state implementation plan (sip) revision documents

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Background Document for State Implementation Plan Revision

Bulk Silos, Ramsey County, MN This document describes the State Implementation Plan (SIP) revision for Bulk Silos (formerly Lafarge North America, Childs Road), located in the Red Rock Road Maintenance Area for the 1987 coarse particulate matter (PM10) National Ambient Air Quality Standards (NAAQS). The Red Rock Road area is in St. Paul, Ramsey County, Minnesota. Bulk Silos is a portland cement distribution terminal. The facility currently operates six silos with pollution control equipment; the silos are used for the storage and distribution of cementitious products. The material is currently received by rail, stored in silos, and distributed by truck. A process flow diagram of the existing and new equipment that comprise the facility’s operations is included at the end of this document. Bulk Silos is subject to a State Individual Permit containing Title I PM10 SIP conditions. These Title I SIP conditions are intended to ensure that the Red Rock Road area continues to maintain the PM10 NAAQS. The requirements and emission limits of the most recently SIP-approved State Individual Permit for this facility, No. 12300391-002 (final approval effective as of September 11, 2007, 72 FR 51713) will continue to apply until this SIP revision is approved by the EPA. The primary purpose of this permit action and related SIP revision is to address several physical and operational changes at the Bulk Silos facility, most of which are affected by Title I SIP conditions. This permit action, and subsequent SIP revision, will result in an overall decrease in allowable PM10 emissions at the Bulk Silos facility. This SIP revision is being proposed in conjunction with a major amendment to a State Individual Permit containing federally-enforceable Title I SIP conditions (Air Emission Permit No. 12300391-102). The permit and its technical support document (TSD) provide information on the proposed changes to the operations at Bulk Silos (Attachments 1 and 2, respectively). This background document is intended to address only the changes to the permit that are relevant to the facility’s Title I SIP conditions for PM10. All conditions necessary for maintaining the NAAQS are included in the SIP; in this permit, those conditions are cited as “40 CFR pt. 51, Title I Condition: 40 CFR 50.6(PM10 SIP)”, making it clear that the term is part of the SIP. In SIP submittals, Minnesota requests that only those requirements with the term “40 CFR pt. 51, Title I Condition: 40 CFR 50.6(PM10 SIP)” be included in the SIP. Consistent with past procedures of revising the SIP when changes were made to the permit, any changes to these “40 CFR pt. 51, Title I Condition: 40 CFR 50.6(PM10 SIP)” conditions will require a major permit amendment and a SIP revision, with all the associated EPA review and public participation requirements. All requirements labeled “40 CFR pt. 51, Title I Condition: 40 CFR 50.6(PM10 SIP)” are permanent and federally enforceable. The permit issuance and SIP revision for Bulk Silos is one of many projects the MPCA is reviewing in the Red Rock Road area. Since the changes Bulk Silos is making to their facility will ultimately reduce PM10 emissions from their operations, the MPCA is moving ahead to authorize construction and seek EPA approval of changes to Title I SIP conditions on a facility-by-facility basis. Future modeling for other Red Rock Road-area projects may indicate the need for additional SIP revisions at Bulk Silos or other facilities. The MPCA will continue to coordinate with EPA as needed.

Background document for Bulk Silos SIP revision, permit 12300391-102

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Reasons for changes to the applicable Title I SIP conditions in the Bulk Silos State Individual Permit Bulk Silos has submitted a major permit amendment for several projects, including the replacement three existing fabric filters and the construction of (1) three new silos, (2) a new bucket elevator, and (3) twelve new fabric filters (three replacement filters and nine new ones). The facility will also be adding barge unloading to their operations, which will expand the facility’s ability to receive cementitious products from barge traffic in addition to rail. The material will be conveyed pneumatically from the barges to the storage silos. The facility has several existing Title I SIP PM10 SIP conditions in their permit. Specifically, Bulk Silos has requested the following changes to its facility, each of which has implications for the site-specific SIP related to Permit No. 12300391-102:

• New throughput limits for overall facility operations (silo unloading) (COMG 2), truck loading operations (EQUI 4), and bucket elevator operations (EQUI 5);

• Lower allowable PM10 emissions limits for truck loading operations (EQUI 4); Silo 3 (EQUI 11); and the pneumatic conveyance equipment used to move material to silos (existing EQUI 1, EQUI 2, EQUI 6, EQUI 7, EQUI 11, and EQUI 12);

• Replacement of three existing fabric filters with three new fabric filters with higher flow rates (TREA 1 with TREA 5, TREA 2 with TREA 6, and TREA 3 with TREA 9); and

• New construction with Title I SIP conditions attached. Cumulatively, the changes associated with this major amendment to the Bulk Silos permit will result in a reduction of allowable PM10 emissions at the Bulk Silos facility. As such, the MPCA is requesting that EPA approve the following changes to the site-specific SIP for Bulk Silos (included in the Minnesota SIP at 40 CFR 52 Subp. Y). New throughput limits Permit No. 12300391-102 and this SIP revision includes the authorization to increase the facility’s throughput limits, and to add specific limits to both truck unloading and bucket elevator operations. These limits are described below, and in the permit and TSD (Attachments 1 and 2). Each of the throughput limits will help to maintain compliance with the PM10 NAAQS in the Red Rock Road area. Table 1 includes a comparison of existing throughput limits in the SIP-effective Permit No. 12300391-002 to new limits in the updated Permit No. 12300391-102.


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Table 1. Changes in operational throughput limits from the effective permit to the new permit. MPCA is requesting these limits be included in the site-specific SIP as a part of this revision.

Limit in SIP-Effective Permit

12300391-002

Limit in Draft Permit 12300391-102 Pre-Project (prior to EPA

approval of the SIP) Post-Project (after EPA

approval of the SIP)

Unloading Operations

Throughput <= 1,100 ton/day on 24-hour rolling average

(at TFAC 1)

Throughput <= 100,000 ton/year on 12-month rolling

average (at TFAC 1)

Throughput <= 1,100 ton/day on daily average

(at COMG 2)


sum (at COMG 2)


(at COMG 2)


sum (at COMG 2)

Truck Loading Operations The limit does not exist The limit does not exist


(at EQUI 4)


sum (at EQUI 4)

Bucket Elevator Operations The unit does not exist The unit does not exist


(at EQUI 5)


sum (at EQUI 5)

Taken in tandem with other changes at the facility and precise, facility-specific emissions factors (as described in this document), increased throughput limits will not result in increased emissions of PM10 at the facility. We are requesting that these requirements be added to the site-specific SIP for this facility. Operational throughput (silo unloading) The facility requested a higher operational throughput limit, for unloading silos, as part of their major amendment application. Upon approval of the SIP and startup of the proposed project, the facility’s allowable average daily throughput would increase from 1100 tons per day to 2500 tons per day; allowable average throughput, calculated as a 12-month rolling sum, would increase from 100000 tons per year to 740000 tons per year. The current and new limits are listed in the permit at COMG 2. The significant increase in the allowable throughput was approved as part of Permit No. 12300391-102 for the following reasons.

• Facility-specific emissions factors. As part of the modeling exercise required for the MPCA to review and reissue Permit No. 12300391-102 to Bulk Silos, the facility provided equipment- and process-specific emissions factors, which had not been identified and used in prior modeling exercises. These new emissions factors, which were developed based on a performance test conducted at the facility, were significantly lower than those used in prior modeling demonstrations, and resulted in our ability to significantly increase the permitted operational throughput of the facility while continuing to maintain the PM10 (and other) NAAQS. The facility-specific


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emissions factors were also used to calculate the allowable throughput limits for both the truck loading and bucket elevator operations.

• Stricter control equipment performance testing requirements. In order to ensure compliance with the conditions in their operating permit and continued protection of the NAAQS, Permit No. 12300391-102 requires the facility to conduct regular performance testing of control equipment. Performance testing requirements are listed at equipment throughout the permit, and are enforceable by both Minnesota and federal regulations. Continued performance testing demonstrating compliance with their permit and SIP conditions, as well as the emissions rates used in the SIL analysis, will serve to confirm whether or not the facility-specific emissions factors provided to the MPCA are accurate.

The requested higher throughput limits would not apply until EPA approves this SIP revision. For this reason, the permit includes the language specifying “This requirement expires upon startup of the Project” for current operational throughput (COMG 2, 5.3.1 and 5.3.2), and that the increased limits would go into effect “Upon startup of the Project” (COMG 2, 5.3.3 and 5.3.4). Truck loading operations Permit No. 12300391-102 includes allowable emissions limits for truck loading operations (loading trucks from silos) at the Bulk Silos facility. These truck operation-specific throughput limits are new, and have attached Title I SIP conditions. The throughput limits are distinct from the allowable emissions limits placed on the loading operations at EQUI 4 (discussed in more detail below). Throughput limits have been placed on these operations at an average of 2500 tons per day, and an annual (12-month rolling sum) allowable limit of 740,000 tons per year. The new throughput limits would not apply until EPA approves this SIP revision. For this reason, the permit includes the language specifying the increased limits would go into effect “Upon startup of the Project” (EQUI 4, 5.7.3 and 5.7.4). Bucket elevator process Permit No. 12300391-102 authorizes the construction and operation of a new bucket elevator at the facility. To ensure continued compliance with the NAAQS, Title I SIP-enforced throughput limits have been placed on the bucket loading process at an average of 1100 tons per day and 350,000 tons per year (12-month rolling sum). The requested throughput limits, and operation of the bucket elevator, would not apply until EPA approves this SIP revision. For this reason, the permit includes the language specifying the increased limits would go into effect “Upon startup of the Project” (EQUI 5, 5.8.1 and 5.8.2). Lower allowable PM10 emissions limits Permit No. 12300391-102 includes decreased emissions limits on several pieces of equipment and processes at the Bulk Silos facility, including truck loading operations (EQUI 4); Silo 3 (EQUI 11); and the pneumatic conveyance equipment used to move material to silos (existing EQUI 1, EQUI 2, EQUI 6, EQUI 7, EQUI 11, and EQUI 12). These lower emissions limits, described in Table 2, would go into effect once EPA approves the changes into the SIP. In addition to lowering the limits, the new permit has changed the averaging times and recordkeeping requirements to better represent the activities at the facility: this is primarily the case changing from a “24-hour rolling average” to a “daily average”, since Bulk Silos does not operate 24 hours a day.


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Table 2. Changes equipment emissions limits from the effective permit to the new permit. MPCA is requesting these limits be included in the site-specific SIP as a part of this revision.

Limit in SIP-Effective Permit

12300391-002

Limit in Draft Permit 12300391-102 Pre-Project (prior to EPA

approval of the SIP) Post-Project (after EPA

approval of the SIP)

EQUI 1 PM10 < 0.25 lb/hr on 24-hr rolling average (at EQUI 1)

PM10 < 0.25 lb/hr on daily average

(at EQUI 1)

PM10 <= 0.009 lb/hr on daily average

(at COMG 2)

EQUI 2 PM10 < 0.25 lb/hr on 24-hr rolling average (at EQUI 2)


(at EQUI 2)


(at COMG 2)

EQUI 3 (including EQUIs 6, 7, 11, and 12)*

PM10 < 0.84 lb/hr on 24-hour rolling average

(at EQUI 3)


(at COMG 1)


(at COMG 2; includes EQUIs 6, 7, and 12)

and

PM10 <= 0.0008 lb/hr on daily

average (at EQUI 11)

EQUI 4 (truck loading)

PM10 <= 0.15 ton/year on 24-hour rolling average

(at EQUI 4)

and

PM10 <= 0.15 ton/year on 12-month rolling average

(at EQUI 4)


(at EQUI 4)

and

PM10 <= 0.15 ton/year on 12-

month rolling average (at EQUI 4)


(at EQUI 4)

FUGI 2 (unpaved roads)


(at FUGI 2)

and

PM10 <= 0.30 ton/year on 12-month rolling average

(at FUGI 2)

None – roads were paved prior to issuance of this permit. Previous limits in effective permit -002 have been removed in

new permit -102.

*Previously, EQUI 3 was comprised of four different emission units: EQUI 6, EQUI 7, EQUI 11 (Silo 3), and EQUI 12. EQUIs 6, 7, and 12 are unloading silos. Therefore, post-project, they are subject to the PM10 limit at COMG 2. EQUI 11 will become a “middle man” silo – its only purpose will be to help move product from other silos to the truck loading operation. It will not have product unloaded into it; therefore, it is subject to a separate PM10 limit post-project.

Overall, these lower allowable PM10 emissions limits, combined with other equipment and operational limitations, would result in a facility-wide net decrease of 1.77 pounds per hour in allowable emissions, and about 0.45 tons per year. We are requesting that these requirements be added to the site-specific SIP for this facility.


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Replacement of fabric filters Permit No. 12300391-102 authorizes Bulk Silos to replace three existing fabric filters with three new fabric filters. The filter replacements are as follows:

• TREA 1, a Scientific Dust Collector SPJ-18, will be replaced by TREA 5, a Donaldson BVF1401; • TREA 2, a Scientific Dust Collector SPJ-18, will be replaced by TREA 6, a Donaldson BVF1301; and • TREA 3, a Mikro-Pulsaire 81S-10-20-B, will be replaced by TREA 9, a Scientific Dust Collector SPJ-24-X4B6BV.

New construction with Title I SIP conditions Permit No. 12300391-102 authorizes construction of new equipment at the Bulk Silos facility. Since the MPCA has an EPA-approved permit program and delegated authority to issue construction and operation permits that are protective of the NAAQS, the MPCA would not typically add Title I SIP conditions to the requirements for new (non-replacement) equipment or operations as part of the authorization for a facility. In the case of the Bulk Silos facility, however, we are requesting that EPA approve new Title I SIP conditions into Minnesota’s SIP in order to demonstrate continued compliance with the PM10 NAAQS in the Red Rock Road Maintenance Area. New equipment would not be operable by the facility until EPA approves the requirements into Minnesota’s SIP, thereby approving new operations at the facility. Prior permits explicitly required Bulk Silos to provide a modeling protocol for an equivalent-or-better demonstration in order to make any physical changes to the PM10 SIP-approved equipment at the facility. For the issuance of Permit No 12300391-102, Bulk Silos underwent a SIL analysis for PM10. Since new equipment and processes were included in the SIL modeling relied on for the issuance of the permit, the MPCA is requesting that these new equipment and processes be incorporated into Minnesota’s SIP. Adding these new Title I SIP conditions will ensure that the facility continues to not contribute to an exceedance of the PM10 NAAQS in the Red Rock Road Maintenance Area. Further, Permit No. 12300391-102 has changed the modeling requirements for the facility by specifically listing triggers for when a modeling protocol must be submitted, replacing the equivalent-or-better requirements (see TFAC 1, 5.1.1 and 6.1.1). Clarifying what’s need for modeling will ensure that future modeling efforts will fully capture the changes made to the permit and SIP as a result of the issuance of Permit No. 12300391-102. Permit No. 12300391-102 authorizes the construction of the following equipment at the facility:

• Construction of three new silos (EQUI 8, EQUI 9, and EQUI 10); • Construction of a new bucket elevator (EQUI 5); and • Construction of nine new fabric filters (TREA 7, TREA 8, TREA 10, TREA 11, TREA 12, TREA 13, TREA 14, TREA 15,

and TREA 16). Each of the new components being added to the Bulk Silos facility will include Title I SIP requirements on their emissions limits, throughput limits (in the case of EQUI 5), and monitoring/recordkeeping requirements (TREAs). EPA must approve these changes into Minnesota’s SIP before Bulk Silos can operate the new equipment. New silos. EQUIs 8, 9, and 10 are new pneumatic conveyance systems for moving materials to new Silos 9, 8, and 7, respectively. The ventilation of each EQUI into their respective fabric filters (TREAs) are specified in the permit requirements for each piece of equipment, and have Title I SIP conditions attached. New bucket elevator. EQUI 5 is a bucket elevator that will be used to move material at the site. The new elevator will be subject to allowable throughput limits of 1100 tons per day on average, or 350,000 tons per year calculated as a 12-month rolling sum.


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New fabric filters. In addition to replacing three fabric filters, Permit No. 12300391-102 authorizes the construction of nine new fabric filters. These filters will also have a higher flow rate and monitoring and recordkeeping requirements subject to Title I SIP conditions. The new fabric filters being added to the facility are as follows:

• TREA 7, a Donaldson (BVF1402); • TREA 8, a Donaldson (BVF1101); • TREA 10, a Donaldson (CF3301); • TREA 11, a Donaldson (BVF2701); • TREA 12, a Donaldson (BVF2801); • TREA 13, a Donaldson (BVF2901); and • TREAs 14, 15, and 16, for which the exact models are yet to be determined.

We are requesting that the above requirements be added to the site-specific SIP for this facility. Permit clean-up When SIP revisions propose changes to conditions in a facility’s SIP, the permit conditions hold language that says that the new conditions will become applicable and old conditions will be terminated upon EPA’s approval of the SIP. This allows for continuity of operations at the facility and a clear distinction for when new conditions become applicable. MPCA permit engineers also use major amendments as an opportunity to update permit formatting, specific language, and citations, as needed; these changes do not affect actual emissions limits. Some of these changes have been made in the Bulk Silos permit, and have been included in this SIP revision.


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PM10 emission changes Table 3 shows the proposed PM10 emission changes from the prior SIP submittal (associated with permit 12300391-002, 72 FR 51713) to this submittal (associated with permit 12300391-102). This SIP revision incorporates several changes to the Bulk Silos permit and Title I SIP conditions, but the overall allowable PM10 emissions at the facility are reduced relative to their previously-approved SIP levels. This reduction is due to a combination of significantly-lower facility-specific emissions factors used for modeling, lower allowable hourly emissions of PM10 at several emissions points, and newer operational limitations. The overall proposed reduction of the 24-hr allowable PM10 emissions is 1.18 lb/hr, while the reduction in the annual allowable PM10 emissions is 0.45 tpy. These reductions are found even with increased allowable throughput limits and new equipment being added at the facility. Table 3. Allowable PM10 emission changes from the previously-approved SIP to this current SIP revision.

24-Hour Average Annual Average Emissions Unit MPCA ID Existing SIP

PM10 Limit (lb/hr)

New SIP PM10 Limit

(lb/hr)

Change to SIP PM10

Limit (lb/hr)

Existing SIP PM10 Limit

(tpy)

New SIP PM10 Limit

(tpy)

Change to SIP PM10

Limit (tpy)

Pneumatic Conveyance to Silo 6

EQUI 1 0.25 --+ -0.25 -- -- --


EQUI 2 0.25 --+ -0.25 -- -- --

Former EQUI 3 COMG 1 (EQUI 3)* 0.84 --* -0.84 -- -- --

Truck Loading Operations EQUI 4 0.15 0.009 -0.141 0.15 -- -0.15 Unpaved Roads FUGI 2 0.30 -- -0.30 0.30 -- -0.30 Bucket Elevator EQUI 5 -- 0.0031 0.0031 -- -- -- Unloading Silos COMG 2 -- 0.009 0.009 -- -- -- Silo 3 EQUI 11 -- 0.0008 0.0008 -- -- -- Major Amendment Impacts to PM10 SIP

Limits -1.77 -0.45

+Upon startup of the new operating scenario (“the Project”), the Permittee will have the ability to unload product into EQUIs 1, 2, 6, 7, 8, 9, 10, or 12. Therefore, COMG 2 was created with these EQUIs. They are collectively subject to the Unloading Process Throughput limits and the “New SIP PM10 Limit” of 0.009 lb/hr. This is why the “New SIP PM10 Limit” column is blank for EQUI 1 and EQUI 2. *EQUI 3 was previously comprised of four individual emission units: EQUI 6, EQUI 7, EQUI 11, and EQUI 12. These four units are subject to the combined PM10 limit of 0.84 lb/hr at COMG 1 until startup of the Project. Then, the PM10 limit for EQUIs 6, 7, and 12 will be encompassed by the PM10 limit at COMG 2 and the PM10 limit for EQUI 11 will be at EQUI 11. This is why the “New SIP PM10 Limit” column is blank for COMG 1.


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Modeling Prior permits explicitly required Bulk Silos to provide a modeling protocol for an equivalent-or-better demonstration in order to make any physical changes to the PM10 SIP-approved equipment at the facility; the relevant equipment were listed in the previous permits at Appendix B (12300391-002) and Appendix A (12300391-101). For the issuance of Permit No. 12300391-102, which included significant changes to the permit and facility operations, Bulk Silos underwent a SIL analysis for PM10. Since new equipment and processes were included in the SIL modeling relied on for the issuance of the permit, the MPCA is requesting that these new equipment and processes be incorporated into Minnesota’s SIP. Historically, Appendices B and A included a minimal number of equipment and processes at the facility. Table 4 shows the original features and parameters used for previous modeling exercises. Table 4. Original PM10 emissions sources and parameters included in prior Appendices B and A to Bulk Silos permits

Source ID

EQUI; STRU; TREA

Source Description

Emission Rate Location UTM NAD83 Base Elev (m)

Stack Height

(m)

Stack Temp

(K)

Stack Exit Vel. (m/s)

Stack Dia (m) g/s lb/hr X (m) Y (m)

SILO1

EQUI 1; STRU 1; TREA 1

Silo No. 1 (new material)

0.0318 0.25 496283.1 4975465 213 25.6 293 9.7 0.305

SILO2 EQUI 2; STRU 2; TREA 2


0.0318 0.25 496289.7 4975468 213 25.6 293 9.7 0.305

SILO3_6 EQUI 3; STRU 3; TREA 3

Silo No. 3-6 (fly ash) 0.1058 0.84 496279.2 4975480 213 31.09 293 31.35 0.309

PM10 Volume Source Modeling Parameters

Source ID FUGI Source

Description


Release Height

(m) σ Y (m) σ Z (m)

g/s lb/hr X (m) Y (m)

UNLOAD EQUI 4

Silo Unloading and Truck Loading

4.25E-03 3.37E-02 496285.3 4975474 213 3 1.41 1.39

TRUCK FUGI 2 TREA 4

Fugitive Emissions from Truck Traffic

8.58E-03 6.81E-02 496285.3 4975474 213 1 11.4 0.85


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Permit No. 12300391-102 authorizes the construction of several new PM10 emissions sources. In order to approve the new conditions listed in Permit No. 12300391-102, the MPCA conducted SIL modeling to determine compliance with the PM10 NAAQS using both existing and new PM10 emissions sources. Table 5 describes the updated list, now included with Table 4 in Appendix A of the permit. Permit No. 12300391-102 replaced the equivalent-or-better demonstration language with specific triggers that would require future modeling, assuming they result in changes to the parameters in the permit Appendix A and/or include new PM10 emissions points, per the requirements listed in the permit at TFAC 1, 5.1.1 and 6.1.1. Table 5. Updated PM10 modeling sources and parameters included in, and used to issue, Permit No. 12300391-102.

Permit ID Source Description

Averaging Time

Emission Rate Location UTM NAD83 Stack

Height (m) Stack Temp

(K)

Stack Exit Vel.

(m/s)

Stack Dia (m)

Flow Rate

(ACFM) g/s lb/hr X (m) Y (m)

STRU 10 Silo 4 (EQUI 6, TREA 8)

24-hr 0.0006 0.0045

496,270 4,975,470 29.9 293 19.1 0.34 3,640

Annual 0.0005 0.0037

STRU 11 Truck loading operation (EQUI 4, TREA 9)

24-hr 0.0011 0.009 496,281 4,975,470 27.4 293 32.1 0.18 1,800

Annual 0.0009 0.0073

STRU 12 Bucket elevator operation (EQUI 5, TREA 10)

24-hr 0.0004 0.0031 496,264 4,975,479 6.1 293 7.2 0.49 2,900

Annual 0.0003 0.0027


24-hr 0.0011 0.009 496,278 4,975,489 29.9 293 18.2 0.49 7,275

Annual 0.0009 0.0073


24-hr 0.0011 0.009 496,269 4,975,482 29.9 293 18.2 0.49 7,275

Annual 0.0009 0.0073


24-hr 0.0011 0.009 496,260 4,975,475 29.9 293 18.2 0.49 7,275

Annual 0.0009 0.0073


24-hr 0.0011 0.009 496,283 4,975,458 25.3 293 19.1 0.34 3,640

Annual 0.0009 0.0073


24-hr 0.0011 0.009 496,292 4,975,467 25.3 293 19.1 0.34 3,640

Annual 0.0009 0.0073


24-hr 0.0011 0.009 496,286 4,975,485 29.9 293 19.1 0.34 3,640

Annual 0.0009 0.0073


24-hr 0.0006 0.0045 496,266 4,975,466 29.9 293 19.1 0.34 3,640

Annual 0.0005 0.0037


24-hr 0.0001 0.0008 496,271 4,975,471 25.3 293 3.9 0.34 750

Annual 0.0001 0.0007


24-hr 0.0011 0.009 496,277 4,975,477 29.9 293 19.1 0.34 3,640

Annual 0.0009 0.0073


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The results of the SIL modeling indicate that facility operations scenarios that apply after EPA approves our requested changes into the site-specific SIP for this facility will be far below the NAAQS. This includes and accounts for increased throughputs, new and replaced equipment, and other changes subsequently authorized in Permit No. 12300391-102. Table 6 shows the results of the PM10 SIL analysis. Table 6. SIL analysis results for PM10 emissions expected at the Bulk Silos facility

Averaging period SIL (µg/m3) Total modeled concentration (µg/m3) Percent of standard (%)

24-hour 5 1.08 22 Annual 1 0.3 30

Monitoring The MPCA has a collocated PM10 monitor placed at the south end of the Ramsey County Red Rock Road Maintenance Area. This monitor is a one-in-six-day sampler. Table 7 shows the design values of PM10 at the monitor for the most recent three years available (2017-2019) for comparison to the PM10 NAAQS. Table 7. PM10 monitoring data from the monitor south of the Bulk Silos facility, in the Ramsey County Red Rock Road maintenance area.

Monitor Red Rock Road (27-123-0866) Standard Year(s) Design Value (µg/m3) Percent of Standard Daily (0866-1) 2017-2019 90 60 Daily background (0866-2) 2017-2019 80 53

The decrease in allowable emissions associated with this SIP revision will aid the continued attainment and maintenance of the PM10 NAAQS in the Red Rock Road Maintenance Area.


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Process flow diagram

New STRU 11

New STRU 12

New STRU 13 New STRU 14

New STRU 15

Barge and Railcar Unloading

400 ton/hour (200 ton/hour from Rail and 200 ton/hour from

Barge)

(can happen simultaneously)

Silo 1 (EQUI 7)

Silo 2 (EQUI 12)

Silo 3 (EQUI 11)

New Silo 9 (EQUI 8)

Silo 4 (EQUI 6) (EU 004)

New Silo 8 (EQUI 9)

New Silo 7 (EQUI 10)

New Bucket Elevator (EQUI 5) (EU 006)

Truck Loading (EQUI 4) (EU 005)

New TREA 13

New TREA 12

New TREA 11

New TREA 10

New TREA 9

new STRU 18 STRU 30

New TREA 7

Currently EQUI 3

new TREA 15

New STRU 20 STRU 32

New STRU 21 STRU 33

New TREA 8

New STRU 10

New STRU 19 STRU 31



new STRU 16 STRU 28

new TREA 6

new STRU 17 STRU 29

new TREA 5

TREA 1 (CE 001)

STRU 1

TREA 2 (CE 002)

STRU 2

TREA 3 (CE 003) STRU 3

new TREA 16

new TREA 14


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Attachments Attachment 1: Air Emission Permit No. 12300391-102 Attachment 2: Technical Support Document for Permit No. 12300391-102 Attachment 3: Highlight version of Air Emission Permit No. 12300391-102 Attachment 4: List of all SIP conditions in Air Emission Permit No. 12300391-102 Attachment 5: Air Emission Permit No. 12300391-102 showing only SIP conditions to be incorporated by reference Attachment 6: Table of allowable PM10 emission changes Attachment 7: Public notice Attachment 8: Completeness review This summary was prepared by Fawkes Char, Environmental Analysis and Outcomes Division, MPCA.

Attachment 1: Air Emission Permit No. 12300391-102, issued to Bulk Silos Permit No. 12300391-102 was issued to Bulk Silos on xx, 2021 [to be updated]. All proposed SIP changes are applicable only upon approval by EPA of this permit into Minnesota’s SIP. Until that date, the SIP-approved requirements and limits of Permit No. 12300391-101 (which are the same as those in SIP-effective Permit No. 12300391-002) continue to apply. Permit No. 12300391-102 can also be found on the MPCA’s website: [Final draft permit available at https://www.pca.state.mn.us/public-notices - link will be updated once comment period has ended and final permit is issued.]

https://www.pca.state.mn.us/public-notices

DRAFT

Air Individual Permit Major Amendment

12300391-102 Permittee: Bulk Silos

Facility name: Bulk Silos 2145 Childs Rd Saint Paul, MN 55106 Ramsey County

Operating permit issuance date: November 17, 2006 Expiration date: Non-expiring Permit * All Title I Conditions do not expire Major Amendment: [Action Issue Date] Permit characteristics: State; Limits to avoid Part 70/ Limits to avoid NSR; Limits to avoid NSR Each new or revised condition designated “Title I Condition: 40 CFR 50.6 (SIP for PM10)” is not effective or enforceable until approved by U.S. Environmental Protection Agency (EPA) as a State Implementation Plan (SIP) revision under Title I of the Clean Air Act. The emission units, control equipment and emission stacks at the stationary source authorized in this permit amendment are as described in the submittals listed in the Permit Applications Table. This permit amendment supersedes Air Emission Permit No. 12300391-101 and authorizes the Permittee to modify and operate the stationary source at the address listed above unless otherwise noted in the permit. The Permittee must comply with all the conditions of the permit. Any changes or modifications to the stationary source must be performed in compliance with Minn. R. 7007.1150 to 7007.1500. (Any additions or changes to conditions incorporated into Minnesota’s State Implementation Plan (SIP) under 40 CFR § 52.1220, designated “Title I Condition: 40 CFR 50.6 (SIP for PM10)” must go through the federal SIP approval process before becoming effective.) Terms used in the permit are as defined in the state air pollution control rules unless the term is explicitly defined in the permit. Unless otherwise indicated, all the Minnesota rules cited as the origin of the permit terms are incorporated into the SIP under 40 CFR § 52.1220 and as such are enforceable by EPA Administrator or citizens under the Clean Air Act.

