permit applications table · air emission permit no. 09100060-004 this technical support document...

Permit Applications Table Permit Type Application Date Permit Action Total Facility Operating Permit 9/16/2005 001 Major Amendment 4/21/2008 002 Major Amendment 5/23/2008 003 Major Amendment 11/24/2010 004

TABLE OF CONTENTS

Notice to the Permittee Permit Shield Facility Description Amendment Description Table A: Limits and Other Requirements Table B: Submittals Appendices Appendix I: Insignificant Activities and Applicable Requirements Appendix II: Haul Roads Fugitive Dust Control Plan Appendix III: Modeling Inputs Appendix IV: Truck Traffic / Fence Diagram Appendix V: Daily Sweeping and Vacuuming Road Segments Appendix VI: HAP Performance Testing Appendix VII: Best Management Practices for Odor Prevention

NOTICE TO THE PERMITTEE: Your stationary source may be subject to the requirements of the Minnesota Pollution Control Agency’s (MPCA) solid waste, hazardous waste, and water quality programs. If you wish to obtain information on these programs, including information on obtaining any required permits, please contact the MPCA general information number at: Metro Area 651-296-6300 Outside Metro Area 1-800-657-3864 TTY 651-282-5332 The rules governing these programs are contained in Minn. R. chs. 7000-7105. Written questions may be sent to: Minnesota Pollution Control Agency, 520 Lafayette Road North, St. Paul, Minnesota 55155-4194. Questions about this air emission permit or about air quality requirements can also be directed to the telephone numbers and address listed above. PERMIT SHIELD:

Subject to the limitations in Minn. R. 7007.1800, compliance with the conditions of this permit shall be deemed compliance with the specific provision of the applicable requirement identified in the permit as the basis of each condition. Subject to the limitations of Minn. R. 7007.1800 and 7017.0100, subp. 2, notwithstanding the conditions of this permit specifying compliance practices for applicable requirements, any person (including the Permittee) may also use other credible evidence to establish compliance or noncompliance with applicable requirements.

FACILITY DESCRIPTION:

Buffalo Lake Energy, LLC is a fuel-grade ethanol production facility in Fairmont, Minnesota. The facility has a design capacity of 118 million gallons of undenatured ethanol (increased to 122.9 million gallons in permit action 004). The plant also produces Distillers Dried Grains and Solubles (DDGS) for animal feed as a by-product of the ethanol production process. Emission sources at the facility include fermentation, distillation, DDGS handling and drying, combustion sources, storage tanks, production loadout, and fugitive sources such as grain handling and dust from haul roads.

The ethanol facility is located adjacent to an existing Cargill grain elevator (permit no. 09100061-002). The grain for the ethanol facility will be provided from and stored at the Cargill facility. The Cargill grain elevator was classified as a Country Grain Elevator according to the May 1999 MPCA Air Quality Rules and Permitting for the Grain and Feed Industry fact sheet. A conveying system will transport the grain from the Cargill facility to the hammermilling process at the facility. The two facilities are considered a single source for PSD purposes but they are being permitted separately.

The primary emissions are Volatile Organic Compounds (VOC), Particulate Matter (PM), Particulate Matter less than 10 um in size (PM10), Nitrogen Oxides (NOX), and Carbon Monoxide (CO) and Carbon Dioxide (CO2). VOCs are emitted by fermentation, distillation, DDGS drying, wetcake production and storage, ethanol loading, and VOC liquid storage and piping. PM/PM10 is emitted by DDGS handling and drying, corn receiving and handling, and vehicle traffic. NOX and CO and CO2 are emitted by combustion sources.

Air pollution control equipment includes fabric filters (CE004 to CE009 and CE015 to CE017), the Wet Scrubber (CE018), Multiclones (CE019 and CE021) and the Thermal Oxidizers (CE020 and CE022). The scrubber controls emissions from the fermentation and distillation units including the beer well, evaporators and centrifuges; and the thermal oxidizer controls emissions from the dryers, distillation process and DDGS coolers. A flare is used to control emissions from truck and rail ethanol loadout. Baghouses control PM/PM10 from the corn and DDGS handling and storage systems and the truck/rail loadout area. There are five internal floating roof tanks for ethanol, denaturant and denatured ethanol. Emissions from process valves and piping are controlled through an inspection and maintenance program.

Permit Action 002

This permit action updated design changes made during construction (deletion of three fabric filter baghouses, CE001, CE002 and CE003).

CE001 and CE002 were originally intended to control dust from a conveyor that moves corn from the Cargill storage facility into the Buffalo Lake Energy facility. The installed conveyor is a sealed design from which dust cannot escape. CE003 was to control dust from a bulkweigher, which was deleted from the design.

The permit action also corrected the list of baghouses in GP001 by deleting CE010 - CE014. These baghouses were deleted from the design prior to issuance of the first permit but were inadvertently left in this group. These baghouses would have controlled dust from DDGS handling and loadout. DDGS dust is now controlled by CE015, CE016 and CE017.

This permit action also included a change requested through an administrative amendment application for use of an access restriction plan in place of fencing.

Permit Action 003

This permit action updated the allowance of an increase in the PM10 grain loading limit for facility baghouses to 0.003 grains per dry standard cubic foot.

This action also updated the allowance of an increase in truck traffic to 250 trucks/day during the months of December through March; an increase in the NOX emission limit on the TO/HRB (SV019) to 20.93 lb/hr; the addition of two new baghouses to the DDGS handling system (CE024 and CE025); a reduction of the cooling tower circulating flow rate to 45,000 gal/min; and a change in the tank sizes from the original design specifications.

Permit Action 004

This major amendment will increase the undenatured ethanol (200-proof) production limit to < 122.9 million gal/yr (previously < 118 million gal/yr). This increase will be achieved through process optimization and no new equipment will be required to achieve this increase in undenatured ethanol production. Increases in emissions will result for TK001, TK002, TK004, TK005 and EU061. The denatured ethanol truck loadout limit will be renamed to denatured/undenatured ethanol truck loadout, but remain at 61,950,000 gallons per year. The language “50 percent truck loadout or” was removed from this limit. Two previously unlisted emission units; Yeast Propagation Tanks 1 and 2 (EU069/070) will be added and associated with CE018. An existing emergency generator will be added as EU071. Performance testing frequencies will be applied to numerous stacks and corrections will be made to citations and requirements.

TABLE A: LIMITS AND OTHER REQUIREMENTSBuffalo Lake Energy LLC

09100060 - 004

Facility Name:

Permit Number:

05/04/11A-1

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

Subject Item: Total Facility

What to do Why to do itOPERATIONAL LIMITS hdr

Production: less than or equal to 122.9 million gallons/year using 12-month RollingSum of ethanol (200-proof, prior to addition of denaturant).

Title I Condition: To avoid major source classificationunder 40 CFR Section 52.21 and Minn. R. 7007.3000;and to avoid major source classification under 40 CFRSection 70.2 and Minn. R. 7007.0200

Process Throughput: less than or equal to 1223704 tons/year using 12-monthRolling Sum of corn, based on a 56 pound bushel. That is equivalent to 43,703,704bushels per year.


Daily Recordkeeping. On each day of operation, the Permittee shall calculate,record, and maintain the total quantity of grain received at the Buffalo Lake EnergyLLC facility.

Title I Condition: To avoid classification as a majorsource and modification under 40 CFR Section 52.21and Minn. R. 7007.3000; and to avoid classification asa major source under 40 CFR Section 70.2 and Minn.R. 7007.0200

Monthly Recordkeeping - Grain Received. By the 15th of the month, the Permitteeshall calculate and record the following:1) The total tonnage of grain for the previous calendar month using the daily usagerecords.2) The tonnage for the previous month.3) The 12 month rolling sum solids usage for the previous 12 month period bysumming the monthly grain tonnage data for the previous 12 months.

Minn. R. 7007.0800, subps. 4 and 5

Process Throughput: less than or equal to 360000 tons/year using 12-monthRolling Sum of Distillers Dried Grains (DDGS) on a dry basis.


SOURCE-SPECIFIC REQUIREMENTS hdr

Comply with Fugitive Emission Control Plan: The Permittee shall follow the actionsand recordkeeping specified in the control plan. The plan may be amended by thePermittee with the Commissioner's approval. If the Commissioner determines thePermittee is out of compliance with Minn. R. 7011.0150 or the fugitive control plan,then the Permittee may be required to amend the control plan and/or to install andoperate particulate matter ambient monitors as requested by the Commissioner.

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

Follow the Odor Action Plan which is attached to this permit. Minn. R. 7007.0800, subp. 2

Permit Appendices: This permit contains 7 appendices as listed in the permit Tableof Contents. The Permittee shall comply with all requirements contained inappendices I - II and IV - VII.Modeling parameters in Appendix III Modeling Inputs are included for referenceonly and compliance with these parameters is achieved through meeting therequirements that reference Appendix III Modeling Inputs.

Minn. R. 7007.0800, subp. 2

OPERATIONAL REQUIREMENTS hdr

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

Minn. R. 7011.0020

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

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

Operation and Maintenance Plan: Retain at the stationary source an operation andmaintenance plan for all air pollution control equipment. At a minimum, the O & Mplan shall identify all air pollution control equipment and control practices and shallinclude a preventative maintenance program for the equipment and practices, adescription of (the minimum but not necessarily the only) corrective actions to betaken to restore the equipment and practices to proper operation to meet applicablepermit conditions, a description of the employee training program for properoperation and maintenance of the control equipment and practices, and the recordskept to demonstrate plan implementation.

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


09100060 - 004

Facility Name:

Permit Number:

05/04/11A-2

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

Minn. R. 7019.1000, subp. 4

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

Minn. R. 7011.0150

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

Minn. R. 7030.0010 - 7030.0080

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

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

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

Minn. R. 7007.0800, subp. 16

PERFORMANCE TESTING hdr

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

Minn. R. ch. 7017

Performance Test Notifications and Submittals:

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

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

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

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

Limits set as a result of a performance test (conducted before or after permitissuance) apply until superseded as stated in the MPCA's Notice of Complianceletter granting preliminary approval. Preliminary approval is based on formal reviewof 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 amendmentincorporating the change.

Minn. R. 7017.2025, subp. 3

MONITORING REQUIREMENTS hdr

Monitoring Equipment Calibration: The Permittee shall calibrate all requiredmonitoring equipment at least once every 12 months (any requirements applying tocontinuous emission monitors are listed separately in this permit).

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

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

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

RECORDKEEPING hdr

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

Minn. R. 7007.1200, subp. 4

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

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


09100060 - 004

Facility Name:

Permit Number:

05/04/11A-3

Recordkeeping: Maintain records describing any insignificant modifications (asrequired by Minn. R. 7007.1250, subp. 3) or changes contravening permit terms (asrequired by Minn. R. 7007.1350, subp. 2), including records of the emissionsresulting from those changes.

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

REPORTING/SUBMITTALS hdr

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

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

Minn. R. 7019.1000, subp. 3

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

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

Minn. R. 7019.1000, subp. 2

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

Minn. R. 7019.1000, subp. 1

Notification of Deviations Endangering Human Health or the Environment Report:Within 2 working days of discovery, notify the Commissioner in writing of anydeviation from permit conditions which could endanger human health or theenvironment. Include the following information in this written description:1. the cause of the deviation;2. the exact dates of the period of the deviation, if the deviation has been corrected;3. whether or not the deviation has been corrected;4. the anticipated time by which the deviation is expected to be corrected, if not yetcorrected; and5. steps taken or planned to reduce, eliminate, and prevent reoccurrence of thedeviation.

Minn. R. 7019.1000, subp. 1

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

Minn. R. 7007.1150 - 7007.1500

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

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

Emission Inventory Report: due on or before April 1 of each calendar yearfollowing permit issuance. To be submitted on a form approved by theCommissioner.

Minn. R. 7019.3000 - 7019.3100

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

The Permittee must submit a Risk Management Plan (RMP) under 40 CFR pt. 68.Each owner or operator of a stationary source, at which a regulated substance ispresent above a threshold quantity in a process, shall design and implement anaccidental release prevention program. An initial RMP must be submitted no laterthan the latest of the following dates: 1) June 21, 1999; 2) Three years after thedate on which a regulated substance is first listed under 40 CFR Section 68.130; or3) The date on which a regulated substance is first present above a thresholdquantity in a process. A full update and resubmission of the RMP is required atleast once every five years. The five-year anniversary date is reset whenever yourfacility fully updates and resubmits their RMP. Submit RMPs to the RiskManagement Plan Reporting Center, P.O. Box 1515, Lanham-Seabrook, Maryland20703-1515. RMP information may be obtained at http://www.epa.gov/swercepp orby calling 1-800-424-9346.

40 CFR pt. 68


09100060 - 004

Facility Name:

Permit Number:

05/04/11A-4

MODELING REQUIREMENTS hdr

Parameters Used in Modeling: The parameters used in the modeling performed foran Environmental Assessment Worksheet under Minn. R. ch. 4410 and fordetermining emission and/or operational limits, if applicable for this facility are listedin Appendix III of this permit. If the Permittee intends to change any of theseparameters, the Permittee must submit the revised parameters to theCommissioner and receive written approval before making any changes. Therevised parameter information submittal must include, but is not limited to: thelocations, heights and diameters of the stacks; locations and dimensions of nearbybuildings; velocity and temperatures of the gases emitted; and the emission rates.The plume dispersion characteristics due to the parameter revisions must equal orexceed the dispersion characteristics modeled for this permit, and the Permitteeshall demonstrate this in the proposal.

Minn. R. 7009.0020; Minn. R. 7007.0800, subp. 2

Parameters Used in Modeling: The stack heights, stack diameters, air flow rates,and exhaust gas temperatures used in the modeling performed for the PSDanalysis for this permit are listed in Appendix III of this permit. The Permittee mustsubmit to the Agency for approval any revisions of these parameters that arecaused by a physical change or change in the method of operation of the facilityand must wait for a written approval before making such changes. The informationsubmitted must include, at a minimum, the locations, heights and diameters of thestacks, locations and dimensions of nearby buildings, the velocity and temperatureof the gases emitted, and the PM10 emission rates. The plume dispersioncharacteristics after the proposed revisions must be equivalent to or better than thedispersion characteristics used in the model dated March 13, 2006. The Permitteeshall demonstrate this equivalency in the proposal.

Title I Condition: 40 CFR Section 52.21(k); Minn. R.7007.3000

If the information submitted does not demonstrate equivalent or better dispersioncharacteristics, or if a conclusion cannot readily be made about the dispersion, thePermittee must remodel.

For any physical change to or change in the method of operation of a stack emittingPM10 or for any increase in PM10 emissions (whether or not the increase wouldrequire a permit amendment of any type), the Permittee must remodel.

For changes that do not involve any increase to any emission rate or any emissionsfrom a new emission point, this proposal must be submitted as soon as practicable,but no less than 60 days before beginning actual construction of the modification,stack, or associated emission unit(s).


For changes involving increases in emission rates or emissions from a newemission point and that require a minor permit amendment, the proposal and/orrequired modeling analysis must be submitted as soon as practicable, but no lessthan 60 days before beginning actual construction of the modification, stack, orassociated emission unit(s).

For changes involving increases in emission rates or emissions from a newemission point and that require a permit amendment other than a minoramendment, the proposal and/or modeling analysis must be submitted with thepermit application.


The Permittee shall install fencing around the facility. In areas where fencing is notpermissible by setbacks, right-of-ways, safety concerns, or clearances, thePermittee will use signage and patrolling to sufficiently restrict public access to theproperty outlined as fenced in the dispersion modeling.

The Permittee shall maintain an Access Restriction Plan onsite describing physicaland active barriers sufficient to restrict public access to the property as delineatedin the most recent compliant dispersion modeling analysis.

Minn. R. ch. 7009


09100060 - 004

Facility Name:

Permit Number:

05/04/11A-5

Subject Item: GP 001 Baghouses

Associated Items: CE 004 Fabric Filter - Low Temperature, i.e., T<180 Degrees F

CE 005 Fabric Filter - Low Temperature, i.e., T<180 Degrees F










What to do Why to do itPOLLUTION CONTROL REQUIREMENTS hdr

Total Particulate Matter: greater than or equal to 99 percent control efficiency . ThePermittee shall operate and maintain the fabric filters such that they achieve 99%overall control efficiency. This limit applies to each fabric filter individually.


PM < 10 micron: greater than or equal to 99 percent control efficiency . ThePermittee shall operate and maintain the fabric filters such that they achieve 99%overall control efficiency. This limit applies to each fabric filter individually.


OPERATIONAL LIMITS hdr

Pressure Drop: greater than or equal to 1 inches of water column and less than orequal to 6 inches of water column , unless a new range is set by permit reopeningor permit amendment, based on the values recorded during the most recent MPCAapproved performance test where compliance was demonstrated. The Permitteeshall record the pressure drop once every 24 hours when in operation.

Title I Condition: To avoid classification as a majorsource and modification under 40 CFR Section 52.21and Minn. R. 7007.3000; To avoid classification asmajor source under 40 CFR Section 70.2 and Minn. R.7007.0200, Minn. R. 7007.0800, subps. 2 and 14;Minn. R. 7017.2025, subp. 3

Visible Emissions: The Permittee shall check the fabric filter stacks for any visibleemissions once each day of operation during daylight hours. During inclementweather, the Permittee shall read and record the pressure drop across the fabricfilter, once each day of operation.

Title I Condition: Monitoring for Limit taken to avoidclassification as a major source and modification under40 CFR Section 52.21; to avoid classification as amajor source under 40 CFR Section 70.2; Minn. R.7011.0080


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

Title I Condition: To avoid classification as a majorsource and modification under 40 CFR Section 52.21and Minn. R. 7007.3000; To avoid classification as amajor source under 40 CFR Section 70.2 and Minn. R.7007.0200; Minn. R. 7007.0800, subps. 4 and 5

The Permittee shall operate and maintain the fabric filters at all times that anyemission unit controlled by the fabric filter is in operation. The Permittee shalldocument periods of non-operation of the control equipment. Vent emissions fromall units controlled by the baghouses in GP001, through the baghouses at all timesthat the associated units are in operation.

Title I Condition: To avoid classification as a majorsource and modification under 40 CFR Section 52.21and Minn. R. 7007.3000; To avoid classification asmajor source under 40 CFR Section 70.2 and Minn. R.7007.0200, Minn. R. 7007.0800, subps. 2 and 14

The Permittee shall operate and maintain the fabric filter according to the controlequipment manufacturer's specifications and/or in accordance with the Operationand Maintenance (O & M) Plan. The Permittee shall keep copies of the O & M Planavailable onsite for use by staff and MPCA staff.

Minn. R. 7007.0800, subp. 14

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

Minn. R. 7007.0800, subp. 4


09100060 - 004

Facility Name:

Permit Number:

05/04/11A-6

Corrective Actions: The Permittee shall take corrective action as soon as possible ifany of the following occur:- visible emissions are observed;- the recorded pressure drop is outside the required operating range; or- the fabric filter or any of its components are found during the inspections to needrepair.Corrective actions shall return the pressure drop to within the permitted range,eliminate visible emissions, and/or include completion of necessary repairsidentified during the inspection, as applicable. Corrective actions include, but arenot limited to, those outlined in the O & M Plan for the fabric filter. The Permitteeshall keep a record of the type and date of any corrective action taken for eachfilter.

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

Periodic Inspections: At least once per calendar quarter, or more frequently asrequired by the manufacturing specifications, the Permittee shall inspect the controlequipment components. The Permittee shall maintain a written record of theseinspections.

Minn. R. 7007.0800, subps. 2 and 14


09100060 - 004

Facility Name:

Permit Number:

05/04/11A-7

Subject Item: GP 003 Dryers

Associated Items: EU 056 DDGS Dryer A

EU 058 DDGS Dryer B


Fuel Burned: Natural gas only Title I Condition: To avoid major source classificationunder 40 CFR Section 52.21 and Minn. R. 7007.3000;and to avoid major source classification under 40 CFRSection 70.2 and Minn. R. 7007.0200

Operating limits based on performance tests: Limits set following a performancetest for dryers may include a production limit (wetcake feedrate or beer feedrate asa surrogate), syrup feedrate, and dryer temperature.

Minn. R. 7017.2025, subp. 3

When a shutdown or breakdown of either thermal oxidizer occurs, the Permitteeshall stop wetcake feed to the dryer. The Permittee may continue operation of thedryer only as long as necessary to empty material already in the dryer.

Title I Condition: to avoid major source classificationunder 40 CFR Section 52.21 and Minn. R. 7007.3000;to avoid major source classification under 40 CFRSection 70.2 and Minn. R. 7007.0200

POLLUTION CONTROL REQUIREMENTS hdr

Vent all emissions to the thermal oxidizer (CE020 and CE022). Title I Condition: To avoid major source classificationunder 40 CFR Section 52.21 and Minn. R. 7007.3000;and to avoid major source classification under 40 CFRSection 70.2 and Minn. R. 7007.0200

The Permittee shall operate and maintain each dryer in accordance with theOperation and Maintenance (O & M) Plan. The Permittee shall keep copies of theO & M Plan available onsite for use by staff.

Minn. R. 7007.0800, subp. 14

PROCESS MONITORING hdr

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

Minn. R. 7007.0800, subps. 2 and 14

Inspect monthly or as required by manufacturing specifications, all components thatare subject to wear or plugging. Maintain a written record of the inspection and anyaction resulting from the inspection.

Minn. R. 7007.0800, subps. 2 and 14

Calibrate gauges annually or as often as required by manufacturing specificationsand maintain a written record of the calibration and any action resulting from thecalibration.

Minn. R. 7007.0800, subps. 2 and 14


09100060 - 004

Facility Name:

Permit Number:

05/04/11A-8

Subject Item: GP 004 Thermal Oxidizer with Heat Recovery Boiler

Associated Items: EU 011 Slurry Tank 1

EU 012 Liquefaction Tank 1

EU 013 Yeast Tank 1

EU 014 Yeast Tank 2

EU 015 Process Condensate Tank

EU 016 Beer Column 1


EU 018 Stripper 1

EU 019 Stripper 2

EU 020 Rectifier 1

EU 021 Rectifier 2

EU 022 Evaporator 1

EU 023 Evaporator 2

EU 024 Syrup Tank

EU 025 Centrifuge 1

EU 026 Centrifuge 2

EU 027 Centrifuge 3

EU 028 Centrifuge 4

EU 029 Centrifuge 5

EU 030 Centrifuge 6

EU 031 Centrifuge 7

EU 032 Centrifuge 8

EU 033 Molecular Sieve 1




EU 037 200 Proof Condenser


EU 057 Thermal Oxidizer/Heat Recovery Generator 1


What to do Why to do itSUBPART Db REQUIREMENTS hdr

Nitrogen Oxides: less than or equal to 0.10 lbs/million Btu heat input using 30-dayRolling Average

40 CFR 60.44b(a)(1)(i); Minn. R. 7011.0565

The Permittee shall install, calibrate, maintain, and operate a continuous monitoringsystem, and record the output of the system, for measuring nitrogen oxidesemissions discharged to the atmosphere.

40 CFR 60.48b(b)(1); Minn. R. 7011.0565

The Permittee subject to the nitrogen oxides emission limit under 40 CFR Section60.44b shall submit to the Administrator the performance test data from the initialperformance test and the performance evaluation of the CEMS using the applicableperformance specifications in 40 CFR pt. 60, appendix B.

40 CFR 60.49b(b); Minn. R. 7011.0565

The Permittee shall record and maintain records of the amounts of natural gascombusted during each day and calculate the annual capacity factor individually fornatural gas for the reporting period. The annual capacity factor is determined on a12-month rolling average basis with a new annual capacity factor calculated at theend of each calendar month.

40 CFR 60.49b(d); Minn. R. 7011.0565



09100060 - 004

Facility Name:

Permit Number:

05/04/11A-9

Temperature: greater than or equal to 1400 degrees F using 3-hour RollingAverage as a 3-hour rolling average at the combustion chamber outlet, unless anew limit is set pursuant to Minn. R. 7017.2025, subp. 3 based on the valuesrecorded during the most recent MPCA-approved performance test wherecompliance was demonstrated. The new limit shall be implemented upon receipt ofthe Notice of Compliance letter granting preliminary approval. The limit is final uponissuance of a permit amendment incorporating the change. If the 3-hour rollingaverage temperature is below the minimum temperature limit, the VOC used duringthat time shall be considered uncontrolled until the average temperature is abovethe minimum temperature limit. This shall be reported as a deviation.


The Permittee shall operate and maintain the control equipment such that itachieves an overall control efficiency for Volatile Organic Compounds: greater thanor equal to 98.0 percent control efficiency


Fuel Burned: Natural gas only Title I Condition: To avoid major source classificationunder 40 CFR Section 52.21 and Minn. R. 7007.3000;and to avoid major source classification under 40 CFRSection 70.2 and Minn. R. 7007.0200

Vent all emissions from DDGS Dryers (EU 056 and EU 058) and DDGS Coolers tothe Thermal Oxidizers/Heat Recovery Boilers (EU 057 and EU 059)


The Permittee shall operate and maintain the thermal oxidizer any time that anyprocess equipment controlled by the thermal oxidizer is in operation in accordancewith the Operation and Maintenance (O & M) Plan. The Permittee shall keepcopies of the O & M Plan available onsite for use by staff and MPCA staff. ThePermittee shall document periods of non-operation of the control equipment. Ventemissions from all units controlled by the thermal oxidizers EU057 and EU059,through the thermal oxidizers at all times that the associated units are in operation.

Title I Condition: To avoid classification as a majorsource and modification under 40 CFR Section 52.21and Minn. R. 7007.3000; To avoid classification asmajor source under 40 CFR Section 70.2 and Minn. R.7007.0200, Minn. R. 7007.0800, subps. 2 and 14


The Permittee shall maintain and operate a thermocouple monitoring device thatcontinuously indicates and records the combustion chamber temperature of thethermal oxidizer. The thermocouple must be installed, in use, and properlymaintained whenever operation of the thermal oxidizer is required. The monitoringdevice shall have a margin of error less than the greater of +/- 0.75 percent of thetemperature being measured or +/- 2.5 degrees Celsius. The recording deviceshall also calculate the three-hour rolling average combustion chambertemperature.

Minn. R. 7007.0800, subps. 4 and 5

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

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

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

Minn. R. 7007.0800, subps. 4 and 5

Quarterly Inspections: At least once per calendar quarter, the Permittee shallinspect the control equipment internal and external system components, includingbut not limited to the refractory, heat exchanger, and electrical systems. ThePermittee shall maintain a written record of the inspection and any correctiveactions taken resulting from the inspection.

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

Annual Calibration: The Permittee shall calibrate the temperature monitor at leastannually and shall maintain a written record of the calibration and any actionresulting from the calibration.

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

RECORDKEEPING AND REPORTING hdr

The Permittee shall maintain a continuous hard copy readout or computer disk fileof the temperature readings for the combustion chamber.


CONTINUOUS MONITORING REQUIREMENTS hdr

CEMS Installation: Install NOx and CO CEMS. Minn. R. 7017.1006

Installation Notification: due 60 days before installing the continuous emissionsmonitoring system. The notification shall include plans and drawings of the system.

Minn. R. 7017.1040, subp. 1


09100060 - 004

Facility Name:

Permit Number:

05/04/11A-10

CEM Certification Test: due 60 days after achieving maximum capacity but not laterthan 180 days after startup, or 90 days after the due date of the first excessemissions report, which ever is more stringent.

40 CFR Section 40 CFR Section 60.8(a); 40 CFRSection 60.13(b); Minn. R. 7017.1050, subp. 1

CEMS Certification Test Plan: due 30 days before CEMS Certification Test. 40 CFR Section 60.7(a)(5); Minn. R. 7017.1060,subps. 1 and 2

CEMS Certification Test Pretest Meeting: due 7 days before CEMS CertificationTest.

Minn. R. 7017.1060, subp. 3

CEMS Certification Test Report: due 45 days after CEMS Certification Test Minn. R. 7017.1080, subps. 1, 2 and 4; 40 CFRSection 60.13(c)(2)

CEMS Certification Test Report - Microfiche or CD Copy: due 105 days afterCEMS Certification Test.

Minn. R. 7017.1080, subp. 3

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

Minn. R. 7017.1170, subp. 3

Cylinder Gas Audit (CGA): due before end of each calendar quarter followingCEMS certification test. A CGA is not required during any calendar quarter inwhich a RATA was performed. The initial CGA must be performed within 80 daysfollowing certification of the CEMS. The CGAs shall be conducted at least threemonths apart but no more than eight months apart. A CGA shall be conductedaccording to the procedures in 40 CFR pt. 60, Appendix F, section 5.1.2.

