Technical Support Document Draft Air Emission Permit No ......• STRU 11/TREA 12 (formerly SV001/CE001) – Baghouse / fabric filter will be removed. Includes the removal of units

Technical Support Document, Permit Number: 01300099-101 Page 1 of 31

Technical Support Document For

Draft Air Emission Permit No. 03900028-101 This technical support document (TSD) is intended for all parties interested in the draft 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 draft 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)

Al-Corn Clean Fuel 797 5th Street Claremont, MN 55294

Al-Corn Clean Fuel 797 5th Street Claremont, MN 55294

Contact: Jacque Paranteau, Plant Manager Phone: 507-681-7106 Dodge County

1.2 Facility description

Al-Corn Clean Fuel is a fuel-grade dry-mill ethanol plant located approximately one half mile west of Claremont, Minnesota, on Highway 14. The Facility will use up to 1.4 million tons of grain per year to produce 133.2370 million gallons of fuel-grade ethanol (denatured). The primary air emissions are volatile organic compounds (VOCs), particulate matter (PM/PM10/PM2.5), nitrogen oxides (NOX), carbon monoxide (CO), sulfur dioxide (SO2) and hazardous air pollutants (HAPs). VOCs and HAPs are emitted by fermentation, distillation, dried distiller’s grains with solubles, (DDGS) drying, ethanol loading, and VOC liquid storage and piping. Particulate matter is emitted by the DDGS drying, cooling and handling, grain receiving and handling, and vehicle traffic. NOX and CO are emitted by combustion sources. SO2 is emitted from DDGS drying (sulfuric acid is used to clean equipment and added to balance the pH). The facility will be limited to a production capacity of 133.2370 MMGal/year of denatured ethanol; a throughput capacity of 1.4 million tons/year (tpy) of grain, and 440,000 tpy of DDGS.

The primary pieces of control equipment are fabric filters, a wet scrubber, two regenerative thermal oxidizers (RTO), and two flares. The wet scrubber controls emissions from cook, fermentation and distillation units, while two RTOs are used to control emissions from distillation and drying units. Fabric filters control PM/ PM10/ PM2.5

from the grain and DDGS handling and storage systems. There are fourteen large, internal floating roof and fixed roof tanks for ethanol, denaturant, and denatured ethanol storage. The facility uses flares to control VOC emissions from the ethanol loading racks. Fugitive emissions from process valves and piping are controlled through an inspection and maintenance program.

The facility has accepted limits on the amounts of particulate matter, NOX, CO and VOCs that could be emitted to the atmosphere, so that it is classified as a non-major source under the federal New Source Review program (40 CFR § 52.21). The Permittee has also accepted limits on HAP emissions to establish the facility as an area source of hazardous air pollutants (HAPs).


1.3 Description of the activities allowed by this permit action

This permit action is for the issuance of a first-time Part 70 operating permit. This permit authorizes construction and operation of a natural gas combustion turbine with duct burner for combined heat and power, grain storage and handling equipment, expanded rail loading/unloading capabilities, equipment for fermentation, distillation, and product storage, an additional boiler, DDGS dryer, and RTO. The MPCA has a combined operating and construction permitting program under Minn. R. ch. 7007, and under Minn. R. 7007.0800. Under that authority, this permit action authorizes construction. Further, the EPCO Carbon Dioxide Products Inc. facility currently co-located with Al-Corn is expected to cease operations in 2017. However, it is authorized to continue operation.

Following permit issuance, the following changes are authorized to take place at the facility:

Removed Emission Units and Control Equipment

As part of the project, Al-Corn plans to remove the following units from the facility. The existing units are authorized to continue to operate for three years after permit issuance. Compliance requirements reflect this transition. Several emission units have also been removed from the facility.

· STRU 11/TREA 12 (formerly SV001/CE001) – Baghouse / fabric filter will be removed. Includes the removal of units controlled by TREA 12: EQUI (EU003) – Scalper, EU004 – Corn Bin #1, EQUI 51 (EU005) – Corn Bin #2, EQUI 52 (EU006) – Corn Bin #3, EQUI 53 (EU007) – Corn Bin #4, EQUI 64 (EU035) – Corn Bin #5, and EQUI 48 (EU068) – Corn Bin #7.

· STRU 12/TREA 1 (formerly SV002/CE002) – Baghouse / fabric filter will be removed. Includes the removal of units controlled by TREA 1: EQUI 77 (EU008) – Hammermill #1, EQUI 65 (EU041) – Hammermill #2, EQUI 66 (EU055) – Hammermill #3, Drag lines (EQUI 25) and Drag lines 2 (EQUI 26).

· STRU 27/TREA 10 (formerly SV003/CE010) – Packed-gas Adsorption Column will be removed. The existing Flash Tank (EQUI 10), Liquefaction Tank (EQUI 21), Cook Water Tank (EQUI 27), Slurry Tanks (previously EU020), Cook Tube (previously EU73), and Yeast Tank (EQUI 58) will be removed. Remaining units which previously vented to TREA 10 will vent to TREA 16. The existing beerwell (EQUI 34) will be repurposed as a cook water tank and will vent to STRU 37/TREA 16.

· STRU 13/EQUI 68 (formerly SV005/EU017) – Boiler #1 was removed from the facility and is not authorized to operate.

· STRU 14 (formerly SV006) - Includes the removal of EQUI 67 (EU014) – DDGS Dump Pit, EQUI 72 (EU019) – DDGS Storage, EQUI 49 (EU069) – DDGS Pit conveyor, EUQI 69 (EU015) – DDGS elevator, EQUI 23 (EU071) – DDGS loadout scale, EQUI 24 (EU072) – DDGS conveyor #2, EQUI 7 (EU033) – rail car DDGS loadout, EQUI 70 (EU016) - DDGS truck loadout and associated uncaptured emissions from EQUI 7 and EQUI 70.

· STRU 15 (formerly SV008) – DDGS Cooling Cyclone will be removed.

· STRU 23/TREA 2/EQUI 13 (formerly SV019/CE007/EU080) – Flour Transfer baghouse will be removed.

· STRU 9/TREA 4 (formerly SV021/CE009) – Baghouse / fabric filter will be removed. Includes the removal of units controlled by TREA 4: EQUI 74 (EU001) – Corn Dump #1, EQUI 75 (EU002) – Elevator, EQUI 15 (EU082) – Receiving Pit Drag Lines, EQUI 16 (EU083) – Return Conveyors, EQUI 17 (EU084) – Plant Conveyors, EQUI 18 (EU085) – Plant Elevator Leg, EQUI 19 (EU086) – Plant Conveyors #2 and associated uncaptured emissions (EQUI 74).

· EU031 – Loading Rack #1 was removed from the facility and is not authorized to operate.

· EU 040/SV 011 – Biodigester flare was removed from the facility and is not authorized to operate.


· EU 054 – Corn bin #6 was never built and is not included in this permit.

· SV016 – EQUI 61 Process Generator will vent to STRU 54 following permit issuance

· CE005/SV007 – Packed-gas adsorption column was decommissioned in the previous permit and is removed from this permit. All emission units that vented to CE005/SV007 were re-routed to the existing thermal oxidizer TREA 6 as of permit action -011.

· FUGI 8 - wetcake storage was removed from the permit, with wetcake storage no longer authorized at the facility. In the event that the dryers are shut down, the Permittee redirects whole stillage, which would normally go to the centrifuges, back to the beerwell until the dryers are operating again.

Reclassified Units

The two existing DDGS dryer multiclones (EQUIs 234 and 235) were reclassified as process equipment only. TREA 7 and TREA 9 (formerly CE 004 and CE 006) were inactivated and the existing requirements were moved to EQUIs 234 and 235. The units continue to vent to the existing thermal oxidizer (TREA 6) and STRU 46.

The existing DDGS cooling cyclone (EQUI 71) was reclassified as process equipment only.

The existing DDGS cooling cyclone

Modified Emission Units (relocated, new stack, new control equipment)

· STRU 18/EQUI 29 (formerly SV014/ EU047) – Well House Generator: A new oxidation catalyst (TREA 27) has been added for emission control.

· STRU 19/EQUI 60 (formerly SV015/ EU048) – Dryer Load Generator: A new oxidation catalyst (TREA 28) has been added for emission control.

· EQUI 61 (formerly EU049) – Process Generator: Moved to a new stack STRU 54 (SV018 was removed from the permit). A new oxidation catalyst (TREA 31) has been added for emission control.

· STRU 21/EQUI 62 (formerly SV017/ EU050) – Cooling Tower Generator: A new oxidation catalyst (TREA 29) has been added for emission control.

· EQUI 63 (formerly EU053) – Dryer Load Generator #2: Moved to new location on Al-Corn site, and a new stack, STRU 55. A new oxidation catalyst (TREA 30) has been added for emission control.

New Emission Units

As part of the facility upgrades, the following units are added by this permit action:

· STRU 52 – Combined Heat and Power (CHP) Equipment. The following units will vent to STRU 52:

EQUI 225 – Combustion Turbine: This unit, in conjunction with the Duct Burner (see below), will provide heat and power for the facility. EQUI 225 will be fueled by natural gas, has a maximum fuel input of 72 MMBtu/hr (HHV).

EQUI 226 – Duct Burner: This unit provides additional heat energy for the heat recovery steam generator (HRSG) to produce additional steam from the turbine exhaust. The Duct Burner is also fueled by natural gas and has a maximum fuel input of 106 MMBtu/hr (HHV).

EQUI 227 – Boiler: Natural gas-fired boiler with a maximum fuel input of 99 MMBtu/hr. The boiler will operate independently of the combustion turbine and duct burner, but they will share a common stack (STRU 52).


· EQUI 231 – Centrifuges #2: Emissions from the new centrifuges will be routed to TREA 25/STRU 47 (New RTO) for control.

· STRU 36/TREA 11 – Ethanol Loading Rack Flare #2: Maximum ethanol loading throughput of 180,000 gallons/hr. The new flare will control vapor emissions from the two new loading racks EQUIs 228 and 229.

· STRU 37/TREA 16 – Fermentation System Scrubber: This new control device will control VOC emissions from new cook, fermentation, and distillation units as well as many existing emission units.

· STRU 38/TREA 17 – Grain Handling Baghouse: The new grain handling baghouse will replace TREA and will control PM/ PM10/PM2.5 emissions from new grain receiving, handling, transfer, and storage equipment.

· STRU 39/TREA 18 – Grain Milling Baghouse: Will controls PM/ PM10/PM2.5 emissions from new grain handling, scalping, and milling equipment.

· STRU 40/TREA 19 – DDGS Loadout Baghouse: Will control PM/ PM10/PM2.5 emissions from new DDGS handling and loadout sources.

· STRU 41/EQUI 211– Emergency Fire Pump: New 600 bhp engine used only in emergency situations.

· STRUs 42 – 44/TREAs 20 – 21/EQUIs 212-214 – DDGS Conveyors and aspirators #1 - 3. These units will control PM/ PM10/PM2.5 emissions from DDGS conveying.

· STRUs 45 and 48/TREAs 23 and 26/EQUIs 215 and 222 – DDGS Bins #1 and 2. These units will control PM/ PM10/PM2.5 emissions from DDGS bin loading and unloading.

· STRU 46/EQUIs 216 and 217 – New DDGS Cooling Cyclones: These units receive and cool DDGS from the dryers and vent to the atmosphere through STRU 46.

· STRU 47/TREA 25 – Dryer/RTO stack: The new thermal oxidizer (TREA 25) will control emissions from the new centrifuges (EQUI 231), new DDGS dryer (EQUI 218), and new fluid bed cooler (EQUI 219)

· FUGI 7 – New Cooling Towers: three new cooling tower cells.

· New storage tanks. As part of the project, Al-Corn will install the following storage tanks: EQUI 168 – 200 Proof Ethanol Day Tank: 300,000 gallon capacity, EQUI 169 – 200 Proof Ethanol Day Tank: 300,000 gallon capacity, EQUI 170 – Ethanol Storage Tank: 2,000,000 gallon capacity, EQUI 171 – Ethanol Storage Tank: 2,000,000 gallon capacity, EQUI 172 – Denaturant Tank: 100,000 gallon capacity, EQUI 173 – Corrosion Inhibitor Tank: 3,000 gallon capacity, and EQUI 144 – 200 Proof Ethanol Day Tank: 120,000 gallon capacity. EQUI 144 has already been constructed through a minor permit amendment received 12/31/2016.

Section 1.6 of this TSD will describe in further detail the physical and operational changes that have been made to the permit.

1.4 Description of notification and application included in this action

Table 2. Notifications and applications included in this action

Date received Application/notification type and description

5/27/2016 DQ 5555 – Major permit amendment: Application for issuance for a first time Part 70 operating permit which incorporates a request for permit modifications to Permit No. 03900028-011.

12/31/2015 DQ 5443 – Minor permit amendment: Application for the installation of a new 120,000 gallon day tank for 200-proof ethanol (EQUI 144).

1.5 Facility emissions:


Table 3. Title I Emissions Summary

Pollutant

Limited Potential Emissions from

the Modification* (tpy)

Unlimited Potential Emissions from the

Modification (Facility-Wide PTE)

(tpy)

NSR/112(g) Threshold for New Major Source

(tpy) NSR/ 112(g) Review Required? (Yes/No)

PM 38.0 122.9 250 No PM10 38.4 107.6 250 No PM2.5 28.5 91.5 250 No NOx 123.6 184.0 250 No SO2 25.7 68.6 250 No CO 109.2 224.9 250 No Ozone (VOC) 84.9 178.0 250 No CO2e** 485,499 767,297 100,000 No HAP single /total

9.0/20.0*** 9.53/20.70 10/25 No

*Carbon dioxide equivalents as defined in Minn. R. 7007.0100. ** Permit limited single and total HAP, previously 9.0 tpy and 24.0 tpy, respectively

Table 4. Total facility potential to emit summary

PM tpy

PM10 tpy

PM2.5 tpy

SO2 tpy

NOx tpy

CO tpy

CO2e tpy

VOC tpy

Single HAP tpy

All HAPs tpy

Total facility limited potential emissions 122.9 107.6 91.5 68.6 184.0 224.9

767,297 178.0 9.53* 20.70

Total facility actual emissions (2014) 29.95 23.73 22.60 0.76 31.15 43.47 126,267 53.40 *

*Not reported in Minnesota emission inventory. ** Maximum single HAP is acetaldehyde

Table 5. Facility classification

Classification Major Synthetic minor/area Minor/area PSD X Part 70 Permit Program X Part 63 NESHAP X

1.6 Changes to the permit

Requirements for the new units which will be constructed after permit issuance are discussed in detail in Section 3 of this TSD. The MPCA has a combined operating and construction permitting program under Minnesota Rules Chapter 7007, and under Minn. R. 7007.0800, the MPCA has authority to include additional requirements in a permit. Under that authority, the following changes to the permit are also made through this permit action:

· The permit has been updated to reflect current MPCA templates and standard citation formatting.

· EQUI, STRU, TREA and FUGI data has been updated;

· Some requirements have been reordered to help with clarity (i.e., similar requirements are grouped).


Total facility

· Increased ethanol production limits from 50 million gallons per year undenatured ethanol (MGY) to 130 MGY. In addition to the increase in production limits, the production limit on 200-proof un-denatured ethanol (E-100) was changed to a limit on denatured ethanol production. Denatured ethanol production can be tracked more easily because denatured ethanol is the end product of the ethanol refining process, rather than an intermediate product of the process. The redundant denatured ethanol limit at the flare group (COMG 16) was subsequently removed. Daily recordkeeping requirements were also added to track compliance with the production limits.

· Increased grain receiving limit from 518,888 ton/yr 12-month rolling sum to 1.400 million ton/yr. Added daily recordkeeping requirements.

· Increased DDGS loadout limit from 175,080 ton/yr 12-month rolling sum to 440,000 ton/yr. Added daily recordkeeping requirements.

· A requirement was added to the total facility requirements to ensure that denaturant received at the facility is used as denaturant of ethanol only. The PTE of operations such as on-site vehicle fueling can often exceed new source review (NSR) major thresholds.

· Requirements for fugitive emissions from paved roads were moved from the total facility to FUGI 3 – Truck Traffic on Paved Roads.

· Requirements for emissions from when wetcake, a byproduct similar to DDGS, is produced by the facility were moved from the total facility to the new subject item FUGI 8 – Wetcake storage.

· Updated modeling language to reflect most recent modeling analysis. See Section 3.2 for further discussion on the modeling requirements added to the permit.

· As noted in the previous permit, Al-Corn Clean Fuels and the adjacent EPCO Carbon Dioxide Products Inc. facility (now known as Air Products) constitute a single stationary source under 40 CFR 52.21 and 40 CFR 70.2. The previous permit stated that “EPCO operates under a separate air permit, Permit No. 03900031-002”. However, this permit was voided on 3/24/2004 although Air Products continued to operate the source. The facility will be shut down in 2017, with Al-Corn Clean Fuels stating that they will stop delivering carbon dioxide to the Air Products facility by 12/31/2017 (Attachment 9 to this TSD). A requirement was added to the total facility level of the permit requiring Air Products to submit a Part 70 permit application, or Al-Corn Clean fuels to submit a major permit amendment to incorporate the facility if it is not shut down by 12/31/2017. If Air Products ceases operation prior to that date, they shall submit a notification with the date that the facility operations have been permanently disabled. Air Products has no insignificant activities and does not use any emergency generators.

· Removed annual VOC, CO, Single HAP, and total HAP limits of < 95 tpy from the facility. Facility emissions are limited through lb/hr limits at the stacks, and annual throughput limits on grain receiving, ethanol production and DDGS loadout.

· Added tracking requirements for flexibility provisions (equipment labeling and annual report).

Several groups were removed from the permit due to equipment being removed. Further, groups where the requirements in the group apply to the members of the group individually were also removed.

The following groups were removed, with the applicable requirements being verified, updated and moved to the individual subject items:


· GP 001 - Baghouse Monitoring and Maintenance

· GP 002 - Scrubber Monitoring and Maintenance

· GP 004: Tanks 1 and 3: EQUIs 137 and 141 were moved to COMG 14 (Emission sources subject to Minn. R. 7011.0715) and COMG 7 (Denaturant tanks subject to Minn. R. 7011.1505), respectively.

· GP 005 – Tanks 2, 4, 5, and 6: EQUI 138 was moved to COMG 7 (Kb Tanks w/ Liquid Mounted Seal), EQUIs 139 and 140 were moved to COMG 14 (Emission sources subject to Minn. R. 7011.0715 (IPER)), while EQUI 142 was moved to COMG 8 (Kb Tanks w/ Liquid Mounted Seal).

· GP 006 – Fuel Requirements: Dryers, Boiler and thermal oxidizer: This group contained the group NOX limit. The three remaining units subject to legacy BACT-equivalent limits all vent to the same stack (STRU 24). The limit of 7.28 lb/hr NOX assumed for modeling and to avoid PSD ensures compliance with the average emission factor of 0.040 lb/MMBtu. Boiler 1 is subject to a different emission factor limit, and is to be removed from the facility after completion of the modification. The other NOX limits at the facility for the generators apply individually to each unit.

The following new groups were created:

· COMG 3 (previously ) - HAPs limit group: Limits total HAPs to ≤ 17.0 tpy, limits acetaldehyde emissions ≤ 9.0 tpy, and limits formaldehyde ≤ 5.0 tpy for associated units. Includes daily recordkeeping and monthly calculations. HAP emission factors are based on performance testing conducted at respective stacks.

· COMG 7 - Denaturant Tanks subject to Minn. R. 7011.1505

· COMG 8 - Kb Tanks w/ Liquid Mounted Seal: NSPS subp. Kb requirements for storage tanks at the facility utilizing liquid mounted seals

· COMG 10 – Combustion turbine and duct burner: Contains NSPS subp. KKKK requirements

· COMG 11 - DDSG Storage and Loadout: Minn. R. 7011.1005 and monitoring requirements for the group of emission sources located in the existing DDGS storage and loadout area. Includes daily visible emissions checks and opacity testing.

· COMG 12 - DDGS Storage Silo Baghouses: Control equipment requirements for the two identical baghouses used to control emissions from the facility’s DDGS storage silos. Contains flexibility provisions allowing for the replacement of the baghouses.

· COMG 13 - Kb Tanks w/ Double-seal System: NSPS subp. Kb requirements for storage tanks at the facility utilizing double-seals to mitigate VOC emissions.

· COMG 14 - Emission sources subject to Minn. R. 7011.0715 (IPER).

· COMG 16 - Ethanol Loadout Racks #3 and #4: Process throughput limits and control equipment requirements for the facility’s loadout racks, and requirement that any rail cars be dedicated for transport of ethanol and denatured ethanol.

· COMG 2 (previously GP007) is clarified to apply to diesel generators > 500 hp. The group limits contain updated requirements for 40 CFR pt. 63, supb. ZZZZ and Minn. R. 7011.2300.

Equipment (EQUI) subject item changes and new units:

· EQUI 7 DDGS Loadout: Added daily visible emissions checks and opacity testing to show compliance with opacity limits in Minn. R. 7011.1005, subp. 3(A).

· EQUI 28 Office Generator: Added updated requirements for Minn. R. 7011.2300 and 40 CFR pt. 63, subp. ZZZZ.


· EQUI 74: Added opacity limits for uncaptured grain receiving emissions.

· EQUI 178: Authorized permittee to operate beerwell for 3 years after permit issuance, and states that the new beerwell cannot operate at the same time as the existing beerwell.

· EQUI 211 - Fire pump: Included updated requirements for 40 CFR pt. 63, subps. A and ZZZZ. Best management practices were also included because the emergency generator was not included in the facility’s modeling analysis.

· EQUIs 212-214 – DDGS Conveyance Aspiration #1-3: Added PM, PM10, and PM2.5 emission limits to reflect assumptions made in PTE calculations. Performance testing requirements were added at the respective STRU level.

· EQUIs 215, 222 - DDGS Bin #1: Added PM, PM10, and PM2.5 emission limits to reflect assumptions made in PTE calculations. Performance testing requirements were added at the respective STRU level.

· EQUIs 223, 224, 243 – Grain Receiving and DDGS Loadout Uncaptured Emissions: Added PM, PM10, and PM2.5 emission limits to reflect assumptions made in PTE calculations. Performance testing requirements for captured emissions were added at the respective STRU level while hood evaluation requirements were placed at the TREA level.

· EQUI 227 – Boiler: 40 CFR pt. 60, subp. Dc recordkeeping requirements were added to EQUI 227, along with fuel type restrictions and fuel use recordkeeping.

· FUGI 3 – Truck Traffic on Paved Roads: Updated production and process throughput limits based on the values used in calculating PTE of the facility’s paved roads. The Permittee is also required to sweep whenever visible emissions are observed or monthly, at a minimum.

· FUGI 4 – Cooling Towers: Added Minn. R. 7011.0715, subp. 1 requirements.

· FUGI 5 – Valves, Flanges, and Seals (tank leaks) – Added 40 CFR pt. 60, subp. VVa requirements. The facility was previously subject to subp. VV. The new project will trigger subp. VVa requirements.

Structure (STRU) subject item changes and new units:

· STRU 9 – Grain Receiving Baghouse: Added PM, PM10, and PM2.5 emission limits along with performance testing requirements. Short-term process throughput limits were also added to ensure the Permittee tests during worst-case conditions, e.g. highest process throughput rates. Grain receiving is also limited to 14 hours/day due to assumptions made in the Permittee’s modeling analysis.

· STRU 11 – Grain Handling Baghouse: Added PM, PM10, and PM2.5 emission limits along with performance testing requirements. Short-term process throughput limits were also added to ensure the Permittee tests during worst-case conditions, e.g. highest process throughput rates.

· STRU 12 – Grain Milling Baghouse: Added PM, PM10, and PM2.5 emission limits along with performance testing requirements. Short-term process throughput limits were also added to ensure the Permittee tests during worst-case conditions, e.g. highest process throughput rates.

· STRU 15 - DDGS Cooling Cyclone: Added PM, PM10, and PM2.5 emission limits along with performance testing requirements. Short-term process throughput limits were also added to ensure the Permittee tests during worst-case conditions, e.g. highest process throughput rates.

· STRU 23 – Flour Transfer Baghouse: Added PM, PM10, and PM2.5 emission limits along with performance testing requirements. Short-term process throughput limits were also added to ensure the Permittee tests during worst-case conditions, e.g. highest process throughput rates.

