air emission permit no. 13900002-001 is issued to bunge ... · bunge north america’s facility in...

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

AIR EMISSION PERMIT NO. 13900002- 001

IS ISSUED TO

Bunge North America, Inc.

BUNGE NORTH AMERICA INC - PORT BUNGE 12100 Yosemite Avenue South

Savage, Scott County, MN 55378 The emission units, control equipment and emission stacks at the stationary source authorized in this permit are as described in the following permit application: Permit Type Application Date Total Facility Operating Permit June 12, 1996 (updated June 5, 2006) This permit authorizes the Permittee to operate the stationary source at the address listed above unless otherwise noted in Table A. The Permittee must comply with all the conditions of the permit. Any changes or modifications to the stationary source must be performed in compliance with Minn. R. 7007.1150 to 7007.1500. Terms used in the permit are as defined in the state air pollution control rules unless the term is explicitly defined in the permit.

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

Issue Date: November 20, 2006

Expiration: Permit does not expire All Title I Conditions do not expire. Richard J. Sandberg, Manager Air Quality Permits Section Industrial Division for Brad Moore Acting Commissioner Minnesota Pollution Control Agency

TABLE OF CONTENTS

Notice to the Permittee Permit Shield Facility Description Table A: Limits and Other Requirements Table B: Submittals Table C: not used in this permit Appendix A: not used in this permit Appendix B: Insignificant Activities

NOTICE TO THE PERMITTEE:

Your stationary source may be subject to the requirements of the Minnesota Pollution Control Agency’s (MPCA) solid waste, hazardous waste, and water quality programs. If you wish to obtain information on these programs, including information on obtaining any required permits, please contact the MPCA general information number at:

Metro Area 651-296-6300

Outside Metro Area 1-800-657-3864

TTY 651-282-5332

The rules governing these programs are contained in Minn. R. chs. 7000-7105. Written questions may be sent to: Minnesota Pollution Control Agency, 520 Lafayette Road North, St. Paul, Minnesota 55155-4194.

Questions about this air emission permit or about air quality requirements can also be directed to the telephone numbers and address listed above. PERMIT SHIELD:

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

Bunge North America’s facility in Savage (Port Bunge) is a terminal elevator receiving corn and beans from farmers and other elevators. Grain is primarily received by truck, with occasional rail receiving. Most grain is shipped by barge up the Minnesota River to the Mississippi. Occasionally some grain will be shipped by truck or rail. Part or all of the particulate matter emissions are captured; those captured are controlled by baghouses. Uncaptured particulate emissions are considered fugitive and are regulated by the Minnesota Standard of Performance for Bulk Agricultural Commodity Facilities.

TABLE A: LIMITS AND OTHER REQUIREMENTS 11/20/06

Bunge North America Inc - Port Bunge

13900002 - 001

Facility Name:

Permit Number:

A-1

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

Subject Item: Total Facility

What to do Why to do itSOURCE-SPECIFIC REQUIREMENTS hdr

Process Throughput: less than or equal to 1500000 tons/year using 12-monthRolling Sum . The Permittee may decide whether to manage this limit on a "tonsreceived" or "tons shipped" basis, and must keep all records and perform allcalculations consistent with this choice.

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

Daily Recordkeeping: Each operating day, record the tons of grain received orshipped (depending on which method was chosen for showing compliance with thethroughput limit).


Monthly Recordkeeping: By the 15th day of each month, calculate and record theamount of grain (tons) received or shipped (whichever method is chosen, above)for the previous month and for the previous 12 months.


This permit requires modeling to demonstrate compliance with the NationalAmbient Air Quality Standards (NAAQS). The Permittee may not make any changeat the source that would result in an increase in PM10 emissions, until it can bedemonstrated that emissions from the facility as permitted do not cause anexceedance of the NAAQS. This includes changes that might otherwise qualify asinsignificant modifications and minor or moderate amendments. This is a state-onlyrequirement and is not enforceable by the EPA Administrator or citizens under theClean Air Act.