40 CFR pt. 60, Appendix F, section 5.1.2; Minn. R.7017.1170, subp. 4

CEMS Relative Accuracy Test Audit (RATA): due before end of each calendaryear following CEMS Certification Test . A RATA is not required in any calendaryear if a RATA conducted in the previous year demonstrated a relative accuracyvalue of less than 15 percent or if the associated emissions unit operated less than48 hours during the calendar year. If the exception is used, the next RATA shall beconducted during the first half of the following calendar year. RATAs shall beconducted at least 3 months apart according to 40 CFR pt. 60, Appendix F, section5.1.1.

40 CFR pt. 60, Appendix F, section 5.1.1; Minn. R.7017.1170, subp. 5

Relative Accuracy Test Audit (RATA) Notification: due 30 days before CEMSRelative Accuracy Test Audit (RATA)) . <When subject to Appendix F>

Minn. R. 7017.1180, subp. 2

Continuous Operation: CEMS must be operated and data recorded during allperiods of emission unit operation including periods of emission unit start-up,shutdown, or malfunction except for periods of acceptable monitor downtime. Thisrequirement applies whether or not a numerical emission limit applies during theseperiods. A CEMS must not be bypassed except in emergencies where failure tobypass would endanger human health, safety, or plant equipment.

Acceptable monitor downtime includes reasonable periods as listed in Items A, B,C and D of Minn. R. 7017.1090, subp. 2.

Minn. R. 7017.1090, subp. 1

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

Minn. R. 7007.1130

QA Plan: Develop and implement a written quality assurance plan that covers eachCEMS. The plan shall be on site and available for inspection within 30 days aftermonitor certification. The plan shall contain all of the information required by 40CFR pt. 60, App. F, section 3.

Minn. R. 7017.1170, subp. 2


09100060 - 004

Facility Name:

Permit Number:

05/04/11A-11

Subject Item: GP 005 Internal Floating Roof Tanks

Associated Items: TK 001 200 Proof Ethanol

TK 002 200 Proof Ethanol

TK 003 Denaturant

TK 004 Denatured Ethanol


What to do Why to do itPOLLUTION CONTROL REQUIREMENTS hdr

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

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

Internal Floating Roof Seal Requirement: Each internal roof shall be equipped withone of the closure devices between the wall of the storage vessel and the edge ofthe internal floating roof as described in 40 CFR Section 60.112b(a)(1)(ii).

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


Inspection - Prior to initial fill of tanks: Visually inspect the internal floating roof, theprimary seal, and the secondary seal (if one is in service), prior to filling the storagevessel with Volatile Organic Liquid (VOL). If there are holes, tears, or otheropenings in the primary seal, the secondary seal, or the seal fabric; or defects inthe internal floating roof, or both, the Permittee shall repair the items before fillingthe storage vessel.

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

Inspection - Annual: Visually inspect the internal floating roof, the primary seal, andthe secondary seal (if one is in service) through manholes and roof hatches on thefixed roof at least once every twelve (12) months after initial fill as required by 40CFR Section 60.113b(a)(2).

40 CFR Section 60.113b(a)(2) and (4); Minn. R.7011.1520(C)

Inspection - Tank Empty and Degassed: Visually inspect the internal floating roof,the primary seal, and the secondary seal (if one is in service), gaskets, slottedmembranes and sleeve seals (if any) each time the tank is emptied and degassedas required by 40 CFR Section 60.113b(a)(4). In no event shall inspectionsconducted in accordance with this provision occur at intervals greater than 10years.

40 CFR Section 60.113b(a)(2) and (4); Minn. R.7011.1520(C)

RECORDKEEPING REQUIREMENTS hdr

Keep a record of each inspection performed as required by 40 CFR Section60.113b(a). Each record shall identify the storage vessel on which the inspectionwas performed and shall contain the date the vessel was inspected and theobserved condition of each component of the control equipment (seals, internalfloating roof, and fittings).


Recordkeeping: Maintain records showing the dimensions of each tank and ananalysis showing tank capacity.

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

Recordkeeping: Maintain records of the volatile organic liquid (VOL) stored, theperiod of storage, and the maximum true vapor pressure of the VOL during therespective storage period, calculated as described in 40 CFR Section 60.116b(e).

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

REPORTING REQUIREMENTS hdr

Notification: Notify the Commissioner in writing at least 30 days prior to the filling orrefilling of each tank for which an inspection is required by 40 CFR Section 60.113b(a)(1) and (a)(4) to afford the Commissioner the opportunity to have an observerpresent. If the inspection required by 40 CFR 6.113b(a)(4) is not planned and thePermittee could not have known about the inspection 30 days in advance of refillingthe tank, the Permittee shall notify the Administrator at least 7 days prior to therefilling of the tank. Notification shall be made by telephone followed by writtendocumentation demonstrating why the inspection was unplanned. Alternatively,this notification including the written documentation may be made in writing andsent by express mail so that it is received by the Commissioner at least 7 days priorto the refilling.


After each inspection required by 40 CFR Section 60.113b(a)(3) that finds holes ortears in the seal or seal fabric, or defects in the internal floating roof, or othercontrol equipment defects listed in 40 CFR Section 60.113b(a)(3)(ii), a report shallbe furnished to the Administrator within thirty (30) days of the inspection. Thereport shall identify the storage vessel and the reason it did not meet thespecifications of 40 CFR Section 60.112b(a)(1) or 40 CFR Section 60.113b(a)(3)(ii)and list each repair made.

40 CFR Section 60.115b(a)(4); Minn. R. 7011.1520 (C)


09100060 - 004

Facility Name:

Permit Number:

05/04/11A-12

Notification - Control Equipment Installation and Certification: After installing theinternal floating roofs, furnish the Administrator with a report describing the controlequipment (fixed roof/internal floating roof combination) and certifying that thecontrol equipment meets the specifications of Sections 60.112b(a)(1) and60.113b(a)(1). This report shall be attached to the initial startup notificationrequired by Section 60.7(a)(3) and located in Table B of this permit.


Reporting - Annual Inspection Results: If any of the conditions described in 40CFR Section 60.113b(a)(2) are detected during the annual visual inspectionrequired by 40 CFR Section 60.113b(a)(2), a report shall be furnished to theAdministrator within 30 days of the inspection. Each report shall identify the tank,the nature of the defects, and the date the tank was emptied or the nature of anddate the repair was made.



09100060 - 004

Facility Name:

Permit Number:

05/04/11A-13

Subject Item: GP 006 Ethanol Loadout

Associated Items: EU 060 Ethanol Loadout (Truck)

EU 061 Ethanol Loadout (Rail)

What to do Why to do itVent all emissions when loading ethanol into trucks and/or railcars to the LoadoutFlare (EU066, CE023).



09100060 - 004

Facility Name:

Permit Number:

05/04/11A-14

Subject Item: GP 007 Multiclones

Associated Items: CE 019 Centrifugal Collector - High Efficiency

CE 021 Centrifugal Collector - High Efficiency

What to do Why to do itPressure Drop: greater than or equal to 2 inches of water column and less than orequal to 10 inches of water column , unless a new range is set by permit reopeningor permit amendment, based on the values recorded during the most recent MPCAapproved performance test where compliance was demonstrated. The Permitteeshall record the pressure drop once every 24 hours when in operation.

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

Record pressure drop once each day of operation. Title I Condition: To avoid major source classificationunder 40 CFR Section 52.21 and Minn. R. 7007.3000;and to avoid major source classification under 40 CFRSection 70.2 and Minn. R. 7007.0200

Vent all emissions to the thermal oxidizers (CE020 and CE022). Title I Condition: To avoid major source classificationunder 40 CFR Section 52.21 and Minn. R. 7007.3000;and to avoid major source classification under 40 CFRSection 70.2 and Minn. R. 7007.0200

Inspect monthly, or as required by manufacturing specificatioins, all componentsthat are subject to wear or plugging. Maintain a written record of the inspectionsand any corrective actions resulting from the inspection.

Minn. R. 7007.0800, subps. 2 and 14

Calibrate the pressure gauge annually or as often as required by manufacturingspecifications and maintain a written record of the calibration and any actionresulting from the calibration.

Minn. R. 7007.0800, subps. 2 and 14

Corrective Actions: If the pressure drop is outside of the range specified by thispermit or if the dryers or any of their components are found during the inspectionsto need repair, the Permittee shall take corrective action as soon as possible.Corrective actions shall return the pressure drop to the permitted range and/orinclude completion of necessary repairs identified during the inspection, asapplicable. Corrective actions include, but are not limited to, those outlined in the O& M Plan for the dryers. The Permittee shall keep a record of the type and date ofany corrective action taken.

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


09100060 - 004

Facility Name:

Permit Number:

05/04/11A-15

Subject Item: GP 009 Hammermills

Associated Items: EU 007 Hammermill 1

EU 008 Hammermill 2

EU 009 Hammermill 3

EU 010 Hammermill 4

What to do Why to do itThe Hammermills are not to be operating while corn is being shipped from CargillAgHorizons.

Title I Condition: To avoid classification as a majorsource and modification under 40 CFR Section 52.21and Minn. R. 7007.3000; To avoid classification asmajor source under 40 CFR Section 70.2 and Minn. R.7007.0200

Daily Recordkeeping. At any time that grain is shipped from the Cargill AgHorizonsfacility, the Permittee shall record and maintain a record of the dates and timeswhich the Hammermills are not operating.



09100060 - 004

Facility Name:

Permit Number:

05/04/11A-16

Subject Item: SV 004 Corn Elevator Baghouse 1

Associated Items: EU 004 Corn Elevator 1

GP 008 Limited Baghouses

What to do Why to do itTotal Particulate Matter: less than or equal to 0.0030 grains/dry standard cubic foot Title I Condition: To avoid major source classification

under 40 CFR Section 52.21 and Minn. R. 7007.3000;and to avoid major source classification under 40 CFRSection 70.2 and Minn. R. 7007.0200

PM < 10 micron: less than or equal to 0.0030 grains/dry standard cubic foot Title I Condition: To avoid major source classificationunder 40 CFR Section 52.21 and Minn. R. 7007.3000;and to avoid major source classification under 40 CFRSection 70.2 and Minn. R. 7007.0200

Performance Test: due before end of each 60 months starting 10/21/2008 for PM. Title I Condition: To avoid major source classificationunder 40 CFR Section 52.21 and Minn. R. 7007.3000;and to avoid major source classification under 40 CFRSection 70.2 and Minn. R. 7007.0200

Performance Test: due before end of each 60 months starting 10/21/2008 forPM10.


Performance Test Notifications and Submittals;

Performance Test Notification (written): due 30 days before each Performance TestPerformance Test Plan: due 30 days before each Performance TestPerformance Test Pre-Test Meeting: due 7 days before each Performance TestPerformance Test Report: due 45 days after each Performance TestPerformance Test Report - Microfiche Copy or CD: due 105 days after eachPerformance Test.The Notification, Test Plan, and Test Report may be submitted in alternate formatas allowed by Minn. R. 7017.2018.

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


09100060 - 004

Facility Name:

Permit Number:

05/04/11A-17

Subject Item: SV 005 Corn Storage Silo Baghouse 1

Associated Items: EU 005 Scalper

EU 006 Corn Storage Silo 1












09100060 - 004

Facility Name:

Permit Number:

05/04/11A-18

Subject Item: SV 006 EP6













09100060 - 004

Facility Name:

Permit Number:

05/04/11A-19














09100060 - 004

Facility Name:

Permit Number:

05/04/11A-20














09100060 - 004

Facility Name:

Permit Number:

05/04/11A-21














09100060 - 004

Facility Name:

Permit Number:

05/04/11A-22

Subject Item: SV 015 DDGS Handling Baghouse 6

Associated Items: EU 053 DDGS Bucket elevator












09100060 - 004

Facility Name:

Permit Number:

05/04/11A-23

Subject Item: SV 016 DDGS Loadout Baghouse 1

Associated Items: EU 054 DDGS Truck Load Spout












09100060 - 004

Facility Name:

Permit Number:

05/04/11A-24


Associated Items: EU 055 DDGS Rail Load Spout












09100060 - 004

Facility Name:

Permit Number:

05/04/11A-25

Subject Item: SV 019 TO/HRBs



EU 013 Yeast Tank 1

EU 014 Yeast Tank 2




EU 018 Stripper 1

EU 019 Stripper 2

EU 020 Rectifier 1

EU 021 Rectifier 2

EU 022 Evaporator 1

EU 023 Evaporator 2

EU 024 Syrup Tank

EU 025 Centrifuge 1

EU 026 Centrifuge 2

EU 027 Centrifuge 3

EU 028 Centrifuge 4

EU 029 Centrifuge 5

EU 030 Centrifuge 6

EU 031 Centrifuge 7

EU 032 Centrifuge 8







EU 056 DDGS Dryer A


EU 058 DDGS Dryer B


EU 062 DDGS Cooler #1


What to do Why to do itLIMITS hdr

Opacity: less than or equal to 20.0 percent opacity (6-minute average), except forone 6-minute period per hour of not more than 27 percent opacity. The limit appliesat all times, except during periods of startup, shutdown, or malfunction.

This is more stringent than Minn. R. 7011.0610, subp. 1(A)(2).

40 CFR Section 60.43b(f); 40 CFR Section 60.43b(g);Minn. R. 7011.0610, subp. 1(A)(2)

Volatile Organic Compounds: less than or equal to 4.0 lbs/hour using 12-monthRolling Sum as total mass of VOC.


Total Particulate Matter: less than or equal to 8 lbs/hour Title I Condition: To avoid major source classificationunder 40 CFR Section 52.21 and Minn. R. 7007.3000;most stringent, meets limits set by Minn. R. 7011.0610.


09100060 - 004

Facility Name:

Permit Number:

05/04/11A-26

PM < 10 micron: less than or equal to 8 lbs/hour Title I Condition: To avoid major source classificationunder 40 CFR Section 52.21 and Minn. R. 7007.3000;and to avoid major source classification under 40 CFRSection 70.2 and Minn. R. 7007.0200

Carbon Monoxide: less than or equal to 20.0 lbs/hour , based on a 30-day rollingaverage calculated using the total mass emissions for the previous 30 days.


Nitrogen Oxides: less than or equal to 20.9 lbs/hour , based on a 30-day rollingaverage calculated using the total mass emissions for the previous 30 days.


Sulfur Dioxide: less than or equal to 15.0 lbs/hour Title I Condition: To avoid major source classificationunder 40 CFR Section 52.21 and Minn. R. 7007.3000;and to avoid major source classification under 40 CFRSection 70.2 and Minn. R. 7007.0200

PERFORMANCE TESTING REQUIREMENTS hdr

Performance Test: due before end of each 60 months starting 02/27/2009 for PM. Minn. R. 7017.2020, subp. 1


Minn. R. 7017.2020, subp. 1

Performance Test: due before end of each 36 months starting 02/27/2009 for NOx. Minn. R. 7017.2020, subp. 1

Performance Test: due before end of each 60 months starting 10/21/2008 for CO. Minn. R. 7017.2020, subp. 1

Performance Test: due before end of each 60 months starting 10/21/2008 for totalmass VOC emissions including HAPS as outlined in Appendix VI.

Minn. R. 7017.2020, subp. 1


Performance Test Notification (written): due 30 days before each Performance TestPerformance Test Plan: due 30 days before each Performance TestPerformance Test Pre-Test Meeting: due 7 days before each Performance TestPerformance Test Report: due 45 days after each Performance TestPerformance Test Report - Microfiche Copy or CD: due 105 days after eachPerformance Test.The Notification, Test Plan, and Test Report may be submitted in alternative formatas allowed by Minn. R. 7017.2018.



09100060 - 004

Facility Name:

Permit Number:

05/04/11A-27

Subject Item: SV 023 DDGS Bulkweigher Baghouse

Associated Items: EU 067 DDGS Bulkweigher





Initial Performance Test: due 180 days after Initial Startup for PM Title I Condition: To avoid major source classificationunder 40 CFR Section 52.21 and Minn. R. 7007.3000;and to avoid major source classification under 40 CFRSection 70.2 and Minn. R. 7007.0200

Initial Performance Test: due 180 days after Initial Startup for PM10 Title I Condition: To avoid major source classificationunder 40 CFR Section 52.21 and Minn. R. 7007.3000;and to avoid major source classification under 40 CFRSection 70.2 and Minn. R. 7007.0200





09100060 - 004

Facility Name:

Permit Number:

05/04/11A-28

Subject Item: SV 024 DDGS Cross Conveyor Baghouse

Associated Items: EU 068 DDGS Cross Conveyor





Initial Performance Test: due 180 days after Initial Startup for PM Title I Condition: To avoid major source classificationunder 40 CFR Section 52.21 and Minn. R. 7007.3000;and to avoid major source classification under 40 CFRSection 70.2 and Minn. R. 7007.0200

Initial Performance Test: due 180 days after Initial Startup for PM10 Title I Condition: To avoid major source classificationunder 40 CFR Section 52.21 and Minn. R. 7007.3000;and to avoid major source classification under 40 CFRSection 70.2 and Minn. R. 7007.0200





09100060 - 004

Facility Name:

Permit Number:

05/04/11A-29

Subject Item: EU 065 Emergency Fire Pump

Associated Items: SV 021 Emergency Fire Pump

What to do Why to do itOpacity: less than or equal to 20.0 percent opacity Once operating temperatureshave been attained.

Minn. R. 7011.2300, subp. 1

Operating Hours: Less than or equal to 100 hours per year using a 12-month rollingsum for the pump for routine testing and maintenance. The sum for the previous12-month period is to be calculated by the 15th day of each month.

Title I Condition: To avoid major source classificationunder 40 CFR Section 52.21 and Minn. R. 7007.3000;and to avoid major source classification under 40 CFRSection 70.2 and Minn. R. 7007.0200; 40 CFR Section60.4211(e)

Hours of Operation: The Permittee shall record each month the number of hours ofoperation of the fire pump and a monthly record of 12-month rolling sum of thehours of operation.


NSPS SUBPART IIII REQUIREMENTS hdr

Owners and operators of fire pump engines with a displacement of less than 30liters per cylinder must comply with the emission standards in Table 4 to subpartIIII, for all pollutants.

40 CFR Section 60.4205(c); Minn. R. 7011.3520

Effective October 1, 2007, diesel fuel must meet 40 CFR Section 80.510(a);Effective October 1, 2010, diesel fuel must meet 40 CFR Section 80.510(b) fornonroad diesel fuel.

40 CFR Section 60.4207(a) and (b); Minn. R.7011.3520

The engine must be equipped with a nonresettable hours-of-operation meter. 40 CFR Section 60.4209(a); Minn. R. 7011.3520

The Permittee shall keep the records or perform the tests specified in one of themethods specified in 40 CFR Section 60.4211.

40 CFR Section 60.4211(b); Minn. R. 7011.3520

RECORDKEEPING hdr

Hours of Operation: The Permittee shall maintain documentation on site that theunit is an emergency generator by design that qualifies under the U.S.EPAmemorandum entittled "Calculating Potential to Emit (PTE) for EmergencyGenerators" dated September 6, 1995, limiting operation to 500 hours per year.

Minn. R. 7007.0800, subps. 4 and 5

Fuel Supplier Certification: The Permittee shall obtain and maintain a fuel suppliercertification for each shipment of fuel oil, certifying that the fuel oil meets therequirements of 40 CFR Section 80.510(a) or (b).

Minn. R. 7007.0800, subps. 4 and 5


09100060 - 004

Facility Name:

Permit Number:

05/04/11A-30

Subject Item: EU 071 Natural Gas Emergency Generator

What to do Why to do it40 CFR pt. 63, subp. ZZZZ applies to this generator. In accordance with Section63.6590(c) the generator must meet the requirements of this part by meeting therequirements of 40 CFR pt. 60, subp. JJJJ. Since the engine was not manufacturedon or after January 1, 2009, there are no applicable requirements from subp. JJJJfor this emission unit.

40 CFR pt. 63, subp. ZZZZ; Minn. R. 7011.8150

EMISSION LIMITS hdr

Opacity: less than or equal to 20 percent opacity once operating temperatures havebeen attained.

Minn. R. 7011.2300, subp. 1

Sulfur Dioxide: less than or equal to 0.5 lbs/million Btu heat input . Minn. R. 7011.2300, subp. 2


Fuel type: Natural gas only. Minn. R. 7005.0100, subp. 35a

Operating Hours: less than or equal to 500 hours/year using 12-month Rolling Sum. The U.S. EPA memorandum entitled "Calculating Potential to Emit (PTE) forEmergency Generators", dated September 6, 1995, limits operation to 500 hoursper year.

Minn. R. 7007.0800, subps. 4 and 5

RECORDKEEPING REQUIREMENTS hdr

Recordkeeping - Operating Hours: The Permittee shall maintain documentation ofhours of operation of EU071.

Minn. R. 7007.0800, subps. 4 and 5

Reporting: Annually by January 30th the report of the previous 12 monthly12-month rolling sum calculations on the natural gas emergency generator.

Minn. R. 7007.0800, subp. 6


09100060 - 004

Facility Name:

Permit Number:

05/04/11A-31

Subject Item: CE 018 Wet Scrubber - High Efficiency

Associated Items: EU 039 Fermenter 1

EU 040 Fermenter 2

EU 041 Fermenter 3

EU 042 Fermenter 4

EU 043 Fermenter 5

EU 044 Fermenter 6

EU 045 Fermenter 7

EU 046 Fermenter 8

EU 047 Beer Well

EU 069 Yeast Propagation Tank 1


GP 002 Wet Scrubber


Volatile Organic Compounds: less than or equal to 12.5 lbs/hour Title I Condition: To avoid major source classificationunder 40 CFR Section 52.21 and Minn. R. 7007.3000;and to avoid major source classification under 40 CFRSection 70.2 and Minn. R. 7007.0200

Pressure Drop: greater than or equal to 2.0 inches of water column and less than orequal to 10 inches of water column or as determined by the most recentperformance testing that demonstrated compliance with the permitted emissionlimit.


Water flow rate: greater than or equal to 35.0 gallons/minute absolute minimum,unless a new limit is set pursuant to Minn. R. 7017.2025, subp. 3 based on thevalues recorded during the most recent MPCA-approved performance test wherecompliance was demonstrated. The new limit shall be implemented upon receipt ofthe Notice of Compliance letter granting preliminary approval. The limit is final uponissuance of a permit amendment incorporating the change. If the water flow rate isbelow the minimum limit, the VOC emitted during that time shall be considereduncontrolled until the flow rate is above the minimum limit. This shall be reported asa deviation.


Total Fermentation Tank Volume: Limited to 6,517,912 gallons. Minn. R. ch. 4410




Vent all emissions from all fermentation units EU039 through EU047, EU069 andEU070 to the Wet Scrubber (CE018) at all times that the associated units are inoperation.


Record the pressure drop and water flow rate of the scrubber once each day ofoperation.

Minn. R. 7007.0800, subps. 2 and 14

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

Minn. R. 7007.0800, subps. 2 and 14

Monitoring Equipment: The Permittee shall install and maintain the necessarymonitoring equipment for measuring and recording pressure drop as required bythis permit. The monitoring equipment must be installed, in use, and properlymaintained when the monitored scrubber is in operation.

Minn. R. 7007.0800, subp. 4

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

Minn. R. 7007.0800, subp. 14

Calibrate the gauges annually, or as often as required by manufacturingspecifications and maintain a written record of the calibration and any actionresulting from the calibration.

Minn. R. 7007.0800, subps. 2 and 14


09100060 - 004

Facility Name:

Permit Number:

05/04/11A-32

Corrective Actions: The Permittee shall take corrective action as soon as possible ifany of the following occur:- the recorded pressure drop or water flow rate is outside the required operatingrange; or- the scrubber or any of its components are found during the inspections to needrepair.Corrective actions shall return the pressure drop to within the permitted rangeand/or include completion of necessary repairs identified during the inspection, asapplicable. Corrective actions include, but are not limited to, those outlined in the O& M Plan for the scrubber. The Permittee shall keep a record of the type and dateof any corrective action taken for each scrubber.

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

PERFORMANCE TESTING hdr







09100060 - 004

Facility Name:

Permit Number:

05/04/11A-33

Subject Item: CE 023 Flaring



EU 066 Loadout Flare

What to do Why to do itOpacity: The Flare shall be operated so that there are no visible emissions fromthe stack (SV022).

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

Emissions from the ethanol loadout units (EU060 and EU061) will be controlled bythe flare (CE023) that shall meet 98 percent control efficiency.

Minn. R. 7007.0800, subp. 2

Fuel Usage: The flare shall be used only with the net heating value of the gasbeing combusted being 300 Btu/scf or greater if the flare is steam-assisted orair-assisted; or with the net heating value of the gas being combusted being 200Btu/scf or greater if the flare is non-assisted.

Minn. R. 7007.0800, subp. 2

The flare shall be operated at all times when emission units may be vented to them.Vent emissions from all units controlled by the flare EU066, through the flare at alltimes that the associated units are in operation.

Minn. R. 7007.0800, subp. 2

The presence of a flare pilot flame shall be monitored using a thermocouple or anyother equivalent device to detect the presence of a flame.

Minn. R. 7007.0800, subp. 2

Visible Emissions: The Permittee shall check the flare stack (SV 022) for anyvisible emissions once each day of operation during daylight hours. The Permitteeshall keep a written record of each daily observation.

Minn. R. 7007.0800, subps. 4 and 5


09100060 - 004

Facility Name:

Permit Number:

05/04/11A-34

Subject Item: FS 001 Truck Traffic

What to do Why to do itTruck Traffic: less than or equal to 401 trucks/day when the cooling towers andhammermills are not operating or 345 trucks per day when the cooling towers andhammermills are operating during the months of April through November.


Truck Traffic: less than or equal to 371 trucks/day when the cooling towers andhammermills are not operating or 315 trucks per day when the cooling towers andhammermills are operating during the months of December through March.


Recordkeeping: The Permittee shall record the number of grain delivery trucksentering the facility each calendar day and keep these records on-site.


Truck Traffic: Annual DDGS loadout will be limited to 50 percent truck loadout or180,000 tons of DDGS loadout by truck per year. Wetcake (DGS) may be shippedout by truck. For wetcake, the equivelent dry weight shall be used to demonstratecompliance with the 180,000 ton limit.


Recordkeeping: The Permittee shall record the number of DDGS loadout trucksentering the facility each calendar day and keep these records on-site.


Truck Traffic: Annual denatured/undenatured ethanol loadout will be limited to61,950,000 gallons of denatured/undenatured ethanol loadout by truck per year.


Recordkeeping: The Permittee shall record the number of ethanol loadout trucksentering the facility each calendar day and keep these records on-site.


Truck Traffic: Annual denaturant delivery will be limited to 50 percent truck loadoutor 2,950,000 gallons of denaturant delivery by truck per year.


Recordkeeping: The Permittee shall record the number of denaturant deliverytrucks entering the facility each calendar day and keep these records on-site.


Recordkeeping: The Permittee shall record the number and type of receiving andhauling trucks entering the facility each calendar day and keep these recordson-site.


Fugitive Emissions: Do not cause or permit the transporting of any material in amanner which may allow avoidable amounts of particulate matter to becomeairborne. Do not cause or permit a road or a driveway to be constructed, used,repaired or demolished without applying all such reasonable measures as may berequired to prevent particulate matter from becoming airborne.

Minn. R. 7011.0150

Abide by the Fugitive Dust Control Plan in Appendix II. Minn. R. 7011.0150

Initial Performance Test: due before 07/31/2009 for paved road silt load. 40 CFR Section 52.21 and Minn. R. 7009.0020

Performance Test: due before end of each calendar half-year starting 02/27/2009for paved road silt load. The Initial Performance Test is due by July 31, 2009. Allsubsequent tests shall be performed in January and July of each calendar year.The tests shall be conducted in accordance with EPA guidance in Appendix C.1and Appendix C.2 of AP42. The Permittee shall keep records of silt loading testing.If tested silt loading values together with other paved roads terms (e.g. vehicleweight, vehicle speed) yields PM10 emission factors (pounds pervehicle-mile-traveled, lb/vmt) that are found to be greater than those assumed inthe most recent approved modeling, then the road cleaning (sweeping andvacuuming) frequency will be revised so that lb/vmt values are low enough tocomport with the most recent approved modeling (December 17, 2008).

40 CFR Section 52.21 and Minn. R. 7009.0020


09100060 - 004

Facility Name:

Permit Number:

05/04/11A-35

Subject Item: FS 002 DDGS Storage Building

What to do Why to do itOpacity: less than or equal to 5.0 percent opacity for fugitive emissions from DDGShandling activities or DDGS railcar loading.