· STRU 24 – TO/HRSG: Added PM, PM10, and PM2.5 emission limits, which reflect the limits required by the facility’s Consent Decree. Short-term process throughput limits were also added to ensure the Permittee tests during worst-case conditions, e.g. highest process throughput rates. Flexibility


provisions were added to allow the Permittee to replace dryers venting to STRU 24 without necessarily needing a major permit amendment.

· STRU 27 – Fermentation System: Short-term process throughput limits were added to ensure the Permittee tests during worst-case conditions, e.g. highest process throughput rates.

· STRU 37 – Fermentation System Scrubber: Added VOC, HAPs, PM, PM10, and PM2.5 emission limits along with performance testing requirements. Short-term process throughput limits were also added to ensure the Permittee tests during worst-case conditions, e.g. highest process throughput rates. Flexibility provisions were added to allow the Permittee to replace fermentation units venting to STRU 24 without necessarily needing a major permit amendment.

· STRU 38 – Grain Handling Baghouse: Added PM, PM10, and PM2.5 emission limits along with performance testing requirements. Short-term process throughput limits were also added to ensure the Permittee tests during worst-case conditions, e.g. highest process throughput rates. Flexibility provisions were added to allow the Permittee to replace grain handling units venting to STRU 38 without necessarily needing a major permit amendment. Grain receiving is also limited to 14 hours/day due to assumptions made in the Permittee’s modeling analysis.

· STRU 39 – Grain Milling Baghouse: Added PM, PM10, and PM2.5 emission limits along with performance testing requirements. Short-term process throughput limits were also added to ensure the Permittee tests during worst-case conditions, e.g. highest process throughput rates. Flexibility provisions were added to allow the Permittee to replace grain milling units venting to STRU 39 without necessarily needing a major permit amendment.

· STRU 40 – DDGS Loadout Baghouse: Added PM, PM10, and PM2.5 emission limits along with performance testing requirements. Short-term process throughput limits were also added to ensure the Permittee tests during worst-case conditions, e.g. highest process throughput rates. Flexibility provisions were added to allow the Permittee to replace DDGS loadout units venting to STRU 40 without necessarily needing a major permit amendment.

· STRU 46 – DDGS Cooling Cyclone: Added VOC, PM, PM10, and PM2.5 emission limits along with performance testing requirements. Short-term process throughput limits were also added to ensure the Permittee tests during worst-case conditions, e.g. highest process throughput rates.

· STRU 47 – DDGS/RTO: Added NOX, CO, SO2, VOC, PM, PM10, and PM2.5 emission limits along with performance testing requirements. Short-term process throughput limits were also added to ensure the Permittee tests during worst-case conditions, e.g. highest process throughput rates. Flexibility provisions were added to allow the Permittee to replace units venting to STRU 47 without necessarily needing a major permit amendment.

· STRU 49 – Combined Heat and Power Dump Stack: Requirement to only operate bypass stack during emergencies. Added NOX, CO, PM, PM10, and PM2.5 emission limits to reflect assumptions made in PTE calculations.

· STRU 53- Dryer/RTO Bypass Stack: Requirement to only operate bypass stack during emergencies.

Treatment (TREA) subject item changes and new units:

· TREAs 1, 2, 4, 12, 17, 18, 19, 20, 21, 22, 23, 26, – Fabric filters: Added minimum control efficiency limits for PM, PM10, and PM2.5 which reflect the assumptions made in the PTE calculations. Visible emissions checks were also required to ensure the fabric filters are properly operated. Annual hood evaluations are required for the units with capture efficiencies < 100% (TREA 4). Further construction authorizations, requirements to operate fabric filters to control particulate emissions, flexibility language for equipment replacements, and emission limits were placed at the individual EQUI levels.


· TREAs 3 and 15 – Ethanol Loading Rack Flare #1 and #2: Added minimum control efficiency limits for VOC which reflect the assumptions made in the PTE calculations and the facility’s Consent Decree. Monitoring requirements were added to ensure proper operation of the control equipment.

· TREA 6 – Thermal Oxidizer: Added minimum control efficiency limits for VOC and CO which reflect the assumptions made in the PTE calculations and the facility’s Consent Decree. Monitoring requirements were added to ensure proper operation of the control equipment.

· TREA 10 – Packed-Gas Adsorption Column: Added minimum control efficiency limits for VOC which reflect the assumptions made in the PTE calculations and the facility’s Consent Decree. Monitoring requirements were added to ensure proper operation of the control equipment.

· TREA 16 – Fermentation System Scrubber: Added minimum control efficiency limits for VOC which reflect the assumptions made in the PTE calculations. Monitoring requirements, water flow rate, and additive flow rate limits were added to ensure proper operation of the control equipment.

· TREA 25 - RTO: Monitoring requirements, water flow rate, and additive flow rate limits were added to ensure proper operation of the control equipment.

· TREAs 27-31– Generator Catalysts: Added 40 CFR subp. ZZZZ and Section 63.8 requirements for the catalysts which are used to control emissions from the facility’s generators. Performance testing requirements are located at the individual EQUI level.

2. Regulatory and/or statutory basis

2.1 New source review (NSR)

The existing facility is subject to limits such that all NSR-regulated air pollutants, other than greenhouse gases (GHG), are less than the major source thresholds for NSR (40 CFR § 52.21(b)(1)).

Al-Corn has an unrestricted Potential-to-Emit (PTE) of more than 100,000 tons per year of GHG (as CO2e, Table 4). The Supreme Court’s Decision in Utility Air Regulatory Group v. EPA ruled that a source cannot be major for NSR based on GHG emissions alone. The facility is not subject to regulation of GHG emissions because the emission totals for all other criteria pollutants are less than the major source thresholds. Therefore, the facility is not considered a major source for NSR.

2.2 Part 70 permit program

This is a first time Pt. 70 permit. The facility from this permit action forward is considered a major source under 40 CFR Section 70.2. The limited PTE of PM10, NOX, CO, and VOC are above the major source threshold for Pt. 70 facilities as shown in Table 4.

2.3 New source performance standards (NSPS)

The following New Source Performance Standards apply to the operations at this facility: Subp. Dc: The new boiler (EQUI 227) has a maximum design heat input capacity of 99.00 MMBtu/hr and is therefore subject to NSPS Subpart Dc, “Standards of Performance for Small Industrial-Commercial-Institutional Steam Generating Units”. The boiler will operate independently of the new turbine and duct burner, although the three units will share a common stack (STRU 52). The existing heat recovery steam generator (HRSG) (TREA 6) is also subject to NSPS Subpart Dc. Because each of the boilers will be fueled with natural gas, only the initial notification and recordkeeping requirements apply for each boiler/HRSG under the rule. Boiler #1 was permanently disconnected prior to permit issuance.


Subp. Kb: 40 CFR pt. 60, subp. Kb Standards of Performance for Volatile Organic Liquid Storage Vessels for which construction, reconstruction, or modification commenced after July 23, 1984. The following table provides the data used for determining applicability of the standard to each of the facility’s storage tanks:

Table 6: NSPS subp. Kb Applicability

Tank Capacity (m3) Material stored

Max vapor pressure

(kPa)1

Is capacity ≥ 75 m3 and

constructed after July 23, 1984?

Is 75 m3 < capacity < 151 m3 and VP < 15

kPa?

Is it a process tank as

defined in 60.111b?

Subject to NSPS

subp. Kb?

EQUI 168 (T-7001)

1,135.62 Ethanol (E100) 7.83 kPa Yes No Yes No

EQUI 169 (T-7002) 1,135.62 Ethanol (E100) 7.83 kPa Yes No Yes No

EQUI 170 (T-7003) 7,570.82 Ethanol (E100) 7.83 kPa Yes No No Yes

EQUI 171 (T-7004) 7,570.82 Ethanol (E100) 7.83 kPa Yes No No Yes

EQUI 172 (T-7250) 378.54 Gasoline, Non-

oxygenated >68.10 kPa Yes No No Yes

EQUI 173 (T-7050) 11.36

Corrosion Inhibitor Fuel

Additive 76.74 kPa No, exempt n/a n/a No

EQUI 137 (T-801) 147.63 Ethanol (E100) 8.07 kPa Yes Yes, exempt Yes No


oxygenated 25.38 kPa Yes No No Yes

EQUI 139 (T-803) 454.25 Ethanol (E100) 8.68 kPa Yes No Yes No

EQUI 140 (T-804) 454.25 Ethanol (E100) 8.68 kPa Yes No Yes No


oxygenated >68.10 kPa No, exempt n/a n/a No

EQUI 142 (T-810)

3766.48 Ethanol (E100) 8.68 kPa Yes No No Yes

EQUI 143 (T-868) 5.41

Corrosion Inhibitor Fuel

Additive Will be IA No, exempt No n/a No

EQUI 144 (T-806) 454.25 Ethanol

(E100) 7.83 kPa Yes No Yes No

1. Max. vapor pressure is defined as local maximum monthly average temperature as reported by the National Weather Service for VOL’s stored at the ambient temperature. The vapor pressure used in the Tanks program is a different value based on a different averaging period.

2. See EPA determination dated 11/20/2007 Process Tanks Defined, Control Number: 0800041

Subp. DD: This facility is not subject to 40 CFR pt. 60, subp. DD – Standards of Performance for Grain Handling Facilities. Applicability is based on a grain elevator’s storage capacity, which must exceed 2.5 million bushels for any grain storage facility not for human consumption. The new corn bins (EQUIs 190 and 191) will have a combined storage capacity of 1.5 million bushels. The previous storage capacity (EQUIs 48, 50 – 53, and 64, will be removed) was 817,000 bushels. Therefore, Subpart DD does not apply to the facility before or after the modification.

Subp. IIII: The new emergency diesel fire pump engine (EQUI 211) is subject to 40 CFR pt. 60, Subpart IIII, “Standards of Performance for Stationary Compression Ignition Internal Combustion Engines”. NSPS Subpart


IIII does not apply to the facility’s non-emergency generator engines (COMG 2) because the engines were constructed prior to July 11, 2005. Table 11 in Section 3.6 of this TSD gives further information on the applicability of 40 CFR pt. 60, subp. IIII.

Subp. VV and VVa: The Permittee is currently subject to 40 CFR pt. 60, Subpart VV, “Standards of Performance for Equipment Leaks of VOC in the Synthetic Organic Chemical Manufacturing Industry” for facilities constructed before November 2006. The proposed project will trigger NSPS Subpart VVa, “Standards of Performance for Equipment Leaks of VOC in the Synthetic Organic Chemical Manufacturing Industry,” which applies to facilities constructed, reconstructed, or modified after November 2006. Section 60.480a(c) of NSPS Subpart VVa states that, for an existing facility, the “addition or replacement of equipment for the purpose of process improvement which is accomplished without a capital expenditure shall not by itself be considered a modification under this subpart.” Al-Corn has verified that no previous projects have met the definition of a capital expenditure, including the addition of a new fermenter (EQUI 9) authorized by permit action -011, and the addition of a new ethanol day tank (EQUI 144), authorized through the minor permit amendment submitted 12/31/2015. The additional fermentation equipment and storage tanks included in the proposed project will meet the definition of a capital expenditure. Therefore, Subpart VVa requirements were added to the permit at FUGI 5.

Subp. KKKK: 40 CFR pt. 60, subp. KKKK Standards of Performance for Stationary Combustion Turbines. The new turbine (EQUI 225) and duct burner (EQUI 226) are subject to this subpart, and the requirements were added to the permit at the new group COMG 10, Combustion turbine and duct burner. Because the turbine has a maximum heat input above 50 MMBtu/hr (HHV), the turbine is considered part of the “new natural gas turbine (electric generating) with a peak heat input between 50 MMBtu/hr and 850 MMBtu/hr” and is subject to a NOX limit of 25 ppm (15% O2) or 1.2 pounds per MWh of useful output. The duct burner will be subject to the same NOX limit as the turbine (25 ppm) because the turbine and duct burner share a common steam header and stack (STRU 52), and are not independent.

The new boiler (EQUI 227) is not subject to this rule. Although it will share a common stack (STRU 52) with the COMG 10 units, the boiler will be a standalone unit and will not operate as a heat recovery steam generator.

The boiler exhaust will be ducted to the common stack so that the combined COMG 10 emissions can be tested separately from the boiler.

Subp. JJJJ: The natural gas-fired engine (EQUI 28) was installed prior to 2006, thus the requirements of 40 CFR pt. 60, subp. JJJJ do not apply.

2.4 National emission standards for hazardous air pollutants (NESHAP)

The Facility has accepted practically enforceable limits on hazardous air pollutant (HAP) emissions such that it is a non-major source under 40 CFR pt. 63. Requirements include operation of scrubbers, RTO, and a flare to reduce HAP emissions. Other controls taken into account include the liquid storage tanks (floating roofs) and the Leak Detection and Repair program for piping leaks. However, with the Pt. 70 permit application Al-Corn is taking limits on individual and total HAPs to remain an area source. These limits on single and total HAP are placed at COMG 3. The Permittee is required to verify HAP emission factors relied upon in their regulatory determination with recurring performance testing. Thus, no major source NESHAPs apply.

Subp. Q: Cooling towers are not subject to the cooling tower NESHAP which prohibits use of chromium-containing chemicals to treat the cooling water because the facility is not a major source under 40 CFR pt. 63.

Subp. ZZZZ: The facility is subject to the provisions of 40 CFR pt. 63, subp. ZZZZ: National Emissions Standards for Hazardous Air Pollutants for Stationary Reciprocating Internal Combustion Engines (area source). NESHAP


subp. ZZZZ requirements were added to the permit at COMG 2 (CI engines greater than 500 bhp) and at EQUI 28 (SI engines < 500 bhp). Table 11 in Section 3.6 of this TSD gives further information on the applicability of 40 CFR pt. 63, subp. ZZZZ. The new emergency fire pump (EQUI 211) is subject to subp. ZZZZ because it is an emergency generator greater than 500 bhp and will be constructed in 2017 at an area source. Compliance with subp. ZZZZ for EQUI 211 is met by complying with the NSPS subp. IIII.

Subp. JJJJJ: US EPA has promulgated Subpart JJJJJJ to Part 63 to regulate emissions from boilers at area (minor) sources of HAP. A boiler is an existing affected source if construction commenced on or before June 4, 2010. Because Al-Corn only uses natural gas and propane in the boilers (EQUIs 68 and 227) there are no applicable requirements in Subpart JJJJJJ.

2.7 Compliance assurance monitoring (CAM)

There are several units at the facility which have been identified as “Other PSEUs”. Because this is a first time Pt. 70 permit, only information about large PSEUs is required to be submitted. Al-Corn has no large PSEUs as defined by 40 CFR pt. 64. CAM will be implemented for the Other-PSEUs at the facility during permit reissuance.

2.8 Environmental review and air emissions risk analysis (AERA)

The Project will be capable of storing one million gallons or more of a hazardous material. Therefore, an Environmental Analysis Worksheet (EAW) was prepared pursuant to Minn. R. 4410.4300, subp. 10(B). The Project will also be capable of emitting more than 100,000 tpy of greenhouse gas emissions, which requires the preparation of an EAW pursuant to Minn. R. 4410.4300, subp. 15(B). On April 1, 2016, the Al-Corn submitted a draft EAW to the MPCA for the Project. The public comment period for the EAW began on August 15, 2016, and ended on September 14, 2016. A Negative Declaration for the Project was issued on October 3, 2016, stating that the Project does not have the potential for significant environmental effects and an Environmental Impact Statement (EIS) is not needed.

Al-Corn prepared an Air Emissions Risk Analysis (AERA) and conducted Air Dispersion modeling as required by the MPCA for projects that trigger the preparation of an EAW under Minn. R. 4410.4300, subp. 15(B). The AERA includes a qualitative and quantitative analysis of potential human health risks from exposure to air toxics emitted from the Facility. Cancer and non-cancer risks from inhalation and ingestion exposures were analyzed using the MPCA’s Risk Assessment Screening Spreadsheet. The MPCA concluded that the Project does not present any significant increases in the levels of non-cancer or cancer risk that warrant further study. Assumptions made in the AERA for process throughput, operating times, and emission limits will be implemented as permit limits and requirements. Information on the modeling analysis results are in Section 3.2 of this TSD.

2.9 Minnesota state rules

Portions of the facility are subject to the following Minnesota Standards of Performance: · Minn. R. 7011.0150 Standards of Performance for Preventing Particulate Matter from Becoming Airborne

· Minn. R. 7011.0570 Standards of Performance for Small Industrial-Commercial-Institutional Steam Generating Units

· Minn. R. 7011.0610 Standards of Performance for Fossil-Fuel-Burning Direct Heating Equipment · Minn. R. 7011.0715 Standards of Performance for Post-1969 Industrial Process Equipment · Minn. R. 7011.1005 Standards of Performance for Bulk Agricultural Commodity Facilities · Minn. R. 7011.1505 Standards of Performance for Liquid Petroleum and Volatile Organic Liquid Storage

Vessels · Minn. R. 7011.2300 Standards of Performance for Stationary Internal Combustion Engines


· Minn. R. 7011.2305 Standards of Performance for Stationary Compression Ignition Internal Combustion Engines

· Minn. R. 7011.8150 Standards of Performance for Stationary Reciprocating Internal Combustion Engines

Table 8. Regulatory overview of the facility

Level* Applicable Regulations Comments: CAAA of 1990 The citation CAAA of 1990 in this table is a shortened reference to

legacy BACT-equivalent requirements that were negotiated in a 2002 federal Consent Decree. See Section 3.9 of this TSD for further information.

TFAC 2 – Air Quality Total Facility

Title I Condition to avoid PSD Production limit: ≤ 133.327 million gallons/yr of denatured ethanol production based on a 12-month rolling sum. This will be the design capacity of the facility and is used as the basis of the calculations. Process throughput limit of 1.4 million tons/yr of grain based on a 12-month rolling sum. This will be the design capacity of the facility and is used as the basis of the calculations. The annual corn throughput is relied upon for modeling compliance with the PM10 and PM2.5 annual NAAQS. Process throughput limit of 440,000 tons/yr of DDGS based on a 12-month rolling sum. This will be the design capacity of the facility and is used as the basis of the calculations. The production limits, in addition to other limits, restrict allowable emissions to below major source thresholds for New Source Review, and Pt. 63 NESHAPs.

40 CFR pt. 68 The facility must submit a Risk Management Plan (RMP) under 40 CFR pt. 68.

Minn. R. 7011.1005, subp. 1

Minnesota Standards of Performance for Dry Bulk Agricultural Facilities applies to facility property. Facility handles commodities (grain and grain by-products), therefore they must clean up spills to minimize fugitive emissions to a level consistent with RACT.

Minn. R. 7007.0800, subp. 2 Flexibility Provisions. Equipment labeling and inventory requirements are located at the total facility level of the permit. This is additional recordkeeping and reporting necessary to track replacement or modified units.

Minn. R. 7011.0150 Minnesota Standards of Performance for Preventing Particulate Emissions from Becoming Airborne. This subpart applies to the facility in general.

Title V modeling

The annual grain and DDGS throughput is relied upon for modeling compliance with the PM10 and PM2.5 annual NAAQS. NO2, PM10, and PM2.5 dispersion modeling requirements. As described in Section 3.2.

COMG 2 Facility Diesel Generators (EQUIs 29, 60-63)

Title I limit to avoid PSD Prevention of Significant Deterioration. Limit of No. 1 and 2 fuel oil usage to ≤ 100 hours/year (meets definition of limited use engine) is relied upon to reduce SO2, NOX, CO, CO2e, PM, PM10, PM2.5 and VOC potential emissions to avoid classification as a major source under 40 CFR § 52.21.

40 CFR pt. 63, subp. ZZZZ National Emission Standards for Hazardous Air Pollutants for Stationary Reciprocating Internal Combustion Engines. These units are existing limited-use compression ignition generators located at an area source of HAPs. See Section 3.9 for applicability discussion.

Minn. R. 7011.2300 Standards of Performance for Stationary Internal Combustion Engines applies.

COMG 3 (GP008) Title I Condition to avoid major status under 40 CFR Section 63.2

Limits on Acetaldehyde (Single-HAP) (< 9.0 tpy), formaldehyde (Single-HAP) (< 5.0 tpy), and total-HAP (< 17.0 tpy) to avoid major source status under 40 CFR Section 63.2. The group contains HAP emissions from processes that are subject to emission limits at the stack. The facility will conduct performance testing for VOCs as mass,


Level* Applicable Regulations Comments: which includes speciation of HAP compounds. These results will be used to calculate HAP emissions. Periods of uncontrolled operation are included in the calculation method. HAP emissions due to combustion sources, leaks and fugitive sources are accounted for outside the HAP limits in COMG 3 at PTE.

COMG 7 Denaturant Tanks subject to Minn. R. 7011.1505

Minn. R. 7011.1505 Standards of Performance for Storage Vessels. This rule applies only to the storage of petroleum products. See Table 6 for more information on storage tank regulations and applicability.

COMG 8 Kb Tanks w/ Liquid Mounted Seal

40 CFR pt. 60, subp. Kb Standards of Performance for Volatile Organic Liquid Storage Vessels for which construction, reconstruction, or modification commenced after July 23, 1984. See Table 6 for more information on storage tank regulations and applicability.

COMG 10 Combustion turbine and duct burner

40 CFR pt. 60, subp. KKKK Standards of Performance for Stationary Combustion Turbines. In Table 1 of the standard, the affected facility is considered a new turbine firing natural gas, >50 MMBtu/hr and ≤ 850 MMBtu/hr.

COMG 11 DDGS Storage and Loadout

Minn. R. 7011.1005 Standards of Performance for Dry Bulk Agricultural Commodity Facilities. The facility handles commodities (grain and grain by-products), therefore they are subject to this standard. DDGS is considered a grain by-product. The facility has an annual commodity throughput of more than 180,000 tons, and was constructed after 1/1/84. Therefore, it is subject to control. Control for the existing DDGS operations is established by achieving compliance with the opacity limits in the rule. DDGS operations are contained within a building. The Permittee will conduct daily VE checks and periodic opacity testing. If daily VE checks identify VE, then the Permittee will implement corrective actions (such as closing the door) until there are no visible emissions.

COMG 12 DDGS Storage Silo Baghouses

Minn. R. 7011.1005 Standards of Performance for Dry Bulk Agricultural Commodity Facilities. The facility handles commodities (grain and grain by-products); therefore, they are subject to this standard. DDGS is considered a grain by-product. The facility has an annual commodity throughput of more than 180,000 tons, and was constructed after 1/1/84. Therefore, it is subject to control. To show that the emissions are controlled to the required opacity limits, the Permittee will conduct daily VE checks and periodic opacity testing. If daily VE checks identify VE, then the Permittee will implement corrective actions (such as slowing down the rate of grain flowing to the elevator) until there are no visible emissions.

COMG 13 Kb Tanks w/ Double-seal System

40 CFR pt. 60, subp. Kb Standards of Performance for Volatile Organic Liquid Storage Vessels for which construction, reconstruction, or modification commenced after July 23, 1984. See Table 6 for more information on storage tank regulations and applicability.

COMG 14 Emission Sources subject to Minn. R. 7011.0715 (IPER)

Minn. R. 7011.0715 Standards of Performance for Post-1969 Industrial Process Equipment. Equipment for which there is no other promulgated performance standard are subject to the opacity and PM limits in this rule. The facility was constructed after 1969.

COMG 16 Ethanol Loadout Racks #3 and #4

Title I Condition to avoid PSD & CAAA of 1990; Minn. R. 7007.0800, subp. 2

Limits on ethanol loadout via railcar and requirements to operate flare to avoid major source classification under 40 CFR Section 52.21. Railcars must be dedicated to ethanol service.

EQUI 7 DDGS Loadout (will be removed)

Minn. R. 7011.1005 Standards of Performance for Dry Bulk Agricultural Commodity Facilities. The facility handles commodities (grain and grain by-products); therefore, they are subject to this standard. DDGS is considered a grain by-product. The facility has an annual commodity throughput of more than 180,000 tons, and was constructed after 1/1/84. Therefore, it is subject to control. Control for the existing


Level* Applicable Regulations Comments: DDGS operations is established by achieving compliance with the opacity limits in the rule. DDGS operations are contained within a building. The Permittee will conduct daily VE checks and periodic opacity testing. If daily VE checks identify VE, then the Permittee will implement corrective actions (such as closing the door) until there are no visible emissions.

