Intent to Issue Air Emission Permit to Bluegrass Protein Inc ...

Technical Support Document, Permit Number: 07300016-101 of 13

Draft Technical Support Document

for Draft Air Emission Permit No. 07300016-101

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: 2022 - Natural, Processed, and Imitation Cheese)

Kerry Williams 1117 Cleveland Ave Glasgow, Kentucky 42141

Bluegrass Proteins 1864 311th Ave Dawson, MN 56232

Contact: Dave Cornelius Phone: 320-769-2997x222

1.2 Facility description

Bluegrass Proteins, Inc., in Dawson, Minnesota, formerly owned by Associated Milk Producers Inc. (AMPI), produces and packages natural cheeses and dries and packages concentrated cheese whey. The facility has the following equipment/operations that produce air emissions:

· Two boilers – one combusting natural gas with fuel oil as back-up, one combusting natural gas. · Two emergency generators combusting ultra-low sulfur diesel fuel. · A whey atomizer dryer that combusts natural gas or propane. Dried product is collected by four

product collection cyclones, in parallel, that are inherent process equipment. · Two fluidized bed dryers heated by steam in series. Product is collected by a product collection

cyclone and particulate matter (PM) emissions are controlled by a wet scrubber. · A whey powder collection surge bin. PM emissions from the surge bin are collected by a baghouse. · A 50,000 gallon fuel oil storage tank, which qualifies as an insignificant activity. · A wastewater treatment operation, which qualifies as an insignificant activity.

1.3 Description of the activities allowed by this permit action

This permit action is Part 70 Reissuance.

1.4 Description of notifications and applications included in this action

Table 2. Notifications and applications included in this action

Date received Application/Notification type and description 07/15/2010 Part 70 Reissuance (IND20100001)

Between this Part 70 reissuance and the last permit amendment (IND20070001), issued June 10, 2008, the Permittee submitted two Administrative Amendment applications for an ownership change (received April 16, 2014, and August 25, 2015). Both applications were deemed incomplete since they were missing the


required written agreement between the former (AMPI) and new Permittee that contained a specific date for transfer of permit responsibility, coverage, and liability, as required by Minn. R. 7007.1400, subp. 1(E). The required written agreement was not submitted to MPCA within 150 days of the date that either original application was received, so both applications are considered withdrawn. However, between the two applications (June 11, 2015) the Permittee submitted the required written agreement (separate from an amendment application) that stated that the specific date for transfer of permit responsibility, coverage, and liability was April 8, 2014. Therefore, the changes related to Administrative Amendment applications IND20140001 and IND20150001 have been processed.

1.5 Facility emissions

Table 3. Total facility potential to emit summary (in tons per year (tpy))

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 64 52 44 240 147 54

94,761 6.6 0.087 0.17

Total facility actual emissions (2016) 57.7 39.7 18.0 0.05 8.1 6.8 * 0.44 *

*Not reported in Minnesota emission inventory. Table 4. Facility classification

Classification Major Synthetic minor/area Minor/Area New Source Review X Part 70 X Part 63 X

1.6 Changes to permit

The permit does not authorize any specific modifications; however, the MPCA has a combined operating and construction permitting program under Minn. R. ch. 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. · Completed requirements were deleted. The 2006 reissuance permit required the facility to conduct

national ambient air quality standards (NAAQS) modeling for particulate matter less than 10 micron (PM10), which was completed in 2010. The computer-generated PM10 modeling result report is Attachment 3 to this TSD.

· Some requirements have been reordered to help with clarity (specifically, equipment requirements were moved from stacks to equipment or groups of equipment).

· The EU/TK, CE, and SV identifiers have been updated to EQUI, TREA, and STRU, respectively, to reflect MPCA’s current permitting practice.

· Data on the site’s emission units, stacks, and buildings has been updated based on the 2010 permit reissuance application, 2017 site visit, and 2017 supplemental information.

· National Emission Standards for Hazardous Air Pollutants (NESHAP) for Stationary Reciprocating Internal Combustion Engines (40 CFR pt. 63, subp. ZZZZ) requirements have been incorporated into this permit for EQUI 7 (formerly EU003) and EQUI 11 (formerly an insignificant activity).

· A requirement to submit dispersion modeling information for PM10, sulfur dioxide (SO2), and nitrogen oxides (NOx) was added to the permit. See Section 3.2 for details.


· The permitted fuel type for EQUI 1 (formerly EU001) was updated to reflect that the boiler is gas-fired as defined in 40 CFR § 63.11237. See Section 2.4 for details.

· PM10 emission factor performance test requirements were added to EQUI 3 (STRU 4, formerly SV006) and COMG 2 (STRU 8, formerly SV007). See Section 3.4 for details.

· The whey process throughput limit on EQUI 3 (formerly EU006) was changed to 7,670 lb whey/hr 24-hr block average to reflect compliant performance testing results. The block average was changed from weekly to daily to provide more reasonable assurance of compliance. See Section 3.4 for details.

· The product collection cyclone system (formerly EU010) has four cyclones in it, two that were replaced in July of 2003 and two that were replaced on July 27, 2005. The old EQUI was deactivated to reflect the removed cyclones, and four emission units (EQUI 14, 15, 16, and 17) were made to reflect that there are four cyclones following the atomizer dryer. COMG 1 was made to group the four units’ requirements.

· The fluidized bed dryer emission unit (formerly EU007) was split into two emission units (EQUI 12 and 13) to reflect that there are two fluidized bed dryers in series at the facility. COMG 2 was made to group the two units’ requirements.

· Operating and monitoring requirements were added to the cyclones (EQUI 9, formerly EU011, and EQUI 14, 15, 16, 17 (COMG 1), formerly EU010) to be consistent with inherent process equipment practice.

· The control equipment efficiencies, monitoring, and recordkeeping requirements were updated to remain consistent with the MN control equipment rule.

· The potential to emit calculations were updated with the following: o Updated emission factors where available, and added emission factors for ammonia, lead and

other hazardous air pollutants (HAPs), carbon dioxide, methane, nitrous oxide, and carbon dioxide equivalent where available;

o Updated whey-drying PM emission factor to process-specific AP-42 factor rather than limits from the Industrial Process Equipment Rule (IPER);

o Updated PM10 emission factors to be consistent with the 2010 NAAQS modeling; and o Added control equipment efficiencies for TREA 1 and 2.

· The following items were removed from the permit: o The product collection cyclone system (formerly EU010) to reflect cyclones removed from the

facility in 2003 and 2005. It was replaced with four subject items for the four installed between 2003 and 2005, as detailed earlier in this section.

o The canning line stack/vent (formerly SV005) since it is related to a decommissioned activity; o The mineral spirits parts cleaner (formerly EU009) because it was permanently decommissioned;

and o The aboveground storage tank (AST) and its related requirements since the Permittee replaced

former TK001 with a smaller tank that qualifies as an insignificant activity under Minn. R. 7007.1300, subp. 2(E)(3).

2. Regulatory and/or statutory basis

2.1 New source review (NSR)

The permit carries forward limits on the facility such that it is a minor source under New Source Review regulations. No changes are authorized by this permit.

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

2.3 New source performance standards (NSPS) The Cleaver-Brooks boiler (EQUI 2) is subject to 40 CFR pt. 60, subp. Dc (NSPS for Small Industrial-Commercial-Institutional Steam Generating Units). EQUI 2 is subject to only one requirement from the NSPS because it only combusts natural gas or propane. EQUI 2 is subject to 40 CFR § 60.48c(g) which generally requires records of daily fuel usage. However, because EQUI 2 only burns natural gas or propane, it is subject to paragraph 2 (40 CFR § 60.48c(g)(2)), which allows for monthly fuel usage records.


In previous permits, former TK001 was subject to 40 CFR pt. 60, subp. Kb (NSPS for Volatile Organic Liquid Storage Vessels). However, in 2011 TK001 was replaced with a smaller tank that qualifies as an insignificant activity under Minn. R. 7007.1300, subp. 2(E)(3). The new tank is not subject to 40 CFR pt. 60, subp. Kb, according to 40 CFR § 60.110b(b), because its volume is >150m3 (actual volume is 189 m3) with an average true vapor pressure (ATVP) <3.5 kPa (actual ATVP is <0.001 kPa according to EPA AP-42 Table 7.1-2 for fuel oil no. 6).

2.4 National emission standards for hazardous air pollutants (NESHAP) The facility is an existing area source of HAPs. It has two reciprocating internal combustion engines (RICEs) that are subject to 40 CFR pt. 63, subp. ZZZZ (NESHAP for Stationary RICEs). In 2011 AMPI submitted an Initial Notification stating that the facility’s Nebraska Boiler (EQUI 1) was subject to 40 CFR pt. 63, subp. JJJJJJ (NESHAP for Industrial, Commercial, and Institutional Boilers Area Sources). The following rationale was used to determine NESHAP JJJJJJ applicability to EQUI 1:

· The facility is an area source of HAPs. · The facility operates an industrial boiler. · The maximum design heat input capacity of the unit is >10 MMBtu/hr (60 MMBtu/hr). · The unit combusts fuel oil and natural gas.

However, prior to NESHAP JJJJJJ’s compliance date (March 21, 2014), the facility began operating EQUI 1 as the subpart defines gas-fired boilers: primarily on natural gas, using fuel oil only during natural gas supply interruption and for less than a combined total of 48 hours per year for periodic testing, maintenance, or operator training. Since AMPI began operating EQUI 1 as a gas-fired boiler before the compliance date, it stated that NESHAP JJJJJJ no longer applied. Bluegrass Proteins has chosen to take a fuel type restriction to continue operating the boiler as gas-fired and be exempt from NESHAP JJJJJJ. If the facility would like to begin using fuel oil outside the periods allowed for gas-fired boilers in 40 CFR § 63.11237, the Permittee will likely have to request a permit modification. If EQUI 1 becomes subject to NESHAP JJJJJJ, it is useful to know that the boiler has an oxygen trim system. The Cleaver-Brooks Boiler (EQUI 2) is not subject to NESHAP JJJJJJ because it is also a gas-fired boiler.

2.5 Minnesota State Rules

Portions of the facility are subject to the following Minnesota Standards of Performance: · Minn. R. 7011.0515 Standards of Performance for New Indirect Heating Equipment · 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. 7011.2300 Standards of Performance for Stationary Internal Combustion Engines

Table 5. Regulatory overview of facility

Subject item* Applicable regulations Rationale TFAC 1 - Air Quality Total Facility

Minn. R. 7007.0800, Minn. Stat. 116

Ambient Air Quality Standards: The facility previously conducted PM10 dispersion modeling. Parameters used in the modeling are included in Appendix B of the permit to provide a benchmark for future changes.

Minn. R. 7007.0100, Minn. R. 7009.0020, Minn. Stat. 116

The permit contains requirements to submit PM10, SO2, and NOx computer dispersion modeling information.


Subject item* Applicable regulations Rationale EQUI 1 - Nebraska Boiler

Minn. R. 7011.0515 Standards of Performance for new Indirect Heating Equipment · Construction of the unit was after January 31, 1977; · The unit burns gaseous and liquid fuels; · The facility is located outside of the Twin Cities; · The unit capacity is <250 MMBtu/hr (60 MMBtu/hr); and · The facility has <250 MMBtu/hr of indirect heating

equipment (147 MMBtu/hr). EQUI 2 - Cleaver-Brooks Boiler

40 CFR pt. 60, subp. Dc

NSPS for Small Industrial-Commercial-Institutional Steam Generating Units · The unit is a steam generating unit for which construction

commenced after June 9, 1989; · The unit burns gaseous fuels; · The unit capacity is <100 MMBtu/hr but >10 MMBtu/hr

(74 MMBtu/hr); and · The unit has not been modified after February 28, 2005.

EQUI 3 - Atomizer Dryer

Minn. R. 7011.0610 Standards of Performance for Direct Heating Equipment · Construction of the unit was after July 9,1969; · The unit burns gaseous fuels; · The facility is located outside of the Twin Cities; and · The facility has <250 MMBtu/hr of indirect and direct

heating equipment (147 MMBtu/hr). Minn. R. 7007.0800, Minn. Stat. 116

Ambient Air Quality Standards: The facility previously conducted PM10 dispersion modeling. PM10 parameter used in the modeling added as an emission factor performance test requirement.

EQUI 5 - Surge Bin EQUI 9 - Secondary Cyclone EQUI 14, 15, 16, & 17 (COMG 1) - Primary Cyclones

Minn. R. 7011.0715

Standards of Performance for Post-1969 Industrial Process Equipment. Equipment for which there are no other promulgated performance standards are subject to the opacity and PM limits in this rule. The units were constructed after July 9, 1969.

EQUI 7 and EQUI 11 - Main and WWTP Emergency RICEs

40 CFR pt. 63, subp. ZZZZ

NESHAP for Stationary RICEs · The facility is an area source of HAPs; · The units are stationary emergency RICEs; · Construction of the units was before June 12, 2006; · EQUI 7 is Compression Ignition (CI), 250 horsepower, with

a displacement of 2.2 liters per cylinder; and · EQUI 11 is CI, 102 horsepower, with a displacement of 1

liter per cylinder. Minn. R. 7011.2300 Standards of Performance for Stationary Internal Combustion

Engines. Fuel limited to ultra-low sulfur diesel only.

EQUI 12 and 13 (COMG 2) - Fluidized Bed Dryers

Minn. R. 7011.0715 Standards of Performance for Post-1969 Industrial Process Equipment. Equipment for which there are no other promulgated performance standards are subject to the opacity and PM limits in this rule. The units were constructed after July 9, 1969.

Minn. R. 7007.0800, Minn. Stat. 116

Ambient Air Quality Standards: The facility previously conducted PM10 dispersion modeling. PM10 parameter used in the modeling added as an emission factor performance test requirement on COMG 2.


Subject item* Applicable regulations Rationale TREA 1 - Wet Scrubber

Minn. R. 7011.0070-0080 Standards of Performance for Listed Control Equipment and Control Equipment Efficiencies · The unit is a listed control equipment that does not have a

different control efficiency specified by a part 70, state, or general permit.

*Location of the requirement in the permit (e.g., EQUI 1, STRU 2, etc.).

3. Technical information 3.1 Calculations of potential to emit (PTE)

Attachment 1 to this TSD contains PTE calculations of the facility, which contain detailed spreadsheets and supporting information prepared by the MPCA and the Permittee. The PTE calculations have been updated since the previous permit issuance. Emission equations, rates, and known physical properties are generally based on AP-42, as well as previous equipment performance tests and 2010 NAAQS modeling. Control efficiencies stated in the permit were added for the control equipment TREA 1 and 2. 3.1.1 Sulfur Dioxide (SO2) Limit

By burning fuel oil no. 6, EQUI 1 has the potential to emit more than 250 tpy SO2. To avoid being classified as a major source under 40 CFR § 52.21, permit action 07300016-002 limited EQUI 1 SO2 emissions to 240 tpy. Current MPCA practice is to set limits at 90% of a major source threshold; here that would calculate to a 225 tpy limit. Rather than decreasing the limit to 225 tpy, the 240 tpy SO2 limit was continued in this permit action. It is acceptable for the following reasons:

· The facility only has a few insignificant activities and none of them emit significant SO2 emissions; · The facility’s actual emissions have routinely been significantly below the limit, e.g., 2016 SO2

emissions were 0.02% of the limit (see Table 3); · The facility’s method of calculating its SO2 PTE (sulfur content of fuel oil) is reliable; and · The facility has not submitted many insignificant modifications over the life of its air permits, so it

is not likely to lose track of its SO2 PTE.

3.1.2 STRU 4 and 8 (Stacks for Atomizer and Fluidized Bed Dryers and Cyclones) PM emission factors were updated from generic IPER limits to a process-specific AP-42 emission factor for whey drying. The emission factor calculated similar potential emissions to past performance tests, but a few performance tests at the facility demonstrated emissions higher than PTE calculated with the AP-42 emission factor, so a safety factor of 1.5 was applied to calculations for PM PTE from the dryers. In the 2010 NAAQS modeling, the same AP-42 emission factor as above was used to calculate the PM10 emission rates to STRU 4 and 8. The PM10 emission factors from the 2010 NAAQS modeling were used in the PTE calculations for STRU 4 and 8. Some past performance tests demonstrated PM10 emissions higher than the PTE calculated with the AP-42 emission factor, so PM10 emission factor performance testing was added to the permit at EQUI 3 and COMG 2 (STRU 4 and 8, see Section 3.2 and 3.4 for details). PM2.5 emission factors were assumed to be equal to the PM10 emission factors. No emission factors were included for the cyclones (EQUI 9, 14, 15, 16, and 17) because they are not emission units. Rather, they are inherent process equipment for product recovery. All the product collected by the cyclones is returned to the dryers to minimize product loss out of STRU 4 and 8. Equipment characterized as inherent process equipment does not generate emissions on its own.

3.1.3 EQUI 5 (Surge Bin, emits to STRU 7) To calculate PM, PM10, and PM2.5 emissions from EQUI 5, the formula for fugitive dust from AP-42 Chapter 13.2.4 was used. All assumptions are detailed in Attachment 1.


3.2 Dispersion modeling Per MPCA policy, as permitted in the reissuance Part 70 permit 07300016-003, the facility triggered the requirement to complete air dispersion modeling to show modeled compliance with the PM10 NAAQS. The modeling was completed in 2010 and demonstrated compliance with the NAAQS at that time. Table 6 presents a summary of the PM10 dispersion modeling results in comparison to the applicable standards. Table 6. Dispersion Modeling Results Summary

Pollutant Metric Year Modeled Impact (µg/m3) C 2010 NAAQS (µg/m3) Percent of Standard

PM10 24-hour A

2010 99.01 150 66.0% Annual B 33.34 50 66.7%

A 24-hour impacts are based on the highest-sixth-high concentration over 5 modeled years. B Annual impacts are based in the highest-first-high concentration of each modeled year. C Background sources concentrations were 37 µg/m3 (for the 24-hour metric) and 23 µg/m3 (for the annual metric). Both background concentrations are included in the modeled results. Past performance tests at STRU 4 and 8 demonstrated that PM10 has been emitted at a rate higher than the AP-42 emission factors used in the 2010 NAAQS modeling. Accordingly, emission factor performance test requirements were incorporated in this pt. 70 reissuance permit to serve as verification of the PM10 emission factor at STRU 4 and 8 (EQUI 3 and COMG 2). See Section 3.4 for details. Per MPCA practice, a table of the modeled parameters has been added to the permit as Appendix B. Other than the STRU 4 and 8 emission rates mentioned above, the parameters listed in Appendix B of the permit describe the operation of the facility at maximum capacity. In other words, the flow rates and temperatures listed in Appendix B represent the minimum parameters at the maximum emission rates. The MPCA does not require any specific compliance demonstration with these parameters because they are worse-case conditions. The purpose of listing the parameters in the permit appendix is to provide a benchmark for determining if and when additional modeling is required. Further modeling requirements are based on how close the modeled impacts are to the NAAQS. Additional modeling requirements are based on whether a proposed change would result in an emissions increase that would require a permit amendment. The modeling results above only require parameter documentation, no re-modeling. A requirement to submit updated dispersion modeling information for PM10, SO2, and NOx was included in the reissuance permit because PM10 was previously modeled and the SO2 and NOx PTE were over 100 tpy but the actuals were under modeling thresholds of 250 and 1000 tpy, respectively.

