## GRAIN ELEVATOR AND PROCESSOR NSPS INDUSTRY SURVEY

INTRODUCTION AND GENERAL INSTRUCTIONS

This survey form is to be completed by a respondent for each of its wholly owned facilities as described in the following four paragraphs (A-D), using the definitions at the end of this introductory section. Respondents must meet the requirements of paragraphs A, B, and C. A. This survey is limited to the following facilities: any “grain elevator” that would constitute a “grain terminal elevator” or a “grain storage elevator” (as those terms are defined by Subpart DD (40 CFR 60.301)) if only permanent storage or both permanent and temporary storage at the grain elevator are taken into account. A respondent need not provide data for any facility not possessing this type of grain elevator. B. EPA is interested in obtaining information about the following categories of grain elevators: (1) Country grain elevators with storage capacity^ ≥ 2,500,000 bushels (2) Other stand-alone elevators with storage capacity^ ≥ 2,500,000 bushels (3) Wheat flour mill elevators * 

### (4) Wet corn mill elevators * 

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

### (6) Rice mill elevators * 

### (7) Soybean oil extraction elevators *

^”Storage capacity” may include only permanent storage c apacity, or it may include both permanent and temporary storage capacity. *Grain elevators in categories 3-7 above must have storage capacity of ≥ 1,000,000 bushels. 

### For each of the above seven categories, a respondent must submit a response for at least five facilities under its control. If a respondent has less than five facilities in a particular category, the respondent must provide information for all of its facilities in that category.

### C. EPA is also interested in obtaining inform ation about the following types of facilities:

 Grain elevators located in each EPA Region.

 Five storage combinations:

- Grain elevator alone

- Grain elevator w/emergency storage

- Grain elevator w/temporary storage

- Grain elevator w/emergency and temporary storage

- Grain elevator w/barge unloading

 Facilities handling multiple grains.

 Facilities handling only one grain. A respondent must submit a response for each of the facilities listed below to the extent it has any such facility under its control for each of the 7 categories listed in paragraph B:

 At least one facility in each Region;

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

 At least one facility that handles multiple grains; and

 At least one facility that handles only one grain. For example, if a respondent has 18 facilities in t he country grain elevator category, and 10 are in EPA Region 5 and eight are in EPA Region 6, the respondent shall provide information for a minimum of five grain elevators. At least one elevator must be in Region 5 and one in Region 6. In addition, if applicable, the respondent shall provide information on at least one facility with each of the five grain storage combinations. The respondent must also provide information for at least one facility that handles multiple grains and one that handles only one grain. In this example, assuming the respondent owned each of the different types of grain elevators of interest to EPA, it is possible to meet the EPA requirements with five facilities responding if the five chosen facilities can meet multiple requirements (e.g., handling multiple grains in EPA Region 5 and using each of the 5 storage methods). However, it may be necessary to provided additional facility respons es to meet the EPA requirements if facilities cannot meet multiple EPA requirements. D. The total number of facilities for a respondent may exceed 35 (five facilities in each of the seven categories) when including the regional, combination, and grain information. However, no respondent is required to submit information about more than 51 facilities. Since one of the goals of this survey is to gather data on temporary storage facilities, EPA encourages respondents to exercise any discretion afforded by paragr aphs A-D above in favor of submitting data on such facilities. For the same reason, EPA encourages respondents to include along with their required responses to this survey any supplemental data on such facilities that may go beyond the bounds of this survey but nevertheless would be helpful to EPA in understanding tem porary storage facilities fully from the standpoint of Subpart DD. This survey is provided in paper format and by first-class mail. However, you may opt to complete this survey either in paper format or in electronic format. To obtai n an electronic file (in Microsoft Word) to compile your responses, please contact Bill Schrock at schrock.bill@epa.gov . Please submit complete responses to Bill Schrock within 60 days after receipt by first-class mail. Any request for an extension of that 60-day period must be submitted to Bill Schrock within 30 days after rece ipt by first-class mail. Extensions will not be granted except upon a showing of undue hardship and then only for the minimum time reasonably necessary. It is important to note that, throughout this document, we have used the terms “permanent storage,” “temporary storage” and “emergency storage” to differentiate between those structures typically constructed of concrete and topped with metal roofs and the pyramid shaped storage uni ts typically with low concrete walls and a vinyl top. The use of the terms “permanent storage” and “temporary storage” is strictly to reflect the current

### receipt by first-class mail. Any request for an extension of that 60-day period must be submitted to Bill Schrock within 30 days after receipt by first-class mail. Extensions will not be granted except upon a showing of undue hardship and then only for the minimum time reasonably necessary. It is important to note that, throughout this document, we have used the terms “permanent storage,” “temporary storage” and “emergency storage” to differentiate between those structures typically constructed of concrete and topped with metal roofs and the pyramid shaped storage units typically with low concrete walls and a viny l top. The use of the terms “permanent storage” and “temporary storage” is strictly to reflect the current terminologies used in industry as defined by the U.S. Department of Agriculture (USDA) and in no way represents any EPA decision as to how these units will be treated in any subsequent action. See definitions section for a list of terms used in this survey. In addition to the items listed in the survey forms that follow this introduction, we are also requesting copies of the following information to the extent it relates to grain elevators or portions of processing plants that consist of grain elevators: 1. Your current air quality operating permit, if you have one. 2. Copies of the most recent results from PM/PM10 emissions testing conducted at your facility within the last 3 years, including but not limited to, opacity measurements and stack testing. No new testing is required for this survey. Following is a summary of the forms that comprise this survey:

Form A General Form . One should be completed for each facility. Form B Storage Information . Please complete for storage units at each facility. Form C Receiving and Shipping . Complete for shipping/receiving units at each facility. Form D Temporary Storage . Please complete one form for each temporary storage area. Form E Emergency Storage . Complete one form for each emergency storage area. Form F Grain Dryers . Please complete one form for fuels used for grain dryers. Form G Permitted Sources . Please complete if any part of your facility is covered under an air quality operating permit. Form H Work Practices . Please complete if any part of your grain elevator or processing facility uses work practices for grain storage, shipping, and receiving operations. Form I Add-on Particulate Controls . Please complete for each add-on particulate control.

