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 currentreceipt 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.

### 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)

### 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 controlENCLOSURE 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).

### Facility ID: AGPRDAWS Facility Diagram

R

‐ 1 P

‐ 1

D

‐ 2 D

‐ 1 P

‐ 2 R

‐ 3 E

‐ 1

S

‐ 1

R

‐ 2 APCD1 APCD2

Beans Received via Truck Beans Received via Truck Beans Received via TruckTesting Date(s): Report Date:

Revision Date:

Subject Facility: Ag Processing, Inc. Ag Processing, Inc. 800 Diagonal Street
Dawson, MN 56232

Telephone No.: Regulatory Permit No.:

07300002-002

Subject Emission Sources: Dryer Deck Cyclone SV029 Top Dryer Deck Cyclone SV031 Hammermill (Drying) SV007 W Dryer Exhaust Vent SV016 E Dryer Exhaust Vent SV017 New Mac Dehulling Disc. SV018 Telephone No.: Cracking & Flaking SV020 E-mail Address: Hammermill (Meal Grind) SV027 Cooler Cyclone SV030 #1 Side Flaker Aspiration SV055 terry.borgering@pacelabs.com (612) 607-6374 No revison to date

Report Prepared For:

Report Preparation Supervised By:

1700 Elm Street, Suite 200

Minneapolis, MN 55414 Terry Borgering Pace Analytical Services, Inc. 

# Emissions Test Report Comprehensive

Mark McCormick Ag Processing, Inc. 800 Diagonal Street
Dawson, MN 56232 Ag Processing, Inc.

November 18, 2009

Pace Project No. 0909-108 (320) 769-4386 Compliance Testing Opacity

October 30, 2009

## Table of Contents

Report Cover 1

Table of Contents 2

Introduction 3
Results Summary 4

Detail Tables 5
Tables 1-10 Results of Opacity Observations 6

Process Description 1 6

Test Procedures Summary 1 7

Report Signatures 1 8

Appendix A Field Data Sheets and Notes A-1

Appendix B Quality Assurance Data B-1

Appendix C Process Information C-1

Appendix D Test Plan and Test Correspondence D-1

## Introduction

Pace Analytical Services, Inc. personnel con ducted visible emission compliance testing

on ten sources located at the Ag Processing, Inc. facility located in Dawson, Minnesota.

Matt McDermott performed on-site testing activities. Terry Borgerding provided

administrative project management. Marc McCormick with Ag Processing, Inc.

coordinated facility activities. Pace Anal ytical Services, Inc. prepared a comprehensive

test protocol that was subm itted to the MPCA and approved prior to testing. On-site

activities consisted of the following measurements:

- Opacity, one independ ent one-hour observation period on each unit.

The project objectives were to quantify opac ity emission constituents and compare them

to applicable air emissions regulations stip ulated by MPCA and the facility permit.

These measurements were performed at normal operating condition. Quality protocols

comply with all regulatory comp liance testing requirements.

Subsequent sections summarize the test resu lts and provide descriptions of the process

and test methods. Supporting information and raw data are in the appendices.

## Results Summary

Results of opacity observations are summariz ed in Tables 1-10. All observational

readings on the ten sources tested were 0%. The permitted opacity limit for these

sources is 20% except for SV027 (Meal Grind Hammermill) which has a limit of 10%,

and SV055 (No.1 Side Flaker Aspiration) which has a limit of 2.5%. The process rates

of these emission sources were at normal operating condition duri ng testing. Process

rate information can be found in Appendix C.

The data in this report are indicative of emission char acteristics of the measured

sources for process conditions at the time of the test. Representations to other sources

and test conditions are beyond the scope of this report.

## Detail Tables

## Ag Processing, Inc.

Dawson, Minnesota Opacity Evaluation
Pace Project No. 0909-108 East Dryer Exhaust-SV017

Test 1

Percent Opacity Optical Density Relative Frequency

0 0.000 100.00

5 0.022 0.00

10 0.046 0.00

15 0.071 0.00

20 0.097 0.00

25 0.125 0.00

30 0.155 0.00

35 0.187 0.00

40 0.222 0.00

45 0.260 0.00

50 0.301 0.00

55 0.347 0.00

60 0.398 0.00

65 0.456 0.00

70 0.523 0.00

75 0.602 0.00

80 0.699 0.00

85 0.824 0.00

90 1.000 0.00

95 1.301 0.00

99 2.000 0.00

Average > 0.0 0.000 Total > 100

Average Opacity Per Sequential Six Minute Period: High Six Minute Average: 0.0
Period Opacity Period Opacity Maximum reading: 0.0