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

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

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


Table 7 summarizes the monitoring requirements. Table 7. Monitoring

Subject Item* Requirement (basis)

What is the monitoring? Why is this monitoring adequate?

EQUI 1 - Nebraska Boiler

SO2 <= 240 tpy calculated on a 12-month rolling sum basis. (Title I Condition: Avoid major source under 40 CFR § 52.21(b)(1)(i) and Minn. R. 7007.3000)

Calculate, record, and monitor monthly fuel usage and fuel oil sulfur content. Calculate, record, and monitor monthly and 12-mo. rolling sum SO2 emissions (using fuel oil sulfur content).

Required routine monitoring confirms that the boiler is not approaching its SO2 limit. Actual SO2 emissions from EQUI 1 in 2016 were 0.02% of the applicable limit. As long as natural gas continues to be used as the primary fuel source, it is unlikely that the limit will be exceeded.

PM <= 0.4 lb/MMBtu heat input. Opacity <= 20% (Minn. R. 7011.0515)

Recordkeeping: monthly fuel usage.

Potential PM emissions are 0.083 lb/MMBtu (~20% of the applicable limit) when burning fuel oil and 0.0075 lb/MMBtu (<2% of the limit) when burning natural gas.

EQUI 2 - Cleaver-Brooks Boiler

PM <= 0.4 lb/MMBtu heat input Opacity <= 20% (Minn. R. 7011.0515)

Record and maintain records of quantity of fuel combusted on a monthly basis.

Per 40 CFR § 60.48c(g)(2), monthly (instead of daily) fuel usage records required for NSPS Dc boilers burning gaseous fuels. Potential PM emissions are less than 2% of the limit when burning natural gas or propane, so EQUI 2 is highly unlikely to exceed opacity or PM limits.

EQUI 3 - Atomizer dryer

Process Throughput <= 7,670 lb/hr on a 24-hr block average. (Minn. R. 7017.2025, subp. 3)

Calculate, record, and monitor the total quantity of dried whey produced on a 24-hr basis.

The process throughput limit is measured as dried whey (less than or equal to 5% moisture) collected. The throughput is not tracked hourly because the facility does not have a whey flowmeter; they track throughput by weighing the whey at the end of batches that can take several hours to finish.

PM <= 0.30 gr/dscf or less stringent of Minn. R. 7011.0730 or 0735. Opacity <= 20% (Minn. R. 7011.0610, subp. 1(A))

PM performance testing every 36 months.

EQUI 3 fuel is limited to natural gas or propane; therefore, the likelihood of violating either of the emission limits due to combustion is very small. Performance testing is required every 36 months to ensure that the facility can demonstrate compliance with permit conditions.




PM10 emission factor <= 5.94 lb/hr (Minn. R. 7007.0800, Minn. Stat. 116)

PM10 initial emission factor performance testing and every 12, 36, or 60 months thereafter.

Initial performance testing is required by 9/17/2018. Within 60 days of the test, the Permittee will submit a test frequency plan specifying future performances test intervals to ensure that the facility can demonstrate compliance with the emission factor.

EQUI 5 - Surge Bin

PM <= 0.30 gr/dscf or less stringent of Minn. R. 7011.0730 or 0735. Opacity <= 20%. (Minn. R. 7011.0715, subp. 1)

TREA 2 monitoring and check STRU 7 for visible emissions once per day when in operation.

If visible emissions are observed out of STRU 7 or if the TREA 2 pressure drop is outside the required operating range, corrective actions will begin shortly thereafter. EQUI 5 receives product from EQUI 9 (fluidized bed dryers’ cyclone) only. The production limit that applies to EQUI 3 indirectly applies to this unit, and similarly limits its emissions. TREA 2 also limits emissions out of STRU 7.

EQUI 7 and EQUI 11 - Main and WWTP Emergency RICEs

Opacity <= 20% SO2 <= 0.0015 lb/MMBtu heat input (Minn. R. 7011.2300)

Record fuel type and usage on a monthly basis. Maintain a fuel supplier certification for each shipment of diesel fuel.

Using ultra-low sulfur diesel (meeting the requirements of 40 CFR § 80.510(c)), both generators have a PTE for SO2 below the limit.

EQUI 9 - Secondary Cyclone



Performance testing is required every 60 months to ensure that the facility can demonstrate compliance with permit conditions. EQUI 9 receives product from EQUI 12 and 13 (fluidized bed dryers) only. The production limit that applies to EQUI 3 (the atomizer dryer) indirectly applies to this unit, and similarly limits its emissions. TREA 1 also limits emissions out of EQUI 9.

EQUI 12 and 13 (COMG 2) - Fluidized bed dryers



Performance testing is required every 60 months to ensure that the facility can demonstrate compliance with permit conditions. EQUI 12 and 13 receive product from EQUI 14, 15, 16, and 17 (atomizer dryer’s cyclones) only. The production limit that applies to EQUI 3 (the atomizer dryer) indirectly applies to these units, and similarly limits their emissions. TREA 1 also limits emissions out of EQUI 9, which EQUI 12 and 13 send all their emissions to.

PM10 emission factor <= 6.07 lb/hr (Minn. R. 7007.0800, Minn. Stat. 116)

PM10 initial emission factor performance testing and every 12, 36, or 60 months thereafter.

Initial performance testing is required by 10/15/2018. Within 60 days of the test, the Permittee will submit a test frequency plan specifying future performances test intervals to ensure that the facility can demonstrate compliance with the emission factor.




EQUI 14, 15, 16, and 17 (COMG 1) - Primary Product Collection Cyclones

PM <= 0.30 gr/dscf or less stringent of Minn. R. 7011.0730 or 0735. Opacity <= 20% (Minn. R. 7011.0610, subp. 1(A))


Performance testing is required every 36 months to ensure that the facility can demonstrate compliance with permit conditions. EQUI 14, 15, 16, and 17 receive product from EQUI 3 (atomizer dryer) only. The production limit that applies to EQUI 3 indirectly applies to these units, and similarly limits their emissions.

TREA 1 - Wet Scrubber

Water flow rate >= 1.5 gal/min Pressure Drop >= 0.5 and <= 6.0 inWC. (Minn. R. 7011.0075) Control efficiency for PM >= 94% Control efficiency for PM10 and PM2.5 >= 84% (Minn. R. 7011. 0070, subp. 1)

Monitor and record TREA 1 water flow rate and pressure drop once per day when in operation.

If either parameter is outside the required operating range, corrective actions will begin as soon as possible.

TREA 2 - Fabric Filter

Pressure Drop >= 1.0 & <= 8.0 inWC. (Minn. R. 7007.0800, subp. 14) Control efficiency for PM and PM10 >= 99% Control efficiency for PM2.5 >= 93% (Minn. R. 7007.0800, subp. 14)

Record the pressure drop and check for visible emissions once per day when in operation.

If the pressure drop is outside the required operating range or if visible emissions are observed out of STRU 7, corrective actions will begin as soon as possible.

*Location of the requirement in the permit (e.g., EQUI 1, STRU 2, etc.).

3.4 Performance Testing Requirements Previous permits required PM performance testing and set the performance test frequency at specific intervals. Table 8 contains the dates of the performance tests performed since 2003, the average whey production rates the tests were performed at, results from the testing, PM limits, the test results as a percentage of the limits, and whether each performance test was in compliance or not. Results from tests performed prior to the last reissuance are included below for reference, since they were not included in the last reissuance.


Table 8. PM Performance Test Results

Emission Unit Test Date

Production Rate

Test Result Limit A

% of Limit

Test Result Limit B

% of Limit

Test compliant? C

Units à lb/hr gr/dscf % lb/hr % Y or N

STRU 4 (Atomizer Dryer Stack)

15 Oct 2003 7720 0.068 0.056 121 -- -- -- N 31 Mar 2005 D 6374 D 0.021 0.060 35 6.26 7.37 85 Y 13 Oct 2005 6987 0.010 0.058 17 3.07 7.80 39 Y 8 Oct 2008 7670 0.010 0.056 18 3.53 8.26 43 Y 5 Oct 2011 8262 0.015 0.056 27 5.27 8.65 61 Y

25 Jun 2015 8287 0.059 0.057 104 20.1 8.67 231 N 17 Sep 2015 7944 0.018 0.057 32 6.02 8.44 71 Y

STRU 8 (Fluidized Bed Dryers Stack)

15 Oct 2003 7939 -- -- -- 0.67 8.44 1 Y

8 Oct 2008 7832 0.078 0.091 86 6.16 8.37 74 Y

10 Oct 2013 7578 0.004 0.084 4.8 0.406 8.53 4.8 Y A Limit calculated using average source gas volume (dscfm) on each test date and the equation in Minn. R. 7011.0735. B Limit calculated using average process weight rate (lb/hr) on each test date and the equation in Minn. R. 7011.0730. C The Permittee is required to comply with the less stringent limit of Minn. R. 7011.0735 or 7011.0730. D Two production rates were used on this test date. The lower production rate generated more emissions, so it is listed here with its results. The higher production rate of 6,892 lb/hr was also below the limits. The results of recent PM performance tests were reviewed to inform this permit action. As described in footnote C to Table 8, each EQUI venting to STRU 4 and 8 is required to comply with a limit that has units of either gr/dscf or lb/hr. Historically, compliance with IPER at the facility has been determined by the gr/dscf limit and test result. Similarly, the PM performance test interval for each EQUI is determined based on the gr/dscf results as a percentage of the limits. The PM performance test interval for COMG 2 (STRU 8) will continue at 60-month intervals. The most recent test result for EQUI 3 (STRU 4) was less than 60% of the gr/dscf limit (which would normally produce a 60-month test frequency); however, because it was not in compliance during its initial 2015 performance test, EQUI 3 (STRU 4)’s PM performance tests will continue at 36-month intervals. This is to provide MPCA with a reasonable assurance that the facility can demonstrate compliance with permit conditions. In performance tests prior to 2011, the Permittee tested dry + Method 202 wet catch (PM10) and dry + organic wet catch (PM) and reported both results to MPCA. Table 9 contains the dates of past performance tests that also reported PM10 results, the average whey production rates the tests were performed at, results from the testing, the PM10 emission factors used in the 2010 modeling and the PTE, and the test results as a percentage of the emission factor. Table 9. PM10 Performance Test Results

Emission Unit

Test Date

Production Rate (lb/hr)

Test Result (lb/hr)

Emission Factor A (lb/hr)

% of Emission Factor

Would test be in compliance? B

STRU 4 (Atomizer Dryer Stack)

31 Mar 2005 C 6374 C 6.45 5.94

109 N 13 Oct 2005 6987 3.23 54 Y 8 Oct 2008 7670 3.601 61 Y

STRU 8 (Fluidized Bed Dryers Stack)

15 Oct 2003 7939 0.068 6.07

1 Y

8 Oct 2008 7832 6.23 103 N A Emission factors taken from 2010 NAAQS modeling. See Section 3.2 for details.


B Starting with this permit action, the EQUI must comply with the listed emission factors. Past performance tests were reviewed to see if the emission factors were reasonable. C Two production rates were used on this test date. The lower production rate generated more emissions, so it is listed here with its results. The higher production rate of 6,892 lb/hr was also below the limits. PM10 test results from STRU 4 and STRU 8 varied from 1% to >100% of the AP-42 emission factors used in the 2010 modeling and in PTE calculations. To verify the accuracy of the AP-42 emission factors, emission factor performance tests were added as a requirement to EQUI 3 and COMG 2 (STRU 4 and 8). After the initial PM10 emission factor tests (due by 9/17/2018 and 10/15/2018) the Permittee will develop test frequency plans for PM10 at EQUI 3 and COMG 2 to propose routine performance test frequencies. This will provide MPCA with a reasonable assurance that the facility can demonstrate compliance with PM10 permit conditions. As shown in Tables 8 and 9, the lower production rate of the 2008 performance tests is the most recent compliant production rate for both the PM IPER limits and the new PM10 emission factors. Therefore, the production rate limit on EQUI 3 was changed to 7,670 lb whey/hr 24-hr block average. The past weekly block average was changed to a daily block average to provide more reasonable assurance that the facility is demonstrating compliance with the permit conditions.

3.5 Insignificant activities Bluegrass Proteins has several operations which are classified as insignificant activities under the MPCA’s permitting rules. These are listed in Appendix A to the permit. The permit is required to include periodic monitoring for all emissions units, including insignificant activities, per EPA guidance. The insignificant activities at this facility are only subject to general applicable requirements. Using the criteria outlined earlier in this TSD, Table 10 documents the justification why no additional periodic monitoring is necessary for the current insignificant activities. See Attachment 1 of this TSD for PTE information for some of the insignificant activities. Table 10. Insignificant activities

Insignificant activity General applicable emission limit Discussion

Emissions from a laboratory, as defined in Minn. R. 7007.1300, subp. 3(G)

PM, variable depending on airflow Opacity <= 20% (Minn. R. 7011.0715)

These are small, intermittent operations that typically do not have any emissions. It is highly unlikely that they could violate the applicable requirements. No monitoring warranted.

Brazing, soldering or welding equipment


These are small, intermittent operations that typically do not have any emissions. It is highly unlikely that they could violate the applicable requirements. In addition, these units are operated and vented inside a building, so testing for PM or opacity is not feasible.

Individual units with potential emissions less than 2000 lb/year of certain pollutants


There is 1 wastewater treatment plant. Based on the EPA published emission factor, it is highly unlikely that the unit could violate the applicable requirements. See PTE calculations for justification of emissions < 2,000 lb/yr. No monitoring warranted.

Fugitive dust emissions from unpaved entrance roads and parking lots

Requirement to take reasonable measures to prevent PM from becoming airborne (Minn. R. 7011.0150)

The facility has paved parking lots and few private roads. Nearly all surfaces are currently paved. There is minimal vehicle traffic on unpaved roads. No monitoring warranted.


3.6 Permit organization In this permit, federal requirements from NESHAP and NSPS are included in two different formats. The requirements for 40 CFR pt. 60, subp. Dc, are incorporated into the permit as individual permit requirements, which has historically been MPCA’s standard practice. However, 40 CFR pt. 63, subp. ZZZZ and subp. A are included in a different way. For these rules, requirements in Section 5 of the permit list the citations of all of the applicable parts of the standards along with a reference to the permit appendix where the full text of each standard is included. 40 CFR pt. 63, subp. ZZZZ, is included in Appendix C to the permit, and 40 CFR pt. 63, subp. A, is included in Appendix D. The only item that deviates from MPCA Tempo Guidance is the listing of certain applicable requirements at the group level even though they apply at the individual unit. For example: IPER is listed at COMG 1 and 2. In general, limits that apply to individual pieces of equipment should be tracked at the unit level and should not be listed at a group. The main reason is if there were noncompliance with a limit by one unit within the group, the computer system would say the whole group was out of compliance. For this case, it is standard procedure that EQUI 14, 15, 16, and 17 always operate together, never just two or three cyclones, so if one is out of compliance, it’s likely that all four are. This is also the case with EQUI 12 and 13. Therefore, it is highly unlikely that the MPCA would need to track noncompliance with these requirements at the individual unit level, so the permit team decided that a group was an acceptable way to include these requirements.

3.7 Comments received This Section will be completed after the referenced review periods.

4. Permit fee assessment This permit action is the reissuance of an individual Part 70; therefore, no application fees apply under Minn. R. 7002.0016, subp. 1. Incorporating a new NESHAP is not a chargeable activity (i.e., the standard was not triggered by the permit application – it falls under a permit reopening being incorporated in the reissuance).