Signature Date

# Definitions (in addition to those in Subpart DD):
Storage Unit – For the purposes of this survey, a storage unit is any building, bin, silo, or pile used to store corn, wheat, sorghum, rice, rye, oats, barley or soybeans. Permanent Storage – A storage unit with an immovable roof; a floor made of concrete, asphalt or similar material; and sidewalls made of steel, concrete or similar material. Temporary Storage – A storage unit that is comprised of: asphalt, concrete, or other comparable base material; rigid self-supporting sidewalls; a tarp , cover or the equivalent; and an aeration system. Emergency Storage – A form of storage other than permanent storage or temporary storage. Country Elevator – Any grain elevator where more than 50% of grain is received from farms.

Other Stand

- Alone Elevator – Any grain elevator where less than 50% of grain is received from farms AND grain processing is not the primary activity. Grain Processing – Equipment or processes used to alter the natural state of grain by fractioning, grinding, blending, conditioning, etc., in order to produce a product for human or animal consumption or the production of biofuels. Shipping Units – All equipment associated with loading grain from a storage unit. Receiving Units – All equipment associated with loading grain into a storage unit. Design or Work Practice – Any technique other than the installation of air pollution control equipment for the reduction of particulate matter emissions.

## FORM A Page 1 

# Grain Elevator Survey

FORM A – General Information

A-1 Facility Name:

A-2 (a) Facility Street Address:
(b) Suite or P.O (s pecify): (c) City:
(d) State: (e) Zip Code: (f) County:

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

A-4 (a) Technical contact (for info rmation on this survey):
(b) Title: (c ) Telephone Number:
(d) Email Address:

A-5 Number of full-time employees at this location (total for all shifts): A-6 Number of seasonal employees at this location (total for all shifts):

A-7 (a) Parent Company/ Co-Op:
(b) Is this a co-op? (check one) Yes No
(c) Parent Company/ Co-Op Main Office Street Address:

(d) Suite or P.O. (specify) : (e) City:
(f) State: (g) Zip Code:

A-8 Number of full-time employees within all business units of the Parent Company:
(please check one): < 100 101- 249 250- 499 > 500

A-9 Number of seasonal employees within a ll business units of the Parent Company
(please check one): < 100 101- 249 250- 499 > 500 FACILITY ID:
FACID : (First 4 letters of company name plus first 4 letters of city name. If not unique identifier, add number at end of ID)

# FORM B - Storage Information
(B-1) FACID:

FORM B Page 1 B-2 In what year was this facility first constructed?

B-3 Total number of storage units: (a) "permanent" storage (b) "t emporary" storage (c) "emergency" storage

[Note : In completing the remainder of the survey, y ou will be able to group information for similar storage units. See B-4 for example.]

B-4 Please provide an overview flow diagram (or blo ck flow diagram) of the grain elevator(s) at your facility. Please include pe rmanent (P), temporary (T), and emergency (E) storage units, associated receiving (R) and shipping (S ) units, and grain dryers (D).

o Permanent Storage ID: use your current designation or assign a nu merical value. If assigning an ID, please use “P-1, P-2, etc” format. You may group multiple storage units into one permanent storage ID; if not readily apparent, please provide ex planations on the back of this sheet or indicate in your elevator diagram.

o Temporary Storage ID: use your current designation or assign a nu merical value. If assigning a new ID, please use “T-1, T-2” format.

o Emergency Storage ID: use your current designation or assign a nu merical value. If assigning a new ID, please use “E-1, E-2” format.

o Receiving Units ID: use your current designation or assign a numerical value. If assigning an ID, please use “R-1, R-2” format.

o Shipping Units ID: use your current designati on or assign a numerical value. If assigning an ID, please use “S-1, S-2” format.

o Grain Dryer ID: use your current designation or assign a numerica l value. If assigning an ID, please use “D-1, D-2” format.