1 0.0 6 NA Minumum reading: 0.0

2 0.0 7 NA

3 0.0 8 NA Observer: Matt McDermott

4 0.0 9 NA Date of test: 10/30/2009

5 0.0 10 NA Time of test: 935-1035

NOTE: The High Six minute Average opacity is the maximum value for any consecutive 24 reading s 

## Table 1

## Ag Processing, Inc.

Dawson, Minnesota Opacity Evaluation
Pace Project No. 0909-108 West Dryer Exhaust-SV016

Test 1

Percent Opacity Optical Density Relative Frequency

0 0.000 100.00

5 0.022 0.00

10 0.046 0.00

15 0.071 0.00

20 0.097 0.00

25 0.125 0.00

30 0.155 0.00

35 0.187 0.00

40 0.222 0.00

45 0.260 0.00

50 0.301 0.00

55 0.347 0.00

60 0.398 0.00

65 0.456 0.00

70 0.523 0.00

75 0.602 0.00

80 0.699 0.00

85 0.824 0.00

90 1.000 0.00

95 1.301 0.00

99 2.000 0.00

Average > 0.0 0.000 Total > 100

Average Opacity Per Sequential Six Minute Period: High Six Minute Average: 0.0
Period Opacity Period Opacity Maximum reading: 0.0

1 0.0 6 0.0 Minumum reading: 0.0

2 0.0 7 0.0

3 0.0 8 0.0 Observer: Matt McDermott

4 0.0 9 0.0 Date of test: 10/30/2009

5 0.0 10 0.0 Time of test: 935-1035

NOTE: The High Six minute Average opacity is the maximum value for any consecutive 24 reading s 

## Table 2

## Process Description

Ag Processing, Inc. owns and operates a soybean processi ng plant at 800 Diaganol

Street in Dawson, Minnesota. The stationary sources cons ist of emission units related

to soybean receiving, soybean processi ng, solvent extraction/recovery, meal

processing, steam production, and storage of VOC co ntaining materials. Process data

from the sources is included in Appendix C.

## Test Procedures

EPA Method 9 defines procedures to ev aluate the opacity of the plume emitted from a source stack. An independently certified visible emissions observer visually estimates the opacity of the non-moisture plume from the source. The observer positions themselves with the sun (or other light sour ce) at their back and perpendicular to the plume when directly facing the emission point. The observer must also ensure a clear and contrasting background behind the plume. The certified observer then estimates (based on certificati on trials) the percentage of the background blocked by the source plume (plume opacity) in increments of 5%. Observed opacity readings are recorded at 15-second intervals throughout the run. Tabulated re sults include run average and successive six-minute averages. The spreadsheet software also searches the data set for a group of 24 consecutive readings that yield the highest possible six-minute average. Details of the opacit y evaluation are outlined below.

Evaluation Period: One hour Observation Frequency: 15 Seconds
No. of Observations: 240 No. of Six-minutes Averages: 10
Observer Certifications: Semi-annual

## Report Signatures

# Appendix A

Field Data Sheets & Documentation

## EPA Method 9 Field Data Sheets

# Appendix B

Quality Assurance Data

## Visible Emission Certification

# Appendix C

Process/Source Information

## Process Descriptive Information

# Appendix D

Test Plan & Pretest Correspondence

## Regulatory Approval Letter(11/3/2009) Terry Borgerding - Test Plan Approval for the testing on October Page 1

From: "Severin, Marc" <Marc.Severin@state.mn.us>

To: <mmccormick@agp.com>

CC: "Terry Borgerding" <tborg@pacelabs.com>

Date: 10/23/2009 9:34 AM Subject: Test Plan Approval for the testing on October 29, 2009

Attachments: Ag Processing_Dawson_TPAL_Oct09.doc; Performance Test Report Completeness Criteria (PTRCC).doc; OPERATING DATA SUMMARY FOR PROCESS SOURCES.doc; MICROFICHE AND CD REPORT SUBMITTALS.doc; CERTIFICAT IONS REQUIRED FOR PERFORMANCE TEST
REPORT.doc

Hi Mark,

Attached is the Test Plan Approval Letter (TPAL) for the Performance Test(s) to be conducted on multiple units on October 29, 2009 at your facility in Dawson, Minnesota. Please include a copy of the Test Plan, TPAL, and this email in the final report.