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

Opacity: less than or equal to 10.0 percent opacity for fugitive emissions fromDDGS truck loading.

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

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

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


09100060 - 004

Facility Name:

Permit Number:

05/04/11A-36

Subject Item: FS 003 Uncaptured Emissions from DDGS Handling

What to do Why to do itOpacity: less than or equal to 5.0 percent opacity for fugitive emissions from DDGShandling activities or DDGS railcar loading.

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

Opacity: less than or equal to 10.0 percent opacity for fugitive emissions fromDDGS truck loading.

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

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

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


09100060 - 004

Facility Name:

Permit Number:

05/04/11A-37

Subject Item: FS 004 Equipment Leaks

What to do Why to do itSTANDARDS: PUMPS hdr

Pumps in light liquid service:

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

Each pump in light liquid service shall be checked by visual inspection eachcalendar week for indications of liquids dripping from the seal.

40 CFR Section 60.482-2Minn. R. 7011.2900

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

If there are indications of liquids dripping from the pump seal, a leak is detected.

When a leak is detected, it shall be repaired as soon as practicable, but not laterthan 15 calendar days after it is detected, except as provided in 40 CFR Section60.482-9 (Delay of Repair).

A first attempt at repair shall be made no later than 5 calendar days after each leakis detected.

40 CFR Section 60.482-2(b) and (c)Minn. R. 7011.2900

STANDARDS: COMPRESSORS hdr

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

40 CFR Section 60.482-3(a)Minn. R. 7011.2900

Each compressor seal system shall be:

- Operated with the barrier fluid at a pressure that is greater than the compressorstuffing box pressure; or

- Equipped with a barrier fluid system that is connected by a closed vent system toa control device that complies with the requirements of 40 CFR Section 60.482-10;or

- Equipped with a system that purges the barrier fluid into a process stream withzero VOC emissions to the atmosphere.

40 CFR Section 60.482-3(b)Minn. R. 7011.2900

The barrier fluid system shall be in heavy liquid service or shall not be in VOCservice.

Each barrier fluid system shall be equipped with a sensor that will detect failure ofthe seal system, barrier fluid system, or both.

40 CFR Section 60.482-3(c) and (d)Minn. R. 7011.2900

Each sensor shall be checked daily or shall be equipped with an audible alarm.

The Permittee shall determine, based on design considerations and operatingexperience, a criterion that indicates failure of the seal system, the barrier fluidsystem, or both.

40 CFR Section 60.482-3(e)Minn. R. 7011.2900

If the sensor indicates failure of the seal system, the barrier system, or both basedon the criterion determined under paragraph 40 CFR Section 60.482-3(e)(2), a leakis detected.

40 CFR Section 60.482-3(f)Minn. R. 7011.2900

When a leak is detected, it shall be repaired as soon as practicable, but not laterthan 15 calendar days after it is detected except as provided in 40 CFR Section60.482-9 (Delay of Repair).

A first attempt at repair shall be made no later than 5 calendar days after it isdetected, except as provided in 40 CFR Section 60.482-9.

40 CFR Section 60.482-3(g)Minn. R. 7011.2900

STANDARDS: PRESSURE RELIEF DEVICES IN GAS/VAPOR SERVICE hdr

Except during pressure releases, each pressure relief device in gas/vapor serviceshall be operated with no detectable emissions, as indicated by an instrumentreading of less than 500 ppm above background as determined by the methodsspecified in 40 CFR Section 60.485(c).


After each pressure release, the pressure relief device shall be returned to acondition of no detectable emissions, as indicated by an instrument reading of lessthan 500 ppm above background, as soon as practicable, but no later than 5calendar days after the pressure release, except as provided in 40 CFR Section60.482-9 (Delay of Repair).

40 CFR Section 60.482-4(b)Minn. R. 7011.2900

STANDARDS: VALVES hdr


09100060 - 004

Facility Name:

Permit Number:

05/04/11A-38

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

The cap, blind flange, plug, or second valve shall seal the open end at all timesexcept during operations requiring process fluid flow through the open-ended valveor line.


Each open-ended valve or line equipped with a second valve shall be operated in amanner such that the valve on the process fluid end is closed before the secondvalve is closed.

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

40 CFR Section 60.482-6(b) and (c)Minn. R. 7011.2900


09100060 - 004

Facility Name:

Permit Number:

05/04/11A-39

Subject Item: FS 005 Cooling Towers

What to do Why to do itThe cooling tower fans are not to be operating while corn is being shipped fromCargill AgHorizons.


Daily Recordkeeping. At any time that grain is shipped from the Cargill AgHorizonsfacility, the Permittee shall record and maintain a record of the dates and timeswhich the cooling tower fans are not operating.



09100060 - 004

Facility Name:

Permit Number:

05/04/11A-40

Subject Item: FS 006 Wet Cake Storage

What to do Why to do itWetcake storage limitation: When wetcake by-product is produced, and ambienttemperature is greater than 55 degrees Fahrenheit, it will be stored for no longerthan 72 hours on-site, except in unforeseen cases of product shipmentcancellations, holidays, or weekends in which the recipient of the wetcake is unableto pick up the material. Under these unforeseen conditions, the wetcake will not bestored on site more than 5 calendar days. In all cases, the wetcake will be movedoff-site as soon as possible.

Time stored onsite is determined for each storage period by dividing the totalamount of wetcake put into storage during the storage period (either 3 or 5calendar days depending on the circumstances) by the average daily amountshipped offsite during the same period.

Minn. R. 7007.0800, subp. 2

Cont.

The Permittee shall keep a record of the amount of wetcake sent to storage eachday and the amount shipped offsite each day. The Permittee will also keep recordsof any circumstances that require the wetcake to be stored more than 72 hours.

Minn. R. 7007.0800, subp. 2

TABLE B: SUBMITTALSFacility Name: Buffalo Lake Energy LLC

Permit Number: 09100060 - 004

05/04/11B-1

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

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

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

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

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

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

Send any application for a permit or permit amendment to:

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

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

Unless another person is identified in the applicable Table, send all other submittals to:

AQ Compliance Tracking Coordinator Industrial Division Minnesota Pollution Control Agency 520 Lafayette Road North St. Paul, Minnesota 55155-4194

TABLE B: ONE TIME SUBMITTALS OR NOTIFICATIONSFacility Name: Buffalo Lake Energy LLC


05/04/11B-2

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

PermitTotal Facility

Notification of the Actual Date of Initial Startup due 15 days after 05/15/2008 This notificationhas been submitted and was received by theMPCA on 6/2/2008.

GP004

Notification of the Actual Date of Initial Startup due 15 days after Initial Startup GP005

Notification of the Date Construction Began due 30 days after Start Of Construction.Submit the name and number of each unitand the date construction of each unit began.

GP005

Testing Frequency Plan due 60 days after Initial Performance Test forPM emissions. The plan shall specify atesting frequency based on the test data andMPCA guidance. Future performance testsbased on one-year (12 month), 36 month, and60 month intervals, or as applicable, shall berequired upon written approval of the MPCA.

SV023, SV024

Testing Frequency Plan due 60 days after Initial Performance Test forPM10 emissions. The plan shall specify atesting frequency based on the test data andMPCA guidance. Future performance testsbased on one-year (12 month), 36 month, and60 month intervals, or as applicable, shall berequired upon written approval of the MPCA.

SV023, SV024

TABLE B: RECURRENT SUBMITTALSFacility Name: Buffalo Lake Energy LLC


05/04/11B-3

What to send When to send Portion of Facility AffectedCylinder Gas Audit (CGA) Results Summary due 30 days after end of each calendar

quarter following end of the calendar quarterin which the Audit was performed

GP004

Excess Emissions/Downtime Reports (EER's) due 30 days after end of each calendarquarter following Initial Startup of the Monitor(Submit Deviations Reporting Form DRF-1 asamended). The EER shall indicate all periodsof monitor bypass and all periods ofexceedances of the limit includingexceedances allowed by an applicablestandard, i.e. during startup, shutdown, andmalfunctions.

GP004

Semiannual Deviations Report due 30 days after end of each calendarhalf-year starting 08/24/2006 . The firstsemiannual report submitted by the Permitteeshall cover the calendar half-year in which thepermit is issued. The first report of eachcalendar year covers January 1 - June 30.The second report of each calendar yearcovers July 1 - December 31. If no deviationshave occured, the Permittee shall submit thereport stating no deviations.

Total Facility

Compliance Certification due 31 days after end of each calendar yearstarting 08/24/2006 (for the previous calendaryear). To be submitted to the Commissioneron a form approved by the Commissioner.This report covers all deviations experiencedduring the calendar year.

Total Facility

Relative Accuracy Test Audit (RATA) ResultsSummary

due 45 days after end of each calendar yearfollowing CEMS Relative Accuracy Test Audit(RATA)

GP004

APPENDIX MATERIAL Facility Name: Buffalo Lake Energy LLC Permit Number: 09100060-004

Appendix I:

Insignificant Activities and Applicable Requirements

The table below lists the insignificant activities that are currently at the facility and their associated general applicable requirements.

Minn. R. 7007.1300,

subpart Rule Description of the Activity

Applicable Requirement

3(A) Fuel use: space heaters fueled by natural gas or propane. These space heaters will have less than 30,000 BTU/hr heating capacity.

Minn. R. 7011.0510/0515

3(J) Fugitive Emissions from roads and parking lots. Main facility haul roads will be paved. Unpaved pull-offs may exist but are not used on a regular basis.

Minn. R. 7011.0150

3(K) Infrequent use of spray paint equipment for routine housekeeping or plant upkeep activities not associated with primary production processes at the stationary source, such as spray painting of buildings, machinery, vehicles, and other supporting equipment.

Minn. R. 7011.0710/0715

Appendix II:

Haul Roads Fugitive Dust Control Plan

Buffalo Lake Energy, LLC

TABLE OF CONTENTS Section Page

1.0 INTRODUCTION ................................................................................................... 1 2.0 HAUL ROADS ....................................................................................................... 2 3.0 GRAIN HANDLING ................................................................................................ 3 4.0 DDGS HANDLING ................................................................................................. 4 5.0 WET CAKE PRODUCTION ...................................................................................... 5 6.0 EQUIPMENT LEAKS ............................................................................................... 6

1.0 INTRODUCTION

Buffalo Lake Energy, LLC (BLE) received an air construction permit (Permit Number 09100060-001) on August 24, 2006 to construct a 118 million gallon per year ethanol production facility to be located in Fairmont, Minnesota. Subsequent permits were issued to BLE for revisions to the facility design and operation (permit Numbers 09100060-002 and 09100060-003). As required by these permits, a Fugitive Emissions Control Plan must be submitted to the agency identifying all fugitive emissions sources, primary and secondary contingent control measures, and record keeping procedures. Fugitive emissions emitted at this site may be particulate matter (PM) or volatile organic compounds (VOC). The following operations with the potential to create fugitive dust emissions are required to be included in the Plan.

• Haul Roads • Grain Handling • DDGS Handling • Wet Cake Production • Equipment Leaks

The Plan has been completed to fulfill air permit requirements stated in the “Total Facility” section on the permit.

1. Haul Roads Fugitive Dust Control Plan This section outlines the truck haul road fugitive emissions control measures that will be

implemented at BLE.

1.1 Description of Fugitive Emission Source

Through the hauling process, fugitive dust is generated from the contact between the roads and the vehicle tires causing the re-suspension of loose material on the road surface. The following operations will have the potential of generating fugitive dust emissions:

• Grain Receiving Haul Trucks • Grain Shipping Haul Trucks • DDGS Shipping Haul Trucks • Denaturant Receiving Haul Trucks • Ethanol Shipping Haul Trucks

1.2 Control Measures

BLE proposes the following control measures to mitigate emissions from the truck hauling activities at the site:

• Haul roads at the site will be paved; • The north entrance to the facility will be swept and vacuumed twice daily as

illustrated in Appendix V of the Air Permit; • Visual inspections of the haul roads will be performed daily; • Haul roads at the site will be swept and vacuumed weekly or when silt has

accumulated to visible levels on the road; • Signage will be posted to limit the truck traffic speed to 10 miles/hour; • The total number of vehicles hauling materials will be limited as stated in the

permit; In addition to the above control measures, the facility will conduct a vacuum test of the silt loading semiannually. The first test will be completed within 12 months of initial startup and all subsequent tests will occur in July and January in order to collect data during both normal baseline conditions and winter baseline conditions, respectively. The MPCA will be notified of the testing procedure under a submitted testing protocol. The results of the test will be kept on file and provided to the MPCA upon request.

1.3 Record Keeping

The number of haul vehicles traveled on the roads will be recorded as stated in the permit. The silt loading values from the semiannual testing will be recorded and kept on file.

2. Grain Handling

This section outlines the fugitive emissions control measures that will be implemented at BLE during the grain handling operations. 2.1 Description of Fugitive Emission Source Fugitive dust is generated during the grain handling process. Fugitive dust may be emitted when the grain is received, transferred, or stored. 2.2 Control Measures BLE proposes the following control measures to mitigate emissions from the grain handling activities at the site:

• All grain receiving and transfer points will be controlled by a high efficiency fabric filter baghouse; the baghouses will provide at least a 99% control efficiency;

• Receiving and loadout areas are within a building structure to limit disturbance from wind;

• If grain is spilled, the areas will be cleaned. •

2.3 Record Keeping Parameters related to the baghouse operations will be recorded as stated in the air permit. The baghouses will be monitored daily for any visible emissions and at least once per year the control units will be inspected for potential malfunctions. All data related to the monitoring and inspections will be maintained and filed.

3. DDGS Handling

This section outlines the fugitive emissions control measures that will be implemented at BLE during the dried distillers grain with solubles (DDGS) handling operations. 3.1 Description of Fugitive Emission Source Fugitive dust is generated during the DDGS handling process. Fugitive dust may be emitted when the DDGS is transferred, stored, or during loadout. 3.2 Control Measures BLE proposes the following control measures to mitigate emissions from the grain handling activities at the site:

• All DDGS transfer points and loadout operations will be controlled by a high efficiency fabric filter baghouse; the baghouses will provide at least a 99% control efficiency;

• The DDGS will be stored in an enclosed building and transferred via enclosed conveyors to the DDGS loadout area;

• The loadout area is within a building structure to limit disturbance from wind; • If DDGS is spilled, the area will be cleaned; • The DDGS handling and rail loadout operations will be limited to 5.0% opacity; • The DDGS truck loadout operations will be limited to 10.0% opacity.

3.3 Record Keeping Parameters related to the baghouse operations will be recorded as stated in the air permit. The baghouses will be monitored daily for any visible emissions and at least once per year the control units will be inspected for potential malfunctions. All data related to the monitoring and inspections will be maintained and filed.

4. Wet Cake Production

This section outlines the fugitive emissions control measures that will be implemented at BLE during the wet cake production operating scenario. 4.1 Description of Fugitive Emission Source BLE has a secondary operating scenario of wet cake production rather than drying the byproduct to DDGS. The wet cake is stored on an open cement storage area. Fugitive emissions generated during the wet cake production process include PM and VOC emissions. 4.2 Control Measures BLE proposes the following control measures to mitigate emissions from the wet cake production activities at the site:

• The wet cake will be stored no longer than permitted and the material will be sold and shipped as quickly as possible;

4.3 Record Keeping The facility will record the amount of wet cake produced on an annual basis. Buffalo Lake Energy, LLC

5. Equipment Leaks

This section outlines the fugitive emissions control measures that will be implemented at BLE to limit the amount of VOC emissions from equipment leaks. 2.1 Description of Fugitive Emission Source Units with the potential to emit VOC emissions are controlled through wet scrubbing, thermal oxidation, or flaring. The pipes that connect these units have the potential to emit VOC emissions through leaks at the valves or other connection points. 2.2 Control Measures BLE proposes the following control measures to mitigate emissions from equipment leaks at the site:

• The facility will operate in compliance with New Source Performance Standard • Subpart VV as stated in the permit and summarized below: • Each pump in light liquid service will be monitored monthly to detect

potential leaks, • Each pump in light liquid service will be checked by visual inspection on a

weekly basis, • Each compressor will be equipped with a seal system that includes a

barrier fluid system to prevent leakage, • The barrier sensor will be checked daily or will be equipped with an alarm, • Except during pressure releases, all pressure relief devices in gas/vapor

service will operate with no detectable emissions, • Each open ended valve or line will be equipped with a cap, flange, plug or

a second valve, • All leaks will be repaired as stated in the permit

2.3 Record Keeping All detected leaks will be recorded on the date of detection. The day the leak is repaired will be recorded and filed.

Appendix III:

Modeling Inputs MPCA Dispersion Modeler: Lance Breitenbach Date: July 2008 Other dates of importance: Site visit August 2008 Project Facility: Buffalo Lake Energy, LLC Fairmont, MN, Cargill AgHorizons, Fairmont Modeling was submitted by Natural Resource Group on behalf of Buffalo Lake Energy, LLC and Cargill AgHorizons. This location is considered one source with two permits. I recommend that the air dispersion modeling for the Buffalo Lake Energy and Cargill facility be accepted; the modeling represents an accurate depiction of the facility. Modeling Comments

• 280 Trucks per day summer, 250 in winter. • There is no fence completely surrounding the facility to prohibit the public from getting on site. Indicate what measures are being taken

to restrict public access from the site. Railroad tracks are not considered a physical barrier. • Modeling was done for hours of operation of 0600-2100. • BLE was unable to achieve 1 SIL of future growth so any future changes will need to be modeled. • Modeling Parameters used Alternate 1 PM10 24hr:

*** POINT Source DATA *** Number Emission Rate BASE STACK STACK STACK STACK BLDG URBAN Cap/ EMIS RATE SOURCE PART. (g/s) X Y ELEV. HEIGHT TEMP. EXIT Vel. DIAMETER EXISTS SOURCE Hor SCALAR ID CATS. (Meters) (Meters) (Meters) (Meters) (DEG.K) (M/SEC) (Meters) VARY BY CHSSV001 0 1.48E-01 378610.9 4836087 366.7 48.77 294.26 20.1 1.17 YES NO NO CHSSV002 0 1.40E-02 378608 4836095 366.7 49.68 299.82 17.5 0.3 YES NO NO CHSSV003 0 1.40E-02 378599 4836103 366.7 49.68 299.82 17.5 0.3 YES NO NO CHSSV004 0 5.42E-03 378601 4836089 366.7 6.1 299.82 14.8 0.2 YES NO NO

CHSSV005 0 2.43E-02 378529 4836116 366.7 39.62 299.82 17.39 0.51 YES NO NO CHSSV006 0 1.47E+00 378555 4836108 366.7 54.86 327.44 17.48 2.06 YES NO NO CHSSV007 0 8.10E-02 378540 4836107 366.7 39.62 299.82 17.13 0.73 YES NO NO CHSSV008 0 1.40E-01 378546 4836102 366.7 39.62 299.82 16.17 0.61 YES NO NO CHSSV009 0 4.90E-02 378551 4836097 366.7 39.62 299.82 17.13 0.73 YES NO NO CHSSV010 0 9.80E-03 378607 4836103 366.7 48.77 299.82 18.19 0.24 YES NO NO CHSSV011 0 6.60E-03 378595 4836094 366.7 48.77 299.82 17.82 0.2 YES NO NO CHSSV012 0 2.17E-01 378613.5 4836090.5 366.7 48.77 299.82 19.96 1.42 YES NO NO CHSSV013 0 9.68E-01 378510 4836174 366.7 42.67 310.93 22 1.52 YES NO NO CHSSV015 0 2.53E-01 378518 4836098 366.7 48.77 422.04 16.49 1.07 YES NO NO CHSSV020 0 1.81E-02 378495 4836084 366.7 10.67 449.82 16.1 0.53 YES NO NO CHSSV021 0 9.00E-03 378412 4836030 366.7 27.43 422.04 11.6 0.3 YES NO NO CHSSV022 0 9.00E-03 378422 4836022 366.7 27.43 422.04 11.6 0.3 YES NO NO CHSSV023 0 4.28E-03 378397 4836054 366.7 13.11 299.82 11.5 0.2 YES NO NO CHSSV016 0 2.53E-01 378525 4836103 366.7 48.77 422.04 16.5 1.07 YES NO NO CHSSV024 0 2.53E-01 378521 4836108 366.7 48.77 422.04 16.5 1.07 YES NO NO LFJSV001 0 3.28E+00 351758.5 4851120 396 15.85 632 19.81 4.5 NO NO NO LFJSV002 0 3.28E+00 351802.4 4851120 396 15.85 632 19.81 4.5 NO NO NO LFJSV003 0 3.28E+00 351885.6 4851118 396 15.85 632 19.81 4.5 NO NO NO LFJSV004 0 3.28E+00 351928.8 4851117 396 15.85 632 19.81 4.5 NO NO NO LFJSV005 0 3.28E+00 352012.7 4851117 396 15.85 632 19.81 4.5 NO NO NO LFJSV006 0 3.28E+00 352056.6 4851116 396 15.85 632 19.81 4.5 NO NO NO VSWSV005 0 1.26E+00 372503 4835768 372 38.1 394.26 13.72 3.05 YES NO NO VSWSV006 0 5.75E-04 372455.4 4835878.5 372 10.67 699.82 13.72 1.22 YES NO NO VSWSV019 0 2.88E-02 372544.6 4835775 372 12.19 0 20.18 1.52 YES NO NO VSWSV001 0 2.70E-01 372654.7 4835880 372 12.19 0 26.36 1.07 YES NO NO VSWSV002 0 5.41E-02 372618.9 4835882.5 372 12.19 0 5.18 1.07 YES NO NO VSWSV003 0 1.30E-01 372651.9 4835826 372 12.19 0 12.5 1.07 YES NO NO VSWSV007 0 7.68E-02 372390.8 4835714.5 372 8.53 0 0.15 9.14 YES NO NO VSWSV008 0 7.68E-02 372403.7 4835713.5 372 8.53 0 0.15 9.14 YES NO NO VSWSV009 0 7.68E-02 372416.4 4835713 372 8.53 0 0.15 9.14 YES NO NO VSWSV010 0 7.68E-02 372429.4 4835712.5 372 8.53 0 0.15 9.14 YES NO NO EP4 0 8.69E-03 379038.6 4835651 365.3 14.63 0 0 0.37 YES NO NO EP5 0 8.06E-03 379046.7 4835658.5 365.4 45.72 0 0 0.31 YES NO NO EP15 0 4.41E-03 379234.9 4835615.5 365.8 16.46 0 0 0.24 YES NO NO EP16 0 5.80E-03 379182 4835558.5 365.8 15.24 0 13.76 0.28 YES NO NO *** POINT Source DATA *** NUMBER EMISSION RATE BASE STACK STACK STACK STACK BLDG URBAN CAP/ EMIS RATE

SOURCE PART. (GRAMS/SEC) X Y ELEV. HEIGHT TEMP. EXIT Vel. DIAMETER EXISTS SOURCE HOR SCALAR ID CATS. (METERS) (METERS) (METERS) (METERS) (DEG.K) (M/SEC) (METERS) VARY BY EP17 0 5.80E-03 379180.9 4835551.5 365.8 15.24 0 8.36 0.36 YES NO NO EP19 0 7.19E-01 379254.8 4835760 365.8 42.67 408.15 23.5 1.89 YES NO NO EP102 0 3.48E-02 378982.8 4835577 364.3 43.28 0 0 0.69 YES NO NO EP103 0 4.95E-02 378991.9 4835579 364.7 15.24 0 23.7 0.76 YES NO NO FIREPUMP 0 6.70E-03 379213.4 4835799.5 365.8 3.15 699.82 0 0.22 YES NO NO EP102PA 0 -3.48E-02 378983.2 4835577 364.3 44.81 0 16.78 0.76 YES NO NO SV022 0 1.64E-03 379195.6 4835582.5 365.8 16.31 0 0 0.13 YES NO NO SV023 0 6.80E-03 379190.8 4835579.5 365.8 17.53 0 0 0.37 YES NO NO EP104 0 5.04E-02 378972.1 4835571.5 363.8 50.9 0 55.16 0.51 YES NO NO *** VOLUME Source DATA *** NUMBER EMISSION RATE BASE RELEASE INIT. INIT. URBAN Emission Rate SOURCE PART. (GRAMS/SEC) X Y ELEV. HEIGHT SY SZ SOURCE Scalar Vary ID CATS. (Meters) (Meters) (Meters) (Meters) (Meters) (Meters) BY FS101 0 1.15E-03 379165.3 4835635 365.8 5.33 31.88 4.97 NO FS003 0 4.16E-04 379161.5 4835558.5 365.8 2.29 1.7 2.27 NO FS002 0 4.16E-04 379245.8 4835567 365.8 2.13 0.85 1.98 NO FS105/2A 0 5.67E-03 378983.7 4835595 364.4 2.29 1.7 2.27 NO FS105/2B 0 5.67E-03 378977.1 4835595.5 364.2 2.29 1.7 2.27 NO EP101PA 0 -6.39E-01 379008.5 4835578 365.3 25.6 5.79 7.94 NO FS101PA 0 -1.15E-03 379160.2 4835634.5 365.8 5.33 31.88 4.97 NO F105/2AP 0 -5.90E-03 378983.5 4835594.5 364.4 2.29 1.7 2.27 NO F105/2BP 0 -5.90E-03 378977.2 4835596 364.2 2.29 1.7 2.27 NO CONVPA 0 -3.42E-02 378985 4835588 364.4 40.23 1.42 1.42 NO STORPA 0 -9.49E-03 378974.8 4835588.5 364.1 40.23 0.7 1.42 NO STOR2PA 0 -9.49E-03 378953 4835582 363.6 40.23 0.71 1.42 NO FS104PA 0 -6.33E-03 378977.2 4835564.5 363.9 4.57 0.28 0.28 NO CONV2PA 0 -3.42E-02 378964.7 4835591 363.9 40.23 1.42 1.42 NO CONV3PA 0 -3.42E-02 378935.6 4835600.5 363.5 20 1.42 1.42 NO

• Modeling Parameters used Alternate 2 PM10 24hr:

Appendix IV:

Truck Traffic

Fence Diagram

Appendix V:

Daily Sweeping and Vacuuming Road Segments

Appendix VI:

HAP Performance Testing

When conducting performance testing for HAP, the Permittee must test for: CO2 Scrubber and Process Scrubber Compounds: ethanol, acetaldehyde, ethyl acetate, isoamyl alcohol, acetic acid, acrolien, formaldehyde, and methanol Cooling Cyclone and RTO Compounds: acetaldehyde, ethyl acetate, methanol, ethanol, acetone, 2,3-butadione, formaldehyde, isoamyl alcohol, acetic acid, furfural, 2,3-butanediol, formic acid, and acrolien Additional chemicals may be required by the MPCA Performance Test Coordinator.

Appendix VII:

Best Management Practices

for

Odor Prevention

Table of Contents Section Page

Possible Sources of Odors Emissions .......................................................................................................1

Operation and Maintenance Requirements……………………………...............................................................2

Equipment Failure and Response Analysis...............................................................................................3

Notification...............................................................................................................................................3

General Comments regarding Odors

This best management practices (BMP) odor prevention plan is intended to meet the requirements of Minnesota Pollution Control Agency (MPCA) Air Emission Permit Program (permit applied for) regarding any potential odors. This BMP plan is contingent on the construction and subsequent operation of the proposed facility. The facility is intended to operate continuously (24 hours per day) and is expected to produce minimal odor during normal operations. Any possible exposure to malodorous emissions beyond the property boundaries, considering the intensity, frequency, and duration, will be a function of the prevailing weather conditions such as temperature, wind direction, wind speed, and humidity. These odor characteristics may also be affected by unpredicted and undesirable process upsets. In the event that odors from the facility occur during normal operations, the response portion of this plan will be implemented once the odor compliant is validated by the local governing unit (LGU) or MPCA. This plan describes the response the facility will take if odor complaints, validated by the LGU or MPCA, occur. The plan also describes the potential odor sources and the odor abatement best management practices and controls in place to minimize or negate the possibility of odors at all times.

