### GRAIN ELEVATOR AND PROCESSOR NSPS INDUSTRY SURVEY

INTRODUCTION AND GENERAL INSTRUCTIONS

This survey form is to be completed by a respondent for each of its wholly owned facilities as described in the following four paragraphs (A-D), using the definitions at the end of this introductory section. Respondents must meet the requirements of paragraphs A, B, and C.
A. This survey is limited to the following facilities: any “grain elevator” that would constitute a “grain terminal elevator” or a “grain storage elevator” (as those terms are defined by Subpart DD (40 CFR 60.301)) if only permanent storage or both permanent and temporary storage at the grain elevator are taken into account. A respondent need not provide data for any facility not possessing this type of grain elevator.
B. EPA is interested in obtaining information about the following categories of grain elevators:
(1) Country grain elevators with storage capacity^ ≥ 2,500,000 bushels (2) Other stand-alone elevators with storage capacity^ ≥ 2,500,000 bushels (3) Wheat flour mill elevators * 

### (4) Wet corn mill elevators * 

### (5) Dry corn mill (human consumption) elevators * 

### (6) Rice mill elevators * 

### (7) Soybean oil extraction elevators *

^”Storage capacity” may include only permanent storage c apacity, or it may include both permanent and temporary storage capacity.
*Grain elevators in categories 3-7 above must have storage capacity of ≥ 1,000,000 bushels.


### For each of the above seven categories, a respondent must submit a response for at least five facilities under its control. If a respondent has less than five facilities in a particular category, the respondent must provide information for all of its facilities in that category.

### C. EPA is also interested in obtaining inform ation about the following types of facilities:

 Grain elevators located in each EPA Region.

 Five storage combinations:

- Grain elevator alone

- Grain elevator w/emergency storage

- Grain elevator w/temporary storage

- Grain elevator w/emergency and temporary storage

- Grain elevator w/barge unloading

 Facilities handling multiple grains.

 Facilities handling only one grain.
A respondent must submit a response for each of the facilities listed below to the extent it has any such facility under its control for each of the 7 categories listed in paragraph B:

 At least one facility in each Region;

 At least one facility with each of the grain storage combinations;

 At least one facility that handles multiple grains; and

 At least one facility that handles only one grain.
For example, if a respondent has 18 facilities in t he country grain elevator category, and 10 are in EPA Region 5 and eight are in EPA Region 6, the respondent shall provide information for a minimum of five grain elevators. At least one elevator must be in Region 5 and one in Region 6. In addition, if applicable, the respondent shall provide information on at least one facility with each of the five grain storage combinations. The respondent must also provide information for at least one facility that handles multiple grains and one that handles only one grain. In this example, assuming the respondent owned each of the different types of grain elevators of interest to EPA, it is possible to meet the EPA requirements with five facilities responding if the five chosen facilities can meet multiple requirements (e.g., handling multiple grains in EPA Region 5 and using each of the 5 storage methods). However, it may be necessary to provided additional facility respons es to meet the EPA requirements if facilities cannot meet multiple EPA requirements.
D. The total number of facilities for a respondent may exceed 35 (five facilities in each of the seven categories) when including the regional, combination, and grain information. However, no respondent is required to submit information about more than 51 facilities.
Since one of the goals of this survey is to gather data on temporary storage facilities, EPA encourages respondents to exercise any discretion afforded by paragr aphs A-D above in favor of submitting data on such facilities. For the same reason, EPA encourages respondents to include along with their required responses to this survey any supplemental data on such facilities that may go beyond the bounds of this survey but nevertheless would be helpful to EPA in understanding tem porary storage facilities fully from the standpoint of Subpart DD.
This survey is provided in paper format and by first-class mail. However, you may opt to complete this survey either in paper format or in electronic format. To obtai n an electronic file (in Microsoft Word) to compile your responses, please contact Bill Schrock at schrock.bill@epa.gov . Please submit complete responses to Bill Schrock within 60 days after receipt by first-class mail. Any request for an extension of that 60-day period must be submitted to Bill Schrock within 30 days after rece ipt by first-class mail. Extensions will not be granted except upon a showing of undue hardship and then only for the minimum time reasonably necessary.
It is important to note that, throughout this document, we have used the terms “permanent storage,” “temporary storage” and “emergency storage” to differentiate between those structures typically constructed of concrete and topped with metal roofs and the pyramid shaped storage uni ts typically with low concrete walls and a vinyl top. The use of the terms “permanent storage” and “temporary storage” is strictly to reflect the current

### receipt by first-class mail. Any request for an extension of that 60-day period must be submitted to Bill Schrock within 30 days after receipt by first-class mail. Extensions will not be granted except upon a showing of undue hardship and then only for the minimum time reasonably necessary.
It is important to note that, throughout this document, we have used the terms “permanent storage,” “temporary storage” and “emergency storage” to differentiate between those structures typically constructed of concrete and topped with metal roofs and the pyramid shaped storage units typically with low concrete walls and a viny l top. The use of the terms “permanent storage” and “temporary storage” is strictly to reflect the current terminologies used in industry as defined by the U.S. Department of Agriculture (USDA) and in no way represents any EPA decision as to how these units will be treated in any subsequent action. See definitions section for a list of terms used in this survey.
In addition to the items listed in the survey forms that follow this introduction, we are also requesting copies of the following information to the extent it relates to grain elevators or portions of processing plants that consist of grain elevators:
1. Your current air quality operating permit, if you have one. 2. Copies of the most recent results from PM/PM10 emissions testing conducted at your facility within the last 3 years, including but not limited to, opacity measurements and stack testing. No new testing is required for this survey.
Following is a summary of the forms that comprise this survey:

Form A General Form . One should be completed for each facility. Form B Storage Information . Please complete for storage units at each facility. Form C Receiving and Shipping . Complete for shipping/receiving units at each facility. Form D Temporary Storage . Please complete one form for each temporary storage area. Form E Emergency Storage . Complete one form for each emergency storage area. Form F Grain Dryers . Please complete one form for fuels used for grain dryers. Form G Permitted Sources . Please complete if any part of your facility is covered under an air quality operating permit. Form H Work Practices . Please complete if any part of your grain elevator or processing facility uses work practices for grain storage, shipping, and receiving operations. Form I Add-on Particulate Controls . Please complete for each add-on particulate control.

Signature Date

## Definitions (in addition to those in Subpart DD):
Storage Unit – For the purposes of this survey, a storage unit is any building, bin, silo, or pile used to store corn, wheat, sorghum, rice, rye, oats, barley or soybeans.
Permanent Storage – A storage unit with an immovable roof; a floor made of concrete, asphalt or similar material; and sidewalls made of steel, concrete or similar material.
Temporary Storage – A storage unit that is comprised of: asphalt, concrete, or other comparable base material; rigid self-supporting sidewalls; a tarp , cover or the equivalent; and an aeration system.
Emergency Storage – A form of storage other than permanent storage or temporary storage.
Country Elevator – Any grain elevator where more than 50% of grain is received from farms.

Other Stand

- Alone Elevator – Any grain elevator where less than 50% of grain is received from farms AND grain processing is not the primary activity.
Grain Processing – Equipment or processes used to alter the natural state of grain by fractioning, grinding, blending, conditioning, etc., in order to produce a product for human or animal consumption or the production of biofuels.
Shipping Units – All equipment associated with loading grain from a storage unit.
Receiving Units – All equipment associated with loading grain into a storage unit.
Design or Work Practice – Any technique other than the installation of air pollution control equipment for the reduction of particulate matter emissions.

### FORM A Page 1 

# Grain Elevator Survey

FORM A – General Information

A-1 Facility Name:

A-2 (a) Facility Street Address:
(b) Suite or P.O (s pecify): (c) City:
(d) State: (e) Zip Code: (f) County:

A-3 (a) Facility Manager: (b) Phone:

A-4 (a) Technical contact (for info rmation on this survey):
(b) Title: (c ) Telephone Number:
(d) Email Address:

A-5 Number of full-time employees at this location (total for all shifts):
A-6 Number of seasonal employees at this location (total for all shifts):

A-7 (a) Parent Company/ Co-Op:
(b) Is this a co-op? (check one) Yes No
(c) Parent Company/ Co-Op Main Office Street Address:

(d) Suite or P.O. (specify) : (e) City:
(f) State: (g) Zip Code:

A-8 Number of full-time employees within all business units of the Parent Company:
(please check one): < 100 101- 249 250- 499 > 500

A-9 Number of seasonal employees within a ll business units of the Parent Company
(please check one): < 100 101- 249 250- 499 > 500 FACILITY ID:

FACID : (First 4 letters of company name plus first 4 letters of city name. If not unique identifier, add number at end of ID)§B-4 Overview Flow DiagramFACID: ARCHCOLUTruck Pit(2) R-1(WM-01)P-2Silo 4-8(Group)(WM57-61)P-1Silo 1-3(Group)(WM54-56)P-3Silo 9-12(Group)(WM72-79)P-4Silo 13-17(Group)(WM80-89)Truck Pit(2) R-2(WM-02)Rail PitR-3(WM-71)CornCleaner(WM-03)Process

## FORM B - Storage Information
(B-1) FACID:

FORM B Page 1 B-2 In what year was this facility first constructed?

