Notice of Decision: Approval -Effective Immediatelypermits.air.idem.in.gov/33784f.pdf§ 60.301...

INDIANA DEPARTMENT OF ENVIRONMENTAL MANAGEMENT We Protect Hoosiers and Our Environment.

100 N. Senate Avenue • Indianapolis, IN 46204

(800) 451-6027 • (317) 232-8603 • www.idem.IN.gov

Michael R. Pence Thomas W. Easterly Governor Commissioner

To: Interested Parties Date: July 17, 2014 From: Matthew Stuckey, Chief Permits Branch Office of Air Quality Source Name: AC Grain Permit Level: New Source Construction and

Federally Enforceable State Operating Permit (FESOP) Permit Number: 165-33784-00015 Source Location: 225 Briarwood Avenue, Dana, Indiana Type of Action Taken: Initial Permit

Notice of Decision: Approval - Effective Immediately

Please be advised that on behalf of the Commissioner of the Department of Environmental Management, I have issued a decision regarding the matter referenced above. The final decision is available on the IDEM website at: http://www.in.gov/apps/idem/caats/ To view the document, select Search option 3, then enter permit 33784. If you would like to request a paper copy of the permit document, please contact IDEM’s central file room:

Indiana Government Center North, Room 1201 100 North Senate Avenue, MC 50-07 Indianapolis, IN 46204 Phone: 1-800-451-6027 (ext. 4-0965) Fax (317) 232-8659

Pursuant to IC 13-15-5-3, this permit is effective immediately, unless a petition for stay of effectiveness is filed and granted according to IC 13-15-6-3, and may be revoked or modified in accordance with the provisions of IC 13-15-7-1.

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An Equal Opportunity Employer

Recycled Paper

If you wish to challenge this decision, IC 4-21.5-3 and IC 13-15-6-1 require that you file a petition for administrative review. This petition may include a request for stay of effectiveness and must be submitted to the Office of Environmental Adjudication, 100 North Senate Avenue, Government Center North, Suite N 501E, Indianapolis, IN 46204, within eighteen (18) calendar days of the mailing of this notice. The filing of a petition for administrative review is complete on the earliest of the following dates that apply to the filing: (1) the date the document is delivered to the Office of Environmental Adjudication (OEA); (2) the date of the postmark on the envelope containing the document, if the document is mailed to

OEA by U.S. mail; or (3) The date on which the document is deposited with a private carrier, as shown by receipt issued

by the carrier, if the document is sent to the OEA by private carrier. The petition must include facts demonstrating that you are either the applicant, a person aggrieved or adversely affected by the decision or otherwise entitled to review by law. Please identify the permit, decision, or other order for which you seek review by permit number, name of the applicant, location, date of this notice and all of the following: (1) the name and address of the person making the request; (2) the interest of the person making the request; (3) identification of any persons represented by the person making the request; (4) the reasons, with particularity, for the request; (5) the issues, with particularity, proposed for considerations at any hearing; and (6) identification of the terms and conditions which, in the judgment of the person making the

request, would be appropriate in the case in question to satisfy the requirements of the law governing documents of the type issued by the Commissioner.

If you have technical questions regarding the enclosed documents, please contact the Office of Air Quality, Permits Branch at (317) 233-0178. Callers from within Indiana may call toll-free at 1-800-451-6027, ext. 3-0178.

Enclosures Final-Permit 4/4/14

Attachment A to Federally Enforceable Source Operating Permit (FESOP)

Source Description and Location

Source Name: AC Grain Source Location: 225 Briarwood Avenue, Dana, Indiana 47847 County: Vermillion SIC Code: 5153 Operation Permit No.: F165-33784-00015 Permit Reviewer: APT

PART 60—STANDARDS OF PERFORMANCE FOR NEW STATIONARY SOURCES

Subpart DD—Standards of Performance for Grain Elevators

Source: 43 FR 34347, Aug. 3, 1978, unless otherwise noted.

§ 60.300 Applicability and designation of affected facility.

(a) The provisions of this subpart apply to each affected facility at any grain terminal elevator or any grain storage elevator, except as provided under §60.304(b). The affected facilities are 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.

(b) Any facility under paragraph (a) of this section which commences construction, modification, or reconstruction after August 3, 1978, is subject to the requirements of this part.

[43 FR 34347, Aug. 3, 1978, as amended at 52 FR 42434, Nov. 5, 1988]

§ 60.301 Definitions.

As used in this subpart, all terms not defined herein shall have the meaning given them in the Act and in subpart A of this part.

(a) Grain means corn, wheat, sorghum, rice, rye, oats, barley, and soybeans.

(b) Grain elevator means any plant or installation at which grain is unloaded, handled, cleaned, dried, stored, or loaded.

(c) Grain terminal elevator means any grain elevator which has a permanent storage capacity of more than 88,100 m3 (ca. 2.5 million U.S. bushels), except those located at animal food manufacturers, pet food manufacturers, cereal manufacturers, breweries, and livestock feedlots.

(d) Permanent storage capacity means grain storage capacity which is inside a building, bin, or silo.

(e) Railcar means railroad hopper car or boxcar.

(f) Grain storage elevator means any grain elevator located at any wheat flour mill, wet corn mill, dry corn mill (human consumption), rice mill, or soybean oil extraction plant which has a permanent grain storage capacity of 35,200 m3 (ca. 1 million bushels).

(g) Process emission means the particulate matter which is collected by a capture system.

(h) Fugitive emission means the particulate matter which is not collected by a capture system and is released directly into the atmosphere from an affected facility at a grain elevator.

http://ecfr.gpoaccess.gov/cgi/t/text/text-idx?c=ecfr;sid=46398c81279a7316dbbc40ceb9f961c2;rgn=div5;view=text;node=40%3A6.0.1.1.1;idno=40;cc=ecfr

of 3 Attachment A to FESOP No.: F165-33784-00015 (i) Capture system means the equipment such as sheds, hoods, ducts, fans, dampers, etc. used to collect particulate matter generated by an affected facility at a grain elevator.

(j) Grain unloading station means that portion of a grain elevator where the grain is transferred from a truck, railcar, barge, or ship to a receiving hopper.

(k) Grain loading station means that portion of a grain elevator where the grain is transferred from the elevator to a truck, railcar, barge, or ship.

(l) Grain handling operations include bucket elevators or legs (excluding legs used to unload barges or ships), scale hoppers and surge bins (garners), turn heads, scalpers, cleaners, trippers, and the headhouse and other such structures.

(m) Column dryer means any equipment used to reduce the moisture content of grain in which the grain flows from the top to the bottom in one or more continuous packed columns between two perforated metal sheets.

(n) Rack dryer means any equipment used to reduce the moisture content of grain in which the grain flows from the top to the bottom in a cascading flow around rows of baffles (racks).

(o) Unloading leg means a device which includes a bucket-type elevator which is used to remove grain from a barge or ship.

[43 FR 34347, Aug. 3, 1978, as amended at 65 FR 61759, Oct. 17, 2000]

§ 60.302 Standard for particulate matter.

(a) 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 this subpart shall cause to be discharged into the atmosphere any gases which exhibit greater than 0 percent opacity from any:

(1) Column dryer with column plate perforation exceeding 2.4 mm diameter (ca. 0.094 inch).

(2) Rack dryer in which exhaust gases pass through a screen filter coarser than 50 mesh.

(b) On and after the date on which the performance test required to be conducted by §60.8 is completed, no owner or operator subject to the provisions of this subpart shall cause to be discharged into the atmosphere from any affected facility except a grain dryer any process emission which:

(1) Contains particulate matter in excess of 0.023 g/dscm (ca. 0.01 gr/dscf).

(2) Exhibits greater than 0 percent opacity.

(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 this subpart shall cause to be discharged into the atmosphere any fugitive emission from:

(1) Any individual truck unloading station, railcar unloading station, or railcar loading station, which exhibits greater than 5 percent opacity.

(2) Any grain handling operation which exhibits greater than 0 percent opacity.

(3) Any truck loading station which exhibits greater than 10 percent opacity.

(4) Any barge or ship loading station which exhibits greater than 20 percent opacity.

of 3 Attachment A to FESOP No.: F165-33784-00015 (d) The owner or operator of any barge or ship unloading station shall operate as follows:

(1) The unloading leg shall be enclosed from the top (including the receiving hopper) to the center line of the bottom pulley and ventilation to a control device shall be maintained on both sides of the leg and the grain receiving hopper.

(2) The total rate of air ventilated shall be at least 32.1 actual cubic meters per cubic meter of grain handling capacity (ca. 40 ft3 /bu).

(3) Rather than meet the requirements of paragraphs (d)(1) and (2) of this section the owner or operator may use other methods of emission control if it is demonstrated to the Administrator's satisfaction that they would reduce emissions of particulate matter to the same level or less.

