JJC CPFP|7001011 |0 91214|14236|93A288S4 

# Iowa Department of Natural Resources

Air Quality Construction Permit

Permit Holder

Firm: Muscatine Power and Water

Contact: Responsible Party:

Mary Jean Brewster Mary Jean Brewster

Mgr. Env. Affairs Mgr. Env. Affairs

(563) 262

- 3259

3205 Cedar St., PO Box 899

Muscatine

, IA 52761



# Permitted Equipment

Emission Unit(s): Rail Unloading System

– Unit 9 (See Condition 11)

Control Equipment: Fabric Filter Baghouse (CE21)

Dust Suppression System (CE24A)

Emis sion Point: EP21 (vents inside)

Equipment Location: 1700 Dick Drake Way

Muscatine, IA 52761

Plant Number: 70

- 01

- 011

Issuance of this permit shall not relieve the owner or operator of the responsibility to comply fully with

applicable pr ovisions of the State Implementation Plan (SIP), and any other requirements of local, state,

and federal law.

Permit No. Proj. No. Description Date Stack

Testing

93

- A

- 288

- S 4 14

- 236 Modify PM 2.5 

### limit 09/12/14 No

____________________________________

U nder the Direction of the Director of

the Department of Natural Resources

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## PERMIT CONDITIONS

1. Departmental Review

This permit is issued based on information submitted by the applicant. Any misinformation, false statements or

misrepresentations by t he applicant or by the applicant’s representative(s) shall cause this permit to be void. In

addition, the applicant may be subject to criminal penalties according to Iowa Code Section 455B.146A.

This permit is issued under the authority of 567 Iowa Admin istrative Code (IAC) 22.3. The proposed equipment has

been evaluated for conformance with Iowa Code Chapte r 455B; 567 IAC Chapters 20

– 35 ; and 40 Code of Federal

Regulations ( CFR ) Parts 51, 52, 60, 61, and 63 and has the potential to comply.

No review h as been undertaken on the engineering aspects of the equipment or control equipment other than the

potential of that equipment for reducing air contaminant emissions. The Department assumes no liability, directly or

indirectly, for any loss due to damage to persons or property caused by, resulting from, or arising out of the design,

installation, maintenance or operation of the proposed equipment.



### 2 . Owner and Operator Responsibility

This permit is for the construction and operation of specific emissio n unit(s), control equipment, and emission point

as described in this permit and in the application for this permit. The permit holder, owner, and operator of the

facility shall assure that the installation of the equipment listed in this pe rmit conforms to the design in the

application (i.e. type, maximum rated capacity, etc.)

. No person shall construct, install, reconstruct or alter this

emission unit (s) , control equipment, or emission point without the r equired amended permit

.

Any owner or operator of the specified emission unit(s), control equipment, or emission point, including any person

who becomes an owner or operator subsequent to the date on which this permit is issued, is responsible for assuring

that the installation, operation, and maintenanc e of the equipment listed in this permit is in compliance with the

provisions of this permit and all other applicable requirements.

The owner or operator of any emission unit or control equipment shall maintain and operate the equipment and

control equipm ent at all times in a manner consistent with good practice for minimizing emissions, as required by

paragraph 567 IAC 24.2(1) "Maintenance and Repair”

.



### 3 . Transferability

As limited by 567 IAC 22.3(3)”f”, this permit is not transferable from one locati on to another or from one piece of

equipment to another, unless the equipment is portable. When portable equipment for which a permit has been

issued is to be transferred from one location to another, the Department shall be notified in writing at least s even ( 7 )

days prior to transferring to the new location unless the equipment will be located in an area which is classified as

nonattainment for the National Ambient Air Quality Standards (NAAQS) or is a maintenance area for the NAAQS

in which case notific ation shall be given fourteen (14 ) days prior to the relocation of equipment 1 (See Pe rmit

Condition 8.A.2 ). The owner or operator will be notified at least ten (10) days prior to the scheduled relocation if

the relocation will cause a violation of the (NA AQ S). In such case, a supplemental permit shall be required prior to

the initiation of construction of additiona l control equipment or modifications to equipment needed to meet the

standards.

1 A list of nonattainment areas and maintenance areas for the NAAQS can be obtained from the Department.



### 4 . Construction

A. General Requirements

It is the owner's responsibility to ensure that construction conforms to the final plans and specifications as

submitted, and that adequate operation and maintenance is p rovided to ensure that no condition of air

pollution is created.

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4 . Construction (Continued)

In permit amendments, all provisions of the original permit remain in full force and effect unless they are

specifically changed by the permit amendment. If a proposed project is not timely completed, the owner or

operator shall seek a permit amendm ent in order to revert back to the most recent previous version of the

permit. The previous

, unchanged permit provisions are included in the amendment for your conv enience

only and are unappealable.

This permit or amendment shall become void if any one of the following conditions occurs:

(1) the construction or implementation of the proposed project, as it affects the emission point permitted

herein, is not initiated wi thin eighteen (18) months after the permit issuance date; or

(2) the construction or implementation of the proposed project, as it affects the emission point permitted

herein, is not completed within thirty

- six (36) months after the permit issuance date; or

(3) t he construction or implementation of the proposed project, as it affects the emission point permitted

herein, is not completed within a time period specified elsewhere in this permit.

B. Changes to Plans and Specifications

The owner or operator shal l amend this permit or amendment prior to startup of the equipment if:

(1) Any changes are made to the final plans and specifications submitted for the proposed project; or

(2) This permit becomes void.

Changes to the final plans and specification shall include changes t o plans and specifications for permitted

equipment and control equipment and the specified operation thereof.

C. Amended Permits

The owner or operator may continue to act under the provisions of the pre vious permit for the affected

emission unit(s) and emis sion point, toget her with any previous amendment to the permit

, until one of the

following conditions occurs:

(1) The proposed project authorized by this amendment is completed as it affects the emission unit(s) and

emission point permitted herein; or

(2) This cur rent amendment becomes void.



