TECHNICAL SUPPORT DOCUMENT
For
AIR EMISSION PERMIT NO. 03700070-007

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: 2077)	
Sanimax USA, LLC
PO Box 10067
Green Bay, WI 54307	Sanimax USA, LLC
505 Hardman Ave S
South St. Paul
Dakota County, Minnesota 55075	
Contact: Ben Bertram
Phone: (920)494-0418 x1230
E-mail address: ben.bertram@sanimax.com	
1.2	Facility Description
Sanimax USA, LLC (“Sanimax”) recycles animal, vegetable, and food processing residues. The products manufactured from these recycled materials are primarily used by the animal feed manufacturing and chemical industries. The principle products processed at Sanimax’s manufacturing facility are beef, poultry and pork by-products, animal and vegetable oils and a variety of other residues from food processing, meat processing, and livestock industries.
This permit action addresses two existing boilers, a dryer, two pneumatic conveyance systems, two storage silos, a continuous milling system, two continuous cookers and a protein recovery facility. This permit would also allow the installation and operation of a new boiler and require the removal of one of the existing boilers. All other emission units qualify as insignificant activities under Minn. R. 7007.1300, subps. 2, 3 and 4.
Prior to the current permit action (Air Emission Permit No. 03700070-007), this existing source was a major source under federal Operating Program (40 CFR pt. 70). That changes with this permit action, which limits the facility’s emissions so that it is classified as a minor stationary source under federal New Source Review regulations (40 CFR § 52.21), as well as a nonmajor source under Minnesota’s operating permit program (Minn. R. ch. 7007, approved by the Environmental Protection Agency (EPA) as the state’s “Part 70” or “Title V” permitting program) and under the National Emissions Standards for Hazardous Air Pollutants (NESHAPs, 40 CFR pt. 63).
Sanimax's plant is composed of four distinctly separate operations: 
•	Animal matter recycling (rendering); 
•	Blood processing; 
•	Protein recovery facility (high protein meal production); and 
•	Vegetable oils and animal fats processing. 
The emission units and operations are described in the following paragraphs. 
a.	Boilers
Boiler No. 1 (EQUI 19), the main boiler, is a Nebraska boiler with rated heat input 51 million Btu per hour. It is capable of burning natural gas as the primary fuel and refined animal fats and vegetable oils (RAFVO), glycerin, and No. 2 distillate fuel oil as backup fuels. It was installed in 1979. Sanimax plans to retire this unit after the installation of Boiler No. 3.
Boiler No. 2 (EQUI 5) is a Johnston 509A boiler with maximum rated heat input of 17.58 million Btu per hour while fired with natural gas and 16.24 million Btu per hour while fired with No. 2 distillate fuel oil. It is also capable of burning glycerin and RAFVO. Boiler No. 2 was installed in 1994. 
The installation of Boiler No. 3 (EQUI 10) will be authorized by the current permit action (Air Emission Permit No. 03700070-007). Boiler No. 3 is a new, permanent 98 million British thermal unit per hour (MMBtu/hr) boiler capable of burning natural gas, No. 2 diesel fuel, glycerin and RAFVO. 
b.	Animal Waste Recycling (Rendering)
There are three steps in the animal waste recycling, or rendering, process: raw material receiving, cooking and pressing, and the continuous milling system.
Raw Material Receiving
Raw materials are deposited in the receiving and handling area. Two grinding and pumping lines feed the continuous cooker operations. Equipment associated with the material receiving and transfer includes conveyors, a grinder, an electromagnet and a surge bin. 
Cooking and Pressing
In the steam heated continuous cooking vessels (EQUI 16 and EQUI 17), water is evaporated and the temperature of the material is raised to approximately 250-270 degrees F. Water vapor is routed to an air condenser. The cookers are unloaded into a perc-pan where the free fat is allowed to drain out through perforations. Cooked material is then transferred across a mechanical device to an area that separates fatty liquids from protein solids. Liquid fat is pumped across a screen where residual solids are removed. Liquid fat from the cooker and the presses are pumped through a centrifuge where the remaining solids are removed. The fat is pumped to storage tanks for loading into railroad cars or tanker trucks for delivery.
Continuous Milling System
Solids are transferred to a surge bin and then to a continuous hammer milling system (EQUI 3) where the particle size is further reduced. Ground protein solids are conveyed across a screen and conditioner to meet specific customer requirements before being conveyed to storage silos.
c.	Blood Processing
Sanimax unloads blood from tank trucks into storage tanks. It then coagulates the blood with steam and centrifuges it before conveying it into the blood/ring dryer (EQUI 4). There the blood is dried. The blood/ring dryer burns natural gas with No. 2 distillate fuel oil as a back-up, has a maximum rated heat input of 5.00 million Btu per hour while firing either fuel, and was installed in 1982. The dried blood meal is transferred using one of a conveyance system (EQUI 21) to the finished product storage vessels. 
d.	Protein Recovery Facility
Raw materials for the protein recovery facility (EQUI 20) are delivered in vehicles designed for the purpose. The vehicles unload the raw materials into a receiving vessel or area designed for the materials. The high protein raw feed is conveyed through a magnetic separator and size reduction system into steam jacketed cookers where it remains until it reaches proper temperature. The material is conveyed to a dryer where final moisture reduction takes place before the material is milled, screened and transferred using a conveyance system (EQUI 18) to finished product storage vessels (EQUI 1 and EQUI 2) for shipment.
Water evaporated in the cooking process and drying vessels is condensed in a condenser. Condensate is sewered and noncondensable gases pass through a multi-stage system designed to oxidize the odors before release to the atmosphere. The receiving and process space are ventilated with a single stage system also designed to oxidize any odors before release to the atmosphere. Steam from one of the boilers is the heat source for the cooking and drying cycles.
e.	Vegetable Oil Recovery
Sanimax heats waste grease from area restaurants in two 3250-gallon mixing tanks for 24 to 48 hours, until the materials are properly homogenized. Impurities in the product settle to the bottom of the tank where they are then drawn off for further processing. Purified liquid is drawn from the top of the tank into storage tanks. 
During the raw material heating period, any gases vented from the tank are released into the room air and drawn through the room air scrubber. Since the vapor pressure of the raw material at elevated temperature remains low (0.001 mmHg at 480 degrees F and 0.05 mmHg at 585 degrees F), the process emits only very small amounts of volatile organic compounds (VOCs). For this reason, vegetable oil recovery qualifies as an insignificant activity under Minn. R. 7007.1300, subp. 4.
This permit action is a reissuance and a conversion from a Part 70 permit to a state permit. 
1.3	Description of the Activities Allowed by this Permit Action
This permit action (Air Emission Permit No. 03700070-007):
1.	Renews the total facility permit for the stationary source and converts the facility’s operating permit to a federally-enforceable state operating permit (commonly referred to as a state permit) from its previous Part 70 permit; 
2.	Authorizes physical changes to the facility (a minor source under the Prevention of Significant Deterioration (PSD) regulation) requested in an application for a major permit amendment; 
3.	Changes the name of the facility as requested in an application for an administrative amendment; 
4.	Migrates the permit conditions into Tempo (the MPCA’s new permitting database) from Delta (the previous database); and
5.	Makes updates, corrections, and other changes.
a.	Total facility permit
The expiration date of Sanimax’s current permit was July 18, 2013. Since then, however, the MPCA received a permit application for the reissuance of a Part 70 permit on January 18, 2013 (six months prior to the expiration of the operating permit), the permit remains effective until the MPCA issues this new total facility permit (Air Emission Permit No. 03700070-007). 
Sanimax proposes to accept limits on the sulfur content in the liquid fuels that it burns. This necessitates the elimination of No. 6 fuel oil at the facility. With the limit on fuel sulfur, the facility’s potential to emit sulfur dioxide (SO2) drops below 100 tons per year (tpy). This was the only pollutant with emissions exceeding the Part 70 permit threshold of 100 tpy. Because they are no longer required to hold a Part 70 permit, the facility also requested that its total facility permit be a state permit. With this permit action, the MPCA grants that request.
b.	Major amendment
The MPCA received a permit application for a major amendment from Sanimax on May 7, 2013. The MPCA received additional information throughout the permitting process, including a supplemental application received by the MPCA on September 14, 2013 and information received by the MPCA on February 3, 2015.
In this application (as revised), Sanimax proposed to:
•	Install a new, permanent 98 million British thermal unit per hour (MMBtu/hr) boiler (Boiler No. 3; EQUI 10/STRU 16) capable of burning natural gas, No. 2 diesel fuel, and RAFVO;
•	Remove existing Boiler No. 1 (EQUI 19/STRU 14, formerly identified as EU 001/SV 001) following installation and initial operation of Boiler No. 3 (EQUI 10);
•	Discontinue the use of No. 6 fuel oil throughout the facility; 
•	Add sulfur limits on liquid fuels (sulfur limits of 0.05 percent by weight in distillate fuel and of 0.10 percent by weight sulfur in RAFVO and glycerin);
•	Remove the facility-wide SO2 emission limit (following the elimination of No. 6 fuel oil and the addition of sulfur limits on liquid fuels, it is no longer needed to keep the facility below the PSD major source threshold);
•	Expand the operating pressure drop ranges for their Venturi scrubbers; and
•	Update emission limits for emission units EQUI 4 (EU 002) and EQUI 5 (EU 006).
This permit reflects these proposed changes. 
c.	Administrative amendment
This amendment also changes the facility and corporate operator name from Sanimax USA Inc. to Sanimax USA, LLC. This change was requested in an application for an administrative amendment dated February 6, 2015.
d.	Migration to Tempo
The MPCA has used the Delta database for nearly two decades. In October 2015, the MPCA moved the data from Delta into its new permitting database, Tempo. 
Sanimax and others reviewing the permit will notice a number of changes to the permit from the migration to Tempo. The identification of the units has changed. (See section 3.9 for more information.) In addition, the permits issued from the new database are formatted differently. 
e.	Other changes
The following changes were made to the Facility Description in Tempo:
•	Added Buildings and structure information for all buildings;
•	Updated parameters for STRU 14 (SV 001), STRU 19 (SV 005), and STRU 20 (SV 014);
•	Removed SV 007 (previously removed);
•	Removed SV 019 (never built);
•	Updated information for TREA 30 (CE 025);
•	Updated information for EQUI 8 (EU 021), and EQUI 9 (EU 022), and EQUI 066 (EU 020);
•	Changed control equipment descriptions for TREA 26 (CE 001), TREA 27 (CE 003), and TREA 28 (CE 012); and
•	Added STRU 16 and EQUI 10 for Boiler No. 3.
1.4	Description of Notifications and Applications Included in this Action
Date Received	Application/Notification Type and Description	
January 18, 2013	Part 70 permit reissuance	
May 7, 2013	Major amendment – installation of new boiler	
February 18, 2015	Administrative amendment – name change	
1.5	Facility Emissions:
The existing facility is not a major stationary source under the PSD regulation. To determine PSD applicability, increases in the annual emissions of PSD pollutants are compared to the major stationary source threshold as shown in Table 2.

Table 2. Title I Emissions Summary (for the installation of EQUI 10)
Pollutant	Unlimited Potential Emissions from the Modification
(tpy)	NSR/112(g) Threshold for New Major Source (tpy)	NSR/112(g) Review Required?
(Yes/No)	
PM	16.9	250	No	
PM10	10.4	250	No	
PM2.5	5.6	250	No	
NOX	44.0	250	No	
SO2	53.7	250	No	
CO	35.3	250	No	
Ozone (VOC)	3.8	250	No	
Lead	0.0002	250	No	
CO2e*	77,600	Not applicable**	No	
Total HAPs	0.80	25	No	
Individual HAP (hexane)	0.76	10	No	
*Carbon dioxide equivalents as defined in Minn. R. 7007.0100.
** When another pollutant is subject to PSD, the PSD threshold for CO2e is 75,000 tpy. However, when no other pollutant exceeds its PSD threshold, a CO2e emissions increase (even above 75,000 tpy) does not trigger a PSD analysis.

Table 3. Total Facility Potential to Emit Summary
	PM
tpy	PM10
tpy	PM2.5
tpy	SO2
tpy	NOx
tpy	CO
tpy	VOC
tpy	CO2e
tpy	Single
HAP
tpy	All
HAPs
tpy	
Total Facility Limited Potential Emissions (per Air Emission Permit 03700070-006)	58	50	32	240	96	27	13	55,000	0.57	0.60	
Total Facility Limited Potential Emissions, post-modification	50	40	24	64	61	43	25	95,000	0.93	0.98	
Total Facility Actual Emissions (2014)	3.0	13.3	10.4	0.1	18.9	15.9	1.7	*	*	
* Not reported in MN emission inventory.