EQUI 28 Office 25 kW Generator, nat. gas

Title I Condition to avoid PSD 40 CFR pt. 63, subp. ZZZZ

The Permittee will limit hours of operation ≤ 100 hr/yr to avoid major source classification under 40 CFR Section 52.21 and to meet the definition of a limited use engine under 40 CFR pt. 63, subp. ZZZZ. National Emissions Standards for Hazardous Air Pollutants for Stationary Reciprocating Internal Combustion Engines. The engine is subject to operating limitations for existing RICE at an area source of HAPs (Table 2d).

EQUI 73 Ethanol Loading Rack #2 (trucks only)

Title I Condition to avoid PSD & CAAA of 1990

Requirement to operate flare (TREA 3) when EQUI 73 is operated.

EQUI 74 Grain Receiving – Uncaptured Emissions (will be removed)

Minn. R. 7011.1005 Standards of Performance for Dry Bulk Agricultural Commodity Facilities. The facility handles commodities (grain and grain by-products), therefore they are subject to this standard. DDGS is considered a grain by-product. The facility has an annual commodity throughput of more than 180,000 tons, and was constructed after 1/1/84. Therefore, it is subject to control. Emissions from the grain receiving pit are aspirated to a baghouse. Controlled emissions are vented through STRU9 to TREA 4. This EQUI# represents the portion of emissions that is not captured by the hood and vented to STRU9.

EQUI 178 Beerwell Title I Condition to avoid PSD Construction authorization for EQUI 178 clarifies that the existing beerwell and the new beerwell may not operate simultaneously.

EQUI 211 Emergency Fire Pump Engine

40 CFR pt. 60, subp. IIII 40 CFR pt. 63, subp. ZZZZ

Standards of Performance for Stationary Compression Ignition Internal Combustion Engines and National Emissions Standards for Hazardous Air Pollutants for Stationary Reciprocating Internal Combustion Engines. In accordance with 40 CFR 63.6590(c), compliance with subp. ZZZZ is achieved by complying with subp. IIII. The engine will be manufactured after 2007.

EQUIs 212, 213, and 214 DDGS Conveyance Aspiration #1-3

Title I Condition to avoid PSD PM, PM10 and PM2.5 limits and aspiration to a fabric filter are required to avoid major source classification under 40 CFR Section 52.21. Separate limits for annual and short-term rates used in the modeling demonstration were created to properly characterize worst-case emissions during a 24-hour period. Based on uncontrolled PTE calculations for average annual operations, the required control to achieve the PM limits is 97.4% for PM, 89.6% for PM10 and 40.6% for PM2.5. It is expected that proper O&M of the fabric filter will readily achieve this level of control, therefore performance testing is not required to verify the limits.

Title V modeling Short-term (lb/hr) emission rates, based on maximum throughput in a 24-hour period were relied upon for modeling compliance with the PM10 and PM2.5 annual NAAQS. See Section 3.2 for more information. NO2, PM10, and PM2.5 dispersion modeling requirements. As described in Section 3.2. Requirements to operate control equipment which was relied upon for modeling and PTE calculations.

Minn. R. 7011.1005 Standards of Performance for Dry Bulk Agricultural Commodity Facilities. The facility handles commodities (grain and grain by-products), therefore they are subject to this standard. DDGS is considered a grain by-product. The facility has an annual commodity throughput of more than 180,000 tons, and was constructed after 1/1/84. Therefore, it is subject to control. Emissions from the grain


Level* Applicable Regulations Comments: receiving pit are aspirated to a baghouse. Emissions from this operation are vented to fabric filters with a collection efficiency > 80% as required by this rule.

Title I Condition to avoid PSD Title V modeling

Flexibility. The Permittee is authorized to replace the equipment with equipment that does not exceed the maximum capacity identified in Appendix C of the permit.

EQUIs 215 and 222 DDGS Bins #1-2

Title I Condition to avoid PSD PM, PM10 and PM2.5 limits to avoid major source classification under 40 CFR Section 52.21. Separate limits for annual and short-term rates used in the modeling demonstration were created. The Permittee is not required to reach maximum capacity to demonstrate compliance with the annual emission rates.

Minn. R. 7007.3000 Requirements to operate control equipment which was relied upon for modeling and PTE calculations.

Minn. R. 7011.1005 Standards of Performance for Dry Bulk Agricultural Commodity Facilities

Title I Condition to avoid PSD Title V modeling

Flexibility. The Permittee is authorized to replace the equipment with equipment that does not exceed the maximum capacity identified in Appendix C of the permit.

EQUIs 223, 224 Grain Receiving, DDGS Loadout – Uncaptured

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

Standards of Performance for Dry Bulk Agricultural Commodity Facilities

EQUI 227 Boiler 40 CFR pt. 60, subp. Dc Standards of Performance for Small Industrial-Commercial-Institutional Steam Generating Units

EQUI 243 Corn Dump Pit #1 Uncaptured Emissions (will be removed)

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

Standards of Performance for Dry Bulk Agricultural Commodity Facilities

FUGI 3 Truck Traffic on Paved Roads

Title I Condition to avoid PSD & CAAA of 1990

Consent Decree requirements to minimize fugitive dust emissions Process throughput limits: 15,680 tons/day of grain receiving, 3,640 tons/day of DDGS shipping, 840,000 gal/day of denaturant delivery, 2482 tons/day of CO2 shipping, and 84,000 gal/day of corn oil. These values were used to calculate the PTE of fugitive emissions from truck traffic.

FUGI 4 Cooling Towers Minn. R. 7011.0715 Standards of Performance for Post-1969 Industrial Process Equipment

FUGI 5 Valves, Flanges, and Seals (tank leaks)

40 CFR pt. 60, subp. VVa Standards of Performance for Volatile Organic Liquid Storage Vessels for which construction, reconstruction, or modification commenced after July 23, 1984

FUGI 7 Cooling Towers Minn. R. 7011.0715 Standards of Performance for Post-1969 Industrial Process Equipment

STRU 9 Grain Receiving Baghouse (will be removed)

Title I Condition to avoid PSD PM, PM10 and PM2.5 limits to avoid major source classification under 40 CFR Section 52.21. Process throughput limit: ≤ 354 tons/hr of grain received. This value was used to calculate the PTE of STRU 9 and can be changed based on the throughput rate sustained during performance testing. Operating hours: ≤ 14 hours/day. Requirements to operate control equipment which was relied upon for PTE calculations.

STRU 11 Grain Handling Baghouse (will be removed)

Title I Condition to avoid PSD PM, PM10 and PM2.5 limits to avoid major source classification under 40 CFR Section 52.21. Process throughput limit: ≤ 354 tons/hr of grain throughput. This value was used to calculate the PTE of STRU 11 and can be changed based on the throughput rate sustained during performance testing. Operating hours: ≤ 14 hours/day.


Level* Applicable Regulations Comments: Requirements to operate control equipment which was relied upon for PTE calculations.

STRU 12 Grain Milling Baghouse (will be removed)

Title I Condition to avoid PSD PM, PM10 and PM2.5 limits to avoid major source classification under 40 CFR Section 52.21. Process throughput limit: ≤ 70 tons/hr of grain throughput to hammermills. This value was used to calculate the PTE of STRU 12 and can be changed based on the throughput rate sustained during performance testing. Requirements to operate control equipment which was relied upon for PTE calculations.

STRU 15 DDGS Cooling Cyclone (will be removed)

Title I Condition to avoid PSD Minn. R. 7011.1005, subp. 3(D)

VOC, PM, PM10 and PM2.5 limits to avoid major source classification under 40 CFR Section 52.21. Process throughput limit: ≤ 50.23 tons/hr of output rate of DDGS from dryer. This value is based on the throughput rate sustained during the most recent performance tests. Requirements to operate control equipment which was relied upon for PTE calculations. Standards of Performance for Dry Bulk Agricultural Commodity Facilities

STRU 23 Flour Transfer Baghouse (will be removed)

Title I Condition to avoid PSD Minn. R. 7011.1005, subp. 3(D)

PM, PM10 and PM2.5 limits to avoid major source classification under 40 CFR Section 52.21. Process throughput limit: ≤ 70.0 tons/hr of grain input to mills. This value was used to calculate the PTE of STRU 23 and can be changed based on the throughput rate sustained during performance testing. Requirements to operate control equipment which was relied upon for PTE calculations. Standards of Performance for Dry Bulk Agricultural Commodity Facilities

TREA 6, STRU 24 TO/HRSG

Title I Condition to avoid PSD & CAAA of 1990 Minn. R. 7011.0610 Minn. R. 7011.0715

VOC, CO, PM, PM10 and PM2.5 limits established from Al-Corn Clean Fuel Consent Decree and to avoid major source classification under 40 CFR Section 52.21 NOX, PM10 and PM2.5 limits assumed in modeling calculations. SO2 limit to avoid major source classification under 40 CFR Section 52.21. Separate limits for annual and short-term rates used in the modeling demonstration were created. Process throughput limit: ≤ 70.0 tons/hr of grain input to mills. This value was used to calculate the PTE of STRU 23 and can be changed based on the throughput rate sustained during performance testing. Requirements to operate control equipment which was relied upon for PTE calculations. Standards of Performance for Fossil Fuel Burning Direct Heating Equipment. Opacity and PM limits applies to EQUIs, 47, 54, and TREA 6. Standards of Performance for Post-1969 Industrial Process Equipment. Opacity and PM limits applies to EQUIs 234 and 235 (Multiclones).

STRU 27 Fermentation System (will be removed)

Title I Condition to avoid PSD & CAAA of 1990 Minn. R. 7011.0715

VOC limit established from Al-Corn Clean Fuel Consent Decree and to avoid major source classification under 40 CFR Section 52.21 Process throughput limit: ≤ 900 gal/min of grain input to mills. This value was used to calculate the PTE of STRU 23 and can be changed based on the throughput rate sustained during performance testing. Standards of Performance for Post-1969 Industrial Process Equipment


Level* Applicable Regulations Comments: TREA 16, STRU 37 Fermentation System Scrubber

Title I Condition to avoid PSD & CAAA of 1990 Minn. R. 7011.0715

VOC limit established from Al-Corn Clean Fuel Consent Decree and to avoid major source classification under 40 CFR Section 52.21 Process throughput limit: ≤ 1760 gal/min beer output rate to distillation process. This value was used to calculate the PTE of STRU 37 and can be changed based on the throughput rate sustained during performance testing. Requirements to operate control equipment which was relied upon for PTE calculations. Standards of Performance for Post-1969 Industrial Process Equipment

STRU 38 - Grain Handling Baghouses

Title I Condition to avoid PSD Minn. R. 7007.0800 Minn. R. 7011.1005, subp. 3(A)

PM, PM10 and PM2.5 limits and requirements to operate control equipment to avoid major source classification under 40 CFR Section 52.21. Operating hours: ≤ 14 hours/day. Process throughput limit: ≤ 1120 tons/hr of grain received. This value was used to calculate the PTE of STRU 38 and can be changed based on the throughput rate sustained during performance testing. Standards of Performance for Dry Bulk Agricultural Commodity Facilities



PM, PM10 and PM2.5 limits and requirements to operate control equipment to avoid major source classification under 40 CFR Section 52.21. Process throughput limit: ≤ 168 tons/hr of grain received. This value was used to calculate the PTE of STRU 38 and can be changed based on the throughput rate sustained during performance testing. Standards of Performance for Dry Bulk Agricultural Commodity Facilities



PM, PM10 and PM2.5 limits and requirements to operate control equipment to avoid major source classification under 40 CFR Section 52.21. Process throughput limit: ≤ 168 tons/hr of grain received. This value was used to calculate the PTE of STRU 38 and can be changed based on the throughput rate sustained during performance testing. Standards of Performance for Dry Bulk Agricultural Commodity Facilities

STRUs 45, 48 DDGS Storage Silo Baghouses

Title I Condition to avoid PSD Minn. R. 7011.1005

Requirements to operate control equipment to avoid major source classification under 40 CFR Section 52.21. Standards of Performance for Dry Bulk Agricultural Commodity Facilities

STRU 46 DDGS Cooling Cyclone


Pollutant emission limits and requirements to operate control equipment to avoid major source classification under 40 CFR Section 52.21. Standards of Performance for Post-1969 Industrial Process Equipment

TREA 25, STRU 47 Distillation/DDGS/RTO


Pollutant emission limits and requirements to operate control equipment to avoid major source classification under 40 CFR Section 52.21. Standards of Performance for Post-1969 Industrial Process Equipment Standards of Performance for Fossil Fuel Burning Direct Heating Equipment

TREA 6 (CE011) Title I Condition to avoid PSD 40 CFR pt. 60, subp. Dc

Limits to avoid major source classification under 40 CFR Section 52.21 Standards of Performance for Small Industrial Commercial Institutional Boilers


3. Technical information

3.1 Project timeline and removal of old units

Due to the amount of equipment changes the project will be implemented in phases. Requirements for emission units, control equipment, and stacks which will be removed from the facility remain in the permit so that they may still be operated following permit issuance. For each new unit, or stack representing a group of emission units, a requirement was added to the permit to authorize construction within two years of permit issuance. For new units that are replacing old ones, actual operation of the new units is only authorized to begin after permanently removing and/or disabling the piece of equipment which it is replacing. The Permittee will be required to submit notifications with the dates of the equipment removal and actual start of operation. Actual operation is defined in the permit as “as the date that normal process operations commence, and does not include project commissioning activities”. This allows the Permittee to continue ethanol production while the new emission unit groups are being installed and tested.

3.2 Modeling

The Permittee completed an air dispersion modeling analysis to demonstrate compliance with the National Ambient Air Quality Standards (NAAQS), the Minnesota Ambient Air Quality Standards (MAAQS) and the MPCA air emissions risk analysis (AERA) risk assessment screening spreadsheet (RASS) air emissions analysis. To assess whether the Project will cause or contribute to an air quality violation, the Permittee completed a Significant Impact Level (SIL) analysis for the Project using the U.S. Environmental Protection Agency regulatory plume dispersion model AERMOD. Pollutants modeled in the SIL analysis were SO2, CO, PM10, PM2.5, and NO2. Cumulative dispersion modeling analysis was completed for all receptors greater than the SIL: NO2, PM10, and PM2.5. The modeling results predicted a maximum impact that was below the NAAQS and MAAQS for all pollutants modeled for all averaging times as shown in the Table below:

Table 9. NAAQS Modeling Results

Pollutant

Averaging Period

Modeled Impact NAAQS MAAQS Percent

of NAAQS

(%)

Percent of MAAQS

(%)

Exceed

NAAQS/MAAQS? (μg/m3) (μg/m3) (μg/m3)

NO2 1-Hour 187.74 188 NA 99.86 NA No Annual 10.92 100 100 10.93 10.93 No

SO2 1-Hour 27.67 196 1300 14.12 2.13 No 3-Hour 26.67 NA 1300 NA 2.05 No

24-Hour 10.67 365 365 2.92 2.92 No Annual 2.05 80 60 2.56 3.42 No

PM10 24-Hour 122.52 150 150 81.68 81.68 No Annual 36.65 NA 50 NA 73.30 No

PM2.5 24-Hour 33.07 35 65 94.48 50.88 No Annual 9.61 12 15 80.12 64.09 No

As a result of the modeling, tiered modeling requirements were added to the total facility requirements for NO2, PM10, and PM2.5 according to the thresholds in Table 9. Tier 3 modeling requirements were added for NO2 and PM2.5, while Tier 2 modeling requirements were added for PM10. The requirements ensure that changes cannot be made at the facility which would affect modeled parameters unless an equivalent or better dispersion modeling demonstration is completed.

Table 10. Modeling Language Tier Thresholds % 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 Tier 3** Tier 2** Tier 1 Not PSD – No Limits Tier 1 Tier 1 Tier 1 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 facility relied upon a memo dated 5/16/2011 from Chris Nelson, MPCA manager to remove paved road fugitive dust from the air dispersion modeling analysis. Paved road fugitive dust does not need to be included in the model if the predicted ambient impacts are less than or equal to 95% of the applicable PM10 and PM2.5

standards. Instead, the permit must contain an enforceable fugitive dust control plan or comparable permit conditions. These conditions were added at FUGI 3 – Paved Roads.

3.3 Performance testing at maximum capacity

Performance tests shall be conducted at worst case conditions as defined at Minn. R. 7017.2005, subp. 8. For ethanol production facilities, this means that each process emitting to a tested stack must be operated at maximum capacity during testing. However, it is often difficult at an ethanol facility to determine maximum capacity, or to always achieve maximum permitted capacity. Language was added to all performance testing requirements to ensure that short-term production rates relied upon to determine compliance with lb/hr emission limits are not exceeded. An Appendix C was also added to the permit which lists the process parameters that must be tracked during each performance test. These limits are used to define expected worst case conditions according to Minn. R.7017.2025 subp. 3(A).

Following the initial performance tests, if the Permittee tests at < 80% of the associated emission limit(s) and the throughput rate during testing is > 90% of the established short-term listed production limit, the Permittee can increase the short-term production limit by 10% without a retest.

3.4 Emission unit and control equipment replacement provisions

Permit flexibility conditions were added that make existing conditions enforceable for replacement and modified control devices and emission units. This may allow the Permittee to make these changes without necessarily triggering a major amendment. The Permittee may only replace or modify individual units which can meet the requirements of the permit. Language was changed at the TREA and STRU levels so that replacement or modified units will be subject to the existing permit requirements. These flexibility provisions were added to the following units:

Replacement flexibility provisions for certain emission units were added to the following stacks:

· STRU 24: Dryers which vent to STRU 24/TREA 6 (RTO)

· STRU 37: Pre-fermentation, fermentation, and distillation process units which vent to TREA 16 and STRU 37 (evaporator, distillation stripper, molecular sieve, liquefaction tank, or beer well).

· STRU 38: Conveyors, elevator legs, drag lines, grain bins or grain-cleaning equipment venting to STRU 38, except for the grain receiving pits (EQUIs 179 - 181).

· STRU 47: Distillation units and dryers which vent to STRU 47/TREA 25 (New RTO)

Replacement flexibility provisions were also added for the following control equipment units:


· TREA 17: Grain Handling Baghouse venting to STRU 38

· TREA 18: Grain Milling Baghouse venting to STRU 39

· TREA 19: DDGS Loadout Baghouse venting to STRU 40

· DDGS Conveyance Baghouses (TREAs 20 – 22; venting to STRUs 42 – 44)

· DDGS Storage Silo Baghouses (TREAs 23 and 26; venting to STRUs 45 and 48)

New requirements were added at the total facility level to track equipment replacements using an equipment inventory (Appendix C of the permit).

3.5 Uncaptured grain and DDGS emissions

Emissions from grain and DDGS loading and unloading can be reasonably captured (for example, by closing doors), so these do not qualify as fugitive emissions under New Source Review. To account for these uncaptured emissions, EQUIs were added for Uncaptured Grain Handling - EQUI 223 and DDGS Loadout Uncaptured Emissions - EQUI 224.

The hoods which are used to capture emissions from loading and unloading will need to be evaluated according to Minn. R. 7011.0072. Permit requirements to conduct initial hood certifications for the grain receiving and DDGS loadout areas were added to EQUIs 179-181 – Dump Pits #1-3, EQUI 209 – DDGS Loadout – truck, and EQUI 210 – DDGS Loadout – railcar.

3.6 NESHAP subp. ZZZZ requirements

Specific requirements to comply with NESHAP subp. ZZZZ were added to the permit. Table 11 below gives further information on the applicability of 40 CFR pt. 63, subp. ZZZZ for each of the facility’s generators. Catalytic oxidizers (TREAs 21 - 23) were installed on the generators (EQUIs 56 – 58) to comply with the standard, and applicable control equipment rules and subp. ZZZZ standards were added to the permit at COMG 2.

Table 11. Facility Generator Details

Subject Item Name Compression (CI) or

Spark Ignition (SI)

Engine rating (bHP)

Installation date

Subject to NSPS subp. IIII?

Subject to NESHAP subp. ZZZZ?

Permit Conditions/ NOTES

EQUI 28/ EU046 Office Generator SI: comply by

10/19/2013 41 2000 No Yes 90,000 CF/yr limit

EQUI 29/ EU047

Well House Generator

CI: comply by 5/3/2013 533 2001 No Yes

Catalytic oxidizer installed 5/3/2013; Limited use

EQUI 60/ EU048

Dryer #1 (Dryer B) Load Generator

CI: comply by 5/3/2013

1881 2001 No Yes


EQUI 63/ EU049

Process Generator



EQUI 62/ EU050

Cooling Tower Generator



EQUI 61/ EU053

Dryer #2 (Dryer A) Load Generator



EQUI 211 Emergency Diesel Fire Pump Engine

CI: comply by 5/3/2013 600 2017 Yes Yes

NESHAP subp. ZZZZ compliance met through NSPS subp. IIII


All engines have displacements of less than 30 liters/cylinder and are therefore required to use diesel fuel that meets the requirements in 40 CFR §80.510(b) for nonroad diesel fuel. None of the engines are used for blackstart purposes, and all are fitted with closed crankcase ventilation systems.

Limited use engine requirements

A limit of 100 hours/yr for each COMG 2 engine was added to the permit in order to designate the engines as limited use only under the NESHAP subp. ZZZZ. By designating the engines as limited use, the Permittee is required to conduct performance testing every 5 years rather than every 3 years for each engine. This limit was relied upon in the modeling exercise and to avoid major source status under PSD.

3.7 New Emergency Fire Pump - EQUI 211

A new emergency fire pump engine will be installed at the facility. The engine will be at an area source of HAPs and is subject to 40 CFR pt. 60, subp. IIII. While the unit is subject to 40 CFR pt. 63, subp. ZZZZ, in accordance with 40 CFR 63.6590(c), the unit meets the requirements of this part by meeting the requirements of 40 CFR pt. 60, subp. IIII. No further requirements apply for emergency fire pump engines under subpart ZZZZ. The Permittee will demonstrate compliance with the NSPS subpart IIII by purchasing an engine certified by the manufacturer to meet the emission limits of the subpart. Best management practices for emergency engine use and testing were also added to EQUI 154. These practices are required in the permit in lieu of including the emergency fire pump in the modeling analysis.

3.8 New emergency use bypass stacks

In addition to the new stacks described above, two ‘emergency’ stacks were also added to the permit. During emergency situations, exhaust from these emission units can be vented to these stacks while these emission units are in the process of shutting down. Use of these stacks will be reported as a deviation and as an excursion:

· STRU 49 – CHP Dump Stack: Turbine (EQUI 225) emissions will vent to this stack during emergency situations only. If the duct burner/HRSG must be shut down, turbine emissions will vent to the bypass stack rather than STRU 52 and the turbine will be shut down as quickly and safely as possible. The duct burner/HRSG (EQUI 226) will not operate when the bypass stack is in use. The turbine and duct burner are uncontrolled at all times so it is not necessary to recalculate the emissions during bypass events.

· STRU 53 – Dryer/RTO Bypass Stack: Dryer (EQUI 218) emissions will vent to this stack during emergency situations only. If the new RTO (TREA 25) must shut down, dryer emissions will vent to the bypass stack and the dryer will be shut down as quickly and safely as possible. Emissions for this period will be calculated as uncontrolled for emission inventory purposes. RTO shutdown events are expected to be infrequent, as the facility’s existing dryer/TO system (EQUIs 47 and 54/TREA 6) has had zero hours of uncontrolled operations in the last three years. When the TO shuts down, the facility shuts down their dryers.

3.9 Consent decree requirements

A Consent Decree was filed with the United States District Court for resolving claims pursuant to Section 113(b) of the Clean Air Act. It was executed on 9/20/2002 and terminated 11/3/2005. The Consent Decree addressed, among other issues, injunctive relief for potential violations of the Prevention of Significant Deterioration (PSD) provisions of the Act for VOCs, PM, PM10, SO2, CO, and NOX. The Consent Decree alleged that the Facility commenced construction of a major emitting facility and major modifications of a major


emitting facility in violation of the Prevention of Significant Deterioration (PSD) provisions of the Act without obtaining the appropriate preconstruction permits nor installing the appropriate air pollution control equipment. As a result of the Consent Decree, the Permittee was required to comply with a Control Technology Plan (CTP) (Attachment 6 to this TSD) and compliance limits which were placed in the permit.

The Consent Decree was terminated 11/3/2005 after all control equipment had been installed according to the Consent Decree and CTP. The Permittee had completed annual performance tests in accordance with the Consent Decree and CTP, with the test results meeting Consent Decree and air permit limits.

