air individual permit state permit no. 11700027-101 for

Air Individual Permit State Permit

11700027-101 Permittee: CHS Inc - Ruthton Grain Elevator

Facility name: CHS Inc - Ruthton Grain Elevator 701 Railroad Ave Ruthton, MN 56170 Pipestone County

Expiration date: Non-expiring Permit State Permit: July 17, 2018 Permit characteristics: State; Limits to avoid Part 70/ Limits to avoid NSR; Limits to avoid NSR The emission units, control equipment and emission stacks at the stationary source authorized in this permit are as described in the submittals listed in the Permit Applications Table. This permit supersedes Air Emission Permit No. 11700027- 001 and authorizes the Permittee to 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. 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 U.S. Environmental Protection Agency (EPA) Administrator or citizens under the Clean Air Act.

Signature: Jared LaFave This document has been electronically signed. for the Minnesota Pollution Control Agency

for Don Smith, P.E., Manager Air Quality Permits Industrial 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 .................................................................................................................................... 7 6. Submittal/action requirements ................................................................................................................................. 21

Permit issued: July 17, 2018 11700027-101 Permit expires: Non-expiring Permit of 21

1. Permit applications table

Subsequent permit applications: Title description Application receipt date Action number State Permit 10/19/2017 (supplemental information

received 5/22/2018) 11700027-101


2. Where to send submittals

Send submittals that are required to be submitted to the 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]

mailto:[email protected]

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


3. Facility description

The CHS Inc - Ruthton Grain Elevator (Facility) is located at 701 Railroad Ave in Ruthton, Pipestone County, Minnesota. CHS Inc - Ruthton Grain Elevator ("CHS" or "the facility") is a country grain elevator limited to 594,000 tons of grain received per year. Two types of grain are received at the facility: corn and soybeans. There are two receiving pits, one that only receives from trucks and one that can receive from truck or rail. The facility has 11 vented silo/bins for storage. Grain may also be stored in four outdoor storage piles. Pile XT2, XT4, and XT5 are fed by three outdoor portable conveyors that receive directly from trucks. The fourth pile, Pile XT3, is fed by a fixed conveyor that is connected to one of the receiving pits. All piles are covered by tarps while grain is stored. The piles are filled and emptied only once each year, and the maximum amount of grain that is put into temporary storage is 112,000 tons each year. When grain is reclaimed from the piles, a portion of the tarp is torn away and a front end loader is used to scoop up grain and drop it into a truck. The truck then drives to one of the receiving pits to dump the grain for drying or storage in one of the silo/bins. If wet grain is received or reclaimed from one of the temporary storage areas, the grain may be dried in the column dryers prior to storage or loadout. There are four truck loadout spouts and one rail loadout station. Grain is primarily loaded out to rail, with a small portion loaded out to truck. Particulate matter (PM), particulate matter less than ten microns (PM10), and particulate matter less than 2.5 microns (PM2.5) are the main pollutants of concern at this facility. Sources of particulate matter include emissions from grain receiving, storage (silo vents), drying, handling, and loadout, and fugitive emissions from unpaved roads, truck traffic, the addition of grain to temporary storage piles, and reclaim of grain from the storage piles. A small amount of combustion-related pollutants are also emitted from drying, including nitrogen oxides (NOx), carbon monoxide (CO), carbon dioxide equivalent (CO2e), and hazardous air pollutants (HAPs).


4. Summary of subject items

SI ID: Description

Relationship Type

Related SI ID: Description

TFAC 1: CHS Inc - Ruthton Grain Elevator

COMG 1: Enclosed Conveyors and Legs

has members

EQUI 2, EQUI 3, EQUI 4, EQUI 5, EQUI 6, EQUI 7, EQUI 8, EQUI 9, EQUI 11, EQUI 12, EQUI 13, EQUI 14, EQUI 15

COMG 2: Vented Silos has members

EQUI 27, EQUI 28, EQUI 29, EQUI 30, EQUI 31, EQUI 32, EQUI 33, EQUI 34, EQUI 35, EQUI 36, EQUI 37

EQUI 1: Grain Receiving Pit 1

EQUI 2: Conveyor 1 EQUI 3: Conveyor 2 EQUI 4: Conveyor 3 EQUI 5: Conveyor 4 EQUI 6: Conveyor 5 EQUI 7: Conveyor 6 EQUI 8: Conveyor 7 EQUI 9: Conveyor 8 EQUI 10: Conveyor 9 EQUI 11: Leg 1 EQUI 12: Leg 2 EQUI 13: Leg 3 EQUI 14: Leg 4 EQUI 15: Leg 5 EQUI 16: Zimmerman Dryer

sends to STRU 1: Dryer Emissions

EQUI 18: Rail Loadout

SI ID: Description

Relationship Type

Related SI ID: Description

EQUI 19: Truck Loadout 1

EQUI 20: Grain Receiving Pit 2




EQUI 24: Portable Conveyor 1



EQUI 27: Storage Bin 1 EQUI 28: Storage Bin 2 EQUI 29: Storage Bin 3 EQUI 30: Storage Bin 4 EQUI 31: Storage Bin 5 EQUI 32: Storage Bin 6 EQUI 33: Storage Bin 7 EQUI 34: Storage Bin 8 EQUI 35: Storage Bin 9 EQUI 36: Storage Bin 10 EQUI 37: Storage Bin 11 EQUI 38: Front End Loader 1

EQUI 39: Front End Loader 2

FUGI 1: Unpaved Roads FUGI 2: Pile XT2 FUGI 3: Pile XT3 FUGI 4: Pile XT4 FUGI 5: Pile XT5 STRU 1: Dryer Emissions

Permit Issued: July 17, 2018 11700027-101 Permit Expires: Non-expiring Permit of 21

5. Limits and other requirements

Subject Item Sec.SI.Reqt SI des:SI desc Requirement & Citation TFAC 1 11700027 CHS Inc - Ruthton

Grain Elevator

5.1.1 The Permittee shall limit Process Throughput <= 594000 tons per year of grain received to be calculated by the 15th day of each month for the previous 12-month period as described later in this permit. [Title I Condition: Avoid major source under 40 CFR 52.21(b)(1)(i) and Minn. R. 7007.3000, To avoid major source under 40 CFR 70.2 & Minn. R. 7007.0200]

5.1.2 Daily Recordkeeping: Once each day of operation the Permittee shall calculate, record, and maintain records of the total grain received at receiving pits EQUI 1 or EQUI 20, not including grain reclaimed from Pile XT3 (FUGI 3). Daily records shall by based on ticket reports and maintained electronically. [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]

5.1.3 Monthly Recordkeeping: By the 15th day of each month, for the previous calendar month, the Permittee shall calculate and record the following: 1. the tons of grain received at receiving pits EQUI 1 or 20, not including grain reclaimed from Pile XT3 (FUGI 3), and 2. the 12-month rolling sum of grain received for the previous 12-month period by summing the monthly records for the previous 12 months. [Minn. R. 7007.0800, subps. 4-5]

5.1.4 PERMIT SHIELD: Subject to the limitations in Minn. R. 7007.1800, compliance with the conditions of this permit shall be deemed compliance with the specific provision of the applicable requirement identified in the permit as the basis of each condition. Subject to the limitations of Minn. R. 7007.1800 and 7017.0100, subp. 2, notwithstanding the conditions of this permit specifying compliance practices for applicable requirements, any person (including the Permittee) may also use other credible evidence to establish compliance or noncompliance with applicable requirements. This permit shall not alter or affect the liability of the Permittee for any violation of applicable requirements prior to or at the time of permit issuance. [Minn. R. 7007.1800, (A)(2)]

5.1.5 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]

5.1.6 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]


Subject Item Sec.SI.Reqt SI des:SI desc Requirement & Citation 5.1.7 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)]

5.1.8 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]

5.1.9 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]

5.1.10 The Permittee shall clean up commodities spilled on the driveway and other facility property as required to minimize fugitive emissions to a level consistent with RACT (reasonably available control technology). [Minn. R. 7011.1005, subp. 1(A)]

5.1.11 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]

5.1.12 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)]

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

5.1.14 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


Subject Item Sec.SI.Reqt SI des:SI desc Requirement & Citation separately in this permit. [Minn. R. 7007.0800, subp. 4(D)]

5.1.15 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)]

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

5.1.17 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)]

5.1.18 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]

5.1.19 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]

5.1.20 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


Subject Item Sec.SI.Reqt SI des:SI desc Requirement & Citation increase in the emissions of any regulated air pollutant. The 24-hour time period starts when the breakdown was discovered or reasonably should have been discovered by the owner or operator. However, notification is not required in the circumstances outlined in Items A, B and C of Minn. R. 7019.1000, subp. 2. At the time of notification or as soon as possible thereafter, the owner or operator shall inform the Commissioner of the cause of the breakdown and the estimated duration. The owner or operator shall notify the Commissioner when the breakdown is over. [Minn. R. 7019.1000, subp. 2]

5.1.21 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]

5.1.22 Notification of Deviations Endangering Human Health or the Environment Report: Within 2 working days of discovery, notify the Commissioner in writing of any deviation from permit conditions which could endanger human health or the environment. Include the following 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]

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

5.1.24 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)]

5.1.25 Emission Inventory Report: due on or before April 1 of each


Subject Item Sec.SI.Reqt SI des:SI desc Requirement & Citation calendar year following permit issuance. Submit in a format specified by the Commissioner. [Minn. R. 7019.3000-7019.3100]

5.1.26 Emission Fees: due 30 days after receipt of an MPCA bill. [Minn. R. 7002.0005-7002.0095]

COMG 1 Enclosed

Conveyors and Legs

5.2.1 Opacity <= 5 percent opacity from handling operation fugitive emissions. This limit applies separately to each individual unit in the group. [Minn. R. 7011.1005, subp. 3(A)]

COMG 2 Vented Silos 5.3.1 Opacity <= 5 percent opacity from any bin vent while transferring

grain into or out of the bin. This limit applies separately to each individual unit in the group. [Minn. R. 7011.1005, subp. 3(A)]

EQUI 1 Grain Receiving

Pit 1

5.4.1 Opacity <= 5 percent opacity from truck unloading station fugitive (uncaptured) emissions. [Minn. R. 7011.1005, subp. 3(A)]

5.4.2 Visible Emissions: The Permittee shall check EQUI 1 for any visible emissions using Method 22 once each day of operation during daylight hours. The observation period shall be no less than 10 minutes and shall be conducted while grain unloading occurs. Each observer determining the presence of visible emissions must meet the training requirements specified in 40 CFR Part 60, appendix A-7, Section 2.3 of Method 22. [Minn. R. 7007.0800, subps. 1-2]

5.4.3 Visible Emissions: Recordkeeping: The Permittee shall record the time and date of each visible emission inspection, and whether or not any visible emissions were observed. The presence of visible emissions at the unloading station is considered a deviation and must be reported in the semiannual deviations report required by this permit. If no grain is received at EQUI 1 during the operating day, then the Permittee shall record that no grain was received. [Minn. R. 7007.0800, subps. 4-5]

5.4.4 Visible Emissions: Corrective Actions: The Permittee shall take corrective action as soon as possible if visible emissions are observed. Corrective actions include, but are not limited to, reducing the truck unloading rate, shrouding the pit during unloading operations, and ceasing operations until no visible emissions are observed. The Permittee shall keep a record of the type and date of any corrective action taken and whether or not the corrective actions eliminated the visible emissions. [Minn. R. 7007.0800, subps. 4-5]

EQUI 10 Conveyor 9


Subject Item Sec.SI.Reqt SI des:SI desc Requirement & Citation 5.5.1 Opacity <= 5 percent opacity from handling operation emissions.

[Minn. R. 7011.1005, subp. 3(A)] 5.5.2 Visible Emissions: The Permittee shall check EQUI 10 for any visible

emissions at the grain drop point using Method 22 during daylight hours on each day that the conveyor is operated. The observation period shall be no less than 10 minutes and shall be conducted while grain is being added to the pile. Each observer determining the presence of visible emissions must meet the training requirements specified in 40 CFR Part 60, appendix A-7, Section 2.3 of Method 22. [Minn. R. 7009.0800, subps. 1-2]

5.5.3 Visible Emissions: Recordkeeping of Visible Emissions. The Permittee shall record the time and date of each visible emission inspection, and whether or not any visible emissions were observed. The presence of visible emissions from the conveyor or the conveyor drop point is considered a deviation and must be reported in the semiannual deviations report and annual deviations report required by this permit. If the conveyor was not used during the operating day, then the Permittee shall record that the conveyor was not used. [Minn. R. 7007.0800, subps. 4-5]

5.5.4 Visible Emissions: Corrective Actions: The Permittee shall take corrective action as soon as possible if visible emissions are observed. Corrective actions include, but are not limited to, adding mineral oil, reducing the conveyor speed and postponing operations until no visible emissions are observed. The Permittee shall keep a record of the type and date of any corrective action taken and whether or not the corrective actions eliminated the visible emissions. [Minn. R. 7007.0800, subps. 4-5]

EQUI 16 Zimmerman

Dryer

5.6.1 The perforations of a column dryer screen must not exceed 3/32 inches in diameter. [Minn. R. 7011.1005, subp. 5(A)]

EQUI 18 Rail Loadout 5.7.1 Opacity <= 5 percent opacity from railcar loading station fugitive

(uncaptured) emissions. [Minn. R. 7011.1005, subp. 3(A)] 5.7.2 Visible Emissions: The Permittee shall check EQUI 18 for any visible

emissions using Method 22 once each day of operation during daylight hours. The observation period shall be no less than 10 minutes and shall be conducted while grain is being loaded out to rail. Each observer determining the presence of visible emissions must meet the training requirements specified in 40 CFR Part 60, appendix A-7, Section 2.3 of Method 22. [Minn. R. 7009.0800, subps. 1-2]

5.7.3 Visible Emissions: Recordkeeping of Visible Emissions. The Permittee shall record the time and date of each visible emission inspection, and whether or not any visible emissions were observed. The presence of visible emissions from rail loadout is


Subject Item Sec.SI.Reqt SI des:SI desc Requirement & Citation considered a deviation and must be reported in the semiannual deviations report and annual deviations report required by this permit. If no grain is added is loaded out to rail during the operating day, then the Permittee shall record that no grain was loaded out to rail. [Minn. R. 7007.0800, subps. 4-5]

5.7.4 Visible Emissions: Corrective Actions: The Permittee shall take corrective action as soon as possible if visible emissions are observed. Corrective actions shall eliminate visible emissions. Corrective actions include, but are not limited to, reducing the rate of grain being loaded out, utilizing a dead box or sock at the loadout spout, and postponing operations until no visible emissions are observed. The Permittee shall keep a record of the type and date of any corrective action taken. [Minn. R. 7007.0800, subps. 4-5]