B-3 Total number of storage units: (a) "permanent" storage (b) "t emporary" storage (c) "emergency" storage

[Note : In completing the remainder of the survey, y ou will be able to group information for similar storage units. See B-4 for example.]

B-4 Please provide an overview flow diagram (or blo ck flow diagram) of the grain elevator(s) at your facility. Please include pe rmanent (P), temporary (T), and emergency (E) storage units, associated receiving (R) and shipping (S ) units, and grain dryers (D).

o Permanent Storage ID: use your current designation or assign a nu merical value. If assigning an ID, please use “P-1, P-2, etc” format. You may group multiple storage units into one permanent storage ID; if not readily apparent, please provide ex planations on the back of this sheet or indicate in your elevator diagram.

o Temporary Storage ID: use your current designation or assign a nu merical value. If assigning a new ID, please use “T-1, T-2” format.

o Emergency Storage ID: use your current designation or assign a nu merical value. If assigning a new ID, please use “E-1, E-2” format.

o Receiving Units ID: use your current designation or assign a numerical value. If assigning an ID, please use “R-1, R-2” format.

o Shipping Units ID: use your current designati on or assign a numerical value. If assigning an ID, please use “S-1, S-2” format.

o Grain Dryer ID: use your current designation or assign a numerica l value. If assigning an ID, please use “D-1, D-2” format.

o Capacity: please provide capacity in bushels. Do not use a pack factor

.FORM BPage2Please check one: This page includes CBI□This page does NOT include CBI□[If no box is checked, EPA will assume that the page does NOT contain CBI]FORM B – Storage Information(B-1) FACID:B-5.Please complete the following table for storage information. An example is provided.2005 2006 2007Storage Type(P, T, E)StorageIDYear FirstUsedStorageCapacity(Bushels)2GrainStored1Through-put(actual bushels)2Weeks peryear utilizedThrough-put(actual bushels)2Weeks per yearutilizedThrough-put(actual bushels)2Weeks peryear utilizedCorn100,0002P - exampleP-11970300,000Wheat400,00050300,00050300,00050P - exampleP-21985400,000Corn400,00052400,00050400,00048T - exampleT-12004450,000Corn200,00022250,00020150,000241 Use grain designations: corn, wheat, sorghum, rice, rye, oats, barley, soybeans, or specify a different grain.2 Storage capacity and throughput refer to the aggregated storage capacity and throughput of the units included in the storageID from B-4. Fortemporary and emergency storage units, storage capacity and throughput may be estimated based on operator’s knowledge if actualdata is notavailable. For permanent storage units, throughput may be estimated based on operator’s knowledge if actual data is not available.FORM CPage1Please check one: This page includes CBI□This page does NOT include CBI□[If no box is checked, EPA will assume that the page does NOT contain CBI]FORM C – Receiving and Shipping Information(C-1) FACID:C-2Please complete the following table for receiving and shipping operationsat each storage unit (orgroup of units). Use theStorage, Shipping, and Receiving ID’s provided in B-4.An example is provided.What is the Maximum LoadingRate?Receiving/ShippingIDStorage IDassociated withreceiving/shipping unitHow is Grain Received Into orShipped (Loaded) Out ofStorage?aValue UnitsAre there any addon controls for thereceiving/shipping unit (Y/N)Any qualitativeemissionsmonitoringconducted?b(Y/N)R-1P1Fixed Conveyor BeltS-1P1Fixed Conveyor BeltR-1T1Portable AugeraLoading and unloading methods include:portable augerfixed receiving pit with leg to aeration towerenmass drag conveyor unloaderportable inclined beltfixed conveyor off main complexpneumatic unloadergravity fill spoutportable conveyor with trucksor specify a different methodfront-end loadermarine legfixed drag conveyortrack hoe/clamshell unloaderfixed conveyor beltcontinuous barge unloaderbQualitative methods include opacity measurements as well as monitoring instruments (e.g. CEMS), and monitoringof parameters toindicate whether the air pollutioncontrol device is operating properly.

## FORM D – “Temporary” Storage
(D-1) FACID: (D-2) Temporary Storage ID:

FORM D Page 1 (Please copy this sheet and comp lete a separate sheet for each temporary storage at your facility)

D-3 Please provide a diagram of each storage unit and indicate which pieces of equipment (e.g., walls, cover, floor, conveyance system, generator, housing for electrical, etc) remain in place year round and which are removed during specific time s of the year. If th is system is identical (or nearly identical) to another temporary system at the same facility, only one diagram is needed. Please include all applicable ID numbers on the diagram and explain any differences
below.

D-4 What are the materials of construction for this storage unit?

(a) Walls:

(b) Cover/tarp:

(c) Floor:

D-5 (a) Has the cover/tarp ever been replaced? (check one) Y N

(b) If yes, month(s)/year(s) cover/ tarp was used before being replaced:

## FORM D – “Temporary” Storage
(D-1) FACID: (D-2) Temporary Storage ID:

FORM D Page 2 D-6 Describe the routine maintenance (including repai r and replacement) that is conducted on the temporary storage units, including frequency of these activities. If you typically replace a component of a unit (e.g., repl acement of a tarp/cover in sections, as opposed to entire replacement), indicate frequency and typical perc ent of the entire unit that is replaced.
Walls:

Floors:

Cover/Tarp:

Aeration:

Other equipment associated with st orage (e.g., conveying equipment)

D-7 Describe methods used to reduce particulate emissions during receiving and shipping, aeration (or other similar processes), and general storage. Indicate frequencies of any actions. (Please complete Form I for any add-on pollution control device).

## FORM E – “Emergency” Storage
(E-1) FACID: (E -2) Emergency Storage ID:

FORM E  Page 1 E- 3 Explain any approaches taken to minimize particulate emissions from the emergency storage pile. Indicate frequencies of any actions.

## FORM F – Grain Dryers
(F-1) FACID:

FORM F  Page 1 F-  Please complete the following tabl e for grain dryers used at your facility. Use the Dryer, Storage, Shipping, and Receiv ing ID’s provided in B-3. An example is provided.

How much fuel was used Grain Dryer ID Storage/Receiving/Ship ping units associated with Dryer Fuel Used 1 2005 2006 2007 D-1 P-1, P-2, R-1, S-1 FO2 10,000 10,000 8,000 D-2 T-1 FO2 1,000 1,000 1,000

1 

### Select fuel from list below. If other, please specify.
FO2 - #2 Fuel Oil (gallons) FO6 - #6 Fuel Oil (gallons) NG – Natural Gas (MM cubic feet) Bio – Biofuel (gallons) O – Other, please specify type of fuel and unit of measure

F-  For each column dryer at your facility that does not include a perforated column plate in its design, please: (1) describe the design of that dryer, including whether it uses woven wire screening; (2) indicate the grain(s) for which t he dryer is used; and (3) provide the year of original installation.

## FORM G –Permitted Sources
(G-1) FACID:

FORM G Page 1 G-2 Please indicate the total number of each component listed below that you have at this facility and the number for which your operating permit specifies an applicable control requirement.

Component Total Number at Site Number for which your permit specifies a control requirement? 

### Truck receiving station Truck shipping station Barge and ship receiving station Barge and ship shipping station Railcar receiving station Railcar shipping station Grain dryer



### G-3 Is any grain handling equipment subjected to a control requi rement in your permit?

(check one) Y N

As defined in NSPS, Subpart DD, grain handling operations includ e, as an assemblage of equi pment, bucket elevators or legs (excluding legs used to unload barges or ships), sc ale hoppers and surge bins (garners), turn heads, scalpers, cleaners, trippers, and the headhouse and other such structures. 

### For purposes of Form G, the term “control requirement” refers onl y to particulate matter (PM) emission limits specified for the particular “component” in question and expressed in terms of emissions per unit of time or production ( e.g., lb of PM/hr; grains/dscf), opacity ( e.g., 20%), or a design or work practice ( e.g., use of enclosure), and not to rest rictions on operational parameters such as hours, feedstock or throughput.

## FORM H – Work Practices
(H-1) FACID:

FORM H Page 1 H-2 Describe the design or work practices you follow to reduce emissions (e.g, choke flow, louvered grates, mineral oil, etc.). Please describe the frequency the activity is used (e.g, during each loading operation, all the time, etc) and the estimated time spent on the activity per usage (e.g, 20 minutes per loading event). For “barge and ship receiving station,” pleas e provide copies of any equivalency determinations under 40 CFR 60.302(d) and any permit conditions resulting from such determinations.



