### 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.

Signature Date

## Definitions (in addition to those in Subpart DD):

Storage Unit – For the purposes of this survey, a storage unit is any building, bin, silo, or pile used to store corn, wheat, sorghum, rice, rye, oats, barley or soybeans.

Permanent Storage – A storage unit with an immovable roof; a floor made of concrete, asphalt or similar material; and sidewalls made of steel, concrete or similar material.

Temporary Storage – A storage unit that is comprised of: asphalt, concrete, or other comparable base material; rigid self-supporting sidewalls; a tarp , cover or the equivalent; and an aeration system.

Emergency Storage – A form of storage other than permanent storage or temporary storage.

Country Elevator – Any grain elevator where more than 50% of grain is received from farms.

Other Stand

- Alone Elevator – Any grain elevator where less than 50% of grain is received from farms AND grain processing is not the primary activity.

Grain Processing – Equipment or processes used to alter the natural state of grain by fractioning, grinding, blending, conditioning, etc., in order to produce a product for human or animal consumption or the production of biofuels.

Shipping Units – All equipment associated with loading grain from a storage unit.

Receiving Units – All equipment associated with loading grain into a storage unit.

Design or Work Practice – Any technique other than the installation of air pollution control equipment for the reduction of particulate matter emissions.

### FORM A Page 1 

# Grain Elevator Survey

FORM A – General Information

A-1 Facility Name:

A-2 (a) Facility Street Address:

(b) Suite or P.O (s pecify): (c) City:

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

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

A-4 (a) Technical contact (for info rmation on this survey):

(b) Title: (c ) Telephone Number:

(d) Email Address:

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

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

A-7 (a) Parent Company/ Co-Op:

(b) Is this a co-op? (check one) Yes No

(c) Parent Company/ Co-Op Main Office Street Address:

(d) Suite or P.O. (specify) : (e) City:

(f) State: (g) Zip Code:

A-8 Number of full-time employees within all business units of the Parent Company:

(please check one): < 100 101- 249 250- 499 > 500

A-9 Number of seasonal employees within a ll business units of the Parent Company

(please check one): < 100 101- 249 250- 499 > 500 FACILITY ID:

FACID :
(First 4 letters of company name plus first 4 letters of city name. If not unique identifier, add number at end of ID)

## 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).- --- ----------------~

Buddy Garcia, Chairman Larry R. Sqward, Commissioner Bryan W. Shaw, Ph.D., Commissioner
Mark R. Vickery, P.E., Executive Director

TEXAS COMMISSION ON ENVIRONMENTAL QUALITY

Protecting Texas by Reducing and Preventing Pollution

MR JEFFREY J BECKER VICE PRESIDENT OF US GRAIN OPERATIONS AND ENGINEERING ARCHER DANIELS MIDLAND COMPANY 1001 N BRUSH COLLEGE RD DECATURIL 62521-1656

Re: Permit Renewal Permit Number: 2199D Grain Elevator Galveston, Galveston County Regulated Entity Number: RNI 020 17340 Customer Reference Number: CN600123913 Account Number: GB-0027

- W

Dear Mr. Becker: July 22, 2008

This is in response to your application Form PI-IR (General Application for Air Permit Renewals) concerning, the proposed renewal of Permit Number 2199D. Also, this. will acknowledge that your application for the above-referenced Tenewal is technically complete as of June 16, 2008. Additionally, we understand that you wish to correct permit representations to

remove sources which are no longer in operation at this facility.

As indicated in Title 30 Texas Administrative Code 

## S 116.314(a) [30 TAC 

## S 116.314(a)), and based on our review, your permit is hereby renewed. Enclosed is a permit for your facility. Also enclosed are new special conditions and a maximum allowable emission rates table. We appreciate your careful review of the special conditions of the permit and assuring 'that all requirements are consistently met. This permit will be in effect for tim years from the date of approval (Commission's final decision). If this permit is appealed and the permittee does not

commence any action authorized by this permit during judicial review, the term will. not begin until judicial review is concluded.

