report submitted for htis purpose shall include the following information:

(1) process unit identification (2) number of valves subject to the requirements of 40 CFR Section 60.482-7 (3) number of pumps subject to the requirements of 40 CFR Section 60.482-2 (4) number of compressors subject to the requirements of 40 CFR Section 60.482-3

44.0 CD 40 CFR Section 60.487(c)(1) and (2)(i)-(2)(iv)

(c) All semiannual reports shall include the following information summarized from the information in 40 CFR 60.486:

(1) process unit identification (2) for each month during the semiannual reporting period, (i) number of valves for which leaks were detected as described in 40 CFR Section 60.482-7(b) or 40 CFR Section 60.483-2 (ii) number of valves for which leaks were not repaired as required in 40 CFR Section 60.482-7( d)(1) (iii) number of pumps for which leaks were detected as described in 40 CFR Section 60.482-2(b) and (d)(6)(i) (iv) number of pumps for which leaks were not repaired as required in 40 CFR Section 60.482-2(c)(1) and (d)(6)(ii)

45.0 CD 40 CFR Section 60.487(c)(2)(v)-(vii)

(v) number of compressors for which leaks were detected as described in 40 CFR Section 60.482-3(f) (vi) number of compressors for which leaks were not repaired as required in 40 CFR Section 60.482-3(g)(1) (vii) the facts that explain each delay of repair and, where appropriate, why a process unit shutdown was technically infeasible

46.0 CD 40 CFR Section 60.487(c)(3) and (4)

(3) dates of process unit shutdowns which occurred within the semiannual reporting period (4) revisions to items reported according to paragraph (b) if changes have occurred since the initial report or subsequent revisions to the initial report

47.0 CD 40 CFR Section 60.487(e) (e) Report the results of all performance tests in accordance with 40 CFR Section 60.8. The provisions of 40 CFR Section 60.8 do not apply to affected facilities subject to the provisions of this subpart except that an owner or operator must notify the Administrator of the schedule for the intial performance tests at least 30 days before the initial performance tests.

DENCO II, LLC 14900013-006

Attachment 3 Points Calculator

Points Calculator

1) AQ Facility ID No.: 14900013 2) Facility Name: DENCO II, LLC 3) Small business? y/n? n 4) DQ Numbers (including all rolled): 5271 4738 5) Date of each Application Received: 06/16/15 03/31/14 6) Final Permit No. 14900013-006 7) Permit Staff Robert Little 8) "Work completed" in which .xls file (i.e. unit 2b, unit 1a, biofuels)?

Application Type DO No. Qty. Points Total Points

Administrative Amendment 4728 1 1 1 Minor Amendment 4 0 Applicability Request 10 0 Moderate Amendment 15 0 Major Amendment 5271 1 25 25 Individual State Permit (not reissuance) 50 0 Individual Part 70 Permit (not reissuance) 75 0

Additional Points Modeling Review 15 0

BACT Review 15 0 LAER Review 15 0 CAIR/Part 75 CEM analysis 10 0 NSPS Review 10 0 NESHAP Review 10 0 Case-by-case MACT Review 20 0 Netting 10 0 Limits to remain below threshold 5271 2 10 20 Plantwide Applicability Limit (PAL) 20 0 AERA review 15 0 Variance request under 7000.7000 35 0 Confidentiality request under 7000.1300 2 0 EAW review Part 4410.4300, subparts 18, item A; and 29 15 0 Part 4410.4300, subparts 8, items A & B; 10, items A to C; 16, items A ft D; 17, items A to C & E to G; and 18, items B & C

35 0

Part 4410.4300, subparts 4; 5 items A & B; 13; 15; 16, items B & C; an d 17 item D

70 0

Ack > Point r, 20 1

iTotal Points 46

Details

PT. 70, PSD

(DQ 5271)

DENCO II, LLC 14900013-006

Attachment 4 Permit Notes to be Addressed Now or Later

DENCOII

Bonnie Nelson PERMIT comments and notes July 13, 2015

Address NOW

Address LATER

Facility Description Updates X

Flow Chart Update X

Modeling Assessment X

Remodel (if determined needed) X

Calculations Updated • EU085/Prefermentation Units/Misc. PM bins/Fugitive sources • Fire Pump?