§ 60.303 Test methods and procedures.

(a) In conducting the performance tests required in §60.8, the owner or operator shall use as reference methods and procedures the test methods in appendix A of this part or other methods and procedures as specified in this section, except as provided in §60.8(b). Acceptable alternative methods and procedures are given in paragraph (c) of this section.

(b) The owner or operator shall determine compliance with the particulate matter standards in §60.302 as follows:

(1) Method 5 shall be used to determine the particulate matter concentration and the volumetric flow rate of the effluent gas. The sampling time and sample volume for each run shall be at least 60 minutes and 1.70 dscm (60 dscf). The probe and filter holder shall be operated without heaters.

(2) Method 2 shall be used to determine the ventilation volumetric flow rate.

(3) Method 9 and the procedures in §60.11 shall be used to determine opacity.

(c) The owner or operator may use the following as alternatives to the reference methods and procedures specified in this section:

(1) For Method 5, Method 17 may be used.

[54 FR 6674, Feb. 14, 1989]

§ 60.304 Modifications.

(a) The factor 6.5 shall be used in place of “annual asset guidelines repair allowance percentage,” to determine whether a capital expenditure as defined by §60.2 has been made to an existing facility.

(b) The following physical changes or changes in the method of operation shall not by themselves be considered a modification of any existing facility:

(1) The addition of gravity loadout spouts to existing grain storage or grain transfer bins.

(2) The installation of automatic grain weighing scales.

(3) Replacement of motor and drive units driving existing grain handling equipment.

(4) The installation of permanent storage capacity with no increase in hourly grain handling capacity.

Indiana Department of Environmental Management Office of Air Quality

Addendum to the Technical Support Document (ATSD) for a

PBR Transitioning to a Federally Enforceable State Operating Permit (FESOP) with New Source Review (NSR)

Source Background and Description


On June 13, 2014, the Office of Air Quality (OAQ) had a notice published in the Daily Clintonian, Clinton, Indiana, stating that AC Grain had applied for a PBR Transitioning to a Federally Enforceable State Operating Permit (FESOP) with New Source Review (NSR) to construct and operate new emission units at an existing stationary grain elevator and transition from operating under 326 IAC 2-11-3 Permit By Rule for Grain Elevators to a FESOP. The notice also stated that the OAQ proposed to issue a FESOP for this operation and provided information on how the public could review the proposed permit and other documentation. Finally, the notice informed interested parties that there was a period of thirty (30) days to provide comments on whether or not this permit should be issued as proposed.

Comments and Responses On July 7, 2014, Eric Olson of U.S. Compliance Corporation on behalf of AC Grain submitted comments to IDEM, OAQ on the draft FESOP. The Technical Support Document (TSD) is used by IDEM, OAQ for historical purposes. IDEM, OAQ does not make any changes to the original TSD, but the permit will have the updated changes. The comments and revised permit language are provided below with deleted language as struck and new language bolded. Comment 1: Based on the attached memo (shown below this comment), the only units that should be subject to NSPS, Subpart DD (and thus testing requirements) are the ones constructed during or after the facility capacity exceeded the applicability threshold for the NSPS. Please remove all units not subject to the rule from Section E.1 of the permit. Memo Attachment: Determination Detail Control Number: DD02 Category: NSPS EPA Office: DSSE Date: 04/13/1982 Title: Addition of Storage Capacity Recipient: Lambert, Dean A. Author: Reich, Edward E. Subparts: Part 60, A - General Provisions Part 60, DD - Grain Elevators

AC Grain Page 2 of 4 Dana, Indiana ATSD for FESOP No.: F165-33784-00015 Permit Reviewer: APT References: 60.14 60.2 60.300 60.301(c) 60.301(f) 60.304(b) Abstract: See below. Determination available in abstract form only. Included under "Letter" field to facilitate database word searching. Letter: Would the addition of 800,000 bushels of storage capacity bring an existing 800,000 bushel grain storage elevator under Subpart DD? If an expansion project would bring the permanent storage capacity of a grain elevator above the one mm bushel cutoff, the standard would apply to any affected facilities that are constructed or modified as part of the project or any future project.

Response to Comment 1: IDEM agrees with the recommended changes, based on the provided EPA guidance. The permit has been revised as follows: SECTION E.1 EMISSIONS UNIT OPERATION CONDITIONS

Emissions Unit Description: (a) One (1) open grain receiving operation, identified as EU101, constructed in 1995, controlled by

baghouse CE01, with emissions exhausted through vent VE01 and consisting of the following:

(1) One (1) underground truck dump pit, identified as Dump Pit 1, with a maximum capacity of 550 tons/hr, constructed in 1995, equipped with baghouse filter control with emissions exhausted to the atmosphere.

(2) One (1) underground truck dump pit, identified as Pit 2 (auger), with a maximum capacity of

300 tons/hr, constructed in 1995, equipped with baghouse filter control with emissions exhausted to the atmosphere.

(b) One (1) grain load out operation, identified as EU103, constructed in 1995, with emissions venting

without control and consisting of the following:

(1) Two (2) load out stations, identified as load out 1 and load out 2, with a combined maximum capacity of 166 tons/hr constructed in 1995.

(c) One (1) completely enclosed belt conveyor system, identified as EU105, with emissions exhausted to

the atmosphere, with maximum throughput of 675 tons/hr and consisting of the following:

(1) Ten (10) enclosed belt conveyors constructed prior to 1995, with a combined maximum throughput of 675 tons/hr.

(d) One (1) completely enclosed bucket conveyor system, identified as EU106, with emissions exhausted

to the atmosphere, with maximum throughput of 675 tons/hr and consisting of the following:

(1) Seven (7) enclosed bucket conveyors constructed prior to 1995, with a combined maximum throughput of 675 tons/hr.

AC Grain Page 3 of 4 Dana, Indiana ATSD for FESOP No.: F165-33784-00015 Permit Reviewer: APT

(e) One (1) completely enclosed drag conveyor system, identified as EU107, with emissions exhausted to

the atmosphere, with maximum throughput of 675 tons/hr and consisting of the following:

(1) Seven (7) enclosed drag conveyors constructed prior to 1995, with a combined maximum throughput of 675 tons/hr

(f) One (1) completely enclosed grain auger system, identified as EU108, with emissions exhausted to the

atmosphere, with maximum throughput of 100 tons/hr and consisting of the following:

(1) One (1) enclosed auger constructed prior to 1995, with a combined maximum throughput of 100 tons/hr.

(g) One (1) completely enclosed storage silo, identified as EU109, with emissions exhausted to the

atmosphere, storage capacity of 90,000 bushels.

(1) Two (2) enclosed storage silos, constructed in 1975, with a combined maximum capacity of 90,000 bushels.

(h) One (1) completely enclosed storage silo, identified as EU110, with emissions exhausted to the

atmosphere, storage capacity of 645,000 bushels.

(1) Six (6) enclosed storage silos, constructed in 1995, with a combined maximum capacity of 645,000 bushels

(i) One (1) column grain dryer, natural gas-fired, identified as EU112, constructed in 1995, with a

maximum heat input capacity of 31.0 MMBtu/hr and a maximum throughput rate of 75 tons/hr. The dryer is loaded by the Dryer Wet Leg and emptied by the Dryer Dry Leg.

(j) One (1) grain receiving operation, identified as EU102, constructed in 2013, controlled by baghouses identified as CE02-CE17, with emissions exhausted through vents VE02-VE17 and consisting of the following:

(1) Two (2) underground receiving pits, identified as Pit 1 and Pit 2, with a combined maximum

capacity of 1250 tons/hr, constructed in 2013.

(k) One (1) grain load out operation, identified as EU104, constructed in 2013, with emissions controlled by baghouses CE18-CE19, with emissions exhausting through VE18-VE19.

(1) Two (2) load out stations, identified as load out 1 and load out 2, with a combined maximum

capacity of 1500 tons/hr constructed in 2013.

(l) One (1) enclosed storage warehouse, identified as EU111, with emissions exhausted to the atmosphere, storage capacity of 9,500,000 bushels.

(1) One (1) enclosed storage warehouse, constructed in September 2013, with a combined

capacity of 9,500,000 bushels (m) One (1) column grain dryer, natural gas-fired, identified as EU113, constructed in September 2013,

with a maximum heat input capacity of 108.0 MMBtu/hr and a maximum throughput rate of 250 tons/hr. The dryer is loaded by the bucket elevator wet leg and emptied by the bucket elevator dry leg.

(The information describing the process contained in this emissions unit description box is descriptive information and does not constitute enforceable conditions.)