Signature: [Type e-Signature] This document has been electronically signed. for the Minnesota Pollution Control Agency

[Type name] [Title] [Division]

Table of Contents

Page

1. Permit applications table ............................................................................................................................................. 3 2. Where to send submittals ............................................................................................................................................ 4 3. Facility description ....................................................................................................................................................... 5 4. Summary of subject items ........................................................................................................................................... 6 5. Limits and other requirements .................................................................................................................................... 8 6. Submittal/action requirements ................................................................................................................................. 48 7. Appendices ................................................................................................................................................................. 60 Appendix A: Title I Condition: State Implementation Plan (SIP) for PM10 NAAQS. ......................................................... 61

Permit issued: [month day, year] 12300391-102 Permit expires: [month day, year] Page 3 of 63

1. Permit applications table

Permit applications: Title description Application receipt date Action number State Permit 04/13/2006 12300391- 002 Major Amendment 04/17/2009 12300391- 003 Administrative Amendment 02/04/2016 12300391-101 Major Amendment 04/16/2020, with supplemental

information received 02/12/2021 and 04/20/2021

12300391-102


2. Where to send submittals

Send submittals that are required to be submitted to the U.S. EPA regional office to: Chief Air Enforcement Air and Radiation Branch EPA Region V 77 West Jackson Boulevard Chicago, Illinois 60604

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

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

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

Send any application for a permit or permit amendment to:

Fiscal Services – 6th Floor Minnesota Pollution Control Agency 520 Lafayette Road North St. Paul, Minnesota 55155-4194

Also, where required by an applicable rule or permit condition, send to the Permit Document Coordinator notices of:

a. Accumulated insignificant activities b. Installation of control equipment c. Replacement of an emissions unit, and d. Changes that contravene a permit term

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

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

Or Email a signed and scanned PDF copy to: [email protected] (for submittals related to stack testing) [email protected] (for other compliance submittals) (See complete email instructions in “Routine Air Report Instructions Letter” at http://www.pca.state.mn.us/nwqh472.)

mailto:[email protected]


http://www.pca.state.mn.us/nwqh472


3. Facility description

The Bulk Silos (Facility) is located at 2145 Childs Rd, Saint Paul, Ramsey County, Minnesota. Bulk Silos is a Portland cement distribution terminal. The facility currently operates six silos with pollution control equipment used for storage and distribution of cementitious products. The material is currently received by rail, stored in the silos, and distributed by truck. The main sources of emissions are Particulate Matter (PM), Particulate Matter less than 10 microns (PM10), and Particulate Matter less than 2.5 microns (PM2.5). Emissions are controlled by baghouses on all of the operations at the facility. The major amendment is for the construction of three new silos (EQUI 8, EQUI 9, and EQUI 10), a new bucket elevator (EQUI 5), and nine new fabric filters (TREA 7, TREA 8, TREA 10, TREA 11, TREA 12, TREA 13, TREA 14, TREA 15, and TREA 16). Three existing fabric filters will be replaced (TREA 1 with TREA 5, TREA 2 with TREA 6, and TREA 3 with TREA 9). The Facility will also be adding barge unloading, and the material will be conveyed pneumatically from the barges to the storage silos. Many permit requirements are triggered by the startup of "the Project" which is defined as the startup of EQUI 5, EQUI 8, EQUI 9, and/or EQUI 10. After startup of the Project, product will no longer be unloaded into Silo 3 (EQUI 11). This silo will serve as a storage silo for the cementitious product in Silos 7, 8, and 9 (EQUIs 8, 9, and 10) as it is transferred from these silos, to the bucket elevator, to EQUI 11, and eventually to the truck loading operation (EQUI 4).


4. Summary of subject items

SI ID: Description

Relationship type

Related SI ID: Description

TFAC 1: Childs Road Terminal

COMG 1: Silos 1-4 has members EQUI 6, EQUI 7, EQUI 11, EQUI 12

COMG 2: Unloading Silos

has members EQUI 1, EQUI 2, EQUI 6, EQUI 7, EQUI 8, EQUI 9, EQUI 10, EQUI 12

COMG 3: Existing Unloading Silos

has members EQUI 1, EQUI 2, EQUI 6, EQUI 7, EQUI 11, EQUI 12

COMG 4: Bucket Elevator and Silo 3 Operations

has members EQUI 5, EQUI 11

EQUI 1: Pneumatic Conveyance to Silo 6

sends to STRU 1: Silo No. 6




is controlled by

TREA 1: Silo 6 Baghouse (existing)


is controlled by

TREA 5: Silo 6 Baghouse






is controlled by



is controlled by


EQUI 3: Material Storage Silo Nos. 3-6

EQUI 4: Truck Loading Operations



sends to STRU 11: Truck Loading


is controlled by

TREA 3: Truck Loading and COMG 1 Baghouse (existing)


is controlled by

TREA 9: Truck Loading

SI ID: Description

Relationship type

Related SI ID: Description Baghouse

EQUI 5: Bucket Elevator

sends to STRU 12: Bucket Elevator


is controlled by

TREA 10: Bucket Elevator Baghouse








is controlled by



is controlled by



is controlled by

TREA 14: Silo 4 Second Baghouse






is controlled by



is controlled by





is controlled by





is controlled by





is controlled by


EQUI 11: Silo 3 sends to STRU 3: Silo No. 3

Permit Issued: [month day, year] 12300391-102 Permit Expires: [month day, year] Page 7 of 63

SI ID: Description

Relationship type



EQUI 11: Silo 3 is controlled by









is controlled by



is controlled by


FUGI 3: Paved Roads STRU 1: Silo No. 6 STRU 2: Silo No. 5 STRU 3: Silo No. 3 STRU 10: Silo No. 4 STRU 11: Truck Loading

STRU 12: Bucket Elevator

STRU 13: Silo No. 9 STRU 14: Silo No. 8 STRU 15: Silo No. 7 STRU 28: Silo No. 5 STRU 29: Silo No. 6 STRU 30: Silo No. 1 STRU 31: Silo No. 4

SI ID: Description

Relationship type


STRU 32: Silo No. 3 STRU 33: Silo No. 2 TREA 1: Silo 6 Baghouse (existing)







TREA 9: Truck Loading Baghouse









5. Limits and other requirements

Requirement number Requirement and citation TFAC 1 Childs Road Terminal 5.1.1 This permit requires modeling to demonstrate compliance with the National Ambient Air Quality

Standards (NAAQS). The Permittee may not make any change at the source that would result in an increase in PM10 or PM2.5 emissions until it can be demonstrated that emissions from the facility as permitted do not cause an exceedance of the NAAQS. This includes changes that might otherwise qualify as insignificant modifications and minor or moderate amendments. [40 CFR pt. 51, Minn. R. 7007.0800, subp. 2(A)&(B), Minn. R. 7009.0020-7009.0090, Minn. Stat. 116.07, subd. 4a(a), Title I Condition: 40 CFR 51.6(PM10 SIP), Title I Condition: 40 CFR pt. 52, subp. Y]

5.1.2 ACTIVITIES NOT REQUIRING A MODIFICATION TO THE SIP: The Permittee is authorized to make changes to the facility without obtaining a modification to the SIP as long as the change does not increase from any emission point, the PM10 emission rates (either lb/hr or gr/dscf) or overall PM10 emissions, or alter equipment or parameters described in Appendix A, which forms the basis of the PM10 modeling. [40 CFR pt. 51, Title I Condition: 40 CFR 50.6(PM10 SIP), Title I Condition: 40 CFR pt. 52, subp. Y]

5.1.3 ACTIVITIES REQUIRING A MODIFICATION TO THE SIP: Activities requiring a modification of the SIP prior to the Permittee commencing the activity include, but are not limited to, the following: 1. Any decrease in stack emissions exit velocity contained in Appendix A, Table 1; 2. Any decrease in the exit point heat content of stack emissions contained in Appendix A, Table 1; 3. Any reduction in stack height below that contained in Appendix A, Table 1; 4. Any increase in stack exit diameter above that contained in Appendix A, Table 1; and 5 Any construction or modification of structures that increase the effective structural dimensions contained in Appendix A, Table 1. [40 CFR pt. 51, Title I Condition: 40 CFR 50.6(PM10 SIP), Title I Condition: 40 CFR pt. 52, subp. Y]

5.1.4 Upon startup of the Project: ACTIVITIES REQUIRING A MODIFICATION TO THE SIP: Activities requiring a modification of the SIP prior to the Permittee commencing the activity include, but are not limited to, the following: 1. Any decrease in stack emissions exit velocity contained in Appendix A, Table 2; 2. Any decrease in the exit point heat content of stack emissions contained in Appendix A, Table 2; 3. Any reduction in stack height below that contained in Appendix A, Table 2; 4. Any increase in stack exit diameter above that contained in Appendix A, Table 2; and 5 Any construction or modification of structures that increase the effective structural dimensions contained in Appendix A, Table 2. [40 CFR pt. 51, Title I Condition: 40 CFR 50.6(PM10 SIP), Title I Condition: 40 CFR pt. 52, subp. Y]

5.1.5 General Operation and Maintenance Requirements for the SIP: The Permittee shall operate and maintain the process and control equipment described in Appendix A according to the parameters set forth in Appendix A. The parameters were used in the computer modeling performed to demonstrate that the Childs Road portion of the PM10 maintenance area will attain compliance with the PM10 NAAQS. [40 CFR pt. 51, Title I Condition: 40 CFR 50.6(PM10 SIP), Title I Condition: 40 CFR pt. 52, subp. Y]

5.1.6 Shutdown or Breakdown of Pollution Control Equipment: In an event of a shutdown or breakdown of pollution control equipment, the Permittee shall follow the shutdown and breakdown procedures found in Minn. R. 7019.1000. [40 CFR pt. 51, Title I Condition: 40 CFR 50.6(PM10 SIP), Title I Condition: 40 CFR pt. 52, subp. Y]

5.1.7 Construction and Operation of SIP Emission Units: The Permittee may begin actual construction of new emission units or modification to existing emission units upon permit issuance. However, the


Requirement number Requirement and citation Permittee shall not operate any new emission unit or modified emission unit until any required SIP amendment is approved by EPA. [40 CFR pt. 51, Title I Condition: 40 CFR 50.6(PM10 SIP), Title I Condition: 40 CFR pt. 52, subp. Y]

5.1.8 Permanent Records for SIP: The Permittee shall permanently maintain the following information together with all amendments, revisions, and modifications to this information: 1. The Permittee shall maintain a file or files of information on the design, construction and operation of each emission facility, emission source, stack, structures pertinent to modeling for downwash, and any other information required to conduct PM10 ambient air quality modeling of emissions from the facility. 2. The Permittee shall maintain a file at the facility which includes all PM10 emission compliance demonstration plans which upon approval by the MPCA or EPA become integral and enforceable parts of the SIP. [40 CFR pt. 51, Minn. R. 7007.0800, subp. 5, Title I Condition: 40 CFR 50.6(PM10 SIP), Title I Condition: 40 CFR pt. 52, subp. Y]

5.1.9 Non-Permanent Records for SIP: The Permittee shall retain all records at the stationary source for a period of six (6) years from the date of the required monitoring, sample, measurement, or report that corresponds with a State Implementation Plan (SIP) Title I Condition include, but not limited to the following: 1. Monitoring, Testing (if required by the Commissioner, and other Records); 2. Startup, Shutdown, Bypass and Breakdown for each piece of process equipment, control equipment, emission stack, and monitoring system; 3. Any exceedance of an emission limitation or opacity limitation and any noncompliance with an operational requirement at the facility; 4. All required documents, records, reports and plans in a form suitable for determination of the facility's compliance with the SIP by EPA or MPCA staff. The Permittee shall maintain the information at the facility in files which are easily accessible of inspection by EPA or MPCA staff, and are available for inspection. [40 CFR pt. 51, Minn. R. 7007.0800, subp. 5, Title I Condition: 40 CFR 50.6(PM10 SIP), Title I Condition: 40 CFR pt. 52, subp. Y]

5.1.10 Reporting: The Permittee may undertake certain changes to the facility without obtaining a modification to the SIP. However, if the Permittee does make a change, and if the change in any way affects PM10 emissions (reduces the amount or changes the concentration, size, character, velocity, direction, or location of PM10 emissions) the Permittee shall notify the Commissioner in writing at least 30 days prior to undertaking the change. The notification shall describe the change and why it does not require a modification of the SIP. [40 CFR pt. 51, Title I Condition: 40 CFR 50.6(PM10 SIP), Title I Condition: 40 CFR pt. 52, subp. Y]

5.1.11 Permit Appendices: This permit contains appendices as listed in the permit Table of Contents. Modeling parameters in Appendix A are included for reference only as described elsewhere in this permit. [Minn. R. 7007.0800, subp. 2(A)&(B)]

5.1.12 The Permittee must comply with Minn. Stat. 116.385. The Permittee may not use trichloroethylene at its permitted facility after June 1, 2022, including in any manufacturing, processing, or cleaning processes, except as described in Minn. Stat. 116.385, subd. 2(b) and 4. This is a state-only requirement and is not enforceable by the U.S. Environmental Protection Agency (EPA) Administrator and citizens under the Clean Air Act. [Minn. Stat. 116.385]

5.1.13 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


Requirement number Requirement and citation other credible evidence to establish compliance or noncompliance with applicable requirements. This permit shall not alter or affect the liability of the Permittee for any violation of applicable requirements prior to or at the time of permit issuance. [Minn. R. 7007.1800(A)(2)]

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

5.1.15 Air Pollution Control Equipment: Operate all pollution control equipment whenever the corresponding process equipment and emission units are operated. [Minn. R. 7007.0800, subp. 16(J), Minn. R. 7007.0800, subp. 2(A) & (B)]

5.1.16 Operation and Maintenance Plan: Retain at the stationary source an operation and maintenance plan for all air pollution control equipment. At a minimum, the O & M plan shall identify all air pollution control equipment and control practices and shall include a preventative maintenance program for the equipment and practices, a description of (the minimum but not necessarily the only) corrective actions to be taken to restore the equipment and practices to proper operation to meet applicable permit conditions, a description of the employee training program for proper operation and maintenance of the control equipment and practices, and the records kept to demonstrate plan implementation. [Minn. R. 7007.0800, subp. 14, Minn. R. 7007.0800, subp. 16(J)]

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

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

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

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

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

5.1.22 Performance Testing: Conduct all performance tests in accordance with Minn. R. ch. 7017 unless otherwise noted in this permit. [Minn. R. ch. 7017]

5.1.23 Performance Test Notifications and Submittals: Performance Test Notification and Plan: due 30 days before each Performance Test Performance Test Pre-test Meeting: due seven days before each Performance Test Performance Test Report: due 45 days after each Performance Test The Notification, Test Plan, and Test Report must be submitted in a format specified by the commissioner. [Minn. R. 7017.2017, Minn. R. 7017.2030, subps. 1-4, Minn. R. 7017.2035, subps. 1-2]

5.1.24 Limits set as a result of a performance test (conducted before or after permit issuance) apply until superseded as stated in the MPCA's Notice of Compliance letter granting preliminary approval. Preliminary approval is based on formal review of a subsequent performance test on the same unit as specified by Minn. R. 7017.2025, subp. 3. The limit is final upon issuance of a permit amendment


Requirement number Requirement and citation incorporating the change. [Minn. R. 7017.2025, subp. 3]

5.1.25 Monitoring Equipment Calibration - The Permittee shall either: 1. Calibrate or replace required monitoring equipment every 12 months; or 2. Calibrate at the frequency stated in the manufacturer's specifications. For each monitor, the Permittee shall maintain a record of all calibrations, including the date conducted, and any corrective action that resulted. The Permittee shall include the calibration frequencies, procedures, and manufacturer's specifications (if applicable) in the Operations and Maintenance Plan. Any requirements applying to continuous emission monitors are listed separately in this permit. [Minn. R. 7007.0800, subp. 4(D)]

5.1.26 Operation of Monitoring Equipment: Unless noted elsewhere in this permit, monitoring a process or control equipment connected to that process is not necessary during periods when the process is shutdown, or during checks of the monitoring systems, such as calibration checks and zero and span adjustments. If monitoring records are required, they should reflect any such periods of process shutdown or checks of the monitoring system. [Minn. R. 7007.0800, subp. 4(D)]

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

5.1.28 Recordkeeping: Maintain records describing any insignificant modifications (as required by Minn. R. 7007.1250, subp. 3) or changes contravening permit terms (as required by Minn. R. 7007.1350, subp. 2), including records of the emissions resulting from those changes. [Minn. R. 7007.0800, subp. 5(B)]

5.1.29 If the Permittee determines that no permit amendment or notification is required prior to making a change, the Permittee must retain records of all calculations required under Minn. R. 7007.1200. For non-expiring permits, these records shall be kept for a period of five years from the date that the change was made. The records shall be kept at the stationary source for the current calendar year of operation and may be kept at the stationary source or office of the stationary source for all other years. The records may be maintained in either electronic or paper format. [Minn. R. 7007.1200, subp. 4]

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

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


Requirement number Requirement and citation Commissioner of the cause of the breakdown and the estimated duration. The owner or operator shall notify the Commissioner when the breakdown is over. [Minn. R. 7019.1000, subp. 2]

5.1.32 Notification of Deviations Endangering Human Health or the Environment: As soon as possible after discovery, notify the Commissioner or the state duty officer, either orally or by facsimile, of any deviation from permit conditions which could endanger human health or the environment. [Minn. R. 7019.1000, subp. 1]

5.1.33 Notification of Deviations Endangering Human Health or the Environment Report: Within two working days of discovery, notify the Commissioner in writing of any deviation from permit conditions which could endanger human health or the environment. Include the following information in this written description: 1. the cause of the deviation; 2. the exact dates of the period of the deviation, if the deviation has been corrected; 3. whether or not the deviation has been corrected; 4. the anticipated time by which the deviation is expected to be corrected, if not yet corrected; and 5. steps taken or planned to reduce, eliminate, and prevent reoccurrence of the deviation. [Minn. R. 7019.1000, subp. 1]

5.1.34 Application for Permit Amendment: If a permit amendment is needed, submit an application in accordance with the requirements of Minn. R. 7007.1150 through Minn. R. 7007.1500. Submittal dates vary, depending on the type of amendment needed. Upon adoption of a new or amended federal applicable requirement, and if there are three or more years remaining in the permit term, the Permittee shall file an application for an amendment within nine months of promulgation of the applicable requirement, pursuant to Minn. R. 7007.0400, subp. 3. [Minn. R. 7007.0400, subp. 3, Minn. R. 7007.1150 - 7007.1500]

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

5.1.36 Within 15 days of a request from the Commissioner, the Permittee must provide a complete summary of all performance tests required at the facility including the subject item, pollutant, most recent test date (if applicable), and the date of the next test in an approved format. [Minn. R. 7007.0800, subp. 16(L)]

5.1.37 Emission Inventory Report: due on or before April 1 of each calendar year following permit issuance. Submit in a format specified by the Commissioner. [Minn. R. 7019.3000-7019.3100]

5.1.38 Emission Fees: due 30 days after receipt of an MPCA bill. [Minn. R. 7002.0005-7002.0085] 5.1.39 The Permittee is authorized to construct the Barge Unloading and Silo Addition Project ("Project")

which includes the addition of EQUI 5, EQUI 8, EQUI 9, EQUI 10, TREA 5, TREA 6, TREA 7, TREA 8, TREA 9, TREA 10, TREA 11, TREA 12, TREA 13, TREA 14, TREA 15, TREA 16, and FUGI 3. Upon federal approval of the SIP Revision, the Permittee is authorized to operate the subject items listed above. The authorization to construct expires 5 years after issuance of Air Emissions Permit No. 12300391-102. The units shall meet all applicable permit requirements. [40 CFR pt. 51, Title I Condition: 40 CFR 50.6 (PM10 SIP), Title I Condition: 40 CFR pt. 52, subp. Y, Title I Condition: Avoid major modification under 40 CFR 52.21(b)(2) & Minn. R. 7007.3000, Title I Condition: Avoid major source under 40 CFR 52.21( b)(1)(i) & Minn. R. 7007.3000]

COMG 1 Silos 1-4 5.2.1 Requirements for COMG 1 expire upon startup of the Project. [Minn. R. 7007.0800, subp. 2(A)]


Requirement number Requirement and citation 5.2.2 PM < 10 micron < 0.84 pounds per hour daily average to be calculated as described later in this

permit. [40 CFR pt. 51, Title I Condition: 40 CFR 50.6(PM10 SIP), Title I Condition: 40 CFR pt. 52, subp. Y]

5.2.3 Process Throughput: Daily Recordkeeping. On each day of operation the Permittee shall record and maintain the total quantity of all materials unloaded from rail and/or barge to the members of COMG 1. The records shall be based on the midnight to midnight calendar day period and the computer/ticketing system. This shall be recorded in written or electronic usage logs. [40 CFR pt. 51, Title I Condition: 40 CFR 50.6(PM10 SIP), Title I Condition: 40 CFR pt. 52, subp. Y]

5.2.4 PM < 10 micron: Daily calculation. On each day of operation, for the previous day, the Permittee shall calculate, record, and maintain a record of the daily average lb/hr PM < 10 emissions from the unloading operations using the following equation: PM < 10 = EF x TP / 24 Where: PM < 10 = the daily average PM < 10 emissions from the previous operating day, in lb/hour; EF = 0.0000863 lb PM < 10 / ton of throughput (emission factor from calculations at time of permit issuance) or from the most recent emission factor performance test for COMG 1; and TP = total daily COMG 1 throughput for the previous calendar day, in ton/day. [Minn. R. 7007.0800, subps. 4-5]

COMG 2 Unloading Silos 5.3.1 Unloading Operations: The Permittee must limit Process Throughput <= 1100 tons per day daily

average. This requirement expires upon startup of the Project. [40 CFR pt. 51, 40 CFR pt. 52, subp. Y, Title I Condition: 40 CFR 50.6 (PM10 SIP)]

5.3.2 Unloading Operations: The Permittee must limit Process Throughput <= 100000 tons per year 12-month rolling sum. This requirement expires upon startup of the Project. [40 CFR pt. 51, 40 CFR pt. 52, subp. Y, Title I Condition: 40 CFR 50.6 (PM10 SIP), Title I Condition: Avoid major modification under 40 CFR 52.21(b)(2) & Minn. R. 7007.3000, Title I Condition: Avoid major source under 40 CFR 52.21(b)(1)(i) & Minn. R. 7007.3000, To avoid major source under 40 CFR 70.2 & Minn. R. 7007.0200]

5.3.3 Upon startup of the Project: The Permittee must limit Unloading Operations Process Throughput <= 2500 tons per day daily average to be calculated as described later in this permit. [40 CFR pt. 51, Minn. R. 7007.0800, subp. 2(A)&(B), Title I Condition: 40 CFR 50.5(PM10 SIP), Title I Condition: 40 CFR pt. 52, subp. Y]

5.3.4 Upon startup of the Project: The Permittee must limit Unloading Operations Process Throughput <= 740000 tons per year 12-month rolling sum to be calculated as described later in this permit. [40 CFR pt. 51, Minn. R. 7007.0800, subp. 2(A)&(B), Title I Condition: 40 CFR 50.6(PM10 SIP), Title I Condition: 40 CFR pt. 52, subp. Y, Title I Condition: Avoid major modification under 40 CFR 52.21(b)(2) & Minn. R. 7007.3000, Title I Condition: Avoid major source under 40 CFR 52.21(b)(1)(i) & Minn. R. 7007.3000, To avoid major source under 40 CFR 70.2 & Minn. R. 7007.0200]

5.3.5 Upon startup of the Project: PM < 10 micron <= 0.009 pounds per hour daily average to be calculated as described later in this permit. [40 CFR pt. 51, Minn. R. 7007.0800, subp. 2(A)&(B), Title I Condition: 40 CFR 50.6(PM10 SIP), Title I Condition: 40 CFR pt. 52, subp. Y]

5.3.6 Upon startup of the Project: PM < 2.5 micron <= 0.009 pounds per hour daily average to be calculated as described later in this permit. [Minn. R. 7007.0800, subp. 2(A)&(B)]

5.3.7 Upon startup of the Project: PM < 10 micron <= 0.017 pounds per hour 3-hour average. This limit applies individually to each member of COMG 2. [Minn. R. 7007.0800, subp. 2(A)]

5.3.8 Upon startup of the Project: PM < 2.5 micron <= 0.017 pounds per hour 3-hour average. This limit applies individually to each member of COMG 2. [Minn. R. 7007.0800, subp. 2(A)]


Requirement number Requirement and citation 5.3.9 Unloading Operations Process Throughput. Daily Recordkeeping. On each day of operation the

Permittee shall record and maintain the total quantity of all materials unloaded from rail and barge. The records shall be based on the midnight to midnight calendar day period and the computer/ticketing system. This shall be recorded in written or electronic usage logs. [40 CFR pt. 51, Minn. R. 7007.0800, subp. 2(A)&(B), Minn. R. 7007.0800, subps. 4-5, Title I Condition: 40 CFR 50.6 (PM10 SIP), Title I Condition: 40 CFR pt. 52, subp. Y, Title I Condition: Avoid major modification under 40 CFR 52.21(b)(2) & Minn. R. 7007.3000, Title I Condition: Avoid major source under 40 CFR 52.21(b)(1)(i) & Minn. R. 7007.3000, To avoid major source under 40 CFR 70.2 & Minn. R. 7007.0200]

5.3.10 Unloading Operations Process Throughput. Monthly Recordkeeping. By the 15th of the month, the Permittee shall calculate and record the following: 1) The total process throughput for the unloading operations for the previous calendar month using the daily records; and 2) The 12-month rolling sum of process throughput for the previous 12-month period by summing the monthly process throughput used for the previous 12 months. [Minn. R. 7007.0800, subps. 4-5]

5.3.11 Upon startup of the Project: PM < 10: Daily calculation. On each day of operation, for the previous day, the Permittee shall calculate, record, and maintain a record of the daily average lb/hr PM < 10 emissions from the unloading operations using the following equation: PM < 10 = EF x TP / 24 Where: PM < 10 = the daily average PM < 10 emissions from the previous operating day, in lb/hour; EF = 0.0000863 lb PM < 10 / ton of throughput (emission factor from calculations at time of permit issuance) or from the most recent emission factor performance test for COMG 2; and TP = total daily COMG 2 throughput for the previous calendar day, in ton/day. [Minn. R. 7007.0800, subps. 4-5]

5.3.12 Upon startup of the Project: PM < 2.5: Daily calculation. On each day of operation, for the previous day, the Permittee shall calculate, record, and maintain a record of the daily average lb/hr PM < 2.5 emissions from the unloading operations using the following equation: PM < 10 = EF x TP / 24 Where: PM < 2.5 = the daily average PM < 2.5 emissions from the previous operating day, in lb/hour; EF = 0.0000863 lb PM < 2.5 / ton of throughput (emission factor from calculations at time of permit issuance) or from the most recent emission factor performance test for COMG 2; and TP = total daily COMG 2 throughput for the previous calendar day, in ton/day. [Minn. R. 7007.0800, subps. 4-5]

COMG 4 Bucket Elevator and Silo 3 Operations 5.4.1 Upon startup of the Project: PM < 10 micron <= 0.009 pounds per hour 3-hour average for EQUI 5

and EQUI 11 combined. [Minn. R. 7007.0800, subp. 2(A)] 5.4.2 Upon startup of the Project: PM < 2.5 micron <= 0.009 pounds per hour 3-hour average for EQUI 5

and EQUI 11 combined. [Minn. R. 7007.0800, subp. 2(A)] EQUI 1 Pneumatic Conveyance to Silo 6 5.5.1 PM < 10 micron < 0.25 pounds per hour daily average to be calculated as described later in this

permit. This requirement expires upon startup of the Project. [40 CFR pt. 51, Title I Condition: 40 CFR 50.6(PM10 SIP), Title I Condition: 40 CFR pt. 52, subp. Y]

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


Requirement number Requirement and citation 5.5.3 Particulate Matter <= 0.30 grains per dry standard cubic foot of exhaust gas unless required to further

reduce emissions to comply with the less stringent limit of either Minn. R. 7011.0730 or Minn. R. 7011.0735. [Minn. R. 7011.0715, subp. 1(A)]