5. Conclusion Based on the information provided by Bluegrass Proteins the MPCA has reasonable assurance that the proposed operation of the emission facility, as described in the Air Emission Permit No. 07300016-101 and this TSD, will not cause or contribute to a violation of applicable federal regulations and Minnesota Rules. Staff members on permit team: Laura Lyons (permit engineer)

Adriane Lorsung (peer reviewer) Janine Noggle (enforcement) Curtis Stock (stack testing) Beckie Olson (permit writing assistant) Laurie O’Brien (administrative support)

TEMPO360 Activities: Part 70 Reissuance (IND20100001)

Attachments: 1. PTE summary calculation spreadsheets 2. Subject item inventory and facility requirements 3. PM10 Modeling Results report

ATTACHMENT 1:

Emissions Summary Calculation Spreadsheets

EQUI 1 (Nebraska Boiler, formerly EU001)

Boiler Rating: 60 MMbtu/hr

Residual #6 Fuel Oil 1% sulfur (FO) Natural Gas (NG)#6 FO: 150 MMbtu/103-gal Natural Gas: 1,020 btu/scf#6 FO: 0.400 103-gal/hrSulfur: 1 %

lb/103-gal lb/MMbtu lb/hr tpy lb/106-scf lb/MMbtu lb/hr tpyPMA 12.4 0.083 4.96 22 PMJ 7.6 0.0075 0.45 2.0

PM10B 12.2 0.081 4.87 21 PM10 7.6 0.0075 0.45 2.0PM2.5C 7.0 0.046 2.783 12.2 PM2.5K 0.0020 0.12 0.53

NOxA 55 0.37 22 96 NOxL 100 0.0980 5.88 26SO2A 157 1.05 62.8 275 SO2J 0.6 0.0006 0.04 0.15COA 5 0.033 2 8.8 COL 84 0.082 4.9 22

VOCD 0.28 0.0019 0.11 0.49 VOCJ 5.5 0.005 0.3 1.4CO2

E 24,400 163 9,760 42,749 CO2J 120,000 118 7,059 30,918

CH4D 1.0 0.01 0.40 1.8 CH4

J 2.3 0.00 0.14 0.59N2O

F 0.53 0.00 0.21 0.93 N2OJ 2.2 0.00 0.13 0.57

CO2eG 24,583 164 9,833 43,069 CO2e

G 120,713 118 7,101 31,101AmmoniaH 0.8 0.005 0.32 1.4 AmmoniaM 3.2 0.003 0.19 0.82

LeadI 0.0015 0.0000 0.0006 0.0026 LeadJ 0.0005 0.0000 0.0000 0.0001

Maximum Fuel Usage Example Calculations:FactorFO (lb/MMbtu) = (lb/103-gal)/(MMBtu/103-gal)

SO2 Limit: 240 tpy FactorNG (lb/MMbtu) = (lb/106-scf)*(106-scf/106 scf)

480,000 lb/yrPTE (lb/hr) = Factor (lb/MMbtu) * Boiler Rating (MMbtu/hr)

#6 FO (1% S): 7,642.7 hr/yearNG Balance: 1,117.3 hr/year Solver function used to cap SO2 emissions at 240 tpy with combined FO and NG emissions

Fuel lb/hr tpy Example Calculations:PM FO/NG* 4.4 19 PTE* = ((FO hr/yr)*(FO lb/hr) + (NG hr/yr)*(NG lb/hr))/2000

PM10 FO/NG* 4.3 19PM2.5 FO/NG* 2.4 10.7NOx FO/NG* 20 87SO2 FO/NG* 55 240CO NG 4.9 22

VOC NG 0.32 1.4CO2e FO/NG* 9,485 41,543CO2 FO/NG* 9,415 41,240

Ammonia FO/NG* 0.30 1.3Lead FO/NG* 0.0005 0.0023

Single HAP FO 0.013 0.058All HAPs FO 0.03 0.13

Emission Factor Boiler #1 PTE Emission Factor Boiler #1 PTE

* Based on the maximum amount of FO while staying below the 240 tpy SO2 limit, with the remainder NG. The pollutants that have a higher PTE from burning NG assumed NG was burned 100% of the year.

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PTE

(Limit taken to avoid being major for PSD) (btu/scf)*(106 btu/MMBtu)

Potential to Emit, Permit Number: 07300016-101 Page 1 of 14

EQUI 1 (Nebraska Boiler, formerly EU001, continued)

Hazardous Air Pollutants from Residual Oil/Natural Gas Combustion, whichever is larger

Boiler #1 HAP PTElb/mgal lb/106-scf lb/hr tpy

AntimonyI 5.25E-03 2.E-03 9.2E-03ArsenicI 1.32E-03 5.E-04 2.3E-03BerylliumI 2.78E-05 1.E-05 4.9E-05BenzeneN 2.1.E-03 1.E-04 5.4E-04CadmiumI 3.98E-04 2.E-04 7.0E-04CobaltI 6.02E-03 2.E-03 1.1E-02ChromiumI 8.45E-04 3.E-04 1.5E-03EthylbenzeneO 6.36E-05 3.E-05 1.1E-04FormaldehydeO 3.30E-02 1.E-02 5.8E-02 < highest single HAPMercuryI 1.13E-04 5.E-05 2.0E-04NaphthaleneO 1.13E-03 5.E-04 2.0E-03NickelI 8.45E-03 3.E-03 1.5E-02TolueneO 6.20E-03 2.E-03 1.1E-02o-XylenesO 1.09E-04 4.E-05 1.9E-04PhosphorusI 9.46E-03 4.E-03 1.7E-02POMI 1.30E-03 5.E-04 2.3E-03SeleniumI 6.83E-04 3.E-04 1.2E-03

A Factors for PM, NOx, SO2, CO from fuel oil combustion are from AP42 table; 1.3-1, S=1B Factor for PM10 is from AP42 table 1.3-5; 7.17(1.12S + 0.37); added 1.5 for cushion and to match 2010 model parametersC Factor for PM2.5 is from AP42 table 1.3-5; 4.67(1.12S + 0.37) = PM2.5D Factors for VOC and CH4 from fuel oil combustion are from AP42 table 1.3-3E Factor for CO2 from fuel oil combustion is from AP42 table 1.3-12F Factor for N2O from fuel oil combustion is from AP42 table 1.3-8G CO2e calculated with equation: CO2+CH4*global warming potential(GWP)+N2O*GWP. GWPs Source: 40 CFR pt. 98, table A-1H Factor for Ammonia from fuel oil combustion is from Illinois EPA Common Boiler Emission FactorsI Factors for HAP metals from fuel oil combustion are from AP42 table 1.3-11J Factors for PM, SO2, VOC, CO2, CH4, N2O, and lead from natural gas combustion are from AP42 table 1.4-2K Source:

L Factors for NOx and CO from natural gas combustion are from AP42 table 1.4-1M Factor for Ammonia is from "Development and Selection of Ammonia Emission Factors-Final" Battye, et al., August, 1994N Factor for Benzene from natural gas combustion is from AP42 table 1.4-3O Factors for ethylbenzene, formaldehyde, naphthalene, toluene, & o-Xylenes from fuel oil combustion are from AP42 table 1.3-9

PM2.5 Speciation Profiles and Emission Factors from Petroleum Industry Gas-Fired Sources, Wien & England, GE Energy & Environmental Research - Figure 3 for steam generator. Highest of three runs used.

Emission Factor


EQUI 2 (Cleaver-Brooks Boiler, formerly EU002)

Boiler Rating: 74 MMbtu/hr

Propane (Pr) Natural Gas (NG)PropaneA: 91.5 MMbtu/103-gal Natural Gas: 1,020 btu/scf

lb/103-gal lb/MMbtu lb/hr tpy lb/106-scf lb/MMbtu lb/hr tpyPMB 0.7 0.0077 0.57 2.5 PME 7.6 0.0075 0.55 2.4

PM10C 0.7 0.0077 0.57 2.5 PM10C 7.6 0.0075 0.55 2.4PM2.5C 0.7 0.0077 0.57 2.5 PM2.5F 0.0020 0.15 0.65

NOxB 13 0.14 11 46 NOxG 100 0.0980 7.25 32SO2B 0.10 0.0011 0.08 0.35 SO2E 0.6 0.0006 0.04 0.19COB 7.5 0.082 6.1 27 COG 84 0.082 6.1 27

VOCB 1.0 0.011 0.81 3.5 VOCE 5.5 0.005 0.40 1.7CO2

B 12,500 137 10,109 44,279 CO2E 120,000 118 8,706 38,132

CH4B 0.20 0.00 0.16 0.71 CH4

E 2.3 0.00 0.17 0.73N2O

B 0.90 0.01 0.73 3.2 N2OE 2.2 0.00 0.16 0.70

CO2eD 12,773 139.60 10,330 45,246 CO2e

D 120,713 118 8,758 38,358AmmoniaH 3.2 0.003 0.23 1.0

Example Calculations:Fuel lb/hr tpy FactorPR (lb/MMbtu) = (lb/103-gal)/(MMBtu/103-gal)

PM Pr 0.57 2.5 FactorNG (lb/MMbtu) = (lb/106-scf)*(106-scf/106 scf)PM10 Pr 0.57 2.5PM2.5 Pr 0.57 2.5 PTE (lb/hr) = Factor (lb/MMbtu) * Boiler Rating (MMbtu/hr)NOx Pr 11 46SO2 Pr 0.08 0.35CO NG 6.1 27

VOC Pr 0.81 3.5CO2e Pr 10,330 45,246

Ammonia NG 0.23 1.0Lead NG 0.00004 0.00016

Single HAP NG 0.0054 0.024All HAPs NG 0.0063 0.028

PTE

Emission Factor Boiler #1 PTE Emission Factor Boiler #1 PTE

(btu/scf)*(106 btu/MMBtu)

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EQUI 2 (Cleaver-Brooks Boiler, formerly EU002, continued)

Hazardous Air Pollutants from Natural Gas Combustion I

Boiler #1 HAP PTElb/106-scf lb/MMbtu lb/hr tpy

ArsenicJ 2.0.E-04 2.0E-07 1.E-05 6.4E-05BerylliumJ 1.2.E-05 1.2E-08 9.E-07 3.8E-06BenzeneK 2.1.E-03 2.1E-06 2.E-04 6.7E-04CadmiumJ 1.1.E-03 1.1E-06 8.E-05 3.5E-04CobaltJ 8.4.E-05 8.2E-08 6.E-06 2.7E-05ChromiumJ 1.4.E-03 1.4E-06 1.E-04 4.4E-04FormaldehydeK 7.5.E-02 7.4E-05 5.E-03 2.4E-02 < highest single HAPLeadE 5.0.E-04 4.9E-07 4.E-05 1.6E-04MercuryJ 2.6.E-04 2.5E-07 2.E-05 8.3E-05NaphthaleneK 6.1.E-04 6.0E-07 4.E-05 1.9E-04NickelJ 2.1.E-03 2.1E-06 2.E-04 6.7E-04SeleniumJ 2.4.E-05 2.4E-08 2.E-06 7.6E-06TolueneK 3.4.E-03 3.3E-06 2.E-04 1.1E-03

A Heating value of propane from AP42 Section 1.5.3.1B Factors for PM, NOx, SO2, CO, VOC, CO2, CH4, and N2O from propane combustion are from AP42 table 1.5-1C Assume PM10, PM2.5 = PMD CO2e calculated with equation: CO2+CH4*GWP+N2O*GWP. GWPs Source: 40 CFR pt. 98, table A-1E Factors for PM, SO2, VOC, CO2, CH4, N2O, and lead from natural gas combustion are from AP42 table 1.4-2F Source:

G Factors for NOx and CO from natural gas combustion are from AP42 table 1.4-1H Factor for Ammonia is from "Development and Selection of Ammonia Emission Factors-Final" Battye, et al., August, 1994I AP-42 Section 1.5 (Propane combustion) does not contain HAP emission factors for propane combustionJ Factors for metals from natural gas combustion are from AP42 table 1.4-4K Factors for benzene, formeldahyde, naphthalene, and toluene from natural gas combustion is from AP42 table 1.4-3

PM2.5 Speciation Profiles and Emission Factors from Petroleum Industry Gas-Fired Sources, Wien & England, GE Energy & Environmental Research - Figure 3 for steam generator. Highest of three runs used.

Emission Factor


EQUI 5 (Surge Bin, formerly EU008)

Production Limit A: 7,670 lbs dried whey/hr3.84 tons dried whey/hr

PM emission factors calculated using the formula B: k(0.0032)(U/5)^1.3 (M/2)^1.4

where: U (wind speed)= 0.1 mphM (moisture)= 5 %

TREA 2: Fabric FilterCaptured PTE (controlled)

kC lb/ton lb/hr tpy tpy tpyPM 0.74 0.0000041 0.031 0.14 0.14 0.0014

PM10 0.35 0.0000019 0.000007 0.000032 0.000032 0.00000032PM2.5 0.053 0.0000003 0.000001 0.0000049 93% 0.0000045 0.00000034

Uncontrolled tpy tpy lb/hr

PM 0.14 0.0014 0.00031PM10 0.000032 0.00000032 7.4E-08PM2.5 0.0000049 0.00000034 7.8E-08

A Permitted process throughput limit on EQUI 3 (indirectly applies to EQUI 5)B AP42 13.2.4, equation 1C k factors for PM, PM10, and PM2.5 are from AP42 13.2.4 pg 4D Minimum control efficiencies set in permit

Emission Factor Control EfficiencyD

99%

PTE (uncontrolled)

PTEControlled


EQUI 7 and EQUI 11 (Reciprocating Internal Combustion Engines (RICE))

EQUI 7 (formerly EU003) EQUI 11 (lift station generator)4.3 MMBtu/hr 0.73 MMBtu/hr

Fuel: Diesel DieselUsage: 500 hr/yr 500 hr/yr

Emission Factors

TOTAL PTE

lb/MMbtu lb/hr tpy lb/hr tpy tpyPMA 0.31 1.33 0.33 0.23 0.057 0.39

PM10B 0.31 1.33 0.33 0.23 0.057 0.39

PM2.5A 0.31 1.33 0.33 0.23 0.057 0.39

NOxB 4.41 19 4.7 3.22 0.80 5.5SO2C 0.0015 0.0065 0.0016 0.0011 0.0003 0.0019COB 0.95 4.1 1.0 0.69 0.17 1.2

VOCB 0.36 1.5 0.39 0.26 0.07 0.45CO2eB 164 705 176 120 30 206

Single HAP 0.005 0.0013 0.0009 0.0002 0.001All HAPs 0.017 0.0042 0.0028 0.0007 0.005

AcetaldehydeD 7.7.E-04 3.3.E-03 8.2.E-04 5.6.E-04 1.4.E-04 9.6E-04AcroleinD 9.3.E-05 4.0.E-04 9.9.E-05 6.8.E-05 1.7.E-05 1.2E-04

1,3-ButadieneD 3.9.E-05 1.7.E-04 4.2.E-05 2.9.E-05 7.1.E-06 4.9E-05BenzeneD 9.3.E-04 4.0.E-03 1.0.E-03 6.8.E-04 1.7.E-04 1.2E-03

FormaldehydeD 1.2.E-03 5.1.E-03 1.3.E-03 8.6.E-04 2.2.E-04 1.5E-03NaphthaleneD,E 8.5.E-05 3.6.E-04 9.1.E-05 6.2.E-05 1.5.E-05 1.1E-04

Total PAHD,E 1.7.E-04 7.2.E-04 1.8.E-04 1.2.E-04 3.1.E-05 2.1E-04TolueneD 4.1.E-04 1.8.E-03 4.4.E-04 3.0.E-04 7.5.E-05 5.1E-04XylenesD 2.9.E-04 1.2.E-03 3.1.E-04 2.1.E-04 5.2.E-05 3.6E-04

Example Calculations:PTE (lb/hr) = Factor (lb/MMBtu) * Rating (MMBtu/hr)PTE (tpy) = (lb/hr)*(500 hr/yr)/(2000 lb/ton)

A Assume PM, PM2.5 = PM10B Emission factors for diesel fuel combustion in RICE from AP42 table 3.3-1C AP42 3.3: "sulfur compounds, mainly SO2, are directly related to the sulfur content of the fuel."

Fuel sulfur limit: 0.0015

D Emission factors for VOCs/HAPs from diesel combustion in RICE from AP42 table 3.3-2E PAH = Polycyclic aromatic hydrocarbons (includes naphthalene)

EQUI 7 PTE EQUI 11 PTE

Emission factor from Minn. R. 7011.2300, subp. 2(B), which is more strict than AP42 emission factor of 0.29 lb/MMBtu

< highest single HAP at the facility

Generator Rating:


STRU 4 (Atomizer Dryer and Primary Cyclones: EQUI 3, 14, 15, 16, 17)Formerly SV006 (EU006, EU010)

Dryer Rating: 12.7 MMbtu/hrEQUI 3 Propane (Pr) EQUI 3 Natural Gas (NG)

PropaneA: 91.5 MMbtu/103-gal Natural Gas: 1,020 btu/scf

lb/103-gal lb/MMbtu lb/hr tpy lb/106-scf lb/MMbtu lb/hr tpyPMB 0.7 0.008 0.097 0.43 PME 7.6 0.0075 0.095 0.41

PM10C 0.7 0.008 0.097 0.43 PM10C 7.6 0.0075 0.095 0.41PM2.5C 0.7 0.008 0.097 0.43 PM2.5F 0.0020 0.025 0.11

NOxB 13 0.14 1.8 7.9 NOxG 100 0.0980 1.25 5.5SO2B 0.10 0.0011 0.01 0.06 SO2E 0.6 0.0006 0.01 0.03COB 7.5 0.082 1.0 4.6 COG 84 0.082 1.0 4.6

VOCB 1.0 0.011 0.139 0.61 VOCE 5.5 0.005 0.1 0.30CO2

B 12,500 137 1,735 7,599 CO2E 120,000 118 1,494 6,544

CH4B 0.20 0.00 0.03 0.12 CH4

E 2.3 0.00 0.03 0.13N2O

B 0.90 0.01 0.12 0.55 N2OE 2.2 0.00 0.03 0.12

CO2eD 12,773 140 1,773 7,765 CO2e

D 120,713 118 1,503 6,583AmmoniaH 3.2 0.0031 0.0 0.17

EQUI 3,14,15,16,&17: Whey Drying I

Process Throughput: 7,670 lb whey/hrPTE STRU 4 PM10 limit: 5.94 lb/hr

lb PM/ton whey lb/hr tpy

26.0 tpy

PMJ 2.33 8.92 39.1 Max of PM10 from Pr or NG : 0.097 lb/hrPM10K 5.84 25.6PM2.5 5.84 25.6 5.84 hr/year

FuelEQUI 3 lb/hr tpy

PM Pr+Drying 9.01 39.5PM10 Pr+Drying 5.94 26.0PM2.5 Pr+Drying 5.94 26.0NOx Pr 1.8 7.9SO2 Pr 0.01 0.06CO NG 1.0 4.6

VOC Pr 0.14 0.61CO2e Pr 1,773 7,765

Ammonia NG 0.04 0.17Single HAP FO 0.0009 0.0041

All HAPs FO 0.0011 0.0047

Emission Factor Dryer PTE Emission Factor Dryer PTE

Emission Factor

PTE

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Max PM10 allowed from Whey DryingK:

(Limit derived from 2010 NAAQS PM10 modeling)


STRU 4 (Atomizer Dryer and Primary Cyclones: EQUI 3, 14, 15, 16, 17, continued)

Hazardous Air Pollutants from Natural Gas Combustion L

Boiler #1 HAP PTElb/106-scf lb/MMbtu lb/hr tpy

ArsenicM 2.0.E-04 2.0E-07 2.E-06 1.1E-05BerylliumM 1.2.E-05 1.2E-08 1.E-07 6.5E-07BenzeneN 2.1.E-03 2.1E-06 3.E-05 1.1E-04CadmiumM 1.1.E-03 1.1E-06 1.E-05 6.0E-05CobaltM 8.4.E-05 8.2E-08 1.E-06 4.6E-06ChromiumM 1.4.E-03 1.4E-06 2.E-05 7.6E-05FormaldehydeN 7.5.E-02 7.4E-05 9.E-04 4.1E-03 < highest single HAPLeadE 5.0.E-04 4.9E-07 6.E-06 2.7E-05MercuryM 2.6.E-04 2.5E-07 3.E-06 1.4E-05NaphthaleneN 6.1.E-04 6.0E-07 8.E-06 3.3E-05NickelM 2.1.E-03 2.1E-06 3.E-05 1.1E-04SeleniumM 2.4.E-05 2.4E-08 3.E-07 1.3E-06TolueneN 3.4.E-03 3.3E-06 4.E-05 1.9E-04

A Heating value of propane from AP42 Section 1.5.3.1B Factors for propane combustion PM, NOx, SO2, CO, VOC, CO2, CH4, and N2O are from AP42 table 1.5-1C Assume PM10, PM2.5 = PMD CO2e calculated with equation: CO2+CH4*GWP+N2O*GWP. GWPs Source: 40 CFR pt. 98, table A-1E Factors for natural gas combustion PM, SO2, VOC, CO2, CH4, and N2O are from AP42 table 1.4-2FG Factors for natural gas combustion NOx and CO are from AP42 table 1.4-1H Factor for Ammonia is from "Development and Selection of Ammonia Emission Factors-Final" Battye, et al., August, 1994I

J Factor for whey drying PM is from AP42 table 9.6.1-2 (added filterable and condensible PM emission rates) x 1.5 safety factorK PM10 emission rate found by subtracting max fuel PM10 emissions from PM10 limit derived from 2010 NAAQS modelingL AP-42 Section 1.5 (Propane combustion) does not contain HAP emission factors for propane combustionM Factors for metals from natural gas combustion are from AP42 table 1.4-4N Factors for benzene, formeldahyde, naphthalene, and toluene from natural gas combustion is from AP42 table 1.4-3

Emission Factor

Factor for PM2.5: Speciation Profiles & Emission Factors..., Wien & England, GE Energy & Environmental Research - Figure 3

PM/PM10/PM2.5 emissions from whey drying are not calculated individually for EQUI 14, 15, 16, and 17. The atomizer dryer (EQUI 3) vents to cyclones (EQUI 14-17), which are inherent process equipment used to capture and control the whey. Combined they have the same flow rate as EQUI 3 and no material is added into any of the cyclones that hasn't already gone through EQUI 3. Since the cyclones are inherent process equipment, not emission units, no emission factors were used for them.