Emissions from certain processes at the facility remain subject to the Consent Decree and CTP requirements, including units that are subject to BACT-equivalent controls as a result of the Consent Decree. A detailed analysis of the BACT-equivalent limits in the permit is included as Attachment 7 to this TSD.

3.10 Biodigester flare

A biodigester is used at the facility to reduce liquid and solid waste. Methane gas is produced by the biodigester, which is sent to the existing DDGS dryers (EQUI 47s and 54). Previously, the methane was sent to a biodigester flare (formerly EU 040) If the dryers were shut down. The biodigester flare is no longer operated and the unit and corresponding stack was removed from the permit.

3.11 Calculations of potential to emit

Attachment 1 to this TSD contains a summary of the proposed PTE of the facility, calculation spreadsheets and supporting information prepared by the MPCA and the Permittee. Based on the calculations, the project is not subject to NSR under 40 CFR §52.21.

Equipment that will be removed as a part of the planned project was left in the permit in order to allow operation after permit issuance. However, the PTE calculations assumed that all of the emissions would be from the new replacement units which all have larger capacities and therefore greater PTE’s than the old units. For each new unit, a requirement was added to the permit which authorizes operation only after the unit which it is replacing is permanently removed or disabled.

The VOC and HAP emission calculations included in the permit application are primarily based on the most recent performance tests that measured VOCs as VOCs by mass. The airflows and concentrations which were measured during the most recent tests for the existing scrubber and RTO were scaled according to the increase in capacity to determine the PTE of the new scrubber and RTO. Summaries of the facility’s most recent performance tests are included in Attachment 5 to this TSD.

3.12 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. · The kind of monitoring found on similar units elsewhere.


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

Table 12. Monitoring

Level* Requirement (basis) Additional Monitoring Discussion

TFAC Total Facility

Process throughput: ≤ 133.237 MMgal/yr of denatured ethanol Process Throughput: ≤ 1.40 MMton/yr of corn received Process Throughput: ≤ 440,000 ton/yr of DDGS (Avoid major source under 40 CFR § 52.21)

Daily and monthly recordkeeping

The Permittee shall record and maintain the throughputs on each operating day, and sum the total monthly.

COMG 2 Facility Diesel Generators

Operating Hours: ≤ 100 hr/yr (each engine) on a 12-month rolling sum basis (40 CFR pt. 63, subp. ZZZZ, Avoid major source under 40 CFR § 52.21)

Hour meter on each engine, recordkeeping

The Permittee shall record and maintain the total hours of operation for each COMG 2 engine on each operating day, and sum the total monthly.

Sulfur Content of Fuel: ≤ 15 ppmw (40 CFR § 60.4207(c))

Fuel supplier certification of sulfur content, recordkeeping

The engines must use ultra-low sulfur diesel fuel only.

CO: ≤ 23 ppm (40 CFR pt. 63, subp. ZZZZ)

Performance testing, temperature and pressure drop monitoring at TREAs 27-31

Performance tests are required every 5 years on each unit.

Opacity: ≤ 20% SO2: ≤ 0.50 lb/MMBtu heat input (Minn. R. 7011.2300)

None

The potential to emit for each unit is 0.0015 lb/MMBtu due to equipment design and allowable fuel. Minimal opacity is expected due to the fuel.

COMG 3 HAPs Limit Group

HAPs - Total: ≤ 17.0 tons/yr, HAPs – Single (Acetaldehyde): ≤ 9.0 tons/yr, HAPs – Single (Formaldehyde): ≤ 5.0 tons/yr on a 12-month rolling sum basis (Limits to avoid major source under 40 CFR § 63.2))

Performance testing, recordkeeping

Initial performance tests are required at the respective STRU levels to test HAP emission factors. The Permittee shall keep monthly records of individual HAP emissions.

COMG 10 Combustion turbine and duct burner

NOX: ≤ 25 ppm at 15% O2 SO2: ≤ 0.060 lb/MMBtu (40 CFR pt. 60, subp. KKKK)

Performance testing Annual performance tests are required for the combined emissions of the turbine and duct burner, STRU 52

COMG 11 DDGS Storage and Loadout

Opacity: ≤ 5% for uncaptured emissions from a truck/rail unloading station, rail loading station, or grain handling operation Opacity: ≤ 10% for uncaptured emissions from a truck loading operation (Minn. R. 7011.1005)

Visible emissions checks

The Permittee shall check each door of the DDGS building door for any visible emissions at least once each day of operation during daylight hours while DDGS or grain is being handled or transferred into or out of the building

COMG 12 DDGS Storage Silo Baghouses

Total PM, PM10 control efficiency: ≥ 92.2%, 68.9% (Avoid major source under 40 CFR § 52.21)

Pressure drop and visible emissions monitoring

The required control efficiencies are less than those in Minn. R. 7011.0070 so performance testing is not necessary.

COMG 14 Emission sources subject to Minn. R. 7011.0715 (IPER)

Opacity: ≤ 20% Total PM: ≤ 0.30 gr/dscf (Minn. R. 7011.0715)

None The tanks store ethanol or denaturant so minimal PM and opacity emissions are expected.

COMG 15 Diesel Generator Oxidation Catalysts

CO control efficiency: ≥ 70.0% (40 CFR Pt. 63, subp. ZZZZ)

Performance testing, temperature and pressure drop

Performance tests are required every 5 years on each unit. The pressure drop ranges for each catalyst have already been set through initial performance tests.


monitoring at COMG 15

COMG 16 Ethanol Loadout Racks #3 and #4

Process throughout: ≤ 740.21 hours per year of denatured ethanol loadout via railcar (Avoid major source under 40 CFR §§ 52.21 and 63.2)


The Permittee shall record and maintain the hours of operation on each operating day, and sum the total monthly. Documentation for the emission factors used for HAP emissions from ethanol loadout are given in Attachment 8 to this TSD.

EQUI 7 DDGS Loadout (will be removed) Opacity: ≤ 5% (Minn. R. 7011.1005) Visible emissions

checks

The Permittee shall check rail loadout operation for any visible emissions at least once each day of operation during daylight hours while DDGS or grain is being handled or transferred into or out of the building

EQUI 28 Office 25 kW Generator, nat. gas

Hours of operation: ≤ 250 hours/year (Avoid major source under 40 CFR § 52.21)


The Permittee shall record and maintain the hours of operation on each operating day, and sum the total monthly.

Opacity: ≤ 20% (Minn. R. 7011.2300) None

The engine is restricted to natural gas use only so minimal opacity is expected if the engine is properly maintained and operated.

SO2: ≤ 0.50 lb/MMBtu (Minn. R. 7007.0800, subps. 14 & 16(J))

None The potential to emit from the unit is 0.0006 lb/MMBtu due to equipment design and allowable fuels.

EQUI 74 Grain Receiving – Uncaptured Emissions (will be removed)

Opacity: ≤ 5% (Minn. R. 7011.1005) Annual hood evaluations

Each control device hood must be evaluated as specified in Minn. R. 7011.0072, subp. 2(A) and must conform to the design and operating requirements listed in Minn. R. 7011.0072.

EQUI 211 Emergency Fire Pump

NMHC+ NOX: ≤ 3.0 g/kW-hr Total PM: ≤ 0.15 g/kW-hr (40 CFR pt. 60, subp. IIII)

Engine purchase records

40 CFR § 60.4202 requires stationary CI internal combustion engine manufacturers to meet the limits of 40 CFR § 89.112.

EQUIs 212-214 DDGS Conveyance Aspiration #1-3

PM, PM10, PM2.5: ≤ 0.0430 lb/hr (Avoid major source under 40 CFR § 52.21, Minn. 7009.0010)

Performance testing Initial performance testing requirements are located at STRUs

Opacity: ≤ 10% (Minn. R. 7011.1005) VE checks at TREA 20 Minimal opacity is expected if control equipment is properly operated.

EQUIs 215 and 222 DDGS Bins #1-2

PM, PM10: ≤ 0.130 lb/hr PM2.5 ≤ 0.070 lb/hr PM10, PM2.5 : ≤ 0.260 lb/hr (Avoid major source under 40 CFR § 52.21, Minn. 7009.0010))

Pressure drop monitoring, VE checks at TREA 23

Separate emission limits are used since separate process throughput limits were used when calculating PTE for modeling purposes.

Opacity: ≤ 10% (Minn. R. 7011.1005) Minimal opacity is expected if control equipment is properly operated.

EQUIs 223 and 224 Uncaptured emissions

Opacity: ≤ 5% from a railcar or truck unloading station, railcar loading station, or grain handling operation Opacity: ≤ 10% from a truck loading station (Minn. R. 7011.1005)

Annual hood evaluations



EQUI 243 Corn Dump Pit #1 Uncaptured Emissions (will be removed)

Opacity: ≤ 5% from a railcar or truck unloading station, railcar loading station, or grain handling operation (Minn. R. 7011.1005)

Annual hood evaluations


FUGI 3 Truck Traffic on Paved Roads

Process throughout: ≤ 15680 ton/day of grain receiving Production: ≤ 3640 ton/day of DDGS shipping, 14 hrs/day Process throughout: ≤ 840,000 gal/day of denaturant delivery Production: ≤ 3.360 MMgal/day of ethanol shipping Production: ≤ 84,000 gal/day of corn oil shipping Production: ≤ 2482 tons/day of carbon dioxide shipping (Avoid major source under 40 CFR § 52.21, Minn. 7009.0010)


The Permittee shall record and maintain the throughputs on each operating day, and sum the total monthly.

FUGIs 4 & 7 Cooling Towers Opacity: ≤ 20% Total PM: ≤ 0.30 gr/dscf (Minn. R. 7011.0715)

None

The PTE was determined using the guidance for ‘Calculating TSP, PM-10 and PM-2.5 from Cooling Towers’ from the New Mexico Environment Department. Cooling tower particulate emissions are a function of the drift rate and the concentration of dissolved solids (TDS) present in the water. The Permittee assumed a TDS concentration of 2,500 ppm and manufacturer supplied drift losses of 0.005% and 0.0025% for FUGIs 4 and 7.

STRU 9 Grain Receiving Baghouse (will be removed)

PM, PM10, PM2.5 ≤ 0.290 lb/hr Process throughput: ≤ 354 tons/hr of grain received (Avoid major source under 40 CFR § 52.21, Minn. 7009.0010)

Recordkeeping, Performance testing, pressure drop monitoring, VE checks at TREA 4

The Permittee shall record and maintain the throughputs on each operating day, and sum the total monthly. Recordkeeping requirements are located at TFAC 2 level. Performance tests are used to verify emission factors. The next test is due 9/25/2018, unless the unit is removed prior to then.

STRU 11 Grain Handling Baghouse (will be removed)

PM, PM10, PM2.5 ≤ 0.580 lb/hr Process throughput: ≤ 354 tons/hr of grain received (Avoid major source under 40 CFR § 52.21, Minn. 7009.0010)


Performance tests are used to verify emission factors. The next test is due 9/25/2018, unless the unit is removed prior to then. The Permittee shall record and maintain the throughputs on each operating day, and sum the total monthly. Recordkeeping requirements are located at TFAC 2 level.

STRU 12 Grain Milling Baghouse (will be removed)

PM, PM10, PM2.5 ≤ 0.130 lb/hr (Avoid major source under 40 CFR § 52.21, Minn. 7009.0010)

Performance testing

Performance tests are used to verify emission factors. The next test is due 9/25/2018, unless the unit is removed prior to then.

Process throughput: ≤ 70 tons/hr of grain received


The Permittee shall record and maintain the throughputs on each operating day, and sum the total monthly. Recordkeeping requirements are located at TFAC 2 level.

STRU 15 DDGS Cooling Cyclone (will be removed)

Opacity: ≤ 10% (Minn. R. 7011.1005) None

The opacity limit applies to each subject item venting to STRU 15. Minimal opacity is expected from the dryers and coolers.

Process throughput: ≤ 50.23 tons/hr output rate of DDGS from dryer PM, PM10, PM2.5: ≤ 5.87 lb/hr VOC: ≤ 4.00 lb/hr

Recordkeeping, Performance testing

The Permittee shall record and maintain the throughputs during each performance test. The next test is due 8/7/2018, unless the unit is removed prior to then.


(Avoid major source under 40 CFR § 52.21 and CAAA, Minn. 7009.0010)

STRU 23 Flour Transfer Baghouse (will be removed)

Process throughput: ≤ 70.0 tons/hr of grain input to mills PM, PM10, PM2.5: ≤ 0.28 lb/hr (Avoid major source under 40 CFR § 52.21, Minn. 7009.0010)



STRU 24 TO/HRSG

CO: ≤ 16.63 lb/hr PM, PM10, PM2.5: ≤ 3.560 lb/hr VOC: ≤ 2.50 lb/hr NOX: ≤ 9.840 lb/hr, 7.440 lb/hr SO2: ≤ 9.130 lb/hr (Avoid major source under 40 CFR § 52.21 and CAAA)

Temperature monitoring at TREA 6, performance testing

Different limits are established due to Al-Corn’s consent decree and those used in calculating the current PTE. The Permittee shall record the relevant process throughputs during each test.

PM: ≤ 5.220 lb/hr PM10, PM2.5: ≤ 7.00 lb/hr VOC: ≤ 2.70 lb/hr NOX: ≤ 7.280 lb/hr (Minn. 7009.0010)


None The thermal oxidizer burns natural gas so minimal opacity is expected.

STRU 27 Fermentation System (will be removed)

VOC: ≤ 9.60 lb/hr Process throughput: ≤ 900 gal/min beer output rate (Avoid major source under 40 CFR § 52.21 and CAAA)

Performance testing, Recordkeeping, Operation of control equipment (TREA 10)



Operation of control equipment (TREA 10)

If the control equipment is properly operated, minimal opacity and particulate emissions are expected.

STRU 37 Fermentation Scrubber

VOCs: ≤ 20.80 lb/hr Process throughput: ≤ 1760 gal/min beer output rate to distillation process (Avoid major source under 40 CFR §§ 52.21 & 63.2)

Scrubber water flowrate, additive flow rate, and pressure drop monitoring at TREA 10, performance testing

Initial performance tests to confirm emission factors for each pollutant are due 180 days after initial startup. The Permittee shall record the relevant process throughputs during each test.


None If the control equipment is properly operated, minimal opacity and particulate emissions are expected.

STRU 38 Grain Handling Baghouse

Total PM, PM10, PM2.5: ≤ 1.93 lb/hr Process throughput: ≤ 1120 tons/hr grain received (Avoid major source under 40 CFR § 52.21)

Pressure drop monitoring at TREA 17, performance testing


Opacity: ≤ 5% (Minn. R. 7011.1005) VE checks at TREA 17 Minimal opacity is expected if the control

equipment is properly operated

STRU 39 Grain Milling Baghouse

Total PM, PM10, PM2.5 control efficiency: ≤ 1.54 lb/hr Process throughput: ≤ 168 tons/hr grain input to hammermills (Avoid major source under 40 CFR § 52.21)




Opacity: ≤ 5% (Minn. R. 7011.1005) VE checks at TREA 18 Minimal opacity is expected if the control

equipment is properly operated

STRU 40 DDGS Loadout Baghouse

Total PM, PM10, PM2.5: ≤ 0.43 lb/hr (Avoid major source under 40 CFR § 52.21)



Opacity: ≤ 10% from control equipment (Minn. R. 7011.1005)

VE checks at TREA 19 Minimal opacity is expected if the control equipment is properly operated

STRU 46 DDGS Cooling Cyclone

VOC: ≤ 4.00 lb/hr PM, PM10, PM2.5: ≤ 5.87 lb/hr Process throughput: ≤ 50.23 tons/hr dryer output rate (Avoid major source under 40 CFR §52.21)

Performance testing



None If the control equipment is properly operated, minimal opacity and particulate emissions are expected.

STRU 47 Distillation/DDGS/RTO

CO: ≤ 10.640 lb/hr PM, PM10, PM2.5: ≤ 2.280 lb/hr PM, PM10, PM2.5: ≤ 4.480 lb/hr VOC: ≤ 1.60 lb/hr NOX: ≤ 4.660 lb/hr, 7.440 lb/hr SO2: ≤ 5.840 lb/hr Process throughput: ≤ 50.23 tons/hr dryer output rate (Avoid major source under 40 CFR § 52.21, Minn. 7009.0010)

Temperature monitoring at TREA 25, performance testing

Separate emission limits are used since separate process throughput limits were used when calculating PTE for modeling purposes. The Permittee shall record the relevant process throughputs during each test.

Opacity: ≤ 20% Total PM: ≤ 0.30 gr/dscf (Minn. R. 7011.0715 and Minn. R. 7011.0610)

None The thermal oxidizer burns natural gas so minimal opacity is expected.

STRU 49 Combined Heat and Power Dump Stack

PM, PM10, PM2.5: ≤ 4.750 lb/hr CO: ≤ 17.980 lb/hr NOX: ≤ 26.310 lb/hr (Avoid major source under 40 CFR § 52.21, Minn. 7009.0010)

Performance testing Initial performance tests are used to verify emission factors.

TREA 1 Grain milling baghouse (will be removed)

Total PM, PM10, PM2.5 control efficiency: ≥ 99.9%, 99.9%, 99.8% (Avoid major source under 40 CFR §52.21)

Pressure drop monitoring, visible emissions checks and performance testing at STRU 12

Performance tests are used to verify control efficiencies and emission rates. The next test is due 9/25/2018, unless the unit is removed prior to then.

TREA 2 Flour transfer fabric filter (will be removed)


Pressure drop monitoring, visible emissions checks at STRU 23

The efficiencies are less than the listed control efficiencies in Minn. R. 7007.0070. Performance tests are not required.

TREA 3 Ethanol Loading Rack Flare #1 (will be removed)

VOC control efficiency: ≥ 98.0% Opacity: 5% (Avoid major source under 40 CFR §52.21 and CAAA)

VE checks, pilot flame monitoring


TREA 4 Fabric filter (will be removed)

Total PM, PM10, PM2.5 control efficiency: ≥ 99.4%, 98.7%, 92.4% (Avoid major source under 40 CFR §52.21, Minn. 7009.0010)



TREA 6 Thermal Oxidizer CO control efficiency: ≥ 90.0% VOC control efficiency: ≥ 95.0%

Temperature monitoring,

TREA 6 is subject to CAM as an Other PSEU. CAM will be applied at permit reissuance.


(Avoid major source under 40 CFR §§ 52.21 and 63.2)

performance testing at STU 24

TREA 10 Packed-Gas Adsorption Column (will be removed)

VOC control efficiency: ≥ 95.0% (Avoid major source under 40 CFR §§ 52.21 and 63.2 and CAAA)

Pressure drop monitoring, water flow rate monitoring, performance testing at STRU 27


TREA 12 Fabric filter (will be removed)

Total PM, PM10, PM2.5 control efficiency: ≥ 98.9%, 97.5%, 97.0% (Avoid major source under 40 CFR §52.21, Minn. 7009.0010)



TREA 15 Ethanol Loading Rack Flare #2

VOC control efficiency: ≥ 98.0% Opacity: 5% (Avoid major source under 40 CFR §52.21 and 63.2)

VE checks, pilot flame monitoring


TREA 16 Fermentation System Scrubber

VOC control efficiency: ≥ 95.0% (Avoid major source under 40 CFR §§ 52.21 and 63.2)

Pressure drop, water flow rate and liquid additive monitoring, performance testing at STU 37


TREA 17 Grain Handling Baghouse




TREA 18 Grain Milling Baghouse




TREA 19 DDGS Loadout Baghouse


Pressure drop monitoring, visible emissions checks at STRU 40

Annual hood evaluations are also required for units with capture efficiencies less than 80%.

TREA 20, 21, 22 DDGS Conveyance Aspiration #1-3


Pressure drop monitoring, visible emissions checks


TREA 23, 24 DDGS Storage Fill Vent #1-2

Total PM, PM10, control efficiency: ≥ 92.2%, 68.9% (Avoid major source under 40 CFR §52.21)

Pressure drop monitoring, visible emissions checks


*Location of the requirement in the permit (e.g., EQUI000000001, STRU0000000002, etc.).

4. Insignificant activities

Al-Corn Clean Fuel has several operations which are classified as insignificant activities under the MPCA’s permitting rules. These are listed in Appendix A to the permit.

5. Permit organization

In general, the permit meets the MPCA Tempo Guidance for ordering and grouping of requirements. One area where this permit deviates slightly from Tempo 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 the Requirements table in Tempo. 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.


6. Comments received

This section is to be completed following the end of the public and EPA notice periods.

7. Permit fee assessment

This permit action is the issuance of an individual Part 70 permit based on an application received 5/27/2016. Even though the Permittee previously held a state operating permit, this action is not considered a reissuance of an individual state or Part 70 operating permit; therefore, the application fees apply under Minn. R. 7002.0019. Attachment 4 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.

8. Conclusion

Based on the information provided by the Permittee, the MPCA has reasonable assurance that the proposed operation of the emission facility, as described in the Air Emission Permit No. 04900001-101 and this TSD, will not cause or contribute to a violation of applicable federal regulations and Minnesota Rules.