EQUI 19 Truck Loadout 1 5.8.1 Opacity <= 10 percent opacity from truck loading station fugitive

emissions. [Minn. R. 7011.1005, subp. 3(B)] 5.8.2 Visible Emissions: The Permittee shall check EQUI 19 for any visible

emissions using Method 22 once each day of operation during daylight hours. The observation period shall be no less than 10 minutes and shall be conducted while grain loading occurs. Each observer determining the presence of visible emissions must meet the training requirements specified in 40 CFR Part 60, appendix A-7, Section 2.3 of Method 22. [Minn. R. 7007.0800, subps. 1-2]

5.8.3 Visible Emissions: Recordkeeping of Visible Emissions. The Permittee shall record the time and date of each visible emission inspection, and whether or not any visible emissions were observed. The presence of visible emissions at the loading station is considered a deviation and must be reported in the semiannual deviations report and annual deviations report required by this permit. If no grain is loaded at EQUI 19 during the operating day, then the Permittee shall record that no grain was loaded out. [Minn. R. 7007.0800, subps. 4-5]

5.8.4 Visible Emissions: Corrective Actions: The Permittee shall take corrective action as soon as possible if visible emissions are observed. Corrective actions include, but are not limited to, reducing the truck loading rate, utilizing a dead box or sock at the loadout spout, and postponing operations until no visible emissions are observed. The Permittee shall keep a record of the type and date of any corrective action taken and whether or not the corrective actions eliminated the visible emissions. [Minn. R. 7007.0800, subps. 4-5]

EQUI 20 Grain Receiving

Pit 2

5.9.1 Opacity <= 5 percent opacity from truck unloading station fugitive (uncaptured) emissions. [Minn. R. 7011.1005, subp. 3(A)]

5.9.2 Visible Emissions: The Permittee shall check EQUI 20 for any visible emissions using Method 22 once each day of operation during


Subject Item Sec.SI.Reqt SI des:SI desc Requirement & Citation daylight hours. The observation period shall be no less than 10 minutes and shall be conducted while grain unloading occurs. Each observer determining the presence of visible emissions must meet the training requirements specified in 40 CFR Part 60, appendix A-7, Section 2.3 of Method 22. [Minn. R. 7007.0800, subps. 1-2]

5.9.3 Visible Emissions: Recordkeeping: The Permittee shall record the time and date of each visible emission inspection, and whether or not any visible emissions were observed. The presence of visible emissions at the unloading station is considered a deviation and must be reported in the semiannual deviations report required by this permit. If no grain is received at EQUI 20 during the operating day, then the Permittee shall record that no grain was received. [Minn. R. 7007.0800, subps. 4-5]



(uncaptured) emissions. [Minn. R. 7011.1005, subp. 3(B)] 5.10.2 Visible Emissions: The Permittee shall check EQUI 21 for any visible



5.10.4 Visible Emissions: Corrective Actions: The Permittee shall take corrective action as soon as possible if visible emissions are observed. Corrective actions include, but are not limited to, reducing the truck loading rate, utilizing a dead box or sock at the loadout spout, and postponing operations until no visible emissions are observed. The Permittee shall keep a record of the type and date of any corrective action taken and whether or not the corrective actions eliminated the visible emissions. [Minn. R.


Subject Item Sec.SI.Reqt SI des:SI desc Requirement & Citation 7007.0800, subps. 4-5]









5.12.3 Visible Emissions: Recordkeeping of Visible Emissions. The Permittee shall record the time and date of each visible emission inspection, and whether or not any visible emissions were observed. The presence of visible emissions at the loading station is considered a deviation and must be reported in the semiannual deviations report and annual deviations report required by this permit. If no grain is loaded at EQUI 23 during the operating day, then the Permittee shall record that no grain was loaded out.


Subject Item Sec.SI.Reqt SI des:SI desc Requirement & Citation [Minn. R. 7007.0800, subps. 4-5]


EQUI 24 Portable

Conveyor 1

5.13.1 Opacity <= 5 percent opacity from truck unloading and handling operation emissions. This limit applies to emissions from unloading of the grain from trucks to the conveyor, from the grain being conveyed, and from the drop of the grain onto the pile. [Minn. R. 7011.1005, subp. 3(A)]

5.13.2 Visible Emissions: The Permittee shall check EQUI 24 for any visible emissions using Method 22 once each day of operation during daylight hours. The observation period shall be no less than 10 minutes and shall be conducted while grain is being added to a temporary storage pile. Each observer determining the presence of visible emissions must meet the training requirements specified in 40 CFR Part 60, appendix A-7, Section 2.3 of Method 22. [Minn. R. 7007.0800, subps. 1-2]

5.13.3 Visible Emissions: Recordkeeping of Visible Emissions. The Permittee shall record the time and date of each visible emission inspection, and whether or not any visible emissions were observed. The presence of visible emissions is considered a deviation and must be reported in the semiannual deviations report and annual deviations report required by this permit. If the conveyor was not used during the operating day, then the Permittee shall record that the conveyor was not used. [Minn. R. 7007.0800, subps. 4-5]

5.13.4 Visible Emissions: Corrective Actions: The Permittee shall take corrective action as soon as possible if visible emissions are observed. Corrective actions include, but are not limited to, reducing the rate of grain being unloaded and conveyed, reducing the drop height of the grain into the pile, adding a sleeve or sock to the conveyor spout, and postponing operations until no visible emissions are observed. The Permittee shall keep a record of the type and date of any corrective action taken and whether or not the corrective actions eliminated the visible emissions. [Minn. R. 7007.0800, subps. 4-5]

EQUI 25 Portable

Conveyor 2

5.14.1 Opacity <= 5 percent opacity from truck unloading and handling


Subject Item Sec.SI.Reqt SI des:SI desc Requirement & Citation operation emissions. This limit applies to emissions from unloading of the grain from trucks to the conveyor, from the grain being conveyed, and from the drop of the grain onto the pile. [Minn. R. 7011.1005, subp. 3(A)]


5.14.3 Visible Emissions: Recordkeeping of Visible Emissions. The Permittee shall record the time and date of each visible emission inspection, and whether or not any visible emissions were observed. The presence of visible emissions is considered a deviation and must be reported in the semiannual deviations report and annual deviations report required by this permit. If the conveyor was not used during the operating day, then the Permittee shall record that the conveyor was not used. [Minn. R. 7007.0800, subps. 4-5]


EQUI 26 Portable

Conveyor 3

5.15.1 Opacity <= 5 percent opacity from truck unloading and handling operation emissions. This limit applies to emissions from unloading of the grain from trucks to the conveyor, from the grain being conveyed, and from the drop of the grain onto the pile. [Minn. R. 7011.1005, subp. 3(A)]


5.15.3 Visible Emissions: Recordkeeping of Visible Emissions. The Permittee shall record the time and date of each visible emission inspection, and whether or not any visible emissions were


Subject Item Sec.SI.Reqt SI des:SI desc Requirement & Citation observed. The presence of visible emissions is considered a deviation and must be reported in the semiannual deviations report and annual deviations report required by this permit. If the conveyor was not used during the operating day, then the Permittee shall record that the conveyor was not used. [Minn. R. 7007.0800, subps. 4-5]


EQUI 38 Front End Loader

1

5.16.1 Opacity <= 5 percent opacity from handling operation fugitive emissions (this includes emissions from moving grain around any outdoor storage pile and reclaiming grain from the outdoor storage pile). [Minn. R. 7011.1005, subp. 3(A)]

5.16.2 Opacity <= 10 percent opacity from truck loading fugitive emissions (this includes emissions from dropping the grain from the front end loader into a truck). [Minn. R. 7011.1005, subp. 3(B)]


5.16.4 Visible Emissions: Recordkeeping: The Permittee shall record the time and date of each visible emission inspection, and whether or not any visible emissions were observed. The presence of visible emissions is considered a deviation and must be reported in the semiannual deviations report required by this permit. If EQUI 38 was not used to move grain during the operating day, then the Permittee shall record that EQUI 38 was not used. [Minn. R. 7007.0800, subps. 4-5]



Subject Item Sec.SI.Reqt SI des:SI desc Requirement & Citation EQUI 39 Front End Loader

2

5.17.1 Opacity <= 5 percent opacity from handling operation fugitive emissions (this includes emissions from moving grain around any outdoor storage pile and reclaiming grain from the outdoor storage pile). [Minn. R. 7011.1005, subp. 3(A)]

5.17.2 Opacity <= 10 percent opacity from truck loading fugitive emissions (this includes emissions from dropping the grain from the front end loader into a truck). [Minn. R. 7011.1005, subp. 3(B)]


5.17.4 Visible Emissions: Recordkeeping: The Permittee shall record the time and date of each visible emission inspection, and whether or not any visible emissions were observed. The presence of visible emissions is considered a deviation and must be reported in the semiannual deviations report required by this permit. If EQUI 39 was not used to move grain during the operating day, then the Permittee shall record that EQUI 39 was not used. [Minn. R. 7007.0800, subps. 4-5]


FUGI 1 Unpaved Roads 5.18.1 The Permittee shall clean up commodities spilled on the driveway

and other facility property as required to minimize fugitive emissions to a level consistent with RACT (reasonably available control technology). [Minn. R. 7011.1005, subp. 1(A)]

5.18.2 The Permittee shall clean all roads at least once each calendar month. Anytime fugitive emissions are observed on facility roadways, the Permittee shall immediately eliminate fugitive emissions by cleaning those road segments and/or apply water or a chemical dust suppressant. [Minn. R. 7007.0800, subp. 1(A) and (B)]

5.18.3 Recordkeeping of visible emissions: On each day of operation, the Permittee shall visually inspect all surfaces to minimize or eliminate fugitive emissions. The facility shall maintain records of this


Subject Item Sec.SI.Reqt SI des:SI desc Requirement & Citation inspection that include the date of inspection, whether or not fugitive dust was observed leaving the property, what corrective actions were taken (if any), when the corrective actions were taken, and whether the corrective actions eliminated the fugitive dust. [Minn. R. 7007.0800, subps. 4-5]

5.18.4 The Permittee shall implement and enforce a facility-wide speed limit of 10 miles per hour. The Permittee must post the speed limit in a highly visible location near the facility entrance. [Minn. R. 7007.0800, subp. 2(B)]

FUGI 2 Pile XT2 5.19.1 Opacity <= 5 percent opacity from handling operation fugitive

emissions. [Minn. R. 7011.1005, subp. 3(A)] 5.19.2 The Permittee shall fully cover the pile while grain is being stored.

[Minn. R. 7007.0800, subp. 2(B)] 5.19.3 The capacity of Pile XT2 (FUGI 2) is 19,732 tons of grain. The

Permittee shall fill the pile only once each calendar year. [Minn. R. 7007.0800, subp. 2(B)]














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.

Subject Item Sec.SI.Reqt SI des:SI desc Requirement & Citation TFAC 1 11700027 CHS Inc - Ruthton

Grain Elevator

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

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

Technical Support Document, Permit Number: 11700027-101 Page 1 of 9

Technical Support Document for

Air Emission Permit No. 11700027-101 This technical support document (TSD) is intended for all parties interested in the permit and to meet the requirements that have been set forth by the federal and state regulations (40 CFR § 70.7(a)(5) and Minn. R. 7007.0850, subp. 1). The purpose of this document is to provide the legal and factual justification for each applicable requirement or policy decision considered in the determination to issue the permit. 1. General information

1.1 Applicant and stationary source location Table 1. Applicant and source address

Applicant/Address Stationary source/Address (SIC Code: 5153 - Grain and Field Beans)

CHS Inc 5500 Cenex Dr Inver Grove Heights, Minnesota 55077-1721

CHS Inc - Ruthton Grain Elevator 701 Railroad Ave Ruthton, MN 56170

Contact: Stephanie McGrath Phone: 651-355-6998

1.2 Facility description

CHS Inc - Ruthton Grain Elevator ("CHS" or "the facility") is a country grain elevator limited to 594,000 tons of grain received per year. Two types of grain are received at the facility: corn and soybeans. There are two receiving pits, one that only receives from trucks and one that can receive from truck or rail. The facility has 11 vented silo/bins for storage. Grain may also be stored in four outdoor storage piles. Pile XT2, XT4, and XT5 are fed by three outdoor portable conveyors that receive directly from trucks. The fourth pile, Pile XT3, is fed by a fixed conveyor that is connected to one of the receiving pits. All piles are covered by tarps while grain is stored. The piles are filled and emptied only once each year, and the maximum amount of grain that is put into temporary storage is 112,000 tons each year. When grain is reclaimed from the piles, a portion of the tarp is torn away and a front end loader is used to scoop up grain and drop it into a truck. The truck then drives to one of the receiving pits to dump the grain for drying or storage in one of the silo/bins. If wet grain is received or reclaimed from one of the temporary storage areas, the grain may be dried in the column dryers prior to storage or loadout. There are four truck loadout spouts and one rail loadout station. Grain is primarily loaded out to rail, with a small portion loaded out to truck. Particulate matter (PM), particulate matter less than ten microns (PM10), and particulate matter less than 2.5 microns (PM2.5) are the main pollutants of concern at this facility. Sources of particulate matter include emissions from grain receiving, storage (silo vents), drying, handling, and loadout, and fugitive emissions from unpaved roads, truck traffic, the addition of grain to temporary storage piles, and reclaim of grain from the storage piles. A small amount of combustion-related pollutants are also emitted from drying, including nitrogen oxides (NOx), carbon monoxide (CO), carbon dioxide equivalent (CO2e), and hazardous air pollutants (HAPs).

1.3 Description of the activities allowed by this permit action

This permit action is a State Permit.

1.4 Facility emissions


Table 2. Total facility potential to emit summary

PM tpy

PM10 tpy

PM2.5 tpy

SO2 tpy

NOx tpy

CO tpy

CO2e tpy

VOC tpy

Single HAP tpy

All HAPs tpy

Total facility limited potential emissions including fugitive sources 274 89.1 16.0 0.156 37.5 21.6 36,800 2.88 0.465 0.488 Total facility limited potential emissions not including fugitive sources 164 49.7 10.1 0.156 37.5 21.6 36,800 2.88 0.465 0.488 Total facility actual emissions (2017) 47.2 17.9 17.9 0.0 0.76 0.44 * 0.060 *

*Not reported in Minnesota emission inventory. Table 3. Facility classification

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

2. Regulatory and/or statutory basis

2.1 New source review (NSR)

The Permittee has accepted limits on the facility such that it is a minor source under New Source Review regulations. Emissions of PM do exceed 250 tons per year when fugitives are included. However, the facility is not one of the source types listed in 40 CFR § 52.21(b)(1)(iii), so fugitives emissions are not included when determining major source applicability. The fugitive sources that are not included in the total are the emissions from the temporary storage piles and the unpaved roads. When those emissions are excluded, the PM potential to emit is 164 tons per year.