Table 4. Facility Classification
Classification	Major/Affected Source	Synthetic Minor/Area	Minor/Area	
PSD 		X		
Part 70 Permit Program		X		
Part 63 NESHAP		X		
2.	Regulatory and/or Statutory Basis
The following discussion applies only to the proposed changes, not to the entire facility.
New Source Review
Sanimax’s facility is subject to the PSD major stationary source threshold of 250 tons per year of any regulated New Source Review (NSR) pollutant  since it is not one of the types of stationary sources listed in 40 CFR § 52.21(b)(1)(i)(a). Prior to the proposed modification, Sanimax was a minor PSD stationary source because Air Emission Permit No. 03700070-006 included a restriction on emissions of sulfur dioxide (SO2) that limited facility-wide emissions to 240 tons per year and the facility’s potential to emit other NSR pollutants was below the 250 tpy threshold.
The emissions of NSR pollutants from the proposed new Boiler No. 3 (EQUI 10) are below the 250 tpy threshold, so this physical change does not trigger PSD review. In addition, Air Emission Permit No. 03700070-007 prohibits the use of No. 6 (residual) fuel oil at the facility and restricts the sulfur concentration of No. 2 fuel oil to 0.05 percent by weight and the sulfur concentration of other fuels to 0.10 percent by weight. (The permit contains Title I Conditions with these restrictions.) These conditions effectively limit facility-wide SO2 emissions, so the previous facility-wide SO2 limit was removed.
Part 70 Permit Program
Prior to permit action -007, the facility’s allowable emissions exceeded 100 tpy of SO2, so the stationary source required a Part 70 permit program. Following this permit action, the facility’s allowable emissions of air pollutants subject to regulation will not exceed 100 tpy; after permit issuance, the existing facility will hold a state-only operating permit.
New Source Performance Standards (NSPS)
The effective date of the federal Standards of Performance for Small Industrial-Commercial-Institutional Steam Generating Units (40 CFR 60 Subpart Dc) is June 9, 1989. Construction of Boiler No. 1 (EQUI 19) began in 1978, prior to the effective date, so Subpart Dc does not apply to it. 
Construction of Boiler No. 2 (EQUI 5) began in 1994. It is subject to an SO2 limit under this NSPS, but not a particulate or opacity limit because Boiler No. 2’s heat input is less than 30 MMBtu/hr. 
Boiler No. 3 (EQUI 10) will be subject to Subpart Dc, as construction on this unit will begin after June 9, 1989. Because Sanimax accepted a limit on the fuel sulfur content of its liquid fuels below 0.50 weight percent, Subpart Dc’s PM limit does not apply to Boiler No. 3.
The heat input for all of the boilers is below 100 MMBtu/hr, so none of the boilers is subject to the other New Source Performance Standards for Boilers (Subparts D, Da, or Db).
National Emission Standards for Hazardous Air Pollutants (NESHAP)
Sanimax is an area source of Hazardous Air Pollutants (HAPs), as the potential of this facility to emit any individual Hazardous Air Pollutant (HAP) is below 10 tpy and its potential to emit total HAPs is below 25 tpy. No major source NESHAPs apply.
The boilers at Sanimax are potentially subject to the National Emission Standards for Hazardous Air Pollutants for Industrial, Commercial, and Institutional Boilers Area Sources (40 CFR 63 Subpart JJJJJJ). However, this area source NESHAP does not apply at this time because the existing boilers, Boiler No. 1 and Boiler No. 2, are currently operated as gas-fired units.,  (The existing boilers may have burned liquid fuel only during periods of gas curtailment, gas supply interruptions, or startup, or during periodic testing.) If these emission units no longer meet the definition of gas-fired units, they become existing affected sources subject to the requirements of the oil subcategory and must meet the requirements of the NESHAP, including:
•	Submitting a notification of fuel switch;
•	Providing an initial notification;
•	Conducting an energy assessment and/or tune-up; and 
•	Submitting the Notification of Compliance Status.
Sanimax also plans to initially operate its new 98 million Btu per hour boiler, Boiler No. 3, as a gas-fired boiler. However, because the construction of the No. 3 Boiler will start after June 4, 2010, it will become subject to the requirements of the oil subcategory as a new affected source.
Compliance Assurance Monitoring (CAM)
CAM does not apply to the modification allowed in this permit amendment, since the emission unit added is not a large pollutant specific emission unit (PSEU) or other PSEU.
Environmental Review & Air Emissions Risk Analysis (AERA)
The proposed installation of Boiler No. 3 does not fall into any of the mandatory categories for Environmental Review, nor do emissions from the proposed Boiler No. 3 project exceed 250 tons per year. Therefore, the modification does not trigger the requirements for an Environmental Assessment Worksheet (EAW).
Minnesota State Rules
Because Boiler No. 1 (EQUI 19) was constructed before the effective date of 40 CFR 60 Subp. Dc but after January 31, 1977, it must meet the particulate, opacity, and sulfur dioxide provisions for new indirect heating equipment subject to the Standards of Performance for Indirect Heating Fossil-Fuel-Burning Equipment (Minn. R. 7011.0500-7011.0550).
The Ring/Blood Dryer/Oven (EQUI 4) is subject to the particulate, opacity, and sulfur dioxide provisions of the Standards of Performance for Fossil-Fuel-Burning Direct Heating Equipment (Minn. R. 7011.0600-7011.0620) because construction of EQUI 4 commenced after January 31, 1977 and no federal standards of performance apply to the unit. 
Several emission units (EQUI 1, EQUI 2, EQUI 3, EQUI 8, EQUI 9, EQUI 16, EQUI 17, EQUI 18, EQUI 20, EQUI 21, and EQUI 66) are subject to the particulate matter and opacity standards of the Industrial Process Equipment rule (Minn. R. 7011.0700-7011.0735).
No Minnesota Standards of Performance apply to the proposed Boiler No. 3 project. 
Table 5. Regulatory Overview of Facility
Subject Item*	Applicable Regulations	Rationale	
FC	Minn. Stat. Section 116.07, subds. 4a & 9; Minn. R. 7007.0100, subp. 7(A), 7(L), & 7(M); Minn. R. 7007.0800, subps. 1, 2 & 4; Minn. R. 7009.0010-7009.0080	Modeling requirements: Refined modeling submitted in November 2010 for PM10 and PM2.5 in support of Air Emission Permit No, 03700070-006 showed that Sanimax was at ~70 percent of the 24-hour PM10 NAAQS and at 98 percent of the 24-hour PM2.5 NAAQS. The proximity of this modeled ambient concentration to the PM2.5 NAAQS indicates that changes to the facility – even those allowed by minor amendments – may threaten modeled compliance, so the permit requires a modeling demonstration for even small changes to provide assurance that the NAAQS are protected. 
The 2010 modeling provided the baseline for “Equivalent or Better Dispersion” (EBD) comparisons for permit action 03700070-007. EBD modeling submitted for PM2.5 in May 2015 indicated that the modification authorized in Air Emission Permit 03700070-007 does not cause a modeled exceedance of the PM2.5 NAAQS. Future changes to PM2.5 emission rates and stack parameters will be compared to the values in the 2015 EBD modeling to determine if a modeling demonstration is needed for the proposed (future) change.	
COMG 7
(EQUI 3, EQUI 16, EQUI 17, STRU 24, TREA 28)	Title I Condition: To avoid classification as a major source under 40 CFR Section 52.21 and Minn. R. 7007.3000; 
Title I Condition: To avoid major source classification under 40 CFR Section 70.2 and Minn. R. 7007.0200	The facility is required to operate the Venturi scrubber (TREA 28) to control particulate (PM, PM10, and PM2.5) emissions from EQUI 3, EQUI 16, and EQUI 17. 
These particulate matter emission limits rely on the effective operation of the control equipment and provide assurance that the entire facility is a minor stationary source under the PSD regulation and a nonmajor source under the operating permits program (40 CFR Part 70, Minn. R. ch. 7007).	
	Minn. Stat. Section 116.07, subds. 4a & 9; Minn. R. 7007.0100, subp. 7(A), 7(L), & 7(M); Minn. R. 7007.0800, subps. 1, 2 & 4; Minn. R. 7009.0010-7009.0080	The facility accepted PM10 and PM2.5 limits that reflect the potential to emit of EQUI 3, EQUI 16, and EQUI 17 (after control). These limits were included in the demonstration of modeled compliance with the PM10 and PM2.5 NAAQS.	
EQUI 1 STRU 26 TREA 32
Protein Silo/Bin No. 1	Title I Condition: To avoid classification as a major source under 40 CFR Section 52.21 and Minn. R. 7007.3000 
Title I Condition: To avoid major source classification under 40 CFR Section 70.2 and Minn. R. 7007.0200	The permit restricts the PM10 emissions from this unit and other units at the facility. The combination of these limitations keeps the facility PM10 emissions below the PSD major source threshold and below the Part 70 major source threshold.	
	Minn. Stat. Section 116.07, subds. 4a & 9; Minn. R. 7007.0100, subp. 7(A), 7(L), & 7(M); Minn. R. 7007.0800, subps. 1, 2 & 4; Minn. R. 7009.0010-7009.0080	Emissions of PM10 for this unit are limited to the value modeled for Air Emission Permit No. 03700070-006. This limit and other PM10 permit limits allow the facility to demonstrate compliance with the PM10 NAAQS. 	
	Title I Condition: To avoid classification as a major source under 40 CFR Section 52.21 and Minn. R. 7007.3000 
Title I Condition: To avoid major source classification under 40 CFR Section 70.2 and Minn. R. 7007.0200	The permit restricts the PM2.5 emissions from this unit and other units at the facility. The combination of these limitations keeps the facility PM2.5 emissions below the PSD major source threshold and below the Part 70 major source threshold.	
	Minn. Stat. Section 116.07, subds. 4a & 9; Minn. R. 7007.0100, subp. 7(A), 7(L), & 7(M); Minn. R. 7007.0800, subps. 1, 2 & 4; Minn. R. 7009.0010-7009.0080	Emissions of PM2.5 for this unit are limited to the value modeled in the “Equivalent or Better Determination” (EBD) analysis for Air Emission Permit No. 03700070-007. This limit and other PM2.5 permit limits allow the facility to demonstrate compliance with the PM2.5 NAAQS.	
	Title I Condition: To avoid classification as a major source and modification under 40 CFR Section 52.21 and Minn. R. 7007.3000
Title I Condition: To avoid major source classification under 40 CFR Section 70.2 and Minn. R. 7007.0200	The facility accepted limits on particulate (PM, PM10, and PM2.5) emissions so the entire facility is a minor stationary source under the PSD regulation and a nonmajor source under the operating permits program (40 CFR Part 70, Minn. R. ch. 7007). Particulate emissions from Protein Silo/Bin No. 1 must be controlled to meet these limits, so emissions from Protein Silo/Bin No. 1 must be vented to TREA 32, a fabric filter, whenever Protein Silo/Bin No. 1 operates.	
	Minn. Stat. Section 116.07, subds. 4a & 9; Minn. R. 7007.0100, subp. 7(A) & 7(M); Minn. R. 7007.0800, subps. 1, 2 & 4; Minn. R. 7009.0010-7009.0080	Air Emission Permit No. 578- 93-I/O-1 established a limit on Total Suspended Particulate (TSP) based on modeling performed at the time. Since PM10 replaced TSP as a criteria pollutant, the TSP is now a state-only limit.	
	Minn. R. 7011.0715, subp. 1	Since operation of Protein Silo/Bin No. 1 began in 1994 (after July 9, 1969) and the unit is industrial process equipment as defined in Minn. R. 7011.0700, subp. 3, it is subject to the state standards of performance for industrial process equipment. These include standards for particulate matter and opacity.	
EQUI 2 STRU 27 TREA 33 
Protein Silo/Bin No. 2	Title I Condition: To avoid classification as a major source under 40 CFR Section 52.21 and Minn. R. 7007.3000 
Title I Condition: To avoid major source classification under 40 CFR Section 70.2 and Minn. R. 7007.0200	The permit restricts the PM10 emissions from this unit and other units at the facility. The combination of these limitations keeps the facility PM10 emissions below the PSD major source threshold and below the Part 70 major source threshold.	
	Minn. Stat. Section 116.07, subds. 4a & 9; Minn. R. 7007.0100, subp. 7(A), 7(L), & 7(M); Minn. R. 7007.0800, subps. 1, 2 & 4; Minn. R. 7009.0010-7009.0080	Emissions of PM10 for this unit are limited to the value modeled for Air Emission Permit No. 03700070-006. This limit and other PM10 permit limits allow the facility to demonstrate compliance with the PM10 NAAQS. 	
	Title I Condition: To avoid classification as a major source under 40 CFR Section 52.21 and Minn. R. 7007.3000 
Title I Condition: To avoid major source classification under 40 CFR Section 70.2 and Minn. R. 7007.0200	The permit restricts the PM2.5 emissions from this unit and other units at the facility. The combination of these limitations keeps the facility PM2.5 emissions below the PSD major source threshold and below the Part 70 major source threshold.	
	Minn. Stat. Section 116.07, subds. 4a & 9; Minn. R. 7007.0100, subp. 7(A), 7(L), & 7(M); Minn. R. 7007.0800, subps. 1, 2 & 4; Minn. R. 7009.0010-7009.0080	Emissions of PM2.5 for this unit are limited to the value modeled in the “Equivalent or Better Determination” (EBD) analysis for Air Emission Permit No. 03700070-007. This limit and other PM2.5 permit limits allow the facility to demonstrate compliance with the PM2.5 NAAQS.	
	Title I Condition: To avoid classification as a major source and modification under 40 CFR Section 52.21 and Minn. R. 7007.3000
Title I Condition: To avoid major source classification under 40 CFR Section 70.2 and Minn. R. 7007.0200	The facility accepted limits on particulate (PM, PM10, and PM2.5) emissions so the entire facility is a minor stationary source under the PSD regulation and a nonmajor source under the operating permits program (40 CFR Part 70, Minn. R. ch. 7007). Particulate emissions from Protein Silo/Bin No. 2 must be controlled to meet these limits, so emissions from Protein Silo/Bin No. 2 must be vented to TREA 33, a fabric filter, whenever Protein Silo/Bin No. 2 operates.	
	Minn. Stat. Section 116.07, subds. 4a & 9; Minn. R. 7007.0100, subp. 7(A) & 7(M); Minn. R. 7007.0800, subps. 1, 2 & 4; Minn. R. 7009.0010-7009.0080	Air Emission Permit No. 578- 93-I/O-1 established a limit on Total Suspended Particulate (TSP) based on modeling performed at the time. Since PM10 replaced TSP as a criteria pollutant, the TSP is now a state-only limit.	
	Minn. R. 7011.0715, subp. 1	Since operation of Protein Silo/Bin No. 2 began in 1994 (after July 9, 1969) and the unit is industrial process equipment as defined in Minn. R. 7011.0700, subp. 3, it is subject to the state standards of performance for industrial process equipment. These include standards for particulate matter and opacity.	
EQUI 3 STRU 24 TREA 29 [COMG 7]
Continuous Milling Equipment	Title I Condition: To avoid classification as a major source under 40 CFR Section 52.21 and Minn. R. 7007.3000 
Title I Condition: To avoid major source classification under 40 CFR Section 70.2 and Minn. R. 7007.0200	The permit restricts the PM10 emissions from this unit and other units at the facility. The combination of these limitations keeps the facility PM10 emissions below the PSD major source threshold and below the Part 70 major source threshold.	
	Minn. Stat. Section 116.07, subds. 4a & 9; Minn. R. 7007.0100, subp. 7(A), 7(L), & 7(M); Minn. R. 7007.0800, subps. 1, 2 & 4; Minn. R. 7009.0010-7009.0080	Emissions of PM10 for this unit are limited to the value modeled for Air Emission Permit No. 03700070-006. This limit and other PM10 permit limits allow the facility to demonstrate compliance with the PM10 NAAQS. 	
	Title I Condition: To avoid classification as a major source under 40 CFR Section 52.21 and Minn. R. 7007.3000 
Title I Condition: To avoid major source classification under 40 CFR Section 70.2 and Minn. R. 7007.0200	The permit restricts the PM2.5 emissions from this unit and other units at the facility. The combination of these limitations keeps the facility PM2.5 emissions below the PSD major source threshold and below the Part 70 major source threshold.	
	Minn. Stat. Section 116.07, subds. 4a & 9; Minn. R. 7007.0100, subp. 7(A), 7(L), & 7(M); Minn. R. 7007.0800, subps. 1, 2 & 4; Minn. R. 7009.0010-7009.0080	Emissions of PM2.5 for this unit are limited to the value modeled in the “Equivalent or Better Determination” (EBD) analysis for Air Emission Permit No. 03700070-007. This limit and other PM2.5 permit limits allow the facility to demonstrate compliance with the PM2.5 NAAQS.	
	Title I Condition: To avoid classification as a major modification under 40 CFR Section 52.21	A PSD permit established a limit on Total Suspended Particulate (TSP). Although TSP has been replaced by PM10 as a criteria pollutant at the federal level, the state of Minnesota retains an ambient air quality standard for TSP. (See Minn. R. 7009.0080, “Particulate Matter.”)	
	Minn. R. 7011.0715, subp. 1	Since operation of the Continuous Milling Equipment began in 2002 (after July 9, 1969) and the unit is industrial process equipment as defined in Minn. R. 7011.0700, subp. 3, it is subject to the state standards of performance for industrial process equipment. These include standards for particulate matter and opacity.	
	Title I Condition: To avoid classification as a major source under 40 CFR Section 52.21 and Minn. R. 7007.3000; 
Title I Condition: To avoid major source classification under 40 CFR Section 70.2 and Minn. R. 7007.0200	The facility is required to operate the particulate capture unit to control particulate (PM, PM10, and PM2.5) emissions from EQUI 3. The facility accepted particulate matter limits that require the effective operation of this control equipment so the entire facility is a minor stationary source under the PSD regulation and a nonmajor source under the operating permits program (40 CFR Part 70, Minn. R. ch. 7007).	
EQUI 4 STRU 21 TREA 26 
Ring/Blood Dryer/ Oven	Title I Condition: To avoid classification as a major source under 40 CFR Section 52.21 and Minn. R. 7007.3000 
Title I Condition: To avoid major source classification under 40 CFR Section 70.2 and Minn. R. 7007.0200	The permit restricts the PM10 emissions from this unit and other units at the facility. The combination of these limitations keeps the facility PM10 emissions below the PSD major source threshold and below the Part 70 major source threshold.	
	Minn. Stat. Section 116.07, subds. 4a & 9; Minn. R. 7007.0100, subp. 7(A), 7(L), & 7(M); Minn. R. 7007.0800, subps. 1, 2 & 4; Minn. R. 7009.0010-7009.0080	Emissions of PM10 for this unit are limited to the value modeled for Air Emission Permit No. 03700070-006. This limit and other PM10 permit limits allow the facility to demonstrate compliance with the PM10 NAAQS. 	
	Title I Condition: To avoid classification as a major source under 40 CFR Section 52.21 and Minn. R. 7007.3000 
Title I Condition: To avoid major source classification under 40 CFR Section 70.2 and Minn. R. 7007.0200	The permit restricts the PM2.5 emissions from this unit and other units at the facility. The combination of these limitations keeps the facility PM2.5 emissions below the PSD major source threshold and below the Part 70 major source threshold.	
	Minn. Stat. Section 116.07, subds. 4a & 9; Minn. R. 7007.0100, subp. 7(A), 7(L), & 7(M); Minn. R. 7007.0800, subps. 1, 2 & 4; Minn. R. 7009.0010-7009.0080	Emissions of PM2.5 for this unit are limited to the value modeled in the “Equivalent or Better Determination” (EBD) analysis for Air Emission Permit No. 03700070-007. This limit and other PM2.5 permit limits allow the facility to demonstrate compliance with the PM2.5 NAAQS.	
	Title I Condition: To avoid classification as a major source and modification under 40 CFR Section 52.21 and Minn. R. 7007.3000
Title I Condition: To avoid major source classification under 40 CFR Section 70.2 and Minn. R. 7007.0200	The facility accepted limits on particulate (PM, PM10, and PM2.5) emissions so the entire facility is a minor stationary source under the PSD regulation and a nonmajor source under the operating permits program (40 CFR Part 70, Minn. R. ch. 7007). Particulate emissions from the ring/blood dryer/oven must be controlled to meet these limits, so emissions from the ring/blood dryer/oven must be vented to TREA 26, a Venturi scrubber, whenever the ring/blood dryer/oven operates.	
	Title I Condition: To avoid classification as a major source under 40 CFR Section 52.21 and Minn. R. 7007.3000 
Title I Condition: To avoid major source classification under 40 CFR Section 70.2 and Minn. R. 7007.0200	The permit restricts the sulfur content of No. 2 (distillate) fuel oil to 0.05 percent by weight and the sulfur content of other fuels to 0.10 percent by weight at all combustion units. This combination of these limitations keeps the facility’s SO2 emissions below the PSD major source threshold and below the Part 70 major source threshold.	
	Minn. R. 7011.0610	Since the Ring/Blood Dryer/Oven is capable and authorized to burn fossil fuels (natural gas and distillate fuel oil), it is subject to the state standards of performance for fossil-fuel-burning direct heating equipment. The facility is located within the Minneapolis-Saint Paul air Quality Control Region and the total rated heat input of all indirect and direct heating equipment at this location is less than 250 million Btu per hour. 
The unit is subject to standards for particulate matter, SO2, and opacity.	
	Minn. R. 7017.2020, subp. 1	The PM10 emission factor used by Sanimax for calculating the potential to emit and actual emissions from the Ring/Blood Dryer/Oven combines two emission factors from AP-42. The proximity of the modeled ambient air quality concentration to the PM2.5 National Ambient Air Quality Standard indicates that a performance test is needed to confirm the PM10 emission rate.	
	Minn. R. 7017.2020, subp. 1	The PM2.5 emission factor used by Sanimax for calculating the potential to emit and actual emissions from the Ring/Blood Dryer/Oven combines two emission factors from AP-42. The proximity of the modeled ambient air quality concentration to the PM2.5 National Ambient Air Quality Standard indicates that a performance test is needed to confirm the PM2.5 emission rate.	
EQUI 5 STRU 25
Boiler No. 2	Title I Condition: To avoid classification as a major source under 40 CFR Section 52.21 and Minn. R. 7007.3000 
Title I Condition: To avoid major source classification under 40 CFR Section 70.2 and Minn. R. 7007.0200	The permit restricts the PM10 emissions from this unit and other units at the facility. The combination of these limitations keeps the facility PM10 emissions below the PSD major source threshold and below the Part 70 major source threshold.	
	Minn. Stat. Section 116.07, subds. 4a & 9; Minn. R. 7007.0100, subp. 7(A), 7(L), & 7(M); Minn. R. 7007.0800, subps. 1, 2 & 4; Minn. R. 7009.0010-7009.0080	Emissions of PM10 for this unit are limited to the value modeled for Air Emission Permit No. 03700070-006. This limit and other PM10 permit limits allow the facility to demonstrate compliance with the PM10 NAAQS. 	
	Title I Condition: To avoid classification as a major source under 40 CFR Section 52.21 and Minn. R. 7007.3000 