The Performance Test Report Comple teness Criteria (PTRCC) form is referenced in the TPAL. Please use this to review the report prior to submitting to the agency. The form is designed to ensure completeness of test reports and aid in efficient MPCA report review and compliance

determination.

Please feel free to call with any questions

Marc Severin

Pollution Control Specialist

Minnesota Pollution Control Agency

Ph. # (651)757-2716

______________________________________________________________________ This email has been scanned by the MessageLabs Email Security System. For more information please visi t http://www.messagelabs.com/email

______________________________________________________________________aq-f6-09
5/1/07 Page 1 of 2 

# Air Performance Test Form

Performance Test Plan Approval

Facility Information (please print)

Facility name: Ag Processing Inc. - Dawson AQ#: 42

Facility contact: Mr. Mark McCormick

Address: 800 Diagonal Street Dawson, MN

Phone: (320) 769-4386

Unit(s) to be tested: SV029, SV031, SV007, SV016, SV017, SV018, SV020, SV027, SV030, SV055

Scheduled for: October 29, 2009 at your facility located in: Dawson Minnesota

Test Plan

Submitted on (date): September 17, 2009 Discussed on (date): Waived

Your test plan has been approved by the Minnesota Pollution Control Agency (MPCA) as follows:

Shortened test notification approved

Test plan approved without modification
Test plan approved with the following provisions:

1. Opacity testing to be conduc ted on SV029, SV031, SV007, SV016, SV0 17, SV018, SV020, SV027, SV030, and
SV055 with EPA method 9.

2. Include in the final test report(s) all process and pollution control equipment operating data collected at 15 minute intervals and averaged for each test period. This information should be easily understood by individuals not familiar with the process.
3. Include in the final test report(s) the full reference method data record (strip chart and/or datalogger output)

used to calculate emissions. The data record should incl ude calibration values for any instrumental analyzer used for emissions compliance testing.
4. Include in the final test report and CD-ROM copy; a sign ed certifications form, the te st plan, this test plan approval letter (TPAL) and the email to which the TPAL was attached.
5. The CD-ROM test report copy must be labeled with the AQ File Number, Company Name, Emission Unit

Tested and Test Dates as stated on the submittal form. Only one paper copy and one CD-ROM copy of the test report are to be submitted.
6. Include in the final test report a simplified drawing of the test locations including pollution control equipment, stack orientation and test port locations.
7. Use of the PTRCC form will help assure that a complete test report is submitted to the MPCA.

8. Please be reminded all periods of noncompliance with emission limits must be reported to the MPCA, this includes any periods of engineering tests. The requ irements outlined under the Notification of Deviations Endangering Human Health or the Environment, Minn. R. 7019.1000, subp. 1., shall be followed. This information should also be clearly stated and readily avai lable in the executive summary of the test report.
9. Obtain the required submittal and operati ng data forms from the Web site noted below. Forms have been revised as of May 1, 2007. Please utiliz e the current forms for this test.

Required Forms

Operating Data Summary – Combustion Sources Operating Data Summary – Asphalt Plants
Operating Data Summary – Process Sources Microfiche/CD-ROM Submittal Form

Certifications Form Performance Test Report Completeness Criteria (PTRCC)

Note: Forms are available at www.pca.state.mn.us/air/performancetest.htmlaq-f6-09
5/1/07 Page 2 of 2 Approved by:

Date: October 23, 2009

Pollution Control Specialist Compliance and Enforcement Unit Minnesota Pollution Control Agency

Please contact me at 651-757-2716 if you have any questions regarding this approval.

Please be aware that enforcement action will be taken for performance test failures indicating emissions above applicable limit s (excess actual emissions to the environment). Failures commonly re sult in assessment of a monetary penalty. Upon the first test failure, the Company should take immediate measures to minimize emissions. The measures taken should be documented, as they will become part of the record of corrective actions.