### Truck receiving station

Truck shipping station

Barge and ship receiving station

Barge and ship shipping station

Railcar receiving station

Railcar shipping station

Grain dryer

Grain handling operations a

a As defined in NSPS, Subpart DD, grain handl ing operations include, as an assemblage of equipment, bucket elevators or legs (excluding legs used to unload barges or ships), sc ale hoppers and surge bins (garners), turn heads, scalpers, cleaners, trippers, and the headhouse and other such structures.FORM I – Add-on Pollution Control Device(I-1) FACID:FORM IPage 1If data are not available or unknown, please enter NDI-2Please complete the following table for any air pollution control devices at your facility. Please provide ID and include on processdiagram. For each unit, please provide the most recent performance data you have.An example is provided.Air Pollution ControlDevice IDType of Control [e.g., fabricfilter/baghouse; cyclone;other (specify)]Points controlledby this control(Use ID’s fromForms B, C, andD)Type of Data Available [e.g.,performance test, manufacturer’sspecs or guarantee, engineeringcalculations, other (specify)]DesignEfficiencyUnits (include whetherefficiencies are for PM,PM10PM2.5, opacity)APCD-1 exampleCycloneR-1, R-2Manufacturer’s specifications40%PMAPCD-2 exampleFabric FilterS-1Manufacturer’s specifications90%PM and PM10Make additional copies, as necessary

## FORM I – Add-on Pollution Control Device
(I-1) FACID:

FORM I   Page 2 I-3. Provide a copy of the most re cent performance test for each air pollution control device
If no performance tests are available, complete questions I-4 through I-7.

I-4. Please complete for each c ontrol device listed in I-2.

Inlet Flow Pressure Drop Inlet Temperature APCD ID Max Units Min Max Units Min Max o 

### C/ o 

### F



### I-5 For each cyclone, please co mplete the following table

APCD ID Particle Density Units

## FORM I – Add-on Pollution Control Device
(I-1) FACID:

FORM I  Page 3 I-6 . For each fabric filter/baghouse, pl ease provide the following information.
APCD ID Number of bags Total Surface Area Units

I-7 For each control not listed in I-5 and I-6, please describe the te chnology and the parameters that are relevant for operation of the control

### ENCLOSURE 2
EPA's Information Gathering Authority Under Section 114 of the Clean Air Act
Under Section 114 of the Act (42 U.S.C. 7414), Congress has given the U.S. Environmental Protection Agency broad authority to secure information needed for the purpose of (i) developing or assisting in the development of any implementation plan under Sect ion 110 or 111(d), any standard of performance under Section 111, or any emission standard under Section 112; (ii) determining whether any person is in violation of any such standard of any requirement of such a plan; or (iii) carrying out any prov ision of this Act. Among other things, Section 114 authorizes EPA to make ins pections, conduct tests, examine records, and require owners or operators of emission sources to submit information reasonably required for the purpose of developing such standards. In addition, the EPA Office of General Counsel has interpreted Section 114 to include authority to photograph or require submission of photographs of pertinent equipment, emissions, or both.
Under Section 114, EPA is empowered to obtain info rmation described by that section even if you consider it to be confidential. You may, however, request that EPA treat such information as confidential. Information obtained under Section 114 and covered by such a request will ordinarily be released to the public only if EPA determines that the information is not entitled to confidential treatment. 1 

### Procedures to be used for making confidentiality determinations, substantive criteria to be used in such determinations, and special rules governing information obtained under Section 114 are set forth in 40 CFR Part 2 published in the Federal Register on September 1, 1976 (40 FR 36902).
Pursuant to § 2.204(a) of EPA's Freedom of Information Act (FOIA) regulation, in the event a request is received, or it is determined that a request is likely to be received, or EPA desires to determine whether business information in its possession is entitled to confidential treatment even though no request for release of the information has been received, please be advised that EPA will seek, at that time, the following information to support your claim as required by § 2.204(e)(4) of EPA's FOIA regulations:
1. Measures taken by your company to guard against undesired disclosure of the information to others;
2. The extent to which the information has been disclosed to others, and the precautions taken in connection therewith;
3. Pertinent confidentiality determinations, if any, by EPA or other Federal agencies, and a copy of any such determinations, or reference to it, if available; and
4. Whether your company asserts that disclosure of the information would be likely to result in substantial harmful effects on the business' competitive position, and if so, what those harmful effects would be, why they should be viewed as substantial, and an explanation of the causal relationship between disclosure and such harmful effects.

1 Section 114 requires public availability of all emission da ta and authorizes disclosure of confidential information in certain circumstances. See 40 FR 36902 - 36912 (September 1, 1976).FORM I – Add-on Pollution Control Device(I-1) FACID:FORM IPage 1If data are not available or unknown, please enter NDI-2Please complete the following table for any air pollution control devices at your facility. Please provide ID and include on processdiagram. For each unit, please provide the most recent performance data you have.An example is provided.Air Pollution ControlDevice IDType of Control [e.g., fabricfilter/baghouse; cyclone;other (specify)]Points controlledby this control(Use ID’s fromForms B, C, andD)Type of Data Available [e.g.,performance test, manufacturer’sspecs or guarantee, engineeringcalculations, other (specify)]DesignEfficiencyUnits (include whetherefficiencies are for PM,PM10PM2.5, opacity)APCD-1 exampleCycloneR-1, R-2Manufacturer’s specifications40%PMAPCD-2 exampleFabric FilterS-1Manufacturer’s specifications90%PM and PM10Make additional copies, as necessaryFORM I – Add-on Pollution Control Device(I-1) FACID:FORM IPage 1If data are not available or unknown, please enter NDI-2Please complete the following table for any air pollution control devices at your facility. Please provide ID and include on processdiagram. For each unit, please provide the most recent performance data you have.An example is provided.Air Pollution ControlDevice IDType of Control [e.g., fabricfilter/baghouse; cyclone;other (specify)]Points controlledby this control(Use ID’s fromForms B, C, andD)Type of Data Available [e.g.,performance test, manufacturer’sspecs or guarantee, engineeringcalculations, other (specify)]DesignEfficiencyUnits (include whetherefficiencies are for PM,PM10PM2.5, opacity)APCD-1 exampleCycloneR-1, R-2Manufacturer’s specifications40%PMAPCD-2 exampleFabric FilterS-1Manufacturer’s specifications90%PM and PM10Make additional copies, as necessary

# , 

# STATE OF NEBRASKA

Mike Johanns Gouemor DEPARTMEi'IT OF ENVlRONMEi'ITAL QUAUTY Michael J. Linder Director Suite 400, The Atrium 1200 'N' Slree' P.O. Box 98922 Uncoln. Nebraska 68509-8922 Phone (402) 471-2186

FAX (402) 471· 2909

PERMIT TO OPERATE A CLASS I AIR CONTAMINANT SOURCE IS HEREBY ISSUED TO:

Archer Daniels Midland Company 3000 East 8 th Street Columbus, NE 68601-9073

FOR THE OPERATION OF:

A Wet Com Milling and Ethanol Production Facility

LOCATION OF OPERATION:

ADM Com Processors

3000 East 8 th Street Columbus, Nebraska 68601-9073

Pursuant to Title 129, Chapter 14, of the Nebraska Air Quality Regulations, the public has been notified by prominent advertisement of this proposed operation of an air contaminant source and the thirty (30) day period allowed for comments has elapsed. This Operating Permit approves the proposed operation of the wet com milling manufacturing facility (primary SIC 2046). The operation covered by this permit consists of a facility that manufactures ethanol (secondary SIC 2869), starches, high fructose

corn syrup, and animal feed products utilizing the wet milling process. Attachment A contains an equipment list for this facility.

Compliance with this permit shall not be a defense to any enforcement action for violation of an ambient air quality standard.

This permit is issued with the following conditions:

General Conditions



### 1. Administrative amendment of this permit for a change in ownership or operational control of this

source is allowed provided the Department determines that no other change in the permit is necessary and a written agreement containing a specific date for transfer of permit responsibility, coverage, and liability between the current and new permittee has been submitted to the Department. (Title 129, Chapter 15, Section 001)

II, The permittee shall allow the Department, EPA or an authorized representative, upon presentation of credentials to (Title 129, Chapter 8, Section 012.02):

Archer Daniels Midland Company-39285001.doc Class I Operating**Permil~Page** I All Equal Opportunff.,yAf/irmatlue Action Employer

Printed with S&jlnk OIl recycled paper •(A) Enter upon the pennittee's premises at reasonable times where a source subject to this pennit is located, emissions-related activity is conducted, or where records must be kept under the conditions of this pennit, for the purpose of ensuring compliance with this pennit or applicable requirements;

(B) Have access to and copy, at reasonable times, any records that must be kept under the conditions of this pennit, for the purpose of ensuring compliance with this pennit or applicable requirements;

(C) Inspect at reasonable times any facilities, pollution control equipment, including monitoring and air pollution control equipment, practices, or operations regulated or required under this pennit, for the purpose of ensuring compliance with this pennit or applicable requirements;



### (D) Sample or monitor at reasonable times substances or parameters for the purpose of ensuring compliance with the pennit or applicable requirements.