STRU 8 (Fluidized Bed Dryers and Secondary Cyclone: EQUI 12, 13, 9)Formerly SV007 (EU007, EU011)

Process Throughput A: 7,670 lb whey/hr

EQUI 9,12,&13: Fluidized Whey Drying Beds B TREA 1: Wet ScrubberPTE (tpy) PTE (tpy)

lb PM/ton whey lb/hr Uncontrolled Controlled

PMD 2.33 8.92 39.1 94% 36.7 2.34PM10

E 6.07 26.6 22.3 4.25PM2.5

F 6.07 26.6 22.3 4.25

Uncontrolledtpy tpy lb/hr

PM 39.1 2.34 0.53PM10 26.6 4.25 0.97PM2.5 26.6 4.25 0.97

A Permitted process throughput limit on EQUI 3 (indirectly applies to EQUI 12, 13, and 9)B

C Minimum control efficiencies set in permit to satisfy Minn. R. 7011.0700, subp. 1.D

E PM10 emission rate set equal to PM10 limit derived from 2010 NAAQS modelingF Assume PM10 = PM2.5

ControlledPTE

PM/PM10/PM2.5 emissions from whey drying are not calculated individually for EQUI 9, 12, and 13. The fluidized bed dryers (EQUI 12 and 13) vent to a cyclone (EQUI 9), which is inherent process equipment used to capture and control the whey. All three EQUI have the same flow rate, and no material is added into EQUI 13 or 9 that hasn't already gone through EQUI 12. Since the cyclone is inherent process equipment, not an emission unit, no emission factor was used for it.

Factor for whey drying PM is from AP42 table 9.6.1-2 (added filterable and condensible PM emission rates) x 1.5 safety factor

Control Efficiency C

Captured(tpy)

Emission Factor

84%


PROCESS EQUIPMENT EMISSION RATES

Subject due to MN R. 7011.0610, subp. 1(A) Subject due to MN R. 7011.0715, subp. 1(A) Subject due to MN R. 7011.0715, subp. 1(A)Emission Point: 4 Whey Dryer & Cyclones Emission Point: 7 Surge Bin Emission Point: 8 Fluidized Bed Dryers & Cyclone

Table 1 Table 1 Table 1

Process Weight Rate A Emission Rate Process Weight Rate A Emission Rate Process Weight Rate A Emission Rate7670 lb/hr 8.26 lbs/hour 7670 lb/hr 8.26 lbs/hour 7670 lb/hr 8.26 lbs/hour

36.2 tpy 36.2 tpy 36.2 tpy

Table 2 Table 2 Table 2

Source Gas Volume B Emission Rate C Source Gas Volume D Emission Rate C Source Gas Volume E Emission Rate C

39,651 dscfm 0.057 gr/dscf 368 dscfm 0.10 gr/dscf 11,772 dscfm 0.084 gr/dscf19.4 lbs/hour 0.32 lbs/hour 8.5 lbs/hour84.9 tpy 1.4 tpy 37.3 tpy

0.057 gr/dscf 8.26 lbs/hour 0.084 gr/dscf85 tpy 36 tpy 37 tpy

A Permitted process whey throughput limit B Flow rate from 9/17/2015 STRU 4 Performance TestC Emission rate in lbs/hour uses the grain constant of 7,000 grains per poundD Flow rate converted from 366 acfm at 650F (supplied by the Permittee)E Flow rate from 10/10/2013 STRU 8 Performance Test

This section calculates allowable PM emission rates based on Minnesota Rules parts 7011.0730 (Table 1) and 7011.0735 (Table 2).

Emission Limit (based on Minn. R. 7011.0715, subp. 1(A)):




INSIGNIFICANT ACTIVITIESPer Minn. R. 7007.1300, subp. 3(I), the following qualify as insignificant activities: A

Wastewater Treatment

EF Capacitylb/106-gal 106-gal/yr lb/yr tpy

VOCB 8.9 128 1,137 0.57

A

Pollutants that satisfy Minn. R. 7007.1300, subp. 3(I) rqmts are written like this.B

Minn. R. 7007.1300, subp. 3(I): Individual emission units at a stationary source qualify as insignificant activities if each have a PTE the following pollutants in amounts less than: (1) 4,000 lb/yr of CO;(2) 2,000 lb/yr of each NOx, SO2, PM, PM10, VOCs, and O3; and (3) 1,000 tpy of CO2e.

WWTP PTE

Assumes max of 350,000 gallons treated per day. Emission factor is from EPA's Factor Information Retrieval (FIRE) Data System v.6.22


FUGITIVE Truck Traffic, 2010

E A = k(sL/2)0.65(W/3)1.5 (speed/30)0.5

Constants Summer Winter Unitsk PM10

B lb/VMTVM per truckVM per day

sL C 1.1 2.4 g/m2

lbstons

Speed mph4.607 7.650 lb/day0.192 0.319 lb/hour0.0242 0.0402 g/s

Number of TrucksE

Use this # of Trucks

Gross Weight/ truck (W)

Milk Trucks 24.0 24 81,000Condensed Whey 3.3 4 81,500Freight In 3.2 4 64,000Freight Out 8.3 9 67,050Whey Cream Out 0.3 1 54,400Total 39.1 42 75,806 Weighted Average

A Equation 1 in AP42 section 13.2.1.3 *B k values from AP42 table 13.2.1-2 *C

D W values calculated in table below.E Number of trucks based on AMPI operating history in 2009, assumed a 7-day week.

16.40.39

*AP-42 table and equation references are from Chapter 13 in December 2009. Many AP-42 equations and constants changed in 2011. See next page for updated 2017 emission factors. 2010 emission factors used in modeling were conservative.

sL values from AP42 table 13.2.1-4*. Lower end sL used because a food processing facility will be cleaner than the other industrial facilities listed. Silt values of 1.1 for summer and 2.4 for winter have been discussed with Dennis Becker (MPCA) and agreed upon.

Vehicle Mile Traveled (VMT)

W D

E

0.016

75,80637.90

10


FUGITIVE Truck Traffic, 2017

E F = k(sL)0.91(W)1.02

Summer Winter Unitsk PM10

G lb/VMTVM per truckVM per day

sL C 1.1 2.4 g/m2

lbstons

1.602 3.258 lb/day0.067 0.136 lb/hour0.0084 0.0171 g/s

Number of TrucksE Use

Gross Weight/ truck

Milk Trucks 24.0 24 81,000Condensed Whey 3.3 4 81,500Freight In 3.2 4 64,000Freight Out 8.3 9 67,050Whey Cream Out 0.3 1 54,400Total 39.1 42 75,806 Weighted Average

C

D W values calculated in table below.E Number of trucks based on AMPI operating history in 2009, assumed a 7-day weekF Equation 1 in AP42 section 13.2.1.3, dated January 2011G k values from AP42 table 13.2.1-1, dated January 2011

E

sL values from AP42 table 13.2.1-2. Lower end sL used because a food processing facility will be cleaner than the other industrial facilities listed. Silt values of 1.1 for summer and 2.4 for winter have been discussed with Dennis Becker (MPCA) and agreed upon.

VMT 0.3916.38

W D75,80637.90

0.0022


Bluegrass Proteins - Dawson

Potential to Emit - Facility Totals (tons per year)

Descriptions:Atomizer Dryer & Cyclone System Surge Bin

STRU 1 STRU 2 STRU 5 STRU 6 STRU 7EQUI 1 EQUI 2 EQUI 3,14,15,16,17 EQUI 7 EQUI 11 EQUI 5 EQUI 12,13,9SV001 SV002 SV003 SV004 SV008EU001 EU002 EU006,010 EU003 -- EU008 EU007,011

PM 19 2.5 39 0.33 0.057 0.001 2.3 0.0 64PM10 19 2.5 26 0.33 0.057 3.2E-07 4.3 0.0 52PM2.5 10.7 2.5 26 0.33 0.057 3.4E-07 4.3 0.0 44NOx 87 46 7.9 4.7 0.80 0.0 0.0 0.0 147SO2 240 0.35 0.06 0.0016 0.0003 0.0 0.0 0.0 240CO 22 27 4.6 1.0 0.17 0.0 0.0 0.0 54

VOC 1.4 3.5 0.61 0.39 0.07 0.0 0.0 0.57 6.6CO2e 41,543 45,246 7,765 176 30 0.0 0.0 0.0 94,761

single HAP 0.058 0.024 0.0041 0.0013 0.0002 0.0 0.0 0.0 0.087All HAPs 0.13 0.028 0.0047 0.0042 0.0007 0.0 0.0 0.0 0.17

Potential to Emit - Facility Totals (lb/hr)STRU 1 STRU 2 STRU 5 * STRU 6 * STRU 7EQUI 1 EQUI 2 EQUI 3,14,15,16,17 EQUI 7 EQUI 11 EQUI 5 EQUI 12,13,9

PM 4.4 0.57 9 1.3 0.23 0.000 0.53 0.0 16PM10 4.3 0.57 5.9 1.3 0.23 7.4E-08 0.97 0.0 13PM2.5 2.4 0.57 5.9 1.3 0.23 7.8E-08 0.97 0.0 11NOx 20 11 1.8 19 3.2 0.0 0.0 0.0 54SO2 55 0.08 0.01 0.0 0.00 0.0 0.0 0.0 55CO 4.9 6.1 1.0 4.1 0.69 0.0 0.0 0.0 17

VOC 0.32 0.81 0.14 1.5 0.26 0.0 0.0 0.13 3.2CO2e 9,485 10,330 1,773 705 120 0.0 0.0 0.0 22,413

single HAP 0.013 0.0054 0.0009 0.005 0.0009 0.0 0.0 0.0 0.026All HAPs 0.030 0.0063 0.0011 0.017 0.0028 0.0 0.0 0.0 0.057

* RICE (EQUI 7 and 11) lb/hr emission rates are higher than tpy PTE because they are limited to operating 500 hr/yr.

New SI:STRU 4 STRU 8

IATOTAL (lb/hr) after control

BoilersReciprocal Internal

Combustion EnginesFluidized Bed

Dryers & Cyclone

SV006 SV007IA

TOTAL (tpy) after control

New SI:

Old SI:

STRU 4 STRU 8


ATTACHMENT 2:

Subject Item Inventory and Facility Requirements

Agency Interest Name Subject Item ID SI Designation and Description

Blue Grass ProteinsWWTP

ACTV1NullAll IA's

AISI579NullNull

COMG1NullPost-Atomizer Dryer Cyclones

COMG2NullFluidized Bed Dryers

EQUI1EU001Nebraska Boiler

EQUI2EU002Cleaver-Brooks Boiler

EQUI3EU006Niro Atomizer Dryer

EQUI5EU008Surge Bin

EQUI7EU003Main Emergency Generator

EQUI9EU011Secondary Product CollectionCyclone

EQUI11NullWWTP Lift Station EmergencyGenerator

EQUI12EU007Niro Fluidized Bed Dryer (Hot)

EQUI13 EU007Niro Fluidized Bed Dryer (Cold)

List of SIs

Agency Interest: Blue Grass Proteins WWTPAgency Interest ID: 579Activity: IND20100001 (Part 70 Reissuance)

Details for:SI Category: NoneSI Type: All

Agency Interest Name Subject Item ID SI Designation and DescriptionBlue Grass ProteinsWWTP


EQUI13EU007Niro Fluidized Bed Dryer (Cold)

EQUI14EU010Primary Cyclone (1 of 4)




STRU1SV001Nebraska Boiler Stack

STRU2SV002Cleaver-Brooks Boiler Stack

STRU4SV006Atomizer Dryer Stack

STRU5SV003Main Emergency Generator Stack

STRU6SV004WWTP Lift Station EmergencyGenerator Stack

STRU7SV008Surge Bin Baghouse Stack

STRU8SV007Fluidized Bed Dryer Stack

STRU9 BG001Main Building

List of SIs



Agency Interest Name Subject Item ID SI Designation and DescriptionBlue Grass ProteinsWWTP


STRU9BG001Main Building

STRU10BG002Diesel Generator Building

TFAC107300016Bluegrass Proteins Inc

TREA1CE001Wet Scrubber-High Efficiency w/oLime

TREA2CE002Fabric Filter - Low Temperature,i.e., T<180 Degrees F

List of SIs



Agency Interest Na.. Activity ID Subject Ite..Subject Item Type Description Subject Item ID SI Designation and Description Status Desc..Sub Attribute Description


IND20100001 Activity Insignificant Air Emissions Activity ACTV1 NullAll IA's

Active /Existing

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

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

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

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

Insignificant air emissions activity


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

Agency Interest Name Subject Item ID SI Designation and Description Group Member ID (padded)


COMG1 NullPost-Atomizer Dryer Cyclones

EQUI14

EQUI15

EQUI16

EQUI17

COMG2 NullFluidized Bed Dryers

EQUI12

EQUI13

Component Group (Members)

Agency Interest: Blue Grass Proteins WWTPAgency Interest ID: 579Activity: None (Part 70 Reissuance)

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

Subject ItemCategory Description

Subject Item TypeDescription Subject Item ID

Subject ItemDesignation Subject Item Description Pollutant

Potential (lbs/hr)

Unrestricted Potential

(tons/yr)

Potential Limited

(tons/yr)

Actual Emissions

(tons/yr)

Equipment Boiler EQUI1 EU001 Nebraska Boiler Ammonia

Antimony compounds

Arsenic compounds

Benzene

Beryllium

Cadmium compounds

Carbon Dioxide

Carbon Dioxide Equivalent

Carbon Monoxide

Chromium compounds

Cobalt compounds

Ethylbenzene

Formaldehyde

HAPs - Single

HAPs - Total

Lead

Mercury

Methane

Naphthalene

Nickel compounds

Nitrogen Oxides

Nitrous Oxide

Particulate Matter

Phosphorus

PM < 2.5 micron

PM < 10 micron

Polycyclic organic matter

Selenium compounds

Sulfur Dioxide

Toluene

Volatile Organic Compoun..

Xylene (o-)

EQUI2 EU002 Cleaver-Brooks Boiler Ammonia

Arsenic compounds

Benzene

Beryllium

Cadmium compounds

Carbon Dioxide


Carbon Monoxide

Chromium compounds

Cobalt compounds

Formaldehyde

HAPs - Single

HAPs - Total

Lead

Mercury

Methane

Naphthalene

Nickel compounds

Nitrogen Oxides

Nitrous Oxide

Particulate Matter

PM < 2.5 micron

PM < 10 micron

Selenium compounds

Sulfur Dioxide

Toluene


Reciprocating IC EngineEQUI7 EU003 Main EmergencyGenerator

1,3-Butadiene

Acetaldehyde

Acrolein

Benzene


Carbon Monoxide

0.0001911.42

0.01086240

0.00120.0022818.8710.7030.0165719.20.8887.360.01480.00198

1.60.0001980.00230.1310.05780.0578

0.0001110.010550.0014821.6441,54341,240

0.0006974.87e-050.0005410.002310.00921.3

0.0001911.42

0.01086240

0.00120.0022818.8710.7030.0165719.20.8887.360.01480.00198

1.60.0001980.00230.1310.05780.0578

0.0001110.010550.0014821.6441,54341,240

0.0006974.87e-050.0005410.002310.00921.3

4.4e-050.324

0.0024854.8

0.000270.000524.3082.444

0.003784.390.2

19.940.003380.000450.37

4.5e-050.000520.02990.01320.01322.5e-050.002410.000338

4.949,484.79,415.50.0001591.1e-050.0001240.0005280.00210.3

3.540.001080.354

7.63e-062.482.482.48

3.188146.05

0.0006670.0001940.73098.26e-050.0001590.02760.02380.02382.67e-050.00044526.6945,24644,2790.000353.81e-060.0006676.36e-05

1.02

3.540.001080.354

7.63e-062.482.482.48

3.188146.05

0.0006670.0001940.73098.26e-050.0001590.02760.02380.02382.67e-050.00044526.6945,24644,2790.000353.81e-060.0006676.36e-05

1.02

0.8090.0002470.08091.74e-06

0.570.570.57

0.727910.51

0.0001524.43e-050.16691.89e-053.63e-050.00630.005440.005446.09e-060.000102

6.0910,330.210,109.37.98e-058.71e-070.0001521.45e-050.232

176.30.001

9.94e-050.0008254.2e-05

176.30.001

9.94e-050.0008254.2e-05

7050.004010.0003980.0033

0.000168

PTE by subject item

Agency Interest: NoneAgency Interest ID: 579Activity: None (Part 70 Reissuance)

Details for:SI Category: AllSI Type: All

Subject ItemCategory Description

Subject Item TypeDescription Subject Item ID

Subject ItemDesignation Subject Item Description Pollutant

Potential (lbs/hr)

Unrestricted Potential

(tons/yr)

Potential Limited

(tons/yr)

Actual Emissions

(tons/yr)

Equipment Reciprocating IC EngineEQUI7 EU003 Main EmergencyGenerator


Carbon Monoxide

Formaldehyde

HAPs - Single

HAPs - Total

Naphthalene

Nitrogen Oxides

Particulate Matter

PM < 2.5 micron

PM < 10 micron

Sulfur Dioxide

Toluene

Total Polycyclic aromatic ..