Title I Condition: To avoid major source classification under 40 CFR Section 70.2 and Minn. R. 7007.0200	The permit restricts the PM2.5 emissions from this unit and other units at the facility. The combination of these limitations keeps the facility PM2.5 emissions below the PSD major source threshold and below the Part 70 major source threshold.	
	Minn. Stat. Section 116.07, subds. 4a & 9; Minn. R. 7007.0100, subp. 7(A), 7(L), & 7(M); Minn. R. 7007.0800, subps. 1, 2 & 4; Minn. R. 7009.0010-7009.0080	Emissions of PM2.5 for this unit are limited to the value modeled in the “Equivalent or Better Determination” (EBD) analysis for Air Emission Permit No. 03700070-007. This limit and other PM2.5 permit limits allow the facility to demonstrate compliance with the PM2.5 NAAQS.	
	Title I Condition: To avoid classification as a major source under 40 CFR Section 52.21 and Minn. R. 7007.3000 
Title I Condition: To avoid major source classification under 40 CFR Section 70.2 and Minn. R. 7007.0200	The permit restricts the sulfur content of No. 2 (distillate) fuel oil to 0.05 percent by weight and the sulfur content of other fuels to 0.10 percent by weight at all combustion units. This combination of these limitations keeps the facility’s SO2 emissions below the PSD major source threshold and below the Part 70 major source threshold.	
	Minn. R. 7011.0515, subp. 1 and subp. 2	Since construction of Boiler No. 2 began in 1994 (after January 31, 1977) and the unit is capable of burning natural gas and distillate fuel oil, it is subject to the state standards of performance for new indirect fossil-fuel-burning equipment. These include standards for particulate matter, SO2, NOX, and opacity.	
	40 CFR pt. 60, subp. Dc	Since construction of Boiler No. 2, a steam generating unit, began in 1994 (after June 9, 1989), and the unit’s maximum design heat input capacity of 17.58 million Btu per hour is between 10 and 100 million Btu per hour, the unit is subject to the federal Standards of Performance for Small Industrial-Commercial-Institutional Steam Generating Units. These include standards for particulate matter, SO2, and opacity. However, because the heat input for Boiler No. 2 is below 30 MMBtu/hr, the PM and opacity limits do not apply.	
	40 CFR pt. 63, subp. JJJJJJ	Since the effective date of 40 CFR Subpart JJJJJJ (March 21, 2014), Boiler No. 2 has met the definition of a gas-fired boiler in 40 CFR 63.11237; to date, it is not subject to this regulation.
However, Boiler No. 2 is a boiler located at an area source of HAPs. It is capable of and is authorized to burn natural gas, No. 2 fuel oil, glycerin, and RAFVO. The boiler does not have an oxygen trim system. When the unit fails to meet the definition of a gas-fired boiler, it will become subject to Subpart JJJJJJ.	
	Minn. R. 7005.0100, subp. 35a; Minn. R. 7007.0800, subp. 2; Minn. R. 7017.2020, subp. 1	Sanimax plans to burn conventional fuels (natural gas, propane, and distillate fuel oil) and, potentially, “alternative fuels” (i.e., glycerin and RAFVO) in Boiler No. 2. Since the emissions from the alternative fuels are not well-characterized, the permit requires Sanimax to conduct initial performance tests for criteria and HAP emissions (i.e., PM, PM10, PM2.5, opacity, CO, NOX, SO2, HCl, volatile organic compounds (VOCs), and HAPs) according to the state stack testing rules. These tests are needed to confirm that the emission factors used in the calculations for Air Emission Permit No. 03700070-007 for the combustion of distillate fuel oil are equal to or greater than the actual emissions factors for the combustion of the alternative fuel and to assure that the combustion of these materials meets permit emissions limits and that no new regulatory requirements are triggered.
While the permit authorizes test burns of the alternative fuels, full authorization to burn alternative fuels depends on the written approval by the MPCA after considering the results of fuel testing.	
	Minn. R. 7007.0800, subps. 4 and 5	HAP calculation: Following testing for the use of alternative fuels, the permit requires tracking of HAPs to assure that the facility remains an area source for NESHAPs. HAP emissions must remain below 9.0 tons per year.	
EQUI 8 STRU 15 TREA 30
PPF Pressing	Title I Condition: To avoid classification as a major source under 40 CFR Section 52.21 and Minn. R. 7007.3000 
Title I Condition: To avoid major source classification under 40 CFR Section 70.2 and Minn. R. 7007.0200	The permit restricts the PM10 emissions from this unit and other units at the facility. The combination of these limitations keeps the facility PM10 emissions below the PSD major source threshold and below the Part 70 major source threshold.	
	Minn. Stat. Section 116.07, subds. 4a & 9; Minn. R. 7007.0100, subp. 7(A), 7(L), & 7(M); Minn. R. 7007.0800, subps. 1, 2 & 4; Minn. R. 7009.0010-7009.0080	Emissions of PM10 for this unit are limited to the value modeled for Air Emission Permit No. 03700070-006. This limit and other PM10 permit limits allow the facility to demonstrate compliance with the PM10 NAAQS. 	
	Title I Condition: To avoid classification as a major source under 40 CFR Section 52.21 and Minn. R. 7007.3000 
Title I Condition: To avoid major source classification under 40 CFR Section 70.2 and Minn. R. 7007.0200	The permit restricts the PM2.5 emissions from this unit and other units at the facility. The combination of these limitations keeps the facility PM2.5 emissions below the PSD major source threshold and below the Part 70 major source threshold.	
	Minn. Stat. Section 116.07, subds. 4a & 9; Minn. R. 7007.0100, subp. 7(A), 7(L), & 7(M); Minn. R. 7007.0800, subps. 1, 2 & 4; Minn. R. 7009.0010-7009.0080	Emissions of PM2.5 for this unit are limited to the value modeled in the “Equivalent or Better Determination” (EBD) analysis for Air Emission Permit No. 03700070-007. This limit and other PM2.5 permit limits allow the facility to demonstrate compliance with the PM2.5 NAAQS.	
	Title I Condition: To avoid classification as a major source and modification under 40 CFR Section 52.21 and Minn. R. 7007.3000
Title I Condition: To avoid major source classification under 40 CFR Section 70.2 and Minn. R. 7007.0200	The facility accepted limits on particulate (PM, PM10, and PM2.5) emissions so the entire facility is a minor stationary source under the PSD regulation and a nonmajor source under the operating permits program (40 CFR Part 70, Minn. R. ch. 7007). Particulate emissions from PPF Pressing must be controlled to meet these limits, so emissions from the PPF Pressing must be vented to TREA 30, a Venturi scrubber, whenever PPF Pressing operates.	
	Minn. R. 7011.0715, subp. 1	Since operation of PPF Pressing began in 2011 (after July 9, 1969) and the unit is industrial process equipment as defined in Minn. R. 7011.0700, subp. 3, it is subject to the state standards of performance for industrial process equipment. These include standards for particulate matter and opacity.	
EQUI 9 STRU 15 TREA 30
PPF Milling	Title I Condition: To avoid classification as a major source under 40 CFR Section 52.21 and Minn. R. 7007.3000 
Title I Condition: To avoid major source classification under 40 CFR Section 70.2 and Minn. R. 7007.0200	The permit restricts the PM10 emissions from this unit and other units at the facility. The combination of these limitations keeps the facility PM10 emissions below the PSD major source threshold and below the Part 70 major source threshold.	
	Minn. Stat. Section 116.07, subds. 4a & 9; Minn. R. 7007.0100, subp. 7(A), 7(L), & 7(M); Minn. R. 7007.0800, subps. 1, 2 & 4; Minn. R. 7009.0010-7009.0080	Emissions of PM10 for this unit are limited to the value modeled for Air Emission Permit No. 03700070-006. This limit and other PM10 permit limits allow the facility to demonstrate compliance with the PM10 NAAQS. 	
	Title I Condition: To avoid classification as a major source under 40 CFR Section 52.21 and Minn. R. 7007.3000 
Title I Condition: To avoid major source classification under 40 CFR Section 70.2 and Minn. R. 7007.0200	The permit restricts the PM2.5 emissions from this unit and other units at the facility. The combination of these limitations keeps the facility PM2.5 emissions below the PSD major source threshold and below the Part 70 major source threshold.	
	Minn. Stat. Section 116.07, subds. 4a & 9; Minn. R. 7007.0100, subp. 7(A), 7(L), & 7(M); Minn. R. 7007.0800, subps. 1, 2 & 4; Minn. R. 7009.0010-7009.0080	Emissions of PM2.5 for this unit are limited to the value modeled in the “Equivalent or Better Determination” (EBD) analysis for Air Emission Permit No. 03700070-007. This limit and other PM2.5 permit limits allow the facility to demonstrate compliance with the PM2.5 NAAQS.	
	Title I Condition: To avoid classification as a major source and modification under 40 CFR Section 52.21 and Minn. R. 7007.3000
Title I Condition: To avoid major source classification under 40 CFR Section 70.2 and Minn. R. 7007.0200	The facility accepted limits on particulate (PM, PM10, and PM2.5) emissions so the entire facility is a minor stationary source under the PSD regulation and a nonmajor source under the operating permits program (40 CFR Part 70, Minn. R. ch. 7007). Particulate emissions from PPF Milling must be controlled to meet these limits, so emissions from the PPF Milling must be vented to TREA 30, a Venturi scrubber, whenever PPF Milling operates.	
	Minn. R. 7011.0715, subp. 1	Since operation of PPF Milling began in 2011 (after July 9, 1969) and the unit is industrial process equipment as defined in Minn. R. 7011.0700, subp. 3, it is subject to the state standards of performance for industrial process equipment. These include standards for particulate matter and opacity.	
EQUI 10 STRU 16 
Boiler No. 3	Minn. R. 7007.0200, subp. 2	The permit authorizes the construction and operation of a new boiler, described by the permit application. The authorization to construct expires 18 months after the date of permit issuance.	
	Title I Condition: To avoid classification as a major source under 40 CFR Section 52.21 and Minn. R. 7007.3000 
Title I Condition: To avoid major source classification under 40 CFR Section 70.2 and Minn. R. 7007.0200	The permit restricts the PM2.5 emissions from this unit and other units at the facility. The combination of these limitations keeps the facility PM2.5 emissions below the PSD major source threshold and below the Part 70 major source threshold.	
	Minn. Stat. Section 116.07, subds. 4a & 9; Minn. R. 7007.0100, subp. 7(A), 7(L), & 7(M); Minn. R. 7007.0800, subps. 1, 2 & 4; Minn. R. 7009.0010-7009.0080	Emissions of PM2.5 for this unit are limited to the value modeled in the “Equivalent or Better Determination” (EBD) analysis for Air Emission Permit No. 03700070-007. This limit and other PM2.5 permit limits allow the facility to demonstrate compliance with the PM2.5 NAAQS.	
	Title I Condition: To avoid classification as a major source under 40 CFR Section 52.21 and Minn. R. 7007.3000	The permit restricts the sulfur content of No. 2 (distillate) fuel oil to 0.05 percent by weight and the sulfur content of other fuels to 0.10 percent by weight at all combustion units. This combination of these limitations keeps the facility’s SO2 emissions below the PSD major source threshold.	
	40 CFR pt. 60, subp. Dc	Standards of Performance for Small Industrial-Commercial-Institutional Steam Generating Units. Determination of applicable limits from rule:
•	The unit will be constructed after June 9, 1989. 
•	The heat input capacity will be 98 MMBtu/hr (below 100 MMBtu/hr but above 10 MMBtu/hr), so the unit will be subject to an opacity standard as well as the SO2 standard.
The fuels to be burned by Boiler No. 3 are limited to natural gas, No. 2 fuel oil, glycerin, and RAFVO. No. 2 fuel oil will have a maximum sulfur content of 0.05 percent by weight. Other liquid fuels are limited to 0.10 percent sulfur by weight.	
	40 CFR pt. 63, subp. JJJJJJ	When installed, Boiler No. 3 will be a boiler located at an area source of HAPs. It will be capable of and is authorized to burn natural gas, No. 2 fuel oil, glycerin, and RAFVO. The boiler has an oxygen trim system.
If, upon startup, Sanimax operates the unit in a way that allows it to meet the definition of a gas-fired boiler in 40 CFR 63.11237, Boiler No. 3 will not be subject to Subpart JJJJJJ. However, when the unit fails to meet the definition of a gas-fired boiler, it becomes subject to Subpart JJJJJJ.	
	Minn. R. 7005.0100, subp. 35a; Minn. R. 7007.0800, subp. 2; Minn. R. 7017.2020, subp. 1	Sanimax plans to burn conventional fuels (natural gas, propane, and distillate fuel oil) and, potentially, “alternative fuels” (i.e., glycerin and RAFVO) in Boiler No. 3. Since the emissions from the alternative fuels are not well-characterized, the permit requires Sanimax to conduct initial performance tests for criteria and HAP emissions (i.e., PM, PM10, PM2.5, opacity, CO, NOX, SO2, HCl, volatile organic compounds (VOCs), and HAPs) according the state stack testing rules. These tests are needed to confirm that the emission factors used in the calculations for Air Emission Permit No. 03700070-007 for the combustion of distillate fuel oil are equal to or greater than the actual emissions factors for the combustion of the alternative fuel and to assure that the combustion of these materials meets permit emissions limits and that no new regulatory requirements are triggered.
While the permit authorizes test burns of the alternative fuels, full authorization to burn alternative fuels depends on the written approval by the MPCA after considering the results of fuel testing.	
	Minn. R. 7007.0800, subps. 4 and 5	HAP calculation: Following testing for the use of alternative fuels, the permit requires tracking of HAPs to assure that the facility remains an area source for NESHAPs. HAP emissions must remain below 9.0 tons per year.	
EQUI 19 STRU 14
Boiler No. 1	Title I Condition: To avoid classification as a major source under 40 CFR Section 52.21 and Minn. R. 7007.3000 
Title I Condition: To avoid major source classification under 40 CFR Section 70.2 and Minn. R. 7007.0200	The permit restricts the PM10 emissions from this unit and other units at the facility. The combination of these limitations keeps the facility PM10 emissions below the PSD major source threshold and below the Part 70 major source threshold.	
	Minn. Stat. Section 116.07, subds. 4a & 9; Minn. R. 7007.0100, subp. 7(A), 7(L), & 7(M); Minn. R. 7007.0800, subps. 1, 2 & 4; Minn. R. 7009.0010-7009.0080	Emissions of PM10 for this unit are limited to the value modeled for Air Emission Permit No. 03700070-006. This limit and other PM10 permit limits allow the facility to demonstrate compliance with the PM10 NAAQS. 	
	Title I Condition: To avoid classification as a major source under 40 CFR Section 52.21 and Minn. R. 7007.3000 
Title I Condition: To avoid major source classification under 40 CFR Section 70.2 and Minn. R. 7007.0200	The permit restricts the PM2.5 emissions from this unit and other units at the facility. The combination of these limitations keeps the facility PM2.5 emissions below the PSD major source threshold and below the Part 70 major source threshold.	
	Minn. Stat. Section 116.07, subds. 4a & 9; Minn. R. 7007.0100, subp. 7(A), 7(L), & 7(M); Minn. R. 7007.0800, subps. 1, 2 & 4; Minn. R. 7009.0010-7009.0080	Emissions of PM2.5 for this unit are limited to the value modeled in the “Equivalent or Better Determination” (EBD) analysis for Air Emission Permit No. 03700070-007. This limit and other PM2.5 permit limits allow the facility to demonstrate compliance with the PM2.5 NAAQS.	
	Title I Condition: To avoid classification as a major source under 40 CFR Section 52.21 and Minn. R. 7007.3000 
Title I Condition: To avoid major source classification under 40 CFR Section 70.2 and Minn. R. 7007.0200	The permit restricts the sulfur content of No. 2 (distillate) fuel oil to 0.05 percent by weight and the sulfur content of other fuels to 0.10 percent by weight at all combustion units. This combination of these limitations keeps the facility’s SO2 emissions below the PSD major source threshold and below the Part 70 major source threshold.	
	Minn. R. 7007.0800, subp. 2	Boiler No. 1 must be shut down within 180 days of initial startup of the Boiler No. 3. This provides sufficient time for the overlap in the operation of the two boilers to ensure that the new boiler can operate correctly.
Boiler No. 1 must be shut down to ensure that the modeling conducted in support of this permit action is accurate, as the new modeling scenario does not include this boiler.	
	Minn. R. 7011.0515, subp. 1 and subp. 2	Since construction of Boiler No. 1 began in 1978 (after January 31, 1977) and the unit is capable of burning natural gas and distillate fuel oil, it is subject to the state standards of performance for new indirect fossil-fuel-burning equipment. These include standards for particulate matter, SO2, NOX, and opacity.	
	40 CFR pt. 63, subp. JJJJJJ	Since the effective date of 40 CFR Subpart JJJJJJ (March 21, 2014), Boiler No. 1 has met the definition of a gas-fired boiler in 40 CFR 63.11237; to date, it is not subject to this regulation.
However, Boiler No. 1 is a boiler located at an area source of HAPs. It is capable of and is authorized to burn natural gas, No. 2 fuel oil, glycerin, and RAFVO. The boiler does not have an oxygen trim system. When the unit fails to meet the definition of a gas-fired boiler, it will become subject to Subpart JJJJJJ.	
	Minn. R. 7005.0100, subp. 35a; Minn. R. 7007.0800, subp. 2; Minn. R. 7017.2020, subp. 1	Sanimax plans to burn conventional fuels (natural gas, propane, and distillate fuel oil) and, potentially, “alternative fuels” (i.e., glycerin and RAFVO) in Boiler No. 1. Since the emissions from the alternative fuels are not well-characterized, the permit requires Sanimax to conduct initial performance tests for criteria and HAP emissions (i.e., PM, PM10, PM2.5, opacity, CO, NOX, SO2, HCl, volatile organic compounds (VOCs), and HAPs) according the state stack testing rules. These tests are needed to confirm that the emission factors used in the calculations for Air Emission Permit No. 03700070-007 for the combustion of distillate fuel oil are equal to or greater than the actual emissions factors for the combustion of the alternative fuel and to assure that the combustion of these materials meets permit emissions limits and that no new regulatory requirements are triggered.
While the permit authorizes test burns of the alternative fuels, full authorization to burn alternative fuels depends on the written approval by the MPCA after considering the results of fuel testing.	
	Minn. R. 7007.0800, subps. 4 and 5	HAP calculation: Following testing for the use of alternative fuels, the permit requires tracking of HAPs to assure that the facility remains an area source for NESHAPs. HAP emissions must remain below 9.0 tons per year.	
EQUI 20 STRU 22 TREA 27 
Protein Recovery Facility (PRF)	Title I Condition: To avoid classification as a major source under 40 CFR Section 52.21 and Minn. R. 7007.3000 
Title I Condition: To avoid major source classification under 40 CFR Section 70.2 and Minn. R. 7007.0200	The permit restricts the PM10 emissions from this unit and other units at the facility. The combination of these limitations keeps the facility PM10 emissions below the PSD major source threshold and below the Part 70 major source threshold.	
	Minn. Stat. Section 116.07, subds. 4a & 9; Minn. R. 7007.0100, subp. 7(A), 7(L), & 7(M); Minn. R. 7007.0800, subps. 1, 2 & 4; Minn. R. 7009.0010-7009.0080	Emissions of PM10 for this unit are limited to the value modeled for Air Emission Permit No. 03700070-006. This limit and other PM10 permit limits allow the facility to demonstrate compliance with the PM10 NAAQS. 	
	Title I Condition: To avoid classification as a major source under 40 CFR Section 52.21 and Minn. R. 7007.3000 
Title I Condition: To avoid major source classification under 40 CFR Section 70.2 and Minn. R. 7007.0200	The permit restricts the PM2.5 emissions from this unit and other units at the facility. The combination of these limitations keeps the facility PM2.5 emissions below the PSD major source threshold and below the Part 70 major source threshold.	
	Minn. Stat. Section 116.07, subds. 4a & 9; Minn. R. 7007.0100, subp. 7(A), 7(L), & 7(M); Minn. R. 7007.0800, subps. 1, 2 & 4; Minn. R. 7009.0010-7009.0080	Emissions of PM2.5 for this unit are limited to the value modeled in the “Equivalent or Better Determination” (EBD) analysis for Air Emission Permit No. 03700070-007. This limit and other PM2.5 permit limits allow the facility to demonstrate compliance with the PM2.5 NAAQS.	
	Title I Condition: To avoid classification as a major source and modification under 40 CFR Section 52.21 and Minn. R. 7007.3000
Title I Condition: To avoid major source classification under 40 CFR Section 70.2 and Minn. R. 7007.0200	The facility accepted limits on particulate (PM, PM10, and PM2.5) emissions so the entire facility is a minor stationary source under the PSD regulation and a nonmajor source under the operating permits program (40 CFR Part 70, Minn. R. ch. 7007). Particulate emissions from the protein recovery facility must be controlled to meet these limits, so emissions from the protein recovery facility must be vented to TREA 27, a Venturi scrubber, whenever the protein recovery facility operates.	
	Minn. R. 7011.0715, subp. 1	Since operation of the Protein Recovery Facility began in 1994 (after July 9, 1969) and the unit is industrial process equipment as defined in Minn. R. 7011.0700, subp. 3, it is subject to the state standards of performance for industrial process equipment. These include standards for particulate matter and opacity.	
EQUI 21 STRU 19 TREA 31 TREA 34 
Blood Pneumatic Conveying System	Title I Condition: To avoid classification as a major source under 40 CFR Section 52.21 and Minn. R. 7007.3000 
Title I Condition: To avoid major source classification under 40 CFR Section 70.2 and Minn. R. 7007.0200	The permit restricts the PM10 emissions from this unit and other units at the facility. The combination of these limitations keeps the facility PM10 emissions below the PSD major source threshold and below the Part 70 major source threshold.	
	Minn. Stat. Section 116.07, subds. 4a & 9; Minn. R. 7007.0100, subp. 7(A), 7(L), & 7(M); Minn. R. 7007.0800, subps. 1, 2 & 4; Minn. R. 7009.0010-7009.0080	Emissions of PM10 for this unit are limited to the value modeled for Air Emission Permit No. 03700070-006. This limit and other PM10 permit limits allow the facility to demonstrate compliance with the PM10 NAAQS. 	
	Title I Condition: To avoid classification as a major source under 40 CFR Section 52.21 and Minn. R. 7007.3000 
Title I Condition: To avoid major source classification under 40 CFR Section 70.2 and Minn. R. 7007.0200	The permit restricts the PM2.5 emissions from this unit and other units at the facility. The combination of these limitations keeps the facility PM2.5 emissions below the PSD major source threshold and below the Part 70 major source threshold.	