## m. Applicable regulations:

(A) Federal Regulations including those not currently delegated to Nebraska or not yet included in Title 129

- Nebraska Air Quality Regulations

(B) Title 129

- Nebraska Air Quality Regulations as amended February 7,2004.

TV. The pennittee shall comply with 40 CFR Part 82, PROTECnO OF THE STRATOSPHERIC OZONE. Affected controlled substances include, but are not limited to, cWorofluorocarbons and hydrocWorofluorocarbon refrigerants, halons, carbon tetracWoride, and methyl cWoroform (specific affected controlled substances are listed in 40 CFR part 82, Subpart A, appendices A, {class I} and B (class II}).

The following subparts and sections of 40 CFR Part 82 are conditions of this pennit:

Subpart A - Production and Consumption Controls Subpart B - Servicing of Motor Vehicle Air Conditioners Subpart E - Labeling of Products Using Ozone-Depleting Substances: Sections; 82.106 Warning
statement requirements, 82.108 Placement of warning statement, 82.110 Form of label bearing warning statement, and 82.112 Removal of label bearing warning
statement Subpart F - Recycling and Emissions Reduction: Sections; 82.156 Required practices, 82.158 Standards for recycling and recovery equipment, 82.161 Technician certification, and 82.166 Reporting and recordkeeping requirements Subpart G - Significant New Alternatives Policy Program

V. This pennit is issued for a fixed term of five (5) years. A renewal application shall be submitted
to the Department a minimum of six (6) months and a maximum of eighteen (18) months before permit expiration. The source may continue to operate subject to final action by the Department provided their application is submitted within the above timeframe and the application is deemed complete by the Department. (Title 129, Chapter 8, Section 003 and Title 129, Chapter 7, Section 002.06)

An:her Daniels Midland Company-3928500l.doc Class J Operating Pennit-Pagc 2VI. The pennittee shall comply with all conditions of this penni!. Any pennit noncompliance shall constitute a violation of the Nehraska Environmental Protection Act and the Federal Clean 

### Air Act, and is grounds for enforcement action; pennit termination, revocation and reissuance, or modification; or for denial of a pennit renewal application. (Title 129, Chapter 8, Section 007.01)

VII. It shall not be a defense for a pennittee in an enforcement action to claim that it would have been
necessary to halt or reduce the permitted activity in order to maintain compliance with the conditions of this penni!. (Title 129, Chapter 8, Section 007.02)

VITI. This pennit may be modified; revoked, reopened, and reissued; or terminated for cause in accordance with Title 129 and Title 115, Rules of Practice and Procedure. The filing of a request by the permittee for a pennit modification, revocation and reissuance, or termination, or of a notification of planned changes or anticipated noncompliance does not supersede any permit condition. (Title 129, Chapter 8, Section 007.03)

IX. Conditions under which this permit will be reopened, revoked and reissued or terminated during its term for cause, include but are not limited to: (Title 129, Chapter 8, Section 0 I0 & Chapter 15, Section 006)

(A) Additional applicable requirements under the Nebraska Environmental Protection Act or the Federal Clean Air Act, which become applicable to this source with a remaining permit term of three (3) or more years;

(B) Additional requirements, including excess emissions requirements, that become applicable to an affected source under the acid rain program under Chapter 26;

(C) A determination by the Director, or the Administrator of EPA that:

(1) the pennit must be revoked and reissued to ensure compliance with the applicable requirements;

(2) the pennit contains a material mistake or that inaccurate statements were made in the emissions standards or other terms or conditions of the pennit;

(3) an applicable requirement or applicable requirement under the Federal Clean 

### Air Act applies which was not identified by the pennittee in its application;



## x. This pennit may be revoked during its term for cause, including but not limited to: (Title 129, Chapter 8, Section 010 & Chapter 15, Section 006.02)

(Al The existence at the facility of unresolved noncompliance with applicable requirements

or a term or condition of the pennit, and refusal of the pennittee to agree to an enforceable schedule of compliance to resolve the noncompliance;

(B) The submittal by the pennittee of false, incomplete, or misleading information to the Department or EPA;

An;her Daniels Midland Company-3928500I.doc Class I Operating Permit-Page 3(C) A determination by the Director that the permitted facility or activity endangers human health or the environment and that the danger cannot be removed by a modification of the permit; or

(D) The failure of the permittee to pay a penalty owed pursuant to court order, stipulation and agreement, or order issued by the Administrator of the EPA.

Xl. The permit does not convey any property rights of any sort, or any exclusive privilege. (Title 129, Chapter 8, Section 007.04)

XII. The permittee shall furnish to the Department, within the time specified by the Department, any information requested by the Department in writing to determine whether cause exists for modifying, revoking and reissuing, or terminating the permit or to determine compliance with the permit. Upon request, the permittee shall also furnish to the Department copies of records required to be kept in accordance with the permit or, for information claimed to be confidential, the permittee may furnish such records along with a claim of confidentiality pursuant to Title lIS

- Rules of Practice and Procedure. (Title 129, Chapter 8, Section 007.05)



### Xli. The provisions of this permit supersede the provisions of any previously issued operating or construction permit. The conditions of previously issued construction permits are applicable requirements of this permit. (Title 129, Chapter 8, Sections 002 and 007.06)

XIV. In the event of a challenge to any portions of this permit, the unchallenged 

### permit requirements shall remain valid. (Title 129, Chapter 8, Section 006)



## xv. Certification of compliance with the terms and conditions of this permit for the preceding calendar year, shall be submitted to the Department and to EPA Region VIl's Air Compliance Coordinator by March 31 of each year. The report must be certified by a responsible official in accordance with Condition XXIX and shall include the following: (Title 129, Chapter 8, Sections 004.02, 004.03& 012.01, & 012.05)

(A) The identification of each term or condition of the permit that is the basis of the certification;

(B) The compliance status and all instances of deviations from permit requirements;

(I) reports of deviations shall include the probable cause of such deviations and any corrective action or preventive measures taken.

(C) A determination of whether compliance was continuous or intermittent;

(D) The methods used for determining the compliance status of the source, currently and

over the reporting period;

(E) Applicable monitoring requirements.

XVI. The permittee shall submit a report of applicable monitoring and all instances of deviations from permit requirements for every six (6) calendar months to the Department. The report for the first six months (January through June) is due September 30 of each year. The report for the second six months (July through December) is due March 31 of the following year. Each report must be

Archer Daniels Midland Company-3928500l.doc Class I Operating Pennit-Page 4certified by a responsible official in accordance with Condition XXIX. (Title 129, Chapter 8, Sections 004.02,004.03& 004.04 & 012.01)

XVll. The permittee shall report all deviations from permit requirements, identify the cause of the deviations, and list corrective actions. All reports of deviations must be submitted within the time frame as per Conditions XVll.(A), (B), and (C) below (See Below). The following schedule
must be followed to report all deviations: (Title 129, Chapter 8, Sections 004.03 

### & 004.04)

(A) Any deviation resulting from emergency or upset conditions shall be reported within two working days of the date on which the permittee first becomes aware of the deviation if the permittee wishes to assert the affirmative defense authorized under Chapter II of Nebraska Title 129. The report may be submitted initially without a certification by a responsible official (in accordance with Condition XXIX) if an appropriate certification is provided within ten days thereafter, together with any corrected or supplemental information required concerning the deviation.

(B) Any deviation that poses an imminent and substantial danger to public health, safety, or the environment shall be reported as soon as is practicable. The report may be submitted initially without a certification by a responsible official (in accordance with Condition XXIX) if an appropriate certification is provided within ten days thereafter, together with any corrected or supplemental information required concerning the deviation.

(C) All other deviations shall be reported as per Condition XVI.

XVill. The following methods may be used to determine compliance with the terms and conditions in this permit (Title 129, Chapter 34, Section 008):

(A) Any compliance test method specified in the State Implementation Plan;

(B) Any test or monitoring method approved for the source in a permit issued pursuant to Title 129, Chapters 8, 17, 19, or 27;

(C) Any test or monitoring method provided for in Title 129; or

(D) Any other test, monitoring, or information-gathering method that produces information comparable to that produced by any method described in (A) through (C).