2.2 Part 70 permit program The Permittee has accepted limits on the facility such that it is a nonmajor source under the Part 70 permit program. Although PM potential to emit is over 100 tpy, PM is not considered a “regulated pollutant” within the definition of a major source in 40 CFR § 70.2. According to the EPA guidance document dated October 16, 1995, with subject line Definition of Regulated Pollutant for Particulate Matter for Purpose of Title V, written by Lydia N. Wegman, Deputy Director, a Title V operating permit is not required if the only pollutant that would make the source major is particulate matter.

2.3 New source performance standards (NSPS) The Permittee has stated that no New Source Performance Standards apply to the operations at this facility. This facility is not subject to 40 CFR pt. 60, subp. DD – Standards of Performance for Grain Handling Facilities. Applicability is based on a grain elevator’s storage capacity, which must exceed 2.5 million bushels for any grain storage facility not for human consumption. The storage capacity of grain elevators at this facility is 915,688 bushels; therefore, Subpart DD does not apply.

2.4 National emission standards for hazardous air pollutants (NESHAP)


The facility is an area source under NESHAP regulations. The Permittee has stated that no area source NESHAP standards apply.

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

· Minn. R. 7011.1005 Standards of Performance for Dry Bulk Agricultural Commodity Facilities Table 4. Regulatory overview of facility

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

Title I Condition: Avoid major source under 40 CFR 52; To avoid major source under 40 CFR 70.2

Prevention of Significant Deterioration (PSD). Limits on total annual grain throughput and annual grain drying to reduce PM10 and PM2.5 emissions below major source thresholds under NSR and Part 70.

TFAC 1 (Air Quality Total Facility)

Minn. R. 7011.1005 Standards of Performance for Dry Bulk Agricultural Commodity Facilities (Bulk Ag Rule or “BAR”). This rule applies to facilities that unload, handle, store, grind, or load dry bulk agricultural commodities, which includes corn, soybeans, and wheat. Any owner or operator of a commodity facility is subject to a requirement to clean up commodities on the driveway and facility property in order to minimize fugitive emissions.

COMG 1 (Enclosed Conveyors and Legs)

Minn. R. 7011.1005 Standards of Performance for Dry Bulk Agricultural Commodity Facilities. This rule applies to facilities that unload, handle, store, grind, or load dry bulk agricultural commodities, which includes corn, soybeans, and wheat. Commodity facilities fall into the “control required” category of the rule if they have an annual commodity throughput of more than 180,000 tons. The Prairie Lakes facility has consistently had annual commodity throughputs well over this amount, and will have a maximum throughput of 594,000 tons per year upon issuance of permit #12100021-101. For “control required” facilities, a five percent opacity limit applies to emissions from any handling operation. The equipment in COMG 1 includes all fully enclosed conveyors and legs at the facility. The transfer and movement of grain is considered a handling operation, therefore the opacity limit applies.

COMG 2 (Vented Silos)

Minn. R. 7011.1005 Standards of Performance for Dry Bulk Agricultural Commodity Facilities. See COMG 1 for explanation of rule applicability. A five percent opacity limit applies to emissions from any handling operation, including transfer of grain into or out of vented bins.

EQUI 1 and 20 (Grain Receiving Pit 1 and 2)

Minn. R. 7011.1005 Standards of Performance for Dry Bulk Agricultural Commodity Facilities. See COMG 1 for explanation of rule applicability. A five percent opacity limit applies to emissions from truck unloading stations and Grain Receiving Pit 1 is a truck unloading station.

EQUI 10 (Conveyor 9)

Minn. R. 7007.1005 Standards of Performance for Dry Bulk Agricultural Commodity Facilities. See COMG 1 for explanation of rule applicability. A five percent opacity limit applies to emissions from any handling operation, including transfer of grain by conveyors. This conveyor feed storage Pile XT3 (FUGI 3).


Subject item* Applicable regulations Rationale EQUI 16 (Zimmerman Dryer)

Minn. R. 7007.1005 Standards of Performance for Dry Bulk Agricultural Commodity Facilities. See COMG 1 for explanation of rule applicability. The BAR contains specifications for perforation size that apply to column dryers and the Zimmerman Dryer is a column dryer.

EQUI 18 (Rail Loadout)

Minn. R. 7007.1005 Standards of Performance for Dry Bulk Agricultural Commodity Facilities. See COMG 1 for explanation of rule applicability. A five percent opacity limit applies to emissions from rail loading stations.

EQUI 19, 21, 22, and 23 (Truck Loadout 1, 2, 3, and 4)

Minn. R. 7011.1005 Standards of Performance for Dry Bulk Agricultural Commodity Facilities. See COMG 1 for explanation of rule applicability. A ten percent opacity limit applies to emissions from truck loading stations.

EQUI 24, 25, and 26 (Portable Conveyor 1, 2, and 3)

Minn. R. 7011.1005 Standards of Performance for Dry Bulk Agricultural Commodity Facilities. See COMG 1 for explanation of rule applicability. A five percent opacity limit applies to emissions from truck loadout and handling operations. Truck loadout occurs when the grain is transferred from the truck to the portable conveyor, and handling occurs as the grain is transferred up the conveyor and dropped onto the pile.

EQUI 38 and 39 (Front End Loader 1 and 2)

Minn. R. 7011.1005 Standards of Performance for Dry Bulk Agricultural Commodity Facilities. See COMG 1 for explanation of rule applicability. A five percent opacity limit applies to emissions from any handling operation, and a ten percent opacity limit applies to emissions from truck loading. Both limits apply to different portions of the Front End Loader. Handling occurs as the front end loader scoops up grain from the pile and conveys it upward, and truck loading occurs when the grain is dropped out from Front End Loader and into the truck.

FUGI 1 (Unpaved Roads)

Minn. R. 7011.1005 Standards of Performance for Dry Bulk Agricultural Commodity Facilities. See COMG 1 for explanation of rule applicability. A requirement to clean up commodities spilled on the driveway or other facility property “as required to minimize fugitive emissions to a level consistent with RACT (reasonably available control technology)” applies to the roadways at the facility.


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

Emission Limitations and Standards. Minnesota Permit Content rules dictate that the permit must include emission limitations, operational requirements, and other provisions needed to ensure compliance with all applicable requirements, and must include conditions as necessary to protect human health and the environment. The requirement to clean roadways whenever fugitive emissions are observed (and on a monthly basis, at a minimum) is necessary to comply with the BAR applicable requirement to minimize fugitive emissions from spilled commodities and with Minn. R 7011.0150 requirement (see TFAC) to prevent particulate matter from becoming airborne. Other corrective actions may be necessary to protect human health and the environment from fugitive dust emissions from the unpaved roads.


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

Emission Limitations and Standards. Minnesota Permit Content rules dictate that the permit must include conditions as necessary to protect human health and the environment. Limiting vehicle speed on unpaved roads greatly reduces that amount of fugitive dust generated.


Subject item* Applicable regulations Rationale FUGI 2, 3, 4, and 5 (Piles XT2, XT3, XT4, and XT5)

Minn. R. 7011.1005 Standards of Performance for Dry Bulk Agricultural Commodity Facilities. See COMG 2 for explanation of rule applicability. A five percent opacity limit applies to emissions from any handling operation, including adding grain to the pile or removing grain from the pile.

FUGI 2, 3, 4, and 5 (Piles XT2, XT3, XT4, and XT5)

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

Emission Limitations and Standards. Minnesota Permit Content rules dictate that the permit must include conditions as necessary to protect human health and the environment. The Permittee has stated, and assumed in the calculations, that the piles would be fully covered while grain is being stored. Excessive fugitive PM, PM10, and PM2.5 emissions from temporary storage of grain can have a detrimental effect on human health and the environment, therefore, it is necessary to cover the pile whenever possible.

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

3. Technical information

3.1 Calculations of potential to emit (PTE) Attachment 1 to this TSD contains the PTE summary for the Facility, and detailed spreadsheets and supporting information prepared by the MPCA and the Permittee.

3.2 Bulk Agricultural Rule Requirements Due to compliance concerns at other grain handling facilities that are subject to the BAR, daily visible emissions checks (and corrective actions if visible emissions are seen) are required at many of the emission units that are subject to an opacity limit from the rule. This includes each receiving pit, silo vent, unloading station, outdoor conveyor, and the grain gobbler. From the BAR, opacity limits apply to “fugitive” emissions from loading and unloading stations, and from handling operations. Although opacity limits do not explicitly apply at silo vents, the transfer of grain into and out of the silo is considered a handling operation, and the point that emissions may occur is at the silo vent. Similarly, opacity limits apply to the outdoor conveyors and to the grain gobbler because these are grain handling activities. The exceptions where no visible emissions checks were put in the permit are at the fully enclosed conveyors and legs (COMG 2), the silos without vents (COMG 3), and the storage piles (FUGI 1, 3, 4, and 5). Opacity limits apply to the enclosed conveyors, legs, and unvented silos, but no emissions are expected to occur. Opacity limits apply to the temporary storage piles as well, but only while handling occurs, so the visible emissions checks were placed at the emissions units that are used to add or remove grain to the pile, and not to the piles themselves. With the exception of truck loading (which has a 10 percent opacity limit) a 5 percent opacity limit applies to the activities where monitoring is required. 5 percent opacity is very low. Essentially, if the emissions are visible then they are exceeding the limit, therefore Method 22 for Visual Determination of Fugitive Emissions is appropriate. If visible emissions are observed, the Permittee must take corrective actions. Several possible corrective actions are listed at each subject item, but the Permittee may employ other corrective actions as needed.

3.3 Monitoring

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

· the likelihood of the facility violating the applicable requirements; · whether add-on controls are necessary to meet the emission limits;


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

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

Table 5 summarizes the monitoring requirements. Table 5. Monitoring

Subject Item* Requirement (basis)

What is the monitoring? Why is this monitoring adequate?

TFAC 1 (Air Quality Total Facility)

The Permittee shall limit Process Throughput <= 594,000 tons per year 12-month rolling sum of grain received. [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]

Daily recordkeeping, monthly totals, month calculation of 12-month sum.

The Permittee will maintain daily records of the amount of grain received in any receiving pit, unless it is grain that was reclaimed from Pile XT3. The grain from Pile XT3 is accounted for when it is added to the pile through one of the receiving pits, so counting it again when it is reclaimed from the pile would double count. Grain amounts are automatically recorded in the computer system that is hooked up to the Permittee’s scale system. These daily records can be used to calculate the total amount of grain received each month, and the monthly totals can be used to calculate the 12-month rolling sum.

COMG 1 (Enclosed Conveyors and Legs)

Opacity <= 5 percent opacity from handling operation fugitive emissions. [Minn. R. 7011.1005, subp. 3(A)]

None This component group (COMG) consists only of fully enclosed conveyors and legs that are used to transport grain. No pressure release valves or fans are used in the grain handling system. Pressure that is created from the movement of grain through an individual conveyor or leg is taken in by other connected conveyors and legs. These enclosed emission units are designed to lose as little material as possible, therefore, very little, if any, opacity is expected to be emitted from them and no monitoring is needed.

COMG 2 (Vented Silos)

Opacity <= 5 percent opacity from any bin vent while transferring grain into or out of the bin. [Minn. R. 7011.1005, subp. 3(A)]

None This COMG consists only of concrete storage bins. The bins have 1-4 vents on the top where displaced air is released when grain is being added to the bin. The Permittee has stated that no visible emissions are present while grain is being added to the bins. This comports with the size and dimensions of the concrete bins, which are taller and narrower, and generally have less capacity than metal silos. It is unlikely that much particulate matter is released from the bins vents, and opacity monitoring is not needed.




EQUI 1 and 20 (Grain Receiving Pit 1 and 2)

Opacity <= 5 percent opacity from truck unloading station fugitive (uncaptured) emissions. [Minn. R. 7011.1005, subp. 3(A)]

Daily Visible Emissions (VE) checks

The Permittee will use Method 22 to check for visible emissions from each grain receiving pit once each day of operation. Since the opacity limitation for this type of operation is low (5 percent opacity) VE checks are appropriate to determine compliance. If visible emissions are seen, then it is likely that the limitation is being exceeded, and the Permittee must take corrective actions.

EQUI 10 (Conveyor 9)

Opacity <= 5 percent opacity from handling operation emissions. [Minn. R. 7011.1005, subp. 3(A)]


The Permittee will use Method 22 to check for visible emissions from the pile conveyors once each day of operation. Since the opacity limitation for this type of operation is so low (5 percent opacity) VE checks are appropriate to determine compliance. Emissions are not expected from the movement of the grain on the conveyors themselves, since the conveyors are enclosed, but opacity may be seen at the drop point from the conveyor to the pile. If visible emissions are seen, then it is likely that the limitation is being exceeded, and the Permittee must take corrective actions.

EQUI 18 (Rail Loadout)

Opacity <= 5 percent opacity from railcar loading station fugitive (uncaptured) emissions. [Minn. R. 7011.1005, subp. 3(A)]


The Permittee will use Method 22 to check for visible emissions from rail loadout once each day of operation. Since the opacity limitation for this type of operation is so low (5 percent opacity) VE checks are appropriate to determine compliance. If visible emissions are seen, then it is likely that the limitation is being exceeded, and the Permittee must take corrective actions.

EQUI 19, 21, 22, and 23 (Truck Loadout 1, 2, 3, and 4)

Opacity <= 10 percent opacity from truck loading station fugitive emissions. [Minn. R. 7011.1005, subp. 3(B)]


The Permittee will use Method 22 to check for visible emissions from truck loadout once each day of operation. Even though the emission limit is slightly higher than most at 10 percent opacity instead of 5 percent, the presence of visible emissions is still a good indicator that the emission limit is being exceeded. If visible emissions are seen the Permittee must take corrective actions.

EQUI 24, 25, and 26 (Portable Conveyor 1, 2, and 3)

Opacity <= 5 percent opacity from truck unloading and handling operation emissions. [Minn. R. 7011.1005, subp. 3(A)]


The Permittee will use Method 22 to check for visible emissions from each portable conveyor once each day of operation. Emissions may be generated from unloading of the grain from trucks to the conveyor, from the grain being conveyed, and from the drop of the grain onto the pile. Since the opacity limitation for this type of operation is so low (5 percent opacity) VE checks are appropriate to determine compliance. If visible emissions are seen, then it is likely that the limitation is being exceeded, and the Permittee must take corrective actions.