Minn. Stat. Section 116.07, subds. 4a & 9; Minn. R.7009.0020; Minn. R. 7007.0100; Minn. R. 7007.0800,subp. 2

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

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

OPERATIONAL REQUIREMENTS hdr

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

Minn. R. 7011.0020

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

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

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

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

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

Minn. R. 7019.1000, subp. 4

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

Minn. R. 7011.0150

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

Minn. R. 7030.0010 - 7030.0080

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

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

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

Minn. R. 7007.0800, subp. 16



13900002 - 001

Facility Name:

Permit Number:

A-2

PERFORMANCE TESTING hdr

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

Minn. R. ch. 7017

Performance Test Notifications and Submittals:

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

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

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

Minn. Rs. 7017.2030, subp. 1-4, 7017.2018 and Minn.R. 7017.2035, subp. 1-2

Limits set as a result of a performance test (conducted before or after permitissuance) apply until superseded as specified by Minn. R. 7017.2025 followingformal review of a subsequent performance test on the same unit and completion ofpermit reopening and reissuance. If limits serve to cause more stringent operatingconditions, resulting changes to facility operation need to be made immediately. Iflimits serve to relax current operating conditions, resulting changes to facilityoperation must not be made prior to issuance of permit amendment with new limitincorporated.

Minn. R. 7017.2025

MONITORING REQUIREMENTS hdr

Monitoring Equipment Calibration: Annually calibrate all required monitoringequipment (any requirements applying to continuous emission monitors are listedseparately in this permit).

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

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

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

RECORDKEEPING hdr

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

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

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

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

REPORTING/SUBMITTALS hdr

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

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

Minn. R. 7019.1000, subp. 3

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

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

Minn. R. 7019.1000, subp. 2



13900002 - 001

Facility Name:

Permit Number:

A-3

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

Minn. R. 7019.1000, subp. 1

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

Minn. R. 7019.1000, subp. 1

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

Minn. R. 7007.1150 through Minn. R. 7007.1500

Extension Requests: The Permittee may apply for an Administrative Amendmentto extend a deadline in a permit by no more than 120 days, provided the proposeddeadline extension meets the requirements of Minn. R. 7007.1400, subp. 1(H).

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

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

Minn. R. 7019.3000 through Minn. R. 7019.3100

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



13900002 - 001

Facility Name:

Permit Number:

A-4

Subject Item: GP 001 Grain Receiving

Associated Items: CE 001 Fabric Filter - Low Temperature, i.e., T<180 Degrees F

CE 002 Fabric Filter - Low Temperature, i.e., T<180 Degrees F



EU 001 Truck Receiving 1

EU 002 Rail Receiving



What to do Why to do itEMISSION LIMITS hdr

Opacity: less than or equal to 10 percent opacity from the control equipment stack.This limit applies individually to each CE unit listed in GP001.

Minn. R. 7011.1005, subp. 3.D.

Opacity: less than or equal to 5 percent opacity from fugitive emissions. This limitapplies individually to each EU unit listed in GP001.

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

CONTROL REQUIREMENTS [See Subject Items CE001, CE002, CE003, andCE004, for additional requirements]

hdr

The Permittee shall operate and maintain each fabric filter at all times that theassociated emission unit is in operation. The Permittee shall document periods ofnon-operation of the control equipment.


Particulate Matter < 10 micron: greater than or equal to 99 percent controlefficiency


Total Particulate Matter: greater than or equal to 99 percent control efficiency Title I Condition: To avoid classification as a majorsource under 40 CFR Section 52.21 and Minn. R.7007.3000 (Meets requirements of Minn. R.7011.1005, subp. 3.E.)

TESTING REQUIREMENTS hdr

Performance Test: due 180 days after Permit Issuance to measure opacity fromfugitive emissions. Choose one representative unit on which to perform the test.

Minn. R. 7017.2020, subp. 1

Performance Test Notifications and Submittals;

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

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



13900002 - 001

Facility Name:

Permit Number:

A-5

Subject Item: GP 003 Grain Handling




EU 007 Elevator Leg Boots

EU 009 Barge Loadout conveyor junction

EU 012 Leg Heads and Distributors


Opacity: less than or equal to 10 percent opacity from the control equipment stack.This limit applies individually to each CE unit listed in GP003.