XIX. The permittee shall submit completed emission inventory forms for the preceding calendar year to the Department by March 31 of each year. (Title 129, Chapter 6)

XX. The permittee shall submit fees, due July I of each year, based on the actual emission tonnage, up to and including 4,000 tons per year for each regulated pollutant, as established in the emission inventory for the previous calendar year. (Title 129, Chapter 8, Section 008)

XXI. A permit shield is granted. (Title 129, Chapter 8, Section 014)

(A) During the term of this permit, compliance with the specific conditions identified in Condition XXX, constitutes compliance with the underlying applicable requirement, as

An:her Daniels Midland Company-3928500l.doc Class I Operating Permit-Page 5of the date of permit issuance, identified as the origin and authority for each specific condition.

(B) The permit shield does not affect:

(I) The emergency provisions of eb. Rev. Stat. § 81-1507 of the ebraska Environmental Protection Act;

(2) Liability for any violation of applicable requirements or applicable requirements under the Federal Clean Air Act prior to or at the time of permit issuance;

(3) The applicable requirements of Chapter 26;

(4) The authority of the Department or EPA to obtain information; or

(5) Any other permit provisions, terms, or conditions, including, but not limited to, construction permits issued pursuant to Chapter 17 or permits issued pursuant to other State authorities and Titles.

XXIT. The permittee may make changes to a permitted facility without a permit revision if the changes would not require a construction permit under Title 129, Chapter 17, 18, 19,23,27, or 28; would
not result in an exceedance of emissions allowable under this permit; would not violate any terms of this permit related to monitoring, testing, recordkeeping, reporting or compliance certification; and would not violate any applicable requirements. A permit shield shall not apply to changes made under this condition. Notification shall be in accordance with the requirements of Title 129, Chapter 15, Section 007. (Title 129, Chapter 15, Section 007 and Chapter I, Section 102)



## xxm. The permittee shall comply, in a timely manner, with all applicable requirements that become effective during the term of this permit unless a more detailed compliance schedule is expressly required by the applicable requirement. (Title 129, Chapter 7, Section 006.02H3(b) & Chapter 8, Section 012.03)

XXIV. This permit may contain abbreviations and symbols of units of measure, which are defined in 40 CPR Part 60.3. Other abbreviations may include, but are not limited to, the following: Code of Federal Regulations (CFR), Carbon Monoxide (CO), Construction Permit (CP), Continuous Emissions Monitor (CEM), New Source Performance Standards (NSPS), Nitrogen Oxides (NOx), Operating Permit (OP), Particulate Matter (PM), Particulate Matter less than or equal to 10 micrometers (PM IO ), Prevention of Significant Deterioration (PSD), Sulfur Dioxide (S02), Total Reduced Sulfur (TRS), Volatile Organic Compounds (YOC).

XXV. Open fires are prohibited except as allowed by Title 129, Chapter 30.

XXVI. Particulate Matter

- General Requirements (Title 129, Chapter 32)

(A) The permittee shall not cause or permit the handling, transporting or storage of any material in a manner, which allows particulate matter to become airborne in such quantities and concentrations that it remains visible in the ambient air beyond the property line.

Archer Daniels Midland Company-39285001.doc Class 1 Opernting Permit-Page 6

### (B) The permittee shall not cause or permit the construction, use, repair or demolition of a building, its appurtenances, a road, a driveway, or an open area without applying all reasonable measures to prevent particulate matter from becoming airborne and remaining visible beyond the property line. Such measures include, but not limited to, paving or frequent cleaning of roads, driveways and parking lots; application of dust-free surfaces; application of water; and planting and maintenance of vegetative ground cover.

XXVII. Application for review of plans or advice furnished by the Director will not relieve the permittee of legal compliance with any provision of these regulations, or prevent the Director from enforcing or implementing any provision of these regulations. (Title 129, Chapter 37)

XXVID. 

### If and when the Director declares an air pollution episode as defmed in Title 129, Chapter 38, Sections 003.0IB, 003.01 C, or 003.0ID, the permittee shall immediately take all required actions listed in Title 129, App. I until the Director declares the air pollution episode terminated. (Title 129, Chapter 38, Section 003)

XXIX. All reports and compliance certifications submitted shall contain certification by a responsible official of truth, accuracy, and completeness. This certification shall state that, based on information and belief formed after reasonable inquiry, the statements and information in the document are true, accurate, and complete. (Title 129, Chapter I, Section 098 and Chapter 7, Section 008)


### Specific Conditions

XXX. Terms and conditions of this permit are in accordance with the requirements of Nebraska Title 129, Chapter 8 Section 00 I. The specific applicable requirement which is the basis for each specific permit condition is listed with each permit condition. The specific conditions of this permit are:
(A) The New Source Performance Standards for Industrial-Commercial- Institutional Steam Generating Units, Subparts A 

### and Db (Title 129, Chapter 18, Sections 001.01 

### and 001.22) apply to boilers I, 2, 3, and 4. In the event of any discrepancies between this condition 

### and the NSPS standards, the NSPS standards take precedence unless they are less stringent. The requirements of Subparts A and Db include, but are not limited to, the following: (Construction permit issued July 12, 1995)

(I) Continuous Emissions Monitoring Systems (CEMs) shall be installed and certified, in accordance with Performance Specification 2 found in 40 CFR 60 Appendix B, for measuring NOx (nitrogen oxides) emissions from the boiler stacks.



### (B) The New Source Performance Standards for Equipment Leaks ofVOC in the Synthetic Organic Chemicals Manufacturing Industry-Subpart VV (Title 129, Chapter 18, Paragraph 001.14) apply to each pump, compressor, pressure relief device, sampling connection system, open-ended valve or line, valve, and connector used in the ethanol production process. They include but are not limited to the following requirements: The owner/operator shall comply with the equipment-specific standards specified in 40 CFR 60.482-1 through 60.482-10. Test methods and procedures shall be consistent with the requirements found in 40 CFR 60.485. Recordkeeping requirements shall be consistent

Archer Daniels Midland Company-3928S00I.doc Class I Operating Permit-Page 7with 40 CFR 60.486. Reporting requirements shall be consistent with 40 CFR 60.487, July 1992 edition. (Construction pennit issued July 12, 1995)

(C) The New Source Performance Standards for Volatile Organic Liquid Storage VesselsSubpart Kb (Title 129, Chapter 18, Paragraph 001.62) apply to the ethanol, denaturant, and denatured ethanol storage tanks. (Construction pennit issued July 12, 1995)



### (0) Particulate emissions: (Operating Pennit Condition)



### (l) Particulate matter emissions from each emissions unit shall not exceed the limits in Title 129, Chapter 20, Section 001 (Table 20-1) as applicable. Compliance with this condition may be demonstrated through compliance with Conditions XXX.(H), (I), (1), (K), (L), (M), (N), 

### (0), (P), (Q), (R), (X) and (Y);

(2) Particulate matter emissions from fuel combustion shall not exceed the limits in Title 129, Chapter 20, Section 002 and 003, as applicable. Compliance with this condition may be demonstrated through compliance with Condition XXX.(Y);

(3) Unless otherwise specified elsewhere in this pennit, opacity of visible emissions shall not equal or exceed 20%, as evaluated by an EPA-approved method in accordance with Title 129, Chapter 20, Section 004. Compliance with this condition may be demonstrated through compliance with Conditions XXX.(H), 

### (n, (1), (K), (L), (M), (N), (P), (Q), (R), (X), and (Y).

(E) Sulfur oxide emissions shall not exceed two and one half pounds per million BTU input (2.5 Ibs./MMBtu), maximum 2 hour average. Compliance with this condition may be demonstrated through compliance with Condition XXX.(Y)(2). (Title 129, Chapter 24) (Operating Pennit Condition)

(F) The New Source Performance Standards for Grain Elevators, Subpart DD (Title 129, Chapter 18, Section 001.19) apply to all whole grain unloading stations, and whole grain handling operations at this facility. These requirements include but are not limited to the following: (40 CFR, Part 60, Subpart DD)



### (l) Any grain handling operations other than grain dryers shall not emit particulate
matter in excess of 0.023 g/dscm 

### (Om gr/dsct) and shall not exhibit greater than 0% opacity.

(2) Fugitive particulate matter emissions from railcar unloading shall not exhibit greater than 5% opacity.

Compliance with subpart (I) of this condition may be demonstrated through compliance with Conditions XXX.(R), (I), (1), (K), and (L).

(G) The grain receiving for the entire facility shall not exceed a 365 day rolling average of 240,000 bushels per day. The processing (grind) rate of the source shall not exceed a 365 day rolling average of219,125 bushels per day. The amount of corn received and processed shall be recorded daily. (Construction Pennit issued July 3, 2001)

Archer Daniels Midland Company-3928S00I.doc Class I Operating Permit-Page 8

### (H) Specific conditions for the rail receiving and corn handling area: (Construction Permit issued July 3, 2001)

(I) Particulate matter emissions from the railcar unloading stations shall be controlled by use of a capture and control system, including use of a fabric filter dust collector (rail receiving area baghouse). The particulate matter capture and control system required by Conditions XXX.(H)(I) and XXX.(H)(3) shall be properly installed, maintained, and operated in accordance with Condition XXX.(M).

