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. 

 
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) 

AGPRDAWS Ag Processing Inc800 Diagonal Street Dawson MN 56232 Lac Qui Parle Lee Gunderson (320) 769-4386 Kelly Jorgensen Director of Environmental 

Compliance

(402) 498-5501 kjorgensen@agp.com 610

Ag Processing Inc ■

12700 West Dodge Road

Omaha NE 68103-2047 ■

■
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. 

AGPRDAWS 1951 2

0

1
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 

AGPRDAWS PPE P-1 1971 1,372,968 Soybeans 734,700 52 584,200 52 

P-2 1964 600,000 Soybeans 734,700 52 584,200 52 E-1 1990 400,000 Soybeans 398,233 52 137,267 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. 

AGPRDAWS R-1 P1/P2 Fixed Receiving Pit with Leg and Fixed Conveyor 15430 BU/HR Y 

R-2 P1/P2 Fixed Receiving Pit with Leg and Fixed Conveyor 15000 BU/HR Y R-3 E1 Portable 10000 BU/HR N 

S-1 P1/P2 Payloader NA NA N 
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: 

AGPRDAWS

This plant site does not have temporary storage.
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).

AGPRDAWS
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. 

AGPRDAWS

Mineral oil is sprayed on the beans when they are conveyed on the incline conveyor belt. The amount is approximately 

11pounds of mineral oil per 1000 bushel of soybeans.
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. 

AGPRDAWS 33 D-1 R-1, R-2, R-3, P-1, P-2, E-1 NG 50 52 37 D-2 R-1, R-2, R-3, P-1, P-2, E-1 NG 34 24
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. 

AGPRDAWS 3 2

1 0

0 0

0 0

0 0

0 0

2 2

■
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. 

AGPRDAWS

Mineral oil is added to beans received trough R-3 that are going to E-1. 

Commodities spilled on the driveway and other facility property are cleaned up as to minimize fugitive emission. 

None Not applicable to plant operations. Not applicable to plant operations. Not applicable to plant operations. Not applicable to plant operations. None None
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 

AGPRDAWS APCD-1 Fabric Filter R-1 ND ND 

APCD-2 Fabric Filter R-2 ND ND 
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 

 

AGPRDAWS APCD-1 10000 acfm 0.1 7.0 Inches Ambient Ambient C/F APCD-2 10000 acfm 0.1 7.0 Inches Ambient Ambient C/F
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 

AGPRDAWS APCD-1 130 1290 ft2 APCD-2 100 992 ft2
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). 
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 Truck









	
	


	









 !!

	

Testing 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

Pace Analytical

FSD 0909-108

Report Date 11/18/09

Ag Processing, Inc.

Page 1 of 19
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 16

Test Procedures Summary 17

Report Signatures 18

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 

Pace Analytical

FSD 0909-108

Report Date 11/18/09

Ag Processing, Inc.

Page 2 of 19
Introduction

Pace Analytical Services, Inc. personnel conducted 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 Analytical Services, Inc. prepared a comprehensive 

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

activities consisted of the following measurements: 

- Opacity, one independent one-hour observation period on each unit. 

The project objectives were to quantify opacity emission constituents and compare them 

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

These measurements were performed at normal operating condition. Quality protocols 

comply with all regulatory compliance testing requirements. 

Subsequent sections summarize the test results and provide descriptions of the process 

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

Pace Analytical

FSD 0909-108

Report Date 11/18/09

Ag Processing, Inc.

Page 3 of 19
Results Summary

Results of opacity observations are summarized 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 during testing. Process 

rate information can be found in Appendix C. 

The data in this report are indicative of emission characteristics 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. 

Pace Analytical

FSD 0909-108

Report Date 11/18/09

Ag Processing, Inc.

Page 4 of 19
Detail Tables

Pace Analytical

FSD 0909-108

Report Date 11/18/09

Ag Processing, Inc.

Page 5 of 19
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 readings

Table 1

Pace Analytical

FSD 0909-108

Report Date 11/18/09

Ag Processing, Inc.

Page 6 of 19
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 readings

Table 2

Pace Analytical

FSD 0909-108

Report Date 11/18/09

Ag Processing, Inc.

Page 7 of 19
Process Description

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 data 

from the sources is included in Appendix C. 

Pace Analytical

FSD 0909-108

Report Date 11/18/09

Ag Processing, Inc.

Page 16 of 19
Test Procedures

EPA Method 9 defines procedures to evaluate 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 source) 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 certification 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 results 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 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 

Pace Analytical

FSD 0909-108

Report Date 11/18/09

Ag Processing, Inc.

Page 17 of 19
Report Signatures

Pace Analytical

FSD 0909-108

Report Date 11/18/09

Ag Processing, Inc.

Page 18 of 19

Appendix A

Field Data Sheets & Documentation 

Pace Analytical

FSD 0909-108

Report Date 11/18/09

Ag Processing, Inc.