o Capacity: please provide capacity in bushels. Do not use a pack factor

.FORM BPage2Please check one: This page includes CBI□This page does NOT include CBI□[If no box is checked, EPA will assume that the page does NOT contain CBI]FORM B – Storage Information(B-1) FACID:B-5.Please complete the following table for storage information. An example is provided.2005 2006 2007Storage Type(P, T, E)StorageIDYear FirstUsedStorageCapacity(Bushels)2GrainStored1Through-put(actual bushels)2Weeks peryear utilizedThrough-put(actual bushels)2Weeks per yearutilizedThrough-put(actual bushels)2Weeks peryear utilizedCorn100,0002P - exampleP-11970300,000Wheat400,00050300,00050300,00050P - exampleP-21985400,000Corn400,00052400,00050400,00048T - exampleT-12004450,000Corn200,00022250,00020150,000241 Use grain designations: corn, wheat, sorghum, rice, rye, oats, barley, soybeans, or specify a different grain.2 Storage capacity and throughput refer to the aggregated storage capacity and throughput of the units included in the storageID from B-4. Fortemporary and emergency storage units, storage capacity and throughput may be estimated based on operator’s knowledge if actualdata is notavailable. For permanent storage units, throughput may be estimated based on operator’s knowledge if actual data is not available.FORM CPage1Please check one: This page includes CBI□This page does NOT include CBI□[If no box is checked, EPA will assume that the page does NOT contain CBI]FORM C – Receiving and Shipping Information(C-1) FACID:C-2Please complete the following table for receiving and shipping operationsat each storage unit (orgroup of units). Use theStorage, Shipping, and Receiving ID’s provided in B-4.An example is provided.What is the Maximum LoadingRate?Receiving/ShippingIDStorage IDassociated withreceiving/shipping unitHow is Grain Received Into orShipped (Loaded) Out ofStorage?aValue UnitsAre there any addon controls for thereceiving/shipping unit (Y/N)Any qualitativeemissionsmonitoringconducted?b(Y/N)R-1P1Fixed Conveyor BeltS-1P1Fixed Conveyor BeltR-1T1Portable AugeraLoading and unloading methods include:portable augerfixed receiving pit with leg to aeration towerenmass drag conveyor unloaderportable inclined beltfixed conveyor off main complexpneumatic unloadergravity fill spoutportable conveyor with trucksor specify a different methodfront-end loadermarine legfixed drag conveyortrack hoe/clamshell unloaderfixed conveyor beltcontinuous barge unloaderbQualitative methods include opacity measurements as well as monitoring instruments (e.g. CEMS), and monitoringof parameters toindicate whether the air pollutioncontrol device is operating properly.

# FORM D – “Temporary” Storage
(D-1) FACID: (D-2) Temporary Storage ID:

FORM D Page 1 (Please copy this sheet and comp lete a separate sheet for each temporary storage at your facility)

D-3 Please provide a diagram of each storage unit and indicate which pieces of equipment (e.g., walls, cover, floor, conveyance system, generator, housing for electrical, etc) remain in place year round and which are removed during specific time s of the year. If th is system is identical (or nearly identical) to another temporary system at the same facility, only one diagram is needed. Please include all applicable ID numbers on the diagram and explain any differences below.

D-4 What are the materials of construction for this storage unit?

(a) Walls:

(b) Cover/tarp:

(c) Floor:

D-5 (a) Has the cover/tarp ever been replaced? (check one) Y N

(b) If yes, month(s)/year(s) cover/ tarp was used before being replaced:

# FORM D – “Temporary” Storage
(D-1) FACID: (D-2) Temporary Storage ID:

FORM D Page 2 D-6 Describe the routine maintenance (including repai r and replacement) that is conducted on the temporary storage units, including frequency of these activities. If you typically replace a component of a unit (e.g., repl acement of a tarp/cover in sections, as opposed to entire replacement), indicate frequency and typical perc ent of the entire unit that is replaced.
Walls:

Floors:

Cover/Tarp:

Aeration:

Other equipment associated with st orage (e.g., conveying equipment)

D-7 Describe methods used to reduce particulate emissions during receiving and shipping, aeration (or other similar processes), and general storage. Indicate frequencies of any actions. (Please complete Form I for any add-on pollution control device).

# FORM E – “Emergency” Storage
(E-1) FACID: (E -2) Emergency Storage ID:

FORM E  Page 1 E- 3 Explain any approaches taken to minimize particulate emissions from the emergency storage pile. Indicate frequencies of any actions.

# FORM F – Grain Dryers
(F-1) FACID:

FORM F  Page 1 F-  Please complete the following tabl e for grain dryers used at your facility. Use the Dryer, Storage, Shipping, and Receiv ing ID’s provided in B-3. An example is provided.

How much fuel was used Grain Dryer ID Storage/Receiving/Ship ping units associated with Dryer Fuel Used 1 2005 2006 2007 D-1 P-1, P-2, R-1, S-1 FO2 10,000 10,000 8,000 D-2 T-1 FO2 1,000 1,000 1,000

1 

## Select fuel from list below. If other, please specify. FO2 - #2 Fuel Oil (gallons) FO6 - #6 Fuel Oil (gallons) NG – Natural Gas (MM cubic feet) Bio – Biofuel (gallons) O – Other, please specify type of fuel and unit of measure

F-  For each column dryer at your facility that does not include a perforated column plate in its design, please: (1) describe the design of that dryer, including whether it uses woven wire screening; (2) indicate the grain(s) for which t he dryer is used; and (3) provide the year of original installation.

# FORM G –Permitted Sources
(G-1) FACID:

FORM G Page 1 G-2 Please indicate the total number of each component listed below that you have at this facility and the number for which your operating permit specifies an applicable control requirement.

Component Total Number at Site Number for which your permit specifies a control requirement? 

### Truck receiving station Truck shipping station Barge and ship receiving station Barge and ship shipping station Railcar receiving station Railcar shipping station Grain dryer



## G-3 Is any grain handling equipment subjected to a control requi rement in your permit?

(check one) Y N

As defined in NSPS, Subpart DD, grain handling operations includ e, as an assemblage of equi pment, bucket elevators or legs (excluding legs used to unload barges or ships), sc ale hoppers and surge bins (garners), turn heads, scalpers, cleaners, trippers, and the headhouse and other such structures. 

## For purposes of Form G, the term “control requirement” refers onl y to particulate matter (PM) emission limits specified for the particular “component” in question and expressed in terms of emissions per unit of time or production ( e.g., lb of PM/hr; grains/dscf), opacity ( e.g., 20%), or a design or work practice ( e.g., use of enclosure), and not to rest rictions on operational parameters such as hours, feedstock or throughput.

