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Minutes of the Regular Council Meeting, January 25, 1988 Page 2 KEM MILLING (CONT'D) 4. What time frame is there for compliance with MPCA rules and regulations? Liefert advised the MPCA will expect Gordon Rendering to be in compliance and a permit issued by June 1, 1988. He stated they will have to agree to the type of testing to be done at the plant and begin promptly; if good test data results are received from all three plants, MPCA should be able to determine what will be necessary in the permits and get them written, as MPCA is aware of the citizen concerns with the upcoming summer. . 5. What method will MPCA pursue to ensure compliance on an on-going basis7 Liefert stated that the MPCA will ensure continuous compliance by requiring source emission tests semi-annually with additional testing as necessary, if needed to resolve any disputes of non-compliance. Liefert knows that semi-annual testing is required, if something arises between those test periods and the MPCA determines there is no violation of the rule,the MPCA will be able to go in and 'make another test. The MPCA will also coordinate unscheduled inspections and complaint inspections with the City staff. 6. What specific testing programs will be required? Liefert stated the MPCA will specifically require Gordon Rendering to conduct odor emission tests on all control equipment exhausts while operating at maximum production rates and temperatures. Whatever conditions are recorded for production and control equipment will be used to write the permit. The odor tests will be conducted in accordance with Minn. Rules part 70050930 with MPCA staff present to record conditions. Observance of these tests will be coordinated with City staff; Liefert assumed that would be Mr. Fridgen. . Liefert explained that if the plant wanted to run a half load in the cooker, over a longer period of time, at half temperature, conditions on the scrubber, that recorded data would be written into the permit. 7. What long range plan will the MPCA haye to assure consistent compliance? Liefert advised that the MPCA will issue an Air Emission Facility Permit to Gordon Rendering which could be revoked if consistent compliance is lacking over the long range. However, revocation of the permit would only occur after attempting to resolve the odor problem through improved control equipment or other mechanical changes to the facility (i.e. raising the stack height). Strict enforcement of the permit conditions will be done during the permit life by MPCA staff and City Staff. A member of the audience questioned if there was a time limit for the plant to meet the requirements and improve their equipment. Scott Parr adVised that those types of conditions would be negotiated in any stipulation agreements or enforcement actions taken by MPCA; consideration would be given for the company to order additional equipment, installation of new equipment and a reasonable time period would be set. Liefert advised that the . permits currently issued include a time period for construction compliance; if a problem is identified, relative to equipment or method of processing, the permit is still issued with a time period specified for bringing equipment or method of processing into compliance. Mr. Freed, member of the Clean Air Committee, questioned if incineration would be required unless something equal to or better than was provided. Liefert stated incineration would be required if necessary; if existing equipment is not adequate. He stated at this time the MPCA would prefer waiting until tests have been completed to determine if the equipment is not adequate or if it has not been run properly. Scott Pahr stated that raising the stacks may solve the problem; MPCA would rather investigate all possible avenues before requiring an incinerator~ Councilmember Winiecki questioned if all of the testing that will be a part of the permit and the kind of benchmarks that will be adhered to will go on prior to the June 1, 1988 deadline. Liefert stated that is correct; testing will be performed with plant production as it will operate, and permit will limit the plant to operating under conditions at which it complies with MPCA standards. Liefert explained if the plant decided .~ to operate under different conditions than those specified, they would have to apply for an amendment to the permit and the tests would be performed again to insure compliance.