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### PERMIT ISSUANCE May 27, 2005
CERTIFIED MAIL
Bruce Boomer Environmental Manager
Archer Daniels Midland 1251 Beaver Channel Parkway Clinton, IA 52732

Re: IDNR Project: 04-528; Plant Number: 23-01-006; ADM – Clinton Corn Processing
Issuance of PSD Permits & Associated Air Construction Permits

Dear Mr. Boomer:

This letter transmits the attached PSD and associated air cons truction permits for the above re ferenced project consisting of the following air contaminant sources and control equipment as described in th e PSD construction permit applications received September 10, 2004.

Emission

Point Description Control Testing Required IDNR Permit
NumberEPCOG-1 No. 1 CFB Boiler Baghouse, Selective NonCatalytic Reduction, & Limestone Injection Flue Gas
Desulfurization PM (Federal & State),
PM 10 

### , Opacity, SO 2 

### , NOx, VOC, CO, PB, F,
H 2 

### SO 4 

### , Hg, HCl & TSM 05-A-313-P

EPCOG-2 No. 2 CFB Boiler Baghouse, Selective NonCatalytic Reduction, & Limestone Injection Flue Gas
Desulfurization PM (Federal & State),
PM 10 

### , Opacity, SO 2 

### , NOx, VOC, CO, PB, F,
H 2 

### SO 4 

### , Hg, HCl & TSM 05-A-314-P

EPCOG-3 No. 3 CFB Boiler Baghouse, Selective NonCatalytic Reduction, & Limestone Injection Flue Gas
Desulfurization PM (Federal & State),
PM 10 

### , Opacity, SO 2 

### , NOx, VOC, CO, PB, F,
H 2 

### SO 4 

### , Hg, HCl & TSM 05-A-315-P

EPCOG-4 No. 1 Gas-Fired Boiler None PM (State), Opacity, NOx, & CO 05-A-316-P

EPCOG-5 No. 2 Gas-Fired Boiler None PM (State), Opacity, NOx, & CO 05-A-317-P

EPIC-1 Emergency Generator None PM 10 

### , Opacity, & CO 05-A-318-P EPIC-2 Diesel Fire Pump None PM 10 

### , Opacity, & CO 05-A-319-P EPCH-1 Coal Receiving Baghouse PM (State), PM 10 

### , & Opacity 05-A-320

EPCH-2 Coal Transfer & Storage Baghouse PM (State), PM 10 

### , & Opacity 05-A-321

EPCH-3 Coal Preparation Baghouse PM (State), PM 10 

### , & Opacity 05-A-322Mr. Boomer May 27, 2005 Page 2 of 3 

### EPLH-1 Limestone Receiving Fabric Filter Dust Collector PM (State), PM 10 

### , & Opacity 05-A-323

EPLH-2 Limestone Transfer & Storage Bin Vent Filter PM (State), PM 10 

### , & Opacity 05-A-324

EPLH-3 Limestone Transfer & Storage Bin Vent Filter PM (State), PM 10 

### , & Opacity 05-A-325

EPAH-1 Fly Ash Handling Baghouse PM (State), PM 10 

### , & Opacity 05-A-326

EPAH-2 Fly Ash Handling Baghouse PM (State), PM 10 

### , & Opacity 05-A-327

EPAH-3 Fly Ash Handling Baghouse PM (State), PM 10 

### , & Opacity 05-A-328

EPAH-4 Fly Ash Storage Silo Baghouse PM (State), PM 10 

### , & Opacity 05-A-329

EPAH-5 Bed Ash Handling Baghouse PM (State), PM 10 

### , & Opacity 05-A-330

EPAH-6 Bed Ash Handling Baghouse PM (State), PM 10 

### , & Opacity 05-A-331

EPAH-7 Bed Ash Handling Baghouse PM (State), PM 10 

### , & Opacity 05-A-332

EPAH-8 Bed Ash Storage Baghouse PM (State), PM 10 

### , & Opacity 05-A-333

EPCT-1 Cooling Tower Drift Eliminator None 05-A-334 EPCT-2 Cooling Tower Drift Eliminator None 05-A-335 EPCT-3 Cooling Tower Drift Eliminator None 05-A-336
EPBW-1 Boiler Feedwater Treatment (BFT) Baghouse None 05-A-337

EPBW-2 BFT – Neutralization
Tank Vent None None 05-A-338

Your attention is directed toward the specified permit conditions contained within th e permit (especially Permit Conditions 10 through 16). Ba sed on the information submitted in your ap plication, the Department has made the following determinations:

1. The following emission units are subject to the New Source Performance Standards (NSPS):

• CFB Boilers – Subpart A (General Provisions) and Su bpart Db (Standards of Performance for IndustrialCommercial-Institutional Steam Generating Units),

• Gas-Fired Boilers – Subpart A (General Provisions) a nd Subpart Db (Standards of Performance for IndustrialCommercial-Institutional Stea m Generating Units), and

• Coal Transfer & Storage and Coal Preparation – Subpa rt A (General Provisions) and Subpart Y (Standards of Performance for Coal Preparation Plants). No other emission units are subject to an NSPS at this time.