### 5

. Credible Evidence

As stated in 567 IAC 21.5 and also in 40 CFR Part § 60.11(g), where applicable, any credible evidence may be used

for the purpose of establishing whether a person has violated or is in violation of any p rovisions specified in this

permit or any provisions o f 567 IAC Chapters 20 through 35

.



### 6 . Excess Emissions

Per 567 IAC 24.1(1), e xcess emissions during a period of startup, shutdown, or cleaning of control equipment are

not a violation of the emission standard if it is accomplished expeditiously and in a manner consistent with good

practice for minimizing emissions except when another regulation applicable to the unit or process provides

otherwise. Cleaning of control equipment, which does not require the shutdown of process equipment, shall be

limited to one (1) six

- minute period per one (1) hour period.

An incident of excess emissions other than the above is a violation and may be subject to criminal penalties

according to Iowa Code 455B.146A. If excess emissions are occurring, either the control equipment causing the

excess shall be repaired in an expeditious manner, or the process generating the emissions shall be shutdown within

a reasonable period of time, as specified in 567 IAC 24.1.

An i ncident of excess emissions shall be orally reported by telephone, electronic mail or in person to the appropriate

field office within eight (8) hours of, or at the start of, the first working day following the onse t of the incident (See

Permit Condition 8 .B.1). A written report of an incident of excess emissions shall be submitted as a follow

- up to all

required initial reports within seven (7) days of the onset of the upset condition (See Permit Condition 8.B.2)

.

### Muscatine Power and Water Rail Unloading System, Unit 9 ( EP 21 ) Page 4 of 10

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7. Permit Violations

Knowingly comm itting a violation of this permit may carry a criminal penalty of up to $10,000 per day fine and two

( 2 ) years in jail according to Iowa Code Section 455B.146A.



### 8 . Notification, Reporting, and Recordkeeping

A. The owner or operator shall furnish the Depar tment the following written notifications:

(1) Per 567 IAC 22.3(3)”b”:

(a) T he date construction, installation, or alteration is initiated postmarked within thirty (30) days

following initiation of construction, installation, or alteration;

(b) The actual date of star tup, postmarked within fifteen (15) days following the start of operation;

(2) Per 567 IAC 22.3(3)”f”, when portable equipment for which a permit has been issued is to be

transferred from one location to another, the Department shall be notified:

(a) at least four teen ( 14 ) days before equipment relocation if the equipment will be located in a

nonattainment area for the National Ambient Air Quality Standards (NAAQS) or a maintenance

area for the NAAQS;

(b) at least seven (7 ) days before equipment relocation.

(3) Per 567 IA C 22.3(8), a new owner shall notify the Department of the t ransfer of equipment ownership

within thirty ( 30 ) days of the occurrence. The notification shall be mailed to:

Air Quality Bureau

Iowa Department of Natural Resources

7900 Hickman Road, Suite 1

W indsor Heights, IA 50324

and include the following information:

 The date of ownership change,

 The name, address, and telephone number of the responsible official, the contact person, and the

owner of the equipment both before and after the ownership chan ge; and

 The construction permit number(s) of the equipment changing ownership.

(4) Unless specified per a federal regulation, notification of ea ch compliance test required by P ermit

Condition 12 shall be done not less than thirty (30) days before the required test or performance

evaluation of a continuous emission monitor [567 IAC 25.1(7)] . The notification shall include :

 the time,

 the place,

 the name of the person who will conduct the tests,

 and other information as required by the Department;

If the owner or operator does not provide timely notice to the Department, the Department shall not

consider the test results or performance evaluation results to be a valid demonstration of compliance

with the applicable rules or permit conditions. Upon written requ est, the Department may allow a

notification period of less than thirty (30) days.

B. T he owner or operator shall furnish the Department with the following reports:

(1) Per 567 IAC 24.1(2), an incident of excess emissions as defined in 567 IAC 20.2 shall be repo rted

within eight (8) hours or at the start of the first working day following the o nset of the incident. The

report may be made by electronic mail, in person or by telephone.

(2) Per 567 IAC 24.1(3), a written report of an incident of excess emissions as def ined in 567 IAC 20.2

shall be submitted as a follow

- up to all required initial reports to the Department within seven (7) days

of t he onset of the upset condition.

(3) Operation of this emission unit(s) or control e quipment outside of those operating parameter s specified

in Permit Condition 14 in accordance to the schedule set forth in 567 IAC 24.1.

(4) Per 567 IAC 25.1(6), the owner or operator of any facility required to install a continuous monitoring

system or systems shall provide quarterly reports to the Dire ctor, no later than thirty (30) calendar days

following the end of the calendar quarter, on forms provided by the Director.

### Muscatine Power and Water Rail Unloading System, Unit 9 ( EP 21 ) Page 5 of 10

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8 . Notification, Reporting, and Recordkeeping (Continued)

(5) Per 567 IAC 25.1(7), a written compliance demonstration report for each compliance testing event,

whether successful or not, postmarked not later than six (6) weeks after the completion of the test

period unless other regulations provide for other notification requirements. In that case, the more

stringent reporting requ irement shall be met;

C. All data, records, reports, documentation, construction plans, and calculations required under this permit

shall be available at the plant during normal business hours for inspection and copying by federal, state, or

local air pollut ion regulatory agencies and their authorized representatives, for a minimum of two (2) year s

from the date of recording unless otherwise required by another applicable law (i.e. NSPS, NESHAP, etc.)

D. The owner or operator shall send correspondence regarding this permit to the following address:

Construction Permit Supervisor

Air Quality Bureau

Iowa Department of Natural Resources

7900 Hickman Road, Suite 1

Windsor Heights, IA 50324

Telephone: (515) 725

- 9549

Fax: (515) 725

- 9501

E. The owner or operator shal l send correspondence concerning stack testing to:

Stack Testing Coordinator

Air Quality Bureau

Iowa Department of Natural Resources

7900 Hickman Road, Suite 1

Windsor Heights, IA 50324

Telephone: (515) 725

- 9545

Fax: (515) 725

- 9502

F. The owner or operat or shall send reports and notifications to:

Compliance Unit Supervisor

Air Quality Bureau

Iowa Department of Natural Resources

7900 Hickman Road, Suite 1

Windsor Heights, IA 50324

Telephone: (515) 725

- 9550

F ax: (515) 725

- 9502 Iowa DNR Field Office 6

1 023 West Madison

Washington , IA 52353

Telephone: (319) 653

- 2135

Fax: (319) 653

- 2856



### 9

. Appeal Rights

All conditions within an original permit may be appealed, subject to the appeal rights set forth in 561 IAC Chapter

7. Amended conditions within a permit amendment may be appealed, subject to the appeal rights set forth in 561

IAC Chapter 7. In permit amendments, all provisions of the original permit remain in full force and effect unless

they are specifically changed by the permit amendment. The previous

, unchanged permit provisions are included in

the amendment for your convenience only and are unappealable.