5.5.4 Process Throughput: Daily Recordkeeping. On each day of operation the Permittee shall record and maintain the total quantity of all materials unloaded from rail and/or barge to EQUI 1. The records shall be based on the midnight to midnight calendar day period and the computer/ticketing system. This shall be recorded in written or electronic usage logs. This requirement expires upon startup of the Project. [40 CFR pt. 51, Title I Condition: 40 CFR 50.6(PM10 SIP), Title I Condition: 40 CFR pt. 52, subp. Y]

5.5.5 PM < 10 micron: Daily calculation. On each day of operation, for the previous day, the Permittee shall calculate, record, and maintain a record of the daily average lb/hr PM < 10 emissions from the unloading operations using the following equation: PM < 10 = EF x TP / 24 Where: PM < 10 = the daily average PM < 10 emissions from the previous operating day, in lb/hour; EF = 0.0000863 lb PM < 10 / ton of throughput (emission factor from calculations at time of permit issuance) or from the most recent emission factor performance test for COMG 3; and TP = total daily EQUI 1 throughput for the previous calendar day, in ton/day. This requirement expires upon startup of the Project. [Minn. R. 7007.0800, subps. 4-5]

5.5.6 The Permittee shall vent emissions from EQUI 1 to control equipment meeting the requirements of TREA 1 whenever EQUI 1 operates. This requirement expires upon startup of TREA 5. [40 CFR pt. 51, Title I Condition: 40 CFR 50.6(PM10 SIP), Title I Condition: 40 CFR pt. 52, subp. Y, Title I Condition: Avoid major modification under 40 CFR 52.21(b)(2) & Minn. R. 7007.3000, Title I Condition: Avoid major source under 40 CFR 52.21(b)(1)(i) & Minn. R. 7007.3000, To avoid major source under 40 CFR 70.2 & Minn. R. 7007.0200]

5.5.7 Upon startup of TREA 5: The Permittee shall vent emissions from EQUI 1 to control equipment meeting the requirements of TREA 5 whenever EQUI 1 operates. [40 CFR pt. 51, Minn. R. 7007.0800, subp. 2(A)&(B), Title I Condition: 40 CFR 50.6 (PM10 SIP), Title I Condition: 40 CFR pt. 52, subp. Y, Title I Condition: Avoid major modification under 40 CFR 52.21(b)(2) & Minn. R. 7007.3000, Title I Condition: Avoid major source under 40 CFR 52.21(b)(1)(i) & Minn. R. 7007.3000, To avoid major source under 40 CFR 70.2 & Minn. R. 7007.0200]

EQUI 2 Pneumatic Conveyance to Silo 5 5.6.1 PM < 10 micron < 0.25 pounds per hour daily average to be calculated as described later in this


5.6.2 Opacity <= 20 percent opacity. [Minn. R. 7011.0715, subp. 1(B)] 5.6.3 Particulate Matter <= 0.30 grains per dry standard cubic foot of exhaust gas unless required to further




Requirement number Requirement and citation 5.6.5 PM < 10 micron: Daily calculation. On each day of operation, for the previous day, the Permittee shall

calculate, record, and maintain a record of the daily average lb/hr PM < 10 emissions from the unloading operations using the following equation: PM < 10 = EF x TP / 24 Where: PM < 10 = the daily average PM < 10 emissions from the previous operating day, in lb/hour; EF = 0.0000863 lb PM < 10 / ton of throughput (emission factor from calculations at time of permit issuance) or from the most recent emission factor performance test for COMG 3; and TP = total daily EQUI 2 throughput for the previous calendar day, in ton/day. This requirement expires upon startup of the project. [Minn. R. 7007.0800, subps. 4-5]


5.6.7 Upon startup of TREA 6: The Permittee shall vent emissions from EQUI 2 to control equipment meeting the requirements of TREA 6 whenever EQUI 2 operates. [40 CFR pt. 51, Minn. R. 7007.0800, subp. 2(A)&(B), Title I Condition: 40 CFR 50.6(PM10 SIP), Title I Condition: 40 CFR pt. 52, subp. Y, Title I Condition: Avoid major modification under 40 CFR 52.21(b)(2) & Minn. R. 7007.3000, Title I Condition: Avoid major source under 40 CFR 52.21(b)(1)(i) & Minn. R. 7007.3000, To avoid major source under 40 CFR 70.2 & Minn. R. 7007.0200]

EQUI 4 Truck Loading Operations 5.7.1 PM < 10 micron <= 0.15 tons per year 24-hour rolling average. This requirement expires upon startup

of the Project. [40 CFR pt. 51, Title I Condition: 40 CFR 50.6(PM10 SIP), Title I Condition: 40 CFR pt. 52, subp. Y]

5.7.2 PM < 10 micron <= 0.15 tons per year 12-month rolling average. This requirement expires upon startup of the Project. [40 CFR pt. 51, Title I Condition: 40 CFR 50.6(PM10 SIP), Title I Condition: 40 CFR pt. 52, subp. Y]

5.7.3 Upon startup of the Project: The Permittee must limit Truck Loading Operations Process Throughput <= 2500 tons per day daily average to be calculated as described later in this permit. [40 CFR pt. 51, Minn. R. 7007.0800, subp. 2(A)&(B), Title I Condition: 40 CFR 50.6(PM10 SIP), Title I Condition: 40 CFR pt. 52, subp. Y]

5.7.4 Upon startup of the Project: The Permittee must limit Truck Loading Operations Process Throughput <= 740000 tons per year 12-month rolling sum. [40 CFR pt. 51, Minn. R. 7007.0800, subp. 2(A)&(B), Title I Condition: 40 CFR 50.6(PM10 SIP), Title I Condition: 40 CFR pt. 52, subp. Y, Title I Condition: Avoid major modification under 40 CFR 52.21(b)(2) & Minn. R. 7007.3000, Title I Condition: Avoid major source under 40 CFR 52.21(b)(1)(i) & Minn. R. 7007.3000, To avoid major source under 40 CFR 70.2 & Minn. R. 7007.0200]

5.7.5 Upon startup of the Project: PM < 10 micron <= 0.009 pounds per hour daily average to be calculated as described later in this permit. [40 CFR pt. 51, 40 CFR pt. 52, subp. Y, Minn. R. 7007.0800, subp. 2(A)&(B), Title I Condition: 40 CFR 50.6(PM10 SIP)]


5.7.7 Upon startup of the Project: PM < 10 micron <= 0.017 pounds per hour 3-hour average. [Minn. R.


Requirement number Requirement and citation 7007.0800, subp. 2(A)]

5.7.8 Upon startup of the Project: PM < 2.5 micron <= 0.017 pounds per hour 3-hour average. [Minn. R. 7007.0800, subp. 2(A)]

5.7.9 Truck Loading Operations Process Throughput. Daily Recordkeeping. On each day of operation the Permittee shall record and maintain the total quantity of all materials loaded into the truck loading operation (EQUI 4). The records shall be based on the midnight to midnight calendar day period and the computer/ticketing system. This shall be recorded in written or electronic usage logs. [40 CFR pt. 51, Minn. R. 7007.0800, subp. 2(A)&(B), Title I Condition: 40 CFR 50.6(PM10 SIP), Title I Condition: 40 CFR pt. 52, subp. Y]

5.7.10 Truck Loading Operations Process Throughput. Monthly Recordkeeping. By the 15th of the month, the Permittee shall calculate and record the following: 1) The total process throughput for EQUI 4 for the previous calendar month using the daily records; and 2) The 12-month rolling sum of process throughput for the previous 12-month period by summing the monthly process throughput used for the previous 12 months. [Minn. R. 7007.0900, subps. 4-5]

5.7.11 Upon startup of the Project: PM < 10: Daily calculation. On each day of operation, for the previous day, the Permittee shall calculate, record, and maintain a record of the daily average lb/hr PM < 10 emissions from EQUI 4 using the following equation: PM < 10 = EF x TP / 24 Where: PM < 10 = the daily average PM < 10 emissions from the previous operating day, in lb/hour; EF = 0.0000863 lb PM < 10 / ton of throughput (emission factor from calculations at time of permit issuance) or from the most recent emission factor performance test for EQUI 4; and TP = total daily EQUI 4 throughput for the previous calendar day, in ton/day. [Minn. R. 7007.0800, subps. 4-5]

5.7.12 Upon startup of the Project: PM < 2.5: Daily calculation. On each day of operation, for the previous day, the Permittee shall calculate, record, and maintain a record of the daily average lb/hr PM < 2.5 emissions from EQUI 4 using the following equation: PM < 2.5 = EF x TP / 24 Where: PM < 2.5 = the daily average PM < 2.5 emissions from the previous operating day, in lb/hour; EF = 0.0000863 lb PM < 2.5 / ton of throughput (emission factor from calculations at time of permit issuance) or from the most recent emission factor performance test for EQUI 4; and TP = total daily EQUI 4 throughput for the previous calendar day, in ton/day. [Minn. R. 7007.0800, subps. 4-5]

5.7.13 The Permittee shall vent emissions from EQUI 4 to control equipment meeting the requirements of TREA 3 whenever EQUI 4 operates. This requirement expires upon startup of TREA 9. [40 CFR pt. 51, Title I Condition: 40 CFR 50.6(PM10 SIP), Title I Condition: 40 CFR pt. 52, subp. Y, Title I Condition: Avoid major modification under 40 CFR 52.21(b)(2) & Minn. R. 7007.3000, Title I Condition: Avoid major source under 40 CFR 52.21(b)(1)(i) and Minn. R. 7007.3000, To avoid major source under 40 CFR 70.2 & Minn. R. 7007.0200]




Requirement number Requirement and citation 5.7.16 Upon startup of TREA 9: The Permittee shall vent emissions from EQUI 4 to control equipment

meeting the requirements of TREA 9 whenever EQUI 4 operates. [40 CFR pt. 51, Minn. R. 7007.0800, subp. 2(A)&(B), Title I Condition: 40 CFR 50.6(PM10 SIP), Title I Condition: 40 CFR pt. 52, subp. Y, Title I Condition: Avoid major modification under 40 CFR 52.21(b)(2) & Minn. R. 7007.3000, Title I Condition: Avoid major source under 40 CFR 52.21(b)(1)(i) & Minn. R. 7007.3000, To avoid major source under 40 CFR 70.2 & Minn. R. 7007.0200]

EQUI 5 Bucket Elevator 5.8.1 Upon startup of the Project: The Permittee must limit Bucket Elevator Process Throughput <= 1100

tons per day daily average to be calculated as described later in this permit. [40 CFR pt. 51, Minn. R. 7007.0800, subp. 2(A)&(B), Title I Condition: 40 CFR 50.6(PM10 SIP), Title I Condition: 40 CFR pt. 52, subp. Y]

5.8.2 Upon startup of the Project: The Permittee must limit Bucket Elevator Process Throughput <= 350000 tons per year 12-month rolling sum. [40 CFR pt. 51, Minn. R. 7007.0800, subp. 2(A)&(B), Title I Condition: 40 CFR 50.6(PM10 SIP), Title I Condition: 40 CFR pt. 52, subp. Y, Title I Condition: Avoid major modification under 40 CFR 52.21(b)(2) & Minn. R. 7007.3000, Title I Condition: Avoid major source under 40 CFR 52.21(b)(1)(i) & Minn. R. 7007.3000, To avoid major source under 40 CFR 70.2 & Minn. R. 7007.0200]

5.8.3 PM < 10 micron <= 0.0031 pounds per hour daily average to be calculated as described later in this permit. [40 CFR pt. 51, Minn. R. 7007.0800, subp. 2(A)&(B), Title I Condition: 40 CFR 50.6(PM10 SIP), Title I Condition: 40 CFR pt. 52, subp. Y]

5.8.4 PM < 2.5 micron <= 0.0031 pounds per hour daily average to be calculated as described later in this permit. [Minn. R. 7007.0800, subp. 2(A)&(B)]

5.8.5 Bucket Elevator Process Throughput. Daily Recordkeeping. On each day of operation the Permittee shall record and maintain the total quantity of all materials processed by the Bucket Elevator (EQUI 5). The records shall be based on the midnight to midnight calendar day period and flow meter readings. This shall be recorded in written or electronic usage logs. [40 CFR pt. 51, Minn. R. 7007.0800, subp. 2(A)&(B), Title I Condition: 40 CFR 50.6(PM10 SIP), Title I Condition: 40 CFR pt. 52, subp. Y]

5.8.6 Bucket Elevator Process Throughput. Monthly Recordkeeping. By the 15th of the month, the Permittee shall calculate and record the following: 1) The total process throughput for EQUI 5 for the previous calendar month using the daily records; and 2) The 12-month rolling sum of process throughput for the previous 12-month period by summing the monthly process throughput used for the previous 12 months. [Minn. R. 7007.0800, subps. 4-5]

5.8.7 PM < 10 micron: Daily calculation. On each day of operation, for the previous day, the Permittee shall calculate, record, and maintain a record of the daily average lb/hr PM < 10 emissions from EQUI 5 using the following equation: PM < 10 = EF x TP / 24 x (2900 / (2900 + 750)) Where: PM < 10 = the daily average PM < 10 emissions from the previous operating day, in lb/hour; EF = 0.0000863 lb PM < 10 / ton of throughput (emission factor from calculations at time of permit issuance) or from the most recent emission factor performance test for COMG 4; and TP = total daily EQUI 5 throughput for the previous calendar day, in ton/day. [Minn. R. 7007.0800, subps. 4-5]

5.8.8 PM < 2.5 micron: Daily calculation. On each day of operation, for the previous day, the Permittee shall calculate, record, and maintain a record of the daily average lb/hr PM < 2.5 emissions from EQUI 5 using the following equation:


Requirement number Requirement and citation PM < 2.5 = EF x TP / 24 x (2900 / (2900 + 750)) Where: PM < 2.5 = the daily average PM < 2.5 emissions from the previous operating day, in lb/hour; EF = 0.0000863 lb PM < 2.5 / ton of throughput (emission factor from calculations at time of permit issuance) or from the most recent emission factor performance test for COMG 4; and TP = total daily EQUI 5 throughput for the previous calendar day, in ton/day. [Minn. R. 7007.0800, subps. 4-5]



5.8.11 The Permittee shall vent emissions from EQUI 5 to control equipment meeting the requirements of TREA 10 whenever EQUI 5 operates. [40 CFR pt. 51, Minn. R. 7007.0800, subp. 2(A)&(B), Title I Condition: 40 CFR 50.6(PM10 SIP), Title I Condition: 40 CFR pt. 52, subp. Y, Title I Condition: Avoid major modification under 40 CFR 52.21(b)(2) & Minn. R. 7007.3000, Title I Condition: Avoid major source under 40 CFR 52.21(b)(1)(i) & Minn. R. 7007.3000, To avoid major source under 40 CFR 70.2 & Minn. R. 7007.0200]

EQUI 6 Pneumatic Conveyance to Silo 4 5.9.1 Opacity <= 20 percent opacity. [Minn. R. 7011.0715, subp. 1(B)] 5.9.2 Particulate Matter <= 0.30 grains per dry standard cubic foot of exhaust gas unless required to further


5.9.3 The Permittee shall vent emissions from EQUI 6 to control equipment meeting the requirements of TREA 3 whenever EQUI 6 operates. This requirement expires upon startup of TREA 8 and/or TREA 14. [40 CFR pt. 51, Title I Condition: 40 CFR 50.6(PM10 SIP), Title I Condition: 40 CFR pt. 52, subp. Y, Title I Condition: Avoid major modification under 40 CFR 52.21(b)(2) & Minn. R. 7007.3000, Title I Condition: Avoid major source under 40 CFR 52.21(b)(1)(i) & Minn. R. 7007.3000, To avoid major source under 40 CFR 70.2 & Minn. R. 7007.0200]

5.9.4 Upon startup of TREA 8 and/or TREA 14: The Permittee shall vent emissions from EQUI 6 to control equipment meeting the requirements of TREA 8 and/or TREA 14 whenever EQUI 6 operates. [40 CFR pt. 51, Minn. R. 7007.0800, subp. 2(A)&(B), Title I Condition: 40 CFR 50.6(PM10 SIP), Title I Condition: 40 CFR pt. 52, subp. Y, Title I Condition: Avoid major modification under 40 CFR 52.21(b)(2) & Minn. R. 7007.3000, Title I Condition: Avoid major source under 40 CFR 52.21(b)(1)(i) and Minn. R. 7007.3000, To avoid major source under 40 CFR 70.2 & Minn. R. 7007.0200]




5.10.4 Upon startup of TREA 7: The Permittee shall vent emissions from EQUI 7 to control equipment


Requirement number Requirement and citation meeting the requirements of TREA 7 whenever EQUI 7 operates. [40 CFR pt. 51, Minn. R. 7007.0800, subp. 2(A)&(B), Title I Condition: 40 CFR 50.6(PM10 SIP), Title I Condition: 40 CFR pt. 52, subp. Y, Title I Condition: Avoid major modification under 40 CFR 52.21(b)(2) & Minn. R. 7007.3000, Title I Condition: Avoid major source under 40 CFR 52.21(b)(1)(i) and Minn. R. 7007.3000, To avoid major source under 40 CFR 70.2 & Minn. R. 7007.0200]










EQUI 11 Silo 3 5.14.1 Opacity <= 20 percent opacity. [Minn. R. 7011.0715, subp. 1(B)] 5.14.2 Particulate Matter <= 0.30 grains per dry standard cubic foot of exhaust gas unless required to further


5.14.3 The Permittee shall vent emissions from EQUI 11 to control equipment meeting the requirements of TREA 3 whenever EQUI 11 operates. This requirement expires upon startup of TREA 15. [40 CFR pt. 51, Title I Condition: 40 CFR 50.6(PM10 SIP), Title I Condition: 40 CFR pt. 52, subp. Y, Title I Condition: Avoid major modification under 40 CFR 52.21(b)(2) & Minn. R. 7007.3000, Title I Condition: Avoid


Requirement number Requirement and citation major source under 40 CFR 52.21(b)(1)(i) & Minn. R. 7007.3000, To avoid major source under 40 CFR 70.2 & Minn. R. 7007.0200]




5.14.7 Upon startup of the Project: Process Throughput: Daily Recordkeeping. On each day of operation the Permittee shall record and maintain the total quantity of all materials processed through EQUI 11. The records shall be based on the midnight to midnight calendar day period and the computer/ticketing system. This shall be recorded in written or electronic usage logs. [40 CFR pt. 51, Title I Condition: 40 CFR 50.6(PM10 SIP), Title I Condition: 40 CFR pt. 52, subp. Y]

5.14.8 Upon startup of the Project: PM < 10: Daily calculation. On each day of operation, for the previous day, the Permittee shall calculate, record, and maintain a record of the daily average lb/hr PM < 10 emissions from EQUI 11 using the following equation: PM < 10 = EF x TP / 24 x (750 / (2900 + 750)) Where: PM < 10 = the daily average PM < 10 emissions from the previous operating day, in lb/hour; EF = 0.0000863 lb PM < 10 / ton of throughput (emission factor from calculations at time of permit issuance) or from the most recent emission factor performance test for COMG 4; and TP = total daily EQUI 11 throughput for the previous calendar day, in ton/day. [Minn. R. 7007.0800, subps. 4-5]

5.14.9 Upon startup of the Project: PM < 2.5: Daily calculation. On each day of operation, for the previous day, the Permittee shall calculate, record, and maintain a record of the daily average lb/hr PM < 2.5 emissions from EQUI 11 using the following equation: PM < 2.5 = EF x TP / 24 x (750 / (2900 + 750)) Where: PM < 2.5 = the daily average PM < 2.5 emissions from the previous operating day, in lb/hour; EF = 0.0000863 lb PM < 2.5 / ton of throughput (emission factor from calculations at time of permit issuance) or from the most recent emission factor performance test for COMG 4; and TP = total daily EQUI 11 throughput for the previous calendar day, in ton/day. [Minn. R. 7007.0800, subps. 4-5]



5.15.3 The Permittee shall vent emissions from EQUI 12 to control equipment meeting the requirements of TREA 3 whenever EQUI 12 operates. This requirement expires upon startup of TREA 16. [40 CFR pt.


Requirement number Requirement and citation 51, Title I Condition: 40 CFR 50.6(PM10 SIP), Title I Condition: 40 CFR pt. 52, subp. Y, Title I Condition: Avoid major modification under 40 CFR 52.21(b)(2) & Minn. R. 7007.3000, Title I Condition: Avoid major source under 40 CFR 52.21(b)(1)(i) & Minn. R. 7007.3000, To avoid major source under 40 CFR 70.2 & Minn. R. 7007.0200]

5.15.4 Upon startup of TREA 16: The Permittee shall vent emissions from EQUI 12to control equipment meeting the requirements of TREA 16 whenever EQUI 12 operates. [40 CFR pt. 51, Minn. R. 7007.0800, subp. 2(A)&(B), Title I Condition: 40 CFR 50.6(PM10 SIP), Title I Condition: 40 CFR pt. 52, subp. Y, Title I Condition: Avoid major modification under 40 CFR 52.21(b)(2) & Minn. R. 7007.3000, Title I Condition: Avoid major source under 40 CFR 52.21(b)(1)(i) & Minn. R. 7007.3000, To avoid major source under 40 CFR 70.2 & Minn. R. 7007.0200]

FUGI 3 Paved Roads 5.16.1 The Permittee shall clean up commodities spilled on the driveway and other facility property as

required to minimize fugitive emissions. [Minn. R. 7011.1005, subp. 1(A)] 5.16.2 On each day of operation, the Permittee shall visually inspect all facility roads and parking areas to

minimize or eliminate fugitive emissions. The facility shall maintain records of this inspection that include the date of inspection, whether fugitive dust was observed, what corrective actions were taken, when the corrective actions were taken, and whether the corrective actions eliminated the fugitive dust. Inspection is not required when the roadway is wet, snow or ice covered, or during times of adverse weather conditions. [Minn. R. 7007.0800, subp. 2(A), Minn. R. 7007.0800, subp. 5, Minn. R. 7011.0150]

5.16.3 The Permittee shall sweep/clean all paved roads and parking areas at least once each calendar month. Anytime fugitive emissions are observed on facility paved surfaces, the Permittee shall immediately eliminate fugitive emissions by sweeping those road segments and/or applying water or a chemical dust suppressant. The Permittee must record the time, date, and location that the facility paved surfaces were swept/cleaned as well as the method for eliminating fugitive emissions, and whether the fugitive dust was eliminated. [Minn. R. 7007.0800, subp. 2(A), Minn. R. 7007.0800, subp. 5, Minn. R. 7011.0150]

TREA 1 Silo 6 Baghouse (existing) 5.17.1 Requirements for TREA 1 expire upon startup of TREA 5. [Minn. R. 7007.0800, subp. 2(A)] 5.17.2 The Permittee shall vent emissions from EQUI 1 to TREA 1 whenever EQUI 1 operates, and operate

and maintain TREA 1 at all times that any emissions are vented to TREA 1. The Permittee shall document periods of non-operation of the control equipment TREA 1 whenever EQUI 1 is operating. [40 CFR pt. 51, Title I Condition: 40 CFR 50.6(PM10 SIP), Title I Condition: 40 CFR pt. 52, subp. Y, Title I Condition: Avoid major modification under 40 CFR 52.21(b)(2) & Minn. R. 7007.3000, Title I Condition: Avoid major source under 40 CFR 52.21(b)(1)(i) & Minn. R. 7007.3000, To avoid major source under 40 CFR 70.2 & Minn. R. 7007.0200]

5.17.3 If the Permittee replaces TREA 1, the replacement control must meet or exceed the control efficiency requirements of TREA 1 as well as comply with all other requirements of TREA 1. Prior to making such a change, the Permittee shall apply for and obtain the appropriate permit amendment, as applicable. If no amendment is needed for the replacement, the Permittee shall submit an electronic notice to the Agency using Form CR-05. The notice must be received by the Agency seven working days prior to the commencement/start of replacement. [40 CFR pt. 51, Title I Condition: 40 CFR 50.6(PM10 SIP), Title I Condition: 40 CFR pt. 52, subp. Y, Title I Condition: Avoid major modification under 40 CFR 52.21(b)(2) & Minn. R. 7007.3000, Title I Condition: Avoid major source under 40 CFR 52.21(b)(1)(i) & Minn. R. 7007.3000, To avoid major source under 40 CFR 70.2 & Minn. R. 7007.0200]

5.17.4 The Permittee shall operate and maintain control equipment such that it achieves a control efficiency for Particulate Matter >= 99 percent control efficiency. [Title I Condition: Avoid major modification under 40 CFR 52.21(b)(2) & Minn. R. 7007.3000, Title I Condition: Avoid major source under 40 CFR


Requirement number Requirement and citation 52.21(b)(1)(i) & Minn. R. 7007.3000, To avoid major source under 40 CFR 70.2 & Minn. R. 7007.0200]

5.17.5 The Permittee shall operate and maintain control equipment such that it achieves a control efficiency for PM < 10 micron >= 93 percent control efficiency. [Title I Condition: Avoid major modification under 40 CFR 52.21(b)(2) & Minn. R. 7007.3000, Title I Condition: Avoid major source under 40 CFR 52.21(b)(1)(i) & Minn. R. 7007.3000, To avoid major source under 40 CFR 70.2 & Minn. R. 7007.0200]

5.17.6 The Permittee shall operate and maintain control equipment such that it achieves a control efficiency for PM < 2.5 micron >= 93 percent control efficiency. [To avoid major source under 40 CFR 70.2 & Minn. R. 7007.0200]

5.17.7 The Permittee shall operate and maintain the fabric filter in accordance with the Operation and Maintenance (O & M) Plan. The Permittee shall keep copies of the O & M Plan available onsite for use by staff and MPCA staff. [Minn. R. 7007.0800, subp. 14]

5.17.8 Visible Emissions: The Permittee shall check the fabric filter stack STRU 1 for any visible emissions once each day of operation during daylight hours. [40 CFR pt. 51, Minn. R. 7007.0800, subps. 4-5, Title I Condition: 40 CFR 50.6(PM10 SIP), Title I Condition: 40 CFR pt. 52, subp. Y]

5.17.9 Recordkeeping of Visible Emissions: The Permittee shall record every 24 hours during operation the time and date of each visible emission inspection and whether or not any visible emissions were observed, and take the appropriate corrective actions. The permittee shall record every calendar day the total time the emission unit is in operation during that calendar day. [40 CFR pt. 51, Title I Condition: 40 CFR 50.6(PM10 SIP), Title I Condition: 40 CFR pt. 52, subp. Y]

5.17.10 Recordkeeping of Pressure Drop. The Permittee shall record every 24 hours, if in operation, the time and date of each pressure drop reading and whether or not the recorded pressure drop was within the range specified in this permit and take the appropriate corrective actions. If pressure drop range exceed the permitted limit, the Permittee shall report it as a deviation in the Company's semiannual report. The permittee shall record every calendar day the total time the emission unit is in operation during that calendar day. [40 CFR pt. 51, Title I Condition: 40 CFR 50.6(PM10 SIP), Title I Condition: 40 CFR pt. 52, subp. Y]

5.17.11 Corrective Actions: The Permittee shall take corrective action as soon as possible if any of the following occur: - visible emissions are observed; - the recorded pressure drop is outside the required operating range; or - the fabric filter or any of its components are found during the inspections to need repair. Corrective actions shall return the pressure drop to within the permitted range, eliminate visible emissions, and/or include completion of necessary repairs identified during the inspection, as applicable. Corrective actions include, but are not limited to, those outlined in the O & M Plan for the fabric filter. The Permittee shall keep a record of the type and date of any corrective action taken for each filter. [Minn. R. 7007.0800, subp. 14, Minn. R. 7007.0800, subp. 2(A), Minn. R. 7007.0800, subp. 5]

5.17.12 Monitoring Equipment: The Permittee shall install and maintain the necessary monitoring equipment for measuring and recording pressure drop as required by this permit. The monitoring equipment must be installed, in use, and properly maintained when the monitored fabric filter is in operation. [Minn. R. 7007.0800, subp. 4]

5.17.13 The Permittee shall calibrate or replace the pressure drop monitor at least once every 12 months and shall maintain a written record of any action resulting from the calibration. [Minn. R. 7007.0800, subp. 14, Minn. R. 7007.0800, subp. 4, Minn. R. 7007.0800, subp. 5]

5.17.14 Periodic Inspections: At least once per calendar quarter, or more frequently as required by the manufacturing specifications, the Permittee shall inspect the control equipment components. The


Requirement number Requirement and citation Permittee shall maintain a written record of these inspections. [Minn. R. 7007.0800, subp. 14, Minn. R. 7007.0800, subp. 4, Minn. R. 7007.0800, subp. 5]

5.17.15 Pressure Drop >= 0.5 and <= 6.0 inches of water, unless a new range is set pursuant to Minn. R. 7017.2025, subp. 3 based on the values recorded during the most recent MPCA-approved performance test where compliance was demonstrated. The new range shall be implemented upon receipt of the Notice of Compliance letter granting preliminary approval. The range is final upon issuance of a permit amendment incorporating the change. If the recorded pressure drop is outside the required range, the emissions during that time shall be considered uncontrolled until the pressure drop is once again within the required range. The period of time for which the pressure drop is considered out of range shall be reported as a deviation. The Permittee shall record the pressure drop at least once every 24 hours when in operation. [40 CFR pt. 51, Title I Condition: 40 CFR 50.6(PM10 SIP), Title I Condition: 40 CFR pt. 52, subp. Y]




5.18.4 The Permittee shall operate and maintain control equipment such that it achieves a control efficiency for Particulate Matter >= 99 percent control efficiency. [Title I Condition: Avoid major modification under 40 CFR 52.21(b)(2) & Minn. R. 7007.3000, Title I Condition: Avoid major source under 40 CFR 52.21(b)(1)(i) & Minn. R. 7007.3000, To avoid major source under 40 CFR 70.2 & Minn. R. 7007.0200]




5.18.8 Visible Emissions: The Permittee shall check the fabric filter stack (STRU 2) for any visible emissions once each day of operation during daylight hours. [40 CFR pt. 51, Minn. R. 7007.0800, subps. 4-5, Title I Condition: 40 CFR 50.6(PM10 SIP), Title I Condition: 40 CFR pt. 52, subp. Y]


Requirement number Requirement and citation 5.18.9 Recordkeeping of Visible Emissions: The Permittee shall record every 24 hours during operation the

time and date of each visible emission inspection and whether or not any visible emissions were observed, and take the appropriate corrective actions. The permittee shall record every calendar day the total time the emission unit is in operation during that calendar day. [40 CFR pt. 51, Title I Condition: 40 CFR 50.6(PM10 SIP), Title I Condition: 40 CFR pt. 52, subp. Y]





5.18.14 Periodic Inspections: At least once per calendar quarter, or more frequently as required by the manufacturing specifications, the Permittee shall inspect the control equipment components. The Permittee shall maintain a written record of these inspections. [Minn. R. 7007.0800, subp. 14, Minn. R. 7007.0800, subp. 4, Minn. R. 7007.0800, subp. 5]


TREA 3 Truck Loading and COMG 1 Baghouse (existing)


Requirement number Requirement and citation 5.19.1 Requirements for TREA 3 expire upon startup of TREAs 7, 8, 9, 14, 15, and 16. [Minn. R. 7007.0800,

subp. 2(A)] 5.19.2 The Permittee shall vent emissions from EQUI 4, EQUI 6, EQUI 7, EQUI 11, and/or EQUI 12 to TREA 3

whenever EQUI 4, EQUI 6, EQUI 7, EQUI 11, and/or EQUI 12 operates, and operate and maintain TREA 3 at all times that any emissions are vented to TREA 3. The Permittee shall document periods of non-operation of the control equipment TREA 3 whenever EQUI 4, EQUI 6, EQUI 7, EQUI 11, and/or EQUI 12 is operating. Upon startup of TREA 7, TREA 8, TREA 9, TREA 14, TREA 15, and/or TREA 16: The Permittee shall vent emissions from EQUI 4, EQUI 6, EQUI 7, EQUI 11, and/or EQUI 12 to TREA 9, TREA 8 and/or TREA 14, TREA 7, TREA 15, and TREA 16, respectively whenever EQUI 4, EQUI 6, EQUI 7, EQUI 11, and/or EQUI 12 operates, and operate and maintain TREA 7, TREA 8, TREA 9, TREA 14, TREA 15, and TREA 16 at all times that any emissions are vented to them. The Permittee shall document periods of non-operation of the control equipment listed above whenever EQUI 4, EQUI 6, EQUI 7, EQUI 11, and/or EQUI 12 is operating. See additional requirements at TREA 7, TREA 8, TREA 9, TREA 14, TREA 15, and TREA 16. [40 CFR pt. 51, Title I Condition: 40 CFR 50.6(PM10 SIP), Title I Condition: 40 CFR pt. 52, subp. Y, Title I Condition: Avoid major modification under 40 CFR 52.21(b)(2) & Minn. R. 7007.3000, Title I Condition: Avoid major source under 40 CFR 52.21(b)(1)(i) & Minn. R. 7007.3000, To avoid major source under 40 CFR 70.2 & Minn. R. 7007.0200]







5.19.9 Recordkeeping of Pressure Drop. The Permittee shall record every 24 hours, if in operation, the time and date of each pressure drop reading and whether or not the recorded pressure drop was within the range specified in this permit and take the appropriate corrective actions.