I. Possible Sources of Odors

Batch Fermentation. Fermentation of sugar produces ethanol and also carbon dioxide (CO2) as a major by-product. Fermentation occurs in batch fermentation tanks. The vents of the fermentation tanks are routed to a CO2 scrubbing system. The CO2 Scrubber uses water to clean the gases. CO2 and other non-condensing gases leaving the scrubber are vented to the atmosphere. The water absorbs a high percentage of volatile organic compounds (VOC) which are the primary source of odors at this type of facility. Distillation/Dehydration. The beer resulting from fermentation runs through a distillation system to remove the spent grain and water from the ethanol. The exhaust gases from the distillation process as well as gases from the slurry preparation (prior to fermentation) and mash cooling (after fermentation) are directed to a thermal oxidizer prior to venting to the atmosphere. Thermal oxidizers destroy VOC by combustion, eliminating most of the odor from this part of the plant. Dried Distillers Grain Drying and Handling. Distillers grain is dried in a ring dryer system. A portion of the exhaust from the dryer is recycled to the inlet of the dryer to recover energy and provide a lower temperature drying environment. Exhaust gases not recycled to the dryer inlet are vented to the thermal oxidizer to destroy VOC and odor. Ethanol Storage Tanks. The product is pumped daily from the day tanks to the ethanol storage tanks. All storage tanks will be located above ground in a lined, secondary containment area. Each tank has a floating roof to reduce evaporative loss from the tank, which in turn reduces odors.

Fugitive & Miscellaneous Emissions. Potential fugitive emissions have been considered for all applicable processes, including but not limited to grain handling and milling, feed transfers, piping components, product loading, and on-site roads. Additional emissions (summarized here as miscellaneous) have also been quantified in the air permit application package. Such emissions include the cooling tower, emergency fire water pump, and industrial flares. Wet Cake (Distillers Grains) – Wet cake will be sold and shipped as quickly as possible to avoid the potential for odor impacts near the facility. Wet cake will not be stored for longer than permitted. Wetcake is a fast-turnaround product that is not typically produced unless there is an immediate plan to ship it out to a customer.

Other emissions sources – All other emission sources planned for the facility were evaluated as having insignificant odor potential. These include: corn unloading and DDGS loading, corn milling, DDGS cooling, maintenance activities, warehousing and transport engines, fire control equipment, office and janitorial activities, heating, small engine fuel storage, water for boilers, and sewer plumbing.

II. Operation and Maintenance Requirements

Daily operational checks as well as monthly and quarterly maintenance schedules will be performed and recorded based on the air operating permit requirements and manufacturer specifications. These schedules will occur according to operation and maintenance plans and Best Management Practices as summarized below. The following items must be maintained for each unit:

DDGS Dryer System-

Burner control system and the mechanical components of the conveyors. Fans, conveyors, drive motors, and centrifuges are inspected per manufacturer’s specifications. Status of drive motors, conveyors, and fans is recorded per maintenance management procedures.. Wet Scrubbers- Operational checks are performed on the circulation pumps and packing as needed. Scrubber level, differential pressure, water flow rate and other operational data is reviewed and recorded daily or as required by the manufacturer.. Wet Cake (Distillers Grains)

• Record wet cake production daily.

2

III. Equipment Failure and Response

In the event of a process or odor control equipment breakdown, the facility will comply with MN Rules 7019.1000 and will use this document as the “compliance document.” The following steps will be taken in the event of process or odor control equipment failure:

DDGS Dryer System If the dryer system is not operating, the minimum operating conditions for this process will be production of wet cake limited by livestock feed markets.

Wet cake (stillage) The minimum operating conditions for storage of this wet cake include: Wet cake would not be stored for longer than permitted on site, unless the ambient temperature is below 55 °F, or The facility will sell the wet cake as soon as possible or transport the wet cake offsite for land application or agricultural bagging. Distillers wet or dry grain is a valuable co-product. It would not be economical to produce distillers’ grains without a market or sale of the product. Spoiled product is not suitable for sale to DDGS customers, so it must be avoided.

Fermentation Vessels Failure or malfunction of the CO2 scrubber – If the scrubber is to fail, fermentation continues for up to 48 hours for batch completion. However, fermentation would be suspended thereafter; until the scrubber is operable.

IV. Notification

If the facility does not follow the aforementioned response steps, the commissioner must be notified within 24 hours of the breakdown of more than one hour as specified in MN Rules 7019.1000. The plant electronic or written logs will serve as the record of compliance. Such records may include work orders or revised procedures for maintenance of odor abatement operations.

Technical Support Document, Permit Action Number: 09100060 - 004 Page 1 of 10 Date: 5/4/2011

TECHNICAL SUPPORT DOCUMENT For

AIR EMISSION PERMIT NO. 09100060-004 This technical support document (TSD) is intended for all parties interested in the permit and to meet the requirements that have been set forth by the federal and state regulations (40 CFR § 70.7(a)(5) and Minn. R. 7007.0850, subp. 1). The purpose of this document is to provide the legal and factual justification for each applicable requirement or policy decision considered in the determination to issue the permit.

1. General Information

1.1 Applicant and Stationary Source Location:

Table 1. Applicant and Source Address

Applicant/Address Stationary Source/Address (SIC Code: 2869, 5153)

BioFuel Energy, LLC 1801 Broadway, Suite 1060 Denver, CO 80202

Buffalo Lake Energy, LLC 1125 N Bixby Road Fairmont, Martin County

Contact: Rick Yabroff Phone: 303-640-6493

1.2 Facility Description

Buffalo Lake Energy, LLC (BLE) is a fuel-grade ethanol production facility in Fairmont, Minnesota. The facility has a design capacity of 122.9 million gallons of undenatured ethanol. The plant also produces Distillers Dried Grains and Solubles (DDGS) for animal feed as a by-product of the ethanol production process. Emission sources at the facility include fermentation, distillation, DDGS handling and drying, combustion sources, storage tanks, production loadout, and fugitive sources such as grain handling and dust from haul roads.

The ethanol facility is located adjacent to an existing Cargill grain elevator (permit no. 09100061-003). The grain for the ethanol facility is provided from and stored at the Cargill facility. The Cargill grain elevator is classified as a Country Grain Elevator according to the May 1999 MPCA Air Quality Rules and Permitting for the Grain and Feed Industry fact sheet. A conveying system transports the grain from the Cargill facility to the hammermilling process at the facility. The two facilities are considered a single source for PSD purposes but they are permitted separately.

The primary emissions are Volatile Organic Compounds (VOC), Particulate Matter (PM) Particulate Matter less than 10 um in size (PM10), Nitrogen oxides (NOX), Carbon Monoxide (CO) and Carbon Dioxide (CO2). VOCs are emitted by fermentation, distillation, DDGS drying, wetcake production and storage, ethanol loading, and VOC liquid storage and piping. PM/PM10 is emitted by DDGS handling and drying, corn receiving and handling, and vehicle traffic. NOX and CO are emitted by combustion sources. CO2 is emitted by the chemical reaction to produce ethanol and combustion sources.

Air pollution control equipment includes fabric filters (CE004 to CE009 and CE015 to CE017), the Wet Scrubber (CE018), Multiclones (CE019 and CE021) and the Thermal Oxidizers (CE020 and CE022). The scrubber controls emissions from the fermentation and distillation units including the beer well,


evaporators and centrifuges; and the thermal oxidizer controls emissions from the Dryers, distillation process and DDGS coolers. A flare is used to control emissions from truck and rail ethanol loadout. Baghouses control PM/PM10 from the corn and DDGS handling and storage systems and the Truck/Rail Loadout area. There are five internal floating roof tanks for ethanol, denaturant, and denatured ethanol. Emissions from process valves and piping are controlled through an inspection and maintenance program.

1.3 Description of the Activities Allowed by this Permit Action

This permit action will increase the undenatured ethanol (200-proof) production limit to < 122.9 million gal/yr (previously 118.0 million gal/yr) based on a 12-month rolling sum. BLE had determined that this increase is due to process optimization, thus no physical changes, new equipment or increased grain receiving are involved. Emissions increases will only be observed for TK001, 002, 004 and 005, and EU061. Two emission units not previously included for the facility will be added. These are Yeast Propagation Tanks 1 and 2 (EU069 and 070, respectively). Emissions from EU069 and 070 are accounted for in previous performance tests. An existing emergency generator will be added as EU071. The label of a truck traffic limit at the FS001 level will be amended to “denatured/undenatured” ethanol (previously “denatured” ethanol), though the value of the limit will not change. Performance testing frequencies will be updated based on test results for numerous stacks. PM2.5 emissions will be added to the facility description, though PTE for PM2.5 is unchanged by this amendment. According to the permit application, BLE is required to submit a pollution prevention plan progress report in 2011.

1.4. Facility Emissions:

Table 2. Title I Emissions Increase Summary

Pollutant

Unlimited Potential Emissions from the Modification (tpy)

Limited Potential

Emissions from the

Modification (tpy)

PSD/112(g) Significant

Thresholds for major sources (tpy)

NSR/ 112(g) Review Required?

(Yes/No)

PM 0 0 250 No

PM10 0 0 250 No

PM2.5 0 0 250 No

NOx 0.08 0.08 250 No

SO2 0 0 250 No

CO 0.14 0.14 250 No

CO2e 15,411.2 15,411.2 75,000 No

Ozone (VOC) 0.09 0.09 250 No

Lead 0 0 250 No

HAPs 0 0 10/25 No


Table 3. Total Facility Potential-to-Emit Summary

Pollutant PM PM10 PM2.5 SO2 NOX VOC CO2e CO HAP

Single HAP Total

Ethanol Facility

55.46 50.01 30.28 65.73 94.60 87.33 686,362 92.29 9.0*

14.5

Cargill Grain Handling Facility

27.31 12.48 NA 0 0 0 NA 0 0 0

Total 82.77 62.49 30.28 65.73 94.60 87.33 686,362 92.29 9.0 14.5 * Acetaldehyde

Table 4. Facility Classification

Classification Major/Affected Source

Synthetic Minor Minor

PSD CO2e* Part 70 Permit Program CO2e* Part 63 NESHAP X * Facility has until 6/30/12 to submit an application to revise permit status to PSD major for CO2e

2. Regulatory and/or Statutory Basis

New Source Review

The permit contains limits on fuel use, ethanol and DDGS production that restrict annual emissions of PM, PM10, NOX, CO, SO2 and VOC to less than 250 tons per year. VOCs are measured, and compliance is determined as total VOCs by mass. The ethanol facility and the Cargill grain elevator are considered one source for Prevention of Significant Deterioration (PSD) purposes and must add the emissions from the two facilities to determine major source status. No changes to PSD status are authorized by this permit action.

The facility is located in Martin County. In Martin County, the minor source baseline for PM10 was established in 1999, when Lakefield Junction submitted a permit application for a major PM10 source. Because the minor source baseline has been established and because this source is co-located next to a major PSD source (Cenex Harvest States), the facility must account for its consumption of PM10 increment.

Part 70 Permit Program

The facility taken limits to remain a minor source under the Part 70 permit program.

New Source Performance Standards (NSPS)

The tanks are subject to 40 CFR pt. 60, subp. Kb. The fluid handling equipment is subject to 40 CFR pt. 60, subp. VV and the thermal oxidizer heat recovery steam generating unit is subject to 40 CFR pt. 60, subp. Db. The emergency fire pump (EU065) is subject to 40 CFR pt. 60, subp. IIII. A small emergency generator is subject to 40 CFR pt. 60, subp. JJJJ but there are no subp. JJJJ requirements that apply at this time. National Emission Standards for Hazardous Air Pollutants (NESHAP)


The facility has accepted limits on VOC which effectively limit hazardous air pollutants (HAP) emissions such that it is a non-major source under 40 CFR pt. 63. The VOC limits are found at GP004, GP005, GP006, SV019, CE018, CE023 and FS004 and are expressed as limits in lb/hr and limits on operational parameters of air pollution control equipment. Most HAPs emitted from ethanol production are VOC, so VOC limits can effectively limit HAPs in this case. Test data from ethanol plants has confirmed that if total VOC is limited by having at least 95% VOC control on the fermentation and drying processes, and the plant demonstrates compliance with VOC limits, then HAP emissions will be below major source thresholds. Other controls taken into account include the liquid storage tanks and the Leak Detection and Repair (LDAR) program for piping leaks.

Thus, no NESHAPs which apply only to major sources apply. The cooling tower is subject to the cooling tower NESHAP which prohibits use of chromium containing chemicals to treat the cooling water. There is a small emergency engine which is covered by NESHAP subp. ZZZZ which simply requires the engine to be subject to NSPS subp. JJJJ.

Compliance Assurance Monitoring (CAM)

This is a state permit, thus CAM does not apply to this permit amendment.

Environmental Review & AERA

The facility is limiting its production increase such that it is not subject to environmental review, i.e. an Environmental Assessment Worksheet (EAW), and is not required to perform an Air Emissions Risk Analysis (AERA). The proposed increase in undenatured ethanol production of 4.9 million gallons per year is below the threshold that would require an EAW (5 million gallons/year).

Minnesota State Rules

Portions of the facility are subject to the following Minnesota Standards of Performance:

• Minn. R. 7011.0150 Standards of Performance for Control of Fugitive Particulate Matter (entire facility)

• Minn. R. 7011.0610 Standards of Performance for Fossil-Fuel-Burning Direct Heating Equipment (dryers)

• Minn. R. 7011.1005 Standards of Performance for Dry Bulk Agricultural Commodity Facilities (grain and DDGS handling)

• Minn. R. 7011.0565, 7011.1520(C) and 7011.2900 Incorporation of New Source Performance Standards by Reference

• Minn. R. 7011.2300 Standards of Performance for Stationary Internal Combustion Engines (emergency generator)

• Minn. R. 7011.3520 Standards of Performance for Stationary Compression Ignition Internal Combustion Engines (emergency fire pump)

Table 5. Regulatory Overview of Units Affected by the Modification/Permit Amendment

Level* Applicable Regulations Comments: FC Title I Condition: To avoid

major source classification under 40 CFR Section 52.21 and Minn. R. 7007.3000; and to avoid major source

Production of ethanol (200-proof, prior to addition of denaturant) < 122.9 million gal/yr.


Level* Applicable Regulations Comments: classification under 40 CFR Section 70.2 and Minn. R. 7007.0200

CE018 Title I Condition: To avoid major source classification under 40 CFR Section 52.21 and Minn. R. 7007.3000; and to avoid major source classification under 40 CFR Section 70.2 and Minn. R. 7007.0200

Emissions from Yeast Propagation Tanks 1 and 2 (EU069 and 070) will be vented to the wet scrubber (CE018) at all times the associated units are in operation. Emissions accounted for in previous performance tests.

FS001 Title I Condition: 40 CFR Section 52.21(k); Minn. R. 7007.3000

Limit value remains unchanged at 61,950,000 gallons loadout by truck each year. The label is being amended to “denatured/undenatured” ethanol (previously “denatured” ethanol).

EU071 40 CFR pt. 63, subp. ZZZZ Minn. R. 7011.2300, subps. 1 and 2

Emergency generator subject to NESHAP subp. ZZZZ and meets requirements by meeting the requirements of NSPS subp. JJJJ. Standards of Performance per Minn. R.

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

3. Technical Information

BLE is submitting a major amendment proposing an increase in the facility undenatured ethanol (200-proof) production limit to < 122.9 million gal/yr (previously < 118 million gal/yr) based on a 12-month rolling sum. No physical changes or new equipment will be required to achieve the increase in production of undenatured ethanol. There will also be no increase in grain receiving. The increase in production will be achieved solely through process optimization.

An increase in denaturant usage is not being requested for this permit amendment. BLE has applied for approval by the Tax and Trade Bureau to ship undenatured ethanol. Thus, the maximum denatured ethanol production would increase to up to 128.8 million gal/yr (122.9 million gal/yr 200-proof ethanol + 5.9 million gal/yr denaturant).

BLE is not requesting changes to existing permit limits at FS001 (Truck Traffic) including:

• Number of total trucks/day; • Annual DDGS loadout by truck (180,000 tons); • Denatured ethanol truck loadout (61,950,000 gallons)*; • Denaturant delivery by truck (2,950,000 gallons). *BLE is requesting the denatured ethanol truck

loadout limit be renamed to denatured/undenatured ethanol.

Because no changes are being requested to the limits at FS001, there will be no increase in potential or actual fugitive particulate emissions from FS001.

Emissions of volatile organic compounds (VOC) will increase from storage tanks TK001 and TK002 (200-proof ethanol storage tanks), storage tanks TK004 and TK005 (denatured ethanol storage tanks), and from EU061 (ethanol loadout rail) due to the increase in undenatured ethanol (4.9 million gallons)


production. There is also an increase in CO and NOX emissions from EU061 related to this increase in undenatured ethanol production.

In addition, BLE requests two emission units not previously listed in the facility permit be added. Yeast propagation tanks 1 and 2 (EU069 and EU070), will be associated with CE018 (CO2 Wet Scrubber). The yeast propagation tanks 1 and 2 are currently vented to the thermal oxidizers EU057 and EU059. BLE is not requesting changes in the emission limitations for GP004 or CE018.

Storage Tanks TK001 and TK002

VOC emissions will increase from 592.60 lb/yr to 613.35 lb/yr for each storage tank TK001 and TK002. This results in a total increase of 41.5 lb/yr VOC (20.75 lb/yr per tank).

Storage Tanks TK004 and TK005

VOC emissions will increase from 317.97 lb/yr to 388.04 lb/yr for each storage tank TK004 and TK005. This results in a total increase of 140.14 lb/yr VOC (70.07 lb/yr per tank).

Ethanol Loadout Rail EU061

VOC emissions will increase by 0.01 tons/yr from the loadout of an additional 4.9 million gallons of denatured/undenatured ethanol to a dedicated fleet of railcars carrying solely denatured ethanol product. An increase of 0.08 tpy NOX and 0.14 tpy CO will also be observed. As mentioned above, the denatured ethanol truck loadout limit is being renamed to denatured/ undenatured ethanol truck loadout and remaining at 61,950,000 gallons.

Performance Testing

Initial performance testing was conducted between October 2008 and February 2009 for numerous stacks at the facility. This permit action will implement the approved test frequencies for these stacks based on the results of the performance tests. The stacks, test frequencies, pollutants to be tested and due dates for future performance tests are shown below in Table 6. Test frequency plan requirements at the CE and SVs listed were removed from the permit.

Table 6. Future Performance Testing

Location Pollutant Frequency Due by SV004 Corn Elevator BH PM/PM10 60 months 10/21/2013 SV005 Corn Storage Silo BH PM/PM10 36 months 10/21/2011 SV006 Hammermill No. 1 PM/PM10 60 months 10/16/2013 SV007 Hammermill No. 2 PM/PM10 36 months 10/16/2011 SV008 Hammermill No. 3 PM/PM10 36 months 11/21/2011 SV009 Hammermill No. 4 PM/PM10 60 months 11/21/2013 SV015 DDGS Handling BH PM/PM10 60 months 10/22/2013 SV016 DDGS Loadout BH 1 PM/PM10 60 months 10/24/2013 SV017 DDGS Loadout BH 2 PM/PM10 60 months 11/14/2013 SV019 TO/HRB PM/PM10 60 months 2/27/2014 SV019 TO/HRB NOX 36 months 2/27/2012 SV019 TO/HRB CO/VOC* 60 months 10/21/2013 CE018 Fermentation Scrubber VOC* 60 months 10/21/2013 * VOC test includes HAPs as specified in Appendix VI


Citation and Requirement Corrections

A number of citations and requirements were corrected or updated to meet current MPCA practice.

Emergency Generator

BLE has an emergency generator (EU071) that is subject to 40 CFR pt. 63, subp. ZZZZ and meets its requirements by meeting the requirements of 40 CFR pt. 60, subp. JJJJ. The generator is also subject to the opacity and fuel sulfur content limits in Minn. R. 7011.2300. Emissions calculations for EU071 are included in the PER003 application and are being added to the facility description in this permit action.

Greenhouse Gases

Greenhouse gases are a regulated pollutant under the Clean Air Act as of January 2, 2011. The facility’s current PTE of CO2 equivalents (CO2e) is above 100,000 tpy. Since the modification is an increase of less than 75,000 tpy CO2e, it is not subject to regulation for greenhouse gases. The facility is aware of their total facility CO2e PTE and at this time does not wish to accept limits that would inherently limit CO2e to below 100,000 tpy. The Permittee must submit a permit application by June 30, 2012 to revise their permit to address greenhouse gases.

The CO2e emissions increase from the proposed expansion of 4.9 million gallons is calculated below:

4.9 million gal EtOH * 0.789 g EtOH/cm3 * 3785.41 cm3/gal = 1.46 E 10 g EtOH

1.46 E 10 g EtOH * 1 mol EtOH/46.06844 g EtOH * 2 mol CO2/2 mol EtOH = 317,674,607.6 mol CO2

317,674,607.6 mol CO2 * 44.0095 g CO2/mol CO2 * 1 lb/453.59 g = 30,822,330 lb CO2

30,822,330 lb CO2 * 1 ton/2000 lb = 15,411.2 ton CO2

Using similar calculations for the total facility production of 128.8 million gallons of denatured EtOH (note 1 gallon of denatured EtOH has 0.954 gal of 200-proof EtOH), the CO2e from fermentation is 773,070,318.17 lb CO2 or 386,535.16 tons CO2. The CO2e from combustion of natural gas and diesel (Fire Pump, EU065) is 299,826.8 tons. This includes 298,950.4 tons CO2, 33.39 tons CH4 (701.2 tons CO2e) and 0.565 tons of N2O (175.3 tons CO2e).

3.1 Emissions Increase Analysis

The TANKS program was used to estimate emissions from TK001, 002, 003, 004 and 005 and EU061 at the facility. The resultant increases in emissions are shown above in Table 2. Detailed calculations are contained in the permit application materials. Trace amounts of cyclohexane, benzene, hexane, pentane, toluene, xylene, ethyl benzene, 1,2,4-trimethyl benzene, carbon disulfide and cumene were also calculated. A brief summary of emissions calculations including greenhouse gas emissions increases associated with this permit action are attached.

3.2 Periodic 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 considers the following:

• The likelihood of violating the applicable requirements; • Whether add-on controls are necessary to meet the emission limits;


• The variability of emissions over time; • The type of monitoring, process, maintenance, or control equipment data already available for

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

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

Table 7. Periodic Monitoring

Level* Requirement (rule basis)

Additional Monitoring

Discussion

FC Production: < 122.9 million gal/yr using 12-month rolling sum (200-proof EtOH)

Title I Condition: to avoid PSD & Pt. 70 major source status

200-proof ethanol production limit increased to < 122.9 million gal/yr (previously 118.0 million gal/yr). Since the increase is less than 5 million gallons, environmental review is not triggered. Increase in production is from facility optimization.

FS001 (Truck Traffic)

Loadout: ≤ 61,950,000 gallons denatured/ undenatured ethanol

Title I Condition: 40 CFR Section 52.21(k); Minn. R. 7007.3000

Recordkeeping: Record number of ethanol loadout trucks entering the facility each day and keep records onsite.

The value of this limit is unchanged, though the label of the limit is amended to “denatured/ undenatured” ethanol.

CE018 (Wet Scrubber)

Title I Condition: to avoid PSD & Pt. 70 major source status

None Vent all emissions associated with CE018 to the Wet Scrubber (CE018) at all times that the associated units are in operation. EU069/070 are being added.

EU071 Opacity: < 20%

SO2: < 0.5 lbs/mmBtu

Minn. R. 7011.2300, subps. 1 & 2

SO2 content in fuel < 0.5% by weight

Fuel usage must be less than or equal to 0.5% by weight sulfur content. Emergency generator is also subject to NESHAP subp. ZZZZ and meets requirements by meeting requirements of NSPS subp. JJJJ.

EU071 Minn. R. 7007.0800, subps. 4 & 5 and Minn.

Monthly fuel records, hours of

Generator must use natural gas with sulfur content that meets the limit in Minn. R. 7011.2300 subp. 2.


Level* Requirement (rule basis)

Additional Monitoring

Discussion

R. 7007.0100, subp. 35a

operation

May burn only natural gas

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

3.3 Insignificant Activities

Buffalo Lake Energy, LLC has several operations which are classified as insignificant activities. These are listed in Appendix I to the permit. No additional insignificant activities are associated with this permit action.

3.4 Permit Organization

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

3.5 Comments Received

Public Notice Period: March 25, 2011 - April 25, 2011 EPA Review Period: March 25, 2011 - April 25, 2011

Comments were not received from the public during the public notice period. Comments were not received from EPA during their review period.

4. Permit Fee Assessment

Attachment 3 to this TSD contains the MPCA’s assessment of Application and Additional Points used to determine the permit application fee for this permit action as required by Minn. R. 7002.0019. The permit action includes one permit application received after the effective date of the rule (July 1, 2009) (25 points, paid). The permit includes the revision of limits taken to avoid PSD and Pt. 70 major source status (20 points). The action also includes a reopening (0 points).

5. Conclusion

Based on the information provided by Buffalo Lake Energy, LLC, the MPCA has reasonable assurance that the proposed operation of the emission facility, as described in the Air Emission Permit No. 09100060-004 and this TSD, will not cause or contribute to a violation of applicable federal regulations and Minnesota Rules.

Staff Members on Permit Team: Tarik Hanafy (permit writer/engineer) Jennifer Lovett (enforcement) Curtis Stock (stack testing) Jessica Forsberg (peer reviewer)

AQ File No. 4267; DQ 3316, 2852


Attachments: 1. Facility Description and CD-01 Forms

2. Emissions Calculations 3. Points Calculator

Attachment 1: Facility Description and CD-01 Forms

MINNESOTA POLLUTION CONTROL AGENCYAIR QUALITY520 LAFAYETTE ROADST. PAUL, MN 55155-4194

Show:Action:AQD Facility ID:Facility Name:

Active and Pending RecordsPER 00409100060Buffalo Lake Energy LLC

FACILITY DESCRIPTION: GROUPS (GP)

4 May, 2011 11:42

ID No. AddedBy

(Action)

RetiredBy

(Action)

Includein EI

OperatorID

for Item

Group Description Group ItemsGroupStatus

1 GP 001 PER 003 Baghouses CE 004, CE 005, CE 006, CE 007, CE 008, CE 009, CE 015, CE 016, CE 017,CE 024, CE 025

Active

2 GP 002 PER 001 Wet Scrubber CE 018, SV 018Active

3 GP 003 PER 001 Dryers EU 056, EU 058Active

4 GP 004 PER 001 Thermal Oxidizer with Heat Recovery Boiler EU 011, EU 012, EU 013, EU 014, EU 015, EU 016, EU 017, EU 018, EU 019,EU 020, EU 021, EU 022, EU 023, EU 024, EU 025, EU 026, EU 027, EU 028,EU 029, EU 030, EU 031, EU 032, EU 033, EU 034, EU 035, EU 036, EU 037,EU 038, EU 057, EU 059

Active

5 GP 005 PER 001 Internal Floating Roof Tanks TK 001, TK 002, TK 003, TK 004, TK 005Active

6 GP 006 PER 001 Ethanol Loadout EU 060, EU 061Active

7 GP 007 PER 001 Multiclones CE 019, CE 021Active

8 GP 008 PER 003 Limited Baghouses SV 004, SV 005, SV 006, SV 007, SV 008, SV 009, SV 015, SV 016, SV 017,SV 023, SV 024

Active

9 GP 009 PER 003 Hammermills EU 007, EU 008, EU 009, EU 010Active

Page 1 of 1


Show: Active and Pending RecordsAction: PER 004AQD Facility ID: 09100060Facility Name: Buffalo Lake Energy LLC

4 May, 2011 11:42

FACILITY DESCRIPTION: STACK/VENTS (SV)

ID No. Discharge DirectionFlow Rate/Temperature

Information Source

Exit GasTemperature

at Top(ºF)

DesignFlow Rate

at Top(ACFM)

Width(feet)

Diameteror Length

(feet)

Inside DimensionsHeight ofOpening

FromGround(feet)

AddedBy

(Action)

RetiredBy

(Action)

OperatorID

for Item

Operators DescriptionStack/Vent

Status

1 SV 001 PER 002 Not installedRemoved



4 SV 004 HorizontalEstimate27001.2148PER 003 Corn Elevator Baghouse 1Active

5 SV 005 HorizontalEstimate25001.20150PER 001 Corn Storage Silo Baghouse 1Active

6 SV 006 Up, No CapEstimate59391.8636PER 002 EP6Active









15 SV 015 HorizontalEstimate15000.7954PER 002 DDGS Handling Baghouse 6Active

16 SV 016 Up, No CapEstimate18000.9255PER 002 DDGS Loadout Baghouse 1Active

17 SV 017 Up, No CapEstimate30001.1857.25PER 002 DDGS Loadout Baghouse 2Active

18 SV 018 Up, No CapEstimate80340003.060PER 001 CO2 ScrubberActive

19 SV 019 Up, No CapEstimate2751396596.2140PER 002 TO/HRBsActive

20 SV 020 *ErrorEstimate87020002.5020PER 001 GenSetActive

21 SV 021 HorizontalEstimate80040000.7110.33PER 002 Emergency Fire PumpActive

22 SV 022 Up, No CapEstimate1600340002.536PER 001 FlareActive

23 SV 023 500.42753.51PER 003 DDGS Bulkweigher BaghouseActive

24 SV 024 2100PER 003 DDGS Cross Conveyor BaghouseActive

Page 1 of 1



4 May, 2011 11:42

FACILITY DESCRIPTION: CONTROL EQUIPMENT (CE)

ID No. AddedBy

(Action)

RetiredBy

(Action)

OperatorID

for Item

Control

Equip.Type

Control Equipment Description ModelControlEquip.Status

Manufacturer PollutantsControlled

AfterburnerCombustionParameters

CaptureEfficiency

(%)

Destruction/CollectionEfficiency

(%)

1 CE 001 PER 002 099 Not installed TBDRemoved TBD PM 100 99



4 CE 004 PER 001 018 Fabric Filter - Low Temperature, i.e., T<180 Degrees F TBDActive TBD PM10PM

100100

9999


100100

9999


100100

9999


100100

9999


100100

9999


100100

9999







100100

9999


100100

9999


100100

9999

18 CE 018 PER 001 001 Wet Scrubber - High Efficiency CustomActive Delta T Corp. VOC 100 97

19 CE 019 PER 001 007 Centrifugal Collector - High Efficiency TBDActive TBD PM10PM

100100

8080

20 CE 020 PER 001 131 Thermal Oxidizer TBDActive TBD PMVOC

100100

9595

21 CE 021 PER 001 007 Centrifugal Collector - High Efficiency TBDActive TBD PM10PM

100100

8080

22 CE 022 PER 001 131 Thermal Oxidizer TBDActive TBD PMVOC

100100

9595

23 CE 023 PER 001 023 Flaring TBDActive TBD VOC 100 98

Page 1 of 2



4 May, 2011 11:42

FACILITY DESCRIPTION: CONTROL EQUIPMENT (CE)

ID No. AddedBy

(Action)

RetiredBy

(Action)

OperatorID

for Item

Control

Equip.Type

Control Equipment Description ModelControlEquip.Status

Manufacturer PollutantsControlled

AfterburnerCombustionParameters

CaptureEfficiency

(%)

Destruction/CollectionEfficiency

(%)

24 CE 024 EIS 005 018 Fabric Filter - Low Temperature, i.e., T<180 Degrees FActive PM10PM

100100

9999

25 CE 025 EIS 005 018 Fabric Filter - Low Temperature, i.e., T<180 Degrees FActive PM10PM

100100

9999

Page 2 of 2

ST. PAUL, MN 55155-4194

Show: Active and Pending RecordsAction: PER 004AQD Facility ID: 09100060Facility Name:

MINNESOTA POLLUTION CONTROL AGENCYAIR QUALITY520 LAFAYETTE ROAD

4 May, 2011 11:43

FACILITY DESCRIPTION: EMISSION UNIT (EU)

MaxFuelInput

(mil Btu)

Buffalo Lake Energy LLC

RetiredBy

(Action)

Operator DescriptionID No. EmissionUnit

Status

AddedBy

(Action)

ControlEquip.