Staff members on permit team: Eric Sulita (permit engineer)

Bonnie Nelson (peer reviewer)

Beckie Olson (permit writing assistant)

Laurie O’Brien (administrative support)

Andy Place (compliance)

Dan Dietrich (enforcement)

TEMPO360 Activities: IND20110003, IND20150003

Attachments: 1. PTE summary and emissions increase calculation spreadsheets

2. Requirements development report

3. Subject item inventory/details

4. Points calculator

5. 2012 and 2013 Performance Test Results

6. Consent Decree Control Technology Plan

7. MPCA Supplemental BACT-equivalent Analysis

8. Documentation for Emission Factors for HAP Emissions from Ethanol Loadout

9. Air Products Letter

Attachment 1: Requirements development report

Attachment 2: Subject item inventory/details

Agency Interest Name Subject Item ID Subject Item ..Subject Item DescriptionAl-Corn Clean Fuel ACTV2 Null All AI's

AISI4665 Null Null

COMG2 GP007 Facility Diesel Generators > 500 HP

COMG3 GP008 HAPs Limit Group

COMG4 GP001 Baghouse Monitoring and Maintenance

COMG6 GP006 Fuel Requirements: Dryers, Boiler and thermal oxidizer

COMG7 GP004 Denaturant Tanks subject to Minn. R. 7011.1505

COMG8 GP005 Kb Tanks w/ Liquid Mounted Seal

COMG10 Null Combustion turbine and duct burner

COMG11 Null DDGS Storage and Loadout

COMG12 Null DDGS Storage Silo Baghouses

COMG13 Null Kb Tanks w/ Double-seal System

COMG14 Null Emission sources subject to Minn. R. 7011.0715 (IPER)

COMG15 Null Diesel Generator Oxidation Catalysts

COMG16 Null Flare 2 Ethanol Loadout

EQUI7 EU033 DDGS Loadout (railcar)

EQUI9 EU073 Cook Tube

EQUI10 EU074 Flash Tank

EQUI11 EU078 Liquefaction Tank #3

EQUI12 EU079 Centrifuges

EQUI13 EU080 Flour Transfer

EQUI15 EU082 Receiving Pit Drag Lines

EQUI16 EU083 Return Conveyors

EQUI17 EU084 Plant Conveyors

EQUI18 EU085 Plant Elevator Leg

EQUI19 EU086 Plant Conveyor #2

EQUI22 EU070 DDGS Conveyor

List of SIs

Agency Interest: Al-Corn Clean FuelAgency Interest ID: 4665Activity: IND20110003 (Part 70 Permit)

Details for:SI Category: NoneSI Type: All

Agency Interest Name Subject Item ID Subject Item ..Subject Item DescriptionAl-Corn Clean Fuel

EQUI19 EU086 Plant Conveyor #2

EQUI22 EU070 DDGS Conveyor

EQUI23 EU071 DDGS Loadout Scale

EQUI24 EU072 DDGS Conveyor #2

EQUI25 EU076 Mill Drag Line

EQUI26 EU077 Mill Drag Line #2

EQUI27 EU075 Cook Water Tank

EQUI28 EU046 Office Generator

EQUI29 EU047 Well House Generator

EQUI31 EU038 Fermenter #5



EQUI34 EU052 Cook Water Tank




EQUI38 EU024 Side Stripper #1

EQUI39 EU028 Molecular Sieve #1

EQUI40 EU043 Rectifier #1

EQUI41 EU044 Beer Stripper #1

EQUI42 EU059 Molecular Sieve #2

EQUI43 EU060 Evaporator #2




EQUI47 EU037 DDGS Dryer #2 (SV 012)

EQUI48 EU068 Corn Bin #7

EQUI49 EU069 DDGS Pit Conveyor

List of SIs





EQUI49 EU069 DDGS Pit Conveyor

EQUI50 EU004 Corn Bin #1 - Silo/Bin




EQUI54 EU013 DDGS Dryer #1 (SV012)

EQUI56 EU021 Liquefaction Tank 1

EQUI57 EU022 Liquefaction Tank 2

EQUI58 EU023 Yeast Tanks

EQUI59 EU029 Evaporator #1

EQUI60 EU048 Dryer #1 (Dryer B) Load Generator

EQUI61 EU053 Dryer #2 (Dryer A) Load Generator

EQUI62 EU050 Cooling Tower Generator

EQUI63 EU049 Process Generator


EQUI65 EU041 Hammermill #2


EQUI67 EU014 DDGS Dump Pit

EQUI69 EU015 DDGS Elevator

EQUI70 EU016 DDGS Loadout (truck)

EQUI71 EU018 DDGS Cooling Cyclone - Cooler

EQUI72 EU019 DDGS Storage Building

EQUI73 EU065 Ethanol Loading Rack #2

EQUI74 EU001 Corn Dump Pit #1

EQUI75 EU002 Elevator Legs

EQUI76 EU003 Scalper


List of SIs




EQUI76 EU003 Scalper


EQUI137 T-801 Ethanol / 39000 gal / TK001

EQUI138 T-802 Gasoline, Non-Oxygenated / 39000 gal / TK002





EQUI143 T-868 Fuel additive / 1480 gal / TK007







EQUI173 T-7050 Fuel additive / 3000 gal / TK014


EQUI175 Eu118 Fermenter #8



EQUI178 EU121 Beerwell

EQUI179 EU122 Dump Pit #1



EQUI182 EU125 Pit Conveyor #1



EQUI185 EU128 Receiving Elevator Leg #1

List of SIs







EQUI187 EU130 Receiving Transfer Conveyor #1

EQUI188 EU131 Receiving Transfer Conveyor #2

EQUI189 EU132 Bin Fill Conveyor



EQUI192 EU135 Reclaim Conveyor #1

EQUI193 EU136 Reclaim Conveyor #2

EQUI194 EU137 Hammermill Feed Leg

EQUI195 EU138 Feed Conveyor

EQUI196 EU139 Scalper Surge Bin

EQUI197 EU140 Hammermill Surge Bin

EQUI198 EU141 Scalper #1

EQUI199 EU142 Scalper #2





EQUI204 EU147 Hammermill Collection

EQUI205 EU148 DDGS Bulkweigher



EQUI208 EU151 DDGS Dust Conveyance Cyclone

EQUI209 EU152 DDGS Loadout (truck)


EQUI211 EU154 Emergency Fire Pump Engine

List of SIs





EQUI211 EU154 Emergency Fire Pump Engine



EQUI214 EU157 DDGS Conveyance Aspiration #3

EQUI215 EU158 DDGS Bin #1

EQUI216 EU159 DDGS Cooling Cyclone #1

EQUI217 EU160 DDGS Cooling Cyclone #2

EQUI218 EU161 DDGS Dryer (with Multiclone)

EQUI219 EU162 Fluid Bed Cooler

EQUI221 EU164 Centrifuge Vent Fan

EQUI222 EU165 DDGS Bin #2

EQUI223 EU166 Grain Receiving - Uncaptured emissions

EQUI224 EU167 DDGS Loadout - Uncaptured emissions

EQUI225 EU168 Combustion Turbine

EQUI226 EU169 Duct Burner (HRSG)

EQUI227 EU170 Boiler



EQUI231 EU176 Centrifuges

EQUI232 EU177 Liquefaction Tank

EQUI233 EU178 Slurry Tank

EQUI234 EU174 Multiclone

EQUI235 EU175 Multiclone

EQUI236 EU179 Yeast Prop Tank

EQUI237 EU180 Yeast Prop Tank



List of SIs







EQUI241 EU184 Evaporators #3

EQUI242 EU185 Molecular Sieves #3

EQUI243 Null Corn Dump Pit #1 Uncaptured Emissions

FUGI3 FS002 Truck Traffic on Paved Roads - Paved Road

FUGI4 FS005 Cooling Towers - Cooling Tower

FUGI5 FS004 Valves, Flanges, and Seals (tank leaks) - Equipment Leaks

FUGI7 FS009 Cooling Towers

STRU1 BG001 Offices

STRU2 BG002 Well House

STRU3 BG003 CO2 Plant

STRU4 BG004 Process Building

STRU5 BG005 Boiler #1/Maintenance Shop

STRU6 BG006 Grain Receiving/DDG Storage

STRU7 BG007 Dryers/TO

STRU9 SV021 Grain Receiving Baghouse

STRU10 SV020 Ethanol Loading Rack Flare

STRU11 SV001 Grain Handling Baghouse

STRU12 SV002 Grain Milling Baghouse

STRU14 SV006 DDGS Handling

STRU15 SV008 DDGS Cooling Cyclone

STRU17 SV013 Office Generator

STRU18 SV014 Well House Generator

STRU19 SV015 Dryer Load Generator

STRU21 SV017 Cooling Tower Generator

STRU23 SV019 Flour Transfer Baghouse

List of SIs




STRU21 SV017 Cooling Tower Generator

STRU23 SV019 Flour Transfer Baghouse

STRU24 SV012 TO/HRSG

STRU27 SV003 Fermentation System

STRU29 SV010 Boiler #2

STRU30 SV004 (CE 004 multiple cyclone)

STRU36 SV024 Ethanol Loading Rack Flare #2

STRU37 SV025 Fermentation System Scrubber

STRU38 SV026 Grain Handling Baghouse

STRU39 SV027 Grain Milling Baghouse

STRU40 SV028 DDGS Loadout Baghouse

STRU41 SV029 Emergency Fire Pump

STRU42 SV030 DDGS Conveyance Aspiration #1



STRU45 SV033 DDGS Storage Silo Fill Vent #1

STRU46 SV034 DDGS Cooling Cyclone

STRU47 SV035 Distillation/Dryers/RTO

STRU48 SV036 DDGS Storage Silo Fill Vent #2

STRU49 SV037 CHP Dump Stack (only used in emergency situations)

STRU52 SV040 Combined Turbine/Burner/Boiler Stack

STRU53 SV041 Dryer/RTO Bypass Stack (only used in emergency situations)

STRU54 Null Dryer #2 (Dryer A) Load Generator

STRU55 Null Process Generator

TFAC2 03900028 Al-Corn Clean Fuel

TREA1 CE002 Fabric Filter - Low Temperature, i.e., T<180 Degrees F


TREA3 CE008 Flaring

List of SIs





TREA3 CE008 Flaring


TREA6 CE011 Thermal Oxidizer

TREA10 CE010 Packed-Gas Adsorption Column

TREA11 CE012 Single Cyclone


TREA15 CE029 Ethanol Loading Rack Flare #2

TREA16 CE013 Fermentation System Scrubber

TREA17 CE014 Grain Handling Baghouse

TREA18 CE015 Grain Milling Baghouse

TREA19 CE016 DDGS Loadout Baghouse

TREA20 CE017 DDGS Conveyance Aspiration/Filter #1



TREA23 CE020 DDGS Storage Silo Fill Vent #1

TREA25 CE022 RTO

TREA26 CE023 DDGS Storage Silo Fill Vent #2

TREA27 CE024 Well House Generator Catalyst

TREA28 CE025 Dryer #1 (Dryer B) Generator Catalyst

TREA29 CE026 Cooling Tower Generator Catalyst

TREA30 CE027 Process Generator Catalyst

TREA31 CE028 Dryer #2 (Dryer A) Generator Catalyst

List of SIs



Agency Interest Name Activity ID Subject Item ..Subject Item ..Subject Item ID Subject Item ..Subject Item ..Status Descr..Sub Attribute Description

Al-Corn Clean Fuel IND20110003 Activity Insignificant AirEmissionsActivity

ACTV2 Null All AI's Null Minn. R. 7007.1300, subp. 3(A)

Minn. R. 7007.1300, subp. 3(B)(2)

Minn. R. 7007.1300, subp. 3(E)(2)

Minn. R. 7007.1300, subp. 3(G)

Minn. R. 7007.1300, subp. 3(H)(3)

Minn. R. 7007.1300, subp. 3(H)(7)

Minn. R. 7007.1300, subp. 3(J)

Minn. R. 7007.1300, subp. 3(K)

Insignificant air emissions activity


Details for:SI Category: ActivitySI Type: Insignificant Air Emissions Activity

Agency Interest Name Subject Item ID Subject Item ..Subject Item Description Group Member ID (p..Al-Corn Clean Fuel COMG2 GP007 Facility Diesel Generators > 500 HP EQUI29

EQUI60

EQUI61

EQUI62

EQUI63

COMG3 GP008 HAPs Limit Group EQUI9

EQUI10

EQUI11

EQUI12

EQUI27

EQUI31

EQUI32

EQUI33

EQUI34

EQUI35

EQUI36

EQUI37

EQUI38

EQUI39

EQUI40

EQUI41

EQUI42

EQUI43

EQUI44

EQUI45

EQUI46

EQUI47

Component Group (Members)


Details for:SI Category: Component GroupSI Type: Air Component Group

Agency Interest Name Subject Item ID Subject Item ..Subject Item Description Group Member ID (p..Al-Corn Clean Fuel COMG3 GP008 HAPs Limit Group

EQUI46

EQUI47

EQUI54

EQUI57

EQUI58

EQUI59

EQUI71

EQUI174

EQUI175

EQUI176

EQUI177

EQUI178

EQUI218

EQUI219

EQUI231

EQUI232

EQUI233

EQUI234

EQUI235

EQUI236

EQUI237

EQUI238

EQUI240

EQUI241

EQUI242

STRU15

STRU24

STRU27




Agency Interest Name Subject Item ID Subject Item ..Subject Item Description Group Member ID (p..Al-Corn Clean Fuel COMG3 GP008 HAPs Limit Group

STRU24

STRU27

STRU37

STRU46

STRU47

COMG4 GP001 Baghouse Monitoring and Maintenance TREA1

TREA2

TREA4

TREA12

COMG6 GP006 Fuel Requirements: Dryers, Boiler and thermal oxidizer EQUI47

EQUI54

TREA6

COMG7 GP004 Denaturant Tanks subject to Minn. R. 7011.1505 EQUI138

EQUI141

EQUI142

EQUI170

EQUI171

EQUI172

COMG8 GP005 Kb Tanks w/ Liquid Mounted Seal EQUI138

EQUI142

EQUI170

EQUI171

EQUI172

COMG10 Null Combustion turbine and duct burner EQUI225

EQUI226

COMG11 Null DDGS Storage and Loadout EQUI22

EQUI23

EQUI24




Agency Interest Name Subject Item ID Subject Item ..Subject Item Description Group Member ID (p..Al-Corn Clean Fuel COMG11 Null DDGS Storage and Loadout

EQUI23

EQUI24

EQUI49

EQUI67

EQUI69

EQUI70

EQUI72

COMG12 Null DDGS Storage Silo Baghouses TREA23

TREA26

COMG13 Null Kb Tanks w/ Double-seal System EQUI170

EQUI171

COMG14 Null Emission sources subject to Minn. R. 7011.0715 (IPER) EQUI137

EQUI139

EQUI140

EQUI143

EQUI144

EQUI168

EQUI169

EQUI173

COMG15 Null Diesel Generator Oxidation Catalysts TREA27

TREA28

TREA29

TREA30

TREA31

COMG16 Null Flare 2 Ethanol Loadout EQUI228

EQUI229




Subject ItemCategoryDescription

Subject Item TypeDescription Subject Item ID

Subject ItemDesignation Subject Item Description

Relationship(F/R)

Related Subject ItemID

Related Subject Item TypeDescription

Start Date(Subject ItemRelated)

End Date(Subject ItemRelated)

ConfidentialityFlag

Activity Insignificant Air Emi..ACTV2 Null All AI's Null Null Null Null Null Null

Agency Interest Conventional Site AISI4665 Null Null Null Null Null Null Null Null

ComponentGroup

Air ComponentGroup

COMG2 GP007 Facility Diesel Generators > 5..Null Null Null Null Null Null

COMG3 GP008 HAPs Limit Group Null Null Null Null Null Null

COMG4 GP001 Baghouse Monitoring and Mai..Null Null Null Null Null Null

COMG6 GP006 Fuel Requirements: Dryers, B..Null Null Null Null Null Null

COMG7 GP004 Denaturant Tanks subject to .. Null Null Null Null Null Null

COMG8 GP005 Kb Tanks w/ Liquid Mounted .. Null Null Null Null Null Null

COMG10 Null Combustion turbine and duct ..Null Null Null Null Null Not Confidential

COMG11 Null DDGS Storage and Loadout Null Null Null Null Null Not Confidential

COMG12 Null DDGS Storage Silo BaghousesNull Null Null Null Null Not Confidential

COMG13 Null Kb Tanks w/ Double-seal Syst..Null Null Null Null Null Not Confidential

COMG14 Null Emission sources subject to M..Null Null Null Null Null Not Confidential

COMG15 Null Diesel Generator Oxidation C..Null Null Null Null Null Not Confidential

COMG16 Null Flare 2 Ethanol Loadout Null Null Null Null Null Not Confidential

Equipment AbovegroundStorage Tank

EQUI137 T-801 Ethanol / 39000 gal / TK001 Null Null Null Null Null Not Confidential

EQUI138 T-802 Gasoline, Non-Oxygenated / 3..Null Null Null Null Null Not Confidential





EQUI143 T-868 Fuel additive / 1480 gal / TK0..Null Null Null Null Null Not Confidential







EQUI173 T-7050 Fuel additive / 3000 gal / TK0..Null Null Null Null Null Not Confidential

Boiler EQUI227 EU170 Boiler sends to STRU52 Stack/Vent 10/24/2016 Null Null

Conveyor EQUI182 EU125 Pit Conveyor #1 is controlled ..TREA17 018-Fabric Filter - Low Tem..10/19/2016 Null Null

sends to STRU38 Stack/Vent 10/19/2016 Null Null

EQUI183 EU126 Pit Conveyor #2 is controlled ..TREA17 018-Fabric Filter - Low Tem..10/19/2016 Null Null


is controlled ..TREA17 018-Fabric Filter - Low Tem..10/19/2016 Null Null

SI - SI relationships


Details for:SI Category: AllSI Type: All




Relationship(F/R)





ConfidentialityFlag

Equipment ConveyorEQUI183 EU126 Pit Conveyor #2 sends to STRU38 Stack/Vent 10/19/2016 Null NullEQUI184 EU127 Pit Conveyor #3 is controlled ..TREA17 018-Fabric Filter - Low Tem..10/19/2016 Null Null


EQUI187 EU130 Receiving Transfer Conveyor#1



EQUI188 EU131 Receiving Transfer Conveyor#2



EQUI189 EU132 Bin Fill Conveyor is controlled ..TREA17 018-Fabric Filter - Low Tem..10/19/2016 Null Null


EQUI192 EU135 Reclaim Conveyor #1 is controlled ..TREA18 018-Fabric Filter - Low Tem..10/19/2016 Null Null


EQUI193 EU136 Reclaim Conveyor #2 is controlled ..TREA18 018-Fabric Filter - Low Tem..10/19/2016 Null Null


EQUI195 EU138 Feed Conveyor is controlled ..TREA18 018-Fabric Filter - Low Tem..10/19/2016 Null Null


EQUI206 EU149 DDGS Conveyor #1 is controlled ..TREA19 018-Fabric Filter - Low Tem..10/20/2016 Null Null








EQUI214 EU157 DDGS Conveyance Aspiration#3



Cooler EQUI71 EU018 DDGS Cooling Cyclone - Cool..sends to STRU15 Stack/Vent 11/30/2016 Null Null

EQUI219 EU162 Fluid Bed Cooler is controlled ..TREA25 131-Thermal Oxidizer 10/20/2016 Null Null


STRU53 Stack/Vent 10/20/2016 Null Null

Dehydrator EQUI43 EU060 Evaporator #2 is controlledby

TREA6 131-Thermal Oxidizer 8/1/2006 Null Null

TREA16 050-Packed-Gas Adsorption..10/19/2016 Null Null



EQUI59 EU029 Evaporator #1 is controlledby










Relationship(F/R)





ConfidentialityFlag

Equipment Dehydrator EQUI59 EU029 Evaporator #1

is controlledby TREA16 050-Packed-Gas Adsorption..10/19/2016 Null Nullsends to STRU24 Stack/Vent 12/15/2006 Null Null


Distillation EquipmentEQUI12 EU079 Centrifuges is controlled ..TREA6 131-Thermal Oxidizer 7/1/2007 Null Null



EQUI40 EU043 Rectifier #1 is controlledby





EQUI44 EU061 Rectifier #2 is controlledby





EQUI242 EU185 Molecular Sieves #3 is controlled ..TREA16 050-Packed-Gas Adsorption..10/20/2016 Null Null


Dryer/Oven, directfired

EQUI218 EU161 DDGS Dryer (with Multiclone) is controlled ..TREA25 131-Thermal Oxidizer 10/20/2016 Null Null


Dryer/Oven, unknownfiring method

EQUI47 EU037 DDGS Dryer #2 (SV 012) is controlled ..TREA6 131-Thermal Oxidizer 6/1/2002 Null Null


EQUI54 EU013 DDGS Dryer #1 (SV012) is controlled ..TREA6 131-Thermal Oxidizer 4/29/1996 Null Null


Duct Burner EQUI226 EU169 Duct Burner (HRSG) sends to STRU52 Stack/Vent 10/24/2016 Null Null

Elevator EQUI69 EU015 DDGS Elevator sends to STRU14 Stack/Vent 11/30/2016 Null Null

EQUI75 EU002 Elevator Legs is controlled ..TREA4 018-Fabric Filter - Low Tem..12/15/2006 Null Null


EQUI185 EU128 Receiving Elevator Leg #1 is controlled ..TREA17 018-Fabric Filter - Low Tem..10/19/2016 Null Null


EQUI186 EU129 Receiving Elevator Leg #2 is controlled ..TREA17 018-Fabric Filter - Low Tem..10/19/2016 Null Null


Feeder EQUI194 EU137 Hammermill Feed Leg is controlled ..TREA18 018-Fabric Filter - Low Tem..10/19/2016 Null Null


FermentationEquipment

EQUI9 EU073 Cook Tube is controlled ..TREA6 131-Thermal Oxidizer 7/1/2007 Null Null


EQUI10 EU074 Flash Tank is controlled ..TREA6 131-Thermal Oxidizer 7/1/2002 Null Null








Relationship(F/R)





ConfidentialityFlag

Equipment FermentationEquipment

EQUI10 EU074 Flash Tankis controlled ..TREA6 131-Thermal Oxidizer 7/1/2002 Null Null


EQUI27 EU075 Cook Water Tank is controlled ..TREA6 131-Thermal Oxidizer 7/1/2006 Null Null


EQUI31 EU038 Fermenter #5 is controlledby















EQUI34 EU052 Cook Water Tank is controlledby




















EQUI58 EU023 Yeast Tanks is controlled ..TREA6 131-Thermal Oxidizer 12/15/2006 Null Null


EQUI174 EU117 Fermenter #7 is controlled ..TREA16 050-Packed-Gas Adsorption..10/19/2016 Null Null








Relationship(F/R)





ConfidentialityFlag

Equipment FermentationEquipment

EQUI174 EU117 Fermenter #7is controlled ..TREA16 050-Packed-Gas Adsorption..10/19/2016 Null Null


EQUI175 Eu118 Fermenter #8 is controlled ..TREA16 050-Packed-Gas Adsorption..10/19/2016 Null Null






EQUI178 EU121 Beerwell is controlled ..TREA16 050-Packed-Gas Adsorption..10/19/2016 Null Null


LiquefactionEquipment

EQUI11 EU078 Liquefaction Tank #3 is controlledby





EQUI56 EU021 Liquefaction Tank 1 is controlled ..TREA6 131-Thermal Oxidizer 8/1/2006 Null Null


EQUI57 EU022 Liquefaction Tank 2 is controlledby





Loading-UnloadingEquipment

EQUI7 EU033 DDGS Loadout (railcar) sends to STRU14 Stack/Vent 7/25/1997 Null Null

EQUI70 EU016 DDGS Loadout (truck) sends to STRU14 Stack/Vent 4/29/1996 Null Null

EQUI73 EU065 Ethanol Loading Rack #2 is controlled ..TREA3 099-Other 12/15/2006 Null Null


EQUI179 EU122 Dump Pit #1 is controlled ..TREA17 018-Fabric Filter - Low Tem..10/19/2016 Null Null






EQUI205 EU148 DDGS Bulkweigher is controlled ..TREA19 018-Fabric Filter - Low Tem..10/20/2016 Null Null


EQUI209 EU152 DDGS Loadout (truck) is controlled ..TREA19 018-Fabric Filter - Low Tem..10/20/2016 Null Null


EQUI210 EU153 DDGS Loadout (railcar) is controlled ..TREA19 018-Fabric Filter - Low Tem..10/20/2016 Null Null








Relationship(F/R)





ConfidentialityFlag

Equipment Loading-UnloadingEquipment

EQUI210 EU153 DDGS Loadout (railcar)is controlled ..TREA19 018-Fabric Filter - Low Tem..10/20/2016 Null Null


EQUI223 EU166 Grain Receiving - Uncaptured ..Null Null Null Null Null Null

EQUI224 EU167 DDGS Loadout - Uncaptured ..Null Null Null Null Null Null

EQUI228 EU171 Ethanol Loading Rack #3 is controlled ..TREA15 023-Flaring 10/24/2016 Null Null


EQUI229 EU172 Ethanol Loading Rack #4 is controlled ..TREA15 023-Flaring 10/24/2016 Null Null


EQUI243 Null Corn Dump Pit #1 Uncaptured..Null Null Null Null Null Not Confidential

Material HandlingEquipment

EQUI13 EU080 Flour Transfer is controlled ..TREA2 018-Fabric Filter - Low Tem..7/1/2002 Null Null


EQUI15 EU082 Receiving Pit Drag Lines is controlled ..TREA4 018-Fabric Filter - Low Tem..7/1/2011 Null Null


EQUI16 EU083 Return Conveyors is controlled ..TREA4 018-Fabric Filter - Low Tem..7/1/2007 Null Null


EQUI17 EU084 Plant Conveyors is controlled ..TREA4 018-Fabric Filter - Low Tem..7/1/2002 Null Null


EQUI18 EU085 Plant Elevator Leg is controlled ..TREA4 018-Fabric Filter - Low Tem..7/1/2002 Null Null


EQUI19 EU086 Plant Conveyor #2 is controlled ..TREA4 018-Fabric Filter - Low Tem..7/1/2002 Null Null


EQUI22 EU070 DDGS Conveyor sends to STRU14 Stack/Vent 7/1/2002 Null Null

EQUI23 EU071 DDGS Loadout Scale sends to STRU14 Stack/Vent 1/1/2002 Null Null

EQUI24 EU072 DDGS Conveyor #2 sends to STRU14 Stack/Vent 1/1/2002 Null Null

EQUI25 EU076 Mill Drag Line is controlled ..TREA1 018-Fabric Filter - Low Tem..7/1/2002 Null Null


EQUI26 EU077 Mill Drag Line #2 is controlled ..TREA1 018-Fabric Filter - Low Tem..7/1/2002 Null Null


EQUI49 EU069 DDGS Pit Conveyor sends to STRU14 Stack/Vent 7/1/1996 Null Null

EQUI67 EU014 DDGS Dump Pit sends to STRU14 Stack/Vent 1/1/2002 Null Null

EQUI72 EU019 DDGS Storage Building sends to STRU14 Stack/Vent 1/1/2002 Null Null

EQUI74 EU001 Corn Dump Pit #1 is controlled ..TREA4 018-Fabric Filter - Low Tem..12/15/2006 Null Null


Milling Equipment EQUI65 EU041 Hammermill #2 is controlled ..TREA1 018-Fabric Filter - Low Tem..6/1/2001 Null Null









Relationship(F/R)