2. The following emission units are subject to the Nati onal Emissions Standards for Hazardous Air Pollutants (NESHAP):

• CFB Boilers – Subpart A (General Provisions) and Subpart DDDDD (National Emissions Standards for Hazardous Air Pollutants for Industrial, Commercia l, and Institutional Boilers and Process Heaters),

• Gas-Fired Boilers – Subpart A (General Provisions) and Subpart DDDDD (National Emissions Standards for Hazardous Air Pollutants for Industrial, Commercial, and Institutional Boilers and Process Heaters), and

• Emergency Generator and Diesel Fire Pump – Subpart A (General Provisions) and Subpart ZZZZ (National
Emissions Standards for Hazardous Air Pollutants for Sta tionary Reciprocating Internal Combustion Engines). No other emission units are subject to a NESHAP at this time.Mr. Boomer May 27, 2005 Page 3 of 3



### 3. This facility is a major source with regard to Prevention of Significant Deterioration (PSD) requirements. This is a major modification to a major source.

4. This facility is a major source with regard to Title V require ments. As a result of this project, your Title V Operating Permit may need to be updated. For additional assi stance, please contact Jason Marcel at (515) 242-5014.

5. The existing boiler (Boilers 1 through 14) must be shut down, as per the Permit Conditions, no later than 180 days after the startup of two of the new Circulating Fluidi zed Bed Boilers (EPCOG-1 through EPCOG-3). Please submit the required rescission request to Ms. Kelli Book of this Department.

6. The proposed project has the ability to meet all state and federal air quality standards a nd no adverse comments were received during the Public Comment Period; th erefore, the PSD permits are being issued.

In the future, a status report of the construction permit appli cation(s) submitted to the Department is available at the State Permitting and Air Reporting System (SPARS). The contact person for SPARS is Kevin Co nnolly at (515) 281-8983 or kevin.connolly@dnr.state.ia.us . When requesting modifications to the pe rmits, use the permit number and your plant number for identification. Should you have any qu estions, please contact Shawn Corbin at 515-242-5272.

Sincerely,

Christopher A. Roling, Senior Environmental Engineer Air Construction Permitting Air Quality Bureau, IDNR

Enclosures – PSD & Air Construction Permits, and Response to Comments

cc: 1) Field Office 6 (w/ enclosures) 2) File: 23-01-006 (w/ enclosures) 3) Kelli Book, IDNR (w/o enclosures) 4) Bill Peterson (w/ enclosures) Air, RCRA, and Toxics Division U.S. EPA Region 7
901 North 5 th 

### Street Kansas City, KS 66101

# Iowa Department of Natural Resources Air Quality PSD Construction Permit

Permit Holder

Firm: ADM – Clinton Corn Processing

Contact: Responsible Party:

Bruce Boomer James Woll Environmental Manager Plant Manager

(563) 241-1620

1251 Beaver Channel Parkway Clinton, IA 52732



# Permitted Equipment

Emission Unit(s): No. 2 CFB Boiler, EUCOG-2 (1500 MMBtu/hr)

Control Equipment: Baghouse (CECOG-2A), Selective Non-Catalytic Reduction (CECOG2C), and Limestone Injection Flue Gas Desulfurization (CECOG-2B)

Emission Point: EPCOG-2

Equipment Location: 1251 Beaver Channel Parkway Clinton, IA 52732

Plant Number: 23-01-006

Permit No. Proj. No. Description Date Testing 05-A-314-P 04-528 Original Permit 5/27/05 Yes

__

Under the Direction of the Director of the Department of Natural Resources

### ADM – Clinton Corn Processing No.2 CFB Boiler (EPCOG-2) page 2 of 10 Clinton, Iowa 05-A-314-P



## PERMIT CONDITIONS

The permit holder, owner and operator of the facility shall assure that the installation, operation, and maintenance of this equipment is in compliance with all of the conditions of this permit.