X

Calculations Updated to reflect current changes (identify EUs, bottlenecks)

X

S02 Testing for dryer/RTO for EF X

Consent Decree limits (update citations now) X X

FC • update template language X

• Add daily records X

• Update Tier modeling language X

Flexibility Provisions if desired X NSPS language Updates (Kb, Dc) Add General Provisions, update applicability decisions

X

Minn. R. 7011.1505 Should not apply to ethanol tanks

X

GP008 - add correct rule language for Minn. R. 7011.0515 X

GP010 limit for propane use Correctly identify as Consent Decree requirement

X

GP011 limit for NOx Correctly identify as Consent Decree requirement

X

• Testing for NOx emission factors for GP011 units for propane and natural gas. TO can't burn propane.

X

• Correct compliance demonstration method so it makes sense (i.e. calculate a Ib/MMBtu or Ib/hr result, can't just track daily fuel)

X

SV005 Grain Handling Add testing for PM sources relying on 99% control for PM10 and PM2.5 Identify as modeling limit

X

SV005 Grain Handling Correct Minn. R. 7011.1005 citations and requirements

X

SV005 Corn Bins Remove association with CE

X

SV005 Add hood cert for grain receiving pit, accounting for cross-drafts X

SV016DDGS Handling Add testing Identify 99% efficiency as modeling limit (efficiency for avoiding PSD may be different)

X

• Correct Minn. R. 7011.1005 citations and requirements X

• Assess that all equipment is being vented to CE X

• Add compliance requirement to submit hood evaluation for DDGS loadout accounting for cross drafts

X

SV018 Fermentation Scrubber Add short-term production limits from 12/14/10 test (beef feed <= 291 x 1.1 = 320 gpm)

X

• Assess VOC destruction efficiency for BACT-equivalent X

• Add testing for HAP EF X

• Identify if any additives added during testing to control acetaldehyde formation. Include requirement if relied upon during testing.

X

• Assess units being vented to scrubber, ensure multiple units not contained within one EU

X

SV019 Dryer • Add PM2.5 limit and testing X

• Add modeling citations to PM10 and PM2.5 limits X

• Test for HAP EF X

• Increased PM10 limit without assessing BACT-equivalency X • Assess need for uncontrolled emissions during time of RTO

breakdown X

• Add testing for S02 X

• Add short-term production limits from testing X

• Correct efficiency requirements X

SV020 Biodigester Flare EU067 has no requirements, associated with CE023 which only has hood requirements.

X

SV021 Hammermill FF EUs not in permit, add testing for PM10/PM2.5; modeling limit

X

SV022 (see EU071 cooling cyclone) SV024 DDGS loadout + misc. bins • Add testing for PM/PM10/PM2.5; modeling limit if don't have PTE

or relied up >93% efficiency • Previously identified as Golden Lyk, verified permanently removed

X

• Add hood certification and evaluation requirements X

EU071 Cooling cyclone Add modeling limits for PM10/2.5

X

• Add testing for HAP EF • Add PM2.5 limits and testing requirements

X

• Remove reference to cyclone as CE, it is a p rocess unit X

CE018 Remove hood certifications requirements X

CE020 Remove hood certification requirements X

CE021 Remove hood certification requirements X

• Assess need to identify as CE X

CE023 Flaring for Bio-digester Update requirements

X

CE024 Hammermill FF • Remove hood language

X

• Add efficiencies (99%); modeling citations X

CE025 Ethanol loadout flare Add 95% efficiency for Consent Decree, remove hood language (100% capture), add higher efficiency for avoiding PSD if relied upon in calculations

X

CE026 DDGS loadout • Add efficiencies; modeling limit

X

CE027 Add PM/PM10/PM2.5 control efficiency requirement of 60%; modeling limit and to avoid PSD

X

FS001 Truck Traffic (roads) Assess versus modeling (hours of operation limits needed?). Add requirements of fugitive dust plan from Consent Decree

X

• Some information within file states that truck traffic is 120 trucks/day; model limits on hours and days of operation (M-F, except Sat in October)

X

• Emissions calculations did not allow for the facility to accept straight trucks, they stated only hopper trucks; modeling limit

X X

FS002 Uncaptured Grain Assign EU/SV number. Modeling limits - assess

X

FS003 Uncaptured DDGS Assign EU/SV number. Modeling limits - assess

X

FS004 EthanolLoadout This is not a fugitive source. Give EU# and require that emissions be vented to flare CE025.

X

FS004 Consent Decree required all railcars to be dedicated to ethanol. Not a portion. Identify as BACT-equivalent requirements.

X

FS005 Subp. VVa Changes will likely trigger VVa. VV is in permit. Permittee needs to submit highlight pt. 63, both VVa and A.