EQUI 38 and 39 (Front End Loader 1 and 2)

Opacity <= 5 percent opacity from handling operation fugitive emissions. [Minn. R. 7011.1005, subp. 3(A)]; Opacity <= 10 percent opacity from truck loading fugitive emissions. [Minn. R. 7011.1005, subp. 3(B)]


The Permittee will use Method 22 to check for visible emissions from handling operations and truck loading once each day of operation. Handling operations include the reclaim of grain from the pile using the front end loader. Since the opacity limitation for this type of operation is low (5-10 percent opacity) VE checks are appropriate to determine compliance. If visible emissions are seen, then it is likely that the limitation is being exceeded, and the Permittee must take corrective actions.

FUGI 2, 3, 4, and 5 (Piles XT2, XT3, XT4, and XT5)

Opacity <= 5 percent opacity from handling operation fugitive emissions. [Minn. R. 7011.1005, subp. 3(A)]

None The opacity limit applies when grain is being added to or removed from a pile, and does not apply while the grain is being stored. Since the emission units that add or remove grain already have daily visible emissions checks, there is no need to have visible emissions checks on the piles themselves.

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

3.4 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 unit. Specifically: opacity limits from the Standards of Performance for Dry Bulk Agricultural Commodity Facilities that apply to Enclosed Conveyors and Legs (COMG1) and Vented Bins (COMG 2) are listed at the group level. In general, limits that apply to individual pieces of equipment should be tracked at the unit level and should not be listed at a group. The main reason is if there were noncompliance with a limit by one unit within the group, the computer system would say the whole group was out of compliance. For this case, the enclosed conveyors and legs and the vented bins are not reasonably expected to generate enough particulate matter to violate the opacity limits. Therefore, it is highly unlikely that the MPCA would need to track noncompliance with this limit at the individual unit level so the permit team decided that a group was an acceptable way to include these requirements.

3.5 Comments received Public Notice Period: June 7th, 2018 – July 6th, 2018 EPA Review Period: June 7th, 2018 – July 6th, 2018 No comments were received from the public during the public notice period. No comments were received from EPA during their review period.

4. Permit fee assessment This permit action is the issuance of an individual State Permit based on an application received 10/19/2017. Even though the Permittee previously held a registration permit, this action is not considered a reissuance of an individual state operating permit; therefore, the application fees apply under Minn. R. 7002.0019. 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.


5. Conclusion Based on the information provided by CHS Inc - Ruthton Grain Elevator the MPCA has reasonable assurance that the proposed operation of the emission facility, as described in the Air Emission Permit No. 11700027-101 and this TSD, will not cause or contribute to a violation of applicable federal regulations and Minnesota Rules. Staff members on permit team: Rachel Yucuis (permit engineer)

Peggy Bartz (peer reviewer) Joe Handtmann (permit writing assistant) Laurie O'Brien (administrative support) Patrick Connerton (enforcement) Curt Stock (testing)

TEMPO360 Activities: State Permit (IND20170001)

Attachments: 1. PTE summary and calculation spreadsheets 2. Subject item inventory and facility requirements 3. Points Calculator

Attachment 1: PTE Summary and Calculation Spreadsheets CHS Inc – Ruthton Grain Elevator Permit Number: 11700027-101

Unrestricted Emissions (tpy)EQUI # Description PM PM10 PM2.5 NOx CO SO2 VOC N2O CH4 CO2 CO2e HAPs-Total HAPs-SingleEQUI 1 Grain Receiving Pit 1 473.0 155.1 26.3

EQUI 20 Grain Receiving Pit 2 236.5 77.5 13.1EQUI 16 Zimmerman Dryer 291.1 74.3 14.4 37.46 21.61 0.156 2.881 2.593 0.576 36017 36804 4.88E-01 4.65E-01EQUI 18 Rail Loadout 283.8 23.1 3.9EQUI 19 Truck Loadout 1 113.0 38.1 6.44EQUI 21 Truck Loadout 2 565.0 190.5 32.2EQUI 22 Truck Loadout 3 56.5 19.1 3.2EQUI 23 Truck Loadout 4 56.5 19.1 3.2EQUI 27 Bin 1 98.6 24.8 4.3EQUI 28 Bin 2 98.6 24.8 4.3EQUI 29 Bin 3 98.6 24.8 4.3EQUI 30 Bin 4 98.6 24.8 4.3EQUI 31 Bin 5 32.9 8.3 1.4EQUI 32 Bin 6 65.7 16.6 2.9EQUI 33 Bin 7 65.7 16.6 2.9EQUI 34 Bin 8 65.7 16.6 2.9EQUI 35 Bin 9 65.7 16.6 2.9EQUI 36 Bin 10 65.7 16.6 2.9EQUI 37 Bin 11 65.7 16.6 2.9COMG 1 Grain Handling 240.5 134.0 22.9FUGI 1 Unpaved Roads 288.4 76.8 7.7FUGI 2 Pile XT2 217.0 102.0 17.4FUGI 3 Pile XT3 3416.0 1233.3 209.3FUGI 4 Pile XT4 926.6 334.5 56.8FUGI 5 Pile XT5 1479.8 534.3 90.7

Totals with fugitives 9465.0 3218.7 543.6 37.5 21.6 0.2 2.9 2.6 0.6 36016.5 36803.7 0.5 0.5Totals without fugitives 2831.1 787.1 136.0 37.5 21.6 0.2 2.9 2.6 0.6 36016.5 36803.7 0.5 0.5

Limited Emissions (tpy)EQUI # Description PM PM10 PM2.5 NOx CO SO2 VOC N2O CH4 CO2 CO2e HAPs-Total HAPs-SingleEQUI 1 Grain Receiving Pit 1 27.64 9.06 1.54

EQUI 20 Grain Receiving Pit 2 27.64 9.06 1.54EQUI 16 Zimmerman Dryer 67.36 18.35 4.81 37.46 21.61 0.16 2.88 2.59 0.58 36016.52 36804 4.88E-01 4.65E-01EQUI 18 Rail Loadout - - -EQUI 19 Truck Loadout 1 8.5140 2.8710 0.4851EQUI 21 Truck Loadout 2 8.5140 2.8710 0.4851EQUI 22 Truck Loadout 3 8.5140 2.8710 0.4851EQUI 23 Truck Loadout 4 8.5140 2.8710 0.4851EQUI 27 Bin 1 0.6981 0.1759 0.0307EQUI 28 Bin 2 0.6981 0.1759 0.0307EQUI 29 Bin 3 0.6981 0.1759 0.0307EQUI 30 Bin 4 0.6981 0.1759 0.0307EQUI 31 Bin 5 0.6981 0.1759 0.0307EQUI 32 Bin 6 0.6981 0.1759 0.0307EQUI 33 Bin 7 0.6981 0.1759 0.0307EQUI 34 Bin 8 0.6981 0.1759 0.0307EQUI 35 Bin 9 0.6981 0.1759 0.0307EQUI 36 Bin 10 0.6981 0.1759 0.0307EQUI 37 Bin 11 0.6981 0.1759 0.0307COMG 1 Grain Handling 18.74 10.44 1.78FUGI 1 Unpaved Roads 44.20 11.78 1.18FUGI 2 Pile XT2 15.71 5.67 0.96FUGI 3 Pile XT3 - - -FUGI 4 Pile XT4 15.71 5.67 0.96FUGI 5 Pile XT5 15.71 5.67 0.96

Totals with fugitives 274.4 89.1 16.0 37.5 21.6 0.156 2.9 2.6 0.6 36016.5 36803.7 0.488 0.465Totals without fugitives 163.7 49.7 10.1 37.5 21.6 0.156 2.88 2.6 0.6 36016.5 36803.7 0.488 0.465

*Grain can be received at any pit, so worst-case limited emissions occur when grain is received at the truck pits the are not controlled by the baghouse (EQUI 5 and 11)**Worst-case loadout is by truck, so limited emissions from loadout are accounted for at the truck loadout stations (EQUI60, 61, and 62)***Pile 1 is excluded from the limited emissions from because it does not include emissions from the transfer of grain from a truck to a pile conveyor, since Pile 1 is fed by enclosed permanent conveyors that receive grain from a pit. Limited emissions are applied at the other three piles (FUGI 3, 4, and 5)

Actual Grain ReceivedYear Bushels Tons Conversions lb/bushel lb/ft^32013 6,651,782 199,553 Corn 56 44.82014 7,306,403 219,192 Soybeans 60 482015 8,174,563 245,237 Conservatively assume 60 lb/bushel for all grain.2016 10,579,735 317,3922017 8,078,367 242,351

Temporary Storage Piles Capacity Bushels TonsXT2 657730 19,732XT3 677423 20,323XT4 1168000 35,040XT5 1227266 36,818

Total 111,913

Permit LimitsTotal Throughput 594,000 tons/year

CHS Inc - Prairie Lake Coop, Glenwood Grain ElevatorPermit #12100021-101

Grain ReceivingReceiving Pits EQUI # Limiting factor design capacity units design capacity units

Grain Receiving Pit 1 EQUI 1 Leg 1 (EQUI 11) 20000 bushels/hr 600 tons/hrGrain Receiving Pit 2 EQUI 20 Leg 2 (EQUI 12) 10000 bushels/hr 300 tons/hr

Notes:

Emission factors are from AP-42 Table 9.9.1-1.Grain is received from straight trucks, hopper trucks, or rail. Worst-case emissions are from straight truck receiving.

Grain Receiving Pit 1 (EQUI 1)

PollutantEmission Factor

lb/tonEmissions

lb/hr

Unlimited/Uncontrolled Emissions

tpyPM 0.180 108.0 473.0

PM10 0.059 35.4 155.1PM2.5 0.010 6.00 26.3

Grain Receiving Pit 2 (EQUI 20)

PollutantEmission Factor

lb/tonEmissions

lb/hr

Unlimited/Uncontrolled Emissions

tpyPM 0.180 54.0 236.5

PM10 0.059 17.7 77.5PM2.5 0.010 3.0 13.1

Limited Annual Emissions for both

Description PollutantMax Annual Throughput

tons/yrEmission Factor

lb/tonLimited Annual emissions tpy

Straight Trucks PM 614,323 0.180 55.29Straight Trucks PM10 614,323 0.059 18.12Straight Trucks PM2.5 614,323 0.010 3.07

Limited emissions per receiving station (total/2) PM 27.64PM10 9.06PM2.5 1.54

Leg capacity is used to determine the hourly receiving rate for each receiving pit, since Leg capacity is the limiting factor (has a throughput capacity less than the receiving conveyor).

Limited annual emissions assume 594,000 tons/year (permit limit) and that all grain is received by straight truck (worst case). Limited emissions also include potential emissions from trucks that are used to reclaim grain from temporary storage Pile XT3. Storage Pile XT3 is fed by conveyors that are connected to the main grain handling system, so grain that is stored at Pile XT3 may be received twice (once when added to the pile and once when reclaimed from the pile). The pile may be filled only once per year, and the capacity the pile is 20,323 tons.

CHS Inc - Prairie Lake Coop, Glenwood Grain ElevatorPermit #12100021-101Grain Drying Criteria Pollutant EmissionsZimmerman Dryer (EQUI 16)

short-term capacity 10000 bushels/hr

60.0 lb/bushel300 tons/hr

annual throughput 594,000 tons/yrFuel Propane-fired

Heat input 60.192 MMBtu/hr91.5 MMbtu/10^3 gallon

0.6578 10^3 gallons/hr5762.64 10^3 gallons/year

Overall emissions from the dryer are from the grain itself plus the emissions from fuel combustion.Emission factors below are from AP-42 Table 9.9.1-1 for grain drying with a column dryer

Description Equipment # PollutantThroughput Rate

tons/hrEmission Factor

lb/tonEmissions

lb/hrZimmerman Dryer EQUI 16 PM 300 0.220 66.00Zimmerman Dryer EQUI 16 PM10 300 0.055 16.50Zimmerman Dryer EQUI 16 PM2.5 300 0.0094 2.82

PollutantThroughput Rate


lb/tonLimited Emissions

tpyPM 594,000 0.220 65.34

PM10 594,000 0.055 16.34PM2.5 594,000 0.0094 2.79

Zimmerman Dryer Combustion Emissions (Propane)

PollutantEmission Factorlb/10^3 gallons

Emission Factor SourceEmissions

lb/hrUnlimited Emissions

tpyLimited Emissions

tpy

NOx 13 AP-42 Table 1.5-1 8.55 37.46 37.46CO 7.5 AP-42 Table 1.5-1 4.934 21.61 21.61PM 0.70 AP-42 Table 1.5-1 0.460 2.0169 2.02

PM10 0.7 AP-42 Table 1.5-1 0.460 2.0169 2.02PM2.5 0.7 AP-42 Table 1.5-1 0.460 2.0169 2.02SO2 0.054 AP-42 Table 1.5-1 (SO2 content 0.54 gr/100 ft^3) 0.036 0.1556 0.16VOC 1.0 AP-42 Table 1.5-1 0.658 2.8813 2.88N2O 0.9 AP-42 Table 1.5-1 0.592 2.5932 2.59CH4 0.2 AP-42 Table 1.5-1 0.132 0.5763 0.58CO2 12500 AP-42 Table 1.5-1 8223 36017 36016.52

CO2e NA 40 CFR Part 98, Table A-1¥ 8403 36804 36804¥Global warming potentials of 1 for CO2, 25 for methane, and 298 for nitrous oxide.