Per 561 IAC 7.4(1), the owner or operator shall file any written notice of appeal within thirty (30) days of receipt of

the issued permit. The written notice of appeal shall be filed with the Director of the Department with a copy to the

Legal Services Bureau Chief at the following addresses:

Director

Iowa Department of Natural Resources

502 East 9 th Street

Des Moines, IA 50319 Bureau Chie f

Legal Services Bureau

Iowa Department of Natural Resources

502 East 9 th Street

Des Moines, IA 50319

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### 10 . Emission Limits

The following emission limits shall not be exceeded:

Pollutant lb/hr 1 tons/yr 2 Additional

Limits Reference

(567 IAC)

Particul ate Matter (PM)

– Federal NA NA NA NA

Particulate Matter (PM)

– State 0.86 0.56 0.01 gr/dscf Requested limits

PM 10 0.86 3 0.56 NA NA AQS

PM 2.5 0.0 36 4 NA NA N AAQS

Opacity NA NA 2 0% 5 23.1(2)”v” 5

Sulfur Dioxide (SO 2 ) NA NA NA NA

Nitrogen Oxides (NO

x ) NA N A NA NA

Volatile Organic Compounds (VOC) NA NA NA NA

Carbon Monoxide (CO) NA NA NA NA

Lead (Pb) NA NA NA NA

Carbon Dioxide equivalents (CO 2 e ) NA NA NA NA

(Single HAP) NA NA NA NA

(Total HAP) NA NA NA NA

1 The emission limit is expressed as the aver age of three (3) runs.

2 The emission limit is a twelve (12) month rolling total.

3 The limit for PM 10 emissions is established for air dispersion modeling.

4 The limit for PM 2.5 emissions is established to address the “Finding of Substantial Inadequacy of Implementation Plan; Call

for Iowa SIP Revision” for PM 2.5 published in the Federal Register (76 FR 9706) on February 22, 2011

. 5 NSPS Subpart Y. The emission limit is a six (6) minute average.



### 11 . Emission Point Characteristics

This emission point sha ll conform to the specifications listed below:

Parameter Value

Stack Height, (ft, from the ground) 25.6 Ft.

Discharge Style Horizontal 1

Stack Opening (inches ) 420 inches x 360 inches

Exhaust Temperature (  F) Ambient

Exhaust Flowrate (scfm) 35,693 scfm

1 The baghouse vents inside a building. For dispersion modeling, emissions are assumed to be discharged from the building in a horizontal

manner.

The temperature and flow rate are intended to be representative and characteristic of the design of th e permitted

emission point. The Department recognizes that the temperature and flow rate may vary with changes in the process

and ambient conditions. If it is determined that either the temperature or flowrate above are different than the values

stated, the owner or operator shall submit a request to the Department within thirty (30) days of the discovery to

determine if a permit amendment is required or submit a permit application requesting to amend the permit.

This emission point, EP 21, along with it s control equipment, is connected to the following emissions units:

Emission Unit Description Maximum Capacity

Rail Hoppers A, B & C (EU20) 1400 tons/hr

Feeder Belt

- A (EU21) 700 tons/hr

Feeder Belt

- B (EU22) 700 tons/hr

Transfer Conveyor Load (EU2 3) 1400 tons/hr

### Muscatine Power and Water Rail Unloading System, Unit 9 ( EP 21 ) Page 7 of 10

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12. Compliance Demonstration(s)

Pollutant Compliance

Demonstration Compliance Methodology Frequency

PM

– Federal No NA NA

PM

– State No NA NA

PM 10 No NA NA

PM 2.5 No NA NA

Opacity No NA NA

SO 2 No NA NA

NO

x No NA NA

VOC No NA NA

CO No NA NA

Pb No NA NA

CO 2 No NA NA

CH 4 No NA NA

N 2 O No NA NA

CO 2 e No NA NA

HAP No NA NA

If an initial compliance demonstration specified above is testing , the owner or the owner’s authorized agent shall

verify compliance with the emissi on limitations contained in Permit Condition 10 within sixty (60) days after

achieving maximum production rate and no later than one hundred eighty (180) days after the initial startup date of

the proposed equipment.

If subsequent testing is specified a bove , the owner or the owner’s authorized agent shall verify compliance with

the emission limitations contained in Permit Condition 10 according to the frequency and timeframe noted above.

If testing is required, the owner or the owner’s authorized agent shall use the test method and run time listed in the

table below unless another testing methodology is approved by the Department prior to testing.

Pollutant Test Run Time Test Method

PM

– Federal 1 hour 40 CFR 60, Appendix A, Method 5

PM

– State 1 ho ur 40 CFR 60, Appendix A, Method 5

40 CFR 51 Appendix M Method 202

PM 10 1 hour 40 CFR 51, Appendix M, 201A with 202

PM 2.5 1 hour 40 CFR 51, Appendix M, 201A with 202

Opacity 1 hour 40 CFR 60, Appendix A, Method 9

SO 2 1 hour 40 CFR 60, Appendix A, Meth od 6C

NO

x 1 hour 40 CFR 60, Appendix A, Method 7E

VOC 1 hour 40 CFR 60, Appendix A, Method 25A

CO 1 hour 40 CFR 60, Appendix A, Method 10

Pb 1 hour 40 CFR 60, Appendix A, Method 12

CO 2 1 hour 40 CFR 60, Appendix A, Method 3

CH 4 1 hour 40 CFR 60, Appe ndix A, Method 18

N 2 O 1 hour 40 CFR 60, Appendix A, Method 320

HAP 1 hour 40 CFR 60, Appendix A, Method 18

Each emissions compliance test must be approved by the Department. Unless otherwise specified by the

Department, each test shall consist of thre e (3) separate runs. The arithmetic mean of three (3) acceptable test runs

shall apply for compliance, unless otherwise indicated by the Department.