Requirement number Requirement and citation If pressure drop range exceed the permitted limit, the Permittee shall report it as a deviation in the Company's semiannual report. The permittee shall record every calendar day the total time the emission unit is in operation during that calendar day. [40 CFR pt. 51, Title I Condition: 40 CFR 50.6(PM10 SIP), Title I Condition: 40 CFR pt. 52, subp. Y]







TREA 5 Silo 6 Baghouse 5.20.1 The Permittee shall vent emissions from EQUI 1 to TREA 5 whenever EQUI 1 operates, and operate

and maintain TREA 5 at all times that any emissions are vented to TREA 5. The Permittee shall document periods of non-operation of the control equipment TREA 5 whenever EQUI 1 is operating.


Requirement number Requirement and citation [40 CFR pt. 51, Minn. R. 7007.0800, subp. 2(A)&(B), Title I Condition: 40 CFR 50.6(PM10 SIP), Title I Condition: 40 CFR pt. 52, subp. Y, Title I Condition: Avoid major modification under 40 CFR 52.21(b)(2) & Minn. R. 7007.3000, Title I Condition: Avoid major source under 40 CFR 52.21(b)(1)(i) & Minn. R. 7007.3000, To avoid major source under 40 CFR 70.2 & Minn. R. 7007.0200]

5.20.2 If the Permittee replaces TREA 5, the replacement control must meet or exceed the control efficiency requirements of TREA 5 as well as comply with all other requirements of TREA 5. Prior to making such a change, the Permittee shall apply for and obtain the appropriate permit amendment, as applicable. If no amendment is needed for the replacement, the Permittee shall submit an electronic notice to the Agency using Form CR-05. The notice must be received by the Agency seven working days prior to the commencement/start of replacement. [40 CFR pt. 51, Minn. R. 7007.0800, subp. 2(A)&(B), Title I Condition: 40 CFR 50.6(PM10 SIP), Title I Condition: 40 CFR pt. 52, subp. Y, Title I Condition: Avoid major modification under 40 CFR 52.21(b)(2) & Minn. R. 7007.3000, Title I Condition: Avoid major source under 40 CFR 52.21(b)(1)(i) & Minn. R. 7007.3000, To avoid major source under 40 CFR 70.2 & Minn. R. 7007.0200]








5.20.10 Corrective Actions: The Permittee shall take corrective action as soon as possible if any of the following occur:


Requirement number Requirement and citation - visible emissions are observed; - the recorded pressure drop is outside the required operating range; or - the fabric filter or any of its components are found during the inspections to need repair. Corrective actions shall return the pressure drop to within the permitted range, eliminate visible emissions, and/or include completion of necessary repairs identified during the inspection, as applicable. Corrective actions include, but are not limited to, those outlined in the O & M Plan for the fabric filter. The Permittee shall keep a record of the type and date of any corrective action taken for each filter. [Minn. R. 7007.0800, subp. 14, Minn. R. 7007.0800, subp. 2(A), Minn. R. 7007.0800, subp. 5]





TREA 6 Silo 5 Baghouse 5.21.1 The Permittee shall vent emissions from EQUI 2 to TREA 6whenever EQUI 2 operates, and operate

and maintain TREA 6 at all times that any emissions are vented to TREA 6. The Permittee shall document periods of non-operation of the control equipment TREA 6 whenever EQUI 2 is operating. [40 CFR pt. 51, Minn. R. 7007.0800, subp. 2(A)&(B), Title I Condition: 40 CFR 50.6(PM10 SIP), Title I Condition: 40 CFR pt. 52, subp. Y, Title I Condition: Avoid major modification under 40 CFR 52.21(b)(2) & Minn. R. 7007.3000, Title I Condition: Avoid major source under 40 CFR 52.21(b)(1)(i) & Minn. R. 7007.3000, To avoid major source under 40 CFR 70.2 & Minn. R. 7007.0200]

5.21.2 If the Permittee replaces TREA 6, the replacement control must meet or exceed the control efficiency requirements of TREA 6 as well as comply with all other requirements of TREA 6. Prior to making such a change, the Permittee shall apply for and obtain the appropriate permit amendment, as applicable. If no amendment is needed for the replacement, the Permittee shall submit an electronic notice to the Agency using Form CR-05. The notice must be received by the Agency seven working days prior to the commencement/start of replacement. [40 CFR pt. 51, Minn. R. 7007.0800, subp. 2(A) &(B), Title I Condition: 40 CFR 50.6(PM10 SIP), Title I Condition: 40 CFR pt. 52, subp. Y, Title I Condition: Avoid major modification under 40 CFR 52.21(b)(2) & Minn. R. 7007.3000, Title I Condition: Avoid major source under 40 CFR 52.21(b)(1)(i) & Minn. R. 7007.3000, To avoid major source under 40 CFR 70.2 & Minn. R. 7007.0200]


Requirement number Requirement and citation 5.21.3 The Permittee shall operate and maintain control equipment such that it achieves a control efficiency

for Particulate Matter >= 99 percent control efficiency. [Title I Condition: Avoid major modification under 40 CFR 52.21(b)(2) & Minn. R. 7007.3000, Title I Condition: Avoid major source under 40 CFR 52.21(b)(1)(i) & Minn. R. 7007.3000, To avoid major source under 40 CFR 70.2 & Minn. R. 7007.0200]









5.21.12 The Permittee shall calibrate or replace the pressure drop monitor at least once every 12 months and shall maintain a written record of any action resulting from the calibration. [Minn. R. 7007.0800,


Requirement number Requirement and citation subp. 14, Minn. R. 7007.0800, subp. 4, Minn. R. 7007.0800, subp. 5]


5.21.14 Pressure Drop >= 0.5 and <= 6.0 inches of water, unless a new range is set pursuant to Minn. R. 7017.2025, subp. 3 based on the values recorded during the most recent MPCA-approved performance test where compliance was demonstrated. The new range shall be implemented upon receipt of the Notice of Compliance letter granting preliminary approval. The range is final upon issuance of a permit amendment incorporating the change. If the recorded pressure drop is outside the required range, the emissions during that time shall be considered uncontrolled until the pressure drop is once again within the required range. The period of time for which the pressure drop is considered out of range shall be reported as a deviation. The Permittee shall record the pressure drop at least once every 24 hours when in operation. [40 CFR pt. 51, Title I Condition: 40 CFR 50.6(PM10 SIP)]

TREA 7 Silo 1 Baghouse 5.22.1 Upon startup of TREA 7: The Permittee shall vent emissions from EQUI 7 to TREA 7 whenever EQUI 7

operates, and operate and maintain TREA 7 at all times that any emissions are vented to TREA 7. The Permittee shall document periods of non-operation of the control equipment TREA 7 whenever EQUI 7 is operating. [40 CFR pt. 51, Minn. R. 7007.0800, subp. 2(A)&(B), Title I Condition: 40 CFR 50.6(PM10 SIP), Title I Condition: 40 CFR pt. 52, subp. Y, Title I Condition: Avoid major modification under 40 CFR 52.21(b)(2) & Minn. R. 7007.3000, Title I Condition: Avoid major source under 40 CFR 52.21(b)(1)(i) & Minn. R. 7007.3000, To avoid major source under 40 CFR 70.2 & Minn. R. 7007.0200]















5.22.14 Pressure Drop >= 0.5 and <= 6.0 inches of water, unless a new range is set pursuant to Minn. R. 7017.2025, subp. 3 based on the values recorded during the most recent MPCA-approved performance test where compliance was demonstrated. The new range shall be implemented upon receipt of the Notice of Compliance letter granting preliminary approval. The range is final upon issuance of a permit amendment incorporating the change. If the recorded pressure drop is outside the required range, the emissions during that time shall be considered uncontrolled until the pressure drop is once again within the required range. The period of time for which the pressure drop is considered out of range shall be reported as a deviation. The


Requirement number Requirement and citation Permittee shall record the pressure drop at least once every 24 hours when in operation. [40 CFR pt. 51, Title I Condition: 40 CFR 50.6(PM10 SIP), Title I Condition: 40 CFR pt. 52, subp. Y]

TREA 8 Silo 4 Baghouse 5.23.1 Upon startup of TREA 8: The Permittee shall vent emissions from EQUI 6 to TREA 8 and/or TREA 14

whenever EQUI 6 operates, and operate and maintain TREA 8 and/or TREA 14 at all times that any emissions are vented to TREA 8 and/or TREA 14. The Permittee shall document periods of non-operation of the control equipment TREA 8 and/or TREA 14 whenever EQUI 6 is operating. [40 CFR pt. 51, Minn. R. 7007.0800, subp. 2(A)&(B), Title I Condition: 40 CFR 50.6(PM10 SIP), Title I Condition: 40 CFR pt. 52, subp. Y, Title I Condition: Avoid major modification under 40 CFR 52.21(b)(2) & Minn. R. 7007.3000, Title I Condition: Avoid major source under 40 CFR 52.21(b)(1)(i) & Minn. R. 7007.3000, To avoid major source under 40 CFR 70.2 & Minn. R. 7007.0200]
















TREA 9 Truck Loading Baghouse 5.24.1 Upon startup of TREA 9: The Permittee shall vent emissions from EQUI 4 to TREA 9 whenever EQUI 4

operates, and operate and maintain TREA 9 at all times that any emissions are vented to TREA 9. The Permittee shall document periods of non-operation of the control equipment TREA 9whenever EQUI 4 is operating. [40 CFR pt. 51, Minn. R. 7007.0800, subp. 2(A)&(B), Title I Condition: 40 CFR 50.6(PM10 SIP), Title I Condition: 40 CFR pt. 52, subp. Y, Title I Condition: Avoid major modification under 40 CFR 52.21(b)(2) & Minn. R. 7007.3000, Title I Condition: Avoid major source under 40 CFR 52.21(b)(1)(i) & Minn. R. 7007.3000, To avoid major source under 40 CFR 70.2 & Minn. R. 7007.0200]

5.24.2 If the Permittee replaces TREA 9, the replacement control must meet or exceed the control efficiency requirements of TREA 9 as well as comply with all other requirements of TREA 9. Prior to making such a change, the Permittee shall apply for and obtain the appropriate permit amendment, as applicable.


Requirement number Requirement and citation If no amendment is needed for the replacement, the Permittee shall submit an electronic notice to the Agency using Form CR-05. The notice must be received by the Agency seven working days prior to the commencement/start of replacement. [40 CFR pt. 51, Minn. R. 7007.0800, subp. 2(A)&(B), Title I Condition: 40 CFR 50.6(PM10 SIP), Title I Condition: 40 CFR pt. 52, subp. Y, Title I Condition: Avoid major modification under 40 CFR 52.21(b)(2) & Minn. R. 7007.3000, Title I Condition: Avoid major source under 40 CFR 52.21(b)(1)(i) & Minn. R. 7007.3000, To avoid major source under 40 CFR 70.2 & Minn. R. 7007.0200]








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


Requirement number Requirement and citation each filter. [Minn. R. 7007.0800, subp. 14, Minn. R. 7007.0800, subp. 2(A), Minn. R. 7007.0800, subp. 5]





TREA 10 Bucket Elevator Baghouse 5.25.1 The Permittee shall vent emissions from EQUI 5 to TREA 10 whenever EQUI 5 operates, and operate




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


Requirement number Requirement and citation for PM < 10 micron >= 93 percent control efficiency. [Title I Condition: Avoid major modification under 40 CFR 52.21(b)(2) & Minn. R. 7007.3000, Title I Condition: Avoid major source under 40 CFR 52.21(b)(1)(i) & Minn. R. 7007.3000, To avoid major source under 40 CFR 70.2 & Minn. R. 7007.0200]











Requirement number Requirement and citation 5.25.14 Pressure Drop >= 0.5 and <= 6.0 inches of water, unless a new range is set pursuant to Minn. R.

7017.2025, subp. 3 based on the values recorded during the most recent MPCA-approved performance test where compliance was demonstrated. The new range shall be implemented upon receipt of the Notice of Compliance letter granting preliminary approval. The range is final upon issuance of a permit amendment incorporating the change. If the recorded pressure drop is outside the required range, the emissions during that time shall be considered uncontrolled until the pressure drop is once again within the required range. The period of time for which the pressure drop is considered out of range shall be reported as a deviation. The Permittee shall record the pressure drop at least once every 24 hours when in operation. [40 CFR pt. 51, Title I Condition: 40 CFR 50.6(PM10 SIP), Title I Condition: 40 CFR pt. 52, subp. Y]








5.26.7 Recordkeeping of Visible Emissions: The Permittee shall record every 24 hours during operation the time and date of each visible emission inspection and whether or not any visible emissions were observed, and take the appropriate corrective actions.


Requirement number Requirement and citation The permittee shall record every calendar day the total time the emission unit is in operation during that calendar day. [40 CFR pt. 51, Title I Condition: 40 CFR 50.6(PM10 SIP), Title I Condition: 40 CFR pt. 52, subp. Y]










Requirement number Requirement and citation and maintain TREA 12 at all times that any emissions are vented to TREA 12. The Permittee shall document periods of non-operation of the control equipment TREA 12 whenever EQUI 9 is operating. [40 CFR pt. 51, Minn. R. 7007.0800, subp. 2(A)&(B), Title I Condition: 40 CFR 50.6(PM10 SIP), Title I Condition: 40 CFR pt. 52, subp. Y, Title I Condition: Avoid major modification under 40 CFR 52.21(b)(2) & Minn. R. 7007.3000, Title I Condition: Avoid major source under 40 CFR 52.21(b)(1)(i) & Minn. R. 7007.3000, To avoid major source under 40 CFR 70.2 & Minn. R. 7007.0200]








5.27.9 Recordkeeping of Pressure Drop. The Permittee shall record every 24 hours, if in operation, the time and date of each pressure drop reading and whether or not the recorded pressure drop was within the range specified in this permit and take the appropriate corrective actions. If pressure drop range exceed the permitted limit, the Permittee shall report it as a deviation in the Company's semiannual report. The permittee shall record every calendar day the total time the emission unit is in operation during that calendar day. [40 CFR pt. 51, Title I Condition: 40 CFR 50.6(PM10 SIP), Title I Condition: 40 CFR pt.


Requirement number Requirement and citation 52, subp. Y]






TREA 13 Silo 7 Baghouse 5.28.1 The Permittee shall vent emissions from EQUI 10 to TREA 13 whenever EQUI 10 operates, and

operate and maintain TREA 13 at all times that any emissions are vented to TREA 13. The Permittee shall document periods of non-operation of the control equipment TREA 13 whenever EQUI 10 is operating. [40 CFR pt. 51, Minn. R. 7007.0800, subp. 2(A)&(B), Title I Condition: 40 CFR 50.6(PM10 SIP), Title I Condition: 40 CFR pt. 52, subp. Y, Title I Condition: Avoid major modification under 40 CFR 52.21(b)(2) & Minn. R. 7007.3000, Title I Condition: Avoid major source under 40 CFR 52.21(b)(1)(i) & Minn. R. 7007.3000, To avoid major source under 40 CFR 70.2 & Minn. R. 7007.0200]

5.28.2 If the Permittee replaces TREA 13, the replacement control must meet or exceed the control efficiency requirements of TREA 13 as well as comply with all other requirements of TREA 13. Prior to making such a change, the Permittee shall apply for and obtain the appropriate permit amendment, as applicable. If no amendment is needed for the replacement, the Permittee shall submit an electronic notice to the Agency using Form CR-05. The notice must be received by the Agency seven working days prior to


Requirement number Requirement and citation the commencement/start of replacement. [40 CFR pt. 51, Minn. R. 7007.0800, subp. 2(A)&(B), Title I Condition: 40 CFR 50.6(PM10 SIP), Title I Condition: 40 CFR pt. 52, subp. Y, Title I Condition: Avoid major modification under 40 CFR 52.21(b)(2) & Minn. R. 7007.3000, Title I Condition: Avoid major source under 40 CFR 52.21(b)(1)(i) & Minn. R. 7007.3000, To avoid major source under 40 CFR 70.2 & Minn. R. 7007.0200]






5.28.8 Visible Emissions: The Permittee shall check the fabric filter stack (STRU 15) for any visible emissions once each day of operation during daylight hours. [Minn. R. 7007.0800, subps. 4-5, Title I Condition: 40 CFR 50.6(PM10 SIP), Title I Condition: 40 CFR pt. 52, subp. Y]



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


Requirement number Requirement and citation for measuring and recording pressure drop as required by this permit. The monitoring equipment must be installed, in use, and properly maintained when the monitored fabric filter is in operation. [Minn. R. 7007.0800, subp. 4]




TREA 14 Silo 4 Second Baghouse 5.29.1 Upon startup of TREA 14: The Permittee shall vent emissions from EQUI 6 to TREA 8 and/or TREA 14




5.29.4 The Permittee shall operate and maintain control equipment such that it achieves a control efficiency for PM < 10 micron >= 93 percent control efficiency. [Title I Condition: Avoid major modification under 40 CFR 52.21(b)(2) & Minn. R. 7007.3000, Title I Condition: Avoid major source under 40 CFR












5.29.14 Pressure Drop >= 0.5 and <= 6.0 inches of water, unless a new range is set pursuant to Minn. R. 7017.2025, subp. 3 based on the values recorded during the most recent MPCA-approved


Requirement number Requirement and citation performance test where compliance was demonstrated. The new range shall be implemented upon receipt of the Notice of Compliance letter granting preliminary approval. The range is final upon issuance of a permit amendment incorporating the change. If the recorded pressure drop is outside the required range, the emissions during that time shall be considered uncontrolled until the pressure drop is once again within the required range. The period of time for which the pressure drop is considered out of range shall be reported as a deviation. The Permittee shall record the pressure drop at least once every 24 hours when in operation. [40 CFR pt. 51, Title I Condition: 40 CFR 50.6(PM10 SIP), Title I Condition: 40 CFR pt. 52, subp. Y]

TREA 15 Silo 3 Baghouse 5.30.1 Upon startup of TREA 15: The Permittee shall vent emissions from EQUI 11 to TREA 15 whenever

EQUI 11 operates, and operate and maintain TREA 15 at all times that any emissions are vented to TREA 15. The Permittee shall document periods of non-operation of the control equipment TREA 15 whenever EQUI 11 is operating. [40 CFR pt. 51, Minn. R. 7007.0800, subp. 2(A)&(B), Title I Condition: 40 CFR 50.6(PM10 SIP), Title I Condition: 40 CFR pt. 52, subp. Y, Title I Condition: Avoid major modification under 40 CFR 52.21(b)(2) & Minn. R. 7007.3000, Title I Condition: Avoid major source under 40 CFR 52.21(b)(1)(i) & Minn. R. 7007.3000, To avoid major source under 40 CFR 70.2 & Minn. R. 7007.0200]






5.30.7 Recordkeeping of Visible Emissions: The Permittee shall record every 24 hours during operation the time and date of each visible emission inspection and whether or not any visible emissions were observed, and take the appropriate corrective actions. The permittee shall record every calendar day the total time the emission unit is in operation during


Requirement number Requirement and citation that calendar day. [40 CFR pt. 51, Title I Condition: 40 CFR 50.6(PM10 SIP), Title I Condition: 40 CFR pt. 52, subp. Y]









EQUI 12 operates, and operate and maintain TREA 16 at all times that any emissions are vented to


Requirement number Requirement and citation TREA 16. The Permittee shall document periods of non-operation of the control equipment TREA 16 whenever EQUI 11 is operating. [40 CFR pt. 51, Minn. R. 7007.0800, subp. 2(A)&(B), Title I Condition: 40 CFR 50.6(PM10 SIP), Title I Condition: 40 CFR pt. 52, subp. Y, Title I Condition: Avoid major modification under 40 CFR 52.21(b)(2) & Minn. R. 7007.3000, Title I Condition: Avoid major source under 40 CFR 52.21(b)(1)(i) & Minn. R. 7007.3000, To avoid major source under 40 CFR 70.2 & Minn. R. 7007.0200]
















6. Submittal/action requirements

This section lists most of the submittals required by this permit. Please note that some submittal requirements may appear in the Limits and Other Requirements section, or, if applicable, within a Compliance Schedule section.

Requirement number Requirement and citation TFAC 1 Childs Road Terminal 6.1.1 PM10 Performance Test Corrective Actions: The Permittee shall submit a computer dispersion

modeling protocol for PM10 refined modeling : Due 180 days after the Permittee receives a 2nd notice of noncompliance (NON) from the MPCA stating that they have failed to pass the PM10 emission rate performance test at COMG 2, COMG 4, and/or EQUI 4. Upon receipt of the first NON, the Permittee will retest one more time to measure emissions.


Requirement number Requirement and citation The protocol will describe the proposed modeling methodology and input data, in accordance with MPCA modeling guidance for Title V air dispersion modeling analyses. [40 CFR pt. 51, Minn. R. 7007.0800, subp. 2(A)&(B), Minn. R. 7009.0020-7009.0090, Minn. Stat. 116.07, subd. 4a(a), Title I Condition: 40 CFR 50.6(PM10 SIP), Title I Condition: 40 CFR pt. 52, subp. Y]

6.1.2 PM < 10 micron: The Permittee shall submit computer dispersion modeling results due 270 calendar days after the Permittee receives a 2nd notice of noncompliance (NON) from the MPCA stating that they have failed to pass the PM10 emission rate performance test at COMG 2, COMG 4, and/or EQUI 4. [40 CFR pt. 51, Minn. R. 7007.0800, subp. 2(A) & (B), Minn. R. 7009.0020-7009.0090, Minn. Stat. 116.07, subd. 4a(a), Title I Condition: 40 CFR 50.6(PM10 SIP), Title I Condition: 40 CFR pt. 52, subp. Y]

6.1.3 PM2.5 Performance Test Corrective Actions: The Permittee shall submit a computer dispersion modeling protocol for PM2.5 refined modeling : Due 180 days after the Permittee receives a 2nd notice of noncompliance (NON) from the MPCA stating that they have failed to pass the PM2.5 emission rate performance test at COMG 2, COMG 4, and/or EQUI 4. Upon receipt of the first NON, the Permittee will retest one more time to measure emissions. The protocol will describe the proposed modeling methodology and input data, in accordance with MPCA modeling guidance for Title V air dispersion modeling analyses. [Minn. R. 7007.0800, subp. 2(A) & (B), Minn. R. 7009.0020-7009.0090, Minn. Stat. 116.07, subd. 4a(a)]

6.1.4 PM < 2.5 micron: The Permittee shall submit computer dispersion modeling results due 270 calendar days after the Permittee receives a 2nd notice of noncompliance (NON) from the MPCA stating that they have failed to pass the PM2.5 emission rate performance test at COMG 2, COMG 4, and/or EQUI 4. [Minn. R. 7007.0800, subp. 2(A) & (B), Minn. R. 7009.0020-7009.0090, Minn. Stat. 116.07, subd. 4a(a)]

6.1.5 Annual Report for SIP: due 30 days after end of each calendar year following Permit Issuance to the Commissioner. The report shall contain the following information: a record of data used in calculating PM10 emissions, and calculations of the PM10 emissions; a record of each unscheduled startup, shutdown, and breakdown of process and control equipment; a summary record of excess PM10 emissions, opacity exceedances and noncompliance with fugitive emissions requirements (or the Permittee shall state if no exceedances, and noncompliance conditions occurred in the calendar year). [40 CFR pt. 51, Title I Condition: 40 CFR 50.6(PM10 SIP), Title I Condition: 40 CFR pt. 52, subp. Y]

6.1.6 The Permittee must submit a semiannual deviations report : Due semiannually, by the 30th of January and July. The first semiannual report submitted by the Permittee must cover the calendar half-year in which the permit is issued. The first report of each calendar year covers January 1 - June 30. The second report of each calendar year covers July 1 - December 31. Submit this on form DRF-2 (Deviation Reporting Form). If no deviations have occurred, submit the signed report certifying that there were no deviations. [Minn. R. 7007.0800, subp. 6(B)(2)]

6.1.7 The Permittee must submit a compliance certification : Due annually, by the 31st of January (for the previous calendar year). Submit this on form CR-04 (Annual Compliance Certification Report). This report covers all deviations experienced during the calendar year. If no deviations have occurred, submit the signed report certifying that there were no deviations. [Minn. R. 7007.0800, subp. 6(D)]

6.1.8 The Permittee shall submit a notification of the actual date of startup of the Project: Due 15 calendar days after startup. Startup of the Project is defined as the startup of EQUI 5, EQUI 8, EQUI 9, and/or EQUI 10. The notification shall be submitted electronically on Form CS-02. [Minn. R. 7007.0800, subp. 16(L)]

COMG 2 Unloading Silos 6.2.1 PM < 10 micron: The Permittee shall conduct an initial performance test due 180 calendar days after

startup of the Project and at a minimum every 60 months thereafter to verify the emission factor of 0.0000863 lb/ton.