* * *

AC Grain Page 4 of 4 Dana, Indiana ATSD for FESOP No.: F165-33784-00015 Permit Reviewer: APT E.1.2 Standards of Performance for Grain Elevators [40 CFR Part 60, Subpart DD] [326 IAC 12]

Pursuant to 40 CFR Part 60, Subpart DD, the Permittee shall comply with the provisions of Standards of Performance for Grain Elevators (included as Attachment A), which are incorporated by reference as 326 IAC 12, for the receiving identified as (EU101 and EU102) (Pit 1 and Pit 2), headhouse and grain handling processes (EU105-EU108), the grain dryers identified as (EU112-EU113), the enclosed storage warehouse, identified as EU111, and all the load-out facilities (EU102 - EU103): facility identified as EU104 (load out 1 and load out 2):

***

IDEM Contact (a) Questions regarding this proposed FESOP can be directed to Angela Taylor at the Indiana

Department Environmental Management, Office of Air Quality, Permits Branch, 100 North Senate Avenue, MC 61-53 IGCN 1003, Indianapolis, Indiana 46204-2251 or by telephone at (317) 234-5329 or toll free at 1-800-451-6027 extension (4-5329).

(b) A copy of the permit is available on the Internet at: http://www.in.gov/ai/appfiles/idem-caats/ (c) For additional information about air permits and how the public and interested parties can

participate, refer to the IDEM Permit Guide on the Internet at: http://www.in.gov/idem/5881.htm; and the Citizens' Guide to IDEM on the Internet at: http://www.in.gov/idem/6900.htm.

http://www.in.gov/ai/appfiles/idem-caats/

http://www.in.gov/idem/5881.htm

http://www.in.gov/idem/6900.htm

Indiana Department of Environmental Management

Office of Air Quality Technical Support Document (TSD) for a PBR Transitioning to a Federally

Enforceable State Operating Permit (FESOP) with New Source Review (NSR)

Source Description and Location


On October 16, 2013, the Office of Air Quality (OAQ) received an application from AC Grain related to the construction and operation of new emission units at an existing stationary grain elevator and transition from operating under 326 IAC 2-11-3 Permit By Rule for Grain Elevators to a FESOP.

Existing Approvals This source has been operating under Permit by Rule for Grain Elevators, pursuant to 326 IAC 2-11-3.

County Attainment Status

The source is located in Vermillion County.

Pollutant Designation SO2 Better than national standards. CO Unclassifiable or attainment effective November 15, 1990. O3 Unclassifiable or attainment effective July 20, 2012, for the 2008 8-hour ozone

standard.1 PM2.5 Unclassifiable or attainment effective April 5, 2005, for the annual PM2.5 standard. PM2.5 Unclassifiable or attainment effective December 13, 2009, for the 24-hour PM2.5

standard. PM10 Attainment effective October 27, 1997, for the part of Clinton Township that includes

sections 15, 16, 21, 22, 27, 28, 33, and 34. Unclassifiable effective November 15, 1990, for the remainder of Vermillion County.

NO2 Cannot be classified or better than national standards. Pb Unclassifiable or attainment effective December 31, 2011.

1Unclassifiable or attainment effective October 18, 2000, for the 1-hour ozone standard which was revoked effective June 15, 2005.

(a) Ozone Standards

Volatile organic compounds (VOC) and Nitrogen Oxides (NOx) are regulated under the Clean Air Act (CAA) for the purposes of attaining and maintaining the National Ambient Air Quality Standards (NAAQS) for ozone. Therefore, VOC and NOx emissions are considered when evaluating the rule applicability relating to ozone. Vermillion County has been designated as attainment or unclassifiable for ozone. Therefore, VOC and NOx emissions were reviewed pursuant to the requirements for Prevention of Significant Deterioration (PSD), 326 IAC 2-2.

AC Grain Page 2 of 9 Dana, Indiana TSD for FESOP No.: F165-33784-00015 Permit Reviewer: APT

(b) PM2.5 Vermillion County has been classified as attainment for PM2.5. On May 8, 2008, U.S. EPA promulgated the requirements for Prevention of Significant Deterioration (PSD) for PM2.5 emissions. These rules became effective on July 15, 2008. On May 4, 2011, the air pollution control board issued an emergency rule establishing the direct PM2.5 significant level at ten (10) tons per year. This rule became effective, June 28, 2011. Therefore, direct PM2.5, SO2, and NOx emissions were reviewed pursuant to the requirements for Prevention of Significant Deterioration (PSD), 326 IAC 2-2. See the State Rule Applicability – Entire Source section.

(c) Other Criteria Pollutants

Vermillion County has been classified as attainment or unclassifiable in Indiana for all other criteria pollutants. Therefore, these emissions were reviewed pursuant to the requirements for Prevention of Significant Deterioration (PSD), 326 IAC 2-2.

Fugitive Emissions

This type of operation is not one of the twenty-eight (28) listed source categories under 326 IAC 2-2, 326 IAC 2-3, or 326 IAC 2-7; however, there is an applicable New Source Performance Standard that was in effect on August 7, 1980. Therefore, fugitive emissions are counted toward the determination of PSD, Emission Offset, and Part 70 Permit applicability.

Background and Description of Permitted Emission Units and New Source Review The Office of Air Quality (OAQ) has reviewed an application, submitted by AC Grain on October 16, 2013, relating to the construction and operation of new emission units and the continued operation of an existing stationary grain elevator source. Due to the addition of new equipment and increased processing throughput, this source is no longer eligible to operate under the provisions of 326 IAC 2-11 (Permit by Rule). The source consists of the following permitted emission units: (a) One (1) open grain receiving operation, identified as EU101, constructed in 1995, controlled by

baghouse CE01, with emissions exhausted through vent VE01 and consisting of the following:

(1) One (1) underground truck dump pit, identified as Dump Pit 1, with a maximum capacity of 550 tons/hr, constructed in 1995, equipped with baghouse filter control with emissions exhausted to the atmosphere.

(2) One (1) underground truck dump pit, identified as Pit 2 (auger), with a maximum capacity

of 300 tons/hr, constructed in 1995, equipped with baghouse filter control with emissions exhausted to the atmosphere.

(b) One (1) grain load out operation, identified as EU103, constructed in 1995, with emissions venting

without control and consisting of the following:


(c) One (1) completely enclosed belt conveyor system, identified as EU105, with emissions

exhausted to the atmosphere, with maximum throughput of 675 tons/hr and consisting of the following:

(1) Ten (10) enclosed belt conveyors constructed prior to 1995, with a combined maximum

throughput of 675 tons/hr.

(d) One (1) completely enclosed bucket conveyor system, identified as EU106, with emissions exhausted to the atmosphere, with maximum throughput of 675 tons/hr and consisting of the following:


(1) Seven (7) enclosed bucket conveyors constructed prior to 1995, with a combined maximum throughput of 675 tons/hr.

(e) One (1) completely enclosed drag conveyor system, identified as EU107, with emissions

exhausted to the atmosphere, with maximum throughput of 675 tons/hr and consisting of the following:

(1) Seven (7) enclosed drag conveyors constructed prior to 1995, with a combined maximum

throughput of 675 tons/hr

(f) One (1) completely enclosed grain auger system, identified as EU108, with emissions exhausted to the atmosphere, with maximum throughput of 100 tons/hr and consisting of the following:

(1) One (1) enclosed auger constructed prior to 1995, with a combined maximum throughput

of 100 tons/hr

(g) One (1) completely enclosed storage silo, identified as EU109, with emissions exhausted to the atmosphere, storage capacity of 90,000 bushels.

(1) Two (2) enclosed storage silos, constructed in 1975, with a combined maximum capacity

of 90,000 bushels.

(h) One (1) completely enclosed storage silo, identified as EU110, with emissions exhausted to the atmosphere, storage capacity of 645,000 bushels.

(1) Six (6) enclosed storage silos, constructed in 1995, with a combined maximum capacity of

645,000 bushels (i) One (1) column grain dryer, natural gas-fired, identified as EU112, constructed in 1995, with a

maximum heat input capacity of 31.0 MMBtu/hr and a maximum throughput rate of 75 tons/hr. The dryer is loaded by the Dryer Wet Leg and emptied by the Dryer Dry Leg.

The following is a list of the new emission units and pollution control devices:

(j) One (1) grain receiving operation, identified as EU102, constructed in 2013, controlled by

baghouses identified as CE02-CE17, with emissions exhausted through vents VE02-VE17 and consisting of the following:

(1) Two (2) underground receiving pits, identified as Pit 1 and Pit 2, with a combined

maximum capacity of 1250 tons/hr, constructed in 2013.

(k) One (1) grain load out operation, identified as EU104, constructed in 2013, with emissions

controlled by baghouses CE18-CE19, with emissions exhausting through VE18-VE19.


(l) One (1) enclosed storage warehouse, identified as EU111, with emissions exhausted to the

atmosphere, storage capacity of 9,500,000 bushels.