(2) Fugitive emissions from the railcar unloading stations shall be further reduced by choke loading the receiving pits. Additionally, the railcar unloading stations shall be partially enclosed by a roof and two (2) sidewalls.

(3) Particulate matter emissions from the elevator legs and conveying equipment shall be controlled by use of an emission capture and control system, including

use of a fabric filter dust collector (rail receiving area baghouse).

(4) On and after the 60 th 

### day of achieving the maximum production rate at which the affected facility will be operated, but no later than 

### 180 days after initial startup, the following apply.

(a) The rail receiving area baghouse effluent gas PMlPM IO 

### emissions shall
not exceed the following amounts:

(i) 1.371bs. per hour. {Nebraska Title 129, Chapters 17 and 19}

(ii) 0.005 grains per dry 

### standard cubic feet (gr/dscf)). {40 CFR 60J02(b)(I)}

(b) The rail receiving area baghouse effluent gas shall not exhibit greater than zero (0) percent opacity. {40 CFR 60.302(b)(2)}

(c) The fugitive emissions discharged into the atmosphere from the railcar unloading station shall not exhibit greater than five (5) percent opacity. {40 CFR 60.302(c)(I)}

Compliance with this condition shall be demonstrated by compliance with Conditions XXX.(M) and XXX.(X).

(I) 

### Specific conditions for the truck receiving and corn handling area: (Construction Permit issued July 3, 200 I)

(I) Particulate matter emissions from the east truck unloading pits #1 and #2 shall be controlled by use of a capture and control system, including use of a fabric filter dust collector (truck receiving pits #1 and #2 baghouse).

(2) Particulate matter emissions from the west truck unloading pits #3 and #4 shall be controlled by use of a capture and control system, including use of a fabric filter dust collector (truck receiving pits #3 and #4 

### baghouse).

Archer Daniels Midland Company-3928500I.doc Class I Opernting Permit-Page 9(3) The particulate matter capture and control systems required by Conditions XXX.(I)(I) and XXX.(I)(2) shall be properly installed, maintained, and operated in accordance with Condition XXX.(M).

(4) On and after the 60'" day of achieving the maximum production rate at which the affected facility will be operated, but no later than 180 days after initial startup, the following apply.

(a) The truck receiving pits #1 and # 2 area baghouse efIluent gas PMlPM IO emissions shall not exceed the following amounts:

(i) 0.52Ibs. per hour. {Nebraska Title 129, Chapters 17 and 19}

(ii) 0.005 grains per dry standard cubic feet (gr/dscf). {40 CFR 60.302(b)(1)}

(b) The truck receiving pits #3 and # 4 area baghouse effluent gas PMlPM IO emissions shall not exceed the following amounts:

(i) 0.52 Ibs. per hour. {Nebraska Title 129, Chapters 17 and 19}

(ii) 0.005 grains per dry standard cubic feet (gr/dscf). {40 CFR 60.302(b)(1)}

(c) The truck receiving pits #1 and #2 area baghouse effluent gas shall not exhibit greater than zero (0) percent opacity. {40 CFR 60.302(b)(2)}

(d) The truck receiving pits #3 and 

### #4 area baghouse eftluent gas shall not exhibit greater than zero (0) percent opacity. {40 CFR 60.302(b)(2)}

Compliance with this condition shall be demonstrated by compliance with Conditions XXX.(M) and XXX.(X).

(1) Specific conditions for the storage bin vents: (Construction Permit issued July 3, 2001)

(I) Particulate matter emissions from the corn storage bin vents shall be controlled by use of a capture and control system, including use of fabric filter dust collectors (18 bin vents).

(2) The storage bin vents efiluent gas shall not exhibit greater than zero (0) percent opacity. {40 CFR 60.302(b)(2)}

(3) The particulate matter capture and control system required by Condition XXX.(J)(I) shall be properly installed, maintained, and operated at all times an associated emission unit is operated. Manufacturer's instructions, if available, shall be kept on site and readily available to Department representatives.

To determine whether each fabric dust collector is functioning properly, regular observations (at least once weekly during operation) shall be conducted and

Archer Daniels Midland Company-3928S00 Ldoc Class I Opernling Pcnn.it·Page 10recorded to detennine whether there are excessive visible emissions from the stack, or other indications of poor performance requiring corrective action. Corrective action shall be taken immediately, if necessary.

(K) Specific conditions for the exterior gravity and vibrating com cleaners: (Construction Pennit issued July 3, 2001)

(I) Particulate matter emissions from the com cleaners shall be controlled by use of

a capture and control system, including use of a fabric filter dust collector (com cleaner baghouse). The particulate matter capture and control system required by Condition XXX.(K)(l) shall be properly installed, maintained, and operated in accordance with Condition XXX.(M).

(2) On and after the 60 th day of achieving the maximum production rate at which the affected facility will be operated, but no later than 180 days after initial startup, the following apply.

(a) The com cleaner baghouse effluent gas PMlOernissions shall not exceed the following amounts:

(i) 0.87Ibs. per hour. {Nebraska Title 129, Chapters 17 and 19}

(ii) 0.005 grains per dry standard cubic feet (gr/dscf)). {40 CFR 60.302{b)(l)}

(b) The com cleaner baghouse effluent gas shall not exhibit greater than

zero (0) percent opacity. {40 CFR 60.302{b)(2)}

Compliance with this condition shall be demonstrated by compliance with Conditions XXX.(M) and XXX.(X).

(L) Specific conditions for the com cleaner fines bin vents: (Construction Pennit issued July 3,2001)

(1) Particulate matter emissions from the com cleaner fines bin vents shall be controlled by use of a capture and control system, including use of a fabric filter dust collector (com cleaner fines bin vent baghouses). The particulate matter capture and control system required by Condition XXX.(L)(l) shall be properly installed, maintained, and operated in accordance with Condition XXX.(M).

(2) On and after the 60 th day of achieving the maximum production rate at which the affected facility will be operated, but no later than 180 days after initial startup, the following apply.

(a) The corn cleaner fmes bin vent baghouses effluent gas PMlPM IO emissions shall not exceed the following amounts:

(i) 0.1 lbs. per hour. {Nebraska Title 129, Chapters 17 and 19}

Archer Daniels Midland C<>mpany-3928500I.dnc Class I Operating Pennit-Page 11(ii) 0.005 grains per dry standard cubic feet (gr/dscf). {40 CFR 60.302(b)(1)}

(b) The corn cleaner flnes bin vent baghouses effluent gas shall not exhibit greater than zero (0) percent opacity. {40 CFR 60.302(b)(2)}

(3) The PMlPMlOconcentration of the corn cleaner fmes bin vent baghouse effluent
gas shall be tested within 90 days of pennit issuance in accordance with Condition XXX.(L)(3)(a-c) below to demonstrate compliance with the emission limit given in Conditions XXX.(L)(2)(a)(i) and XXX.(L)(2)(a)(ii). (40 CFR 60.302(b)}

(a) Method 5, given in 40 CFR 60 Appendix A, shall be used to determine the particulate matter concentration and the volumetric flow rate of the baghouse effluent gas. Method 17 may be used as an alternative to Method 5. {40 CFR 60.303(b)(l) and 40 CFR 60.303(c)(I)}

(b) The sampling time and sampling volume for each run shall be at least 60 minutes and 1.70 dscm (60 dscf). {40 CFR 60.303(b)(1)}

(c) The probe and f1lter holder shall be operated without heaters. (40 CFR 60.303(b)(l)}

(4) The opacity of the corn cleaner fines bin vent baghouse effluent gas shall be measured within 90 days of pennit issuance to demonstrate compliance with the opacity limit given in Condition XXX.(L)(2)(b). An EPA-approved method shall be used to measure opacity.

(M) Operation of each fabric dust collector controlling the rail receiving area, the truck receiving pits #1, #2, #3, and #4, the corn storage bins, and the corn cleaners shall be in accordance with the following requirements: (Construction Pennit issued July 3, 200 I)

(l) The fabric dust collectors shall be operated at all times associated equipment is in operation.

(2) The fabric dust collectors shall be properly installed, operated, and maintained. Manufacturer's instructions, if available, shall be kept on site and readily available to Department representatives.

(3) Each fabric dust collector shall be equipped with an operational pressure differential indicator, except for storage bin vents passive fabric dust collector system required in Condition XXX.(J)(l).

(4) Routine observations (at least once per day of dust collector operation, unJess otherwise noted) shall be conducted to determine whether there are visible emissions from the stack, leaks, or noise, atypical pressure differential readings (except as noted for storage bin vent fabric filtration system), or other indications that may necessitate corrective action. Corrective action shall be taken immediately if necessary.