Requirement number Requirement and citation The Commissioner will set the subsequent test frequency as stated in a Notice of Compliance (NOC) or Notice of Verification (NOV) letter with review of the initial performance test. Subsequent tests shall be completed no less than every 60-months by the due date (month and day) based on the initial test date or more frequently as stated in the NOC/NOV letter. If the Commissioner sets a test frequency at less than every 60 months, the Permittee must apply for an administrative amendment to incorporate the prescribed test frequency into the permit. A major amendment is required to reduce the test frequency once set in the permit. The performance test shall be conducted at worst-case conditions defined at Minn. R. 7017.2005, subp. 8 or at the operating conditions described at Minn. R. 7017.2025, subp. 2, using EPA Reference Methods 201A and 202, or other method approved by MPCA in the performance test plan approval. Testing shall be completed on two members of COMG 2. Testing shall be completed on a rotating basis such that no single silo within COMG 2 is tested twice before all other silos have been tested once. Testing conducted during the 60 days prior to a performance test due date will not reset the due date for future testing. Testing conducted more than 60 days prior to the specified due date satisfies this test due date requirement but will reset future performance test due dates based on the most recent performance test date. [40 CFR pt. 51, Minn. R. 7007.0800, subp. 2(A) & (B), Minn. R. 7017.2020, subp. 1, Title I Condition: 40 CFR 50.6(PM10 SIP), Title I Condition: 40 CFR pt. 52, subp. Y]

6.2.2 PM < 2.5 micron: The Permittee shall conduct an initial performance test due 180 calendar days after startup of the Project and at a minimum every 60 months thereafter to verify the emission factor of 0.0000863 lb/ton. The Commissioner will set the subsequent test frequency as stated in a Notice of Compliance (NOC) or Notice of Verification (NOV) letter with review of the initial performance test. Subsequent tests shall be completed no less than every 60-months by the due date (month and day) based on the initial test date or more frequently as stated in the NOC/NOV letter. If the Commissioner sets a test frequency at less than every 60 months, the Permittee must apply for an administrative amendment to incorporate the prescribed test frequency into the permit. A major amendment is required to reduce the test frequency once set in the permit. The performance test shall be conducted at worst-case conditions defined at Minn. R. 7017.2005, subp. 8 or at the operating conditions described at Minn. R. 7017.2025, subp. 2, using EPA Reference Methods 201A and 202, or other method approved by MPCA in the performance test plan approval. Testing shall be completed on two members of COMG 2. Testing shall be completed on a rotating basis such that no single silo within COMG 2 is tested twice before all other silos have been tested once. Testing conducted during the 60 days prior to a performance test due date will not reset the due date for future testing. Testing conducted more than 60 days prior to the specified due date satisfies this test due date requirement but will reset future performance test due dates based on the most recent performance test date. [Minn. R. 7007.0800, subp. 2(A) & (B), Minn. R. 7017.2020, subp. 1]


Requirement number Requirement and citation 6.2.3 PM < 10 micron: The Permittee shall conduct an initial performance test due 180 calendar days after

startup of the Project and at a minimum every 60 months thereafter to measure emissions. The Commissioner will set the subsequent test frequency as stated in a Notice of Compliance (NOC) or Notice of Verification (NOV) letter with review of the initial performance test. Subsequent tests shall be completed no less than every 60-months by the due date (month and day) based on the initial test date or more frequently as stated in the NOC/NOV letter. If the Commissioner sets a test frequency at less than every 60 months, the Permittee must apply for an administrative amendment to incorporate the prescribed test frequency into the permit. A major amendment is required to reduce the test frequency once set in the permit. The performance test shall be conducted at worst-case conditions defined at Minn. R. 7017.2005, subp. 8 or at the operating conditions described at Minn. R. 7017.2025, subp. 2, using EPA Reference Methods 201A and 202, or other method approved by MPCA in the performance test plan approval. Testing shall be completed on two members of COMG 2. Testing shall be completed on a rotating basis such that no single silo within COMG 2 is tested twice before all other silos have been tested once. Testing conducted during the 60 days prior to a performance test due date will not reset the due date for future testing. Testing conducted more than 60 days prior to the specified due date satisfies this test due date requirement but will reset future performance test due dates based on the most recent performance test date. See PM10 Performance Test Corrective Actions requirement under section 6 at TFAC 1. [40 CFR pt. 51, Minn. R. 7007.0800, subp. 2(A)&(B), Minn. R. 7017.2020, subp. 1, Title I Condition: 40 CFR 50.6(PM10 SIP), Title I Condition: 40 CFR pt. 52, subp. Y]

6.2.4 PM < 2.5 micron: The Permittee shall conduct an initial performance test due 180 calendar days after startup of the Project and at a minimum every 60 months thereafter to measure emissions. The Commissioner will set the subsequent test frequency as stated in a Notice of Compliance (NOC) or Notice of Verification (NOV) letter with review of the initial performance test. Subsequent tests shall be completed no less than every 60-months by the due date (month and day) based on the initial test date or more frequently as stated in the NOC/NOV letter. If the Commissioner sets a test frequency at less than every 60 months, the Permittee must apply for an administrative amendment to incorporate the prescribed test frequency into the permit. A major amendment is required to reduce the test frequency once set in the permit. The performance test shall be conducted at worst-case conditions defined at Minn. R. 7017.2005, subp. 8 or at the operating conditions described at Minn. R. 7017.2025, subp. 2, using EPA Reference Methods 201A and 202, or other method approved by MPCA in the performance test plan approval. Testing shall be completed on two members of COMG 2. Testing shall be completed on a rotating basis such that no single silo within COMG 2 is tested twice before all other silos have been tested once. Testing conducted during the 60 days prior to a performance test due date will not reset the due date


Requirement number Requirement and citation for future testing. Testing conducted more than 60 days prior to the specified due date satisfies this test due date requirement but will reset future performance test due dates based on the most recent performance test date. See PM2.5 Performance Test Corrective Actions requirement under section 6 at TFAC 1. [Minn. R. 7007.0800, subp. 2(A)&(B), Minn. R. 7017.2020, subp. 1]

COMG 3 Existing Unloading Silos 6.3.1 PM < 10 micron: The Permittee shall conduct an initial performance test due 24 months after Permit

Issuance Date and at a minimum every 60 months thereafter to verify the emission factor of 0.0000863 lb/ton. The Commissioner will set the subsequent test frequency as stated in a Notice of Compliance (NOC) or Notice of Verification (NOV) letter with review of the initial performance test. Subsequent tests shall be completed no less than every 60-months by the due date (month and day) based on the initial test date or more frequently as stated in the NOC/NOV letter. If the Commissioner sets a test frequency at less than every 60 months, the Permittee must apply for an administrative amendment to incorporate the prescribed test frequency into the permit. A major amendment is required to reduce the test frequency once set in the permit. The performance test shall be conducted at worst-case conditions defined at Minn. R. 7017.2005, subp. 8 or at the operating conditions described at Minn. R. 7017.2025, subp. 2, using EPA Reference Methods 201A and 202, or other method approved by MPCA in the performance test plan approval. Testing shall be completed on two members of COMG 3. Testing shall be completed on a rotating basis such that no single silo within COMG 3 is tested twice before all other silos have been tested once. Testing conducted during the 60 days prior to a performance test due date will not reset the due date for future testing. Testing conducted more than 60 days prior to the specified due date satisfies this test due date requirement but will reset future performance test due dates based on the most recent performance test date. This requirement expires upon startup of the Project. [40 CFR pt. 51, Minn. R. 7017.2020, subp. 1, Title I Condition: 40 CFR 50.6(PM10 SIP), Title I Condition: 40 CFR pt. 52, subp. Y]

COMG 4 Bucket Elevator and Silo 3 Operations 6.4.1 PM < 10 micron: The Permittee shall conduct an initial performance test due 180 calendar days after

startup of the Project and at a minimum every 60 months thereafter to verify the emission factor of 0.0000863 lb/ton. Testing shall be completed on simultaneous operation of EQUI 5 and EQUI 11. The emission factor value applies individually to STRU 12 and STRU 32. The Commissioner will set the subsequent test frequency as stated in a Notice of Compliance (NOC) or Notice of Verification (NOV) letter with review of the initial performance test. Subsequent tests shall be completed no less than every 60-months by the due date (month and day) based on the initial test date or more frequently as stated in the NOC/NOV letter.


Requirement number Requirement and citation If the Commissioner sets a test frequency at less than every 60 months, the Permittee must apply for an administrative amendment to incorporate the prescribed test frequency into the permit. A major amendment is required to reduce the test frequency once set in the permit. The performance test shall be conducted at worst-case conditions defined at Minn. R. 7017.2005, subp. 8 or at the operating conditions described at Minn. R. 7017.2025, subp. 2, using EPA Reference Methods 201A and 202, or other method approved by MPCA in the performance test plan approval. Testing conducted during the 60 days prior to a performance test due date will not reset the due date for future testing. Testing conducted more than 60 days prior to the specified due date satisfies this test due date requirement but will reset future performance test due dates based on the most recent performance test date. [40 CFR pt. 51, Minn. R. 7007.0800, supb. 2(A)&(B), Minn. R. 7017.2020, subp. 1, Title I Condition: 40 CFR 50.6(PM10 SIP), Title I Condition: 40 CFR pt. 52, subp. Y]

6.4.2 PM < 2.5 micron: The Permittee shall conduct an initial performance test due 180 calendar days after startup of the Project and at a minimum every 60 months thereafter to verify the emission factor of 0.0000863 lb/ton. Testing shall be completed on simultaneous operation of EQUI 5 and EQUI 11. The emission factor value applies individually to STRU 12 and STRU 32. The Commissioner will set the subsequent test frequency as stated in a Notice of Compliance (NOC) or Notice of Verification (NOV) letter with review of the initial performance test. Subsequent tests shall be completed no less than every 60-months by the due date (month and day) based on the initial test date or more frequently as stated in the NOC/NOV letter. If the Commissioner sets a test frequency at less than every 60 months, the Permittee must apply for an administrative amendment to incorporate the prescribed test frequency into the permit. A major amendment is required to reduce the test frequency once set in the permit. The performance test shall be conducted at worst-case conditions defined at Minn. R. 7017.2005, subp. 8 or at the operating conditions described at Minn. R. 7017.2025, subp. 2, using EPA Reference Methods 201A and 202, or other method approved by MPCA in the performance test plan approval. Testing conducted during the 60 days prior to a performance test due date will not reset the due date for future testing. Testing conducted more than 60 days prior to the specified due date satisfies this test due date requirement but will reset future performance test due dates based on the most recent performance test date. [Minn. R. 7007.0800, subp. 2(A)&(B), Minn. R. 7017.2020, subp. 1]

6.4.3 PM < 10 micron: The Permittee shall conduct an initial performance test due 180 calendar days after startup of the Project and at a minimum every 60 months thereafter to measure emissions. Testing shall be completed on simultaneous operation of EQUI 5 and EQUI 11 with emissions measured from STRU 12 and STRU 32 combined. The Commissioner will set the subsequent test frequency as stated in a Notice of Compliance (NOC) or Notice of Verification (NOV) letter with review of the initial performance test. Subsequent tests shall be completed no less than every 60-months by the due date (month and day) based on the initial test date or more frequently as stated in the NOC/NOV letter. If the Commissioner sets a test frequency at less than every 60 months, the Permittee must apply for an administrative amendment to incorporate the prescribed test frequency into the permit. A major


Requirement number Requirement and citation amendment is required to reduce the test frequency once set in the permit. The performance test shall be conducted at worst-case conditions defined at Minn. R. 7017.2005, subp. 8 or at the operating conditions described at Minn. R. 7017.2025, subp. 2, using EPA Reference Methods 201A and 202, or other method approved by MPCA in the performance test plan approval. Testing conducted during the 60 days prior to a performance test due date will not reset the due date for future testing. Testing conducted more than 60 days prior to the specified due date satisfies this test due date requirement but will reset future performance test due dates based on the most recent performance test date. See PM10 Performance Test Corrective Actions requirement under section 6 at TFAC 1. [40 CFR pt. 51, Minn. R. 7007.0800, subp. 2(A)&(B), Minn. R. 7017.2020, subp. 1, Title I Condition: 40 CFR 50.6(PM10 SIP), Title I Condition: 40 CFR pt. 52, subp. Y]

6.4.4 PM < 2.5 micron: The Permittee shall conduct an initial performance test due 180 calendar days after startup of the Project and at a minimum every 60 months thereafter to measure emissions. Testing shall be completed on simultaneous operation of EQUI 5 and EQUI 11 with emissions measured from STRU 12 and STRU 32 combined. The Commissioner will set the subsequent test frequency as stated in a Notice of Compliance (NOC) or Notice of Verification (NOV) letter with review of the initial performance test. Subsequent tests shall be completed no less than every 60-months by the due date (month and day) based on the initial test date or more frequently as stated in the NOC/NOV letter. If the Commissioner sets a test frequency at less than every 60 months, the Permittee must apply for an administrative amendment to incorporate the prescribed test frequency into the permit. A major amendment is required to reduce the test frequency once set in the permit. The performance test shall be conducted at worst-case conditions defined at Minn. R. 7017.2005, subp. 8 or at the operating conditions described at Minn. R. 7017.2025, subp. 2, using EPA Reference Methods 201A and 202, or other method approved by MPCA in the performance test plan approval. Testing conducted during the 60 days prior to a performance test due date will not reset the due date for future testing. Testing conducted more than 60 days prior to the specified due date satisfies this test due date requirement but will reset future performance test due dates based on the most recent performance test date. See PM2.5 Performance Test Corrective Actions requirement under section 6 at TFAC 1. [Minn. R. 7007.0800, subp. 2(A)&(B), Minn. R. 7017.2020, subp. 1]

EQUI 4 Truck Loading Operations 6.5.1 PM < 10 micron: The Permittee shall conduct an initial performance test due 180 calendar days after

startup of the Project and at a minimum every 60 months thereafter to verify the emission factor of 0.0000863 lb/ton. The Commissioner will set the subsequent test frequency as stated in a Notice of Compliance (NOC) or Notice of Verification (NOV) letter with review of the initial performance test. Subsequent tests shall be completed no less than every 60-months by the due date (month and day) based on the initial test


Requirement number Requirement and citation date or more frequently as stated in the NOC/NOV letter. If the Commissioner sets a test frequency at less than every 60 months, the Permittee must apply for an administrative amendment to incorporate the prescribed test frequency into the permit. A major amendment is required to reduce the test frequency once set in the permit. The performance test shall be conducted at worst-case conditions defined at Minn. R. 7017.2005, subp. 8 or at the operating conditions described at Minn. R. 7017.2025, subp. 2, using EPA Reference Methods 201A and 202, or other method approved by MPCA in the performance test plan approval. Testing conducted during the 60 days prior to a performance test due date will not reset the due date for future testing. Testing conducted more than 60 days prior to the specified due date satisfies this test due date requirement but will reset future performance test due dates based on the most recent performance test date. [40 CFR pt. 51, Minn. R. 7007.0800, subp. 2(A)&(B), Minn. R. 7017.2020, subp. 1, Title I Condition: 40 CFR 50.6(PM10 SIP), Title I Condition: 40 CFR pt. 52, subp. Y]

6.5.2 PM < 2.5 micron: The Permittee shall conduct an initial performance test due 180 calendar days after startup of the Project and at a minimum every 60 months thereafter to verify the emission factor of 0.0000863 lb/ton. The Commissioner will set the subsequent test frequency as stated in a Notice of Compliance (NOC) or Notice of Verification (NOV) letter with review of the initial performance test. Subsequent tests shall be completed no less than every 60-months by the due date (month and day) based on the initial test date or more frequently as stated in the NOC/NOV letter. If the Commissioner sets a test frequency at less than every 60 months, the Permittee must apply for an administrative amendment to incorporate the prescribed test frequency into the permit. A major amendment is required to reduce the test frequency once set in the permit. The performance test shall be conducted at worst-case conditions defined at Minn. R. 7017.2005, subp. 8 or at the operating conditions described at Minn. R. 7017.2025, subp. 2, using EPA Reference Methods 201A and 202, or other method approved by MPCA in the performance test plan approval. Testing conducted during the 60 days prior to a performance test due date will not reset the due date for future testing. Testing conducted more than 60 days prior to the specified due date satisfies this test due date requirement but will reset future performance test due dates based on the most recent performance test date. [Minn. R. 7007.0800, subp. 2(A)&(B), Minn. R. 7017.2020, subp. 1]

6.5.3 PM < 10 micron: The Permittee shall conduct an initial performance test due 180 calendar days after startup of the Project and at a minimum every 60 months thereafter to measure emissions. The Commissioner will set the subsequent test frequency as stated in a Notice of Compliance (NOC) or Notice of Verification (NOV) letter with review of the initial performance test. Subsequent tests shall be completed no less than every 60-months by the due date (month and day) based on the initial test date or more frequently as stated in the NOC/NOV letter. If the Commissioner sets a test frequency at less than every 60 months, the Permittee must apply for an administrative amendment to incorporate the prescribed test frequency into the permit. A major amendment is required to reduce the test frequency once set in the permit.


Requirement number Requirement and citation The performance test shall be conducted at worst-case conditions defined at Minn. R. 7017.2005, subp. 8 or at the operating conditions described at Minn. R. 7017.2025, subp. 2, using EPA Reference Methods 201A and 202, or other method approved by MPCA in the performance test plan approval. Testing conducted during the 60 days prior to a performance test due date will not reset the due date for future testing. Testing conducted more than 60 days prior to the specified due date satisfies this test due date requirement but will reset future performance test due dates based on the most recent performance test date. See PM10 Performance Test Corrective Actions requirement under section 6 at TFAC 1. [40 CFR pt. 51, Minn. R. 7007.0800, subp. 2(A)&(B), Minn. R. 7017.2020, subp. 1, Title I Condition: 40 CFR 50.6(PM10 SIP), Title I Condition: 40 CFR pt. 52, subp. Y]

6.5.4 PM < 2.5 micron: The Permittee shall conduct an initial performance test due 180 calendar days after startup of the Project and at a minimum every 60 months thereafter to measure emissions. The Commissioner will set the subsequent test frequency as stated in a Notice of Compliance (NOC) or Notice of Verification (NOV) letter with review of the initial performance test. Subsequent tests shall be completed no less than every 60-months by the due date (month and day) based on the initial test date or more frequently as stated in the NOC/NOV letter. If the Commissioner sets a test frequency at less than every 60 months, the Permittee must apply for an administrative amendment to incorporate the prescribed test frequency into the permit. A major amendment is required to reduce the test frequency once set in the permit. The performance test shall be conducted at worst-case conditions defined at Minn. R. 7017.2005, subp. 8 or at the operating conditions described at Minn. R. 7017.2025, subp. 2, using EPA Reference Methods 201A and 202, or other method approved by MPCA in the performance test plan approval. Testing conducted during the 60 days prior to a performance test due date will not reset the due date for future testing. Testing conducted more than 60 days prior to the specified due date satisfies this test due date requirement but will reset future performance test due dates based on the most recent performance test date. See PM2.5 Performance Test Corrective Actions requirement under section 6 at TFAC 1. [Minn. R. 7007.0800, subp. 2(A)&(B), Minn. R. 7017.2020, subp. 1]

EQUI 8 Pneumatic Conveyance to Silo 9 6.6.1 The Permittee shall submit a notification of the date construction began: Due 30 calendar days after

Date of Construction Start (or reconstruction). Submit the name and number of the Subject Item and the date construction began. The notification shall be submitted electronically on Form CS-02. [Minn. R. 7007.0800, subp. 16(L)]

6.6.2 The Permittee shall submit a notification of the actual date of initial startup: Due 15 calendar days after Initial Startup Date. Submit the name and number of the Subject Item and the date of startup. Startup is as defined in Minn. R. 7005.0100, subp. 42a.


Requirement number Requirement and citation The notification shall be submitted electronically on Form CS-02. [Minn. R. 7007.0800, subp. 16(L)]



6.7.2 The Permittee shall submit a notification of the actual date of initial startup: Due 15 calendar days after Initial Startup Date. Submit the name and number of the Subject Item and the date of startup. Startup is as defined in Minn. R. 7005.0100, subp. 42a. The notification shall be submitted electronically on Form CS-02. [Minn. R. 7007.0800, subp. 16(L)]




TREA 1 Silo 6 Baghouse (existing) 6.9.1 The Permittee shall submit a notification of equipment removal/dismantlement: Due 15 calendar days

after Equipment Removal and/or Dismantlement Date. This notification shall specify which Subject Items (by ID#) were removed and on what date. [Minn. R. 7007.0800, subp. 2(A)]



TREA 3 Truck Loading and COMG 1 Baghouse (existing) 6.11.1 The Permittee shall submit a notification of equipment removal/dismantlement: Due 15 calendar days


TREA 5 Silo 6 Baghouse 6.12.1 The Permittee shall submit a notification of the date construction began: Due 30 calendar days after



TREA 6 Silo 5 Baghouse


Requirement number Requirement and citation 6.13.1 The Permittee shall submit a notification of the date construction began: Due 30 calendar days after









TREA 9 Truck Loading Baghouse 6.16.1 The Permittee shall submit a notification of the date construction began: Due 30 calendar days after



TREA 10 Bucket Elevator Baghouse 6.17.1 The Permittee shall submit a notification of the date construction began: Due 30 calendar days after

Date of Construction Start (or reconstruction). Submit the name and number of the Subject Item and the date construction began.













TREA 14 Silo 4 Second Baghouse 6.21.1 The Permittee shall submit a notification of the date construction began: Due 30 calendar days after











7. Appendices


Appendix A: Title I Condition: State Implementation Plan (SIP) for PM10 NAAQS. Table 1: PM10 Point Source Modeling Parameters Relied Upon in 2006 Modeling to Demonstrate Compliance with NAAQS

Source ID EQUI; STRU; TREA

Source Description


Stack Height (m)

Stack Temp

(K)



SILO1 EQUI 1; STRU

1; TREA 1

Silo No. 1 (new material) 0.0318 0.25 496283.1 4975465 213 25.6 293 9.7 0.305

SILO2 EQUI 2; STRU

2; TREA 2


SILO3_6 EQUI 3; STRU

3; TREA 3

Silo No. 3-6 (fly ash) 0.1058 0.84 496279.2 4975480 213 31.09 293 31.35 0.309


Source ID FUGI Source Description


Release Height (m) σY (m) σZ (m)


UNLOAD EQUI 4 Silo Unloading and Truck Loading 4.25E-03 3.37E-02 496285.3 4975474 213 3 1.41 1.39

TRUCK FUGI 2 TREA 4

Fugitive Emissions from Truck Traffic 8.58E-03 6.81E-02 496285.3 4975474 213 1 11.4 0.85


Table 2: PM10 and PM2.5 Point Source Modeling Parameters Relied Upon in 2020 SIL Analysis

Permit ID Source Description Pollutant Averaging Time

Emission Rate Location UTM NAD83 Stack Height (m)

Stack Temp (K)


Stack Dia (m)

Flow Rate (ACFM) g/s lb/hr X (m) Y (m)


PM10 and PM2.5

24-hr 0.0006 0.0045 496,270 4,975,470 29.9 293 19.1 0.34 3,640

PM10 and PM2.5

Annual 0.0005 0.0037

STRU 11 Truck loading

operation (EQUI 4, TREA 9)

PM10 and PM2.5

24-hr 0.0011 0.009 496,281 4,975,470 27.4 293 32.1 0.18 1,800

PM10 and PM2.5

Annual 0.0009 0.0073

STRU 12 Bucket elevator


PM10 and PM2.5

24-hr 0.0004 0.0031 496,264 4,975,479 6.1 293 7.2 0.49 2,900

PM10 and PM2.5

Annual 0.0003 0.0027


PM10 and PM2.5

24-hr 0.0011 0.009 496,278 4,975,489 29.9 293 18.2 0.49 7,275

PM10 and PM2.5

Annual 0.0009 0.0073


PM10 and PM2.5

24-hr 0.0011 0.009 496,269 4,975,482 29.9 293 18.2 0.49 7,275

PM10 and PM2.5

Annual 0.0009 0.0073


PM10 and PM2.5

24-hr 0.0011 0.009 496,260 4,975,475 29.9 293 18.2 0.49 7,275

PM10 and PM2.5

Annual 0.0009 0.0073


PM10 and PM2.5

24-hr 0.0011 0.009 496,283 4,975,458 25.3 293 19.1 0.34 3,640

PM10 and PM2.5

Annual 0.0009 0.0073


PM10 and PM2.5

24-hr 0.0011 0.009 496,292 4,975,467 25.3 293 19.1 0.34 3,640

PM10 and PM2.5

Annual 0.0009 0.0073



PM10 and PM2.5

24-hr 0.0011 0.009 496,286 4,975,485 29.9 293 19.1 0.34 3,640

PM10 and PM2.5

Annual 0.0009 0.0073


PM10 and PM2.5

24-hr 0.0006 0.0045 496,266 4,975,466 29.9 293 19.1 0.34 3,640

PM10 and PM2.5

Annual 0.0005 0.0037


PM10 and PM2.5

24-hr 0.0001 0.0008 496,271 4,975,471 25.3 293 3.9 0.34 750

PM10 and PM2.5

Annual 0.0001 0.0007


PM10 and PM2.5

24-hr 0.0011 0.009 496,277 4,975,477 29.9 293 19.1 0.34 3,640

PM10 and PM2.5

Annual 0.0009 0.0073

Attachment 2: Technical Support Document (TSD) for Permit No. 12300391-102 This attachment includes the TSD for Permit No. 12300391-102 issued to Bulk Silos xx, 2021 [to be updated]. Permit No. 12300391-102 and its TSD can also be found on the MPCA’s website: [Final draft permit and TSD (with attachments) available at https://www.pca.state.mn.us/public-notices - link will be updated once comment period has ended and final permit is issued.]


Technical Support Document, Permit Number: 12300391-102 Page 1 of 24

Technical Support Document For

Proposed Air Emission Permit No. 12300391-102 This technical support document (TSD) is intended for all parties interested in the draft permit and to meet the requirements that have been set forth by the federal and state regulations (40 CFR § 70.7(a)(5) and Minn. R. 7007.0850, subp. 1). The purpose of this document is to provide the legal and factual justification for each applicable requirement or policy decision considered in the preliminary determination to issue the draft permit. 1. General information

1.1 Applicant and stationary source location:

Table 1. Applicant and source address

Applicant/Address

Stationary source/Address (SIC Code: 5032 - Brick, Stone, and Related Construction Materials)

Bulk Silos 2145 Childs Rd Saint Paul, Minnesota 55106

Bulk Silos 2145 Childs Rd Saint Paul, MN 55106

Contact: Alex Olin Phone: 651-686-1307

1.2 Facility description

Bulk Silos is a Portland cement distribution terminal. The facility currently operates six silos with pollution control equipment used for storage and distribution of cementitious products. The material is currently received by rail, stored in the silos, and distributed by truck. The main sources of emissions are Particulate Matter (PM), Particulate Matter less than 10 microns (PM10), and Particulate Matter less than 2.5 microns (PM2.5). Emissions are controlled by baghouses on all of the operations at the facility.

1.3 Description of the activities allowed by this permit action This permit action is a Major Amendment. The major amendment is for the construction of three new silos (EQUI 8, EQUI 9, and EQUI 10), a new bucket elevator (EQUI 5), and nine new fabric filters (TREA 7, TREA 8, TREA 10, TREA 11, TREA 12, TREA 13, TREA 14, TREA 15, and TREA 16). Three existing fabric filters will be replaced (TREA 1 with TREA 5, TREA 2 with TREA 6, and TREA 3 with TREA 9). The Facility will also be adding barge unloading, and the material will be conveyed pneumatically from the barges to the storage silos. Many permit requirements are triggered by the startup of "the Project" which is defined as the startup of EQUI 5, EQUI 8, EQUI 9, and/or EQUI 10. After startup of the Project, product will no longer be unloaded into Silo 3 (EQUI 11). This silo will serve as a storage silo for the cementitious product in Silos 7, 8, and 9 (EQUIs 8, 9, and 10) as it is transferred from these silos, to the bucket elevator, to EQUI 11, and eventually to the truck loading operation (EQUI 4). The MPCA has a combined operating and construction permitting program under Minn. R. ch. 7007. Under that authority, this permit action authorizes construction. The Permittee cannot operate the Project until the EPA approves the SIP revision. See Section 2.5 below for more information.


1.4 Description of notifications and applications included in this action Table 2. Notifications and applications included in this action

Date received Application/notification type and description 04/16/2020 Major Amendment (IND20200001)

1.5 Facility emissions: Table 3. Title I emissions summary

Pollutant

Unlimited potential emissions from the modification (tpy)

Limited potential emissions from the modification (tpy)

NSR/112(g) threshold for new major source (tpy)

NSR/112(g) review required? (yes/no)

PM 10,249 5.42 250 No

PM10 6,594 1.13 250 No PM2.5 1,742 0.325 250 No

NOX 0.00 0.00 250 No SO2 0.00 0.00 250 No

CO 0.00 0.00 250 No

Ozone (VOC) 0.00 0.00 250 No Lead 0.00 0.00 250 No

CO2e* 0.00 0.00 100,000 No Individual / Total HAPs 0.00 0.00 10/25 No *Carbon dioxide equivalents as defined in Minn. R. 7007.0100. The data in Table 3 represents the total facility potential to emit even though the project involves adding only three silos and a bucket elevator. Therefore, the emissions increase summary in Table 3 is a conservative analysis.

Table 4. Total facility potential to emit summary

PM tpy

PM10 tpy

PM2.5 tpy

SO2 tpy

NOx tpy

CO Tpy

CO2e tpy

VOC tpy

Single

HAP tpy

All

HAPs tpy

Total Facil ity Limited Potential Emissions

5.42 1.13 0.325 0.00 0.00 0.00 0.00 0.00 0.00 0.00

Total Facil ity Actual Emissions (2019)

0.646 0.381 0.132 0.00 0.00 0.00 * 0.00 *

* Not reported in MN emission inventory.

