AIR EMISSION PERMIT NO. 03700020-002 IS ISSUED TO ConAgra ... · ConAgra Flour Milling Company operates a wheat flour and animal feed mill in Hastings, Minnesota. The facility consists

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

AIR EMISSION PERMIT NO. 03700020-002

IS ISSUED TO

ConAgra Flour Milling Company P.O. Box 3500

Omaha, NE 68103-0500

For

CONAGRA FLOUR MILLING COMPANY – HASTINGS 2005 South Vermilion Street

Hastings, Dakota County, MN 55033 The emission units, control equipment and emission stacks at the stationary source authorized in this permit are as described in the following permit application(s): Permit Type Application Date Total Facility Operating Permit 02/15/1996 Revised copy rec. 11/05/01 Major Amendment 07/28/2003 This permit authorizes the Permittee to operate and modify the stationary source at the address listed above unless otherwise noted in Table A. The Permittee must comply with all the conditions of the permit. Any changes or modifications to the stationary source must be performed in compliance with Minn. R. 7007.1150 to 7007.1500. Terms used in the permit as defined in the state air pollution control rules unless the term is explicitly defined in the permit. Permit Type: State; Limits to Avoid Pt 70/Limits to Avoid NSR Issue Date: December 9, 2002 Amendment Issuance: January 26, 2004 Expiration: Permit does not expire All Title I Conditions do not expire. Ann M. Foss Major Facilities Section Manager Majors and Remediation Division For Sheryl A. Corrigan Commissioner Minnesota Pollution Control Agency

TABLE OF CONTENTS

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

NOTICE TO THE PERMITTEE: Your stationary source may be subject to the requirements of the Minnesota Pollution Control Agency’s (MPCA) solid waste, hazardous waste, and water quality programs. If you wish to obtain information on these programs, including information on obtaining any required permits, please contact the MPCA general information number at: Metro Area (651) 296-6300 Outside Metro Area 1-800-657-3864 TTY (651) 282-5332 The rules governing these programs are contained in Minn. R. chs. 7000-7105. Written questions may be sent to: Minnesota Pollution Control Agency, 520 Lafayette Road North, St. Paul, Minnesota 55155-4194. Questions about this air emission permit or about air quality requirements can also be directed to the telephone numbers and address listed above. PERMIT SHIELD: Subject to the limitations in Minn. R. 7007.1800, compliance with the conditions of this permit shall be deemed compliance with the specific provision of the applicable requirement identified in the permit as the basis of each condition. Subject to the limitations of Minn. R. 7007.1800 and 7017.0100, subp. 2, notwithstanding the conditions of this permit specifying compliance practices for applicable requirements, any person (including the Permittee) may also use other credible evidence to establish compliance or noncompliance with applicable requirements. FACILITY DESCRIPTION:

ConAgra Flour Milling Company operates a wheat flour and animal feed mill in Hastings, Minnesota. The facility consists of hardwheat mills, durum mills, durum processing, a rye mill, and associated elevator, storage, and packaging areas. Seventy-five percent of the wheat received is processed into flour and the remaining 25 percent into feed. The facility operates a boiler for heating and wheat tempering during the winter months. Methyl bromide is used for fumigation.

In Permit -001, the facility accepted limits on the amount of wheat to be processed, and on the amount of fumigant (methyl bromide) which may be used. These limits were federally enforceable, and resulted in the facility being a non-major source under the Part 70 permit program, New Source Review, and the National Emission Standards for Hazardous Air Pollutants program.

AMENDMENT DESCRIPTION:

This amendment removes all three Particulate Matter less than 10 microns (PM10) process throughput limits. The process throughput limits are replaced by an overall facility wide 95 tons per year (tpy) PM10 emission limit. The previous permit (-001) had a facility wide Potential to Emit PM10 emission of 95 tpy. Hence, there is no change in the PM10 Potential to Emit or other pollutant emissions.

TABLE A: LIMITS AND OTHER REQUIREMENTS 01/26/04

ConAgra Flour Milling Co - Hastings

03700020 - 002

Facility Name:

Permit Number:

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

Subject Item: Total Facility

What to do Why to do itFACILITY-SPECIFIC REQUIREMENTS hdr

This permit establishes limits on the facility (including authorized modifications) tokeep it a minor source under New Source Review. The Permittee may not makeany change at the source that would make the source a major source under NewSource Review until a permit amendment has been issued. This includes changesthat might otherwise qualify as insignificant modifications and minor or moderateamendments.

Title I Condition: To avoid major source classificationunder 40 CFR Section 52.21 and Minn. R. 7007.3000

The Permittee shall not begin construction of any single project or projects that areconnected or phased which will cause a total increase in actual emissions ofgreater than 99 tons per year for any criteria pollutant without first getting a permitamendment to authorize the project. Connected and phased have meanings asdefined in Minn. R. 4410.0200 subps. 9b and 60. The Permittee shall not beginconstruction of any other project which is listed in Minn. R. 4410,4300 or Minn. R.4410.4400 without first getting a permit amendment to authorize the project. Suchprojects may require the completion of an Environmental Assessment Worksheet oran Environmental Impact Statement prior to the amendment being issued. This is astate only requirement and is not federally enforceable.

Minn. R. 4410.4300 and Minn. R. 4410.4400

Recordkeeping -- Hours of Generator Operation: The Permittee shall maintaindocumentation on site that the generator listed as an insignificant activity inAppendix B of this permit is an emergency generator by design that qualifies underthe U.S. EPA memorandum entitled "Calculating Potential to Emit (PTE) forEmergency Generators" dated September 6, 1995, limiting operation to 500 hoursper year.

