GRAIN ELEVATOR AND PROCESSOR NSPS INDUSTRY SURVEY 

INTRODUCTION AND GENERAL INSTRUCTIONS 

This survey form is to be completed by a respondent for each of its wholly owned facilities as described in the 

following four paragraphs (A-D), using the definitions at the end of this introductory section. Respondents must 

meet the requirements of paragraphs A, B, and C. 

A. This survey is limited to the following facilities: any “grain elevator” that would constitute a “grain 

terminal elevator” or a “grain storage elevator” (as those terms are defined by Subpart DD (40 CFR 

60.301)) if only permanent storage or both permanent and temporary storage at the grain elevator are 

taken into account. A respondent need not provide data for any facility not possessing this type of 

grain elevator. 

B. EPA is interested in obtaining information about the following categories of grain elevators: 

(1) Country grain elevators with storage capacity^ ≥ 2,500,000 bushels 

(2) Other stand-alone elevators with storage capacity^ ≥ 2,500,000 bushels 

(3) Wheat flour mill elevators *

(4) Wet corn mill elevators*

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

(6) Rice mill elevators*

(7) Soybean oil extraction elevators* 

^”Storage capacity” may include only permanent storage capacity, or it may include both permanent and temporary 

storage capacity. 

*Grain elevators in categories 3-7 above must have storage capacity of ≥ 1,000,000 bushels. 

For each of the above seven categories, a respondent must submit a response for at least five 

facilities under its control. If a respondent has less than five facilities in a particular category, the 

respondent must provide information for all of its facilities in that category. 
C. EPA is also interested in obtaining information about the following types of facilities: 

 Grain elevators located in each EPA Region. 

 Five storage combinations: 

- Grain elevator alone 

- Grain elevator w/emergency storage 

- Grain elevator w/temporary storage 

- Grain elevator w/emergency and temporary storage 

- Grain elevator w/barge unloading 

 Facilities handling multiple grains. 

 Facilities handling only one grain. 

A respondent must submit a response for each of the facilities listed below to the extent it has any such 

facility under its control for each of the 7 categories listed in paragraph B: 

 At least one facility in each Region; 

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

 At least one facility that handles multiple grains; and 

 At least one facility that handles only one grain. 

For example, if a respondent has 18 facilities in the country grain elevator category, and 10 are in EPA 

Region 5 and eight are in EPA Region 6, the respondent shall provide information for a minimum of five 

grain elevators. At least one elevator must be in Region 5 and one in Region 6. In addition, if 

applicable, the respondent shall provide information on at least one facility with each of the five grain 

storage combinations. The respondent must also provide information for at least one facility that 

handles multiple grains and one that handles only one grain. In this example, assuming the respondent 

owned each of the different types of grain elevators of interest to EPA, it is possible to meet the EPA 

requirements with five facilities responding if the five chosen facilities can meet multiple requirements 

(e.g., handling multiple grains in EPA Region 5 and using each of the 5 storage methods). However, it 

may be necessary to provided additional facility responses to meet the EPA requirements if facilities 

cannot meet multiple EPA requirements. 

D. The total number of facilities for a respondent may exceed 35 (five facilities in each of the seven 

categories) when including the regional, combination, and grain information. However, no respondent 

is required to submit information about more than 51 facilities. 

 

Since one of the goals of this survey is to gather data on temporary storage facilities, EPA encourages 

respondents to exercise any discretion afforded by paragraphs A-D above in favor of submitting data on such 

facilities. For the same reason, EPA encourages respondents to include along with their required responses to 

this survey any supplemental data on such facilities that may go beyond the bounds of this survey but 

nevertheless would be helpful to EPA in understanding temporary storage facilities fully from the standpoint of 

Subpart DD. 

This survey is provided in paper format and by first-class mail. However, you may opt to complete this survey 

either in paper format or in electronic format. To obtain an electronic file (in Microsoft Word) to compile your 

responses, please contact Bill Schrock at schrock.bill@epa.gov. Please submit complete responses to Bill 

Schrock within 60 days after receipt by first-class mail. Any request for an extension of that 60-day period 

must be submitted to Bill Schrock within 30 days after receipt by first-class mail. Extensions will not be granted 

except upon a showing of undue hardship and then only for the minimum time reasonably necessary. 