ConfidentialityFlag

Equipment Milling EquipmentEQUI65 EU041 Hammermill #2 sends to STRU12 Stack/Vent 6/1/2001 Null NullEQUI66 EU055 Hammermill #3 is controlled ..TREA1 018-Fabric Filter - Low Tem..12/15/2006 Null Null


EQUI77 EU008 Hammermill #1 is controlled ..TREA1 018-Fabric Filter - Low Tem..1/1/2001 Null Null










EQUI204 EU147 Hammermill Collection is controlled ..TREA18 018-Fabric Filter - Low Tem..10/19/2016 Null Null


Other Emission Unit EQUI76 EU003 Scalper is controlled ..TREA12 018-Fabric Filter - Low Tem..6/1/2002 Null Null


Reciprocating ICEngine

EQUI28 EU046 Office Generator sends to STRU17 Stack/Vent 7/1/2000 Null Null

EQUI29 EU047 Well House Generator is controlled ..TREA27 109-Catalytic Oxidizer 10/24/2016 Null Null


EQUI60 EU048 Dryer #1 (Dryer B) LoadGenerator

is controlled ..TREA28 109-Catalytic Oxidizer 10/24/2016 Null Null


EQUI61 EU053 Dryer #2 (Dryer A) LoadGenerator

is controlled ..TREA30 109-Catalytic Oxidizer 10/24/2016 Null Null


EQUI62 EU050 Cooling Tower Generator is controlled ..TREA29 109-Catalytic Oxidizer 10/24/2016 Null Null


EQUI63 EU049 Process Generator is controlled ..TREA31 109-Catalytic Oxidizer 10/18/2016 Null Null


EQUI211 EU154 Emergency Fire Pump Engine sends to STRU41 Stack/Vent 10/24/2016 Null Null

Refining Equipment EQUI240 EU183 Rectifier #3 is controlled ..TREA16 050-Packed-Gas Adsorption..10/20/2016 Null Null


SeparationEquipment

EQUI39 EU028 Molecular Sieve #1 is controlledby












Relationship(F/R)





ConfidentialityFlag

Equipment SeparationEquipment

EQUI39 EU028 Molecular Sieve #1 sends to STRU37 Stack/Vent 10/20/2016 Null NullEQUI42 EU059 Molecular Sieve #2 is controlled

byTREA6 131-Thermal Oxidizer 8/1/2006 Null Null




EQUI198 EU141 Scalper #1 is controlled ..TREA18 018-Fabric Filter - Low Tem..10/19/2016 Null Null


EQUI199 EU142 Scalper #2 is controlled ..TREA18 018-Fabric Filter - Low Tem..10/19/2016 Null Null


EQUI208 EU151 DDGS Dust ConveyanceCyclone



EQUI216 EU159 DDGS Cooling Cyclone #1 sends to STRU46 Stack/Vent 10/20/2016 Null Null

EQUI217 EU160 DDGS Cooling Cyclone #2 sends to STRU46 Stack/Vent 10/20/2016 Null Null

EQUI221 EU164 Centrifuge Vent Fan Null Null Null Null Null Null

EQUI231 EU176 Centrifuges is controlled ..TREA25 131-Thermal Oxidizer 10/20/2016 Null Null


EQUI234 EU174 Multiclone is controlled ..TREA6 131-Thermal Oxidizer 10/20/2016 Null Null


EQUI235 EU175 Multiclone is controlled ..TREA6 131-Thermal Oxidizer 10/20/2016 Null Null


Silo/Bin EQUI48 EU068 Corn Bin #7 is controlled ..TREA12 018-Fabric Filter - Low Tem..1/1/2013 Null Null


EQUI50 EU004 Corn Bin #1 - Silo/Bin is controlled ..TREA12 018-Fabric Filter - Low Tem..4/29/1996 Null Null










EQUI190 EU133 Corn Bin #1 is controlled ..TREA17 018-Fabric Filter - Low Tem..10/19/2016 Null Null


EQUI191 EU134 Corn Bin #2 is controlled ..TREA17 018-Fabric Filter - Low Tem..10/19/2016 Null Null








Relationship(F/R)





ConfidentialityFlag

Equipment Silo/Bin EQUI191 EU134 Corn Bin #2is controlled ..TREA17 018-Fabric Filter - Low Tem..10/19/2016 Null Null


EQUI196 EU139 Scalper Surge Bin is controlled ..TREA18 018-Fabric Filter - Low Tem..10/19/2016 Null Null


EQUI197 EU140 Hammermill Surge Bin is controlled ..TREA18 018-Fabric Filter - Low Tem..10/19/2016 Null Null


EQUI215 EU158 DDGS Bin #1 is controlled ..TREA23 018-Fabric Filter - Low Tem..10/20/2016 Null Null


EQUI222 EU165 DDGS Bin #2 is controlled ..TREA26 018-Fabric Filter - Low Tem..10/20/2016 Null Null


EQUI232 EU177 Liquefaction Tank is controlled ..TREA16 050-Packed-Gas Adsorption..10/19/2016 Null Null


EQUI233 EU178 Slurry Tank is controlled ..TREA16 050-Packed-Gas Adsorption..10/19/2016 Null Null


EQUI236 EU179 Yeast Prop Tank is controlled ..TREA16 050-Packed-Gas Adsorption..10/19/2016 Null Null


EQUI237 EU180 Yeast Prop Tank is controlled ..TREA16 050-Packed-Gas Adsorption..10/19/2016 Null Null


EQUI241 EU184 Evaporators #3 is controlled ..TREA16 050-Packed-Gas Adsorption..10/20/2016 Null Null


Stripping Equipment EQUI38 EU024 Side Stripper #1 is controlledby





EQUI41 EU044 Beer Stripper #1 is controlledby





EQUI45 EU062 Beer Stripper #2 is controlledby





EQUI46 EU066 Side Stripper #2 is controlledby











Relationship(F/R)





ConfidentialityFlag

Equipment Stripping Equipment EQUI46 EU066 Side Stripper #2 sends toSTRU24 Stack/Vent 8/1/2006 Null Null


EQUI238 EU181 Beer Stripper #3 is controlled ..TREA16 050-Packed-Gas Adsorption..10/20/2016 Null Null


EQUI239 EU182 Side Stripper #3 is controlled ..TREA16 050-Packed-Gas Adsorption..11/15/2016 Null Null


Turbine EQUI225 EU168 Combustion Turbine sends to STRU49 Stack/Vent 10/24/2016 Null Null


Fugitive Cooling Tower FUGI4 FS005 Cooling Towers - Cooling Tow..Null Null Null Null Null Null

FUGI7 FS009 Cooling Towers Null Null Null Null Null Null

Equipment Leaks FUGI5 FS004 Valves, Flanges, and Seals (t..Null Null Null Null Null Null

Paved Road FUGI3 FS002 Truck Traffic on Paved Roads ..Null Null Null Null Null Null

Structure Building STRU1 BG001 Offices Null Null Null Null Null Null

STRU2 BG002 Well House Null Null Null Null Null Null

STRU3 BG003 CO2 Plant Null Null Null Null Null Null

STRU4 BG004 Process Building Null Null Null Null Null Null

STRU5 BG005 Boiler #1/Maintenance Shop Null Null Null Null Null Null

STRU6 BG006 Grain Receiving/DDG Storage Null Null Null Null Null Null

STRU7 BG007 Dryers/TO Null Null Null Null Null Null

Stack/Vent STRU9 SV021 Grain Receiving Baghouse Null Null Null Null Null Null

STRU10 SV020 Ethanol Loading Rack Flare Null Null Null Null Null Null

STRU11 SV001 Grain Handling Baghouse Null Null Null Null Null Null

STRU12 SV002 Grain Milling Baghouse Null Null Null Null Null Null

STRU14 SV006 DDGS Handling Null Null Null Null Null Null

STRU15 SV008 DDGS Cooling Cyclone Null Null Null Null Null Null

STRU17 SV013 Office Generator Null Null Null Null Null Null

STRU18 SV014 Well House Generator Null Null Null Null Null Null

STRU19 SV015 Dryer Load Generator Null Null Null Null Null Null

STRU21 SV017 Cooling Tower Generator Null Null Null Null Null Null

STRU23 SV019 Flour Transfer Baghouse Null Null Null Null Null Null

STRU24 SV012 TO/HRSG Null Null Null Null Null Null

STRU27 SV003 Fermentation System Null Null Null Null Null Null

STRU29 SV010 Boiler #2 Null Null Null Null Null Null

STRU30 SV004 (CE 004 multiple cyclone) Null Null Null Null Null Null

STRU36 SV024 Ethanol Loading Rack Flare #2 Null Null Null Null Null Not Confidential

STRU37 SV025 Fermentation System ScrubberNull Null Null Null Null Not Confidential







Relationship(F/R)





ConfidentialityFlag

Structure Stack/VentSTRU36 SV024 Ethanol Loading Rack Flare #2 Null Null Null Null Null Not Confidential

STRU37 SV025 Fermentation System ScrubberNull Null Null Null Null Not Confidential

STRU38 SV026 Grain Handling Baghouse Null Null Null Null Null Not Confidential

STRU39 SV027 Grain Milling Baghouse Null Null Null Null Null Not Confidential

STRU40 SV028 DDGS Loadout Baghouse Null Null Null Null Null Not Confidential

STRU41 SV029 Emergency Fire Pump Null Null Null Null Null Not Confidential

STRU42 SV030 DDGS Conveyance Aspiration..Null Null Null Null Null Not Confidential



STRU45 SV033 DDGS Storage Silo Fill Vent #1Null Null Null Null Null Not Confidential

STRU46 SV034 DDGS Cooling Cyclone Null Null Null Null Null Not Confidential

STRU47 SV035 Distillation/Dryers/RTO Null Null Null Null Null Not Confidential

STRU48 SV036 DDGS Storage Silo Fill Vent #2Null Null Null Null Null Not Confidential

STRU49 SV037 CHP Dump Stack (only used i..Null Null Null Null Null Not Confidential

STRU52 SV040 Combined Turbine/Burner/Boil..Null Null Null Null Null Not Confidential

STRU53 SV041 Dryer/RTO Bypass Stack (onl..Null Null Null Null Null Not Confidential

STRU54 Null Dryer #2 (Dryer A) Load Gene..Null Null Null Null Null Not Confidential

STRU55 Null Process Generator Null Null Null Null Null Not Confidential

Total Facility Air Quality Total Fac..TFAC2 03900028 Al-Corn Clean Fuel Null Null Null Null Null Null

Treatment 018-Fabric Filter -Low Temp, T<180Degrees F

TREA1 CE002 Fabric Filter - Low Temperatur..Null Null Null Null Null Null




TREA17 CE014 Grain Handling Baghouse Null Null Null Null Null Not Confidential

TREA18 CE015 Grain Milling Baghouse Null Null Null Null Null Not Confidential

TREA19 CE016 DDGS Loadout Baghouse Null Null Null Null Null Not Confidential

TREA20 CE017 DDGS Conveyance Aspiration..Null Null Null Null Null Not Confidential



TREA23 CE020 DDGS Storage Silo Fill Vent #1Null Null Null Null Null Not Confidential

TREA26 CE023 DDGS Storage Silo Fill Vent #2Null Null Null Null Null Not Confidential

023-Flaring TREA15 CE029 Ethanol Loading Rack Flare #2 Null Null Null Null Null Not Confidential

050-Packed-GasAdsorption Column

TREA10 CE010 Packed-Gas Adsorption Colu.. Null Null Null Null Null Null

TREA16 CE013 Fermentation System ScrubberNull Null Null Null Null Not Confidential

075-Single Cyclone TREA11 CE012 Single Cyclone Null Null Null Null Null Null

099-Other TREA3 CE008 Flaring Null Null Null Null Null Null







Relationship(F/R)





ConfidentialityFlag

Treatment075-Single Cyclone TREA11 CE012 Single Cyclone Null Null Null Null Null Null

099-Other TREA3 CE008 Flaring Null Null Null Null Null Null

109-CatalyticOxidizer

TREA27 CE024 Well House Generator CatalystNull Null Null Null Null Null

TREA28 CE025 Dryer #1 (Dryer B) Generator ..Null Null Null Null Null Null

TREA29 CE026 Cooling Tower Generator Cat..Null Null Null Null Null Null

TREA30 CE027 Process Generator Catalyst Null Null Null Null Null Null

TREA31 CE028 Dryer #2 (Dryer A) Generator ..Null Null Null Null Null Null

131-Thermal OxidizerTREA6 CE011 Thermal Oxidizer Null Null Null Null Null Null

TREA25 CE022 RTO Null Null Null Null Null Not Confidential




Subject ItemTypeDescription Subject Item ID

Subject Item Designation

Capacity(gal) AST Substance Stored

ColumnDiameter(ft)

ColumnCount Deck Type

InteriorDiameter(ft)

InteriorHeight(ft)

MaximumTrueVaporPressure(psia) Construction Type Seal Type Support Type

ConfidentialityFlag

AbovegroundStorage Tank

EQUI137 T-801 39000 Ethanol (Ethyl Alcohol) Null Null Null 16 26 1.17 Fixed Roof Null Null Not Confidential

EQUI138 T-802 39000 Gasoline, Non-Oxygen..Null Null Bolted, details not specified 26 10 3.68 Internal Floating Roof Resilient; liquid mounted prim..Column, construction type not ..Not Confidential

EQUI139 T-803 120000 Ethanol (Ethyl Alcohol) Null Null Bolted, details not specified 28 26 1.26 Internal Floating Roof Resilient; liquid mounted prim..Column, construction type not ..Not Confidential

EQUI140 T-804 120000 Ethanol (Ethyl Alcohol) Null 1 Bolted, details not specified 28 26 1.26 Internal Floating Roof Resilient; liquid mounted prim..Column, construction type not ..Not Confidential

EQUI141 T-805 18000 Gasoline, Non-Oxygen..Null Null Null 12 21 Null Fixed Roof Null Null Not Confidential

EQUI142 T-810 995000 Ethanol (Ethyl Alcohol) Null 1 Bolted, details not specified 71 32 Null Internal Floating Roof Resilient; liquid mounted prim..Column, construction type not ..Not Confidential

EQUI143 T-868 1480 Fuel Additive Null Null Null 6 7 4.43 Null Null Null Not Confidential

EQUI144 T-806 120000 Ethanol (Ethyl Alcohol) Null Null Bolted, details not specified 0 0 1.26 Internal Floating Roof Resilient; liquid mounted prim..Column, construction type not ..Not Confidential

EQUI168 T-7001 300000 Ethanol (Ethyl Alcohol) Null 1 Bolted, 5 ft wide cont. sheet c..36 40 1.13 Internal Floating Roof Resilient; vapor mount w/ rim ..Column, construction type not ..Not Confidential

EQUI169 T-7002 300000 Ethanol (Ethyl Alcohol) Null 1 Bolted, 5 ft wide cont. sheet c..36 40 1.13 Internal Floating Roof Resilient; vapor mount w/ rim ..Column, construction type not ..Not Confidential

EQUI170 T-7003 2000000 Ethanol (Ethyl Alcohol) Null 1 Bolted, 5 ft wide cont. sheet c..85 47 1.13 Internal Floating Roof Mechanical; w/ rim mounted s..Column, construction type not ..Not Confidential

EQUI171 T-7004 2000000 Ethanol (Ethyl Alcohol) Null 1 Welded 85 47 1.13 Internal Floating Roof Mechanical; w/ rim mounted s..Column, construction type not ..Not Confidential

EQUI172 T-7250 100000 Gasoline, Non-Oxygen..Null 1 Bolted, 5 ft wide cont. sheet c..21 40 Null Internal Floating Roof Resilient; vapor mount w/ rim ..Column, construction type not ..Not Confidential

EQUI173 T-7050 3000 Fuel Additive Null Null Null 6 14 4.43 Fixed Roof Null Null Not Confidential

Aboveground Storage Tanks, General


Details for:SI Category: EquipmentSI Type: Aboveground Storage Tank


Subject ItemDesignation Manufacturer Model

Max DesignCapacity

Max DesignCapacityUnits(numerator)

Max DesignCapacityUnits(denominator)Material

ConstructionStart Date

OperationStart Date

Modification Date

ConfidentialityFlag

Conveyor EQUI182 EU125 Null Null Null Null Null Null Null Null Null Null

EQUI183 EU126 Null Null Null Null Null Null Null Null Null Null













Cooler EQUI71 EU018 Thompson Dehydrationcustom 24000 cubic feet minutes Airflow 5/2/1995 1/1/2007 Null Null

EQUI219 EU162 Null Null 50.23 tons hours Distillers Dried Grains With So..Null Null Null Null

Dehydrator EQUI43 EU060 A&B Process Systems custom 900 gallons minutes Material 8/1/2006 8/1/2006 Null Null

EQUI59 EU029 Senior Engineering custom 900 gallons minutes Material 5/2/1995 4/1/1996 Null Null

DistillationEquipment

EQUI12 EU079 Alfa-Laval CHNX-944B, NX944HS 900 gallons minutes Material 7/1/2007 7/1/2007 Null Null

EQUI40 EU043 Arrow custom 400 gallons minutes Ethanol 5/2/1995 6/1/1995 Null Null

EQUI44 EU061 Westmor custom 700 gallons minutes Ethanol 8/1/2006 8/1/2006 Null Null

EQUI242 EU185 Null Null 250 gallons minutes Ethanol Null Null Null Null

Elevator EQUI69 EU015 Schlagel custom 5000 bushels hours Unknown 5/2/1995 1/1/2002 Null Null

EQUI75 EU002 Schlagel custom 22500 bushels hours Grain 5/2/1995 4/1/1996 Null Null



Feeder EQUI194 EU137 Null Null Null Null Null Null Null Null Null Null


EQUI9 EU073 Judson Tank Co Serial 075 6300 gallons unknown Water 7/1/2007 7/1/2007 Null Null

EQUI10 EU074 Westmore custom 2300 gallons unknown Water 7/1/2002 7/1/2002 Null Null

EQUI27 EU075 Wimbco custom 300000 gallons unknown Water 7/1/2006 7/1/2006 Null Null

EQUI31 EU038 Wimbco custom 535000 gallons unknown Unknown 5/2/2001 6/1/2001 Null Null






EQUI37 EU067 BMT custom 535000 gallons unknown Unknown 1/1/2011 1/1/2011 Null Null

EQUI58 EU023 MDF Millerberndt custom 20000 gallons unknown Unknown 5/2/1995 4/1/1996 Null Null

EQUI174 EU117 TBD TBD Null Null Null Null Null Null Null Null

Emission Units 1


Details for:SI Category: EquipmentSI Type: Conveyor, Cooler, Dehydrator and 14 more



Max DesignCapacity




OperationStart Date

Modification Date

ConfidentialityFlag


EQUI58 EU023 MDF Millerberndt custom 20000 gallons unknown Unknown 5/2/1995 4/1/1996 Null Null

EQUI174 EU117 TBD TBD Null Null Null Null Null Null Null Null

EQUI175 Eu118 Null Null Null Null Null Null Null Null Null Null




LiquefactionEquipment

EQUI11 EU078 Westmore custom 42296 gallons unknown Water 7/1/2002 7/1/2002 Null Null


EQUI57 EU022 Westmore custom 40296 gallons unknown Unknown 5/2/1995 1/1/2002 Null Null

Loading-UnloadingEquipment

EQUI7 EU033 custom custom 100 tons hours Distillers Dried Grains With So..5/2/1995 4/1/1996 Null Null

EQUI70 EU016 custom custom 100 tons hours Distillers Dried Grains With So..5/2/1995 4/1/1996 Null Null

EQUI73 EU065 MRW custom 1000 gallons minutes Unknown 8/1/2006 8/1/2006 Null Null


EQUI180 EU123 Null Null 950 bushels each Grain Null Null Null Null

EQUI181 EU124 Null Null 950 bushels each Grain Null Null Null Null








EQUI243 Null Custom Custom 500 bushels each Grain 1/1/1995 1/1/1996 Null Not Confidential

Material HandlingEquipment

EQUI13 EU080 Gardner Denver 11CDL 2200 cubic feet minutes Airflow 7/1/2002 7/1/2002 Null Null

EQUI15 EU082 RSI custom 22500 bushels hours Grain 7/1/2011 7/1/2011 Null Null

EQUI16 EU083 GSI custom 12000 bushels hours Grain 7/1/2007 7/1/2007 Null Null

EQUI17 EU084 Schlagel 810 powerflow 2500 bushels hours Grain 7/1/2002 7/1/2002 Null Null

EQUI18 EU085 Schlagel custom 2500 bushels hours Grain 7/1/2002 7/1/2002 Null Null

EQUI19 EU086 Schlagel/Tramco 810 powerflow/G18X16 2500 bushels hours Grain 7/1/2002 7/1/2002 Null Null

EQUI22 EU070 Schlagel custom 100 tons hours Distillers Dried Grains With So..7/1/2002 7/1/2002 Null Null



EQUI25 EU076 custom custom 2500 bushels hours Grain 7/1/2002 7/1/2002 Null Null

EQUI26 EU077 custom custom 2500 bushels hours Grain 7/1/2002 7/1/2002 Null Null


EQUI67 EU014 custom custom 5000 bushels hours Unknown 5/2/1995 4/1/1996 Null Null

EQUI72 EU019 custom custom Null Null Null Null 5/2/1995 6/1/1995 Null Null

EQUI74 EU001 custom custom 500 bushels unknown Grain 5/2/1995 4/1/1996 Null Null

Milling Equipment EQUI65 EU041 Bliss E-3824-TFA 21.6 tons hours Unknown 5/2/1997 6/1/1997 Null Null

EQUI66 EU055 Bliss E-3824-TF 14.8 tons hours Unknown 8/1/2006 8/1/2006 Null Null

Emission Units 1





Max DesignCapacity




OperationStart Date

Modification Date

ConfidentialityFlag

Milling EquipmentEQUI65 EU041 Bliss E-3824-TFA 21.6 tons hours Unknown 5/2/1997 6/1/1997 Null Null

EQUI66 EU055 Bliss E-3824-TF 14.8 tons hours Unknown 8/1/2006 8/1/2006 Null Null

EQUI77 EU008 Bliss E-3824-TF 26000 pounds hours Unknown 5/2/1995 1/1/2001 Null Null






Other Emission Unit EQUI76 EU003 Law-Margot C4805 7500 bushels hours Unknown 5/2/1995 6/1/2002 Null Null

Refining Equipment EQUI240 EU183 Null Null 1300 gallons minutes Ethanol Null Null Null Null

SeparationEquipment

EQUI39 EU028 Nova custom 50 gallons minutes Ethanol 5/2/1995 4/1/1996 Null Null

EQUI42 EU059 ICM custom 150 gallons minutes Ethanol 8/1/2006 8/1/2006 Null Null







EQUI231 EU176 Null Null 1760 gallons minutes Material Null Null Null Null



Silo/Bin EQUI48 EU068 Null Null 240000 bushels unknown Grain 12/1/2012 1/1/2013 Null Null

EQUI50 EU004 GSI custom 12000 bushels unknown Grain 5/2/1995 4/1/1996 Null Null











EQUI232 EU177 Null Null 100000 gallons each Beer Null Null Null Null

EQUI233 EU178 Null Null 50000 gallons each Water Null Null Null Null



EQUI241 EU184 Null Null 900 gallons minutes Ethanol Null Null Null Null

Stripping Equipment EQUI38 EU024 custom custom 400 gallons minutes Ethanol 5/2/1995 4/1/1996 Null Null


Emission Units 1





Max DesignCapacity




OperationStart Date

Modification Date

ConfidentialityFlag

Stripping EquipmentEQUI38 EU024 custom custom 400 gallons minutes Ethanol 5/2/1995 4/1/1996 Null Null


EQUI45 EU062 Westmor custom 700 gallons minutes Unknown 8/1/2006 8/1/2006 Null Null

EQUI46 EU066 Westmor Null 700 gallons minutes Ethanol 8/1/2006 8/1/2006 Null Null

EQUI238 EU181 Null Null 1300 gallons minutes Beer Null Null Null Null

EQUI239 EU182 Null Null 1300 gallons minutes Beer Null Null Null Null

Turbine EQUI225 EU168 Null Null 72 1000 British t..hours Heat Null Null Null Null

Emission Units 1





Max DesignCapacity

Max Design Capacity Units(numerator)



OperationStart Date

ModificationDate

Confidentiality Flag

Boiler EQUI227 EU170 Null Null 99 1000 British thermal units hours Heat Null Null Null Null

Dryer/Oven, direct fired EQUI218 EU161 Null Null 99 1000 British thermal units hours Heat Null Null Null Null


EQUI47 EU037 ICM custom 45 million British thermal units hours Heat 5/2/2002 6/1/2002 Null Null

EQUI54 EU013 Thompson Dehydrating custom 42 million British thermal units hours Heat 5/2/1995 4/1/1996 Null Null

Duct Burner EQUI226 EU169 Null Null 106 1000 British thermal units hours Heat Null Null Null Null

Reciprocating IC Engine EQUI28 EU046 Katolight N25FDG4 25 kilowatts unknown Energy 7/1/2000 7/1/2000 Null Null

EQUI29 EU047 Katolight/Volvo D350FRV4 350 kilowatts unknown Energy 7/1/2001 7/1/2001 Null Null

EQUI60 EU048 Katolight/Volvo D1300FRY4 1300 kilowatts unknown Energy 7/1/2001 7/1/2001 Null Null

EQUI61 EU053 Katolight/ Volvo D1300FRY4 1300 kilowatts unknown Energy 7/1/2000 7/1/2000 Null Null

EQUI62 EU050 Katolight/Cummins D2000FRY4 2000 kilowatts unknown Energy 7/1/2001 7/1/2001 Null Null

EQUI63 EU049 Katolight D1300FRY4 1300 kilowatts unknown Energy 7/1/2001 7/1/2001 Null Null

EQUI211 EU154 Null Null 600 brake horsepower hours Energy Null Null Null Null

Emission Units 2


Details for:SI Category: EquipmentSI Type: Boiler, Dryer/Oven, direct fired, Dryer/Oven, unknown firing method and 2 more


Subject ItemDesignation Firing MethodEngine Use

EngineDisplacement

EngineDisplacementUnits

Subject toCSAPR?