ID No(s).

Stack/Vent

ID No(s).

OperatorID

for Item

Insignif-icant

Activity

SICManufacturer ModelNumber

Max.Design

Capacity

MaximumDesign

Capacity

Materials Units n Units d

1 Corn Conveyor 1 - inletEU 001 Active PER 002 001 Hr Heat2869TBD TBD 5000 Btu

2 Corn Conveyor 2 - outletEU 002 Active PER 002 002 Hr Heat2869TBD TBD 5000 Btu

3 Not installedEU 003 Active PER 002 003 Hr Heat2869TBD TBD 5000 Btu

4 Corn Elevator 1EU 004 Active PER 001 CE 004SV 004 (M)004 Hr Heat2869TBD TBD 5000 Btu

5 ScalperEU 005 Active PER 001 CE 005SV 005 (M)005 Hr Heat2869TBD TBD 5000 Btu

6 Corn Storage Silo 1EU 006 Active PER 001 CE 005SV 005 (M)006 2869TBD TBD 110000 Bushel

7 Hammermill 1EU 007 Active PER 001 CE 006SV 006 (M)007 Hr Heat2869TBD TBD 5000 Btu




11 Slurry Tank 1EU 011 Active PER 001 CE 020CE 022

SV 019 (M)011 2869Delta T Corp Custom 77212 Gal

12 Liquefaction Tank 1EU 012 Active PER 001 CE 020CE 022

SV 019 (M)012 2869Delta T Corp TBD 190884 Gal

13 Yeast Tank 1EU 013 Active PER 001 CE 020CE 022


14 Yeast Tank 2EU 014 Active PER 001 CE 020CE 022


15 Process Condensate TankEU 015 Active PER 001 CE 020CE 022


16 Beer Column 1EU 016 Active PER 001 CE 020CE 022

SV 019 (M)016 Yr 2869Delta T Corp TBD 59 Mgal

17 Beer Column 2EU 017 Active PER 001 CE 020CE 022


18 Stripper 1EU 018 Active PER 001 CE 020CE 022


19 Stripper 2EU 019 Active PER 001 CE 020CE 022


20 Rectifier 1EU 020 Active PER 001 CE 020CE 022


21 Rectifier 2EU 021 Active PER 001 CE 020CE 022


22 Evaporator 1EU 022 Active PER 001 CE 020CE 022


23 Evaporator 2EU 023 Active PER 001 CE 020CE 022


Page 1 of 4 (a)

4 May, 2011 11:43


ID No. ElevatorType

BottleneckPct.Fuel/

SpaceHeat

Firing MethodAddedBy

(Action)

RemovalDate

InitialStartup

Date

Comm-ence

Const.Date

EmissionUnit

Status

1 EU 001 PER 002 03/01/200703/01/2006Active

2 EU 002 PER 002 03/01/200703/01/2006Active

3 EU 003 PER 002 03/01/200703/01/2006Active

4 EU 004 PER 001 03/01/200703/01/2006Active

5 EU 005 PER 001 03/01/200703/01/2006Active

6 EU 006 PER 001 03/01/200703/01/2006Active

7 EU 007 PER 001 03/01/200703/01/2006Active

8 EU 008 PER 001 03/01/200703/01/2006Active

9 EU 009 PER 001 03/01/200703/01/2006Active

10 EU 010 PER 001 03/01/200703/01/2006Active

11 EU 011 PER 001 03/01/200703/01/2006Active

12 EU 012 PER 001 03/01/200703/01/2006Active

13 EU 013 PER 001 03/01/200703/01/2006Active

14 EU 014 PER 001 03/01/200703/01/2006Active

15 EU 015 PER 001 03/01/200703/01/2006Active

16 EU 016 PER 001 03/01/200703/01/2006Active

17 EU 017 PER 001 03/01/200703/01/2006Active

18 EU 018 PER 001 03/01/200703/01/2006Active

19 EU 019 PER 001 03/01/200703/01/2006Active

20 EU 020 PER 001 03/01/200703/01/2006Active

21 EU 021 PER 001 03/01/200703/01/2006Active

22 EU 022 PER 001 03/01/200703/01/2006Active

23 EU 023 PER 001 03/01/200703/01/2006Active

Page 1 of 4 (b)

ST. PAUL, MN 55155-4194



4 May, 2011 11:43


MaxFuelInput

(mil Btu)


RetiredBy

(Action)


Status

AddedBy

(Action)

ControlEquip.

ID No(s).

Stack/Vent

ID No(s).

OperatorID

for Item

Insignif-icant

Activity


Max.Design

Capacity

MaximumDesign

Capacity


24 Syrup TankEU 024 Active PER 001 CE 020CE 022


25 Centrifuge 1EU 025 Active PER 001 CE 020CE 022
















33 Molecular Sieve 1EU 033 Active PER 001 CE 020CE 022








37 200 Proof CondenserEU 037 Active PER 001 CE 020CE 022


38 200 Proof CondenserEU 038 Active PER 001 CE 020CE 022


39 Fermenter 1EU 039 Active PER 001 CE 018SV 018 (M)041 2869Delta T Corp TBD 814739 Gal







Page 2 of 4 (a)

4 May, 2011 11:43


ID No. ElevatorType

BottleneckPct.Fuel/

SpaceHeat


(Action)

RemovalDate

InitialStartup

Date

Comm-ence

Const.Date

EmissionUnit

Status

24 EU 024 PER 001 03/01/200703/01/2006Active

25 EU 025 PER 001 03/01/200703/01/2006Active

26 EU 026 PER 001 03/01/200703/01/2006Active

27 EU 027 PER 001 03/01/200703/01/2006Active

28 EU 028 PER 001 03/01/200703/01/2006Active

29 EU 029 PER 001 03/01/200703/01/2006Active

30 EU 030 PER 001 03/01/200703/01/2006Active

31 EU 031 PER 001 03/01/200703/01/2006Active

32 EU 032 PER 001 03/01/200703/01/2006Active

33 EU 033 PER 001 03/01/200703/01/2006Active

34 EU 034 PER 001 03/01/200703/01/2006Active

35 EU 035 PER 001 03/01/200703/01/2006Active

36 EU 036 PER 001 03/01/200703/01/2006Active

37 EU 037 PER 001 03/01/200703/01/2006Active

38 EU 038 PER 001 03/01/200703/01/2006Active

39 EU 039 PER 001 03/01/200703/01/2006Active

40 EU 040 PER 001 03/01/200703/01/2006Active

41 EU 041 PER 001 03/01/200703/01/2006Active

42 EU 042 PER 001 03/01/200703/01/2006Active

43 EU 043 PER 001 03/01/200703/01/2006Active

44 EU 044 PER 001 03/01/200703/01/2006Active

45 EU 045 PER 001 03/01/200703/01/2006Active

Page 2 of 4 (b)

ST. PAUL, MN 55155-4194



4 May, 2011 11:43


MaxFuelInput

(mil Btu)


RetiredBy

(Action)


Status

AddedBy

(Action)

ControlEquip.

ID No(s).

Stack/Vent

ID No(s).

OperatorID

for Item

Insignif-icant

Activity


Max.Design

Capacity

MaximumDesign

Capacity



47 Beer WellEU 047 Active PER 001 CE 018SV 018 (M)049 2869Delta T Corp TBD 1057971 Gal

48 DDGS Bucket Elevator 1 --Not Installed

EU 048 Active PER 003 050 Hr 2869Delta T Corp TBD 20.4 Ton

49 DDGS Storage Silo 1 -- NotInstalled

EU 049 Active PER 003 052 Hr 2869Delta T Corp TBD 20.4 Ton

50 DDGS Storage Silo 2 -- NotInstalled

EU 050 Active PER 003 054 Hr 2869TBD TBD 20.4 Ton

51 DDGS Bucket Elevator 2 --Not Installed


52 DDGS Converyor Inlet -- NotInstalled


53 DDGS Bucket elevatorEU 053 Active PER 003 CE 015SV 015 (M)057 Hr 2869TBD TBD 40.8 Ton

54 DDGS Truck Load SpoutEU 054 Active PER 001 CE 016SV 016 (M)058 Hr 2869TBD TBD 40.8 Ton

55 DDGS Rail Load SpoutEU 055 Active PER 001 CE 017SV 017 (M)059 Hr 2869TBD TBD 40.8 Ton

56 DDGS Dryer AEU 056 Active PER 001 CE 019CE 021

SV 019 (M) Hr Heat2869 80 Mmbtu

57 Thermal Oxidizer/HeatRecovery Generator 1

EU 057 Active PER 001 CE 021SV 019 (M) Hr Heat2869 145 Mmbtu

58 DDGS Dryer BEU 058 Active PER 001 CE 020CE 022

SV 019 (M) Hr Heat2869 80 Mmbtu

59 Thermal Oxidizer/HeatRecovery Generator 2

EU 059 Active PER 001 CE 022SV 019 (M) Hr Heat2869 145 Mmbtu

60 Ethanol Loadout (Truck)EU 060 Active PER 001 CE 023SV 022 (M) 2869

61 Ethanol Loadout (Rail)EU 061 Active PER 001 CE 023SV 022 (M) 2869

62 DDGS Cooler #1EU 062 Active PER 001 CE 020CE 022

SV 019 (M) 2869

63 DDGS Cooler #2EU 063 Active PER 001 CE 020CE 022

SV 019 (M) 2869

2.1164 Emergency Fire PumpEU 065 Active PER 001 SV 021 Energy2869TBD TBD 290 Hp

6.465 Loadout FlareEU 066 Active PER 001 CE 023SV 022 Ft3 Heat2869MRW TBD 850 Btu

66 DDGS BulkweigherEU 067 Active PER 003 CE 024SV 023 2869

67 DDGS Cross ConveyorEU 068 Active PER 003 CE 025SV 024 2869

68 Yeast Propagation Tank 1EU 069 Active PER 004 CE 018 2869

Page 3 of 4 (a)

4 May, 2011 11:43


ID No. ElevatorType

BottleneckPct.Fuel/

SpaceHeat


(Action)

RemovalDate

InitialStartup

Date

Comm-ence

Const.Date

EmissionUnit

Status

46 EU 046 PER 001 03/01/200703/01/2006Active

47 EU 047 PER 001 03/01/200703/01/2006Active

48 EU 048 PER 003 03/01/200703/01/2006Active

49 EU 049 PER 003 03/01/200703/01/2006Active

50 EU 050 PER 003 03/01/200703/01/2006Active

51 EU 051 PER 003 03/01/200703/01/2006Active

52 EU 052 PER 003 03/01/200703/01/2006Active

53 EU 053 PER 003 03/01/200703/01/2006Active

54 EU 054 PER 001 03/01/200703/01/2006Active

55 EU 055 PER 001 03/01/200703/01/2006Active

56 EU 056 PER 001Active













Page 3 of 4 (b)

ST. PAUL, MN 55155-4194



4 May, 2011 11:43


MaxFuelInput

(mil Btu)


RetiredBy

(Action)


Status

AddedBy

(Action)

ControlEquip.

ID No(s).

Stack/Vent

ID No(s).

OperatorID

for Item

Insignif-icant

Activity


Max.Design

Capacity

MaximumDesign

Capacity


69 Yeast Propagation Tank 2EU 070 Active PER 004 CE 018 2869

70 Natural Gas EmergencyGenerator

EU 071 Active PER 004 2869

Page 4 of 4 (a)

4 May, 2011 11:43


ID No. ElevatorType

BottleneckPct.Fuel/

SpaceHeat


(Action)

RemovalDate

InitialStartup

Date

Comm-ence

Const.Date

EmissionUnit

Status



Page 4 of 4 (b)

Insignif-icant

Activity

OperatorID

for Item



4 May, 2011 11:44

FACILITY DESCRIPTION: STORAGE TANKS (TK)

ID No. Capacity(1000 gal)

InteriorHeight

(ft.)

InteriorDiameter

(ft.)

AddedBy

(Action)

Construction TypeTankStatus

Product StoredControlEquip.

ID No(s).

RetiredBy

(Action)

1 TK 001 19244 25.2 Internal Floating RoofActive PER 003 200 Proof Ethanol

2 TK 002 19244 27.2 Internal Floating RoofActive PER 003 200 Proof Ethanol

3 TK 003 11736 23.5 Internal Floating RoofActive PER 003 Denaturant

4 TK 004 156252 71.5 Internal Floating RoofActive PER 003 Denatured Ethanol

5 TK 005 156252 71.5 Internal Floating RoofActive PER 003 Denatured Ethanol

Page 1 of 1 (a)

ID No.

FACILITY DESCRIPTION: STORAGE TANKS (TK)

4 May, 2011 11:44

YearRemoved

YearInstalled

Seal Type(floating roof only)

AddedBy

(Action)

Support Type(floating roof only)

ColumnCount

ColumnDiameter

(ft.)

Deck Type(floating roof only)

TankStatus

1 TK 001 2006PER 003 Column Supported Roof, Construction Type N 1Active





Page 1 of 1 (b)



4 May, 2011 11:44

FACILITY DESCRIPTION: FUGITIVE SOURCES (FS)

ID No. Fugitive Source Description YearInstalled

YearRemoved

AddedBy

(Action)

RetiredBy

(Action)

Insignif-icant

Activity

OperatorID

for Item

Pollutant(s)Emitted

ControlEquip.

ID No(s).

FugitiveSourceStatus

1 FS 001 2006PER 001 PM Truck TrafficActive

2 FS 002 2006PER 001 PM DDGS Storage BuildingActive

3 FS 003 2006PER 001 PM Uncaptured Emissions from DDGS HandlingActive

4 FS 004 2006PER 001 VOC Equipment LeaksActive

5 FS 005 2006PER 001 PM Cooling TowersActive

6 FS 006 2006PER 001 VOC Wet Cake StorageActive

Page 1 of 1


4 May, 2011 11:44

FACILITY DESCRIPTION: Potential-to-emit (by item)

Show: Active and Pending RecordsAQD Facility ID:Facility Name:

09100060Buffalo Lake Energy LLC

Item UnrestrictedPotential

(tons per yr)

LimitedPotential

(tons per yr)

ActualEmissions

(tons per yr)

Pollutant AddedBy

(Action)

RetiredBy

(Action)

HourlyPotential

(lbs per hr)

EU 065

PM < 10 micron PER 003Total Particulate Matter PER 003

EU 071

Carbon Dioxide Equivalent PER 004 6.42E+002.57E+01 6.42E+00Carbon Monoxide PER 004 4.01E-011.60E+00 4.01E-01Nitrogen Oxides PER 004 1.11E-014.44E-01 1.11E-01PM < 2.5 micron PER 004 4.00E-041.60E-03 4.00E-04PM < 10 micron PER 004 4.00E-041.60E-03 4.00E-04Total Particulate Matter PER 004 4.00E-041.60E-03 4.00E-04Sulfur Dioxide PER 004 3.00E-051.20E-04 3.00E-05Volatile Organic Compounds PER 004 1.10E-024.40E-02 1.10E-02

FS 001

PM < 10 micron PER 002 1.30E+00 1.30E+003.00E-01 1.30E+00Total Particulate Matter PER 002 6.66E+00 6.66E+001.52E+00 6.66E+00

FS 002

PM < 2.5 micron PER 004 2.00E-036.00E-04PM < 10 micron PER 002 1.40E-02 1.00E-023.00E-03 1.40E-02Total Particulate Matter PER 002 6.00E-02 5.00E-021.00E-02 6.00E-02

FS 003

PM < 2.5 micron PER 004 2.00E-036.00E-04PM < 10 micron PER 002 1.40E-02 1.00E-023.00E-03 1.40E-02Total Particulate Matter PER 002 6.00E-02 5.00E-021.00E-02 6.00E-02

FS 004

Volatile Organic Compounds PER 001 7.11E+00 7.11E+001.62E+00 7.11E+00

FS 005

PM < 2.5 micron PER 004 4.60E+001.05E+00PM < 10 micron PER 003 9.46E+00 9.46E+002.16E+00 9.46E+00Total Particulate Matter PER 003 9.46E+00 9.50E+002.16E+00 9.50E+00

SV 001


SV 002


SV 003


SV 004

PM < 2.5 micron PER 004 5.00E-021.20E-02PM < 10 micron PER 003 3.00E-01 3.00E-016.90E-02 3.00E+01Total Particulate Matter PER 003 3.00E-01 3.00E-016.90E-02 3.00E+01

SV 005

PM < 2.5 micron PER 004 5.00E-021.10E-02PM < 10 micron PER 003 2.80E-01 2.80E-016.40E-02 2.80E+01

Page 1 of 4


4 May, 2011 11:44





(tons per yr)

LimitedPotential

(tons per yr)

ActualEmissions

(tons per yr)

Pollutant AddedBy

(Action)

RetiredBy

(Action)

HourlyPotential

(lbs per hr)

SV 005

Total Particulate Matter PER 003 2.80E-01 2.80E-016.40E-01 2.80E+01

SV 006


SV 007


SV 008


SV 009


SV 010


SV 011


SV 012


SV 013


SV 014


SV 015


SV 016


SV 017


Page 2 of 4


4 May, 2011 11:44





(tons per yr)

LimitedPotential

(tons per yr)

ActualEmissions

(tons per yr)

Pollutant AddedBy

(Action)

RetiredBy

(Action)

HourlyPotential

(lbs per hr)

SV 018

Carbon Dioxide Equivalent PER 004 3.87E+058.83E+04 3.87E+05Carbon Dioxide PER 004 3.87E+058.83E+04 3.87E+05Volatile Organic Compounds PER 001 5.48E+01 5.48E+011.25E+01 1.77E+03

SV 019

Carbon Dioxide Equivalent PER 004 2.97E+056.77E+04 2.97E+05Carbon Monoxide PER 002 8.76E+01 8.76E+012.00E+01 1.80E+03Carbon Dioxide PER 004 2.96E+056.75E+04 2.96E+05Nitrogen Oxides PER 003 9.17E+01 9.17E+012.09E+01 9.17E+01PM < 2.5 micron PER 004 2.50E+015.70E+00PM < 10 micron PER 003 3.50E+01 1.31E+018.00E+00 2.50E+02Total Particulate Matter PER 003 3.50E+01 1.31E+018.00E+00 2.50E+02Sulfur Dioxide PER 001 6.57E+01 6.57E+011.50E+01 6.57E+01Volatile Organic Compounds PER 002 1.75E+01 1.75E+014.00E+00 3.50E+02

SV 020

Carbon Monoxide PER 003 4.00E-01 4.00E-011.60E+00 7.01E+00Nitrogen Oxides PER 003 1.10E-01 1.10E-014.40E-01 1.93E+00Volatile Organic Compounds PER 003 1.00E-02 1.00E-024.00E-02 1.80E-01

SV 021

Carbon Dioxide Equivalent PER 004 3.00E+016.84E+00 3.00E+01Carbon Monoxide PER 003 1.00E-01 1.00E-011.94E+00 8.50E+00Carbon Dioxide PER 004 2.98E+016.81E+00 2.98E+01Nitrogen Oxides PER 003 4.50E-01 4.50E-018.99E+00 3.94E+01PM < 10 micron PER 003 3.00E-02 3.00E-026.40E-01 2.80E+00Total Particulate Matter PER 003 3.00E-02 3.00E-026.40E-01 2.80E+00Volatile Organic Compounds PER 003 4.00E-02 4.00E-027.20E-01 3.14E+00

SV 022

Carbon Dioxide Equivalent PER 004 3.27E+037.47E+02 3.27E+03Carbon Monoxide PER 003 3.65E+00 3.65E+001.82E+00 7.97E+00Carbon Monoxide PER 004 3.79E+00 3.79E+001.90E+00 8.32E+00Carbon Dioxide PER 004 3.26E+037.45E+02 3.26E+03Nitrogen Oxides PER 003 2.18E+00 2.18E+001.09E+00 4.77E+00Nitrogen Oxides PER 004 2.26E+00 2.26E+001.13E+00 4.95E+00Volatile Organic Compounds PER 003 6.12E+00 6.12E+002.80E+00 1.23E+01Volatile Organic Compounds PER 004 6.14E+00 6.14E+007.34E+00 3.07E+02

SV 023


SV 024


TK 001

Volatile Organic Compounds PER 001 2.80E-01 2.80E-016.00E-02 2.80E-01Volatile Organic Compounds PER 004 3.10E-01 3.10E-017.00E-02 3.10E-01

Page 3 of 4


4 May, 2011 11:44





(tons per yr)

LimitedPotential

(tons per yr)

ActualEmissions

(tons per yr)

Pollutant AddedBy

(Action)

RetiredBy

(Action)

HourlyPotential

(lbs per hr)

TK 002

Volatile Organic Compounds PER 001 2.80E-01 2.80E-016.00E-02 2.80E-01Volatile Organic Compounds PER 004 3.10E-01 3.10E-017.00E-02 3.10E-01

TK 003

Volatile Organic Compounds PER 001 7.40E-01 7.40E-011.70E-01 7.40E-01

TK 004

Volatile Organic Compounds PER 003 1.90E-01 1.14E+002.60E-01 1.14E+00Volatile Organic Compounds PER 004 1.94E-01 1.14E+002.60E-01 1.14E+00

TK 005

Volatile Organic Compounds PER 003 1.90E-01 1.14E+002.60E-01 1.14E+00Volatile Organic Compounds PER 004 1.94E-01 1.14E+002.60E-01 1.14E+00

Page 4 of 4

4 May, 2011 11:45

Show: Active and Pending Records

FACILITY DESCRIPTION: Potential-to-emit (by pollutant)

RetiredBy

(Action)

AddedBy

(Action)

ItemPollutant ActualEmissions

(tons per yr)

LimitedPotential

(tons per yr)

UnrestrictedPotential

(tons per yr)

HourlyPotential

(lbs per hr)

AQD Facility ID: 09100060Facility Name: Buffalo Lake Energy LLC


Carbon Dioxide Equivalent

PER 004EU 071 2.568E+01 6.420E+00 6.420E+00

PER 004SV 018 8.825E+04 3.865E+05 3.865E+05

PER 004SV 019 6.770E+04 2.965E+05 2.965E+05

PER 004SV 021 6.840E+00 2.995E+01 2.995E+01

PER 004SV 022 7.470E+02 3.272E+03 3.272E+03

Totals 6.864E+05 6.864E+05 0.000E+00

Carbon Monoxide

PER 004EU 071 1.600E+00 4.010E-01 4.010E-01

PER 002SV 019 2.000E+01 1.800E+03 8.760E+01 8.760E+01

PER 003SV 020 1.600E+00 7.010E+00 4.000E-01 4.000E-01

PER 003SV 021 1.940E+00 8.500E+00 1.000E-01 1.000E-01

PER 003SV 022 1.820E+00 7.970E+00 3.650E+00 3.650E+00

PER 004SV 022 1.900E+00 8.320E+00 3.790E+00 3.790E+00

Totals 1.824E+03 9.229E+01 9.189E+01

Carbon Dioxide

PER 004SV 018 8.825E+04 3.865E+05 3.865E+05

PER 004SV 019 6.750E+04 2.957E+05 2.957E+05

PER 004SV 021 6.810E+00 2.984E+01 2.984E+01

PER 004SV 022 7.448E+02 3.262E+03 3.262E+03

Totals 6.855E+05 6.855E+05 0.000E+00

Nitrogen Oxides

PER 004EU 071 4.440E-01 1.110E-01 1.110E-01

PER 003SV 019 2.093E+01 9.167E+01 9.167E+01 9.167E+01

PER 003SV 020 4.400E-01 1.930E+00 1.100E-01 1.100E-01

PER 003SV 021 8.990E+00 3.938E+01 4.500E-01 4.500E-01

PER 003SV 022 1.090E+00 4.770E+00 2.180E+00 2.180E+00

PER 004SV 022 1.130E+00 4.950E+00 2.260E+00 2.260E+00

Totals 1.380E+02 9.460E+01 9.449E+01

PM < 2.5 micron

PER 004EU 071 1.600E-03 4.000E-04 4.000E-04

PER 004FS 002 6.000E-04 2.000E-03

PER 004FS 003 6.000E-04 2.000E-03

PER 004FS 005 1.050E+00 4.600E+00

PER 004SV 004 1.200E-02 5.000E-02

PER 004SV 005 1.100E-02 5.000E-02

PER 004SV 006 2.600E-02 1.100E-01

Page 1 of 4

4 May, 2011 11:45



RetiredBy

(Action)

AddedBy

(Action)


(tons per yr)

LimitedPotential

(tons per yr)


(tons per yr)

HourlyPotential

(lbs per hr)