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12. Compliance Demonstration(s) (Continued)

Per 567 IAC 25.1(7)”a”, at the Department’s request, a p retest meeting shall be held not later than fifteen (15) days

before the owner or operator conducts the compliance demonstration. A testing protocol shall be submitted to the

Department no later than fifteen (15) days before the owner or operator conducts the compliance demonstration.

Representatives from the Department shall attend this meeting, along with the owner and the testing firm, if any. It

shall be the responsibility of the owner to coordinate and schedule the pretest meeting. A representative of the

Department shall be allowed to witness the test(s). The Department shall reserve the right to impose additional,

different, or more detailed testing requirements.

The owner shall be responsible for the installation and maintenance of test ports. The unit(s) being sampled shall be

operated in a normal manner at its maximum continuous output as rated by the equipment manufacturer, or the rate

specified by the owner as the maximum production rate at which this unit(s) will be operated. In cases wher e

compliance is to be demonstrated at less than the maximum continuous output as rated by the manufacturer, and it is

the owner's intent to limit the capacity to that rating, the owner may submit evidence to the Department that this

unit(s) has been physic ally altered so that capacity cannot be exceeded, or the Department may require additional

testing, continuous monitoring, reports of operating levels, or any other information deemed necessary by the

Department to determine whether this unit(s) is in comp liance.



### 13. New Source Performance Standards ( NSPS ) and

National Emission Standards for Hazardous Air Pollutants ( NESHAP ) Applicability

These emission units are subject to the requirements of 40 CFR Part 60, Subpart Y, “Standards of Performance for

Co al Preparation Plants.” (IAC 23.1(2)”v”) and General Provisions, Subpart A.

These emission unit s are not subject to a National Emission Standards for Hazardous Air Pollutants

(NESHAP) as there are no subparts for this source category.



### 14. Operating Limits

Operating limits for this emission unit shall be:

A. This emissions unit shall not operate more than 1295 hours in any rolling twelve

- month period.

B. The differential pressure drop across the baghouse shall be maintained between 2 and 10 inches water

c olumn while the equipment is in operation

.

C. The owner or operator shall develop a nd maintain an operating and maintenance plan for the baghouse

including a preventative maintenance schedule that is consistent with the manufacturer's instructions for

routine and long

- term maintenance.



### 15. Operating Condition Monitoring and Recordkeeping

Unless specified by a federal regulation, a ll records as required by this permit shall be kept on

- site for a minimum of

two (2) years and shall be available for inspectio n by the Department . Records shall be legible and maintained in an

orderly manner. These records shall show the following:

A. The owner or operator shall maintain the following monthly records:

i. the number of hours that the emissions unit operated; and

ii. the rolling twelve

- month total number of hours that the emissions unit operated.

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B. The owner or operator shall properly operate and maintain equipment to periodically monitor the

differential pressure drop across the baghouse . The monitoring device s and any recorders shall be installed,

calibrated, operated and maintained in accordance with the manufacturer’s recommendations, instructions

and operating manuals or per written facility specific operation and maintenance plan.

C. The owner or operator sha ll collect and record the pressure drop across the baghouse , in inches of water, at

least once per day . This requirement shall not apply on the days that the equipment is not in operation.

D. The owner or operator shall maint ain a record of all inspections an d maintenance and any actio n resulting

from the inspection and maintenance of the baghouse

.



### 16. Continuous Emission Monitoring

Continuous emission monitoring is not required by this permit at this time.



### 17. Permit History

Permit No. Proj. No. Desc ription Date Stack

Testing

93

- A

- 288 93

- 044 Original Permit 7/28/93 Yes

93

- A

- 288

- S1 95

- 156 Limit hours of operation based on testing 7/15/95 No

93

- A

- 288

- S2 06

- 015 Replace Dust Suppression System 2/2/06 Yes

93

- A

- 288

- S3 12

- 290 Add PM 2.5 emission limit 07/ 22/13 Yes



### 18. Description of Terms and Acronyms

The descriptions below are meant only as a brief explanation of terms contained within the permit and may not be

the exact definition of the term or acronym as contained within the regulatio ns.

acfm Actual cubic feet per minute

Applicant The owner, company official or authorized agent

Btu British thermal unit

 C Degrees Celsius

Condensable PM Material that condenses and/or reacts upon cooling and dilution in the ambient air to form

pa rticulate matter immediately after discharge from the stack

CO 2 e Carbon dioxide equivalent which is the aggregate emissions of greenhouse gas (GHG )

emissions based on global warming potential s

Department Iowa Department of Natural Resources

dia. Diamete r

 F Degrees Fahrenheit

ft Foot

GHG Greenhouse Gas which is defined as being the group of carbon dioxide (CO 2 ), methane

(CH 4 ), nitrous oxide (N 2 O), hydrofluorocarbons (HFC), perfluorocarbons (PFC) and

sulfur hexafluoride (SF 6 )

g grams

g/dscm Grams p er dry standard cubic meter

gr Grains

gr/dscf Grains per dry standard cubic foot

gr/scf Grains per standard cubic foot

HAP Hazardous Air Pollutant(s)

hp horsepowerJJC CPFP|7001011 |091214|14236|93A289S4 

# Iowa Department of Natural Resources

Air Quality Construction Permit

Permit Holder

Firm: Muscatine Power and Water

Contact: Responsible Party:

Mary Jean Brewster Mary Jean Brewster

Mgr. Env. Affairs Mgr. Env. Affairs

(563) 262

- 3259

3205 Cedar St., PO Box 899

Muscatine

, IA 52761



# Permitted Equipment

Emission Unit(s): Rail Unloading System

– Unit 9 (See Condition 11)

Control Equipment: Fabric Filter Baghouse (CE22)

Dust Suppression System (CE24A)

Emis sion Point: EP22 (vents inside)

Equipment Location: 1700 Dick Drake Way

Muscatine, IA 52761

Plant Number: 70

- 01

- 011

Issuance of this permit shall not relieve the owner or operator of the responsibility to comply fully with

applicable pr ovisions of the State Implementation Plan (SIP), and any other requirements of local, state,

and federal law.