Minn. R. 7011.1005, subp. 3.D

Opacity: less than or equal to 5 percent opacity from fugitive emissions. This limitapplies individually to each EU unit listed in GP003.

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

CONTROL REQUIREMENTS [See Subject Items CE005, CE006, and CE009 foradditional requirements]

hdr

The Permittee shall operate and maintain the fabric filter at all times that theemission unit is in operation. The Permittee shall document periods ofnon-operation of the control equipment.







13900002 - 001

Facility Name:

Permit Number:

A-6

Subject Item: GP 004 Grain Storage (Bin Vents)

Associated Items: EU 013 Concrete Storage Bins

EU 014 Concrete Storage Annex

EU 015 Steel Tank 30






Opacity: less than or equal to 20 percent opacity . This limit applies to each itemlisted in GP004.

Minn. R. 7011.0715, subp. 1(B)

Total Particulate Matter: less than or equal to 0.3 grains/dry standard cubic foot ofexhaust gas unless required to further reduce emissions to comply with the lessstringent limit of either Minn. R. 7011.0730 or Minn. R. 7011.0735.

Minn. R. 7011.0715, subp. 1(A)



13900002 - 001

Facility Name:

Permit Number:

A-7

Subject Item: EU 003 Truck Loadout


GP 002 Grain Loadout

SV 006 Leg heads and distributors & Truck Loadout


Opacity: less than or equal to 10 percent opacity from CE006/SV006. Minn. R. 7011.1005, subp. 3.D.

Opacity: less than or equal to 10 percent opacity from fugitive emissions. Minn. R. 7011.1005, subp. 3.B.

CONTROL REQUIREMENTS [See Subject Item CE006 for additionalrequirements]

hdr








13900002 - 001

Facility Name:

Permit Number:

A-8

Subject Item: EU 004 Rail Loadout



SV 004 Rail Receiving & Loadout



Opacity: less than or equal to 5 percent opacity from fugitive emissions. Minn. R. 7011.1005, subp. 3.A.


hdr








13900002 - 001

Facility Name:

Permit Number:

A-9

Subject Item: EU 005 Barge Loadout



SV 010 Barge Loadout



Opacity: less than or equal to 20 percent opacity from fugitive emissions, exceptthat during trimming or topping off, when normal loading procedures cannot beused, no opacity standard applies.

Minn. R. 7011.1005, subp. 3.C.


hdr





Total Particulate Matter: greater than or equal to 99 percent control efficiency Title I Condition: To avoid classification as a majorsource under 40 CFR Section 52.21 and Minn. R.7007.3000 (Meets requirements of Minn. R.7011.1005, subp. 3E.)

TESTING REQUIREMENTS hdr

Performance Test: due 180 days after Permit Issuance to measure opacity fromfugitive emissions.

Minn. R. 7017.2020, subp. 1

Performance Test Notifications and Submittals;

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

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



13900002 - 001

Facility Name:

Permit Number:

A-10

Subject Item: EU 006 Cleaning/Scalping


SV 007 Scalpers and cleaners



Opacity: less than or equal to 5 percent opacity from fugitive emissions. Minn. R. 7011.1005, subp. 3.A.


hdr








13900002 - 001

Facility Name:

Permit Number:

A-11

Subject Item: EU 011 Dust Tank


SV 011 Dust tank vent


Total Particulate Matter: less than or equal to 0.3 grains/dry standard cubic foot ofexhaust gas unless required to further reduce emissions to comply with the lessstringent limit of either Minn. R. 7011.0730 or Minn. R. 7011.0735.

Minn. R. 7011.0715, subp. 1(A)

Opacity: less than or equal to 20 percent opacity . This limit applies to the exhaustpoint (SV011) of the control equipment (CE011).