Xylenes, Total

EQUI11 Null WWTP Lift StationEmergency Generator

1,3-Butadiene

Acetaldehyde

Acrolein

Benzene


Carbon Monoxide

Formaldehyde

HAPs - Single

HAPs - Total

Naphthalene

Nitrogen Oxides

Particulate Matter

PM < 2.5 micron

PM < 10 micron

Sulfur Dioxide

Toluene

Total Polycyclic aromatic ..


Xylenes, Total

Silo/Bin EQUI5 EU008 Surge Bin Particulate Matter

PM < 2.5 micron

PM < 10 micron

Structure Stack/Vent STRU4 SV006 Atomizer Dryer Stack Ammonia

Arsenic compounds

Benzene

Beryllium

Cadmium compounds


Carbon Monoxide

Chromium compounds

Cobalt compounds

Formaldehyde

HAPs - Single

HAPs - Total

Lead

Mercury

Naphthalene

Nickel compounds

Nitrogen Oxides

Particulate Matter

PM < 2.5 micron

PM < 10 micron

Selenium compounds

Sulfur Dioxide

Toluene


STRU8 SV007 Fluidized Bed Dryer Stack Particulate Matter

PM < 2.5 micron

PM < 10 micron

0.0003060.387

0.0001810.000440.00160.3330.3330.3334.74

9.12e-050.00420.001270.001271.02

0.0003060.387

0.0001810.000440.00160.3330.3330.3334.74

9.12e-050.00420.001270.001271.02

0.001231.5

0.0007220.001760.00651.331.331.3319

0.0003650.017

0.005070.00507

4.1

5.2e-050.06573.07e-057.46e-050.0002740.05660.05660.05660.805

1.55e-050.0007

0.0002150.0002150.17329.93

0.000171.69e-050.000147.14e-06

5.2e-050.06573.07e-057.46e-050.0002740.05660.05660.05660.805

1.55e-050.0007

0.0002150.0002150.17329.93

0.000171.69e-050.000147.14e-06

0.0002080.26

0.0001230.0002990.00110.230.230.233.22

6.19e-050.0028

0.0008610.000861

0.69120

0.0006816.75e-050.000562.85e-05

3.23e-073.42e-070.00136

3.23e-054.89e-060.136

7.37e-087.81e-080.000311

0.6080.0001850.061

1.31e-06262639.57.903

0.0001153.33e-051.42e-052.73e-050.004730.004090.004094.58e-067.63e-054.5817,7656e-05

6.54e-070.0001151.09e-050.175

0.6080.0001850.061

1.31e-06262639.57.903

0.0001153.33e-051.42e-052.73e-050.004730.004090.004094.58e-067.63e-054.5817,7656e-05

6.54e-070.0001151.09e-050.175

0.1394.23e-050.014

2.29e-075.945.949.011.804

2.61e-057.6e-063.24e-066.23e-060.001080.0009340.0009341.05e-061.74e-051.0461,772

1.37e-051.49e-072.61e-052.49e-06

0.04

4.254.252.24

26.626.637.3

0.970.970.51

PTE by subject item


Details for:SI Category: AllSI Type: All

Subject ItemCategoryDescription

Subject Item TypeDescription Subject Item ID SI Designation and Description Relationship

Related SubjectItem ID % Flow

Related Subject ItemType Description

Start Date (RelatedSubject Item)

End Date (RelatedSubject Item)

Equipment Boiler EQUI1EU001Nebraska Boiler

sends to STRU1 100 Stack/Vent 8/15/2000 Null



Dryer/Oven, directfired

EQUI3EU006Niro Atomizer Dryer


Dryer/Oven,indirect fired





Reciprocating ICEngine

EQUI7EU003Main Emergency Generator


EQUI11NullWWTP Lift Station Emergency Gener..


SeparationEquipment

EQUI9 EU011Secondary Product Collection Cyclone

is controlledby

TREA1 100001-Wet Scrubber - HighEfficiency

8/15/2000 Null










Silo/Bin EQUI5 EU008Surge Bin

is controlledby

TREA2 100018-Fabric Filter - LowTemp, T<180 Degrees F

8/15/2000 Null


SI - SI relationships


Details for:SI Category: EquipmentSI Type: All

Subject ItemTypeDescription Subject Item ID SI Designation and Description Manufacturer Model

Max DesignCapacity

Max DesignCapacityUnits(numerator)

Max DesignCapacity Units(denominator) Material

ConstructionStart Date

OperationStart Date

ModificationDate

SeparationEquipment

EQUI9EU011Secondary Product Collection Cyclone

NiroNA - fieldconversion

8287 pounds hours Product 1/1/1982 1/1/1982 Null













Silo/Bin EQUI5EU008Surge Bin



Emission Units 1


Details for:SI Category: NoneSI Type: Separation Equipment & Silo/Bin

Subject Item TypeDescription Subject Item ID SI Designation and Description Manufacturer Model

Max DesignCapacity

Max DesignCapacity Units(numerator)

Max DesignCapacity Units(denominator) Material

ConstructionStart Date

OperationStart Date

ModificationDate

Boiler EQUI1EU001Nebraska Boiler

Nebraska NS-E-50 60million Britishthermal units

hours Heat 1/1/1978 6/1/1978 Null


Cleaver-Brooks 1800 HP 74million Britishthermal units

hours Heat 9/22/1997 3/23/1998 Null

Dryer/Oven, direct firedEQUI3EU006Niro Atomizer Dryer

Niro Hudson, Inc.NA- fieldconversion


Dryer/Oven, indirectfired


Niro Hudson, Inc.NA - fieldconversion



Niro Hudson, Inc.NA - fieldconversion


Reciprocating IC EngineEQUI7EU003Main Emergency Generator

Cummings KT855-G 205 kilowatts hours Energy 1/1/1978 2/1/1978 Null

EQUI11NullWWTP Lift Station Emergency Gene..

Katolight D60FRJ4CEP60 kilowatts hours Energy 10/17/1994 10/17/1994 Null

Emission Units 2


Details for:SI Category: EquipmentSI Type: Boiler, Dryer/Oven, direct fired, Dryer/Oven, indirect fired and 1 more

Subject Item TypeDescription Subject Item ID SI Designation and Description

FiringMethod Engine Use

EngineDisplacement

EngineDisplacementUnits

Subject toCSAPR?

ElectricGeneratingCapacity(MW)

Boiler EQUI1EU001Nebraska Boiler

Not coalburning

Null Null Null N Null


Not coalburning

Null Null Null N Null

Dryer/Oven, direct firedEQUI3EU006Niro Atomizer Dryer

Not coalburning

Null Null Null Null Null

Dryer/Oven, indirectfired


Not coalburning



Not coalburning


Reciprocating IC EngineEQUI7EU003Main Emergency Generator

CI Emergency/blackstart 2.2 liters per cylinderNull Null

EQUI11NullWWTP Lift Station Emergency Gene..

CI Emergency/blackstart 1 liters per cylinderNull Null

Emission Units 2 (continued)


Details for:SI Category: EquipmentSI Type: Boiler, Dryer/Oven, direct fired, Dryer/Oven, indirect fired and 1 more

Subject ItemTypeDescription Subject Item ID SI Designation and Description Height

Units(height) Length

Units(length) Width

Units(width)

Building STRU9BG001Main Building

78 feet 450 feet 500 feet

STRU10BG002Diesel Generator Building

12 feet 65 feet 60 feet

Buildings, General


Details for:SI Category: StructureSI Type: Building

Subject ItemTypeDescription Subject Item ID SI Designation and Description

Stack Height(feet)

StackDiameter(feet)

Stack Length(feet)

Stack Width(feet)

Stack Flow Rate(cubic ft/min)

DischargeTemperature(°F)

Flow Rate/TempInformationSource Discharge Direction

Stack/Vent STRU1SV001Nebraska Boiler Stack

60 3.5 Null Null 14571 250 ManufacturerUpwards with no cap onstack/vent

STRU2SV002Cleaver-Brooks Boiler Stack

43 3.5 Null Null 28489 585 EstimateUpwards with no cap onstack/vent

STRU4SV006Atomizer Dryer Stack

85.5 4 Null Null 58000 190 Test dataUpwards with no cap onstack/vent

STRU5SV003Main Emergency Generator Stack

10 0.5 Null Null 2547 650 Estimate Horizontally

STRU6SV004WWTP Lift Station Emergency Generato..

12 0.5 Null Null 30 500 EstimateUpwards with no cap onstack/vent

STRU7SV008Surge Bin Baghouse Stack

83.5 0.5 Null Null 366 65 EstimateUpwards with no cap onstack/vent


88.5 2.5 Null Null 12250 105 Test dataUpwards with no cap onstack/vent

Stack/Vent, General


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


InstallationStart Date

PollutantControlled

CaptureEfficiency(%)

DestructionCollectEfficiency(%)

Subject toCAM?

Large orOther PSEU?Efficiency Basis

Scrubber MinimumPressure Drop (in.of water column)

ScrubberMaximumPressureDrop (in. of ..

MinimumLiquid FlowRate(gal/min)

001-WetScrubber -HighEfficiency

TREA1 CE001Wet Scrubber-High Efficiency w/o Lime

Niro None 1/1/1982ParticulateMatter

100 94 No NullControlEquipment Rule

0.5 6 1.5

PM < 10micron


0.5 6 1.5

Scrubbers, General


Details for:SI Category: TreatmentSI Type: 001-Wet Scrubber - High Efficiency


Installation Start Date

PollutantControlled

CaptureEfficiency(%)

DestructionCollectEfficiency(%)

Subject toCAM?

Large orOther PSEU?Efficiency Basis

Fabric FilterMinimumPressureDrop (in. of ..

Fabric FilterMaximumPressureDrop (in. of ..

Bag leakdetector inuse?

018-FabricFilter - LowTemp, T<18..

TREA2 CE002Fabric Filter - Low Temperature, i.e., T<180Degrees F

FlexClean 84bc9-ii 1/1/2007ParticulateMatter


1 8 No

PM < 10micron


1 8 No

Fabric Filters, General


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

Subject Item ID Sequence Number Requirement Preview Desc

TFAC 1 3

Permit Appendices: This permit contains appendices as listed in the permit Table of Contents. The Permittee

shall comply with all requirements contained in Appendix A: Insignificant Activities and General Applicable

Requirements, Appendix B: PM10 Modeling Parameters, Appendix C: 40 CFR pt. 63, subp. ZZZZ, and Appendix

D: 40 CFR pt. 63, subp. A.

Modeling parameters in Appendix B are included for reference only as described elsewhere in this permit.

[Minn. R. 7007.0800, subp. 2]

TFAC 1 1260

PERMIT SHIELD: Subject to the limitations in Minn. R. 7007.1800, compliance with the conditions of this

permit shall be deemed compliance with the specific provision of the applicable requirement identified in the

permit as the basis of each condition. Subject to the limitations of Minn. R. 7007.1800 and 7017.0100, subp. 2,

notwithstanding the conditions of this permit specifying compliance practices for applicable requirements,

any person (including the Permittee) may also use other credible evidence to establish compliance or

noncompliance with applicable requirements.

This permit shall not alter or affect the liability of the Permittee for any violation of applicable requirements

prior to or at the time of permit issuance. [Minn. R. 7007.1800, (A)(2)]

TFAC 1 1380

The Permittee shall comply with National Primary and Secondary Ambient Air Quality Standards, 40 CFR pt.

50, and the Minnesota Ambient Air Quality Standards, Minn. R. 7009.0010 to 7009.0090. Compliance shall be

demonstrated upon written request by the MPCA. [Minn. R. 7007.0100, subp. 7(A), 7(L), & 7(M), Minn. R.

7007.0800, subp. 4, Minn. R. 7007.0800, subps. 1‐2, Minn. Stat. 116.07, subd. 4a, Minn. Stat. 116.07, subd. 9]

TFAC 1 1390

Circumvention: Do not install or use a device or means that conceals or dilutes emissions, which would

otherwise violate a federal or state air pollution control rule, without reducing the total amount of pollutant

emitted. [Minn. R. 7011.0020]

TFAC 1 1400

Air Pollution Control Equipment: Operate all pollution control equipment whenever the corresponding

process equipment and emission units are operated. [Minn. R. 7007.0800, subp. 16(J), Minn. R. 7007.0800,

subp. 2]

TFAC 1 1410

Operation and Maintenance Plan: Retain at the stationary source an operation and maintenance plan for all

air pollution control equipment. At a minimum, the O & M plan shall identify all air pollution control

equipment and control practices and shall include a preventative maintenance program for the equipment

and practices, a description of (the minimum but not necessarily the only) corrective actions to be taken to

restore the equipment and practices to proper operation to meet applicable permit conditions, a description

of the employee training program for proper operation and maintenance of the control equipment and

practices, and the records kept to demonstrate plan implementation. [Minn. R. 7007.0800, subp. 14, Minn. R.

7007.0800, subp. 16(J)]

TFAC 1 1420

Operation Changes: In any shutdown, breakdown, or deviation the Permittee shall immediately take all

practical steps to modify operations to reduce the emission of any regulated air pollutant. The Commissioner

may require feasible and practical modifications in the operation to reduce emissions of air pollutants. No

emissions units that have an unreasonable shutdown or breakdown frequency of process or control

equipment shall be permitted to operate. [Minn. R. 7019.1000, subp. 4]

TFAC 1 1430

Fugitive Emissions: Do not cause or permit the handling, use, transporting, or storage of any material in a

manner which may allow avoidable amounts of particulate matter to become airborne. Comply with all other

requirements listed in Minn. R. 7011.0150. [Minn. R. 7011.0150]

TFAC 1 1440

Noise: The Permittee shall comply with the noise standards set forth in Minn. R. 7030.0010 to 7030.0080 at all

times during the operation of any emission units. This is a state only requirement and is not enforceable by

the EPA Administrator or citizens under the Clean Air Act. [Minn. R. 7030.0010‐7030.0080]

TFAC 1 1450

Inspections: The Permittee shall comply with the inspection procedures and requirements as found in Minn.

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

TFAC 1 1460

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

7007.0800, subp. 16]

TFAC 1 1470

Monitoring Equipment Calibra on ‐ The Permi ee shall either:

1. Calibrate or replace required monitoring equipment every 12 months; or

2. Calibrate at the frequency stated in the manufacturer's specifica ons.

For each monitor, the Permittee shall maintain a record of all calibrations, including the date conducted, and

any corrective action that resulted. The Permittee shall include the calibration frequencies, procedures, and

manufacturer's specifications (if applicable) in the Operations and Maintenance Plan. Any requirements

applying to continuous emission monitors are listed separately in this permit. [Minn. R. 7007.0800, subp. 4(D)]


TFAC 1 1471

Operation of Monitoring Equipment: Unless noted elsewhere in this permit, monitoring a process or control

equipment connected to that process is not necessary during periods when the process is shutdown, or

during checks of the monitoring systems, such as calibration checks and zero and span adjustments. If

monitoring records are required, they should reflect any such periods of process shutdown or checks of the

monitoring system. [Minn. R. 7007.0800, subp. 4(D)]

TFAC 1 1480

PM < 10 micron: The Permittee shall submit computer dispersion modeling information due 1096 calendar

days after Permit Issuance Date. [Minn. R. 7007.0100, Minn. R. 7007.0800, subp. 2(A), Minn. R. 7009.0020,

Minn. Stat. 116.07, subd. 4a, Minn. Stat. 116.07, subd. 9]

TFAC 1 1481

Sulfur Dioxide: The Permittee shall submit computer dispersion modeling information due 1096 calendar days

after Permit Issuance Date. [Minn. R. 7007.0100, Minn. R. 7007.0800, subp. 2(A), Minn. R. 7009.0020, Minn.

Stat. 116.07, subd. 4a, Minn. Stat. 116.07, subd. 9]

TFAC 1 1490

Nitrogen Oxide: The Permittee shall submit computer dispersion modeling information due 1096 calendar

days after Permit Issuance Date. [Minn. R. 7007.0100, Minn. R. 7007.0800, subp. 2(A), Minn. R. 7009.0020,

Minn. Stat. 116.07, subd. 4a, Minn. Stat. 116.07, subd. 9]

TFAC 1 1500

Modeled Parameters for PM < 10 micron: The parameters used in PM < 10 micron modeling for permit

number 07300016‐003 are listed in Appendix B of this permit. The parameters describe the operation of the

facility at maximum permitted capacity. The purpose of listing the parameters in the appendix is to provide a

benchmark for future changes. [Minn. R. 7007.0100, subp. 7(A), 7(L), & 7(M), Minn. R. 7007.0800, subp. 4,

Minn. R. 7007.0800, subps. 1‐2, Minn. R. 7009.0010‐7009.0090, Minn. Stat. 116.07, subd. 4a, Minn. Stat.

116.07, subd. 9]

TFAC 1 1580

Recordkeeping: Retain all records at the stationary source, unless otherwise specified within this permit, for a

period of five (5) years from the date of monitoring, sample, measurement, or report. Records which must be

retained at this location include all calibration and maintenance records, all original recordings for continuous

monitoring instrumentation, and copies of all reports required by the permit. Records must conform to the

requirements listed in Minn. R. 7007.0800, subp. 5(A). [Minn. R. 7007.0800, subp. 5(C)]

TFAC 1 1600

Recordkeeping: Maintain records describing any insignificant modifications (as required by Minn. R.