ElectricGeneratingCapacity(MW)


Boiler EQUI227 EU170 Null Null Null Null N Null Null

Dryer/Oven, direct fired EQUI218 EU161 Null Null Null Null Null Null Null


EQUI47 EU037 Null Null Null Null Null Null Null

EQUI54 EU013 Null Null Null Null Null Null Null

Duct Burner EQUI226 EU169 Null Null Null Null N Null Null

Reciprocating IC Engine EQUI28 EU046 Null Unlimited use Null Null Null Null Null

EQUI29 EU047 Null Unlimited use Null Null Null Null Null

EQUI60 EU048 CI Unlimited use Null Null Null Null Null




EQUI211 EU154 CI Emergency/blackstart Null Null Null Null Null

Emission Units 2 (continued)


Details for:SI Category: EquipmentSI Type: Boiler, Dryer/Oven, direct fired, Dryer/Oven, unknown firing method and 2 more


Subject Item Designation Install Year Pollutants Emitted


CoolingTower

FUGI4 FS005 Null Particulate Matter Null

PM < 2.5 micron Null

PM < 10 micron Null

Volatile Organic Compounds Null

FUGI7 FS009 Null Null Null

EquipmentLeaks

FUGI5 FS004 Null Acetaldehyde Null

Benzene Null

Carbon disulfide Null

Cumene (Isopropylbenzene) Null

Ethylbenzene Null

HAPs - Total Null

Hexane Null

Methanol Null

Toluene Null

Volatile Organic Compounds Null

Paved Road FUGI3 FS002 Null Particulate Matter Null

PM < 2.5 micron Null

PM < 10 micron Null

Fugitive Sources


Details for:SI Category: FugitiveSI Type: Cooling Tower, Equipment Leaks, Paved Road


Subject Item Designation Height Units (height)Length Units (length)Width Units (width)


Building STRU1 BG001 Null Null 83 feet 36 feet Null

STRU2 BG002 Null Null 50 feet 43 feet Null






Buildings, General


Details for:SI Category: StructureSI Type: Building



Stack Height(feet)

StackDiameter(feet)

Stack Length(feet)

Stack Width(feet)

Stack FlowRate (cubicft/min)

DischargeTemp (°F)

Info SourceDesc Discharge Direction

ConfidentialityFlag

Stack/Vent STRU9 SV021 7 1.75 Null Null 6750 70 Manufacturer Upwards with no cap on stack/vent Null

STRU10 SV020 Null Null Null Null Null Null Manufacturer Upwards with no cap on stack/vent Null

STRU11 SV001 7 1.75 Null Null 13500 68 Manufacturer Upwards with a cap on stack/vent Null

STRU12 SV002 12 1 Null Null 3000 68 Manufacturer Upwards with a cap on stack/vent Null

STRU14 SV006 30 3 Null Null 21000 68 Manufacturer Horizontally Null

STRU15 SV008 60 1.5 Null Null 22000 90 Manufacturer Upwards with no cap on stack/vent Null

STRU17 SV013 5.58 0.17 Null Null 220 1220 Manufacturer Upwards with no cap on stack/vent Null





STRU24 SV012 175 5 Null Null 40500 210 Test data Upwards with no cap on stack/vent Null

STRU27 SV003 67.5 1 Null Null 3288.35 80 Estimate Horizontally Null

STRU29 SV010 33.5 2 Null Null 22512 410 Estimate Upwards with no cap on stack/vent Null

STRU30 SV004 60 2.8 Null Null 20234 210 Estimate Upwards with no cap on stack/vent Null

STRU36 SV024 32 4.99 Null Null 8040 799.97 Manufacturer Upwards with no cap on stack/vent Not Confidential

STRU37 SV025 70 1.99 Null Null 8188 68.99 Manufacturer Upwards with no cap on stack/vent Not Confidential

STRU38 SV026 140 3.99 Null Null 48853 70 Manufacturer Upwards with no cap on stack/vent Not Confidential


STRU40 SV028 140 2 Null Null 5556 70 Manufacturer Upwards with no cap on stack/vent Not Confidential

STRU41 SV029 30 0.87 Null Null 3500 800 Estimate Upwards with no cap on stack/vent Not Confidential






STRU47 SV035 160 5 Null Null 110110 300 Manufacturer Upwards with no cap on stack/vent Not Confidential



STRU52 SV040 170 8 Null Null 35000 296 Estimate Upwards with no cap on stack/vent Not Confidential

STRU53 SV041 50 5 Null Null 110110 300 Estimate Upwards with no cap on stack/vent Not Confidential

STRU54 Null 56 1.7 Null Null 15548 824 Estimate Upwards with no cap on stack/vent Not Confidential

Stack/Vent, General


Details for:SI Category: StructureSI Type: Stack/Vent



Stack Height(feet)

StackDiameter(feet)

Stack Length(feet)

Stack Width(feet)

Stack FlowRate (cubicft/min)

DischargeTemp (°F)

Info SourceDesc Discharge Direction

ConfidentialityFlag

Stack/VentSTRU53 SV041 50 5 Null Null 110110 300 Estimate Upwards with no cap on stack/vent Not Confidential



Stack/Vent, General


Details for:SI Category: StructureSI Type: Stack/Vent


Subject Item Designation Manufacturer Model

Install StartDate

Pollutant Controlled(treatment)

CaptureEfficiency (%)

Destruction/CollectionEfficiency (%)

Subject toCAM? Large PSEU?

EfficiencyBasis

ScrubberMinimumPressureDrop (in. ofwater column)

ScrubberMaximumPressureDrop (in. ofwater column)

ScrubberMinimumLiquid FlowRate(gal./min)

ConfidentialityFlag

050-Packed-GasAdsorptionColumn

TREA10 CE010 Thermal Kinetics serial no.508-6

Null Acetaldehyde 100 90 Y N Other 2 10 44.5 Null

Acrolein 100 32.5 N Null Other 2 10 44.5 Null

Formaldehyde 100 90 N Null Other 2 10 44.5 Null

Methanol 100 95 N Null Other 2 10 44.5 Null

Volatile Organic Compounds 100 95 Y N Other 2 10 44.5 Null

TREA16 CE013 TBD TBD Null HAPs - Total 100 95 Null Null Null Null Null Null Not Confidential

Volatile Organic Compounds 100 95 Null Null Null Null Null Null Not Confidential

Scrubbers, General


Details for:SI Category: TreatmentSI Type: 050-Packed-Gas Adsorption Column



Install StartDate





EfficiencyBasis

Other operating parameters?

Other operatingparametersdescription

ConfidentialityFlag

023-Flaring TREA15 CE029 TBD TBD Null Volatile Organic Compounds 100 95 Null Null Null N Null Not Confidential

099-Other TREA3 CE008 MMT Env Sigma 15..Null Volatile Organic Compounds 100 95 N Null Other Y Operate with flame p..Null

Other Control Equipment


Details for:SI Category: TreatmentSI Type: 023-Flaring & 099-Other



Install StartDate

PollutantControlled(treatment)




EfficiencyBasis

Fabric FilterMinimumPressureDrop (in. ofwater column)

Fabric FilterMaximumPressureDrop (in. ofwater column)

Bag leakdetector inuse?

ConfidentialityFlag

018-FabricFilter - LowTemp, T<180Degrees F

TREA1 CE002 MAC custom Null Particulate Matter 100 99.9 Y N Other 1 8 N Null

PM < 2.5 micron 100 99.8 Y N Other 1 8 N Null

PM < 10 micron 100 99.9 Y N Other 1 8 N Null

TREA2 CE007 MAC 39AVRC..Null Particulate Matter 100 93.5 N Null Other 1 8 N Null

PM < 2.5 micron 100 31.4 N Null Other 1 8 N Null

PM < 10 micron 100 88.3 N Null Other 1 8 N Null

TREA4 CE009 MAC 120MCF.. Null Particulate Matter 100 98.9 Y N Other 1 6 N Null

PM < 2.5 micron 100 84.7 Y N Other 1 6 N Null


TREA12 CE001 MAC 120LVS81 Null Particulate Matter 100 98.9 Y N Other 1 6 N Null

PM < 2.5 micron 100 97 Y N Other 1 6 N Null


TREA17 CE014 TBD TBD Null Particulate Matter 100 99.4 Null Null Null Null Null Null Not Confidential

PM < 2.5 micron 100 93.3 Null Null Null Null Null Null Not Confidential

PM < 10 micron 100 98.9 Null Null Null Null Null Null Not Confidential






PM < 10 micron 100 97 Null Null Null Null Null Null Not Confidential











PM < 2.5 micron 100 0 Null Null Null Null Null Null Not Confidential



PM < 2.5 micron 100 0 Null Null Null Null Null Null Not Confidential


Fabric Filters, General


Details for:SI Category: TreatmentSI Type: 018-Fabric Filter - Low Temp, T<180 Degrees F

Subject Item ID


Install StartDate

PollutantControlled(treatment)




EfficiencyBasis

Catalyst BedReactivity(kat)

BurnerCapacity(MMBTU/hr)

CatatlyticOxidizer InletTemperature(°F)

OutletTemperature(°F)


..ytic Oxidizer, TREA27CE024 Null Null Null Null Null Null Null Null Null Null Null Null Null Null





Catalytic Oxidizers, General


Details for:SI Category: TreatmentSI Type: 109-Catalytic Oxidizer


Install StartDate





EfficiencyBasis

ThermalOxidationBurnerCapacity (°F)

ThermalOxidationInletTemperature(°F)

ThermalOxidationMinimumCombustionTemperature..

ThermalOxidationOutletTemperature(°F)

ThermalOxidationResidenceTime(seconds)

ConfidentialityFlag

131-ThermalOxidizer,TREA6,CE011

Metpro custom Null Carbon Monoxide 100 90 Y N Other 98.96 Null 1477 Null Null Null

HAPs - Total 100 80 N Null Other 98.96 Null 1477 Null Null Null

Particulate Matter 100 50 N Null Null 98.96 Null 1477 Null Null Null

PM < 2.5 micron 100 50 N Null Null 98.96 Null 1477 Null Null Null

PM < 10 micron 100 50 N Null Null 98.96 Null 1477 Null Null Null

Volatile Organic Co.. 100 95 Y N Other 98.96 Null 1477 Null Null Null

131-ThermalOxidizer,TREA25,CE022

TBD TBD Null Carbon Monoxide 100 85 Null Null Null Null Null Null Null Null Not Confidential

HAPs - Total 100 90 Null Null Null Null Null Null Null Null Not Confidential

Particulate Matter 100 50 Null Null Null Null Null Null Null Null Not Confidential

PM < 2.5 micron 100 50 Null Null Null Null Null Null Null Null Not Confidential

PM < 10 micron 100 50 Null Null Null Null Null Null Null Null Not Confidential

Volatile Organic Co.. 100 98 Null Null Null Null Null Null Null Null Not Confidential

Direct Flame Afterburners, General


Details for:SI Category: TreatmentSI Type: 131-Thermal Oxidizer

Attachment 3: Points calculator

Points Calculator

1) AI ID No.: 85851 Total Points 1892) Facility Name: Al-Corn Clean Fuel3) Small business? y/n? n 4) Air Project Tracking Numbers (including 5555, 5443 5) Date of each Application Received: 5/27/2016, 12/31/20156) Final Permit No. 03900028-1017) Permit Staff Eric Sulita

Total TotalApplication Type Air Project Tracking No. Tempo Activity ID Qty. Points Points Additionl Cost DetailsAdministrative Amendment 1 0 -$ Minor Amendment 5443 20150003 1 4 4 1,140.00$ Applicability Request 10 0 -$ Moderate Amendment 15 0 -$ Major Amendment 25 0 -$ Individual State Permit (not reissuance) 50 0 -$ Individual Part 70 Permit (not reissuance) 5555 20110003 1 75 75 21,375.00$

Additional PointsModeling Review 5555 20110003 1 15 15 4,275.00$

BACT Review 15 0 -$ LAER Review 15 0 -$ CAIR/Part 75 CEM analysis 10 0 -$ NSPS Review 5555 20110003 3 10 30 8,550.00$ subps. IIII, Vva, KKKKNESHAP Review 5555 20110003 1 10 10 2,850.00$ subp. ZZZZCase-by-case MACT Review 20 0 -$ Netting 10 0 -$ Limits to remain below threshold 5555 20110003 2 10 20 5,700.00$ PSD, 40 CFR pt. 63Plantwide Applicability Limit (PAL) 20 0 -$ AERA review 15 0 -$ Variance request under 7000.7000 35 0 -$ Confidentiality request under 7000.1300 2 0 -$ EAW reviewPart 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 & D; 17, items A to C & E to G; and 18, items B & C

5555 20110003 1 35 35 9,975.00$

Part 4410.4300, subparts 4; 5 items A & B; 13; 15; 16, items B & C; and 17 item D

70 0 -$

Add'l Points 110

NOTES: Highlighted copies of NSPS subp. Dc and Kb were included in DQ 5555, though most of the applicable requirements were already in the permit.

(DQ 5323)

Attachment 4: 2012 and 2013 Performance Test Results

Attachment 5: Consent Decree Control Technology Plan

Attachment 7: MPCA Supplemental BACT-equivalent Analysis

Al-Corn MPCA SUPPLEMENTAL BACT-equivalent ANALYSIS 12/13/2016 PROPOSED PHYSICAL AND OPERATIONAL CHANGES

1. The facility will increase throughput from 50 mg/yr to 130 mg/yr of undenatured ethanol. 2. The facility will increase grain and DDGS throughput. 3. Emissions from the fermentation process are subject to BACT-equivalent controls. The bulk of the existing fermentation process train will remain, and will be

expanded. Scrubber (CE003) was replaced with scrubber (CE010) in Permit Action 10 (2006). Now, fermentation scrubber (CE010) will be replaced with one scrubber (TREA 16); however, emissions from the distillation process will now be routed to TREA 16 instead of to the TO/HRSG (TREA 6). Facility will maintain minimum control of 95%.

4. DDGS cooling cyclone (EU018) will be removed and replaced with 2 new cyclones (EU159 and EU160). Since the entire process is being replaced, BACT-equivalent requirements will not be applicable to the new units.

5. Emissions from DDGS drying are subject to BACT-equivalent control. The existing dryers and RTO will remain, however, the throughput will be increased. The control reduction efficiencies will be maintained, however, the additional load could result in an increase in lb/hr levels.

6. EU017, a boiler subject to the group NOx limit will be removed. New boilers will not be subject to the group NOx limit. After the removal of boiler 1, the only remaining combustion sources subject to the BACT-equivalent limit of <= 0.04 lb/MMBtu per emission unit (on average) will all vent to a common stack. Therefore, the limit will be set as 0.04 lb/MMBtu, or an equivalent lb/hr at STRU 24.

BACT-EQUIVALENT ANALYSIS

7. BACT-equivalent limits remain in the permit and cannot be changed without a revised analysis. A revised analysis is required to ensure that the affected units continue to be controlled to levels considered equivalent to BACT.

MPCA-Proposed BACT-equivalent Control and Emission Limits

Emission Unit/SV Pollutant Consent Decree BACT-equivalent limit NOTES NOx from Natural Gas Combustion Boiler 1 (EU017), EU013, EU037 and EU042

NOx Low-NOx burner equivalent NOx: < 0.04 lb/MMBtu (average)

≤9.840 lb/hr based on an average of 0.04 lb/MMBtu before Boiler 1 is removed. ≤7.440 lb/hr based on an average of 0.04 lb/MMBtu after Boiler 1 is removed

EQUI 54/EU013 (Dryer 1) = 42 MMBtu/hr EQUI 47/EU037 (Dryer 2) = 45 MMBtu/hr TREA 6/EU042 (TO/HRSG) = 98.96 MMBtu/hr EQUI 68/EU017 (Boiler 1) = 60 MMBtu/hr (to be removed) (42 + 45 + 60 + 98.96) MMBtu/hr x 0.04 lb/MMBtu = 9.8384 lb/hr => 9.84 lb/hr (42 + 45 + 98.96) MMBtu/hr x 0.04 lb/MMBtu = 7.7384 lb/hr => 7.740 lb/hr Permit calculations rely upon a NOx emission rate of 7.280 lb/hr, so this value is achievable.

PM/PM10 Test and set (lb/hr) ≤5.220 lb/hr PM based on a 3-hour average

Calculations assume an PM/PM10 control efficiency of 50%. This is consistent with BACT-

DDGS Drying from EQUI54 and EQUI 47, and TREA 6 (TO/HRSG)

Use of multiclones on dryers for PM/PM10 control

Vent to thermal oxidizer (TO)

equivalent controls of the time for thermal oxidation. The Consent Decree required the facility to “test” to “set” a limit. The first test was in 2007:

2007 test: PM/PM10 = 2.61 lb/hr o 2.61 * 0.5 (50% control) = 5.22 lb/hr

Permit calculations rely upon a PM emission rate of 3.560 lb/hr, so this value is achievable.

If needed the Permittee would be able to justify a higher emission rate (lb/hr) in the future, based on the fact that the production throughput has increased.

VOC 95% reduction or 10 ppm outlet concentration

Test and set (lb/hr)

Vent to TO

≤2.70 lb/hr VOC as mass based on a 3-hour average ≥ 95% overall control

Calculations assume a VOC control of 98%, this is higher than the required BACT-equivalent efficiency of 95% for this control This is consistent with BACT-equivalent controls of the time for thermal oxidation.

Performance Testing. The Permittee did not test for VOC as total mass until 10/23/2102. The result of that test was 1.08 lb/hr. The Permittee has stated that the TO is capable of achieving 98% overall control. This is consistent with previous testing.

1.08 lb/hr = (100-98)/100 * 54 lb/hr

54 lb/hr * (100-95)/100 = 2.70 lb/hr normalized to 95% overall control.

BACT-equivalent limit in PER009 was 1.5 lb/hr VOC as total mass (no basis for limit was documented).

Permit calculations rely upon a VOC emission rate of 2.50 lb/hr, so this value is achievable.

CO 90% reduction or <100 ppm

≥90% reduction or <100 ppm

Calculations estimate uncontrolled PTE.

2007 test: CO = 58.44 ppm

Vent to TO ≤ 16.630 lb/hr CO based on a 3-hour average

2008 test: CO = 13.3 lb/hr, 81 ppm Since the initial test, the facility has

increased throughput capacity from 30 MGY to 50 MGY, (represented by 2007 and 2008 tests). This permit action will increase throughput from 50 MGY to 130 MGY, therefore the load will increase.

BACT-equivalent limit set in PER 009 ≤ 15.8 lb/hr CO (set equivalent to 81 ppm), which is more restrictive than 100 ppm.

Permit calculations rely upon a CO emission rate of 16.63 lb/hr. Since the facility did not provide calculations on uncontrolled CO emissions, this value will be used to represent the BACT-equivalent limit, and it is expected that this value is achievable.

NOx NOx: < 0.04 lb/MMBtu (average)

* See NOx discussion in first row of this table above.

Existing Fermentation Scrubber (STRU 27/SV003, TREA 10) New Fermentation Scrubber (STRU 37, TREA 16)

VOC 95% or <20 ppm if inlet less than 200 ppm; Test and set (lb/hr)

≥95% overall control or <20 ppm if inlet less than 200 ppm

≤ 9.60 lb/hr VOC as total mass based on a 3-hour average at STRU 27

≤ 20.80 lb/hr VOC as total mass based on a 3-hour average at STRU 37

Monitor Scrubber, Water circulation flow rate

Performance test conducted 2/19/2008, at 50 MGY. SV003 = 5.25 lb/hr @98.33%

5.25 lb/hr x (100-98.33)/100 = 314.37 lb/hr.

314.37 lb/hr x (100-95)/100 = 15.719 lb/hr LIMIT based on 2008 test (at 50 MGY).

BACT-equivalent limit set in PER 009 ≤7.7 lb/hr VOC as mass (at 30 MGY).

BACT-equivalent limit set in PER 011 ≤9.6 lb/hr VOC as mass (at 50 MGY). This will remain as a BACT-equivalent limit for the existing facility which vents fermentation process emissions to STRU 27, controlled by TREA 10.

Permit calculations rely upon a VOC emission rate of 20.80 lb/hr based on 95% overall control. It is reasonable to expect the lb/hr emission rate to increase when the process throughput is increased from 50 MGY to 130

MGY. Furthermore, all of the distillation process emissions and pre-fermentation emissions will be routed to TREA 16. This additional load was not represented in the previous performance tests conducted at TREA 10 (original fermentation scrubber).

EQUI 71/STRU 15 Cooling Cyclone

VOC Test and set (lb/hr) If Al-Corn concludes that controls are not technically feasible, they shall propose a VOC limit based on data collected from initial performance testing.

BACT-equivalent limit set in PER 011 ≤4.00 lb/hr VOC as total mass

Permittee has determined that routing the emissions to the thermal oxidizer is not cost effective (it would be in excess of $100,000 to remove ~ 8 tons of VOC), especially given that this unit will be removed in 2017 or 2018.

New cyclone not subject to BACT-equivalent Initial test conducted 1/21-23, 2003 at 62 gpm ethanol (32.5 MGY)

Acetaldehyde = 0.039 lb/hr (HAP, VOC)

Acetic Acid = 0.33 lb/hr (VOC)

Acrolein = 0.017 lb/hr (HAP, VOC) Ethanol = 3.11 lb/hr (VOC)

Ethyl Acetate = 0.017 lb/hr (VOC)

Methanol = 0.017 lb/hr (HAP, VOC) Formaldehyde = 0.011 lb/hr (HAP, VOC)

SUM VOC as mass = 3.541 lb/hr (2.81 lb/hr as C)

Tested at 1.82 lb/hr VOC in 2005 (limit <= 6.0 lb/hr)

Ethanol Loadout

Existing tanks/racks

Not applicable to new system.

VOC Truck load-out must vent to Thermal Oxidizer. Limited to 4 million gallons/year of uncontrolled operation.

95% reduction

Vent to flare (or other control equipment capable of achieving 95% destruction)

TO originally required by Consent Decree, which is 95% control. Permittee would have option of rerouting to TO instead of flare.

Facility may rely upon 98% reduction of VOCs by flare for purposes of PSD.

Truck Traffic PM/PM10 Pave roads that are used for truck and car traffic (see map), Fugitive Dust Control Plan

Weekly visual inspections, Document inspections and corrective actions, Use water or mechanical means of removal to minimize identified fugitive dust emissions.

BACKGROUND Information

Fermentation Scrubber (SV003)

2005 BACT Permit RBLC 2015 BACT Testing

VOC 98% or xx ppm,d VOC as C.