Minn. R. 7011.0715, subp. 1(B)


hdr








13900002 - 001

Facility Name:

Permit Number:

A-12

Subject Item: CE 001 Fabric Filter - Low Temperature, i.e., T<180 Degrees F

Associated Items: EU 001 Truck Receiving 1

GP 001 Grain Receiving

What to do Why to do itThe Permittee shall operate and maintain the fabric filter at all times that anyemission unit controlled by the fabric filter is in operation. The Permittee shalldocument periods of non-operation of the control equipment.

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

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

Minn. R. 7007.0800, subp. 14

Visible Emissions: The Permittee shall check the fabric filter stack (SV001) for anyvisible emissions once each day of operation during daylight hours. Duringinclement weather when visible emission readings are not possible, the Permitteeshall read and record the pressure drop across the fabric filter, once each day ofoperation.

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

Pressure Drop: greater than or equal to 0.5 inches of water column and less than orequal to 6 inches of water column , unless a new range is required to be setpursuant to Minn. R. 7017.2025, subp. 3. If a new range is required to be set, it willbe based on the values recorded during the most recent MPCA approvedperformance test where compliance was demonstrated.


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


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

Minn. R. 7007.0800, subp. 4

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

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

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

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



13900002 - 001

Facility Name:

Permit Number:

A-13







Minn. R. 7007.0800, subp. 14








Minn. R. 7007.0800, subp. 4


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


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



13900002 - 001

Facility Name:

Permit Number:

A-14







Minn. R. 7007.0800, subp. 14








Minn. R. 7007.0800, subp. 4


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


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



13900002 - 001

Facility Name:

Permit Number:

A-15


Associated Items: EU 002 Rail Receiving

EU 004 Rail Loadout





Minn. R. 7007.0800, subp. 14








Minn. R. 7007.0800, subp. 4


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


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



13900002 - 001

Facility Name:

Permit Number:

A-16


Associated Items: EU 007 Elevator Leg Boots

GP 003 Grain Handling




Minn. R. 7007.0800, subp. 14








Minn. R. 7007.0800, subp. 4


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


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



13900002 - 001

Facility Name:

Permit Number:

A-17


Associated Items: EU 003 Truck Loadout

EU 012 Leg Heads and Distributors






Minn. R. 7007.0800, subp. 14








Minn. R. 7007.0800, subp. 4


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


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



13900002 - 001

Facility Name:

Permit Number:

A-18


Associated Items: EU 006 Cleaning/Scalping




Minn. R. 7007.0800, subp. 14








Minn. R. 7007.0800, subp. 4


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


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



13900002 - 001

Facility Name:

Permit Number:

A-19


Associated Items: EU 009 Barge Loadout conveyor junction





Minn. R. 7007.0800, subp. 14








Minn. R. 7007.0800, subp. 4


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


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



13900002 - 001

Facility Name:

Permit Number:

A-20


Associated Items: EU 005 Barge Loadout





Minn. R. 7007.0800, subp. 14








Minn. R. 7007.0800, subp. 4


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


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



13900002 - 001

Facility Name:

Permit Number:

A-21


Associated Items: EU 011 Dust Tank





Minn. R. 7007.0800, subp. 14








Minn. R. 7007.0800, subp. 4


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


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

TABLE B: SUBMITTALSFacility Name: Bunge North America Inc - Port Bunge

Permit Number: 13900002 - 001

11/20/06B-1

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

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

Send any application for a permit or permit amendment to:

AQ Permit Technical Advisor Industrial Division 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 Technical Advisor notices of:- accumulated insignificant activities,- installation of control equipment,- replacement of an emissions unit, and- 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

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

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

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

TABLE B: ONE TIME SUBMITTALS OR NOTIFICATIONSFacility Name: Bunge North America Inc - Port Bunge


11/20/06B-2

What to send When to send Portion of Facility AffectedComputer Dispersion Modeling Protocol due 365 days after Permit Issuance (for

PM10). This protocol will describe theproposed modeling methodology and inputdata, in accordance with MPCA modelingguidance for Title V air dispersion modelinganalyses. The protocol will be based onequipment capabilities and permittedoperating conditions under the existing permit.This is a state-only requirement and is notenforceable by the EPA Administrator orcitizens under the Clean Air Act.

