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 capacity, 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 information 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 the 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 responses 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 paragraphs 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 temporary 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 obtain 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 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 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 vinyl 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 (specify): (c) City: 

(d) State: (e) Zip Code: (f) County: 

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

A-4 (a) Technical contact (for information 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 all 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) 

ARCH COLU ADM Corn Processing - Columbus 3000 E 8th St Columbus NE 68601 Platte Luther Pohlmann 402-564-6353 ext 5299 402-562-5006 Environmental Specialist kevin.whited@adm.com 4250

Archer Daniels Midland Company ■

4666 Faries Pkwy

Decatur NE 62526 ■

■

Kevin R. Whited
§B-4 Overview Flow Diagram 

FACID: ARCHCOLU

Truck Pit 

(2) R-1 

(WM-01)

P-2 

Silo 4-8 

(Group) 

(WM57-

61) 

P-1 

Silo 1-3 

(Group) 

(WM54-

56) 

P-3 

Silo 9-

12 

(Group) 

(WM72-

79)

P-4 

Silo 13-

17 

(Group) 

(WM80-

89)

Truck Pit 

(2) R-2 

(WM-02)

Rail Pit 

R-3 

(WM-71)

Corn 

Cleaner 

(WM-03) 
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) "temporary" storage 

 (c) "emergency" storage 

[Note: In completing the remainder of the survey, you will be able to group information for similar 

storage units. See B-4 for example.]

B-4 Please provide an overview flow diagram (or block flow diagram) of the grain elevator(s) at 

your facility. Please include permanent (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 numerical 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 explanations on the back of this 

sheet or indicate in your elevator diagram. 

o Temporary Storage ID: use your current designation or assign a numerical value. If assigning 

a new ID, please use “T-1, T-2” format. 

o Emergency Storage ID: use your current designation or assign a numerical 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 designation 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 numerical 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. 

ARCH COLU 1992 17
FORM B 

Please 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 

Storage Type 

(P, T, E) 

Storage 

ID 

Year First 

Used 

Storage 

Capacity 

(Bushels)2

Grain 

Stored1 Through-put (actual bushels)2 Weeks per year utilized Through-put (actual bushels)2 Weeks per year utilized T

(ac

Corn 100,000 2 P - example P-1 1970 300,000 

Wheat 400,000 

50 

300,000 50 

P - example P-2 1985 400,000 Corn 400,000 52 400,000 50 

T - example T-1 2004 450,000 Corn 200,000 22 250,000 20 

1 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 th

temporary and emergency storage units, storage capacity and throughput may be estimated based on operator’s knavailable. For permanent storage units, throughput may be estimated based on operator’s knowledge if actual data 

ARCH COLU P (Grouped) P (Grouped) P-1 1992 407,025 Corn 19,901,190 52 20,049,563 52 

P (Grouped) P-2 1995 630,854 Corn 19,901,190 52 20,049,563 52 

P-3 2002 563,012 Corn 19,901,190 52 20,049,563 52 

P (Grouped) P-4 2002 1,482,796 Corn 19,901,190 52 20,049,563 52 
FORM C 

Please 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-2 Please complete the following table for receiving and shipping operations at each storage unit (or grou

Storage, Shipping, and Receiving ID’s provided in B-4. An example is provided. 

What is the Maximum Loading Receiving/ Rate? 

Shipping 

ID 

Storage ID 

associated with 

receiving/ 

shipping unit 

How is Grain Received Into or 

Shipped (Loaded) Out of 

Storage?a Value Units 

Are there any add

on controls for th

receiving/ 

shipping unit (Y/N

R-1 P1 Fixed Conveyor Belt 

S-1 P1 Fixed Conveyor Belt 

R-1 T1 Portable Auger 

aLoading and unloading methods include: 

 portable auger  fixed receiving pit with leg to aeration tower  enmass drag conve

 portable inclined belt  fixed conveyor off main complex  pneumatic unloader  gravity fill spout  portable conveyor with trucks  or specify a differen front-end loader  marine leg  fixed drag conveyor  track hoe/clamshell unloader  fixed conveyor belt  continuous barge unloader bQualitative methods include opacity measurements as well as monitoring instruments (e.g. CEMS), and mon

indicate whether the air pollution control device is operating properly. 