Permit No. Proj. No. Description Date Stack

Testing

93

- A

- 289

- S 4 14

- 236 Modify PM 2.5 

### limit 09/12/14 No

____________________________________

U nder the Direction of the Director of

the Department of Natural Resources

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## PERMIT CONDITIONS

1. Departmental Review

This permit is issued based on information submitted by the applicant. Any misinformation, false statements or

misrepresentations by t he applicant or by the applicant’s representative(s) shall cause this permit to be void. In

addition, the applicant may be subject to criminal penalties according to Iowa Code Section 455B.146A.

This permit is issued under the authority of 567 Iowa Admin istrative Code (IAC) 22.3. The proposed equipment has

been evaluated for conformance with Iowa Code Chapte r 455B; 567 IAC Chapters 20

– 35 ; and 40 Code of Federal

Regulations ( CFR ) Parts 51, 52, 60, 61, and 63 and has the potential to comply.

No review h as been undertaken on the engineering aspects of the equipment or control equipment other than the

potential of that equipment for reducing air contaminant emissions. The Department assumes no liability, directly or

indirectly, for any loss due to damage to persons or property caused by, resulting from, or arising out of the design,

installation, maintenance or operation of the proposed equipment.



### 2 . Owner and Operator Responsibility

This permit is for the construction and operation of specific emissio n unit(s), control equipment, and emission point

as described in this permit and in the application for this permit. The permit holder, owner, and operator of the

facility shall assure that the installation of the equipment listed in this pe rmit conforms to the design in the

application (i.e. type, maximum rated capacity, etc.)

. No person shall construct, install, reconstruct or alter this

emission unit (s) , control equipment, or emission point without the r equired amended permit

.

Any owner or operator of the specified emission unit(s), control equipment, or emission point, including any person

who becomes an owner or operator subsequent to the date on which this permit is issued, is responsible for assuring

that the installation, operation, and maintenanc e of the equipment listed in this permit is in compliance with the

provisions of this permit and all other applicable requirements.

The owner or operator of any emission unit or control equipment shall maintain and operate the equipment and

control equipm ent at all times in a manner consistent with good practice for minimizing emissions, as required by

paragraph 567 IAC 24.2(1) "Maintenance and Repair”

.



### 3 . Transferability

As limited by 567 IAC 22.3(3)”f”, this permit is not transferable from one locati on to another or from one piece of

equipment to another, unless the equipment is portable. When portable equipment for which a permit has been

issued is to be transferred from one location to another, the Department shall be notified in writing at least s even ( 7 )

days prior to transferring to the new location unless the equipment will be located in an area which is classified as

nonattainment for the National Ambient Air Quality Standards (NAAQS) or is a maintenance area for the NAAQS

in which case notific ation shall be given fourteen (14 ) days prior to the relocation of equipment 1 (See Pe rmit

Condition 8.A.2 ). The owner or operator will be notified at least ten (10) days prior to the scheduled relocation if

the relocation will cause a violation of the (NA AQ S). In such case, a supplemental permit shall be required prior to

the initiation of construction of additiona l control equipment or modifications to equipment needed to meet the

standards.

1 A list of nonattainment areas and maintenance areas for the NAAQS can be obtained from the Department.



### 4 . Construction

A. General Requirements

It is the owner's responsibility to ensure that construction conforms to the final plans and specifications as

submitted, and that adequate operation and maintenance is p rovided to ensure that no condition of air

pollution is created.

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4 . Construction (Continued)

In permit amendments, all provisions of the original permit remain in full force and effect unless they are

specifically changed by the permit amendment. If a proposed project is not timely completed, the owner or

operator shall seek a permit amendm ent in order to revert back to the most recent previous version of the

permit. The previous

, unchanged permit provisions are included in the amendment for your conv enience

only and are unappealable.

This permit or amendment shall become void if any one of the following conditions occurs:

(1) the construction or implementation of the proposed project, as it affects the emission point permitted

herein, is not initiated wi thin eighteen (18) months after the permit issuance date; or

(2) the construction or implementation of the proposed project, as it affects the emission point permitted

herein, is not completed within thirty

- six (36) months after the permit issuance date; or

(3) t he construction or implementation of the proposed project, as it affects the emission point permitted

herein, is not completed within a time period specified elsewhere in this permit.

B. Changes to Plans and Specifications

The owner or operator shal l amend this permit or amendment prior to startup of the equipment if:

(1) Any changes are made to the final plans and specifications submitted for the proposed project; or

(2) This permit becomes void.

Changes to the final plans and specification shall include changes t o plans and specifications for permitted

equipment and control equipment and the specified operation thereof.

C. Amended Permits

The owner or operator may continue to act under the provisions of the pre vious permit for the affected

emission unit(s) and emis sion point, toget her with any previous amendment to the permit

, until one of the

following conditions occurs:

(1) The proposed project authorized by this amendment is completed as it affects the emission unit(s) and

emission point permitted herein; or

(2) This cur rent amendment becomes void.



### 5

. Credible Evidence

As stated in 567 IAC 21.5 and also in 40 CFR Part § 60.11(g), where applicable, any credible evidence may be used

for the purpose of establishing whether a person has violated or is in violation of any p rovisions specified in this

permit or any provisions o f 567 IAC Chapters 20 through 35

.



### 6 . Excess Emissions

Per 567 IAC 24.1(1), e xcess emissions during a period of startup, shutdown, or cleaning of control equipment are

not a violation of the emission standard if it is accomplished expeditiously and in a manner consistent with good

practice for minimizing emissions except when another regulation applicable to the unit or process provides

otherwise. Cleaning of control equipment, which does not require the shutdown of process equipment, shall be

limited to one (1) six

- minute period per one (1) hour period.