PM < 2.5 micron

PER 004SV 007 2.600E-02 1.100E-01

PER 004SV 008 2.600E-02 1.100E-01

PER 004SV 009 2.600E-02 1.100E-01

PER 004SV 015 6.000E-03 3.000E-02

PER 004SV 016 8.000E-03 3.000E-02

PER 004SV 017 8.000E-03 3.000E-02

PER 004SV 019 5.700E+00 2.500E+01

PER 004SV 023 2.000E-03 1.000E-02

PER 004SV 024 9.000E-03 4.000E-02

Totals 4.000E-04 3.028E+01 0.000E+00

PM < 10 micron

PER 003EU 065 0.000E+00 0.000E+00 0.000E+00 0.000E+00

PER 004EU 071 1.600E-03 4.000E-04 4.000E-04

PER 002FS 001 3.000E-01 1.300E+00 1.300E+00 1.300E+00

PER 002FS 002 3.000E-03 1.400E-02 1.400E-02 1.000E-02

PER 002FS 003 3.000E-03 1.400E-02 1.400E-02 1.000E-02

PER 003FS 005 2.160E+00 9.460E+00 9.460E+00 9.460E+00

PER 002SV 001 0.000E+00 0.000E+00 0.000E+00 0.000E+00

PER 002SV 002 0.000E+00 0.000E+00 0.000E+00 0.000E+00

PER 002SV 003 0.000E+00 0.000E+00 0.000E+00 0.000E+00

PER 003SV 004 6.900E-02 3.000E+01 3.000E-01 3.000E-01

PER 003SV 005 6.400E-02 2.800E+01 2.800E-01 2.800E-01

PER 003SV 006 1.540E-01 6.800E+01 6.800E-01 6.800E-01

PER 003SV 007 1.540E-01 6.800E+01 6.800E-01 6.800E-01

PER 003SV 008 1.540E-01 6.800E+01 6.800E-01 6.800E-01

PER 003SV 009 1.540E-01 6.800E+01 6.800E-01 6.800E-01

PER 002SV 010 0.000E+00 0.000E+00 0.000E+00 0.000E+00

PER 002SV 011 0.000E+00 0.000E+00 0.000E+00 0.000E+00

PER 002SV 012 0.000E+00 0.000E+00 0.000E+00 0.000E+00

PER 002SV 013 0.000E+00 0.000E+00 0.000E+00 0.000E+00

PER 002SV 014 0.000E+00 0.000E+00 0.000E+00 0.000E+00

PER 003SV 015 3.500E-02 1.500E+01 1.500E-01 1.500E-01

PER 003SV 016 4.600E-02 2.000E+01 2.000E-01 2.000E-01

PER 003SV 017 4.600E-02 2.000E+01 2.000E-01 2.000E-01

PER 003SV 019 8.000E+00 2.500E+02 3.504E+01 1.314E+01

Page 2 of 4

4 May, 2011 11:45



RetiredBy

(Action)

AddedBy

(Action)


(tons per yr)

LimitedPotential

(tons per yr)


(tons per yr)

HourlyPotential

(lbs per hr)



PM < 10 micron

PER 003SV 021 6.400E-01 2.800E+00 3.000E-02 3.000E-02

PER 003SV 023 1.300E-02 6.000E+00 6.000E-02 6.000E-02

PER 003SV 024 5.400E-02 2.400E+01 2.400E-01 2.400E-01

Totals 6.786E+02 5.001E+01 2.810E+01

Total Particulate Matter

PER 003EU 065 0.000E+00 0.000E+00 0.000E+00 0.000E+00

PER 004EU 071 1.600E-03 4.000E-04 4.000E-04

PER 002FS 001 1.520E+00 6.660E+00 6.660E+00 6.660E+00

PER 002FS 002 1.000E-02 6.000E-02 6.000E-02 5.000E-02

PER 002FS 003 1.000E-02 6.000E-02 6.000E-02 5.000E-02

PER 003FS 005 2.160E+00 9.500E+00 9.460E+00 9.500E+00

PER 002SV 001 0.000E+00 0.000E+00 0.000E+00 0.000E+00

PER 002SV 002 0.000E+00 0.000E+00 0.000E+00 0.000E+00

PER 002SV 003 0.000E+00 0.000E+00 0.000E+00 0.000E+00

PER 003SV 004 6.900E-02 3.000E+01 3.000E-01 3.000E-01

PER 003SV 005 6.400E-01 2.800E+01 2.800E-01 2.800E-01

PER 003SV 006 1.540E-01 6.800E+01 6.800E-01 6.800E-01

PER 003SV 007 1.540E-01 6.800E+01 6.800E-01 6.800E-01

PER 003SV 008 1.540E-01 6.800E+01 6.800E-01 6.800E-01

PER 003SV 009 1.540E-01 6.680E+02 6.800E-01 6.800E-01

PER 002SV 010 0.000E+00 0.000E+00 0.000E+00 0.000E+00

PER 002SV 011 0.000E+00 0.000E+00 0.000E+00 0.000E+00

PER 002SV 012 0.000E+00 0.000E+00 0.000E+00 0.000E+00

PER 002SV 013 0.000E+00 0.000E+00 0.000E+00 0.000E+00

PER 002SV 014 0.000E+00 0.000E+00 0.000E+00 0.000E+00

PER 003SV 015 3.500E-02 1.500E+01 1.500E-01 1.500E-01

PER 003SV 016 4.600E-02 2.000E+01 2.000E-01 2.000E-01

PER 003SV 017 4.600E-02 2.000E+01 2.000E-01 2.000E-01

PER 003SV 019 8.000E+00 2.500E+02 3.504E+01 1.314E+01

PER 003SV 021 6.400E-01 2.800E+00 3.000E-02 3.000E-02

PER 003SV 023 1.300E-02 6.000E+00 6.000E-02 6.000E-02

PER 003SV 024 5.400E-02 2.400E+01 2.400E-01 2.400E-01

Totals 1.284E+03 5.546E+01 3.358E+01

Sulfur Dioxide

PER 004EU 071 1.200E-04 3.000E-05 3.000E-05

Page 3 of 4

4 May, 2011 11:45



RetiredBy

(Action)

AddedBy

(Action)


(tons per yr)

LimitedPotential

(tons per yr)


(tons per yr)

HourlyPotential

(lbs per hr)



Sulfur Dioxide

PER 001SV 019 1.500E+01 6.570E+01 6.570E+01 6.570E+01

Totals 6.570E+01 6.570E+01 6.570E+01

Volatile Organic Compounds

PER 004EU 071 4.400E-02 1.100E-02 1.100E-02

PER 001FS 004 1.620E+00 7.110E+00 7.110E+00 7.110E+00

PER 001SV 018 1.250E+01 1.770E+03 5.475E+01 5.475E+01

PER 002SV 019 4.000E+00 3.500E+02 1.752E+01 1.752E+01

PER 003SV 020 4.000E-02 1.800E-01 1.000E-02 1.000E-02

PER 003SV 021 7.200E-01 3.140E+00 4.000E-02 4.000E-02

PER 003SV 022 2.800E+00 1.226E+01 6.120E+00 6.120E+00

PER 004SV 022 7.340E+00 3.069E+02 6.140E+00 6.140E+00

PER 001TK 001 6.000E-02 2.800E-01 2.800E-01 2.800E-01

PER 004TK 001 7.000E-02 3.100E-01 3.100E-01 3.100E-01

PER 001TK 002 6.000E-02 2.800E-01 2.800E-01 2.800E-01

PER 004TK 002 7.000E-02 3.100E-01 3.100E-01 3.100E-01

PER 001TK 003 1.700E-01 7.400E-01 7.400E-01 7.400E-01

PER 003TK 004 2.600E-01 1.140E+00 1.900E-01 1.140E+00

PER 004TK 004 2.600E-01 1.140E+00 1.940E-01 1.140E+00

PER 003TK 005 2.600E-01 1.140E+00 1.900E-01 1.140E+00

PER 004TK 005 2.600E-01 1.140E+00 1.940E-01 1.140E+00

Totals 2.441E+03 8.733E+01 8.921E+01

Page 4 of 4

MINNESOTA POLLUTION CONTROL AGENCYAIR QUALITY520 LAFAYETTE ROADST. PAUL, MN 55155-4194 COMPLIANCE PLAN CD-01

Facility Name: Buffalo Lake Energy LLC


4 May, 2011 11:41Page 1 of 42

Subject Item: Total Facility

NC/CA

Type Citation Requirement

CD hdr OPERATIONAL LIMITS1.0

LIMIT Title I Condition: To avoid majorsource classification under 40CFR Section 52.21 and Minn. R.7007.3000; and to avoid majorsource classification under 40CFR Section 70.2 and Minn. R.7007.0200

Production: less than or equal to 122.9 million gallons/year using 12-month RollingSum of ethanol (200-proof, prior to addition of denaturant).

2.0


Process Throughput: less than or equal to 1223704 tons/year using 12-monthRolling Sum of corn, based on a 56 pound bushel. That is equivalent to 43,703,704bushels per year.

3.0

CD Title I Condition: To avoidclassification as a major sourceand modification under 40 CFRSection 52.21 and Minn. R.7007.3000; and to avoidclassification as a major sourceunder 40 CFR Section 70.2 andMinn. R. 7007.0200

Daily Recordkeeping. On each day of operation, the Permittee shall calculate,record, and maintain the total quantity of grain received at the Buffalo Lake EnergyLLC facility.

4.0

CD Minn. R. 7007.0800, subps. 4 and5

Monthly Recordkeeping - Grain Received. By the 15th of the month, the Permitteeshall calculate and record the following:1) The total tonnage of grain for the previous calendar month using the daily usagerecords.2) The tonnage for the previous month.3) The 12 month rolling sum solids usage for the previous 12 month period bysumming the monthly grain tonnage data for the previous 12 months.

5.0


Process Throughput: less than or equal to 360000 tons/year using 12-monthRolling Sum of Distillers Dried Grains (DDGS) on a dry basis.

6.0

CD hdr SOURCE-SPECIFIC REQUIREMENTS7.0

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

Comply with Fugitive Emission Control Plan: The Permittee shall follow the actionsand recordkeeping specified in the control plan. The plan may be amended by thePermittee with the Commissioner's approval. If the Commissioner determines thePermittee is out of compliance with Minn. R. 7011.0150 or the fugitive control plan,then the Permittee may be required to amend the control plan and/or to install andoperate particulate matter ambient monitors as requested by the Commissioner.

8.0

CD Minn. R. 7007.0800, subp. 2 Follow the Odor Action Plan which is attached to this permit.9.0

CD Minn. R. 7007.0800, subp. 2 Permit Appendices: This permit contains 7 appendices as listed in the permit Tableof Contents. The Permittee shall comply with all requirements contained inappendices I - II and IV - VII.Modeling parameters in Appendix III Modeling Inputs are included for referenceonly and compliance with these parameters is achieved through meeting therequirements that reference Appendix III Modeling Inputs.

10.0

CD hdr OPERATIONAL REQUIREMENTS11.0

CD Minn. R. 7011.0020 Circumvention: Do not install or use a device or means that conceals or dilutesemissions, which would otherwise violate a federal or state air pollution control rule,without reducing the total amount of pollutant emitted.

12.0

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

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

13.0




4 May, 2011 11:41Page 2 of 42

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

Operation and Maintenance Plan: Retain at the stationary source an operation andmaintenance plan for all air pollution control equipment. At a minimum, the O & Mplan shall identify all air pollution control equipment and control practices and shallinclude a preventative maintenance program for the equipment and practices, adescription of (the minimum but not necessarily the only) corrective actions to betaken to restore the equipment and practices to proper operation to meet applicablepermit conditions, a description of the employee training program for properoperation and maintenance of the control equipment and practices, and the recordskept to demonstrate plan implementation.

14.0

CD Minn. R. 7019.1000, subp. 4 Operation Changes: In any shutdown, breakdown, or deviation the Permittee shallimmediately take all practical steps to modify operations to reduce the emission ofany regulated air pollutant. The Commissioner may require feasible and practicalmodifications in the operation to reduce emissions of air pollutants. No emissionsunits that have an unreasonable shutdown or breakdown frequency of process orcontrol equipment shall be permitted to operate.

15.0

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

16.0

CD Minn. R. 7030.0010 - 7030.0080 Noise: The Permittee shall comply with the noise standards set forth in Minn. R.7030.0010 to 7030.0080 at all times during the operation of any emission units.This is a state only requirement and is not enforceable by the EPA Administrator orcitizens under the Clean Air Act.

17.0

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

18.0

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

19.0

CD hdr PERFORMANCE TESTING20.0

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

21.0

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

Performance Test Notifications and Submittals:

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

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

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

22.0

CD Minn. R. 7017.2025, subp. 3 Limits set as a result of a performance test (conducted before or after permitissuance) apply until superseded as stated in the MPCA's Notice of Complianceletter granting preliminary approval. Preliminary approval is based on formal reviewof 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 amendmentincorporating the change.

23.0

CD hdr MONITORING REQUIREMENTS24.0

CD Minn. R. 7007.0800, subp. 4(D) Monitoring Equipment Calibration: The Permittee shall calibrate all requiredmonitoring equipment at least once every 12 months (any requirements applying tocontinuous emission monitors are listed separately in this permit).

25.0

CD Minn. R. 7007.0800, subp. 4(D) Operation of Monitoring Equipment: Unless otherwise noted in Tables A and/or B,monitoring a process or control equipment connected to that process is notnecessary during periods when the process is shutdown, or during checks of themonitoring systems, such as calibration checks and zero and span adjustments. Ifmonitoring records are required, they should reflect any such periods of processshutdown or checks of the monitoring system.

26.0

CD hdr RECORDKEEPING27.0




4 May, 2011 11:41Page 3 of 42

CD Minn. R. 7007.1200, subp. 4 When the Permittee determines that no permit amendment or notification isrequired prior to making a change, the Permittee must retain records of allcalculations required under Minn. R. 7007.1200. For expiring permits, theserecords shall be kept for a period of five years from the date the change was madeor until permit reissuance, whichever is longer. The records shall be kept at thestationary source for the current calendar year of operation and may be kept at thestationary source or office of the stationary source for all other years. The recordsmay be maintained in either electronic or paper format.

28.0

CD Minn. R. 7007.0800, subp. 5(C) Recordkeeping: Retain all records at the stationary source for a period of five (5)years from the date of monitoring, sample, measurement, or report. Records whichmust be retained at this location include all calibration and maintenance records, alloriginal recordings for continuous monitoring instrumentation, and copies of allreports required by the permit. Records must conform to the requirements listed inMinn. R. 7007.0800, subp. 5(A).

29.0

CD Minn. R. 7007. 0800, subp. 5(B) Recordkeeping: Maintain records describing any insignificant modifications (asrequired by Minn. R. 7007.1250, subp. 3) or changes contravening permit terms (asrequired by Minn. R. 7007.1350, subp. 2), including records of the emissionsresulting from those changes.

30.0

CD hdr REPORTING/SUBMITTALS31.0

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

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

32.0

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

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

33.0

CD Minn. R. 7019.1000, subp. 1 Notification of Deviations Endangering Human Health or the Environment: As soonas possible after discovery, notify the Commissioner or the state duty officer, eitherorally or by facsimile, of any deviation from permit conditions which could endangerhuman health or the environment.

34.0

CD Minn. R. 7019.1000, subp. 1 Notification of Deviations Endangering Human Health or the Environment Report:Within 2 working days of discovery, notify the Commissioner in writing of anydeviation from permit conditions which could endanger human health or theenvironment. Include the following information in this written description:1. the cause of the deviation;2. the exact dates of the period of the deviation, if the deviation has been corrected;3. whether or not the deviation has been corrected;4. the anticipated time by which the deviation is expected to be corrected, if not yetcorrected; and5. steps taken or planned to reduce, eliminate, and prevent reoccurrence of thedeviation.

35.0

S/A Minn. R. 7007.0800, subp. 6(A)(2) Semiannual Deviations Report: due 30 days after end of each calendar half-yearstarting 08/24/2006 . The first semiannual report submitted by the Permittee shallcover the calendar half-year in which the permit is issued. The first report of eachcalendar year covers January 1 - June 30. The second report of each calendaryear covers July 1 - December 31. If no deviations have occured, the Permitteeshall submit the report stating no deviations.

36.0

CD Minn. R. 7007.1150 - 7007.1500 Application for Permit Amendment: If a permit amendment is needed, submit anapplication in accordance with the requirements of Minn. R. 7007.1150 throughMinn. R. 7007.1500. Submittal dates vary, depending on the type of amendmentneeded.

37.0




4 May, 2011 11:41Page 4 of 42

S/A Minn. R. 7007.0400, subp. 2 Application for Permit Reissuance: due 180 days before expiration of ExistingPermit

38.0

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

39.0

S/A Minn. R. 7007.0800, subp. 6(C) Compliance Certification: due 31 days after end of each calendar year starting08/24/2006 (for the previous calendar year). To be submitted to the Commissioneron a form approved by the Commissioner. This report covers all deviationsexperienced during the calendar year.

40.0

CD Minn. R. 7019.3000 - 7019.3100 Emission Inventory Report: due on or before April 1 of each calendar yearfollowing permit issuance. To be submitted on a form approved by theCommissioner.

41.0

CD Minn. R. 7002.0005 - 7002.0095 Emission Fees: due 60 days after receipt of an MPCA bill.42.0

CD 40 CFR pt. 68 The Permittee must submit a Risk Management Plan (RMP) under 40 CFR pt. 68.Each owner or operator of a stationary source, at which a regulated substance ispresent above a threshold quantity in a process, shall design and implement anaccidental release prevention program. An initial RMP must be submitted no laterthan the latest of the following dates: 1) June 21, 1999; 2) Three years after thedate on which a regulated substance is first listed under 40 CFR Section 68.130; or3) The date on which a regulated substance is first present above a thresholdquantity in a process. A full update and resubmission of the RMP is required atleast once every five years. The five-year anniversary date is reset whenever yourfacility fully updates and resubmits their RMP. Submit RMPs to the RiskManagement Plan Reporting Center, P.O. Box 1515, Lanham-Seabrook, Maryland20703-1515. RMP information may be obtained at http://www.epa.gov/swercepp orby calling 1-800-424-9346.

43.0

CD hdr MODELING REQUIREMENTS44.0

CD Minn. R. 7009.0020; Minn. R.7007.0800, subp. 2

Parameters Used in Modeling: The parameters used in the modeling performed foran Environmental Assessment Worksheet under Minn. R. ch. 4410 and fordetermining emission and/or operational limits, if applicable for this facility are listedin Appendix III of this permit. If the Permittee intends to change any of theseparameters, the Permittee must submit the revised parameters to theCommissioner and receive written approval before making any changes. Therevised parameter information submittal must include, but is not limited to: thelocations, heights and diameters of the stacks; locations and dimensions of nearbybuildings; velocity and temperatures of the gases emitted; and the emission rates.The plume dispersion characteristics due to the parameter revisions must equal orexceed the dispersion characteristics modeled for this permit, and the Permitteeshall demonstrate this in the proposal.

45.0

CD Title I Condition: 40 CFR Section52.21(k); Minn. R. 7007.3000

Parameters Used in Modeling: The stack heights, stack diameters, air flow rates,and exhaust gas temperatures used in the modeling performed for the PSDanalysis for this permit are listed in Appendix III of this permit. The Permittee mustsubmit to the Agency for approval any revisions of these parameters that arecaused by a physical change or change in the method of operation of the facilityand must wait for a written approval before making such changes. The informationsubmitted must include, at a minimum, the locations, heights and diameters of thestacks, locations and dimensions of nearby buildings, the velocity and temperatureof the gases emitted, and the PM10 emission rates. The plume dispersioncharacteristics after the proposed revisions must be equivalent to or better than thedispersion characteristics used in the model dated March 13, 2006. The Permitteeshall demonstrate this equivalency in the proposal.

46.0


If the information submitted does not demonstrate equivalent or better dispersioncharacteristics, or if a conclusion cannot readily be made about the dispersion, thePermittee must remodel.

For any physical change to or change in the method of operation of a stack emittingPM10 or for any increase in PM10 emissions (whether or not the increase wouldrequire a permit amendment of any type), the Permittee must remodel.

For changes that do not involve any increase to any emission rate or any emissionsfrom a new emission point, this proposal must be submitted as soon as practicable,but no less than 60 days before beginning actual construction of the modification,stack, or associated emission unit(s).

47.0




4 May, 2011 11:41Page 5 of 42


For changes involving increases in emission rates or emissions from a newemission point and that require a minor permit amendment, the proposal and/orrequired modeling analysis must be submitted as soon as practicable, but no lessthan 60 days before beginning actual construction of the modification, stack, orassociated emission unit(s).

For changes involving increases in emission rates or emissions from a newemission point and that require a permit amendment other than a minoramendment, the proposal and/or modeling analysis must be submitted with thepermit application.

48.0

CD Minn. R. ch. 7009 The Permittee shall install fencing around the facility. In areas where fencing is notpermissible by setbacks, right-of-ways, safety concerns, or clearances, thePermittee will use signage and patrolling to sufficiently restrict public access to theproperty outlined as fenced in the dispersion modeling.

The Permittee shall maintain an Access Restriction Plan onsite describing physicaland active barriers sufficient to restrict public access to the property as delineatedin the most recent compliant dispersion modeling analysis.

49.0




4 May, 2011 11:41Page 6 of 42

Subject Item: GP 001 Baghouses

Associated Items: CE 004 Fabric Filter - Low Temperature, i.e., T<180 Degrees F











NC/CA


CD hdr POLLUTION CONTROL REQUIREMENTS1.0


Total Particulate Matter: greater than or equal to 99 percent control efficiency . ThePermittee shall operate and maintain the fabric filters such that they achieve 99%overall control efficiency. This limit applies to each fabric filter individually.

2.0


PM < 10 micron: greater than or equal to 99 percent control efficiency . ThePermittee shall operate and maintain the fabric filters such that they achieve 99%overall control efficiency. This limit applies to each fabric filter individually.

3.0


LIMIT Title I Condition: To avoidclassification as a major sourceand modification under 40 CFRSection 52.21 and Minn. R.7007.3000; To avoid classificationas major source under 40 CFRSection 70.2 and Minn. R.7007.0200, Minn. R. 7007.0800,subps. 2 and 14; Minn. R.7017.2025, subp. 3


5.0

CD Title I Condition: Monitoring forLimit taken to avoid classificationas a major source andmodification under 40 CFRSection 52.21; to avoidclassification as a major sourceunder 40 CFR Section 70.2; Minn.R. 7011.0080

Visible Emissions: The Permittee shall check the fabric filter stacks for any visibleemissions once each day of operation during daylight hours. During inclementweather, the Permittee shall read and record the pressure drop across the fabricfilter, once each day of operation.

6.0


CD Title I Condition: To avoidclassification as a major sourceand modification under 40 CFRSection 52.21 and Minn. R.7007.3000; To avoid classificationas a major source under 40 CFRSection 70.2 and Minn. R.7007.0200; Minn. R. 7007.0800,subps. 4 and 5

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

8.0




4 May, 2011 11:41Page 7 of 42

CD Title I Condition: To avoidclassification as a major sourceand modification under 40 CFRSection 52.21 and Minn. R.7007.3000; To avoid classificationas major source under 40 CFRSection 70.2 and Minn. R.7007.0200, Minn. R. 7007.0800,subps. 2 and 14

The Permittee shall operate and maintain the fabric filters at all times that anyemission unit controlled by the fabric filter is in operation. The Permittee shalldocument periods of non-operation of the control equipment. Vent emissions fromall units controlled by the baghouses in GP001, through the baghouses at all timesthat the associated units are in operation.

9.0

CD Minn. R. 7007.0800, subp. 14 The Permittee shall operate and maintain the fabric filter according to the controlequipment manufacturer's specifications and/or in accordance with the Operationand Maintenance (O & M) Plan. The Permittee shall keep copies of the O & M Planavailable onsite for use by staff and MPCA staff.

10.0

CD Minn. R. 7007.0800, subp. 4 Monitoring Equipment: The Permittee shall install and maintain the necessarymonitoring equipment for measuring and recording pressure drop as required bythis permit. The monitoring equipment must be installed, in use, and properlymaintained when the monitored fabric filter is in operation.

11.0

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

Corrective Actions: The Permittee shall take corrective action as soon as possible ifany of the following occur:- visible emissions are observed;- the recorded pressure drop is outside the required operating range; or- the fabric filter or any of its components are found during the inspections to needrepair.Corrective actions shall return the pressure drop to within the permitted range,eliminate visible emissions, and/or include completion of necessary repairsidentified during the inspection, as applicable. Corrective actions include, but arenot limited to, those outlined in the O & M Plan for the fabric filter. The Permitteeshall keep a record of the type and date of any corrective action taken for eachfilter.

12.0


Periodic Inspections: At least once per calendar quarter, or more frequently asrequired by the manufacturing specifications, the Permittee shall inspect the controlequipment components. The Permittee shall maintain a written record of theseinspections.

13.0




4 May, 2011 11:41Page 8 of 42

Subject Item: GP 003 Dryers

Associated Items: EU 056 DDGS Dryer A

EU 058 DDGS Dryer B

NC/CA



CD Title I Condition: To avoid majorsource classification under 40CFR Section 52.21 and Minn. R.7007.3000; and to avoid majorsource classification under 40CFR Section 70.2 and Minn. R.7007.0200

Fuel Burned: Natural gas only2.0

CD Minn. R. 7017.2025, subp. 3 Operating limits based on performance tests: Limits set following a performancetest for dryers may include a production limit (wetcake feedrate or beer feedrate asa surrogate), syrup feedrate, and dryer temperature.

3.0

CD Title I Condition: to avoid majorsource classification under 40CFR Section 52.21 and Minn. R.7007.3000; to avoid major sourceclassification under 40 CFRSection 70.2 and Minn. R.7007.0200

When a shutdown or breakdown of either thermal oxidizer occurs, the Permitteeshall stop wetcake feed to the dryer. The Permittee may continue operation of thedryer only as long as necessary to empty material already in the dryer.

4.0



Vent all emissions to the thermal oxidizer (CE020 and CE022).6.0

CD Minn. R. 7007.0800, subp. 14 The Permittee shall operate and maintain each dryer in accordance with theOperation and Maintenance (O & M) Plan. The Permittee shall keep copies of theO & M Plan available onsite for use by staff.

7.0

CD hdr PROCESS MONITORING8.0


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

9.0


Inspect monthly or as required by manufacturing specifications, all components thatare subject to wear or plugging. Maintain a written record of the inspection and anyaction resulting from the inspection.

10.0


Calibrate gauges annually or as often as required by manufacturing specificationsand maintain a written record of the calibration and any action resulting from thecalibration.

11.0




4 May, 2011 11:41Page 9 of 42

Subject Item: GP 004 Thermal Oxidizer with Heat Recovery Boiler



EU 013 Yeast Tank 1

EU 014 Yeast Tank 2




EU 018 Stripper 1

EU 019 Stripper 2

EU 020 Rectifier 1

EU 021 Rectifier 2

EU 022 Evaporator 1

EU 023 Evaporator 2

EU 024 Syrup Tank

EU 025 Centrifuge 1

EU 026 Centrifuge 2

EU 027 Centrifuge 3

EU 028 Centrifuge 4

EU 029 Centrifuge 5

EU 030 Centrifuge 6

EU 031 Centrifuge 7

EU 032 Centrifuge 8









NC/CA


CD hdr SUBPART Db REQUIREMENTS1.0

LIMIT 40 CFR 60.44b(a)(1)(i); Minn. R.7011.0565

Nitrogen Oxides: less than or equal to 0.10 lbs/million Btu heat input using 30-dayRolling Average

2.0

CD 40 CFR 60.48b(b)(1); Minn. R.7011.0565

The Permittee shall install, calibrate, maintain, and operate a continuous monitoringsystem, and record the output of the system, for measuring nitrogen oxidesemissions discharged to the atmosphere.

3.0

CD 40 CFR 60.49b(b); Minn. R.7011.0565

The Permittee subject to the nitrogen oxides emission limit under 40 CFR Section60.44b shall submit to the Administrator the performance test data from the initialperformance test and the performance evaluation of the CEMS using the applicableperformance specifications in 40 CFR pt. 60, appendix B.

4.0

CD 40 CFR 60.49b(d); Minn. R.7011.0565

The Permittee shall record and maintain records of the amounts of natural gascombusted during each day and calculate the annual capacity factor individually fornatural gas for the reporting period. The annual capacity factor is determined on a12-month rolling average basis with a new annual capacity factor calculated at theend of each calendar month.

5.0




4 May, 2011 11:41Page 10 of 42



Temperature: greater than or equal to 1400 degrees F using 3-hour RollingAverage as a 3-hour rolling average at the combustion chamber outlet, unless anew limit is set pursuant to Minn. R. 7017.2025, subp. 3 based on the valuesrecorded during the most recent MPCA-approved performance test wherecompliance was demonstrated. The new limit shall be implemented upon receipt ofthe Notice of Compliance letter granting preliminary approval. The limit is final uponissuance of a permit amendment incorporating the change. If the 3-hour rollingaverage temperature is below the minimum temperature limit, the VOC used duringthat time shall be considered uncontrolled until the average temperature is abovethe minimum temperature limit. This shall be reported as a deviation.