(1) One (1) enclosed storage warehouse, constructed in September 2013, with a combined capacity of 9,500,000 bushels

(m) One (1) column grain dryer, natural gas-fired, identified as EU113, constructed in September

2013, with a maximum heat input capacity of 108.0 MMBtu/hr and a maximum throughput rate of 250 tons/hr. The dryer is loaded by the bucket elevator wet leg and emptied by the bucket elevator dry leg.

This source is subject to the New Source Performance Standards for Grain Elevators (40 CFR 60, Subpart DD).


Unpermitted Emission Units and Pollution Control Equipment The source consists of the following unpermitted emission units: (a) One (1) grain receiving operation, identified as EU102, constructed in 2013, controlled by

baghouses identified as CE02-CE17, with emissions exhausted through vents VE02-VE17 and consisting of the following:

(1) Two (2) underground receiving pits, identified as Pit 1 and Pit 2, with a combined

maximum capacity of 1250 tons/hr, constructed in 2013.

(b) One (1) grain load out operation, identified as EU104, constructed in 2013, with emissions controlled by baghouses CE18-CE19, with emissions exhausting through VE18-VE19.

(1) Two (2) load out stations, identified as load out 1 and load out 2, with a combined

maximum capacity of 1500 tons/hr constructed in 2013.

(c) One (1) enclosed storage warehouse, identified as EU111, with emissions exhausted to the atmosphere, storage capacity of 9,500,000 bushels.

(1) One (1) enclosed storage warehouse, constructed in September 2013, with a combined

capacity of 9,500,000 bushels (d) One (1) column grain dryer, natural gas-fired, identified as EU113, constructed in September

2013, with a maximum heat input capacity of 108.0 MMBtu/hr and a maximum throughput rate of 250 tons/hr. The dryer is loaded by the bucket elevator wet leg and emptied by the bucket elevator dry leg.

Enforcement Issues

IDEM is aware that equipment has been constructed and operated prior to receipt of the proper permit. IDEM is reviewing this matter and will take the appropriate action. This proposed approval is intended to satisfy the requirements of the construction permit rules.

Emission Calculations See Appendix A of this TSD for detailed emission calculations.

Permit Level Determination – FESOP The following table reflects the unlimited potential to emit (PTE) of the entire source before controls. Control equipment is not considered federally enforceable until it has been required in a federally enforceable permit.

Pollutant Potential To Emit (tons/year) PM > 250

PM10(1) < 100

PM2.5(1) < 100

SO2 < 100 NOx < 100 VOC < 100 CO < 100

GHG as CO2e < 100,000 (1) Under the Part 70 Permit program (40 CFR 70), particulate matter with an aerodynamic

diameter less than or equal to a nominal 10 micrometers (PM10) and particulate matter with an aerodynamic diameter less than or equal to a nominal 2.5 micrometers (PM2.5), not particulate matter (PM), are each considered as a "regulated air pollutant".


HAPs Potential To Emit (tons/year) Single HAP < 10

TOTAL HAPs < 25 (a) The PTE of all regulated criteria pollutants are less than one hundred (100) tons per year.

However, the source has requested to be issued a Federally Enforceable State Operating Permit (FESOP) (326 IAC 2-8).

(b) The potential to emit (PTE) (as defined in 326 IAC 2-7-1(29)) of any single HAP is less than ten

(10) tons per year and the PTE of a combination of HAPs is less than twenty-five (25) tons per year. Therefore, this source is an area source under Section 112 of the Clean Air Act (CAA).

(c) The potential to emit (PTE) (as defined in 326 IAC 2-7-1(29)) greenhouse gases (GHGs) is less

than the Title V subject-to-regulation threshold of one hundred thousand (100,000) tons of CO2 equivalent (CO2e) emissions per year.

PTE of the Entire Source After Issuance of the FESOP

The table below summarizes the potential to emit of the entire source after issuance of this FESOP, reflecting all limits, of the emission units. Any control equipment is considered federally enforceable only after issuance of this FESOP, and only to the extent that the effect of the control equipment is made practically enforceable in the permit.

Process / Emission Unit Potential To Emit of the Entire Source After Issuance of FESOP (tons/year)

PM PM10* PM2.5* SO2 NOx VOC CO GHG as CO2e**

Total HAPs

Worst Single HAP

EU101 - Receiving 27.56 9.03 1.53 --- --- --- --- --- --- ---

EU102 - Receiving 39.94 13.09 2.22 --- --- --- --- --- --- ---

EU103 - Grain Loadout 1.23 0.18 0.03 --- --- --- --- --- --- ---

EU104 - Grain Loadout 11.10 1.65 0.28 --- --- --- --- --- --- ---

EU105 - 108 - Headhouse 22.88 12.75 2.18 --- --- --- --- --- --- ---

EU109 - EU110 - Grain Tank 4.69 1.18 0.21 --- --- --- --- --- --- ---

EU111 - Grain Warehouse 4.69 1.18 0.21 --- --- --- --- --- --- ---

EU112-113 - Grain Dryer 82.50 20.63 7.50 --- --- --- --- --- --- ---

EU112-113 - Combustion 1.13 4.54 4.54 0.36 59.7 3.28 50.1 55,990 1.13 1.07

Total Non-fugitive emissions 195.7 64.23 18.68 0.36 59.7 3.28 50.1 55,990 1.13 1.07

EU114 - Outside Storage Piles 1.04 0.52 0.08 --- --- --- --- --- --- ---

Roads - Paved Haul Roads 3.73 0.75 0.18 --- --- --- --- --- --- ---

Total Fugitive Emissions 4.76 1.26 0.26 --- --- --- --- --- --- ---

Total PTE of Entire Source 200.5 65.49 18.94 0.36 59.7 3.28 50.1 55,990 1.13 1.07


Process / Emission Unit Potential To Emit of the Entire Source After Issuance of FESOP (tons/year)

PM PM10* PM2.5* SO2 NOx VOC CO GHG as CO2e**

Total HAPs

Worst Single HAP

Title V Major Source Thresholds** NA 100 100 100 100 100 100 100,000 25 10

PSD Major Source Thresholds** 250 250 250 250 250 250 250 100,000 NA NA

negl. = negligible *Under the Part 70 Permit program (40 CFR 70), PM10 and PM2.5, not particulate matter (PM), are each considered as a regulated air pollutant". **The 100,000 CO2e threshold represents the Title V and PSD subject-to-regulation thresholds for GHGs in order to determine whether a source’s emissions are a regulated NSR pollutant under Title V and PSD.

(a) FESOP Status

This existing source is not a Title V major stationary source, because the potential to emit criteria pollutants from the entire source is less than the Title V major source threshold levels. In addition, this existing source is not a major source of HAPs, as defined in 40 CFR 63.41, because the potential to emit HAPs is less than ten (10) tons per year for a single HAP and twenty-five (25) tons per year of total HAPs. Therefore, this source is an area source under Section 112 of the Clean Air Act and is subject to the provisions of 326 IAC 2-8 (FESOP).

(b) PSD Minor Source

This existing source is not a major stationary source, under PSD (326 IAC 2-2), because the potential to emit PM is limited to less than 250 tons per year, the potential to emit all other attainment regulated criteria pollutants are less than 250 tons per year, and this source is not one of the twenty-eight (28) listed source categories, as specified in 326 IAC 2-2-1(ff)(1). The potential to emit greenhouse gases (GHG) is less than the PSD subject-to-regulation threshold of one hundred thousand (100,000) tons of CO2 equivalent (CO2e) emissions per year. Therefore, pursuant to 326 IAC 2-2, the PSD requirements do not apply. In order to render the requirements of 326 IAC 2-2 (Prevention of Significant Deterioration (PSD)) not applicable, the source shall comply with the following:

(a) The source-wide corn/grain throughput shall not exceed 750,000 tons per twelve (12)

consecutive month period, with compliance determined at the end of each month; and

(b) PM emissions before control shall not exceed the following emission limitations:

Process/Emission Unit Description PM Emission Limit (lbs/ton)

Receiving - Hopper truck 0.035 Receiving - Straight truck 0.18 Receiving - Rail 0.032 Grain Cleaning - internal vibrating 0.075 Grain Drying - Column 0.22 Headhouse and Grain Handling (legs, conveyors, belts, distributor, scale, etc.)

0.061

Storage Bin (vent) including silos 0.025

Grain Shipping (loadout) - truck 0.086 Grain Shipping (loadout) - railcar 0.027

Compliance with these limits, shall limit the source-wide total potential to emit of PM to less than 250 tons per 12 consecutive month period and shall render the requirements of 326 IAC 2-2 (Prevention of Significant Deterioration (PSD)) not applicable for PM.


Federal Rule Applicability Determination Compliance Assurance Monitoring (CAM)

Pursuant to 40 CFR 64.2, Compliance Assurance Monitoring (CAM) is not included in the permit, because the unlimited potential to emit of the source is less than the Title V major source thresholds and the source is not required to obtain a Part 70 or Part 71 permit.