PM Totals from grain drying and fuel combustion

PollutantEmissions



tpyPM 66.46 291.10 67.36

PM10 16.96 74.29 18.35PM2.5 3.28 14.37 4.81

of 13

CHS Inc - Prairie Lake Coop, Glenwood Grain ElevatorPermit #12100021-101Grain Drying HAP Emissions

Zimmerman Dryer (EQUI 16)Propane-fired 60.192 MMBtu/hr

NG heat content 1020 Btu/scf

HAPEmission Factor

lb/10^6 scfEmission Factor

SourceEmission Factor

lb/MmbtuEmissions

lb/hrUnrestricted Emissions

tpy2-Methylnaphthalene 2.40E-05 AP-42 Table 1.4-3 2.35E-08 1.42E-06 6.20E-06

3-methylchloranthrene 1.80E-06 AP-42 Table 1.4-3 1.76E-09 1.06E-07 4.65E-077,12-dimethylbenz(a)anthracene 1.60E-05 AP-42 Table 1.4-3 1.57E-08 9.44E-07 4.14E-06

Acenaphthene 1.80E-06 AP-42 Table 1.4-3 1.76E-09 1.06E-07 4.65E-07Acenaphthylene 1.80E-06 AP-42 Table 1.4-3 1.76E-09 1.06E-07 4.65E-07

Anthracene 2.40E-06 AP-42 Table 1.4-3 2.35E-09 1.42E-07 6.20E-07Benz(a)anthracene 1.80E-06 AP-42 Table 1.4-3 1.76E-09 1.06E-07 4.65E-07

Benzene 2.10E-03 AP-42 Table 1.4-3 2.06E-06 1.24E-04 5.43E-04Benzo(a)pyrene 1.20E-06 AP-42 Table 1.4-3 1.18E-09 7.08E-08 3.10E-07

Benzo(b)fluoranthene 1.80E-06 AP-42 Table 1.4-3 1.76E-09 1.06E-07 4.65E-07Benzo(g,h,i)perylene 1.20E-06 AP-42 Table 1.4-3 1.18E-09 7.08E-08 3.10E-07

Benzo(k)fluoranthene 1.80E-06 AP-42 Table 1.4-3 1.76E-09 1.06E-07 4.65E-07Chrysene 1.80E-06 AP-42 Table 1.4-3 1.76E-09 1.06E-07 4.65E-07

Dibenzo(a,h)anthracene 1.20E-06 AP-42 Table 1.4-3 1.18E-09 7.08E-08 3.10E-07Dichlorobenzene 1.20E-03 AP-42 Table 1.4-3 1.18E-06 7.08E-05 3.10E-04

Fluoranthene 3.00E-06 AP-42 Table 1.4-3 2.94E-09 1.77E-07 7.75E-07Fluorene 2.80E-06 AP-42 Table 1.4-3 2.75E-09 1.65E-07 7.24E-07

Formaldehyde 7.50E-02 AP-42 Table 1.4-3 7.35E-05 4.43E-03 1.94E-02Hexane 1.8 AP-42 Table 1.4-3 1.76E-03 1.06E-01 4.65E-01

Indeno(1,2,3-cd)pyrene 1.80E-06 AP-42 Table 1.4-3 1.76E-09 1.06E-07 4.65E-07Naphthalene 6.10E-04 AP-42 Table 1.4-3 5.98E-07 3.60E-05 1.58E-04

Phenanthrene 1.70E-05 AP-42 Table 1.4-3 1.67E-08 1.00E-06 4.39E-06Pyrene 5.00E-06 AP-42 Table 1.4-3 4.90E-09 2.95E-07 1.29E-06Toluene 3.40E-03 AP-42 Table 1.4-3 3.33E-06 2.01E-04 8.79E-04Arsenic 2.00E-04 AP-42 Table 1.4-4 1.96E-07 1.18E-05 5.17E-05

Beryllium 1.20E-05 AP-42 Table 1.4-4 1.18E-08 7.08E-07 3.10E-06Cadmium 1.10E-03 AP-42 Table 1.4-4 1.08E-06 6.49E-05 2.84E-04Chromium 1.40E-03 AP-42 Table 1.4-4 1.37E-06 8.26E-05 3.62E-04

Cobalt 8.40E-05 AP-42 Table 1.4-4 8.24E-08 4.96E-06 2.17E-05Manganese 3.80E-04 AP-42 Table 1.4-4 3.73E-07 2.24E-05 9.82E-05

Mercury 2.60E-04 AP-42 Table 1.4-4 2.55E-07 1.53E-05 6.72E-05Nickel 2.10E-03 AP-42 Table 1.4-4 2.06E-06 1.24E-04 5.43E-04

Selenium 2.40E-05 AP-42 Table 1.4-4 2.35E-08 1.42E-06 6.20E-06Lead 5.00E-04 AP-42 Table 1.4-2 4.90E-07 2.95E-05 1.29E-04

Total HAPs 1.11E-01 4.88E-01Max Single HAP 1.06E-01 4.65E-01

No emission factors are available form AP-42 for propane combustion, so emission factors were converted to lb/MMBtu from the natural gas emission factors assuming a natural gas heat content of 1020 Btu/scf.


Grain Loadoutcapacity (bushels/hr) capacity (tons/hr)

Rail Loadout 80000 2400Truck Loadout 1 10000 300Truck Loadout 2 50000 1500Truck Loadout 3 5000 150Truck Loadout 4 5000 150

Emission factors from AP-42 Table 9.9.1-1 for grain shipping by truck or railcar.

Description EQUI # PollutantEmission Factor

lb/tonEmissions


tpyRail Loadout EQUI 18 PM 0.027 64.8 283.82Rail Loadout EQUI 18 PM10 0.0022 5.28 23.13Rail Loadout EQUI 18 PM2.5 0.00037 0.888 3.89

Truck Loadout 1 EQUI 19 PM 0.086 25.8 113.00Truck Loadout 1 EQUI 19 PM10 0.029 8.7 38.11Truck Loadout 1 EQUI 19 PM2.5 0.0049 1.47 6.44Truck Loadout 2 EQUI 21 PM 0.086 129 565.02Truck Loadout 2 EQUI 21 PM10 0.029 43.5 190.53Truck Loadout 2 EQUI 21 PM2.5 0.0049 7.35 32.19Truck Loadout 3 EQUI 22 PM 0.086 12.9 56.50Truck Loadout 3 EQUI 22 PM10 0.029 4.35 19.05Truck Loadout 3 EQUI 22 PM2.5 0.0049 0.735 3.22Truck Loadout 4 EQUI 23 PM 0.086 12.9 56.50Truck Loadout 4 EQUI 23 PM10 0.029 4.35 19.05Truck Loadout 4 EQUI 23 PM2.5 0.0049 0.735 3.22

Limited EmissionsOverall loadout is limited by the total facility grain throughput limit of 594,000 tons/year. Truck loadout is worst case.

PollutantThroughput Rate


lb/tonLimited Annual emissions tpy

Emissions per truck loadout station (total/4)

PM 594,000 0.086 25.54 8.51PM10 594,000 0.029 8.61 2.87PM2.5 594,000 0.0049 1.46 0.485


COMG 1 (EQUI 2-9, 11-15)Enclosed Conveyors and LegsThe "headhouse" emission factor from AP-42 Table 9.9.1-1 accounts for the grain lost while moving through the grain handling system.Maximum hourly throughput is determined by the total receiving rate for all pits.Limited throughput is based on 594,000 tons per year plus the grain that may be reclaimed from Pile XT3 (20,323 tons per year).Grain Handling

Description PollutantThroughput Rate

tons/hr

Limited Throughput Rate

tons/yr

Emission Factorlb/ton

Emission Factor SourceEmissions



tpy

Headhouse PM 900 614,323 0.061 AP-42 Table 9.9.1-1 54.90 240.46 18.74Headhouse PM10 900 614,323 0.034 AP-42 Table 9.9.1-1 30.60 134.03 10.44Headhouse PM2.5 900 614,323 0.0058 AP-42 Table 9.9.1-1 5.22 22.86 1.78

Unpaved Roads

Page 9


Unpaved Roads (FUGI 1)

Unpaved road emissions from grain receiving and grain loadout to truck Source: AP-42 13.2.2 (11/2006)

Throughput (max capacity) = 1,208,323

Throughput (max capacity) = 900 tons/hour (based on total receiving capacity)

k = PM particle size multiplier 4.9k10 = PM10 particle size multiplier 1.5

k2.5= PM2.5particle size multiplier 0.15

s = silt content of road (%) 6 6% value from top of range of plant road; from AP-42 Table 13.2.2-1 (11/06) .

W = mean vehicle weight (ton) 17.0 As calculated from the table below.

Vpotential = # vehicle trips / yr 67129 Based on the potential maximum annual throughput and vehicle capacities.

Vpotential = # vehicle trips / hour 50

M = miles of unpaved roads 0.2

Hopper trucks Straight trucks

0% 100% % of total trips

12.5 8 Empty weight (tons)

40 26 Full weight (tons)

27.5 18 Truck capacity (tons)

Worst-case assumption is all straight trucks.

Potential Vehicle Miles Traveled (VMT) / year = Vpotential x M 13,426

Potential Vehicle Miles Traveled (VMT) / hr = Vpotential x M 10

PM emission factor (lb/VMT) = k(s / 12)0.7 (W / 3)0.45 6.58PM10 emission factor (lb/VMT) = k(s / 12)0.9 (W / 3)0.45 1.75

PM2.5 emission factor (lb/VMT) = k(s / 12)0.9 (W / 3)0.45 0.18

Emissionslb/hr

Unlimited Annual emissionstpy

Limited Annual emissions

tpyPM 65.84 288.37 44.20

PM10 17.55 76.85 11.78PM2.5 1.75 7.68 1.178

tons/year (total grain received (594,000 tons) plus max amount of grain loaded out by truck (594,000 tons) plus portion stored on outdoor storage pads (111,913 tons/year)

CHS Inc - Prairie Lake Coop, Glenwood Grain ElevatorPermit #12100021-101Temporary Storage

Emission factors are from AP-42 Table 9.9.1-1 for straight truck (applied to steps 1 and 4) or headhouse (applied to steps 2 and 3).

PollutantStraight truck emission

factorsHeadhouse emission factors Units

PM 0.360 0.061 lb/tonPM10 0.118 0.034 lb/tonPM2.5 0.020 0.0058 lb/ton

Emissions from wind erosion of the piles during storage is not needed because the piles are covered by tarps.

Pile FUGI Pile Name Associated conveyors Capacity (bushels/hr) Capacity (tons/hr)

FUGI 2 Pile XT2 Portable Conveyor 3 15000 450FUGI 3 Pile XT3 Conveyor 9 and Portable Conveyors 60000 1800FUGI 4 Pile XT4 Portable Conveyor 2 15000 450FUGI 5 Pile XT5 Portable Conveyor 1 25000 750

Capacity (bushels/hr) Capacity (tons/hr)Front end loader 7,000 2101) Truck to pile conveyor (speed of transfer limited by conveyor capacity, so conveyor capacity is used to calculate the transfer rate)

Pollutant Emissions (lb/hr)Unlimited Emissions

(tpy)FUGI 2 PM 648.0 2838.2

PM10 212.4 930.3PM2.5 36.0 157.7

FUGI 4 PM 162.0 709.6PM10 53.1 232.6PM2.5 9.0 39.4

FUGI 5 PM 270.0 1182.6PM10 88.5 387.6PM2.5 15.0 65.7

There are four outdoor storage piles at the facility. Grain is added to the piles by fixed outdoor conveyors or portable conveyors. Pile XT3 has one fixed conveyor that drops grain into the storage area. Piles XT2, XT3, and XT4 are fed by portable conveyors.

Emissions from storage pile-related activities are accounted for at each FUGI. With the exception of Pile XT3 (where grain is added to the pile from silo storage (so there is no transfer of the grain directly from trucks), the emission sources for each pile are from: 1) transfer of the grain from trucks to the pile conveyor, 2) conveyance of the grain and transfer from the pile conveyor to the pile 3) reclaim of the grain using a grain gobbler (which is a machine that uses an auger to gather the grain from the pile and a conveyor to elevate the grain and drop it into a truck), and 4) the drop of grain into the truck.

2) Conveyor to pile (rate determined by conveyor capacity)

Pollutant Emissions lb/hrUnlimited Emissions

tpyFUGI 2 PM 27.5 120.2

PM10 15.3 67.0PM2.5 2.6 11.4

FUGI 3 PM 109.8 480.9PM10 61.2 268.1PM2.5 10.4 45.7

FUGI 4 PM 27.5 120.2PM10 15.3 67.0PM2.5 2.6 11.4

FUGI 5 PM 45.8 200.4PM10 25.5 111.7PM2.5 4.4 19.1

3) Reclaim by front end loader (only one front end loader so can only reclaim from one pile at a time)

PollutantEmissions


tpyUnlimited Emissions

per pile tpy

PM 12.8 56.1 14.0PM10 7.1 31.3 7.8PM2.5 1.2 5.3 1.3

4) Drop into truck (rate determined by front end loader capacity)

PollutantEmissions


tpyUnlimited Emissions

per pile tpy

PM 75.6 331.1 82.8PM10 24.8 108.5 27.1PM2.5 4.2 18.4 4.6

Total emissions per pile

PollutantEmissions


tpy

FUGI 2 PM 115.9 217.0PM10 47.2 102.0PM2.5 8.03 17.4

FUGI 3 PM 846.2 3416.0PM10 305.5 1233.3PM2.5 51.9 209.3

FUGI 4 PM 277.9 926.6PM10 100.3 334.5PM2.5 17.0 56.8

FUGI 5 PM 404.2 1479.8PM10 145.9 534.3PM2.5 24.8 90.7

Limited EmissionsTemporary storage capacity: 111,913 tpyLimited Emissions (tpy) from all storage

Pollutant 1) Truck to pile conveyor 2) Conveyor to pile3) Reclaim by front

end loader4) Drop into truck Total

PM 20.14 3.41 3.41 20.14 47.12PM10 6.60 1.90 1.90 6.60 17.01PM2.5 1.12 0.32 0.32 1.12 2.89

Emissions per pile excluding FUGI 3 (Total/3) PM 15.71PM10 5.67PM2.5 0.962

CHS Inc - Prairie Lake Coop, Glenwood Grain Elevator

Permit #12100021-101

Grain Storage

Seven of the storage silos have bin ventsEmission factors are from AP-42 Table 9.9.1-1 for storage bin (vents)Unlimited Emissions are based on the capacity of the conveyor(s) that add grain to each bin.

EQUI # Name Conveyor into binConveyor Rate

(bushels/hr)Rate (tons/hr)

EQUI 27 Bin 1 Conveyors 5 and 7 30000 900

EQUI 28 Bin 2 Conveyor 3 and 7 30000 900



EQUI 31 Bin 5 Conveyor 3 10000 300

EQUI 32 Bin 6 Leg 1 20000 600

EQUI 33 Bin 7 Leg 1 20000 600

EQUI 34 Bin 8 Leg 1 20000 600



EQUI 37 Bin 11 Leg 1 20000 600

Limited emissions are based on the annual throughput limit plus the amount that may be reclaimed from Pile 1 (since the Pile 1 grain may pass through a vented bin twice) divided evenly among each bin = (594,000 + 20,323)/10 = 61,432.