7007.1250, subp. 3) or changes contravening permit terms (as required by Minn. R. 7007.1350, subp. 2),

including records of the emissions resulting from those changes. [Minn. R. 7007.0800, subp. 5(B)]

TFAC 1 1620

Performance Testing: Conduct all performance tests in accordance with Minn. R. ch. 7017 unless otherwise

noted in this permit. [Minn. R. ch. 7017]

TFAC 1 1630

Performance Test No fica ons and Submi als:

Performance Test No fica on and Plan: due 30 days before each Performance Test

Performance Test Pre‐test Mee ng: due 7 days before each Performance Test

Performance Test Report: due 45 days a er each Performance Test

The Notification, Test Plan, and Test Report must be submitted in a format specified by the commissioner.

[Minn. R. 7017.2017, Minn. R. 7017.2030, subps. 1‐4, Minn. R. 7017.2035, subps. 1‐2]

TFAC 1 1640

Limits set as a result of a performance test (conducted before or after permit issuance) apply until superseded

as stated in the MPCA's Notice of Compliance letter granting preliminary approval. Preliminary approval is

based on formal review of a subsequent performance test on the same unit as specified by Minn. R.

7017.2025, subp. 3. The limit is final upon issuance of a permit amendment incorporating the change. [Minn.

R. 7017.2025, subp. 3]

TFAC 1 1650

Shutdown Notifications: Notify the Commissioner at least 24 hours in advance of a planned shutdown of any

control equipment or process equipment if the shutdown would cause any increase in the emissions of any

regulated air pollutant. If the owner or operator does not have advance knowledge of the shutdown,

notification shall be made to the Commissioner as soon as possible after the shutdown. However, notification

is not required in the circumstances outlined in Items A, B and C of Minn. R. 7019.1000, subp. 3.

At the time of notification, the owner or operator shall inform the Commissioner of the cause of the

shutdown and the estimated duration. The owner or operator shall notify the Commissioner when the

shutdown is over. [Minn. R. 7019.1000, subp. 3]


TFAC 1 1660

Breakdown Notifications: Notify the Commissioner within 24 hours of a breakdown of more than one hour

duration of any control equipment or process equipment if the breakdown causes any increase in the

emissions of any regulated air pollutant. The 24‐hour time period starts when the breakdown was discovered

or reasonably should have been discovered by the owner or operator. However, notification is not required in

the circumstances outlined in Items A, B and C of Minn. R. 7019.1000, subp. 2.

At the time of notification or as soon as possible thereafter, the owner or operator shall inform the

Commissioner of the cause of the breakdown and the estimated duration. The owner or operator shall notify

the Commissioner when the breakdown is over. [Minn. R. 7019.1000, subp. 2]

TFAC 1 1670

Notification of Deviations Endangering Human Health or the Environment: As soon as possible after discovery,

notify the Commissioner or the state duty officer, either orally or by facsimile, of any deviation from permit

conditions which could endanger human health or the environment. [Minn. R. 7019.1000, subp. 1]

TFAC 1 1680

Notification of Deviations Endangering Human Health or the Environment Report: Within 2 working days of

discovery, notify the Commissioner in writing of any deviation from permit conditions which could endanger

human health or the environment. Include the following informa on in this wri en descrip on:

1. the cause of the devia on;

2. the exact dates of the period of the devia on, if the devia on has been corrected;

3. whether or not the devia on has been corrected;

4. the an cipated me by which the devia on is expected to be corrected, if not yet corrected; and

5. steps taken or planned to reduce, eliminate, and prevent reoccurrence of the deviation. [Minn. R.

7019.1000, subp. 1]

TFAC 1 1690

Application for Permit Amendment: If a permit amendment is needed, submit an application in accordance

with the requirements of Minn. R. 7007.1150 through Minn. R. 7007.1500. Submittal dates vary, depending on

the type of amendment needed.

Upon adoption of a new or amended federal applicable requirement, and if there are 3 or more years

remaining in the permit term, the Permittee shall file an application for an amendment within nine months of

promulgation of the applicable requirement, pursuant to Minn. R. 7007.0400, subp. 3. [Minn. R. 7007.0400,

subp. 3, Minn. R. 7007.1150 ‐ 7007.1500]

TFAC 1 1700

If the Permittee determines that no permit amendment or notification is required prior to making a change,

the Permittee must retain records of all calculations required under Minn. R. 7007.1200. For expiring permits,

these records shall be kept for a period of five years from the date the change was made or until permit

reissuance, whichever is longer. The records shall be kept at the stationary source for the current calendar

year of operation and may be kept at the stationary source or office of the stationary source for all other

years. The records may be maintained in either electronic or paper format. [Minn. R. 7007.1200, subp. 4]

TFAC 1 1710

Extension Requests: The Permittee may apply for an Administrative Amendment to extend a deadline in a

permit by no more than 120 days, provided the proposed deadline extension meets the requirements of

Minn. R. 7007.1400, subp. 1(H). Performance testing deadlines from the General Provisions of 40 CFR pt. 60

and pt. 63 are examples of deadlines for which the MPCA does not have authority to grant extensions and

therefore do not meet the requirements of Minn. R. 7007.1400, subp. 1(H). [Minn. R. 7007.1400, subp. 1(H)]

TFAC 1 1720

Emission Inventory Report: due on or before April 1 of each calendar year following permit issuance. Submit

in a format specified by the Commissioner. [Minn. R. 7019.3000‐7019.3100]

TFAC 1 1730 Emission Fees: due 30 days after receipt of an MPCA bill. [Minn. R. 7002.0005‐7002.0095]

TFAC 1 1740

The Permittee shall submit a semiannual deviations report : Due semiannually, by the 30th of January and

July. The first semiannual report submitted by the Permittee shall cover the calendar half‐year in which the

permit is issued. The first report of each calendar year covers January 1 ‐ June 30. The second report of each

calendar year covers July 1 ‐ December 31. Submit this on form DRF‐2 (Deviation Reporting Form). If no

deviations have occurred, submit the signed report certifying that there were no deviations. [Minn. R.

7007.0800, subp. 6(A)(2)]

TFAC 1 1760

The Permittee shall submit a compliance certification : Due annually, by the 31st of January (for the previous

calendar year). Submit this on form CR‐04 (Annual Compliance Certification Report). This report covers all

deviations experienced during the calendar year. If no deviations have occurred, submit the signed report

certifying that there were no deviations. [Minn. R. 7007.0800, subp. 6(C)]

TFAC 1 1761

The Permittee shall submit an application for permit reissuance : Due 180 calendar days before Permit

Expiration Date. [Minn. R. 7007.0400, subp. 2]


COMG 1 3680

Particulate Matter <= 0.30 grains per dry standard cubic foot of exhaust gas unless required to further reduce

emissions to comply with the less stringent limit of either Minn. R. 7011.0730 or Minn. R. 7011.0735. This limit

applies to each unit individually. [Minn. R. 7011.0715, subp. 1(A)]

COMG 1 3690

EQUI 14, EQUI 15, EQUI 16, and EQUI 17 are cyclone collectors used for product recovery from EQUI 3.

Therefore, they are not treated as or considered to be control equipment.

Any replacement, change, or modification of EQUI 14, EQUI 15, EQUI 16, and/or EQUI 17 is a replacement,

change, or modification of an emission unit for purposes of determining if a permit amendment is required.

[Minn. R. 7007.0800, subp. 2(A)]

COMG 1 3690 Opacity <= 20 percent opacity. [Minn. R. 7011.0715, subp. 1(B)]

COMG 1 3691

The Permittee shall vent emissions from EQUI 3 to EQUI 14, EQUI 15, EQUI 16, and EQUI 17 whenever EQUI 3

operates, and operate and maintain EQUI 14, EQUI 15, EQUI 16, and EQUI 17 at all times that any emissions

are vented to the cyclones. The Permittee shall document periods of non‐operation of EQUI 14, EQUI 15, EQUI

16, and/or EQUI 17 whenever EQUI 3 is opera ng.

See additional requirements at EQUI 3. [Minn. R. 7007.0800, subp. 14, Minn. R. 7007.0800, subp. 2(A)]

COMG 1 3694

The Permittee shall operate and maintain the cyclones in accordance with the Operation and Maintenance (O

& M) Plan. The Permittee shall keep copies of the O & M Plan available onsite for use by staff and MPCA staff.

[Minn. R. 7007.0800, subp. 14]

COMG 1 3695

Periodic Inspections: At least once per calendar quarter, or more frequently as required by the manufacturing

specifications, the Permittee shall inspect the cyclones' components. The Permittee shall maintain a written

record of these inspections. [Minn. R. 7007.0800, subp. 14, Minn. R. 7007.0800, subps. 4‐5]

COMG 1 19660

Corrective Actions: The Permittee shall take corrective action as soon as possible if any cyclone or any of its

components are found during the inspec ons to need repair.

Corrective actions shall include completion of necessary repairs identified during the inspection. Corrective

actions include, but are not limited to, those outlined in the O & M Plan for the cyclones. The Permittee shall

keep a record of the type and date of any corrective action taken for the cyclones. [Minn. R. 7007.0800, subp.

14, Minn. R. 7007.0800, subps. 4‐5]

COMG 2 3461


emissions to comply with the less stringent limit of either Minn. R. 7011.0730 or Minn. R. 7011.0735. This limit

applies to each unit individually. [Minn. R. 7011.0715, subp. 1(A)]

COMG 2 3680 Opacity <= 20 percent opacity. [Minn. R. 7011.0715, subp. 1(B)]

COMG 2 3681

The Permittee shall vent emissions from EQUI 12 and EQUI 13 to EQUI 9 and TREA 1 whenever EQUI 12 or

EQUI 13 operates. [Minn. R. 7007.0800, subp. 14, Minn. R. 7007.0800, subp. 2(A)]

COMG 2 3690

Particulate Matter: The Permittee shall conduct a performance test on STRU 8 due before 10/15/2018 and

every 60 months thereafter to measure emissions. The next test is due by the date specified and all

subsequent tests shall be completed every 60 months thereafter by the set due date (month and day) and as

described below.

The performance test shall be conducted at worst‐case conditions as defined at Minn. R. 7017.2025, subp. 2,

using EPA Reference Methods 5 and 202, or other method approved by MPCA in the performance test plan

approval.

Testing conducted during the 60 days prior to the performance test due date will not reset the test due date

for future testing as required by this permit or within a Notice of Compliance letter. Testing conducted more

than two months prior to the performance test due date satisfies this test due date requirement but will reset

future performance test due dates based on the performance test date. [Minn. R. 7017.2020, subp. 1]

COMG 2 3691

PM < 10 micron: The Permittee shall conduct an initial performance test on STRU 8, due before 10/15/2018 to

verify the PM < 10 micron emission factor of 6.07 pounds per hour.


using EPA Reference Methods 201A and 202, or other method approved by MPCA in the performance test

plan approval. [Minn. R. 7007.0100, subps. 7(A), 7(L), & 7(M), Minn. R. 7007.0800, subps. 1, 2, & 4, Minn. R.

7009.0010‐7009.0090, Minn. R. 7017.2020, subp. 1, Minn. Stat. 116.07, subds. 4a & 9]


COMG 2 19670

PM < 10 micron: The Permittee shall submit a test frequency plan for PM10: Due 60 calendar days after Initial

Performance Test Date for PM10 emission factor. The plan shall specify a testing frequency based on the test

data and MPCA guidance. Future performance tests based on 12‐month, 36‐month, or 60‐month intervals, or

as applicable, shall be required upon written approval of the MPCA. [Minn. R. 7007.0100, subps. 7(A), 7(L), &

7(M), Minn. R. 7007.0800, subps. 1, 2, & 4, Minn. R. 7009.0010‐7009.0090, Minn. R. 7017.2020, subp. 1, Minn.

Stat. 116.07, subds. 4a & 9]

EQUI 1 1

The Permittee shall limit emissions of Sulfur Dioxide <= 240 tons per year calculated on a 12‐month rolling

sum to be calculated by the 15th day of each month for the previous 12‐month period as described later in

this permit. [Title I Condition: Avoid major source under 40 CFR 52.21(b)(1)(i) and Minn. R. 7007.3000]

EQUI 1 3

Particulate Matter <= 0.4 pounds per million Btu heat input. The potential to emit PM from the unit while

burning no. 6 fuel oil is 0.08 lb/million Btu heat input. [Minn. R. 7011.0515, subp. 1]

EQUI 1 4

Opacity <= 20 percent opacity except for one six‐minute period per hour of not more than 60 percent opacity.

[Minn. R. 7011.0515, subp. 2]

EQUI 1 5

Fuel Type: Pipeline natural gas. Fuel oil only as allowed under 40 CFR pt. 63, subp. JJJJJJ, for gas‐fired boilers,

as defined in 40 CFR 63.11237. [Minn. R. 7007.0800, subp. 2(A), Minn. Stat. 116.07, subd. 4a]

EQUI 1 7

The Permittee shall record and maintain a record of the total gallons of fuel oil and/or total million cubic feet

of natural gas combusted in EQUI 1 on a monthly basis. These records shall consist of purchase records,

receipts, or fuel meter readings. [Minn. R. 7007.0800, subp. 5]

EQUI 1 10

Fuel Usage: Monthly Recordkeeping.

By the 15th of each month, the Permi ee shall calculate and record the following:

1) The total EQUI 1 usage of fuel oil in gallons per month and natural gas in million cubic feet per month for

the previous calendar month, using purchase records, receipts, or fuel meter readings;

2) The SO2 emissions for the previous month using the formulas specified below in this permit; and

3) The 12‐month rolling sum SO2 emissions for the previous 12‐month period by summing the monthly total

EQUI 1 SO2 emissions data for the previous 12 months. [Minn. R. 7007.0800, subps. 4‐5, Title I Condition:

Avoid major source under 40 CFR 52.21(b)(1)(i) and Minn. R. 7007.3000]

EQUI 1 12

Monthly SO2 Emissions Calcula ons:

By the 15th of each month, the Permittee shall calculate and record SO2 emissions in tons per month using

the following equa on:

Total EQUI 1 SO2 emissions (tons/month) = [(So * 0.1576 * FO) + (0.63 * NG)]/2000

where:

So = % sulfur by wt. in fuel oil, as determined under the "Determination of Sulfur Content of Fuel Oil in

Storage Tank" found below

FO = EQUI 1 monthly fuel oil usage (gallons/month)

NG = EQUI 1 monthly natural gas usage (million cubic feet/month). [Minn. R. 7007.0800, subps. 4&5, Title I

Condition: Avoid major source under 40 CFR 52.21(b)(1)(i) and Minn. R. 7007.3000]

EQUI 1 13

Fuel Oil Sulfur Content Monitoring: The Permittee shall determine the sulfur content in percent by weight, of

all fuel oil deliveries by obtaining and maintaining a fuel oil supplier certification from the fuel supplier for

each shipment of fuel oil. The certification shall specify the percent sulfur (by weight) in the fuel oil. In

addition, immediately prior to any fuel oil delivery, the Permittee shall measure and record the volume of fuel

oil (in gallons) in the fuel oil storage tank. [Minn. R. 7007.0800, subps. 4&5, Title I Condition: Avoid major

source under 40 CFR 52.21(b)(1)(i) and Minn. R. 7007.3000]


EQUI 1 14

Determina on of Sulfur Content of Fuel Oil in Storage Tank:

Immediately after any fuel oil delivery, the Permittee shall determine and record the sulfur content of the

fuel, in percent by weight, in the fuel oil storage tank by calculating the prorated sulfur content based on

known sulfur content and fuel volume in the tank prior to delivery, and percent sulfur content and volume of

the fuel delivery. The calcula on shall be made using the equa on below:

So = [(Ve * Se) + (Vd * Sd)]/Vt

where:

So = prorated sulfur content a er fuel delivery (% by wt)

Ve = volume of fuel oil in tank prior to delivery (gallons)

Se = sulfur content of fuel oil in tank prior to delivery (% by wt)

Vd = volume of delivery (gallons)

Sd = sulfur content of delivered fuel (% by wt) determined using Fuel Oil Supplier Cer fica on

Vt = total fuel volume in tank after delivery, Vt = Ve + Vd (gallons). [Minn. R. 7007.0800, subps. 4&5, Title I

Condition: Avoid major source under 40 CFR 52.21(b)(1)(i) and Minn. R. 7007.3000]

EQUI 2 4

Fuel Types: Pipeline natural gas and propane. [Title I Condition: Avoid major source under 40 CFR 52.21(b)(2)

and Minn. R. 7007.3000]

EQUI 2 5

The Permittee shall record and maintain records of the amount of fuel combusted during each calendar

month. The Permittee shall maintain these records for a period of five years following the date of such record.

[40 CFR 60.13(i), 40 CFR 60.48c(g)(2), 40 CFR 60.48c(i), Minn. R. 7007.0800, subp. 5]

EQUI 3 3450


emissions to comply with the less stringent limit of either Minn. R. 7011.0730 or Minn. R. 7011.0735. [Minn. R.

7011.0610, subp. 1(A)(1)]

EQUI 3 3455

Opacity <= 20 percent opacity except for one six‐minute period per hour of not more than 60 percent opacity.

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

EQUI 3 3456

Process Throughput <= 7670 pounds per hour on a 24‐hr block average. Measured as dried whey (less than or

equal to 5% moisture) collected; downtime of 15 or more minutes is not included as operating time. [Minn. R.

7017.2025, subp. 3]

EQUI 3 3457 Fuel types: Pipeline natural gas or propane. [Minn. R. 7007.0800, subp. 2(A)]

EQUI 3 3460

The Permittee shall vent emissions from EQUI 3 to EQUI 14, EQUI 15, EQUI 16, and EQUI 17 whenever EQUI 3

operates. [Minn. R. 7007.0800, subp. 14, Minn. R. 7007.0800, subp. 2(A)]

EQUI 3 3461

Recordkeeping: On each day of operation, the Permittee shall calculate, record, and maintain the total

quantity of dried whey (less than or equal to 5% moisture) produced in EQUI 3. The Permittee shall maintain a

written record of the daily verifications. [Minn. R. 7007.0800, subp. 2(A)]

EQUI 3 19670

Particulate Matter: The Permittee shall conduct a performance test on STRU 4 due before 9/17/2018 and

every 36 months thereafter to measure emissions. The next test is due by the date specified and all

subsequent tests shall be completed every 36 months thereafter by the set due date (month and day) and as

described below.


using EPA Reference Methods 5 and 202, or other method approved by MPCA in the performance test plan

approval.