Table 5. Facility classification

Classification Major Synthetic minor/area Minor/area

PSD X


Classification Major Synthetic minor/area Minor/area

Part 70 Permit Program X Part 63 NESHAP X

1.6 Changes to permit

The MPCA has a combined operating and construction permitting program under Minnesota rules Chapter 7007, and under Minn. R. 7007.0800, the MPCA has authority to include additional requirements in a permit. Under that authority, the following changes to the permit are also made through this permit action:

• The permit has been updated to reflect current MPCA templates and standard citation formatting. See Attachment 4 of this TSD for a full discussion of how the standard language was evaluated and updated.

• The existing process throughput limits and their recordkeeping were moved from TFAC 1 to COMG 2.

• Previously, the Permittee was required to submit an “equivalent to or better” (EBD) demonstration before making any physical changes or changes to the method of operation which may affect parameters listed in Appendix A to the permit. This requirement was removed and replaced with a requirement outlining specific modeling triggers. The existing full-facility modeling demonstration is outdated (2006) and therefore not an applicable basis for an EBD demonstration. See Section 3.2 of this TSD for more information on modeling done for this permit action.

• EQUI 1 was renamed to “Pneumatic Conveyance to Silo 6,” and EQUI 2 was renamed to “Pneumatic Conveyance to Silo 5.” This was done to match the Permittee’s nomenclature and to reduce confusion during permit drafting correspondence.

• EQUI 3 was previously comprised of four individual emission units: EQUI 6, EQUI 7, EQUI 11, and EQUI 12. These four units are subject to a combined PM10 limit, now at COMG 1. The remaining requirements from the existing EQUI 3 were copied to each individual EQUI.

• The PM limit of 0.02 grains per dry standard cubic foot was removed from EQUI 1, EQUI 2, and EQUI 3. This was the incorrect limit value from Minn. R. 7011.0715. The correct value from the rule is now in the permit at these EQUIs.

• The opacity requirement from Minn. R. 7011.0105 was removed from EQUI 1, EQUI 2, EQUI 6, EQUI 7, EQUI 11, and EQUI 12. The Standards of Performance for Visible Emissions Restrictions for Existing Facilities apply to any emissions facility for which a specific standard of performance has not been promulgated in another rule. These emission units are subject to the opacity and particulate standards from Minn. R. 7011.0715 and are therefore not subject to Minn. R. 7011.0105.

• The averaging times for the following limits were updated: o The PM10 emission rates at COMG 1, EQUI 1 and EQUI 2. These were previously pound/hour

24-hour rolling average limits. However, the facility does not operate 24 hours/day, therefore a pound/hour daily average is more representative of the emissions.

o The process throughput annual limit at COMG 2. This was previously a tpy 12-month rolling average limit. However, a tpy 12-month rolling sum is more representative of the emissions and the purpose of the limit.

• Added recordkeeping for the existing PM10 emission limits at COMG 1, EQUI 1, EQUI 2, and EQUI 4. • Added a truck traffic limit on FUGI 2. • Added a control efficiency for PM2.5 at TREAs 1, 2, and 3. • Removed FUGI 2 (Unpaved Roads) and its requirements. The MPCA received notification on

4/20/2021 that all roads at the facility had been paved. During the SIL Analysis correspondence, the Permittee committed to paving the roads at the facility in order to exclude unpaved road emissions from the SIL Analysis.

2. Regulatory and/or statutory basis


2.1 New source review (NSR) The permit carries forward existing throughput limits on the facility such that it is a minor source under New Source Review regulations. The permit action also authorizes new throughput limits that will become effective upon startup of the Project. The new throughput limits are to avoid major source and modification classification under NSR; therefore, they do not change the facility’s status and will continue to limit them such that the facility will stay a minor source under the NSR permit program.

2.2 Part 70 permit program The permit carries forward existing throughput limits on the facility such that it is a nonmajor source under the Part 70 permit program. The permit action also authorizes new throughput limits that will become effective upon startup of the Project. The new throughput limits are to avoid major source classification under Part 70; therefore, they do not change the facility’s status and will continue to limit them such that the facility will stay a nonmajor source under the Part 70 permit program.

2.3 New source performance standards (NSPS) The Permittee has stated that no New Source Performance Standards apply to the operations at this facility.

2.4 National emission standards for hazardous air pollutants (NESHAP)

The Permittee has stated that no National Emission Standards for Hazardous Air Pollutants apply to the operations at this facility.

2.5 State implementation plan (SIP) Bulk Silos is located in the Red Rock Road Maintenance Area for the 1987 coarse particular matter (PM10) National Ambient Air Quality Standards (NAAQS) and is subject to numerous state implementation plan (SIP) requirements to restrict those emissions. These Title I SIP conditions are intended to ensure that the Red Rock Road area continues to maintain the PM10 NAAQS. The requirements and emission limits of the most recently SIP-approved State Individual Permit for this facility, No. 12300391-002 (final approval effective as of September 11, 2007, 72 FR 51713) will continue to apply until the SIP revision for this permit is approved by the EPA. Bulk Silos was required to provide a modeling protocol for an equivalent-or-better demonstration in order to make any physical changes to the PM10 SIP-approved equipment at the facility. For the issuance of this permit, which will include significant changes to the permit and facility operation, Bulk Silos underwent a Significant Impact Levels (SIL) Analysis for PM10. See Section 3.2 below for more discussion on the SIL Analysis and its results.


2.6 Regulatory overview Table 6. Regulatory overview of units affected by the modification/permit amendment Subject item* Applicable regulations Rationale

TFAC 1 – Childs Road Terminal

40 CFR pt. 51, Title I Condition: 40 CFR 50.6 (PM10 SIP), Title I Condition: 40 CFR pt. 52, subp. Y ; Title I Condition: Avoid major modification under 40 CFR 52.21(b)(2) & Minn. R. 7007.3000 ; Title I Condition: Avoid major source under 40 CFR 52.21(b)(1)(i) & Minn. R. 7007.3000

Prevention of Significant Deterioration (PSD) and SIP. Authorization to construct EQUI 5, EQUI 8, EQUI 9, EQUI 10, TREA 5, TREA 6, TREA 7, TREA 8, TREA 9, TREA 10, TREA 11, TREA 12, TREA 13, TREA 14, TREA 15, TREA 16, and FUGI 3 and avoid major source and modification under PSD and to comply with the site-specific PM10 SIP conditions. The permit requires notification of installation for each unit. The construction authorization expires if construction has not begun within 60 months.

COMG 1 – Silos 1-4 EQUI 1 – Pneumatic Convey-ance to Silo 6 EQUI 2 – Pneumatic Convey-ance to Silo 5

EQUI 4 – Truck Loading Operations

40 CFR pt. 51, Title I Condition: 40 CFR 50.6(PM10 SIP), Title I Condition: 40 CFR pt. 52, subp. Y

SIP. PM10 l imits and other operating requirements are carried forward to meet the SIP. The Permittee shall attain, demonstrate, and maintain compliance with the applicable state and federal ambient air quality standards for PM10. These l imits expire upon startup of the Project, when new SIP l imits and operating requirements will be effective as described in this table.


Subject item* Applicable regulations Rationale

COMG 2 – Unloading Silos

40 CFR pt. 51, Title I Condition: 40 CFR 50.6(PM10 SIP), Title I Condition: 40 CFR pt. 52, subp. Y

40 CFR pt. 51, 40 CFR pt. 52, subp. Y, Title I Condition: 40 CFR 50.6 (PM10 SIP), Title I Condition: Avoid major modification under 40 CFR 52.21(b)(2) & Minn. R. 7007.3000, Title I Condition: Avoid major source under 40 CFR 52.21(b)(1)(i) & Minn. R. 7007.3000, To avoid major source under 40 CFR 70.2 & Minn. R. 7007.0200 40 CFR pt. 51, Title I Condition: 40 CFR 50.6(PM10 SIP), Title I Condition: 40 CFR pt. 52, subp. Y, Minn. R. 7007.0800, subp. 2(A) & (B)

40 CFR pt. 51, Minn. R. 7007.0800, subp. 2(A) & (B), Title I Condition: 40 CFR 50.6(PM10 SIP), Title I Condition: 40 CFR pt. 52, subp. Y, Title I Condition: Avoid major modification under 40 CFR 52.21(b)(2) & Minn. R. 7007.3000, Title I Condition: Avoid major source under 40 CFR 52.21(b)(1)(i) & Minn. R. 7007.3000, To avoid major source under 40 CFR 70.2 & Minn. R. 7007.0200

Minn. R. 7007.0800, subp. 2(A) & (B)

Minn. R 7007.0800, subp. 2(A)

SIP. The daily throughput l imit and other operating parameters are carried forward to meet the SIP. The Permittee shall attain, demonstrate, and maintain compliance with the applicable state and federal ambient air quality standards for PM10. This l imit expires upon startup of the Project, when new SIP l imits and operating requirements will be effective as described in this table.

PSD, SIP, and Part 70. The annual throughput l imit and other operating parameters are carried forward from past permit actions and to avoid major source and modification classification under PSD, major source under Part 70, and to comply with site-specific PM10 SIP conditions. This l imit expires upon startup of the Project.

SIP and SIL Analysis. The following l imits were derived from the SIL Analysis to fulfi l l site-specific PM10 SIP conditions for modifications and to demonstrate that the Project emission increases were at or below the National Ambient Air Quality Standards (NAAQS)-based significant impact levels: the new daily throughput l imit and the PM10 daily average l imit.

PSD, SIP, Part 70, and SIL Analysis. The new annual throughput l imit was derived from the SIL Analysis to fulfi ll site-specific PM10 SIP conditions for modifications and to demonstrate that the Project emission increases were at or below the NAAQS-based significant impact levels. It also avoids major source and modification classification under PSD and major source under Part 70.

SIL Analysis. The PM2.5 emission l imits were derived from the SIL Analysis to demonstrate that the Project emission increases were at or below the NAAQS-based significant impact levels.

The PM10 and PM2.5 emission l imits were derived from the maximum hourly potential to emit of the operation.



COMG 4 – Bucket Elevator and Silo 3 Operations

Minn. R 7007.0800, subp. 2(A) The PM10 and PM2.5 emission l imits were derived from the maximum hourly potential to emit of the operation.


40 CFR pt. 51, Title I Condition: 40 CFR 50.6(PM10 SIP), Title I Condition: 40 CFR pt. 52, subp. Y, Minn. R. 7007.0800, subp. 2(A) & (B)


Minn. R. 7007.0800, subp. 2(A) & (B)

Minn. R 7007.0800, subp. 2(A)

SIP and SIL Analysis. The following l imits were derived from the SIL Analysis to fulfi l l site-specific PM10 SIP conditions for modifications and to demonstrate that the Project emission increases were at or below the National Ambient Air Quality Standards (NAAQS)-based significant impact levels: the daily throughput l imits and PM10 daily average l imit.

PSD, SIP, Part 70, and SIL Analysis. The annual throughput l imits were derived from the SIL Analysis to fulfi l l site-specific PM10 SIP conditions for modifications and to demonstrate that the Project emission increases were at or below the NAAQS-based significant impact levels. Although the throughput l imits from truck loading alone do not avoid major source and modification classification under PSD and major source under Part 70, the facil ity as a whole does. If the facil ity exceeds the threshold, all parts of the facil ity have contributed.


The PM10 and PM2.5 emission l imits were derived from the maximum hourly potential to emit of EQUI 4.



EQUI 5 – Bucket Elevator



Minn. R. 7007.0800, subp. 2(A) & (B)

SIP and SIL Analysis. The following l imits were derived from the SIL Analysis to fulfi l l site-specific PM10 SIP conditions for modifications and to demonstrate that the Project emission increases were at or below the National Ambient Air Quality Standards (NAAQS)-based significant impact levels: the daily throughput l imits and PM10 daily average l imit.

PSD, SIP, Part 70, and SIL Analysis. The annual throughput l imits were derived from the SIL Analysis to fulfi l l site-specific PM10 SIP conditions for modifications and to demonstrate that the Project emission increases were at or below the NAAQS-based significant impact levels. Although the throughput l imits from the bucket elevator alone do not avoid major source and modification classification under PSD and major source under Part 70, the facil ity as a whole does. If the facil ity exceeds the threshold, all parts of the facil ity have contributed.




EQUI 1 – Pneumatic Conveyance to Silo 6









EQUI 11 – Silo 3


Minn. R. 7011.0715 Standards of Performance for post-1969 Industrial Process Equipment. Equipment for which there is no other promulgated performance standard is subject to the opacity and PM limits in this rule. Construction of each unit was on or after July 9, 1969.



EQUI 11 – Silo 3


Minn. R. 7007.0800, subp. 2(A) & (B)

SIP and SIL Analysis. The PM10 daily average l imit was derived from the SIL Analysis to fulfi l l site-specific PM10 SIP conditions for modifications and to demonstrate that the Project emission increases were at or below the National Ambient Air Quality Standards (NAAQS)-based significant impact levels.


FUGI 3 – Paved Roads


SIP and SIL Analysis. The Permittee has committed to paving all parking lots and haul roads at the facil ity. This exempted the paved roads from being including in the SIL Analysis to fulfi l l site-specific PM10 SIP conditions for modifications and to demonstrate that the Project emission increases were at or below the NAAQS-based significant impact levels.

TREA 1 – Silo 6 Baghouse (existing) TREA 2 – Silo 5 Baghouse (existing) TREA 3 – Truck Loading and COMG 1 Baghouse (existing)

Title I Condition: Avoid major modification under 40 CFR 52.21(b)(2) & Minn. R. 7007.3000, Title I Condition: Avoid major source under 40 CFR 52.21(b)(1)(i) & Minn. R. 7007.3000, To avoid major source under 40 CFR 70.2 & Minn. R. 7007.0200 Title I Condition: 40 CFR pt. 52, subp. Y, Title I Condition: Avoid major modification under 40 CFR 52.21(b)(2) & Minn. R. 7007.3000, Title I Condition: Avoid major source under 40 CFR 52.21(b)(1)(i) & Minn. R. 7007.3000, To avoid major source under 40 CFR 70.2 & Minn. R. 7007.0200 To avoid major source under 40 CFR 70.2 & Minn. R. 7007.0200

PSD and Part 70. Control efficiency and other operating parameter requirements to l imit PM PTE to avoid major source and modification classification under PSD and major source classification under Part 70. Limits reflect that the units have total enclosures. Permit specifies that replacement fabric fi lters must meet the respective TREA requirements.

PSD and Part 70. Control efficiency and other operating parameter requirements to l imit PM10 PTE to avoid major source and modification classification under PSD and to avoid major source classification under Part 70. Limits reflect that the units have total enclosures. Permit specifies that replacement fabric fi lters must meet the respective TREA requirements.

Part 70. Control efficiency and other operating parameter requirements to l imit PM2.5 PTE to avoid major source classification under Part 70. Limits reflect that the units have total enclosures. Permit specifies that replacement fabric fi lters must meet the respective TREA requirements.



TREA 5 – Silo 6 Baghouse




TREA 9 – Truck Loading Baghouse

TREA 10 – Bucket Elevator Baghouse




TREA 14 – Silo 4 Second Baghouse



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

To avoid major source under 40 CFR 70.2 & Minn. R. 7007.0200

PSD and Part 70. Control efficiency and other operating parameter requirements to l imit PM PTE to avoid major source and modification classification under PSD and major source classification under Part 70. Limits reflect that the units have total enclosures. Permit specifies that replacement fabric fi lters must meet the respective TREA requirements.

Part 70. Control efficiency and other operating parameter requirements to l imit PM2.5 PTE to avoid major source classification under Part 70. Limits reflect that the units have total enclosures. Permit specifies that replacement fabric fi lters must meet the respective TREA requirements.

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


3. Technical information

3.1 Calculations of potential to emit and emissions increase analysis Attachment 1 to this TSD contains a summary of the PTE of the Facility, the Title I net emissions increase calculations for this modification, and detailed spreadsheets describing the calculations and data sources used. This information was prepared by the MPCA and the Permittee. Silo Unloading The potential emissions from silo unloading (COMG 2) are based on AP-42 Section 11.12 and an emission factor created using the results of Bulk Silos’ self-reported performance test. After startup of the Project, material will be received via rail and barge and is unloaded via pneumatic conveyor. The worst-case scenario would be one conveyor unloading from barge at 200 ton/hour simultaneously as another conveyor unloading from rail at 200 ton/hour. Unrestricted emissions were calculated using this assumption and the emission factors for uncontrolled pneumatic conveyance from AP-42 Section 11.12. Controlled and permit allowable emissions were calculated using the site-specific emission factor and the daily and yearly throughput limits as applicable. Aggregate Transfer The potential emissions from aggregate transfer operations (EQUI 5 and EQUI 11) are based on AP-42 Section 11.12 and the same site-specific emission factor. The worst-case scenario would be operation at the maximum throughput of 100 ton/hour. Unrestricted emissions were calculated using this assumption and the emission factors for aggregate transfer from AP-42 Section 11.12. Controlled and permit allowable emissions were calculated using the site-specific emission factor and the daily and yearly throughput limits as applicable. Truck Loading The potential emissions from truck loading operations (EQUI 4) are based on AP-42 Section 11.12 and the same site-specific emission factor. Truck loading operations export the cementitious product. Product can be loaded from EQUIs 1, 2, 6, 7, 11, and/or 12, one silo at a time. The worst-case scenario would be operation at the maximum throughput of 200 ton/hour. Unrestricted emissions were calculated using this assumption and the emission factors for aggregate transfer from AP-42 Section 11.12. Controlled and permit allowable emissions were calculated using the site-specific emission factor and the daily and yearly throughput limits as applicable. Paved Roads The potential fugitive emissions from truck traffic on the paved roads are based on AP-42 Section 13.2.1. Emissions are calculated using the equations from that section as well as information related to the amount of truck traffic expected, the distance the trucks will be driving, and the weight of the trucks. Emission Factor Testing The site-specific emission factor created during the self-reported performance test is the basis for the calculations at the facility. This emission factor of 0.0000863 lb/ton will be verified through performance test requirements in the permit at COMG 2, COMG 3, COMG 4, and EQUI 4. Compliance calculations throughout the permit shall use this emission factor or the emission factor from the most recent emission factor performance test for the applicable COMG/EQUI. The self-reported performance test consisted of three runs and was completed at the following stack parameters: stack height of 80 ft; volumetric flow rate of 3,600 ACFM; and gas exit temperature of 55 degrees Fahrenheit. The throughputs for the three runs were: 110 tons/test, 113 tons/test, and 111 tons/test.


3.2 Dispersion modeling As required in Permit No. 12300391-101 and the SIP, before making any physical change or changes to the method of operation which may affect previous modeling parameters (those listed in Appendix A to the Permit from the 2006 full facility modeling demonstration), the Permittee was required to demonstrate to the MPCA that the PM10 plume dispersion characteristics following the physical change or change in method of operation would be equivalent to or better than the PM10 dispersion characteristics previously modeled. The Permittee fulfilled this requirement by completing dispersion modeling to show that the new emission units at Bulk Silos are below Significant Impact Levels (SILs) for PM10. A SIL analysis was also completed for PM2.5. The worst-cast scenario used in the SIL analysis assumed the following simultaneous operations: truck loading (EQUI 4), the bucket elevator (EQUI 5), the temporary storage silo used when loading out product from EQUIs 8, 9, and/or 10 (EQUI 11), and the entire silo loading throughput being conveyed to one silo. Several operating restrictions were assumed when the modeling was conducted, so these have been incorporated as permit limits (e.g., process throughputs for unloading, bucket elevator, and truck loading, etc.) in the draft permit. In addition, per MPCA practice, a table of the parameters used in the SIL analysis has been added to the permit as an appendix. Other than the specific operating restrictions mentioned above, the parameters listed in Table 2 of Appendix A of the permit describe the operation of the facility at maximum capacity. In other words, the flow rates and temperatures listed in Table 2 of Appendix A represent the minimum parameters at the maximum emission rates. The MPCA does not require any specific compliance demonstration with these parameters because they are worst case conditions. The purpose of listing the parameters in the permit appendix is to provide a benchmark for determining if and when additional modeling is required. The SIL Analysis results can be found below in Table 7. Table 7. SIL Analysis results

Pollutant Averaging period SIL

(µg/m3) Total modeled concentration (µg/m3) Percent of SIL threshold (%)

PM10 24-hour 5 1.08 22

Annual 1 0.3 30

PM2.5 24-hour 1.2 1.08 89

Annual 0.3 0.3 100

3.3 Ambient air boundary In the SIL analysis, the facility modeled receptors throughout the entire facility property (excluding buildings). Since no receptors showed exceedances of the national ambient air quality standards (NAAQS) or Minnesota ambient air quality standards (MAAQS), this permit does not require a general public preclusion plan.

3.4 Single Source Determination The Agency requested a single-source determination for Bulk Silos at 2145 Childs Road and Cemstone Products Company at 936 Childs Road. The Agency agrees with the Permittee’s determination that the two facilities are separate sources. Bulk Silos falls under NAICS Code 423320 (Brick, Stone, and Related Construction Material Merchant Wholesalers) and SIC Code 5032 (Brick, Stone, and Related Construction Materials). Cemstone Products Company falls under NAICS Code 327320 (Ready-Mix Concrete Manufacturing) and SIC Code 3273 (Ready-


Mixed Concrete). Therefore, these two facilities have different NAICS and SIC Codes and are considered separate sources. Based on recent records, Bulk Silos sold material to approximately 60 different locations, and only 8% of the total volume was sold to Cemstone Products Company. The Cemstone facility purchased material from five different vendors, and only 10% of the purchased product came from Bulk Silos. Additional support for this determination includes separate ownership and the physical distance between the facilities. Bulk Silos and Cemstone Products Company have separate ownership groups; however, there is some overlap of members in these groups. They each have their own separate operation groups and operational management. The two facilities make their own operational and construction decisions independent from the other. Lastly, the facilities are located approximately one mile apart with multiple industrial sites between them. See the Permittee’s Single-Source Determination Letter in Attachment 5 to this TSD for more information.

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

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

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

The table below summarizes the monitoring requirements associated with this amendment. Table 8. Monitoring

Subject item* Requirement (rule basis)

What is the monitoring Why is this monitoring adequate?

COMG 1 – Silos 1-4

PM10 < 0.84 lb/hr daily average [Limit from SIP]

Daily records of material throughput, daily calculation and records of emissions

The Permittee is able to use the daily COMG 1 throughput and emission factor to calculate the daily average emission rate. Performance testing at COMG 3 is to verify the emission factor used in compliance calculations. These records, and the l imits and associated monitoring for the associated control, provide adequate assurance of compliance with the l imits.


COMG 2 – Unloading Silos

Process throughput <= 1,100 ton/day [Limit from SIP] Process throughput <= 100,000 tpy 12-month roll ing sum [Limit from SIP, Limit to avoid PSD, Limit to avoid part 70]

Process throughput <= 2,500 ton/day [Limit from SIP, Limit from SIL Analysis] Process throughput <= 740,000 tpy 12-month roll ing sum

[Limit from SIP, Limit from SIL Analysis, Limit to avoid PSD, Limit to avoid part 70]

PM10 <= 0.009 lb/hr daily average [Limit from SIP, Limit from SIL Analysis]

PM2.5 <= 0.009 lb/hr daily average [Limit from SIL Analysis]

PM10 <= 0.017 lb/hr 3-hour average

PM2.5 <= 0.017 lb/hr 3-hour average

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

Daily records of material throughput, monthly calculations of process throughput and 12-month roll ing sum.

Daily records of material throughput, daily calculation and records of emissions, performance testing

The Permittee is able to use their computer and ticketing system to generate throughput records on a daily basis. These daily records are then used to calculate monthly and 12-month roll ing sums to demonstrate compliance with the l imit. Because the daily process throughput fluctuates throughout the year, a 12-month roll ing sum is adequate to ensure the facil ity remains below major source PSD, major modification PSD, and part 70 thresholds as well as meets the requirements for the SIP and SIL analysis.

Performance testing for PM10 and PM2.5 will be used to verify compliance with emission l imits. Testing at worst-case conditions is a direct method for determining compliance with an emissions l imit when a CEMS is not available. Testing frequencies are typically set at 12, 36, or 60-month increments and are based on the initial test results, applicable rules, potential emissions, location of source, and past compliance history. The testing frequencies will be stated in the NOC/NOV letter. Testing shall be completed on two members of COMG 2 at the time of each test. Testing shall be completed on a rotating basis such that no single si lo within COMG 2 is tested twice before all other si los have been tested. The Permittee is able to use the daily COMG 2 throughput and emission factor to calculate the daily average emission rate. These records, and the l imits and associated monitoring for the associated control, provide adequate assurance of compliance with the l imits.




COMG 3 – Existing Unloading Silos

See l imits at COMG 1, EQUI 1, and EQUI 2

Performance Testing

Performance testing for PM10 and PM2.5 will be used to verify compliance with emission factor used in compliance calculations at COMG 1, EQUI 1, and EQUI 2. Testing frequencies are typically set at 12, 36, or 60-month increments and are based on the initial test results, applicable rules, potential emissions, location of source, and past compliance history. The testing frequencies will be stated in the NOC/NOV letter. Testing shall be completed on two members of COMG 3 at the time of each test. Testing shall be completed on a rotating basis such that no single si lo within COMG 3 is tested twice before all other si los have been tested. This requirement expires upon startup of the Project. The previous permit action did not include monitoring or recordkeeping for the existing PM10 l imits; therefore, performance testing is required by this permit action and due 24 calendar months after permit issuance date. This performance testing allows the Permittee to demonstrate compliance if the Permittee decides to forgo the construction and completion of the Project.

COMG 4 – Bucket Elevator and Silo 3 Operations

PM10 <= 0.009 lb/hr 3-hour average PM2.5 <= 0.009 lb/hr 3-hour average

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

Performance testing

Performance testing for PM10 and PM2.5 will be used to verify compliance with emission l imits. Testing frequencies are typically set at 12, 36, or 60-month increments and are based on the initial test results, applicable rules, potential emissions, location of source, and past compliance history. The testing frequencies will be stated in the NOC/NOV letter.



Opacity <= 20% opacity PM <= 0.30 gr/dscf [Minn. R. 7011.0715]


None

The Permittee is able to use the daily EQUI 1 throughput and emission factor to calculate the daily average emission rate. Performance testing at COMG 3 is to verify the emission factor used in compliance calculations. These records, and the l imits and associated monitoring for the associated control, provide adequate assurance of compliance with the l imits.

Other l imits at TREAs 1 and 5 (and associated monitoring) ensure that this applicable requirement is being met. These other operational l imits give this unit a PTE of 0.017 lb/hr. Applicable rule l imit at maximum airflow is 3.11 lb/hr.








None

The Permittee is able to use the daily EQUI 2 throughput and emission factor to calculate the daily average emission rate. Performance testing at COMG 3 is to verify the emission factor used in compliance calculations. These records, and the l imits and associated monitoring for the associated control, provide adequate assurance of compliance with the l imits. Other l imits at TREAs 2 and 6 (and associated monitoring) ensure that this applicable requirement is being met. These other operational l imits give this unit a PTE of 0.017 lb/hr. Applicable rule l imit at maximum airflow is 3.11 lb/hr.



Process Throughput <= 2,500 tons/day [Limit from SIP, Limit from SIL Analysis]

Process Throughput <= 740,000 tpy 12-month roll ing sum [Limit from SIP, Limit from SIL Analysis, Limit to avoid PSD, Limit to avoid part 70]

PM10 <= 0.15 tpy 24-hour roll ing average PM10 <= 0.15 tpy 12-month roll ing average

[Limit from SIP]

PM10 <= 0.009 lb/hr daily average

[Limit from SIP, Limit from SIL Analysis]

PM2.5 <= 0.009 lb/hr daily average [Limit from SIL Analysis]

PM10 <= 0.017 lb/hr 3-hour average

PM2.5 <= 0.017 lb/hr 3-hour average [Minn. R. 7007.0800, subp. 2(A)]

Opacity <= 20% opacity

Daily records of material throughput, monthly calculations of process throughput using the daily records; and monthly calculations and records of the 12-month roll ing sum.

None

Daily records of material throughput, daily calculation and records of emissions, performance testing

None

The Permittee is able to use their computer and ticketing system to generate throughput records on a daily basis. These daily records are then used to calculate monthly and 12-month roll ing sums to demonstrate compliance with the l imit. Because the daily process throughput fluctuates throughout the year, a 12-month roll ing sum is adequate to ensure the facil ity remains below major source PSD, major modification PSD, and part 70 thresholds as well as meets the requirements for the SIP and SIL analysis.

Other l imits at TREA 3 and associated monitoring ensure that this l imit is met. The PTE for this unit is 0.08 tpy using the maximum capacity of 200 ton/hour, controlled emission factor of 0.0000863 lb/hour, and conversion factors of 2000 lb/ton and 8760 hours/year (200 x 0.0000863 x 8760 / 2000). This gives adequate assurance of compliance with the l imits.

Performance testing for PM10 and PM2.5 will be used to verify compliance with emission l imits. Testing at worst-case conditions is a direct method for determining compliance with an emissions l imit when a CEMS is not available. Testing frequencies are typically set at 12, 36, or 60-month increments and are based on the initial test results, applicable rules, potential emissions, location of source, and past compliance history. The testing frequencies will be stated in the NOC/NOV letter.

The Permittee is able to use the daily EQUI 4 throughput and emission factor to calculate the daily average emission rate. These records, and the l imits and associated monitoring for the associated control, provide adequate assurance of compliance with the l imits.

