Recommended Scope of Analysis

for Endangered Species Evaluation

Archer Daniel Midland Company, Decatur, Illinois -- Glycols Plant

December 20, 2006

[Purpose of analysis]{.underline}:

The analysis is intended to determine whether the proposed modifications
to the Archer Daniel Midland Company's (ADM's) Decatur facility are
likely to directly or indirectly adversely affect federally listed
species. This recommended scope of analysis or roadmap recommends using
USEPA's ecological risk assessment process to inform the decision points
in section 7 of the Endangered Species Act. Portions of the USEPA's
draft Screening Level Ecological Risk Assessment Protocol for Hazardous
Waste Combustion Facilities (EPA 530-D-99-001A) provides useful guidance
for this analysis. Although this guidance was designed specifically to
assess the impact of hazardous waste combustion facilities, it offers
general approaches for assessing the fate of chemicals released to the
air that can be applied to all types of industrial facilities.

Overall, the evaluation should focus on increased emissions from the
project; however, if reductions will occur as a result of this project
or are planned in conjunction with this project, these reductions should
be considered in the evaluation. To complete this analysis we need an
understanding of the background concentrations and deposition patterns.
The anticipated emissions from permitted but not yet operational
facilities other than ADM should be included in background. The
anticipated concentration in air or deposition at sites supporting
listed species should be compared against NOEL (No observed effects
level) benchmarks thought to be protective of the appropriate group
(e.g., plants). The evaluation should look at the incremental addition
in the context of background concentrations.

[Benchmarks]{.underline}:

For these analyses, commonly accepted NOEL (no observed effects levels)
benchmarks should be used. Where more than one benchmark can be found
the most conservative value should be used, unless an explanation is
given to justify a less conservative benchmark. When there is no
commonly accepted benchmark, there should be a search of the scientific
literature for relevant toxicity information to provide a basis for risk
assessment for the species of concern.

[Modeling protocol]{.underline}:

Modeling should follow the general guidance provided in Chapter 3 of
USEPA's SLERA protocol for assessing chemical fate and transport. The
modeling should show air concentrations and deposition rates for all
pollutants (where appropriate). The air emissions resulting from the
project should be modeled at the facility level, not on a unit basis.
Total impacts should be evaluated looking at the combined effects of the
vapor phase, particle phase and particle-bound phase of pollutants.
ISCST3 or AERMOD are acceptable models for this analysis. For chemicals
amenable to deposition, models in the SLERA guidance should be used to
estimate concentrations in soil, sediment and surface water in
conjunction with relevant fate and transport parameters.

[Assessment Area]{.underline}:

For the chemicals amenable to deposition, the majority should deposit
within a 3 km radius of the facility. We recommend using the maximum
deposition value within that 3 km radius in performing the analysis.

[Background Levels]{.underline}:

Background levels of pollutants of concern should be located for soil,
water and sediment. If actual values cannot be located, representative
values may be used.

[Suite of pollutants to consider]{.underline}:

The assessment should cover all air pollutants emitted from the facility
including ozone, sulfur compounds, oxides of nitrogen, carbon monoxide,
particulates, and hazardous air pollutants. USEPA will provide the
analysis for ozone for this project.

[Types of impact to consider]{.underline}:

1.  Short term, depending on pollutant compare worst 1 hr, 8 hr, and 24
    hr. concentration in air with appropriate bench marks for acute
    effects. A discussion of each pathway should be included with an
    explanation of which is considered most sensitive. This includes,
    but is not limited to, impact to physical structures, cuticle
    uptake, stomatal uptake, root uptake, and particulate clogging of
    stomates for plant species. For the bald eagle and the Inidana bat
    determine the exposure via food sources that would be taking up
    contaminants through soil, water and sediment.

2.  Long term, depending upon pollutant compare worst 1 yr of 5
    concentration in air or deposition on soil with appropriate bench
    marks for chronic effects.

3.  For compounds that may accumulate, evaluate estimated total
    deposition over life of project. These concentrations should be
    compared against benchmarks.

[Listed Species]{.underline}:

The following species may occur within a short distance of the facility:

1\. Bald Eagle (*Haliaeetus leucocephalus*)

2\. Indiana Bat (*Myotis sodalist*): can occur in caves, mines and
forage in small stream corridors with well developed riparian woods and
upland forests.

> 3\. Eastern Prairie Fringed Orchid (*Platanthera leucophaea*): can
> occur in Mesic to wet prairies.
>
> 4\. Prairie Bush Clover (*Lespedeza leptostachya*): can occur in Dry
> to mesic prairies with gravelly soil.

ADM may rely on GIS data to exclude certain species from the analysis.
The eastern prairie fringed orchid would most likely be associated with
wet meadows or wet prairies not in a stream or river floodplain;
however, it may also occur on mesic prairie habitat. We suggest using
the National Wetlands Inventory (NWI) and the Land Use and Land Cover
map to determine if suitable habitat is present. The NWI code that best
illustrates the wet prairie habitat would be the PEM series outside of
the 100 year floodplain. On the Land Use and Land Cover maps, look for
nonagricultural grassland.

To rule out the prairie bush clover use the Land Use and Land Cover map.
Look for nonagricultural grasslands. If there are none, than the prairie
bush clover can be excluded.

To rule out the Indiana Bat, look for grassy field, stream corridors and
forested, non-developed areas. If there are none, then the Indiana Bat
may be ruled out.