An::her Daniels Midland Company·3928500 I.doc Class I Operating Permit-Page 12(N) Performance testing required under Condition XXX.(L) shall be conducted by reputable, qualified individuals. A testing protocol shall be submitted to the Department prior to the performance testing. Performance testing shall be conducted in accordance with the submitted protocol.

The source shall notify the Department of the anticipated testing date at least thirty (30) days prior to such date for any testing performed to demonstrate compliance with this permit. A written report of performance test results shall be furnished to the Department within forty-five (45) days after completion of the tests.

During any stack testing conducted at the source, the permittee shall also conduct a velocity traverse test during the performance test. The information collected should be analyzed by the source and submitted with the performance test results to the Department
to verify that the exit velocities are similar to exit velocities specified. 

### If the measured velocity varies significantly from velocities assumed for purposes of atmospheric dispersion modeling, the Department may require corrective actions or the remodeling of the source to demonstrate compliance with applicable ambient standards or maximum allowable increases. (Construction Permit issued July 3,2001)

(0) Permanent fencing shall be adequately maintained in order to restrict public access to the fenced area within. Tbis fencing shall comply with the requirements specified in the CP dated July 3, 2001.



### (P) PM JO emissions from Starch Dryer #2 shall not exceed 3.03 Ibs. per hour and 0.00438 grains per dry standard cubic foot. Compliance with tbis condition shall be demonstrated by compliance with Conditions XXX.(Q) and XXX.(R). (Construction Permit issued December 23, 1999)

(Q) Operation of the emissions control equipment for the starch dryer shall be in accordance with the following requirements: (Construction Permit issued December 23, 1999)

(I) The cyclones and scrubber shall be operated at all times during dryer operation.

(2) The cyclones and scrubber shall be properly installed, operated, and maintained. Manufacturer's instructions or equivalent operating instructions shall be kept on site and readily available to Department representatives.

(3) The cyclone and scrubber shall be equipped with an operational pressure differential indicator. The pressure differential indicator readings shall be recorded at least once each shift that the associated cyclone and scrubber is operating.

(4) The scrubber shall be equipped with a device to monitor the liquid flow rate to the scrubber in terms of gallons per minute (gpm). The scrubber liquid flow rate shall be recorded at least once each sbift that the associated scrubber is operating.

(5) The pressure drop across the cyclone shall be between 10" and 20" WC, and the pressure drop across the scrubber shall be between 5" and 15" WC. The minimum scrubber recirculation water flow rate shall be 400 gpm.

Archer Daniels Midland Company-3928500I.doc Class I Operating Permit-Page 13

### (6) To determine whether each cyclone and scrubber is functioning properly, regular observations (at least once each day of operation) shall be conducted and recorded to determine whether there are excessive visible emissions from the stack, excessive leaks or noise, pressure differential readings outside of the established range, or other indications of poor performance requiring corrective action. Corrective action shall be taken immediately if necessary.

(7) Collected product material from the cyclones shall not be handled, transported,

or stored in a manner that may allow particulate matter to become airborne in such quantities and concentrations that it remains visible in the ambient air beyond the premises where it originates.

(R) Operation of each fabric dust collector controlling the starch storage bins (13 and 14), the pneumatic starch dryer transportlIoadout receiver, and the pneumatic off spec starch receiver (bin 9) shall be in accordance with the following requirements: (Construction Permit issued December 23, 1999)

(I) 

### The fabric dust collectors shall be operated at all times associated equipment is in operation.

(2) The fabric dust collectors shall be properly installed, operated, and maintained. Manufacturer's instructions shall be kept on site and readily available to Department representatives.

(3) Each fabric dust collector shall be equipped with an operational pressure differential indicator. The pressure differential indicator readings shall be recorded at least once each shift that the associated fabric dust collector is operating.

(4) The pressure drop across each fabric dust collector controlling the starch storage bins, the pneumatic starch dryer transportlIoadout receiver, and the pneumatic off spec starch receiver shall be between 0" and 5" WC.

(5) Fabric dust collector filter bags are to be inspected and/or replaced according to the manufacturer's recommendations or more frequently as indicated by pressure differential indicator readings. To determine whether each fabric dust collector is functioning properly, regular observations (at least once each day of dust collector operation) shall be conducted and recorded to determine whether there

are excessive visible emissions from the stack, excessive leaks or noise, pressure differential readings outside of the established range, or other indications of poor performance requiring corrective action. Corrective action shall be taken immediately if necessary.
(6) Collected product material from the fabric dust collectors shall not be handled, transported, or stored in a manner that may allow particulate matter to become airborne in such quantities and concentrations that it remains visible in the ambient air beyond the premises where it originates.

Archer Daniels Midland Company-3928500I.doc Class I Operating Permit-Page 14(S) The two starch storage bins (13 and 14) associated with the new starch dryer line shall
not be filled simultaneously. The source shall keep records of when each bin is filled. (Title 129, Chapter 19) (Construction Permit issued December 23, 1999)

(T) The following condition applies to: ETHANOL PRODUCTION AND LOADOUT (Construction Permit issued March 31, 2003)

(I) Ethanol production and loadout shall not exceed 100,000,000 gallons in any twelve (12) consecutive calendar month period, excluding the denaturant blended into the 

### fina1 product before shipment. (Title 129, Chapter 19) (Construction Permit issued 2002)

(2) Submerged loading shall be used when transferring liquid product (denarured ethanol) from the storage tanks to railcar or tank truck. (Title 129, Chapter 19)

(3) The truck and railloadout shall be equipped with a vapor recovery system that is routed to and controlled by a flare. (Title 129, Chapter 19)

(4) The vapor recovery system shall have a minimum overall collection/control efficiency of 95%. (Title 129, Chapter 19)

(5) The vapor recovery system shall be properly designed, installed, operated, and maintained. Manufacturer's specifications shall be kept on site and readily available to Department representatives.

(6) The flare shall be operated with a flame present at all times the truck and railcar loadout is in operation. A thermocouple or equivalent device capable of continuously monitoring the flame shall be installed. The thermocouple shall be calibrated in accordance with manufacrurer's instructions.

(7) The vapor recovery system and flare shall be installed, operating, and in compliance with paragraph (T)(4) of this condition no later than twelve (12) months from the startup date of the modification.

(U) The following conditions apply to: FERMENTATION (Construction Permit issued March 31, 2003)

(I) For the two existing fermentation scrubbers (SV #32 and 33) the following conditions apply: (Title 129, Chapter 19)

(a) The total combined VOC emission rate shall not exceed 10.0 lbslhr.

(2) Compliance with Condition XXX.(U)(I)(a) shall be demonstrated by conducting

an initial performance test pursuant to Title 129, Chapter 34. The performance
test shall include speciation and quantification of the hazardous air pollutant composition of the emissions from each scrubber. All tests shall be conducted by reputable, qualified individuals within 60 days of achieving maxiroum production output, but no later than 180 days after the startup date of the modification. A source test protocol must be submitted and approved by the Department prior to testing. ADM shall notify the Department of the anticipated

Archer Daniels Midland Company·3928500I.doc Class I Operating Pennit-Page 15

### testing date at least 30 days prior to such date. A written report of the performance test results shall be furnished to the Department within 45 days after completion of the tests.

(3) The source shall test the ethanol produced at this facility for speciation and quantification of the HAP content. A minimum of one liquid sample shall be taken concurrently with the scrubber testing required in Condition XXX.(U)(2) and results submitted with the referenced scrubber test results. (Title 129, Chapter 27)

(4) The scrubber systems shall be properly maintained and operated in accordance with parameters established at the time of compliance testing and with good air pollution control practices at all times the associated emission units are operating.

(V) 

### The following condition applies to: BOILER NOS. 1,2,3, AND 4 (Construction Pennit issued March 31, 2003)

Total nitrogen oxides (NO,.) emissions from boiler Nos. I, 2, 3, and 4 combined shall not exceed 174.16 tons per twelve consecutive calendar month period. Compliance with this limit shall be calculated based on boiler CEM data and natural gas usage records.

(y.f) 

### The following conditions apply to the haul traffic fugitive emissions: (Construction Permit issued April IS, 2003)

(I) The maximum number of grain haul trucks entering ADM property and unloading their cargoes shall not exceed 300 trucks per day. A maximum of 45 additional corn delivery trucks per day shall be allowed to enter the ADM property and stage, without unloading, on the haulage road between the corn truck unloading facility and 8 th 

### Street. To demonstrate compliance with this condition, the pennittee shall maintain records of the number of trucks unloaded each day.

(X) Periodic monitoring requirements for emission sources subject to opacity standards, including but not limited to the 20% visible emissions opacity standard of Title 129, Chapter 20 and the 0% opacity standard of Title 129, Chapter 18, Section 001.19, are as follows: (Title 129, Chapter 8, Section 012.01, Chapter 20, Section 004, and Chapter 18, Section 001.19) (Operating Permit Condition).