# FORM H – Work Practices
(H-1) FACID:

FORM H Page 1 H-2 Describe the design or work practices you follow to reduce emissions (e.g, choke flow, louvered grates, mineral oil, etc.). Please describe the frequency the activity is used (e.g, during each loading operation, all the time, etc) and the estimated time spent on the activity per usage (e.g, 20 minutes per loading event). For “barge and ship receiving station,” pleas e provide copies of any equivalency determinations under 40 CFR 60.302(d) and any permit conditions resulting from such determinations.



## Truck receiving station

Truck shipping station

Barge and ship receiving station

Barge and ship shipping station

Railcar receiving station

Railcar shipping station

Grain dryer

Grain handling operations a

a 

### As defined in NSPS, Subpart DD, grain handl ing operations include, as an assemblage of equipment, bucket elevators or legs (excluding legs used to unload barges or ships), sc ale hoppers and surge bins (garners), turn heads, scalpers, cleaners, trippers, and the headhouse and other such structures.FORM I – Add-on Pollution Control Device(I-1) FACID:FORM IPage 1If data are not available or unknown, please enter NDI-2Please complete the following table for any air pollution control devices at your facility. Please provide ID and include on processdiagram. For each unit, please provide the most recent performance data you have.An example is provided.Air Pollution ControlDevice IDType of Control [e.g., fabricfilter/baghouse; cyclone;other (specify)]Points controlledby this control(Use ID’s fromForms B, C, andD)Type of Data Available [e.g.,performance test, manufacturer’sspecs or guarantee, engineeringcalculations, other (specify)]DesignEfficiencyUnits (include whetherefficiencies are for PM,PM10PM2.5, opacity)APCD-1 exampleCycloneR-1, R-2Manufacturer’s specifications40%PMAPCD-2 exampleFabric FilterS-1Manufacturer’s specifications90%PM and PM10Make additional copies, as necessary

# FORM I – Add-on Pollution Control Device
(I-1) FACID:

FORM I   Page 2 I-3. Provide a copy of the most re cent performance test for each air pollution control device If no performance tests are available, complete questions I-4 through I-7.

I-4. Please complete for each c ontrol device listed in I-2.

Inlet Flow Pressure Drop Inlet Temperature APCD ID Max Units Min Max Units Min Max o 

### C/ o 

### F



## I-5 For each cyclone, please co mplete the following table
APCD ID Particle Density Units

# FORM I – Add-on Pollution Control Device
(I-1) FACID:

FORM I  Page 3 I-6 . For each fabric filter/baghouse, pl ease provide the following information. APCD ID Number of bags Total Surface Area Units

I-7 For each control not listed in I-5 and I-6, please describe the te chnology and the parameters that are relevant for operation of the control

### ENCLOSURE 2 EPA's Information Gathering Authority Under Section 114 of the Clean Air Act Under Section 114 of the Act (42 U.S.C. 7414), Congress has given the U.S. Environmental Protection Agency broad authority to secure information needed for the purpose of (i) developing or assisting in the development of any implementation plan under Sect ion 110 or 111(d), any standard of performance under Section 111, or any emission standard under Section 112; (ii) determining whether any person is in violation of any such standard of any requirement of such a plan; or (iii) carrying out any prov ision of this Act. Among other things, Section 114 authorizes EPA to make ins pections, conduct tests, examine records, and require owners or operators of emission sources to submit information reasonably required for the purpose of developing such standards. In addition, the EPA Office of General Counsel has interpreted Section 114 to include authority to photograph or require submission of photographs of pertinent equipment, emissions, or both. Under Section 114, EPA is empowered to obtain info rmation described by that section even if you consider it to be confidential. You may, however, request that EPA treat such information as confidential. Information obtained under Section 114 and covered by such a request will ordinarily be released to the public only if EPA determines that the information is not entitled to confidential treatment. 1 

### Procedures to be used for making confidentiality determinations, substantive criteria to be used in such determinations, and special rules governing information obtained under Section 114 are set forth in 40 CFR Part 2 published in the Federal Register on September 1, 1976 (40 FR 36902). Pursuant to § 2.204(a) of EPA's Freedom of Information Act (FOIA) regulation, in the event a request is received, or it is determined that a request is likely to be received, or EPA desires to determine whether business information in its possession is entitled to confidential treatment even though no request for release of the information has been received, please be advised that EPA will seek, at that time, the following information to support your claim as required by § 2.204(e)(4) of EPA's FOIA regulations: 1. Measures taken by your company to guard against undesired disclosure of the information to others; 2. The extent to which the information has been disclosed to others, and the precautions taken in connection therewith; 3. Pertinent confidentiality determinations, if any, by EPA or other Federal agencies, and a copy of any such determinations, or reference to it, if available; and 4. Whether your company asserts that disclosure of the information would be likely to result in substantial harmful effects on the business' competitive position, and if so, what those harmful effects would be, why they should be viewed as substantial, and an explanation of the causal relationship between disclosure and such harmful effects.