Minn. R. 7007.0800, subp. 4 and 5

PERFORMANCE TESTING hdr

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

Minn. R. ch. 7017

Limits set as a result of a performance test (conducted before or after permitissuance) apply until superseded as specified by Minn. R. 7017.2025 followingformal review of a subsequent performance test on the same unit.

Minn. R. 7017.2025

REQUIREMENTS APPLICABLE TO ALL FACILITIES hdr

Operation and Maintenance Plan: Retain at the stationary source an operation andmaintenance plan for all air pollution control equipment. At a minimum, the O & Mplan shall identify all air pollution control equipment and shall include a preventativemaintenance program for that equipment, a description of (the minimum but notnecessarily the only) corrective actions to be taken to restore the equipment toproper operation to meet applicable permit conditions, a description of theemployee training program for proper operation and maintenance of the controlequipment, and the records kept to demonstrate plan implementation.

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

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

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

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

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

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

Minn. R. 7011.0020

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

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

Minn. R. 7019.1000, subp. 3

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03700020 - 002

Facility Name:

Permit Number:

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

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

Minn. R. 7019.1000, subp. 2

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

Minn. R. 7019.1000, subp. 1

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

Minn. R. 7019.1000, subp. 1

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

Minn. R. 7019.1000, subp. 4

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

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

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

Minn. R. 7011.0150

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

Minn. R. 7007.1150 through Minn. R. 7007.1500

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

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

Recordkeeping: Maintain records describing any insignificant modifications (asrequired 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 emissionsresulting from those changes.

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

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

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

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

Minn. R. 7030.0010 - 7030.0080

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

Minn. R. 7007.0800, subp. 16

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

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

Emission Inventory Report: due 91 days after end of each calendar year followingpermit issuance (April 1). To be submitted on a form approved by theCommissioner.

Minn. R. 7019.3000 through Minn. R. 7019.3010

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

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03700020 - 002

Facility Name:

Permit Number:

The Permittee is required to submit a Risk Management Plan (RMP) under thefederal rule, 40 CFR pt. 68. Each owner or operator of a stationary source, at whicha regulated substance is present above a threshold quantity in a process, shalldesign and implement an accidental release prevention program. A complete RMPmust be submitted to the RMP Reporting Center, PO Box 3346, Merrifield, VA22116. RMP submittal information may be obtained athttp://www.epa.gov/swercepp or by calling 1-800-424-9346. These requirementsmust be complied with no later than the latest of the following dates: (1) June 21,1999; (2) Three years after the date on which a regulated substance is first listedunder 40 CFR Section 68.130; or (3) The date on which a regulated substance isfirst present above a threshold quantity in a process.

40 CFR pt. 68

Particulate Matter < 10 micron: less than or equal to 95 tons/year using 365-dayRolling Sum

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

Calculations: By the 15th day of each month, the Permittee shall record theprocess throughput for each of the four process weights, for each day, of theprevious month and calculate each of the four 365-day rolling sum process weightsfor each day. The Permittee shall also calculate the 365-day rolling sum PM10emissions for each day of the previous month.

For each day, the 365-day rolling sum PM10 emissions are to be calculated usingthe following equation:

E = (R * 6.95E-07) + (M * 1.75184E-04) + (P * 4.5E-05) + (F * 8.32E-08) + 0.96

where:E = Facility - wide PM10 emissions as per 365-day (in tons/yr)R = Grain receiving process throughput weight (from EU 002), in tonsM = Milling process throughput weight (from EU 004), in tonsP = Pellet cooling process throughput weight (from EU 008), in tonsF = Feed Loadout process throughput weight (from EU 005), in tons

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

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03700020 - 002

Facility Name:

Permit Number:

Subject Item: GP 001 Baghouses

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

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































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

Minn. R. 7011.0075, subp. 2; MInn. R. 7007.0800,subp. 4, 5, and 14

Visible Emissions: The Permittee shall check the exhaust stack of each fabric filterincluded in GP001 for any visible emissions once each day of operation duringdaylight hours. During inclement weather, the Permittee shall read and record thepressure drop across the fabric filter, once each day of operation.


Pressure Drop: greater than or equal to 0.5 inches of water column and less than orequal to 8 inches of water column , unless a new range is set pursuant to Minn. R.7017.2025, subp. 3, based on the values recorded during the most recent MPCAapproved performance test where compliance was demonstrated.

Minn. R. 7011.0080

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


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03700020 - 002

Facility Name:

Permit Number:

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


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


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03700020 - 002

Facility Name:

Permit Number:

Subject Item: GP 002 Cyclones

Associated Items: CE 031 Centrifugal Collector - Medium Efficiency

CE 032 Centrifugal Collector - Medium Efficiency

What to do Why to do itThe Permittee shall operate and maintain each cyclone in accordance with theOperation and Maintenance (O & M) Plan. The Permittee shall keep copies of theO & M Plan available onsite for use by staff and MPCA staff.


Pressure Drop: The Permittee shall read and record the pressure drop across thetwo cyclones listed in GP002, once each day of operation.


Pressure Drop: greater than or equal to 4.0 inches of water column , unless a newminimum is set pursuant to Minn. R. 7017.2025, subp. 3, based on the valuesrecorded during the most recent MPCA approved performance test wherecompliance was demonstrated.

Minn. R. 7011.0080

Recordkeeping of Pressure Drop. The Permittee shall record the time and date ofeach pressure drop reading, and whether or not the observed pressure drop waswithin the range specified in this permit.




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


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03700020 - 002

Facility Name:

Permit Number:

Subject Item: EU 001 Boiler

Associated Items: SV 023 Boiler Exhaust

What to do Why to do itOPERATING AND RECORDKEEPING REQUIREMENTS hdr

Fuel Use: Limited to natural gas and distillate oil only Minn. Stat. 116.07, subd. 4a; Minn. R. 7007.0800,subp. 2

Sulfur Content of Fuel: less than or equal to 0.5 percent by weight , based oncertification from fuel supplier.