### 1. Departmental Review

This permit is issued based on information submitted by the applicant. Any misinformation, false statements or misrepresentations by the applicant 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 Administrative Code (IAC) 22.3. The proposed equipment has been evaluated for conformance with Iowa Code Chapter 455B; 567 IAC Chapters 20-31; and 40 CFR Parts 51, 52, 60, 61 and 63 and has the potential to comply.

No review has 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 DNR assumes no liability, directly or indirectly, for any loss due to damage to persons or prope rty caused by, resulting from, or arising out of the design, installation, maintenance or operation of the proposed equipment.



### 2. Transferability

As limited by 567 IAC 22.3(3)"f", this permit is not transf erable from one location 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, th e DNR shall be notified in writing at least thirty (30) days prior to transferring to the new location (See 8.A.6). The owner will be notified at least ten (10) days prior to the scheduled relocation if the relocation will cause a violation of the National Ambient Air Quality Standards. In such case, a supplemental permit shall be required prior to the initiation of construction of additional control equipment or equipment modifications needed to meet the standards.

This permit is for the construction and operation of the specific emission unit(s), control equipment and emission point as described in this permit and in the application for this 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 compliance with the provisions of this permit. No person shall construct, install, reconstruct or alter this emission unit, control equipment or emission point without the required revisions to this permit.



### 3. Construction

This permit shall become void if construction on the propos ed project has not been in itiated within eighteen (18) months after the date of the issuance of this permit and completed within forty-eight (48) months after the date of the issuance of this permit.

It shall be the responsibility of the owne r to ensure that construction conforms to the final plans and specifications as submitted and that adequate operation and maintenance is provided to ensure that no condition of air pollution is created. A supplement to this permit shall be obtained if the owner proposes changes to the final submitted plans and specifications.

### ADM – Clinton Corn Processing No.2 CFB Boiler (EPCOG-2) page 3 of 10 Clinton, Iowa 05-A-314-P
4. 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 provisions specified in this permit or any provisions of 567 IAC Chapters 20 through 31.



### 5. Owner Responsibility

Issuance of this permit shall not relieve the owner or opera tor of the responsibility to co mply fully with applicable provisions of the State Implementation Plan (SIP), and any other requirements of local, state, and federal law.

The owner or operator of any emission unit or control e quipment shall maintain and operate the equipment and control equipment 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".



### 6. Disposal of Contaminants

The disposal of materials collect ed by the control equipment shall meet all applicable rules.



### 7. Excess Emissions

Excess 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 consis tent 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 six-minute period per one-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 em issions 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 incident of excess emissions shall be orally reported to the appropriate DNR field office within eight (8) hours of, or at the start of, the first working day following the onset of the incident (See section 8.B.1). A written report of an incident of excess emissions shall be submitted as a follow-up to all required oral reports within seven (7) days of the onset of the upset condition.



### 8. Notification, Reporting and Recordkeeping

A. The owner shall furnish the DNR the following written notifications:
1. The date construction, installation, or alteration is initiated postmarked within thirty (30) days following initiation of construction, installation, or alteration;
2. The actual date of startup, postmarked within fifteen (15) days following the start of operation;
3. The date of each compliance test required by Permit C ondition 12, at least thirty (30) days before the anticipated compliance test date;
4. The date of each pretest meeting, at least fifteen (15) days before the proposed meeting date. The owner shall request a proposed test plan protocol questionna ire at least sixty (60) days prior to each compliance test date. The completed questionnaire sh all be received by the DNR at least fifteen (15) days before the pretest meeting date;
5. Transfer of equipment ownership, within 30 days of the occurrence;

6. Portable equipment relocation, at least thirty (30) days before equipment relocation.

### ADM – Clinton Corn Processing No.2 CFB Boiler (EPCOG-2) page 4 of 10 Clinton, Iowa 05-A-314-P

8. Notification, Reporting and Recordkeeping (Continued)

B. The owner shall furnish DNR with the following reports:
1. Oral excess emissions reports, in accordance with 567 IAC 24.1;
2. A written compliance demonstration report for each co mpliance testing event, whether successful or not, postmarked not later than forty-five (45) days after the completion of the test period unless other regulations provide for other notif ication requirements. In that case, the more stringent reporting requirement shall be met;
3. Operation of this emission unit(s) or control equipment outside of those limits specified in Permit Conditions 10 and 14 and according to th e schedule set forth in 567 IAC 24.1.