Description EQUI # PollutantThroughput Rate

tons/hrLimited Throughput Rate


lb/tonEmissions



tpy

Bin 1 EQUI 27 PM 900 55,848 0.025 22.50 98.55 0.698

Bin 1 EQUI 27 PM10 900 55,848 0.006 5.67 24.83 0.176

Bin 1 EQUI 27 PM2.5 900 55,848 0.0011 0.99 4.34 0.031

Bin 2 EQUI 28 PM 900 55,848 0.025 22.50 98.55 0.698

Bin 2 EQUI 28 PM10 900 55,848 0.006 5.67 24.83 0.176

Bin 2 EQUI 28 PM2.5 900 55,848 0.0011 0.99 4.34 0.031

Bin 3 EQUI 29 PM 900 55,848 0.025 22.50 98.55 0.698

Bin 3 EQUI 29 PM10 900 55,848 0.006 5.67 24.83 0.176

Bin 3 EQUI 29 PM2.5 900 55,848 0.0011 0.99 4.34 0.031

Bin 4 EQUI 30 PM 900 55,848 0.025 22.50 98.55 0.698

Bin 4 EQUI 30 PM10 900 55,848 0.006 5.67 24.83 0.176

Bin 4 EQUI 30 PM2.5 900 55,848 0.0011 0.99 4.34 0.031

Bin 5 EQUI 31 PM 300 55,848 0.025 7.50 32.85 0.698

Bin 5 EQUI 31 PM10 300 55,848 0.006 1.89 8.28 0.176

Bin 5 EQUI 31 PM2.5 300 55,848 0.0011 0.33 1.45 0.031

Bin 6 EQUI 32 PM 600 55,848 0.025 15.00 65.70 0.698

Bin 6 EQUI 32 PM10 600 55,848 0.006 3.78 16.56 0.176

Bin 6 EQUI 32 PM2.5 600 55,848 0.0011 0.66 2.89 0.031

Bin 7 EQUI 33 PM 600 55,848 0.025 15.00 65.70 0.698

Bin 7 EQUI 33 PM10 600 55,848 0.006 3.78 16.56 0.176

Bin 7 EQUI 33 PM2.5 600 55,848 0.0011 0.66 2.89 0.031

Bin 8 EQUI 34 PM 600 55,848 0.025 15.00 65.70 0.698

Bin 8 EQUI 34 PM10 600 55,848 0.006 3.78 16.56 0.176

Bin 8 EQUI 34 PM2.5 600 55,848 0.0011 0.66 2.89 0.031

Bin 9 EQUI 35 PM 600 55,848 0.025 15.00 65.70 0.698

Bin 9 EQUI 35 PM10 600 55,848 0.006 3.78 16.56 0.176

Bin 9 EQUI 35 PM2.5 600 55,848 0.0011 0.66 2.89 0.031

Bin 10 EQUI 36 PM 600 55,848 0.025 15.00 65.70 0.698

Bin 10 EQUI 36 PM10 600 55,848 0.006 3.78 16.56 0.176

Bin 10 EQUI 36 PM2.5 600 55,848 0.0011 0.66 2.89 0.031

Bin 11 EQUI 37 PM 600 55,848 0.025 15.00 65.70 0.698

Bin 11 EQUI 37 PM10 600 55,848 0.006 3.78 16.56 0.176

Bin 11 EQUI 37 PM2.5 600 55,848 0.0011 0.660 2.891 0.031

Attachment 2: Subject Item Inventory and Calculation Spreadsheets CHS Inc – Ruthton Grain Elevator Permit Number: 11700027-101

TEMPO SI Category TEMPO SI ID TEMPO SI Type Description TEMPO Status TEMPO Status Date NameTotal Facility TFAC 1 Air Quality Total Facility Active / Existing 11/24/2010 CHS Inc - Ruthton Grain ElevatorComponent Group COMG 1 Air Component Group Active / Existing 5/2/2018 Enclosed Conveyors and LegsEquipment EQUI 1 Loading-Unloading Equipment Active / Existing 1/1/1999 Grain Receiving Pit 1Equipment EQUI 2 Material Handling Equipment Active / Existing 1/1/2014 Conveyor 1Equipment EQUI 3 Material Handling Equipment Active / Existing 1/1/2014 Conveyor 2Equipment EQUI 4 Material Handling Equipment Active / Existing 1/1/2013 Conveyor 3Equipment EQUI 5 Material Handling Equipment Active / Existing 1/1/2011 Conveyor 4Equipment EQUI 6 Material Handling Equipment Active / Existing 1/1/2014 Conveyor 5Equipment EQUI 7 Material Handling Equipment Active / Existing 1/1/2015 Conveyor 6Equipment EQUI 8 Material Handling Equipment Active / Existing 1/1/1999 Conveyor 7Equipment EQUI 9 Material Handling Equipment Active / Existing 1/1/1999 Conveyor 8Equipment EQUI 10 Material Handling Equipment Active / Existing 1/1/1999 Conveyor 9Equipment EQUI 11 Material Handling Equipment Active / Existing 1/1/2012 Leg 1Equipment EQUI 12 Material Handling Equipment Active / Existing 1/1/1989 Leg 2Equipment EQUI 13 Material Handling Equipment Active / Existing 1/1/2014 Leg 3Equipment EQUI 14 Material Handling Equipment Active / Existing 1/1/2011 Leg 4Equipment EQUI 15 Material Handling Equipment Active / Existing 1/1/2011 Leg 5Equipment EQUI 16 Dryer/Oven, direct fired Active / Existing 1/1/2011 Zimmerman DryerEquipment EQUI 18 Loading-Unloading Equipment Active / Existing 1/1/2014 Rail LoadoutEquipment EQUI 19 Loading-Unloading Equipment Active / Existing 1/1/1989 Truck Loadout 1Equipment EQUI 20 Loading-Unloading Equipment Active / Existing 1/1/2015 Grain Receiving Pit 2Equipment EQUI 21 Loading-Unloading Equipment Active / Existing 1/1/1989 Truck Loadout 2Equipment EQUI 22 Loading-Unloading Equipment Active / Existing 1/1/1989 Truck Loadout 3Equipment EQUI 23 Loading-Unloading Equipment Active / Existing 1/1/1989 Truck Loadout 4Equipment EQUI 24 Loading-Unloading Equipment Active / Existing 1/1/2017 Portable Conveyor 1Equipment EQUI 25 Loading-Unloading Equipment Active / Existing 1/1/2009 Portable Conveyor 2Equipment EQUI 26 Loading-Unloading Equipment Active / Existing 1/1/2006 Portable Conveyor 3Equipment EQUI 27 Silo/Bin Active / Existing 1/1/1990 Storage Bin 1Equipment EQUI 28 Silo/Bin Active / Existing 1/1/1990 Storage Bin 2Equipment EQUI 29 Silo/Bin Active / Existing 1/1/1990 Storage Bin 3Equipment EQUI 30 Silo/Bin Active / Existing 1/1/1990 Storage Bin 4Equipment EQUI 31 Silo/Bin Active / Existing 1/1/1990 Storage Bin 5Equipment EQUI 32 Silo/Bin Active / Existing 1/1/1999 Storage Bin 6Equipment EQUI 33 Silo/Bin Active / Existing 1/1/1999 Storage Bin 7

Equipment EQUI 34 Silo/Bin Active / Existing 1/1/1999 Storage Bin 8Equipment EQUI 35 Silo/Bin Active / Existing 1/1/1999 Storage Bin 9Equipment EQUI 36 Silo/Bin Active / Existing 1/1/1999 Storage Bin 10Equipment EQUI 37 Silo/Bin Active / Existing 1/1/1999 Storage Bin 11Equipment EQUI 38 Loading-Unloading Equipment Active / Existing 5/4/2018 Front End Loader 1Equipment EQUI 39 Loading-Unloading Equipment Active / Existing 1/1/2009 Front End Loader 2Structure STRU 1 Stack/Vent Active / Existing 4/27/2018 Dryer EmissionsFugitive FUGI 1 Unpaved Roads Active / Existing 1/1/1989 Unpaved RoadsFugitive FUGI 2 Piles Active / Existing 1/1/1999 Pile XT2Fugitive FUGI 3 Piles Active / Existing 1/1/1999 Pile XT3Fugitive FUGI 4 Piles Active / Existing 1/1/2005 Pile XT4Fugitive FUGI 5 Piles Active / Existing 1/1/2005 Pile XT5

Agency Interest Name Subject Item ID SI Designation and Description Group Member ID (padded)CHS Inc - Ruthton Grain Elevator COMG1 Enclosed Conveyors and Legs EQUI2CHS Inc - Ruthton Grain Elevator COMG1 Enclosed Conveyors and Legs EQUI3CHS Inc - Ruthton Grain Elevator COMG1 Enclosed Conveyors and Legs EQUI4CHS Inc - Ruthton Grain Elevator COMG1 Enclosed Conveyors and Legs EQUI5CHS Inc - Ruthton Grain Elevator COMG1 Enclosed Conveyors and Legs EQUI6CHS Inc - Ruthton Grain Elevator COMG1 Enclosed Conveyors and Legs EQUI7CHS Inc - Ruthton Grain Elevator COMG1 Enclosed Conveyors and Legs EQUI8CHS Inc - Ruthton Grain Elevator COMG1 Enclosed Conveyors and Legs EQUI9CHS Inc - Ruthton Grain Elevator COMG1 Enclosed Conveyors and Legs EQUI11CHS Inc - Ruthton Grain Elevator COMG1 Enclosed Conveyors and Legs EQUI12CHS Inc - Ruthton Grain Elevator COMG1 Enclosed Conveyors and Legs EQUI13CHS Inc - Ruthton Grain Elevator COMG1 Enclosed Conveyors and Legs EQUI14CHS Inc - Ruthton Grain Elevator COMG1 Enclosed Conveyors and Legs EQUI15CHS Inc - Ruthton Grain Elevator COMG2 Vented Silos EQUI27CHS Inc - Ruthton Grain Elevator COMG2 Vented Silos EQUI28CHS Inc - Ruthton Grain Elevator COMG2 Vented Silos EQUI29CHS Inc - Ruthton Grain Elevator COMG2 Vented Silos EQUI30CHS Inc - Ruthton Grain Elevator COMG2 Vented Silos EQUI31CHS Inc - Ruthton Grain Elevator COMG2 Vented Silos EQUI32CHS Inc - Ruthton Grain Elevator COMG2 Vented Silos EQUI33CHS Inc - Ruthton Grain Elevator COMG2 Vented Silos EQUI34CHS Inc - Ruthton Grain Elevator COMG2 Vented Silos EQUI35CHS Inc - Ruthton Grain Elevator COMG2 Vented Silos EQUI36CHS Inc - Ruthton Grain Elevator COMG2 Vented Silos EQUI37

Subject Item Type Description Subject Item ID SI Designation and Description Manufacturer Model Max Design Capacity Max Design Capacity Units (numerator) Max Design Capacity Units (denominator) Material Construction Start Date Operation Start DateLoading-Unloading Equipment EQUI1 Grain Receiving Pit 1 Schlagel 3020 20000 bushels hours Grain 1/1/1999 1/1/1999Loading-Unloading Equipment EQUI18 Rail Loadout InterSystem NA 80000 bushels hours Grain 1/1/2014 1/1/2014Loading-Unloading Equipment EQUI19 Truck Loadout 1 Howell NA 50000 bushels hours Grain 1/1/1989 1/1/1990Loading-Unloading Equipment EQUI20 Grain Receiving Pit 2 Howell 2014LARU69 10000 bushels hours Grain 1/1/2015 1/1/2015Loading-Unloading Equipment EQUI21 Truck Loadout 2 Howell NA 10000 bushels hours Grain 1/1/1989 1/1/1990Loading-Unloading Equipment EQUI22 Truck Loadout 3 Howell NA 5000 bushels hours Grain 1/1/1989 1/1/1990Loading-Unloading Equipment EQUI23 Truck Loadout 4 Howell NA 5000 bushels hours Grain 1/1/1989 1/1/1990Loading-Unloading Equipment EQUI24 Portable Conveyor 1 Lemar NA 25000 bushels hours Grain 1/1/2017 1/1/2017Loading-Unloading Equipment EQUI25 Portable Conveyor 2 Howell NA 15000 bushels hours Grain 1/1/2009 1/1/2009Loading-Unloading Equipment EQUI26 Portable Conveyor 3 Lemar NA 15000 bushels hours Grain 1/1/2006 1/1/2006Material Handling Equipment EQUI2 Conveyor 1 Hi-Roller 5029-155-486 60000 bushels hours Grain 1/1/2014 1/1/2014Material Handling Equipment EQUI3 Conveyor 2 Hi-Roller 5029-155-486 60000 bushels hours Grain 1/1/2014 1/1/2014Material Handling Equipment EQUI4 Conveyor 3 Schlangel 1614LABRU-UT52 10000 bushels hours Grain 1/1/2013 1/1/2013Material Handling Equipment EQUI5 Conveyor 4 GSI 2020 15000 bushels hours Grain 1/1/2011 1/1/2011Material Handling Equipment EQUI6 Conveyor 5 Schlangel NA 10000 bushels hours Grain 1/1/2014 1/1/2014Material Handling Equipment EQUI7 Conveyor 6 Howell 2014LARU905 8000 bushels hours Grain 1/1/2015 1/1/2015Material Handling Equipment EQUI8 Conveyor 7 Schlangel NA 20000 bushels hours Grain 1/1/1999 1/1/1999Material Handling Equipment EQUI9 Conveyor 8 Schlangel 2040 20000 bushels hours Grain 1/1/1999 1/1/1999Material Handling Equipment EQUI10 Conveyor 9 Gorbon NA 5000 bushels hours Grain 1/1/1999 1/1/1999Material Handling Equipment EQUI11 Leg 1 Schlagel NA 20000 bushels hours Grain 1/1/2012 1/1/2012Material Handling Equipment EQUI12 Leg 2 Howell NA 10000 bushels hours Grain 1/1/1989 1/1/1989Material Handling Equipment EQUI13 Leg 3 Schlagel 4324102p-2 60000 bushels hours Grain 1/1/2014 1/1/2014Material Handling Equipment EQUI14 Leg 4 GSI 10190032 15000 bushels hours Grain 1/1/2011 1/1/2011Material Handling Equipment EQUI15 Leg 5 GSI 10140011 15000 bushels hours Grain 1/1/2011 1/1/2011Silo/Bin EQUI17 Grain Storage Bins McCormick NA 60000 bushels hours Grain 1/1/1989 1/1/1990Silo/Bin EQUI27 Storage Bin 1 McCormick NA 158591 bushels each Grain 1/1/1989 1/1/1990Silo/Bin EQUI28 Storage Bin 2 Storage Bin 2 McCormick 159816 bushels each Grain 1/1/1989 1/1/1990Silo/Bin EQUI29 Storage Bin 3 McCormick NA 163714 bushels each Grain 1/1/1989 1/1/1990Silo/Bin EQUI30 Storage Bin 4 McCormick NA 10000 bushels each Grain 1/1/1989 1/1/1990Silo/Bin EQUI31 Storage Bin 5 McCormick NA 9500 bushels each Grain 1/1/1989 1/1/1990Silo/Bin EQUI32 Storage Bin 6 McCormick NA 95359 bushels each Grain 1/1/1998 1/1/1999Silo/Bin EQUI33 Storage Bin 7 McCormick NA 95359 bushels each Grain 1/1/1998 1/1/1999Silo/Bin EQUI34 Storage Bin 8 McCormick NA 22703 bushels each Grain 1/1/1998 1/1/1999Silo/Bin EQUI35 Storage Bin 9 McCormick NA 95359 bushels each Grain 1/1/1998 1/1/1999Silo/Bin EQUI36 Storage Bin 10 McCormick NA 95359 bushels each Grain 1/1/1998 1/1/1999Silo/Bin EQUI37 Storage Bin 11 McCormick NA 9928 bushels each Grain 1/1/1998 1/1/1999Loading-Unloading Equipment EQUI38 Front End Loader 1 Case 821 4000 bushels hours Grain 1/1/2009 1/1/2009Loading-Unloading Equipment EQUI39 Front End Loader 2 Case NA 7000 bushels hours Grain 1/1/2009 1/1/2009