Total Facility

Computer Dispersion Modeling Results due 540 days after Permit Issuance (forPM10). To be submitted after the MPCA hasreviewed and approved the modeling protocol.The submittal should adhere to MPCAmodeling guidance for Title V air dispersionmodeling analyses. This is a state-onlyrequirement and is not enforceable by theEPA Administrator or citizens under the CleanAir Act.

Total Facility

Fugitive Control Plan due 60 days after Permit Issuance for reviewand approval by the Commissioner. The planshall identify all fugitive emission sources,primary and contingent control measures, andrecord keeping. The Permittee shall followthe actions and record keeping specified inthe control plan. The plan may be amendedby the Permittee with the Commissioner'sapproval. If the Commissioner determines thePermittee is out of compliance with Minn. R.7011.0150 or the fugitive emission controlplan, then the Permittee may be required toamend the control plan and/or to install andoperate particulate matter ambient monitors.

Total Facility

Testing Frequency Plan due 60 days after Performance Test foropacity emissions (fugitive). The plan shallspecify a testing frequency based on the testdata and MPCA guidance. Futureperformance tests based on one-year (12month), 36 month, and 60 month intervals, oras applicable, shall be required upon writtenapproval of the MPCA.

EU005

Testing Frequency Plan due 60 days after Performance Test foropacity emissions (fugitive). The plan shallspecify a testing frequency based on the testdata and MPCA guidance. Futureperformance tests based on one-year (12month), 36 month, and 60 month intervals, oras applicable, shall be required upon writtenapproval of the MPCA.

GP001

TABLE B: RECURRENT SUBMITTALSFacility Name: Bunge North America Inc - Port Bunge


11/20/06B-3

What to send When to send Portion of Facility AffectedSemiannual Deviations Report due 30 days after end of each calendar

half-year following Permit Issuance. The firstsemiannual report submitted by the Permitteeshall cover the calendar half-year in which thepermit is issued. The first report of eachcalendar year covers January 1 - June 30.The second report of each calendar yearcovers July 1 - December 31. If no deviationshave occured, the Permittee shall submit thereport stating no deviations.

Total Facility

Compliance Certification due 31 days after end of each calendar yearfollowing Permit Issuance (for the previouscalendar year). To be submitted to theCommissioner on a form approved by theCommissioner. This report covers alldeviations experienced during the calendaryear.

Total Facility

APPENDIX B: Insignificant Activities Facility Name: Bunge North America, Inc. - Port Bunge Permit Number: 13900002-001

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

Minn. R. 7007.1300,

subpart Rule Description of the Activity Likely Applicable Requirement

3(G) Emissions from a laboratory, as defined in the subpart.

The Permittee has lab facilities for the purpose of determining the quality of shipments of grain received.

Minn. R. 7011.0710/0715

3(J) Fugitive Emissions from roads and parking lots. Minn. R. 7011.0150

Technical Support Document, Permit Action Number: 13900002-001 Page 1 of 7 Date: 11/14/2006

TECHNICAL SUPPORT DOCUMENT For

AIR EMISSION PERMIT NO. 13900002-001 This technical support document is intended for all parties interested in the permit and to meet the requirements that have been set forth by the federal and state regulations (40 CFR § 70.7(a)(5) and Minn. R. 7007.0850, subp.1). The purpose of this document is to provide the legal and factual justification for each applicable requirement or policy decision considered in the determination to issue the permit. 1. General Information 1.1. Applicant and Stationary Source Location:

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

Bunge North America P.O. Box 28500 St. Louis, MO 63146

Port Bunge 12100 Yosemite Avenue South Savage, Scott County

Contact: Bob Hendricks, (314) 292-2342 1.2. Description of the Facility and Permit Action

Bunge North America’s facility in Savage (Port Bunge) is a terminal elevator receiving corn and beans from farmers and other elevators. Grain is primarily received by truck, with occasional rail receiving. Most grain is shipped by barge up the Minnesota River to the Mississippi. Occasionally some grain will be shipped by truck or rail. Particulate matter emissions from all sources are controlled by baghouses. 1.3 Description of any Changes Allowed with this Permit Issuance