Testing conducted during the 60 days prior to the performance test due date will not reset the test due date

for future testing as required by this permit or within a Notice of Compliance letter. Testing conducted more

than two months prior to the performance test due date satisfies this test due date requirement but will reset

future performance test due dates based on the performance test date. [Minn. R. 7017.2020, subp. 1]

EQUI 3 19671

PM < 10 micron: The Permittee shall conduct an initial performance test on STRU 4, due before 9/17/2018 to

verify the PM < 10 micron emission factor of 5.94 pounds per hour.


using EPA Reference Methods 201A and 202, or other method approved by MPCA in the performance test

plan approval. [Minn. R. 7007.0100, subps. 7(A), 7(L), & 7(M), Minn. R. 7007.0800, subps. 1, 2, & 4, Minn. R.

7009.0010‐7009.0090, Minn. R. 7017.2020, subp. 1, Minn. Stat. 116.07, subds. 4a & 9]


EQUI 3 19672

PM < 10 micron: The Permittee shall submit a test frequency plan for PM10: Due 60 calendar days after Initial

Performance Test Date for PM10 emission factor. The plan shall specify a testing frequency based on the test

data and MPCA guidance. Future performance tests based on 12‐month, 36‐month, or 60‐month intervals, or

as applicable, shall be required upon written approval of the MPCA. [Minn. R. 7007.0100, subps. 7(A), 7(L), &

7(M), Minn. R. 7007.0800, subps. 1, 2, & 4, Minn. R. 7009.0010‐7009.0090, Minn. R. 7017.2020, subp. 1, Minn.

Stat. 116.07, subds. 4a & 9]

EQUI 5 3680



7011.0715, subp. 1(A)]

EQUI 5 3690 Opacity <= 20 percent opacity. [Minn. R. 7011.0715, subp. 1(B)]

EQUI 5 19650

The Permittee shall vent emissions from EQUI 5 to control equipment meeting the requirements of TREA 2

whenever EQUI 5 operates. [Minn. R. 7007.0800, subp. 14, Minn. R. 7007.0800, subp. 2(A)]

EQUI 7 4 Sulfur Dioxide <= 0.0015 pounds per million Btu heat input. [Minn. R. 7011.2300, subp. 2(B)]

EQUI 7 8 Opacity <= 20 percent opacity once operating temperatures have been attained. [Minn. R. 7011.2300, subp. 1]

EQUI 7 12

Fuel type: Diesel fuel meeting the requirements of 40 CFR Section 80.510(c) only. [Minn. R. 7007.0800, subp.

2(A)]

EQUI 7 17

Fuel Supplier Certification: The Permittee shall obtain and maintain a fuel supplier certification for each

shipment of diesel fuel oil, certifying that the sulfur content does not exceed 0.0015 percent by weight. [Minn.

R. 7007.0800, subps. 4‐5]

EQUI 7 20 The Permittee shall keep records of fuel type and usage on a monthly basis. [Minn. R. 7007.0800, subp. 5]

EQUI 7 21

Hours of Operation: The Permittee shall maintain documentation on site that the unit is an emergency

generator by design that qualifies under the U.S. EPA memorandum entitled "Calculating Potential to Emit

(PTE) for Emergency Generators" dated September 6, 1995, limiting operation to 500 hours per year. [Minn. R.

7007.0800, subps. 4‐5]

EQUI 7 23

The Permi ee must comply with all applicable requirements of 40 CFR pt. 63, subp. ZZZZ as follows:

40 CFR 63.6585(a), (c)‐(d);

40 CFR 63.6590 (a)(1)(iii);

40 CFR 63.6595(a);

40 CFR 63.6603(a);

40 CFR 63.6605(a)‐(b);

40 CFR 63.6625 (e)(3), (f), (h)‐(i);

40 CFR 63.6640(a)‐(b), (e)‐(f), (f)(1), (f)(2)(i), (f)(4);

40 CFR 63.6655(e)‐(f);

40 CFR 63.6660(a)‐(c);

40 CFR 63.6665;

40 CFR 63.6675;

40 CFR pt. 63, subp ZZZZ Table 2(d) (Item 4);

40 CFR pt. 63, subp ZZZZ Table 6 (Item 9);

40 CFR pt. 63, subp ZZZZ Table 8.

A copy of 40 CFR pt. 63, subp. ZZZZ is included in Appendix C.

If the standard changes or upon adoption of a new or amended federal applicable requirement, and if there

are more than 3 years remaining in the permit term, the Permittee shall file an application for an amendment

within nine months of promulgation of the applicable requirement, pursuant to Minn. R. 7007.0400, subp. 3.

[40 CFR pt. 63, subp. ZZZZ, Minn. R. 7011.8150]


EQUI 7 21040

The Permi ee must comply with all applicable requirements of 40 CFR pt. 63, subp. A as follows:

40 CFR 63.1(a); 40 CFR 63.1(b)(1); 40 CFR 63.1(c)(1); 40 CFR 63.1(c)(2); 40 CFR 63.1(c)(5); 40 CFR 63.1(e); 40 CFR

63.2; 40 CFR 63.3; 40 CFR 63.4(a); 40 CFR 63.4(b); 40 CFR 63.4(c); 40 CFR 63.6(a)(1); 40 CFR 63.6(a)(2); 40 CFR

63.6(c)(1); 40 CFR 63.6(c)(2); 40 CFR 63.6(c)(5); 40 CFR 63.7(a)(3); 40 CFR 63.8(b)(1); 40 CFR 63.8(f); 40 CFR

63.9(c); 40 CFR 63.9(h); 40 CFR 63.9(i); 40 CFR 63.9(j); 40 CFR 63.10(a)(5); 40 CFR 63.10(b)(1); 40 CFR

63.10(b)(2)(xii); 40 CFR 63.10(b)(2)(xiv); 40 CFR 63.10(b)(3); 40 CFR 63.10(d)(1); 40 CFR 63.10(d)(4); 40 CFR

63.10(f); 40 CFR 63.12; 40 CFR 63.13; 40 CFR 63.14; 40 CFR 63.15(a); 40 CFR 63.15(b); and 40 CFR 63.16.

A copy of 40 CFR pt. 63, subp. A is included in Appendix D. If the standard changes or upon adoption of a new

or amended federal applicable requirement, and if there are more than 3 years remaining in the permit term,

the Permittee shall file an application for an amendment within nine months of promulgation of the

applicable requirement, pursuant to Minn. R. 7007.0400, subp. 3. [40 CFR 63.6665, Minn. R. 7007.0400, subp.

3, Minn. R. 7007.1150‐1500, Minn. R. 7011.7000, Minn. R. 7011.8150, Minn. R. 7017.1010 & 7017.2025, Minn.

R. 7019.0100]

EQUI 9 3680



7011.0715, subp. 1(A)]

EQUI 9 3690

EQUI 9 is a cyclone collector used for product recovery from EQUI 12 and EQUI 13. Therefore, it is not treated

as or considered to be control equipment.

Any replacement, change, or modification of EQUI 9 is a replacement, change, or modification of an emission

unit for purposes of determining if a permit amendment is required. [Minn. R. 7007.0800, subp. 2(A)]

EQUI 9 3690 Opacity <= 20 percent opacity. [Minn. R. 7011.0715, subp. 1(B)]

EQUI 9 3691

The Permittee shall vent emissions from EQUI 12 and EQUI 13 to EQUI 9 whenever EQUI 12 and/or EQUI 13

operates, and operate and maintain EQUI 9 at all times that any emissions are vented to EQUI 9. The

Permi ee shall document periods of non‐opera on of EQUI 9 whenever EQUI 12 or EQUI 13 is opera ng.

See additional requirements at COMG 2 for EQUI 12 and 13. [Minn. R. 7007.0800, subp. 14, Minn. R.

7007.0800, subp. 2(A)]

EQUI 9 3693

The Permittee shall vent emissions from EQUI 9 to control equipment meeting the requirements of TREA 1

whenever EQUI 9 operates. [Minn. R. 7007.0800, subp. 14, Minn. R. 7007.0800, subp. 2(A)]

EQUI 9 3694

The Permittee shall operate and maintain the cyclone in accordance with the Operation and Maintenance (O

& M) Plan. The Permittee shall keep copies of the O & M Plan available onsite for use by staff and MPCA staff.

[Minn. R. 7007.0800, subp. 14]

EQUI 9 3695


specifications, the Permittee shall inspect the cyclone components. The Permittee shall maintain a written

record of these inspections. [Minn. R. 7007.0800, subp. 14, Minn. R. 7007.0800, subps. 4‐5]

EQUI 9 19660

Corrective Actions: The Permittee shall take corrective action as soon as possible if the cyclone or any of its

components are found during the inspec ons to need repair.

Corrective actions shall include completion of necessary repairs identified during the inspection. Corrective

actions include, but are not limited to, those outlined in the O & M Plan for the cyclone. The Permittee shall

keep a record of the type and date of any corrective action taken for the cyclone. [Minn. R. 7007.0800, subp.

14, Minn. R. 7007.0800, subps. 4‐5]

EQUI 11 4 Sulfur Dioxide <= 0.0015 pounds per million Btu heat input. [Minn. R. 7011.2300, subp. 2(B)]

EQUI 11 6 Opacity <= 20 percent opacity once operating temperatures have been attained. [Minn. R. 7011.2300, subp. 1]

EQUI 11 7

Fuel type: Diesel fuel meeting the requirements of 40 CFR Section 80.510(c) only. [Minn. R. 7007.0800, subp.

2(A)]

EQUI 11 22

Fuel Supplier Certification: The Permittee shall obtain and maintain a fuel supplier certification for each

shipment of diesel fuel oil, certifying that the sulfur content does not exceed 0.0015 percent by weight. [Minn.

R. 7007.0800, subps. 4‐5]

EQUI 11 23 The Permittee shall keep records of fuel type and usage on a monthly basis. [Minn. R. 7007.0800, subp. 5]

EQUI 11 3520

Hours of Operation: The Permittee shall maintain documentation on site that the unit is an emergency

generator by design that qualifies under the U.S. EPA memorandum entitled "Calculating Potential to Emit

(PTE) for Emergency Generators" dated September 6, 1995, limiting operation to 500 hours per year. [Minn. R.

7007.0800, subps. 4‐5]


EQUI 11 3530

The Permi ee must comply with all applicable requirements of 40 CFR pt. 63, subp. ZZZZ as follows:

40 CFR 63.6585(a), (c)‐(d);

40 CFR 63.6590 (a)(1)(iii);

40 CFR 63.6595(a);

40 CFR 63.6603(a);

40 CFR 63.6605(a)‐(b);

40 CFR 63.6625 (e)(3), (f), (h)‐(i);

40 CFR 63.6640(a)‐(b), (e)‐(f), (f)(1), (f)(2)(i), (f)(4);

40 CFR 63.6655(e)‐(f);

40 CFR 63.6660(a)‐(c);

40 CFR 63.6665;

40 CFR 63.6675;

40 CFR pt. 63, subp ZZZZ Table 2(d) (Item 4);

40 CFR pt. 63, subp ZZZZ Table 6 (Item 9);

40 CFR pt. 63, subp ZZZZ Table 8.

A copy of 40 CFR pt. 63, subp. ZZZZ is included in Appendix C.

If the standard changes or upon adoption of a new or amended federal applicable requirement, and if there

are more than 3 years remaining in the permit term, the Permittee shall file an application for an amendment

within nine months of promulgation of the applicable requirement, pursuant to Minn. R. 7007.0400, subp. 3.

[40 CFR pt. 63, subp. ZZZZ, Minn. R. 7011.8150]

EQUI 11 21041

The Permi ee must comply with all applicable requirements of 40 CFR pt. 63, subp. A as follows:

40 CFR 63.1(a); 40 CFR 63.1(b)(1); 40 CFR 63.1(c)(1); 40 CFR 63.1(c)(2); 40 CFR 63.1(c)(5); 40 CFR 63.1(e); 40 CFR

63.2; 40 CFR 63.3; 40 CFR 63.4(a); 40 CFR 63.4(b); 40 CFR 63.4(c); 40 CFR 63.6(a)(1); 40 CFR 63.6(a)(2); 40 CFR

63.6(c)(1); 40 CFR 63.6(c)(2); 40 CFR 63.6(c)(5); 40 CFR 63.7(a)(3); 40 CFR 63.8(b)(1); 40 CFR 63.8(f); 40 CFR

63.9(c); 40 CFR 63.9(h); 40 CFR 63.9(i); 40 CFR 63.9(j); 40 CFR 63.10(a)(5); 40 CFR 63.10(b)(1); 40 CFR

63.10(b)(2)(xii); 40 CFR 63.10(b)(2)(xiv); 40 CFR 63.10(b)(3); 40 CFR 63.10(d)(1); 40 CFR 63.10(d)(4); 40 CFR

63.10(f); 40 CFR 63.12; 40 CFR 63.13; 40 CFR 63.14; 40 CFR 63.15(a); 40 CFR 63.15(b); and 40 CFR 63.16.

A copy of 40 CFR pt. 63, subp. A is included in Appendix D. If the standard changes or upon adoption of a new

or amended federal applicable requirement, and if there are more than 3 years remaining in the permit term,

the Permittee shall file an application for an amendment within nine months of promulgation of the

applicable requirement, pursuant to Minn. R. 7007.0400, subp. 3. [40 CFR 63.6665, Minn. R. 7007.0400, subp.

3, Minn. R. 7007.1150‐1500, Minn. R. 7011.7000, Minn. R. 7017.1010 & 7017.2025, Minn. R. 7019.0100]

TREA 1 1

The Permittee shall operate and maintain TREA 1 such that it achieves a control efficiency for Particulate

Matter >= 94 percent control efficiency. [Minn. R. 7011.0070, subp. 1(A)]

TREA 1 2

The Permittee shall operate and maintain TREA 1 such that it achieves a control efficiency for PM < 10 micron

>= 84 percent control efficiency. [Minn. R. 7011.0070, subp. 1(A)]

TREA 1 3

The Permittee shall operate and maintain TREA 1 such that it achieves a control efficiency for PM < 2.5 micron

>= 84 percent control efficiency. [Minn. R. 7007.0800, subp. 14, Minn. R. 7007.0800, subp. 2(A)]

TREA 1 4

Wet Scrubber Water flow rate >= 1.5 gallons per minute, unless a new range is set pursuant to Minn. R.

7017.2025, subp. 3, based on the values recorded during the most recent MPCA‐approved performance test

where compliance was demonstrated. The new range shall be implemented upon receipt of the Notice of

Compliance letter granting preliminary approval. The range is final upon issuance of a permit amendment

incorporating the change.

The Permittee shall record the water flow rate at least once every 24 hours when in operation. If the recorded

flow rate is outside the required range, the emissions during that time shall be considered uncontrolled until

the pressure drop is once again within the required range. The period of time for which the pressure drop is

considered out of range shall be reported as a deviation, as defined by Minn. R. 7007.0100, subp. 8a. [Minn. R.

7011.0075, subp. 1, Minn. R. 7011.0080(A)]


TREA 1 6

Wet Scrubber Pressure Drop >= 0.5 and <= 6.0 inches of water column, unless a new range is set pursuant to

Minn. R. 7017.2025, subp. 3, based on the values recorded during the most recent MPCA‐approved

performance test where compliance was demonstrated. The new range shall be implemented upon receipt of

the Notice of Compliance letter granting preliminary approval. The range is final upon issuance of a permit

amendment incorporating the change.

The Permittee shall record the pressure drop at least once every 24 hours when in operation. If the recorded

pressure drop is outside the required range, the emissions during that time shall be considered uncontrolled

until the pressure drop is once again within the required range. The period of time for which the pressure

drop is considered out of range shall be reported as a deviation, as defined by Minn. R. 7007.0100, subp. 8a.

[Minn. R. 7011.0075, subp. 1, Minn. R. 7011.0080(A)]

TREA 1 7

The control equipment is listed control equipment under Minn. R. 7011.0060 to 7011.0080. The Permittee

shall vent emissions from EQUI 9 to TREA 1 whenever EQUI 12, EQUI 13, and/or EQUI 9 operate, and operate

and maintain TREA 1 at all times that any emissions are vented to TREA 1. The Permittee shall document

periods of non‐operation of the control equipment TREA 1 whenever EQUI 12, EQUI 13, and/or EQUI 9 are

operating. [Minn. R. 7011.0075, subp. 1]

TREA 1 9

Correc ve Ac ons: The Permi ee shall take correc ve ac on as soon as possible if any of the following occur:

‐ the recorded water flow rate is outside the required opera ng range;

‐ the recorded pressure drop is outside the required opera ng range; or

‐ the scrubber or any of its components are found during the inspec ons to need repair.

Corrective actions shall return the pressure drop and/or water flow rate to within the permitted range(s),

and/or include completion of necessary repairs identified during the inspection, as applicable. Corrective

actions include, but are not limited to, those outlined in the Operation and Maintenance (O & M) Plan for the

scrubber. The Permittee shall keep a record of the type and date of any corrective action taken for the control

equipment. [Minn. R. 7007.0800, subp. 14, Minn. R. 7007.0800, subps. 4‐5]

TREA 1 10

Monitoring Equipment: The Permittee shall install and maintain the necessary monitoring equipment for

measuring and recording pressure drop and water flow rate as required by this permit. The monitoring

equipment must be installed, in use, and properly maintained when the monitored scrubber is in operation.

[Minn. R. 7007.0800, subp. 14, Minn. R. 7007.0800, subp. 4, Minn. R. 7011.0075, subp. 3]

TREA 1 12

The Permittee shall maintain each piece of control equipment according to the control equipment

manufacturer's specifications, and shall:

A. maintain an inventory of spare parts that are subject to frequent replacement, as required by the

manufacturing specification or documented in records under items H and I;

B. train staff on the operation and monitoring of control equipment and troubleshooting, and train and

require staff to respond to indications of malfunctioning equipment;

C. thoroughly inspect all control equipment at least annually, or as required by the manufacturing

specification;

D. inspect monthly, or as required by the manufacturing specification, components that are subject to wear or

plugging, for example: bearings, belts, hoses, fans, nozzles, orifices, and ducts;

E. inspect quarterly, or as required by the manufacturing specification, components that are not subject to

wear including structural components, housings, ducts, and hoods;

F. check daily, or as required by the manufacturing specification, monitoring equipment, for example:

pressure gauges, chart recorders, temperature indicators, and recorders;

G. calibrate (or replace) annually, or as required by the manufacturing specification, all monitoring

equipment;

H. maintain a record of activities conducted in items A to G consisting of the activity completed, the date the

activity was completed, and any corrective action taken; and

I. maintain a record of parts replaced, repaired, or modified for the previous five years. [Minn. R. 7011.0075,

subp. 2]

TREA 1 13

Recordkeeping of Pressure Drop and Water Flow Rate: The Permittee shall record the time and date of each

pressure drop reading and water flow rate reading, and whether or not the recorded values were within the

ranges specified in this permit. [Minn. R. 7007.0800, subps. 4‐5, Minn. R. 7011.0080]


TREA 1 14

If the Permittee replaces TREA 1, the replacement control must meet or exceed the control efficiency

requirements of TREA 1 as well as comply with all other requirements of TREA 1. Prior to making such a

change, the Permi ee shall apply for and obtain the appropriate permit amendment, as applicable.