Other l imits at TREAs 3 and 9 (and associated monitoring) ensure that this applicable requirement is being met. These other operational l imits give this unit a PTE of 0.017




PM <= 0.30 gr/dscf [Minn. R. 7011.0715]

lb/hr. Applicable rule l imit at maximum airflow is 1.54 lb/hr.


Process throughput <= 1,100 tons/day [Limit from SIP, Limit from SIL Analysis]

Process throughput <= 350,000 tpy 12-month roll ing sum [Limit from SIP, Limit from SIL Analysis, Limit to avoid PSD, Limit to avoid part 70]

PM10 <= 0.0031 lb/hr daily average [Limit from SIP, Limit from SIL Analysis]

PM2.5 <= 0.0031 lb/hr daily average

[Limit from SIL Analysis]

Opacity <= 20% opacity PM <= 0.30 gr/dscf

[Minn. R. 7011.0715]

Daily records of material throughput; monthly calculations of process throughput using the daily records; and monthly calculations and records of the 12-month roll ing sum.


None

The Permittee is able to use the flow meter on EQUI 5 to generate records on a daily basis. These daily records are then used to calculate monthly and 12-month roll ing sums to demonstrate compliance with the l imit. Because the daily process throughput fluctuates throughout the year, a 12-month roll ing sum is adequate to ensure the facil ity remains below major source PSD, major modification PSD, and part 70 thresholds as well as meets the requirements for the SIP and SIL analysis.


Other l imits at TREA 10 (and associated monitoring) ensure that this applicable requirement is being met. These other operational l imits give this unit a PTE of 0.009 lb/hr. Applicable rule l imit at maximum airflow is 2.48 lb/hr.




EQUI 6 – Pneumatic Conveyance to Silo 4 EQUI 7 – Pneumatic Conveyance to Silo 1

Silo 12 – Pneumatic Conveyance to Silo 2


None Other l imits at TREAs 3, 7, 8, 14, and 16 (and associated monitoring) ensure that this applicable requirement is being met. These other operational l imits give each of these units a PTE of 0.017 lb/hr. Applicable rule l imit at maximum airflow is 3.11 lb/hr.

EQUI 8 – Pneumatic Conveyance to Silo 9 EQUI 9 – Pneumatic Conveyance to Silo 8


Opacity <= 20% opacity

PM <= 0.30 gr/dscf [Minn. R. 7011.0715]

None Other l imits at TREAs 11, 12, and 13 (and associated monitoring) ensure that this applicable requirement is being met. These other operational l imits give each of these units a PTE of 0.017 lb/hr. Applicable rule l imit at maximum airflow is 6.14 lb/hr.

EQUI 11 – Silo 3

PM10 <= 0.0008 lb/hr daily average [Limit from SIP, Limit from SIL Analysis] PM2.5 <= 0.0008 lb/hr daily average

[Limit from SIL Analysis]

Opacity <= 20% opacity PM <= 0.30 gr/dscf

[Minn. R. 7011.0715]


None


Other l imits at TREAs 3 and 15 (and associated monitoring) ensure that this applicable requirement is being met. These other operational l imits give this unit a PTE of 0.009 lb/hr. Applicable rule l imit at maximum airflow is 0.64 lb/hr.




FUGI 3 – Paved Roads

Clean up spil led commodities [Minn. R. 7011.1005] Minimize or eliminate fugitive emissions [Minn. R. 7011.0150]

Daily visual inspections and corrective actions; sweep/clean all paved roads and parking areas monthly

The Permittee can demonstrate that fugitive emissions from the paved roads are minimized by completing a daily visible inspection, applying corrective actions when needed, and sweeping/cleaning all paved roads and parking areas monthly. Roads are used to loadout product by trucks, and trucks will be stopped or moving slowly.

TREA 1 – Silo 6 Baghouse (existing) TREA 2 – Silo 5 Baghouse (existing)

PM >= 99% control efficiency

[Limit to avoid PSD, Limit to avoid part 70]

PM10 >= 93% control efficiency [Limit to avoid PSD, Limit to avoid part 70]

PM2.5 >= 93% control efficiency [Limit to avoid part 70]

Pressure Drop >= 0.5 and <= 6 inches of water

[Limit from SIP]

Daily and periodic inspections, operation and maintenance, pressure drop, visible emissions, corrective actions, and recordkeeping

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




TREA 3 – Truck Loading and COMG 1 Baghouse (existing)

PM >= 99% control efficiency [Limit to avoid PSD, Limit to avoid part 70]

PM10 >= 93% control efficiency

[Limit to avoid PSD, Limit to avoid part 70]

PM2.5 >= 93% control efficiency [Limit to avoid part 70]

Pressure Drop >= 2 and <= 6 inches of water

[Limit from SIP]








TREA 7 – Silo 1 Baghouse TREA 8 – Slo 4 Baghouse TREA 9 – Truck Loading Baghouse TREA 10 – Bucket Elevator Baghouse


TREA 12 – Silo 8 Baghouse TREA 13 – Silo 7 Baghouse TREA 14 – Silo 4 Second Baghouse TREA 15 – Silo 3 Baghouse TREA 16 – Silo 2 Baghouse

PM >= 99% control efficiency PM10 >= 93% control efficiency [Limit to avoid PSD, Limit to avoid part 70]

PM2.5 >= 93% control efficiency [Limit to avoid part 70] Pressure Drop >= 0.5 and <= 6 inches of water [Limit from SIP]



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

3.6 Insignificant activities There are no insignificant activities at the Facility, therefore, no insignificant activities are affected by this major amendment.

3.7 Permit organization

The only item that deviates from MPCA Tempo Guidance is the listing of certain applicable requirements at the group level even though they apply at the individual level. Specifically: the PM10 and PM2.5 3-hour


average limits at COMG 2. In general, limits that apply to individual pieces of equipment should be tracked at the unit level and should not be listed at a group. For this case, the performance tests are to be completed on two members of COMG 2, and the performance tests are to verify these PM10 and PM2.5 3-hour average limits. The permit team decided that keeping these limits at the group was acceptable since the performance testing is at the group level.

3.8 Comments received Public Notice Period: [start date] – [end date] EPA Review Period: [start date] – [end date] This section will be filled in upon completion.

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 application received after the effective date of the rule (July 1, 2009). The action includes a modeling review, limits to avoid NSR, and limits to avoid part 70.

5. Conclusion

Based on the information provided by Bulk Silos the MPCA has reasonable assurance that the proposed operation of the emission facility, as described in the Air Emission Permit No. 12300391-102 and this TSD, will not cause or contribute to a violation of applicable federal regulations and Minnesota Rules. Staff members on permit team: Elizabeth Lennartson (permit engineer)

Sarah Sevcik (peer reviewer) Jennifer Carlson (enforcement) Curtis Stock (compliance) Maggie Wenger (SIP staff) Fawkes Char (SIP staff) Jim Sullivan (Modeling) Beckie Olson (data coordinator and permit writing assistant) Laurie O’Brien (administrative support)

Tempo Activities: Major Amendment (IND20200001)

Attachments: 1. PTE summary and emissions increase calculation spreadsheets

2. Subject item inventory and requirements report 3. Points calculator 4. Updates to standard permit conditions 5. Permittee’s Single Source Determination Letter

Attachment 3: Highlight version of Air Emission Permit No. 03700011-102 A copy of Permit No. 12300391-102 that highlights the proposed changes to SIP conditions is submitted to EPA for reference in reviewing Minnesota’s proposed SIP revision. [To be updated.]

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7. Appendices




Source Description


Stack Height (m)

Stack Temp

(K)



SILO1 EQUI 1; STRU

1; TREA 1


SILO2 EQUI 2; STRU

2; TREA 2



3; TREA 3

Silo No. 3-6 (fly ash) 0.1058 0.84 496279.2 4975480 213 31.09 293 31.35 0.309







TRUCK FUGI 2 TREA 4






Stack Temp (K)


Stack Dia (m)



PM10 and PM2.5

24-hr 0.0006 0.0045 496,270 4,975,470 29.9 293 19.1 0.34 3,640

PM10 and PM2.5

Annual 0.0005 0.0037



PM10 and PM2.5

24-hr 0.0011 0.009 496,281 4,975,470 27.4 293 32.1 0.18 1,800

PM10 and PM2.5

Annual 0.0009 0.0073



PM10 and PM2.5

24-hr 0.0004 0.0031 496,264 4,975,479 6.1 293 7.2 0.49 2,900

PM10 and PM2.5

Annual 0.0003 0.0027


PM10 and PM2.5

24-hr 0.0011 0.009 496,278 4,975,489 29.9 293 18.2 0.49 7,275

PM10 and PM2.5

Annual 0.0009 0.0073


PM10 and PM2.5

24-hr 0.0011 0.009 496,269 4,975,482 29.9 293 18.2 0.49 7,275

PM10 and PM2.5

Annual 0.0009 0.0073


PM10 and PM2.5

24-hr 0.0011 0.009 496,260 4,975,475 29.9 293 18.2 0.49 7,275

PM10 and PM2.5

Annual 0.0009 0.0073


PM10 and PM2.5

24-hr 0.0011 0.009 496,283 4,975,458 25.3 293 19.1 0.34 3,640

PM10 and PM2.5

Annual 0.0009 0.0073


PM10 and PM2.5

24-hr 0.0011 0.009 496,292 4,975,467 25.3 293 19.1 0.34 3,640

PM10 and PM2.5

Annual 0.0009 0.0073



PM10 and PM2.5

24-hr 0.0011 0.009 496,286 4,975,485 29.9 293 19.1 0.34 3,640

PM10 and PM2.5

Annual 0.0009 0.0073


PM10 and PM2.5

24-hr 0.0006 0.0045 496,266 4,975,466 29.9 293 19.1 0.34 3,640

PM10 and PM2.5

Annual 0.0005 0.0037


PM10 and PM2.5

24-hr 0.0001 0.0008 496,271 4,975,471 25.3 293 3.9 0.34 750

PM10 and PM2.5

Annual 0.0001 0.0007


PM10 and PM2.5

24-hr 0.0011 0.009 496,277 4,975,477 29.9 293 19.1 0.34 3,640

PM10 and PM2.5

Annual 0.0009 0.0073

Attachment 4: List of all SIP conditions in Air Emission Permit No. 03700011-102 The attached table lists all SIP conditions in Air Emission Permit No. 12300391-102 to aid in EPA’s review. All SIP conditions are written as “Title I Condition: 40 CFR 50.6(PM10 SIP)” and “Title I Condition: 40 CFR pt. 52, subp. Y”. Note that many of the requirements in the permit include non-SIP conditions. Those conditions are not listed in this table. [To be updated.]

Attachment 4: all SIP conditions in permit 12300391-102 | 1

Subject item Citation Requirement Section 5, Limits and other requirements TFAC 1 (Childs Road Terminal)

5.1.1 This permit requires modeling to demonstrate compliance with the National Ambient Air Quality Standards (NAAQS). The Permittee may not make any change at the source that would result in an increase in PM10 or PM2.5 emissions until it can be demonstrated that emissions from the facility as permitted do not cause an exceedance of the NAAQS. This includes changes that might otherwise qualify as insignificant modifications and minor or moderate amendments.

5.1.2 ACTIVITIES NOT REQUIRING A MODIFICATION TO THE SIP: The Permittee is authorized to make changes to the facility without obtaining a modification to the SIP as long as the change does not increase from any emission point, the PM10 emission rates (either lb/hr or gr/dscf) or overall PM10 emissions, or alter equipment or parameters described in Appendix A, which forms the basis of the PM10 modeling.

5.1.3 ACTIVITIES REQUIRING A MODIFICATION TO THE SIP: Activities requiring a modification of the SIP prior to the Permittee commencing the activity include, but are not limited to, the following: 1. Any decrease in stack emissions exit velocity contained in Appendix A, Table 1; 2. Any decrease in the exit point heat content of stack emissions contained in Appendix A, Table 1; 3. Any reduction in stack height below that contained in Appendix A, Table 1; 4. Any increase in stack exit diameter above that contained in Appendix A, Table 1; and 5 Any construction or modification of structures that increase the effective structural dimensions contained in Appendix A, Table 1.

5.1.4 Upon startup of the Project: ACTIVITIES REQUIRING A MODIFICATION TO THE SIP: Activities requiring a modification of the SIP prior to the Permittee commencing the activity include, but are not limited to, the following: 1. Any decrease in stack emissions exit velocity contained in Appendix A, Table 2; 2. Any decrease in the exit point heat content of stack emissions contained in Appendix A, Table 2; 3. Any reduction in stack height below that contained in Appendix A, Table 2; 4. Any increase in stack exit diameter above that contained in Appendix A, Table 2; and 5 Any construction or modification of structures that increase the effective structural dimensions contained in Appendix A, Table 2.

5.1.5 General Operation and Maintenance Requirements for the SIP: The Permittee shall operate and maintain the process and control equipment described in Appendix A according to the parameters set forth in Appendix A. The parameters were used in the computer modeling performed to demonstrate that the Childs Road portion of the PM10 maintenance area will attain compliance with the PM10 NAAQS.

5.1.6 Shutdown or Breakdown of Pollution Control Equipment: In an event of a shutdown or breakdown of pollution control equipment, the Permittee shall follow the shutdown and breakdown procedures found in Minn. R. 7019.1000.

5.1.7 Construction and Operation of SIP Emission Units: The Permittee may begin actual construction of new emission units or modification to existing emission units upon permit issuance. However, the Permittee shall not operate any new emission unit or modified emission unit until any required SIP amendment is approved by EPA.

5.1.8 Permanent Records for SIP: The Permittee shall permanently maintain the following information together with all amendments, revisions, and modifications to this information: 1. The Permittee shall maintain a file or files of information on the design, construction and operation of each emission facility, emission source, stack, structures


pertinent to modeling for downwash, and any other information required to conduct PM10 ambient air quality modeling of emissions from the facility. 2. The Permittee shall maintain a file at the facility which includes all PM10 emission compliance demonstration plans which upon approval by the MPCA or EPA become integral and enforceable parts of the SIP.

5.1.9 Non-Permanent Records for SIP: The Permittee shall retain all records at the stationary source for a period of six (6) years from the date of the required monitoring, sample, measurement, or report that corresponds with a State Implementation Plan (SIP) Title I Condition include, but not limited to the following: 1. Monitoring, Testing (if required by the Commissioner, and other Records); 2. Startup, Shutdown, Bypass and Breakdown for each piece of process equipment, control equipment, emission stack, and monitoring system; 3. Any exceedance of an emission limitation or opacity limitation and any noncompliance with an operational requirement at the facility; 4. All required documents, records, reports and plans in a form suitable for determination of the facility's compliance with the SIP by EPA or MPCA staff. The Permittee shall maintain the information at the facility in files which are easily accessible of inspection by EPA or MPCA staff, and are available for inspection.

5.1.10 Reporting: The Permittee may undertake certain changes to the facility without obtaining a modification to the SIP. However, if the Permittee does make a change, and if the change in any way affects PM10 emissions (reduces the amount or changes the concentration, size, character, velocity, direction, or location of PM10 emissions) the Permittee shall notify the Commissioner in writing at least 30 days prior to undertaking the change. The notification shall describe the change and why it does not require a modification of the SIP.

5.1.39 The Permittee is authorized to construct the Barge Unloading and Silo Addition Project ("Project") which includes the addition of EQUI 5, EQUI 8, EQUI 9, EQUI 10, TREA 5, TREA 6, TREA 7, TREA 8, TREA 9, TREA 10, TREA 11, TREA 12, TREA 13, TREA 14, TREA 15, TREA 16, and FUGI 3. Upon federal approval of the SIP Revision, the Permittee is authorized to operate the subject items listed above. The authorization to construct expires 5 years after issuance of Air Emissions Permit No. 12300391-102. The units shall meet all applicable permit requirements.

COMG 1 (Silos 1-4) 5.2.2 PM < 10 micron < 0.84 pounds per hour daily average to be calculated as described later in this permit.

5.2.3 Process Throughput: Daily Recordkeeping. On each day of operation the Permittee shall record and maintain the total quantity of all materials unloaded from rail and/or barge to the members of COMG 1. The records shall be based on the midnight to midnight calendar day period and the computer/ticketing system. This shall be recorded in written or electronic usage logs.

COMG 2 (Unloading Silos)

5.3.1 Unloading Operations: The Permittee must limit Process Throughput <= 1100 tons per day daily average. This requirement expires upon startup of the Project.

5.3.2 Unloading Operations: The Permittee must limit Process Throughput <= 100000 tons per year 12-month rolling sum. This requirement expires upon startup of the Project.

5.3.3 Upon startup of the Project: The Permittee must limit Unloading Operations Process Throughput <= 2500 tons per day daily average to be calculated as described later in this permit.

5.3.4 Upon startup of the Project: The Permittee must limit Unloading Operations Process Throughput <= 740000 tons per year 12-month rolling sum to be calculated as described later in this permit.

5.3.5 Upon startup of the Project: PM < 10 micron <= 0.009 pounds per hour daily average to be calculated as described later in this permit.

5.3.9 Unloading Operations Process Throughput. Daily Recordkeeping. On each day of operation the Permittee shall record and maintain the total quantity of all materials


unloaded from rail and barge. The records shall be based on the midnight to midnight calendar day period and the computer/ticketing system. This shall be recorded in written or electronic usage logs.

EQUI 1 (Pneumatic Conveyance to Silo 6)

5.5.1 PM < 10 micron < 0.25 pounds per hour daily average to be calculated as described later in this permit. This requirement expires upon startup of the Project.

5.5.4 Process Throughput: Daily Recordkeeping. On each day of operation the Permittee shall record and maintain the total quantity of all materials unloaded from rail and/or barge to EQUI 1. The records shall be based on the midnight to midnight calendar day period and the computer/ticketing system. This shall be recorded in written or electronic usage logs. This requirement expires upon startup of the Project.

5.5.6 The Permittee shall vent emissions from EQUI 1 to control equipment meeting the requirements of TREA 1 whenever EQUI 1 operates. This requirement expires upon startup of TREA 5.

5.5.7 Upon startup of TREA 5: The Permittee shall vent emissions from EQUI 1 to control equipment meeting the requirements of TREA 5 whenever EQUI 1 operates.


5.6.1 PM < 10 micron < 0.25 pounds per hour daily average to be calculated as described later in this permit. This requirement expires upon startup of the Project.

5.6.4 Process Throughput: Daily Recordkeeping. On each day of operation the Permittee shall record and maintain the total quantity of all materials unloaded from rail and/or barge to EQUI 2. The records shall be based on the midnight to midnight calendar day period and the computer/ticketing system. This shall be recorded in written or electronic usage logs. This requirement expires upon startup of the Project.



EQUI 4 (Truck Loading Operations)

5.7.1 PM < 10 micron <= 0.15 tons per year 24-hour rolling average. This requirement expires upon startup of the Project.

5.7.2 PM < 10 micron <= 0.15 tons per year 12-month rolling average. This requirement expires upon startup of the Project.

5.7.3 Upon startup of the Project: The Permittee must limit Truck Loading Operations Process Throughput <= 2500 tons per day daily average to be calculated as described later in this permit.

5.7.4 Upon startup of the Project: The Permittee must limit Truck Loading Operations Process Throughput <= 740000 tons per year 12-month rolling sum.


5.7.9 Truck Loading Operations Process Throughput. Daily Recordkeeping. On each day of operation the Permittee shall record and maintain the total quantity of all materials loaded into the truck loading operation (EQUI 4). The records shall be based on the midnight to midnight calendar day period and the computer/ticketing system. This shall be recorded in written or electronic usage logs.



EQUI 5 (Bucket Elevator)

5.8.1 Upon startup of the Project: The Permittee must limit Bucket Elevator Process Throughput <= 1100 tons per day daily average to be calculated as described later in this permit.

5.8.2 Upon startup of the Project: The Permittee must limit Bucket Elevator Process Throughput <= 350000 tons per year 12-month rolling sum.


5.8.3 PM < 10 micron <= 0.0031 pounds per hour daily average to be calculated as described later in this permit.

5.8.5 Bucket Elevator Process Throughput. Daily Recordkeeping. On each day of operation the Permittee shall record and maintain the total quantity of all materials processed by the Bucket Elevator (EQUI 5). The records shall be based on the midnight to midnight calendar day period and flow meter readings. This shall be recorded in written or electronic usage logs.

5.8.11 The Permittee shall vent emissions from EQUI 5 to control equipment meeting the requirements of TREA 10 whenever EQUI 5 operates.


5.9.3 The Permittee shall vent emissions from EQUI 6 to control equipment meeting the requirements of TREA 3 whenever EQUI 6 operates. This requirement expires upon startup of TREA 8 and/or TREA 14.

5.9.4 Upon startup of TREA 8 and/or TREA 14: The Permittee shall vent emissions from EQUI 6 to control equipment meeting the requirements of TREA 8 and/or TREA 14 whenever EQUI 6 operates.










EQUI 11 (Silo 3) 5.14.3 The Permittee shall vent emissions from EQUI 11 to control equipment meeting the requirements of TREA 3 whenever EQUI 11 operates. This requirement expires upon startup of TREA 15.



5.14.7 Upon startup of the Project: Process Throughput: Daily Recordkeeping. On each day of operation the Permittee shall record and maintain the total quantity of all materials processed through EQUI 11. The records shall be based on the midnight to midnight calendar day period and the computer/ticketing system. This shall be recorded in written or electronic usage logs.



5.15.4 Upon startup of TREA 16: The Permittee shall vent emissions from EQUI 12to control equipment meeting the requirements of TREA 16 whenever EQUI 12 operates.

TREA 1 (Silo 6 Baghouse – existing)

5.17.2 The Permittee shall vent emissions from EQUI 1 to TREA 1 whenever EQUI 1 operates, and operate and maintain TREA 1 at all times that any emissions are vented to TREA 1. The Permittee shall document periods of non-operation of the control equipment TREA 1 whenever EQUI 1 is operating.

5.17.3 If the Permittee replaces TREA 1, the replacement control must meet or exceed the control efficiency requirements of TREA 1 as well as comply with all other requirements of TREA 1. Prior to making such a change, the Permittee shall apply for and obtain the appropriate permit amendment, as applicable. If no amendment is needed for the replacement, the Permittee shall submit an


electronic notice to the Agency using Form CR-05. The notice must be received by the Agency seven working days prior to the commencement/start of replacement.

5.17.8 Visible Emissions: The Permittee shall check the fabric filter stack STRU 1 for any visible emissions once each day of operation during daylight hours.

5.17.9 Recordkeeping of Visible Emissions: The Permittee shall record every 24 hours during operation the time and date of each visible emission inspection and whether or not any visible emissions were observed, and take the appropriate corrective actions. The permittee shall record every calendar day the total time the emission unit is in operation during that calendar day.

5.17.10 Recordkeeping of Pressure Drop. The Permittee shall record every 24 hours, if in operation, the time and date of each pressure drop reading and whether or not the recorded pressure drop was within the range specified in this permit and take the appropriate corrective actions. If pressure drop range exceed the permitted limit, the Permittee shall report it as a deviation in the Company's semiannual report. The permittee shall record every calendar day the total time the emission unit is in operation during that calendar day.

5.17.15 Pressure Drop >= 0.5 and <= 6.0 inches of water, unless a new range is set pursuant to Minn. R. 7017.2025, subp. 3 based on the values recorded during the most recent MPCA-approved performance test where compliance was demonstrated. The new range shall be implemented upon receipt of the Notice of Compliance letter granting preliminary approval. The range is final upon issuance of a permit amendment incorporating the change. If the recorded pressure drop is outside the required range, the emissions during that time shall be considered uncontrolled until the pressure drop is once again within the required range. The period of time for which the pressure drop is considered out of range shall be reported as a deviation. The Permittee shall record the pressure drop at least once every 24 hours when in operation.

TREA 2 (Silo 5 Baghouse – existing)


5.18.3 If the Permittee replaces TREA 2, the replacement control must meet or exceed the control efficiency requirements of TREA 2 as well as comply with all other requirements of TREA 2. Prior to making such a change, the Permittee shall apply for and obtain the appropriate permit amendment, as applicable. If no amendment is needed for the replacement, the Permittee shall submit an electronic notice to the Agency using Form CR-05. The notice must be received by the Agency seven working days prior to the commencement/start of replacement.

5.18.8 Visible Emissions: The Permittee shall check the fabric filter stack (STRU 2) for any visible emissions once each day of operation during daylight hours.


5.18.10 Recordkeeping of Pressure Drop. The Permittee shall record every 24 hours, if in operation, the time and date of each pressure drop reading and whether or not the recorded pressure drop was within the range specified in this permit and take the appropriate corrective actions. If pressure drop range exceed the permitted limit, the Permittee shall report it as a


deviation in the Company's semiannual report. The permittee shall record every calendar day the total time the emission unit is in operation during that calendar day.


TREA 3 (Truck Loading and COMG 1 Baghouse – existing)

5.19.2 The Permittee shall vent emissions from EQUI 4, EQUI 6, EQUI 7, EQUI 11, and/or EQUI 12 to TREA 3 whenever EQUI 4, EQUI 6, EQUI 7, EQUI 11, and/or EQUI 12 operates, and operate and maintain TREA 3 at all times that any emissions are vented to TREA 3. The Permittee shall document periods of non-operation of the control equipment TREA 3 whenever EQUI 4, EQUI 6, EQUI 7, EQUI 11, and/or EQUI 12 is operating. Upon startup of TREA 7, TREA 8, TREA 9, TREA 14, TREA 15, and/or TREA 16: The Permittee shall vent emissions from EQUI 4, EQUI 6, EQUI 7, EQUI 11, and/or EQUI 12 to TREA 9, TREA 8 and/or TREA 14, TREA 7, TREA 15, and TREA 16, respectively whenever EQUI 4, EQUI 6, EQUI 7, EQUI 11, and/or EQUI 12 operates, and operate and maintain TREA 7, TREA 8, TREA 9, TREA 14, TREA 15, and TREA 16 at all times that any emissions are vented to them. The Permittee shall document periods of non-operation of the control equipment listed above whenever EQUI 4, EQUI 6, EQUI 7, EQUI 11, and/or EQUI 12 is operating. See additional requirements at TREA 7, TREA 8, TREA 9, TREA 14, TREA 15, and TREA 16.


5.19.8 Visible Emissions: The Permittee shall check the fabric filter stack STRU 3 for any visible emissions once each day of operation during daylight hours.





TREA 5 (Silo 6 Baghouse)








5.21.1 The Permittee shall vent emissions from EQUI 2 to TREA 6whenever EQUI 2 operates, and operate and maintain TREA 6 at all times that any emissions are vented to TREA 6.


The Permittee shall document periods of non-operation of the control equipment TREA 6 whenever EQUI 2 is operating.







5.22.1 Upon startup of TREA 7: The Permittee shall vent emissions from EQUI 7 to TREA 7 whenever EQUI 7 operates, and operate and maintain TREA 7 at all times that any emissions are vented to TREA 7. The Permittee shall document periods of non-operation of the control equipment TREA 7 whenever EQUI 7 is operating.




The permittee shall record every calendar day the total time the emission unit is in operation during that calendar day.





5.23.1 Upon startup of TREA 8: The Permittee shall vent emissions from EQUI 6 to TREA 8 and/or TREA 14 whenever EQUI 6 operates, and operate and maintain TREA 8 and/or TREA 14 at all times that any emissions are vented to TREA 8 and/or TREA 14. The Permittee shall document periods of non-operation of the control equipment TREA 8 and/or TREA 14 whenever EQUI 6 is operating.





5.23.14 Pressure Drop >= 0.5 and <= 6.0 inches of water, unless a new range is set pursuant to Minn. R. 7017.2025, subp. 3 based on the values recorded during the most recent


MPCA-approved performance test where compliance was demonstrated. The new range shall be implemented upon receipt of the Notice of Compliance letter granting preliminary approval. The range is final upon issuance of a permit amendment incorporating the change. If the recorded pressure drop is outside the required range, the emissions during that time shall be considered uncontrolled until the pressure drop is once again within the required range. The period of time for which the pressure drop is considered out of range shall be reported as a deviation. The Permittee shall record the pressure drop at least once every 24 hours when in operation.

TREA 9 (Truck Loading Baghouse)

5.24.1 Upon startup of TREA 9: The Permittee shall vent emissions from EQUI 4 to TREA 9 whenever EQUI 4 operates, and operate and maintain TREA 9 at all times that any emissions are vented to TREA 9. The Permittee shall document periods of non-operation of the control equipment TREA 9whenever EQUI 4 is operating.






TREA 10 (Bucket Elevator Baghouse)












5.27.14 Pressure Drop >= 0.5 and <= 6.0 inches of water, unless a new range is set pursuant to Minn. R. 7017.2025, subp. 3 based on the values recorded during the most recent MPCA-approved performance test where compliance was demonstrated. The new range shall be implemented upon receipt of the Notice of Compliance letter granting preliminary approval. The range is final upon issuance of a permit amendment


incorporating the change. If the recorded pressure drop is outside the required range, the emissions during that time shall be considered uncontrolled until the pressure drop is once again within the required range. The period of time for which the pressure drop is considered out of range shall be reported as a deviation. The Permittee shall record the pressure drop at least once every 24 hours when in operation.








TREA 14 (Silo 4 Second Baghouse)

5.29.1 Upon startup of TREA 14: The Permittee shall vent emissions from EQUI 6 to TREA 8 and/or TREA 14 whenever EQUI 6 operates, and operate and maintain TREA 8 and/or TREA 14 at all times that any emissions are vented to TREA 8 and/or TREA 14. The Permittee shall document periods of non-operation of the control equipment TREA 8 and/or TREA 14 whenever EQUI 6 is operating.