7.0



8.0


Fuel Burned: Natural gas only9.0


Vent all emissions from DDGS Dryers (EU 056 and EU 058) and DDGS Coolers tothe Thermal Oxidizers/Heat Recovery Boilers (EU 057 and EU 059)

10.0

CD Title I Condition: To avoidclassification as a major sourceand modification under 40 CFRSection 52.21 and Minn. R.7007.3000; To avoid classificationas major source under 40 CFRSection 70.2 and Minn. R.7007.0200, Minn. R. 7007.0800,subps. 2 and 14

The Permittee shall operate and maintain the thermal oxidizer any time that anyprocess equipment controlled by the thermal oxidizer is in operation in accordancewith the Operation and Maintenance (O & M) Plan. The Permittee shall keepcopies of the O & M Plan available onsite for use by staff and MPCA staff. ThePermittee shall document periods of non-operation of the control equipment. Ventemissions from all units controlled by the thermal oxidizers EU057 and EU059,through the thermal oxidizers at all times that the associated units are in operation.

11.0



The Permittee shall maintain and operate a thermocouple monitoring device thatcontinuously indicates and records the combustion chamber temperature of thethermal oxidizer. The thermocouple must be installed, in use, and properlymaintained whenever operation of the thermal oxidizer is required. The monitoringdevice shall have a margin of error less than the greater of +/- 0.75 percent of thetemperature being measured or +/- 2.5 degrees Celsius. The recording deviceshall also calculate the three-hour rolling average combustion chambertemperature.

13.0


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

14.0


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

15.0


Quarterly Inspections: At least once per calendar quarter, the Permittee shallinspect the control equipment internal and external system components, includingbut not limited to the refractory, heat exchanger, and electrical systems. ThePermittee shall maintain a written record of the inspection and any correctiveactions taken resulting from the inspection.

16.0




4 May, 2011 11:41Page 11 of 42


Annual Calibration: The Permittee shall calibrate the temperature monitor at leastannually and shall maintain a written record of the calibration and any actionresulting from the calibration.

17.0

CD hdr RECORDKEEPING AND REPORTING18.0


The Permittee shall maintain a continuous hard copy readout or computer disk fileof the temperature readings for the combustion chamber.

19.0

CD hdr CONTINUOUS MONITORING REQUIREMENTS20.0

CD Minn. R. 7017.1006 CEMS Installation: Install NOx and CO CEMS.21.0

CD Minn. R. 7017.1040, subp. 1 Installation Notification: due 60 days before installing the continuous emissionsmonitoring system. The notification shall include plans and drawings of the system.

22.0

S/A 40 CFR Section 40 CFR Section60.8(a); 40 CFR Section 60.13(b);Minn. R. 7017.1050, subp. 1

CEM Certification Test: due 60 days after achieving maximum capacity but not laterthan 180 days after startup, or 90 days after the due date of the first excessemissions report, which ever is more stringent.

23.0

CD 40 CFR Section 60.7(a)(5); Minn.R. 7017.1060, subps. 1 and 2

CEMS Certification Test Plan: due 30 days before CEMS Certification Test.24.0

CD Minn. R. 7017.1060, subp. 3 CEMS Certification Test Pretest Meeting: due 7 days before CEMS CertificationTest.

25.0

CD Minn. R. 7017.1080, subps. 1, 2and 4; 40 CFR Section 60.13(c)(2)

CEMS Certification Test Report: due 45 days after CEMS Certification Test26.0

CD Minn. R. 7017.1080, subp. 3 CEMS Certification Test Report - Microfiche or CD Copy: due 105 days afterCEMS Certification Test.

27.0

CD Minn. R. 7017.1170, subp. 3 CEMS Daily Calibration Drift (CD) Test: The CD shall be quantified and recorded atzero (low-level) and upscale (high-level) gas concentrations at least once daily.The CEMS shall be adjusted whenever the CD exceeds twice the specification of40 CFR pt. 60, Appendix B. 40 CFR pt. 60, Appendix F, shall be used to determineout-of-control periods for CEMS. Follow the procedures in 40 CFR pt. 60, AppendixF.

28.0

CD 40 CFR pt. 60, Appendix F,section 5.1.2; Minn. R. 7017.1170,subp. 4

Cylinder Gas Audit (CGA): due before end of each calendar quarter followingCEMS certification test. A CGA is not required during any calendar quarter inwhich a RATA was performed. The initial CGA must be performed within 80 daysfollowing certification of the CEMS. The CGAs shall be conducted at least threemonths apart but no more than eight months apart. A CGA shall be conductedaccording to the procedures in 40 CFR pt. 60, Appendix F, section 5.1.2.

29.0

S/A Minn. R. 7017.1180, subp. 1 Cylinder Gas Audit (CGA) Results Summary: due 30 days after end of eachcalendar quarter following end of the calendar quarter in which the Audit wasperformed

30.0

CD 40 CFR pt. 60, Appendix F,section 5.1.1; Minn. R. 7017.1170,subp. 5

CEMS Relative Accuracy Test Audit (RATA): due before end of each calendaryear following CEMS Certification Test . A RATA is not required in any calendaryear if a RATA conducted in the previous year demonstrated a relative accuracyvalue of less than 15 percent or if the associated emissions unit operated less than48 hours during the calendar year. If the exception is used, the next RATA shall beconducted during the first half of the following calendar year. RATAs shall beconducted at least 3 months apart according to 40 CFR pt. 60, Appendix F, section5.1.1.

31.0

CD Minn. R. 7017.1180, subp. 2 Relative Accuracy Test Audit (RATA) Notification: due 30 days before CEMSRelative Accuracy Test Audit (RATA)) . <When subject to Appendix F>

32.0

S/A Minn. R. 7017.1180, subp. 3 Relative Accuracy Test Audit (RATA) Results Summary: due 45 days after end ofeach calendar year following CEMS Relative Accuracy Test Audit (RATA)

33.0

S/A Minn. R. 7017.1110, subps. 1 and2

Excess Emissions/Downtime Reports (EER's): due 30 days after end of eachcalendar quarter following Initial Startup of the Monitor (Submit DeviationsReporting Form DRF-1 as amended). The EER shall indicate all periods of monitorbypass and all periods of exceedances of the limit including exceedances allowedby an applicable standard, i.e. during startup, shutdown, and malfunctions.

34.0




4 May, 2011 11:41Page 12 of 42

CD Minn. R. 7017.1090, subp. 1 Continuous Operation: CEMS must be operated and data recorded during allperiods of emission unit operation including periods of emission unit start-up,shutdown, or malfunction except for periods of acceptable monitor downtime. Thisrequirement applies whether or not a numerical emission limit applies during theseperiods. A CEMS must not be bypassed except in emergencies where failure tobypass would endanger human health, safety, or plant equipment.

Acceptable monitor downtime includes reasonable periods as listed in Items A, B,C and D of Minn. R. 7017.1090, subp. 2.

35.0

CD Minn. R. 7007.1130 Recordkeeping: The owner or operator must retain records of all CEMS monitoringdata and support information for a period of five years from the date of themonitoring sample, measurement or report. Records shall be kept at the source.

36.0

CD Minn. R. 7017.1170, subp. 2 QA Plan: Develop and implement a written quality assurance plan that covers eachCEMS. The plan shall be on site and available for inspection within 30 days aftermonitor certification. The plan shall contain all of the information required by 40CFR pt. 60, App. F, section 3.

37.0

S/A 40 CFR Section 60.7(a)(3); Minn.R. 7019.0100, subp. 1

Notification of the Actual Date of Initial Startup: due 15 days after 05/15/2008 Thisnotification has been submitted and was received by the MPCA on 6/2/2008.

38.0




4 May, 2011 11:41Page 13 of 42

Subject Item: GP 005 Internal Floating Roof Tanks

Associated Items: TK 001 200 Proof Ethanol

TK 002 200 Proof Ethanol

TK 003 Denaturant



NC/CA



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

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

2.0

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

Internal Floating Roof Seal Requirement: Each internal roof shall be equipped withone of the closure devices between the wall of the storage vessel and the edge ofthe internal floating roof as described in 40 CFR Section 60.112b(a)(1)(ii).

3.0


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

Inspection - Prior to initial fill of tanks: Visually inspect the internal floating roof, theprimary seal, and the secondary seal (if one is in service), prior to filling the storagevessel with Volatile Organic Liquid (VOL). If there are holes, tears, or otheropenings in the primary seal, the secondary seal, or the seal fabric; or defects inthe internal floating roof, or both, the Permittee shall repair the items before fillingthe storage vessel.

5.0

CD 40 CFR Section 60.113b(a)(2) and(4); Minn. R. 7011.1520(C)

Inspection - Annual: Visually inspect the internal floating roof, the primary seal, andthe secondary seal (if one is in service) through manholes and roof hatches on thefixed roof at least once every twelve (12) months after initial fill as required by 40CFR Section 60.113b(a)(2).

6.0

CD 40 CFR Section 60.113b(a)(2) and(4); Minn. R. 7011.1520(C)

Inspection - Tank Empty and Degassed: Visually inspect the internal floating roof,the primary seal, and the secondary seal (if one is in service), gaskets, slottedmembranes and sleeve seals (if any) each time the tank is emptied and degassedas required by 40 CFR Section 60.113b(a)(4). In no event shall inspectionsconducted in accordance with this provision occur at intervals greater than 10years.

7.0

CD hdr RECORDKEEPING REQUIREMENTS8.0


Keep a record of each inspection performed as required by 40 CFR Section60.113b(a). Each record shall identify the storage vessel on which the inspectionwas performed and shall contain the date the vessel was inspected and theobserved condition of each component of the control equipment (seals, internalfloating roof, and fittings).

9.0

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

Recordkeeping: Maintain records showing the dimensions of each tank and ananalysis showing tank capacity.

10.0

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

Recordkeeping: Maintain records of the volatile organic liquid (VOL) stored, theperiod of storage, and the maximum true vapor pressure of the VOL during therespective storage period, calculated as described in 40 CFR Section 60.116b(e).

11.0

CD hdr REPORTING REQUIREMENTS12.0


Notification of the Date Construction Began: due 30 days after Start OfConstruction. Submit the name and number of each unit and the date constructionof each unit began.

13.0


Notification of the Actual Date of Initial Startup: due 15 days after Initial Startup14.0


Notification: Notify the Commissioner in writing at least 30 days prior to the filling orrefilling of each tank for which an inspection is required by 40 CFR Section 60.113b(a)(1) and (a)(4) to afford the Commissioner the opportunity to have an observerpresent. If the inspection required by 40 CFR 6.113b(a)(4) is not planned and thePermittee could not have known about the inspection 30 days in advance of refillingthe tank, the Permittee shall notify the Administrator at least 7 days prior to therefilling of the tank. Notification shall be made by telephone followed by writtendocumentation demonstrating why the inspection was unplanned. Alternatively,this notification including the written documentation may be made in writing andsent by express mail so that it is received by the Commissioner at least 7 days priorto the refilling.

15.0




4 May, 2011 11:41Page 14 of 42

CD 40 CFR Section 60.115b(a)(4);Minn. R. 7011.1520 (C)

After each inspection required by 40 CFR Section 60.113b(a)(3) that finds holes ortears in the seal or seal fabric, or defects in the internal floating roof, or othercontrol equipment defects listed in 40 CFR Section 60.113b(a)(3)(ii), a report shallbe furnished to the Administrator within thirty (30) days of the inspection. Thereport shall identify the storage vessel and the reason it did not meet thespecifications of 40 CFR Section 60.112b(a)(1) or 40 CFR Section 60.113b(a)(3)(ii)and list each repair made.

16.0


Notification - Control Equipment Installation and Certification: After installing theinternal floating roofs, furnish the Administrator with a report describing the controlequipment (fixed roof/internal floating roof combination) and certifying that thecontrol equipment meets the specifications of Sections 60.112b(a)(1) and60.113b(a)(1). This report shall be attached to the initial startup notificationrequired by Section 60.7(a)(3) and located in Table B of this permit.

17.0


Reporting - Annual Inspection Results: If any of the conditions described in 40CFR Section 60.113b(a)(2) are detected during the annual visual inspectionrequired by 40 CFR Section 60.113b(a)(2), a report shall be furnished to theAdministrator within 30 days of the inspection. Each report shall identify the tank,the nature of the defects, and the date the tank was emptied or the nature of anddate the repair was made.

18.0




4 May, 2011 11:41Page 15 of 42

Subject Item: GP 006 Ethanol Loadout



NC/CA



Vent all emissions when loading ethanol into trucks and/or railcars to the LoadoutFlare (EU066, CE023).

1.0




4 May, 2011 11:41Page 16 of 42

Subject Item: GP 007 Multiclones

Associated Items: CE 019 Centrifugal Collector - High Efficiency

CE 021 Centrifugal Collector - High Efficiency

NC/CA


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


1.0


Record pressure drop once each day of operation.2.0


Vent all emissions to the thermal oxidizers (CE020 and CE022).3.0


Inspect monthly, or as required by manufacturing specificatioins, all componentsthat are subject to wear or plugging. Maintain a written record of the inspectionsand any corrective actions resulting from the inspection.

4.0


Calibrate the pressure gauge annually or as often as required by manufacturingspecifications and maintain a written record of the calibration and any actionresulting from the calibration.

5.0

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

Corrective Actions: If the pressure drop is outside of the range specified by thispermit or if the dryers or any of their components are found during the inspectionsto need repair, the Permittee shall take corrective action as soon as possible.Corrective actions shall return the pressure drop to the permitted range and/orinclude completion of necessary repairs identified during the inspection, asapplicable. Corrective actions include, but are not limited to, those outlined in the O& M Plan for the dryers. The Permittee shall keep a record of the type and date ofany corrective action taken.

6.0




4 May, 2011 11:41Page 17 of 42

Subject Item: GP 009 Hammermills


EU 008 Hammermill 2

EU 009 Hammermill 3

EU 010 Hammermill 4

NC/CA


CD Title I Condition: To avoidclassification as a major sourceand modification under 40 CFRSection 52.21 and Minn. R.7007.3000; To avoid classificationas major source under 40 CFRSection 70.2 and Minn. R.7007.0200

The Hammermills are not to be operating while corn is being shipped from CargillAgHorizons.

1.0


Daily Recordkeeping. At any time that grain is shipped from the Cargill AgHorizonsfacility, the Permittee shall record and maintain a record of the dates and timeswhich the Hammermills are not operating.

2.0




4 May, 2011 11:41Page 18 of 42

Subject Item: SV 004 Corn Elevator Baghouse 1

Associated Items: EU 004 Corn Elevator 1


NC/CA



Total Particulate Matter: less than or equal to 0.0030 grains/dry standard cubic foot1.0


PM < 10 micron: less than or equal to 0.0030 grains/dry standard cubic foot2.0

S/A Title I Condition: To avoid majorsource classification under 40CFR Section 52.21 and Minn. R.7007.3000; and to avoid majorsource classification under 40CFR Section 70.2 and Minn. R.7007.0200

Performance Test: due before end of each 60 months starting 10/21/2008 for PM.3.0



4.0

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



5.0




4 May, 2011 11:41Page 19 of 42

Subject Item: SV 005 Corn Storage Silo Baghouse 1

Associated Items: EU 005 Scalper

EU 006 Corn Storage Silo 1


NC/CA










4.0




5.0




4 May, 2011 11:41Page 20 of 42




NC/CA










4.0




5.0




4 May, 2011 11:41Page 21 of 42




NC/CA










4.0




5.0




4 May, 2011 11:41Page 22 of 42




NC/CA










4.0




5.0




4 May, 2011 11:41Page 23 of 42




NC/CA










4.0




5.0




4 May, 2011 11:41Page 24 of 42

Subject Item: SV 015 DDGS Handling Baghouse 6

Associated Items: EU 053 DDGS Bucket elevator


NC/CA










4.0




5.0




4 May, 2011 11:41Page 25 of 42


Associated Items: EU 054 DDGS Truck Load Spout


NC/CA










4.0




5.0




4 May, 2011 11:41Page 26 of 42


Associated Items: EU 055 DDGS Rail Load Spout


NC/CA










4.0




5.0




4 May, 2011 11:41Page 27 of 42

Subject Item: SV 019 TO/HRBs



EU 013 Yeast Tank 1

EU 014 Yeast Tank 2




EU 018 Stripper 1

EU 019 Stripper 2

EU 020 Rectifier 1

EU 021 Rectifier 2

EU 022 Evaporator 1

EU 023 Evaporator 2

EU 024 Syrup Tank

EU 025 Centrifuge 1

EU 026 Centrifuge 2

EU 027 Centrifuge 3

EU 028 Centrifuge 4

EU 029 Centrifuge 5

EU 030 Centrifuge 6

EU 031 Centrifuge 7

EU 032 Centrifuge 8







EU 056 DDGS Dryer A


EU 058 DDGS Dryer B




NC/CA


CD hdr LIMITS1.0

LIMIT 40 CFR Section 60.43b(f); 40 CFRSection 60.43b(g); Minn. R.7011.0610, subp. 1(A)(2)

Opacity: less than or equal to 20.0 percent opacity (6-minute average), except forone 6-minute period per hour of not more than 27 percent opacity. The limit appliesat all times, except during periods of startup, shutdown, or malfunction.

This is more stringent than Minn. R. 7011.0610, subp. 1(A)(2).

2.0




4 May, 2011 11:41Page 28 of 42


Volatile Organic Compounds: less than or equal to 4.0 lbs/hour using 12-monthRolling Sum as total mass of VOC.

3.0

LIMIT Title I Condition: To avoid majorsource classification under 40CFR Section 52.21 and Minn. R.7007.3000;most stringent, meets limits set byMinn. R. 7011.0610.

Total Particulate Matter: less than or equal to 8 lbs/hour4.0


PM < 10 micron: less than or equal to 8 lbs/hour5.0


Carbon Monoxide: less than or equal to 20.0 lbs/hour , based on a 30-day rollingaverage calculated using the total mass emissions for the previous 30 days.

6.0


Nitrogen Oxides: less than or equal to 20.9 lbs/hour , based on a 30-day rollingaverage calculated using the total mass emissions for the previous 30 days.

7.0


Sulfur Dioxide: less than or equal to 15.0 lbs/hour8.0

CD hdr PERFORMANCE TESTING REQUIREMENTS9.0

S/A Minn. R. 7017.2020, subp. 1 Performance Test: due before end of each 60 months starting 02/27/2009 for PM.10.0

S/A Minn. R. 7017.2020, subp. 1 Performance Test: due before end of each 60 months starting 02/27/2009 forPM10.

11.0

S/A Minn. R. 7017.2020, subp. 1 Performance Test: due before end of each 36 months starting 02/27/2009 for NOx.12.0

S/A Minn. R. 7017.2020, subp. 1 Performance Test: due before end of each 60 months starting 10/21/2008 for CO.13.0

S/A Minn. R. 7017.2020, subp. 1 Performance Test: due before end of each 60 months starting 10/21/2008 for totalmass VOC emissions including HAPS as outlined in Appendix VI.

14.0




15.0




4 May, 2011 11:41Page 29 of 42

Subject Item: SV 023 DDGS Bulkweigher Baghouse

Associated Items: EU 067 DDGS Bulkweigher


NC/CA







Initial Performance Test: due 180 days after Initial Startup for PM3.0






5.0

S/A Minn. R. 7017.2020, subp. 1 Testing Frequency Plan: due 60 days after Initial Performance Test for PMemissions. The plan shall specify a testing frequency based on the test data andMPCA guidance. Future performance tests based on one-year (12 month), 36month, and 60 month intervals, or as applicable, shall be required upon writtenapproval of the MPCA.

6.0

S/A Minn. R. 7017.2020, subp. 1 Testing Frequency Plan: due 60 days after Initial Performance Test for PM10emissions. The plan shall specify a testing frequency based on the test data andMPCA guidance. Future performance tests based on one-year (12 month), 36month, and 60 month intervals, or as applicable, shall be required upon writtenapproval of the MPCA.

7.0




4 May, 2011 11:41Page 30 of 42

Subject Item: SV 024 DDGS Cross Conveyor Baghouse

Associated Items: EU 068 DDGS Cross Conveyor


NC/CA













5.0

S/A Minn. R. 7017.2020, subp. 1 Testing Frequency Plan: due 60 days after Initial Performance Test for PMemissions. The plan shall specify a testing frequency based on the test data andMPCA guidance. Future performance tests based on one-year (12 month), 36month, and 60 month intervals, or as applicable, shall be required upon writtenapproval of the MPCA.

6.0

S/A Minn. R. 7017.2020, subp. 1 Testing Frequency Plan: due 60 days after Initial Performance Test for PM10emissions. The plan shall specify a testing frequency based on the test data andMPCA guidance. Future performance tests based on one-year (12 month), 36month, and 60 month intervals, or as applicable, shall be required upon writtenapproval of the MPCA.

7.0




4 May, 2011 11:41Page 31 of 42

Subject Item: EU 065 Emergency Fire Pump

Associated Items: SV 021 Emergency Fire Pump

NC/CA


LIMIT Minn. R. 7011.2300, subp. 1 Opacity: less than or equal to 20.0 percent opacity Once operating temperatureshave been attained.

1.0

CD Title I Condition: To avoid majorsource classification under 40CFR Section 52.21 and Minn. R.7007.3000; and to avoid majorsource classification under 40CFR Section 70.2 and Minn. R.7007.0200; 40 CFR Section60.4211(e)

Operating Hours: Less than or equal to 100 hours per year using a 12-month rollingsum for the pump for routine testing and maintenance. The sum for the previous12-month period is to be calculated by the 15th day of each month.

2.0


Hours of Operation: The Permittee shall record each month the number of hours ofoperation of the fire pump and a monthly record of 12-month rolling sum of thehours of operation.

3.0

CD hdr NSPS SUBPART IIII REQUIREMENTS4.0

CD 40 CFR Section 60.4205(c); Minn.R. 7011.3520

Owners and operators of fire pump engines with a displacement of less than 30liters per cylinder must comply with the emission standards in Table 4 to subpartIIII, for all pollutants.

5.0

CD 40 CFR Section 60.4207(a) and(b); Minn. R. 7011.3520

Effective October 1, 2007, diesel fuel must meet 40 CFR Section 80.510(a);Effective October 1, 2010, diesel fuel must meet 40 CFR Section 80.510(b) fornonroad diesel fuel.

6.0

CD 40 CFR Section 60.4209(a); Minn.R. 7011.3520

The engine must be equipped with a nonresettable hours-of-operation meter.7.0

CD 40 CFR Section 60.4211(b); Minn.R. 7011.3520

The Permittee shall keep the records or perform the tests specified in one of themethods specified in 40 CFR Section 60.4211.

8.0

CD hdr RECORDKEEPING9.0


Hours of Operation: The Permittee shall maintain documentation on site that theunit is an emergency generator by design that qualifies under the U.S.EPAmemorandum entittled "Calculating Potential to Emit (PTE) for EmergencyGenerators" dated September 6, 1995, limiting operation to 500 hours per year.

10.0


Fuel Supplier Certification: The Permittee shall obtain and maintain a fuel suppliercertification for each shipment of fuel oil, certifying that the fuel oil meets therequirements of 40 CFR Section 80.510(a) or (b).

11.0




4 May, 2011 11:41Page 32 of 42

Subject Item: EU 071 Natural Gas Emergency Generator

NC/CA


CD 40 CFR pt. 63, subp. ZZZZ; Minn.R. 7011.8150

40 CFR pt. 63, subp. ZZZZ applies to this generator. In accordance with Section63.6590(c) the generator must meet the requirements of this part by meeting therequirements of 40 CFR pt. 60, subp. JJJJ. Since the engine was not manufacturedon or after January 1, 2009, there are no applicable requirements from subp. JJJJfor this emission unit.

1.0

CD hdr EMISSION LIMITS2.0

LIMIT Minn. R. 7011.2300, subp. 1 Opacity: less than or equal to 20 percent opacity once operating temperatures havebeen attained.

3.0

LIMIT Minn. R. 7011.2300, subp. 2 Sulfur Dioxide: less than or equal to 0.5 lbs/million Btu heat input .4.0


CD Minn. R. 7005.0100, subp. 35a Fuel type: Natural gas only.6.0

LIMIT Minn. R. 7007.0800, subps. 4 and5

Operating Hours: less than or equal to 500 hours/year using 12-month Rolling Sum. The U.S. EPA memorandum entitled "Calculating Potential to Emit (PTE) forEmergency Generators", dated September 6, 1995, limits operation to 500 hoursper year.

7.0

CD hdr RECORDKEEPING REQUIREMENTS8.0


Recordkeeping - Operating Hours: The Permittee shall maintain documentation ofhours of operation of EU071.

9.0

CD Minn. R. 7007.0800, subp. 6 Reporting: Annually by January 30th the report of the previous 12 monthly12-month rolling sum calculations on the natural gas emergency generator.

10.0




4 May, 2011 11:41Page 33 of 42

Subject Item: CE 018 Wet Scrubber - High Efficiency

Associated Items: EU 039 Fermenter 1

EU 040 Fermenter 2

EU 041 Fermenter 3

EU 042 Fermenter 4

EU 043 Fermenter 5

EU 044 Fermenter 6

EU 045 Fermenter 7

EU 046 Fermenter 8

EU 047 Beer Well



GP 002 Wet Scrubber

NC/CA




Volatile Organic Compounds: less than or equal to 12.5 lbs/hour2.0


Pressure Drop: greater than or equal to 2.0 inches of water column and less than orequal to 10 inches of water column or as determined by the most recentperformance testing that demonstrated compliance with the permitted emissionlimit.

3.0


Water flow rate: greater than or equal to 35.0 gallons/minute absolute minimum,unless a new limit is set pursuant to Minn. R. 7017.2025, subp. 3 based on thevalues recorded during the most recent MPCA-approved performance test wherecompliance was demonstrated. The new limit shall be implemented upon receipt ofthe Notice of Compliance letter granting preliminary approval. The limit is final uponissuance of a permit amendment incorporating the change. If the water flow rate isbelow the minimum limit, the VOC emitted during that time shall be considereduncontrolled until the flow rate is above the minimum limit. This shall be reported asa deviation.

4.0

CD Minn. R. ch. 4410 Total Fermentation Tank Volume: Limited to 6,517,912 gallons.5.0



6.0



Vent all emissions from all fermentation units EU039 through EU047, EU069 andEU070 to the Wet Scrubber (CE018) at all times that the associated units are inoperation.

8.0


Record the pressure drop and water flow rate of the scrubber once each day ofoperation.

9.0




4 May, 2011 11:41Page 34 of 42


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

10.0

CD Minn. R. 7007.0800, subp. 4 Monitoring Equipment: The Permittee shall install and maintain the necessarymonitoring equipment for measuring and recording pressure drop as required bythis permit. The monitoring equipment must be installed, in use, and properlymaintained when the monitored scrubber is in operation.

11.0

CD Minn. R. 7007.0800, subp. 14 The Permittee shall operate and maintain the scrubber in accordance with theOperation and Maintenance (O & M) Plan. The Permittee shall keep copies of theO & M Plan available onsite for use by staff and MPCA staff.

12.0


Calibrate the gauges annually, or as often as required by manufacturingspecifications and maintain a written record of the calibration and any actionresulting from the calibration.

13.0

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

Corrective Actions: The Permittee shall take corrective action as soon as possible ifany of the following occur:- the recorded pressure drop or water flow rate is outside the required operatingrange; or- the scrubber or any of its components are found during the inspections to needrepair.Corrective actions shall return the pressure drop to within the permitted rangeand/or include completion of necessary repairs identified during the inspection, asapplicable. Corrective actions include, but are not limited to, those outlined in the O& M Plan for the scrubber. The Permittee shall keep a record of the type and dateof any corrective action taken for each scrubber.

14.0

CD hdr PERFORMANCE TESTING15.0



16.0




17.0




4 May, 2011 11:41Page 35 of 42

Subject Item: CE 023 Flaring



EU 066 Loadout Flare

NC/CA



Opacity: The Flare shall be operated so that there are no visible emissions fromthe stack (SV022).

1.0

CD Minn. R. 7007.0800, subp. 2 Emissions from the ethanol loadout units (EU060 and EU061) will be controlled bythe flare (CE023) that shall meet 98 percent control efficiency.

2.0

CD Minn. R. 7007.0800, subp. 2 Fuel Usage: The flare shall be used only with the net heating value of the gasbeing combusted being 300 Btu/scf or greater if the flare is steam-assisted orair-assisted; or with the net heating value of the gas being combusted being 200Btu/scf or greater if the flare is non-assisted.