No specific changes are authorized by this permit. 1.4 Permit History

Permit Number and Issuance Date

Action Authorized

393A-90-OT-2 Issued July 24, 1990

Total facility operating permit (predates Minn. R. 7007 permit rules)

Amendment 1 to 393A-90-OT-2 Issued February 20, 2002

Major Amendment, changed grain throughput limit from a monthly limit to an annual limit based on a 12 month rolling average.

1.5. Facility Emissions:

Table 1. Total Facility Potential to Emit Summary

PM tpy

PM10 tpy

Total Facility Limited Potential Emissions 35.7 10.3 Total Facility Actual Emissions (2005 emission inventory) 3.4 1.7


Table 2. Facility Classification

Classification Major/Affected Source

Synthetic Minor Minor

PSD X Part 70 Permit Program X Part 63 NESHAP X 2. Regulatory and/or Statutory Basis New Source Review

The facility is a non-major source under New Source Review, because of emission control requirements and limits on annual throughput. No changes are authorized by this permit.

Part 70 Permit Program

The facility is a non-major source under Part 70, because of emission control requirements and limits on annual throughput.

New Source Performance Standards (NSPS)

A determination was made when the most recent operating permit was issued (1990) that the facility is not subject to New Source Performance Standards for Grain Elevators (40 CFR 60, Subpart DD). The facility was originally constructed in the early 1970s. Portions were destroyed in a 1978 explosion and rebuilt in 1979. The affected facility under NSPS is the entire facility, not individual operations.

National Emission Standards for Hazardous Air Pollutants (NESHAP)

The facility is not a HAP source. Thus, no NESHAPs apply.

Minnesota State Rules

The facility is subject to the Minnesota Standards of Performance for Dry Bulk Agricultural Commodity (DBAC) Facilities, Minn. R. 7011.1000 – 1015. Certain operations at the facility that do not fall under the definitions listed in the DBAC rule are subject to the Industrial Process Equipment Rule for Post-1969 facilities, Minn. R. 7011.0715.

Table 3. Regulatory Overview of Facility

EU, GP, or SV

Applicable Regulations Comments:

EU 001 – EU010, EU012

Minn. R. 7011.1005 Operations meeting the definitions in Minn. R. 7011.1000 are subject to Minnesota Standards of Performance for Bulk Agricultural Commodity Facilities.

EU011, EU013 – EU019

Minn. R. 7011.0715 Operations not meeting the definitions in Minn. R. 7011.1000 are subject to Minnesota Standards of Performance for Industrial Process Equipment

EU 001 – EU019

Title I Condition The facility must control PM and PM10 in order to avoid being classified as a major source under 40 CFR § 52.21, as well as to avoid being a major source under Part 70.

Total Facility

Title I Condition Limit on grain throughput to avoid being classified as a major source under 40 CFR § 52.21, as well as to avoid being a major source under Part 70.


EU, GP, or SV

Applicable Regulations Comments:

Total Facility

State-only requirement * Facility is required to do dispersion modeling showing that the facility as permitted does not violate NAAQS, before any changes resulting in increased PM10 may occur.

* The language 'This is a state-only requirement and is not enforceable by the EPA Administrator and citizens under the Clean Air Act' refers to permit requirements that are mandated by state law rather than by the federal Clean Air Act. The language is to clarify the distinction between permit conditions that are required by federal law and those that are required by state law. State law requirements are not enforceable by U.S. EPA or by citizens under the federal Clean Air Act, but are fully enforceable by the MPCA and citizens under provisions of state law. 3. Technical Information 3.1 Calculations of Potential to Emit

Attachment 1 to this TSD includes calculations of the PTE of the Facility.

Capture Efficiencies: For those operations where PM/PM10 emissions are not collected through a total enclosure (grain receiving), a capture efficiency of 90% was used. The more typical assumption of 80% for a “hood” was not used, for the following reason.