New Source Performance Standards (NSPS) 40 CFR 60, Subpart DD - Standards of Performance for Grain Elevators

The provisions of this subpart apply to each affected facility at any grain terminal elevator (permanent storage capacity of 2.5 million bushels) or any grain storage elevator (permanent storage capacity of 1 million bushels) that commenced construction after August 3, 1978. The affected facilities are 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.

This source has a storage capacity greater than 2.5 million bushels (10.5 million), and is a grain elevator that was constructed after August 3, 1978. Therefore, this source is subject to the provisions of this rule. The receiving (EU101 and EU102), headhouse and grain handling processes (EU105-EU108), grain dryers (EU112-EU113), and all load-out facilities (EU102 - EU103) are subject to the New Source Performance Standards for Grain Elevators (40 CFR 60, Subpart DD). Applicable portions of the NSPS are the following:

(a) 40 CFR 60.300 (b) 40 CFR 60.301 (c) 40 CFR 60.302 (d) 40 CFR 60.303 (e) 40 CFR 60.304

The requirements of 40 CFR Part 60, Subpart A – General Provisions, which are incorporated as 326 IAC 12-1, apply to the facilities except as otherwise specified in 40 CFR 60, Subpart DD.

Other NSPS There are no New Source Performance Standards (NSPS) (326 IAC 12 and 40 CFR Part 60) included in the permit for this source.

National Emission Standards for Hazardous Air Pollutants (NESHAP) There are no National Emission Standards for Hazardous Air Pollutants (NESHAPs) (326 IAC 14,

326 IAC 20 and 40 CFR Part 63) included in the permit for this source.

State Rule Applicability Determination 326 IAC 2-8-4 (FESOP)

FESOP applicability is discussed under the PTE of the Entire Source After Issuance of the FESOP section above.

326 IAC 2-2 (Prevention of Significant Deterioration (PSD))

PSD applicability is discussed under the PTE of the Entire Source After Issuance of the FESOP section above.

326 IAC 2-4.1 (Major Sources of Hazardous Air Pollutants (HAP)) This source is not subject to the requirements of 326 IAC 2-4.1, since the unlimited potential to emit of HAPs from the entire source is less than ten (10) tons per year for any single HAP and less than twenty-five (25) tons per year of a combination of HAPs.

AC Grain Page 8 of 9 Dana, Indiana TSD for FESOP No.: F165-33784-00015 Permit Reviewer: APT 326 IAC 2-6 (Emission Reporting)

Pursuant to 326 IAC 2-6-1, this source is not subject to this rule, because it is not required to have an operating permit under 326 IAC 2-7 (Part 70), it is not located in Lake, Porter, or LaPorte County, and it does not emit lead into the ambient air at levels equal to or greater than 5 tons per year. Therefore, 326 IAC 2-6 does not apply.

326 IAC 5-1 (Opacity Limitations)

326 IAC 5-1 (Opacity Limitations) This source is subject to the opacity limitations specified in 326 IAC 5-1-2(1).

326 IAC 6-4 (Fugitive Dust Emissions Limitations)

Pursuant to 326 IAC 6-4 (Fugitive Dust Emissions Limitations), the source shall not allow fugitive dust to escape beyond the property line or boundaries of the property, right-of-way, or easement on which the source is located, in a manner that would violate 326 IAC 6-4.

326 IAC 12 (New Source Performance Standards)

See Federal Rule Applicability Section of this TSD.

State Rule Applicability – Individual Facilities Grain Elevator Terminal Operations 326 IAC 6-3-2 (Particulate Emission Limitations for Manufacturing Processes)

Pursuant to 326 IAC 6-3-2, the particulate matter (PM) from the grain processing operations shall not exceed the following pound per hour limitations:

ID Process Rate

(Tons per hour)

Calculated PM Emission Limit

(lb/hr)

EU101 Grain Receiving Dump Pit #1 550 70.10 Dump Pit #2 300 63.00 EU102 Grain Receiving Pit #1 625 71.66 Pit #2 625 71.66 EU103 Grain Loadout load out #1 83 49.43 load out #2 83 49.43 EU104 Grain Loadout load out #1 750 73.93 load out #2 750 73.93 EU105 Headhouse 675 72.61 EU106 Headhouse 675 72.61 EU107 Headhouse 675 72.61 EU108 Headhouse 100 51.28 EU109 Grain Tank 43 43.18 EU110 Grain Tank 43 43.18 EU111 Grain Warehouse 43 43.18 EU112 Grain Dryer 75 48.43 EU113 Grain Dryer 250 60.96


The pound per hour limitations were calculated with the following equation:

Interpolation and extrapolation of the data for the process weight rate in excess of sixty thousand (60,000) pounds (30 tons) per hour shall be accomplished by use of the equation:

E = 55.0 P0.11 - 40 where E = rate of emission in pounds per hour; and

P = process weight rate in tons per hour

Based on calculations, no control devices are needed to comply with these limits.

Compliance Determination, Monitoring and Testing Requirements There are no compliance determination or monitoring requirements applicable to this source.

Conclusion and Recommendation Unless otherwise stated, information used in this review was derived from the application and additional information submitted by the applicant. An application for the purposes of this review was received on October 16, 2013. Additional information was subsequently received on November 22, 2013, February 12, March 4, March 14, and March 28, 2014. The operation of this source shall be subject to the conditions of the attached proposed New Source Review and FESOP No.: F165-33784-00015. The staff recommends to the Commissioner that this New Source Review and FESOP be approved.

IDEM Contact (a) Questions regarding this proposed permit can be directed to Angela Taylor at the Indiana

Department Environmental Management, Office of Air Quality, Permits Branch, 100 North Senate Avenue, MC 61-53 IGCN 1003, Indianapolis, Indiana 46204-2251 or by telephone at (317) 234-5329 or toll free at 1-800-451-6027 extension 4-5329.

(b) A copy of the findings is available on the Internet at: http://www.in.gov/ai/appfiles/idem-caats/ (c) For additional information about air permits and how the public and interested parties can

participate, refer to the IDEM’s Guide for Citizen Participation and Permit Guide on the Internet at: www.in.gov/idem

http://www.in.gov/ai/appfiles/idem-caats/

http://www.in.gov/idem

Appendix A: Emissions Calculations Page 1 of 6 TSD App A

Emissions SummarySource Name: AC Grain

Source Location: 110 N. Willow Street, Dana, Indiana 47847County: Vermillion

SIC Code: 5153Operation Permit No.: F165-33784-00015

Permit Reviewer: APT

PM PM10 PM2.5 SO2 NOx VOC CO CO2e[1]

Total HAPs

Individual HAP

Non-Fugitive Emissions**

EU101 Grain Receiving 33.07 10.84 1.84 --- --- --- --- --- --- ---

EU102 Grain Receiving (New) 47.93 15.71 2.66 --- --- --- --- --- --- ---

EU103 Grain Loadout 3.87 1.31 0.22 --- --- --- --- --- --- ---

EU104 Grain Loadout (New) 34.83 11.75 1.98 --- --- --- --- --- --- ---

EU105 - 108 27.45 15.30 2.61 --- --- --- --- --- --- ---

EU109 - EU110 5.63 1.42 0.25 --- --- --- --- --- --- ---

EU111 5.63 1.42 0.25 --- --- --- --- --- --- ---

EU112-113 Grain Dryer Emissions (E113 new) 99.00 24.75 9.00 --- --- --- --- --- --- ---

EU112-113 Combustion Emissions (E113 new) 1.13 4.54 4.54 0.36 59.69 3.28 50.14 72,051.52 1.13 1.07

Non-Fugitive Total 258.53 87.02 23.35 0.36 59.69 3.28 50.14 72,051.52 1.13 1.07Fugitive Emissions**

EU114 Outside Storage Piles 11.08 5.52 0.83 --- --- --- --- --- --- ---

Roads Paved Haul Roads 3.73 0.75 0.18 --- --- --- --- --- --- ---

Fugitive Total 14.81 6.26 1.01 --- --- --- --- --- --- ---

Total Non-Fugitive and Fugitive Emissions** 273.34 93.29 24.36 0.36 59.69 3.28 50.14 72051.52 1.13 1.07

PTE of new emission units only 138.77 44.77 12.92 0.28 46.38 2.55 38.96 72,051.52 0.88 0.83Title V Major Threshold Level NA 100 100 100 100 100 100 100,000 25 10

PSD Major Threshold Level 250 250 250 250 250 250 250 NA NA NA[1] An additional 451,794 tons/yr of CO2e is emitted from Valero's fermentation process; greenhouse gas emissions from biogenic processes are currently exempt from GHG regulations