40 CFR Section 60.42c(d); 40 CFR Section60.42c(h)(1); Minn. R. 7011.0570

Recordkeeping: For each shipment of fuel oil, the Permittee shall obtain andmaintain a copy of the fuel supplier's certification, which shall include the name ofthe oil supplier, and a statement from the oil supplier that the oil complies with thespecifications under the definition of distillate oil in 40 CFR Section 60.41c.

40 CFR Section 60.48c(f)(1); Minn. R. 7011.0570

Monthly Recordkeeping: Record and maintain records of the amounts of each fuelcombusted on a monthly basis. These records may consist of purchase records orreceipts.

40 CFR Section 60.13(i) and February 20, 1992,February 22, 1993, and June 25, 2002 EPAmemoranda to meet the requirements of 40 CFRSection 60.48c(g) and (i); Minn. R. 7011.0570

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03700020 - 002

Facility Name:

Permit Number:

Subject Item: EU 002 Grain Receiving


SV 001 Receiving Exhaust

What to do Why to do itEMISSION LIMITS AND OPERATING REQUIREMENTS hdr

Opacity: less than or equal to 10 percent opacity from the stack Minn. R. 7011.1005, subp. 3(D)

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

Pre-Authorized Changes: The Permittee may modify, replace, or add emissionunits under the designation "EU002," provided grain receipts are tracked andcalculated as specified in this permit, and all other permit conditions are met.

If a proposed change triggers an applicable requirement that is not contained in thispermit, the change must go through the appropriate procedures in Minn. R. ch.7007.

Changes resulting in actual grain throughputs beyond what are allowed in thispermit are not allowed under this provision.

Title I Condition: To avoid classification of equipmentchanges as modifications under 40 CFR Section 52.21

CONTROL EQUIPMENT REQUIREMENTS (CE001 - See GP001 for additionalrequirements)

hdr

The Permittee shall operate and maintain the fabric filter at all times that anyprocess equipment controlled by the fabric filter is operating.

Minn. R. 7011.0065, subp. 2(A)

Total Particulate Matter: greater than or equal to 99 percent control efficiency Minn. R 7011.0065, subp. 1(A)

Total Particulate Matter: greater than or equal to 80 percent control efficiency Minn. R. 7011.1005, subp. 3(E)

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

Minn. R 7011.0065, subp. 1(A)

MONITORING AND RECORDKEEPING REQUIREMENTS hdr

Labeling Requirement: The Permittee shall permanently affix the emission unitnumber (EU002) and another unique number to each piece of equipmentdesignated as part of "Grain Receiving," for tracking purposes. Labeling must becompleted within 120 days of permit issuance. The number can be affixed byplacard, stencil, or other means, provided it is maintained and readable from a safedistance.If equipment is added, it shall be given a new number; numbers from replaced orremoved equipment shall not be reused.

Title I Condition: Monitoring of equipment changesallowed while still avoiding major source classificationunder 40 CFR Section 52.21 and Minn. R. 7007.3000

Equipment List: The Permittee shall maintain a list of each piece of equipmentdesignated under the "Grain Receiving" category. The list shall include:- the type of equipment- the emission unit number (EU002) and another unique identifier- the date of installation and/or modification.

If equipment is added or modified after permit issuance, the Equipment List shallalso note that the following two evaluations were made prior to the change:- the change does not trigger any applicable requirements that are not alreadylisted in this permit- the change does cause violation of any limits listed in this permit.

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

Daily Recordkeeping: Grain Receiving

By the 15th day of each month, the Permittee shall record the grain receivingthroughput quantity (weight), for each day, of the previous month. The Permitteeshall also calculate the 365-day rolling sum of the grain receiving throughput foreach day (in tons). The 365-day rolling sum is "R" for the purpose of thecompliance equation under Subject Item: Total Facility.

Title I Condition: Monitoring of limit to avoid majorsource classification under 40 CFR Section 52.21 andMinn. R. 7007.3000; monitoring of limit to avoid majorsource classification under 40 CFR Section 70.2 andMinn. R. 7007.0200

TESTING REQUIREMENTS hdr

Performance Test: due 365 days after Permit Issuance (Amendment -002) tomeasure opacity from fugitive emissions.

Minn. R. 7017.2020, subp. 1

Performance Test Notifications and Submittals:

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

Minn. R. 7017.2030, subps. 1 - 4;Minn. R. 7017.2018; and Minn. R. 701.2035, subps. 1 -2

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03700020 - 002

Facility Name:

Permit Number:

Subject Item: EU 003 Grain Cleaning










SV 003 Cleaning Exhaust










Opacity: less than or equal to 10 percent opacity from each stack Minn. R. 7011.1005, subp. 3(D)






CONTROL EQUIPMENT REQUIREMENTS (CE003 - CE010, CE035; See GP001for additional requirements)

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The Permittee shall operate and maintain each fabric filter at all times that anyprocess equipment controlled by the fabric filter is operating.

Minn. R. 7011.0065, subp. 2(A)




Minn. R 7011.0065, subp. 1(A)


Labeling Requirement: The Permittee shall permanently affix the emission unitnumber (EU003) and another unique number to each piece of equipmentdesignated as part of "Grain Cleaning," for tracking purposes. Labeling must becompleted within 120 days of permit issuance. The number can be affixed byplacard, stencil, or other means, provided it is maintained and readable from a safedistance.If equipment is added, it shall be given a new number; numbers from replaced orremoved equipment shall not be reused.