	Minn. Stat. Section 116.07, subds. 4a & 9; Minn. R. 7007.0100, subp. 7(A), 7(L), & 7(M); Minn. R. 7007.0800, subps. 1, 2 & 4; Minn. R. 7009.0010-7009.0080	Emissions of PM2.5 for this unit are limited to the value modeled in the “Equivalent or Better Determination” (EBD) analysis for Air Emission Permit No. 03700070-007. This limit and other PM2.5 permit limits allow the facility to demonstrate compliance with the PM2.5 NAAQS.	
	Title I Condition: To avoid classification as a major source and modification under 40 CFR Section 52.21 and Minn. R. 7007.3000
Title I Condition: To avoid major source classification under 40 CFR Section 70.2 and Minn. R. 7007.0200	The facility accepted limits on particulate (PM, PM10, and PM2.5) emissions so the entire facility is a minor stationary source under the PSD regulation and a nonmajor source under the operating permits program (40 CFR Part 70, Minn. R. ch. 7007). Particulate emissions from the blood pneumatic conveying system must be controlled to meet these limits, so emissions from the blood pneumatic conveying system must be vented to TREA 31 or TREA 34, fabric filters, whenever the blood pneumatic conveying system operates.	
	Minn. R. 7011.0715, subp. 1	Since operation of the Blood Pneumatic Conveying System began in 1991 (after July 9, 1969) and the unit is industrial process equipment as defined in Minn. R. 7011.0700, subp. 3, it is subject to the state standards of performance for industrial process equipment. These include standards for particulate matter and opacity.	
EQUI 66 STRU 15 TREA 30 
PPF Cooking	Title I Condition: To avoid classification as a major source under 40 CFR Section 52.21 and Minn. R. 7007.3000 
Title I Condition: To avoid major source classification under 40 CFR Section 70.2 and Minn. R. 7007.0200	The permit restricts the PM10 emissions from this unit and other units at the facility. The combination of these limitations keeps the facility PM10 emissions below the PSD major source threshold and below the Part 70 major source threshold.	
	Minn. Stat. Section 116.07, subds. 4a & 9; Minn. R. 7007.0100, subp. 7(A), 7(L), & 7(M); Minn. R. 7007.0800, subps. 1, 2 & 4; Minn. R. 7009.0010-7009.0080	Emissions of PM10 for this unit are limited to the value modeled for Air Emission Permit No. 03700070-006. This limit and other PM10 permit limits allow the facility to demonstrate compliance with the PM10 NAAQS. 	
	Title I Condition: To avoid classification as a major source under 40 CFR Section 52.21 and Minn. R. 7007.3000 
Title I Condition: To avoid major source classification under 40 CFR Section 70.2 and Minn. R. 7007.0200	The permit restricts the PM2.5 emissions from this unit and other units at the facility. The combination of these limitations keeps the facility PM2.5 emissions below the PSD major source threshold and below the Part 70 major source threshold.	
	Minn. Stat. Section 116.07, subds. 4a & 9; Minn. R. 7007.0100, subp. 7(A), 7(L), & 7(M); Minn. R. 7007.0800, subps. 1, 2 & 4; Minn. R. 7009.0010-7009.0080	Emissions of PM2.5 for this unit are limited to the value modeled in the “Equivalent or Better Determination” (EBD) analysis for Air Emission Permit No. 03700070-007. This limit and other PM2.5 permit limits allow the facility to demonstrate compliance with the PM2.5 NAAQS.	
	Title I Condition: To avoid classification as a major source and modification under 40 CFR Section 52.21 and Minn. R. 7007.3000
Title I Condition: To avoid major source classification under 40 CFR Section 70.2 and Minn. R. 7007.0200	The facility accepted limits on particulate (PM, PM10, and PM2.5) emissions so the entire facility is a minor stationary source under the PSD regulation and a nonmajor source under the operating permits program (40 CFR Part 70, Minn. R. ch. 7007). Particulate emissions from PPF Cooking must be controlled to meet these limits, so emissions from the PPF Cooking must be vented to TREA 30, a Venturi scrubber, whenever PPF Cooking operates.	
	Minn. R. 7011.0715, subp. 1	Since operation of PPF Cooking began in 2011 (after July 9, 1969) and the unit is industrial process equipment as defined in Minn. R. 7011.0700, subp. 3, it is subject to the state standards of performance for industrial process equipment. These include standards for particulate matter and opacity.	
TREA 26	Title I Condition: To avoid classification as a major source and modification under 40 CFR Section 52.21 and Minn. R. 7007.3000
Title I Condition: To avoid major source classification under 40 CFR Section 70.2 and Minn. R. 7007.0200	The facility is required to operate the Venturi scrubber to control particulate (PM, PM10, and PM2.5) emissions from EQUI 4. The facility accepted particulate matter limits that require the effective operation of this control equipment so the entire facility is a minor stationary source under the PSD regulation and a nonmajor source under the operating permits program (40 CFR Part 70, Minn. R. ch. 7007). 	
TREA 27	Title I Condition: To avoid classification as a major source and modification under 40 CFR Section 52.21 and Minn. R. 7007.3000
Title I Condition: To avoid major source classification under 40 CFR Section 70.2 and Minn. R. 7007.0200	The facility is required to operate the Venturi scrubber to control particulate (PM, PM10, and PM2.5) emissions from EQUI 20. The facility accepted particulate matter limits that require the effective operation of this control equipment so the entire facility is a minor stationary source under the PSD regulation and a nonmajor source under the operating permits program (40 CFR Part 70, Minn. R. ch. 7007).	
TREA 28	Title I Condition: To avoid classification as a major source and modification under 40 CFR Section 52.21 and Minn. R. 7007.3000
Title I Condition: To avoid major source classification under 40 CFR Section 70.2 and Minn. R. 7007.0200	The facility is required to operate the Venturi scrubber to control particulate (PM, PM10, and PM2.5) emissions from EQUI 16 and EQUI 17. The facility accepted particulate matter limits that require the effective operation of this control equipment so the entire facility is a minor stationary source under the PSD regulation and a nonmajor source under the operating permits program (40 CFR Part 70, Minn. R. ch. 7007).	
TREA 31	Title I Condition: To avoid major source classification under 40 CFR Section 70.2 and Minn. R. 7007.0200	The facility is required to operate this fabric filter (TREA 31) to control particulate (PM, PM10, and PM2.5) emissions from EQUI 21. 
The facility accepted particulate matter limits that require the effective operation of this control equipment so the entire facility is a minor stationary source under the PSD regulation and a nonmajor source under the operating permits program (40 CFR Part 70, Minn. R. ch. 7007).	
TREA 32	Title I Condition: To avoid classification as a major source under 40 CFR Section 52.21 and Minn. R. 7007.3000; 	The facility is required to operate the fabric filter (TREA 32) to control particulate (PM, PM10, and PM2.5) emissions from EQUI 1.
The facility accepted particulate matter limits that require the effective operation of this control equipment so the entire facility is a minor stationary source under the PSD regulation and a nonmajor source under the operating permits program (40 CFR Part 70, Minn. R. ch. 7007).	
TREA 33	Title I Condition: To avoid major source classification under 40 CFR Section 70.2 and Minn. R. 7007.0200	The facility is required to operate the fabric filter (TREA 33) to control particulate (PM, PM10, and PM2.5) emissions from EQUI 2.
The facility accepted particulate matter limits that require the effective operation of this control equipment so the entire facility is a minor stationary source under the PSD regulation and a nonmajor source under the operating permits program (40 CFR Part 70, Minn. R. ch. 7007).	
TREA 34	Title I Condition: To avoid classification as a major source under 40 CFR Section 52.21 and Minn. R. 7007.3000; 	The facility is required to operate this fabric filter (TREA 34) to control particulate (PM, PM10, and PM2.5) emissions from EQUI 21. 
The facility accepted particulate matter limits that require the effective operation of this control equipment so the entire facility is a minor stationary source under the PSD regulation and a nonmajor source under the operating permits program (40 CFR Part 70, Minn. R. ch. 7007).	
TREA 35	Title I Condition: To avoid classification as a major source and modification under 40 CFR Section 52.21 and Minn. R. 7007.3000
Title I Condition: To avoid major source classification under 40 CFR Section 70.2 and Minn. R. 7007.0200	The facility is required to operate the fabric filter to control particulate (PM, PM10, and PM2.5) emissions from EQUI 18. The facility accepted particulate matter limits that require the effective operation of this control equipment so the entire facility is a minor stationary source under the PSD regulation and a nonmajor source under the operating permits program (40 CFR Part 70, Minn. R. ch. 7007).	
*Location of the requirement in the permit (e.g., EQUI, STRU, COMG, etc.).
3.	Technical Information
3.1	Calculations of Potential to Emit and Emissions Increase Analysis
Attachment 1 to this TSD contains several emission-related pieces of information, including:
•	Form GI-07, which summarizes the PTE of the facility;
•	Detailed spreadsheets and supporting information prepared by the MPCA and the Permittee; and
•	The Title I emissions increase calculations for this modification, which demonstrates that this modification is not a major modification for PSD. 
AP-42 was the primary source of emission factors for the combustion units, including most of the emission factors for the proposed Boiler No. 3 (EQUI 10). However, manufacturer’s guarantees provided Boiler No. 3’s filterable PM emissions and controlled NOX emissions. Filterable PM10 and PM2.5 fractions for the other combustion units were derived using AP‑42. Condensable particulate emissions factors were also from AP‑42. Greenhouse gas emissions factors came from 40 CFR Part 98.
To estimate emissions from RAFVO combustion, Sanimax relied on a heating value of 127,333 Btu per gallon. For most pollutants, Sanimax used the AP‑42 emission factors for No. 2 fuel oil. Formaldehyde emissions were estimated from performance tests at another Sanimax facility and the heat content. Sanimax estimated a maximum fuel sulfur content of 0.10 percent by weight, which was used in the calculation of sulfur dioxide emissions.
In its review of the modeling protocol, the MPCA noted that the calculations of fugitive dust from paved and unpaved roads changed from the previous permit. This occurred for two reasons: (1) an error was made in the previous permit, as vehicle weights were presented in pounds rather than tons (the emission calculation uses tons); and (2) the emission factors from AP-42 were updated. The effect of each change was a reduction in calculated fugitive emissions, so the overall impact was a reduction in calculated fugitive emissions. Fugitive emissions remain an insignificant activity in the permit. These emission changes were included in the Equivalent or Better Determination” (EBD) modeling demonstration. 
Additional details on the emissions factors are provided in the facility’s calculation spreadsheets.
3.2	State-Only Limits on PM  (Protein Silo/Bin No. 1 and Protein Silo/Bin No. 2)
Sanimax’s permit contains limits on Total Particulate Matter emissions from the Protein Silo/Bin No. 1 (EQUI 1) and Protein Silo/Bin No. 2 (EQUI 2). The permit identifies these limits as state-only limits derived from modeling.
These limits on Total Particulate Matter (formerly called Total Suspended Particulate, or TSP) were originally established in a permit issued on September 20, 1993 (Air Emission Permit No. 578-93-I/O-1). According to the Technical Support Document for Air Emission Permit No. 03700070-001 (issued April 29, 2003) a nearby area was, at that time, a nonattainment area for PM10. This facility was modeled to determine if it contributed to the particulate problems there, but it was found not to contribute. The TSP limit appears to have been derived from this modeling. Since PM10 replaced TSP as the criteria pollutant for particulate matter, this limit is now identified as a state-only limit.
3.3	Combustion of Alternative Fuels
Air Emission Permit No. 03700070-006 allowed Sanimax to burn natural gas, residual oil, distillate oil, animal fat/vegetable oil, propane, or glycerin in its combustion equipment. The permit required test burns, written approval from the MPCA, and the receipt of the appropriate permit for the use of RAFVO and glycerin beyond the test burns.
Two actions change the permit conditions governing the fuels allowed to be combusted at the Sanimax facility. These are discussed below.
a.	Request to change allowable fuels
In its application for this permit action (Air Emission Permit No. 03700070-007), Sanimax requested that the permit no longer allow the use of residual fuel oil. By eliminating the potential use of residual fuel oil, the facility’s potential to emit SO2 is reduced to a level where it can operate under a state operating permit rather than a Part 70 operating permit.) 
Initially, Sanimax also requested that it no longer be allowed to combust RAFVO at the South Saint Paul facility. In subsequent communications, however, the company indicated that it wanted to retain the capability to burn natural gas, distillate oil, propane, as well as alternative fuels – RAFVO and glycerin. The permit and its supporting documents reflect the omission of residual fuel oil. The remainder of the fuels allowed in Air Emission Permit No. 03700070-006 may still be burned, but with some additional constraints. 
b.	EPA’s promulgation of a solid waste definition 
The EPA recently promulgated a rule under the Resource Conservation and Recovery Act (RCRA) identifying non-hazardous secondary materials that are solid waste. The definition of solid waste in the rule determines “whether a combustion unit is required to meet the emissions standards for solid waste incineration units under section 129 or the Clean Air Act (CAA) or the emissions standards for commercial, industrial, and institutional boilers issued under section 112 of the CAA.” EPA also finalized a definition of traditional fuels in the rulemaking.
Sanimax indicated that it does not want to be a solid waste incinerator, so the facility cannot burn solid waste. Non-hazardous secondary materials used as fuels in boilers (rather than solid wastes burned in incinerators) must meet several criteria. Sanimax documented its understanding of refined animal fats and glycerin as alternative fuels in a memorandum submitted at the MPCA’s request. This memorandum is included with the TSD as Attachment 4.
As noted above, the boilers at the Sanimax facility will be subject to the National Emission Standards for Hazardous Air Pollutants for Industrial, Commercial, and Institutional Boilers Area Sources (40 CFR Part 63, Subpart JJJJJJ) if they no longer operate within the definition of gas-fired boilers. The authority for this rule comes from section 112 of the CAA.
3.4	Requirement to Conduct Performance Tests
Sanimax is required to perform a limited number of performance (stack) tests.
a.	Develop emission factors for alternative fuels
The permit allows Sanimax to perform test burns of glycerin and RAFVO. Since the emissions from these materials are not well-characterized, the emissions calculations for these materials assumed that the emission factors for No. 2 fuel oil provide an upper limit on the emissions. The facility must complete performance tests during the tests burns to provide assurance that the combustion emissions are conservatively estimated. 
b.	Confirm PM10 and PM2.5 emission factors for the Ring/Blood Dryer/Oven (EQUI 4)
The permit requires the company to confirm the particulate emission factors used in the calculations for the Ring/Blood Dryer/Oven (EQUI 4) and demonstrate compliance with the modeled emissions rate. The emissions calculations relied on a composite factor derived from EPA’s AP-42 document as well as a generalized particle size distribution. Performance tests for PM10 and PM2.5 will ensure that the factors used for estimating emissions and for modeling ambient air quality from this unit are accurate. 
3.5	Alternative Operating Scenario
The National Emission Standards for Hazardous Air Pollutants for Industrial, Commercial, and Institutional Boilers Area Sources (40 CFR Part 63, Subpart JJJJJJ) do not apply to gas-fired boilers, as the term is defined in the rule. Sanimax has operated Boiler No. 1 and Boiler No. 2, its existing boilers, as gas-fired boilers since the compliance date of the rule (March 21, 2014). In the future, however, the company may operate them as oil-fired units. Similarly, Sanimax plans to initially operate Boiler No. 3 as a gas-fired unit but wants to retain the possibility of operating it as an oil-fired unit in the future. 
The permit accommodates both possibilities by creating two sets of permit language, called alternative operating scenarios. The first operating scenario will apply to the units (Boiler No. 1, Boiler No. 2, and the new Boiler No. 3) as long as they operate as natural gas-fired boilers. A boiler that operates in a way that no longer meets the definition of gas-fired boiler becomes part of the oil subcategory and must follow the second operating scenario. 
3.6	Dispersion Modeling
Air Emission Permit No. 03700070-006 included a condition that required a remodeling submittal when a proposed project at Sanimax affected a modeled parameter or emission rate documented in Appendix B of the permit and also required a major permit amendment. Because the current project (i.e., the basis of Air Emission Permit No. 03700070-007) meets these criteria, Sanimax submitted a modeling protocol for an “Equivalent or Better Determination” (EBD) for PM2.5. The EBD approach uses positive allowable emission rates for the “new” facility and negative allowable emission rates for the “old” facility (which was previously modeled). Any other changes to modeling parameters (e.g., stack temperatures, stack heights, flow rates) are also modified with the new emission rates. Positive modeled values reflect a potential degradation in air quality, while a “zero” means no change in the facility characteristics in comparison to ambient baseline conditions. Thus, to be “equivalent or better,” the modeling results should not result in a positive value (identified as a value exceeding 0.0050 µg/m3) at an ambient receptor. 
Compliance with the NAAQS depends on a number of factors that include the emission limits and permit conditions that were included in Air Emission Permit 03700070-006 and carried over to Air Emission Permit 03700070-007. Permit Action -007 revises emission limits for EQUI 4 and EQUI 5. It also adds a condition requiring the removal of EQUI 19 (Boiler No. 1) after the installation of EQUI 10 (Boiler No. 3) and a PM2.5 emission limitation for EQUI 10 (representing the new boiler’s potential to emit).
The EBD modeling for Sanimax reflected the changes in Permit Action -007. Although Sanimax’s EBD modeling resulted in a positive value, further analysis showed that the highest baseline condition shifted or moved to different parts of the modeling domain without a change in compliance. The MPCA approved Sanimax’s EBD submittal on May 13, 2015.
This permit action retains the Tier 3 status of PM2.5 for modeling, continuing to require an EBD analysis for changes at the facility that require a minor, moderate, and major permit amendment and affect any modeled PM2.5 parameter or emission rate listed in Appendix C to the permit. Changes to emission rates include the addition of new PM2.5-emitting equipment. The permit language for the modeling conditions has been updated.
PM10 retains its Tier 1 status for modeling; the permit does not require PM10 modeling. However, there may be circumstances under which the MPCA requests a PM10 modeling demonstration. Appendix B to the permit continues to contain the modeling parameters for PM10. 
3.7	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.
The table below summarizes the monitoring requirements associated with this amendment.
Table 6. Monitoring
Subject Item*	Requirement (rule basis)	Monitoring	Discussion	
COMG 7 (TREA 28, EQUI 3, EQUI 16, EQUI 17, & STRU 24)
Continuous Cookers and Control Equipment	PM ≤ 2.0 lb/hr using 3-hour rolling average
Title I Condition: to avoid classification as a major source under 40 CFR Section 52.21 and Minn. R. 7007.3000	See TREA 28.	The PM emission limit represents the potential to emit of the COMG 7 units using TREA 28 (reflecting enforceable controls).
This permit contains a requirement to vent emissions from EQUI 16 and EQUI 17 to TREA 28 at all times EQUI 16 or EQUI 17 is operating. See TREA 28 for additional monitoring and recordkeeping requirements for EQUI 16 and EQUI 17.	
	PM10 ≤ 1.8 lb/hr using 3-hour rolling average
PM2.5 ≤ 1.1 lb/hr using 3-hour rolling average
Title I Condition: to avoid classification as a major source under 40 CFR Section 52.21 and Minn. R. 7007.3000; Minn. Stat. Section 116.07, subds. 4a & 9; Minn. R. 7007.0100, subp. 7(A), 7(L), & 7(M); Minn.R. 7007.0800, subps. 1, 2, & 4; Minn. R. 7009.0010-7009.0800	See TREA 28.	The PM10 and PM2.5 emission limits represent the potentials to emit of the COMG 7 units using TREA 28 (reflecting enforceable controls).
This permit contains a requirement to vent emissions from EQUI 16 and EQUI 17 to TREA 28 at all times EQUI 16 or EQUI 17 is operating. See TREA 28 for additional monitoring and recordkeeping requirements for EQUI 16 and EQUI 17.	
	PM ≤ 0.30 gr/dscf of exhaust gas unless required to further reduce emissions to comply with the less stringent limit of either Minn. R. 7011.0730 or Minn. R. 7011.0735
Opacity ≤ 20 percent
Minn. R. 7011.0715, subp. 1(A) and 1(B)	Operate and maintain the pollution control equipment at all times.	The permit contains a requirement to vent emissions from EQUI 16 and EQUI 17 to TREA 28 at all times that EQUI 16 and EQUI 17 are operating. The permit requires daily visible emissions, pressure drop, and flow rate reading for TREA 28. In addition, periodic inspections facilitate ongoing control equipment performance checks.	
EQUI 1/ TREA 32/ STRU 26
Protein Silo/Bin No. 1	PM10 ≤ 0.050 lb/hr using 3-hour rolling average
PM2.5 ≤ 0.050 lb/hr using 3-hour rolling average
Title I Condition: to avoid classification as a major source and modification under 40 CFR 52.21 and Minn. R. 7007.3000; Minn. Stat. Section 116.07, subds. 4a & 9; Minn. R. 7007.0100, subp. 7(A), 7(L), & 7(M); Minn. R. 7007.0800, subps. 1, 2 & 4; Minn. R. 7009.0010-7009.0080	See TREA 32.	This permit contains a requirement to vent emissions from EQUI 1 to TREA 32 at all times EQUI 1 is operating. See TREA 32 for additional monitoring and recordkeeping requirements for EQUI 1.	
	PM ≤ 0.10 lb/hr using 3-hour rolling average
Minn. Stat. Section 116.07, subds. 4a & 9; Minn. R. 7007.0100, subp. 7(A), 7(L), & 7(M); Minn. R. 7007.0800, subps. 1, 2 & 4; Minn. R. 7009.0010-7009.0080 (state-only condition)	See TREA 32.	This permit contains a requirement to vent emissions from EQUI 1 to TREA 32 at all times EQUI 1 is operating. See TREA 32 for additional monitoring and recordkeeping requirements for EQUI 1.	