1 

### Section 114 requires public availability of all emission da ta and authorizes disclosure of confidential information in certain circumstances. See 40 FR 36902 - 36912 (September 1, 1976).1021 NORTH GRAND AVENUE EAST, P.O. Box 19506, SPRINGFIELD, ILLINOIS 62794-9506

- ( 217) 782-2113

DOUGLAS P. SCOTT, DIRECTOR i r.:. '.- 

### ILLINOIS ENVIRONMENTAL PROTECTION AGENCY

217/782-2113

LIFETIME OPERATING PERMIT

- NSPS SOURCE

- REVISED

PERMITTEE

ADM Grain Company Attn: Miranda Gerard Environmental Specialist 4666 Faries Parkway Decatur, Illinois 6 2525

Application No,: 73070147 Applicant's ,Designation: NEW BIN Subj ect: Gra'in Elevator Date Issued: March 24, 2009 Location: 5848 Old Route 54, New Berlin, I.D. No.: 167808AAB Date Received: January 2, 2009

Expiration Date: See Condition 1. Sangamon County

This permit is hereby granted to the above-designated Permittee to OPERATE emission unit(s) and/or air pollution control equipment consisting of the following grain handling operations structures/equipment:

Two (2) Truck Receiving Pits controlled by a Baghouse One (1) Rail Receiving Pit with Truck Loadout One (1) Rail Receiving Pit controlled by a Baghouse Two (2) Column Dryers Grain Cleaning Internal Transfer Enclosed Grain Storage Bins with Side Draw Spouts One (1) Rail, Loadout Spout with Truck Receiving Pit One (1) Rail Loadout Spout controlled by a baghouse 1,771,000 Bushel Grain Storage Pile System

pursuant to the above~referenced application. This permit is subject to standard conditions attached hereto and the following special condition(s}:

lao This" operating permit is effective only if the Permittee has complied with all standard conditions of the construction permit.

b. Operation of the emission units included "in this permit shall not begin until all associated air pollution control equipment" has been constructed and is operational.

c. Thi"s perrnit shall expire 180 days af.ter the"Illinois EPA"~sends a written request for the renewal of this permit.

d. This permit sha'l,l'- ,terminate if" it is withdrawn or is superseded by a "revised permit.

PRINTED ON RECYCLED PAPER

# ..Page 2

2a. This source is a grain terminal elevator as defined in the New Source

Performance Standard (NSPS) for Grain Elevators, 40 CFR 60 Subparts A and DD. Affected facilities under this NSPS (e.g. each truck unloading station, truck loading station, barge and ship unloading station, barge and ship loading station, railcar loading station, railcar unloading station; grain dryer, and all "grain handling operations, constructed, modified or reconstructed after August 3, 1978) are subject to the requirements of 40 CFR 60 Subparts A and DD. Please be advised that the USEPA has not yet determined whether the l,771,OOO-bushel grain storage pile system is to be considered an affected facility as defined at 40 CFR 60.300 and the associated grain storage capacity designated as permanent storage capacity as defined at 40 CFR 60.301(d). Therefore, it is not known at this time if the subject grain storage pile system is subject"to the requirements of 40 CFR Part 60 Subparts A and DD. Should it be determined that the subject grain storage pile system is

an affected facility subject to the requirements of 40 CFR Part 60 Subparts A and DD, the Permittee shall submit the appropriate permit application(s) and request for permit modification to the Illinois EPA within 90 days of learning of such a determination in order to implement any needed revisions/additions to.the source necessary to achieve compliance with 40 CFR Part 60 Subparts A and DD. The Illinois EPA it administrating NSPS in Illinois on behalf of the United States EPA under a delegation agreement.

b. Pursuant to 40 CFR 60.302(c), on and after the 60th day of achieving the maximum production rate at which the affected facility will be operated, but no later than 180 days after initial startup, no owner or operator subject to the provisions of 40 CPR Part 60 Subpart DD shall
cause to be discharged into the atmosphere any fugitive emission from:

i. Any grain handling operation, which exhibits greater than a percent opacity [40 CFR 60.302 (c) (2)]

.

c. Pursuant to 40 CFR 60.11(d), at all times, the Permittee shall, to the extent practicable, maintain and operate the grain terminal elevator, in a manner consistent with good air pollution control practice for minimizing emissions, pursuant to the New Source Performance Standard.

3. The Permittee shall 

### obtain 'appropriate construction permits for any future

construction of emission units or air pollution control equipment and also request revision of this permit unless such emission unit or equipment is exempted from permitting requirements pursuant -to 35 Ill. Adm. Code 201.146. 4a. No person shall cause or allow the emission of fugitive particulate matter from any process, including any material handling or storage activity that is visible by an observer looking generally toward the zenith (that is, looking at the sky directly overhead) from a point beyond the property line of the emission source, pursuant to 35 Ill. Adm. Code 212.301 except as provided in 35 Ill. Adm. Code 212.314.



### b. The Permittee shall implement maintain a housekeeping check 35 Ill. Adm. Code .212.461(b). required housekeeping practices and list for the grain elevator, pursuant This checklist shall contain the toPage 3

applicable housekeeping practices described in the attached 

### ~Minimum Recommendations for Housekeeping Practices for Grain Handling Facilities."

c. The Permittee shall operate the facility in such a.way that the opacity does not exceed the limits specified in 35 Ill. Adm. Code 212.123.

5. The Permittee shall comply with the requirements of 35 Ill. Adm. Code

212.462.

6a. i. Grain receiving in all dump pits shall be conducted in accordance

with good operating practices to minimize particulate matter emissions.

ii. Each dump pit shall be inspected for proper operation while receiving is occurring, at least once each week (Monday through Sunday) when 

### grain. is received.



### b. i. Grain drying with a column dryer shall be conducted in a dryer

with enclosed grain inlet and outlet and perforations in the external sheeting not exceeding 0.094 inch, pursuant to 35 Ill. Adm. Code 212.463(a).

ii. Each such dryer shall be inspected for any leaks in enclosures

and proper condition df the external sheeting, on at least an annual basis prior to the harvest season.