PM PM10 PM2.5 SO2 NOx VOC CO CO2e[1]

Total HAPs

Individual HAP

Non-Fugitive Emissions**

EU101 Grain Receiving 27.56 9.03 1.53 --- --- --- --- --- --- ---

EU102 Grain Receiving (New) 39.94 13.09 2.22 --- --- --- --- --- --- ---

EU103 Grain Loadout 1.23 0.18 0.03 --- --- --- --- --- --- ---

EU104 Grain Loadout (New) 11.10 1.65 0.28 --- --- --- --- --- --- ---

EU105 - 108 22.88 12.75 2.18 --- --- --- --- --- --- ---

EU109 - EU110 4.69 1.18 0.21 --- --- --- --- --- --- ---

EU111 4.69 1.18 0.21 --- --- --- --- --- --- ---

EU112-113 Grain Dryer Emissions 82.50 20.63 7.50 --- --- --- --- --- --- ---

EU112-113 Combustion Emissions 1.13 4.54 4.54 0.36 59.69 3.28 50.14 72,052 1.13 1.07

Non-Fugitive Total 195.72 64.23 18.68 0.36 59.69 3.28 50.14 72051.52 1.13 1.07Fugitive Emissions**

EU114 Outside Storage Piles 1.04 0.52 0.08 --- --- --- --- --- --- ---

Roads Paved Haul Roads 3.73 0.75 0.18 --- --- --- --- --- --- ---

Total Limited Non-Fugitive and Fugitive Emissions** 200.48 65.49 18.94 0.36 59.69 3.28 50.14 72051.52 1.13 1.07

Limited PTE of new emission units only 97.86 29.76 9.98 0.28 46.38 2.55 38.96 72,051.52 0.88 0.83Title V Major Threshold Level NA 100 100 100 100 100 100 100,000 25 10

PSD Major Threshold Level 250 250 250 250 250 250 250 NA NA NA[1] An additional 451,794 tons/yr is emitted from fermentation processes; greenhouse gas emissions from biogenic processes are currently exempt from GHG regulations.*Potential to Emit (PTE) is based on rated capacity at 8,760 hours/year.

Unlimited/Uncontrolled Potential to Emit (tons/year)*

**Since this type of operation is not one of the twenty-eight (28) listed source categories under 326 IAC 2-2, 326 IAC 2-3, or 326 IAC 2-7, and there is no applicable New Source Performance Standard that was in effect on August 7, 1980, fugitive emissions are not counted toward the determination of PSD, Emission Offset, and Part 70 Permit applicability.

Headhouse Emissions

Grain Tank Emissions

Headhouse Emissions

Grain Tank Emissions

Grain Warehouse Emissions (New)

Limited Potential to Emit Summary

Grain Warehouse Emissions (New)

Source Name: AC GrainSource Location: 110 N. Willow Street, Dana, Indiana 47847 Page 2 of 6 TSD App A

County: VermillionSIC Code: 5153

Operation Permit No.: F165-33784-00015Permit Reviewer: APT

Country elevator

Capacity (

Terminal elevator

Capacity tons/yearMax. Capa tons/year

Potential Emissions Source unless otherwise noted: EPA AP-42 Chapter 9.9.1

Maximum Capacity

PM Emission Factor

PM10 Emission

factor

PM2.5 Emission

factor(tons/year) (lb/ton) (lb/ton) (lb/ton) (ton/year) (lbs/hour) (ton/year) (lbs/hour) (ton/year) (lbs/hour) (tons/year) (lbs/hour) (ton/year) (lbs/hour) (ton/year) (lbs/hour)

900,000 (%)Hopper truck 90% 0.035 0.0078 0.0013 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00Straight truck 367,456 90% 0.18 0.059 0.01 33.07 7.55 10.84 2.47 1.84 0.42 3.31 7.55 1.08 2.47 0.18 0.42Rail 90% 0.032 0.0078 0.0013 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00Hopper truck 90% 0.035 0.0078 0.0013 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00Straight truck 532,544 90% 0.18 0.059 0.01 47.93 10.94 15.71 3.59 2.66 0.61 4.79 10.94 1.57 3.59 0.27 0.61Rail 90% 0.032 0.0078 0.0013 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00Truck 90,000 0% 0.086 0.029 0.0049 3.87 0.88 1.31 0.30 0.22 0.05 3.87 0.88 1.31 0.30 0.22 0.05Railcar 0% 0.027 0.0022 0.00037 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00Truck 810,000 90% 0.086 0.029 0.0049 34.83 7.95 11.75 2.68 1.98 0.45 3.48 7.95 1.17 2.68 0.20 0.45Railcar 90% 0.027 0.0022 0.00037 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00

EU105-108 900,000 90% 0.061 0.034 0.0058 27.45 6.27 15.30 3.49 2.61 0.60 2.75 6.27 1.53 3.49 0.26 0.60

-- 0 0% 0.375 0.095 0.0032 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00EU109 -110 450,000 0% 0.025 0.0063 0.0011 5.63 1.28 1.42 0.32 0.25 0.06 5.63 1.28 1.42 0.32 0.25 0.06

EU111 Storage Warehouse (vent) 450,000 0% 0.025 0.0063 0.0011 5.63 1.28 1.42 0.32 0.25 0.06 5.63 1.28 1.42 0.32 0.25 0.06Rack 0 0% 3 0.75 0.13 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00Column 900,000 0% 0.22 0.055 0.02 99.00 22.60 24.75 5.65 9.00 2.05 99.00 22.60 24.75 5.65 9.00 2.05

Total Emissions 257.40 82.49 18.81 128.45 34.25 10.62Source unless otherwise noted: EPA AP-42 Chapter 9.9.1

Estimated Actual EmissionsProportion of Throughput

Actual Throughput

PM Emission

Factor

PM10 Emission

factor

PM2.5 Emission

factor(% throughput) (tons/year) (lb/ton) (lb/ton) (lb/ton) (ton/year) (lbs/hour) (ton/year) (lbs/hour) (ton/year) (lbs/hour) (tons/year) (lbs/hour) (ton/year) (lbs/hour) (ton/year) (lbs/hour)

(%)Hopper truck 0% 0 90% 0.035 0.0078 0.0013 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00Straight truck 100% 306,213 90% 0.18 0.059 0.01 27.56 6.29 9.03 2.06 1.53 0.35 2.76 6.29 0.90 2.06 0.15 0.35Rail 0% 0 90% 0.032 0.0078 0.0013 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00Hopper truck 0% 0 90% 0.035 0.0078 0.0013 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00Straight truck 100% 443,787 90% 0.18 0.059 0.01 39.94 9.12 13.09 2.99 2.22 0.51 3.99 9.12 1.31 2.99 0.22 0.51Rail 0% 0 90% 0.032 0.0078 0.0013 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00Truck 10% 7,500 90% 0.086 0.029 0.0049 0.32 0.07 0.11 0.02 0.02 0.00 0.03 0.07 0.01 0.02 0.00 0.00Railcar 90% 67,500 90% 0.027 0.0022 0.00037 0.91 0.21 0.07 0.02 0.01 0.00 0.09 0.21 0.01 0.02 0.00 0.00Truck 10% 67,500 90% 0.086 0.029 0.0049 2.90 0.66 0.98 0.22 0.17 0.04 0.29 0.66 0.10 0.22 0.02 0.04Railcar 90% 607,500 90% 0.027 0.0022 0.00037 8.20 1.87 0.67 0.15 0.11 0.03 0.82 1.87 0.07 0.15 0.01 0.03

EU105-108 100% 750,000 90% 0.061 0.034 0.0058 22.88 5.22 12.75 2.91 2.18 0.50 2.29 5.22 1.28 2.91 0.22 0.50

-- 0% 0 0% 0.375 0.095 0.0032 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00EU109 - EU110 50% 375,000 0% 0.025 0.0063 0.0011 4.69 1.07 1.18 0.27 0.21 0.05 4.69 1.07 1.18 0.27 0.21 0.05

EU111 50% 375,000 0% 0.025 0.0063 0.0011 4.69 1.07 1.18 0.27 0.21 0.05 4.69 1.07 1.18 0.27 0.21 0.05Rack 0% 0 0% 3 0.75 0.13 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00Rack - self-cleaning screen 0% 0 0% 0.47 0.12

0.00 0.00 0.00 0.00 0.00 0.000.00 0.00 0.00 0.00 0.00 0.00

Column 50% 750,000 0% 0.22 0.055 0.02 82.50 18.84 20.63 4.71 7.50 1.71 82.50 18.84 20.63 4.71 7.50 1.71Total Emissions 194.59 59.69 14.15 102.15 26.66 8.54

Controlled PM2.5 EmissionsUncontrolled PM Uncontrolled PM10

Uncontrolled PM2.5

Controlled PM10 EmissionsUncontrolled

PM2.5Uncontrolled PMUncontrolled

PM10

Controlled PM EmissionsPM Capture /

Control Efficiency

Note: Emission factors are from AP-42, Chapter 9.9.1 - Grain Elevators, Table 9.9.1-1 (04/03), hopper truck (SCC: 3-02-005-52). Assume all the grain is received and loadout by trucks, which is the worst case scenario.