A-9



03700020 - 002

Facility Name:

Permit Number:

Equipment List: The Permittee shall maintain a list of each piece of equipmentdesignated under the "Grain Cleaning" category. The list shall include:- the type of equipment- the emission unit number (EU003) and another unique identifier- the date of installation and/or modification.



A-10



03700020 - 002

Facility Name:

Permit Number:

Subject Item: EU 004 Milling
















SV 011 Milling Exhaust









CONTROL EQUIPMENT REQUIREMENTS (CE011 - CE025; See GP001 foradditional requirements)

hdr


Minn. R. 7011.0065, subp. 2(A)




Minn. R 7011.0065, subp. 1(A)


Labeling Requirement: The Permittee shall permanently affix the emission unitnumber (EU004) and another unique number to each piece of equipmentdesignated as part of "Milling," for tracking purposes. Labeling must be completedwithin 120 days of permit issuance. The number can be affixed by placard, stencil,or other means, provided it is maintained and readable from a safe distance.If equipment is added, it shall be given a new number; numbers from replaced orremoved equipment shall not be reused.


A-11



03700020 - 002

Facility Name:

Permit Number:

Equipment List: The Permittee shall maintain a list of each piece of equipmentdesignated under the "Milling" category. The list shall include:- the type of equipment- the emission unit number (EU004) and another unique identifier- the date of installation and/or modification.



Daily Recordkeeping: Milling

By the 15th day of each month, the Permittee shall record the milling throughputquantity (weight), for each day, of the previous month. The Permittee shall alsocalculate the 365-day rolling sum of the milling throughput for each day (in tons).The 365-day rolling sum is "M" for the purpose of the compliance equation underSubject Item: Total Facility.


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03700020 - 002

Facility Name:

Permit Number:

Subject Item: EU 005 Feed Loadout


SV 016 Feed Loadout


Opacity: less than or equal to 5 percent opacity from fugitive emissions from railcarloading.

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

Opacity: less than or equal to 10 percent opacity from fugitive emissions from truckloading.

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






CONTROL EQUIPMENT REQUIREMENTS (See requirements under CE030) hdr


Labeling Requirement: The Permittee shall permanently affix the emission unitnumber (EU005) and another unique number to each piece of equipmentdesignated as part of "Feed Loadout," for tracking purposes. Labeling must becompleted within 120 days of permit issuance. The number can be affixed byplacard, stencil, or other means, provided it is maintained and readable from a safedistance.If equipment is added, it shall be given a new number; numbers from replaced orremoved equipment shall not be reused.


Equipment List: The Permittee shall maintain a list of each piece of equipmentdesignated under the "Feed Loadout" category. The list shall include:- the type of equipment- the emission unit number (EU005) and another unique identifier- the date of installation and/or modification.



Daily Recordkeeping: Feed Loadout

By the 15th day of each month, the Permittee shall record the feed loadoutthroughput quantity (weight), for each day, of the previous month. The Permitteeshall also calculate the 365-day rolling sum of the feed loadout throughput for eachday (in tons). The 365-day rolling sum is "F" for the purpose of the complianceequation under Subject Item: Total Facility.


TESTING REQUIREMENTS hdr

Performance Test: due 365 days after Permit Issuance (Amendment -002) tomeasure opacity from fugitive emissions.

Minn. R. 7017.2020, subp. 1

Performance Test Notifications and Submittals:

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

Minn. R. 7017.2030, subps. 1 - 4;Minn. R. 7017.2018; and Minn. R. 701.2035, subps. 1 -2

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03700020 - 002

Facility Name:

Permit Number:

Subject Item: EU 006 Grain Handling


SV 002 Grain Handling Exhaust








CONTROL EQUIPMENT REQUIREMENTS (CE002; See GP001 for additionalrequirements)

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The Permittee shall operate and maintain the fabric filter at all times that anyprocess equipment controlled by the fabric filter is operating.

Minn. R. 7011.0065, subp. 2(A)


Total Particulate Matter: greater than or equal to 80 percent collection efficiency Minn. R. 7011.1005, subp. 3(E)


Minn. R 7011.0065, subp. 1(A)


Labeling Requirement: The Permittee shall permanently affix the emission unitnumber (EU006) and another unique number to each piece of equipmentdesignated as part of "Grain Handling," for tracking purposes. Labeling must becompleted within 120 days of permit issuance. The number can be affixed byplacard, stencil, or other means, provided it is maintained and readable from a safedistance.If equipment is added, it shall be given a new number; numbers from replaced orremoved equipment shall not be reused.


Equipment List: The Permittee shall maintain a list of each piece of equipmentdesignated under the "Grain Handling" category. The list shall include:- the type of equipment- the emission unit number (EU006) and another unique identifier- the date of installation and/or modification.



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03700020 - 002

Facility Name:

Permit Number:

Subject Item: EU 007 Flour Storage and Loading







SV 017 Storage/Loadout Exhaust







Opacity: less than or equal to 5 percent opacity from fugitive emissions from railcarloading.

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

Opacity: less than or equal to 10 percent opacity from fugitive emissions from truckloading.

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






CONTROL EQUIPMENT REQUIREMENTS (CE026 - CE029, CE033, CE034; SeeGP001 for additional requirements)

hdr


Minn. R. 7011.0065, subp. 2(A)




Minn. R 7011.0065, subp. 1(A)


Labeling Requirement: The Permittee shall permanently affix the emission unitnumber (EU007) and another unique number to each piece of equipmentdesignated as part of "Flour Storage and Loading," for tracking purposes. Labelingmust be completed within 120 days of permit issuance. The number can be affixedby placard, stencil, or other means, provided it is maintained and readable from asafe distance.If equipment is added, it shall be given a new number; numbers from replaced orremoved equipment shall not be reused.