ARCH COLU R-1 P1 Fixed Drag Conveyor 10,000 Bu/Hr Y 

R-2 P1 Fixed Drag Conveyor 10,000 Bu/Hr Y R-3 P2 Fixed Drag Conveyor 20,000 Bu/Hr Y R-4 P2 Fixed Drag Conveyor 20,000 Bu/Hr Y R-5 P3-4 Fixed Drag Conveyor 20,000 Bu/Hr Y 
FORM D – “Temporary” Storage 

(D-1) FACID: (D-2) Temporary Storage ID: 

FORM D Page 1 

 (Please copy this sheet and complete 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 times of the year. If this 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: 

ARCH COLU
FORM D – “Temporary” Storage 

(D-1) FACID: (D-2) Temporary Storage ID: 

FORM D Page 2 

D-6 Describe the routine maintenance (including repair 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., replacement of a tarp/cover in sections, as opposed to entire 

replacement), indicate frequency and typical percent of the entire unit that is replaced. 

Walls: 

 Floors: 

Cover/Tarp: 

Aeration: 

Other equipment associated with storage (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).

ARCH COLU
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. 

ARCH COLU
FORM F – Grain Dryers 

(F-1) FACID: 

 

FORM F Page 1 

F- Please complete the following table for grain dryers used at your facility. Use the Dryer, 

Storage, Shipping, and Receiving 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 Used1

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 the dryer is used; and (3) provide the year of 

original installation. 

ARCH COLU
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 requirement in your permit? 

 (check one) Y N 

As defined in NSPS, Subpart DD, grain handling operations include, as an assemblage of equipment, bucket elevators or 

legs (excluding legs used to unload barges or ships), scale 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 only 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 restrictions on operational parameters 

such as hours, feedstock or throughput. 

ARCH COLU 4 4

1 1

■
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,” please 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 operationsa 

a

As defined in NSPS, Subpart DD, grain handling operations include, as an assemblage of equipment, bucket elevators or 

legs (excluding legs used to unload barges or ships), scale hoppers and surge bins (garners), turn heads, scalpers, 

cleaners, trippers, and the headhouse and other such structures. 

ARCH COLU

Indoor unloading, choke flow, fast roll doors, dust collection system, daily housekeeping. Used all the time Indoor unloading, choke flow, plastic strips on doorways, dust collection system, daily housekeeping. Used all the time. Dust collection system, daily housekeeping. Used all the time.
FORM I – Add-on Pollution Control Device 

(I-1) FACID: FORM I If data are not available or unknown, please enter ND I-2 Please complete the following table for any air pollution control devices at your facility. Please provide I

diagram. For each unit, please provide the most recent performance data you have. An example is pro

Air Pollution Control 

Device ID 

Type of Control [e.g., fabric 

filter/baghouse; cyclone; 

other (specify)] 

Points controlled 

by this control 

(Use ID’s from 

Forms B, C, and 

D) 

Type of Data Available [e.g., 

performance test, manufacturer’s 

specs or guarantee, engineering 

calculations, other (specify)] 

Desig

Efficien

APCD-1 example Cyclone R-1, R-2 Manufacturer’s specifications 40% APCD-2 example Fabric Filter S-1 Manufacturer’s specifications 90% Make additional copies, as necessary 

ARCH COLU WM-01 Fabric Filter R-1-2 Manufactures specifications 0.005 grains

WM-02 Fabric Filter R-3-4 Manufactures specifications 0.005 grainsWM-71 Fabric Filter R-5 Manufactures specifications 0.003 grainsWM-03 Fabric Filter Grain Handling Manufactures specifications 0.003 grainsWM-54 Fabric Filter P-1 Manufactures specifications 0.005 grainsWM-55 Fabric Filter P-1 Manufactures specifications 0.005 grainsWM-56 Fabric Filter P-1 Manufactures specifications 0.005 grainsWM-57 Fabric Filter P-2 Manufactures specifications 0.005 grainsWM-58 Fabric Filter P-2 Manufactures specifications 0.005 grainsWM-59 Fabric Filter P-2 Manufactures specifications 0.005 grains
FORM I – Add-on Pollution Control Device 

(I-1) FACID: 

FORM I  Page 2 

I-3. Provide a copy of the most recent 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 control device listed in I-2. 