(1) Visible emissions shall be observed on a daily basis, unless otherwise specified in the permit, to ensure that no visible emissions except water vapor occur from the facility, including but not limited to the emission sources listed in Table 1. 

### If visible emissions are observed, this would be considered a deviation and corrective action shall be initiated as soon as possible.

(2) 

### If corrective action does not return the observation to no visible emissions, then

a source representative trained in EPA Test Method 9 shall conduct a visible emissions observation according to Method 9. If during the Method 9 observations opacity readings are greater than 20% for sources subject to the 20% limit, this would be considered a deviation. If during the Method 9

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### observations any visible emissions except water vapor are observed for sources subject to a 0% limit, this would be considered a violation.

(3) If 

### weather or lighting conditions prevent the observer or person trained in EPA Test Method 9 from conducting a visible emissions observation, the observer shall note such conditions for the record. At least two attempts shall be made to retake the observation during daylight hours.

(4) The results of the daily visible emissions surveys shall be recorded in a log, which shall include, at a minimum, all emission points from Table I and whether

or not visible emissions (except for water vapor) occurred.

(5) For emission point(s) with visible emissions that equal or exceed 20% opacity or the applicable standard during the visible emissions surveys performed pursuant to Condition XXX.(X).(2), the source representative shall proceed with appropriate corrective action and record the following:

(a) The cause of the emissions.

(b) The corrective action taken and the approximate opacity in increments of 5%, following corrective action.

(6) Records of individuals trained in EPA Test Method 9 shall be kept on site for at least 5 years. Trained in EPA Test Method 9 shall mean someone who has participated in the classroom and field observation exercises at least once in the last 5 years and has received certification at least once in the last 5 years.
(7) A compliance schedule is set as follows:

(a) The facility shall have a ninety (90) day period from the issuance of this pennit to conduct the required Method 9 training per condition XXX(X)(6).

(b) During the period visible emission surveys shall be conducted and corrective action shall be taken if necessary.

Table 1. 

### Ooacitv Monitorinl! Source List SV# Eouioment Descrintion SV# Eouinment Descrintion

4 Com Cleaner Baghouse 28 Gluten Stora"e Bin No.5
6 Starch Dryer No. I Scrubber 29 Gluten Stora"e Bin No.6 7 Germ Dryers 1-3 (Sly Scrubber) 30 Gluten Storage Bin No.7 8 Fluidized Bed Germ Dryer 31 Gluten Storage Bin No.8 9 Germ Cooling Baghouse No. I 35 Carbon Furnace No. I 10 Germ Cooling Baghouse No.2 36 Carbon Furnace No.2 

### 11 Germ Cooling Baghouse No.3 38 BoilerNo. I 12 Germ Cooling Baghouse NO.4 39 Boiler No. 2 16 Gluten Flash Dryer No. I 40 Boiler Nos. 3 and 4

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### 17 Gluten Cooling Bal!llOuse No. I 42 Com Fines Transfer Baghouse
18 Gluten Flash Dryer No.2 44 Gluten Recvcle Baghouse
19 Gluten Cooling Baghouse No.2 45 Starch Dryer #2 Scruhber 20 Starch Storage Bin No. 11 46 Starch Bin No. 13
21 Starch Storage Bin No. 12 47 Starch Bin No. 14
23 Starch Storage Bin No. 10 48 Starch Dryer #2 Loadout Receiver
24 Germ Storage Bin No. I 22 Starch Storage Bin No.9 25 Germ Storage Bin No.2 62 Lime Silo Bin Yent 26 Germ Storage Bin No.3 63 Soda Ash Receiving Yent 27 Germ Storage Bin No.4

(Y) 

### A compliance schedule is set as follows: (Title 129, Chapter 19 and EPA Consent Decree filed August 21, 2003)

(I) On or before December 15,2003, the permittee shall submit a PSD permit application for the Columbus facility and correct such increment and NAAQS non-compliance as might be indicated in the PSD application and permitting process as required by the EPA consent decree.

(2) Until such time as the revised PSD permit is issued, the permittee shall continue
to comply with the PSD permit issued for this facility on July 12, 1995.

(3) Within one hundred eighty (180) days of issuance of the revised PSD permit, the permittee shall submit an application for a Class I Operating Permit Modification
to incorporate the revised PSD permit into this operating permit.

(Z) On August 21, 2003 a Consent Decree negotiated under United States v. ADM (C.D. IL, No. 03-CY-2066), was filed with the U.S. District Court

- Central District of Illinois. This Consent Decree requires certain emission units and control equipment at the facility have emission limits requiring pollution control technology or alternative projects designed to reduce emissions. The permittee shall comply with all 

### applicable requirements and schedules in the Consent Decree.

(AA) A compliance schedule is set as follows: (Title 129, Chapter 6, Section 002.03A and Chapter 17, Section 001.01 H)



### (I) ADM shall submit a facility-wide emission inventory for HAPs within one hundred eighty (180) calendar days following issuance of this permit.

(2) Emissions sources that should be addressed include, but are not limited to, combustion units, fermentation equipment, fugitive equipment leaks, ethanol loadout, distillation equipment, and all ethanol and denaturant storage tanks.

(AB) The source shall comply with the requirements of 40 CFR Part 68, Accidental Release Prevention Requirements. The source shall submit a Risk Management Plan in accordance with 40 CFR Part 68 no later than the latest of the following dates: (NOPC Title 129 Chapter 8)

Archer Daniels Midland**Company~3928500I.doc** Class 1 Operating Permit·Page 18(I) Three years after the date on which a regulated substance is first listed under 40 CFR Section 68.130; or

(2) The date on which a regulated substance is first present above a threshold quantity in a process

(AC) Clear and readily accessible records of all measurements, results, inspections, and observations listed above, as conditions of this permit, shall be maintained on-site for a minimum period of 5 year.; unless specified otherwise. These records shall be updated to be current through the end of the previous month no later than the 15"' day of each calendar month. Wherever the record involves a quantity, monthly totals and a running total for the preceding 12-month period must be maintained. 

### If continuous monitoring is done, then the monitored quantities shall be totaled daily in addition to monthly and for the preceding 12-month period. These records shall be clear and readily accessible to department representatives and shall include the following (Title 129, Chapter 34): (previous Construction Permits and Operating Permit Conditions)

(I) Daily records of com receiving and processing to demonstrate compliance with Condition XXX.(G). (July 3, 200 I Construction Permit condition)

(2) Inspection and maintenance records for each fabric dust collector, cyclone, and scrubber, to show compliance with Conditions XXX.(M), XXX.(J), XXX.(Q) and XXX.(R), including the following: (July 3, 200 I and December 23, 1999 Construction Permit condition)

(a) Records documenting when routine maintenance and inspections were performed with a description of the maintenance and/or inspection performed.

(b) Records documenting pressure gauge readings and when readings were taken.

(c) Maintenance records for scrubber and scrubber recirculating water flow
rate. Dust collector fIlter replacement records including fIlter position (location in dust collector housing), type of filter, and the date of filter installation.

(d) Records documenting equipment failures, malfunctions, or other variations, including time of occurrence, remedial action taken, and when corrections were made.

(3) In addition to the requirements of Conditions XXX.(Q) and XXX.(R) maintenance and inspections shall be performed according to the manufacturer's suggested reco=endations and schedule, compliance or maintenance plan, or

more frequently if regular breakdowns occur. (December 23, 1999 Construction Permit condition)

Archer Daniels Midland Company·39285001.doc Class I Operating Permit-Page 19(4) Ethanol production and loadout, recorded daily and compiled monthly by the 15 th day of each month for the previous month and the previous 12 consecutive calendar month period. (March 31, 2003 Construction Permit condition)

(5) Monitoring records for the ethanolloadout flare, to demonstrate compliance with Condition XXX.(T)(6). (March 31, 2003 Construction Permit condition)

(6) Compliance test results required in Conditions XXX.(U)(2) and XXX.(U)(3). (March 31, 2003 Construction Permit condition)

(7) Natural gas usage and average CEM values, recorded daily for each boiler in operation during that day and compiled monthly by the 15 th day of each month for the preceding 12 consecutive calendar month period. These records shall be used to demonstrate compliance with the NO. emissions limit in Condition XXX.(V). (March 31, 2003 Construction Permit condition)

(8) Any exceedance of the limits of Conditions XXX.(T)(I) and/or XXX.(V) shall be reported to the Department upon discovery. A written statement shall be submitted within 15 days after discovery of non-compliance, which will include information as required by Title 129, Chapter 35, Section 002. (March 31, 2003 Construction Permit condition)

Pursuant to a Delegation Memorandum dated May 3, 2000, and signed by the Director, the undersigned hereby executes this document on behalf of the Director.

Date

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