The operations take place within a structure which does not meet the definition of a hood. Observation of the grain receiving operations showed that there is not a large amount of uncaptured dust emissions escaping to the environment. While trucks were unloading, there was observed a small “cloud” of dust that drifted partway toward the door, and was then “sucked” back into to the receiving pit in the floor. A document published by the University of Missouri – Columbia Extension service (“Grain Elevator and Grain Processing Air Quality Permits and Reports) lists control efficiencies to apply to a variety of control options. The configuration of the receiving pits at Port Bunge coincides with a capture efficiency of approximately 92%, according to this document. The Permittee assumed 95% in their calculations. 90% was considered a reasonable assumption for permitting purposes. No hood certification is required, since the enclosure is not a hood. The University of Missouri document is attached as Attachment 3.

For other operations where the emission are not captured via a total enclosure (grain loadout), while the capture systems are not “hoods,” a capture efficiency of 80% was nonetheless assumed. Again, no hood certification is required, since the enclosures are not hoods, and the potential emissions are well below the federal thresholds. 3.2 NAAQS

As part of the Capped Emissions Permit rulemaking, a large group of facilities were modeled using a screening level analysis. The resulting data indicated the need for a closer look at approximately 140 sources, including Port Bunge. Additional screening was performed by the MPCA using the CAPS spreadsheet (http://www.pca.state.mn.us/air/permits/capped.html#resources) and site specific information for stack heights, emission rates, and distance to property line. The results continue to indicate the possibility that the Permittee may not be compliant with the NAAQS for PM10. The Permittee is required to submit a modeling protocol and conduct the modeling after permit issuance to resolve this issue. The facility will have to demonstrate compliance with the NAAQS before being allowed to make any changes that would result in increases in PM10 emissions, including any changes that may otherwise qualify as insignificant modifications or require a minor or moderate amendment.


3.3 Periodic Monitoring

In accordance with the Clean Air Act, it is the responsibility of the owner or operator of a facility to have sufficient knowledge of the facility to certify that the facility is in compliance with all applicable requirements.

In evaluating the monitoring included in the permit, the MPCA considers the following:

• The likelihood of violating the applicable requirements;

• Whether add-on controls are necessary to meet the emission limits;

• The variability of emissions over time;

• The type of monitoring, process, maintenance, or control equipment data already available for the emission unit;

• The technical and economic feasibility of possible periodic monitoring methods; and

• The kind of monitoring found on similar units elsewhere.

Table 4 summarizes the periodic monitoring requirements for those emission units for which the monitoring required by the applicable requirement is nonexistent or inadequate.

Table 4. Periodic Monitoring

Emission Unit or Group

Requirement (basis) Additional Monitoring Discussion

Total Facility

Grain Throughput: Less than or equal to 1,500,000 tons per year on a 12 month rolling sum basis

(Title I condition)

Daily recordkeeping of grain throughput

Monthly calculation of grain throughput for the previous month and the previous 12 months.

Grain Receiving (GP001, EU001, EU002, EU008, EU010)

Opacity: < 10% (stack)

Opacity: ≤ 5% (fugitive)

(Minn. R. 7011.1005, subp. 3)

Daily visible emission checks (stack)

Proper O&M of fabric filter *

Performance test on fugitive emissions

Choose one representative unit to test for fugitive emission opacity.

Grain Handling (GP003, EU007, EU009, EU012)


Opacity: 5% (fugitive)

(Minn. R. 7011.1005, subp. 3)


Proper O&M of fabric filter*

Since the operations are totally enclosed, fugitive emissions are not expected to occur.




Grain Storage Bins (GP004, EU013 – EU019)

Opacity: < 20%

PM: Variable, not to exceed 0.3 gr/dscf

(Minn. R. 7011.0715, subp. 1)

None Emissions occur only through air displacement when grain is being put into the bins.

Truck Loadout (EU003)


Opacity: < 10% (fugitive)

(Minn. R. 7011.1005, subp. 3)

Daily visible emission checks (stack) when in operation


Since this operation is rarely used, performance testing is not required at this time.