Page A-1 of 22
EPA Method 9 Field Data Sheets 

Pace Analytical

FSD 0909-108

Report Date 11/18/09

Ag Processing, Inc.

Page A-2 of 22
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Ag Processing, Inc.

Page A-6 of 22
Appendix B

Quality Assurance Data 

Pace Analytical

FSD 0909-108

Report Date 11/18/09

Ag Processing, Inc.

Page B-1 of 3
 Visible Emission Certification

Pace Analytical

FSD 0909-108

Report Date 11/18/09

Ag Processing, Inc.

Page B-2 of 3
Pace Analytical

FSD 0909-108

Report Date 11/18/09

Ag Processing, Inc.

Page B-3 of 3
Appendix C

Process/Source Information 

Pace Analytical

FSD 0909-108

Report Date 11/18/2009

Ag Processing, Inc.

Page C-1 of 12
Process Descriptive Information

Pace Analytical

FSD 0909-108

Report Date 11/18/2009

Ag Processing, Inc.

Page C-2 of 12
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FSD 0909-108

Report Date 11/18/2009

Ag Processing, Inc.

Page C-8 of 12
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FSD 0909-108

Report Date 11/18/2009

Ag Processing, Inc.

Page C-9 of 12
Appendix D

Test Plan & Pretest Correspondence 

Pace Analytical

FSD 0909-108

Report Date 11/18/09

Ag Processing, Inc.

Page D-1 of 14
Regulatory Approval Letter 

Pace Analytical

FSD 0909-108

Report Date 11/18/09

Ag Processing, Inc.

Page D-2 of 14
(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; CERTIFICATIONS 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 Completeness 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 visit http://www.messagelabs.com/email 

______________________________________________________________________

Pace Analytical

FSD 0909-108

Report Date 11/18/09

Ag Processing, Inc.

Page D-3 of 14
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 conducted on SV029, SV031, SV007, SV016, SV017, 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 include calibration values for any instrumental analyzer 

used for emissions compliance testing. 

4. Include in the final test report and CD-ROM copy; a signed certifications form, the test 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 requirements 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 available in the executive summary of the test report. 

9. Obtain the required submittal and operating data forms from the Web site noted below. Forms have been 

revised as of May 1, 2007. Please utilize 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.html

Pace Analytical

FSD 0909-108

Report Date 11/18/09

Ag Processing, Inc.

Page D-4 of 14
aq-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 limits 

(excess actual emissions to the environment). Failures commonly result 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 

Pace Analytical

FSD 0909-108

Report Date 11/18/09

Ag Processing, Inc.

Page D-5 of 14
 Project Test Plan 

Pace Analytical

FSD 0909-108

Report Date 11/18/09

Ag Processing, Inc.

Page D-6 of 14
	
	


	









 !!

	

Plant 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

Opacity

Pace Analytical

FSD 0909-108

Report Date 11/18/09

Ag Processing, Inc.

Page D-7 of 14
Subject 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

Pace Analytical

FSD 0909-108

Report Date 11/18/09

Ag Processing, Inc.

Page D-8 of 14
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.

Pace Analytical

FSD 0909-108

Report Date 11/18/09

Ag Processing, Inc.

Page D-9 of 14
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: Single 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 TBD 

 

Pace Analytical

FSD 0909-108

Report Date 11/18/09

Ag Processing, Inc.

Page D-10 of 14
Baghouse 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 for October 29, 2009 based on plant prodution. Testing will 

be performed with process operations at the fullest capacity possible. 

Test Report

A final test report will be compiled by Pace Analytical at the completion of testing. The 

report will be submitted to the client within 30 days of the last day of sampling. The client 

will be responsible for submitting report copies as required by regulatory agencies. Two 

electronic copies of the test report on CD-ROM will be included 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 information (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. 

Pace Analytical

FSD 0909-108

Report Date 11/18/09

Ag Processing, Inc.

Page D-11 of 14
• 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 aspect 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 test firm is required to follow plant safety 

protocols and rules as well as their own safety program. Attention must be given to 

special considerations related to testing such as overhead work, solvent usage, 

compressed gases, flammable materials, open ports and electrical appliances. 

Observers and regulatory witnesses must comply with both plant and test firm safety 

protocols. Pace cannot provide PPE for visitors 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 

Pace Analytical

FSD 0909-108

Report Date 11/18/09

Ag Processing, Inc.

Page D-12 of 14
 Attachment 1 

Method Summaries 

Pace Analytical

FSD 0909-108

Report Date 11/18/09

Ag Processing, Inc.

Page D-13 of 14
EPA Method 9 defines procedures to evaluate 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 source) 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 certification 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 results 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 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

Pace Analytical

FSD 0909-108

Report Date 11/18/09

Ag Processing, Inc.

Page D-14 of 14