As of July 1, 2008, all analytical data generated by a mobile or stationary laboratory in support of compliance with air permits must be obtained from a J\'ELAC (National Environmental Laboratory Accreditation Conference) accredited laboratory under the Texas Laboratory Accreditation Program or meet one of several exemptions. Specific information concerning which laboratories must be accredited and which are exempt may be found in 30 TAC 

## SS 25.4
and 25.6.

P.O. Box 13087 • Austin, Texas 78711-3087 • 512/239-1000 • Internet address: www.tceq.state.lX.us prir.ted on recycled p~per using soy.b:lSed inkMr. Jeffrey J. Becker

Page 2 July 22, 2008

Re: Pennit Number 2199D

For additional infonnation regarding the laboratory accreditation program and a list of accredited laboratories and their fields of accreditation, please see the following website:

http://www.tceq.state.lx.us/compliance/ compliance_support! q a/ env _lab

_ accredi tation.html

For questions regarding the accreditation program, you may contact the Texas Laboratory Accreditation Program at (512) 239-3754 or bye-mail atlabprgms@tceq.state.lx.us.

You may file a motion to overturn with the Chief Clerk. A motion to overturn is a request for the comIDission to review the Texas Commission on Environmental Quality (TCEQ) Executive Director's approval of the application. Any motion must explain why the conimission should. review the TCEQ Executive Director's action.

A motion to overturn must be received by the Chief Clerk within 23 days after the date of this letter. An original and 11 copies of a motion must be filed with the Chief Clerk in person or by mail. The Chief Clerk's mailing address is Office of the Chief Clerk (MC-105), Texas Commission on Environmental Quality, P.O. Box 13087, Austin, Texas 78711-3087. On the

same day the motion is transmitted to the Chief Clerk, please provide copies to Mr. Roben Martinez, Director, Environmental Law Division (MC- I 73), and Mr. BIas J. Coy, Jr., Public Interest Counsel (MC-103), both at the same TCEQ address above. If a motion is not acted on by the commission within 45 days after the date of this letter, then the motion shall be deemed overruled.

Thank you. for your cooperation in sending us the information necessary to evaluate your operations and for your commitment to air pollution control. If you need further information or have in y questions, please contact Mr. Joel Stanford at (512) 239-0270 or write to the Texas Commission on Environmental Quality, Office of Permitting, Remediation, and Registration, Air Permits Division (MC-163), P.O. Box 13087, Austin, Texas 78711-3087./ ~ )

Mr. Jeffrey J. Becker Page 3 July 22, 2008

Re: Permit Number 2l99D

This action is taken under authority delegated by the Executive Director of the TCEQ.

Sincerely,

Richard A. Hyde, P.E" Director Air Permits Division Office of Permitting, Remediation, and Registration Texas Commission on Environmental Quality

RAH/JS/js

Enclosures

cc: Air Section Manager, Region 12

- Houston

Project Number: 132725EMISSION SOURCES

- MAXIMUM ALLOWABLE EMISSION RATES

Permit Number 2199D

This table lists the maximum allowable emission rates and all sources of air contaminants on the applicant's property covered by this permit. The emission rates shown are those derived from information submitted as part of the application for permit and are the maximum rates allowed for these facilities. Any proposed increase in emission rates may require an application for a modification of the facilities covered by this permit.

AlRCONTANITNANTSDATA

Emission Source Air Contaminant Emission Rates Point No. (1) Name (2) Name (3) Iblhr TPY

RR-l Rail Receiving Pit NO.1 PMlPM lO 0.32 0.04

RR-2 Rail Receiving Pit NO.2 PMlPM lO 0.33 0.48

RR-3 Rail Receiving Pit NO.3 PMlPM 10 0.33 0.48

TR-l TruckReceiving Pit NO.1 PMlPMlO 0.14 <0.01

C-I Cleaner No. 1 PMlPM lO 0.05 0.01

C-2 Cleaner NO.2 PMlPM lO 0.05 0.01

C-3 Cleaner NO.3 PMlPMlO 0.05 0.01

SHIP-1 Ship Loadout NO.1 PMlPMlO 2.69 2.80

SHIP-2 Ship Loadout NO.2 PMlPM lO 2.69 2.80

SHIP-3 Ship Loadout NO.3 PMlPM IO 2.69 2.80

SHIP-4 TrucklRail Loadout PM/PMIO 0.Q3 <0.01

ill Internal Handling PMlPMlO 12.28 2.14

(1) Emission point identification

- either specific equipment designation or emission point number from a plot

. plan. (2) Specific point source names. For fugitive sources, use an area name or fugitive source name. (3) PM particulate matter, suspended in the atmoSphere, including PM lO and PM 2 .5. PM lO particulate matter equal to or less than 10 microns in diameter.

Dated July 22,2008SPECIAL CONDITIONS

Permit Number 21990

EMISSION LIMITATIONS

1. This permit covers only those sources of emissions listed in the attached table entitled "Emission Sources

- Maximum Allowable Emission Rates," and those sources are limited to the emission rates and other conditions specified in the table.

