Agri-Energy is one of twelve ethanol facilities in Minnesota. EPA met with the twelve companies over a three month period to discuss how to resolve their underestimated VOC and CO problem. Each facility was permitted as a synthetic minor and tripped PSD by actually emitting at major source levels. The facilities installed BACT-level controls for all of their significant units, and came into compliance with federal and state regulations in a very short amount of time. These twelve cases were part of an expedited negotiation process that involved EPA, DOJ, and MPCA