PER005: 95% or <20 ppm; 2.73 lb/hr mass; 39 gpm PER010: 95% or <20 ppm; 2.73 lb/hr mass 31.5 gpm

2005: 97, 95, 97, 11.8 lb/hr 2015: 98 (32.52 lb/hr); 98.5 (10.2); 98

Thermal Oxidizer 6/2005: 0.29 lb/hr as ethanol; 99.9% 9/2012: 0.49 lb/hr as mass; 35.1 gpm

Distillation Scrubber

2005 Permit RBLC 2015 Testing

VOC 98% or xx ppm,d VOC as C.

PER005: 95% or <10/20 ppm; 0.99 lb/hr mass; 6 gpm PER010: 95% or <20 ppm;

2005: 98, 95, 95 (D); 2015: 98 (0.93)

Thermal Oxidizer

Distillation and Fermentation Scrubber (SV016)

2005 Permit RBLC 2015 Testing VOC 98%, Thermal Oxidizer,

now a scrubber

PER005: 95% or <20 ppm; 4.70 lb/hr; 68 gpm PER010: 95% or <20 ppm; 6.59 lb/hr mass; 60.3 gpm PER006 increased VOC limit from 4.70 to 6.59 lb/hr, no basis for the increase.

2005: 98, 95, 95 (D); 2015: 98 (0.93)

Scrubber 8/2007: 1.03 as mass; 67 gpm; 753 gpm beer 5/2012: 5.35

Dryers controlled by VRTO 1 (SV011):

2005 Permit RBLC 2015 Testing PM/PM10 0.014

g/dscf PER005: PM/PM10 < 3.47 lb/hr; 90% PER010: PM/PM10 < 5.75 lb/hr; 90%

.01, 0.015 g/dscf Thermal Oxidizer Cyclone

6/2005: T&S 1.50 PM; 2.96 PM10 Tested at 5.12 lb/hr8/2010 retest.

VOC 96% or 41 ppm,d VOC as C.

PER005: 95% or < 10 ppm; 1580 F; 8.87 lb/hr mass (no explanation of basis)

2005: 95% or 10 ppm, 95% and 5 lb/hr

2015: 98% (except Heartland)

Thermal Oxidizer 6/2005: T&S 2.55 <as mass; 4.42 as ethanol; 97.8%; 480 gpm beer 9/2012: 2.09 as mass; 445 gpm beer;

didn’t do method 25A for %

CO PER005: 11.3 lb/hr; 90% or 100 ppm (no explanation of basis)

GCP 6/2005: 71.1 ppm 8/2007: VRTO2 = 8.0 lb/hr

10/2007: 85.6 ppm, 10.1 lb/hr 8/2011: 8.64 lb/hr 9/2012: VRTO2 = 8.96 lb/hr < 19.4

NOx Part of NOx group.

Consent Decree: < 0.04 lb/MMBtu

31 MMBtu/hr x 0.04 lb/MMBtu = 1.24 lb/hr Was 18 MMBtu x 0.04 = 0.72 lb/hr

6/2005: 0.059 lb/MMBtu, 6.06 lb/hr 8/2007: VRTO2 0.03 lb/MMBtu 2/2011: 6.17 lb/hr, 16.0 ppm 2/2011: VRTO2 = 11.1 lb/hr, 26.7 ppm 10/2015: VRTO2 = 9.27 lb/hr, 20.5 ppm

DDGS Loadout

2005 Permit RBLC 2015 Testing PM/PM10 BMP for handling within

building. Feasible means include closing doors as possible, install plastic strips.

PER2010: 15 mph speed limit, immediately eliminate any fugitive emissions on roadway by sweeping or watering/chem. suppressant.

2005: Baghouse 0.41 lb/hr; Baghouse 99%

Thermal Oxidizer Cyclone

Note from BACT analysis: “Unfortunately the naming of the source has probably led to confusion. This is not a ducted source. DDGS is loaded onto piles within the DDGS storage building. The source described is a purely fugitive source and the primary issue is not control equipment, but the ability to capture these emissions to route to control equipment. ..”

Attachment 8: Documentation for Emission Factors for HAP

Emissions from Ethanol Loadout

MSDS No: PEG-UNL Page 1 of 13 03/05/2008

UNLEADED GASOLINE (ALL GRADES) MATERIAL SAFETY DATA SHEET

Petrocom Energy Group, LLC 1330 Post Oak Blvd., Suite 2350 Houston, Texas 77056 Phone: 713-418-3000 Fax: 713-418-3001 Revision Date: 03/05/2008 Section 1: Product Identification Name: Unleaded Gasoline Synonyms: Regular/Midgrade/Premium Gasoline, Motor Fuel, Reformulated Gasoline, RFG,

Conventional Gasoline. CAS No.: 86290-81-5 MSDS No.: PEG-UNL Use: Motor fuel Section 2: Product Composition Component CAS Number Amount (%) Gasoline 86290-81-5 0 – 100 Benzene 71-43-2 0 – 5 Toluene 108-88-3 0 – 30 Xylene (all isomers) 1330-20-7 0 – 25 Hexane (other isomers) Mixture 5 – 25 n-Hexane 110-54-3 0 – 3 Cyclohexane 110-82-7 0 – 3 Octanes (all isomers) Mixture 0 – 20 Heptane (all isomers) 142-82-5 0 – 15 Ethanol 64-17-5 0 – 10 Pentanes (all isomers) Mixture 0 – 20 Trimethylbenzenes (all isomers) 95-63-6 0 – 5 Ethylbenzene 100-41-4 0 – 5 Cumene 98-82-8 0 – 5 Methyl Tertiary Butyl Ether (MTBE) 1634-04-4 0 – 16 Tertiary Amyl Methyl Ether (TAME) 994-05-8 0 – 6

khillbrandt

Highlight

khillbrandt

Highlight

khillbrandt

Highlight

khillbrandt

Highlight


Petrocom Energy Group, LLC MSDS – Unleaded Gasoline (All Grades) Section 3: Hazards Identification

Emergency Overview

DANGER!

Extremely Flammable liquid and vapor Harmful if swallowed

Skin Irritant May cause eye and respiratory irritation

Cancer Hazard – Contains material which can cause cancer

Hazard Rankings

NFPA

Physical form: Liquid Appearance: Clear to amber Odor: Strong, Gasoline Potential Health Effects Eyes: Contact with eyes may cause irritation, redness, tearing, stinging,

watering and blurred vision. Skin: Contact with skin may cause irritation, itching, redness and skin damage.

Prolonged or repeated contact may cause drying and cracking of the skin, and may also cause dermatitis and inflammation. (See also section 11).

Inhalation: Breathing high concentration can be harmful. Throat and lung irritation may occur. Central nervous system effects including nausea, euphoria, dizziness, headache, fatigue, drowsiness or unconsciousness may occur due to long term or high concentration exposure to vapors.

Ingestion: Toxic if swallowed. This product may cause nausea, vomiting, dizziness, drowsiness, diarrhea if swallowed. Central nervous system effects may be caused. Swallowing this product can result in severe lung damage and/or death.

Signs / Symptoms: When overexposed to this product effects such as nausea, vomiting, blurred vision, respiratory failure, central nervous system depression, unconsciousness, tremor, death may occur.

See toxicological Information (section 11)

13

0


Petrocom Energy Group, LLC MSDS – Unleaded Gasoline (All Grades) Section 4: First Aid Measures Eye contact: Flush eyes immediately with fresh, cool water for at least 15

minutes. If irritation or redness or any symptoms persist, seek medical attention.

Skin contact: Remove contaminated clothes and shoes. Flush affected area

with large amounts of water. If skin surface is damaged, apply a clean dressing and seek medical attention. If skin surface is not damaged, wash affected area thoroughly with soap and water. If irritation or redness develops, seek medical attention.

Inhalation (Breathing): If inhaled, immediately move person to fresh air. If there is

difficulty breathing, give oxygen. If not breathing, immediately give artificial respiration. Seek medical attention.

Ingestion (Swallowing): This product may be harmful or fatal if swallowed. This product

may cause nausea, vomiting, diarrhea and restlessness. Do not induce vomiting. Do not give anything by mouth because this material can enter the lungs and cause severe lung damage. If victim is unconscious or drowsy, place on the left side with the head down. Seek immediate medical attention.

Notes to Physician: This material sensitizes the heart to the effects of

sympathomimetic amines. Epinephrine and other sympathomimetic drugs may initiate cardiac arrhythmias in individuals exposed to this material.

Inhalation overexposure can produce toxic effects. Monitor respiratory distress. If difficulty in breathing evaluate upper respiratory tract inflammation, bronchitis and pneumonitis. Administer supplemental oxygen as required.

If ingested, this material presents a significant aspiration and chemical pneumonitis hazard. Cinsuder activated charcoal and/or gastric lavage. If patient is obtunded, protect the airway by cuffed endotracheal intubtion or by placement of the body in a Trendelenburg and left lateral decubitus position.


Petrocom Energy Group, LLC MSDS – Unleaded Gasoline (All Grades) Section 5: Fire Fighting Measures NFPA Hazard Class: Health = 1 ; Flammability = 3 ; Instability = 0

(0 – Minimal ; 1 – Slight ; 2 – Moderate ; 3 – Serious ; 4 – Severe)

Auto – ignition temperature : >260 ˚C (500 ˚F) Flash point : Closed cup: -43 ˚C (-45 ˚F) Flammable limits : Lower: approximately 1.4% Upper: approximately 7.6% Products of combustion : Carbon monoxide, carbon dioxide, nitrogen and sulfur oxides,

smoke, fumes, unburned hydrocarbons and other products of incomplete combustion.

Special properties : Flammable liquid! This material can be ignited by heat, sparks,

flames or other sources of ignition. Vapors may travel long distances to a source where they can ignite and flash back, or explode. A mixture of vapor and air can create an explosion hazard in confined spaces. If container is not properly cooled, it can rupture n the heat of a fire.

Extinguishing media : Use of dry chemical, carbon dioxide, or foam is recommended to

extinguish fire. Water spray is recommended to cool or protect exposed materials or structures. Carbon dioxide can displace oxygen. Use caution when applying carbon dioxide in confined spaces. Water may not extinguish the fire, unless it is used by experienced fire fighters and under favorable conditions.

Protective Equipment for : Fire fighters should wear appropriate protective equipment and Fire Fighters self contained breathing apparatus (SCBA) with a full face piece

operated in positive pressure mode.

13

0


Petrocom Energy Group, LLC MSDS – Unleaded Gasoline (All Grades) Section 6: Accidental Release Measures Personal precautions: This material is extremely flammable. Eliminate all ignition

sources. Keep all hot metal surfaces away from spill/release. All equipment used when handling this material must be grounded.

Spill precautions: Stay upwind and away from spill. Notify persons down

wind of the spill, isolate spill area and keep unauthorized personnel out. If it can be done with minimal risk, try to stop spill. Always wear protective equipment, including respiratory protection. Contact emergency personnel.

Environmental precautions: Prevent spilled material from entering sewers, drains, soil,

and natural waterways. Use foam or spills to minimize vapors (section 5). Spilled material may be absorbed into an appropriate absorbent material.

Methods for cleaning up: Notify fire authorities and appropriate federal, state and

local agencies. Immediate cleanup is recommended. Section 7: Handling and Storage Handling: Flammable liquid and vapor. To be used only as a motor fuel. Avoid inhalation

of vapors and contact with skin. Wash hands thoroughly after handling this material. Use in a well ventilated area away from all ignition sources. Use product with caution around heat, sparks, static electricity and open flames. Static electricity may ignite vapors and cause fire.

Empty containers retain residue and may be dangerous. Do not pressurize, cut,

weld, braze, solder, drill, grind, or expose such containers to heat, flame, sparks or other ignition sources. The may explode and cause injury and/or death. Empty drums should be completely drained, properly bunged, and returned promptly to a drum reconditioner. All containers should be disposed of in an environmentally safe manner and in accordance with governmental regulations.

Storage: Store in approved containers only. Keep in tightly closed containers in cool,

dry, well ventilated areas. Keep isolated away from heat, sources of ignition and hot metal surfaces.


Petrocom Energy Group, LLC MSDS – Unleaded Gasoline (All Grades) Section 8: Exposure Controls / Personal Protection Engineering controls: Provide ventilation or other engineering controls to keep the

airborne concentrations of vapor or mists below their occupational exposure limits. Eyewash stations and safety showers should be located near the work-station.

Personal Protection Eye Protection: Keep away from eyes. Safety glasses complying with approved

standards should be worn. Chemical type goggles should be worn.

Skin Protection: Keep away from skin. Skin protection should be worn. Chemical

resistant, impervious gloves should be worn. Always follow good personal hygiene practices after handling the material.

Respiratory Protection: Approved respiratory equipment must be used if a risk

assessment indicates it is necessary. If workplace exposure limits for product or components are exceeded, NIOSH approved equipment should be worn.

General Protection: Use this material in well ventilated areas. Ventilation equipment

should be explosion proof also.


Petrocom Energy Group, LLC MSDS – Unleaded Gasoline (All Grades)

Component Applicable Workplace Exposure Limits Gasoline ACGIH – TWA: 300 ppm (8 hours)

STEL: 500 ppm (15 minutes) Benzene ACGIH – TWA: 0.5 ppm (8 hours)

STEL: 2.5 ppm (15 minutes) OSHA – TWA: 1 ppm (8 hours) STEL: 5 ppm (15 minutes)

Toluene ACGIH – TWA: 20 ppm (8 hours) OSHA – TWA: 200 ppm (8 hours) CEIL: 300 ppm PEAK: 500 ppm (10 minutes)

Xylene (all isomers) ACGIH – TWA: 100 ppm (8 hours) STEL: 150 ppm (15 minutes) OSHA – TWA: 100 ppm (8 hours)

Hexane (other isomers) ACGIH – TWA: 500 ppm (8 hours) STEL: 1000 ppm (15 minutes)

n-Hexane ACGIH – TWA: 50 ppm (8 hours) OSHA – TWA: 500 ppm (8 hours)

Cyclohexane ACGIH – TWA: 100 ppm (8 hours) OSHA – TWA: 300 ppm (8 hours)

Octanes (all isomers) ACGIH – TWA: 300 ppm (8 hours) OSHA – TWA: 500 ppm (8 hours)

Heptane (all isomers) ACGIH – TWA: 400 ppm (8 hours) STEL: 5000 ppm (15 minutes) OSHA – TWA: 500 ppm (8 hours)

Ethanol ACGIH – TWA: 1000 ppm (8 hours) OSHA – TWA: 1000 ppm (8 hours)

Pentanes (all isomers) ACGIH – TWA: 600 ppm (8 hours) OSHA – TWA: 1000 ppm (8 hours)

Trimethylbenzenes (all isomers) ACGIH – TWA: 25 ppm (8 hours)

Ethylbenzene ACGIH – TWA: 100 ppm (8 hours) STEL: 125 ppm (15 minutes) OSHA – TWA: 100 ppm (8 hours)

Cumene ACGIH – TWA: 50 ppm (8 hours) OSHA – TWA: 50 ppm (8 hours)

Methyl Tertiary Butyl Ether (MTBE) ACGIH – TWA: 50 ppm (8 hours) Tertiary Amyl Methyl Ether (TAME) ACGIH – TWA: 20 ppm (8 hours)


Petrocom Energy Group, LLC MSDS – Unleaded Gasoline (All Grades) Section 9: Physical and Chemical Properties Physical State: Liquid. Color: Transparent, clear to amber liquid. Odor: Strong. Characteristic gasoline odor. pH: Not applicable Boiling Point: >26 ˚C (>78 ˚F) Melting Point: Not applicable. Specific gravity: 0.66 to 0.75 (Water = 1) Vapor density: 3 to 4 (Air = 1) Vapor pressure: 220-450 mm Hg at 20˚C (68˚F) / 6-15 Reid-psia at 37.8˚C (100˚F) Volatility: 720 – 770 g/l VOC (w/v) Viscosity (at 40 ˚C): < 1 Flash Point: < -45 ˚F / < 43˚C Bulk Density: 6.0 – 6.4 lbs/gal Solubility in water: Negligible Section 10: Stability and Reactivity Stability: Stable. Extremely flammable liquid and vapor. Vapor can cause

fire. Conditions to avoid: Keep away from heat, flame and all other possible sources of

ignition. Materials to avoid: Keep away from strong oxidizing agents such as acids, chlorine,

hydrogen peroxide and oxygen. Hazardous decomposition Please refer to the combustion products identified in Section 5 of products: this MSDS. Hazardous Polymerization: Not expected to occur.


Petrocom Energy Group, LLC MSDS – Unleaded Gasoline (All Grades) Section 11: Toxicological Information Toxicology Information Oral toxicity: Almost non-toxic. LD 50: > 2000 mg/kg (species: rats) Dermal toxicity: Almost non-toxic. LD 50: > 2000 mg/kg (species: rabbits) Inhalation toxicity: Almost non-toxic. LD 50: > 5 mg/l (species: rats) Eye irritation: Almost non-irritating. Draize score: > 6 and < 15 (species: rabbits) Skin irritation: Irritant. Primary irritation index: > 3 and < 5 (species: rabbits) Other data: Inhalation of high concentrations of vapors or mists may cause

respiratory system irritation and damage. It may also result in the damage and depression of the central nervous system and may cause death. Prolonged contact with the material may cause severe skin irritation.

Subchronic toxicity: Dermal studies resulted in significant irritation but not systematic

toxicity (species: rabbits). Inhalation exposures (90 day, approximately 1500 ppm vapor) produced light hydrocarbon nephropathy but no significant systemic toxicity (species: rats).

Neurotoxicity: Repeated and prolonged exposures to high concentrations of

vapor has been reported to result in central nervous system damage and eventually, death. In a study in which ten human volunteers were exposed for 30 minutes to approximately 200, 500 or 1000 ppm concentrations of gasoline vapor, irritation of the eyes was the only significant effect observed, based on both subjective and objective assessments.

However, no persistent neurotoxic effects were observed in subchronic inhalation studies of gasoline.

Reproductive toxicity: An inhalation study with rats exposed to 0, 400 and 1600 ppm of

wholly vaporized unleaded gasoline, 6 hours per day on day 6 through 16 of gestation, showed no teratogenic effects nor indication of toxicity to either the mother or the fetus. Another inhalation study in rats exposed to 3000, 6000, or 9000 ppm of gasoline vapor, 6 hours per day on day 6 through 20 of gestation, also showed no teratogenic effects nor indications of toxicity to either the mother or the fetus.

Chronic toxicity: A lifetime mouse skin painting study of unleaded gasoline applied

at 50 microliters, three time weekly, resulted in some severe skin irritation and changes, but no statistically significant increase in skin cancer or cancer to any other organ. Lifetime inhalation of wholly vaporized unleaded gasoline over 2000 ppm has caused increased liver tumors in female mice and increased kidney tumors in male rats. The EPA has concluded that mechanism by which wholly vaporzied unleaded gasoline causes kidney damage is unque to the male rat. The effects in that species (kidney damage and cancer) should not be used in human risk assessment.


Petrocom Energy Group, LLC MSDS – Unleaded Gasoline (All Grades) Other toxic effects Extremely hazardous in case of ingestion. on humans Very hazardous in case of eye contact. Hazardous in case of skin contact. Slightly hazardous in case of inhalation. Carcinogenic effects: Contains material that may cause cancer depending on the level

and duration of exposure. Target organs: Contains material that may cause damage to humans organs such

as (but not limited to) blood, kidneys, lungs, liver, eye, skin, nervous system and upper respiratory tract.

Section 12: Ecological Information Ecotoxicity: This material may be toxic to aquatic organisms such as algae

and daphnia. It has also shown to be toxic to fish. Environmental fate: The material is expected to be readily biodegradable. When

released into the environment, some of the constituents of gasoline will volatilize and be photo degraded in the atmosphere. Following spillage, the more volatile components of gasoline will be rapidly lost, with concurrent dissolution of these and other constituents into the water. Factors such as local environmental conditions, photo-oxidation, biodegradation and adsorption onto suspended sediments, can contribute to the weathering of spilled gasoline.

Section 13: Disposal Considerations Waste disposal: Avoid disposal of spilled material and runoff and contact with soil,

waterways, drains and sewers. Disposal of this product and any of its by products should always comply with the requirements of environmental protection and waste disposal legislation and any local authority requirements. This material would likely be identified as a federally regulated RCRA hazardous waste. See sections 7 and 8 for further information on handling, storage and personal protection. See section 9 for the material’s physical and chemical properties.


Petrocom Energy Group, LLC MSDS – Unleaded Gasoline (All Grades) Section 14: Transportation Information This material is U.S Department of Transportation (DOT) regulated material. Shipping name: Gasoline, 3, UN 1203, PG II

Gasohol, 3, NA 1203, PG II (for gasoline blended with less than 20% ethanol).

Hazard class: 3 DOT Class: Flammable liquid Packing Group: II UN / NA Number: UN1203 / NA1203 Emergency Response Code: 128 Label:

Section 15: Regulatory Information TSCA Inventory: This product and/or its components are listed on the Toxic

Substances Control Act (TSCA) SARA 302 / 304: The Superfund Amendments and Reauthorization Act of 1986 Emergency planning and (SARA) Title III requires facilities subject to Subparts 302 and notification 304 to submit emergency planning and notification information

based on Threshold Planning Quantities (TPQs) and Reportable Quantities (RQs) for “Extremely Hazardous Substances” listed in 40 CFR 302.4 and CFR 355. No components were identified.

SARA 311 / 312: SARA Title III requires facilities subject to this subpart to Hazard identification submit aggregate information on chemicals by “Hazard

Category” as defined in 40 CFR 370.2. This material would be classified under: Fire, Acute (immediate) Health Hazard, Chronic (Delayed) Health Hazard.


Petrocom Energy Group, LLC MSDS – Unleaded Gasoline (All Grades) CERCLA / SARA 313: This material contains the following chemicals subject to the Toxic and chemical reporting requirements of Section 313 of SARA Title III and notification and release 40 CFR 372 reporting Component CAS Number Amount (%) Benzene 71-43-2 0 – 5 Toluene 108-88-3 0 – 30 Xylene (o, m, p isomers) 1330-20-7 0 – 25 n-Hexane 110-54-3 0 – 3 Cyclohexane 110-82-7 0 – 3 1, 2, 4 Trimethylbenzenes 95-63-6 0 – 5 Ethylbenzene 100-41-4 0 – 5 Cumene 98-82-8 0 – 5 Methyl Tertiary Butyl Ether (MTBE) 1634-04-4 0 – 16 California Proposition 65: This material may contain detectable quantities of the following

chemicals known to the State of California to cause cancer, birth defects or other reproductive harm, and which may be subject to the requirements of California Proposition 65 (CA Health & Safety Code Section 25249.5):

Benzene (CAS NO. 71-43-3) Toluene (CAS No. 108-88-3) Ethylbenzene (CAS No. 100-41-4) Naphthalene (CAS No. 91-20-3)

Canadian Regulations: WHMIS Hazard Class: B2 – Flammable Liquids D2A – Very Toxic Material


Petrocom Energy Group, LLC MSDS – Unleaded Gasoline (All Grades) Section 16: Other Information Issue date: March 5, 2008 Previous issue date: No previous date Version: 1 MSDS Code: PEG-UNL Legend: ACGIH = American Conference of Governmental Industrial Hygienists CAS = Chemical Abstracts Service Registry CEIL = Ceiling Limit CERCLA = The Comprehensive Environmental Response, Compensation and Liability Act EPA = Environmental Protection Agency NFPA = National Fire Protection Association OSHA = Occupational Safety and Health Administration SARA = Superfund Amendments and Reauthorization Act STEL = Short Term Exposure Limit (15 minutes) TWA = Time Weighted Average (8 hours) WHMIS = Worker Hazardous Materials Information System (Canada) Disclaimer: The information presented in this Material Safety Data Sheet (MSDS) d on data believed to be accurate as of the issuance date of this MSDS. No warranty is expressed or implied for the accuracy or completeness of the above provided information. Petrocom Energy Group, LLC does not assume any liability for any damage or injury arising out of product use by others. The end user of the product has the responsibility for evaluating the accuracy of the data, and determining the safety, toxicity and suitability of the product under any conditions.

Attachment 9: Air Products Letter

Documents

Technical Support Document Draft Air Emission Permit No ......• STRU 11/TREA 12 (formerly SV001/CE001) – Baghouse / fabric filter will be removed. Includes the removal of units