Subject Item Type Description

Subject Item ID

SI Designation and Description Manufacturer Model

Max Design Capacity

Max Design Capacity Units (numerator)

Max Design Capacity Units (denominator) Material

Construction Start Date

Operation Start Date Firing Method

Dryer/Oven, direct fired EQUI16 Zimmerman Dryer Zimmerman Z-10090 10000 bushels hours Grain 1/1/2011 1/1/2011 Not coal burning

Subject Item Type Description Subject Item ID SI Designation and Description Install Year Pollutants EmittedPiles FUGI2 Pile XT2 1999 Particulate MatterPiles FUGI2 Pile XT2 1999 PM < 2.5 micronPiles FUGI2 Pile XT2 1999 PM < 10 micronPiles FUGI3 Pile XT3 1999 Particulate MatterPiles FUGI3 Pile XT3 1999 PM < 2.5 micronPiles FUGI3 Pile XT3 1999 PM < 10 micronPiles FUGI4 Pile XT4 2005 Particulate MatterPiles FUGI4 Pile XT4 2005 PM < 2.5 micronPiles FUGI4 Pile XT4 2005 PM < 10 micronPiles FUGI5 Pile XT5 2005 Particulate MatterPiles FUGI5 Pile XT5 2005 PM < 2.5 micronPiles FUGI5 Pile XT5 2005 PM < 10 micronUnpaved Roads FUGI1 Unpaved Roads 1989 Particulate MatterUnpaved Roads FUGI1 Unpaved Roads 1989 PM < 2.5 micronUnpaved Roads FUGI1 Unpaved Roads 1989 PM < 10 micron


Subject Item ID

SI Designation and Description

Stack Height (feet)

Stack Diameter (feet)

Stack Flow Rate (cubic ft/min)

Discharge Temperature (°F)

Flow Rate/Temp Information Source

Discharge Direction

Stack/Vent STRU1 Dryer Emissions 127.3 30 500000 80 Manufacturer Horizontally

Subject Item Category Description


Subject Item ID

SI Designation and Description

Relationship Related Subject Item ID

% Flow Related Subject Item Type Description

Start Date (Related Subject Item)

Equipment Dryer/Oven, direct fired EQUI16 Zimmerman Dryer sends to STRU1 100 Stack/Vent 1/1/2011

Subject Item ID Sequence Number Requirement Preview Desc TFAC 1 1 The Permittee shall limit Process Throughput <= 594000 tons per year of grain

received to be calculated by the 15th day of each month for the previous 12-month period as described later in this permit. [Title I Condition: Avoid major source under 40 CFR 52.21(b)(1)(i) and Minn. R. 7007.3000, To avoid major source under 40 CFR 70.2 & Minn. R. 7007.0200]

TFAC 1 2 Daily Recordkeeping: Once each day of operation the Permittee shall calculate, record, and maintain records of the total grain received at receiving pits EQUI 1 or EQUI 20, not including grain reclaimed from Pile XT3 (FUGI 3). Daily records shall by based on ticket reports and maintained electronically. [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]

TFAC 1 3 Monthly Recordkeeping: By the 15th day of each month, for the previous calendar month, the Permittee shall calculate and record the following: 1. the tons of grain received at receiving pits EQUI 1 or 20, not including grain reclaimed from Pile XT3 (FUGI 3), and 2. the 12-month rolling sum of grain received for the previous 12-month period by summing the monthly records for the previous 12 months. [Minn. R. 7007.0800, subps. 4-5]

TFAC 1 4 PERMIT SHIELD: Subject to the limitations in Minn. R. 7007.1800, compliance with the conditions of this permit shall be deemed compliance with the specific provision of the applicable requirement identified in the permit as the basis of each condition. Subject to the limitations of Minn. R. 7007.1800 and 7017.0100, subp. 2, notwithstanding the conditions of this permit specifying compliance practices for applicable requirements, any person (including the Permittee) may also use other credible evidence to establish compliance or noncompliance with applicable requirements. This permit shall not alter or affect the liability of the Permittee for any violation of applicable requirements prior to or at the time of permit issuance. [Minn. R. 7007.1800, (A)(2)]

TFAC 1 5 Circumvention: Do not install or use a device or means that conceals or dilutes emissions, which would otherwise violate a federal or state air pollution control rule, without reducing the total amount of pollutant emitted. [Minn. R. 7011.0020]

TFAC 1 6 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]

Subject Item ID Sequence Number Requirement Preview Desc TFAC 1 7 Operation and Maintenance Plan: Retain at the stationary source an operation

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

TFAC 1 8 Operation Changes: In any shutdown, breakdown, or deviation the Permittee shall immediately take all practical steps to modify operations to reduce the emission of any regulated air pollutant. The Commissioner may require feasible and practical modifications in the operation to reduce emissions of air pollutants. No emissions units that have an unreasonable shutdown or breakdown frequency of process or control equipment shall be permitted to operate. [Minn. R. 7019.1000, subp. 4]

TFAC 1 9 Fugitive Emissions: Do not cause or permit the handling, use, transporting, or storage of any material in a manner which may allow avoidable amounts of particulate matter to become airborne. Comply with all other requirements listed in Minn. R. 7011.0150. [Minn. R. 7011.0150]

TFAC 1 10 The Permittee shall clean up commodities spilled on the driveway and other facility property as required to minimize fugitive emissions to a level consistent with RACT (reasonably available control technology). [Minn. R. 7011.1005, subp. 1(A)]

TFAC 1 11 Noise: The Permittee shall comply with the noise standards set forth in Minn. R. 7030.0010 to 7030.0080 at all times during the operation of any emission units. This is a state only requirement and is not enforceable by the EPA Administrator or citizens under the Clean Air Act. [Minn. R. 7030.0010-7030.0080]

TFAC 1 12 Inspections: The Permittee shall comply with the inspection procedures and requirements as found in Minn. R. 7007.0800, subp. 9(A). [Minn. R. 7007.0800, subp. 9(A)]

TFAC 1 13 The Permittee shall comply with the General Conditions listed in Minn. R. 7007.0800, subp. 16. [Minn. R. 7007.0800, subp. 16]

TFAC 1 14 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)]

TFAC 1 15 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

Subject Item ID Sequence Number Requirement Preview Desc the monitoring systems, such as calibration checks and zero and span adjustments. If monitoring records are required, they should reflect any such periods of process shutdown or checks of the monitoring system. [Minn. R. 7007.0800, subp. 4(D)]

TFAC 1 16 Recordkeeping: Retain all records at the stationary source, unless otherwise specified within this permit, for a period of five (5) years from the date of monitoring, sample, measurement, or report. Records which must be retained at this location include all calibration and maintenance records, all original recordings for continuous monitoring instrumentation, and copies of all reports required by the permit. Records must conform to the requirements listed in Minn. R. 7007.0800, subp. 5(A). [Minn. R. 7007.0800, subp. 5(C)]

TFAC 1 17 Recordkeeping: Maintain records describing any insignificant modifications (as required by Minn. R. 7007.1250, subp. 3) or changes contravening permit terms (as required by Minn. R. 7007.1350, subp. 2), including records of the emissions resulting from those changes. [Minn. R. 7007.0800, subp. 5(B)]

TFAC 1 18 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]

TFAC 1 19 Shutdown Notifications: Notify the Commissioner at least 24 hours in advance of a planned shutdown of any control equipment or process equipment if the shutdown would cause any increase in the emissions of any regulated air pollutant. If the owner or operator does not have advance knowledge of the shutdown, notification shall be made to the Commissioner as soon as possible after the shutdown. However, notification is not required in the circumstances outlined in Items A, B and C of Minn. R. 7019.1000, subp. 3. At the time of notification, the owner or operator shall inform the Commissioner of the cause of the shutdown and the estimated duration. The owner or operator shall notify the Commissioner when the shutdown is over. [Minn. R. 7019.1000, subp. 3]

TFAC 1 20 Breakdown Notifications: Notify the Commissioner within 24 hours of a breakdown of more than one hour duration of any control equipment or process equipment if the breakdown causes any increase in the emissions of any regulated air pollutant. The 24-hour time period starts when the breakdown was discovered or reasonably should have been discovered by the owner or operator. However, notification is not required in the circumstances outlined in Items A, B and C of Minn. R. 7019.1000, subp. 2. At the time of notification or as soon as possible thereafter, the owner or operator shall inform the Commissioner of the cause of the breakdown and the estimated duration. The owner or operator shall notify the Commissioner when the breakdown is over. [Minn. R. 7019.1000, subp. 2]

TFAC 1 21 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]

Subject Item ID Sequence Number Requirement Preview Desc TFAC 1 22 Notification of Deviations Endangering Human Health or the Environment

Report: Within 2 working days of discovery, notify the Commissioner in writing of any deviation from permit conditions which could endanger human health or the environment. Include the following 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]

TFAC 1 23 The Permittee shall submit a semiannual deviations report : Due semiannually, by the 30th of January and July. The first semiannual report submitted by the Permittee shall cover the calendar half-year in which the permit is issued. The first report of each calendar year covers January 1 - June 30. The second report of each calendar year covers July 1 - December 31. Submit this on form DRF-2 (Deviation Reporting Form). If no deviations have occurred, submit the signed report certifying that there were no deviations. [Minn. R. 7007.0800, subp. 6(A)(2)]

TFAC 1 24 Application for Permit Amendment: If a permit amendment is needed, submit an application in accordance with the requirements of Minn. R. 7007.1150 through Minn. R. 7007.1500. Submittal dates vary, depending on the type of amendment needed. Upon adoption of a new or amended federal applicable requirement, and if there are 3 or more years remaining in the permit term, the Permittee shall file an application for an amendment within nine months of promulgation of the applicable requirement, pursuant to Minn. R. 7007.0400, subp. 3. [Minn. R. 7007.0400, subp. 3, Minn. R. 7007.1150 - 7007.1500]

TFAC 1 25 Extension Requests: The Permittee may apply for an Administrative Amendment to extend a deadline in a permit by no more than 120 days, provided the proposed deadline extension meets the requirements of Minn. R. 7007.1400, subp. 1(H). Performance testing deadlines from the General Provisions of 40 CFR pt. 60 and pt. 63 are examples of deadlines for which the MPCA does not have authority to grant extensions and therefore do not meet the requirements of Minn. R. 7007.1400, subp. 1(H). [Minn. R. 7007.1400, subp. 1(H)]

TFAC 1 26 The Permittee shall submit a compliance certification : Due annually, by the 31st of January (for the previous calendar year). Submit this on form CR-04 (Annual Compliance Certification Report). This report covers all deviations experienced during the calendar year. If no deviations have occurred, submit the signed report certifying that there were no deviations. [Minn. R. 7007.0800, subp. 6(C)]

Subject Item ID Sequence Number Requirement Preview Desc TFAC 1 27 Emission Inventory Report: due on or before April 1 of each calendar year

following permit issuance. Submit in a format specified by the Commissioner. [Minn. R. 7019.3000-7019.3100]

TFAC 1 28 Emission Fees: due 30 days after receipt of an MPCA bill. [Minn. R. 7002.0005-7002.0095]

COMG 1 29 Opacity <= 5 percent opacity from handling operation fugitive emissions. This limit applies separately to each individual unit in the group. [Minn. R. 7011.1005, subp. 3(A)]

COMG 2 30 Opacity <= 5 percent opacity from any bin vent while transferring grain into or out of the bin. This limit applies separately to each individual unit in the group. [Minn. R. 7011.1005, subp. 3(A)]

EQUI 1 31 Opacity <= 5 percent opacity from truck unloading station fugitive (uncaptured) emissions. [Minn. R. 7011.1005, subp. 3(A)]

EQUI 1 32 Visible Emissions: The Permittee shall check EQUI 1 for any visible emissions using Method 22 once each day of operation during daylight hours. The observation period shall be no less than 10 minutes and shall be conducted while grain unloading occurs. Each observer determining the presence of visible emissions must meet the training requirements specified in 40 CFR Part 60, appendix A-7, Section 2.3 of Method 22. [Minn. R. 7007.0800, subps. 1-2]

EQUI 1 33 Visible Emissions: Recordkeeping: The Permittee shall record the time and date of each visible emission inspection, and whether or not any visible emissions were observed. The presence of visible emissions at the unloading station is considered a deviation and must be reported in the semiannual deviations report required by this permit. If no grain is received at EQUI 1 during the operating day, then the Permittee shall record that no grain was received. [Minn. R. 7007.0800, subps. 4-5]

EQUI 1 34 Visible Emissions: Corrective Actions: The Permittee shall take corrective action as soon as possible if visible emissions are observed. Corrective actions include, but are not limited to, reducing the truck unloading rate, shrouding the pit during unloading operations, and ceasing operations until no visible emissions are observed. The Permittee shall keep a record of the type and date of any corrective action taken and whether or not the corrective actions eliminated the visible emissions. [Minn. R. 7007.0800, subps. 4-5]

EQUI 10 35 Opacity <= 5 percent opacity from handling operation emissions. [Minn. R. 7011.1005, subp. 3(A)]