C. The owner shall send correspondence regard ing this permit to the following addresses:

Construction Permit Supervisor Air Quality Bureau Iowa Department of Natural Resources 7900 Hickman Road, Suite 1 Urbandale, IA 50322 Telephone: (515) 281-8189 Fax: (515) 242-5094

D. The owner shall send correspondence concerning stack testing to:

Stack Testing Coordinator Air Quality Bureau Iowa Department of Natural Resources 7900 Hickman Road, Suite 1 Urbandale, Iowa 50322 Telephone: (515) 242-6001 FAX: (515) 242-5127

E. The owner shall send reports and notifications to:

Compliance Unit Supervisor Air Quality Bureau Iowa Department of Natural Resources 7900 Hickman Road, Suite 1 Urbandale, IA 50322 Telephone: (515) 281-8448 Fax: (515) 242-5127 IDNR Field Office 6
1023 West Madison Washington, IA 52353 Telephone: (319) 653-2135 Fax: (319) 653-2856



### F. All data, records, reports, documentation, constructi on plans, and calculations required under this permit shall be available at the plant during normal business hour s for inspection and copying by federal, state, or local air pollution regulatory agenci es and their authorized represen tatives, for a minimum of two (2) years from the date of recording.



### 9. Permit Violations

Knowingly committing a violation of this permit may carry a criminal penalty of up to $10,000 per day fine and 2 years in jail according to Io wa Code Section 455B.146A.

### ADM – Clinton Corn Processing No.2 CFB Boiler (EPCOG-2) page 5 of 10 Clinton, Iowa 05-A-314-P

10a. BACT Emission Limits

Pollutant Tons/Yr (1) Additional Limits Volatile Organic Compounds NA 0.004 lb/MMBTU (2)
Carbon Monoxide (CO) (3) 1052 0.15 lb/MMBTU (4)

(1) Standard is a 365-day rolling total.
(2) Standard is expressed as the average of 3 runs.
(3) Compliance with the emission standards shall be demonstrated through the use of Continuous Emission

Monitoring Systems (CEMS).
(4) This standard is a 30-day rolling average not including periods of startup, shutdown, and malfunction.



### 10b. Other Emission Limits

Pollutant lb/hr Tons/Yr (1) Additional Limits Reference (567 IAC) Federal PM NA NA 0.025 lb/MMBtu heat input (2), (3) 40 CFR 63 Subpart

DDDDD (4)
State PM NA NA 0.018 lb/MMBtu heat input (2) PSD Synthetic Minor

PM 10 27.0 (5) NA 0.018 lb/MMBtu heat input (2) PSD Synthetic Minor Opacity (6) NA NA 20% (7) 23.1(2)”ccc” (8)

SO 2 (6) 1200 (5), (9) 3629 (10) 1.2 lb/MMBtu heat input (11)

and
90% reduction (12) 23.1(2)”ccc” (8)

NO X (6) NA 1445 (10) 0.20 lb/MMBtu heat input (11) 23.1(2)”ccc” (8)

VOC NA NA NA NA

CO (6) 450 (13), (14) NA 400 ppmv @ 7% O 2 (15) 40 CFR 63 Subpart DDDDD Pb NA NA 0.00003 lb/MMBtu heat input (2) PSD Synthetic Minor

H 2 SO 4 NA NA 0.004 lb/MMBtu heat input (2) PSD Synthetic Minor F NA NA 0.0012 lb/MMBtu heat input (2) PSD Synthetic Minor

Total Selected Metals (TSM) (4), (16) NA NA 0.0003 lb/MMBtu heat input (2), (17) 40 CFR 63 Subpart DDDDD

HCl NA NA 0.02 lb/MMBtu heat input (2), (17) 40 CFR 63 Subpart DDDDD Hg NA NA 0.000003 lb/MMBtu heat input (2) 40 CFR 63 Subpart DDDDD