EU101 Receiving

EU103 Grain Loadout

Headhouse and Grain Handling (legs, conveyors, belts, distributor, scale, enclosed cleaners, etc.)Grain Cleaning (internal vibrating)Storage Bin (vent)

EU112-113 Grain Drying

Storage Warehouse (vent)

Controlled PM2.5 Emissions

EU101Receiving (Old @ 34.5k bph) (capacity is Dump pit 1 combined with Pit 2)

Controlled PM Emissions

EU103 Grain Loadout (two stations at 166 tph each)

Emission Unit ID No.

Activity Capture / Control

Efficiency

EU102 Receiving (new @ 50k bph)

30

750,000900,000

Controlled PM10 Emissions

Each activity type (receiving, loadout, etc, except drying) must total the max capacity. If you use multiple methods

within an activty, use the method with the higher emission factor for max capacity =

Receives more than 50 percent of its grain from farmers in the immediate vicinity during

the harvest season.

Largest amount of grain handled in any of the past five years.

Capacity multiplied by 1.2 to account for the possibility of record harvests or other reasons you might handle

more grain than in past years.

Receives grain primarily from other elevators.Maximum amount of grain that could possibly be processed assuming an unlimited supply is

available.Same as capacity.

Air Emissions for Grain ElevatorsTo make sure you are using the correct numbers in the emission calculations below, first determine whether your facility is a country elevator or terminal elevator, as defined by the EPA.

Definition Capacity Maximum CapacityAC Grain

Country elevator

Grain Loadout

EU102 Receiving

EU104 Grain Loadout

EU112 - 113 Grain Drying

EU104

Emission Unit ID No.

Activity

Enter actual throughput for each activity type (receiving, loadout, handling, etc).

Headhouse and Grain Handling (legs, conveyors, belts, distributor, scale, enclosed cleaners, etc.)Grain Cleaning (internal vibrating)Storage Bin (vent)

Emissions Calculations - Natural Gas-Fired Combustion Page 3 of 6 TSD App A

Source Name: AC GrainSource Location: 110 N. Willow Street, Dana, Indiana 47847



Equipment Name MMBtu/hr MMCF/yrEU113 108.00 927.53EU112 31.00 266.24

Total 139.00 1193.76

PM* PM10* PM2.5 SO2 NOx VOC CO1.9 7.6 7.6 0.6 100.0 5.5 84.0

**see belowNew Dryer - EU113 0.88 3.52 3.52 0.28 46.38 2.55 38.96

Existing Dryer - EU112 0.25 1.01 1.01 0.08 13.31 0.73 11.18

1.13 4.54 4.54 0.36 59.69 3.28 50.14*PM emission factor is filterable PM only. PM10 & PM2.5 emission factors are filterable and condensable fractions combined.**Emission Factors for NOx: Uncontrolled = 100, Low NOx Burner = 50, Low NOx Burners/Flue gas recirculation = 32

Benzene Dichlorobenzene Formaldehyde Hexane Toluene2.1E-03 1.2E-03 7.5E-02 1.8E+00 3.4E-03

New Dryer - EU113 9.74E-04 5.57E-04 3.48E-02 8.35E-01 1.58E-03Existing Dryer - EU112 2.80E-04 1.60E-04 9.98E-03 2.40E-01 4.53E-04

1.25E-03 7.16E-04 4.48E-02 1.07E+00 2.03E-03

Lead Cadmium Chromium Manganese Nickel Total Haps5.0E-04 1.1E-03 1.4E-03 3.8E-04 2.1E-03

New Dryer - EU113 2.3E-04 5.1E-04 6.5E-04 1.8E-04 9.7E-04 0.88Existing Dryer - EU112 6.7E-05 1.5E-04 1.9E-04 5.1E-05 2.8E-04 0.25

2.98E-04 6.57E-04 8.36E-04 2.27E-04 1.25E-03 1.13The five highest organic and metal HAPs emission factors are provided above.

CO2 CH4 N2O120000 2.3 2.2

EU113 Potential Emission in tons/yr 55,652 1.1 1.0EU112 Potential Emission in tons/yr 15,974 0 0EU113 - Summed Potential Emissions in tons/yr 55,654EU112 - Summed Potential Emissions in tons/yr 15,975

Total Summed Potential Emissions in tons/yr 71,629CO2e Total in tons/yr based on 11/29/2013 federal GWPs 72,052

New Dryer - EU113 55,982Existing Dryer - EU112 16,069

Methodology

The N2O Emission Factor for uncontrolled is 2.2. The N2O Emission Factor for low Nox burner is 0.64.

Global Warming Potentials (GWP) from Table A-1 of 40 CFR Part 98 Subpart A.

CO2e (tons/yr) based on 11/29/2013 federal GWPs= CO2 Potential Emission ton/yr x CO2 GWP (1) + CH4 Potential Emission ton/yr x CH4 GWP (25) + N2O Potential Emission ton/yr x N2O GWP (298).

MMCF = 1,000,000 Cubic Feet of GasPotential Throughput (MMCF) = Heat Input Capacity (MMBtu/hr) x 8,760 hrs/yr x 1 MMCF/1,020 MMBtuEmission Factors from AP 42, Chapter 1.4, Tables 1.4-1, 1.4-2, and 1.4-3, SCC #1-01-006-01, 1-01-006-04 (AP-42 Supplement D 3/Emission (tons/yr) = Throughput (MMCF/yr) x Emission Factor (lb/MMCF)/2,000 lb/ton

Emission Factors are from AP 42, Table 1.4-2 SCC #1-02-006-02, 1-01-006-02, 1-03-006-02, and 1-03-006-03.

Emission (tons/yr) = Throughput (MMCF/yr) x Emission Factor (lb/MMCF)/2,000 lb/ton

Criteria Pollutants (Emission Factor in lb/MMCF)

MMBtu = 1,000,000 Btu

Total Potential Emission in tons/yr

HAPs - Organics (Emission Factor in lb/MMcf)


HAPs - Metals (Emission Factor in lb/MMcf)


Greenhouse Gas

Emission Factor in lb/MMcf

All emission factors are based on normal firing.

Source Name: AC Grain Page 4 of 6 TSD App A

Source Location: 110 N. Willow Street, Dana, Indiana 47847County: Vermillion

SIC Code: 5153Operation Permit No.: F165-33784-00015

Permit Reviewer: APT

Grain Dryer Emission Calculations

Process Emissions

PM PM10 PM2.5

(tons/hr) (tons/yr) (tons/yr) (lbs/ton) (lbs/ton) (lbs/ton)EU113 250 2190000 0.22 0.055 0.0094EU112 75 657000 0.22 0.055 0.0094

PM PM10 PM2.5

(lbs/hr) (lbs/hr) (lbs/hr)EU113 55 13.75 2.4EU112 16.5 4.125 0.7

PM PM10 PM2.5 PM PM10 PM2.5

(lbs/hr) (lbs/hr) (lbs/hr) (tons/yr) (tons/yr) (tons/yr)EU113EU112

326 IAC 6-3-2 Allowable PM Emission Limit based on E = 55.0 P0.11 - 40PM

(lbs/hr)EU113 60.96EU112 48.43

Emission Unit ID

No.

The hourly particulate PTE is less than the particulate limit under 326 IAC 6-3-2; therefore, no controls are required in order to comply with the provisions of this rule.

Emission factors are from AP-42, Chapter 9.9.1 - Grain Elevators, Table 9.9.1-1 for Column dryers.

Emission Unit ID

No.

Limited PTE

9.42 2.35 0.40

Limited PTE

41.25 10.31 1.76

Emission Unit ID

No.

Unlimited Throughput

Emission Unit ID

No.