EQUI 10 36 Visible Emissions: The Permittee shall check EQUI 10 for any visible emissions at the grain drop point using Method 22 during daylight hours on each day that the conveyor is operated. The observation period shall be no less than 10 minutes and shall be conducted while grain is being added to the pile. Each observer determining the presence of visible emissions must meet the training requirements specified in 40 CFR Part 60, appendix A-7, Section 2.3 of Method 22. [Minn. R. 7009.0800, subps. 1-2]

EQUI 10 37 Visible Emissions: Recordkeeping of Visible Emissions. The Permittee shall record the time and date of each visible emission inspection, and whether or not any visible emissions were observed. The presence of visible emissions from the conveyor or the conveyor drop point is considered a deviation and must be reported in the semiannual deviations report and annual deviations report required by this permit. If the conveyor was not used during the operating day, then the Permittee shall record that the conveyor was not used. [Minn. R. 7007.0800, subps. 4-5]

Subject Item ID Sequence Number Requirement Preview Desc EQUI 10 38 Visible Emissions: Corrective Actions: The Permittee shall take corrective

action as soon as possible if visible emissions are observed. Corrective actions include, but are not limited to, adding mineral oil, reducing the conveyor speed and postponing operations until no visible emissions are observed. The Permittee shall keep a record of the type and date of any corrective action taken and whether or not the corrective actions eliminated the visible emissions. [Minn. R. 7007.0800, subps. 4-5]

EQUI 16 39 The perforations of a column dryer screen must not exceed 3/32 inches in diameter. [Minn. R. 7011.1005, subp. 5(A)]

EQUI 18 40 Opacity <= 5 percent opacity from railcar loading station fugitive (uncaptured) emissions. [Minn. R. 7011.1005, subp. 3(A)]

EQUI 18 41 Visible Emissions: The Permittee shall check EQUI 18 for any visible emissions using Method 22 once each day of operation during daylight hours. The observation period shall be no less than 10 minutes and shall be conducted while grain is being loaded out to rail. Each observer determining the presence of visible emissions must meet the training requirements specified in 40 CFR Part 60, appendix A-7, Section 2.3 of Method 22. [Minn. R. 7009.0800, subps. 1-2]

EQUI 18 42 Visible Emissions: Recordkeeping of Visible Emissions. The Permittee shall record the time and date of each visible emission inspection, and whether or not any visible emissions were observed. The presence of visible emissions from rail loadout is considered a deviation and must be reported in the semiannual deviations report and annual deviations report required by this permit. If no grain is added is loaded out to rail during the operating day, then the Permittee shall record that no grain was loaded out to rail. [Minn. R. 7007.0800, subps. 4-5]

EQUI 18 43 Visible Emissions: Corrective Actions: The Permittee shall take corrective action as soon as possible if visible emissions are observed. Corrective actions shall eliminate visible emissions. Corrective actions include, but are not limited to, reducing the rate of grain being loaded out, utilizing a dead box or sock at the loadout spout, and postponing operations until no visible emissions are observed. The Permittee shall keep a record of the type and date of any corrective action taken. [Minn. R. 7007.0800, subps. 4-5]

EQUI 19 44 Opacity <= 10 percent opacity from truck loading station fugitive emissions. [Minn. R. 7011.1005, subp. 3(B)]

EQUI 19 45 Visible Emissions: The Permittee shall check EQUI 19 for any visible emissions using Method 22 once each day of operation during daylight hours. The observation period shall be no less than 10 minutes and shall be conducted while grain loading occurs. Each observer determining the presence of visible emissions must meet the training requirements specified in 40 CFR Part 60, appendix A-7, Section 2.3 of Method 22. [Minn. R. 7007.0800, subps. 1-2]

EQUI 19 46 Visible Emissions: Recordkeeping of Visible Emissions. The Permittee shall record the time and date of each visible emission inspection, and whether or not any visible emissions were observed. The presence of visible emissions at the loading station is considered a deviation and must be reported in the semiannual deviations report and annual deviations report required by this permit. If no grain is loaded at EQUI 19 during the operating day, then the Permittee shall record that no grain was loaded out. [Minn. R. 7007.0800, subps. 4-5]


action as soon as possible if visible emissions are observed. Corrective actions include, but are not limited to, reducing the truck loading rate, utilizing a dead box or sock at the loadout spout, and postponing operations until no visible emissions are observed. The Permittee shall keep a record of the type and date of any corrective action taken and whether or not the corrective actions eliminated the visible emissions. [Minn. R. 7007.0800, subps. 4-5]

EQUI 20 48 Opacity <= 5 percent opacity from truck unloading station fugitive (uncaptured) emissions. [Minn. R. 7011.1005, subp. 3(A)]


EQUI 20 50 Visible Emissions: Recordkeeping: The Permittee shall record the time and date of each visible emission inspection, and whether or not any visible emissions were observed. The presence of visible emissions at the unloading station is considered a deviation and must be reported in the semiannual deviations report required by this permit. If no grain is received at EQUI 20 during the operating day, then the Permittee shall record that no grain was received. [Minn. R. 7007.0800, subps. 4-5]


EQUI 21 52 Opacity <= 10 percent opacity from truck loading station fugitive (uncaptured) emissions. [Minn. R. 7011.1005, subp. 3(B)]



EQUI 21 55 Visible Emissions: Corrective Actions: The Permittee shall take corrective action as soon as possible if visible emissions are observed. Corrective actions include, but are not limited to, reducing the truck loading rate, utilizing a dead box or sock at the loadout spout, and postponing operations until no visible emissions are observed. The Permittee shall keep a record of the type and

Subject Item ID Sequence Number Requirement Preview Desc date of any corrective action taken and whether or not the corrective actions eliminated the visible emissions. [Minn. R. 7007.0800, subps. 4-5]




EQUI 22 59 Visible Emissions: Corrective Actions: The Permittee shall take corrective action as soon as possible if visible emissions are observed. Corrective actions include, but are not limited to, reducing the truck loading rate, utilizing a dead box or sock at the loadout spout, and postponing operations until no visible emissions are observed. The Permittee shall keep a record of the type and date of any corrective action taken and whether or not the corrective actions eliminated the visible emissions. [Minn. R. 7007.0800, subps. 4-5]




EQUI 23 63 Visible Emissions: Corrective Actions: The Permittee shall take corrective action as soon as possible if visible emissions are observed. Corrective actions include, but are not limited to, reducing the truck loading rate, utilizing a dead box or sock at the loadout spout, and postponing operations until no visible emissions are observed. The Permittee shall keep a record of the type and date of any corrective action taken and whether or not the corrective actions eliminated the visible emissions. [Minn. R. 7007.0800, subps. 4-5]

Subject Item ID Sequence Number Requirement Preview Desc EQUI 24 64 Opacity <= 5 percent opacity from truck unloading and handling operation

emissions. This limit applies to emissions from unloading of the grain from trucks to the conveyor, from the grain being conveyed, and from the drop of the grain onto the pile. [Minn. R. 7011.1005, subp. 3(A)]

EQUI 24 65 Visible Emissions: The Permittee shall check EQUI 24 for any visible emissions using Method 22 once each day of operation during daylight hours. The observation period shall be no less than 10 minutes and shall be conducted while grain is being added to a temporary storage pile. Each observer determining the presence of visible emissions must meet the training requirements specified in 40 CFR Part 60, appendix A-7, Section 2.3 of Method 22. [Minn. R. 7007.0800, subps. 1-2]

EQUI 24 66 Visible Emissions: Recordkeeping of Visible Emissions. The Permittee shall record the time and date of each visible emission inspection, and whether or not any visible emissions were observed. The presence of visible emissions is considered a deviation and must be reported in the semiannual deviations report and annual deviations report required by this permit. If the conveyor was not used during the operating day, then the Permittee shall record that the conveyor was not used. [Minn. R. 7007.0800, subps. 4-5]

EQUI 24 67 Visible Emissions: Corrective Actions: The Permittee shall take corrective action as soon as possible if visible emissions are observed. Corrective actions include, but are not limited to, reducing the rate of grain being unloaded and conveyed, reducing the drop height of the grain into the pile, adding a sleeve or sock to the conveyor spout, and postponing operations until no visible emissions are observed. The Permittee shall keep a record of the type and date of any corrective action taken and whether or not the corrective actions eliminated the visible emissions. [Minn. R. 7007.0800, subps. 4-5]

EQUI 25 68 Opacity <= 5 percent opacity from truck unloading and handling operation emissions. This limit applies to emissions from unloading of the grain from trucks to the conveyor, from the grain being conveyed, and from the drop of the grain onto the pile. [Minn. R. 7011.1005, subp. 3(A)]




Subject Item ID Sequence Number Requirement Preview Desc EQUI 26 72 Opacity <= 5 percent opacity from truck unloading and handling operation

emissions. This limit applies to emissions from unloading of the grain from trucks to the conveyor, from the grain being conveyed, and from the drop of the grain onto the pile. [Minn. R. 7011.1005, subp. 3(A)]




EQUI 38 76 Opacity <= 5 percent opacity from handling operation fugitive emissions (this includes emissions from moving grain around any outdoor storage pile and reclaiming grain from the outdoor storage pile). [Minn. R. 7011.1005, subp. 3(A)]

EQUI 38 77 Opacity <= 10 percent opacity from truck loading fugitive emissions (this includes emissions from dropping the grain from the front end loader into a truck). [Minn. R. 7011.1005, subp. 3(B)]


EQUI 38 79 Visible Emissions: Recordkeeping: The Permittee shall record the time and date of each visible emission inspection, and whether or not any visible emissions were observed. The presence of visible emissions is considered a deviation and must be reported in the semiannual deviations report required by this permit. If EQUI 38 was not used to move grain during the operating day, then the Permittee shall record that EQUI 38 was not used. [Minn. R. 7007.0800, subps. 4-5]


action as soon as possible if visible emissions are observed. Corrective actions include, but are not limited to, reducing the truck unloading rate, shrouding the pit during unloading operations, and ceasing operations until no visible emissions are observed. The Permittee shall keep a record of the type and date of any corrective action taken and whether or not the corrective actions eliminated the visible emissions. [Minn. R. 7007.0800, subps. 4-5]

EQUI 39 81 Opacity <= 5 percent opacity from handling operation fugitive emissions (this includes emissions from moving grain around any outdoor storage pile and reclaiming grain from the outdoor storage pile). [Minn. R. 7011.1005, subp. 3(A)]

EQUI 39 82 Opacity <= 10 percent opacity from truck loading fugitive emissions (this includes emissions from dropping the grain from the front end loader into a truck). [Minn. R. 7011.1005, subp. 3(B)]


EQUI 39 84 Visible Emissions: Recordkeeping: The Permittee shall record the time and date of each visible emission inspection, and whether or not any visible emissions were observed. The presence of visible emissions is considered a deviation and must be reported in the semiannual deviations report required by this permit. If EQUI 39 was not used to move grain during the operating day, then the Permittee shall record that EQUI 39 was not used. [Minn. R. 7007.0800, subps. 4-5]


FUGI 1 86 The Permittee shall clean up commodities spilled on the driveway and other facility property as required to minimize fugitive emissions to a level consistent with RACT (reasonably available control technology). [Minn. R. 7011.1005, subp. 1(A)]

FUGI 1 87 The Permittee shall clean all roads at least once each calendar month. Anytime fugitive emissions are observed on facility roadways, the Permittee shall immediately eliminate fugitive emissions by cleaning those road segments and/or apply water or a chemical dust suppressant. [Minn. R. 7007.0800, subp. 1(A) and (B)]

FUGI 1 88 Recordkeeping of visible emissions: On each day of operation, the Permittee shall visually inspect all surfaces to minimize or eliminate fugitive emissions. The facility shall maintain records of this inspection that include the date of inspection, whether or not fugitive dust was observed leaving the property, what corrective actions were taken (if any), when the corrective actions were taken, and whether the corrective actions eliminated the fugitive dust. [Minn. R. 7007.0800, subps. 4-5]

Subject Item ID Sequence Number Requirement Preview Desc FUGI 1 89 The Permittee shall implement and enforce a facility-wide speed limit of 10

miles per hour. The Permittee must post the speed limit in a highly visible location near the facility entrance. [Minn. R. 7007.0800, subp. 2(B)]

FUGI 2 90 Opacity <= 5 percent opacity from handling operation fugitive emissions. [Minn. R. 7011.1005, subp. 3(A)]

FUGI 2 91 The Permittee shall fully cover the pile while grain is being stored. [Minn. R. 7007.0800, subp. 2(B)]

FUGI 2 92 The capacity of Pile XT2 (FUGI 2) is 19,732 tons of grain. The Permittee shall fill the pile only once each calendar year. [Minn. R. 7007.0800, subp. 2(B)]










Attachment 3: Points Calculator CHS Inc – Ruthton Grain Elevator Permit Number: 11700027-101

Points Calculator

(DQ Points)

1) AI ID No.: 137947 Total Points 702) Facility Name: CHS Inc - Ruthton Grain Elevator3) Small business? y/n? n

4) Air Project Tracking Numbers (including all

5902 5) Date of each Application Received: 10/19/2017

6) Final Permit No. 11700027-1017) Permit Staff Rachel Yucuis

Total TotalApplication Type Air Project Tracking No. Tempo Activity ID Qty. Points Points Additionl Cost DetailsAdministrative Amendment 1 0 -$

Minor Amendment 4 0 -$ Applicability Request 10 0 -$ Moderate Amendment 15 0 -$ Major Amendment 25 0 -$ Individual State Permit (not reissuance) 5902 IND20170001 1 50 50 14,250.00$ Individual Part 70 Permit (not reissuance) 75 0 -$

Additional PointsModeling Review 15 0 -$

BACT Review 15 0 -$ LAER Review 15 0 -$ CAA section 110(a)(2)(D)(i)(I) Review (i.e., Transport Rule/CAIR/CSAPR)

10 0 -$

Part 75 CEM analysis 10 0 -$ NSPS Review 10 0 -$ NESHAP Review 10 0 -$ Case-by-case MACT Review 20 0 -$ Netting 10 0 -$ Limits to remain below threshold 5902 IND20170001 2 10 20 5,700.00$ NSR, Part 70Plantwide Applicability Limit (PAL) 20 0 -$ AERA review 15 0 -$ Variance request under 7000.7000 35 0 -$ Confidentiality request under 7000.1300 2 0 -$ EAW review 0Part 4410.4300, subparts 18, item A; and 29 15 0 -$ Part 4410.4300, subparts 8, items A & B; 10, items A to C; 16, items A & D; 17, items A to C & E to G; and 18, items B & C

35 0 -$

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

70 0 -$

Add'l Points 20

NOTES:

air individual permit state permit no. 11700027-101 for

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