(1) Standard is a 12-month rolling total.
(2) Standard is expressed as the average of three (3) runs.
(3) Should the facility choose not to utilize PM as a surroga te for TSM an emission limit of 0.051 lb/MMBtu heat input shall apply as per 567 IAC 23.1(2)”ccc”. (IAC refere nce to NSPS Subpart Db (Standards of Performance for
Industrial-Commercial-Institutional Steam Generati ng Units). See also 40 CFR §60.40b – 40 CFR §60.49b.
(4) The listed Federal PM limit may be utilized as a surrogate for TSM.
(5) Emission rate used to demonstrate no exceedences of the National Ambient Air Quality Standards (NAAQS).
(6) Compliance with the emission standards shall be demonstrated through the use of a CEMS.
(7) Opacity shall not exceed 20% (6-minut e average), except for one (1) 6-minute period per hour of not more than 27% opacity.
(8) IAC reference to NSPS Subpart Db (Standards of Pe rformance for Industrial-Comme rcial-Institutional Steam Generating Units). See also 40 CFR §60.40b – 40 CFR §60.49b.
(9) Standard is expressed as a three (3) hour average.
(10) This emission limit is a “cap” for the boiler system, Nos. 1-3 CFB Boilers and Nos. 1 &2 Gas Boilers.
(11) Compliance with this standard is determined on a 30-day rolling average basis.
(12) Reduction in the equivalent inlet SO 2 emission rate. The equivalent inlet SO 2 emission rate means the stack emissions (on a lb/MMBtu heat input basis) that would result from the combustion of “as-fired” fuels in the boiler
without SO 2 controls, assuming 100% conversion on sulfur in the fuels to SO 2
. (13) Emission rate used to demonstrate no exceedences of the NAAQS.
(14) This standard is expressed as a one (1) hour standard.
(15) Compliance with this standard is determined on a 30-day rolling average basis not including periods of startup, shutdown, and malfunction
(16) Total Selected Metals (TSM) means the combination of the following metallic HAP: arsenic, beryllium, cadmium, chromium, lead, manganese, nickel, and selenium.
(17) As alternative to the listed emission limits, the facility may opt to comply with the health-based compliance

### ADM – Clinton Corn Processing No.2 CFB Boiler (EPCOG-2) page 6 of 10 Clinton, Iowa 05-A-314-P standards located in Appendix A of 40 CFR 63 Subpart DDDDD.



### 11. Emission Point Characteristics

This emission point shall conform to the specifications listed below.

Parameter Value Stack Height, (ft, from the ground) 412.5 Discharge Style Vertical Unobstructed Stack Opening, (feet, diameter) 12 Exhaust Temperature ( ° F) 310 Exhaust Flowrate (acfm) 495,000

The temperature and flow rate are intended to be representative and characteristic of the design of the 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 any of the emission point design characteris tics are different than the values stated above, the owner/operator must notify the Department and obtain a permit amendment, if required.



### 12. Initial Performance Testing Requirements

Pollutant Testing Required Test Run Time Test Method PM (federal) Yes (1) 2 hours 40 CFR 60, Appendix A, Method 5 PM (state) Yes 2 hours Iowa Compliance Sampling Manual Method 5

PM 10 Yes 3 hours 40 CFR 51, Appendix M, 201A with 202 Opacity Yes (1), (2) 1 hour 40 CFR 60, Appendix A, Method 9

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

NO X Yes (1), (2) 1 hour 40 CFR 60, Appendix A, Method 7E VOC Yes 1 hour 40 CFR 60, Appendix A, Method 25A

CO Yes (2), (3) 1 hour 40 CFR 60, Appendix A, Method 10 Pb Yes 1 hour 40 CFR 60, Appendix A, Method 12 or 29 F Yes 2 hours 40 CFR 60, Appendix A, Method 13A

H 2 SO 4 Yes 1 hour 40 CFR 60, Appendix A, Method 8 Mercury Yes 1 hour 40 CFR 60, Appendix A, Method 29 or ASTM
D6784-02 HCl Yes 1 hour 40 CFR 60, Appendix A, Method 26 TSM Yes 1 hour 40 CFR 60, Appendix A, Method 29

(1) See NSPS Subpart Db (40 CFR §60.40b – 40 CFR §60.49b) for initial performance testing requirements.
(2) Compliance shall be measured continuously through the use of Continuous Emission Monitoring Systems

(CEMS).
(3) The CO compliance tests shall be conducted under the same operating and combus tion conditions as the NO

x

compliance tests.

If specified above , the owner shall verify compliance with the emission limitations contained in Permit Condition
10 within 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. Th e unit(s) being sampled should 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 where 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 physically altered so that capacity cannot be exceeded, or the department may require additional testing, continuous monitoring, reports of operating levels, or any other inform ation deemed necessary by the department to determine whether this unit(s) is in compliance.

Each emissions compliance test must be approved by th e DNR. Unless otherwise speci fied by the DNR, each test shall consist of three separate runs. The arithmetic mean of th ree acceptable test runs sh all apply for compliance, unless otherwise indicated by the DNR. The test methods and run times to be used are those stated above unless otherwise approved by the DNR.

### ADM – Clinton Corn Processing No.2 CFB Boiler (EPCOG-2) page 7 of 10 Clinton, Iowa 05-A-314-P

12. Initial Performance Testing Requirements (Continued)

A pretest meeting shall be held at a mu tually agreeable site no less than fifteen (15) days prior to the date of each test. Representatives from the DNR 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. The owner shall be responsible for the installation and main tenance of test ports. The DNR shall reserve the right to impose additional, different, or more detailed testing requirements.