FEDERAL APPLICABILITY

2. These facilities shall comply with all applicable requirements of the US. Environmental Protection Agency (EPA) Regnlations on Standards of Performance for New Stationary Sources in Title 40 Code of Federal Regnlations (40 CFR) Part 60 promulgated for Grain Elevators, Subparts A and DO. (7/08)

OPERATIONAL LIMITATIONS, WORK PRACTICES, AND PLANT DESIGN

3. The maximum hourly and annuiu maximum grain throughput shall be limited to theamounts represented in the confidential file application received by the Texas Commission

on Environmental Quality (TCEQ) Air Permits Division on September 13; 2007. (7/08)

4. Fugitive emissions from all receiving pits shall be minimized through the use of' "choke feeding." (7/08)

5. A Fabric Filter Baghouse, properly installed and in good working order, shall control particulate matter emissions from Emission Point Numbers (EPNs) RRl, RR2, RR3, TR-l, C-l, C-2, C-3, SHIP-I, SHIP-2, SHIP-3, SHIP-4, and IH when these areas are in operation. (7/08)

6. Truck and railloadout devices (augers, drop spouts, etc.) shall be equipped with drop socks
at the drop points to minimize fugitive emissions from loadout areas. (10/08)SPECIAL CONDITIONS

Permit Number 2l99D Page 2

RECORDKEEPING REQUIREMENTS

7. Records of annual and hourly throughputs shall be maintained at this facility and made available at the request of personnel from the TCEQ or any other air pollution control
program having jurisdiction to demonstrate compliance with permit limitations. These records shall be totaled for each calendar month and retained for a rolling 24-month period. (7/08)

Dated October 6, 2008Buddy Garcia, Chairman

.

Larry R. Soward, .Commissioner Bryan W: Shaw, Ph.D., Commissioner
Mark'R. Vickery, P.G., Executive Director

L 

### TEXAS COMMISSION ON ENVIRONMENTAL QUALITY
Protecting Texas by Reducing and Preventing Pollution

October 6, 2008 MS MIRANDA GERARD ENVIRONMENTAL SPECIALIST ARCHER DANIELS MIDLAND COMPANY 4666 E FARIES PKWY DECATUR IL 62526-5666

Re:. Permit Alteration Permit Number: 21990 Grain Elevator Galveston, Galveston County Regulated Entity Number: RNI 020 17340 Customer Reference Number: CN600123913 Account Number: GB-0027-W

Dear Ms. Gerard:~,

,This is in response to your letter received August 5, 2008, requesting alteration of the conditions of the above-referenced permit. We understand that you wish to alter your permit to clarify permit representations at this facility.

As indicated in Title 30 Texas Administrative Code 

## S 116.1 16(c) [30 TAC 

## S 116.116(c)), and based on our review, Permit Number 2199D is altered. Enclosed are the altered permit conditions to replace those currently attached to your permit. Please attach these to your permit.

As of July 1, 2008, all analytical data generated by a mobile or stationary laboratory in support of compliance with air peimits must be obtained from a NELAC (National Environmental Laboratory Accreditation Conference) accredited laboratory under the Texas Laboratory Accreditation Program or meet one of several exemptions. Specific information concerning which laboratories must be accredited and which are exempt may be found in 30 T AC 

## SS 25.4 and 25.6.

For additional information regarding the laboratory accreditation program and a list of accredited laboratories and their fields of accreditation; please see the following website:,

http://www.tceq.state.tx.us/compliance/complia.nce

_ support/qalenv _lab

_ accreditation.html

P.O. Box 13087 • Austin, Texas 78711-3087 • 512/239-1000 • Internet address: www.tceq.state.tx.us

- . primed on recycled paper using soy-based inkMs. Miranda Gerard

Page 2 October 6, 2008

Re: Permit Number 2199D

For questions regarding the accreditation program, you may contact the Texas Laboratory Accreditation Program at (512) 239-3754 or bye-mail atlabprgms@tceq.state.tx.us.

Your cooperation in this matter is appreciated. If you need further infoITnation or have any questions, please contact Mr. Joel Stanford'at (512) 239-0270 or write to the Texas Commission

on Environmental Quality, Office of Permitting, Remediation, and Registration, Air Permits Division (MC-163), P.O. Box 13087, Austin, Texas 78711-3087.

This action is taken under authority delegated by the Executive Director of the Texas Commission on Environmental Quality.