Hard Copy Performance Test Reports and Microfiche or CD Copy submittals will be addressed to:

Air Quality Compliance Tracking Coordinator Minnesota Pollution Control Agency 520 Lafayette Road North St. Paul, Minnesota 55155-4194

cc: Terry Borgerding (terry.borgerding@pacelabs.com) Mark McCormick (mmccormick@agp.com) Rachel Peters, MPCA, St. Paul (rachel.peters@state.mn.us) AQ Correspondence File No. 42

## Project Test PlanPlant Name: Protocol Date: September 15, 2009

Revision Date: No revisions to date Testing Dates: October 29, 2009

Subject Facility: Ag Processing, Inc.

800 Diagonal Street
Dawson, MN 56232 Telephone No.: (320) 769-4386 Facsimile No.: (320) 769-2668 Regulatory Permit No.: E-mail Address: mmccormick@agp.com

07300002-002

Subject Emission Sources: Dryer Deck Cyclone SV029 Top Dryer Deck Cyclone SV031 Hammermill (Drying) SV007 W Dryer Exhaust Vent SV016 E Dryer Exhaust Vent SV017 New Mac Dehulling Disc. SV018 Cracking & Flaking SV020 Telephone No.: (612) 607-6374 Hammermill (Meal Grind) SV027 Facsimile No.: (612) 607-6388 Cooler Cyclone SV030 E-mail Address: #1 Side Flaker Aspiration SV055 Client Test Coordinator:

terry.borgering@pacelabs.com Testing Firm Coordinator: Ag Processing, Inc.

Minneapolis, MN 55414 Dawson, MN 56232

Pace Analytical Services, Inc.

1700 Elm Street, Suite 200 800 Diagonal Street Ag Processing, Inc.

Mark McCormick

Terry Borgering 

# Protocol Emissions Testing OpacitySubject Facility:

Plant Contact: Company Affiliation:

Office Address:

Telephone Number:

Facsimile Number:

E-mail Address:

Reason for Test:

Project Contact: Testing Firm:

Office Location:

Telephone Number:

Facsimile Number:

E-mail Address

Subcontractors:

Regulatory Agency: Testing Contact:

Office Location:

Telephone Number:

Facsimile Number:

E-mail Address 

### Plant/Source Information

Regulatory Contact Information

Minnesota Polllution Control Agency Dawson, MN 56232

Ag Processing, Inc. 800 Diagonal Street
Dawson, MN 56232

(320) 769-4386



### Testing Firm Information 800 Diagonal Street Ag Processing, Inc. Ag Processing, Inc.

Mark McCormick

(320) 769-2668 mmccormick@agp.com

Emissions Permit Requirement

Terry Borgering Pace Analytical Services, Inc. 1700 Elm Street, Suite 200 Minneapolis, MN 55414 (612) 607-6374 (612) 607-6388 terry.borgering@pacelabs.com

No subcontractors to be used.

St. Paul, Minnesota 55155-4194 520 Lafayette Road North Marc Severin

marc.severin@state.mn.us (651) 296-8717 (651) 296-7376

### Project Organization

Management Regulatory
General Manager MPCA

Don Stock Marc Severin

(612) 607-6370 (651) 296-7376

don.stock@pacelabs.com marc.severin@state.mn.us

QA/Safety Officer Project Manager

Pace Pace

Aaron Fredrikson Terry Borgering

(612) 607-6379 (612) 607-6374

aaron.fredrikson@pacelabs.com terry.borgering@pacelabs.com

Pretest Survey Test Protocol Field Testing Analyses Reporting

Pace

Pace Pace Pace MN Laboratory Pace
Field Services Field Services Field Services (612) 607-1700 Field Services

Subcontract Lab

No sub lab on

this project.

Note: Chart based on anticipated participants at the time of protocol development and is subject to change. Subject Facility

mmccormick@agp.com (320) 769-4386 Mark McCormick Ag Processing, Inc. Client Coordinator Dawson, MN 56232 800 Diagonal Street Ag Processing, Inc.

### Testing Requirements

Emissions Testing Constituents

Source

No. Source Identification Regulated
Constituent

s Emission

Limits Applicable Rules or Regulations Progra

m

SV029
SV031
SV007
SV016
SV017
SV018
SV020
SV027
SV030
SV055 Dryer Deck Cyclone Top Dryer Deck Cyclone Hammermill (Drying ) W Dryer Exhaust Vent E Dryer Exhaust Vent New Mac Dehulling Disc. Cracking & Flaking BH Hammermill(Meal grinding) Cooler Cyclone #1 Side Flaker Aspiration Opacity 20%

20%

20%

20%

20%

20%

20%

10%

20% 2.5%( 6-Min. Ave) 7011.0715,subp 2(A) State

Process Samples to be Collected

Collection of process samples is not required for this test event.