An incident of excess emissions other than the above is a violation and may be subject to criminal penalties

according to Iowa Code 455B.146A. If excess emissions are occurring, either the control equipment causing the

excess shall be repaired in an expeditious manner, or the process generating the emissions shall be shutdown within

a reasonable period of time, as specified in 567 IAC 24.1.

An i ncident of excess emissions shall be orally reported by telephone, electronic mail or in person to the appropriate

field office within eight (8) hours of, or at the start of, the first working day following the onse t of the incident (See

Permit Condition 8 .B.1). A written report of an incident of excess emissions shall be submitted as a follow

- up to all

required initial reports within seven (7) days of the onset of the upset condition (See Permit Condition 8.B.2)

.

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7. Permit Violations

Knowingly comm itting a violation of this permit may carry a criminal penalty of up to $10,000 per day fine and two

( 2 ) years in jail according to Iowa Code Section 455B.146A.



### 8 . Notification, Reporting, and Recordkeeping

A. The owner or operator shall furnish the Depar tment the following written notifications:

(1) Per 567 IAC 22.3(3)”b”:

(a) T he date construction, installation, or alteration is initiated postmarked within thirty (30) days

following initiation of construction, installation, or alteration;

(b) The actual date of star tup, postmarked within fifteen (15) days following the start of operation;

(2) Per 567 IAC 22.3(3)”f”, when portable equipment for which a permit has been issued is to be

transferred from one location to another, the Department shall be notified:

(a) at least four teen ( 14 ) days before equipment relocation if the equipment will be located in a

nonattainment area for the National Ambient Air Quality Standards (NAAQS) or a maintenance

area for the NAAQS;

(b) at least seven (7 ) days before equipment relocation.

(3) Per 567 IA C 22.3(8), a new owner shall notify the Department of the t ransfer of equipment ownership

within thirty ( 30 ) days of the occurrence. The notification shall be mailed to:

Air Quality Bureau

Iowa Department of Natural Resources

7900 Hickman Road, Suite 1

W indsor Heights, IA 50324

and include the following information:

 The date of ownership change,

 The name, address, and telephone number of the responsible official, the contact person, and the

owner of the equipment both before and after the ownership chan ge; and

 The construction permit number(s) of the equipment changing ownership.

(4) Unless specified per a federal regulation, notification of ea ch compliance test required by P ermit

Condition 12 shall be done not less than thirty (30) days before the required test or performance

evaluation of a continuous emission monitor [567 IAC 25.1(7)] . The notification shall include :

 the time,

 the place,

 the name of the person who will conduct the tests,

 and other information as required by the Department;

If the owner or operator does not provide timely notice to the Department, the Department shall not

consider the test results or performance evaluation results to be a valid demonstration of compliance

with the applicable rules or permit conditions. Upon written requ est, the Department may allow a

notification period of less than thirty (30) days.

B. T he owner or operator shall furnish the Department with the following reports:

(1) Per 567 IAC 24.1(2), an incident of excess emissions as defined in 567 IAC 20.2 shall be repo rted

within eight (8) hours or at the start of the first working day following the o nset of the incident. The

report may be made by electronic mail, in person or by telephone.

(2) Per 567 IAC 24.1(3), a written report of an incident of excess emissions as def ined in 567 IAC 20.2

shall be submitted as a follow

- up to all required initial reports to the Department within seven (7) days

of t he onset of the upset condition.

(3) Operation of this emission unit(s) or control e quipment outside of those operating parameter s specified

in Permit Condition 14 in accordance to the schedule set forth in 567 IAC 24.1.

(4) Per 567 IAC 25.1(6), the owner or operator of any facility required to install a continuous monitoring

system or systems shall provide quarterly reports to the Dire ctor, no later than thirty (30) calendar days

following the end of the calendar quarter, on forms provided by the Director.

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8 . Notification, Reporting, and Recordkeeping (Continued)

(5) Per 567 IAC 25.1(7), a written compliance demonstration report for each compliance testing event,

whether successful or not, postmarked not later than six (6) weeks after the completion of the test

period unless other regulations provide for other notification requirements. In that case, the more

stringent reporting requ irement shall be met;

C. All data, records, reports, documentation, construction plans, and calculations required under this permit

shall be available at the plant during normal business hours for inspection and copying by federal, state, or

local air pollut ion regulatory agencies and their authorized representatives, for a minimum of two (2) year s

from the date of recording unless otherwise required by another applicable law (i.e. NSPS, NESHAP, etc.)

D. The owner or operator shall send correspondence regarding this permit to the following address:

Construction Permit Supervisor

Air Quality Bureau

Iowa Department of Natural Resources

7900 Hickman Road, Suite 1

Windsor Heights, IA 50324

Telephone: (515) 725

- 9549

Fax: (515) 725

- 9501

E. The owner or operator shal l send correspondence concerning stack testing to:

Stack Testing Coordinator

Air Quality Bureau

Iowa Department of Natural Resources

7900 Hickman Road, Suite 1

Windsor Heights, IA 50324

Telephone: (515) 725

- 9545

Fax: (515) 725

- 9502

F. The owner or operat or shall send reports and notifications to:

Compliance Unit Supervisor

Air Quality Bureau

Iowa Department of Natural Resources

7900 Hickman Road, Suite 1

Windsor Heights, IA 50324

Telephone: (515) 725

- 9550

F ax: (515) 725

- 9502 Iowa DNR Field Office 6

1 023 West Madison

Washington , IA 52353

Telephone: (319) 653

- 2135

Fax: (319) 653

- 2856



### 9

. Appeal Rights

All conditions within an original permit may be appealed, subject to the appeal rights set forth in 561 IAC Chapter

7. Amended conditions within a permit amendment may be appealed, subject to the appeal rights set forth in 561

IAC Chapter 7. In permit amendments, all provisions of the original permit remain in full force and effect unless

they are specifically changed by the permit amendment. The previous

, unchanged permit provisions are included in

the amendment for your convenience only and are unappealable.