3.0

CD Minn. R. 7007.0800, subp. 2 The flare shall be operated at all times when emission units may be vented to them.Vent emissions from all units controlled by the flare EU066, through the flare at alltimes that the associated units are in operation.

4.0

CD Minn. R. 7007.0800, subp. 2 The presence of a flare pilot flame shall be monitored using a thermocouple or anyother equivalent device to detect the presence of a flame.

5.0


Visible Emissions: The Permittee shall check the flare stack (SV 022) for anyvisible emissions once each day of operation during daylight hours. The Permitteeshall keep a written record of each daily observation.

6.0




4 May, 2011 11:41Page 36 of 42

Subject Item: FS 001 Truck Traffic

NC/CA


LIMIT Title I Condition: 40 CFR Section52.21(k); Minn. R. 7007.3000

Truck Traffic: less than or equal to 401 trucks/day when the cooling towers andhammermills are not operating or 345 trucks per day when the cooling towers andhammermills are operating during the months of April through November.

1.0

LIMIT Title I Condition: 40 CFR Section52.21(k); Minn. R. 7007.3000

Truck Traffic: less than or equal to 371 trucks/day when the cooling towers andhammermills are not operating or 315 trucks per day when the cooling towers andhammermills are operating during the months of December through March.

2.0


Recordkeeping: The Permittee shall record the number of grain delivery trucksentering the facility each calendar day and keep these records on-site.

3.0


Truck Traffic: Annual DDGS loadout will be limited to 50 percent truck loadout or180,000 tons of DDGS loadout by truck per year. Wetcake (DGS) may be shippedout by truck. For wetcake, the equivelent dry weight shall be used to demonstratecompliance with the 180,000 ton limit.

4.0


Recordkeeping: The Permittee shall record the number of DDGS loadout trucksentering the facility each calendar day and keep these records on-site.

5.0


Truck Traffic: Annual denatured/undenatured ethanol loadout will be limited to61,950,000 gallons of denatured/undenatured ethanol loadout by truck per year.

6.0


Recordkeeping: The Permittee shall record the number of ethanol loadout trucksentering the facility each calendar day and keep these records on-site.

7.0


Truck Traffic: Annual denaturant delivery will be limited to 50 percent truck loadoutor 2,950,000 gallons of denaturant delivery by truck per year.

8.0


Recordkeeping: The Permittee shall record the number of denaturant deliverytrucks entering the facility each calendar day and keep these records on-site.

9.0


Recordkeeping: The Permittee shall record the number and type of receiving andhauling trucks entering the facility each calendar day and keep these recordson-site.

10.0

CD Minn. R. 7011.0150 Fugitive Emissions: Do not cause or permit the transporting of any material in amanner which may allow avoidable amounts of particulate matter to becomeairborne. Do not cause or permit a road or a driveway to be constructed, used,repaired or demolished without applying all such reasonable measures as may berequired to prevent particulate matter from becoming airborne.

11.0

CD Minn. R. 7011.0150 Abide by the Fugitive Dust Control Plan in Appendix II.12.0

S/A 40 CFR Section 52.21 and Minn.R. 7009.0020

Initial Performance Test: due before 07/31/2009 for paved road silt load.13.0

S/A 40 CFR Section 52.21 and Minn.R. 7009.0020

Performance Test: due before end of each calendar half-year starting 02/27/2009for paved road silt load. The Initial Performance Test is due by July 31, 2009. Allsubsequent tests shall be performed in January and July of each calendar year.The tests shall be conducted in accordance with EPA guidance in Appendix C.1and Appendix C.2 of AP42. The Permittee shall keep records of silt loading testing.If tested silt loading values together with other paved roads terms (e.g. vehicleweight, vehicle speed) yields PM10 emission factors (pounds pervehicle-mile-traveled, lb/vmt) that are found to be greater than those assumed inthe most recent approved modeling, then the road cleaning (sweeping andvacuuming) frequency will be revised so that lb/vmt values are low enough tocomport with the most recent approved modeling (December 17, 2008).

14.0




4 May, 2011 11:41Page 37 of 42

Subject Item: FS 002 DDGS Storage Building

NC/CA


LIMIT Minn. R. 7011.1005, subp. 3(A) Opacity: less than or equal to 5.0 percent opacity for fugitive emissions from DDGShandling activities or DDGS railcar loading.

1.0

LIMIT Minn. R. 7011.1005, subp. 3(B) Opacity: less than or equal to 10.0 percent opacity for fugitive emissions fromDDGS truck loading.

2.0

CD Minn. R. 7011.1005, subp. 1(A) Clean up commodities spilled on the driveway and other facility property asrequired to minimize fugitive emissions to a level consistent with RACT(Reasonably Available Control Technology).

3.0




4 May, 2011 11:41Page 38 of 42

Subject Item: FS 003 Uncaptured Emissions from DDGS Handling

NC/CA


LIMIT Minn. R. 7011.1005, subp. 3(A) Opacity: less than or equal to 5.0 percent opacity for fugitive emissions from DDGShandling activities or DDGS railcar loading.

1.0

LIMIT Minn. R. 7011.1005, subp. 3(B) Opacity: less than or equal to 10.0 percent opacity for fugitive emissions fromDDGS truck loading.

2.0

CD Minn. R. 7011.1005, subp. 1(A) Clean up commodities spilled on the driveway and other facility property asrequired to minimize fugitive emissions to a level consistent with RACT(Reasonably Available Control Technology).

3.0




4 May, 2011 11:41Page 39 of 42

Subject Item: FS 004 Equipment Leaks

NC/CA


CD hdr STANDARDS: PUMPS1.0

CD 40 CFR Section 60.482-2Minn. R. 7011.2900

Pumps in light liquid service:

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

Each pump in light liquid service shall be checked by visual inspection eachcalendar week for indications of liquids dripping from the seal.

2.0

CD 40 CFR Section 60.482-2(b) and(c)Minn. R. 7011.2900

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

If there are indications of liquids dripping from the pump seal, a leak is detected.

When a leak is detected, it shall be repaired as soon as practicable, but not laterthan 15 calendar days after it is detected, except as provided in 40 CFR Section60.482-9 (Delay of Repair).

A first attempt at repair shall be made no later than 5 calendar days after each leakis detected.

3.0

CD hdr STANDARDS: COMPRESSORS4.0

CD 40 CFR Section 60.482-3(a)Minn. R. 7011.2900

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

5.0

CD 40 CFR Section 60.482-3(b)Minn. R. 7011.2900

Each compressor seal system shall be:

- Operated with the barrier fluid at a pressure that is greater than the compressorstuffing box pressure; or

- Equipped with a barrier fluid system that is connected by a closed vent system toa control device that complies with the requirements of 40 CFR Section 60.482-10;or

- Equipped with a system that purges the barrier fluid into a process stream withzero VOC emissions to the atmosphere.

6.0

CD 40 CFR Section 60.482-3(c) and(d)Minn. R. 7011.2900

The barrier fluid system shall be in heavy liquid service or shall not be in VOCservice.

Each barrier fluid system shall be equipped with a sensor that will detect failure ofthe seal system, barrier fluid system, or both.

7.0

CD 40 CFR Section 60.482-3(e)Minn. R. 7011.2900

Each sensor shall be checked daily or shall be equipped with an audible alarm.

The Permittee shall determine, based on design considerations and operatingexperience, a criterion that indicates failure of the seal system, the barrier fluidsystem, or both.

8.0

CD 40 CFR Section 60.482-3(f)Minn. R. 7011.2900

If the sensor indicates failure of the seal system, the barrier system, or both basedon the criterion determined under paragraph 40 CFR Section 60.482-3(e)(2), a leakis detected.

9.0

CD 40 CFR Section 60.482-3(g)Minn. R. 7011.2900

When a leak is detected, it shall be repaired as soon as practicable, but not laterthan 15 calendar days after it is detected except as provided in 40 CFR Section60.482-9 (Delay of Repair).

A first attempt at repair shall be made no later than 5 calendar days after it isdetected, except as provided in 40 CFR Section 60.482-9.

10.0

CD hdr STANDARDS: PRESSURE RELIEF DEVICES IN GAS/VAPOR SERVICE11.0


Except during pressure releases, each pressure relief device in gas/vapor serviceshall be operated with no detectable emissions, as indicated by an instrumentreading of less than 500 ppm above background as determined by the methodsspecified in 40 CFR Section 60.485(c).

12.0




4 May, 2011 11:41Page 40 of 42

CD 40 CFR Section 60.482-4(b)Minn. R. 7011.2900

After each pressure release, the pressure relief device shall be returned to acondition of no detectable emissions, as indicated by an instrument reading of lessthan 500 ppm above background, as soon as practicable, but no later than 5calendar days after the pressure release, except as provided in 40 CFR Section60.482-9 (Delay of Repair).

13.0

CD hdr STANDARDS: VALVES14.0


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

The cap, blind flange, plug, or second valve shall seal the open end at all timesexcept during operations requiring process fluid flow through the open-ended valveor line.

15.0

CD 40 CFR Section 60.482-6(b) and(c)Minn. R. 7011.2900

Each open-ended valve or line equipped with a second valve shall be operated in amanner such that the valve on the process fluid end is closed before the secondvalve is closed.

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

16.0




4 May, 2011 11:41Page 41 of 42

Subject Item: FS 005 Cooling Towers

NC/CA



The cooling tower fans are not to be operating while corn is being shipped fromCargill AgHorizons.

1.0


Daily Recordkeeping. At any time that grain is shipped from the Cargill AgHorizonsfacility, the Permittee shall record and maintain a record of the dates and timeswhich the cooling tower fans are not operating.

2.0




4 May, 2011 11:41Page 42 of 42

Subject Item: FS 006 Wet Cake Storage

NC/CA


CD Minn. R. 7007.0800, subp. 2 Wetcake storage limitation: When wetcake by-product is produced, and ambienttemperature is greater than 55 degrees Fahrenheit, it will be stored for no longerthan 72 hours on-site, except in unforeseen cases of product shipmentcancellations, holidays, or weekends in which the recipient of the wetcake is unableto pick up the material. Under these unforeseen conditions, the wetcake will not bestored on site more than 5 calendar days. In all cases, the wetcake will be movedoff-site as soon as possible.

Time stored onsite is determined for each storage period by dividing the totalamount of wetcake put into storage during the storage period (either 3 or 5calendar days depending on the circumstances) by the average daily amountshipped offsite during the same period.

1.0

CD Minn. R. 7007.0800, subp. 2 Cont.

The Permittee shall keep a record of the amount of wetcake sent to storage eachday and the amount shipped offsite each day. The Permittee will also keep recordsof any circumstances that require the wetcake to be stored more than 72 hours.

2.0

Attachment 2: Emissions Calculations

Buffalo Lake Energy, LLCPotential CO2 Emission Summary

Before ModificationCO2 CH4 N2O CO2e

Emissions (tons) Emissions (tons) Emissions (tons) Emissions (tons)Fire Pump EU065 2.98E+01 8.81E-04 2.94E-04 2.99E+01Emergency Generator EU071 6.40E+00 7.15E-04 1.21E-05 6.42E+00DDGS Dryer A EU056 4.08E+04 4.56E+00 7.71E-02 4.09E+04Thermal Oxidizer / Heat Recovery Steam EU057 1.07E+05 1.20E+01 2.02E-01 1.07E+05DDGS Dryer B EU058 4.08E+04 4.56E+00 7.71E-02 4.09E+04Thermal Oxidizer / Heat Recovery Steam EU059 1.07E+05 1.20E+01 2.02E-01 1.07E+05Loadout Flare EU066 3.26E+03 3.64E-01 6.17E-03 3.27E+03Fermentation SV018 3.71E+05 3.71E+05Total Facility 6.70E+05 3.34E+01 5.65E-01 6.71E+05

After ModificationCO2 CH4 N2O CO2e

Emissions (tons) Emissions (tons) Emissions (tons) Emissions (tons)Fire Pump EU065 2.98E+01 8.81E-04 2.94E-04 2.99E+01Emergency Generator EU071 6.40E+00 7.15E-04 1.21E-05 6.42E+00DDGS Dryer A EU056 4.08E+04 4.56E+00 7.71E-02 4.09E+04Thermal Oxidizer / Heat Recovery Steam EU057 1.07E+05 1.20E+01 2.02E-01 1.07E+05DDGS Dryer B EU058 4.08E+04 4.56E+00 7.71E-02 4.09E+04Thermal Oxidizer / Heat Recovery Steam EU059 1.07E+05 1.20E+01 2.02E-01 1.07E+05Loadout Flare EU066 3.26E+03 3.64E-01 6.17E-03 3.27E+03Fermentation SV018 3.87E+05 3.87E+05Total Facility 6.85E+05 3.34E+01 5.65E-01 6.86E+05

Change in EmissionsCO2 CH4 N2O CO2e

Emissions (tons) Emissions (tons) Emissions (tons) Emissions (tons)Fire Pump EU065 0.00E+00 0.00E+00 0.00E+00 0.00E+00Emergency Generator EU071 0.00E+00 0.00E+00 0.00E+00 0.00E+00DDGS Dryer A EU056 0.00E+00 0.00E+00 0.00E+00 0.00E+00Thermal Oxidizer / Heat Recovery Steam EU057 0.00E+00 0.00E+00 0.00E+00 0.00E+00DDGS Dryer B EU058 0.00E+00 0.00E+00 0.00E+00 0.00E+00Thermal Oxidizer / Heat Recovery Steam EU059 0.00E+00 0.00E+00 0.00E+00 0.00E+00Loadout Flare EU066 0.00E+00 0.00E+00 0.00E+00 0.00E+00Fermentation SV018 1.54E+04 1.54E+04Total Facility 1.54E+04 0.00E+00 0.00E+00 1.54E+04

Source

Source

Source

H:\Worksheet in Delta 2 1 of 1

Emission Year:Facility Name:Facility #:

CO2 CH4 N2OFuel Type Fuel Subtype Emission Unit Throughput Units Emissions (tons) Emissions (tons) Emissions (tons)Coal Industrial MMBtu 205.15 lbs/MMBtu 0.0245 lbs/MMBtu 0.0035 lbs/MMBtu 0.0000 0.0000 0.0000Distillate Fuel (Diesel) Industrial Fire Pump 2,669.06 gallons 159.69 lbs/MMBtu 0.00066 lbs/gallon 0.00022 lbs/gallon 29.8356 0.0009 0.0003LPG Industrial gallons 136 lbs/MMBtu 0.00044 lbs/gallon 0.00022 lbs/gallon 0.0000 0.0000 0.0000Natural Gas Industrial Emergency Generator 110.00 MMBtu 116.38 lbs/MMBtu 0.0130 lbs/MMBtu 0.00022 lbs/MMBtu 6.4009 0.0007 0.0000Natural Gas Industrial 56 700,800.00 MMBtu 116.38 lbs/MMBtu 0.0130 lbs/MMBtu 0.00022 lbs/MMBtu 40,779.5520 4.5552 0.0771Natural Gas Industrial 57 1,839,600.00 MMBtu 116.38 lbs/MMBtu 0.0130 lbs/MMBtu 0.00022 lbs/MMBtu 107,046.3240 11.9574 0.2024Natural Gas Industrial 58 700,800.00 MMBtu 116.38 lbs/MMBtu 0.0130 lbs/MMBtu 0.00022 lbs/MMBtu 40,779.5520 4.5552 0.0771Natural Gas Industrial 59 1,839,600.00 MMBtu 116.38 lbs/MMBtu 0.0130 lbs/MMBtu 0.00022 lbs/MMBtu 107,046.3240 11.9574 0.2024Natural Gas Industrial 66 56,064.00 MMBtu 116.38 lbs/MMBtu 0.0130 lbs/MMBtu 0.00022 lbs/MMBtu 3,262.3642 0.3644 0.0062

298,950.3527 33.3912 0.5654CO2e 298,950.3527 701.2154 175.2618

Emission Factor Emission Factor Emission Factor

EIQ #: (Title V Facilities Only) 1 MMcf Natural Gas = 1050 MMBtu (if other value used, please enter it here in red box).CO2 CH4 N2O

Potential Emissions Assumptions:Buffalo Lake Energy, LLC 1 therm Natural Gas = 0.09997612 MMBtu

1 gallon diesel = 0.140 MMBtu, gallon LPG = 0.094 MMBtu

Note: Unless otherwise noted, all emission factors were obtained from the California Climate Action Registry General Reporting Protocol Version 2.2 March 2007 Tables C.5 and C.6

Note: The Emergency Generator emissions are calculated using 500 hours per year operation, the Fire Pump emissions are calculated using 100 hours per year operation, and the remaining fuel burning equipment is assumed to operate 8760 hours per year. Note: The maximum firing capacity (420 MMBtu/hr) for Emission Units 57 and 59 was utilized to calculate the potential CO2e emission rates. The expected firing capacity of 290 MMBtu/hr used in the facility potential emission calculations to limit Nox emissions was not used. Under current design it is unlikely that the potential CO2e emission rate could be achieved as existing permit limits would be exceeded.

H:\Worksheet in Delta 2 1 of 1


bushels of corn processed

Given:128,800,000 gallons of denatured EtOH produced

0.954 percentage of the denatured EtOH that is 200 proof EtOH46.06844 [g/mol] mole weight of EtOH

0.789 [g/cm3] density of liquid EtOH44.0095 [g/mol] mole weight of CO2

and:C6H12O6 + yeast = 2 CH3CH2OH + 2 CO2

sugar + yeast = ethanol + carbon dioxide

Therefore:128,800,000 gal denatured EtOH 0.954 gal 200 proof EtOH 0.789 g EtOH 3,785.41 cm3

1 gal denatured EtOH 1 cm3 1 gal

= 3.67064E+11 g EtOH 1 mol EtOH46.06844 g EtOH

= 7,967,797,812 mol EtOH 2 mol CO2

2 mol EtOH

= 7,967,797,812 mol CO2 44.0095 g CO2 1 lb1 mol CO2 453.59 g

= 773,070,318.17 lbs CO2 / annual production of denatured EtOH (gallons)= 386,535.16 tons CO2

Potential Emissions After ModificationBuffalo Lake Energy, LLC

EIQ #: (Title V Facilities Only)

H:\Worksheet in Delta 2 1 of 1H:\Worksheet in Delta 2 1 of 1


bushels of corn processed

Given:123,900,000 gallons of denatured EtOH produced

0.952 percentage of the denatured EtOH that is 200 proof EtOH46.06844 [g/mol] mole weight of EtOH

0.789 [g/cm3] density of liquid EtOH44.0095 [g/mol] mole weight of CO2

and:C6H12O6 + yeast = 2 CH3CH2OH + 2 CO2

sugar + yeast = ethanol + carbon dioxide

Therefore:123,900,000 gal denatured EtOH 0.952 gal 200 proof EtOH 0.789 g EtOH 3,785.41 cm3

1 gal denatured EtOH 1 cm3 1 gal

= 3.52429E+11 g EtOH 1 mol EtOH46.06844 g EtOH

= 7,650,123,204 mol EtOH 2 mol CO2

2 mol EtOH

= 7,650,123,204 mol CO2 44.0095 g CO2 1 lb1 mol CO2 453.59 g

= 742,248,149.26 lbs CO2 / annual production of denatured EtOH (gallons)= 371,124.07 tons CO2

Potential Emissions Prior to ModificationBuffalo Lake Energy, LLC

EIQ #: (Title V Facilities Only)

H:\Worksheet in Delta 2 1 of 1H:\Worksheet in Delta 2 1 of 1

L = 12.46 · S · P · M ÷ T

where: L = Loading Loss, lb VOC/1000 gal of liquid loadedS = Saturation Factor (AP-42 Table 5.2-1)P = True Vapor Pressure of Liquid Loaded, psiaM = Molecular Weight of Vapors, lb/lb-moleT = Temperature of Bulk Liquid Loaded, R

The values of T and M are taken from the TANKS software which calculates the annual average bulk product temperature based on the annual averagetemperatures for the city of Sioux Falls, SD. Pressure (P) is based on linear interpolation of vapor pressures identified in Table 7.1-2 of AP-42 for RVP13.The PTE is based on loading the maximum volume of ethanol that can be distilled by the facility plus denaturant at a concentration of 5% by volume.

The Loadout Flare is assumed to achieve 98% destruction of captured VOC emissions from ethanol loadout process.

TOTAL annual Throughput 128,800 (1000 gal)Control Efficiency 98%Truck pump rate 550 gpm

Rail pump rate 1,050 gpm

VaporAnnual Saturation Molecular Product True Vapor Loading

Throughput Factor Weight Temperature Pressure LossProduct (1000 gal) S MW T (deg R) P (psia) (lb/1000 gal) (lb/hr) (ton/yr) (Lb/hr) (ton/yr)

Truck Loadout1

Gasoline (RVP13) 61,950 1 62 507.92 6.2 9.4299 66.69 292.09 6.22 5.84Controlled Truck Loadout PTE 6.22 5.84

Rail Loadout2

Denatured Ethanol 61,950 0.6 49.98 507.92 0.6 0.4423 3.13 13.70 0.56 0.27Controlled Rail Loadout PTE 0.56 0.27

Additional Rail Loadout2

Denatured/Undenatured Ethanol 4,900 0.6 49.98 507.92 0.6 0.4423 27.86 1.08 0.56 0.02Controlled Rail Loadout PTE 0.56 0.02

Total VOC Emissions36.14

3 Total assumes 50% truck loadout and 50% rail loadout for 123.9 MM gallons of denatured ethanol and 100% rail loadout of 4.9 MM gallons of denatured ethanol as worst case.

From Fifth Edition AP-42, Section 5.2:

Buffalo Lake Energy, LLCEthanol Loading Rack

2 Rail cars are a dedicated fleet carrying solely denatured ethanol product.

Loss (98% Control)Uncontrolled Controlled Loss

1 Trucks are assumed to be a non-dedicated fleet carrying gasoline on their last load, to be conservative.

J:\Projects and Proposal\Biofuel Energy\6016 0902 BLE Yeast Tank\Application Forms\Completed Forms\BLE Emission Calculations 11-4-10.xlsx

Production Data:

Undenatured EtOH 122,900,000 gal/yr

Denaturant 5,900,000 gal/yr

Denatured EtOH 128,800,000 gal/yr

Tank ID Capacity Type Throughput

TK001 (192,000 gal)Ethanol Day Tank

(50% of 122,900,000) 61,450,000 gal/yr

TK002 (192,000 gal)Ethanol Day Tank

(50% of 122,900,000) 61,450,000 gal/yr

TK003 (116,900 gal)Denaturant (5% of

122,900,000) 5,900,000 gal/yrTK004 (1,562,000 gal) Denatured EtOH) 64,400,000 gal/yrTK005 (1,562,000 gal) Denatured EtOH 64,400,000 gal/yr

TOTAL Ethanol Emissions (lb/yr)

TOTAL gasoline emissions (lb/yr)

Cyclohexane (lb/year)

Benzene (lb/year)

n-Hexane (lb/year)

Pentane (lb/year)

Toluene (lb/year)

Xylene (lb/year)

Ethyl Benzene (lb/year)

1,2,4-Trimethyl benzene (lb/year)

Carbon Disulfide (lb/year)

Cumene (lb/year)

Loadout 562.6 28.7 8.9E-01 1.5E+00 4.4E+00 7.2E+00 8.9E-01 1.5E+00 3.0E-01 3.0E-02 1.4E-03 2.9E-03TK001 613.5 0.0 0.0E+00 0.0E+00 0.0E+00 0.0E+00 0.0E+00 0.0E+00 0.0E+00 0.0E+00 0.0E+00 0.0E+00TK002 613.5 0.0 0.0E+00 0.0E+00 0.0E+00 0.0E+00 0.0E+00 0.0E+00 0.0E+00 0.0E+00 0.0E+00 0.0E+00TK003 0.0 1429.0 1.3E+01 2.1E+01 9.9E+01 5.8E+02 4.2E+00 3.2E+00 6.9E-01 4.0E-02 7.1E-02 1.4E-01TK004 325.3 62.7 1.2E+00 2.0E+00 8.8E+00 4.7E+01 5.4E-01 6.1E-01 1.3E-01 1.0E-02 3.1E-03 6.3E-03TK005 325.3 62.7 1.2E+00 2.0E+00 8.8E+00 4.7E+01 5.4E-01 6.1E-01 1.3E-01 1.0E-02 3.1E-03 6.3E-03TOTALS (lb/year) 2440.2 1583.1 1.6E+01 2.6E+01 1.2E+02 6.8E+02 6.1E+00 5.9E+00 1.2E+00 9.0E-02 7.9E-02 1.6E-01TOTALS (ton/year) 1.2 0.8 8.1E-03 1.3E-02 6.1E-02 3.4E-01 3.1E-03 2.9E-03 6.2E-04 4.5E-05 4.0E-05 7.9E-05TOTALS (lb/hr) 0.3 0.2 1.8E-03 3.0E-03 1.4E-02 7.8E-02 7.0E-04 6.7E-04 1.4E-04 1.0E-05 9.0E-06 1.8E-05

Buffalo Lake Energy, LLCStorage Tanks


SO2 is negligible based on minimal H2S levels

PM/PM10 is negligible based on smokeless design

Rate 6.4 MMBtu/hrHeating Value 850 Btu/scfOperating Hours 4000 Hours/yr

Emission NOx 0.077 lb/ 1000 gal Manufactuer estimates*Factors CO 0.129 lb/ 1000 gal Manufactuer estimates**See attached MRW Technologies Specification Sheet

Emissions NOx 1.13 lb/hr 2.26 ton/yrCO 1.90 lb/hr 3.79 ton/yr

Limited emissions

Ethanol Loadout FlareBuffalo Lake Energy, LLC


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Doc Type: Permit Application

Instructions on Page 2

1a) AQ Facility ID No.: 9100060 1b) AQ File No.:

2) Facility Name: Buffalo Lake Energy, LLC

3a) 3b) 3c) CAS#: CAS#: CAS#:

Emission Emission 3d) Pollutant Name: VOC Pollutant Name: NOX Pollutant Name: CO

Source Source 3e) 3f)

Type ID No. Potential Actual Potential Actual Potential Actual

Lbs per Hr

Unrestricted tpy

Limited tpy

Tons per yr

Lbs per Hr

Unrestricted tpy

Limited tpy

Tons per yr

Lbs per Hr

Unrestricted tpy

Limited tpy

Tons per yr

SV 022 6.22 306.87 6.14 1.13 2.26 2.26 1.90 3.79 3.79

TK 001 0.07 0.31 0.31

TK 002 0.07 0.31 0.31

TK 004 0.04 0.19 0.19

TK 005 0.04 0.19 0.19

4) Potential Actual Potential Actual Potential Actual

Total Unrestricted Limited Tons/year Unrestricted Limited Tons/year Unrestricted Limited Tons/year

Facility 2.44E+03 87.25 94.49 94.49 91.87 91.87

5) Compact disc containing editable calculation spreadsheet(s) included in the application package Editable calculation spreadsheet(s) will be emailed to the MPCA upon request

Attachment 3: Points Calculator

3316

1) AQ Facility ID No.: 09100060 Total Points 202) Facility Name: Buffalo Lake Energy LLC3) Small business? y/n? N 4) DQ Numbers (including all rolled) : 3316, 2852 5) Date of each Application Received: 11/24/10, 9/18/096)Final Permit No. 09100060-0047) Permit Staff Tarik Hanafy

Application Type DQ No. Qty. Points Total Points DetailsAdministrative Amendment 1 0Registration Permit 2 0State General Permit 3 0Part 70 General Permit 4 0Minor Amendment 4 0Capped Permit 4 0Applicability Request 10 0Moderate Amendment 15 0Major Amendment 3316 25 0 Production expansionIndividual State Permit - First Time 50 0Individual Part 70 Permit - First Time 75 0

Additional PointsModeling Review 15 0

BACT Review 15 0LAER Review 15 0CAIR/Part 75 CEM analysis 10 0NSPS Review 10 0NESHAP Review 10 0Case-by-case MACT Review 20 0Netting 10 0Limits to remain below threshold 3316 2 10 20 Avoid PSD and Pt. 70

Page 1

Plantwide Applicability Limit (PAL) 20 0AERA review 15 0Variance request under 7000.7000 35 0Confidentiality request under 7000.1300 2 0EAW reviewPart 4410.4300, subparts 18, item A; and 29 15 0Part 4410.4300, subparts 8, items A & B; 10, items A to C; 16, items A & D; 17, items A to C & E to G; and 18, items B & C

35 0

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

70 0

NoNOTES: Production limit to avoid PSD and Pt. 70; Application fee paid; DQ 2852 is a reopening

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permit applications table · air emission permit no. 09100060-004 this technical support document...

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