### 13. NSPS and NESHAP Applicability

This emission unit is subject to Subpart A (General Provisions, 40 CFR §60.1 through 40 CFR §60.19) and Subpart Db (Standards of Performance for Industrial-Commerc ial-Institutional Steam Generating Units, 40 CFR §60.40b through 40 CFR §60.49b) of the New Source Performance Standards (NSPS).

This emission unit is subject to Subpart A (General Provisions, 40 CFR §63.1 – 40 CFR §63.15) and Subpart DDDDD (National Emission Standards for Hazardous Air Pollutants for Industr ial, Commercial and Institutional Boilers and Process Heaters, 40 CFR §63.7480 – 40 CFR §63.7575) of the National Emission Standards for Hazardous Air Pollutants (NESHAP).



### 14. Operating Limits

A. This emission unit, EUCOG-2, shall be limited to firing on coal, natural gas, fuel oil, and coal/alternative
fuel blends.

B. The alternative fuels fired in the emission unit shall be limited to petroleum coke, tire-derived fuel (TDF),
and biomass fuels. The amount of alternative fuels u tilized in the coal/alternativ e fuel blends shall not exceed 20% by heat input.

C. The sulfur content of the fuel fired in this emission unit sh all not exceed 6.5% by weight.

D. These units are subject to all applicable operating limits set forth in NSPS Subparts A (40 CFR §60.1 – 40 CFR §60.19) and Db (40 CFR §60.40b – 40 CFR §60.49b).

E. The permit holder, owner and operator of the facility shall furnish the IDNR with final detailed plans and specifications for all emission control equipment se lected by the owner to meet the emission limits contained Permit Condition 10. In addition, the facility shall detail all revisions made to the affected emission units. This information shall be submitted to the IDNR at least 30 days in advance of construction of any control equipment.

F. The permit holder, owner and operator of the facility may continue operation of existing Boilers 1 through 14, during the construction and shakedown period of the Circulating Fluidized Bed Boilers (EUCOG-1 and EUCOG-2). The permit holder, owner and operator of the facility; however, shall shutdown Boilers 1 through 14 (EUYRD-3A, EUYRD-4A EUYRD-5A EUYRD-6C EUYRD-7D, EU56-29, EU56-30, EU54- 1B, EU54-1A, EU55-1B, EU54-2, EU54-3, EU208-1A2, and EU208-1B2) no later than 180 days after the startup of the new boilers (EUCOG-1 and EUCOG-2).

G. The permit holder, owner and operator of the facility shall furnish, for review by the IDNR, a final netting analysis for NO

x and SO 2 within 60 days of start-up for the affected emission unit (i.e., boilers).

### ADM – Clinton Corn Processing No.2 CFB Boiler (EPCOG-2) page 8 of 10 Clinton, Iowa 05-A-314-P

15. Operating Condition Monitoring

All 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 DNR. Records shall be legible and maintained in an orderly manner.

A. The permit holder, owner and operator of the facility shall record the amounts of each fuel combusted during each day and calculate a new annual capacity fact or for each fuel type at the end of each calendar month as specified in 40 CFR §60.49b(d).

B. The permit holder, owner and operator of the facility shall record the net actual electrical output to any utility power distribution system fo r sale annually, calculated as an average over any three (3) calendar year period.

C. The permit holder, owner and operator of the facility shall maintain a record of periods of startup,
shutdown or malfunction.

D. The permit holder, owner and operator of the facility shall record an analysis showing the sulfur content representative of the fuel combusted each day.

E. The permit holder, owner and operator of the facility shall submit a request to rescind the permits for the existing boilers (EUYRD-3A, EUYRD-4A EUYRD-5A EUYRD-6C EUYRD-7D, EU56-29, EU56-30, EU54-1B, EU54-1A, EU55-1B, EU54-2, EU54-3, EU208-1A2, and EU208-1B2) and a notification the existing boilers are no longer operational within 180 days after the new boilers (EUCOG-1 and EUCOG-2) covered by permits (05-A-313-P and 05-A-314-P) have initiated startup. The date of submittal shall be considered equivalent to the date th e required notification is postmarked.

F. All applicable recordkeeping set forth in NESHAP Subparts A (40 CFR §63.1 – 40 CFR §63.15) and DDDDD (40 CFR §63.7480 – 40 CFR §63.7575).