Per 561 IAC 7.4(1), the owner or operator shall file any written notice of appeal within thirty (30) days of receipt of

the issued permit. The written notice of appeal shall be filed with the Director of the Department with a copy to the

Legal Services Bureau Chief at the following addresses:

Director

Iowa Department of Natural Resources

502 East 9 th Street

Des Moines, IA 50319 Bureau Chie f

Legal Services Bureau

Iowa Department of Natural Resources

502 East 9 th Street

Des Moines, IA 50319

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### 10 . Emission Limits

The following emission limits shall not be exceeded:

Pollutant lb/hr 1 tons/yr 2 Additional

Limits Reference

(567 IAC)

Particul ate Matter (PM)

– Federal NA NA NA NA

Particulate Matter (PM)

– State 1.24 0. 80 0.01 gr/dscf Requested limits

PM 10 1.24 3 0. 80 NA NA AQS

PM 2.5 0.0 36 4 NA NA N AAQS

Opacity NA NA 2 0% 5 23.1(2)”v” 5

Sulfur Dioxide (SO 2 ) NA NA NA NA

Nitrogen Oxides (NO

x ) NA N A NA NA

Volatile Organic Compounds (VOC) NA NA NA NA

Carbon Monoxide (CO) NA NA NA NA

Lead (Pb) NA NA NA NA

Carbon Dioxide equivalents (CO 2 e ) NA NA NA NA

(Single HAP) NA NA NA NA

(Total HAP) NA NA NA NA

1 The emission limit is expressed as the aver age of three (3) runs.

2 The emission limit is a twelve (12) month rolling total.

3 The limit for PM 10 emissions is established for air dispersion modeling.

4 The limit for PM 2.5 emissions is established to address the “Finding of Substantial Inadequacy of Implementation Plan; Call

for Iowa SIP Revision” for PM 2.5 published in the Federal Register (76 FR 9706) on February 22, 2011

. 5 NSPS Subpart Y. The emission limit is a six (6) minute average.



### 11 . Emission Point Characteristics

This emission point sha ll conform to the specifications listed below:

Parameter Value

Stack Height, (ft, from the ground) 25.6 Ft.

Discharge Style Horizontal 1

Stack Opening (inches ) 384 inches x 384 inches

Exhaust Temperature (  F) Ambient

Exhaust Flowrate (scfm) 32,661 scfm

1 The baghouse vents inside a building. For dispersion modeling, emissions are assumed to be discharged from the building in a horizontal

manner.

The temperature and flow rate are intended to be representative and characteristic of the design of th e permitted

emission point. The Department recognizes that the temperature and flow rate may vary with changes in the process

and ambient conditions. If it is determined that either the temperature or flowrate above are different than the values

stated, the owner or operator shall submit a request to the Department within thirty (30) days of the discovery to

determine if a permit amendment is required or submit a permit application requesting to amend the permit.

This emission point, EP22, along with its control equipment, is connected to the following emissions units:

Emission Unit Description Maximum Capacity

Rail Hoppers A, B & C (EU20) 1400 tons/hr

Feeder Belt

- A (EU21) 700 tons/hr

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12. Compliance Demonstration(s)

Pollutant Compl iance

Demonstration Compliance Methodology Frequency

PM

– Federal No NA NA

PM

– State No NA NA

PM 10 No NA NA

PM 2.5 No NA NA

Opacity No NA NA

SO 2 No NA NA

NO

x No NA NA

VOC No NA NA

CO No NA NA

Pb No NA NA

CO 2 No NA NA

CH 4 No NA NA

N 2 O No NA N A

CO 2 e No NA NA

HAP No NA NA

If an initial compliance demonstration specified above is testing , the owner or the owner’s authorized agent shall

verify compliance with the emission limitations contained in Permit Condition 10 within sixty (60) days afte r

achieving maximum production rate and no later than one hundred eighty (180) days after the initial startup date of

the proposed equipment.

If subsequent testing is specified above , the owner or the owner’s authorized agent shall verify compliance wit h

the emission limitations contained in Permit Condition 10 according to the frequency and timeframe noted above.

If testing is required, the owner or the owner’s authorized agent shall use the test method and run time listed in the

table below unless ano ther testing methodology is approved by the Department prior to testing.

Pollutant Test Run Time Test Method

PM

– Federal 1 hour 40 CFR 60, Appendix A, Method 5

PM

– State 1 hour 40 CFR 60, Appendix A, Method 5

40 CFR 51 Appendix M Method 202

PM 10 1 hour 40 CFR 51, Appendix M, 201A with 202

PM 2.5 1 hour 40 CFR 51, Appendix M, 201A with 202

Opacity 1 hour 40 CFR 60, Appendix A, Method 9

SO 2 1 hour 40 CFR 60, Appendix A, Method 6C

NO

x 1 hour 40 CFR 60, Appendix A, Method 7E

VOC 1 hour 40 CFR 60, A ppendix A, Method 25A

CO 1 hour 40 CFR 60, Appendix A, Method 10

Pb 1 hour 40 CFR 60, Appendix A, Method 12

CO 2 1 hour 40 CFR 60, Appendix A, Method 3

CH 4 1 hour 40 CFR 60, Appendix A, Method 18

N 2 O 1 hour 40 CFR 60, Appendix A, Method 320

HAP 1 hour 40 CFR 60, Appendix A, Method 18

Each emissions compliance test must be approved by the Department. Unless otherwise specified by the

Department, each test shall consist of three (3) separate runs. The arithmetic mean of three (3) acceptable test runs

shall apply for compliance, unless otherwise indicated by the Department.

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12. Compliance Demonstration(s) (Continued)

Per 567 IAC 25.1(7)”a”, at the Department’s request, a pretest meeting shall be held not later than fifteen (15) days

before the ow ner or operator conducts the compliance demonstration. A testing protocol shall be submitted to the

Department no later than fifteen (15) days before the owner or operator conducts the compliance demonstration.