Equipment List: The Permittee shall maintain a list of each piece of equipmentdesignated under the "Flour Storage and Loading" category. The list shall include:- the type of equipment- the emission unit number (EU007) and another unique identifier- the date of installation and/or modification.



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03700020 - 002

Facility Name:

Permit Number:

Subject Item: EU 008 Pellet Cooling

Associated Items: CE 031 Centrifugal Collector - Medium Efficiency

CE 032 Centrifugal Collector - Medium Efficiency

SV 014 Pellet Cooling Exhaust


Total Particulate Matter: less than or equal to 0.3 grains/dry standard cubic foot ofexhaust gas unless required to further reduce emissions to comply with the lessstringent limit of either Minn. R. 7011.0730 or Minn. R. 7011. 0735.

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

Opacity: less than or equal to 20 percent opacity Minn. R. 7011.0715, subp. 1(B)





CONTROL EQUIPMENT REQUIREMENTS (CE031 & CE032; See GP002 foradditional requirements)

hdr

The Permittee shall operate and maintain each cyclone at all times that anyprocess equipment controlled by the device is operating.

Minn. R. 7011.0065, subp. 2(A)



Minn. R 7011.0065, subp. 1(A)


Labeling Requirement: The Permittee shall permanently affix the emission unitnumber (EU008) and another unique number to each piece of equipmentdesignated as part of "Pellet Cooling," for tracking purposes. Labeling must becompleted within 120 days of permit issuance. The number can be affixed byplacard, stencil, or other means, provided it is maintained and readable from a safedistance.If equipment is added, it shall be given a new number; numbers from replaced orremoved equipment shall not be reused.


Equipment List: The Permittee shall maintain a list of each piece of equipmentdesignated under the "Pellet Cooling" category. The list shall include:- the type of equipment- the emission unit number (EU008) and another unique identifier- the date of installation and/or modification.



Daily Recordkeeping: Feed Pelletization

By the 15th day of each month, the Permittee shall record the feed pelletizationthroughput quantity (weight), for each day, of the previous month. The Permitteeshall also calculate the 365-day rolling sum of the feed pellization throughput foreach day (in tons). The 365-day rolling sum is "P" for the purpose of thecompliance equation under Subject Item: Total Facility.


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03700020 - 002

Facility Name:

Permit Number:

Subject Item: CE 030 Fabric Filter - Low Temperature, i.e., T<180 Degrees F

Associated Items: EU 005 Feed Loadout

What to do Why to do itThe operation of this piece of control equipment is not necessary in order for theprocess to meet applicable emissions limits. However, the Permittee wishes totake credit for its operation for the purposes of reporting actual emissions foremission inventory. Therefore, in order for PM and PM10 to be consideredcontrolled for the purposes of emissions inventory, the fabric filter must comply withthe requirements of this permit during the time credit for control is taken. The PMand PM10 generated during that time shall be considered controlled, and thecontrol efficiency used is the limit given in this table.

Minn. Stat. 116.07, subd. 4a; Equipment used underMinn. R. 7019.3020(F)

Total Particulate Matter: greater than or equal to 99 percent control efficiency Minn. Stat. 116.07, subd. 4a; Equipment used underMinn. R. 7019.3020(F)

Total Particulate Matter: greater than or equal to 80 percent control efficiency Minn. Stat. 116.07, subd. 4a; Equipment used underMinn. R. 7019.3020(F)



Total Particulate Matter: greater than or equal to 80 percent capture efficiency Minn. Stat. 116.07, subd. 4a; Equipment used underMinn. R. 7019.3020(F)

Particulate Matter < 10 micron: greater than or equal to 80 percent captureefficiency


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


Visible Emissions: The Permittee shall check SV016 for any visible emissions onceeach day of operation during daylight hours. During inclement weather, thePermittee shall read and record the pressure drop across the fabric filter, onceeach day of operation.


Pressure Drop: greater than or equal to 0.5 inches of water column and less than orequal to 8 inches of water column , unless a new range is set pursuant to Minn. R.7017.2025, subp. 3, based on the values recorded during the most recent MPCAapproved performance test where compliance was demonstrated.


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




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


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03700020 - 002

Facility Name:

Permit Number:

Subject Item: FS 001 Fugitive HAP Sources (Fumigation, Preservation, etc.)

What to do Why to do itBromomethane: less than or equal to 9.75 tons/year using 12-month Rolling Sumcalculated monthly

Title I Condition: To avoid major source classificationunder 40 CFR Section 63.2; to avoid major sourceclassification under 40 CFR Section 70.2 and Minn. R.7007.0200

HAP-Single: less than or equal to 9.75 tons/year using 12-month Rolling Sumcalculated monthly. This shall include each individual HAP used, including thoseused for water purification and product preservation.


HAPs - Total: less than or equal to 9.75 tons/year using 12-month Rolling Sumcalculated monthly. This shall include each individual HAP used, including thoseused for water purification and product preservation.


Monthly Recordkeeping: HAP Emissions

By the 15th day of each month, the Permittee shall calculate and record thefollowing:

1. The quantity of methyl bromide used during the previous month.2. The quantities of other individual HAPs emitted during the previous month(including all HAPs used in water purification and product perservation)3. The 12-month rolling sums of each individual HAP, and total HAPs, by addingtogether the usages calculated for each of the previous 12 months.