### c. i. Grain transfer within the elevator (internal transfer), and any

cleaning shall be conducted without visible emissions to the atmosphere.

ii. The grain elevator shall be inspected for presence of visible

emissions from internal transfer and cleaning, while such activity is occurring, at least once each week when such activity is performe~:L

d. i. Grain load-out shall be conducted with socks, sleeves or

equivalent
..

devices, extending to within at least 6 inches below the sides of the receiving vehicle except for topping off. Choke load-out may be performed aS,an equivalent method.

ii. Grain load-out socks, sleeves or equivalent devices shall be

inspected for proper operation while load-out is occurring, at least once each week when grain load-out is performed.

7. Emissions and operation of the source shall not exceed the following limits:

### ~ 

## ..

Page 4

Emissions (Tons/Year) PM PM" Emission Source Receiving: Straight Truck Railcar Drying: , Colwnn Shipping: Truck Loadout Rail Loadout Cleaning Internal Transfer Storage Bin Vents Annual Throughput (Bushel* /Year)

35,000,000** 1,000,000**

9,000,000 

## i,ooo,oOO*** 35,000,000*** 12,000,000 111,600,000 36,000,000 Emissions Factors (Lbs/Ton) PM PM 10

0.180 0.0590 0.032 0.0078

0.220 0.0550

0.086 0.0290 0.027 0.0022 0.075 0.0190 0.061 0.0340 0.025 0.0063

Totals: 1. 76

0.02

27.72

0.60 13.23 12.60 0.95 12.60 69.48 0.58

0.'01

6.93

0.20 1.08 3.19 0.53 3.18 15.70

* One bushel equals 56 pounds

** The total amount of grain received and unloaded into the dump pit

areas shall not exceed 36,000,000 bushels/year overall

.. While the above table shows a 35,000,000 bushels/year maximum from straight trucks and 1,000,000 bushels/year maximum from railcars, only straight trucks are limited to 35,000,000 bushels/year due to their higher emission rate. The amount received via railcar may include the entire 36,000,000 bushels, reduced by the amount actually received via straight trucks in a given year.



### *** The total amount of grain loadout shall not exceed 36,000,000 bushels/year overall. While the above table shows a 1,000,000 bushels/year maximum from truck loadout and 35,000,000 bushels/year maximum from rail loadout, only trucks loadout is limited to 1,000,000 bushels/year due to their higher emission rate. The amount loadout via rail may include the entire 36,000,000 bushels, reduced by the'amount actually loadout via truck loadout in a given year.

These limits are "based on" AP-"4'2 emission factors -based on 98% control efficiency for dump pits controlled by.baghouse, 99% control efficiency for enclosed internal transfer via conveyors and receiving legs, 50% control efficiency for truck loadout with socks, 

### and "information in the permit application. Compliance with annual limits shall be determined from a running total of 12 months of data. '

8a. The amount of grain handling shall not exceed the following limits:

i. The amount -of grain received shall not exceed 36,000,000 bushels/year.

ii. The amount of grain transferred shall not exceed 111,600,000 ,bushels/year.Page 5

iii. The total amount of grain shipped by truck and rail shall not exceed 36,000,000 bushels/year.

iv. The amount of grain dried shall not exceed 9,000,000 bushels per year.

V. The amount of grain cleaned shall not exceed 12,OOO,OOO-bushels

per year.

b. Compliance with annual limits shall be determined on a monthly basis from a running total of monthly data, that is, the current month plus the preceding 11 months.

c. Natural gas, liquefied petroleum gas or propane shall be the only fuels fired in the grain dryer(S)

.

9a. The Permittee shall, in accordance with the manufacturer(s) and/or vendor(s} recommendations, perform periodic inspections and maintenance

on the equipment .covered under this permit such that the equipment are kept in proper working condition and not cause a violation of the Environmental Protection Act or regulations 

### promulgate~ therein.

b. Pollution control devices shall be in operation at all times when the associated emission unites) is in operation and emitting air .contaminants.

lOa. The Permittee shall maintain records of the following items for the grain elevator':

i. Records of housekeeping check lists completed by the elevator manager.

ii. Records for the inspections required by Condition.4(b), 6 and 9, with date, time and observations if such information is not incorporated in the housekeeping.checklist.

iii. Records addressing use of good operating practices for the .emission sources and pollution control equipment:

A. Records for periodic inspection of the emission sources and

pollution control equipment with date, individua1 4 performing the inspection, and nature of inspection; and

B. Records for prompt repair of defects, with -identification

and description of defect, effect on emissions, date identified, date repaired,. and nature of repair.

b. The Permittee shall maintain monthly records of the following items for the source:

i. Total grain received, bushels/month and bushels/year (running

total of 12 months data)

.Page 6

i. Total grain received, bushels/month and bushels/year (running total of 12 months data).

ii. Grain dried, bushels/month and bushels/year (running total of 12 months data)

.
iii. Grain cleaned, bushels/month and bushels/year (running total of

12 months data).

iv. Grain shipped, bushels/month and bushels/year (running total of

12 months data).

v. PM emissions (tons/month, tons/year) with supporting

calculations.



### c. The Permittee shall maintain records for any deviation or exceedance from the requirements of this permit, as determined by the above records or by other means, with date, time, duration, description, corrective action, and measures to prevent future reoccurrences.

11. The Permittee shall maintain records of any repairs or maintenance to the grain elevator as related to emissions of particulate matter including, as applicable, repairs to the dryer enclosures or sheeting

or associated cyclone or filter, repair to enclosures on internal transfer, and replacement of load-out sleeves, socks or equivalent devices with date and description of activity.