	PM ≤ 0.30 gr/dscf using 3-hour rolling average 
Opacity ≤ 20 percent
Minn. R. 7011.0715, subp. 1(A) & 1(B)	See TREA 32.	This permit contains a requirement to vent emissions from EQUI 1 to TREA 32 at all times EQUI 1 is operating. See TREA 32 for additional monitoring and recordkeeping requirements for EQUI 1.	
EQUI 2/ TREA 33/ STRU 27
Protein Silo/Bin No. 2	PM10 ≤ 0.050 lb/hr 
PM2.5 ≤ 0.050 lb/hr
Title I Condition: to avoid classification as a major source and modification under 40 CFR 52.21 and Minn. R. 7007.3000; Minn. Stat. Section 116.07, subds. 4a & 9; Minn. R. 7007.0100, subp. 7(A), 7(L), & 7(M); Minn. R. 7007.0800, subps. 1, 2 & 4; Minn. R. 7009.0010-7009.0080	See TREA 33.	This permit contains a requirement to vent emissions from EQUI 2 to TREA 33 at all times EQUI 2 is operating. See TREA 33 for additional monitoring and recordkeeping requirements for EQUI 2.	
	PM ≤ 0.10 lb/hr using 3-hour rolling average
Minn. Stat. Section 116.07, subds. 4a & 9; Minn. R. 7007.0100, subp. 7(A), 7(L), & 7(M); Minn. R. 7007.0800, subps. 1, 2 & 4; Minn. R. 7009.0010-7009.0080 (state-only condition)	See TREA 33.	This permit contains a requirement to vent emissions from EQUI 2 to TREA 33 at all times EQUI 2 is operating. See TREA 33 for additional monitoring and recordkeeping requirements for EQUI 2.	
	PM ≤ 0.30 gr/dscf using 3-hour rolling average 
Opacity ≤ 20 percent
Minn. R. 7011.0715, subp. 1(A) & 1(B)	See TREA 33.	This permit contains a requirement to vent emissions from EQUI 2 to TREA 33 at all times EQUI 2 is operating. See TREA 33 for additional monitoring and recordkeeping requirements for EQUI 2.	
EQUI 3/ TREA 29/ STRU 25
COMG 7
Continuous Milling Equipment	PM10 ≤ 0.28 lb/hr using 3-hour rolling average
PM2.5 ≤ 0.10 lb/hr using 3-hour rolling average
Title I Condition: to avoid classification as a major source and modification under 40 CFR 52.21 and Minn. R. 7007.3000; Minn. Stat. Section 116.07, subds. 4a & 9; Minn. R. 7007.0100, subp. 7(A), 7(L), & 7(M); Minn. R. 7007.0800, subps. 1, 2 & 4; Minn. R. 7009.0010-7009.0080	See TREA 29.	This permit contains a requirement to vent emissions from EQUI 3 to TREA 29 at all times EQUI 3 is operating. See TREA 29 for additional monitoring and recordkeeping requirements for EQUI 3.	
	PM ≤ 0.34 lb/hr using 3-hour rolling average
Title I Condition: to avoid classification as a major source and modification under 40 CFR 52.21 and Minn. R. 7007.3000; Minn. Stat. Section 116.07, subds. 4a & 9; Minn. R. 7007.0100, subp. 7(A), 7(L), & 7(M); Minn. R. 7007.0800, subps. 1, 2 & 4; Minn. R. 7009.0010-7009.0080	See TREA 29.	This permit contains a requirement to vent emissions from EQUI 3 to TREA 29 at all times EQUI 3 is operating. See TREA 29 for additional monitoring and recordkeeping requirements for EQUI 3.	
	PM ≤ 0.30 gr/dscf using 3-hour rolling average 
Opacity ≤ 20 percent
Minn. R. 7011.0715, subp. 1(A) & 1(B)	See TREA 29.	This permit contains a requirement to vent emissions from EQUI 3 to TREA 29 at all times EQUI 3 is operating. See TREA 29 for additional monitoring and recordkeeping requirements for EQUI 3.	
EQUI 4/ TREA 26/ STRU 21
Ring/Blood Dryer	PM10 ≤ 1.3 lb/hr using 3-hour rolling average
PM2.5 ≤ 0.78 lb/hr using 3-hour rolling average
Title I Condition: to avoid classification as a major source and modification under 40 CFR 52.21 and Minn. R. 7007.3000; Minn. Stat. Section 116.07, subds. 4a & 9; Minn. R. 7007.0100, subp. 7(A), 7(L), & 7(M); Minn. R. 7007.0800, subps. 1, 2 & 4; Minn. R. 7009.0010-7009.0080	Performance tests are required for PM10 and PM2.5 to confirm emission factors and demonstrate compliance with modeled values. 
Also see TREA 26.	The permit limit reflects the emission factors derived from AP-42. This limit was revised from 0.74 lb/hr to reflect the calculated potential to emit of EQUI 4.
(This revision was included in the EBD modeling analysis prepared for this permit action.)	
	PM ≤ 0.30 gr/dscf using 3-hour rolling average of exhaust gas unless required to further reduce emissions to comply with the less stringent limit of either Minn. R. 7011.0730 or Minn. R. 7011.0735.
Opacity ≤ 20 percent except for one six-minute period per hour of not more than 60 percent opacity
Minn. R. 7011.0610, subp. 1(A)	See TREA 26.	This permit contains a requirement to vent emissions from EQUI 4 to TREA 26 at all times EQUI 4 is operating. See TREA 26 for additional monitoring and recordkeeping requirements for EQUI 4.	
	Sulfur content of No. 2 fuel oil ≤ 0.05 percent by weight
Title I Condition: To restrict facility emissions below New Source Review thresholds; Minn. R. 7007.0800, subp. 2	Supplier certification of fuel sulfur content 	Boilers No. 2 (EQUI 5) and No. 3 (EQUI 10) must comply with the New Source Performance Standard for Small Industrial-Commercial-Institutional Steam Generating Units (40 CFR 60, Subpart Dc), including the requirement to acquire a supplier certification for the fuel oil that they burn. The fuel oil entering the facility is used by all combustion units. Thus, Sanimax must acquire a supplier certification for the fuel oil used by this boiler. That certification is sufficient to demonstrate compliance at this emission unit.	
	Sulfur dioxide ≤ 2.0 lb/MMBtu
Minn. R. 7007.0610	Supplier certification of fuel sulfur content	A certified fuel sulfur content of 0.05 percent by weight is sufficient to assure compliance with the state standard.	
EQUI 5/ STRU 25
Boiler No. 2	PM10 ≤ 0.29 lb/hr using 3-hour rolling average
PM2.5 ≤ 0.19 lb/hr using 3-hour rolling average
Title I Condition: to avoid classification as a major source and modification under 40 CFR 52.21 and Minn. R. 7007.3000; Minn. Stat. Section 116.07, subds. 4a & 9; Minn. R. 7007.0100, subp. 7(A), 7(L), & 7(M); Minn. R. 7007.0800, subps. 1, 2 & 4; Minn. R. 7009.0010-7009.0080	None	The permit limit reflects the emission factor derived from AP-42. The PM2.5 limit was revised from 0.030 lb/hr to reflect the calculated potential to emit of EQUI 5. 
(This revision was included in the EBD modeling analysis prepared for this permit action.)	
	Sulfur content of No. 2 fuel oil ≤ 0.05 percent by weight
Title I Condition: To restrict facility emissions below New Source Review thresholds; Minn. R. 7007.0800, subp. 2	Supplier certification of fuel sulfur content 	The monitoring and reporting requirements of the NSPS are sufficient to demonstrate compliance with this limit.	
	Sulfur content of other liquid fuel ≤ 0.10 percent by weight
Title I Condition: To restrict facility emissions below New Source Review thresholds; Minn. R. 7007.0800, subp. 2	Supplier certification of fuel sulfur content 	The monitoring and reporting requirements of the NSPS are sufficient to demonstrate compliance with this limit.	
	Sulfur content of liquid fuels ≤ 0.50 weight % or  ≤ 0.50 lb/MMBtu
40 CFR pt. 60, subp. Dc	Supplier certification of fuel sulfur content	Since a fuel sulfur content of 0.10 percent by weight for the fuels allowed is a maximum of 0.055 lb SO2/MMBtu, compliance with the fuel sulfur requirement is sufficient to assure compliance with the state standard.	
	PM ≤ 0.40 lb/million Btu heat input 3-hour rolling average 
Opacity ≤ 20 percent except for one six-minute period per hour of not more than 60 percent opacity
Minn. R. 7011.0515, subps. 1 & 2	None	Since residual fuel oil has been eliminated, the allowable PM emissions from this unit are expected to ~0.4 lb/hr. This is well below the 7.0 lb/hr allowed by this PM limit. At this emission level, no monitoring is needed.	
EQUI 8/ TREA 30/ STRU 15 
PPF Pressing	PM10 ≤ 0.38 lb/hr using 3-hour rolling average
PM2.5 ≤ 0.22 lb/hr using 3-hour rolling average
Title I Condition: to avoid classification as a major source and modification under 40 CFR 52.21 and Minn. R. 7007.3000; Minn. Stat. Section 116.07, subds. 4a & 9; Minn. R. 7007.0100, subp. 7(A), 7(L), & 7(M); Minn. R. 7007.0800, subps. 1, 2 & 4; Minn. R. 7009.0010-7009.0080	See TREA 30.	This permit contains a requirement to vent emissions from EQUI 8 to TREA 30 at all times EQUI 8 is operating. See TREA 30 for additional monitoring and recordkeeping requirements for EQUI 8.	
	PM ≤ 0.30 gr/dscf using 3-hour rolling average 
Opacity ≤ 20 percent
Minn. R. 7011.0715, subp. 1(A) & 1(B)	See TREA 30.	This permit contains a requirement to vent emissions from EQUI 8 to TREA 30 at all times EQUI 8 is operating. See TREA 30 for additional monitoring and recordkeeping requirements for EQUI 8.	
EQUI 9/ TREA 30/ STRU 16 
PPF Milling	PM10 ≤ 0.14 lb/hr using 3-hour rolling average
PM2.5 ≤ 0.050 lb/hr using 3-hour rolling average
Title I Condition: to avoid classification as a major source and modification under 40 CFR 52.21 and Minn. R. 7007.3000; Minn. Stat. Section 116.07, subds. 4a & 9; Minn. R. 7007.0100, subp. 7(A), 7(L), & 7(M); Minn. R. 7007.0800, subps. 1, 2 & 4; Minn. R. 7009.0010-7009.0080	See TREA 30.	This permit contains a requirement to vent emissions from EQUI 9 to TREA 30 at all times EQUI 9 is operating. See TREA 30 for additional monitoring and recordkeeping requirements for EQUI 9.	
	PM ≤ 0.30 gr/dscf using 3-hour rolling average 
Opacity ≤ 20 percent
Minn. R. 7011.0715, subp. 1(A) & 1(B)	See TREA 30.	This permit contains a requirement to vent emissions from EQUI 9 to TREA 30 at all times EQUI 9 is operating. See TREA 30 for additional monitoring and recordkeeping requirements for EQUI 9.	
EQUI 10/ STRU 16 
Boiler No. 3	PM2.5 ≤ 1.28 lb/hr
Minn. Stat. Section 116.07, subds. 4a & 9; Minn. R. 7007.0100, subp. 7(A), 7(L), & 7(M); Minn. R. 7007.0800, subps. 1, 2 & 4; Minn. R. 7009.0010-7009.0080	None	The permit limit reflects the emission factor derived from AP-42.	
	Sulfur content of No. 2 fuel oil ≤ 0.05 percent by weight
Title I Condition: To restrict facility emissions below New Source Review thresholds; Minn. R. 7007.0800, subp. 2	Supplier certification of fuel sulfur content required by 40 CFR pt. 60, subp. Dc	The monitoring and reporting requirements of the NSPS are sufficient to demonstrate compliance with this limit.	
	Sulfur content of other liquid fuel ≤ 0.10 percent by weight
Title I Condition: To restrict facility emissions below New Source Review thresholds; Minn. R. 7007.0800, subp. 2	Supplier certification of fuel sulfur content 	The monitoring and reporting requirements of the NSPS are sufficient to demonstrate compliance with this limit.	
	Sulfur content of No. 2 fuel oil ≤ 0.50 weight % or 0.50 lb/MMBtu
40 CFR pt. 60, subp. Dc 	Supplier certification of fuel sulfur content required by 40 CFR pt. 60, subp. Dc	The monitoring and reporting requirements of the NSPS are sufficient.	
	Sulfur content of No. 2 fuel oil ≤ 0.50 weight %
40 CFR pt. 63, subp. JJJJJJ	Supplier certification of fuel sulfur content required by 40 CFR pt. 60, subp. Dc	The monitoring and reporting requirements of the NSPS are sufficient to demonstrate compliance with this limit.	
	Opacity ≤20%, except for one 6-minute period per hour of not more than 27 percent opacity.
40 CFR pt. 60, subp. Dc	Initial and subsequent opacity tests required by 40 CFR pt. 60, subp. Dc	The monitoring and reporting requirements of the NSPS are sufficient.	
EQUI 18/ TREA 35/ STRU 20
Feather Pneumatic Conveying System	PM10 ≤ 0.010 lb/hr using 3-hour rolling average
PM2.5 ≤ 0.010 lb/hr using 3-hour rolling average
Title I Condition: to avoid classification as a major source and modification under 40 CFR 52.21 and Minn. R. 7007.3000; Minn. Stat. Section 116.07, subds. 4a & 9; Minn. R. 7007.0100, subp. 7(A), 7(L), & 7(M); Minn. R. 7007.0800, subps. 1, 2 & 4; Minn. R. 7009.0010-7009.0080	See TREA 35.	This permit contains a requirement to vent emissions from EQUI 18 to TREA 35 at all times EQUI 18 is operating. See TREA 35 for additional monitoring and recordkeeping requirements for EQUI 18.	
	PM ≤ 0.30 gr/dscf using 3-hour rolling average 
Opacity ≤ 20 percent
Minn. R. 7011.0715, subp. 1(A) & 1(B)	See TREA 35.	This permit contains a requirement to vent emissions from EQUI 18 to TREA 35 at all times EQUI 18 is operating. See TREA 35 for additional monitoring and recordkeeping requirements for EQUI 18.	
EQUI 19/ STRU 14
Boiler No. 1	PM10 ≤ 1.8 lb/hr using 3-hour rolling average
PM2.5 ≤ 1.1 lb/hr using 3-hour rolling average
Title I Condition: to avoid classification as a major source under 40 CFR Section 52.21 and Minn. R. 7007.3000; Minn. Stat. Section 116.07, subds. 4a & 9; Minn. R. 7007.0100, subp. 7(A), 7(L), & 7(M); Minn.R. 7007.0800, subps. 1, 2, & 4; Minn. R. 7009.0010-7009.0800	None	The PM10 and PM2.5 emission limits are set at the potentials to emit of EQUI 19, so no monitoring is needed.	
	PM ≤ 0.40 lb/million Btu heat input using 3-hour rolling average 
Opacity ≤ 20 percent except for one six-minute period per hour of not more than 60 percent opacity
Minn. R. 7011.0515, subps. 1 & 2	None	Since residual fuel oil has been eliminated, the allowable PM emissions from this unit are expected to ~2.3 lb/hr. This is well below the 20 lb/hr allowed by this PM limit. At this emission level, no monitoring is needed.	
	Sulfur content of No. 2 fuel oil ≤ 0.05 percent by weight
Title I Condition: To restrict facility emissions below New Source Review thresholds; Minn. R. 7007.0800, subp. 2	Supplier certification of fuel sulfur content 	Boilers No. 2 (EQUI 5) and No. 3 (EQUI 10) must comply with the New Source Performance Standard for Small Industrial-Commercial-Institutional Steam Generating Units (40 CFR 60, Subpart Dc), including the requirement to acquire a supplier certification for the fuel oil that they burn. The fuel oil entering the facility is used by all combustion units. Thus, Sanimax must acquire a supplier certification for the fuel oil used by this boiler. That certification is sufficient to demonstrate compliance at this emission unit.	
	Sulfur content of other liquid fuel ≤ 0.10 percent by weight
Title I Condition: To restrict facility emissions below New Source Review thresholds; Minn. R. 7007.0800, subp. 2	Supplier certification of fuel sulfur content 	Boilers No. 2 (EQUI 5) and No. 3 (EQUI 10) must comply with the New Source Performance Standard for Small Industrial-Commercial-Institutional Steam Generating Units (40 CFR 60, Subpart Dc), including the requirement to acquire a supplier certification for the fuel that they burn. The fuel entering the facility is used by all combustion units. Thus, Sanimax must acquire a supplier certification for the fuel used by this boiler. That certification is sufficient to demonstrate compliance at this emission unit.	
	Sulfur dioxide ≤ 2.0 lb/MMBtu
Minn. R. 7007.0515, subp. 1	Supplier certification of fuel sulfur content	Based on the fuels that potentially could be used (distillate fuel oil, glycerin, and RAFVO), a fuel sulfur content of 0.10 percent by weight is, at most,  equivalent to 0.33 lb SO2/MMBtu, compliance with the fuel sulfur requirement is sufficient to assure compliance with the state standard.	
EQUI 20/ TREA 27/ STRU 22
Protein Recovery Facility (PRF)	PM10 ≤ 1.0 lb/hr using 3-hour rolling average
PM2.5 ≤ 0.97 lb/hr using 3-hour rolling average
Title I Condition: to avoid classification as a major source and modification under 40 CFR 52.21 and Minn. R. 7007.3000; Minn. Stat. Section 116.07, subds. 4a & 9; Minn. R. 7007.0100, subp. 7(A), 7(L), & 7(M); Minn. R. 7007.0800, subps. 1, 2 & 4; Minn. R. 7009.0010-7009.0080	See TREA 27. 
Performance tests to confirm emission factors.	The permit limits reflects the emission factors derived from AP-42 (reflecting enforceable controls) and stack tests at other facilities. An initial performance test for each pollutant (PM10 and PM2.5) is needed to confirm these factors.
This permit contains a requirement to vent emissions from EQUI 20 to TREA 27 at all times EQUI 20 is operating. See TREA 27 for additional monitoring and recordkeeping requirements for EQUI 20.	
	PM ≤ 0.30 gr/dscf 
Opacity ≤ 20 percent
Minn. R. 7011.0715, subp. 1(A) & 1(B)	See TREA 27.	This permit contains a requirement to vent emissions from EQUI 20 to TREA 27 at all times EQUI 20 is operating. See TREA 27 for additional monitoring and recordkeeping requirements for EQUI 20.	
EQUI 21/ TREA 31 & TREA 34/ STRU 19
Blood Pneumatic Conveying System	PM10 ≤ 0.0050 lb/hr using 3-hour rolling average
PM2.5 ≤ 0.0050 lb/hr using 3-hour rolling average
Title I Condition: to avoid classification as a major source and modification under 40 CFR 52.21 and Minn. R. 7007.3000; Minn. Stat. Section 116.07, subds. 4a & 9; Minn. R. 7007.0100, subp. 7(A), 7(L), & 7(M); Minn. R. 7007.0800, subps. 1, 2 & 4; Minn. R. 7009.0010-7009.0080	See TREA 31 and TREA 34.	This permit contains a requirement to vent emissions from EQUI 21 to TREA 31 or TREA 34 at all times. See TREA 31 and TREA 34 for additional monitoring and recordkeeping requirements for EQUI 21.	
	PM ≤ 0.30 gr/dscf 
Opacity ≤ 20 percent
Minn. R. 7011.0715, subp. 1(A) & 1(B)	See TREA 31 and TREA 34.	This permit contains a requirement to vent emissions from EQUI 21 to TREA 31 or TREA 34 at all times. See TREA 31 and TREA 34 for additional monitoring and recordkeeping requirements for EQUI 21.	
EQUI 66/ TREA 30/ STRU 15 
PPF Cooking	PM10 ≤ 1.4 lb/hr using 3-hour rolling average
PM2.5 ≤ 0.77 lb/hr using 3-hour rolling average
Title I Condition: to avoid classification as a major source and modification under 40 CFR 52.21 and Minn. R. 7007.3000; Minn. Stat. Section 116.07, subds. 4a & 9; Minn. R. 7007.0100, subp. 7(A), 7(L), & 7(M); Minn. R. 7007.0800, subps. 1, 2 & 4; Minn. R. 7009.0010-7009.0080	See TREA 30.	This permit contains a requirement to vent emissions from EQUI 66 to TREA 30 at all times EQUI 66 is operating. See TREA 30 for additional monitoring and recordkeeping requirements for EQUI 66.	
	PM ≤ 0.30 gr/dscf using 3-hour rolling average 
Opacity ≤ 20 percent
Minn. R. 7011.0715, subp. 1(A) & 1(B)	See TREA 30.	This permit contains a requirement to vent emissions from EQUI 66 to TREA 30 at all times EQUI 66 is operating. See TREA 30 for additional monitoring and recordkeeping requirements for EQUI 66.	
TREA 26
Blood Process Venturi Scrubber	Control efficiency for PM ≥ 90 percent
Control efficiency for PM10 ≥ 90 percent
Control efficiency for PM2.5 ≥ 90 percent
Pressure drop ≥ 4.0 inches and ≤ 6.0 inches of water column
Flow rate ≥ 48 gallons/minute
Title I Condition: to avoid classification as a major source under 40 CFR Section 52.21 and Minn. R. 7007.3000; Minn. R. 7007.0800, subps. 2 and 14	Daily monitoring of visible emissions, pressure drop, and liquid flow rate
Quarterly inspections of TREA 26’s components.
Daily records of visible emissions inspections, pressure drop, and flow rate. Quarterly records of inspections of TREA 26’s components.	TREA 26 must operate properly to ensure compliance with the limits to avoid 40 CFR § 52.21. The permit contains a requirement to operate, monitor and maintain TREA 26 to ensure compliance with the limits.	
TREA 27
PRF Venturi Scrubber	Control efficiency for PM ≥ 90 percent
Control efficiency for PM10 ≥ 90 percent
Control efficiency for PM2.5 ≥ 90 percent
Pressure drop ≥ 4.0 inches and ≤ 6.0 inches of water column
Flow rate ≥ 16 gallons/minute
Title I Condition: to avoid classification as a major source under 40 CFR Section 52.21 and Minn. R. 7007.3000; Minn. R. 7007.0800, subps. 2 and 14	Daily monitoring of visible emissions, pressure drop, and liquid flow rate
Quarterly inspections of TREA 27’s components.
Daily records of visible emissions inspections, pressure drop, and flow rate. Quarterly records of inspections of TREA 27’s components.	TREA 27 must operate properly to ensure compliance with the limits to avoid 40 CFR § 52.21. The permit contains a requirement to operate, monitor and maintain TREA 27 to ensure compliance with the limits.	
TREA 28
Venturi Scrubber	Control efficiency for PM ≥ 90 percent
Control efficiency for PM10 ≥ 90 percent
Control efficiency for PM2.5 ≥ 90 percent
Pressure drop ≥ 3.5 inches and ≤ 7.0 inches of water column
Flow rate ≥ 65 gallons/minute
Title I Condition: to avoid classification as a major source under 40 CFR Section 52.21 and Minn. R. 7007.3000; Minn. R. 7007.0800, subps. 2 and 14	Daily monitoring of visible emissions, pressure drop, and liquid flow rate
Quarterly inspections of TREA 28’s components.
Daily records of visible emissions inspections, pressure drop, and flow rate. Quarterly records of inspections of TREA 28’s components.	TREA 28 must operate properly to ensure compliance with the limits to avoid 40 CFR § 52.21. The permit contains a requirement to operate, monitor and maintain TREA 28 to ensure compliance with the limits.	
TREA 29
Continuous Milling System and Associated Control Equipment	Control efficiency for PM ≥ 90 percent
Control efficiency for PM10 ≥ 90 percent
Control efficiency for PM2.5 ≥ 90 percent
Title I Condition: to avoid classification as a major source under 40 CFR Section 52.21 and Minn. R. 7007.3000; Minn. R. 7007.0800, subps. 2 and 14	Daily checks of visible emissions and operation of broken bag detector during daylight hours; implementation of corrective actions if needed
Quarterly (or more frequent, per manufacturer) inspection of components	Daily checks for VEs and broken bags and quarterly inspection of component ensures that the company is conducting proper operation and maintenance.
This permit contains a requirement to vent emissions from EQUI 3 to TREA 29 at all times EQUI 3 is operating. EQUI 3 is also subject to particulate emission limits. Compliance with those limits and proper operation and maintenance ensures that the control efficiencies are met. (It is not practical to test inlet and outlet loading of the control device.) 	
TREA 30
PPF Venturi Scrubber	Control efficiency for PM ≥ 90 percent
Control efficiency for PM10 ≥ 90 percent
Control efficiency for PM2.5 ≥ 90 percent
Pressure drop ≥ 2.0 inches and ≤ 9.0 inches of water column
Flow rate ≥ 60 gallons/minute
Title I Condition: to avoid classification as a major source under 40 CFR Section 52.21 and Minn. R. 7007.3000; Minn. R. 7007.0800, subps. 2 and 14	Daily monitoring of visible emissions, pressure drop, and liquid flow rate
Quarterly inspections of TREA 30’s components.
Daily records of visible emissions inspections, pressure drop, and flow rate. Quarterly records of inspections of TREA 30’s components.	TREA 30 must operate properly to ensure compliance with the limits to avoid 40 CFR § 52.21. The permit contains a requirement to operate, monitor and maintain TREA 30 to ensure compliance with the limits.	
TREA 31
Blood System Fabric Filter	Control efficiency for PM ≥ 99 percent
Control efficiency for PM10 ≥ 99 percent
Control efficiency for PM2.5 ≥ 99 percent
Title I Condition: to avoid classification as a major source under 40 CFR Section 52.21 and Minn. R. 7007.3000; Minn. R. 7007.0800, subps. 2 and 14	Daily monitoring of visible emissions and broken bag detectors.
Quarterly inspections of TREA 31’s components.
Daily records of visible emissions inspections and broken bag detector reading and quarterly records of inspections of TREA 31’s components.	TREA 31 must operate properly to ensure compliance with the limits to avoid 40 CFR § 52.21. The permit contains a requirement to operate, monitor and maintain TREA 31 to ensure compliance with the limits.
This permit contains a requirement to vent emissions from EQUI 21 to TREA 31 and TREA 34 at all times EQUI 21 is operating.
	