### 16. Continuous Emission Monitoring

A. In accordance with 40 CFR §60.48b(a), the permit holder, owner and operator of the facility shall install calibrate, maintain, and operate a continuous monitoring system (CEMS) on EPCOG-2 for measuring the opacity of emissions discharged to the atmosphere and record the output of the system. The system shall be designed to meet the 40 CFR 60, Appendix B, Performance Specification 1 (PS1).

B. In accordance with 40 CFR §60.48b(b), the permit holder, owner and operator of the facility shall install calibrate, maintain, and operate a continuous monitoring system (CEMS) on EPCOG-2 for measuring nitrogen oxides emissions discharged to the atmosphere and record the output of the system. The system shall be designed to meet the 40 CFR 60, Appendix B, Performance Specification 2 (PS2) and Performance Specification 6 (PS6) requirements. The specificati ons of 40 CFR Appendix F (Quality Assurance/Quality Control) shall apply. Appendix F requirements shall be supplemented with a quarterly notice to the Department with the dates of the qua rterly cylinder gas aud its and annual relative accuracy test audit.

C. In accordance with 40 CFR §60.47b(a), the permit holder, owner and operator of the facility shall install calibrate, maintain, and operate a continuous monitoring system (CEMS) on EPCOG-2 for measuring sulfur dioxide (SO 2 ) emissions discharged to the atmosphere and record the output of the system. SO 2 emissions shall be monitored at the outlet. The system shall be designed to meet the 40 CFR 60, Appendix B, Performance Specification 2 (PS2) and Perform ance Specification 6 (PS6) requirements. The specifications of 40 CFR 60, Appendix F (Quality Assurance/Quality Control) shall apply. Appendix F requirements shall be supplemented with a quarterly notice to the Department with the dates of the quarterly cylinder gas audits and a nnual relative accuracy test audit.

D. In accordance with 40 CFR §60.47b(a), the permit holder, owner and operator of the facility shall install calibrate, maintain, and operate a continuous monitoring system (CEMS) on EPCOG-2 for measuring either oxygen or carbon dioxide content of the flue gas at each location where SO 2 emissions are monitored, and record the output of the system.

### ADM – Clinton Corn Processing No.2 CFB Boiler (EPCOG-2) page 9 of 10 Clinton, Iowa 05-A-314-P

16. Continuous Emission Monitoring (Continued)

E. The permit holder, owner and operator of the facility shall install, calibrate, maintain, and operate a CEMS on EPCOG-2, and record the output of the system, for measuring carbon monoxide (CO) emissions discharged to the atmosphere. The system shall be designed to meet the 40 CFR 60, Appendix B, Performance Specification 4A (PS4A) and Perform ance Specification 6 (PS6) requirements. The specifications of 40 CFR 60, Appendix F (Quality Assurance/Quality Control) shall apply. Appendix F requirements shall be supplemented with a quarterly notice to the Department with the dates of the quarterly cylinder gas audits and a nnual relative accuracy test audit.

F. The required CEMS shall be operated and data record ed during all periods of operation of the affected facility including periods of start up, shutdown, malfunction or emergency conditions, except for CEMS breakdowns, repairs, calibration checks, and zero and span adjustments.

G. Compliance with the non-NSPS opacity, SO 2 , and NO

x emission standards of this permit shall be demonstrated through the use of the monitors requi red by NSPS Subpart Db. The following conditions shall apply to all CEMS for non-NSPS opacity, SO 2 , NO

x , and CO emission standards: (1) The CEMS required by this permit shall be operated and data recorded during all periods of operation except for CEM breakdowns, preventive maintenance and repairs. Data is recorded during calibration checks, and zero and span adjustments. (2) The 1-hour average SO 2 , NO

x , and CO emission rates measured by the CEMS required by this permit shall be used to calculate compliance with the emission standards of this permit. At least 2 data points must be used to calculate each 1-hour average. (3) For each hour of missing emission data (NO