12. All records and logs required by this permit shall be retained at a 

### readily~accessible location at the source for at least' three years from the date of entry and shall be made available for inspection and copying by the Illinois EPA upon request. Any records retained in an electronic format (e.g., computer) shall be capable of being retrieved and printed on paper during normal source office hours so as to be able to respond to an Illinois EPA 'request for records during the course of

a source inspection.

13. If there is-an'exceedance of or deviation from the requirements of this permit as determined by the records required by this permit, the Permittee shall submit a report to the Illinois EPA's Compliance Section in Springfield, Illinois within 30 days ,after the ~ exceedancejdeviation. The report shall include the 

### e~issions released. in accordance with the recordkeeping requirements, a copy of the relevant records, and a description of the exceedance or deviation and efforts to reduce emissions and future occurrences.

14. Two (2) copies of required reports and notifications shall be sent to:

Illinois Environmental Protection Agency Division of Air Pollution Control Compliance Section (#40) P.O. Box 19276 Springfield, Illinois 62794-9276Page 7

and one (1) copy shall be sent to"the.Illinois .EPA's regional office at .the. following address"uriless 

### otherwise indlcat'ed:



### Illinois Environmental. Protection Agency Division of Air Pollution Control 5415 North University Peoria, Illinois .61614

15. Persons with lifetime operating permits must obtain a revised permit

for any of the following changes .at the source:

'"', t. a. An increase in emissions above the amount the emission unit or

.,]}'~1" :l:he'source is perm.itted 

### t.o emi:ti



### b. A modification;

c. A 

### change in operations that will result in the source's noncompliance'with conditions in the existing permit; or

d. A change in ownership, company name, or address, so that the

application o~ existing permit is no longer accurate.

16. Thi~ permit has

.. been revised to i~cl~de operation _of the equipme.nt described in Construction Permit No. 09010001~ Please be .advised, .howeveL, that the authorization to operate the equipment described in Corts"truction Permit No. 09010001.,p~rsuan't .to this ~operating"permit ~shall termina~e if the testing. descrIbed in Construc~iori Permit No

.. 09010001 is not performed as required or if satisfactory testing results demonstrating compliance with the applicable. standards and permit conditions are not achieved and submitted ~o the- Il~inois EPA as required

.



### . 

# , This perinit'has been revised to also remove the bulk handling capability that this facility was permitted for as requested by the Permittee,

If you have any .21,7 /,7,82"2113

.. questions on this permit, please contact German Barria at

Edwin G.- .Bakowski,. P. E

.. Manager, Permit :Section Division of 

# A:Lr. Polltltion' Control



# ,-

' .

. ECB:GB:jws Date Signed:

cc:
~,~ ,. 

## -. Region 2

. ' 

### . ..,\

-~. '. '



### ..STATg OF ILLINOIS ENVIRON~g~AL PROTECTION AGENCY
DIVISION O~ AIR POLLUTION CONTROL

P.O. BOX 19506 SPRINGFIELD, ILLINOIS 62794~9S06



### STANDARD

CONDITIONS FOR , 

### LIFETIME

OPERATING

PERMITS

J~11y 1,.1999


### Thi, Illinois Environmental Protection Act [415 

### ILCS 5/39 

### (formerly

- Illinois -Revised Statutes, Chapter 111-1/2, 

### Section 1039) 

### I _grants the Illinois Environmental Protection Agency authority to impose conditions on permits which it issues

.

. } 

### •.. 1_. 

### The issuance of this Permit does not- release the Permitt~e from compliance

- with state and-- federal regulations which- "are part of the Illinois _State Irnplementatiorr plan, as well as with other applicable statues

- and regulations of the United States
or the State of Illinois or with applicable local laws,-_ ordinances and regulatioris:

2. The IllirioisEPA has issued this Permit based upon the information -submitted by the Pe-rmittee irithe permit- application. Any misinformation, false-statement or misrepresentation -in the application shall be ground

- for revocation under 35- Ill. Adm. Code 201.166.



### a. 3. 

### The _Permittee shall not authorize, cause, direct or allow any modification,

as defined_ -in 35 Ill. Adm. Code -201.102, 

### -of

- equipment,

- operations -or practices which are- reflected in the permit application as submitted,

_ until the appropriate permit is obtained _from the Illinois EPA.

b. The Permittee shall obtain a new.or revised permit under Section 39.5 of the Act, if the source no longer meets the applicability- criteria of 35- Ill.: Adm. Code 201169 

### because of changes in emissions units or control equipment.

c. The Permittee shall obtain a revised permit prior to any ~f the

- following changes- at the source:
i. An" 

### ,increase in emissions above' the amount the emission unit .or the
source 'is permitted 

### to emit; or
ii. A modification; or
iii. A change in operations that will result in the source's noncompliance with 

## a condition in the existing permit; or


### iv. A

- change in application o!, ownership, company name, or address;.

existing permit is no' longer accurate.""

. so that ;"~. :-"J': 

### the

a. -This 

## P~i:;mrE



# "6~ly c~~eisemlS"s io,1ilrii lOs -and coritrolequipmenlO.whilephys ically

.. present

_

at the indicated source location. Unless the- Permit specifically provides

- for equipment relocation, this Permit is void for n -item

- of equipment on the day it is removed from the -permitted location,

- or if all equipment is removed.

b. The Permittee shall notify the Illinois EPA in writing to withdraw the Permit if all operations the source have been permanently discontinued.

Page 1 of 2

PRINTED ON RECYCLED PAPER

..