It is important to note that, throughout this document, we have used the terms “permanent storage,” “temporary 

storage” and “emergency storage” to differentiate between those structures typically constructed of concrete 

and topped with metal roofs and the pyramid shaped storage units typically with low concrete walls and a vinyl 

top. The use of the terms “permanent storage” and “temporary storage” is strictly to reflect the current 
receipt by first-class mail. Any request for an extension of that 60-day period must be submitted 

to Bill Schrock within 30 days after receipt by first-class mail. Extensions will not be granted 

except upon a showing of undue hardship and then only for the minimum time reasonably 

necessary. 

It is important to note that, throughout this document, we have used the terms “permanent 

storage,” “temporary storage” and “emergency storage” to differentiate between those structures 

typically constructed of concrete and topped with metal roofs and the pyramid shaped storage 

units typically with low concrete walls and a vinyl top. The use of the terms “permanent storage” 

and “temporary storage” is strictly to reflect the current terminologies used in industry as defined 

by the U.S. Department of Agriculture (USDA) and in no way represents any EPA decision as to 

how these units will be treated in any subsequent action. See definitions section for a list of 

terms used in this survey. 

In addition to the items listed in the survey forms that follow this introduction, we are also 

requesting copies of the following information to the extent it relates to grain elevators or 

portions of processing plants that consist of grain elevators: 

1. Your current air quality operating permit, if you have one. 

2. Copies of the most recent results from PM/PM10 emissions testing conducted at your 

facility within the last 3 years, including but not limited to, opacity measurements and 

stack testing. No new testing is required for this survey. 

Following is a summary of the forms that comprise this survey: 

Form A General Form. One should be completed for each facility. 

Form B Storage Information. Please complete for storage units at each facility. 

Form C Receiving and Shipping. Complete for shipping/receiving units at each facility. 

Form D Temporary Storage. Please complete one form for each temporary storage area. 

Form E Emergency Storage. Complete one form for each emergency storage area. 

Form F Grain Dryers. Please complete one form for fuels used for grain dryers. 

Form G Permitted Sources. Please complete if any part of your facility is covered under 

an air quality operating permit. 

Form H Work Practices. Please complete if any part of your grain elevator or processing 

facility uses work practices for grain storage, shipping, and receiving operations. 

Form I Add-on Particulate Controls. Please complete for each add-on particulate 

control. 

Signature Date 
Definitions (in addition to those in Subpart DD): 

Storage Unit – For the purposes of this survey, a storage unit is any building, bin, silo, or pile used to 

store corn, wheat, sorghum, rice, rye, oats, barley or soybeans. 

Permanent Storage – A storage unit with an immovable roof; a floor made of concrete, asphalt or 

similar material; and sidewalls made of steel, concrete or similar material. 

Temporary Storage – A storage unit that is comprised of: asphalt, concrete, or other comparable base 

material; rigid self-supporting sidewalls; a tarp, cover or the equivalent; and an aeration system. 

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

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

Other Stand-Alone Elevator – Any grain elevator where less than 50% of grain is received from farms 

AND grain processing is not the primary activity. 

Grain Processing – Equipment or processes used to alter the natural state of grain by fractioning, 

grinding, blending, conditioning, etc., in order to produce a product for human or animal consumption or 

the production of biofuels. 

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

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

Design or Work Practice – Any technique other than the installation of air pollution control equipment 

for the reduction of particulate matter emissions. 
FORM A Page 1 

Grain Elevator Survey

FORM A – General Information

A-1 Facility Name: 

A-2 (a) Facility Street Address: 

(b) Suite or P.O (specify): (c) City: 

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

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

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

(b) Title: (c) Telephone Number: 

(d) Email Address: 

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

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

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

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

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

 

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

(f) State: (g) Zip Code: 

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

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

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

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

FACILITY ID: 

FACID:

(First 4 letters of company name plus first 

4 letters of city name. If not unique 

identifier, add number at end of ID) 

ARCHGALV ADM Grain Company 3100 Wharf Road P.O. Box 2647 Galveston Texas 77553 Galveston Brent Turner 409-763-6443 ext 2210 409-763-6443 ext 2210 Brent Turnerbrent.turner@adm.com 530

Archer Daniels Midland Company ■

4666 Faries Parkway

Decatur IL 62526 ■

■
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. 