TREA 32
Protein Silo Fabric Filter	Control efficiency for PM ≥ 99 percent
Control efficiency for PM10 ≥ 99 percent
Control efficiency for PM2.5 ≥ 99 percent
Title I Condition: to avoid classification as a major source under 40 CFR Section 52.21 and Minn. R. 7007.3000; Minn. R. 7007.0800, subps. 2 and 14	Daily monitoring of visible emissions and broken bag detectors.
Quarterly inspections of TREA 32’s components.
Daily records of visible emissions inspections and broken bag detector reading and quarterly records of inspections of TREA 32’s components.	TREA 32 must operate properly to ensure compliance with the limits to avoid 40 CFR § 52.21. The permit contains a requirement to operate, monitor and maintain TREA 32 to ensure compliance with the limits.
	
TREA 33
Protein Silo Fabric Filter	Control efficiency for PM ≥ 99 percent
Control efficiency for PM10 ≥ 99 percent
Control efficiency for PM2.5 ≥ 99 percent
Title I Condition: to avoid classification as a major source under 40 CFR Section 52.21 and Minn. R. 7007.3000; Minn. R. 7007.0800, subps. 2 and 14	Daily monitoring of visible emissions and broken bag detectors.
Quarterly inspections of TREA 33’s components.
Daily records of visible emissions inspections and broken bag detector reading and quarterly records of inspections of TREA 33’s components.	TREA 33 must operate properly to ensure compliance with the limits to avoid 40 CFR § 52.21. The permit contains a requirement to operate, monitor and maintain TREA 33 to ensure compliance with the limits.
	