X

FS006 Cooling Towers Provide calculations and basis for assumptions/EF; modeling limits

X

FS007 Flat storage. Modeling limits for calculation assumptions. Need to verify calculation methodology and assumptions.

X

Verify that facility does not have an emergency generator/firepump (NESHAP applicability). They do not

Done.

Verify insignificant activities • Golden Lyk (perhaps a modified DDGS product, why removed?) • Document that process permanently removed.

X Done.

Assess that all prefermentation units are in permit X Assess that all EUs have a standard of performance X Corn Bins are incorrectly characterized in permit - they vent to the atmosphere individually

X

Comments and Explanations

1. Facility Description. Please update and correct the facility description data which describes your facility operations.

a. All relevant cells must be filled in: i. Emission Unit: maximum capacity, design materials, units, commence

construction, startup date, removal date, manufacturer and model; correct any misinformation (i.e. corn bins not vented to CE)

ii. Stack/Vent: add stack parameters for new bins and equipment; ensure that values are consistent with the modeling (i.e. SV019 in FD is 80 feet, model = 67 feet)

iii. Pollution Control: List all parameters for which control is enforceable (i.e. HAPs, PM2.5, CO...), update manufacturer and model information.

iv. Fugitive Sources. 1. Uncaptured emissions from grain handling and DDGS handling are not

considered fugitive sources. Assign an EU/SV number and fill out facility description information.

2. Ethanol Loadout is not a fugitive source of emissions. Assign an EU/CE number.

3. Update pollutants, year installed v. Tank: Update all relevant cells.

2. Flow Chart. Update to reflect current facility operations. 3. Calculations. Provide a functional spreadsheet with updated calculations that reflect permit and

required modeling limits (24-hour and annual, as well as any additional operational limits and assumptions).

a. Flat Storage calculations. The emission factor used is for aggregate/minerals. Please provide documentation of an emission factor for storage of grain. A quick search of other state permits show that a significantly higher emission factor was used for grain storage (i.e. 0.1783 lb/ton for PM10 versus 0.0028 lb/ton PM10). This could result in exceeding state permitting thresholds.

b. Describe what material is put in temporary flat storage, and why it is still required. Temporary infers storage of short duration (i.e. pending construction of bins).

c. Calculations for EU076-EU085 need assessment. d. It was clear that the corn bins used a short-term Ib/hr value for modeling compliance

with the 24-hr standard, however that did not appear to be the case for grain receiving or DDGS load-out. Need to assess.

4. Modeling Limits. The facility conducted modeling in 2012 as pa rt of Permit Action 005. There were several assumptions made which were included as permit limits. The emissions calculations that did not result in permit conditions were calculated to reflect the worst-case operations of the emissions units. However, there appears to be several discrepancies between

the Ib/hr emission rates used for the modeling analysis and those provided in the calculations. It also appears that there are some sources of PM10/PM2.5 emissions that were not included in the modeling analysis.

a. Provide a reconciliation of the current Ib/hr emission calculations of PM10/PM2.5 to those used for the modeling analysis, identifying any increases or decreases of emissions.

b. Identify any sources of PM10/PM2.5 emissions at the facility that were not included in the modeling analysis. Provide an explanation if possible.

i. Specifically address uncaptured grain and DDGS handling emissions. 5. Sulfur Dioxide emissions. It is expected that the facility uses H2S04 (or other sulfur-containing

materials) at their facility as an additive. The calculations need to address S02 emissions from the dryer/RTO from sulfur-containing materials in the DDGS.

a. Testing for a S02 emission factor will be added to the permit. 6. Consent Decree limits

a. Updating citations b. Limits based upon test and set. c. Process used to change BACT-equivalent limits

7. Facility may need some instruction on what triggers a major modification. I noted that several EU were added through Emission Inventory that would have triggered a major modification, and an "existing fermenter" was added to SV018. Also, the flat storage was added and change of a tank from denatured ethanol to E-5 made through insignificant modification (rolled into 2012 major mod).

8. TSD states that cooling towers are subject to the Cooling Tower NESHAP. Verify. TSD language regarding applicability of JJJJJ needs revision.

9. No HAP limits - at their own risk. Facility could exceed major-source thresholds. With new scrubber this is less likely. Acetaldehyde emissions exceeded 9 tpy using a previous calculation methodology. Need to assess need for limit.

10. Discussion in previous TSD about ensuring that a modification did not exceed 15 tpy to trigger BACT. Ensure that permit limit reflects that any associated limit is Title I to avoid a major modification.

air emission permit no. 14900013-006 is issued to denco ii llc

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