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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 construction permits for the above referenced project consisting 

of the following air contaminant sources and control equipment as described in the PSD construction permit applications 

received September 10, 2004. 

Emission 

Point

Description Control Testing Required IDNR Permit 

Number

EPCOG-1 No. 1 CFB Boiler Baghouse, Selective NonCatalytic Reduction, & 

Limestone Injection Flue Gas 

Desulfurization 

PM (Federal & State), 

PM10, Opacity, SO2, 

NOx, VOC, CO, PB, F, 

H2SO4, 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), 

PM10, Opacity, SO2, 

NOx, VOC, CO, PB, F, 

H2SO4, 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), 

PM10, Opacity, SO2, 

NOx, VOC, CO, PB, F, 

H2SO4, 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 PM10, Opacity, & CO 05-A-318-P 

EPIC-2 Diesel Fire Pump None PM10, Opacity, & CO 05-A-319-P 

EPCH-1 Coal Receiving Baghouse PM (State), PM10, & 

Opacity 

05-A-320 

EPCH-2 Coal Transfer & 

Storage 

Baghouse PM (State), PM10, & 

Opacity 

05-A-321 

EPCH-3 Coal Preparation Baghouse PM (State), PM10, & 

Opacity 

05-A-322 
Mr. Boomer 

May 27, 2005 

Page 2 of 3 

EPLH-1 Limestone Receiving Fabric Filter Dust Collector PM (State), PM10, & 

Opacity 

05-A-323 

EPLH-2 Limestone Transfer & 

Storage 

Bin Vent Filter PM (State), PM10, & 

Opacity 

05-A-324 

EPLH-3 Limestone Transfer & 

Storage 

Bin Vent Filter PM (State), PM10, & 

Opacity 

05-A-325 

EPAH-1 Fly Ash Handling Baghouse PM (State), PM10, & 

Opacity 

05-A-326 

EPAH-2 Fly Ash Handling Baghouse PM (State), PM10, & 

Opacity 

05-A-327 

EPAH-3 Fly Ash Handling Baghouse PM (State), PM10, & 

Opacity 

05-A-328 

EPAH-4 Fly Ash Storage Silo Baghouse PM (State), PM10, & 

Opacity 

05-A-329 

EPAH-5 Bed Ash Handling Baghouse PM (State), PM10, & 

Opacity 

05-A-330 

EPAH-6 Bed Ash Handling Baghouse PM (State), PM10, & 

Opacity 

05-A-331 

EPAH-7 Bed Ash Handling Baghouse PM (State), PM10, & 

Opacity 

05-A-332 

EPAH-8 Bed Ash Storage Baghouse PM (State), PM10, & 

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 the permit (especially Permit 

Conditions 10 through 16). Based on the information submitted in your application, 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 Subpart Db (Standards of Performance for IndustrialCommercial-Institutional Steam Generating Units), 

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

• Coal Transfer & Storage and Coal Preparation – Subpart 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 National 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, Commercial, 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 Stationary 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 requirements. As a result of this project, your Title V Operating 

Permit may need to be updated. For additional assistance, please contact Jason Marcel at (515) 242-5014. 

5. The existing boiler (Boilers 1 through 14) must be shutdown, as per the Permit Conditions, no later than 180 days 

after the startup of two of the new Circulating Fluidized 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 and no adverse comments were 

received during the Public Comment Period; therefore, the PSD permits are being issued. 

In the future, a status report of the construction permit application(s) submitted to the Department is available at the State 

Permitting and Air Reporting System (SPARS). The contact person for SPARS is Kevin Connolly at (515) 281-8983 or 

kevin.connolly@dnr.state.ia.us. When requesting modifications to the permits, use the permit number and your plant 

number for identification. Should you have any questions, 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 5th 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 property 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 transferable 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, the 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 proposed project has not been initiated 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 owner 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 operator of the responsibility to comply 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 equipment 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 collected 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 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 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 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 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 Condition 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 questionnaire at least sixty (60) days prior to each 

compliance test date. The completed questionnaire shall 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 compliance 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 notification 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 the schedule set forth in 567 IAC 24.1. 

C. The owner shall send correspondence regarding 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, 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 pollution regulatory agencies and their authorized representatives, 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 Iowa 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 

PM10 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)

SO2

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

and 

90% reduction(12)

23.1(2)”ccc” (8)

NOX

(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% O2

(15) 40 CFR 63 Subpart DDDDD 

Pb NA NA 0.00003 lb/MMBtu heat input(2) PSD Synthetic Minor 

H2SO4 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 surrogate for TSM an emission limit of 0.051 lb/MMBtu heat 

input shall apply as per 567 IAC 23.1(2)”ccc”. (IAC reference to NSPS Subpart Db (Standards of Performance for 

Industrial-Commercial-Institutional Steam Generating 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-minute 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 Performance for Industrial-Commercial-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 SO2 emission rate. The equivalent inlet SO2 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 SO2 controls, assuming 100% conversion on sulfur in the fuels to SO2. (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 characteristics 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 

PM10 Yes 3 hours 40 CFR 51, Appendix M, 201A with 202 

Opacity Yes(1), (2) 1 hour 40 CFR 60, Appendix A, Method 9 

SO2 Yes(1), (2) 1 hour 40 CFR 60, Appendix A, Method 6C 

NOX 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 

H2SO4 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 combustion conditions as the NOx

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. The 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 information deemed necessary by the department to determine 

whether this unit(s) is in compliance. 

Each emissions compliance test must be approved by the DNR. Unless otherwise specified by the DNR, each test 

shall consist of three separate runs. The arithmetic mean of three acceptable test runs shall 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 mutually 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 maintenance 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-Commercial-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 Industrial, 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 utilized in the coal/alternative fuel blends shall not 

exceed 20% by heat input. 

C. The sulfur content of the fuel fired in this emission unit shall 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 selected 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 NOx and SO2 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 factor 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 for 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 the 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 specifications 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 quarterly cylinder gas audits 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 (SO2) emissions discharged to the atmosphere and record the output of the system. SO2 

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 Performance 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 annual 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 SO2 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 Performance 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 annual relative accuracy test audit. 

F. The required CEMS shall be operated and data recorded during all periods of operation of the affected 

facility including periods of startup, shutdown, malfunction or emergency conditions, except for CEMS 

breakdowns, repairs, calibration checks, and zero and span adjustments. 

G. Compliance with the non-NSPS opacity, SO2, and NOx emission standards of this permit shall be 

demonstrated through the use of the monitors required by NSPS Subpart Db. The following conditions 

shall apply to all CEMS for non-NSPS opacity, SO2, NOx, 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 SO2, NOx, 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 (NOx, SO2, 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 automated data acquisition and handling system for each 

hour of each missing data period according to the following procedures: 

i. For the missing data period less than or equal 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 90th percentile hourly concentration 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. 

(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 automated data acquisition and handling system for each 

hour of each missing data period according to the following procedures: 

i. For a missing data period of less than or equal 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 than 8 hours, substitute the greater of: 

1. The 95th percentile hourly pollutant concentration 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 shall coordinate the quarterly cylinder gas audits with 

the Department to afford the Department 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 for 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 

NOX 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 

PM10 Particulate Matter equal to or less than 10 microns in aerodynamic diameter 

scfm Standard cubic feet per minute 

SIP State Implementation Plan 

SO2 Sulfur Dioxide 

VOC Volatile Organic Compound 

END OF PERMIT CONDITIONS 
DNR 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

DNR 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