Sincerely,

Richard A. Hyde, P.E., Director Air Permits Division Office of Permitting, Remediation, and Registration Texas Commission on Environmental Quality

RAH/JS/pg

Enclosure

cc: Air Section Manager, Region 12

- Houston

Project Number: 140103 . ,SPECIAL CONDITIONS

Permit Number 2199D

EMISSION LIMITATIONS

1. This permit covers only those sources of emissions listed in the attached table entitled "Emission Sources

- Maximum Allowable Emission Rates," and those sources are limited to the emission rates and other conditions specified in the table.

FEDERAL APPLICABILITY

2. These facilities shall comply with all applicable requirements of the U.S. Environmental Protection Agency (EPA) Regulations on Standards of Performance for New Stationary Sources in Title 40 Code of Federal Regulations (40 CFR) Part 60 promulgated for Grain Elevators, Subparts A and DD. (7/08)

OPERATIONAL LIMITATIONS, 

## woRk PRACTICES, AND PLANT DESIGN

3. The maximum hourly and annual maximum grain, throughput shall be limited to the

amounts represented in the confidential file application received by the Texas Commission

on Environmental Quality (TCEQ) Air Permits Division on September 13, 2007, (7/08).

4. Fugitive emissions from all receiving pits shall be minimized through the use of "choke feeding." (7/0l!)

5. A Fabric Filter Baghouse, properly installed and in good working order; shall control particulate matter emissions fromEmission Point Numbers (EPNs) RRI, RR2, RR3, TR-I, C-I, C-2, C-3, SHIP-I, SHIP-2, SHIP-3, SHIP-4, and IH when these areas are in operation. (7/08)

6. Truck and railloadout devices (augers, drop spouts, etc.) shall be equipped with drop socks
at the drop points to minimize fugitive emissions from loadout areas. (10/08)SPECIAL CONDITIONS

Permit Number 2l99D Page 2

RECORDKEEPING REOUIREMENTS

7. Records of annual and hourly throughputs shall be maintained at this facility and made available at the request of personnel from 'the TCEQ or any other air pollution control
program having jurisdiction to demonstrate' compliance with permit limitations. These records shall be totaled for each calendar month and retained for a rolling 24-month period. (7/08)

Dated October 6, 2008

### TEXAS COM~SSION ON ENVIRONMENTi~) QUALITY AIR QUALITY PERMIT

. .

A pERMIT IS HEREBY ISSUED TO Archer Daniels Midland Company AUTHORIZING THE CONTINUED OPERATION OF

Grain Elevator LOCATED A T Galveston, Galveston County, Texas LATITUDE 29 0 18' 03" LONGITUDE 094 0 47' 53"

1. Facilities covered by this permit shall be constructed and operated as specified in the application for the permit. All representations regDrding construction plans <lnd operation procedures contained in the. pennil application shaii be conditions upon which the permit is jssu~. Variations from these representations shall be unlawfullinless the permit holder first makes application to the Texas Commission on EnvironmentDI Quality (commission) Executive Director to amendJthis permit in that regard and such
amendment is approved. [Title 30 Texas Administrative Code lj 116.116 (30 TAe 9 116.116)]

2. Voiding of Permit. A permit Of permit amendment is automatically void if the holder fails to begin construction within 18 months of the date of issuance, discontinues construction for more than 18 months prior to completion, or fails to c9mplete constnlction within a reasonable time. Upon request, the executive director may grant an l8-month extension. Before the extension is granted'the permit may be 'subject to revision based on best available control technology, lowest achievable emission rate, and netting or offsets as applicable, One additional extension of up to 18 months may be granted if the permit holder demon~trates that emissions from the facility will comply with all rules and regulations of the commission, the intent of the Texas Clean Air Act (rCAA), including protection of the public's health and physical property; and (b)(l )the permit holder is a party to litigation not of the permit holder's initiation regarding the issuance of the permit; or (b)(2) the pem,it holder has spent, or committed to spend, at leastlO percent of the esti~ated total cost of the project up to a maximum' of $5 million. A pennit holder granted an extension under subsection (b)(l) of this sect!on may receive one subsequent extension if the permit holder meets the conditions of subsection (b)(2) of this seetlo:'!. [30 TAC 9 1 1 6. 120(a), (b) and (c)l

3. Construction Progress. Start of construction, construction interruptions exceeding 45 days, and completion of construction shall be reported to the appropriate regional office of the commission not later than 15 working days after occurrence of the event. [30 TAC S 1l6.II,5(b)(2)(A))