Rail Loadout (EU004)


Opacity: < 5% (fugitive)

(Minn. R. 7011.1005, subp. 3)



Since this operation is rarely used, performance testing is not required at this time.

Barge Loadout (EU005)


Opacity: < 20% (fugitive, except during trimming or topping-off)

(Minn. R. 7011.1005, subp. 3)



Performance test for fugitive emissions

Fugitive emission opacity shall be tested.

Cleaning/ Scalping (EU006)


Opacity: 5% (fugitive)

(Minn. R. 7011.1005, subp. 3)



Since the operation is totally enclosed, fugitive emissions are not expected to occur.

Permittee disagrees with subjecting the cleaning/scalping operation to the requirements of Minn. R. 7011.1005, subp. 3, on the basis that the Minn R. definition of “handling” does not include cleaning and scalping. However, the NSPS definition of grain handling does include cleaning and scalping, and we have routinely included these operations for facilities in Minnesota.




Grain Dust Tank (EU011)


PM: Variable, not to exceed 0.3 gr/dscf

(Minn. R. 7011.0715, subp. 1)

Daily visible emission checks

Proper O&M of fabric filter*

Since the operation is totally enclosed, fugitive emissions are not expected to occur.

* The permit includes requirements that each fabric filter be 99% efficient. This is a value accepted by default for properly maintained fabric filters, without further demonstration. There is no intent to require testing of the fabric filter efficiency. This requirement is routinely added to permits for fabric filters (and other control devices, but using different efficiencies), per request by EPA Region 5. 3.4 Insignificant Activities

Bunge North America has some operations which are classified as insignificant activities. These are listed in Appendix B to the permit.

The permit is required to include periodic monitoring for all emissions units, including insignificant activities, per EPA guidance. The insignificant activities at this Facility are only subject to general applicable requirements. Using the criteria outlined earlier in this TSD, the following table documents the justification why no additional periodic monitoring is necessary for the current insignificant activities.

Table 5. Insignificant Activities

Insignificant Activity

General Applicable Emission limit

Discussion

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

PM, variable depending on airflow Opacity < 20%

(Minn. R. 7011.0710/715)

The facility has capability of analyzing the quality of grain received. No emissions are expected from this activity.

Fugitive Emissions from unpaved roads and parking lots

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

Those roads which are not paved are coated with dust suppressant which results in a crusty coating and limits the amount of dust that becomes airborne.

3.5 Permit Organization In general, the permit meets the MPCA Delta Guidance for ordering and grouping of requirements. Two areas where this permit deviates slightly from Delta guidance are:

GP002 does not appear in the permit as a group of units with common requirements. It is used only for purposes of reporting annual PM and PM10 emissions from shipping of grain.. It is allowable to report annual PM and PM10 emissions as a group because modeling for PM10 will use hourly rates, which are reported in Delta on a per-unit basis.

The use of appendices: While appendices are fully enforceable parts of the permit, in general, any requirement that the MPCA thinks should be tracked (e.g., limits, submittals, etc.), should be in Table A or B. The main reason is that the appendices are word processing sections and are not


part of the tracking system. Violation of the appendices can be enforced, but the computer system will not automatically generate the necessary enforcement notices or documents. Staff must generate these.

3.6 Comments Received

Public Notice Period: 10/15/06 – 11/13/06

Comments were not received from the public or EPA during the public notice period. 4. Conclusion Based on the information provided by Bunge North America, the MPCA has reasonable assurance that the proposed operation of the emission facility, as described in the Air Emission Permit No. 13900002-001 and this technical support document, will not cause or contribute to a violation of applicable federal regulations and Minnesota Rules.

Staff Members on Permit Team: Toni Volkmeier (permit writer/engineer) Scott Parr (enforcement) Curt Stock (stack testing) John Chikkala (peer reviewer)

Attachments: 1. PTE Summary and Calculation Spreadsheets 2. Facility Description and CD-01 Forms 3. “Grain Elevator and Grain Processing Air Quality Permits and Reports”

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