Title I Condition: Monitoring for limit to avoid majorsource classification under 40 CFR Section 63.2, 40CFR Section 70.2, and Minn. R. 7007.0200

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TABLE B: SUBMITTALSFacility Name: ConAgra Flour Milling Co - Hastings

Permit Number: 03700020 - 002

01/26/04

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

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

Send any application for a permit or permit amendment to:

Permit Technical AdvisorPermit SectionAir Quality DivisionMinnesota Pollution Control Agency520 Lafayette Road NorthSt. Paul, Minnesota 55155-4194

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

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

SupervisorCompliance Determination UnitAir Quality DivisionMinnesota Pollution Control Agency520 Lafayette Road NorthSt. Paul, Minnesota 55155-4194

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

Mr. George CzerniakAir and Radiation BranchEPA Region V77 West Jackson BoulevardChicago, Illinois 60604

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

U.S. Environmental Protection AgencyClean Air Markets Division1200 Pennsylvania Avenue NW (6204N)Washington, D.C. 20460

B-1

TABLE B: ONE TIME SUBMITTALS OR NOTIFICATIONSFacility Name: ConAgra Flour Milling Co - Hastings


01/26/04

What to send When to send Portion of Facility AffectedTesting Frequency Plan due 60 days after Initial Performance Test for

opacity.EU002

Testing Frequency Plan due 60 days after Initial Performance Test foropacity.

EU005

B-2

TABLE B: RECURRENT SUBMITTALSFacility Name: ConAgra Flour Milling Co - Hastings


01/26/04

What to send When to send Portion of Facility AffectedReport due 30 days after end of each half-year

starting 08/08/1994. The report shall besubmitted to the U.S. EPA, and shall includethe following:- the calendar dates covered in the reportingperiod- records of fuel oil supplier certifications- certified statement signed by the owner oroperator stating that the records of fuelsupplier certifications submitted represent allof the fuel oil combusted during the reportingperiod.

EU001

Semiannual Deviations Report due 30 days after end of each calendarhalf-year starting 12/09/2002 . The firstsemiannual report submitted by the Permitteeshall cover the calendar half-year in which thepermit is issued. The first report of eachcalendar year covers January 1 - June 30.The second report of each calendar yearcovers July 1 - December 31. If no deviationshave occured, the Permittee shall submit thereport stating no deviations.

Total Facility

Annual Report due 90 days after end of each calendar yearstarting 12/09/2002 . The Permittee shallsubmit an annual report by April 1 thatdescribes the changes made at the facilityduring the previous calendar year. The reportwhall include a copy of all Equipment Lists,and shall document any equipment changesthat took place during the previous calendaryear, and any applicable New SourcePerformance Standards or NESHAPs thatbecame effective during the previous calendaryear. This report may be submitted with theannual emissions inventory, but it shall be aseparate document marked as the "AnnualReport." As part of the Annual Report, thePermittee shall verify and certify that thefacility has maintained minor source status forNew Source Review and Part 70.

Total Facility

Compliance Certification due 31 days after end of each calendar yearstarting 12/09/2002 (for the previous calendaryear). To be submitted to the Commissioneron a form approved by the Commissioner.This report covers all deviations experiencedduring the calendar year.

Total Facility

B-3

APPENDIX MATERIAL Facility Name: ConAgra Flour Milling Co - Hastings Permit Number: 03700020-002

Insignificant Activities and Applicable Requirements

Minn. R. 7007.1300,

subpart Rule Description of the Activity Applicable Requirement

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

• One QA laboratory

Minn. R. 7011.0510/0515; Minn. R. 7011.0610; Minn. R. 7011.0710/0715

3(I) Individual emissions units at a stationary source, each of which have a potential to emit the following pollutants in amounts less than:

1. 4,000 lbs/year of carbon monoxide; and

2. 2,000 lbs/year each of nitrogen oxide, sulfur dioxide, particulate matter, particulate matter less than ten microns, volatile organic compounds (including hazardous air pollutant-containing VOC), and ozone.

• One 250-amp natural gas fired emergency backup generator

Minn. R. 7011.2300

Technical Support Document, Permit Action Number: 03700020 - 002 Page 1 of 9 Date: 2/3/2004

TECHNICAL SUPPORT DOCUMENT For

AIR EMISSION PERMIT NO. 03700020-002 This technical support document is intended for all parties interested in the permit and to meet the requirements that have been set forth by the federal regulations and Minn. R. (40 CFR, Section 70.7(a)(5) and Minn. R. 7007.0850, subp.1). The purpose of this document is to provide the legal and factual justification for each applicable requirement or policy decision considered in the determination to issue the permit. 1. General Information 1.1. Applicant and Stationary Source Location:

Applicant/Address Stationary Source/Address (SIC Code: 2041)

ConAgra Flour Milling Company P.O. Box 3500

Omaha, NE 68103-0500

2005 South Vermillion Street Hastings, Dakota County, Minnesota

Contact:

Brandon Headlee (at facility address) Plant Manager (651)437-3161

1.2. Description Of The Facility ConAgra Flour Milling Company operates a wheat flour and animal feed mill in Hastings, Minnesota. The facility consists of hardwheat mills, durum mills, durum processing, a rye mill, and associated elevator, storage, and packaging areas. Seventy-five percent of the wheat received is processed into flour and the remaining 25% into feed. The facility operates a boiler for heating and wheat tempering during the winter months. Methyl bromide is used for fumigation. The facility had initially accepted (Permit-001) limits on the amount of wheat to be processed and on the amount of fumigant (methyl bromide) which may be used. These limits were federally enforceable, and resulted in the facility being a non-major source under the Part 70 permit program, New Source Review, and the National Emission Standards for Hazardous Air Pollutants (NESHAP) program. 1.3 Description of the Activities Allowed by this Permit Action

The Permittee requested this major amendment (-002) to allow for greater flexibility in operations. As a result, this amendment removes all three Particulate matter less than 10


microns (PM10) process throughput limits. The process throughput limits are replaced by an overall facility wide 95 tons per year (tpy) PM10 emission limit. The previous permit (-001) had a facility wide PTE PM10 emission of 95 tpy. Hence, there is no change in the PM10 Potential to Emit (PTE) or other pollutant emissions.