4, Start-up Notification. The appropriate !lir program regional office shall be notified prior to the commencement of operations of the facilities authorized by the permit in such a manner that a representative of the commission may be present. The permit holder shall provide a separate notification for the commencement of operations for each unit of phased construction, which may involve a series of units 'commencing operations at different times. Prior to operation of the facilities authorized by the permit, the permit holder shall identify to the Office of Pennitting, Remediation, and Registration the source or sources of allowances to be utilized for compliance with Chapter 101, Subcnapter H, Division 3 of this title (relating to Mass Emissions Cap and Trade Program)., [30 TAC 9 116,115(b)(2)(B)]

, ,5. Snmpling Requirements, If sampling is required. the permit holder ,shall contaci the commission's Office of Compliance and Enforcement prior to sampling to obtain the
proper data forms and procedures. All sampling and testing procedures must be approved by the executive director and coordinated with the regional representatives of the commission: The pennit holder is also responsible for providing sampling facilities and conducting the'sampling operations or contracting with an independent sampling
consultant. [JOTAC! J16.J15(b)(2)(C»)

. . .
6. Equivalency of Methods. The permit holder must demonstrate or otherwise justify the equivalency of emission control methods, sampling or other eini~sion testing methods, and monitoring methods proposed as alternatives to methods indicated in the conditions of the pennit. Alternative methods shall be applied for in writing and must bercviewed and approved by the executive director prior to their u~e in fulfilling any requirements ofthe permit. (30 TAC S 116,l15(b)(2)(D))

7. Recordkeeping. The penni! holder shall maintain a copy of the pennit along with records containing the information and data sufficient to demonstrate compliance with the' permit, including production records and operating hours; keep all required records in a file at the plant site. If, however, the facility normally operates ~attended, records shall be maintained at the nearest staffed location within Texas specified in the application; make, the records available at the request of personnel from' the commission or any air pollution control program having jurisdiction; comply with any additional recordkeeping requirements specifierl in special conditions attached to the permit; and retain information in the file for at least two years following the date that,the information or data is obtained. [30 TAC 9 116.115(b)(2)(E»)

8. Maximum Allowable Emission Rates. The lotal emissions of air contaminantS from any of the sou~s of emissions must not exceed the values stated on the table attached

to the permit entitled "Emission Sources-Maximum Allowable Emis'sion Ratcs." [30 TAC

~ 116.115(b)(2)(F)]

9. Maintenance of EmissiDn ContrDI. The permitted facilities shall nol be oper~ted unless all air pollution emission capture an'd abatement equipment is maintained in good working order Bnd operating properly during Tionnal facility operations, The pennit holder shall provide notification for upsets and maintenance in accordance with ~9 101.201, lO1.211,-and 101.221 of this title (relating to Emissions Event Reporting and Recordkeeping Requirements; Scheduled Maintenance, Startup, and Shutdown Reporting and Recordkeeping Requirements; and Operational Requirements). [30 TAC g 116.115(b)(2)(G)]

10. Compliance with Rules. Acceptance of a pennit by an applicant' constiwtes an acknowledgment and agreement that the permit holder will comply with all rules, regulations, and orders of the commission"issued in conformity with the TCAA and the conditions precedent to the granting of the permit If more than one state or federal rule or regulation or pennit r:ondition is applicable, the most stringent limit or'condition shall govern and be the standard by which compliance shall be demonstrated. Acceptance includes consent to the entrance of commission .employees ,and agents into the permitted premises i1t reasonable times to investigate conditions relating to the
emission or concentration of air contaminants, including corpp!ian'ce with the permit (30 TAC 9 116.115(b)(2)(H)]

11. This permit maybe appealed pursuanllo 30 TAC S 50.139.

12, This permit may not be trnnsferred, assigned, or conveyed'by lhe holder except as provided by rule. [30 TAC S 116,lI0(e»)

13. There 'may be additional spedal conditions llt~ched to a permit upon issuance or modification of the permit. Such conditions in a pennit may be more restrictive than the requirements of Title 30 oflhe Texas Adminislrntive Code. [30 TAC 9 116.115(c)]

,
14. Emissions from this facility must nOI cause or contribute to a condition of "nir pollution" as d~fil1ed in TCAA S 382.003(3) or violate TCAA S 382.085, as codified in the Texas'Health and Safety Code, If the executive director determines that such a condition or violation occurs, the holder shall implement additional ablltement measures as
necessary to control orprev~nt the condition or violation.

PERMITm.w

Date: July 22 200&