375,000

Maximum Throughput

Rate

Annual Throughput

LimitEmission Factor

Uncontrolled PTE

Source Name: AC Grain Page 5 of 6 TSD App ASource Location: 110 N. Willow Street, Dana, Indiana 47847



E= [(k x (sL)^0.91) x (W)^1.02)(1-(P/4N))] AP-42, Section 13.2.1-1, January 2011

Factor Description Source PM Value PM10 Value PM2.5 Value PM Value PM10 Value PM2.5 Value

E = Emission factor (lb/VMT, vehicle miles traveled) Calculation, above 0.17 0.03 0.01 0.60 0.12 0.03k = PM Particle size multiplier (lb/VMT) AP-42, Section 13.2.1 0.011 0.0022 0.00054 0.011 0.0022 0.00054sL = Road surface silt loading (g/m2) AP-42, Section 13.2.1-2 0.60 0.60 0.60 2.40 2.40 2.40P = Number of "wet" days in an averaging period 120 120 120 120 120 120N = Number of days in the averaging period 365 365 365 365 365 365W = Average vehicle weight (ton) 25.0 25.0 25.0 25.0 25.0 25.0

Average Annual Emission Factors

Average Factor

PM 0.28PM10 0.06PM2.5 0.01

Average MilesVehicle No. of Traveled AnnualWeight Trucks per Truck Mileage Controlled* Controlled* Controlled*

Activity (tons) (truck/yr) (miles/truck) (VMT/yr) (lb/yr) (tpy) (tpy) (lb/yr) (tpy) (tpy) (lb/yr) (tpy) (tpy)Grain receiving 25 30,000 0.45 13,500 3,727 1.86 0.93 745 0.37 0.19 183 0.09 -Grain shipping 25 30,000 0.45 13,500 3,727 1.86 0.93 745 0.37 0.19 183 0.09 -Total 3.73 1.86 0.75 0.37 0.18 0.00*Periodic sweeping will be done to provide control (50%) to PM/PM10/PM2.5 emissions.

PM2.5 EmissionsUncontrolled

Paved Roads Emission Calculations

Summer Months Winter Months

UncontrolledPM Emissions PM10 Emissions

Uncontrolled

Source Name: AC Grain Page 6 of 6 TSD App ASource Location: 110 N. Willow Street, Dana, Indiana 47847



Total dust emissions from aggregate storage piles result from several distinct source activities within the storage cycle:

1. Loading of aggregate onto storage piles (batch or continuous drop operations).

2. Equipment traffic in storage area.

3. Wind erosion of pile surfaces and ground areas around piles.

4. Loadout of aggregate for shipment or for return to the process stream (batch or continuous drop operations).

Emission Factor Equation from AP-42 Chapter 13.2.4, 1995:

k x 0.0032 x (U/5)1.3

(M/2)1.4

where:EF = Emission Factor (lbs/ton) PM PM10 PM2.5

k = Particle size multiplier = 0.74 0.35 0.053U = Mean wind speed (mph) = 10M = Material Moisture content (%) = 5

Unlimited PTE Limited PTE


0.0016 0.0008 0.0001 0.0016 0.0008 0.0001


0.73 0.34 0.05 0.61 0.29 0.04

*Assumes all grain received is stored at the grain piles as a worst case scenario; the majority of grain received will be stored within permanent storage silos and tanks.

1. Fugitive Emissions from grain Storage Piles

Storage pile emissions, which result from wind erosion, are determined by the following calculations:

Ef = 1.7 *k * (s/1.5) * (365-p) / 235 * (f/15)PM = 5.67 lb/ac/day

PM10 = 2.84 lb/ac/dayPM2.5 = 0.43 lb/ac/day

where: k (PM) = 1 particle size multiplier (dimensionless)k (PM10) = 0.5 particle size multiplier (dimensionless)

k (PM2.5) = 0.075 particle size multiplier (dimensionless)s = 4.9 % silt content of materialp = 125 days of rain greater than or equal to 0.01 inchesf = 15 % of wind greater than or equal to 12 mph

Storage capacity (SC) of site (tons) = (# acres)*(43560 sqft/acre)*(25 ft high)*(1/40 ton/cuft)Storage capacity (SC) of site (tons) = 272250

PTE of PM (tons/year) = Ef *SC*(40 cuft/ton)*365 day/yr /(2000 lb/ton * 43560 sqft/acre * 25 ft)Controlled

PTE of PM (tons/year) = 10.35 PTE of PM (tons/year) = 1.04PTE of PM10 (tons/year) = 5.18 PTE of PM10 (tons/year) = 0.52PTE of PM2.5 (tons/year) = 0.78 PTE of PM2.5 (tons/year) = 0.08Based conservatively on 10 acres of storage capacity.

PTE (tons/yr)PTE (tons/yr)

900,000Max Throughput (tons/yr)*

EF =

Emission Factors (lb/ton) Emission Factors (lb/ton)

Max Throughput (tons/yr)*750,000



(800) 451-6027 • (317) 232-8603 • www.idem.IN.gov


SENT VIA U.S. MAIL: CONFIRMED DELIVERY AND SIGNATURE REQUESTED TO: Rick Sims

AC Grain 110 N. Willow St.

Dana, IN 47847 DATE: July 17, 2014 FROM: Matt Stuckey, Branch Chief Permits Branch Office of Air Quality SUBJECT: Final Decision New Source Construction and Federally Enforceable State Operating Permit (FESOP) 165-33784-00015 Enclosed is the final decision and supporting materials for the air permit application referenced above. Please note that this packet contains the original, signed, permit documents. The final decision is being sent to you because our records indicate that you are the contact person for this application. However, if you are not the appropriate person within your company to receive this document, please forward it to the correct person. A copy of the final decision and supporting materials has also been sent via standard mail to: Eric Olson, U.S. Compliance Corporation OAQ Permits Branch Interested Parties List If you have technical questions regarding the enclosed documents, please contact the Office of Air Quality, Permits Branch at (317) 233-0178, or toll-free at 1-800-451-6027 (ext. 3-0178), and ask to speak to the permit reviewer who prepared the permit. If you think you have received this document in error, please contact Joanne Smiddie-Brush of my staff at 1-800-451-6027 (ext 3-0185), or via e-mail at [email protected].

Final Applicant Cover letter.dot 6/13/2013


Recycled Paper

mailto:[email protected]



(800) 451-6027 • (317) 232-8603 • www.idem.IN.gov


July 17, 2014 TO: Newport Vermillion County Public Library

From: Matthew Stuckey, Branch Chief Permits Branch Office of Air Quality Subject: Important Information for Display Regarding a Final Determination

Applicant Name: AC Grain Permit Number: 165-33784-00015 You previously received information to make available to the public during the public comment period of a draft permit. Enclosed is a copy of the final decision and supporting materials for the same project. Please place the enclosed information along with the information you previously received. To ensure that your patrons have ample opportunity to review the enclosed permit, we ask that you retain this document for at least 60 days. The applicant is responsible for placing a copy of the application in your library. If the permit application is not on file, or if you have any questions concerning this public review process, please contact Joanne Smiddie-Brush, OAQ Permits Administration Section at 1-800-451-6027, extension 3-0185.

Enclosures Final Library.dot 6/13/2013


Recycled Paper

Mail Code 61-53

IDEM Staff VHAUN 7/17/2014 AC Grain 165-33784-00015 FINAL

AFFIX STAMP HERE IF USED AS CERTIFICATE OF MAILING

Name and address of Sender ►

Indiana Department of Environmental Management Office of Air Quality – Permits Branch 100 N. Senate Indianapolis, IN 46204

Type of Mail:

CERTIFICATE OF MAILING ONLY

Line Article

Number Name, Address, Street and Post Office Address Postage Handing

Charges Act. Value (If Registered)

Insured Value

Due Send if COD

R.R. Fee

S.D. Fee S.H. Fee

Rest. Del. Fee Remarks

1 Rick Sims AC Grain 110 N Willow St Dana IN 47847 (Source CAATS) CONFIRMED DELIVERY 2 Vermillion County Health Department 257 Walnut Street Clinton IN 47842-2342 (Health Department) 3 Newport Vermillion County Library P.O.Box 100, 385 E. Market St Newport IN 47966-0100 (Library) 4 Vermillion County Commissioners P.O. Box 190 Newport IN 47966 (Local Official) 5 J.P. Roehm PO Box 303 Clinton IN 47842 (Affected Party) 6 Dana Town Council PO Box 371 Dana IN 47847 (Local Official) 7 Eric Olson U.S. Compliance Corporation 520 Third Street, Suite 100 Excelsior MN 55331 (Consultant) 8 9 10 11 12 13 14 15 Total number of pieces Listed by Sender

6 Total number of Pieces Received at Post Office

Postmaster, Per (Name of Receiving employee)

The full declaration of value is required on all domestic and international registered mail. The maximum indemnity payable for the reconstruction of nonnegotiable documents under Express Mail document reconstructing insurance is $50,000 per piece subject to a limit of $50, 000 per occurrence. The maximum indemnity payable on Express mil merchandise insurance is $500. The maximum indemnity payable is $25,000 for registered mail, sent with optional postal insurance. See Domestic Mail Manual R900, S913, and S921 for limitations of coverage on inured and COD mail. See International Mail Manual for limitations o coverage on international mail. Special handling charges apply only to Standard Mail (A) and Standard Mail (B) parcels.

FACSIMILIE OF PS Form 3877

Notice of Decision: Approval -Effective Immediatelypermits.air.idem.in.gov/33784f.pdf§ 60.301...

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