1.4 Description of all amendments issued since the issuance of the last total facility permit and to be included in the Part 70 Permit.

None.

1.5 Comments made during the Public Notice Period.

In response to the public comment period, the Minnesota Department of Health (MDH) made two comments on December 11, 2003. The first comment recommended that air monitoring be required at the facility property line to ensure that Health Risk Value (HRV) exceedances of methyl bromide do not occur. The HRV for methyl bromide is 2 mg/m3. It is noted that MDA regulates the use of methyl bromide in this application. MDA stated that levels must below 5 ppm, after 3 days, when an entrance (i.e., door) is opened or worker entering the building must appropriately “suit up.” Monitoring is required, under MDA authorities, for the 5 ppm threshold. The second comment requested that ambient modeling be done to determine that the PM10 NAAQS is not exceeded. The MDH expressed concern that the facility’s particulates may be allergens, making them more problematic than most dusts. It is noted that current MPCA policy is to not require PM10 ambient modeling for facilities with less than 100 tpy of actual PM10 emissions. These comments are attached. The MDH comments are related to issues that were not proposed to be modified during this comment period. Minnesota Rule 7001.0190, subp. 1. Accordingly, the MPCA will not be pursuing the MDH comments, as it relates to this amendment. The MPCA recommended to the Permittee, however, that it consider these issues in the long-term operation of its facility. 1.6 Facility Emissions: As a result of this amendment (-002), there are no changes in emissions from the previous permit (-001).

Table 1. Total Facility Potential to Emit Summary3:

PM tpy

PM10 tpy

SO2 tpy

NOX tpy

CO tpy

VOC tpy

Pb tpy

SingleHAP tpy

All HAPs

tpy Total Facility Limited Potential Emissions

189.6 95.0 30.2 8.4 4.7 10.1 Neg. 9.75 9.75

Total Facility Actual 167.9 83.6 0.55 1.89 1.48 0.10 Neg. NR 2 NR 2


Emissions 1 1 From the 2001 emission inventory 2 NR = Not Reported (HAP emissions are not reported in the annual emission inventory) 3 No change in emissions resulting from this amendment (-002)

Table 2. Facility and Permit Classification1

Classification Major/Affected Source *Synthetic Minor *Minor PSD PM, PM10 All others NAAR - not applicable Part 70 Permit Program PM10, HAPs All others * Refers to potential emissions that are less than those specified as major by 40 CFR 52.21, 40 CFR pt. 51 Appendix S, and 40 CFR pt. 70. 1 No change in classification resulting from this amendment (-002)


2. Regulatory and/or Statutory Basis

(The following section addresses the entire facility even though this major amendment (-002) only impacts PM10 emissions.)

Part 70 Permit Program

The facility has accepted federally enforceable emission limits, so that the source is permitted as a non-major source.

New Source Review

The facility is subject to a NSR threshold of 250 tons per year for criteria pollutants. The facility is located in an area that is considered attainment for all pollutants. The facility has accepted federally enforceable emission limits, and is permitted as a non-major source under New Source Review.

New Source Performance Standards (NSPS)

The facility operates a boiler that is subject to NSPS Subpart Dc.

National Emission Standards for Hazardous Air Pollutants (NESHAP)

There are no promulgated, proposed, or upcoming NESHAP or MACT standards that apply to this facility. Because the facility has the capability of emitting in excess of 10 tons per year of methyl bromide, it would be subject to the MACT Hammer; however, this permit limits HAP emissions to below the major source thresholds.

Minnesota Standards of Performance

Sources as the facility are subject to the following standards:

• Minn. R. 7011.0700 – 7011.0715 Standards of performance for pre- and post-1969 industrial process equipment.

• Minn. R. 7011.1000 – 7011.1015 Standards of performance for dry bulk agricultural commodity facilities.

• Minn. R. 7011.2300 Standards of performance for stationary internal combustion engines.

• Minn. R. 7011.0570 Incorporation of new source performance standard (NSPS Subpart Dc) by reference.

• Minn. R. 7011.0060 – 7011.0080 Control equipment rules.

Table 3. Regulatory Overview of Facility

EU, GP, or SV

Applicable Regulations

Comments:

EU001 40 CFR 60, Subpart Dc Minn. R. 7011.0570

Standards of Performance for Small Industrial-Commercial-Institutional Steam Generating Units


EU, GP, or SV

Applicable Regulations

Comments:

EU002 EU003 EU006 EU004 EU005 EU007

Minn. R. 7011.1000 – 7011.1015

Standards of performance for dry bulk agricultural commodity facilities

EU008 Minn. R. 7011.0700 – 7011.0715

Standards of performance for pre- and post-1969 industrial process equipment (The standards of performance for dry bulk agricultural commodity facilities do not apply to the pelletizing operation.)

FS001 Title I Limits on HAP emissions to avoid being a major HAP source

GP001 GP002

Minn. R. 7011.0060 – 7011.0080

Control Equipment Rule

CE030 Minn. Stat. 116.07, subd. 4 (Minn. R. 7019.3020(F))

Use of control equipment is not required to meet permit or rule limits. However, to count the control in the emission inventory, permit requirements must be met.

Total Facility

Title I Limits on facility PM10 emissions, to avoid being a major source under NSR (and Part 70).

3. Technical Information

(The following section addresses the entire facility even though this major amendment (-002) only impacts PM10 emissions.)

3.1 Calculations No calculations are attached. This is because the emission limit is based on four variable process parameters that will be recorded.

