Letter to MN officials about ADM Red Wing air permit

To:         jacobe.timler@state.mn.us

From:    Alan Muller <amuller@dca.net>

Subject: ADM air permit public notice

CC:         Kathleen.Winters@state.mn.us, “Carol A. Overland” <overland@legalectric.org>, Ruth.greenslade@co.goodhue.mn.us, john.stine@state.mn.us, ed.ehlinger@state.mn.us, Anne     Jacobson<ajacobson@republican-eagle.com>

May 10, 20717

Jacobe Timler
Industrial Division. Minnesota Pollution Control Agency
520 Lafayette Rd
St. Paul, MN 55155
Phone: 651-757-2410
Email: jacobe.timler@state.mn.us

Dear Mr. Timler:

I am a resident of Red Wing and am reviewing the:

“Public Notice of Intent to Modify Air Permit 04900001-101” dated May 4, 2017, for the subject ADM facility in Red Wing.

These are initial questions and comments:

Please provide a copy of the “Consent Decree” referenced in various places in the Technical Support Document.

The expiration date of the permit is February 28, 2011.  I question the appropriateness of modifications to a long-expired permit.  Can the MPCA provide assurances that the long-expired permit, as modified in the current action, would comply with all current State and Federal laws, regulations, rules, and agency guidance, and be adequately protective of the community?

The Technical Support Document (TSD), at page 1, states:

“The facility emits particulate matter (PM), particulate matter less than 10 microns in size (PM10), PM less than 2.5 microns in size (PM2.5), volatile organic compounds (VOC), sulfur dioxide (SO2), carbon monoxide (CO), nitrogen oxides (NOx) and hazardous air pollutants (HAPs). PM/PM10/PM2.5 emissions are emitted from the handling and processing of the seeds, the meal system, and the refinery. PM/PM10/PM2.5, SO2, CO, NOx, and VOC emissions are emitted from the boilers. Hexane emissions (which are both VOC and HAP emissions) are released from the hexane extraction and recovery systems. The facility is a major source under federal New Source Review (NSR), the federal Operating Permit Program (40 CFR pt. 70), and federal National Emission Standards for Hazardous Air Pollutants (NESHAPs, 40 CFR pt. 63).”

Has any ambient or fenceline monitoring been conducted to ensure compliance with air quality standards?

Have the cumulative impacts of this facility and others in the area been evaluated?

Has a Health Impact Analysis of this facility every been conducted?

Some of the emissions from this may be allergens, soybean particulate, etc.   Has this been evaluated for possible health and quality of life impacts?

The TSD also states at page one that:

“Due to the time-sensitive nature of this project, this amendment will be issued in stages. The first stage (Stage 1) of the issuance will include the NSR portion of the permit (construction authorization and Title I requirements) while the second and final stage (Stage 2) will include the Part 70 portion of the permit (operating and periodic monitoring requirements). This effectively allows the Permittee to complete the construction-portion of this project during EPA review. The second stage (facility operation) will be issued following EPA review.”

What makes this project “time sensitive” in the eyes of the MPCA?

I am concerned about the statement “allows the Permittee to complete the construction-portion of this project during EPA review.”  Construction should not be allowed to commence, let alone be completed, until the permitting process has gone to conclusion.  Does the MPCA consider the EPA review an insignificant formality?

Please provide the name and contact information for the Region 5 staff who will be/are reviewing this permit.

At page 88 of the TSD (as pages are counted by the PDF viewer) begins a long series of line items entitles “PTE [Potential to Emit] by subject item.”  The column headings are not aligned, but there seem to be entries for “Unrestricted Potential” and “Limited Potential.”  In a great many cases the “Limited Potential” is given as zero.  Just to pick one example, at page 95, emissions of “particulate matter” (undefined?) from “Bins/Harvestore” are given as 279 tons/year (“unrestricted”) and 0 (zero) “limited.”  Since few if any air pollution control measures or devices are 100 percent effective, all these zeros seem questionable to me, and need further explanation and/or correction.

Neither the Public Notice nor the Draft Permit nor the TDS contains any summary of the total emissions of the facility.  (The large emissions of Hexane, for example).  This fails, in my opinion, to give reasonable, good-faith notice to the public of why this permit action/this facility might be of interest from an air quality point of view.

In view of the issues raised by even my cursory review of the Public Notice, the Draft Permit, and the Technical Support Document, the public comment period may need to be extended, else a Public Information Meeting may be needed.

Yours very truly,

Alan Muller
1110 West Avenue
Red Wing, MN, 55066

Alan Muller
Energy & Environmental Consulting
Red Wing, MN
Port Penn, DE

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