x , SO 2 , or CO), the owner or operator shall substitute data by: (a) If the monitor data availability is equal to or greater than 95.0%, the owner or operator shall calculate substitute data by means of the automa ted data acquisition and handling system for each hour of each missing data period accord ing to the following procedures:
i. For the missing data period less than or equa l to 24 hours, substitute the average of the hourly concentrations recorded by a pollutant concentration monitor for the hour before and the hour after the missing data period.
ii. For a missing data period greater than 24 hours, substitute the greater of:
1. The 90 th percentile hourly concentration reco rded by a pollutant concentration monitor during the previous 720 quality -assured monitor operating hours; or
2. The average of the hourly concentrations recorded by a pollutant concentration monitor for the hour before and the hour after the missing data period. (b) If the monitor data availability is at least 90.0% but less than 95.0%, the owner or operator shall calculate substitute data by means of the automa ted data acquisition and handling system for each hour of each missing data period accord ing to the following procedures:
i. For a missing data period of less than or equa l to 8 hours, substitute the average of the hourly concentrations recorded by a pollutant concentration monitor for the hour before and the hour after the missing data period.
ii. For the missing data period of more th an 8 hours, substitute the greater of:
1. The 95 th percentile hourly pollutant concen tration recorded by a pollutant concentration monitor during the previous 720 quality-assured monitor operating hours; or
2. The average of the hourly concentrations recorded by a pollutant concentration monitor for the hour before and the hour after the missing data period. (c) If the monitor data availability is less than 90.0%, the owner or operator shall obtain actual emission data by an alternate testing or monitoring method approved by the Department.

H. If requested by the Department, the owner/operator sha ll coordinate the quarterly cylinder gas audits with the Department to afford the Depart ment the opportunity to observe these audits. The relative accuracy test audits shall be coordinated with the Department

I. The procedures under 40 CFR §60.13 shall be followed fo r installation, evaluation, and operation of the
CEMS.

### ADM – Clinton Corn Processing No.2 CFB Boiler (EPCOG-2) page 10 of 10 Clinton, Iowa 05-A-314-P

17. Descriptions of Terms and Acronyms

acfm Actual cubic feet per minute Applicant The owner, company official or authorized agent CFR Code of Federal Regulations Department Iowa Department of Natural Resources DNR Iowa Department of Natural Resources gr/dscf Grains per dry standard cubic foot HAP Hazardous Air Pollutant(s)
IAC Iowa Administrative Code
MMBtu One million British thermal units NA Not Applicable NAAQS National Ambient Air Quality Standards
NO X Nitrogen Oxides Owner The owner or authorized representative Permit This document including permit conditions and all submitted application materials PM (federal) Includes particulate matter captured in only the front-half (filterable) during compliance testing PM (state) Includes particulate matter captured in the front-half (filterable) and back-half (condensable) during compliance testing

PM 10 Particulate Matter equal to or less than 10 microns in aerodynamic diameter scfm Standard cubic feet per minute SIP State Implementation Plan
SO 2 Sulfur Dioxide VOC Volatile Organic Compound



## END OF PERMIT CONDITIONSDNR Form 542-4008 (5/2005) 

# Air Quality Equipment Notification Form

Facility and Equipment Information:

Company ADM – Clinton Corn Processing

Equipment Location Clinton, Iowa Check ( √ ) here for portable equipment


### Facility Number
( Not EIQ Number) 

### 23-01-006

Emission Unit No. 2 CFB Boiler

Emission Point # EPCOG-2

Construction Permit # 05-A-314-P



## Notification Type (check the appropriate box or boxes):

Date Construction, Installation, or Alteration Started:
Notification must be postmarked within 30 days after construction starts.

Date of Actual Equipment Start Up:
Notification must be postmarked within 15 days after equipment is placed into operation.



## Signature of Company Official:

Signature Date

Name (please print)

Title

Phone Number



### This form is also available on the Internet at http://www.state.ia.us/epd/airconst/conaps/aqcnap.htm

Please mail form to (no faxes please): Compliance Unit Supervisor Air Quality Bureau Department of Natural Resources 7900 Hickman Road, Suite 1 Urbandale, IA 50322DNR Form 542-4008 (5/2005) 

# Air Quality Equipment Notification Form

Facility and Equipment Information:

Company ADM – Clinton Corn Processing

Equipment Location Clinton, Iowa Check ( √ ) here for portable equipment


### Facility Number
( Not EIQ Number) 

### 23-01-006

Emission Unit No. 2 CFB Boiler

Emission Point # EPCOG-2

Construction Permit # 05-A-314-P



## Notification Type (check the appropriate box or boxes):

Date Construction, Installation, or Alteration Started:
Notification must be postmarked within 30 days after construction starts.

Date of Actual Equipment Start Up:
Notification must be postmarked within 15 days after equipment is placed into operation.



## Signature of Company Official:

Signature Date

Name (please print)

Title

Phone Number



### This form is also available on the Internet at http://www.state.ia.us/epd/airconst/conaps/aqcnap.htm

Please mail form to (no faxes please): Compliance Unit Supervisor Air Quality Bureau Department of Natural Resources 7900 Hickman Road, Suite 1 Urbandale, IA 50322