TREA 34
Blood System Fabric Filter	Control efficiency for PM ≥ 99 percent
Control efficiency for PM10 ≥ 99 percent
Control efficiency for PM2.5 ≥ 99 percent
Title I Condition: to avoid classification as a major source under 40 CFR Section 52.21 and Minn. R. 7007.3000; Minn. R. 7007.0800, subps. 2 and 14	Daily monitoring of visible emissions and broken bag detectors.
Quarterly inspections of TREA 34’s components.
Daily records of visible emissions inspections and broken bag detector reading and quarterly records of inspections of TREA 34’s components.	TREA 34 must operate properly to ensure compliance with the limits to avoid 40 CFR § 52.21. The permit contains a requirement to operate, monitor and maintain TREA 34 to ensure compliance with the limits.
This permit contains a requirement to vent emissions from EQUI 21 to TREA 31 and TREA 34 at all times EQUI 21 is operating.
	
TREA 35
Feather System Fabric Filter (LT)	Control efficiency for PM ≥ 99 percent
Control efficiency for PM10 ≥ 99 percent
Control efficiency for PM2.5 ≥ 99 percent
Operate broken bag detector
Title I Condition: to avoid classification as a major source under 40 CFR Section 52.21 and Minn. R. 7007.3000; Minn. R. 7007.0800, subps. 2 and 14	Daily monitoring of visible emissions and broken bag detector
Quarterly inspections of TREA 35’s components.
Daily records of visible emissions inspections and broken bag detector readings. Quarterly records of inspections of TREA 35’s components.	TREA 35 must operate properly to ensure compliance with the limits to avoid 40 CFR § 52.21. The permit contains a requirement to operate, monitor and maintain TREA 35 to ensure compliance with the limits.	
*Location of the requirement in the permit (e.g., EQUI, STRU, COMG, etc.).
3.8	Insignificant Activities
This permit action does not authorize any new insignificant activities. However, Sanimax has several operations classified as insignificant activities under the MPCA’s permitting rules. These are listed in Appendix A to the permit. 
Many small natural gas space and line heaters and one small kerosene hot water washer are used at the facility. The emission calculations show that the equipment qualifies as insignificant under either Minn. R. 7007.1300, subps. 3(I)(2) or 4(B). Emission calculations are included in Attachment 1.
The emission calculations show that the vegetable oil recovery processes qualify as insignificant activities under Minn. R. 7007.1300, subp. 4(B). Emission calculations are included in Attachment 1.
The permit is required to include periodic monitoring for all emissions units, including insignificant activities, per EPA guidance. The insignificant activities at this facility are only subject to general applicable requirements. Using the criteria outlined earlier in this TSD, the following table documents the justification why no additional periodic monitoring is necessary for the insignificant activities currently located at this site. 
Table 7. Insignificant Activities
Insignificant Activity	General Applicable Emission limit	Discussion	
Fuel use: space heaters fueled by, kerosene, natural gas, or propane.	PM < 0.40 lb/mmBtu
Opacity < 20 %
SO2 < 4 lb/mmBtu
Minn. R. 7011.0515	Based on the fuels used and EPA published emissions factors, it is highly unlikely that these units could violate the applicable requirement. In addition, these units would be operated and vented inside a building, so testing for PM or opacity is not feasible.	
Brazing, soldering or welding equipment	PM, variable depending on airflow
Opacity < 20%
Minn. R. 7011.0715	Based on EPA published emissions factors, it is highly unlikely that these units could violate the applicable requirement. In addition, these units are operated and vented inside a building, so testing for PM or opacity is not feasible.	
Cleaning operations: alkaline/phosphate cleaners and associated cleaners and associated burners	PM, variable depending on airflow
Opacity < 20%
Minn. R. 7011.0610,  Minn. R. 7011.0715	Some emission factors are available for the burners, but very little information is available regarding the cleaning operation. However, based on general knowledge of their operation, it is unlikely that they would violate the applicable requirement or that testing would be feasible.	
Individual emissions units, each of which have a potential to emit the following pollutants in amounts less than:
1. 2 tpy of CO; and
2. 1 tpy each of NOx, SO2, PM/PM10, and VOC (including HAP –containing VOC)	PM, variable depending on airflow
Opacity < 20%
Minn. R. 7011.0715	These insignificant activities are the inside and outside storage tanks, a kerosene hot water washer, and the loadout housekeeping vacuum system. Most of these units are not expected to generate particulate matter. Because kerosene is clean enough to burn indoors, it is highly unlikely that the hot water washer could violate the applicable requirement. In addition, most of these units are operated and vented inside a building, so testing for PM or opacity is not feasible.	
Individual emissions units that have actual emissions of < 1 ton per year of the criteria pollutants, and for hazardous air pollutants, emissions units with potential emissions of 25 percent or less of the hazardous air pollutant thresholds listed in Minn. R 7007.1300, subp. 5.	PM, variable depending on airflow
Opacity < 20%
SO2 < 4 lb/mmBtu
Minn. R. 7011.0715	These insignificant activities are the vegetable oil recovery process and the natural gas line heaters. Given the highly conservative approach used to estimate their particulate emissions and a general knowledge of their operation, it is unlikely that they could violate the applicable requirement. By burning only natural gas, the Permittee ensures that the emissions from these units remain well below the limits of the applicable rule.	
3.9	Permit Organization 
This permit action marks the transition of Sanimax’s air quality permit from the MPCA’s Delta permitting system to the Tempo 360 permitting system. The MPCA migrated data from Delta – including the description of the facility (e.g., emission units, stack/vents, and groups) and permit text – to Tempo. In the migration, items were renamed and are now identified differently. Table 8 shows the relationship of the items as identified in Delta to their new names in Tempo.
Table 8. Relationship of Delta ID Numbers to Tempo Subject Items
Delta ID No.	Tempo Subject Item		Delta ID No.	Tempo Subject Item	
Emission Unit	Equipment		Control Equipment	Treatment	
EU 001	EQUI 19		CE 001	TREA 26	
EU 002	EQUI 4		CE 003	TREA 27	
EU 003	EQUI 20		CE 006	TREA 31	
EU 005	EQUI 21		CE 009	TREA 35	
EU 006	EQUI 5		CE 010	TREA 32	
EU 009	EQUI 1		CE 011	TREA 33	
EU 010	EQUI 2		CE 012	TREA 28	
EU 011	EQUI 3		CE 014	TREA 34	
EU 012	EQUI 16		CE 016	TREA 29	
EU 013	EQUI 17		CE 025	TREA 30	
EU 014	EQUI 18				
EU 020	EQUI 66		Delta ID No.	Tempo Subject Item	
EU 021	EQUI 8		Stack or Vent	Structure	
EU 022	EQUI 9		SV 001	STRU 14	
EU 023	EQUI 10		SV 002	STRU 21	
			SV 003	STRU 22	
Delta ID No.	Tempo Subject Item		SV 005	STRU 19	
Group	Component Group		SV 006	STRU 25	
GP 001	COMG 2		SV 009	STRU 26	
GP 002	COMG 4		SV 010	STRU 27	
GP 003	COMG 7		SV 012	STRU 24	
GP 004	COMG 5		SV 014	STRU 20	
GP 005	COMG 6		SV 018	STRU 15	
GP 007	COMG 1		SV 020	STRU 16	