It is noted that the emissions from the boiler did not change from Permit -001. The boiler emissions were calculated using emission factors from AP-42 and the maximum capacity of the boiler. The boiler has a 0.96 tpy PTE. This 0.96 tpy PTE is included in the facility PM10 equation.

It is also noted that the actual hourly emission calculation methodology from the grain, feed, and flour operations did not change from Permit -001. The actual hourly emissions will still be calculated using the same emission factors from AP-42, the process throughput of the operation processes, and the control efficiency from Minn. R. 7011.0060-0080. It is noted there were no changes in the April 2003 AP-42 9.9.1 Grain Elevators and Processes revisions.


The PM10 annual emission will limit either/or all the grain, feed, milling, and flour operations, depending on facility choices.

The PM10 emission limit that is added in this amendment (-002) includes all the PM10 emissions from EU001 through EU008. This amendment also requires the daily recording of the milling (EU 004) process throughput in weight.

The development of the PM10 emission limit can be found in Attachment 1 to this document. 3.2 Insignificant Activities

The insignificant activities that are required to be listed are shown in Appendix B to the permit. There are no changes in the insignificant activities. 3.3 Periodic Monitoring In accordance with the Clean Air Act, it is the responsibility of the owner or operator of a facility to have sufficient knowledge of the facility to certify that the facility is in compliance with all applicable requirements.

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

• The likelihood of violating an applicable requirement;

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

• 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.

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

Table 4. Periodic Monitoring

EU/GP/CE Emission Limit (basis)

Additional Monitoring

Discussion

EU001 Fuel sulfur content (NSPS Subpart Dc)

Nothing beyond what is required by the standard

EU002

EU004 EU005

Title I Recordkeeping (Throughout)

Stack and fugitive Daily visible Baghouse collecting through a total


EU/GP/CE Emission Limit (basis)

Additional Monitoring

Discussion

opacity limits (Minn. Rules)

emission checks

Proper baghouse O&M

enclosure should result in 0% opacity

EU003, EU004 EU006, EU007

Stack and fugitive opacity limits (Minn. Rules)

Daily visible emission checks

Proper baghouse O&M

Baghouse collecting through a total enclosure should result in 0% opacity

EU008 PM and opacity limits (Minn. Rules)

Proper cyclone O&M

The limit at maximum capacity is 26.4 lb/hour, or 0.273 gr/dscf, from the stack. The maximum PTE is 9.0 lb/hour, including fugitive emissions which don’t reach the stack. Noncompliance is unlikely.

Title I Recordkeeping (Throughput)

EU002, EU005

Fugitive opacity limits (Minn. Rules)

Performance Test Since these are uncontrolled units, there is nothing to monitor. Rather than requesting a certified opacity observer be on-site, a performance test is being required. (This requirement is added in Permit-002.)

FS001 HAP limits (Title I) Recordkeeping

3.4 Permit Organization Deviations from “Normal” This permit does not change the permit organization from the previous permit (-001). 4. Conclusion

Based on the information provided by ConAgra Flour Milling Company, the MPCA has reasonable assurance that the proposed operation of the emission facility, as described in the Air Emission Permit No. 03700020-002 and this technical support document, will not cause or contribute to a violation of applicable federal regulations and Minnesota Rules. Staff Members on Permit Team: Bruce Braaten, Scott Parr, Toni Volkmeier (peer review)


Attachment: 1. Emission Calculation Equation Development 2. December 11, 2003 MDHealth Comment Letter


Attachment 1. Emission Calculation Equation Development

The following is the proposed calculation of facility-wide emissions based on four separate process recorded throughputs: E = Facility-wide PM10 emissions per 365-day period (tons/365-day rolling sum) (note: The proposed emission limit is E = 95.) R (EU002) = Grain Receiving Throughput (tons/365-day period) C (EU003) = Grain Cleaning Throughput (tons/365-day period) = R H (EU006) = Grain Handling Throughput (tons/365-day period) =2*R M (EU004) = Grain Milling Throughput (tons/365-day period) P (EU008) = Pellet Cooling Throughput (tons/365-day period) F (EU005) = Feed Loadout Throughput (tons/365-day period) S (EU007) = Flour Shipping Throughput (tons/365-day period) = 0.75*M Note: worst-case boiler emissions (EU001) are 0.96 ton/365-day period R (EU002)/Grain Receiving Emission Factor = 0.059 lb/ton C (EU003)/Grain Cleaning Emission Factor = 0.012 lb/ton H (EU006)/Grain Handling Emission Factor = 0.034 lb/ton M (EU004)/Grain Milling Emission Factor = 35.0 lb/ton P (EU008)/Pellet Cooling Emission Factor = 0.36 lb/ton F (EU005)/Feed Loadout Emission Factor = 0.0008 lb/ton S (EU007)/Flour Shipping Emission Factor = 0.049 lb/ton E = R*0.059/2000*0.01 + C*0.012/2000*0.01 + H*0.034/2000*0.01 + M*35/2000*0.01 + P*0.36/2000*0.25 + F*0.0008/2000*0.208 + S*0.049/2000*0.01 + 0.96 Simplifying: E = R*[0.059/2000*0.01 + 0.012/2000*0.01 + 2*0.034/2000*0.01] + M*[35/2000*0.01 +0.75*0.049/2000*0.01]+ P*0.36/2000*0.25 + F*0.0008/2000*0.208 + 0.96 E = R* 0.000000695 + M* 0.000175184+ P* 0.000045 + F* 0.0000000832 + 0.96

Documents

AIR EMISSION PERMIT NO. 03700020-002 IS ISSUED TO ConAgra ... · ConAgra Flour Milling Company operates a wheat flour and animal feed mill in Hastings, Minnesota. The facility consists