Representatives from the Department shall a ttend this meeting, along with the owner and the testing firm, if any. It

shall be the responsibility of the owner to coordinate and schedule the pretest meeting. A representative of the

Department shall be allowed to witness the test(s). The Department shall reserve the right to impose additional,

different, or more detailed testing requirements.

The owner shall be responsible for the installation and maintenance of test ports. The unit(s) being sampled shall be

operated in a normal manner at its maxi mum continuous output as rated by the equipment manufacturer, or the rate

specified by the owner as the maximum production rate at which this unit(s) will be operated. In cases where

compliance is to be demonstrated at less than the maximum continuous outp ut as rated by the manufacturer, and it is

the owner's intent to limit the capacity to that rating, the owner may submit evidence to the Department that this

unit(s) has been physically altered so that capacity cannot be exceeded, or the Department may req uire additional

testing, continuous monitoring, reports of operating levels, or any other information deemed necessary by the

Department to determine whether this unit(s) is in compliance.



### 13. New Source Performance Standards ( NSPS ) and

National Emissi on Standards for Hazardous Air Pollutants ( NESHAP ) Applicability

These emission units are subject to the requirements of 40 CFR Part 60, Subpart Y, “Standards of Performance for

Coal Preparation Plants.” (IAC 23.1(2)”v”) and General Provisions, Subpart A.

These emission unit s are not subject to a National Emission Standards for Hazardous Air Pollutants

(NESHAP) as there are no subparts for this source category.



### 14. Operating Limits

Operating limits for this emission unit shall be:

A. This emissions un it shall not operate more than 1295 hours in any rolling twelve

- month period.

B. The differential pressure drop across the baghouse shall be maintained between 2 and 10 inches water

column while the equipment is in operation

.

C. The owner or operator shall deve lop a nd maintain an operating and maintenance plan for the baghouse,

including a preventative maintenance schedule that is consistent with the manufacturer's instructions for

routine and long

- term maintenance.



### 15. Operating Condition Monitoring and Reco rdkeeping

Unless specified by a federal regulation, a ll records as required by this permit shall be kept on

- site for a minimum of

two (2) years and shall be available for inspection by the Department . Records shall be legible and maintained in an

orderly manner. These records shall show the following:

A. The owner or operator shall maintain the following monthly records:

i. the number of hours that the emissions unit operated; and

ii. the rolling twelve

- month total number of hours that the emissions unit operated.

B. The owner or operator shall properly operate and maintain equipment to periodically monitor the

differential pressure drop across the baghouse . The monitoring devices and any recorders shall be installed,

calibrated, operated and maintained in accordance with the manufacturer’s recommendations, instructions

and operating manuals or per written facility specific operation and maintenance plan.

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C. The owner or operator shall collect and record the pressure drop across the baghouse , in inches of wat er, at

least once per day . This requirement shall not apply on the days that the equipment is not in operation.

D. The owner or operator shall maint ain a record of all inspections and maintenance and any actio n resulting

from the inspection and maintenance of the baghouse

.



### 16. Continuous Emission Monitoring

Continuous emission monitoring is not required by this permit at this time.



### 17. Permit History

Permit No. Proj. No. Description Date Stack

Testing

93

- A

- 289 93

- 044 Original Permit 7/28/93 Yes

93

- A

- 289

- S1 95

- 156 Limit hours of operation based on testing 7/15/95 No

93

- A

- 289

- S2 06

- 015 Replace Dust Suppression System 2/2/06 Yes

93

- A

- 289

- S3 12

- 290 Add PM 2.5 emission limit 07/22/13 No



### 18. Description of Terms and Acronyms

The descript ions below are meant only as a brief explanation of terms contained within the permit and may not be

the exact definition of the term or acronym as contained within the regulations.

acfm Actual cubic feet per minute

Applicant The owner, company officia l or authorized agent

Btu British thermal unit

 C Degrees Celsius

Condensable PM Material that condenses and/or reacts upon cooling and dilution in the ambient air to form

particulate matter immediately after discharge from the stack

CO 2 e Carbon dioxid e equivalent which is the aggregate emissions of greenhouse gas (GHG )

emissions based on global warming potential s

Department Iowa Department of Natural Resources

dia. Diameter

 F Degrees Fahrenheit

ft Foot

GHG Greenhouse Gas which is defined as bei ng the group of carbon dioxide (CO 2 ), methane

(CH 4 ), nitrous oxide (N 2 O), hydrofluorocarbons (HFC), perfluorocarbons (PFC) and

sulfur hexafluoride (SF 6 )

g grams

g/dscm Grams per dry standard cubic meter

gr Grains

gr/dscf Grains per dry standard cubic foot

gr/scf Grains per standard cubic foot

HAP Hazardous Air Pollutant(s)

hp horsepower

hr Hour

lb Pound

lb/hr Pounds per hour

m Meter

mg Milligram

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MM Million

MW Megawatt

NA Not Applicable

PM 2.5 Particulate Matter with an aerodyna mic diameter equa l to or less than 2.5 microns

PM 10 Particulate Matter with an aerodynamic diameter equa l to or less than 10 microns

PM

– Federal Particulate Matter that does not include the condensable PM

PM

– State Particulate Matter that includes condensable PM

ppm parts per million

ppm

v parts per million by volume

ppm

w parts per million by weight

scfm Standard cubic feet per minute

SHAP Single hazardous air pollutant

THAP Total hazardous air pollutants

tons/yr Tons per year

yr Year



## END OF PERMIT

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hr Hour

lb Pound

lb/hr Pounds per hour

m Meter

mg Milligram

MM Million

MW Megawatt

NA Not Applicable

PM 2.5 Particulate Matter with an aerodynamic diameter equa l to or less than 2.5 microns

PM 10 Particulate Matter with an aerodynamic diameter equa l to or less than 10 microns

PM

– Federal Particulate Matter that doe s not include the condensable PM

PM

– State Particulate Matter that includes condensable PM

ppm parts per million

ppm

v parts per million by volume

ppm

w parts per million by weight

scfm Standard cubic feet per minute

SHAP Single hazardous air po llutant

THAP Total hazardous air pollutants

tons/yr Tons per year

yr Year



## END OF PERMIT