In general, the permit meets the MPCA Guidance for ordering and grouping of requirements. However, the Technical Support Document is based on the Delta template instead of the Tempo version, since the TSD was already in development. 
3.10	Comments Received
Public Notice Period: February 19, 2016 – March 21, 2016
No comments were received during the public notice period. 
4.	Permit Fee Assessment
Attachment 3 to this TSD contains the MPCA’s assessment of Application and Additional Points used to determine the permit application fee for this permit action as required by Minn. R. 7002.0019. Fees are required because the permit action includes a major permit application that was received after the effective date of the rule (July 1, 2009).
This permit action responds to an application for a major permit amendment submitted May 7, 2013 and to an application for an administrative amendment submitted February 9, 2015. There is an additional fee of 50 points under the “Application Type” because this is the first individual state permit that will be issued to Sanimax. The permit action also includes the incorporation of an NSPS and a NESHAP (10 points each), a modeling review (15 points) and limits to keep the facility below the PSD major source threshold (10 points) and the Part 70 threshold (10 points). This results in a total of 105 additional points. 
5.	Conclusion
Based on the information provided by Sanimax USA, LLC, the MPCA has reasonable assurance that the operation of the emission facility, as described in the Air Emission Permit No. 03700070-007 and this TSD, will not cause or contribute to a violation of applicable federal regulations and Minnesota Rules.
Staff Members on Permit Team:	Tyler Johnson (permit engineer)
Richard Cordes (permit engineer)
Daniel Dietrich (enforcement)
Curt Stock (compliance)
Jim Sullivan (modeling)
Amrill Okonkwo (peer reviewer) 
Beckie Olson (permit writing assistant)
Laurie O’Brien (administrative support)

AQ File No. 578; DQ #4268; DQ #4278; DQ #5089; DQ #5103
Attachments: 	1.	PTE Summary and Emissions Calculation
2.	Points Calculator
3.	Sanimax Memorandum: Use of Refined Animal Fats and Glycerin as Boiler Fuels
4.	Subject Item Details Inventory
5.	Requirements Development Report

Attachment 1 – PTE Summary and Emissions Calculations

Attachment 2 – Points Calculator

Attachment 3 – Sanimax Memorandum
Use of Refined Animal Fats and Glycerin as Boiler Fuels

Attachment 4 – Subject Item Details Inventory

Attachment 5 – Requirements Development Report