Inlet Flow Pressure Drop Inlet Temperature 

APCD ID Max Units Min Max Units Min Max o

C/oF 

 

I-5 For each cyclone, please complete the following table 

APCD ID Particle Density Units 

 

ARCH COLU Ambient WM-01 12,187 DSCF/MIN 0.5 10 In H2O Ambient Ambient oF WM-02 12,187 DSCF/MIN 0.5 10 In H2O Ambient Ambient oF WM-71 32,013 DSCF/MIN 0.5 10 In H2O Ambient Ambient oF WM-03 20,370 DSCF/MIN 0.5 10 In H2O Ambient oF WM-54-56 369 DSCF/MIN ND ND ND ND ND oF WM-57-61 369 DSCF/MIN ND ND ND ND ND oF WM-72-79 369 DSCF/MIN ND ND ND ND ND oF WM-80-89 369 DSCF/MIN ND ND ND ND ND oF
FORM I – Add-on Pollution Control Device 

(I-1) FACID: 

FORM I  Page 3 

I-6. For each fabric filter/baghouse, please 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 technology and the parameters that 

are relevant for operation of the control 

ARCH COLU WM-01 416 9802 1

WM-02 416 9802 1

WM-71 270 7634 1

WM-03 124 3506 1

WM54-61 and WM72-89 are passive bin vents with a fabric filter. No pressure differential is measured. Temperature is the 

ambient temperature.
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 Section 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 provision of this Act. Among 

other things, Section 114 authorizes EPA to make inspections, 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 information 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. 

 

 1Section 114 requires public availability of all emission data 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 I If data are not available or unknown, please enter ND I-2 Please complete the following table for any air pollution control devices at your facility. Please provide I

diagram. For each unit, please provide the most recent performance data you have. An example is pro

Air Pollution Control 

Device ID 

Type of Control [e.g., fabric 

filter/baghouse; cyclone; 

other (specify)] 

Points controlled 

by this control 

(Use ID’s from 

Forms B, C, and 

D) 

Type of Data Available [e.g., 

performance test, manufacturer’s 

specs or guarantee, engineering 

calculations, other (specify)] 

Desig

Efficien

APCD-1 example Cyclone R-1, R-2 Manufacturer’s specifications 40% APCD-2 example Fabric Filter S-1 Manufacturer’s specifications 90% Make additional copies, as necessary 

ARCH COLU WM-01 Fabric Filter R-1-2 Manufactures specifications 0.005 grains

WM-02 Fabric Filter R-3-4 Manufactures specifications 0.005 grainsWM-71 Fabric Filter R-5 Manufactures specifications 0.003 grainsWM-03 Fabric Filter Grain Handling Manufactures specifications 0.003 grainsWM-54 Fabric Filter P-1 Manufactures specifications 0.005 grainsWM-55 Fabric Filter P-1 Manufactures specifications 0.005 grainsWM-56 Fabric Filter P-1 Manufactures specifications 0.005 grainsWM-57 Fabric Filter P-2 Manufactures specifications 0.005 grainsWM-58 Fabric Filter P-2 Manufactures specifications 0.005 grainsWM-59 Fabric Filter P-2 Manufactures specifications 0.005 grains
FORM I – Add-on Pollution Control Device 

(I-1) FACID: FORM I If data are not available or unknown, please enter ND I-2 Please complete the following table for any air pollution control devices at your facility. Please provide I

diagram. For each unit, please provide the most recent performance data you have. An example is pro

Air Pollution Control 

Device ID 

Type of Control [e.g., fabric 

filter/baghouse; cyclone; 

other (specify)] 