If no amendment is needed for the replacement, the Permittee shall submit an electronic notice to the

Agency using Form CR‐05. The notice must be received by the Agency seven working days prior to the

commencement/start of replacement. [Minn. R. 7007.0800, subp. 14]

TREA 2 1

The Permittee shall operate and maintain control equipment such that it achieves a control efficiency for

Particulate Matter >= 99 percent control efficiency. [Minn. R. 7007.0800, subp. 14]

TREA 2 7

The Permittee shall operate and maintain control equipment such that it achieves a control efficiency for PM

< 10 micron >= 99 percent control efficiency. [Minn. R. 7007.0800, subp. 14]

TREA 2 10

The Permittee shall operate and maintain control equipment such that it achieves a control efficiency for PM

< 2.5 micron >= 93 percent control efficiency. [Minn. R. 7007.0800, subp. 14]

TREA 2 17610

Pressure Drop >= 1.0 and <= 8.0 inches of water.

The Permittee shall record the pressure drop at least once every 24 hours. [Minn. R. 7007.0800, subp. 14]

TREA 2 18480

The Permittee shall vent emissions from EQUI 5 to TREA 2 whenever EQUI 5 operates, and operate and

maintain TREA 2 at all times that any emissions are vented to TREA 2. The Permittee shall document periods

of non‐operation of the control equipment TREA 2 whenever EQUI 5 is operating. [Minn. R. 7007.0800, subp.

14]

TREA 2 18490

The Permittee shall operate and maintain the fabric filter in accordance with the Operation and Maintenance

(O & M) Plan. The Permittee shall keep copies of the O & M Plan available onsite for use by staff and MPCA

staff. [Minn. R. 7007.0800, subp. 14]

TREA 2 18510

Visible Emissions: The Permittee shall check the TREA 2 stack (STRU 7) for any visible emissions once each day

of operation during daylight hours. During inclement weather, the Permittee shall only read and record the

pressure drop across TREA 2, once each day of operation. [Minn. R. 7007.0800, subps. 4‐5]

TREA 2 18530

Monitoring Equipment: The Permittee shall install and maintain the necessary monitoring equipment for

measuring and recording pressure drop as required by this permit. The monitoring equipment must be

installed, in use, and properly maintained when the monitored fabric filter is in operation. [Minn. R.

7007.0800, subp. 4]

TREA 2 18540


specifications, the Permittee shall inspect the control equipment components. The Permittee shall maintain a

written record of these inspections. [Minn. R. 7007.0800, subp. 14, Minn. R. 7007.0800, subp. 4, Minn. R.

7007.0800, subp. 5]

TREA 2 18550

Correc ve Ac ons: The Permi ee shall take correc ve ac on as soon as possible if any of the following occur:

‐ visible emissions are observed;

‐ the recorded pressure drop is outside the required opera ng range; or

‐ the fabric filter or any of its components are found during the inspec ons to need repair.

Corrective actions shall return the pressure drop to within the permitted range, eliminate visible emissions,

and/or include completion of necessary repairs identified during the inspection, as applicable. Corrective

actions include, but are not limited to, those outlined in the O & M Plan for the fabric filter. The Permittee

shall keep a record of the type and date of any corrective action taken for each filter. [Minn. R. 7007.0800,

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

TREA 2 18560

Recordkeeping of Visible Emissions and Pressure Drop. The Permittee shall record the time and date of each

visible emission inspection and pressure drop reading, and whether or not any visible emissions were

observed, and whether or not the observed pressure drop was within the range specified in this permit.

[Minn. R. 7007.0800, subps. 4‐5]

TREA 2 19640

If the Permittee replaces TREA 2, the replacement control must meet or exceed the control efficiency

requirements of TREA 2 as well as comply with all other requirements of TREA 2. Prior to making such a

change, the Permittee shall apply for and obtain the appropriate permit amendment, as applicable.

If no amendment is needed for the replacement, the Permittee shall submit an electronic notice to the

Agency using Form CR‐05. The notice must be received by the Agency seven working days prior to the

commencement/start of replacement. [Minn. R. 7007.0800, subp. 14]

ATTACHMENT 3:

2010 PM10 Modeling Results Report

AIR DISPERSION MODELING REPORT

Prepared for: Pat Kearney

Associated Milk Producers – Dawson 1864 311th Ave

Dawson, MN 56232

5 January 2010

Prepared by: Robert E Reinertsen, Senior Air Quality Engineer Reinertsen Environmental Services, LLC 2411 Highway 3 Two Harbors, MN 55616 218-834-5872 [email protected]

mailto:[email protected]�

AMPI Dawson AERMOD Results January 2010

Page 2 of 14

Table of Contents 1.0 Introduction ..................................................................................................... 3

2.0 Results Summary ............................................................................................ 4

3.0 Modeling Methodology .................................................................................... 4 3.1 Model Selection ..................................................................................................... 4

3.3 Meteorological Data ............................................................................................... 8

3.4 Land Use/Surface Roughness ............................................................................... 9

3.5 Building Downwash ............................................................................................... 9

3.6 Receptor Grid ...................................................................................................... 10

3.7 Flagpole Receptors .............................................................................................. 11

3.9 Nearby Sources ................................................................................................... 11

3.10 Background Concentrations ............................................................................... 12

4.0 Results Details .............................................................................................. 12


Page 3 of 14

1.0 Introduction Associated Milk Producer’s Facility (AMPI) in Dawson Minnesota produces and packages natural cheeses and dries and packages concentrated cheese whey. The facility PM10 emission sources include two boilers, two emergency generators, a whey drying system, and a whey powder collection surge bin. The facility is permitted as a major source under the 40 CFR Part 70 Operating Permits Program. Its air emission permit sets limits on sulfur dioxide that render the source synthetically minor under federal New Source Review. The AMPI Air Emission Permit was issued January 11, 2006. That permit contained the following conditions:

“Computer Dispersion Modeling Protocol due 1096 days after 01/11/2006 for PM10. This protocol will describe the proposed modeling methodology and input data in accordance with MPCA modeling guidance for Title V air dispersion modeling analyses. This is a state-only requirement and is not enforceable by the EPA Administrator or citizens under the Clean Air Act.” And “Computer Dispersion Modeling Results due 1462 days after 01/11/2006 for PM10. To be submitted after the MPCA has reviewed and approved the modeling protocol. The submittal should adhere to MPCA modeling guidance for Title V air dispersion modeling analyses. This is a state only requirement and is not enforceable by the EPA Administrator or citizens under the Clean Air Act.”

Screening modeling was proposed prior to January 11, 2009. In the protocol for the screening modeling AMPI proposed performing full scale modeling only in the event that the screening model predicted concentrations greater than ambient standards. When run, that screening modeling did predict concentrations greater than standards showing that more refined modeling would be necessary. Subsequently, the full scale modeling protocol was submitted dated December 1, 2009. That protocol was approved via e-mail on December, 3, 2009. Modeling results were initially submitted on December 28, 2009. Based on comments received from Dennis Becker regarding the UTM coordinates in the area, this is a resubmittal of the modeling results. The coordinates used are now based on the Minnesota DNR’s Landview system, rather than Google Earth.


Page 4 of 14

2.0 Results Summary The model results demonstrate National Ambient Air Quality Standards (NAAQS) and Minnesota Ambient Air Quality standards (MAAQS) attainment for 24 hour and annual PM10 concentrations. The most recent version of AERMOD (Version 09292) was used. Five point sources and road traffic were modeled and run with 5 years of meteorological data. For modeling purposes continuous plant operation at maximum capacity for the entire 5 years was assumed.

Table 1: NAAQS Standards for PM10

24 Hour 150 µg/m3 Annual 50 µg/m3

Table 2: Modeling Results for PM10

24 Hour 99.01 µg/m3 Annual 33.34 µg/m3

1. As per MPCA policy, results reported above include added MPCA specified background

concentrations of 37 µg/m3 and 23 µg/m3 for the 24-hour and annual concentrations respectively. 2. The 24-hour concentration presented is the High 6th High (H6H) for the 5 years of meteorological

data.

3.0 Modeling Methodology Computer dispersion modeling was used to conduct the ambient air quality modeling for the existing facility to demonstrate compliance with the NAAQS, and MAAQS. The modeling was conducted in accordance with the MPCA modeling guidance for Title V required modeling provided in MPCA Air Dispersion Modeling Guidance for Minnesota Title V Modeling Requirements and Federal PSD Requirements (MPCA, 2004), supplemented with additional guidance provided on MPCA’s web site (http://www.pca.state.mn.us/air/modeling.html) and EPA’s Guideline on Air Quality Models (“GAQM”; U.S. EPA, 2005). AMPI is classified as an Industrial Setting. 3.1 Model Selection The most recent version of AERMOD (Version 09292) was used. Inputs for the AMPI facility included:

• Sources: exhaust stack sources (point sources) and road traffic sources (volume sources;

http://www.pca.state.mn.us/air/modeling.html�


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• Buildings and other structures that could produce downwash effects for point sources; and

• Terrain data to determine building, source, and receptor elevations. The regulatory default options in AERMOD were used. 3.2 Facility Information Table 4 contains the emission rates and stack parameters that were used in the dispersion modeling. The emission rates reflect worst case predicted emissions. SV001, SV002, SV003, SV006, SV007 and road dust emissions exceed the 0.1 lb/hour emissions rate estimation and were included in the model. The remaining sources were excluded. Emission calculations and their data source references are included with this submittal in an attached spreadsheet. During the MPCA’s review of the protocol, it became apparent that the boiler stack gas flow rates given in the MPCA delta database were incorrect. Also incorrect were stack heights and stack diameters. The protocol had proposed modeling flow rates of 9575 acfm, and 25,000 acfm for Boilers #1 and #2 respectively. Both of these flow rates are less than the predicted flow rates using EPA’s “F” factors from 40 CFR 60, Appendix A, Method 19. Those factors give cubic feet produced per million Btu of fuel burned for several types of fuel. The flow rate can then be calculated by multiplying the fuel specific F factor by the maximum heat input of the boiler. The product gives the theoretical amount of air that would be produced if combustion were stochiometric. In practice, some excess air is used to ensure complete combustion. Published values of 5% and 10% excess air were used for natural gas and oil respectively. The calculations are shown on the boiler’s spreadsheet in the calculations attached to this document. This method increased the flow rate for Boiler #1 to 14,571 acfm and to 28,489 acfm for Boiler #2. The correct values are shown in Table 4. It was also determined that the stack exit velocities for the dryers were too low. The protocol proposed a velocity of approximately 5 m/s for both stacks that was based on incorrect stack diameter information. Corrected calculations show that the velocities should instead be 23.5 m/s for the atomizer and 12.6 m/s for the fluid bed. Nevertheless, a separate model run was performed at the more conservative 5 m/s because this specific issue was not discussed with MPCA staff. The dispersion modeling did not show exceedances of any ambient standard. Model results are shown in Table 3.

Table 3: Modeling Results for PM10 With lower dryer stack exit velocities

24 Hour 121.6 µg/m3 Annual 35.75 µg/m3

The model results presented earlier in Table 2 reflect the results using all correct stack parameters and are, as would be expected, lower in concentration than those shown in


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Table 3. The rest of the results and discussion to follow in this report refer to the modeling performed with correct stack parameters The fact that the flow rates in the delta database, as well as stack heights and diameters were incorrect was discussed with Trevor Shearon. He stated that he had discussed the issue with Dennis Becker of the MPCA and they had agreed that the correct values should be used rather than the values that existed in the MPCA database. Stack heights and diameters were determined by facility staff measurement.

Table 4: Facility Information Calculations and Stack Parameters

AMPI Dawson PM10 Facility Emission Calculations

Emission Point

Emission Unit PM10 Emission Rate

g/s Height Height Diameter Radius Temp2 Temp Flow2 Flow Velocity

lb/hr ft m ft m F K acfm m3/m m/s SV001 Boiler No. 1 4.8733 0.6140 60 18.29 3.5 0.53 250 394.4444 14571 412.6086 7.698 SV002 Boiler No. 2 0.5600 0.0706 43 13.11 3.5 0.53 585 580.5556 28489 806.7069 15.050 SV0034 Main Em. Generator 1.5593 0.1965 10 3.05 0.5 0.08 650 616.6667 2547 72.13239 65.939 SV0043 Lift St. Em. Generator 0.0000 12 3.66 0.5 0.08 500 533.3333 0 0 0.000 SV006 Atomizer 5.9443 0.7490 85.5 26.06 4 0.61 190 361.1111 58000 1642.377 23.459 SV007 Fluid Bed 6.0698 0.7648 88.5 26.97 2.5 0.38 105 313.8889 12250 346.8814 12.684 SV008 Surge Bin 0.0000 0.0000 83.5 25.45 0.5 0.08 65 291.6667 na FS001 Traffic Summer 0.1920 0.0242 Traffic Winter 0.3188 0.0402

Notes: 1 For Building Dimensions, see BPI file 2 SV height, diameter from measurements at facility, flow rates for generator and boilers calculated, dryers measured by stack test. 3 The lift Station Emergency Generator's emissions will be modeled vented out SV003 as this is how the facility is configured. The MPCA database is not correct. 4 Emissions from the Lift Station Emergency Generator are included in this stack's emission rate.

3.3 Meteorological Data Five years, 2004 – 2008, of meteorological data from Marshall, MN were used. The data was processed with AERSURFACE using average moisture conditions and the EPA recommended 1.0 km radius for surface roughness and 10.0 km radius for albedo and the Bowen ratio. The wind rose plot shown in Figure 1 summarizes the distribution of wind direction and wind speeds for the Marshall, MN airport data for the years 2004 – 2008.

Figure 1: Wind Rose Summary for AMPI Modeling Meteorology

Marshall MN Airport, 2004-2008


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3.4 Land Use/Surface Roughness For this analysis, an aerial photo of the AMPI facility area was reviewed showing that the 3-km area surrounding the AMPI facility is predominantly rural and under cultivation, and similar in surface roughness, Bowen ratio, and albedo to the Marshall weather station (source of the meteorological data for this modeling). An aerial photo of the area surrounding AMPI is presented in Figure 2.

Figure 2: Area Surrounding Associated Milk Producers 3.5 Building Downwash There exists the potential for downwash effects at the AMPI site. On-site building geometry is complex, and there are several building tiers. The BPIP file for the facility configuration is attached to this document. BPIP-PRIME was run at the beginning of the computer modeling procedure. Figure 3 is a 3-d image


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representing the AMPI complex generated from the BPIP. The terrain color coding represents elevation, and the Cartesian grid represents receptor positions. A line of magenta objects represent receptors placed along the property boundary. The stack sources are located on the rooftops on the southwest side of the complex. The red boxes circling the complex are AERMOD model volume sources representing road traffic.

Figure 3: AMPI Computer Model Graphic - Looking Northwest 3.6 Receptor Grid A comprehensive Cartesian receptor grid was developed for use in the AERMOD modeling. As recommended by MPCA, receptors and source locations were UTM coordinates in NAD83. The grid was organized in fine-to-coarse densities based on distance from the facility. The grid was approximately centered at the SV001 stack and the receptors were spaced at the following intervals.

• 10 meter spacing around the property perimeter • 25 meter increments from the property line out to 500 meters • 100 meter increments out to 2 kilometers


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For the purposes of demonstrating attainment, data for receptors falling inside the AMPI properly line were excluded. The AMPI property line is documented in the attached site plan.

Figure 4: Model Receptor Grid (For attainment demonstration receptors within AMPI property line were excluded)

3.7 Flagpole Receptors No flagpole receptors were used. 3.8 Terrain Terrain elevations were developed for the buildings, sources, and model receptors based upon a National Elevation Dataset (NED) file obtained from the United States Geological Survey (USGS). 3.9 Nearby Sources No nearby sources were modeled.


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3.10 Background Concentrations As per Dennis Becker, the background concentration used was 37 and 23 ug/m3 for the 24 hour and annual concentrations respectively.

4.0 Results Details Figure 5 shows the location of the 24 hour H6thH. The value was 62.01 µg/m3 and occurred at a model boundary receptor on the west end of the property. This figure does not include background.

North

South

Figure 5: Result for 24 hour High 6th High The MPCA specified background value of 37 µg/m3 was added to the 62.01 µg/m3 for a total of concentration of 99.01 µg/m3. Results for 6h high for all model receptors are contained in the attached “Other, all, 24-hr, 6th high.plt” file.


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Figure 6 shows the location of the high annual average for the 5 years of modeling data. The value was 10.34 µg/m3 and occurred at a model boundary receptor on the west end of the property. This figure does not include background.

North

South

Figure 6: Result for High 1st High Annual Average The MPCA specified background value of 23 µg/m3 was added to the 10.34 µg/m3 for a total of concentration of 33.34 µg/m3. Results for all receptor annual concentrations are contained in the attached “Other, all, annual.plt” file. For conservatism the model boundary line receptors near the north-south road (311th Avenue) were set 20 meters to the east of the edge of the road. The modeling results show that Associated Milk Producers of Dawson Minnesota is in compliance with NAAQS and MPCA requirements for PM10 concentrations.


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Attachments (provided electronically): AERMAP NED terrain files AERMET meteorological data files (.SFC and *.PFL) Emission calculations spreadsheet Aermap input file Aermap output file Aermap map detail file Aermap map parameters file Aermap receptor file Aermap source file Bpip input file Bpip output file Bpip summary file Aermod input file Aermod output file 04-08 S.txt 04-08 P.txt Sensitive receptor file Other, all, 24-hr, 1st high.plt Other, all, 24-hr, 6th high.plt Other, all, annual.plt

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