ARCHGALV 1974 1

0

0
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 

ARCHGALV P P-1 1974 2,988,823 WHEAT,CORN,SORGHU,SOYBEANS 99,571,181 52 157,913,363 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. 

ARCHGALV R-1 P1 FIXED CONVEYOR BELT 40,000 BPH Y R-2 P1 FIXED CONVEYOR BELT 40,000 BPH Y R-3 P1 FIXED CONVEYOR BELT 40,000 BPH Y S-1 P1 ENMASS DRAG CONVEYOR LOADER 35,000 BPH Y S-2 P1 ENMASS DRAG CONVEYOR LOADER 35,000 BPH Y S-3 P1 35,000 BPH Y S-4 P1 SCREW CONVEYOR LOADER 3,500 BPH Y ENMASS DRAG CONVEYOR LOADER 
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: 

ARCHGALV

N/A - There are no Temporary Storage Piles at this facility. 
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).

ARCHGALV
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. 

ARCHGALV

N/A - There are no Emergency Storage Piles at this facility. 
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. 

ARCHGALV

N/A - There are no Grain Dryers at this facility. 
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. 

ARCHGALV 0

1

0 0

1

0 0

3 3

3 3

0 0

0

0 0

0 0

■
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. 

ARCHGALV

Retractable exhaust hood and drop socks at spout used during each loading of truck or railcar. Truck loading event 

average 45 minutes. 

Ship Loader spout end Bustle Filter Module used during each ship or barge loading. Ship loading event average 24 

hours. 

Choke feed through fixed baffle at pit grate used continuously. Railcar unloading event average 9 minutes per car per 

Receiving Pit.

Utilizes same facility and equipment as Truck shipping station. Railcar loading event average 90 minutes. Grain handling operations equipment (conveyor belts' transfer points, garners, scales, cleaners, turnheads) are aspirated 

and filtered through baghouses at various locations in the facility. 
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 

ARCHGALV APCD-1 Fabric Filter R-1 Manufacturer's specifications ND 

APCD-2 Fabric Filter R-2 Manufacturer's specifications ND APCD-3 Fabric Filter R-3 Manufacturer's specifications ND APCD-4 Fabric Filter S-1 Manufacturer's specifications ND APCD-5 Fabric Filter S-2 Manufacturer's specifications ND APCD-6 Fabric Filter S-3 Manufacturer's specifications ND APCD-7 Fabric Filter S-4 Manufacturer's specifications 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 

 

ARCHGALV -

1 ND - 0.5" 4.0" WG Ambient - -

2 ND - 0.5" 4.0" WG Ambient - -

3 ND - 0.5" 4.0" WG Ambient - -

4 ND - 1.5" 3.5" WG Ambient -

5 ND - 1.5" 3.5" WG Ambient - -

6 ND - 1.5" 3.5" WG Ambient - -

7 ND - 0.5" 4.0" WG Ambient - -
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 

ARCHGALV 1 144 3,060 sq ft 2 144 3,060 sq ft 3 144 3,060 sq ft 4 12 1,104 sq ft 5 12 1,104 sq ft 6 12 1,104 sq ft 7 72 1,530 sq ft
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). 

- --- 

~

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~perusing soy.b:lSed ink
Mr. 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! qa/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- I73), 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 iny 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: 132725
EMISSION 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 PMlPMlO 0.32 0.04

RR-2 Rail Receiving Pit NO.2 PMlPMlO 0.33 0.48

RR-3 Rail Receiving Pit NO.3 PMlPM10 0.33 0.48

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

C-I Cleaner No. 1 PMlPMlO 0.05 0.01

C-2 Cleaner NO.2 PMlPMlO 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 PMlPMlO 2.69 2.80

SHIP-3 Ship Loadout NO.3 PMlPMIO 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 PMlO and PM2.5.

PMlO particulate matter equal to or less than 10 microns in diameter.

Dated July 22,2008
SPECIAL 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, 2008
Buddy 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 TAC

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 ink
Ms. 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 290 18' 03" LONGITUDE 094047' 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 9 116. 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

~9101.201, 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 i1treasonable 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&