Points controlled 

by this control 

(Use ID’s from 

Forms B, C, and 

D) 

Type of Data Available [e.g., 

performance test, manufacturer’s 

specs or guarantee, engineering 

calculations, other (specify)] 

Desig

Efficien

APCD-1 example Cyclone R-1, R-2 Manufacturer’s specifications 40% APCD-2 example Fabric Filter S-1 Manufacturer’s specifications 90% Make additional copies, as necessary 

ARCH COLU WM-01 Fabric Filter R-1-2 Manufactures specifications 0.005 grains

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,

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 8th 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 8th Street

Columbus, Nebraska 68601-9073

Pursuant to Title 129, Chapter 14, ofthe Nebraska Air Quality Regulations, the public has been

notified by prominent advertisement ofthis 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 ofthe 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 ofthis 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 IOperating 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 ofthis 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 ofthis pennit:

Subpart A - Production and Consumption Controls

Subpart B - Servicing ofMotor 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 oflabel 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 offive (5) years. A renewal application shall be submitted

to the Department a minimum ofsix (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)

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VI. The pennittee shall comply with all conditions ofthis 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 ofEPA 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 ofthe 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 ofthe pennit, and refusal ofthe pennittee to agree to an

enforceable schedule of compliance to resolve the noncompliance;

(B) The submittal by the pennittee offalse, incomplete, or misleading information to the

Department or EPA;

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(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 ofthe permittee to pay a penalty owed pursuant to court order, stipulation

and agreement, or order issued by the Administrator ofthe 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 ofrecords

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 ofthis 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 ofthis permit, the unchallenged permit requirements

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

xv. Certification of compliance with the terms and conditions ofthis 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 ofthe

certification;

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

(I) reports of deviations shall include the probable cause ofsuch 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 ofthe 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 ofthe following year. Each report must be

Archer Daniels Midland Company-3928500l.doc

Class IOperating Pennit-Page 4
certified 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 ofthe

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 ofthis permit, compliance with the specific conditions identified in

Condition XXX, constitutes compliance with the underlying applicable requirement, as

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ofthe 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 ofthe 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 ofChapter 26;

(4) The authority ofthe 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 ifthe 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 ofTitle

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 (PMIO), 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.

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Class 1Opernting 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

oflegal 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 ofNebraska 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 ofthis

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

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with 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) ofthis 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 ofthe 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)

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(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 60th 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 PMlPMIO 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).

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(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 PMlPMIO

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 PMlPMIO

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 offabric 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

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Class IOpernling Pcnn.it·Page 10
recorded 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 60th 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 60th 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 PMlPMIO

emissions shall not exceed the following amounts:

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

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(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 ofthe 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 ofthe

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 ofthe 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.

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(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 ofthe 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. Ifthe 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) PMJO 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.

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(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 ofthe

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 offspec 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

offspec 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 ofthe 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.

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(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 ofthe 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 ofthe 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 ofthe

modification. A source test protocol must be submitted and approved by the

Department prior to testing. ADM shall notify the Department ofthe anticipated

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testing date at least 30 days prior to such date. A written report ofthe

performance test results shall be furnished to the Department within 45 days

after completion ofthe 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 8th Street. To demonstrate compliance with this

condition, the pennittee shall maintain records ofthe number oftrucks 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 ofTitle 129,

Chapter 20 and the 0% opacity standard ofTitle 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) Ifcorrective 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) Ifweather 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 ofthe 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 ofthe emissions.

(b) The corrective action taken and the approximate opacity in increments of

5%, following corrective action.

(6) Records ofindividuals 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 ofthis

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 ofissuance ofthe 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 ofIllinois.

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 ofthis 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 of40 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)

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(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 ofthe 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. Ifcontinuous 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 offilter, 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 ofConditions 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 ifregular breakdowns occur. (December 23, 1999 Construction

Permit condition)

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(4) Ethanol production and loadout, recorded daily and compiled monthly by the 15th

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 15th 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 ofthe 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 ofthe Director.

Date

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