### 5. The Permittee shall allow any duly auth~rized agent of the Illinois EPA, upon' the

pre"sentation of credentials" at reasonable times:

.

a. To enter th'e ,Permittee's 

### emission or noise units are 'pursuant to this. Permit; property where actual or potential located or where any. activity is to be effluent, conducted,

b. To .have access to and to copy 

### any records required to be kept under the terms and 'conditions of this Permit;

C.' To inspect, 

### including during any 'hours. of 

### operatIon of 

### equipment constructed
or operated under this Permit,. such equipment and any equipment required to be kept, used, operated, .calibrated .and .maintained under .this Permit;

or:.,,'.


### or e. l'

- 

### d. 'To obtain an~ remove samples of any discharge or emission of'pollutants; and~

To enter. and utilize any photographic, recording, testing, monitoring other

. equipment for the ',purpose of, preserving,. testing, monitoring

. recoJ;ding any activity, discharge. or emission authorized by this

.. Permit

..

6. 

### The iSsuance of this Permit:

liability for damage to person or the construction / : maintenance, or a. Shall not be considered as' in any manne'r affecting the title of the premises upon which the permitted source is located;

Does not release'the Permittee f~om any property caused by or resulting from operation 'of .the ~source;' b.

c. Does not take into consideration or attest to the structural stability of any unit or part of .the projeet;'and

d. In no manner implies '"r sugge~ts that the Illinois EPA

. (or its officers,

agents; 'or employees) assumes any liability, directly or indirectly,

.. for any loss due to

. damage, ' installation, maintenance,. or operation of' the "'proposed equipmerit 

# or source. .
7. The Permittee shall maintain all ,equipment covered under this Permit in such. a manner that 'the "performance of' such equipment shall not cause a.violation ,of. the Environmental Protection Act or,regulations promulgated thereuner.

8. 

### The Permittee' shall maintain 'a tl1;aintenance 

### record on the .pre~ises

... fqr :each_'"i~em .of, .'

__ " ~ ahp61l\ition'\controi "',,'qifii\ment

.. .' Thls_ records shall be' made availabie" 

# to 'any' 'a'gent : of the

. Illinois EPA

. at any time during normal working hours and/or operating hours. As a minimum,. this record shall show the. dates of. performance

. and nature of preventative maintenance activities
.

.. ;. 

### 9. No pers~n shall' cause or allOW' startup of any emission unit or continued operation during mal'function. 

### ,or breakdown of any emission. unit, or related air pollution



# .. confro:r~equl pmeii"t--.

if ,- 

# sudi'--stirt lip.'

- 

# .or' -con 

# t'Inued-o.pera-tion-'w'ouf,f 

# :~'a:use --'a- 

# '~io la t-i"on

. - ~ f

an applicable emission standard o~ permit limitation if such. operation .,is 

### -not allowed .as a special 'condition,ofthis Permit; as required by .35 Ill. Adm. Code 201,149.

.
10.' The Permittee' shall submit an' Annual Emission Report as required by 35 Ill. Adm. Code -201.302 ."and 35 III : Adm. 'Code Part 254

..
11. .The Permittee shall pay:the' annual site fee for 'the source in accordance with Section.9.S of the Act. Page 2 of 2

PRINTED ON RECYCLED PAPER, 

# . . . DIRECTORY ENVIRONMENTAL.

PROTECTION

AGENCY ..BtlREAU OF AIR . '.' '.

.'. ;. 

### .'

. 

# ,

.. ' llY:HC1Toa

i. ; ,'to .•• ' -~ 

## ...



# .

. 

### Illinois EPA 

## Regi on 1 Bureau of air, FOS 95IlW~st Harrison Des. Plaine's, Illinois

. .60016 

## 847/294-4000

Illinois EPA: 

## Regi on 2 5415 North University Peoria. 'rI1:1.nois. 616141',_~

.. " ~', "

. 309/693";5463'

. .

Illinois EPA

. JRegiOri 3 2009 Mall Street. Collinsville. Illinois.6Zi34: 618/346'-5120 '. 

## 111 i noi s Envi ronnienta 1 Protecti on .Agency Division of Air.Pollution.Control Permit Section '

..

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. 

### 1021 ]I.' 

### Grand Ave E; p:,0.B~i

..

l95Q6: ,_.

.. Spriri~field •. Illinois 62794-9506 

## For assistance in preparing a permit application contact:the Permit, Section.

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### Emissions Measurement Group Office of Compliance and Ethics



## Integrity: Nurturing the Potential Within sm 

### Archer Daniels Midland Company 2205 N. Brush College Road Decatur, IL T 217

. 451.8182 F 217.451.4044 

## November 24, 2006
Ms. Julie Armitage Illinois Environmental Protection Agency Division of Air Pollution Control Compliance Section (#40) P.O. Box 19276 Springfield, Illinois 62794-9276

Re: Archer Daniels Midland Grain Co. Grain Elevator 5848 Old Rte 54 New Berlin, IL 62670 Facility ID: 167808AAB Application #: 06010054
Dear Ms. Armitage:
On October 18, 2006, Beth York, of ADM, performed the requir ed Visual Determination of the Opacity of Emissions for the grain transfer equ ipment constructed under the above referenced construction permit. Tests were conducted in accordance with USEPA Method 9.

Three one-hour tests were conducted on the Enclosed Fill Conveyor leg. The range of opacity readings for the test location was zero percent . Test runs are enclosed, along with process unit operational data.
If you have any questions about the test method used or the re sults obtained, or require further information, please contact me at (217) 451-3522. Tha nk you for your attention to this matter.
Sincerely,

Paul C. Maisel Emissions Measurement Technician Office of Compliance and Ethics
CC: Kevin Mattison, IEPA / Des Plaines Steven Youngblut IEPA/ Springfield