### Process Description and Operating Conditions

Target Operating Conditions: Si ngle Condition at 90+% Capacity

Ag Processing, Inc. owns and operates a soybean processing plant at 800 Diaganol Street in Dawson, Minnesota. The stationary sources consist of emission units related to soybean receiving, soybean processing, solvent extraction/recovery, meal processing, steam production, and storage of VOC containing materials.

Process Monitoring Parameters

Source

No. Process

Parameter Monitoring

Method Normal Range

All
Sources Product Throughput Scale TBDBaghouse and Cyclone Monitoring Parameters

Source

No. Control

Parameter Monitoring

Method Normal Range

All applicable

sources Pressure Drop Magnehelic TBD



### Emissions Testing Methods

Parameter Test Method Reference No. of

Runs Length
of Run Sample
Vol/Rate Report
Units Detection

Limit

Visible

Emissions EPA Method 9 40 CFR 60, Appendix A 1 1 Hour NA % Opacity 0 Percent (5% Incr.)



### Testing Schedule

Testing is presently planned fo r October 29, 2009 based on pl ant prodution. Testing will be performed with process operations at the fullest capacity possible.



### Test Report

A final test report will be compiled by Pace Anal ytical at the completion of testing. The report will be submitted to the cli ent within 30 days of the last day of sampling. The client will be responsible for submitting report copies as required by regulat ory agencies. Two electronic copies of the test report on CD-ROM will be in cluded with hardbound copies of the report. The final test report will include the following information:

• Name and location of emission facility.
• Identification of emission unit.
• Date of tests. • Name and address of testing company. • Certification of project informati on (client signatures also required).
• Reasons and constituents for test.
• Names of observers and witnesses • Emission results expressed in the units of the emission limitation

criteria.• Process descriptions as provided by the client. • Process rate information as provided by the client. • Descriptions of maintenance activities as provided by the client. • Discussions of problems or errors encountered. • Sampling and analytical procedures. • Copies of raw field data. • Copies of laboratory analytical reports. • Calculation equations. • Sampling train calibration data • Copy of this test plan and other pertinent pretest correspondence.



### Safety Considerations

Safety is an important aspec t of sampling programs, especially when test teams and observers are in unfamiliar plant surroundings. Plants are required to provide test ports, safe test platforms and access routes. The te st firm is required to follow plant safety protocols and rules as well as their own safe ty program. Attention must be given to special considerations related to testi ng such as overhead work, solvent usage, compressed gases, flammable materials, open ports and electrical appliances. Observers and regulatory witnesses must comp ly with both plant and test firm safety protocols. Pace cannot provide PPE for visi tors and observers. The following protocols and Personal Protection Equipment ( PPE) will be required for this site.

Safety Requirements Pace

Protocol Plant

Protocol No Smoking X Safety Shoes X

Hard Hat X Safety Glasses X
Abrasion Resistant Gloves X Temperature Insulating Gloves X Full Length Trousers (Waist to Ankle) X Long-Sleeved Shirt Plant Security Log In Plant Safety Training

Plant Escort Designated Break/Smoking Areas



### Attachment

Attachment 1 Method Summary

# Attachment 1

Method SummariesEPA Method 9 defines procedures to evaluate the opacity of t he plume emitted from a source stack. An independently certified visible emissions observer visually estimates the opacity of the non-moisture plume from the source. The observer positions themselves with the sun (or other light s ource) at their back and perpendicular to the plume when directly facing the emission poin t. The observer must also ensure a clear and contrasting background behind the plume. The certified observer then estimates (based on certification trials ) the percentage of the backgr ound blocked by the source plume (plume opacity) in increments of 5% . Observed opacity readings are recorded at 15-second intervals throughout the run. Tabulated results include run average and successive six-minute averages. The spreads heet software also s earches the data set for a group of 24 consecutive r eadings that yield the highest possible six-minute average. Details of the opacity evaluation are outlined below.

Evaluation Period: One hour Observation Frequency: 15 Seconds
No. of Observations: 240 No. of Six-minutes Averages: 10
Observer Certifications: Semi-annual