5.29.2 If the Permittee replaces TREA 14, the replacement control must meet or exceed the control efficiency requirements of TREA 14 as well as comply with all other requirements of TREA 14. Prior to making such a change, the Permittee shall apply for


and obtain the appropriate permit amendment, as applicable. If no amendment is needed for the replacement, the Permittee shall submit an electronic notice to the Agency using Form CR-05. The notice must be received by the Agency seven working days prior to the commencement/start of replacement.










5.30.9 Recordkeeping of Pressure Drop. The Permittee shall record every 24 hours, if in operation, the time and date of each pressure drop reading and whether or not the


recorded pressure drop was within the range specified in this permit and take the appropriate corrective actions. If pressure drop range exceed the permitted limit, the Permittee shall report it as a deviation in the Company's semiannual report. The permittee shall record every calendar day the total time the emission unit is in operation during that calendar day.








5.31.14 Pressure Drop >= 0.5 and <= 6.0 inches of water, unless a new range is set pursuant to Minn. R. 7017.2025, subp. 3 based on the values recorded during the most recent MPCA-approved performance test where compliance was demonstrated. The new range shall be implemented upon receipt of the Notice of Compliance letter granting preliminary approval. The range is final upon issuance of a permit amendment incorporating the change. If the recorded pressure drop is outside the required range, the emissions during that time shall be considered uncontrolled until the pressure drop is once again within the


required range. The period of time for which the pressure drop is considered out of range shall be reported as a deviation. The Permittee shall record the pressure drop at least once every 24 hours when in operation.

Submittal/action requirements TFAC 1 (Childs Road Terminal)

6.1.1 PM10 Performance Test Corrective Actions: The Permittee shall submit a computer dispersion modeling protocol for PM10 refined modeling : Due 180 days after the Permittee receives a 2nd notice of noncompliance (NON) from the MPCA stating that they have failed to pass the PM10 emission rate performance test at COMG 2, COMG 4, and/or EQUI 4. Upon receipt of the first NON, the Permittee will retest one more time to measure emissions. The protocol will describe the proposed modeling methodology and input data, in accordance with MPCA modeling guidance for Title V air dispersion modeling analyses.

6.1.2 PM < 10 micron: The Permittee shall submit computer dispersion modeling results due 270 calendar days after the Permittee receives a 2nd notice of noncompliance (NON) from the MPCA stating that they have failed to pass the PM10 emission rate performance test at COMG 2, COMG 4, and/or EQUI 4.

6.1.5 Annual Report for SIP: due 30 days after end of each calendar year following Permit Issuance to the Commissioner. The report shall contain the following information: a record of data used in calculating PM10 emissions, and calculations of the PM10 emissions; a record of each unscheduled startup, shutdown, and breakdown of process and control equipment; a summary record of excess PM10 emissions, opacity exceedances and noncompliance with fugitive emissions requirements (or the Permittee shall state if no exceedances, and noncompliance conditions occurred in the calendar year).

COMG 2 (Unloading Silos)

6.2.1 PM < 10 micron: The Permittee shall conduct an initial performance test due 180 calendar days after startup of the Project and at a minimum every 60 months thereafter to verify the emission factor of 0.0000863 lb/ton. The Commissioner will set the subsequent test frequency as stated in a Notice of Compliance (NOC) or Notice of Verification (NOV) letter with review of the initial performance test. Subsequent tests shall be completed no less than every 60-months by the due date (month and day) based on the initial test date or more frequently as stated in the NOC/NOV letter. If the Commissioner sets a test frequency at less than every 60 months, the Permittee must apply for an administrative amendment to incorporate the prescribed test frequency into the permit. A major amendment is required to reduce the test frequency once set in the permit. The performance test shall be conducted at worst-case conditions defined at Minn. R. 7017.2005, subp. 8 or at the operating conditions described at Minn. R. 7017.2025, subp. 2, using EPA Reference Methods 201A and 202, or other method approved by MPCA in the performance test plan approval. Testing shall be completed on two members of COMG 2. Testing shall be completed on a rotating basis such that no single silo within COMG 2 is tested twice before all other silos have been tested once. Testing conducted during the 60 days prior to a performance test due date will not reset the due date for future testing. Testing conducted more than 60 days prior to the specified due date satisfies this test due date requirement but will reset future performance test due dates based on the most recent performance test date.


6.2.3 PM < 10 micron: The Permittee shall conduct an initial performance test due 180 calendar days after startup of the Project and at a minimum every 60 months thereafter to measure emissions. The Commissioner will set the subsequent test frequency as stated in a Notice of Compliance (NOC) or Notice of Verification (NOV) letter with review of the initial performance test. Subsequent tests shall be completed no less than every 60-months by the due date (month and day) based on the initial test date or more frequently as stated in the NOC/NOV letter. If the Commissioner sets a test frequency at less than every 60 months, the Permittee must apply for an administrative amendment to incorporate the prescribed test frequency into the permit. A major amendment is required to reduce the test frequency once set in the permit. The performance test shall be conducted at worst-case conditions defined at Minn. R. 7017.2005, subp. 8 or at the operating conditions described at Minn. R. 7017.2025, subp. 2, using EPA Reference Methods 201A and 202, or other method approved by MPCA in the performance test plan approval. Testing shall be completed on two members of COMG 2. Testing shall be completed on a rotating basis such that no single silo within COMG 2 is tested twice before all other silos have been tested once. Testing conducted during the 60 days prior to a performance test due date will not reset the due date for future testing. Testing conducted more than 60 days prior to the specified due date satisfies this test due date requirement but will reset future performance test due dates based on the most recent performance test date. See PM10 Performance Test Corrective Actions requirement under section 6 at TFAC 1.

COMG 3 (Existing Unloading Silos)

6.3.1 PM < 10 micron: The Permittee shall conduct an initial performance test due 24 months after Permit Issuance Date and at a minimum every 60 months thereafter to verify the emission factor of 0.0000863 lb/ton. The Commissioner will set the subsequent test frequency as stated in a Notice of Compliance (NOC) or Notice of Verification (NOV) letter with review of the initial performance test. Subsequent tests shall be completed no less than every 60-months by the due date (month and day) based on the initial test date or more frequently as stated in the NOC/NOV letter. If the Commissioner sets a test frequency at less than every 60 months, the Permittee must apply for an administrative amendment to incorporate the prescribed test frequency into the permit. A major amendment is required to reduce the test frequency once set in the permit. The performance test shall be conducted at worst-case conditions defined at Minn. R. 7017.2005, subp. 8 or at the operating conditions described at Minn. R. 7017.2025, subp. 2, using EPA Reference Methods 201A and 202, or other method approved by MPCA in the performance test plan approval. Testing shall be completed on two members of COMG 3. Testing shall be completed on a rotating basis such that no single silo within COMG 3 is tested twice before all other


silos have been tested once. Testing conducted during the 60 days prior to a performance test due date will not reset the due date for future testing. Testing conducted more than 60 days prior to the specified due date satisfies this test due date requirement but will reset future performance test due dates based on the most recent performance test date. This requirement expires upon startup of the Project.

COMG 4 (Bucket Elevator and Silo 3 Operations)

6.4.1 PM < 10 micron: The Permittee shall conduct an initial performance test due 180 calendar days after startup of the Project and at a minimum every 60 months thereafter to verify the emission factor of 0.0000863 lb/ton. Testing shall be completed on simultaneous operation of EQUI 5 and EQUI 11. The emission factor value applies individually to STRU 12 and STRU 32. The Commissioner will set the subsequent test frequency as stated in a Notice of Compliance (NOC) or Notice of Verification (NOV) letter with review of the initial performance test. Subsequent tests shall be completed no less than every 60-months by the due date (month and day) based on the initial test date or more frequently as stated in the NOC/NOV letter. If the Commissioner sets a test frequency at less than every 60 months, the Permittee must apply for an administrative amendment to incorporate the prescribed test frequency into the permit. A major amendment is required to reduce the test frequency once set in the permit. The performance test shall be conducted at worst-case conditions defined at Minn. R. 7017.2005, subp. 8 or at the operating conditions described at Minn. R. 7017.2025, subp. 2, using EPA Reference Methods 201A and 202, or other method approved by MPCA in the performance test plan approval. Testing conducted during the 60 days prior to a performance test due date will not reset the due date for future testing. Testing conducted more than 60 days prior to the specified due date satisfies this test due date requirement but will reset future performance test due dates based on the most recent performance test date.

6.4.3 PM < 10 micron: The Permittee shall conduct an initial performance test due 180 calendar days after startup of the Project and at a minimum every 60 months thereafter to measure emissions. Testing shall be completed on simultaneous operation of EQUI 5 and EQUI 11 with emissions measured from STRU 12 and STRU 32 combined. The Commissioner will set the subsequent test frequency as stated in a Notice of Compliance (NOC) or Notice of Verification (NOV) letter with review of the initial performance test. Subsequent tests shall be completed no less than every 60-months by the due date (month and day) based on the initial test date or more frequently as stated in the NOC/NOV letter. If the Commissioner sets a test frequency at less than every 60 months, the Permittee must apply for an administrative amendment to incorporate the prescribed test frequency into the permit. A major amendment is required to reduce the test frequency once set in the permit.


The performance test shall be conducted at worst-case conditions defined at Minn. R. 7017.2005, subp. 8 or at the operating conditions described at Minn. R. 7017.2025, subp. 2, using EPA Reference Methods 201A and 202, or other method approved by MPCA in the performance test plan approval. Testing conducted during the 60 days prior to a performance test due date will not reset the due date for future testing. Testing conducted more than 60 days prior to the specified due date satisfies this test due date requirement but will reset future performance test due dates based on the most recent performance test date. See PM10 Performance Test Corrective Actions requirement under section 6 at TFAC 1.

EQUI 4 (Truck Loading Operations)

6.5.1 PM < 10 micron: The Permittee shall conduct an initial performance test due 180 calendar days after startup of the Project and at a minimum every 60 months thereafter to verify the emission factor of 0.0000863 lb/ton. The Commissioner will set the subsequent test frequency as stated in a Notice of Compliance (NOC) or Notice of Verification (NOV) letter with review of the initial performance test. Subsequent tests shall be completed no less than every 60-months by the due date (month and day) based on the initial test date or more frequently as stated in the NOC/NOV letter. If the Commissioner sets a test frequency at less than every 60 months, the Permittee must apply for an administrative amendment to incorporate the prescribed test frequency into the permit. A major amendment is required to reduce the test frequency once set in the permit. The performance test shall be conducted at worst-case conditions defined at Minn. R. 7017.2005, subp. 8 or at the operating conditions described at Minn. R. 7017.2025, subp. 2, using EPA Reference Methods 201A and 202, or other method approved by MPCA in the performance test plan approval. Testing conducted during the 60 days prior to a performance test due date will not reset the due date for future testing. Testing conducted more than 60 days prior to the specified due date satisfies this test due date requirement but will reset future performance test due dates based on the most recent performance test date.



The performance test shall be conducted at worst-case conditions defined at Minn. R. 7017.2005, subp. 8 or at the operating conditions described at Minn. R. 7017.2025, subp. 2, using EPA Reference Methods 201A and 202, or other method approved by MPCA in the performance test plan approval. Testing conducted during the 60 days prior to a performance test due date will not reset the due date for future testing. Testing conducted more than 60 days prior to the specified due date satisfies this test due date requirement but will reset future performance test due dates based on the most recent performance test date. See PM10 Performance Test Corrective Actions requirement under section 6 at TFAC 1.

Attachment 5: Air Emission Permit No. 03700011-102 showing only SIP conditions to be incorporated by reference The attached version of Air Emission Permit No. 12300391-102 contains only the SIP conditions that will be relevant upon approval of this submittal by EPA. This document is used by EPA to incorporate these permit conditions by reference into federal law. [To be updated.]

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Table of Contents

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12300391-102



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7. Appendices




Source Description


Stack Height (m)

Stack Temp

(K)



SILO1 EQUI 1; STRU

1; TREA 1


SILO2 EQUI 2; STRU

2; TREA 2



3; TREA 3

Silo No. 3-6 (fly ash) 0.1058 0.84 496279.2 4975480 213 31.09 293 31.35 0.309







TRUCK FUGI 2 TREA 4






Stack Temp (K)


Stack Dia (m)



PM10 and PM2.5

24-hr 0.0006 0.0045 496,270 4,975,470 29.9 293 19.1 0.34 3,640

PM10 and PM2.5

Annual 0.0005 0.0037



PM10 and PM2.5

24-hr 0.0011 0.009 496,281 4,975,470 27.4 293 32.1 0.18 1,800

PM10 and PM2.5

Annual 0.0009 0.0073



PM10 and PM2.5

24-hr 0.0004 0.0031 496,264 4,975,479 6.1 293 7.2 0.49 2,900

PM10 and PM2.5

Annual 0.0003 0.0027


PM10 and PM2.5

24-hr 0.0011 0.009 496,278 4,975,489 29.9 293 18.2 0.49 7,275

PM10 and PM2.5

Annual 0.0009 0.0073


PM10 and PM2.5

24-hr 0.0011 0.009 496,269 4,975,482 29.9 293 18.2 0.49 7,275

PM10 and PM2.5

Annual 0.0009 0.0073


PM10 and PM2.5

24-hr 0.0011 0.009 496,260 4,975,475 29.9 293 18.2 0.49 7,275

PM10 and PM2.5

Annual 0.0009 0.0073


PM10 and PM2.5

24-hr 0.0011 0.009 496,283 4,975,458 25.3 293 19.1 0.34 3,640

PM10 and PM2.5

Annual 0.0009 0.0073


PM10 and PM2.5

24-hr 0.0011 0.009 496,292 4,975,467 25.3 293 19.1 0.34 3,640

PM10 and PM2.5

Annual 0.0009 0.0073



PM10 and PM2.5

24-hr 0.0011 0.009 496,286 4,975,485 29.9 293 19.1 0.34 3,640

PM10 and PM2.5

Annual 0.0009 0.0073


PM10 and PM2.5

24-hr 0.0006 0.0045 496,266 4,975,466 29.9 293 19.1 0.34 3,640

PM10 and PM2.5

Annual 0.0005 0.0037


PM10 and PM2.5

24-hr 0.0001 0.0008 496,271 4,975,471 25.3 293 3.9 0.34 750

PM10 and PM2.5

Annual 0.0001 0.0007


PM10 and PM2.5

24-hr 0.0011 0.009 496,277 4,975,477 29.9 293 19.1 0.34 3,640

PM10 and PM2.5

Annual 0.0009 0.0073

Attachment 6: Table of allowable PM10 emission changes This table provides a summary of the changes to PM10 emission limits proposed as part of this SIP revision. This is the same table that was provided in the background document.

24-Hour Average Annual Average Emissions Unit MPCA ID Existing SIP

PM10 Limit (lb/hr)

New SIP PM10 Limit

(lb/hr)

Change to SIP PM10

Limit (lb/hr)

Existing SIP PM10 Limit

(tpy)

New SIP PM10 Limit

(tpy)

Change to SIP PM10

Limit (tpy)


EQUI 1 0.25 --+ -0.25 -- -- --


EQUI 2 0.25 --+ -0.25 -- -- --

Former EQUI 3 COMG 1 (EQUI 3)* 0.84 --* -0.84 -- -- --

Truck Loading Operations EQUI 4 0.15 0.009 -0.141 0.15 -- -0.15 Unpaved Roads FUGI 2 0.30 -- -0.30 0.30 -- -0.30 Bucket Elevator EQUI 5 -- 0.0031 0.0031 -- -- -- Unloading Silos COMG 2 -- 0.009 0.009 -- -- -- Silo 3 EQUI 11 -- 0.0008 0.0008 -- -- -- Major Amendment Impacts to PM10 SIP

Limits -1.77 -0.45

+Upon startup of the new operating scenario (“the Project”), the Permittee will have the ability to unload product into EQUIs 1, 2, 6, 7, 8, 9, 10, or 12. Therefore, COMG 2 was created with these EQUIs. They are collectively subject to the Unloading Process Throughput limits and the “New SIP PM10 Limit” of 0.009 lb/hr. This is why the “New SIP PM10 Limit” column is blank for EQUI 1 and EQUI 2. *EQUI 3 was previously comprised of four individual emission units: EQUI 6, EQUI 7, EQUI 11, and EQUI 12. These four units are subject to the combined PM10 limit of 0.84 lb/hr at COMG 1 until startup of the Project. Then, the PM10 limit for EQUIs 6, 7, and 12 will be encompassed by the PM10 limit at COMG 2 and the PM10 limit for EQUI 11 will be at EQUI 11. This is why the “New SIP PM10 Limit” column is blank for COMG 1.

Attachment 7: Public notice [This section to be updated after public notice period has ended] Draft Permit No. 12300391-102 and the proposed SIP revision were on public notice from April xx, 2021 to May xx, 2021. The notice was published electronically via GovDelivery, and all permit and SIP documents were made available on the MPCA public notice website: https://www.pca.state.mn.us/public-notices. This attachment includes a copy of the web notice published on the MPCA’s website [to be added].


Attachment 8: Completeness review A. Administrative materials (40 CFR pt. 51, Appendix V, Part 2.1) The EPA’s Criteria for Determining the Completeness of Plan Submittals, published at 40 CFR part 51, Appendix V, requires states to provide the basic documents that show that the State has properly followed the administrative requirements called for by the CAA for the adoption of SIPs. The requirements, and how this SIP revision complies with these requirements, are discussed here: 1) Formal Letter of Submittal:

“A formal letter of submittal from the Governor or his designee, requesting EPA approval of the plan or revision thereof.”

Attached to this SIP revision request is a formal letter of submittal from the MPCA Commissioner, Laura Bishop, to the EPA Region 5 Administrator, xxxxxx [to be included in final document]. The office of the Commissioner of the MPCA is statutorily created in Minnesota statute § 116.03, subd. 1 (a). The Commissioner is appointed by the Governor, and the duties of the position include acting as the state agent to “apply for, receive, and disburse federal funds made available to the state by federal law or rule and regulations promulgated thereunder for any purpose related to the power and duties of the MPCA or the Commissioner. The Commissioner shall comply with any and all requirements of such federal law or such rules and regulations promulgated thereunder to facilitate application for, receipt, and disbursement of such funds.” Minn. Stat. § 116.03 subd. 3. 2) Evidence of State Adoption of Plan and Issuance of Orders in Final Form

“Evidence that the State has adopted the plan in the State code or body of regulations; or issued the permit, order, consent agreement (hereafter ‘document’) in final form. That evidence shall include the date of adoption or final issuance as well as the effective date of the plan, if different from the adoption/issuance date.”

[To be updated.] Attachment 1 contains the State Individual Permit (No. 12300391-102) issued to Bulk Silos. The State Individual Permit contains the relevant Title I SIP conditions, labeled “40 CFR pt. 51, Title I Condition: 40 CFR 50.6(PM10 SIP)”. This Air Emission Permit became effective as soon as it was signed (xx, 2021). All Title I SIP conditions are non-expiring. 3) Legal Authority Documentation “Evidence that the State has the necessary legal authority under State law to adopt and implement the plan.” This SIP revision request is an update to the SIP for the Red Rock Road area, within the Ramsey County Coarse Particulate Matter (PM10) Maintenance Area. Attachments to previous submittals document MPCA’s legal authority to submit SIP revisions and to issue, modify, and revoke permits, as well as to enforce those permits. On May 2, 1995, EPA approved MPCA’s revised operating permit program as a SIP revision (60 FR 21447). MPCA submitted the operating permit program for inclusion in the SIP in part so that permits issued under the program could be considered federally enforceable vehicles for imposing emissions limitations on culpable source located in nonattainment areas.

EPA’s conclusion that MCPA has the authority to issue permits with non-expiring Title I SIP conditions in order to replace Administrative Orders has been further documented in an April 4, 1997 letter from Michael Sandusky of the MPCA to David Kee of EPA Region 5, a July 3, 1997 letter from David Kee of EPA Region 5 to Michael Sandusky of the MPCA and in a June 15, 2006 letter from Jay Bortzer of EPA Region 5 to David Thornton of the MPCA. Copies of these letters have been submitted with previous SIP revisions.

4) Compliance with State Procedures

“Evidence that the state followed all of the procedural requirements of the State’s laws and constitution in conducting and completing the adoption/issuance of the plan.”

MCPA complied with all relevant state procedures for issuing the permit as well as the SIP revision, including a public notice period and the opportunity to request a hearing.

5) Public Notice

“Evidence that public notice was given of the proposed change consistent with the procedures approved by the EPA, including the date of the publication of the notice.”

[This section to be updated]

The public notice for the permit issuance and subsequent SIP revision was published electronically via GovDelivery and on the MPCA website on xx, 2021 with the public comment period ending on xx, 2021. During the public comment period, a copy of the SIP revision was made available on the MCPA’s website; due to COVID 19, the MPCA office in St. Paul is not currently open to the public, meaning a hardcopy of the SIP revision is not available for review in our office at this time. A copy of the public notice can be found in Attachment 7 [to be included with final].

6) Public Hearing Certification

“Certification that public hearing(s) were held in accordance with the information provided in the public notice and the State’s laws and constitution, if applicable.”

The public notice states: “An online-only public informational meeting regarding the SIP revision will be held if one is requested during the public comment period. If such a meeting is requested, it will be held on the evening of June 8, 2021. To find out if a public meeting will be held, please contact Fawkes Char at 651-757-2327 or [email protected], after the close of the public comment period. The public information meeting will provide information, receive public input, and answer questions about the proposed SIP revision. If a public information meeting is requested, the comment period for the proposed SIP will be extended to July 8, 2021.”

7) Public Comments and State Response

“Compilation of the public comments and State’s response thereto.”

[This section to be updated]

B. Technical Support 1) Pollutants regulated “Identification of all regulated pollutants affected by the plan.” The regulated pollutant subject to this SIP revision is coarse particulate matter (PM10). 2) Source Identification

“Identification of the locations of affected sources including the EPA attainment/nonattainment designation of the locations and the state of the Attainment Plan for the affected area(s).”

The affected source within the Red Rock Road area of the Ramsey County PM10 Maintenance Area is Bulk Silos. Further information on the facility is included in the attached Technical Support Document (Attachment 2). 3) Emissions Quantification

“Quantification of the changes in the plan; allowable emissions from the affected sources; estimates of changes in current actual emissions from affected sources or, where appropriate, quantifications of the changes in actual emissions through calculations of the differences between certain baseline levels and allowable emissions anticipated as a result of the revision.”

The changes allowed in this SIP revision result in a reduction of allowable PM10 emissions from this facility. Details on the SIP changes can be found in the Background Document. 4) NAAQS Protections

“The State’s demonstration that the NAAQS, prevention of significant deterioration increments, reasonable further progress demonstration, and visibility, as applicable, are protected if the plan is approved and implemented.”

The changes allowed in this SIP revision result in a reduction of allowable PM10 emissions from this facility. Details on the SIP changes can be found in the Background Document. The proposed changes at the facility will aid the continued attainment and maintenance of the PM10 NAAQS in the Ramsey County Maintenance Area. 5) Modeling Information

“Modeling information required to support the proposed revision, including input data, output data, models used, justification of the model selections, ambient monitoring data used, meteorological data used, justification for use of off-site data (where used), modes of models used, assumptions, and other information relevant to the determination of adequacy of the modeling analysis.”

Prior permits explicitly required Bulk Silos to provide a modeling protocol for an equivalent-or-better demonstration in order to make any physical changes to the PM10 SIP-approved equipment at the facility; the relevant equipment were listed in the previous permits at Appendix B (12300391-002) and Appendix A (12300391-101). For the issuance of Permit No. 12300391-102, which included significant changes to the permit and facility operations, Bulk Silos underwent a SIL analysis for PM10. Since new equipment and processes were included in the SIL modeling relied on for the issuance of the permit, the MPCA is requesting that these new equipment and processes be incorporated into Minnesota’s SIP.

Historically, Appendices B and A included a minimal number of equipment and processes at the facility. Table 4 shows the original features and parameters used for previous modeling exercises. Table 8. Original PM10 emissions sources and parameters included in prior Appendices B and A to Bulk Silos permits

Source ID

EQUI; STRU; TREA

Source Description


Stack Height

(m)

Stack Temp

(K)



SILO1

EQUI 1; STRU 1; TREA 1


0.0318 0.25 496283.1 4975465 213 25.6 293 9.7 0.305

SILO2 EQUI 2; STRU 2; TREA 2


0.0318 0.25 496289.7 4975468 213 25.6 293 9.7 0.305

SILO3_6 EQUI 3; STRU 3; TREA 3

Silo No. 3-6 (fly ash) 0.1058 0.84 496279.2 4975480 213 31.09 293 31.35 0.309


Source ID FUGI Source

Description


Release Height

(m) σ Y (m) σ Z (m)


UNLOAD EQUI 4

Silo Unloading and Truck Loading

4.25E-03 3.37E-02 496285.3 4975474 213 3 1.41 1.39

TRUCK FUGI 2 TREA 4

Fugitive Emissions from Truck Traffic

8.58E-03 6.81E-02 496285.3 4975474 213 1 11.4 0.85

Permit No. 12300391-102 authorizes the construction of several new PM10 emissions sources. In order to approve the new conditions listed in Permit No. 12300391-102, the MPCA conducted SIL modeling to determine compliance with the PM10 NAAQS using both existing and new PM10 emissions sources. Table 5 describes the updated list, now included with Table 4 in Appendix A of the permit. Permit No. 12300391-102 replaced the equivalent-or-better demonstration language with specific triggers that would require future modeling, assuming they result in changes to the parameters in the permit Appendix A and/or include new PM10 emissions points, per the requirements listed in the permit at TFAC 1, 5.1.1 and 6.1.1. Table 9. Updated PM10 modeling sources and parameters included in, and used to issue, Permit No. 12300391-102.

Permit ID Source Description

Averaging Time

Emission Rate Location UTM NAD83 Stack

Height (m) Stack Temp

(K)

Stack Exit Vel.

(m/s)

Stack Dia (m)

Flow Rate

(ACFM) g/s lb/hr X (m) Y (m)


24-hr 0.0006 0.0045

496,270 4,975,470 29.9 293 19.1 0.34 3,640

Annual 0.0005 0.0037

STRU 11 Truck loading operation (EQUI 4, TREA 9)

24-hr 0.0011 0.009 496,281 4,975,470 27.4 293 32.1 0.18 1,800

Annual 0.0009 0.0073

STRU 12 Bucket elevator operation (EQUI 5, TREA 10)

24-hr 0.0004 0.0031 496,264 4,975,479 6.1 293 7.2 0.49 2,900

Annual 0.0003 0.0027


24-hr 0.0011 0.009 496,278 4,975,489 29.9 293 18.2 0.49 7,275

Annual 0.0009 0.0073


24-hr 0.0011 0.009 496,269 4,975,482 29.9 293 18.2 0.49 7,275

Annual 0.0009 0.0073


24-hr 0.0011 0.009 496,260 4,975,475 29.9 293 18.2 0.49 7,275

Annual 0.0009 0.0073


24-hr 0.0011 0.009 496,283 4,975,458 25.3 293 19.1 0.34 3,640

Annual 0.0009 0.0073


24-hr 0.0011 0.009 496,292 4,975,467 25.3 293 19.1 0.34 3,640

Annual 0.0009 0.0073


24-hr 0.0011 0.009 496,286 4,975,485 29.9 293 19.1 0.34 3,640

Annual 0.0009 0.0073


24-hr 0.0006 0.0045 496,266 4,975,466 29.9 293 19.1 0.34 3,640

Annual 0.0005 0.0037


24-hr 0.0001 0.0008 496,271 4,975,471 25.3 293 3.9 0.34 750

Annual 0.0001 0.0007


24-hr 0.0011 0.009 496,277 4,975,477 29.9 293 19.1 0.34 3,640

Annual 0.0009 0.0073

The results of the SIL modeling indicate that facility operations scenarios that apply after EPA approves our requested changes into the site-specific SIP for this facility will be far below the NAAQS. This includes and accounts for increased throughputs, new and replaced equipment, and other changes subsequently authorized in Permit No. 12300391-102. Table 6 shows the results of the PM10 SIL analysis. Table 10. SIL analysis results for PM10 emissions expected at the Bulk Silos facility

Averaging period SIL (µg/m3) Total modeled concentration (µg/m3) Percent of standard (%)

24-hour 5 1.08 22 Annual 1 0.3 30

Additional information regarding modeling for this facility can be found in section 3.2 of the permit Technical Support Document (Attachment 2). 6) Continuous Emission Reduction “Evidence, where necessary, that emission limitations are based on continuous emission reduction technology.” These requirements are addressed in the State Individual Permit document issued to the source (Attachment 1). 7) Emission Level Assurance

“Evidence that the plan contains emission limitations, work practice standards and recordkeeping/requirements, where necessary, to ensure emissions levels.”

These requirements are addressed in the State Individual Permit document issued to the source (Attachment 1). 8) Compliance/Enforcement “Compliance and enforcement strategies, including how compliance will be determined in practice.” These requirements are addressed in the State Individual Permit document issued to the source (Attachment 1). 9) Special Economic and Technological Justifications

“Special economic and technological justifications required by any applicable EPA policies, or an explanation of why such justifications are not necessary.”

Does not apply to this SIP submittal.

state implementation plan (sip) revision documents

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